6 15 672 https://www.nal.usda.gov/exhibits/speccoll/files/original/4f706fe5003d6b9611eab9a1b015b870.pdf 8e4206a1a60b10f6e6afebd912a223f9 PDF Text Text Item D Number 0575 Author Haber, Paul A. L. ° D Not Scanned Corporate Author RODOrt/ArtlGlO Title Memorandum to Members, from Chairman, Subject: VA Advisory Committee on Health-Related Effects of Herbicides, July 9, 1979 Journal/Book Title Year Month/Day Color El Number of Images ° DeSCrlptOO NOtBS Attachments missing. Thursday, March 28, 2002 Page 5750 of 5780 �JUL9 m DATE TO: UNITED STATES GOVERNMENT Memorandum Members FROM Chairman SUBJ VA Advisory Committee on Health-Related Effects of Herbicides 1. Thank you for your participation in our first Advisory Committee meeting. Your individual contributions made it a very fruitful, productive and intellectually-stimulating experience. It is believed this fine beginning was a most favorable forecast of our future efforts together as we seek to find answers to questions concerning health-related effects of exposure to herbicides used in Vietnam. 2. Enclosed is a copy of the verbatim transcript of the meeting minutes. We would appreciate your looking them over and confirming the accuracy of those portions pertaining to your participation. Any changes should be sent to Mrs. Rennie Williams at the address shown on the attached sheet, or you may call her on (202) 389-2450. Please key your corrections to line and page number. If we do not hear from you before August 1, 1979, we will assume you have no corrections. 3. During the course of the meeting, some of you indicated you have documents, studies, etc., which you would be willing to share with the full committee membership. If you have not already sent them, would you please forward them to Mrs. Williams as soon as it is convenient. 4. You will recall the VA Central Office Ad Hoc Steering Committee on the Toxic Effects of Herbicides referred eleven questions to the Advisory Committee, and there were three unanswered questions received from the audience. The Advisory Committee is responsible for preparing position papers, limited to no more than three pages, double-spaced, addressing each of these questions. In order to accomplish this task, each member has been designated the Coordinator for preparation of a specific paper (see attached list). In addition to your assigned question, please review the entire list and choose other questions to which you would like to respond, place a check mark beside them, and return the list to Mrs. Williams. The respective Coordinator for that particular paper will be notified of your interest and contact you for your input. We would like to have your first draft mailed to Mrs. Williams by August 15. 5. Our next meeting will be in September. Please let us know which of the following three dates would be most convenient for you by returning your response in the envelope provided: (1) September 10; (2) September 17, or (3) September 24, We will advise you of the final date selected. Attachments PAUL A. L. HABER, M. D. Buy U,S. Savings Bonds Regularly on the Payroll Savings Plan VA � Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Alvin L. Young Collection on Agent Orange Description An account of the resource <p style="margin-top: -1em; line-height: 1.2em;">The Alvin L. Young Collection on Agent Orange comprises 120 linear feet and spans the late 1800s to 2005; however, the bulk of the coverage is from the 1960s to the 1980s and there are many undated items. The collection was donated to Special Collections of the National Agricultural Library in 1985 by Dr. Alvin L. Young (1942- ). Dr. Young developed the collection as he conducted extensive research on the military defoliant Agent Orange. The collection is in good condition and includes letters, memoranda, books, reports, press releases, journal and newspaper clippings, field logs and notebooks, newsletters, maps, booklets and pamphlets, photographs, memorabilia, and audiotapes of an interview with Dr. Young.</p> <p>For more about this collection, <a href="/exhibits/speccoll/exhibits/show/alvin-l--young-collection-on-a">view the Agent Orange Exhibit.</a></p> Text A resource consisting primarily of words for reading. Examples include books, letters, dissertations, poems, newspapers, articles, archives of mailing lists. Note that facsimiles or images of texts are still of the genre Text. Box The box containing the original item. 203 Folder The folder containing the original item. 5750 Series The series number of the original item. Series VIII Subseries III Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Creator An entity primarily responsible for making the resource Haber, Paul A. L. Title A name given to the resource Memorandum to Members, from Chairman, Subject: VA Advisory Committee on Health-Related Effects of Herbicides, July 9, 1979 ao_seriesVIII https://www.nal.usda.gov/exhibits/speccoll/files/original/00a05b74cf6b72dc5346713df5cbf713.pdf 4797df5425895601c7d659e869604c78 PDF Text Text lt.mlM.tor 0542, Author Haile ' Clarence L Corporate Author Report/Article Tltlfl Comprehensive Assessment of the Specific Compounds Present in Combustion Processes, Volume I: Pilot Study of Combustion Emissions Variability Journal/Book Title Year Month/Day Color Number of Images ° DBSCriptOn Notes Task 3 Final Re ' P°rt, EPA Contract No. 68-01-5915, MRI Project No. 4901-A(3) Friday, March 08, 2002 Page 5421 of 5427 �United States Environmental Protection Agency Office of Toxic Substances Washington DC 20460 EPA-560/5-83-004 June, 1983 Toxic Substances xvEPA Comprehensive Assessment of the Specific Compounds Present in Combustion Processes Volume I Pilot Study of Combustion Emissions Variability ^^^^TIv~^rr'r- i 4 fr^ \\ ^ 1 L \ i t ' �PILOT STUDY OF INFORMATION OF SPECIFIC COMPOUNDS FROM COMBUSTION SOURCES by Clarence L. Haile and John S. Stanley Midwest Research Institute Robert M. Lucas and Denise K. Melroy Research Triangle Institute Carter P. Nulton Southwest Research Institute and William L. Yauger, Jr. Gulf South Research Institute TASK 3 FINAL REPORT EPA Contract No. 68-01-5915 MRI Project No. 4901-A(3) Prepared for U.S. Environmental Protection Agency Office of Pesticides and Toxic Substances Field Studies Branch 401 M Street, S.W. Washington, D.C. 20460 Attn: Dr. Frederick Kutz, Project Officer Mr. David Redford, Task Manager �DISCLAIMER This document has been reviewed and approved for publication by the Office of Toxic Substances, Office of Pesticides and Toxic Substances, U.S. Environmental Protection Agency. Approval does not signify that the contents necessarily reflect the views and policies of the Environmental Protection Agency, nor does the mention of trade names or commercial products constitute endorsement or recommendation for use. �PREFACE This final report was prepared for the Environmental Protection Agency under EPA Contract No. 68-01-5915, Task 3. The task was directed by Dr. Clarence L. Haile. Substantial portions of the effort were subcontracted to Southwest Research Institute under Dr. Carter P. Nulton and to Gulf South Research Institute under Mr. William L. Yauger, Jr. This work was completed in coordination with statistical design studies conducted by Research Triangle Institute under Dr. Robert M. Lucas. This report was prepared by Dr. Clarence L. Haile and Dr. John S. Stanley with substantial contributions from Dr. Robert M. Lucas, Ms. Denise K. Melroy, Dr. Carter P. Nulton, and Mr. William L. Yauger, Jr. MIDW5ST)RESEARCH,INSTITUTE r E. Going Program Manager Approved: James L. Spigarelli, Director Analytical Chemistry Department June 1983 111 �CONTENTS Preface Figures Tables 1. 2. 3. 4. 5. 6. 7. 8. 9. 10. 11. iii v vi Introduction Summary Recommendations Plant Descriptions Ames Municipal Power Plant, Unit No. 7 Chicago Northwest Incinerator, Unit No. 2 Sampling Methods Flue Gas Plant Background Air Solid and Aqueous Media Continuous Monitoring Process Data Collection Analysis Methods Organics Cadmium Field Test Data Ames Municipal Power Plant, Unit No. 7 Chicago Northwest Incinerator, Unit No. 2 Analytical Results Ames Municipal Power Plant, Unit No. 7 Chicago Northwest Incinerator Analytical Quality Assurance Results Surrogate Compound Recoveries Interlaboratory Comparison Studies Emissions Results Ames Municipal Power Plant, Unit No. 7 Chicago Northwest Incinerator, Unit No. 2 Statistical Summary of Pilot Study Data Overview First Tier Summary Second Tier Summary References 1 3 5 6 6 1 9 9 12 12 1? 15 16 16 31 34 34 42 52 52 83 107 107 107 112 112 112 129 129 129 137 147 Appendix A - TRW Field Test Report for the Ames Municipal Electric System, Unit No. 7 148 Appendix B - TRW Field Test Report for the Chicago Northwest Incinerator, Unit No. 2 242 �FIGURES Number Page 1 Modified Method 5 train for organics sampling 10 2 Locations of flue gas sampling ports on a typical combustion unit 11 3 Sector schemes for sampling bottom ash 14 4 General analytical scheme 18 5 TOC1 chromatogram for Aroclor 1254 23 �TABLES Number 1 PAH Compounds Selected 16 2 Recovery of Selected PAHs and 1,2,3,4-TCDD From Ames Fly Ash. 20 3 TOC1 Analysis Parameters 22 4 HRGC Screening Parameters 24 5 Extract Compositing Scheme for Tier 2 Analyses 25 6 HRGC/MS Parameters Used for Analyses of PCDDs and PCDFs in Composite Chicago NW Flue Gas Outlet Extracts 26 HRGC/MS-SIM Parameters Used for Analysis of PCBs in Composite Flue Gas Outlet Extracts 27 PCB Compounds Used for Determinations in Composite Flue Gas Outlet Extracts 27 Ions Monitored During HRGC/HRMS Confirmatory Analysis of PCDDs and PCDFs in Composite Chicago NW Flue Gas Outlet Extracts 29 PCDD and PCDF Compounds Used for Determinations in Composite Chicago NW Flue Gas Outlet Extracts 29 HRGC/HRMS Parameters Used for Analysis of 2,3,7,8-Tetrachlorodibenzo-£-dioxin in Composite Chicago NW Flue Gas Outlet Extracts 30 Recovery of Cadmium From Fortified Samples of Fly Ash From the Chicago NW Incinerator 33 Recovery of Cadmium From Fortified Samples From the Ames Municipal Power Plant 33 Daily Data Summaries for Flue Gas Sampling, Ames Municipal Power Plant, Unit No. 7 35 Average Process Data for the Ames Municipal Power Plant, Unit No. 7 38 7 8 9 10 11 12 13 14 15 VI �TABLES (continued) Number Page 16 Fuel Combustion During Flue Gas Sampling 40 17 Daily Production and Consumption at Ames Municipal Power Plant, Unit No. 7 41 Heat Content of Fuels Used at the Ames Municipal Power Plant During Sampling Period 43 Daily Data Summaries for Flue Gas Measurements, Chicago Northwest Incinerator, Boiler No. 2 44 Means of the Means for Process Data, All Test Days, Chicago NW Incinerator, Boiler No. 2 46 Weekly Inventories of Refuse and Residue at the Chicago NW Incinerator (All Boilers) 48 Charges Fed to Boiler No. 2 on a Shift Basis Chicago Northwest Incineration Facility 49 TOC1 and Surrogate Recovery Results for the Ames Flue Gas Inlet Samples 53 TOC1 Results and Surrogate Recoveries for the Ames Flue Gas Outlet Samples. 55 TOC1 Results and Surrogate Recoveries for Ames Plant Background Air Particulate Samples 56 TOC1 Results and Surrogate Recoveries for Ames ESP Ash Samples 57 TOC1 Results and Surrogate Recoveries for Ames Bottom Ash Samples 60 28 TOC1 Results and Surrogate Recoveries for Ames Coal Samples . 63 29 TOC1 Results and Surrogate Recoveries for Ames Refuse Derived Fuel Samples 64 TOC1 Results and Surrogate Recoveries for Ames Bottom Ash Hopper Quench Water Influent Samples 67 TOC1 Results and Surrogate Recoveries for Ames Bottom Ash Hopper Quench Overflow Water Samples 68 TOC1 Results and Surrogate Recoveries for Ames Untreated Well Water 71 18 19 20 21 22 23 24 25 26 27 30 31 32 vii �TABLES (continued) Number 33 Page Compounds Quantitated in Samples From the Ames Municipal Power Plant, Unit No. 7 72 Concentrations of Polychlorinated Biphenyl Isomers in Flue Gas Outlet Samples From the Ames Municipal Power Plant, Unit No. 7 77 35 Cadmium Results for Ames - ESP Ash Samples 78 36 Cadmium Results for Ames - Bottom Ash Samples 79 37 Cadmium Results for Ames - Coal Samples 80 38 Cadmium Results for Ames - Refuse-Derived Fuel Samples. . . . 81 39 Cadmium Results for Ames - Flue Gas Outlet Particulates . . . 82 40 TOC1 Results and Surrogate Recoveries for Chicago NW Flue Gas Samples ..... 84 TOC1 Results and Surrogate Recoveries for Chicago NW Plant Background Air Samples 85 TOC1 Results and Surrogate Recoveries for Chicago NW ESP Ash Samples • 86 TOC1 Results and Surrogate Recoveries for Chicago NW Combined Bottom Ash Samples 89 TOC1 Results and Surrogate Recoveries for Chicago NW Refuse Samples 92 TOC1 Results and Surrogate Recoveries for Chicago NW Tap Water Samples 95 Compounds Quantitated in Samples From the Chicago NW Incinerator, Unit No. 2 96 34 41 42 43 44 45 46 47 48 49 Comparison of TOC1 Results From Direct TOC1 Assays Versus Calculated TOC1 From Specific Compounds Identified in Composite Chicago NW Extracts . 98 Concentrations of Polychlorinated Biphenyl Isomers in Flue Gas Outlet Samples From the Chicago Northwest Incinerator Unit No. 1 99 Concentrations of Polychlorodibenzo-o,-dioxins and Furans in Flue Gas From the Chicago Northwest Incinerator and Corresponding Emission Rates 100 viii �TABLES (continued) Number 50 Page Concentrations of 2,3,7,8-Tetrachlorodibenzo-pj-dioxin in flue Gas From the Chicago NW Incinerator 102 Cadmium Concentrations in Fly Ash From Chicago Northwest Incinerator, Unit No. 2 103 Cadmium Concentrations in Combined Bottom Ash From Chicago Northwest Incinerator, Unit No. 2 104 Cadmium Concentrations in Refuse From Chicago Northwest Incinerator 105 Cadmium Concentrations in the Flue Gas Outlet Particulates From Chicago Northwest Incinerator, Unit No. 2 106 55 Summary of Surrogate Recovery Data. . 108 56 Results of Interlaboratory TOC1 Analyses 109 57 Interlaboratory Comparison of Analytical Results for the Extraction and Analysis of Specific Compounds in Four Sets of Quality Assurance Samples 110 Interlaboratory Comparison of the Levels of PCDDs and PCDFs in Composite extracts From the Chicago NW Incinerator . . . Ill Total Organic Chlorine Inputs and Emissions - Ames Municipal Power Plant, Unit No. 7 113 Compounds Quantitated in the Primary Input and Emission Media for the Ames Municipal Power Plant, Unit No. 7 114 Flue Gas Concentrations for PCBs and Emission Rates for the Ames Municipal Power Plant, Unit No. 7. 118 Cadmium Inputs and Emissions - Ames Municipal Power Plant, Unit No. 7 119 Total Organic Chlorine Inputs and Emissions - Chicago Northwest Incinerator, Unit No. 2 120 Compounds Quantitated in Input and Emission Media Chicago NW Incinerator, Unit No. 2 122 Flue Gas Concentrations of PCBs and Emission Rates for the Chicago Northwest Incinerator Unit No. 1 124 51 52 53 54 58 59 60 61 62 63 64 65 IX �TABLES (continued) Number 66 Page Concentrations of Polychlorodibenzo-£-dioxins and Furans in Flue Gas From the Chicago Northwest Incinerator and Corresponding Emission Rates 125 67 Concentrations of 2,3,7,8-Tetrachlorodibenzo-£-dioxin in Flue Gas From the Chicago NW Incinerator and Corresponding Emission Rates 127 68 Cadmium Input and Emissions From Chicago Northwest Incinerator, Unit No. 2 128 Summary Statistics for Total Organic Chlorine Concentration Data From Ames, Iowa 132 Summary Statistics for Total Organic Chlorine Concentration Data From Chicago NW 133 Summary of Surrogate Compounds Percent Recovery for Specimens From Ames, Iowa 134 69 70 71 72 Summary of Surrogate Compound Percent Recovery for Specimens From Chicago, NW 135 73 Validity of Confidence Statements for Selected Levels of Bias 136 74 Summary of Coefficient of Variation for the Pilot Study. . . 138 75 Summary of Statistics for Compounds Quantitated in Primary Input Media at Ames, Iowa . 140 76 Summary Statistics for Compounds Quantitated in Gaseous Emissions at Ames, Iowa 141 Summary Statistics for Compounds Quantitated in Solid Emissions at Ames, Iowa 142 77 78 Summary of Total Input and Emissions From Ames, Iowa . . . . 143 79 Summary of Statistics for Compounds Quantitated in Gaseous Emissions From Chicago 144 Summary of Flue Gas Emissions of Polychlorinated Biphenyl Isomers from Ames, Iowa 145 80 81 Summary of Flue Gas Emissions of Polychlorinated Biphenyls, Dibenzo-£-dioxins, and dibenzofurans from Chicago NW . . . 146 �SECTION 1 INTRODUCTION This pilot study was conducted as a prelude to a nationwide survey of organic emissions from major stationary combustion sources. The primary objectives of the pilot study were to obtain data on the variability of organic emissions from two such sources and to evaluate the sampling and analysis methods. These data are used to construct the survey design for the nationwide survey. The compounds of interest are polynuclear aromatic hydrocarbons (PAHs) and chlorinated aromatic compounds, including polychlorinated biphenyls (PCBs), polychlorinated dibenzo-p_-dioxins (PCDDs), and polychlorinated dibenzofurans (PCDFs). Of particular interest is 2,3,7,8-tetrachlorodibenzop_-dioxin (TCDD). In addition, total cadmium was also determined in special samples from both plants to meet special Environmental Protection Agency (EPA) needs. Midwest Research Institute (MRI) was responsible for overall task management, specifying the sampling and analysis methods, assisting in the collection of samples, receiving samples at the plant sites, shipping the samples to the analysis laboratories, and conducting all sample analyses. MRI was assisted in this effort by two subcontractors. Southwest Research Institute (SwRI) assisted in sampling, exercised sample control, and conducted most of the analyses for samples from the first plant. Gas chromatographic/ mass spectrometric confirmation of PCBs, PCDDs, and PCDFs was conducted by MRI. Gulf South Research Institute (GSRI) provided similar assistance for the second plant. The statistical design of the pilot study was constructed by Research Triangle Institute (RTI). RTI also conducted statistical analysis of the resulting emissions data and constructed the design for the nationwide survey. The results of the statistical analysis are summarized in Section 9 of this report. The survey design is summarized in a report to the EPA Office of Toxic Substances.*• TRW, Inc. was responsible for conducting the field sampling and data collection. The results of TRW's efforts are described in two reports to EPA's Industrial Environmental Research Laboratory in Research Triangle Park.2'3 The body of these reports are contained in Appendices A and B. A summary of the results of this study is contained in Section 2 of this report. Section 3 presents recommendations for future work. Brief descriptions of the two combustion sources are contained in Section 4. The sampling and analysis methods are described in Sections 5 and 6. Sections 7 and 8 present the field test data and analytical results. The analytical quality �assurance results are summarized in Section 9. Section 10 presents the emissions results and Section 11 is a statistical summary of the emissions results. �SECTION 2 SUMMARY Two major stationary combustion sources, a municipal incinerator and a co-fired (refuse-derived fuel plus coal) power plant, were studied to determine the variability of organic emissions between sources and over a designated time period for each plant. The pilot study results served as a basis for structuring the survey design for a nationwide survey1 for organic emissions from stationary combustion sources. All inputs and outputs (including fuel, air, water, ash, and flue gas) that were influenced by the combustion process at each facility were sampled for a minimum of 11 days. Daily flue gas samples (20 m3) were collected concurrently at the inlet and outlet of the control devices using a modified Method 5 sampling train. The solid and aqueous inputs and outputs from each plant were collected six times per day (at roughly 4-hr intervals). The samples were extracted and analyzed for total organic chlorine (TOC1), PAHs, PCBs, PCDDs, and PCDFs. A limited number of samples were analyzed for cadmium. The TOC1 procedure (more correctly, total extractable organic halide) was developed for this study to provide a sensitive measure of the variability of chlorinated organic emissions. The TOC1 emissions from the municipal incinerator and the co-fired power plant differed and were variable within the test duration for each plant. The flue gas accounted for more than 80% of each plant's TOC1 emissions. The TOC1 emissions averaged 322 mg/hr from the municipal incinerator and 246 mg/hr from the co-fired power plant. The variability of the TOC1 results was the key element in the construction of the nationwide survey design.1 A number of specific compounds including chlorinated benzenes and chlorinated phenols were detected in the flue gas from the municipal incinerator. The sum of the organic chlorine concentrations attributable to these specific compounds is comparable to the TOC1 results. Fewer chlorinated compounds were identified in the flue gas extracts of the co-fired plant and were generally present at lower concentrations than in extracts from the municipal incinerator. Polycyclic organic compounds including PAHs, PCDDs and PCDFs were identified in the flue gas extracts from the municipal incinerator. Some PAHs and PCBs were also identified and quantitated in the flue gas from the cofired power plant, but PCDDs and PCDFs were not detected. �The mean concentration observed for total PCBs from the municipal incinerator was 42 ng/dscm (dscm = dry standard cubic meter), compared to an average of 19 ng/dscm from the co-fired power plant. However, the order of the average emission rate is reversed because of the lower flue gas flow rate of the refuse incinerator. The average PCB emission rates for the RDF/coal-fired power plant and the refuse incinerator were 6 mg/hr and 3.6 mg/hr, respectively. Because of the variability observed in the data, no significant differences between concentrations or emission rates between the two plants can be determined. The PCB isomer distribution ranged from dichlorinated to pentachlorinated compounds for the municipal incinerator and trichlorinated to decachlorinated compounds for the co-fired power plant. PCDDs and PCDFs were not identified in sample extracts from the co-fired power plant. However, several PCDDs and PCDFs were identified in composited sample extracts from the municipal incinerator. Trichloro- and tetrachlorodibenzofurans were the most abundant of the PCDDs and PCDFs in these extracts, averaging 300 ng/dscm and 90 ng/dscm, respectively. The specific PCDD isomer 2,3,7,8-tetrachlorodibenzo-£-dioxin (2,3,7,8-TCDD) was also identified in these extracts from the municipal incinerator and averaged 0.4 ng/dscm (average mass emission 34 (jg/hr). This isomer was identified in these extracts using high resolution gas chromatography/high resolution mass spectrometry. This identification was confirmed by an independent laboratory using similar instrumentation. The level of cadmium was also measured in the inputs and outputs for a limited number of sample days for each plant. The mass balance observed for the inputs and emissions of the co-fired power plant was fairly good. However, the agreement for cadmium inputs and emissions for the municipal incinerator was poor. This was likely due to the difficulties encountered in obtaining representative samples of the refuse burned at this facility. �SECTION 3 RECOMMENDATIONS The nationwide this report provide analysis procedures fired power plants, combustion study should be conducted. The results in the basis for a sound statistical design for sampling and in future programs (i.e., municipal incinerators, coaletc.). Extraction studies should be undertaken with fly ash samples that have been shown to contain PCDDs and PCDFs. Analysis of such a material could provide a better measure of recovery efficiency of these compounds than from other similar solid materials. The modified Method 5 sampling procedure used in this study is based on sound developments for particulate sampling coupled with adsorption of organic vapors on a resin of known properties. However, this sampling procedure should be rigorously evaluated for the collection efficiencies of PCDDs and PCDFs as an additional quality assurance measure. The preliminary data presented in this report surement should be further evaluated for use as an organic emissions. The development of a good TOC1 cantly reduce the costs of obtaining large amounts suggest that the TOC1 meaindicator of chlorinated measurement could signifiof combustion source data. Additional work should be conducted to improve the selective separation and detection of PCDDs and PCDFs. Current methods require labor-intensive extractions and cleanup procedures. �SECTION 4 PLANT DESCRIPTIONS AMES MUNICIPAL POWER PLANT, UNIT NO. 7 The Ames Municipal Power Plant is owned and operated by the city of Ames, Iowa, and is located within the city limits. The coal-fired utility boiler tested at this plant was Unit No. 7, one of three units that have been modified to burn processed refuse as a supplemental fuel with coal. Unit No. 7, a pulverized coal suspension fired boiler, is used under normal operating condition. The other two units are operated under peak demand or when Unit No. 7 is down. This unit was originally designed to burn either coal or natural gas as the primary fuel. It was first brought into operation in 1968 and was modified to burn refuse-derived fuel (RDF) in 1975. Unit No. 7 generally burns a mixture of Colorado coal, Iowa coal, and RDF. Generally, the ratio of the two types of coal varies, although during this particular testing period a 45 to 55% ratio of Colorado to Iowa coal was maintained in the pulverized coal mixture. Approximately 20% (by weight) of the total fuel prepared and fired at this facility was RDF and 80% was pulverized coal. The RDF is produced at a separate Ames city facility located near the power plant. Raw refuse is sorted to remove glass and metals for recycling. The remaining material (largely papers and plastics) are milled and pneumatically conveyed to a storage bin. The RDF is fed from this bin to the boiler at the required rate. The maximum RDF feed rate is 8.5 tons/hr (7.7 metric tons/hr). Pulverized coal is supplied to the furnace by tangentially orientated nozzles so that combustion is accomplished in a suspension. Approximately 20% of the total ash produced during coal-only firing is bottom ash. RDF is supplied to the furnace at a point just above the primary coal combustion zone. Moveable grates hold the residual RDF at the bottom of the coal combustion zone to enhance RDF combustion. The grates are lowered during bottom ash wasting and when RDF is not being fired. The ash and slag deposited in the hopper are removed at least three times per day. An average of 758,000 liters/day (200,000 gal./day) of well water (sluice water) is used to remove the solid waste from the furnace bottom. This waste is drained to a holding pond where the ash is dredged out and stock piled. The water from the holding pond is allowed to percolate through the soil and eventually into a nearby river. �Electrostatic precipitators (ESPs) are used to remove particulates from the stack gases. The ESPs require at least 61 kw of the maximum 35,000 kw gross output of Unit No. 7. Fly ash collected in the ESP hoppers is pneumatically conveyed (3 times/day) to the bottom ash hopper drain system. Additional information including schematics of the plant site, the flow system, Unit No. 7 design, and the solid waste recovery system is presented in the pilot test program engineering report provided by TRW (see Appendix A). Other tables in the TRW report list the boiler design data, the pulverizer specifications, the fan design performance parameters, performance characteristics of the ESP, and the predicted performance characteristics of Unit No. 7. CHICAGO NORTHWEST INCINERATOR, UNIT NO. 2 The Chicago Northwest Incinerator is one of four municipal incinerators owned and operated by the city of Chicago (Illinois) and located within the city limits. This plant has four incinerators, each having a nominal burning capacity of 400 ton/24 hr day (363 metric tons/24 hr day). Each incinerator has a charging hopper, feed chute, hydraulic powered feeders and stoker, boiler, economizer and fly ash hoppers. Draft through the furnace is provided by forced draft fans, overfire air fans, and induced draft fans. Mixed refuse from domestic sources is brought to the incinerator in trucks having a capacity of 5 tons (4,500 kg) or 25 cubic yards (19 m3). The refuse varies considerably in consistency and moisture content seasonally and from load to load. All refuse is collected in a storage pit of 9,700 cubic yard (7,400 cubic yard) capacity. The refuse is not sorted prior to storage in the pit except for large items (e.g., furniture and large appliances) which are milled prior to storage in the pit. The refuse typically contains considerable quantities of automobile tires, small appliances, and similar discarded durable goods. The refuse is removed from the pit by one of three transfer cranes and is dumped directly into the four furnace feed hoppers. Refuse in the charging hopper of each incinerator flows by gravity from the hopper to three stoker feeders through a feed chute. The stoker feeders at the bottom of the feed chute push the refuse into the stoker by a reciprocating action. Alternate lateral rows of grate steps have controlled continuous reciprocating action with the moving grate steps pushing in reverse direction to the flow of refuse. This action moves a portion of the burning refuse under the unignited material and thereby effects an agitation and blending of the whole burning mass. Combustion air entering from below the grates cools the grates, helps to agitate the burning refuse and supplies the oxygen which produces a maximum burn-out in the shortest length of grate travel. The combustion air combines with the burning refuse to generate heat and raise the temperature of the flue gas to as high as 2000°F (1100°C). At rated burning capacity and based on 50% excess air (dry) the flue gas flow rate at 550°F (290°C) is estimated to be 142,300 actual cubic feet per minute (acfm) or 4,030 m3/min. The flue gas passes upward through the'furnace, through the boiler passes and finally through the economizer to the electrostatic precipitator. As it passes through the boiler it transfers heat to the water. �At the inlet to the electrostatic precipitator the temperature is reduced to approximately 500°F (260°C) because of the above heat exchange. During the passage of the flue gas through the boiler passes and economizer the heavier fly ash particles drop out. Hoppers are provided below the boiler and economizer for the collection of the particulates. In order to obtain maximum combustion efficiency, the depth of the refuse bed is controlled by automatic discharge or clinker rollers located at the end of the grate. As the residue reaches this point it is dumped into an ash discharger and is quenched in water. The residue is pushed up an inclined slope that permits draining and produces a residue of less than 15% moisture. In addition to quenching, the ash discharger also serves as a water seal for the furnace and prevents infiltration of air into the furnace. The furnace operates under slight negative pressure. The residue leaving each incinerator ash discharger passes through a hydraulically operated chute to one of two residue conveyors. The residue is screened to separate material larger than 2 in. (5 cm) in diameter. Hydraulic powered chutes are used to direct the flow of the residue away from the rotary screens and into a by-pass hopper. The residue conveyors also receive and transport stoker grate sittings and fly ash accumulations from the boiler hoppers, economizer hoppers, and the electrostatic precipitators. Stoker grate siftings collect in six hoppers under each of the three stoker grate sections. Residue from the hoppers is removed from the plant by trucks. The weight of the residue leaving the plant is measured and recorded at the weighing station. The boiler fly ash is collected in four hoppers, two of which discharge to the stoker grates. The other two hoppers are discharged directly through a common pipe to the residue conveyor. The fly ash from the economizer hoppers passes through a common pipe connected to the-discharge end of a conveyor handling fly ash from the two electrostatic precipitator hoppers. The fly ash is deposited directly into the residue discharge chute. The flue gas exiting the ESPs is vented to a 250-ft (76 m) high stack via an induced draft fan. Flue gases from two identical units are discharged from a single stack via a breaching. A more detailed description of the plant operation and schematics of the plant site, the flow system, and the flue gas and grab sampling locations is presented in the TRW pilot test program engineering report (see Appendix B). �SECTION 5 SAMPLING METHODS FLUE GAS Flue gas sampling for organic compounds was accomplished concurrently at points both inlet and outlet to the electrostatic precipitators using two modified Method 5 sampling trains (shown in Figure 1) at each location. Figure 2 shows the locations of sampling ports on a typical unit. The sampling crew collected 10 m3 (10 ± 1 m3) samples with each sampling train by extracting the flue gas at rates approximating the flue gas velocity for each plant. Cadmium was sampled at the ESP outlet using a single Method 5 sampling train. The standard train was operated the same as depicted in Figure 1, but without condenser and the XAD-2 sorbent trap. EPA Method 5 Procedures4 for particulate sampling were followed for both organic and inorganic sampling procedures, except that 10 m3 was sampled with each organic train. Detailed descriptions of the Method 5 calibration and actual sampling procedures for specific ducts and stacks at the Ames Municipal Power Plant and Chicago Northwest Incinerator have been presented in the respective field data reports (Appendices A and B). Additional details on the pretest preparation and sample recovery procedures are described in a methods manual for the nationwide combustion source survey.5 The flue gas sampling at the Ames facility was conducted both on the duct just before the electrostatic precipitator and on the stack. Sampling for organics was to be performed for 14 consecutive days with an additional 3 days sampling for particulate cadmium. However, due to extreme weather conditions only 11 days of concurrent inlet and outlet samples were collected. Eight additional inlet samples were also collected. The flue gas sampling at the Chicago plant was conducted at the duct inlet to the electrostatic precipitator and at the duct leading from the precipitator to the stack. Despite boiler down time and equipment malfunction, 11 days of organic samples (including concurrent inlet and outlet flue gas) were taken. A complete sampling train, including resin trap filter and impinger solutions was set up as a train background (blank) at each plant. The train was taken to normal operating temperature and allowed to remain at this temperature for 1 hr. Upon completion of testing, the sampling equipment was brought to a clean laboratory area for recovery. Each sampling train was kept in a separate area to prevent sample mixup and cross contamination. The individual sample train components were recovered as follows: �Cyclone (optional) Condenser & Resin Cartridge Thermocouple Reverie-Type Pitot Tube Console Impingers 1,3 and 4 are of (he Modified Greenburg-Smllh Type Impinger 2 is of I lie Greenburg-Smith Design Impinger I and 2 Contain 100 ml Water Impinger 3 Empty Impinger 4 Contains 200-300 Grams Silica Gel Figure 1. Modified Method 5 train for organics sampling. 10 �ESP Inlet Ports Stack Platform and Ports Figure 2. Locations of flue gas sampling ports on a typical combustion unit. 11 �Dry particulate in cyclone - cyclone flasks were transferred to cyclone catch bottle. • Probe was wiped to remove all external particulate matter near probe ends. Filters were removed from their housings and placed in proper containers. • After recovering dry particulate from the nozzle, probe, cyclone, and flask, these parts were rinsed with distilled water to remove remaining particulate. They were subsequently rinsed with glass distilled acetone and cyclohexane and put into a separate container. All rinses were retained in an amber glass container. Sorbent traps were removed from the train, capped with glass plugs, and given to an on-site MRI representative. Condenser coil, if separate from the sorbent trap, and the connecting glassware to the first impinger was rinsed into the condensate catch (first impinger). • First and second impingers were measured, volume recorded and retained in an amber glass storage bottle. The impingers were then rinsed with small amounts of distilled water, acetone and cyclohexane. These rinsings were combined with the condensate catch. Rinse volumes were also recorded. • The volumes of the third and fourth impingers were measured and recorded. Solutions were discarded. Silica gel was weighed, weight gain recorded and regenerated for further use. To maintain sample integrity, all containers were amber glass, with TFElined lids. PLANT BACKGROUND AIR A high volume air sampler was used to collect organic compounds and cadmium associated with particulates in the air used for combustion. The samples were collected on 8 in. x 10 in. (20 cm x 25 cm) glass fiber filters. A high volume sampler was placed on the roof of each facility to obtain a representative background of outside ambient air, rather than sampling air inside the building that could have been contaminated or influenced by the combustion process. SOLID AND AQUEOUS MEDIA Solid and aqueous samples that directly contact the combustion process were collected several times during each 24-hr period according to schedules 12 �provided by RTI. Four solid sample types were collected from the Ames plant, coal, ESP hopper ash, bottom ash, and RDF. ESP ash, refuse, and combined ash were sampled at the Chicago plant. Combined ash includes mixed ESP ash and bottom ash since the design of the Chicago ash handling system did not allow separate access to bottom ash. All solid samples were collected six times per day at roughly 4-hr intervals. Some solid samples were accessible from more than one nominally equivalent point in the plant. In these cases, samples were taken from specific points according to a randomized scheme provided by RTI. Hence, coal was sampled from two feed streams, RDF was sampled from four feed streams, and ESP ash was sampled from two collection hoppers at the Ames plant based on this scheme. Similarly, bottom ash from the Ames plant and bottom ash and refuse from the Chicago plant were sampled from specific sectors of the exposed material according to the randomized scheme. Figure 3 shows the sector systems used in sampling bottom ash from the Ames and Chicago plants. Raw refuse was sampled at the Chicago incinerator from the two sides of the feed hopper. The aqueous streams sampled at Ames included cooling tower blowdown water, well water, and bottom ash quench overflow. Only city tap water (plant intake water) was sampled at the Chicago facility. Liquid streams that did not flow continuously were allowed to purge for 3 min prior to obtaining samples. Sample containers were rinsed three times with sample liquid prior to being filled with that liquid. The streams sampled and frequency of sampling were as follows : • Bottom ash quench overflow water was sampled twice per shift, for a total of six samples per 24-hr period. Cooling tower blowdown feed for the bottom ash quench system was sampled once per day. Three well water samples were collected over the testing period. City tap water was sampled once per day. CONTINUOUS MONITORING The continuous monitoring data collected for the two different plants included: (1) oxygen [03] concentrations, (2) carbon dioxide [C02] concentrations, (3) carbon monoxide [CO] concentrations, (4) hydrocarbon concentrations [THC] [GI through C6] and (5) ambient temperatures. On-line monitoring was performed at the inlet of the electrostatic precipitators (ESP) at both plants and in the duct leading from the exit side of the ESP to the induced draft fan at the Chicago Northwest Incinerator and at the 100 ft (30 m) level on the stack at the Ames Municipal Power Plant. A stainless steel filter connected to a 3-ft (91-cm) probe was inserted into the sample port for each sample location. Heat traced line was run from the sample port to a gas conditioner. Vacuum pumps were used to draw the inlet and outlet sample gas from the sample ports through the gas conditioner 13 �' / E F C D A B North Hopper Door Ames Municipal Electric System, Unit No. 7 Bottom Ash Hopper A B C D F Chicago Northwest Incinerator, Unit No. 2 Residue Discharge Chute Figure 3. Sector schemes for sampling bottom ash. 14 �and to the analytical instruments. An automatic timer switched the continuous monitoring equipment from inlet to outlet every 15 rain. The average values for 02, C02) CO and THC recorded during each test period are presented in Section 8 of this report with a summary of the flue gas testing parameters. A more detailed description of the continuous monitoring data is presented in Appendices A and B. PROCESS DATA COLLECTION In order to fully characterize the operation of the two different combustion facilities and to designate periods of dramatic changes in the performance of a particular unit, numerous operating parameters were recorded throughout the flue gas sampling periods, as well as on a 24-hr basis. This information included mass flow data for fuels (coal, fuel oil, and RDF), periods of soot blowing, unit downtime, steam flow rate, steam pressure, steam temperature, feedwater flow rate, feedwater temperature, combustion air flow rate, combustion air temperature, percent excess oxygen, induced and forced fan pressures, furnace draft, furnace temperature, flue gas temperature, and ambient temperature and ambient pressure. The process data averages based on 24-hr periods and the flue gas test durations are presented in Section 7 of this report. Data for these parameters taken on an hourly basis are presented in detail in the Appendices. 15 �SECTION 6 ANALYSIS METHODS ORGANICS The analysis methods for organics were designed to provide qualitative and quantitative determinations of several specific analytes and to provide semiquantitative information on any additional polychlorinated aromatic compounds identified. The specific analytes included eight PAH compounds (listed in Table 1), PCBs, PCDDs, and PCDFs. Special emphasis was placed on highly selective and sensitive procedures for determining 2,3,7,8-TCDD. TABLE 1. PAH COMPOUNDS SELECTED Benzo[a]pyrene Pyrene Fluoranthene Phenanthrene Chrysene Indeno[l,2,3-cd]pyrene Benzo[£,h,ijperylene Anthracene Samples were also assayed for total organic chlorine (TOC1) to provide a general measure of the variability of chlorinated emissions. Since it was anticipated that concentrations for many specific compounds would be near minimum detectable levels, the variabilities observed for specific compounds may be more representative of measurement error than emission variabilities. The sensitivity of the TOC1 procedure should allow more reliable detection of the variability of emissions for chlorinated organics. 16 �A tiered scheme was used to economize on the total number of analyses required. The tier 1 operations, schematically shown in Figure 4, included sample extraction, TOC1 assays, capillary gas chromatographic (HRGC) screening for halogenated compounds and hydrocarbons, and PAH analysis by capillary gas chromatography/mass spectrometry (HRGC/MS). Extract analysis by capillary gas chromatography with Hall electrolytic conductivity and flame ionization detectors (HRGC/Hall-FID) provided a sensitive screen for halogenated compounds that was used to aid the identification of specific halogenated compounds in the HRGC/MS data. Some of the individual grab samples were composited to form daily and shift composite samples prior to extraction for tier 1 analysis. The sample compositing scheme was provided by RTI. The tier 2 analyses, also shown in Figure 4, focused on very sensitive and selective determinations of PCBs, PCDDs, and PCDFs. Extracts were analyzed by HRGC/MS operated in selected ion monitoring mode (HRGC/MS-SIM). Suspected responses for PCDDs and PCDFs were confirmed by using high resolution mass spectrometry (HRGC/HRMS-SIM). In addition, three extracts were submitted to the EPA laboratory at Research Triangle Park for collaborative confirmation of PCDDs and PCDFs. The analytical quality assurance program included analyses of method spikes, method blanks, and field blanks in addition to the use of stable isotope-labelled surrogate compounds spiked into all samples to provide some analytical recovery data for all samples. Scanning HRGC/MS analyses were conducted using a stable isotope-labelled internal standard, dio~anthracene. HRGC/HRMS-SIM analyses for TCDD employed 37Cl4-2,3,7,8-tetrachlorodibenzo-£dioxin. In addition, two sets of check samples, one set for TOC1 and one set for specific chlorinated aromatic compounds, were sent to the two laboratories conducting the tier 1 analyses. The analytical methods used are described in detail in the subsections that follow. Additional details of the analytical procedures are described in methods manual for the nationwide combustion source survey.5 Tier 1 Methods Sample Preparation and Compositing-Flue gas samples—The contents of the two modified Method 5 sampling trains used at each sampling point on each day were analyzed as a single sample. That is, the four trains used each sampling day (except for several days at the Ames site on which outlet flue gas was not sampled) comprised daily samples for outlet and inlet flue gas. Hence, the corresponding sample components from both trains were extracted together, i.e., filters, cyclone catch, train rinsings, and resin cartridges. All extracts resulting from the two trains were then combined. All filters and cyclone catches were weighed prior to extraction to allow estimation of particulate emissions. However, the filters were not desiccated to constant weight according to the Method 5 procedures in order to maintain sample integrity for subsequent organic analyses. Hence, the particulate emissions estimates may not be valid. 17 �Sample Extract Short Packed Column GC/Hall (TOCI) TIER 1 HRGC/Hall-FIDor HRGC/FID Screen Add Internal Standard Anthracene - d]g HRGC/MS (Scanning) Surrogates + Pol/cyclic Organic Compounds Add Internal Standard 37, 2,3,7,8-Tetrachlorodibenzo-p-dioxinHRGC/MS-SIM Chlorinated Polycyclic Organic Compounds (Biphenyls, Dioxins, Furans) ••Hold TIER 2 HRGC/HRMS-SIM Confirmation ••Hold Interlaboratory Verification HRGC/HRMS-SIM Figure 4. General analytical scheme. 18 �Grab samples--Portions of the ash, fuel, and aqueous samples were composited according to a schedule provided by RTI to form daily and shift composites for each sample type for selected sampling days. Fly ash, bottom ash, and coal from the Ames site were prepared prior to compositing by pulverizing in a ceramic ball mill with stainless steel balls. Plant background air samples—The single combustion air sample collected each day was extracted and analyzed individually. Prior to extraction, the filters were weighed to allow estimation of the total particulate catch. Sample Extraction— Solid samples—In order to determine the most appropriate extraction procedure, a number of solvent and extraction systems were evaluated using samples of Ames fly ash spiked with selected PAH's and 1,2,3,4-TCDD. Chlorinated solvents were avoided in order to minimize the possibility of producing chlorinated species during the extraction. Preliminary evaluations of simple sample-solvent contact techniques added by mechanical or ultrasonic agitation produced low recoveries. Subsequent evaluations were focused on Soxhlet and reflux procedures. Table 2 summarizes the results of evaluations of seven sample pretreatment and solvent system combinations using Ames fly ash spiked with selected PAHs and 1,2,3,4-TCDD. Pretreatment with water and Soxhlet extraction with benzene provided the highest recovery for all spiked compounds. The average recovery for the nine compounds was 81%. The range of recoveries obtained with this procedure was 56 to 107%. The influence of pretreatment with water on the extractability of the target compounds is not clear. However, a general improvement in recoveries was observed for extractions with acetone/cyclohexane azeotrope when water was added to the ash prior to extraction. Similar effects have been reported for soil and sediment extraction by many researchers. Possibly, the water hydrates cations in the ash that tend to associate with the mobile n-cloud of polynuclear species so that they are more easily extractable. Some researchers have reported good recoveries with procedures involving pretreatment with aqueous acid and extraction with aromatic solvents, e.g., pretreatment with 1 N HC1 and extraction with toluene.6 However, this procedure was determined to be unsatisfactory for several reasons. Acid pretreatment may encourage degradation of some compounds. Reflux or Soxhlet extraction with toluene must be conducted at a higher temperature than for benzene (the boiling points of toluene and benzene are 111 and 80°C, respectively) so that thermally unstable and relatively volatile compounds may be lost. In addition, toluene extracts cannot be conveniently concentrated using Kuderna-Danish evaporation over a steam or hot water bath. All solid samples were Soxhlet extracted with benzene for 8 to 16 hr. The entire sample was extracted for the flue gas train components. Twentygram aliquots of coal, refuse, refuse-derived fuel (RDF), bottom ash, and fly ash were extracted. The fly ash was mixed with 10 ml of prepurified water just prior to analysis. All samples were spiked with the two surrogate spiking compounds, dg-naphthalene and d12-chrysene, just prior to extraction. However, since the extracts for various flue gas components were later combined, only one component for each flue gas sample was selected for surrogate 19 �TABLE 2. RECOVERY OF SELECTED PAHs AND 1,2,3,4-TCDD FROM AMES FLY ASH % Recovery D E F G 62 46 102 63 49 42 107 65 68 60 25 94 60 65 68 64 24 86 72 54 74 75 72 67 81 Chrysene 38 40 NSa NS 38 15 73 Benzo [ a ] py rene 26 28 35 52 26 8 69 Indeno[l,2,3-c,d]pyrene 15 20 27 40 15 0 58 Benzo [ g , h , i ] pery lene 17 24 25 41 17 0 56 Average 45 48 50 59 44 25 81 Compound A B C Phenanthrene 62 76 60 63 Anthracene 49 67 48 Fluoranthene 60 61 Pyrene 64 1,2,3,4-TCDD Note: A. B. C. D. E. Soxhlet 16 hr, cyclohexane, dry fly ash (20 g). Same as A except 5 ml H20 + 5 ml acetone added to fly ash. Soxhlet 16 hr, acetone/cyclohexane azeotrope (67% acetone). Same as C except 5 ml H20 added to fly ash (80% cyclohexane). Soxhlet 16 hr, cyclohexane/ethanol azeotrope + 10 ml water on fly ash (20 g). F. Reflux 4 hr with 250 ml H20 + 50 ml toluene. G. Soxhlet 16 hr with benzene + 10 ml H20 added to 20 g fly ash. a NS = No chrysene in spike. 20 �spiking. The component selected was varied so as to provide some recovery data for all components. The extracts from coal, refuse, and RDF were washed with three 100-ml portions of prepurified water to remove polar interferences. The extracts from all solid samples were dried by passage through short columns of preextracted anhydrous sodium sulfate before concentration to 2 to 10 ml in Kuderna-Danish evaporators. The extracts were further concentrated under a gentle stream of dry nitrogen. The final extract volume was typically 1.0 ml. However, some extracts were analyzed at volumes ranging from 0.20 to 10.0 ml. All extracts were spiked with the internal standard for scanning HRGC/MS, djo-anthracene, prior to analysis. Aqueous samples—All aqueous samples, i.e., flue gas rinses, first impinger waters, overflow waters, raw waters, etc., were batch extracted in separatory funnels with three 60-ml portions of cyclohexane. As in the case of the solid samples, the aqueous samples were spiked with the surrogate spiking compounds just prior to analysis. The resulting extracts were dried and concentrated to 0.20 to 1.0 ml according to the procedures described for solid samples. TOC1 Assay-The TOC1 contents of all extracts were determined using a simplified GC/ Hall procedure. A short packed column and a rapid temperature program were used to elute all chromatographable compounds with volatilities equal to or greater than dichlorobenzene as a single peak. The TOC1 contents of sample extracts were determined by comparing the area response of the peak with that obtained for chlorinated standards. TOC1 results were expressed as chloride. The specific parameters used by SwRI and GSRI for TOC1 assays of the Ames and Chicago samples, respectively, are shown in Table 3. A sample TOC1 chroraatogram for an Aroclor 1254 PCB standard (GSRI procedure) is shown in Figure 5. HRGC/Hall-FID Screening-Sample extracts were screened by HRGC/Hall-FID prior to HRGC/MS analysis to provide a preliminary indication of their halogenated and hydrocarbon contents. In addition, the Hall responses were used to help identify elution times on which to focus examination of the subsequent mass spectral data for halogenated compounds. The specific parameters used by SwRI and GSRI are shown in Table 4. Fused silica capillary columns were used with Grob-type capillary injection systems operated in the splitless mode. GSRI did not have a fused silica column effluent splitter available; hence, extracts from the Chicago plant were screened using FID detection only. Scanning HRGC/MS-Sample extracts were analyzed by HRGC/MS to determine the target PAH compounds and to allow identification and quantitation of specific chlorinated compounds. The primary determinations of surrogate spiking compound recoveries were made from the HRGC/MS data. The chromatographic parameters utilized were essentially identical to those used for the HRGC/Hall-FID screening. 21 �TABLE 3. TOC1 ANALYSIS PARAMETERS Parameter SwRI (Ames samples) GSRI (Chicago NW samples) Column 0.9 m x 4 nun ID, glass 1.0 m x 2 mm ID, glass Packing 2.5 cm of 10% SP-2100 UltraBond 3.8 cm of 2.5% SE-30 on 80/100 mesh Chromosorb G, rest of column filled with 80/100 mesh glass beads Carrier gas He at 60 ml/min He at 30 ml/min Column temperature 60°C for 3 min, then to 230°C at 40°C/min 60°C for 3 min, then to 250°C at 40°C/min External standard compound chlorobiphenyl Aroclor 1254 22 �25 ng Aroclor 1254 Attenuation - 500 V) a> ID V ex. Vent Valve Closed 4 8 12 Time (Minutes) Figure 5. TOC1 chromatogram for Aroclor 1254. 23 16 �TABLE 4. HRGC SCREENING PARAMETERS Parameter GSRI (Chicago NW samples) SwRI (Ames samples) Column 30 m fused silica, wall coated with SE-30 30 m fused silica, wall coated with SE-30 Column temperature 100°C for 5 min, then to 300°C at 10°C/min 60°C for 2 min, then to 300°C at 10°C/min Detectors Hall-FID, 1:1 split FID During the runs, the spectrometer was repetitively scanned over the range m/e 35 to 550 at 1.0 sec/scan. The PAH compounds, including the surrogates, were identified using three extracted ion current plots (EICPs). The criteria for compound identification are coincident peaks in all EICPs at the appropriate retention time with the characteristic response ratios. Compounds identified were quantitated by comparing the EICP response for the most abundant ion with that for the same compound in a mixed standard solution. Tier 2 Methods Following completion of the tier 1 chemical analyses, RTI conducted a statistical analysis of the TOC1 results and constructed a preliminary design for the nationwide survey based on the observed TOC1 variabilities. The preliminary survey design specified sampling programs of 5 and 3 days duration for coal-fired and refuse-fired plants, respectively. Hence, in order to allow inclusion of the pilot study data in the survey data set, the extracts were composited prior to further analysis to simulate a 5-day test at the Ames plant and a 3-day test at the Chicago plant. The compositing scheme, provided by RTI, is shown in Table 5. The composite extracts for each composite day were prepared by combining equal volumes of daily composites from the designated sample days. This necessitated the preparation of daily composites from shift composite extracts or individual sample extracts for many samples and sample days. 24 �TABLE 5. EXTRACT COMPOSITING SCHEME FOR TIER 2 ANALYSES Composite day I II III IV V Sample days combined Ames samples Chicago samples 3/2, 3/15 3/13, 3/22 3/14, 3/19 3/17, 3/20 3/3, 3/23 5/6, 5/9, 5/16 5/7, 5/10, 5/12 5/11, 5/13, 5/15 The composite extracts were screened by HRGC/Hall-FID or HRGC/FID prior to analysis for PAH compounds by scanning HRGC/MS, and for PCBs, PCDDs, and PCDFs by HRGC/MS-SIM. Only extracts for which positive responses were obtained for PCDDs and PCDFs were analyzed by HRGC/HRMS-SIM. HRGC/Hall-FID and HRGC/FID Screening— The composited extracts were screened by HRGC/Hall-FID (Ames samples) or HRGC/FID (Chicago samples) by the procedures described for Tier 1 screening except that fused silica capillary columns wall-coated with SE-54 were used. Scanning HRGC/MS Analysis— The HRGC/MS procedures employed for the composite extracts were essentially the same as was used for tier 1 analyses. The target PAH compounds were determined and any other compounds observed were identified by manual and computer-assisted spectral interpretation. Quantitative estimates for all compounds identified were based on responses versus responses for the same or similar compounds in standard solutions. HRGC/MS-SIM AnalysisAll composite extracts were screened for the presence of PCDDs and PCDFs by HRGC/MS-SIM. The chromatographic parameters used by SwRI and GSRI for the Ames and Chicago extracts, respectively, were the same as were used for scanning HRGC/MS analyses. The ions selected for detection were the two most abundant ions in the molecular cluster for each compound. No positive responses were detected in any of the Ames extracts. Positive responses were detected in composite flue gas extracts from the Chicago plants. However, interfering materials in the extracts hindered reliable identifications. Three composite flue gas extracts from the Chicago plant were cleaned by a vigorous base treatment, an acid treatment, and an alumina chromatographic procedure specifically developed for PCDD and PCDF assays. The composited extracts were split into two fractions each. One fraction was spiked with l,2,3,4-tetrachlorodibenzo-£-dioxin and octachlorodibenzo-£-dioxin, and the other fraction was not spiked. The extracts were stirred with 45% aqueous KOH solution at ambient temperature for 3 hr. The mixture was extracted with hexane and the extract was washed with concentrated sulfuric acid until the washes remained colorless. The extract was concentrated and chromatographed on an alumina column using dichloromethane as the eluting solvent. 25 �The cleaned extracts were analyzed at MRI by HRGC/MS-SIM. The instrumental parameters are listed in Table 6. These analyses were conducted using a high resolution mass spectrometer operated at 1,000 resolution (10% valley). Positive PCDD and PCDF responses were detected in all extracts. Since low resolution mass spectrometric analysis of PCDDs and PCDFs in environmental extracts may be obscured by the presence of similar chlorinated aromatic compounds (e.g., PCB's), these extracts were held for analysis by capillary gas chromatograpy/high resolution mass spectrometry using selected ion monitoring (HRGC/HRMS-SIM). TABLE 6. HRGC/MS PARAMETERS USED FOR ANALYSES OF PCDDs AND PCDFs IN COMPOSITE CHICAGO NW FLUE GAS OUTLET EXTRACTS Column 18 m fused silica wall-coated with SE-54 Column temperature 110°C for 2 min, then to 325°C at 10°C/ min Injector J&W on-column Spectrometer resolution 1,000 (10% valley) Scan rate 1-2 sec/scan (3-5 ions/scan) Ions selected (m/e) Trichlorodibenzo-£-dioxin Tetrachlorodibenzo-£-dioxin Pentachlorodibenzo-£-dioxin Hexachlorodibenzo-£-dioxin Heptachlorodibenzo-£-dioxin Octachlorodibenzo-£-dioxin 285.9, 319.9, 353.9, 389.8, 423.8, 457.7, 287.9 321.9 355.9 391.8 425.8 459.7 Trichlorodibenzofuran Tetrachlorodibenzofuran Pentachlorodibenzofuran Hexachlorodibenzofuran Heptachlorodibenzofuran Octachlorodibenzofuran 269.9, 303.9, 337.9, 373.8, 407.8, 441.7, 271.9 305.9 339.9 375.8 409.8 443.7 The Ames and Chicago composite flue gas outlet extracts were also analyzed at MRI for PCBs by HRGC/MS-SIM. The instrumental parameters and ions selected are shown in Table 7. The focused ions were switched several times during a single HRGC/MS run so that all PCB compounds could be analyzed in two runs, one for odd chlorine substitutions and a second for even chlorine substitutions. PCBs were quantitated by comparing the total area response for all 26 �TABLE 7. HRGC/MS-SIM PARAMETERS USED FOR ANALYSIS OF PCBs IN COMPOSITE FLUE GAS OUTLET EXTRACTS Column 15 m fused silica, wall-coated with DB-5 (a specially bonded SE-54 coating) Column temperature 60°C for 2 min, then to 265°C at 8°C/min Injector Grob-type, splitless Spectrometer resolution 1,000 (10% valley) Scan rate 1-2 sec/scan (2-4 ions/scan) Ions selected (m/e) Dichlorobiphenyl Trichlorobiphenyl Tetrachlorobiphenyl Pentachlorobiphenyl Hexachlorobiphenyl Heptachlorobiphenyl Octachlorobiphenyl Nonochlorobiphenyl 221.9, 255.9, 291.9, 323.9, 357.8, 393.8, 427.7, 461.7, 223.9 257.9 293.9 325.9 359.8 395.8 429.7 463.7 compounds identified for a specific chlorine substitution with the area response for a specific isomer of the same chlorine substitution number. For example, total trichlorobiphenyls were quantitated against 2,5,2'-trichlorobiphenyl. The PCB isomers used for quantitation are listed in Table 8. TABLE 8. PCB COMPOUNDS USED FOR DETERMINATIONS IN COMPOSITE FLUE GAS OUTLET EXTRACTS 2,2'-Dichlorobiphenyl 4,4'-Dichlorobiphenyl 2,5,2'-Trichlorobiphenyl 2,4,2',4'-Tetrachlorobiphenyl 2,4,2',5'-Tetrachlorobiphenyl 2,3,4,5,6-Pentachlorobiphenyl 2,4,6,2',4',6'-Hexachlorobiphenyl 2,3,4,2',3',4'-Hexachlorobiphenyl 2,3,4,5,6,2',5'-Heptachlorobiphenyl 2,3,4,5,2',3',4',5'-Octachlorobiphenyl Decachlorobiphenyl 27 �HRGC/HRMS-SIM Confirmatory Analysis of PCDDs and PCDFs-PCDDs and PCDFs were identified and quantitated in the composite Chicago flue gas outlet extracts by HRGC/HRMS-SIM. The instrumental parameters employed were the same as for low resolution screening at MRI except that the spectrometer was operated at 10,000 resolution (10% valley). The selected ions monitored are listed in Table 9. In order to achieve maximum sensitivity while minimizing the number of HRGC/HRMS-SIM runs, ions for a specific chlorine substitution for both dioxins and furans were monitored in a single run. For example, trichlorodibenzo-p_dioxins and trichlorodibenzofurans were analyzed in the same run. However, the tetra-substituted compounds were analyzed in separate runs to provide even better sensitivity for the most toxic PCDDs and PCDFs. The PCDD and PCDF compounds identified were quantitated by comparing the total area response for all compounds of a specific chlorine substitution with the area response for a specific isomer of the same chlorine substitution number. The specific PCDD and PCDF isomers used for quantitation are listed in Table 10. Compounds for which no corresponding authentic compound was available were quantitated against the most similar compound. Hence, hexachlorodibenzofurans were quantitated against hexachlorodibenzo-£-dioxin. The response factor used for pentachlorodibenzodioxins was the average of responses for tetra- and hexa-isomers. Tetrachlorodibenzo-p_-dioxins were quantitated using 37Cl4-2,3,7,8-tetrachlorodibenzo-£-dioxin as an internal standard. Since discrete isomers were not identified, only totals were determined for each chlorine substitution. A separate HRGC/HRMS-SIM analysis with a 60-m Carbowax column was used to determine 2,3,7,8-tetrachlorodibenzo-g-dioxin. The instrumental parameters are shown in Table 11. The Carbowax column, although providing good separation of specific tetra-isomers, required longer analysis times and caused signficant peak broadening. Hence, it was not used for general PCDD and PCDF analyses. The internal standard method employing 37Cl-labeled compound was used for quantitation. Quality Assurance Procedures The analytical quality assurance program consisted of the use of surrogate spiking compounds in all samples; the use of internal standards for most GC/MS analyses; analyses of field blanks and method blanks; and interlaboratory comparison studies for selected determinations. Surrogate spiking compounds were used as the primary analytical quality indicators. The two stable isotope labeled surrogates, dg-naphthalene and dj2~chrysene, were spiked immediately prior to extraction into all samples at 5 to 10 times the limits of detection. The surrogate concentrations were determined using scanning HRGC/MS data. The surrogate compound recoveries provide indications of overall quality of the extraction and extract concentration procedures. All scanning HRGC/MS analyses were conducted using dio~anthracene as the internal standard. Tetrachlorodibenzo-£-dioxin analyses by HRGC/HRMS-SIM were conducted using 37Cl4-2,3,7,8-tetrachlorodibenzo-D-dioxin. 28 �TABLE 9. IONS MONITORED DURING HRGC/HRMS CONFIRMATORY ANALYSIS OF PCDDs AND PCDFs IN COMPOSITE CHICAGO NW FLUE GAS OUTLET EXTRACTS Compound m/e Trichlorodibenzo-£-dioxin Tetrachlorodibenzo-£-dioxin 37 Cl4-2,3,7,8-Tetrachlorodibenzo-£-dioxin (internal standard) enacorenzo-£-oxn Pentachlorodibenzo-£-dioxin Hexachlorodibenzo-£-dioxin -Heptachlorodibenzo-£-dioxin Octachlorodibenzo-£-dioxin 285.9355, 287.9325 319.8965, 321.936 327.8847 joj.ooo/, 353.8887, 389.8157, 423.7688, 457.7377, 333.0020 355.8858 391.8127 425.7659 459.7347 Trichlorodibenzofuran Tetrachloridibenzofuran Pentachlorodibenzofuran Hexachlorodibenzofuran Heptachlorodibenzofuran Octachlorodibenzofuran 269.9406, 303.9017, 337.8938, 373.8208, 407.7739, 441.7428, 271.9376 305.8987 339,8909 375.8178 409.7710 443.7398 TABLE 10. PCDD AND PCDF COMPOUNDS USED FOR DETERMINATIONS IN COMPOSITE CHICAGO NW FLUE GAS OUTLET EXTRACTS 1,2,4-Trichlorodibenzo-£-dioxin 1,2,3,4-Tetrachlorodibenzo-£-dioxin 2,3,7,8-Tetrachlorodibenzo-£-dioxin Hexachlorodibenzo-£-dioxin (isomer unknown) Octachlorodibenzo-£-dioxin 2,3,7,8-Tetrachlorodibenzofuran Octachlorodibenzofuran 29 �TABLE 11. HRGC/HRMS PARAMETERS USED FOR ANALYSIS OF 2,3,7,8-TETRACHLORODIBENZO-R-DIOXIN IN COMPOSITE CHICAGO NW FLUE GAS OUTLET EXTRACTS Column 60 m fused silica, wall-coated with Carbowax 20M Column temperature 110°C for 2 min, then to 220°C at 10°C/min Injector J&W on-column (1 pi injection) Spectrometer resolution 10,000 (10% valley) Scan rate 1 sec/scan (3 ions) Ions selected 319.8965, 321.8936 Tetrachlorodibenzo-g-dioxin 37 C142,3,7,8-Tetrachloro-£dioxin (internal standard) 327.8847 Analyses of field blanks and method blanks (i.e., laboratory blanks) provided indications of possible sample contamination due to contact with the sampling and analysis equipment as well as general sample and extract handling. Field blanks comprised 10 to 15% of the total samples and included unused components of the flue gas sampling train, a complete sampling train for each plant (as described in Section 5), unused sample containers, and aliquots of solvents used for sample recovery at the plant. Method blanks were extracts prepared in the same manner as sample extracts although no samples were extracted. Since the tier 1 analyses were conducted by two laboratories (SwRI and GSRI), interlaboratory comparison studies were conducted to check the comparability of the resulting data. Three such studies were conducted. Comparability of TOC1 results was investigated by a set of TOC1 check extracts prepared by MRI and by an exchange of selected sample extracts between SwRI and GSRI. Check samples of fly ash spiked with selected chlorinated compounds were also prepared by MRI and analyzed by SwRI and GSRI using HRGC/Hall and scanning HRGC/MS. In addition, extracts in which positive responses were observed for PCDDs and PCDFs by HRGC/HRMS-SIM were submitted to Robert Harless at EPA's Environmental Monitoring and Support Laboratory in Research Triangle Park for collaborative analysis. The results of these analyses are described in Section 9. 30 �CADMIUM Samples of fly ash weighing 0.1 g or samples of bottom ash weighing 0.1 to 1 g were placed in 150-ml beakers that had been precleaned with nitric acid. Ten milliliters of aqua regia were initially added to each ash sample. The samples were gently heated and allowed to reflux until the evolution of yellow fumes subsided. An additional 5 ml of aqua regia was then added, and the ash was allowed to continue digesting. Another 5 ml of aqua regia was added to all samples, and the samples were allowed to digest for at least 20 more min. The samples were permitted to cool, and all of the material was transferred to 50-ml plastic centrifuge tubes. Centrifugation was accomplished at 2,500 rpm for approximately 5 min. The supernatant liquid was transferred by Pasteur pipets to the original beakers. Deionized water was added to the residue in the centrifuge tubes, the mixtures were agitated, the tubes were once again centrifuged, and the supernatant was added to that in the original beakers. This washing procedure was repeated again. The residue remaining in the centrifuge tube was then washed three times with a 5% (v/v) nitric acid solution. For each washing, 5 ml of the acid solution was added to each sample, and the samples were centrifuged and processed as described above. The final solutions in the beakers (approximately 85 ml) were returned to the hot plate and heated gently until the volume of the solution was reduced to 20 ml. The solutions were allowed to cool, filtered through Whatman No. 4 filter paper, and diluted to 50 ml with deionized water. A modification of this procedure was used for the digestion of refuse and filter samples. Fifteen milliliters of aqua regia and 10 ml of deionized water were added to 1-g portions of refuse or to the entire air filter. Tap water and probe-rinse water were digested by adding 3 ml of concentrated nitric acid and 1 ml of concentrated hydrochloric acid to 200 ml of sample and heating gently until the volume was reduced to less than 50 ml. The digested sample was diluted to 50 ml with deionized water. Solutions prepared by digestion of solid samples were analyzed by flame atomic absorption spectrophotometry (AAS) using an air-acetylene flame. Water samples were analyzed by heatedgraphite atomization AAS. A comprehensive QA/QC control program was conducted for cadmium analyses. The program included analysis of the National Bureau of Standards coal fly ash standard reference material, aqueous solutions of cadmium prepared in-house, fortified and duplicate samples, and reagent blanks. Samples were usually digested and analyzed in groups of eight: four distinct samples, a duplicate of one of the original four which had been fortified with 10 pg of cadmium, a duplicate of another of the original four which was unaltered, a quality-control sample, and a reagent blank. The fresh dilutions of a standard solution of cadmium were prepared on each day of analysis and were used to calibrate the AAS. The precision and accuracy of the analytical method used by GSRI were determined by analysis of a coal fly ash standard reference material from the National Bureau of Standards (NBS) and fortified fly ash from the Chicago 31 �Northwest Incinerator. The average and standard deviation of the percentage of cadmium recovered by analysis of four replicate samples of the NBS coal fly ash was 98 ± 11. Analysis of seven replicate samples of incinerator fly ash showed the cadmium concentration to be 260 M8/8- The recovery of cadmium from the incinerator fly ash was determined by analysis of samples fortified with cadmium. The results of the recovery study are presented in Table 12. An average of 95 ± 15% of the cadmium was recovered from the fortified samples. SwRI provided QA measures in terms of analysis of all sample types spiked at the levels shown in Table 13. 32 �TABLE 12. RECOVERY OF CADMIUM FROM FORTIFIED SAMPLES OF FLY ASH FROM THE CHICAGO NW INCINERATOR Cadmium determined in fortified sample (|Jg/g) Cadmium added to sample (Mg/g) Percent cadmium recovered Sample Cadmium in original sample (Hg/g)3 1 260 100 330 70 2 260 99 370 111 3 260 100 360 100 4 260 97 350 93 5 260 100 360 100 6 260 100 370 110 7 260 100 340 80 Mean recovery 95 Standard deviation 15 a Average of seven replicate analyses. TABLE 13. RECOVERY OF CADMIUM FROM FORTIFIED SAMPLES FROM THE AMES MUNICIPAL POWER PLANT Sample type Spike level Fly ash 0.5 Mg/g 97 Bottom ash 0.5 Mg/g 93 Refuse 0.1 Mg/g 98 Coal 0.5 Mg/g 94 Aqueous 4 (Jg/100 ml 33 Recovery 110 �SECTION 7 FIELD TEST DATA AMES MUNICIPAL POWER PLANT, UNIT NO. 7 The field test activity at the Ames Municipal Power Plant took place from February 25, 1980 to March 28, 1980. All required tests were completed and all recovered samples were sent to SwRI for analysis. A summary of the reduced data for flue gas sampling on a daily basis as calculated from the field data sheets is presented in Table 14. The following abbreviations are used throughout this report: DSCF = dry standard cubic feet, DSCM = dry standard cubic meters, ACFM = actual cubic feet per minute, DSCFM = dry standard cubic feet per minute, and DSCMM = dry standard cubic meters per minute. The data listed are corrected to standard conditions, i.e., 20°C (68°F) and a barometric pressure of 29.92 in. of mercury (1.0 atm). Percent isokinetic is the sampling velocity expressed as percent of the gas velocity in the stack or duct at the sampling points. Events that may have created uncertainties as to the quality of the flue gas sampling procedures are noted. Due to severe weather conditions, flue gas outlet samples were not collected on test days 3 to 11. Process data was monitored on an hourly basis during the entire testing period. Table 15 presents a summary of the pertinent process data as averages for daily 24-hr plant operation and operation during the flue gas sampling durations. The process data gathered indicated that the operating conditions fluctuated in patterns related to the amount of electricity generation demand placed on the boiler, and on the type of fuel being burned to meet that demand. Overall fluctuation consisted of two components. The first component was the daily variation. The load peaked in the afternoon and fell to a minimum before dawn. The second type of variation was caused by sudden operational changes, which was due to reduced power generation for various reasons such as the buying of cheaper power from a private utility, or the reduction in flow of RDF to the boiler. Unit No. 7 was generally operated between a range of 16 to 35 MW. Production over 35 MW placed considerable wear on the unit, and was avoided whenever possible. Production under 16 MW introduced instability and the possibility of large transient swings in operating conditions. Usually the boiler was operating close to one of these limits. It operated at 35 MW during peakloads because the load of the serviced community was over 35 MW. Production was reduced to 16 MW when off-peak power could be bought more cheaply from neighboring utilities. 34 �TABLE 14. DAILY DATA SUMMARIES FOR FLUE GAS SAMPLING, AMES MUNICIPAL POWER PLANT, UNIT HO. 7 Date Test (1980) no. Sampling location Inlet 3-2 3-3 1 2 North0 Soutjh Outlet 263d 4 3-6 5 3-7 6 3-8 7 3-9 8 3-10 9 3-11 10 3-12 11 Stack THC temperature pp. °F Molecular weight Moisture Velocity ft/sec 4.48 4.48 6.34 6.34 12.79 12.79 11.31 11.31 18.00 18.00 15.00 15.00 < < < < 2 2 2 2 334.31 311.78 320.93 309.92 29.01 29.35 29.30 29.31 9.95 7.15 6.32 6.24 33.55 29.09 22.69 24.79 Northe 173.54 North* 126.93 South* 212.05 South 101.52 ISA 324.36 2&3 307.31 4.92 3.60 6.01 2.88 9.19 8.70 4.38 4.33 4.33 4.33 5.87 5.87 13.80 13.80 13.80 13.80 12.44 12.44 . 12.00 12.00 11.00 11.00 11.00 < < < < < < 2 2 2 2 2 2 351.55 373.36 234.83 369.90 342.38 336.94 29.34 29.32 29.41 29.39 29.31 29.31 8.39 8.59 7.81 7.97 7.45 7.48 37.78 42.94 46.61 37.15 26.00 26.10 North South 14 &8 2&3* 184.21 252.78 5.22 4.43 7.16 4.43 14.41 14.41 17.00 < 2 17.00 < 2 370.46 352.55 29.56 29.30 7.43 9.48 North South 1&4I* 2S3h 256.88 246.73 7.28 6.99 4.41 4.41 14.56 14.56 18.00 < 2 18.00 < 2 361.09 349.23 29.49 29.38 Inlet North South 367.65 323.17 10.41 9.15 4.35 4.35 13.79 13.79 18.00 18.00 < 2 < 2 363.83 347.46 Inlet North South 368.68 365.42 10.44 4.59 10.35 4.59 13.92 13.92 16.00 < 2 16.00 < 2 Inlet North South 351.42 333.61 9.95 9.45 4.79 4.79 13.60 13.60 28.00 28.00 Inlet North1 North1 South3. Souttr" 74.03 294.81 121.92 140.22 2.10 8.35 3.45 3.97 7.1 7.1 7.1 7.1 11.6 11.6 11.6 11.6 Inlet North!* South 130.81 193.61 3.70 5.48 3.7 3.7 Inlet North South 394.09 383.01 11.16 10.85 4.7 4.7 Inlet , Gas flow ACFM DSCFM DSCMM North" South Inlet Outlet Inlet 3-5 Gas composition C02 CO ppm 5.80 7.43 6.06 6.88 Inlet 3 °2 204.62 262.52 214.10 243.02 Outlet 3-4 Sanple volume DSCM DSCF Outlet Isokinetic rate % 247,700 147,000 4,162 gg'oj 296,000 182,000 5,153 ™m*° _ 650,300 376,000 10,650 gjj'^g 107.14 324,600 190,600 5,397 gg'^ 45.10 43.72 346,200 193,100 5,467 *'^ || 8.14 9.03 43.20 41.09 333,300 189,800 5,375 ,gj'jo 29.28 29.18 8.93 9.72 42.92 43.48 341,600 200,300 5,671 ''4 ^5 351.00 335.86 28.14 29.27 18.32 9.18 43.61 44.01 346,400 187,400 5,307 'gjj'gj < 2 < 2 377.55 359.83 29.19 29.16 9.56 9.75 39.62 39.28 312,000 171,460 4,855 JQJ'J* 25.00 25.00 25.00 25.00 < < < < 316.83 364.73 344.38 315.88 29.19 29.16 29.20 29.17 7.79 8.05 7.78 8.02 30.27 30.38 36.43 27.38 492,300 286,000 8,098 ,gj ''j 13.9 13.9 25.00 25.00 < 2 < 2 352.09 330 . 65 29.31 28.25 8.59 17.13 45.23 43.77 351,900 196,200 5,555 gg'^g 13.5 13.5 22.0 22.00 < 2 < 2 374.75 356.59 29.49 29.30 6.98 8.48 45.68 44.20 355,400 201,000 5,692 jpj'jg 2 2 2 2 95.60 50.55 (continued) �TABLE 14 (continued) Date Test (1980) no. Sampling location Inlet 3-13 12 Outlet Inlet 3-14 13 Outlet Inlet 3-15 14 Outlet Inlet 3-17 15 Outlet Inlet 3-18 16 Outlet Inlet 3-19 17 Outlet Inlet 3-20 18 Outlet Inlet 3-22 19 Outlet Inlet 3-23 20 Outlet Sample volume DSCM DSCF Gas composition C02 CO ppm X % 02 Stack THC temperature ppi. °F Molecular weigl.t Moisture X Velocity ft/sec North South 1&4" 2&3 350.46 369.82 158.98 305 . 29 9.92 3.34 10.47 3.34 4.50 5.17 10.35 5.17 15.56 15.56 13.97 13.97 21.00 21.00 18.00 18.00 < < < < 2 2 2 2 361.78 340.61 339.44 315.08 29.53 29.54 29.56 29.28 8.63 8.54 7.10 9.37 42.45 41.41 25.85 26.58 North South 1&4 2&3 374.34 352.11 367.77 351.36 10.60 3.70 14.81 9.97 3.70 14.81 10.42 5.31 13.18 9.95 5.31 13.18 28.00 28.00 30.00 30.00 < < < < 2 2 2 2 384.68 375.70 365.94 358.75 29.31 29.30 29.14 29.15 9.67 9.70 9.60 9.50 43.48 41.49 24.34 24.84 North South 1&4 2&3 276.77 268.37 319.13 307 . 00 6.31 12.59 22.00 6.31 12.59 22.00 8.37 10.67 19.00 8.37 10.67 19.00 < < < < 2 2 2 2 368.23 357.65 319.42 356.65 29.27 28.32 29.09 29.10 8.14 7.68 7.88 7.83 North South 1&4 2&3 359.80 390.47 406.86 391.84 10.19 11.06 11.52 11.10 3.73 3.73 5.43 5.43 14.40 14.40 12.90 12.90 < < < < 2 2 2 2 371.23 348.41 354.56 345.31 29.35 29.44 29.21 29.25 North South 1&4 2&3 369.16 371.50 392.69 353.25 10.45 10.52 11.12 10.00 3.82 14.39 3.82 14.39 5.42 13.00 5.42 13.00 23.00 < 2 23.00 < 2 24.00 < 2 24.00 < 2 381.96 354.96 360.06 357.50 North South 1&4 2S3 349 . 7 1 9.90 3.60 14.40 368 . 75 10.44 3.60 14.40 374.30 10.60 5.30 13.00 360.58 10.21 5.30 13.00 2 2 2 2 North South0 ISA 2&3 347.89 368 . 08 356.20 388.52 9.85 3.80 13.80 22.00 < 2 10.42 3.80 13.80 22.00 < 2 10.09 6.00 12.50 17.00 < 2 11.00 6.00 12.50 17.00 < 2 North South 1&4 2&3 363.46 348.60 402.14 401.16 10.29 3.60 14.20 9.87 3.00 14.20 11.39 5.30 12.70 11.36 5.30 12.70 North South 1&4 2&3 336.53 330.73 301.61 358.98 9.53 9.37 8.54 10.17 7.83 7.60 9.04 8.69 6.00 12.60 6.00 12.60 9.70 10.00 9.70 10.00 22.00 22.00 22.00 22.00 24.00 24.00 26.00 26.00 38.00 38.00 38.00 38.00 < < < < Gas flowb ACFM DSCFH Isokinetic rate Dscrm 332,100 187,100 5,298 326,700 193,600 5,481 336,000 185,400 5,250 306,506 170,300 4,822 30.85 29.96 20.00 21.31 240,400 135,400 3,834 257,500 152,100 4,307 8.83 8.17 8.71 8.43 41.89 42.84 26.01 27.27 335,000 189,000 5,351 332,100 191,500 5,423 29.29 29.37 29.24 29.18 9.36 8.73 8.62 9.09 43.06 41.89 27.12 25.60 335,900 186,300 - 5,274 328,600 187,800 5,319 380.28 361.59 373.12 365.94 29.29 29.37 29.03 29.24 9.68 8.68 10.28 8.59 41.87 43.42 26.75 26.92 337,300 184,300 5,218 334,500 185,300 5,246 350.96 342.65 338.12 342.81 29.33 29.39 29.29 29.21 8.31 7.86 7.79 8.44 42.13 42.11 24.63 26.91 333,100 191,000 5,408 321,200 188,400 5,334 < < < < 2 2 2 2 348.64 342.09 340.00 330.60 29.36 29.41 29.19 29.24 8.54 8.07 8.61 8.23 41.65 39.63 26.26 26.81 321,400 185,000 5,239 330.700 195,500 5,537 < < < < 2 2 2 2 364.41 355.41 354.13 338.13 29.26 28.69 28.82 29.28 8.16 12.74 9.73 5.87 28.65 27.26 16.63 19.70 221,100 121,500 3,440 226,400 132,800 3,761 X 102.35 102.23 77 .72 91.73 101.27 107.20 99.80 96.74 102.11 108.67 104.05 96.83 1 06 . 85 99.99 107.18 95.48 100.17 108.07 99.82 93.81 107.21 97.16 101.03 92.62 92.21 104.31 95.09 97.71 105.17 96.42 104.10 99.03 103.54 115.99 110.45 102.66 (continued) �TABLE 14 (concluded) Test Date (1980) no. 3-24 21 3-25 22 3-26 23 Sampling location Outlet 1,2, 3S4 North1" Southp Outlet 1,2, 3&4 Sample volume DSCF DSCM 02 % Gas composition C02 CO THC % ppm ppm 130.42 3 6 . 9 5.4 13.2 122.79 3.48 5.4 Stack Isokinetic temperature < 2 Molecular °F Moisture Velocity % ft/sec weight 365.47 29.15 9.53 25.76 Gas flow ACFM 160.500 DSCFM rate DSCMM 90,170 2,553 % 103.72 T , Inlet North South Outlet 1,2 3S4 Inlet 326.82 344.98 138.67 13.2 9.26 6 0 12.60 . 0 9.77 6 0 12.60 . 0 3.93 4 8 13.70 . 0 < 2 356.40 29.10 9.92 24.58 < 2 <2 < 2 380.80 382.45 364.38 29.13 29.14 29.24 9.17 9 0 . 9 9.26 37.23 37.40 26.42 153,200 87,030 2,464 101.06 , fi 106.24 1 2 5 0 6 4 6 2 ' '0 ' 0 118.43 164,700 93,240 2,640 106.64 2 5 1 0 9 0 a Average values for duration of test. b Sun of flow through total inlet and total outlet. c Low volume collected due to high leak rate at end. Volume was corrected for leak rate. Test quality fair. d Low volume collected due to freezing of impingers. e At 250 rain, noted nozzle pointed in wrong direction. Switched nozzle from 0.312 to 0.250 in. diameter tip to maintain isokinetic flow. Test quality was good for gas and fair for particulate. f Switched nozzle from 0.312 to 0.237 in. diameter tip to maintain isokinetic flow. g Due to snow and icy conditions, no sample was obtained. h Cancelled per instructions of EPA until 3/13/80. i Switched nozzle from 0.250 to 0.310 in. diameter tip to maintain isokinetic flow. j Switched nozzle from 0.310 k Probe found broken at 140 min, no samples retained. conditions. Test quality was fair. 1 No solutions retained due to backup of H202 into all impingers. • QA test cancelled after 240 min due to leak at one of the probe tips. n Test stopped at 296 min due to continual freezing of the train components. o Problems with the Batelle trap freezing and leaks in the Teflon line were encountered. Test quality was fair to good. p QA test only. Test quality was good. to 0.240 with diameter tip to maintain isokinetic flow. Test restarted with a new probe but only one half the duct was traversed due to freezing The resin, cyclone and filters were retained. Test quality was fair. Test quality was fair to poor. The filter and traps were replaced to solve leak problems. No samples were saved because nozzle was in the wrong direction nnd the test would not be duplicate. �TABLE 15. AVERAGE PROCESS DATA FOR THE AMES MUNICIPAL POWER PLANT, UNIT NO. 7 24-hr Process data Standard deviation Mean Flue gas test duration process data Standard deviation Mean Steam flow rate (1,000 Ib/hr) 255 35 289 50 Steam pressure (psig) 852 3 853 3 Steam temperature 892 3 896 5 Feedwater flow rate (1,000 Ib/hr) 263 37 298 51 Feedwater temperature 366 16 377 19 (°F) Fuel feed rate 1 (1,000's Ibs/hr) 2 30.4 30.6 3.2 3.4 33.1 Fuel oil (gal./hr) 10.7 11.2 - - I.D. fans amps 45 1 46 2 I.D. fans pressure (psig) F.D. fans amps 5.5 0.7 1 29 5.9 30 4.2 1.0 1.1 F.D. fans pressure (psig) 4.0 0.6 4.5 0.9 Furnace draft (psig) 0.6 - 0.6 0.1 Flue gas temperature Boiler exit3 ESP inlet3 Ambient temperature (°F) 667 323 (°F) Ambient pressure in. Hg 24 15 31 13 29.01 a Not total time means. 38 0.13 674 326 39a 29.01 31 18 20 0.13 �The daily mean of gross electrical output (24-hr basis) was typically between 29 and 32 MW due to boiler operation at full output for a large portion of the day. In fact, the hourly readings indicated that output was rarely below 35 MW between the hours of 8 AM and 10 PM or longer. During non-peak hours the boiler operated between 16 and 25 MW, depending on load and the amount of power being purchased from neighboring utilities. Fuel consumption varied directly with the amount of electricity produced. Of the three types of fuels used in Unit No. 7 (coal, RDF, and fuel oil), coal was used in the largest quantity. The amount of RDF burned was limited to approximately 17% in terms of the total heat produced. This was because RDF, due to its lower heating value, cannot sustain sufficient temperatures to maintain required boiler efficiency and steam quality. Also, RDF requires a longer residence time in the boiler for complete combustion, and this places another physical restriction on the amount of RDF in the fuel mixture. Fuel oil is used sparingly, and only as an igniter to insure flame continuity during soot blowing. The large variations in fuel oil consumption noted in Table 15 were more related to operating practices than to the boiler requirements. The means and standard deviations for coal consumption follow those of the gross electrical output. This indicates that coal consumption is closely related to electrical output, as expected. However, these daily averages mask out one important effect. The amount of coal burned depends on whether there is RDF in the mixture or not. All other things being equal, the flow of coal will always go up or down, depending on whether RDF is being removed or introduced into the mixture, respectively. Data for the steam cycle in the boiler are also listed in Table 15 on an average basis. Examination of the data on a daily basis indicated that the steam and feedwater flow rates fluctuate in a daily cycle, with means and standard deviations following the gross electrical output. However, the values for steam temperature and pressure remain fairly constant. The feedwater temperature also varied. It was higher on days of high electricity production, and lower on days of low production. The induced and forced draft fan measurements listed in Table 15 are of limited significance, since they did not respond to increases in production with greater airflows and correspondingly greater current consumption. The furnace draft data indicated little or no correspondence to any of the other measured data. Most of the flue gas and ESP inlet temperature readings were incomplete as they did not cover the entire 24-hr day. Most of this information was recorded during peak operation, and may therefore be considered representative for peak operation conditions. Both the flue gas and ESP inlet temperatures decreased during off-peak periods. The continuous supply of RDF to the boiler during the test was found to be unreliable. The RDF conveyors which feed Unit No. 7 were prone to jamming and required frequent maintenance. Often the RDF supply ran out because the solid waste recovery plant was experiencing mechanical problems, or had run out of refuse to process. The durations of RDF-firing during the flue gas sampling periods are shown in Table 16 along with the mean coal feed rates. 39 �TABLE 16. FUEL COMBUSTION DURING FLUE GAS SAMPLING Date Test period Mean coal feed rate (1,000 Ib/hr) 3/2/80 3/3/80 3/4/80 3/5/80 3/6/80 3/7/80 3/8/80 3/9/80 3/10/80 3/11/80 3/12/80 3/13/80 3/14/80 3/15/80 3/17/80 1120-2000 0920-1855 0900-1800 0900-1820 0840-2140 0850-2220 0840-2215 0830-2211 0810-1733 0825-2235 0910-1315 0835-2147 0840-2255 0905-2206 0849-2225 0900-2325 0843-2407 33.5 32.6 3/20/80 3/22/80 3/23/80 3/24/80 3/25/80 3/26/80 0905-1625 0947-1412 0927-1410 1110-1547 1120-1546 0922-1406 None 1100-1530 Entire run 1020-finish 0900-finish 1230-finish 0900-finish None 1512-finish Entire run Entire run 1608-finish Entire None 1010-1105 1340-finish Entire run Start-1310 1610-finish 1100-1135 Start-1212 None Entire run Entire run Start-1330 34.9 36.2 34.3 35.5 35.4 35.7 32.1 25.2 36.3 33.8 35.1 38.6 34.4 23.0 35.1 3/18/80 3/19/80 RDF feed period 33.3 33.2 21.4 33.1 33.8 35.1 Mean RDF density (lb/ftS) . 5 4.7 5 4.3 4 3.7 4 4 4.3 4.3 4.5 NAa 3.7 4 3.5 4 3.8 3.3 a NA = not available. Out of 23 days of sampling, RDF was burned during the entire test run for only 7 days. On 12 days RDF was burned part of the time, and on 4 days it was not burned during the flue gas sampling. Routine activities such as ash removal and soot blowing were performed at times designated in the test plan. RDF was observed to have a substantially higher ash content than coal, and this characteristic was reflected by longer ash removal periods, and more periodic soot blowing. Both activities decreased substantially when RDF was not being burned. Table 17 contains information on daily production and consumption at the Ames Municipal Power Plant, Unit No. 7 recorded by the power plant operators 40 �TABLE 17. DAILY PRODUCTION AND CONSUMPTION AT AMES MUNICIPAL POWER PLANT, UNIT NO. 7 Date 3/2/80 3/3/80 3/4/80 3/5/80 3/6/80 3/7/80 3/8/80 3/9/80 3/10/80 3/11/80 3/12/80 3/13/80 3/14/80 3/15/80 3/17/80 3/18/80 3/19/80 3/20/80 3/22/80 3/23/80 3/24/80 3/25/80 3/26/80 a Power production (kwh) gross net Thermal energy (Btu/kwh) net gross 681,000 709,000 761,000 759,000 7000 4,0 735,000 648,000 494,000 693,000 739,000 7000 5,0 742,000 729,000 5800 0,0 699,000 759,000 748,000 753,500 7600 0,0 426,000 710,000 700,000 726,000 11,186 11,296 11,396 11,697 11,693 11,652 11,602 11,524 10,955 11,440 11,348 11,544 11,537 11,434 11,170 10,855 10,794 11,368 11,077 11,311 10,841 11,080 10,949 623,902 648,682 700,072 698,461 679,858 674,470 590,057 443,496 635,037 678,629 6846 8,5 681,889 668,119 457,939 639,942 696,494 682,596 689,205 647,644 382,263 650,039 642,011 664,973 12,210 12,346 12,388 12,711 12,728 12,697 12,742 12,836 11,985 12,458 12,362 12,562 12,588 12,684 12,201 11,829 11,829 12,388 12,075 12,605 11,841 12,081 11,954 Steam production (Ib/kwh) 9.57 9.59 9.53 9.73 9.50 9.64 9.54 9.47 9.54 9.57 9.62 9.68 9.51 9.50 9.59 9.52 9.51 9.56 9-55 9.49 9.61 9.52 9.60 Iowa coal (Ibs) 339,988 418,330 412,290 434.538 432,096 427,127 358,286 301,888 486,980 334,328 408,980 432,270 412,440 322,448 412,335 417,010 414,315 445.392 410,520 269,610 629,920 610,880 612,960 This value is derived from the average Btu content of each fuel, b This is only a rough measure of RDF weight. Fuel consumption L RDF" Colorado coal (Ibs) (Ibs) 432,712 342,270 351,210 370.162 339,504 378,773 317,720 267,712 262,220 392,472 334,620 368,230 324,060 253,352 337,365 341,190 338,985 379,408 335,880 220,590 157,480 152,720 153,240 0 113,000 226,800 192,375 213,200 130,800 168,460 26,000 81,200 229,600 229,075 144,075 230,400 22,050 97,650 154,874 134,816 63,700 92,000 0 51,600 93,000 134,970 Oil (gal.) 60 160 70 60 90 100 130 150 100 270 290 50 90 910 70 60 100 490 640 800 490 680 40 Sluice water for bottom and fly ash Removal (gal.) 250,000 340,000 320,000 380,000 450,000 320,000 360,000 314,908 386,716 403,172 413,644 422,620 418,132 335,104 396,000 473,000 477,000 320,000 250,000 180,000 300,000 430,000 540,000 Water input to evaporator (gal.) 8,300 9,000 2,200 6,800 9,200 2,500 1,120 8,500 6,300 5,800 3,500 9,100 0 5,700 11,100 15,200 6,000 7,300 5,400 16,600 4,500 4,000 18,500 �on a daily basis. The total gross and net power production was recorded directly from meters inside the plant. The total steam produced divided by the gross power production gave a good indication of boiler efficiency. Separate meters were used for measuring the water used for ash removal and the total input to the evaporators. The days of highest sluice water use corresponded with days of prolonged use of RDF in the fuel mixture. The evaporators eventually feed into the working fluid cycle of the boiler, and gave a fair indication of make-up water required, except that there was a water reclamation system attached to the boiler. Hence, these values indicated new input to the system, but did not account for total make-up water requirements. Most of the fuel types were very accurately measured. Coal was measured through a weight integrating system, and fuel oil was similarly measured through a volume integrating system. However, no accurate measurement of the RDF was possible. The values listed were derived from volumetric readings and a very rough measurement of the RDF density, taken once every shift. Although rough estimates of the RDF content were made, there was no effective means for obtaining a representative sample of the refuse mixture. The variability of the RDF in the total pulverized mixture is reflected in the results for TOC1 and inputs and emissions of cadmium from this plant. The BTU contribution of each fuel was then calculated by doing calorimetric analyses. This was done periodically, and the values used for the duration of this test program are given in Table 18. By summing the Btu contribution of each fuel, a value for total heat production was found. This value was then divided by either the gross or net electricity production to express thermal energy as it related to the power production of the day. CHICAGO NORTHWEST INCINERATOR, UNIT NO. 2 The field test activity took place from April 30, 1980 to May 23, 1980. All required tests were completed and all recovered samples were sent to GSRI for analysis. A summary of the reduced flue gas data (inlet and outlet) on a daily basis as calculated from the field data sheets is presented in Table 19. Events that may influence the quality of the tests are also noted on this table. The process parameters considered to be important to the operation of Boiler No. 2 included the steam flow rate, steam pressure, feedwater flow rate, feedwater temperature, combustion air flow rate, combustion air temperature, % oxygen, I.D. fan pressure, F.D. fan pressure, furnace draft and furnace temperature. Most of this data was available from instrumentation in the control room. Table 20 summarizes this plant process data in terms of the average values of the typical sampling date operations. This data is presented in terras of 24-hr plant operation and the flue gas test period durations. Although there are some slight variations, the values are readily comparable for the two time intervals. A comparison of the daily process data with the average of the data collected indicates that the Chicago Northwest Incineration facility operated in essentially the same mode 24 hr a day, 7 days a week. Although major changes in steam production were noted to occur over short time intervals (less than 1 hr) no significant variation in steam production occurred day to day indicating a rather consistent fuel feed rates during the duration of the tests. 42 �TABLE 18. HEAT CONTENT OF FUELS USED AT THE AMES MUNICIPAL POWER PLANT DURING SAMPLING PERIOD Duration of test Heat content for each fuel type Colorado Fuel oil coal RDF Iowa coal (Btu/gal.) (Btu/lb) (Btu/lb) (Btu/lb) 3/2/80 thru 3/16/80 8,946 10,556 5,587 138,603 3/17/80 thru 3/26/80 9,035 10,298 6,128 138,603 �TABLE 19. DAILY DATA SUMMARIES FOR FLUE GAS MEASUREMENTS, CHICAGO NORTHWEST INCINERATOR, BOILER NO. 2 Date Test (1980) No. Sampling location Sample volume DSCM DSCF North0 256.84 South6 135.20 Outlet North 317.86 South 324.14 Inlet 5-4 1 2 3 4 5 6 7 8 9 10 2 2 2 2 459.47 444.88 432.76 451.27 28.26 28.52 28.33 28.41 11.56 9.57 11.56 10.87 20.17 21.27 36.40 39.33 111,400 56,500 102,200 51,830 Isokinetic rate % 1,600 1,468 459.04 445.78 442.00 451.04 28.53 28.56 28.45 29.58 12.24 12.03 12.47 2.95 20.62 18.42 38.21 40.60 104,300 51,300 1,453 106,400 55,310 1,566 North South Outlet North South 324.36 400.66 403.32 407.07 9.19 11.34 11.42 11.53 9.4 9.4 9.4 9.4 9.8 9.8 9.7 9.7 185 185 189 189 < < < < 2 2 2 2 445.55 431.46 459.04 457.78 28.34 28.36 28.39 28.41 13.43 13.26 12.86 12.75 19.90 21.23 36.70 38.87 110,900 54,930 1,555 102,000 49,780 1,410 North South, Outlet North South 331.52 370.83 427.50 457.50 9.39 10.50 12.11 12.96 9.9 9.9 10.4 10.4 9.5 9.5 8.9 8.9 142 < 142 < 169 < 169 < 2 2 2 2 445.36 460 . 60 454.20 464.32 28.57 28.50 28.82 28.47 11.27 11.85 8.60 11.60 19.34 19.96 38.39 41.69 105,600 52,770 1,494 108,100 54,430 1,541 North* SouthJ North Outlet South 342.70 367.81 371.55 383.75 9.77 10.42 10.52 10.87 7.9 7.9 8.1 8.1 10.5 10.5 10.7 10.7 61 61 59 59 < < < < 2 2 2 2 423.77 460.80 449.64 437.76 28.30 28.20 28.17 28.24 14.14 14.94 15.46 14.89 17.71 17.31 32.99 32.48 93,900 45,870 1,299 88,400 42,770 1,211 North South. K Outlet North South 320.56 347.61 367.97 412.06 9.08 9.84 10.42 11.67 8.8 10.3 8.8 10.3 9.4 9.7 9.4 9.7 1 1 1 1 < < < < 2 2 2 2 452.59 457.63 448.92 452.28 28.37 28.34 28.50 28.33 13.62 13.83 11.94 13.40 18.12 17.86 35.43 39.50 96,530 46,250 1,310 101,200 49,320 1,397 North South 1 Outlet North " South™ 344.80 378.50 299.62 459.63 9.76 10.72 8.49 13.02 9.8 9.8 9.8 9.8 9.0 9.0 9.5 9.5 1 1 1 1 < < < < 2 2 2 2 463.29 462.48 462.53 447.47 28.19 28.15 28.37 28.30 13.86 14.24 12.91 13.52 19.12 18.51 38.99 38.13 101.000 48,280 1,367 103,900 50,470 1,429 North South Outlet North South 316.55 373.03 376.48 391.17 8.96 10.56 10.66 11.08 8.7 8.7 10.4 10.4 9.7 9.7 9.0 9.0 1 1 1 1 < < < < 2 2 2 2 456.24 468.33 442.84 452.88 28.40 28.38 28.41 28.42 12.57 12.79 12.21 12.08 17.58 19.11 36.73 39.17 98,830 47,970 1,358 102,500 50,800 1,438 North South Outlet North South 308.73 364.16 366.28 388.73 8.74 10.31 10.37 11.01 9.7 9.7 9.1 9.1 9.6 9.6 9.8 9.8 1 1 1 1 < < < < 2 2 2 2 465.61 468.65 457.16 453.52 28.19 28.19 28.25 28.20 14.57 14.52 14.10 14.54 16.42 17.82 36.85 39.39 92,240 43,330 1,227 102,900 49,060 1,389 North 338.45 South 376.86 Outlet North" 377.44 South 396.28 9.59 10.67 10.69 11.22 10.2 10.2 9.6 9.6 9.4 9.4 9.7 9.7 111° 111 98 98 < < < < 2 2 2 2 465.43 458.88 459.56 463.68 28.29 28.27 28.88 28.24 13.60 13.75 8.89 14.22 18.05 17.67 35.47 38.49 95,870 46,760 1,324 99,850 49,810 1,410 Inlet 5-15 < < < < 2 2 2 2 Inlet 5-13 172d 172 156 156 < < < < Inlet 5-12 7.4 7.4 7.7 7.7 159 159 171 171 Inlet 5-11 11.2 11.2 11.3 11.3 10.1 10.1 9.5 9.5 Inlet 5-10 7.27 3.83 9.00 9.20 9.6 9.6 10.4 10.4 Inlet 5-9 DSCMM 11.57 10.74 11.85 12.97 Inlet 5-8 ACFM Gas flowb DSCFM 408.46 379.18 418.43 457.89 Inlet 5-7 Stack temperature Molecular Moisture Velocity weight »F ft/sec % North South Outlet North 8 South Inlet 5-6 Gas composition 02 C02 CO THC % % PP» ppm (continued) 90.82 79.24 94.61 97.96 96.25 98.32 98.85 93.23 98.17 97.71 100.75 96.29 100.22 97.28 96.59 100.04 99.85 101.90 105.57 107.99 108.82 105.61 98.61 96.51 100.85 100.82 99.20 102.22 98.95 94.93 102.67 100.42 105.23 102.11 104.01 102.82 102.87 102.67 102.40 106.30 �TABLE 19 (continued) Date Test (1980) No. Sampling location North South Outlet North South 353.83 357.30 404.61 416.58 Inletp North South Outletp 324.92 331.75 218.81 Inlet 5-16 11 5-17 12 5-18 13 Inlet North South Outlet 5-19 -PLn ,4 Sample volume DSCF DSCM I-l=t Outlet ACFM Gas flow DSCFM DSCMM Isokinetic rate % 465.32 467.67 455.72 460.24 28.49 28.42 28.35 28.38 11.15 11.69 11.79 11.59 18.79 18.22 99,300 49,200 1,395 '93 'ol 40^83 117,500 58,310 1,651 {oi'<;2 80 < 2 80 < 2 84 < 2 474.80 475.00 451.00 28.27 28.37 28.16 13.47 13.70 14.38 17.25 16.85 39.27 91,430 106,000 43,540 51,350 1,233 1,454 *£•*£ 103.01 r 463.00 28.25 13.91 44.37 119,800 57,360 1,624 92.45 r 465.60 28.36 11.65 44.53 120,200 59,140 1,675 98.36 8.5 8.5 7.9 7.9 9.20 10.3 9.40 10.3 6.20 10.7 10.0 10.0 9.0 6.20 10.7 9.2 102 6.81 12.7 7.2 304 88° 88 98 98 < < < < Velocity ft/sec 2 2 2 2 11.1 11.1 11.8 11.8 10.02 10.12 11.46 11.80 , Moisture q 219.36 North South Gas composition3 Stack 02 C02 CO THC temperature Molecular ppm ppoi °F weight q 240.61 a b c d e f g h i j k 1 m n Average during test period. Sum of the North and South train measurements. Test was run for 350 nin. Test was discontinued because of unsuccessful leak checks after filter replacement. High due to excessive instrument drift. Test ran for only 193 nin due to plant shut down because of a boiler leak. Only 21 of the required 24 points were traversed. Test quality was poor due to crack in the probe. Low moisture obtained because of cracked probe. Sampling time increased from 20 to 25 min per point after 180 min. Test quality was good. Sampling time increased from 20 to 25 min per point after 267 min. Test quality was good. Test was halted one point from completion due to stormy water. Test quality was good. Analyzer taken off line (see d). Due to excessive leak rate in the north tracer, 60% of the sample was collected with the south tracer, 40% with the north. Probe was found with a cracked tip. Based on 8.9% moisture versus 12% moisture for the other tests, it was determined that only the last 10 points were traversed with the broken probe. Test quality was fair. o Results ± 10% due to drift, p Inlet QA test, outlet 1st day cadmium test, q Inlet sample not required for cadmium test, r THC data not required for cadmium test. �TABLE 20. MEANS OF THE MEANS FOR PROCESS DATA, ALL TEST DAYS, CHICAGO NW INCINERATOR, BOILER NO. 2* Parameter Steam flow rate (Ibs/hr) Disc recorder Chart recorder Digital integrator Steam pressure (psig) Feedwater flow rate (Ibs/hr) Chart recorder Digital integrator Feedwater temperature (°F) Combustion air flow rate (ft3/hr) Chart recorder Digital integrator Combustion air temperature (°F) 24-hr process data Standard Mean deviation Flue gas test duration process data Standard deviation Mean 99,000 103,000 99,000 4,500 4,500 3,600 100,000 104,000 100,000 8,100 8,300 10,300 282 4 287 2 99,000 97,000 4,800 5,400 101,000 100,000 8,400 11,000 221 1 221 1 79,000 72,000 2,000 2,600 78,000 70,000 2,700 2,200 663 21 673 23 I.D. fans pressure (inches HgO) 2 .6 0.2 2.5 0.3 F.D. fans pressure (inches HgO) 14 .1 0.4 14.1 0.6 Furnace draft (inches ^ ) 0 Furnace temperature (°F) a 0.23 1,160 From Appendix B. 46 0.06 42 0.22 1,198 0.8 67 �Additional information collected for daily process tables included the times of soot blowing, fuel input to Boiler No. 2, down time on Boiler No. 2, daily barometric pressure and miscellaneous comments concerning the boiler operation. Soot blowing was to follow a set schedule of three times per day, although deviations from this schedule were observed. Barometric pressure was obtained once per day from nearby Midway airport and deviations from typical plant operation were noted from the operator's log book. The measurement of fuel input posed a somewhat more difficult problem. All refuse and residue hauling trucks entering and leaving the incinerator plant were carefully weighed. This facilitated the accurate characterization of overall inputs and outputs. However, there was no accurate way of proportioning these materials between specific boilers for a given period of time. Attempts to determine the fuel burned or ash discharged from Boiler No. 2 were approximations. Chicago Northwest Incinerator maintains inventory sheets listing inputs and outputs from the facility on a weekly basis. Relevant data from these sheets are reproduced in Table 21. The weight of refuse received was measured on scales before and after the refuse trucks released their loads. The volume of refuse received was determined by multiplying the number of truck loads by the volume of each truck (19.5 cubic yards). Density of the refuse was estimated using these two measurements, and is therefore the density of refuse inside the trucks. In order to quantify the amount of refuse burned, the number of loads, or charges, handled by the grab bucket cranes were noted for each boiler. The total number of charges to Boiler No. 2 for daily operations are given in Table 22. To approximate the amount of refuse burned in Boiler No. 2, it was necessary to determine an average weight per charge. When refuse trucks enter the plant, they discharge their contents into a large storage pit. Although the weight of refuse added to the pit is well characterized for each weekly period, the carry-over of material from week to week cannot be accurately measured. Furthermore, this carry-over is quite variable over the length of time being considered. It is necessary to quantify the carry-over in terms of weight, so that the total weight of refuse burned, and hence, the average weight per charge, can be approximated. The calculation of the average weight per charge involves using visual measurements of the pit volume taken at the end of each week. This "pit estimate" can then be used in association with the density of the incoming garbage to approximate the weight of refuse in the pit. The average weight per charge can be determined by the following equation: Average wt per charge _ (pit estimate for previous week - pit estimate + refuse delivered) total number of charges All terms in parenthesis must be expressed as weights. This method, however, has a drawback in that the density in the pit is probably not the same as the density inside the refuse trucks, since the refuse inside the trucks is compacted and is liable to expand somewhat as the trucks are unloaded. 47 �TABLE 21. WEEKLY INVENTORIES OF REFUSE AND RESIDUE AT THE CHICAGO NW INCINERATOR (ALL BOILERS) 4/28/80 to 5/4/80 Refuse received By weight (tons) By volume (cu yd) Density (lbs/yd3) Storage pit condition At beginning of week (% full) At end of week ( full) % Refuse consumed No. charges burned Average weight per charge (Ibs) Total weight (tons) Total volume (cu yd) Residue Fine ash fraction (tons) Fine ash fraction (cu yd) Metal fraction (tons) Metal fraction (cu yd) Total ash (tons) Total ash (cu yd) 5/5/80 to 5/11/80 5/12/80 to 5/18/80 5/19/80 to 5/25/80 6,747 24,490 551 9,152 29,618 618 7,902 26,561 595 8,720 28,778 606 84 65 61 42 65 61 42 42 5,205 2,771 5,710 3,240 5,952 2,812 4,714 3,700 7,212 28,562 9,250 36,634 8,367 33,138 8,720 34,535 2,511 3,100 949 5,423 3,460 8,523 2,500 3,086 750 4,286 3,250 7,372 1,815 2,240 1,514 18,651 3,329 10,891 2,904 3,585 629 3,594 3,533 7,179 Volume reduction thru incineration 70% 80% 67% 79% Weight reduction thru incineration 52% 65% 60% 60% 48 �TABLE 22. CHARGES FED TO BOILER NO. 2 ON A SHIFT BASIS CHICAGO NORTHWEST INCINERATION FACILITY No. of Date, shift charges No. of Date, shift charges No. of Date, shift charges No. of Date, shift charges 4-28, 5-12, 2nd 3rd 99 99 5-19, 2nd 3rd 110 105 2nd 3rd 98 99 5-5, 4-29, 1st 2nd 3rd 100 94 101 5-6, 1st 2nd 3rd 68 112 5-13, 1st 2nd 3rd 100 100 60 5-20, 1st 2nd 3rd 104 118 110 4-30, 1st 2nd 3rd 90 94 101 5-7, 1st 2nd 3rd 99 84 100 5-14, 1st 2nd 3rd 96 5-21, 1st 2nd 3rd 100 106 90 5-1, 1st 2nd 3rd 94 49 98 5-8, 1st 2nd 3rd 81 101 100 5-15, 1st 2nd 3rd 104 106 108 5-22, 1st 2nd 3rd 80 105 100 5-2, 1st 2nd 3rd 100 98 101 5-9, 1st 2nd 3rd 100 98 100 5-16, 1st 2nd 3rd 106 97 110 5-23, 1st 2nd 3rd 107 107 102 5-3, 1st 2nd 3rd 100 102 99 5-10, 1st 2nd 3rd 99 101 100 5-17, 1st 2nd 3rd 112 97 114 5-24, 1st 2nd 3rd 98 105 94 5-4, 1st 2nd 3rd 97 96 12 5-11, 1st 2nd 3rd 102 101 105 5-18, 1st 2nd 3rd 108 104 118 5-25, 1st 2nd 3rd 101 105 107 5-5, 1st 5-12, 1st 103 5-19, 1st 105 5-26, 1st 105 Total for week 1,823 2nd 3rd - 1,754 1,943 49 2,159 �It seems likely that the level of compression would have a more pronounced effect upon the refuse density than the actual characteristics of the refuse. Since the compaction inside the pit is always similar, one would also expect the density in the pit to be reasonably constant. The plant personnel indicated that the typical refuse density was 505 Ib/cu yd. Therefore, this value can be used as an assumed density, and the pit estimates used in the equation: Volume of refuse in pit = P*t estimate ( of tota^volume) x total pit volume % total pit volume = 9,700 cu yd Weight of refuse in pit = volume of refuse in pit x refuse density in pit assumed refuse density = 505 Ib/cu yd Weight of refuse incinerated per week = (weight of refuse in pit at beginning of week - weight of refuse in pit at end of week + weight of refuse delivered) . ,. , total weight of refuse incinerated A Average weight per charge = total number of charges Volume of refuse incinerated = weight of refuse incinerated assumed refuse density The amounts of fine ash and metal fractions produced by the incinerator during the test period are listed in Table 21. It should be noted that these are the amounts leaving the plant during this time period, and are not necessarily the same as the ash being produced during this period. Since no account has been taken of any carry-over from week to week, it can only be assumed the carry-over is similar each week. In order to obtain total ash, the metal and fine ash fractions were summed together. The ash volumes were calculated using the following densities: Density of fine ash fraction = 1,620 Ib/cu yd (960 kg/m3) Density of metal fraction = 350 Ib/cu yd (210 kg/m3) These values were based on previous analyses done by the plant, and have been assumed to be typical. Since all of the combined ash was subjected to a water quench, these weights incorporate a rather large moisture content. However, no better characterization was available. The volume and weight reductions achieved through incineration have been calculated as an indication of how efficiently the boilers were operating. Due to the heterogeneous nature of the refuse used to fuel this plant, it was very difficult to obtain representative samples for laboratory analyses for organic compounds and cadmium. The previous discussion of the approximation of refuse burned in Unit No. 2 reflects an additional problem in previding accurate information for the levels of the analytes introduced as inputs to this combustion source. Both the variabilities of TOC1 and cadmium 50 �and the agreement of cadmium between the inputs and emissions from the plant were highly affected by the difficulty of obtaining representative refuse samples. 51 �SECTION 8 ANALYTICAL RESULTS AMES MUNICIPAL POWER PLANT, UNIT NO. 7 Organics The results of TOC1 determinations in flue gas inlet and outlet samples from the Ames plant are shown in Tables 23 and 24, respectively, along with the recoveries observed for the surrogate spiking compounds. The results for plant background air particulates, ESP ash, bottom ash, coal, RDF, bottom ash quench influent water (cooling tower blowdown), bottom ash quench overflow water, and untreated well water (plant intake water) are shown in Tables 25 to 32. These results, as well as all other results in this report, are shown uncorrected for surrogate recoveries. The coal extracts apparently contained very high levels of hydrocarbons. Hence, the Hall detector used for TOC1 assays required cleaning after only one to two analyses. Hence, TOC1 assays were completed on only six coal extracts. Organic chlorine was not detected by the TOC1 procedure in any of the field blanks, method blanks, or flue gas first impinger extracts. In general, the surrogate recoveries were good in all samples. The recoveries for dg-naphthalene (typically 50-80%) were generally lower than for djg-chrysene (typically 70-100%). This is likely due to the much higher volatility of naphthalene compared to chrysene. Hence, naphthalene losses may be partially attributed to volatility losses during extract concentration. The results of determinations of PAH compounds and additional compounds identified in the composite extracts are shown in Table 33. In addition to PAH compounds, chlorinated benzenes and phenols were identified in some samples. Notably, phenol was detected at parts-per-million concentrations in the coal extracts. Phthalate esters were also identified in RDF and ash samples. As anticipated, phthalate levels were high in the RDF extracts. Low levels of phthalate esters were also identified in the composite flue gas extracts, although the levels were similar to those observed in the flue gas train blanks. The levels of phthalate esters in the train blank ranged from 0.3 to 4 pg/dscm. The results of HRGC/MS-SIM analysis of the composite Ames flue gas outlet extracts for PCBs are shown in Table 34. These results are similar to those obtained by Richard and Junk7 for the Ames Unit No. 7. The primary chlorobiphenyl compounds identified were tetra- through hexachloro-substituted. 52 �TABLE 23. TOC1 AND SURROGATE RECOVERY RESULTS FOR THE AMES FLUE GAS INLET SAMPLES TOC1 Sample volume (dscm) Mass (ng) Cone, (ng/dscm) Surrogate recovery dl2~Chrysene dg-Naphthalene () % () % Test day Date 1 3-2 13.23 3,210 243 2 3-3 17.41 20,000 1,150 63, 85 100, 100 3 3-4 12.38 9,480 766 61, 82 98, 79 4 3-5 14.27 6,480 454 31 33 5 3-6 19.56 18,600 951 57 58 6 3-7 20.79 8,560 412 51 82 7 3-8 19.40 7,110 367 43 60 8 3-9 17.87 7,350 411 44, 48 76, 74 9 3-10 9.18 7,650 833 55 81 10 3-11 22.01 12,400 562 42 63 11 3-12 12 3-13 20.39 11,600 568 59 76 13 3-14 20.57 11,500 559 54 81 14 3-15 15.43 6,320 410 49 87 u> 0 85 Test scrubbed (continued) �TABLE 23 (concluded) TOC1 Test day Date Sample volume (dscm) Mass (n«) Cone, (ng/dscm) Surrogate recovery di2-Chrysene dg -Naphthalene ( W () % 15 8,170 394 120 86 3-18 20.97 22,600 1,080 45 39 17 3-19 20.34 6,390 314 63 60 18 3-20 20.27 13,100 647 54 52 19 3-22 20.16 6,330 314 103 87 20 .p- 21.25 16 Ul 3-17 3-23 18.90 4,780 253 50 55 �TABLE 24. TOC1 RESULTS AND SURROGATE RECOVERIES FOR THE AMES FLUE GAS OUTLET SAMPLES TOC1 Sample volume (dscm) Mass (ng) Cone, (ng/dscm) Surrogate recovery dg-Naphthalene d^-Chrysene () % () % Test day Date 1 3-2 12.94 2,020 156 53 92 2 3-3 17.89 21,600 1,210 60 78 12 3-13 14.85 4,920 332 59 98 13 3-14 20.37 34,200 1,680 64 76 14 3-15 17.73 4,230 238 24 64 15 3-17 22.62 21,500 948 43 85 16 3-18 21.12 18,100 855 43 84 17 3-19 20.81 21,800 1,050 49 105 18 3-20 21.09 4,330 205 46 89 19 3-22 22.75 2,830 124 35 77 20 3-23 18.71 2,930 157 41 98 3-lla U1 Ul a No flue gas outlet samples collected due to severe weather. �TABLE 25. TOC1 RESULTS AND SURROGATE RECOVERIES FOR AMES PLANT BACKGROUND AIR PARTICULATE SAMPLES Test Day Date Volume On3) TOC1 (ng) TOC1 (ng/m3) Surrogate Recovery d8 -Naphthalene d^-Chrysene () % () % 1 2 3 4 5 3-2 3-3 3-4 3-5 3-6 500 540 510 550 800 2,930 3,920 3,150 3,190 4,940 5.9 7.3 6.2 5.8 6.2 23 3 24 26 41 85 110 100 96 100 6 7 8 9 10 3-7 3-8 3-9 3-10 3-11 700 600 870 750 830 3,240 3,160 3,460 3,750 5,110 4.6 5.3 4.0 5.0 6.2 56 24 45 39 36 110 73 88 93 93 11 12 13 14 15 3-12 3-13 3-14 3-15 3-17 600 960 930 910 910 4,180 3,260 2,980 4,530 3,820 7.0 3.4 3.2 5.0 4.2 48 59 59 32 80 140 130 140 92 79 16 17 18 19 20 3-18 3-19 3-20 3-22 3-23 950 960 1,110 840 1,040 5,090 6,580 4,620 2,690 1,880 5.4 6.9 4.2 3.2 1.8 68 65 73 51 73 110 77 89 120 83 Filter Blank Filter Blank 4,260 2,110 95 45 120 57 Calculated from the sampling time and the flowmeter reading on the Hi-Vol sampler. 56 �TABLE 26. TOC1 RESULTS AND SURROGATE RECOVERIES FOR AMES ESP ASH SAMPLES Surrogate recovery Test day 0 Date 3-1 Time Hopper code 0300 0430 0830 1230 1630 B A B A A B 2030 1 2 3-2 3-3 0030 0430 0830 1230 1630 2030 TOC1 (ng/g) dg-Naphthalene () % d12-Chrysene () % 1.8 36 100 5.9 6.3 5.8 0.3 4.5 5.3 78 38 60 91 61 73 140 140 87 69 73 95 x ' B B A B B B 0030 0430 A B \ f 4.1 57 84 0830 1230 A A \ ] 2.2 59 58 1630 2030 B \ f 1.1 46 88 5.1 8.7 1.1 10.6 5.4 8.0 40 46 71 61 70 71 110 65 110 78 69 90 B 3 3-4 0030 0430 0830 1230 1630 2030 B B A B B B 4 3-5 0030 0430 A B J j 2.7 52 98 0830 1230 B B \ ] 8.5 54 90 \ f 4.4 54 71 \ f 3.4 1 100 \ f 2.5 5 83 1630 2030 5 3-6 B 0030 0430 A 0830 1230 B B B B (continued) 57 �TABLE 26 (continued) Test day Date Time Hopper code 5 3-6 1630 2030 B A 6 3-7 0030 0430 A A 0830 1230 A A 1630 2030 TOC1 (ng/g) Surrogate recovery da-Naphthalene di2~Chrysene () % () % 9 3-10 10 3-11 2.4 0 90 3.0 60 98 B B I } 4.0 65 89 2330 0330 B B I 210 9 90 A A 3.7 41 100 A I } 5.2 59 99 2330 0330 0730 1130 1530 1930 A A B B A B 8.1 2.5 1.9 3.2 3.6 6.4 47 53 33 20 34 56 53 83 69 69 66 90 2330 0330 B B } 9.8 52 110 A B } 5.7 57 110 1530 1930 3-9 100 0730 1130 8 28 1530 1930 3-8 2.2 0730 1130 7 I } A A I 2.1 35 110 2330 0330 0730 1130 1530 1930 A A B A A B 3.0 3.8 1.9 0.9 2.9 3.7 54 1 45 1 59 8 120 140 110 110 110 73 B (continued) 58 �TABLE 26 (concluded) Surrogate recovery dg-Naphthalene 12 3-13 13 3-14 22 3-25 A B A B B B 3.2 2330 0330 B B 2.6 60 A A 2.1 103 B B 2.1 100 2330 0330 A A 2.1 130 B B 4.4 38 120 1530 1930 3-12 2330 0330 0730 1130 1530 1915 0730 1130 11 Time 1530 1930 Date TOC1 (ng/g) 0730 1130 Test day Hopper code B A 2.6 69 120 0001 0400 0800 1200 1600 2000 A B A A B A 1.7 71 130 59 90 130 �TABLE 27. TOC1 RESULTS AND SURROGATE RECOVERIES FOR AMES BOTTOM ASH SAMPLES Test day 0 Date 3-1 TOC1 (ng/g) Time Sector code 0105 0530 0930 1330 D B D D D v B J 1730 2130 30.3 31 77 67 85 52 110 0.2 75 68 362 92 110 11.1 30 130 79.0 114 26.3 60.0 52.5 81 52 53 41 57 47 69 21 79 47 84 95 72.0 67 50 22.7 72 92 \ " 13.8 50 96 E A \ 1 66.5 58 89 C B } > 55.0 68 110 0130 0530 0930 1300 1730 2130 D E C C D C 2 3-3 0130 0530 C j A F !• j 1730 2130 D B \ • 1 0130 0535 0930 1300 1730 2130 D E F E A E 0130 0530 C I 0930 1330 B | 1730 2130 F 0130 0530 0930 1330 4 5 3-4 3-5 3-6 130 31 42 57 85 39 43 3-2 0930 1330 65 9.0 13.0 0.6 3.3 1.6 99.5 1 3 Surrogate recovery d8-Naphthalene d12-Chrysene () % () % F 251 J (continued) 60 �TABLE 27 (continued) Date Time 5 3-6 1730 2130 C E 6 3-7 0130 0530 C A 0930 1300 TOC1 (ng/g) Sector code Test day Surrogate recovery dg-Naphthalene di2~Chrysene () % () % 10 3-11 39 81 34.0 19 83 C F I 81.0 38 103 0030 0430 E C I 35.9 65 79 B C I 4.9 63 20 A A I 57.5 54 46 0030 0430 0830 1230 1630 2030 B B D D F A 1.3 8.0 0.8 6.2 77 56 12 29 51 6 70 76 46 48 31 49 0030 0430 E E } 3.6 77 63 C F } 92.5 87 120 2030 3-10 51.0 E F I } 1445 1630 9 3-9 90 1630 2030 8 55 0830 1230 3-8 11.6 1730 2130 7 I B 16.4 11 120 0030 0430 0830 1230 1630 2030 D A A D D A 5.7 86 53 77 44 79 66 97 87 160 130 130 120 127 5.8 38.6 136 85.5 97.0 316 (continued) 61 �TABLE 27 (concluded) Surrogate recovery d8-Naphlhalene d12-Chrysenc () % () % Test day Date Time Sector code8 11 3-12 0030 0430 0830 1230 1630 2030 C D A E E A 57.0 61 120 0030 0430 A A 43.3 62 100 0830 D 76.0 54 110 1630 2030 A F 59 100 0030 0430 F C 32.3 59 80 0830 1230 B B 15.8 51 96 1630 2030 A B 64.5 62 110 0100 0500 0900 1300 1700 2100 A D B F B E 14.8 68 70 12 13 22 3-13 3-14 3-25 TOC1 (ng/g) 349 a The accessible portion of the hopper was divided into six sectors which were sampled according to a randomized selection scheme. 62 �TABLE 28. TOC1 RESULTS AND SURROGATE RECOVERIES FOR AMES COAL SAMPLES Date Time 3-1 Test day Feed stream code 0300 0700 1100 1500 1900 2300 A A A B B B 0300 0700 1100 1500 2300 B B A B A 3-2 TOC1 (ng/g) Surrogate recovery d g-Naphthalene 92 4 7 4 5 4 97 97 110 87 92 61 110 96 83 97 59 a Two coal feed lines were sampled according to a randomized selection scheme. �TABLE 29. TOC1 RESULTS AND SURROGATE RECOVERIES FOR AMES REFUSE - DERIVED FUEL SAMPLES Test day 0 Date Time Food stream code8 3-1 0225 0630 1030 1430 B D D A 1430 TOC1 (ng/g) ) ( ( > Surrogate recovery d8-Naphthalene dxa'Chrysene () % () % 3-3 42 61 C 10,800 58 80 1830 2230 2 5,550 B ) B / 29,500 54 160 3 3-4 0230 0630 1030 1430 1830 2230 A A C C A C 5,500 370 19,000 23,600 4,400 2,800 45 75 50 41 66 64 82 120 98 56 120 110 4 3-5 0230 B 480 61 140 1030 1440 D ) D f 5,100 76 150 1830 2250 D \ C J 5,000 71 120 0230 0630 B \ B f 9,500 80 140 1030 1430 A \ c f 13,300 62 110 1830 2230 C \ B f 1,900 55 110 0230 1430 A B 4,250 18,500 77 50 100 110 1830 2230 B t A J 7,050 63 5 6 3-6 3-7 64 170 (continued) �TABLE 29 (continued) Test day Date Time Food stream code8 7 3-8 0130 B 0930 1330 TOC1 (ng/g) Surrogate recovery dg -Naphthalene di2~Chrysene «) «) 22,000 88 98 D\ D j 4,300 68 110 1730 2130 D ] C J 9,900 55 120 8 3-9 0130 B 5,000 71 110 9 3-10 1730 2130 C A 7,350 3,150 64 42 120 68 10 3-11 0130 0530 0930 1330 1730 2130 A C A A D A 4,950 21,100 23,200 8,600 9,550 10,300 73 86 68 35 64 55 150 130 93 120 130 69 11 3-12 0130 0530 0900 1330 1730 2130 D , B D D C C * 19,900 88 130 0130 0530 D) D ] 10,900 66 84 1730 2130 D) C J 8,200 91 98 0130 0530 B\ C J 16,500 77 150 0930 1330 B) C J 4,300 57 84 1730 2130 A) C} 46,300 84 98 (continued) 12 13 3-13 3-14 65 �TABLE 29 (concluded) Test day Date Time Food stream code* 22 3-25 1000 1400 1800 2200 A B C D TOC1 (ng/g) 13,100 Surrogate recovery dg -Naphthalene d12-Chrysene () % () % 83 130 a Four RDF feed lines were sampled according to a randomized selection scheme. 66 �TABLE 30. TOC1 RESULTS AND SURROGATE RECOVERIES FOR AMES BOTTOM ASH HOPPER QUENCH WATER INFLUENT SAMPLES Surrogate recovery dg-Naphthalene d12-Chrysene Date Time TOC1 (ng/A) 1 3-2 2400 239 47 87 3 3-4 0400 271 51 120 5 3-6 1400 441 80 100 8 3-9 2100 339 82 100 10 3-11 0800 369 89 130 13 3-14 0300 576 64 130 Test day 67 �TABLE 31. TOC1 RESULTS AND SURROGATE RECOVERIES FOR AMES BOTTOM ASH HOPPER QUENCH OVERFLOW WATER SAMPLES Surrogate recovery dg-Naphthalene d^-Chrysene () % () % TOC1 (ng/1) Test day Date Time 0 3-1 0100 > 0500 0900 1300 1700 2100 ' NDa'b 90 698 656 680 494 626 528 47 25 44 b NDD 35 28 80 82 120 56 97 92 518 19b 79 50 524 89 1 3-2 0100 0500 0900 1300 1700 2100 2 3-3 0100 0500 \ 0900 1300 | 1700 2100 } 706 3 4 3-4 72 76 488 558 274 294 678 0100 0500 0900 1255 1700 2100 64 30 57 51 37. K NDb 28 54 66 50 22 78 96 825 37 98 49 110 1,180 3-6 I | 1700 2100 5 0100 0500 0900 1300 3-5 } 691 38 94 0100 0500 i 301 ND 24 0900 1300 1 427 ND 889 68 55 (continued) �TABLE 31 (continued) TOC1 (ng/1) Surrogate recovery dg -Naphtha lene ffU \ Test day Date Time 5 3-6 1700 2100 I 947 87 100 6 3-7 0100 0500 J 819 2 80 0900 1300 } 866 80 55 1700 2100 | 81 852 98 2400 0400 | 94 863 120 0800 1200 | 74 94 1600 2000 2400 | ? 1,040 ' 71 94 0400 0800 1200 1600 2000 2400 776 1,050 984 516 496 376 42 63 53 24, D NDb 120 110 87 140 130 120 0 85 80 605 120 7 8 3-8 3-9 3-10 0400 776C \ fa/ 1,100 Mil Ni/i_ 0800 1200 1600 2000 \ 795 46 100 2400 3-11 | 776C 0 85 0400 0800 1200 1600 2000 2400 870 806 778 864 880 728 c 130 110 90 17 57 120 120 86 88 83 (continued) �TABLE 31 (concluded) Surrogate recovery dg-Naphthalene d^-Chrysene Date Time 3-12 0400 0800 1200 1600 2000 2400 603 0400 0800 892 1200 1600 916 44 84 2000 2400 613 ND 57 0400 0800 458 34 78 1200 1600 770 42 97 2000 Test day TOC1 (ng/1) 1,060 42 80 0030 0430 0830 1230 1630 2030 638 36 110 3-13 3-14 3-25 81 a ND = not detected. b Extract was inadvertently evaporated to dryness. c Samples collected at 0400 and 2400 on 3-10 were inadvertently composited. d This sample was not spiked with the surrogate compounds. e This extract was lost prior to analysis for surrogate recoveries. 70 �TABLE 32. TOC1 RESULTS AND SURROGATE RECOVERIES FOR AMES UNTREATED WELL WATER TOC1 (ng/JK) Surrogate recovery di2~Chrysene d8 -Naphthalene () % () % Test day Date Time 0 3-1 0200 33 NDa 68 5 3-6 2200 65 65 99 23 3-26 1615 62 66 97 a Extract was inadvertently evaporated to dryness. 71 �TABLE 33. COMPOUNDS QUANTITATED IN SAMPLES FROM THE AMES MUNICIPAL POWER PLANT, UNIT NO. 7 Concentration Compound Composite day Coal (ng/g) Refuse-derived fuel (ng/g) Plant background air (ng/dscn) Flue gas inlet (ng/dsen) Flue gas outlet (ng/dscn) ESP ash (ng/g) Botton ash (ng/g) Botton ash hopper quench water overflow (|Jg/«) Bottoa ash hopper quench water overflow (Kg/*) Well a water (Mg/» Target PAH compounds Phenanthrene Anthracene Fluoranthene 1 2 3 4 5 7,550 900 ,9 15,400 8,500 18,600 1 2 3 4 5 1,570 1,840 1,260 2,120 4,110 1 1,190 1,640 3,320 2 0.29 1,400 940 948 828 296 5 3,210 Pyrene 1 2 3 4 5 1,340 1,960 3,810 1,070 400 ,4 552 436 282 372 Chrysene 1 2 370 425 434 3 4 5 Benzofalpyrene 1 2 3 4 5 Indeno) 1 ,2,3-c,dJpyrene J 2 3 4 5 90 0 1,060 238 1,300 0.32 0.17 0.16 0.19 0.36 984 271 306 198 3 4 0.6 0.8 0.8 0.7 0.7 1.0 0.5 0.36 0.7 0.7 1.1 0.5 0.29 04 .0 0.37 0.60 03 .8 0.07 0.17 0.11 0.09 0.07 270 420 660 640 200 390 59 57 77 89 100 49 77 78 46 77 70 240 140 87 94 40 97 28 130 220 8SO 480 230 330 320 37 480 21 64 120 19 63 0.2 0.2 0.2 32 250 140 43 500 24 130 10 52 30 46 450 110 96 9.0 64 29 6.0 420 250 66 330 0.3 3.5 28 9.6 2.8 0.3 320 2.7 170 13 28 0.02 (continued) �TABLE 33 (continued) Concentration Compound Composite day Benzo[g,h,i]perylene Coal (ng/g) Refuse-derived fuel (ng/g) 1 2 3 4 5 Plant background air (ng/dscn) Flue gas inlet (ng/dscm) Flue gas outlet (ng/dscm) ESP ash (ng/g) Bottom ash (ng/g) Bottom ash hopper quench water overflow ((Jg/«) Bottom ash hopper quench water overflow (Ug/«) Well water (Mg/*) 3.3 22 4.6 0.09 Additional compounds identified Dichlorobenzene 1,2,4-Trichlorobenzene 1 2 3 4 5 0.07 3.3 1,300 1,200 520 430 1 2 3 4 5 25 79 24 0.07 5 25 0.02 0.01 99 180 110 69 85 OJ Hexachlorobutadiene 1 2 3 4 5 Tetrachlorobenzene 1 2 3 4 5 103 1 2 3 4 5 Pentachlorophenol 0.02 0.07 1,300 24 690 (continued) �TABLE 33 (continued) Concentration Compound Phenol 2,4-DiMthylphenol Composite day 1 2 3 4 5 Coal (ng/g) Fluorene Benz I a ) anthracene Benzofluoranthrene Benzol ejpyrene 3.3 1.3 0.8 1.5 1.8 1,0 000 12,000 280 ,0 23,000 2,0 900 Flue gas inlet (ng/dsn) 4,700 400 ,0 1,0 300 5,100 9,500 1 2 3 4 5 6,400 7,700 300 ,0 6,000 6,200 ESP ash (ng/g) 220 190 380 Botton ash (ng/g) 980 1,600 1,800 360 730 Botton ash hopper quench water overflow (ug/t) Bottom ash hopper quench water overflow (pg/4) Well water (ug/£) 00 .6 0.06 27 8 2,100 1 2 3 4 5 1,400 1,100 1,800 1,800 2,700 1 2 3 3,500 3,100 560 ,0 3,300 7,000 1 2 3 4 5 1 2 3 4 5 Flue gas outlet (ng/dsca) 1,000 1,200 1,300 4 5 Naphthalene Refuse -de rived fuel (ng/g) Plant background air (ng/dso) 2,200 1,500 1,500 0.28 0.22 0.32 0.28 0.13 60 0 450 380 320 02 .2 0.32 02 .8 0.13 36,000 470 960 260 1,200 620 1,800 740 650 550 81 300 850 0.17 15 0.02 360 110 29 0.18 0.5 0.14 0.44 0.53 0.55 0.38 261 710 1,000 0.42 0.67 0.63 0.65 0.51 14 120 7.2 9.9 6.5 2.7 12 6.9 0.03 17 1 2 3 4 5 29 (continued) 0.02 �TABLE 33 (continued) Concentration Compound Acenaphthene Acenaphthylene Composite day Coal (ng/g) 1 2 3 A 5 650 970 1,600 1,400 1,500 1 2 3 4 5 220 240 560 400 450 Trichlorobenzene Bottom ash (ng/g) Well water9 (fig/*) 0.7 1.0 120 75 10 100 130 20 26 1 2 3 4 5 Dimethylphthalate ESP ash (ng/g) 1 2 3 4 5 j>-Chloro-n~cresol Flue gas outlet (ng/dscm) 1,200 1 2 3 4 5 2 , 4-Dichlorophenol Flue gas inlet (ng/dscn) Bottom ash hopper quench water overflow (fig/I) Bottom ash hopper quench water overflow (pg/Jt) 0.07 Refuse-derived fuel (ng/g) Plant background air (ng/dso.) 1 2 3 Ui 36 77 24 0.04 0.30 3.0 A 5 Diet hylphtha late 730 1 2 3 4 5 9,100 250 1,400 11,000 0.20 11 0.5 2.0 37 16 (continued) �TABLE 33 (concluded) Concentration Composite Compound Di-n-butylphthalate day 4 S Flue gas inlet (ng/dscm) 18,000 14,000 640 ,0 14,000 4 S ESP ash (ng/g) 15 3.0 40 . Bottom ash (ng/g) 4.0 42 12 35 170 32 51 49,000 22,000 1 2 3 Flue gas outlet (ng/dscm) 6.0 1 2 3 4 5 Bii(2-ethylhexyl)phthalate Refuse-derived fuel (ng/g) 1 2 3 Butylbenzylphtbalate Coal (ng/g) Plant background air (ng/dscm) 3000 5,0 4,0 400 35,000 22,000 » All extracts fro* these samples were combined for a single composite extract, b Specific isomer not determined. 6.0 3.0 2.0 8.0 90 8 1,200 480 810 Bottom asb hopper quench water overflow (pg/t) Bottom ash hopper quench water overflow (Mg/«) Well water9 (Mg/«) �TABLE 34. CONCENTRATIONS OF POLYCHLORINATED BIPHENYL ISOMERS IN FLUE GAS OUTLET SAMPLES FROM THE AMES MUNICIPAL POWER PLANT, UNIT NO. 7 Compound identified 1 Composite day (Concentration, ng/dscm) 2 3 4 6.4 Trichlorobiphenyl Tetrachlorobiphenyl 2.2 3.0 6.4 1.1 4.1 Hexachlorobiphenyl 4.3 Heptachlorobiphenyl 9.8 3.6 10.1 25.0 17.0 2.9 Decachlorobiphenyl 22.0 3.8 11.0 4.5 Pentachlorobiphenyl 5 2.9 Total chlorobiphenyl 5.2 27.0 23.0 PCDDs and PCDFs were not detected in the Ames samples. The detection limit for PCDD and PCDF compounds in the composite flue gas extracts was 0.1 to 0.25 ng/dscm. Cadmium The results for cadmium analysis of samples of fly ash, bottom ash, coal and refuse-derived fuel for test days 11 to 14 and 21 to 23 are presented in Tables 35 to 39. The fly ash samples contained the highest concentrations of cadmium ranging from approximately 1.5 to 11 pg/g, while the cadmium concentration in bottom ash samples varied from approximately 0.5 to 4 |Jg/g. The concentration of cadmium in the coal samples was generally less than 1 pg/g while values of 1 to 5 pg/g were recorded for refuse-derived fuel. In general, the cadmium concentration for all water samples was below the detection limit (0.6 pg/liter) of the analysis method. Table 35 presents the cadmium concentrations for the flue gas outlet particulate samples for test days 21 to 23. The concentrations of cadmium in flue gas particulates for the three test days did not vary markedly. The mean concentration was 25.3 pg/dscm with a standard deviation of 2.7 pg/dscm. 77 �TABLE 35. CADMIUM RESULTS FOR AMES - ESP ASH SAMPLES Test day Date Time Hopper code3 11 12 3/12 3/13 3/13 3/13 3/13 3/13 3/13 3/14 3/14 3/14 3/14 3/14 3/14 3/15 3/15 3/15 3/15 3/15 3/16 3/16 3/16 3/16 3/16 3/16 3/24 3/24 3/24 3/24 3/24 3/24 3/25 3/25 3/25 3/25 3/25 3/25 3/26 3/26 3/26 3/26 3/26 3/26 2330 0330 0730 1130 1530 1930 2330 0330 0730 1130 1530 1930 2330 0330 0730 1130 1530 1930 2330 0330 0730 1130 1530 1930 0001 0400 0800 1200 1600 2000 0001 0400 0800 1200 1600 2000 0001 0400 0800 1200 1600 2000 B B A A B A A A B B B A B A B B A B A B A B B B B A A B B A A B A A B A A A B A A B 13 14 21 22 23 Cadmium (M8/g) 9.01 10.3 10.8 8.14 9.89 3.67 7.36 8.42 8.16 9.11 9.96 6.78 6.84 8.47 4.39 3.43 8.00 2.88 5.55 2.35 1.94 1.65 2.97 2.93 3.29 2.16 2.16 3.53 7.89 5.69 4.53 5.11 3.36 8.93 9.70 6.41 5.76 5.73 6.86 8.03 9.19 9.70 a Two hoppers were sampled according to a randomized selection scheme. �TABLE 36. CADMIUM RESULTS FOR AMES BOTTOM ASH SAMPLES Test day Date Time Sector o code Cadmium (M8/g) 12 3/13 3/13 3/13 3/13 3/13 3/14 3/14 3/14 3/14 3/14 3/14 3/15 3/15 3/15 3/15 3/15 3/15 3/16 3/16 3/16 3/16 3/16 3/16 3/24 3/24 3/24 3/24 3/24 3/24 3/25 3/25 3/25 3/25 3/25 3/25 3/26 3/26 3/26 3/26 3/26 3/26 0030 0430 0830 1630 2030 0030 0430 0830 1230 1630 2030 0130 0430 0830 1230 1630 2030 0030 0430 0830 1230 1630 2030 0100 0500 0900 1300 1700 2100 0100 0500 0900 1300 1700 2100 0100 0500 0900 1300 1700 1200 A A D A F F C B B A B D A A D D A C D A G E A E C C C A A D D B F B E B A C C B C 3.92 1.86 2.24 0.25 1.28 1.66 3.28 2.96 1.90 1.90 1.46 4.36 7.15 0.74 0.78 0.96 0.46 0.62 0.78 0.48 1.08 0.90 1.00 1.02 2.82 0.60 1.64 0.76 1.34 0.78 3.68 3.24 3.76 1.94 2.78 2.00 2.20 2.28 2.84 2.02 2.48 13 14 21 22 23 a The accessible portion of the hopper was divided into six sectors which were sampled according to a randomized selection scheme. �TABLE 37. CADMIUM RESULTS FOR AMES - COAL SAMPLES Feed stream code Test day Date Time 12 3/13 3/13 3/13 3/13 3/13 3/14 3/14 3/14 3/14 3/14 3/14 3/15 3/15 3/15 3/15 3/15 3/15 3/16 3/16 3/16 3/16 3/16 3/16 3/24 3/24 3/24 3/24 3/24 3/24 3/25 3/25 3/25 3/25 3/25 3/25 3/26 3/26 3/26 3/26 3/26 3/26 0600 1000 1400 1800 1800 0200 00 60 1000 1400 1800 2200 0200 0600 1000 1400 1800 2200 0200 0600 1000 1400 1800 2200 0230 0630 1030 1430 1830 2230 0230 0630 1030 1430 1830 2230 0230 0630 1030 1430 1830 2230 13 14 21 22 23 A 8 A B B B B B B A B A A A A A B B B A B A B A B A B B B B A B A A A B A B B A B Cadmium (M8/g) 0.124 0.024 0.068 0.116 4.04 0.043 007 .8 0.219 0.159 0.128 0.176 0.210 0.293 000 .4 0.153 0.055 0.075 0.138 0.027 0.094 0.099 0.367 0.141 0.157 0.104 0.129 0.241 0.090 0.173 0.122 0.045 0.079 0.055 0.084 0.286 0.193 0.109 0.055 0.222 0.166 0.641 a Two coal feed lines were sampled according to a randomized selection scheme. 80 �TABLE 38. CADMIUM RESULTS FOR AMES - REFUSE-DERIVED FUEL SAMPLES Test day Date Time 12 3/13 3/13 3/13 3/13 3/14 3/14 3/14 3/14 3/14 3/14 3/15 3/24 3/25 3/25 3/25 3/25 3/26 3/26 3/26 3/26 3/26 0130 0530 1730 2130 0130 0530 0930 1330 1730 2130 0130 1400 1000 1400 1800 2200 0200 0600 1000 1800 2200 13 14 21 22 a Feed stream code D D D C B C B C A C A C A B C D B B B A A Cadmium (Mg/g) 2.84 1.99 2.41 1.14 2.31 2.96 4.85 2.79 2.37 3.68 5.30 2.63 3.71 3.72 2.37 1.73 1.59 1.69 6.26 3.60 0.94 Four RDF feed lines sampled according to a randomized selection scheme. 81 �TABLE 39. CADMIUM RESULTS FOR AMES - FLUE GAS OUTLET PARTICULARS Mass (MS) Cadmium Concentration (Mg/dscra) Test day Date Volume (dscm) 21 3/24 3.69 83.2 22.6 22 3/25 3.48 97.3 28.0 23 3/26 3.93 100.0 25.5 �CHICAGO NORTHWEST INCINERATOR Organics The results of TOC1 analyses of flue gas inlet and outlet samples from the Chicago incinerator are shown in Table 40 along with the corresponding surrogate recovery data. TOC1 and surrogate results for plant background, air particulates, ESP ash, combined bottom ash (i.e., bottom ash plus ESP ash), refuse, and tap water (plant intake water) are shown in Tables 41 to 45. Organic chlorine was not detected by the TOC1 procedure in any of the field blanks, method blanks, or flue gas first impinger extracts. These results, as well as all other results in this report, are shown uncorrected for surrogate recoveries. In general, the surrogate recoveries were poor. As with the Ames results, dg-naphthalene recoveries (typically 10-50%) were lower than di2~chrysene recoveries (typically 30-60%). Although a portion of the apparent losses may be attributed to difficult sample matrices, the cause of consistently lower recoveries is not known. The results of determinations of PAH compounds and additional compounds identified in the composite Chicago extracts are shown in Table 46. Composite refuse extracts were not analyzed due to extremely high levels of interfering materials and the likely nonrepresentatative nature of the refuse sample collection. A large number of chlorinated benzene and phenolic compounds were identified. Dibenzofuran was identified in the flue extracts. As noted for the Ames samples, only very low levels of phthalate esters were identified in the flue gas blank extracts. Interestingly, the compound specific determinations compare very favorably with the TOC1 results for the same extracts. Table 47 shows a comparison of the TOC1 results for selected composite extracts (i.e., those in which significant levels of chlorinated compounds were identified) calculated from the TOC1 concentrations in the component extracts with those calculated from the sums of chlorinted compounds identified. The percent deviation from the mean for these pairs is 14%. The results of analysis of the composite Chicago flue gas outlet extracts for PCBs are shown in Table 48. In contrast to the results from the Ames extracts, the PCS contents of the Chicago flue gases were largely di- through pentachloro-substituted. The results of HRGC/HRMS analyses of the composite Chicago incinerator extracts for PCDDs and PCDFs are shown in Table 49. The mean recoveries for 1,2,3,4-tetrachlorodibenzo-j>-dioxin and octachlorodibenzo-|>-dioxin through the extract cleanup were 60 and 25%, respectively. Although a number of PCDD and PCDF compounds were identified, trichlorodibenzofurans were found at the highest concentrations. Table 50 shows the results of specific analyses for 2,3,7,8-tetrachlorodibenzo-£-dioxin. This compound was detected in all three extracts, although the concentrations measured were substantially less than 1 ng/dscm. No PCDD or PCDF isomers were detected in any blank extracts. 83 �TABLE 40. TOC1 RESULTS AMD SURROGATE RECOVERIES FOR CHICAGO NW FLUE GAS SAHPLES TOC1 Test day Date Volume (s. dc) Resin Mass (ng) Particulates Total cone, (ng/dscn) Surrogate recovery diz-Chrysene dg-Naphthalene () I Particulates Resin Particulates Resin (W Flue Gas Inlet 1 2 3 4 5 6 7 8 9 10 11 5-4 5-6 5-7 5-8 5-9 5-10 5-11 5-12 5-13 5-15 5-16 11.10 22.31 20.53 19.89 20.19 18.92 2.8 04 19.52 19.05 20.26 20.22 17,500 33,900 12,300 13,900 22,600 10,700 11,900 11,700 11,000 12,100 33,200 14,400 5,0 220 26,700 21,330 19,700 23,900 1,0 090 36,300 3,0 040 17,400 22,500 Flue Gas 1 2 5 4 5 6 7 8 9 10 11 5-4 18.20 5-6 5-7 5-8 5-9 24.82 22.95 5-10 5-11 5-12 5-13 5-15 5-16 25.07 21.39 2.9 20 21.51 21.74 21.38 21.91 23.26 1,0 680 69,100 32,700 3900 0,0 3,0 220 6,0 320 4,0 790 3,0 940 19,100 4,0 450 3,0 060 37 80 49 54 38 9 17 30 22 25 92 280 ,0 3,860 1,900 1,770 2,090 1,830 1,110 2,470 2,170 1,460 2,753 38 20 41 62 54 27 16 13 46 27 13 40 19 52 16 48 27 17 36 24 28 13 340 ,6 1,100 7 3,140 1,760 13,500 19 7.720 2,0 400 7,070 590 ,4 400 ,6 200 ,7 3,310 2,540 2,920 1.230 230 ,0 1,490 62 58 45 100 47 56 68 25 41 77 29 Outlet 8,780 28,600 12,000 9,940 6,750 67 140 90 110 100 96 58 89 70 67 140 0 16 5 38 44 6 64 64 18 58 58 0 4 35 77 99 54 120 80 82 44 40 130 23 120 50 40 70 68 66 36 �TABLE 41. TOC1 RESULTS AND SURROGATE RECOVERIES FOR CHICAGO NW PLANT BACKGROUND AIR SAMPLES TOC1 (ng) TOC1 (ng/m3) Surrogate recovery d8-Naphthalene djg-Chrysene () % () % Test day Date Volume (m3) 2 5-6 660 1,510 2.3 58 45 3 5-7 490 1,400 2.9 67 74 4 5-8 570 1,840 3.2 46 71 5 5-9 590 1,730 3.0 23 55 6 5-10 510 < 30 < 0.1 7 1 7 5-11 590 430 0.7 55 170 8 5-12 390 < 30 < 0.1 0 0 9 5-13 580 540 0.9 34 33 10 5-15 490 890 1.8 26 28 11 5-16 710 1,240 1.7 37 44 5-17 520 760 1.5 11 24 5-19 320 590 1.8 2 66 a Calculated from the sampling time and the flowmeter reading on the HiVol sampler. 85 �TABLE 42. TOC1 RESULTS AND SURROGATE RECOVERIES FOR CHICAGO NW ESP ASH SAMPLES Test Day TOCI (ng/g) Date Time 0 5-3 0200 0600 1000 1400 1800 2200 1 5-4 0200 0600 1 Surrogate Recovery d8-Naphthalene di2-Chrysene fty \ V fb/ 5-6 41 36 0 44 45 18 68 63 46 80 72 35 59 8 35 1000 1400 2 226 203 68 89 143 54 I « 28 52 1400 62 8 24 ?6 7 39 1800 2200 } 192 58 97 } 49 20 15 1800 2200 5-7 0200 0600 1000 1400 3 } / 95 0 0 4 5-8 0200 0600 1000 1400 1800 2200 370 150 15 14 23 49 60 28 0 18 5 44 83 24 12 7 18 31 5 5-9 0200 0600 1000 1400 1800 2200 130 340 41 210 160 38 40 56 44 37 28 26 28 14 32 21 20 30 6 5-10 0400 0800 1200 111 84 57 37 19 9 32 35 32 (continued) 86 �TABLE 42 (continued) Surrogate Recovery dj2~Chrysene dg-Naphthalene Time TOC1 (ag/g) 5-10 1600 2000 59 65 39 8 40 76 0000 76 23 57 66 21 54 30 38 2000 0000 31 13 0 0400 0800 | 40 36 1200 1600 I « 36 21 2000 0000 | 30 32 0400 0800 \ 65 40 35 1200 1600 6 Date 5-11 Test Day \ 150 30 30 76 26 26 20 12 16 220 203 70 159 < 1 0 52 28 23 0 48 49 25 0 (continued) 7 0400 0800 1200 1600 5-12 8 5-13 9 5-14 \ 108 } 1600 2000 0000 10 5-15 0400 0800 1200 1600 2000 I 132 38 37 �TABLE 42 (concluded) Test Day TOC1 (ng/g) Date Time 5-16 0000 0400 0800 1200 1600 2000 137 211 78 173 15 154 5-17 0100 0900 1300 1700 2100 12 11 12 88 Surrogate Recovery rig-Naphthalene 22 24 39 50 9 0 14 49 59 57 17 39 26 �TABLE 43. TOC1 RESULTS AND SURROGATE RECOVERIES FOR CHICAGO NW COMBINED BOTTOM ASH SAMPLES TOC1 Surrogate Recovery d12~Chrysene d8-Naphthalene < 1 18 23 5-3 0300 0700 1100 1500 1900 2300 E E E A < < < < < < 1 1 1 1 1 1 39 33 18 31 56 52 35 26 23 20 21 25 0300 0700 A A \ J < 1 12 0 D 1 < 1 34 7 1500 A < 1 29 52 C A \ / 6 34 32 0300 0700 A E » / < 1 0 26 B E ) J 6 38 58 1900 2300 3 A 1100 1500 2 2300 1900 2300 1 Time 1100 1500 0 Date 5-2 Test day Sector code D B ) f 3 46 52 5-4 5-6 5-7 (ng/g) B 4 5-8 0700 1100 1500 1900 1900 2300 B B D E C B < 1 < 1 < 1 124 < 1 < 1 8 22 19 37 13 0 24 26 20 64 8 0 5 5-9 0300 0700 1100 1500 1900 2300 B C D C B A 7 76 5 3 < 1 38 11 75 48 72 47 85 5 9 11 78 13 10 (continued) 89 �TABLE 43 (continued) Sector code8 TOC1 (ng/g) 7 16 Test day Date Time 6 5-10 0100 0500 0900 1300 1700 2100 A 0100 0500 E E I 0900 1300 E D } 1700 2100 B C 0100 0500 E B 0900 1300 A B 1700 2100 B E 0100 0500 D D 0900 1300 C A 1700 E 5-14 1700 2100 A A 5-15 0100 0500 0900 1300 7 8 9 10 5-11 5-12 5-13 Surrogate Recovery dg-Naphthalene d12~Chrysene () % 13 42 34 41 34 33 11 43 34 <l 31 25 } < l 36 36 } <> 8 13 1 28 17 25 I » 37 26 I 57 100 I » 60 12 < 1 28 7 > 2 19 0 A E } 18 34 8 C C \ 2 35 7 E B C E E < 1 < 1 < 1 49 • 3.8 7 8 8 11 12 (continued) 90 �TABLE 43 (concluded) Test day Sector j codea TOC1 (ng/g) Surrogate Recovery dg-Naphthalene d12-Chrysene () % () % Time 5-15 11 Dae 1700 2100 E c\ I < 1 21 5 5-16 0100 0500 0900 1300 1700 2100 E C C E B D < 1 26 26 50 44 6 24 6 8 7 6 6 6 7 < < < < 1 1 1 1 The accessible portion of the bottom ash discharge hopper was divided into five sectors which were sampled according to a randomized selection scheme. 91 �TABLE 44. TOC1 RESULTS AND SURROGATE RECOVERIES FOR CHICAGO NW REFUSE SAMPLES 3 0100 0515 0900 1300 1700 2100 A B B B A B 1,780 9,940 0100 0500 A B A 0900 1300 A B A B 2110 1 5-3 1700 2100 0 Time Sector code TOC1 Date 0900 Test day 5-4 5-7 Surrogate recovery d -Naphthalene d12~Chrysene 8 12,300 15 12 12 5 28 15 15 12 0 5 18 15 221 0 0 < 1 0 0 \ f 14 0 0 \ f 1,350 0 0 A < 1 25 0 961 62 778 \ > 4 5-8 0100 0500 0900 1300 1700 2100 A B A B A B 84 165 38 583 27 567 8 12 19 9 0 9 4 15 32 26 0 9 5 5-9 0100 0500 0900 1300 1700 2100 B A A B B A 1,550 36 5 0 14 2 0 120 5 0 10 0 0 246 41 607 1,670 273 (continued) �TABLE 44 (continued) Test day 6 Sector code Date Time 5-10 0300 0700 1100 1500 1900 2300 B A B A B A 0300 0700 TOC1 (ng/g) Surrogate recovery d8-Naphthalene d12-Chrysene 9 5-13 0 0 B \ A| 599 2 0 B \ B J 95 0 0 0300 0700 B A \ I < 1 0 0 A } 1 389 8 3 1900 2300 5-12 < 1 1100 1500 8 B \ A ( 1900 2300 5-11 0 1 0 6 38 0 1100 1500 7 167 11 54 0 9 0 6 46 0 B B \ f < 1 0 0 0300 0700 A } J < 1 0 0 1100 1500 B \ A I < i o o B A 108 467 < 1 (continued) �TABLE 44 (concluded) TOC1 (ng/g) Surrogate recovery d12-Chrysene d g -Naphtha lene () % () % Test day Date Time Sector code 10 5-14 1500 1900 B A < 1 2,700 0 5 50 10 5-15 0300 0700 1100 1500 1900 2300 A A B B A B 22 8,070 < 1 < 1 < 1 < 1 68 30 0 0 0 4 68 32 0 0 0 5 5-16 0300 0700 1100 1500 1900 A B A A B 26 < 1 45 < 1 < 1 16 0 0 17 6 15 0 0 1 6 5-17 0000 B < 1 6 0 11 The accessible portion of refuse was divided into two sectors which were sampled according to a randomized selection scheme. �TABLE 45. TOC1 RESULTS AND SURROGATE RECOVERIES FOR CHICAGO NW TAP WATER SAMPLES Surrogate recovery di2~Chrysene dg-Naphthalene /O> \ \ A>/ () % Test day Date TOC1 (ng/£) 5 5-9 < 30 14 16 6 5-10 < 30 0 0 7 5-11 5-14 < 30 < 30 68 12 24 10 95 �TABLE 46. Compound COMPOUNDS QUANTITATED IN SAMPLES FROH THE CHICAGO NV INCINERATOR, UNIT HO. 2 Composite day Plant backbround air particulates concentration (ng/dsca) Flue gas inlet concentration (ng/dscn) Flue gas outlet concentration (ng/dsoi) Combined ash concentration (ng/g) 120 32 28 200 110 340 110 27 18 39 27 51 17 300 140 57 92 91 77 12 Target PAH Compounds Phenanthrene 1 2 3 Fluoranthene 1 2 3 Pyrene 1 2 3 1.0 0.28 0.82 0.18 9.4 7.8 Additional Compound* Idendified 1 ,3-Dichlorobenzene 1 2 3 130 130 18 1 ,4-Dicblorobenzene 1 2 3 96 98 14 1 ,2-Dichlorobenzene 1 2 3 140 120 20 1,2, 3-Trichlorobenzene 1 2 3 140 81 27 48 57 150 1,2,4-Trichlorobenzene 1 2 3 550 380 160 200 220 560 1 ,3,5-Trichlorobenzene 1 2 3 490 280 120 190 180 460 Tetrachlorobenzene* 1 2 3 1,400 1,000 1,400 790 630 (continued) ESP Ash concentration (ng/g) �TABLE 46 (concluded) Plant backbround air particulates concentration (ng/dscm) Flue gas inlet concentration (ng/dsm) Flue gas outlet concentration (ng/dscn) 1 2 3 too 39 12 Dichlorophenol' 1 2 3 560 240 190 1 2 3 2,100 140 ,0 1,200 1,900 1 2 3 2,200 1,100 1 2 3 130 64 190 160 430 Dibenzofuran 1 2 3 86 28 23 100 67 140 Dine thy Iphthalate 1 2 3 Hexachlorobenzene Tetrachlorophenol" Pentachlorophenol Diethylphthalate 1 2 3 Butylbenzylphthalate 1 2 3 60 0 1,500 1,100 1,700 83 4.8 50 1 2 3 Bis(2-ethylhexyl)phthalate 970 600 1 2 3 Di-n-butylphthalate a ESP Ash concentration (ng/g) 240 280 630 Tri chloropheno 1a Combined ash concentration (ng/g) 110 48 260 Compound Composite day Specific isoner not determined. 15 6.1 32 130 47 370 170 230 89 �TABLE 47. COMPARISON OF TOC1 RESULTS FROM DIRECT TOC1 ASSAYS VERSUS CALCULATED TOC1 FROM SPECIFIC COMPOUNDS IDENTIFIED IN COMPOSITE CHICAGO NW EXTRACTS Composite day TOCI assay Sum of compounds identified Flue gas inlet 1 2 3 130 mg/hr 88 mg/hr 67 mg/hr 200 mg/hr 110 mg/hr 56 mg/hr Flue gas outlet 1 2 3 97 mg/hr 110 mg/hr 86 mg/hr 120 mg/hr 96 mg/hr 190 mg/hr 98 ng/g 93 ng/g Sample type ESP Ash 98 �TABLE 48. CONCENTRATIONS OF POLYCHLORINATED BIPHENYL ISOMERS IN FLUE GAS OUTLET SAMPLES FROM THE CHICAGO NORTHWEST INCINERATOR UNIT NO. 2 Compound identified Composite day (Concentration, ng/dscm) 1 3 2 Dichlorobiphenyl 5.8 6.0 40 Trichlorobiphenyl 7.6 4.3 36 Tetrachlorobiphenyl 4.2 1.5 13 Pentachlorobiphenyl 2.3 1.0 4.5 Total chlorobiphenyl 19.9 12.8 93.5 99 �TABLE 49. CONCENTRATIONS OF POLYCHLORODIBENZO-P-DIOXINS AND FURANS IN FLUE GAS FROM THE CHICAGO NORTHWEST INCINERATOR Concentrations (ng/dscm) Total trichlorodibenzo-p-dioxins Day 1 2 3 Mean S.D. 15 12 11 13 2.1 Total trichlorodibenzofurans Day 1 2 3 Mean S.D. 350 280 270 300 44 Total tetrachlorodibenzo-p-dioxins Day 1 2 3 Mean S.D. 7.2 5.4 6.2 6.3 0.90 Total tetrachlorodibenzofurans Day 1 2 3 Mean S.D. 89 84 96 90 6.0 Total hexachlorodibenzo-p-dioxins Day 1 2 3 Mean S.D. 14 21 14 16 4.0 (continued) 100 �TABLE 49 (concluded) Concentrations (ng/dscm) Total hexachlorodibenzofurans Day 1 2 3 Mean S.D. 43 84 59 62 21 Total heptachlorodibenzo-p-dioxins Day 1 2 3 Mean S.D. 7.2 7.8 7.7 7.6 0.32 Total heptachlorodibenzofurans Day 1 2 3 Mean S.D. 7.2 7.2 8.0 7.5 0.46 Octachlorodibeuzo-p-dioxin Day 1 2 3 Mean S.D. 2.6 2.2 2.8 2.5 0.39 Octachlorodibenzofuran Day 1 2 3 Mean S.D. 0.72 0.63 0.46 0.60 0.13 101 �TABLE 50. CONCENTRATIONS OF 2,3,7,8-TETRACHLORODIBENZO-P-DIOXIN IN FLUE GAS FROM THE CHICAGO NW INCINERATOR Concentration (ng/dscm) Day 1 0.35 2 0.36 3 0.52 Mean 0.41 S.D. 0.10 Cadmium The results for cadmium analysis of samples of fly ash, bottom ash, and refuse for test days 8 to 14 are presented in Tables 51 to 53. The fly ash samples contained the highest concentrations of cadmium, ranging from 86 to 560 (Jg/8- The concentration of cadmium in bottom ash was approximately one order of magnitude lower than that of the fly ash samples. The cadmium content of refuse samples ranged from less than 0.12 to 1.4 (Jg/8- Cadmium was not detected in the tap water from this plant. The concentrations of cadmium in the flue gas outlet samples are listed in Table 54. Also included in these tables are results for the recoveries of spiked samples, which was part of the QA program discussed in the analysis methods. The recovery of cadmium averaged 91% from both the combined ash and the refuse and 114% from the fly ash. 102 �TABLE 51. CADMIUM CONCENTRATIONS IN FLY ASH FROM CHICAGO NORTHWEST INCINERATOR, UNIT NO. 2 Test day Date Time 9 5/13 0000 0400 5/14 10 5/15 0800 1200 1600 1700 2000 0400 0800 1200 Cadmium (Mg/g) 283 201, 212 209, 217, 222 376 458 391 86.1, 82.3 250 1600 200 225 209, 218 380, 392 419, 425, 440 361 560 Spike recovery () %a 139 109 124, 118, 114 11 5/16 0000 0400 0800 1200 1600 306 325, 325 237 250 216 135 12 5/17 0100 0500 0900 1300 1700 2100 230 279, 348 289 290 313 328, 323 94 0100 0500 309 326 13 5/18 97 ± 9° Spiked distilled water a 100 Spiked with 10 (Jg total cadmium. b Spiked with 10 pg total cadmium and analyzed with the sample digests. c Mean and standard deviation for eight determinations. 103 �TABLE 52. CADMIUM CONCENTRATIONS IN COMBINED BOTTOM ASH FROM CHICAGO NORTHWEST INCINERATOR, UNIT NO. 2 Test day Cadmium (Mg/g) Spike recovery () %3 11 5/13 0100 0500 0900 1300 1700 8.20 23.4 8.30, 7.34 36.1, 31.2 15.1 95 61 1700 2100 5.40 30.8, 27.8 88 5/15 0100 0500 0900 1300 1700 2100 15.9, 9.20 31.7 48.8 7.3 17.1 18.5, 49.4 31.7, 60.5 81, 106 0100 0500 0900 1300 2000 2100 10 Time 5/14 9 Date 7.88, 28.7, 6.80 27.8 13.3 10.7, 8.64 12.1 7.5 5/16 12 5/17 0200 0600 1000 1400 1800 2200 5/18 0200 0600 1000 1400 1800 2200 5/19 0200 0600 1000 1400 120 105 6.35 8.00 21.7 4.60 71 3.60 14 67 14.5 10.4 6.00 14.3 13.1, 14.8 17.6 13 98 13.1 46.9 7.85 14.3 93 ± 6C Spiked distilled water a Spiked with 10 pg total cadmium. b Spiked with 10 )Jg total cadmium and analyzed with the sample digests. c Mean and standard deviation for six determinations. 104 �TABLE 53. CADMIUM CONCENTRATIONS IN REFUSE FROM CHICAGO NORTHWEST INCINERATOR Test day 8 10 11 12 13 14 Date Time 5/12 5/13 5/13 5/13 5/13 5/14 5/14 5/14 5/15 5/15 5/15 5/15 5/15 5/15 5/16 5/16 5/16 5/16 5/16 5/17 5/17 5/17 5/17 5/17 5/17 5/18 5/18 5/18 5/18 5/19 5/19 5/19 5/19 2300 0300 0700 1100 1500 1500 1900 2300 0300 0700 1100 1500 1700 2300 0300 0700 1100 1500 1900 0000 0400 0800 1200 1600 2000 0000 1200 1600 2000 0000 0400 0800 1200 Cadmium (Mg/K) 1.45 0.50, 1.25 0.85 0.28 0.45 0.63 1.07 0.95, 1.02 0.67 0.14 0.85 < 0.12 0.20 1.10, 1.04 1.07 0.83, 0.80 < 0.12 < 0.12, < 0.12 0.63 1.10 0.68 < 0.12 0.18 0.16 0.60 0.57 0.25 1.04, 0.94 0.55 1.25 9.85, 8.44 0.79 8.13 Spike recovery () %3 91 72 95 106 105 94 78 ± 22C Spiked distilled water a Spiked with 10 (Jg total cadmium. b Spiked with 10 (Jg total cadmium and analyzed with the sample digests. c Mean and standard deviation for seven determinations. 105 �TABLE 54. CADMIUM CONCENTRATIONS IN THE FLUE GAS OUTLET PARTICULARS FROM CHICAGO NORTHWEST INCINERATOR, UNIT NO. 2 Cadmium Concentration (ng/dscm) Date Volume (dscm) Mass (pg) 12 5/17 6.20 520 84 13 5/18 6.20 1,490 240 14 5/19 6.81 1,850 272 Test day 106 �SECTION 9 ANALYTICAL QUALITY ASSURANCE RESULTS The principal quality assurance indicators used for this study were the recoveries for surrogate compounds spiked into all samples prior to extraction and the results of three interlaboratory comparison studies. SURROGATE COMPOUND RECOVERIES The surrogate recoveries determined for all samples from both plants are summarized in Table 55. As indicated in the previous section, the recoveries observed for naphthalene are generally lower than those for chrysene. Since the compounds of primary interest in this study are less volatile than naphthalene, the naphthalene recoveries likely indicate the maximum losses attributable to volatilization. The chrysene recoveries likely provide a more accurate indication of the recoveries of the principal analytes related to extraction efficiency and general extraction handling. The apparent analytical accuracy and precision as indicated by the recoveries and standard deviations of surrogates observed for each media was likely influenced by the dilution of extracts prior to analysis. Many of the more complex extracts required dilution such that the concentrations of the surrogate compounds in the diluted extracts were near the analytical detection limits. In general, the surrogate recoveries observed for the Ames samples were higher than those observed for the Chicago samples. This is likely attributable, at least in part, to the complexity of the Chicago samples. INTERLABORATORY COMPARISON STUDIES TOC1 Two interlaboratory comparison studies were conducted to check the comparability of TOC1 assay as conducted by SwRI and GSRI. In the first study, selected extracts from the two plants were submitted for TOC1 assay by the other laboratory. A second set of TOC1 extracts was prepared at MRI by mixing several extracts of organic chemicals manufacturing wastewaters. The results of these two studies are shown in Table 56. Although some significant discrepancies are apparent, the data from the two laboratories are generally comparable. 107 �TABLE 55. SUMMARY OF SURROGATE RECOVERY DATA Plant Sample type Determinations Surrogate recovery dg Naphthalene d12-Chrysene () % () % Flue gas outlet 11 47 ± 12 86 ± 12 Flue gas inlet 22 57 ± 24 73 ± 19 Plant background air particulates 21 48 ± 23 98 ± 22 ESP ash 51 44 ± 25 96 ± 22 Bottom ash 51 55 ± 20 85 ± 31 6 90 ± 16 90 ± 18 36 65 ± 15 110 ± 28 Bottom ash hopper quench water influent 6 69 ± 17 110 ± 18 Bottom ash hopper quench water overflow Ames 50 42 ± 32 88 ± 25 44 ± 38 88 ± 17 Coal RDF Well water Chicago Flue gas outlet 11 (resin) 11 (filter) 26 ± 23 29 ± 13 61 ± 37 62 ± 34 Flue gas inlet 11 (resin) 11 (filter) 41 ± 26 32 ± 17 93 ± 28 55 ± 22 Plant background air particulates 12 31 ± 23 51 ± 45 ESP ash 53 26 ± 18 35 ± 22 Bottom ash 51 33 ± 18 21 ± 20 Refuse 51 9 ± 13 10 ± 21 4 24 ± 30 13 ± 10 Tap water a The resin and filter catch portions of the Chicago flue gas samples were spiked, extracted, and analyzed separately for the surrogate compounds, 108 �TABLE 56. RESULTS OF INTERLABORATORY TOC1 ANALYSES TOC1 (ng/extract) SwRI results GSRI results Sample Chicago flue gas outlet (5/15) resin3 Chicago flue gas inlet (5/7) particulate Ames Ames Ames Ames Ames Ames bottom ash (3/7, bottom ash (3/9, flue gas outlet flue gas outlet RDF (3/4, 0230) RDF (3/3, 1430) Synthetic Extract I II III IV a Prepared by SwRI. c Resin and particulate combined. d 11,300 10,900 13,800 12,400, 16,200 Prepared by GSRI. b 1,020 124 4,230 18,100 109,000 215,000 7,300 10,700 7,600 10,400 0130 + 0530)b 2030) (3/15)C (3/18)° 23,000 19,200 39,300 42,800 10,020 31,400 227 91.8 702 443 78,800 181,000 Chicago flue gas outlet (5/12) resin Chicago flue gas outlet (5/9) particulate Chicago flue gas outlet (5/6) particulate Chicago flue gas outlet (5/11) resin 44,500 26,700 39,400 12,000 8,780 47,900 Prepared by MRI. Specific Compound Analysis An interlaboratory study was also conducted using spiked fly ash aliquots spiked with specific compounds. Mixed fly ash from the Ames and Chicago plants was divided into 20-g aliquots. The aliquots were spiked by MRI with six chlorinated compounds and submitted to GSRI and SwRI for analysis by the same extraction, HRGC and scanning HRGC/MS procedures used for the plant samples. Four pairs of duplicate fly ash aliquots were submitted to each laboratory. The results of these analyses are shown in Table 57 along with the surrogate recoveries. Most compounds were identified in the spiked samples by both laboratories. Exceptions were pentachlorophenol in most samples and decachlorobiphenyl in one sample by SwRI. 109 �TABLE 57. INTERLABORATORY COMPARISON OF ANALYTICAL RESULTS FOR THE EXTRACTION AND ANALYSIS OF SPECIFIC COMPOUNDS IN FOUR SETS OF QUALITY ASSURANCE SAMPLES I Compound Spike level (ng/g) II Concentration9 (ng/g) GSRI SwRI Spike level (ng/g) IV III a Concentration (ng/g) SwRI GSRI Concentration (ng/g) GSRI SwRI Spike level (ng/g) 1 ,2-Dichlorobenzeoe 0 NDb ND 585 90, 125 952 , 1,130 2,930 940 , 430 1 ,2,4-Trichlorobenzene 0 ND ND 560 100, 170 1,170 , 1,220 4,200 1,660 , 865 Hexaehlorobenzene 0 ND ND 550 45, 65 295 , 150 2,750 790 , 365 2,4,6-Trichlorophenol 0 ND ND 2,850 ND, 45 1,040 , 748 570 75 , ND " 112 , ND, ND C tr, tr 535 ND , ND tr , tr 1,230 6,050 , 2,890 Spike level (ng/g) Concentration (ng/g) SwRI GSRI 20,200, 4,410 7,420, 6,300 4,390 700, 1,010 11,700, 10,200 2,800 720, 855 7,660, 8,420 85, 75 170, 103 4,280 355, 840 3,690, 2,040 tr, tr 4,020 ND, ND tr, tr 403, 566 2,450 8,650, 6,800 2,460, 1,280 1,630, 1,680 275 Pentarhlorophenol 0 ND ND 2,680 Decachlorobiphenyl 0 ND ND 490 Naphthalene-da 38, 2 88, 88 25, 40 89 , 88 59 ,30 98, 84 34, 42 101, 89 Chrysene-d,2 49, 23 73, 84 41, 40 88 , 76 50 , 38 75, 71 45, 45 111, 103 425, 970 Surrogate Compound Recovery ( ) * a Concentration values reported for two identical samples prepared by MRI. b ND = not detected. c tr = trace. �PCDD and PCDF Analysis The results of the interlaboratory comparison of PCDD and PCDF analyses conducted on Chicago flue gas outlet extracts by MRI and R. Harless at EPA's Research Triangle Park laboratory are shown in Table 58. Both the qualitative and quantitative results from the two laboratories were quite comparable. There were no qualitative discrepancies. The agreement in quantitation is reasonable, particularly in view of the facts that: (1) the two laboratories utilized different gas chromatographic systems and different selected ion monitoring procedures (computer controlled ion selection by MRI and hardware controlled ion selection by EPA) and (2) that the levels were near the limits of detection. TABLE 58. INTERLABORATORY COMPARISON OF THE LEVELS OF PCDDs AND PCDFs IN COMPOSITE EXTRACTS FROM THE CHICAGO NW INCINERATOR Composite Total mass in sample (ng) EPA3 results MRI results Parameter 14 1 24 2 2,3,7, 8-Tetrachlorodibenzo-p-dioxin 24 7.0 3 2,3,7, 8-Tetrachlorodibenzo-p-dioxin 34 9.4 4 Total tetrachlorodibenzo-p-dioxin 500 1,200 5 Total tetrachlorodibenzo-p-dioxin 360 740 6 Total tetrachlorodibenzo-p-dioxin 400 660 7 Total tetrachlorodibenzofuran 5,600 1,640 8 a 2,3,7, 8-Tetrachlorodibenzo-p-dioxin Total hexachlorodibenzo-p-dioxin 1,400 280 Calculated from data in Reference 8. 111 �SECTION 10 EMISSIONS RESULTS AMES MUNICIPAL POWER PLANT, UNIT NO. 7 The TOC1 input and emission rates determined for the Ames plant during the test period are shown in Table 59. These results were calculated from the daily mean levels of TOC1 in coal, RDF, and ash from Section 8 and the mass and volume flow rates from the engineering and process data in Section 7. Since TOC1 is not a conservative parameter, it the mean TOC1 destruction rate is greater than 99%. data indicate that flue gas was responsible for the emissions, 83%. Bottom ash and fly ash contributed tively, of the total emissions. is not surprising that Interestingly, these largest fraction of TOC1 only 11 and 5%, respec- Table 60 shows the input and emission rates for the target PAHs and other compounds identified in the composited Ames extracts. The mass and volume flow data used for the input and emission calculations are averages for the sampling days comprising the composite days. The emission rates for PCBs in Table 61. Only the composited flue PCBs by HRGC/MS-SIM. PCBs may have sions media at concentrations below the Ames flue gas samples are shown in gas outlet extracts were analyzed for been present in other inputs and emisthe limit of detection of scanning HRGC/MS. A summary of the cadmium inputs and emissions for the test days investigated at the Ames Municipal Power Plant is presented in Table 62. The total inputs and emissions represent a good mass balance. CHICAGO NORTHWEST INCINERATOR, UNIT NO. 2 The calculated TOC1 inputs and emissions are shown in Table 63. The apparent mean TOC1 destruction rate (97%) is slightly lower than was observed for the Ames plant. However, the difficulty experienced in taking representative samples of raw refuse hinders accurate destruction efficiency determinations. The contribution of flue gases to total TOC1 emissions is remarkably similar, 87% for the Chicago incinerator relative to 83% for Ames power plant. 112 �TABLE 59. TOTAL ORGANIC CHLORINE INPUTS AND EMISSIONS - AHES MUNICIPAL POWER PLAHT, UKIT Nn Inputs Coal TOC1 RDF Date Load feed Feed () 1 ( ) (kg/hr) I 3/2 3/3 3/4 3/5 36 / 3/7 3/8 3/9 3/10 3/11 3/12 3/13 3/14 3/15 3/17 3/18 3/19 3/20 3/22 3/23 86 86 90 91 8 9 87 80 60 83 8* 89 89 87 62 84 91 89 87 84 52 0 13 23 19 2 2 14 20 4 10 24 21 16 24 4 12 17 15 7 11 0 14,600 14,400 1,0 440 15,200 1,0 460 15,200 12,800 1,0 080 14,200 13,700 1,0 600 14,100 13,900 1,0 090 1,0 420 1,0 430 1,0 420 1,0 560 14,100 9,250 Decemin•tions 20 20 20 Mean 83 14 13,800 Standard 11 deviation 7.7 1,700 (gg n/) TOC1 (t/r ».h) Emissions Refuse-derived fuel tOCl TOC1 (kg/hr) (ng/g) (gh) ./r Total TOC1 ( / r « h ) Botto* ash TOC1 (gh) k/r' 5 73 5 5 5 5 5 5 5 5 5 5 5 5 72 72 76 73 76 64 54 71 6. 85 8. 00 7. 05 6. 95 2.130 4,290 3,640 400 ,3 2,470 3,180 491 1,530 430 ,4 430 ,2 2,720 4,350 5 5 5. 45 71 417 1,850 5 5 71.5 71 2,930 2,550 78 70.5 4. 63 1,200 1,740 0 (gh) ./r 500 400 5 5 5 (ng/g) tOCl 200 350 250 350 100 20 5 HI) 20 6» 8.4 0 toil 20 100 20,100 9,300 350 ,0 820 ,0 9,900 12,100 500 ,0 530 ,0 1,0 300 1,0 990 960 ,0 2,0 200 42,900 39,900 12,700 3,5 300 2,0 450 38,500 2,500 8,100 5,0 640 8,0 600 26,100 95,700 12 12 4,0 300 4,0 000 12,800 3,0 310 2,0 460 3,0 860 260 ,0 820 ,0 5,0 650 8,0 610 2,0 620 9,0 580 12 5.5 0.55 350 550 450 550 400 500 200 300 550 500 400 550 124 97 36 44 55 33 4.4 38 113 57 156 38 43 53 16 24 22 17 0.88 11.4 67 29 62 21 20 13 13 2,312 11,500 3,0 890 3,0 900 380 62 28 1,570 620 ,0 2,0 880 28,800 150 47 21 Mass (kg/hr) ESP ash TOC1 (dscn/hr) Flue ga«" TOC1 TOC1 Total 1UC1 Percent of ttx.1 e«is»io»» (ng/d.«)_ («s/hr) (a.g/hr) 4 7 2.5 6.5 5.2 2.7 3.1 56 3.5 5.2 2.6 5.6 3.0 7.8 6.2 3.2 3.7 67 4.2 6.2 3.1 3920 0,0 323,800 3800 2,0° 322,500C 3030 4.0° 318,400C 29I.300C 2290; 4,0) 3330 3,0° 341,500C 156 1,210 766 454 951 412 367 411 833 562 48.2 392 251 146 324 131 107 100 278 192 54.4 438 312 168 351 156 191 105 296 257 1 10 17 10 7 14 9 1 4 24 10 1 3 3 1 2 35 4 2 1 89 89 80 87 92 84 56 95 94 75 '20 ,0 ,0 20 ,0 20 ,0 20 ,0 20 200 20 0 ,0 20 200 2^3 3.0 3.8 3.6 3890 2,0 289,300 2840 5,0 3540 2,0 319,100 314,800 3000 2,0 332,200 225.700 332 1,680 238 90 5 855 1,050 25 0 124 157 109 486 61.5 39 0 273 331 6. 56 41.2 35.4 174 511 36 4 2 1 62 95 20 13 ND («/hr) Mass ,0 20 ,200 ,0 20 ,200 ,0 20 ,200 ,0 20 ,0 20 ,0 20 ,0 20 1,200 («/«> TOC1 13 19 19 19 M_rA g>s_ _ 12 12 _ 12 12 7.7 9.2 308,700 616 194 246 11 5 83 14.6 17.4 32,900 425 134 138 10 10 13 a Estimated from Mass Missions data collected during 1978. Douglas Fiscus, Midwest Research Institute, personal conminication. b Flue gas sampled at the outlet of the ESP except where indicated. c Flue gas outlet samples were not collected on this day. The mass emission* and TOCl concentration data are for flue gas inlet samples collected on this day. Flue gas TOCl emissions are corrected for the TOCl to the ESP ash. �TABLE 60. COMPOUNDS QUANTITATED IN THE PRIMARY INPUT AND EMISSION MEDIA FOR THE AMES MUNICIPAL POWER PLANT, UNIT NO. 7 Inputs Compound Composite day Refuse-derived Coal fuel Input Input Cone, rate Cone. rate ( g h ) (ng/g) («ft/hr) •/r (ng/g) Plant background air Input rate Cone, (ng/dscn) (•R/hr) Flue gas inlet Emission Cone. rate (ng/dse.) («g/hr) Emissions Flue gas outlet ESP ash Emission Emission Cone. rate Cone. rate (ng/dscn) (»g/hr) (ng/g) («g/hr) Botton ash Enission Cone. rate (ng/g) («g/hr) Target PAH compounds Pyrene 110,000 1000 3,0 210,000 110,000 2000 7,0 1 2 3 4 5 1,570 1,840 1,260 2,120 4,110 2,0 300 2,0 600 1,0 800 2,0 800 59,000 1 2 3 1,190 1,640 3,320 900 3,210 17,000 2,0 300 4,0 600 1,0 200 4,0 600 984 271 306 198 1,300 1,200 580 420 1 2 1,340 1,960 3 Fluoranthene 7,550 900 ,9 15,400 8,500 18,600 3,810 4 Anthracene 1 2 3 4 5 4 5 Phenantbreoe 1,070 400 ,4 2,0 000 2,0 800 5,0 300 1,0 400 5,0 800 552 436 282 372 1,500 1,900 530 790 434 1,200 Chrysene Benzo[a]pyrene 1 2 3 4 5 370 425 1,060 238 1,300 1 2 3 4 5 5,400 600 ,0 15,000 3,200 19,000 76 140 200 200 54 390 320 320 37 480 0.17 0.16 0.19 008 .2 004 .2 0.030 59 57 77 89 100 16 18 22 28 28 49 77 78 3,100 4,100 1, 0 80 1,800 296 810 0.05 0.11 0.11 0.16 0.07 70 240 140 87 94 20 78 42 28 26 46 0.7 0.7 1.1 0.5 0.05 0.12 0.11 0.17 0.07 220 850 480 230 330 64 280 140 74 90 0.29 0.40 0.37 0.60 0.38 0.04 0.07 0.06 0.09 0.05 0.01 0.28 0.016 0.015 008 .0 0.02 0.4 14 26 24 14 22 0.07 0.17 0.11 0.09 0.07 5 270 420 660 640 200 110 0.32 0.04 0.09 0.11 0.13 0.044 0.003 0.29 140 ,0 940 948 828 0.6 0.8 0.8 0.36 0.7 0.7 1.0 0.5 0.36 3.5 28 0.76 77 40 97 28 130 110 96 250 66 330 96 12 13 21 64 120 19 63 0.2 0.2 0.2 0.2 0.2 0.2 Benzo[g,h,i]perylene 1 2 3 4 5 46 10 52 30 1.0 21 17 36 450 160 32 32 74 22 90 9.0 64 29 6.0 420 26 16 1.9 150 0.3 0.90 0.4 3.2 6.0 22 38 6.2 17 2.7 170 0.76 13 3.8 28 6.0 3.3 0.015 13 130 ' 0.09 140 43 500 3.2 99 78 14 180 24 Indeno [ 1 , 2 , 3-c , d Jpy rene 1 2 3 4 5 32 250 13 13 30 8.8 1.0 8.0 9.6 2.8 46 0.3 100 0.96 22 4.6 6.6 1.5 (continued) 58 �TABLE 60 (Continued) Compound Composite day Inputs Refuse-derived Plant Coal fuel background air Input Input Input Cone. rate Cone. rate Cone. rate (ng/g) (mg/hr) (ng/g) (mg/hr) (ng/dscm) (mg/hr) Flue gas inlet Emission rate Cone, (ng/dscm] (mg/hr) 1 Emissions Flue gas ESP ash Bottom ash outlet Emission Emission Emission Cone. rate Cone. rate rate Cone, (ng/dscm) (mg/hr) (ng/R) (mg/hr) (ng/g) (mg/hr) Additional compounds identified Dichlorobenzene 1,2,4-Trichlorobenzene Hexachlorobutadiene 3.3 1 2 3 4 5 1,300 1,200 520 430 25 79 1 2 3 4 5 1.0 24 8.2 24 25 3,500 5,200 980 920 5 1 2 3 002 .08 0.0016 0.02 002 .04 0.07 0.08 1.5 99 180 32 52 110 34 69 0.02 0.01 9.6 6.8 0.07 19 85 24 103 30 6,400 7,700 3,000 6,000 6,200 1,800 2,600 1,000 1,200 1,300 300 400 400 2,100 580 0.010 4 5 Tetrachlorobenzene 1 2 3 5 Pentachlorophenol Phenol 2 , 4-Dinethylphenol 1 2 3 4 5 1 2 3 4 5 1 2 3 4 5 1,300 3,500 24 690 10,000 12,000 2,800 23,000 29,000 150,000 170,000 39,000 310,000 420,000 7.2 1,500 3.3 1.3 0.8 1.5 1.8 0.46 0.21 0.11 0.23 0.25 4,700 4,000 13,000 5,100 9,500 1,300 1,300 4,000 1,600 2,600 220 260 190 380 230 460 98 640 990 110 260 27 920 1,900 1,700 980 1,600 1,800 360 730 11 8 (continued) 2.5 �TABLE 60 (Continued) Inputs Compound Naphthalene Fluorene Benz [a ] anthracene Benzofluoranthrene Benzo[e Jpyrene Acenaphthene Acenaphthylene Trichlorobenzene Composite day Plant Refuse-derived background air Coal fuel Input Input Input Cone, rite Cone. rate Cone, rate (og/g) (•g/hr) (ng/g) («g/hr) (ng/dsca) (•g/hr) 1 2 3 4 5 1,400 1,100 1,800 1,800 2,700 1 2 3 4 5 3,500 50,000 43,000 3,100 5,600 78,000 3,300 45,000 7,000 100,000 710 1,000 620 1,800 740 200 340 190 560 200 0.22 0.32 0.28 0.13 0.037 0.048 0.045 0.017 120 34 0.020 0.073 0.079 0.089 0.052 0.42 0.67 0.63 0.65 0.51 1,600 1,900 712 677 0.040 0.037 0.048 0.045 0.017 0.53 0.55 0.38 600 450 380 320 0.28 0.22 0.32 0.28 0.13 0.14 0.44 20,000 16,000 3 , 0 9 , 0 600 800 25,000 2,200 9,600 24,000 1,500 2,800 39,000 1,500 3,200 1 2 3 4 S 1 2 3 4 5 Emissions Flue gas Flue gas Bottoa ash inlet outlet ESP ash Emission Emission Emission Emission rate Cone. rate Cone. rate Cone. rate Cone, (ng/dsn) («g/hr) (ng/dscn) (•g/hr) (ng/g) (iig/hr) (ng/g) («g/hr) 000 .6 0.11 0.095 0.1 0.070 7.2 3.2 960 260 1,200 3,800 6,600 13,000 3,400 18,000 1 2 3 4 5 650 970 1,600 1,400 1,500 9,500 14,000 22,000 18,000 22,000 1 2 3 4 5 220 240 560 400 450 3,200 3,400 7,700 5,300 6,500 0.17 0.2 0.18 0.22 15 360 110 29 1.5 140 61 9.2 14 17 6.5 2.7 12 6.9 7.7 1.9 0.88 3.6 2.2 29 261 470 8.8 2.3 1 2 3 4 5 1 2 3 4 5 190 180 24 98 240 2.2 9.9 650 550 81 300 850 1,200 3,200 1.0 20 24 120 75 10 100 130 6.6 7.2 36 77 24 10.2 26 7.2 (continued) 0.55 12 30 5.5 32 47 �TABLE 60 (concluded) Compound Dime thy Ipht ha late Diethylphthalate Di-n-butylphthalate Butylbenzylphthaalte Composite day 1 2 3 4 5 a Specific isomer not Emissions Flue gas Flue gas Bottom ash inlet outlet ESP ash Emission Emission Emission Emission Cone. rate Cone. rate Cone. rate Cone. rate (ng/dscm) (mg/hr) (ng/dscm) (ng/hr) (ng/g) (mg/hr) (ng/g) (mg/hr) 3.0 0.20 730 1 2 3 4 5 11 0.5 9,100 25 ,000 290 1 ,300 1 ,400 2,700 11 , 0 23 , 0 00 00 18 ,000 49 ,000 14 ,000 61 ,000 6,400 12 ,000 14 ,000 28 ,000 1 2 3 4 determined. 2.0 0.48 26 1.20 37 48 16 5 .1 4.0 42 12 35 170 0.40 16 .8 6.6 11 58 32 3 .2 15 3.0 36 7.2 4.0 9.6 6.0 14 51 59 ,000 110 ,000 22 ,000 46 ,000 1 2 3 4 5 350 ,000 44 ,000 35 ,000 22 ,000 0.30 1 ,600 1 2 3 4 5 5 Bis(2-ethylhexyl)phthalate Inputs Refuse-derived Plant Coal fuel background air Input Input Input rate Cone. rate Cone. rate Cone, (ng/g) (mg/hr) (ng/g) (nig/hr) (ng/dscm) (mg/hr) 970 ,000 190 ,000 66 ,000 46 ,000 6.0 Ib 28 14 3.0 2.0 8.0 980 7.2 4.8 1,200 480 810 19 9.8 470 260 260 �TABLE 61. FLUE GAS CONCENTRATIONS OF PCBs AND EMISSION RATES FOR THE AMES MUNICIPAL POWER PLANT, UNIT NO. 7 Total PCBs Concentrations Emission rate (ng/dscm) (mg/hr) Ames composite day 1 5.2 1.4 2 27 9.0 3 23 6.8 4 25 8.2 5 17 4.8 Mean 19 6.0 S.D. 8.8 118 3.0 �TABU 62. CADMIUM INPUTS AKD EMISSIONS - AHES MUNICIPAL POVtR PLANT, UNIT NO. 7 Input Test day Date Load () I RDF (I) Mass flow (kt/hr) RDF Coal Cd cone. (MK/I) Cd input (mg/hr) Mass flow (kg/hr) Cd cone. (M8/8) Cd input (mg/hr) Total Cd input (mg/hr) Bottom ash (BA) Mass Cd Cd floo cone. emissions (kg/hr) (mg/hr) (MB/I) Emissions ESP ash (FA) Voluse Cd Mass Cd flow flow cone. emissions (dscm/hr) <m*/hr) (kg/hr) (Ug/g) Flue gas Cd Cd cone. emissions (Uf/dscm) (mg/hr) Total emissions (mg/hr) Percent of total emissions Flue BA FA gas 11 3/12 89 23.5 1.0 390 1,200 9.01 10,800 12 3/13 89 15.3 15.010 0.736 11,050 2,700 2.10 5,670 16,700 400 1.91 760 1,200 8.36 10,030 164,000 13 3/14 87 23.8 13,800 0.135 1,860 4,300 3.16 13,600 15.500 550 2.19 1,200 1,200 8.21 9.850 145,000 14 3/15 3/16 62 3.69 10,800 0.138 0.144 1,490 410 5.30 2,170 360 .6 150 2.41 0.876 360 1,200 1,200 5.43 2.90 6,520 3,480 129,000 21 3/24 85 6.15 14,800 0.149 2,200 970 2.63 2,550 4,750 200 1.36 270 1,200 4.12 4,940 153.000 22.55 3,450 8,660 3 57 22 3/25 84 10.9 14,300 0.112 1,600 1.740 2.88 5,010 6,610 300 2.70 810 1,200 6.34 7,600 148.000 27.95 4,140 12.600 6.5 60 . 5 33 23 3/26 87 15.0 14,400 920 1,200 7.54 9.050 1800 4.0 25.46 3,770 13,700 7 66 27 8 8 6 3 3 3 3 3 3 1,200 6.48 7,780 148,000 61 33 2.2 2,630 11,400 Determinations Mean Standard deviation 550 4,300 0.231 3.320 2.530 2.82 7.130 1.0 050 40 0 7 7 7 7 6 7 6 6 6 7 83 14 13,900 0.235 3,590 2,420 3.15 6,020 9,620 360 1.96 720 1,420 0.224 3.720 1,510 1.11 4,160 5,540 160 0.64 350 9.5 7.8 7 6 8 25.3 2.70 3,790 11,600 S.5 350 2,650 2.2 4.5 40 6.5 �TABLE 63. Date 5/3 5/4 5/6 5/7 5/8 5/9 5/10 5/11 5/12 5/13 5/15 5/16 5/17 Refuse input Feed TOC1 TOC1 rate cone, input (kg/hr) (ng/g) (8h) •/r 15,800 15,200 20,300 17,300 17,300 18,200 18,400 18,900 16,000 15,800 16,900 16,600 17,200 Mass emissions (dsc»/hr) < 1 < 1 3 2.9 21 21 12 2.2 15 10 6.6 < 1 < 5.5 < 5.3 16 14 87 103 60 11 53 34 24 < 3.6 12 12 . 88,080 93,960 84,600 92,460 72,600 83,820 85,740 86,280 83,340 84,600 99,060 - 1,100 3,140 1,760 13,500 2,070 3,310 2,540 2,920 1,230 2,300 1,490 - 11 11 11 11 Total TOC1 emissions (•g/hr) Percent of TOC1enissions Cooibined ash Flue gas (X) U) . 5 5 9 6 41 18 5 17 25 1.1 3 - . 95 95 91 94 59 82 95 83 75 89 97 - 5,500 5,290 5,490 4,680 4,680 4,920 4,970 5,110 3,470 3,430 3,670 3,600 3,730 13 12 13 17,200 590 9,800 4,500 8.1 35 86,780 3,200 285 327 13 87 Standard 1,440 deviation 1,180 18,700 800 7.6 34 6,830 3,500 327 345 12 12 Mean o Emissions Flue gasa TOC1 TOC1 cone. emissions (ng/dsc«) ("g/hr) Combined ash TOC1 Mass TOC1 emissions flow cone, (8h) ./r (kg/hr) (ng/g) 67,900 1,670 0 8,100 4,500 13,300 2,390 4,350 2,100 < 16 22,800 200 < 17 Deterain- 13 ations ro 4,300 110 0 470 260 730 130 230 130 < 1 1,350 12 < 1 TOTAL ORGANIC CHLORINE INPUTS AND EMISSIONS - CHICAGO NORTHWEST INCINERATOR, UNIT NO. 2 a Flue gas collected at the outlet of the ESP. 97 295 149 1,250 150 277 218 252 103 195 148 - 102 311 163 1,337 253 337 229 305 137 219 152 11 11 �The input and emission rates for target PAHs and other compounds identified in the composited Chicago extracts are shown in Table 64. Since the refuse extracts contained very high levels of extracted organics and were very difficult to analyze, composite refuse extracts were not prepared. Hence, the data were not available for the target PAHs and other compounds in the primary input medium for these composite days. The emission rates for PCBs in the Chicago flue gas samples are shown in Table 65. As in the case of the Ames data, only flue gas data was available although PCBs may have been present in other media at low concentrations. The emission rates for PCDDs and PCDFs in the Chicago flue gas samples are shown in Table 66. The mean emission rates for total PCDDs and PCDFs are 3,900 and 38,600 |Jg/hr, respectively. Table 67 shows the flue gas emission rates for 2,3,7,8-tetrachlorodibenzo-p_-dioxin. The mean emission rate is 34 pg/hr. A summary of the cadmium inputs and emissions for the test days investigated is presented in Table 68. The agreement between the total cadmium inputs and emissions is poor and reflects the problems encountered in obtaining representative samples of the refuse materials and resulting ashes. 121 �TABLE 64. Compound Composite day COMPOUNDS QUANTITATED IN INPUT AND EMISSION MEDIA CHICAGO NV INCINERATOR, UNIT NO. 2 Plant background air Conr. Input rate (ng/dscn) (ng/hr) Flue gas inlet Cone, Emission rate (ng/dscn) (•g/hr) Flue gas outlet Cone. Emission rate (ng/dsc«) (ing/hr) Combined ash Cone. Emission rate (ng/g) (mg/hr) Target PAH compounds Phenanthrene Fluoranthene 1 2 3 1 120 32 28 1.0 11 2.8 2.4 200 110 340 17 9.2 28 004 .4 no 9.8 2.4 1.6 39 27 51 2.2 0.012 27 18 2 3 Pyrene 1 0.28 0.82 0.035 2 3 0.18 008 .0 300 140 57 26 12 4.8 3.4 4.4 8.0 92 91 77 6.6 17 9.4 12 1 , 3-Dichlorobenzene 1 2 3 130 130 18 7.8 12 11 1.6 1,4-Dichlorobenzene 1 2 3 96 98 14 8.2 8.2 1.2 1 ,2-Dichlorobenzene 1 2 3 140 120 20 12 10 17 1,2, 3-Trichlorobenzene 1 2 3 140 81 27 12 7.0 2.2 48 57 150 4.0 4.8 12 1,2,4-Trichlo robenzene 1 2 3 550 380 160 46 32 13 200 220 560 17 19 48 1 ,3,5-Trichlorobenzene 1 2 3 490 280 120 44 24 10 190 180 460 16 15 40 Tetrachlorobenzene* 1 2 3 1,400 1,000 120 86 40 790 630 68 54 120 1 2 3 100 39 12 1 0 S3 Hexach lo robenzene 470 9.0 3.4 1.0 1,400 110 48 260 38 56 7.8 Additional compounds identified ,_. 78 9.0 4.0 22 (continued) 32 �TABLE 64 (Concluded) Compound Dichlorophenol Trichlorophenol Conposite day 1 2 3 1 2 3 Plant background air Cone. Input rate (ng/dscn) (ng/hr) Flue gas inlet Cone, Emission rate (ng/dscm) (mg/hr) 560 240 190 2,100 970 600 Flue gas outlet Cone, Emission rate (mg/hr) (ng/dscni) 40 20 16 180 82 52 240 280 630 22 24 1,400 1,200 1,900 120 98 160 1,500 1,100 1,700 130 96 140 16 36 8.8 5.8 11 1 2 3 2,200 1,100 600 190 90 52 1 2 3 130 11 64 5.4 190 160 430 Dibenzofuran 1 2 3 86 28 23 7.4 2.4 2.0 100 67 140 DiMthylphthalate 1 2 3 Tetrachlorophenol Pentachlorophenol 1*0 Diethylphthalate 1 2 3 Buty Ibenzy Iphtha late 1 2 3 14 4.8 50 42 400 15 6.1 32 144 54 260 1 2 3 Bis(2-ethylhexyl)- 54 1 2 3 Di-n-butylphthalate a Specific isomer not determined. Combined ash Cone. Emission rate (ng/g) (ng/hr) 130 47 370 1,200 420 3,000 86 83 �TABLE 65. FLUE GAS CONCENTRATIONS OF PCBs AND EMISSION RATES FOR THE CHICAGO NORTHWEST INCINERATOR UNIT NO. 1 Concentrations (ng/dscm) Emission rate (mg/hr) Composite day 1 20 1.7 2 13 1.1 3 93 7.8 Mean 42 3.5 S.D. 45 3.7 124 �TABLE 66. CONCENTRATIONS OF POLYCHLORODIBENZO-P-DIOXINS AND FURANS IN FLUE GAS FROM THE CHICAGO NORTHWEST INCINERATOR AND CORRESPONDING EMISSION RATES Concentrations (ng/dscm) Emission rate 15 12 11 13 2.1 1,300 Total trichlorodibenzo-p-dioxins Day 1 2 3 Mean S.D. 920 1,100 200 Total trichlorodibenzofurans Day 1 2 3 Mean S.D. 350 280 270 300 44 30,000 24,000 22,000 25,000 4,000 Total tetrachlorodibenzo-p-dioxins Day 1 2 3 Mean S.D. 7.2 5.4 6.2 6.3 0.90 620 460 520 530 81 89 84 96 90 6.0 7,600 7,200 8,000 7,600 400 14 21 14 16 4.0 1,200 1,800 1,200 1,400 350 Total tetrachlorodibenzofurans Day 1 2 3 Mean S.D. Total hexachlorodibenzo-p-dioxins Day 1 2 3 Mean S.D. (continued) 125 �TABLE 66 (concluded) Concentrations (ng/dscm) Emission rate (M8/hr) Total hexachlorodibenzofurans Day 1 2 3 Mean S.D. 43 84 59 62 21 3,800 7,200 5,000 5,300 1,700 Total heptachlorodibenzo-p-dioxins 7.2 7.8 7.7 7.6 0.32 Total 620 660 660 650 23 7.2 7.2 8.0 7.5 0.46 620 620 680 640 34 2.6 2.2 2.8 2.5 0.39 220 190 240 220 25 0.72 0.63 0.46 0.60 0.13 Day 1 2 3 Mean S.D. 62 54 40 52 11 heptachlorodibenzofurans Day 1 2 3 Mean S.D. Octachlorodibenzo-p-dioxin Day 1 2 3 Mean S.D. Octachlorodibenzofuran Day 1 2 3 Mean S.D. 126 �TABLE 67. CONCENTRATIONS OF 2,3,7,8-TETRACHLORODIBENZO-P-DIOXIN IN FLUE GAS FROM THE CHICAGO NW INCINERATOR AND CORRESPONDING EMISSION RATES Concentration (ng/dscm) Day 1 0.35 Emission rate (pg/hr) 3.0 . *"~" i» 2 0^36 30 3 0.52 44 Mean 0.41 34 S.D. 0.10 127 8.0 ^ �TABLE 68. CADMIUM INPUT AND EMISSIONS FROM CHICAGO NORTHWEST INCINERATOR, UNIT NO. 2 Emissions Date Refuse input Mass Cd feed cone, (kg/hr) (pg/g) 8 5/12 16,000 1.45b 9 5/13 17,500 10 5/15 11 Test day Cd input (gh) •/r Combined ash Mass Cd emissions cone. (kg/hr) (Mg/g) Cd emissions (8h) •/r Volume emissions (dscm/hr) Flue gasa Cd cone. (pg/dscm) Cd emissions (mg/hr) Total Cd emissions (mg/hr) Percent of total emissions •Flue Combined gas ash () X 23,200b 3,470 0.54 9,450 3,800 17.6 66,900 16,900 0.47 7,940 3,670 26.6 97,600 5/16 16,600 0.52 8,630 3,600 14.5 52,200 12 5/17 17,200 0.48 8,260 3,730 12.8 47,700 87,200 285 24,900 72,600 66 34 13 5/18 17,500 0.59 10,300 380 ,0 32,500 97,500 240 23,400 55,900 58 42 14 5/19 2,0 240 60b .2 1500 3,0b 740 ,6 1300 5,0 1050 0,0 273 2,0 740 1040 8,0 85 15 5 7 6 3 3 3 Determinations Hean I™4 ro co Standard deviLation 7 5 8.55 2. 05 6 3 3 3 17,700 0.52 8,920 4,220 16.8 75,000 95,100 266 25,200 103,000 70 30 2,100 0.05 960 1,430 6.3 44,100 7,000 23 2,020 67,600 14 14 a Flue gas collected at the outlet of the ESP. b Not included in determinations of mean and standard deviation. �SECTION 11 STATISTICAL SUMMARY OF PILOT STUDY DATA OVERVIEW This section summarizes the data obtained from the chemical analysis of specimens collected in the pilot study. The chemical analysis was performed in two phases or tiers. In the first tier, the total organic chlorine (TOC1) concentration was measured in nearly all of the specimens collected. Some compositing of specimens was performed before chemical analysis to reduce cost. In the second tier, many more specimens were composited because of the greater expense at this level of analysis. Also, only specimens from selected media were analyzed. For the first tier chemical analysis data, the mean, coefficient of variation (CV) and nominal 95% confidence intervals for the TOC1 concentration are calculated for each sampling location at both combustion sites. The mean and CV are calculated for the concentrations of compounds quantified in the second tier analysis. In addition, the total mass flow rate and its CV are calculated. The mass flow rate is calculated by weighting the measured concentration of the compounds by the total mass flow rate associated with each measurement. The summary statistics are presented below with brief descriptions of the calculation methods. FIRST TIER SUMMARY Total Organic Chlorine For the sampling locations where each specimen was chemically analyzed independently (no compositing) the arithmetic mean (X) was calculated using the equation n X = Z X./n where X. is the TOC1 concentration of the i specimen and n is the number of specimens. The CV is calculated by first calculating the sample variance (S2) 129 �S2 = I (X. - X)2/(n - 1) The CV = S/X. The nominal 95% confidence intervals are calculated by (X - t Q5(df) S/S/n" , X + t Q5(df) where t 05(df) is obtained from tables of Student's t distribution9 and df denotes 'tne appropriate number of degrees of freedom, which is equal to the number of independent chemical analyses minus one. For several media many specimens were collected. To minimize the cost of chemical analysis for these media while retaining sufficient statistical information, a complex compositing protocol was developed for the sample locations where more than one specimen per day was collected. The compositing varied for the samples collected each day. On some days all were composited, on others the two within a shift were composited, and on others none were composited. These locations were fly ash, bottom ash, coal, RDF and OW at Ames and fly ash, combined ash and refuse at Chicago, NW. No compositing was done for the specimens collected at the other sample locations. To modify the calculations for X and S2 to compensate for the compositing, each chemical determination was assigned a weight equal to the number of specimens composited. Then the weighted mean Y was calculated by m m Y = 1 W. Y. / I W. , W i=l x x 1=1 x where Y. is the i chemical determination, W. is the number of specimens composited for the i chemical determination^nd m is the number of chem m determinations. Because I W. = n and, on average, m n I W. Y. = I X., then Y equals X, on average. I w i=l * 130 �To estimate S2 from the composited data, calculate m m 2 Sw = ._- W1 (Y. - Yw )2 /I W. I 2 1 ._- i m where W., Y., Yw, and m are the same as above. Because I W? (Y. - Y )2 i i i i w i=1 n approximately equals £ (X. - X)2 on average, S2 approximately equals S2 on average. Hence the CV (S/X) is estimated by S /Y . The technique above gives a method to estimate X and S2 as if no compositing were done. A theoretical justification of these techniques is given in Appendix C of Lucas et al.1 Tables 69 and 70 display the statistical summary of the TOC1 concentrations measured in the pilot study. Chemical Analysis Measurement Errors To assess the measurement errors in the chemical analysis, a method of standard additions was employed. Known amounts of two surrogate compounds, dg-naphthalene and di2~cnrysene, were added to the composited specimens before the chemical analysis. The mean percent recoveries of the surrogate compounds and their CVs are given in Tables 71 and 72. If the percent recoveries in these tables are indicative of the recovery rate for TOC1, then the concentrations of TOC1 are underestimated. This underestimation would be greater for the specimens from Chicago than those from Ames. However, the summary statistics reported in Table 66 and 67 above are not adjusted for the percent recovery. Biases of this type can affect the true confidence of a nominal 95% confidence interval. For example, in Table 68 the mean percent recovery of the surrogate compounds of the flue gas inlet is 59%. If this indicates a negative bias in estimating the true mean concentration of TOC1 of 41%, the true confidence of the nominal 95% confidence interval can be estimated using Table 73. To calculate the ratio of the bias (BIAS) and standard error (SE), use BIAS/SE = 4l/(49/Vl9) = 3.7 , where 41 is the absolute percent bias, 49 is the CV in Table 69, and 19 is the number of specimens analyzed. Table 73 indicates the true confidence of the nominal 95% confidence interval in Table 66 is less than 6%. Table 73 also includes the impact of other levels of bias (relative to the SE) on the true confidence of a nominal 95% confidence interval. 131 �TABLE 69. SUMMARY STATISTICS FOR TOTAL ORGANIC CHLORINE CONCENTRATION DATA FROM AMES, IOWA a Media (units) Number of specimens Mean Degrees Coefficient of of variation ( ) freedom % Nominal 95%b confidence interval Gaseous (ng/dscm) Flue gas inlet Flue gas outlet Ambient air 19 11 20 562 632 * 49 85 18 10 (426, 698) (254, 1,010) 90 (89) 88 11 62 8.3 3.6 58.6 4.4 11,900 536 81 183 23 116 50 (49) 50 5 36 (-1.0, 17.6) (2.9, 4.2) (35.1, 82.1) (3.5, 5.3) (8,342, 15,470) 91 6 664 373 70 33 51 5 (570, 760) (231, 514) 54 32 2 (1.4, 107) Solid (ng/g) Fly ash (c) Bottom ash Coal Refuse-derived fuel Liquid (ng/liter) OWd Quench water influent Well water a Number of independent chemical analyses minus one. b Nominal value based on normal probability distribution theory. c Numbers in ( ) are estimates excluding the maximum value of 210 ng/g. This value is 21 times larger than the next largest value. Both sets of summary statistics are included to illustrate the impact of the one extreme value on the estimates. d Bottom ash hopper quench water overflow. * Measured values in field specimens not significantly different from blanks. 132 �Table 70. SUMMARY STATISTICS FOR TOTAL ORGANIC CHLORINE CONCENTRATION DATA FROM CHICAGO NW Q Media (units) Number of specimens Mean 11 11 (10) 12 2,200 3,220 (2,190) 1.67 72 67 61 93.6 9.9 902 4 30 Nominal 95%b confidence interval Coefficient Degrees of of variation ( ) freedom % Gaseous (ng/dscm) Flue gas inlet Flue gas outlet (c) Ambient air 34 109 ( 36) 64 10 (1,698, 2,702) 10 (862, 5,578) ( 9) (1,330, 3,040) 11 (-.68, 4.02) Solid (ng/g) Fly ash Combined ash Refuse 85 162 251 52 50 50 (71.7, 115.6) (5.8, 13.9) (283.8, 1,520) Liquids (ng/liter) City tap water * 0 Not calculated because there was no variability in the data. a Number of independent chemical analyses minus one. b Nominal value based on normal probability distribution theory. c Numbers in ( ) are estimates excluding the maximum value of 13,500 ng/dscm. This value is 4 times larger than the next largest value. Both sets of summary statistics are included to illustrate the impact of the one extreme value on the summary statistics. 133 �TABLE 71. SUMMARY OF SURROGATE COMPOUNDS PERCENT RECOVERY FOR SPECIMENS FROM AMES, IOWA di2~Chrysene dft-Naphthalene Media No. of analyses Mean % recovery Coefficient of variation ( ) % No. of analyses Mean % recovery Coefficient of variation ( ) % 18 11 56 47 45 25 19 11 71 86 26 14 51 42 6 37 44 55 90 65 56 36 18 22 51 49 6 37 96 85 90 111 24 37 19 25 40 6 2 51 69 66 54 25 1 48 6 3 88 111 88 29 16 20 Gaseous Flue gas inlet Flue gas outlet Solid u> •P- Fly ash Bottom ash Coal Refuse-derived fuel Liquid ow* Quench water influent Well water a Bottom ash quench water overflow. b Specimens that were inadvertently evaporated to dryness were excluded. �TABLE 72. SUMMARY OF SURROGATE COMPOUND PERCENT RECOVERY FOR SPECIMENS FROM CHICAGO, NW Media dg-Naphthalene di2~Chrysene Number Mean Coefficient Number Mean Coefficient of percent of of percent of analyses recovery variation ( ) analyses recovery variation ( ) % % Gaseous Flue Gas Inlet Flue Gas Outlet Ambient Air 11 11 12 37 27 31 84 98 75 11 11 12 74 62 51 48 82 88 53 33 44 26 35 9 68 57 51 52 33 44 36 22 12 61 105 193 3 27 131 3 13 92 Solid Fly Ash Combined Ash Refuse Liquid City Tap Water 135 �TABLE 73. VALIDITY OF CONFIDENCE STATEMENTS FOR SELECTED LEVELS OF BIAS True confidence level* for the x ± 1.96 SE interval a BIAS/SE 0 0.5 0.92 1.0 0.83 1.5 0.68 2.0 0.48 2.5 0.29 3.0 0.15 3.5 0.06 4.0 * 0.95 0.02 Calculated according to the integral of the 1.96 + BIAS/SE ;V e"^ dx -1.96 + BIAS/SE a BIAS/SE is used because the true confidence depends on the relative magnitude of the bias with respect to the SE, not the absolute magnitude. Here, BIAS denotes the absolute average deviation of the estimate from the true value and SE denotes the standard error of the estimate and is equal to the standard deviation (s) divided by the square root of the sample size 136 �Table 74 summarizes the estimates of the CVs (S/X) for both the sampling and measurement (as indicated by the surrogate recovery data) component. One should note that the measurement CVs for Ames are uniformly less than those for Chicago. In fact, for some sampling locations at Chicago NW, the measurement component dominates the total variability giving negative estimates of the sampling component. This is not unexpected for the ambient air and city tap water because at these two locations one would expect the media to be rather homogeneous. However, this is unexpected at the flue gas inlet. SECOND TIER SUMMARY In the second tier of chemical analysis the concentrations of many compounds were measured. Because of the expense at this level of chemical analysis, much compositing of specimens was done before the analyses were performed. At Ames, five pairs of days were randomly selected. For each sampling location, all specimens collected during the pair of days were composited for one chemical determination. This gave a total of five independent chemical determinations in this tier for each sample location from Ames except RDF, where only four chemical determinations were performed. At Chicago, three sets of three days were randomly selected. For the selected sampling locations, all specimens collected during the three days were composited for one chemical determination. This gave a total of three independent chemical determinations in this tier for the selected sample locations at Chicago. To statistically summarize the second tier data, the arithmetic mean (X) and CV (S/X) were calculated for the concentration measurements. Also, to estimate the mass flow rates, the variable Y. was defined as Y. = r. X. ' i i i, where X. is the concentration for the i .chemical determination and r. is the mass flow rate associated with the i chemical determination. The arithmetic mean Y and CV (S/Y) were calculated to summarize the flow rates. In calculating the mean concentrations and flow rates, all trace values were assumed to be zero. This will result in an underestimate of the true values. The number of quantifiable values are also included in the summaries. The magnitude of underestimation resulting from substituting zero for trace values depends upon the number of traces and the levels of quantifiable values compared to the minimum quantifiable level. Because of the relatively few composites measured for each compound, the presence of trace values, and the relative large variability in the data (large CVs), no confidence intervals are included in the data summaries. 137 �Table 74. SUMMARY OF COEFFICIENT OF VARIATION FOR THE PILOT STUDY Media Sampling Ames Measurement Sampling Chicago, NV Measurement Gaseous Flue gas inlet Flue gas outlet Ambient air 25 13 a c 85 c 68 68 87 535 (78) 179 24 38 56 64 143 76 12 114 19 18 194 159 42 84 a Solid Fly ash Bottom ash Combined ash Coal Refuse-derived fuel Refuse Liquid OW Quench water influent City tap water 58 17 38 28 132 a Not calculated because specimen amounts were not significantly different from blanks. b Number in ( ) are estimates excluding the maximum value of 210 ng/g. This value is 21 times larger than the next largest value. Both summary statistics are included to illustrate the impact of the one extreme value on the estimate. c The estimates of these values were negative and were excluded because the CV must be non-negative. * The measurement CVs presented above are a weighted average of the CVs in Tables 68 and 69. They were calculated by CV = (S| + Sf2)^/(X8 + X12), where the subscripts 8 and 12 denote dg-naphthalene and d12-chrysene, respectively. 138 �The second tier chemical analysis data is summarized in Tables 75 through 81. These tables include summaries of the primary input and emissions media at Ames. These are coal, refuse-derived fuel, combustion air, flue gas inlet, flue gas outlet, fly ash and bottom ash. The secondary input and emission media, bottom ash hopper quench water influent, well water, and bottom ash water quench water overflow, were excluded because of the sparsity of the data. These tables also include the summaries for the flue gas inlet and outlet from Chicago. The combustion air, combined ash, and fly ash are excluded because of the sparsity of the data. No second tier chemical analysis was done on the refuse from Chicago. 139 �TABLE 75. SUMMARY STATISTICS FOR COMPOUNDS QUAUTITATED IN PRIMARY INPUT MEDIA AT AMES, IOWA Compound Coal Concentration Number olf (ng/g) detectioiis Mean CV (X) Input rate (•g/hr) Mean CV (X) Refuse-derived fuel Input rate Concentration Number of (ng/g) (•g/hr) detections Mean Mean cv (X) CV (X) Phenanthrene Anthracene Fluoranthene Pyrene Chrysene 5 5 5 5 Benzo[a]pyrene 0 0 4 1 4 4 1 0 0 0 Dichlorobenzene 0 1,2,4-Trichloro- 0 4 0 2b 41 52 56 57 69 1600 6,0 30,800 28,800 34,600 9,720 43 53 56 57 71 1,030 74 440 411 109 25 200 83 28 200 2,700 202 875 1,180 300 41 200 50 53 200 0.56 0.10 0.65 0.67 0.41 0.10 0.004 44 92 37 42 28 41 224 0.083 0.016 0.10 0.10 0.06 0.066 0.001 48 95 42 45 31 182 224 4C 0 IndenoT.1,2,3c.dj-pyrene BenzoTg.h,!]- 5 11,830 2,180 2,050 2,440 679 Combustion air Input rate Concentration (•g/hr) Nunber of (ng/g) Mean detections Mean CV (X) CV (X) 0.02 224 0.003 224 0. 3d 5 3 5 5 5 5. perylene 863 52 2,650 79 0.006 149 0.0009 145 b 0.004 224 0.0005 224 b 0.01 224 0.002 224 5 1.7 0.25 0.19 0.41 54 30 67 40 0.25 0.037 0.029 0.063 51 33 69 44 5 0.58 19 0.087 24 benzene Hexachlorobutadiene 0 0 2 Pentachlorophenol 0 2 498 Pentachlorobi- 0 2 a 0 4 4 0 10,300 438 126 1,250 133 2 0 phenyl Phenol Naphthalene Flourene Benzo(a] anthracene Benzofluoranthrene 5 5 5 0 15,360 1,760 4,500 5 630 68 8,960 71 0 Acenaphthene 5 5 1,220 374 33 38 17,100 5,220 32 37 4 0 Acenaphthylene 68 34 38 217,800 24,800 63,200 68 35 39 300 166 28 200 28,400 1,220 80 0 164 51 200 5 5 4 0 0 * CV denotes the coefficient of variation and is calculated by dividing the standard deviation by the mean. a Only trace values were detected, hence no quantification was attempted. b One specimen contained a quantifiable level and one a trace. The trace is always asstned to be zero to calculate the wan c One specimen contained a quantifiable level and three were traces. d Two specimens contained a quantifiable level and one a trace. and CV. �TABLE 76. SUMMARY STATISTICS FOR COMPOUNDS QUANTITATED IN GASEOUS EMISSIONS AT AMES, IOWA Compound Flue gas inlet Concentration Number of (ng/g) detections Mean CV ( ) % Phenanthrene Anthracene Fluoranthene Pyrene Chrysene Benzolajpyrene Benzojg.h.i]perylene Dichlorobenzene 1,2,4-Trichlorobenzene Hexachlorobutadiene Tetrachlorobenzene Pentachlorophenol Phenol 2,4-Dinethyphenol Naphthalene Fluorene Benzf a] anthracene Benzofluoranthrene Benzo[e]pyrene Acenaphthylene Trichlorobenzene Emission rate (mg/hr) CV ( ) % Mean Number of detections Flue gas outlet Concentration Emission rate (mg/hr) (ng/g) CV ( ) % Mean CV ( ) % Mean 5 5 5 5 5a 5 0 438 76.4 126 422 8.8 57.4 48 24 55 62 129 72 134 22 39 130 2.6 18 51 25 60 68 125 74 5 5 5 5 5^ 3d 3 309 65.4 68.2 170 0.54 8.2 6.0 54 25 64 67 224 151 154 66 20 20 50 0.15 2.0 1.8 74 28 60 60 224 143 153 3 3 25.8 69.6 125 108 7.8 20 126 108 2 3 1.7 39 142 139 0.50 12 141 140 1 20.6 224 6.0 224 0 ' | - lb 0 1 4.8 224 5 0 7,260 53 5 1 1 974 24 1.4 50 224 224 2 5.4 0 2 0 8.8 224 0 54 5 4 5,860 1,120 30 67 1,780 336 33 63 298 6.8 0.44 53 224 224 5 0 0 486 62 146 58 145 1.1 140 5a 5.6 81 1.7 80 224 1.8 224 2.8 135 1 0 3 5.8 138 27 116 8.7 123 1.4 2,160 * CV denotes the coefficient of variation and calculated by dividing the standard deviation by the mean. a Four specimens contained quantifiable levels and one a trace. All trace values are assumed to be zero when calculating the mean and CV. b One specimen contained a trace. c One specimen contained a quantifiable level and four contained traces. d Two specimens contained quantifiable levels and one a trace. �TABLE 77. SUMMARY STATISTICS FOR COMPOUNDS QUANTITATED IN SOLID EMISSIONS AT AMES, IOWA Compound Fly ash Concentration Number of (ng/g) detections Mean CV ( ) % Phenanthrene 5a 0 Anthracene 0 Fluoranthrene Pyrene 0 '1 Chrysene Dichloro1 benzene Phenol 3 0 2,4-Dimethylphenol 2 Naphthalene Fluorene 0 0 Acenaphthene 0 Acenaphthylene 0.2 Emission rate (mg/hr) Mean CV ( ) % Bottom ash Concentration Number of (ng/g) CV ( ) % detections Mean 5 2 4 5 lb 3b 193 31 108 106 34 4.8 102 5 4C 1,094 7.0 137 5a 1 1 5 103 3 0.2 87 61 0.2 71 0.1 0.01 224 224 0.1 0.02 224 224 158 102 190 0.07 137 0.08 Emission rate (mg/hr) Mean CV ( ) % 75 12 40 39 12 1.9 96 169 170 162 224 224 55 167 420 2.7 92 176 146 224 224 55 42 1.5 0.11 25 142 224 224 66 100 183 177 168 224 224 * -Pro CV denotes the coefficient of variation and is calculated by dividing the standard deviation by the mean. a Four specimens contained quantifiable levels and one a trace. calculating the mean and CV. b One specimen contained a quantifiable level and two a trace, c Two specimens contained quantifiable levels and two a trace. Trace values are always assumed to be zero when �TABLE 78. SUMMARY OF TOTAL INPUT AND EMISSIONS FROM AMES, IOWA Compound Phenanthrene Anthracene Fluoranthene Pyrene Chrysene Benzo[a]pyrene IndenoTl,2,3-c,d]pyrene Benzo[g,h,i]perylene Dichlorobenzene 1,2, 4-Trichlorobenzene Hexachlorobutadiene Tetrachlorobenzene Penta chl o ropheno 1 Pentachlorobiphenyl Phenol 2 , 4-Dimethylphenol Naphthalene Fluorene Benz [ a ] anthracene Benzofluoranthrene Benzo[ejpyrene Acenaphthene Acenaphthylene Trichlorobenzene Total input rate (mg/hr) CV ( ) % Mean 169,000 31,000 29,700 35,800 10,020 0.066 0.001 0.003 2,650 0.0009 0.0005 nd 1,250 tr 217,800 nd 53,200 64,400 .063 8,960 nd 17,900 5,220 nd 42 53 54 55 69 182 224 224 79 145 224 133 68 89 38 44 71 32 37 Total emission rate (mg/hr) cv (%) Mean 141 32 60 89 12.2 2.0 nd 1.8 2.4 12 nd nd nd nd 2,390 339 188 1.5 nd 1.7 1.8 0.11 25 8.7 nd denotes not detected, tr denotes trace. * CV denotes coefficient of variation and is calculated by dividing the standard deviation by the mean. 143 62 66 115 79 219 143 153 178 140 31 63 55 224 80 224 224 66 123 �TABLE 79. SUMMARY STATISTICS FOR COMPOUNDS QUANTITATED IN GASEOUS EMISSIONS FROM CHICAGO Compound Number of detections Phenanthrene Fluoranthene Pyrene 1,3-Dichlorobenzene 1 ,4-Dichlorobenzene 1,2-Dichlorobenzene 1,2,3-Trichlorobenzene 1,2,4-Trichlorobenzene 1,3,5-Trichlorobenzene Tetrachlorobenzene Hexachlorobenzene Dichlorophenol Trichlorophenol Tetrachlorophenol Pentachlorophenol Dibenzofuran * Flue gas inlet Emission rate Concentration (mg/hr) (ng/g) Mean CV ( ) % CV ( ) % Mean Number of detections 3 3 3 3 60 52 166 93 87 98 75 70 5.4 4.6 14 8.4 90 98 76 71 3 3 3 0 3 69 69 5.9 69 Flue gas outlet Emission rate Concentration (»g/hr) (ng/g) Mean CV ( ) % Mean CV ( ) % 217 39 87 53 31 10 18 3.3 7.5 52 33 10 0 3 93 69 8.0 69 0 3 83 68 7.1 69 3 85 66 6.9 64 3 363 54 30 55 3 327 62 28 62 3 297 63 26 66 3 277 57 24 60 3 957 49 82 49 3 940 43 81 43 3 50 90 4.5 92 3 139 78 12 80 3 3 330 1,220 61 64 25 105 51 64 3 3 383 1,500 56 24 33 126 54 25 3 1,300 63 111 64 3 1,430 21 122 19 2 65 101 5.5 101 3 260 57 22 55 3 46 77 3.9 76 3 102 36 8.5 31 CV denotes the coefficient of variation and is calculated by dividing the standard deviation by the mean. �TABLE 80. SUMMARY OF FLUE GAS EMISSIONS OF POLYCHLORINATED BIPHENYL ISOMERS FROM AMES, IOWA Emission rate (mg/hr) CV ( ) % Mean Compound Concentration (ng/dscm) cv (%) Mean Dichlorobiphenyl nd Trichlorobiphenyl 1.5 185 0.48 189 Tetrachlorobiphenyl 2.9 63 0.94 64 Penta chlo rob ipheny 1 9.0 87 2.8 80 Hexachlorobiphenyl 5.1 104 1.7 104 Heptachlorobiphenyl 0.6 224 0.2 224 Decachlorobiphenyl 0.6 224 0.2 224 19.4 46 6.1 47 Total Chlorobiphenyl CV denotes the coefficient of variation and is calculated by dividing the standard deviation by the mean. 145 �TABLE 81. SUMMARY OF FLUE GAS EMISSIONS OF POLYCHLORINATED BIPHENYLS, DIBENZO-£-DIOXINS, AND DIBENZOFURANS FROM CHICAGO NW Concentration (ng/dscm) cv (%) Mean Compound Emission rate (mg/hr) cv (%) Mean Dichlorobiphenyl 17.3 114 4.4 113 Trichlorobiphenyl 16.0 109 4.1 108 Tetrachlorobiphenyl 6.2 96 1.6 95 Pentachlorobiphenyl 2.6 68 1.6 67 Total chlorobiphenyl 42.1 105 10.7 104 Total trichlorodibenzo-j>-dioxins 13 16 1.1 19 300 15 Total trichlorodibenzofurans Total tetrachlorodibenzo-p_-dioxins 6.3 27 11 14 0.53 15 Total tetrachlorodibenzofurans 90 7 7.6 5 Total hexachlorodibenzo-£-dioxins 16 25 1.4 25 Total hexachlorodibenzofurans 62 33 5.3 32 Total heptachlorodibenzo-£-dioxins 7.6 4 0.65 4 Total heptachlorodibenzofurans 7.5 6 0.64 5 Octachlorodibenzo-£-dioxin 2.5 12 0.22 12 Octachlorodibenzofuran 0.60 22 0.05 21 * CV denotes the coefficient of variation and is calculated by dividing the standard deviation by the mean. 146 �REFERENCES 1. Lucas, R. M., D. K. Melroy, "A Survey Design for Refuse and Coal Combustion Process," from Research Triangle Park to EPA/EED/OTS/Washington, DC, EPA Contract No. 68-01-5848, June 1981. 2. TRW Environmental Engineering Division, RTW, Inc., "Pilot Test Program, Ames Municipal Power Plant, Unit No. 7," from TRW, Inc., to EPA/IERL/ ORD, Research Triangle Park, NC, under EPA Contract No. 68-02-2197, April 1980. 3. Bakshi, P. S., T. L. Sarro, D. R. Moore, W. F. Wright, W. P. Kendrick, and B. L. Riley, "Pilot Test Program, Chicago Northwest Incinerator, Boiler No. 2," from TRW Environmental Engineering Division to EPA/ IERL/ORD, Research Triangle Park, NC, under EPA Contract No. 68-022197, June 1980. 4. Federal Register. 41(111), 23060-23090, 1976. 5. Stanley, J. S., C. L. Haile, A. M. Small, and E. P. Olson, "Sampling and Analysis Procedures for Assessing Organic Emissions from Stationary Combustion Sources in Exposure Evaluation Division Studies," from Midwest Research Institute to EPA/OPTS/Washington, DC, under Contract No. 68-01-5915, Report No. EAP-560/5-82-014, August 1981. 6. Lustenhouwer, J. W. A., K. Olie, and 0. Hutzinger, "Chlorinated Dibenzo£-dioxins and Related Compounds in Incinerator Effluents: A Review of Measurements and Mechanisms of Formation," Chemosphere, 9, 501, 1980. 7. Richard, J. J., and G. A. Junk, "Polychlorinated Biphenyls and Effluents from Combustion of Coal/Refuse," Environmental Science and Technology, 15, 1095, 1981. 8. Memorandum from R. Harless, Analytical Chemistry Branch, ETD, IERL/RTP to Dr. A. Dupuy, EPA/Toxicant Analysis Center, "Collaborative Analysis for Chlorinated Dibenzo-p_-dioxins and Dibenzofurans in Combustion Source Extracts," August 10, 1981. 9. Snedecor, G. W., and W. G. Cochran, Statistical Methods, The Iowa State University Press, Ames, Iowa, 1980, 507 pp. 147 �APPENDIX A TRW FIELD TEST REPORT FOR THE AMES MUNICIPAL ELECTRIC SYSTEM. UNIT NO. 7 148 �PILOT TEST PROGRAM AMES MUNICIPAL POWER PLANT UNIT NO. 7 TRW ENVIRONMENTAL ENGINEERING DIVISION TRW, INC. 28 April 1980 EPA Contract .68-02-2197 EPA Project Officer: Michael C. Osborne Industrial Environmental Research Laboratory Office of Research and Development U.S. Environmental Protection Agency Research Triangle Park, N.C. 27711 149 �CONTENTS Figures Tables iv 1. Introduction 2. Summary 2.1 Sampling and Analysis 2.2 Process Data 2.3 Continuous Monitoring Data 1-1 2-1 2-1 2-1 2-23 3. System Description 3.1 Boiler Description ..... 3.2 Electrostatic Precipitator 3-1 3-1 3-12 i 4. Sampling Locations. . 4-1 5. Sampling 5.1 Gas Sampling . 5.2 Solid Sampling 5.3 Liquid Sampling -. . 5.4 Hi Volume Sampler 5.5 Quality Assurance 5.6 Sampling Train Background 5.7 Sample Recovery 5.8 Problems Encountered During Recovery 5-1 5-1 5-5 5-5 5-6 5-6 5-6 5-8 5-8 6. Calibration 6.1 Method Five Calibration Data 6.2 Instrument Calibration 6-1 6-1 6-3 7. Technical Problems and Recommendations 7.1 Problems 7.2 Recommendations 7-1 7-1 7-1 Appendices A. B. C. D. Continuous Monitoring Data Field Data Sheets Solid and Liquid Sampling Schedule. Process Data Sheets It 150 , •. A-l B-l C-l D-l �FIGURES Number 2-1 3-1 3-2 3-3 3-4 4-1 4-2 4-3 4-4 5-1 5-2 5-3 5-4 6-1 Page Oxygen in the gas before and after the air preheater. . . . 2-31 Layout of plant site 3-2 Flow diagram for unit #7 at Ames Municipal power(piant. . . 3-4 Schematic of Ames Municipal power plant boiler 17 3-7 Solid waste recovery system 3-11 Unit #7 flow diagram and measurement locations 4-2 Cross section of stack showing traverse point locations . . 4-3 Inlet duct - showing port locations 4-4 Inlet traverse point locations 4-5 ESP inlet sampling train 5-2 Stack sampling train 5-3 EPA Method 5 particulate sampling train 5-4 Ambient air sampler , 5-7 Calibration equipment set-up procedures 6-4 iii 151 �TABLES Number 2-1 2-2 2-3 2-7 2-8 2-9 3-1 Daily Organic Sampling Summary Daily Data Summaries 24 Hour Process Data for the Ames Municipal Power Plant, Unit No. 7 Test Duration Process Data for the Ames Municipal Power Plant, Unit No. 7 Daily Production and Consumption at Ames Municipal Power Plant, Unit No. 7 Heat Content of Fuels Used at the Ames Municipal Power Plant During Sampling Period Continuous Monitoring Data Excess Air Readings Air Preheater Continuous Monitoring Data Boiler Design Data 3-2 Design Specification for Raymond Bowl Pulverizers 3-3 3-4 Fan Design Performance 3-8 Predicted Performance Characteristics of Unit #7 at Ames Municipal Power Plant 3-9 Performance Characteristics of the American Standard ESP. . 3-13 Sampling Locations 4-1 2-4 2-5 2-6 3-5 4-1 1v 152 2-2 2-12 2-14 2-17 2-24 2-25 2-27 2-29 2-30 3-3 3-5 �1. INTRODUCTION This document describes the sampling and monitoring activities at the Ames Municipal Power Plant, boiler unit No. 7. The sampling and field measurement work performed was part of an overall pilot scale test program sponsored by the Office of Pesticides and Toxic Substances in cooperation with the Office of Research and Development, of the U.S. Environmental Protection Agency. The ultimate objective of the pilot scale test program is to develop an optimum sampling and analysis protocol to characterize polychlorinated organic compounds which may be emitted in trace quantities through conventional combustion of fossil fuels and refuse. The genesis of the program is an industrial study by Dow Chemical Company and two groups of European investigators reporting emissions of polychlorinated dibenzo-p-dioxins (PCDD), dibenzofurans (PCDF) and biphenyls (PCB) from stationary conventional combustion sources. The immediate objective of the sampling and field measurements program (for a fossil-fuel 17% RDF-fired utility boiler) is the specification of procedures and equipment to obtain sufficient multimedia samples for the subsequent analytical protocol, and to satisfy the program statistical design requirements. In this respect, the TRW Environmental Engineering Division of TRW, Inc., was one of three contractors participating in the overall EPA program. These contractors, their key individuals and respective roles are: 1. Research Triangle Institute Research Triangle Park, North Carolina Statistical design of the overall test program Mr. R. M. Lucas, Task Manager 2. TRW Environmental Engineering Division, TRW, Inc. Redondo Beach, California Acquisition of samples and field measurements Mr. B. J. Matthews, Project Manager 3. Midwest Research Institute Kansas City, Missouri Laboratory analysis of all field samples Dr. C. L. Haile, Task Manager 1-1 153 �The sampling was oriented toward acquiring multimedia samples for organic compound analysis by Midwest Research Institute (MRI). Compounds of particular interest included: i Benzo [a] pyrene Chrysene Pyrene Indeno [1,2,3-cd] pyrene Fluoranthene Benzo [g_5h.»l] perylene Phenanthene Anthracene In addition, MRI is to make a determination of total organic chlorine emissions from the acquired samples. Potentially, selected samples are to be analyzed for dibenzo-p-dioxins, dibenzofurans and biphenyls. Instrumentation for on-line combustion gas stream monitoring was part of the test program. In addition, utility boiler process information (including RDF data) was also gathered. This information together with the monitoring data were acquired to assist in evaluating and interpreting chemical analysis results. This report contains all the field data for the Ames Municipal Power Plant pilot test program conducted in March 1980. Data provided include the following: • Chlorinated hydrocarbon collection using a modified EPA Method 5 train and Method 5 sampling methodology, • Gas velocities using EPA Method 2, • Continuous monitoring for CO^, CL, and CO and THC, • Particulate collection for inorganic analysis utilizing EPA Method 5. • Process data. The test program followed was described in the Pilot Test Program, Ames Municipal Power Plant, Unit No. 7 site test plan. Deviations from this program are documented and explained in their respective sections of this report. 1-2 154 �2. SUMMARY 2.1 Sampling and Analysis The field test activity took place from February 25, 1980 to March 28, 1980. All required tests were completed and all recovered samples were sent to Southwest Research Institute (SRI)'for analysis. MRI had subcontracted this part of their assignment to SRI. A summary of tests conducted including any significant commentary is presented in Table 2-1. A summary of the reduced data on a daily basis as calculated from the field data sheets is presented in Table 2-2. Data listed are corrected to standard conditions, i.e., 20°C and a barometric pressure of 29.92 inches mercury. Sampling and calibration procedures are described in Sections 4, 5 and 6. Hourly data is provided in the appendices. Appendix A contains continuous monitoring data; Appendix B contains field data; and Appendix C contains the solid and liquid sampling schedule. 2.2 Process Data Process data was monitored on an hourly basis. A summary of the averaged daily process data is provided in Table 2-3. The process data was also averaged for the time duration of actual testing performed. This data is presented in Table 2-4. The process data gathered indicated that the operating conditions fluctuated in patterns related to the amount of electricity generation demand placed on the boiler, and on the type of fuel being burned to meet that demandT~ Overall fluctuation consisted of two components. The first component was the Daily variation - the load peaked in the afternoon and fell a minimum before dawn. The second type of variation was caused by sudden operational changes, which was due to reduced power generation for various reasons such as the buying of cheaper power from a private utility, or the reduction in flow of RDF to the boiler. 2-1 155 �TABLE 2-1. DAILY ORGANIC SAMPLING SUMMARY Date Test 1980 No. Sampling locations 3/2 Inlet North Test started at 1120 and ran for 520 minutes. Low volume collected due to high leak rate at end. Volumes corrected for leak rate. If leak occurred over the entire test period then, at worst case, the results are 50% low. Test quality fair. (Port 13 to be dropped due to absence of flow). Inlet South Test started at 1125 and ran for 520 minutes. Low volume collected trying to stay within 12 hour time limit. Test quality good. (Port 1 to be dropped due to absence of flow.) Outlet Ports 2 and 3 Loss of 3 hours start due to freezing of pumps. Stopped test 360 minutes into test due to freezing of impingers. All of Port 3 traversed and only 1/2 of Port 2 - low volume collected but test quality is good due tp the evenness of flow in stack. Outlet - Ports 1 and 4 Started at 1200, ran for 390 minutes - stopped due to freezing of impingers and equipment - low volume due to stoppage - impingers backed up due to freezing of impinging solutions. Resin in Impingers 1 and 2 also due to freezing. Test quality fair. Hi Volume Sampler Test started at 1115 and off 1939. Continuous monitors Started at 1300 hrs and off at 1930 - lost start time due to gas conditioner being frozen. Unable to maintain heat line temperature due to cold weather and moisture condensing in heat line possibly scrubbing hydrocarbons, hydrocarbon results low. Test quality good. Hydrocarbon fair. Inlet North Dropped port 13 from test. Test started at 0925 and ran for 550 minutes. At 250 minutes nozzle was found to be facing in the wrong direction, reversed nozzle direction continued test. Particulate catch and size distribution will be approximately 25% low. No effect on Battelle trap. Switched to smaller diameter nozzle to maintain vsokinetic flow rate. Test quality for participate fair, for gas good. Inlet SOIR.. Test started at 0945 and ran for 550 minutes. Switched to smaller diameter nozzle to maintain isokinetic flow rate. Test quality good. Dropped port 1 from test. 1 Ul I\J 3/3 Test comments Test quality good. �TABLE 2^1. (Continued) Date Test 1980 No. Sampling Locations 3/3 Outlet Ports 2 and 3 Test started at 0945 and ran for 480 minutes. Test quality good. Outlet Ports 1 and 4 Test started at 0945 and ran for 480 minutes. Test quality good. Hi Volume Sampler Started at 1032 ended at 1915. Test quality good. Test comnents Continuous Monitors Started at 0930 ended at 1900. Test quality good except hydroCarbon values being low and hydrocarbon quality fair. Test started at 0905 and ran 417 minutes. At 75 minutes Battelle trap plugged and replaced with new one. At 250 minutes Battelle trap replaced due to leak and points (total of 2) retested. Switched to 10 minutes a point traverse rather than 25 minutes to complete test. All 3 Battelle traps should be composited due to lower volume sampled during 10 minute/ point traverse. Test quality fair - total volume 50% of required. Test started 0900 ran for 550 minutes. Test quality good. Outlet Ports 2 and 3 Ports 1 and 4 Test started 0938 ran for 15 minutes. Cancelled due to snow and icy conditions. No samples retained. Hi Volume Sampler ro i co Inlet North Inlet South 3/4 Started at 0930 ended at 1800. Filter covered with snow. Test quality fair due to snow blanket. \ Continuous Monitors Gas conditioner frozen until 1230. Started at 1230 ended at 1800. Test quality good. Hydrocarbon results fair. 3/5 Inlet North Test started 0900 and ran for 560 minutes. Test quality good. Inlet South Test started at 0900 and ran for 550 minutes. Test quality good. �TABLE 2-1. (Continued) Date Test 1980 No. Sampling Locations 3/5 Outlet - All Points Cancelled per instructions of EPA until 3/13/80. Hi Volume Sampler Test Comments Started at 1025 ended at 1940. Test quality good. Continuous Monitors Started at 0945 ended at 1150 am. Stopped due to freeze up of lines:Test quality good for data collected. Inlet North Test started at 0850 and ran for 770 minutes. At 11 minutes Into test Battelle trap plugged and was replaced. Test restarted from beginning. Test quality good. Inlet South Test started at 0840 and ran for 770 minutes. Test quality good. Hi Volume Sampler 3/6 Test started at 0852 and ended at 2220 Hrs, Test quality good,. Continuous Monitors Only inlet tested due to outlet freeze up. Test started at 1230 and ended 2045. Two hours late start and shut down 2 hours early to overlap sampling time. Test quality good. Hydrocarbons still fair. V3 3/7 Inlet North Test started at 0930 and ran for 770 minutes. Due to increased amount of water collected, impingers needed changing and during changeout resin flowed into first impinger. Trap replaced and test resumed. Test quality good. Inlet South Test started at 0850 and ran for 770 minutes. Test quality good. Hi Volume Sampler Test started at 1038 and ended at 2225. Construction welding going on nearby. Test quality expected to be good. Continuous Monitors Test started at 1315 hrs and shut down at 2100 hours. Overlap of Inlet test. Test quality good. Hydrocarbons fair. �TABLE 2-1. (Continued) Date Test 1980 No. Sampling Locations 3/8 Inlet North Test started at 0855 and ran for 770 minutes. 10 minute power failure no problems caused by this. Test quality good. Inlet South Test started 0840 and ran for 770 minutes. 30 minute power failure on this side - no problems. Probe broken at end of test during removal from port. Approximately 2% of probe catch lost. Test quality good. HI Volume Sampler Test started at 1335 and ended at 2330. Test quality good. Test Comments Continuous Monitors Test started at 1215 and ended 2030 hrs. Data not taken at inlet during 1300 hrs. to 1400 hours due to change out of probe filters. Test quality good. Hydrocarbon data fair. Test started at 0900 and ran for 770 minutes. Point 8D was run for 70 minutes to correct sampling time lost on point 11A not being sampled after nozzle change. Test quality good. Test started at 0830 and ran for 770 minutes. Changed to larger nozzle to maintain 1sok1net1c flow rate. Due to severe leak, that occurred during last portion of test, this test 1s questionable. HI Volume Sampler 8 Inlet North Inlet South 3/9 Test started at 0908 and ended at 2320 hrs. Test quality good. IM cn Test started at 1245 and ended at 2320 hrs. Test quality good. Hydrocarbon data fair. 3/10 Inlet North Test started at 0825 and ran for 140 minutes. Probe found to be broken and test restarted, no samples retained. Restarted at 1155 ran until 1745. Test stopped, with only 1/2 the duct traversed, due to cold, freeze ups and power failures. Resin, cyclone, filter, 1st impinger saved. Test quality fair. Inlet South Test started at 0810 ran for 515 minutes. Power failures and freeze ups happening cancelled test with the North side. No solutions retained from South due to H20z backup Into all impingers - resin, cyclone and filters retained. Test quality fair. �TABLE 2^1, (Continued) Date Test 1980 No. Sampling Locations 3/10 Hi Volume Sampler Test Comments Test started at 1050 and ended at 2235 hrs. Test quality good. Continuous Monitors Test started at 1130 am and ended at 1730 hours. Stopped with inlet. Test quality good. Hydrocarbon fair. Test started at 0825 and ran 770 minutes. Battelle trap replaced at 220 minutes. 2nd Battelle trap resin broke through and was replaced. 3 Battelle traps used. Test quality good. Test started at 0830 and ran for 770 minutes. Filter clogged and replaced. Test quality good. Hi Volume Sampler 10 Inlet North Inlet South 3/11 Test started at 0920 and ended at 2375 hrs. Test quality good. Continuous Monitors Test started at 1200 and ended at 2030 hrs. Test quality good. Hydrocarbon fair. o\ ro o i o> 11 QA Test Test cancelled after 240 minutes - a leak was found at one of the probe tips-unable to repair and no sample had been drawn through the train. Hi Volume Sampler 3/12 Test started at 0955 stopped at 1955. Test quality good. Continuous Monitors Test started at 0830 stopped at 1430 hrs. Test quality good. Hydrocarbon fair. 3/13 12 Inlet North Test started at 0915 and ran for 770 minutes. Power failures occurredno effect on test. Filter changed due to clogging. Test quality good. Inlet South Test started at 0835 and ran for 770 minutes. Power failure occurred no effect on test. Test quality good. Outlet Ports 2 & 3 Test started at 1210 and ran for 560 minutes. Lost startup due to freezing of equipment and traps - thawing took 1-2 hours. Test quality good. �TABLE 2-1. (Continued) Date Test 1980 No. Sampling Locations 3/13 Outlet Ports 1 & 4 Test started at 1125 and ran for 296 minutes. Stopped due to continual freezing of train components. One port completely traversed. Only 16 minutes of the second. Test quality - fair to poor. H1 Volume Sampler Test started at 0950 and ended 0130. Test quality good. 12 Test Comments Continuous Monitors Test started at 1145 and ended at 1845 hours. Test quality good. Hydrocarbons fair. 3/14 13 Inlet North Test started 0845 and ran for 770 minutes. Filter clogged and was replaced. Test quality good. Inlet South Test started at 0840 and ran for 770 minutes. Test quality good. Outlet Ports 2 & 3 Test started at 0945 and ran for 560 minutes. Test quality good. Outlet Ports 1 & 4 Test started at 1010 and ran for 560 minutes. Probe broken during port change - replaced and test continued. Test quality good. Hi Volume Sampler Test started at 0905 and ended at 2355 hrs. Test quality good. Continuous Monitors Test started at 0900 and ended at 2045 hrs. No data from 1330 to 1515 hrs due to feeeze up. Test quality good. Hydrocarbon fair. 3/15 14 Inlet-North Test started at 0909 and ran for 770 minutes. Test quality good. Inlet South Test started at 0905 and ran for 770 minutes. Test quality good. Outlet Ports 2 & 3 Test started at 0958 and ran for 560 minutes. Test quality good. Outlet Ports 1 & 4 Test started at 1025 and ran for 560 minutes. Test quality good. HI Volume Sampler Test started at 0850 and ended at 2341 hrs. Test quality good. Continuous Monitors Test started at 0845 and ended at 2000 hrs. Test quality good. Hydrocarbon data fair. �TABLE 2-1. (Continued) Date Test 1980 No. Sampling Locations 3/17 Inlet North Test started at 0849 and ran for 770 minutes. Test quality good. Inlet South Test started at 0900 and ran for 770 minutes. Test quality good. Outlet Ports 2 & 3 Test started at 1000 and ran for 560 minutes. Test quality good. Outlet Ports 1 & 4 Test started at 1010 and ran for 560 minutes. Test quality good. HI Volume Sampler Test started at 0926 and ended at 0020 hrs. Test quality good. 15 Test Comments Continuous Monitors Test started at 1030 and ended 2015 hrs. Test quality good. Hydrocarbon data fair. Test started at 0900 and ran for 770 minutes. Test quality good. Test started at 0930 and ran for 560 minutes. Test quality good. Outlet Ports 1 & 4 Test started at 0940 and ran for 560 minutes. Probe broke during port change - switched to 5 ft glass probe to traverse first 6 points of second part. After 10 ft probe of ports 2 and 3 had been recovered and cleaned, it was sent to the stack to finish remaining 2 points of ports 1 and 4. Test quality good. HI Volume Sampler ro oo Test started at 0939 and ran for 770 minutes. Test quality good. Outlet Ports 2 & 3 16 Inlet North Inlet South 3/18 Test started at 1033 and ended 0200 hours. Test quality good. Continuous Monitors Test started at 0845 and ended at 1945 hrs. Test quality good. Hydrocarbon data fair. 3/19 17 Inlet North Test started at 0859 and ran for 770 minutes. Test quality good. Inlet South Test started at 0843 and ran for 770 minutes. Test quality good. Outlet Ports 2 & 3 Test started at 0945 and ran for 560 minutes. Test quality good. �TABLE 2-1. Date Test 1980 No. Sampling Locations 3/19 Outlet Ports 1 & 4 17 H1 Volume Sampler (Continued) Test Conments Test started at 0940 and ran for 560 minutes. Test started with 5 foot probe until new 10 ft arrived. Finished Test with 10 ft probe. Test quality good. Test started at 1006 and ended at 0120 hrs. Test quality good. Continuous Monitors Test started at 0845 and ended at 1915. Test quality good. Hydrocarbon data fair. Test started at 0905 and ran for 770 minutes. Filter clogged and was replaced. Test quality good. Test started at 0914 and ran for 770 minutes. At 1850 hrs. Battelle trap froze and was thawed with warm water. Leak developed in Teflon heat line • retarded leak rate with Teflon tape but leak was still 0.11 cfm. At 2250 Battelle trap froze up and was replaced. It was later found that the filter had separated from the housing and participate had gotten down to the Battelle first. Both filter and trap were replaced and points were retraversed. Test quality good.to fair. Outlet Ports 2 & 3 Test started at 1000 and ran for 560 minutes. Test quality good. Outlet Ports 1 & 4 Test started at 0930 and ran for 560 minutes. Test quality good. HI Volume Sampler 18 Inlet-North Inlet South 3/20 Test started at 1117 and ended at 0540 hrs. Test quality good. ro i <o Continuous Monitors Test started at 1130 and ended at 2030 hrs. Test quality good. Hydrocarbon data fair. 3/22 19 Inlet North Test started at 0947 and ran for 770 minutes. Test quality is good. Inlet South Test started at 1001 and ran for 770 minutes. replaced. Test quality is good. Outlet Ports 2 & 3 Test started at 1000 and ran for 560 minutes. Test quality is good. Filter clogged and was �TABLE 2-1. Date Test 1980 No. (Continued) Test Comments Sampling Locations 19 Outlet Ports 1 & 4 Test started at 1030 and ran for 560 minutes. Test quality is good. Hi Volume Sampler 3/22 Test started at 1422 and ended at 0415 hrs. Test quality is good. Continuous Monitors Test started at 1145 and ended 2115 hrs. CO drift problems. CO taken off line until 1445 hrs. Test quality good. Hydrocarbon data fair. Test started at 0927 and ran for 990 minutes, lower plant out put. Increased time due to Test started at 0935 and ran for 990 minutes lower plant output. Test quality good. Increased time due to Outlet Ports 2 & 3 Test started at 1005 and ran for 640 minutes, Increased time due to lower plant output. Test quality good. Outlet Ports 1 & 4 Test started at 1027 and ran for 640 minutes. Increased time due to lower plant output. Impinger 3 backed up into impinger 2 - not saved. Test quality good. Hi Volume Sampler Test started at 1034 and ended at 0350. Test quality good. Continuous Monitor 20 Inlet North Inlet South 3/23 Test started at 1100 and ended at 0800 hrs. Electronic source balancing problem on CO analyzer. Analyzer (CO) taken off line. No outlet data gas conditioner not in cycle mode. Test quality good for inlet, hydrocarbon data fair. . _. Blank Blank test started at 1200 and ran for 60 minutes at temperature. quality good. Outlet Test started at 1110 and ran for 192 minutes. Test quality good. Hi Volume Sampler Off line Continuous Monitors Test started at 1030 and ended at 1530 hrs. Outlet only for inorganic sampling. No CO on line. Test quality good hydrocarbon data fair. ro 3/24 21 - QA Test to outlet stream. Test quality good. Test �TABLE 2-1. (Continued) Date Test 1980 No. Sampling Locations 3/25 Inlet North and South - QA Test Test started. No solids or liquids taken for QA. QA test only. Test scrubbed, no samples saved because nozzle was in wrong direction and test would not be duplicate. Outlet Ports 1,2, 3 and 4 Test started at 1120 and ran for 192 minutes. Test quality good. 22 Test Comments Continuous Monitors Test started at 1115 and ended at 2106 hrs. Test quality good. Hydrocarbon data fair. Hi Volume Sampler 3/26 23 Test started at 1030 and ended at 2320 hrs. Filter covered with coal dust. Test quality fair. Inlet North QA test started at 1510 and ran for 770 minutes. Test quality good. Inlet South QA test started at 1515 and ran for 770 minutes. Test quality good. Outlet Ports 1,2, 3 and 4 Test started at 0922 and ran for 192 minutes. Test quality good. Continuous Monitors Test started at 1100 and ended at 0830 hrs. No outlet data due to failure of gas conditioner to switch to outlet stream. Test quality good. Hydrocarbon data fair. �TABLE 2-2. DAILY DATA SUMMARIES Gas Composition Sample Volume Data (1930) 3-2 Test No. 1 Sampling Location ""« ES ouu. £ 3-3 2 North* ""«' Out,e, 3-4 3 £$ SouthD «g '- ££ Ou,.e, 3-6 4 5 Inlet North South 0,,,,e, CT> ro i ro 3-7 6 Ou,,e, 3-8 7 s^ln Oullet 3-9 ">"« South' £$ feu.. 3-10 9 10 11 9.95 7.15 6.32 624 29.01 2935 29.30 29.31 33.55 28.09 2? 59 2479 132673.22 116016.35 141428.G2 154523.14 7654988 70423.17 86285.62 95704.38 334.31 311.78 320.93 30992 4.4S 4.48 6.34 6.34 12.79 12.79 11.31 11.31 1800 13.00 1500 1500 -^2 <2 <2 <2 6383 8901 8620 9399 173.544 126.934 212.049 101.519 324.358 307.313 4.92 3.60 6.01 288 9.19 870 839 8.59 781 7.97 7.45 7.48 29.34 29.32 2941 29.39 2931 29.31 37.78 4?.94 46.61 37.16 26.00 26.10 149381.62 169792.93 184280.23 146887.30 162012.17 162637.08 85761.77 95782.34 108410.17 86004.68 94569.98 90037.93 351.55 37336 234.83 369.90 3-12.38 33694 4.38 4.33 4.33 433 5.87 5.87 13.80 13.80 1380 13.80 12.44 12.44 12.00 12.00 11.00 11.00 11.00 <2 <2 <2 <2 <2 <2 9573 6098 107 14 9633 9033 184.208 252.780 5.22 7.16 7.43 9.48 2956 29.30 4S.10 43.72 173312.05 9C6B4.71 172866.82 96380.09 Test Scru 3bod Test Scrut>bed 370.46 352.55 4.43 4.43 14.41 14.41 17.00 17.00 <2 <2 95.59 92.25 256.375 246.727 7.28 6.99 8.14 9.03 29.49 29.38 43.20 41.09 97049.64 17080285 162455.25 92751.96 Test Scrul )bed Test Scrutibed 361.09 349.23 4.41 441 14.56 14.5G 18.00 18.00 <2 <? 9143 104.10 367.648 323.174 10.41 9.15 893 9.72 29.28 29.18 42.92 43.48 169692 43 102970.06 9729597 171937.31 Mot Test cd Not Test ed 363.83 347.46 4.35 4.35 13.79 13.79 1800 1800 <2 <2 9728 90.54 363.684 365.424 1044 10.35 18.32 9.18 28.14 29.27 43.61 44.01 17242559 8743205 173994.36 99965.91 Not Tesi ed Not lest >xl 351.00 335.86 4.59 4.59 13.92 13.92 16.00 16.00 <2 <2 10593 99.65 351.419 333.613 995 9.45 956 9.75 29.19 29.16 3962 3928 85266.27 156073.06 155327.60 86179.64 Not Tested Not Test cd 377.55 359.83 4.79 4.79 1360 1360 2800 28.00 <2 <2 1C3M 105.53 74.033 234.807 121.924 140223 2.10 8.35 3.45 397 7.79 8.05 778 8.02 29.19 29.16 29.20 2917 3027 30.38 36.43 27.38 119C9800 7132576 120108.29 67223.13 144173.75 82977.48 108274.04 64436.72 Not Tcsi od Not Tested 31683 364.73 344.23 315.88 7.1 7.1 7.1 7.1 11.6 11.6 11.6 11.6 2500 25.00 25.00 25.00 <2 <2 <2 <2 95.60 9851 106.23 B0.56J 130811 193613 3.70 548 859 17.13 2931 28.25 45.23 43.77 17885320 103205.95 17304512 92980.29 Not Tcsi ed Not Test ed 352.C9 33065 3.7 3.7 139 13.9 25.00 2500 <2 <2 8884 £958 39-5091 3fa300C 11.16 1085 6.98 8.40 29.49 29.iO 45.63 44.20 18061964 01867.66 174783.47 99143.40 No! Tesi i:d Not Test ed 37475 356.59 4.7 47 13.5 13.5 22.00 22.00 <2 <2 97 17 10529 •*• 361.78 340.61 339.44 315.08 3.34 3.34 5.17 5.17 1556 15.56 13.97 13.&7 21 00 21.00 1800 1800 <2 <2 <2 <2 102 3S 10?.23 7? 72 91.73 «J N s :;f Out* 3-13 5.80 7.43 606 688 £« '-• ££ Out,e, 3 12 204.617 262.517 214098 243024 «*« """ ££ Ou,,et 3-11 Velocity «ps 2l3 NorthF 8 """ Ouu, S i £«" Gas Flow dscfm Isokinelics X Test Scrubbed Test Scrubbed Not Tested Not 1 esled JM 12 THC ppm Molecular Weight £\ """ CO ppm Moisture % £« ""« s^ii; CO? X M3 >2< ""*< £S $ SCF »3! Outlet 35 Stack Temp °F Ga« Flow acfm 350.455 369 B24 158.9M 3.~,5 290 9.92 10.47 4.50 10.35 8.63 8.54 7.10 937 2953 2954 29.56 29.28 42.45 41.41 2585 2658 163079.96 164036 17 161102.3'J 165622.22 93473.48 93628.05 9514681 98426.04 �TABLE 2-2. (Continued) Gat Composition Sample Volume Dale (19801 Tetl No. 3-14 Sampling Location 13 SCF M3 374.335 352.110 367.772 351.364 10.60 ""« i% ou,,., ST.!: 276.767 268.37 31913 307.00 — 555 ou,,., s^ """ £2 <*«•• 2*3 3-15 3-17 3-18 14 15 16 — ££ o- ffi 3-19 17 Inlet nlet Outlet 3 20 18 3-22 19 to North Eoulh «»» — ££ *- % «- £* OutM 3-23 20 JM ,„, , '"'" North Scum out* £« 3-24 21 Outlal 3-25 22 Intel ""* South 1.2.38.4 — ££i Outlet 3-26 23 ">"• ££ Oiillrl A 8 C 0 E F G H 1 J K L 1.2.3&4 1.2.3&4 Moisture % Molecular Weight Gn Velocity Ipt Gai Flow acini Flow dscfm " 43.48 41.49 24.34 24.84 171904.76 164048.73 151720.16 154819.20 94404.58 91011.47 83869.92 86429.91 Stack Temp 02 « CO? % CO ppm THC ppm Isokineties \ 38468 375.70 365.94 358.75 3.70 14.81 14.81 13.18 13.18 2800 28.00 30.00 30.00 <2 <2 <2 <2 101.27 10720 9980 96.74 68088.12 67307.85 75394.82 76705.48 368.23 357.65 319.42 356.65 6.31 6.31 12.59 12.59 10.G7 10.67 2200 22.00 19.00 19.00 <2 <2 <2 <2 102.11 10867 10405 9683 14.40 14.40 2200 2200 22.00 2200 <2 <2 <2 <2 10685 9909 107.18 95.48 23.00 2300 2400 24.00 <2 <2 <2 <2 10017 10807 9982 93.81 <2 <2 <2 <2 10721 97.16 10103 9262 OF 9.67 9.70 9.60 9.50 2931 7.83 7.60 9.04 8.69 814 7.68 7.88 7.83 29.27 2832 2909 29.10 30.85 2996 20.00 2131 121975.44 118444.95 12466269 132801.77 359800 390.474 406855 391.B36 10.19 11.06 11.52 11.10 8.83 8.17 8.71 8.43 29.35 2944 29.21 29.25 41.89 42.84 26.01 2727 1G'j622.66 169381.86 162117.20 169966.05 91774.43 9721069 93334.49 98183.52 371.23 348.41 354.56 34531 3.73 373 543 543 1200 309.159 3/1 .197 392.686 353.252 10.45 9.36 8.73 8.62 9.09 29.29 29.37 29.24 29.18 ! 43.06 41.89 27.12 2560 170259.70 165639.94 169022.81 159531.72 92573.11 93691.77 96719.62 91103.75 381.96 35496 360.06 357.50 3.82 14.39 382 1439 5.42 5.42 1300 41.87 4342 26.75 26.92 165560.57 171695.37 166699.92 167752.85 88914.41 95341.29 9108057 94194.67 36028 361.53 373.12 365.94 9.97 10.42 9.95 1052 11.12 1000 29.30 29.14 29. IS 12.90 13.00 14.40 1440 530 5.30 13.00 13.00 24.00 7400 26.00 2600 350.96 342.65 338.12 312.81 3.80 3.80 6.00 6.00 13.80 13.80 12.50 12.50 22.00 22.00 17.00 17.00 <2 <2 <2 <2 92.21 10431 9509 97.71 94207.94 90821.39 95997 17 9954908 348.64 34209 340.00 33060 360 300 14.70 14.20 12.70 12.70 38.00 38.00 3800 38.00 <2 <2 <2 <2 105.17 85.42 104 10 9903 C3470.17 58005.38 58763 10 74046.56 364.41 355.41 354.13 338.13 6.00 6.00 9.70 9.70 1260 L 12.60 10.00 10.00 <2 <2 <2 <2 10354 11599 11045 10266 365.47 5.4 132 <2 10372 13.2 <2 101.06 <2 <2 <2 10524 11843 106.64 968 10.60 10.21 10.28 8.59 29.29 29.37 29.03 29.24 347.892 368079 356.204 388.522 985 10.42 10.09 11.00 8.31 7.86 7.79 8.44 29.33 2939 29.29 29.21 42.13 42.11 74.63 2G.91 1665/0.31 166487.56 153481.74 18772585 94786.10 96189.05 90622.79 97760.61 363.462 348597 402.144 401.160 10.29 29.36 4165 2941 11.39 11.36 B.54 8.07 8.61 8.23 29.19 29.24 33.63 26.26 26.81 164688.40 156677.09 163656.04 167077.26 33G.525 330.733 301.612 368.976 9.53 9.37 8.54 12.74 973 10.17 5.87 2926 28.69 28.82 2928 28.65 27.28 16.63 19.70 113282.76 107773.49 103679 07 122765.69 8.16 837 837 360 9.90 1044 9.B7 5.31 5.31 3.60 349.709 368.751 374.299 360578 8.68 370 5.30 5.30 130.420 3.69 9.53 29.15 25.76 Blank H un Blank R llll 160547.70 90172.96 122.788 3.48 9.92 2910 24.58 153166.31 8/02b.45 356.40 5.4 326 820 344.976 138673 926 977 9.17 9.09 37.23 37.40 ?6.42 1472C0.78 147872.05 16467985 81800.81 8073346 93244.39 380.80 382.45 364.38 6.00 1260 926 29.13 29.14 20,24 600 3.03 12.60 13.70 Test Scru •bed With.312no»le With .250 nozzle changed to maintain flow With.312nozzle With .237 nozzle changed In maintain (low No sampl3 ietaim.il XViih .no nozzle Wuh .310 nozzle changed 10 maintain How With .240 nozzle With .309 nozzle changed to maintain flow Hesulls questionable dlM> lo l"dteak'ate Teu. .miti'ied due to cold weather. Sample laved Monitor not woiking 4.80 �TABLE 2-3. 24 HOUR PROCESS DATA FOR THE AMES MUNICIPAL POWER PLANT, UNIT NO. 7 3-2-80 Date Mean 3-3-80 Mean a Mean a Mean o Mean o Mean 5.19 4.93 31.9 29.72 4.76 4.44 31.7 28.88 5.55 5.30 30.5 28.24 7.51 7.21 27.85 25.66 6.01 5.79 252.2 36.49 268.8 284.87 56.59 289.58 48.47 279.79 56.73 274.8 74.9 Steam pressure (psig) 857.7 4.16 852.71 4.66 850.63 5.95 848.54 5.61 847.33 7.22 Steam temperature (°F) 899.63 8.53 890.1 891.46 14.63 895.6 10.97 895.33 9.89 Feedwater flow rate (1000's Ibs/hr) 261.17 37.94 278.38 71.65 290.79 52.98 300.42 46.6 291.7 54.23 Feedwater temperature (OF) 366* 7.38* 380.81 2.14 389.7 7.63 382.8 17.36 377.5 Fuel feed rate 1 (1000's Ibs/hr) 2 31.7 32.2 7.07 31.93 31.69 31.03 31.81 5.37 32.45 33.53 6.09 35.38 32.15 Fuel oil (gallons/hr) 4.6 OO Excess air X 22 3-9-80 o 31.58 29.25 Steam flow rate (1000's Ibs/hr) ro a 3-8-80 30.1 7.31 32.04* 0.98* Gross Met Mean 3-7-80 3-6-60 30.19* 2.8* 26.25* 1.51* MU o 3-5-80 3-4-80 71.48 24.01 7.32 2.1 22.08 8.28 20.33 2.35 20.17 3.92 22.21 o5.31 5.12 239.33 61.67 178 46.7 850.21 5.21 851.04 6.08 854 12.3 891.8 893 12.93 888 15.5 286.33 76.82 251.4 62.96 181 59.3 21.03 378.75 26.6 360.2 25.81 338 24.0 1.53 31.65 33.6 32.03* 28.17 1.17* 24.8 23.7 5.75 3.75 2.5 2.9 4.6 Mean 20.9 18.9 15.19 8.23 6.3 25.25 6.25 5.4 4.2 11.2 25.48 10.9 34 12.6 44 1.6 ID fans amps 46.42 1.1 45.75 2.15 46.04 1.76 46.75 1.11 46.2 1.6 46.46 2.41 45 1.72 ID fans pressure (psig) 5.15 O.B9 5.67 1.40 6.17 1.14 6.09 1.04 6.08 0.89 6.06 1.4 5.21 1.07 4.2 0.76 FD fans amps 30.29 1.12 29.91 1.79 29.54 1.41 30.46 1.35 30.3 1.5 30.67 1.79 29.44 0.97 28 1.5 FO fans pressure (psig) 4.26 0.77 3.94 1.13 4.32 0.78 4.32 1.06 4.5 1.3 4.54 1.41 3.54 1.03 3.1 1.05 Furnace draft (psig) 0.60 0.20 0.59 0.18 0.59 0.15 0.62 0.15 0.6 0.13 0.63 0.12 0.53 0.10 0.59 0.092 Flue gas temp (°F) Boiler exit ESP inlet 9.78* 647* 318.5* 6.69* 688* 17.51* 687* 341* 9.19* 3.16* 695* 6.67* 345.5* 1.58* 688* 340* 6.3* 0* 699* 342* 3.94* 4.22* 662* 327* 10.33* 8.23* 629* 305* 20.2* 21.2* Ambient temperature (OF) 16.06 7.58 27.39* 10.39* 24.08 6.81 7.63 5.22 19.79 9.19 24.58 4.29 28.17 4.99 37 7.5 Ambient pressure Inches Hg 29.34 0.18 28.89* 0.11* 28.88* 0.06* Z9.17 0.08 29.04 0.1 28.97 0.048 29.01 0.06 * Hot basted on 24 hour readings 1 2 Based on tachometer type gauge Based on weight type gauge 28.89 0.097 (Continued) �TABLE 2-3. 3-10-80 Date Mean o 3-11-80 Hean . o (Continued) 3-13-BO 3-12-80 Hean o Hean o 3-14-60 Mean a 3-15-80 Mean o 3-18-80 3-17-80 Mean o Mean o 29.1 26.7 8.77 S.43 30.8 28.0 6.10 6.20 31.2 27.1 6.26 7.99 31.2 28.3 6.11 6.16 30.5 28.0 6.25 6.01 21.7 19.6 5.95 5.68 29.5 27.2 7.74 7.58 31.8 29.3 3.84 3. 65 Steaa flow rate (1000's Ibs/hr) 254 80.2 277 62.8 255 94.0 268 82.2 270 62.8 186 55.06 259 76.1 283 40.0 Stead pressure (pslg) 853 9.1 ass 6.24 855 5.8 853 8.6 852 7.0 850 8.6 850 5.3 850 6.3 . Stea« temperature (°f ) 892 11.5 894 11.2 893 11.0 893 12.2 894 12.5 888 11.1 892 9.4 890 16.2 Feedwater flow rate (1000's Ibs/hr) 266 83.1 277 78.5 279 80.2 286 71.0 281 61.3 194 54.0 268 74.5 295 38.1 Feedwater temperature (OF) 362 34.9 372 23.6 370 25.2 371 23.4 371 21.8 330 69.4 367 26.3 375 11.7 Fuel feed rate 1 (1000's Ibs/hr) 2 28.8 31.2 9.03 29.1 30.3 7.08 30.5 31.0 7.13 31.9 33.4 9.81 30.4 30.7 6.64 24.2 24.0 6.6 30.9 31.2 7.23 32.0 31.6 3.84 Fuel oil (gallons/hr) 4.17 Excess air I 24 12.9 20 5.1 20 5.9 23 9.8 24 11.3 39 12.5 26 13.3 21 3.6 ID fans i«ps 45 2.5 46 3.1 46 1.8 46 1.5 45 1.5 42 4.0 46 1.6 46 0.98 5.8 0.77 MU Gross Net 11.25 2.08 12.08 37.9 3.75 2.92 2.50 ID fans pressure (pslg) 5.4 1.32 6.0 1.18 6.2 1.20 6.0 0.91 5.9 1.01 4.3 0.81 5.0 1.00 FD fans amps 30 1.3 30 1.1 28 6.2 30 1.5 29 1.5 28 1.4 30 1.6 30 1.0 FD fans pressure 4.0 1.18 4.6 1.12 4.4 1.46 4.2 1.20 3.7 1.12 3.0 1.00 4.1 1.09 4.1 0.97 Furnace drift (pslg) 0.60 0.036 0.58 0.024 0.61 0.042 0.63 0.024 0?62 0.044 0.74 0.092 0.59 0.074 0.59 0.1 Flue gas te»p (°F) Boiler exit ESP Inlet 685* 340* 5.3* 0* 664* 323* 37.3* 27.1* 675* 327* 31.1* 14.6* 686* 324* 37.5* 20.1* 669* 326* 30.2* 16.0* 625* 295* 27.3* 20.2* 669* 319* 48.9* 21.3* 676* 326* 24.0* 9.5* Ambient temperature 27 7.5 25 7.9 30 1.6 28 2.6 37 12.6 51 11.2 34 4.9 49 12.8 Ambient pressure inches Hg 28.91 0.195 29.14 0.061 28.88 0.08 28.89 0.13 29.11 0.02 28.98 0.10 29.09 0.04 29.06 (Continued) (psig) 0.07 �TABLE 2-3. Date 3-19-80 Mean a 3-20-80 Mean o (Continued) 3-22-80 Mean a 3-23-80 Mean o 3-25-BO 3-24.80 Mean o Mean o 3-26-80 Mean a 31.0 27.2 5.01 6.96 30.6 26.8 5.88 7.68 29.4 27.1 5.16 4.95 18.1 16.2 1.98 1.80 29.7 27.4 7.77 7.55 29.5 27.2 7.54 7.21 30.5* 27.7* 6.17* 6.29* Steam flow rate (1000's Ibs/hr) 277 52.1 273 59.8 260 51.3 153 16.2 264 73.5 262 71.9 258 79.1 Steam pressure (psig) 853 7.0 851 5.0 853 7.4 852 5.7 858 4.9 852 4.8 854 4.4 Steam temperature (°F) 888 12.1 891 12.3 891 11.8 884 10.0 891 11.2 892 10.7 890 16.6 Feed water flow rate (1000's Ibs/hr) 287 50.6 222 US. 4 270 50.5 162 17.8 273 72.5 272 71.4 283 61.6 Feedwater temperature 375 16.5 372 16.8 365 18.9 325 7.1 367 25.4 364 27.6 369 20.9 Fuel feed rate 1 (1000's Ibs/hr) 2 31.1 31.4 5.74 33.6 34.4 7.06 31.3 31.1 8.32 20.8 20.4 1.71 32.3 32.8 8.26 31.8 31.8 7.66 29.6 31.9 7.16 Fuel oil (gallons/hr) 4.17 Excess air t 20 5.9 27 7.7 22 3.8 42 11.0 25 10.8 27 14.3 22 4.8 10 fans amps 45 1.3 46 1.8 45 1.7 42 0.7 46 2.2 46 1.6 45 1.3 ID fans pressure (psig) 5.7 0.85 5.9 0.9 5.3 0.9 3.8 0.22 6.1* 0.27* 5.7 1.14 5.6 1.24 FO fans amps 29 1.5 29 6.4 29 1.5 27 0.6 29 1.7 30 1.3 29 1.5 3.9 1.37 HU Gross Net 33.33 26.67 20.4 1.67 28.33 20.4 FD fans pressure (psig) 3.9 1.18 4.8 1.32 4.1 0.99 2.3 0.3 4.1 0.92 4.2 0.84 Furnace draft (psig) 0.6 0.10 0.6 0.09 0.59 0.1 0.59 0.057 0.53 0.07 0.57* 0.11* 0.53 0.09 Flue gas tenp (°F) Boiler exit ESP inlet 666* 328* 30.2* 15.9* 681* 324* 32.8* 12.7* 659* 320* 30.4* 12.2* 599* 280* 3.9* 0* 660* 322* 36.1* 23.1* 670* 323* 31.6* 2.03* 664 315 37.1 16.6 Anblent temperature (OF) 56 9.3 44 9.2 04 5.9 37 1.6 36 1.0 38 6.3 40 4.1 Ambient pressure inches Hg 28.81 0.09 28.92 0.085 29.04 0.134 28.97 0.04 29.04 0.08 29.17 0.024 29.17 0.05 �TABLE 2-4. TEST DURATION PROCESS DATA FOR THE AMES MUNICPAL POWER PLANT, UNIT NO. 7 Date 3-2-60 Hean 3-3-80 a Hean 3-4-80 a 3-5-80 a Mean 3-6-80 o 3-8-80 3-7-80 o 0800 to 2300 Hean o 0800 to 2300 Hean o 0800 to 2300 1100 MM 31 NS 2.31 34.8 32.3 0.3 0.3 35.2 32.7 0.3 0.2 35.0 32.6 0.2 0.2 34.6 32.2 0.8 0.8 35.3 32.8 1.0 1.0 31.3 NS 29 2.2 2.1 Steam flow rate 1000' s Ibs/hr 278.2 21.5 315.9 5.2 324 3.0 319.1 3.8 315.4 10.3 322.8 11.9 275.6 23.7 Steam pressure psig 859.5 3.5 852.1 4.0 850.5 3.5 850.5 3.5 848.8 6.2 852.2 4.5 851.9 7.3 Steam temperature F 903.6 6.4 902.5 6.2 900.5 3.5 902.3 6.8 897.8 10.2 895.1 12.1 895.3 12.2 288.5 24.1 Gross Net 0900 to 1900 0900 to 1900 Hean Duration of Test to 2100 0900 to 2000 Hean Feedwater flow rate 1000's Ibs/hr 24.6 321.8 5.8 325.5 9.1 328.1 6.0 325.4 11.7 336.5 Feeduater temperature °F j__ 287.5 13.6 NS NS 381.3 2.3 390.5 6.1 394.1 3.0 388.8 3.4 390.1 6.9 375 7.3 Fuel feed rate (coal) 34.9 2.6 36.2 2.1 34.3 0.8 35.5 3.0 35.4 1.5 35.7 5.5 32.1 1.1 Excess air X 22.1 1.6 18.3 4.7 20.1 1.8 18.7 1.3 18.9 1.4 19.3 1.1 19.5 1.0 ID fans amps 47.3 0.5 46.9 0.8 47.2 0.4 47.2 0.4 47.1 0.6 47.9 0.9 46 0.8 ID fans pressure psig 5.6 0.8 6.6 0.4 7.0 0.2 6.7 0.2 6.5 0.6 6.9 0.3 5.84 0.5 0.6 30.0 0.3 Fuel oil gallons/hr FD fans »nps 30.8 1.2 30.8 0.8 30.4 0.5 30.9 0.7 31.2 0.8 31.8 FD fans pressure psig 4.6 0.8 4.5 0.7 4.7 0.3 4.4 0.6 5.2 0.8 5.3 0.7 4.1 0.7 Furnace draft psig 0.7 0.1 0.6 0.1 0.6 0.07 0.62 0.11 0.57 0.1 0.65 0.07 0.5 0.07 Flue gas temp (°F) Boiler exit ESP inlet NS NS HS NS NS NS NS NS NS NS NS NS NS NS NS NS NS NS NS NS NS NS NS NS NS NS NS NS Ambient temperature °F 23 3.1 NS NS 24.2 3.6 10.9 4.1 25.3 5.4 26.9 3.2 30.1 4.9 0.04 29.05 0.02 Ambient pressure Inches Hg NS - Not Sufficient Data 29.22 0.09 NS NS 28.85 0.03 29.23 0.01 28.98 0.05 28.94 (Continued) �TABLE 2-4. (Continued) Sampling Day 3-10-80 3.9.80 Hean o Hean a 3-11-80 Hean o 3.12-80 Hean o 3.13.80 Hean a 3.14.80 Hean a 3.15.80 Hean o 3-17-80 Hean o 21.0 19.1 5.14 4.94 35.0 32.3 0 0.04 35.0 32.4 0 0.09 35.5 32.8 0.58 0.61 35.0 32.4 0 0.10 34.4 31.8 1.12 1.11 19.6 18.2 6.59 6.56 34.8 32.4 0.24 0.62 Steam flow rate 177 46.6 310 5.0 320 5.5 325 0 320 0 309 14.5 182 66.8 312 3.8 Steam pressure 849 2.3 858 5.6 857 4.7 855 0 855 3.2 855 5.7 851 3.7 853 3.8 Steam temperature 892 12.2 896 11.9 898 8.6 905 5.8 899 5.1 896 12.3 889 12.5 895 8.4 13.8 184 64.2 321 4.8 HH Gross Net Feedwater flow 47.8 323 3.5 330 3.2 332 5.0 330 0 Feedwater temperature 340 21.9 390 0 388 2.6 390 0 385 1.4 384 3.1 336 24.9 383 2.5 Fuel feed rate (coal) 1000' s Ibs/hr 25.2 6.04 36.3 2.27 33.8 1.18 35.1 0.25 38.6 2.82 34.4 2.03 23.0 7.34 35.1 1.71 Fuel oil gallons/hr CD 188 319 6.25f NA 4.17f NA 11.25t NA 12.08t NA 2.08t NA 3.75t NA 37.92f HA 2.92f HA Excess air 34 12.1 16 0.8 18 18 18 1.1 17 1.5 41 14.1 18 1.6 41 4.8 46 0.6 ID fans amps 44 1.9 47 0.9 47 1.0 0.7 48 2.9 0.6 47 0.5 46 0.8 0.30 6.4 0.50 4.0 0.80 S.S 0.82 ID fans pressure 4.2 O.B1 6.2 0.25 6.8 0.29 7.4 0.48 6.4 FD fan amps 28 1.8 30 0 30 0.5 30 0 31 0.51 30 0.7 28 1.5 30 0.51 FD fan pressure 2.9 1.01 4.8 0.36 5.3 0.45 6.0 0.71 4.9 0.71 4.2 0.86 2.7 1.00 4.7 0.60 Furnace draft 0.59 0.078 0.61 0.033 0.58 0.024 0.60 0.071 0.63 0.015 0.62 0.047 0.70 0.035 0.58 0.071 Boiler flue gas temp 632* 18.6* 686 5.3 688* 13.7* 690 11.6 709 11.1 685 15.0 618 30.4 695* 35.6* ESP Inlet temperature 309* 16.9* 340 0 340* 0* 335 0 335 1.4 334 1.8 289 21.3 331* 2.2* 4.2 37 4.7 0.048 29.12 0.030 Ambient temperature 42 4.4 22 1.6 31 4.0 30 0.5 30 1.5 46 5.8 10 •Ambient pressure 28.82 0.023 28.96 0.091 29.11 0.053 28.85 0.022 28.92 0.123 29.11 0.018 28.92 Sampling duration 8:30A-10:11P 8:10A-5 :33P 8:25A-10:35P 9:10A-1 :15P 8:35A-9 :47P 8:40A-10:55P B:49A- 10:25P 9:05A- 10:06P (rontlnued) . �TABLE 2-4. Sampling Day 3-18-80 Mean HU Gross Net Steam flow rate a 3-19-80 Mean 0 (Continued) 3-20-flO Mean 3-22-80 a Hean 0 3-23-80 Hean 34.0 31.4 1.90 1.91 33.0 30.4 4.30 4.15 31.8 28.8 5.45 5.42 29.4 26.9 6.93 6.66 18.5 16.6 307 19.5 297 44.1 281 57.6 260 66.3 155 o 1.51 1.36 3-24-80 Hean 3-26-80 3-25-80 0 o Hean 34.6 32.2 0.48 0.57 2.5 311 5.8 851 34.8 32.7 0.29 0.76 11.9 311 855 Hean o 35.0 32.5 0.6 0.6 3.0 310 0.9 4.8 852 2.7 Steam pressure 6.8 853 3.8 851 7.5 856 894 11.1 888 13.9 892 12.5 889 13.6 886 7.7 899 11.8 892 9.6 902 14. B 318 20.5 307 44.1 292 55.8 270 66.2 156 38.2 321 4.8 324 2.4 327 3.9 Feedwater temperature 383 4.2 382 12.7 372 19.8 365 25.7 328 7.9 384 2.5 384 2.5 380 0 Fuel feed rate Coal (1000's Ibs/hr) 113 852 Feeduater flow W 6.0 Steam temperature to 851 4.8 33.3 33.2 7.92 21.4 1.28 33.1 1.03 33.8 0.50 35.1 2.84 2.26 32.6 6.16 8.20 33.5 Excess air 20 1.8 19 6.0 24 3.4 26 13.0 38 10.6 16 1.7 18 1.0 18 0.6 ID fans amps 46 0.5 45 0.9 46 2.4 45 1.3 42 0.6 48 1.0 48 0 46 0 ID fans pressure 6.2 0.46 4.5 0.99 5.8 1.09 5.4 1.02 3.8* 0.24* 6.2 0.17 4.8 1.82 6.6 0.34 FD fan amps 30 0.4 30 1.5 30 1.9 30 1.6 27 0.4 30 0 30 0 30 0 FD fan pressure 4.4 0.61 4.4 1.01 6.5 6.60 4.1 1.14 2.3 0.36 4.5 0.10 4.8 0.51 4.7 0.80 Furnace draft 0.60 0.107 0.60 0.109 0.81 1.019 0.61 0.056 0.58 0.057 0.52 0.093 0.59 0.075 0.53 0.065 Boiler flue gas temp 687* 7.8* 686* 8.6* 695* 15.9* 679* 9.8* 598* 4.6* 674 U.I 676 U.I 689 16.0 0 325 3.5 Fuel oil gallons/hr ESP inlet temperature 330* 3.6* 338* 2.5* 330* 4.8* 328* 2.6* 280* 0* 335 0 335 4.2 37 1.5 37 1.5 44 0.8 43 2.6 0.078 28,98 0.024 29.05 0.012 29.16 0.018 29.17 0.041 Ambient temperature 58 6.8 62 6.3 42 6.2 42 Ambient pressure 29.02 0.056 28.75 0.042 29.03 0.106 28.95 Sampling duration 9:OOA-U:25P * Hot a total time man. 8:43A-12:07A 9:05A-4 :25A 9:47A-2 :12A 9:27A-2 :10A 11:10A-3:47P 11:20A-3:46P 9:22A-2 :06P �Unit No. 7 generally operated between a range of 16 to 35 MW gross, (refer to daily process data tables provided in Appendix D). Production over 35 MW placed considerable wear on the unit, and was avoided whenever possible. Production under 16 MW introduced instability and the possibility of large transient swings in operating conditions. Usually the boiler was operating close to one of these limits. It operated at 35 MW during peakloads because the load of the serviced community was over 35 MW. Production was reduced to 16 MW when off-peak power could be bought more cheaply from neighboring utilities. Examination of Table 2-3 indicates that the daily mean of gross electrical output (24 hour basis) is typically between 29 and 32 MW due to boiler operation at full output for a large portion of the day. In fact, the hourly readings provided in Appendix D indicate that output is rarely below 35 MW between the hours of 8 AM and 10 PM or longer. During non-peak hours, the boiler operated between 16 and 25 MW, depending on load and the amount of power being purchased from neighboring utilities. Comparison of the daily cycles of power production with the standard deviations (24 hour basis) given in Table 2-3, indicates that the standard deviations range between 5 and 7 for days representative of typical operation. Values not lying in this range are indicative of abnormalities such as the buying of cheaper power through the peak hours, or unusually high off-peak loads. The standard deviations in Table 2-3 show that these abnormalities happen most often on weekends, especially Sundays. Weekday operation is fairly consistent, due to uniformly high loads and the resultant high cost of power. Net power output follows identical trends, since the pov/er demand of the auxiliary equipment associated with Unit No. 7 is fairly constant. Fuel consumption varied directly with the amount of electricity produced. Of the three types of fuels used in Unit No. 7 (coal, RDF, and fuel oil), coal was used in the largest quantities. The amount of RDF burned was limited to approximately 17% in terms of the total heat produced. This was because RDF, due to its lower heating value, cannot sustain sufficient temperatures to maintain required boiler efficiency and steam quality. Also, RDF requires a longer residence time in the boiler for complete combustion, and this places another physical restriction on the amount of RDF in the fuel mixture. Fuel oil is used sparingly, and only as an igniter to insure flame continuity dur2-20 174 �ing soot blowing. Different firemen have different procedures for its use, and the large variations in fuel oil consumption shown in Table 2-3 are more related to operating practices than to what was happening in the boiler. The continuous supply of RDF to the boiler during the test was found to be unreliable. Practical experience during the test indicated that RDF supply was very unreliable. The RDF conveyors which feed Unit No. 7 were prone to jamming and required frequent maintenance. Often the RDF supply ran out because the solid waste recovery plant was experiencing mechanical problems, or had run out of refuse to process. Out of 23 days of sampling, only on 6 was RDF burned continuously. On 15 days RDF was burned part of the time, and on 2 days it was not burned at all (refer to Appendix D). The means and standard deviations for coal consumption given in Table 2-3 follow those of the gross electrical output. This indicates that coal consumption is closely related to electrical output, as expected. However, these daily averages mask out one important effect. Referring to the tables in Appendix D, one can see that the amount of coal burned depends on whether there is RDF in the mixture or not. All other things being equal, the flow of coal will always go up or down, depending on whether RDF is being removed or introduced into the mixture, respectively. 2.2.1 Operating Parameters Data for the steam cycle in the boiler are also listed in Table 2-3. Examination of the data indicates that the steam and feedwater flow rates fluctuate in a daily cycle, with means and standard deviations following the gross electrical output. However, the values for steam temperature and pressure remain fairly constant. The feedwater temperature also varied. It was higher on days of high electricity production, and lower on days of low production. Excess air is one of the most important parameters for describing conditions inside the combustion chamber. Unit No. 7 is designed to operate at about 20% excess air. Data in Table 2-3 indicates that on the average this is true. However, the hourly data (refer to Appendix D) indicates wide fluctuations. Excess air tended to increase as the boiler load decreased. 2-21 175 �This was possibly due to the operater not decreasing the intake air with the reduction in fuel supply. On nearly each night the excess air reading was greater than 50% (the maximum readable value on the meter). The standard deviations of the mean excess air values indicate no direct relationshop to the deviations of gross power output. Consequently, excess air is not a function of power output alone. Unlike most other parameters, the excess air setting was subject to the whim of the operator, and changes from work shift to work shift could have introduced important variations. The induced and forced draft fan measurements listed in Table 2-3 are of limited significance , since they did not respond to increases in production with greater airflows and correspondingly greater current consumption. The furnace draft data indicated little or no correspondence to any of the other measured data. Most of the flue gas and ESP inlet temperature readings were incomplete as they did not cover the entire 24 hour day. Most of this information was recorded during peak operation, and may therefore be considered representative for peak operation conditions. Both the flue gas and ESP inlet temperatures decreased during off-peak periods. Routine activities such as ash removal and soot blowing was performed at times designated in the test plan. RDF was observed to have a substantially higher ash content than coal, and this characteristic was reflected by longer ash removal periods, and more periodic soot blowing. Both activities decreased substantially when RDF was not being burned. 2.2.2 Test Duration Data Table 2-4 contains means and standard deviations for all of the parameters given in Table 2-3 on a test duration basis. They are derived from the same hourly data given in Appendix D, but the averages are taken over shorter periods of time than the 24 hour means discussed previously. These values are included only to indicate what operating conditions existed during the hours of each test. They are not, however, indicative of overall boiler performance. For instance, some tests were performed only over peak hours. These means would be indicative only of peak conditions, and the corresponding standard deviations would be very small, since the parameters remained fairly constant during this period. 2-22 176 �2.2.3 Daily Production and Consumption Data Table 2-5 contains information recorded by the power plant on a daily basis. The total gross and net power production was recorded directly from meters inside the plant. The total steam produced divided by the gross power production gave a good indication of boiler efficiency. Separate meters are used for measuring the water used for ash removal and the total input to the evaporators. The days of highest sluice water use corresponded with days of prolonged use of RDF in the fuel mixture. The evaporators eventually feed into the working fluid cycle of the boiler, and gave a fair indication of make-up water required, except that there was a water reclamation system attached to the boiler. Hence, these values indicated new input to the system, but did not account for total make-up water requirements. Most of the fuel types were very accurately measured. Coal was measured through a weight integrating system, and fuel oil was similarly measured through a volume integrating system. However, no accurate measurement of the RDF was -possible. The values listed were derived from volumetric readings and a very rough measurement of the RDF density, taken once every shift. The Btu contribution of each fuel was then calculated by doing calorimetric analyses. This was done periodically, and the values used for the duration this test program are given in Table 2-6. By summing the Btu contribution of each fuel, a value for total heat production can be found. This value was then divided by either the gross or net electricity production to express thermal energy as it related to the power production of the day. 2.3 Continuous Monitoring Data Table 2-7 presents the daily averages of 02, C02, CO, and total hydrocarbon monitoring on approximate test duration basis. Occasionally the continuous monitors were allowed to run longer than the actual test, but the data can still be considered to be representative of the test duration. Hydrocarbon values were always found to be lower than 2 ppm, the sensitivity limit of the instrumentation used. 2-23 177 �TABLE 2-5. DAILY PRODUCTION AND CONSUMPTION AT AMES MUNCIPAL POWER PLANT, UNIT NO. 7 Power Production (kwh) Thermal Energy* (Btu/kwh) Oil (gallons) Sluice Uater for Bottoa and Fly Ash Removal (gallons) Uater Input to Evaporator (gallons) Fuel Consunptlon Steam Production (Ib/kwh) Iowa Coal (Ibs) Colorado Coal (Ibs) RDF* (Ibs) Date 681 000 623 902 11 186 12 210 9.57 339 9 8 8 432 712 0 60 250 000 8 300 ' 3-3-80 709 000 648 682 11 296 12 346 9.59 418 330 342 270 113 000 160 340 000 9 000 3-4-80 761 000 700 072 11 396 12 388 9.53 412 290 351 210 226 800 70 320 000 2 200 3-5-80 759 000 698 461 11 697 \2 711 9.73 434 538 370 162 192 375 60 380 000 6 800 3-6-80 740 000 679 858 11 693 12 728 9.50 432 0% 339 504 213 200 90 450 000 9 200 3-7-80 735 000 674 470 11 652 12 697 9.64 427 127 378 773 130 BOO 100 320 000 2 500 3-8-80 648 000 590 057 11 602 12 742 9.54 358 286 317 720 168 460 130 360 000 1 120 3-9-80 494 000 443 496 11 524 12 836 9.47 301 888 267 712 26 000 150 314 908 8 500 3-10-80 00 Net 3-2-80 ro I £ Gross 693 000 635 037 10 955 11 985 9.54 486 980 262 220 81 200 100 386 716 6 300 3-11-BO 739 000 678 629 11 440 12 458 9.57 334 328 392 472 229 600 270 403 172 5 800 3-12-80 750 000 688 456 11 348 12 362 9.62 408 980 334 620 229 075 290 413 644 3 500 3-13-80 742 000 681 889 11 S44 12 562 9.68 432 270 368 230 144 075 50 422 620 9 100 3-14-80 729 000 668 119 11 537 12 588 9.51 412 440 324 060 230 400 90 . 41B 132 0 3-15-80 508 000 457 939 11 434 12 684 9.50 322 448 253 352 22 050 910 335 104 5 700 3-17-80 699 000 639 942 11 170 12 201 9.59 412 335 337 365 97 650 70 396 000 11 100 3-18-80 759 000 696 494 10 855 11 829 9.52 417 010 341 190 154 874 60 473 000 15 200 3-19-80 748 000 682 596 10 794 11 829 9.51 414 315 338 985 134 816 100 477 000 6 000 3-20-80 753 500 689 205 11 368 12 388 9.56 445 392 379 408 63 700 490 320 000 7 300 3-22-80 706 000 647 644 11 077 12 075 9.55 410 520 335 880 92 000 640 250 000 5 400 3-23-80 426 000 382 263 11 311 12 605 9.49 269 610 220 590 0 800 180 000 16 600 490 300 000 4 500 Gross Net 3-24-80 710 000 650 039 10 841 11 841 9.61 629 920 157 480 51 600 3-25-80 700 000 642 Oil 11 080 12 081 9.52 610 880 152 720 93 000 680 430 000 4 000 3-26-80 726 000 664 973 10 949 11 954 9.60 612 960 153 240 134 970 40 540 000 18 500 •This Is only a rough Measure of RDF weight. This value is derived from the average Btu content of each fuel. �TABLE 2.6, HEAT CONTENT OF FUELS USED AT THE AMES MUNICIPAL POWER PLANT DURING SAMPLING PERIOD Heat Content for each Fuel Type niiM-nnn Dur 1on ^ Test Iowa Coal (Btu/lb) Colorado Coal (Btu/lb) RDF (Btu/lb) Fuel Oil (Btu/gallon) 3-2-80 thru 3-16-80 8946 10,556 5587 138,603 3-17-80 thru 3-26-80 9035 10,298 6128 138,603 2-25 179 �Fluctuations in the 02, C02, and CO levels are usually indicative of process conditions in the boiler. The means for these components at Ames were fairly uniform, as can be seen from Table 2-7. The only unusual days were March 9, 15, and 23, as evidenced by high 02 levels and low levels of C02 and CO. From Table 2-4, it can be seen that these were days of low electrical output and correspondingly high levels of excess air. Furthermore, these were the only days that were typical in this regard. Although excess air was monitored in the plant's control room, it has also Been calculated on a theoretical basis for comparison using the following expression 02 - CO/2 % excess air = 1QO x 1 4 N'2 - (02 - CO/2)] ^6 where the. gaseous components are expressed as percentages. The results of these calculations are given in Table 2-8, along with the values of excess air measured in the control room. The calculated values are consistently smaller, and the same anomalies appear (i.e., large values on the 9.th, 15th, and 23rd). In this case, the measured values are larger because these were taken after the air preheater to the boiler. Evidently, there is some air leakage in the preheater. 2.3.1 Air Preheater Leakage Oxygen in the flue gas at the inlet and outlet to the preheater was monitored on March 8, 1980 to determine air preheater leakage. Continuous monitoring results are presented in Table 2-9. The oxygen readings were also plotted and are shown in Figure 2-1. Examination of the plots in Figure 2-1 indicates that the increases and decreases in oxygen at the boiler exit are closely followed by similar increases and decreases in oxygen at the ESP inlet which is located downstream of the boiler. Since the variable oxygen readings at the inlet and outlet were taken on an intermittent basis, at 15 minute intervals, it was difficult to relate the data points at the boiler exit and the ESP inlet on a same time basis. However, from the graph the similar trends of the two curves can be easily observed. 2-26 180 �TABLE 2-7. CONTINUOUS MONITORING DATA Sampling Location Date (1980) °2 (*) Mean o Mean 2 (t) o CO (ppm) Mean o THC (PP«) a Mean ESP Inlet ESP Outlet 4.6 6.3 0.34 0.53 12.7 11.4 0.44 0.53 17.9 16.5 1.61 1.57 <2 <2 . Inlet Cutlet 3-3 4.4 5.8 0.55 0.65 13.7 12.5 0.63 0.67 12.4 10.7 1.54 1.16 <2 <2 - Inlet Outlet 3-4 4.4 6.1 0.35 0.17 14.4 13.0 0.36 .19 16.7 14.7 0.75 .89 <2 <2 - Inlet 3-5 4.4 5.6 0.66 0.83 14.6 13.4 0.58 .36 18.3 27.8 1.22 10.14 <2 <2 . Inlet Outlet ro 3-2 3-6 4.3 0.29 13.9 DATA TAttN FOR INLET ONLY 0.37 16.7 2.30 <2 - Inlet Outlet 3-7 4.6 5.9 0.32 0.27 13.9 12.8 0.35 0.28 16.4 14.7 1.50 1.63 <2 <2 - Inlet Outlet 3-8 4.3 4.8 0.30 0.40 14.0 13.6 0.30 0.39 27.6 28.4 0.85 2.29 <2 <2 _ Inlet Outlet 3-9 7.1 8.8 1.23 1.38 11.6 11.0 1.22 1.24 24.7 22.6 1.82 2.31 <2 <2 _ Inlet Outlet 3-10 4.0 5.6 0.30 0.19 13.9 12.4 0.30 0.14 24.5 24.9 1.51 1.04 <2 <2 Inlet Outlet 3-11 4.7 5.8 0.28 0.23 13.6 13.2 0.48 0.51 22.4 21.2 1.88 1.29 <2 <2 _ Inlet Outlet 3-12 4.4 5.6 0.29 0.33 14.0 13.8 0.43 0.56 22.1 22.3 1.75 3.77 <2 <2 _ Inlet Outlet 3-13 3.3 5.2 0.30 0.57 15.6 14.0 0.33 0.96 20.7 18.4 0.90 1.03 <2 <2 _ Inlet Outlet 3-14 3.7 5.3 0.40 1.03 14.8 13.1 0.47 0.74 27.7 29.9 4.21 16.56 <2 <2 - (Continued) �TABLE 2-7. (Continued) Sanpl 1 ng Location Date (1980) o2 (%) Mean o co2 Mean THC (ppm) CO (ppm) (X) a Mean a Mean a Inlet Outlet 1.56 1.87 12.6 10.7 1.45 1.67 22.0 18.7 2.03 2.01 <2 <2 - 3-17 3.7 5.4 0.47 0.32 14.4 12.9 0.62 0.33 21.5 20.0 1.73 1.41 <2 <2 - Inlet Outlet 00 6.3 8.4 Inlet Outlet i-- ro 3-15 3-18 3.8 5.4 0.33 0.30 14.4 13.0 0.46 0.40 23.3 23.7 1.18 9.62 <2 <2 Inlet Outlet 3-19 3.8 5.3 0.58 0.47 14.7 13.2 0.72 0.47 23.6 26.2 1.84 17.55 <2 <2 - Inlet Outlet 3-20 4.1 5.9 0.29 0.25 14.3 12.8 0.41 1.11 20.1 17.4 2.21 1.70 <2 <2 - Inlet Outlet 3-22 3.6 5.4 .34 .29 14.2 12.6 .35 .46 38.3 37.7 25.81 22.61 <2 <2 - Inlet Outlet 3-23 5.9 8.8 1.09 .75 12.7 10.1 1.08 .74 NOT OPERATING <2 <2 _ Inlet 3-24 _ I Inlet Outlet 3-25 Inlet Outlet 3-26 H • .24 H H <2 _ 13.8 13.1 .71 .26 H H M <2 <2 - M .87 4.9 13.7 DATA TAKEN FOR INLET ONLY .73 M N <2 - DATA TAKEN FOR OUTLET ONLY 5.4 .24 13.2 4.4 5.4 .83 .23 �TABLE 2-8. EXCESS AIR READINGS Excess A1r %] Excess Air %2 3-2-80 3-3-80 26.7 22.1 25.5 18.3 3-4-80 25.8 20.1 3-5-80 25.9 18.7 3-6-80 3-7-80 3-8-80 3-9-80 3-10-80 24.9 27.2 24.9 49.4 22.6 18.9 19.3 19.5 34 16 3-11-80 3-12-80 3-13-80 3-14-80 3-15-80 3-17-80 3-18-80 3-19-80 3-20-80 3-22-80 3-23-80 3-24-80 3-25-80 3-26-80 27.9 25.7 18 18 18 17 41 18 20 19 24 26 38 16 18 18 Date o 18.2 20.8 41.7 20.6 21.4 21.4 23.5 19.9 37.8 NA 25.6 29.5 Based on continuous monitoring data from the ESP inlet Control room readings 2-29 183 �TABLE 2-9. AIR PREHEATER CONTINUOUS MONITORING DATA Boiler Ex1t/Preheater Inlet Time %o2 % co2 CO ppm THC ppm 1430 4.237 13.926 28 ESP Inlet/Preheater Outlet 0.42 % rn % LU2 CO ppm THC ppm 4.593 13.784 29 0.1 4.975 13.542 28 0.22 4.544 13.668 29 0.20 4.901 13.520 27 0.19 5.207 12.43 26 0.21 4.879 13,538 26 0.15 4.153 14.246 28 0.18 5.141 13.574 26 0.18 4.359 13.902 28 0.04 4.959 13.564 27 0.25 4.397 13.946 28 0.11 4.401 13.558 36 0.18 27.58 0.304 4.71 13.61 28. 1 0.168 0.114 0.34 0.43 2. 7 0.059 1445 4.094 1500 14.222 27 0.49 1515 3.741 1530 14.414 28 0.45 1545 4.637 1600 13.678 28 0.37 1615 4.083 1630 14.304 28 0.41 1645 4.089 1700 13.972 26 0.22 1715 1730 v 4.198 14.154 27 0.18 1745 1800 4.192 13.740 26 0.23 1815 1830 4.295 13.976 28 0.19 1845 1900 3.937 14.154 29 0.22 1915 1930 4.742 13.492 28 0.26 1945 2000 4.632 13.566 28 0.21 2015 Mean 4.24 13.97 0.30 0.30 0.9 %o2 2-30 184 �Figure 2-1. Oxygen 1n the gas before and after the air preheater 2-31 185 �Air preheater leakage is defined as the ratio of the difference between the amount of flue gas out of the preheater and the amount of flue gas into the preheater to the amount of flue gas into the preheater. In order to estimate this leakage average values for oxygen for the inlet and outlet from the monitored data were used. Based on an average oxygen reading of 4.24 percent at the preheater inlet and 4.71 percent at the outlet an air preheater leakage of 2.9 percent was calculated. It must however be noted that during this period the boiler load averaged approximately 88% and the RDF heat input to the boiler was approximately 20 percent. Air preheater leakage will vary with the steam load and type of fuel fired. 2-32 186 �3.0 SYSTEM DESCRIPTION The coal-fired utility boiler tested was the No. 7 unit at the Ames Municipal power plant. The power plant is owned and operated by the city of Ames. Three boiler units, 5, 6, and 7, at the power plant have been modified to burn solid waste as a supplemental fuel with coal. Boilers 5 and 6 are Stoker-fired boilers and boiler No. 7 is a pulverized coal suspension fired boiler. Under normal operating conditions only unit No. 7 is used. Units Nos. 5 and 6 are operated only under peak demand conditions or when unit No. 7 is down. The power plant is located within the city limits of Ames, Iowa. Ames is approximately 54 Km (34 miles) north of Des Moines. The Ames Municipal power plant layout is shown in Figure 3-1. 3.1 Boiler Description Boiler No. 7 was designed to burn coal or natural gas as the primary fuel. It is a tangentially fired, pulverized coval, balanced draft, Combustion Engineering unit, rated at 175000 kg/hr (385,000 Ib/hr) of steam. The generator is rated at 35,000 KW, gross. Unit No. 7 has been operating since June 1968. However, modification to burn refuse derived fuel (RDF) was made in 1975. Boiler No. 7 specification data is provided in Table 3-1 and a flow diagram of unit No. 7 is given in Figure 3-2. As shown in Figure 3-2, coal from the plant stockpile is fed to two Raymond Bowl Mill pulverizers. Air preheated to about 340°C (650°F) by the combustion gases is supplied to the pulverizers to dry the coal, and to convey the pulverized coal to the burners. Pulverizer air preheat is necessary to prevent pulverizer to burner blockage which can be caused by wet fuel. Design specifications of the Raymond Bowl Mill pulverizer are provided in Table 3-2. Pulverized coal entrained in 15 to 20 percent of the total combustion air is conveyed to the individual burner nozzles which direct the coal and primary air into the combustion chamber. Combustion air is supplied to the boiler unit by a Westinghouse forced draft fan. The combustion air drawn 3-1 187 �1 BAND 5i!FT 1. CUD 1 HOUSE I STREET IS METERING STATION Q COOLING CZ3 FUEL Oil STOXACE POWER PLANT NO. 2 TOWER CLEAR WELL ASH COOLING 'SILO O I TOWER r ELECTROSTATIC 1'RKCIPITATOR UNIT NO. 7 ADDITION jn] n LJ; -I ID co co cEj UATF.R PLANT I nro COVERED ENTRY I TRANSFORMER STACK DWELL NO. 3 CO C O A L S T 0 R A C I Figure 3-1. Layout of plant site A R E A �TABLE 3-1. BOILER DESIGN DATA Description Slzt Dtslgn pressure, psl 108S Total effective heating surface sq ft Boiler 16550 Furnace EPRs 6200 Superheater - Convection zone 5200 Radiant zont 1800 Economizer None Regenerative A1r Heater 67200 A1r Preheating Coll 5070 Furnace Volume, cubic feet 27300 Furnace width and depth by 19'-ir C to C of tubes, ft Furnace design pressure, in H^o positive 8" KG Total weight complete. Ib 2,340,000 Water required to fill boiler and water walls to operating level, gal Appro*, 17,900 U.S Gallons Inside diameter and thickness of steel drum 66" DIA - 4 | " x 2 | • | | Overall length of steam drum Appro*. 27' - 0* Drum head thickness, In lifting weight of drum safety valves 2 1/4" 66" 0 Drum • 85000 LBS Manufacturers, type, number and sizeof drum safety valves Consolidated Two (2) 3" I1757A Manufacturer, type, number and stze of blowdown valves Two C21 sets 2- Yarwey 6968-81 Tubes 1n furnace Size and thickness Water well tube spring, In C to C Furnace exit first row tube spring. In C to C 2 1/2" 0,D, x .180 3" all wells 9* (finishing superheater} NO SA 26 9" Are tubes staggered? Material Number Tube spring In C to C Tubes 1n Boiler Size and thickness Material Tube spring C to C (1n) Number - IN LINE - 192 Assemblies (Finishing superheater) 2 1/2- O.D. x ,12 SA -192 3 3/4" Transverse 1472 Water walls - 10 to 1 Circulation ratio, minimum 3-3 189 �BOILER FEED PUMP SPRAY WATER DESUPERHEATER FEEDWATER FIRST STAGE PRESSURE INTEGRATOR STEAM JET AIR EJECTOR COAL TEMPERATURE FEED WATER IN BLEED STEAM' <A> I | FEED WATER HEATER FEED WATER HEATER UNTREATED -WELL WATER a COMBUSTION ENGINEERING PULVERIZER STEAM GENERATOR REFUSE DERIVED FUEL AIR HEATER 'LEAKAGE ATI.AS BIN T TEMPERATURE FLUE GAS IN NDUC-D RAFT AN VOLUMETRIC FLOW DENSITY COOLING TOWER SLOWDOWN AMBIENT AIR OVERGRATE (RDF ONLY) UNIT NO 7 ELECTROSTATIC PRECIPITATOR TEMPERATURE AIR IN FORCED DRAFT FAM UNDERCRATE AIR (RDF ONLY) SEAL _ WATER TEMPERATURE AIR OUT FLY ASH PRIMARY AIR TO PULVERIZER BOTTOM ASH COMBUSTION AIR Figure 3-2. Flow diagram for unit #7 at Ames Municipal power plant �TABLE 3-2. DESIGN SPECIFICATION FOR RAYMOND BOWL PULVERIZERS DESCRIPTION SIZE Pulverizers Manufacturer's Model No. C. E. Raymond No. 613 No. of pulverizers Two (2) Type and size Bowl Mill Weight including driver Approx. 98500 LBS each journal assembly Weight and dimensions of largest piece requiring removal for maintenance 3 x 4 x 4 ft 3900 LBS. Minimum stable firing rate, Ib per hr each of specified coal 8000 LBS/HR Maximum firing rate, Ib per hr of specified coal each 32000 LBS/HR @ 60 GR 17.1235 M Maximum turndown ratio Pul. - Burner Combination 4 to 1 Maximum horsepower input required 265 each Shaft Incl. Exhauster Primary air temperature, F. For the specified coal 651 Max. allowable 750 Maximum boiler load with one pulverizer in operation with specified coal, no gas firing, Ib per hr 250,000 3-5 191 �by the forced draft fan is obtained from the 9th floor of the power plant building (refer to Figure 3-3). Design specifications for the forced draft fan are provided in Table 3-3. The burners are designed to admit controlled quantities of additional air through separate air ports surrounding or built into the fuel nozzle. In the combustion chamber, the combustible matter reacts with oxygen of the air to release thermal energy at temperatures exceeding 1100°C (2000°F). The walls of the combustion chamber are lined with water-filled tubes which absorb thermal energy and generate steam. The water tubes are filled with liquid or vapor, depending on pressure and temperature conditions. Heat transfer in the combustion chamber cools the combustion gases. The cooler combustion gases flow from the combustion chamber to the superheater where further heat transfer and gas cooling occurs. The superheater is a combination Radiant-Convection type with 13 tube rows and 26 steam passes on the primary side and 26 tube rows and 52 steam passes on the secondary side. The maximum design temperatures in the superheater are: steam side - 350°C (primary), 485°C (secondary); gas side - 1150°C (primary), 1050°C (secondary); and outside metal surface - 470°C (primary), 545°C (secondary). Steam superheat is necessary for thermodynamic efficiency and also to prevent steam condensation which would damage the blades of the steam turbine. Combustion gases from the superheater normally flow to the economizer section where heat is transferred to the boiler feed water. However, the No. 7 unit has no economizer and flue gases from the superheater flow to the air preheater,, then to a cold-side electrostatic precipitator via an induced draft fan (refer to Table 3-3) out through the stack. The regenerative air heater has an effective heat exchange surface area of 67200 sq ft. Combustion gases enter the air heater at texperatures of 370° to 400°C (700 to 750°F) and exit at temperatures of 135° to 150°C (280 to 300°F). Air temperature entering the air heater ranges from 35° to 50°C (100 to 120°F) and exit temperatures range from 315° to 335aC (600 to 640°F). Performance characteristics for unit No. 7 provided by the manufacturer are given in Table 3-4. 3-6 192 �GAS OUTLET OJ ^ Figure 3-3. Schematic of Ames Municipal power plant boiler No. 7. �TABLE 3-3. FAN DESIGN PERFORMANCE Forced Draft Fan Manufacturers name Model No. Westinghouse #4054 Blade type Air foil Operating speed, rpm Air inlet temperature, °F Air flow (100% load), Ib/hr Air flow (100% load), ft3/min Fan static pressure, psi Static efficiency (100% load), % 1180 80° 422,696 99,934 0.28 54.6 167.1 Power required, Kw Induced Draft Fan Manufacturers name Model No. Blade type Operating speed, rpm Air inlet temperature, °F Westinghouse #4073 Air fovil 885 279 482,653 153,900 0.26 52.3 249.9 Air flow (100% load), Ib/hr 3 Air flow (100% load), ft /min Fan static pressure, psi Static efficiency (100% load), % Power to fan shaft, Kw 3-8 194 �TABLE 3-4. PREDICTED PERFORMANCE CHARACTERISTICS OF UNIT #7 AT AMES MUNICIPAL POWER PLANT. FUEL COAL Evaporation Feedwater Temperature Superheater Outlet Temperature Superheater Outlet Pressure Superheater Pressure Drop Gas Drop, Furnace to Econ. Outlet Ib/hr F Gas Drop, Econ. Outlet to A.H. Outlet "wg F F F F F "wg F % Gas Temp. Entering Air Heater Gas Temp. Leaving Air Heater, Uncorr. Gas Temp, Leaving Air Heater, Corr. I-1 t»> 10 I Ul to Air Temp. Entering Air Heater Air Temp. Leaving Air Heater Air Press, at F.D. Fan Ambient Air Temperature Excess Air Leaving Economizer F psig psi "wg Ib/hr % Fuel Fired - Coal 0 9506 BTU/J Efficiency 216,000 375 905 900 30 0:85 2.00 705 281 265 119 598 5.10 80 22 28,600 87.99 COAL 360,000 428 905 900 75 1.85 4.35 732 296 279 101 633 7.75 80 22 45,600 87.28 COAL 385,000 433 905 900 85 2.15 4.90 743 297 280 99 635 8.70 80 22 48,500 87.21 Superheat steam temperature control range is from 216,000 to 385,000 Ib/hr. The fuel specifications on which the above are based are as follows: F.C. V.M. Ash Moist. 37.10 32.27 13.51 17.12 100.00% HHV (as fired) 9506 BTU/# �Unit No. 7 generally burns a mixture of Iowa coal, Colorado coal, and refuse derived fuel (RDF). The ratio of the two types of coal in the mixture varies. However, during the test program a 55 to 45 percent ratio of Iowa and Colorado coal was maintained in the pulverized coal mixture. Approximately 20 percent of the total fuel fired is RDF and 80 percent pulverized coal. Coal is stored in the coal yard in two separate piles. Front-end loaders are used to move the coal to the transport conveyor feeding the storage bunker. Coal is alternately moved to the conveyor and is overlayed in the bunker prior to the coal dropping into the pulverizer. This mixing of coal is done on a weight basis and has proven satisfactory to the plant in maintaining the proper blend. RDF is produced at a separate Ames city facility located approximately two blocks away. All of the RDF produced is pneumatically conveyed to a storage bin (Atlas bin) 25 m (85 ft) in diameter with a holding capacity of 454 Mg (500 tons). The RDF is fed from the Atlas bin at the required rate (8.5 tons/hr maximum) and pneumatically conveyed to the RDF burners. There are two RDF burners located approximately 61 cm (24 inches) below the coal burners at opposite corners of the firebox. The location of the RDF burners is shown in Figure 3-4. The by-products of combustion are stack gases and ash. With pulverizedcoal firing, all of the burning is accomplished in suspension with the result that about 80 percent of the ash remains in the flue gases. Due to the utilization of REF to supplement coal as fuel, modifications were made to the boiler. Grates were installed in April 1978 to assist in the combustion of RDF. Prior to the installation of the grates, RDF burning in suspension was not very effective, and substantial portions of the RDF dropped unburnt into the bottom ash hopper. Deposited ash and slag in the boiler furnace bottom are removed at least 3 times per day. An average of 758,000 liters/day (200,000 gallons/day) of sluice water (raw well water) is used to remove the solid waste from the furnace bottom. This waste is then drained to a holding pond where the ash is dredged out. The water from the holding pond percolates through the soil eventually into the nearby Skunk river. Any overflow from the holding pond 3-10 196 �BOILER NO. 5 BOILER NO. 6 VO CO . Section CC From Atlas Bin South Figure 3-4. Solid waste recovery system �is also absorbed by the river. Also deposited in the holding pond is the electrostatic precipitator (ESP) fly ash. The fly ash from the ESP hoppers is pneumatically conveyed (3 times per day) to the bottom ash hopper drain system which transports it to the holding pond. The dredged ash is stored on site in piles. Make up water for the boiler is obtained from the city water supply. Boiler feedwater is processed by water softeners and deaerators and treated with caustic soda, phosphates and hydrazlne to prevent scaling and corrosion. Tannin is also added to maintain particles in suspension. Normal operation of the boiler is 24 hours per day, 7 days per week. The boiler is scheduled to be offline once per year for 10 to 14 days for various types of maintenance. 3.2 Electrostatic Precipitator Flue gases from the air heater are treated in an electrostatic precipitator (ESP) for the removal of particulate matter. The ESP in unit No. 7 is an American Standard Model 371. It is a wire/plate type with rappers and is designed to handle 4900 m /min (175000 cfm) of gas at an average inlet dust loading of approximately 9.27 gm/m (4 gr/scf). The ESP has 4 cell units with 2 fields and 8 insulator compartments. Performance characteristics for the ESP are given in Table 3-5, The collection system of the ESP has an effective surface area of 2030 m (21840 sq ft) with 28 gas passages having a space of 23 cm (9 inches) each. The collecting surface area rappers are of the electric vibrator type 2 and the maximum collecting surface area rapped at one instant is 113 m (1215 sq ft). Total hopper capacity is 48 m (1700 cubic feet) with overall dimensions of 5.2 m x 6.8 m x 18.1 m (17' x 22.5' x 59.5'). 2 The electrical system of the ESP requires a maximum operating voltage of 45 KV. Power requirement at maximum demand is 83 KVA and the total connected load is 61 KW. There are 8 electric vibrator type high voltage rappers and two rectifiers. The two rectifiers are rated at 45 KV each. The primary voltage is approximately 260 volts at the inlet field and 200 at the outlet field. The primary current is approximately 52.0 amps at the inlet field and 34 amps at the outlet field. The secondary voltage and 3-12 198 �currents average 34.0 KV, 35 ma and 29.0 KV, 80 ma at the Inlet and outlet fields respectively. The spark rate averages around 120 per minute at the inlet field and 145 per minute at the outlet field. TABLE 3-5. PERFORMANCE CHARACTERISTICS OF THE AMERICAN STANDARD ESP Performance at 385,000 Ib/hr load, coal fuel Gas to ESP cfm Gas to ESP, Ib/hr Gas Temp °F 167,000 510,000 300 Inlet dust loading, gr/cf Outlet dust loading, gr/cf Efficiency, % Gas velocity, fpm Pressure drop, in, H20 Time of gas contact, sec. 3-13 199 3.7 0.074 98 266 0.5 2.94 �4. SAMPLING LOCATIONS All sampling locations are identified in Table 4-1 Figure 4-2 is a cross sectional schematic depicting the tions at the stack. Figure 4-3 is a horizontal view of ing port locations, and Figure 4-4 is a cross sectional let depicting the traverse point locations. and Figure 4-1. traverse point locathe ESP inlet showview of the ESP in- The continuous monitoring probe was located on the North side of the ESP inlet duct prior to the gas sampling ports and at a depth of approximately 4 feet. At the stack,the monitoring probe was alternated between ports 2 and 3 and at a depth of 4 feet. These two ports were also used for the gas sampling trains. TABLE 4-1. SAMPLING LOCATIONS Solid Sample Locations 1 - Blended Coal 2 - Refuse Derived Fuel 3 - Bottom Ash 4 - Fly Ash Gaseous Sampling Locations 5 - ESP Inlet 6 - Stack 10 - Hi Volume Ambient Air Sampler Liquid Sample Locations 7 - Untreated Well Water 8 - Seal Uater 9 - Cooling Tower Water 4-1 200 �BOILER FEED PUMP SPRAY WATER DESUPERHEATER FBIiUWATKK FIRST STAGE PRESSURE 1LNTEGRATOR STEAM JET AIR EJECTOR COAL TEMPERATURE [FEED WATER IN GRAVIMETRIC SCALE BLEED STEAM- FEED WATER HEATER FEED WATER HEATER O COMBUSTION ENGINEERING STEAM GENERATOR .£> I i- ro TEMPERATURE FLUE GAS IN INDUCED DRAFT FAN AIR HEATER LEAKAGE AT1JVS BIN REFUSE DERIVED FUEL STACK (6 SAMPLI > UNTREATED -WELL WATER PULVERIZER N> O1 __J VOLUMETRIC FLOW DENSITY COOLING TOWER BIX)WDO«JN AMBIENT AIR OVERGRATE (RDF ONLY) Unit NO. 7 ELECTROSTATIC PRECIPITATOR TEMPERATURE AIR IN FLY ASH FORCED DRAFT FAM UNDERGRATE AIR ( (RDF ONLY) SEAL WATER TEMPERATURE AIR OUT PRIMARY AIR TO PULVERIZER BOTTOM ASH COMBUSTION AIR HI VOLUME SAMPLER Source: Compliance test report data prepared by Iowa State University Engineering Research Institute personnel under the direction of Dr. J. L. Hall, et al. from tests conducted during Sept. 1978. Figure 4-1. Unit 7 flow diagran and measurement locations. �SAMPLING PLATFORM T * 't' • 4.0 ft 1 i f i t ' " I ,, A in. PORT •CAPPED WHEN NOT SAMPLING '',<,>!,>' ,'>; r ' , >, "> |66 —.0 CONCRETE WALL NOT TO SCALE SAMPLING POINTS TRAVERSE DISTANCE FROM POINT OUTSIDE EDGE OF STACK NUMBER CM IN POINT DISTANCE FROM OUTSIDE EDGE OF STACK CM IN 1 38.2 97.03 5 59.4 150.88 2 42.8 108.71 6 66.4 168.66 3 47.8 121.41 7 75. 190.75 4 53.2 135.13 8 87.8 223.01 Figure 4-2. Cross Section of stack showing traverse point locations, 202 4-3 �Figure 4-3. Inl«t Duct - Showing Port Locations 4-4 203 �CONTINUOUS MONITORING PROBES Traverse Point Number Traverse Point Location From Outside of Nipple Centimeters Inches 1 22 53.9 2 34 83.3 46 112.7 58 142.1 Figure 4-4. Inlet Traverse Point Locations 4-5 204 �5,0 SAMPLING This section includes information on the sampling program conducted at the Ames facility. Any changes or pertinent comments are included in this section. 5.1 Gas Sampling The flue gas sampling at the Ames facility was performed at the electrostatic precipitator inlet and at the stack. Sampling for organics was to be performed for fourteen consecutive days with an additional three days sampling for particulate cadmium. However, due to extreme weather conditions the program was modified to collect nine inlet and outlet gas samples. Sampling for organics was accomplished concurrently at the inlet and outlet utilizing two modified method 5 trains (Figures 5-1 and 5-2) at both sampling locations. Inorganic cadmium was only sampled at the stack and utilized one standard Method 5 train, Figure 5-3. The sampling crew collected a ten m (10 + 1 m ) sample by extracting the flue gas at a rate approximating the flue gas velocity. The particulate matter was collected in a cyclone and on the filter media. The gas stream was passed through an XAD-2 resin trap to absorb the organic constituents, and through an impinger system to condense any moisture present in the gas. Parameters such as temperatures, pressures, and gas volumes were monitored throughout the sampling period. The sample fractions were recovered from the sampling trains and turned over to an MRI representative. The outlet (stack) sampling position was sampled with no change to the sampling plan while the ESP inlet sampling was modified. • ESP Inlet During the initial tests, it was found that the outermost ports exhibited little or no flow. At one point of the traverse, the velocity head (AP) was negative while the next point indicated positive AP, thereby cancelling each other. It was therefore recommended that these two outer ports be dropped from the test. The recommendation was accepted and implemented as part of the test program. 5-1 205 �FILTER HOUSING HEATED LINE THERMDncTER CYCLONE FLASK t-o O o> cn i ro OVEN BOX STAND BY-PASS VAL\€ ORIFICE THERMOMETERS VACULM GAUGE R9 NAIN VALVE D.RY TtST Figure 5-1. \. AIR TIGHT PU1P ESP inlet sampling train VACUUM LINE �xX"'FILTER HOUSING THERH3T€TER CYCLONE FLASK OVEN BOX STAND BY-PASS VALVE ORIFICE THERMDMETERS VACUUM GAUGE \ DRY TEST • fHTER AIR TIGHT PIMP Figure 5-2. Stack sampling train 5-3 207 VACULM LINE �12 Figure 5-3. EPA Method 5 particulate sampling train 1) 2) 3) 4) 5) 6) 7) 8) 9) 10) 11) 12) Calibrated nozzle Glass lined probe Flexible teflon sample line Cyclone Filter holder " Heated box Ice bath Impinger (water) Impinger (water) Impinger (empty) Impinger (silica gel) Thermometer 5-4 208 13) 14) 15) 16) 17) 18) 19) 20) 21) 22) 23) 24) Check value Vacuum line Vacuum gauge Main value Air tight pump Bypass value . Dry test meter Orifice Pitot manometer Potentiometer Orifice manometer S type pi tot tube �5.2 Solid Sampling During each test day, four solid streams: coal, precipitator ash, bottom ash, and refuse derived fuel (RDF) were sampled six times per day following a schedule set up by Research Triangle Institute (RTI). The sampling was coordinated between RTI, the sampling crew and power plant personnel. The schedule provided the basis for collection of unbiased samples by obtaining a random selection from the multiple sources available for sampling. This approach was taken to avoid any cyclic biases which might have been present in the daily operation of the power plant. The samples and their sampling frequencies were: • The coal samples were taken from the feed line leading from the storage bunkers into the gravimetric feeders supplying the coal pulverizers. A metal scoop was used to remove the sample from the feed line and transfer it to the sample containers. • The precipitator ash was removed and collected from the bottom of the precipitator hoppers. A metal scoop was used to remove the sample from the access pipe and transfer it to the sample container. The hoppers were pneumatically evacuated after each sample was taken. A visual inspection was made to insure complete evacuation of ash from the hoppers. • The bottom ash samples were collected from the base of the furnace. These samples were collected wet with a high solids content from the furnace floor prior to sluicing out the ash by plant personnel. The ash doors were open during the washing procedure and the ash sample was scooped up in a teflon line pan and transferred to the sample container with teflon lined forceps before the furnace floor was washed with water to remove the ash. To provide representative samples of ash, as distributed over the entire rectangular base of the furnace, the area of the furnace floor was divided into an equal-area grid system. The samples were scooped from a specific grid area as provided by Research Triangle Institute each time a sample was taken. • The RDF samples were taken from the feeders in the Atlas bin prior to being pneumatically conveyed to the boiler furnace for firing. The material was placed into sample containers from a specific feeder and returned to the recovery area for labeling. Protective clothing was worn within the feeder area and plant personnel were notified when entering and leaving the area. 5.3 Liquid Sampling Three liquid streams were sampled during the course of the test program: cooling tower blowdown, well water, and bottom ash seal water (overflow water). Liquid streams which did not have continuous flows, were 5-5 209 �allowed to purge for three minutes prior to obtaining samples. Sample containers were rinsed three times with sample liquid prior to being filled with that liquid. The streams sampled and frequency of sampling were as follows: • Seal water was sampled twice per shift, for a total of six samples per 24 hour period. • Cooling tower blowdown was sampled once per day. • Three well water samples were collected over the testing period. Appendix C contains the time frequency schedule utilized by members of the solid and liquid sampling team. 5.4 Hi Volume Sampler To monitor the ambient air background, a high volume ambient air sampler (Figure 5-4) was used. It was placed on the roof of the Ames facility to obtain a representative background utilizing outside ambient air rather than sampling air inside the building that could have been contaminated or influenced by the combustion process. 5.5 Quality Assurance A quality assurance sample was also taken of the final test day. To collect the quality assurance sample, two sampling trains were placed at the same point in the same port at the inlet of the ESP. No traversing was performed. Both trains were run at the same isokinetic rate for the same duration as a normal test day. Also during the Q/A day, solids and liquids were collected as in a normal test day. 5.6 Sampling Train Background To obtain the train background (blank) an entire sampling train, including resin trap filter and impinger solutions was set up at the ESP inlet. The train was taken to normal operating temperatures and allowed to remain at these temperatures for one (1) hour. All train components were recovered as a normal run and all sample blanks were given to an MRI representative. 5-6 210 �HIGH VOLUME AIR SAMPLER FLOW PROBE \MODEL 230 HIGH VOLUME CASCADE IMPACTOR - OPTIONAL MANOMETER OR ROTAMETE: MODEL 310/310A/310B CONSTANT FLOW CONTROLLEF \ FLOW [ADJUSTMENT LINE CORD Figure 5-4. Ambient air sampler 5-7 211 �5.7 Sample Recovery Upon completion of the ESP and stack sampling, the sampling equipment was brought to the laboratory area for recovery. Each sample train was kept in a separate area to prevent sample mixup and cross contamination. The dry powder in the cyclone, probe, and heated flexline was collected in the cyclone catch bottle. After this collection procedure, the individual sample train components were recovered per the following: • Probe was wiped to remove all external particulate matter near probe ends. • Filters were removed from their housings and placed in proper container. • After recovering dry particulate from the nozzle, probe, heated teflon line, cyclone, and flask, these parts were rinsed with distilled water to remove remaining particulate. They were subsequently rinsed with B & J acetone and cyclohexane and put into a separate container. All rinses were retained in an amber glass container. • Sorbent traps were removed from the train, capped with glass plugs, and given to an on-site Midwest Research Institute (MRI) representative. • Condensing coil, if separate from the sorbent trap, and the connecting glassware to the first impinger was rinsed into the condensate catch (first impinger). t First and second impingers were measured, volume recorded and retained in an amber glass storage bottle. The impingers were then rinsed with small amounts of distilled water, acetone and cyclohexane. These rinsings were combined with the condensate catch. Rinse volumes were also recorded . • Third and fourth impingers were measured, volume recorded and solutions discarded. • Silica gel was weighed, weight gain recorded and regenerated for further use. To preserve sample integrity, all glass containers were amber glass, with Teflon-lined lids. 5.8 Problems Encountered During Recovery t If the temperature of the probe, flexline, or oven box was not sufficient (4 250°F) to prevent moisture from condensing, the particulate would cake on the inner walls and become very difficult to remove. 5-8 212 �• Due to the cyclohexane not readily evaporating and adhering to the inner walls, the flex lines and probe liners gave the appearance of being clean when in reality they were still wet and masked any particulate that remained on the walls. Therefore, all components must be thoroughly dry before a visual inspection can be made. If the initial rinses do not remove all the particulate, then brushing with additional water rinses is required to clean the walls. This is then followed with acetone and cyclohexane rinses. 5-9 213 �6,0 CALIBRATION This section describes the calibration procedures used prior to conducting the field test at Ames Municipal Power. tion equipment and how it was set up. 6.1 Figure 6-1 shows the calibra- Method Five Calibration Data 6.1.1 Orifice meter calibration. The orifice meter calibration is performed using a pump and metering system as illustrated in Figure 6-1(a). The dry gas meter with attached critical orifice is run at various orifice flows for a known time. After each run the volume of the dry gas meter, meter inlet/outlet temperatures, time, and orifice setting is recorded. The orifice meter calibration factor is derived by solving the equation. Aura Am? " 0.317 A H Pb (T d + 460) r (Tw L + 460) 6n2 V w ~ ^ J where AH = Average pressure drop across the orifice meter, inches Pb = Barometric pressure, inches Mercury Tj = Temperature of the dry gas meter, °F Tw - Temperature of the wet test meter, °F 0 = Times, minutes Vw s Volume of wet test meter, cubic feet The AH@ yielded is utilized to adjust the sampling train flow rate by regulating the orifice flow. 6.1.2 Dry gas meter calibration. Meter box calibration consists of checking the dry gas meter for accuracy. The dry gas meter with attached critical orifice is connected to a wet test meter (see Figure 6-1 (b) below) and run at various orifice flows for a known time. After each run wet and dry gas meter volumes, temperatures, time, and orifice readings are recorded. Utilizing the equation v _ Vw Pb (Td+460) " Vd (Pb+AH) (TW + 460) 6-1 214 �where V = Volume correction factor Vw a Volume of wet test meter, cubic feet Pb * Barometric pressure, inches Mercury Td s Temperature dry gas meter, °F Vd = Volume of dry gas meter, cubic feet AH a Average pressure drop across the orifice meter, inches H20 T. = Temperature of wet test meter, °F w a volume factor which compares the dry gas meter with the wet test meter is obtained. * 6.1.3 P1tot tube calibration. Pi tot tubes are calibrated on a routine basis utilizing two methods. The type S pi tot tube specifications are illustrated and outlined in the Federal Register, Standards of Performance for New Stationary Sources, [40 CFR Part 60], Reference Method 2 (refer to Figure 6-1(c)). When measurment of pitot openings and alignment verify proper configuration, a coefficient value of 0.84 is assigned to the pitot tube. If the measurements do not meet the requirements as outlined in the Federal Register, a calibration is then performed by comparing the S type pitot tube with a standard pitot tube (known coefficient of 1.0). Under identical conditions, values of AP, for both S type and standard pitot tube are recorded using various velocity flows (14 fps to 60 fps). The pitot tube calibration coefficient is determined utilizing the following equation, Pitot Tube Calibration = (Standard Pitot Tube XrAP reading of std. pitot j 1/2 -, L Factor (CP) Coefficient) AP reading of S type pitot The coefficient assigned to the pitot tube is the average of calculated values over the various velocity ranges. 6-2 215 �6.1.4 Nozzle diameters. The nozzle diameters were calibrated with the use of a vernier caliper if the nozzle showed excessive wear or was considered not fit for use, it was discarded. 6.2 Instrument Calibration Manufacturers recommended calibration procedures were used with the following gases which had an analytical accuracy of +_ 1%: SCOTT CO 812 ppm C02 11.94% 02 4.98% Propane 34.4 ppm in Nitrogen Balance Zero and Calibration adjustment were made prior to the start of the test day. Zero drift checks were made at the end of each test period. Data was recorded every fifteen minutes thus providing two data points per hour for each sampling position. 6-3 216 �r,r* Central Vi*t» \remeftiurt 7. flnf Control Vat** Come Coni'fi Vj vi\ lunptnlun T, I Tt.Tpcniv't T. OfUe* in '•?• '.H WMTtalMdff Figure 6-1(a) Orifice meter calibration XiV-r;.;-!f Pump CXi C* Uc«r Uignchstie Gtuft Figure 6-1(b) Dry gas meter calibration. X* TopYtiw Figure 6-1(c) Equipment used to calibrate pi tot tubes Figure 6-1. Calibration equipment set-up procedures 6-4 217 �7,0 TECHNICAL PROBLEMS AND RECOMMENDATIONS This section describes some of the problems encountered during the Ames test program and recommends a solution to these problems, 7.1 Problems • Construction of weather shelters was not completed on schedule causing a one day delay, • Because of extreme cold weather additional heaters had to be supplied to both the stack and monitoring truck. This resulted rn additional power requirements and caused approximately a half day down time for installation of power switches. • Cpld weather also effected the following: 11 heat lines did not maintain temperature causing moisture to condense and possibly act as a scrubber for hydrocarbons. Therefore, hydrocarbon data are considered only fair. 21 The gas conditioner would freeze restricting sample gas flow to the monitoring equipment. This created data gaps during the test period, 31 Solutions in the sampling trains would freeze causing the test to be shortened or scrubbed. 4). Cyclohexane would freeze at the temperatures encountered at the sampling locations because it has a freezing point higher than water, • Three instruments malfunctioned due to electronics failure or change. These instruments were: 11. Infrared Industries C0/C02 analyzer. The CO section would not maintain calibration and was removed from the system. It was replaced with the Beckman CO analyzer. 2} Beckman 0« analyzer. Detector malfunctioned and was replaced with backup Og analyzer. 3). Beckman CO.Analyzer. Energy source went out of adjustment and could not maintain calibration. No other replacement was_available, as a result, 2 days of CO data were not recorded. 7.2 Recommendations The only significant problems that occurred at the Ames facility were caused by severe weather conditions. In the future, the testing should preferably take place in a warmer environment, during the warmer time of the year or heated constant temperature shelters should be provided. 7-1 218 �MUCCSS OATA «JKS MUIIICIPAI pout* PLAIIT uUlT mfl. 7 •Not based on 24 hr daU Oat* 3-2-80 Tin* W IA I2N 2* 3A 4A SA 6A 7A 25 Srois Net 9A IOA 2t 24 28 23.1 11A 12N IP 29 30 30 4P 2P 3P SP 29.S 27.2 29 ' 29 26. » 26.6 6P 7P 8P 23S 21S 210 208 Siena pressure pslg 8SS •SO 858 Steam temperature F 900 B9S 895 FeedMter flM rate 1000 's Ibs/hr 250 232 lOf IIP 34 33 30 38.19* 2.«* 26.25* 310 310 312 270 2S2.2 36.49 860 4.16 26.1 26.6 27.6 27.6 220 240 2SO 260 26S 270 27S 260 260 260 280 310 ISS 860 8SS 860 860 860 860 860 860 850 860 860 860 860 860 890 89S 89S 910 910 900 890 910 90S 910 910 910 90S 900 900 -900 22S 220 220 205 230 240 250 270 27S 280 270 26S 26S 275 290 320 322 360 360 370 370 370 37S 36S 370 370 28 27. S 27. S 26 27 29 33. S 33 34 34 32 33 33 33. S 36 38. S 38.6 8SS 850 900 860 220 20S 28. S 27. S 9 34 I9S 208 Mean 35 201 222 Feedwater temp F 19.6 Fuel feed rate (coal) 32 1000's Ibs/hr 37831.4 76454.1 Fuel gauge readings 5788.7 gals/hr Fuel oil •Of 9P 32 29.5 27.1 350 Steam (loo rate 1000' s Ibs/hr VO 8A •60 860 •57.7 900 882 899 899.63 8. S3 330 320 289 261.17 37.94 366* 86S 7.38* 37. S 33.6 38.8 Coal Oil 7.07 4 '6 bcess air 1 18 20 22 22 25 21 21 28 22. S 20 21 22 22 24 24 22. S 22 21 23 20 19 24 23 '21 22 2.1 I.D. Fans amps 45 45 45 46 46 45 45 46 45 4S 46 47 47 47 47 47 47 47 47 48 48 48 48 47 46.42 1.1 29 30 30 29 30 29 29 29 30 30 30 30 30 30 30 30 30 30 32 32 32 33 32 31 30.29 psig FO Fans amps 1.12 0.77 Furnace draft pslg 0.4 0.4 0.3 0.15 0.8 0.65 O.M Ambient temp °F 8 8 Ambient pressure inches Hg 29.54 29.52 29.SI Comments 8 1 7 29.87 29.47 7 7 29.46 29.44 S 0.7 0.7 O.S 0.8 O.S 0.7 0.8 0.6 0.6 0.7 63S 300 0.3 Flue MS boiler e»lt Temp *F ESP Inlet 640 320 640 320 640 320 645 320 660 320 660 320 660 320 640 32S 12 18 19 22 23. S 26 29.36 29.31 29 25 9 29.41 29.4 29.39 29.38 29.38 Soot Blog •attorn Ash Removal and FU Ash Removal Start Finish - 2.30A, 6.00A. 9.48*. 2.12P. 6.0SP. 10. ISP 0.7 0.6 O.S 0.7 650 320 .ISP 26 27 26 23 22 19 29.24 29.2 29.19 29.1S 29.14 29. IS 29.13 RDF Density Mo «OF Fired 19 O.SS 0.60 8.20 647* 318. S* 0.98 9.78* 6.69* 1 1 18 It .06 7.S8 29.12 29.11 29.34 0.18 �PROCESS DATA AMES MUNICIPAL POhO P1ANT Mill NO. 7 •Not based M 24 kr data Oate 3-3-80 Tlae MM Gross Met 12N 1A 2A 3A 4A SA 6A 7A IA M IDA ' 14.75 12.15 IS 12.5 15 12.4 34.25 31.65 11A IP 2P 3P 4P 5P 34.5 12.0 IS 12.5 35 12.4 35 12.6 34.5 12.0 34.5 32.0 12N 7P BP » 10P UP Mean 35 32.5 15 12.6 15 32 .« 15 12.6 M 11.5 31 28.6 30.1 12.04* o.«* 100 271 268.8 71.48 6P a 7.11 29 12 1 1 18 18.5 18.5 27 29 Steaa flew rate 1000* s Ibs/hr 240 95 ISO 155 155 155 240 265 120 10 1 315 315 116 10 1 11 1 120 118 310 15 1 115 US 115 Steaa pressure pslg 860 850 ISO ISO 850 ISO 860 850 850 855 855 860 855 850 850 ISO 145 ISO BSD 855 850 855 865 850 852.71 4.66 Steaa teaperaUre °f 195 820 820 900 89S 890 885 900 900 910 900 910 900 900 900 910 910 900 900 900 890 882 880 865 890.1 24.01 FeedMter MOD rate 1000' s Ibs/hr 255 160 240 270 335 130 330 325 320 320 310 320 315 120 320 325 126 325 328 114 278.18 71.65 180 380 180 310 180 380 IBS US 185 380 380 180 180 HO 180 378 180.81 2.14 21. S 32.7 33.0 39 39 38.5 40 36 16.5 34.0 13.0 3S.O 35.0 16.1 36.9 1 34.7 34.5 11.6 12.0 Coal Oil 31.93 31.69 4.6 7.32 14 16 20 16 22.08 1.21 45 45.75 2.15 1.40 108 16S 160 160 Fuel feed rate (coal) 1000' s Ibs/kr Fuel gauge reading RDF 10.5 10.5 18215.9 76M2.1 5716.1 21.6 21.1 21.5 Excess air t 21 33 Feedxater teap °F 39 36 36 1 1 18 SysUa 1 dm 3. 24P m Systea 1 on 1.,47P Systea A started 10.S1A System 1 started11.10P No RDF IB 19 24 22 18 17.5 20 17.5 20 27 15 IS 10 I.D. fans aaps 46 39 43 41 43 43 46 47 48 48 47 47 47 47 47 48 48 46 46 46 46 46 46 1.0. fans pressure pslg 5.5 2.5 3.0 3.6 3.6 3.6 5.0 5.0 6.7 7.0 6.5 7.0 6.5 7.0 7.0 7.0 7.0 6.0 6.0 6.2 6.4 6.3 6.5 6.9 5.67 27 30 30 32 32 31 32 30 10 10 31 32 30 31 30 31 11 10 30 29.91 F.O. fans aaps 31 26 27 27 27 F.O, fans pressure 4 II . 2.1 2.2 2.5 0.7 0.6 0.61 0.55 0.6 Furnace draft psl9 0.6 0.9 0.51 O.S 0.55 0.4 0.7 0.6 0.65 0.3 O.S 0.65 0.6 700 0.59 0.11 700 688* 17. SI* 0.5 0.65 0.7 0.55 0.5 0.7 700 Flue gas teaperature OF 700 710 660 660 680 680 690 24 31 36 37 31 39 41 42 42 27.19* 10.39* 28.85 28.81 28.8 28.8 21.76 28.75 28.75 28.76 28.8** 0.11* Aablent teaperature 17 17 17 1 1 18 1 1 19 19 20 Aabtent pressure inckes Hg 29.09 29.05 29.01 29.00 28.98 28.95 28.91 28.91 28.91 28.86 Coaaents 1.79 1.13 nt? wWP- tatl Start - 1 WYlOP Flnlsk - 2.2SA. 6.0SA, 10.0OA. 2.4SP. 6.05P. 10.40P * Start - 12.5M. 10*05A. 9.SSP RDF Density - 5 Ibs/cu ft �PMCESS MTA AMES MMICIPAl POMM HJUH UN IT «0. 7_ •tot ktsed ea f 4 kr dlti Oete 3-4-M 12H TbM 1A 2A M 4A 5A 6A 7A 8A 9A 15.5 1S.S 35.5 27 25 21 23 23 23 23 26 21.2 21.1 21.1 21.2 21.2 24.1 26.7 31 31 Steia flow rite 1000' s Iks/kr 235 190 190 190 190 190 235 ZIZ 125 Steui pressure psij 850 840 •40 •SO •45 855 MS 845 Steia t overture °f MO MS •80 IBS 865 880 MS 900 feedwtter flow rite 1000'i los/kr 250 202 201 201 205 205 238 280 26.6 22.6 23.0 22.0 21.0 20.2 27.5 33.5 M 10 FeedMter Uap °F NJ 11A 12» IP 2P IP Fuel feed rite (coil) 1000 's Iks/kr Fuel gtuge readings fillons/kr fuel all RBF 35.5 11.0 35.0 12.5 35.5 32.9 IS 1 1 35.0 12.5 320 125 120 125 120 860 850 855 845 •55 910 900 90S 900 900 130 305 325 380 Gross Net o 10A 380 34.5 36.0 4P SP . 6P 7P •P 9P 35.0 35.0 12.6 1S.O 12.6 15.0 12.6 35.0 32.5 12 10P IIP Hem 29.7 5.19 4.93 320 280 2M.U S6.S9 •SS ISS 865 150.63 5.95 •90 900 MS 191.46 14.63 340 332 330 285 290.79 52.98 400 400 400 390 380 389.7 7.63 35. 2 34.6 34.3 35.3 35. 1 30.5 Coil 31.03 31. H 2.9 5.37 15.0 12.5 325 325 330 125 325 325 130 125 850 850 845 •SS •SO 850 ISO •55 900 90S 900 90S 900' 895 895 945 140 32S 325 330 330 325 115 330 330 385 390 390 380 390 385 390 395 400 34.0 34.0 34.0 34.0 34.5 34.5 33.0 14.0 32. SS 12. S 11590.7 77221.1 $7(7.9 on On Excess llr S 19 25 22 20 26 22 20 IS 20 18 23 22 19 20 10 18 20 23 19 1.0. fin taps 45 43 43 41 43 43 45 46 47 47 48 47 47 47 47 47 47 47 47 1.0. fins pressure a 4 .9 . 29 28 FO fins pressure psfo, « • 1C Furnice drift pslg 0.5 0.4 27 27 27 31 4* 31 19 20 19 20 20.11 2.35 48 47 46 46.04 1.76 t.•« ij 1 28 28 temper Jture 0.2 0.1 0.8 0.9 0.6 O.S 30 30 10 30 30 30 31 31 31 30 30 30 29 28 28 lotto• Ask ind Fly Ask »anvil i Stirt - 1.30A. 5.30A. 9.30A. 1.30P. 5.30P. 9.30P Flnisk - 2.0SA. 6.10A. 10.00*. 2.10P. 6.OOP. 10.2SP 0.6 0.7 0.65 O.S 0.6 0.6 0.5 0.6 0.6 680 340 700 340 670 340 680 340 680 340 690 140 690 340 695 340 31 30 29.54 11 1 . 11 * 1.41 28 27 27 26 26 26 26 26 25 22 28.84 28.85 28.86 28.86 28.83 28.83 28.11 28.82 28.83 0.6 Soot «««• 18 17 0.72 IS 28.89 21.91 28.94 0.60 12 0.67 0.7 10 9 0.515 0.15 617* 341* 0.7 695 340 28.84 32 O.S 690 350 Aaklent pressure tnckes Hj Coanents 30 31 .3 0 .7ft /• Flue gis teap „ taller °F ESP Inlet °F feblent 30 31 C 3 .£ •> f| 28 19 47 « FO fins laps Of . 31.51 21.25 3S.S 33.0 9.19* 1.16* 24.08 6.81 21.96 ». 91 28.99 28.88- 1 0.06* �PROCESS MTA AJCS MUNICIPAL mat PUNT UNIT NO. 7 . Dite 3-5-80 •Not Used an 24 kr d>u Tl«e 12H M 2A 29 26.8 26.5 24.6 26 23.9 22 20 21. S 22 19.S 22.1 Stean fl<M r«te 1000' t Ibs/hr 260 245 225 185 186 Steui pressure pstg 85S 840 850 840 850 MM Gross Net 3A 4A SA 6A 11* 12N IP 2P 3P 4P SP <P 7P 8P 9P Keen a 35 32.7 35 32.5 36 32. < 35 32.7 36 32.7 34.6 32.0 35 . 32. T 35 32.7 36 32.7 35 32.6 36 32.7 36 32.5 35 32.6 36 32.7 32 29.7 31.9 29.72 4.76 4.44 320 315 320 315 315 320 315 325 325 320 320 320 322 325 320 300 289.58 48.47 850 850 850 850 845 850 845 855 855 850 850 855 850 850 850 830 848.54 6.61 ' 885 885 900 880 895.6 10.97 340 336 330 307 300.42 46.6 8A 30 28 32 29.7 35 32.6 188 280 29S 850 850 845 9A 5teu tenpertture °F ' 890 890 885 870 900 895 900 910 910 905 900 890 900 906 910 905 • 910 895 265 245 250 200 205 200 290 298 330 330 330 340 330 315 325 330 330 325 330 330 Feedwter to* °F ISJ 880 895 FeedMter flan rite 1000' s Ibs/hr O 10P IOA 7A 390 36S UP 3*0 348 345 345 380 380 400 400 395 395 390 395 395 395 395 395 390 390 390 385 390 375 382.8 17.36 Fuel feed rite (ciul) 29. S 28.9 HMO's Ibs/br 38982.6 Fuel 9tuge readings 775*9.7 (9>no«s/kr) fuel oil 5788.6 RDF 22.5 19.1 23.4 19.5 36.1 37.4 41 40. S 40.5 37 37.8 34 35 33 32 33 33.6 33.9 32.6 33.2 33.2 32.0 Coil 6.09 on 32.46 33.53 2.5 Eicess ilr S 20 20 20 30 28 31 20 16 17 It 18 19 19 21 19 18 18 20 19 19 18 18 19 21 20.17 3.92 10 f«*s ops 46 46 45 45 45 44 48 48 48 48 47 48 47 47 47 47 47 47 47 47 48 47 47 46 46.75 1.11 10 fans press pslg S.S 7 6.7 fO f«HS MpS 29 FD fins press pslg 4.0 Furuce draft pslg 0.5 S.20A •10.20A RDF Destined 28 28 28 28 32 31 32 32 31 32 31 31 31 30 30 30 31 31 32 31 31 31 30.46 1.36 0.7 0.8 0.3 0.8 1.0 0.7 0.45 0.6 0.6 0.65 0.65 0.8 0.7 0.4 0.45 0.6 0.7 0.6 0.7 0.5 0.6 0.45 0.6 0.62 0.164 695 345 700 345 700 345 680 345 690 346 690 345 695 350 700 345 700 345 700 345 695* 345.5* 6.67* 1.58* 1 4 6 7 8 10 12 14 15 15 7.63 5.22 1.06 Flue *»» teaperiture toiler exit ESP Inlet tabieat ta*p DF Acbtent press Inches Hg Coflttnts 1.04 30 2 4 4 2 29.00 29.03 29.04 29.07 29.08 29.10 29.11 29.13 2 2 1 lotto. Ash fnd Fl» As h RoM»il Surt - rioA. 5.30*. 9 30*. 1 JOP. S 30P. 9.30P ' Finis* - 2. ISA. 6.10A. 10.00A. 2. OOP. 6. OOP . 9.S6P 1 15 14 13 12 10 9 29.13 29.22 29.24 29.24 29.24 29.24 29.24 29.22 29.23 29.22 29.22 29.22 29.23 29.23 29.23 29.23 29.17 Soot tlo.il SUrt - , 10A, 7P RDF density - 5 Ibs/cu ft. 5 Ibs/cu ft, 5 Ibs/cu ft 0.08 �PHC£SS MIA AMES nmncipAi POME* PUWT mi IT to. 7 on •lot tased 24 kr diti tote 1-6-80 Ttw NU trass Net 1A 12N 2A 1A 4A SA 6A 24.5 28 22 22 21. S 21. S 7A 8A 1 1 9A 1 .S 1 10A 11A 35 35 1 . 1 1 12.6 32. S 12K IP 35 35 Hal* • 11.5 12.6 12.5 21.6 120 120 120 110 282 279.71 S6.73 850 MS 845 850 850 850 650 855 850 810 836 847.13 7.22 900 890 910 905 • 90S 890 895 •85 BBS wo 880 895.33 11 . 1 130 130 330 130 130 325 130 330 140 10 1 312 290 211.7 54.23 390 395 390 390 310 185 385 190 190 390 180 377.46 21.03 1 1 36.5 38 36 16 16.4 35.6 36.5 15.1 34.0 1. 18 15.18* 12.15 1.53* 305 325 320 120 120 840 •SO 840 840 BIO 848 850 858 855 840 855 855 855 aao aao 890 900 •90 891 890 900 920 900 900 900 900 FeedMtw f lew rite 1000's Ibs/hr 271 200 196 198 204 15 1 230 292 120 315 330 335 Feeduiter tea? °F ' UP 32 12.6 310 SteM t taper* ture °F LO cn 35 120 285 Steu pressure psil rO IS 12.5 12.6 215 171 338 18 1 338 16 1 340 390 380 185 15.5 35 10P 320 12.6 182 390 15 If 32.6 22. S 30.6 180 16 35 M> 120 11.6 181 390 7P 12.5 11.7 IBS 35 6P 12.6 20.1 185 390 SP 115 20.2 255 36.5 4P 120 25.7 14.5 12.1 Fuel feed rite (out) 28.8 19406.3 1000's Ibs/hr 77980.7 Fuel iiy|t re*dl*fi tillMS/hr fuel oil Srti.2 MF 3P 11.17 28.88 21.5 11.7 SUU flou r«te 1000's Ibs/hr NJ o 2r 35 12.5 390 34 14 IS IS Ul i Oil S.5S $.30 1.75 S.40A System 8 off 8 .00AM only 1 conveyor 6.00A SysUB 1 on 9 .flOAN both conveyors on Excess itr X 21 36 30 34 34 12 28 15 17 20 21 18 20 16 19 21 18 20 18 11 20 18 19 19 22.21 10 fins ops 45 44 44 43 44 44 44 46 47 47 47 47 47 47 47 47 48 47 48 47 48 48 46 46 46.17 1.55 * IM A •• U.ta>9 10 fins press psl9 S C .B I .V FurMce drift psil 29 28 28 28 29 28 28 30 30 30 32 30 31 31 31 32 31 •J C 0.5 32 32 32 31 11 10.29 1.41 ta I.K 0.4S 0.8 0.9 0.65 0.8 0.8 0.7 tafcieot tMp "f 9 7 6 Aabtent press Inchts Hg 29.22 21.21 29.17 6 a 10 12 29.14 29.14 29.12 29.11 29.09 | 8otUB Ash iM1 FIvAsI• «e*»v<, t Mf Stirt I.Jo*. ! Finish - 2. ISA. 6.30A. I0.12A. 2.05P. 6. ISP . I1.21P 12 0.6 0.6 0.45 0.45 0.45 0.6 0.4 0.7 690 340 700 340 680 340 680 340 690 340 690 340 690 140 690 340 690 140 13 0.5 0.7 680 140 0.7 Flue 9is tecnp °F toiler eiit ESP inlet CoBiMts 32 31 C FO fins mfi 6.30 16 20 22 25 26 26 29 32 12 30 30 28 27 25 24 11.79 1.19 28.18 28.95 28.94 28.93 28.95 28.95 28.97 28.97 28.97 28.97 21.04 0.015 29.08 29.06 29.06 29.03 At 10.10* ESP hoppers duxn for repilrs 28.91 28.93 Soot 810M Stirt - LISA. 10 O?». 7. IIP 0.51 0.61 0.60 0.62 0.60 5.0 Ibs/cu ft . 4.0 Ibs/cu ft. 4 Ibs/cu ft 0.13 688* 340 •OF density - 0.61 6.32* 0 �PROCESS DATA AMES MUNICIPAL POUEt PLANT UNIT NO. 7 •Not Used on 24 hr diu Dite 3-7-80 I2H Tine Sross 20 Net HU 1A 2A 3A 4A 5A 20. S IS 15 13.2 13.3 6A 9A 7A 8A 26 24 30 27.7 36 33.5 36 10A 36 11A UP X 32.6 3$ 32.5 32 29.6 30.5 7.51 28.24 7.21 IP 2P 3P 4P 5P 6P 7P 8P 9P 3S.S 33.6 33.0 36 31.6 36 33.4 36 33.4 35 32.6 35.5 33.1 35 32.$ 35 32. S 35 32.5 36 Hun a IOP 12N 18.2 20 11.2 18.6 21 19.2 Ste> flow rite 1000's Ibs/hr 170 169 170 177 128 128 210 280 325 330 330 326 330 326 325 325 328 325 325 327 325 320 318 280 274.8 74.1 Steu pressure psls 945 845 850 840 840 850 850 855 855 8S5 860 855 BS5 855 855 850 850 850 840 850 850 850 855 850 850.21 5.21 Stein tanperiture "f 878 890 896 900 910 912 905 885 890 875 880 895 900 891.8 15.19 Feedwater flow rite 1000' s Ibs/hr 178 175 175 336 322 288 286.33 76.82 Feeduiter leap °f MO 340 Fuel feed rate (out) 1000' s Ibs/hr Fuel gauge readings 91! Ions/tor fuel oil 19.0 20 3 9801. S 78357.1 5790.1 Excess lir 1 40 ID fins Mps 43 90S 843 885 885 900 33.5 33.5 340 340 390 395 870 895 900 185 145 135 225 280 335 340 340 340 320 315 355 378 400 400 20 25.5 17. 6 18.8 32.5 35.0 42 42.5 17 47 37 50 50 21 16 20 21 19 18 20 20 20 42 43 44 42 42 46 47 49 49 48 48 48 48 48 7 7 7 42.5 41.5 RDF 905 900 900 340 345 340 340 350 338 340 335 345 395 395 395 390 390 395 385 385 382 385 385 375 373.75 26.6 41.5 37 36 35.5 35.5 35 25.3 25.7 31. 6 34.9 33.6 31.2 Coil Oil 31.65 8.23 33.6 4.2 20 16 20 19 19 19 19 19 19 25.25 11.2 48 48 48 48 48 48 48 47 45 46.46 2.41 7.5 7 7 7.2 7.0 7.2 7.1 6.6 6.0 6.06 32 32 32 31 32 32 32 32 31 30 30.67 1.79 0.71 0.64 0.51 0.70 0.53 0.66 0.63 -12. SOP RDF Restirted ID fins press pstg FD fins mips 28 FD fins press pslg 2.0 Furnlce drift pslg 0.55 1.4 28 28 28 27 28 30 31 32 32 32 32 32 32 5 5 5 5 5 0.6 0.8 0.85 0.6 0.6 0.25 0.55 0.6 0.7 0.7 0.6 0.6 0.7 0.7 0.8 0.6 0.65 700 350 705 350 700 340 705 340 69S 340 695 340 695 340 695 340 700 340 700 340 26 28 28 28 28 30 30 30 29 29 28 28 24.58 4.2* 28.97 28.95 28.91 28.92 28.92 28.92 28.92 28.92 28.91 28.88 28.92 28.97 Flue 915 two °F toiler Kit ESP Inlet Ambient te*f °F 21 21 19 19 19 20 20 20 20 21 22 26 Anbient press Inches Hg 29.02 29.02 29.02 2».02 29.03 29.02 29.01 29.00 29.00 28.99 28.99 29.00 28.99 COMMItS kottOB Ash ind Fly Ash tauvil Stirt - I.JOA, 5.30A. 9.30A. 1.16P. 5. SOP. 9. IOC Stirt - 3:20*. ll"2A. 7,.20P 699* 342« ROf density . 4 IbS/cu ft, 4 Ibs/cu ft 0.12 3.94* 4.22* 0.04* �PROCESS MU AMES MUNICIPAL fOHUL PLANT UNIT W. 1 •Nut based « 24 kr dtu D»U 3-8-80 12* Tine 1A 2A 3A 4A $A 6A 20 18.2 23 21.2 1$ 13.1 1$ 13.1 2P 3P 4P $P 6P 7P 8f 9P IIP Mean 30.$ 28.0 29.$ 27.2 28 2S.7 31 26.7 32 29.5 32.$ 30.2 3$ 32.6 3$ 32.6 33 30.* 32 21.7 31 28.6 27.8$ 25.66 6.01 $.79 124 23$ 260 27$ 28$ 280 27$ 250 240 26$ 280 290 31$ 317 303 278 262 239.33 61.67 850 650 850 83$ 8$$ 8$$ 8$$ 850 850 84$ 850 850 850 8$0 860 8$$ •SO 870 851.05 6.08 8W 890 900 900 90$ 910 870 88$ 89$ 900 910 900 89$ 89$ 900 870 88$ 90$ 893 12.93 13$ 134 130 24$ 270 280 290 29$ 290 270 2$$ 280 29$ 300 328 33$ 318 28$ 280 251.4 62.96 310 30$ 30$ 18.2 2*5 170 16$ 16$ 19$ 12$ 12$ 860 850 84$ 850 850 850 89$ 900 882 900 »00 860 FeedHiter flew rate 1000' s Ibs/hr 2?$ ISO 17$ 17$ 203 Feedmter twp °F ro i IP 121 31.$ 29.2 Steia teMpenture F Ln -vl 11* 32.$ 30.1 Steia pressure pstg O 10A 29.$ 31.$ 27.1 29.2 20 18.2 Stem flOH rite 1000's Ibs/hr N> 9A 27 2$ 20 37$ 340 330 32$ 34$ Sross Net 8A 23.$ 21.7 30.$ 28.3 W 7A • 10P o • 1 17 3* 10 fins MPS 4$ 44 10 fins press pslg $.6 30 21 370 370 370 370 370 380 37$ 380 38$ 38$ 38$ 380 380 370 360.2 25.81 33.0 33.$ 31.0 31.$ 31.$ 30.$ 31.$ 31.0 31.6 33.4 33.2 33.$ 31.3 31.0 CM! 32.03* 1.17* 28.17 $.4 -No KOF 4 AM 01 -9 AM ROF an 3.$ FO fins net 370 34.0 on Excess llr 1 360 32.$ Fuel feed rite (coil) 30.5 40212.$ 1000's Ibs/kr 78752.0 Fuel gauge readings (Ullons/nr fuel all $7*1.1 Mtf 0.56 30 33 $0 $0 $0 21 20 20 19 19 20 21.$ 21 19 18 19 19 19 19 19 19 2$. 48 10.9 42 43 44 42 42 42 47 47 47 47 46 46 46 4$ 46 4$ 46 46 47 4$ 4$ 4$ 4$ 1.72 28 28 28 28 28 28 30 30 30 30 30 30 30 29.$ 30 30 30 30 31 30 30 30 29.44 0.97 $ FurMCe drift pslg 30 4 3 3 3 4.$ $ $.0 4.3 4.$ 4.2 3.7 3.0 3. $4 1.03 0.51 0.$ 0.$$ 0.$ 0.62 0.61 O.S3 0.10 662* 327« 10.33* 8.23* 1.07 0.$ 0.3$ 0.32 0.6 0.6$ 0.64 Flue «as imp °F laller exit ESP Ulet 0.6 0.$ 0.6 0.$ 0.3$ 0.6 O.t$ 0.$ 0.6 0.$ MO 320 0.3 660 330 660 330 670 330 670 340 660 320 660 320 660 320 660 320 680 340 JUbient ten* °F 27 26 26 26 24 24 21 21 20 21 24 26 28 29 31 34 34 3$ 3$ 34 33 33 32 32 28.17 4.99 tafcieat press Inches Hg 28.92 28.92 28.92 28.93 28.93 28.94 28.97 28.96 28.98 29.03 29.04 29.06 29.0$ 29.04 29. 06 29.05 29.07 29.0$ 29.07 29.07 29.0$ 29.0$ 29.07 29.0$ 29.01 0.06 fnnMfnlT Kft finlsk SUrt - Ash Md Fly Ask teaov.l 4.30*. B.JO*. 12.30P. 4.30P. 8.30P 12.$$*. S.IOA. 9.00A, LOOP. 5. OOP. 9. SOP SUrt - S.20*.°ll.30A. 8P RDF density per shift 4 Ibs/cu ft. 3 Ibs/cu ft. 4 Ibs/cu ft �PROCESS MTA /WSMMICIPALPMER PLANT UNIT NO. 7 DatE 3-9-80 •Not based on 24 hr data Tlae tU 1A 2A 3A 4A 5A 6A 7A 8A 9A 28.0 25.4 26.5 24.2 26.0 24.0 25.0 23.1 25.0 23.1 15.0 13.1 15.0 13.2 15.0 13.3 15.0 13.2 25.0 23.0 25.0 23.1 26.0 24.6 247 225 220 215 212 170 122 121 130 212 210 225 12M Gross Net Steaa flan rate 1000's Ibs/hr 10A HA UP Mean a IP 2P 3P 4P 5P 6P 7P 8P 9r 26.5 24.3 27.0 24.7 26.5 24.3 25.5 23.4 16.5 14.5 16.0 IS.O 16.0 14.2 16.0 14.2 16.0 14.2 16.0 14.2 16.0 14.2 16.0 14.2 20.9 18.) 5.31 S.12 230 230 225 220 135 130 131 131 131 135 135 135 178 46.7 12.3 12N 10P Steaa pressure pslg 860 885 890 855 870 865 845 850 850 850 845 850 650 850 845 850 845 845 650 850 850 850 854 895 900 880 885 835 880 690 900 895 900 905 860 895 900 900 900. 900 885 890 895 675 885 885 888 15.5 260 240 235 228 22S 205 125 130 130 220 230 235 240 245 235 230 140 140 142 142 142 146 142 144 181 59.3 Feeduater teap °F O 1 OO 850 880 Feednater flow rate 1000's Ibs/hr rO to O* 840 Steaa teaperature °F 375 360 360 353 350 335 300 300 310 360 360 360 355 360 370 360 320 325 320 320 320 320 310 315 338 24.0 fuel feed rate (coal) 1000's Ibs/hr Fuel gauge readings Fuel oil 33. S 29.5 29.2 24.0 27.5 25. 0 19.1 18.3 17.5 31.0 31.5 31.0 30.7 32.0 30.5 30.5 19.5 19.0 19.3 19.3 19.0 19.8 20.0 19.3 24.8 23.7 6.25 NA NA Oil 405 590 S.75 790815 579 240 4.4SA- RDF -NO RDF Excess air S 20 17 20 25 27 40 >50 >50 >50 26 20 22 28 20 22 22 47 47 46 46 46 43 45 45 34 12.6 ID fans aaps 45 44 44 44 44 42 42 42 43 46 46 46 46 46 45 44 42 42 42 42 42 42 42 42 44 1.6 FD fan aaps 30 28 30 28 28 28 28 28 28 30 30 30 30 30 30 30 25 27 27 27 27 27 27 27 28 1.5 FD fan pressure 4.2 Furnace draft pslg 0.50 0.70 0.70 0.40 0.42 0.65 0.63 0.58 0.70 0.60 0.50 0.60 0.60 0.50 0.40 0.70 0.65 0.65 0.61 0.61 0.60 0.67 0.61 0.62 0.59 0.092 600 640 640 640 650 640 640 640 600 600 629* 20.2* 265 310 320 320 310 320 320 320 280 280 29 30 38 40 43 44 45 45 46 46 46 43 42 26.85 28.84 28.83 28.80 28.80 28.79 28.82 26.81 28.82 28.62 28.82 28.82 teller 1.05 flue gat ESP Inlet teap °F Aabtent teap °F 31 31 30 28 27 26 26 Aablent pressure Inches Kg 29.07 29.05 29.04 29.02 29.01 29.00 28.96 28.94 Comments lot tea and Fli> Ash Re•oval 27 28.69 28.88 SOOt BlOMI SUrt 4.30A. 11.SO*. 8.03P ROF density - 4.0 tbs/cu ft 305- 40 21.1* 3) 38 37 7.5 28.81 28.78 28.69 O.D97 �PROCESS MIA AMES MMICtMl POME* PLANT UNIT NO. 7 Date 3-10-4)0 •mil based M 24 ar data Tlae MM I2M Sross 1A lf.0 14.0 135 Net Steaa flow rate 1000- « Ibs/fcr U.O 2A ' 3A 14.0 li.O 14.1 U.O 135 137 4A 15.0 16.0 14.1 134 134 5A 6A 7A 8A 9A 10A IP 2P 3> 4P 16.0 14.1 U.O 14.2 2».0 26.6 33.5 30.* 35.0 32.3 35.0 32.1 35.0 32.3 15.0 12.4 35.0 12.4 35.0 32.3 35.0 32.3 15.0 32.1 li.O 32.1 35.0 32.1 130 130 250 310 320 310 310 310 310 310 310 300 310 11A 12N 5P 6P 8I> 9P 35.0 12.1 35.0 32.4 15.0 32.2 35.0 12.1 35.0 12.4 29.1 a.; 8.77 8.43 305 305 311 11 1 307 270 254 80.2 9.1 7P 10P UP Mean • Steaa pressure psli 850 850 ISO 850 850 850 860 835 860 860 860 860 865 860 860 845 855 855 850 855 862 845 825 853 •93 880 891 888 IBS 880 882 900 898 902 90S 904 870 885 902 900 890 904 890 900 895 895 900 860 892 11.5 Feeduater flow rate 1000' i Ibs/kr 144 14S 14S 134 140 146 140 235 320 320 325 325 330 325 320 320 325 320 320 320 320 325 330 300 266 83.1 Feeduater teap °F rO N> •SO Steaa teaperatura °F 315 315 315 310 308 305 340 380 390 3*0 390 390 390 390 390 390 390 380 380 380 380 380 380 M2 34.9 Fuel feet rate (CM!) 1000' s Ibs/kr Fuel gauoe readings 19.5 20.0 20.0 17.1 14.5 25.7 37.0 38.0 38.0 38.5 36.5 37.0 37.0 36.5 32.0 33.0 33.6 34.1 34.0 33.0 35.8 31.9 9.03 Coal on 28.8 11.2 4.17 Fuel oil 310 19.6 17.0 40* 538 713 541 S7»l§0 ao RDF RDF- M M -Start ROF at 3.I2P Excess air I 44 4* 42 46 44 42 43 16 18 16 16 It 16 16 17 14 16 16 17 17 17 17 17 17 24 12.9 10 fans aaps 42 42 42 42 42 41 41 46 47 47 48 48 47 47 48 46 46 46 46 47 47 47 47 45 45 2.5 t.O 6.0 6.5 6.0 6.0 6.0 6.5 6.5 6.0 6.1 6.2 6.7 7.6 5.9 5.4 1.32 28 28 28 28 27 27 30 30 30 30 30 30 30 30 30 30 30 30 31 31 30 32 30 30 1.3 0.40 0.65 O.S7 0.60 0.65 0.65 0.55 0.60 0.65 0.60 0.60 0.60 0.65 0.60 0.55 0.55 0.61 0.55 0.55 0.65 680 690 690 690 680 680 680 680 690 690 10 fans pressure pslg 3.6 FO fins aaps 28 FO fan pressure psti 2.3 Furnace draft psig 0.60 1.18 0.43 0.58 •0.60 •oiler flue (as teap 340 340 340 340 340 340 340 340 340 36 36 36 38 38 38 38 33 26 23 22 21 21 21 22 22 22 22 22 Aabient pressure Inckes Hg 2S.74 28.72 28.70 28.6) 28.68 28.69 28.69 28.67 28.74 28.79 28.87 28.94 28.97 29.02 28.90 29.02 29.05 29.06 29.13 29.15 29.16 29.17 Cnaaentt aottoa an* Flf Ask Reao»al Start - 12. MA, 4.30A. I.30P. 4.27P. 8.10P FUtsk - 12.50A. 5.00A. 4.1W. 5.42P. lO.JOf Soat How* Surt • 4^6A. 11. lo»- i OOP ROF density • 4.0 Ibs/cu ft 21 20 5.3« 340* 340 35 0.036 685* Aafctent leap °F ESP Inlet taw *F 0.60 0.0* 27 20 19 29.18 29.19 28.91 7.5 0.195 �PROCESS DATA AMES NMICIPAL POME»PUU(T UNIT NO. 7 ant 3-ii-ao •Not based on 24 hr data lime 12H 1A 2A 3A 4A Gross Net 30.0 27.5 22.0 19.8 21.0 19.0 20.6 18.5 20.5 18.5 Stew flow rtte 1000' s Ibs/hr 260 200 170 171 Stet* pressure pslg 845 855 850 Stew temperature °F 900 870 880 Feedwtter flow rtte 1000' s Ibs/hr 276 230 Feeduater te»p "f 370 360 Fuel feed rtte (cotl) 1000' s Ibs/hr Fuel gauge retdlngs 29.1 21.5 HI o 1 «J 0 Fuel oil ROT 5A 6A 7A 8A 9A 10A 20.5 18.4 20.5 18.5 30.0 27.5 34.0 31.4 35.0 32.2 35.0 32.4 171 170 170 260 305 310 315 320 850 860 840 855 865 850 850 855 885 893 aao aao 900 910 900 910 185 185 185 194 185 272 315 330 325 330 330 330 330 330 360 380 390 390 15.6 16.5 18.0 17.0 25.0 34.5 35.0 36.5 18.5 IP 2P 3P 4P 5P 6P 7P 8P 9P 10P UP 35.0 32.3 35.0 32.4 35.0 32.4 35.0 32.6 35.0 32.5 35.0 32.4 35.0 32.4 35.0 32.4 35.0 32.3 35.0 32.4 31.0 18.4 30.8 28.0 6.10 6.20 320 320 315 315 320 320 320 328 325 330 325 290 277 62.8 855 855 855 855 855 855 855 860 860 860 870 860 860 855 6.24 905 890 885 906 900 900 895 905 900 900 890 880 880 894 11.2 330 330 338 325 330 330 330 330 330 330 330 325 300 277 78.5 390 390 385 390 390 390 390 385 385 385 385 385 380 372 23.6 35.0 34.0 33.0 33.0 32.5 32.8 33.0 33.0 33.0 33.0 30.8 Coal 21.1 30.3 7.08 11A 12N 35.0 35.0 32.3 32.4 35.0 34.0 on 412 375 797 281 579 490 Net* o NA 11.25 NA Excess tlr t 20 26 30 22 25 35 30 20 19 19 17 16 17 18 20 17 18 • 17 17 17 18 17 17 17 20 5.1 ID hns wps 46 44 42 44 44 44 33 46 46 48 48 48 48 48 47 47 46 46 47 47 47 47 47 47 46 3.1 6.0 1.18 28 28 28 28 30 30 30 30 30 30 31 30 30 30 30 31 31 31 31 31 30 30 1.1 0.58 0.60 0.58 0.60 0.56 0.54 0.58 0.024 664* 37.3* 10 ftns pressure pslg 6*0 3.8 4.6 FO ftn taps 30 28 28 Furiuce drtft pslg 0.60 0.55 0.58 0.55 0.60 0.63 660 680 686 680 690 700 340 340 340 340 340 340 340 340 323* 27.1* 24 28 30 32 32 33 33 33 34 33 32 32 32 32 25 7.9 29.11 29.08 29.06 29.05 29.08 29.08 29.08 29.08 27.06 29.06 29.14 0.061 0.60 0.60 0.57 0.58 0.60 0.60 0.55 620 600 600 660 670 700 700 280 ESP Inlet tt»f "f 280 280 280 320 340 340 16 15 15 15 15 17 20 Aibient imp °F 17 17 Agilent pressure Inches Hg 29.19 29.19 29.19 29.20 29.21 29.21 29.20 29.20 29.17 Cownts 0.60 700 0.54 615 0.58 taller flue aas te-pOF 16 Button and Fly Ash Removal Start - 12.30*. 4.30*. 8.29A. 12.30P . 4.30P. 8.23P Finish - 1.10A. 5.30A. 9.15A. 1.39P. 5.15P. 9.5SP 0.60 0.55 29.21 29.18 29.15 29.14 29.19 Soot Blow Start - 4. 30A.~11.AOA. 8.10P. 11 .OOP ROF density - 4 ,0 Ibs/cu ft. 4.0 Ibs/cu ft. 4.0 Ibs/cu ft �PROCESS PATA AMES MUNICIPAL MUCH PLANT UNIT NO. 7 Date 3-12-80 •Not based «« 24 kr data 1A 2A 3A 4A 5A «A 7A 6A 9A 21.0 19.0 21.0 19.0 21.0 19.0 20.5 11.4 21.0 19.0 21.0 18. » 29.0 26.6 32.5 10.0 34.5 31.8 35.0 12.1 16.0 11.1 36.0 1 . 11 Steam flo« rate 1000'i Ibs/kr 165 180 180 170 175 175 250 291 310 325 325 Steam pressure psig 850 850 850 640 850 650 860 860 850 855 Steam temperature °F 880 890 880 880 690 880 900-890 885 910 Feeduater flan rate 1000' s Ibs/kr 190 190 190 190 190 195 270 290 320 FeedMiter temp °F 340 320 320 320 340 340 160 380 Fuel feed rate (coal) 1000's Ibs/kr Fuel gauge readings 19.0 17.2 20.1 19.3 17.5 19.0 10.0 32.8 Tim* HU O ' 12N Cross Net Fuel oil IP 2P 3P 4P SP 6P 7P 8P 9P 15.0 12.1 35.0 32.2 35.5 12.9 35.5 32.9 15.5 32.9 36.0 31.5 16.0 11.4 3S.O 12.4 15.0 12.1 15.0 12.4 15.0 12.4 32.0 19.5 11.2 27.1 6.26 7.99 325 325 325 325 325 325 130 325 125 320 10 1 120 260 255 94.0 655 855 855 855 865 855 855 855 860 660 660 660 870 650 655 5.1 900 910 900 910 900 900 895 900 890 890 870 680 905 890 691 11.0 335 335 135 335 325 330 330 335 335 338 15 1 350 10 1 126 290 279 80.2 380 380 390 390 390 390 390 390 390 390 365 385 185 380 380 360 370 25.2 35.6 38.0 35.0 35.0 15.6 35.0 35.0 34.5 34.5 33.5 34.0 15.2 36.3 11.5 33.4 32.8 Coal Oil 30.5 7.11 31.0 NA 12.01 NA 10A 11* I2N 10P 416 106 (00 7SS 579 760 •OF UP Nean a 7.45A only 1 conveyor 9. 00* botn conveyors on Excess air S 30 30 30 30 29 27 20 19 19 16 19 15 18 22 15 14 16 14 15 15 16 20 14 24 20 10 fans amps 44 41 43 43 42 43 45 45 46 47 47 47 46 48 47 46 46 46 47 47 48 46 47 45 46 1.1 IP fans pressure 4.1 4.8 4.« 3.8 5.3 4.0 5.6 6.4 6.0 6.0 7.0 7.0 7.5 8.0 7.0 7.0 7.0 7.0 6.8 6.8 7.4 7.2 6.5 6.0 6.2 1.20 27 27 27 27 27 29 30 30 30 30 30 30 30 30 30 30 30 31 11 32 11 31 30 26 6.2 0.64 0.64 0.60 0.60 0.54 0.60 0.58 0.59 0.58 0.58 0.55 0.55 0.70 0.60 0.60 0.60 0.60 0.60 0.62 0.70 0.68 0.64 0.61 0.61 0.042 toller flue gas temp °F 620 605 640 675 680 700 700 700 680 680 680 690 700 700 675* H.I- ESP Inlet temp °F 295 300 320 320 324 325 335 335 335 335 340 140 340 340 127- 14.6* FD fan amps 27 FD fan pressure psig 1.6 Furnace draft psig 0.64 1.46 Ambient temp °F 31 30 Ambient pressure Inches Hg 29.03 29.00 28.48 Comments 5.9 30 30 30 30 26.96 28.94 28.94 31 31 26.97 28.96 lottom and Flv Ask « emoval Start - 12.30*. 4.20A. 8.30*. 12.3SP . 4. SOP. 7.0UP flnlsk - I2.55A. 5.03A. MSA. 1.4SP . S.20P. I.20P 31 31 31 30 30 30 1 0 12 31 29 29 26.92 28.89 28.88 28.85 28.84 28.83 28.60 28.79 28.78 26.76 28.62 Soot 8IOM Start - 4.20*. It. 00*. ,7.25P 29 28 27 26 26 1 0 1.6 28.82 28.82 26.82 28.62 28.82 28.66 0.079 RDF density - 4 .5 Ibs/cu ft. 4.0 Ibs/cu ft �PROCESS MIA AMES MUNICIPAL KMCR PLANT UNIT NO. 7 Date 3-13-80 •Not baud on 24 hr data 1A 2A 27.0 24.6 20.0 17.9 20.0 Stea* flax rate 1000' s Ibs/hr 240 165 12N Tine 1*1 Cross Net 3A 4A 5A 6A 7A 8A 9A 20.0 18.0 21.0 18. 0 20.0 18.0 IB. 9 29.0 26.6 32.0 19.5 16.0 35.0 13.4 32.2 15.0 32.4 165 165 162 170 260 295 330 320 IP 2P IP 4P 5P 6P 7P 8P 9P 35.0 32.3 15.0 35.0 32.3 3 2 . 4 15.0 12.5 35.0 32.6 35.0 32.5 15.0 12.4 15.0 32.4 15.0 32.4 15.0 32.4 15.0 32.3 15.0 32.4 13.0 30.4 11.2 28.1 6.11 6.16 320 120 120 120 120 320 320 320 320 320 320 320 320 290 268 82.2 IDA 11A 12N 10P UP Mean o Steaai pressure pstg 850 830 850 850 835 835 865 850 860 855 855 855 855 855 855 855 855 850 860 860 860 850 860 660 851 8.6 Steu temperature °F 885 860 895 895 885 865 895 890 915 895 900 905 900 905 900 905 900 900 900 895 890 890 880 890 891 12.2 Feednater flon rate 1000' s Ibs/hr 250 120 125 180 182 190 263 300 110 330 10 1 330 110 310 330 310 130 310 310 10 1 330 10 1 10 1 100 286 71.0 Feeduater teap °F 180 330 325 325 325 330 365 370 380 380 385 385 IBS 385 385 385 385 385 185 185 185 185 385 180 171 23.4 Fuel feed rate (coal) 1000' s Ibs/hr Fuel gauge readings 26.1 16.7 20.1 19.6 21.0 20.5 30.1 33.4 41.5 40.5 40.0 40.0 40. S 40.5 41.0 15.6 14.8 14.0 16.8 15.4 11.2 11.9 9.81 33.4 NA 2.08 NA Fuel oil 16.5 41.5 15.4 Coal Oil 419 922 804 395 580 050 7.15A only 1 conveyor 7.40A both conveyors 8.3SA- RDf 9.05P Syste* •A" off 9.25P System "A" on -Start RDF at4.0BP Excess air f 20 >50 18 39 18 38 18 17 14 16 17 18 18 18 18 18 16 17 19 18 18 20 17 23 23 9.8 ID fans amps 45 42 44 43 44 44 45 46 48 46 47 47 47 47 47 47 46 46 47 46 46 47 46 46 46 1.5 FD fan aups 29 27 28 27 28 28 29 30 31 10 11 JO 10 11 11 31 11 10 31 10 31 31 11 10 10 1.5 FO fan pressure psig 3.1 0.62 0.61 0.62 0.63 0.61 0.62 0.65 0.60 0.62 0.62 0.62 0.64 0.65 0.64 0.62 0.61 0.65 0.64 0.64 0.68 0.63 0.024 620 620 605 640 660 680 700 700 700 695 700 700 705 710 720 725 720 720 725 675 686* 37.5* 280 280 280 310 320 130 330 335 335 335 335 335 335 335 335 135 335 315 135 335 26 25 25 24 24 25 26 29 30 31 31 31 31 31 11 31 31 29 29 29 28.79 28.78 28.79 28.79 28.79 28.77 28.76 28.76 28.80 28.80 28.86 28.88 28.87 28.91 28.97 29.03 29.07 29.08 29.10 29.11 29.11 28.89 0.127 0.66 0.70 0.60 frailer flue gas teap °f ESP Inlet ump "f Anbient temf "t 26 26 Avbient pressure Inches Kg 28.82 28.81 28.80 Cowents 26 Bottoa and fly Ash Removal SUrt - 12.30A. 4.28A. B.10A , 3. OOP. 4.35P. 8.30P , 10.30P Finish - l.OSA. 5.12A. 9.26A. 3.50P. 5.20P. 9.35P. 10.44P Soot Blown Start - 4.07A RDf density - 4.5 Ibs/cu ft, 4 .0 Ibs/cu ft 0.66 324- 27 28 20.12.6 �PMCtSS DAI* MKS NMIC1ML NUEt PLANT UNIT NO. 7 Date 3-14-80 •Nat •tied on 24 hir dltl 12H Tie» 1A 2A 1A 6A 7A 8A 9A 35.0 12.7 US 165 165 177 300 315 320 840 850 MS MS 860 855 900 900 890 860 895 900 90S 180 180 180 176 185 180 300 370 315 335 335 335 330 335 380 30.7 20.8 18.8 18.2 19.3 19.9 20.3 31.3 35.0 35.0 35. 0 269 165 166 Steu pressure pslg MS MS MS Stem temperature °F 885 MS Feedmter flow rite 1000' s Ibs/hr 275 FeedMter teap °F Fuel feed rite (coil) 1000' t Ibs/hr Fuel 9«H9e railings Fuel ell «DF Excess ilr X 424 007 808 295 590 100 18 12N IP 2P 3P 4P 5* 6P 7P 8P »P 10P IIP Neu a 35.0 32.4 35.0 32.4 35.0 32.2 3S.O 32.3 35.0 12.4 35. 0 31.8 32\4 29.2 34.0 31.4 15.0 32.1 1S.O 32.4 14.0 11.2 32.0 29.4 10.0 27.4 10.5 28.0 6.25 6.01 310 315 115 315 315 115 310 283 300 305 317 305 280 260 270 62.8 860 850 860 ass ass 855 ass 850 850 850 ass 850 850 870 840 852 7.0 905 900 900 900 910 900 900 895 895 880 900 900 900 860 900 894 12.5 330 325 325 325 125 320 320 120 120 290 310 330 345 315 295 280 281 61.3 380 385 385 385 385 385 385 385 3M 380 380 380 390 385 180 180 171 21.8 34.0 36.5 36.0 36.5 34. S 33.0 32.0 31.0 38.0 32.6 35.0 30.S 32.4 Coil Oil 20.0 20.0 18.0 It.O Cross Net HA 10A 21.0 33.0 19.8 30.5 20.0 17.8 Ste*a f low r<te 1000' s Ibs/hr rO CO 5A 20.0 20.0 18.0 17.9 31.0 28.4 MM 4A 30.4 30.7 1.75 NA NA 15.0 35.0 12.1 32.4 6.64 7.35A only 1 conveyor 7.4SA both coiweyors on 43 >50 43 42 39 36 IB 13 15 15 18 16 16 18 18 17 19 18 17 20 16 IS 24 24 11.3 48 47 47 45 45 45 1.5 ID fens ups 45 43 43 43 43 43 43 45 46 46 46 46 46 46 46 46 46 45 45 FD f» ups 30 27 27 27 27 27 27 30 30 30 311 30 30 30 30 30 30 29 30 32 31 30 29 30 29 1.5 FO fin pressure pslg 4.0 2.9 2.0 1.8 FurMce drift pslj 0.59 0.61 0.7) 0.68 0.61 0.60 0.65 0.61 0.60 0.59 0.7S 0.60 0.65 0.60 0.60 0.62 0.60 0.60 0.62 0.70 0.60 0.62 0.044 615 620 600 630 660 680 685 685 690 665 680 680 685 690 680 690 715 700 690 650 660 669* 30.2* 290 290 290 315 330 335 335 335 335 335 135 15 1 335 335 130 335 335 335 315 130 320 326* 16.9* 21 21 21 21 21 26 34 40 42 49 48 50 52 54 53 51 49 46 42 41 40 37 29.13 29.13 29.11 29.11 29.16 29.11 1.01 taller flue «is te-p<>F EiP Inlet leap 21 1.12 Aablent teap °F 23 27 Anblent pressure Incus Mi 29.11 29.11 29.11 29.12 29.12 Convents 29.13 29.13 29.13 29.12 Bottom end fit Ash Neaonil SUrt - I2.27A. 4.28*. I.82A. 12.30P, 4.30P . 8.30P FUlsh - l.OOA. 5.10A. 9.25A. I.52P. S.OOP . 9.5SP 0.60 0.58 29.11 29.10 29.10 29.10 0.«2 29.09 29.09 29.08 29.09 29.10 29.13 SOOt 8 0 I 1 M SUrt - 4.10A, 11.20*. 8.481' RDF density - 4 .5 Ibs/cu ft. 4 .5 Ibs/cu ft 12.6 0.019 �PROCESS DATA AXES MUNICIPAL POWER PLANT UNIT NO. ? Date 3-15-80 •Hot based aa 24 hr data 1A 2A 3A 4A 5A 6A 7A 8A 9A 29.0 2C.6 19.0 17.0 24.5 22.4 24.0 22.0 24.0 21.9 24.0 22.0 24.0 22.0 24.0 21.6 28,0 25.8 30.0 27.2 31.5 28.9 31.0 28,4 Steaa flov rate 1000's Ibs/hr 245 159 212 201 201 205 205 207 240 260 280 Steaa pressure pslg 835 830 835 850 850 875 855 850 850 855 Steaa teaperature °F 890 880 890 880 905 885 885 885 905 900 Feedwter f low rate 1000's Ibs/hr 256 170 220 210 208 215 215 215 245 FeedMter teap °F 370 335 355 3SS 355 155 355 155 Fuel feed rate (coal) 1000's Ibs/hr Fuel gauge readings 29.6 19.0 24.8 30.1 29.4 10.4 Tlae HU 12N Cross Net CO N3 Fuel on 27.3 19.5 IP 2P 3P 11.0 28,4 16.5 14.4 17.0 15.0 16.0 14.0 282 278 135 118 855 858 855 845 905 860 895 895 265 285 291 281 155 365 375 378 11.5 31.5 35.0 34.4 10A 5P 6P 7P 8P 9P 10P UP 16.0 14.0 16.0 14.0 16.0 14.3 16.0 14.2 16.0 14.3 16.0 14.2 16.0 14.2 16.0 14.2 21.7 19.6 135 135 135 135 135 135 U5 115 135 186 850 850 850 845 850 850 850 850 850 850 850 8.6, 900 895 895 885 880 890 890 870 880 880 888 11.1 145 145 145 145 145 145 145 145 140 145 145 194 54.0 375 330 325 325 315 315 120 320 320 320 320 120 330 69.4 11.5 19.5 19.0 19.0 17.0 18.0 18.2 18.1 18.5 19.0 18.8 18.1 24.2 24.0 6.60 UN 11A 4P Coal on 427 756 430 705 811 911 814 720 580 190 581 100 Mean o 5.95 5.68 55.06 37.92 HA HA Midnight readings, 3-15-80 No ROF RDF Encess air I 24 50 30 29 39 38 36 30 24 19 20 20 21 >50 >50 >50 >50 >SO >SO »50 >50 »50 >50 >50 39 12.5 10 fans aaps 45 41 44 43 44 45 44 45 45 46 46 46 46 42 42 41 31 31 41 41 41 41 41 41 42 4.0 10 fans pressure pstj 5.7 28 28 27 28 29 29 29 30 30 30 10 30 27 27 27 27 27 27 27 27 27 27 27 28 1.4 0.80 0.90 0.90 0.81 0.82 0.90 0.78 0.81 0.72 0.73 0.70 0.70 0.68 0.72 0.68 0.68 0.70 0.69 0.70 0.74 0.60 0.60 0.74 0.092 660 600 600 600 600 625* 27.3* FD fan aaps 30 FO fan pressure psl9 4.3 Furnace draft pslg 0.61 Holler flue gas teap OF 0.88 630 640 640 615 645 650 680 670 600 605 610 610 600 595 305 ESP Inlet teap °F Aablent teap °F 40 40 19 Aablent pressure Inches Hg 29.16 29. M 29.1229.11 38 305 305 110 310 120 325 325 325 290 285 285 275 270 275 275 275 275 275 38 38 35 14 40 48 55 60 62 64 64 65 65 64 61 59 56 54 54 51 51 29.08 29.05 29.07 29.44 29.04 29.03 29.00 29.02 28.96 28.92 28.88 28.87 28.89 27.89 28.90 28.90 28.90 28.90 28.87 28.87 28.48 8ottoa and Fly Ash Reao»al Start - l.OOA. 4.28A. 8.30A. 12.39P. 4.37P. 8.30P Finish • I.27A. 5.00*, 9.03*, 1.15P. 5.OOP. 9.0SP Soot BlQMi Start - 3.58*. 10.30*. 8.40P RDF density - 1.5 Ibs/cu ft 295* 20.211.2 0.098 �PROCESS MIA IS MUNICIPAL POME*. flMT UNIT JO.. 7 •Not based on 24 nr data Bate 3-17-80 12M Tie* 1A 2A 3A 4A SA 6A 7A 8A 9A 16.0 14.0 16.0 14.0 16.0 14.0 16.0 13.9 16.0 14.0 28.0 25. 9 32.5 29.8 34.8 32.3 35.0 32.3 3S.O 33.2 130 130 130 130 IX 265 270 310 310 315 10A 11A 4f SP 6P 7f 8P 9f 34.5 33.8 34.5 31.9 34.5 31.9 35.0 32.4 35.0 32.4 35.0 32.3 35.0 32.3 35.0 32.3 30.5 27.» ' 29.5 27.2 7.74 7.S8 310 310 310 310 310 310 310 320 320 260 259 76.1 IP 2P 35.0 33.2 34.5 31.7 34.5 31.6 315 310 12N 10P UP Mean a * NU Gross 28.0 Net Steam flan rate 1000' s Ibs/br 243 160 Steaa pressure pslg 845 840 850 850 •SO 850 •SO 850 835 855 855 855 855 850 850 850 •SO •SO 860 860 850 •SO 850 850 •50 5.3 Steam teeperature °F 890 •80 890 880 870 900 890 885 900 900 900 910 900 880 895 900 900 900 890 900 890 890 880 890 •92 9.4 FeeAuter flon rate 1000' s Ibs/kr 255 188 140 140 141 140 140 265 2S6 320 315 320 320 326 320 320 320 315 320 315 330 330 320 270 268 74.5 Feedueter teap °F N) 25. S 22.0 20.0 365 340 320 320 320 320 320 375 380 380 380 380 380 380 385 385 385 385 385 385 385 385 385 380 367 26.3 Fuel feed rate (coal) 1000' s Ibs/kr Fuel gauge readings Fuel oil 32.4 22.0 18.6 19.4 17.6 18.9 18.9 34.5 39.6 36.5 36.6 37.5 38.0 35.0 34.5 33.5 34.0 33.0 33.4 36.8 35.2 33.5 29.6 on Coal 30.9 31.2 2.92 7.23 HA NA 434 476 818 349 581 370 tIO:10A7 No «OF- MFEicess air X 22 35 >50 1.0. fans aaps 46 1.0. fans pressure F.O. fan aaps 30 27 27 F.O. fan pressure pslg 3.8 3.1 0.42 0.64 0.59 >50 44 44 No Ulf 11:05A 19 >50 46 21 42 48 17 47 18 48 17 20 46 47 -Start WF at 1 :40P 21 17 47 46 18 46 16 46 16 18 16 46 46 20 18 16 24 26 13.3 47 47 46 45 46 1.6 2.1 Furnace draft pslg 43 >SO 4.8 44 43 >50 33.5 46 1.00 27 27 27 30 27 32 30 31 30 31 31 30 30 30 30 30 31 31 31 30 30 0.65 0.55 0.60 0.60 0.69 0.58 0.55 0.60 0.63 0.60 0.55 0.60 0.60 0.60 0.70 600 600 600 645 670 680 785 695 700 695 665 675 675 0.50 280 280 280 320 320 330 330 330 330 330 330 330 335 32 31 31 31 30 29 29 29 29 29 32 36 36 41 41 42 42 42 41 Aablent pressure Inches Ng 29.04 29.04 29.03 29.03 29.05 29.05 29.05 29.06 29.12 29.10 29.14 29.11 29.10 29.10 29.08 29.09 29.08 29.08 29.13 29.16 29.16 0.52 0.70 335 32 0.70 lotto* and Fly Ask la•oval 1:3SP. 10:OOP Soot llOMi 39 0.074 48.9* 319« 0.54 0.59 669* 0.44 685 Aabient teap °F ESP Inlet leap °F Finis* - 6:OOA, 1.6 1.09 toller flue gas teap Coaaents 30 21.3- 34 4.9 36 34 34 29.15 29.14 29.14 29.09 0.043 �PROCESS DATA AMES tUIICIPAl POHE* PIAIIT UH1T HO. 7 •Not b»ed on 24 kr diU Dite 3-18-80 1A 2A 3A 4A SA 6A JA BA 9A IDA I1A 12M IP 2P 3P 4P SP 6P 7P 8P 9P 10P HP 29.0 Z6.6 27.0 24.9 26.5 24.4 25.5 23.4 25.5 23.4 25.5 23.5 27.0 24.8 31.0 28.6 35.5 32.8 36.0 33.4 35.5 33.1 35.0 32.4 35.0 32.5 35.0 32.5 35.0 32.4 35.0 32.5 33.0 30.6 32.5 30.1 32.0 29.4 35.0 32.2 35.0 32.4 35.0 32.4 32.0 29.3 29.0 26.4 31. « 3.84 29.3 3.65 Stew flo« rate 1000* s Ibs/kr 240 230 230 222 220 220 240 275 31S 325 320 320 320 320 31S 315 300 295 295 319 315 310 285 251 283 40.0 Steal pressure pslg 845 835 850 855 840 850 850 850 855 860 855 855 855 850 850 850 850 845 B45 855 850 855 835 855 850 6.3 835 880 870 885 685 90S 910 900 875 900 900 910 900 900 880 BBS BBS 880 895 900 BBS 890 16.2 251 295 324 335 330 338 330 330 330 330 305 310 300 330 325 311 300 260 295 38.1 11.7 Tim Ml Gross Net 12M Nun o SteM teaperiture °F 895 90S 885 FeedMter flow rile 1000' s Ibs/kr 250 245 241 240 235 240 FeedMter teap °F 365 360 360 355 355 355 360 370 380 385 385 385 385 385 385 385 380 380 380 385 385 385 380 370 375 Fuel feed rite (coil) 1 0 ' s Ibs/kr 00 Fuel Muoe reidlngs Fuel olT «OF 30.1 31.1 438297 822 025 581 440 27.0 24. S 28.4 23.9 28.2 32.5 39.5 38.0 36.0 34.5 35.5 35.5 33.5 35.0 33.0 32.0 31.1 32.6 32.7 32.5 31.2 29.3 Coil on 32.0 3.84 31.6 HA 2.50 NA Excess ilr 25 33 23 18 26 25 20 19 18 20 20 17 22 19 23 20 20 19 20 IB 16 IB 20 21 21 3.6 1.0. fins ops 45 45 44 44 44 44 44 45 47 46 46 46 46 47 46 46 46 45 46 46 46 46 47 45 46 0.98 1.0. fins pressure pslg 5.3 F.O. IMS UPS 29 30 29 27 28 28 28 30 32 30 30 30 30 30 30 30 30 29 30 30 30 30 30 29 30 1.0 2.3 2.5 3.0 3.0 5.0 6.0 4.8 4.8 4.8 4.1 0.97 0.65 0.57 0.45 0.61 0.60 0.60 0.70 0.60 0.70 0.60 0.50 0.75 0.53 0.55 0.50 0.40 0.60 0.80 0.65 O.SI 0.59 0.098 625 625 635 650 695 695 695 68S 680 680 695 700 690 690 690 680 680 680 675 676* 24.0* 305 305 310 320 330 330 330 330 330 330 330 335 330 330 330 335 335 330 320 326" 9.5- 34 34 34 34 37 44 51 56 62 61 64 65 66 64 62 59 55 54 50 49 12.8 29.13 29.13 29.12 29.12 29.13 29.10 F.D. fin pressure pslg 3.6 4.4 2.6 Furnice drift pslg 0.6S 0.45 0.69 teller flue gis teap °F ESP Inlet teap °f Aablent teaperiture 33 33 33 Aabtent pressure Inckes Hg 29.14 29.14 29.14 29.14 fnearnts 1:50 P both connectors on 7:15 A only 1 connector 33 ppttoa tek Mid fly tefc jeaovil SUrt - 2:10A. 5:40A. 10:30A. 2:OOP. C:17P. 9:52P Finis. 6:OOA. 11:20*. 2:32P. 7:3SP. 10:1SP 0.60 49 29.09 29.09 29.09 29.08 29.02 29.02 28.99 28.98 29.00 2 . 0 28.96 28.96 28.96 28.95 2 . 6 0.071 90 90 Soot iloxn Stirt - 2:35A. 10:25A, 6:30A RDF density - 3.5 Ibs/cu ft. 4.0 Ibs/cu ft. 3.5 Ibs/ cu ft �PROCESS DATA MKS MMicirAi taut nun UNIT * 0. 7 •Not btud M 24 r deU 1 DtU 3-19-80 I2M Ttae Ml Cross U 2A 3* 4A SA M 2P 3* 4P 5P <P 7P 8P » 31.0 28.3 35.0 32.2 35.0 34.5 32.4 32.0 35.0 32.4 35.0 32.S 35.0 32.0 35.0 32.6 35.0 32.6 35.0 32.6 31.0 28.6 33.0 30.1 36.0 33.1 35.5 32.6 35.5 32.7 32.0 29.2 23.0 20.8 31.0 27.2 t.K 2O8 243 292 314 315 310 310 315 320 320 320 320 280 292 340 320 319 290 190 277 52.1 170 845 ISO 860 860 85S 850 845 855 855 855 855 855 845 845 845 865 860 860 850 853 7.0 8M 885 895 900 895 910 900 885 894 900 900 902 900 860 880 870 875 BBS 880 875 888 12.1 225 220 250 295 322 31S 325 325 325 326 325 328 325 295 305 349 345 325 295 200 287 50.6 355 350 360 395 380 385 385 38S 385 385 385 385 385 385 380 395 390 390 385 350 375 16.5 22.4 30.4 30.4 33.6 34.5 34.0 34.0 33.0 33. 5 39.5 39.0 39.0 31.0 33.5 35.0 33.3 33.9 31.6 19.5 31.1 31.4 4.17 5.74 M M 20 5.9 45 1.3 5.7 0.65 29 1.5 7* M 9A 1 M 11A 27.0 24.1 12N IP 10P UP 21. 0 U.O 2S.S 23.4 Stt» flo* r«U WOO1 s Ibs/br 175 220 215 212 Steal pressure pstg MS 855 850 845 Stetei temperature °F 875 885 8»5 885 Feeduiter flow r<U 1000' • Ibs/hr IBS 232 225 235 FeedMter leap °F 340 3M 360 355 Fuel feed rile (CM|) 1000's Ibs/kr fuel 9*uge reeding* Fuel oil 18.3 23.4 442 234 «2S i » S81 SOO Encess «lr I 40 24 1» 20 24 22 20 16 15 17 IS 18 16 18 19 17 17 22 18 18 12 15 18 32 I.D. fus «ps 43 43 43 44 43 43 44 45 46 46 45 46 46 46 46 46 46 45 46 46 45 46 45 43 I .0. fMis pressure pi 19 4 F.D. fUS UPS 27 Net hO O OJ I (Jl —• 25.0 2S.O 24.0 2S.O 22. « 22.f 21.8 22.8 205 29.S 30.2 24.2 Coal Oil 1-.10P'a 28 28 28 28 28 30 30 . 29 30 30 31 30 32 • 31 32 30 30 30 29 30 29 26 2 8 1. 18 psl« FUTMCC dreft pslg 0.70 O.tO 0.50 0.5* 0.52 ilS taller flue g*s teap 620 0.72 0.67 0.69 0.5S 0.54 0.70 0.80 0.62 0.61 0.64 0.63 0.50 0.68 t20 630 650 680 685 690 675 675 680 690 685 700 695 305 300 300 310 320 335 335 340 335 335 340 340 340 340 ' 48 45 45 45 43 43 43 44 SO 59 62 62 66 68 68 69 68 Aefclent pressure Inches Hg 28. »S 28.95 28.93 28.93 28.93 28.88 28.87 28.88 28.88 28.05 28.83 28.79 28.77 28.76 28.73 28.72 28.71 28.71 28.73 0.50 0.61 0.65 0.30 340 48 0.59 lotto Md Fly Asli «e«ovil SUrt - 1:SOA. S:0SA. l6:JOA. 1:10P. t:30P. 9:25P flalU - 3:2SA. 5:SM. 11:0&A. I-.3SP, 7:54P. 10:00f> SUrt - 3:iU. IDilSA . 6:45 P 0.60 0.101 66«* 0.61 tafclent te«p °F ESP Inlet °F Coaeents o S.Ol •'SUrt •Of .t 4:10P No WF e .• 28 Neui 30.2- 328* 68 15.9* 65 61 58 59 55 56 9.3 28.73 28.73 28.73 28.73 28.73 28.81 0.088 KDf dtensity - 4.0 Ibs/cu ft. 4.0 Ibs/cu ft �PROCESS MIA AMES MUNICIPAL MUt« PLANT UNIT NO. 7 •Not based M 24 hr data Oat* 3-20-80 Tlw NU Cross Nit Stea> HIM rat* 1000's Ibs/hr 12H 22.0 I9.a 190 1A 22.0 19. a 190 2A 22.0 19.6 190 3A 4A SA 6A 21. S 21. S 19.2 19.3 22.0 19.7 24.0 21.8 175 180 188 200 7A IP 2P V 4P Sf> V 7P 8f> 9P 10P UP 35.0 32.5 35.0 32.4 35.0 32. S 35.0 32.6 35.0 32.0 36.0 32.2 3S.O 32.3 35.0 32.3 35.0 32.2 33.5 31.1 29.$ 27.1 30.6 26.1 S.88 7.68 320 11A 320 320 120 315 315 319 319 319 319 300 260 273 59.8 12N M 9A 27.0 24.2 34.5 31.7 35.0 32.4 35.0 32.5 35.0 32.0 35.0 32.5 240 315 315 320 320 10A 0 MM* Staa> pressure psig O 1 —• 00 850 840 850 850 850 850 850 855 855 860 855 855 850 ass ass 850 855 8SO 855 850 850 860 851 6.0 880 900 880 860 880 890 890 895 90S 910 870 880 900 905 910 900 895 895 895 885 885 890 900 891 12.3 200 200 200 195 210 200 210 250 320 325 330 335 330 325 328 325 325 330 325 325 340 330 305 275 222 115.4 Feed»eter tup °F cr> 840 ago Feeduater flow r»te 1000's Ibs/hr (0 CO 840 Uu> teiperaturt °f 350 350 350 350 340 340 360 360 380 385 385 382 382 385 385 385 385 385 385 385 385 385 380 370 372 16.8 20.0 24. S 29.8 Fuel feed rite (coal) 16.9 24.0 24.6 32.4 26.0 1000-s Ibs/hr 444 122 450 244 I Futl eauoe readings 829 315 833 406 1 Mdnlgkt readings . 3-20-80 Fuel oil sai 600 582 090 | IDF 2:3M-No RDF 38.1 38. 0 39.0 37.2 37.0 37.0 36.6 37.0 37.0 39.6 39.6 40.1 41.6 39.0 36.5 Coal 33.6 34.4 NA Oil 20.42 HA Excess air I 35 40 42 40 40 36 25 24 22 22 20 19 23 21 22 21 23 21 21 21 20 26 24 32 27 7.7 1.0. fans anps 44 43 43 43 44 44 44 45 47 47 46 46 47 47 47 47 47 48 48 48 48 48 48 48 46 1.8 1 .0. fans pressure psll 5.0 F.D. fans aups 28 F.D. fans pressure psig 0.54 toller •F V) 0 .w 28 28 27 28 28 29 29 32 31 31 30 30 31 31 31 31 32 32 32 32 32 31 30 29 4.S 0.80 O.M 0.40 flue gas IMP 0.60 615 0.78 620 0.70 625 0.68 630 0.53 695 6.4 1 . 19 J* 0.55 0.60 0.70 0.62 0.68 0.62 0.60 0.55 0.65 0.60 0.50 0.50 0.60 0.62 0.60 0.60 0.093 705 710 670 680 690 700 700 705 710 715 720 680 685 680 680 681* 32.8- 295 ESP Inlet °F 295 300 320 325 325 330 330 330 330 335 335 335 330 330 330 330 330 330 315 324« 12.7« 46 47 44 43 43 42 42 42 44 46 51 52 51 50 45 44 44 42 42 39 44 9.2 28.95 28.93 28.92 28.93 28.97 28.92 0.086 M>«ent teap °F 50 50 46 taktent pressure Inches Hg 20.72 28.72 28.82 28.82 28.83 28.86 28.90 28.90 28.94 28.96 Counts 7.06 No ROF 3.5 Furnace draft psig 11:OOA 11:35* 34.0 46 !»"?• ft"* Ash «« ' « 5S>t HoMn 28.96 28.96 28.97 Start - 3:MA.'10:lSA, 7:10P KOF density - 3.5 Ibs/cu ft 28. 98 28.97 28.99 29.01 29.03 29.03 �MOCESS DATA AlCS HJHIClrAl fOMt» M.AOT UNIT • . 7 0 •hot kased M 24fcrdata Date 3-22-80 1A 2A 1A 4A SA 6A 7A •A 9A 10A 11* 12* If 2P » V SP 6P 7P sp gp 10P UP 22.0 19.9 22.0 19.1 22.0 19.S 22.5 20.4 21.0 20.9 21.0 21.0 21.0 20.8 23.0 20.8 29.0 26.1 32.0 29.7 34.0 31.6 34.0 31.4 34.5 12.0 34.0 11.4 32.5 30.1 12.0 29.6 12.0 29.6 11.0 10.6 13.0 10.1 15.0 12.1 14.5 11.1 14.5 11.7 32.0 29.3 30.0 27.4 29.4 27.1 5.16 4.9S Stew flan rate 1000's Ibt/hr 188 188 188 190 195 200 195 195 255 288 110 320 110 107 285 280 285 290 295 312 110 110 285 265 260 Sl.l Stew pressure pslg 850 850 860 860 850 850 860 850 868 850 850 880 850 850 850 850 850 850 850 050 850 850 850 850 851 7.4 12M Tin. m Gross Net MM* . Stew twperature °F 890 900 890 870 870 870 880 900 90S 900 900 910 890 890 900 905 900 900 890 890 900 880 880 880 891 11.8 FeedMter flOH rate lOOO's Us/nr 200 200 200 210 210 200 205 200 263 293 110 115 320 115 300 295 295 300 102 322 110 325 295 265 270 50.5 Feedwter twp °F 340 340 340 340 340 340 340 340 365 175 380 385 176 380 380 380 380 180 380 185 380 380 180 365 365 18.9 Fuel feed rate (coal) 1 0 ' s Iks/nr 00 Fuel gaimi readings Fuel ill •OF 19.3 453 901 •36 954 582 768 21.2 19.4 20.8 20.3 18.0 25.0 2B.O 32.0 35.5 36.1 16.0 38.5 35.5 37.0 38.0 19.0 18.5 40.2 4. 05 40.1 38.6 31.5 Coal 11.1 8.12 11.1 M 26.67 NA Excess air I 27 27 27 25 27 27 26 25 17 22 21 1.0. fws aaps 42 42 42 42 43 43 43 43 44 45 46 1.0. fans pressure pslg 4.6 F.O. fans aups 27 28 27 27 27 28 27 27 29 30 30 20.2 on 12: UP F.O. fans pressure pslg 3.0 06 .8 0.44 30 15 30 18 30 19 30 18 20 20 20 20 20 19 " 22 1.1 46 46 46 46 46 46 45 45 I.I 30 30 30 31 31 31 30 30 29 1.5 4.1 31 21 18 46 19 0.99 0.59 0.101 659* 30.4- 1.0 Furnace draft pslg • No ROF 0.40 ESr Inlet °F Ambient tenp °F 16 34 Ambient pressure Inches Hg 29.21 29.21 29.21 29.17 34 31 31 Finish 0.70 0.47 0.45 0.65 0.60 0.70 0.68 0.68 0.65 0.50 0.58 610 615 640 660 685 700 680 675 670 675 670 680 300 300 315 320 330 310 130 330 330 125 325 325 33 34 33 35 16 38 40 44 45 46 50 50 50 29.18 29.18 29.15 29.14 29.11 90 29.08 29.05 29.02 29.00 2 . 8 28.97 28.96 2 . 6 28.87 28.87 28.87 28.87 28.87 2 . 4 0.134 88 89 29.18 29.18 lotto* and Fly Ask Kenoval Comments 0.60 300 0.74 0.68 610 0.40 •oiler flue gas leap •F Soot lloun 0.55 0.56 0.65 0.58 0.62 0.65 120* 46 •OF density - 3.5 Iks/cu ft, 4.5 Iks/cu ft 41 41 41 39 19 12.2* 40 5.9 �PROCESS DATA AMES MUNICIPAl POWER PLANT uHIT NO. 7 •mot based on 24 kr data Date 3-23-80 12* 10P IIP a Men IP 2P 3P 4P 5P 6P 7P 17.0 15.4 17.0 15.2 17.0 15.3 17.0 15.4 17.0 15.4 17.0 15.4 20.0 18.3 20.0 1S.O 20.0 18.0 20.0 18.0 20.0 17.9 20.0 18.0 18.1 16.2 1.98 1.80 144 144 144 144 142 144 144 168 168 168 168 168 168 153 16.2 845 850 850 855 850 855 855 855 860 860 860 860 860 860 852 5.7 885 895 890 890 880 890 890 895 eao 890 870 880 880 880 884 10.0 150 150 165 150 151 150 150 150 180 180 180 180 180 180 162 17.8 320 325 320 320 320 320 320 320 325 330 340 330 330 330 340 325 7.1 19.8 19.6 21.0 21.0 21.0 20.0 20.0 20.5 19.5 22.0 22.6 22.9 23.0 22.6 22.2 Coal Oil 20.8 1.71 20.4 M 33.33 M >50 >50 >50 >50 >50 >50 >50 >50 41 40 29 29 26 26 26 28 '42 11.0 43 43 43 42 42 42 43 42 41 41 42 42 42 42 42 42 42 0.7 1A 2A 3A 4A 5A 6A 7A 8A 9A 25.0 22.4 17.0 15.0 17.0 15.0 17.0 15.2 17.0 15.2 17.0 15.2 17.0 15.1 17.0 15.2 17.0 15.2 17.0 15.2 17.0 15.2 17.0 15.4 SUM flax rate 1000' s Ib/kr 210 145 144 144 144 144 145 145 142 142 143 Steam pressure pslg 850 840 850 850 845 850 850 850 845 850 Steam temperature °F 880 880 890 850 880 890 880 880 890 900 Feeduatcr flow rate 1000 's Ibs/kr 220 162 155 155 152 150 150 150 150 150 FeediMter teap °F 340 320 320 320 320 320 320 320 320 Fuel feed rate (coal) 1000' s Ibs/kr Fuel gauge readings Fuel oil RDF 26.2 19.5 457 717 840 602 583 406 19.6 19.5 19.5 19.6 19.0 20.2 19.4 Excess air X 19 >60 >50 >50 >50 >50 >50 >5fl 1.0. fans aaps 44 43 43 43 43 43 43 43 1.0. fans pressure pslg 4.0 4.0 4.0 F.O. fan aaps 29 28 28 27 27 F.O. fan pressure f>sl| 2.0 2.7 2.7 2.7 2.2 Furnace draft pslg 0.54 0.60 0.64 0.58 0.54 TIM NU w • oo g » ftp Gross Net IDA 11A 12N No RDF 0.22 27 28 27 27 27 27 27 28 27 27 27 26 26 27 27 27 27 27 27 27 0.6 0.67 0.60 0.64 0.58 0.51 0.56 0.60 0.40 0.63 0.60 0.58 0.64 0.64 0.62 0.65 0.57 0.60 0.55 0.56 0.59 0.057 600 600 600 600 605 590 600 600 600 595 595 599* 3.9« 280 280 280 280 280 280 280 280 280 280 280 280* 0* 37 3) 40 38 37 1.6 Boiler flue gas teap ESP Inlet °F Ambient teap °F 40 39 41 Ambient pressure inches Mg 28.87 28.96 28.95 28.94 28.93 28.92 28.92 28.99 28.98 28.98 29.01 Comments _•<""• and Fly Ask Removal 39 37 36 36 36 $S't»!9-? 36 36 Start - 2:30A. 11:15*. 7:OOP 36 38 38 40 37 36 36 36 36 36 28.99 28.97 28.97 28.96 28.95 28.96 28.96 29.00 29.00 29.01 29.01 29.01 29.01 28.97 0.036 RDF density - No ROF �PMCESS DATA UK HJMIClfM KMtR PtANT UNIT NO. 7 Date 3-24-80 •Not based on 24 hr data Time 12M 1A 2A 3A 5A 4* 6A •7A 8A 9A 10A 11A 3S.O 32.4 35.0 32.6 35.0 32.4 310 310 305 4P SP if M.S 33.8 3S.O 32.S 3S.O 32.4 3S.O 32.5 3S.O 32.$ 35.0 32.S 15.0 32.S 310 310 310 US 320 320 IP 2P 3P M.5 32.0 35.0 32.6 310 315 12N 7P 10P UP 3S.O 32. S 15.0 32.4 32. S 30.0 29.7 27.4 7.77 7.55 318 318 318 290 264 73. S 4.9 8P 9P Moan a 20.0 18.0 20.0 18.0 18.0 16.0 17.0 1S.O 17.0 1S.2 17.8 IS. 2 17.0 15.2 30.0 27.3 3S.O 32.3 Steam flox rate 1000' s Ibs/hr 16S 165 ISO 148 148 148 148 260 3IS Steam pressure pslg 860 860 860 ato 860 860 860 860 860 855 855 840 850 860 850 860 860 ass 860 860 860 860 860 860 868 Steam temperature °F 880 900 880 880 900 890 880 890 890 9W 904 900 890 890 900 91S 880 890 890 900 860 890 890 aw 891 11.2 FeedtMter flon rat* 1000's Ibs/hr 180 180 160 160 164 15S 155 270 323 320 320 312 315 32S 320 325 320 320 328 328 332 330 328 290 273 72. S Feednater temp °F 340 340 330 330 330 320 320 3 0 3 0 380 380 380 380 385 385 385 385 385 38$ 390 390 385 390 380 367 25.4 Fuel feed rate (coal 1000's Ibs/hr Fuel gauge readings Fuel oil 22.8 22.8 20.2 19.4 20.3 19.0 20.1 33.7 37.5 37.0 37.0 M.5 32.0 33.0 33.0 M.5 33.4 39.5 41.1 42.8 42. S 41.7 40.6 37.0 Oil 32.3 8.26 32.8 NA 20.42 NA Ml Cross Net 460 266 842 955 S84 200 Coal to ROF at 10:27A NO ROF RDF- 4:10P- No ROF Encess air I 28 29 45 45 41 46 45 24 19 20 18 19 17 18 17 14 1 8 19 18 19 19 19 17 19 25 10.8 1.0. fans amps 42 43 43 43 42 42 43 46 47 47 47 46 48 48 48 46 46 46 47 47 47 47 47 43 46 2.2 1.0. fans pressure pstg 6.1 27 F.O. fans amps 27 27 F.O. fan pressure 2.3 3.0 O.SS 0.57 0.27* 27 27 27 27 29 31 30 30 31 30 30 30 30 30 30 31 31 31 31 31 31 29 1.7 0.92 ps1« Furnace draft psig 0.60 0.50 0.60 0.58 0.58 0.50 0.68 670 685 700 685 600 toiler fuel gas temp 59S 595 655 680 0.38 0.62 0.47 0.62 0.50 0.40 O.SS 0.5$ 660 670 680 680 685 0.55 0.50 0.50 O.SS 0.48 0.073 36.1* 322* 0.40 O.S3 660* O.S2 23.1* •f 280 280 280 335 330 330 33S 335 335 335 335 335 33$ 33S Ambient temp °F 36 35 35 36 36 36 36 36 36 36 36 35 35 36 38 38 38 38 37 37 37 36 36 35 36 1.0 Ambient pressure Inches Kg 28.96 28.96 28.96 28.96 28.96 28.96 28.96 28.96 28.99 26.98 29.01 29.02 29.04 29.01 29.06 29.06 29.06 29.08 29.13 29.13 29.13 29.18 29.18 29.18 29.04 0.079 ESP Inlet temp °F tottM andFly Ash Remove 1 Comments Start finis. - Soot 81lMl *OF density - 4.0 Ibs/cu ft >:3SA. 2:06P. �PROCESS DATA *KS HUHICIPM. POMER It All I UNIT NO. 7 Date 3-25-80 •Hot based on 24 hr data 1* 2A 3A 4* 5* 6* 7* 8* 9* 22.0 19. S 18.0 16.2 18.0 16.2 18.0 16.2 18.0 16.2 18.0 16.2 18.0 16.1 28.0 25.8 35.0 32.3 35.0 32.2 180 148 148 150 155 155 155 250 317 12H TIM Ml Gross Net Steaei flow rate 1000' s Ibs/hr 7P 8P 9P 10P IIP 35.0 36.0 32.3 32.5 35.0 32.3 35.0 32.5 35.0 32.S 35.0 32.5 25.5 23.7 312 312 312 311 312 312 313 252 12N IP 2P 3P 4P 35.0 32.5 35.0 35.0 32.5 32.6 35.0 32.6 34.0 31.4 34.5 32.1 35.0 32.3 315 318 315 315 310 308 312 10* 11* 5P 6P Mean 0 29.57.54 27.27.21 262 71.9 Stean pressure pslg 860 850 850 850 850 850 860 840 860 855 855 855 855 855 845 850 850 850 850 850 810 850 853 850 852 4.8 Steaei temperature °F 870 890 880 880 880 880 880 890 900 905 900 900 880 890 900 900 900 900 900 905 882 900 900 880 892 10.7 Feedwater flow rate 1000's Ibs/hr 210 158 160 160 160 325 324 320 280 272 71.4 Feeduater te«p °F 340 320 382 382 382 380 364 27.6 160 165 250 325 320 325 325 325 320 325 324 320 320 320 318 385 380 385 385 383 383 383 383 34.0 34.0 34.0 35.7 48.3 38.7 320 320 320 320 320 360 380 380 380 380 Fuel feed rate (coal) 21.9 21.0 1000's Ibs/hr 464 277 Fuel tauge readings 846 818 Fuel oil 584 690 RDF 21.0 21.4 21.5 21.5 21.5 33.9 34.7 35.3 33.0 33.0 33.0 Excess air S 38 >50 >50 >50 >50 >50 >SO 22 22 19 20 18 IB 19 19 17 16 17 15 IB 17 15 18 18 . 27 I.D. fans aups 43 45 43 44 45 45 45 46 48 47 48 48 48 48 48 48 46 46 46 46 46 46 46 45 46 1.0. fans pressure ps'9 3.8 5.0 F.O. fans taps 28 28 F.D. fan pressure PSl9 3.0 Furnace draft pslg 0.53 •Start RDF at 7:40* do RDF 37.5 39.0 30.0 31.8 7.66 Coal 31.8 Oil 28.33 N* M 10:OOP system ••" OFF 8:00* . 3-26-80 10:22P Systea T ON 4:OSP reduced RDF flow until 14.3 1.6 1.14 28 28 28 28 28 30 31 31 30 30 30 30 30 30 30 30 31 31 32 31 31 29 30 1.3 0.84 0.90 0.52 0.55 0.60 0.49 0.67 0.61 0.55 0.63 0.63 690 685 690 700 690 665 670 680 685 35 32 Aefclent pressure Inches Hg 29.18 29.18 29.18 29.18 31 31 280 310 330 330 330 330 335 335 335 335 335 29 33 34 36 42 44 43 44 45 46 46 29.18 29.18 29.18 29.22 29.21 29.18 29.19 29. IB 29.17 29.15 29.14 29.14 29.12 29.15 29.14 31 29.18 lotto* and Fir*sh Removal Start - 1:OUA . 5:00*. 9:00*. 1:01P, 5:OOP. Finish 9:45*. MSP. 5l43P. 0.50 O.SO 0.40 0.57* 0.108* 335 31 610 280 ESP Inlet teap °F Actlent te*p °F 0.57 695 605 31 0.60 0.57 640 0.43 toiler flue gas teem Co**ents 39.939.5 7:OOP. 9:05P 7:40P. 9: SOP Start - 275SA. "11:35*. 7:OOP RDF 670* 31.6* 323" 46 density - 3.5 Ibs/cu ft. 4.0 Ibs/cu ft 45 2.03' 38 6.3 45 43 41 40 29.15 29.15 29.15 29.15 29.17 0.024 �o PROCESS OATA AMES MUNICIPAL POHER P1ANT 1 1 NO. I *! •Hot based o» 24 br data Date 3-26-80 1A 2A 3A 4A 5A 6A 7A 8A 9A 10A 11A 12N IP 2P 3f 4P 21.5 19.5 21.5 19.5 21.5 19.S 21.$ 19.5 21.5 19.5 21.5 19.5 30.0 17.5 34.5 31.8 34.5 31.S 36.0 33.4 34.5 32.0 35.0 32.5 34.5 32.0 35.0 32.4 35.0 32.5 35.0 32.5 -180 180 1M 180 180 180 178 270 317 316 310 310 310 310 312 310 310 Stew pressure pslg 850 850 850 850 850 850 850 860 860 855 850 850 855 850 855 855 Stew teaperatur* °F 880 860 890 880 890 890 890 900 900 900 910 900 900 880 920 902 Feedxater flox rate 1000- s Ibs/kr 190 190 190 195 190 190 190 270 327 323 328 328 320 330 328 324 322 FeedHiter teap °F 340 340 340 340 340 340 340 340 3BO 385 380 380 380 380 380 385 385 385 385 385 Fuel feed rate (coal) 1000* s Ibs/hr Coal gauge readings Fuel otl (gallons/hr) ROF 19.0 19.0 18.5 468 170 850561 585 370 Reduced ROF flau 21.0 18.7 19.4 19.4 25.2 34.4 35.1 35.0 33.5 33.0 34.0 40.0 34.0 34.5 33.6 33.5 34.2 Eicess air s 34 28 30 27 27 28 27 20 19 18 18 19 18 18 19 19 19 17 20 20 19 20 1.0. fans aaps 44 44 44 44 44 44 42 45 47 47 46 46 46 46 46 48 46 46 46 46 46 46 l.D. fans pressure pslg 3.8 F.D. fans aaps 27 27 27 27 28 27 27 30 31 31 30 30 30 30 30 30 30 30 31 31 30 F.D. fan pressure pslg 2.0 1.9 Furnace draft psig 0.34 0.50 0.40 0.50 0.60 0.70 0.72 0.60 0.49 0.43 0.60 0.45 04 .8 0.55 0.58 0.52 0.49 0.60 0.52 0.65 toller flue gas top 620 630 620 600 600 600 605 665 690 695 700 700 700 665 680 690 690 690 700 700 ESP Inlet teap °F 290 290 290 290 290 290 290 320 330 325 320 325 325 325 330 330 330 325 325 /tab t Mt teap °F 38 36 36 35 35 35 35 34 34 36 40 40 45 44 45 45 45 45 43 Aabient pressure inches Hg 29.21 29.21 29.21 29.20 29.20 29.20 29.23 29.23 29.23 29.23 29.23 29.19 29.17 23.15 29.12 29.11 29.12 29.11 29.12 29.10 12N Tlae M Gross Net Stew flau rat* 1000* s Ibs/kr ro U* 22.0 20.0 tottoaand Coaaents Start Finish - i Reaova1 .10P. 7P 8P 9P 10P IIP 35.0 32.3 35.0 32.4 35.0 32.2 35.0 32.3 35.0 32.3 32.0 29.3 30.$* 6.17* 27.7* ».»* 31t 312 312 315 312 312 290 258 79.1 855 860 860 860 860 860 850 850 864 4.4 - 910 880 890 890 840 880 890 880 890 16.6 327 325 325 330 322 322 305 283 61.6 385 385 385 385 369 20.9 33.5 34.0 34.9 33.4 Coal on 29.6 31.* 1.67 7.16 NA NA 20 20 22 4.8 46 45 45 1.3 30 30 30 29 1.5 0.60 0.44 0.50 0.55 0.53 0.092 665 675 680 670 664 37.1 325 325 325 325 320 315 16.6 43 42 40 39 38 40 4.1 29.14 29.14 29.14 29.14 29.17 006 .4 No ROF 1:30»——- Start RDF at 2:12P 8 0 * resuae noraal RDF fl ow :0 9:5SA. 2.48P. 6P SP Soot Rloun Start - 27fO». 11.-45A. 7:05P RDF density - 3.5 Iks/cu ft. 3.0 Ibs/cu ft Moan • �APPENDIX B TRW FIELD TEST REPORT FOR THE CHICAGO NORTHWEST INCINERATOR. UNIT NO. 2 242 �PILOT TEST PROGRAM CHICAGO NORTHWEST INCINERATOR BOILER NO. 2 P, S. Bakshi, T. L. Sarro, D, R. Moore, W. F. Wright, W. P. Kendrick, B. L. Riley TRW ENVIRONMENTAL ENGINEERING DIVISION TRW, INC. EPA Contract 68-02-2197 EPA Project Officer: Michael Osborne Industrial Environmental Research Laboratory Office of Research and Development U.S. Environmental Protection Agency Research Triangle Park, N.C. 27711 243 �CONTENTS Figures iii Tables Acknowledgment iv v 1, Introduction 2, Summary . , , . , , 2.1 Sampling and Analysis. , , . , 2.2 Process Data , 2.3 Continuous Monitoring Data , , 3, Riant Description .,, 3.1 General Description. , . , , 3.2 Detailed Descriptions, . . , , , . . , , , , , 4, Sampling Locations. , , . , , , , , . , , , , , 5, Sampling, , , , „ , . , , . . , , , , , , , . , . , 5.1 Gas Sampling , . . . , , , , , , , , , , , , . . , , . 5.2 Solid Sampling , , , . , , . , , , , , . , , , , . . . 5.3 Liquid Sampling. , . , , , , , . , , , . , , , , . . . 5.4 Hi Volume Sampler. . , . , . . , , . , , 5.5 Quality Assurance , 5.6 Sampling Train Background, . , , , , , ,.. 5.7 Sample Recovery , ,., 5.8 Observations During Recovery , , , , , . t , , , , . . 6, Calibration , , 6.1 Method Five Calibration Data ,.... 6.2 Instrument Calibration 7, Technical Problems and Recommendations, 7.1 Problems . . . , , , 7.2 Recommendations, , 1-1 2-1 2-1 2-1 2-25 3-1 3-1 3-3 4-1 5-1 5-1 5-1 5-4 5-4 5-4 5-4 5-6 5-7 6-1 6-1 6-4 7-1 7-1 7-1 Appendices A. B. C. D. Continuous Monitoring Data, . , . , , , . . . , , , , . . . Field Data Sheets , Sample Inventory Sheets ,,.,.,,.,,... Process Data ,,.,., n 244 A-l B-l Crl D-l �FIGURES Number Page 3-1 3-2 Layout of plant site Flow diagram of Chicago Northwest Incinerator 3-2 3-4 3-3 Combustion air and flue gas system 3-11 4-1 4-2 4-3 4-4 Flow diagram and measurement locations Outlet sampling position Top view of ESP inlet showing port locations Cross sectional of ESP inlet showing traverse point locations Sampling train EPA Method 5 particulate sampling train Ambient air sampler Calibration equipment set-up procedures 4-2 4-3 4-4 5-1 5-2 5-3 6-1 m 245 4-5 5-2 5-3 5-5 6-3 �TABLES Number 2-1 2-2 2-3 2-4 Daily Sampling Summary Daily Data Summary 24 Hour Process Data for the Chicago Northwest Municipal Incinerator, Unit No. 2 Means of the Means for 24-Hour Process Data, All Test Days, Chicago Northwest Municipal Incinerator 2-5 2-6 2-7 2-8 Test Duration Process Data for the Chicago Northwest Municipal Incinerator, Unit No. 2 Weekly Inventories of Refuse and Residue at the Chicago Northwest Municipal Incinerator (All Boilers) Charges Fed to Each Boiler on a Shift Basis Chicago Northwest Incineration Facility Down Time Expressed as Lost Furnace Hours for the Entire Chicago Northwest Incineration Facility 2-9 2-10 3-1 4-1 page 2-2 2-9 2-13 2-15 2-16 2-18 2-19 2-26 Continuous Monitoring Data Means of Percent Oxygen Taken by Control Room Gauge and 02 Analyzer for Test Duration 2-27 Characteristics of Chicago Northwest Incinerator Sampling Locations 3-3 4-1 iv 246 2-28 �ACKNOWLEDGEMENTS This sampling and field measurement work was performed for the U.S. Environmental Protection Agency (EPA) under Contract No. 68-02-2197. The program was sponsored jointly by the Office of Pesticides and Toxic Substances in cooperation with the Office of Research and Development (ORD) of the EPA. The ORD-sponsored portion of the program was directed by Mr. Michael C. Osborne, Industrial Environmental Research Laboratory, Research Triangle Park, North Carolina. The Office of Pesticides and Toxic Substances sponsored portion of this study was directed by Mr. Martin Hal per, Washington, D.C. Three contractors participated in the overall test program, namely, TRW Inc., Midwest Research Institute (MRI) and Research Triangle Institute (RTI). TRW Inc. was responsible for the field testing; MRI had responsibility for the sampling analysis;and RTI had overall responsibility for the statistical design of the test program. Many individuals contributed to the sampling, testing, data reduction and report preparation for this study. Mr. Birch Matthews had overall responsibility for this program at TRW Inc. He was assisted in his management activities by Dr. Chris Shin and Mr. Don Price. The Field Team Leader was Mr. Dave Moore and the field sampling team members were Mr. J. Berger, Mr. M. Drehsen , Mr. 0. Gordon, Mr. W. Kendrick, Mr. J. McReynolds, Ms B. Riley, Mr. T. Rooney, Mr. D. Savia, Mr. B. Wessel and Mr. W. Wright. The Process Engineers were Mr. P. Bakshi and Mr. T. Sarro. The Chicago Northwest Incinerator personnel who provided significant assistance in completing the study were: Mr. Emil Nigro, the Supervising Engineer of the city of Chicago, Bureau of Sanitation; Mr. Stanley Oenning, the Chief Operations Engineer at the plant; and Mr. Gerry Golubski, Plant Chemist. In addition, there were numerous other plant personnel who provided assistance during the field testing. Their efforts are greatly appreciated and their contribution is hereby acknowledged. v 247 �1.0 INTRODUCTION This document describes the sampling and monitoring activities performed at the Chicago Northwest Incinerator, Boiler No. 2. The sampling and field measurement work was part of an overall pilot scale test program sponsored by the Office of Pesticides and Toxic Substances in cooperation with the Office of Research and Development, of the U.S. Environmental Protection Agency. The ultimate objective of the pilot scale test program is to develop an optimum sampling and analysis protocol to characterize polychlorinated organic compounds which may be emitted in trace quantities through conventional combustion of fossil fuels and refuse. The genesis of the program is an industrial study by Dow Chemical Company and two groups of European investigators reporting emissions of polychlorincted dibenzo-p-dioxins (PCDD), dibenzofurans (PCDF) and biphenyls (PCB) from stationary conventional combustion sources. The immediate objective of the sampling and field measurements program is the specification of procedures and equipment to obtain sufficient multimedia samples for the subsequent analytical protocol, and to satisfy the program statistical design requirements. In this respect, the TRW Environmental Engineering Division of TRW, Inc., was one of three contractors participating in the overall EPA program and was responsible for the acquisition of samples and measurements in the field. The sampling was oriented toward acquiring multimedia samples for organic compound analysis by Midwest Research Institute (MRI). Compounds of particular interest included: Benzo [a] pyrene Pyrene Fluoranthene Phenanthene Chrysene Indeno [1,2,3-cd] pyrene Benzo [g,h,i] perylene Anthracene In addition, MRI is to make a determination of total organic chlorine emissions from the acquired samples. Potentially, selected samples are to be analyzed for polychlorinated dibenzo-p-dioxins, dibenzofurans and biphenyls. 248 �Instrumentation for on-line combustion gas stream monitoring was part of the test program. In addition, Incinerator process Information was also gathered. This Information together with the monitoring data were acquired to assist In evaluating and Interpreting chemical analysis results. This report contains all the field data for the Chicago Northwest Incinerator pilot test program conducted in May 1980. Data provided Include the following: t Chlorinated hydrocarbon collection using a modified EPA Method 5 train and Method 5 sampling methodology. • Gas velocities using EPA Method 2, • Continuous monitoring for C02, 02, and CO and THC, • Part1culate collection for inorganic analysis utilizing EPA Method 5. • Process data. The test program followed was described in the Pilot Test Program, Chicago Northwest Incinerator, Boiler No. 2, site test plan. Deviations from this program are documented and explained in their respective sections of this report. 1-2 249 �2.0 SUMMARY 2.1 SAMPLING AND ANALYSIS The field test activity took place from April 30, 1980 to May 23, 1980. All required tests were completed and all recovered samples were sent to Gulf South Research Institute (GSRI) for analysis,. MRI had subcontracted this part of their assignment to GSRI. A summary of tests conducted including any significant commentary is presented in Table 2-1. A summary of the reduced data on a daily basis as calculated from the field data sheets is presented in Table 2-2. Data listed are corrected to standard conditions, i.e., 20°C and a barometric pressure of 29.92 inches mercury. Sampling and calibration procedures are described in Sections 4, 5 and 6. Hourly data is provided in the appendices. Appendix A contains continuous monitoring data; Appendix B contains field data; and Appendix C contains sample inventory sheets supplied by GSRI. 2.2 PROCESS DATA For every day of inlet or outlet testing, a 24 hour record of process data was obtained. This information is provided in the daily process data sheets in Appendix D. Most of this data was obtained from instrumentation in the control room. The parameters considered important to the operation of Boiler No. 2, and for which instrumentation was available include steam flow rate, steam pressure, feedwater flow rate, feedwater temperature, combustion air flow rate, combustion air temperature, % oxygen, I.D. fan pressure, F.D. fan pressure, furnace draft, and furnace temperature. No data were available for steam temperature, excess air, or the power consumption of the fans. A chart recording instrument located in the control room provided continuous instantaneous readings for steam flow rate, feedwater flow rate, and combustion air flow rate. These were read directly from the instrument in 1000's of pounds per hour, 1000's of pounds per hour, and 1000's of cubic feet per hour, respectively. These are given in Appendix D under the heading "chart recorder" for each of the three parameters. 2-1 250 �TABLE 2-1. DAILY SAMPLING SUMMARY Date (1980) 1 Inlet-North Test started at 0835 hours and ran for 350 minutes. Low volume was obtained. Test was discontinued because of unsuccessful leak checks after filter replacement. Test started at 0835 hours and ran for 193 minutes. Low volume was obtained. Battelle trap also appeared to plug up and was therefore changed. However, this did not occur during remaining tests. Filter blockage also occurred probably due to filter oven temperature not being hot enough (250°F). At 1600 hours the plant had to shut down due to boiler leaks. Test quality was fair. Outlet-North i ro Sampling locations Inlet-South 5/4 Test No. Test started at 0825 hours and ran for 404 minutes. No significant problems occurred. Test quality was good. Test started at 0820 hours and ran for 375 minutes. No new leak rate was obtained at filter change. New filter housing was found to be warped which caused the leak problem. Test quality was good. Sample was lost due to the wind blowing the filter out of the filter holder. No problems were encountered. Test quality was good. Outlet-South to Hi Volume Sampler 5/6 Continuous monitors Inlet-North Inlet-South Outlet-North Test comments Test were Test were with both Test Test were started at 1230 hours and ran for 525 minutes. There no significant problems. Test quality was good. started at 1230 hours and ran for 525 minutes. There no significant problems. Test was inadvertently stopped only 21 of the required 24 points traversed. However, gas volume and particulate collections were sufficient. quality was good. started at 1235 hours and ran for 500 minutes. There no significant problems. Test quality was good. �TABLE 2-1. Date (1980) 5/6 Test No. Sampling locations Outlet-South Hi Volume Sampler 5/7 ro ro m i ro co Continuous monitors Inlet-North Inlet-South Outlet-North Outlet-South Hi Volume Sampler 5/8 Continuous monitors Inlet-North Inlet-South Outlet-North Outlet-South (Continued) Test comments Test started at 1230 hours and ran for 500 minutes. Probe was found to be cracked at the end of test. However, based on a moisture calculation of only Z% (vs. 12% in other test), it appears that the probe cracked during the first 280 minutes. The probe was switched and the test continued an additional 200 minutes. Test quality was poor as only air was sampled for 50% of the test. Test started at 1311 hours and was stopped at 2325 hours, Test quality was good. Test quality was good. Test started at 0835 hours and ran for 420 minutes, No problems were encountered. Test quality was good. Test started at 0837 hours and ran for 480 minutes, No problems were encountered. Test quality was good. Test started at 0930 hours and ran for 500 minutes, No problems were encountered. Test quality was good. Test started at 0955 hours and ran for 500 minutes, No problems were encountered. Test quality was good. Test started at 1215 hours and was stopped at 2000 hours. Test quality was good. No problems were encountered. Test quality was good. Test started at 0845 hours and ran for 420 minutes. No problems were encountered. Test quality was good. Test started at 0832 hours and ran for 480 minutes. No problems were encountered. Test quality was good. Test started at 0930 hours and ran for 500 minutes. Low moisture obtained because of cracked probe. Test started at 0925 hours and ran for 500 minutes, No problems were encountered. Test quality was good. �TABLE 2-1. Date (1980) 5/8 Test No. Sampling locations HI Volume Sampler Continuous monitors 5/9 Inlet-North Inlet-South ro ro Ul u> Outlet-North Outlet-South HI Volume Sampler Continuous monitors 5/10 (Continued) Inlet-North Inlet-South Test comments Test started at 1015 hours and was stopped at 1910. Test quality was good. No problems were encountered. Test quality was good. CO readings were suspect, refer to 5/9/80 continuous monitoring data. Test started at 0820 hours and ran for 480 minutes. After 180 minutes the sampling time was increased from 20 to 25 minutes per point to collect sufficient sample volume. Boiler was operating at lower load conditions during this period. Test quality was good. Test started at 0805 hours and ran for 542 minutes. After 267 minutes the sampling time was increased from 20 to 25 minutes per point. (See Inlet-North above). Test quality was good. Test started at 0905 hours and ran for 500 minutes. Test quality was good. Test started at 0920 hours and ran for 500 minutes. Test quality was good. Test started at 0915 hours and was stopped at 1850 hours. Test quality was good. CO was exhibiting drift problems due to exhausted dessicant. Dessicant was therefore replaced. Previous days (5/8/80) data were suspect as CO dropped to lower level after dessicant changeout. Test quality was good. Test started at 0815 hours and ran for 420 minutes. No problems were encountered. Test quality was good. Test started at 0810 hours and ran for 480 minutes. No problems were encountered. Test quality was good. �TABLE 2-1. Date (1980) 5/10 Test No. Sampling location Outlet-North Outlet-South Hi Volume Sampler N> 5/11 Continuous monitors Inlet-North Inlet-South Outlet-North Outlet-South (Continued) Test comments Test started at 0915 hours and ran for 480 minutes. No problems were encountered. However, test was halted one point from completion due to stormy weather. There was little effect on test data. Test quality was good. Test started at 0840 hours and ran for 550 minutes. No problems were encountered. Test quality was good. Test started at 1100 hours and was stopped at 1900 hours. (Problems due to wind were encountered but the sample was not destroyed). Results were fair to good* CO was taken off line due to span and balance problems. Remaining data were good. Test started at 0828 hours and ran for 462 minutes. No problems were encountered. Test quality was good (changed sampling time to 22 minutes per point for inlet trains prior to starting test). Test started at 0934 hours and ran for 528 minutes. No problems were encountered. Test quality was good. Excessive number of filters were used during this test day for both inlet trains. Test started at 0900 hours and ran for 360 minutes. Due to excessive amount of time needed to correct malfunctioning equipment, the north train was utilized for only 20 points instead of the normal 25 points. Total volume sampled for north and south trains was 20 nr. Test quality was good. (Changed sampling time to 18 minutes per point prior to start of test). Test started at 0915 hours and ran for 540 minutes. South train traversed 30 points (see comments for Outlet-North train for 5/11/80). No problems were encountered and test quality was good. �TABLE 2-1. (Continued) Date (1980) 5/11 5/12 Test No. Sampling locations 7 Hi Volume Sampler 8 Continuous monitors Inlet-North Inlet-South Outlet-North Outlet-South ro i Hi Volume Sampler Ul t_n 5/13 9 Continuous monitors Inlet-North Inlet-South Outlet-North Outlet-South Hi Volume Sampler Test conments Test started at 1014 hours and was stopped at 1930 hours. Test quality was good. CO was still off line. Backup unit was ordered but had not arrived. Remaining data quality was good. Test started at 0840 hours and ran for 462 minutes. No problems were encountered. Test quality was good. Test started at 0837 hours and ran for 528 minutes. No problems were encountered. Test quality was good. Test started at 1040 hours and ran for 450 minutes. No problems were encountered. Test quality was good. Test started at 0854 hours and ran for 450 minutes. No problems were encountered. Test quality was good. Test started at 1243 hours and was stopped at 1840 hours. Test quality was good. No CO data was being monitored. Remaining data was good. Test started at 0833 hours and was down at conclusion of test quality was good. Test started at 0815 hours and quality was good. Test started at 0832 hours and quality was good. Test started at 0818 hours and quality was good. Test started at 0912 hours and Test quality was good. ran for 472 minutes. Boiler for grate cleaning. Test ran for 528 minutes. Test ran for 450 minutes. Test ran for 450 minutes. Test was stopped at 1820 hours. �TABLE 2-1. (Continued) Date (1980) Test No. Sampling locations 5/13 9 Continuous monitors CO was still off line, however remaining data was good. 5/15 10 Inlet-North Test started at 0805 hours and ran for 464 minutes. Test quality was good. Test started at 0803 hours and ran for 528 minutes. Test quality was good. Test started at 0840 hours and ran for 450 minutes. Probe was found with a cracked tip. Based on 8.9% moisture vs. 12% moisture for the other tests, it seems only the last 10 pts. were traversed with broken probe. Test quality was fair. Test started at 0820 hours and ran for 450 minutes. Test quality was good. Test started at 1110 hours and was stopped at 1840 hours. Test quality was good. New CO analyzer came on line. Test quality was good. Inlet-South Outlet-North Outlet-South ro i HI Volume Sampler 5/16 11 Continuous monitors Inlet-North Inlet-South Outlet-North Outlet-South Test comments Test started at 0830 hours and ran for 462 minutes. No problems were encountered. Test quality was good. Test started at 0924 hours and ran for 528 minutes. Final leak rate was not obtained, however the data was corrected by subtracting out the last two unknown points (35 cu. ft.). This caused little effect on the final outcome of the test. Test quality was good. Test started at 0808 hours and ran for 450 minutes. No problems were encountered. Test quality was good. Test started at 0828 hours and ran for 450 minutes. No problems were encountered. Test quality was good. �TABLE 2-1. Date (1980) 5/16 5/17 Test No. Sampling locations 11 Hi Volume Sampler 12 Continuous monitors Inlet-North and South Outlet-North and South Blank Hi Volume Sampler ro i CO 1-0 Ul Continuous monitors -J 5/18 13 Outlet-North Hi Volume Sampler Continuous monitors 5/19 14 Outlet-North and South Hi Volume Sampler Continuous monitors (Continued) Test comments Test started at 0306 hours and was stopped at 1910 hours. Test quality was good. THC data reading was high (300 ppm) between 1000 hours and 1030 hours due to temporary shortage of garbage in chute. Test started at 0928 hours and ran for 500 minutes. QA test was performed simultaneously at Inlets on the north and the south. Test quality was good. Test started at 0815 hours and ran for 250 minutes. This was the first day for the cadmium test. Test quality was good. Test started at 0820 hours and ran for one hour at 250°F. Test quality was good. Test started at 1028 hours and was stopped at 1835 hours. Test quality was good. No problems were encountered. Test quality was good. Test started at 0820 hours and ran for 250 minutes. For the cadmium test the outlet was only tested. No problems were encountered. Test quality was good. Test started at 0800 hours and was stopped at 1305 hours. Test quality was good. The outlet was only tested and no THC data was recorded since it was not required for the cadmium test. Test quality was good. Test started at 0810 hours and ran for 250 minutes. No problems were encountered. Test quality was good. Test started at 0800 hours and was stopped at 1300. Test quality was good. No problems were encountered. Test quality was good. �TABLE 2-2. DAILY DATA SUWWRY Gas Composition^' Samplt Volume Dm (1980) Tert No. Sampling Location 1 5-6 2 5-7 3 00 5-8 5-9 4 5 5-10 6 5-11 7 5-12 8 ""« o"'*' ""«< Ou "« ""« Ou <"< °«««< ""« £2 £2 22 22 S3 22 *2S 22 22 O""" 5-4 £2 '•"«< °— '"•« *""•< °"<"' £2 £2 2SL rf 22 £2 "? THC ppm Stock Temperature *F Molecular Weight Moisture 177® 172 156 156 <2 <2 <2 <2 459.47 444.88 432.76 451.27 28.26 26.52 28.33 28.41 11.66 9.S7 11.56 10.87 ACFM DSCFM IMMCH wtlc Raw • % 20.17 21.27 36.40-39.33 50332.218 61074.783 49138.650 53102.715 24952.931 31543.243 25074.591 26754.698 90.82 79.24 94.61 97.96 12.24 12.03 12.47 2.95 20.62 18.42 38.21 40.60 51452.853 52895.304 51588.415 54822.866 25077.734 26217.875 25528.869 29782.359 96.25 98.32 98.85 93.23 28.34 28.36 28.39 28.41 13.43 13.26 12.88 12.75 19.90 21.23 38.70 38.87 49665.946 24406.919 61306.230 '30511360 49556.634 24144.057 52477.069 25634.970 98.17 97.71 100.75 96.29 445.36 460.60 454.20 464.32 28.57 28.50 28.82 28.47 11.27 11.85 8.60 11.60 19.34 19.96 38.39 41.69 48268.522 57305.160 51835.952 56292.592 24418.162 28349.017 26693.503 2773X316 100.22 97.28 96.59 100.04 <2 <2 <2 <2 423.77 460.80 449.64 437.76 28.30 28.20 28.17 28.24 14.14 14.94 15.46 14.89 17.71 V 17.31 32.99 32.48 44193.534 49705.623 44544.600 43856.604 22187.466 23679.562 21337.899 21431.687 99.85 101.90 105.57 107.99 . <2 <2 <2 <2 452.59 457.63 448.92 452.28 28.37 28.34 28.50 28.33 13.62 13.83 11.94 13.40 18.12 17.86 35.43 39.50 45257.690 51267.447 47837.327 53339.650 21770.430 24476.323 2357X100 25751.431 108.82 105.61 98.61 96.51 . <2 <2 <2 <2 463.29 462.48 462.53 447.47 28.19 28.15 28.37 28.30 13.86 14.24 12.91 13.52 19.12 18.51 38.99 38.13 47760.487 53212.640 42103.978 61760.300 22877.439 25400.444 20345.095 30126.657 100.85 100.82 99.20 102.22 <2 <2 <2 <2 456.24 468.33 44X84 452.88 28.40 28.38 28.41 28.42 12.57 12.79 12.21 12.08 17.58 19.11 36.73 39.17 43898.069 54933.801 49586.850 52884.900 21492.745 26479.880 24703.730 26093.924 98.95 94.93 102.67 100.42 CO ppm GMFlow SDCF Nm? 256.837 135.203 317.860 324.144 7.27 3.83 9.00 9.20 11.2 11.2 11.3 11 J 7.4 7.4 7.7 7.7 408.462 379.181 418.430 457.890 11.57 10.74 11.85 12.97 9.6 9.6 10.4 10.4 10.1 10.1 9.5 9.5 159 159 171 171 <2 <2 <2 <2 459.04 445.78 442.00 451.04 28.53 28.56 28.45 29.58 324.361 400.656 403.319 407.071 9.19 11.34 11.42 11.53 9.4 9.4 9.4 9.4 9.8 9.8 9.7 9.7 IBS 185 189 189 <2 <2 <2 <2 445.55 431.46 459.04 457.78 331.522 370.826 427.497 457.496 9.39 10.50 12.11 12.96 9.9 9.9 10.4 10.4 9.6 9.5 8.9 8.9 142 142 169 169 <2 <2 <2 <2 342.697 367.809 371.551 383.750 9.77 10.42 10.52 10.87 7.9 7.9 8.1 8.1 10.5 10.5 10.7 10.7 61 61 59 59 320.564 347.607 367.971 412.061 9.08 9.84 10.42 11.87 8.8 8.8 9.4 9.4 10.3 10.3 9.7 9.7 344.803 378.495 299.617 459.634 9.76 10.72 8.49 13.02 9.8 9.8 9.8 9.8 9.0 9.0 9.5 9.5 316.551 373.034 376.483 391.172 8.96 10.56 10.66 11.06 8.7 8.7 10.4 10.4 9.7. 9.7 9.0 9.0 * r % Velocity ft/sec �TABLE 2-2. (Continued) G n ixMnpoiilion^1 9 Outlet Inlet 5-15 10 Outlet Inlet 5-16 11 ro rwiti«t i i-jfi) Inler*' 5-17 12 5-18 13 5-19 14 Outlet . Moisture •F <2 <2 <2 <2 466.61 468.65 457.16 453.52 28.19 28.19 28.25 28.20 14.57 14.52 14.10 14.54 <2 <2 <2 <2 465.43 458.88 459.56 463.68 28.29 28.27 28.88 28.24 13.60 13.75 8.89 14.22 <2 466.32 467.67 466.72 28.49 28.42 North South North South 306.728 364.161 366.284 388.729 8.74 10.31 10.37 11.01 9.7 9.7 9.1 9.1 9.6 9.6 9.8 9.8 North South North South 338.450 376.856 377.441 396.275 9.59 10.67 10.69 11.22 9.4 9.4 9.7 9.7 Il l 98 98 North South North South 353.833 357.302 404.610 416.675 10.02 10.12 11.46 11.60 11.1 11.1 11.8 11 J 8.6 8.6 7.0 7.9 88 98 M <a North South 324.920 331.750 9.20 9.40 10.3 10.3 10.0 10.0 80 80 <2 <2 218.810 6.20 10.7 9.0 84 <2 . North South Velocity ft/sec Isokinetic Rale ACFM OSCFM 16.42 17.82 36.85 39.39 41015.923 51223.782 49744.800 19294.229 24032.783 23723.700 105.23 107.11 104.01 iaos 17.67 35.47 3&49 45076.682 50795.373 47889.900 51958.800 21919.803 24835.199 24697.316 25113.412 102.87 102.67 102.40 11.15 11.69 ia79 46930.228 -23389.304 2S8Z3.208 101.23 93.06 MM ii'-9 2*27 28.37 13.47 13.70 *7lf 17.25 16.85 n!ilJi?nfi nifwum 474.80 476.00 461.00 28.16 14.38 39.27 Iff8297 43045.650 48387.834 20524.938 23013.917 l?i"? 97.56 102.20 106035.080 51352.600 103.01 \ © 219.36 North South GaaFlow Molecular Weight Nm3 Outlet Inlet THC ppm SOCF Outlet® Inlet "P CO ppm OtOlNM Inlet Stack 02 I 5-13 Sampling Location "- Test No. wjopp Date (19801 Sample Volume 6.20 10.7 9.2 102 © 463,00 28.25 13.91 44.37 119798.300 57360.170 92.45 6.81 12.7 7.2 304 (!) 465.60 28.36 11.66 44.53 120233.700 69137.720 98.36 © 240.61 Test period average High due to excessive instrument drift Analyzer taken off line (see© ) Due to excessive leak rate in the north train. 60% of sample was collected with south train, 40% with the north Results t 10 ppm due to drift Inlet QA Test, Outlet 1st day Cadmium Test Inlet sample not required for Cadmium Test THC data not required for Cadmium Test �These three parameters were also monitored by means of integrating counters. Each numerical reading multipled by 150 yielded the amount of steam in pounds, the amount of feedwater in pounds, or the amount of combustion air in cubic feet. These numbers have been included in the tables in Appendix D in terms of 1000's of pounds or 1000's of cubic feet. The differences of these numbers were also calculated on an hourly basis to determine flow rates from these quantities and are listed under "digital integrator" in Appendix D. Each integrator reading is assumed to have been taken at the end of the hour in question. For instance, the 5 PM reading represents the hour ending at 5 PM, as opposed to the hour beginning at 5 PM. This was necessary in order to maintain consistency, especially in the case of the integrator differences. The difference between the 5 PM integrator reading and the 4 PM integrator reading represents the flow occuring between 4 PM and 5 PM, and therefore is a 5 PM flow measurement, according to this end-of-the-hour convention. Further, the digital counters recycle occasionally. Since the counters have six digits, the largest possible number is 999,999 x 150 * 1000 or 150,000. It must also be noted that even a 5 minute delay in taking a reading introduces a substantial error in the hourly value. Finally, these integrator values were the only readings not routinely taken by plant personnel on a 24 hour basis. As a result, large gaps exist in this data. Averages were taken over these periods whenever possible. The steam flow rate was also recorded on a continuous basis. This was done by an ink pen recorder located outside the control room. The recorder plotted instantaneous steam flow values on graph paper. Hourly values were recorded from these sheets, and are presented in Appendix D under the heading "disc recorder". Although this instrument may have been very accurate, the operators were not always careful at aligning the paper discs. The erratic nature of steam production at the plant was easily observable from these plots. Oscillations of an amplitude of 30,000 Ibs/hr and a frequency of 6-10 cycles per hour seemed typical. A sample plot is provided in Appendix D. 2-11 260 �Steam pressure, combustion air temperature, % oxygen, I.D. fan pressure, F.D. fan pressure, furnace draft, and furnace temperature were all noted from pointer gauges in the control room. The combustion air temperature was actually a measurement of the flue gas leaving the boiler and entering the economizer. The sensor for % oxygen was located on the ESP side of the economizer. It must also be noted that the furnace draft and I.D. fan meters were actually measuring a vacuum. Other information contained in the daily process data tables includes times of soot blowing, fuel input to Boiler No. 2, down time on Boiler No. 2, a daily barometric pressure and miscellaneous comments concerning the boiler operation. According to plant procedure, soot blowing should have always occurred at 3 AM, 11 AM, and 7 PM every day, but deviations from this schedule were often observed. Fuel input is usually expressed as crane loads, or charges of refuse. In only one instance was natural gas burned to start up the boiler. The amount of gas burned is reported in cubic feet, but the actual measurement involved reading a numeric counter and multiplying by 3.5. Down time is expressed as lost burning time, and was available by consulting plant records. The barometric pressure was obtained once a day from nearby Midway airport. Comments listed on the process sheets (refer to Appendix D) were derived from the operator's log book or by discussing plant conditions first-hand with the operators and firemen on duty. 2.2.1 24-Hour Data The means and standard deviations of the parameters included in the daily process sheets were calculated on a 24-hour basis for every day of testing. This information has been presented in Table 2-3. On some days Boiler No. 2 did not operate for the entire 24 hour period. For these days, data was not available on a 24 hour basis, consequently values have been calculated based on available information. Also, since the integrator differences were often averaged over long periods of time, it did not seem appropriate to provide standard deviations in these instances. A qualitative observation from Table 2-3 indicates that the plant operation is very uniform over a time average of one day. According to the daily process sheets, no strong diurnal variations occurred. This is not to say that large variations did not exist. Shorter averaging times (less 2-12 261 �i ;-3. a to* "Bctss »i« rw TH cmmo mimsi micim WI«««TI».I»IT •». z D»t« 5-4-80 5-6-8D 5-J-SU 5-8-80 5-9-80 5 M>-*0 5- 11-80 5-12-89 5-13-80 5-15-80 5-16-80 5-17-80 N«M " DUc Reorder (Ibt/hr) Chart Recorder (ll»/hr) Digital Integrator (tfas/hr) SteMrrttttire (pitg) KMOOO* 108000* 100000* 11389.3 9358.6 M 91000* 102000* 91000* 30891.2 11827.8 M FeedMter le^er*t«r« 1>F) Cn*«tfo« Mr Flo- 3 late Chart Recorder (ft /hr) Digital Integrator (ftVhr) Conbustlofi Atr Tei^erature (*F) Veneni 0>ygen 103000 »JOO» 99000 13078.3 11804.8 R» 102000 106000 103000 1T545.0 8801.8 M HMOOO 104000 WJOOO 10309.1 M9S7.8 M 100000 WOOD 102000 11262.9 14320.8 M 94000 104000 98000 10490.6 I42D5.S Rft 95000* tOtOBO* 100000* 14826.7 13869.7 RM 9COOQ 102000* 97000 97000 98000 47000 97N.9 1255.0 M M3000* 102000 100000 9330.3 94C5.0 M V2000* •HOW 99088 I395O.9 I3S76.9 m 92000 90000 93800 18800.6 19195.7 M t.O 270* 4.9 284 6.8 784 7.6 2H 6.' 7R5 «J8 783 4.4 282* 7.S 6.1 782 7.0 285* 4.9 284 4.7 277 5.3 9486.8 M 104080* 86000* 793S.6 M 103000 99000* 17740.4 Rft 96000 98000 16606.7 M M3000 102000 10908.6 M 101000 102000 12171.4 A* 102000 180000 13«68.4 Rft 102000 97000 13660.4 M 96000* 99000* K224.4 Nt 96000* IOODDD 9785.0 M 93000 95000 98)6.3 UK 99000 W2OOD* 17032.) » 103800 14676 .0 87000 13947 .9 277* 3.0 ?22* 3.2 220 1.0 720 0.6 220 0.8 271 1.4 270 f.l 221 2.1 270* 8.6 221 0.9 220 O.C 221 771 0.9 770 0.76 87000* 75000* 3010.4 M 79000* 74000* S369.7 M 77000 70000 4505.8 M 8 MHO 73000 S070.5 M 77008 70080 7494.8 M 79000 77000 7979.9 R* 17000 71000 4iB5.l « 77000 69000 46B5.C RA 78000* 70000* 4486.0 « 78000* 72000 5348.0 RH 87000 74000 S7S3.4 W 82000 73080 5«93.7 M 80000 72000 43K.9 m BIOOB 79000 9279.8 M 6S8* 126.3 681 642 26. t 662 27.3 67D 615 38.9 653 651* 71.5 660 66C 73.0 «51 25.8 67S 31.2 V*.I* 21.7 ln . tt.B* 5.0 10.5 306.0 1209 39.4 1.5C \ZA 1.6 U.I t.55 (t.O 20.1 \A\ U.I t.JB 11.1 77.4 1.M 66S* 49.7 M.7* 2.M 1168* 108.7 283 983'.B 9367.3 m 5-19-80 o 98000* 97000* m* 284 8868.5 99*9.8 M PteM 283* Fec«Wt«r F!M flat* Chart Recorder (Ita/hr) Digital Integrator (Ibi/hr) 59.4 »3000 W8000 107000 5-M-80 • 11.1 1.35 13.5 3S.4 2.13 MM 8.93 1. 12 •MOO M.I m 1.50 nooo 12.6 * 1.20 MjO »?0 Fwnace Te^wrater* (f) 1178* * Does not raprtimt fall 24-hB«r period NJ ON ro *1.2 1096* RK • Rot JlpproyrUtt 71.0 IH? 72.7 1189 107.8 1164 77.3 1203 186.4 1)60 «8.l 1170 65.S 1112 60.8 1204 78.« 1207 «.6 1081 99.0 2-13 �than an hour) would indicate large swings, and this is reflected in the large standard deviations for steam production in Table 2-3. This was due to the intermittent nature of fuel feed to the boiler. However, these production swings did not depend on time of day or day of week. Consequently, it was possible to calculate means and standard deviations over a large number of test days. This has been done for all of the test days (refer to Table 2-4). An examination of data in Table 2-4 indicates that the standard deviations are smaller than most of the standard deviations in Table 2-3. Although variations may be expected to decrease over longer averaging times, this would not be true if certain days had significantly different modes of operation. The aforementioned therefore indicates that the Chicago Northwest Incineration facility operates in essentially the same mode 24 hours a day, 7 days a week, although instantaneous swings in steam production do occur continuously over short time intervals (less than one hour). 2.2.2 Test Duration Data Means and standard deviations have been calculated on a test duration basis for all of the test days. This information has been provided in Table 2-5. The discussion on diurnal variations pertaining to the 24-hour data also pertains here, although the standard deviations should, in general, be smaller due to the shorter period of time being considered. An examination of the data in Table 2-5 bears this out. None of the data in Table 2-5 appears particularly anomalous. No significant variation in steam production occurred from day to day indicating a rather consistent fuel feed rate during the duration of the tests. Some days exhibited wider variations as reflected by higher standard deviations, particularly on the 19th of May, The variation of feed water flow does not corelate well with the variation in steam production. The operating parameters seemed to fluctuate rather independently, without any pronounced impact on other aspects of plant operation. 2-14 263 �TABLE 2-4. MEANS OF THE MEANS FOR 24-HOUR PROCESS DATA, ALL TEST DAYS, CHICAGO NORTHWEST MUNICIPAL INCINERATOR. Parameter Steam Flow Rate (Ibs/hr) Disc Recorder Chart Recorder Digital Integrator Steam Pressure (psig) Feedwater Flow Rate (Ibs/hr) Chart Recorder Digital Integrator Mean a 99,000 103,000 99,000 282 4,516.8 3,577.0 4.02 99,000 97,000 4,822.7 5,445.5 221 0.7 79,000 72,000 2,016.4 2,593.3 663 21.2 Feedwater Temperature (°F) Combustion Air Flow Rate (ft /hr) Chart Recorder Digital Integrator Combustion Air Temperature (°F) % Oxygen 11.8 1.23 I.D. Fans Pressure (inches H20) 2.6 0.22 F.D. Fans Pressure (inches H20) 14.1 0.38 Furnace Draft (inches H20) 0.23 Furnace Temperature (°F) 1,160 2-15 264 .061 41.5 �UBXE 2.-, . UST DUMIHBI mass D*U rot rat CHICAGO miMCSi mnicirni Date 5-4-80 5-6-80 S-7-M 5-8-80 5-9-80 5-10-80 "*an StewFlw **t* Disc R«cor4er (Ita/hr) Chart *«C«ntor (lb»/hr) Dljltal InteyHOr (Ibt/hr) StM«Pr«wrc (Bilg) F *ctjrt*»«iXV(IH/hO Bt.ltll iHtefritor (m/V) FertMtcr tv-twratw-c (T) CvtwsttM Air Flo. lite Chart Recorfer (rtVhr) Olfltal Integrator (ftVhr) Cnatasttwi Air Te-veratwe (T) Percent 0*rf*« FBTMCC TtJV«ratvrc (*F) • SOME data points tr* mi**l*i 96000 103000 91000 HH46.3 11319.2 W 98000 104000 104000 17676.4 7H6.1 M W7000 1IB8O 108006 286 7.4 286 7.0 288 95000 90000 7SS9.3 M 104000 100000 7146.1 M M8000 183000* 22J 3.6 221 2.1 87000 7MMO 3770.1 M 79000 74000 701 724 K -* 1M9 26.2 '-*' 45.8 »•' T20S Ne«n 17509.6 12878.7 * 110000 11)000 113000 8165.6 3500.0 IN 103000 112000 MKOBO 12202.5 16465.8 M 99000 109008 WWOO 11121.8 12)01.8 M 4.1 284 6.1 290 8.0 288 6.) 284 S.S 285 5.0 8738.6 M 9SOOO H2000 24494.9 M 114000 I MOOT 4I8S.6 M tMOOO WS008 18C09.6 M 107000 KKOOO 1)64 JJ M 103000 H3000 KH43.5 M 220 1.5 220 0 271 1.7 221 14 222 3.1 4743.4 M 77000 690OD 4101.0 M 80000 73000 3503.2 M 77000 67000 3492.1 Hft 79000 70008 8350.6 M 76000 69000 MM.* M 76000 7 1000 5186.5 M 31.4 6TB 33.2 646 29-* 676 28.5 611 27.1 G92 653 18.9 S9.9 »•* 1275 '•" 52.4 "•* 1189 '-u 71.8 220 *•' 1290 9 '•** 67.9 tt -° 12(75 2 n - 100.6 94 1264 21.6 1.64 M.S 97000* tOSOOO 105000 5- 1?-BO • 110000 111000 104000 '-14 63S6.1 9)42.8 « S- 1 1-80 • M.S I19S 11BB6.0 MH22.0 HA 1.83 121.2 ttun S- 11-80 « 96000 10 WOO KXDOO* 284 102000 WOOOO* 220 77000* 68000* 672 11.1 UN Ncln 1)785.7 N319.4 M 95000 94000* 100000 6.8 287 6687.5 IN 98000* 104000 0.* 220 5669.5 IN 77000* 70000 38.8 S- IS 80 • 657 1.42 48.1 11.2 1188 II2'6.) 3*11.1 M 3.5 8292.6 M 0 U74.7 M 23.1 1.32 73.8 HCM 5- 16-80 • 95000 99000 92000 287 93000 9)000 220 88000 72000 647 14.0 1129 10 MB. 8 7153.6 M 3.3 10972. > M 0 H43.4 M 28.7 1.01 64.7 5- 17-80 • NCM 10)000 106000 94000 289 104000 84000222 81000 67000 671 9.8 12)8 Plean 8533.4 879S.2 IW 5-18-80 a HTOOO 106000 104000 Mean 11604.6 33M.6 M 79000 82000 7 NOD 23741.7 3Q7H.J HI 2.9 288 2.4 281 2.5 8266.4 M 108000 117000 5000.0 M 80000 7 WOO 1789S.S M 0.9 221 1.2 222 1.0 SHOO 69000 2500.0 M 4313.S -ft 75.8 l.ZS 62.6 80000 73000 690 D.9 1269 0 M 8.2 37.5 68.1 645 1.64 13.1 T019 W • MH Appropriate hJ Ul 5- 19-80 • 2-16 1.11 134.1 �2.2,3 Meekly Refuse and Residue Inventory All refuse and residue hauling trucks entering and leaving the incinerator plant were carefully weighed. This facilitates the accurate characterization of overall inputs and outputs. However, there is no accurate way of proportioning these materials between specific boilers for a given period of time. Any attempt to determine the fuel burned or ash discharged from Boiler No. 2 can only be an approximation. Chicago Northwest Incinerator maintains inventory sheets listing inputs and outputs from the facility on a weekly basis. Relevant data from these sheets have been reproduced in Table 2-6. The weight of refuse received was measured on scales before and after the refuse trucks released their loads. The volume of refuse received was determined by multiplying the number of truck loads by the volume of each truck (19.5 cubic yards). Density of the refuse was estimated using these two measurements, and is therefore the density of refuse inside the trucks. In order to quantify the amount of refuse burned, the number of loads, or charges, handled by the grab bucket cranes were noted for each boiler. A total number of charges are listed in Table 2-7. The charges delivered to Boiler No. 2 are given in the daily process data sheets on a shift basis. These are provided in Appendix D, To approximate the amount of refuse burned in Boiler No. 2, it is necessary to determine an average weight per charge, since the number of charges fed into this boiler are known (Appendix D). The method for doing this, however, is not entirely obvious. When refuse trucks enter the plant, they discharge their contents into a large storage pit. Although the weight of refuse added to the pit is well characterized for each weekly period, the carry-over of material from week to week cannot be accurately measured. Furthermore, this carry-over is quite variable over the length of time being considered. It is also significant, as the pit is sometimes over half full, corresponding to roughly 5000 cubic yards of refuse. It is necessary to quantify the carry-over in terms of weight, so that the total weight of refuse burned, and hence, the average weight per charge, can be approximated. This can be done by 3 different methods. 2-17 266 �TABLE 2-6. WEEKLY INVENTORIES OF REFUSE AND RESIDUE AT THE CHICAGO NORTHWEST MUNICIPAL INCINERATOR (ALL BOILERS). 4/28/80 to 5/4/80 5/5/80 to 5/11/80 5/12/80 to 5/18/80 5/19/80 to 5/25/80 6,746.65 24,490 551 9,152.34 29,618 618 7,902.34 26,561 595 8,720.21 28,778 606 84 65 61 42 65 61 42 42 5,205 5,710 5,952 4,714 2,771 7,212 28,562 3,240 9,250 36,634 2,812 8,367 33,138 3,700 8,720 34,535 2,511 3,100 2,500 3,086 1,815 2,240 2,904 3,585 Metal fraction (tons) Metal fraction (cubic yards) 949 5,423 750 4,286 1,514 18,651 629 3,594 Total ash (tons) Total ash (cubic yards) 3,460 8,523 3,250 7,372 3,329 10,891 3,533 7,179 70% 80% 67% 79% 52% 65% 60% 60% Refuse Received By weight (tons) By volume (cubic yards) Density (lbs/yd3) Storage Pit Condition At beginning of week (% full) At end of week (% full) Refuse Consumed # charges burned Average weight per charge (Ibs) Total weight (tons) Total volume (cubic yards) Residue Fine ash fraction (tons) Fine ash fraction (cubic yards) Volume Reduction thru incineration Weight Reduction thru incineration 2-18 267 �TABLE 2-7. CHARGES FED TO EACH BOILER ON A SHIFT BASIS CHICAGO NORTHWEST INCINERATION FACILITY Unit No. 1 Unit No. 2 Unit No. 3 88 101 101 27 89 35 -78 75 38 94 101 101 97 33 27 62 20 94 36 101 98 99 100 94 101 90 94 101 94 49 98 100 98 101 100 102 99 97 96 12 -- 101 100 101 89 97 94 99 94 95 45 93 98 95 96 102 96 97 98 93 101 100 Total for week 1398 1823 1984 Date, Shift 4-28, 4-29, 4-30, 5-1, 5-2, 5-3, 5-4, 5-5, 2nd 3rd 1st 2nd 3rd 1st 2nd 3rd 1st 2nd 3rd 1st 2nd 3rd 1st 2nd 3rd 1st 2nd 3rd 1st 2-19 268 Unit No. 4 Total 287 300 302 210 287 219 193 273 264 132 285 299 294 294 235 225 258 215 283 149 201 0 5205 �TABLE 2-7. Date, Shift 5-5, 2nd 3rd 5-6, 1st 2nd 3rd 5-7, 1st 2nd 3rd 5-8, 1st 2nd 3rd 5-9, 1st 2nd 3rd 5-10, 1st 2nd 3rd 5-11, 1st 2nd 3rd 5-12, 1st Total for week Unit No. 1 Unit 106 83 102 104 70 37 14 . 101 (Continued) • • • No. 2 Unit No. 3 -._ 68 112 99 101 86 103 107 111 98 77 102 102 101 101 101 98 52 101 103 102 99 104 84 100 81 101 100 100 98 100 99 101 100 102 101 105 103 83 97 101 101 98 100 100 101 101 100 102 103 101 102 100 1860 1754 2096 Unit No. 4 2-20 269 Total 207 169 205 279 293 234 181 298 259 304 300 301 299 302 298 253 303 308 304 306 307 0 5710 �TABLE 2-7. (Continued) Date, Shift 5-12, 2nd 3rd 5-13, 1st 2nd 3rd 5-14, 1st 2nd 3rd 5-15, 1st 2nd 3rd 5-16, 1st 2nd 3rd 5-17, 1st 2nd 3rd 5-18, 1st 2nd 3rd 5-19, 1st Total for week Unit No. 1 Unit No. 2 Unit No. 3 39 97 102 104 98 100 98 94 99 99 100 100 60 --96 98 99 100 104 103 236 295 302 308 261 100 96 102 200 194 292 106 105 107 104 106 108 106 97 110 107 106 no 85 108 320 318 321 324 220 330 98 118 112 97 114 112 98 108 334 293 340 106 75 -- 108 104 118 109 105 124 -- 105 110 323 284 242 215 1943 2194 108 38 112 no 1815 Unit No. 4 no 2-21 270 0 Total 5952 �TABLE 2-7. (Continued Unit No. 1 Unit No. 2 Unit No. 3 5-19, 2nd 3rd 5-20, 1st 2nd 3rd 5-21, 1st 2nd 3rd 5-22, 1st 2nd 3rd 5-23, 1st 2nd 3rd 5-24, 1st 2nd 3rd 5-25, 1st 2nd 3rd 5-26, 1st „ 103 110 105 104 118 110 100 106 90 80 105 100 114 105 106 100 108 103 104 Total for week 416 Date, Shift 104 120 __ — -68 21 -__ — -__ — — __ — — -— 107 105 2139 107 107 102 98 105 94 101 105 2-22 271 Total 224 313 314 338 218 203 210 246 183 88 82 107 100 104 104 100 92 107 101 104 108 102 100 2159 Unit No. 4 212 200 211 211 202 190 212 195 205 213 209 205 0 4714 �The first method involves using visual measurements of the pit volume taken at the end of each week. This "pit estimate" can then be used in association with the density of the incoming garbage to approximate the weight of refuse in the pit. Then the average weight per charge can be determined by the following equation: Average wt per charge (pit estimate for previous week - pit estimate ~ + refuse delivered) * total number of charges All terms in parenthesis must be expressed as weights. This method however has a drawback in that the density in the pit is probably not the same as the density inside the refuse trucks, since the refuse inside the trucks is compacted and is liable to expand somewhat as the trucks are unloaded. The second method is essentially the same as the first, but a different assumption is made for pit density. It seems likely that the level of compression would have a more pronounced effect upon the refuse density than the actual characteristics of the refuse. Since the compaction inside the pit is always similar, one would also expect the density in the pit to be reasonably constant. In principle, this is the method applied by the plant personnel, but in practice it is not consistently used by them. It has been found from plant operational experience that a density of 505 Ibs/yd is typical of the pit contents. Therefore, this value can be used as an assumed density, and the pit estimates used in the equation as before. The third method circumvents the problem of pit estimation entirely. Assuming that every charge constitutes a full load of the crane grab bucket, the weight of the charge can then be estimated by multiplying the maximum volume of the bucket by an assumed density. The maximum volume of the bucket is five cubic yards. The primary disadvantage of this method is that any inaccuracy in the density is directly reflected in the average weight per charge. In this report the second method was chosen as the most appropriate, and the values for total refuse consumed and average weight per charge were tabulated (refer to Table 2-6 ). A constant, assumed pit density (assumed in method 2) was preferred to a variable "measured" density of method 1. 2-23 272 �Furthermore, a "bad" density assumption will cause smaller errors in the first and second cases than in the third case. The second method can be summarized as follows: Volume of refuse in pit = pit estimate (% of total volume) X total pit volume 100 total pit volume = 9700 yd3 Weight of refuse in pit = volume of refuse in pit X refuse density in pit assumed refuse density = 505 Ib/yd Weight of refuse incinerated per week = (weight of refuse in pit at beginning of week - weight of refuse in pit at end of week + weight of refuse delivered) Average weight per charge = total weight of refuse incinerated total number of charges Volume of refuse weight of refuse incinerated incinerated - assumed refuse density The amount of fine ash and metal fractions produced by the incinerator during the test period are listed in Table 2-6 . It should be noted that these are the amounts leaving the plant during this time period, and are not necessarily the same as the ash being produced during this period. Since no account has been taken of any carry-over from week to week, it can only be assumed the carry-over is similar each week. In order to obtain total ash, the metal and fine ash fractions were summed together. The ash volumes were calculated using the following densities: Density of fine ash fraction = 1620 Ibs/yd Density of metal fraction = 350 Ib/yd3 These values are based on previous analyses done by the plant, and have been assumed to be typical. Since all of the combined ash was subjected to a water quench, these weights incorporate a rather large moisture content. However, no better characterization was available. The volume and weight reductions achieved through incineration have been calculated as an indication of how efficiently the boilers were operating. 2-24 273 �The ash produced by each boiler can be estimated by either of two ways. First, by estimating the number of hours each boiler was down, the total number of operating hours can be found, and an approximate ash production rate per boiler operating hour can be calculated. All necessary information concerning boiler down hours is presented in Table 2-8. Alternatively, by knowing the number of charges fed to the boilers in a weeks time, an approximate ash production rate per charge of refuse can be calculated. A distribution of charges fed to each boiler on a shift basis is presented in Table 2-7. 2.3 CONTINUOUS MONITORING DATA Table 2-9 presents daily averages of 02, C02, CO, total hydrocarbons, and ambient temperature as monitored by continuous data logging instrumentation over test duration periods. Hydrocarbon values were consistently lower than the instrument sensitivity of 2 ppm. Most of the data indicates very little variation except for the CO values. The rapid change between May 8, 1980 and May 9, 1980 was due to instrument drift, which places doubt on the validity of the previous data also. The CO analyzer was taken off line, and a new one replaced on May 15, 1980. The high CO value on May 19, was due to unusally high moisture in the fuel on this day. Moreover, the operators did not compensate for the wet feed by changing boiler condition. They were reluctant to change conditions because a new supply of dry feed was anticir pated. The high moisture content in the fuel probably inhibited combustion and made burning less efficient. This is reflected in higher 02, lower C02, and higher CO concentration as compared to those on normal operating days. In Table 2-10, values of percent oxygen measured in the control room and by TRW continuous monitoring instrumentation are compared. The control room readings were observed to be higher than the 02 analyzer readings on all days except one. This is unusual since the readings should be identical. In any event, the 02 analyzer should either yield identical or higher readings, because the sample was obtained further downstream and any leakage in the duct would tend to increase the 02 level of the gas stream. This discrepancy could be due to offset instrument calibrations. It must be noted that the 02 analyzer indicating lower readings was calibrated (for zero and span) prior to the start of testing and also after the testing concluded for each test day. The control room oxygen analyzer was calibrated once a week. 2-25 274 �TABLE 2-8. DOWN TIME EXPRESSED AS LOST FURNACE HOURS FOR THE ENTIRE CHICAGO NORTHWEST INCINERATION FACILITY Unit Unit No. 2 Unit No. 3 Unit No. 4 Total 16 0 0 1 8 0 15 9 5 0 0 7 0 0 0 6 0 0 0 24 24 24 24 24 24 24 25 32 41 43 24 39 40 ~57~ ^T3~ T- T5S~ 2~4T~ 0 5 13 2 0 5 0 24 12 0 2 0 0 0 0 0 0 0 0 24 24 24 24 48 41 37 28 0 0 24 24 24 24 29 24 25 38 0 168 231 5 0 0 0 6 0 11 0 5 16 0 1 0 0 0 0 0 29 29 40 0 0 24 24 24 24 24 24 24 ~22~ "22" ^r T58~ 2l3~ 10 0 8 18 23 24 24 24 0 0 0 24 24 0 0 0 0 0 24 24 0 0 0 1 0 24 24 24 34 32 42 47 48 49 48 Total for week 131 0 1 168 300 Total 235 73 8 672 988 Date 4-28-80 4-29-80 4-30-80 5-1-80 5-2-80 5-3-80 5-4-80 Total for week 5-5-80 5-6-80 5-7-80 5-8-80 5-9-80 5-10-80 5-11-80 Total for week 5-12-80 5-13-80 5-14-80 5-15-80 5-16-80 5-17-80 5-18-80 Total for week 5-19-80 5-20-80 5-21-80 5-22-80 5-23-80 5-24-80 5-25-80 No. 1 1 8 0 1 Total possible hours • 2688 Hours lost » 36.8% 2-26 275 24 32 24 35 �TABLE 2-9 . Sampling Location oz (») Date (1980) CONTINUOUS MONITORING DATA co2 Mean a Mean CO (pom) (*) a THC (ppm) Mean o Mean a *nb1ent Temperature (°C) Mean o ESP Inlet ESP Outlet 7.4 7.7 1.07 0.82 172 156 32.76 25.38 <2 <2 24.7 2.36 5-6 9.6 10.4 1.43 1.37 10.1 9.5 1.34 1.20 163 171 20.92 25.04 <2 <2 15.5 5.45 5-7 9.4 9.4 1.06 1.78 9.8 9.7 0.96 1.51 185 198 17.28 44.88 <2 <2 11.6 1.10 Inlet Outlet I 1.38 0.90 Inlet Outlet N> 11.2 11.3 Inlet Outlet ro 5-4 5-8 9.9 10.4 1.98 1.81 9.5 8.7 1.B1 1.43 142 169 51.32 90.54 <2 <2 10.0 1.21 Inlet Outlet 5-9 7.9 8.1 1.09 1.62 11.0 10.7 0.96 1.37 78 71 38.76 38.66 <2 <2 14.1 1.98 Inlet Outlet 5-10 8.8 1.36 <2 18.4 3.56 1.74 10.3 9.7 1.38 9.4 Inlet Outlet 5-11 9.8 9.8 1.18 1.58 9.5 9.5 1.06 1.05 <2 <2 16.7 1.77 Inlet Outlet 5-12 9.6 10.4 1.11 1.69 9.7 9.0 0.89 1.42 <2 <2 12.4 0.66 Inlet Outlet 5-13 9.7 9.6 1.67 1.42 9.6 9.8 Inlet Outlet 5-15 10.2 9.6 1.51 1.47 Inlet Outlet 5-16 11.1 11.8 Inlet Outlet 5-17 Inlet Outlet 5-18 Inlet Outlet 5-19 1.54 Instrument Malfunc. tion ., <2 H n N M .38 .14 " " <2 <2 11.6 5.60 9.4 9.7 .38 .18 112 98 36.01 25.70 <2 <2 15.6 2.71 1.39 1.32 8.5 7.9 .18 .16 88 98 61.92 75.58 <2 <2 16.3 1.19 10.3 10.7 0.90 1.36 10.0 9.0 0.75 1.17 80 84 29.61 27.26 <2 <2 12.8 1.23 Kl_«. 12.0 1.34 0.93 not Required 10.7 u_a. HOt Required 13.0 0.96 12.7 1.86 n^+ . n-.*- -. taken for outlet only 0.35 102 9.2 —• 18.71 taken for outlet on 1 y 304 1.69 7.2 184.86 �TABLE 2-10. Testing Date 5-4 5-6 5-7 5-8 5-9 5-10 5-11 5-12 5-13 5-15 5-16 5-17 5-18 5-19 MEANS OF PERCENT OXYGEN TAKEN BY CONTROL ROOM GAUGE AND 0« ANALYZER FOR TEST DURATION Control Room (%) 16.4 10.1 10.3 11.5 9.2 12.0 9.8 10.3 11.1 11.2 14.0 9.8 10.9 13.1 2 Analyzer Difference (ESP inlet) (%) (Control Room Analyzer) 11.2 9.6 9.4 9.9 7.9 8.8 9.8 9.6 9.7 10.2 11.1 10.3 10.7 12.7 2-28 277 5.2 0.5 0.9 1.6 1.3 3.2 0.0 0.7 1.4 1.0 2.9 -0.5 0.2 0.9 �3.0 PLANT DESCRIPTION Chicago Northwest Incinerator is located south of W. Chicago Avenue between the tracks of the Chicago and North-western Railway on the west and Kilbourn Avenue on the east. The principal building of the complex is the Incinerator, a multi-storied structure of reinforced concrete with dimensions of 330 feet by 180 feet and with a maximum height of 79 feet from grade to the main floor. The lowest part of the structure is the floor of the refuse storage pit, approximately 37 feet below grade. To the south of the Incinerator Building and connected to it by the residue conveyors enclosure is the Ash Discharge Building. To the north is the Incinerator Office Building which also houses the maintenance shops. Two stacks each 250 feet in height are located east of the Incinerator Building. The electrostatic precipitators and the induced draft fans are situated between the Incinerator Building and the stacks. The Chicago Northwest Incinerator layout is shown in Figure 3-1. The general characteristics of the Chicago Northwest Incinerator are listed in Table 3-1. 3.1 General Description Refuse is delivered to the dumping pit of the plant by trucks which back into position above the refuse pit. From the refuse storage pit, crane grapple buckets pick up the refuse and dump it directly into the four furnace feed hoppers. The furnace feed hoppers open into feed chutes which feed automatically onto the stoker grates of the four furnaces. The grates operate with a reverse-reciprocating action producing an initial downward movement of the refuse and then an upward movement. This combined movement results in a tumbling action. The motion of the grates, an underfire grate jet action, and overfire air jets above the grates all combine to promote highly effective burn-out and complete oxidation of the furnace gases. The hot furnace gases travel through five boiler passes enroute to the electrostatic precipitator (ESP). Approximately 110,000 pounds of steam is generated by each of the four boilers. In passing through the boiler, the 3-1 278 ' �WEIGF STATION ^STACKS CHICAGO NORTHWEST INCINERATOR ELECTROSTATIC PRECIPITATOR ASH REMOVAE EQUIPMENT INCINERATOR 286 REFUSE STORAGE PIT I IN) 330' TIPPING FLOOR AREA VO SERVICE STATION PARKING AREA Figure 3-1. Layout of plant site �TABLE 3-1. CHARACTERISTICS OF CHICAGO NORTHWEST INCINERATOR Number of incinerator units Number of refuse cranes Number of chimneys Refuse pit capacity Capacity of each crane bucket Average heating value range of refuse Capacity: Refuse Steam Generation Furnace temperature Stack gas temperature Gas cleaning equipment Precipitator efficiency Precipitator outlet grain loading 4 3 2, each 250 feet high 9,700 cubic yards 5 cubic yards 5,000 BTU/lb 1,600 tons/days 440,000 Ibs/hour 1,500° - 2,000°F 450°F 4 electrostatic precipitators 972 0.05 grains/std. cu. ft. gases are reduced in temperature to approximately 450°F. The residue from the grates and the fly ash collected by the ESPs are dumped into the ash discharger. The discharger which is partly filled with water quenches the ashes and via residue conveyors transferred to the ash building. The ashes are then screened. Salvageable metals are sold for reuse. The remaining ashes are taken from the ash building by trucks and used in construction projects or places as sanitary landfill. A line diagram of the Incinerator is presented in Figure 3-2. 3.2 DETAILED DESCRIPTIONS 3.2.1 Refuse Handling Mixed refuse from domestic sources 1s brought to the incinerator plant in collection trucks, each truck has a capacity of 5 tons or 25 cubic yards. The refuse averages 400 pounds per cubic yard. The refuse varies considerably in consistency and moisture content over a period of time and 3-3 280 �r TRUCKED REFUSE FEED MATER AIR COOLED CONDENSERS UPSCALE REFUSE DELIVERY PIT EH i REFUSE FEED HOPPER I BOILER OVERFIRE •> COft€RCIAL STEAM STEAM DRUMS INTAKE FAN i. • BOILER HOPPER FLY ASH (ECONOMIZER] 1 HOPPER 1 AIR hO 00 S T A C K 1 HOPPER i f f ASH DISCHARGE HOPPER STOKER GRATES COMBINED ASH SIFTING GRATES I FORCED DRAFT FAN HEAVY METALS Figure 3-2. Flow diagram of Chicago Northwest Incinerator FINE ASH �this condition is reflected in the changeable calorific (heat) content of the refuse. Trucks are weighed over scale platforms. After weighing these trucks are directed to eleven stalls in front of the refuse storage pit. After depositing their load the trucks leave the building through doors in the south end. Refuse items that are too large to be handled through the charging hopper and feed chute (such as mattresses, upholstered furniture, etc.) are removed. Bulky metal objects from the storage area are removed by trucks. The refuse storage pit has a storage capacity of 9,700 cubic yards or 1,940 tons or sufficient "fuel" to last 29 hours when the four incinerators are operating normally. This necessitates refuse collection on six days of the week. However this is not always possible due to various reasons such as unfavorable weather etc. At such times auxiliary gas firing is utilized to meet steam demand and to keep the furnaces from cooling down. The refuse is removed from the pit by one of three transfer cranes. These cranes are overhead, high speed, two-girder, single trolley, travelling, grab bucket cranes each of 8.5 tons capacity handling mixed refuse from the storage pit to the furnace charging hoppers. An auxiliary hoist of 2.5 tons capacity is provided on each of the end cranes and mounted on crane trolleys. Each crane bucket has a 5 cubic yard capacity and is a fourline, line-type grapple. All crane components are electric motor driven under control of an operator in a cab suspended from the bridge and located so as to permit the operator to see the bottom of the refuse storage pit as well as the charging hoppers. The cranes are capable of performing a maximum of 29 cycles per hour per crane including an allowance of approximately 20 percent for rehandling refuse and other interruptions. The cranes span 44' - 8" center to center of rails and the crane runaway is 286' - 0" in length. Crane operations are manually controlled from within each respective crane cab. Each refuse transfer crane was initially equipped with solidstate computerized weighing systems to record the amount of material charged into the hoppers by each crane and also record into which hopper the material is charged. Due to various problems the use of the solid state systems was abandoned and now the number of times the refuse is charged into the hopper 3-5 282 �is monitored manually by the crane operator. of 5 cubic yards capacity. 3.2.2 Each charge is assumed to be Refuse Burning The plant has four incinerators each having a nominal burning capacity of 400 tons per 24 hour day. Each incinerator has a charging hopper, feed chute, hydraulic powered feeders and stoker (manufactured by Josef Martin, Germany), boiler, economizer and fly ash hoppers. Draft throught the furnace (boiler) is provided by forced draft fans, overfire air fans and induced draft fans. Refuse in the charging hopper of each incinerator flows by gravity from the hopper to three stoker feeders through a feed chute, the lower portion of which is water cooled. Near the bottom of each charging hopper is a hydraulic powered pivoted type gate normally open but closed when the feed chute is empty of refuse. The charging hopper gates are manually controlled through operation of a four-way valve on the charging floor. The stoker feeders at the bottom of the feed chute push the refuse into the stoker by the reciprocating action of their hydraulic powered rams. The stokers of each incinerator are assembled with three runs or sections and have a sloping activated surface consisting of 17 rows of grate steps. The grate sections incline from the hortizontal at an angle of 26°, the lower end being at the rear. The stoker is of the reverse acting, reciprocating grate type. Alternate lateral rows of grate steps have controlled continuous reciprocating action with the moving grate steps pushing in reverse direction to the flow of refuse. This action moves a portion of the burning refuse under the unignited material and thereby effects an agitation and blending of the whole burning mass. Combustion air entering from below the grates cools the grates, helps to agitate the burning refuse and supplies the oxygen which produces a maximum burn-out in the shortest length of grate travel. Although the spacing between the grate bars comprises less than two percent of the total grate area, it is still possible for small siftings or ashes to find their way through the grate. These ashes are handled by the automatic sifting discharge which extends underneath the air plenum chambers serving the stoker. At regular intervals high pressure air is 3-6 283 �directed through the siftings channel, driving the siftings into the ash discharges. In order to obtain maximum burn-out, the depth of the refuse bed is controlled by automatic discharge or clinker rollers located at the end of the grate. As the residue reaches this point it is dumped into the Martin ash discharger where it is immediately quenched in water. The residue, following quenching by means of a hydraulic powered ram is pushed up an inclined slope which permits draining. This produces a residue of less than 15 percent moisture, and permits dry type conveying. In addition to quenching, the ash discharger also serves as a water seal for the furnace. This seal prevents infiltration of air into the furnace which is under negative pressure. Each refuse burning boiler is provided with two gas burners suitable for use with natural gas. They are automatically controlled and have an electric ignition. 3.2.3 Residue Handling The residue leaving each incinerator ash discharger passes through a hydraulically operated bifurcated chute to one or the other of two residue conveyors. These apron type conveyors travel at a rate of 17 feet per minute and have a capacity of 35 tons per hour. Only one conveyor operates at a time and extends horizontally past the four incinerators. It discharges its load onto rotary screens and storage hoppers in the Ash Discharge building. The electric motor driven rotary screens separate material larger than 2 inches in diameter from smaller sized material. Hydraulic power operated diverting chutes are provided to direct the flow of residue away from the rotary screens and into a bypass hopper. Material from the hoppers is removed from the plant by motor trucks. The weight of the residue leaving the plant is measured and recorded at the weighing station. The residue conveyors also receive and transport stoker grate siftings and fly ash accumulations from the boiler hoppers, economizer hoppers, and the electrostatic precipitators. Stoker grate siftings collect in six hoppers under each of three stoker grate sections. The siftings are conveyed 3-7 284 �to the residue conveyors through automatically controlled, pneumatic cylinder actuated ash dampers to ducts connected to the residue discharge (drop) chute. Boiler fly ash is collected in four hoppers and the front two hoppers discharge to the stoker grates through ducts equipped with pneumatic cylinder actuated pendulum dampers. The rear two hoppers discharge to the residue discharge chute through a common connecting pipe equipped with slide gate and an electric motor driven rotary valve. Fly ash from the economizer hoppers passes through a common pipe connected to the discharge end of the conveyor handling fly ash from the electrostatic precipitator. The two fly ash hoppers located under each precipitator discharge ash onto a drag conveyor which transmits the fly ash into the incinerator building onto a conditioning conveyor. This conveyor discharges into the residue discharge chute. Water is mixed with the fly ash in the conditioning conveyor. The fly ash handling system is designed for continuous operation and the various devices are actuated from controls on the stoker panel. The control of residue handling equipment is manual. 3.2.4 Steam Supply Refuse with a calorific value of approximately 5,000 BTU per pound at the rate of 400 tons per day is used to generate 110,000 pounds per hour of steam at 250 psig. Each boiler has the capacity to produce up to 135,000 pounds/hour of steam. The stokers and boiler heating surfaces are designed to receive refuse of up to 6,500 BTU/lb. The allowable design of the stoker grate loading is 65 Ibs/sq.ft. per hour and thus the average stoker heat release is 325,000 BTU per hour/sq.ft. of projected grate area. The boilers are convection, water well, natural circulation types with economizers. Each boiler has 19,776 sq.ft. of heating surface and is designed for a 300 psig working pressure. Steam produced in the boiler accumulates above the water surface in the steam drum and leaves the drum through double row of tubes connected to the saturated steam header outside of and supported on the boiler steam drum. From the saturated steam header the steam flows to the main header and then through branch lines to turbines driving fans and pumps, export lines and 3-8 285 �high pressure condensers. Steam at reduced pressure is also used for heating various systems such as water chiller absorption units, office buildings, low pressure condensers, etc. When the steam produced in the plant is more than that required for operating the steam turbine equipment, heating purposes or export, the excess quantity "spills over" to the high pressure condensers located on the roof of the incinerator building. From the condensers the condensate flows to the deaerating feed water heater, the rate of flow being automatically controlled and modulated to equal the rate of condensation. The requirements for make-up to replace steam condensate lost or wasted are met by using softened water. The water softening unit includes duplex softening units containing synthetic type zeolite resin, a salt storage tank, a brine measuring tank, electric motor driven brine pumps and interconnecting piping. It has a nominal flow rate of 260 gpm and a maximum rate of 480 gpm. From the feedwater heater, water flows by gravity to the inlets of the boiler feed pumps. There are four pumps, each having a nominal capacity of 400 gpm. The pumps are multi-stage, horizontal, centrifugal type. These pumps transmit the water to the boilers. Each boiler has a continuous blowdown system with water drawn from the steam drums. The blowdown pipe lines from the four boilers extend to a single flash tank. Fla>sh steam is returned to the deaerating feedwater heater at 5 psig. From the heat exchanger the blowdown water flows to an underground concrete blowdown tank where the water cools before overflowing to a sewer. 3.2.5 Combustion Air and Flue Gas The incinerator stokers are designed to utilize 67,200 scfm of primary air (introduced under the stoker grates) at 18 inches w.c. and an overfire air (secondary) flow of 16,800 scfm at 15 inches w.c. Overfire air is introduced into the furnace to reduce stratification of gas and thus provide more complete combustion of the gases. The air enters through the front and rear water walls. The underfire air is discharged into several compartments under the stoker grate. The compartments are provided with dampers which are individually adjustable by manual operation of regulating stands 3-9 286 �located on the stoker operating floor. During the burning of refuse a constant air pressure is maintained under the stoker grates by means of automatic pneumatic controls. Combustion air combines with the burning refuse to generate heat and raise the temperature of the flue gas to as high as 2000°F. At rated burning capacity and based on 50 percent excess air (dry) the flue gas flow rate at 550°F is estimated to be 142,300 acfm. The flue gas passes upward through the furnace, through the boiler passes and finally through the economizer to the electrostatic precipitator. As it passes through the boiler it transfers heat to the water. At the inlet to the electrostatic precipitator the temperature is reduced to approximately 500°F because of the above heat exchange. During the passage of the flue gas through the boiler passes and economizer the heavier fly ash particles drop out. Hoppers are provided below the boiler and economizer for the collection of the drop out material. The plate type electrostatic precipitators (ESP) (one for each incinerator) have a series of vertical collector plates between which are suspended the charging electrodes. The ESP's are designed for an inlet grain loading of 1.6 gr/scf (70°F and 29.92 in Hg) and an outlet grain loading of 0.05 gr/scf with a collection efficiency of 97 percent. The gas velocity through the ESP is around 3 ft/sec. From the precipitator the flue gas passes through a breaching continuation to the inlets of the induced draft fans and then through the 250 ft. stacks to the atmosphere. A line diagram of the combustion air and flue gas system is provided in Figure 3-3. 3-10 287 �FRESH AIR BOILER INTAKE A I i FURNACE STORAGE ro go 00 to i —i FURNACE ROOM "pTf A I I FORCED DRAFT FANS OVERFIRE AIR FAN STOKER Figure 3*-3. Combustion air and flue gas system �4.0 SAMPLING LOCATIONS All sampling locations are identified in Table 4-1 and Figure 4-1. Figure 4-2 is a schematic depicting the traverse point locations at the stack. Figure 4-3 is a top view of the ESP inlet showing port locations, and Figure 4-4 is a cross sectional view of the ESP inlet depicting the traverse point locations. The continuous monitoring probe was located on the South side of the ESP inlet duct utilizing one of the gas sampling ports and at a depth of approximately 4 feet. At the outlet, the monitoring probe was alternated between ports 2 and 3 and at a depth of 4 feet. These two ports were also used for the gas sampling trains. TABLE 4-1. SAMPLING LOCATIONS Solid Sample Locations 1 - Refuse derived fuel 2 - Fly ash 3 - Combined ash Gaseous Sampling Locations 4 - Hi volume ambient air sampler 5 - ESP inlet 6 - ESP outlet Liquid Sample Locations 7 - City tap water 4-1 289 �TRUCKED REFUSE BOILER FEED WATER AIR COOLED CONDENSERS REFUSE DELIVERY PIT LECTROSTATld PRECIPITATOR BOILER OVERFIRE AIR ASH STOKER GRATES DISCHARGE HOPPER COMBINED ASH SIFTING GRATES FORCED DRAFT FAN HEAVY METALS Figure 4-1. Flow diagram and measurement locations �OUTLET - FRONT V I E W (CONTINUOUS M O N I T O R I N G PORTS) • • • • • (PARTICULATE SAMPLING PORTS) OUTLET - TOP V I E W 60" u. 1 1=1 2 K- U 3 U 4 •H •108" SAMPLING POINTS - Traverse Point OUTLET Distance from Outside Edge of Nipple No. In. Cm. 1 11.5 29.21 2 17.5 44.45 3 23.5 59.69 4 29.5 74.93 5 35.5 90.17 6 41.5 105.41 7 47.5 120.65 7 53.5 135.89 9 59.5 151.13 10 65.5 166.37 Figure 4-2. Outlet sampling position 4-3 291 �Figure 4-3. Top view of ESP inlet showing port locations �71" 60" EL 60" DUSTCAKE SAMPLING POINTS - INLET Traverse Point No. Distance from Outside Edge Nipple No. In. Cm. 1 11.5 2 15.375 29.21 39.05 3 19.625 49.35 4 23.875 28.125 32.375 36.625 40.875 45.125 49.375 60.64 71.44 82.23 93.03 103.32 114.62 53.625 57.375 136,21 145.73 5 6 7 8 9 10 11 12 Figure 4-4. 125.41 Cross sectional of ESP inlet showing traverse point locations. 293 4-5 �5.0 SAMPLING This section provides information on the sampling program conducted at the Chicago Northwest Incinerator (CNI). 5.1 GAS SAMPLING The original test plan called for sampling to be performed on Boiler No. 1. However, upon arriving at the test site, this unit had been taken off line for repairs. As all four (4) units at the Chicago Northwest facility are identical, the sampling effort was switched from unit 1 to unit 2. The flue gas sampling was performed at the electrostatic precipitator (ESP) inlet and at the duct leading from the precipitator to the stack. The stack was common to two boiler units and for this reason, no testing was performed at the stack level. Sampling for organics was to be performed for fourteen consecutive days with three additional days for sampling of inorganic cadmium. Due to boiler down time and equipment malfunction, only eleven organic samples were taken. Sampling for organics was accomplished concurrently at the inlet and outlet utilizing two modified Method 5 trains (refer to Figure 5-1) at both sampling locations. Inorganic cadmium was only sampled at the stack and utilized one standard Method 5 train, Figure 5-2. The sampling crew collected a ten m 3 (10 +_ 1 m 3) sample by extracting the flue gas at a rate approximating the flue gas velocity. The particulate matter was collected in a cyclone and on the filter media. The gas stream was passed through an XAD-2 resin trap to absorb the organic constituents and through an impinger system to condense any moisture present in the gas. Parameters such as temperatures, pressures, and gas volumes were monitored throughout the sampling period. The sample fractions were recovered from the sampling trains and turned over to an MRI representative. 5.2 SOLID SAMPLING During each test day, 3 solid streams: precipitator ash, combined ash, and refuse derived fuel (RDF) were sampled six times per day following a schedule set up by Research Triangle Institute (RTI). The sampling was coordinated between RTI, the sampling crew and plant personnel. The 5-1 294 �XX X FILTER HOUSING THERMOf-ETER DRY TEST • fKTER AIR TIGHT PUMP Figure 5-1. Sampling train 5-2 295 �figure 5-2. EPA Method 5 particulate sampling train 1) 2) 3) 4) 5) 6) 7) 8) 9) 10) 11) 12) Calibrated nozzle Glass lined probe Flexible teflon sample line Cyclone Filter holder Heated box Ice bath Impinger (water) Impinger (water) Impinger (empty) Impinger (silica gel) Thermometer 5-3 296 13) 14) 15) 16) 17) 18) 19) 20) 21) 22) 23) 24) Check value Vacuum line Vacuum gauge Main value Air tight pump Bypass value . Dry test meter Orifice Pitot manometer Potentiometer Orifice manometer S type pi tot tube �schedule provided the basis for collection of unbiased samples by obtaining a random selection from the multiple sources available for sampling. This approach was taken to avoid any cyclic biases which might have been present in the daily operation of the power plant. The CNI sampling plan did not call out specific sampling protocol for the RDF. At a meeting prior to the start of testing, it was decided that the RDF would be sampled 6 times during the course of the day. The sample was taken directly from the charge hopper, utilizing a post-hole digger and alternating grab spots across the hopper. At the conclusion of RDF sampling, one days collection (6 samples) was shredded, mixed and stored in an amber glass jar. MRI had purchased a large leaf mulcher to do the shredding. TRW performed the shredding of the sample provided by GSRI 5.3 LIQUID SAMPLING Only one liquid stream (city water) was sampled at the incinerator facility. The sampling was performed by GSRI. The sampling protocol and frequency of sampling will be supplied by GSRI in their report. 5.4 HI VOLUME SAMPLER To monitor the ambient air background, a high volume ambient air sampler (Figure 5-3) was used. It was placed on the roof of the Chicago Northwest Incinerator facility to obtain a representative background utilizing outside ambient air rather than sampling air inside the building that could have been contaminated or influenced by the combustion process. 5.5 QUALITY ASSURANCE A quality assurance sample was also taken of the final test day. To collect the quality assurance sample, two sampling trains were placed at the same point in the same port at the inlet of the ESP. No traversing was performed. Both trains were run at the same isokinetic rate for the same duration as a normal test day. Also during the Q/A day, solids and liquids were collected as in a normal test day. 5.6 SAMPLING TRAIN BACKGROUND To obtain the train background (blank) an entire sampling train, including resin trap filter and impinger solutions was set up at the ESP inlet. The train was taken to normal operating temperatures and allowed to 5-4 297 �HIGH VOLUME AIR SAMPLER FLOW PROBE \MODEL 230 HIGH VOLUME CASCADE IMPACTOR - OPTIONAL MANOMETER OR ROTAMETE: MODEL 310/310A/310B CONSTANT FLOW CONTROLLEF FLOW iJUSTMENT LINE CORD Figure 5-3. Ambient air sampler. 5-5 298 �remain at these temperatures for one (1) hour. All train components were recovered as a normal run and all sample blanks were given to an MRI representative, 5J SAMPLE RECOVERY Upon completion of testing, the sampling equipment was brought to the cleaned laboratory area for recovery. Each sampling train was kept in a separate area to prevent sample mixup and cross contamination. The individual sample train components were recovered per the following: • Dry particulate in cyclone r cyclone flasks were transferred to cyclone catch bottle. t Probe was wiped to remove all external particulate matter near probe ends, • Filters were removed from their housings and placed in proper container, • After recovering dry particulate from the nozzle, probe, cyclone, and flask, these parts were rinsed with distilled water to remove remaining particulate, They were subsequently rinsed with B & 0 acetone and cyclohexane and put into a separate container. All rinses were retained in an amber glass container, t Sorbent traps were removed from the trainl capped with glass plugs, and given to an on-site Midwest Research Institute (MRI; representative, • Condensing coil \ if separate from the sorbent trap, and the connecting glassware to the first impinger was rinsed into the condensate catch (ftrst impinger). • First and second impingers were measured, volume recorded and retained in an amber glass storage bottle. The impingers were then rinsed with small amounts of distilled water, acetone and cyclohexane. These rinsings were combined with the condensate catch. Rinse volumes were also recorded. • Third and fourth impingers were measured, volume recorded and solutions discarded. • Silica gel was weighed, weight gain recorded and regenerated for further use. To maintain sample integrity, all glass containers were amber glass, with Teflon-lined lids. 5-6 299 �5.8 OBSERVATIONS DURING RECOVERY 0 The first day setup of impingers did not include ^Og, as the shipment had not been delivered from the manufacturer. • Many filters that were supplied for the particulate catch, had the identification number stamped in blue ink on the top; or, particle gathering side. • Some Battelle Traps were packed with too much glass wool. (As a result, flow rate was somewhat restricted.) The probe and oven box did not remain hot enough to keep the cyclone and flask dry. For the first few days of testing, the cyclone had moisture on the inside walls, so no dry particulate could be collected. • On 5/10/80, the wind blew the Hi Volume Air sampler cabinet over. The cabinet had to be moved to a less exposed area nearer the building. • On 5/5/80, 5/8/80, and 5/9/80 yellow residue was noted in the teflon line connecting the back of the filter housing to the front of the Battelle cooling coil. When the teflon line was rinsed with acetone, the rinse turned to reddish-brown. • When the filters were not kept completely dry throughout the particulate test period, the filter paper would stick to the rubber gasket and was very difficult to completely remove. t A reddish color remained on the inlet filter backing plates on 5/8/80 and 5/15/80. The color washed off with water, and the rinse was discarded. § The inlet glass transition tubes connecting the probe to the cyclone, had to be wrapped in an attempt to keep moisture and particulate from dropping out and depositing on the walls. • All parts were inspected for cleanliness after the water and acetone rinses, but before the cyclohexane rinse. Cyclohexane does not rapidly evaporate and gives any part rinsed with it the appearance of being clean. In reality the parts were still wet and masked any particulate that remained on the walls. 5-7 300 �6.0 CALIBRATION This section describes the calibration procedures used prior to conducting the field test at Chicago Northwest Incinerator facility. Figure 6-1 shows the calibration equipment and how it was set up. 6.1 METHOD FIVE CALIBRATION DATA 6.1.1 Orifice Meter Calibration The orifice meter calibration is performed using a pump and metering system as illustrated in Figure 6-1 (a). The dry gas meter with attached critical orifice is run at various orifice flows for a known time. After each run the volume of the dry gas meter, meter inlet/outlet temperatures, time, and orifice setting is recorded. The orifice meter calibration factor is derived by solving the equation. AHia - 0.317 A H - Pb (Td + 460) AH@ + 460) e n 2 —TO- ] r (Tw C where AH = Average pressure drop across the orifice meter, inches H20 Pb Td Tw e Vw = = = = = Barometric pressure, inches Mercury Temperature of the dry gas meter, °F Temperature of the wet -test meter, °F Times, minutes Volume of wet test meter, cubic feet The AH@ yielded is utilized to adjust the sampling train flow rate by regulating the orifice flow. 6.1.2 Dry Gas Meter Calibration Meter box calibration consists of checking the dry gas meter for accuracy. The dry gas meter with attached critical orifice is connected to a wet test meter (see Figure 6-1 (b) below) and run at various orifice flows for a known time. After each run wet and dry gas meter volumes, temperatures, time, and orifice readings are recorded. Utilizing the equation: 301 �v . Vw Pb (Td +460) Vd (Pb + AH)(t + 460) TT.6 w where V = Volume correction factor Vw = Volume of wet test meter, cubic feet Pb = Barometric pressure, inches mercury Td = Temperature dry gas meter, °F Vd = Volume of dry gas meter, cubic feet AH = Average pressure drop across the orifice meter, inches H20 TW = Temperature of wet test meter, °F a volume factor which compares the dry gas meter with the wet test meter is obtained. 6.1.3 Pi tot Tube Calibration Pitot tubes are calibrated on a routine basis utilizing two methods. The type S pitot tube specifications are illustrated and outlined in the Federal Register, Standards of Performance for New Stationary Sources, [40 CFR Part 60], Reference Method 2 (refer to Figure 6-1(c)). When measurement of pitot openings and alignment verify proper configuration, a coefficient value of 0.84 is assigned to the pitot tube. If the measurements do not meet the requirements as outlined in the Federal Register, a calibration is then performed by comparing the S type pitot tube with a standard pitot tube (known coefficient of 1.0). Under identical conditions, values of AP, for both S type and standard pitot tube are recorded using various velocity flows (14 fps to 60 fps). The pitot tube calibration coefficient is determined utilizing the following equation, Pitot Tube Calibration = (Standard Pitot Tube X rAP reading of std. pitot J -il/2 L Factor (CP) Coefficient) AP reading of S type pi tot The coefficient assigned to the pitot tube is the average of calculated values over the various velocity ranges. 6-2 302 �tttgnchstic Gtupe Figure 6-1(a) Orifice meter calibration Figure 6-1(b) Dry gas meter calibratipn fcunf Wftcrc 7m or filer Ti/t* Wou/tf £f WAen Too View Figure 6-1(c) Equipment used to calibrate pi tot tubes Figure 6-1. Calibration equipment set-up procedures 6-3 303 �6.1.4 Nozzle Diameters The nozzle diameters were calibrated with the use of a vernier caliper. If the nozzle showed excessive wear or was considered not fit for use, it was discarded. 6.2 INSTRUMENT CALIBRATION The manufacturer's recommended calibration procedures were used with the following gases: Zero gas: Nitrogen, high purity dry grade (99.997%) Union Carbide Co., Linde Division Calibration gas: Carbon monoxide 798.5 +_ 0.8 ppm Carbon dioxide 11.93 ±0.01% Propane 39.6 + 0.04 ppm Oxygen 5.03 ± 0.005% Nitrogen Balance (all gases contained in one cylinder) Scott Environmental Technology Inc. Specialty Gas Division Zero and Calibration adjustment were made prior to the start of the test day. Zero drift checks were made at the end of each test period. Data was recorded every fifteen minutes thus providing two data points per hour for each sampling position, or four data points per hour for a single sampling position 6.4 304 �7.0 TECHNICAL PROBLEMS AND RECOMMENDATIONS This section describes some of the problems encountered during the Chicago Northwest Incinerator test program and recommends a solution to these problems. 7.1 PROBLEMS • Electrical outlets were not installed on schedule (lost time 1 day). • One of the tubes in Boiler No. 2 developed a leak. The boiler had to be shutdown for repairs. This caused a delay of one day. • The boiler grates malfunctioned and required cleaning. This resulted in down time of one day. • Sampling equipment malfunctions caused further delays. This was due to: 1) Difficulty in containing leaks during equipment operation. 2) Failure of oven box heaters. 3) Drift problems of the Beckman 865 CO analyzer. The analyzer had to be taken off line and subsequent inspection by manufacturer indicated that the stationary shutters were knocked out of alignment. This resulted in the loss of 4 days of CO data before a replacement was obtained. 7.2 RECOMMENDATIONS Most of the above problems frequently occur in the field and should be considered normal during the course of a major field effort. The instrument problem may have been caused during shipment. Perhaps, stronger shipping containers should be used in the future. 7-1 305 �REPORT DOCUMENTATION PAGE 4. T,tie and subntie . '•- Rtno-n NO. | 3. ''L-r.iptent's Arc;e*3'un No 2. i 560/5-83-004 i •' ' : Comprehensive Assessment of Specific Compounds Present in Combustion Processes. Vol. 1.-Pilot study of Combustion Emissions Variability. 7 Au-hcriM Clarence" Ha lie and JoTfn Stanley (MRI) Carter Nulton (SWRI) William Yauger, Jr. (GSRI) 0. Performing O-,;.iniz,ition Name and Acdress 5, Report Date June 19_83__ 6. ! a. Performing OrRanizanori Rept. No I I 10. Proiect/TaskAVork Unit No. ! - Midwest Research Institute 425 Volker Blvd. Kansas City, MO 64110 Task 3 ; 11. Conlract(C) or C r a r . t ( G ) No. i'c> - . 68-01-5915 ! (G) 1C*. Spon c ,orrii? Or^ani* .itii'n Namf and Address 13. Type of Report & Period C o w e r e d Field Studies Branch, EED.TS-798 US EPA 401 M St. SW Final _ . 1 i _ _ _ 14. Washington, DC 20460 IS. Supolcrrent.iry N c t e s F.W. Kutz, Project Officer D.P. Redford, Task Manager is. Abstract (urn,:-200 words) xhis pilot study was conducted as a prelude to a nation wide survey of organic emissions from major stationary combustion sources. The primary objectives of the pilot study were to obtain data on the variability of organic emissions from two such sources and to evaluate the sampling and analysis methods. These data are used to construct the survey design for the nationwide survey. The compounds of interest are polynuclear aromatic hydrocarbons (PAHs) and chlorinated aromatic compounds, including polychlorinated biphenyls (PCBs), polychlorinated dibenzo-p-dioxins (PCDDs), and polychlorinated di-benzofurans (PCDFs). Of particular interest is 2,3,7,8tetrachlorodibenzo-p-dioxin (TCDD). In addition total cadmium was also determined in special samples from both plants to meet special Environmental Protection Agency (EPA) needs. A summary of the results of this study is contained in Section 2 of this report. Section 3 presents recommendations for future work. Brief descriptions of the two combustion sources are contained in Section 4. The sampling and analysis methods are described in Sections 5 and 6. Sections 7 and 8 present the field test data and analytical results. The analytical quality assurance results are summarized in Section 9. Section 10 presents the emissions results and Section 11 is a statistical summary of the emissions results. 17. Document Analysis a. Descriptors Combustion, Emissions, Sampling and Analysis b. Identifiers/Open-Ended Terms PAH,PCDD,PCDF,POM c. C O S A T I f i e l d / G r o u p 18. A v a i l a b i l i t y Statement 19. Security Class (This Report) Unclassified Release to public (Sr-v A N S I - / 3 9 13) 20. Security Cln$,s(T,his, PaRe) Unc See Instructions on Reverse 1 21. No. of Pages i 305 22. Price OPTIONAL FORM 2 7 2 ( 4 - 7 7 r m m e r l y NTIS-3S) r>v-~^rlrnent of Commerce � Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Alvin L. Young Collection on Agent Orange Description An account of the resource <p style="margin-top: -1em; line-height: 1.2em;">The Alvin L. Young Collection on Agent Orange comprises 120 linear feet and spans the late 1800s to 2005; however, the bulk of the coverage is from the 1960s to the 1980s and there are many undated items. The collection was donated to Special Collections of the National Agricultural Library in 1985 by Dr. Alvin L. Young (1942- ). Dr. Young developed the collection as he conducted extensive research on the military defoliant Agent Orange. The collection is in good condition and includes letters, memoranda, books, reports, press releases, journal and newspaper clippings, field logs and notebooks, newsletters, maps, booklets and pamphlets, photographs, memorabilia, and audiotapes of an interview with Dr. Young.</p> <p>For more about this collection, <a href="/exhibits/speccoll/exhibits/show/alvin-l--young-collection-on-a">view the Agent Orange Exhibit.</a></p> Text A resource consisting primarily of words for reading. Examples include books, letters, dissertations, poems, newspapers, articles, archives of mailing lists. Note that facsimiles or images of texts are still of the genre Text. Box The box containing the original item. 192 Folder The folder containing the original item. 5421 Series The series number of the original item. Series VIII Subseries I Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Creator An entity primarily responsible for making the resource Haile, Clarence L John S. Stanley Robert M. Lucas Denise K. Melroy Carter P. Nulton William L. Yauger, Jr. Date A point or period of time associated with an event in the lifecycle of the resource 1983-06-01 Title A name given to the resource Comprehensive Assessment of the Specific Compounds Present in Combustion Processes, Volume I: Pilot Study of Combustion Emissions Variability ao_seriesVIII https://www.nal.usda.gov/exhibits/speccoll/files/original/a38c4f49724d9d7ae51fa9331032d24c.pdf a23610651e3c9ac87378877c37225e5a PDF Text Text ItemDNumber 05350 Author Hansen, Warren G. Corporate Author United States Environmental Protection Agency (EPA), D Report/Article TitlB Pr°Ject Summary: Cost Comparisons of Treatment and Disposal Alternatives for Hazardous Materials, Volumes I and II Journal/Book Title Year Month/Day Color February D Number of Images ° DosGripton Notes EPA-eoo/S2-8o-i 88 Tuesday, March 05, 2002 Page 5350 of 5363 �United States Environmental Protection Agency Research and Development oEPA Municipal Environmental Research Laboratory Cincinnati OH 45268 EPA-600/S2-80-188 Feb. 1981 Project Summary Cost Comparisons of Treatment and Disposal Alternatives for Hazardous Materials Volumes I and II Warren G. Hansen and Howard L. Rishel Life cycle cost information is an important element in selecting hazardous waste treatment and disposal technologies. This project evaluates the technologies and costs of wastes from the organic/inorganic chemicals, and the electroplating and metal finishing industries for 16 alternative treatment and 5 alternative disposal methods. Capital and operation/ maintenance costs were calculated for each process by using computer models. Final cost comparisons of treatment/disposal technologies for similar waste streams were then made. Risks associated with each technology were qualitatively assessed in terms of susceptibility to catastrophic events, unexpected downtime, and adverse environmental impacts. This Project Summary was developed by EPA's Municipal Environmental Research Laboratory, Cincinnati. OH, to announce key findings of the research project that is fully documented in a separate report of the same title (see Project Report ordering information at back). Introduction This study details hazardous waste treatment and disposal technologies and costs. Guidance is provided for making conceptual cost estimates for selected technologies and making comparisons among a l t e r n a t i v e processes when more then one option is available. Specific project objectives were to: • Assemble available data on the costs of technologies for treatment and disposal of hazardous wastes. • Upgrade existing information from literature sources and equipment manufacturers. • Rank treatment and disposal processes according to their cost effectiveness for environmental protection. • Provide assessments and comparisons of the risk for adverse environmental impacts and complexity of implementing each technological process. Comparisons of effectiveness are based on criteria developed by the U.S. Environmental Protection Agency, Office of Solid Waste, for controlling hazardous wastes as promulgated under Subtitle C of RCRA (P.L 94-580). �Treatment and Disposal Technologies The treatment and disposal of aqueous hazardous wastes produced by organic and inorganic chemicals in the electroplating and metal finishing industries are addressed. The types of chemicals contained in the waste streams of these three industries are listed in Table 1. Considerable attention must be given to selecting treatment and disposal technologies compatible with the chemical constituents of various waste streams. Initial work on the cost-effectiveness models involved identifying the technologies and waste streams. Each treatment and disposal process was rated according to these criteria: • Applicability within industry categories. • Presence in typical off-site or municipal treatment processes. • Availability of cost and performance data. • Determination of whether the technique is destructive or involves indefinite fixation/storage. Sixteen treatment and five disposal technologies were selected for study (Table 2). Detailed analyses of each of these technologies yielded descriptions and process flow schematics. In Table 2, the 21 treatment and disposal technologies are related to the equipment/process needed to achieve treatment/disposal. Costs Additional data collections and assessments produced (1) a compilation of comprehensive cost files for each technology and individual component, and (2) cost and performance equations that relate the cost of components to scaling factors and system variables. This information along with the executive programs (described in full in the report) were then coded and entered in a modified Fortran IV format for analysis. Cost data are sufficiently detailed so that equipment and size of the operation can be modified, and a specific cost estimate can be derived. Table 3 summarizes the life cycle costs for the 16 treatment and the 5 disposal technologies addressed in this study. These cost estimates consider: Table 1. Chemicals Contained in Waste Streams of Three Industries Industry Hazardous Waste Category Organic Chemicals Phenols and cresols, ethers, halogenated aliphatics, polycyclic aromatic hydrocarbons, monocyclic aromatics, nitrosamines, PCBs, phthalate esters Metals, Metal Misc. (used in Salts, Complexes, catalysts) etc. Inorganic Chemicals Electroplating/ Metal Finishing Organic Chemicals Chlorinated hydrocarbons Non-Metal Inorganics Various Acids Caustics Misc. acids Misc. caustics (used in production reactions) Certain halogenated aliphatics Hg, HgC1, HgS. Pb, Pb, Cr, Cu, Ni, Cr, Cu, Ni, Sb. An, Cd, Pd chromates, sodiumcalcium, calciumfluoride, ferric ferrocyanide, ferric arsenate, arsenic chlorides, nickel hydroxide, lead salts, arsenic trisulfide Asbestos Cyanides Phosphorus sulfide Fluorides Phosphorus trichloride Hydrofluoric acid Sulfuric acid Sulfuric acid Hydrochloric Hydrochloric acid acid Caustics Caustics Inorganic pesticide Chlorinated manufacture hydrocarbons (mainly metals; Cu, Pb, Zn) Pesticides Capital Costs: • Costs of purchased equipment required for the processes, including contingencies and contractor's profit. • Cost of equipment delivery, field erection, installation, piping, concrete, steel, instrumentation, electrical insulation, and all appurtenances required for proper operation of the processes. • Prime contractor engineering for the technology. Licenses and fees. Construction overhead. Costs of buildings when required for proper process function or protection from weather. Land costs. Working capital. Allowance for funds during construction. Degreasing solvents, chlorinated hydrocarbons Operating and Maintenance Costs: • Utility costs. • Labor. • Chemical costs (transported to site and prepared for use). • Maintenance. • Product or residuals (salable commodities as well as further disposal costs). • Administrative overhead. • Debt service and amortization. • Real estate taxes and insurance. The risk assessment process considers the probability of catastrophic events occuring (this can be related to geographical location); downtime risks associated with system reliability, unexpected equipment damage, and in some cases, problems independent of the technology selected (e.g., chemical supply or labor problems); and adverse environmental �Table 2. Unit Process Modules Comprising the Hazardous Waste Treatment and Disposal Technologies .2 to ^ Q) Precipitation Coagulation/Flocculation/ Sedimentation Filtration Evaporation Distillation Flotation Oil/Water Separator Reverse Osmosis Ultrafiltration Chemical Oxidation/ Reduction Hydrolysis Aerated Lagoon Trickling Filter Waste Stab. Pond Anaerobic Digestion Carbon Adsorption Activated Sludge Evaporation Pond Incineration Land Disposal Chemical Fixation Encapsulation X X factors (emphasizing the existence or absence of potential causes of such impacts). Evaluations of each of the 21 treatment/disposal technologies included the following engineering/design information: • Technology description processes, flow diagram, design detail. • Changes in technology configuration with scale. • Application (hazardous waste streams treated and/or disposed of according to industry and waste type). • Cost: Summary of capital cost. Changes in capital costs with scale. Summary of first year operating costs. X X X X Chemical Storage: Gas Chemical Storage: Liqu, Chemical Storage: Solic Sludge Equalization Haz. Waste Land Dispo: Encapsulation Deaerator Evaporation Pond Steam Generator Sludge Digestor i?5 Multi-media Filter Distillation Evaporator Reverse Osmosis Ultrafiltration Carbon Adsorption Decanter 1 Flocculator Flash Mixer Jacketed Flash Mixer Aerated Lagoon Aerated Basin Sludge Digestor Trickling Filter Waste Stab. Pond Chemical Fixation Incinerator Sedimentation Basin Clarifier Rotary Drum Vacuum F, Air Flotation Oil/Water Separator 8 en ^ X X X X X X X X X X X X X X XXX X X X X X X X X X X X X X X XX X X X X X X X X X X X X X X X X X X X X X Changes in operation and maintenance costs with scale. Life cycle average costs. Life cycle average costs according to scale. Computed costs were typical of waste discharge rates from the three industries studied. Costs given are for mid-1978 and are based on unit costs as they apply in Chicago, Illinois. Example An example evaluation procedure for one of the selected treatment technologies (reverse osmosis) follows; the report includes similar assessments for the remaining 20 alternative treatment and disposal technologies. Technology Description The basic unit for an industrial waste treatment process that uses a reverse osmosis plant is the reverse osmosis process. The modules are assembled in a racklike configuration to accommodate the desired waste flow rate. Theoretically, reverse osmosis is induced by applying high pressure to a suitable membrane that, at the same time, rejects the salt molecules and produces a relatively salt-free water stream. The remaining salt solution is concentrated and removed from the system. Care must be exercised with reverse osmosis systems to ensure that waste does not contain certain colloidal substances or heterogeneous matter; otherwise, these may, in time, reduce the permeability of the membrane and subsequently reduce the quantity of effluent produced. �Table 3. Cost Comparisons Among Treatment and Disposal Technologies: Standard Units Life Simple Average Cost ($ per 1,000galJa Life Cycle Average Cost ($ per 1,000 gal.f at gpm at gpm 7,000 2,000 3,000 4,000 5,000 7,000 2,000 3,000 4,000 5,000 Technology Precipitation/'Flocculation/ Sedimentation Filtration Evaporation Distillation Flotation Oil/Water Separator Reverse Osmosis Ultrafiltration Chemical Oxidation/Reduction Hydrolysis Aerated Lagoon Trickling Filter Waste Stab. Pond Anaerobic Digestion Carbon Adsorption Activated Sludge Evaporation Pond 10 10 5 5 10 10 7 7 5 5 15 15 5 10 7 10 20 • Incineration 5 Land Disposal Chemical Fixation With Solids Chemical Fixation Without Solids Encapsulation a 20 NA NA 7 2.65 2.16 1.94 1.85 1.79 1.72 1.40 3.66 3.12 2.75 2.54 2.43 2.31 1.97 10.33 9.43 9.12 8.98 8.89 8.48 7.74 15.86 16.36 16.37 16.36 16.40 13.02 13.39 1.98 1.62 1.43 1.33 1.27 1.26 1.04 0.76 0.51 0.44 0.44 0.48 0.48 0.32 9.05 9.40 9.61 9.62 9.79 6.97 6.71 4.04 3.36 3.61 3.61 3,76 3.02 2.51 5.31 4.56 4.52 5.23 6.22 4.36 3.74 0.99 0.83 0.75 0.74 0.76 0.82 0.69 5.30 3.81 3.31 3.89 4.35 2.62 1.89 4.70 3.82 3.63 3.30 3.19 2.37 1.93 4.45 3.94 3.71 3.63 3.54 3.70 3.28 7.88 6.91 6.53 6.41 6.28 5.14 4.53 27.43 16.43 12.69 10.96 9.89 4.84 3.54 3.11 4.02 4.84 8.99 8.20 7.90 7.75 7.75 Simple Average Cost ($ per 1,000 Ibs.f at Ibs/hr 1,000 2,000 3,000 4,000 5,000 1.26 1.20 1.16 1.74 1.61 1.54 7.49 7.37 7.30 13.41 13.40 13.43 0.92 0.85 0.81 0.28 0.28 0.30 7.12 7.13 7.25 2.70 2.70 2.81 3.71 4.29 5.10 0.62 0.62 0.63 1.64 1.93 2.15 1.84 1.68 1.63 3.09 3.02 2.95 4.29 4.21 4.13 20.26 12.14 9.38 8.10 7.31 3.08 2.28 2.00 2.57 3.10 4.01 3.71 3.60 3.54 3.54 Life Cycle Average Cost ($ per 1,000 Ibs.f at Ibs/hr 1,000 2,000 3,000 4,000 5,000 305.30 2SS.23 235.10293.34 293.64 256.55 246.91 244.34 242.88 243.15 389.94235.14178.08149.40132.36154.34 91.26 68.37 56.86 50.01 90.00 90.00 90.00 90.00 90.00 90.00 90.00 90.00 90.00 90.00 24.00 24.00 24.00 24.00 24.00 24.00 24.00 24.00 24.00 24.00 61.99 56.90 46.62 42.87 3 $/1,000 gal. = $/m "S/7,000 Ibs. = $/t x 0.453 Changes in Configuration with Scale Additional banks of modules are used to accommodate increased flow rates. Applications The following applications are documented for reverse osmosis: • Separation of plating salts. • Reclamation of rinse waters for reuse. • Reclamation of metals from plating. • Removal of residual total dissolved solids. • Removal of certain trace organic compounds (e.g., pesticides). Costs The capital and first-year operating costs for the example facility are calculated with the use of the capital and operating/maintenance cost files and the computer model cost equations. First year operating costs for a 1,000 gpm Chicago-based facility (including administrative overhead, debt service and amortization, real estate taxes, and insurance) are approximately $871,000. The life cycle average costs for the example facility (assuming a life cycle of 7 years) are calculated to be $6.71 per 1,000 gallons of waste treated. No economy of scale was observed over the range of design flows that were studied. In fact, for reverse osmosis treatment, the average life cycle cost increases. This increase is attributed to the need for larger and more complex module arrangements, support facilities, and increased chemical costs. Volume II Volume II contains the following: Appendix A, Section 250.45 of the Resource Conservation Act; Appendix B, Capital Unit Cost File; Appendix C, Operation and Maintenance Unit Cost File; Appendix D, Curve Fitting for Cost Files; Appendix E, Module Descriptions; and Appendix F, System Variable Equations. Risk Assessment The risk assessment concludes that some potential loss may occur from (1) catastrophic events (e.g., earthquakes, floods, tornadoes, or fires), and (2) unexpected downtime (e.g., membrane clogging). Potential adverse environmental impacts are assessed, and, in most instances, it is determined that only minimal impacts are likely. �Warren G. Hansen and Howard L. Rishell are with SCS Engineers, Redmond, WA 98052 and Long Beach, CA 90807, respectively. Oscar W. Albrecht is the EPA Project Officer (see below). The complete reports, entitled "Cost Comparisons of Treatment and Disposal Alternatives for Hazardous Wastes: Volume I and Volume II," (Order Nos. PB 81-125 814; Cost: $20.00 and PB 81-128 522; Cost: $9.50, subject to change) will be available only from: National Technical Information Service 5285 Port Royal Road Springfield, VA 22161 Telephone: 703-487-4650 The EPA Project Officer can be contacted at: Industrial Environmental Research Laboratory U.S. Environmental Protection Agency Cincinnati, OH 45268 * U.8. OOVEHNMENT PRINTINO OFFICE: 1961-757-012/7001 �United States Environmental Protection Agency Center for Environmental Research Information Cincinnati OH 45268 Official Business Penalty for Private Use $300 r L "i Postage and Fees Paid Environmental Protection Agency EPA 335 � Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Alvin L. Young Collection on Agent Orange Description An account of the resource <p style="margin-top: -1em; line-height: 1.2em;">The Alvin L. Young Collection on Agent Orange comprises 120 linear feet and spans the late 1800s to 2005; however, the bulk of the coverage is from the 1960s to the 1980s and there are many undated items. The collection was donated to Special Collections of the National Agricultural Library in 1985 by Dr. Alvin L. Young (1942- ). Dr. Young developed the collection as he conducted extensive research on the military defoliant Agent Orange. The collection is in good condition and includes letters, memoranda, books, reports, press releases, journal and newspaper clippings, field logs and notebooks, newsletters, maps, booklets and pamphlets, photographs, memorabilia, and audiotapes of an interview with Dr. Young.</p> <p>For more about this collection, <a href="/exhibits/speccoll/exhibits/show/alvin-l--young-collection-on-a">view the Agent Orange Exhibit.</a></p> Text A resource consisting primarily of words for reading. Examples include books, letters, dissertations, poems, newspapers, articles, archives of mailing lists. Note that facsimiles or images of texts are still of the genre Text. Box The box containing the original item. 184 Folder The folder containing the original item. 5350 Series The series number of the original item. Series VIII Subseries I Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Creator An entity primarily responsible for making the resource Hansen, Warren G. Howard L. Rishel Description An account of the resource <strong>Corporate Author: </strong>United States Environmental Protection Agency (EPA), Municipal Environmental Research Laboratory, Cincinnati, Ohio Date A point or period of time associated with an event in the lifecycle of the resource 1981-02-01 Title A name given to the resource Project Summary: Cost Comparisons of Treatment and Disposal Alternatives for Hazardous Materials, Volumes I and II ao_seriesVIII https://www.nal.usda.gov/exhibits/speccoll/files/original/b7eef174761b20ee26ed21cfc092f4bb.pdf 19859d1fadbc1b8a156ff75e4c1f793f PDF Text Text Item D Number °5207 Author Marker, Timothy L. Corporate Author Environmental Protection Agency, Office of the General D (jot Scanned Report/Article TitiB United States Environmental Protection Agency (EPA) Before the Administrator, In re: 2,4,5 -T, FIFRA Consolidated Docket No. 295, Respondent's First Pretrial Brief and Second Pretrial Brief Journal/Book Title Year 1974 Month/Day March n Color Number of Images D 82 Descriptor! Notes Friday, March 01, 2002 Page 5207 of 5263 �UNITED STATES OF AMERICA ENVIRONMENTAL PROTECTION AGENCY BEFORE THE ADMINISTRATOR IN RE: 2,4,5-T } ) FIFPA CONSOLIDATED DOCKET NO. 295 RESPONDENT'S FIRST PRETRIAL BRIEF Timothy L, Harker Attorney for Respondent Office oi' the £c ; iterel Counsel 401 !-i Street., S. W, tJarsirinoton, D. C. (202) 75-.-0725 �This case is the c u l m i n a t i o n of a prolonged effort to test in a p u b l i c forum the response of the pesticide Registrants herein to serious questions as to the risk to p u b l i c safety raised by the use of 2,4,5-Trichlorophenoxyacetic Acid (2,4,5-T). Initial public concern over the use of 2,4,5-T was motivated by reports in the summer and fall of 1969 of an alleged increased incidence of birth defects in South Vietnam, potentially l i n k e d to a m i l i t a r y I/ defoliation campaign utilizing this phenoxy herbicide. A broad screening of pesticide and industrial chemicals, thereafter, by the Bionetics Research Laboratory confirmed that 2,4,5-T fed to laboratory mice and rats induced the birth of deformed offspring. Federal agencies made the initial regulatory response in the spring of 1970 after the Secretary of Health, Education and Welfare speaking on behalf of the Surgeon General informed the Secretary of Agriculture that, " . . . a prudent course of action must be based on the decision that exposure to this herbicide may present an imminent hazard to women of child-bearing age." y On April 15, 1970 the Secretary of Agriculture announced the immediate suspension of the registrations for all V Report of the Advisory Committee On 2,4,5-T to the Administrator of the Environmental Protection Agency, May 1971, p. 3. 2f Ibid, at p. 4. �2,4,5-T products used In lakes, ponds and ditch banks, and for 2,4,5-T liquid formulations used around homes, recreation areas and similar I/ sites involving direct human exposure. Shortly thereafter USDA cancelled the registrations of all granular 2,4,5-T formulations for use around the home and similar places of potential human exposure and cancelled all registered uses of 2,4,5-T on food crops intended for I/ human consumption. Pursuant to the provisions of the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) 5/ four registrants challenged the order of cancel!ation, two requesting a hearing and two moving that the matter be referred to an Advisory Committee of the National Academy of Science. Public hearing was deferred, pending issuance of the Advisory Committee Report, accomplished on May 7, 1971. The Advisory Committee concluded that based on current patterns of usage of 2,4,5-T and what was known about its fate in the environment, it was unlikely that accumulation could occur so as to constitute a hazard to human health. The majority opinion was, however, accompanied by a warning — that there was an absence of environmental information about a particularly poisonous contaminant of 2,4S5-T formulations, 2,3,7,8Tetrachlorodibenzoparadioxin (TCDD or tetra-dioxin), and that this toxicant could pose a problem for human health, although a level of .1 ppm (parts per million) may be acceptable. 3/ USDA-PRD, PR 70-1, 20 Apr. 1970. 4/ USDA-PRD, PR 70-13 1 May 1970, 5/ 7 USC 135 et. seq; amended, 1972, 7 USC 136 et. seq. (Supp. T973). - 2- �A minority report was filed, which reasoned that the Committee in its optimism had neglected to consider fully the consequences of the dearth of data on the fate of TCDD in the food chain and in tissue. After due consideration of these 'contrasting opinions the Administrator of the Environmental Protection Agency effect the order of cancellation. Z/ y continued in In subsequent orders £/ the Administrator elaborated upon the reasons for continuing the cancellation, as follows: 1. A contaminant of 2,4,5-T—tetrachlorodibenzoparadioxin (TCDD, or dioxin)-~is one of the most teratogenic chemicals known. The registrants have not established that 1 part per million of this contaminant—or even 0.1 ppm--in 2,4,5-T does not pose a danger to the public health and safety. 2. There is a substantial possibility that even "pure" 2,4,5-T is itself a hazard to man and the environment. 3. The dose-response curves for 2,4,5-T and dioxin have not been determined, and the possibility of "no effect" levels for these chemicals is only a matter of conjecture at this time. 4. As with another well-known teratogen, thalidomide, the possibility exists that dioxin may be many times more potent in humans than in test animals. 6/ EPA under the Reorganization Plan Mo. 3 of 1970 (December 2, 1970, 35 Fed. Reg. 15G23) was entrusted with the administration of the FIFRA. 7/ Determination and Order of the Administrator, August G '(971 "(36 Fed. Reg. 14777). a/ Orders of the Administrator of November 4, 1971 and April 13, "1972 (FIFKA Docket ,\'os. 42 and 44). - 3- �5. The registrants have not established that the dioxin and 2,4,5-f do not accumulate'in body tissues. If one or both does accumulate, even small doses could build up to dangerous levels within man and animals, and possibly in the food chain as well. 6. The question of whether there are other sources of dioxin in the environment has not been fully explored. Such other sources, when added to the amount of dioxin from 2,4,5-T, could result in a substantial total body burden for certain segments of the population. 7. The registrants have not established that there is no danger from dioxins other than TCDD, such as the hexa- and heptadioxin isomers, which also .can be present in 2,4,5-T, and which are known to be teratogem'c. 8. There is evidence that the polychlorophnols in 2,4,5-T may decompose into dioxin when exposed to high temperatures, such as might occur with incineration or even in the cooking of food. .9. Studies of medical records in Vietnam hospitals, and clinics below the district capital level suggest a correlation between the spraying of 2,4,5-T defoliant and the incidence of birth defects. 10. The registrants have not established the need for 2,4,5-T in light of the above-mentioned risks. Benefits from 2,4,5-T should be determined at a public hearing, but tentative studies by this agency have shown little necessity for those uses of 2,4,5-T which are now at issue. These expressions of doubt as to the safety of and necessity for using 2,4,5-T on human food crops are now among the issues for adjudication in this Consolidated Proceeding. Registrant Dow Chemical Company then obtained an injunction against £/ further administrative action on ^,4,5-T. After almost two years 1Q/ of " i n t e r l o c u t o r y j u d i c i a l j o u s t i n g " the legal impediments to a __9/ Unreported; Memorandum and Order; E. D. A r k . , June 22, 1972. 1P7 Dow Chemical Co. v. Rud^ljshous,, 477 F. 2d 1317, 1326 (8 Cir. 1973). . .4 > �public hearing ware removed when the U. S. Court of Appeals overturned the lov;er court injunction. At this time significant new information was revealed which altered the course of this controversy. Residues of 2,4,5-T related TCDD were reported in Vietnamese fish and crustaceans, and the development of the refined instrument sensitivity (parts per trillion) necessary for determining whether TCDD is penetrating into the United States environment il/ was disclosed. In response to the greatly increased analytical sensitivity, Respondent initiated an extensive environmental and human monitoring project for TCDD. The finding of TCDD in Vietnamese fish disclosed a potential threat to public health and to the environment from even the non-food uses of 2,4,5-T (rangeland, rights of way, forestry), and in response, pursuant to section 6(b)(2) of the FIFRA as amended, EPA issued a Notice of Intent to Hold a Hearing to determine whether Ji/ all remaining registered uses of 2,4,5-T should be cancelled. The issues therein designated for hearing, in addition to those already set for hearing on the cancelled food uses of 2,4,5-T, are as follows: ll/ Baughman and fleselson. An Analytical Method for Detecting TCDD (Dicxin): Levels of TCDD in Samples from Vietnam; Environ. Health Persp., L'xper. Issue f!o. 5, pp. 27-35, 1973. 12/ 33 Fed. Reg. 19860, July 24, 1973. �A, The health hazards to n:an and to other animals which may be caused by 2,4,5-T and/or its extren^ly toxic conta.iiir.nnt, 2,3 ,7 ,8-tetrachlorcdibert20-p~dioxin (TCDD), with emphasis on the foil owing: 1. Is 2,4,5-T or TCDD a teratogen? 2. Does 2,4,5-T or TCDD induce other adverse reproductive effects? 3. Is 2,4,5-T or TCDD a mutagen? 4. Is 2,4,5-T or TCDD a carcinogen? 5. Can exposure to 2,4,5-T or TCDD induce sublethal chronic health effects? 6. Can chronic, low-level exposure to 2,4,5-T and/or TCDD cause delayed lethality? B. The extent of the health risk for man and other animals posed by 2,4,5~T and TCDD, with emphasis on the following conditions: 1. Can additional TCDD be generated in the environment .by the thermal stress of 2,4,5-T or its metabolites? 2. Can 2,4,5-T or TCDD persist and bioaccumulate in the environment? 3. What are the avenues of human and animal exposure to 2,4,5-T and TCDD? For example, can aerial drift or water transport of 2,4,5~T or TCDD cause movement of these compounds away from the site of application? 4. Are 2,4,5-T or TCDD residues being stored and accumulated in the human food supply and in human and animal tissue, including humans and wildlife directly exposed to 2,4,5-T? 5. Are other dioxins and similar contaminants, besides TCDD, present in 2,4,5-T and, if so s what risk to health do they constitute? G. What are other environmental sources of dioxins particularly TCDD, and do these sources enhance the total dioxin body burden and exacerbate the health risks raised by 2,4,5-T and related TCDD? - 6- �7. What are the current levels of dioxins in registered 2,4,5-T products and in technical material used to formulate these products? 8. Do the current methods of manufacture of 2,4,5~T provide for consistently lev/ levels of dioxins in the final technical product and what are the quality control measures used to minimize dioxin levels? C. The necessity for the continuation of the registered uses of 2,4,5-T, with enphasis on the following: 1. What are the pests which each registered use is intended to control and the degree of control achieved by each use? 2. What is the cost, timing, and rate of application of 2,4,5-T for each use? 3. What alternative controls exist for each registered use and what is the cost and effectiveness of each alternative. 4. Do alternative pesticide products cause adverse environmental effects? 5. What are the economic implications of these alternatives, including that of no control? By motion of Respondent on October 2, 1973 and order of the Chief Administrative Law Judge on November 12, 1973 these hearings on all registered uses of 2,4,5-T have been consolidated into the proceeding herein. y?.-<LL Forney/ork of the _Proceedinq From this Consolidated Proceeding a final determination will be derived as to whether the registrations xrf 2.,4,5-T should be cancelled. This decision by the Administrative Law Judge and ultimately by the Administrator is shaped significantly by certain principles. - 7 �The registrations at issue must fall unless it can be convincingly demonstrated that these uses of 2,4,5-T do not cause unreasonable adverse effects on the environment, !§/ In reaching the determination as to unreasonable adverse environmental effects, the risk to public health and to. wildlife must be balanced against any * benefit to the public's welfare from continued use of 2,4,5-T. Constit- uents of the overall balance are the answers to scientific and technical questions posed as issues for this hearing, supra. It is the burden of Registrants and of the Intervenors in behalf of continued registration to answer these questions and to persuade the Administrative Law Judge and the Administrator by clear and convincing evidence that each contested use of 2,4,5-T does not present an unacceptable risk of J!/ adverse environmental effects„ 13/ 7 USC 136. The term 'unreasonable adverse effects on the environment' means any unreasonable risk to man or the environment, taking into account the economic, social,' and environmental costs and benefits of the use of any pesticide. 14/ Seejleodane Company, Inc.v. Environmental^rotection Agency, "470 F. 2cf T9TT8'cTrY"WfJ;*lii ReJSt^ei^lnHusfneJTsr F^R. 13369 (1972); a f f ' d EpF v. Envinjnmqnt¥j_ j£roTectTo7Q''Ao'fincy7 No. 72-1548 (CADC, 1973); EOF" v, Ruckelsliaus, 43FF7"2cT58TlCADC, '1971); Stearns Eiectn^^astcfCpmnanf^rY!^'^! F. 2d 293, 304, 306 (7 Cir.~, T9T2)"; and Reasons linearly inn the Rcynstfation Deci_si_pns Concerning Products P^-'r^J.''ill10-i::!.b-£^;L?^"t-l^i^JLOlJlsLill^l^Vll1 >~ ^'n^'''^oiiinentaTTJ"rotec'Ti^n '/uje'ncy ReleVse, iSarcFTs, 1*97f,"al" p. 4VwneVe the Administrator stated: "It is clear from the statute, the legislative history, and judicial construction that the burden of establishing the safety and effectiveness of a product remain$ with the registrant from the time of initial application through continued registration of the product." - 8 - �That Respondent must go forv/ard with an' affirmative exposition of those facts which indicate why the food uses of 2,4,5-T should be cancelled and which address the questions raised as to all 2,4,5-T uses does not obviate Registrants' burden of ultimate persuasion on each issue of this proceeding, Information available to Respondent will work considerably to resolve the issues in the 2,4,5-T controversy. In its First Pre-Hearing Brief, Respondent sets forth that information which is now developed. Respondent's current data, however, docs not thoroughly illuminate certain areas of inquiry. In this regard, it is anticipated that Registrants, in attempting to demonstrate the safety of and social necessity for their pesticide product, will adduce significant new data, derived from thorough research and field monitoring, particularly on the crucial questions involving the toxicity of low-levels of TCDD. The Advisory Cownittee requested such data in May, 1971. Surely the intervening 2 1/2 years has been sufficient for Registrants to undertake meaningful research on these questions. ]_5/ Ji/ The Advisory Committee's recommendations included: "That existing deficiencies in information relative to possible accumulation in the soil and possible magnification in the food chain of the dioxin TCDD be rectified by specific research directed to this end, with these questions to be subjected to scientific review within three years of the present date and yearly thereafter until these questions are resolved. That additional post-registration monitoring for adverse effects of agricultural chemicals be established, to include both surveillance for such effects in man and domestic and wild animals, as well as consideration of the applicability of new methodology that may be evolved for specialized testing, e.g., for carcinogenesis , mutagenesis or teratogenesis." op. cit. Note 1 at p. 67. - 9- �Many of the issues presented in the Administrate:" 's 2,4,5~T Orders of November 4, 1971 and April 13, 1972 are sub?i',;ied under issues contained in the Statement of Issues of July ID, 1973. Where appropriate herein, Respondent has grouped these related issues. The numerous subsidiary questions are discussed first; ultimate questions are then discussed where Respondent is prepared to adopt a regulatory position. A. The health hazards to man and to other animals which may be caused by 2,4,5-T and/or its extremely toxic contaminant, 2,3,758-tetrachlorodibenzo-p-dioxin (TCDD), with emphasis on the following: Teratogenicity 1. Is 2,4,5-T or TCDD a teratogen? A contaminant of 2,4,5-T — tetrachlorodibenzoparadioxin (TCDD, or dioxin) -- is one of the most teratogenic chemicals known. The registrants have not established that 1 part per million of this contaminant — or even 0.1 ppm -- in 2,4,5-T does not pose a danger to the public health and safety. There is a substantial possibility that even "pure" 2,4,5-T is itself a hazard to man and the environment. The dose-response curves for 2,4,5-T and dioxin have not been determined, and the possibility of "no effect" levels for these chemicals is only a matter of conjecture at this time. As with another well-known teratogen, thalidomide, the possibility exists that dioxin may be many timer, more potent, in humans than in test animals. Studies of medical records in Vietnam hospitals and clinics below the district capital level suggest a correlation between the spraying of 2,4,5-T defoliant and the incidence of birth defects. - 10 - �Teratology is concerned with the origin and development of congenital malformations, which are abnormalities in the structural or functional development of the embryo or fetus. Embryotoxicity is a more general term which describes fetal toxicity, growth retardation and teratology. It is clear that 2,4,5-T and TCDD constitute a potential teratogenic and embryotox'ic hazard to man. Ascertaining the effect of 2,4,5-T on the fetus has been complicated by the presence of various amounts of TCDD in the tested 2,4,5-T. However, tests with 2,4,5-T in which the content of TCDD was 1 ppm or less indicate that even so-called "pure" 2,4,5-T is teratogenic. Terata including kidney abnormalities and deformed eyes and. tails has been induced by 2,4,5-T in different strains of rats at levels of 100 mg/kg/day. Embryotoxicity has been induced in rats at doses as !§/ low as 50 nig/kg. Fetal deformities, including exencephaly, missing eyelids, delayed head ossification and cleft palate were produced in hamsters tested with 2,4,5-T at doses from 40 to 80 mg/kg, containing less than .1 ppm TCDD m The dosage of 80 mg/kg caused a significant decrease in the percentage of viable fetuses per litter. A dosage of 40 mg/kg with nn detectable TCDD caused decreases both in the percentage of viable fetuses and in the average fetal weight. Increasing the amount of TCDD in the 2,4,5-T generally increased the incidence of adverse effects in the hamster. W Op.cit., Note 1. MJ C o l l i n s , T. F. X . , and W i l l i a m s , C. H. Environ. Contain. Toxicol. f{: 559 -567, 1971. - 11 - �Courtney and Moore using 2,4,5-T at 100 nig/kg, containing less than .05 ppm TCDD produced cleft palate and kidney malformations IE./ in three strains of mice. Roll demonstrated that 2,4,5-T can : 20/ produce cleft palate in mice at 35 mg/kg. Neubert and Dillman induced cleft palate in mice with 45 rug/kg 2,4,5-T, containing less than .02 ppm TCDD. As little as 15 mg/kg of purified 2,4,5-T and 12 mg/kg of 2,4,5-T butyl ester caused a decrease in fetal weight (fetotoxicity). TCDD has been demonstrated to be a potent teratogen and embryotoxicant inducing adverse effects in the microgram per kilogram (ug/kg) range in all species tested. Two teratogenic effects have been clearly related to TCDD, cleft palate and kidney abnormalities. Other effects include involution of lymphatic tissues, predominately a drastic reduction in the size of the thymus, the spleen and the lymph nodes. Because this impairment of the lymphatic organs causes a postnatal impairment of a basic defense system and thereby causes a pronounced reduction in postnatal survival the effect may be considered teratogenic, even though they may also occur in young or adult animals treated with TCDD. Other TCDD effects are embryotoxic, not teratogenic, and are also induced in adult and young animals under the toxic influence of TCDD. Theso are intestinal hemorrhage, the infiltration of fat into the 18/ Courtney, K. D. , and Moore, J. A., Toxicol. Appl. Phannacol,, 20:396-403, 1971. 19/ Roll, R.» Fd. Cosmet. Toxicol., 9:671- 579, 1971. 20/ Neubert, D. and Dillman, I., Naunym-Scimiedebcrg's Arch. Pharmacol., 272j 24 3-264, 1972. 2J/ Ncubert, D., et. aj_., Environ. Health P 2 r s p . s Exper. Issue No. 5, pp. 67-79, 1973. - 12 - �22/ liver, subcutaneous edema and delayed ossification., 237 Sparschu, et al. found increased fetal mortality, early and late fetal resorption and intestinal hemorrhage of the fetus of rats at a dietary dose of .125 .2 ug/kg. In this study no enibryotoxic effects .were noticed at .03 ug/kg; a dose approximating 600 ppt in the rats' diet during 2AJ the critical period of pregnancy. Courtney and Moore produced kidney abnormalities in rat fetuses with .5 ug/kg TCDD. They reported cleft palate and kidney abnormalities in three strains of mice after dams were injected with 1 to 3 ug/kg during days 6 - 15 of pregnancy. Neubert IS/ reported a clear-cut potentiating teratogem'c effect between 2,4,5-T and TCDD. Available knowledge makes demonstrating the presence of a public risk of 2,4,5-T, TCDD-induced birth defects less difficult than assessing the magnitude of, that risk. One gap in the state of the medical art is precise knowledge of the predictive value for man of terata testing in animals. Imprecision is inherent in extrapolating from test animals to 22/ Ibid. 23_/ Sparschu, et. _aJL_s Food Cosmet. Toxicol. 9_:405-412, 1971. 24/ Courtney and Moore, Toxicol. Appl. Pharmacol. £0:396-403, 1971. 25/ Op. cit., Note 21. - 13 - �man, but the application of certain guidelines demonstrates the importance of such testing in predicting risk to man: i 1. Society should not knowling'iy permit its members to be used as divining rods for discerning hidden destructive forces. Laboratory animals are, therefore, not a convenience but a necessity if public agencies are not to await the noticeable occurence of human birth defects which can be traced directly to a specific source before taking protective measures. Even a significant increase in human birth defects which might be related to 2,4,5-T, TCDD would likely be inapparent from normal observation of the incidence of birth defects. There is no national registry of teratogenic effects. Nor has any major human teratogen been detected by prospective monitoring of the population at large. The teratogenicity of X-ray, German measles, thalidomide and methyl mercury were recognized not by epidemio'logical survey but rather by individual medical practitioners who observed small "clusters" of deformities and traced them to the source. 2§/ The terata induced in laboratory animals by 2,4,5-1", TCDD, primarily cleft palate and kidney abnormalities, are not so egregious (as contrasted, for example, with the absence of 'limbs, caused by thalidomide) as to make an increase in the human incidence of such deformities readily noticeable. 26/ Report of the Secretary's Commission on Pesticides and Their Relationship to Environmental Health, Parts I and II, U. S. Department of Health Education and Welfare, December 1969, pp. 661-662. - 14 - �The fact that public exposure to TCDD would likely come through residues in the food supply, would prohibit even the "cluster" approach to detecting human terata, such as was pursued in the cases of thalidomide and other major teratogens, rendering a very real effect from 2,4,5-T, TCDD all the more hidden from detection by observation of the population. These informational voids compel reliance upon test animals. 2. Physiological variations existing between test animals and man do not necessarily indicate that man will be unresponsive or less responsive to 2,4,5-T and TCDD. They may be such as to render man more susceptible. Variations may exist between man and test animal in the distribution and release of TCDD during vital periods in organogenesis, in the time and degree of association of TCDD with the embryo or fetus, and in the elimination of TCDD from the maternal and fetal receptors. Little is understood about the etiology of birth defects. Even less is known about the long-term behavior of tetra-dioxin in the body of mammals. Nothing is known about the retention, distribution and elimination of TCDD in the human organism, Man may thus respond more readily than test animals to this teratogen. The thalidomide experience is demonstrative. The lowest observed effective dose for human terata was .5 mg/ky/day. The hamster, dog, rat and mouse exhibited effects at 350, 100, 50 and 30 mg/kg/day, respectively, 27/ ((alter, H., Teratology of the Central Nervous System: Induced and Spontaneous Malformations of Laboratory, Agricultural and Domestic Animals. Chicago, University of Chicago Press, 1968. - 15 - �Thus, laboratory tests on mammalian species showing that 2,4,5-T and TCDD are teratogenic present real grounds for concern. But these animal tests permit no more refined a practical conclusion, particularly as to TCDD, than that a risk of unknown magnitude exists of causing human birth defects by using 2,4,5,-T so as to contaminate the public food supply. There is no accepted procedure for setting safe levels for man based on no-effect levels for terata produced in the laboratory. The potential greater sensitivity of man to this teratogen renders highly tenuous any effort to extrapolate "no effect" levels for man. In addition, there is no widely accepted scientific procedure for establishing a safe level for teratogens in the food supply. Further, reliable no-effect levels for tetra-dioxin, in the laboratory species tested, which take into account a proportionality between the number of animals tested and the resultant teratogenic effect, may not have been ascertained. For example, in the case of thalidomide, a teratogen much more potent in man than in the tested animals, laboratory tests 28/ may have failed to designate a threshold level even for the test animals. In this regard, the fact that laboratory testing on TCDD (carried out on very small numbers of animals) demonstrates its teratogenic action at extremely low levels casts even greater doubt on the wisdom of attempting to set an acceptable "safe level" for the millions of people at presumptive risk. 23/ Jusko, William J., Pharmacodynamic Principles in Chemical Teratology: Dose-Effect Relationships. Journ. Phannac. and Exper, Therap., Vol. 183, No. 3, 1972, pp. 469-480. - 16 - �Other difficulties make impossible at present predicting an acceptable no effect level for this teratogen. Just as man may be much more susceptible than test animals, some persons in the exposed, at-risk population will be more susceptible to teratogenic effects than others. The genetics of cleft palate, for example, indicate 29/ varying susceptibilities to the inheritance of this birth defect. Further, only a fraction of the women who took thalidomide gave birth 30/ to deformed children. With varying individual susceptibilities, establishing one level for the protection of all women would be speculation. There is also lacking any clear indication that human exposure to 2,4,5-T, TCDD has not caused significant increases in birth defects. Past surveys of human exposure have not arrived at statistically significant conclusions. However the report to the American Association for the Advancement of Science si/ ™ does indicate higher stillbirths and malformations In certain areas and during periods of the heaviest 2,455~T defoliation campaign in Vietnam. That a spurious effect may have been produced in this survey by incomplete data does nots however, _29/ Personal Communication, Matthew Meselson, Harvard University, January 11, 19/4. 30 / Op, Cit., Note 26, at p. 659. 3]/ Meselson, isi. A., A. H. Westing and J. D. Constable, 1970. Backfjround Material Relevant to Presentations at the 1970 Annual Meeting of tho AAAS, Herbicide Assessment Commission of the American Association for the Advancement of Science. Revised January 14, 1971. • - 17 - �necessarily indicate that the effect was to exaggerate the incidence of stillbirths and terata. Rather, the importance of this effect may 32/ as wall have been to disguise a higher level of birth defects. Available information, then, depicts a hazard of birth defects from 2,4,5-T and related TCDD. The magnitude of the risk cannot be reliably quantified. The extent, therefore, of the hazard to man must depend on the risk of human exposure, particularly to tetra-diox'in. Where the risk of such exposure is direct, Respondent will seek the final cancellation of the related 2,4,5-T use. Where information as to the risk of human exposure is less clear, Registrants must bear the burden of demonstrating that the risk is de minimis or that the particular pesticide use in question has compelling public importance, so as to outweigh even a minor threat of human exposure. 327 Op. cit., Note 1, at pp. 71-72. . - 18 - �A•2• Does 2,4,5-T or TCDD Induce Other Adverse Reproductive Effects? Substantial questions have been raised as to whether adverse 30 / reproductive effects are induced by 2,4,5-T and TCDD. Moore, et al.—' have reported adverse postnatal effects on the kidneys of mice whose dams were treated with TCDD. The importance of TCDD in mother's milk is suggested by the fact that the highest incidence of kidney abnormality occurred in those progeny whose mothers had been treated with TCDD during the nursing period. 2,4,5-T administered during pregnancy has been demonstrated to cause increased resportion and decreased fetal and maternal weight.—7 Thomas and Lloyd^/ found that 2,4,5-T behaved similarly to other organochlorines, e.g., dieldrin and DDT, in decreasing the ability of the mouse prostrate gland to accumulate aridrogen, probably the consequence of reducing the actual uptake of androgen. The research with "toxic fat", infra, p. 24, showed a marked decrease in spermatogenesis linked to TCDD. It is known that decreased sexual drive is among the reported chronic symptoms of persons oc / who have been occupationally exposed to 2,4,5-T, TCDD.—-7 33/ op. cit., Note 18. 347 Dougherty, W.H., et_al_., Alst 9 p. 7 5 12th Annual Meeting Soc. Toxicol., 1973. 35/ Thomas, O.A. and Lloyd, J.W., Pesjticides and__the Enyjrpjiment_, Intercontinental Medical Book Corp., N.Y. pp. 43-51, 1973. 36/ Bauer, II., Schulz, K.H., Spiegelberg, U., Arch. Gewcrbepath, Vol. 18, 538-555, 1961. - 19 - ' �The significance of these indicators for human or wildlife reproduction is unclear. While Registrants must attempt to demonstrate the unimportance of such facts, it is unfortunate that there has been a failure to complete necessary multi-generation reproductive studies with 2,4,5-T, TCDD. A.3. Is2.4,5-T or TCDD a Mutagen? As with the various reproductive effects noted, there are indications that TCDD is mutagenic. One in vitro study—/ with bacteria exposed to 2,4,5-T noted no mutagenic effects. However, a practical negative conclusion cannot be reached from this study. Here, also, Registrants' laboratory research and occupational hygiene information should be adduced to speak more clearly to the question of the importance for man of these risks. Hussain, £LjlL_—/ using three distinct bacterial systems reported TCDD to be mutagenic. Jackson^./ demonstrated a dramatic inhibition of mitosis and the production of cytologies! abnormalities in the African blood lilly at levels of .2 to 1 ug/1 TCDD. 37/ Anderson, K.J., ejt_al_._, J. Agric. Food Chem. 20:649-656, 1972. 3jy Hussain, S., et al.» Arnbio., 1(1 ):32-33, 1972. 39/ Jackson, W.T., J. Cell. Sci. 10:15-25, 1972. - 20 - �A •4• Is 2,4,5-T or TCDD a Carcinogen? The carcinogenic potential of 2,4,5-T related TCDD exists. The available information conveys no discernible indication that 2,4,5-T itself, is a carcinogen. The carcinogenic potential of TCDD is determined from the following work. Buu-Hoi, et_a]_.^ reported that intraperitoneal doses of TCDD (1 and 10 nig/kg) induced liver lesions in rats. These lesions were characterized by amisokaryosis, frequent binucleation, and focal hyperplas ia of Kuffer cells. They also reported a similarity between TCDD and known heptacarcinogenic compounds in the effects on microsomal hydroxylases and in reducing liver arginase.-— 427 Gupta, eJLJLl-— reported degenerative liver lesions and large mu.ltinuclea.ted giant heptatocytes, produced by 10 ug/kg/day TCDD in rats for 13 days. The researchers conclude that the presence of these cells, the increased number of mitotic figures, and the i pleomorphism of cord cells point to the need for assessing the possibility that TCDD induces hyperplastic nodules or neoplasms. 40/ Buu-Hoi, N.P., et_a_rs."Naturwiss. 59_(4): 174-175, 1972. 41_/ Buu-Hoi, N.P., et_ai-, C.R. Acad. Sci. (Paris) D273(3)-.708-711, 1971. 4_2/ Gupta, B.N., Environ. Health Persp. Exper. Issue No. 5., pp. 127-140, 1973. �A • 5. CanJExpj)sure to 2,4,5-T or TCDD Induce Sub-lethal Chronic Health Effects? . 6' Can Chronic, Low-1 eve1_ Exposu/e to '2,4,5-T and/or TCDD Cause PeTayed Lethality? Except for the potential reproductive and mutagenic damage previously discussed, available information does not indicate that exposure to low levels of 2,4,5-T, itself, induces chronic effects. The apparent rapid human excretion of 2,4,5-T tends to support a tentative conclusion that chronic ill health would not be expected from long-term low-level 4V exposure.— The same cannot be said for 2,4,5-T related TCDD or other possible toxic contaminants of 2,4,5-T. The facts on TCDD's chronic health effects are of major evidentiary concern. These facts describe a pernicious, little understood toxicant, capable in minute quantities of inducing a variety of chronic illness and, perhaps, of causing death as a delayed response to exposure. The burden of mitigating this concern must be particularly heavy for Registrants in that the risk is clearly raised by every available research effort and the lifetime feeding studies in mammalian species, necessary to effectively lay to rest these strong signals, have not been conducted. Of major concern is the effect of TCDD on lymphoid tissue, previously discussed.—/ Related to such impairment of an organism's basic defense system is the conclusion of Vos, et__a]_.---' that TCDD at sublethal doses 43/ G e h r i n g , P . O . , e_t__aj_. , T o x i c o l . App. P h a r m a c o l . 26:352-361, 1973. p. 1_3_. 45/ V o s , O . G . , et nl . , E n v i r . Health Pcrsp., Exper. Issue No. 5, pp. 149-162VT973. - 22 - �suppresses the cell-mediated immunity in both mice and guinea pigs. The authors suggest that, in the absence of major pathologic effects except in the lymphoid system, the death caused by sub-lethal doses was due to impairment of the organism defense mechanism. Zinkl, et al . ' — observed TCDD related lymphophenia in mice and guinea pigs, a result which is consistent with its noted immuno-suppresive effects. Allen and Carstens— ^ fed monkeys various percentages of "toxic fat", reported to contain 35 ppm of TCDD and other dioxions. There was an inverse relationship between the percent toxic fat in the diets and the number of days the monkeys survived. Monkeys fed 5 or 10% began dying around the third month. At the lowest dose, the total dioxin intake which produced a mean survival time of 445 days was 2.15 mg/1.— / In all test groups, the TCDD induced a -variety of chronic illness one or two months before death, including alopecia and subcutaneous edema, focal neurosis of the liver, gastric ulcers, reduced hematopoiesis and spermatogenesis. These test data suggest that TCDD poisoning may be cumulative.---' Daily doses of 10 ug/kg/TCDD killed 15 of 1C rats, on days 15 through 31.--/ Rats receiving 1 ug/kg for 31 days suffered h Persp., Issue No. 5, pp. 111-123, 1973. 47;/ Allen and Carstens, Amer. J. Vet. Res., 28: 1513-1526, 1967. 4S/ Flick, ejt. aK , Poultry Sci., _52: 1637-1641, 1973. 49 / Baughrnan and Meselson, Environ. Health Persp., Exper. Issue No. 5, pp. 27-35, 1973. 50/ Gupta, ct_al_. , Environ. Health Persp. Issue No. 5, pp. 125-140, 1973. - 23 - �decreased weight gain which was reversed after cessation of dosing. A no effect level was not found and whether withdrawal after chronic exposure may reverse more serious ill-effects is unclear. Dosing guinea pigs with 1 ug/kg a week killed all animals, on the average within four weeks.--' pries52/ added TCDD (C~^ labelled) in the diet of rats at 7 and 20 ppb. The rats were placed on the feed for 6 weeks and withdrawn for 4 weeks. After 6 weeks of feeding a plateau in the body residues had apparently not been attained in either sex. Decreased feed consumption and weight gain were observed. The liver/body weight ratio was also increased. This effect was reversed by withdrawal but only as to the lower dose. Poland and Glover™'1' using the chick embryo conclude that TCDD is approximately' 3 orders of magnitude more potent than other known porphyrogenic compounds. Goldstein, et^ al.—' also conclude that TCDD is the most potent porphyrogenic chemical known. A single doss of 150 ug/kg TCDD caused a 4s000 fold increase in the uroporphyrin content of the mice livers within 3 weeks and increased induction of ALA synthetase. Similar effects were induced by weekly doses of 25 ug/kg for one month. Jn addition to porphyria, extensive liver damage, atrophy of the thymus, 5_iy i b i d , at p. 127. 52/ USDA - Beltsville; unpublished. 53/ Poland, A. and Glover, E., Science, 170., 476-477 (1973). Goldstein, et al., Fed. Proc., 32 702 (Abstr. 1973) -24 - �edema and terminal hemorrhages were observed. The authors suggest effects may be seen at lower levels after longer periods of exposure. Because the effects of long-term exposure to low levels of TCDD remain undetermined, an acceptable level for man cannot be set. If TCDD exposure causes delayed lethality or, if continuous impingement of TCDD on human organs otherwise causes cumulative effects, or if TCDD concentrates in human tissue, a level of exposure which would be safe for the general population may not exist. Even residues below the current level of detection may be unsafe. A• The Risk to___the_ Environment (Non-Human) Of the twenty or so different chemical compounds commonly called 2,4,5-T, each contains impurities or inert ingredients in the technical pesticide product. Among these impurities is such "inert" material as TCDD. The total published wildlife toxicological information for these compounds and their impurities is slightly more than zero. An abundance of data on other toxicants—/ hss permitted Respondent in its regulatory posture to parse with relative precision. With little environmental data now available, Respondent will adhere to certain guidelines, derived from existing knowledge, in its effort to illuminate the sphere of ecological hazard. Hopefully, Registrants and their intervenors by proffering reliable field and laboratory data on the Industries, 37 F.R. 13369. - 25 - �degree of environmental risk, will also avoid parsing with a cleaver. Surely Registrants cannot insist that "body counts" are necessary before the trier of fact herein can reasonably conclude that unacceptable risk to the non-human environment exists. Respondents environmental guidelines for this proceeding are as follows: (1) The "indirect" ecological effects on wildlife from using 2,4,5-T are a subject for discussion in this hearing. Many wild species are dependent for their very survival upon the availability of specific habitats. Some must have even specific plants to exist. For example, "range management," the widespread, indiscriminate removal of sagebrush by 2,4,5-T (or by other means), will eliminate the sage grouse which depends upon sagebrush for 99% of its food.^L/ Similarly, the Montana Fish and Game Commission showed that 2,4,5-T used for total brush control in one area had caused an 86% reduction in mule deer.—/ The Registrants and appropriate Intervenors must discuss the extent of such range management, and the environmental as well as the economical acceptability of more restricted brush control or strip spraying, by which areas of brush necessary for wildlife habitat are left standing. (2) There is no reason to assume that the demonstrated low-level toxicity of tetra-dioxiri is not exerting its effect, in the environment. Ranyeland application of 2,4,5-T may amount to 4 pounds acid equivalent per acre, resulting in 120-960 ppni on grasses. The dioxin content of the grasses therefore could reach .96 ppb assuming an initial TCDD level of 1 ppm in the 2,4,5-T. Grass-eating wildlife species with an acute oral LDr)0 of .6 ug/kg (that of the most sensitive 5_6/ 8th Western States Sage Grouse Workshop Proceedings, Lewiston, Montana, August 7-8, 1973, p. 19. 57/ Personal CoiVniiunication, State of Montana Department of Fish and Game, Helena, Montana. - 26 - �non-wildlife species tested so far, the guinea pig) would consume a median lethal dosage by the time of ingesting one-half their body weight in grasses, a feat which would require one to three days for small species. Less TCDD could produce teratogenic effects. Given the extremely rapid environmental scavenging of dead or deformed small speciesj the detection of such field mortalities would be extremely difficult. (3) Information discussed, infra, indicates the capacity of TCDD to penetrate, persist, to move and to bio-concentrate in the aquatic and terrestrial environment. Given the incomparable toxicity of this small molecular compound, and given the practical nonexistence of facts about its ecological effects, the Respondent suggests that it cannot make a reliable conclusion that TCDD is not causing serious environmental injury. Demonstrating a socially acceptable risk is the obligation of Registrants. B. The Extent of the Health Risk For Man and Other Animals Posed by 2,4,5-T and TCDD, with Emphasis on the Following: 1. Can Additional TCDD be Generated in the Environment by the Thermal Stress of 2,4,5-T or its Metabolites? There is Evidence that the Polychlorophenol in 2,4,5-T May Decompose into Dioxin when Exposed to High Temperatures, Such as Might Occur with Incinceration or Even Cookinn of Food. - 27 - �TCDD can be generated by the thermal stress of 2,4,5-T and some of its metabolites. This raises the potential for the generation of additional dioxin under environmental conditions. The widespread use of 2,4,5-T, coupled with the persistency of TCDD and Us extreme toxicity, therefore, raise the possibility that people may be exposed to a latent destructive force -- the accidental or unknown triggering of the thermal release mechanism by which "harmless" amounts of 2,4,5-T, its esters or salts, convert to lethal tetra-dioxin. Tests-—/ demonstrate the thermal conversion of alkaline salts of 2,4,5-T into TCDD. Sodium 2,4,5-Trichlorophenate held at the melting point produced measureable quantities of TCDD. Baughman and Meselsonri/ report they have repeatedly formed TCDD at the 1000 to 2000 ppm level by. heating the sodium salt of 2,4,5-T, a form most likely to persist on wood. Recent work by Thomas-—' corroborates the observations of Baughman and Meselson. A summary of these findings is as follows: 1. When the sodium salt fo 2,4,5-T + Cu -I- NaOH are heated in a closed tube (entire tube heated) at 450°C for 6 hours, ca 10 pprn of TCDD are produced. 2. When the sodium salt of 2,4,5-T and 2,4,5-trichlorophenol are heated in an open tube (only the bottom of the tube is heated) in a sand bath at 350° for 7-1/2 hours, between 250 and 500 ppm of TCDD are produced. 3. When the sodium salt of 244,5-T and 2,4,5-trichlorophcnol are heated in a closed tube (entire tube heated) at 350° for 7 hours, ca 1500-3000 pprn of TCDD are formed. 58/ Lancjur, H.G., cjtjaJL» Environ. Health Persp., No. 5 5 pp. 259-266 (1973). 59/ Communication with the Office of Pesticide Programs (OPP), U.S. EPA., July 30, 1973. 60/ Private communication with Mr. Carroll Collier, OPP, EPA; Beltsville, Md, - 28 - �Thus three independent groups have demonstrated this thermal conversion into TCDD.—' Pyrolysis has also been shown to form dioxins from chlorophenates, under presumably anhydrous conditions.—' Five chlorophenates, from 2.4 dichlorophenate to pentachlorophenate were tested, each formed a corresponding dioxin. Crosby—/ reports the formation of octachlorodioxin from the burning of wood treated with pentachlorophenol. Buu~Hoi—^ reported the formation of tetra-dioxin from burning vegetation. No details are available on the procedures followed in burning the foliage or in collecting the samples. Analyses of the mass cr I spectra asserted to be that of TCDD do not appear completely valid.—7 Most existing tests on the burning or the heating of 2,4,5-T treated products (vegetation, meat, fat) have not produced detectable tetra-dioxin.—'/ But the level of analytical sensitivity in these experiments was .05 to .1 ppm. Current sensitivity for such analyses is down to about 5 parts per trillion. The generation of TCDD at levels much lower than .05 ppni would be 'Lexicologically significant. In addition, the multitude of environmental conditions under which 2,4,5-T, its salts and esters, can be exposed to thermal stress makes complete laboratory replication impossible and prohibits reliance on only a few negative laboratory tests. FIT" o'pTTTtV', ~l"lotis~58 - 60. 62/ op. cit., Note 58. 63 Crosby, et_al,., Environ. Health Persp. , No. 5, pp. 259-266 (1973). 64/ Buu-Hoi, et_aJL, Comptes Rendus Acad. Sci., Paris', 273 Series D, 708 (1971). 65/ op. cit. , Note 62. C6/ Watts, R.R. and R. Storher, JAOAC, 56^(4)1026 (1973). - 29 - �B 2 • CAN 2.4,5-T or TCDJD PERSIST AMD BIOACCUMULATE. THE RER.I STRAHTS.. J !AVF. JiQTMISTAnL IS! I ED TII'YT THE ' TISSUES. ir'Oiir'OR' . SHALL DOSE S_ CpJLD^ BLHL DJ/l£" T^OTIuUS_ L E VE" L S HI THIN MAT] AND ANIMALS, AMP POSSIBLY 1'QH'E FOOD CHAIN AS UELl. • • B.4. ARE 2,4,5-T_or_TCDD RESJOUES BEING STORED AMD ACCUMULATED IN THE KgWTtJOL) SUPPLY A! IT) Hi HUTJATTA'TlY Alj IjffiTY ISSUE,, I HUMAllS A;']i) VyTTDllFL 'DIRECTLY EXPOSED TO" 2 5 4 , 5-T 2,4,5-T does not appear to be a persistent compound, but not enough is known about its metabolic products or pathways and about the presence of conjugated including "bound" products, and therefore undetected residues in foods resulting from the use of 2,4,5-T. Unfortunately, methods for the determination of "bound" residues will only detect those conjugated products to the extent to which they are subject to the technique in use. For example, the §2J method of Chow, et al can lead to signicantly higher results for "bound" residues of 2,4,5-T in rice straw than the method of Yip and 68/ Ney or the current method of the Food and Drug Administration. There remains however, the possibility of the presence of other conjugated products not so cleaved which would not be detected,, Much of this area has not been clarified by the Registrant. 697 Many species matabolize 2,4,5-T. ~ Also, 2,4,5,T can be rapidly degraded by soil organisms, usually not persisting into the next growing season. The degradation rate in soil is influenced by climatic conditions Zl/ and microbial action. Because definitive soil metabolism studies are unavailable the buildup of persistent matabolites, however, cannot be discounted. Nor can movement of 2,4,5-T metabolites into rotational crops be discounted since current analytical techniques may be unresponsive to residues of bound 2,4,5-T or its metabolites. ^ c . ,6 576 (1971). 687 Yip and Ney, V'eods J4 167 (196G);and FlJA Pesticide Analytical Manual V o l . 1 . , Sections 222. T'3c>222. 14,222. 15, &222.1G(b) (1963 r e v ' d cd.) 69/ Loos. M.A. "Degradation of Herbicides", pp. 1-49, Ed. P.C. Kearney, Marco! Dekker Inc. N . Y . (1969) 7p_/ Bauer, et a]. Wood Sci., 1_7 567 (1969); Alexander & Aleen, J.Agr. Food Cheni. 9 45 (1961) - 30 - �Storage of 2,4,5-T metabolites in the tissues of certain aquatic organisms may also occur. Exposure of fish to degraded 2,4,-D Zi/ residues results in tissue accumulation of metabolites. It is reasonable to conclude, based on the similarity of many of the degradation products of 2,4,-D and 2,4,5-T, that acquatic organisms would also store 2,4,5-T metabolites. Ill Considerable data exists on the persistence of 2,4,5-T in grasses. Rapid decline of 2,4,5-T residue is observed, starting immediately after treatment and reaching "neglible" levels in about 6 months. This decline must be the combined result of dilution, plant metabolism, surface erosion, volatilization and photodegradation. Residues of 2,4,5-T and of the 2,4,5-Trichlorophenol moiety in milk and meat resulting from the use of 2,4,5,-T in pastures and on rangeland have been 737 reviewed. While the author concludes that residues in milk, meat, fat or meat by-products are not likely to be significant if 2,4,5-T is used according to label direction, more recent research shows that "bound" residues of 2,,4,5-T in sheep and cattle livers may be measurable (>.05 pprn)even after withdrawal from a diet containing 2!>4.15~T.74/ No data are available on the fate of metabolic products from forest or right-of way applications nf ? J /i 5r^ I « i~T U I <*"! Monitoring of human food supply appears to cooroborate these conclusions on-the persistency of 2,4,5-T, although nothing is known about potential metabolites of 2,4,5-T in human food or the presence of bound residues which are not subject to detection by existing 2,4,5-1 analytical methods. TV "SchGTtz, ETF.iC. ~Agr ToocfcTiGin. ,2_1, 186 (1973) "72/ op.cit,, Hotc 70; and Bovory,R."Bauer, Bull Env. Cont. Toxic 8 (4) 229 (1972) 737 Lcruj. M . L . , Down to E a r t h , 2 8 ( 1 )12(1972) 7£/ Pesticide P e t i t i o n , 2,4,5-tT the Dow Chemical Company, No. 1 F 1102. - 31 - �Since 1969 the Food and Drug Administration (FDA) has monitored for chlorophenoxy acetic acids in the following commodities: (1) Whole grains for human use, such as wheat, corn, rice, oats, etc, (2) Animal by-products including slaughtered mammals and fowl. (3) Milk (4) Other dairy products. From 1969-1971, 19 of 1226 samples contained 2,4,5,-T or 2,4,-D derivatives, ranging from a trace to .02 ppm. All but one sample was milk. Earlier FDA results are summarized reliably in the May 7, 1971 Advisory Committee Report, "From about 10,000 food and feed samples examined from 1964 through 1969 only 25 contained trace amounts of 2,4,5-T (less than 0.1 ppm) and only two contained measurable amounts, 0.19 ppm in a sample of milk in 1965 and 0.29 ppm-in a sample of sugar beets in 1966. Furthermore, of the 134 total diet samples involving 1600 food composites (Market Basket Survey) analyzed from 1964 through April 1969, only 3 contained 2,4,5-T. Tv/o were dairy products containing 8 to 13^ fat with .008 and 0.19 ppm in the fat. A single moat, fish and poultry composit from Boston consisting of 17 to 23% of Zi/ fat was found to contain .003 ppm 2,4,5-T on a fat basis." 75/ op. cit., Note 1 �Tetra-dioxin, on the other hand, is clearly both persistent and bioaccuinulative. It resists microbial deterioration.7_6_/ Out of 100 microbial strains which degrade most persistent pesticides, only 5 showed any ability to degrade TCDD. Soil studies indicate that tetra-clioxin has a half-life of greater ILJ than one year. That no metabolites were found in this research also indicates the absence of microbial degradation. Herbicide test plots sprayed with Agent Orange (2,4,D and 2,4,5-T) have 78/ shown measurable amounts of TCDD several years after final treatment. Model ecosystem studies suggest that TCDD bioconcentrates more than DDT. A two trophic level, model ecosystem with mosquito larvae and brook silverside minnows demonstrated a bioaccumulation factor of TCDD in minnows 540 times that of the TCDD in the water. DDT's 111 accumulation factor by comparison was 306. A similar acquatic ecosystem showed catfish to accumulate tetra- 8Q/ d i o x i n in only three days by a factor of 14..000. "" A direct r e l a t i o n s h i p was observed between concentrations in ambient water and in the tissues of several acquatic species, when tetra-dioxin was introduced into the a q u a t i c system in the form of treated sediment. The f o l l o w i n g i l l u s t r a t e s the observed r e l a t i o n s h i p between TCDD concentration in soil and in the water: 767 TiaTsairfura . ,'F*. and Ti7 PJenezet, Eny. Health Persp.No.5^53(1973) 77 / Kearney, P.C.ejt a j . , " C h l o r o d i o x i n s - O r i a i n and Fate," E . B l a i r , e t pp. 105-111, Amer." Chem Soc. , Adv. ChenTsin 120,1973. 7F./ P r i v a t e C o m m u n i c a t i o n with OPP, Major Mabson, USAF, Wash. D.C. 79/ Op. c i t . , Note 76 807 Private Communication,USDA, Isensee •30 \JO �TCDD Concentration jn Soil (PPM) TCDD Concentration in K'ater (PPT ) 0.1 7ol3 0.01 0.66 0.001 0.26 0.0001 Oo05 When the soil content was .1 ppm TCDD, various acquatic organisms accumulated the following levels of tetrs-dioxin: i-ini TCDD Level (PPM) Time of Exposure Algae .08 28 ~ 29 days Duckweek .03 28 - 29 days Snails .12 28 - 29 days Daphnia .16 28-29 days Gambusia .44 3 days Catfish .10 3 days Thereforej rice flood. waters and sediment containing 2,4,5-T related TCDD may well transport tetra-dioxin from the ricefields. to fish and crayfish, components of the human food supply. For example, a one pound per acre treatment of rice with 2,4,5-T containing .1 ppm TCDD will generate a tetra-dioxin level of approximately 12 ppt in the upper 1/4 inch of soil. A graphical extrapolation of the soil-water data discussed, s_up_rn^ indicates that this could lead to a water concentration of .01 ppt« A direct correlation between water and fish concentrations would result in a tetra-dioxin level of 140 ppt in fish within 3 days of exposure to rice flood water. Residue data corroborate these conclusions as to the persistency and bioaccumulation of 2,4,5-T related TCDD. - 34 - �Analysis of residues in Vietnamese shrimp and crustaceans detected significant levels of tetra-dioxin following defoliation treatments with 2,4,5-T in regions draining into 8/ ] the areas from which the shrimp were collected. It appears that these residues have not declined appreciably between 1970 and 1973, although the defoliation ceased in 1969. Wildlife in the vicinity of areas of Agent Orange application at Eglin Air Force Base retained measurable levels of TCDD several years 82/ after use of the herbicide was stopped. Beef calves fed for 28 days .on diets containig 100 and 1800 ppm 2,4,5-T with .5 ppm TCDD, retained substantial amounts of tetra-dioxin in the 83/ fat and in the liver. It therefore appears that at least 25% of the dietary intake of tetra-dioxin may be stored in body tissues. Fries feeding rats 7 and 20 ppb TCDD suggests that 75% of the total retained residues may be stored in the liver.8_4_/ Table I infra suggests that the withdrawal of cattle from a diet contaminated with dioxin for as long as one week may have little effect in decreasing TCDD residues. Therefore, current label provisions requiring "feed off" periods on dioxin free food in order to assure the absence of dioxin residues in the meat are not likely to be effective in reducing tetra-dioxin residues if present in any significant amounts. 8J7 Baughman and Meselson, op.cit, Note _49 82/ Op. Cit, Note 78 837 EPA, OPP TCDD Monitoring Project 847 Private Communication, Fries. G. USDA Beltsville, Md. - 35 - �Cattle, sheep and goats fed immediately after application of 2,4,5-T to rancjsland accumulated residues of tetra-dioxin in their fat from 6 to 41 ppt and in the liver from 1 to 5 ppt.85/ The totra-dioxin content of the commercial 2,4,5-T used was .04 ppm. Using a factor of fat/TCDD diet of 2.1 (See Table I) one can calculate a value of 10.08 ppt, which could be expected in the fat of a young calf exposed to similar residues. Monitoring of wildlife collected along rights of way in the U.S. demonstrates, as does the Vietnamese aquatic residue data, that 2,4,5-T related TCDD can enter the food chain from "non-food" uses. Shrews sampled accumulated tetra-dioxin residues up to 397 ppt, averaging 202 ppt.86/ Thus, 2,4,5,-T related tetra-dioxin is persistent, and it bioconcentrates. It is quite capable of penetrating into the environment and contaminating the human food supply. While Respondent is in the midst of extensive residue monitoring in order to define this hazard more precisely, it is now the obligation of those who profess the safety of this pesticide to prove their position in the face of these facts. 85/ Op" cit Note 83 86/ "I bTd ~~~ - 36 - �TABLE 7." DOW CHEM CO. CALF NO. r- - TCDO LEVEL IN LLT CALF FAT AND LIVER RESULTING FROM CONTROLLED EXPOSURE (28 DAYS) TO DIETS CONTAINING VARIOUS LEVELS OF CONTAMINATED M.5-T TOTAL ' CALF • WEIGHT (kg) - TOTAL AMOUNT OF FORTIFIED DIET FED OVER 28 DAY PERIOD 0 Control PPM 2,4,5-T IN FORTIFIED DIET PPT TCDD IN FORTIFIED DIET 0 PPT TCDD FOUND IN CALF FAT N.D. 0 PPT TCDD FOUND IN CALF LIVER N.D. TCDD PPT FAT PPT DIET PPT TCDD EXPECTED IN FAT IF 100/i OF TCDD ABSORBED *** % TCDD UPTAKE FROM DIET 362 242 231 100 50 103 28 2.1 365 28 3G3 251 255 300 150 300 61 2.0 1171 26 372 213 173 900 450 505 168 1.1 2918 17 378 222 172 1800 900 1120 406 1.2 5440 21 969 215 114 1800** 900 1077 240 1.2 3585 30 *TCDD Conte.it of 2,4,5-"-" -^^ 0.5 ppm • **Feeding Period followed by 7 day withdrawal from TCDD containing feed. ***Based on a fat content of 13% for a 500$ steer (See Morrison, J. B.» "Feeds and Feeding'Sp.. 202, Morrison Publishing Co., Ithaca, N.Y., (1954). �B. 3. WHAT ARE THE AVENUES OF HUMAN AND ANIMAL EXPOSURE TO 2,4,5-T AND TCDD? FOR EXAMPLE CAN AERIAL DRIFT OR WATER TRANSPORT OF 2,4,5-T OR TCDD CAUSE MOVEMENT OF THESE COMPOUNDS AWAY FROM THE SITE OF APPLICATION? Besides the contamination of the sites of 2,4,5-T application with the uptake of pesticide residues by plants and animals in those areas and the resulting bio-concentration, there are indications that 2,4,5-T and related tetra-dioxin will be transported aerially and by water beyond the sites of application. Aerial application of 2,4,5-T cannot be made without aerial drift. The magnitude of such dispersal depends on the droplet size, wind velocity, humidity, type of formulation used, air temperature and altitude of the aircraft. Elaborate precautions taken with the aerial use of Tordon 225 (USEPA Reg. No. 464-407) exemplfy this problem of drift on rangeland. Tordon 225, a formulation of 2,4,5-T and picloram used to control mesquite, cannot be aerially applied unless a buffer zone between food crops of up to 1/2 mile is maintained. Aerial applicators are given special training. Similarly the aerial use of 2,4,D - a phenoxy herbicide, on Louisiana rice fields must not be applied closer than 1/2 mile to susceptible crops, and only under the supervision of a state inspector. EJ 87/ Gerlow, A. R., "The Economic Impact of Cancelling the Use of 2,4,5-T in Rice Production", p. 7, ERS-510, USDA, Washington, D. C., 1973. 37 �In addition, drought conditions on the. range and the persistency of tetra-dioxin in soil suggest the probability that TCDD contained in tops oil is transported by wind erosion. Thus, in any area of 2,4,5-T application, aerial distribution of 2,4,5-T and TCDD beyond the immediate site of application, uptake from there and further transport, are distinct probabilities. The absence of air monitoring samples of TCDD prevents a determination of whether TCDD persists and is transported long distances in the atmosphere. Similarly, while Respondent has not yet completed field monitoring, it is probable that water transport of TCDD occurs. Given the demonstrated persistency of TCDD in the soil, gulley and sheet erosion would be expected to carry silt particles from the upper layers of soil into bodies of water for transport. This would be especially true as to poorer quality, over-grazed rangelands, where the ratio of grass tuft to bare ground is low. In poor-condition, short-grass ranges bare spaces of 1 to 4 feet can predominate. ™ It is probable that 2,4,5-T is also directly applied to range!and water holes. Livestock and wildlife drinking such water are likely exposed to TCDD via the sediment suspended in such waters or as TCDD which has dissolved in tho water. 80/ The Yearbook of Agriculture — "Grass", p. 525, USDA, Washington, ETC., 1948. 38 �Suspended sediment containing TCDD in rice fields and rights of way would also be transported by run-off from such sites. Once the tetra- dioxin (as sorbed on silt particles) reaches water a new sorption/desorption equilibrium is established, with discrete amounts of tetra-dioxin dissolving directly into the water. 89/ Estimates by Miller, et. al. are that forest applications of 2,4,5-T can be expected to cause residues of about .01 ppt of TCDD in streamwater, if a tetra-dioxin level of .1 ppm exists in the original formulation. Direct application of 2,4,5-T to streamwater would cause most of this residue. Therefore, based on the solubility of tetra-dioxin in water and provided no adsorption occurs on benthic surfaces or suspended solids, all such tetra-dioxin would be expected to remain in solution. Using considerations discussed, sj-ysra^ for graphically projecting acquatic residue bio-accuniulation, tetra-dioxin could be expected to build up to at least 140 ppt in fish from such forest applications. Contamination of water supplies with'tetra-dioxin is further suggested by recent monitoring data on streams in the Western United 90/ States, * The Canadian River near l/hitefield, Oklahoma, and the Arkansas River belo;.1 Van Buren, Arkansas showed the greatest contamination of 2,4,5-T with levels ranging from .03 ppb - .04 ppb and .01 - .04 ppb, respectively. 897 Miller, R., et. aj^, Envir. Health Persp,,, No. 5, 177 (1973). 907 Mnnigold, D. B. and J. Schulze, Pest. Kon. J., 3(2)2 (1969). 39 Other �streams with detectable levels were the Brazos River at Rich-man, Texas (.01 ppb - .06 ppb), the Pecos River near Artesia, N.M. (.05 ppb) and the Green River at Green River, Utah (.07 ppb). Since the analytical methodologies utilized were sensitive only to 2,4,5-T and its esters, TCDD or degraded 2,4,5-T in terms of trichlorophenol moiety metabolites would not be identified,, Therefore, the levels of 2,4,5-T detected are indicative of substantially higher inputs of 2,4,5-T followed by. microbiol degradation. In addition, the fact that residues of tetra-dioxin are detected in Vietnamese shrimp caught 30 kilometers from the shore also suggests that this 9J/ contaminant is quite mobile. B. 5. ARE OTHER DIOXINS AND SIMILAR CONTAMINANTS BESIDES TCDD PRESENT IN 2,4,5-T AND, IF SO, WHAT RISKS TO HEALTH DO THEY CONSTITUTE? B. 6. -WHAT ARE OTHER ENVIRONMENTAL SOURCES OF DIOXINS PARTICULARLY TCDD, AMD DO THESE SOURCES ENHANCE THE TOTAL DIOXIN BODY BURDEN AND EXACERBATE THE HEALTH RISKS RAISED BY 2,4,5-T AMD RELATED TCDD? What are the current levels of dioxins in registered 2,4,5-T products and in technical material used to formulate these products? The absence of other chlorodioxins, chlorodibenzofurans and chlorinated hydroxy diphenyl ethers has not been carefully established for any 92/ currently registered technical 2,4,5-T products. In 1972, Firestone ™~ 9)J Personal Communication, Matthew l-^selson, Harvard University. These shrimp as juveniles may have ingested the TCDD while in estuaries near the shore. 92/ Firestone, D. et^ £L.» JOAOC, 55(1)85 (1972). 40 �conducted a survey of dioxins In trichlorophenol samples collected in 1970 using a gc/ms (gas chromatograph, mass spectrometry) method. Other dioxins including 2,7 dichloro, 1,3,6,8-tetrachloro and a pentachlorodioxin were found. Chlorofurans and chloroethers were also found. A hexachlorodiophenyl ether was found in one sample and trichlorotetrachloro- and pentachloro furans were found in some of the other samples. No information is available on the presence or absence of 2,3,7 trichloro dibenzo-p-dioxin although bioassays by the method of 93/ Poland ' suggest that this compound may have a potent biological activity in the same order of magnitude as TCDD. The recent findings of additional, unknown "neutral" contaminants in production grade 94/ 2,4,5-T " clearly demonstrates how little is known about various impurities in 2,4S5~T. Similar impurities in the "neutral" fraction 95/ of 2,4,5-T have also been noted in our own laboratories. In any event, all chemicals made by manufacturing processes having the capability of forming impurities with the degree of | toxicity of TCDD should be supported with quality contrcjl procedures capable of detecting and quantifying such materials. Furthermore, once the Registrants have identified all of the impurities, these should be toxicological'ly evaluated. The so-called "pre-dioxitk", hydroxy 93/ Poland, A. and E. Glover, Science 179,476 (1972). 9_4/ Huston, B., J. Agr. Food Chern., 30J3) 724 (1972). 95/ Op. cit. , Note 60. 41 �967 chlorodiphenyl ethers should also be evaluated in terms of their possible presence in 2,4,5-T formulations. If present, these materials are potential sources for 2,4,5-T related dioxin formation under environmental conditions. Table II gives a list of registered pesticide products in addition to 2,4,5-T which are expected to be potential sources of dioxins. Of these, five utilize 2,4,5-trichlorophenol as a manufacturing intermediate, and therefore can be expected to add to the overall environmental burden of dioxin. Since some of these compounds have established tolerances on food or feeds, any dioxins residues entering the food supply from these sources would be directly additive to any similar residues resulting from the 2Z/ use of 2,4,5-T. A special and unique situation is encountered with the currently registered use of ronnel [0,0-dimethyl 0"(2,4j,5~trichlorophenyl) 98/ phosphorothioate]. When used as a supplement to cattle food * this compound is a potential source of TCDD in beef and dairy cattle. the currently registered dosage of .002 Ibs. At active ronnel (in food) per TOO Ibs of body weight per day for 7 consecutive days, a 500 Ib. beef containing 13.7% fat could accumulate up to 5 parts per trillion TCDD in its body fat. This is based on a retention factor of 25% (see 96_/ Nilsson, C. and L. Renberg, "Further Studies on Impurities in Chlorophenol." Unpublished manuscript. 97/ 98/ EPA Compensiuni of Registered Uses; Section III--R-1. 2. ibid. 42 �Table II), and a TCDD content of .05 ppin in the ronnel. Another potential source of TCDD could be from the photochemical reductive dechlorination of higher dioxins, especially hexachloro, heptachloro 99/ and octachloro dioxin found in pentachlorophenol. A.lso, the additive toxic effect of other chlorodioxins, including the octa, hexa, hepta, penta, tri and di isomers, all of which can be found in one or more of the products listed in Table II, cannot be discounted. For example, 2,3,7 trichloro-ciioxin demonstrates a . high degree of biological activity in the enzyme screening process of TOO/ Poland." To date all compounds showing high activity with-the Poland enzyme assay have also been found to be patent acnegens and/or are highly ernbryotoxic. Formation of 2,3,7-trichloro dioxin from TCDD by reductive dechlorination caused by photochemical effects is a distinct possibility. If these residues accumulate as readily as TCDD, their biological effect would, indeed, be additive in nature. _JJ9/ Plimrner, J. et,._ aj^, Science U3 748 (1971). TOO/ Op. cit., Note 93. 43 �TABLE II 2,4,5-trichlorophenol and salts 2,4,6-trichlorophenol 2,3,4,6-tetrachlorophenol and salts Pentachlorophenol ( a n d sodium salt) 2,4-dichlorophenyl benzenesulfonate p-chlorophenyl 2,4,5-trichlorophenyl sulfone (Tetradifon) 2,4-dichlorophenoxy acetic acid (2,4-D) and its derivatives 2,(2,4,5-trich1orQplienoxy)propionic acid and derivatives (2,4-DP) 0-2,4-dichlorophenyl 0,0-dicthyl phosphorothioate (VC-13) 0-2,4-dichlorophenyl p-nitrophenyl ether (TDK) 2-(2,4,5-trich1orophenoxy)ethyl 2,2-dichloropropionate (Erbon) 0,0-dirnethyl 0-(2,4 s 5-trichlorophenyl) phosphorothioate (rcmnol) 3,6-dichloro-o-anisic acid (Dicamba) 3,5,6~trichloro-0"anisic acid (Tricamba) TrisI(2,4-dichlorophenoxy)ethy1 phosphite Hexachloropiiene 0-(4-bro;no-2 > 5-dichloropheny1) 0,0-dimethyl phosphorothioate (Bron;ophos) �B 7 - !'!1/\T AR^THEJURRKNT LEVI1S OF DTOXIIIS II! REGI$TE_RFD_2,4,5-T 5 MP^'L l£Jll CTft'ircAl !'•. -. n- iiTAi 'uslin p FORMULATE THESE PRODUCTS'" B 8 " DO Tr!E CURRENT _MEJI 10DSJJ.F. ! WIU FATUR£_ OF _2 ,£, 5-T provide FOR CUiiSIST'ErrfLY' LOU LEVEL 5~OF~Dl6XINS'"l if THE' FINAL . CT"APD :Jl/\? ARTTlii: OU/fl.nt CONTROlv MEASUkYs"D"SED T O " 7 ' J l a " " Transvaal, Inc., states that the TCDD content of its 2,4,5-T acid, from which their products are derived, is less than 2 pptn and TOT/ averages less than 1 ppm. Registrant Thompsbn-Hayward Chemical states that their product contains less than 0.1 ppm J02/ TCDD. ~ Dow Chemical Co. has repeatedly stated that technical J03/ 2,4,5-T produced since 1970 in their plant contains less than 0.1 ppm. " C.H. Boehringer Sohn, Ingleheirn, Germany, states that since 1970, the TCDD content.of their technical 2,4,5-T has been held at less than 0,1 ppm. Recent, analyses by EPA of technical products from the three U.S. TiBriufactur-Ts are shown in Table III. The representativeness of these "levels arid the tetyv-r'ioxin levels in formulated products remains to be dei;ionstri> vod by Registrants. JOT/ LeUcrfrom Dr. /"..G. Sidv/ell, Transvaal, Inc, 3/30/73. 10JY LoLt.c-r from Kr. Edwin Upton, Thompson Hayward Chemical Co., 3/29/73 1H3/ TOsV Pr, .;r.r,al Coimv.iiiication, OPP, EPA Lei;,or from fir. Donald Yoder, BASE Hyandotte Corp, May 14, 1973 44 �- RECENT ANALYSES* OF TECHNICAL 2,4,5-T PRODUCTS MANUFACTURED IN THE UNITED STATES TABLE. EPA Reg. No. Company Date of Collection and Lot Size I.D. # TCDD Level (PPM) 4W-205 Dow '"•"" DOW Dew Description " T- -. ; Dow 2, 4, 5-T Propylene glycol butyl ether ester 69.2% 7/13/73 Lot #675233 1 gal. can 102526 ^ .1 405-205 Dow 2, 4, 5-T Propylene glycol butyl ether ester 69.2% 7/13/73 Lot #675293 1 gal. can 102527 ^ .1 4H--205 Dow 2, 4, 5-T Propylene glycol butyl ether ester 69.2% 7/13/73 Lot #675423 55 gal . drum 102530 ^ .1 I \ , Transvaal 'l '587-30 2,4, 5-T Acid, 100% 7/13/73 Bin #90 (3500#) 104593 , <.! Transvaal 11687-30 2 ,4, 5-T Acid, 100% 9/21/73 Bin #121 (3500#) 104593 ^.1 : Transvaal 11687-30 2, 4, 5-T Acid, 100% 9/21/73 Bin #100-16 (3500#) 104593i.: < .1 } Transvaal 11687-30 2, 4, 5-T Acid, 100% 9/21/73 Bin #70 (3500#) 104593 ^.1 : Transvaal. •1687-30 2,4,5-T Acid, 100% 9/21/73 Bin #100-10 (3500#) 104593 <.l Transvaal 11687-30 2, 4, 5-T Acid, 100% 9/21/73 Bin #119 (3500#) 104593 <l • Thompson Hayward 143-924 2,4,5-T Isooctyl Ester 7/12/73 102206 ^..1 \ Tech, 97% From 10,000 gal. bulk tank *Analyses conducted at EPA/OPP/7SD Laboratory, Beltsville, Maryland, �C. THE REGISTRANTS HAVE NOT ESTABLISHED fTME NEED FOR 2,4,5-T in LIGHT OF THE ABQVE_ - [•iEHTIONED RISKS.j THE NECESSITY FOR THE CONTINUATION OFJ THE REGISTERED USES OF2 7 4 ^ 1 7 " " i ~ 1. What are the pests which each registered use is intended to control and the degree of contjro! achieved by each use? 2. What is the cost, timing and rate! of application of 2,4,5-T for each use? 3. What alternative controls exist for each registered use and what is the cost and effectiveness of each alternative? The registered uses of 2,4,5-T are intended to control a 105/ i multitude of weed and plant pests. Over 1.8 million acres of rice are harvested annually in tjhe United States. j 100,000 of these acres are treated with 2,4,5-T, virtually all within the States of Arkansas and Mississippi. In Arkansas, 10 percent of the crop (44,000 acres) is treated with 2,4,5-T, while in Mississippi, 85 percent (44,000 of 51,000 acres) receives treatment. For rice weeds the herbicide is applied in one foliar application of .75 to 1.25 Ib/acre at a cost of a pproxirna t e 1 y $4 to $5 acre, for the control of arrowhead, coffeebean, curly indigo, gooseweecl, ducksalad, Mexican weed, redstem, smartweed, spikerush and umbrellaplant. However, the major agricultural use of 2,4,5-T is for the control of brush on rangeland. There is some use for brush control on pastures but it is much less extensive. Texas, Oklahoma and New Mexico are the primary users of 2,4,5-T for rangeland control. Within these 3 states See Table IV for General Estimates of the Rate, Timing and Costs of Application of 2,4,5-T 45 �approximately 1.4 of 177 million acres of rangoland receives 2,4,5-T treatr;)2nt each year. Because treatment lasts for several years, about 8.4 million acres of range are currently benefiting in varying degrees i roni chemical brush control. 2,4,5-T is used on pastures and rangland to control woody species; blackjack oak, inesquite, post oak, sand shinnery oak and yucca. One foliar application of 1/2 to 2 Ibs/acre, depending on the rate of regrowth is made every 5-6 years at a cost of approximately 4-6 dollars per acre. In heavily infested areas a second application may be necessary the following year. The application is made during the period of rapid growth or while leaves are expanding. The USDA has estimated that 430,000 acres of forest land are treated annually with 2,4,5~T, exclusive of its use by the United States Forest Service. It is used for site preparation, conifer release, and pine release., to control alder, bigleaf maple, blackjack oak> California black oak, Ceanothus, chinquapin, gum, .Oregon white oak, sumac,, vine maple, white oak, e.nd wild cherry and other species. Application rates for eo.ch !i:ajor forestry use are: SJjte_J;r,:p-3i\;?ti_oi; - One foliar1 application at a rate of 2-4 Ibs acre after leaves of-undesirable hardwocds have fully expanded, but before planting of seedlings. s" Convfj::i^ rc.'l_0r!s_e - one- foliar application 2-4 years after seedlings have ix'ui planted (depending on rate of regrowth of undesirable hardwoods). • Application should be macb prior to buclbreak of the conifers to prevent injury at a rate of 2-4 Ibs. acre. 46 �JNelease - one foliar application 2-4 years after seedlings have been planted (depending on rate of regrowth of undesirable hardwoods) after spring growth of pines has hardened, at a rate of 2-4 Ibs acre. Specific data on the remaining registered uses (Rights of ways, Roadv/ays, Fencerows and wasteland) is unavailable, although an estimated 2.2 million acres of rights of way is treated annually. It is used to control ailanthus, alder, ash brambles, basswood, ceanothus, chinquapin, elm, ground cherry, gum, hickory, horsenettle, maple rnesquite, poison ivy, locust, oak, persimmon, sassafras, shinnery oak, sumac, Virginia creeper, wild cherry, and other species. 2,4,5-T for these uses is applied as follows. (a) one foliar application every 5-6 years (depending on rate of regrowth) to brush 6-8 ft tall during the period of most active growth, at a rate of 2-12 Ibs acre depending on species to be controlled and density of population (b) one basal bark treatment anytime of the year gives satisfactory control to susceptible species less than 6 inches in diameter at. breast height, at a rate of 12-16 Ibs acre/100 gals of solution, (c) frilling can be employed during anytime of the year on any size tree at a rate of 8-16 Ibs. acre/100 gals solution. (d) injections can be made during anytime of the year on any size tree at a rate of 4 Ibs acre 10-20 gals of solution with satisfactory results. (e) stump treatment are utilized on freshly cut trees more than 2 inches in diameter at the base, at a rate of 12-16 Ibs acre/100 gals of solution. There are available generally effective alternatives for the great majority of these 2,4,6-T uses. 2,4,5-TP, "silvex", appears to be the most broadly effective substitute for all registered uses. Table IV coni.ains a list of registered alternatives to 2,4,5-T. 47 �Silvex, MCPA, and 2,4-D all provide varying degrees of control for the rice weeds that are controlled by 2,4,5-T. The following chart lists these weeds and the herbicide(s) providing the best control:-^-' Arrowhead Dayflower Smartweed Coffeebean Curly indigo Ducksalad Gooseweed Mexicanweed Redstem Spikerush Umbrellaplant - all provide a similar degree of control " " 2,4,5-T; Silvex; 2,4-D 2,4,5-T; Silvex 2,4-D 2,4,5-T; Silvex 2,4,5-T; Silvex Silvex; 2,4-D Silvex; 2,4-D 2,4-D For every weed listed, that is controlled by 2,4,5-T, there is at least one alternative that is either equal to or superior to the control achieved with 2,4,5-T. In most cases there are 2 or more. The major concern over the use of these alternative herbicides is the phytotoxic hazard to nearby susceptible crops as a result of drift, and volatility. All four phenoxy herbicides .{including 2,4,5-T) will adversely \ effect highly susceptible crops, such as cotton and soybeans, if allowed to driit onto them during application. However, they do differ as to the degree of injury. Injury to cotton caused by these four herbicides, in order of greatest to least injury, is 2,4-D; HCPA; Silvex; and 2,4,5-T. For-soybeans the order is Silvex; 2,455~T; 2,4-D; and MCPA. It would appear that the most satisfactory alternative to 2,4,5~T (regarding drift hazard) would be Silvcx when applied adjacent to cotton. In areas whore soybeans are grown both 2,4-D and 1-iCPA would produce even less damage than 2,4,5-T. IJW USDA Handbook 289 and 292, and State Herbicide Recommendations. 48 �An important point in considering drift is that most injury problems 2 the direct result of misapplication, and if care is not taken in applying Jiese herbicides, as indicated on the registered labels, even 2,4,5-T is a hazard to nearby susceptible crops. Concerning volatility, all 3 of the alternative herbicides can be formulated as the salt. Since the hazard from the use of a salt formulation is negligible, their application near susceptible crops poses no greater volatility problem than that of 2,4,5-T. c • 4 • Dp_A Iter nat i v e_Pe stjknd e_ ftodhjcts__ Cd ujse_ Adverse En'vi ronmeptal" Effects? With the possible exception of one herbicide and on the basis of available information, Respondent believes the registered alternatives are environmentally acceptable. 2,4,5-TP (Silvex), apparently the most broadly subst'itutable herbicide for 2,4,5-T uses, is suspected of containing tetradioxin. It is anticipated that this question will be resolved, particularly by reliable facts from Si 1 vox registrants, before the close of this proceeding. Should 2,4,5-TP prove to be free of dioxins arid of other inordinately toxic, persistent contaminants, it too, would be considered environmentally acceptable. C. 5 l\h;;.t _A re__t!ie Er.onomi c J.i-,r • 1 i c? Li ons o-r_ T]ies_e /\IterriaJ._n/es \Jncl_ud_Uij! tji^t^Oj7 j\'p Con__trp_1_? Should si 1 vex prove to be a safe alternative, the economic impact of cancelling all registered 2,4,5-T uses v/ould not be significant. Respondent is in the process of developing specific cost-effectiveness information on the remaining substitutes and on the economic impact, if any, of cancelling the remaining registrations of 2,4,5-T. 49 �Table IV Reg i s to r;ed _A1 1 c r native 1terb 1 c i d e s f or ?. , 4 , 5—T Rice - 2,4,5; 2,4,5-TP, (Silvex); MCPA: Propanil; Molinate. Pasture and R,amiejand foliar -2,4, D; 2,4,-D + 2,4, 5-T; 2,4-D + Dicamba; .2, 4-TP, (Silvex); MCPA; Ammonium sulfamate. basal bark - 2,4-D + 2,4, 5~T; 2,4-D -I- 2,4-DP; 2,4-D + Dicamba; Dicamba; Bromacil. Frill - 2,4-D; 2,4»D + 2,4, 5-T; 2,4-D + 2,4-DP; 2,4-D + Picloram; Ammonium sulfamate; Dicamba. stump - 2,4-D; 2,4-D + 2,4,5-Tj 2,4-D -:- 2,4-DP; 2,4-D + 2,4,5-TP; 2,4,5-TP; Ammonium sulfamate. Ri girts -of; Way " _ . ._ R o a a wv "s_"s F e'n c e rb\\fs , ay Waste iaridn[?oTi ar) "- 2,4-D; 2 , 4 - D •!- 2 5 4 5 5 - T ; 2 , 4 - D + P i c l o r a m ; 2 , 4 - D Dicamba; 2,4-D -i- 2,4-DP; 2,4,5-TP; K a r b u t i l a t e ; A m i t r o l e ; Ammonium s u l f a m a t e ; Maleic hydrazide (growth retardant); 'Cacodylic acid; MSMA. R i q i rl:s_- of;- Vis y Read's/ays, Foiicojc'./s,- See herbicides listed in Pasture and Rnngeland. r_r i l l , "LnJcc: io u arid i^jilPF . ifer_ - 2 , 4 - D ; 2 , 4 - D + 2, 4, 5-T; 2 , 4 , 5 - T P . c:n_(i j pine re i t ' c s e �SUMMARY OF RESPONDENT'S POSITION The use of 2,4,5-T on rice, in accordance with label directions and widely recognized and accepted practice, causes unreasonable adverse effects on the environment and must be cancelled. The rice use constitutes a direct application (the only remaining one) of 2,4,5-T and 2,4,5-T related tetra-dioxin to human food. 'By its potential contamination of rice and its associated contamination of water and aquatic species, also a part of the human food supply, this use creates a direct route for the ingestiori by man of tetra-dioxin, a teratogenic and inmcomparably poisonous compound. Testing on tetra-dioxin demonstrates the extreme potency of minute quantities, a fact which cannot be obfuscated by specious comparisons between the "small" amounts of this toxicant available for environmental contamination and greater amounts of other infinitely less toxic and non-teratogenic contaminants. Besides the gross qualitative and quantitative difference's in toxicity, tetra-dioxin has demonstrated persistency and a propensity for bionic.cirri f ication. It has not been demonstrated Ihzrt the rir,!'. to man from this compound is insignificant. Any such assertion is speculative, founded not on reliable research, but on the mere hope that man is less not. more sensitive than the mammalian species tested in the "laboratory. 50 �In theory, perhaps, Registrants, in fulfilling their burden of ultimate persuasion, cannot "prove a negative", that the use of 2,4,5-T presents absolutely no risk. In fact existing information compels the conclusion that a direct food use of 2,4,5-T presents a clear hazard to public health. Nothing derived from'scientific research, field experimentation or experienced observation of widespread human exposure to 2,4,5-T demonstrates, to the contrary, that this risk is of insignificant proportions. Respondent's best scientific judgment, compatible with the conclusion in 1970 of the Surgeon General and the Secretary of Health, Educations and Welfare, is that while the magnitude of this hazard cannot be quantified, it constitutes a direct risk to man. It is untenable that society should unknowingly and involuntarily be subjected to this hazard in light of an absence of substantial benefit from the use of 2,4.,5-T on rice and the availability Of substitutes for this use. Such risk is, indeed, socially unacceptable. For the moment, Respondent reserves its judgment on the remaining registered uses of 2,4,5-T, Whether the health hazard raised by the food uses of 2,4,5-T is also presented by the other uses, depends principally upon the risk of human exposure to tetra-dioxin from these uses. In this regard a so-called "non-food" use, on rangel'and and pastures raises serious questions of safety because of its rather obvious link to human ingestion of tetra- dioxin. Respondent believes, the relationship must be established somewhat more firmly. 51 �In addition, while data do not clearly demonstrate its mobility, the patterns of 2,4,5-T application (all uses), TCDD's apparent persistence in soil and its vapor pressure (similar tc that of DDT) all suggest that tetra-dioxin, like DDT, can be expected to penetrate readily in the environment, ferreting out human food sources unrelated to and beyond the areas of 2,4,5-T use. Whether widespread environmental distribution is occurring from these "non-food" uses and the ecological and human health impact of such broadcasting of tetra-dioxin are not yet obvious. Clearly the potential for risk exists. Respondent anticipates that it will develop more information on I these remaining substantial questions of safety. Further, those who wo il Id favor the continued distribution of this extraordinary toxicant mujst illuminate their optimistic conclusions of safety with convincing i evidence. Respondent would prefer that a decision, herein, rest on thorough scientific information, reasoned inference and reliable prediction, rather than on the sheer force of lav/. But the hazard to public safety is clearly raised. The Congress has seen fit to protect the public health in such cases by coin pel ling cancellation of these pesticides,, unless Registrants can convincingly demonstrate the acceptability of the public risk. There is no overv.'helrning social benefit from 2,4,5-T. Registrants can, therefore, meet their burden only by reliable negative long-term toxicity testing on tetra-dioxin., �by thorough environmental monitoring for TCDD' and by adequate human i survey of the chronic effects of exposure. Con_cjjjs_i_pji Respondent's evidence will prove that the risk to public health from the use of 2S4,5-T on rice is unequivocally greater than any social value derived from such use. -Th-is pesticide use causes unreasonable adverse effects on the environment and should be cancelled. Respectfully submitteds Timothy L. Hafker Office of the General Counsel Counsel for Respondent Office of Hazardous Materials Control Environmental Protection Agency 53 �ENVIRONMENTAL PROTECTION AGENCY BEFORE THE CHIEF ADMINISTRATIVE LAW JUDGE ) IN RE THE DOW CHEMICAL COMPANY, et al., )I.F. & R. Consolidated ("2,4,5-T") ) Docket No. 295 Registrants ) RESPONDENT'S INITIAL SUBMISSION OF PROPOSED EXHIBITS- 2,4,5-T 1. Environmental Health Perspectives; Experimental Issue No. 5, Department of Health, Education and Welfare; U. S. Public Health Service; National Institute of Health; September, 1973, - A l l reports of research therein. 2. Buu-Hoi, et. al., Comptes Rendus Acad. Sci., Paris, 273, Series D, 708 (1971). 3. Johnson, J., "The Public' Health I m p l i c a t i o n of the Use *• of Phenoxy H e r b i c i d e s and Picloram"; B i o s c i e n c e , 2J_ (17), 899 (1971). 4. Watts, R. R. and R. Storherr, " N e g a t i v e F i n d i n g of 2,3,7,8 - T e t r a c h l o r o d i b e n z o - p - d i o x i n in Cooked Fat . C o n t a i n i n g Actual and Fortified R e s i d u e s of Ronnel and/ or 2,4,5-Trichlorophenol ," JAOAC, 56 (4) 1026 (1973). 5. Chow* et. al., Methodology and Analysis for Residues of MCP and 2,4,5-T in Wheat. 576 (1971). B u l l , E n v . Cont. Tox., 6. �6. Bauer, J., Bovey» R. arid J. Smith, Herbicide Concentrations in Live Oak Treated with Mixtures of Picloram and 2,4,5-T, Weed Sci, 1?, 567 (1969). 7. Alexander, M. and M. Aleem, Effect of Chemical Structure on Microbial Decomposition of Aromatic Herbicides, Food Chem., g, 45 (1961). 8. Schultz, 0. P., Dynamics of a Salt of (2,4-Dichlorophenoxy) Acetic Acid in Fish Water, and Hydrosol, J. Agr. Food Chem., 9. 21 (2) 186 (1973). . . • t Bovey, R. and J. Bauer., Persistence of 2,4,5-T in Grasslands of Texas, B u l l . Env. Cont. Tox., £ (4) 229 (1972). 10. Manigold, D. B. and J. Schulze, Pesticides in Water. Pest. Mon. J., 3 (2) 23 (1969). 11. Firestone, D., et. a!., Determination of Polychlorodibenzo/ p-dioxins and Related Compounds in Commercial Chlorophenols JAOAC, 55. (1) 85 (1972) . 12. Poland, A. and E. Glover, 2,3,7,8 - Tetrachlorodibenzo-p• dioxin: A Potent Inducer of A m i n o l e v u l i n e r Acid Synthetase. Science 111,476 (1972). 13. Huston, B., Identification of Three Neutral Contaminants in Production Grade 2,4-D., J. Food Chem., 3_0 (3) 724 (1972) 14. N i l s s o n , C. and L. Renberg, "Further Studies on Impurities in Chlorophenol", u n p u b l i s h e d manuscript. - 2 - �15. Plimmer, J. et. a l . » Photodecompositon of Chlorinated Dibenzo-p-Dioxins, Science 173, Science 173 748 (1971) 16. Emerson, G. L., jet aJK , Teratogenic Studies on Trichlorophenoxyacetic Acid 'in the Rat and Rabbit, Fd, Cosmet, Toxlcol., 1:395-404, 1971. 17. Courtney, K. D., and Moore, J. A. - Teratology Studies with 2,4,5-Trichlorophenoxyacetic Acid and 2,3,7,8 - Tetrachlorophenoxyacetic Acid and 2,3,7,8 - Tetrachlorodibenzo-p-dioxin, Toxicol. Appl. Pharmacol., 20:396-403, 1971. 18. Roll, R., Investigations Concerning tfoe Teratogenic Effect of 2,4,5-T in Mice, Fd. Cosmet. ToxicoT., 9.:671-679, 1971 19. Neubert, D., and Dillman, I., Embryotoxic Effects in Mice Treated with 2,4,5-T and TC.DD, Naunym-Schmiedeberg' s Arch. Pharmacol., 272:243-264, 1972. 20. Thomas, J. A., and Lloyd, J. W. Organochl oride Pesticides and Sex Accessory Organs of Reproduction," Pes t i cides an d the / jE.nyironment, Intercontinental Medical Book Corp., N.Y. pp. 43-51, 1973. 21. F l i c k , et a!.., Toxicity of Chick Ederma Factors in the C h i c k , « Chick Embryo and Monkey, Poultry Sci., .52:1637-1641, 1973. 22. A l l e n and Carstens, L i g h t and Electron Microscopic Observations in Macaca Mulatta Monkeys Fed Toxic Fat, Amer. J. Vet. Res., 28:1513-1526, 1967. - 3 - �23. Buu-Hoi, N. P., j^t a_K, Cancerominetic Properties of TCDD, ("Dioxin"), C. R. Acad. Sci (Paris) D273 (3):708-711, 1971. 24. Buu-Hoi, N. P., e_t -aj_., Organs as Targets of Dioxin Intoxication. 25. Naturwiss. ^9 (4): 174-175, 1972. Jackson, W. T., Cytological Effects of 2,4,5-T and of Dioxin Contaminants in 2,4,5-T Formulations, J. Cell Sci. 10:15-25, 1972. 26. Hussain, S., et aj_., Mutagenic Effects of TCDD on Bacterial Systems, Ambio., l(l):32-33, 1972. 27. Sparschu, ejt aj_., Study of the teratogenici ty of TCDD in the Rat. 28. Food Cosmet. Toxicol. 9:405-412 (1971). Goldstein, J. A.m et aV. , Hepatic Porphyria Induced by TCDD in the Mouse. Res. Comm. Path. Pharm. 6_(3) 919 (1973). - 4 - �E N V I R O N M E N T A L PROTECTION AGENCY B E F O R E THE C H I E F A D M I N I S T R A T I V E LAW JUDGE IN RE THE DOW CHEMICAL COMPANY, et a l . f ) I.F. & R. Consolidated ("2,4,5-T") ) Docket No. 295 Registrants ) OPPOSITION TO FIELD H E A R I N G Respondent opposes the convening of field hearings in this proceeding, for the following reasons: 1. The issues for adjudication can be- resolved only by adducing scientific and technical evidence generally beyond the purview of "lay"witnesses. Consequently, convening field hearings, traditionally scheduled in order to permit the convenient testimony of such persons, would not serve a v a l u a b l e purpose. 2. In those r e l a t i v e l y few instances where non- expert testimony may be r e l e v a n t , convenience is better served by requiring such i n d i v i d u a l s to appear in W a s h i n g t o n , D. C., than by r e q u i r i n g a l l parties to travel to a "field location". Respectfully submitted, _ Tinfbthy L. 'ttarker Counsel for Respondent �UNITED STATES OF AMERICA ENVIRONMENTAL PROTECTION AGENCY BEFORE THE ADMINISTRATOR IN RE: 2,4,5,-T ) ) ) FIFRA CONSOLIDATED DOCKET NO. 295 * RESPONDENT'S SECOND PRETRIAL BRIEF Timothy L. Marker Attorney for Respondent Office of the General Counsel 401 M Street, S. W. Washington, D. C. (202) 755-0796 �Point I The Scientific Data to Which Dow Chemical Company Subscribes in its First Prehearing Memorandum, If Accurate, Does Not Sustain Registrant's Burden of Ultimate Persuasion. Registrant, Dow Chemical Company, in its First Prehearing Memorandum has failed to reckon adequately with numerous important issues in this proceeding. Confronting its burden of proof on substantial questions of public health and safety, Registrant would seek to persuade with demonstrably incomplete scientific information and unreasonable inference. Particularly as to the hazards birth defects, chronic illness and delayed lethality from long-term exposure to minute quantities of tetradioxin (TCDD), associated with the use of 2,4,5-T, Registrant has engaged merely in a recitation of insufficient data and conclusory optimism. Despite the fact that more than 2 1/2 years has elapsed since the 2,4,5-T Advisory Committee expressed concern over the deficiency of information on the environmental presence and risks to health from tetra-dioxin, Registrant has neglected to undertake reliable life-time toxicity testing on, thorough environmental monitoring for and adequate, statistically reliable human survey of the effects of chronic exposure to TCDD. Such a failing legal stance must not be lent undue credence trom the construction of a false issue by Dow Chemical Company and the U. S. Department of Agriculture (USDA) — the assertion that in meeting their •* ' ; burden of proof the proponents of registration are asked to but cannot �"prove a negative"; i.e. that there is no risk from the use of 2,4,5-T. */ As Respondent stated in its First Pretrial Brief, nothing derived from scientific and field research with 2,4,5-T or from reliable observation of widespread human exposure to 2,4,5-T demonstrates that the threat to public health from 2,'",5-T, TCDD contamination of the food supply is anything less than significant. Reliable, thorough research which demonstrates such risks to be deminimis is legally necessary in order to permit a reasoned inference to the contrary. This the proponents of 2,4,5-T have failed to undertake or to adduce. A. Dow Chemical has not presented statistically significant, reasonably reliable survey of human exposure to 2,4,5-T, TCDD which would tend to * support its conclusion that 2,4,5-T, TCDD do not adversely affect fetal **/ / . —: f •> development and the well-being of human offspring. * / I n d e e d , the statutory obligation of Registrants is to demonstrate by clear and convincing evidence that continued use of 2,4,5-T does not constitute an unacceptable risk of adverse environmental affects. Respondent's Brief, page 8, Note 8. .This is logically as well as legally inconsistent with the rhetorical straw man of Dow Chemical and USDA — that Respondent would have them "prove a negative". **/ Dow does discuss a survey of 126 employees, exposed allegedly to Inhalation of 2,4,5-T, TCDD for 60 to 960 days. (Dow Brief, p. 100). Not only is the route of ingestion inapposite to the health concern over the use of 2,4,5-T -- oral ingestion through the food supply — but the sample size is far too small, the amount and length of exposure unclear to permit statistically reliable conclusions. Of course the study did not even attempt to answer the questions of teratology in women and chronic illness from life-time exposure.• However, Respondent would be interested in investigating the records, of this'health survey and, perhaps, of utilizing some of these employees to determine the extent of TCDD residue in their fat. Perhaps Dow Chemical would be willing to cooperate in such an effort. - 2- �B. Dow Chemical would opine that human offspring are not jeopardized despite the demonstrated teratogenicity of 2,4,5-T, TCDD in laboratory animals, at very low levels, and the potential greater sensitivity of man to teratogenic effects than of tested laboratory species, and in the face of the demonstrated exceptional toxic potency and biological activity of tetra-dioxin. As Respondent verified in its First Pretrial Brief (p. 15), little is known about the nature of teratogenic effects and even less is understood about the nature and source of TCDD's toxic influence. Registrants and USDA have deposited no additional information in these lacunae in medical knowledge. Reasonable prudence focused on what is not known, in the light of what is known about the destructive influence of tetra-dioxin on normal birth, compels the conclusion that 2,4,5-T containing TCDD must not be permitted to contaminate the human food supply. ' «»• f c. Dow Chemical, in addition, concludes that the general public faces no danger of chronic ill-health from tetra-dioxin. Yet, the Registrants and USDA have produced no monitoring data which would demonstrate that TCDD is not contaminating the American food supply or the American public. The Registrants and USDA have ignored or overlooked the disturbing presence of tetra-dioxin in the Vietnamese food supply and have failed, even, to discuss in reasoned and specific fashion the significance for man of *J known or potential TCDD residue in certain foods. V See pp. 35-36 and Table I of Respondent's First Pretrial Brief. - 3- �It is known that 2,4,5-T related TCDD is environmentally persistent and bioaccumulative, that it has entered food supplies in as well as away from areas of 2,4,5-T uses, that it is extremely poisonous in minute quantities and that its toxic consequences can be incremental and delayed as well as acute. In light of what is known, what is not known and what Registrants have neglected to investigate leaves no rational cause for optimism over the use of 2,4,5-T on or near human food. Point II That Scientific Information to Which Registrant Subscribes to Sustain its Burden of Proof is at Times Inadequately Discussed Or Combined With Casual Assumptions in Order to Support Otherwise Unfounded Conclusions. In addition to the major omissions discussed, supra, the detailed shortcomings in Dow Chemical's scientific analysis, discussed in part, **.,-> infra, demonstrate that the evidence as developed in Registrant's First Prehearing Memorandum, assuming it to be competent, is wholly inadequate to persuade by clear and convincing evidence that the use of 2,4,5-T on or related to food does not cause unreasonable adverse effects on man. A. Teratology Without discussion of the etiology of birth defects or of the relationship between birth defects in laboratory animals and in man, Registrant concludes that TCDD is not a potent teratogen, although concession is made that "TCDD has embryotoxic tendencies." pp. 31, 52, emphasis added.) - 4- (Dow Brief, �Oow's observation apparently rests on two grounds. The first is the contention that TCDD does not cause deformities over a wide range of dose levels. Although it does clearly induce birth defects at extremely low dosages, over the broad range of doses tested, Dow argues, TCDD "tends to cause death of the embryo or fetus." (Dow Brief, pp. 5 and 31.) The second ground consists of Dow's argument that TCDD does not produce birth defects as serious as those induced by some other teratogens. (Dow Brief, p. 5.) Assuming airguendo that its conclusion is technically proper, Registrant misses the practical point for man. Death of the human embryo or fetus must be considered the ultimate malformation. TCDD is, indeed, a very potent toxin. Respondent is, therefore, concerned with the total adverse fetal or embryonic effect of this persistent poison. This concern is well founded, as TCDD, clearly a teratogen at'minute levels, also exerts in"" extremely small doses (albeit, perhaps, across a broader range of doses) general toxic effects (including death) on the fetus which can occur during the entire development in utero and which can as well retard postnatal development. The total toxic effect on embryonic and fetal development and postnatal growth can be exacerbated by the potential for the excretion I/ of low levels of TCDD in mother's milk. Thus the toxic effect of tetra-dioxin on the development, survival and growth of mammalian offspring is not necessarily limited to a specific period of gestation. V R e s p o n d e n t ' s First PretriaT Brief, p. 19. - 5- �Registrant's argument as to the dose range of TCDD's teratogenic effects is, therefore, as incomplete as it is unnecessary quibbling. Of the second ground for Dow's conclusion, its argument that TCDD is not a potent teratogen because to date it has primarily caused cleft palate in the species tested, Registrant has again introduced an inadequate analysis. It has failed to suggest why the teratogenic expression of TCDD in man is necessarily similar to its expression in some lab species (cleft palate). Certainly there is no reason to assume a parallel manifestation of defects. Rather, absent more reliable information on human exposure one can as well assume varying expressions, more or less serious in man. But of far more importance to demonstrating the failings of Dow's analysis is its conclusion that cleft palate is not a major deformity. One may conclude that cleft palate is far less serious to a given individual than deformed or missing limbs. However, a proper judgment as to the "' '" relative pub1ic importance of cleft palate and other birth defects would require an assessment of the comparative frequency with which they occur. Dow Chemical has not proffered such analysis. As a matter of public regulatory policy, Dow's medical distinction between major and minor teratogens is irrelevant. 2,4,5-T related TCDD in food presents a serious risk of birth defects and other toxic effects in the human embryo and fetus. That the most common and obvious consequence of that risk may be cleft palate rather than some other, more horrible defect should be a matter of no legal significance whatsoever. - 6- �Registrant also finds "that 2,4,5-T as now manufactured (<0.1 ppm TCDD) does not present a teratogenic hazard to women when used in accordance with presently registered uses." (Dow Brief, p. 53.) Certain shortcomings, additional to those discussed, supra, render the statement conclusory. Dow has not demonstrated that reasonably reliable "no effect" levels have been ascertained even in the species tested, which take into account a proportionality between the number of animals tested and the resultant embryotoxic effect, and which utilized sufficiently large samples. In addition, Registrant's discussion of the gamut of 2,4,5-T toxicity testing (including but not limited to teratology) consistently and improperly resorts to extrapolating a "no-effect" level for TCDD based on laboratory testing with 2,4,5-T in which the TCDD content was known. (For one example, see p. 8.) Dow Chemical takes for granted that sample sizes and the distribution of toxic responses were sufficient even to permit reasonably safe extrapolation to man. (Dow Brief, %pp. 8 and 28.) Such assumption must be clearly proven as a prerequisite to Dow's further assumption that a laboratory "no-effect" level is a reliable predictor of a safe level for man. Furthermore, the use of 2,4,5-T testing as a source of toxicological predictions for TCDD simplistically fails to account for potential effects of the 2,4,5-T itself on the storage of TCDD, and on the quality and degree of TCDD association with the embryo and fetus (or body organs), and on the excretion of TCDD. The extrapolation also fails to give a "real world" - 7- �picture because it fails to account for the bioaccumulative impact of TCDD in the environment. Such conclusions are unreliable. Registrant also obfuscates the importance for regulatory policy of the thalidomide experience. Dow Chemical concludes that had the ratios between the teratogenic dose and the maternal toxic dose of thalidomide been considered, and "all of the available data utilized", the dose level at which thalidomide caused teratogenic effects in humans could have been predicted. (Dow Brief, p. 30.) The argument of "prediction aside" (especially in view of the fact that Dow fails to mention in what manner "all of the available" thalidomide data should have been "utilized"), Registrant's conclusion as stated in no way indicates that man is not potentially more sensitive than laboratory species to embryotoxic (including teratogenic) effects, as the thalidomide case indicates. Dow Chemical also apparently seeks to exonerate 2,4,5-T of'teratogenic implications by spurious analogy to certain environmental circumstances'/ such as fasting and stress, which may, arguably, produce adverse effects on embryonic or fetal development. (Dow Brief, p. 48.) The fact is that of the 50 pesticide chemicals evaluated in the original Bionetics II Laboratory research, only a few induced teratogenic effects. course, this does not mean that others are not also teratogenic.) V R"e"p'ort"bf~the Secretary's Coniniission on Pesticides and their Relationships To Environmental Health, U. S. Department of Health, Education and Welfare. December, 1969. pp. 665-669. - 8- �B. Chronic Toxicity and Delayed Lethality With no lifetime feeding studies in mammalian species from which to derive reasonably safe negative toxicological conclusions and with no reliable environmental or human residue monitoring information on TCDD, ' Dow Chemical opines: Exposure to 2,4,5-T as presently used, and to TCD!) resulting from its presence in 2,4,5-T at <'0.1 ppm as now produced, causes no chronic sublethal health effects in man or other animals. (Dow Brief, p. 100.) Present uses of 2,4,5-T as currently manufactured will not cause delayed lethality in man or other animals because exposure to both 2,4,5-T or TCDD\ is many times less than that which could cause such an effect. (Dow Brief, p. 114.) No thorough research effort even suggests that tetra-dioxin will not readily accumulate and be stored in the liver and adipose tissue or other human organs after long-term, low-level exposure through the food supply,, Nor is there adequate toxicology testing from which to conclude with even reasonable safety that serious health effects are not caused by chronic exposure to minute quantities of TCDD. It is known that TCDD can bioaccumulate and can be stored in animal organs and tissue. It is known that TCDD is extremely toxic, both acutely and incrementally. Current data suggests that it may well exert delayed lethal effects. Chronic exposure of the general population to TCDD at any level cannot be permitted. - 9- �C. Persistence and Bioconcentration Registrant contends that a "steady-state" level of TCDD will be attained in man in approximately 90 days. (Dow Brief, p. 178), Dow Chemical then concludes that TCDD does not accumulate in body tissue. (Dow Brief, summary at p. 32'and p. 161.) The manner in which those 161-165, 177-178 conclusions are derived from the analysis (Dow Brief, p./ ) is totally unclear. The statements appear conclusory and unfounded. Accepting arguendo the 90 day "steady state" conclusion would of course indicate clear bioaccumulation from exposure, thus refuting Dow's ultimate conclusion as to no accumulation of TCDD. Existing data strongly suggest the presence of TCDD in the food supply t (Respondent's First Pretrial Brief, pp. 35-36) and therefore the potential for such accumulation. But Dow's steady-state analysis is a mere projection without even minimally supporting analysis or theoretical reasons as to why such a • f " projection is reliable. The one research effort cited (without clear analysis by Dow) to support the conclusory statement (Dow Brief, p. 177), utilized a single, near lethal do.se of TCDD. Such extrapolation to the repetitive dose, low-level exposure of the real world is arguably sufficient for limited purposes with an ordinary compound, but is to risky with TCDD because of its exceptional potency and potential for delayed lethality. The.conclusion of a.90 day steady-state should be based on, at least, chronic feeding studies over a considerable portion of the lifetime of the tested species. The cited research takes no account of and Dow fails even to discuss the demonstrated toxic influence of TCDD on the - 10 - �liver and kidneys which could diminish over the span of long term exposure man's capacity to excrete or to detoxify TCDD — a vital assumption in Dow's convenient "steady-state" speculation. Similarly, the newborn and the ill, may have less efficient kidneys than those by which > Dow predicts a steady state. Nor does Dow discuss the potential significant variation in the detoxification and excretion of TCDD when administered in high single doses versus when administered in continuous, small doses. Also lacking is discussion of the toxicological importance of very small amounts of TCDD which bind to the liver to remain beyond the "steady-state" projection, i.e., why is the accumulation of TCDD as projected by Dow, assuming it ceases at 90 days, not of great significance to man's health? Similarly, the cited study clearly indicates that TCDD has a half-life in the male rat of 17 days. This fact, in itself contradicts Dow's contention and suggest that TCDD can accumulate in mammalian species •**:r-> because it is not readily excreted. Also Dow Chemical overlooks the serious potential for harm caused by the continuous assault of low levels of TCDD, even if, as Registrant assumes, bioaccumulation does not occur. Existing information suggests that tetra-dioxin is cumulative and/or delayed in its toxic influence. (Respondent's First Pretrial Brief, p. 23. Dow Brief, p. 114.) There is no long-term, reliable research to the contrary. Finally, several additional facts undermine various bases of Dow's "steady-state", "no-accumulation" conclusion: - 11 - �1. Existing residue data (Respondent's Brief, pp. 35-36) indicate the contamination of food by TCDD. Dow in its analysis expressed the erroneous view that TCDD was not in food. (Dow Brief, p.161). *J 2. TCDD is apparently not metabolized by mammalian systems, contrary to Registrant's opinion. (Dow Brief, p. 35.) 3. The authors of the research paper cited by Dow to buttress its "steady state" contention emphasize that the TCDD recovered within 48 hours of administration is probably"unabsorbed TCDD, contrary to Dow's opinion that absorbed TCDD is eliminated via the feces. (Dow Brief, p. 35.) 4. The clearance rate of TCDD from body fat would be expected to be considerably different than from the liver, contrary to Dow's opinion that clearance of TCDD would be the same for all tissues. (Dow Brief, pp. 124, 178.) Respondent's cattle feeding study data indicate this variation in clearance. (Respondent's Brief, Table I.) Clearance"" from different organs in different species would be expected to differ. C. General Observations of Registrant's Inadequate Analysis and Unfounded Conclusions. Indicative of Dow Chemical Company's incomplete scientific analysis is a number of errors and self-serving or misleading definitions. Some of these are discussed. Dow defines "Teratogenic" as, "causing a toxic effect on the embryo which seriously interferes with normal development or survival of the offspring." (Dow Brief, p. 54. Emphasis added.) The use of the modifier J7 Vinopal, J. H. and Caseida, J. E. Arch. Environ. Contamination and Toxicol. 1: 122-132 (1973). �"seriously" is a scientifically unacceptable, subjective judgment supported by little, if any, research. As with Dow's subjective judgment that TCDD is not a "potent teratogen" because it induces inter alia, cleft palate, this subjective stance is also of misleading convenience, and may be used in partial support of such false statements as, "TGDD has teratogenic tendencies." (Dow Brief, p. 52. Emphasis added.) Dow concludes that 2,4,5-T at currently registered "environmental use levels" of TCDD poses no threat to public health. (Dow Brief, p. 47 for example.) Registrant neglects even to define "environmental use levels" of TCDD. Apparently, Dow intends thereby to mean less than .01 ppm in the technical material. Besides the fact that Dow has not even adequately discussed what levels of TCDD may be dangerous for man, it has also failed to adduce . t refined residue monitoring data on the extent to which TCDD has/penetrated the U. S. environment and the food supply. Dow's use of the word "(environmental" to define levels of TCDD, thus, has absolutely no bearing on reality. Conclusions derived therefrom as to the absence of a public health risk should be disregarded. Dow resorts to definitional looseness in concluding that residues of TCDD in human food would be of such "ultra low level as to provide an adequate margin of safety" for the public. (Dow Brief, p. 103.) Since reliable no-effect levels in a variety of laboratory species have not been established for the great majority of TCDD's known toxic effects (e.g. embryotoxicity, fetotoxicity, teratogenicity, chloracne, skin lesions, gastrointestinal hemorrhages, immunosuppression, liver function impact, - 13 - �including induction of microsomal enzmes and the increase of uroporphyrin, and induction of ALA synthetase) Dow's opinion as to the safety of "ultra low" levels of tetra-dibxin is clearly unfounded, even if it had adduced the environmental monitoring data necessary to define the phrase "ultra low." Dow reports that the research of Courtney and Moore demonstrates a "low incidence" of TCDD induced cleft palate. (Dow Brief, p. 84.) Yet the data from that terata testing (as reported in Dow Brief, p. 85) reflect a significant number of affected litters. Registrant makes a number of conclusions as to the persistence and and bioaccumulation of tetra-dioxin that are incomplete or inaccurate! Dow's conclusion that TCDD has to date not been found in the U. S. environment is now inoperative (Respondent's First Pretrial Brief, pp. 35* 36). But of more importance is Dow's rationale for this conclusion ~^r, "(t)his (the alleged absence of TCDD residues) is in accord with theoretical knowledge of the behavior of these compounds ..." (Dow Brief, p.150). Registrant's "theoretical knpwledge" is equally erroneous. Laboratory data suggest that TCDD is both unusually persistent, resisting normal environmental degradation, and has bioaccumulative potential. (Respondent's Brief, pp. 33-34.) Respondent's initially reported monitoring data (ibid. p. 35-36) tends to confirm its "theoretical" conclusions that TCDD is persistent and bioconcentrates. - 14 - �Dow's conclusions as to TCDD's persistence and bioaccumulation also relate to its opinion that TCDD readily degrades in soil, that it will readily photodegrade in the environment, and that environmental dilution of the available TCDD would dissipate its toxic impact. Dow's conclusions as to soil and microbial degradation of TCDD are incomplete. (Dow Brief pp. 150 and 159, Respondent's Brief, p. 33.) Its opinion as to photodegradation is misleading. Under environmental conditions of 2,4,5-T uses TCDD can as well be protected by screening. The reliance on dilution to dissipate the effect of any persistent widely used poison is unsound. This is even more so in regard to an extremely potent, persistent compound such as TCDD. Registrant's report of no TCDD residues in the U.S. environment is due i not only to its faulty "theoretical knowledge", but also to the fact that t it relies upon a number of monitoring studies which utilized analytical^ methods of insufficient sensitivity to ascertain levels of TCDD which could well be of importance to human health. - 15 - (Dow Brief, pp. 124, 140-141, 179.) �Finally, Dow adduces significant new information on the extent of environmental distribution of several dioxins, in addition to TCDD, from 2,4,5-T. Apparently, also present in 2,4,5-T are the contaminants pentadioxin, hexa-dioxin, and octa-dioxin, each in quantities of less than .1 pptn in the technical material, (p. 194.) Particularly as to hexa-dioxin, there must be concern for public health. Respondent will present additional toxicology information on this risk. Registrant's conclusion as to the toxicity of this contaminant in 2,4,5-T as well as the risk to man from TCDD and hexa-dioxin in other pesticides (Dow Brief, p. 187) is again mere speculation, resting on Dow's major defense — that these toxicants are present in "extremely small" quantities (Dow Brief, p. 193). Based on Dow's own reports (id. p. 187) it is d i f f i c u l t to conclude that these levels are "extremely small." ' Furthermore, it is Dow's opinion that cumulative toxic effect canop;t be expected from TCDD and hexa-dioxin in 2,4,5-T and in other pesticides. From the total absence of reasoned discussion and underlying fact, Dow's conclusion that the "uses of such products are sufficiently remote in time and space so that the cumulative impact is negligible . . . " «r (Dow Brief, p. 193) can be considered, unfounded rhetoric. Registrant, Dow Chemical Company, must persuade the trier of fact on this and numerous other issues by reliable environmental monitoring, adequate negative toxicity testing and sound inference. Dow Chemical - 16 - �in its First Prehearing Memorandum has failed to develop and to explicate such convincing proof. Respectfully submitted, Timothy L. Marker Counsel for Respondent Office of Hazardous Materials Control Environmental Protection Agency Office of General Counsel 401 M Street, S. W. Washington, D. C. 20460 - 17 - �CERTIFICATE .OF SERVICE I hereby certify that I have this llth day of March, 1974, served by mail one copy of the Respondents Second Pretrial Brief (FIFRA Consolidated Docket No. 295) upon every other party to the 2,4,5-T proceeding and have served by hand delivery one copy of said Brief on the Administrative Law Judge and 5 copies on the Office of Hearing Clerk of EPA. --£> Ti rnb'tVTy I. Harker '" Dated: March 11, 1974. � Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Alvin L. Young Collection on Agent Orange Description An account of the resource <p style="margin-top: -1em; line-height: 1.2em;">The Alvin L. Young Collection on Agent Orange comprises 120 linear feet and spans the late 1800s to 2005; however, the bulk of the coverage is from the 1960s to the 1980s and there are many undated items. The collection was donated to Special Collections of the National Agricultural Library in 1985 by Dr. Alvin L. Young (1942- ). Dr. Young developed the collection as he conducted extensive research on the military defoliant Agent Orange. The collection is in good condition and includes letters, memoranda, books, reports, press releases, journal and newspaper clippings, field logs and notebooks, newsletters, maps, booklets and pamphlets, photographs, memorabilia, and audiotapes of an interview with Dr. Young.</p> <p>For more about this collection, <a href="/exhibits/speccoll/exhibits/show/alvin-l--young-collection-on-a">view the Agent Orange Exhibit.</a></p> Text A resource consisting primarily of words for reading. Examples include books, letters, dissertations, poems, newspapers, articles, archives of mailing lists. Note that facsimiles or images of texts are still of the genre Text. Box The box containing the original item. 177 Folder The folder containing the original item. 5207 Series The series number of the original item. Series VIII Subseries I Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Creator An entity primarily responsible for making the resource Harker, Timothy L. Description An account of the resource <strong>Corporate Author: </strong>Environmental Protection Agency, Office of the General Counsel Date A point or period of time associated with an event in the lifecycle of the resource March 11 1974 Title A name given to the resource United States Environmental Protection Agency (EPA) Before the Administrator, In re: 2,4,5 -T, FIFRA Consolidated Docket No. 295, Respondent's First Pretrial Brief and Second Pretrial Brief ao_seriesVIII Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Alvin L. Young Collection on Agent Orange Description An account of the resource <p style="margin-top: -1em; line-height: 1.2em;">The Alvin L. Young Collection on Agent Orange comprises 120 linear feet and spans the late 1800s to 2005; however, the bulk of the coverage is from the 1960s to the 1980s and there are many undated items. The collection was donated to Special Collections of the National Agricultural Library in 1985 by Dr. Alvin L. Young (1942- ). Dr. Young developed the collection as he conducted extensive research on the military defoliant Agent Orange. The collection is in good condition and includes letters, memoranda, books, reports, press releases, journal and newspaper clippings, field logs and notebooks, newsletters, maps, booklets and pamphlets, photographs, memorabilia, and audiotapes of an interview with Dr. Young.</p> <p>For more about this collection, <a href="/exhibits/speccoll/exhibits/show/alvin-l--young-collection-on-a">view the Agent Orange Exhibit.</a></p> Text A resource consisting primarily of words for reading. Examples include books, letters, dissertations, poems, newspapers, articles, archives of mailing lists. Note that facsimiles or images of texts are still of the genre Text. Box The box containing the original item. 178 Folder The folder containing the original item. 5222 Series The series number of the original item. Series VIII Subseries I Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Creator An entity primarily responsible for making the resource Harvey, R. G. Date A point or period of time associated with an event in the lifecycle of the resource December 11 1974 Title A name given to the resource Typescript: Benefits and Hazards of Herbicides ao_seriesVIII https://www.nal.usda.gov/exhibits/speccoll/files/original/05ab4aa2ed4dc4372ceca26b91b492c1.pdf 72512f9f125cbfb74c56ee217a81f036 PDF Text Text Item D Number °5171 Author Ha s Harr w v' D v - United States Department of Agriculture, Agricultural Re RBDOrt/ArtlClB HUB Notice to Manufacturers, Formulators, Distributors and Registrants of Economic Poisons: Suspension of 2,4,5T Products Bearing Certain Directions for Use Journal/Book Title Year 197 Month/Day April 20 Color D Number of Images ° ° Descrtyton Notes Friday, March 01, 2002 Page 5171 of 5263 �. UNITED STATES DEPARTMENT OF AGRICULTURE AGRICULTURAL RESEARCH SERVICE PESTICIDES REGULATION DIVISION WASHINGTON, D. C. 202SO ft/Uv . NOTICE TO MANUFACTURERS, FORMULATORS, DISTRIBUTORS AND REGISTRANTS OF ECONOMIC-'POISONS Attention: Person Responsible for Federal Registration of Economic Poisons ' • • . Suspension of 2,4,5-T Products Bearing Certain Directions for .Use Recent studies by the'National Environmental Health Service of the Department of Health, Education, and Welfare have shown that the syh._cu£aneous administration of hjyjji concentrations, of the purest samples of 2,4*;"31^T"that are practical to manufacture at the present time produce a significant number of fetal abnormalities in mice. In accordance with the Interdepartmental 'Agreement for Protection of the Public Health and the Quality of the Environment in Relation to Pesticides, the Secretary of Health, Education, and Welfare has advised the Secretary of Agriculture that exposure to this herbicide may present an imminent health hazard to women of child-bearing age and has recommended suspension of certain registered uses of 2,4,5-T. On the basis of the above and in accordance with Section 4.c. of the statute, it is hereby found that in order to prevent an imminent hazard to the public it is necessary to'suspend the registration for products containing 2,4,5-T and bearing directions for use as follows-: I. All uses in lakes, ponds or on ditch banks. II. Liquid formulations for use around the home, recreation areas, and similar sites. Therefore, such registrations are hereby suspended and such products may not be lawfully distributed in interstate commerce. Labeling for products containing 2,4,5-T that can be modified by deleting the above claims may be amended. Revocation, of these suspension orders will be considered if 5 copies of acceptable labeling are submitted with PR Form 9-198. Harry«. Hays Director ' . ' �UMT2i> SVAT2S U2PARTi''-iNT Or Y,~ «.;.«~, UNITED STATES D2PART?.2IiT OP HEALTH, EDUCATION. AND KELFAB2 Washington, April 15, 1970 ^e Use of 2, 4, 5-T Suspended: Secretary of Agriculture Clifford M. Hardin, Secretary of tho Interior. V/alter J. Kickol, and Socrotary of Health, Education, end Kolfaro Robert H. Finch today announced tho iezzodiate suspension by tho Department of Agriculture o£ tho rogistrationa of liquid formulations of tho wood killer 2,4,S-T, for uses affcasd tho ho=» end on Ickes, ponds, and ditch banks. Thoso actions ara boing taken pursuant to the "Interagoncy Agrocr.ont * for Protection of the Public Health and the Quality of the Environment in Relation to Posticidop" Ezong tho three DopartnentS. The throo Socrotaries also announced that the Departccnt of Agricultura intends to cancel registered uses of non-liquid formulations of 2, 4, 5-T the hoco mid CTI all food crops intended for huaan consumption (applos, blueberries, barley, com, oats, rice, rye and sugar cane). : . The suspension actions were based on the opinion of the Dopartcont of Health, Education, and Welfare that contamination resulting frca uses of 2, 4, 5-T around tho hccie and in water areas could constitute a hazard to huaan health. . New information reported to DHEW on Monday, April 13, 1970, indicates that 2, 4, 5-T, as well as its contaminant, dioxins, may produce abnormal development in unborn animals. Nearly pure 2, 4, 5-T was reported to cause birth defects when injected at high doses into experimental t>regnant mice but not in jyats. No data on humans are available. ; 7197 ' . (more ) . • ' . . USDA 1176-70 �These actions do not eliminate registered use of 2,4,5-T for control • of weeds and brush on range, pasture, and forests or on rights of way and other non-agricultural land. Users are cautioned that 2,4,5-T should not be used near homes or recreation areas. Registered uses are being reviewed by the three Departments to make certain that they include adequate precautions against grazing treated areas long enough after treatment by 2,4.,5-T so that no contaminated meat or milk results from animals grazing the treated area. . While residues of. 2,4,5-T in meat and milk are very rare, such residues . are illegal and render contaminated products subject to seizure. There is * no tolerance for 2,4,5-T on meat, milk or any other"feed or food. USDA will issue guidelines for disposal of household products containing 2,4,5-T. The chemical is biologically decomposed in a moist environment. Background Information Secretary Finch's Coccaission on Pesticides, which reported its findings in November and December 1969, expressed concern that research conducted at Bionetics Research Laboratories, under the Direction of the National Cancer Institute, indicated that 2,4,5-T had produced a number of birth defects when fed or injected into certain strains of mice and rats. Because the test material contained substantial concentrations of chemical impurities (dioxins), the birth abnormalities could not be attributed with certainty either to 2,4,5-T, or to the impurities known to be present. Representatives of the chemical industry pointed to evidence of extreme potency of the impurities as toxic agents. They demonstrated that 2,4,5-T now being •marketed is of #. 'greater purity than that which had been tested in the Bionetics experiments and urged that further testing be undertaken to clarify the questions raised. . (more) �- 3 -. : .',*•;. ' • ''. •'! '' Responding to this suggestion and utilizing materials supplied by .'•£ • • ,-;• one of the major producers of 2,4,5-T, scientists at the National Institute .;/; of Environmental Health Sciences promptly initiated studies to determine whether 2,4,5-T itself, its impurities or a combination of both, had caused :'.''< .-I. .-' o '*'•£ the earlier findings, and whether the 2,4,5-T now being marketed produces .• birth abnormalities in mice'and rats. On Monday j •I .' and Tuesday of this week the analyses of the data were presented to the ~y regulatory agencies of the Federal Government and to the members of the ;,; Cabinet. ••'. The experiments were completed last week aid the statistical analyses performed over the weekend. : ^ ' • . '. * The dioxin impurities and the 2,4,5-T as it is now manufactured, separately produced birth abnormalities in the experimental mice. Because ! absolutely pure 2,4,5-T was not available for testing, it is possible only to infer from certain of the observations that the pure 2,4,5-T probably would be found to be teratogenic if it were tested. But, since pure • 2,4,5-T is, not marketed and could not be produced in commercial quantities, this is not a practical issue for consideration. Believing that prudence must dictate action in these circumstances, the regulatory agencies of the Federal, government are moving to minimize human exposure to 2,4,5-T and its impurities. .The measures being taken are designed to provide maximum protection to women in the childbaaring years by eliminating formulation of 2,4,5-T from use in household, aquatic, and recreational areas. Its use on food crops will be cancelled, and use on range Aind pastureland will be controlled. Maximum surveillance of water (more) . : �. - 4 • • . . supplies and marketed foods will be maintained as a measure of the ..-. % J • 't .• • • ' • " •:'f : -.•••in- effectiveness of these controls. These measures will be announced more '•.';.;:-;' • • '. r ' ' . :~!:. specifically in the Federal Register shortly. .j .| While the restriction to be imposed upon the use of this herbicide • ,£ may cause some economic hardship, the Secretaries urged full cooperation ••/ to protect human health from potential hazards of 2,4,5-T, other pesticides '•'• and the dioxins. ) The three Secretaries coircnended the chemical industry for its prompt and willing cooperation with the NIEHS in the studies to clarify questions :•••£ raised by the initial studies of this herbicide and for working closely with ^ '/i the FDA in the other studies still underway. They urged the full.support / i • . - • >. of industry, agriculture and the home gardner in insuring the safe use of 2,4,5-T and other pesticides which contribute in important ways to the welfare of the Nation. . . • USDA 1176-70 ."> � Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Alvin L. Young Collection on Agent Orange Description An account of the resource <p style="margin-top: -1em; line-height: 1.2em;">The Alvin L. Young Collection on Agent Orange comprises 120 linear feet and spans the late 1800s to 2005; however, the bulk of the coverage is from the 1960s to the 1980s and there are many undated items. The collection was donated to Special Collections of the National Agricultural Library in 1985 by Dr. Alvin L. Young (1942- ). Dr. Young developed the collection as he conducted extensive research on the military defoliant Agent Orange. The collection is in good condition and includes letters, memoranda, books, reports, press releases, journal and newspaper clippings, field logs and notebooks, newsletters, maps, booklets and pamphlets, photographs, memorabilia, and audiotapes of an interview with Dr. Young.</p> <p>For more about this collection, <a href="/exhibits/speccoll/exhibits/show/alvin-l--young-collection-on-a">view the Agent Orange Exhibit.</a></p> Text A resource consisting primarily of words for reading. Examples include books, letters, dissertations, poems, newspapers, articles, archives of mailing lists. Note that facsimiles or images of texts are still of the genre Text. Box The box containing the original item. 176 Folder The folder containing the original item. 5171 Series The series number of the original item. Series VIII Subseries I Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Creator An entity primarily responsible for making the resource Hays, Harry W. Description An account of the resource <strong>Corporate Author: </strong>United States Department of Agriculture, Agricultural Research Service, Pesticides Regulation Division, Washington, D. C. Date A point or period of time associated with an event in the lifecycle of the resource April 20 1970 Title A name given to the resource Notice to Manufacturers, Formulators, Distributors and Registrants of Economic Poisons: Suspension of 2,4,5-T Products Bearing Certain Directions for Use ao_seriesVIII https://www.nal.usda.gov/exhibits/speccoll/files/original/0ae3947549bbe53fabd07b1d60ac4bd5.pdf f27d57adf0e63e248b8f4552d45e8446 PDF Text Text nemDNumber 05172 Author ° Not Scanned Hays, Harry W. United States Department of Agriculture, Agricultural Re RGport/APtiClB TltlO Notice to Manufacturers, Formulators, Distributors and Registrants of Economic Poisons: Cancellation of 2,4,5T Products Bearing Certain Directions for Use Journal/Book Title Year 197 Month/Day Ma 1 Color ° v D o Friday, March 01, 2002 Page 5172 of 5263 �PR Notice 70-13 UNITED STATES, DEPARTMENT OF AGRICULTURE .. • AGRICULTURAL RESEARCH SERVICE PESTICIDES REGULATION DIVISION ". ' . • WASHINGTON, D.C. 20250 May 1, 1970 ; ' NOTICE TO MANUFACTURERS, FORMULATORS, DISTRIBUTORS, AND REGISTRANTS .OF ECONOMIC POISONS •. . • ...,, ,:-, .. 'Attention: Person Responsible "for Federal Registration of Economic Poisons Cancellation of 2,4,5-T Products Bearing Certain Directions for Use ' " ' "•• • Recent studies by the. National Environmental Health Service of the ,•••.' Department of Health, Education, and Welfare have shown that the subcutaneous administration of high concentrations of the purest samples of 2,4,5-T that are practical to manufacture at the present time produced a significant number of fetal abnormalities in mice. On April 15, 1970, .Secretary of Agriculture Clifford M. Hardin, Secretary of the Interior Walter J. Hic'kel, and Secretary of Health, Education, and Welfare Robert J. Finch announced the suspension of certain uses of 2,4,5-T. The President's Science Advisory Committee Report in 1963 on "use of pesticides" recommended continuing review of pesticide uses and, after hazard evaluation, .restriction or disapproval on a basis of "reasonable doubt" of safety. The Eleventh Report by the Committee on Government Operations (House Report No. 91-637) stated "The Committee recommends that the United States Department of Agriculture take appropriate steps to insure that cancellation proceedings are promptly initiated whenever a reasonable question as to the safety of a registered product becomes apparent." Since there are no finite tolerances established for the use of 2,4,5-T on food crops intended for human consumption and since women of child bearing age may be exposed to granular material for use around the home, a reasonable doubt exists as to the safety of certain uses of this material and, therefore, whether products registered for these uses are in compliance with the Federal Insecticide, Fungicide, and Rodenticide Act (7 U.S.C. 135 et seq.). In accordance with the provisions of Section 4.c. of the Act, you are, hereby notified that the registration of all products with directions for use as listed below are hereby cancelled effective 30 days following receipt of this notice, unless within such time all directions for such uses are deleted from the labeling of such products or other procedures provided for under Section 4.c. of the Act are invoked: •. �I. All granular 2,4,5-T formulations for use around the home, recreation areas and similar sites. .' " II. All 2,4,5-T uses on food crops intended for human consumption. • Labeling for products containing 2,4,5-T that can be modified by deleting the above claims should be amended. Five copies.of the revised label must be submitted to the Registration Branch, Pesticides Regulation Division, Agricultural Research Service, U.S. Department of Agriculture, Washington, D.C. 20250, for amended registration (PR Form 9-198). • ' •'• • • '•'•'• '• '• ' " ' ;" . . . . Harry W/ /Hays wf Has Director : '' � Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Alvin L. Young Collection on Agent Orange Description An account of the resource <p style="margin-top: -1em; line-height: 1.2em;">The Alvin L. Young Collection on Agent Orange comprises 120 linear feet and spans the late 1800s to 2005; however, the bulk of the coverage is from the 1960s to the 1980s and there are many undated items. The collection was donated to Special Collections of the National Agricultural Library in 1985 by Dr. Alvin L. Young (1942- ). Dr. Young developed the collection as he conducted extensive research on the military defoliant Agent Orange. The collection is in good condition and includes letters, memoranda, books, reports, press releases, journal and newspaper clippings, field logs and notebooks, newsletters, maps, booklets and pamphlets, photographs, memorabilia, and audiotapes of an interview with Dr. Young.</p> <p>For more about this collection, <a href="/exhibits/speccoll/exhibits/show/alvin-l--young-collection-on-a">view the Agent Orange Exhibit.</a></p> Text A resource consisting primarily of words for reading. Examples include books, letters, dissertations, poems, newspapers, articles, archives of mailing lists. Note that facsimiles or images of texts are still of the genre Text. Box The box containing the original item. 176 Folder The folder containing the original item. 5172 Series The series number of the original item. Series VIII Subseries I Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Creator An entity primarily responsible for making the resource Hays, Harry W. Description An account of the resource <strong>Corporate Author: </strong>United States Department of Agriculture, Agricultural Research Service, Pesticides Regulation Division, Washington, D. C. Date A point or period of time associated with an event in the lifecycle of the resource May 1 1970 Title A name given to the resource Notice to Manufacturers, Formulators, Distributors and Registrants of Economic Poisons: Cancellation of 2,4,5-T Products Bearing Certain Directions for Use ao_seriesVIII https://www.nal.usda.gov/exhibits/speccoll/files/original/1ee179c58ffe3d599dbff90cabd6b33b.pdf 558adcfabcdbf6740aacf22d06a0c1e3 PDF Text Text Item D Number 0^255 D Author Heath, Robert G. CorpOratB Author Human Effects Monitoring Branch, Environmental protec RBUOrt/ArtiClO TitlO Typescript: Interlaboratory Method Validation Study for Dioxin Journal/Book Title Year 1979 Month/Day January 5 Color Number of Images D 54 Descripton Notes Friday, March 01, 2002 Page 5255 of 5263 �INTERLABORATORY METHOD VALIDATION STUDY FOR DIOXIN AN INTERIM REPORT by Robert G. Heath Human Effects Monitoring Branch OPP, OTS, EPA January 5, 1979 �Interlaboratory Method Validation Study for Dioxin A. Introduction and Scope B. Study Design C. Results: Tables and Graphs Standards . Beef Fat Human Milk Types and Frequencies of Errors D. Statistical Analysis of Lab C Beef Fat Reports. The regression equation and confidence limits. Confidence limits'for'a predicted report value for a given spiking level. Spiking and extraction precision vs. quantitation (GC-MS) precision Detection limit characteristics E. Estimation of a "true" TCDD level, with statistical confidence limits, from spiking study results (Lab C Beef Fat example) F. Discussion �Acknowledgements page to be prepared. ii �A. Introduction and Scope The Interlaboratory Method Validation Study for Dioxin was undertaken to measure the accuracy and precision with which 2,3,7,8-tetrachlorodiobenzo-p-dioxin (TCDD)> when added to beef fat and human milk at low parts-per-trillion concentrations, can be extracted and quantified by methods of gas chromatography-mass spectrometry (GC-MS). Method validation also included quantitation of equivalent amounts * of TCDD standards. ' r 'f In particular, the studj was undertaken to develop regression statistics for converting reported TCDD concentrations to "best estimates" of actual (but unknown) concentrations and for expressing the reliability of such estimates in terms of statistical confidence limits. The study was also intended to determine the lowest concentration of TCDD that was identified with practicable consistency and the frequency of "false positive" and "false negative" reports. All samples were prepared and extracted at the EPA Pesticide Monitoring Laboratory, Bay St. Louis, Mississippi. Analyti- cal laboratories participating in all or part of the GC-MS quantitation were those of Dow Chemical Company, Harvard University, University of Nebraska, Wright State University and the EPA Health Effects Research Laboratory (HERL), -1- �Research Triangle Park, North Carolina. Analytical laboratories are identified only as laboratory A,B>C,D, or E' throughout the report; alphabetical order is independent • of the above laboratory order. The number of samples, by type, quantified by each laboratory is shown in Table A-l. -2- �TABLE A-l. Number of Samples, by Type, Quantified by Participants Sample Description Acid/base cleanup Human milk Beef fat Neutral Extraction Laboratory Standard A B C 26 25 26 + 3 0 1 26 26 26 6 0 26 26 0 0 11 0 0 16 16 0 78 77 71 22 12 81 84 63 32 260 D E Type totals Beef fat Lab Totals �B. Study Design Beef fat and human milk samples were "spiked" with TCDD at levels ranging from 0 to 81 ppt. Cl Standards were prepared so as to contain equivalent amounts of the chemical, Samples were prepared from one of two pools of rendered beef fat (pools F and G) and one of two pools of human milk (pools M and N). Pat was from cattle without potential exposure to dioxin; the milk had been collected in regions where use of pesticides potentially contaminated with TCDD was incidental. Pools were constructed using equal amounts of fat or milk from each animal or donor/ using a separate set of animals or donors for construction of each pool. ;' Eleven samples each were prepared from fat pool F and milk pool M—the major pools. The samples from each pool were spiked individually at 0, 0.5, I, 4, 9, 16, 25, 36, 49, 64 or 81 ppt. The samples were then extracted by procedures developed/refined at PML, and the extract was divided into the required numbers of equal aliquots for shipment to the analytical laboratories. Spiking levels, excepting 0.5 ppt, were systematically incremented as the squares of the digits 0 through 9 to provide close spacing at low levels and a moderate, systematic increase in spacing with increasing levels. -4- �To test the precision of the extraction methodology, five samples each were prepared from the minoc pools (fat pool G and milk pool N). These samples were spiked individually at 0, 9, 25, 49, and 81 ppt, extracted by the same procedures used for samples from pools F and M, and divided into the required number of equal aliquots for shipment to the analytical laboratories. Thus, fat pools F and G and milk pools M and N provide replicate samples at the above levels of spiking for testing extraction precision. V I To test the precision of GC-MS quantitation for comparison with that of extraction, laboratories were provided two aliquots of the G- and N-pool extracts, along with two aliquots from each of the matching extracts from pools F and N, so as to obtain duplicate analyses of the s'ame extract. Labs also received four standards at each equivalent of 0, 9, 25, 49, and 81 ppt, as well as single standards at 0.5, 1, 4, 16, 36, and 64 ppt. Standards are denoted as S. All samples—fat, milk and standards—were required to be prepared and shipped in random order, and laboratories were to analyze the samples in the order in which they were received. Samples were identified only by shipment number, so that laboratories knew neither the type of sample nor the TCDD level at the time of analysis. -5- �A variation in the above procedure was developed for a set of beef fat samples analyzed at Lab D. The fat samples in that set were spiked at PMLput were extracted at Lab D using a^^neutral extractionyprocedure rather than the acid/base procedure utilized throughout the study. Accuracy (the degree of constant tendency to either underreport or over-report the true level) and precision (variation among repeated measurements of the same extract) have been measured by methods of regression analysis; comparisons of extraction vs quantitation precision are by analysis of variance based on those spiking levels for which there were duplicate analyses of replicate extractions. schedule is presented in Table B-l. -6- The analytical �Table B-l. Design Diagram for Phase II Dioxin Study TCDD Level (ppt) Beef Pat Measuranents Human Milk Measuranents Pool Code Lab A Lab B etc. 0 0 1/2 1 4 9 9 16 25 25 36 49 49 64 81 81 Pool Code Lab A Lab B etc. P M G F P P P G P F G F F 2 2 1 1 1 2 2 1 2 2 1 G P 2 2 1 F G 2 2 2 2 1 1 1 2 2 1 2 2 1 2 2 1 2 2 N M M M M N M M N M M N M M N 2 2 1 1 1 2 2 1 2 2 1 2 2 1 2 2 -7- 2 2 1 1 1 2 2 1 2 2 1 2 2 1 2 2 Standard Measurements Pool Code Lab A Lab B etc. S 4 4 S S S S 1 1 1 4 1 . 1 1 S S 1 4 1 4 S S 1 4 4 S S 1 4 1 4 4 1 �C. General Results Analytical results for the quantitation of standards are presented in Tables C-l through C-3. Figures C-l through C-3 (each figure follows its respective table) show the plotted results and the least squares regression lines and equations for reported values on spiked values. The theore- tical line y=x,. for perfect extraction and quantitation is also shown for comparison. * Equivalent results for beef fat samples are presented in Tables and Figures C-4 through C-9, and those for human milk appear in Tables and Figures C-10 through C-12. An explanation of the types of reporting errors and an enumeration of those errors are presented in Tables C-13 through C-16. In this report, the reporting of a positive value in an unspiked sample is identifed as a "False Positive" (FP), and a positive report given when the detection limit exceeds the level of spiking is.identified as a "false positive" (fp). A "false not detected" (fnd) is defined as a report of "nd" when, in fact, the level of detection is less than the level of spiking. As might have been expected, the highest frequency of errors. occurred at spiking levels below 9 ppt. -8- �Table C-l. Dioxin Phase II: Interlaboratory Quantitation Study Type of Sarcple: Standard (5g equivalent) Preparation Lab: PML Quantitation Lab: Lab A 5 Sample ID Study FML S-0.5 ST--Q ST-0 ST-0 ST-0 ST-.5 S-l ' ST-1 .3-4 ST-4 S -°l s-o2 s-o3 s-o4 S 9 ~1 S-92 S-93 S-94 S-16 S-25, S-252 S-253 S-254 S-36 S 4 9 " 1 S-492 S-493 S-494 .3-64 O <*••* S OT S-8 S-813 S-814 ST-9 ST-9 ST-9 ST-9 ST-16 ST-25 ST-25 ST-25 ST-25 ST-36 ST-49 ST-49 ST-49 ST-49 ST-64 ST-81 ST-81 ST-81 ST-81 Shipment 2 40 45 Recov. •37 7 cr (%) 88 101 TCDD Levels (ppt) Reported Added .320 322 Avg. 0 0 0 0 0.5 1 32 44 83 94 95 '141 77 68 93 113 69 86 93 90 64 131 81 67 109 98 4 9 9 9 9 16 25 25 25 25 36 49 49 49 50 17 12 29 43 51 98 107 46 98 102 106 49 64 81 81 81 81 49 15 19 10 21 28 46 47 22 16 42 48 52 5 13 nd nd 2 nd 1 nd 2 7 .4 7 10 6 nd 19 8 18 16 23 26 18 68 rri 44 40 44 56 -9- Detection Limit 320 322 0.3 6 2 2 1 2 2 2 2 7 3 2 0.7 3 2 2 4 2 2 1 4 0.5 2 2 2 3 �Figure C-l Standards Lab A .(322 m/e) 120 • 110 100 QO . \J f j * 80 j • * • ./ *^ 4 * .4 r ^ 70 •i ^ *1 -' -JV<^j O?" *~ XV c* ^ * t + > y. ts 6r <u j * 4J o S C- 0) S c 50 5 c.n c £-: ——x*^-* ' | | i &» 40 O^i 'm^s^ fj** _4£- ^^^ ' j j }-f^^ \x • s 30 ^~ / , f .j ^^^ ' 20 A A ___ jzatL 10 -^L 10 20 *' 0 if •' BEE 10X10 ' 60 50 a TCDD ad ded (ppt) /tO 30 X J 70 8'D -10- �Table C-2. Dioxin Phase II: Interlaboratory Quantitation study of Sample: Standard (5g equivalent) Preparation Lab: PML /] Quantitation Lab: Lab B k/ Sample ID Study S "°l s ~°2 s-o3 s-o4 S-0.5 S-l S-4 S-9, . S-92 S-93 S 9 ~4 S-16 S-25]_ S-252 S-253 S-254 S-36 ShipPML ST-0 ST-0 ST-0 ST-0 ST-.5 ST-1 ST-4 ST-9 ST-9 ST-9 ST-9 ST-16 ST-25 ST-25 ST-25 ST-25 ST-36 ST-49 S 49 ~ 1 S-492 . ST-49 ST-49 S-493 ST-49 S-494 ST-64 S-64 ST-81 S-81, ST-81 S-8 ST-81 S-813 ST-81 S-81, ment Recov. -.. Cl (%) added Reported 320 322 Avg. 0 2 40 45 49 15 19 10 21 28 46 47 22 16 42 48 • . nd 0 0 0 0.5 1 4 9 9 9 9 nd 3 nd nd nd 16. 25 25 25 — 4 9 4 10 10 16 17 7 2 nd nd 5 6 6 7 10 22 13 19 nd nd nd nd 4.5 7.5 5 8.5 10 19 15 13 Limit 322 4 2 2 3 3 4 - 3 3 2 1 4 5 - 3 4 2 3 2 4 2 1 2 1 2 1 1 4 1 2 3 1 59 21 77 12 22 29 18 25 33 50 23 47 4 5 5 1 2 3 5 1 6 5 3 1 1 1 2 2 1 83 43 63 3 2 29 6 13 52 40 8 28 29 43 51 81 -11- nd nd nd 320 25 9 17.5 40.5 29 16.5 30.5 54.5 22 62 25 36 49 49 49 49 64 81 81 81 52 5 13 32 44 50 17 22 Detection TCDD Levels (ppt) 21 2 �TCDD reported (ppt) M H« o s s l - - ,s s D r o O S - '• - ' ' O l^ ' \ ^ v . ..A . \ 1S - U O l O \ *»4 C O 0 . O O <O O O O M »-J N J O O . , S1 Q :.. ' sk ' " \k w i - '\ .° .t " i\ k a. ! . 1 > . S i j . * ^ - S O i . y • a a. P 0 > '\ P> - v V o J - y to j 0 ' S o » s R g • « • - • ^ ' ^ L y (0 (X i •S* ( r» O ^ > ".JS..! . . ' . ; . ' \ S s -- . >• "' • • ^ OPv - , - - i O '' s > S' * '' - ' 1 •• \ i ^* 1 o j_ _j_ j. 1 i i < i; 1—* QQ • ' j1 - V ° ; t • '. i ! Ii •. i. i ! . : •i ! i i i i * ^ !i • ii li ;l i' i i • . ••? .• ! ! ^ ' t ' . ' • ' '1 l i l j ! ' _ _ _ - - - . . _ _ - _ . _ - - _ _ _ . „ . . . - _ . . . - - . - ~ - . . . . _ _ - . _ _ > - ^ . _ ' j < st 1 Ai H x Vti . i ., , 'r ... • Tf ' > 1 ii '. \ >^ • 1 1. i i ; i iiluii i 11 *~* *• i ^- _LL ^ « V ! ! \ i * ; * ;' i' V• ' Vj \ . . JM » B . ! i -~ ^ ! XI i1 iii i i i i ii . i . j * . • ^ .-|- » : •'*—i *i ii i r~ r * 1 , - , . - . IX. • i i t \~t~ i i t f •" • .._—-. .. - _ i _ _ _ *_ L—^ I ^— « �; ' I !t I ':!»•; 1 ! . Ml I!! •..i ; !<> . r-~t--- • • ! 1 i\.| ' 1> rt \ 1* <u OT ~B "C M 0 ca cvi to a^ tf> o 0) 3 00 •H O C>l • O O O O> O O CO \o (3dd) �Table O3. Dioxin Phase II: .Interlaboratory Quantitation Study Hype of Sample: Standard (5g equivalent) Preparation Lab: PML Quantitation Lab: Lab C Sample ID Study PML s-ox s-o 2 . s-o3 s-*o4 ST-0 ST-0 ST-0 ST-0 S-0.5 S-l S-4 S-9, S-92 ST-.5 ST-1 ST-4 ST-9 ST-9 ST-9 ST-9 ST-16 ST-25 ST-25 ST-25 s 9 "3 S-9, S-16 S-25, S-252 S-253 S-254 S-36 S-49. S-492 S-493 S-494 S-64 S-81, S-8 S-813 S-81, ST-25 ST-36 ST-49 ST-49 ST-49 ST-49 Recov. Shipment 2 48 57 62 15 19 10 21 56 60 64 22 16 55 63 69 5 13 51 52 70 17 12 . 3? C1 J '(%) TCDD Levels (ppt) Reported Added 320 322 Avg. 0 0 0 0 0.5 1 4 9 9 9 9 16 25 25 25 25 36 49 49 49 49 64 81 nd nd nd nd nd nd nd nd 1 1 9 6 16 21 17 25 24 34 41 51 47 47 • 81 ST-81 49 59 81 65 76 77 80 ST-81 67 81 80 ST-64 ST-81 ST-81 '-14- Detection Limit 322 320 • 10 4 4 4 6 12 6 10 5 4 4 10 4 4 4 4 16 12 3 9 5 6 6 3 3 5 �Standards Figure C-3 /w^^-* Lab C (3 22 m/e) 1 ; 120 1 „, - 110 0 , | I n 100 1 . ' 1 . • . » **f X j^ JX IT _r "x .* y .x^ y - -T y _ v^ y T * ^r ^ ,y r) > > y it * X X * X y ^" • y^ y^ X^ _/", * " x . .y ff * •** x r *"— C 1 o ' ' /^^ ^j** _r^ rf > (/" f —. " _^ ^^ X • i^*^* J ' X T * X X ' x t ^^ . n a . - y V yx X X1 •^ r X^ __ _. " y X" x^ X -/X ,X _r O u X X y 1 x^ ,, X1 X" ^ V n * •• • - , y y^1 * 4 ^ X * rr . -^ X X n x ^x • ' ' ——— .X X "X w • • . x" x 0 BEE 10X10 10 2o 30 4'3 '50 T CDD added <PPt) 60 70 8D *-!5- j- �Table C-4. Dioxin Phase II: Interlaboratory Quantitation Study Type of Sample: Beef Fat (5g sample) Extraction Lab: EML; Method: Acid/base Quantitation Lab: Lab A Sample ID Study F-01 F-02 Gr01 G "°2 F-0.5 F-l F-4 ^9i F~9 2 G-9, G-92 F-16 F-25-L F-252 G-25, G-252 F-36 F-49-L F-492 ^* a A Q \J m *g •* T G-492 F-64 F-8^ F-812 G 8 1 " 1 G-812 EML PE FE GB GB FG FC PI FK FK GC GC FL FD FD GE GE FA FH FH GA GA FB FJ FJ GD GD Recov. Shipment 11 31 24 39 1 7 6 25 41 20 30 26 3 34 18 38 8 27 33 14 35 9 23 31 4 36 Cl37 { 9t) 71 72 73 53 69 72 70 64 75 93 68 72 71 77 73 68 80 73 99 87 68 101 53 89 69 71 TCDD Levels (ppt) Added 0 0 0 0 0.5 1 4 9 9 9 9 Reported 320 322 Avg. 103 nd nd 2 12 3 28 4 9 2 nd Detection Limit 320 322 7 5 4 2 0.4 2 5 2 1 1 1 4 1 49 49 49 49 64 81 81 81 8 110 22 5 8 34 18 7 6 32 86 25 22 110 81 40 2 16 25 25 25 25 36 -16- 6 5 1 3 2 2 0.8 5 3 2 4 1 �Figure C-<! Beef Fat- Samples Lab A .( 322 in/e) ^3 1 120 1 t rt 10 1 • 100 " •- - ! , 90 y X / ,. „ * • j • O f\ 80 X , > " " _ . ' . . ' *-/ r ^ ?* *T? >* y 9," ** * 7n o. v^ —W J •^rZ? *L*U x 1 •o 4] jj tj o jX x X" X" AD i f )4 A O O CJ H > ^_^* w f ^^^^ ^r~^ - 50 Jf . J rt*~ jf f 40 f i i . i j p , — i^xC '^r^ X . ^ j r^' r\"^ ^^fA P• .-^"^ y V*JX^ ^P**^ .. .. ^ +. Jr \r\ ————— — jf ^ - • ' — ^^ -x^ ">^ ' • : . 2n 0 -. - — — — , • - ' " — —— « j _ _____ jf -^*~ "' —- * _._ -. ' —— - . ,_ « 1 r™ ^ [ . 10 j r f • • • 9 0* 1 x • ' ' f f1 • » LO BEE 10X10 20 3n Ij 4 50 fbO 7 o. a0 �Table c-5. Dioxin Phase II: Interlaboratory Quantitation Study Type of Sample: Beef Fat (5g sample) Extraction Lab: EML; Method: Acid/base Quantitation Lab: Lab B /"\ ,, Sample ID Study F-Oj^ F-O, oro1 G ~°2 F-O. 5 F-l P-4 F-9X F-92 G 9 ~1 G-92 F-16 E-251 F-252 G-25, G-252 F-36 F-49, F-492 G-491 G-492 F-64 F-811 F-812 G-81]_ G-8L, EML FE FE GB GB FG FC FI FK FK GC ' GC FL FD FD GE GE FA FH Ffl GA GA FB FJ FJ GD GD Recov. ,Cl (%) Shipment TCDD Levels'(ppt) Reported Added 320 322 Avg. 4 13 27 33 14 35 9 23 31 4 9 16 25 25 25 25 36 49 49 49 49 64 81 81 81 8 7 13 12 12 18 12 27 21 35 38 15 54 42 27 60 7 6 10 5 12 nd 20 13 13 21 11 18 10 17 27 8 29 22 26 43 28 25 34 32 64 36 81 39 32 11 37 24 39 1 7 6 25 41 20 30 26 3 34'' 18 38 8 ' v \ ' 0 0 0 0 0.5 1 4 9 9 9' -13- nd 9 7 nd 7 7 6 5.5 Detection Limit 320 322 13.5 10 9.5 14.5 9 15.5 11 14.5 22.5 10 28 21.5 30.5 40.5 21.5 39.5 38 29.5 62 4 • 2 . 4 2 4 4 5 5 2 7 2 7 4 2 6 3 5 3 3 7 2 8 5 2 9 2 3 4 2 3 4 5 3 2 5 2 2 2 3 6 2 7 2 2 3 2 2 1 3 5 35.5 2 2 9.5 7 9.5 nd �1 rt ~ \ • -» .. j. . . ..i !. 1 1 . > •v H r' i • v, " " — * ..__.- !i ' i ' ' v i :t i i I " -* r TI i' M •1 T i ._. • . 1—»-+-i— —r " " u -- || • \ ..,.:-,_!>. .{ . i l .^ . ' 'N ; .- . "• ; ! 1 t : 1 t j 1 1 • •' ; 1 ; !-r- i i : , 1 ; ! ! • : \ I 1 !•• I 1 ' CP 1 l' i i • '' (' ^V . i \j i 1 ; I ' ' ' ' • 1 1 !' ^ ' 1 1 j ' 1 • i ' ! ' ;i !i• i i •I ! ' ! • i 1 ,! : . . ; ; | , , ,: , . • , , , , , ; ! -' \ k • 1 1 i i Q . .. « I ' ' i\ js| ~~t— t — • — *• X 0 \ V <A 1 L < * o L^ \, \ w /-^ a) Q) '' '••.. r . - .. * : 'i . , . , - , , • . rt pf ff^ <H Ji i' ' : ' . - - .i ' . \ T . " " . . . " . T "*" T "«: *O ' "rt \ ,O <J> ^' ) " ' '. P. m P- > ^ ^ ". -,- o \ * » . _.- < ; i i i . ( 0' 4J »— ' 1 ..j-.^-.. . . - , - . - _ , - . - - . - "P. ~B m CO C4 *" > . ' i , ,i .- O -* 0 i 8 H ctf « ^ I V\ II 1 \ \ 1 • 1 • CO ) ', . ' . k » ' 1 S ' 1 ) J I ° 'S \ rt in 1 o N i • A M ' ' * 'V \ I' . __j •|| r* O tS r^ .^ ! 1 C rH rH : • .- - - :: O O\ C OO O f^ (qdd) r+ H » S N B 's - ' ' O O iH . V i 01 * O O VD O i n C <f O CO C C4 ' 4 O rH < " " S O ' ' ' �TCDD reported (ppt) o N> o o GO O Ov o o o VO O H O o • A OQ •6 ID O I Ul o* r1 w B> <D cr ID Mt fU rt 1 0 O (D (0 CO :j *tZ \ 111 1 '• ': l Tl �Table C-6. Dioxin Phase II: Interlaboratory Quantitation Study Type of Sample: Extraction Lab: Beef Fat (5g sample) EML; Method: Acid/base Quantitation Lab: Lab C Sample ID ShipStudy F-0-j^ M-, G-0, • X G ~°2 F-0.5 P-l F-4 F-9-L F-92 G 9 "1 G-92 F-16 F 25 ~ 1 F-252 G-251 G-252 F-36 F 49 ~ 1 F-492 G-49, j. G-492 F-64 F 8 1 " 1 F-812 G-811 G-81- -!ML 11 FE FE FG PC PI FK GC GC FL FD FD GE GE FA FH FH GA GA FB FJ FJ GD GD ' 7 6 25 68 20 50 26 3 47 18 71 8 27 58 14 66 9 23 61 Cl (%) TCDD Levels (ppt) Reported Added 0 0 54 24 65 1 GB GB FK ment Recov. -- 0 . 0 0.5 1 4 9 9 9 9 16 25 320 322 Avg. • nd nd nd nd nd . nd nd 4 25 25 25 36 49 49 49 49 6-4 81 81 81 9 11 nd 12 19 (63)* 24 26 27. 31 50 48 39 48 58 76 74 76 53 .81 77 *Aberrant value both included and excluded in calculations. -21- Detection Limit 320 322 8 5 6 6 14 10 18 4 5 14 5 10 10 2 12 4 6 6 ' 4 10 6 4 6 4 14 3 �• ; i 5 i f. '> \' i IT i '• k \ u * *ju S i i *v S N f-1, ^ ^ — ~>^* *eZ^ —•> •' \ , r S ^ ^ IN : ' ' - | - ^ y \ \K §»'« , . , . , , ' - r , - '( ,- • ' ; ^ s > C6S 1 1 ^ 4_l CN| g tfl CO' i TT ^ \ • X-N i j t^M \ « VS T i "i T ~f || • i • i• " ^ » . S > ' • N S, s tn^FJ fll .O M . - . . _ . i3 ' . . . . . . . . _ : .^ . ( ii w ' . " ' ' . . . . . ^ . S ' : ; : . ' ' ri i . . . t "- . L! ' t - . . . (C . . . . . . t S s S \o - i 1 U ' [ . " • ._ ' . .- -. - r _, - .. ^ ., ! s] . 3 • 60 . •H .. . <t> • tH tH cb O rH O. °* -. L -f I \ 1 1 s s s . <f> IS iH - ^ ( V o» I s ^> w <3 »~s. O CO (qdd) O \o O in O <j~ O n O t>i C3 r ^ sS> 'j. O �TCDD reported (ppt) H1 O o vk IO O UJ O *O L s k . . 1» s CD S s '» n i' r . . S' r § T '' H. . *g n» . . . ' ' . . ' . S . '. ss ^ * " ' fy - - • - . s > C ) s S . t '. - - - S . . . - S . • S o 1 .' ." a4 ' , .. - . . N ^ . '^ . - i . .' . ' . • • - • - • . . . . • '• : ... - - - - ' ' :. - - . . . . . .. • . • '. • ••;..::' fk S J - - *\ v Vy .: •- * -.'..-' . . . . y " '" JX • • . • . . .. • .: : . . .. . • - s B. ' . - IT ^"* - -' • i • V \ • * • . : . - " . < • ", . s s . io o . i b Old g \ \ ,< 8 a Cf> O L ' 1 Ul O j L...|i j T 0, (0 O* 10 ' " . : ' ' T^ *tr** U rt t T^ TV CO hi /->. ^ 0 •a •CJ n> 0 y ' ,' rt •*~f *~s s —• \ ^- 1 ' 1 ' j : i • '! ' r a> I i i ! ! , , . . . , P to • f LJ 1 I 1 -J. L_ _L I I " \ '1 _j ^Vj V <~ \ • \ s .* I » N > x^ , fVfo *«. ^^ i o \ X ss 1 1 ' V ' ' j | oi ^r >^ "*«^. *O \» * k ^ M o \ y ^ ^ • . a " i *' ~ �Table C-7. Dioxin Phase II: Interlaboratory Quant i tat ion Study Type of Sample: Beef Fat (2.5g sample) Extraction Lab: Lab Dy Method: Neutral extraction Quantitation Lab: Lab C . / J, Sample ID Recov. Ship„ ment ClJ/(%) 1CDD Levels (ppt) Reported 320 322 Avg. Detection Limit 320 322 Study PML F'-0L S-12 41 0 nd 6 S-l 28 0 nd 6 ' F S-4 S-9 S-2 S-10 31 37 29 38 0.5 1 4 9 nd nd 17 nd 6 6 6 8 G--9, S-13 42 9 10 5 F'-16 S-3 S-6 30 34 16 25 12 24 6 5 S-ll 40 25 25 10 F'-36 F._49i S-16. S-15 45 44 36 49 31 45 6 G'-491 S-8 36 49 70 5 P'-64 F'-81 S-14 S-5 43 33 64 81 52 76 5 8 S-7 35 81 70 G-0, P'-0.5 ' F'-l P'-4 '-91 P '~251 Added G ^ -24- 9 �figure C- 7 Be<it Fat Saniples Laij C (322 n i/e) Neutral Extracticm, 2.5 go , •i ^ 10 2. 110 — 100 i. • : ; r • ! 90 jf • s , 80 n «.. 70 ^< ^f * f "/ * t • S ,s A , . , , S _i•f -X ^ ' * o • j, ,r jT f/ j» V ' 1 a.. e. a § t .... - .N J*'^ J '"V J* f t~. S S I'M rr .^ - »^ ^ y^ x JC5 >r _/ X. . , %', * j^ *** _r j ^ i j^" —±^—i y 60 ^^ A jT f ' ' f -. J^ ^^ ,. y' * y fc^ s 50 s ^ ^ ~ S A XVX" . V"^ *>^ y*yr 40 /^ -X"^ *^f _,£ , 30 j, y »• -. . '' • ' ^r J* ^ J ni™ ,- ^x£t V— -X" 20 f f ^ :f ^ -X" —• 1 V ^ X JX^ S ^ y X' 1 .. ,r -_^—*— ;— 10 —7* •+ : — 7« f BEE 10110 u 20 30 4( >0 TCDD addesd (ppt) du /o a0 -25- / �Table C-8. Dioxin Phase II: Interlaboratory Quantitation Study Type of Sample: Extraction Lab: Beef Fat Lab D; Method: NeutraJ. extraction Quantitation Lab: Lab D Sample ID Study PML Reccv. ' Ship3 ? raent ClJ/(%) TCDD Levels (ppt) Aided nd nd nd 23 7.7 0 nd 23 (23) 35 6.9 nd 2.3 24 . 45 17 44 18 16 0.8 13 0.4 16 15 92 . 0.5 4 9 nd 2.5 nd 0.9 42 19 9 9 nd 11 nd 8.5 11 16 46 16 25 25 29 19 26 22 28 9.2 12 15 12 62 10 41 G '° "l S-l 28 P'-O.S S-4 31-1 31-2 05 . S-9 37-1 37-2 29 38 1 57 81 » P'-l F'-4" Detection Limit 320 322 0 S-12 P1-^ Reported 320 322 Avg. 53 nd nd 2.2 15 15 P '-91 S-2 S-10 G'-9X S-13 42-1 42-2 F'-16 . F--25, S-3 S-6 30 34 G '"251 S-ll 40 25 nd 25 (25) Fl-36 P'-491 S-16 S-15 45 44 36 49 32 62 41 73 37 , 68 8.5 22 25 33 S-8 36 49 49 49 49 25 10 F'-64 S-14 54 155 52 (155) 34 S-5 64 81 50 F'-SL, 43 33 8.5 70 S-7 35 81 89 86 88 24 38 ' G1^ -26- - - .15 �Figui e C-8 . *j ]Seef Fat £Samples Lai3 D (Avg. of 320, 2 22 m/e) ]Neutral EJctraction * ( rt. V 20 tw— ^M ^ 10 >r ~r—:—~~ yt 1 00 —^ • ' V ^_y -y A, •jy 90 "/ . J -r~ V* X^ f ^/_ ^ x x x » 80 |/ ./r , -7- X X /. / X jT f • * ., jf 70 X X .X X .f - ^ X x^ ; 1 : • *ty r? ' *v ^ t?"s/i' **" j X i ' ' 60 * _r x^ . . ^ffc1. / jf v VX jf , f /^ f X ' ' X f 50 j jf jf ^ •^ V y / J .f X J' ^u, J • 1 f r 40 f jf f / f 1 f f f —T^*-1" ~J r * jr jf jr . tr . 30 X X --. / ^r jX jT / 20 — V ^ y X" X • X 10 / • X • x * S X J ' ' ' \ ........ X" • _X X "/ X /" : —^— jf ft ./r ^ J* * f • ft *y*_ X" . 0 ass loiio-LO i.0 30 4 TCDD add ed (ppt) 50 v0 ~S 0 -27- /: �Table C-9. Dioxin Phase II: Interlaboratory Quantisation Study Beef Fat Type of Sample: EML; Method: Acid/base Extraction Lab: Quantitation Lab: Lab D Pecov. Sample ID Study F-0, 1 F-02 G-O-L G-02. F-tD.5 P-l F-4 EML FE Shipment 3- Cl (%) SO-5 FC SO-4 P-9, 1 F-92 G-9. 1 G-92 F-16 F-25, 1 F-2S2 G-25, 1 G-252 F-36 F-49, 1 F-492 G-49, 1 G-492 F-64 FK FK GC SO-1 FB SO-6 F-811 F-812 G-81, 1 G-81. FJ FJ SO-2 GC PL FD FD GS GE SO-3 FA FH FH GA GA Added 0 0 0 0 0.5 1 4 FE GB GB FG FI TCDD Levels (ppt) 83 9 9 9 9 16 25 25 25 25 36 49 49 49 49 64 GD 10 nd (nd) (nd) nd nd nd nd 3 (11) nd 13 nd,nd nd (8.3) nd,36 29 16 24 35 (14) 44 (37) 37 68 (73) 143 (154) 74 4 8.3 10 9.8 3.0 (8.0) 10 (14) 107 (17) 10 (100) (17) (145) -28- 66 (15) 6 14 71 (83) 114 81 Detection Limit 320 322 6 32 (34) 81 81 81 GD Reported 320 322 Avg. 127 10 6.1 (3.1) 5.0 (7.0) 4.4 (8) 5.0 (7.0) 12 4 6 10 (13) 6 �Ileaf Fat S amples Lab D AcJ.d/Base Cl eanup ( .5 gm) W<,rvW* 2 Figure C-9 j' 120 110 X i ! X -/ hA X ' x x - 100 ! \ X S J f ' *f % _r >^ /" X 90 »^ .r ^ «* X * x X *-. " X ac x x^ x * ' ^r . ^» x x x x f X" / 1 ©, / 1 X^ ^1 ^ * <^» i W X^ X^ ^ 'V • ' t 1 c/' T r r •'—/••^ . J / f i t?j" ' / * , v' M.JT, X" 'f f 40 i S / X^ 50 V ^ ' x X x x 60 , • i X ^n y x x p J> ^ jf X * '^ ^ * ^ / 7C . A f .. : i • ' y / ' ^ ' 30 x f * <* -• v > , X ' ' 7_— fy j^O m/e f X — s- 20 . yf X o 322 m/e ^ Avg. 320, 322 m/e; Regression based on averages jft J*L_r y 10 if 1*1 ' x X* X X t. f X i r^ J* • 0 BEE 10X1^- 0 20 33 ^^0 50 60 TCDD adde d Cppt) 70 80 -29- / �Table C-10. Dioxin Phase II: Interlaboratory Quantitation Study Type of Sample: Human Milk (10 g sample) Extraction Lab: EML; Method: Acid/base Quantitation Lab: Lab A t 1 <Recov. Sample ID Study EML M-Oj^ AB M AB BB BB AD AE AF AC AC ~°2 N "°l N "°2 M-0.5 * M-l M-4 M-9X M-92 N-9]L BC N-92 BC M-16 PG AH AH BD BD AI AA AA BA BA AJ ' AK AK BE BE M-25X M-252 N-251 N-252 M-36 M-49 M-49 N-49 N-49 M-64 M-81 M-81 N-81 N-81 Shipment 71 77 58 60 54 59 63 53 55 61 64 56 70 76 66 ' 74 69 72 78 57 62 68 67 75 73 79 3? ClJ/(%) 103 92 80 103 99 91 92 93 89 69 107 79 99 90 81 104 96" 110 119 100 98 85 89 104 136 121 TCDD Levels (ppt) Reported Added 320 322 Avg. 0 0 0 0 0.5 1 4 9 9 9 9 16 25 25 25 25 36 49 49 49 49 64 81 81 81 81 -30- 1 4 Detection Limit 320 322 5 1 2 2 2 1 11 1 1 5 4 ^ 2 nd nd 1 •3 4 5 15 11 15 7 28 29 29 36 39 36 31 21 114 24 —! — 1 2. 2 1 1 1 1 3 1 '1 2 1 2 2 1 �TCDD reported (ppt) K> o Ul o o oo o vo o o o OQ fl> o ET W l-o ID \ ' !l ' ' vr v N �Table Oil; Dioxin Phase II: Interlaboratory Quantitation Study !Iype of Sample: Extraction Lab: Human Milk (10 g sample) EML; Method: Acid/base Quantitation Lab: Lab B Sample ID Study PML M-OI AB AB BB BB AD AE M "°2 N-OI N-02 M-»0.5 M-l M-4 M-9X M-92 N-9, N-92 M-16 M 2 5 " 1 M-252 N-25-L N-252 M-36 M-49 M-49 N-49 N-49 M-64 M-81 M-81 N-81 N-81 . AF AC AC EC BC AG AH AH BD BD AI AA AA BA BA AJ AK AK BE BE G\ Recov. Shipment CLJ/(%) 71 77 58 60 54 59 63 53 55 61 64 56 70 76 66 74 69 72 78 57 62 68 67 75 73 79 ' • s TCDD Levels (ppt) Reported Added 320 322 Avg. 0 0 0 0 0.5 1 4 9 9 9 9 16 25 25 25 25 36 49 49 49 49 64 81 81 81 81 -32- 2 2 - nd 3 3 2 7 7 24 29 23 45 49 17 - 10 (10) 8 (8) 17 9.5 15 8.5 3 (3) 7 (7) • 4 (4) 7 5 7 5 10 6 9 (9) 9 a 26 16.5 35 29.5 34 31.5 32 (32) 38 30.5 69 57 53 51 21 19 10 (10) 82 (82) 110 (110) 97 (97) 110 (110) 96 (96) Detection 320 Limit 322 - 2 2 2 3 2 3 1 3 2 '1 2 2 2 2 2 2 2 2 2 1 2 4 2 1 2 2 1 2 3 2 4 2 1 2 1 3 3 2 - 2 2 �Figure C-lla Human Milk Samples - Lab B (322 m/3) 20 1U i ! 00 jT > t-7^-—H x • • • • X r x rt » ^^* ^> • 80 ^.j* / V x"^ X" 1 •x ^ . / x^ ' X^ "V"" X^ 4 V* _r X1^ _j?C <• x x^ 1 l ' If, ^ x •o (U 4J x x 7n ™ h x^ x x, . . ..._. X X' 0 a. 0) k § 8 X ^ x .y, r1 JT : fin i i ' X X X V" •^ x X • „ so * • _ A x x • • •x X J* .... r 40 s / • f X > • x - , ! / . » _ . -,,r.i • O rt jU Jr s f 9s t^r— ^ / f ">0 AU —y£. ,f 10 0. 1— — . — £.— _ 7 x » = 7* 0 BEE 10110- 0 2.0 3b 4b 50 11 TCDD ad ied (PP ) f0 ' 56 d0 -33- I • /. �TCDD reported (ppt) ui to o O o O O CO o M O NJ o HS (D O £ ta 0 w P 10 H« | O JT* ^B fl> I 11 I : !'! i Tt !l! �Table C-12. Dioxin Phase II: Interlaboratory Quant itat ion Study Type of Sample: Human Milk + 1 standard Extraction Lab: JML; Method: 'Acid/base Quantitation Lab: Lab E Sample ID Study M-0. M-4 M-l M-4 M-9X \£«>Q rn*"*^j M-16 M-25 S-l PML Recov. Shipment AB HMT-3 AB -10 A2 -6 AD -4 AI • -9 AE -11 AF -2 AC -1AC -7 AG -5 AH -8 STD-1 -12 ci37(%) 100+ 66 95 64 100 100 77 100+ 100+ 100+ 100+ 100 TCDD Levels (ppt) Detection Reported Limit Avg Added 320 322 Avg. 320 322 0 0 0.2 0.5 0.8 1 4 9 .9 16 25 1 -35- 1.5 . 0.6 9 0 0.9 1.4 6 145.5 29 34 1.9 0.3 0.1 1 0.2 0.3 0.4 0.-6 3 1 2.1 2 0.2 �Figure C-12 .• Human Milk Samples Lab E (Avg. of 320, 322 m/e) O/ftf _. f. 120 / -/ Jr /— 110 f 100 f / . '. • i • . . \ f IA. "1 _r "** f f 90 A / / */ / f \\ f , 80 » 1 \ f . J f / / / f / > / r V f u 0 a. <u s-l § / 70 ,. A / a. a. s > _x / / x / ^ *• f / / f / / / 60 . f" A > / f f / f ' J jf ./ / / f 50 9^ f + , / • / 1 .^ 40 * r' X ' "fT _r y 30 J ^ r ./^ ,/ ^ ~MI ™ : * y^ X' . / / _ £ . A 20 .., X / . ._ /. f / ^ «*" _ — —^ 10 . ^ 1 : :/ / Z*= ^ aauiiolO 20 30 40 30 TCDD added (ppt) bU /u ou -36- / �TRBLE C-13. Types of "Valid" and "Erroneous" Values Reported for Spiked Samples Spiking Category Laboratory Report Sanrole Not Spiked S < DL I/ S >. DL 2/ not detected (nd) valid valid false nd (fnd) positive value False Positive (FP) false positive (fp) valid Sample Spiked I/ Spiking level less than the detection limit. 2/ Spiking level greater than or equal to the detection limit. -37- �TABLE C-14. Incidence of Reporting Errors—' for Standards Number of Measurements (n) and Errors, by Types Lab m/e A B B C D E ft 322 320 322 322 Avg: 320, 322 Totals: I/ Sample Not Spiked (n) FP (4) (4) 1 ll (4) \jj 0 (4) (0) (0) (16) 3 Sample Spiked Spike > 9 ppt Spike < 9 ppt (n) 1-P fnd. (n) fp fnd (3) (2) (2) ' (3) (0) 0 0 0 0 - (19) (19) (19) (19) (0) 0 0 0 0 0 0 (1) -(11) 0 0 (76) See Table C-13 for error definitions -38- (0) 0 0 0 0 0 0 0 - �TABLE C-15. I/ 2/ Incidence of Reporting Errors-' for Beef Fat Samples-^' Number of Measurements (n) and Errors, by Type Lab m/e A B 322 320 322 C 322, . C (NE)-' 322 D (NE) 320 D (NE) 322 D 320 D 322 E Sample Not Spiked (n) FP Sample Spiked Spike < 9 ppt Spike _> 9 ppt (n) fp fnd (n) fp fnd (4) (4) (4) (4) (2) (2) (2) (2) (2) (0) 2 3 4 0 0 1 1 1 0 - (3) (3) (3) (7) (2) (4) (0) 2 2 2 0 1 2 3 1 0 - (20) (6) 10 1 (18) (18) 7 6 (3) (3) (8) 0 0 0 0 0 0 0 • o 0 - (19) (19) (19) (19) (11) (14-) (13) (10) (8) (0) 0 0 0 0 0 1 1 2 0 - as 0 0 /2^ & 0 0 0 0 — Totals: Acid/base NE 0 0 :94; ;38; 2 2 I/ See Table C-13 for error definitions 2/ NE denotes neutral extraction; otherwise, acid/base cleanup utilized -39- 1 1 �TABLE C-16. Incidence of Reporting Errors^ for Human Milk Samples—' Number of Measurements (n) and Errors, by Types Lab m/e A 322 B 320 322 C D E Avg: 320, 322 Totals: Sample Not Spiked (n) FP Sample Spiked Spike < 9 PPt Spike > 9 PPt (n) fp fnd (n) fp fnd (3) (1) (3) (0) (0) (2) 3 2' 4 2 (12) 11 (4) (2) (4) (0) (0) 1 1 (5) 0 0 2 0 1 (12) 2 3 I/ See Table C-13 for error definitions 2/ All extractions utilized acid/base cleanup -40- (19) (11) (4) 0 0 0 0 (53) 0 (19) (0) (0) @ (} 0 0 0 �D. Statistical Analysis of Laboratory C Beef Fat and Standard Reports . For practicality, a detailed statistical analysis of analytical results is presented only for Laboratory C in order to determine the optimum known accuracy and precision that can currently be achieved in quantifying low ppt levels of TCDD in samples of the types analysed. (Complete statistical analyses of the results of other laboratories can be conducted if determined advisable.) Laboratory C quantified only stan- dards and beef fat samples; therefore, the exact reliability of the analytical method for human milk is currently speculative. Two types of upper and lower 95% confidence limits have been calculated for the regressions of reported values (Y) on spiking levels (X), as shown for standards iri"~Figure D-l and for beef fat in Figures D-2 and D-3. First are the 95% confidence limits for the line itself, as are graphed by the pairs of lines closest to the regression line in the above Figures. These limits are interpreted as follows: The true regression line (as would be determined if the experiment were repeated a countless number of times under the same conditions) lies within the confidence limits unless the test results are sufficiently unusual to be among those expected to occur less than 5% of the time. -41- �The second set of confidence limits, depicted by the pair of lines furthest from the regression line, predict the 95% confidence limits for the result of a single analysis at a particular spiking level. Interpretation is as follows: The result (reported value) of a single analysis of a standard or beef fat sample spiked at a given level can be predicted to fail between the 95% confidence lines unless the analytical result (which includes extraction as well as GC-MS quantitation) is one sufficiently unusual to be expected to occur approximately 5% of the time. In calculating the regression lines and confidence limits, values of "nd" have been excluded. For Lab C all spiking levels below 9 ppt were reported as nd, and therefore, the lower limit of quantitation in this study must be considered to fall somewhere between 5 and 9 ppt. Lab C gave no erroneous reports (i.e., no reports classified as FP, fp or fnd) for standards or for 5g beef fat samples when extraction utilized acid/base cleanup. The calculated regression line for standards lies very close to the theoretical line, the slope of 0.983 being essentially equal to the theoretical slope of 1 and any point on the line being from 1 to 2 ppt less than the spiking level (Figure D-l). The 95% confidence limits for a predicted result of a single analysis fall only 6 to 7 ppt above and below the regression line. Thus, accuracy can be expressed as a negative -42- �bias averaging about 2 ppt over the range of levels tested, and precision in terms of the confidence limits for the line and for predicted results of individual standards. There was no apparent tendency for increased variability among reported values at higher (or lower) spiking levels, i.e., variance about regression was apparently independent of the spiking level (See Table C-3 to compare values). The results of the beef fat analyses were slightly more variable than those for standards, as might be expected. In particular, one value was an apparent outlier (reported value 63 ppt; spiking level 25 ppt) and has been both excluded (Figure D-2) and included (Figure D-3) in calculations. The rationale for excluding the value is based on a discussion with the principal investigator at Lab C; he was reasonably certain that on-the-spot calculation of separate measurements of the same GC-MS run would have revealed a discrepancy and the sample would have been- rerun. Thus, exclusion of the value assumes a laboratory procedural modification to eliminate the possibility of reoccurance. value of the sample's duplicate was 24 ppt. The reported (A second sample—that spiked at 64 ppt—was originally reported as 32 ppt. Recalculation without'knowledge of the spiking level revealed an arithmetic error, resulting in a revised value of 58 ppt, which has been used in calculations.) -A3- �Figure D-l Standards Lab C (322 m/e) 130 ICO =i; Theoretical line, y»X Regression line: y * .98x - 1.30 3= SvEzS / \-f-—f 95% conf. limits for regression line^ 95% conf. limits for individual analyses 0. c. "3 4J 10 M o p. (U a, Q so •h _r ffSj _sjrs -H- ss • • -,*w/ s /* •* £' '• T* 10 0 U£ 10X1010 7o 3o TCDD added '(ppt) , -44- ,( i �Figure D— 2 Beef Fat Samples, Lab C (n- - 17): 5g, acid/base, .322 m/e * r 1 110 f 1_ Uheoretical line, Y » X •*•""" —^9r . Degression line, Y » 0.89X + 2.7 i— ^^s _____ 100 1 35% confidence limits: '"\ .; * ••• \ \ 1 a 70 2 \ \ \ • \ V \ \ \ \ • 60 g o \ . \\ st •••\ —• /* \ 1 -^ X/' f \ \ i1 /"' / \\ /' J / 'f ..? S S \ 1/-1* x x\ \ \\ // i / • / ; • \ \ st *&Ss ' ' £ S \\ \ St rS f / *•/* y i -1 y \ \\ 7 \,\i r~/ j^•>»7*-'- x — y << J•f -•/^ xy* x- >rir x X*l* X. 1 \ x >"^ 4C| s S S jJ J^> if X x x 30 ' / , *" >" J " X 7 IT X^ jff / X 'SSjj ^ -^ ^^^ J -X" ^ ^ s s •" -X T / f^ J^ ' J^J* •'''' _/* *" J^ ^ jfS - y* /" ^_r X J* 10 / s ^ / / j f f vtf vv s*j* ^ _. > ssss ,x ^ f f ,x ' -X" X X" s s s / X jf \- yT* N_ / S*^J • I — JX" ' ' 1 y ' >* )^ ' • S i V: Jr /' X s X X X S X"^ .V • X " . ——— X1 —-—-—-——— - > f S / S s / /— 0 .,1 r >—*^ j^ vS* y' S sTS/ X <yX X. s^i.- x x x i Ix ' * X X / ' y y. Xy • / S rS •• '*Xjf S xx^ .fxy\. x S ^v^y X X <i ' -^ X / X X -X" X _Je\_f y y}*y x ' Z>*X •y_>V V x yy«x y ,/H x*/rVr S S 20 X X r ^f J* S 'yxv^ >£ A 'sS S / s ^s s X Vi "S*f / s /S/,' •* / / f X i y' f\\S \1* XX X !X X / • V S / 1 x'' X X X \ —s r x / • x , J \ s r p r / f SI i x y"/1^ t V / _ > s s s ~~~ I s .s x\' % 's fs ^ ^ 50 X V \ \ \ X X "' X \ >\ > —y.^j...-^, X^ — \ X ' \S S S 4 \ X \\ '> f sir s s '' \ V \ : ^k -^ JL % —v \ S u s* o c« \ \ \ \ 1 \ \ 1 V V \ \ \ \ \\ \ \ \ . • \\ \ ^S. \\ ILL \\ V \ \ \ \ \ \\ \ \\ \ \ V \\ \ \ \ \ \ -\ individual samples • • \ ' \ ,•—s U Sw/ \ V 90 80 \ ^A.. regression line «*' """"•"••^ » ^s ^v\ — BEE 10X10 • 10 2'1 30 50 40 TCTD added (not) 60 70 1 - - .n-,.. 80 -45- J �D-3 Bee£- Fati Samples, I^ab c_(n^£)_- ; 5g, acid/base y . 322 We , .__. 110 100 Theoretical line: Y Regression line: Y - 0.84X 90 :x± '.1. 95% confidence limits: regression line individual samples 80 70 60 50 40 30 20 10 BEE 10X10 50 D added--(opt)- 60 -46- i �E. Estimation of Actual TCDD Levels, with Confidence Limits, from Spiking Results: Lab C .Using regression statistics developed from spiking study data, a "best estimate" of the "true" level of TCDD in an unspiked sample can be derived from the reported level, as well as statistical confidence limits for that estimate. The. procedure is that of estimating the value of the independent variable (X) for a measurement of the dependent . variable (Y), in this case the reported TCDD level in a sample. (The basic approach is used, for example, in estimating LD-Q'S in dose-response studies.) Confidence limits for such estimates tend to be broad relative to these for the regression line per se. Figures E-l and E-2 present estimated "true" values of TCDD A (X) for reported values (Y) ranging from approximately 9 to 80 ppt. In- both figures the reported values (Y) now appear on the horizontal axis and the estimated "true" values (X) on the vertical axis. The slope of the new line is the . reciprocal of the slope of the regression of Y on X. The new regression equations appear on the graphs. The 95% confidence limits for estimates of actual values range from 6 to 7 ppt above and below the predicted value - when the aberrant value of 63 ppt is eliminated from the -47- �calculations (Figure E-l) (see part D).~ When that value-is included, the confidence limits are about four times as wide (Figure E-2). For example, the estimated actual value for a reported value of 40 ppt is 42 ppt with 95% confidence limits of 35 to 49 ppt when the aberrant 63 ppt has been excluded from regression calculations. When included, the estimated true level for the same reported value (40 ppt) is 39 ppt with confidence limits of- 12 to 66 ppt. Again/ the essentiality of.developing procedures to detect and correct aberrant results at the onset is emphasized. The confidence limits presented in the above graph are for a single extraction and GC-MS quantitation of a sample. Confi- dence limits can be narrowed if 2 or more independent extractions and quantitations of the cause sample are performed and the reported values averaged. This approach may be of value in applied TCDD residue evaluations. -48- �Eigure E-l Estimated True TCDD Level in Beef Fat: Lab C. (From regression analysis of 17 spiked samples) 120 110 100^- —I 90 Q. O. Estimated true level: « 80 ^=t $ = (Y - 2 7 / . 9 ,.)08 —/—~\- 95% confidence limits for _ true level in 5g sample u 3 ^ H 4J CO =^r.^—.-i( =-.-yR=? W II > <X •-SE2 50 S^ 40 ^- 30 ^s. —y—!- 20 ^ ^r-^^ 10 r^: 3= : 0 vc 7 " Reported TCDD level (ppt) -49- �i X « Es timated true TCDD level (ppt) ! I •'• NJ O (-• 0 0 *• O j Ln> O | • i 0> Ui O ~J o ^ v OO o. o O o i i i i VO H o o . _ . i i H ID ^ i • 1 *V vl „ K O s i i !..;. i i ..oil"Y i i J i i i t i i i i i . i l ' V j s Q \ .-'• ' ID 1 1, - "V, ^ S ^ \ ^ « *- 4. - * 1 j 0 H : s {» « =• A-i s rt • > • . . . . ' - - \ s 1 3 t 1 -;;,.-• ,' • • • ^rs s I S ! X tJ ^ V, ' % 1• ' . !! ; . ' 1 : < 3i i i 1 • -i i «V _ L ! i _ i . . , ' j 1 ' "... o , i t i! ' l i J i j : Oi i ! ) / s : i ! ^Sfc '\ \ I) - \S l^^iis "^3 V > l '' :i ^ i__j t f rt tJ ^^ O HH> O ll > H £ ID H- ID CO K-> 00 ID If! »| - 0) CO H0 B (0 < l\l ,X ID ID WP. ID (0 Hi •d n1 !"*• '*J ID rt (X .. / (A CJ «"• 0 P) 4 ^T *CJ D* (D to O N^-- 1 ** w 'S. ^\ . t, •- ^ . s x O P1 s s . v 1 iJ-'T . |f 0 *» rt S K_ . . ..-• .JltL w * *i • < ^ jl M' \ - ' '' N "V - ^ ' ^^ ' i i ; ; i; . \ f*J^ S ' 1^ ^t^ i ' ! / i I 1 1 i: ; i - - - \ * * > . "Nj / iV i tj • 00 «1 (0 ^9 m < J HTh'x k i ! I . i g&- . . &. . " " " • fT l-« x. o *" R .jX ' ; i M — S ft s :.'. . '\\ \ s, i 1 ' . . : . ._SsV . • W ft H. ^ S' «o H3 < hi S" 8 Ol H« \s . ••...•• r >> Is a i: 2 ^ . ^ ffl 1 S. s V - -i- H ... X> f e «s ^ Ni V . 1 M ft tn H «» c \ cr s td to 1 ' *, i • i o a s 1 * s \ s . , �P. Discussion ' This study has demonstrated that for standards and spiked samples o£ beef fat, the extraction and quantitation methodology exist to quantify TCDD at levels as low as 9 ppt with practicable accuracy and precision. This conclusion assumes that extraction methods are exactly those used at PML and quantitation utilizes procedures and instrumentation indentical or equivalent to that of Lab C. Otherwise, practicable precision has not been fully demonstrated. The reliability of the above methodology for quantifying TCDD in human milk is yet to be determined. However, based on the fact that milk results are essentially as precise as those for beef fat among laboratories that performed both sets of analyses, a quantitation problem is not anticipated. None-the-less, the procedure needs to be verified with further testing. Lab C has indicated that their instrumentation may be capable of quantifying TCDD levels below 9 ppt in samples of the type used in the study. Reports of False Positives (positive TCDD values 'reported for unspiked samples) by laboratories other than Lab C may present a basic problem when attempting to quantify in the range of 0 to possibly 8 ppt. Additional analyses of spiked samples are necessary to determine if a quantification level below 9 ppt can be achieved. -51- � Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Alvin L. Young Collection on Agent Orange Description An account of the resource <p style="margin-top: -1em; line-height: 1.2em;">The Alvin L. Young Collection on Agent Orange comprises 120 linear feet and spans the late 1800s to 2005; however, the bulk of the coverage is from the 1960s to the 1980s and there are many undated items. The collection was donated to Special Collections of the National Agricultural Library in 1985 by Dr. Alvin L. Young (1942- ). Dr. Young developed the collection as he conducted extensive research on the military defoliant Agent Orange. The collection is in good condition and includes letters, memoranda, books, reports, press releases, journal and newspaper clippings, field logs and notebooks, newsletters, maps, booklets and pamphlets, photographs, memorabilia, and audiotapes of an interview with Dr. Young.</p> <p>For more about this collection, <a href="/exhibits/speccoll/exhibits/show/alvin-l--young-collection-on-a">view the Agent Orange Exhibit.</a></p> Text A resource consisting primarily of words for reading. Examples include books, letters, dissertations, poems, newspapers, articles, archives of mailing lists. Note that facsimiles or images of texts are still of the genre Text. Box The box containing the original item. 179 Folder The folder containing the original item. 5255 Series The series number of the original item. Series VIII Subseries I Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Creator An entity primarily responsible for making the resource Heath, Robert G. Description An account of the resource <strong>Corporate Author: </strong>Human Effects Monitoring Branch, Environmental protection Agency (EPA) Date A point or period of time associated with an event in the lifecycle of the resource January 5 1979 Title A name given to the resource Typescript: Interlaboratory Method Validation Study for Dioxin ao_seriesVIII Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Alvin L. Young Collection on Agent Orange Description An account of the resource <p style="margin-top: -1em; line-height: 1.2em;">The Alvin L. Young Collection on Agent Orange comprises 120 linear feet and spans the late 1800s to 2005; however, the bulk of the coverage is from the 1960s to the 1980s and there are many undated items. The collection was donated to Special Collections of the National Agricultural Library in 1985 by Dr. Alvin L. Young (1942- ). Dr. Young developed the collection as he conducted extensive research on the military defoliant Agent Orange. The collection is in good condition and includes letters, memoranda, books, reports, press releases, journal and newspaper clippings, field logs and notebooks, newsletters, maps, booklets and pamphlets, photographs, memorabilia, and audiotapes of an interview with Dr. Young.</p> <p>For more about this collection, <a href="/exhibits/speccoll/exhibits/show/alvin-l--young-collection-on-a">view the Agent Orange Exhibit.</a></p> Text A resource consisting primarily of words for reading. Examples include books, letters, dissertations, poems, newspapers, articles, archives of mailing lists. Note that facsimiles or images of texts are still of the genre Text. Box The box containing the original item. 193 Folder The folder containing the original item. 5460 Series The series number of the original item. Series VIII Subseries I Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Creator An entity primarily responsible for making the resource Hobson, Lawrence B. Description An account of the resource <strong>Corporate Author: </strong>Agent Orange Projects Office, VA Date A point or period of time associated with an event in the lifecycle of the resource February 14 1984 Title A name given to the resource Epidemiology of Soft-Tissue Sarcoma and Related Human Research with two addendum from December 5 and December 19, 1983, accompanied by memorandum from John H. Thompson, Deputy Assistant General Counsel, Veterans Administration to Alvin L. Young, Office of ao_seriesVIII https://www.nal.usda.gov/exhibits/speccoll/files/original/07193077e1fa3552067de709ff0a6c9b.pdf 714e0c582984d6d8e48b61c3e9fdf155 PDF Text Text Item D Number °5179 Author Holstun, J. T. D ^scanned Corporate Author ROpOrt/ArtiClB Title Typescript: Answers to "Statements of Issues" Journal/Book Title Year 000 ° Month/Day Color D Descripton Notes Friday, March 01, 2002 Page 5179 of 5263 �<r* 1» The ftocv«te%y of Agriculture «Ji4 not r®fw&» to siiKpetMi the stated »8 food cropfi for iwoaaa eoas»tp-tici» and »o»itqwl^ fowiwla the bane end in recreatttm iurea£;*«be decided tliat flw milder eour&e of action 0£ cancellation df fcc-^ie of tliefte uP.es 'bati:er sax-ved the best of tlMt g«n«ml public., H'n4 tibat it would Btoqustaly pi-otacfc tbe bft»t iat«rs»t« of «A<^ end every ittdli?Wual involved. H^ di«J saspesci otlisr tMMH»A not b®«attB© tihttflie otbftr «»«s i*ses«aC«<d a ttigulficaafc danger, but th« «3vitie«ce thut tliescs sus-peiKled ua«is vere K^fe waa not as that supporfcing tfe©- $af«ty of ths« c»»c&llfid «»©». Hife actions are supported subetsmfcijsl evidence on the record as a wboie* �2. The Seewsfewy1*! «etto« wa« wdfeher «rbitar«Ty BC« c«pri«i,ows. It aot SB abws© of 41S'G#a£i0nv «w* »*« uot «3©s» without a r*tt»iffll battle. I'iw-t,. aei&tttisfts «4vi««4 iilta that 2 f 4»5-T ted tarsfcagtaie «f£ecw on c«trt«i& trains of ««wll wileaca whttt tb» 2,4,5-T «ssa £«d 01- t»iij0ct«d sf large ito»g©s* text* fcM® flndiagtoa<Jto b6 swdllied wb«B it cie»ti«i:s fibst the 2,4,5-1' us«i for the t^lth « ^loKlw* t&inl^ gctdifcioxuti t<8M8£s V j^ to ,J Pk 't<^ its small £04«tnt&» b«t «p;pat«ntly 4-1^ eau»-a ;>uch Qf£ae-u In » fev ' /I -^~ tl*8 radasifc® iribaa fad at 4o®«§®» ef 100 Kig/fcg of ilv« W4S»ighc to # f it t«i«fc IM» rft<u>giDii««d fciwfc the ta Misl£tiiiae4 fet«s«s wer that wotil4 -toe t«i:l«i to ttis piregnani: sro<3e»t0. Msny the ©esenfclsl vifcamis A t «y* tutrae^genie «b®» adfaialsfceeed «uel> tostie &j«©g<as, FurKfearg it Iras 'b«is» ettisblltb©^ fche-t J)MSO» a «<arri«r to .edwt»isfcsri»g tha 2,4*5*1' iw «euw of She test*, t«- i» itself The naoii-t fchate e<»ttl4 fee t«gie»lly cottewd^ifi frost fcfets® 4«t« te tJw»t Z» co»,'fc«i«ittg fifi iw«li a« 27 p|« o£ dlostitt mi^it p'ir®,8*ist a faaisaird £0 However, Cliose »&ws> &*$•& also iiKiie«te th«t «ucit e batar4y aveti If it of in »«B«titivi! atagaii «£ p»ag»a«ey» to levels af 2,40S"f eoatalnittg fe*se0 iJtt»««fcte of r«s»t«s. 0» t^« otfe»r tend1* it is well n&t&^lisk&A tl»t Btegea of pr«g-»aaey £««s<-|«@»tly ladwc* one �chotaieais tjlilch has greatly incTOmMMi fiood firoductloxi throughout much v£ Sf*«! vox-Id, tltia JMI» not only taade cio.ye food ."Viiilsfele, fane te« helped to o«tke It flv«liable at n f£teft within tb«s reset* of rao#t hwtisae, The Secratuary'K decijsloa provided protecfci.on is those 4r««« where human es-q'oc-ure tt«s !«£«% imd pei'iaitteu the contiiauatiuiJ, for of tf&i«fcl,01 U«NH» of 2,f.4»5*t In aifewatlwie wlied^ efe»-w;ee of «tes»g* to htttwn fetal A w®t* «« *e«ofce that tib«y isould tw pufc l«to about tih«fi«eu»eafc«g0iy «s %»i^g e«t« % « tig«r on fehe plai»s of Kane-ss* 1S»i» aefelon p»evi4«s boftb «4®quett |j»ot«efci0tt Hor p«ofl@ and ti«g for �*»*« »t» qsT» p«>3»«BK»3f si p«wg« :j«»tip»t aw fiatt? 3:0 �5 4» ftoe SeeiN&fcatry tiid aofe fail to proptrfy «pply bis «wa &attot iwmaKi wfeait ha tisclded that tter« existed no serious emergency UMI «e* of 2t4»5-f <a» food crops. Mtero tturn 26 ,ywr» of injury to e 'husaaa I row eating food witliout one c«ee of is «apl« 0vid«]aco wf titee aouateiHis of tteelsion. ^it higfitipp&r&t/ngcvi.6emw is by vto ontm tctstrictctl to this u»iicieiat:tfiet but Sfcev&rtJt&Ms-a valid, ARS:CR:JTHolstun:dr 10-S 15-70 � Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Alvin L. Young Collection on Agent Orange Description An account of the resource <p style="margin-top: -1em; line-height: 1.2em;">The Alvin L. Young Collection on Agent Orange comprises 120 linear feet and spans the late 1800s to 2005; however, the bulk of the coverage is from the 1960s to the 1980s and there are many undated items. The collection was donated to Special Collections of the National Agricultural Library in 1985 by Dr. Alvin L. Young (1942- ). Dr. Young developed the collection as he conducted extensive research on the military defoliant Agent Orange. The collection is in good condition and includes letters, memoranda, books, reports, press releases, journal and newspaper clippings, field logs and notebooks, newsletters, maps, booklets and pamphlets, photographs, memorabilia, and audiotapes of an interview with Dr. Young.</p> <p>For more about this collection, <a href="/exhibits/speccoll/exhibits/show/alvin-l--young-collection-on-a">view the Agent Orange Exhibit.</a></p> Text A resource consisting primarily of words for reading. Examples include books, letters, dissertations, poems, newspapers, articles, archives of mailing lists. Note that facsimiles or images of texts are still of the genre Text. Box The box containing the original item. 176 Folder The folder containing the original item. 5179 Series The series number of the original item. Series VIII Subseries I Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Creator An entity primarily responsible for making the resource Holstun, J. T. Title A name given to the resource Typescript: Answers to "Statements of Issues" ao_seriesVIII Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Alvin L. Young Collection on Agent Orange Description An account of the resource <p style="margin-top: -1em; line-height: 1.2em;">The Alvin L. Young Collection on Agent Orange comprises 120 linear feet and spans the late 1800s to 2005; however, the bulk of the coverage is from the 1960s to the 1980s and there are many undated items. The collection was donated to Special Collections of the National Agricultural Library in 1985 by Dr. Alvin L. Young (1942- ). Dr. Young developed the collection as he conducted extensive research on the military defoliant Agent Orange. The collection is in good condition and includes letters, memoranda, books, reports, press releases, journal and newspaper clippings, field logs and notebooks, newsletters, maps, booklets and pamphlets, photographs, memorabilia, and audiotapes of an interview with Dr. Young.</p> <p>For more about this collection, <a href="/exhibits/speccoll/exhibits/show/alvin-l--young-collection-on-a">view the Agent Orange Exhibit.</a></p> Text A resource consisting primarily of words for reading. Examples include books, letters, dissertations, poems, newspapers, articles, archives of mailing lists. Note that facsimiles or images of texts are still of the genre Text. Box The box containing the original item. 176 Folder The folder containing the original item. 5187 Series The series number of the original item. Series VIII Subseries I Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Creator An entity primarily responsible for making the resource Honorof, Ida Title A name given to the resource Letter from Ida Honorof to William Ruckelshaus, April 22, 1973 ao_seriesVIII https://www.nal.usda.gov/exhibits/speccoll/files/original/e913fe547760a74923fb7ac1b363e1b6.pdf ca1d9b9c6b9980ae26899235309aacd5 PDF Text Text Rom D Number osssi Author D NotSBannBn- Houk, Vernon N. Corporate Author RODOrt/ArtlGlOTItlO Memorandum from Chair, Science Panel, Agent Orange Working Group, to Members, Science Panel, Agent Orange Working Group, Subject: Minutes of December 14 Meeting and Draft Memorandum to Chair, AOWG, dated December 17, 1981 Journal/Book Title Year 1981 Month/Day Color Number of Images D ° Descrlptoo Notes Tuesday, March 19, 2002 Page 5581 of 5611 �DEPARTMENT OF HEALTH & HUMAN SERVICES Date Public Health Service Centers for Disease Control .December 17, 1981 (404) 452-4111 FTS 236-4111 From Chair, Science Panel Agent Orange Working Group Subject Minutes of December 14 Meeting and Draft Memorandum to Chair, AOWG To Members, Science Panel Agent Orange Working Group Attached are the minutes, of the last meeting and a memorandum to the Chair, Agent Orange Working Group concerning the Wisconsin Mapping proposal. Please provide your feedback by January 14. The next meeting will be January 14, 1982, 9 a.m., in Room 729G of the Hubert Humphrey Building, Washington, DC. ernon N. Houk, M.D. 2 Attachments �DRAFT MINUTES OF THE SCIENCE PANEL AGENT ORANGE WORKING GROUP The Science Panel met on December 14. appended. A list of the attendees (Tab A) is The Science Panel notes with pleasure that Dr. Peter Greenwald, Director, Division of Resource Centers and Community Activities, National Cancer Institute, has been invited to membership on the Science Panel. Documents Distributed.to the Members; Texas State Veterans Agent Orange Act, H. B. No. 2129 (Tab B). Associated Press release on the State of Wisconsin veterans populations with alleged health effects of Agent Orange (Tab C). Jennifer A, Hanify, et al, "Aerial Spraying of 2,4,5-T and Human Birth Malformations: An Epidemiological Investigation," Science, Vol. 212, 17 April 1981 (Tab D). Kingsley M. Stevens, "Agent Orange Toxicity: Human Toxicology (1981), Vol. 1 (Tab E). A Quantitative Perspective," "The Public Health Conference on Records and Statistics, The People's Health: Facts, Figures, and the Future," DHEW Publication No. (PHS) 79-1214 (Tab F). Protocols Received Dr. Shelia K. Hoar, Environmental Epidemiology Branch, National Cancer Institute, submitted a research protocol, "A Case-Control Study of Lymphoma and Soft-Tissue Sarcoma: Association with Herbicide Exposures," to the Science Panel for review (Tab G). The Chair asked for individual comments by January 15, 1982. These comments will be consolidated and returned to Dr. Hoar. Agent Orange Troop Exposure and Non-Exposure Cohort Selection Concept Paper The Department of Defense transmitted on December 4, 1981, a proposed Agent Orange troop exposure and nonexposure cohort selection concept paper (Tab H). From this concept, DOD indicated that it would be possible to identify groups of personnel down to the platoon level who have had certain characteristics of exposure to Agent Orange. These would include being within a kilometer within 7 days of fixed wing herbicide spraying, stationed in base camps with perimeter spraying, being associated with the so-called "aborted missions," etc. Other groups could be identified who would not have any of the above characteristics. An additional group could be identified from serving in the same time frame in southern continental United States bases where no herbicides were used. These groups could then be the basis of the VA Morbidity Study. The DOD was aksed to provide and report more specific details in the next meeting on January 14, 1982, �Wisconsin Proposal for HERBS Tapes Data for Mapping At a previous meeting the proposal from Wisconsin to the Veterans Administration to develop detailed, accurate, and reliable map series or atlas based on the HERBS tape data depicting the dates and locations of herbicide spraying missions conducted in the Republic of South Vietnam had been distributed and comments requested. In general, it was felt that to be useful, the maps should be accurate and reliable. Because they would not include information on base perimeter spraying and the so called "aborted missions," it was felt they would not be scientifically useful since they would be incomplete. Using the data on the HERBS tapes alone would require mapping on a 1:50,000 scale and would require approximately 1500 maps. The Chair will develop recommendations to the Agent Orange Working Group that contains the consensus of the entire Science Panel to be delivered to the Agent Orange Working Group at its next meeting in January. Veterans Administration MortalityJ5tudy_ The preliminary protocol for the Vietnam veterans study was again discussed. Serious concerns were raised the accuracy of the DOD computerized records that are being proposed for this study. The Science Panel members had divergent views on whether the study should be of the total Vietnam veterans death records or whether sample techniques could be used. A subcommittee was formed to review this matter and make recommendations to the Science Panel at the next meeting on January 14. The subcommittee to be chaired by Dr. Kimbrough also includes Drs. Greenwald, Keller, Brown, and Shepard. Dr. Greenwald also discussed the Upstate New York Mortality Study. Vernon N. Houk, M.D. Chair, Science Panel Agent Orange Working Group �DRAFT 12/17/81 FROM: Chair, Science Panel Agent Orange Working Group SUBJECT: TO: Wisconsin Proposal for HERBS Tapes Data for Mapping Mr. James Stockdale Chair, Agent Orange Working Group At a previous meeting the proposal from Wisconsin to the Veterans Administration to develop a detailed, accurate, and reliable map series or atlas based on the HERBS tape data depicting the dates and locations of herbicide spraying missions conducted in the Republic of South Vietnam had been distributed and comments requested (Tab A). The following is a consensus recommendation to you from the Science Panel. If you concur, we recommend it be forwarded to the Veterans Administration. While the Science Panel agrees in principle that detailed maps could be made available to others for the purpose of determining exposure to Agent Orange in Vietnam, we have serious reservation because it is unlikely that they would be sufficiently accurate to determine proximity to exposure in all instances. A mapping of only the HERBS tapes locations would require from 1,200 to 2,000 maps on a minimum scale of 1:50,000. There are sufficient errors on the HERBS tapes that would not allow exact locations of all fixed wing spraying missions. In addition, very few of probably hundreds of helicopter spraying missions around fire bases, along roads, lines of communications, and along rivers are documented in the HERBS tapes. �Similarly, perimeter spraying from trucks and by backpack sprayers could not be adequately documented. While we agree in principle that we should make everything available, it is our consensus that if. the maps are inaccurate and so voluminous as not to be useable that they in fact will do a disservice. One can argue that detailing the limitations of the maps is an approach to being able to provide them. It is our experience that those caveats are not always recognized and the maps are used as "gospel" without full understanding of their limitations. This would also be costly and would not successfully compete for the scarce resource dollars available for health studies. Thus, there are public relations reasons for approving this proposal but scientific reasons for not doing so. and usefulness. Those scientific reasons are accuracy The Science Panel would recommend at this time that the Veterans Administration be advised not: to financially support such a project. Vernon N. Houk, M.D. � Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Alvin L. Young Collection on Agent Orange Description An account of the resource <p style="margin-top: -1em; line-height: 1.2em;">The Alvin L. Young Collection on Agent Orange comprises 120 linear feet and spans the late 1800s to 2005; however, the bulk of the coverage is from the 1960s to the 1980s and there are many undated items. The collection was donated to Special Collections of the National Agricultural Library in 1985 by Dr. Alvin L. Young (1942- ). Dr. Young developed the collection as he conducted extensive research on the military defoliant Agent Orange. The collection is in good condition and includes letters, memoranda, books, reports, press releases, journal and newspaper clippings, field logs and notebooks, newsletters, maps, booklets and pamphlets, photographs, memorabilia, and audiotapes of an interview with Dr. Young.</p> <p>For more about this collection, <a href="/exhibits/speccoll/exhibits/show/alvin-l--young-collection-on-a">view the Agent Orange Exhibit.</a></p> Text A resource consisting primarily of words for reading. Examples include books, letters, dissertations, poems, newspapers, articles, archives of mailing lists. Note that facsimiles or images of texts are still of the genre Text. Box The box containing the original item. 198 Folder The folder containing the original item. 5581 Series The series number of the original item. Series VIII Subseries II Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Creator An entity primarily responsible for making the resource Houk, Vernon N. Date A point or period of time associated with an event in the lifecycle of the resource 1981 Title A name given to the resource Memorandum from Chair, Science Panel, Agent Orange Working Group, to Members, Science Panel, Agent Orange Working Group, Subject: Minutes of December 14 Meeting and Draft Memorandum to Chair, AOWG, dated December 17, 1981 ao_seriesVIII https://www.nal.usda.gov/exhibits/speccoll/files/original/4dde28725097f18152b8d6f2e8cba29b.pdf 9e07b829ff30f8cdbab8357f68d5fea9 PDF Text Text item D Number 05534 Author G Not Scanned Houk, Vernon N. Corporate Author Report/Article Tltlfl Memorandum from Chair, Science Panel, Agent Orange Working Group, to Members, Science Panel, Agent Orange Working Group, Subject: Minutes of January 27 Meeting, dated February 2, 1982 Journal/Book Title Year 1982 Month/Day Color Number of Images D 3 Tuesday, March 19, 2002 Page 5584 of 5611 �DEPARTMENT OF HEALTH & HUMAN SERVICES Public Health Service Centers for Disease Control Memorandum Date From February 2, 1982 Chair, Science Panel Agent Orange Working Group Subject Science Panel Meeting Minutes To Members, Science Panel Attached are the minutes of the last Science Panel meeting. Please return your comments to me by February 16 so that I may finalize the comments. Vernon N. Houk, M.D. Attachment �MINUTES OF THE SCIENCE PANEL AGENT ORANGE WORKING GROUP The Science Panel met on January 27, 1982. is appended. ' A list of the attendees (Tab A) ' Status of Fat Biopsies i The Chairman of the Fat Biopsy Subcommittee reported that the Subcommittee is developing a report to the Science Panel on fat biopsies for dioxins that will include information on (a) what is currently known and the current status, (b) when we would recommend it be done and under what circumstances, and (c) its limitations. It is anticipated that this report will be available within 6 weeks. Protocol Review The Science Panel completed its review of the National Cancer Institute (NCI) "A Case-Control Study of Lymphoma and Soft-Tissue Sarcoma: Association with Herbicide Exposures." It was agreed that the individual reviews will be returned to NCI. In general, the Science Panel was supportive of the proposal, and several agencies offered to help provide specific information. We further noted that this study should be complementary to the NIOSH proposed case control study on soft tissue sarcoma. The two studies are not exclusive of one another. Veterans Administration Mortality Study The Chairman of the Subcommittee reviewing the VA Mortality Study reported to the Science Panel. There was "considerable discussion about the proposed study's ability to answer the question. Most but not all members feel that a proportional mortality study of all of the death certificates may be desired. Though the BIRLS tapes data are generally considered to be accurate and complete, there is question about the accuracy and completeness of the proposed Department of Defense (DOD) tapes that are going to be used for matching data. The Science Panel requested the subcommittee continue its work and report within 6 weeks on various options and resource requirements for each option to address this issue. The VA provided information (Tab B) on the numbers of individuals involved for the proposal as it was submitted. Agent Orange Troop Exposure and Non-Exposure Cohort Selection Concept Paper The DOD'provided further details (Tab C). It is agreed that it is possible to develop cohorts of exposed and nonexposed units. It is anticipated that the Science Panel will recommend to the Agent Orange Working Group that a letter detailing the proposal and requesting that it be completed be sent from Secretary Schweiker to Secretary Weinberger. In addition, a review of the disposal of herbicide waste and a trip report by the DOD assessing the herbicide usage in Vietnam were made available to the Science Panel (Tab D). �Assessment of Agent Orange Health Hazards Among the Vietnam Population Recent press reports of a group returning from Vietnam indicated that the Government of Vietnam would welcome assessment of the health risks in the Vietnam population by American scientists. There is concern about the status : of the records and the availability of those records in Vietnam. Dr. T. E. Woodward, VA distinguished physician, reported that he found the records to be useful. There was general agreement that a study would be difficult to do and difficult to interpret. The members of the Science Panel were asked to provide written comments to the Chair within 2 weeks. A concensus document will then be developed for transmission to the Agent Orange Working Group. Health Problems of U.S. Military Veterans and Possible Exposure to Phenoxy Acid Herbicides in Vietnam: Partial Coding and Statistical Analysis of the Citizen Soldier Health Questionnaire (CSHQ) Dr. John Moore made available to the Science Panel the final report to the National Toxicology Program of the statistical analysis by Dr. James H. Dwyer and Mr. Robert Smith of the New York State University at Stony Brook (Tab E). Public Information A member of the Science Panel expressed concern that the public does not have information available to counter some of the claims of adverse health effects which are not yet proven. There was general discussion of this topic. Most members feel that there is insufficient data to make firm statements on these issues at the moment. It was* noted that the Scientific Panel under the direction of Dr. John Moore prepared such a document that was released at the public meeting of the Agent Orange Working Group held in September 1980. A copy of that document will be reviewed to determine if any additional information is available. The members of the Science Panel were asked to communicate their thoughts in writing to the Chair, and this will be discussed further. Vernon N. Houk, M.D. Chair, Science Panel Agent Orange Working Group � Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Alvin L. Young Collection on Agent Orange Description An account of the resource <p style="margin-top: -1em; line-height: 1.2em;">The Alvin L. Young Collection on Agent Orange comprises 120 linear feet and spans the late 1800s to 2005; however, the bulk of the coverage is from the 1960s to the 1980s and there are many undated items. The collection was donated to Special Collections of the National Agricultural Library in 1985 by Dr. Alvin L. Young (1942- ). Dr. Young developed the collection as he conducted extensive research on the military defoliant Agent Orange. The collection is in good condition and includes letters, memoranda, books, reports, press releases, journal and newspaper clippings, field logs and notebooks, newsletters, maps, booklets and pamphlets, photographs, memorabilia, and audiotapes of an interview with Dr. Young.</p> <p>For more about this collection, <a href="/exhibits/speccoll/exhibits/show/alvin-l--young-collection-on-a">view the Agent Orange Exhibit.</a></p> Text A resource consisting primarily of words for reading. Examples include books, letters, dissertations, poems, newspapers, articles, archives of mailing lists. Note that facsimiles or images of texts are still of the genre Text. Box The box containing the original item. 198 Folder The folder containing the original item. 5584 Series The series number of the original item. Series VIII Subseries II Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Creator An entity primarily responsible for making the resource Houk, Vernon N. Date A point or period of time associated with an event in the lifecycle of the resource 1982 Title A name given to the resource Memorandum from Chair, Science Panel, Agent Orange Working Group, to Members, Science Panel, Agent Orange Working Group, Subject: Minutes of January 27 Meeting, dated February 2, 1982 ao_seriesVIII https://www.nal.usda.gov/exhibits/speccoll/files/original/f5622d5af3de69e74c6be5bafafce4f8.pdf 60c527070e23186ef0e347cf44febd78 PDF Text Text Item D Number °5588 D Not Scanned Houk, Vernon N. Corporate Author Roport/Artldo TitlB RePort of Science Panel to the Agent Orange Working Group with Science Panel Review of Proposed Protocol Design for Veterans Administration Epidemiology Study, dated March 5, 1982 Journal/Book Title Year 1982 Month/Day Color Number of Images D 6 Doscripton Notes Tuesday, March 19, 2002 Page 5588 of 5611 �REPORT OF SCIENCE PANEL TO THE AGENT ORANGE WORKING GROUP There have been several meetings of the Science Panel since my last report. Protocol Review The Science Panel completed its review of the National Cancer Institute (NCI) "A Case-Control Study of Lymphoma and Soft-Tissue Sarcoma: Association with Herbicide Exposures." It was agreed that the individual reviews will be returned to NCI. In general, the Science Panel was supportive of the proposal, and several agencies offered to help provide specific information. We further noted that this study should be complementary to the NIOSH proposed case control study on soft tissue sarcoma. The two studies are not exclusive of one another. Status of Fat Biopsies The Chairman of the Fat Biopsy Subcommittee reported that the Subcommittee is developing a report to the Science Panel on fat biopsies for dioxins that will include information on (a) what is currently known and the current status, (b) when we would recommend it be done and under what circumstances, and (c) its limitations. It is anticipated that this report will be available in the near future. Assessment of Agent Orange Health Hazards in the Population in Vietnam Recent press reports of a group returning from Vietnam indicated that the Government of Vietnam would welcome assessment of the health risks in the Vietnam population by American scientists. There is concern about the status of the records and the availability of those records in Vietnam. Dr. T. E. Woodward, VA distinguished physician, reported that he found the records to be useful. There was general agreement that a study would be difficult to do and difficult to interpret. We believe that assessing exposure would be virtually impossible. Public Information A member of the Science Panel expressed concern that the public does not have information available to counter some of the claims of adverse health effects which are not yet proven. There was general discussion of this topic. Most members feel that there is insufficient data to make firm statements on these issues at the moment. The Veterans Administration Mortality Study The Subcommittee reviewing the proposed Veterans Administration Mortality Study has reached consensus on recommendations to be made to the Veterans Administration. These will be forthcoming to the Chair, Agent Orange Working Group within the next 2 weeks. �Review of the Veterans Administration Epidemiology Study The Science Panel concluded its review of the Veterans Administration Epidemiology Study proposed protocol from the University of California at Los Angeles. A detailed review has been submitted to the Chair, Agent Orange Working Group for transmittal to the Veterans Administration. In summary, on the basis of the present document, the panel believes it is possible to begin the pilot phase of the study. The selection of the cohort for the Pilot Study should immediately proceed as well as the quality control and quality assurance procedures, the redesign of the questionnaire, and the determination of comparability and interpretation of some of the proposed instruments, such as nerve conduction studies, spirometry, etc., between examining centers. Finally, we believe that major progress has been made in the past several months and that it is now possible to do the Veterans Administration Epidemiology Study, looking not only at Vietnam exposure but exposure to Agent Orange. We view as the only remaining factors that will prevent the successful completion of this study to be the degree of participation among the selected veterans and the nonavailability of necessary resources. Vernon N. Houk, M.D. Chair, Science Panel Agent Orange Working Group 3/5/82 �AGENT ORANGE WORKING GROUP SCIENCE PANEL REVIEW OF PROPOSED PROTOCOL DESIGN FOR VETERANS ADMINISTRATION EPIDEMIOLOGY STUDY By School of Public Health University of California at Los Angeles The following represents a consensus of the reviewers of the proposed protocol design. All reviewers were present except one and his detailed comments were made available to the other members. The individual comments are enclosed (Tab B). Overall Design We agree that the historical cohort approach is the appropriate one. One member suggested more consideration be given to a case control approach but all other reviewers felt this is not possible because there is no clear cut definition of a "case." We also agree with the approach to try to make it as compatible as possible with other large studies such as the Ranch Hand and the Australian Study. COHORT Selection The panel unanimously agrees that the Department of Defense (DOD) should select the cohorts in accordance with Dr. Bricker's cohort selection paper (Tab A). This will provide, we believe, for elimination of as much misclassification as is possible from the existing or potentially reconstructable records. We believe it is absolutely essential that the identification and assignment of these individuals to the different cohorts not be available to the participants or to the investigators until initial analysis of the data is completed. The Science Panel will oversee this cohort selection process. The study investigators must be aware of the method used to select the cohorts but must not be aware of the individuals placed in each group. Criteria For Each Group We recommend that groups be composed of high probability of exposed Vietnam veterans, high probability of nonexposed Vietnam veterans, and a non-Southeast Asia veterans group. Some felt that it would be desirable to include a Vietnam veterans group exposed midway between the first and second groups in order to make an assessment of dose response. The consensus is that though this may be desirable, the inclusion of the fourth group is not essential nor critical to the study. Sample Size We agree that 6,000 in each cohort group is a reasonable figure. As the study progresses and as more information becomes available from other studies, this issue may need to be reexamined. DOD anticipates being able to provide 12,000 in each of the study groups for selection. �Proposed Exclusions from the Cohort Group We believe it is unreasonable to exclude officers and multi-tour Vietnam veterans. These may be separately identified so that appropriate analysis can take place but they should not be excluded from the study. QUESTIONNAIRE Questionnaire to Personal Health Providers of the Individual Veterans Some of the selected veterans may have had multiple health care providers since returning from Vietnam. The panel doubts that many private physicians will fill out detailed questionnaires on their patients and thus wonder about the usefulness of this part of the study. The needed information may have to be obtained in other ways. Individual Veteran Questionnaire The questionnaire as it now exists is unacceptable. It is overly long and uses highly technical terminology which many people including many physicians will not understand. We recommend that careful thought be given to the information that is needed to be gathered, who will administer and where the questionnaire will be administered (telephone, home visits, etc.), and that the questionnaire be redesigned to meet those criteria. The questionnaire should be limited to information that is critical to the study and that will be used in the analysis of the results. Other Instruments The psychological and neuropsychological instruments, all of which were not available for review, should be evaluated and should include only information that will be used in the analysis of the results and presented in a way that would not be offensive to the participants. Physical Examination Data collected from the physical examination should be limited to those items that will be used in the analysis of the study. This does not mean that the physcial examination should not be comprehensive as determined by the examining physician for the particular individual, although items to be used for analysis of results must be collected according to a standard protocol. Laboratory The final decision for the inclusion of laboratory tests for this study should be made after consultation with laboratory scientists to ensure that the best tests for that particular purpose are being used. There are other tests such as chest x-ray, spirometry, nerve conduction tests, etc., that probably have limited usefulness because of the inability to standardize and to intrepret between multiple examining centers. �It is critical that the standardization of laboratory procedures proceed with quality control and quality assurance for collection, transportation, handling, and analysis and that this process be begun immediately in the participating laboratories. Other Areas of Concern For all participants, the panel believes that information should be collected only on those items that are critical to the study, can be standardized, and are such to appropriately interpret between multiple examining centers and laboratories. If the practising physician feels that additional information is necessary for a particular patient to evaluate the health status, it obviously should be done but should not be part of the overall data collection and analysis for the purposes of this study. It is not clear from the proposed protocol the duration of the overall study or time estimates for each individual participant. These should be determined. A possibility that should be considered in regard to future duration is that after completion of the initial examination and analysis, the cohorts names be matched against the National Center for Health Statistics (NCHS) Annual Mortality Index. This would provide nearly all of the necessary followup information and would be more efficient than a mail survey or a hands-on followup of each individual. It should be explicitly stated in the final design that when an abnormality for an individual is found, how that abnormality will be followed, who will follow and treat it, and what system will be set in place to ensure that each individual will receive the necessary medical care. After the initial analysis has been completed and depending upon the results, additional well focused, smaller studies, such as specific case control studies, may be necessary to further define the extent of possible uncovered problems. After the initial analysis has been completed, the method of cohort selection should be made public. While still ensuring individual confidentiality, each participating veteran should be informed of his or her status in the cohort selection process. The panel assumes that the final protocol will address the usual concerns of patient confidentiality, freedom to withdraw from the study, and methods of providing the individual veteran specific medical information of which he or she or his or her physician should be aware for the proper care of the individual veteran. Pilot Study We believe the Pilot Study should include 5 percent of the anticipated study population. We recognize it may not be possible that this be a random sample of the population but that it be clearly stated and understood what that 5 percent represents. The panel unanimously disagrees that the Pilot Study should take place in only one study site but recommends strongly that it be conducted in all examination centers and study sites that will �be used in the overall study. The Pilot Study should be used to determine participation rates and to further refine the instruments to be used in this study. An analysis of the results of the pilot study can be used to make a determination of the possibility of success of the larger study. The results should in no way be interpreted as to effects but only whether it is possible to conduct a scientifically valid overall study. Summary On the basis of the present document, the panel believes it is possible to begin the pilot phase of the study. The selection of the cohort for the Pilot Study should immediately proceed as well as the quality control and quality assurance procedures, the redesign of the questionnaire, and the determination of comparability and interpretation of some of the proposed instruments, such as nerve conduction studies, spirometry, etc., between examining centers. Finally, we believe that major progress has been made in the past several months and that it is now possible to do the Veterans Administration Epidemiology Study, looking not only at Vietnam exposure but exposure to Agent Orange. We view as the only remaining factors that will prevent the successful completion of this study to be the degree of participation among the selected veterans and the nonavailability of necessary resources. � Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Alvin L. Young Collection on Agent Orange Description An account of the resource <p style="margin-top: -1em; line-height: 1.2em;">The Alvin L. Young Collection on Agent Orange comprises 120 linear feet and spans the late 1800s to 2005; however, the bulk of the coverage is from the 1960s to the 1980s and there are many undated items. The collection was donated to Special Collections of the National Agricultural Library in 1985 by Dr. Alvin L. Young (1942- ). Dr. Young developed the collection as he conducted extensive research on the military defoliant Agent Orange. The collection is in good condition and includes letters, memoranda, books, reports, press releases, journal and newspaper clippings, field logs and notebooks, newsletters, maps, booklets and pamphlets, photographs, memorabilia, and audiotapes of an interview with Dr. Young.</p> <p>For more about this collection, <a href="/exhibits/speccoll/exhibits/show/alvin-l--young-collection-on-a">view the Agent Orange Exhibit.</a></p> Text A resource consisting primarily of words for reading. Examples include books, letters, dissertations, poems, newspapers, articles, archives of mailing lists. Note that facsimiles or images of texts are still of the genre Text. Box The box containing the original item. 198 Folder The folder containing the original item. 5588 Series The series number of the original item. Series VIII Subseries II Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Creator An entity primarily responsible for making the resource Houk, Vernon N. Date A point or period of time associated with an event in the lifecycle of the resource 1982 Title A name given to the resource Report of Science Panel to the Agent Orange Working Group with Science Panel Review of Proposed Protocol Design for Veterans Administration Epidemiology Study, dated March 5, 1982 ao_seriesVIII https://www.nal.usda.gov/exhibits/speccoll/files/original/10eea2c0364e48b0bf2860dc6f33bfee.pdf 31dc8cef6632c1f2bfc5929419f76254 PDF Text Text ItemDNumber NotScaniwd Author Huddle, F. P. Corporate Author Science Policy Research Division, Legislative Referenc RODOPt/ArtiClB TltlO A Technology Assessment of the Vietnam Defoliant Matter, A Case History: Report to the Subcommittee on Science, Research, and Development of the Committee on Science and Astronautics, U. S. House of Representatives, Ninety-First Congress, First Session Journal/Book Title Year Month/Day Color Number of Images Augusts D o Friday, March 01, 2002 Page 5167 of 5263 �ALV1N L. YOUNG, Major, USAF 'Consultant, Environmental Sciences V'" fllVFM I- iYCUNQ [COMMITTEE PKIHT] - A .'TECHNOLOGY ASSESSMENT oi' run ~ VIETNAM 'DEFOLIANT MATTER A CASE HISTORY.. REPORT ~ TO THK .'.SUBCOMMITTEE ON'SCIENCE, RESEARCH, AND •"•'•• •-''• •'••••"'• :;:.":" DEVELOPMENT ' • OF THE . . . . .. COMMITTEE QN SCIENCE AND ASTRONAUTICS "^ U.S. HOUSE OF REPRESENTATIVES NINETY-FIRST CONGRESS FIRST SESSION / • '• PREPARED BV THF, ' SCIENCE POLICY EBSEA-RCH DIVISION >.---v/:i?- •"*-" " LEGISLATIVE REFERENCE SERVICE --j.-'cV"--""-!-?-.- - • 'LIBRARY OF CONGRESS] '* -- *: " ' " Serial P . • AUGUST 8, iSGO • Printed for thetise of the Committee on Science arid Astronautics •"''* :\ ~-l:-l-*."l- *-:. "".'- XT.S-.GOVERNMENT PRINTING OFFICE >!Q �n5B; < COMMITTEE OX SCIENCE AND ASTRONAUTICS LETTER OF TRANSMITTAL OEOUOE P. MILLE U, California. Chairman X K. TEAGUK, Tcias JAMES O. FULTON, Kl'H K. KAIiTJI, J.£l»nesota CHARLEij A. MOSHKR, Ohio < JIKCHLEK, West Virginia RICHARD I/. ROUDEBUSII. Indiana ;r.ro Q. DAUOAIUO. Connecticut ALPIION/,0 BELL, California !>• W. DAVIS. Geort-la THOMAS M. PELLY, Washington ,'MAS N. DOWNING, Virginia JOHN W. WYDLKK, New York : I). WAGGONNEK. JB., Louisiana GUY VANUEK JAGT, Michigan .' 1'L'QUA. Kiori-Ja LAIUtY WINN, JR., Kansas >i'.GE K. BROWN, JR., California ' JKRKY L. PETTI3, Cnllfornla :I.E CABELL. Texas D. K. (BUZ) LUKENS, Ohio :TI;AM L. PODELL, NCT York ROBERT PRICE!, Texas I'NE N. ASP1NALL, Colorado LOWELL P. WEICKEK, JR., Connecticut ' A. TAYLOn, North Carolina LOUIS KKEY, JR., Florida ;i(Y HULSTOSKI, New Jersey BARRY M. GOLDWATER, Jr.., CaUfonaSa lIOBIAGGI. New Tor!: ivS W. SYMINGTON, Missouri , - ARD I. KOCU, New York . CHAELICS F. DUCANDER, £zpcutive D tree tor and Chief Counsel JOHN A. CARSTAUPUKN, Jr., CA'e/ Clcrft and Counsel PHJLIPB. TEAQEE, Counsel FKA.NK R. HAMMIW,, Jr., Counsel Vf. H. BOONE, rec/micol Cons«!!ant JAMES E. WILSON, Technical Connultant RICIIABDP. HI.NES, Staff Consultant' \ ' HAROI-D A. Gour.n, Technical Consultant -. PHILIP P. DICKINSON, Technical Consultant " '" WILLIASI G, WELLS, Jr., Technical Consultant JOSEPH M. FELTO.V, Counsel . K. GCILD NICHOLS, Jr., Staff Consultant ELIZABKTU S. KEKNAN, Scientific Research Aseittant FRANK J. GIROOX, Clerk DE.VJS C. QOIOLET, Publication} Clerk ' . K. SHCLLAW, Aeslslant Publications Clerk JAM EH A. Ross, Jr., Minority Staff SUBCOMMITTEE ON SCIENCE, RESEARCH, AND DEVELOPMENT EMILIO Q. DADDARIO, Connecticut, Chairman "• W. DAVIS, Georgia ALPIIONZO BELL, California 3. WAGGONNEU, JR., Louisiana CIIARLKS A. MOSIIEK, Olilo iVR K. BKOWN, Jd.. California ' D. E. ( B U Z ) LUKENS, Ohio ,K CAHKLL. TPIUS :KAM L. POL-ELL, New York ..>W, SYMINGTON, Missouri . LARKY WINX, JK., KHIIMM JERRY L. PUTT-IS, California ' ', • . • ' . • • ' • HOUSE OF KEI'RK?EN'TATI\XS. Coanirrm: ox SCIF.XCKAXD ASTRONAUTICS, " . ' . . • ' • . . , « Washington, D.C., Augusts, 1969. Hon. GEORGE P. MILLER, - . . t Chairman, Committee on Science and Astronautics, House of Refn^esentatvues, "Washington, D.C. DEAR MR. CHABOIAX: The Subcommittee on Science, Research, and Development is carrying on a continuous study of technology assessment—seeking the best means of providing for the Congress an early, warning of the unanticipated hazards or benefits from applications of science. » . ' Tho process of technology assessment can best be seen -with reference - to historical episodes, but the record of such episodes is often incomplete! If we are to&ecure a. useful working knowledge of the elements oif the process, it is expedient for us to take opportunities to observe .closely those episodes which chance makes accessible. It was for this reason that the subcommittee commissioned the study "Technical Information for Congress" by the"Science Policy Research .Division—A -documentation-of 14 important case histories'which-had attracted, con-gressional attention since World War II. This report is a 15th case history. It has special significance for Congress in. the technology assessment context, since it represents a conflict which is current but which has developed a sufficient history .to give it perspective and meaning. It is distinguished from the other case histories in that the assessment was performed by the scientific community itself, and outside of the Halls of Congress. We are'dealing here with the controversy over the military uso of chemical defoliants and herbicides in Vietnam. The issue contains all . the elements that complicate such assessments: a difficult problem of ecological impact, clouded by the political controversy surrounding the Vietnamese conflict it.«e-l f." The report transmitted herewith does not address itself to the merits of the issue; .it does not judge the propriety or impropriety of the military use of herbicides. Instead, it centers upon the- process by .which tho American Association for tho Advancement, of Science undertook to assess tho ecological effects of the military use of chemical defoliants -and herbicides in a zone, of activity. The cooperation of the .participants in tho assessment was, of course, indispensable to the study, and wo were most fortunate that they fully appreciated the professional nature of tho proposed inquiry and were unstinting in providing the documentation for it. At my dmv( ion, the Legislat i ve- Reference Service secured the status of observer to tho prom'ilings..Frwu this vantage, point tho study is • ' . - ' • ' ' . i tin �ssessment in a ^^HFuit can guide similar projects in the future. It ,-ill aid tho variora^roups who are developing'teclmology assessment apabilities for the legislative branch, and in other institutions. Sincerely yours, , . . . ' ' • • EMIUO Q. DADDARIO\, • kairrnan, Subcommittee on Science, Research, awl Development. LETTER OP SUBMITTAL ''•-.-. . ' T H E LIBRAKY o r CONORKSS, •LEGISLATIVE EEI-TREKCE SERVICE, ' ' Washington, D.C., July 30,19G3. ' •' Hon. EMILIO Q. DADDAIUO, Chairman, Subcommittee 'on Science, Research, and Development, Committee on Science and Astronautics, House of Rcprcsenta-' fives, Washington, D.C. . • •DEAR MR. DADOAIUO: The report submitted with this letter results from arrangements made at your direction to follow the prepress of the American Association for the Advancement of Science in its investigation of'the environmental effects of defoliation in Vietnam. Mr. Richard A. Carpenter, Assistant Chief of our Science Policy ll^carch Division, sought permission from the major participating organizations in early 19G7,for LRS to act as an observer of the a^'.-^ment process as it took f^lace. In this way, the problems and successes of assessment methodology could be more accurately ascertained than by the usual ex post facto examination. Wo, of course, made it clear to all parties that the LRS had no interest in the defoliation-ecology question itself but only in how the assessment was.car.ricd out. '." 'The cooperation of-the following persons and their associates made .the report possible: . . ' Don K. Price, dean, John Fitzgerald Kennedy School .of Government, Harvard University. ' • . Dr. Dael Wolfle, American" Association for the Advancement- of Science.' ' ..- • •. Rodney W.. Nichols, Office of the Director of Defense, Ucsearcli and Engineering. Dr. William B. House, Midwest Research Institute. John S. Coloman, Xntiona'l Academy of Sciences. Tin1, report was written by Franklin P". Huddle, of the. Science Policy Research Division. Tn view of Dr. Huddle's earlier authorship of tho study, "Technical Information for Congress," the present report can Ixs regarded as in a sense supplementary to that longer work, dealing with a similar kind of problem but in the hands of a distinctly different group. Tho Legislative- Reference Service is gratified to have the opportunity to participate in this illuminating series of analyses of tlie complex problem of accommodating our society to the changes wrought by modern science. . ' . . " . • . . -...:.._ - .-•-"Sincerely yours, ." • ' LESTMI S. JAYSOX, Director, Legislative Reference Service. �CONTENTS Letter of tr/insmittal 'Letter of submittal » : I. Introduction ' .1 • ;•• Development of potent new organic herbicides '. .— Second thoughts about the virtues of herbicides and other pcstioi des ' . II. Evolution of the military herbicide program.,.. -.. Development of herbicide warfare in Vietnam Full-scale military use of herbicides, 1900-60 Decisionmaking arrangements for military, uses of herbicides in Vietnam . L ' III. Criticism of herbicide warfare '; IV. Role of the AAAS in iwsedsing war use of herbicides Organizational structure of the AAAS L' •' r AAAS council's action on Pfeiffer resolutiori . Implementation of the 1906 AAAS resolution on herbicides Implementation of recommendations of thci AAAS ad. hoc committee J, Implementation of recommendation for ecological field investi••'/ . gations..: • L... The Midwest Research Institute study of Ideological effects of , '• herbicides j. • .". Cross-pressures within AAAS, December-January, 19G7-6S National Academy of Sciences review of MRI report ., , ' . • ! . ' Review of MRI report by National Academy of Sciences....,.-- . •'•'' ... ' '•"> 'Press reception of the'MRI report..1.-....IL,'1 '..".J.'._•.•-. ". i .Assessment of MRI report by AAAS board of directors.... '.'-• ' • • • ; • Exchanges of AAAS correspondence with State, Defense, and ' ' ' j • United Nations i '• • State Department attempt at herbicide assessment . . . • U.N. actions after appeal from AAAS 1 • ... : . Renewed AAAS appeal for field ecological investigation — .-• . ' Apparent reduction in AAAS concern over herbicides in 1069 D.r. Pfeiffer's volunteer .herbicide assessment expedition V. Conclusions and observations ». \—L . . • .' TABLES \ . • • .. , . • • . ." i • Estimated extent and cost of chemical weed control in the United States, .• . 19G2.1 :..i Composition and characteristics of inilitary lierbicides *— Estimated area herbicidally truated in South Vietnam through 196S i APPENDIX III V 1 2 4 7 9 15 17 22 28 29. 29 31 • 32' 33 34 35 38 . .35).. °40~ 4446 4S S3 53 56 58 61 4 10 15 .: Appendix A: ' '• • ' ' • Draft of pending section of manual on use of herbicides for military .. purposes , .. .. . 67 �I.; INTRODUCTION \ •' A new military technology of defoliation by aerial spraying of herbicidal chemicals was introduced in 19C2 into the Vietnam conflict. The teelmology was called into play as a means of saving lives—pro.tecting troops, shipping, and aircraft from ambush from the- jungle cover; it was also used to complicate the adversary's logistics—to deny guerrillas their sources of food from remote garden plots by the spraying of these crops from the air with crop-destroying chemicals. These uses of technology were condemned as immoral by virtue of their nonspecificity; as contravening tacit international policy against • chemical and biological warfare, as crossing a threshold beyond which lay the threat of mass destruction by chemical and biological weapons; they were also challenged .on the more technical grounds that the generous tise of these potent Chemicals over wide areas by insufficiently trained military personnel might wreak serious and lasting injury to a region's ecology. I " • The role of U.S. scientists' and their professional organizations in calling for technological assessment of military uses of herbicides, and in participating in such anj assessment, was determined by Representative Emilio Q. Daddario' as being a suitable subject ior this study. Its purpose, accordingly, was not intended as a judgment of the merits . of the decision -respecting military use-of herbicicUv,-but to illuminate "the complicated process within a large, interdisciplinary organiza• tion of scientists by which a political issue with a scientific content was passed in review. Many (such issues come before the American Association for the Advancement of Science. Activist groups continually strive to compel the association to take a stand on other political issues they care deeply about.! The effectiveness of the association as .a policy-supporting organization, and the question as to the proper role of scientists in pursuing political .issues, are central elements of the study. ! The relevance of the study as a subject of interest to the Congress derives from a number of related considerations. In it. the Congress can find its function of technology assessment being attempted by a group of concerned citizens, mostly with scientific qualifications. The problems encountered by this group in performing its assessment can be regarded as "the other side-of the coin." The pressures and thought processes of the group mirror those, of the Congress, and provide a convincing demonstration of the difficulties of the task, even when it is not accompanied bv the larger responsibility of the Congress for lawmaking in the public interest, and when, on the other hand, the participants enjoy some extent of.special training in the subject matter in question. Another relevant, aspect is the preoccupation of the Congress in 1%9 with environmental quality. Much pending legislation, and many (1) 32-405— CO- — 2 �ini uniL-t m^^^^Hu mans iragiju environment, me uunc'sMnes [^countered by a pBrcssional group in ordering and resolvingcriTEs'onlental issues related to the massive and repeated application of ferbiides in Vietnam serve ,1 useful warning: and object lesson as to the cod for systematic,, objective, nnd deliberate approaches on the part, f the Congress in dealing with legislation aimed at tho prcscrraltaon r restoration of environmental quality in the United JStates. In the study ''Technical Information for Congress," it. vras ptKiatod nt. that "In the 'management of a. political issue, with substantial sciitifie or technological content, the political issue is always larpstr in '•ope than the scientific question within it." The study suggested tiiat In principle, the scientific question needs to be dealt with first." Sfore\"er, it was important that, the .scientific question be. "carefully fctsned > that the answer to it p rondos a useful and significant piece ofevicnco. for guidance, in the consideration of the broader political issue.*'. ';;-3 present study enlarges indirectly on this point by revealing" sthe ;;:vme difficulty encountered by a, technically oriented group in sep: icing out the technical issue, and defining it in manageable terms. It • rves notive, by inference, that a politically oriented group -\uwnld uwrience even greater difficulty in separating tho technical from tthe >Htical issue for analysis and decision. of Potent New Organic Herbicides Agricultural research in the 1930's had identified a roup of plant. ••rnones that regulated plant growth. By 1939, 54 differentsubsteaices •.•;•:: listed that had this effect. The most, powerful of these was ttlie.. .epical 2,4-dichlorophenoxyacetic acid, later nicknamed "2,4-D." he chemical synthesis of this compound was describee) in the Isteraire in June 1941. Experimenters often observed that in overdose of •;e of these plant hormones injured and even killed plants. OSK re.1 rcher, E. J. Kraus, head of the botany department of the University ; Chicago, suggested in a letter to two of his co-workers, in Angusf '41, that the^o compounds might be useful as weed killers. Karly results in his researches led Kraus to bring this promising mew t-haoiogy to the affonf ion of n committee of the National A en demy of •it-TWS-National Kese:uv,h Council under tho direct ion of <stvk, established at. the rc<|uest of Socivtary of War Henry L. :; to provide advice on all aspects of biological warfare. Kraus wrote .•if "il>c toxic properties of growth-regulating substances for t3ie«3c:u.'fion of crops or tho limitation of crop production'' nu^ht Iws of f«>:vst to ih(> eommilt<x\ K x p o r i m o n t n l rosoaivh in (!) is field It formally l»r<>u>;ht under an A n u v oo oontrni't s-'tty of Chion^*, in I:1!,'*, In cvnijunction with tins worSt, a •• u--U p!,v:r,u>\ \\; muJoi-wav rtf tho Kvvasvh station of was intensified as of possible use in the "island-hopping"' car Gen. Douglas MacArthur. The method of clearing landing urca.-s of foliage at that time,j\vas by saturating them with high explosive shell bombardment by naval artillery- Kraus reported verbally on his research progress'to tho "ABC" Committee of the Academy of Sciences in February 1943, and .submitted a preliminary written report to the committee March .8, describing his experiments. Camp De trick, Md., had been establish as a research center for biological warfare research in November 1042; in January 1944, the Army decided to make her- bicido research a major program at this center. Nearly 1.100 substances were tested there, under the, direction of Kraus with A. Q. Nonnan. However, "The chemicals were never used abroad, and the war terminated before we could get the materials in the field."z At the conclusion of World War II, Secretary of War Robert P. Patterson released a letter report from Merck, describing biological warfare research conducted by the United States. Merck cited as an important accomplishment of this program, the testing of "the effects of more than 1,000 different chemical agents 'on living plants." Later Merck was quoted^ as stating that "only the rapid ending of the war prevented field trials in an.active theater of synthetic agents that would, without injury to human or animal life, affect the growing crops and make them useless." In April, 1944, the emphasis.of the research at Beltsville shifted. Detrick had a vigorous, war-oriented program underway. So the Belts-; ..'ville group'returned to their earlier interest in 2',4-D as a weed killer. In June 1944, in'an article in the Botannical Gazette, Mitchell, in association with Charles L. Hamner (another former student of Kraus), suggested publicly for tho first time that 2,4-D had "some importance in connection with the differential killing of weeds." 3 Another report in this journal in December 1944 elaborated on this work. The chemical was found highly toxic to bindweed, dandelion, and other broadleafed plants, while-leaving lawns (bluegrass) unharmed. The public interest in the. new herbicide was intense. In 104 ">, the American Chemical Paint, Co. marketed the first systemic herbicide under the brand name "Weedone." Other companies were soon licensed to produce- the • material. Tests that year revealed that the new chemical was indeed a revolutionary discovery. The toxicity level of tho new chemical, for man and animals was i n vest i era tod, and determined to bo low enough to make the chemical acceptable for general use as a wocd killer. Lists of weeds killed by 2,4-D lenirfhenod. Costs dropped from !?12..">0 a pound in 10 14 to SO'.'iO a pound in Ifl.'O, The material was easy to handle. noncorrosivo, and effective in uso. Production went up fast: 017,000 «C. >:. MlimrU-. "Crop nirtvMn rvrii!i«!tv>n Prosrnm." PnwMlncs <>f tho Third rvMi.-u Hon rmif-ivmv. Atic. in j j . Tl'ii.V p. II. Tlu> ro<t of th!< luwnnf t.- li;>«ist on an .'irtlclrp,v (ialo K, iVtorHon. "Ttio Dlsi-owry niul IVvplopnn'nt of ",4-n", Affrioaihiral lil*t<<rr (vnj, -!t, No. ,X Jnl,v 10c!T>, s* • ft ^v..»f i > Substnnws." �o.ur.ds in 10-15, 5,460,000 in 10-1G, -and'more than 14 million by .1050. 'he author of .thj^^fcipr concluded:' Ironically, 20 yc.^^^Kr Knius had suggested it to the National AcacEemy of clonces, 2,4-D becjSiWi too! of chemical warfare, * * * Developed t'<»x war, ;t vi^sijtiod for agriculture, the U.S. military at last found application ifor its •snrributlou to the development and testing of 2,4-D.4 A survey of the domestic use of herbicides in the United States, conucteJ by the Department of Agriculture, reported in August. 1005, •;U in tl'ie year 1062 a total of TO million acres was treated (see table ), at a cost of more than $270 million. The report note that by 19G2, bout 100 herbicides in G,00 formulations were available. The rate of creased use was such that acreages treated would continue to clkmble i 10 years. (Actually, they leveled off at about 120 million acnes by C35.)' . . ' . - . - • • . . • . ' . BLE l.-ESTIMATED EXTENT AND COST OF CHEMICAL WEED CONTROL IN THE UNITED STAGES, 1962 Crap or area • r-, " t;.i . V] -s ••; s-:..-.s ' . 4 5 25,302 5,433 2, 827 ' 18,931 940 8 • • 310 15 • . 362 25 2,665 - 20 • 439 29 . S51 -'. * .' 171 -. 2 . 16• ' • ' - - 30 .1 26 21 .267 . . . -• •! :---.--..tS . .,« - - • :e-is • •.-iisi r:;; - t-jrs ... _ :-, ; f.-.;ts and nuts ' ;~!crnls 15 28 '. 45 15 .-; - ., !;r~s ;:!».-!<} V:jj.'jii;f...V.~IIIIIir" Tc^a! Total acreage Harvested acretrealed aja trealed (thousands). • (percent) States reporting (number) • - 33 ' •• - ' 45 20 31 JO ' : 38. 8 • . 557,600 16,805 34.9 10,835 ' 10.2 ,• '29,579 23.5 •• 6,250 ' • 53.0 ' 2,565 22.0 ' . 2,237 .. . 32.8 5, 258 .' 23.1 • ,-. 2.416 : .. •. 16.1 35.5 : -' . 8,634 ' . - • ' . 12.4 • •:•• 1.1 : ' : 187 V. ' ' 4 . 6 ' •'.' 650 : - . - . - • 27.0 • 2,397 9.7 ' 51 672 .. - 412 4,714 2,262 ' 274 .. 3,612 .. ' 23 70,6£7 Total cost, all herbicides and Averajprast per applications :K'i. all (thousands) treatments ' J2.28 3.09 •3.83 1. 56 6.65 8.27 ' 6.18 1.97. -5. 50 .• 9. 09 . •5.95 , • -••• 7. 12 .'6.23 ' ' . •••• ,25.00 .8. 93 ' . ; !' •:-,:• .-'w - •'> .. . • . ' 969 .15,368 • 1.794 ' ' 13,340 6,265 . • ' '.3- •. . ••*' ' 2,752 83,714 24.8 8. 4 5 . - 41 270,746 .. '19. 00 22. 86 8.69. 2. 83 2.77 10.04 .23. 18 3.86 £j:luc>s (ores! planlinjs a n d noncrojland. • ' : . ' , • • • ; • Kry.: U.S. Department of Agriculture. Aiiricultural Rosearch Servics and Federal Extension Service. "Crops Rraeirch; t?i of Etient and Cost of Vsced Control and Specific Weed Problem}." (Aug. 1955, ARS 34-23-1), p. 3. '."on<ZT~ftf>ughfs About the Virtue* of Ilerliicidfifs and Other Pestwldes The explosive rate of acceptance of the new technology eventually ve rise to apprehensions as to its possible adverse side cllects. A. techlogical assessment of the domestic use- of herbicides— and of jwjsti!e,s in general — *ivas triggered by tlio appearance in 1002 of an am fluHal popular bo;1; by Kachel Cai-son, titled "Silent Spring." This u>k described disadvantageous consequences of pesticides, incliudingf a possibility of tho toxicity of somo of thorn to man or animals, ftheir long-term biological (e.g., pathogenic, carcinogen icr and c) efTects, and the ways in which postic-ides reached beyond "The Dl-scovery and Development of 2,4-D." Op. clt., p. 253. their intended target organisms to strike down others m<a sometimes insufficiently appreciated. This last type of e<'" logical damage caused by pesticides—was emphasized . book. Although Miss Carson reserved her most severe criticisms for insecticides, she did not spare the weedkillers: The legend that the herbicides are toxic only to plants and so pose no threat to animal li£e has been widely disseminated, 'but unfortunately it is iios true (p. 41). [Arninotriazole] is rated as having relatively low toslcity. But in the long run its tendency to cause malignant tumors 01" the thyroid taay lie far more significant * * * (p. -13). Among the herbicides are some that are classified as 'mutagens," or agents capable of modifying the genes, the materials of heredity. We are rightly.appalled by the genetic effects of radiation; how, then, can we be indifferent to the saiae effect 5u chemicals that we dis.senunatwl widely in our environment? (p. -13.) • * * * The whole elo.sely knit fabric of life has been ripped apart (p. C7>. [By this "shotgun approach to nature"] the spraying also eliminates a great many plants that were.not its intended target (p. 67). * * * The wholesale broadcasting of chemicals would be .seen to be more costly in dollars as well as infinitely damaging to the long-range health of the landscape and to all the varied interests that depend on it (p. 09). The most widely used herbicides are 2,4-1), 2,4,5-T, and related compounds. Whether or not these are actually toxic is a matter of controversy. People spraying their lawns with 2,4-D and becoming wet with spray have occasionally developed severe neuritis and even paralysis * * *. It has. been shown experi• mentally to disturb liie basic physiological process of respiration, in the cell, and to imitate X-rays in damaging the chromosomes (p. 75). •[Fruit flies] developed mutations so damaging as to be fatal oa exposure to oae of the common herbicides * * * (pp. 100-191). The full maturing of whatever seeds of malignancy have been sown by these chemicals Is yet to come (p. 201).5 -.• • Various-technological-assessments -were serin' motion'by the Carson book, or took place concurrently with it. A series of reports were issued by a committee on pest control and wildlife relationships of the National Academy of Sciences-National Research Council.6 The lengthy investigation was conducted by the Government Operations Committee'of the Senate, culminating in a final report, July 21, l!H'>t>. Tho conclusion of this report otiers perhaps .the best consensus available^ on the broad question of whether or not herbicides (and other pesticides) should bo used, and if so under what circumstance;;. It recommended that the present regulatory system should !« strengthened to prevent unintentional contamination of-thc environment, That • Knclit'l Carson. Silent Spring. (Greenwich, Conn. Kiuvcstt Publications. Inc 10S2 100(1.) -'ill p. phut Index. . • N a t i o n a l Academy of Sciences. Committee on t'cxt Control nnt! Wildlife Uclatlotichlps. "A Symposium on IV-t Control anil Wlltlllfv Kvlntlunxlilpn." By Committee on Pent Control and \ V I I < t l l f i > ili'latlonslilpK. Mar. 10, lOfil. 2,1 pp. (Piinl. SOT) : "I'est Control antl Wildlife Ki-lalluiiNliljis." Pt. 1 : "Evaluation of Pesticlili-Wlltlllfe l'robl«-m«." (li)(i!J), 2S pn ( P u h l . ftl'O-A) ; I't. 2: "1'ullcy anil I'twilimiH for 1'tint Control" (IOC,:;), 5.'! pp. (J'ubl, 02(»~I1) ; and I't. 3: "HMi-aroli Needs" (iuii:<), 2S pp. (I'nbl. Iti'u-C). (Wanhiiigtun, H.C.. JNntlwial Academy of Si'lerit/i'H.) 7 U.S. I'ri'Hldi-tit'a Hdviivc Advisory Committee. "Cue of I'estlclilen." Tho WJiltc House May tn. it»«:i. ""KfTeetH, 1,'tn'H, Control, anil Itefearcli of .\irrli'ul(\tr«l IV '«<•«." (A report tty mirVi>y« mid I t i v t ' H t l p i t l n i i K HtnlT.l April 1H, lliiin. Hi'pr">hici'<l i n . ' •.. t'><i.i;rt'ss. IIiMis«'. Comnilttri; tin ApiiroprlritloiiH, Jd'iiartmi'at of .Vv'rii'iiltiifi' Aj>!'?<ii4..'»i<t!i<» f«r H»ilti. H"'iiriiif."M before a Hiitifoinmllti'tf of tlnr • • * pt. 1, bUlh Cuiig,, Snt »«•»«. (W<t»lil»jitua, U.S. Uuveruiut'iit t'rliitlin; Office, 1000). ' ' ' . . " • ' • . & V, �Fcck'rai programs of jh'.-t control should be coordinated more closely, timr, lieulth WCJM^IS relevant to pesticide's should ho expanded, and that scientific ^^B'h into the effects of pesticides should he stepped up to provide ^H^0 adequate. basis for future national policy.9 As a result, tiffin, of the apprehensions rinsed by the Carson hook, the need vras recognized for more closely controlled use of herbicides, and for more penetrating research into the ecological consequences of their u?e. At the same time, it became more fully appreciated that thebenefits conferred by this use, and the extent of reliance on it for icgrieulturejn a technologically oriented society, could not easily bc»:'f oregone. Use would continue, but under measured control that would be further refined as knowledge of adverse effects became more precise. It was during this same period of technological assessment of the domestic u?e of pesticides general!}', that the military use of herbicides L-egan and expanded in Vietnam. This >vas perhaps not the first time that defoliant, chemicals were used in counter-guerrilla warfare. 10 However, their use in Vietnam certainly appears to have been n unprecedentr-d in terms of its extensiyeness, scope, and systematic nsi nature of appl i cation for military objectives. As the military use of defoliants in Vietnam intensified, various _ questions were ra'ised_by groups, and individuals in the United States concerning the. morality, the legality, and the possibly adverse longr >nge consequences, of the program. The rest of this study describes, in governing body and with the Department of Defense, (d) the efforts of the Department of Defense to perform its. own assessment of the technology, (e) the subsequent efforts of scientists to perfect their as-sessment, and (/) the present status of the defoliation assessment. The study .concludes with a statement summarizing the observations to be drawn from this case as an example of technological assessment moti-' rated by a large professional society, relative to national science policy. II. EVOLUTION OF THE MiLITAKY HERBICIDE PKOGI1AM The close of World War II was the signal for a varis^^f small insurgent uprisings throughout the world, usually characterized by informal .or guerrilla forces in challenge- of existing governmental authority. These occurred in Greece, Malaya, Cliina, Cuba, Tndoncsia|.j the Philippines, the Congo, Cyprus, Algeria, and elsewhere. In some- respects, the- British camgaign against the guerrillas in Malaya served -as a prototype of the later conflict in Vietnam, in that .it was to combat a Communist-inspired uprising in a jungle area of Southeast Asia, with an essentially colonial economy, employing weapons of terror against a technologically sophisticated adversary. An important difference was that in Malaya the guerrillas were not in contact with an outside source of logistic support .and had no sanctuary. Tactics of counter-guerrilla warfare in Malaya, accordingly, were concentrated on: (a) keeping the guerrillas separated from the civilian noncombatant population by fortifying and protecting villages, (I) keeping military pressure on guerrillas to wear them down, and_(<?) denying the guerrillas sources of food.11 Despite a vigorous campaign, . however, thejMalayan guerrilla war cost the British heavily in wealth, and dragged,on for a decade.. Early in his administration, President Kennedy was motivated by the first Cuban crisis and other manifestations of political instabilitv in developing countries to increase the U.S. capability in dealing with "guerrilla forces, insurrections, and subversion." Such-a. capability would entail a general strengthening of military resources of anthropological, cultural, -and other social .science data.in relevant areas of,, the -world. In Shis March 28, 19G1, message on the Defence'budget, the - President said that the U.S. interests were threatened by limited guerrilla warfare such as had brought Castro to power in Cuba. To counter the threat of being "nibbled to death,1' as the President expressed it, the United States needed to strengthen the capability for lower levels of intensity of Conflict. ". • ; . . . To meet oxir own extensive commitments and needed Improvements in conventional forces, 1 re'commend the following: A strengthened capacity to meet limited and Kuerrillii warfare » * * V/e need a greater ability to deal with guerrilla forces, insurrections, and subversion." Within limits, the British experience served as a guide to the '.Government forces in South Vietnam, and to their U.S. military » Several references stress the I m p o r t a n c e of denying (,*iierrill:i* sources of fivxi. Ynt example, Lt. Col. Unwliind S. N. Mans w r o t e : "The most !>ui.'i.'essfiil operations in Mnla.vn "were those aimed itt d e n y i n g liny form of food supplies to t h y (RiierrilUis J," (flNoj "As '{heir fooil caches were reduced, the [(jm'rrlllasl crew more and more dcspentte. They took risks that exposed them to SKurlty Force retaliation . . , Lack of food often forced .1 ( S i K i r r l l l n ) to surrender." ("Victory 111 Mnlaya," I n : I.t. Co!. T. X. Creoiie ( e d . > . The Guerrilla — Anil How To Fk'ht Him.. .Selections from the M:ir!ne Corps G;ui'lte. (Frederick * ' A. Praeprer, New York. ItillS, I*riie>:er I'uperhnckg), pp. lU-t-325. Joseph P. Kut^er also The stresses t h i s theme : "The tftierrllins started to t>'?\ the pressure of th? • dlMlenlty of u m l n t f t l i i t n K local Kiipp'y lines n f t e r the relocation of the junplo f r l n i n ireilu<:0'l them to depemlin^' upou crops ralseil In Jungle elertrin^s. The i.i^t presented the British nlr linn with suitable targets. The HAP w u u l i l ohserve' the urea Hiut nt 'he propitious moment dampen the spirits of tht; helea>?uerej t,'»err!ll«s by s p r n y l n ^ the fn.iil plots with polmui or stttlnt; nllre a llelil ntmnt to be hiirve«fe«l." ( I n : "Irr«'K>i!'ir Wart'arc iu 15 Transition." M i l i t a r y A f f a l r x . (Vol. X X I V . No. ;t Fall, lldio), p, 121.) I'resldiMit John F. KiMinedy. Special inessn^-e to the CVnt;r>:xs on thi; it»fen«e bu'ltret. 'In I'ubllc I'lipers of the t'ri'KlriVnlK — John F. Kennedy, 1001. (Washlngtoa, U.S. Oor- eminent i'rliitlni; Oltlce, ll)(>2), p. 236. �supubrtcrrtf,"iiT the "cleVv'. "nicnl of strategy and tactics in the Vietnamese war, Ai^ng the important differences wore the fact that the guerrillas in U^^tter war were able to concentrate in larger force unit?, to ovei^^Billage redoubts, and then retreat to sanctuaries in the jungle, ^Rh Laos, Cambodia, or north of the demilitarized zone (DM2). The rice growing areas in the delta country, south and east of Saigon, were abundant sources of food on which the whole country depended;_ these sources could bo denied to the guerrillas only by physically holding the area and taking custody of the crops as they cHu-ed areas to supplement their supplies of food from above the jDMZ.^These plantings were similar to the slash-and-burn agriculture '.••: 'irionally practiced by the indigenous Montagnard population in ' • '.-ria. • ..-ties of the guerrilla forces in South Vietnam in general involved r-,_ • ' . ; ; ' f u l use of jungle cover and the merging with the local pxopular.~ -:i, as iu Malaya. There were roadblocks, with systematic taxing of :;-yre.lers; retreats to elaborate underground strongholds in tine fore-^s; ambushes along roads; sniping at river traffic from the bush; kidnappings, assassinations, and terrorist demonstrations. Logistic transport took place.at night, or under the forest cover; use was made a> sanctuary of neighboring territory formally denied to defending troops of the.Republic of Vietnam. V . , . -*. _\-'J i I V i^j^ivVlV^ » J » . l J^y-Wi. V . .1 A ' / » * ^ V &1. i \J±1 JLXtl^tlllJJtJI. I J O.V/VJ J.. JL J. U^3i.U.tMJ V IX *:rn advised President Kennedy that "the forces of International Communists now arrayed a a i n s t us are more than we can meek with t:-.-;_ resources at hand. We must have further assistance from the . I .:fcd States if we are to win the war now being waged against us." (.'.. December S, the U.S. State Department issued a report describing i '....• pattern of guerrilla activity in South Vie.tna.rn, the increased use o: rerror tactics, the support received from North 'Vietnam, and the V:-:- of Laos as a base and logistic supply route. Shortly afterward, on I-r!>ruary 3, 1%2, the. American Military Assistance Command (Vietn i i a ) was established to supervise American military personnel and coordinate joint planning; by mid- 1962, U.S. military forces In the ait-a reached the number of "12.000. Popular disaffection with the Diem regime, during IOCS, culminated in its overthrow by a military coup, November l; sfoortly before the assassination in the United States of President Kennedy. At the end of the year, President Johnson after consultations, with Defense Secretary McXarnara and CIA Director McCone, assured the new government of continued U.S. -support. Tins position was confi.-inod by jointjresolution of Congress, signed August 10, 19G4, asserting that the United States was "* * * prepared, as the President determine.", to take all necessary steps, including the use of armed force. to assist any member or protocol state of the Southeast Asia Collective Defense Treaty requesting assistance in defense of its freedom," (Public Law 88-108). This resolution became law 8 days after "~tnu 'lonkiu liuii incident iii winch the; U.h.S. attacked by three North Vietnamese torpedo boat--. BonibL^ .strikes against North Vietnamese objectives by U.S. planes bcgj^BbPe-bru-, ary 1965, and a U.S. Marine battalion landed in Vietm^^HLrch 9. Thereafter, the war escalated in intensity, with progre^^ely increased U.S. participation. U.S. forces in Vietnam grew from about 23,000 on January 1, 1965, to about 181,000 at the end of that year; by the end of 1967, they numbered 480,000. ' The essential failure of the village redoubt approach to pacification in 'South Vietnam meant that increased emphasis would new! to be'placed on other aspects of strategy found effective in the Malayan counterinsurgency campaign (the closest prototype), and that additional new techniques would also be needed. Use of herbicides _ to remove foliage along thoroughfares as cover for ambushes, which may have been used in a small way in Malaya, become an important part of U.S. practice in Vietnam. The harrying of guerrilla forces, and" attempts to encircle guerrilla strongholds,_ required both aeriul reconnaissance and close ground support of military forces; removal of protective cover of foliage was helpful in both cases. Finally, the denial of food, which had definitely played such an important role iii the British Malayan campaigns, was extremely difficult in the Mekong Delta region, which was generally a food-surplus area. However, in the areas west and north of Saigon, the population was more sparse and food production much less abundant: in these areas, it seemed feasible to develop the strategy of destroying subsi5teri.ee crops of the guerrillas, thereby increasing the burden on the logistic supply coming .from North Vietnam.^Beginning in 19G1_, herbicides grew to be - a n important element in Vietnamese counterinsurgency, Development of Herbicide Warfare in Vietnam Experiments with defoliant and desiccant chemicals as herbicides had continued at Fort Detrick, after World War II. Some 1-2,000 chemicals had been tested and the most promising 700 screened in greenhouse and field tests. Some of them had been tried out on tropical vegetation in Puerto Rico. An extensive test, over an area of 4 square mileSj had been conducted at Camp Drum, N.Y. Finally, "a variety_of chemical agents were shipped to the Vietnamese military authorities, and from July 1961 to April 19C2, a preliminary series of defoliation trials were conducted under the guidance of J. W. Brown." The program was then halted, pending an assessment of its military eU'ectiveness. These tests showed that -2,4-D and 2,4,5-T (see table '2) were effective defoliants when .applied during a period of active growth; in addition, cacodylic acid sprayed from aircraft showed promise for use against riceficlds, While further tests were being conducted bv U.S. military forces and under contract, in Thailand, Texas, and Puerto Rico, Vietnamese military forces and U.S. planes spraved jmhgrove and nipa palm vegetation along canals and roads east or Saigon, with considerable improvement reported .'in overhead visibility of the ground." • . |.| n , nl 'i ' ' • "Mill report, op. Clt, pp. 113-115. fla-IOB—00- • •' • �ana or limited potential effectiveness. . Exeerpts: TABLE 2.-COMPOSITION AND CHARACTERISTICS OF MILITARY HERBICIDES Agent Composition Pounds per jallon AE Purpose n-Butyl ester 2.4-D, 50 percent(vveiglit).... n-Butyf ester 2,4,5-T, 50 percent (weiaht). 4.2 3.7 n-Eutyl eslsr 2.4-D 50 percent (weight)... ti-Butylestef 2 1,5-1,30 percent(woigM).. Isobuty! sster 2,4,5-T, 20 percent (weight).. Oran£* 4.2 2.2 Total. While CTsrdon 101) Total. S'u; (f-ii/tar 5SM) forfeit, brush. 8.9_ Tout. Purr's General defoliation; broad-leafed crops. General defoliation; interim- agent used ' interchangeably with oranse. 8.9 Trf-isoprapanalamiiie 531(2,4-0 Tri-isopropanateminesJltpicIoram- 2.0 Forest defoliation; long-term jangle . 54 . control, brush suppression!. 2.54 Sodi'jm cscodylate, 27.7 percent Ffee c.3cod>iic acid, 4 8 percent Water; soii.'um chloride, bol 3.1 Rapid defoliation (short durctiion); Jrassy plant control, rice destruction. - Source: MidAcst Research Institute. "Assessment of Ecological Effects of Extensive or Repeated Use of Hterbicides." 3) W. 3. House «t 2!. Final report, Aug. IS-Dec. 1, 1967. (Hereinafter called "MRI Report".) Sponsored fc# Advanced ?-jifvcMPisiKtsAsi.-iiy of the Department of Defense, ARPA Order No. JOSS. MRI Project No. 3103-8 (Midv/esit Research ' There is no riuestion but what you can have nn effective defoliate. The is £5 n<! in i; one ihitt is fait enough acting to make it militarily worthwhile. (Qiv/siion: [Its use in guerrilla warfare) would not appear to have to>o 'great - • >:ai<:a or b-5 of too great importance . . . ; is that correct?) (Answer: Xes sir; • .<..•>• er tlu'.rc are methods of doiiiic this with chemical compound*. 'Amfl •oh" an " -•• >.-rir: sen trt! basis, we have demonstrated that wooded areas can be stripped of ': iU.i^e. This work was done as part of our antic-fop program.) - • . * * * "'lie quantity of matt-rial to cover an area —well, you cnn sec that they ';.,-'- rf -rilly .small —but when it comes to a number ot square miles, the nuanber of i-'i r-""£ aiik-s that can iojri.stically bo covered here, as far as our researcih work i<i< uncovered, a re vtry few. • ' itr. J'LI/OD. As a strategic weapon, this has no value? •-. , . . ,. " • One-nil STUUBS. Xo, sir. ' • . ' . Mr. FLOOD. But, I could particularly V.AO that to advantage in jungle warfare, o>::aiiii>t? Ofiicr.il STCMS. Whf-n it comes to ,a very limited operations, sir, we baive the chwjii'-a! today that can do that kind of work. i Question : How long does it take after it is applied to have effect?) ( Ajnswtr : L'n.'ortiinately, it takes too Ion;;, This requires some 2 or 3 days.) " Not long after the above exchange took place, preliminary tests were underway in Vietnam. According to one account— AmPritti'H defoliation effort in Vietnam bcptn modestly in late IfXJl. Six'C-123 transport planes, traditionally wed for tarrying soldiers, flew into South Vietnam ,'.-.'•;:» Clark Kit-Id in the Philippines and were outfitted with special tanksKicarry:.\_;' JO.iXK; pounds of defuliarit, enough to cover 300 acres. . - ..... — The planes flt-vv CO flights in IfXJl and 107 in l'M2 HH oxi>crlinent.s continued. 1 A toral of ] 7,000 acres were sprayed in 10C2." . ,". , '•U.K. Conerffs, House. Committee on ,Appr«i>rlnt!on« for 10(12, Itonrltij;a bi'C»re the S'.ibcommltt'1!' nt tho . . . f'nrt 4, Iti-m'iirrh. Ifi'VchiptiK-nt, Test, urn] ICvnlnutlmi, H7(lli Cong. !.•<£ B-SS. <WnKlilni;ton, U.S. ()»vfrnini>nt I'rintlni: Ollli'c, l i K J l ) , p. 2:11. " A r t n r o P. (ionznlfi!. Jr. " I x - f o l l i i t l u n — A Cootrovcrnlnl it. H. Mission In Virttniim." Data (Vol. 13, Oct. 1!M!8), p. 1,1. Acc-orilliii,' t» ri<ronlH of tlio Dfiinrtrni'iit of R)!ie Air Korce, no operational nitufing -wna diint' In 1U01 nltnoiixh BOIIIC ti-Kt nt'tlvlllrn wnre con1uct>*il <iIo»K ranal.s anil roml* nt-ar riulK-on. Ojicrittlonal eprayliiR of C(IH1 cccnm wux carried O B t l u 1UG2. ' bell, stated that among the new techniques employed agaT^Pne Yietcong was defoliation from the air-—"* * * a chemical means of stripping leaves from the foliage that hides Vietcong movements in thickly wooded areas." The report continued: "Known Vietcong bases will be surrounded by bare stretches where the guerrillas will find it difficult to move undetected from their hideouts, which are often underground."" .' ' Further explanation of the program appeared in a story datelinea January 11, 1902. It indicated that the implementation of defoliation efforts had been delayed pending resolution of "the question of how to publicize this form of chemical warfare * * *." The spraying now is expected to bojdn soon, following a formal announcvmpnt approved by high official* of both countries. The announcement declares that the chemical operation is intended to "improve the country's economy by permitting freer communication as well as to fuciiitate the Vietnamese Army's task of ket.'i^ ing these avenues free of Vietcong- harassments." 1T A.week later, it was announced by "a high South Vietnamese official" that the' program had begun. A 70-mile road from Saigon to the sea had been sprayed "to remove foliage hiding Communist .guerrillas" and "defoliant chemicals would also be sprayed on^Yictcorig plantations of manioc and sweet potatoes in the highlands." The . account said that "The exact locations of these plantations have already been plotted by aerial surveys" and tests had been made that showed that "* * * Manoic and sweet potatoes die 4 days after having been Saigon, under the bvline of Homer Bigart, reported that. ''The United States has shied away from plans to starve out Communi.-n guerrillas by spraying chemicals on .rebel-controlled manioc and riceiields." The roluctanee to join the'crop-killinj,' program urged by the South Vietnamese is believed b.'isi-d on American sensitivity to the possibility that accusations would be made that Americans took part in chemical warfare." A story appearing in the Bankok World, Februaiy 24, 1%2. attrib' uted to a "spokesman'' for the "U.S. Defense Department" stated that: "Commercial weed killer has been sent to-South Yietnam in an amount adequate to accomplish the purpose of clearing Jungle growth along highways and trails." The "spokesman" was further quoted as saying, in answer to a question: "Xo, the chemical has not been u.-ed for crop destruction." Apparently, after these first experiments with herbicides, there was a lull in the program, while military assessment was made, of their effectiveness. One indication that tlie experiment had not been au ITN,.\V York Tim.'* (.Ian. \'2. I H H 2 » . p. .1. (Thi- IVp.irtmfnt of I>ff.-n*n tukos K-M;" w i t h the Now York flmi-H Intorpri-lntluii that ni>ra?ln£ prfsf"'"" »'*>•« Uclsyttl by cousldmItoiiH of piilillcri'latloiiK.) '• New York Tlicu'M. (J»n. 10, 10<12), (). 4. » New York Tlm»>», (.Inn. -tf, 1!")-), J>. 1. �presented in a study by the Agi cultural Research Service of the U.S. Department of Agriculture, under contract to Advanced Research Projects Agency of the Department of Defense, February IOCS. This study reported: Some forested areas in Vietnam, wore sprayed with 'herbicides in the early lOiW's in riu effort to reduce the amount of obscuration by vegetation. The results were particularly good on mangrove in coastal areas and along canals. Results on evorgrc-en. rain forests and upland semideciduous forests left much to be desired. Consequently, a team of military and civilian experts reviewed the operational si-ray program and made recommendations for improvement. Since there -was a c'-.-.zrth ot information available about the response of tropical woody plants to 2:-rMc:O.Ds, a research program was recommended that would answer soiaeioif the c.-: r'.-.-al problems Involving the defoliation of tropical forests.21 •'."Hiring March 1062, Roger Hilsman, a-senior adviser in the State .: xu'tment, visited Vietnam and on his return prepared'a. number f-.i :uemorandums on current issues, one of which was the use of de:'. •'.''Silts—a device that, he said, "had political disadvantages" and was of doubtful benefit. Excerpts from a later statement by Hilsman on this period are as follows: . ' • rv-foliants * * * were new. They were chemical weed killers, which had been ht-rbly developed in the United States and were widely used, for example, to kill 7...urotation along the rights of way of power lines. The military headquarter* in Saigon thought that these defoliants would bo idoal for clearing the undwlurusti along the sides of road- where the Vietcong laid their ambushes and for diss.troyLv.; crops in areas ui>: •:• Vietcong domination, and General Taylor and the Joint Chiffs of Staff agrec-d. The State Department view, on the other hand, was that.. the political repercu^ions would outweigh any possible gains. Defoliation was .. just too reminiscent of gas warfare. It would cost us international political support, and the Vietcong would use it to good propaganda advantage as an fcsampie of the American making war on the peasants. My own-feeling was that at a much, much later stage, when the Vietcong had been isolated frona the population and were attempting to grow their own food in the mountainss, the advantages might be significant. • ' [HUsrnan questioned the advantage of defoliants either- to deny food, to sruerri'liis or to rernovfc cover for ambushes at the time in Question.] * * * As for removing the cover for ambushes while in Vietnam I had flown down a stretch o' r-'iad than had been used fur a test and found that the results wore not very , ;::.[Ti'.-sivc. * • • Later, the senior Australian military representative In Salion, Colonel Sr-rong, also pointed out that defoliation actually aided the anilmwhi-rs— " if the vegi'tation was close to the road those who were ambushed could take cover cni'-kly; wbc-ti it was removed the guerrillas had a bettor field of fire. But the >'utif>n.il Security Council spent tense sessions debating the matter." Military assessment of defoliants a-ppears to have involved such questions as the feasibility of developing techniques by which large, slow-moving and low-flying aircraft could traverse cnemy-occajpiod jungle terrain without being shot down: *,he selection of else appro-. prio-to chemicals for particular kinds of foliage to be stripped of leaves; tho timing of the spray missions in relation to the local rain- . fall pattern, and local wind conditions, in addition to military tactical requirements; and the survey of the urea to be sprayed^•jyermine tho risk and extent of inadvertent damage to crops and t^^^Bplantations. This learning process coincided with internal in?ta1«PPR within tho Saigon government, and the gradual enlargement of U.S. military personnel serving as advisers to the field foives of the (/ovtnmiCT.t. Mesmwhile, separate experiments in U.S. territoiy, and in Tliailand. helped toward perfecting the. techniques of application. In. particular, the. military authorities,!/! the United States wore concerned over tho various timelags in defoliation evidenced by the different species of . plants to which the sprays were appj ied. Evaluation of the proposed military uses of defoliant Chemicals .by the Department of State, judging by the Hilsman discussion, involved the impact of world opinion on U.S. foreign relations. The various work orders by the Advanced Ke?earch Projects Agency '(ARPA) of the Department of Defense to the Department.of Agriculture had to do initially with the military effectiveness of the chemicals. Later on, questions were explored as to residues in plants and in the soil (March 5, 1063); however, in these initial stages no significant emphasis appears to' have boon placed on the need for .research concerning the long-range effects of herbicides on the ecology; The. Department of Agriculture studies for ARPA inclulied («) vegetation of Southeast Asia: Studies of forest types, December IT'O."*; (Z>) forests of Southeast Asia, Puerto Ilico, and Texas, published September 10GT: and (c) response of tropical and subtropical woodr plains to chemical treatments, February IOCS. • ' ] To prepare the first report, Fred H. Tschirley. Crops Research Divi'sion, Agricultural Research Service, USDA, visited Thailandjdunng December 1063 to January 106-i, and December 1064 to February IDf;:,. In Tliailand he was assisted by Thai forestry experts, and particularly Mr. Tern Smitinand, taxonqmist in the Royal Forest Department 'of Thailand. The purpose of this first reconnaissance was to identify • tho characteristic types of foliage growing in wooded areas of ^oatheast Asia. ,. ' ' ' '•&'•...-': •• •• - -. • ! Tho second report fronf'USDA-to AliPA was a comparative study of forests in Soutluvist As|a in .comparison with forests in Puerto Rico and Texas. The to re wo'Fd to this study states: . ! * * * Information on the floristic coin]>ositton and structure of a particular forest type, occurring under tropical, subtropical, or temperate C"ndi!i<>:is, is essential for comparative purpose, nnd is of value to tho ecolo^'i>tt fur»sfcr, KCOKrnjihor an<l others. In brief, vegetation is the suinination of climate, coil tyjK'S, and general conditions in a particular onvironnu-tit. Throughout tho report, emphasis is placed on analogous and nnotnalous features of the forests of Southeast Asia. Puerto Rico, and Texas. This comparison is based principally on investigations conducted by the author [l.iowMyn Williams] throughout-Thailand at Intervals during 1SXJ3 to i;xk*>: in 1 Tnorto Bieo In April 11K13 and June liKIO; and in eastern Texas in September 10«',«>. Other studios, osiKH'ially on sctMlling.s apivaring in succcssional growth, wore con.lui'tcd in I'uorfo Kico hy J. A. Duke- during llKiS to ISKiO. Tiie third report, eoinpilod hy Tschirley, described the results of experiments with herbicides in Puerto IJico and Texas, and interpreted tho effects in relation to military objectives in Vietnam. An indication of tho development of the scientific aspects of tho program is provided by .tho summary of successive work orders ami �-AUI-.-V urucr i^^^m LISSUOU j.in. ;ju, i:x>;ij was established for a 2-year orl. The objecfl^^Pl ttic work in College Stntion. Tex., were to: "Discover d evaluate new herbicides and principles for killing trees, brush and other leration; develop methods of evaluating herbicides on different species of ody vegetation; develop methods and principles for improved application chniques; ami dotcrmiue effects of promising- herbicides." The. objectives of research in Puerto llieo were to: "Conduct advanced evaluation of pronnlslns; decides for killing tropical and subtropical vegetation ; and determine optimum ::\f>s and rates of application, distribution patterns, formula Lions and im.xihircs -r :no>n effective use of herbicides." The objectives of the taxonomie investijjai'fj-z were to: "Obtain sufHcieut botanical information so that correlations can l^ ta:ide .lietween vegetation indigenous to COXUS ami Puerto Rico, and Southf:-st.\.*ia. " • AIlPA Order Xo. 424 was extended for an additional year by amemlionent Xo. :! dated March 5. IOC,". Additional objectives of the research were to: (1) K;uph:}«ize effects of environment on behavior and effectiveness of tierE>ieiues a nil persistence of control including residues in soils and plants. {2) study secondary succession of vegetation -following different herbicidal treatment.' as related to "visibility," (3) correlate the results of defoliation in. Texas an.j Puerto Rico, (4)-investigate methods for improving absorption, translocate:, and a-ctivity of herbicides and defoliants, and (5) compare the penetration : s-.-raj-!» through a forest canopy that is obtained from a cableway system with 1 . - • ( obtained from aircraft. A st-cond extension was granted by amendment Xo. 3, dated March 29, lOdC. .'urins: the final year of the project, increased emphasis was given to the effects ••" vavironment on herbicidal effectiveness, the composition and frequency of '.'.c-Tessional species following herbicidal treatment, the effect of defoliation and :u:;-;-i-ient regeneration on -the degree of obscuration, and herbicidal residues. r. !<•>• h plants and soiN. The interrelation <••' data from the fields of taxonomy, ecology, weed science. UK! engineering have been extremely valuable during the course of this project. Ft is axiomatic- that the breadth of a study determines the.extent to'which i.ifa developed from that study can be extrapolated. For example, a great deal >" research han rn-ea done on the control and defoliation of woody plants in eapvT-nte zones. Information was available regarding which herbicides were nost effective, what rates should be used, and when treatments should bo r:adir, Hut no one could extrapolate that information to a tropical evergreen ores': with any degree of. as.si;rnnce. In like manner, penetration of a spray sola* ; on through a forest canopy wviild be expected to be different for a desert s=3mib . ormntion, a coniferous fore it, a temperate deciduous forest, arid a tropical • •ri-rgrecn forest. Once the effective herbicides, the penetration of spray solu-. ;<>!;.-•. and the taxonomtf affinities of several diverse vegetative types are known, xtr.ij^iation of that inforiiiar.ion to entirely new areas win he made with much r;<>rv assurance. Thus, the correlated efforts of taxonomists,.engineers, and iveed '•>r.ti.sts in the AIU'A project has provided information that can be allied ••;th reasonable assurance 0on a worldwide basis, rather than being restricted ••• UK.- area of investigation. By July lDo'5, flic main emphasis in military research in horbieidos v;is on shortening the reaction time, of plants treated. However, the '-c!nif»!oj/v was so new—for military purposes—that precise perform';.-*• -'Kvifif-.-ifions had not bwn developed. As ono civilian scientist xpn-.-^ed it: ' .' • • . ' . . It iroos without saying that the materials must he applicable by grimiul and Jr fpray. Miat they mi'^t be logisticaily feasibk;, anil tliat they must be- uou** U.S. Pi-p.-irtmi-nt of A i f f l c u l t ' i r c . A e r l f i i l l u r n l Ki'itcnrch Sorvlci'. KcHcnrch Ki-port . . ......in-c "f Trn|iji-i)l nfi'l S t i l i l r i i j i l n i l Wdnil.v I'Jiuif.s ti> Clii'inli'iil Tri'iitnirntH. Ciinii't'i'it tiy f'-'l If. T"<-h!rl"v. Crojrn H'"<ouri-li Division. ISHKCM] on Iti'scnrrli C'miliicti'it tiv I,. V. JHOIIHI-. ( al. IJniliT AUI'A Onlcr No. 101. A d v i i n c p i l Hi^carcli I'riiJ'-i'tH Aci-ncy, U.S. I>i'|uir««iout [ r)cfrii«i', CJC-W-C7. I-'i-tiruury JOfiS (U.S. I>i!{iitrtniCiit <>f AKrlcnltiirc, 1(I«S), pji. 4-5. irt-'i;i, LU me usuai luiniary-nuiusinai couaiioratioa * * *. in t do not have rigidly specified characteristics. I have stated t-oinu o r o broad requirements that a successful defoliating chemical should have but. within th« general framework wo will accept and use materials that will do a job for u>. In a few years it may be that we will come up with more definite .specifications* * *.« . . During the first 5 years of defoliant use, the rato of increase was slow. In 1901, only.GO missions were flown; 107 occurred in 1002. However, by the latter part of 19C5 the rate of use began to increase sharply. (See tableS.) . . ' ' j . TABLE 3.—ESTIMATED AREA HERBICIOALLY TREATEO IN SOUTH VIETNAM, THROUGH 1053 < . " ' • • (Figures in square mils:! . Year 1962 1903 ., 1964 ...^ 196S 1966 1967 1968 Defoliation „.,' ...: >. .-....• Total!'...... .'. ... ., . ,. ' I J., „ .. 8 39 130 240 1,160 2,320 • 1,980 .-. • ' • 5.877 Crop attic'* Total itti sprayel I ' • (!) U 9 33 Ui 343 103 158 343 100 1.3iS 2.6G3 2,083 726. 6.603 1 Source: Letter to Representative McCarthy from Legislative Liaison, Department ol the Air Force, Mi-/15,13S3. 'Less than 1. > These figures do.not represent total acreaje soray figures calculated from missions flown, tank capacity, is estimated at about 60 percentof the indicated total. t 1 seres , ; about 2,540,000 acres anj tiic tolal amount of trsalment applied is aSout 4,226 ,BOO acres. Full-Scale Military Usa of IlerWaidcs^ 19G6-G9 • • • By 1967, herbicide usage in Vietnam began to level off. However, military procurement of "defoliant chemicals continued to climb, to build a stockpile of reserves for the future.- 3 According to au oflU'ial statement about the program, released in Saigon: Jiy December,' 10G2, Kan'ch Hand [code name of the aerial defoliation program unit] had completed two iiew project*. These were the defoliation of canals and rivers In the south and a pass south of Qni Nhon. In IOCS lines of communications targets included a powerline from Daliit to Saigon, the railroad from Saigon to I'han Thict, and other highways and canals. Bcx.-au.se ground tire and hits to aircraft were increasing, the Ranch Hand unit experimented with spraying at night with lighting provided by llaro ships and by moonlight alone. These operations were dj.seonthnied mainly iKK'nust- of the small chance of rescue in the dark. DofoUatiou derations increased in 10G-I, and hits on aircraft became more frequent until on April 30, one aircraft was hit 14 times, and the copilot was *• 17.S. Anrij-. Itlo!o»rl''ril T.nhonttnrli-s. CY<>[« Hivlslon. rrdr.'ptHncn of the First Defoliation Coiifcn-ni'i'. .Ttilj- 2U-IIO. ltir,:l. Itioliiulcil I/ihoriitorlvn. i-'cirt Dotrk-k. Marylivtul. Compllod hy Vi'Mtn /.. Miittle. M n n i l n r y l i n i t . AD SML'TXT 1). pp. 1.1. til. »lii'clnnliii; A p r i l 1. 11IU7, lullltar.v rnti'il onlrrn pri>-i'ni|it'Mi priiituetinn of 2.4.5-T f.ir use w l f t i 2,4 -I> t» proiliicc "(^riLri^n" ticrtiU'ldo, t h e most r>xti'iiHli-r'ly ijii'd cli^mlciil < i i ' f o l i n n t In V l i ' t n n i n , AH p r o i l i U ' t i o n liu'r^M^ciI :nul tnUHai'.v rt'qiilri'nionrs slacktriU'it. ;1i<* cotitrolx wort* lifted d u r i n g A p r l l - M i i y , IDfiS. They WITP t h > ' » rt'xtureil, and n i l Jinn 1 production wi-i.t to i n l l l t i i r y piiri'linsiTs. TlHTi-iifti'i-, n i l o c i i i l u n w n s p n r t l n l . and hy mld-I'i-C'-mhcr, Ifti! 1 *, t h n controls wcro t e r m i n a t e d . Slnro ttn-n. tin* i n l l U u r y H« i rvtrt^ havi* p t i r f h i i ^ t - d no hi'rt'!<*M«? nt nil. A c t u a l t>xt>i'ndiluri'!< fur m i l i t a r y h<>rl>!r!d<> rose from .flu,.") n i U l l n i i In the (lii'jil 101)(I to $45,2 million In l''.Y. 07, and rcnuiliicd ntiuut nt that Irvi't fur nnother �\v(.>..:nde-I. At this t^e operations \vere discontinued for mililarj" reassessment, tbcr vivtv ri'siiiri'^^^^ly with increased sorties prosr.'imed. A srii'liial iuci^^^H sorties continued during 19C-">. and in nud-Xovertiber the Kaneh Hand uu^^Hr almost doubled as three additional aircraft and crews arrived from the UfiHed States." In the spring of 19G5 the first systematic program of aerial spraying to destroy food crops was begun in Vietnam. A story datolined 'December 20 from Saigon, under the byline of Charles Molir, in ilio New ' York Times described this program as having begun "last spring." It was ':a politically delicate subject." According to the story, "officials say that no herbicide [i.e.; crop destroying] missions have beers, flown or will bo flown in heavily populated areas"' (such as the Mekong I.'olta). The missions were "aimed only at relatively small areas of major military importance where the guerrillas grow their o«rn 2r food or wheiv the population is willingly committed to their cause-/' By early March 19G6, crop destruction had become an important pliase of counterguerrilla. activity. A statement was made, public by the Department of State, March, £), reporting that some 20,000.acres of crops had Been ctascroyed to deny food to guerrillas. The areas involved were dexribed as remote and thinly populated, and "known from Intelli70nee sources to be occupied by Vietcong military units." The .state:-.fc also described precautions being taken in the crop-defoliation ..'mm to avoid adverse effects on noncotnbatants: ."..•* herbicides used are rr'-.'ifoivic and not dangerous to man or onieanl life. ".': !:;:ul is not affected for fi:r ir« use. ~';-e Yiotcong and n.-iy innocent persons in the area are warned of the gd.iimed a't.oa. Tney arc; asla-sl to leave the area. They are promised food and Eocv.3 treatii'. nt v.'hen they move out Tlio.se who have moved from Yietcons territory for uiJ.s reason havo b<?<;n fed and eared for.25 ' '' ""'•". . .. By Sfptember I960, the defoliation spraying program by aircraft, again?t forest cover had been extended near the DMZ.-'J By the end of rl:-it month, the possibility of defoliating jungle growth withLn the j/M% itself was reported to be under consideration by the ..Joint Chiefs or Staff'. It was also reported that Gen. William. C. Westrnors-1 and, C-mrnander of U.S.'.Forces in South Vietnam, had asked for Presi-:>,'.","!a! approval to'u.se herbicides to 30 defoliate 50 square miles of the ;ii?:_r!e-covered mountains of tluiDMZ. By early IOCS, the program had been well established for botli reno •,-;•.! of jungle cover and crop destruction. The31Department of DerVr,.-e released statistics covering the year 19G2-G7. At about thi.* same ti.'iif-, it was announced that the Air Force was "preparing to slump 10 million gallons of vegetation and crop-killing poison over South Vicrnam in the year beginning in July" of 19GS~f>f). The chemicals required would cost $70.8 million. The report concluded: "FHgfots of '-* At rcp"'t''<l !D: T«k««M Oka. "Tight Controls Pinpoint DffoHntlon." CtrlBtlais ^So-lcnco Sf-oif.r. ur.ir. 2S, J O C ' l i . p. 4. ^O'hari"* .Mohr, "U..S. Spray PJaacs Dcstfoy KIce In Vietcong Territory." Sew i'orfc r:-'..--. (J)'-c. 21. l!n;3). p. 1. " 'V.H. TcllH of C'rop Dctitructlon In South Vietnam." N'ow York Times. (Starch 1<S. IflfiO), >. (>. " T.R. In ncfnllatlon NVnr nnffer Zone." (Story fiatellncd Silicon, Scptembnr-sa.) Ni'W lork TliiiPd. CSi-pt. 24. l!)(5<J).j>. 2. kv 'Krnnt-I,!i>(> T;n!t« Hnck I)i-f»!Iiitlon." New York Times (Story DatcllawJ DaruuEK, Sept. !S) ! New York Tlmps. {O.'t. 2, 1!HIO). p. 7. * "(;.H. To KxiiunU I>cfulltition la South Vietnam." \Va»hln«ton Post. <May 13. IOCS). >. A-17. Air Force C-123's equipped with 1,000-gullou < tanks began in 1962 with a modest 107 missions. Chemical OL have continued to escalate, however, and by 1%G, U.S. pfl flying more than 3,000 spray sort ics a year." '•' ^^^ In actuality, the military use of herbicides in Vietnam^Tached its peak in the fiscal year 19G7, and declined somewhat in each of the following 2 years. Whether or not in response to the cautions expressed by Dr. Tschirley of the U.S. Department of Agriculture (see pp. f>051) and Dr. Pfpvft'er of the University of Montana (see p. GO) there was evidence of an increased military restraint in herbicide usage. The complex mechanism of defoliation target selection that had evolved to apply the expanding criteria of suitability (?f-e p. IS sq.)' provided opportunity to bring these cautions to bear on military herbicide operations. Moreover, with increasing experience, the military services themselves had become better able to judge both the values and the limitations of herbicide application. By May ipC9, the Department of the Army was preparing to issue a new manual of instruction on herbicides for troop use. (See app. A for text of the draft.) In addition, the Department of the Air Force was soliciting a contractor to perform work looking toward the "ultimate goal" of a "handbook for Air Force base civil engineers with worldwide recommendations for effecting vegetation control."33 DecinoMnaking Arrangements for Military 'Uses of Herbicides in Vietnam The complex political situation in Vietnam has resulted in numerous difficulties in U.S. support of .the Republic- of Vietnam (RVX). Military and political decisions are complicated by three Pels of cir: cumstances: (l)'by the informal nature of the undeclared war. wir.ii its mixture of regular and irregular troops confronting RVX and •supporting U.S. forces; (2) by the mixture of economic motives in •which the progress of the KVJS" toward economic and political 'Sovereignty by replacing a colonial economv •..with... self-controlled . 3 ~ * ^ ," a i i i' economy »' » f •» I* i i -j , .*, • _„• n t quiring coordination with U.S. military against.guerrilla and North Vietnamese forces. The use of herbicides in support of military objectives is similarly complicated by these sots of circumstances. Although extensive U.S. military forces have l>een brought into the territory over which IJVX asserts "sovereignty, the role of these forces is as invited assistance in support of a friendly nation. Accordingly, the use of herbicides, a novel form of military technology, has required two-sets of formal military approval. In addition, since U.S. objectives in the area encompass not only military but also'economic and sociopolitical goals, the actual field plans for usage of herbicides for military purposes has required review for military, economic, and sociopolitical eti'ects. ""U.S. To Increase War Use of Crop-Killing Chemically." Washington IVst (Mai 10, lOilK), pt), " "KMiOiirch and Development Sources Sought." Commerce Business Daily. (Mar. 2$, 1000), p. 0. 32-405—-OU-- �Insofar asU.S^HJlitary forces are concerned, the All-Service, Mannal of Armed I^^A Doctrine for Chemical and Biological Weapons Employment a^^^pefenso34 specifies that "The President <rf • the United States nmKes the decision to.employ CB weapon?." Also, "'The ileeision for U.S. forces to use chemical and biological weapons rests with the President of the United States." It adds35 that "commanders urecurrently authorized to use .* ,* * defoliants." Defoliant is defined in this manual as "a chemical used to remove prematurely the loaves : from plants." " ' . ' • • . - . . ' . ' Although the President, of the United States received, an it acceded to, :i request from the. IIVX for the uset>f herbicides, the policy was ?.~t- Mished at'the outset that proposals for defoliation actions would [•-; initiated, by the Vietnamese people, locally, and would be reviewed !-y l.-oth military and economic group?, and by both United States and Republic of Vietnam authorities. A statement issued by the Depart-, :•: ' 'if Defense, late, in 1%7, describes in general terms the naodus. \.--^ ••• rii involved in. this program, as follows: U i* the jK>!icy of the Government of Vietnam to take every possible s'tep to r.Lif-:- the prod'^-tinn of fowl for its people. It is the policy of the United Suites to assist tue Vietnamese in this effort. Many steps have been tak»-« in tlae past in thi.s direction—through the import of fertilizer, the introduction of new strains • >! livestock, improved growing teehiuques, and other methods. As a result of the. r •••.-r.t Honolulu conference and the visit to Vietnam of Secretary Freeman arid :;m of agricultural experts, new and. more intensive efforts are lieing" mndcr• ; •:: in this direction. <;•• question has been asked how can we and the Vietnamese fry to increase -.-•! production, on. the one hand, while defoliating trees and destroying:-crops, j.i the other. First, these, two matter.-* should he separated. Defoliation has been used to deprive Communist guerrillas wlipw? poss-uhle- of r-*»vf-r and concealment. It is used along roads, railroads, and canals wh<we the V'lefi.-ong. have regularly taken advantage of thick foliage to set up amRnishes .-.jninst both military and civilian traffic. It is used against remote Vic.teotss hase i ?-,:.-: where, the Communists have used thick natural cover to conceal! their f-.--av.My fortified training and recoupment centers. It is used against laiowiu trail rni]r--s winch the Communists have used as supply channels for men and weapons in South Vietnam. . . In some cases, herbicides have been used to destroy crops in remote- areas !•••::;: occupied by the 'Victeong. Tlie areas affected are known to be nsscd to ;•.- .cliir-e fix>d for Vietcong m i l i t a r y units in the area. In war, food is as <essen::al to the effectiveness of u military u n i t as its weapons and flmuimiUiora. Several things should be noted in this connection. The areas nfleeted Biy this ::.:!r(-'l crop destruction program are remote and thinly populated. Tlwey fire :.:"-.v;i from intelligence soun-es to be occupied by Vietcong military iiuifts. The • ••••'. -ifli-x used are no-itoxic am! not dangerous to man or animal Jjfe. Th«- land - •'.'•it :i fleeted in terms of f u t u r e u.se. The Vietcong and any innocent pcrwons in - .- ari-ri arc warned of planned action. They- are asked to leave the urt>;*v. 'They :•• promised f<cid and good treatment when they move out. T!in«<> wl«» have - .;v.'d f n u n Vietv-.-jng territory for this reason have been fed and '('anil ifor. A scfoml j K i i a t — a l l defoliation nnd crop destruction actions ane initialed liy :.i- Vietn:i:;n'.-f themselves, lisually a district or province chief who has located iri nr.-ii f.f's;i<nvn Vietcong oc'-npation. . Tie- run-raff and te<-iiri(<-,il capnbiiity for this program are IiiwJy Ani<e.ri<-aii •i.-nj.ly tK-<-:Mj>(; the Vietnamese do not yet. have the personnel arsil oquFifluneiit •-rivwiry. I'.nt tlien- is Vietnnmese participation at every stage anil tlm iiiiil.ijitive '••r all sueh programs Is entirely Vietnamese.1" « F M 101- (O/NPW SflfrWAFMaRB-S/I-KMO 3, DnimrtmontH of (lie Artny, in<l Ilio Air Kon'p, April, 10(14, p. 3. " l!.i<l.. p. 4. M l w - [ i t i r i n i e n t f>f DcfpnNc. "TJifi U«> «f Dffollunti in Vietnam." (Oi act hln-ft. No ilntc.) Navy, . A. news account, of this program of target selection early in 19GG, described it as follows: Setting up targets is a ticklish diplomatic business. Xo eitljer United States or Vietnamese'army commandi-r.s, but if an Aai»rieai; wants a target sprayed, he-has to pass the recommendation on to a Vietname-e officer, wliO goes over I he target with the province chi>-f. TiK-n tlif- refommenil.-ttion goes to the Vietnamese Army's general staff in Saigon and, if approved, the request is sent on to the intelligence section of t h e U.S. Military •Assistance Command—Vietnam in Saigon.1" • • t In pnu.'tiee, requests for approval of herbicide targets'.proved up fr\vo parallel chains of command. Specific approval or disapproval actions are required at each level of both chains. One is the Army of HVX chain which requires approval of the district and province chief, and three other levels, before being, submitted to the U.S. 'Military Assistance Command—Vietnam (MAC-V). The other is the U.S. chain, which runs through district adviser, sector adviser, divisional senior adviser, and corps senior adviser, before going to MAC-V. Approval by these officials carries with it the assurance of approval by local civilian U.S. technical authorities (AID, etc.) at These levels. At headquarters, MAC-V,. the target requests, countersigned up both chains, are coordinated, with Joint Staff intelligence, Joint Staff operations, the Chief of Stall, the Embassy, U.S. AID, and two civil affairs groups—the civil 1 operations revolutionary • development support (COUDS)_ and the psychological warfare'directorate (MAC-PD). Coordination is managed by MAC-V ofiice 20:>. Only when approval lias been completed may the proposed target be scheduled." • An" indication of the scope of information needed to accompany a target-request.is the following "Checklist, for Defoliation Requests" prepared f o r u s e i n this process: • ' • . . . CHECKLIST FOR DEFOLIATION REQUESTS* ; 1. Overlays or annotated photographs depicting the exact area. 2. Target list: . , . . . ' (a) Area—Province and district. . - . ( & ) UTM Coordinates. .. ' . :' . (17) Length and width. • , (il) Number o f hectares. . - • " . ' . - • (c) Type of vegetation. . 3. Just ideation: '. • .. , ' .. • {«) Objectives and military worth. ' -. ' (6) Summary of incidents. • \ 4. Psywar annex (prepared by sector) : '• : . • ( < / ) U-allets. • .\ • • (fc) Loudspeaker tex.ts. ,. 1 C, Civil aft'uirs annex (prejiared by sector) : •• (a) No crops within one km. (l>) Contingency plan to provide food or money to families whose crops ure. accidentally damaged by the defoliation Deration. 0. Certification by province chief: ,. • (</) I'i'oviiXT chief nppi'ovul. . . . (l>) Indomnltieatiou will he made [by IIVX] for accidental damage to .crops, • • • '- •.; .•' . .. A major consideration in decisions to approve u proposed target for ^rbicido application is whether it accomplishes a military objecfivo In V l i ' l n n i n , " N n l t n n n ) OliMTViT, vol. 5. no. 0, i-me « W Pi-mien " l i i --d i H u M n iir ti I'N'liriMiry '.'«, l!>iirt. <.iimti'il In M l i t lti-|»>rt. Oi>. clt.. p. 12(1. liifoniiiitlon pruvliltnl liy Dr. M l n n r t k , May 5, i'.KKl. "Source : Mlineotjriipli »hcct HU[>i>llcil l>y Pr. Mlniirlk. ., 3-1-. �for its adverse_eiu-ets on the economy of the .country. There appeal's tci be no question but that the program has injured the economy— '-.' rough iiitidvertent damage to rubber plantations, injury to tiinber .';--:\~. and'tlrift onto food crops, for example. Inadvertent damage is r : ; .'.rently inescapable. However, it is reported that complaints of '-,'. .i vet-tent damn go, collected and reported by U.S. AID, which ;.-.r"icr -were numbering some 30 a month, had'been reduced to 3 a r<cv!-th by early 1D09.SO Constraints on the program are imposed by physical circumstances. [\-foliation is most effective during the growing season, and is much • •- effective and slower at other times. The type of foliage to be at-' •'• ;-iilons (32.25 pounds) per acre. It is delivered by 10 aircraft flying at .-r altitude of 150 feet, at an airspeed of 130 knots.- To avoid drift -.:"!' for spraying during early morning hours "while inversion tem•••--M ture. gradient, 1prevails and the wind speed is still low (does not :: c-dSknots).'" ' As to the rate of application of herbicide, Dr. Minarik has said: T; is potent herbicidnl mixture [i.e., ORANGE] is being applied without ';••.-. •• -Q ; but this is necessary to reduce the number of sorties required to. • --.: .in area, of a. given size or to state it conversely, to maximize the area • -.-.:•;.: jt-r mission. ' . . . . . . Ti:n.v- gallons per acre deposit is employed. We-would prefer to u.se less i f • could get uniform deposition, but in these dense jungle areas where there : . !j be 300 tons of veg'/tatlon per acre, this is the minimal effective volume. ".;» Z gallons contains 2-t pounds of herbicide on an acid equivalent basis. This''" i-rii dosage rate is also a requirement since much of the vegetation consists ' r tr«c-.-3 100 to 1ZQ feet tall.'- . - Military assessment of the program lias been sustained throughout, nd has received the participation.of both scientific staff people in • lie. Pentagon, and military, and civilian personnel in Saigon. An . coount of the course of this assessment was recently reported in lie following terms: -' .• • Prior to operations in Vietnam the DOD sponsored research by tlie Departi-ijt of Agriculture in Southeast Asia, I'uerto Rico, and Texas, to ascertain ;t- effects of massive herbicide use on analog vegetated areas. This research. . suited in two rather lonjrthy rei>ort.s [which wen?] : . "Foiv.sts or Southeast Asia, Iii<-rto Itlco, and Texas." U&DA Report CK-32-trr, September 1007, AD-W-IOTO. "Research Kfport—Kesi>onso of Troplnil and Sub-Tropical Woody Plants to Cheinic-al Treatments." US DA Report CR-1S-07, February, IOCS, ' ' • " Based on those studies, and nr...-it the knowledge, t h a t the use of of millioiin of pounds of lurrbield-- in the United States over 20 stiirtliiiK adverse effects, the l.'nited States proceeded with the gram for the purpose of increasing visibility in heavily forested nmbTish along roads and canals and to increase ground and aerl:iWP^veilUiii'.-e of Victcong hideouts. The use is restricted to South Vietnam, -always with the approval ami usually at the request of South Vietnamese authorities. ISeqm-sts for approval are considered at s(fveral levels of military and civilian authority, both Vic-rnainese and United States. In all cases approval of the province ehi.-f, and the central government is required. Realizing that the area of I'niK-term ecological effects of massive u.«e of herbicides was not very well known, the DOI> siwn^ored a study in 1007 to collect the available information. This study is * * * as follows: "Assessment of Kcologicsil Effects of Extensive or Repeated Use of Herbicides", Midwest Kesearch Institute, Kansas City, Mo., December l'J<J~, AD-S24314. . The study dealt largely with the effects of herbicides in the United States, whore massive, repeated use has been carried out for the i>iu'i>o>es of crop, rang*-, and pasture management, right-of-way maintenance, and 'control of weeds in . waterways and miscellaneous areas. * * * We requested the National 'Academy of Sciences to review this report for accuracy and completeness, which they did. The report and the review were then sent to the American Association for the Advancement of Sciences for consideration by the Board df Directors . * * * Subsequent. to this effort, Ambassador Bunker of the U.S. mission in Saison convened a group to consider all aspects of the herbicide operation. * * » The technical study contributory to [the release of data by the mission] was informed by Dr. Frerf Tschirley of USDA, who published his findings in Science, yoluine 103, February 21, 1000. He has recommended that ecologic research be conducted in Vietnam after cessation of hostilities, that continuing assessment be made in Vietnam, and that defoliation be conducted in strips or checkerboard ' patterns to leave undefoliated areas for seed source and wildlife habitat. His .'recommendations were endorsed in principle by Ambassador.Bunker. * * * " . Indications are available, that the"sereeninc:.T>roee?s for a'-^'-'u-ul of herbicide targets is more than pro forma. There arc many assertions that no aerial herbicide spraying has been conducted in the large . delta area south and east of .Saijron. and no evidence has l«en i»und to the contrary. Also, according: to Dr. Minarik. a number of province chiefs have given a general disapproval to spraying within their jurisdictions. Crop spraying has been sharply reduced in IOCS-GO. Reports of complaints or damage claims are also at a lower level than formerly. Tlie.se circumstances seem to suggest that military use of herbicides has become, increasingly selective and t h a t controls are in etl'ect, subject to many different sets of criteria at. different levels of review. Tho extent to which m i l i t a r y control in the field of the use of herbicides is responsive to policy direction from the Oflioe of the Secretary of Defense, and the, exlent- to which this policy direction has been responsive to technical studies undertaken under the. stimulus of criti•cisms of tiie program by outside scientists, are matters of pure- speculation. However, it is evident that the. program has received a great deal of oflicial review at many levels, and also that it has been the subject of a wide rango of expressions of concern by many scientists. Tho record of these expressions of concern' is surveyed in tho two chapters tO follow. « C. i-:. Ml.inrlk. "The C«c of [lerblrldfs in VIMrinui." Paper delivered hofore N'ortbi'astcrn ff-'l (.1-111 ru! Conference, New Ynrk City, Jim. IttiiH " I > n i f t Imuniir.l nn uno of clivintral nh'vnM, rliaptor on "Antlpliiat Aifitnt OncriiUonu. I'-i'I" ',, ' 1 '<- |lIll 'V'l Aspt-clK" MS slimmed by Dc[in.rtr.ifut ot UeCcuge. N'o Uate. *• ilin.irlk. Op. clt., p. 4. n u t.'.'ttf'f frcitis It. I,, Iliirrls. TVptity APsNI'ntit Dln-cfor (Clicmlcnl Ti-i'liniiln«y). to 1'MlVssor CimrlON Tuwin% Dcjiixnmrnt uf 1'lu'slcn, University ot California, at Apt. 23, HHJ!J. �IJL CIUTICIBM'OF HERBICIDE WAKFAKE | Various gi •j^^^were found for expressions of disapproval of the I use of defoliail^^HSnicals in Vietnam, when directed against guerrilla i crops, or jungh^Wver. The earliest criticisms questioned the military 1 effectiveness of the technology, and the risk of inadvertent injury t< 1 Vietnamese crops and plantations. For example: a » ^ ^ - - - * * Our chemical warfare people have been very unhappy for the last 4 or I "> years about the whole operation. * * * Defoliation is no new gimmir3£ with . ... „,„.....,.... j./1-iuiiiuKm is Kinimir a tin- Army Chemical Corps. They have come here ami shmvn no t,i..(n~,^ rtiad toij 1 the Army Corps. They here and shown us pictures ~-..i us that in some areas it was not effective. It was not tactically successful." I An early protest by scientists against military uses of herbicides was | contained as an addendum to a statement on biological and chemical jl weapons-adopted by the Federation of American Scientists, at a spring | 100-i meeting of the FAS Council. After urging "nofirstitae.?' of | chemical and biological weapons, and discussing these at some length, I the statement concluded: ' . , r a e o a n g aigents h.:ve t'OL-a used to destroy protective cover have boon continued by reprawentaI tivt-s of the Department of Defense. These charges give rise to the broader fmpli|e,iriou that the United States is using the Vietnamese battlefield as a psrovlng I fi'-.iurifl for chemical and biological warfare. * * * We are * * * opposed to je.':;vr:nientatlon on foreign soil, and also feel that such experimen-tation laivoly-|:r'~ citizens of other countries compounds the moral liability of such actions.'* - • I Later, when anticrop K.-.--J of defoliants had been adopted as a policy | in Vietnam, a prou;.-:t was addressed specifically against this practice . I by a group'of 29 scientists from the Boston area, under the, 'leadership' '" "•• | of John Kdsall, professor of biochemistry at Harvard University, in ' ; January 1966. However, the remedy sought by the protesters was the , e proesers was te abolition of the use of defoliants. The group appealed to the President "* * * to proclaim publicly that the use of such cheaiical 1 weapons by our Armed Forces is forbidden, and to oppose their use I'.'y the South Vietnamese or any of our allies."' According to thcr |-*V.-:raent— • . ' .*•,' 3 Kr.-n if it can bo shown that the chemicals are not toxic to man, such tactics •.I;.-- barbarous bccausi? they are indiscriminate; they represent an attack OTI the I 1 :. riff population of the region where the crops are destroyed, combatants and if i •:,,T>jjib.itnnts alike. [Moreover, such attacks would serve as a] precedent for I !.•• «:.•?(; of .-cir.-iilnr but even more dungcroti.s chemical agents against our allies fJTj-i our.xdves. Chemical warfare is cheap; small countries can practice it <cffeeI'ivp.'j- against us and will probably do so if wo lead the way. In the long raw .the |;-.- ,it .•.-iK-h weapons by United .States is thus a threat, not an asset, to ouar na|i'.f;.-il security ,** | During the latter half of 19fiG, a move was initiated within tho ;,.-. •i.-iber.-Jiip of the American Association for the Advancement of ?-'• ii-iiro (AAAS) to formulaic and adopt a policy concerning rnuliI ;;ry use of herbicides. The lengthy process of assessment by the AAAS I -J " I'.S. CII.'I^T '•(•». Ilnnxe. Coti»iillti>c on Appropfjjitlnris, Drjinrtuii'nt of IVIVn.so Apffiritj.'l.-ifl'ii.i) f...-- I'.n/ii. IIcnrlniTH brtotf u Kiiticniiiinlttfc of tlin . . Tnrt 5, l!«\sp;tr«:li. IVuu-liip.?•:?:.-.•. To«t. .in 1 1 3«s-». ! >:,!, iti'i.o) :<{>. Hrniiiallon. Svith CuiiK,, lut KPH*. ( Wunhhitttou, U.S. Oovi.Tuuu-Ht 1'riaitlni; •1 -!--(. (OirtolH-i- I l i C j ) . on Itlolodcal and Clirmlcnt Warfare." Ilutlclln of the Atomic Stdcn•"•K.'.H Stati'iiif-nt. |. [i. 4C--1T. ij I « "Mcieri(!.Nt* i'rot.'st Viet Cruji Diwtruotloii," Science (Jan, 21, J!)0(i), |), 300, is the subject of the following section of this study. The remainder of the present section will give illustrative examples of ^Ife protest, movements, during 1967. and after, that lent prominemj^^HiH is.sne. A more broadly based protest of scientists against "ai^B^akt-ning of the worldwide prohibitions and restraints on the use of chemical and biological (CB) weapons" was expressed in a letter to Pn-sirlcnt Johnson, September 19, I960, by 22 scientists from 12 diil'erent edu'-ational institutions (seven Xobcl laureates). This group related to ' ; CIJ weapons" the "large-scale use of anticrop and 'nonletlwl' antipersonnel chemical weapons in Vietnam." Tliis activity was seen as a "dangerous precedent" because "no lasting distinction seems feasible between incapacitating and lethal weapons or between chemical and biological warfare." These chemical and biological agents formed a "continuous spectrum" such that "if the restraints on the use of one kind of CB weapon are. broken down, the use of others will be encouraged." Ac-. cordingly, the group urged the President to— "Institute a White House study of overall government policy, regard i:ig CB weapons and the possibility of arms control measures * * *." . "Order an end to the employment of antipi-rsomiel and anticrop chemical weapons in Vietnam." "Reestablish and categorically declare the intention of the United States to refrain from initiating tho use of chemical and biological weapons." */ Both lists contained the names of four members of the faculty of the Harvard University biological laboratories. These were: .£oim E<lsidL Matthew ^ S. ^fcsolson Keith.. Po'ter . were -'crecTTfecl, late Tr7 10GG, with^collecting tiie signatures of more than 5,000 scientists as cospo'nsors of the ' Adviser. "The originators sent out 50 to 100 letters and the Federation of American Scientists sent letters asking' its 2.500 mombers to get signatures, tho men explained." 40 Among the signatories of the petition were IT Xobcl laureates and 120 members of the .National Academy of Sciences. Those prosontiny tlm petition were Meselson, Edsall, and Paul lJ>oty of Harvard, and Irwin C. Gnn?alus of the University of Illinois. 50 _ I n midsummer 10(17, Kdsall again attacked ant'uTop clieniii-iils. His views appeared in Scientist and Cili/cn, a* journal ptiblislu-d by tho committee for environmental information, St. T.ouis. Mo., in a special1 issue addressed to the subject of chemical and biological wurfaiv. II* asserted that "fateful p^ol'u'V dec|sioiys,iregar(liii'ig .X.l.!g-(.to-yj.'io|)-UiciiLaiiil l^^L.o.I_fxliCmL^AiiindJmib4d^4-^^^ n mv . confront us and olhi-r peoples throughout tho world/' The immediacy of such doi'isions, li«» went on, "largely arises from tho use, by our own Armed Forces in ""SclcntUtrt Speak Out On CK Woupons," H u l l . -tin of tin- Atomic Scientist* . p.. .'!!>.. " "C»--Knt<-rln« Wcilue," Th« Nntlnn. (.Tan. 1rt. inr,r>, p. (IS. • ' -• : •"".1000 Scl'-iitlsts Asl< Hun (in (ins) In Vli-tiiiim." WiiHlilinrton Post. (Feb. 1.1, tOi'.T). . A-'l. 1 *> "Chemical u»J I!lolo«lcnl Wiirfaro IVtltlon." Science. (Fc-b, 17, 11)0"), p. SIS. �Vietnam, of ^ ' gases in military operations, and of defoliants .and herbicic"* destroy crops in areas under control of the Viet. lu the of the journal, Jean Mayer, professor of nutrition at Harvard University, attacked the use ofmh^ii)icj^l£|_jtfi^d.ejitrj cro l;£Ji!L!k!L!l?J£^^ ?'c.ili£U£. °J 4Lll^X^'an^211lllilii2i1':; IJ-e contended that military services, TiiclutlTiTg even~"\ lefnamesIT'guerrinas, had better medical care than civilians, and-also "Vieteong soldiers may * * * be expected to fret the fighter's share of whatever food there is." He drew parallels. from instances of military blockade in history, and asserted that "food denial in war affects the fighting men least and last, if at all, and is, therefore, unsuccessful unless accompanied by military victories by the blockaders. It is hardest on civilians, particularly children and the elderly; -where economic class divisions are sharp, it is particularly hard on the poor." " Another article in the same special issue of Scientist and Citizen, by. * When we intervene in the ecology of a region on a massive scale, we >et in motion an irreversible chain of events which could continue to affect. ;;.'_> agriculture and the wildlife of the 'area—and, therefore, the people, -!..•-. 5 after t h e war Is over. •' .• . - . . Gali'ton referred in his article to a letter which he as one of 12 plant hysiologists had written to President Johnson (and that had been c--produccfl .1in the ii._ January 19G7? • ,.f -i Bioscience, •p. -.10): this letter issue of • 1 1 i • _•< j.!,_j. ...:.... . . . 11 concentration of toxic herbicides, or of toxic reaction products with the- soil, in food chains; soil erosion from contatnin.it^Hfcdl bared of foliage; wide-scale self-poisoning of plants by toxic P'j^^H' stimulated by the herbicide; injury to fish and wild iiiaimnalsjcjprdeliiyed toxicity. . In summary, the Galston-article concluded: ' We fire too ignorant of the interplay of fonvs in efolo^icnl i>rolil'. p rns to know ho\v far-rc;ic)iiiiK and how lasting will be tin; (•h.-inyc's'in tc-ol'Cfy brouxlic about by the wi'd'-spreitd sprayijis of herbicides in Vietnam. Tlio-c clia)is<".< jn.;y include immediate harm to people i t i - t h u sprayed areas and limy extend to .-ftri'/us and lasting damage to soil and ngriculture, rendering more dillicult Kouth Vietnam's recovery from war, regardless of who is the "victor.":l . The association of herbicides with chemical or biological warfare, germ warfare, poison gas, and other "inhumane" weapons was p^n.'erally characteristic of the numerous letters to the editor and as.-om15on protests during this period, attacking the use of defoliant chemicals in the counierguerrilla program in Vietnam. To an indeterminate extent, of course, these protests reflected a generalized dis-'••* • • - IP -...i T T C « ..*.t~'.~.^t.'< in "arms control and disarmament" as a new uueiieciutu uiscipune. and the development of criteria to limit the kinds of weaponry used in .war or used a^ "deterrents"; difficulties "were encountered in distinguishing between the military use of herbicides to gain military advantage and the use. of various chemicals having direct physiologica"! effects on nvnvrplevant to warfare, and particularly those frum-mr within the scope, of the Geneva Protocol of 102.V? • '•. tbitants, according to Galston, were the alleged toxicity of cacodylic :;.[: " injury to crops from drifting spray or volatility (there ifave •'••! about 500 complaints or requests for compensation filed with .ifjik-t chiefs for transmission to the- province chief in one urea alone); "John T. K<!*a!t. "Introduction." Scientist and Citizen. (Vol. 9, No. 7, 1067), AugustS'-rt-ml.vr. p. 113. "Jean Mayer. "Starvation as a Weapon." Scientist and Citl/en. Op. cit., pp. 110, 121. "Throughout the course of the technolog!<;al assessment of military use of herliiddes In V i e t n a m , one element at Issue was the toxicity of these chemicals to tnan and animals. Czro'lyllc acM was hlnKlKl out because it contains the element, arsenic, within Its complex E:'-:ecuhir structure. Since most itrsenlc-containing compounds are highly tosle to man &i.d anin:.il^. the a-^urnptlon WUH made that caeodyllc aeid had this characteristic. However, t';^ i f K I Ki'i-irt, a f t e r snrveylnff tl.e l i t e r a t u r e on this point, ohservcd (p. 1C-I) : "In the <••!,.'ninatinr. of th« potc-ntlnl toxicity hazard for this compound, \ve are jmrtlcularly l~. ; , r ..,,.-.,j (,y the ]v,w oral tuxlr-lty." Dr. Tsehlrley, In his report at SalK"ii (see pp. SO-'U'), g i : t-- c'-inparittlvtt lethal dosage rates of "ARent Blue" (coDtiilnitii; <ir> percent cacodylic • aci'li and "asiilrin." The terms he used were "I-D")!)" or nveniKC lethal dose In mllllKrnmx t.f chemleiil p*-r kllngram of bo<Iy wi-lfht. The Hfruro for "Itluu" IK 2000; the figure for " A « p l r i n " M 177.".. In his report nt .Siil«mi fin "Toxlclly of Ilerlilclile.H in f'se in ICV.N." I'r. Min.-crlif asserted t h a t it wa.s "currently helnj; em|ilciye<l nt a rate no higher than !»..T [and thi-rcfnre]. It i» safe"to assunif'thttt there, w i l l hi; no harm to nmu or anlRi.-cU nt tin rat. •*." / . . • ! • , f 1 . , . • -I . .-<, sum mi- 1^.1 m.n. , .,t v^. t<>n..>i^ employed were in common use in th.c United States. (The rationale was similar to that used to justify the employment of tear gas (CS) against guerrilla forces; this kind of agent was, in fact, in general use by civilian police forces throughout the world as an antiriot agent.) .Some confusion was contributed, however, by the imprecision of military usage of terms. Thus, the Joint Chiefs of Staff Dictionary 8 * defmes'herbicidc as "a chemical oomnouud which will kill or include? "omplants." Chemical warfare is extended, by definition, to incl * *'' 7>lovment of chemicals * * * to create a military advantag . Biological war faro is defined as "employment of living organisms, toxic biological products, and plant growth regulators to product- death or casualties in man, animals, or plants or defense against such action." <" Arthur W. Galstnn. "rhnnjrinir the T.nvlrontuent." Scientist nnd Citizen, op. cit.. i. 12.'t-120. Pr. Gcilxhm wns* professur of biolocy at Yole tlulvvrslty. imst presiitent of e American Society of I'lnnt I'hyMologlsts, ami pri-shlent-olect of the Botanical Siieiety . illspi-rxm] In nature, rind oceurs n a t u r a l l y in the Koli nt rnteu milistiintlnlly higher thnn thnt cnntriiiuteil hy thf- siiriiyinj,' of areas at the rate of !>.;) pounds per iicre, the additional nrnenlc from caeodyllc: uciU can apparently be regarded an trivial. lilclrth - J oiv.n t Chief* of R t a f f . Dlctlonarv of T'nited Ktatea M i l i t a r y Term* for Joint w U.S. i (Short Title: J O ) . (\VanhlnRton, D.C., U.S. Government PrlnttiiK Oillue, August 1, JC'S 1'ub. 1. ' �Clearly, by th&?e definitions, herbicides arc, both chemical and biological \vaVf:n"e &£«.^|fcj[Iowever, the same definitions would also esncom- . pass the use of^^Bcieidcs to control typhus epidemics in relocated refugee camps.^d^ On the other hand, it can be plausibly asserted that the use of .tear gas to flush guerrillas from tunnels to face hostile bullets; or ifee denuding of foliage that conceals guerrillas from hostile fire, are both forms of chemical warfare with ultimately lethal consequences. In tluvo two cases, the chemicals are not the, direct cause of defttla, but, :-:ui l>e regarded as an accessory before the fact. Acceptance or-condemnation of chemical defoliants on legal or moral grounds therefore ap;x?ars to hinge on whether those judging the action find the conflict; iu-i-lf acceptable on legal or moral grounds. Evaluation of the anticrop program appeal's to have followed somewhat the same rationale. The "scorched earth" policy in warfare tends :o l>e praised when conducted by one's allies—for example, the [J.S.S.K. in World War II—and condemned when practiced by/one's i-iversary—for example, the pollution of wells and waterholes daring : i :> withdrawal of the Turks from Arabia in World War I. The introduction of the concept that belligerents share a responsi".'••: for preserving the ecology of the area of conflict is a very ' -.--; development. Presumably it is an outgrowth of several con••;iry trends: (a) the concept of limited war for limited cJbjec'. ,•- . generally regarded as made necessary by the development of ;•••• uiously destructive nuclear weapons that enable nations possess-. r.g them and their means of delivery to inflict "unacceptable" <da-in-' .ge on other nations in a general war for unlimited objectives; (&'| the nonr.ous potency of modern chemicals, whether used in military cam- " "."': iaign.s or for civilian pursuits; (c) the increased concern .of scientists . , •>r the protection of the total world environment-to preserve its bsafeit- ' :.' h>ijity for mankind at largo, and (d) the recognition that the human •opulufion of the earth is expanding at a rapid rate, and is now ffore. ••;• n to IJQ approaching the limits of the capacity of the earth to sustain . • . In.-re.isingly, the-criticism_ of the military herbicide program in "u-tiiiuii by some U.S. scientists has focused on the ecological issue, f was .-tressed by Galston in his article for Science and Citizen. Tt -vvas ;<j main question considered by the AA AS (as discussed in the auction f _tins study to follow). A strongly worded, forensic stutemerai in '•ientisf. and Citizen in mSd-1%8 elaborated on this theme with :.~rv.-_t to piclorain, a newly developed herbicide- being iutrotlmcetl t military use iu Vietnam. The article stressed the unmatched potency f the herbicide, its longevity and uncertain fate in the soil, the d:taiger * its migration either along food chains or watorl>orne, the possibility uit if.s extensive application to tropical soils would expose therm so ; to cause luterization (i.e., a process by which some kinds of soils in iC Tropics when exposed to the sun become infertile and too Shard > plo\v)j ami tl i;it. death of trees would cause t!ie death of many ami-. ;tl species. Concluded the article: "The military upped for [i.e^-of] !-n for this herbicide is obvious; pilots-spraying it don't have to reapplication. Bub the Vietnamese farmer wants to re^ Also ill 19G8, Professor.Galston took his case against r y use ngdom. of' herbicides to the scientific community of the United In an article in the British journal, Xew Scientist, he declared that "The United States, which was the first arid so far the only nation, to use nuclear energy 1'or military purposes, has recently become the first and so far the only nation to use m war chemicals directed against rowing plants." The eiiects of this action, lie said, were unknown and gro possibly disastrous: -One must conclude [he wrote] that the ecological consequences of the widespread use of herbicides Iri Vietnam are unpredictable. We are certainly. rtoina some damage to the ecology of Vietnam; just how much and how long lastin will bo discovered only after the "experiment" has .boon completed." Earlier, Galston, had denounced U.S. plans to "prison the_son'^so as to denude completely the vegetation from a strTp~^r7ancr"goTTig entirely across Vietnam from east to west. This mamnade desert [he wrote] separating Xorth from South Vietnam, ami presumably serving to prevent infiltration, could have ecologically cata-strophical consequences which cannot at present be envisioned. In summary, we'are too ignorant of the interplay of forces in ecological problems to know how far reaching and how lasting will be the changes in ecology brought about by, the widespread spraying of herbicides in Vietnam. These changes may include ^immediate harm to people in the sprayed areas and may extend to serious and lasting damage to soil and agriculture, rendering more difiicnlt'South Vietnam's recovery from war, regardless of who is the "victor."" K George J{. Ilnrvey nnd Jay D. Mann. "Plcloram la Vii-tnum." .Si'lftiti.-'t ami Citiztn . (September, 10CS1. pp. 165-171. Tills article ivas subsequently an.ilyyod Ui tletnil !>y *'::£. • incmbi'in of Dow Chemical Coniiiany. producers of filcl-iram'. ThVy t-luir^iHl that the a u t h o r s hull been guilty of "inference, misquotation, uml m i s i n t t r p r e t a t i o n of ptibli.-h.tj scifniltlc dutii." For example, the article dcclnrvil that "A vbccp was killeil by a dive of tliirty-six milligrams of plcloram mixeo! with 2,-1-D.: However, the reference cited as a u t h o r i t y f'»r •this statement reported tlint 11 sheep h.-ul bec-a treated with Ji'j mllllirrnins of plclor.\m ' mixed w i t h l.'!-J milllKmins of 2,4-1). per kilogram of bo.ly weight, with 5 daily treatmeut.-i. The results of tills experiment were that of tbe 11 sheep so treated, all became sick and 4 died. Assuming t h n t tlie average bndy weight of a slieep n*as 2S kiloL-nims, t h i s would amount to a totnl ingestlon of 5,000 milligrams o£ plcloram and SH.iiiH) niniifrrams of 2,4-D «V('r n 5 day period. (Source of the tinnlvslH : J!. C. Byrd. Marguerlt.- I.euc, J. II. Davidxon, E. E. Kenaga and J. C. Hansen. "Critique of Ficloram in Vletuaru." {DowChemical Com pan v.) September, 10i!.<. p. 11-12. " A r t h u r W. Gal.ston. "Military Uses of Herbicides In Vietnam," Xcw Scientist (June IS, .10(58). pp. flRft-SS-J. • • "Arthur W. Galston. "Herbicides In Vietnam." The New Republic. (Nov. 20, 3907), p. 21. �' IV. BOLE OMHE AAAS IX ASSESSING WAR USE OF .' ; ^A HERBICIDES . • The AmericamKsociation for the Advancement of Science was organized in Philadelphia, Se.ptembei"20, 18-18, by a group consisting mainly of ideologists and natural scientists. Its objects were initially to promote scientific intercourse, stimulate and direct scientific research, and "procuro for tho labours of scientific men, increased facilities and a wider usefulness." In 1000, Science magazine became tho official publication of the association. As American science expanded, specialized societies proliferated in new fields of research, and many ' of these became affiliated with AAAS: indeed, most had been organized at annual meetings of the parent institution. By 19G9, the total membership of AAAS was put at 120,277 and the total membership of the affiliated societies and academies of science exceeded 7 million. In 1046, the association adopted a new (fifth) constitution that »edefined its objectives as: . * * * to further the work of scientists, to facilitate cooperation among; tliem, to improve the effectiveness of science in the promotion of human welfare, and to increase public understanding and appreciation of the importance and pciomise of the methods of science in human progress. Regional divisions of AAAS were established including one for the Pacific i-egion in 1915. It was at a meeting of the Council of the Pacific Division, June 15, 1966, that the issue of war use of. fcerbi-' cicles first entered the formal policy deliberations of the AAAS. AJ; ^ It proposedli resolution 'fwTcoiisiderauolTBy:"fnTcouncil} wKicli. read':' Whereas xinits of tho U.S. Department of Defense have used both chemical and Inolojricnl warfare agents (as defined by U.S. Department of the Army, TMS-216) In nj.--r;if.!ons against enemy forces in Vietnam; and Vi'terL-as, tba effect of these agents upon biological systems in warfare- 5s not AW.va to the scientific community; and ' • \\1iereas. the scientific community has a responsibility to be fully informed •at these asent-s arid their use in warfare because they are a result of senentilic' rest-arch: Therefore b e i t . . ' . . ' . - - 1. The Pacific division of the AAAS establish a committee of expert* in the field of biological and chemical warfare to study the u.se of CW HVU& BW agents In Vietnam with tho purjwse of determining what agents ha we bcn»n • used, the exti-nt of their use, and the effects on all biologic-ill systemts that might have been affected. 2. That the above committee make n public report of their findings Jit the next meeting of the Pacific division of the AAAS. ' The minutes of the meeting reveal that the Pfeiffer resolution Iliad a mixed reception, Eventually, the council decided to refer if—without recommendation—to the national office of AAAS. Even this decision . was controversial—being carried by a 9-to-5 vote with several abstentions. During debate on the resolution, members of the council <ques- ;• t.ioned the propriety of having the action taken at a regional meeting, viewed tho issue as more properly one for treatment by the National Academy of_Sciences, and rejected the proposition in the, resolution that the Pacific division had tho means to conduct field iuvestigaitions in Vietnam. . . • • Orrjaniaatitinal Structure of the AAAS ' ' The AAAS is a complex federation of scientists u! societies, designed primarily to facilitate the exchange information. It has six classes of members, general arid administrative officers, a council, 21 sections (organised by scientific discipline). 245 aflil iated scientific organizations, 4h associated academies of science, and nine committees. A difficulty in appraising the effect of an action "taken by theAAAS". is that there are many'levels at which views can !x>, expn;s~<;d, but no ready means to obtain ft consensus of the entire mernl>ership. The large membership of AAAS exists mainly to receive the organization's periodical, Science. Only "fellows," who constitute some 18 percent of the total membership', are eligible to become'officers. The council of tho AAAS, consisting of some 530 memtais, is not elected from tho AAAS membership at large. It includes officers of the AAAS (elected by the council);''officers of the sections; two representatives each, named from those affiliated societies with more than 100 members; one representative, from each affiliated academy of science; and a number of others. Although the members of the council may in general terms be regarded as spokesmen for the disciplines. or groups they represent, ihev are not literally "elected representa'.tives'.'of the AAAJrJ membership; . . The board of directors of AAAS, which is the "legal representative^ of the association, consists of the president-elect, the president, and the past president; eight other fellows; and (ex-oi'icio) the executive officerand tho trensmtr of AAAS. Tho px-ofllno of!ii--(>iM pre ii-inxiinted by -the board; the regular' members of the board-are elected by the council. •'_• Positions on issues can be taken by the board, the council, one-of the •nine committees, by requesting affiliated societies and academic to express their views, or conceivably by, referring an issue to a vote of the entire AAAS membership. The board meets four times a year, and can adopt actions at these meetings. The council meets annually (between Christmas and Xew .Year's), and takes up issues at these meetings. ' ' ' • The president of AAAS is chairman of the council. Quo of the nine committees deals with council affairs: its chairman is the presidentelect of AAAS, who serves in this capacity for a year before becoming president. Among the duties of this committee are to "rtveive or iniiiate, coordinate, and advise on reports of council committees, resolutions, or actions submitted for consideration by the council." AAAS Councils Action on Pfciffcr Resolution As president-elect of AAAS, Mr. Don 1C. Price, dean of tho Kennedy School of Government, Harvard University, wti.s chairman of tho connnittoo on council affairs in the fall of 10GC. In this capacity, he received Professor Pfein'or's resolution. During tho yearend meetings of AAAS, in Washington. D.C., the committee on council affairs held a public meeting, at "syhich PfeiiTer and others spoke on tho subject of tho proposed resolution. A f t e r this open session, the committee in an executive session decided to modify tho resolution before �IV. RCXT,E £E THE AAAS IX ASSESSING WAR USE OF ; ^A HERBICIDES The AmeriSKVssociation for the Advancement of Science wasorganized in Philadelphia, September 20, 18-18, by a group consisting mainly ofi.ceologists and natural scientists. Its objects were initially to promot't- scientific intercourse, stimulate and direct scientific research, and "procure for tho labours of scientific men, increased facilities and a wider usefulness." In 1000, Science magazine becurae the official publication of tho association. As American science expaiaded, specialized societies proliferated in new fields of research, and many ' of these became affiliated with AAAS: indeed, most had been organized at annual meetings of the parent institution. By 19G9, the total membership of AAAS was put at 120,277 and tho total membership of the affiliated societies and academies of science exceeded 7 million. In 1!HC, the association adopted a new (fifth) constitution that nedeiine-d its objectives as: * * * to further the work of scientists, to facilitate cooperation among tliein, to improve the effectiveness of science in the promotion of human welfare, and to increase public understanding: and appreciation of the importance and pwomise of the methods of science in human progress. Regional divisions of AAAS were established including orae for the Pacific region in 1915. It was at a meeting of the Council of the Pacific Division, June 15, 1900, that the issue of war use of laerbi-' cides first entered the formal policy deliberations'of the AAAS. AJ; ^ th5s_jn£^.jiig, the, secretary presented a communication froniELJJV. * proTessor orlsooloifvTfTlicrCniversity oOlontaiia. iFproposedTa resolutioiTfor coiisTcIe"rauoirf>yTIie couiicT17'\viricli read: i*"*"?"^' -——-••-p •--— "i" •• ••>'•**«..-..-*—^Wg—<»«-.•-.."—.-<-!•*•-»• • •i—i-^-.i.».....'.^^.»—~.y^...»i..».-.•<•»..—.. ^ , , Whereas units of the U.S. Department of Defense 'have used both chemical and Moiogical warfare agents (as defined hy U.S. Department of the Army, TM3-21G) i" operations against enemy forces in Vietnam; and "Whereas, the effect of these agents upon biological systems in warfare is not known to the scientific community; and • • . Whereas, the scientific community has a responsibility to 'be fully informed ft these agents and their use in warfare because they are a result of-scientific' restart-h: Therefore be it ' . Rcsolccd, That— ' . 1. The 1'acific division of the AAAS establish a committee of experts 5n the field of biological and chemical warfare to study the use of CW awd BYV a grunts in Vietnam with the purjxwe of determining what agents havw been used, the extent of their use, and the effects on all biological systems that might have been affected.' 2. That the above committee make a public report of their findings ;at the next meeting of the Pacific division of the AAAS. The minutes of the meeting reveal that the Pfeilter resolution liad a •mixed reception. Eventually, tho council decided to refer it—without recommendation—to the national office of AAAS. Even this derision was controversial—being carried by a 9-to-5 vote with several abstentions. During debate on the resolution, members of tho council: ques- Organizaticinal Structure of the AAAS The AAAS is a complex federation of scientists societies, designed primarily to facilitate the exchang _ information. It has six classes of member*, general and adinini.-frutive officers, a council, 21 sections {organised by scientific discipline). 24.". affiliated scientific organizations, 4S associated academies of science, and ' nine committees. A difficulty in appraising the. effect of an action "taken by tho AAAS". is that there are manylevels at which views can l>e expressed, but no ready means to obtain a consensus of the entire'membership. The large membership of AAAS exists mainly to receive the organization's periodical, Science. Only ''fellows," who constitute some 18 percent of the total membership', are eligible to become'officers. . Tho council of the AAAS. consisting of some 530 memlxjrs, is not elected from the AAAS meimVrshi'p at large. It includes officers of the . . AAAS (elected by the council); ofTicei-s of the sections; two rc-pre. seuttitives each, named from those affiliated societies with more than 100 members; one representative from each affiliated academy of science; and a number of others. Although the members of the council may in general terms be .regarded as spokesmen for the disciplines /vrtL or groups they represent, they are not literally "elected repre.-enta3^6 . . • tives" of the AAAirJ membership. The board of directors of AAAS, which is the "legal representative" of the association, consists of the president-elect, the president, and the past president; eight other fellows; and Cex-oHicio) the executive o.Ticer and the treasurer of A A A S . Thf px-nfllcin officers nre u-nrx>intt'd by '••the board; thfe regular members of the- board- nre elected by the eounril. •' ' Positions on 'issues can be taken by the board, the 'council, one. of the •nine committees, by requesting affiliated societies and academies to express their views, or conceivably by referring an is^ue to a vote of tho entire AAAS membership. The board meets four times a year, and can adopt actions at these meetings. The council meets annually (between Christmas and Xew '.Year's), and takes up issues at these meetings. ' ' • The. president of AAAS is chairman of the council. One of the nine committees deals with council affairs: its chairman is the presidentelect of AAAS, who serves in this capacity for a year before becoming president. Among the duties of this committee, are to "receive or initiate, coordinate, and advise on reports of council committees, resolutions, or actions submitted for consideration by the council." A A AS Council's Act fan on Pf differ Resolution As president-elect of AAAS. Mr. Don K. Price, dean of the Kenairman of ne dy School of Government, 1 larva rd University, was cha tho committee on council affairs in the fall of 10GO. In this capacity, ho received Professor Pfeill'or's resolution. During tho yearoml meetings of AAAS, in Washington, D.C.. Jtlu> committee, on council affairs held a public mooting, at which Pfeiil'or and others spoke on the subject of 'tho proposed resolution. After thi.s open sessi ' the committee in an executive session decidod to modify tho resolution before in Vietnam. •r. �introducing; i t a s new business before the council. 60 The resolution as redrafted' by^fc^committee had received PfeifTer's approval.151 Its text at that >ad as follows: Whereas mo<f?Hr"seier!ce and technology now give men unprecedented power to niter his environment and affect the ecological balance of this planet; smd Whereas the full impact of the uses of biological and chemical agents- te> modify the environment, whether for peaceful or military purposes, is not fully known; and Whotviis the major users of these agents on ft scale sufficiently large to modify the ecological balance are now the governments of this and other countries: Be it Rcxolrctl. That the American Association for the Advancement of Science— (1) Expresses its concern regarding the long-range consequences of the use of biological and chemical agents which modify the environment; and (2) Establishes a committee to study all aspects of such use, starting with the effects of chemical nnd biological warfare agents, and periodically to . report its findings through appropriate channels of tho association ; and (3) Volunteers its cooperation with public agencies nnd offices of ffovernn:ent for the task of ascertaining scientifically and objectively the full implications of major programs and activities which modify the environment and affect the ecological balance on a large scale.*J Tlie. resnon.-e of the council to the amended resolution was. later described by Mr. Price, as follows: ' • •' After I Introduced the resolution on behalf of the Committee on Council Affairs, and told of our discussions^vith you and your approval of the text which we had . ;> iopted. there followed a long nnd rather.vigorous debate. The key points an that •:'. -Sate were as follows : On motion of Bentley Glass two amendments were voted in the next to tlie last I'-irLigraph of the resolution: the first deleted the words "all aspects of" and the nd siiiintitutrd "including" fur "starting with." Oa the- former point IJentley that no committee could study all aspects of so tremendous a problem, n n d -$-* • particularly urged that such a committee not undertake to deal with the politi- -. '1 aspects of, for example,.biological and chemical warfare. Dr. Rapoport and I • •-!: .•irgu^l against this interpretation, holding that it should be possible to study '••••i'ifically the political aspects as well as—although perhaps not as objectively •.. •; rigorously as—any other. Thnt particular amendment I bc-lieve carried more ..:-.-;i- others thought that the whole field was an impossibly broad one rather .-:. br-cjiu>-(! anyone wl.shed to exclude any particular aspect of tho ppohlcrn. .- <-.t!:er revision (the substituting of "including") wds defended on tlie argu• • thar fhf commit tee's hands should not. be tied with respect to its owra judg- • .-. r.f priorities and that the council itself should not prejudge the f.^siie of .-;:ii-s. Both of these amendments were carried by a vote that was so over• !::ilng tli.'it no one demanded a specific count. i'•,'.•!>. a cotiiii-il member whose name I do not know, objected to the identifying ' "t!,f» crovernments of this nnd other countries" as tho principal offender*,, fin tho •-•MMt-nt that industrial corporations and, indeed, private citizens and private .."::-r.bi!(..i were responsibl" for much of the pollution of the environme-ait. He .•••—.I,to .strike out t!if> third "whereas." Ar:,l again this motion was carried by a very heavy majority. Thrt-o, Ted Byerly of the Department of Agriculture then moved to tuMc the :?:re resolution, denouncing it as watered down nnd weasel worded, but adding .f—-If I remember his language accurately—ho did riot like the original resolui f referring to your own) any better. The vote on this was close enough KO that • :-ouM not make a suf!i<-ir>ntly accurate count from the platform on a sKaow of :-•'•; but had to appoint toilers to walk down the aisles to be certain. But tho. • :!»jr '.it table lost and the amended resolution was then carried although by a • v tli.sr seemed to me re:: ",'i;U'ly close. l YiiiJf T fim sure you v.v.ubl him- preferred not to have these several amu'iid- ' i-cf* uiii'i;.t<-d, I am Inclim-,1 to think that—judging from the close vote- which «"rx-(f.T Inm rrire- In t'ti-llTrr. Jnn. S. 10(17. It in IVnri Price's rcoullcrtlon Mint he !;.<'i]sM-i| tli.- m i i t l f - r w l i l i I'r(>f''«snr I'Mffi-r nfti>r fhft opr-n hcarlnu nn<l li'forc ttw Com,;U.-P nii-i'tin^. nn.i dint PMffT l«-ft (own (»>fnrc tlic Council inPctlnff. " Ix'ttr-r fn.m I'fclffor. to I'rl'-<>. Di'C. 27, tOC.n. "iflniHrs <i£ the Mectlre of lhc AAAS Council, VTnshlngtoQ, D.C., Dec. 30, 11)00, (>p. 7-8. prevented the tabling of the amended resolution—the nmendimg^^-ere necessary to the passage of the final vote. I am sure that a number 0j^^Hl' !ik<; Hrtitley Glass would liave voted against the unarnendcd resolution,^^•Kreut many more against the resolution in your original form. There is sf^ffi a. question whether compromises are worth it in order to get something pas.st.'d, but I hope that you will feel that something useful may yet come out of this effort." In reply, Professor Pfoiffcr professed himself "pleased" with the final product." The closeness of the division on final adoption of the twice-amended resolution by the council is indicated by the vote: li"> to approve and 95 opposed. In its final form, as approved, the resolution . read: Whereas modern science and technology now give'inan unprecedented power to alter his environment and affect the ecological balance of this phuiot; and Whereas the full impact of the uses of biological and chemical agent-; t<i modify • th'e environment, whether for peaceful or military purposes, is not fully known: Be it ' Jffevolved, That the American Association for the-Advancement of Science—• •'..' • (1) Expresses its concern regarding the long-range consuluences of the ' u s e of biological and chemical' agwiw which modify the environment; and (2) Establishes a committee to study such use, including the effects o£ '' chemical and biological warfare airents, and periodically to report its findings through appropriate channels of th-- association ; and (3) Volunteers Its cooperation w i t h public agencies and offices of government for- the task of ascertaining wifntifieally and objectively the full implications of majon programs and activities which modify the environment and affect the ecologfcal balance on a large scale."1 Implementation of the 19GG AAAS Resolution on Ilerliciths In its final form, the resolution dealt primarily with the issue _of environmental impairment oa a prloV.al b;i:i::,;-.::;! only very icor/r.darily with military -use- of herbicides-. Also, while Pfcifi'er had ?ou<rhi'ajy .. actual scientific field investigation by qualified ecologies under AAAS sponsorship in Vietnam, the AAAS Council had lx?en content to_e.\pre.ss concern over the lon<r-riui[re consequeni.-es of the use of chemical and biological agents (whether public or private) that modify the environment, to establish a committee to study the jreneral question, .-and to volunteer AAAS's cooperation with the Federal Government to identify implications of major programs that "modify the environment and sv fleet'the ecological balance on a large scale." °'3 The council action on the amended PfeitVer resolution wa-? re|>orted tothe AAAS membership without any particular emphasis."7 The first -. implementing; action in response to the, resolut ion was the formation by ; the AAAS board of directors of an ad hoc committee on environmental :. alteration, during; its nuTtiag March. 11-1*2, 10t>7. The committee was M Letter from Price to Pfelffer, Jim. 3. liW. Op. clt. ' <« Letter from Pfclffor to Price, Jitn. i). ISMiT. "Minutes of the Mcotlng of the AAAS Council, Washington, D.C., Dec. 30, 1000, Op. clt. p. 1). . *> In comment on tlie foreeiilnc: ncctlon, hy letter of July 7, IfldO, to Mr. R. A. Carpenter. Dt'iin Price. KiiKgcHtH ttint the forek'olni; ncconnt of AAAS (lelilicrnfhiiis. wlillc "accurate «« f u r ns It KOCH," Is "mlsleadlni; In tliiit It tells the xtor.v only from the point <>f view of V l o t n n m nnd Dr. Pfelffer." Hn olmiTtvs tlint rniuiy nienitiers of the AAAS K>:iril hel<l the view Hint the Association for nevi;ral yenrs liinl lieeii concerned &* to tli» rel-iHon of deletion tn e n v i r o n m e n t a l |>rnt>IcniM unit K«W the I'fc'llTer resolution <u fnllini; Into tlilsi context. In retrospect, Peiiu Trice continues, •" * • I'crHiinitlly, I t h i n k It w.1.i i inl^tiiiir> to combine- the two lH«ue» (puiern! coitivrn for envli-oinneritnl iiolllitlon ninl 'th' *(."i'lal jiroblem of V i e t n a m ) . " Moreover, tin; new'swortliy nspect of the I n t t e r t<«ni» c.-iu-'e.l n d l d p r i i p o r t l o n n t e uiiioun.t of n t t e n t i o u to he R i v e n It. AH Denn Trice snyn: ••• • • The iicwnpiiper covernp- Iprnoreil (he Hear I n t e n t of tho Council am! portrayed the re«»Iiitli>n (is If It hud hoen nlmeil nt the V l e t n n m war." *> Duel.\Vollle ( A A A S executive olllcer). "AAAS Connc-lt Meeting, 10«0," Science. (Feb. 1007), |>l>. HRS-HflO. �chaired by Dr. Rene Pnbos, Rockefeller University. Its members included Pfjjjj^r and Mayer, who had been active in the herljicido issue. Whe^^Hid hoc committee reported, in Alay, it recommended e.scablishmc^^Hr a continuing AAAS "Commission on the Consequences of Environmental Alteration," and discussed three examples of. problems with which the commission should be concerned. These were chemical agents, chemical fertilizers, and waste recycling. The com-' mission should have as its objectives the. improved management of information and education on environmental factors, and the design of large-scale controls and emergency measures relative to major aspects of environmental impairment. . '. "With respect to "chemical agents" the Dubos committee identified four of importance: pesticides (to control hicppf.^ Imi-KJnM,^ /+« ~— _ ^^.i.nnnju u^vma {iv iacmuue Harvesting and to improve visibility). The committee recommended that studies of the use of these agents be made "in selected areas where massive programs ar« ia progress." In particular: "In Vietnam such agents are being introduced most intensive!v; therefore this is a region where the ecological eU'ectsniay be expected to be most marked." - ' . r >3 Tho recommended studies [said the report] would involve continuing review, collection, and analysis of information and reporting of findings of the ecofojdeal c<>!is=equfnces of such massive intervention (for example, effects on nutritioa and h'.-ukli, decree of aceutmilaticfn of the chemical agents in various links of the food chuia. shifts in distribution of animal and vegetable species, patterns of recovery 0. trees and other organisms). The short-term consequences should not be ne•-•; ••.!•.•<! ia uK-su studies, Lut sj»xi.-il attention should be given to lohjj-turm <ow~. :'.:,:l changes, for altogether too little attention has so far been given to thelojig-':., '.-•:• f-CV'cts of massive intervention in tho environment.- • ; ." ' - - " : ' •• -""• The committee offered a number of suggestions as to ways in which tae proposed Commission should conduct its affairs..In particular, it. • .-aid: ' -' '• • Oa occasion, it may be desirable for the Commission -to make arrangementsr.< have studies conducted by others. We recommend that the board of diwtorsf<>: AAAS] consider requesting the National Academy of Science to arrange acoririiiuin^ study and scientific record of the effects of chemical and biological warf:;rf n^'.;;its on soil, biota, and human health. . ' However, one member of the committee, E. W. Pfeiffer, took e.wep- '• I ~-'.i to tliis suggestion. In a separate, "minority" statement, he said he' ;: i not believe that the National Academy of Sciences was "a truly ^:.i!i-pi-iv!'.:nt organization of scientists" Iwcanso it liad been identified' . [ I.-i Si-it'.':ce. Jan. 13,11)071 as a "source of advice for the biological warf ifv tii'ort * * * and !iud also been involved in a postdoctoral research ••.•Hou-ship program sjKjnsoivd by Fort Detrick" ['!)iological warfare •• ^>arcli center], for which candidates were "screened by the. Academy''' . .:•.'[ "permitted to describe themselves as having received a, NAS-XJJC V'iowsljip." . , -•' . : • . '•' 'ir-pfemrntalion of Recommendations', of the AAAS Aff Hoc nuttr.c • • receipt of the ad hoc commiltoc's report, tho AAAS board! of •s at its meeting in June 1007- decided to divide tho general t into two parts; one was tho general question of tho cotisef qucnces of environmental alteration, and the other the specific question of the use of chemical and biological^warfare agents jjjjjjetnam. The Board, voted to ask the AAAS Committee on Science J^^HjPromotion of Human Welfare to "assume continuing responsibi^pRr tidvishig tho board concerning developments, actions, or proposals for action that appear likely to result in major alterations of the environment, and from time to time, as tho committee considers appropriate, to recommend-that the board appoint special commissions for the study of particular actions or proposals." The, board would then "appoint groups of persons especially qualified .in each such urea selected for • study and report."68 The board itself agreed to^accept responsibility for the next stage of action on the specific question ol military herbicide use in Vietnam. Implementation of Recommendation for Ecological Field Investigations With respect to "the more specific question of the use of chemical and biological warfare agents in Vietnam," the board recognized that "no effective study of the effects of such agents could be carried out in an active theater of war without military or other official per. mission and sponsorship." It therefore instructed the AAAS president (Don Price) and the executive officer (Dael Wolfle) to urge appropri. ate officers of the federal Government to arrange for a thorough study under official auspices. Accordingly— • • Conferences on this proposal were held' with Frederick Belts, who is Chairman of the Defense Science Board as well as President of the National Academy of Sciences; Donald Hornig', Director of the Office of. Science and Technology; and Donald MacArthur and Rodney W. Nichols of the staff of Robert S. ilcNamara, Secretary of Defense.-Following-these conferences, the AAAS pi'e*i-" dent wrote to Secretary McXamara, urging that a study by an independent sci.. eutific institution or committee of both the short- and, long-range effects of the military use of chemical agents, which modify the environment be authorized and undertaken.* The letter to Secretary McXamara recognized that "decisions regarding the use of [chemical agents which modify the environment] in various circumstances must'be made in-the light of tactical and strategic considerations: but. that nevertheless, tile "consequences of .their use may have such long-range social, economic, and political consequences,, both in Vietnam and on the world scene, that the problem warrants study under tho highest responsible political auspice?." The letter suggested that the National Academy of Sciences-National Research Council would be an appropriate institution for this purjxw; an independent commission responsible to the Secretary of Defense or to the President's Science Advisory Committee would be an acceptable alternative. Tho letter concluded by offering "any assistance it "could in such an undertaking, either bv sharing in its formal sponsorship, or '• by advising in the selection of tFiose who are to carry out the studv." ro . The AAAS letter of September 13, 10G7, was answered by Dr. John S. Foster, Jr., Director of Defense Research and Engineering, Se'p.'" Circular Ictfir from Dncl Wollle, executive officer, AAAS, to members of tlic AAAS Coiinr-ll, Xov. 1, 1VX17. •* Idem. *" Letter from I'rtco to Secretary McN'amurn, Sept. 13, 10C7. 32-405—00- �;j ember '20. First, he. dealt with the present state of knowledge convi'tTning tile Jj^fe^- or long-term ecological impacts" of the use of ?>J'ierbicidc5 oi^^^liant chemicals in Vietnam: Whether such impacts /Jrxisted, and ^Bmer they were detrimental or advantageous, he said, "j-vas not definitively known. Then he went on— ment of herbicides for military rise; and (c) a generally sound reputation for. technically reliable work in chemically on^j^kl research. According to the report, the contract ran from Augus^^HjDecember . 1,19G7.'1 ' ^^ Tho work statement for the MRI contract read as follows: Qualified scapntists, both inside and outside our Government, and in the governments of othnr nations, have judged that seriously adverse consequences will :»t oi-our. I'nless we li:ul confidence in those judgments, we would not continue' these materials. ' • The contractor .shall review available data nnd information cori'-eniing the ecological consequences of extensive and/or repeated me of lif.'i-bi<-id(.v. Primary attention will be Riven to ^,-l-di<-hloroj>!icrioxyafetif arid, 2,-!-.~>-trk-h!o:-ophenoxyacetir: iifid (including their various forms .such as tlic Jj'ityli-.stur.-)), cncodyllo acid, and Tordon (trade; niiinu of Dow Chemical Co.). TJ:tta to b<; v>.:'viewed includes published literuUi're, but other source* Mjr-h a.s Federal dcjiartnients and industries must be used to the fullest extent. - 'A In view of the uncertainties remaining, Dr. Foster said ho had iht>a two steps. One was to commission a ''leading nonprofit research '.>titufi> to thoroughly review and assess all current data in this old." The other was to request the National Academy of Sciences';\tional Research Council to assemble a group of professionally qual; :-.l experts to "review the results of the study and to make np:-.v|;r;.-:.v recommendations concerning it." Dr. Foster made clear •••••! :-e expected no definitive answers from these actions. Instead, .oy should be considered the first of a number of necessary steps. :.0 itudy he hud commissioned should provide— (1) A comprehensive compilation of available information; (2) An assessment of the current information gaps; (3) Inferences concerning any possible ecological impacts; and (4) A ba=is for planning. •'• .' • . Upon completion of this effort, Dr. Foster suggested, there should '. a consultation concerning its findings between the Department of •._-fr:;?e. and the AAAS leadership., in order to define next steps to - t-ikc-n. The report was scheduled to be completed by mid-Deeernber, .• t-.-iable i^.-i--examination-by the AAAS-Council and board-of di: rors in advance'of the association's annual meeting. - . Dean Price responded for the AAAS board, October 2fi. He expressed ."vificution that the contractor's report and the National Academy of.. •''•jioes review would both Ixi available before the AAAS Council '.- ting in New York City, "between Christmas and New Year's." -• also asked Dr. Foster to elaborate on the"sources of informed •inion that hud led to the conclusion by the, Government "that :-in;i~Iy adverse consequences would not occur from the current use ' herbiHde.s and defoliants." In reply, November 10, Dr. Foster said e conclusion derived from a "consensus of informed opinion" of rue 50-70 individuals, in the absence of "hard data." Nevertheless, ; .-aid, "we remain convinced that our judgments were, and arc. reanable and take account of all significant data." ' •-* Midwext liezeMf'-.h Institute Ktudy of Ecological Effects of Ile.rlricidcs Tlie selection of u contractor to perform (he function envisioned • Dr. "Foster in his letter of September 20 had already been eoincfod at that time. The contractor was tho Midwest Research Insti.te, located in Kansas City, Mo. The qualifications of the. con tract or *:.i-luded: (a) general familiarity of its personnel with tho chemistry •f>f herbicides, as u result of earlier work for the Food and Drug Ad|!iinistration on tho establishment of standards for pesticide residues 7m foodstuffs; (b) absence of any past participation in tho develop- Simultaneously with the research project underway at Midwest I!e• search Institute, the staff of the AAAS were undertaking a bibliographic research program of their own, in response to instructions from the board of directors at the fall meeting. Letters were sent to about 100 organizations and individuals requesting bibliographic lists on the subjects of herbicides and defoliants. This action was in connection with the 19GG council resolution "that the association undertake a study of the long-range consequences of the use of biological and chemical agents which modify the environment, [.and that if.] report periodically its findings, and volunteer its cooperation with public ' agencies and ofiices of government for the task of ascertaining scientif• ically and objectively the full implications of major programs and activities which modify the environment and afi'ect the ecological balance on'a large scale."" Although the A A A S oflire in Y\*a.-iiiugTon, D.C., accumulated considerable bibliographic information in response to this request,'no further action was taken with specific reference to '; these 'data;.' One of the respondents.-in fact, observed that "Your re•'.quest for information simply duplicates the eil'orts of the Midwest • -Research Institute." ™ . Cross-Pressures Within AAAS, Decembci^-Janunry. 19G7-GS . The MRI report had not been available to the board by the time the AAAS convened in New York City for its annual meeting. At the AAAS Boa'rd meeting, Docembor 29, it became known that the committee on science in the promotion of human welfare, under the chairmanship of Dr. Margaret Mead, had concluded that it had more than enough work already before it, and that the importance of the environ• mental issues identified by tho Dubos committee warranted the establishment by AAAS of a now permanent committee. Accordingly, the board at this same meeting decided to establish a new permanent committee. on environmental alteration "and proceeded on the spot to name ii few members (sonic at least of whom were in the room.") 74 The now work on tli" roiiuostcil ns^ " Kxtniet from HAniplc Irttcr, nmoni? ft roup sfnf out NOV. 7. l!>ft(, rfpro<1uci>il In Mr>mo> r n n i l u m to A A A S Jtiinnl of Director*, I> . 21, 11)07. by WilHnm T. Knbixeh. " "-'•' p. ;t. : from rrlcc to Cnrpenter, July 7, 1009. Op. clt �committee, was instructed to "cany on a continuing evaluation of the iinplicatj-on^^echnolo^ical intrusion oh environmental processes and their inten^^Bp with human population ; and, in view of the previously exi*HM& concern of council regarding the use of chemical and blologicaOigents in Vietnam and elsewhere, to request the com-' mitteo committee Barry Commoner of "Washington University, and Dr. Athelstan F. Spilhaus, president of the Franklin Institute, initially named as members, with others to be appointed later. The board action \yas reported : to the council a day or two later. Since the MRI report had been delayed, the council and the board of directors would be unable to participate in a review of it at the time of their convention in New York, at the end of 19G7. It was apparently, understood that tho two issues, which the board had sought to separate, could be brought together onco more within the purvue of the new Committee on Environmental Alteration, if the committee desired this; however, the committee had the option of dealing only with broader and le?s controversial issues of environmental degradation.7? Apparently there was a good deal of pressure on the new committee not only to'deal with Vietnamese herbicide usage, but to make it priority business. Before the MKI report was made available to AAAS, the new committee ran into a snag. Several week's-after its formation, the chairman, Dr. Goddard, resigned, as did Dr. Spilhaus. As reported in Science: • . _ . ' . . Both cited extensive professional commitments as' the reason for their resig-' nation,--though Goddard, in a--telephone-interview with Science, added, • "no fwmT was my appointment announced tiian I started getting pressures from all directions. The emotional overtones were terrific."" . ' ;• ' , Criticism was aldo expressed over the selection of members of tho . committee." ' ' - ' . . • • ' Dr. Goddard sent his letter of resignation, as chairman and rnemJx>r of the Committee on Environmental Alteration, to President Price' of_AAAS, January 24, IOCS. The letter illustrates'the need for firm, objective leadership in the face of the cross-currents, pressures, and c-L'kulties confronting a science-oriented committee handed a heated ~ T!io precise rolo eipectod of Urn new committee wltli respect to the Vlctnnmcsc -•;*•. nr. i ."a t<* whf.-thf-r or not It wn* a part of the broader onvironnient.il Issue, Is a "mutter " :i; ^--.-; : '.';it!'>ri." In coinment on this s i t u a t i o n , D:ifl Woltlo h;iH oxpl.'tlnod that j* t tlte ..--.i-.-r:!/-,-. K)i",8, niWtlnff, the Board oC the A A A S "certainly intended ti> combine th<* lirrhl•:•• I.-.-.-.- nml the more Ee.'iornl nmttvra u n d e r tho sumo committee." lie adds : "TScis do-!-. p. wns, I t h i n k , a ivronj; one. It d e p n r t e i l f r n m the earlier decision of t h e It.i.ird to ' .i-m Sf[>;irate, ft po.-dllon to wMi:h the U<\'ird returned at ittf March IOCS mp^Un^." l l f . a l < - t r r r to .Mr. R. A. Caroenter, Science Policy Kcserch Division, LecUHUive Iti-'fcrcnce iw, J i i l v jo. irn;;>.) D. S.. Gei-enhftg. "D'.foll.-itton : A A A S Study Delayed by Rcalgniitions from ComiriUtee." , (Vol. jr.O, L'.'i Feb. liHiS), p. S57. ' "Thus, Cfcarl'- <;. Wilt/or, Colorado State TTnlverslty, cornplnlued t h u t "It Rooms that T n , Jr.fil.'idii.-iis were cho.--i-n p r l i n r i r i l v on the han[n of tlu-lr active political Involveira.i'nt In ere A A S riff-sirs." lie K»;;i:'-sted t h a t "tlie fact t h a t an i n d i v i d u a l la concerned about t» civen In no way ' i i u i l l M i M him to n.ake j u i l t r m e n t K on that problem." He uls<> rxproiwii the i,<* "''.hit the jjowi* s t r n c i u r u in the A A A S will take a second look at this rornmiUcti ftml .ii:r«: t h a t »t least one i n d i v i d u a l w!:o \n competent In the scientific nspects of ciM'inleftl .irf.in; -will he lnrMiided us a votinj; uioinbcr * * *." (Letter to tho editor. Scientific He!xrch (Mar. IS, l O O S J . p . B.) political issue. Because of the bearing of the letter oni tL^vliola probtern of technological assessment in a political envirom ^Hbc bour of ie b the letter is reproduced in its entirety, as follows: DKAB Dox: This is to inform you that I am resigning as a m^iahfr'and chair• man of tho AAAS Committee on the Alteration of the Knvironruwjc. It i.s with great rehietanco that I hiive cwue to this conclu.sion. TJie decision was not an easy one to make and was based on two factors. Out- i.s that of severely limited tijae: 1 .should iiavo realisii'd earlier that the enormous dwuanils rcijuin.-il of tin; chairman of the committee would conflict witli my heavy m-iuZeniii; jidmijji.'-tra. tive duties at the university. The other i.s t h a t o f - t h e VSetnain issuer already this issue is creating treinendous pres.surt'.s f»r tlie committee, not only more time consuming and diflieult but wiiieh will also endanger U.s v»-ry purj'o.-e. ' iWhen we set up the committee we were concerned with intellfC'tual and practical problems of environmental alteration, whether they resulted from the i»>i>ulation explosion, from modern industry, from automobiles, from thy overuse of jtpsticldes and herbicides, or from the excessive use of agricultural fertilizers. The AAAS was concerned that it should not become directly involve*! in itoUtir-s arid that it had a role to play in pointing 1 out to the public and the Government ' ways in which scientific .knowledge should be the liii.si»- for governmental action. It also recognized that we were going to have to deal with tin; i»rohl"in which has arisen in Vietnam due to the use of chemical agents, particularly lierbict(I"<, by the Department of Defense. However, we did not wane the basic life of the ' committee to be OTerwhelmed by this particular problem. • '• It appears that I was naive concerning the political pre-s^nrf* In relation, to the Vietnam problem. Someone, probably someone connected with rh« Depart" inent of Defense, leaked the report of the JJid'.vest Rr-'-'enreli I n - i t i t u t i - to fin 1 New York Times evtn though the report has been denied to the AAAS until the National Academy of Sciences evaluates it. It is clear tli.it it is going to be extremely difficult to obtain an impartial view of the report. One might think chat professional scientists would not expect the ci-mmtrtee to reach conclusions before it has received scientific evidence, but this i« clearly not the case. The correspondence reaching my desk, and t.lie telephone'Crti!-• — • niany of them from very "distinguished .scientists—iiidie.T'e"'that "many poodle nave prejudged the issue before-any commiitfe can be formed. Ouj<: t !vr.-? are . trying to determine the composition of the committee arid the concliwir>n< tiian it will reach. If this seems exaggerated, I would refer one to Luther Carter's • article in Science, January 12, IMS. Anyone who knows me knows that I would be unwilling to chair a committee that would either whitewash tiie Department of Defense or would reach conclusions before scientific evidence was presented to i t ; I would also be unwillins to servo on a committee that j 'was organized in advance to condemn the De-' partment of Defense without adequate data. Though I have serious doubts of the military necessity, or the morality of the American participation in Vietnam. if I am to serve on a AAAS committee I must do so as a five agent. The r«>!itical climate within the membership of the AAAS is such that I do nut believe that nn Impartial study can be made. I am al<o afraid t h a t tin; Vietnam war and the emotions that it creates makes dilHenlt any attempt to really evaluate tho other important problems of tho alteration of the environment. I reali/.e that my delay In reaching these conclusions has caused difficulties for the AAAS. I can only wish it every success and IIOJH' thut a committee can •be set up that can be of value not only to the AAAS but to American society. With my best wishes to the officers and directors of the association, Sincerely yours, .'• ' .. . DAVID R. GoDb.uio. Tho article by Luther «T. Carter to which Dr. Gmldard referred in his letter was an attempt to specify tho task of the n.o\v Committee, on Environmental Alteration, and to indicate tho nature of the challenges that faced it. It opened by stating that the- first order of business of tho committee would bo "the ecological impact of chemical �agents U'-ecl^BK"ietnam and elsewhere.'* Factors in this consideration would be t^^Bl! study and the NAS-NRC review of it. The_j>ositions of th^Ppartment of Defense and leading critics of herbicides in war were identified. One item of criticism of the cpmmittee «cited by the article was tlvat of Dr. Pfeiffer. According to Carter: . Pfoiffor fi-cls that, \\-hilo the new committee is chaired by David R. Gtoddard mvost of tlio University of Pennsylvania) rather than by Dubos, it is essentially fc;:tUu!ation of the iul hoc comiuittoo under a new name. His confidem:« in it l'.'i be greater, he said, if among (lie members to bo added are people wach as. i'^on ;it>it two Harvard contributors to Scientist and Citizen's issue on ctuemicnl ril warfare—John T. Kdsall, a biological chemist, aud Jean Maj'er, a and specialist on the history of public health. . ' '• in his article, observed that among the members of the 'wore Barry Commoner, who had been a leader in the information movement, in which Pfeifl'er also had been Two other members—Dubos and Athelstan Spillmis—were of the science advisory board of Scientist and Citizen, official public-lit ion of the Scientists' institute for Public Information- Also in the article. Carter had volunteered the editorial comment that not confine Tthemselves to recommending further studies or action by others." « Xational Academy of Sciences Review of .MRI Report The haste with which the MRT report was pressed to completion' is .-Mrgested by the method of its delivery. On November 7,1967, the jSTAS . P.sriel met. with personnel from MRI and the Oflice of the Dissector f'! De-fense Research and Engineering, at which time copie's of chapters 1. 2. ?,. and 5 were turned over for analysis by the Panel. Then, on D*'''V!i:ber 1. MRI mailed directly to the NAS Panel members complete '••i-.Mu-s of the report. However, according to the later recollection of V-'iliiam B. House, director of the Biological -Sciences Division, Mid•\.--~i Research Institute, the institute was dissatisfied with the appear;•>.::•>•• of the document, which had been typed on one side of the- page only, making it voluminous in size. Copies of the revised report were r.'i-cived by O.D.D.R. & K. on December 20. These were sent, to the'.NAS J Panel to replace the earlier copies. On January 31, IOCS, the NAS Panel ; Import was rer-eived by O.D.D.R. & E., and on February 15, th? MRI | report was made available for distribution by the Defense Docunawnta: :| t;on Centora.s a method of public release. | The review of the MRI report by the National Academy of Sciences j (NAS) apparently beer*in Novemlmr 7 and was completed by Jatuwary -i : '|, lOHS. In the mi-untune, however, as Dr. Goddiml had indicated in | his letter of resignation, <i discussion of the MRI report's findings had : uppenred in the New York Times :' weeks earlier, and had apparently | ;.f stimulated further excitement over the issue.'Treatment of the report port -,'oy the NAS was some what noncommittal. I TGI*" I'D ''jr S\n~'nri*r' r>Vw A A A S "Commlttco to Study Cliemicul Dcfiillnntfi.- The report itself was a substantial volume, 3C9 referencing 147 persons as_ information sources, — : 1,500 items of bibliographical references. The re ing findings: 79 aultilithed, iges listing the follow- (1) Direct ecological conscrjuence of herbicide use in Vietnam wns tb£ destruction oC vefe'etation, setting a region back to an earlier stage 'of development, from which the process of restoration would then occur. . (2) Food chains of fauna mid heterotrophic; plants would be altered. 1 (3) I'hytotoxicity of herbicides in the soil wa:s not a con.-udrration. nor were letluil toxicity to humans or wildlife, or concentration of deleterious chemical* in food chains. (4) Data on chronic toxicity were incomplete. (5) Data on aquatic environmental effects of herbicides were inconclusive :and niixed — some favorable and some unfavorable. The report then identified four important areas of uncertainty that . remained: (1) The effect of . 2,4-1) and 2,4,.>-T on water quality. '(2) The possible threat to mammals and birds already approaching extinction. (3) Micrometeorological effects of forest denudation. ! (4) Possibility <jf exposing lateritic soils, such as to result in tlif-ir hard>nins -•and infertility. . • Reoicw of MRI Report by National Academy of Sciences In accordance >vith the understanding between the O.D.D.Tv. & E. staff and the board of directors of AA'AS, the NAS Review Panel was to comment, on "the thoroughness ;i:.d accuracy with which the scientific literature relating to herbicides and their ecological e:" . had been examined and evaluated.'' • •;.-' The NA.S assessment (presumably drafted by .the Gluiirinau o!: the Review Panel)'1" noted that the Panel had not functioned as a committee "in the usual sense'' because they "did not have an opportunity to meet as a group after the final report was made available." They had, however, provided specific comments and advice on early drafis of •chapters in the report and, after completion of the first full dhift, .submitted corrections, suggestions for deletions and additions, laud general comments." The consensus of the Panel was as follows: (1) Midwest Hosearch Institute Iws done a creditable job of culUrtin^ corrt>t-tly abstracting, and citing much of the relevant published InfiTiiintitin, although, under the cifi-unistiuuvs, tin- report could not In- expected to covi-r in u truly <-ompreluM>sive way so vast a literature. ' (2) Of necessity, the preponderance of the matt-rial deals with herbicides as tUi>y are used in vegetation matia^i'iuent in a diversity of situations and environments. On this general topic, abundant data are available. However, the M.-U-Utitic literature provides markedly less factual information on the ecological cmisenuciuvs of. herbicide use and particularly of repeated or heavy herbicide applications. The Midwest Kesrurch Institute report correctly iviUrts this disparity. In transmitting the. report to Dr. Foster, January 31, IOCS, the Pivflident of the National Academy of Sciences, Frederick Seitz, ' TnrnphrftMi'd from MRI report, Op c l t . , pp. 2nO-2!>2. "Tin- iviuiol WIIH Hinlri'd hy l>r. A. S. Crjirtu, ViilvrTstty of Cullfornln at tinvli. Mem1v>r« wrc : Or. K c l t l i C, HiirroiH. illrcctur. I'lunt Science Ilowiirrh rind IVvi-lupmcDt, I)<iw CliiTiilrul C<». : l>r, lUfiiiint Kfliri'iiH, ili-tuirtiiK'ni »C *ite«tiatny nn,\ pliint irftu'tlfs. « l n l v . of M l n i i . : l > r . W l l l l u i n S. lti<iuiliiKlii)ir. i l i ' i m r t i H i - i i t of tx'tany, Unlv. of Mii.-!i. ; Dr. W l l l l n m K. Kurtlfk, {tcpiirtinnat of farm rni|'«, ()n-i;»n Htuti- i'nlv. ; nnj Dr. Wiirr.in C. Sluiw, crop roxi'iircll illvlnton, A c r l c u l t i i r n l IteMcnrcli Scri-liv. U.S. IVpt. of Agrlcu'tute. Th«.M!<I ri-port w«n Hiihmtttitl to the 1'rcnlUctX ot.tlie N'.VS. Jun. 29, IOCS. �expressed the view that "it is clear that the compilation of this report is onl -'ep in investigating furl her fc3ie ecological effects of ^^^ herbicides. Some research in this area is now under but WiK more 'needs to be clone." Dr. S«*itz indicated that "the . Academy will be glad to participate in any useful way in the planning and promotion of such research." Attached to the Panel report were 16 excerpted comments by mem| bers, not individually identified, that the chairman judged tp be "informative and illuminating." These are briefly summarised as, • follows: • • • . , . - , A good job, particularly considering the short time in which they had to- . conduct the- study and prepare the manuscript. There is a need for short-form [ecological] studies [including determination of residues in fish]. • . . * * * A substantial report in the restricted time available * * *. However, the re]x>rt cannot be considered a complete compilation of the available scientific literature on herbicides or the ecological consequences of herbicide tisasc . Unfortunately in ecological evaluations quantitative conclusions must in c:fi-t instances ?:ve way to qualitative judgments Erased on past experience. 'Questioned the "areas of uncertainty" cited by tlie MUI report.) .'T'ifferencc'in biomass betwen Vietnam and temperate regions exaggerated.) "; l:e entire section evaluating the major ecological 'Questions and making a j, :,'ment on each one is sound in all respects. It is conservative, yet not ex^ x-'ively so. * *.* The problem of soil laterixation [rsiay not be real]. I am very favorably impressed by this entire section of evaluation. * * * Reasonably accurate and fairly comprehensive Teview of the literature. (Ho-wovor, noted that there was a dearth of literature directly pertinent to- th? title of the MIU report.) Kcological consequences of herbicide use, which is the main theme for the nianu<=cript, suffers most from the inadequacy of the Jtuforiuation available to- , . actually present an assessment. . „ .. -•• . . ' : " . * * -* A more adequate job could have'been done in reviewing current researchuii'lr-r way to strengthen infonnation on ecological nspt'-cts eff herbicide use. I (Tlie report did not consider a wide array of ;';:'->j-?efs !by the Department of ' I ---. -,-r;-:ulturi! bearing directly on the relationship oH ii'-rlijcMcs to the environment.) _ '* '- ' *" An enormous number of hours researching the literature, and developing' . | ; -.i.k^round understanding of tlie field of herbicides. * * * Put together as a . j r- :•. :li entirely of knowledge gained -through literature review without a working-. I J-.-i'.-kground in the field involved. (Frequent oversitaplsffications but.reasonably. I thorough and authentic.) ' -^ (Evaluation by XAS is based on currently used fceirlncides.) 'I (Ic.suflkient knowledge available about movement antS persistence of picloram S : M S'.-ils and water.) . '.";•. ii {Concern for lateralization is exaggerated;'soils aze not laid bare.by her* H-iddes.) . ' - ' • ••• - rf the MRI Report ' ' \ . ;\'. . \ Ta the professional press, the if RI report had a>. smixed reception. Dr.. 11'red IT. T.-;cliirley, an authority on herbicides with the U.S. Depart- . 'if! -\';i of Agriculture (Assistant Chief, Crops Protection Branch, Agri.if::.]rund Kc.-'oarch Service, USDA), called it a we33-done literature re- ' fvlew but "disappointing localise its direct applicability to Vietnam .|i.-i so tenuous."S1 Ecologjst JFnuik E. Egler, who Iiad pioneered in the .}u-e of herbicides in Connecticut, comp In ined of the study'that "NcitJier • . •the published literature, nor the scientific knowledge allow us to make, ~-y,\ afif^-ssment of long-term ecological effects of extensive or repeated i:..-« of herbicides."" Howard T. Odum, of the University of North j— . '"litvlewH," Kcotogy (Vol. ^f•, No. 6), p. 1212. ' . .- ' Carolina,83 observed that "Data on Vietnam ecosystems are not in this volume." Science News titled a description of th^H^I study "The Nondefinitivelleport." 8l ^^H ' deception by the general press was also diffusecl^BFinconclusJve. ' i -i r J.I.- -.,...,...* 4-1.,,f *!-.„, Vietnam." 0 " INCWSWCCK wits jnun; »A^U^.II>. jji^u. ,. t ^.. v..^ ......^..v.v-voluminous report in hand, neither the. Pentagon nor the AAAS is • likely to be satisfied entirely." in fact, the article continued, "Thy real evaluation—in the field—must await a quieter and safer time for scientists in Vietnam." 80 Thomas O'Toole, in the Washington Post, had his story headlined "Defoliation Threatening Viet Wildlife." 87 William Hhies r story in 'the Washington Evening Star, was headlined "Defoliation Study a'Bit Hazy—Vietnam effects unclear."ss A succession of headlines- in the Xew York Times illustrates the equivocal effecti of the ^Mill study. _ Thus, on January*^T./\a preliminaryY*4. -» i i »j. 1 . 1 t. , „ .i',.,,-.^,/] ,.-^_. 1 T ii,, .,/] J»T ? ew Victim or me n ar, xuaiuiue/ -; It is possible that much of the news comment about j:he report was j prepared on the basis of a short summary of its contents prepared by 'Dr. llaywai'd of the oflice of the Director of Defense Ittseuivh and , jEnghveerhur find released' arpun'd"February .1', ls">GS. The full 'Mill • I report and'jt.he accompanying XA-S analysis were hot releaied' until 'February la. - • " : . ' In the .opinion, of Dr. House, "* * * The, press, at least to my knowledge, [were] addressing themselves to a release before the report itself was available. Although it mentions in the release that it was a 3t59•'.pago "state-of-the-knowledge.'! survey, 1 feel that some of the comments conun'g from the press might, have been slanted in a diu'erent way if they-;had been reporting directly from the report itself. The report carried a considerable amount of factual data and our pliilos. ophy in approaching this problem could not be adequately expressed in a 41/j-pago summary." 03 . By the latter part of February'IOCS, there was a good deal of confusion as to the status of the "technological assessment'' that the AAAS had undertaken in response to Dr. Pfeiil'er's communication, Thisstato "Idcm. « vol. n:i. 24 TVb. inn<». p. iss. » (Kch. 2.'(, 1110S), p. 70. . » (Fob. so, i n n < 5 , |>. no. « h-'ch, 11, inns), p. A-l. . * (Jan. SI, 11)08), p. A-7. » (Jim. 7. 10OS), p. 3. *> (I'Vb. 1.1, lunsi, p. 4. •1 (Fi'h, IS. I'.H'.Sl. II. 5. « (Vc-ti, an, uxts>. p. o. *» Jitter to Mr. Cnriicntcr, op. clt. �. ,v •| •jf .'4 .f $ 4 .'-' $ •'3 :Jj formexl to inviSJ^Po us<\s of cli'omlcal and biological agents. I'feiffer haw offered' to servo and is now planning to bring pressure on the association, to spoEwor an extensive symposium on the subject. The Scientists' Institute for Public Inferjjujtian in Xcu' York will be eulistod by I'fciiTer, nltlioug'i another group—Thysiciiitis for Six-ial Hfsjvnisiliility—has already offered to help. This group tos had' exivrieuro of firsthand Held research in Viotnam, having visited hospitals there. If the AAAS won't, sensor the symposium, said I'feifl'er, another organMationlike the International Red Cross or the World Health Organization will be-' approached. ''The symiwiinm would hopefully stimulate people to go iflito the'' fit?Id and get data on the effects of herbicides. This should include Vietnam in1 areas which are not continually under fire," Pfeiffer said." I Thus, by the. first, half of 1968, the problems of conducting a teehno$ logical assessment by a large association of scientists had been identi3 fled as complex and formidable. 3 There, was the importance attached by many leaders of the scientific | community to the preservation, of the canons of scientific objectivity, .5 which meant avoiding resolution by scientists of technical issues into•I which a considerable element of political controversy had entered. : | There was the problem of screening out of the controversy the bias 4|of those who were opposed to all forms of participation by the United' t|8tates in the Vietnamese conflict, and who rejected out of hand the•"^defoliation program as merely one- more Manifestation of a program Jfto which they objected on broader, political'grounds. :•* There was the tendency of some scientists to recrard the orgainiza: '•-i' • .. . 1 . . - 1_ . • IT-.. f : 1 • •> . . /. -r^ » ^ . . '; a conspiracy to defend and justify programs simply on grounds' •r>; ;hort-tenn military expedience. .:^ There was the fundamental difficulty that the sciences "contributing: Jo- -ecology u'cre insufficiently developed to permjt definitive findings |i- to the long-range impact of herbicides even. in the United States Js-.-here they had beeji used for more than two'Vlecades; so that an "|i -:>--?ment of repeated and possibly heavier application of herbicide in an altogether different ecology, under the hazardous coiidi•\i\--:\< of a diffused guerrilla warfare, posed insuperable problems of •J/^nitive assessment. I An assessment of the use of herbicides in Vietnam required (ft) •"'Vrvincial resources to mount an expedition, (I) military support for ,,|' t f » gain entry to the combat area and receive protec protection wliilo ' j r n ' j f - t n g its onsite examination, and (f>) stafling by recognised '-'-iontists unconnected with any aspect of the defoliation program to -tablish objectivity and maintain credibility. It. had l)ecome apparent |i:rit tho-MRI report was only the first step toward such an assessJi''nt. Wljilti it had eliminated- a number of questions it 'had raised •'|r underlined others. Hut there ii[)peared to be a growing consensus. " ' . further investigation w a s needwl. .- J " SclenUDc Research (Feb. 19, 1008), p. 12. ,.J _l^n r r — ^^^^ There have been outright attempts to kill the project couiplete^^^ v,-<-nt on]. Are American scientists capable of making an inderxmdent study or not? So far the situation has been up in the air. You cannot get the AAAS board of dire-ctors to commit themselves to'such a study, am] I don't think the average AAAS member knows that the study was ever being considered. . He regarded the use of defoliant chemicals in Vietnam as a "burning ' issue" and said: "I hope the new committee can send a. group to Vietnam, and that it will include people who are concerned with this . issue."K • , ' • -. Dean Price saw the role o£ AAAS somewhat differently: ' . Our role is far from finished [he said]. This i» a slow process. My own opinion is that we had the choice between the kind of operation that would call for n. large staff and large sums of money to do firsthand field research. The AAAS has never done this. We operate by committees and review field work done by others. To do Held work In the combat zone is even more difficult. We could have mounted a protest movement which would have achieved little and which would have been opposed violently by the overwhelming majority of our member*. The other way was to get the best scientific study done, and then have a committee of hard scientific competence to review it1* When tho MRI report, and the accompanying assessment by XAS, reached the oflices^f AAAS, early in February, the association was unable to take any immediate action because there was no continuing group in session. However, in March, the board of directors met and voted to accept directly the responsibility to review the Mill • report. Arrangements were made to have copies of both th« report and the NAS assessment, provided'to all members; in addition, the' AAAS staff, was asked to send copies to a number of consultants to secure their comments and advice.97 • The precises function of the AAAS in relation to the MM report is not clear. From the point of view of most board members, the- important question was^the broad, long-range condition of tlu> human environment. The military use of herbicides in Vietnam was decidedly secondary. Tho latter issue was also so inflammatory that any AAAS committee asked to study both the general environmental condition .and the specific issue of Vietnamese herbi.cide usage, would be under great pressure topical primarily with the- secondary issue. Experience' had shown tho diflieulty of organizing u committee willing to accept both.issues. ' Onco tho Mill report had been received, the board decided- to accept direc.t responsibility itself for the assessment of the report and of the Vietnamese herbicide issue. It was not accidental that a number of board memlxjrs were qualified as biologists or ecologists, specifically ""'Chemical War: a hot potato for AAAS," Scientific Research (Jan. 22, lOOS), p. H. . •i Theno wore Bent t«» members of the DiiUos Committee, ami of tho Committee on Science " Idem. In tin- I'romutliin of Human W e l f a r e ; they iiNo WITH Kent to nine presumed authorities in tho Ili'M. of whom only three rrttirttnl tliclr comments before the June nwtiui; of (be Board, Ho.wever, at the .Tune/ meotliiR the Hoard received the benefits of extciuU-il com. Ou;niH from llnrnlit Coolldno, executive director of tin- 1'acillc Science Hoard, whu had hrcn In Vietnam a few motitlm earlier, and hud met with Vk'tnamcHe HClcntletM IntcrcstvU In tin; ecological cffcctH of the m l l i t i i r y Mac of hfrblcltlcH. �( f u - v . Giiiiiiionc'r, Huagland, Steinbach, and T h i m a n n ; the biologic soien.v.-; h^e always been strongly represented in AAAS membership and Kv^flwp, although nol necessarily the particular sulxfeciplines (tropid^^Blogy, plant metabolism, weed chemistry, an<I control proeesse^Wc.) most precisely germane to the MRI report and the related Vietnamese issue. On the other hand, the board members ' reasoned that the board itself could not escape ultimate responsibility for any.report generated by the committee of the AAAS, because the public, release of any such report would require board review and approval in any case. Moreover, the issue was regnrdetl ..as less technical than of a'general scientific-political-organizational nature. ' The issue was what AAAS should do about the MRI report, rather than the scientific task of designing a field study of the consequences of the use. of herbicides in Vietnam. Finally, the board could, If necessary, obtain the advice of a technical. committee or of individual consultants, in handling the matter. Distribution, of the MRI report, as described above, would facilitate this. • Assessment of MR f Report by AAAS Board of Directors In mid-July IOCS, the Board of Directors of the AAAS issued its own policy statement on the use of herbicides in war. The statement took the form of a review of the MRI report, together with'tlse XAS commentary on it. The board almost unanimously issued a basic statement, accompanied by three supplementary-statements by "some members of the board of directors," and a separate dissenf by a single board member who preferred an entirely different analytical approach. In the basic statement, the board expressed t-h'e conviction that "many questions concerning the long-range, ecological influences'/of y " chemical herbicides remain unanswered.;" One of these was the extent : of long-term deleterious-effects of the forest defoliation in Vietnam.''- : ' They also questioned the use of arsenicals on crops and the "ultimate route taken by arsenical compounds in plants, soil, aiWl animaJs.w Accordingly, (hey did not '"'share the confidence expresses! by the TVj-wutment of Defense * * * that seriously adverse consequences win not occur as a result of the use of herbicidal chemicals in Vietnam, insofar as arsenical compounds are concerned.'' They also took account of the "serious concern expressed by scientists in Vietnam 'over long-term environmental consequences of the military use of herbicides." Be- ' cause of the uncertainties in available, evidence of these consequences, said the board, "such charges cannot now be answered unequivocally." Accordingly, the board recommended— \ That a field study he undertaken under tho auspices nnd direction of the T'nited Xntions, with the participation of Vietmtmpse scientists arwl scientists ir'/m other countries, find with cooperation, support, nnd protection prorhtwl !>y I-he contending forces In the area. This study, which could well ho supplcHsr.-jited >.'>• pxi*'rim<-;if;il work els"when>, should provide n detailed environmental tin- • . .'jjys-is of the lonff-njiijre effects of the agents used and of tho steps necessary to .-; r-ure optimum future prodinMrltf of tho environment for the welfare of its ., '• i.-.h.ii'itarirs. -. . • • •...._.... - ."". . Further, we nrjre that the maximum possihle, nmourit of relevant data be . released from military security, so that the scieritistw conducting the studf anay kiioyv the r-mjiloyed. arcnn affected, the ngent.s used, the dates applied, nnd the dwiages We express especial concern about tho nsc of arsenical hprbl^kg! in Vietnam, and urge that their use be suspended, if it has not already U^^HJopiff'd. mull the ultimate fate of the degraded arsenical compounds cai^^^Kre reliably determined. • ^^J We recognize the difficulties involved in the proposed field study: however, it .is our hope that the feasibility of such a study may be increased as a re-ult of the current peace talks ijj| 1'aris. Finally, we hope the' recommended study can bo initiated promptly and we proffer the good offices of the association in helping to plan it and to publicize its findings.1" ' One.' supplementary statement, by Messrs. Commoner, ITolton, and • ' Steinbach, declared that the herbicide program, should be stopped because (a) U.S. experience was not relevant, in view of the higher do=ajre levels in military use; (&) the chemicals inhibited the formation of nitrogen-fixing nodules in leguminous plants; and (c) might cause widespread chromosomal, damage among plants. Moreover, the use of herbicides raised serious moral and political questions whiHi "Ought to bo carefully considered in the present national debate on the morality and political wisdow of the war i n Viet nain. 90 A second supplementary statement, by Messrs. Roberts and Tliimann, took specific exception to the first supplementary statement, and held that "the use of 2,4-1) and 2,4,5-T for defoliation of forest cover probably represents a military device for saving lives that has an tui• precedented degrefc of harmlessness to the environment." in!' A ^ third supplementary statement^ by Messrs. Glass, Hoagland, ilolton, Klopsteg, Price, Kees, Rieser, Roberts, Steinbach, and "\Volile, agreed that United Nations sponsorship of. the recommended study • would be desirable, but insisted that "iix case such a course of action . •'is not politically feasible for the United Xations,'theU.S. Govm-maent should reserve the option of initiating and supporting such a study ..through some private institution or special panel of independent observers." m A fourth supplementaiy statement', by John A. YTheeler, a juiclear physicist, expressed the view that 20 years of ecological research would not produce "an order-of-nmgnitude increase in the available iuformat ion," and that enough was already known for the immediate jwlicy decision. He recommended greater effort in disseminating herbicide information, issuance by tho United Nations of limits on arsenical herbicides, U.S. research on herbicides in the. United States, and ac• ceptance of tho existing situnf ion in Vietnam in which the local people had tho responsibility for deciding tho military use or nouttse of herbicides.10; A clarifying exchange regarding this action by the AAAS board appeared subsequently in the pages of BioSciencc, the journal of the . American Institute of Biological Sciences. Prof. A. Carl Leopold, of »» 11)1(1., p. 2.Vi. Iil.'tn. �ti:o Department of Horticulture at Purdue University, in an editorial stareme-m aj^^^ t h a t t!ie cil'oets ot' military herbicide use should be studied; bi^^Bacted strongly airuinst the position taken by Messrs. Commoner JpPFon, and Steinbach: "* * * With 500,000 American men in a killing war in Vietnam, to assert that this herbicide cannot Iv used in protecting them, when we use f>7 million pounds of it per year in our own country, is fantastic.'' 103 The three AAAS board. nu v mlK>rs whoso, position Leopold questioned, replied in a joint statement in the December issue of the same, journal. They referred to Dr. Fu-tcr's assurance to the AAAS board, by letter of September 29,19GT, (1) Qualified scientists, both inside and outside our ^Government, and in the governments of other nations, have judged that seriously adverse consequences will not occur [from the military use of herbicides]. (~2) Unless we had confidence in these judgments, vwe would not continue to employ these materials. • ' . . The respondents insisted that what was involved was scientific judgment : whether the use of herbicides by the military services would in fact, have serious long-term ecological consequences. They went on to suggest that the Leopold editorial "* * * reflects confusion re-. garding the role of scientific judgment in the social issues which involve substantive questions of a technical nature." Kvery technology [their statement continued] involves benefits and hazards; scientific evidence is required to evaluate the extent of (fee hazard associated with a given benefit. However, a judgment which determines whether the estimated hazards outweigh the estimated benefits is not a scientific matter. Such a judgment must be made by an individual on ethical grounds, and Ivy a society on the basis •:<f political decisions, which it i.s to be hoped, reflect ilic moral views of that society. It i.s i/erhn]« useful to point out that the Ooveniisaent of the United States, has already forsworn the use of certain weapons in Vietnam that might con- . '•civably, in the short run, save the lives of some U.S. soldiers: nuclear weapons. The present question i.s whether the chemical weapons now in use in Vietnam ought to fall under a .simi'.ur proscription. Leopold is, o€ course, free to express his own view <in the moral Judgment, but he, and other responsible members of •In- scientific commur;ity, also have an obligation to refra.it] from confusing their own moral judgment with scientific fact.10' ,. • • • - of AAAS Correxpowhncp, with Stale. Defoitsc, and United • Nations . ' . • - • Following the AAAS board meeting, lot tors were sent out "July 19, |]Oi;,S, over the .signature of Dr. Dael WoHle, e.woutive ofiicer of the f AAAS, to the Secretaries of State and Defense, and to the Secretary :]' (t-iH-ral of t!ie United Xations. The letter io list- Secretary General rransmifU'd a cojjy of the statcmont by the Ixwrd of directors, and fn-k-ed that consideration be given to the, proim^n] that (he Uniled Xah'ons assume responsibility for a study of the long-term effects of jthf 1 . u-c of flii'inii'iil hei'bicides on the ecology of Vietnam, This, said it : ic Ictft-r, would be a ''means of insuring objectivity and iutjTnatiniiiil |;>artiri|iafinn "' * V The response, August 5, signed by .lost' KolxiF'f-nnoft. fixU-r Secretiiry fieneral for Special Political All'airs, indi•atcd that, the Socivlury Cioiu'rul oll'ered assunmcos " * * * that the |.iatt4T of Hicmiral and bacteriological weapons 5s receiving his very. i-ioHc attention." • 8, vol. IS. No. !)), p. «53. i," KiuSclmrv, (Ijrcrmbnr, JfKJS), p. 1007. The response of the Department of State, dated Septea^er 3, signed by Charles E. Bohlen, .Deputy Under Secretary, to^BLte of the fact that "there are differences of opinion on the use o^^Kn chemicals even among the members of this distinguished grou^r l^ivcalled 'that limited studies, already made by Government • agencies, had "failed to reveal serious ecological disturbance.-;/"- It. acknowledged, however, that "the ultimate ell'ect, of these herbicides c"in_ be determined definitively only by-long-term studies." Accordingly it favored • such a long-term study in Vietnam. However— ' . Such studies in combat areaH are.'obviously difficult at present. The United States will be happy to cooperate in responsible long-term investigations of thi.s • type as soon as practicable. The participants should be selected on the basis of their scientific competence to insure acceptance by tbe .scientific community. , The AA AS letter to the Secretary of Defense expressed "ratification at the MR I survey. .But it noted "that "* * * on .a number of points information is lacking or insufficient." • . The [AAAS] board has concluded that a study should be conducted of the long-term effects of the use of chemical defoliants on the ecology of Vietnam, and • has proposed that that study bo carried out under the U.X. auspices. A majority of the members of the board have added a supplementary recommendation that th«« United States assume responsibility for such a study if the United Xations is unable to do so. gn t eip the AAA|S board,1 and repeated the earlier assurance that herbicides ..would not be used if competent opinion found them to have scriou.slv seri adverse-consequences. The.letter continued— • ' • •-.-- - - -. • •* * * Vife.have continued to gather data and to repvaUiate-aU available data and technical judgments. While th^re are a number of scientific. i|Uc>tii>:i> left unanswered by available studios. I those fiuestions apparently \\uiiiil ;n>f be answered Iff additional, short-term investigations. On balance, wo continue to be • confident tjiat the controlled use of jherbicUU-s will have no long-term tvola^u-ul • impacts inimical to the ix>ople and interests of South Vietnam. Before we started the herbicide program in Vietnam, we siwnt a year studying the effects I of. herbicides on experimental plots in South Vietnam. \\V hud ai.-> compiled n botanical survey of South Vietnam, a copy of which is attached. On several occasions we have sent scientists, both from DOO and the IVi>:ir;tiient of Agriculture, to South Vietnam, to search for evidence of adverse ecological change. 'Tlie Department of State and AID hnve also made evaluative surveys utilizing consultants from universities, the Department of Ai:ricuUiin>, and the U.S. Forest Service. To date, ail of the reports of these surveys indicate no evidence of serious adverse ecological effects. . Systematic scientific investigation in combat zones is virtually imixis-ible. Substantial military protection I i required to secure an area for meaningful study. Therefore we have devoted effort to studies' of analogous areas. \\V .-upporfed the Department of Agriculture in a fi-year study of herbicides in areas nf Puerto llieo and Texas which are similar to areas of South Vietnam; a copy of the ivixn-t on those Investigations is also attached. Wo have boneliltod from the-experience of others. For example, ur.-onica! herbicides have been used extensively in nibbor and oil-palm plantations In Malaysia for over 20 years nt application rates 5 to i> time* in i«xivs.s of timse used In South Vietnam, apparently without adverse eil'ects. The ar.-enical we 'have used,(dimethyl ursinio acid) I.s one of tin- least t«xic of herbicides to mammals. Wo are, -of course, continuing our Investigations and Mirvcyn. 1 believe we have consistently taken n responsible and o|M'timinded approach to the herbieido program of the Department of !>efenve. As SMMUI i\* iwaceful condition's return to Vietnam, niul M.v.stomati'.' scientific Investigation becomes feasible, we will support additional stud ION in nil ways that im« legal and proper. ' �t Attempt at Herbicide Assessment ion that seems relevant to the calls for an immediate ly of the effects of repeated use of herbicides on the logy was an assessment under State Department Vietnamese auspices in Saigon during'September IOCS. Apparently no single vector was responsible for motivating this assessment; rather, it was . ' the culmination of a number of unrelated developments: The request, by the, AAAS board of directors that brought in the United Nations, as well as the Department of State; The. fact that Dr. Fred IT. Tschirley of Oae U.S. Department of Agriculture, at the request of the Department of State, had niado ecological observations earlier in the year In some areas of Viet-..' na?n where herbicides had been used; _ _. • ' The fact that the AAAS board of directors was still in c'om" munication with the Department of Defense on the herbicide issue; • ' . ' . • The apparent concern of officials of tine Agency for Inter- '. national Development. (AID) over occasional instances of inadvertent damage to crops from military herbicide spraying. operations; . . The drumfire of propaganda from Hanoi and Peking, charging 1 the use of "poisonous ' herbicides (which tiae Yietcong guerrillas apparently accepted at face value) ; . The possibility that "world public opinion" had been influenced by Communist allegations that required contradiction from well- • . documented sources: • •• •' "1 The possibility that South Vietnamese officials and public.re-. ; ""'qtiired some degree of formal reassurance. . . . •'.•';"•.."'""•','.! Apparently, the herbicide program in Vietnam had been. subj jected to repeated reviews and assessments within the official U.S. '.. ini-sion to Vietnam. A report by Elizabeth Pond .in the Christian S'"'-'-nce Monitor, in late 1067, noted that in the spring of that year, " Fallowing damage to rubber trees and to fruit trees, the military command reportedly ran a reassessment of its program and banned some • ' . of the more volatile herbicides it had been iisuig and extended the . radius of prohibited operation? around plantations." A more extensive a.-.--:--^ment was in progress in December 19G7. According to the story . from Miss Pond, "no one. in the mission questions the use of defoliants . where military gains are clear cut and accompanying agricultural looses are, minimal." However, there was nneasJmess "about the actual practice of defoliation, about the. doctrine and guidelines under which it i.s carried out." A subjective .indicator cited \Va.s t h a t "One American ••ifTiciul i;i II i Corps, the hardest hit of any of the corps by unintended fallout, {rave the -judgment that virtually every Farmer in that, corps knows of the defoliation program and disapproves of it." Accordingly, there was an apparent need for "some workable rule, of thumb for measuring potential military gain against potential economic, and . ' political loss." The economic officials, sho said, '"have asked recently '."•'" for a technical study on tho potency and duration of effectiveness of some of the chemicals used." In addition, the mission oflicials— * * • would likf> to run « cheek on the guidelines ttfvf In use on defoliation operations. They would like to reconsider the permillcij margin of error, the ad- ju«tmpnt to changed conditions due to time lags between conceptio: of operations, and duration of authorization—-currently 1 year. They would like to find out how much the danger of low-alti the other delicate controls needed in mixed forest-cropland a execution » ug affects The more extensive.'assessment by the Department of State that took place during, 1968, under the sponsorship of Ambassador ELs.worth Bunker, was reported in Saigon by the U.S. niiikion, September J18; the text of the basic press release was as follows; . In keeping with tho U.S. mission's policy of continually monitoring the U.S. jrole In Allied herbicide operations iix South Vietnam, Ambassador Ellsworth Bunker established a special interagency committee earlier 'this year to make a comprehensive review of the program. The herbicide program, which is under the overall direction, of the GVX and supportf.-d by U.S. military and civilian elements, has been an integral part of the allied military effort. The committee's tusk was to asses.s'the military benefits of the program in relation to its economic costs arid to shidy its effects upon tho ecology of the country. The review indicated that in. general herbicide operations in Vietnam have been accomplished without significant damage to the ecology of the country and that the military . benefits in terms of lives saved and other factors have far outweighed certain known adverse economic effects. The committee, however, recommended certain steps to reduce some of the economic costs as noted below. Assisting the committee were a number of scientific and technical experts, pome of whom were brought from the United States for this study. Among them was Dr. Fred H. Tschirley, an authority on tropical ecology who is with the U.S. Department of Agriculture. He conducted a separate investigation of the ecological consequences (Jf the defoliation in Vietnam. The full.text of this study is attached to this press release. • ' According to the findings of the committee, the use of herbicides around base perimeters, along lines of communication, and against enemy infiltration routes, staging and base areas has, both in terms of offensive and defensive action., reduced the number of men and amount Of equipment required for combat mission.*. •.secured..material and facilities, and, most.importantly, helped .to save.the,lives. .of many Vietnamese and Allied personnel. . • . -- ' . ' • The military benefits of the use of herbicides against enemy food sources ia food-scarce highland areas.in I, II. Ill corps, tho only areas where such o;>er::tions are conducted, was more difficult to assess. There was, however, considerable evidence that food shortages for which herbicide operations were partly responsible, have created logistical problems for the enemy by causing him" to divert h u m n n and other resources to noncombat activities. Kfonomic costs were found to be sizable. The principal cost was in lost or j damaged timber reserves and merchantable timber, particularly in war s-.nno P [ where security conditions have not permitted salvage efforts. There were other, '. minor economic losses for accideutal damage to various crops due to spray or ! vapor drift, equipment failure, and emergency jettisoning of herbicides. "The .committee cutisideivd it within the capability of the GV\ and tho USd, however. ; to reduce and eliminate some of the economic costs of the program, prin«.-ii<aliy 'through salvage operations and reforestation. i Tims, In weighing the overall costs, problems, and unknowns of the herbicide 'programs against the benefits, the committee concluded that the latter outweigh the former and that the programs should be continued, (Also available for information to interested correspondent* are copies of wveral other papers prepared for the committee on a mimlier of technical subjects, including spray drift, the toxieity of herlUeliles used In Vietnam, urn! the persistence of herbicides In soil and water.)' - Query Response . . ....If asked about implementation of Tachirley's recommendations and/or other information concerning program controls and execution, we would respond, as Is necessary and appropriate t h a t : (a) Yes, controls and methods of execution of herbicide programs were reviewed ; (6) Xo repeat no deficiencies were found that . <Dec. 27, rnnil. "V.S, Oillelals Review Vlut Defoliation." Christian Science Monitor. ' �.(rf) Details involve seeuri ng controls and tlie implementation of herbicide, programs rmution mill tantiot be discussed. Accompanying tlie ofiicial 'press release at the Saigon briefing were a • number of papers that liad been prepared earlier. Three of jt|he.ge were unclassified. One. was a detailed report by Dr. Tschirley—"An Assessment of Ecological Consequences of tlie Defoliation Program in Vietnam," duted'April 12. l!)GS.10li The other two, both by T>r..C. E. Minn,rik, director of the plant science laboratory and Dr. K. A. I>;irrow, Chief of the Plant Physiology Division, Department of the Arinv, Fort Detrick, Mel., -\verc: "Toxicity of Herbicides in Use'in IIVX," dated April 3, and "persistence of Herbicides in Soil and Water," dated April C. The, Tschirley paper enumerated the scope of his investigation as follows: ' '. . . •' . The mangrove vocational complex was viewed from a helicopter overflight of the-Rung Sat Special /.one fRSSZ) on March 18, IOCS. Defoliation of-the mangrove in the B.SSX was started in IMG, but most of the defoliation flights were iii.ido after June 1007. A mangrove area on the Ong Doc River that hsul boon sprayed in 1002 was viewed from a C-123 overflight on April 7, 100S. Scmidfciduous forest in war zones C and D were surveyed from a C-123 on Marcli 23, 100S. A more detailed aerial survey was made on March 27, 10«J8 from a high-wing Porter aircraft. Helicopter flights were also made over many of the same arc-as, and some now areas, in the course of being transported to and from specific areas that were surveyed on the ground. Ground surveys weru made from Special Forces camps located at Thien Xgon, Kamni, Tong Is Chom, and Bn L>op from March 2f) to April 1. IOCS, inclusive. Several hours were spent in the fore,<;t at each local ion, to assess <ie foliation,. ivfoliiition, sueccssionril patterns, and to get a feel for the possible effect.-; of the • defoliation on wildlife. In addition to the personal observations, nien at the camps •were, questioned regarding the effect of defoliation on their operation, their irnpri-ssions about the. relative difficulty of human movement in the forest (a roughmeasure of the density and composition of the ground story vegetation), and M.shlinss tlioy had mitdo of wildlife. . • Aerial and ground surveys were concentrated in war zones C and D twcause l.irgn' areas have been sprayed with defoliant in those- zones. Portions of C and P zones have been sprayed 2 and 3 times. There are no,other areas in Vietnam where such large, blocks have been treated or that have been treated so intensively 'an exception to that statement: would be the DM/). Thus, tho ecological eonsequences of the defoliation program would bo expected to he most evident and !i:'»st easily defined in those areas. War zones O and D were also acco.islhle for neris<i survey.* and tho location of Special Forces camps afforded the opportunity nt elose observation from t h o ground. ' - . A concluding introductory remark is necessary, This report can in no sense lie considered a complete, authoritative assessment of tho ecologio effects resulting from defoliation of forest canopy. The conclusions readied are judgments based *~,n prior experience and the 7iecessari!y few observations that were poss'lile. in an area of war activity within the time frame demanded. '"• Substantial)? fills unint- par>«T npponrnil umlcr tin- tltlo "nofnllntlon In VMnnm," ' SH»nri« (vol. lO.'J. Fcii. 21, Ififi!)). pp. 770-TSO. ,\n I m p o r t n n t a i l i l l l l d n to (.lie Science' nrtii-le, not Inclinlc'l with tlif pnpi-r r"lf;iK«'il In .Siil^'nn, WIIH a <;ondu<1inj* Kcolinn of M > r» o*>innji'n(Jji11f>n'*" -whlrli rnnil: . - " ( 1 ) Tli" (Ic.-irnMlity nt <"-<i)n«lc rcscnrch In V l f t n n m n f t c r tlio wnr cndu' onnnot hn ovr'f(»inj>hrt i -iroij. Tiin r*"<cnr«'li vhoiiM IM- iKlmlulHtnr/ 1 '! t l i r n t i1y h nn i t w t l h i t l o n t h ^ t t will futivMr r n n t t i i i i l l y ntiil briMiltli for the r^^'virch prnKrnm. Tin oppordinlty of p H t n M l x h l n j : ocolnclo. ri-nrnn li iui'li>r f l i p f n t p r n n t l ' i i i n l Ill'ilnclcnl I'mtstnm K l u m l i l lif> i>xplor<'<!. "(2) Ci.ritlnnitiit nssi'HMni'iit «f (!»• ili-fnllntlmi program nt It nffi'i'lH fori'Htry nrul wntcr'h'-tl v.iliirK vlioiilil do mnili: Cirnuwt oKxi-mitlmiH nri> lin«f (Ic.ilril!>]'', h u t ncrlnl "llrvcyn during various nfusnua ol the ycur will c n i i t r l b u t o much Knod l i t f u r i n n l l o u " (p, 7Kri). A. Climatic cffcctx . . ^^^V Alleged effects of defoliation on climate assessed as follows: preeipituiiun. no effect; ground twiU'Orature. increa.-cd ; wind .-•[let.-d at ground level, higher. Swttinary : no great effect on higher plants and animals; "might temporarily ai'ft-cv lower life forms more dependent on specific microcliuiatic niche.s for growth iitn! .survival" (pp. -11-42). 'Ji. KffcrtH mi x&lU Kxpresscd fears of laterization (conver.sion of soli to hardened,- infertile form) assessed as follows: only about 30 percent of Vietnamese soils satisfy the condition forlaterization. "I'nrter natural conditions Jaterix.ation is a long-UTii; pro-os. The process is speeded up when soil is exposed to direct solar radiation and wind. • I do not find it, reasonable that the. defoliation program in Vietnam would hastenthe laterization process significantly because bare soil docs not result from defoliation" (p. 44). Possibility of soil erosion : information insufficient for assessment (p. 44). • Possibility of destruction of soil microorganisms: "* * * should have no detrimental effect" (p. 45). ' • • •. • C, Effects on plant and animal populations (1) Mangrove forcat ' Trees wore killed: "20 years is a conservative estimate of the time 'needed for this forest to return to its original condition" (pp. 40—17). ."There has been a steadily incnvasing fish catch." [This .-•ncrge.sf.s that in mangrove areas] the acjujtic food chain has not been. seriously disturbed'' (p. 4S>. "It is reasonable to assume that there has been some reduction in bird nvj.ulation" [but proportionately loss than tho ratio of area treated to total area] (p. 40). "Kffects on other forms of animal life are unlaiown. but surely the popi Ration of invertebrates jn particular has been reduced." [Hut wot 'to the ' point of ' ' "• - (2), Semidccl'iluoua forest . ' - • ' ' Actual area treated is S.140 square kilometers, plus 4€rt square kilometers of mangrove forest: this is 10.2 percent of total forest area. Of this, about 10 percent 'was treated 2 or 3 times. Area studied had been retreated mn-it intensively. [However, this was the dry season, and "there could not have been :\ wor*e time to assess the ecologic impact" on semideciduous forests.] For single treatir.cnr. no "great or lasting effect" was found, but multiple treatment would liavo •'.•» far 'greater effect," '[There is little knowledge about relative susceptibility <-l' tf>rvfi species in Vietnam to herbicides, or about natural regeneration in tropical .forests.] (Pp. -10-.-.3.) : "The greatest danger resulting from repeated defoliation treatments in Vietnam is that such areas \viil be invaded by bamboo" (p. rifi). "Tho greater the number of lierbicid.'il treatments the greater the harm to animal populations" (p. &S). Tho report on herbicide toxirity repeated the fitulitip* rollcvted by. the Mill report respect in<r 2,4-1) and 2. t,'>-T. It found "no syneririi-tic toxicities" in animals as a result of iisim;- these- mixtures. However, tineffect of "orange" (a combination of these two herbicides) nii«rht be fatal to fish under some conditions, although."there have l>ven no ivports of fish k i l l attributed to herbicides." With respect to acid, it was "currently boiiiff employed at a vute no hifjhor than O.."/ pounds per acre, [and accordingly] it is safe to assume that there will bo no harm to man or animals at tlie.-e use rates. Tlie hijrh tolerance of rats, other laboratory animals nnd tish to this herbicide pla<'«» it in a safer category than h'erbicideoran^e. With respect to pu'lonuu "white" �4 was not to b^Mhssidered toxic or hazarctous to luunans, animals or . >f--h at the use ^^^ieing employed in Vietnam." -;| The- report c^PR-bicide persistence in soils and water identified jleloram as the most persistent. However; "In Puerto Rico tests, the |iKmnt of chemical remaining 6 to 12 months after direct application --.'•vji the soil of picloram in amounts four to six times greater thantlsat * VD L.UHUI iiii. vi ui uciui t>uv;ui m^ icoio uii r>uno AI VMII ^» v AW » ii jjrovinccs taken from'1966 to 19G7 defoliation targets, no persistence ;:|f herbicide, was found 11 to 17 months after single and double applications of white." Agent orange was not persistent in soil, and the -.;-J!t-'mk"\ls "disappear in 1 -to 3 months at the rates of application "fj.-ed in I?VX." Agent blue was "rapidly absorbed and inactivated in 'I'ils" so that "susceptible crops can be planted directly in soils witliin ' fevr days after application of eacotlylic acid at rates greater than the gallons per acre, used in 11VX." The. reception among '''concerned" U.S. scientists of the data released t Saigon by Ambassador Ellsworth Bunker's interagency committee •as not well documented. Dr. Barry Commoner called it "pretty bad." . The conclusion I reach [Commoner is quoted P.S saying] Ss that the people .isho distribute the defoliants don't know what they are doing. If the. evidence s ;'.s gathorc-d from, the air the damage must he-pretty had.107 The interagency study received comparatively little mention at tlic > A AS meeting in Dallas, toward the end of the year. In particulai*, ':l|>-. PfeifYer, who had been insistently calling-for a field study in •|'ietnam of ecological effects of herbicide use, appeared not to regard ft';---; Bunker assessment as meeting Ms requirements. ' •. • yj ~f> tied Nation* A ctiorm After A ppeal from A A AS - ' '. | Two actions with possible relevance to the AAA.S request did occur . | . thf. United Nations in the fall of 19G8. One was the adoption \vith: 'I'.it objection by the General Assembly of a resolution that proposed Jo convene in 197-2 a United Nations Conference"on Human Environ,;|;ent. In advance of the conference, the Secretary General was called 4.-1 to submit, a report concerning— I1 .-1 (a) The nature, scope, and progress of work at present being done In the if field of h n r n n u environment; ,;i ( f t ) The main probU-ms facing developed and developing oountrios it* this »| area, which mi^ht with particular advantage be considered at such n con•j| ferewcc, Including the possibilities for inerwxsetl intornational cooperation, ,ls especially as they relate to economic andjsQcial development, in particular -j of the developing countries; ' •J| (c) rosslble methods of preparing for the Conference and the time ueces•'-| fiary for such preparations; (rf) A possible time ntul piuce for the Conference; (n) The range of financial Implications for the United Nations of the holding of the Conference."" M "It's still 'no* on AAAS ttfortu to luunfih Vietnam ecological murvny;"'Scientific >*ffireh (Oct. H. lOHSl. p. 10. '•'" Gcnornl A«»"'mlily Hi-Kulutlnno, Z.'tn! ri'vrulnr sdsHlon. Resolution niloptfxl 2.W.S (XXltl), ''"•r. ?,, 1IK1S. n.'i.lnl plenary mi'^tlni*. In coinmcnt nn tliU nrtlon, Sciuttor Milsklo, Apr. 3, :• i-!nrc.-l Hint "Thi> nntloiiK »f tin- worlil must. ilvv^Iop coolrmlrul t'onscli-ni'i'a, nn nw«r»-npsa :i:tf WP KTf nil n part of ,1 tiltiKlt ooosyntcm iltsvclopcil OVi-r con« of tlmi>. Our nltcmllon f lliat tfiroHystcm [iiitti n lu-nvy rcsponslltltlty on »n:i» to nuinn^fr f h c n n u l l t y of tin* environ* in-lit to nsstiro his own unrvlvivl nml tlio survival of tlioso otlii-r spocliiH cKHoattul to lEfc on .irth." II- oSiTi-iJ n ri'xolutloh (S. Iloa, 170) t h u t the United K t n t c B Blionlil artlvi-ly Hut>l<ort ni! pftrtlM|iiit« In Kiich n ronfeti'licc-aiKl assist in HH formation. (ConBrcKKlonnl Itrcord. '.pr. 3. lOHa, pp. S:«30-S3531.)' Tlio other TJ.N. action was an Assembly resolution that, •onion'.; other things, called upon the Secretary General to "prepar^B^icise. Report * * * based on accessible material and' prepared v^^^Bu £i.-?istarid' anco of qualified consultant experts" concerning "vari "pects of position _ „ ____ ____ . . .. warfare, including herbicides, hud been de=-;ci-i)K;d to -the U.X. Assembly, December 5, l%f>, by.San'iuel M.. Xubrit.'U.S. A nibaHHador to the United Nations. He said"the U.S. dclugsition would support, the U.N. endorsement "of the Geneva protocol of 102"). As uncler.-.rood by the United States, the Geneva protocol of 1025, he said, "prohibits the use in war of asphyxiating and poisonous gas and other similar gases and liquids with equally -deadly eil'ects." However, "* * * the protocol does not apply to herbicides,' which involve the same chemicals and have the same eil'ects as those used domostica'lly in the United States, the Soviet Union and many other countries to control weeds .and other unwanted vegetation." uo The AAAS Board of Directors invited to its October meeting, for the discussion of the herbicide issue a number of persons involved in this issue in or for the Department of 'Defense.111 At this meeting, a public symposium >vas planned for the annual meeting of the a.^ociation, to air views on the MRI report, the Tschirlev report in Saigon, and other aspects. Dr. Pfeiil'er, who had apparently not been. ~ati>f;t-d with either the MKI report or the. subsequent Tseh'irley nvestigatinn. a few days after the board meeting, oll'cred to the Committee on Coun' cil Affairs a resolution that- the. council ask the committee ou.i'nvh-oii,mental alteration to appoint a subcommittee to conduct the. field study called for in the board resolution adopted the previous J une. Renewed AAAS Appeal for Field Ecological In-i-e tf When the AAAS membership convened at Dallas, at the close of ' IOCS, the status of the controversy over military use of herbicide.-? in Vietnam was as follows : Tho Department of Defense had released considerable technical information assertedly relevant to its conclusion that no "seriouslv adverse consequences" resulted from military herbicide usage; and had given assurance that the assessment program was continuing. The AAAS board of directors had urged specific reductions in the program, and had not revised this recommendation upon receipt of DOD information. . i" Gfiifnil 'ASKomlilv HcsoluUons. 2.1r<) rcpilar session, Resolution Adopted 24. r i-t-.\(XXlin. t>cc. ^0>, lOC.S, 1750th plenary inc-etinjr. no Representative Robert Kn&tenwi'li'r, Sept. It, IP.V.*, liail pruposeil n rc-xolutlnn (U.Cnn. Res. -lail) that wmilil renlllrm the "lon^stiHiilhii: pulley of the Vnitisl stnt«.s Uiat In th» event of wnr the United Ktiitex Hhull under no rlrrunistwnecu resort to the u-"- of h'.nlc'glcal -weapons or the nse of poisonous or (noxious) t'lt-^'-'s unities they are I'r^t usisl by" our pnemleK," Both the Department* of Ktute nml ivfense opp«»i'd pnnRnw nf this renoluttoti. However, 8tnte'» opposition was based on tlie propusltUm t h a t It was r m l u n d n n t h'H^iu-'e the U n i t e d StiHon WUH already romtitlttol to n-fnilu from t hi e use of fonv of any kind In a niniiner contrary to the charter of the fnlti-d Rations. I)i parti«fiit of ivfi'ti".- oppi>>l* tlon WIIB Also bused on (he f u r t h e r conslderiilion tlmt other coimtrli-s were nctlvely smrmilii); programs In thin Held, nnd the propo-od ri-solnilon would posslhly "lutnxliji-e uncertainty Into the neeessitry tiliinnlnt; of tin* Dejiurtrneiit of iN-fen^e In freparliij; to meet ponslhle luiHtlle uetloti of all kinds." "'Them' WiTe: Mi'SHrs. Rodnry NldiolR nnd A. K. Hnywnrd ttf the Office of the Piroetor of Defenne ReseureU and Kngluecrlni; • find Dr». Mlnarlk and Tuelilrley. �0-i I AAAS liadJJ^unable to find a way to enlist the. resources of the T'.X. iti the cd^^Bof an on-the-spot study; the study performed by 1i >OD at the inlHIce. of the AAAS had been limited to the open litcra-| uro, and had'not involved the collection of onsite data; the State I)eJ v.u-tinc>nt,'ri release of data in Saigon had not,quieted those who sought l|f jf'i'.sUo data. . . ' I Accordingly, in the annual meeting of the. AAAS Council, m Dc$v-.VH-r lOr.S.tho board of directors announced that the AAAS "would |; .-..-* icipate in a study of the use of herbicides in Vietnam." An account •'*;>: t';! t « council's msponse to this announcement. carried in Science, was s follows:" . ' In a. heated meeting in an overheated room on Monday, the hoard's inclusion ;" Vii tnam in its original resolution was challenged by cotuieil members. TLe stack was oix'iied by .Tunics U. Ross, representing the Xatun; Con.sorvancy, who .\u that tin- hoard should concern itself with other environmental hazards and $='..>;;'.d not single out Vietnam. A resolution expressing the agreement of the |e..-;r;.'-i! w i t h the sense of the board resolution to conduct a study of the use of }!';•. •.•-!• ifides in Vietnam, but advising changes in the language of the board's orig..-Jir.:;! resolution so as to delete mention of Vietnam, was passed overwhelmingly. $!:> pussinij such a resolution, the council was taking' a iwsition similar' to that .;|;^ .;.ted at rhelOCG AAAS meeting in Washington, D.C. ;-?| 'in accordance with this advice from the council, the board revised its resolu: ?.i i\<--n to read as follows : 1 •it is the sense of the board tbat the association, looking not only to tlje effects r.hc wartime use of herbicides, but also to tho .opportunities for the peacetime <>::struetion of the agriculture and economy of Effected areas : '(1) Determines that 1 1 .-•!• ill be1 a purpose of the association to bring into ';•• field study of the potential long- and short-tomn rig the mo-t effective p ' • • "' . •'•.•jfical risks nnrllionefir.- • . ' h " areas affected; " i 2 i . Sjvcilically directs t i •• AAAS staff to convene, as soon as possible, an-SMl1' •• pv.u;> involving rf-pre .-creation of interested national and •international organization.-! to prr-pure specific plans for conduct of such a field study r.d with t!ic exiK-<;tuHon that the AAAS would participate in such 'a study within .-.• rvjsoiiabU- limits o f i t s resources." "2 • . . • . . ' • . The article went on to note that "At the Dallas meeting of the AAAS, .. V,'. Pfcifi'or of the University of Montana introduced, before the Yhv-re were also papers on tho possible ecological consequences of the ;:-<i of herbicides in Vietnam presented at si meeting sponsored i'Miitly by the AAAS Committee on Science in tho Promotion of FFmntin Welfare and the Scientists' Institute for Public Information. • The technical papers before the joint meeting were presented by Dr. Tschirlcy, "Dr. P.ovsie K. Day, professor of plant physiology and :iH.-.ociato director of the experiment station, University of California f Riverside), Professor Galston, and a panel discussion with questions from i\-.f: Hoor. . ' . Dr. T.-<-h iriey, in his prepared statement, covered essentially the :-:i7ne. matt-rial a:-; in his Saigon report. T)r. Day stressed TT.S. domestic' experience, with herbicides—noting that some 100,000 ^rganic comlounds were synthesized and tested annually as herbicides, 125 were' bicing marketed, and about 50 we.ro in quite "extensive use. There was I'T.rycp Ni'l-ion. "ITorhlrl.Ji-a -In Vietnam : AAAS Board Seeks VIM (Vol. lfi:i,.Jfon. ,1, 1000), p. K.H. ' . , Study," Science ..•,.:.:, A.^ no relation between herbicidal effect and mammalian t^^ity. The hazards to vegetation included "failure of selectivity/i^^^nges rh climate, soil, rainfall," and "migration of the herbicfdcJBHprikT.site." In the United States, he said, tiie use of herbicides was •unduly regulated." _The primary discoverer of a herbicide develops toxicity information, develops use information, and supplies this i n f o r m a t i o n to, an agency of the Government in support of a request; for registration. Tho label, in this trade, he said, was "a sort of a holy document/' To obtain the label involved some'$:> million of laboratory and Jit-Id research and up to $G, -$8, $10 million i n ' f u r t h e r development. (The. implication of this presentation was that before herbicides found their way into military service, they had received an abundance of testing so that their properties were rather precisely known.) The presentation-.by Professor Galston took tlie opposite position. He acknowledged that 'plant regulating chemicals 1md been a "really brilliant' contribution." However, the "use of any chemical additive carries with it certain dangers." While peacetime society "has safeguards of such use," he warned that "Under military and especially under wartime conditions these restraints can he an autocatalyti'c process leading to still further transgressions and that it is in this area in which a signal lack of restraints currently bedevils us. and alarms some of us.".He wjis critical of the "bland reassurances" of Defense scientists as to the nontoxicity of military herbicides, and declared that in view 'of the "great stability*' of picloram, its use presented a real hazard of long-term damage to the ecology. "I suspect that great •damage will have been done," he said. lie voiced again his earlier apprehensions concerning danger to microorganisms in the foil, latent* scat ion, and massive erosion from monsoonal rains. Then he warned: "We are continually investigating new chemicals for military use.***" Moreover, "The restraints in this area and the rules governing the introduction of new weapons into warfare constitute a very great danger for all of us." The initiating action, under combnt conditions, is taken by a military oflicer. There is a clearance procedure, he conceded, but it was not as'precise and absolute as with the "big bang weapons." Then he concluded: I believe that, we have restraints built into our warfare situation n the bifj bang weapons. We know that, nobody may use any nuclear device in warfare unless the President of the t'nited States authorizes the pressing of that button. With regard to the chemical agents, the restraints seem much looser and it seems to me that . practices that are being conducted in the name of thf American people in Vietnam in the way of killing vegetation at the moment have not been subjected to the same kind of searching and restrainiuir curiosity that r personally would like to see. What about the new wcai>ons that are under development now? Who is going to exert control over the use of those? If. for example, a decision Is made to kill rice, which feeds [validations, as a weai«>n of war, why, then, report to the use of chemicals which have to be sprayed by airplane time after time with the (lunger to the pilots » * ». Why not use an organism to do thisV • ' - Tho panel discussion highlighted some of the dillicuitie.-; the entists were encountering in achieving a coiir-viisus in tho «*-i»«"<mont of herbicides in Vietnam. A condensed sampling of the- dii-vussion is us follows: Dr. Commoner: Expnwod concern over u n a n t i c m n t o ' t biological hazards. Were there anv? Were they anticipated? What steps, were �taken to sco t! were anticipated? What was the relation between this report p port) and their military use ? Dr. Day: ow a great deal about, herbicides. Piclorant <does break down soil. There-i_ - been some 10.000 pupcrs p t 1 • have dealing n * ir\ ___!.: c. AI - LL., . . with the, effects of 2,4-D, which comes from the "stone age of faerbicides." • • • ' I'll'' ' ' Dr. Margaret Mead: "We are, talk-ing about a variant of the "scorched earth policy." Today, there is a "new ethics"—it is a now thfrag to worry about the weliarc of an enemy. We arc beginning to realize that we are living on a planet—"a total system." Yet, we. have a'tendency: to-worry about smii-1 i?sues. "' ' • . Dr. Day: ';I admit that the world is run on incomplete knowledge.'* The MKI report gave little coverage of much of the practical literature. "The thing was prepared in GO days by people who know not/lung about herbicides." Dr. Commoner: "The public revelations about this problem havebeen characterized by * * * quick and poorly conceived responses to jabs of criticism made by concerned scientists." He referred to Dr. Tschirley's survey as a "30 day quickie look in the dry season/'' What was needed, he said, was a "long-term continued investigation."' Dr. Tsehirle.y: Was in agreement, but who would pay for it? Could it be made a part- of the activity under the international biological program: Jrie com l:.-ined that the "ecosystem approach" had fit* been clone; there was •>' much communication between ecologists and other scientists. T; re was a need to get together with tho people- who work with pest!••• •-. There was a great deal known about these, in the United States. W '.ould admit we need.more ecological information,-., But vre can mak:/ ;ter use of what we already know. We know, very lir;.!--about ecosyst. us in any sense. • -. '• • Dr. Galstori:*]*: ;-:«! a question about the metabolism of cacodylic . i:c:d. and the availability of information about it. Dr. Day: There was "so much arsenic lying around in nature that r',3 very difficult to sort out the little bit that Ave're putting into the s-.'.-.tem." The effect-of arsenic deriving from cucodylic acid applications, he said, was "trivial." Agricultural applications of arsewicals amount to as much as 400 to 800 pounds per acre, whereas cacodylic cieid provided only something like 1 or 2 pounds per acre. Dr. Hoi ton: Expressed concern over the use of an incomplete body of scientific knowledge as the basis for action. He stressed the limitations of the scientific support for policymaking. Nevertheless, he roc••v_rni2e.'l, policymakers have to act. Their decisions, though, should not' v --i made dependent on limited scientific knowledge—scientists should ::i-/fc bo made- responsible for political decisions taken on the basis of such insufficient knowledge. Apparent Reduction in AAA8 G'oncarn Over IIfMidden in JOG-9 One action in response to the, new council resolution was tnloen bv Walter Orr Rolxirts, who had retired us AAAS president, to Ixeoomc Hiuirman of the board of directors at the close of IOCS. Ho \vrot«> tho ^vwtary of State, January 10,^1900, on behalf of tho Assonatum ''to request your assisianco in making certain that, as soon as conditions permit there will be undertaken a comprehensive study of the eco- logical effects of th& use of herbicides in Vietnam." Dr. Roberts expressed the Board's gratification that the State Deps^Bfclat/hac} "adopted the recommendations of your consultant, J|^Mchirley regarding the need for ecological research to be ctirrisWPat," and said: "We also understand that there_is, from your Department. a recommendation for the adoption, prior to the cessation of combat, of a policy of defoliation in strips as opposed to big area defoliation." Finally, he ofl'ered the support and assistance- of AAAS in preparing for the recommended postwar assessment: I am sure [ho concluded1] that our board and'our council will enthusiastically support those stops to control the use of defoliants in Vietnam, and to assess the long-term ecological consequences of. the defoliant usage of the past. Thy AAAS will be very Imppy to help in any way that we can. As scientists and citiz'.-rw, v.-n sincerely hope that the steps approved by your Department and our Embassy in - Vietnam will be put promptly Into effect. We will be very pleased to help to plan or to organize an appropriate ecological study that can be conducted in the field . after, very hopefully, tho hostilities cease.10 By the end of June 1909, it appeared that the AAAS had virtually exhausted its initiatives. The association had'obtained assurances from the Department of Defense that herbicide usage would be continually assessed. A general policy had also been established that there should be no long-range and seriously adverse consequences of such usage. .Both tho Departments of State'and Defense had promised support for a postwar ecological investigation of long-range consequences of the military use of Herbicides in Vietnam. The United Nations had agreed 'to sponsor a full-scale international meeting of world scientists on •environmental quality. The issue of chemical and biological warfare had been referred by the General Assembly to the iSth National Dis-: armament Conference in Geneva for consideration as a part of irs per-" manent. agenda. Technical cautions had been expressed by the AAAS board concerning the treatment of large areas or blocks of territory; .the issues of bibdegradability, toxidty, heavy application, and repeated application had been made publicly visible. On tho other hand, the operational role of the AAAS in making -ready for long-sought postwar assessment had not yet been defined. Although pledging its support and assistance, the board and council had taken no steps to mobilize AAAS resources for this purpose. A substantial membership roster had been recruited for the new AAAS Committee on Environmental Alteration, but the staff of AAAS Jiavo made, clear that it was not expected to spearhead the Ouort. 1 '- 4 « 5 l n oommntit on tlic olrcumstancoa loaillnp up to the pnn>.irat!f>n of Wnltf-r Roberts letter, DMO! Wfilfte notM that "Uls<'.\i*»lon« Hobi'ctH had with I"''1!'1"-' in ODDK.'iT: in tl:« Itiiinciliutcly followlne [the I(i):>rtl nif'tliitf of Doci'mher 1V01*! IM! him to Thcoiiorp"C. > "ltyoriy", Ailiiiliilstriit'or.'Oooiu'riitivi? Stnh> U'^caroh Scrvii*, I'.S. IVoi_i.iftmi'nt of Acrli'iiltiiri-:. Dr. John K. <. 1 untl.>n, I'rof.-ssor of Kc««lnK.v. >Ii(rhl ; rau Suite fiinrmncoiuKy. t;onii'il umvi'ruiiy i-inii'co or -Mcuiruic; IT. ^nuiii .•;. ...i....<..., ..•,. of Chi'iiili-nl Ki)«ln(MTlii(f, City ColU-fie of the City. Uolvcrulty of >ew iotk ; Or. '{ �"here was available no indication that its future program would hide the. d^ign^B^fcologieal survey of herbicide efleets in Viets'l, or eveii'the d^^^Htnent of criteria that such a survey would need jarisfy. It reniaimiKo be seen whether its membership could pre.•ehoth stability of leadership and forward momentum. n comment on the status of the'AAAS action on postwar exaralnai of the ebnsequeiu'es of herbicides use in Vietnam, Dael Wolfle has Gained that at the board meeting in April 1009, there- had been no ly to the letter from Dr. Roberts to the Secretary of State, but the . ird chose, to wain a little longer. The State Department still had Jiot lied by the rime of the June meeting, so the board felt it necessary to irn to its December IOCS statement. Accordingly, the AAAS bourd, lint time, began organizing a meeting of representatives of national t international .-•.- ; entific organizations to begin planning the iwomnded field scudy. De. Wollie noted that both the State, Department 1 the Cilice of Defense Research, and Engineering were on record as irnving the idea ol' a substantial field study. lie expressed the la ope t the proposed AAAS sponsored meeting would get this study ler way.115 . ' Pfcijfer's Volunteer llcrliicide Asscsxm-eiit Expedition l;e originator of the motion that had involved the AAAS ira the bteide. controversy. Prof. _E. W. Pfeiffer, of the University of" ntana.had persistently called, throughout subsequent developments, an objective, authoritative, on-the-spot examination and analysis ;he ecological impacts of repeated application of herbicides milif purposes. lie had been frequently quoted with reference to the vious attempts at assessment. The 'MRI study was a "snow job'5-; • S:ugon assessment too general. In October 19GS, he still sougM a :! study: . 'here there's a will there's probably a way [lie was quoted as saying], !<-anbi'licve t h a t there is that much fighting going on in the areas affectc.'-d by )if:iflf.«. Sonic things could be learned and some knowledge is better tlutu no ivledge, which is our situation now. Simply from conversations with South n.'uaese biologists and French plantation owners on the scene, valuable Juforion could be obtained * * *. Already, some European scientists have liteeu, North Vietnam, into the battle zones and have pictures of defoliation :t^'-s 'he AAAS resolution in December lOfiS, calling for a "field sfauly 'lie potential long- and short-term ecological risks and benefits of bio'idf- use r ' was attributed "to the dogged persistence of; A A A S ;ib»'T.s such as PfeilTer and of some, members of the boanU'" 7 Pfeiti'or had also been active, during 1908, in attempting io arouse :ivst. in having a survey organized under the sponsorship of the k-ty for Social Responsibility in Science (SSRS). In this effort v;is supported by Franklin Miller, Jr., of Kenyon College, GamJbier, :o, and vice president of the, society. Miller was reported as saying: hen the war ends it will be of the utmost importance to restore (ho d t i c t i v i f y of the land areas in the combat zones. It is an urgent task r.-'ttf-r from Hr. r>:ifl Wr.lfl* to U. A. Carpenter, July 10, SflflO. Op. fit, "It's f t l ' t *n<">' f-n A ^ A S «-lTortR (o Inuiu-Ji Vli'tn.ijrt f^olo^'l^jtl f»urvf.v." <>J>. clt., p. 10. »ry<-c Nrlhori, "HiTblrlrti-H in Vietnam : A A A S l««ninl Sfi.'k.H Klclil Htndy," i>v. clt.. g>. f>8. gather the necessary information as a basis for sensible and prompt ;tion." Accordingly, his group was "* * * * seeking ways utfMLrlcli; l revive interest,, in such an investigation." 1 " 1 Even before tl'^^^Bv.S . n in December 19GS, Dr. Pfeiil'er had annotmced his ' of conducting a reconnaissance survey in Vietnam under the auspices of the SSIvS. According to a statement in the newsletter of the society. "the trip should produce valuable information and may serve, as a pilot project for a much larger investigation into this field long overdue for scientifically trained observation." The plan' for the survey was described as follows: . ' ' .•'... I. PUIU'OSKS . (a) To stimulate awareness nmons scientists of the need for :ui intensive and long-term study of the effects of military usi's of chemical agents in Vietnam. (ti) To demonstrate the possibility of obtaining meaningful information even with limited funds and personnel. (c) To obtain from Vietnamese .scientists information related to the military uses of chemicals in Vietnam. (il) To obtain samples of foil, water, plant, and animal tissues from treated areas for analyses to determine levels of contamination by different chemicals. (c) To determine effects of defoliants and herbicides on anininl populations. (/) To make a eijiematogrnphic record of areas in Vietnam that hiive been treated by defoliants and herbicides.. • . • •' n. JLEIHODS (a) Interviews with Vietnamese scientists and officials of such organizations as the- National Committee for the Conservation of Xatnre in Vietnam, (It) Examine hospital records vitli ix-ference to patients .suffering from exposure to war fjfises. (<;) Collect samples of soil, water, plant, and animal tissues frouj areas exposed to chemicals... Analyze, these samples, at .'laboratories in the United States to " ....... '' ' . ; 'determine concentrations of chemicals. - (<?) Estimate' population of different mammalian species in chemically treated areas and in ecological similar areas not treated b;* chemicals. Use standard small mammal or bird population sampling technicuies. (c) Make 3(i millimeter motion picture records of the areas in Vietnam that have been treated with chemicals.1" It was not evident that this ambitious plan of investigation was feasible in ''a 15-day incursion into a region of actual combat, by two zoologists, one specializing in the evolution of vertebrate social systems and the, other interested mainly in the renal physiology of mammals. lOven w i t h the assistance of the Department of Defense, which enabled the two scientists to fly defoliation missions, hispoet defoliated areas from gunboat and helicopter, and converse with biologists in Saigon, their findings were necessarily largely based on qualitative information and hearsay. Much of it was economic information about damage being claimed by managers of rubber plantations. Professor Pfeill'er, accompanied by Prof. G. II. Orians, o f _ t h e department of zoolology, University of Washington, Seattle, visited the Republic, of Vietnam, from March 17 to April 1, l!X'>i>. pursuant to this plan. They flew defoliation missions, and observed the effects lit "Ciiomtonl Hiirvcv !u V i e t n a m plumiuil by milvrrslty nnil i n d u s t r y scientists," Scientific cwiiroli, A U K . r>. lOHs., i>. in. "" .S.SKS Ni'W.sk'Uer, No. 1!)4, NovomhiT-lVci-mbcr IOCS, p. 1. �.'in n by river patrol boat in the Mekong Delta. jj£ report, April G, they noted: Crop n programs had been reduced to about one-third ©f 10G7 level; Defolint' protective cover was being maintained at about its 10G7-CS level: Agent white (pidoram and 2,-1-D) was being used much more, extensively in the central highland than previously, because of its low volatility*; Bird life in the ''Saigon Kiver Delta" had apparently been greatly rotduced ; 2\o adverse etTeet from toxioity against mammals was noted frouu agent blue (caeodylie acid) ; :f Accidental, defoliation ''bad been very costly, and is a factor in the greatly | reduced rubber production in Vietnam:" .), "We determined from conversations with U.S. AID experts that tlhe de;-3 foliation program is a potential threat to the forest industry of Soutlh Viet^ naia" such that multiple applications "may kill approximately 00 {percent »i of commercially valuable timber in defoliated'forests." •JJ '•* * * A great deal of accidental defoliation of fruit trees and vegetable ,-t, gardens has occurred as the result of drifting of defoliant and from jeifctison»j ing entire loads of defoliant because of aircraft engine failure;" •i The peculiarity of a guerrilla war, without battle lines.or secure territory a and fixed military targets, inherently results in an effort to increase ffiatali-| ties, deny resources, and deprive cover to the adversary, which is destructive 1 of lives and ecological communities."" \| In the press interview in Isew York upon his return, Professor 'pfeiffcr expanded somewhat on this report. He observed that lit was ;j'cornplctely unrealistic" to expect military commanders to abstain Jirom defoliation actions. "There is no question about it," he' sa:id. j-'fhey save American lives." On a 65-rmle journey by armed! iboat Ji rom Saigon to the sea, he said, "We scarcely saw a living" plant." Mow|,:ver, he added that had the vegetation not been destroyed, he arad his -'companion would probably not have returned alive,"-121.' • .-' -.; :. v;. Ffeiffer and G. H. Orlans. "The Ecological Ejects of the Vietnam \T,"ar: A -;aciry lie-port." (Society for Social ItcsponsIbiUty lu Science, mimeo, Apr. 3. 3.000), ' -ii;*r Sullivan. "Zoologist, Back From Vietnam, Notes Defoliants' Value and; 'Toll." /--.rk Times (Apr. 4, 1909), p. 5. • . , .. .' . ..'. :- V. CONCLUSIONS AXD OB^.RVATIOXS Initial, development of herbicides had been quickly r^^Bzcd in the United States, after World War II, as having enoil^HJfavorable consequences for agriculture. Although their developnWit had been hastened as a part of the scientific effort supporting the war efforts, and a number of new chemicals of unprecedented potency as herbicides resulted from this wartime program, herbicide.s had long l^en used commercially in the United Si ates. The rapid adoption of the new • chemicals into agricultural practice as weed killers was facilitated by the. highly technological diameter of .U.S. 'agriculture generally. Chemically defoliants were closelj*"compatible with farm practice nrul yielded important economic gains through increased farm productivity. Reassessment of the complex secondary and long range consequences of wide-spread usage of commercial herbicides was intensified after 19G2, when the Carson book, "Silent Spring," dramatized the possibly adverse effects of pesticide usage. As more information was accumulated about desirable and undesirable effects of the new chemicals, tho initial-emotional response stimulated by the book was tempered by a more objective realization that herbicides were both potentially dangerous to the environment and important for human survival. It became evident thijt active programs of scientific research were essential to discover as much as.possible about the "ecosystem'*' and the effects of pesticides upon it. Only by this effort would it be possible to maximize the benefits, and reduce the. injurious consequences of the new potent agricultural chemicals. It also became evident that the •science of 'ecology-was in-its infancy, that-an -interdisciplinary ap- . .groach'was needed, and that the. various disciplines contributing to an' . understanding of environmental factors were encountering difficultyin exchanging knowledge across disciplinary boundaries. The initial decision to use herbicides in Vietnam was made by the .-President of the United States at the request of the Republic of Vietnam. Development of the program took place concurrently with an 'enlargement of U.S. participation in the conflict. The program was •dictated by military'advantage. Its primary purpose was to maintain • road and canal trallic with a minimum expenditure of lives and manpower. Its undoubted effectiveness for this purpose lias motivated its • continuation. The program was initiated despite early warnings that adverse public opinion could be expected in response to such a new military application of chemical technology. A positive effort has been maintained by the military services, in cooperation with Republic of Vietnam and United States civil authorities in Saigon and in the .field, to counteract the adverse public reaction by the careful screen-ing of targets, restraint in the use of herbicide chemicals, arrangements to reimburse victims of inadvertent damage, and final approval •of each proposed application at tho highest available level?. Tho. research emphasis in the initial stages of the program was on the development of herbicides that would 1m effective against the. kinds of flora actually encountered in Vietnam. Kmphasis was «1so plaml on tho nchie.vement of tin- speediest possible response—the swift defoliation of tho jungle after the application of a herbicide. However, alien- �tioii was also given to the technology of application to luininuze inadverfentfspi^jug: of unintended targets and to 'assure that sprays could be dii^^H|efliciently against their intended objectives, with least waste. '•Hrghout the program, the question of toxicity <of the chemicals to man and animals was an important concern. Toxicity is important because of tho implications for "chemical warfare" ;und the claims of the, Vietcong that many persons had been noisoroed by aerially sprayed herbicides. Although toxicity has always been difficult to characterize, or measure with absolute precision, and particularly with respect to long range effects of repeated exposures, there hasbeen much experience, in the United States with the measurement of h-:-rbicidc toxicity for practical purposes of home and farm usts. Assessment of the use of herbicides in Vietnam has proved more complex and difficult than the assessment of the use of these same materials in the United csates. One important complicating factor is the 1 controversial nature of U.S. participation'in the hostilities. Anor! •:- is the question as to the propriety of chemicals as a part of the t<-•••:. P. ology employed in conflict—the possible, escalation that anight result from it, and the general desirability of preserving'thresholds f.-> si;..-h escalation. A third complicating factor is the informal arad limited nature of the conflict itself: (1) a number of nations are giving ;••_;:•'•= ."t to the Republic of Vietnam, and a number of other natiorns are ..'.'. ", : '-ipport to the guerrillas and the organized forces of the Xorth ;•' : v.=e: (2) specific restraints have been decided upon arad dc.-_:.::\•-' 1 >. effect, in the conduct of the hostilities; (3) a large psart of t::e ;..•-;"ilities are conducted within the jurisdietional .limits, iif not control, of the Republic of .Vietnam; (4) a very large part w>'f the r -•.-;. of herbicides,, along transportation, arteries, has both military. :.avar.trigo to reduce the likelihood of ambush and the same gcp.neral convenience that, motivates its use along right-of-way .in the TUnited Stares. ' • • A fourth complicating factor'is the imposition of the restraints of j :iitary security over thei flow of information about various aspects o:" tho conflict, including the use and the cffects-of herbicides. A series of protests arose among scientists in the United Stages as r::-_herbicide, program in V i e t n a m expanded after 1902. The general r i t i o n a l e for protests from this source was that since scientists had <•• n r r i b u f e d to the development of tho new technology of herbicides, :! -y had a right to exercise some extent of moral or technical sassess!-;--.'-.i of tlu-ir use. Ic. is indeterminate as to the. extent that this anxiety to assess was '..•ucnsified by the disapproval of U.S. participation 'in the com diet. However, the fact that annual spraying of herbicides in the, United traces, since 1905, has maintained a level of some 120 million. ;acres :-• ••_"_'p.sts t h a t the greater concvni over the more, intensive. UPC of siknilar - • •h.u-iilosjigiiiri.st. 5 million acres in'Vietnam is motivated in part by < ••.-ilk-rations 1-f.yond that for ecological consequences. * A long aiTiiy of specific issues has been raised as questions associated v.-irh military herbicide usage,:_ toxicity to man and animals;, synf-rgistic toxicity of several herbicides in combination, or in coidJmiatfori with oilier^environmental factors, or in interaction with tluc soil, o:- oilier chemical compounds resulting from decomposition; con- centration of herbicides along food chains, in surface'water, in ground reservoirs, in water plants or organisms, in grojlh.'aU'r, m the soil; effects of herbicides on timber crop, and rubl or on food supply generally; losses of domesticated and fish and birds; threatened extinction of rare species; genetic impairments of animals or plants; encroachment of unwanted species on bared areas; mass destruction of sensitivo_ vegetation (e.g., mangrove) requiring decades to recover ; and possibility of hiteri/atiou of exposed jungle soils. . ' In an effort to distinguish military from civilian use. of herbicides attention was drawn to .the asserted greater intensity and more frequent application of defoliants to achieve military objectives, the moral issue of crop destruction, and the question as to the propriety of using chemicals to expose enemy personnel to attack by conventional weapons. The question was also raised as to the military ability to exorcise due restraint in the type, amount, and 'frequency of herbicide applications. The annual meetings of the American Association for the Advancement of Science provided an opportunity for the scientific politicization of the issue. Once the council of the AAAS had adopted a resolution bearing somewhat on the relationship of herbicides to the human environment, those concerned with the use of herbicides in Vietnam continued to keep Jho question of this war use alive among the. membership and the leadership of the association. An attempt wn-> made to separate the thorny political question of military heroic-ides from tho broader but less inflammatory technical issue of "environmental alteration." However, when the board of directors of AAAS attempted to develop a position on the military, herbicide is.sue, it- was able t o agreo substantially on only the one. proposition that the long-range ecological eil'ects needed, study.1-- However, the board of directors did not speak with a single voice, but with five. The e fleet of its dilVused expression of views was doubtful. All parties were agreed as to the desirability of learning more about the long-range ecological ollVcts of intensive military use of herbicides. But the AAAS board of directors had not assumed leadership in defining what form this assessment should take. By June 19G'«), neither those who favored nor those who opposed defoliants in Vietnam had given a clear indication as to what 'tho ecological questions were nor how the}' should be answered. A number of observations can be made on the record of this assessment. process. One. is that a large federation of scientific soeiecies like tho AAAS can provide a valuable forum in which to discuss issues of great public moment. Tho annual meetings of tho AAAS bring together from nil over the United States scientific specialists from many disciplines. An opportunity is provided for those in each individual discipline to exchange knowledge, and also for the valuable crossfertilization of interdisciplinary discussions. Issues that rife_ out of this intellectual ferment, and become recognized by a substantial part of the membership present at these meetings us important concerns, '"To bo mm-, It was nlno fmmcu-tint oonn-rniMl nhmit HIP »."e of cnccxlyllc nelil. find »r;.-H thnt l t n lino bo "miHprniltMl" u n t i l moiv wits known ntuxit HH "f.-itc." lint In .Snlj,">n, two montliti l n l c r , l>r. M l m i r l k ohurnclcrl/.cil IIH t r i v i nlls u tlio qimotttk's of products of d o u b t f u l t o x l c l t v tluit wore l e f t on llni Krouiul frnm 1 1"' > o' *" ls difmlcnl. Tlii; game 'Juclyincut WUH offered In A A A S UlseusHlonH tliv fulluwlHf DvvumLicr by Dr. I>ny. �u-.;-e; \ e u> Oo uu-.vh jvriou.sty by the public at large. With (he effective— if some-times imprecise—aid of the public press, the AAAS is able to identify'anj^^kractfrizo scientific issues in which tho genera:! public has a legitii^^^B)ncern. By the &fflWroken, the AAAS board of directors in its nvore frequent' meetings, and the_ AAAS Council in its formal annual assemblies, are able to crystallize these, issues in a form that can'be cocrnminicated to responsible political dccisionmakers. Hoard actions ami (council resolutions can serve usefully as challenges to existing policy* and as ' demands for policy reviews. Sometimes, the need for specific actions or ' changes can even be made apparent. In the herbicide case, tMs combination of organizational forces gave undoubted emphasis ta> :tho ef-' forts of the- Department of Defense to keep its own house irl order, and to anticipate the need for information about its program. Military reassessment might have gone on in any event, but the persistent ex; •••••ssioiis of concern from the governing'bodies of the AAAS maiy have • ''-ed to make these, reassessments more frequent and more searching. Another observation is that any'issuc on which there are bofth dif:~ -.ilt scientific questions and intense political feeling is unlikelV to be r-/olved in the great forum of discussion that the annual meetrings of I'.Q AAAS produces. Even the more formal and structured sessions of thet AAAS Council appear to be an inappropriate mechanism for the revolving of such political/scientificjis-sues. And, indeed, tlie relaitively small and select group that comprises the "legal entity" of theJLAAS :-; not effective as an instrument for technology assessment. Tlie question might be asked as to wheiher, indeed, the AAAS or : •'.-•• of its component parts should be expected to function as a decisionr. --"ring body on technological assessment matters with a.substantial ; i I ' ricul content. Can scientist's, any more than other people, connpart':. • iralize their judgment regarding'issues they feel strongly sabout? I •" they ignore tlie political content'and address themselves im pure ' j .' -.-to the technical? • | I : . r/e history of the herbicide controversy illustrates once more the I i.• r.-rent difficulty of demonstrating a negative scientifically. Questions !; - to acute toxicity and ecological effects of herbicides used in. "Vict• i- -..'-I were answered for immediate practical purposes. However, clcfinijit! •••• answers as to chronic long-term toxicity, genetic impairment, and .•.'ig-term ecological consequences wore not. available relative to> Viot|r \ :n any more than they wore for tho United States. It can probably bo concluded with justice that the herbicide iques-. :-.."—militan' or civilian—is a part of the larger question of ecological ; 1 environmental consequences of and for man. Apart from tho ;,;cal or normative issues of tho Vietnamese war, tho question w>f tho •::-orim-nws of herbicide use on the environment is a serious and .'loiiit on«, but one that needs to bo answered. The moans by wShich •-. provide the answers are not yet at hand. The fact that all parties • •••Ived in the assessment have agreed-to look long and hard sat tho • twar Vietnanip.^', ecology is reassuring. However, tho state «sf tho •t of the, ecological^ disciplines, and the ability of professional ••oplc in those disciplines to exchange knowledge and under.stan«:ling, • ill be tested to tho limit in.tho performance of such an assessment. tary expedience—irrelevant to tho purposes of science—and whore the results would bo likely to bo clouded by emotional dissonance. �APPENDIX A DRAFT or PENDING SECTION OF M.AXUAL ox Usn OF HKKUJCIDKS FOR ' . ' MILITARY PtTM'OSKS ' . . ' ' ' ' MS SCITLIED BY; DKFAKTMENT OF THE AlllIY ' • • Section I.: TECHNICAL ASPECTS 51. General ; Antiplant agents arc chemical agents which possess a high offensive potential for destroying or seriously limiting the production of food and defoliating vegetation. These compounds include herbicides that kill or inhibit the growth of plants; plant growth regulators that either regulate o r . inhibit plant growth, sometimes causing plant death; desiccants that dry up: plant foliage; and soil sterilants that prevent or inhibit the growth; of %-egetation by action with the soil. Military applications for antiplant agents are based on denying the enemy food and concealment. • 52. Antiplant agents in use a. ORANGE. . (1) Description. Agent ORANGE is the Standard A agent. IT is composed of a 50:50 -mixture -of the n-butyl esters • of 2.4- D and 2,4,5-T (app_D_a.ncl Cl, TM_ 3-1-215). ORANGE appears as a dark. brown oily liquid which is insoluble in water but misoible in oils such as diescl fuel. It weighs about 10.75 pounds per gallon and becomes quite viscous as the temperature drops, solidifying at. 4~>° F. It is noncorrosivc, of low volatility, and nonexplosive, but deteriorates rubber. . . ' i I • ' - (2) Rate of application. The recommended rate of application of ORANGE is 3 gallons per acre. This may vary depending on the . typo of vegetation (app C). In some situations b'etter coverage may bo obtained by diluting ORANGE with diesel fuel oil, which results in a less viscous solution that is dispersed in smaller droplets. Dilution may also be required when using dispersion equipment which dot\s not permit the flow rate to be conveniently adjusted to 3 gallons per acre. See discussion of application methods in paragraphs ">" and 58. •(3) Effect on foliage. ORANGE penetrates the waxy covering of leaves and is absorbed' info the, plant system. Tt a fleets" the crowing points of the plant, resulting in its death. Rains occurring within the First hour after spraying will not reduce the effectiveness of ORANGE to the extent that they reduce the effectiveness of aqueous solutions. Bmulleaf plants arc highly susceptible to ORANGE. Some grasses ca.n IKS controlled but require a much higher dose rate than broadleaf plants. Susceptible, plum's exhibit varying degrees of susceptibility to ORANGE. TVa tli of a given plant may occur within a week or less, or may require up to several months depending on the . (07) �plant's age. stage of growth, susceptibility, and the dose rate. See employment? co^flhtatious in paragraphs 53 through 55. ' (4) Saj^^B'ccautt'onJi and decontamination. ORANGE is relatively nontoSBw man or animals. No injuries have been reported to personnel exposed to aircraft spray. Personnel subject to splashes from handling the agent need not be alarmed, but should shower and change clothes at a convenient, opportunity. ORANGE is noncorrosive to metals but will remove aircraft paint and .walkway coatings. Contaminated aircraft should be washed with soapy water to remove the agent. Rubber hoses and other rubber parts of transfer and dissemination equipment will deteriorate and require replacement, since ORANGE softens rubber. • J. BLUE (Phi/tar 560G). ' • '.'• . (1) Description. Agent BLUE is an aqueous solution containing about 3 pounds per gallon of the sodium salt of cacodylic acid, the proper amount of surfactant (a substance which increases the effec! t-veuess of the solution), and a neutralize.!' to prevent corrosion of I r.ii-' ;! spray apparatus. BLUE is the agent normally used for crop : ik'o:ruction. , . •(2) Rate of o-pplication. BLUE may be sprayed as received! from the manufacturer without dilution, if desired. The recommended .application rate for crop destruction is about 1 to 2 gallons per acre (app .C). However, much higher use rates of BLUE are required to kail tall • grasses, such as elephant grass or sugarcane, because of the large i:lasses of vegetation. For hand-spray operations, two gallons of l BLUE diluted with water to'make 50 gallons will give a solution that can bo dispersed by hand at a rate equivalent to approximately 1-to' 3 gallons o f pure agent p e r acre. . ' ' • " . ' • ..-•-.•-•• (3) Effect on. foliage. Enough BLUE applied to any kind «f foil- . age will cause it to dry and shrivel, but the agent-is more effective ;:L'ain.-;f grassy plants than broadleaf varieties. Best results are obxtaincd when the plant, is thoroughly covered, since the agent, kills by al/sorp- . \ tion of moisture from the leaves. The plants will die within 2 to- 4 days . \ or less and can then bo burned if porinitte.fl to dry sufficiently. Blue in | low do«e rates can also prevent grain formation in rice without any apparent external effect. The plant develops normally but does not yield a crop. Spray rates higher than about one-half gallon per aero usually kill the crop. Although BLUE can produce relatively rapid defoliation, regrowth may occur again in about 30 days. Repeated spraying is ncce.ssary to provide a high degree of continuous plant . ^» 11 *• * (4.) Safety precautions and decontamination. Normal sanitary precautions should be followed when handling BLUE. Although it contains a form of arsenic, BLUE is relatively nontqxic. It should not bo taken, internally, however. Any material' that get on the Lands, face, or other parts of iho body should be washed off at the. first opportunity. Clothes that became, wet with a solution of BLUE should f>e. changed. Aircraft used for spraying this solution .should be, washed well afterward. When WHITE is added to BLUE, u precipitate forms that will clog the system. I f the same, spray apparatus is to !s« used ; for spraying agents WHITE and BLUE, llio system must bo flushed to assure that u.11 residue of the previous ngunt is removed. _-.c. WHITE (TordonJOJ}. ' ' ' . . . ' (1) Description. The active ingredients of agent percent picloram and 80 percent isopropylamine salt c ^ ^ ^ - Active ingredients constitute about 25 percent of the solution.^P^factant is also present. WHITE is soluble in water, noncorrosive, nonflammable, nonvolatile, immiscible in oils, and more viscous .than ORANGE at the same temperature. (2) Rate of application. WHITE usually should be applied at a rate of 3 to 5 gallons per acre on broadleaf vegetation. However, the rate may vary depending on the type of flora. Quantities required to • control jungle vegetation may varv from 5 to 12 gallons per acre. This quantity exceeds the spray capability of most, aircraft spray systems for a single pass. It is usually unfeasible in large-scale military opcra' tions to apply such large volumes. For ground-based spray operations, however, high volumes are necessary. Hand-spray operations cannot evenly cover a whole acre with only 3 gallons of solution. Three gallons of WHITE diluted to a 30-gallon solution can be more easily sprayed over an area of one acre. The manufacturer recommends 'diluting WHITE with sufficient water to make a 10-gallon solution for each gallon of''agent. (3) Effect on foliage. WHITE kills foliage in the same manner as ORANGE, sirjco 80 percent of the active ingredient is 2,4-D. ' PICLORAM is irfore effective than 2,4-D, but acts slower. WHITE is • effective on many plant species, and equal to or more effective than ORANGE on the more woody species. The material must be absorbed through the leaves. The water solution does not penetrate-the waxy • covering of leaves as well as oily mixtures, and is more easily washed • off by rain."" •" " -' • .• . ' ' •-..., • . -•• = (4) Safety precaution* anrl decontamination-. WHITE exhibits' a low hazard from accidental ingest ion. However, it may cause some irritation if splashed into the eyes. Should eye contact' occur. f!u-=h with 'plenty of water. Splashes on the skin should be thoroughly washed with soap and water at the first opportuniiv. Contaminated clothing should be washed before reuse. When WHITE is used in the same equipment as BLUE, all of the WHITE should be i-emoved !•<>fore using BLUE. The two agents produce a white precipitate that will clog spray systems. ' • d. Soil Stcrilants. ' , ( 1 ) BROMACIL. . - ' ' • ' . (a) Drxrr!pf!f>n. BROMACTL is an odorless. nonriMT«~;ve, vliito crystalline solid, slijifhtlv soluble in water or die.-cl fuel oil. Three dip'orent forms are produced: HYVAR-X, a wettable powder containing 80-percent active ineredient; HVVAR-N-WS, a fiO-penvnt active ingredient water-soluble powder; and URON 'B', a liquid containing 4 pounds of active ingredient per gallon (app I)). (5) Rate of application. HYVAR-X is applied at a rate of 15 to 30 pounds per aero; TIYVAR-X-WS, 2-1- to 4S pounds per acre; and UROX 'B', 3 to 0 gallons per acre, Sprav concentrations of the agent as high as 50 to 150 pounds per 100 gallons' of wafer or oil can bo handled by aircraft-mounted spray systems. Tim 80-percent wet- �V-/ ' . (a) JJ&fiption. IIRO'X 22 is'a granular substance containing 122 percent monuron trichloroacetftte. ' ' (i) $nte of application. Tlie manufacturer suggests using 150 I to 200 pounds per acre. (:?) Effect on foliage. Soil sterilants act by absorption through, the jroot system and therefore aro most effective under conditions of good • ;lsoil moisture. They are relatively stable once absorbed into the soil. ' : iS(>il sterilants kill vegetation and may prevent regrowth for periods ;-'of a few months to a year, depending on the quantity and soil concli- coils or a. In some plants, leaves and growing stems form develop marked curvature. I. Growing stems may remain green, but may swell, develop cracks, and form callous tissue. G. Watery, translucent buds often appear at the crowns of some . plants. d. Spongy, enlarged roots may appear, turn black or gray, and rot. e. Dead 'areas will form on the leaves wherever the spray droplets have settled on'the leaf surface. A yellow ring may appear around the 'dead area, and gradually the entire leaf will develop yellow, brown, .or red autumnal coloration and fall. SECTION* III. DISSEMIXATION* METHODS : | (4) Safety pre can f ions and handling. Soil sterilants are only'slightly corrosive to metals, but dispersion equipment should be thor; ;pug!i!y flushed after use. They are relatively nontoxic to humans, but ;1 re-pi rat or masks should be worn to prevent inhalation of dust during '"handling. . . • ..1 ; SECTION" TI. COXCErrS OF EMl'LOVMEXT '• ' y>'-\. General •' . •;j c. The employment of antiplant agents must be carefully controlled' |!<y technically qualified personnel to avoid many undesirable nftcr'•?(<•• :i''~ts. FM :-MO discusses the employment concepts, analysis of opera- . 'us, and limitations of antiplant agents-. a was is ideal for elusive hit-and-run tactics of the guerrilla.'. L.*-::ioval or reduction of this concealment limits the guerrilla's ca-. . {r I'-.ility to operate in the defoliated area. . ' P-;. KiMploymcnt considerations ' . ' -<S l.-i addition to the. concepts discussed in FM 3-10, tho following .v/oiiits should be considered when planning the use of antiplant agents. J ft. Type of Poling4. ORAXGK is a wide-range, general-purpose agent iVhirh is effective on the many types of foliage found in jungle areas. I'.VHITK is also considered a general-purposo herbicide, but it is geu'i Tilly slower than O'KAXGK. BLUE is most effective on the narrow .iip.if .species: the grasses, sugarcane, rice, and other cereal grains. | f>. When to Ai'pty. Tise best time to apply antiplunt agents is during ~~?l:-'. i:i'~t active growing season. This corresponds roughly tot-he pc-riocl ;;" ' • ::;f. appearaticB of new buds until 3 or -t weeks before onset of .^ . •;. =eii.^on. Wh'iIt; spraying during the. dry season does produce -'.:.'ifi», vegetation is not killed as quickly as it is during the. most :'f: "h• <.'.\-<:, growing season. An exception would be in certain tropical j f i w l a n d areas where water is plentiful and c-onfinuous growth exists; ;"1 iiu.s antiplant agents are effective, throughout the. year. 56. Genera] Antiplant agents may be disseminated by various methods depending on tho sizes of the area to be defoliated and whether.the agent- is in liquid, slurry, or solid form. 57. Ground-based application Ground-based, gpray or dispersion methods are suited to small-scale operations such as defoliation around base camps or installations or clearing along routes of communication. These methods depend on •easy access to the area on foot or by spray vehicle. ; 'a. Hand broadcast ing is the simplest way to disperse dry agents. . • such as soil.sterilants,.but-is a rather time-consuming method. . b. A 3-galloti- hand-pump sprayer is easy to xise in areas accessible •by foot but where vehicles cannot, enter. It- is a slow method, however, and areas out of arm's reach arc still inaccessible. (1) UTI-1 series aircraft. (a) .A simple expedient ppray system for a 1*11-1 type aircraft .might consist of a 55-gallon drum fitted with a rubber hose which delivers the solution to a spray bar temporarily mounted ae.iw? the skids. Slight, pre-ssumat.ion of the drum will usually help empty the. drum at a steady rate. A portable* flamethrower pressure, bottle or an A.X-M4 compressor can lx* used for pressurizing, but a gage should be in the. system to warn of excess pressure, (no more than S to 12 psi should be used). The six.e and numlxn- of holes in the spray bar may be determined by trial and error; however, %-inch holes spaced G inches apart will provide, good results. (ft) Another field expedient system uses the, tank and Ill-foot boom of the HI DAL. A 2">-gpm personnel carrier bilge pump delivers the agent, allowing 30 to 40 meters coverage in width. (2) CH-Jfl fth'craff. An expedient spray system for a OH—it aircraft might consist of a oOO-gallon collapsible fuel bladder or a 400-gallon metal, skid-mounted tank. A power-driven fuel transfer pump (50 to 100 gpm) can be used to deliver tho antiplant agent to a spray bar attached to the ramp at the rear of tho aircraft. �j •. The M100 Mity ?>f!te (para 26) may be used $0 disperse liquid or v- .TntipIfui1*^jBts. Foot, access to the ai'ea i,; i-e<quired, but inaccess\i> areas mt^^^Kovcred to some extent, since the Mity Mite will ray a distnQjHsf about 50 feet, d. A ptnccr-Srivcn dccohtfiminating appamtifJi (PDDA) may 1)0 pd when the area is accessible to wheeled vehicles. It is especially 1 mod for spraying soil sterilant in slurry form. The PDDA may j,l-o be used to spray liquid antiplant agents. WHITE and BLU,E , e.scnt no corrosion problems, but the apparatus must be well cleaned rii changing between the two agents. OIJAXGK will soften'the I >'>er parts, such as hoses and valve diaphragms, requiring their I placement after a while. Spraying OEAXGE'lsy PDDA also pro4\ :os a hre hazard. . . •. • I c. Comm-crcial orchard-sprayers, if available, may be used for 1 ..aying liquid solutions where ground access to vehicles is possible. Aerial spray methods ' . • j Aerial spray methods are suited for large-scale operations, since a 1 icer area can be covered and ground access is not necessary. Aerial Y jlieation methods are much more subject to weather conditions, such > wind direction and spc-od and temperature .gradient, than are juuuii-b;'!>od methods. Therefore, particular atteniion 'must be paid \ the possibility of agent drift onto any nearby friendly crops. The jrht of attack, airspeed, and area coverage depend on'weather and rain conditions and pilot experience. a. UC-12-3B Aircraft. UC-123B cargo aircraft fitted with internal Irs and external ?pniy booms are used tor largo-scale defoliation ?pray booms for lar^e-scalc 1 crop c destruction operations. Using the present systems at an al;do of 150 feet as id aii-spced of 130 knots rcsulss in a spray rate of 1.50 i :lions per aera, >-•. FIDAL (Fi:/:cd-v:iny Insecticide Dispersal A ppamfm. Liquid}'. : : FIDAL YA a Xavy developed and tested systom. It has not been udardized by the AVmy. When available, it can bo used to supplant the spray capability of the C-123 systems.'The FIDAL is ig on the AIE or All! aircraft without "modification. Each tank Ms about 275 gallons and has its own ram air turbine to provide ver for pumping this spray through a spray boom. Cosi, is much less n that of C-12:> inboard systems, and spray missions do not tie up aircraft since the tanks can be hung or removed iu'minutes.• • t-. IleJieoptcr-Mowntfid Spray Systems. ' •• \(1) HI DAL (Helicopter Insecticide Dtsspental Appnrafi./s, "p;id)i The IJTIDAL system is a 1%-gallon spcay system suitable ',. us/s in a UH—1 scries helicopter. Helicoptei's are useful in spray' areas around installations that arc; not acce-siblo to wheeled vc'-.-•: minefields, barbed wire barrieiii, etc. The IIIDAL is sclf• •••'], has an adjustable spray rate, and can. l>e installed'and re, -I ;,-. a matter of minutes. It is a Xavy developed system and has ]/:•";'! standardized by tho Army. • . • • ..'•'.-• . f-2) AGAVENCO xpm/<'r, Tho AGAVEXCO system has capaj i l tics similar to those of tlie IIIDAL and is presently being pro,red in a limited quantity. It has not lx>cn stantliirdixod. 1 (~* t 1 ft ^ d. Field Expedient Spray Systems. When systems such OM tu, ; HIDAL are unavailable, field expedient spray systenuj^fct'wiy yrform adequately might be constructed. ^^^B G. Effect on Nearby^ Crops. If the application of a^|^_nt agents is on target to begin with, the main clanger to nearby susceptible crops will be from drift. The main factors affecting agent drift are vandij direction and speed, dissemination method (para 56 through 58), tern-1' perature gradient (TAI 3-240), and the agent used. Conditions for dissemination of antiplant agents are usually most -favorable during early morning hours (before OSOO) while inversion temperature gradient prevails and the wind speed is still low (doc:s_not exceed 8 . knots). A volatile antiplant agent may also produce drift effect even after the spray has settled on target. For example, the slight vaporization of OllAXGE may produce drift damage, especially if nearby iiponzn subjc Thus they can be more safely used near susceptible crops provided . cautions such as wind direction are heeded, and a dissemination method that tends to. produce the least amount o£ drift is used. Although 'soil sterilants do not drift, they should not be used closer than 1UO meters to crops or cropland in a friendly area onto which drainage from treated areas flows.*' d. Duration of Effect. Neither OR AXGE, BLUE, nor WHITE can be consideredi"permano.nt" type antiplant agents. They act by direct contact with the plant. Defoliation result ing from aerial application of BLUE may lie. effective only until new growth appears. Defoliation resulting froin'aerial'application'.'of OR AXGE or WHITE will' usually bo effective for one growing season, but may be effective for periods of approximately 0 months to 1 year. Soil sterilants. on the other hand, ma^y be effective for period.- • • f up to a year or more, because they are desigi ed to be slowly dissolved by rainfall and remain active in the soil. o .13 � Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Alvin L. Young Collection on Agent Orange Description An account of the resource <p style="margin-top: -1em; line-height: 1.2em;">The Alvin L. Young Collection on Agent Orange comprises 120 linear feet and spans the late 1800s to 2005; however, the bulk of the coverage is from the 1960s to the 1980s and there are many undated items. The collection was donated to Special Collections of the National Agricultural Library in 1985 by Dr. Alvin L. Young (1942- ). Dr. Young developed the collection as he conducted extensive research on the military defoliant Agent Orange. The collection is in good condition and includes letters, memoranda, books, reports, press releases, journal and newspaper clippings, field logs and notebooks, newsletters, maps, booklets and pamphlets, photographs, memorabilia, and audiotapes of an interview with Dr. Young.</p> <p>For more about this collection, <a href="/exhibits/speccoll/exhibits/show/alvin-l--young-collection-on-a">view the Agent Orange Exhibit.</a></p> Text A resource consisting primarily of words for reading. Examples include books, letters, dissertations, poems, newspapers, articles, archives of mailing lists. Note that facsimiles or images of texts are still of the genre Text. Box The box containing the original item. 176 Folder The folder containing the original item. 5167 Series The series number of the original item. Series VIII Subseries I Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Creator An entity primarily responsible for making the resource Huddle, F. P. Description An account of the resource <strong>Corporate Author: </strong>Science Policy Research Division, Legislative Reference Service, Library of Congress Date A point or period of time associated with an event in the lifecycle of the resource August 8 1969 Title A name given to the resource A Technology Assessment of the Vietnam Defoliant Matter, A Case History: Report to the Subcommittee on Science, Research, and Development of the Committee on Science and Astronautics, U. S. House of Representatives, Ninety-First Congress, First Session ao_seriesVIII