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RepOrt/ArtlGlO Title Committee Print Veterans' Administration Health-Care
Programs Improvement Act of 1985: Report of the
Committee on Veterans' Affairs, United States Senate,
to accompany S. 876

Journal/Book Title
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1985

Month/Day

Ju| 8

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v

D

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2

DBSCrlptOfl NOtOS

99th Congress, 1st Session, Report 99-101. Calendar No.
220. One page only

Friday, March 15, 2002

Page 5510 of 5571

�Calendar No. 220
MTHGONQMtt

}

fiRMATO
SENATE

RWO T

»

VETERANS' ADMINISTRATION HEALTH-CARE
PROGRAMS IMPROVEMENT ACT OF 1085

REPORT
OF THE

COMMITTEE ON VETERANS' AFFAIRS
UNITED STATES SENATE
TO ACCOMPANY

S. 876

JULY 8, 1985.—Ordered to be printed

V.B. QOVZRHttKNT PRINTINQ OFFICE
49-ttt 0

WASHINGTON ! 1666

�47

disability (or age), income, and net worth limitations; readjustment
counseling; certain burial benefits; loan guaranty benefits in certain cases; and certain employment benefits
Extension of Health-Care Eligibility Based on Exposure to Dioxin or
Other Toxic Substances in Vietnam or to Nuclear Radiation

Section 202 of the Committee bill, which ia derived from section 4
of S. 6, would extend until September 30,1989, the provision in current law which provides certain veterans—those who exposed to
dioxin or other toxic substances used in herbicides or defoliants in
Vietnam or to ionizing radiation from nuclear detonations—with
eligibility for priority health care from the VA for the treatment of
most disabilities.
Background

Under current law, this authority, which was enacted in 1981 by
Public Law 97-72, ia scheduled to terminate 1 year after the Administrator submits the first report on the epidemiological study of
Vietnam veterans mandated by Public Law 96-161. That report is
to be submitted 24 months after the protocol for the study is ap&gt;
proved, which occurred on February 14,1985, Thus, this ajwl'lRi, Interim health-care eligibility is scheduled to expire on February 14,
1987.
^
"
Committee bill

The Committee is proposing to extend this authority becausethe
major study designed to yield the necessary information—d&lt;8 gpl8"
, ^enuplogieal rsBtudy-cf^yietnam --veterans mandated *in ri0TO**pjr
Public. Law 96-151 and authorised-to be expanded byPubiie^JBw
47*72,.which is being carried out by the Centers for DiseaMOon*
irol (GDC), and «ny scientific study-of.th?}ie§lth status of veteram^exposed 4o-radiation undertaken -pursuant ib Public Law ^S^WKKwfflnot be sufficiently advanced by February 1987 to permit final
decisions to be made at that time.
The CDC study—which is now underway—will involve 30,000
veterans, 10,000 of whom will undergo comprehensive 3-day medical examinations at a nongovernmental medical facility in Albuquergue. New Mexira. JThei«c&lt;»pe^f fthifliUiyeat"
" ••«"Selected Cancers •""
jwever, no results regarding the health effects of ex*
,
sin are expected prior to September 1988, the target
late that CDC haa set for reporting on the study. If that target
date is met and this extension has been enacted, the Congress
would have a year before the proposed new expiration date in
which to evaluate the results of the CDC study and other pertinent
information and make decisions on appropriate further action with
regard to dioxin exposure,
i
The Committee intends to monitor closely the CDC study and f
other ongoing studies relating to dioxin exposure as well as studies V
and other activities relating to the health effects of exposure to ra- \
diation. It is the Committee's intention to reconsider the need for •

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Author
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ROpOTt/ArtlCto Tlth Committee Print: Report on Congressional Delegation
Trip to Southeast Asia to the Committee on Veterans'
Affairs, House of Representatives, Ninety-eighth
Congress, Second Session

Journal/Book Tito
Year
Month/Day
Color

O

Number of humus

27

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98th

Tuesday, March 19, 2002

Congress, 2nd Session, Committee Print No. 87

Page 5516 of 5611

�98TH (.k&gt;NCJKES8

I

COMMITTEE PRINT

|

No. H7

REPORT
ON

CONGRESSIONAL DELEGATION TRIP TO
SOUTHEAST ASIA
TO THE

COMMITTEE ON VETERANS' AFFAIRS
HOUSE OF REPRESENTATIVES
NINETY-EIGHTH CONGRESS
SECOND SESSION

U.S. GOVERNMENT PRINTING OFFICE
41-470 O

WASHINGTON : 1985

�ttE ON VKTKKAN.S' AFFAIRS
(i V iSONNYi MONTGOMERY. MiMitoitipi, Chairman
JOHN I ' A I I I . HAMMKIJS&lt;'HMI1)1', Arkansas
DON EDWAKDM, California
CHAI.MKHS P WYLJK, Ohio
HOB EDGAR, Peii.isylvania
KI.WOOD 1111,1,IS, Indiana
SAM B HAM.. JK , Texas
GERALD H I I SOLOMON, New York
DOUGLAS APPLEGATE, Ohio
BOB M. KWEN. Ohio
MARVIN I.EATH, Texas
CHRISTOPHER H. SMITH, NBW Jersey
R1CHAKI) C SHELBY, Alabama
DENNY SMITH, Oregon
DAN MICA, Florida
PHIL liltAMM, Texas
THOMAS A. DASCHLE, South Dakota
DAN BURTON, Indiana
WAYNE DOWDY, Miw.ibs.ppi
DON SIINDQUIST, Tennessee
MATTHEW G MARTINEZ, California
MICHAKI. BILIRAKIS. Florida
LANE EVANS. Illimiib
NANCY LEE JOHNSON, Connecti. ut
MARCY KAPTUR, Ohio
FRANK HARRISON, Pennsylvania
ALAN B MOLIOHAN, West Virginia
TIMOTHY J PENNY, Minnesota
HARLEY O STAGGERS, JK , West Virginia
J ROY ROWLAND, Georgia
JIM SLATTERY, Kantuu
JOHN BKYANT, Texas
JAMES J FLOKIO, New Jeraey
'/«//" Uiret'tor
MACK KU.MIM. i'ht,/ ( ,

�FOREWORD
It was my privilege and honor to head a delegation of six
members on a trip to Indochina from December 6-17, 1984.
During that period we visited Hawaii, the Republic of the
Philippines, Vietnam, Cambodia, Laos and Burma. The delegation met
with high officials in all of the countries visited as well as
representatives of the U.S. State Department. In addition, we met
with Veterans' Administration and military officials in Hawaii and
the Philippines. The meetings included discussions on the health
effects on humans exposed to the herbicide Agent Orange, Amerasian
children, the status of Vietnamese still being held in reeducation
camps in Vietnam and servicemen who continue to be listed as
missing in action (MIA) from the Vietnam conflict. In Hawaii and
the Philippines, the delegation visited facilities where benefits
for veterans and their dependents are provided and/or administered
by the Veterans' Administration.
In the Philippines, the
delegation met with the Deputy Director of the VA regional office
and received a thorough update of its programs and activities.
I want to especially commend LTC Warren Taylor, U.S. Army
Liaison Officer, and his staff for helping make this a most
productive and pleasant trip. LTC Taylor was always available to
the members, and his cooperation and support are deeply appreciated
by all members of the delegation. It was a long arduous trip which
took us to countries that Congressional delegations have visited
infrequently. Special praise is extended to COL Ira Mehlman, M.D.
the delegation physician. He anticipated our every need and his
care and concern for our welfare were crucial to the success of the
trip. The trip took a lot of planning and we salute LTC Taylor and
his staff and COL Mehlman for a job well done.
I also want to single out for special thanks Henry J. Kenny,
Senior Foreign Affairs Officer for Asia, U.S. Arms Control Agency,
and J. Richard Bock, Office of Legislative Affairs for the
Department of State whose advice and counsel were vital to the
success of the trip. I would be most remiss if I failed to mention
Wilbur E. Garrett, editor of the National Geographic Magazine.
Perhaps no other American is as familiar and knowledgeable of the
history, customs, and cultures of the nations of Southeast Asia we
visited. We thank Bill Garrett for a most important contribution.

�IV

It was an extremely worthwhile trip.
Significant
information was obtained which will be helpful in our resolution of
the issues and programs which were reviewed.
The delegation was fortunate to have a magnificent flight
crew, led by LTC Lenwood Steward, to see to our comfort and to
provide an enjoyable and safe journey.
I have received many inquiries concerning the visit. This
report includes findings and recommendations which will be useful
in the work of the Veterans' Affairs Committee and all Members of
Congress.
The delegation noted an increasingly evident Soviet presence
during its visit to Indochina and is concerned that the Soviet
buildup is continuing while American influence in Indochina remains
negligible.
This is particularly disturbing because in every
location we visited, the people were genuinely friendly. It was
obvious that they like Americans.
The delegation concluded that an open and continuing
conversation between the countries of Indochina and the U.S. is
important to the mutual best interests of our nations.
G. V. (Sonny) MONTGOMERY, Chairman
Committee on Veterans' Affairs

�THE DELEGATION
Rep.
Rep.
Rep.
Rep.
Rep.
Rep.
Mr.

G. V. (Sonny) Montgomery (D-Miss.) Chairman
John Paul Hammerschmidt (R-Ark.)
Don Sundquist (R-Tenn.)
Bob Stump (R-Ariz.)
David E. Bonior (D-Mich.)
Larry J. Hopkins (R-Ky.)
Francis W. Stover, Deputy Chief Counsel,
Veterans' Affairs Committee
Mr. James H. Holley, Public Affairs Director,
Veterans' Affairs Committee
Mr. J. Richard Bock, Office of Legislative
Affairs, State Department
COL Ira Mehlman, M.D., Delegation Physician
LTC Warren Taylor, Army Liaison
SSGT Jay Creekmur, Army Escort
SGT Ronald L Starling, Army Escort
Dr. Henry J. Kenny, Senior Foreign Affairs Officer for
Asia, U.S. Arms Control and Disarmament Agency
Mr. Wilbur E. Garrett, Editor, National Geographic
Magazine
(V)

�INTRODUCTION
During the period of December 6-17, 1984, the delegation
visited Hawaii, the Philippines, Vietnam, Cambodia, Laos, and Burma
to discuss issues which are legacies of the Vietnam conflict—the
possible adverse health effects of exposure to Agent Orange on
humans; Amerasian children; Americans who continue to be listed as
missing in action, the MIAs whose families are deeply concerned as
to the whereabouts of their remains; and the citizens of the former
Republic of South Vietnam who supported the U.S. during the Vietnam
war and are still being held in "reeducation camps."
The delegation also visited a Veterans' Administration
facility in Honolulu and was briefed by an official of the
Veterans' Administration in Manila. The delegation also visited
the Joint Casualty Resolution Center (JCRC) in Honolulu, which is
the arm of the Government responsible for continuing efforts to
locate and identify remains of U.S. servicemen still listed as
missing in action.
Prior to departure the delegation discussed these and other
issues pertaining to Southeast Asia with Assistant Secretary of
State for East Asia Affairs, Paul Wolfowitz, as well as with other
officials from the State Department and the White House. This
report summarizes the findings of the delegation and is intended to
provide greater understanding of key issues currently affecting
both American citizens and the future relationship of the United
States with the countries of Indochina.
Assisting the members of the delegation throughout the trip
were Francis W. Stover, Deputy Chief Counsel, and James Hollev,
Director of Public Affairs, House Committee on Veterans' Affairs;
LTC Warren Taylor. U.S. Army; J. Richard Bock U.S. State
Department; and Henry J. Kenny, Senior Foreign Affairs Officer for
Asia, U.S. Arms Control and Disarmament Agency.

(l)

�SCOPE OF REPORT
This report provides current information furnished by
officials of the countries we visited on the issues of Agent
Orange, MIAs, Amerasian children, and political prisoners in
reeducation camps, and the status of a number of veterans' programs
being administered by the Veterans' Administration in Honolulu and
Manila. It is hopeful that this information will be helpful to the
Members of the Committee and to the Congress as they are called
upon to consider legislation on these issues and programs.
PURPOSE OF THE MISSION
The primary purpose of the mission was to investigate a
number of issues which are of continuing deep concern to all
Americans. In the veteran community, the possible adverse health
effects on veterans having been exposed to the defoliant Agent
Orange is a priority issue. We know that Agent Orange used in
Vietnam was contaminated with trace amounts of dioxin, but there is
much uncertainty that exposure to Agent Orange causes long-term
adverse health effects. Therefore, a major priority of the trip
was to meet with top officials of the government of Vietnam and
neighboring countries to learn firsthand the effects of exposure to
Agent Orange on its veterans and citizens and what is being done
about it.
There are a number of American servicemen listed as missing
in action from the Vietnam conflict. One purpose of the mission
was to find as much information as possible on these individuals.
There were discussions regarding an estimated 10,000 to
15,000 Amerasian children, many roaming the streets of Ho Chi Minh
City, who both sides agree should be allowed to emigrate to the
United States.
Many of our former allies and supporters during the Vietnam
war are still being held in so-called reeducation camps. We wanted
to find out firsthand from the officials of these governments the
facts on the issues as they view them, and to exchange views on
possible solutions or procedures which could help our Government to
bring these matters to a successful conclusion as soon as possible.

�BACKGROUND ON AGENT ORANGE
Veterans who served in the Republic of Vietnam during the
Vietnam era are deeply concerned about possible long-term health
effects of exposure to herbicides containing dioxin.
There is
scientific and medical uncertainty regarding such long-term adverse
health effects.
In Public Law 97-72, the Congress responded to that
uncertainty by authorizing priority medical care at Veterans'
Administration facilities for any disability of a veteran who may
have been so exposed (even though there is insufficient medical
evidence linking such disability with such exposure).
The Congress has further responded to that medical and
scientific uncertainty by requiring, in Public Law 96-151 and
Public Law 98-160, the conduct of thorough epidemiological studies
of the health effects experienced by veterans in connection with
exposure to herbicides containing dioxin.
There are 66
federally-sponsored research projects being conducted relating to
herbicides containing dioxin, at a cost to the Federal Government
in excess of $130 million.
The initial results of one project—an epidemiological study
conducted by the U.S. Air Force School of Aerospace Medicine on the
health status of the "Ranch Hand" veterans who carried out the
loading and aerial spraying of herbicides containing dioxin in
Vietnam and who, in the process, came into direct skin contact with
such herbicides in their most concentrated liquid form—were
released on February 24, 1984.
The results contained the
conclusion "that there is insufficient evidence to support a cause
and effect relationship between herbicide exposure and adverse
health in the Ranch Hand group at this time."
In approving H.R. 1961 (Public Law 98-542) Congress
reaffirmed its strong commitment to those citizens who have served
their country through service in the Armed Forces during a period
of war. Now the Veterans' Administration is required to conduct a
careful, thorough, systematic review of the evidence regarding
claims for compensation due to exposure to Agent Orange. Public
Law 98-542 represents the culmination of two years of work by the
Congress and is an example of the attention being given to this
subject by the Congress.

�ITINERARY

DEPARTURE AND ARRIVAL TIMES

THURSDAY, DECEMBER 6
8:00 AM
Depart Washington, D.C.
1:15 PM
Arrive Honolulu, Hawaii
FRIDAY, DECEMBER 7
8:00 AM
Depart Honolulu
(Cross International Dateline)
SATURDAY, DECEMBER 8
12:30 PM
Arrive Manila, Philippines
SUNDAY, DECEMBER 9
9:00 AM
Depart Manila
10:45 AM
Arrive Hanoi, Vietnam
TUESDAY, DECEMBER 11
9:00 AM
Depart Hanoi
10:50 AM
Arrive Ho Chi Minh City, Vietnam
WEDNESDAY, DECEMBER 12
10:30 AM
Depart Ho Chi Minh City
11:15 AM
Arrive Phnom Penh, Cambodia
THURSDAY, DECEMBER 13
8:00 AM
Depart Phnom Penh
8:45 AM
Arrive Ho Chi Minh City
9:30 AM
Depart Ho Chi Minh City
11:30 AM
Arrive Vientiane, Laos
FRIDAY, DECEMBER 14
9:00 AM
Depart Vientiane
9:50 AM
Arrive Rangoon, Burma
SATURDAY, DECEMBER 15
8:00 AM
Depart Rangoon
2:00 PM
Arrive Clark Air Base, Philippines

�SUNDAY, DECEMBER 16
8:00 AM
Depart Clark Air Base
(Cross International Dateline)
12:40 AM
Arrive Hickam AFB, Hawaii
MONDAY, DECEMBER 17
7:00 AM
Depart Hickam AFB
9:20 PM
Arrive Washington, D.C.

�VISIT TO HONOLULU
A major purpose of the delegation was to learn firsthand the
status of plans by the Veterans' Administration and Department of
the Army to renovate an existing wing at Tripler Army Medical
Center. The Veterans' Administration has a regional office in
Hawaii but no hospital. There are over 100,000 veterans in Hawaii
whose medical care is provided through an outpatient clinic.
The outpatient clinic is located in the Federal Building.
The clinic operates a 20-bed VA psychiatric ward (the Max Cleland
Ward), located at Tripler Army Medical Center.
Current plans
include the renovation of an existing inpatient wing to house a
130-bed long-term care facility.
This will be located on the
Tripler Center grounds. Veterans medical activities have a fiscal
year 1984 authorized staffing level of 100.3 full-time employees.
The outpatient clinic has been affiliated with the University of
Hawaii Patient Clinic School of Medicine since February 1975.
The delegation met with Army and Veterans' Administration
officials at Tripler Army Medical Center.
The briefing was
presented by General Tracy Strevey, Commanding General of the
center, who later provided us with a tour of the facility. The
delegation found that the center is providing high quality health
care. Dr. William J. Vandervoort, Veterans' Administration Clinic
Director, also briefed the delegation on the progress of the E-Wing
of Tripler which, upon completion, will be used to provide
long-term and psychiatric care for veterans. Dr. Vandervoort is
deeply concerned that the construction schedule may not keep on
track and there will be a delay on its final completion.
The delegation also inquired about the effectiveness of the
"Vet Center" in Honolulu and about Agent Orange. Dr. Vandervoort
described the Vet Center, which has seven Veterans' Administration
personnel, as excellent. Dr. Vandervoort said that the Veterans'
Administration clinic has conducted over 500 medical exams on
Vietnam veterans who may have been exposed to Agent Orange. Mr.
Montgomery and Mr. Hammerschmidt indicated that upon their return
to Washington, they would meet with the new Veterans'
Administration Chief Medical Director, Dr. John W. Ditzler, to make
sure the construction of the E-Wing would not fall behind schedule.

�Presently, veterans in Hawaii who require hospitalization
are referred to Tripler Army Medical Center, which serves as the
Federal tertiary medical center of the Pacific Basin.
Veterans
requiring open heart and spinal cord injury rehabilitation are
referred to VA medical centers on the mainland. The Honolulu VA
Outpatient Clinic provides a broad range of general medical and
outpatient treatments, including a mental health clinic, alcohol
rehabilitation program, day treatment center and 19 subspecialty
clinics. The need for a VA facility in Hawaii to provide inpatient
psychiatric and nursing home care has long been recognized. The
Army has requested fiscal year 1985 funds to construct new
facilities at Tripler Medical Center. The Army has agreed to make
the E-Wing Building available to the VA upon completion of the
construction of their new buildings. The E-Wing Building will be
available to the VA in late 1987 or early 1988.
Remodel E-Wing, Tripler Army Medical Center FY 1987 (Design)
$4,200,000 FY 1988 (Construction) $37,800,000
This project proposes to renovate the E-Wing Building at
Tripler Army Medical Center in order to accommodate 60 to 70
psychiatric beds and 60 nursing home care beds. Construction will
provide modern nursing units, establishment of the necessary
support services and updating of all utility systems. The Advance
Planning Fund (APF) process associated with this project will
determine the overall scope of work to be accomplished.
VA REGIONAL OFFICE — MANILA, PHILIPPINE ISLANDS
The delegation was briefed by Frank T. Tajalle, Assistant
Director, in the absence of Howard Price, Director, who was
attending a conference in Washington, D.C. Mr. Tajalle gave an
overview of the Veterans' Administration activities in the
Philippines and a brief history of the office since it was
established shortly after World War I.
The U.S. Veterans' Administration in the Philippines is
charged with the responsibility of administering the various laws
of the United States which provide benefits for veterans and their
beneficiaries residing in the Philippines. The office now has 206
employees, including nine Americans.

�Mr. Tajalle stated there are several distinct groups of
veterans in the Philippines who are potential USVA beneficiaries.
These include 20,000 old Philippine Scouts and others who served in
the regular components of the U.S. Armed Forces as far back as the
Spanish-American War; 110,000 Commonwealth Army Veterans
who saw action during World War II; 312,000 recognized guerrillas
who joined the resistance movement after the fall of Bataan and
Corregidor; and 30,000 new Philippine Scouts who were recruited
after liberation to patrol and police territories formerly occupied
by Japan. The total is 472,000, of whom an estimated 203,000 may
still be living. The widows, children and dependent parents of
veterans who died in or as a result of their military service are
also entitled to benefits from the USVA.
The largest portion of the USVA activity is directed toward
the payment of monetary benefits. Current disbursements average
$10.5 million monthly or $126 million a year.
Total USVA
disbursements to the Philippines since 1946 have exceeded $2.6
billion.
The USVA also maintains an outpatient clinic in Manila.
This clinic provides treatment and authorizes hometown treatment
and medication to veterans for service-connected conditions. By
law it is the admitting service for USVA veterans at the Veterans
Memorial Medical Center and determines legal eligibility and
medical need for hospitalization.
Mr. Tajalle emphasized there is also in the Manila Regional
Office a unique USVA activity - the U.S. Social Security Program in
the Philippines.
These beneficiaries are mostly Filipinos who
worked in the United States and earned Social Security coverage, or
their survivors.
At present there are 31,859 Social Security
beneficiaries who are receiving payments in the Philippines. These
benefits now total $6.7 million a month.
Mr. Tajalle stated that the USVA enjoys an excellent
relationship with the veterans organizations in the Philippines,
particularly with the Veterans Federation of the Philippines and
the Philippine Department of the American Legion.
Legislation is required to authorize the USVA to maintain an
office in the Philippines. The present authority terminates on
September 30, 1985.

�THE VETERANS MEMORIAL MEDICAL CENTER
Under the Rogers Act (Public Law 88-65), the United States
constructed and equipped the Veterans Memorial Hospital (VMM) at a
cost of $9,400,000. The hospital was turned over to the Philippine
government in 1955 and is now known as the Veterans Memorial
Medical Center.
Eligible veterans are hospitalized at the VMMC on a contract
per diem basis. Aside from VMMC, there are several fee-basis
hospitals throughout the country where service-connected veterans
may seek emergency medical care.
Public Law 97-72 authorized the Veterans' Administration to
contract with VMMC for the care of U.S. veterans in the
Philippines. The Veterans' Administration was also authorized to
furnish grants up to $500,000 annually for 5 years to assist the
VMMC in the replacement and upgrading of its equipment, including
the rehabilitation of its physical plant and facilities.
In
implementing Public Law 97-72, the Philippine government agreed to
assume full responsibility for the medical care and treatment of
all eligible Filipino veterans effective October 1, 1981.
The delegation asked about the future status of the regional
office and the $500,000 grant which must be reauthorized or
extended beyond fiscal year 1986. Mr. Tajalle was most emphatic
that this is a unique regional office and is especially suited to
handle claims of Filipino veterans.
One of the persistent problems that is unique to this office
is fraudulent and misrepresented claims.
This problem is
stimulated by a very low average annual income for the Philippines.
This VA regional office saves and will continue to save the U.S.
Government millions of dollars in its adjudication of claims for
benefits, which would not be the case stateside. The delegation
felt that the regional office is doing a good job and that it
should be maintained.
Mr. Tajalle also informed the delegation that the Veterans
Memorial Medical Center which is now owned and operated by the
Philippine Government is still in desperate need for equipment and
assistance.
Mr. Tajalle urged favorable consideration of an
extension of this assistance.
The delegation indicated that it
would take a look at this next year.

�10
The delegation also had the pleasure of meeting with top
veteran leaders, including American Legion National Commander
Clarence M. Bacon, who reaffirmed the American Legion support for
Congress to extend the authorization for a regional office in
Manila when it expires next year and to continue Veterans'
Administration grants for the Veterans Memorial Medical Center at
the current level of $500,000 a year.
JOINT CASUALTY RESOLUTION CENTER (JCRC)
Enroute to Indochina the group met with the Commander and
staff of the Joint Casualty Resolution Center (JCRC) in Hawaii.
JCRC officials described the history of their efforts since the
Center was established in January 1973 to assist in the recovery or
status resolution of unaccounted for Americans in Southeast Asia.
They expressed the hope that current quarterly meetings with
Vietnamese officials would lead to improved Vietnamese efforts in
locating crash sites and in providing information and remains of
missing Americans. They anticipated that the Lao agreement in
principle to permit joint excavation of a crash site near Pakse, in
which several Americans were lost, would result in a prompt and
full on-site investigation.
MANILA
The delegation stopped in Manila for the night prior to
going on to Hanoi. Ambassador Stephen Bosworth and his staff,
including Frank J. Tajalle, assistant director of the Veterans'
Administration office, briefed the members on the current situation
in the Philippines and discussed with them various aspects of
Philippine - American relations.
HANOI
In Hanoi, the delegation met with Prime Minister Pham Van
Dong, Foreign Minister Nguyen Co Thach, Vice Foreign Minister Phan
Doan Nam, and several other officials. The Congressmen stressed
the humanitarian nature of their mission and expressed hope for the
fullest possible Vietnamese cooperation on the four issues of
concern.
With respect to MIAs, it was emphasized that progress in
resolving as many cases as possible would remove an obstacle in our
bilateral relationship.
Along with peaceful cooperation and
negotiations with its neighbors in Cambodia, it could, as stated by

�11
President Reagan in July, bring about normal relations between
Vietnam and the international community. The delegation stressed
the importance of this issue to the American people, and the view
that progress on this issue could lead to progress in other areas.
The Vietnamese officials agreed with the concept of treating
the MIA issue as a separate humanitarian concern. They expressed
satisfaction with the existing framework of joint meetings to help
resolve MIA matters. They stated that Vietnam had uncovered no new
information on missing Americans, but would provide any information
which was uncovered. The officials expressed the hope that the
United States would reciprocate by assisting Vietnam in healing the
wounds of war in their country. When asked whether any Americans
whatsoever were being held prisoner in Vietnam, they replied that
no Americans are alive in captivity except Mr. William Mathers.
Mathers was apprehended last July on charges of violating
Vietnamese territorial waters. The delegation asked for the prompt
release of Mathers, and was told by the Vietnamese that officials
would check into the matter. The case is under the jurisdiction of
the Interior Ministry.
While disassociating the humanitarian issue of MIAs from
other matters, the Vietnamese did state that humanitarian concerns
are a two-way street. They mentioned that there are over a million
Vietnamese MIAs, that searching for American MIAs is expensive, and
that it is difficult for them to ask their people to search for
American MIAs when there are so many Vietnamese MIAs. The
delegation urged the Vietnamese to discuss with the U.S. Joint
Casualty Resolution Center the question of providing the necessary
equipment and materials for the excavation of aircraft crash sites.
It expressed the belief that such assistance would not be overly
expensive.
It reiterated the hope, both to Foreign Ministry
officials and to Premier Pham Van Dong, that progress on MIAs was
crucial to our long-term relationship. Congressman Montgomery
asked Premier Dong to permit MIA family members to visit Vietnam on
behalf of their missing men. The Premier said he would consider
this request.
On the issue of Amerasian children, the delegation expressed
appreciation that the numbers departing Vietnam had increased in
recent months, that Vietnam had provided a partial list of Amerasian children to the U.S. Government, and that Vietnam had agreed

�12
to let all such children and their immediate families depart for
the United States. The Congressmen asked for the total number of
Amerasian children in Vietnam and requested a list of additional
children.
They also expressed hope that the number of such
departures would continue to increase in the future.
The Vietnamese replied that their Government is compiling an
additional list of Amerasian children, that there is some
difficulty in discriminating between French and American Asian
children, and that they will provide the list when completed. They
expressed the view that the existing Orderly Departure Program
(OOP) quota for Amerasian children is too low, and that if the past
rate of departure continued, it could take 10 years for all
Amerasian children to leave Vietnam. They proposed that a new
program, separate from the OOP, be established so that all
Amerasians could depart within six months, adding that Amerasians
should not be considered refugees since they are U.S. citizens.
They said that the total number of Amerasian children is between
10,000 and 15,000, that they are American citizens, and that the
United States should take them as soon as possible. The Vietnamese
volunteered that Vietnam is not discriminating against Amerasian
children and that they receive equal treatment with Vietnamese
children.
The delegation noted that while most Amerasian children are
not considered American citizens, the United States is prepared to
take them all in an orderly manner as soon as possible. It again
expressed appreciation for the increased rate of departures.
With respect to Vietnamese in "reeducation camps" who were
associated with the United States or the government or military of
the former Republic of Vietnam, the delegation emphasized the
importance of a prompt release. It asked for a list of prisoners
and an estimate of their total number. The Congressmen noted that
Vietnamese leaders have stated their willingness to release all
such prisoners and that Secretary Shultz has said that the United
States will accept them.
The delegation expressed concern that their departure be
regulated so as to avoid problems such as those associated with
Castro's release of Cuban prisoners a few years ago. It was
suggested that both sides might agree to the release of 1,000
prisoners as an initial step in a program for the release of all
such persons.

�13
The Vietnamese responded by labeling these prisoners as
"criminals," stating they had opposed and fought against their
government and were therefore guilty of breaking Vietnamese law.
Such "criminals," they said, could not be released under a program
designed for refugees. They further stated that the total number
of such prisoners was less than one percent of the 1.5 million
South Vietnamese they said opposed them during the war. They
described these persons as the most intransigent and most
bellicose, and expressed a strong fear that the prisoners, if
released, would independently or with the support of the United
States, conduct anti-Vietnamese activity both in America and
Indochina. They asked for a commitment or a guarantee that such
activity would not take place, stating that only by negotiating
such an agreement would the release be possible.
The delegation also asked to visit "reeducation camps." The
Vietnamese declined to grant the request to visit a "reeducation
camp," saying that their representatives at the United Nations are
restricted to within 25 miles of the city - clearly implying
linkage to American travel in Vietnam.
The delegation reiterated its expectation that the Vietnamese prisoners would soon be released. It urged that the
definition of these prisoners as "refugees" or "criminals" not be a
stumbling block to their release. It pointed out that there are
U.S. laws which prohibit organized private groups from hostile
activities in foreign countries and that the released prisoners
would be interested only in building a new life and supporting
their families in the United States. It is the opinion of the
delegation that Vietnamese travel in the United States, outside the
25 mile limit in New York, be considered on a case-by-case basis.
In a separate meeting. Congressman Bonior asked Vietnamese
officials in Hanoi to permit the departure of two Vietnamese who
had relatives in his district. The officials promised to raise the
matter with local Vietnamese authorities.
The delegation discussed the concern of many on the possible
long term health effects on veterans of U.S. Armed Forces who
served in Vietnam. In this regard, the delegation referred to a
number of studies being conducted in the U.S. to determine if there
have been adverse health effects on persons exposed to Agent Orange
or other chemicals during the period 1961-1972. The Vietnamese
responded by referring to the International Symposium on Herbicides
and Defoliants: The Long Term Effects on Man and Nature, which was

�14
held in 1983 in Ho Chi Minh City. The Symposium drew participants
from 21 countries including a number of American scientists and
researchers.
Twenty-nine reports were filed as well as 72
scientific papers. The conclusion of the Symposium was that
exposure to chemicals (Agent Orange) does cause health problems for
humans.
The delegation asked if the Vietnamese soldiers who were
exposed to Agent Orange had suffered adverse health effects and
whether the Vietnamese have any statistics or reliable information
regarding the matter. The Vietnamese responded that there had been
a strong increase in the number of females coming to their
hospitals who had health problems traceable to being exposed to
Agent Orange when they were quite young. The Vietnamese had no
records or information on their own soldiers. It was indicated
that the Vietnamese do not have the resources or scientific
personnel to conduct such a study. The Vietnamese, however, were
open to suggestions for independent studies by scientists from the
international community.
The delegation pointed out that there have been many changes
in Vietnam since the defoliant was sprayed. Therefore, time is of
the essence in conducting such a study. The Vietnamese, in this
regard, indicated there will be follow-ups to the 1983 symposium
but did not indicate when.
Besides the foregoing issues of concern to the delegation,
the Vietnamese officials raised several political issues of concern
to them. First, they were clearly interested in increased dialogue
with the U.S. Government, often stating that diplomatic relations
would facilitate resolution of outstanding differences as well as
help assure peace and stability in Southeast Asia. They felt some
progress on bilateral issues could be made in the absence of
normalization, but that such progress would, of necessity, be
limited. Second, while maintaining that most of the four issues
raised by the delegation should be and are humanitarian and not
political issues, they stressed their expectation that humanitarian
assistance be a "two-way street." While not specifying the form
American humanitarian assistance would take, they emphasized that
Vietnam is a poor country and needs assistance in many areas.
Third, they criticized China in the strongest possible terms, even
to the point of saying China used the war in Vietnam as a means to
increase its influence in Southeast Asia.
In this context, they
quoted a statement attributed to General William Westmoreland that
China had been prepared to fight the war in Vietnam to the last

�15
Vietnamese. Beginning in 1975, they said, China and the United
States cut a deal by which China would pressure Vietnam. During
the past year, in their opinion, American collusion with China
increased significantly.
Fourth, the Vietnamese stated the
position that their troops could be withdrawn from Cambodia
provided support for Pol Pot was removed and an agreement was
reached on a regional arrangement for Southeast Asia involving both
the ASEAN and Indochina countries. In this context, as well as in
the context of joining ASEAN, the Vietnamese stated that they
realized Vietnam could not ask the United States to abandon its
bases in the Philippines, but did require assurances that the bases
would not be used against Vietnam.
The delegation took note of these Vietnamese concerns. It
expressed appreciation of Vietnamese agreement in treating the
issues of MIAs, Agent Orange, and Amerasians as separate
humanitarian concerns and reiterated the hope and expectation that
progress would be made in all four areas raised by the delegation.
Congressman Montgomery stressed the need for Vietnam to withdraw
its forces from Cambodia and agreed that Pol Pot should never
return to power. The delegation agreed that the United States and
Vietnam have differences of opinion over many issues, but that
increased dialogue by both executive and legislative groups would
improve mutual understanding and resolve as many differences as
possible.
HO CHI MINH CITY
In Ho Chi Minn City (Saigon) the delegation met with
Director of External Affairs Vu Hac Bong, and with Vice Chairman of
the City People's Committee, Le Quang Chanh. The officials opened
with considerable detail, emphasizing economic development in the
city.
They said, inter alia, that there are 150,000 handicraft
workers now operating, and that construction of a power plant and
grid system is underway which will provide the city an additional
400,000 kw of power. They claimed an annual increase in industrial
production of 16-20 percent during the 1980-1984 period. They said
there remained a large number (80-90,000) of unemployed persons,
which was partially due to a high birth rate. The present birth
rate was put at 1.9 percent, down from 2.8 percent in 1975. The
objective for 1985 is a 1.5 percent birth rate, which Vietnamese
officials hope to achieve through a family planning public
information program, as well as promotion of abortions, which are
free of charge at local hospitals.

�16
Regarding the Chinese population of metropolitan Ho Chi Minn
City, the Vietnamese said their number had dropped from 540,000 in
1978 to 420,000 in 1984. Many had departed, they said, because the
Peoples Republic of China had stirred them up in support of Pol
Pot. Some 165,000 ethnic Chinese in Vietnam left for China in
1978, some by Chinese ships and some illegally. The remaining
overseas Chinese, they said, are loyal to Vietnam.
The Vietnamese also indicated that there would be a major
trial before the Supreme Court in Ho Chi Minh City beginning
December 14, 1984, which would involve the prosecution of a few
rich and former rich Vietnamese, as well as overseas Chinese.
(Local rumor held that over 100 persons had already been arrested
in connection with the trial.) With respect to punishment attending this or other crimes, the officials said policy indicated the
punishment should match the crime. Capital punishment by shooting
is permissible.
The delegation requested information on the status of
Amerasians in southern Vietnam and was told that at the outset of
the OOP program there were an estimated 15,000 Amerasian children.
Since that time some 4,300 persons, including both Amerasian
children and their immediate family members, were said to have left
Vietnam for the United States under the OOP.
The officials
repeated the statement made in Hanoi that Vietnam was working on a
new list. Acccording to these officials, for every one Amerasian
child there is an average of two other family members. If these
numbers are correct the delegation estimates that the total number
of departees under this category could exceed 40,000.
When asked if he had any information on American MIAs, Mr.
Chanh responded in the negative. He also indicated, in response to
a query by Mr. Montgomery, that he knows of no Americans residing
in Ho Chi Minh City.
In Ho Chi Minh City the delegation also met with a visiting
group from the Vietnam Veterans of America (WA), a national
veterans organization with wide ranging membership. The delegation
was told that the WA had sent two persons to Can Tho in an
unsuccessful attempt to visit and obtain the release of Mr. William
Mathers. Another group of WA members had the opportunity to visit
a crash site about 30 miles outside of Hanoi. Traveling with the
WA was Dr. Arnold Schecter from Binghamton, New York, who is
engaged in a study of Agent Orange and its effects on the
Vietnamese. Dr. Schecter had conducted analyses on 30 specimens of

�17
persons who may have been exposed to Agent Orange, and was
attempting to determine whether a significant difference existed
between these and unexposed persons in northern Vietnam.
PHNOM PENH
The delegation was the largest Congressional group to visit
Cambodia in 10 years.
The mission was intended to open a
productive dialogue on problem areas of both countries. During
their one day and overnight stay in Phnom Penh, the Members visited
the Tuol Sleng prison where Pol Pot leader of the Khmer Rouge,
tortured and murdered thousands of Cambodians as well as some
foreign nationals. The group visited a mass grave outside the city
where 9,000 victims had been buried. Many of these persons had
been lined up and blindfolded, with hands tied behind their backs.
They were then struck a heavy blow over the head and dumped into
mass pits.
The delegation unanimously condemns the atrocities which
were perpetrated by the Pol Pot regime. The mass murder, between
1975 and 1979, of an estimated 3 million men, women, and children,
including the entire class of professional people, is a holocaust
in every sense of the word. The delegation stresses the need for
the withdrawal of all foreign support for Pol Pot, as well as the
removal of Vietnamese troops from Cambodia.
In addition, it
expresses the hope that, in the future, an independent government
of the people will be allowed to assume power, and that this
government will be able to conduct relations with the other
countries of Southeast Asia on a basis of peace and friendship.
Mr. Montgomery expressed the hope that the United States will be
very careful not to support Pol Pot in any way, including votes at
the United Nations.
He notes that the delegation is "definitely
against" a return to power by Pol Pot.
While in Cambodia the delegation met with Foreign Minister
Hun Sen, as well as with several other officials. The Foreign
Minister said that there were only 70 people alive when his men
first reached Phnom Penh. He asked the delegation to see for
itself the atrocities committed by Pol Pot. Besides the millions
murdered by Pol Pot, the Foreign Minister stated there are today
200,000 orphans in Cambodia as a result of Khmer Rouge killings.
He strongly denied that Cambodia is a Vietnamese colony, stating
that his is a regime not fabricated in Hanoi.

�18
The Foreign Minister criticized what he called Chinese American - Thai collusions against Cambodia by their support for
Pol Pot and Son Sann, the leader of the anti-Communist guerrilla
force. He stated that although the war had ended 10 years ago, the
United States has not stopped its war against Cambodia. In his
opinion, the Western media is waging a propaganda war against
Cambodia. To resolve the problem, he suggested an agreement
among the ASEAN states, Indochina, India and the five permanent
members of the United Nations Security Council, to form an
internationally supervised security zone along the Thai border. He
further requested the United States to separate itself from Pol
Pot, whom he said must be eliminated both politically and
militarily. He urged the United States to ask Sihanouk and Son
Sann to disassociate themselves from Pol Pot and to join his
government. He expressed a sense of urgency in this request and
said direct talks between the United States and Cambodia were
needed to help resolve the problem. The alternative, he said, is
for Cambodia to solve the problem on its own. He said that under
this option Pol Pot could be defeated and Vietnamese troops
withdrawn in less than five years.
The sooner Pol Pot is
eliminated, he said, the sooner foreign troops could leave
Cambodian soil.
With respect to MIAs, the Foreign Minister said he understands that there are 82 Americans missing in Cambodia. Despite
the fact he categorized these persons as victims of imperialist
American policies, he stressed that Cambodia would make efforts to
search for MIAs on a humanitarian basis. He claimed to know
personally of the general location of some crash sites but could
not be certain they could be located because of difficult terrain
and jungle. He said that many people who might remember the war
and know of MIAs were killed by Pol Pot.
The Foreign Minister concluded his remarks by stating that
he was finished with his preaching on the situation. He said the
task at hand was to reconstruct the country. The delegation stated
that it would inform the Department of State of the concerns of the
Cambodian officials.
VIENTIANE
In Laos the Congressmen held separate meetings with Vice
Foreign Minister Soubanh Srithirath and Acting Foreign Minister
Khamphai Boupha.
In addition, they met with numerous other
officials at a dinner hosted by Theresa Tull, Charge' d'Affaires at

�19
the American Embassy in Vientiane. Ms. Tull and her staff were
most helpful both with the delegation visit and in stimulating
overall improved relations between Laos and the United States. The
Embassy was particularly instrumental in facilitating the provision
of 5,000 tons of rice in response to a shortfall in southern Laos
and has helped with the provision of emergency medical supplies to
Laos.
The delegation stressed the importance of continued Lao
progress in resolving as many cases of missing Americans as
possible. The Lao officials stated that their country has been
making considerable efforts in this regard and that whatever
remains found have been given to the United States. They said that
a joint Lao-American team would be able to visit the crash site of
a downed AC 130 aircraft near Pakse as soon as the site is ready,
noting that the terrain in the area is still too muddy from the
recent rain season. The Lao officials also claimed to be making
considerable efforts to find remains in other areas. They stressed
that the issue of missing Americans is being treated as a
humanitarian one. Noting that the Lao people also suffered heavily
during the war, the officials expressed the hope that American
assistance would be forthcoming as a matter of humanitarian
concern, adding that American humanitarian aid would also help
convince the Lao people of the propriety of searching for American
MIAs. They further stated that Laos has 10,000 MIAs of its own.
Because of the dense forest and small population it is difficult to
find MIAs and even downed planes or remnants. The officials stated
that, despite the difficulties, Laos would try to do its best to
find them. They noted that the Lao people do this despite American
bombing during the war because they are Buddhists and do not wish
to take revenge on anyone.
The delegation expressed appreciation for the Lao efforts on
MIAs. It noted recent American assistance of rice and medicine, as
well as recent American votes in international financial
institutions favoring loans to Laos. They again expressed the hope
that further progress would be possible on MIAs. The Lao officials
responded by alluding to other recent improvements in Lao-American
relations, noting that the United States remained neutral when some
Lao villages were "attacked" by Thailand, and that there are no
more American-backed anti-Lao military activities, as in the past.
The delegation expressed the hope for continued progress on MIAs
and other matters and reiterated its support for the work of both
countries' embassies.

�20
Congressman Bonior raised the issue of MIA Robert Tucci, who
was shot down over Laos in January 1979. Lao officials expressed
an interest in the matter and a follow-up is expected.
RANGOON
The delegation had the opportunity to stop in Burma before
returning to the United States. Ambassador Dan O'Donohue and his
staff briefed the Members on the situation in Burma and on its
relations with the United States. The delegation met with Foreign
Minister U Chit Hlaing, who discussed general foreign policy
questions and Burmese efforts to eliminate production and
trafficking in opium. The Foreign Minister said Burma considers
this a top priority and is doing its best in combatting the opium
trade. During a dinner hosted by Ambassador O'Donohue, the
delegation had the opportunity for discussion with a wide variety
of government officials and businesss and social leaders.

�21
A full list of officials met by the delegation in Indochina
is as follows:
VIETNAM
Prime Minister - Pham Van Dong
Foreign Minister - Nguyen Co Thach
Vice Foreign Minister - Phan Doan Nam
Vice Chairman of the National Assembly - Phan Anh
Ministry of Foreign Affairs: MIA Commission Director Cu Dinh Ba
Ministry of Foreign Affairs: MIA Commission Member - Ngo Hoan
Ministry of Foreign Affairs: MIA Commission Member Vu Bac My
Ministry of Foreign Affairs: Protocol - Doan Phi Luong
Ministry of Foreign Affairs: Dung Van Ngoc
Director of External Affairs, Ho Chi Minh City - Vu Mac Bong
Vice Chairman of the City People's Committee - Le Quang Chanh
Head of Commission on Agent Orange Ministry of Health Le Cao Dai
British Embassy: Ambassador Michael Pike
France: Ambassador Yvan Bastouil
Denmark: Charge d'Affaires Ulrik Helweg-Larsen
Italy: Ambassador Lodovicio Mazetti
Netherlands: Charge d'Affaires Hein C.R.M. Princen

�22
LAOS
Acting Foreign Minister - Khamphai Boupha
Vice Foreign Minister - Soubanh Srithirath
CAMBODIA
Foreign Minister - Hun Sen
Director of Tuol Sleng prison - Ing Pech
Ms. Peou Lyda, Member, General Assembly and Sihanouk's
cousin.
Ms. Phlek Phirun, Secretary General of General Assembly
Mr. My Samedy, Member of General Assembly

BURMA
Foreign Minister - U Chit Hlaing

O

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                    <text>item D Number

05740

a

Author
Corporate Author
Report/Article Title Compilation of Information on the Federal Government
and Agent Orange

Journal/Book Title
Year

000

°

Month/Day
Color

D

Number of Images

°

DBSOrlptOn NOtBS

13 sections

. including a history of the AOWG, studies of note,
and Congressional committees.

Tuesday, March 26, 2002

Page 5740 of 5743

�I N D E X

Section I

Executive Summary

Section II

Statement of President Reagan

Section III

Agent Orange
A. Fact Sheet
B. Expenditures (circle charts)

Section IV

Use of Agent Orange in Vietnam
A. White House Primer on Agent Orange - 10/27/83

Section V

Background of the Agent Orange Working Group
A. White House memo - 12/11/79
B. White House memo 07/17/81
C. White House memo 08/21/81
D. Secretary Margaret Heckler's Press
Release - 6/6/83
E. Charter

Section VI

Agent Orange Working Group Organization
A. Membership and staff

Section VII Advisory Committee on Special Studies
A. White House memos - 09/16/80
B.

Charter

C. Members
Section VIII Congressionally Authorized Epidemiological Study
Section IX

Scientific Studies of Note
A. CDC Birth Defects
B. International Soft Tissue Sarcoma Studies
C. National Cancer Institute Ongoing Studies
D. Air Force Ranch Hand Studies
E. Proposed Studies

Section X

Science Panel Report
A. Executive Summary
B. Brief History
C.

D.

Rationale for Research Efforts from

a. What is known
b. What is not known
Federal Research 1981-1987
a. Effects in animals
b. Effects in humans
c. Others

E.

Evaluation

F.

Future Directions

1980

�Index (cont'd)
Section XI

Additional Information
A. Exposure Opportunity Index
B. Agent Orange Litigation
C. VA Advisory Committee created by P.L. 98-5A2

Section XII Congressional Veterans Committees
A. Senate Committee
B. House Committee
Section XIII Appendix - Literature Review

�EXECUTIVE SUMMARY

The Agent Orange Issue
A legacy of the Vietnam conflict is the concern of many Vietnam
veterans that they may be at risk of a spectrum of adverse health
effects as a result of their service in Vietnam. These concerns
focus largely on Agent Orange, a herbicide used for defoliating
areas of enemy troop concentration and staging.
History
In late 1979, the White House established an Interagency Work
Group to bring together knowledgeable government scientists to
oversee the research, develop areas where scientific study is
needed, and report the results as soon as they become available to
the Congress and the public. On August 21, 1981, President Reagan
established an Agent Orange Working Group (AOWG) as part of the
Cabinet Council on Human Resources, elevating and enlarging the
scope of the prior group. Secretary Margaret Heckler, as Chair
pro tempore of this Cabinet Council, named John (Jack) Svahn, at
that time Under Secretary, to chair the AOWG and in a Press
Release dated June 6, 1983 stated her well known concern for
veterans and her particular concern in the Agent Orange question
"By designating the second highest official of my department as
Chairman, I am reaffirming this administration's commitment to the
prompt and scientifically responsible resolution of the health
concerns of Vietnam veterans who were exposed to Agent Orange and
other environmental factors during their service to their country
in that conflict. His leadership of this vital working group will
help us get the answers we need " the Secretary said.
Subsequent chairpersons have been Assistant Secretary for Health,
Dr. Edward Brandt September 1983 - December 1984, Under Secretary
Charles N. Baker, December 1984 * August 1985.
On April 11, 1985 the eight Cabinet Councils, including Human
Resources were combined into two, the Council on Economic Policy
Council and the Council on Domestic Policy to which the AOWG now
reports.
Organization
The Agent Orange Working Group is under the leadership of the
Department of Health and Human Services and includes scientific,
legal and policy representatives from that Department, the
Departments of Defense and State, the Veterans Administration, the
Environmental Protection Agency, the Department of Agriculture,
the Occupational Safety and Health Administration of the Labor
Department, the White House Offices of Policy Development and of

�the Science and Technology Policy, Office of Management and
Budget, Council of Economic Advisors, ACTION, and Congress' Office
of Technology Assessment (observer status).
The Science
The issue of possible adverse health effects in humans as a
consequence of exposure to Agent Orange in Vietnam has attracted
and maintained the attention of the nation for nearly a decade.
For the past four years, the AOWG has been evaluating the
direction and extent of the government's scientific research in
Agent Orange and related issues. When the AOWG was formed in
1981, it was clear from animal studies and the limited human
studies that the toxic contaminant of Agent Orange (TCDD) has the
potential to cause a broad range of deleterious effects. The
extent to which these effects were likely to appear in humans
exposed to Agent Orange in Vietnam, however, was unknown.
Between 1981 and 1987, AOWG member agencies will have expended
$150
million in Agent Orange-related research with over one
hundred and fifty (150) studies. The majority of these funds has
been directed at closing the largest gap in our knowledge on Agent
Orange: the effects of Agent Orange on humans.
Ten major
epidemiological studies scheduled for completion by 1990, and five
ongoing health surveillance projects should provide information on
whether exposure to Agent Orange has affected the health of
Vietnam veterans and for framing hypotheses which can be tested in
follow*up studies if necessary. Additional resources have been
expended to better characterize
known toxic properties of
2,3 ,7 ,8*TCDD and Agent Orange.
The Public
The Agent Orange Working Group has received support from veterans
organizations and members of Congress and its recommendations have
been accorded significant weight.
The President
In a July 17, 1981 meeting with veterans leaders, President Reagan
indicated that the Administration took seriously the concerns of
Vietnam veterans and their families about their health status as a
result of their actual or presumed exposure to Agent Orange in
Vietnam and was firmly committed to con* tinuing and according the
highest priority to the current scientific research studies now
being conducted and planned by Federal agencies.

�-3*

The President cautioned that the scientific research may never
yield definitive answers to the question of whether Agent Orange
i»» or any other single factor ^* has adversely affected the health
of an individual veteran but that we can learn whether Vietnam
veterans as a group are suffering any chronic health effects not
present in a comparable population that did not serve in Vietnam.
The Results
The results of the scientific research will prove useful in
helping to formulate sound public policy regarding health care and
compensation for Vietnam veterans. Some studies are completed and
are inconclusive; the major Epidemiologic studies underway by the
Centers for Disease Control, mandated by Congress is the most
comprehensive but will not be completed until late 1989.
Based on the growing body of information in hand, the worst case
scenarios envisioned by some as a consequence of exposure to Agent
Orange are not being realized.
Populations known or possibly
exposed to Agent Orange which are being studied have not so far
exhibited increased incidences of cancer, or death from other
causes, or abnormally high rates of birth defects in their
offspring. This optimism is tempered by the knowledge that other,
less*well characterized effects of concern may by associated with
2,3,7.8TTCDD ( e . g . , immunotoxicity). Some effects (e.g., cancer)
may not become manifest for several more years, due to a longer
latency period.
The consensus of the Science Panel is that initiation of any new,
major epidemiological study should await and be built upon the
results of studies already underway.
A large number of
ongoing research projects
designed to
characterize the toxicity and mechanisms of action of 2,3,7,8-TCDD
in laboratory animals will also help to identify possible adverse
human health effects and will assist in the interpretation of
epidemiologic study results.

�AGENT O R A N G E D I O X I N EXPENDITURE
AGENCY EXPENDITURES BY STUDY TYPE
$152,455,000 TOTAL EXPENDITURES

ANIMAL (12.8%)

ANALYT (1 .6%)
ENVIR (6.2%)
UT (1 .2%)

STUDY TYPE

EXPENDITURES

HUMAN
ANIMAL
ENVIRONMENT
ANALYTICAL
LITERATURE
TOTAL

$119,293,500
19,522,000
9,382,000
2,368,000
1,890,000
$152,455,000
,X

HUMAN (78.2%)

�AGENT O R A N G E D I O X IN EXPENDITURES
$152,455,000

TOTAL COST

IJSDA (Q.4%) $594,000
N

DOD (22.O%)$33,605,000

\

Jk

VA (53.3%)
$81,286,000

EPA (9.5%) $ 1 4 , 4 6 7 , 0 0 0

y
X X HHS (14.8%)$22,503,000

�HHS A.O./DIOXIN EXPENDITURES
$22,50.3,000 TOTAL EXPENDITURES

ANALYT (2.5%) $556,000

HUMAN (41 .1%)
$9,244,000

ANIMAL (56.5%)
$12,703,000

�DOD A.O./DIOXIM EXPENDITURES
$33,605,500 TOTZVL EXPENDITURES

ANIMAL (0.9%) $288,000

HUMAN (99.1%)

$33,317,500

�USDA A.O./DIOXIN EXPENDITURES
$594,000 TOTAL EXPENDITURES

LIT (1O.8%)
$64,000

HUMAN (89.2%)
$530,000

�EPA A.O./DIOXIN EXPENDITURES
$14,467,000 TOTAL EXPENDITURES

$2,146,000
ANIMAL (14.8%)

LIT (7.3%)
$1,052,000

ANALYT (12.5%)
$1,812,000

HUMAN (G.5%)
$75,000

ENVIR (64.9%)
$9,382,000

�V.A. A.O./DIOXIN EXPENDITUREIS
$81 .286.OOO TOTAL EXPENDITURES

$774,000

$4,385,000

\

r

( 4 O ) $76,127,OOU
9 . %

�HHS
U.S. DEPARTMENT Of HEALTH AND HUMAN SERVICES

FOR IMMEDIATE RELEASE
DRAFT

Contact:
Telephone

HHS Secretary Margaret M. Heckler today forwarded to the Cabinet
Council on Domestic Policy an updated report from the Agent Orange Working
Group suggesting no new major studies are needed on the subject until
evaluations have been done on those already completed or continuing through
1987 at a cost of more than $150 million.

Terming results of the studies thus far as "reassuring," Secretary
Heckler said, "Completed studies show no increase in birth defects among
children of Vietnam veterans or higher mortality due to Agent Orange
exposure.
"However, careful and intensive epidemiological studies in other areas
are going on and we must await their findings."
The advisory science panel formed by the AOWG says in the report that
the numerous research projects completed or already underway are the ones
it considers both essential and feasible.
It recommends "that any additional major research efforts involving
Vietnam veterans' exposure to Agent Orange should await evaluation of the
results of studies which are currently in progress."
Created in 1979 as a small interagency work group, the AOWG was
enlarged and elevated to cabinet council status in July 1981 by President
Reagan to show his concern over the fears of Vietnam veterans that they may
suffer ill effects from exposure to phenoxy acid herbicides, principally
Agent Orange. The herbicides were sprayed to defoliate dense jungle areas
from which enemy troops operated.
- MORE -

�- 2-

Veterans groups have maintained they were endangered by an increase in
cancers and liver disorders, and expressed fears that their children might
be born with defects. They called for scientific research, compensation
and treatment.
In forwarding the new AOWG report to the Cabinet Council on Domestic
Policy, Secretary Heckler, a long-time advocate of veterans' rights, said,
"The

president's promise to support any research necessary to learn whether

Vietnam veterans as a group are suffering any chronic health effects not
i

present in a comparable population that did not serve in Vietnam, will be
kept."
Twelve federal departments or independent agencies are represented on
the Agent Orange Working Group. It sets priorities, coordinates and
overses federal research into the possibility of long-term adverse health
effects resulting from exposure to the herbicides used in Vietnam.
The science panel's report says HHS, the departments of Defense and
Agriculture; the Environmental Protection Agency; and the Veterans
Administration are conducting ongoing studies with the other AOWG members
providing advice and guidance.
The others are the Department of State; Department of Labor; ACTION;
the White House Offices of Policy Development, Science and Technology
Policy; Office of Management and Budget; Council of Economic Advisors; and
the Congressional Office of Technology Assessment, the latter as an
observer.
####

�STATEMENT OF PRESIDENT REAGAN
JULY 17, 1981

"One of the most unfortunate legacies of the Vietnam conflict
is the continuing concern of many Vietnam veterans that they
are, or may be, at increased risk of a broad spectrum of
adverse health effects as a result of their service in
Vietnam. These concerns have largely focused on Agent Orange,
a herbicide used for defoliating areas of enemy ground troop
concentrations and staging. Agent Orange was made by combining
two herbicides that were in widespread use in forestry and
agriculture.
Unfortunately, despite much discussion in the media and among
scientists, there are still few definitive answers to the
difficult scientific issues involved. Indeed, we may never be
able to determine with certainty whether Agent Orange — or any
other single factor •*- has adversely affected the health of an
individual veteran. The scientists working on this problem are
hopeful, however, that we can learn whether Vietnam veterans as
a group are suffering any chronic health effects not present in
a comparable population that did not serve in Vietnam. In
addition, several studies —» including an epidemiological study
of the Air Force Personnel who sprayed Agent Orange *•*• are
directly examining the Agent Orange issue. The results of
these and other studies, including a congressionally mandated
VA epidemiological study of the health status of Vietnam
veterans, should be extremely useful in helping to formulate
sound public policy regarding health care and compensation for
Vietnam veterans.
I believe that .the Federal Government has made significant
progress in the past year in organizing and beginning a serious
scientific inquiry into the Agent Orange issue. Much, however,
remains to be done and I share the deep and abiding concern of
Vietnam veterans about their health and that of their
children.
I am committed to assuring that the important
scientific research now under way and being planned under the
overall guidance
and coordination of the White House
Inter agency Work Group continue to completion in an efficient,
expeditious
manner,
consistent
with
sound
scientific
principles. Accordingly, I am hereby reaffirming the mandate
of the Work Group and making its work a major priority of my
Administration."

�Agent Orange
The terra "Agent Orange" is derived from the orange color code
painted on the barrels of herbicide shipped to Vietnam. Other
herbicides used in Vietnam carried various other color codes
depending on the nature of the herbicide.
Agent Orange was a 50/50 mixture of the herbicide 2,4,-D and
2,4,5*7.
The product was provided on contract with the
Department of Defense by a number of chemical companies.
A by-product created in extremely small amounts during the
manufacture of 2,4,5~T was the chemical, dioxin. The average
contamination amount of dioxin was, according to the Veterans
Administration, two parts per million.
Dioxin has caused lethal and toxicological effects in some
laboratory animals at lower levels than any other man-made
chemical.
However, both the lethal dose levels and the
toxicological effects vary considerably among different animal
species. The toxicological effect upon humans remains under
study and additional work must be done before an authorized
view of the risks can be made.

�A a n j, s

Nv w n H

ana,

�CABINET COUNCIL ON DOMESTIC POLICY
AGENT ORANGE WORKING GROUP
FEDERALLY SPONSORED HUMAN STUDIES RELATED TO AGENT ORANGE
TYPE OF STUDY

AGENCY

STUDY TITLE

Mortality

ReproMorbidity Cancer duction Analytical

STATUS

Estimated
Completed Ongoing Completion Date

DEPARTMENT OF HEALTH AND
HUMAN SERVICES

NIOSH Investigation of
Leukemia Cluster in
Madison County, Kentucky
Allegedly Associated with
Pentachlorophenol Treated
Ammunition Boxes

Published NTIS
1984

NIOSH Dioxin Registry

X

Late 1985

NIOSH Soft Tissue Sarcome
Investigation

X

Published
Scan. J. Work
Environ Health
1984

NIOSH NJ/Missouri plant
worker and worker's spouse
reproductive outcome study
Reproductive outcomes in
persons possibly exposed
to 2,3,7,8 RDP
Measurement of TCDD levels
in adipose tissue from potentially exposed persons in
Missouri.

X
(begins
1985)

�Page 2
FEDERALLY SPONSORED HUMAN STUDIES RELATED TO AGENT ORANGE
TYPE OF STUDY

AGENCY

STUDY TITLE

Mortality

ReproMorbidity Cancer duction Analytical

STATUS

Completed Ongoing

Estimated
Completion Date

DEPARTMENT OF HEALTH
AND HUMAN SERVICES cont'd

NIEHS Establishment and
Maintenance of an International Register of Persons
Exposed to Phenoxy Acid
Herbicides and Contaminants

X

NIEHS Effects on Intestinal
Cells UNC-CU Grad student

X

Indefinite

X
1984
X
1984

Lipid Assimilation NRSA
Membrane/LP Receptor NRSA

X

X

1986

NIEHS Pesticides and
transport across bilayer
Lipid membranes (toxicology)

X

X

1987

NIEHS Occupational and
Environmental Health Center
Grant (toxicology)

X

1987

NIEHS - Dioxin Environmental
Health Sciences Center Grant
Clinical Studies

X

1987

NIEHS Dioxin Mechanism(s)
for toxicity of chlorinated
dibenzodioxins (toxicology)

X

1987

�Page 3

FEDERALLY SPONSORED HIMAN STUDIES RELATED TO AGENT ORANGE
TYPE OP STUDY

STUDY TITLE

Mortality

Repro*
Morbidity Cancer duction

Analytical

Estimated
Completed Ongoing Completion Date

NIEHS Dioxtn Environmental
pollutants and toxicology
of the liver

X

X

1986

NIEHS Dioxin XenobiotLc
induction of pleiotropic
responses in liver

X

X

1986

NIEHS Dioxin molecular
toxicology of TODD

X

X

1986

NIEHS Dioxin chlorinated
dibenzoisp-dioxins;
mechanisms of toxicity

X

X

1987

NIEHS Dioxin » Toxic
halogenated wastes: In
vitro bioassay development

X

X

1986

NIEHS Dioxin * Atomic
emission spectrometry for
dioxin trace anlaysis
(detection)

X

X

1986

NCI Study of Mortality Among
Pesticide Applicators from
Florida

Publications in
Press

NCI Case Control Study of
Lymphoma and Soft Tissue Sarcoma

Indefinite

�Page 4
FEDERALLY SPONSORED HUMAN STUDIES RELATED TO AGENT ORANGE
AGENCY

STLDY TITLE

TYPE

Mortality

OF b 1 UDY

Repro*
Morbidity Cancer duction

CDC Birth Defects and
Military Service in
Vietnam Study

STATUS

Analytical

Estimated
Completed Ongoing Completion Date
X

Published
Aug. 1984

*CDC Epidemiologic Study of
Ground Troops Exposed to
Agent Orange during the
Vietnam Conflict

Sept 1989

CDC Study for Body Burden
for Dioxin in the General
Population

Late 1988

VETERANS ADMINISTRATION

Vietnam Veteran Mortality
Studies

December 1985

Vietnam Veteran Identical
TWin Studies

Under Review
by OTA and
AOWG

VA/AFIP Case Control Study of
Soft Tissue Sarcoma

*Mandated to the VA by P.L. 9&amp;S-151 Sec. 307.
1983.

X

July 1986

Transferred from VA to CDCunder Interagency Agreement January 14,

�Page 5
FEDERALLY SPONSORED HUMAN STUDIES RELATED TO AGENT GRANGE
Or

AGEUOf

STUDY TITLE

Mortality

b l U U Y

Repro*Morbidity Cancer diction Analytical

STAIUS

Estimated
Completed Ongoing Completion Date

VETERANS ADMINISTRATION cont'd
Survey of Patient Treat-!ment File for Vietnam
Veteran In-Patient Care

X

Sarcoma Study in Patient
Treatment File
Agent Orange Registry
Examinations

X

December 1985

X

X

Review of Soft Tissue

Initial 1983
Survey

Indefinite

X

TCDD in Body Fat of
Vietnam Veterans and
Other Man

Published

X

Retrospective Study of
Dioxins and Furans in
Adipose Tissue of
Vietnam-Era Veterans

18
96

DEPARTMENT OF DEFENSE
Epidemiologic Investiga'tion of Health Effects
in Air Force Personnel
Following Exposure to
Herbicide Orange (Air
Force Health Study)
Armed Forces Institute
of Pathology Agent Orange
Registry of Vietnam Veteran
Biopsy Tissues

X

Baseline 1983
Complete 1999

Indefinite

�Page 6
FEDERALLY SPONSORED WMAN STIDIES REIATED TO AGENT ORAN&lt;£
AGENCY

STUDY TITLE

TYPE OF

Mortality

STUDY

Repro*
Morbidity Cancer duction Analytical

STATUS

Estimated
Completed Ongoing Completion Date

ENVROEMENTAL PROTECTIDN
AGENCY

Report of Assessment of a
Field Investigation of
Six^Year Spontaneous Abonr
tion Rates in Three Oregon
Areas of Relation to Forest
2,4,5*T Spray Practices

(Published)

National Pesticide Monitor*
ing Project of Human
Adipose Tissue

Indefinite
(Annual
Reports)

DEPARTMENT OF AGRICULTURE

A Case Control Study of
the Relationship Between
Exposure to 2,4*D and
Spontaneous Abortions in
Humans
Exposure Measurements of
Mixers, Loaders and Appli^
cators of 2,4*D on Wheat

1982

Exposure of Forest Workers
to Ground Applications of

1983

�THE

ANIMAL

STUDY

�Page 7
FEDERALLY SPONSORED LABORATORY STUDIES AM) LITERATURE SURVEYS RELATED ID AGENT ORANGE
AGEHCr

STUDY EFECRT

1 i r E OX

Animal

Environmental

b l U D Y

Analytical

STATUS

Literature

Completed

Ongoing

Estimated
Completion Date

DEPARTMENT OF HEALTH
AN) HUMAN SERVICES

NIEHS
Bioassay of Octachlorodiben*zo-^p^dioxin

Indefinite

Carcinogenesis Bioassay of
2,3,7,8rTetrachlorodibenzoi-pr
dioxln in Swiss Webster Mice

Indefinite

Carcinogenesis Bioassay of
2,3,7,8*-Tetradilorodibenzo-»p»
dioxln in Osbornei-Mendel Rats
and B6C3F1 Mice
Bioassay of a Mixture of
1,2,3,6,7,8* and a Mixture
of 1,2,3,6,7,8-rHexachloror
dibenzo*prdioxins for
Possible Carcinogenicity
Comparative species Evalur
ation of Chemical Disposition
and Metabolism of 2,3,7,8r
Tetrachlorodibenzofuran (TCDF)
in Rat, Monkey, Guinea Pig and
Two Strains of Mice
Neurotoxicity of 2,4,-H) in
Rodents

Indefinite

�Pagp 8
FEDERALLY SPObECRED LABORATORY STUDIES AN) LITERATIRE SURVEYS RELATED TO AGENT ORANGE
AGENCY

STUDY EFFORT

l Y F b OF S 1 U D Y

Animal

Environmental

Analytical Literature

STATUS

Completed

Ongoing

Estimated
Completion Date

DEPARTMENTOF HEALTH
AN) HUMAN SERVICES cent 'd

Studies of the Chemical Disposition and Metabolism of
Octachlorodibenzodioxln (OCDD)

Indefinite

Effects of Agent Orange Compor
nents on Male Fertility and
Reproduction
Mutagenicity Studies of TCDD,
2,4-4); 2,4,5~T and Esters of
2,4~D and 2,4,5-T

Indefinite

Implications of Low Level
Exposure of Dioxins

X

X

Indefinite

Mechanisms of Toxicity of
the Chlorinated* prdioxins

X

X

Indefinite

X

Indefinite

Research Toward Understandsing the Molecular Level
Mechanisms of Toxicity of
TCDD and Related Compounds
Synthesis of Selected
Chlorinated dibenzo*prdioxins
and Related compounds as
Analytical Standards

Indefinite

�Page 9
FEDERALLY SPONSORED LABORATORY STUDIES AM) LITERATURE SURVEYS RELATED TO AGENT CRANCE
1YPE

AGENCr

STUDY EFFCRT

Animal

OF S i U U Y

Environmental

Analytical

STAIUS

Literature

Completed

Ongoing

Estimated
Completion Date

DEPARTMENT OF FEALTO

ADO WMAN SERVICES cont'd
Methods for the measurement
of dioxins and furans in human
adipose tissue

Indefinite

Matrix Effect and Sub Parts*
perrbillion Quantitative
Analysis of TCDD by Mass
Spectrometry *• With Special
Reference to Milk

Indefinite

Toxic Actions of Tetrar
chloroazobenzene Dioxins

X

Indefinite

XenobiotLc Induction of
Pleiotropic Responses in
Liver

X

Indefinite

Molecular, Biochemical
Actions of Chlorinated'sp*
dioxins

Indefinite

Mechanism(s) for Toxicity
of Chlorinated Dibenzoidioxins

Indefinite

�Page 10
FEDERALLY SPONSORED LABORATORY STUDIES AM) LITERATURE SURVEYS RELATED 10 AGENT GRANGE
AGENCY

STUDY EFFORT

T Y1? E O F S T U D Y

Animal

Environmental

Analytical Literature

STATUS

Completed

Qngping

Estimated
Completion Date

NIEH3
Teratogenicity of
TCDD T Cleft palata
Induction (mice)

1986

Disposition of TCDD
Fetal Distribution in
mice

1986

2,3,7,8~Tetrachlorodiibenzofur amDis posi t ion
in Rats, Mice, Guinea Pigs

disposir
tion 1983

1,2,4,6,8,9 Hexachlorodi*
benzofuranrDisposition

disposition

metabolism

1986

1986

DDXIN
Structure-Toxicity Rela*
tionships

1984

Theoretical Modeling of
Dioxin Receptor

1984
X

Molecular Modeling of
Dioxin Binding Proteins
Molecular Basis of
Dioxin Toxicity

X
Theoreti*
cal Biochemical

Lipid Assimilation NRSA

X

X

July 1986

X

Membrane /LP Receptor

1986

Nov. 1986

�Page 11
FEDERALLY SPONSORED LABORATORY STUDIES AM) LITERATtRE SURVEYS REIATED TO AGENT GRANGE
AGENCY

STtDY EFFORT

1 Y F L

Animal

O *

Environmental

b l U U Y

Analytical

STATUS

Literature

Completed

Ongoing

Estimated
Completion Date

ENVIROIMENTAL PROTECTION
AGMCY
Evaluation of Large Scale
Combustion Sources

X

X

Evaluation of Municipal
Waste Combustors

X

X

Bacterial Decomposition
of TCDD

X

X

Investigation of Bioavaila*
bility to Fresh Water Fish
of TCDDs in Fly Ash

X

Analysis of Environmental
Samples for PCDDs and PGDFs
DEPARTMENT OF AGRICULTURE
Survey of Phenoxy Herbi*cide Use by Agricultural
Commodity
Survey of Phenoxy Kerbir
cide Literature

Annaul Biblior

graphics
Published

�Page 12
FEDERALLY SPONSORED LABORATORY ST1DIES AN) LITERATURE SURVEYS RELATED TO AGENT GRANGE
AGENCY

STUDY EFFORT

TYPE

Animal

OF

Environmental

S T U D Y

Analytical

STATUS

Literature

Completed

Ongoing

Estimated
Completion Date

DEPARTMENT OF AGRICULTURE
cont'd
Photolysis of 2,4,5-vT

X

Biological and Economic
Assessment of 2,4,5»T and
Silvex

X

TCDD Residue Monitoring
in Deer

Report in
Preparation

DEPARTMENT OF DEFENSE

Environmental Chemistry of
Herbicide orange and TCDD

Indefinite

VETERANS ADMINISTRATION

Review of Literature on
Herbicides, Including
Phenoxy Herbicides and
Associated Dioxins

Published
1981

Annual update
Approved

Urinary 6-i-Hydroxy Cortisol:
Physiological and Pharmaco*logic Studies (Including
Agent Orange)

1982

Effect of TCDD on Lipid
Metabolism

1983

�Page 13
FEDERALLY SPONSORED LABORATORY STIDIES AM) LITERAHRE SIRVEYS RELATED TD AGENT GRANGE
AGEUCr

STIDY EFECRT

1 Y F E

Animal

ul?

Environmental

b l U D Y

Analytical Literature

SlAIUS

Completed

Ongoing

Estimated
Completion Date

VETERANS AEMINISTRATIDN
cont'd

Publication in
Press

Mechanisms of Dioxin Induced
Toxicity Using the Chloracne
Model * Phase I
Behavioral Toxicity of An
Agent Orange Component 2,4*D
X
Effects of 2,3,7,8*Tetra*
chlorodibenzodioxin on Hepato*
biliary function in Animals

1984
X

1986

Mechanism of TODD Absorption
and Toxicity on lipid and
lipoprotein Metabolism

1986

Metabolism of the Her hi*
cides Present in Agent
Orange and Agent Wiite

1986

TOM) Exposed Rhesus Monkeys:
Effects on Behavior and
Stress Hormones

1986

�Page 14
FEDERALLY SPONSORED LABORATORY STUDIES AM) LITERATURE SUNOS RELATED TO AGENT GRANGE
1 Y P L

A(£NCY

STUDY EFFORT

Animal

O f

Environmental

b l U D Y

Analytical

blAlUS

Literature

Completed

Ongoing

Estimated
Completion Date

VETERANS ADMINISTRATION
cont'd
Neuronuscular Toxicity of
Agent Orange

X

X

1986

Mechanisms of Dioxin Induced
Toxicity Using the Chloracne
Model * Phase II

X

X

1986

Effects of Low Dose TCDD
on Mammalian Chromosomes
and liver Cells

X

Mechanism of Porphyria Caused
by TCDD and Related Chemicals

X

X

1986

Effects of Agent Orange on
Sleep

X

X

1986

1986

�Page 15
FEDERALLY SPONSORED LABORATORY STUDIES AM) LITERA1URE SIRVEYS RELATED TO AGENT GRANGE

T Y P E 6 F- s T O b Y

AGENCY

Animal

STUDY EFFORT
ENVIRObMENTAL
AGENCY

Environmental

Analytical

STATUS
Literature

Completed

Ongoing

Estimated
Completion Date

ffiOT£CTE)N

X

Assessment of exposure
to TDCC from contaminated
media

X( Though t-nd.se)

Assessment of methods teed
for analysis of human
adipose tissue

X( Lab-wise)

December 1985

X

X

Evaluation of TOO
destruction technologies

December 1985

Oct. 1984

Behavior of TCDD in blood

X

X

December 1985

Clearance of TCDD from
dose organisms

X

X

December 1985
December 1985

Analytical methods develop*
ment of monoclonal anti*
bodies

X

Workshop report on bio*
availability

December 1985

Movement of TCDD in the
environment

X

X

December 1985

Evaluation of combustion
sources

X

X

December 1985

�Page 16
FEDERALLY SPONSORED LABORATORY STIDIES AN) LITERATURE SIRVEYS RELATED TO AGENT GRANGE
I YP E

AGENCY

STIDY EFFORT

Animal

OF S T U D Y

Environmental

Analytical Literature

STAlUb

Completed

Ongoing

Estimated
Completion Date

Analysis of background
levels of TCDD in die
IB environment

December 1985

Health assessment of
PCDDs

December 1985

Health assessment of
PCDFs

December 1985

�AGENT ORANGE/DIOXIN EXPENDITURES
AGENCY EXPENDITURES BY STUDY TYPE
$152,455,000 TOTAL EXPENDITURES

ANIMAL (12.8%)

ANALYT (1 .6%)
ENVIR (6.2%)

UT (1 . %
2)

STUDY TYPE

EXPENDITURES

HUMAN
ANIMAL
ENVIRONMENT
ANALYTICAL
LITERATURE
TOTAL

$119,293,500
19,522,000
9,382,000
2,368,000
1,890,000
$152,455,000

HUMAN (78.2%)

�AGENT ORANGE/DIOXIN EXPENDITURES
$152,455,000

TOTAL COST

USDA (O.4%) $594,000
DOD (22.O%)$33,605,000

EPA (9.5%) $ 1 4 , 4 6 7 , 0 0 0

VA (5.3.3%)
$81,286,000

X

HHS (14.8%)$22,503,000

�HHS A.O./DIOXIN EXPENDITURES
$22,50.3,000 TOTAL EXPENDITURES

ANALYT (2.5%) $556,000

HUMAN (41 .1%)
$9,244,000
ANIMAL (56.5%)
$12,703,000

�DOD A.O./DIOXIM EXPENDITURES
$33,605,500 TOTAL EXPENDITURES

ANIMAL (Q.9%) $288,000

\
HUMAN (99.1%)

$33,317,500

�USDA A.O./DIOXIN EXPENDITURES
$594,000 TOTAL EXPENDITURES

LIT (1O.8%)
$64,000

HUMAN (89.2%)
$530,000

�EPA A.O./DIOXIN EXPENDITURE
~S
$14,467,000 TOTAL EXPENDITURES

$2,146,000
ANIMAL (14.8%)

UT (7.3%)
$1,052,000

ANALYT (12.5%)
$1,812,000

HUMAN i;o.c«%)
$75,000

ENVIR (64.9%)
$9,382,000

�V.A. A.O./DIOXIN

EXPENDITURES

$81 ,286,000 TOTAL EXPENDITURES

t-1%)ANIMftL

$774,000

$4,385,000
~"""-x

V

\
\

.0%) $76,127,000

�Agent Orange Use In Vietnam
Agent Orange was the most widely used of the various
herbicides.
During the period 1964*1970, approximately 12
million gallons were sprayed in Vietnam.
In addition,
approximately five million gallons of Agent White, composed of
the chemical Picloram and 2, 4-D, and approximately three
million gallons of Agent Blue composed of cacodylic acid were
sprayed.
Neither Agent White nor Agent Blue contained the
contaminant dioxin.
The herbicides were used to defoliate jungle areas to expose
enemy troop movements and staging areas and to eliminate ambush
opportunities. . B a s e perimeters, river banks and enemy crop
resources were also defoliated.
The principal means of
distribution was by O123 fixed wing a i r c r a f t (Operation Ranch
H a n d ) . Helicopters, back~packs, truck-equipped equipment and
Navy river boats were also used. In all, it is estimated that
101 of the land area of South Vietnam was sprayed at least once.
Its use was discontinued in late 1970 because of allegations of
a link between 2, 4, 5»T and birth defects of children born in
South Vietnam. These allegations have never been substantiated.
All remaining stocks of Agent Orange were incinerated at sea
near Johnston Island (a remote island in the South P a c i f i c ) in
1977.

�THE WHITE HOUSE
WASHINGTON

SCIENTIFIC ISSUES AND AGENT ORANGE EXPOSURE
October 27, 1983

Introduction:

Dr. G. A. Keyworth
Science Advisor to the President

Briefing:

Dr. Alvin Young

Scientific Advisor, Veterans Administration
Discussion

�AGENT ORANGE EXPOSURE

�"DIOXIN" IS A FAMILY OP 75 COMPOUNDS

DIBENZO-PARA-DIOXINS

�DIOXIN OP CONCERN

2,3,7,8-TCDD

�TOXICITY OF 2,3,7,8-TCDD

Acute Tox i c i t y :

Single Dose LDgp (&gt;ig/kg )

Guinea Pig
Rat
•
Monkey
Rabbit
Dog
House
Hamster
Bullfrog
Han

0. 6
40
70
115
150
200
3,500
Over 1,000
No deaths reported

�IN LABORATORY ANIMALS, DIOXIN CAUSES

BIRTH DEFECTS
FETAL DEATH
CANCER
MUTATION?

�SOURCES OF HUMAN EXPOSURE

Industrial Accidents
Occupational Exposure
Contaminated Industrial Wastes
Herbicide Applications
Contaminated Pood
Low Temperature Combustion

�USE

OP AGENT ORANGE i IN VIETNAM

962 - 1 9 7 3
'OPERATION RANCH HAND"

�Da Nang

Phu Cat

SOUTH VIETNAM
1969
RANCH HAND BASES

Sien Hoa
• Saigon (Tan
on
Nhut)

�ESTIMATED QUANTITES OF HERBICIDES AND
TCDD SPRAYED IN VIETNAM,
JANUARY 1962 - FEBRUARY 1971*

Chemical
2,4-D
2,4,5-T
TCDD

Pounds
55,940,150
44,232,600
368

�ESTIMATED QUANTITES OP HERBICIDES AMD
TCDD SPRAYED IN UNITED STATES,
JANUARY 1962 - JANUARY 1971

Chemical
2,4-D
2,4,5-T
TCDD

Pounds
327,627,000
78,100,000
650

�VIETNAM VETERANS ARE WORRIED ABOUT

Birth Defects and Miscarriages
Cancers
S o f t T i s s u e Sarcoma
Other
Early f)eath
Skin Disorders
Chloracne
PCT

Disease Due to Dioxin
in Tissue

�BOW DO SCIENTISTS ADDRESS THESE COK*SRNS?

EPIDEMIOLOGY
AND

HEALTH SORVEILLANCE

CONSENSUS

�EPIDEMIOLOGY: STUDY OP FREQUENCY AND
CAUSE OF DISEASE IN BUMAN POPULATIONS

CASE-CONTROL STUDY Experiences compared between subjects
selected for Disease and- Subjects
without the disease.
COHORT STUDY -

Exposed and non-exposed populations
examined for disease.

�SCIENTIFIC CONSENSUS ACHIEVED WHEN

«

Statistically significant data
*

Withstand peer review, and
Results duplicated by others

�MEDICAL CONSENSUS NOW RELATES DIOXIN EXPOSURE TO

*

Chloracne

*

Porphyria Cutanea Tarda (PCT)

*

Temporary Health Effects

�DIOXIN EXPOSURE - TEMPORARY EFFECTS

Headache
Fatigue
Muscle and Joint Pain
Tingling in extremities
Sexual dysfunction

Loss of appetite
and weight
Sleep disturbances
Impaired memory
and learning ability
Abnormal liver function

�FBOERAL GOVERNMENT ADORBSSBS

VETERAN CONCERNS:

WHITE
BOOSE

CAPITOL

\
AGENT ORANGE
WORKING GROUP

�CONCERN - BIRTH DEFECTS AND M I S C A R R I A G E S

COMPLETED: EPA A R K A N S A S

STUDY-1979

NIOSH NEW YORK STATE STUDY
1979
NEW ZEALAND APPLICATOR STUDY-1982
AUSTRALIAN BIRTH DEFECTS
STUDY-1983
CONCLUSION: MEN AND WOMEN ARE AT
NO INCREASED RISK
ON-GOING: CDC/DOD/VA BIRTH DEFECTS
STUDY- 1984
AIR FORCE HEALTH STUDY- 1984

�CONCERN - MORTALITY:

COMPLETED:

CONCLUSION:

NUMBER/AGE/CAUSB

FOUR INDUSTRIAL HEALTH
STUDIES-1980-1983
FINLAND MORTALITY STUDY OP
HERBICIDE APPLICATORS-1982
AIR FORCE HEALTH STUDYBASELINE MORTALITY-1983
NO EVIDENCE OP INCREASED
DEATH RATE

ON-GOING:

NEW YORK STATE MORTALITY STUDY - 1984
VA MORTALITY STUDY -

1984

�CONCERN - CONNECTIVE TISSUE CANCER
(SOFT TISSUE SARCOMA, STS)

COMPLETED: SWEDISH STS STUDIES - 1978-1983
NEW ZEALAND STS STUDY-1932
FINLAND CANCER STODY-1982
INDUSTRIAL STUDIBS-1980-1983
CONCLUSION:

NO CONSENSUS

ON-GOING: NEW YORK STATE STUDY - 1984
NCI STUDIES - 1984-85
VA/AFIP STUDY - 1985
NIOSH REGISTRY STUDY - 1985
CDC STUDY - 1986

�CONCERN -

OTHER FORMS OP CANCER

COMPLETED: FINLAND CANCER STODY-1982
SWEDISH RISK EVALUATION OF
PESTICIDES-1982
NCI FLORIDA PESTICIDE
APPLICATOR STODY-1983
INDUSTRIAL STUDIES-1980-1983
CONCLUSION:
ON-GOING:

NO CONSENSUS

AIR FORCE HEALTH STODY-1984
NIOSH DIOXIN REGISTRY-1985
CDC AGENT ORANGE STODY-1987

�CONCERN -

CURRENT EVIDENCE:

CHLORACNE

RARE
41

ON-GOING STUDIES:

AIR FORCE HEALTH STUDY

�CONCERN -

OTHER HEALTH PROBLEMS

ON-GOING STUDIES: AIR FORCE HEALTH STODY-1984
7A TWIN STUDY-1986
CDC STUDIBS-1987
OTHER EFFORTS: VA AGENT ORANGE REGISTRY
VA PATIENT TREATMENT PILE

�CONCERN - DIOXIN IN BODY TISSUE

COMPLETED: VA FEASIBILITY STUDY-1982
CANADIAN STUDY-1983

*

CONCLDSIOHS: SMALL AMOUNTS DETECTED
NO CORRELATION WITH EXPOSURE
OR HEALTH
ON-GOING: VA/BPA DIOXIN STUDY

�SUMMARY

Short-term health effects do occur
Long-term health effects may occur
- Mo conclusive evidence to date
Massive research program underway
on long-term effects

�SCIBNTIFIC CONSENSUS EXPECTED

*

Birth Defects

1984

*

Mortality

1984

*

Soft Tissue Sarcoma

1985

Other Health Problems

1986-87

�ON-GOING VA PROGRAMS WHILE RESEARCH IN PROGRESS

Health Surveillance
- Agent Orange Registry
- Patient Treatment File
Health Care
- Public Law 97-72

�CONCERN -

OTHER FORMS OP CANCER

COMPLETED: FINLAND CANCER STODY-1982
SWEDISH RISK EVALUATION OP
PESTICIDES-1982
NCI FLORIDA PESTICIDE
APPLICATOR STODY-1983
INDUSTRIAL STODIBS-1980-1983
CONCLUSION:
ON-GOING

NO CONSENSUS

AIR FORCE HEALTH STODY-1984
NIOSH DIOXIN REGISTRY-1985
CDC AGENT ORANGE STDDY-1987

�CONCERN -

CHLORACNE

CURRENT EVIDENCE:

RARE

ON-GOING STUDIES:

AIR PORCS HEALTH STUDY

�CONCERN -

OTHER HEALTH PROBLEMS

ON-GOING STUDIES: AIR FORCE HEALTH STODY-1984
VA TWIN STDDY-1986
CDC STCDIES-1987
OTHER EFFORTS: VA AGENT ORANGE REGISTRY
VA PATIBNT TREATMENT

PILE

�CONCERN - OIOXIM IN BODY TISSUE

COMPLETED: VA PBASIBILITY STUDY-1982
CANADIAN STUDY-1983
CONCLUSIONS: SMALL AMOUNTS DETECTED

NO CORRELATION WITH EXPOSURE
OR HEALTH
ON-GOING: VA/EPA DIOXIN STUDY

�SUMMARY

Short-term health effects do occur
*

Long-term health effects may occur
- No conclusive evidence to date

' Massive research program underway
on long-term effects

�SCIENTIFIC CONSENSUS EXPECTED

Birth Defects

1984
«

•

Mortality

1984

*

Soft Tissue Sarcoma

1985

Other Health Problems

1986-87

�ON-GOING VA PROGRAMS WHILE RESEARCH IN PROGRESS

Health Surveillance
- Agent Orange Registry
- Patient Treatment Pile
Health Care
- Public Law 97-72

�Background of Agent Orange Working Group
On December 11, 1979, Stuart Eizenstat, Assistant to President
Carter, requested HHS to take the lead in convening an
Interagency Work Group (IWG) to study possible long»term health
effects of phenoxy herbicides and contaminants ( T a b A). The
IWG was to oversee, coordinate and set priorities among Federal
government research activities in this area. In designing a
research agenda, the IWG was to take into consideration the
possible health effects of exposure to Agent Orange by Vietnam
veterans.
President Reagan announced on July 17, 1981, that he was
reaffirming the mandate of the Interagency Work Group and his
intention
to "make its
work a major
priority of my
Administration". The Interagency Working Group was renamed the
Agent Orange Working Group (AOWG) and raised in status to
Cabinet Council level (Tab B ) . In his implementing memorandum
of August 21, 1981, Secretary Schweiker stated that the
President had been motivated because he shared the widespread
public and Congressional concern over possible adverse health
effects among Vietnam veterans exposed to Agent Orange and
other substances (Tab C). In the same memorandum the Secretary
reaffirmed the charter language of December 11, 1979, and added
the responsibility for guiding the epidemiologic study of the
health of Vietnam veterans authorized by P.L. 96*151 as amended
by P.L. 97*72.
In appointing her Under Secretary as chair of the AOWG in a
Press Release dated June 6, 1983, Secretary Heckler added her
personal long time interest and concern for Vietnam veterans.
"I am reaffirming this administration's commitment to the
prompt and scientifically responsible resolution of the health
concerns of Vietnam veterans who were exposed to Agent Orange
and other environmental factors during their service to their
country in that conflict" she said. (Tab D)
The charter of IWG, and now of AOWG, is a broad mandate which
provides in explicit terms the authority to design and direct
all research activities on the health effects of exposure to
phenoxy herbicides and contaminants, with exposure to Agent
Orange by Vietnam veterans as one part of the total research
design (Tab E). The contaminants mentioned include that class
of chemicals known as the dioxins produced during the
manufacture of these herbicides
The renaming of the IWG by
President
Reagan
focused
the
Work
Group's
primary
responsibility on Agent Orange, but without a change in the
language of the charter, a lack of clarity regarding the AOWG's
purpose and scope resulted.

�MEMORANDUM FOR SECRETARY OF DEFENSE
SECRETARY OF HEALTH/ EDUCATION,
AMD WELFARE
ADMINISTRATOR OF VETERANS AFFAIRS

SUBJECT:

Interagency Work Group to Study the
Possible Long-Term Health Effects of
Phenoxy Herbicides and Contaminants

In recent months the public and the Congress have become
concerned about adverse health effects to veterans following their possible exposure to herbicides, particularly
Agent Orange, while serving in Vietnam. Although there are
suggestions of adverse' health effects of human exposure to
such herbicides and contaminants, there is currently an
inadequate scientific basis for concluding that health •
problems experienced by Vietnam veterans were caused by
previous exposure to herbicides. Moreover, there is
inadequate information on the long-term health effects of
phenoxy herbicides in general.
Individually, each of your agencies has a strong interest ir.
resolving this issue. Several studies have been initiated
to answer questions about the possible health effects of
exposure to herbicides and more generally to the class of
substances called the dioxins. Collectively, the Federal
government needs to have reliable data and criteria on which
to base decisions and policies which affect the entire
country. 'Although I am aware that there has already been
extensive interagency cooperation on these issues, I believe
there is a need for formal interagency coordination.
Therefore, I request that you establish an interagency work
group to coordinate agency efforts to determine if there ara
long-term health effects following exposure to phenoxy
herbicides and contaminants, with special immediate focus or.
exposure of Vietnam veterans to Agent Orange. This interagency group should:
1. Oversee, coordinate, and set priorities among
Federal government research activities designed

�e exposure to pher.cxy he rbicides to icr.chealth, effects.
a research agenda to assure that the
'-il Government conducts comprehensive
on the long-term health effects of
compounds, in response to both scienti.ic
needs. The type and duration of
..f-.usn to Agent Orange by Vietnam veterans
-iuiic' we considered in the research agenda design
so" that the Veterans Administration will _ be able
to establish sound policies for determining
comncnsation for veterans exposed to Agent
•: Vietnam, should a relationship
..........- :;vraicide exposure and Icng-terra adverse
i;cai.rn effects be established. The research
ngcnaa snould build on current agency activities,
including the Department of Defense's Ranch Hand
study. The interagency work group should identify ^
the appropriate agencies to conduct the recommended
research, either individually or through joint
efforts.
n

3.

Provide technical support to individual agencies
and independent researchers in the formulation,
development, and implementation of research on
the bicmedical effects of phenoxy herbicides
and contaminants.

4.

Assure that the protocols and methodology of
ongoing and proposed Federally funded research
studies v/ill produce valid, reliable, timely,
and relevant data, and periodically review the
status of such research.

5.

Assure that all relevant research findings, whether
publicly or privately financed, are promptly
nude available to the public and the Congress, in
a comprehensible and comprehensive fashion. The
work group should establish a working relationship
with the Veterans Administration's Advisory
Committee on Health-Related Effects of Herbicides
and should promptly provide the Committee all
relevant information as it becomes available.

I am asking Secretary Harris to take the lead in convening
the interagency group and woulc' like to have an initial
report on the progress of the group submitted to me by

�vxr

February 15. The
of current agency
progress reports,
other agencies on

initial report should indicate the status
activities, a proposed schedule for public
and any recommendations for inclusion of
the work group.

I have asked the Office of Science and Technology Policy to
be an ex-officio participant on the work group. In addition,
the Depsrtment of Agriculture, the Environmental Protection
Agency, and the Occupational Safety and Health Administration
will initially participate on the work- gro-u? in; an observer
status.

Stuart E. Eii^nstat
Assistant to the President
for Domestic Affairs and Policy

cc:

Secretary of Agriculture
Administrator, Environmental Protection Agency
Assistant Secretary of Labor for Occupational
Safety and Health
Director, Office of Scienca and Technology Policy

�/•

THE WHITE HOUSE
WASHINGTON

July 17, 1981

MEMORANDUM FOR:

SECRETARY R1CSARO SCHWE1XZR
CHAIRMAN PRO-TZM, CABINS? COUNCIL
OH HUMAN RESOURCES

FROM:

ROBERT CARL2SON
EXECUTIVE SECRETARY OF HUMAN RSSOURC2S
CABIN2T COUNCIL

SUBJECT:

Ag«nt Orange Wor3cing Group
*

,

The 5«er«tariat of the Human Resources Cabinet Council has
established an Agent Orange Working Group. The lead agency will
be BBS, and participating members drawn from:
Department of Defense
Department of Agriculture
Department of Health and Human Services
Department of Labor
Environmental Protection Agency
Veterans Administration
Action
Office of Management and Budget
Council of Economic Advisers
Office of Science and Technology
Office of Policy Development

:c: Martin Anderson
Edwin Gray

�THE WHJTE H O U S E
WASHINGTON

AliS?1 1981
MEMORANDUM FOR;

SECRETARY OF DEFENSE

.

SECRETARY OF AGRICULTURE
SECRETARY OF LABOR
DIRECTOR, OFFICE OF MANAGEMENT AND BUDGET
ASSISTANT TO THE PRESIDENT FOR POLICY
DEVELOPMENT
CHAIRMAN, COUNCIL OF ECONOMIC ADVISERS
DIRECTOR OF ACTION
ADMINISTRATOR, ENVIRONMENTAL PROTECTION AGENCY
AD NISTRATOR OF VETERANS AFFAIRS
OF/2C£ OF SCIENCE AND TECHNOLOGY
tY_"

yztwtju^

FROM

SEtRETARY'RICHARD SCHWEIKER
CHAIRMAN.PRO-TEM, CABINET COUNCIL
ON HUMAN RESOURCES

SUBJECT

Agent Orange Working Group

The Administration has reviewed the excellent work of the
Interagency work Group to Study the Possible Long^Term Health
Effects of Phenoxy Herbicides and Contaminants and believes
that it has made significant progress toward fulfilling its
important mandate. Sy bringing together knowledgeable
scientists -from the various Federal departments and agencies
the Work Group has identified ongoing research activities on
phenoxy herbicides and contaminants and begun to develop anc
organize the means to carry out additional needed scientific
research.
President Reagan shares the widespread public and
congressional concern over possible adverse health effects
among Vietnam veterans exposed to Agent Orange and other
substances. The President stated, during his meeting with
national veterans organization leaders at the white House on
July 17, 1981, that the Administration is giving special
consideration to those concerns of Vietnam veterans.
At the White House meeting, the President announced that
the administration had re-established an expanded working Grouc
as the Agent Orange Working Group and raised its status to
Cabinet Council level. The President is personally determinec
to assure that the full resources of the Federal government are

�-2-

available to support the working Group's continuing efforts.
The decision to re-establish and expand the membership of the
working Group and to make it an integral part of the Cabinet
Council on Human Resources reflects the President's commitment
and accords the highest priority to its mission.
As Chairman Pro-Tern of the Cabinet Council on Human
Rtsources, I am, accordingly, reaffirming by this memorandum
the Agent Orange working Group's mandate of December 11, 1979
and providing specific guidance as to how that mandate is to be
carried out in accordance with the Cabinet Council's decisions.
The Department of Health and Human Services shall continue
to have lead responsibility for overall direction and
management of the Agent Orange working Group. The Secretary of
Defense and the Administrator of veterans Affairs shall
continue to assure that their respective agencies participate
fully in all working Group activities. The Departments of
Agriculture and Labor and the Environmental Prm action Agency,
each of which have until now been observers, sr.dil assume full
membership and their respective agency heads shall assure that
those agencies participate fully in all work Group activities.
In addition, ACTION, the Office of Management and Budget,
and the Council of Economic Advisers, as well as the wnite
House Office of Science and Technology Policy and the Office of
Policy Development, snail assume membership on the working
Group and the heads of those agencies and offices shall assure
that the resources of their respective agency or office are
fully available to support it.
Also, the congressional Office of Technology Assessment,
which has been actively involved in all working Group
activities as an observer, will be invited to continue to
participate ir that capacity, and the General Accounting
Office, which has been extremely helpful to the working Grouo
in the past, will continue to be kept abreast of developments
and invited to advise and assist as appropriate.
The working Group has initiated research efforts designed
to find answers to many of the questions surrounding Agent
Orange that have been raised. These efforts include the birth
defects study being conducted by HHS' Centers for Disease
Control, the Ranch Hand Study being conoucted by the Air Fores,
the epidemiological study being planned by the Veterans
Administration pursuant to P.L. 96-151, and the compilation by
HHS' National Institute of Occupational Safety and Health of a
national registry of workers exposed to dioxins. Each of these
research activities, as well as tne other important research

�-3*

activities being conducted under the overall guidance of the
working Group, are to be continued without interruption or
delay.
The working Group has developed an impressive record of
scientific objectivity, impartiality and integrity and it is
imperative to the success of the Working Group effort that this
record and the Group's credibility be maintained. In this
regard, regular progress reports to the Cabinet Council, the
Congress and the public will continue to be made by the Agent
Orange working Group.
To assure effective leadership of the working Group, I am
hereby appointing James Stockdale, HHS Deputy Under Secretary
for Intergovernmental Affairs, as Chair. Also, I am appointing
Or. Vernon N. Houk of the Center for Environmental Health of
the Centers for-Disease Control as Chair of the Working Grouo's
Science Panel. In addition, I am appointing HHS Legal Counsel
Leslie A. Platt, who has served as legal adviser to and staff
director of the working Group since its inception, to continue
in tnose capacities. I know and believe you will find that
these individuals share my commitment to carrying out this
important mission.
•
Please review your representation on the working Group to
assure that your agency or office is adequately represented 5y
appropriate technical experts, scientists and policy-level
officials. In order to facilitate the Group's effectiveness,
it is of course important that each agency's total membersni:
be limited.
The first meeting of the full working Group has been
scheduled for Friday, August 28, 1981 and a meeting of the
Science Panel will be scheduled for shortly thereafter.
Accordingly, please 'et Mr. Bart Kull, Special Assistant tc :-e
Deputy Under Secretary for Intergovernmental Affairs
(245-6154), or Dr. Peter Beach, HHS Director of Veterans
Affairs (245-2210), know as soon as possible the name(s) z*
your designated representative(s) so that briefing materials
may be forwarded to them.
Attached for your information is a copy of the memorancu"
of the Executive Secretary to the Cabinet Council on Human
Resources establishing the Working Group.
Attachment
cc: Comptroller General of the Urited States

Director, Congressional Office of Technology Assessment
' Mr. Robert Carleson
Mr. Edwin Gray

�Ki
DEPARTMENT Of HEALTH AND HUMAN SERVICES

FOR IMMEDIATE RELEASE

RuSSf&gt;11

N«k"(2«&gt;

Monday, June 6, 1983
Health and Human Services Secretary Margaret M. Heckler today named her
department's under secretary, John A. Svahn, as chairman of the Agent Orange Working
Group of the Cabinet Council on Human Resources.
The working group coordinates and oversees federal research Into the posslblHt;
of long term adverse health effects resulting from exposure to phenoxy add herbicides used during the Vietnam War. The herbicides, principally Agent Orange, were
s

used primarily to defoliate dense jungle cover to reveal enemy troop movements and
staging areas.
"By designating the second highest official of my department as chairman, I am
reaffirming this administration's commitment to the prompt and scientifically
responsible resolution of the health concerns of Vietnam veterans who were exposed
to Agent Orange and other environmental factors during their service to their country
In that conflict. Jack Svahn1s leadership of this vital working group will help us
get the answers we need," Secretary Heckler said.
In response to veterans' concerns about the possibility of illness as a result
of their exposure, the working group was created 1n late 1979. It was reestablished
and upgraded to Cabinet Council reporting level by President Reagan 1n July 1981.
Under the aegis of the working group, various federal agencies, including HHS1
Public Health Service, the Veterans Administration and Department of Defense, are
conducting 64 separate research studies relating to Agent Orange and other health
effects of service in Vietnam, at a cost estimated in excess of $100 million.
As chairman of the working group, Svahn will report to the president through
Secretary Heckler in her capacity as chairperson pro-tern of the Cabinet Council on

�-2-

Svahn was appointed under secretary of the Department of Health and
Human Services March 8. Prior to that appointment he served as commissioner
of Social Security since May 6, 1981.
Following service 1n the U.S. A1r Force 1n 1968, Svahn held administrative
positions with the state of California, the federal government and the private
sector.

I II

�CHARTER

Cabinet Council Agent Orange Working Group
December 11, 1979, as Reaffirmed
on August 21, 1981
The Agent Orange Working Group shall:
1.

Oversee, coordinate, and set priorities among Federal
government research activities designed to relate
exposure to phenoxy herbicides to long-term health
effects.

2.

Design a research agenda to assure that the Federal
government conducts comprehensive research on the longterm health effects of the compounds, in response to
both scientific and policy needs. The type and
duration of exposure to Agent Orange by Vietnam veterans
must be considered in the research agenda design so
that the Veterans Administration will be able to establish sound policies for determining compensation for
veterans exposed to Agent Orange in Vietnam, should a
relationship between herbicide exposure and long-term
adverse health effects be established. The research
agenda should build on current agency activities,
including the Department of Defense's Ranch Hand study.
The Working Group should identify the appropriate
agencies to conduct the recommended research,
either individually or through joint efforts.

3.

Provide technical support to individual agencies and
independent researchers in the formulation, development,
and implementation of research on the biomedical effects
of phenoxy herbicides and contaminants.

4.

Assure that the protocols and methodology of ongoing
and proposed federally funded research studies will
produce valid, reliable, timely, and relevant data,
and periodically review the status of such research.

5.

Assure that all relevant research findings, whether
publicly or privately financed, are promptly made
available to the public and the Congress, in a comprehensible and comprehensive fashion.
The work group
should establish a working relationship with the Veterans
Administration's Advisory Committee on Health-Related
Effects of Herbicides and should promply provide the
Committee all relevant information as it becomes
available.

6.

Provide guidance to the epidemologic study of the health
of Vietnam Veterans authorized by P.L. 96-151 as amended
by P.L. 97-72.

�Agent Orange Working Group Organization

Following a review of the work of the Interagency Working
Group, President Reagan in July 1981 re-established and
expanded the Interagency Work Group, raised its status to
Cabinet Council level and renamed it the Agent Orange Working
Group (AOWG). The purpose was to reflect his commitment to the
work of the group and to place high priority on its mission.
The President asked the Secretary of HHS, as Chair Pro-Tern of
the Cabinet Council on Human Resources, to oversee its work.
The AOWG now reports to the Cabinet Domestic Council.
The AOWG membership includes representatives from the Veterans
Administration (VA), Departments of State, Defense and Labor,
the Office of Management and Budget, the Environmental
Protection Agency, the ACTION Agency, the Council of Economic
Advisors, the White House Office of Science and Technology
Policy and the Assistant to the President for Policy
Development.
The Congressional Office of Technology Policy
participates as an observer.
The AOWG organization is headed by a Chair appointed by the
Secretary as a member of the Cabinet. The Chair, AOWG, in turn
appoints:
1.2.
3.
4.
5.

Chair, Science Panel
Legal Counsel
Executive Secretary
Chair, Resources Panel
Chair, Public and Congressional
Affairs Panel

The Science Panel, composed of expert medical and scientific
personnel drawn from various government agencies concerned with
issues of public health, advises the AOWG on the conduct of
research related to Agent Orange. The Science Panel includes
two subpanels: a Research Agenda Subpanel to recommend needed
research and a Research Review Subpanel to review all planned
research for adequacy of design and conformance with the AOWG
mission.
The Resources Panel is concerned with the proper allocation of
available resources among planned and on-going research and the
avoidance of duplication of effort.
The Public and Congressional Affairs Panel defines policies to
be used in information dissemination to insure that such
dissemination is timely, accurate and complete.

�-2-

In addition to these structures, the AOWG is advised by the
Advisory Committee on Special Studies Relating to the Possible
Long-Term Health Effects of Phenoxy Herbicides and Contaminants.
This Advisory Committee is composed of pre-eminent scientists
from outside the Government.
membership
with
the
current
designated
The
agency
represenatives from each and the staff of the AOWG are listed
at Tab A.

�DEPARTMENT OF HEALTH &amp; HUMAN SERVICES

Office of the Secretary
Washington, D.C. 20201

AGENT ORANGE WORKING GROUP
MEMBERSHIP
DEPARTMENT OF HEALTH AND HUMAN SERVICES

Lead Representatives:

Mr. Dixon Arnett
Acting Chair Pro Tempore, AOWG
Deputy Under Secretary
for Intergovernmental Affairs
Department of Health and Human Services
200 Independence Avenue, S.W.
Room 606-E, HHH Building
Washington, D.C. 20201
(202) 245-0409
Dr. James 0. Mason
Vice-Chair, AOWG
Acting Assistant Secretary for Health
Department of Health and Human Services
200 Independence Avenue, S.W.
Room 716-H, HHH Building
Washington, D.C. 20201
(202) 245-7694
Dr. Carl Keller*, Chair
Science Panel
Epidemiologist
National Institute of Environmental
Health Sciences•
Room 2B55, Building 31
National Institute of Health
Bethesda, Maryland 20205
(301) 496-3511
Mr. Edwin Weiss (AOWG Legal Counsel)
Office of the General Counsel
330 Independence Avenue, S.W.
North Building, Room 4460
Washington, D.C. 20201
(202) 475-0155
Dr. Peter Beach
AOWG Executive Secretary
Director of Veterans Affairs
Office of the Under Secretary
Room 632-F, HHH Building
200 Independence Avenue, S.W.
Washington, D.C. 20201
(202) 245-2210 or 245-6156

^Denotes Science Panel Member
Revised:

September 1985

�-2-

DEPARTMENT OF HEALTH AND HUMAN SERVICES cont'd (Members)
Dixon Arnett
Deputy Under Secretary
for Intergovernmental Affairs
Department of Health and Human Services
200 Independence Avenue, S.W.
Room 606-E, HHH Building
Washington, D.C. 20201
(202) 245-0409
Shirley Earth
AOWG Public/Congressional
Affairs Panel, Chair
US/PHS
200 Independence Avenue, S.W.
Room 716-G, HHH
Washington, D.C. 20201
(202) 472-5663
Lee Mosedale
Policy Coordinator
OS/ES
HHH Building, Room 635-G
200 Independence Avenue, S.W.
Washington, D.C. 20201
(202) 245-7462
•
Dr. Vernon Houk*

Director
Center for Environmental Health
Centers for Disease Control
1600 Clifton Road, N.E.
Atlanta, Georgia 30333
FTS 236-4111 Commercial (404) 452-4111
Dr. David Rail*
Director, National Institute of
Environmental Health Sciences
P.O. Box 12233
Research Triangle Park, N.C. 27709
FTS 629-3201 Commercial (919) 541-3201
Dr. James S. Dickson, III
Senior Advisor for Environmental Affairs
Office of the Assistant Secretary
for Health
Department of Health and Human Services
200 Independence Avenue, S.W.
Room 701-H, HHH Building
Washington, D.C. 20201
(202) 245-6811

�DEPARTMENT OF HEALTH AND HUMAN SERVICES

cont'd

Dr. Renata Kimbrough*
Research Medical Officer
Centers for Disease Control
1600 Clifton Road, N.E.
Atlanta, Georgia 30333
FTS 236-4324 Commercial (404)

454-4324

Dr. Philip Landrigan, Director*
Division of Surveillance, Hazard
Evaluations and Field Studies
4673 Columbia Parkway
Cincinnati, Ohio 45226
FTS 684-4428 Commercial (513) 684-4428
Miriam Davis, Ph.D.*
Staff Assistant/PHS
AOWG Science Panel
200 Independence Avenue, S.W.
Room 716-G, HHH
Washington, D.C. 20201
(202) 245-6301
Dr. Robert W. Miller*
Chair, Advisory Committee
Clinical Epidemiology Branch
National Cancer Institute - NIH
Room 5A21, Landow Building
Bethesda, Maryland 20205
(301) 496-5785
Dr. Marilyn Fingerhut*
Section Chief
NIOSH - EPI I

4676 Columbia Parkway
Mail Stop R-15
Cincinnati, Ohio 45226
(FTS) 684-4411 Commercial (513) 684-4411
WHITE HOUSE OFFICE OF POLICY DEVELOPMENT

Lead Representative:

Dr. William Roper*
Special Assistant to the
President for Health Policy
Old Executive Office Building
Room 235
Washington, D. C. 20500
(202) 456-6722

�-4WHITE HOUSE OFFICE OF SCIENCE AND TECHNOLOGY POLICY
Lead Representative:

Dr. George Keyworth*
Science Adviser to the President
&amp; Director, Office of Science
Technology Policy
Old Executive Office Building
Room 358
Washington, D.C. 20500
(202) 456-7116
Dr. Alvin Young*
Senior Policy Anaylst
Office of Science Technology Policy
New Executive Office Building
Room 5005
Washington, D.C. 20500
(202) 395-3125

VETERANS ADMINISTRATION
Lead Representative:

Mr. Everett Alvarez
Deputy Administrator
Veterans Administration
810 Vermont Avenue, N.W., Rm. 1000N
Washington, D.C. 20420
(202) 389-5428
Dr. Barclay Shepard (102)*
Director, Agent Orange Projects Office
Veterans Administration
810 Vermont Avenue, N.W., Room 308
Washington, D*C. 20420
(202) 376-7528
Dr. Lawrence B. Hobson (102)*
Deputy Director
Agent Orange Projects Office
Veterans Administration
810 Vermont Avenue, N.W., Rm. 116
Washington, D.C. 20420
(202) 389-5534

DEPARTMENT OF DEFENSE

Lead Representative:

Captain Peter A. Flynn, MC, USN*
Director, Professional Services
ODASD(Health Promotion),
OASH (Health Affairs)
The Pentagon, Room 3E337
Washington, D.C. 20301
(202) 697-8973

�-5-

DEPARTMENT OF DEFENSE cont'd
Richard S. Christian, C.R.M.*
Director, Environmental Support Group
Army Agent Orange Task Force
1730 K Street, N.W., Room 210
Washington, D.C. 20006
(202) 653-1832
Lt. Col. Robert Capell*
Asst. for Bioenvironmental Engineering
Office of Surgeon General
USAF/SGES
Boiling Air Force Base
Washington, D.C. 20332
(202) 767-5078
DEPARTMENT OF AGRICULTURE

Lead Representative:

Dr. Philip Kearney*
Chief, Pesticide Degradation Lab
U.S. Department of Agriculture
BARC-West
Building 050 - Room 100
Beltsville, Maryland 20705
(301) 344-3533

ENVIRONMENTAL PROTECTION AGENCY

Lead Representative:

Dr. Jack Moore*
Assistant Administrator
for Pesticides &amp; Toxic Substances
U.S. Environmental Protection Agency
401 M Street, S.W., (TD788)
Washington, D. C. 20460
(202) 382-2902
Dr. Donald Barnes*
Senior Science Adviser to the
Assistant Administrator
for Pesticides and Toxic Substances
U.S. Environmental Protection Agency
401 M Street, S.W., (TS788)
Washington, D.C. 20460
(202) 382-2897

�-6DEPARTMENT OF LABOR
Lead Representative

Mr. Donald Shasteen
Assistant Secretary for
Veterans Employment and Training
Department of Labor
Francis Perkins Building, Rm. S-1315
200 Constitution Avenue, N.W.
Washington, D.C. 20210
(202) 523-9116
Mr. Stephen Mallinger*
Deputy Director for the Director
of Technical Support
U.S. Department of Labor
OSHA
200 Constitution Avenue, N.W.
Room N-3651, FPB
Washington, D.C. 20210
(202) 523-7047

ACTION
Lead Representative

Vacant
James Hearn
Deputy Director
The President's Vietnam Veterans
Leadership Program
ACTION
806 Connecticut Ave., N.W. Room 1006
Washington, D.C. 20525
(202) 634-9339

COUNCIL OF ECONOMIC ADVISERS
Lead Representative:

Vacant

�-7-

OFFICE OF MANAGEMENT AND BUDGET
Lead Representative:

Mr. John Cogan
Associate Director for Human
Resources, Veterans &amp; Labor
Office of Management and Budget
Old Executive Office Building
Room 246
Washington, D.C. 20503
(202) 395-3120
Mr. Bernard H. Martin
Deputy Associate Director for
Labor, Veterans &amp; Education Division
Office of Management and Budget
New Executive Office Building
Room 7025
Washington, D.C. 20503
(202) 395-3971
Susan Jacobs
Chief of Veterans Affairs Branch
Veterans Affairs Branch
Office of Management and Budget
New Executive Office Building
726 Jackson Place, N.W., Rm. 7007
Washington, D.C. 20503
(202) 395-4500
Ms. Annette Rooney
Budget Examiner
Veterans Affairs Branch
Office of Management and Budget
New Executive Office Building
726 Jackson Place, N.W., Rm. 7013
Washington, D.C. 20503
(202) 395-4500

CONGRESSIONAL OFFICE OF TECHNOLOGY ASSESSMENT (OBSERVER)

Lead Representative:

Dr. Michael Gough*
Senior Analyst
United States Congress
Office of Technology Assessment
Washington, D.C. 20510
(202) 226-2070

�-8CONGRESSIONAL OFFICE OF TECHNOLOGY ASSESSMENT (OBSERVER)
(cont*d)

Ms. Hellen Gelband*
Analyst
Office of Technology Assessment
United States Congress
Washington, D.C. 20510
(202) 226-2070
DEPARTMENT OF STATE
Lead Representative:

Mr. William J. Walsh, III
Biomedical Research Officer
Office of Environment and Health
Department of State
Room 7820
Washington, D.C. 20520
(202) 632-4824
Dr. Charles E. Brodine, M.D.*
Assistant Medical Director for
Environmental Health and
Preventive Medicine
Office of Medical Services, M/MED
Department of State, Rm. 4253
Washington, D. C. 20520
(202) 632-5337
*

Mr. Steve Johnson
Vietnam Desk Officer
Bureau of East Asia and Pacific Affairs
Department of State, Room 5210
Washington, D.C. 20520
(202) 632-3132

�Agent Orange Working Group
Public Affairs Panel
Ms. Shirley Earth
Chair USPHS/Public Affairs
Room 716G Hubert H. Humphrey Bldg.
200 Independence Avenue, S. W.
Washington, D.C. 20201
Mr. William J. Walsh, III
Biomedical Research Officer
Office of Environment and Health
Department of State
Room 7820
Washington, D.C. 20520
Lt. Colonel Edwina Palmer
Department of Defense
Public Affairs
Room 1E794
The Pentagon
Washington, D.C. 20301
Mr. Robert Putnam
106
Veterans Administration
Public Affairs
810 Vermont Avenue, N.W.
Washington, D.C. 20420
Ms..Inez Artico A-107

Public Affairs
Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 2046
Mr. Donald Berreth
Centers for Disease Control
Room 2067, Building 1
Atlanta, Georgia 30333

�Advisory Committee on Special Studies
The Advisory Committee on Special Studies Relating to the
Possible Long-Term Health Effects of Phenoxy Herbicides and
Contaminants had its genesis in the directives of the White
House for an independent review from scientists outside the
Government of the Air Force Ranch Hand Study (Tab A). This
study compared mortality and morbidity of the Air Force
personnel involved in the spraying of Agent Orange in Vietnam
with a group of Air Force personnel who were not exposed to the
herbicide.
Because of the value of this kind of independent review, the
Advisory Committee on Special Studies was chartered to permit
it, at the discretion of the Chair, Agent Orange Working Group
(AOWG), to undertake a review of any study, proposed or
on-going, which falls within the purview of the AOWG.
The Advisory Committee on Special Studies is established under
the provisions of the Advisory Committee Act and is governed by
the regulations of 45 CFR Part 11.
The Charter of the
Committee is at Tab B, and its membership is listed at Tab C.

�THE WHT- H'-V-SF:
Scr,tc:rbcr 1G, 1980

' -.' ' •.•'•'"•I
".; | V ., ,.."'
; IJ
&lt;*J k.i dO

MEMORANDUM FOR THE SECRETARY OF DEFENSE
THE SECRETARY OF HEALTH AND HUMAN SERVICES-x
THE SECRETARY OF AGRICULTURE
THE ADMINISTRATOR OF VETERANS AFFAIRS
THE ADMINISTRATOR OF THE ENVIRONMENTAL
PROTECTION AGENCY
THE ASSISTANT SECRETARY OF THE OCCUPATIONAL
SAFETY AND HEALTH ADMINISTRATION
SUBJECT:

Epidemiological Study of Ranch Hand Personnel
V'

Last December, I asked you to participate in &lt;r- « interagency work
group to coordinate federal agoncy efforts to determine if
there are long-term health effects following exposure to
phenoxy herbicides and contaminants, with special immediate
'focus on exposure of veterans to Agent_Orange in Vietnam.
I am gratified by the progress that the.Work Group has made
in a short period and by the respect that the Work Group has
earned with the Congress and the public. The members of
your agencies who have participated on the Work Group should
be commended for their diligence and spirit of cooperation.
"r.-'^uy , I air. i;\ f r ;•.- ino S^occ r ri.ry ;: ; . •.•..•;! rr,,it T '. v^ cc;,c-.::: :;.
winh the Intcracwncy v.'ork Group's rcco;..-"--nd i-: "n L'nat the
Air Force proceed to conduct the? Fp i r.r:v i ^ !&lt;_'••:: e.i 1 Su'.u:y c :'
'vir.ch li.it'id Pet'sor.iio 1 . I strongly i^l;.".- •:;,::. -m •.•*;•&gt;;:; t : • '.
c&lt;..'..'potieii t of tins c i fort must be \ t,;.':. •; •t'fv.'.cn t re ^ Lew v ind
••ionitoring over the n'jxt few yi.-.-irs ITy tTTTo nTT^TTiTTeiTcy '.-.'or'-.
Group's Scientific T^acl.
In addition, I look to the Work Group uc urovuie s u b s t a n t i a l
resistance to the Veterans Adrnin i st rat i or., who &lt;il«o w i l l
conduct a major op: douiiologi cal ptudy of the rorr.ible lonetni/m health efforts in veterans of service i,-, V •' ^t nnm. T':•.•:•
V.'ork Group's expertise and credibility w i l l nr^vir.e v a l u a r l - _ assistance to tiic v;».

�dr:r.onstruted as well as the concinuino ;-o:!t.;i r\ r^nts for
f;i?vcrr.r,-"::':."!l c^v.cios or. f'-.cnc::^ h^rbicicc r, rrrr.!: Pr.zc 2nd
I wish now to reaffirm the mandate of the InLcragcncy Work
Group. I hope that your agencies continue to give participation
on the Work Group as much importance in the future as they
have in the past.
T/-~&amp;fal

Stuart E. Eizenstat
Assistant to the President
for Domestic Affairs and Policy

�&lt;•

'•»

•

.

-»

» 1

THE WHITE Hbu'3
WASHINGTON

September 16/ 1980

MEMORANDUM FOR THE SECRETARY OF DEFENSE

The Air Force has sought guidance from the Interagency Work
Group on the Possible Long-Term Health Effects of Phenoxy
Herbicides and Contaminants on whether it should proceed
with the Epidemiological Study of Ranch Hand Personnel
because the National Academy of Sciences review of the Air
Force protocol had expressed concern about the credibility
of the Air Force to conduct the study.
Ranch Hand personnel, who applied Agent Orange between 1962
and 1971 in Vietnam, are the only population whose frequency
and duration of exposure to Agent Orange are known with any
accuracy. The Interagency Work Group agrees with the Air
Force that the results of the Ranch Hand study should
provide valuable information about the long-term health
effects of exposure by veterans to Agent Orange in Vietnam.
Over the past 20 months, the Air Force has made a conscientious
effort to design a scientifically valid study responsive to
the recommendations of five separate peer reviews, including
that of the National Academy of Sciences. After a thorough
review of the proposed final study protocol, which includes
certain changes based on the separate peer reviews, and after
consultation with the Air Force scientists responsible for
the study, the Work Group recommended to me that the Air
Force be instructed to carry out the Ranch Hand study. In
light of the progress already made by the Air Force and the
need to proceed expeditiously with this important study,
Frank Press and I concur with the Work Group'-e recommendation.
There remains deeply"felt concern among some Vietnam veterans
and others about the objectivity of the Air Force to study
the possible health effects of Agent Orange. While affirming
the capability of the Air Force to assure the proper conduct
of the study, the Interagency Work Group has suggested that
this concern can be reasonably addressed by independent review
and monitoring of the study. I believe that the Scientific
Panel of the Interagency Work Group, which is already familiar

�with the Ranch Hand protocol, is tne appropriate body to
oversee the study and to provide technical assistance, as
needed, to the Air Force scientists responsible for the
study. For the--purpose of assuring the public that the -,
study'results are reliable and valid, the Work Group plans
to augment the Scientific Panel with reputable scientists
fchp government, including those suaoftsted hy
veterans organizations.
The Interagency Work Group noted that the evaluation of
Ranch Hand personnel may have to continue for a lengthy
period of time in order to have a better chance of detecting
latent or subtle health effects, particularly related to
cancer. The Air Force, in consultation with the Scientific
Panel, has already designed the protocol to reflect this
recommendation.
I an advised that the Ranch Hand study presents a number of
difficult technical problems. While recognizing *:he need to
obtain study results promptly, the Air Force's p^.mary
responsibility must be to assure that the results will be
reliable and valid. I urge the Air Force to utilize fully
the expertise of the Scientific Panel of the Interagency
Work Group to advise them on the difficult decisions that
will surely arise during the course of the study.
In closing, I would like to reaffirm the importance of the
Ranch Hand study to Vietnam veterans and their families.
The Interagency Work Group and the White House are prepared
to offer any assistance that the Air Force may require in
discharging its responsibility to conduct a high quality
scientific investigation.
Stuart E.£Eizenstat
Assistant to the President
for Domestic Affair&gt; and Policy

�CHARTER

( A s Amended M a y 1984)

Advisory Committee on Special Studies
Relating to the Possible Long-Term Health
Effects of Phenoxy Herbicides and Contaminants
Purpose
By memorandum of December 11, 1979, the Assistant to the
President for Domestic Affairs and Policy directed the
establishment of an Interagency Work Group to Study the
Possible Long-Term Health Effects of Phenoxy Herbicides and
Contaminants (Work Group) under the leadership of the
Secretary of Health and Human Services. The Work Group was
specifically directed to assure that the protocols and
methodology of proposed federal research studies will
provide reliable data, as well as to provide technical
support to individual agencies in the implementation of
research.
On August 1, 1980, the Work Group recommended that the
United States Air Force conduct its proposed Epidemiologic
Studies of Ranch Hand Personnel (Rand Hand Study) and that
the conduct of the study be overseen by an independent
monitoring committee. By memorandum of September 16, 1980,
the Assistant to the President for Domestic Affairs and
Policy directed the Air Force to conduct the Ranch Hand
Study. In addition, the memorandum directed the Scientific
Panel of the Work Group, augmented by scientists from
outside the government and including those suggested by
veterans organizations, to oversee the study arid to provide
technical assistance, as needed, to the Air Force.
On July 17, 1981, the President re-established the Interagency
Work Group as the Agent Orange Working Group (A.OWG) and
elevated it to Cabinet Council status. On August 21, 1981,
the Secretary, DHHS, Acting as Chairman Pro-Tern, Cabinet
Counsel on Human Resources, reaffirmed the Work Group's
mandate of December 11, 1979 and appointed the Deputy
Undersecretary for Intergovernmental Affairs as Chair of the
AOWG.
Authority
The Committee on Special Studies was established under the
provisions of section 222 of the Public Health Service Act,
as amended, 42 U.S.C. 217a. The Committee is governed by
the provisions of 45 CFR Part 11 which sets forth standards
for the creation and use of advisory committees.

I /

I I

�- 2-

Function
The Advisory Committee on Special Studies Relating to the
Possible Long-Term Health Effects of Phenoxy Herbicides and
Contaminants shall advise the Secretary and the Chair,
Cabinet Council Agent Orange Working Group (AOWG), concerning:
1.

Its oversight of the conduct of the
Ranch Hand Study by the Air Force;

2.

Its oversight and evaluation of the Agent
Orange/Vietnam Experience Study mandated
by Section 307 of P.L. 96-151 as amended
by P.L. 97-72; and

3.

Other studies in which the Secretary or
the Chair, AOWG, believes involvement by
the Advisory Committee is desirable.

The Advisory Committee may provide technical assistance to
the study under its consideration.
On the basis of its oversight and evaluation, the Advisory
Committee may, inter alia, recommend to the Secretary and
the Chair, AOWGT(a) approval, (b) deferral because of a
need for further evaluation, (c) disapproval in whole or in
part, or (d) imposition of additional conditions which in
its judgemnt are necessary to assure or protect advancement
of the study under consideration.
Structure
The Committee shall consist of the Secretary, or designee,
as Chair, and eight members selected by the Secretary from
authorities knowledgeable in fields related to the studies
under its oversight and evaluation. The Executive Secretary
shall be selected by the Chair.
Management and support services shall be provided by the
National Cancer Institute.
Meetings
Meetings shall usually be held quarterly at the call of the
Chair, who shall also approve the agenda. A government
official shall be present at all meetings.
Meetings shall be open to the public except as determined
otherwise by the Secretary; notice of all meetings shall be
given to the public.

�Meetings shall be conducted, and records of the proceedings
kept, as required by applicable laws and Departmental
regulations.
Compensation
Members who are not full-time federal employees shall be paid
at the rate of $100 per day, plus per diem and travel expenses
in accordance with Standard Governmental Travel Regulations.
Annua1 Cos t Estimate
Estimated annual cost for operating the Committee, including
compensation and travel expenses for members but excluding
staff support, is $19,736. Estimate of annual man years of
staff support required is one-quarter, at an estimated annual
cost of $8,380.
Reports
An annual report shall be submitted to the Secretary through
the Chair/ AOWG, not later than November 1 of each year, which
shall contain as a minimum a list of members and their business
addresses, the Committee's functions, dates and places of
meetings, and a summary of Committee activities and recommendations made during the fiscal year. A copy of the report shall
be provided to the Department Committee Management Office.
Termination Date
The duration of the Advisory Committee on Special studies
Relating to the Possible Long-Term Effects of Phenoxy
Herbicides and Contaminants is five years. Unless renewed by
appropriate action prior to its expiration, the Committee will
terminate on January 19, 1985.

�PROFESSIONAL AREA BREAKDOWN - ADVISORY COMMITTEE ON SPECIAL STUDIES RELATING TO THE POSSIBLE LONG-TERM
HEALTH EFFECTS OF PHENOXY HERBICIDES AND CONTAMINANTS

Authorized Positions:
Name

Term Ending

Corns tock
Friedman

Duration of Committee
Duration of Committee

Kreiss

Duration of Committee

Kurland
Monson
Nelson
Ramey

Duration
Duration
Duration
Duration

of Committee
of Committee
of Committee
of Committee

Expertise
Epidemiology
Pediatrics, human
genetics
Occupational Health,
epidemiology
Epidemiology, neurology
Epidemiology
Toxicology
Statistics, psychology

8

Prof ./Lay/Res.

Geog. Dist.

X
X

MA
TX

X

CO

X
X
X
X
X

MN
MD
NY
NC

PROPOSED CANDIDATE FOR VACANCY

Pardes

Duration of Committee

Psychiatry

Minority/Female

NY

X

�CONGRESSIQNALLY AUTHORIZED EPIDEMIOLOGICAL STUDY

In January 1979, the Congress enacted P.L. 96-151 which directed
the Veterans Administration (VA) to investigate health effects
of Agent Orange. The authorization was expanded in November
1981 by P.L. 97-72 to include "other factors."
In January 1983, responsibility for design and execution of the
study was formally transferred from VA to the Centers for
Disease Control (CDC), with resources, both FTE's and funding,
to be provided by VA.
The CDC protocol for conducting the study was completed and
distributed for scientific review in May 1983. Principal review
was conducted by the Office of Technology Assessment. Reviews
were also conducted by the Agent Orange Working Group Science
Panel, by the Advisory Committee on Special Studies Relating to
the Possible Long Term Health Effects of Phenoxy Herbicides and
Contaminants (which oversees the Air Force Ranch Hand Study),
and by the CDC Ad Hoc Review Panel.
National veterans'
organizations were invited to comment.
All reviews were
completed by September 1983.
The CDC protocol contains three study components: (1) Vietnam
Experience; (2) Agent Orange; and (3) Selected Cancers Study.
1. ' The Vietnam Experience Study is to determine whether
veterans who served in Vietnam are at greater risk for poor
health than are similar veterans who did not serve in
Vietnam. The study will identify, from personnel records,
6,000 one-term Army veterans who have served in Vietnam and
6,000 similar veterans who have never been in Vietnam. All
of these will be followed for mortality or given a
telephone interview covering general health information and
demographic data. 2,000 from each group will be given
comprehensive physical and psychological examination and
health outcomes for the two groups will be compared.
The questionnaire for this study has been reviewed by the
Science Panel and cleared by OMB. A pilot test to
determine
locatability
and
participation
rates
of
prospective subjects has been completed and reviewed by the
Science Panel.
Participation rates were better than
anticipated and the study is preceding to the main data
collection phase.
Concerns were raised by the Science
Panel that self-reported health data, including information on reproduction outcomes, should be verified from
medical and/or vital records or not collected at all. Some

�-2-

plans for utilization of these data are currently being
developed at CDC and will be discussed at a Science Panel
meeting in the near future.
2.

The Agent Orange Study is to determine whether Vietnam
veterans who were highly likely to have been exposed to
Agent Orange while in Vietnam are at greater risk for poor
health than are Vietnam veterans with similar experiences
while in Vietnam but very unlikely to have been exposed to
Agent Orange while there. The study will identify, from
Battalion Daily Reports, 6,000 one-term Army Vietnam
veterans who were likely to have been exposed to Agent
Orange on several occasions, 6,000 similar Vietnam veterans
who were not likely to have been exposed to Agent Orange,
and 6,000 Vietnam veterans known to have served in areas
where Agent Orange was never used. All of these will be
followed for mortality or given a telephone interview and
2,000 from each group will be examined as in the Vietnam
Experience Study.
The questionnaire for this study is similar to the one
being used in the Vietnam Experience Study. The pilot has
not been completed but should yield similar results, to the
one which has been used for the Vietnam Experience Study.
Since the identification of Agent Orange exposed and
unexposed subjects who are similar in other ways is crucial
to the successful completion of the Agent Orange Study, the
selection of the three study cohorts will be reviewed by
the Science Panel when this stage has been completed and
before the main study begins.

3.

The Selected Cancers Study is to determine whether Vietnam
veterans are at greater risk for certain cancers than the
rest of the population. The study will select post 1985
diagnoses of soft tissue sarcoma, Non-Hodgkins Lymphoma and
other cancers from newly identified entries into the
Surveillance,
Epidemiology,
and
End
Results
(SEER)
Registries sponsored by the National Cancer Institute.
These registries cover approximately 10-12 percent of the
U.S. population including both rural and urban residents.
Cancer cases from the appropriate age group will be
interviewed via telephone and their Vietnam experience
compared to that of age matched controls selected from the
same communities by random digit dialing.

�-3-

The questionnaire for this study has been reviewed and
cleared by the OMB. Data collection begin in 1985 and the
names of identified Vietnam veterans are submitted to the
Army and Joint Services Environmental Support Group for
records review and assignment of an "Exposure Opportunity
Index".
This study should provide a good estimate of
whether service in Vietnam and/or at least minimal exposure
to Agent Orange is associated with an increased risk for
Soft Tissue Sarcomas, Non-Hodgkins Lymphoma and certain
other cancers 15 to 20 years later.

�CDC - Birth Defects Study
The CDC Birth Defects Study was a Case-Control Study
designed to determine if the fathers of babies with major birth
defects were more likely to have served in Vietnam than fathers
of healthy babies.
The study was conducted among all
identified severely affected cases from a population based
Birth Defect Registry in the Atlanta, Georgia, metropolitan
area and included almost 5000 major defects and 3000 normal
babies born in the same hospitals at nearly the same time.
Results of this study indicated that the risk for having a
major birth defected child, diagnosed up to the first year, was
no greater for Vietnam veterans than for other veterans, or for
other men in general. In addition, there was no statistically
significant increase in the relative risk for a Vietnam veteran
fathering a baby with any individual type or group of defects
compared to other men.
In addition to measuring the risks associated with the
Vietnam experience per se, the investigators at CDC worked with
the Department of Defense Army Agent Orange Task Force in
assigning some measure of the likelihood for an opportunity for
exposure to Agent Orange for as many Vietnam veterans as had
available information. Two such indices (EOI) were created
which were similar, but not identical. The analyses reported
by CDC using these indices .indicated an increased risk for
fathering babies with three different defects with increasing
opportunities for exposure on at least one of the indices. The
three defects were spina bifida, cleft lip with or without
cleft palate, and a group of neonatal neoplasms. Whether these
findings are the result of chance occurrence when multiple comparisons are made, which is highly probable, cannot be
determined with certainty. It is also quite possible that the
indices themselves were sufficiently inaccurate as to render
them uninterpretable, particularly since they were in the
developmental stage at the time. It is not possible to make a
definitive evaluation of these findings at this time.
At the suggestion of Congress, and as a matter of appropriate public interest, the Science Panel, through its Research
Agenda
Subpanel,
is
preparing
a
statement
on
the
state-of-the-art of Reproductive Outcome research on the
offspring of Vietnam veterans fathers. The purpose of this
report will be to develop a research agenda of further research
which needs to be done on this issue.

�Soft Tissue Sarcoma - International Studies
The Science Panel reviewed international studies of the
possible
association
between
exposure to phenoxy acid
herbicides and their contaminants and soft-tissue sarcomas. It
was determined that these studies were inconclusive, that it
would not be useful to engage in further in depth analysis of
the already published data and that there are several studies
currently underway that should enable a more definitive
assessment of the possible association between soft tissue
sarcoma and other cancers and exposure to phenoxy herbicides
and contaminants to be made in the next several years.

�NATIONAL CANCER INSTITUTE - CASE-CONTROL STUDY OF SOFT TISSUE
SARCOMAS AND LYMPHQNAS AND THEIR RELATIONSHIP TO HERBICIDE
APPLICATORS IN KANSAS

The purpose of the Case-Control Study of these two cancers
is to determine, by interview, whether cases of Soft Tissue
Sarcoma
and/or Lymphoma are more likely
to have been
occupationally
exposed
to
phenoxy
acid
herbicides
and
contaminants than a matched comparison group.
Cases were
obtained from a population based tumor registry covering the
whole state of Kansas and controls were matched for age, sex,
race and residential area of the state. Kansas was chosen as a
site for this study because, in addition to the existence of a
tumor registry, the agricultural practices in Kansas wheat
growing areas have included considerable application of 2,4,5-T
without other concomittant pesticide use.
The Science Panel reviewed the original protocol for this
study which is nearing completion under contract to the National
Cancer Institute. The Science Panel is particularly interested
in the outcome of this study since it should be useful in
evaluating the possible associations between certain cancers and
herbicide exposures which have been suggested from several
studies conducted in Sweden.
National Cancer Institute - Study of Soft Tissue Sarcomas and
Non-Hodgkins Lymp"homa in Thirteen counties in Washington State
The Batelle Corporation, under grant from the NCI, is
conducting a study of Soft Tissue Sarcoma and Non-Hodgkins
Lymphoma in the 13 county area around Seattle, Washington which
is covered by a population based Tumor Registry. The study will
interview in depth for occupational exposure, residential
history and home use of herbicides, especially 2,4,5-T. It is
intended to verify such use from employment records, reported to
be available in this region where much 2,4,5-T has been used. A
comparison of the amount and rate of exposure of cancer cases
will be made to a comparison group, the nature of which is
unknown (to us) at present.
The Science Panel reviewed a very early version of this
proposal in 1981, but was not involved in the formal review
process. The Science Panel is interested in the outcome of this
study since it should help in further evaluating the
relationship between certain cancers and exposure to dioxin
contaiminated herbicides.

�AIR FORCE RANCH HAND STUDY

The purpose of the Ranch Hand Study is to determine whether
the 1247 Air Force personnel who were involved in the spraying
of Agent Orange (and other herbicides) in Vietnam were more
likely to suffer ill health than a comparable group of Air Force
personnel who were not involved in herbicide spraying activities.
The aerial spraying of herbicide in Vietnam was code named
Operation Ranch Hand and thus all of the Air Force personnel
involved in the loading, operating and maintaining of the C123
Aircraft used in this operation were termed Ranch Handers. The
comparison group consists of Air Force personnel who operated
and maintained C130 aircraft in Southeast Asia and who were not
involved in herbicide activities. The comparisons are matched
to the Ranch Handers by age, race and military rank and
specialty.
The study will include comparing mortality from
various causes between the Ranch Handers and the comparisons
(since their service in Southeast Asia) with annual updates
every year. It will also include comparing morbidity between
the two groups based on an initial telephone interview and an
extensive physical, laboratory and psychological examination
every 3 to 5 years. The study is intended to continue for 20
years from 1981.
The Science Panel originally reviewed the protocol for the
Ranch Hand Study in 1981. The study is of particular interest
since the Air Force estimated at that time that many of the
Ranch Hand personnel were exposed to Agent Orange at a rate 1000
times greater than almost any of the rest of the Armed Forces in
Vietnam. The first Baseline Mortality Results from this study,
published in 1983, indicated virtually no difference in
mortality between the Ranch Handers and their comparisons
through 1982. The Science Panel reviewed this report in the
light of a critique which had been prepared by the Vietnam
Veterans of America and suggested that a lay-language version of
the report would be easier to understand than the rather
detailed version which was released. The second interim report
is scheduled for release in the very near future and is
currently under review by the Advisory Committee for Special
Studies.
Data collected during the interview and the first examination were released as the Baseline Morbidity Results in early
1984. The most interesting findings from this report included:
1.

an increase in non-melanoma skin cancer among Ranch
Handers. This finding will be further studied at the
second examination to determine if exposure to
sunlight has played a significant role since
exposure to solar radiation is the acknowledged
primary cause of skin cancer in the U.S.;

�there was a significant increase in abnormal pulses of
the extremities among the Ranch Handers. This will be
further explored during the second examination since
it is poorly understood and currently has no direct
health related consequences; and
an increased number of minor birth defects (mostly
birth marks) neonatal deaths and physical handicaps to
children were reported by Ranch Hand parents than by
comparisons.
Each of these is currently being
verified through the compilation of appropriate
medical and vital records for all study subjects as
requested by the Agent Orange Working Group.
A
progress report on this should be available imminently.

�PROPOSED STUDIES OF INTEREST TO THE SCIENCE PANEL

Female Veterans Study
The Science Panel reviewed a proposal to study female
Vietnam veterans which had been prepared by CDC. The proposed
study would
interview all, and examine
2000, of the
approximately 7000 female veterans who served in Vietnam, who
can be located, and who agree to participate. The Science Panel
feels that, even though the study appears logistically feasible,
it may not be the most efficient nor appropriate design to test
possible adverse health effects among female Vietnam veterans.
The Panel recommends that specific hypotheses relating Vietnam
exposures and adverse health effects among female veterans be
formulated, and then a suitable research design developed and
evaluated.
Veterans Administration - Twin Study
A concept proposal for a study of identical twins - one of
whom served in Vietnam and one of whom did not - was reviewed
and approved by the Science Panel in 1982. The purpose of the
study would be to compare physical and psychological health of
the two members of an extremely closely matched pair of subjects
who differed in their exposure to the Vietnam Experience including possible exposure to Agent .Orange.
The final
protocols for this study has subsequently been fully developed
and we understand is currently under review.

�THE STATE OF AGENT ORANGE RELATED RESEARCH
IN THE FEDERAL GOVERNMENT
The FY 1985 Report of the Science Panel of the
Cabinet Council Agent Orange Working Group
September 1985

�The State of Agent Orange Related Research
in the Federal Government
The PY 1985 Report of the Science Panel of the
Cabinet Council Agent Orange Working Group
OUTLINE
EXECUTIVE SUMMARY

I.

Introduction

II. Brief History of the Agent Orange Working Group (AOWG)
III. Rationale for the Research Efforts Commencing in 1980
A. What was known

1. Effects in animals
2. Effects in humans
B. What was not known

1. Effects in animals
2. Effects in humans
3. Information management
IV.

Federal Research Related to Agent Orange: 1981-1987
A. Effects in animals

B. Effects in humans
C. Other
1. Information management
2. Environmental fate and transport
3. Monitoring
4. Risk assessment
V.

Evaluation

VI.

Future Directions

APPENDIX A —

Membership of AOWG

APPENDIX B -- Project-by-project listing of agency AO-related
research efforts
APPENDIX C —

Agency summary statements of AO-related research
efforts

�HHS A.O./DIOXIN EXPENDITURES
$22,5O.3,OOO TOTAL EXPENDITURES

ANALYT (2.5%) §556,000

HUMAN (41 .1%)
$9,244,000
ANIMAL (56.5%)
$12,703,000

\
\

�DOD A.O./DIOXIM EXPENDITURES
$33,605,500 TOTAL EXPBJDITUKES

ANIMAL (O.9%) $288,000

\

\.

HUMAN (99.1%)

$33,317,500

�USDA A.O./DIOXIN EXPENDITURES
$594,OOO TOTAL EXPENDITURES

LIT (10.8%)
$64,000
x.

\

\
\

\

HUMAN (89.2%)
$530,000

�EPA A.O./DIOXIN EXPENDITURES
$14,467,000 TOTAL EXPENDITURES

$2,146,000
ANIMAL (14.8%)

LIT (7.3%) /
$1,052,000
/

ANALYT (12.5%)
$1,812,000

HUMAN (O.C.%)
$75,000

\

\

I

/ ENVIR (64,9%)
'' $9,382,000

�A.O./DIOXIN EXPENDITURES
$81 ,286,000 TOTAL EXPENDITURES

$774,000

(O.i

$4 , 385 , 000

1

\
&lt;,
!

\

\

(£H.O%) $76,127,000

�APPENDIX C
AGENCY SUMMARY STATEMENT OF AO-RELATED RESEARCH EFFORTS

�ENVIRONMENTAL PROTECTION AGENCY
Research Program Associated with
Chlorinated Dibenzo-p-dioxins (CDDs) and Dibenzofurans (CDFs)
The US Environmental Protection Agency (EPA) has been concerned
with CDDs/CDFs, particularly 2,3,7,8-TCDD, since the early 1970s.
Much of the early work was related to 2,3,7,8-TCDD as a contaminant
in the herbicde 2,4,5-T and included analytical methods development
and its application to monitoring data.
While the Agency's research work with humans has been limited,
it has been important. In the late 1970s, a controversial
epidemiological study triggered immediate regulatory action by
the Agency. During the same period, the Agency conducted an
investigation of 2,3,7,8-TCDD in the human milk of mothers living
in areas in which 2,4,5-T had been used. No confirmed positive
residues were detected in any of 100 samples. The Agency has
detected trace amounts of 2,3,7,8-TCDD in some human adipose
tissue samples. Ongoing collaborative efforts with the Veterans
Administration is aimed at analyzing samples of human adipose
tissue collected during the 1970s to determine whether or not
Vietnam service personnel have greater residues of 2,3,7,8-TCDD
than do a comparable group of individuals who did not go to
Vietnam. In addition, EPA has conducted assessments of the
potential human risks associated with exposure to 2,3,7,8-TCDD
and some of the other CDDs/CDFs. These "ballpark" risk estimates
have been useful in .reaching regulatory decisions.
During the 1980s, the EPA research program for CDDs/CDFs has
focused on environmental and risk management concerns. Specifically,
Congress directed the Agency of conduct a National Dioxin Study,
the aim of which is the investigation of potential "hot spots"
across the country and the determination of background levels, if
any, of 2,3,7,8-TCDD in the environment. This current effort
builds on more limited, but more focused, Agency efforts searching
for 2,3,7,8-TCDD in envivonmental samples. In an attempt to
conduct such investigations more quickly and inexpensively, the
Agency has sponsored research to develop new methods of analysis
of CDDs/CDFs. In order to better understand the significance of
reports of CDDs/CDFs in the environment, EPA is conducting studies
in the environmental transport and fate of these compounds, with
a particular emphasis on the bioavailability and possible movement
into the human food chain. Large-scale combustion is under
special investigation as a possible source of CDDs/CDFs in the
environment.
A major thrust of recent EPA efforts has been in the direction
•of controlling, managing, and/or destroying CDDs/CDFs once they
are found in the environment. Methods have been found which
successfully destroy 2,3,7,8-TCDD in contaminated soil and liquids.
Procedures are being developed to minimize the emission of
CDDs/CDFs from combustion sources.

�VA/AFIP Soft Tissue Sarcoma Study
The possibility that exposure to phenoxy herbicides may induce rare
forms of cancer in humans such as soft tissue sarcoma (STS) has been
suggested from recent studies in Sweden. Subsequently, there is
much concern in the United States that many veterans who served in
Vietnam might have had a significant exposure to the phenoxy
herbicides including Agent Orange and, therefore, might be at
increased risk of developing STS.
In view of the concern raised by many veterans and conflicting
findings in the scientific literature, the VA, in collaboration with
the Armed Forces Institute of Pathology (AFIP), is conducting a case
control study in which 250 individuals with STS are compared with
750 individuals without STS with respect to Vietnam service,
probable Agent Orange exposure and other host and environmental
risk factors.
The study is conducted in two phases. Phase I of the study will
investigate whether service in Vietnam during 1965-1971 increased
the risk of developing STS. Military service information, in
particular Vietnam service status, for each case and control
patients will be obtained from a review of the patient's military
personnel records archived at the National Personnel Records Center
in St. louis, Missouri!.
Phase II of the study will investigate other host and environmental
risk factors for the development of STS based on information
obtained from telephone interviews with the subjects or their
next-of-kin. Information on risk factors such as occupational and
non-occupational exposure to pnenoxy herbicides, ionizing radiation
asbestos, arsenic, vinyl chloride, and genetic synodromes will be
obtained from the interviews and analyzed individually and jointly
with respect to the risk of developing STS.
As of July, 1985, 58% of the study subjects (616/1,066) have been
located and have completed the telephone interview. Data collection
will be completed by March, 1986 and the final report is expected in
late 1986.

�VA Mortality Study
The Vietnam Veterans Mortality Study is designed to assess
mortality patterns of U.S. servicemen in the Army or Marines who
served during a portion of the Vietnam era. A sample of 75,000
veterans deaths has been selected from the ^ BIRLS files. For each
of the deaths, military service and cause of death information are
being collected and coded. The two types of data will be merged and
analyzed to compare the mortality experience of veterans who served
in Vietnam with veterans of the same era who did not serve in
Vietnam. Various analytical approaches are planned including
classical proportionate mortality ratio (PMR) analyses as well as
categorical data analyses.
As of August 1985 the military records search and abstracting have
been completed for 98% of total cohort of 75,000. Ninety nine
percent of the expected 72,000 death records have been received.
However, about 15% of the records received did not include the cause
of death information. Extensive tracing efforts have been made
using both internal records and records maintained by other
government agencies for all veterans whose VA claims folders lacked
the cause of death information.
Completeness, accuracy and consistency of data on numerous variables
(e.g., age, race, year, of death, cause of death, branch of service,
rank, MOSC, years of active duty, separation year, length of service
in Vietnam, industry, occupation) are being checked in preparation
for analysis. The final report is expected in late 1985.

�Alternate Methods for Assigning Agent Orange
Exposure Status to Vietnam Veterans Exposure
Opportunity Index (EOlT
Some time ago the Joint Services Environmental Support
Group (then the Army Agent Orange last Force (AAOTF) began to
develop methods to estimate potential exposure to Agent Orange
among Vietnam veterans. The method to be used in the proposed
Agent Orange Morbidity and Mortality Studies currently underway
by CDC involves detailed day-by-day tracking of both military
units and individuals while in Vietnam. Amassing the information necessary to do this requires considerable effort and
yields simultaneous information on all of the members of a given
military unit. The method is thus suitable for identifying
cohorts, but is extremely inefficient for determining potential
exposures of individuals selected by other means. Furthermore,
the necessary records apparently do not exist for many units in
Vietnam, particularly non^Army units, and is the major reason
why the CDC Epidemiological studies are confined to veterans of
the Army.
In order to obtain some information on the possible
exposure to Agent Orange of veterans identified through other
sources, an alternative method was proposed by the AAOTF.
The Science Panel was briefed on, and reviewed in depth
the alternative procedures^ for assigning Exposure Opportunity
Indices (EOI) to Vietnam veterans. These procedures are based
on the place, time and job specialty of veterans while in
Vietnam as indicated in personnel records, military unit
quarterly reports and herbicide application records from
Vietnam. The method was proposed by the Department of Defense,
and was developed by the Army and Joint Services Environmental
Support Group in conjunction with the investigators of the CDC
Birth Defects Study. Even though the alternative method is
somewhat subjective and confounds combat status with exposure to
herbicide, all of the members of the Science Panel agree that
the method as developed, can provide an individual estimate of
the relative likelihood for at least some exposure to Agent
Orange while in Vietnam. Attempts to establish whether such
exposures are capable of compromising health status is the
business of ongoing health and mortality studies.

�AGENT ORANGE LITIGATION

In 1979, a class action was commenced in the United States
District Court, Eastern District of New York, charging the
United States and a major portion of the chemical industry with
deaths and injuries to tens of thousands of Vietnam veterans who
came in contact with herbicides used in the war in Southeast
Asia. The suit also claimed that as a result of the veterans'
exposure, their children suffer severe birth defects.
After
five years of numerous motions and extensive discovery, a
settlement amount of $180,000,000 was negotiated between the
plaintiff-veterans and the defendants-manufacturers and approved
by Chief Judge Jack B. Weinstein on June 11, 1984.
Following this settlement, a $10 billion class action was
filed against the United States on behalf of the servicemen,
their wives and children. The class action alleged, among other
things, failure to warn, and pre-induction, in-service, and
post-discharge negligence. At the same time, the defendants
expressed their intention to press third-party contribution and
indemnity claims against the United States, to recover all costs
associated with their defense of the litiga* tion, including the
amount of the settlement.
The United States moved to dismiss the p l a i n t i f f s ' class
action and, on December 10, 1984 Judge Weinstein denied class
certification and dismissed all claims brought by the servicemen. The Court also found that there is no credible medical or
scientific evidence supporting claims of male-mediated birth
defects or miscarriages, but reserved final judgment on these
claims for ninety-days.
The United States will also seek
dismissal of all thirds-party claims pending against it.
Judge Weinstein has established a 28 member advisory board
to advise the Court on how the settlement trust fund proceeds
might be best utilized. The Justice Department has refused to
allow federal personnel to participate in any way in the
settlement process. Judge Weinstein has reserved final approval
of the settlement pending review of the settlement distribution
plan and resolution of all counsel fee disputes.

�.Veterans Administration Advisory Committee
On Environmental Hazards
The
Veterans
Administration
Advisory
Committee
on
Environmental Hazards and its Scientific Council were created by
the Veterans' Dioxin and Radiation
Exposure Compensation
Standards Act, P.L. 98*542, enacted on October 24, 1984. The
functions of this Committee and its Council are not perceived to
encroach on, or duplicate the efforts of the Agent Orange
Working Group (AOWG).
The Veterans
Administration
Advisory
Committee
is
distinguished from the Agent Orange Working Group in that the
Agent Orange Working Group is solely concerned with risk
assessment and the Veterans Administration Advisory Committee
and its Scientific Council are concerned with risk management.
P.L.
98*542 .requires,
inter
alia,
that
the VA
Administrator prescribe regulations on adjudicating claims based
on dioxin
and radiation exposure
after
considering
the
recommendations of an advisory committee and its
scientific
council.
The Advisory Committee on Environmental Hazards created by
the Act icons is ts of fifteen/, members appointed by the VA
Administrator. Eleven of these, of whom none may be from the
Armed Forces, the VA, or Defense and not more than three may be
federal employees, are appointed in consultation with the
Director, NIH. These members must include three authorities on
dioxin, three on ionizing radiation, and five on epidemiology or
a related field.
These eleven members also constitute the
Scientific Council of the Committee.
The Council is divided
into two eight member panels which will, respectively, evaluate
studies on dioxin and radiation exposure.
The Scientific
Council reports to the Committee and to the Administrator
directly.
The balance of the Committee is
made up of four
individuals from the general public with special concerns
regarding exposure to dioxin or radiation. The Chief Medical
Officer and Chief Benefits Director of the VA are ex officio
members.

�SENATE VETERAN AFFAIRS COMMITTEE
99TH

Republicans

CONGRESS

Democrats

Sen. Frank H. Murkowski, (R-AK)
Chairman

Sen.
Sen.
Sen.
Sen.
Sen.
Sen.

Alan K. Simpson, (R-WY)
Rudy Boschwitz, (R-MN)
Robert T. Stafford (R-VT)
Arlen Specter (R-PA)
Jeremiah Denton (R-AL)
Strom Thurmond (R-SC)

Sen. Dennis DeConcini (D-AZ)

Sen. Alan Cranston (D-CA)
Sen. Jay Rockefeller (D-WV)
Sen. George J. Mitchell (D-ME)

Sen. Spark M. Matsunaga (D-HI)

�COMMITTEE MEMBERS AND STAFF

VETERANS' AFFAIRS

COMMITTEE ON VETERANS AFFAIRS
SR-414

224-9126

Frank H. Murfcowski, Alaska, Chairman.
Alan Cranston, Calif.
Spark M. Matsunaga, Hawaii
Dennis DeConcini, Ariz.
George J. Mitchell, Maine
John O. Rockefeller, IV, W. Va.

Alan K. Simpson, Wyo.
Strom Thurmond, S.C.
Robert T. Stafford, Vt.
Aden Specter, Pa.
Jeremiah Oenton, Ala.
Rudy Boschwitz, Minn.
STAFF MCMWMS

Alpert Cynthia PROF ST M SR-420A
Alvarado, Tina RECP SR-414
Billica. Nancy MIN RES ASST SH-202
Boertlein, Judy ST ASST SR-412
Brew, William MIN COUN sn-202
Eckhardt, Kay ST ASST SR-420
Hocks, Becky CHF CLK/LEQISLATIVE CLK SR-«i2
Hughes, Charlotte MIN CASEWKR SH-202
Maraz, Stacy ST ASST SR-420
McTighe, Cathy COUN SR-420A
Moore, Jim PRESS ASST SR&gt;420A

46210
49130
40576
46213
40767
49132
46236
44112
40206
46266
44921

Moore, Lisa RES ASST SR-420A
Phinney, Al COUN SR-420
Polzer, Babette MIN PROF ST SH-202
Post, Ingrid MIN CHF cut SH-202
Principi, Anthony J CHF COUN/ST OIR SR~*IO
Schratwieser, Hugh PROF ST M SR-420

46230
47636
4677S
46204
49126
46263

Scott, Ed MIN QEN COUN SH-202

46262

Steinberg, Jon MIN CHF COUN/ST OIR SH-202
46202
Susman, Julie OPTY ST OIR/LEQ OIR/OPTY CHF COUN
SR-414

Yoder, Chris PROF ST M SR*420

(No Subcommittees)

46293

46212

�CHAIRMAN
COMMITTEE ON VETERANS' AFFAIRS

SIN. "RANK H. MURKOWSKI (R AK)
Committaa on Enargy &amp; Natural Raaooreaa
Subeommmaa on Enargy &amp; Minaral
Raaourcas
Subeommmaa on Enargy Ragulation,

Chairman

Subeommmaa on Watar &amp; Powar
Commfttaa on Foraign Ratetiona
Subeommmaa,on Eaat Asian &amp; Paeifie
Affair*. Chairman
Sutcommmaa on International Economtc
Policy
Subeommmaa on Waatam Hamiapnara
Affatrt
S«n. Frank H. Murkow*ki Commrttaa on Vatarana' Affaira
Salact Commrttaa on Indian Affaira
of Fairbanks
Republican—Jan. 3, 1981

�ASSISTANT MAJORITY LEADER

Sea. Alan K. Slmpwa
of Cody
Republican—Jtn. I, 1979

SIN. ALAN K. SIMMON (ft WV)
Committal on invfronmem &gt; PufcOc Worto
Subcommittee on Environmental Pollution
Subeommmaa on Nudaar Regulation.
Chamnan
Subcommmaa on Toxic Subatancaa &amp;
Environmantal Oversight
CommHta* on Th« Judietafy
Subcommmaa on Courts
Subcommittee on immigration &amp; Refugee
PoHcy. Chairman
Subcommittee on Seoaration of Powers
Committee on Veteran*' Affairs. Chairman

�HOUSE VETERANS AFFAIRS COMMITTEE
99TH CONGRESS

Republicans

Democrats

G.V. (Sonny) Montgomery, Miss.
Chairman
Don Edwards, (D-Calif)
Bob Edgar, (D-Pa)
Sam B. Hall, Jr., (D-Tex)
Douglas Applegate, (D-Ohio)
Richard C. Shelby, (D-Ala)
Dan Mica, (D-Fla)
Thomas A. Daschle, (D-S.Dak)
Wayne Dowdy, ((D-Miss)
Lane Evans, (D-I11)
Marcy Kaptur, (D-Ohio)
Alan B. Moliohan, (D-W.Va.)
Timothy J. Penny, (D-Minn)
Harley 0* Staggers, Jr. (D-W.Va)
J. Roy Rowland, (D-Ga)
John Bryant, (D-Tex)
James J. Florio, (D-N.J.)
Kenneth J. Gray, (D-lll)
Paul E. Kanjorski, (D-Pa)
Tommy F. Robinson, (D-Ark)

John Paul Hammerschmidt, (R-Ark)
Chalmers P. Wylie, (R-Ohio)
Elwood Hillis, (R-Ind)
Gerald B.H. Solomon, (R-N.Y.)
Bob McEwen, (R-Ohio)
Christopher H. Smith, (R-N.J.)
Dan Burton, (R-Ind)
Don Sundquist, (R-Tenn)
uon ounuquisc, (,&amp;.Michael Bilirakis, (R-Fla)
Bilirakis,
Nancy Lee Johnson, Vi. w~
Guy V. Molinari, (R-N.Y.
Thomas J. Ridge, (R-Pa)
Bill Hendon, (R-N.C.)
John G» Rowland, (R-Conn

�COMMITTEE MEMBERS AND STAFF

VETERAMS AFFA(RS

COMMITTEE ON VETERANS' AFFAIRS
335 CANNON HOB

225-3527

G. V. (Sonny) Montgomery, Miss.. Chairman

Don Edwards, Calif.
Bob Edgar, Pa.
Sam B. Hall. Jr.. Tex.
Douglas Applegate, Ohio
Richard C. Shelby, Ala.
Dan Mica. Fla.
Thomas A. Daschle. S. Oak.

John Paul Hammerschmiat. Ark.
Chalmers P. Wylie. Ohio
Elwood Hillis. Ind.
Gerald B. H. Solomon, N.Y.
Bob McEwen, Ohio
Christopher H, Smith, N.J.
Dan Burton, Ind.
Don Sundquist, Tenn.
Michael BUirakis, Fla.
Nancy Lee Johnson, Conn.
GuyV. Molinari, N.Y.
Thomas J. Ridge, Pa.
Bill Hendon, N.C.
John G. Rowland, Conn.

Wayne Dowdy, Miss.
Lane Evans. III.
Marcy Kaptur, Ohio
Alan B. Mollohan, W. Va.
Timothy J. Penny. Minn.
Hartey O. Staggers, Jr., W. Va.
J. Roy Rowland, Ga.
John Bryant. Tex.

James J. Florio, N.J.
Kenneth J. Gray. III.
Paul E. Kaniorski, Pa.
Tommy F. Robinson, Ark.
MAJORITY STAFF

Burtey. Suzy FILE CLK 335
Burnett, Aden* AOMIN ASST 335
Cochran, JHl PROF STF MEM EDUC. TRAIN, EMPLOY 335
Daw*. Barbara STF ASST HOSP, HEALTHCARE 33a
Evans, Semmes STF ASST 337
Fleming. Mack CHF COUN &amp; STF OIR 33S
Frone. Stanley STF ASST 335

53527
59165
53527
59154
59164
53527
53527

Grant, Bob PRTG CLK 33S
i
Holley, Jim PROF STF MEM PUB AFRS 337
Kitker, Beth STF ASST EDUC. TRAIN, EMPLOY 335
MeOermott. Mary FIN CLK 335

53535
53664
59112
59557

Moon. Arnold COUN COMPCNS. PENS. INS 337
Parker. Pam STF ASST OVERSIGHT a INVEST 33S
Raymond. Vic PROF STF MEM 338
Richardson. Jean STF ASST COMPCNS. PENS, INS 337..
Royce, Gloria PROF STF MEM HOUS &amp; MEMORIAL AFRS
337

53569
59044
59154
53569

Ryan, Patrick COUN 335
Shultz, Richard COUN OVERSIGHT &amp; INVEST 335
Sniffen, Candis Lee LEGIS ASST 335
Tippett, Patricia RECEPT 335

59154
53541
S3S27
53527

53664

McOonell. Jack PROF STF MEM HOSP, HEALTH CARE
338
:... 59154
MINORITY STAFF

Brandes. Sharon A PROF STF MEM 333A
Oonohue, Patricia AOMIN ASST 333
Forrest. Sue STF ASST 333A

59756
53551
59756

Smith, Kingston OPTY COUN 4 STF OIR 333A
Wilson, Rutus COUN &amp; STF OIR 333

S97S6
53551

SUBCOMMITTEE STAFF

CaWweii, Anne PROF STF MEM, HOUS &amp; MEMORIAL
AFRS 2443
52665
Dunshm, Michael PROF STF MEM, EDUC, TRAIN.
EMPLOY 2465
52901
Fuller. Richard PROF STF MEM, HOSP. HEALTH CARS
3362
52011

Gallion, Edward MIN PROF STF MEM. COMPENS. PENS.
INS 2342

55614

Sechrist. Timothy PROF STF MEM. COMPENS. PENS, INS
2464
56265

251

�VETERANS AFFAIRS

U.S. HOUSE OF REPRESENTATIVES
SUBCOMMITTEE ON OVERSIGHT AND INVESTIGATIONS
335 CANNON HOB

225-3541

G. V. (Sonny) Montgomery, Miss., Chairman
Elwood Hillis, Ind.
Dan Burton, Ind.
Don Sundquist, Tenn.
Nancy Lee Johnson. Conn.
Thomas J. Ridge, Pa.

Don Edwards, Calif.
Kenneth J. Gray, III.
Sam B, Hall, Jr., Tex.
Timothy J. Penny, Minn.
J. Roy Rowland, Ga.
Tommy F. Robinson, Ark.
MAJORITY STAFF.

53541

MINORITY STAFF..

59756

SUBCOMMITTEE ON HOSPITALS AND HEALTH CARE
338 CANNON HOB

225-9154

Bob Edgar, Pa., Chairman
Dan Mica, Fla.
Wayne Dowdy, Miss.
Lane Evans, III.
Marcy Kaptur, Ohio
Alan B. Mollohan, W. Va.
Timothy J. Penny, Minn.
Harley O. Staggers, Jr., W. Va.
J. Roy Rowland, Ga.
John Bryant, Tex.
James J. Florio, N.J.
!vPaul E. Kanjorski, Pa.
Tommy F. Robinson, Ark.
Richard C. Shelby, Ala.
Thomas A. Daschle, S. Dak.

John Paul Hammerschmidt, Ark.
Elwood Hillis, Ind.
Gerald B. H. Solomon. N.Y.
Bob McEwen, Ohio
Christopher H. Smith, N.J.
Michael Bilirakis, Fla.
Nancy Lee Johnson, Conn.
Guy V. Molinari, N.Y.
Thomas J. Ridge, Pa.
Bill Hendon, N.C,
John G. Rowland, Conn.

MAJORITY STAFF.

59154

MINORITY STAFF..

59756

SUBCOMMITTEE ON COMPENSATION, PENSION, AND INSURANCE
337 CANNON HOB

225-3569

Douglas Applegate, Ohio, Chairman
Sam B. Hall, Jr., Tex.
G. V. (Sonny) Montgomery, Miss.
Dan Mica. Fla.
Wayne Dowdy, Miss.
Lane Evans, III.
Tommy F. Robinson, Ark.

Gerald B. H. Solomon. N.Y.
Chalmers P. Wylie. Ohio
John Paul Hammerschmidt, Ark.
Dan Burton, Ind.
Guy V. Molinari, N.Y.

MAJORITY STAFF....

53569

MINORITY STAFF....

59756

252

�COMMITTEE MEMBERS AND STAFF

VETERANS AFFAIRS

SUBCOMMITTEE ON EDUCATION, TRAINING AND EMPLOYMENT
335 CANNON HOB

225-9166

Thomas A. Daschle, S. Oak., Chairman
Lane Evans, III.
Marcy Kaptur, Ohio
John Bryant, Tex.
James J. Florio, N.J.
Kenneth J. Gray, III.

Bob McEwen. Ohio
Chalmers P. Wylie, Ohio
Gerald 8. H. Solomon, N.Y.
BUI Hendon. N.C.

MAJORITY STAFF

59166

MINORITY STAFF

59756

SUBCOMMITTEE ON HOUSING AND MEMORIAL AFFAIRS
337 CANNON HOB

225-9164

Richard C. Shelby, Ala., Chairman
Bob Edgar, Pa.
Douglas Applegate, Ohio
Alan B. Mollohan, W. Va.
John Bryant, Tex.
James J. Florio, N.Y.

Christopher H. Smith, N.J.
Don Sundquist, Tenn.
Michael Bilirakis, Fla.
John G. Rowland, Conn.

MAJORITY STAFF

59164

MINORITY STAFF

59756

�(AH S9iun|OA) - L - ON

SUJXOIQ peiepossv
pue seppjqjGH
Axoueqj uo ejniejejn

om»uep.s ^o s.isdouAs
sueeie

�VA CONTRACT NO: V101(93)P-953

C(
SYNOPSIS OF SCIENTIFIC
LITERATURE ON PHENOXY HERBICIDES
AND ASSOCIATED DIOXINS

Prepared for Contracting Officer's Technical Representative:
Barclay M. Shepard, M.D.
Director, Agent Orange Projects Office
Department of Medicine and Surgery
Veterans Administration
810 Vermont Avenue, N.W.
Washington, D.C. 20420

c o
Submitted by:
Clement Associates, Inc.
1515 Wilson Boulevard
Arlington, Virginia 22209

�PREFACE
In October 1981, the Veterans Administration published the first two volumes of a comprehensive report entitled Review of Literature on Herbicides, Including Phenoxy Herbicides
and Associated Dioxins. A continuation of this important effort resulted in the preparation
and publication in April 1984 of volumes III and IV. At this point it was thought that a summary in layman's terms, with emphasis on health effects would be helpful to the general
public's understanding of the complex and often controversial issue of Agent Orange. Consequently this summary has been prepared to fill that need. It should be noted that this synopsis
includes only that body of scientific literature published through December 1983, and
therefore does not include the results of more recent research such as the study of birth defects
conducted by the Centers for Disease Control and published in August 1984. Also not included is
the mortality study of Australian Vietnam-era veterans published in September 1984. The
results of these and other more recent repons will be summarized in a similar synopsis currently being developed by the VA for publication in the near future. It is hoped that these laylanguage summaries will serve as useful supplements for assisting non-technically oriented
readers in understanding both the significance and impact of such literature and thereby assist
in the ultimate resolution of the many and varied issues related to the phenoxy herbicides and
associated dioxins.

Agent Orange Projects Office
Veterans Administration
Washington, D.C.
1985

�CONTENTS
Page
Preface
1. Introduction

1

2. What is Agent Orange?

1

3. Who was exposed?

2

4. What do we know about the health effects?

2

5. How do we determine the health effects?

3

6. Summary of the studies on health effects:
Cancer

;

Reproductive effects

6
8

Enzyme effects

10

Effects of the immune system

12

Chloracne

13

Neurobehavioral effects

15

Other toxic effects

16

7. Summary and conclusions

17

�1. Introduction

For the past several years the Veterans Administration, in response to the concerns of
veterans who served in the war in Vietnam, has been conducting or sponsoring research on the
health effects of Agent Orange, the principal herbicide used by U.S. military forces in that
country and to which some American military personnel were exposed.
In April 1984, under contract to the Veterans Administration, Clement Associates, Inc., a
research firm in Arlington, Virginia, completed a two-volume survey of the extant scientific
literature on the health effects of Agent Orange. The material that follows is a lay summary of
that survey and is published because the Veterans Administration believes that it will be of interest to Vietnam veterans and others who have been following the Agent Orange issue.
2. What is Agent Orange?

"Agent Orange" is a name that has come to be used to describe a particular type of chemical
herbicide that was used in military operations in Vietnam from 1965 to 1971. The name came
from the orange stripe that identified the 55-gallon drums in which the herbicide was shipped
and stored. Agent Orange was not a single chemical compound but rather a mixture of
chemicals containing equal amounts of the two active ingredients, 2,4-D and 2,4,5-T. These
weed-killing chemicals enjoyed extensive commercial and private use in the United States and
in many countries around the world from the 1940s well into the 19705.^ 2,4-D is still used extensively in this country and abroad.
Like many industrial chemical mixtures, the Agent Orange that was manufactured during
the Vietnam era contained small quantities of impurities. These impurities included chemicals
used in the production of 2,4-D and 2,4,5-T as well as by-products which developed during
the manufacturing process. Some of the impurities were a family of closely related compounds
known as polychlorinated dibenzodioxins which, as a group, have often been called
"dioxins."
One of these dioxins, 2,3,7,8-tetrachlorodibenzo-p-dioxin or TCDD, has been extensively
tested in experimental animals and is believed to be the most toxic member of the dioxin family.
TCDD is one of the contaminating dioxins in 2,4,5-T. In the remainder of this report the term
dioxin will be used to refer to any of a number of different polychlorinated dibenzodioxins,
usually unidentified. The term TCDD will be used to designate the specific chemical
2,3,7,8-tetrachlorodibenzo-p-dioxin.
Agent Orange was produced by several manufacturers in a number of chemical plants
throughout the United States under contract to the Department of Defense, which specified
the composition of the herbicide. Therefore the nature and amount of the active ingredients
were the same regardless of the manufacturer. Although Defense Department specifications
set an upper limit on the total amount of impurities that could be present in a batch of Agent
Orange, it is certain that both the exact amount and the nature of these impurities varied from
batch to batch, from year to year, and from manufacturer to manufacturer. Furthermore,
since very little attention was paid to the importance of the impurities in Agent Orange until
1

�late in the Vietnam experience, there is relatively little information available on the amount of
the impurities contained in the herbicide shipped to Vietnam.
Agent Orange was somewhat different from commercial formulations of this class of herbicides made and marketed in the United States and in other countries around the world. In
addition, we don't really know precisely all the types and amounts of the impurities that were
present in Agent Orange, and furthermore we don't have any accurate way to find out.
Because there is considerable evidence that the health effects of these herbicide mixtures depend heavily on the amounts and types of impurities such as dioxins which were present in the
mixture, we can accept, only with reservations, information on health effects obtained from
studies of people exposed to other herbicide preparations containing 2,4-D, 2,4,5-T, or both.
If we hope to understand the health effects of Agent Orange with a high degree of certainty, it
is essential to identify and study people who were exposed to Agent Orange.
3. Who was exposed?
The only individuals who are known to have been exposed to Agent Orange are those who
were exposed during its manufacture and distribution or as a result of its use in Vietnam.
Because Agent Orange was considered relatively safe at the time of its use, however, there
were no systematic studies to determine how much Agent Orange might enter a person's
system as a result of exposure in a manufacturing plant, during spraying operations or other
applications, or from entering an area that had already been sprayed.
Another way of determining exposure is to depend on people's memory of when and how
often they might have been exposed. Unfortunately, several different types of chemicals were
manufactured in most of the plants that manufactured Agent Orange. In addition, several
other herbicide mixtures as well as insecticides and other chemicals were used in Vietnam.
It would be very difficult for most individuals to know when they were exposed to Agent
Orange specifically and how much exposure they received. The Air Force did keep records of
most of the aerial herbicide spraying missions. By combining this information with data from
records of the location of military units, the probability of exposure from aircraft spraying can
be estimated. Those people who were actually involved in the handling and application of
Agent Orange were undoubtedly among the most heavily exposed, but it is not possible to
determine accurately the amount to which they were exposed.
4. What do we know about the health effects?
As one might guess from the information above, we don't have precise and direct information on the human health effects of Agent Orange itself. Scientists cannot identify people who
were definitely exposed to known quantities of Agent Orange in order to compare such a
group to people who were not exposed to Agent Orange or similar herbicides. Furthermore,
Agent Orange as such was not tested in experimental animals at the time of its manufacture
and use.

5. How do we determine the health effects?
Since we cannot study the human health effects of Agent Orange directly, we must use other
techniques to learn what health effects might result from exposure to this material. Several
methods are available and all of them have been used during the last 10 or 15 years. Each has
limitations that make it difficult for scientists to reach definitive conclusions about the adverse
human health effects of Agent Orange. Nevertheless, if scientists and health professionals
review the entire body of information that has become available from all these approaches,
certain patterns emerge.
It is now possible to begin reaching tentative conclusions about the health effects of Agent
Orange. However, these conclusions are still somewhat uncertain. The results of studies which
are currently in progress or planned will go a long way toward removing this uncertainty, but, for
the general reasons described above and for specific reasons described below, it is quite likely
that we may never be completely sure of what the health effects of Agent Orange are. This
same uncertainty exists for many environmental health issues and is a result of the normal
limitations of science.
One of the most promising approaches to studying the health effects of Agent Orange is to
evaluate the health of people who may have been exposed to it as a result of the Vietnam experience and to compare their health with that of people who were not exposed to these herbicides. A few such studies have been conducted and several more are in progress. Some of the
limitations of these studies have already been mentioned.
We don't have reliable records of everyone who was exposed, so assumptions are made such
as "any veteran who served in Vietnam was exposed to Agent Orange" (Australian Veterans
Health Study) or "any individual who was assigned to Operation Ranch Hand was heavily exposed to Agent Orange" (U.S. Air Force Epidemiology Study). These assumptions may lead to
the inclusion in the "exposed" group of people who had very little exposure. If enough of these
people are mis-classified as to exposure, scientists will not be able to detect any real health effects that might be present in those who were actually heavily exposed. In other words, the
greater the mis-classification rate, the less reliable are conclusions regarding health effects of
exposure.
Another serious limitation is that it is very difficult to select a group of "unexposed" people
who can be closely matched with the people in the "exposed" group. Ideally, the two groups
should be the same except for their potential exposure to Agent Orange. This means that individuals in both groups should not only be the same in age, weight, and sex, but they should
also have similar smoking habits, diets, jobs, life styles, and places of residence. Another problem inherent in these studies relates to the widespread use in the United States of commercial
herbicides that are similar to Agent Orange. In addition, dioxins are known to be present in
other industrial chemicals in the environment. It is therefore very possible that some individuals in the "unexposed" group have actually been exposed to the ingredients of Agent
Orange at other times and in other places.

�small town of Seveso immediately downwind of the plant. In succeeding weeks many persons
living in Seveso showed signs of dioxin exposure, the most prominent being chloracne, a form
of acne which includes the appearance of blackheads around the eyes and ears and in some
cases covers much of the body.

Another problem with studies of people who were exposed to Agent Orange is that a
relatively short period of time has elapsed since exposure took place. The phenoxy herbicides
contained in Agent Orange were first used in Vietnam in 1962. Heavy use and potentially
heavy exposure to Agent Orange did not begin until three years later, so the time that has
elapsed since most veterans were exposed has been about 15 to 20 years. Certain adverse
health effects such as cancer, heart disease, and 'respiratory problems that result from exposure to chemicals may take many years to develop. Increased cancer rates due to smoking or
exposure to toxic chemicals have been shown to reach a peak 20 to 30 years after exposure.
Thus, a lack of evidence of increased rates of cancer and heart disease in populations exposed
to Agent Orange might suggest that exposure to Agent Orange does not increase the risk of
developing these diseases. On the other hand, it might be that they haven't had time to appear
in sufficient numbers to be detected.

No direct measurements were made of the chemicals in the accidental gas cloud itself but it
has been possible to estimate the dioxin exposure of people in different areas by three independent methods. The first was a calculation of the distribution of the dioxin based on the nature
of the chemical reaction, the quantity of ingredients, and the wind direction and speed at the
time of the accident. The second method recorded biomedical changes, such as the death of
birds and other wild and domestic animals and the appearance of chloracne in people. These
changes were then correlated with the geographic location of each person or animal affected.
The third method, performed somewhat later, was the actual analysis of the soil for dioxin.
This gave results which were judged to be in agreement with those of the other two methods.
In addition, reports by the exposed individuals provided supplementary and confirmatory information.

The studies of populations who were probably exposed to Agent Orange as a result of the
Vietnam experience have not yet provided clearcut answers to questions about its health effects. This is the result of some of the limitations described above. Furthermore, future studies
of this type will not be capable of answering all these questions. It is therefore necessary to
ask, "Where else can we look for these answers?" One potentially valuable source of information is the study of human populations with exposure to commercial herbicidal mixtures that
were similar, but not identical, to Agent Orange. A number of such studies are available. Most
are of workmen who sprayed herbicides on the job, but some are of populations who lived in
areas where herbicides containing 2,4-D and 2,4,5-T were used. Most of these studies are subject to the same limitations as those of the people exposed to Agent Orange.
In all of these studies, the determination that a person is or is not exposed is based largely on
that person's memory of past events or, in many cases, simply on where the person lived or
worked. Also, people may be included in the exposed group who worked at a job or lived in
an exposed area for only a few weeks. On the other hand, people may be included in the unexposed group if they are currently working in jobs or living in areas where they are not exposed
to herbicides but who may have been exposed to herbicides in some previous job or place of
residence, perhaps even without knowing it. Either type of error decreases the ability of scientists to detect possible effects of exposure to the chemical.
Other potential sources of information about the health effects of Agent Orange are studies
of humans who were exposed to some of the components of Agent Orange. There are a
number of groups of people throughout the world who were exposed to dioxins as a result of
industrial accidents or unintentional release of dioxin into the environment. Several of these
groups "have been followed for a number of years and much information has been gathered. It
is difficult, however, to judge how relevant these findings are to people exposed to Agent
Orange. The specific dioxins to which these people were exposed were not always completely
or accurately identified, and they may be somewhat different from those found in Agent
Orange.
One of the most widely publicized incidents in which humans were exposed to dioxins was
the explosion of a chemical reactor at the ICMESA plant near Milan, Italy, in July 1976. A
cloud of chemicals containing relatively large quantities of dioxins blanketed a portion of the

•

In the areas with the most intense exposure, animals and birds died; humans did not. People
experienced a variety of symptoms shortly after the explosion including weakness, headache,
loss of appetite and weight, insomnia, impotence, nausea and abdominal pain. There was also
a burning sensation and an eruption of the skin, but the role of dioxin, as opposed to other
more caustic chemicals suspected of being present in the cloud, is unclear. The symptoms
cleared up within a brief period but one characteristic skin change, chloracne, persisted.
Chloracne was present, especially in children under the age of 14. In the most heavily contaminated areas about 20 per cent of the children developed the skin disorder. The changes
gradually cleared over the ensuing months.
1

Early after the exposure there were laboratory results suggesting changes in liver function,
but the test results did not differ a great deal from those obtained in an unexposed, control
population. Within a year after the exposure careful examinations showed some problems
with the nerves controlling muscle function. These changes apparently disappeared within the
following two or three years.
It is not clear that the exposure to dioxin had any effect on the pregnancy rate, the miscarriage rate or the birth rate since there are no good statistics from nearby communities with
which to compare the exposed populations. There is no convincing evidence that the dioxin
caused birth defects, interfered with growth, disturbed resistance to disease or increased the
death rate. Some details of these results may be questioned because of the difficulties encountered in collecting the data. It is reasonable, however, to say that the Seveso accident did
not result in a very serious or life-threatening effect on the health of exposed persons, at least
in the near-term. It is too soon to draw final conclusions regarding possible delayed effects.
A final potential source of information about the adverse health effects of Agent Orange includes studies using experimental animals. Care must be taken in interpreting the results of
animal studies because animals may respond quite differently from humans in the way they
absorb chemicals, in the distribution of these chemicals in the body, in the way the chemicals

�are broken down or stored in the body, and in the way they are eliminated. Differences in
body size, diet, lifespan, and the way individual organs function may also cause animals to
respond differently from humans. For these reasons responsible scientists are reluctant to base
predictions of human health effects on animal studies unless the chemical has been tested in
several species of experimental animals and there is a good basis for believing that the test
animals are similar to humans in the way they respond to the chemical.

cancer) among his patients. All three of these patients had served in Vietnam but no other information was given about them.
Comparisons between groups exposed to the herbicides or to dioxins and unexposed groups
have shown no overall increase in cancers. Attention has centered on certain types of cancers.
There have been 11 reports of studies of cancer in men who were employed in jobs that involved the spraying of herbicides similar to Agent Orange. Eight of these studies were limited
to men who sprayed herbicides containing 2,4-D or 2,4,5-T. The other three studies were of
workers exposed to agricultural chemicals in general, including herbicides. These three studies
are not discussed here because of the uncertainty regarding exposure. The eight remaining
reports are also based on groups of workers whose exposure was of doubtful duration and intensity. Two of the eight studies of 2,4-D or 2,4,5-T indicated that there was an association
between exposure and the incidence of soft-tissue sarcoma. A third study showed an association between exposure and lymphoma, and one study showed an association between exposure and stomach cancer. Another of these eight reports described five cases of lymphoma
with cutaneous (skin) lesions seen in an English hospital. Four of the five patients worked with
2,4-D or 2,4,5-T. A case-control study reported an association between herbicide exposure
and cancer of the nose and throat. The remaining three reports showed no association between exposure and any form of cancer, although one suggested a slight association with softtissue sarcoma.

For reasons noted earlier, Agent Orange when it was first used was not tested in experimental
animals and, because the amount and identity of the impurities in Agent Orange varied,, it cannot be exactly reproduced for studies in experimental animals now or in the future. It is
therefore necessary to rely on the results of experimental studies of herbicide mixtures similar
to Agent Orange as well as studies of individual components of Agent Orange such as 2,4-D,
2,4,S-T and TCDD to serve as a basis for predicting the human health effects of Agent
Orange.
The remainder of this report on the health effects of Agent Orange summarizes the information available as of early 1984 from all the types of studies described above. The section that
follows provides a discussion of each of the suspected or potential health effects and in each
case the available evidence is evaluated as a whole. For more detailed information regarding
specific studies the reader is urged to refer -to the Review of Literature on Herbicides,
Including Phenoxy Herbicides and Associated Dioxins, Volumes I, II, III and IV, published
by the Veterans Administration.
6. Summary of the studies on health effects
Cancer
To date only one systematic study of cancer in military personnel exposed to Agent Orange
in Vietnam has been published. In this study of Air Force personnel who were engaged in
Operation Ranch Hand (the herbicide spraying operation in Vietnam), there was no increased
occurrence of serious or life-threatening forms of cancer, but a greater incidence of a type of
skin cancer was found in the exposed group compared to a control group of military personnel
who were not exposed to Agent Orange. This type of skin cancer is a very common, localized
form that is known to be associated with exposure to sunlight. Further studies need to be done
to determine whether Ranch Hand personnel were more likely to have been exposed to
sunlight than were the members of the comparison group. There was also a slightly increased
incidence of cancer of the mouth and throat in the Ranch Hand group, but this excess is so
small that it may be due to chance.
Two other reports are available on cancer in Vietnam veterans but in neither report was
there any confirmation of exposure nor were matched control groups used. In one survey, based
on Vietnam veterans who registered with the VA's Agent Orange Registry, a somewhat higher
proportion of mouth and throat cancer and of lymphoma (cancer of the lymphatic system)
was found compared to the same proportion of cancers among U.S. males aged 25 to 39. In
the other report, a physician in Atlanta reported three cases of soft-tissue sarcoma (a rare

:

Of seven studies on populations exposed to dioxins either in the workplace or in -the environment, two showed an increased incidence of cancers. A study of workers exposed to
dioxin as a result of a reactor explosion in a 2,4,5-T manufacturing plant in Germany in 1953
showed an excess of stomach cancer. Another study of the residents of Midland County,
Michigan, where Dow Chemical Company has a large plant, revealed an increased incidence
of soft-tissue sarcoma in women between 1960 and 1980. This finding is unlikely to be related
to dioxin exposure, however, because the excess cancer was seen only in women and several of
the people with soft-tissue sarcoma had lived in Midland County only a short time before the
diagnosis of cancer and had little or no connection with the company.
Three separate reports describe two cases of lymphoma and three cases of soft-tissue sarcoma in workers who may have been exposed to dioxin. These are isolated case reports, and
they contained little evidence of dioxin exposure. Two studies of workers occupationally exposed to dioxin revealed no excess incidence of any form of cancer.
None of the studies of cancer in humans exposed to Agent Orange, related herbicides, or
dioxins provides an answer to the question of whether Agent Orange might cause cancer in
humans. When all the reports are taken together, however, certain patterns appear that provide suggestive evidence that exposure to dioxin-contaminated herbicides may be associated
with an increased incidence of cancer. Thus, seven reports suggest a relationship between such
exposure and soft-tissue sarcoma. Four reports point to a possible connection with lymphoma. Two studies show an association with stomach cancer and three reports suggest a
possible association with cancer of the mouth, nose, or throat.

�The results of animal studies lend support to the hypothesis that dioxins and dioxincontaminated herbicides may cause cancer in humans. Six studies of the potential for TCDD
to cause cancer in animals were positive when relatively large doses were given. TCDD
painted on the skin of mice caused cancers related to soft-tissue sarcomas. Four studies in
which rats were given TCDD by mouth showed that the rats developed cancer of the liver,
mouth and nose, tongue, adrenals, and thyroid. In two studies in which TCDD was given to
mice by mouth, liver and thyroid cancers resulted. Several studies suggest that when TCDD is
given to mice with other cancer-causing chemicals, it increases the response to those cancercausing chemicals.
As yet there have been no published studies which show that Agent Orange or simitar commercial herbicides have a demonstrated potential for causing cancer in laboratory animals. A
few studies designed to measure the effect of 2,4-D and 2,4,5-T on rats and mice have been
negative for cancer, but these studies were not adequate to detect a small increase in cancer in
the treated animals. The current evidence, though far from conclusive, justifies continued
surveillance of people who have been exposed to dioxin and dioxin-contaminated herbicides
in order to confirm or deny an increased incidence of cancer which can be attributed to that
exposure.

Two studies have been reported of men who were exposed to herbicides similar to Agent
Orange. A study of wives and children of herbicide sprayers in New Zealand showed no increases in birth defects, stillbirths, or miscarriages when compared to the population of New
Zealand as a whole. There was a very small increase in the incidence of heart defects, but this
may have been due to chance. Another study of children born to the wives of men who
sprayed herbicides for the Long Island Railroad showed no increase in major birth defects but
two relatively minor birth defects—minimally deformed feet and tear duct obstruction—were
seen in excess.
Several studies have been conducted to ascertain whether there are increased incidences of
spontaneous abortions, stillbirths, or birth defects in areas where herbicides similar to Agent
Orange have been heavily used. In these situations there is the potential for exposure of both
parents as opposed to exposure of only the father as in the four studies discussed above.
One of these general population studies gained a great deal of publicity in the late 1970s
when it was asserted that women living in the vicinity of Alsea, Oregon, experienced a higher
rate of miscarriage than did women living in other parts of Oregon where herbicides were not
commonly used. Careful review of this study by expert scientists has resulted in a consensus
that the results were misinterpreted and that the study did not show the claimed effect.

Reproductive effects
The various possible causes of reproductive abnormalities are difficult to determine because
there are fairly high rates of birth defects, stillbirths, miscarriages, and sterility in all populations. For example, between three and six percent of all children are born with some kind of
defect. The percentage varies depending upon how serious a disturbance has to be before it is
recorded as a defect. In addition, some defects are not noted at birth, but show up later in
childhood or beyond.
Two systematic studies of reproductive performance and outcome among men who may
have been exposed to Agent Orange in Vietnam have been published. In the first of these the
Australian government sponsored a study to see whether birth defects were related to the
father's service in Vietnam. No association was found, although there was a slightly increased
risk of heart defects and Down syndrome among the children of Vietnam veterans.
In the study of Operation Ranch Hand personnel discussed in the cancer section above, a
small increased incidence of miscarriages following Vietnam service was found among the
wives of the Ranch Hand group when compared to wives of the control group. The same difference, however, was observed for pregnancies occurring prior to Vietnam service. There
were also slight increases in deaths of newborn babies and minor birth defects. There may
have been slight increases in learning disabilities and physical handicaps among children of
Ranch Hand personnel. The significance of these findings is not clear because most of the increases are very small, and many of these differences disappear if the data are analyzed differently. In addition, these differences were based on self-reporting and at the time of the
initial report had not been confirmed by a review of medical records.

More recently, a study of people living in an area of New Zealand where herbicides containing 2,4,5-T were often used revealed an increase in the occurrence of clubfoot in children in
the area. Other small and perhaps insignificant increases were found in heart defects and
malformations of the penis. A study conducted in Hungary looked at the rate of five major
birth defects in that country's general population over a five-year period in which the use of
2,4,5-T increased greatly. No changes in the rates of these birth defects were found.
Four studies have been conducted of men exposed to dioxin as a result of working in plants
where 2,4,5-T was manufactured. None of these studies' showed a clearcut effect on reproductive outcomes. Two of them did show a slight increase in spontaneous abortions in the wives
of the workers. Two studies of the population exposed to dioxin as a result of the ICMESA accident at Seveso suggest that there may have been an increase in birth defects (particularly of
the heart) and an increased incidence of spontaneous abortions in the year following the accident, but their validity is questionable because the reporting of birth defects and abortions was
generally unreliable.
The studies of the reproductive effects of 2,4-D, 2,4,5-T, and TCDD in experimental animals
are of limited usefulness in helping to predict the reproductive effects of Agent Orange in male
Vietnam veterans. In almost all of the animal studies, the herbicide or dioxin was given to
pregnant females rather than to male animals. In the one study in which the mixture found in
Agent Orange was fed to male mice, it had no effect on reproductive performance or on the offspring. In two studies, relatively uncontaminated 2,4,5-T and TCDD were fed to both male
and female rats and reproductive performance and outcome were recorded for three successive
generations. These studies showed that both 2,4,5-T and TCDD decreased the number of live
births and the weight of newborn animals, as well as causing an increase in birth defects of the
kidneys. Numerous studies in which TCDD was given to pregnant females in relatively large

�doses indicate that it can cause defects in the developing fetus. TCDD causes birth defects in
pregnant rats, mice, rabbits, and monkeys when given by mouth or injection. It also causes an
increase in the number of spontaneous abortions and a decrease in birth weight of newborn
animals.
In summary, no study of reproduction in humans exposed to Agent Orange conclusively
shows an adverse effect which has been caused by the herbicide. Scientists believe, however,
that people with known exposure to TCDD-contaminated chemicals should be observed for
possible adverse reproductive effects.
Enzyme effects
One of the best studied effects of dioxins in experimental animals is the ability of these compounds, especially TCDD, to alter the activity of certain enzymes. Enzymes are proteins that
serve as catalysts in the formation or breakdown of various chemicals in the body. In some
cases many enzymes are involved in the alteration of just one chemical, whereas other enzymes
are capable of acting upon an entire class of chemicals.
It is very difficult to study the effects of chemicals on enzyme activities in humans. Most enzymes are located in tissues where metabolic activity is greatest, such as the liver, lungs, intestines, brain, and reproductive organs, and these tissues are the least accessible to study.
Furthermore, there are large differences among people in their baseline metabolic activity.
About the only approach available is to look at the levels of chemicals produced by enzyme
reactions that appear in the blood or urine and determine whether they are different in people
exposed to a specific compound when compared to people who are nor exposed to that compound.
Only a few studies of enzyme activities have been conducted in animals which have been fed
or otherwise dosed with 2,4-D and 2,4,5-T. These studies suggest that these compounds do
not cause major alterations in enzyme activities, and some of the small effects seen may be the
result of contamination of these chemicals with small amounts of dioxin. A number of studies
of TCDD, on the other hand, have shown that it alters the activity of some enzymes in experimental animals.
The best studied effect as an increase in the activity of an enzyme known as aryl hydrocarbon hydroxylase (AHH). AHH is important because it makes certain chemicals more soluble
in water and, thus, more likely to be excreted in the urine. Very small amounts of TCDD
cause large increases in the activity of this enzyme in rabbits, mice, rats, guinea pigs, hamsters,
birds, fish, and monkeys. In several studies in which living cells were taken from humans and
allowed to grow in a culture medium, the addition of TCDD to the culture caused an increase
in AHH activity in the cells.
It is interesting that in two studies of human populations exposed to dioxin as a result of industrial accidents (one at Seveso and the other at a 2,4,5-T manufacturing plant in England),
scientists found elevated levels of d-glutaric acid in the urine of exposed people. This chemical
10

is believed to be formed by enzymes that are very closely associated with AHH. This finding
adds support to the theory that TCDD may stimulate AHH activity in humans.
What are the health implications of stimulation of AHH activity? This is a difficult question
to answer because the role of AHH is not yet fully understood. Evidence from animal experiments and some human evidence indicate that some of the aryl hydrocarbons that are
altered by AHH are cancer-causing. Some experiments in which TCDD was given to animals
several days before they were exposed to cancer-causing aryl hydrocarbons showed that it protected the animals against cancer. Thus, TCDD caused an overall health benefit.
Unfortunately, the picture is much more complicated than that because, if TCDD is given to
animals at the same time as the aryl hydrocarbon rather than a few days earlier, the TCDD
binds to the site of the AHH enzyme that is responsible for changing the aryl hydrocarbon and
prevents the AHH enzyme from doing its job. Thus, administration of TCDD with aryl
hydrocarbon causes more cancer than does the aryl hydrocarbon itself.
An additional complication is that there is evidence that AHH catalyzes other tranformations and that some of them may convert inactive chemicals into toxic ones. In the absence of
complete information, the fact that TCDD stimulates AHH activity must be viewed as a
potentially adverse effect.
Animal studies have also shown that TCDD alters some enzymes that are involved in the
manufacture of heme, the portion of the hemoglobin molecule that binds oxygen in red blood
cells. Animal studies indicate that TCDD decreases the activity of an enzyme known as
uroporphyrinogen decarboxylase in the liver. This results in a decrease in the amount of heme
synthesis and a build-up of the chemicals known as porphyrins from which heme is formed. As
the porphyrin level builds up, more porphyrins are excreted in the urine.
A number of animal experiments have shown that the pattern and amount of porphyrins excreted in the urine changes after treatment with TCDD. Two studies of workmen exposed to
dioxin have shown increased urinary excretion of porphyrins. The Air Force study of personnel involved in Operation Ranch Hand has also shown that there are more men with abnormally high porphyrin levels in the exposed group than in the comparison group, although this
finding correlates more strongly with alcohol use than it does with potential exposure to Agent
Orange.
Interference with porphyrin metabolism may result in a condition known as porphyria
cutanea tarda (PCT) in which the skin blisters and later becomes dry and brittle, particularly
on exposure to sunlight. Workers who were exposed to dioxins as a result of two industrial
situations developed this condition but in both instances the men were also exposed to another
chemical known to cause PCT.
The available medical evidence indicates that there are no lasting adverse human health effects that result from alterations in porphyrin metabolism due to exposure to TCDD. The
body adjusts by producing sufficient heme to meet the oxygen-carrying needs of the body.
PCT is a relatively rare manifestation of changed heme metabolism and may be caused by
11

�other external factors, such as alcohol consumption. There is also a known genetic factor
which influences the development of PCT. PCT resulting from exposure to such chemicals as
dioxins and similar compounds is reversible and disappears after exposure.
Another enzyme activity for which there is indirect evidence of interference by dioxins is
related to the conversion and storage of fats. Studies of workmen exposed to dioxins showed
increased blood levels of fat molecules known as triglycerides. Although elevated levels of
some triglycerides are known to be associated with heart disease, to date there is no conclusive
evidence of an association between heart disease and dioxin exposure.
Although it appears that dioxins have the ability to alter the functions of a number of enzymes, at present none of these alterations has been shown to be associated with any serious or
irreversible adverse health effects in humans. However, any influence that substantially alters
the way the body handles internal and external chemicals must be viewed with concern. It
should be remembered that as in the case of most of the effects of these chemicals, the active
herbicide ingredients 2,4-D and 2,4,5-T by themselves are not known to affect the enzyme
system in humans.
Effects on the immune system
Unlike such well-studied and relatively well-understood systems of the body as the cardiovascular and digestive systems, there is still much of the "immune system" which is not well
understood. It is currently the subject of intensive research to better understand its chemistry,
mechanisms, and functions. The immune system is involved in a large and complex array of
processes that defend the body against foreign chemicals, disease-causing bacteria, viruses,
foreign cells from outside the body, and abnormal cells from within the body. Virtually all of
the body's organs and tissues participate in these processes to a greater or lesser extent.
Because of the lack of basic knowledge in some areas, it is difficult to assess the impact of
chemicals on the immune system. One problem is that the system functions in many different
ways. A chemical to which the body is exposed may activate only one or two of dozens of
known defense mechanisms. Therefore, it may be necessary to run a large number of different
tests to detect these changes. Since many of these tests are very complex and some require the
examination of body tissues, it is especially difficult to study altered immune function in
humans.
Two additional factors make it difficult to detect such changes in humans. First, there are
tremendous differences among people in the manner in which their immune systems operate.
For example, there is a wide variation in the way different people manifest an allergic reaction,
which is one of the ways the immune system functions. Second, many activities of the immune
system have no obvious or external manifestations. It is usually not possible to assess a
person's immune function by a simple physical examination. These changes in immune function may only be reflected by subtle variations in indirect indicators, such as increased susceptibility to infections or increased sensitivity to materials that cause allergic reactions. One
result of these problems is that the effect(s) of chemicals on the immune system of humans may

12

be very subtle and difficult to detect. Highly specialized and complex tests are often needed to
detect these changes.
There is no evidence that 2,4-D or 2,4,5-T by themselves alter the immune function of
animals. There have been no studies of humans exposed to Agent Orange or similar herbicides
that show an adverse effect on the immune system, and there have been no reports of increased
allergies or of increased susceptibility to infection, either of which might indicate altered immunity. On the other hand, there have been no studies reported that were designed specifically
. to look for such an effect in humans soon after exposure.
There is considerable evidence, on the other hand, that TCDD interferes with the functioning of the immune system in experimental animals. When TCDD is given to animals, a common effect is a decrease in the size of the thymus, an organ that is involved in the immune
system. This effect occurs at doses lower than those that cause changes in other organs. At
even lower doses, TCDD interferes with the ability of the animal to produce certain types of
white blood cells in response to the presence of foreign materials in the blood stream. In some
studies, this effect is paralleled by decreased resistance to bacterial and viral infections.
It appears that TCDD has the ability to suppress the immune system in unborn animals
when the TCDD is given to pregnant females. Sensitivity decreases in newborns but significant
effects can still be seen in adult animals treated with TCDD. In fact, immune suppression is
the most sensitive indicator of TCDD exposure in mice, occurring at doses below those that cause changes in enzyme activity. Furthermore, although immune function improves after exposure ends, it remains relatively depressed for a very long time in experimental animals.
Most studies of humans who have been exposed to dioxins have not included tests of immune function. There has been a study of children who lived in the heavily contaminated area
of Seveso, Italy. The results of this study showed that these children had higher levels of certain immunologically active blood components than did children from uncontaminated areas.
The body also produced more white blood cells in response to certain foreign materials. These
results suggest that exposure to dioxins stimulated immune function in these children rather
than depressing it, as seen in the animal experiments. This finding is not inconsistent,
however, with experimental findings that some chemicals which depress immune function at
high doses may actually stimulate immune functions at low doses.
Another study of workers exposed to dioxin as the result of an industrial accident has been
reported to have shown decreased immune function in the exposed workers 10 years after
the accident, but this study has not been published and cannot be independently reviewed.
These results, taken together, fall far short of providing convincing evidence that dioxin exposure can cause altered immune function in humans. Nevertheless, the evidence of such effects in experimental animals provides some basis for concern that exposure to dioxin may
adversely affect immune function in humans.
Chloracne

Chloracne is a skin condition that is known to result from exposure to a group of structurally
similar compounds in which chlorine atoms are bound to an aromatic hydrocarbon. One of
13

�exposed than workers who did develop chloracne. Thus, whereas chloracne may be a sensitive
indicator of exposure to dioxins in some people, it may not be in others. Therefore, the
absence of chloracne is not necessarily a reliable basis for concluding that a person has not
been exposed to a chemical which is known to cause chloracne.

these compounds is TCDD. As its name suggests, chloracne, is similar in appearance to the
common forms of acne that affect teenagers and usually appears within a few weeks after exposure to the chemical that causes it.

Neurobehavioral effects

The first sign of chloracne may be excessive oiliness of the skin. This is accompanied or
followed by the appearance of numerous blackheads. In mild cases the blackheads may be
confined to the area around the eyes extending along the temples to the ears. In more severe
cases blackheads may appear in many places on the body. The blackheads are usually accompanied by fluid-filled cysts and by an increased or darker growth of body hair. The skin may
become thicker and flake or peel. In severe cases, the acne may result in opens sores and permanent scars. The condition fades slowly after exposure. Minor cases may disappear
altogether, but more severe cases may persist for years after the exposure.

It has been known for some time that exposure to relatively large amounts of 2,4-D, such as
might occur when it is being mixed or sprayed, can cause adverse effects on the nervous
system. Workmen who splashed 2,4-D on their skin or who stood for a long time in 2,4-D
spray mist developed a variety of symptoms including tingling or decreased feeling in the
hands and feet and tightening of muscles in the arms and legs. Examination of these workmen
showed the loss of the knee-jerk reflex and an increase in the time for nerve impulses to travel
from the hands or feet to the spinal cord and back. Studies in experimental animals give results
similar to those seen in humans. These studies suggest that 2,4-D interferes with the transmission of nerve impulses to muscles. If the exposure is minimal the nervous system recovers.
However, sustained exposure of experimental animals to relatively large quantities of 2,4-D
may cause long-lasting changes in the brain and spinal cord itself.

It is well known that chloracne can result from exposure to dioxins. In seven reported situa' tions where workers were exposed to dioxins as a result of industrial accidents or poor
housekeeping practices, many of the workers and, in a few cases, members of their families
developed chloracne. Chloracne was also diagnosed in 187 people, mostly children, Jiving in
the section of Seveso that was most heavily contaminated with TCDD as a result of the
ICMESA accident in 1976. Two laboratory workers who were exposed during the synthesis
of TCDD developed serious cases of chloracne.
There are no authoritative reports in the literature that document an association between
exposure to Agent Orange or similar herbicides and chloracne. The Air Force study of Ranch
Hand personnel showed no excess of acne in those individuals when compared to unexposed
controls and no cases of chloracne were found. Most of the epidemiologic studies of occupational groups involved in the spraying of Herbicides like Agent Orange do not report the
presence of chloracne among the workers who were studied. A research effort looking for
cancer among herbicide sprayers in Finland turned up a few cases of possible chloracne, one of
which was diagnosed by a dermatologist. It would appear, therefore, that chloracne is not a
sensitive indicator of exposure to herbicides like Agent Orange.
Animal studies are of little use in measuring the potential of Agent Orange for causing
chloracne in humans. The ingredients 2,4-D and 2,4,5-T have not been extensively tested, but
it appears that they do not cause chloracne or similar skin conditions in experimental animals.
Different kinds of animals react differently to TCDD, but it causes skin conditions very similar
to chloracne when applied to the ears of rabbits and to the skin of certain kinds of mice. Scientists disagree, however, as to whether these skin effects are identical to human chloracne.
Some types of experimental animals fail to show any acne-like condition when treated with
TCDD. It seems that only monkeys exposed to TCDD develop a skin condition that appears
identical to human chloracne.
One conclusion that is gaining support on the basis of both animal and human studies is
that susceptibility to chloracne may be genetically controlled. Two individuals equally exposed to TCDD may respond differently because of variations in inherited susceptibility. This
would explain why some of the workers exposed to dioxins in each of the seven industrial incidents did not develop chloracne, even though there is no reason to believe that they were less
14

A few studies of humans and experimental animals exposed to 2,4,5-T have failed to show
any nervous system effects such as those caused by 2,4-D. There is some evidence, however,
that humans exposed to dioxins as a result of industrial exposures or accidents may suffer impaired nervous system function. A wide range of signs and symptoms have been reported in
these people including pain in the arms and legs, numbness in the hands and feet, muscular
weakness particularly in the legs, headache, loss of memory and concentration, sleep disturbances, nervousness, and emotional and behavioral abnormalities. The speed of nerve impulses
was slowed in two groups of workers who were probably exposed to dioxins.
J

There have been very few studies of the effects of TCDD or other dioxins on the nervous
system in animals. It is not clear why this knowledge gap exists, but one possible explanation
is that the doses of TCDD needed to cause detectable signs of nervous system damage in experimental animals are higher than those that cause other serious toxic effects. Scientists have
therefore tended to concentrate on the other effects.
Whether nervous system and psychologic effects have occurred in individuals exposed to
Agent Orange as a result of the Vietnam experience is unclear and controversial. It has been
suggested that Vietnam veterans experience a high rate of psychologic problems, with certain
symptoms appearing quite frequently. These symptoms include nervousness, disturbed sleep,
irritability and short temper, depression, and suicidal thoughts. Many psychiatrists consider
that some of these comprise a distinct collection of symptoms or a syndrome known as posttraumatic stress disorder and that this syndrome is unrelated to any chemical exposure.
Evidence in support of this conclusion is that individuals such as prisoners of war and hostages
who have undergone sustained stress display similar symptoms.
Unfortunately, there are almost no systematic studies of nervous system function or
psychological problems among individuals exposed to Agent Orange. The recent Air Force

15

�study of Ranch Hand personnel showed no difference between the exposed group and unexposed controls in several measurements of nervous system function including the speed of
nerve impulse transmissions. On the other hand, when Ranch Hand personnel were evaluated
by analyzing answers to questions on some of the tests designed to detect emotional disorders
or personality disturbances, psychiatrists concluded that they were different from the comparison group and showed tendencies toward traits defined as "hypochondria, depression,
hysteria, and schizophrenia." Ranch Hand personnel were also said to feel more isolated and
to have a higher degree of nervousness and anxiety, to be more easily startled, and to experience more psychosomatic illness than did the comparison group. These differences were
minor and are difficult to interpret. The methods used in this study would not show whether
the differences between groups were due to post-traumatic stress, Agent Orange exposure, or
both.

Animal studies have suggested another aspect of the toxicity of TCDD which may have implications for human health. It has become increasingly clear that some animals are relatively
resistant to some of the toxic effects of TCDD compared to others. Recent research has shown
that this difference in susceptibility is genetically influenced and that mice with just one parent
in common can show large differences in susceptibility to the toxic effects of TCDD. The effects for which susceptibility appears to be genetically controlled include the appearance of
birth defects in the offspring of female mice exposed to TCDD, the increased activity of
several enzymes including AHH and uroporphyrinogen decarboxylase, depression of immune
function, chloracne, and the lethal effects of TCDD. This suggests the possibility that humans
as a group who are known to be genetically very diverse, may have a wide variation in susceptibility.
7. Summary and Conclusions

The fact that self-perception of psychologic problems is an important component of such an
analysis was shown in a study of 100 veterans who were asked about their exposure to Agent
Orange and their current mental and emotional well-being. Their potential exposure to Agent
Orange was independently assessed by comparing their service records with records of the
time and location of herbicide spraying missions in Vietnam. The frequency and seriousness of
psychologic and emotional problems correlated very closely with how much herbicide the
veterans believed they were exposed to, whereas the correlation was much weaker when the
comparison was based on how much herbicide exposure the records showed.

What can we say about the health effects of Agent Orange? From the evidence now
available we can arrive at almost no definitive conclusions. The limited evidence available suggests that 2,4-D and 2,4,5-T by themselves are not highly toxic to humans. 2,4-D appears to
be capable of causing nervous system toxicity but only in situations where there is very highlevel exposure. 2,4,5-T may contribute to birth defects when pregnant females are exposed.
There is no evidence that purified 2,4-D or 2,4,5-T cause cancer, change the activity of enzymes, affect the immune system, or cause chloracne or porphyrja cutanea tarda in humans.

The issue of the effects of Agent Orange on nervous system and psychologic performance is
probably the most difficult health issue to resolve. There is a great deal of human and animal
evidence that both 2,4-D and TCDD can adversely affect the nervous system. All of this
evidence suggests that these effects are the result of short-term high level exposure rather than
sustained exposure to lesser amounts.
Other toxic effects
Studies of people exposed to Agent Orange or similar herbicide mixtures have failed to
reveal any significant toxic effects other than those discussed above. Other effects have been attributed to TCDD, however. As was mentioned briefly in the section on enzyme effects, there
is suggestive evidence of a higher incidence of heart attacks among workmen exposed to dioxins in industrial accidents. This evidence is far from conclusive, but it is sufficient justification
for continuing to observe the health of people exposed to dioxin, especially since it may take
many years after exposure for adverse effects on the heart to show up.
The most dramatic sign of fatal dioxin poisoning in experimental animals is an apparent
loss of appetite which leads to general body wasting. The animals eventually die of a condition
very similar to starvation. This effect is observed following a large single dose of TCDD. No
similar effect has been described in humans, so it may be of little relevance to human health.
The mechanism by which TCDD causes this apparent loss of appetite is unknown and is the
object of much current research. Some results suggest that TCDD may interfere with an appetite regulating system in the brain or thyroid.

16

'

There is very little direct evidence that Agent Orange causes adverse health effects in
humans, but this may be the result of our limited ability or inability to identify different
groups of people or large numbers of people with well-defined exposure and exposure to a
known amount of the substances of concern. If adverse human health effects are found as a"
result of present or future research efforts, it is highly likely that these will be the result of the
effects of toxic impurities such as dioxins, especially TCDD. The limited evidence of TCDD
toxicity in humans comes from studies of humans exposed to dioxins, and indirectly from
studies of dioxin toxicity in experimental animals. These studies provide some support for the
possibility, but do not prove, that exposure to dioxin-contaminated herbicides may cause
adverse health effects in humans.
These adverse effects may include chloracne, cancer at several different sites, spontaneous
abortion and birth defects in the offspring of exposed females, altered enzyme activity, altered
porphynn metabolism, and altered immune function. Effects for which the available evidence
is very inconclusive but which should be the subject of further study are neurobehavioral effects, including psychologic effects and heart disease. Chloracne does not seem to be of significant importance since it has not been commonly observed even among individuals heavily exposed to herbicides. Therefore chloracne does not appear to be a sensitive indicator of exposure to dioxin-contaminated herbicides.
What will future studies tell us about the health effects of exposure to Agent Orange?
Studies that are planned or in progress have the potential to reduce much of the uncertainty
about the health effects of exposure to Agent Orange. However, because of very serious problems in determining the exact amount and nature of exposure and in choosing appropriate

17

�exposed and unexposed groups to examine, these studies will never be able to demonstrate
conclusively the absence of a toxic effect. The areas in which future studies may be able to
:
provide the most information are the delayed effects such as cancer.
'Studies in experimental animals can still be helpful in suggesting possible adverse health effects of Agent Orange. Particularly helpful would be studies of the purified components of
Agent Orange separately and in known combinations. Other important areas of investigation
include effects on immune function and the genetic control of susceptibility to the toxic effects
of dioxin.
In the meantime, exposed individuals can get some degree of reassurance from the fact that
despite their inadequacies, the studies which have been completed to date have revealed no
widespread or major adverse health effects among the people who were exposed. There is no
evidence that the psychologic disturbances seen in Vietnam veterans are the result of exposure
to Agent Orange.
For many-of the potential health effects, there is little probability that they will first appear
years after exposure. These include reproductive and enzyme effects, chloracne, and
neurobehavioral problems. It is possible that cancer may first appear years after exposure.
Persons exposed to Agent Orange should take no exceptional precautions beyond those that
are prudent for everyone, i.e., consume a balanced diet, exercise regularly, have regular
medical checkups, be alert for tell-tale signs of cancer, abstain from smoking, and use alcohol
moderately, if at ail.

18

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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
&amp; 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&gt;
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&amp;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&amp;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

&lt;
&lt;
&lt;
&lt;

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&amp;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

&lt;
&lt;
&lt;
&lt;
&lt;
&lt;

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
&amp;8
2&amp;3*

184.21
252.78

5.22 4.43
7.16 4.43

14.41
14.41

17.00 &lt; 2
17.00 &lt; 2

370.46
352.55

29.56
29.30

7.43
9.48

North
South
1&amp;4I*
2S3h

256.88
246.73

7.28
6.99

4.41
4.41

14.56
14.56

18.00 &lt; 2
18.00 &lt; 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

&lt; 2
&lt; 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 &lt; 2
16.00 &lt; 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

&lt; 2
&lt; 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

&lt;
&lt;
&lt;
&lt;

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

&lt; 2
&lt; 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

&lt; 2
&lt; 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&amp;4"
2&amp;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

&lt;
&lt;
&lt;
&lt;

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&amp;4
2&amp;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

&lt;
&lt;
&lt;
&lt;

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&amp;4
2&amp;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

&lt;
&lt;
&lt;
&lt;

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&amp;4
2&amp;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

&lt;
&lt;
&lt;
&lt;

2
2
2
2

371.23
348.41
354.56
345.31

29.35
29.44
29.21
29.25

North
South
1&amp;4
2&amp;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 &lt; 2
23.00 &lt; 2
24.00 &lt; 2
24.00 &lt; 2

381.96
354.96
360.06
357.50

North
South
1&amp;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&amp;3

347.89
368 . 08
356.20
388.52

9.85 3.80 13.80 22.00 &lt; 2
10.42 3.80 13.80 22.00 &lt; 2
10.09 6.00 12.50 17.00 &lt; 2
11.00 6.00 12.50 17.00 &lt; 2

North
South
1&amp;4
2&amp;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&amp;4
2&amp;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

&lt;
&lt;
&lt;
&lt;

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

&lt;
&lt;
&lt;
&lt;

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

&lt;
&lt;
&lt;
&lt;

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&amp;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

&lt; 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

&lt; 2

356.40

29.10

9.92

24.58

&lt; 2
&lt;2
&lt; 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

&lt;
&lt;
&lt;
&lt;

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 &lt;
142 &lt;
169 &lt;
169 &lt;

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

&lt;
&lt;
&lt;
&lt;

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

&lt;
&lt;
&lt;
&lt;

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

&lt;
&lt;
&lt;
&lt;

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

&lt;
&lt;
&lt;
&lt;

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

&lt;
&lt;
&lt;
&lt;

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

&lt;
&lt;
&lt;
&lt;

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

&lt;
&lt;
&lt;
&lt;

2
2
2
2

Inlet
5-13

172d
172
156
156

&lt;
&lt;
&lt;
&lt;

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'&lt;;2

80 &lt; 2
80 &lt; 2
84 &lt; 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

&lt;
&lt;
&lt;
&lt;

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&gt;

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

}
&gt;

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)

)
(
(
&gt;

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 &gt;
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&gt;-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&gt;-dioxin and octachlorodibenzo-|&gt;-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

&lt; 30

&lt; 0.1

7

1

7

5-11

590

430

0.7

55

170

8

5-12

390

&lt; 30

&lt; 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
&lt; 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

&lt; 1

18

23

5-3

0300
0700
1100
1500
1900
2300

E
E
E
A

&lt;
&lt;
&lt;
&lt;
&lt;
&lt;

1
1
1
1
1
1

39
33
18
31
56
52

35
26
23
20
21
25

0300
0700

A
A

\
J

&lt; 1

12

0

D

1

&lt; 1

34

7

1500

A

&lt; 1

29

52

C
A

\
/

6

34

32

0300
0700

A
E

»
/

&lt; 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

&lt; 1
&lt; 1
&lt; 1
124
&lt; 1
&lt; 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
&lt; 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

&lt;l

31

25

}

&lt; l

36

36

}

&lt;&gt;

8

13

1

28

17

25

I »

37

26

I

57

100

I »

60

12

&lt; 1

28

7

&gt;

2

19

0

A
E

}

18

34

8

C
C

\

2

35

7

E
B
C
E
E

&lt; 1
&lt; 1
&lt; 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

&lt; 1

21

5

5-16

0100
0500
0900
1300
1700
2100

E
C
C
E
B
D

&lt; 1

26
26
50
44
6
24

6
8
7
6
6
6

7
&lt;
&lt;
&lt;
&lt;

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

&lt; 1

0

0

\
f

14

0

0

\
f

1,350

0

0

A

&lt; 1

25

0

961
62
778
\
&gt;

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

&lt; 1

0

0

A

}
1

389

8

3

1900
2300

5-12

&lt; 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

&lt; 1

0

0

0300
0700

A

}
J

&lt; 1

0

0

1100
1500

B \
A I

&lt; i

o

o

B

A

108
467
&lt; 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

&lt; 1
2,700

0
5

50
10

5-15

0300
0700
1100
1500
1900
2300

A
A
B
B
A
B

22
8,070
&lt; 1
&lt; 1
&lt; 1
&lt; 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
&lt; 1
45
&lt; 1
&lt; 1

16
0
0
17
6

15
0
0
1
6

5-17

0000

B

&lt; 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&gt; \
\ A&gt;/
()
%

Test day

Date

TOC1
(ng/£)

5

5-9

&lt; 30

14

16

6

5-10

&lt; 30

0

0

7

5-11
5-14

&lt; 30
&lt; 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
&lt; 0.12
0.20
1.10, 1.04
1.07
0.83, 0.80
&lt; 0.12
&lt; 0.12, &lt; 0.12
0.63
1.10
0.68
&lt; 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

(«/«&gt;

TOC1

13

19

19

19

M_rA

g&gt;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)
&lt;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)

&lt; 1
&lt; 1
3
2.9
21
21
12
2.2
15
10
6.6
&lt; 1

&lt; 5.5
&lt; 5.3
16
14
87
103
60
11
53
34
24
&lt; 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
&lt; 16
22,800
200
&lt; 17

Deterain- 13
ations

ro

4,300
110
0
470
260
730
130
230
130
&lt; 1
1,350
12
&lt; 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&gt;
•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&gt;-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&gt;

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 &amp; 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 &amp; 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 &amp; 3

Test started at 0945 and ran for 560 minutes. Test quality good.

Outlet Ports 1 &amp; 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 &amp; 3

Test started at 0958 and ran for 560 minutes. Test quality good.

Outlet Ports 1 &amp; 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 &amp; 3

Test started at 1000 and ran for 560 minutes. Test quality good.

Outlet Ports 1 &amp; 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 &amp; 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 &amp; 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 &amp; 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 &amp; 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 &amp; 3

Test started at 1000 and ran for 560 minutes. Test quality good.

Outlet Ports 1 &amp; 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
&lt;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 &amp; 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 &amp; 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 &amp; 3

Test started at 1005 and ran for 640 minutes, Increased time due to
lower plant output. Test quality good.

Outlet Ports 1 &amp; 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&gt;

ro
i
ro

3-7

6

Ou,,e,
3-8

7

s^ln

Oullet

3-9

"&gt;"« 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
&lt;2
&lt;2
&lt;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

&lt;2
&lt;2
&lt;2
&lt;2
&lt;2
&lt;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&gt;bed

370.46
352.55

4.43
4.43

14.41
14.41

17.00
17.00

&lt;2
&lt;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

&lt;2
&lt;?

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

&lt;2
&lt;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 &gt;xl

351.00
335.86

4.59
4.59

13.92
13.92

16.00
16.00

&lt;2
&lt;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

&lt;2
&lt;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

&lt;2
&lt;2
&lt;2
&lt;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

&lt;2
&lt;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

&lt;2
&lt;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.&amp;7

21 00
21.00
1800
1800

&lt;2
&lt;2
&lt;2
&lt;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

&gt;2&lt;

""*&lt; £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

&lt;*«•• 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

"&gt;"• ££

Oiillrl
A
8
C
0
E
F
G
H
1
J
K
L

1.2.3&amp;4

1.2.3&amp;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

&lt;2
&lt;2
&lt;2
&lt;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

&lt;2
&lt;2
&lt;2
&lt;2

102.11
10867
10405
9683

14.40
14.40

2200
2200
22.00
2200

&lt;2
&lt;2
&lt;2
&lt;2

10685
9909
107.18
95.48

23.00
2300
2400
24.00

&lt;2
&lt;2
&lt;2
&lt;2

10017
10807
9982
93.81

&lt;2
&lt;2
&lt;2
&lt;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

&lt;2
&lt;2
&lt;2
&lt;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

&lt;2
&lt;2
&lt;2
&lt;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

&lt;2
&lt;2
&lt;2
&lt;2

10354
11599
11045
10266

365.47

5.4

132

&lt;2

10372

13.2

&lt;2

101.06

&lt;2
&lt;2
&lt;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&gt; 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

&lt;2
&lt;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

&lt;2
&lt;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

&lt;2
&lt;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

&lt;2
&lt;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

&lt;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

&lt;2
&lt;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

&lt;2
&lt;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

&lt;2
&lt;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

&lt;2
&lt;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

&lt;2
&lt;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

&lt;2
&lt;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

&lt;2
&lt;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

&lt;2
&lt;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

&lt;2
&lt;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

&lt;2
&lt;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

&lt;2
&lt;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

&lt;2
&lt;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

&lt;2
&lt;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

&lt;2
&lt;2

-

Inlet
Outlet

3-23

5.9
8.8

1.09
.75

12.7
10.1

1.08
.74

NOT OPERATING

&lt;2
&lt;2

_

Inlet

3-24

_

I

Inlet
Outlet

3-25

Inlet
Outlet

3-26

H

•

.24

H

H

&lt;2

_

13.8
13.1

.71
.26

H

H
M

&lt;2
&lt;2

-

M

.87
4.9
13.7
DATA TAKEN FOR INLET ONLY

.73

M

N

&lt;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'

&lt;A&gt;

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»&gt;
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

.£&gt;
I

i- ro

TEMPERATURE
FLUE GAS IN

INDUCED
DRAFT
FAN

AIR HEATER

LEAKAGE

AT1JVS BIN

REFUSE
DERIVED
FUEL

STACK (6
SAMPLI

&gt;

UNTREATED
-WELL WATER

PULVERIZER
N&gt;
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

'',&lt;,&gt;!,&gt;' ,'&gt;;

r '

, &gt;,

"&gt;

|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&gt;

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 &amp; 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 .£
•&gt;

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&gt;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&lt;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

&lt;P

7P

8P

9P

Keen

a

35
32.7

35
32.5

36
32. &lt;

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&gt;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&gt;

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&gt;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&lt;,
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&gt; 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&gt;

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

&gt;50

&gt;50

&gt;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&gt; 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&gt;

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&gt;

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&gt;

•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

&gt;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&lt;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

&gt;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&lt;&gt;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

&gt;50

&gt;50

&gt;50

&gt;50

&gt;SO

&gt;SO

»50

&gt;50

»50

&gt;50

&gt;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

&gt;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

&gt;50

44

44

No Ulf

11:05A

19

&gt;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

&gt;SO

4.8

44

43

&gt;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

&lt;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&lt;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&amp;A. I-.3SP, 7:54P. 10:00f&gt;

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&gt; 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&gt;

V

7P

8f&gt;

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&gt; 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&gt;

840

ago

Feeduater flow r»te
1000's Ibs/hr

(0
CO

840

Uu&gt; 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&gt;«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&gt;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

&gt;50

&gt;50

&gt;50

&gt;50

&gt;50

&gt;50

&gt;50

&gt;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

&gt;60

&gt;50

&gt;50

&gt;50

&gt;50

&gt;50

&gt;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&gt;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

_•&lt;""• 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

&gt;: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

&gt;50

&gt;50

&gt;50

&gt;50

&gt;50

&gt;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&gt;

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&gt;

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"'*'
""«&lt;
Ou
"«
""«
Ou
&lt;"&lt;
°«««&lt;
""«

£2
£2
22
22
S3
22
*2S
22
22

O"""

5-4

£2

'•"«&lt;
°—
'"•«
*""•&lt;
°"&lt;"'

£2
£2
2SL
rf
22
£2

"?

THC
ppm

Stock
Temperature
*F

Molecular
Weight

Moisture

177®
172
156
156

&lt;2
&lt;2
&lt;2
&lt;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

&lt;2
&lt;2
&lt;2
&lt;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

.

&lt;2
&lt;2
&lt;2
&lt;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

.

&lt;2
&lt;2
&lt;2
&lt;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

&lt;2
&lt;2
&lt;2
&lt;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

&lt;2
&lt;2
&lt;2
&lt;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

&lt;2
&lt;2
&lt;2
&lt;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

&lt;2
&lt;2
&lt;2
&lt;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

&lt;2
&lt;2
&lt;2
&lt;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

&lt;2
&lt;2
&lt;2
&lt;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

&lt;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

&lt;a

North
South

324.920
331.750

9.20
9.40

10.3
10.3

10.0
10.0

80
80

&lt;2
&lt;2

218.810

6.20

10.7

9.0

84

&lt;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&amp;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&gt;-*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&gt;F)
Cn*«tfo« Mr Flo- 3
late
Chart Recorder (ft /hr)
Digital Integrator (ftVhr)
Conbustlofi Atr Tei^erature (*F)
Veneni 0&gt;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. &gt;
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

&lt;2
&lt;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

&lt;2
&lt;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

&lt;2
&lt;2

11.6

1.10

Inlet
Outlet

I

1.38
0.90

Inlet
Outlet

N&gt;

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

&lt;2
&lt;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

&lt;2
&lt;2

14.1

1.98

Inlet
Outlet

5-10

8.8

1.36

&lt;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

&lt;2
&lt;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

&lt;2
&lt;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 .,

&lt;2

H

n

N

M

.38
.14

"

"

&lt;2
&lt;2

11.6

5.60

9.4
9.7

.38
.18

112
98

36.01
25.70

&lt;2
&lt;2

15.6

2.71

1.39
1.32

8.5
7.9

.18
.16

88
98

61.92
75.58

&lt;2
&lt;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

&lt;2
&lt;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

•&gt;

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&gt;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 &amp; 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&gt;

- .

68-01-5915

! (G)
1C*. Spon c ,orrii? Or^ani* .itii'n Namf and Address

13. Type of Report &amp; 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&gt;v-~^rlrnent of Commerce

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05297

Author
Corporate Author
RODOrt/ArtlGlB TltlB Correspondence and Notes: Testimony for EPA
Hearings, 1979-1980

Journal/Book TltlB
Yaar

000

°

Month/Day
Color

D

Number of Images

°

DOSCriptOH Notes

Items were filed together under the label "Testimony for EPA
Hearings."

Tuesday, March 05,2002

Page 5297 of 5363

�7979
Mr. Mark Wine
Kirkland &amp; Ellis Law Firm
1776 K Street NW
Washington ,D.C. 20006
Dear Mark:
Per our conversation of
date , please find enclosed:
1. Pkg of Abstracts/Presentations related to TCDD.
2. Four Technical Reports
3. Chapter 5 of my book on
2,4,5-T.

AUVIN L. YOL'NG, Mainr, USAF
Consultant, EnviionnK'faui Sciences

�LAW O F F I C E S

LA FOLL.ETTE, J O H N S O N , SCHROETER &amp; DEHAAS
JOHN T. LA FOLLETTE
D A R E N T. J O H N S O N
R U D O L F H. SCHROETER
B. E. A T K I S S O N
LOUIS H. DEHAAS
W. T. M A S K E Y
DOROTHY L.WOTRING
C. GARY A R D I Z Z O N E
ALFRED W. GERISCH, JR.
NANCY L. M E N Z I E S
DENNIS G . B E Z A N S O N
B R I A N W. A H E R N E
JACK HYLTON C L A R K
ROBERT W. STEVENSON
LLOYD E. P E A K E
BONNIE ANN BAKER
ROBERT B. PACKER
SABRIELE MARGIT PRATER

A P R O F E S S I O N A L CORPORATION

TELEPHONE
(2131 3 8 O - 3 I 3 I

SUITE 26OO EQUITABLE PLAZA
3435 W I L S H I R E B O U L E V A R D
LOS ANGELES, CALIFORNIA 9 O O I O

OF COUNSEL:
MARK MULLIN

September 6, 1978

Dr. Alvin Young
5226 Prince Valiant
San Antonio, TX
78218
Re:

Paul Reutershan vs. Dow Chemical Co., Hercules,
Shamrock, Rohdia and North American Philips

Dear Dr. Young:
This reiterates my telephonic attempt to retain you as litigation
consultant to my client, The Dow Chemical Company,in its defense
against Paul Reutershan and such other Vietnam veterans as may
yet file suit for injuries allegedly suffered from exposure to
Agent Orange. We do not yet know what specifically Reutershan
claims but anticipate allegation that he developed cancer and
an assortment of other ills.
Please let me know on what basis and in what areas you will be
able to consult with Dow and be assured that my client and I
look forward to working with you.
Sincerely yours,
LA FOLLETTE, JO

HROETER &amp; DEHAAS

BY

RUDOLF H. SCHROETER

RHS:k

�&gt;"
'}

Capt Younq/KCE/3667/27Nov78/kb

/( / ^^ '

I 9 NUV 1978
ECE

2,4,5~T Rebuttable Presumption Against Registration OPP 30000/26
Federal Register Section
Technical Services Division (WH-569)
Office of Pesticide Programs, EPA
Room 401, East Tower
401 M Street SW

Washington DC 20460
1. The attached Air Force Technical Report (USAF OEHL-TR-78-92) on "The
Toxicology, Environmental Pate, and Human Risk of Herbicide Orange and
its Associated Dioxin", is provided in reference to my letter to the
Federal Register Section, dated 4 August 1978.
2. Significant data in this report that relate to the RPAR against
2,4,5-T herbicide include:
a. Data on the analysis of 492 samples of Herbicide Orange (a 50:50
mix of the n-butyl esters of 2,4-D and 2,4,5-T) for TCDD (See Chapter 1).
The levels of TCDD ranged from &lt;0,02 to 15 ppm in herbicide produced during
the 1965-1968 time period. The weighted mean concentrations of TCDD in
Herbicide Orange was 1.98 ppm. The samples were taken from surplus
Herbicide Orange.
b. Industrial hygiene and ambient air sampling data from all landbased dedrumming/transfer operations of Project PACER HO, the 1977 USAF
project to dispose of 2.22 million gallons of Herbicide Orange (see Chapter
II). Results of these sampling programs revealed that under the worst case
noted, the levels of 2,4,5-T (and 2,4-D) vapors were well below the timeweighted Threshold Limit Value (TLV) for each of these materials. The
detected levels were at least two and, in most cases, three orders of
magnitude below the TLVs. TCDD was not detected in any air samples.
Approximately 200 personnel carried out the dedrumming/transfer operations.
Comparisons of available pre- and post-operational medical examinations of
military personnel involved have revealed no apparent physical effects as
a result of these activities.
c. An assessment of the world's scientific literature on the toxicity
of 2,4,5-T, 2,4-D and TCDD in selected laboratory and domestic animal
species (see Chapter IV). Each chemical was critically reviewed fors
1. Acute and short-term toxicity potentials.

2. Subacute and chronic toxicity potentials.

RCF

�33 Absorption , distribution , a,nd excretion potentials.
4. Bmbrvotoxic , fatotoxic, and teratogenie potentials.
5. Carcinogenic and tumorigenio potentials.
6. Mutagenic and eytogenj.e potentials,
d. A review of available scientific data on numerous incidents involving suspected 2 , 4 , 5-T/TCnD poisoning of humans or livestock (see Chapter v) .
Extensive efforts in translating over 30 major foreign documents permitted
for the first time detailed accounts of 23 industrial episodes that involved
exposure of over 1,100 people? to TCDD. An assessment of the medical data
from these industrial episodes and other episodes was made in Chapter VI.
Some of the significant medical conclusions
1. Adverse effects of 2,4,5-T herbicide should manifest themselves
shortly after exposure. Symptoms arising for the first time months to years
after the last exposure are probably due to an etiologv other than the
herbicide.
2. The hallmark of TCDD exposure is chloracne and its absence makes
it unlikely that systemic disorders present are related to TCDP. Asthenic
and vegetative symptoms are often present in overexposure but are difficult
to interpret. They would normally be expected to clear with time.
3. There is no conclusive evidence at this time that neither
3,4,5~T herbicide nor TCPD is mutagenic, teratogenic, or earcinoerenie in wan.
3. I and other Air Fore© ^scientists are continuing studies on the environmental fate of TCD1X These studies' will be forwarded to the EPA Federal
Register Section as they become available.
SIGNED
ALV.TN I,. YOtMO, Captain, USAF, Ph.D.
.

Environmental Sciences Consultant
Herbicide Specialist

3 Atch

-

nSAF OETO

**-78-92 (3)

�DEPARTMENT OP THE AIR PORCE
USAP OCCUPATIONAL AND ENVIRONMENTAL HEALTH LABORATORY (AFSC)
BROOKS AIR FORCE BASE, TEXAS 78235

REPLY TO
ATTN OF:

___
ECE

Literature Requests for Studies of 2,4,5-T and TCDD

T0;

Mr. James Miller
Reader's Digest
P. 0. Box 366
Croton on Hudson NY

10520

1. The attached documents are provided per your request for literature
on ecological studies of 2,4,5~T and TCDD.
2. More research has been conducted on the phenoxy herbicides than on
any other class of herbicides. Numerous bibliographies on the phenoxy
herbicides and TCDD have been published by the Texas Agricultural Experiment station, College Station, Texas. I have attached Volumes I through
IV for your information (Atch 1-4) . Volumes V through VIII have been
recently released and can be acquired from the Texas Agricultural
Experiment Station.
3. The Council for Agricultural Science and Technology (CAST) has
published an extensive review of the use and environmental fate of 2,4,5-T
(Atch 5). This document includes a current appraisal of hazards involving
both herbicide application and the dioxin contaminant.
i.
4. Air Force studies of the environmental fate of 2,4,5-T and TCDD are
contained in four attached Air Force Technical Reports. Three Technical
Reports are pertinent studies on the fate of 2,4,5-T and its trace contaminant, TCDD, in an ecosystem treated with massive quantities of phenoxy
herbicides. Technical Reports AFATL-TR-74-12 (Atch 6), AFATL-TR-75-49 (Atch
7), and AFATL-TR-75-142 (Atch 8), detail ecological studies conducted on
a unique 3.0 km^ military test area (Test Area C-52A, Eglin AFB FL) that
received approximately 73,000 kg 2,4,5-T and 77,000 kg 2,4-D during the
period of 1962-1970. Significant results included:
a. At the termination of spray equipment testing programs in 1970,
significant levels (ppm) of 2,4,5-T soil residues were found throughout
the test area. However, no residues of 2,4,5-T were detected (detection
limits of 10 ppb) in any soil samples collected during 1971-1972.
b. Fifty-four soil samples were collected to a depth of 15 cm from
throughout the test area and analyzed for TCDD. TCDD levels ranged from
&lt; 10 to 1,500 parts per trillion (ppt). The median concentration was
30 ppt, while the mean was 165 ppt.
c.

An ecological survey extending over a five-year period documented

�the presence of more than 123 different plant species, 77 bird species,
71 insect families, 20 species of fish, 18 species of reptiles, 18 species
of mammals, 12 species of amphibians, and 2 species of mollusks. At least
170 biological samples were analyzed for TCDD, including 30 species of
animals. No TCDD was found in any of the plant species examined. However,
TCDD was found in nine species of animals, including two rodent species:
beachmouse (300-1,500 ppt, liver) and hispid cotton rat ( 10-210 ppt, liver);
three species of birds: meadowlark (100-1,020 ppt, liver), mourning dove
(50 ppt, liver), and Savannah sparrows (69 ppt, liver); three species of
fish: spotted sunfish (85 ppt, liver), mosquitofish (12 ppt, whole body), and
sailfish shiner (12 ppt, whole body), and one reptile, the six-lined racerunner
(360-430 ppt, muscle). A composite sample of insects (whole bodies) contained
40 ppt TCDD.
d. Gross pathology was done on all species collected for TCDD residue
analyses. Histopathological examinations were performed on over 300 beachmice or hispid cotton rats from the test area and a control field site.
Examinations were performed on the heart, lungs, trachea, salivary glands,
thymus, liver, kidneys, stomach, pancreas, adrenals, large and small intestine,
spleen, genital organs, bone, bone marrow, skin and brain. Initially, the
tissues were examined on a random basis without the knowledge of whether the
animal was from a control or test area. All microscopic changes were recorded,
including those interpreted as minor or insignificant. The tissues were than
reexamined on a control and test basis, which demonstrated that the test and
control mice could not be distinguished histopathologically. Similar histopathological studies were conducted on the fish and racerunners with no
significant abnormalities being found.
5. Technical Report USAFA-TR-76-18 (Atch 9) is a summary of Air Force
ecological research on TCDD. It also presents analytical data on the soil
degradation of TCDD when in the presence of 2,4,5-T and 2,4-D. Significant
results included:
a. The half-life of TCDD in soils containing 2,4-D and 2,4,5-T appeared
to be between 225 and 275 days.
b. Studies of bacteria, actinomycetes and fungi from soil plots treated
with massive quantitites of 2,4-D and 2,4,5-T (5,000-40,000 ppm) confirm that
these microorganisms proliferate to such an extent that they were probably
using the herbicides and TCDD as metabolic carbon sources and, as such, were
contributing to their degradation.
c. Movement of TCDD in the abiotic portions of the environment occurred
by wind or water erosion of soil particles, but leaching by water alone did
not occur.
6. Per your request, I have also attached a report on the Seveso, Italy
TCDD Episode (Atch 10) by Dr. G. Reggiani, and on the Australian 2,4,5-T
Episode by Aldred, et al (Atch 11).
7. If I can provide any' additional copies of any of these documents or
elaborate on our findings, please contact me.

�our inquiry.

ALVIN L. YOUNG, Captain, USAF,
Environmental Sciences Consultant
USAF Herbicide Specialist

11
1.
2.
3.
4.
5.
6.
7.
8.
9.

Atch
Selected Bibliography,
Selected Bibliography,
Selected Bibliography,
Selected Bibliography,
CAST Report
AFATL-TR-74-12
AFATL-TR-75-49
AFATL-TR-75-142
USAFA-TR-76-18

Vol
Vol
Vol
Vol

10. Reggiani's Sevesjfeo Report
11. Australian Report

I
II
III
IV

�LAW OFFICES

LA FOLLETTE, J O H N S O N , SCHROETER &amp; DE H A A S
JOHN T. LA FOLLETTE
DAREN T. JOHNSON
RUDOLF H. SCHROETER
B. E. A T K I S S O N
LOUIS H. DE HAAS
W. T. M A S K E Y
DOROTHY L . W O T R I N G
A L F R E D W. OERISCH, JR.
NANCY L. M E N Z I E S
B R I A N W. AHERNE
R O B E R T W. S T E V E N S O N
ROBERT B. PACKER
G A B R I E L S M A R O I T PRATER
DONALD C. FESLER

TELEPHONE

PROFESSIONAL CORPORATION

(213) 6 6 6 - 3 6 O O
32O NORTH V E R M O N T A V E N U E
LOS ANGELES, CALIFORNIA 9OOO4

February 21, 1979

OF COUNSEL:
SAM YORTV
MARK MULLIN

Dr. Alvin Young
5226 Prince Valiant
San Antonio, Texas 78218
Re:

RPAR of 2,4,5-T

Dear Dr. Young:
This reiterates my telephonic request that you obtain USAF
consent to act as consultant and expert witness for The Dow
Chemical Company in its preparation for, and presentation of
evidence at, the hearing which will probably be held in late
1979 no matter what determination EPA makes.
I am co-counsel for Dow with the Washington, D.C. (and Chicago)
law firm of Kirkland &amp; Ellis. We would value your participation
and shall await your word regarding when, where, in what areas
and on what basis you will be able to consult with us and our
client.
Sincerely your

LA FOL

, SCHROETER &amp; DE HAAS

BY
RUDOLF H. SCHROETER
RHS:k

�K1RKLAND &amp; ELLIS
Washington Office

1776 K Street, N.W.
Washington, D.C, 20006

ChlcagQ Qfflce

Area Coda 202 857-5000

Area Code 312 861 -2000
Telex 25-4361
200 E. Randolph Drive
Chicago, III. 60601

To Call Writer Direct '
202 857- 5 0 2 4

April 9, 1979
To:

Potential Dow Witnesses at EPA Hearing

As you may have noticed in the April 4 order of the EPA
hearing panel, each of you will be required to submit sworn
written statements in advance of your appearance at the
hearing. To assist in the preparation of your initial
drafts, a few general suggestions follow below. We anticipate working closely with you to insure that your draft
testimony addresses the relevant issues as clearly and '
accurately as possible. We hope to receive your draft
testimony in Washington as soon as possible. When ready,
please send your drafts by express mail or special delivery.
(1) You should include a caption on the very first
page of your testimony as indicated below:
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

In re:

Emergency Suspension Orders
for 2,4,5-T and Silvex

)
)

FIFRA Docket Nos.
409, 410

TESTIMONY OF JOHN SMITH

(2)

In many cases, a table of contents will be help-

ful.
(3) Your opening paragraph or page should briefly review your educational and professional background, with the
details to be included by your current curriculum vitae and
publication list (which should be attached as an exhibit).

�KIRKLAND&amp;ELUS
Dow Witnesses
April 9, 1979

Page 2

(4) Except for very short testimony, a. brief introduction and summary of the main points to be made are usually
helpful.

(5) Since we can introduce as exhibits any published
or unpublished research work relevant to your testimony,
it is unnecessary to include in great detail in your written
statement the experimental methodology. Emphasis should be
placed on a brief review of data and the significance and
conclusions that you draw from that data to the issues at
hand.
(6) Often, short titles for subparts of the testimony
will be useful.
(7) Since the rules require that your statement be
sworn, we recommend the following language be included immeidately before your signature line:
"The above statements are, to the best of my
knowledge, true and correct. April
, 1979."
John Smith
Your signature should be notarized.
If you have any questions concerning any aspect of
the preparation of your written testimony, or otherwise
have questions concerning your participation in the hearings,
please call either John Hahn ((202) 857-5097) or me ((202)
857-5024).
I have also enclosed for your use a copy of the Appendix
to the EPA rebuttal comments. Let me know if you want copies
of any of the references.
Sincerely,

L. Mark Wine

�K1RKLAND8.ELLIS
Dow Witnesses
April 9, 1979

Page 2

(4) Except for very short, testimony, a brief introduction and summary of the main points to be made are usually
helpful.
(5) Since we can introduce as exhibits any published
or unpublished research work relevant to your testimony,
it is unnecessary to include in great detail in your written
statement the experimental methodology. Emphasis should be
placed on a brief review of data and the significance and
conclusions that you draw from that data to the issues at
hand.
(6) Often, short titles for subparts of the testimony
will be useful.
(7) Since the rules require that your statement be
sworn, we recommend the following language be included immeidately before your signature line:

"The above statements are, to the best of my
knowledge, true and correct. April
, 1979."
John Smith
Your signature should be notarized.
If you have any questions concerning any aspect of
the preparation of your written testimony, or otherwise
have questions concerning your participation in the hearings,
please call either John Hahn ((202) 857-5097) or me ((202)
857-5024).

I have also enclosed for your use a copy of the Appendix
to the EPA rebuttal comments. Let me know if you want copies
of any of the references.
Sincerely,

L. Mark Wine

�KIRKLAND&amp;&lt; ELLIS
Washington Office
Area Code 202 857-5000

1776 K Street, N.W.
Washington, D.C. 20006

To Call Writer Direct

202857-5018

October 24,

1979

TO:

Chicago,in.eoeoi

Dow Cancellation Hearing Witnesses

RE:

Chicago Office
Area Code 312 861 -2000
Telex 25-4361
200 E. Randolph Drive

January 22, 1980 Hearing Date

At the prehearing conference held on October 17, Administrative Law Judge Finch set January 22, 1980 as the date for beginning the 2,4,5-T and silvex cancellation hearings. While it
remains possible that some delay could result from ongoing discovery activities or from the Agency's consideration of proposed
hearing notices for the nonsuspended uses, we do not anticipate
any prolonged postponement of the hearings.
At present, we are engaged in completing discovery initiated by Dow and EPA in July. In addition, we are conducting discovery related to a limited number of EPA witnesses, in accordance
with the Administrative Law Judge's directions at the October 17
prehearing conference.
The opponents of continued registration, including EPA,
the Environmental Defense Fund, and the Northwest Coalition for
Alternatives to Pesticides, will present their witnesses first
during the hearings. Nevertheless, it is important that the
written witness statements of Dow witnesses be available in substantially final form prior to January 22, so that we may turn
our full attention to cross-examination of opposing witnesses at
the hearings themselves, and with your assistance prepare to meet
the allegations made by EPA, EOF, and NCAP. We will be working
closely with many of you in the coming weeks in order to facilitate completion of your statements.

�KIRKLAND8.ELLIS
October 24, 1979
Page Two

The next prehearing conference has been set for December 4 .
We will continue to advise you of developments in the proceedings
and will attempt to provide you with a rough estimate of scheduling
for Dow's case as soon as possible.
Sincerely yours,

Edward W. Warren
Counsel for The Dow Chemical
Company

�Memorandum to Dr Welch

29 October 1979

1. On Friday, 26 Oct 1979, Bill Morrison, SAF/GC, called to discuss
Al Young's role in the upcoming 2,4,5-T cancellation hearings. He indicated that the issue on health effects and environmental fate, where Al
will be expected to testify, is not expected prior to the 22nd of January.
He reaffirmed that Agriculture will request Al as a witness. The USDA
attorney, Margaret Brienholt, needs a one paragraph synopsis of the
general nature of Al's testimony. It should be caveated, at the beginning,
with words to the effect, "this testimony does not represent the official
position of the Air Force, but rather represents the personal views of
Major Al Young as an individual expert."
2. Mr Morrison indicated that he would be pleased to review the full text
of Al's testimony. He will call Mr Schroder, the DOW attorney, to inform
him that Major Young will be a government witness. I asked Mr Morrison if
Al should continue to have dialogue with the DOW Company. He advised that
Al should have jao more substantive discussions wi.th_DOW, and that he should
"start to have"dialogue withthe USDA~Tawyer, Margaret Brienholt. He
emphasized that Al should be sure that USDA knows what the bottom line is.
Mr Morrison also indicated that he would ^appreciate a briefing from_Al__at
the earliest opportunity. He would appreciate your advising Al so that he
can "take care of the above requirements.
3. As a matter of interest, I have told both Grant and
working for you, but I guess it is just easier for them
certainly don't mind, but I'm not up to speed enough in
to make suggestions when appropriate. I hope the above
heartburn.

WILLIAM E. MABSON, Colonel, USAF, BSC
Commander

Bill that Al is now
to reach me. I
what you are doing
does not create any

�BRIEF DESCRIPTION OF TESTIMONY*
31 October 1979

Alvin L. Young, Ph.D.
5226 Prince Valiant Drive
San Antonio, TX 78218

Dr. Young, a United States Air Force scientist who has
extensively studied 2,4,5-T, will testify on the persistence,
environmental fate and toxicology of 2,4,5-T and TCDD.
Dr. Young will present results of hts seven-year study,
at Eg!in Air Force Base, Florida, on an area where plant
and animal populations were continuously and heavily exposed to massive amounts of phenoxy herbicides applied
in the course of developing aerial spray equipment for
military use.
EXHIBITS
Sturrock, T. T., and A. L. Young. 1970. A histological study
of Yucca filamentosa L. from Test Area C-52A, Eglin
Reservation, Florida. Technical Report AFATL-TR-70-125,
Air Force Armament Laboratory, Eglin AFB, Florida. 9 p.
Hunter, J. H. and A. L. Young. 1972. Vegetative succession
studies on a defoliant - equipment Test Area, Eglin AFB
Reservation, Florida. Technical Report AFATL-TR-72-31,
Air Force Armament Laboratory, Eglin AFB, Florida. 23 p.
Young, A. L. 1974. Ecological studies on a herbicide - equipment Test Area (TA C-52A), Eglin AFB Reservation, Florida.
Technical Report AFATL-TR-74-12, Air Force Armament
Laboratory, Eglin AFB, Florida. 146 p.
Young, A. L., C. E. Thalken, and W. E. Ward. 1975. Studies of
the ecological impact of repetitive aerial applications of
herbicides on the ecosystem of Test Area C-52A, Eglin AFB,
Florida. Technical Report AFATL-TR-75-142, Air Force
Armament Laboratory, Eglin AFB, Florida. 127 p.

* Testimony for the 2,4,5-T Administrative Hearings before EPA,
January 1980. This testimony does not represent the official
position of the Air Force, but rather represents the personal
views of Dr. Alvin L. Young (USAF, Major) as an,individual expert.

�Young, A. L., C. E. Thalken, E. L. Arnold, J. M. Cupello, and
L. G. Cockerham. 1976. Fate of 2,3,7,8-tetrachlorodibenzop-dioxin (TCDD) in the environment: summary and decontamination recommendations. Technical Report USAFA-TR-76-18,
United States Air Force Academy, Colorado. 41 p.
Arnold, E. L., and A. L. Young. 1976. A rapid gas chromatographic
method for the determination of several phenoxyalkanoic acid
herbicides in soil samples. Technical Memorandum FJSRL(NC)TM76-5, Frank J. Seiler Research Laboratory, United States
Air Force Academy, Colorado. 16 p.
Young, A. L., J. A. Calcagni, C. E. Thalken, and J. W. Tremblay.
1978. The toxicology, environmental fate, and human risk of
Herbicide Orange and its associated dioxin. Technical Report
OEHL-TR-78-92. USAF Occupational and Environmental Health
Laboratory, Brooks AFB, Texas. 247 p.
Cockerham, L. G., A. L. Young, and C. E. Thalken. 1979.
Histopathological and ultrastructural studies of liver tissue
from TCDD-exposed beach mice (Peromyscus polionotus). Technical
Report, Frank J. Seiler Research Laboratory (AFSC), United
States Air Force Academy, Colorado. 46 p.

�DEPARTMENT OF AGRICULTURE
OFFICE OF THE GENERAL COUNSEL
WASHINGTON, D.C. 20250

A

OCT251979
WilliamB. Morrison, Esquire
Air Force General Counsel's Office
Pentagon
Room 4C-927
Washington, D.C.
20550
Dear Mr., Morrison:

.
*

As we discussed on October 23, 1979, we are pleased to sponsor Major
Alvin L. Young, USAP, as a witness in the 2,4,5-T administrative hearings
which will be held under the Federal Insecticide, Fungicide and Rodenticide
.Act, (FIFRA), as amended 7 U.S.C. §136, et seg._/ before the Environmental
Protection Agency.
I plan to file a pleading very soon which will list Major Young as a
witness on behalf of the Secretary of Agriculture. I will send a rough
draft of this paper when it is prepared. Enclosed is a copy for your
information of the initial request for a hearing filed by the Secretary,
our tentative witness list for the risk and exposure portion of the
presentation of evidence, and a proposed list of topics for the agenda
of the third prehearing conference held on September 19, 1979, which
sets forth the Secretary's position in these proceedings. I would
appreciate any comments or suggestions you have on the description of
Major Young's testimony.
I look forward to working with you and Major Young. The hearing record
should benefit greatly from Major Young's expertise, research, and
experience.
Sincerely,

MARGARET M. BREINHOLT
Attorney
Enclosure

�DEPARTMENT OF AGRICULTURE
OFFICE OF THE GENERAL COUNSEL
WASHINGTON, D.C.

20250

December 6, 1979

Alvin L. Young, Major, USAF, Ph.D.
Consultant, Environmental Sciences
USAFSAM/EK

Brooks AFB, Texas

78235

Dear Major Young:
I am planning to sponsor you, on behalf of the Secretary of Agriculture
for the United States, as an expert witness in the 2,4,5-T/silvex administrative
hearings which are being held under the Federal Insecticide, Fungicide
and Rodenticide Act (FIFRA), as amended, 7 U.S.C. §136, et seq., before
the Environmental Protection Agency (FIFRA Docket No. 415, et al.).
Your appearance in these hearings has been discussed with William Morrison,
Esquire, Air Force General Counsel's Office, and he informs me that the
Office of General Counsel has no objections to your appearing to testify
in the proceedings.
Would you please confirm in writing your availability to present this
testimony. At this stage in the hearings it is very difficult to
estimate a time when you would be needed in Washington to give your
statement. I will keep you informed on the progress of the proceedings
to enable you to plan your schedule at your convenience.
Sincerely,

MARGAffeT M. BREINHOLT
Attorney

cc: William B. Morrison, Esq.
Air Force General Counsel's Office
Pentagon

�DEPARTMENT OF THE AIR FORCE
WASHINGTON 20330

OFFICE or THE ASSISTANT SECRETARY

1 2 DE C 1979

MEMORANDUM FOR AF/SG

SUBJECT:

Cancellation Hearings on Herbicide 2,4,5-T

The Environmental Protection Agency (EPA) is conducting
administrative hearings on the cancellation of the use of
2,4,5-T, pursuant to the Federal Insecticide, Fungicide and
Rodenticide Act, as amended, 7 U.S.C., §136 et seq.
The Air Force General Counsel's Office was notified on
October 25, 1979, that the United States Department of Agriculture (USDA) is listing Major Alvin L. Young as a private
expert witness on behalf of the Secretary of Agriculture, and
not as a spokesman or representative of the United States Air
Force. The Dow Chemical Company also expressed their desire
to list Major Young as a witness. However, Dow did not pursue the matter once they were informed that the Department
of Agriculture intended to sponsor Major Young.
Force General Counsel's Office advised me that
any party to the administrative hearing has the power to request
the Administrative Law Judge to issue a subpoena compelling
the testimony of Major Young under 7 U.S.C. §136 (d). Therefore, given Major Young's outstanding credentials and the
Administrativ~e"~"Law~~Judgel s subpoena power, Major Young has no
real alternative but to testify at the hearing. I am pleased
that he is being called as a witness -for a Federal agency,
rather than a private party, since most of his research has
been performed with Federal funds during his service in the
Air Force.
Although the administrative hearing schedule is still
uncertain, the Department of Agriculture has stated that
Major Young will probably not be required to testify before
May 1980. I am aware that Major Young's participation may
impose certain hardships on not only himself, but on your
staff functions as well. Nevertheless, I would greatly
appreciate it if you would take the necessary action to
assure that he is available for the hearings. Unless you
advise me otherwise, I will instruct the General Counsel's
Office to inform the USDA on or about January 2, 1980, that
Major Young will be available.

JOE F. MEIS
Acting Assistant Secretary
cf the Air Force
(.V.tMpower, Reserve Affairs
and Installations

�DEPARTMENT OF THE AIR FORCE
HEADQUARTERS UNITED STATES AIR FORCE
BOLLING AFB, D.C. 2O332

15 JAN 1300
REPLY TO
ATTN OF:

SGES

SUBJECT cancellation Hearings on Herbicide 2,4,5-T
HQ AFSC/SG
1. Request that action be taken to insure that Major Young is
available to the Department of Agriculture as outlined in the
attached memorandum.
2. It is my understanding that the referenced hearings have
now moved from May 1980 to April 1980.
FOR THE CHIEF OF STAFF

PHILLIP G. BROWN, Major US, BSC
Assistant for Bioenvironmental
Engineering
Office of the Surgeon General
1st Ind, AFSC/SGP
TO:

1 Atch
OAS/M,RA&amp;L) Memo,
12 Dec 79

2 2 JAN i960

AMD/SG

1. Maj Al Young has been committed by Maj Gen Dettinger and SAF MI to
testify in the administrative cancellation hearings on herbicide 2, 4, 5-T.
Maj Young's testimony is expected to be requested in the April-May 1980 time
frame.
2. Attached are memos containing related background material.
FOR THE COMMANDER

onel, USAF, BSC
Command Bioenvironmental Engineer
Office of the Command Surgeon

2 Atch
1. nc
2. (Added) HQ USAF/SG Ltr,
15 Jan 80

�MEMORANDUM FOR RECORD

15 Jan 80

SUBJECT: 2,4,5-T Administrative Hearings
1. On 5 Nov 79, I briefed Dr. Welch (SAM/CD) on my potential
participation in the EPA Administrative Hearings on 2,4,5-T
Herbicide. Dr. Welch suggested that I prepare a memorandum
to him for forwarding to AFSC/SG.
2. Following the meeting with Dr. Welch, I contacted Mr. Bill
Morrison (SAF/GC) and informed him of the proposed action. He
recommended that I wait to forward such a memorandum until after
he investigated the ramifications of my potential participation
as a witness for USDA. He indicated that he would call USDA/GC
and discuss the situation. On 16 November, he called to inform
me that on my next TOY to Washington I should plan an additional
day for coordinating my testimony with both SAF/GC and USDA/GC.
3. On 4 December, I visited with Mr. Morrison and Ms. Breinholt
(USDA/GC) at the USDA, Washington, DC. I outlined my area of
testimony and she discussed USDA's plans and the time table
for the hearings. I should have my testimony to her NLT
28 February 1980. She will officially send a letter to SAF/GC
and USAFSAM/CD requesting my participation in the hearings.
Mr. Morrison will coordinate a letter from SAF/MI to USAF/SG
encouraging my participation in the hearings.

ALtftNL. YOUNG, Major, USAF
Consultant, Environmental Sciences

�DEPARTMENT OF THE AIR FORCE
HEADQUARTERS UNITED STATES AIR FORCE
BOLl.ING AFB, D.C. 2O332

15 JAN198o

MEMORANDUM FOR ACTING ASSISTANT SECRETARY OP THE AIR FORCE
(MANPOWER, RESERVE AFFAIRS AND INSTALLATIONS)
SUBJECT:

Cancellation Hearings on Herbicide 2,4,5-T

Per your request, Major Young's schedule will be arrange
so as to accommodate the needs of the Department of Agriculture,

GARTH B. DETTINGER
Maj General, USAF, MC
Deputy Surgeon General

�DEPARTMENT OF THE AIR FORCE
USAF SCHOOL OF AEROSPACE MEDICINE (AFSC)
BROOKS AIR FORCE BASE, TEXAS
78235

REPLY TO
ATTN OF:

SUBJECT;

TO;

16 JAN 1980

CD

Update on Various Herbicide Orange Activities
SAM/CC
AMD/SG
AMD/CO
IN TURN
1 . Major Young, SAM/EK, has been requested to act as an expert
witness for the US DA in an EPA hearing regarding continued use of
2,4,5-T. Attachment 1 contains the background correspondence on
this. I have asked Major Young to coordinate all requests for infoi—
mation through my office prior to dispatch of this information to the
General Counsel's Office. At the time of dispatch, we will forward
an info copy of the letter of transmittal and a listing of documents
provided to AMD/SG, AFSC/SG and AF/SGPES. If you wish
something different, let me know.
2.
Also for your information is an input to the DoD representative
on the VA Advisory Connmittee regarding potential exposure to Orange
in Vietnam (Atch 2). Finally, I would call your attention to page 6 of
HR 3892 (Atch 3) which was signed into law on 20 Dec 79 (PL 96-151).
This directs VA to study the dioxin question. Presumably the VA
does not consider the Ranch Hand study to be in conflict with their
responsibility.

BILLY E. WELCH,
Deputy Director

Ph.D.

3 Atch
1 . EPA Document w/2 Atch
2. Position Paper
3. H.R. 3892
Cy to:

EK/Col Lathrop
EK/Maj Young

�THE UNITED STATES
ENVIRONMENTAL PROTECTION AGENCY

)

In re:

Notice of Intent To Cancel
)
Certain Registrations for 2,4,5-T )
And Silvex
)

FIFRA Docket Nos. 415, et seq.

SUPPLEMENTARY ADDITION TO THE TENTATIVE WITNESSES LIST
PROPOSED ON BEHALF OF THE SECRETARY OF
AGRICULTURE FOR THE UNITED STATES

The Secretary of Agriculture for the United States wishes to submit
an addition to the proposed tentative witness list filed on his behalf
on July 17, 1979, in this proceeding.
A brief summary of the subjects which the witness will discuss is
included below.
Name:

Alvin L. Young, Major, USAF
Consultant, Environmental Sciences

United States Air Force
Occupational &amp; Environmental Health Laboratory
SUSAF

OEHL

Brooks, AFB, Texas

78235

Background;
Dr. Young received his Ph.D. in Agronomy (Herbicide
Physiology) from Kansas State University in 1968. He has
been engaged in studies concerned with phenoxy herbicides
and their effects from 1968 to the present. In addition
to wide-ranging responsibilities concerned with phenoxy
herbicides and other materials Dr. Young has conducted
ecological studies on the fate of TCDD.
Subject Area of Testimony;
Dr. Young, a United States Air Force scientist who has
extensively studied 2,4,5-T, will testify on the persistence,
environmental fate and toxicology of 2,4,5-T and TCDD.
Dr. Young will present results of his seven-year study,
at Eg1in Air Force Base, Florida, on an area where plant
and animal populations were continuously and heavily
exposed to massive amounts of phenoxy herbicides applied
in the course of developing aerial spray equipment for
military use.

I

�We are in the process of reviewing Dr. Young's publications
and plan to submit a list of proposed exhibits soon.
Respectfully submitted,

MARGARET M. BREINHOLT
JUDITH A. WENKER
TERRENCE G. JACKSON

By

Attorneys
Office of the General Counsel
U.S. Department of Agriculture
Washington, D.C. 20250
(202) 447-4733

�DEPARTMENT OF THE AIR FO*CE
\VA5MINCSt~ON J01JO

3 DEC 1979

MEMORANDUM FOR AP/KG
SUBJECT:

Cancel la t ion Hearings on Herbicide 2,4,5-T

The Environmental Protection Agency (EPA) is conducting
administrative hearings on the cancellation of the use of
2,4,5-T, purnu^nt to the Federal Insecticides, Fungicide and
Rodent.icicle Acb, an amended, V U..S,C., 3136 ct se
Th« Air Force General Counsel's off..-lee was notified on
October 2'i, 1079, that the Unito.d Staters Department of Agriculture (OSDA) ir&gt; listing Major Alvin L. Young ar, a private
expert witness on behalf of the Secretory of Agriculture, and
not as a spokesman or representative of. tbo United States Air
Force. Thr- Dow Chemical Company al?o expressed their dociro
to list Major Younc? as a witness. Ho'-'..?v&gt;r, Dow did not pursufi the matter onof they were informed that, th« Denarrtmont
of Agriculture intended to sponsor Major Young.
Tho Air Force General Counsel ' s Offico acivj.rjpsd me that
any party to the administrative hoar ing has the power to roquftct
tha Aominir.trative Law Judge to issuo a subpoena r-ompelling
the testimony of Major Young under 7 U.S.C. 8136 (dU Therefore, givon M«jor Young1 e outstanding crcdonLials arid the
Administrative Law Judge's subpoena povrvr, Major Young has no
real alternative but to testify nt the .'aoaring. T am pleased
thr.it ho x?3 being callod as a v/itnoss for a Focleral agoncy,.
rather tli.in a private party, since mout, ol his research ha?,
been performed with Federal funds during his service in the
Air Forco.
Although the administrative:! hearing schedule is ntill
uncort.Jtln, the Dopartmont of Agriculture hag trtat-cd that
Major Young will probably not ba requ.-i rod to t^.^tify before
May 1980. I am aware that Major Young r partic.ipa!;ion may
impose certain liardshipa on not only himself, buL on your
stal:£ functions a;; well. Nevertheless, T would greatly
iite it if you would tak« tho. necessary action to
-chat he is available for the htv.rj.ngs, Unleran you
advise.! tic1! otherwise, I will instruct i:v&gt;o. Genera.! Cr.vjnn«l's
OL.CJCO to inform the USDA ort or about a/muary 2, .1980, that
Major Young will be available.

jor r.
Air

(iv.,;c|''-v.',:r,

Affairs

�DEPARTMENT OF AGRICULTURE
OFFICE OF THE GENERAL COUNSEL
W A S H I N G T O N , D.C. 20250

December 6, 1979

Alvin L. Young, Major, USAF, Ph.D.
Consultant, Environmental Sciences
USAFSAM/EK

Brooks AFB, Texas

78235

Dear Major Young:
I am planning to sponsor you, on behalf of the Secretary of Agriculture
for the United States, as an expert witness in the 2,4,5-T/silvex administrative
hearings which are being held under the Federal Insecticide, Fungicide
and Rodenticide Act {FIFRA), as amended, 7 U.S.C. §136, et seq., before
the Environmental Protection Agency (FIFRA Docket No. 415, et al.).
Your appearance in these hearings has been discussed with William Morrison,
Esquire, Air Force General Counsel's Office, and he informs me that the
Office of General Counsel has no objections to your appearing to testify
in the proceedings.
Would you please confirm in writing your availability to present this
testimony. At this stage in the hearings it is very difficult to
estimate a time when you would be needed in Washington to give your
statement. I will keep you informed on the progress of the proceedings
to enable you to plan your schedule at your convenience.
Sincerely,

MARGARET M. BREINHOLT
Attorney

cc: William B. Morrison, Esq.
Air Force General Counsel's Office
Pentagon

�POSITION PAPER
Advisory Committee on Health-Related Effects of Herbicides

Question #10: Can criteric"1 be established for determining the level of
exposure of military personnel to dioxin during the Vietnam
war based on spraying tapes and unit histories?

Coordinator: COL J. W. Thiessen, M.D.

�CRITERIA FOR ESTIMATING EXPOSURE LEVLLS
OF MILITARY PERSONNEL TO DIOXIN AND HERRICIDL ORANGE
DURING THE VIETNAM WAR

Any attempt to determine exposure levels of military personnel to
Herbicide Orange and its associated dioxin must be predicated on events that
occurred at least 10 years ago. Since there were no routine occupational or
environmental sampling programs associated with the handling or dissemination
of the herbicides in South Vietnam, a quantitative determination of exposure
can only be subject to speculation. In addition, since specific no-effect
criteria for comparison with actual or derived values do not exist, the
calculation of theoretical exposure levels might provide data in the absence
of a means to assess their significance. The approach taken in this document
is to develop data points for determining "relative" exposures to Herbicide
Orange and dioxin (TCOD). The population at risk certainly did not include
all military personnel who served in South Vietnam. Moreover, within the
military population at risk, the range in magnitude of exposure must have
been great. Therefore, it is important to evaluate those factors which would
have influenced the potential for a given individual to be "at risk" and
those which would have influenced the magnitude of- that exposure. The
following factors for determining relative exposures are proposed:
Tjme
When was the individual in South Vietnam?
Duty
What job(s) did the individual perform?
Exposure
What was the situation at the time of exposure?
What aircraft/vehicle was involved in the exposure?
How did the exposure occur?
Each of these questions will be discussed and available data will be provided
in order to evaluate the magnitude of exposure.

�I. WHEN WAS THE INDIVIDUAL IN VIETNAM?

This issue of time is very important. Not all of the herbicides used in
South Vietnam were used throughout the entire 10 years (1962-1971)
encompassed by the Department of Defense (DOD) defoliation program. In
addition, 2,4,5-T formulations used early in the program are believed to have
contained higher levels of TCDD than did the formulations used in the later
years. The three time periods shown in Table 1 can be differentiated on the
basis of specific herbicides used and the mean dioxin content.
TABLE 1. THE DIFFERENTIATION OF THREE TIME PERIODS DURING THE US MILITARY
DEFOLIATION PROGRAM IN SOUTH VIETNAM*

Period

_____

Herbicides Used
Mean Dioxin Content
[Code Names) ______________ (PJL!lts R?C J!!Llll°Jll.t_

January 1962 June 1965

Purple, Pink, Green
Blue

July 1965 June 1970

Orange
White, Blue

-2 §
0

July 1970 October 1971

White, Blue

0

* Source:

-32t
0

Young et al.3

t Found only in 2,4,5-T containing formulations,
t Value based on analyses of five samples.
§ Value based on the analyses of 488 samples.
Herbicide Orange was the most extensively used herbicide in South
Vietnam. Orange accounted for approximately 10.7 m i l l i o n gallons of the
total 17.7 million gallons of herbicide used (Table 2). It was used from
mid-1965 to June 1970. However, as noted in Table 2, Orange was not the only
2,4,5-T containing herbicide used in the defoliation program. Small
quantities of Purple, Pink, and Green, all containing 2,4,5-T were used from
1962 through mid-1965. In subsequent sections of this document, the term
"Herbicide Orange" will refer to all of the 2,4,5-T containing herbicides
used in Vietnam (Purple, Pink, Green, and Orange).

�TABLE 2.

NUMBER OF GALLONS OF MILITARY HERBICIDE PROCURED BY Til!.: US
DEPARTMENT OF DEFENSE AND DISSEMINATED IN SOUTH VIETNAM DURING
JANUARY 1962 - OCTOBER 1971*

_Cod[e__Najne

Orange
White
Blue
Purple
Pink
Green

ti^jbj9jj^e.

2,4-L); 2,4,5-T
2,4-D; Picloram
Cacodylic Acid
2,4-D; 2,4,5-T
2,4,5-T
2,4,5-T
Total

__

Quan ti_ty_

10,646,000
5,633,000
1,160,000
145,000
123,000
8,200
1.7,7 057200

_

Per;iqd_qf Gs_o_

1965~19/Qt
1965-19/lf
1962-19/lf
1962-1965
1962-196';)
1962-1965

* Source: Young et al.^
t Last fixed-wing mission of Orange 16 April 1970; last helicopter mission of
Orange 6 June 1970.
t Last fixed-wing mission 9 January 1971; all herbicides under US control
stopped 31 October 1971.
II. WHAT JOB(S) DID THE INDIVIDUAL PERFORM DURING HIS TOUR(S) IN SOUTH
VIETNAM?

There were relatively few military operations that involved the handling
of herbicides by military personnel. It is, thus, appropriate to examine
both the functions, or jobs, where individuals would have been at risk, and
to estimate the size of the population at risk.
a. Populations at Risk.
A review of operations involving Herbicide Orange in South Vietnam from
January 1962 to April 1970 revealed that there were essentially three groups
of US military personnel potentially exposed to Herbicide Orange and its
associated dioxin contaminant. These three groups were:
1. "Operation RANCH HAND" personnel actively involved in the
defoliation program. This group included aircrew members and maintenance and
support personnel directly assigned to the RANCH HAND squadrons,
2. Personnel assigned to selected support functions that may have
resulted in exposure to Herbicide Orange. This group included, for example,
personnel who sprayed herbicides, using helicopters or ground application
equipment; personnel who may have delivered the herbicides to the units
performing the defoliation missions; aircraft mechanics who were specialized
and occasionally provided support to RANCH HAND aircraft; or, personnel who
may have flown contaminated C-123 aircraft, but were not assigned to RANCH
HAND (e.g., during the Tet Offensive, all RANCH HAND aircraft were
reconfigured to transport supplies and equipment, and were assigned to
non-RANCH HAND squadrons).

�3. Ground personnel who may have been inadvertently sprayed by
defoliation aircraft or who, during combat operations, may'have entered an
area previously sprayed with Herbicide Orange.
)ujation Estimates.
The total number of US military personnel exposed to Herbicide Orange is
not known. Approximately 1,200 RANCH HAND personnel were exposed in direct
support of the defoliation operations; however, there are no data on the
number of non-RANCH HAND personnel who may have been exposed. The actual
number of people may be in the thousands since at least 100 helicopter spray
equipment units were used in South Vietnam, and most military bases had
vehicle-mounted and backpack spray units available for use in routine
vegetation control programs. The number of military ground personnel who nay
have inadvertently been sprayed by RANCH HAND aircraft, or who may have
entered areas recently sprayed with Herbicide Orange during combat operations
is not known. Approximately 10 percent of South Vietnam was sprayed with
herbicides, and most of this area was contested and/or controlled by enemy
forces. As estimated frequency of occurrence for selected exposure scenarios
is given in Table 3.
TABLE 3.

ESTIMATED FREQUENCY OF EVENTS WHERE MILITARY GROUND PERSONNEL MAY
HAVE KEN EXPOSED TO HERBICIDE ORANGE

jj/ent
Direct application of herbicide on
ground troops

Rare

Ground troops moving into area treated
within 24 hours

Seldom

Ground troops entering a defoliated
area (1 month or more after herbicide
application)

Frequent

Discussions with RANCH HAND aircrew members confirmed that in at least one
instance in 1967, direct application of herbicide onto a Marine patrol did
occur. The basic concept for the major use of the defoliation program, i.e.
the use of chemicals to remove foliage to enhance visibility, supports the
contention that it was unlikely that troops would be in areas to be treated,
or would move into the areas immediately after treatment since the desired
effect would not be evident until 3 to 6 weeks after the herbicides were
applied. However, the occurrence of the first two scenarios in Table 3
cannot be ruled out.

�III.

WHAT WAS THE SITUATION AT THE TIME THE INDIVIDUAL WAS EXPOSED?

There are a number of exposure scenarios in which an individual v/ar» more
likely to have been significantly exposed to a specific herbicide; or even
another pesticide, including:
1. Guards at a base perimeter.
2. An individual at a Special Forces camp in the inland forest.
3. An individual on combat patrol in the Rung Sat Special Zone.
4. An individual repairing contaminated aircraft.
5. A supply clerk or depot aide handling drums of chemicals.

These different situations could have exposed individuals to varying amounts
of different herbicides and insecticides since the use patterns of these
chemicals differed markedly.
Use Patterns of Individual Herbicides.
Each of the three major herbicides (Orange, White, and Blue) had specific
uses. Ninety-nine percent of Herbicide White was applied in defoliation
missions. It was not recommended for use on crops because of the persistence
of Picloram in soils. (Because the herbicidal action on woody plants was
usually slow, full defoliation did not occur for several months after spray
application. Thus, it was an ideal herbicide for use in the inland forests
in areas where defoliation was not immediately required, but where it did
occur it would persist longer than if the area were sprayed with Orange or
Blue.
Herbicide Blue was the herbicide of choice for crop destruction
missions involving cereal or grain crops. Approximately 50 percent of all
Blue was used in crop destruction missions in remote or enemy controlled
areas with the remainder being used as a contact herbicide for control of
grasses around base perimeters.
Ninety percent of all Herbicide Orange was used for forest
defoliation and it was especially effective in defoliating mangrove forests.
Eight percent of Herbicide Orange was used in the destruction of broadleaf
crops (beans, peanuts, ramie, and root or tuber crops). The remaining 2
percent was used around base perimeters, cache sites, waterways, and
communication lines.
Table 4 shows the number of acres in South Vietnam within the three
major vegetational categories.

�TABLE 4.

THE NUMBER OF ACRES TREATED IN SOUTH VIETNAM, 1962-1971, WITH
MILITARY HERBICIDES WITHIN THE THREE MAJOR VEGETATIONAL CATEGORIES

Vegetational Category

_____ Areas Jreated*

Inland forests
Mangrove forests

2,6/0,000
313,000

Cultivated crops

'
Total

* Areas receiving single or multiple coverage.

__ 260^000
372^8,000

Source:

Certain portions of South Vietnam were more likely to have been subjected to
defoliation. Herbicide expenditures for the four Combat Tactical Zones of
South Vietnam are shown in Table 5. These data were obtained from the HERBS
tape^ and total volume is not in complete agreement with the actual
procurement data shown in Table 2 because volume was calculated via spray lino
data (an estimate of rate of application and area sprayed).
TABLE 5. US HERBICIDES EXPENDITURES IN SOUTH VIETNAM, 1962-1971:
BREAKDOWN BY COMBAT TACTICAL ZONE*

A

Herbi cide Ex pencil Lure
(gal Ions)
Orange
Whitp

Combat Tactical Zones

Blue

CTZ I

2,250,000

363,000

298 ,000

CTZ II

2,519,000

729,000

473 ,000

CTZ III
(includes Saigon)

5,309,000

3,719,000

294 ,000

CTZ IV

1,227,000

43S.OOO

62 ,000

11,305,000

5,246,000

1J27 ,000

Subtotals
Grand total

* Source:

17,678,000

HERBS tape2

In addition to the herbicides, numerous other chemicals were shipped
to South Vietnam in 55-gallon drums. These included selected fuel additives,
cleaning solvents, cooking oils, and a variety of other pesticides. The

�insecticide Malathion was widely used for control of mosquitoes and at least
400,000 gallons of it were used from 1966 through 1970. In addition, much
smaller quantities of Lindane and DDT were used in ground operations
throughout the war in Southeast Asia. The distribution of the herbicides
within Vietnam after their arrival did not occur randomly. About 65 percent;
was shipped to the 20th Ordnance Storage Depot, Saigon, and 35 percent was
shipped to the 511th Ordnance Depot, Da Nang.
IV.

WHAT MILITARY AIRCRAFT/VEHICLE WAS INVOLVED IN THE EXPOSURE?

Numerous aircraft were used in the air war in Vietnam, but only a few of
these aircraft were used for aerial dissemination of herbicides. The "work
horse" of Operation RANCH HAND was the C-123/UC-123, "Provider." This cargo
aircraft was adapted to receive a modular spray system for internal carriage.
The module (the A/A 45 Y-i) consisted of a 1,000-gallon tank, punp, and
engine which were all mounted on a frame pallet. An operator's console was
an integral part of the unit, but was not mounted on the pallet. Wing booms
(1.5 inches in diameter, 22 feet long) extended from the outboard engine
nacelles tov/ard the wing tips. A short tail boom (3 inches in diameter, 20
feet long) was positioned centrally near the aft cargo door. Each aircraft
normally had a crew of three men: the pilot, co-pilot; (navigator), and
flight engineer (console operator). During the peak activity of RANCH HAND
operations (1968-1969), approximately 30 C-123/UC-123 aircraft we?re employed.
However, many other squadrons of non-RANCH HAND C-123 aircraft were routinely
used throughout South Vietnam in transport operations.
The control of malaria and other mosquito-borne diseases in South Vietnam
necessitated an extensive aerial insecticide application program in order to
control these vector insects. From 1966 through 1972, three C-123 aircraft
were used to spray Malathion, an organophosphate insecticide. These aircraft
could be distinguished from the Herbicide-spraying aircraft because they were
not camouflaged. These aircraft routinely sprayed insecticide adjacent to
military and civilian installations, as well as in areas where military
operations were in progress, or about to commence.
Approximately 10 to 12 percent of all herbicides used in South Vietnam
was disseminated by helicopter or ground application equipment. Generally,
helicopter crews were not assigned to herbicide spray duties on a full-time
basis and rotated the spraying duties with other mission requirements. The
military UH-1 series of helicopters, deployed by the Air Force, the Army, and
Navy units, generally sprayed the herbicides. The most common spray system
used was the AGRINAUTICS unit. This unit was installed in or removed from
the aircraft in a matter of minutes because it was "tied down" to installed
cargo shackles and aircraft modifications were not required for its use. The
unit consisted of a 200-gallon tank and a collapsible 32-foot spray boom.
The unit was operated by manual controls to control the flow valve and a
windmill brake. Generally, each helicopter had three crew members.

�A summary of the aircraft used in herbicide and insecticide operations is
shown in Table 6. Ground crews that maintained these aircraft were also at
risk for exposure to the herbicides and insecticides.
TABLE 6.

US MILITARY AIRCRAFT USED IN THE DISSEMINATION
INSECTICIDES IN SOUTH VIETNAM*

Aircraft

OF HERBICIDES AND

Camouflaged

Chemical Disseminated

Yes
No

All Herbicides
Malathion

Yes

Grunge, Blue

C-123/UC-123
C-123
Helicopter
Air Force UH-F
Army UH-1B/UH-1D
Navy UH-1E

* Source: Young et al.
Various ground delivery systems were also used in South Vietnam for
control of vegetation in limited areas. Most of these units were towed or
mounted on vehicles. One unit that was routinely used was the Buffalo
turbine. It developed a wind blast with a velocity up to 150 mph at 10,000
ft-Vminute volume. When the herbicide was injected into the air blast, it
was essentially "shot" at the foliage. The Buffalo turbine was useful for
roadside spraying and applications of perimeter defenses. The herbicides of
choice in these operations were Blue and Orange.
V.

HOW DID THE EXPOSURE OCCUR?

As previously noted, the population at highest risk was the RANCH HAND
group since these individuals were exposed to herbicides on a daily basis.
Non-RANCH HAND support personnel who handled herbicides and performed
secondary level maintenance were also at risk. Beyond these limited
populations, the likelihood of other individuals being heavily exposed to
herbicides was significantly less. The exposure of personnel could have
occured by essentially three routes:
1. Percutaneous absorption and inhalation of vapors/aerosols by
direct exposure to sprays.
2. Percutaneous absorption and inhalation of vapors by exposure to
treated areas following spray application, and
3. Ingestion of foods contaminated with the material.

8

�As previously discussed, the use of Herbicide Orange in South Vietnam was
for the purpose of denying the enemy the cover of dense jungle foliage. The
areas normally sprayed were remote, unpopulated, forested areas where very
few, if any, US military personnel were located and the exposure to direct
spray of Herbicide Orange would have been unlikely. In addition, because of
the dense canopy cover, the target of the defoliation operation, the amount
of herbicide penetrating to the forest floor would have been small. The
chemical and physical characteristics of Herbicide Orange and the spray, as
it would have occurred following dissemination from a C-123, are important
factors in assessing relative exposures to the Herbicides and TCDD.
Table 7 reviews the pertinent chemical and physical characteristics of
Herbicide Orange. Table 8 reviews both the application parameters of the
spray system used in the C-123 aircraft and the characteristics of the spray
characteristics
itself. Generally, herbicides were sprayed in the early morning or late
afternoon, so as to minimi/e the effects of air movement on part; cle
dispersion.
TABLE 7. PERTINENT CHEMICAL AND PHYSICAL CHARACTERISTICS OF HERBICIDE ORANGE

Formulation Concentrated

(8.6 Ib .ai/yal )*

Water Insoluble

Density &lt;= 1.28

Vapor Pressure

3.6 x 10-4 mm Hg at 30r

NBEt 2,4-D

:

1.2 x 10-4

NBE 2,4,5-T

:

0.4 x 10-4

TCDD

:

1 x 10-4

Viscous

40 centipoises at 20°C

Noncorrosive to metal
Deleterious to paints, rubber, neoprene
Long shelf life

* Pounds active ingredient (2,4-D and 2,4,5-T) per gallon.
t NBE = Normal butyl ester

�TABLE 8.

APPLICATION PARAMETERS AMD SPRAY C H A R A C T E R I S T I C S OF THE C-123
MODULAR INTERNAL SPRAY SYSTEM

A i r c r a f t speed

130 K1AS*

Aircraft altitude

150 ft

Tank volume

1,000 y,il

Spray time

3.5-1 i;iin

Particle size:
&lt; lOO/i 1.9%
100-5UOjj 7fi.2%
&gt;500y 21.97,

87% impacted within 1 min
13% drifted or v o l a t i l i z e d
Mean particle volume

0.61 ;il

Spray swath

260 j:20 ft

Mean deposition

3 (jcil/acre

Total area/tank

340 acres

* Knots indicated air speed.
Ground combat forces normally would not have been expected to have
entered a previously treated area for several weeks after treatment, during
which time numerous environmental factors would have reduced the potential
for exposure to military personnel. Young et al.3 have conducted an indepth
review of the environmental fate of Herbicide Orange and TCDD. The following
is a summary from that report:
. . . Available data indicate that the vast majority of the
phenoxy herbicides would impact forest canopy, the intended
target. Rapid uptake (e.g., within a few hours) of the ester
formulationis of %,4-D and 2,4,5-T would occur. Mont of the
herbicide probably would undergo rapid degradation (weeks) within
the cellular matrix of the vegetation. However, some of
herbicide may remain unmetabolized and would be deposited on the
forest floor at the time of leaf fall. Soil microbial and/or
chemical action would likely complete the dc&lt;jr\idakion procc-on.

10

�Herbicide droplets that impacted directly on soil or water would.
probably hydrolyze rapidly (within hours). Biological and
nonbiological degradative processes would further occur to
significantly reduce these residues. Some violatilization of the.
esters of 2t4-D and 2,4tf&gt;-T would occur during and immediately
after application. The volatile mater-Lai most likely would
dissipate within the foliage of the target area.
Photodecomposition of TC'DD would minimize the amount of
biologically active volatile residues moving downwind of the
target area.
Accumulation of phenoxy herbicides in animals may occur following
ingestion of treated vegetation. The magnitude of this
accumulation would likely be at nontoxic levels. Herbicide
residues in animals would rapidly decline after withdrawal from
treated feed.
Most TCDD sprayed into the environment during defoliation
operations would probably photodegrade loithin 24 hours of
application. Moreover, recent studies suggest that even w-ithin
the shaded forest canopy, volatilization and subsequent
photodeaomposition of TCDD would occur. Since translocation into
Vegetation would be minimal, most TCDD that escaped
photodegradation would enter the soil-organic complex on the
forest floor following leaf fall. Soil chemical and microbial
processes would further reduce TCDD residues. Bio concentration
of the remaining minute levels of TCDD may occur in liver and fat
of animals ingesting contaminated vegetation or soil. However,
there are no field data available that indicate that the levels
of TCDD likely to accumulate in these animals would have a
biological effect.
The environmental generation of TCDD from 3,4,5-T residues,
through thermal or photolytic processes, would be highly unlikely
and of no consequence. . . .
VI. CONCLUSIONS.
While a precise determination of herbicide exposure cannot be achieved,
the five factors discussed in this document might permit both a
characterization and a relative estimate of the magnitude of the exposure.
In the preparation of a total exposure for a given individual, answers to the
five questions must be determined for each exposure incident, and a summary
exposure estimate developed.

11

�LITERATURE CITED
1. Committee on the Effects of Herbicides in South Vietnam 1974. Part A:
Summary and Conclusions. National Academy of Science, Washington, DC,

398 p.
2. HERBS tapes. 1971. Computer data on herbicide missions in Vietnam,
1965-1971. Department of Defense, Washington, DC.
3. Young, A. L., J. A. Calcagni, C. E. Thai ken, and J. W. Tremblciy. 1978.
The Toxicology and Environmental Fate, and Human Risk of Herbicide
Orange and its Associated Dioxin. Technical Report OEHL-TR-78-92.
USAF Occupational and Environmental Health Laboratory, Brooks Air Force
Base, TX 78235, 247 p.

12

�2d Ind to HQ USAF/SGES Ltr, 15 Jan 80, Cancellation Hearings on Herbicide
2,4,5-T
HQ AMD/SG
TO:

2 9 JAN 1980

USAFSAM/CC

Forwarded for your information and action.
FOR THE COMMANDER

&lt;H^f*~"~^-*r*'-y

1S\

_—JOHfjR. WATSON
Colonel, USAF, MSC
; Director of Medicine &amp; Education

2 Atch
nc

�DEPARTMENT OF AGRICULTURE
OFFICE OF THE GENERAL COUNSEL
WASHINGTON. D.C. 20250

APRioisao
Dr. Rodney W. Bovey
USDA - SEA
Department of Range Science
Texas A S M University
College Station, Texas 77843
Dear Rod:
This is to fol low-up on my telephone request for your appearance as a
witness at the 2,4,5-T/silvex'cancellation hearings. The hearing opened
on March 14 when EPA witnesses began testifying. It is difficult to
estimate when witnesses will be presented on behalf of the Secretary of
Agriculture but we will follow EPA's witnesses in the schedule. Therefore,
we need to prepare for your appearance at the hearings very soon. We
will need a written statement from you either pertaining to your inputs
to the USDA-EPA-States joint assessment report titled "The Biologic and
Economic Assessment of 2,4,5-T" or (if you did not work with the team or
contribute information to them) detailing your expertise on matters such
as 2,4,5-T or silvex application, evaluation, chemical analysis, or
field use.
Our effort In the cancellation hearing will be directed toward identifying
and presenting relevant scientific data. These facts will be the foundation
of our case. Your statement should fully describe the facts known to
you and identify what document or other supporting materials, such as
personal experience .and discussions with other knowledgeable observers,
can provide the basis for each fact. We will need a copy of each document
which is an exhibit or reference in support of your statement. If you
can anticipate questions that may be raised by others, please feel free
to discuss them with me and how you believe they can be addressed.
Reference documents such as field data, reports, or letters to the file
prepared at the time will add to your expert credibility when you are
describing your data and experience. I have enclosed for your use a
list of items needed in the preparation of our presentation. In order
to be prepared for the hearing, I will need .your draft witness statement
and supporting material by May 1.

�I have enclosed an outline of evidence which may be presented by the
»
Department at the hearings. If you have experience or knowledge relating
to these subjects, you should consider including that information in
your draft statement. These topics are somewhat general, and we would
appreciate your comments about specific topics which should be considered
also. Please feel free to call me at 447-2713 or Judith Wenker at 447-2286
or Al Rivas at 447-2714 to discuss these matters.
If you have questions regarding the preparation of your statement,
please contact us. Your efforts in helping us prepare for the hearings
are greatly appreciated.
Sincerely,

MARGARET M. BREINHOLT
Attorney
Litigation Division
Enclosure

y

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I

�DEPARTMENT OF AGRICULTURE
OFFICE OF THE GENERAL COUNSEL
WASHINGTON, D.C. 20250

APR 15 1980
Major Alvin L. Young
Consultant, Environmental Sciences
USAFSAM / EK

Brooks AFB, Texas

78235

Dear Major Young:
For your information, I am enclosing a copy of the letter which has been
sent to USDA employees who are scheduled to be witnesses in the "risk"
portion of the 2,4,5-T/silvex administrative hearings.
If you are close to finishing a draft of your proposed testimony, I
would appreciate receiving a copy as soon as possible. If you prefer,
you could send a copy to Mr. Heady, and he can arrange to provide it to
me and discuss it at his convenience.
It is difficult to tell you exactly when you may be scheduled to appear
for cross-examination on your written direct testimony. It is possible
that USDA may be required to present witnesses soon after June 1, and
the written statements must be filed at least two weeks before a witness
can appear.
Sincerely,

MARGARET M. BREINHOLT
Attorney, Litigation Division
Enclosure
cc: D. Heady, w/enc.

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&lt;p&gt;For more about this collection, &lt;a href="/exhibits/speccoll/exhibits/show/alvin-l--young-collection-on-a"&gt;view the Agent Orange Exhibit.&lt;/a&gt;&lt;/p&gt;</text>
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                    <text>Item D Number

°5654

D (jotScannail

Author
Corporate Author
RBDOrt/ArtlGlB TltlO Correspondence and reports relating to the CDC Agent
Orange Study, 1985

Journal/Book Title
Year

000

°

Month/Day
Color
Number of Imooos

D

°

Descripton Notes

Monday, March 25, 2002

Page 5654 of 5720

�DEPARTMENT OF THE ARMY
US A R M Y ft JOINT SERVICES ENVIRONMENTAL SUPPORT CROUP
1730 K STREET N.W. ROOM 21O
WASHINGTON. DC 20006-3608

»CI&gt;LVTO

December 4,

1985

A T T C N T I O N OF

DAAG-ESG

Dr. Vernon Houk
Director, Center for Environmental Health
Centers for Disease Control
1600 Clifton Road, NE
Atlanta, Georgia
30333
Dear Dr. Houk:
After analyzing and evaluating the AOP interim report
to OTA by our epidemiologist, a scientist and military analyst we found the report did not contain clear guidance in
the determination of possible exposure opportunity. The
material and data contained in this report, especially the
tables, are set up to demonstrate a single point of view
only. It would have been helpful to have the reader understand all the aspects of research, especially the use of
data from combat records. The comments that follow are submitted for your determination in having the best available
analysis of all sides of this complex issue. Further, where
errors are noted, it is requested that the report be
amended/corrected. The epidemiologist that reviewed the
report requests that we see the raw data in order to evaluate the tables. Nowhere in the report was it mentioned that
the methods for capturing and recording of all the data were
dictated by AOP and we fully complied. The AOP liaison officer
spent two years with the data abstractors in the completion
of 18 battalions.
The following are specific comments relative to Interim
Report No. 2:
a. AOP Statement (Section II - Exposure Opportunity
and Combat Selection, paragraph 1, page 2). " We have a list
of 65 combat battalions that served for at least 18 months
in III Corps during 1967 and 1968. This list, called the
AOP master list of battalions
"
ESG Comment - ESG at the request of AOP was directly
responsible for identification of the 65 units that were se-

�lected for the study. On 16 November 1983 we provided the master
list of 123 units which operated in the III Corps tactical
zone in 1967 &amp; 1968.
b.
AOP Statement ^Section II — Exposure Oppurtunity
and Cohort Selection , paragraph 4, subparagraph 2, page 2).M
The present selection criteria or a slight extension of
these will allow us to identify 17,000 U.S. Army veterans . . . . "
ESG Comment - We sent AOP 7,500 qualified personnel
data abstraction forms (under AOP's new criteria) in which
only 1,500 study subjects finally qualified for the study.
The view here is that the criteria should change only when it
becomes apparent AOP will not receive enough study subjects.
This changing of criteria is not considered a slight change
when 70% of the already qualified study subjects become disqualified .
c. AOP Statement (B. Selection of men from combat line
companies^paragraph 1 &amp; 2, page 11). " Additionally, our
projections show that in order to obtain the required number
of men (17,000 qualified veterans), it would be necessary to
select men from almost all of the units on the list and the
selection criteria may have to be changed."
ESG Comment; ESG has presently qualified 12, 500
study subjects for the study. The new criteria would eliminate
approximately 8,500 of these study subjects. AOP has added
significant criteria changes to the study which eliminate
large numbers of veterans. Before we eliminate study subjects we request Science Panel review, because of all the
work that has gone into this phase of this program.
d. AOP Change;
1967 &amp; 1968."

M

A veteran must only serve his tour in

ESG Comment; Every veteran we have qualified that
had served one or more days in 1966 or 1969 is disqualified,
even if the veteran experienced several herbicide exposures
while in a tracked unit during 1967 or 1968. We would like
AOP to explain to the Science Panel, why study subjects who
may register herbicide exposure hits in 1967 or 68 should be
disqualified. This eliminates significant numbers of study
subjects. A total of 828 study subjects were disqualified
from the first subgroup at AOP after qualification and abstraction at ESG. This change of criteria would require ESG
to review an additional 60,000 records for the study in

�order to qualify enbugh study subjects. This change will
disqualify the majority of the many study subjects that were
previously qualified by ESG and sent to AOP.
e. AOP Change; " Entire tour spent in units for which
location data is being collected."
ESG Comment; ESG is currently qualifying veterans
who served in a tracked unit but also transferred to units
that are not being tracked. Even if a veteran experienced
several herbicide exposures while assigned to a tracked
unit, he will be disqualified by AOP if he transferred to a
non-tracked unit. The reasoning AOP uses to disqualify
these veterans who were exposed has not been made clear. We
would like AOP to explain to the Science Panel, why study
subjects who may register multiple herbicide exposure hits
while assigned to tracked units and later assigned to
non-tracked units should be disqualified. This again eliminates high numbers of study subjects. A total of 1,871
study subjects were disqualified at AOP after qualification
at ESG from the first subgroup. The disqualification of
these veterans would require ESG to review additional records each month.
The disqualifying of such large numbers of veterans
could result in tracking of additional battalions in order
for AOP to qualify 17,000 veterans for the study. ESG is
currently reviewing over 6,000 records a month in order to
qualify 2,500 study subjects for use by AOP in which 70% of
the records are later disqualified at AOP. This is a major
increase in the quota every month. We completed the abstraction for the Vietnam Experience Study in which ESG
qualified 1,433 study subjects per month for AOP without
difficulty. This is a significant increase to ESG when
compared to the Vietnam Experience study. Every change
impacts heavily on extraction operations and cannot help but
affect time scheduling from ESG's standpoint.
f. AOP Statement (Section III - Quality and
Completeness of Location Information, paragraph 3, page 14).
"Limited reproducibllity conducted by AOP lead us to conclude
that the data are incomplete and inaccurate."
ESG Comment; The word "limited" might be a description
of the quality control functions AOP has performed to date.
The initial AOP quality control report dated 21 March 1985
states (see TAB A), "Assuming standard procedures for abstraction,

�these differences are due to either errbr In ESG's abstraction, error in AOP's or both. I scrutinized the documents, the sane for ESG and AOP, and found the latter to be
the case. Since the purpose of this report Is to review
ESG's abstraction of troop locations from Army documents,
the discussion that follows is limited to ESG's errors only.
Please note that "error" subsumes a variety of possible
mistakes and oversights and together they refer only to the
standard of abstraction outlined by AOP."
This report verlfys that AOP made errors in their QC
reabstraction process but still only stressed ESG's abstraction process. AOP used the term "possible errors" because
they cannot be completely sure they are errors.
The Epidemiologist, Scientist and Analyst have not had a
chance to analyze these points AOP extracted from the
records. It should be noted that AOP reabstracted or edited
their own abstractions countless times finding numerous
discrepancies from their original abstraction. There is no
yardstick. The rules changed and there is no way to
determine who is correct.
g. AOP Statement (A. Completeness and accuracy of
available location data, page 14). " The ability to reproduce
data is essential to establish the integrity and credibility
of a scientific study."
ESG Comment! It should be clear that there is nothing
comparable to laboratory data findings in the grid locations
and the recording of military data in journals and other
like records. They were never intended to be used for
epldemiologlcal studies. The definition of a grid coordinate means a reference point on the ground. One has to ask
the question who has more expertise and credibility concerning U.S. Army combat troop data, the U.S. Army or AOP?
h. AOP Statement (A. Completeness and accuracy of
location data, page 14)".... members of the AOP staff began
reabstracting data previously abstracted by ESG on selected
units. These AOP staff members were trained by the ESG
abstraction supervisor prior to beginning the process."
ESG Comment; The facts are that one member of AOP
Staff receivedtraining from the ESG supervisor for three days
It would be desirable if we could make an expert on the battalion tracking process in three days but this is just not
possible. It is apparent the AOP abstractors encountered
numerous problems and difficulties when they performed their

�quality control mission. AOP had to go over their own
abstraction countless times. AOP's latest QC report in July
contained errors.
1. AOP Statement (A. Completeness and accuracy of
available location data, paragraph 1, page 14). " We now have
completed data for four months on three different battalions and
present the results in table 7."
ESG Comment: AOP has attempted to provide a rather
one sided view of the data. AOP has provided charts which
show AOP's initial reabstraction compared to ESG's data. AOP
does not state in the report that they reviewed their abstraction and found numerous errors in their original abstraction. AOP did not provide their edited or reabstracted
tables to the Science Panel. These edited and reabstracted
tables were originally reported in AOP's first Quality
Control Report dated 21 March 1985.
j. AOP Statement (A. Completeness and accuracy of
available location data, paragraph 1, page 14). " We compare the
difference between the average of the locations found in the
two independent abstractions of the data on the battalions,
the abstraction originally supplied by ESG and the reabstraction completed by AOP. If the number of points representing unit locations and the general area in which they
occurred were similar for the two Independent abstractions,
we would expect this distance between the centroids to be
small. This, however, was not the case for many of the days
within the period studied."
ESG Comment; First of all, AOP has not provided the
correct data from their own Quality Control Report (Reference
statement above). There are many reasons why these two abstractions disagree: (1) ESG or AOP abstracted the wrong points
(2) ESG or AOP abstracted N points or X points that the
other did not extract. (These points should not be considered for comparison when AOP is establishing a centroid.
Only the line companies (A-E) grid points should be
compared), (3) ESG inputed a grid for a village in which AOP
did not. It is apparent that for each day in which there is
a major difference in the locations, AOP and ESG should
analyze these data in order to identify the reason for the
discrepancy. This has not been done; however, we have
requested AOP's reabstracted grid coordinate points in order
to perform this analysis. ESG will not make assumptions or
initiate reports until we verify what the data reflects.
This can only be accomplished by checking the source

�documents.
k. AOP Statement (paragraph 1, page 15). "We have
also discussed the reabstraction of other units, but ESG has
been unwilling to commit themselves to reabstracting additional data."
ESG Comment; ESG policy has been stated at many
meetings over the last year that we will be happy to reabstract
any battalion when asked to do so. The aforementioned statement
is incorrect. ESG has only been asked to reabstract
battalion #4. We agreed to reabstract this battalion because
it was one of the early battalions tracked when using the
CDC KAYPROS (word processors). We later discarded the
KAYPROS because the researcher could not edit the data once
it was keypunched. AOP recommended that several units be
reabstracted but AOP failed to demonstrate ESG expertise in
the battalion tracking arena. ESG report dated 10 September
1985 (see TAB B) documents the problems ESG found with AOP' s
latest attempt at quality control. AOP wanted ESG to
reabstract 3 or 4 battalions as a result of their Quality
Control Report dated 1 July 1985.
ESG demonstrated to AOP
that their report was less than acceptable and AOP dropped
the notion to reabstract the battalions. We are currently
working closely with Dr. Riduan Joesoef, AOP to develop a
quality control scheme in which the quality of data can be
accurately evaluated.
Dr. Joesoef has worked well with
members of the staff to solve these problems and we
appreciate his Interest and efforts.
1. AOP Statement (paragraph 2, page 15). "The approach used by ESG to abstract military documents Is mechanical . "
ESG Comment; We agree with AOP that ESG developed the current method for abstracting company location
data. This was not the case for the early abstraction
phase when detailed instructions were given to ESG
(which turned out to be poor decisions confirmed at
the last Science Panel meeting). However, AOP has
continuously provided ESG with rules which has limited ESG on the decisions it could and should Infer.
There are numerous decisions or determinations ESG
could initiate if we were given a free hand to utilize our expertise of U.S. Army combat unit data. We
are convinced ESG's current methodology is the best
possible method for tracking combat battalions.
Clearly, the disagreements, technical as they may be,

�point up the need for the separation of responsibilities to make the study believable and that it be done
by military analyst who have worked on this project
for the last three years* In the Interest of getting
on with the project, the Science Panel might consider
assigning the total mission of selecting the study
subjects to ESG, thus allowing AOP to conduct the
interviews, physicals and statistical analysis. During the protocol development of this study ESG
planned to conduct the research and accomplish the
automation process, thus providing the principal
investigators blind lists of study subjects. AOP
wanted the automation portion of the recording of
data and so it was agreed. This concept of the provision of blind lists was also discussed and agreed
upon by the VA when it was thought that the VA would
be doing the study.
m. AOP Statement (paragraph 2, page 15) "AOP has
requested that ESG involve other mililtary experts In decisions concerning the best methods for locating units, but
ESG considered this unnecessary."
ESG Comment; These techniques for abstraction were
dictated by AOP before they understood very much about the
battalion records. The AOP criteria as bad as it was, was
followed to the letter by ESG. The reason ESG has not called
in other so called "experts" to locate military units is
that ESG already has cornered the market in these
specialists with Vietnam combat experience and records
management expertise.
n. AOP Statement (paragraph 3, page 15). " All
parties then agreed to the establishment of a group consisting of persons outside the Army."
ESG Comment; ESG rejected such a proposal because the best current expertise in records extractions is
in ESG. These persons suggested by AOP as reviewers
were less competent than the personnel now doing the
extraction process. We never agreed to a final peer
review selection process hence the last sentence is
not true. Not stated in this paragraph is ESG's
suggestion to let the 4 major Veterans organizations
each provide 2 former combat company or battalion
commanders to come in and review the record extraction process. This was summarily rejected by AOP but
it is never mentioned. AOP tends to write down only

�8
their own proposals and omit any reference to counter
proposals from ESG particularly if AOP does not care
for the idea or suggestion. Another point is that
this peer review idea from AOP was never presented to
the WHAOWG Science Panel for consideration. Rather
it was an arbitrary unilateral decision by AOP that
such a review was called for. AOP should clearly be
made to understand that ESG is in no manner a subcontractor to AOP. We are very willing to serve
in the role of an equal research partner.
o. AOP Statement (paragraph 1, page 20). "We asked
Mr. Tavia Gordon, a consultant with AOP, to establish the
review group."
ESG Comment; Mr. Gordon is not known to us. We
have never met nor communicated with him.
p. AOP Statement (paragraph 2, page 20). "Mr. Gordon
did contact Mr. Stanton, and after further problems were
discussed with the location data supplied by ESG, AOP
employed Mr. Stanton as an AOP staff member."
ESG Comment; ESG is well aware of Mr. Stanton's
background as a historian. If Mr. Stanton should
discover any potential problems with the data we
would be happy to meet with him.
q. AOP Statement (paragraph 4, page 20). "A meeting
took place between ESG and AOP on November 12, 1985. We
discussed the information available for battalion #14
for April 1967.
ESG had reabstracted the information
on the unit for presentation at this meeting. In
this reabstraction, locations were found where none
had been supplied to AOP by ESG from their original
abstraction. In the data originally sent, AOP had
location information for only 4 of 30 days, while
after reabstraction, information was obtained for 27
of 30 days. It also appears that there were numerous
abstraction errors in the data AOP originally received, some of which resulted in placing units almost 100 kilometers from where they actually were."
ESG Comment; AOP had established the criteria
which resulted in location data for only 4 days
out of 30 for battalion #14. When ESG was freed of the AOP
imposed criteria then ESG was able to account for 27 of the
30 days with company locations. This merely proved the fal-

�lacious nature of the original AOP imposed location
criteria.
r. AOP Statement (paragraph 5, page 20). "Based
on the reabstraction of military records for four different
months involving three different battalions mentioned
above, we suspected that we were not receiving all
possible information on a company's location on all
days during 1967 and 1968.
While we had concerns
about the quality of location data being received
from ESG prior to this meeting, the data presented at
the meeting indicated that they may be of such poor
quality that they may compromise the scientific credibility of the study. We also believe, based on our
own research and the reabstraction of data presented
by ESG, that it is possible to obtain a data set of
reasonably high quality If the abstraction process is
changed to collect more of the available information
from the military records. Moreover, we believe that
unit location information of sufficient completeness,
accuracy, and reproducibillty to withstand the
scientific scrutiny which will occur at the completion of the study is more likely to be obtained If
the abstraction process is directed by AOP scientists, rather than ESG."
ESC Comment; We agree that because of the AOF
imposed criteria, t"h"at the data on daily company locations may be faulty. Why doesn't AOP admit this was
of their doing and that if ESG is permitted to freely
abstract and interpret daily locations the problem
will be readily solved with an appreciable improvement in accuracy. AOP gives no information whatsoever as to how they ensured quality control of daily
location data imputs to the AOP computers. In no way
will ESG agree to any transfer of the abstraction
process to AOP scientists who have little or no
background experience with Army operational records.
For further reference see TABs A and B.
s. AOP Statement (paragraph 2, page 21). "AOP
generally would not describe a meeting in a scientific
report, but we believe this information necessary to justify
our recommendation that AOP needs more direct control
over the abstraction process. In this way AOP can be
responsible for the validity of the exposure indices
and can enlist the services of additional experts in
the areas of military operations and records. These

�10
i

F

comments are not intended to minimize the contribution that ESG has made to the study through the abstraction of Information on individual study
participants from military personnel files, and we
trust that this contribution will continue throughout
the remainder of the study."
ESG Comment: A report of any kind should be
presented fairly and supportable. While we can understand it is much more convenient not to be subject to
peer review, AOP does not wish a review from above comments. We have gone the extra mile all along and because
we want to see the study through for the sake of our Nation's
Vietnam veterans we will continue to complete our mission.
t. AOP Statement B. AOP recommendations for obtaining valid location information, page 21 &amp; 22, "Transfer
responsibility for the collection of the location
data to AOP. We believe it would benefit the Agent
Orange Study to transfer the responsibility for the
collection of data on unit locations to AOP. It is
our judgment based on past experience and statistical
analysis that with current resources ESG cannot, on a
timely basis, abstract information with sufficient
accuracy and completeness to withstand scientific
scrutiny the completion of the study. AOP would hire
a contractor to abstract all the unit location data
needed for the study according to uniform procedures
specified by AOP. Performance standards would be
written into the contract and payment would depend on
the quality of service. AOP does not foresee the
need to request an additional Congressional appropriation for this work. We understand that the records being used for unit locations are controlled by
the National Archives and are available to the
public. Therefore, we do not foresee any
difficulties with continuing to gain access to
military Information.
However, we would ask DOD to
help expedite the process. We also would renew our
request to DOD for short term consultative services
from members of the Military History Institute and
the War College. AOF would develop a data collection
procedure on knowledge already possessed and
information on the design from the experts on the
available military documents and the conduct of the
Vietnam War."
ESG Comment;

We totally disagree with AOP's

�11
recommendations. There are many issues throughout this
report that are presented from one single point of
view in AOP's favor. This attempt by AOP to take
over this portion of the study negates the requirements for checks and balances to make a study creditable and acceptable to the veterans who have
repeatedly expressed confidence in ESG. They deserve
the best that we can give them. Do not take that away
from them. Vietnam was an honorable war. We all did
our best. All AOP has to do is ask ESG directly for
what they want as has been the case in the past and
we will produce the Information. In summary:
Non-Concur by ESG. We do not believe that AOP has the
breadth of experience in military records abstraction so
that they can supervise any contractor (nor can a contractor
be found with expertise in personnel such as already
available in ESG).
u. AOP Statement (paragraph 3, page 22). "This
approach may have some merit, but we do not yet know how much
of the location data would have to be reabstracted.
If this approach necessitates a substantial amount of
reabstraction, it would be preferable to reabstract
all of the information as outlined in option 1. AOP
does not recommend this approach since everyone
agrees (ESG, AOP, and others Involved in recent discussions) that more location information exists in
the records than is being collected presently and
this new approach ignores those data. Furthermore,
since this approach requires that we reabstract only
a subset of the data, we are left with the Inaccuracies in the remainder. If AOP adopts this approach
we would increase the quality control on the data
being collected and have the reabstraction done
through a contractor supervised by AOP as with the
first alternative. The scope of work, however, would
be more limited than that described in option 1."
ESG Comment; AOP does not have an understanding of
the problem. After ESG has already qualified the study subjects (163 data elements per individual) they are later
disqualified by AOP because of future new qualifications. The
job is manageable and can be accomplished with a few concessions
from AOP and AOP's admission that their location criteria
is faulty.
v. AOP Statement; (page 22, Cancel the Agent
Orange Study).

�12
f

"While we believe that there Is sufficient
justification for continuing the study and
that the location of companies in Vietnam
can be determined, we also believe that the
study must be based on the most complete
and accurate information available. AOP cannot
suggest that the study be conducted with
less than good quality unit location data
since these data are critical to accurate
exposure assessment and since so much money
and effort are going into assuring that all
other aspects of the study result in valid
data. "
ESG Comment; We concur - let us get on with a
more accurate daily location process as conceived by
ESG and accomplished by the highly trained and competent ESG staff. Let ESG select the study cohorts
(names of individuals) without AOP interference and
unreasonable contraints which have been proven wrong
by AOP themselves, as exemplified by their report.
w. AOP Statement (Section IV - Conclusions, page
23). "Our major concern is the completeness, accuracy, and
reproduclbility of the unit location Information
supplied to us by ESG. Therefore, AOP would like to
discuss the assumption of direct responsibility for
the collection of unit location Information."
ESG Comment; Non-Concur by ESG as to any AOP assumption of direct responsibility for abstraction of unit
location information.
x.
AOP Statement; (Page 24, Appendix I.
Unit Location Information).

Obtaining

"We discussed the accuracy and completeness of
the data supplied by ESG in Section III.
In
this appendix we describe documents and
methods presently employed by ESG and AOP
to obtain company-level location information.
The methods used to abstract the data do
not provide a location for every company on
each day of the period of the study. Consequently, gaps exist in our knowledge of
company locations for approximately 50
percent of the days. In part A of this
appendix we describe data available from

�13

battalion, brigade, and dlvlson level
documents. In part B we evaluate ESG's
suggestion that company-level morning
reports be used to fill gaps In unit
location Information."
»
ESG Comment; The lack of data for 50% of the days
in AOP'a opinion comes from use of incomplete data and the
lack of authority to do interpretation by ESG to fill
in these gaps. It is a difficult process and AOP
does not understand how such a process can be made to
work by ESG.
y.
AOP Statement (paragraph 3, page 24).
received d a t a f r o m 37 of these battalions."

"AOP has

ESG Commentt ESG has already provided AOP data on 40
battalions. By the end of the year 55 battalions will have
been reviewed.
2.
AOP S tatement (paragraph 4, page 24). "The map
coordinates gleaned from these records are in the Universal Transverse Mercator (UTM) system which uses a two
letter and six digit designation of location."
ESG Comment; ESG also abstracts two letter and
six digit grid coordinate locations. Early in the study
we were told by AOP if the Alpha letters were not recorded we could not use them. (See letter TABs D &amp;
E).
a.l. AOP Statement (paragraph 4, page 27). "Unfortunately
AOP f i n d s t h a t T t T s n o t always clear as to what the
location information listed in the morning report
refers, particularly when only an APO is available.

�14

We believe, based on our discussions with military
experts and the analysis of over 40,000 morning reports, that the location refers to the point of mail
distribution which was the base camp of the company's
brigade or division* If this information is presently available, it Is more easily retrieved from
USARV station lists."
ESG Comment; Morning Reports are the document
which would record the actual day a unit moved it's base
camp. USARV Station Lists would not provide this
information. Also the USARV Station Lists are not
updated to reflect a unit's move until many months
later. Morning Reports are definitely the best
source document to use when verifying a unit's major
base camp.
b.l. AOP Statement (paragraph 2, page 28)"....morning reports refer to either the brigade or division base
camps, without further documents, we cannot determine
which."
ESG Comment: ESG could easily furnish additional
documents to verify the morning reports. This method
is done all the time in connection with the many
other ongoing studies where detailed tracking is required. AOP acts as though one could use Morning
Reports exclusively. Such is not the case. ESG has
maintained that the MR's must be used in conjunction
with other reports and daily journals, then they make
sense. This paragraph points out the naivete of the
AOP approach.
c.l. AOP Statement (paragraph 1, page 32). "One major
problem with obtaining locations from morning reports
Is that we have been unable to locate these reports
for 40 percent of the days being studied. When the
reports are available, only an APO number occurs 48
percent of the time."
ESG Comment; There are morning reports for
every month which would verify the major base camp location
for each and every day. An experienced researcher
can interpret the APO number and locate the unit's
main base camp location. There are many reasons why
morning reports are missing. No change in status is
one example. Our trained researchers have the ability to track the unit using other data source materials.

�15

d.l. AOP Statement (paragraph 1, page 32). "Even when
coordinates are listed the coordinates often occur
again and again for the entire time period which
indicates that the coordinates refer to a fixed location such as that of a division base camp and not the
actual location of the company."
ESG Comment; This is to be expected as major
base camps do not move. They were constructed and protected with chain link fences, barbed wire, bunkers
and open fields of fire. However, combat companies do
move in and out of these base camps.
e.l. AOP Statement (paragraph 3, page 32). "If the
locations obtained from morning reports represent these
locations, they should, on average, be reasonably
close to the field locations noted for the companies
in other documents. This analysis, however, indicated
that the locations obtained from the morning reports
are not truly representative of the physical location
of the company."
ESG Comment; This is an apparent misunderstanding
on the part of AOF. There is a significant difference
between a major base camp location and a field location. Being in the field to an infantryman can mean
many things. Out on search-and-des troy missions, ambushes, fire support bases, the taking of an objective, retrograde movement and a host of other battle
situations such as serving as a screening force,
roads, bridges, protection and the like. Some of
these missions may take the company far afield from
the Division base location.
Sincerely,

Richard S. Christian,C.R.M
Director
Enclosures
1. AOP Quality Control Report
2. CDC Quality Control Report
3. Chair, Science Panel Memo, 15 November 1985
4. Epidemiologist Letter, 18 November 1985
5. AOP Letter, 10 February 1984

�»T

'

"

fteVch 21, 1985
I~

Statistician. Agent oranga Projacts
&lt;»
i
Battalion Tracking Procedures
Dan McGee, Senior Statistician, Agent Orange Projects
This memorandum reports the results of a review of the battalion abstraction
process for the Agent Orange Study by Canters for Disease Control (CDC). A
previous report by me gives details of the battalion abstraction process,
including a review of army documents and terminology, a description of each
data field on the battalion abstraction form, and a section on how to
interpret text in the army documents. This report was sent to Mr. Don
Hakenson of The U.S. Army and Joint Services Environmental Support Group (ESG)
on February 6, 1985 for review.
The primary purpose of our review is to see if a group of researchers
independent of the ESG can extract the same information on a battalion's
locations using the same army documents. Specifically, can two independent
groups arrive at the same overall battalion location for each day from their
respective abstractions? The secondary purpose of the review is to numerate
disagreements in abstractions. Characterizing disagreements will help
describe the data and perhaps be useful in editing the battalion data sets for
analysis.
CDC selected randomly four time periods to examine: May and June, 1967 of
Battalion 4; April, 1967 of Battalion 12; and June, 1967 of Battalion 21.
Drew Baughman and Christie Ernst researched the records for these battalions
without knowledge of the data the ESG had abstracted. Appendix A contains all
documents researched for this report. We used the procedures outlined in the
report mentioned above; from all accounts, these procedures appear to be those
that the ESG uses for their abstraction.
The first part of this report estimates the similarity and looks at
differences between ESG and CDC abstractions. The second part compares the
ESG set of locations before and after editing disagreements against the set of
procedures for abstraction documented by CDC.
I. ESG-CDC Comparison
The left side of Tabla 1 shows the distance in kilometers between the ESG and
CDC overall battalion locations and the number of abstracted locations by
battalion, date, and research group. For reasons not discussed here, cluster
analysis is used to compute an overall battalion location for each day, for
the ESG and CDC data sets separately. Appendix B outlines the algorithm to
compute an overall battalion location or centroid.

�2

Table 1
B«twa«n-cenfcroid ^distance and number of locations for initial ESG and CDC
abstractions and for ESG abstraction before and after editing by CDC, by
battalion and data.

Battalion 4:

•

Data

Distance
(km)

May 1
May 2

1.1
0.6

May 3
May
May
May
May

4
5
6
7

May 8

May 9
May 10
May 11
May 12
May 13

May
May
May
May
May
May
May

14
15
16
17
18
19
20

May 21

May
May
May
May
May
May
May
May
May

22
23
24
25
26
27
28
29
30

May 31

Subtotal

—
0.04
0.3
0.03

0.0
4.1
22.0

—
30.3
3.1
24.5

1.6
0.3

—
1.1
0.4
0.04
3.7
•6.0
17.5

3.0
2.7
2.3
18.5

4.5
1.4
1.8

-

(ESG, COG)
Number of
Locations
16
12

24
20
24
32
7
4
1
0
0
0
9
16
8
9
15
25
22
6
18
5
5
10
7
10
3
7
1
7
11

426

337

0.04
0.1

16
15

0
14
20
22
7
11
2
0
1
1
10
17
13
5
35
0
17
15
22
12
24
25
16
23
13
20
13
14
26

Distance
(km)

• -

—
0.02
2.4
0.02
0.0
5.2
11.0
—
—
22.0
2.9
24.9

2.0
0.3

—
0.5
3.3
0.5
1.0
8.1
16.6

0.2
0.1
0.04

00
.
0.2
1.0
0.2

(ESG,

ESG/CDC)
Number of

Locations
16
12
0
14
20
22
7
11
2
0
1
1
10
17
13
5
35
0
17
15
22
12
24
25
16
23
13
20
13
14
26

14
14
23
18
21
26
7
4
3
0
0
0
8
16
8
5
18
18
14
10
19
12
20
24
17
19
13
20
7
15
24
417

�Tabla 1 (Continued)
B«tween-cent,roid distance and numbar of locations for initial ESG and CDC
abstractions and for ESG abstraction baforo and aftor ad i ting by CDC, by
battalion and data.

Battalion 4:
Data
Juna 1
Juno 2
Juna 3
Juna 4
Juna 5
Juna 6
Juna 7
Juna 8
Juna 9
Juna 10
Juna 11
Juna 12
Juna 13
Juna 14
Juna 15
Juna 16
Juna 17
Juna 18
Juna 19
Juna 20

Juna 21
Juna 22
Juna 23
Juna 24
Juna 25
Juna 26
Juna 27
Juna 28
Juna 29
Juna. 30
Subtotal

-

(ESG,

Oistanca
(km)
0.7
1.9
0.5
19.7

1.1
17.1
19.3

3.1
42.8
21.7
22.1

3.6
24.6
19.5
22.4
23.5
24.1
21.6
24.2
36.4
28.3
19.7
21.8
23.2

1.5
46.8
24.0

4.3
3.1
22.7

(ESG,

CDC)

Numbar of
Locations
14

3

38
17
27
46
41
25
30
25
23
21
20
13
32
17
29
18
25
30
39
26
48
41
37
30
20
35
50
37
31

13
12
23
12
8
6
10
2
6
8
6
4
12
7
15
10
17
4
29
14
30
27
19
12
20
9
33
28
22

Distance
•: (km)

ESG/CDC) ".

Number of
Locations

0.5

14

14

0.005
0.04

38
17
27
46
41
25
30
25
23
21
20
13
32
17
29
18
25
30
39
26
48
41
37
30
20
35
50
37
31

36
21
30
33
23
17
29
22
14
20
15
15
27
11
22
17
25
19
42
25
47
50
37
26
24
23
43
40
29

0.1
19.3
24.6
19.5
0.1
37.0
18.0
19.1
0.2
19.6
19.1
' 19.8
20.1
19.5
18.9
19.4
19.4
19.9
19.2
19.7
0.2
19.7
19.9
20.1
1.2
19.7
20.0

�Tabla 1 (Continued)
Betwean-centroid distanca and number of locations for initial ESG and COG
abstractions and for ESG abstraction before and after editing by CDC, by
battalion and date.

Battalion 12:
Distance
(km)

. Data
April
April
April
April
April
April
April
April
April

1
2
3
4
5
6
7
8
9

April 10
April 11
April 12

April
April
April
April

(ESG,

13
14
15
16

April 17

April 18
April 19
April 20

5

0.07

15
8
0
5
0
4
10
8
8

3.6

7.9
—
0.3
1.5
1.9
0.1
0.02
49.1
0.04

2.3
5.3
0.2
9.9
12.3

—
1.7

April 21

April
April
April
April
April
April

22
23
24
25
26
27

April 28
April 29

April 30
Subtotal

Number of
Locations

7.6

—
— '
4.1
3.7
5.6
3.2
15.3

0.1
0.2
5.1

6
18
16
19
13
7
5
1
2
0
0

10
22
7
0
5
0
5
13
8
9
24
11
21
20
16
18
13
2
0
1
0
0

8
11
11
7
10
9
10

15
22
16
15
14
14
19

235

331

18

i

(ESG,

CDC)

11

Distance
(km)

12.6
0.1

ESG/CDC)

Number of
Locations

2.9

6

0.01

18

3.5
5.3

16
19
13
7
5
1
2
0
0
1
8
11
11
7
10
9
10

10
20
11
0
5
0
4
14
8
9
25
10
22
20
18
22
12
6
0
1
0
0
8
13
19
14
12
14
10
19

235

326

—
0.0
0.7
1.9
0.1

5
15
8
0
5
0
4
10
8
8

0.01

18

0.2
0.0

0.04

9.9
0.5
—
1.7
" —
— •

4.0
3.7
7.1
4.5
4.1
0.1
0.2
5.1

�Table 1 (Continued)
Between-ceritroid distance and numbar of locations for initial ESG and CDC
abstractidns and for ESG abstraction bafora and after editing by COG, by
battalion and date.

Battalion 21:

Distance
(km)

Data
Juna 1
June 2
Juna 3
Juna 4
Juna 5
Juna 6
Juna 7
Juna 8
Juna 9
Juna 10
Juna 11
Juna 12
Juna 13
Juna 14
Juna IS
Juna 16
Juna 17
June 18
Juna 19

June
June
June
June
June
June
June

•

20
21
22
23
24
25
26

June 27

June 28
June 29
June 30
Subtotal
Total

1.5
1.1
0.1
0.1
3.1
7.7
0.1
1.6
0.6
0.1
3.2
2.3
0.4
1.3
2.5
0.2
0.3
1.6
2.6
3.3
1.1
0.1
2.1
1.8
0.5
2.1
9.2
1.4
006
.0

5.7

(ESG,

Number of
Locations

2
16
12
17
1
12
27
18
2
21
16
1
25
18
7
7
6

4
4

5
11
16
12
8
13
1
18
5
19
2
326

(ESG, ESG/CDC)

CDC)

1
19
12
18
9
18
35
32
5
28
20
7
20
10
10
14
7
9
4
11
15 .

27
17
16
20
4
16
15
11
3

433

1,872 1,522

Distance
(km)
0.0
1.1
0.01

0.1
3.1
2.0
0.1
0.4
0.5
0.1
0.1
2.3
0.03

0.2
0.9
0.2
0.9
0.3
0.2
3.0
0.03
0.01

3.2
0.5
0.1
2.6
9.4
0.2
0.004

5.3

Number of
Locations

2

16
12
8
13
1
18
5
19
2

2
20
13
19
8
13
35
33
5
29
22
7
33
28
11
11
7
9
7
10
13
19
15
11
15
2
22
16
21
4

326

460

16
12
17
1
12
27
18

2
21
16
1
25
18
7
7
6
4
4
5
11

1,872

1,999

�B«low is a summary of th« (ESG, CDC) comparison in Table 1.

Number of Days with
Extract

Battalion

4 May 67
4 Jun67
12 Apr67
21 Jun67

Period
Apr84
Apr8 4
Aug84
Oct84

Between-Centroid Distance
&lt; 5 km
&gt; 5 km Total
20
9
16
27

6
21
9
3

Number of Locations
CDC

426
885
235
326

26
30
25
30

ESG

££&lt;

337
421
331
433

t-n-

The ESG abstracted more locations for May of Battalion 4 (426 versus 337) and
for June of Battalion 4 (885 versus 421), and CDC extracted more locations for
April of Battalion 12 (331 versus 235) and for June of Battalion 21 (433
versus 326). CDC's abstraction places the battalion at least five kilometers
from ESG's 27 of 56 days for Battalion 4, nine of 25 days for Battalion 12,
and three of 30 days for Battalion 21. Assuming standard procedures for
abstraction, these differences are due to either error in ESG's abstraction,
error in CDC's, or both. I scrutinized the documents, the same for ESG and
CDC, and found the latter to be the case. Since the purpose of this report is
to review ESG's abstraction of troop locations from army documents, the
discussion that follows is limited to ESG's errors only. Please note that
"errors" subsumes a variety of possible mistakes and oversights and together
they refer*only to the standard of abstraction outlined by CDC.
Table 2 shows the errors in abstraction by the ESG for each battalion by
date. Five categories of errors are listed there: transcription errors,
projected or planned locations, coordinates imputed from a master list, a
miscellaneous group, and omissions. The following is a summary of these
disagreements.
.

Battalion

Extract
Period

Number of
Locations

4 Ha^&lt;57
4 -May 6 7
12 Apr67

Apr84
Apr84
Aug84

21 Jun67

Oct84

427
. 885
235
345

Errors
Xpos.
11
78
0
0

Proj.

Imp.

Misc.

39
151
3
5

120
364
8
2

16
11
9
3

Omis.
56
95
124
175

The transcription errors in Battalion 4 are mostly wrong translations for the
^rid. For example, an entry without a grid attached such as 556998 was taken
•s XT556998 instead of XS556998. A few transcription errors are wrong digits
such as taking 1 for 6, or transposition of digits such as 96 for 69.

�"Many locations in Battalion 4 were simply lists of patrols, check points, and
command posts, only soma of which are later raportad for soma group's arrival
at these locations by stating "in position" or "closad." Most of tha
projection* errors are taking every location in tha list, not just the ones
later confirmed, and some are taking planned locations from a paragraph
explaining the next day's operations or from the plans summary at the end of
the journal.
Tha documents for Battalion 4 also contained many references to arrivals to
and departures from Fire Support Base Nicke,! (Nickel), Cu Chi base camp, and
Brno Trai village or airstrip. Of tha 529 such references, 312 are for Nickel
(all XT571046), 145 are for Cu Chi base camp (137 are XT6412 and 8 are
XT6415), and 52 are for Bao Trai village or airstrip (four unique locations).
Table 3 shows a check COG made to see if and when tha location for Nickel
changes.
TabU 3
Tha location of Fire Support Base Nickel recorded by tha ESG and found in tha
day's Brigade Sitrep by CDC, by date for Battalion 4 .*

Data

ESG

May 11

CDC

•
w

•
H

May 12

May
May
May
May

13
14
15
16

May 17

May 18
May
May
May
May
May

19
20
21
22
23

May
May
May
May
May
May

24
25
26
27
28
29

May 30

—
XT571046
XT571046
XT571046
XT571046

XT571046
XT571046
XT571046
XT571046
XT571046
XT571046
XT571046
XT571046
XT571046
XT571046
XT571046

XT571046

—
XT571046

—
XT571046
XT527043

—
XT565046
XT569048

—
—
—
XT568042

XT568042
XT568042
XT568042

*CDC did not check tha first ten days in May and June. A "-" means no
reference to Nickel in the document.
t

�"•'.

Tabla 3 (Continued)
(

j

Tha location of FirQ Support Base Nickel recorded by the ESG and found in the
day's Birgade Sitrep by CDC, by date for Battalion 4.*

Date
June
June
June
June
June
June
June
June
June
June
June
June

ESG

11
12
13
14
15
16
17
18
19
20
21
22

June 23

June 24
June 25
June 26
June 27

June 28
June 29
June 30

XT571046
XT571046
XT571046
XT571046
XT571046
XT571046
XT571046
XT571046
XT571046
XT571046
XT571046
XT571046
XT571046
XT571046
XT571046
XT571046
XT571046
XT571046
XT571046
XT571046

CDC
XT648042
XT568044
XT568044
XT568044

—
XT568044
XT568044
XT568044
XT568044
XT568044
XT568044
XT568044

—
—
—
XT568044

XT568044
XT569044

*CDC did not check the first'ten days in May and June.
reference to Nickel in the document.

—
•™

A "-" means no

All references to Nickel for May and June of Battalion 4 were recorded as
XT571046 and coded as inferred from the day's Brigade Sitrep by the ESG, but
CDC found different coordinates for Nickel in the Brigade Sitreps, indicating
the location of Nickel changed.
The miscellaneous group of errors include taking coordinates for the wrong
battalion, an airstrike, artillery or small arms firing, five-digit
coordinates, and keypunch error.
Omissions were spotted in all three battalions reviewed. These were mostly
"patrol in position," "dustoff" or "dustoff complete" (medical evacuation of
men wounded in action), and "n/c" (no change) or "same position as last hour."
In addition to errors committed in abstracting coordinates, the ESG took the
TIME from the text and not the "TIME IN" column for all documents reviewed.
The ESG and CDC had good agreement for the first digit of the UNIT field, but
there were some differences in the second digit.

�*

Table 2

Number of locations abstracted by the ESG and number of errors by battalion
and date.

Battalion 4:
Errors
Data

Number of
Locations

May 1

16
12

0
0

0
14
20
22
7
11
2
0
1
1
10
13
5
35
0
17
15
22
12
25
25
16
23
13
20
13
14
26

0
0
0
0
0
1
0
0
0
0
0
2
4
0
0
1
0
0
0
0
1
1
0
0
1
0
0
0
0

427*

11

May 2
May 3

May
May
May
May
May
May
May

4
5
6
7
8
9
10

May
May
May
May
May
May

11
12
13
14
15
16

May
May
May
May
May
May
May

17
18
19
20
21
22
23

May 24

May 25
May 26

May
May
May
May
May

27
28
29
30
31

Subtotal

17

Te

Pr

2
0
0
0
0
0
0
9
0
0
0
0
0
0
0
0
0
0
2
4
3
1
3
1
1
5
0

Ri
0

0
0
0
0
0
0
0

2
0

1
1

4
0
4

2
2
0
1
1
0
2
5
1
5
14
14
10
9
10
11
7
9
13

39

120

&lt;o

Ot

0
0
0
0
0
0
0
0
0
0

1
1
1
1
1
1
1
0
1

Om
0
2
0
6
4
8
0
0
2
0
0
0

3
2
0
6
1
1

0
0
3
1
0
0
0
0
2
1
1
0

0
1
0
3
0
0
2
3
1
1
0
4
6

16

56

Legend:
Te
Pr
Ri
Ot

as transcription error
a projected or planned
= researcher imputed coordinates from master list
= wrong battalion, airstrike, artillery or small arms firing, five-digit
coordinate, keypunch error
OH = omission
* as includes namecode-only entries

�10

•

Tabl« 2 (Continued)
i

&gt;•

Number of locations abstracted by the ESG and number of errors by battalion
and data.

Battalion 4:
Errors
Number of
Locations

Date
June 1
June 2

Juna
June
Juna
Juna
Juna
Juna
June
Juna
June

3
4
5
6
7
8
9
10
11

Juna 12
June 13

June
June
Juna
Juna
Juna
Juna
Juna

14 i
15
16
17
18
19
20

14
38
17
27
46
41
25
30
25
23
21
20
13
32
17

.

Te

'.

0
1
2
3
3
10
1
0
2
1
2

0
1

3 i

Pr

Ri

1
1
1

10
20
9
15
21
17
15
19
16
5
10

0
13
13
4
3
0
13
2
1
0
8
4

13
9
14
6
7
10

29

1
1

26
27
28
29
30

18
25
30
39
26
48
41
37
30
20
35
50
37
31

0
0
0
4
5
3
6
6
4.
5
4
5
1
4

9
4
8
3
3
2
5
3
15
10
12
5

4
13
12
10
12
16
18
12
6
14
7
15
9

Subtotal

885

78

151

364.

June 21

Juna 22
June 23

Juna 24
Juna 25

Juna
June
Juna
Juna
June

7
0
1

Ot

0
0
0
0
0
0
3
1
0
0
0
2
0
1
1
0

0
0

1

1
1

0
0

0
0
0
0
0
0
0

11

Om

1
0
3
1
2
1
1
2
0
2
2
2
0
4
1
0
0
0
1
8
6
5
7 5
3
11
4
4
8
11
95

Legend:

Te
Pr
Ri
Ot

=
=
=
=

transcription error
projected or planned
researcher imputed coordinates from master list
wrong battalion, airstrike, artillery or small arms firing, five-digit
coordinate, keypunch error
Om = omission

�11

Tabla 2 (Continued)
Number of locations abstracted by tha ESG and number of errors by battalion
and date.

Battalion 12:

•
Errors
Number of
Locations

Date
April 1
April 2

Te

5
15

19
20
21
22
23
24
25
26
27
28

1
2
0
0
1
8
11
11
7
10

April 29
April 30

9
10

0
0.
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0

Subtotal

235

0

April
April
April
April
April

3
4
5
6
7

8
0
5
0
4

April 8

10

April
April
April
April
April
April
April
April

9
10
11
12
13
14
15
16

8
8
18
6
18
16
19
13

April 17
April 18

7
5

April
April
April
April
April
April
April
April
April
April

;

Pr

2
0
0
0
0
0
0
0

1

0
0
0

0
0
0

0
0
0
0
0

Ri

1
0
0
0
2
0
0
0
0
0
0
0

0
0
0
0

0
3

Ot

0
0
0
0 .
0
0
1
2
0
1
0
0

0

1

2
0
1
1

Om
10
5
3
0
2
0
3
6

2
2
7

5
3
5
0
9
7

2
0

1
'1

0
0

0
0
0
0
0
0
0
0
0
0

0
0
0
0
0
0
0
0
0

0
0
0
0
0
0
0
0
0
0

0
0
9
8
8
5
8
4
2
9

3

8

9

124

0

0

Legend:
Te
Pr
Ri
Ot
Om

=
=
=
=

transcription error
projected or planned
researcher imputed coordinates from master list
wrong battalion, airstrike. artillei"y or small arms fii"ing, five--digit
coordinate, keypunch error
omission

�12

Table 2 (Continued)
Number of locations abstracted by the ESG and number of errors by battalion
and data.

Battalion 21:
Errors
Number of
Locations

Data
June 1
Juna 2
June 3
Juna 4
Juna 5
Juna 6
Juna 7
Juna 8
June 9
June 10
June 11
June 12
June 13
June 14
June 15
June 16
June 17
June 18
June 19
June 20
June 21
June 22
June 23

6
17
12
17

Te

Pr

Ri

Ot

Om

14
27
18
3
23
16
2
25
18
10
8
6
5
4
5
11
16
12
8
14
1
18
5
19
4

0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0

1
0
0
0
0
0
0
0
0
0
0
0
0
1
1
0
0

0
0
1
0
0
1
0
0
0
0
0
0
0

0
0
0
1
0
1
0
0
0

0

0

0
0
0

0

0

0

0
0
0
0

0

0
0
0
0
0

0
0
0
0
0
0
0
0
0
0
0
0

0
0
0
0
0
0
0
0
0
0

3
10
4
7
5
9
8
4
4
10
1
3

Subtotal

345*

0

5

2

3

175

Total

1,865.

89

198

494

39

450

June 24

June
Juna
June
June
June
June

25
26
27
28
29
30

.

1

1

0

1

0

0
0

0
0
0
0

1

0
1
11
3
8
9
9
15
4
9
5
8
1
5
5
5
4
5

Legend:

Te
Pr
Rl
Ot

= transcription error
= projected or planned
55 researcher imputed coordinates from master list
ss wrong battalion, airstrike, artillery or small arms firing, five-digit
coordinate, keypunch error
Om = omission

�13

II. ESG-ESG/CDC Comparison

To astiraata the affect, if any, of errors in abstraction on the daily overall
battalion location, I compute the distance between the daily centroids derived
from the ESG set of data before and after editing the errors listed in
Table 2. All edits to the ESG data set are based on the rules of abstraction
detailed by COC in a previous report. The right side of Table 1 tabulates
this distance by date for each battalion. The following summary of these
distances shows a difference of at least five kilometers 28 of 56 days for
Battalion 4, five of 25 days for Battalion 12, and two of 30 days for
Battalion 21.

Battalion
4
4
12
21

May67
Jun67
Apr67
Jun67

Extract
Period
Apr84
Apr84
Aug84
Oct84

Number of Days with
Between-Centroid Distance
&lt; 5 km &gt; 5 km Total
20

6

8
20
28

22
5
2

26
30
25
30

Number of Locations
ESG/COC
ESG
426
885
235
326

417
796
326
460

Extrapolationg these figures to the rest of the battalion tracking data, I
recommend that Battalion 4 be re-abstracted using the current set of tracking
procedures, and one randomly selected week from each of Battalions 1-3, 5-7 be
reviewed. This statement is based on: (1) the poor reproducibility of the
daily overall battalion location due to errors in abstraction for about 50% of
the days CDC reviewed for Battalion 4; (2) the present Battalion Abstraction
Form was not implemented until Battalion 8, and therefore a different sort of
abstraction may have occurred before Battalion 8; and (3) the current set of
tracking procedures were not formalized for the early battalions.

Drew Baughman
CDC:CEH:CDD:AOP:DBaughman:pfh
DOC096 SEC12

3/21/85

�14

Appendix B
I used PROG FASTCLUS in SAS to cluster points for each day, for each data set
separately. This procedure uses an agglomerative, nearest neighbor method of
clustering. It uses the first nonmissing observation (point) as the initial
cluster seed, defines it as the first cluster, and proceeds sequentially
through the data set, computing.the Euclidean distance from the present
observation to. each of the cluster seeds. An observation is considered a new
seed if its minimum distance to previous seeds is greater than 3 km (chosen by
user).
Each observation is assigned to the cluster with the nearest seed, and after
an observation is processed, that cluster's seed is recalculated as the mean
of the observations currently assigned to the cluster. Cluster seeds are
iteratively recomputed up to five times (chosen by user).
I allowed for a maximum of five clusters on any day and computed the centroid
of all cluster centroids by day for the ESG and CDC sets of data, separately.

�DEPARTMENT OF THE ARMY
US ARMY &amp; JOINT S E R V I C E S ENVIRONMENTAL SUPPORT GROUP
1730 K STREET N.W. ROOM 2IO
WASHINGTON. OC 20008-3888

TO
ATTENTION

DAAG-ESG

./

fff

^

10 September 1985

MEMORANDUM FOR DIRECTOR^SG
SUBJECT: CDC Quality Control Report, Dated 1 July 1985

1. On 16 July 1985, Bob Delaney, Drew Baughman and Riduan Joesoef from CDC
in Atlanta, Georgia, visited our organization to discuss battalion abstraction procedures and quality control.
2. During the visit Mr. Joesoef provided Mr. Hakenson of our staff a copy
of a quality control report he had sent to Mr. McGee concerning a quality
control abstraction comparison between CDC and ESG. lie reported that tae
CDC abstraction produced more points of locations than ESG had abstracted.
3. CDC based their analysis on a one week reabstraction on battalions #1,
2,5, and 7. Their recommendation was that battalion #2,5 and 7 be reabstracted. This was based on CDC'a reabstraction of the battalion data as
the "gold standard". I would like to point out that the procedures used by
CDC abstractors were obtained from a. memo dated March 21, 1985, written by
Mr. Drew Baugman, after spending 3 days at our organization attempting to
learn the abstraction process in January 1985.
4. Upon further reexamination and analysis of the CDC and ESG abstraction
process we were able to uncover CDC abstraction errors and key punch errors
by our staff. On battalion 12 there were two days in which CDC and ESG did
not agree. This was due to a key punch error in which two days of grid coordinates were abstracted for the same day. Except for the key punch error,
all data was exact. In our opinion this did not warrant a total reabstraction.
5. On our examination of battalion #7 we found numerous grid coordinate
errors by the CDC abstractor. CDC showed they found 20 grid coordinate
points. Our examination reduced the number of points to 9. ESG's original
abstraction produced 15 good grid coordinate locations. Listed below are
:t,a types of recurring grid coordinate locations that CDC abstracted.
a. VC Sighting - When the tracked unit sighted VC and provided^ grid
location the CDC abstractor recorded this grid. This is the VC's
location not the tracked unit location.

TA&amp; 6

�DAAG-ESG
SUBJECT: CDC Quality Control Report, Dated 1 July 1985

10 September 1985

b. When an artillery unit fired in an area, CDC recorded this location.
. This is not the units location but where that unit was firing.
c. One entry that was recorded was that the tracked artillery unit was
supporting another unit in a specific location. This was not the
tracked units location, but another unit that was requesting artillery
support (fire support).
6. Due to the discrepancies we found in the CDC abstraction process, we do
not feel the battalions warrant reabstraction. Our new researchers have made
the same sort of errors, but are taught through constant training to find and
identify these types of incidents and not to record them. The only conclusion I can draw from this report is that CDC is not proficient enough at
this stage of the battalion tracking process to produce reports criticizing
ESG. However, this did not stop CDC from producing and circulating a highly
critical quality control report. I would also like to point out that
Mr. Joesoef had never extracted grid coordinates from battalion records
before. 1 would strongly suggest that CDC follow the ESG SOP Abstraction
Procedures dated May 7, 1985 when abstracting grid coordinate locations.

Concur:

16 M. TENBERG
7
Major, USA
/
Chief, Scientific Support
Division
;

-2-

�Date:

July I, 1965.

From!

Riduan Joesoef

Subject: Results of quality control battalion 1,£,S, ana 7.
Toi

Dan WcBee

?

This report summarizes tne results* of qualt iy control for oattalion
tracking 1,2,5, and 7.

For oattalion 3 CDC received brigade daily journal

instead of battalion sally journal, thus, a comparison to the ESS
abstraction was nor possible.

However, a comparison of oattalion daily

journal and brigaoe daily journal was conductea to g i v e a oetter
understanding of -she journals.
Quality Control Procedures

'
i

— -

The same quaii-ty control procedures as aescribea in ;}rew oaagnf/ian* s

memo dated March 51, i5c£ were c-aoliec, except for d«ita entry, edit, ana
verification tvc-r^.

Tnis =-xt---a «-:&gt;rx A&lt;as ccriructec locally by ngerit Orangs

personnel to reduce K.eypur.-c- ir.g error ^o. a minumum.

in addition, only or-s

week period t7 cays) or abstraction r'or ee.cn battai sen was abstracted.
£SQ — CDC comparison
A comparison petween £55 ana CD2 abstractions indicated tna't tne CDC
abstraction produced more points of locations (fao*e 1).

In retard to cne

centro;c—cistance only oatte&gt;.j ion 5 ana 7 sno* si j^ni r i cant
distances (Table l).
To assess furtner tne quality of £S3 aD&amp;traction, an evaluation o^' tr&gt;e
numoer of locations or days wnich were in the source documents put o:tiittea
i
Dy £S3 aostraction was consuctec. in tnis report, tms type of error was
cefineo as omission error wnich consisted of locacions &amp;r\a cays oi'i

�Battali&lt;sn

1

Taale i
Between centr*oid-cistarice ari-a nurnDer of . locau ions
for £5i and CDC aoscrac^ ior;
—_
g
Date
I&gt;i stance
Number of Locasior.s
(km)
cSo
COG

Oct. 15, 1967
Oct. 16, 1967
Oct. 17, 1967
Oct. 2O, 1967
Oct. 21, 1967

~

0
0
2.23

6
5

5

Mar. 13, 1966
Mar. 2O, 1968
Mar. 21, 1968
«ar. ££, 1963
Mar. 23, i966

Mar. 19,
rtar.2O,
Mar. 21,
rtar. 22,
Mar. 23,
Mar. £5,

1368"
1968
1968
1968
1968
1968

"

.6 .
- 5T6

4*

x'^

1

o

i

i

Nov. 17,
Nov. 18,
Nov. 19,
Nov. 2O,
Nov. 21,
Nov. 22,
Nov. 23,

1968
1968
1968
1968.
1968
1968
1968

" //W ^u
3
* // \ \/ \r
1
3

,.

(Jf*1•&lt;^fc-

Xo
Ap

13

0'
1

—
—
I-£L*=^&amp;V vm^r^^v^ ^Bto

V

a &lt;/
i

0
5

—

i

sca'i
3
3

15

/

^

X&lt;3 , , .,,•-" "
#-**" ' J .,.-

^^5)

'

^ -evi^^ic..
^TI

^f') i^u^i^

5*X-*20

\»

\T

A. I
fTV^

v^
v V'
A b K vr

v*" i l

x
a

3S. 99

•Locations include name-code only.

1 \

3

26. O3
0.45
79. 1O

19.41
3. 53
— •~

\u
iv^

O

—

V

\tv^ V r

\/r^

-~^ j0? y 3
vff ^ V

12

7

V

i

••1 .—»
» •

3. 6S

i/l

Y '

;

~

0
O

-

jfo

i?

\
\^
V

O

o

—
—
-

2

a

2

�These errors were critical Because they reaucea the number of
points and unique days obtained from tne abstraction. rtnotner type of
error was inclusion errors.

These errors were defined as the numoer of

locations or days which were not in tne source document but included by
ESG abstractions
To evaluate the omission ana inclusion errors, the ESGi and CDC
abstractions were combined and edited to produce a compromised, optimal
abstraction.

This optimal abstraction was named the ESG and CDC

abstraction and used as a "gold standard" to evaluate the ESG
abstraction.

Two summary taoles— Taole 2 and 3 —were created for these

purposes.
Table 2 shows tne numser of locations ana days for omission arsa
inclusion errors By oattaiion.

;

For example ESS omitted i*t locat ion points

for battalion 2 wnich constituted a S^-'A (lA/ici) omission error,

"ms

reest-is that £53 aossract ion Missed tit-vi of the location points ^na1: eouic bs
.=.2Stracte2 fvom tnat Datfaiion.

Toe nurnpsr of dayti tnat (£Si3 c^i^t so for

Battalion 2 was i cay wnich const itutea a c:u% &lt;l/ii) OMISSION er^o.-".

Cv.

the other hano, £83 abstraction incluaea 11 more location points \--hssa II
points were not in the source document).

Number of j.ocs.t ions- ar-d cays errors
abstracted by ESS by Battalion
rcuniDer of
Days by
dSaJv-CDC

Batt. Number of
i_ocat ion-t£rrors
Locations Omission Inclusion
sy £S34r'CDC N
P
N
P
1

21

3

2

22

it-

5

13

7

2O

7%

O

ux

11

50S

a 62V.

t

13 65*

1O

fet%

•

Day-£rrors
Omission Inclusion
N
P
fa
£

t5

1

ij-

^/

1

31%
5O*

Batt.-Battalion
K« rJuraoer of omission or inclusion
PSB Percent of omission or inclusion

20*

u

0*

• * " ( ! * &gt;

c, X*%

/~'

&gt;•'

•' »

o

if:

J.i"A

o

^^

6

i

17%

1

i7%

^^ /*

�A

' In summary, oattaiion 2,3, and 7 have the most errors for eitner
locations or days.
To investigate the two types or errors at company level. Table £ was
broken down by company to produce Taole 3.

This table shows the number of

locations and days errors at company level for each battalion.
pattern was noticed.
and 7 were serious.
errors.

The omission errors for companies in aafcalion S, 5,
For battalion l only company B has significant

It is worth noting that only division daily journals were

available for battalion S.

Consequently, only two companies C and D were

produced from the division journal aoscraccion.
has a

A similar

Unfortunately, company C

100% omission error for both locations ana days.

In conclusion, reaostraction of oatcalion 2, 5, and 7 are necessary to
increase coverage of locations ana unique a&amp;ys for either company or
aattaiion.

If time permitted oat tali on i should also be

�4

*

Numcer or ioca|ions arid cays errors
abstracted t&gt;y £3Cs oy oa^calien anc company

Ba?r. Co.-« p. Numaer of . Location-Errors
Nunner of
Location
emission Inclusion Days by
oy ESG4CDC N
P
N
P
EBGiCDC

1

ft"
B
C
D
E
X

2

ft
3
C
D
cr
N

X
5

ft
B
C
D
£
N

7

ft
B
C
O
E

3
9
4
1
0

0
3
O
O

o%

0%
33*
0%
0*
- -

O
0
0
O

--

0%
0%
0%
-

4

—
O

0%

O

o%

3
3
3
O
O
3
IO

i
£
0
2
9
_

33%

i

So*

1
0
0

33%
3 3 'A
O%
-

O'/i
0 *
0

—
O%
80%

4

—
4

100%

O
O
9

—
—
4

—
—
44*

a
_
o
—
0

3
4

50%

o

o*

100%

2

IOCS

—
33%

—
2
0

—
33%
0%

O
0

6
4
O
6
4

50%
_

-

—
2
4

100%

Bait.=Battalion, Comp. "Company
N* Number of omission or inclusion
P™ Percent of omission or inclusion

—
—
O%
-

o%

1
3
3
1
O
2
2
2
3
0
0
2
1
0
O
3
O
0
5
4
2
0
3
4

Day-Errors
Omission Inclusion
N
P
N
P

O
1
O
0
-

o
1
i

0

—
-

1

o

O%
33%
O%
O%
0%

O
0
0

0%
0%

o

0%
0%

5O%
50%
0%
50%
O%

o 0%
o%
o ' 0%

—
o

o%

O ;

—
0
0

0%
0%

' —

—
3
—
3

3
2
—
1
4

— .
—

—

—

1OO%

—
o

—
o%

—
—
60%

—
—
o

—

75%
1OO%
— --

o
o

0%
0%

33%

—
o

1OO%

0

—
o%
0%

—
0%

�Battalion and Brigade Daily Journals Comparison
Table 4 indicates that oattalion daily journal nas more location
points and

days than brigade daily journal.

However, only 29* of th€

location points in -che brigade journal matches with the points in the
battalion journal.

Table 4
Number of Locations and Days for
Battalion ana Brigade Daily Journals

Daily Journal

Numoar or
Loca-ions

Brigsce

Battalion

fvumcer of
Days

35

t&gt;

I1A-

7

Kiauan Jossoer

CC. Drew Baughman
Dennis Smith
Debai Kotlovker

�18 November 1985
H3r. Richard Christian
Director
U. S. Army and Joint Services Environmental Support Group
1730 'K' Street, Room 210
Washington, D. C. 20006-3868

Dear Mr. Christian,
This letter is in follow-up to our telephone conversation of 18

the abstraction of grid coordinates
from various military documents.
Beginning in the early planning stages of the Agent Orange Study,
the Centers for Disease Control (CDC) provided very explicit instructions regarding the abstraction of grid coordinates from military documents. In numerous planning meetings, Dr. Lee Aires t
stated which coordinates should/should not be taken. He stated
that coordinates' missing letters or digits (Mote: an exception
bein? a" four [4] digit coordinate) should not be taken as the
true location could not be verified. Moreover, this point of interest was discussed numerous times with several other individuals from CDC and at no time was ESG given any instructions to the
contrary. CDC stressed time and again the importance of consistency in data abstraction and not extrapolating on any incomplete
data. Unless the document clearly stated that the specific unit
of interest was at a particular location, coordinates were not
taken. For example, enemy locations -ware not taken unless U. S.
troops were also at that same location.
Finally, as we are both fully aware, the military documents are
not perfect and they were never intended to be used for any such
scientific endeavor. Never-the-less, despite their limitation,
I firmly believe that they do contain a large quantity of excellent information.
Should you require any further clarification, don't hesitate to
contact me.

Robert J. Lipnick, DSc
Znidemiologist

�DEPARTMENT OF HEALTH &amp; HUMAN SERVICES

Public Health Service
Centers for Disease Control

February 10, 1984

Rob lipnick, Ph.D.
c/o Mr. Dick Christian.
Environmental Support Group
Suite 210
1730 K Street, N. W.
Washington, D. C. 20006
Dear Rob:
The AOP staff express our appreciation to you and your staff for taking the
time to explain the methods and materials used in the Battalion search for the
Agent.Orange Study Pretest. The Agent Orange Project staff have reviewed your
questions concerning the battalion search and would like to provide necessary
guidelines to standardize the abstraction procedure for data collection in
subsequent Battalion searches. In order to adequately address these issues,
we would like ESG to provide us with some detailed information concerning the
locations and movements of infantry and artillery units selected for the Agent
Orange Study.
CDC would like ESG to initially track the companies/batteries, excluding the
headquarters company/battery, in each of the following four battalions:
1. 1st Battalion/2nd Inf. Regiment/lst Brigade/lst Inf. Division
2. 2nd Battalion/2nd Laf. Regiment/3rd Brigade/lst Inf. Division
3. 5th Battalion/2nd Artillery Regiment/II FForce.
4. 1st Battalion/5th Artillery Regiment/Ed.vArty/1st Inf. Division
(Note that on the original CDC list of 48 Battalions, these units were #1, #2,
#6, and 17.) These battalion searches will include tracking at the battalion,
company/batter^^platoon^ana squad uQit levels.
'ru""r"TT"n""
Currently, Paul Simpson, a computer programmer with the Project, and I are
working on a data entry and management system using the computer software
"Infostar" for your use in abstracting data in a standardized way from the
military operational and intelligent reports onto the KAYPRO II personal
computer. He and I plan to be in Washington on February 13 through 15 to
train the ESG researchers how to use the computer program. I have been
corresponding with Joan Wilson of your staff about the format of the data
entry form. A sample of the proposed data entry form is attached. Most of
the fields are self-explanatory. The "time" field refers only to the logging
in or out of coordinates specified in the Brigade and Battalion Daily
Journals. The form will be pretested here using some data sent down to us by
Joan. The remaining "bugs" in the system can be worked out during our stay in
Washington. Other details about transferring the data to CDC will also be
decided at that time.

�w
*

2*- Dr. Upnick
As a measure of accuracy of data abstracted from the Daily Journals and other
military documents, CDC will conduct a replicate study of these four
battalions. Essentially, this will entail designating two CDC staffers with
the Agent Grange Project to replicate at least a portion of the abstraction
process conducted initially by an ESG team. The design and content of the
replicate study is being discussed and developed. This study will not
interrupt ESG's progress on the Battalion search. CDC will provide ESG with
details within the next few weeks.
The replicate study is not in lieu of the quality control program ESG will
perform for the Battalion search. We would like to have in writing a
description of your quality control procedures including (1) training of new
researchers, (2) review of data abstracted from the military records, and (3)
documentation of methods and materials. The CDC staff would, of course, like
to review and comment on the quality control program.
A double-blind quality control study using CDC staff would not be feasible.
Ebwever, the replicate study can be conducted Independently of the ESG
research team. The goal in this exercise would be to compute the concordance
or discordance of location information abstracted by the two groups. If such
a study were not conducted, accuracy of the abstraction method could be open
for criticism as not adequately evaluated.
For the initial searches on the four battalions, it would be best if a team of
two ESG researchers searches the entire two years of a given battalion. In
this way, inter-team variability within a battalion can be avoided, thus the
statistical evaluation of the replicate study will be more straight forward.
Thank you for your time and cooperation.
Sincerely yours ,

Lee Annest, Ph.D.
Geneticist and Statistician
Agent Orange Projects, CEH, CDC

Enclosure

�DWAHTMBNT OF HEALTH* HUMAN SEKVJCBS

Memorandum
November 15, 1988
*«"»

Carl Keller

,^__

Chair, Science PaWfTgiWTOrenge Working Broup
progress of Cohort Selection for Agent Orange 6p1dem1olog1ca1 Study
Arnett
Acting Chair, Agent Orange Working Broup
At a meeting of the Science Panel held after the regular meeting of the ACW6
on November 6, 1988,' the progress of the cohort selection procass for the
Agent Orangt Epldemlologlcal Study being conducted by CDC was discussed.
Following the suggestion by congressional staff that meetings be held between
CDC Agent Orange Project! staff and the Environmental Support Group 1n the
presence of representstives from.the Science Panel, AOWT and OTA, and that the
Congressional staff be notified when such meetings ware to be held, the
Science Panel selected me, as a lubconnrlttee of one. ,to work with the other
participant*. I agreed to participate on those terms, and Ms. Helen 6elband
as an observer to the AOW and as the responsible person at OTA also agreed to
attend such meetings. U* scheduled a*meeting between the principals for
November 12 to be held 1* Washington at the offices of the ES9 and I requested
that both CDC and £56 select the same unit and time period and determine Its
dally location by grid coordinates 1n Vietnam using their respective methods
so that we could compare the two methods 1n concrete rather than theoretical
terms. It was hoped that we would be able to judge which method would be more
suitable for estimating posa1b1l1t1ei for exposure to Agent Orange among Army
combat troops 1n Vietnam, and thus enhance the quality of Inferences concerning the health effects which might be due to such exposure If the results
of the^itudy so Indicated. In order to clarify the purpose of the meeting, 1
prepared an agenda, attached, which outlined two proposed methods for locating
company sized units on those days for which no precise grid coordinate for
the given company was available 1n battalion dally journals or higher level
reports* In addition to the principals listed on the agenda and their
colleagues, the meeting was attended by ttr. Victor Raymond, Majority Staff
Member for the Hospitals and Health Care Subcommittee of the House Veterans
Affairs Coraalttee.
At the beglnlng of the meeting, CDC Indicated that the procedure outlined 1n
method "b" of the agenda was clearly the more accurate but wu probably not
feasible to do for all units wMch would have to be tracked for the study.
The method 1s far too hand-Intensive, relies on Information which has not and
possibly can not be abstracted and coded from the source documents and
requires a level of sophistication for Interpreting records which 1s not
easily acquired on a Urge enough scale to avoid excessive delay 1n the
completion of the study. During the comparison of daily grid Ideations Identified by the two methods on a 3ayby-d*y basis, however, it became apparent
that there were significant gelnt 1ft the accuracy of estimating the dally
location of companies to be had by the contextual approach. The remainder of
;'••;*?:

�tte meeting vis devoted to discussions of how to «ake method "b* more feasible
for uit 1n the ongoing study. ES8 already his sufficient depth of expertise
1n records 1nterprettt1on to undertake the task for a substantial number of
units. It waft suggested by OTA that a good way to screen out units for which
It would not benefit th* study to accurately locate 1s to use method "a* to
Identify units which are more than 25 kilometers from any herbicide application during one-month time periods, and to consider then as unexposed during
that month. Computerlied data already on file at CDC should be accuratt
enough to nake this an efficient and feasible screening process and the anticipated clustering of herb1e1d« applications should yield a substantial number
of battalion-months that trill not require a hand search for loeatlonal Information. As an example, the battalion containing the company which was
selected at random to prepare for the mtlng was never within 25 kilometers
of a herbicide application during the month selected, ind It would have been
unnecessary to more accurately, locate any of the companies of that battalion
during that period. All participants 1n the meeting agreed that the procedures suggested and discussed would benefit the tloely progression and usefulness of the Agent Orange Ep1dem1olog1cal study.

�Agaada far aaatiog
I I« Nofeabar U, J9I5
17)0 K St. Vaihiaitaa, o.C,
Icbadaled PaEtUipaata
Da« Katfea
AOF/CUC
Dl«fe Chriatiaa
II9/VOD
Kola*, Oalbaad
OXA/B1 Caegiaaa
Carl Cellar
4019/IM
the aai* etdet Of kaaiaeee «iU be to att4«pt CO deaetilM aa appropriate
•ethed tot Upuliag Id* apeoifie UTM |ti4 leaetieae of lafiaatry Caapaeite o»
theee &lt;«ye fer ahi«h • preeie* loeetloa 4a not givea la the littalioa Daily
Jevrwai at other battalloa aad higher U*«l rapexte. it laaet t«o
**

tb« 40F «C CfiC voulrf

of eh« ••«• l«et«lioa «bie%

« k»»r» fi««it* loeitloa |iv«a (of tta* •«•« dij 01 tbo§«
for vbicfe «h«r« if a* i«f«x««ti0a ft«o««rdiflc it* lotitlos Xa
tH« lattatioa ox blg\«» l»T«l r«»orta. t»l« Mth«4 aaa th»
«4f««ft«fa of ••ploying a co«p«t»tl«aal alfasiclia «a4 ca« th«a
b« affittlaatly ««aa«rlia«a« »it* a co«f«t«fita4 Jata
b) i ••eb*4 acapoa«a by no «( DOB vovlrf u«* ail availabla lafoc•atiaa» &lt;iala41*f Company Macaiof l*potta» to tatla«&gt;a «feara
•ac* oe«pa»y ta aa cbata rfaya lor able* na ptaeia* lotitfaa
•*i«ta «««»( lattallaa aatf ai|(iar lava! ra««rda. It la DOC
alaar «h*thar tbia approach coiatitataa aa "Ja(o»a4 guaaa",
««« au«b ialas«atlaa ••«!* ba toatAaaiy uaad ea aaalga a loeativa t* ail a«npaaiaa vnlah aight ba ••lactai far tha igaat
Or«ag« Itq4f , not ia« •»e» tla* aovlA k* x»^»tr«4 to toeeapliab tbla eaak.
la far, AAaaaaicattaa avaag th« ptiaaipala aarf tbair igaata baa aet ra*a4 tba tataa »f «backav aaa aacbad ta «ota aaaacata, ar aora i«Ht»lt,
tha a cba attuir, lit aalitaiaa that tba Kacaleg lapocta eoatala aaaful, aad
avaa aaaaatiel, iaCat«atiai a* tha ioaatioa of eaapaar»la«al aatta tor tba
pucpaaaa «f iha Ita4f (i.a,, «* to blag c««paaf laoatiooa altb kac»ioi4a appllaatiaa loaatioaa oaataiaad in tba fetTicaa lacba Tapa). tba U9 baa ae&gt;para4 cba lae»tla» iatfiaata' a* tba Kaialaf ftaparta «it» tbat obtaiaad (ro»
tbair OVA aatdod Car daya fox ahieb tk« loaaftloa of a auabai of aimpaaiaa
•aa kaanv Craai otbar aauraaa, aad foaad thai* ava aatbod t» faa aata aaaotata*
tt «aa aufgaat«4 by QTA aad aOHO tbat auc* a taat aaa laapptoptiata ataaa it
aay vail ba tha aaa« that oa tfeoie* day* for »bicb a |i?aa aaapaay la tlatad
i« battaliaa raevtda it ia alaa «BB« likaiy to ba opacatiaf ia tha fiald aad
aaar »thar ae«paaiaa »f tha aa«a battalioa, vkila aa thaaa daya that it ia
tat liatad aaaag battalia* tacorda it ia aora llhaiy t» ba ia ita baaa ctap
»r athar laaefcifa patitiaa tbat «ay ba.aaat iadieate* oa tba Koraiag ftaport.
! acdar t» b«ip saaaita tba iaaaa t it vaa propoaad oa Oatabar 30 ta oo«•
f"«a tka raaolta aff aaiag aaah at thaa* •atboda oa tha a«aa naita ovar tba
ta&gt;a tica patiad. »la«a tba probiaaj aiaoat aat'taiaiy iavoivaa baa; taaocda
aia ma«d aa wall a* vaiot cacordf ara «aad t it ia aaaaatiai tbat tha raavlta
ta b« «oap«f«d ara ffapavad by tba ia&lt;raa»igata» at tt9 aa4 *OP aecordlai to
tbair raapaativa aatbada, Oaafraaaioaai Itaff praaaat oa Oatabar 30 aadoraad
tbia plan aad hava «taa ra^vaacad that it ba faraaHaa* i* vritiag, far tba
purpaaaa af tka ptaaaat aaatiag, l »m Nvaa^eatiaf that at laaat ail at tha
«a«p«*i«a i* »M at t«a battaiiaia ba ioaatad M lar a apaaifiad aaa ar t«o •
aoatH pariad aaiaf bath ««tbada aa that va ea« aaapaia tha raaaita today»
la ardar to coapara taa»lta,,it *ii4 ba aaaaaaary ta fa tbtoagh a«ih bit of
iafa«a.atiaa aad d«oiala» in aa«« dataii aiace tbara ia •* "gold ataadard*
far itt«pariaoa, It ail* alaa ha oaafal t* a*«aidar tba faaaiaiiity of bath
•atbada Cbr tha fali atady and tha tiaa. aad affatt cca,«ir«4 ta i«pta«aat
thaa aa wall •» tha aff aata of aay aiaaaiaaaifiaatlaa iat*ada«c4 ia th«
a«aigi«a»t ta high a ad low aipoaara eohocta*

�</text>
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                  <text>&lt;p style="margin-top: -1em; line-height: 1.2em;"&gt;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.&lt;/p&gt;&#13;
&lt;p&gt;For more about this collection, &lt;a href="/exhibits/speccoll/exhibits/show/alvin-l--young-collection-on-a"&gt;view the Agent Orange Exhibit.&lt;/a&gt;&lt;/p&gt;</text>
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                    <text>Item D Number

05237

D

NotSBannBfl

Author
Corporate Author
RBOOrt/ArtiGlO Title Correspondence from Erik Jansson of Friends of the
Earth to the Environmental Protection Agency

Journal/Book Title
Year

1978

Month/Day
Color

DBSCriptOn NotBS

n

Letters and attachments express concern over 2,4,5-T and
other herbicides.

Friday, March 01, 2002

Page 5237 of 5263

�' ' &lt;*

FRIENDS OF THE EARTH
620 C STREET, S.E., WASHINGTON, D. C. 20003
(202) 543-4313

/

/ /
' '

iff
-rft/a^.^'e*-

DAVID BROWER, President.

May 11, 1978
*£

Mr. Harvey Warnich
Office of Pesticide Programs
Environmental Protection Agency
401 M Street, S.W.
Washington, D.C.
'

^
**-.

&lt;s

'

"'"•^
^•••

. Dear Mr. Warnich:
We have copied a large portion of our files so that
you will have them available when you upgrade the RPAR
document.
In looking through this material, I hope that you '
can note the following:
(1) The study by Dr. Knight from Santa Monica shows two
Fxtensi e.
'tni-n9s' First, it shows extensive contamination
\ - \ A ~ Contam°f American blood .
samples by 2,4,5-T, Silvex, - 2,4-D
_.,
Blood ' * -,
• , , ,
n
and .., ._ , . , . . .
other herbicides. mi •
This seconds ., ,-,-,
the Florida „State D»
'iination
.
.
study of urine and semen samples.
Secondly, he has analyzed the blood of his patients
that had the virus outbreak after the spray program
in his area. 70 percent of the patients affected
with this virus had significant levels of herbicides
in their blood. This indicates that the Bionetics
finding of lowered resistance in test animals after
exposure to 2,4,5-T likely applies to humans also.

Relation to
Virus

(2) I talked with Dr. A.L. Young (Captain) who has run
the 2,4,5-T and TCDD dioxin studies at Elgin Air
Force Base.
m^o^ 'm i 4 •
Bioaccumulation

He

tells me that they. have proved without a doubt that
_,„.» dioxin ,bio-accumulates. They —;=
,
,
=—;—;
-,
TCDD - , . .
found bioaccumulation
(dioxin levels higher than the soil levels) in insects,
mice, snakes, fish, and a whole series of components.

lazard of
If you look af.,their recently published report (1978)
Rice Application they try to discover why mice are picking up such

high TCDD levels in fat and livers. They found seeds
•of switchgrass in the stomachs, yet this did not show
TCDD above the present levels of measurement capability
which is 10 parts per trillion.
This suggests that application of 2,4,5-T to rice may
offer a very serious health hazard to the average
American.
Committed to the presentation, restoration, and vntioiffil lite of the ccoyihcre

�Since your RPAR document de-emphasizes bioaccumulation,
it appears that it will have to be changed to reflect
these studies. It is also another reason for an
imminent hazard designation.
(3)

The RPAR document fails to note the literature that
is available on the effect of fire and heat on
2,4,5-T. Temperature, as you know, turns this chemical
into TCDD dioxin.

TCDD Dioxin

Produced by
Fire or
Cooking

It appears that cooking a roast may be sufficient to
produce dioxin, which means that any traces of
• . 2,4,5-T in the meat offers and imminent hazard to
the housewife-and her family.

Firewood
Problem

Firewood contaminated with 2,4,5-T is hazardous to
burn and handle. Incidents of four persons suffering
serious harm are reported in the paper on health •
episodes.

(4) Your RPAR fails to mention or analyze the numerous
affadavits and doctor's reports of Americans who
Affadavits
have _lite_ra_lj.^ foundered__ as a result of spray drift
and Doctor's
from pT!afiesapp"ry ing 2 , 4~^ 5-T, Silvex and 2,4-D.
Analysis
Also, large numbers of serious health problems have
been seen among people employed in the forests.
These affadavits are available for your scrutiny and
examination, as you know. Should you be unable to
locate any information along this line, please contact
me.
Spontaneous
Abortions
Above 10
Percent
Cumulative

Poison

(5)

In three spray episodes, spontaneous abortions far
exceeded the normal 10 percent expected for American
women. These episodes occurred in Arkansas, Minnesota,
and Oregon.

(6) James Allen, Wilbur McNulty, and George Streisinger all
note very pointedly' that TCDD dioxin is a cumulative
poison. In the monkey experiments, it does not matter
whether 3 ug/kg of TCDD dioxin is added in one dose or
over time in small doses. The monkeys still die. Captain
Young's grouprhave found damage to spleen and liver in
the microscope' analysis of the mice in their test area.
With best regards,
MAY 24.1978
FEDERAL R£u,ok,»
c. Barry Flamm
c. Doug Costle

WK ,'TIOM

Erik Jansson

�Hand Delivered, June 2, 1978
C i r c u l a t i o n : General D i s t r i b u t i o n

FRIENDS OF THE EARTH

r»
„ -j *
DAVID „
BROVVER, President

620 C STREET, S.E., WASHINGTON, D. C. 20003
(202) 543-4313
June 2, 1978
PETITION

Mr. Doug Costle

Administrator
Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
Dear Mr. Costle:

,

RECEIVED •
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- 2 19/0

Y

Office cf the Assistut Administrator
For Toxic Substances

The undersigned organizations petition you and the
Environmental Protection Agency to take the following actions
to protect the health of Americans and American women, the
health of wildlife, the safety of food, and the quality of
the environment.
(1) We petition you to declare an imminent hazard designation
under FIFRA for 2,4,5-T, a chemical which has come under the
RPAR process.
(2) We petition you to declare an imminent hazard designation
under FIFRA for all pesticides containing TCDD dioxin, as
a generic ban. Silvex is projected to come under the RPAR
process in the next few weeks.
Reasons for (1) and (2)
Reasons for this petition are outlined in the attached
factual background paper.. The conclusion that these pesticides
pose an imminent hazard is clearly documented in the attached
Affadavits from the Field.
To summarize, an imminent hazard designation is necessary because
at present levels of application using customary methods of application
the TCDD containing pesticides have been shown to cause: (a) high
rates of spontaneous abortions and stillborn children (70 percent
rate where skin, gardens.or water supply were contaminated);
(b) death for some of the spray victims; (c) hospitalization for
others of the spray victims; (d) chronic illness for spray victims?
(e) health problems for many spray victims; (f) high rates of
death and illness in wildlife; (g) dangerous levels of contamination
of food.
(3) If there is any delay between now and your action, we petition
you to change the labels of these chemicals containing TCDD
dioxin in the following manner:
(a) change the labels to prohibit use on grazing l.and
in view of the TCDD dioxin found in animal fat
and in milk,

�(b) change the labels to prohibit aerial application
explicitly, because aerial spray guarantees
spray drift and because so many Americans have been
seriously harmed by that spray drift.
(c) change•the labels to prohibit use around the home.
(d) change the labels to prohibit all uses presently
prohibited since 1970 by the label of 2,4,5-T.
(4) We petition you to hire a private lawfirm to represent
the Environmental Protection Agency if your staff cannot
put together an imminent hazard program for the TCDD
containing pesticides.
The Label Program
During the course of reviewing the TCDD containing pesticides,
we have learned a lot about the Environmental Protection Agency
label program. We make two additional petitions relating to that.
(5) We petition you to rewrite all of your pesticide labels
in clear layman's language to inform them specifically
of the following:
(a)
.

a clear list of medical problems in layman's language
that can result from misuse of the pesticide or
contact with the pesticide. (such as miscarriages)

(b) a clear definition of restrictions of the pesticides.
(For example, it is not enough to say do not use on
water, homesites, or recreation. One aerial sprayer
said that he was permitted'within 15 feet of a house.)
(6) We petition you to prohibit aerial application of any
pesticide where label restrictions prohibit spray drift.
Studies by the Environmental Protection Agency and other
government agencies makes it amply clear that spray drift'
cannot be prevented even in mild winds if aerial application
is used. It is clearly a contradictory policy of the
Environmental Protection Agency to permit aerial application
of a pesticide who'se label makes spray drift unlawful.
Sincerely,

Friends of the Earth

Environmental Policy Center
Fund for Animals:

Authorized by Leon Regenstein

�Defenders of Wildlife
Wilderness Society

Citizens National Forest Coalition

u " Y°•
I/^IA^VV w

Coalition for Economic Alternatives

Citizens Against Toxic Sprays, Inc.

7
-•5=7

Rachel Carson Trust

ffL
T

Environmental Action

National Parks and Conservation Assoc

Natural Resources Defense Council:

Authorized in writing by Tom Barlow

Maryland Conservation Council

Potomac River Association

, Jack T. W
/ Preseident

�FRIENDS OF THE EARTH
620 C STREET, S.E., WASHINGTON, D. C. 20003
(202) 543-4313.
DAVID BROWER, President

June 2, 1978
Cover Letter to the Petition

Mr. Doug Costle
Administrator
Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
Dear Mr. Costle:
The attached petition is being forwarded to you for the following
reasons:
iaries of
Vertnik and
Pavel

(1) It shows that many in the environmental community believe that there
is an imminent hazard in the continued use of pesticides containing
TCDD dioxin, like 2,4,5-T. There is a body count already, as you
can see from the diaries of Marion Vertnik and Gladys Pavel. We invite
you to read these. As you can see, people have been killed.
For every year that the Environmental Protection Agency permits these
pesticides to be sold, the body count will increase by about 10 percent.
This is unreasonable,
(2} It shows our concern that a pesticide should be sold that produces
spontaneous abortions and stillborn children (upon contact with the skin
or pollution of water supply or gardens). We invite you to read the
Affadavit of Debra Marano. As you can see, the TCDD level of her garden
due to spray drift from a forestry project exceeded 90 parts per trillion,
and she had four miscarriages as a result.

0 Percent
Spontaneous
Abortion Rate

. As you can also see from the book of affadavits and the fact paper,
of the 23 women reporting that their skin was wet or their water
supply or gardens were contaminated with 2,4»5-T, 16 lost their
babies. This is a rate of 70 percent.
Many of these reports come from small villages that have been sprayed,
and so it is likely that this may be statistically significant. It is
also outrageous.

ontamination
of Mother's
Milk

Contamination of mother's milk with TCDD is a matter of extreme concern,
as are the birth defects associated with these chemicals.
The experiences of American women with regard to spontaneous abortions,
stillborn children, contaminated milk, and birth defects are similar to
the findings of women in Vietnam and Seveso, Italy. High levels of TCDD
were found in mother's milk in Vietnam by Messelson.
•'
C3) We have concluded that the Environmental Protection Agency has substantially
deviated from the legislative intent of FIFRA, which was to avoid
body counts in humans. The use of a judicial or "reasonable man" test
-/ /

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C '•• U f r ^ V J

Committed tn the prcaen&gt;atwri, restoration-and rational usr of the erntphere

�seems sufficient to remove 2,4,5-T from the market.
Indeed, the judges in the recent Oregon District Court and in the recent
Superior Court case in California (brought by the Indian Action Council
against the Humboldt County Agricultural Commissioner) raised questions
about the failure of the government to suspend 2,4,5-T.
• Secondly, the Environmental Protection Agency has the right to require the
r
registration of TCDD, and require manufacturers to submit safety data
MF
before TCDD can be sold as a part of the pesticide.
Third, you can change the label to minimize exposure during the R.P.A.R.
period.
Clearly, the time has come for you to take some immediate action of
some nature on these chemicals.

(4) You now have a substantial amount of evidence, including body counts,
(a) Vietnam: Barely covered in the R.P.A.R. document.
(b) Seveso: Barely covered in the R.P.A.R. document.
(c) New laboratory tests.
(d) Substantial numbers of affadavits from village type of situations.
This means that they can be statistically significant without
sophisticated epidemiological analysis. Also, you have doctor's
reports. You have clear evidence of massive spray drift- from
all over the United States. This material also is barely covered
in the R.P.A.R. document.
Obvious and Weight of Evidence Overwhelming v
We submit to you that the case for suspension of 2,4,5-T has become
obvious and the weight of evidence overwhelming. A_ body count is not
required for removal of a chemical from the market, only a "reasonable man"
or prudent man proof is required.
You do not need any more milk measurements from American women, because.a
body count is not required. You do not need any more laboratory studies- because
you have enough for a "reasonable" man test. You do not need any more American
health data than is available already to your staff, if they would just pick
up the phone or read the affadavits that we have enclosed.
The Public Is Not Going to Understand
In the fact of such large numbers of deaths, spontaneous abortions,
and cases of chronic illness in American citizens, I fail to see how the public
is going to understand the decision of the Environmental Protection Agency
to take a leisurely approach to 2,4,5-T.
./
Sincerely.

Erik Jansson

�FRIENDS OF THE EARTH

'
e

620 C STREET, S.E., WASHINGTON, D. C. 20003

ff/ster

(202)543-4313

^

D A V I D BkowhK, I'tcsidcnt

June 2, 1978

t
Federal Register Section, Technical Services Division
Office of Pesticide Programs, EPA, Room 401
East Tower, 401 M Street, S.W.
Washington, D.C. 20460
Re: OPP-30000/26

(WH-569)

(2,4,5-T Rebuttable Presumption Against Registrat

Dear Sirs:
The attached PETITION, are our response to the RPAR
Factual Paper supporting PETITION
Book of Affadavits from the Field
Xeroxed Studies
process. As you can see, we have met your first deadline
of June 5, 1978, because Friends of the Earth asserts that
the Environmental Protection Agency has had sufficient information
since 1970 to suspend the registration of 2,4,5-T.
Request to Leave Our File Open for 60 Days
We request that you keep our file open for 60 days
so that during this period we can submit further affadavits
of injury to people and wildlife due to exposure to 2,4,5-T.
Sincerely,

Erik Jansson
Research Associate

c. Peter Kirby, N a t i o n a l W i l d l i f e Fed.
c. Tom Barlow, NRDC

�FRIENDS OF THE EARTH
620 C STREET, S.E., WASHINGTON, D. C. 20003
(202) 543-4313
DAVID BROWER, President

BACKGROUND PAPER to PETITION FOR AN IMMINENT
HAZARD FOR 2,4,5-T and the TCDD CONTAINING
PESTICIDES

Prepared by:
Erik Jansson
Research Associate
May 26, 1978

�TABLE OF CONTENTS

I

Shift from a Judicial Standard of Proof

Page
1

Scientific Standard of Proof Still Prevails
at E.P.A.
The Need for an Imminent Hazard Declaration for
TCDD Pesticides Including 2,4,5-T

2

Lack of Information on the TCDD Contaminant Is Grounds for
Suspension of the Registration of Pesticides Containing It
SUMMARY OF OUR FACTUAL FINDINGS
PART I:

PRESENT LEVELS OF EXPOSURE OF AMERICANS
TO 2,4,5-T COMPOUNDS and TCDD ARE IN A
ONE TO ONE RELATIONSHIP TO LABORATORY
FINDINGS.

CONCLUSIONS, PART I:
PART II:

THE TCDD DIOXIN HAS BEEN SHOWN TO
BIOACCUMULATE IN THE ENVIRONMENT AND TO
HAVE A CUMULATIVE EFFECT ON HEALTH
-

3

5

6

CONCLUSIONS, PART II:

7

PART III: THE EXTENT OF POTENTIAL HEALTH DAMAGE

8

CONCLUSIONS, PART III:

9

PART IV: EPIDEMIC OF HEALTH EFFECTS REPORTED
FROM AMERICANS

10

CONCLUSIONS, PART IV:

12

PART V: EPIDEMIC OF WILDLIFE EFFECTS

13

CONCLUSIONS, PART.. V: •
PART VI:

LACK OF EMERGENCY TREATMENT CAPABILITY

14

CONCLUSIONS, PART VI:
PART VII:

ECONOMICS: 2,4,5-T IS A MARGINAL
ECONOMIC PESTICIDE

15

CONCLUSIONS, PART VII:
PART VIII:

LACK OF ADMINISTRATIVE SAFEGUARDS
17
BY THE ENVIRONMENTAL PROTECTION AGENCY

CONCLUSIONS, PART VIII:

18

�1.

In 1973 and 1974, a series of decisions by the
management of the Environmental Protection Agency led
to a considerable change in who must bear the burden of
proof in regulating pesticides and removing them from the
market.
Shift from a Judicial Standard of Proof
The Federal Insecticide, Fungicide, and Rodenticide
Act had envisaged that there would be a judicial standard
of proof that would make experimentation upon humans not
necessary. A standard of "reasonable" man was the trend
of this legislation.
In 1974, the management of the Environmental Protection
Agency decided to leave 2,4,5-T on the market, while they
developed instrumentation to detect the TCDD dioxin and
determine whether it might be entering the food chain.
This decision basically asserted that from that time
on the Environmental Protection Agency Would be required to
prove in the strictest scientific sense (as opposed to the
judicial standard of proof) that humans were actually being
harmed by the pesticide (a body count) before the pesticide
could be removed from the market.
As William Butler, counsel for the Environmental Defense
Fund, said at the time, this meant that the EPA was giving
herbicide manufacturers the go-ahead to use the environment
as their laboratory. "The EPA apparently has decided that
the EPA (rather than the manufacturer) must shoulder the burden
of proving or disproving the safety of 2,4,5-T and related
compounds; and that continued use should be allowed as long
as the severity of the hazards remains uncertain."
Scientific Standard of Proof Still Prevails at EPA
Now that instruments have been developed to measure
TCDD dioxin to the 10 parts per trillion level, the worst
fears of food contamination have been realized. Dr. Meselson
et al of Harvard University have found TCDD dioxin in mother's
milk at levels up to 1.6 parts per trillion in the Oregon
and Texas spray areas.
Extraordinary levels of TCDD have been found in beef
fat from treated rangelands and in wildlife in the spray
areas of Oregon. Average beef fat levels were found to be
10 parts per trillion with a range of 5 ppt to 65 ppt.

�One third of the beef fat samples from the treated
areas were found to be contaminated.
This contamination of food has been determined to be
proof enough for beef, according to EPA monitoring specialists.
But, conforming to the 1974 decision to shift from the intent
of FIFRA and away from the judicial standard of proof, EPA
says that contaminated food is not sufficient. We have to
nave
perfect scientific proof (to meet the scientific standard
of proof that is not envisaged by FIFRA). We must have
body counts in humans, and actually detect TCDD in human tissue.
We must also detect TCDD on the basis of three laboratory
tests, according to present scientific protocol.
Considering the fact that Dr. James Allen has found
that TCDD produces cancer in laboratory rats at 5 parts per
trillion, and Dr. Jacqueline Verrette has shown that 2 parts
per trillion produces embryo defects in chicken eggs and
8 parts per trillion produces a 50 percent mortality of those
embroyoes, we believe that the performance of EPA shows
an outrageous interpretation of FIFRAf and a callous disregard
for the safety of Americans.
The Need for an Imminent Hazard Declaration for the TCDD
Pesticides Including 2,4,5-T
Any time that the contamination of food or the
contamination of people with pesticides reaches a level
which produces harmful effects in laboratory animals,
it is clear that that pesticide should have been banned
long ago. A prudent person and prudent scientific thought
indicates that there should be a wide margin between human
exposure to a toxic chemical and exposure levels found to
cause serious effects in laboratory animals.
It has become clear from laboratory tests and measurements
of TCDD in food that a one to one relationship between exposure
levels to humans and levels that produce effects in laboratory
animals now exists.
Furthermore, this one to one relationship has been demonstrated
in numerous health epidemics due to the use of 2,4,5-T in the
field since 1970.
Lack of Information on the TCDD Contaminant Is Grounds for
Suspension of the Registration of Pesticides Containing It
TCDD has never been registered as a pesticide, yet
it is sold as part of the pesticide package. The Environmental
Protection Agency has the right to require its registration,
and proof from the manufacturer in the form of scientific tests
that it is safe. It is contrary to the provisions of FIFRA
to require the Environmental Protection Agency to prove that
an unregistered chemical used as a pesticide component be proved
safe, rather than the manufacturer.

�SUMMARY OF OUR FACTUAL FINDINGS
PART I: PRESENT LEVELS OF EXPOSURE OF AMERICANS TO 2,4,5-T COMPOUNDS and
TCDD ARE IN A ONE TO ONE RELATIONSHIP TO LABORATORY FINDINGS

Cancer at 5 Parts Per Trillion
Dr. James Allen at the Primate Lab of the University of Wisconsin
has found that 5 parts per trillion of dioxin in the diet of
rats over 18 months produced a signficant amount of cancer.(1)
Mother's milk in the spray areas of Oregon and Texas have
been found to contain dioxin (TCDD) levels up to 1.6 parts per
trillion by Meselson et al of Harvard University. Since babies
are fed for 4 months, this suggests that these mothers are giving
their own children cancer. (2) TCDD was also found in human milk in Vietnam.
Birth Defects at 2 Parts Per Trillion
Dr. Jacqueline Verrett of the Food and Drug Administration has
found that 2 parts per trillion of dioxin causes embryo defects
in chicken embryoes. At 8 parts per trillion 50 percent of the
embryoes die. (3)
This means that when a pregnant woman reduces and releases the
dioxin from her fat that she can cause birth defects in her own
child. The large number of stillborn children among women
contacted by spray drift from 2,4,5-T in spray areas of America
show an impact upon the fetus.
Many doctors recommend that women reduce during pregnancy.
Blood Measurements and Urine and Semen Measurements of 2,4,5-T
in Americans Indicate a Widespread Contamination at Levels
Shown to be Harmful
Dr. Granville F. Knight, M.D. from Santa Monica has analyzed
100 plus blood samples from patients, and found more than half of
them to have measurable levels of 2,4,5-T, 2,4-D, 2,4-DP, or Silvex. (4)(5)
A distinct fit has been shown by Dr. Knight with the large scale
virus epidemic that fit the spray areas. It appears that human
resistance to infection is reduced by exposure to 2,4,5-T, just
as resistance of laboratory animals is reduced. 70 percent of
his patients with this virus had measureable levels of herbicides
in their blood.
Dougherty and Piotrowska found measurable levels of 2,4,5-T in the
.&lt;•
urine of 36 percent of Florida State University dormitory students,
Silvex in 36 percent of the dormitory students and 24 percent of
the FSU football team, 60 percent had 2,4-5-Trichlorophenyl, and
food and city water were found contaminated with Silvex and 2,4,5-T. (6)

�For comparison, a worker in the Hoedad group in Oregon had is
blood levels measured after suffering phenoxy symptoms and found
5.5 parts per billion of Silvex and less than 5.0 parts per
billion of Krenite.(7)
TCDD Levels in Food and Wildlife Have Been Measured At Levels
Harmful to Humans
Dr. Meselson found that one third of his samples of fat from beef
fat grazing on rangeland treated with one pound or more of 2,4,5-T
were found to contain TCDD at concentrations of 5 ppt to 65 ppt.
The average level of TCDD in the beef fat of all the animals from
treated rangeland is of the order of 10 ppt. (7)
There was a distinct relationship between the poundage of 2,4,5-T
applied per acre and the quantity of TCDD found in the beef fat
(suggested at a ratio of 1 pound of 2,4,5-T produces 4 ppt of
TCDD in the fat).
In the Siuslaw National Forest in Oregon, TCDD levels measured under
the auspices of EPA found 15 percent to contain TCDD. The mean
level in all animals examined (including the 85 percent in which
no TCDD was detected) was about 10 ppt, with values ranging from
12 ppt to 143 ppt. This indicates a distinct hazard to hunters
eating game from sprayed areas. (8)
Mahle et al found six positives for TCDD in cow's milk, five from
sprayed pasture areas and one from Midland, Michigan. (9)
Very high levels of TCDD have been found in wildlife and fish
in Vietnam, and one sample of codfish from Boston was found by
Meselson to have 3 ppt. (10)
All these measurements are at levels known to produce very serious
effects in laboratory animals.
Burning of Wood Contaminated with 2,4,5-T and Probably Cooking
Produces TCDD Dioxin
Another area of exposure is the burning and handling of sprayed
wood. Five cases of acute medical harm are reported in Part IV
due to exposure to treated wood or burning of the same.
High temperatures are known to produce TCDD from 2,4,5-T. The
attached paper describes some of the literature on this subject, (11)
and further studies are described in the attached British Columbia
study. (12)
Roasting of meat and vegetables at typical oven temperatures recommended
by cookbooks will also produce TCDD, if the food is contaminated with''
2,4,5-T. This was testified to by EPA in 1970. (13)

�5.

Application of 2,4,5-T and 2,4-D Mixtures and Work in Sprayed
Areas Pose Severe Public Health Issues
The affadavits of workers to severe health problems after
working in spray areas of Oregon that were sprayed with 2,4,5-T
or Silvex are presented in the attachments in full.
Voders study of chromosome abnormalities among herbicide applicators
show a marked increase in chromosome abnormalities among workers
exposed to herbicides during the spray season. (14)
Axelson and Sundell in looking at the epidemiology of Swedish
railroad workers appling 2,4 -D and 2,4,5-T and Amitrole
found the following: For the group exposed to Amitrole (with
some exposure to diuron and or monuron) tumor incidence and
mortality significantly increased. Those applying 2,4-D and
2,4,5-T showed slightly more than the expected tumor incidence
and mortality. (87 workers were involved in the study.) Males
had more tumors. (15)
The R.P.A.R. document is clear in its opinion that exposure to
persons during the spray operation for 2,4,5-T offers too little
a margin for safety for those workers, and this is one of the
grounds for the R.P.A.R. proceedings.

Konstatintinova's study shows the possibility of fetus change in the
second and third generation of mice. (15a)
CONCLUSIONS, PART I: A one to one relationship between present

food and environmental levels of 2,4,5-T and
TCDD and levels that have shown to cause serious
health problems in laboratory animals would be unacceptable
under the "reasonable" man test of FIFRA.
In view of the extreme health effects shown
to come from exposure of humans to 2,4,5-T and
TCDD (Part IV), the Environmental Protection
Agency should take these compounds off the market
immediately.

�6.

PART II: THE TCDD DIOXIN HAS BEEN SHOWN TO BIOACCUMULATE
IN THE ENVIRONMENT AND TO HAVE A CUMULATIVE EFFECT
ON HEALTH
Bioaccumulation
Captain A.L. Young, M.D. has finished the Air Force studies
of TCDD at the test plots at Elgin Air Force Base. They
confirm the initial findings of the 1974 study (16) that
TCDD bioaccumulates in the environment in insects, mice,
snakes, fish, and a whole series of components. (.17)
The studies of Meselson in Vietnam and Suislaw National Forest
show distinctive bioaccumulations. (18)
Hazard of Application to Rice
The 1974 report of Young (16) tries to discover why mice are picking
up such high levels of TCDD in fat and liver. They found seeds
of switchgrass in the stomachs, yet the seeds did not show TCDD
above the present levels of measurement capability which is 10 ppt.
This suggests that application of 2,4,5-T to rice may offer a very
serious health hazard to the average American. It has been shown
that TCDD can be transported into oat and beam plants, and oat
seeds. (19)
Toxicity of TCDD and Cumulative Effect on Health
Various authors have commented on the relative toxicity of TCDD.
It has been noted that it is somewhat more toxic than mustard
warfare gas
and suggested that it was similar to
the toxicity of radiation.
Numerous scientists have suggested that the Allen tests of monkeys
with TCDD show a cumulative effect on health. This has been pointed
out by Streisinger, McNulty, Jacqueline Verrett. (20)
It is pointed out that in the monkey experiments, it does not matter
whether 3 ug/kg of TCDD is added to the monkey's diet in one does,
in 500 ppt doses or 10 ppt doses over a longer period of time.
In every case, once the lethal level is reached the monkeys die. Furthermore,
TCDD appears to continue to work adversely upon health after the
diet addition is ceased.
Captain Young's group has found damage to the spleen and liver in microscope
analysis of the mice from their test area. (21)
t

(

Streisinger goes even further, suggesting that it is quite possible
that it would only take 65 meals contaminated with present levels
of TCDD to get humans into a difficult health situation. Furthermore,
these meals do not have to take place all at once, but over a lifetime.(22)

�Ability to Cross the Placenta
Moore's rat study traced TCDD across the placenta into the fetus, using
radioactive carbon. A single oral dose of 5 ug/kg was given to
344 rats, and radioactive TCDD was found in the fetal liver. There
was a high concentration also in postnatal experiments, because the
TCDD was secreted in the mother's milk.(22a)
Dancker's mice experiment showed that fetal defects were affected by
the time of exposure to 2,4,5-T. During the first 10th to llth day
when the yolk sac and placenta was the only route to the fetus, there
was no measured 2,4,5-T. But in the llth to 18th day period, there
was an increased passage. Birth defects showed up only in the 13th
or 14th day or beyond when there was significant amounts of 2,4,5-T
found in the fetus. (22b)
Konstatintinova's study shows the possibility of fetus change in the
second or third generation of mice.(22c)

CONCLUSIONS, PART II: A prudent man or "reasonable" man- the test
that FIFRA established as the one that the
Environmental Protection Agency was to usewould not permit a chemical (a) a little more
toxic than mustard gas (b) about equal in toxicity
to radiation to be sprayed over people's homes,
to be used on the lawns of the average American,
to be used on pasture!ands when it had been proven
that that chemical was moving into the food chain.
A prudent or "reasonable" man would take a chemical
off the market immediately if it was shown to have
cumulative effects of substantial nature.
A prudent or "reasonable" man would take a chemical
off the market immediately if it bioaccumulated
in the environment. EPA has a responsibility to
the environmental also.

�PART III: EXTENT OF POTENTIAL HEALTH DAMAGE
Forest Workers
The State of Oregon employment division lists 12,700 workers in
logging in the annual average 1977. Many of these work
in areas that are affected by spray drift. There are also large
thinning crews in many states that work directly in spray areas,
and who have shown a substantial health effect due to exposure
to 2,4,5-T. 4,000 transplanters work in Oregon.
Residents of Spray Areas
Without their permission, spray drift can affect residential areas,
and has in several cases with catastrophic effects. (See Part IV)
It is estimated that 1 out of 8 persons in Oregon live in or
adjacent to forested areas or a total of 100,000.
Inversions
Several California incidents show that inversions can spread herbicides
far beyond the spray areas, and cause epidemics of health effects.
(See Part IV)
Forest Fires
Production of TCDD dioxin by forest fires in spray areas offers
the potential of an epidemic situation. Furthermore, fires are
encouraged in such areas because the herbicides do not cause the
dead leaves of the hardwoods to fall to the ground.
Food
Just about everyone eats beef and drinks bovine milk. The contamination
shown for these products indicates a possible epidemic through this
route. Symptoms may range from loss of child to untimely death,
none of which would be picked up except through a sophisticated
epidemiological survey after the fact.
The contamination of wildlife has been suspected in some of the
poisonings that have occurred in the Western states.
Use Around the Home
Labels of Silvex sold in hardware stores do not presently inform
the reader that miscarriages and stillborn babies, birth defects,
acute health problems, chronic health problems such as cancer
can result.

�CONCLUSIONS, PART III:

It would be a reckless person who would permit the
exposure of such a large population to TCDD as that
listed in Part III, in view of the extreme toxicity
of that compound.
FIFRA was passed to prevent catastrophes, and a
reasonable man would suspend the registration of
TCDD containing compounds.

�ID.

PART IV: EPIDEMIC OF HEALTH EFFECTS REPORTED FROM AMERICANS
(1) Abortions and stillborn children:
The 2,4,5-T and TCDD mixture appears to be remarkably efficient
in producing spontaneous abortions and stillborn children,
far above the 10 percent level expected for American women.
Since the reported incidents below (which are backed up by the
attached affadavits) occurred generally in small self-contained
settlements, they are as valid indications of the epidemiology
of spontaneous abortions and stillborn children a^ a .sejf-contained
laboratory experiment. A "reasonable"-or prudent man would be flabergasted.
All of the women involved testify that 2,4,5-T spray wet their
skin, or contaminated water supplies or gardens.
(a) 6 out of 8 women lost their babies in Fayetteville,
Arkansas after a field was sprayed with 2,4,5-T above
a spring supplying water to 20 people. (26)
(b) 4 out of 9 women contacted with spray drift in Oregon
lost their children. (See Kail an report) (27)
(c) 1 out of 1 woman had a stillborn child after walking in a back yard
'that.had been contaminated with 2.4,5~T spray'drift two days
before. (See diary of Marion Vertnik). (28)
(d) An estimated 5 out of 5 lost their babies after spray in a
small settlement in northern Wisconsin (less than 40 families)
after spraying that was done over their homes. This high
rate has continued in this area, with stillborns and
spontaneous abortions.
Last summer there was a deformed baby, with one side of the head
flattened and side of the body stiff. These problems occurred
within a half mile of the original 1971 spray area, and roadside
spraying has gone on since. (29)
(e) For comparison, a ratio of 1 out of 4 women lost their children
in Sevesco, Italy after the TCDD disaster. '51 spontaneous (as compared
to the'many medical) .abortions were recorded or 22 percent rate. (30)
(f) A woman who had her skin wet from a 2,4-D spray on a campus
in northern Wisconsin lost her child in a spontaneous abortion
soon after. (Report of John Stauber)
(g) For comparison, at Hospital A, Dr. Ton That Tung and
collegues reported 22 out of 73 pregnant women interviewed
had miscarriages following spray applications, and there
were similar cases in farm animals. The stillborn rate doubled
at Tay Ninh City provincial hospital. They reported a rate of
58 out of 1000 in a spray area compared to low spray area
of Saigon where the stillborn rate was 29 out of 1000 for the
same period. (30b)

�For comparison, a woman in West Virginia, well along in pregnancy,
did not have her skin wet by the Appalachia Power Company, but they
had to "live with the odor" for a day. She had cramps as a result,
but did not lose her baby. (30$)

�11,

(2) General phenoxy related illness:
The enclosed reports on several hundred affected people in 8 states
due to spray drift from 2,4,5-T show all the classic symptoms
of phenoxy herbicide poisoning.
(a) Summary report of the 8 states.(phone numbers enclosed for EPA)
(b) Affadavits from Oregon'and report of Dr. Kail an.
(c) Affadavits from California where an inversion caused 2,4,5-T

air pollution, with serious health effects.
(d) Affadavits from Arkansas.
(e) Diary of Marion Vertnick, Minnesota.
(f) Description of West Virginia cases.
(g) Affadavit of Cathy O'Hagan- spray of a school by
by the AppaTachia Power Company.
(h) The Arizona account

printed in the 1970 House Hearings.

(3) Relation of 2,4,5-T and herbicides levels in blood to virus
infections.
2,4,5-T and TCDD have been shown to attack the thymus, reducing
resistance to infection in laboratory animals. Similar effects appear
in humans, shown by the outbreak of virus attacks right after spray
drift affected some areas of California.
(a) In Branscomb, California in 1974, 36 residents demanded

an investigation.(31)

(b) Dr. Granville, Knight finds that in his patients 70 percent
affected by the 1977 virus had measurable levels of herbicides
in their blood. The sample size was over 100. (32)
(4) Birth defects.
Theodor Sterling testifies that 50 percent of the birth defects in
British Columbia are of the phenoxy herbicide type. (33)
After the spray of the Tonto National Forest at Globe, Arizona,
there was indication of birth defects of the phenoxy type. In July
1970, the Arizona Commissioner of Health wrote a letter to the
Gila County Board of Health saying that "...your county is leading
the state in deaths caused by diseases of early infancy and
fetal deaths... there are excessive deaths from congenital
malformations." (34)

,

�CONCLUSIONS, PART IV: A reasonable or prudent man- the test under which
FIFRA was intended to operate- would be flabergasted
and shocked by the numerous spray episodes involved
with 2,4,5-T.
It is quite clear that the public cannot be protected
from extremely serious health effects from the
chemical and TCDD contaminant with the standard
application method. In California, the possibility
of inversions and 2,4,5-T air pollution is a matter
of great concern.
No reasonable or prudent man would leave the 2,4,5-T
type of chemicals on the market, and would suspend
the registration of these chemicals to protect
the public from the epidemic type of health problems
that are already occurring.

�PART V: EPIDEMIC OF WILDLIFE EFFECTS
The Environmental Protection Agency has the mandate to protect
the environmental quality as well as human health. The use of
2,4,5-T has had a substantial effect on wildlife, effects that
have been recorded, as well as unknown effect upon endangered
species. For example the following:
(a) 400 deer were killed in the Superior National Forest,
as estimated from deaths in sampling pens. This was
after spraying, and during a mild winter when stresses
were minimal. (35)
(b) Large deer kills were found in Oregon- a substantial
percentage reduction in deer populations. (36)
(c) Boils on deer and rabbits were observed in Minnesota,
an indication of a breakdown of the immune system.(37)
(d) 8,000 steel head trout were killed by spray drift
in Oregon. (38)
(e) Dead or defective born wildlife were observed at many

and indeed most of the spray sites such as Trinity County, Calif
where massive deer kills were reported. (39)

Contamination of Waterways
The U.S. Geological Survey in every year from 1968 to 1.976 has detected
2,4,5-T in 30 to 65 percent of its 60 sampling stations. Silvex was
found in up to 10 percent of the 60 sampling stations.(39a)
This has happened despite label restrictions against application to waterways.*
Further Wildlife Information Available
We believe that there is a great deal more information on adverse effects
of 2,4,5-T on wildlife. The Environmental Protection Agency can develop
more information by contacting the wildlife managers of the National Forests
and the residents of the spray areas. Furthermore, Meselson's study shows
a great buildup of TCDD in the spray areas of Suislaw.
Violation of the Endangered Species Act is suggested'by the attached
letter from Thomas. Morley, U.,of Minnesota Department of Botany.

*There is every reason to.believe that aerial application should be considered
a point source vf water pollution by the Environmental Protection Agency!

�CONCLUSIONS, PART V: A reasonable or prudent man - the test under which
FIFRA was intended to operate- would find the
very heavy wildlife kills to be unacceptable.
It is clear that wildlife (and endangered species)
cannot be adequately protected if 2,4,5-T and
the TCDD pesticides are used on large scale control
of weeds.
Since it has proved impossible to prevent the buildup
of TCDD in wildlife through bioaccumulation (similar
to DDT) a reasonable or prudent man would suspend
the registration of the chemical carrying it.

�0.1

PART VI: LACK OF EMERGENCY TREATMENT CAPABILITY

There is no emergency treatment capability for the following
health effects:
Acute
(a)

chloracne:

only time or plastic surgury can handle this problem.

(b) birth defects
(c) stillborn children
(d) spontaneous abortions
(e) bahavioral changes
(f) skin rash, diarrhea, intestinal problems and all the

other symptoms.
The physician listed by Chevron to assist with poisonings with Silvex
(Ortho) does not have any knowledge of the literature on birth defects
for Silvex. (Call by John Stauber, May 18, 1978)
Chronic
There is no effective medical treatment to prevent the following
effects:

(a) cancer
(b) birth defects
(c) untimely and early death (See Streisinger)
CONCLUSION, PART VI: One of the tests for removal of a pesticide from
the market is the availability of emergency treatment
to solve the health effects. No such treatment
programs exist for 2,4,5-T and the TCDD pesticides.
Indeed many of the health effects for TCDD have been
shown to be chronic. Permanent damage to body
organs and storage of the TCDD in fat, for later
release, are effects that medical science has
no solution for.
This is one more argument, using the "reasonable" man
or prudent man test, that the registration of 2,4,5-T
and the TCDD pesticides should be suspended.

�PART VII:

ECONOMICS: 2,4,5-T IS A MARGINAL ECONOMIC PESTICIDE

Several economic papers are attached to this fact sheet with
the following conclusions:
Forestry (41) (42)
2,4,5-T and herbicides used to promote pine growth appear to
reduce yields in the pine. Visible damage and growth stunting
are two areas of concern.
Secondly, most hardwood spray programs leave the hardwoods standing.
When they rot at the base, they fall, crushing the pine. In one plot
36 percent of the pine were crushed, which means a 36 percent reduction
of fiber yield.
Third, hardwoods produce a higher quality fiber that brings a higher
price per acre, even after one adjusts for the longer growing period.
We have concluded that at the most, 2,4,5-T is a marginal pesticide
in forestry, and suspension of its registration would not have a
great impact (possibly favorable) upon forest yields and profits, and
the national balance-of-payments.
Range! and (.43)
Use of 2,4,5-T to control sagebrush and mesquite is a marginal operation
presently due to the high price of the chemical, and due to the recovery
of the sagebrush.
Furthermore, the proven bioaccumulation of TCDD dioxin in beef fat
could and may
cause a panic in the meat market, similar to
the cranberry scare and numerous other scares of the past.
Utility Lines (44)
The high price of 2,4,5-T almost certainly makes this a marginal chemical
if utilities were to compute costs, as they often do not.
Furthermore, there is good reason to believe
of time a stable vegetation can be grown on
right of ways. (These utility right-of-ways
and vegetation management can take a longer

that over a period
powerline and utility
are long term investments
viewpoint.)

The beginning of a period of damage suits against sprayers also changes
the cost equation.
Rice (45)
Due to the low resolution quality of present instruments, it is presently
impossible to measure TCDD residues of less than 10 parts per trillion.
And so we cannot be certain that rice does not contain TCDD. The capacity
of this chemical to come into the plants and seeds has been demonstrated
at high application levels.

�16.

In Arkansas, 2,4,5-T is used to control morning glory. There are
likely substitutes. For example, the Rohm &amp; Haas Blazer, being
registered for soybeans, will likely do a good job on morning glory
in rice without harming the rice.
Mice feeding on seeds have been shown to have high levels of TCDD in
their fat and livers, despite the fact that TCDD cannot be measured
in the seeds.
The rice industry also appears ripe for a cranberry scare.

CONCLUSIONS, PART VII: A "reasonable" or prudent man would have a hard
time buying the argument that heavy health and
environmental risks should be undertaken for
a marginal economic chemical, for which substitutes
exist and whose price is so high that the substitutes
are quite comparable in economics.

�PART VIII:

LACK OF ADMINISTRATIVE SAFEGUARDS BY THE ENVIRONMENTAL
PROTECTION AGENCY

It is not possible to use 2,4,5-T safely, or any of the TCDD
pesticides for the following reasons.
Label Definitions:Lack of Layman Clarity About Health Effects
It is possible to buy TCDD pesticides (Si 1 vex) off the shelf in
hardware stores and drugstores. The label instruction for Si 1 vex
contains only a warning to keep away from children.
From this label, it is impossible for the consuming public to
know that the compound causes birth defects, spontaneous abortions,
or stillborn children.
Furthermore, in aerial applications of 2,4,5-T, the label is equally
unclear about what is meant about keeping the pesticide away from
houses, recreation areas, water areas etc. Because of this lack of
clarity, the chief forester of the Appalachia Power Company testified
at a public hearing that it was his understanding that they could
spray within 15 feet of a house.(46) He felt that this was lawful.
It is quite clear that at the present time the Environmental Protection
Agency does not have a label program.
Reliance on the manufacturer for health information is no program at
all. John Stauber called the physician at Chevron, who is supposed
to tell people in an emergency what to do. He was uninformed about
the effect of Silvex upon spontaneous abortions, birth defects, and
stillborn children. (47)
Lack of Manpower for Label Enforcement
Even if the labels were informative, which they are not, the Environmental
Protection Agency lacks the manpower to enforce the label.
It is quite clear that the Environmental Protection
have a label enforcement program.

Agency does not

This is shown quite clearly by the Environmental Impact Statements
filed by the Forest Service for the Idaho region, which proposed to
use 2,4,5-T in all the forbidden use areas. .
Lack of Control Over TCDD
The ability of TCDD to bioaccumulate makes it impossible to control.
a

Furthermore, the ability of TCDD to be generated by heat of fire
or cooking makes it impossible to control.
The present manufacturer's agreement to reduce the levels of TCDD
in 2,4,5-T is not sufficient, because it has been shown that TCDD
may accumulate if the 2,4,5-T is stored in the sun'for a period of time,

�18.

Furthermore, there is no government program that is established
to reject high TCDD containing shipments of 2,4,5-T. Even
if this were done, the bioaccumulation of TCDD in the environment
would make this a meaningless program.

CONCLUSIONS, PART VIII: A prudent or "reasonable man, which is the test
for FIFRA, would insist that the registration
of the TCDD pesticides be suspended, because
there are no present Environmental Protection
Agency safeguards to minimize exposure to the
population and secondly, because the TCDD
content of the chemicals, before and after
application cannot be guaranteed to remain small

�FOOTNOTES

(1) Phone conversation with Dr. Allen, who is under contract with
E.P.A.
(2) Messelson, Matthew et al. Freedom of Information inquiry by
Congressman Jira Weaver. 12/15/76
(3) Verrett, Jacqueline, Unpublished Study: The Effects of 2,4-D,
2,4,5-T and Their Contaminants on the Developing Chicken
Embryo. Food and Drug Administration, Division of Toxicology/ADS
Bureau of Foods.
(4) Knight, Granville, F., Testimony in Citizens Against Toxic Sprays vs.
Earl Butz, Civil No. 76-438, U0S0 District Court for the District
of Oregon.
(5) Statistical analysis of patient's blood levels of herbicides
and virus outbreak.
(6) Dougherty, Ralph C and Krystyna Piotrowska, "Screening by negative
chemical ionization mass spectrometry for environmental contamination
with toxic residues: Application to human urines. Proceedings National
Academy of Science, U.S.A. Vol. 73, No. 6, pp. 1777-1781, June 1976.
(7) Affadavits from Citizens Against Toxic Sprays vs. Earl Butz, ibid.
Affadvavits included in folder with this presentation.
*(7a) Meselson, Matthew et al. The Evaluation of Possible Health Hazards
from TCDD in the Environment., Presentation for Symposium on the Use
of Herbicides in Forestry, Arlington, Val. Feb. 21-22, 1978.
E.P.A. and U.S. Forest Service.
(8) Worthington, R.E., 1978. Final Environmental Statement, Vegetation
Management with Herbicides, Pacific Northwest Region Forest Service,
U.S.D.A.
(9) Mahle, N.H. et al, "Search for the Presence of 2,3,7,8-Tetrachlorodibenzo-p-Dioxin in Bovine Milk."Bulletin of Environmental Contamination
&amp; Toxicology, Vol. 18, No. 2, 1977
(10) Meselson, Reported in RPAR study.
(11) Whaley, Betty Lou, Statement on Fire Hazards of Herbicides, Sept.
1977, Environmental Protection Center, P.O. Box 17,
Fort Bragg, California 95437
(12) Warnock, John W. and Jay Lewis, The Other Face of 2,4-D. South
Okanagan Environmental Coalition, Box 188, Penticton, British
Columbia, 1978
/

(13) Whaley, idem.
(14) Yoder, J. et al. 1973. Lymphocyte chromomome analysis of agricultural
workers during extensive occupational exposure to pesticides.
Mutation Res. 21. 335-340.

�20

(15) Axelson, 0. and L. Sundell, "Herbicide exposure, mortality, tumor
incidence, And epidemiological investigation in Swedish railroad
workers." Work Envir. Health 11(1} 21-23, 1974
(l5a).Konstat1nt1nova, T.K., Gig Tr Prof Zabol 9, 29-32, 1974
(.42 mg/kg dose failed to change fetus but 2nd and 3rd generation
were changed)
(16) Young, A.L. Captain, Ecological Studies on a Herbicide-Equipment
Test Area, Eglin AFB Reservation, Florida, Technical Report
AFATL-TR-74-12, Air Force Armament Laboratory, January 1974
(17)

/
./

Phone conversation with Captain Young.

(18) Worthington, idem. Also, Baughman R, and M. Meselson, 1973
An analytical method for detecting TCDD (dioxin): levels of TCDD
in samples from Vietnam. Environmental Health Perspective 5:27-34.
(_19) Insensee, A.R. and G.E. Jones, 1971, J. Agr. Food Chem. 19(6):1210-1214

(20)

Verrett, Jaqueline, Hearings, April 7 and 15, 1970,
Subcommittee on Energy, Natural Resources and the Environment
Serial 91-60, House of Representaitves (Comm. on Commerce)
McNulty, Wilbur, phone communication.
Stresisinger, George, Testimony in Citizens Against Toxic Sprays
versus EarhButz, ibid.

(21)

Young, ibid.

(22)

Streisinger, George, ibid.

(22a) Moore, J.A. et al, National Institute of Environmental Health,
Research Triangle Park, Toxicology App. Pharm. 37(1) 146-47
1976
(22t) Dancker, L. Dept. Toxicol. Univ. Uppsala, Acta Pharmacol. Toxicol.
39 (Supp. 1) 1-13, 1976 .
(22c) Konstatintinova, ibid.
(23)

Citizens Against Toxic Sprays, Eugene, Oregon.

(26) Report by the Public Memebers of the California Department of Food and
Agriculture Phenoxy Herbicide Investigation Team, Jan. 14, 1978&gt; Also: Acres.
(27) Dr. Eloise W. Kailan, M.D., Testimony in Citizens Against
USA. Feb/ 1975
Toxic Sprays, ibid.
(28)

Diary of Marion Vertnik, (Diary enclosed)

(29)

Phone conversation with Mr. &amp; Mrs. NefiSie Friedlund

(30) Missoula, Montana, Borrowed Times, February issue.Thomas Whiteside, The
New Yorker, July 25, 1977 (51 spontaneous abortions, or 22 percent)
Phono conversation with Greq Cnrranante

�21.

(30b)

Aaronson, Terri, "A Tour of Vietnam" Environment. XIII No 2
March 1971, 34
&lt;• \
_

Ton That Tung et al. "Le Cancer Primarie du Foie au Viet-nam." Chirurgie,
XLIX, 1973, 427.
Ton That Tung et al. "Clinical Effects of the Massive and Continuous Use
of Defoliants on Civilian Population." Paris: Proceedings of the
Reunion Internationale de scientifiques sur la guerre chimique au Viet
Nam, December 12, 1970.
Ton That Tung. "Clinical Effects of the Use of Herbicides on Civilian Population," Sapere. Vol. 796, 1976, 100.
Ton That Tung et al, "The Effects of Defoliants on Civilian Population."
Chirurqie, XCIX, 1973, 427.
Ton That Tung et al. Vietnam Studies. XIX, No. 53, 1971.

(3.7) Summary of Betty Lou Whaley, Environment Center, 14101 Hilma Circle
Mendocino, California 95460 : Mendocino Grapevine, Oct. 15, 1974
(32) Dr. Granville Knight (study enclosed)
(33)

Sterling, Theodor, Humanist in Canada, February 1976, No. 36, Vol.
IX, No. 1) "Man Against Himself".

(34)

Shoecraft, Billie, Sue the Bastards, Phoenix, Arizona, Franklin,
Arizona 1971
'(35) Phone conversation with Donna Waters, Northern Minnesota Berbicide
Coalition, 110506 Windmill Ct. Chaska, Minnesota 55318
(36) Citizens Against Toxic Sprays, Eugene, Oregon
(37)

Diary of Marion Vertnik, ibid

(38)

Streisinger, George, Assessments of Hazards Posed by TCDD,
Presented a the Symposium on the Use of Herbicides in
Forestry, Arlington, Va. February 21-22, 1978

(39)

Report by the Public Members of the Calif. Dept. of Food and Ag., ibid.

(39a) Council on Environmental Quality, Environmental Quality, 1977
Ei.ghth Annual Report, Wash-i.ngton, D.C.

(41) Reply of Friends of the Earth to Mr. Steve Yurich, EIS
for Eastern Region, Noyamber 4, 1977
(42)

Friends of the Earth, A Look at the Economics of Eliminating
2,4,5-T and Silvex in the Management of National and Pnivate
Forests, April 10, 1978

(43)

Friends of the Earth, The Impact of a Ban on 2,4,5-T and Silvex
on Range and Cattle Economics, May 1, 1978

�22.

(44)

There is literature on the subject by Frank E. Egler, Aton
Forest, Connecticut.

(45)

Friends of the Earth, A Look at the Economics of Eliminating
2,4,5-T from Rice, Interview with Dr. Ford Baldwin, 1978

(46) David Woolsey, Phone conversation
(47)

Phone call by John Stauber
See list of literature in Warnock, John and Jay Lewis et a!., ibid

�FRIENDS OF TI IE EARTH
620 C STREET, S.E., W A S H I N G T O N , D. C. 20003
(202)543-4313
DAVID BKOWEK, President

Incidents Involving ^65 People in 8 States

HUMAN HEALTH EFFECTS REPORTED FROM THE FIELD
AS A RESULT OF EXPOSURES TO 2,^,5-T SPRAY DRIFT
and EXPOSURE TO OTHER HERBICIDES CONTAINING
TCDD DIOXTN

Prepared by Erik Jansson
Research Associate
May 26, 1978

/2

�Table of Contents
SUMMARYi Human Health Effects Reported from the Field
as:a Result of Exposure to 2,4,5-T Spary Drift...
Testimony of Eloise W. Kailan, M.D. Oregon
Letter from Citizens Against Toxic Sprays, Oregon
Letter from Gladys Pavel of Beaver, Washington
(Description of the change in ecology and people
between 196? and 19??)
Affadavit from Coos Bay, Oregon
(Blood samples and water tap samples)
Affadavit from Oregon Rancher
(Presently suing for damages)
Court Affadavits from Citizens Against Toxic Sprays vs
Secretary But2
(Blood samples, soil samples, water supply samples
and health impacts resulting)
Interview with Robbie Pardue, Little Rock, Arkansas
Affadavits from Arkansas
(Loss of vegetation and hospitalization)
Interview with Mr. and Mrs. Freedlund, Wisconsin
2,^-D Levels Found in Snowshoe Hares and Least Chipmunks
in National Forests of Northern Minnesota
Hazards to Endangered Species of Plants, Letter from
Thomas Morley, U, of Minnesota
The Diary of Marion Vertnik, Britt, Minnesota, 1975
(What happened when ^ families were sprayed,1 Information
on other spray drift problems in Minnesota)
House to House Survey of Health Effects in Globe, Arizona
Two Years After Spray with 2,^-,5-T and 2/1—D by Adelaide Frick
Affadavits from Miranda, California
(Including liver enzyme measurements by Dr. Tessler)
Court Affadavits from Korbel, California
(Including testimony of Dr. Humphry-about birth defect)
Testimony of Dr. Granville Knight from Citizens Against
Toxic Sprays vs. Secretary Butz
Interview with Woman and Couple Sprayed in Kermit, West Virginia
Sworn Testimony of Kathleen O'Hagan from Kermit, West Virginia

�SUMMARY OF FINDINGS

In reviewing state by state the illness that resulted from
spray drift from 2,4-,5-T and similar herbicides, several
conclusions became clean
(1)

It is imp^ssjyxLe to avoid spray drift if aerial
application is used.

i
(2) Hospitalizations and deaths occurred in some cases
due to the spray drift.
(3) But, the mp_sj__striking effect was induced spontaneous
abortions and stillborn children. 2,'4-,5-T and the
pesticides containing TCDD appear to be very efficient
in producing stillborn children or spontaneous
abortions.
Of the 23 women who testified that herbicides containing
TCDD dioxin contacted their skin, or polluted their
water supply or gardens» 16 lost their children.
This is a 2Q._J^rcent loss of child.
6 out of 8 lost their babies in Fayetteville, Arkan:
^ out of 9 lost their babies in Oregon,
1 out of 1 lost their babies in Britt, Minnesota.
An estimated 5 out of 5 lost their babies in
northern Wisconsin.
In the laboratory 2,^,5-T and its dioxin contaminant
have been shown to reduce the capacity of animals
to resist infection by damaging the thymus. In
California, Dr. Granville Knight found that ?0 percent
of his patients who were struck by a virus epidemic
had measurable levels of herbicides in their blood,
suggesting a similar effect for humans.

The labels of 2^-1-,5-T and many herbicides prohibit spray
drift. Yet, the Environmental Protection Agency has refused
to prohibit the use of aerial spray for these herbicides,
even though there is substantial scientific evidence that
spray drift is inevitable in even mild winds if aerial
application is used.
It is quite clear that the Environmental Protection Agency
is permitting unlawful use of the herbicides. The result
has been this epidemic of severe health effects.
At Rodway, California, spray during an air pollution inversion
in 19??' produced 2,^,5-T air pollution.

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°5774

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Author
Corporate Author
ROpOrt/ArtlClB TltlB Correspondence Regarding Assignment of Alvin L.
Young to the Veterans Administration for a Two-Year
Term, February 26, 1981

Journal/Book Title
Year
Month/Day
Color
Number of Images

u

°

Descriptor] Notes

Thursday, March 28, 2002

Page 5774 of 5780

�Veterans
Administration

Memorandum
TO:

Date:

February 26, 1981

Chief Medical Director (10
Assignment of Alvin L. Young,
Major, USAF, to Office of
Environmental Medicine

1. The purpose of this memorandum is to solicit your approval and
support of a request that the Air Force assign Major Alvin L. Young
to the Office of Environmental Medicine for a period of
approximately two years following completion of his current
assignment in July of this year. Major Young has frequently voiced
his personal desire to work with the Veterans Administration on the
Agent Orange program. The recent reversal of the plan to assign
Major Young to the U.S. Air Force Academy has made his detail to
this office a very real possibility which in my opinion would be of
great benefit to the VA.
2. Major Young holds a PhD in Herbicide Physiology, and has been
intimately associated with the Agent Orange program for the past
twelve years. He is a recognized expert on dioxins and the phenoxy
herbicides and has published two books on the subject. Of
particular interest is his involvement in the development of the
protocol for the Air Force Ranch Hand Study.
3. It is my belief that Major Young's assignment to this office
would materially enhance the performance of our mission in the
following areas:
a. Provide additional expert guidance in the conduct of the
literature analysis mandated by P.L. 96-151.
b. Help with managing the contract for the design of the
epidemiological study mandated by P.L. 96-151.
c. Aid in maintaining close liaison with the Air Force's
conduct of the Ranch Hand Study.
d. Provide an additional ib-house source of expertise in a
number of areas related to the whole agent orange issue.

VA FORM 2105
MAR I960

�2.

Chief Medical Director (10)
4. Major Young has stated to me his strong conviction that an
assignment to the Office of Environmental Medicine would give him
great personal and professional satisfaction and that it would have
considerable potential for the enhancement of his military career.
In addition, he has told me that he has received informal
assurances of support from his present commanding officer as well
as the Office of the Air Force Surgeon General.
5. In the event that he is assigned to usr it would be most
beneficial to Major Young to be assigned for administrative
purposes to the Air Force Surgeon General. This would provide
eligibility for housing and other benefits at Boiling Air Force
Base.
6. Attached is a proposed letter from you to General Myers and a
second letter from the Administrator to the Secretary of Defense
soliciting their support for this initiative. Major Young's orders
to the Air Force Academy have recently been cancelled and since he
is a line officer he is potentially available for a wide variety of
assignments. Therfore, provided you agree with my proposal, it
would be desirable to act expeditiously in this matter.

BARCLAY M. SHEPJ^RD, M.D.

Special Assistant to the
Chief Medical Director for
Environmental Medicine (102)
Attachments

�Department of Medicine
and Surgery

Washington, D.C.J 20420

Veterans
Administration

I.t. Gen. Paul W. Myers, USAF, MC
Surgeon General
United States Air Force
Boiling AFB, D.C. 20332
Dear Paul:
This will confirm my telephone conversation with
General Chesney and our mutual agreement supporting the
request to have Major Alvin Young assigned to our Office of
Environmental Medicine for a period of approximately two
years to help with our Agent Orange program. In addition
we have agreed that the Veterans Administration will
reimburse the Air Force for his salary. Dr. Barclay M.
Shepard who coordinates our Agent Orange activities assures
me that Major Young, whose assignment to the Air Force
Academy has been deferred, would very much like a 2-year
"hitch" with us, since it would keep him in his area of
greatest interest and expertise. We in turn would be very
pleased to have him join us.
Major Young has been very helpful to us on a number of
projects in the past, including his work on our recently
released film on Agent Orange and his participation in
several VA meetings and conferences. For these efforts we
are most grateful to him as well as the Air Force for
permitting him to take part in these activities.
I have asked the Administrator to forward a similar
request to the Secretary of Defense, enlisting his support
for this assignment.
Since you concur, it would be beneficial to Major Young if
he could be attached to your office for administrative
purposes, so that he might be eligible for base housing at
Boiling. Thank you very much for your help in this
matter.
Sincerely,

DONALD L. CUSTIS, M.D.
Chief Medical Director
In Reply Refer To:

102

�Office of the
Administrator
of Veterans Affairs

Washington, D.C. 20420

Veterans
Administration

Honorable Caspar W. Weinberger
Secretary of Defense
Pentagon - Room 3E880
3E88
Washington, D.C. 20301

%i^Tk^t^l

\ ftst* /
**•- 4DMlt -^
*
"

Dear Mr. Secretary:
The Agent Orange issue remains a major concern to many
Vietnam veterans and therefore, to this agency. The
Veterans Administration is proceeding to carry out the
mandate of P.L. 96-151 which requires us to conduct a
long-range epidemiological study of veterans exposed to
phenoxy herbicides and a review and analysis of the
world's literature on these chemical agents. The
successful completion of these efforts will require the
specialized knowledge and skills of those individuals most
familiar with the many aspects of this complex issue.
It has been brought to my attention that one of the most
widely recognized experts in the use of herbicides by the
Department of Defense is Major Alvin L. Young, USAF.
Major Young, who holds a Ph.D. in Herbicide Physiology,
has been intimately associated with the Agent Orange
program for the past twelve years and has been the
principal author of two major publications on the
subject.
In view of these considerations and the fact that he will
soon complete his present assignment at Maxwell Air Force
Base, I would very much appreciate your support in
requesting that Major Young be assigned for a period of
approximately two years to the VA's Office of
Environmental Medicine which serves as this agency's focal
point for coordination of Agent Orange activities. During
the past two years Major Young has worked closely with
several members of our staff on a number of Agent Orange
related projects and for this we are most grateful to him
and to the Air Force. He is familiar with our
organizational structure and interagency activities, and
he has developed many contacts with the scientific
community both inside and outside the federal government.

�2.

Secretary of Defense
Major Young's assignment to the Veterans Administration
would, I believe, prove to be mutually beneficial in that
he could serve as an additional point of contact in this
agency for Air Force personnel involved in the conduct of
the Ranch Hand Study with which he has had considerable
personal experience. The VA views this study as probably
the most significant research effort currently underway
in the search for answers to many of the questions related
to the possible health effects of exposure to Agent
Orange.
I am most grateful for all the help which the Air Force
and other elements of the Department of Defense have
provided to this agency and I look forward to our
continued cooperation in our efforts to arrive at a more
complete understanding of the many facets of the Agent
Orange issue.
Sincerely,

RUFUS H. WILSON
Acting Administrator
cc:

J. H. Moxley, III, M.D.
Assistant Secretary of Defense
for Health Affairs

Berne Orr
Secretary of the Air Force
Lt. Gen. Paul W. Myers
Surgeon General, USAF

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Author
Corporate Author
Report/Article TltlB Correspondence regarding Centers for Disease Control
(CDC) Agent Orange Study between Office of
Technology Assessment, United States Senate,
Veterans Administration, Department of health and
Human Services, dated September to Decmber 1985

Journal/Book Title
Year

1985

Month/Day
Color
Number of Images

D

1S

Alvin L Young filed these documents together with others in
a folder labelled, "Agent Orange Working Group Science
Panel, Current Folder."

Monday, March 25, 2002

Page 5649 of 5720

�*
. ..

TECHNOLOGY ASSESSMENT BOARD
st!0 STEVENS,

ALASKA. CHAIRMAN

of t&amp;e tHmteb
OFFICE OF TECHNOLOGY ASSESSMENT

\
MORRIS K. UDALL, ARIZONA, VICE CHAIRMAN
GEORGE E, BROWN, J*., CALIFORNIA
UHRIN G. HATCH. UTAH
JOHN D. DINGELL, MICHIGAN
CHARLES McC. MATHIAS, J»., MARYLAND
EDWARD M. KENNEDY, MASSACHUSETTS
CLARENCE E. MILLER, OHIO
ERNEST f. HOLLINGS, SOUTH CAROLINA
COOPER EVANS, IOWA
DON SUNDQUIST. TENNESSEE
CLAIBONNE PELL HHOOE ISLAND
JOHN H. GIBBONS

The Honorable Jake Garn
Chairman
' Subcommittee on HUD-Independent
}
Agencies
_x'
Committee on Appropriations,-:"""""
i
United States Senate. -"""
^..Washington, D.C. 20510

JOHN H. GIBBONS
DIRECTOR

WASHINGTON, DC 20510

September 23, 1985

RECEIVED SE? 3 0 ^

Dear Jake:
I am writing to inform you about recent developments in the Centers for
Disease Control (CDC) Agent Orange Study. In March, OTA reviewed the method
by which the CDC proposed to assign relative exposure ratings to participants
in the Agent Orange Study. OTA was critical of the method, which relied on
classifying each man according to a location assigned to his battalion, a
single point that would be used to represent about 1,000 men on any given day.
This method differed from CDC's earlier plan, which was to rely on the
location of the man's company, representing about 200 men. The battalion
approach produces a less precise estimator of an individual soldier's location
than would a company-level approach. According to CDC, the change to the
battalion approach was necessitated because records of company locations were
not available for enough companies on a large enough number of days during the
study period. In discussions with the U.S. Army Environmental Support Group
(ESG), the group that is abstracting location information from the military
records for CDC, OTA staff learned that the ESG believed they could provide
company locations. The Staff Memorandum included with my April letter to you
states:
If there are no improvements, OTA may decide that the
problems of deciding on exposure are so overwhelming
that It is impossible to study the possible effects of
Agent Orange.
Since April, the CDC researchers have been working toward a method for
assessing exposure based on company locations. We understand they have made
substantial progress and they expect to supply OTA a revised plan in October.
After we receive that plan, we will hold a meeting of the OTA Agent Orange
Advisory Panel and will report our findings to you. Our critique will
probably come to you in late November or in December.
1
i
ESG has already begun '"qualifying" men for the Agent Orange study, and
has begun supplying CDC with names of potential participants. CDC plans to
begin interviews for the Agent Orange study in January 1986. Undoubtedly,
this will be before the details of the exposure assessment method are worked
out. Since exposure scores do not affect the selection of participants for
the Agent Orange study, that schedule should not cause any difficulties if a
suitable method for exposure assessment is devised.

�Without having seen CDC's revised method, OTA does not know if the
proposal will be complete enough that a judgment can be made that it will or
will not work, or if the proposal will need reworking before a decision can be
made . Nevertheless , a final decision about the adequacy of the exposure index
must be made before very many interviews and examinations are completed.
Otherwise a mindset may develop that the study is too far along to be called
back. OTA realizes that a decision not to go ahead with the Agent Orange
study or to stop it would be a drastic step, but unless the exposure
assessment is much improved, that course may be recommended. Whatever
difficulties might flow from such steps would be minor compared to completing
a study that lacks solid estimates of exposure.
Everyone involved with the Agent Orange study has known since the
earliest days that a reliable measure of exposure is the key to a valid study.
There has always been uncertainty about whether such a measure could be
developed, not because of any inadequacies in the researchers struggling with
the question, but because the information simply may not exist to construct a
valid ..exposure index.
I will keep you- informed of any significant progress in the Agent
Orange study and will report specifically on CDC's October document describing
their, method for assessing Agent Orange exposure.
Sincerely,

Johr/ E

Gibbons

�VA OFFICE

REPORT OF CONTACT

IDENTIFICATION NOS 1C, XC, SS,
V, K, etc.)

XSS,

NOTE: This form must be fitted out in ink or on typewriter,
as it becomes a permanent record in veterans' folders.
LAST NAME—MUST NAME—MIDDLE NAME Of VETERAN (Typt tr print)

DATE OF CONTACT

Oct.

REISS, Marty

23,

1985

TELEPHONE NO. OF VETERAN

ADDRESS OF VETERAN

Senate Appropriations Subcommittee
PERSON CONTACTED

224-7284
TYPE OF CONTACT (Chick)

SEVERN, Karen S.

I—I PERSONAL 4J TELEPHONE
TELEPHONE NO. OF PERSON CONTACTED

ADDRESS OF PERSON CONTACTED

Budget Service (041A)

389-3464

MIEF STATEMENT OF INFORMATION REQUESTED AND GIVEN

SUBJ: DM&amp;S - October 11 Report of Contact (copy attached)
A. How does DM&amp;S put its personnel Budget together?
1. Marty still wants information.
2. Still wants to meet with DM&amp;S/Budget Service to discuss.
3. Wants it soon.
B. Repeat a breakout of JI196 million reduction similar to the
Budget Service chart for 5296 million reduction.
Two versions:

a) What the Controller's Office thinks.
b) What DM&amp;S thinks.

C. Where is the CDC Study?
We've given all this money?
Where are we?
What are we expecting?
Is the design adequate to get reliable data?
Office of Technology and Assessment in a letter to Senator Garn,
expressed concern that the design of the survey will not give the
data we are seeking.

DISTRIBUTION;
001
10
10R
04
041
041A
J041F

Budget Service
VA FORM
JUL 1977

119

(041)

EXISTING STOCKS OF VA FORM 119,
JUL 1S74 WILL U USED-

�Meeting on Status of Epidemiology Study
Held at Request of HvAC Congressional Staff
On October 30, 1985, a meeting relating to the conduct of the Epidemiology Study
by the Centers for Disease Control (CDC) was called and chaired by Mr. Jack
McDone.U (HVAC). The meeting was held in the HVAC hearing room, the Cannon
House Office Building. A list of the attendees is attached.
Opening comments were made by Mr. McDonell who stressed the importance of the
Epidemiology Study, and its ultimate successful conclusion, to Vietnam veterans
and their families and to various members of Congress. Mr. Jonathan Steinberg
(SVAC) addressed the attendees making a strong statement stressing the
importance of the study, pointing out that on this issue, that is, the
successful conduct and conclusion of the study, the credibility of the Congress
and the executive branch was at stake. He stated further that the study must be
conducted on a sound scientific basis such that it would withstand peer review
and be completed in a timely fashion. However, the "worst soenerio" would be to
complete the study and then have it discredited because of technical or
scientific flaws.
CDC representatives were asked to describe the status of the methodology whereby
study subjects would be selected based on exposure or non-exposure to Agent
Orange. Dr. Vernon Houk, CDC, briefly discussed the background and history of
events leading up to the present. He also described the status of the Vietnam
Experience Study, one of the three components comprising the total Epidemiology
Study. This phase of the study is scheduled for completion in 1987.
Dr. Peter Layde, CDC, elaborated on some of the concerns and problems related to
the development of an exposure index. Mr. Dan McGee, CDC, discussed in more
detail the consequences of misclassification of study subjects with regard to
exposure.
Mr. Richard Christian, Director of the Army's Environmental Support Group (ESG)
and members of his staff responded to comments made by CDC concerning the status
of the study, particularly with regard to the development of an exposure index.
Mr. Christian indicated that the ESG had not approved CDC's proposed index nor
had the ESG been given adequate time to review that part of the methodology
provided by CDC. He rebutted CDC's claim that the ESG had not provided CDC with
all of the documents they required for the conduct of the study.
CDC admitted that they have not yet completed their work in developing a useable
exposure index. Part of the delay, according to the CDC representatives, was
due to the difficulties in establishing an internal validation process. Another
cause of delay was OTA's rejection of their attempts to set up a mathematical
computer model based on the "centroid" concept. This was a theoretical model
developed by CDC to establish locations of troop units. .The reason for its
rejection was that it did not accurately reflect actual troop locations based on
available operational-records.

�- 2-

Tie misting concluded with comments by Mr. Steinberg who strongly urged CDC and
the EtxJ to meet as soon as possible for the purpose of developing a workable
•?:qx&gt;s;.jr:e index so that the study can proceed on schedule. He pointed out that
h.-' hoped that such a methodology would be in place before the physical
ex.-jnufvit-.ions scheduled to begin in January 1986 are initiated. Both CDC and
i; ie !.'*". agreed to this cooperative endeavor. Mr. Steinberg's final comments
included the observation, that in his judgement, constitutionality questions not
withstanding, the OTA would be regarded by the Congress as the body responsible
i:or determining the scientific validity of the exposure index to be used Cor the
conduct of the study.

UBARCLAY V. SSiEPARD, M.I
Director, Agent Orange Projects Office (10X2)
13, 1985

�Cannon House Office Building Meeting
of
October 30, 1985
AttendeesSVAC Staff

ESG (US Army)

Mr. Tony
••'.f. Jonathan Steinberg
Mr. 3i II Brew

Mr. Richard Christian
Mr. Doug Clark
Major Tenberg (US Anry)
Mr. Dan Hakeason

HVAC St
DHHS Staff
Mr.
Mr.
'•'r.
Mr.
Mr.

Jack vicDonell
Mac F lemming
Pat Ryan
Vic Raymond
Dick Fuller
Dean
fi.

Dr. Carl Keller
Dr. Peter Beach
OTA Staff
Dr. Michael Gough
Ms. Helen Gelband

!&gt;r. Vornon Houk
Dr. Pater Layde
IV. Han McGee

W Staff
Dr. Barclay M. Shepard

�Date:

Veterans
Administration
NOV 131985

Memorandum

From

Director, Agent Orange Projects Office (10X2)

,Sul&gt;i

VA Policy Relative to Communication with Centers for Disease
Control (CDC) on Conduct of Epidemiology Study
Chief Medical Director (10)
THRU: ACMD for Programs, Planning and Policy Development
1. Recent developments relating to the conduct of the Epidemiology Study on the
Health Status of Vietnam Veterans by the Centers for Disease Control (CDC) have
shown that there is a serious breakdown in communication between the Veterans
Administration (VA) and CDC on the conduct of that study. These developments
include the creation and submission by CDC of a proposed exposure index for
review by the Office of Technology Assessment (OTA) and the award by CDC in
mid-September 1985, of a contract to the National Academy of Sciences Institute
of Medicine to monitor the Epidemiology Study and review and evaluate the
methodology for an Agent Orange exposure index. Although the CDC provides
quarterly status reports to the VA on their Epidemiology Study research
activities, neither of these events were reflected in these reports, nor were
they the subject of open discussions with the VA or in meetings of the Agent
Orange Working Group (AOWG). We became aware of them only after being informed
about them by sources external to this agency.
2. The two events described above were the subject of a meeting held at the
Cannon House Office Building on October 30, 1985. This meeting, called at the
request of the House Veterans Affairs Committee Staff, was attended by key
congressional staff including Mr. Jack McDonald (HVAC) who chaired the meeting,
Mr. Jonathan Steinberg (SVAC), CDC representatives, Army Environmental Support
Group (ESG) staff, OTA representatives, other DHHS staff and myself. The lack
of progress by CDC in developing a useable exposure index and the award of the
NAS contract were obviously of great concern to Mr. McDonald and Mr. Steinberg
who emphasized the importance attached by a number of other key congressional
staff in both the House and Senate to the successful conduct of the study. This
meeting concluded with an agreement for CDC and the ESG to resolve the matter of
developing an exposure index methodology prior to the initiation of physical
examinations of the Epidemiology Study participants in January 1986.
3. It should be noted that the VA will be submitting, on or before February 15,
1986, the first status report on the Epidemiology Study to the appropriate
congressional conroittees. This report is mandated by Public Law 96-151 enacted
December 20, 1979. Although CDC is responsible for the preparation of this
report, the VA remains the agency mandated by law to transmit that report to
Congress with any recommendations the Administrator of Veterans Affairs deems
appropriate. As shown, the VA cannot rely solely on the quarterly status

VAFORM
SEP 1984

�- 2-

reports submitted to us by CDC to remain abreast of such significant
developments/ activities which may bear heavily on any recommendations or
observations which will be included in the letter transmitting the first
mandated report to Congress.
4. Accordingly, I recomnend that:
(1) The VA more actively follow the CDC's conduct of the Epidemiology
Study without in any way advising or assisting the CDC in the design or
conduct of that study and
(2) The attached letter to the Acting Assisting Secretary for Health, DHHS,
be sent as evidence of CDC's failure to keep the VA fully informed of the
difficulties encountered in the study's design and conduct. In pursuing
the first recommendation, quarterly meetings would be held between staff
of the VA's Agent Orange Projects Office and appropriate CDC officials to
discuss the content and implications of that agency's quarterly status
reports.
5. Your review and approval of the above recommendations is appreciated.

-BARCLAY M. SHEPARD, M.D.
Attachment
AGSEE

W. DITZLER, M.D.
ef Medical Director

DISAGREE
V

�DEC. 51985

:- ,"f-

;

-"

James 0. Hasan, K.D. , Dr. P.B.

Acting Assistant Secretary tor Health
Department of Health and Human Services
f&amp;shington, D.C. 20201
"^

»

Dear Dr. Masai:
The January 1903 interagency egreenent between the Veterans Administration
(VA) and the Centers for Disease Control (CDC), relative to the conduct of
the Epideeaiology Study of the Health Status of Vietnam Veterans, provides
for the preparation by CDC of « quarterly status report to the VA on the
conduct of that study. These reports are of great assistance to the V?k in
responding to f recruent inquiries from many sources regarding the progress of
the study.
Recently, the VA became aware through external sources of a significant
development not mentioned in any of the quarterly reports received to date
by the VA. The development concerned the creation and submission by CIXT of
a proposed exposure index for review by the Office of ^technology Assessment
(OTA). Vte have learned, again from sources other than CDC, that the OXA
review found this exposure index methodology to be unsatisfactory. The lack
of progress by CDC in developing an exposure index has never been raentioned
in any of the quarterly status reports received by this agency.
Additionally , to the best of our knowledge* this fact was never cornxunicated
in discussions with the VA or in meetings of the ^ent Orange Marking Group
The purpose of the quarterly status renorts, es originally envisioned during
the development of the interagency sareatasnt, was not only to provide a full
report on CDC's progress on the conduct of the Epidemiology Study , but also,
to tdert the VA to any real or potential problem encountered by CDC which
might irpact on thrt study's progress and eventual successful conpletion.
Ar&gt; you will appreciate, unanticipated difficulties in t*»e research can
effect its ultfcrsf? outcome and tbe manner in v.-hich it will be perceived by
veterans. I 'an sure that you will agree that tho future inclusion of such
significant developments vi-11 assist both the VA and CDC in fulf illing our
respective aoency responsibilities as they relate to this sssjor study. It
wquld be very beneficial to the VA tor the appropriate CDC officials to
provide &amp; briefing on the content anc implications of tine status reports to
Dr. Barclay H. Shepard, Director, Aqent Orange F-rojects Office and raembers

�2.

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Dr. James O. Mason
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of his staff iwwdlstely following the 8uimi«rion of the rtoor-t to that
office. Accordinqly, 1 roquest your consideration «nd approval tor this
activity tor ell future reports.
I appreciate your assistance 4.n this natter,
Sincerely,

JOBS VI. DITZLER, K.t&gt;.
Chief ftedical Director
cc:

02C
101B11

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11/1/85

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Purposes 1b alert the Centers for Disease Control (CDC) of need to keep VA
fully briefed on significant developments related to conduct of the
Epidemiology Study of Health Status of Vietnam Veterans,
General: CMD advises the Acting Assistant Secretary for Health, DHHS, that
VA has become aware of a significant development related to the conduct of
the Epidemiology not reported in CDC's quarterly status report to this
agency or in open discussions. Particularly cited by the CMD is the
development and submission by CDC of a proposed exposure index for Office of
Technology Assessment review and its ultimate disapproval. The CMD requests
that the appropriate CDC officials brief the Director, Agent Orange Projects
Office and members of his staff on the content and implications of the
information contained in all future status reports to that office.
The CMD reminds CDC of the need for full and complete information to assist
the VA in responding to frequent inquiries from many sources concerning the
status of the study. He states that he believes such information will
assist both the VA and CDC in successfully completing their respective
missions.
iTTplicatiojnst It is essential that CDC keep the VA fully briefed on
developments. The first congressionally mandated report to Congress is due
February 15, 1986.,
ReconTOendatioaTS; Approve and dispatch

�Congre** of tfje tUntteb fetate*

TECHNOLOGY ASSESSMENT BOARD
vteo srevcNS. ALASKA. CHAIRMAN

OFFICE OF TECHNOLOGY ASSESSMENT

i*9WMS K. UOAU. ARIZONA. VICt CHAmMAN

WASHINGTON, OC 2O5 10

M C WAtCH. UTAH
•US Met MATWAS. J- MARTLANO
(OMTAKO M. KCNNEOr. MASSACHUSCrTS

GEOftGl I (IIOWN, *, CALIf OKNIA
JOHN O OIHGCU. MICHlCAN
CLAIUNCt (. MULCH. OHIO

CIUIEST f, HQLLWGS, SOUTH CAROLINA

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COOPER EVANS, IOWA

CUISORNC flLL. «HOO( ISLAND

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DON SUWOOUtit. TENNESSEE

JOHN H GIBBONS
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OK 19 JS85

D i r e c tor
Asst Directors
T.McGurn
CPA
Health (2)

The Honorable Patrick J. Leahy
Ranking M i n o r i t y Member
Subcommittee on HUD-Independent
Agencies
Committee on Appropriations
United States Senate
Washington, D.C. 20510
Dear Senator Leahy:
I am writing to inform you about OTA's continuing review of progress in
the mandated Agent Orange study being carried out by the Centers for Disease
Control (CDC). The item of greatest concern has been the lack of a method for
assessing exposure to Agent Orange among study subjects. We last addressed
this issue in March 1985, at which time we expressed serious doubt to you
about the exposure assessment method CDC had proposed in a February report to
OTA. In September, I wrote to you expressing, concern that, although CDC's
timetable called for interviewing Agent Orange study subjects beginning in
January 1986, a revised exposure assessment method had yet to be produced.
On November 18, we received a report from CDC titled "Exposure
Assessment for the Agent Orange Study, Interim Report Number 2." We had by
then arranged to have the OTA Agent Orange Advisory Panel meet on December 14
to review CDC's report. Based on our reading of the November 18 report, OTA
staff requested some additional information from CDC, without which it would
have been impossible for the Advisory Panel to adequately evaluate the
exposure assessment method. On December 9, we received another report, dated
December 8, which contained much of the information that had been requested.
A final packet from CDC, containing specific information requested by OTA
on December:—13":—The—Advisory—PaTte^r-med—Ehe—-f-o^-ow-tttg—day-;
Their advice to OTA is reflected in this letter.
In sura, the recent reports from CDC outline an Agent Orange study of
radically different design than the one that was initially reviewed and
approved by OTA. The changes in design are of sufficient "magnitude to require
interruption of any plans for initiating interviews or examinations of study
subjects.
Further, the plan still appears to be in a state of change. While
all or some of the changes proposed by CDC may be necessitated by relatively
new information about troop locations and eligibility of men as study ,___.
subjects, the reasons for the changes have not been coherently or convincingly
presented in any of the reports OTA has received from CDC.
When the original Agent Orange study design was approved by OTA, there
were still many unanswered questions, and uncertainties which only would be
resolvable when representative data from the military records had been
assembled. There now exists a body of data which, while not complete, gives
an indication of what the records contain. CDC should now be able to make
some final decisions about study design and about the quality of the exposure

�data on which the study results will be based. OTA| therefore, requests a new
statement of study design, incorporating, as necessary, new plans for exposure
assessment, a plan for selecting study subjects, and new plans for data
analysis. The discussion of exposure assessment should contain an explicit
analysis of the probability of misclassification within the "likely to have
been exposed" group. Finally, there should be discussion about whether the
range of exposures likely to be found among the study subjects forms a firm
underpinning for the proposed study. As CDC stated in its original protocol
of November 1983, "Since many of the proposed procedures are untested,
modification, indeed even a recommendation not to proceed with an Agent Orange
study, may be required after pilot study assessments." The data collected to
date should serve as an adequate pilot test of the methods and representation
of results of exposure assessment.
At the same time that the new study protocol has been evolving, the
study has faced a severe managerial problem. This problem, which seems
soluble, is one of collaboration, of CDC and the Environmental Support Group
(ESG). Steps should be taken to insure that this problem is resolved
expeditiously. The Agent Orange Working Group Science Panel may be the
appropriate body to catalyze discussion between the two groups. If other
military experts are required as consultants, they should be brought into the
process, with a clear statement of theirrroles, while it is not appropriate
for OTA to moderate the dispute, we can evaluate the resolution.
It is
important that formal work statements for data abstraction from military
records and for assessing data quality be agreed upon,jointly by CDC and ESG.
OTA would like to be provided copies of these work statements when agreement
has been reached.
I am sending copies of this letter to both CDC and ESG. OTA staff
currently are.writing a detailed set of comments which addtess the issues
raised in this letter. Copies of those comments" will be sent to CDC and ESG,
and to the appropriate Congressional committee staff dealing with Agent Orange
issues.
If OTA is to consider the revised Agent Orange study protocol for
approval, another review will be necessary. Our Agent Orange Advisory Panel
is prepared to meet again in early 1986.
I believe that sometime in March or
April is a realistic expectation for that meeting. In our view, no major new
phase of the study should be undertaken before the new design and exposure
assessment method are found acceptable and the managerial problems resolved.
If you would like further discussion on this matter please do not
hesitate to call me at 4-3695. or Hellen Gelband of the OTA staff at 6-2070.

Sincerely,

John H. Gibbons

�The Honorable Patrick J. Leahy
Ranking Minority Member
Subcommittee on HUD-Independent
Agencies
Committee on Appropriations
United States Senate
Washington, D.C. 20510
Senator Leahy

The Honorable Frank H. Murkowski
Chairman
Committee on Veterans' Affairs
United States Senate
•Washington, D.C. 20510
Mr. Chairman

The Honorable Alan Cranston
Ranking Minority Member
Committee on Veterans' Affairs
United States Senate
Washington, D.C. 20510
Alan

The Honorable Jake Garn
Chairman
Subcommittee on HUD-Independent
Agencies
Committee on Appropriations
United States Senate
Washington, D.C. 20510
Jake

The Honorable G. V. Montgomery
Chairman
Committee on Veterans' Affairs
U.S. House of Representatives
Washington, D.C. 20515
Mr. Chairman

The Honorable John P. Hammerschmidt
Ranking Minority Member
Committee on Veterans' Affairs
U.S. House of Representatives
Washington, D.C. 20515
Congressman Hammerschmidt

�The Honorable Edward P. Boland
Chairman
Subcommittee on HUD;Independent
Agencies
Committee on Appropriations
U.S. House of Representatives
Washington, D.C. 20515
Mr. Chairman

The Honorable Bill Green
Ranking Minority Member
Subcommittee on HUD-Independent
Agencies
'Committee on Appropriations
U.S. House of Representatives
Washington, D.C. 20515
Congressman Green

The Honorable Orrin G. Hatch
Chairman
Committee on Labor and Human Resources
United States Senate
Washington, D.C. 20510
Orrin

The Honorable Edward M. Kennedy
Ranking Minority Member
Committee on Labor and Human Resources
United States Senate
Washington, D.C. 20510
Ted

The Honorable Henry A. Waxman
Chairman
Subcommittee on Health and the Environment
Committee on Energy and Commerce
U.S. House of Representatives
Washington, D.C. 20515
Henry

The Honorable Edward R. Madigan
Ranking Minority Member
Subcommittee on Health and the Environment
Committee on Energy and Commerce
U.S. House of Representatives
Washington, D.C. 20515
Congressman Madigan

�The Honorable William H. Natcher
Chairman
Subcommittee, on Labor, Health
and Human Services, and Education
Committee on Appropriations
U.S. House of Representatives
Washington, D.C. 20515
Mr. Natcher -

The Honorable Silvio 0. Conte
Ranking Minority Member
Subcommittee on Labor, Health
and Human Services, and Education
Committee on Appropriations
U.S. House of Representatives
Washington, D.C. 20515
Congressman Conte

The Honorable Lowell P. Weicker, Jr.
Chairman
Subcommittee on Labor, Health
and Human Services, and Education
Committee on Appropriations
United States Senate
Washington, D.C. 20510
Mr. Chairman

The Honorable William Proxmire
Ranking Minority Member
Subcommittee on Labor, Health
Human Services, and Education
Committee on Appropriations
United States Senate
Washington, D.C. 20510
Senator Proxmire

The Honorable Silvio 0. Conte
Ranking Minority Member
Committee on Appropriations
U.S. House of Representatives
Washington, D.C. 20515
Congressman Conte

The Honorable Jamie L. Whitten
Chairman
Committee on Appropriations
U.S. House of Representatives
Washington, D.C. 20515
Mr. Chairman

�The Honorable John C. S tennis
Ranking Minority Member
Committee on Appropriations
Unite'd States Senate
Washington, D.C. 20510
Senator Stennis

The Honorable Mark 0. Hatfield
Chairman
Committee on Appropriations
United States Senate
Washington, D.C. 20510
Mark

The Honorable John D. Dingell
Chairman
Committee on Energy and Commerce
U.S. House of Representatives
Washington, D.C. 20515
John
-

The Honorable James T. Broyhill
Ranking Minority Member
Committee on Energy and Commerce
U.S. House of Representatives
Washington, D.C. "20515
Congressman Broyhill

The Honorable Harry N. Walters
Administrator
Veterans Administration
810 Vermont Avenue, NW
Washington, D.C. 20402
Harry

�VA OmCE

IDENTIFICATION NOS fC. XC, 8S, XSS.

V, K. tie.)

REPORT OF CONTACT
NOTE: TJili form mutt befitted out In Ink or on typewriter,
as ft becomes a permanent record In vetemnt' folder*.
LAST NAME—FAST NAME— MIDDLE NAMt Of VETERAN (T#t tr frill 1)

DATE Of CONTACT

ADORE it Of VETERAN

TELEPHONE NO. OF VETERAN

PERSON CONTACTED

TYPE OF CONTACT (Cln*)

12/23/85

Kinqston Smith

(_J PERSONAL
UJ TELEPHONE
TELEPHONE NO. OF PClSON CONTACTED

ADDRESS OF PERSON CONTACTED

HVAC
IR1EF STATEMENT OF INFORMATION REQUESTED AND OIVEN

K i n g s t o n Smith, M i n o r i t y S t a f f , House V e t e r a n s ' A f f a i r s
Corrmittee, c a l l e d to d i s c u s s a l e t t e r the Conrmittee had
received
from
the
Office
of
Technology
Assessment
c o n c e r n i n g the p r o g r e s s of the Agent Orange study mandated
by Pub. L. No. 96-151.
The OTA had expressed s e r i o u s
r e s e r v a t i o n s about the approach being taken by the CDC.
They e s p e c i a l l y q u e s t i o n e d the methodology being suggested
f o r d e t e r r m i n i n g t h e e x p o s u r e of study s u b j e c t s . T h i s has been a topic of concern for about three months and was the
s u b j e c t of a meeting held on the Hill at the end of
October.
A t t e n d i n g that meet ing were r e p r e s e n t a t i v e s from
the House and Senate V e t e r a n s A f f a i r s Committees, the
Department of D e f e n s e ' s Envi ronmental Support Group, the
CDC and the VA.
(A copy of a memo surrmarizing t h i s
meeting is attached.)
Mr. Smith s t a t e d that the Agent Orange s t u d y , which he
c h a r a c t e r i z e d a s t h e most p o l i t i c a l l y s e n s i t i v e p a r t o f
t h e e f f o r t , was i n s e r i o u s d i f f i c u l t y . He s t r o n g l y h i n t e d
t h a t h e a r i n g s on the p r o g r e s s of the s t u d y was a d e f i n i t e
p o s s i b i l i t y a n d t h a t i t woul d p r o b a b l y not be a p l e a s a n t
e x p e r i e n c e for the CDC.
I noted that the VA had adopted a
p o s t u r e o f n e u t r a l i t y regarding t h e study f o l l o w i n g
its
transfer
to
CDC at
the
request,
in
part,
of
the
C o m m i t t e e ' s Chairman.
For that r e a s o n , 1 suggested that
the
VA
had
no
comments
to
offer
concerning
this
development.
I did note that t h i s c o n t r o v e r s y did not
- a f f e c t the p r o g r e s s of the Vietnam Experience Study which
is now underway nor the sel ected cancers s t u d y which is
a l s o being conducted by the CDC. Mr. Smith s t a t e d that he
w o u l d f o r w a r d a copy of the OTA l e t t e r to the VA i.n the
next few days.

i* »
EXECUTED IV (Sig**l*ri mm* titU)

DIVISION OH SECTION

Special Assistant to the
General Counsel (02C)
VA FORM . . A
JUL 1877

1 IV

EXISTING STOCKS OF VA FORM 119,
JUI.IB74 WIU &gt;E USED-

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* U.S. GOVERNMENT FftNTINC OFFICE:

ISM-4S 1-488: 1 1710

�</text>
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&lt;p&gt;For more about this collection, &lt;a href="/exhibits/speccoll/exhibits/show/alvin-l--young-collection-on-a"&gt;view the Agent Orange Exhibit.&lt;/a&gt;&lt;/p&gt;</text>
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                <text>1985</text>
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                    <text>Item D Number

05323

D

NotScannBd

Author
Corporate Author
Report/Article Title Correspondence with attachment: Between William E.
Hazeltine, Ph.D. and The Honorable Harold T. (Bizz)
Johnson, Congress of the United States, House of
Representatives, dated May 12, 1980, with bill H.R.
6377, 96th Congress, 2nd Session

Journal/Book Title
Year

198

Month/Day

Ma

Color
Number of Images

°

v

D

7

Descrlpton Notes

Tuesday, March 05, 2002

Page 5323 of 5363

�Z6 Uosiia Way
Oroville, California 95965
May 7,

1980

The Honorable Harold T, ( B l z z ) Johnson
Room 2 3 4 7 , House Office Building
Washington, P. C. 20515

Dear Bizz:
The news last night reported that you were going to carry a
bill to declare that any military veteran of the Vietnam conflict would
be considered as damaged by herbicides used there, unless someone
c on Id prove otherwise.

I hope this was Incorrectly reported, because

it is obvious that such proof ia not possible, and such a precedent
does not seem, reasonable.
If the report is accurate, I wish to voice my disappointment In
' •
f
your decision to provide this authorship. The whole herbicide Issue
la so mixed with the "anti-war - drug producers - back to nature media hype" syndrome that such a declaration by the Congress seems
more aimed at election support than at finding real causes for concern
and compensating for real damages.
I would appreciate a copy of your legislation, and I will reserve
final judgment until I can study it.
Sincerely,

t

WEHjls

William E. Hazeltlne. Ph. D. . U; P. E,

�T. &lt;mzz&gt; JOHN BOM
f *f PuTitior. CAi.ironHiA

PUBLIC WOHK* ANP

^uyujj^V'f

ot
,».C. 20515

May 12, 1980

,26 lloatta W&lt;iy

95965
Pear Or,
In response (;q your letter of May 7. I am plciiaej
enclose a copy of I). K&lt; 637?, the Vletnnm Era Veterans
Oranee Act, which J Joined jn poaponsorvng.
I hope tliat you w^ll feel free to he ill touch with me
If you utlll have concerns after reacting the provisions of the

I
Sincerely youre,.

1IAK01.D T, («I2Z) JOHNSON
Member of Con|;reua
J:P

�DOTH OONdlUU.SS
2D

H. R. 6377

To nmonil lilln 3B, United Stnlcs Code, to provide ft presumption of service
connection (or Ilio occiiroiicp n( certain diseases In vclcrnns who were
exposed tn phenoxy herbicides conlnriiinnlcd by dioxinn.

IN TUB HOUSE OP IlEPllESENTATIVES
go, 1080
Mr. DABCIIII.R Introduced the (ollowing bill; wliicli wnn referred lo Ilio Cominitlco
on Vetornni' AllnirB

A BILL
To amend title 38, United Slates Code, to provide a presumption of service connection for Ilio occurenco of certain discasoa in veterans who were exposed to phcnoxy herbicides
contaminated by dioxins.
1

He it ennctcd by the Senate and House of Reprcsenta-

2 lives of the United Stales of America in Congress assemliled,
3 That this Act may be cited as the "Vietnam Ern. Veterans
4 Agent Orange Act".
f&gt;

SBC. 2. Section 312 of title 38, United States Code, is

.0 amended by adding at the end thereof the following new
•I
'

7 subsection:

�2

1

"(&amp;)(l) For the purposes of section 310 of this title and

2 subject to the provisions of sccliou 813 of this title, in the
3 case of any veteran who served for ninety days or more
4 during the Vietnam era (A) who is suffering from a disease
5 developed to a 10 per centum degree of disability or more
(i that has been determined under paragraph (3)(A) of this sub7 sccliou to be a disease that may bo caused by exposure to
8 phenoxy herbicides contaminated by dioxins, and (14) who
I) during such service was exposed to phenoxy herbicides con10 laminated by dioxins, as determined in accordance with regu11 la I ions prescribed by the Administrator under paragraph
12 (3)(G) of this subsection, such disease shall be considered to
13 have been incurred in or aggravated by such service, not14 withstanding that there is no record of ovidenco of such dis15 ease during the period of service.
Hi

"(2) If l|ie Administrator determines under paragraph

17 (3)(B) of lliis subsection that exposure to phenoxy herbicides
IB contaminated by dioxins may cause birth defects in the naluJi) nil children of persons so exposed, then in the case of any
20 person who—^
21

"(A) is the natural son or daughlcr of a veleran

22

who served for ninety days or more during the Viet-

23

i HI in era and during such service was exposed to phe-

24

noxy herbicides contaminated by dioxins, us dclermined

25

in accordance with regulations prescribed by the Ad-

�8

1

mhnslrator under paragraph (ft)(G) of this subsection;

2

and

3

"(H) is suffering from a bjrth defect llial in an

4

adult is disabling to a degree of 10 per centum or more

5

and that has been ilelci mined by (he Administrator

Q

midcr paragraph (3)(J1) of (Ins subsection to I)" a birth

7

defect, that may be caused by exposure of one of the

8 I

parents of A child (.0 pbcnoxy herbicides contnminaled

0

by dioxins;

10 such person shall be deemed for the purposes of this chapter
11 to be a veteran of a period of Wl»r and such birth defect shall
12 ho deemed fur the purposes of this eliaplcr to be an aggrava191 tion of a preexisting injury suffered ii» lino of duly in the
14 active military, naval, or air service, during a period of war.
15

"(3)(A) The Administrator shall determine, and shall

16 promulgate by regulation, what diseases medical research
17 has shown may he due to exposure to phenoxy herbicides
18 contaminated by dioxins. The Administrator shall include in
19 such regulations a specification of the standards used by the
20 Administrator in making such determination.
21

"(1)) The Administrator shall determine, and shall pro-

22 mtilgalo by regulation, what birth defects, if any, may be
2U mulagcnic birth defects resulting from exposure of the parent
24 of a child lo phciioxy herbicides contaminated by dioxins. The
26 Administrator shall include in such regulations a specification

�4

1 of tlio standards used by the Administrator in making sijch
2 determination.
3

,

"(0) The Administrator shall promulgate by regulation

4 the conditions of service during the Vietnam era required to
5 establish exposure of a veteran to phenoxy, herbicides con.

.

'

'

'''.

'

'

.

'

I

-

i

0 taminatcd by dioxins tor the purposes of paragraphs (1) and
7 (2) of this subsection. Such regulations Inuy not require that, a
8 vcloran be required lo provide any information to the Vcter0 nns" Administration for the purpose of determining such' ex10 posurc beyond the information contained in the veteran's dis11 charge papers and shall establish ii presumption of exposure
12 of a veteran to phctloxy herbicides contaminated by dioxins
13 when Department of Defense records, Information supplied
14 by the veteran, and other information establish a possibility
15 of such exposure. The Administrator shall include in such
10 regulations a specification of the standards used by the Ad17 ministralor in establishing what conditions of service ore re18 quired to establish such exposure to phenoxy herbicides cori10 ta'miriated by dioxins.
20

"(4) Notwithstanding any other provision of law, section

21 5/53 of title 0, relating to agency rutcmaking,. shall apply to.
22 the promulgation of regulations under paragraph (3) of this
23 subsection, and such regulations shall be made on thb record
24 after opportunity for an agency hearing in accordance with
26 sections 550 and 557 of such title. Such regulations shall bo

�5

1 subject to judicial review in accordance with chapter 7 of
2 such title.
8

"(K) The Administrator sltnll complete final agency

4 action on the regulations required to bo promulgated by para-

5 graph (3) of this subsection not later than tho end of the ono6 year period beginning on the date of tho enactment of tho
7 Vietnam Era Veterans Agent Orange Act and shall publish
8 such regulations at the same lime as one set of regulations.".
O

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                <text>Correspondence with attachment: Between William E. Hazeltine, Ph.D. and The Honorable Harold T. (Bizz) Johnson, Congress of the United States, House of Representatives, dated May 12, 1980, with bill H.R. 6377, 96th Congress, 2nd Session</text>
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05502

G Not Scanned

Author
Corporate Author
Report/Article TItlQ Cover Letter, List of Addresses, and Memorandum sent
to Congressional Committees after a meeting of the
Office of Technology Assessment Advisory Panel,
February 28,1985.

Journal/Book Title
Year

000

°

Month/Day
Color

D

Number of Images

°

DeSCrlptOD NOtBS

Memorandum is a Report on the Progress of the Centers For
Disease Control's Studies of the Health of Vietnam Veterans.

Friday, March 15, 2002

Page 5502 of 5571

�TECHNOLOGY ASSESSMENT BOARD

MORRIS K. UDAU. ARIZ., CHAIRMAN
TED STEVENS, ALASKA, VICE CHAIRMAN
GEORGE E. MOWN. Jn.. CALIF.
ORRIN G. HATCH, UTAH
CHARLES McC. MATHIAS, J«.. MO.
EDWARD M. KENNEDY. MASS.
ERNEST F. HOLLINOS, S.C.
CLAIBORNE PELL. R.I.

JOHN O. DINGELL. MICH.
LARRY WINN. J". KANS.
CLARENCE E. MILLER. OHIO
COOPER EVANS. IOWA

Congre** of tfje ®nittb fttate*
OFFICE OF TECHNOLOGY ASSESSMENT
WASHINGTON, D.C. 20510

JOHN H. GIBBONS

1 am e n c l o s i n g a copy of the cover l e t t e r , a i i s t of addresseeSj and
the memorandum that was sent to the appropriate Congressional
Committees after a m e e t i n g of tne OTA advisory panel on Feoruary 28,
1985.
Hi chaei Gough
Acr i i i

JOHN H. GIBBONS
DIRECTOR

�of tfje tHtuteb Stated
TECHNOLOGY ASSESSMENT BOARD

_

T£0

OFFICE OF TECHNOLOGY ASSESSMENT

STEVENS. ALASKA. CHAiRMAN

MORRIS K. UOALL. ARIZONA. VICE CHAIRMAN
ORRIN 0. HATCH. UTAH
CHARLES McC. MATMIAS, J«., MARYLAND
EDWARD M. KENNEDY. MASSACHUSETTS
ERNEST f. HOILINQS. SOUTH CAROLINA
CLAiaORNE PELL, RHODE ISLAND

_

A

_ _ . _„._

JOHN H. GIBBONS
O.RECTOR

WASHINGTON, DC 20510

GEORGE E. BROWN. JK. CALIFORNIA
JOHN 0. DINGELU MICHIGAN
CLARENCE E. MILLER. OHIO
COOPER EVANS. IOWA

JOHN H. GIBBONS

OTA's Agent Orange Advisory Panel met on February 28, 1985,
progress in the Centers for Disease Control's (CDC) studies of the
Vietnam veterans. As discussed in the enclosed memorandum,, CDC is
progress in the conduct of the studies, but OTA draws attention to
that deserve some additional attention:

to discuss
health of
making good
two areas

(1.) A study done in Massachusetts reports a significant excess of
deaths from soft tissue sarcomas among Vietnam veterans. Those cancers are
the ones most frequently associated with exposure to dioxin, although studies
done in different populations and parts of the world have produced conflicting
results. CDC's current plans are to publish the results of a study of soft
tissue sarcomas among veterans in 1990. Because of the interest in those
cancers, OTA suggests that CDC try to increase the number of cancer registries
participating in the soft tissue sarcoma study so that the study can be
completed sooner.
(2.) The major part of the advisory panel meeting and of the enclosed
memo focused on the subject of estimating exposure to Agent Orange. The basic
idea behind estimating exposure is to determine what military units a veteran
served with while in Vietnam, locate the positions (and times) where the units
were stationed in Vietnam, and compare those locations to known uses of Agent
Orange. At the time OTA approved the CDC study plan, it was expected that it
would be possible to locate Army companies. According to a report presented
to OTA by CDC, that had proved impossible. Instead, it was possible only to
locate battalions, which were spread out over areas of scores of kilometers in
Vietnam. As is detailed in our report, OTA questions the usefulness of
exposures estimated with that kind of data. We expect to hold' another meeting
in about six months to see if improvements can be made.

�Following the advisory panel meeting, OTA staff visited the Army
records experts who have information about unit locations in Vietnam and were
told that the Army thought that it is possible to provide data at the company
level. OTA urged that a meeting take place between the Army and CDC to
discuss that possibility. After the meeting was held, OTA received a letter
from CDC stating that efforts are now being made to locate companies. CDC
expects to know by early summer if those efforts are successful.
Sincerely,

John H. Gibbons
Enclosure

�The Honorable Patrick J. Leahy
Ranking Minority Member
Subcommittee on HUD-Independent
Agencies
Committee on Appropriations
United States Senate
Washington, D.C. -20510@
Senator Leahy
The Honorable Frank H. Murkowski
Chairman
Committee on Veterans' Affairs
United States Senate
Washington, D.C. 20510@
Mr. Chairman
The Honorable Alan Cranston
Ranking Minority Member
Committee on Veterans' Affairs
United States Senate
Washington, D.C. 20510@
Alan
The Honorable Jake Garn
Chairman
Subcommittee on HUD-Independent

Agencies
Committee on Appropriations
United States Senate
Washington, D.C. 20510@
Jake
The Honorable G. V. Montgomery
Chairman
Committee on Veterans' Affairs
U.S. House of Representatives
Washington, D.C. 20515@

Mr. Chairman
The Honorable John P. Hammerschmidt
Ranking Minority Member
Committee on Veterans' Affairs
U.S. House of Representatives
Washington, D.C. 20515@
Congressman Hammerschmidt
The Honorable Edward P. Boland
Chairman
Subcommittee on HUD-Independent
Agencies
Committee on Appropriations
U.S. House of Representatives
Washington, D.C. 20515@
Mr. Chairman
The Honorable Bill Green
Ranking Minority Member
Subcommittee on HUD-Independent
Agencies
Committee on Appropriations

�U.S. House of Representatives
Washington, D.C. 20515(§
Congressman Green
The Honorable Orrin G. Hatch
Chairman
Committee on Labor-and Human Resources
United States Senate
Washington, D.C. 20510@

Orrin
The Honorable Edward M. Kennedy
Ranking Minority Member
Committee on Labor and Human Resources
United States Senate
Washington, D.C. 2051&lt;X§
Ted

The Honorable Henry A. Waxman
Chairman
Subcommittee on Health and the Environment
Committee on Energy and Commerce
U.S. House of Representatives
Washington, D.C. 20515@
Henry
The Honorable Edward R. Madigan
Ranking Minority Member
Subcommittee on Health and the Environment
Committee on Energy and Commerce
U.S. House of Representatives
Washington, D.C. 20515@

Congressman Madigan
The Honorable William Natcher

Chairman
Subcommittee on Labor - Health
and Human Services - Education
Committee on Appropriations
U.S. House of Representatives
Washington, D.C. 20515@
Congressman Natcher
The Honorable Silvio 0. Conte
Ranking Minority Member
Subcommittee on Labor - Health
and Human Services - Education
Committee on Appropriations
U.S. House of Representatives
Washington, D.C. 20515@
Congressman Conte
The Honorable Lowell P. Weicker, Jr.

Chairman
Subcommittee on Labor, HHS, Education
and Related Agencies
Committee on Appropriations
United States Senate
Washington, D.C. 20510@
Senator Weicker

�The Honorable William Proxmire
Ranking Minority Member
Subcommittee on Labor, HHS, Education
and Related Agencies
Committee on Appropriations
United States Senate
Washington, D.C. 20510@
Senator Proxmire
The Honorable Silvio 0. Conte
Ranking Minority Member
Committee on Appropriations
U.S. House of Representatives
Washington, D.C. 20515@
Congressman Conte
The Honorable Jamie L. Whitten
Chairman
Committee on Appropriations
U.S. House of Representatives
Washington, D.C. 20515@
Mr. Chairman
The Honorable John C. Stennis
Ranking Minority Member
Committee on Appropriations
United States Senate
Washington, D.C. 20510@
Senator Stennis
The Honorable Mark 0. Hatfield
Chairman
Committee on Appropriations
United States Senate
Washington, D.C. 20510&lt;a
Mark
The Honorable John D. Dingell

Chairman
Committee on Energy and Commerce
U.S. House of Representatives

Washington, D.C.
John

20515@

The Honorable James T. Broyhill
Ranking Minority Member
Committee on Energy and Commerce
U.S. House of Representatives
Washington, D.C. 20515@
Congressman Broyhill

�Staff Memorandum

Prepared by the

Office of Special Projects and
Health Program

April 1985

Report on the Progress of the
Centers for Disease Control's Studies of the
Health of Vietnam Veterans

This OTA Staff Memorandum has
neither been reviewed nor approved
by the Technology Assessment Board.

�Report on Progress in the Centers -for Disease Control's
Studies of the Health of Vietnam Veterans

OTA held a meeting of its Agent Orange Advisory Panel on February
28 and March 1, 1985.

February 28 was devoted to discussing CDC's Agent

Orange, Vietnam Experience, and Selected Cancers studies,

Peter Layde,

Project Officer, and Dan McGee, both -from CDC, attended the m e e t i n g at
OTA's i n v i t a t i o n . They presented information about the studies, and
answered questions from the Advisory Panel, c o n t r i b u t i n g to the
e f f i c i e n t use of time at the meeting. COn March i, the protocol for the
Vietnam Experience Twin Study &lt;VETS II) was considered.

Our f i n d i n g s

about VETS II are contained in the OTA Director's letters of March 20,
1985 to the Chairman and Ranking M i n o r i t y Member of the House Committee
on Veterans' Affairs.]
CDC has made considerable progress in various aspects of a l l three
studies. Among t h e i r accomplishments, they have established that more
than 90 percent of contacted veterans are w i l l i n g to answer the
questionnaire and p a r t i c i p a t e in the medical e x a m i n a t i o n for the Vietnam
Experience Study.

In addition, contracts have been placed for

.administration of the questionnaire and the examinations.

In general,

CDC is on schedule w i t h a large array of tasks and is to be commended on
t h e i r e f f i c i e n t management of the studies.

Rather than catalogue CDC's

accomplishments, however, OTA w i l l use t h i s report to draw a t t e n t i o n to

Report of OTA Advisory Panel M e e t i n g
A p r i l 1985
P. 1

�two major areas o-f concern. The -first is the t i m e t a b l e -for the Selected
Cancers Study, w h i c h is scheduled to be completed in 1989. W h i l e that
scheduling has not, in •fact, changed since the protocol was w r i t t e n , we
are concerned that those results may not be as t i m e l y as they m i g h t be.
The second issue is the method now proposed to estimate Agent Orange
exposure in the Agent Orange study.

That has changed s i g n i f i c a n t l y

since the o r i g i n a l protocol, now representing a much less precise
measure.

Timetable for__the Selected Cancers Study
The Selected Cancers Study is a case-control study o-f so-ft tissue
sarcoma, lymphoma, primary l i v e r cancer, and nasal and nasopharyngeal
cancers.

Except for lymphoma, these are all r e l a t i v e l y rare tumors.

S i x cancer registries that m a i n t a i n records o-f cancers diagnosed in
different areas of the country are currently are under contract to CDC.
They are to provide names of men of the age of Uietnam veterans who have
or w i l l be diagnosed as h a v i n g those cancers between December 1, 1984
and November 30, 1988.

CDC w i l l then contact those men to learn about

service in Vietnam and other factors that m i g h t be related to t h e i r
cancers.

Results of the analysis are expected in 1989.

OTA is concerned that a result in 1989 w i l l have considerably less
v a l u e than one that could be reported sooner. We b e l i e v e that CDC could
considerably shorten the t i m e needed for the study by r e c r u i t i n g
a d d i t i o n a l cancer registries to provide cases. We understand that t h i s
may not be possible, but recommend that it be g i v e n serious
consideration.

CDC already finds it necessary to add one registry

Report of OTA Advisory Panel M e e t i n a
A p r i l 1935
P. 2

�because of the large number of AIDS-associated Kaposi's sarcomas &lt;a type
o-f so-ft tissue sarcoma) in the San Francisco Bay area registry.
Inclusion o-f those tumors, not related to Vietnam service, m i g h t bias
the results o-f the study. S o l i c i t a t i o n o-f other registries could go on
at the same t i m e to enlarge the sample.

Agent Orange Exposure Assessment
Major changes in the method o-f deterrning possible exposure to Agent
Orange have been -forced on CDC. The best way to describe those changes
is to r e c a l l the s a l i e n t features o-f the method described in the CDC
protocol that was approved by OTA.

Brie-fly, the Army's Environmental

Support Group (ESS) was expected to track the movements o-f more than 100
Army companies in Vietnam during the two years o-f peak Agent Orange use.
The locations o-f the companies then would be compared to locations to
known uses o-f Agent Orange, and the-companies d i v i d e d into three groups,
those most and least exposed and an i n t e r m e d i a t e group. The companies
chosen -for the study would be those w i t h the highest and lowest
c u m u l a t i v e exposures to Agent Orange.
Two assumptions were b u i l t into t h i s approach: (1) that many or
most soldiers served t h e i r e n t i r e tours o-f duty in Vietnam w i t h s i n g l e
companies, and &lt;2) that ESG would be able to specify the locations of
companies. In other words, Soldier S served w i t h Company C and Soldier
T w i t h Company D, and once we knew the locations of Companies C and D,
we would be able to classify the soldiers' exposures. According to a
report prepared by CDC, n e i t h e r of those assuptions is j u s t i f i e d .

Report of OTA Advisory Panel M e e t i n g
A p r i l 1985

P. 3

�The CDC report includes the results of a study of combat company
records w h i c h found that only 16 percent of 3838 men spent as long as 9
months in a particular company.

That f i n d i n g means that many men moved

between companies during t h e i r year in Vietnam, making it i m p o s s i b l e to
d i v i d e veterans i n t o h i g h or low exposure on the basis of company
cumulative exposures.

For instance, a soldier who spent 6 months in a

h i g h l y exposed u n i t could have been tranfered to a less exposed company.
The only way to describe h i s exposure is by tracking h i s movements: he
has n e i t h e r the h i g h exposure associated w i t h the f i r s t company nor the
low exposure of the second.

Because i n d i v i d u a l exposure cannot be

equated w i t h company exposure, it is now impossible to p i c k h i g h and low
exposed companies and drop out those in between.

That means exposures

w i l l fall across a continuum from low to intermediate to h i g h rather
than a dichotomous grouping of low versus h i g h . It also means that the
amount of work necessary to classify a veteran is increased,- but that is
not an insurmountable barrier.
Of far more importance is CDC's conclusion that there is too l i t t l e
information to locate companies and that decisions about exposure w i l l
have to be based on b a t t a l i o n locations. The number of men in a
b a t t a l i o n is roughly f i v e times that in a company, and b a t t a l i o n s were
spread out over much larger areas.

CDC presents data showing m u l t i p l e

reported locations for a single b a t t a l i o n on a s i n g l e day.

The

_ d i f f e r e n t locations represent the p o s i t i o n s of i n d i v i d u a l companies or
other subunits of the b a t t a l i o n , and CDC p o i n t s out that the records are
not s u f f i c i e n t to decide how many of the battalion's i.OOO men m i g h t
have been present at any of the reported locations. Therefore, they

Report of OTA Advisory Panel M e e t i n g
A p r i l 1935
P. 4

�c a l c u l a t e a "centroid," w h i c h is an "average" location of the b a t t a l i o n .
Unfortunately, significant distances, approaching 20 kilometers (km),
can separate the reported locations and the centroid.
In the eyes of several OTA advisory panel members, i n a b i l i t y to
locate companies s i g n i f i c a n t l y changes the study from the one that was
approved, seriously and perhaps f a t a l l y compromising the Agent Orange
study.

As an example, consider the locations and centroid on the

diagram &lt;the data are taken from the CDC report).

Assume that a Ranch

Hand mission passed d i r e c t l y over the centroid as shown by track 1.
This would result in the battalion being classified as exposed.
However, the members of the battalion were spread over a large area, and
those at e i t h e r of the two known locations were about 19 km away from
the spray mission. Moreover, si.nce the centroid is a calculated
p o s i t i o n , there may have been no one there at a l l .
Another p o s s i b i l i t y , is that a spray mission was flown as shown by
track 2.

In that case, the track would be about 19 km away from the

centroid, and the b a t t a l i o n would be c l a s s i f i e d as unexposed. Note,
however, that any men at the reported location A could have been
exposed.
The two examples show the p o s s i b i l i t i e s of m i s c l a s s i f i c a t i o n .

In

the track 1 example, men who were not exposed would be c a l l e d exposed;
in the other, exposed men would be c a l l e d unexposed.
These are serious problems, but OTA comes to no conclusion about
t h e i r impact on the study at t h i s t i m e . Ule expect to hold another
m e e t i n g in about s i x months to hear from CDC about any improvements that
can be made.

If there are no improvements, OTA may decide that the

Report of OTA Advisory Panel M e e t i n g
A p r i l 1935
P. 5

�An Example of Recorded Positions of a Battalion's Subunits and the
Calculated "Centroid" of those Locations.

Spray track 2

400
Recorded location A, based on 4 locations recorded on one day

390
Spray track 1

19 km

380

t\j

Centroid, a calculated central location based on
recorded locations A and B

19 km

370

Recorded location B, based on 3 locations
recorded on one day

360
340

350
360
370
kilometers from a known point in Vietnam

�problems of d e c i d i n g on exposure are so overwhelming that it is
impossible to study the possible effects o-f Agent Orange.

OTA made one

request and one suggestion to CDC:
1. If CDC continues w i t h an exposure assessment
s i m i l a r to the one described, OTA would l i k e to have an
estimate of the chance of m i s c l a s s i f i c a t i o n i n t o h i g h
or low exposure categories,
2. Every effort should be made to f i n d an external
validator of exposure. We realise that t h i s is a
d i f f i c u l t task, but an external v a l i d a t o r would be of
great value.

OTA Followup on the Exposure Question
Following the Advisory Panel m e e t i n g , OTA staff contacted Mr.
Richard C h r i s t i a n of the ESG and asked if he concurred in the CDC
e v a l u a t i o n that companies cannot be located.

He said he d i d not,

OTA

staff v i s i t e d h i m and h i s colleagues and were convinced that l o c a t i n g
companies was s t i l l a v i a b l e possibility.

Following that v i s i t , OTA

staff urged that CDC and ESG hold a meeting to discuss the company
question.

According to both ESG and CDC, the meeting was a success, and

efforts are now b e i n g made to apply an ESG-developed method for l o c a t i n g
companies.
This experience underlines the fact that ESG has information
a v a i l a b l e from no other source and that CDC has to make every effort to
understand what ESG can and cannot provide.
organizations must cooperate closely.

Clearly, the two

OTA has not investigated the

r e l a t i o n s h i p between ESG and CDC to the p o i n t that we Know what should
be done to improve and m a i n t a i n good communications between them, but
such communication is i m p e r a t i v e .

Report of OTA Advisory Panel M e e t i n g
April
1985
P, 6

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