United States
Environmental Protection
Agency
Industrial Environmental Research
Laboratory
Research Triangle Park NC 27711
Research and Development
EPA-600/S8-83-027 Sept. 1983
Project Summary
Environmental Monitoring
Reference Manual for
Synthetic Fuels Facilities
D. Bruce Henschel and James T. Stemmle
The Energy Security Act, which es-
tablishes the U.S. Synthetic Fuels Cor-
poration (SFC), specifies that applicants
for SFC financial assistance must de-
velop an acceptable plan for environ-
mental monitoring of the construction
and operation of the proposed synthetic
fuels facilities, following consultation
with EPA and other agencies. This
manual is intended as a technical aid to
applicants, the SFC, and environmental
reviewers in developing and reviewing
plans covering source and ambient
monitoring around coal-, oil shale-, and
tar sand-based synfuels plants, consis-
tent with the Act.
This manual does not provide rigorous
specifications for an "acceptable" mon-
itoring plan. Rather, it describes ap-
proaches to consider and issues to
address in developing a monitoring plan
(or an outline of a plan). The exact
content of the plan or outline for a
specific facility would depend upon
conditions associated with that plant.
This manual addresses approaches
for selecting discharge streams and
ambient media for monitoring sub-
stances/survey procedures to be ad-
dressed, monitoring frequencies, and
sampling/analysis techniques. A phased
monitoring approach is emphasized.
This Project Summary was developed
by EPA's Industrial Environmental Re-
search Laboratory. Research Triangle
Park, NC, to announce key findings of
the research project that is fully docu-
mented in a separate report of the same
title (see Project Report ordering infor-
mation at back).
Purpose of Manual
The purpose of this manual is to aid
applicants to the U.S. Synthetic Fuels
Corporation (SFC) in developing Environ-
mental Monitoring Plans (and outlines of
such plans) covering source and ambient
monitoring around coal-, oil shale-, and
tar sands-based synthetic fuels facilities.
The manual is also intended to assist the
SFC and environmental agencies in re-
viewing these monitoring plans and plan
outlines. The manual is provided as one
component of EPA's consultation process
in monitoring plan development, as
specified in Section 131(e) of the Energy
Security Act.
This manual does not provide rigorous
specifications for an "acceptable" moni-
toring plan. Nor is the manual a compre-
hensive definition of the compliance
monitoring that will be required by per-
mits. Rather, the manual describes ap-
proaches that can be considered, and
issues that need to be addressed, in the
development of a monitoring plan or
outline for a synthetic fuels plant. The
exact content of the monitoring plan or
outline for any specific facility would have
to be developed taking into consideration
the particular conditions associated with
that plant.
Background
The Energy Security Act of 1980 (PL
96-294)—which establishes the SFC—in-
cludes the following requirement (Section
131(e)of the Act):
"Any contract for financial
assistance shall require the de-
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velopment of a plan acceptable
to the Board of Directors (of the
SFC), for the monitoring of envi-
ronmental and health-related
emissions from the construction
and operation of the synthetic
fuel project. Such plan shall be
developed by the recipient of
financial assistance after con-
sultation with the Administrator
of the Environmental Protection
Agency, the Secretary of Energy,
and appropriate State agencies."
The intent of Congress concerning Sec-
tion 131(e) is discussed in the Joint
Explanatory Statement, Committee of
Conference for this Act:
"The monitoring of emissions—
gaseous, liquid or solid—and the
examination of waste problems,
worker health issues and other
research efforts associated with
any synthetic fuel project receiv-
ing assistance'pursuant to this
Part will help to characterize and
identify areas of concern and
develop an information base for
the mitigation of problems asso-
ciated with the replication of
synthetic fuel projects."
In implementing Section 131(e), the
SFC is utilizing a two-stage approach
under which an applicant (1) develops an
outline of the monitoring plan for incor-
poration into the financial assistance
contract, and (2) develops the monitoring
plan itself, based upon the outline, after
the financial assistance contract is execut-
ed. The SFC has published interim final
Environmental Monitoring Plan Guide-
lines (April 1, 1983), setting forth the
procedural steps and the broad substan-
tive areas to be addressed in developing
outlines and plans. These interim final
Guidelines are being reviewed, and might
be revised as a result of the review.
This Environmental Monitoring Refer-
ence Manual is a component of the
mandated consultation process in moni-
toring plan development. Another compo-
nent of the process is direct contact
between EPA and applicants, to assist
applicants in applying the manual to the
specific circumstances of each proposed
facility. The manual will aid in the develop-
ment and review of both monitoring plan
outlines, and the plans themselves, con-
sistent with both the intent of Section
131 (e)and current SFC monitoring guide-
lines.
Scope and Content of
Manual
This manual addresses: coal-, oil
shale-, and tar sands-based synthetic
fuels processes; source and ambient
monitoring; regulated and unregulated
substances; pre-construction, construc-
tion, and operational monitoring; and
control device performance monitoring.
• Coal-, oil shale-, and tar sands-based
synthetic fuels processes. These
processes include coal gasification
(high-, medium-, and low-Btu), coal
liquefaction (indirect and direct), sur-
face and modified in situ oil shale
retorting, and tar sands processing.
The information in the manual should
also be generally applicable in plan-
ning monitoring for heavy oil, peat,
and other synfuels processes.
• Source and ambient monitoring.
Source monitoring includes chemical
and biological analysis of discharge
streams (gaseous, aqueous, solids),
including fugitive discharges inside
the plant boundaries; source moni-
toring also includes monitoring of
environmental control device perfor-
mance. Ambient monitoring includes
chemical and biological tests of the
unconfined environment near the
synfuels plant (atmosphere, surface
waters, water in the unsaturated
soil, surface and deep aquifers, and
the soil). Source and ambient moni-
toring programs are envisioned as
being integrated. The manual does
not address industrial hygiene, wild-
life, or socioeconomic monitoring.
• Regulated and unregulated sub-
stances. The intent of the monitoring—
to develop a synfuels data base on
environmental and health-related
impacts, in order to mitigate prob-
lems in replications—is construed to
necessitate that the monitoring ad-
dress substances in addition to the
pollutants currently regulated in the
ambient and in related industries.
Many substances which might be
discharged from synfuels plants are
not regulated. Accordingly, the moni-
toring approaches considered in this
manual address unregulated sub-
stances as well as regulated pollut-
ants. This consideration of unregu-
lated substances is consistent with
the SFC monitoring plan guidelines.
• Pre-construction, construction, and
operational monitoring, in the case of
ambient monitoring. Source monitor-
ing addresses only monitoring during
operation.
• Monitoring of control device perform-
ance, as one component of source
monitoring. Such monitoring could
address inlet and outlet streams
associated with the control device,
and suitably selected device operat-
ing parameters. The performance/
reliability of conventional control
techniques on synfuels plants has
not been demonstrated in most cases;
an improved understanding of con-
trol performance, obtained by moni-
toring of initial synfuels plants, could
help mitigate environmental prob-
lems in future synfuels plants.
To aid in the development of monitoring
plans and monitoring plan outlines, this
manual: describes a reasonable "infor-
mation base" for the synfuels plant,
discusses alternative potential approach-
es to effectively develop the data base,
presents alternative monitoring proce-
dures, and suggests a meaningful quality
assurance/quality control program.
• A reasonable "information base" for
the synfuels plant (in accordance
with the wording in the congressional
explanatory statement), would in-
volve: analysis for specific chemical
substances; application of analytical
survey techniques, to screen for
classes of substances where the
specific chemical components of a
synfuels stream cannot be predicted
a priori; and biological testing. This
data base was derived considering:
currently regulated substances (in
the ambient and in related indus-
tries); substances which are typically
specified for monitoring in environ-
mental permits for related i ndustries,
unregulated substances which have
been observed in existing source tes
data from synfuels facilities; anc
unregulated substances, included ir
various recognized pollutant lists
which might reasonably be expecte<
to be discharged from a synfuel:
plant. The presentation of the conten
of the data base includes suggestion:
concerning which specific sub
stances/survey techniques/bio
assays might reasonably be consid
ered in which streams (source moni
tormg)or which ambient media (ambi
ent monitoring) under different cir
cumstances.
• Alternative potential approaches the
might be considered for effectivel
developing the data base, in mo.'
cases involve phasing of the mon
toring program, e.g., a fairly compn
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hensive survey is conducted in the
first phase, followed by a reduced
second phase which is based on the
first-phase results. The monitoring
frequency and the duration of each
phase can be selected based on site-
specific statistical considerations.
• Alternative monitoring procedures
(sampling, sample handling, analysis)
might be considered for each sub-
stance and each survey technique
included in the data base. Capabilities
of, and estimated cost ranges for,
individual procedures are indicated.
• A meaningful quality assurance/qual-
ity control program is suggested.
Use of Manual
In using this manual, two important
considerations need to be recognized.
• The manual does not provide rigorous
specifications for an "acceptable"
monitoring plan. Nothing in the
manual is a "requirement." The
manual only describes alternative
approaches that can be considered in
developing the data base referred to
in the Congressional explanation.
These alternatives can be considered
in structuring a monitoring plan (or
plan outline) tailored to a specific
facility.
• Suggestions in this manual which
conflict with permit (compliance)
monitoring requirements for a spec-
ific facility are superseded by the
permit requirements. As a practical
matter, most of the compliance moni-
toring required by permits for a
particular facility will generally be
found in this manual. However, it
cannot be ensured that the monitor-
ing approaches described in the
manual will be inclusive of, and
consistent with, every conceivable
set of permit requirements that might
be encountered in practice. These
requirements will be established by
the cognizant permitting agency
based on the particular conditions
associated with a specific site.
The interim final SFC monitoring plan
guidelines include specifications regard-
ing the content of monitoring plan out-
lines and of monitoring plans themselves.
According to these guidelines, the outline
should:
• Summarize compliance monitoring
obligations
• Indicate the regulated and unregu-
lated substances that will be moni-
tored (or, where specific unregulated
substances cannot be identified be-
forehand, indicate the classes of sub-
stances that will be addressed).
• Indicate the general location of the
monitoring (stream, ambient medi-
um).
• Generally indicate how the monitor-
ing will be performed (e.g., high-
volume sampler); where specific un-
regulated substances cannot be iden-
tified beforehand, indicate the meth-
od(s) by which the specific sub-
stances will be identified.
• Indicate the duration of monitoring.
• Provide background information on
the synfuels projects to enable re-
view of the outline (e.g., overall
process description, process block
flow diagram, control system perform-
ance design, plot plans, detailed site
description, supporting environmen-
tal data).
The monitoring plan should include:
• Further definition of the substances
to be monitored.
• Detailed indication of monitoring site
locations.
• Specific sampling/sample han-
dling/analytical protocols, including
equipment and methods.
• Monitoring frequency for each sub-
stance at each monitoring location.
• Background information, as for the
outline above.
This monitoring reference manual can
be used to address each of the above
specifications for monitoring outlines and
plans.
• To help select specific substances for
monitoring—or classes of unregu-
lated substances, where specific
substances cannot be identified be-
forehand—tables present the sub-
stances (or survey techniques, where
specific substances cannot be de-
fined) in the "information base." The
user would supplement these tables
with engineering judgment, addition-
al data, and permit requirements.
• To help select monitoring location,
the tables referenced above can be
used (source monitoring), indicating
the streams in which the sub-
stances/survey techniques might be
considered; also a section is provided
on ambient monitoring station siting.
• To help select monitoring techniques,
a section and an appendix list alter-
native source monitoring techniques
that might be considered for each
substance and each survey proce-
dure; capabilities and costs of alter-
native techniques are presented.
Specific techniques and detailed pro-
tocols can be selected for a given
plant by an experienced analyst,
based on (for example) desired ana-
lytical sensitivity, potential interfer-
ences, and capabilities of available
laboratories. Similarly, a section and
five appendices list information on
ambient monitoring techniques.
• To help select monitoring frequency
and duration, practical and statistical
considerations are described for the
phased monitoring approach. In ap-
plying the statistical considerations,
the user would need to make site-
specific decisions (in particular, the
accuracy desired in the monitoring
program).
The SFC monitoring guidelines specify
the formation of a Monitoring Review
Committee, representing the developers,
the SFC, and Federal and State agencies
consulting in the monitoring plan devel-
opment. This committee will review the
monitoring results and advise the SFC. If
a phased monitoring approach is utilized,
the committee could help guide the
activity to design the second phase pro-
gram based on the first phase results.
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The EPA authors D. Bruce Henschelfalso the EPA contact, see below) and James
T. Stemmle are with the Industrial Environmental Research Laboratory,
Research Triangle Park, NC 27711 and Office of Environmental Processes and
Effects Research, Washington, DC 2O460, respectively.
The complete report, entitled "Environmental Monitoring Reference Manual for
Synthetic Fuels Facilities," (Order No. PB 83-251 850; Cost: $41.50, subject to
change) will be available only from:
National Technical Information Service
5285 Port Royal Road
Springfield, VA 22161
Telephone: 703-487-4650
D. Bruce Henschel can be contacted at:
Industrial Environmental Research Laboratory
U.S. Environmental Protection Agency
Research Triangle Park, NC 27711
•AU.S GOVERNMENT PRINTING OFFICE 1983-659-0)7/7184
United States
Environmental Protection
Agency
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Information
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