RESOURCE AND ENVIRONMENTAL CONSTRAINTS
OF SYNFUELS DEVELOPMENT
FINAL REPORT
WATER PURIFICATION ASSOCIATES
238 MAIN STREET
CAMBRIDGE, MASSACHUSETTS 02142
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RESOURCE AND ENVIRONMENTAL CONSTRAINTS
OF SYNFUELS DEVELOPMENT
FINAL REPORT
by
John Casana and Harris Gold
WATER PURIFICATION ASSOCIATES
Cambridge, Massachusetts 02142
October, 1980
Prepared for
DENVER RESEARCH INSTITUTE
University of Denver
Denver, Colorado 80208
Under contract to
Industrial Environmental Research Laboratory
U.S. ENVIRONMENTAL PROTECTION AGENCY
Cincinnati, Ohio 45268
Cooperative Agreement R807294010
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ABSTRACT
Resource and environmental constraints of synthetic fuels production
are reviewed. The major resource constraint is water availability in the
semi-arid regions where much of our western coal and oil shale reserves lie.
Applicable air, water and solid waste regulations are summarized and poten-
tial constraints are identified. Generic solutions to overcoming each of
the potential resource and regulatory constraints for synfuels production are
presented and possible intermedia impacts are identified. Almost every generic
solution for constraints in one media affects at least one constraint in another
media.
to,
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TABLE OF CONTENTS
Page
Abstract ii
List of Figures iv
List of Tables v
Purpose and Authority • . 1
Resource Constraints 1
Environmental Constraints 2
Air Emission Constraints 3
Wastewater Discharge Constraints 10
Underground Injection Constraints 15
Solid Waste Constraints 19
Intermedia Constraints 22
111
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LIST OF FIGURES
No. Title Page
1. Location of Coal Resources with Respect to Ambient Air
Quality Standards 6
2. Relationship of Oil Shale Resource Areas to Class I Air
Quality Standards 8
3. Selected Drainage Basins with Water Quality Limited Segments
Near Major Coal Regions 14
4. Basins Affected by Excess Suspended Solids 16
5. Basins Affected by Toxic Pollutants 17
IV
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LIST OF TABLES
No. Title Page
1. Federal Air Quality Regulations 5
2. States Where Ambient Air Quality Standards Exceed Federal
Standards 7
3. Potential Air Emissions Discharge Constraints
4. Current EPA Effluent Standards for Sources Similar to.
Synthetic Fuels 11
5. Potential Wastewater Discharge Constraints 13
6. Organic Priority Pollutants and Other Potentially Harmful
Ingredients Found in Untreated Coal Gasification Condensate . . 18
7. Maximum Concentration of Contaminants for Characteristic of
Extraction Procedure Toxicity 20
8. Potential Solid Waste Disposal Constraints , 23
9. Intermedia Constraints 24
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RESOURCE AND ENVIRONMENTAL CONSTRAINTS OF SYNFUELS DEVELOPMENT
Purpose and Authority
The objective of this report is to identify resource and environmental
limitations of synfuels development for use by authors of Pollution Control
Guidance Documents (PCGD's). These documents are being prepared for the
EPA in response to the President's program to expedite development and
commercialization of synthetic fuels conversion technologies. The technol-
ogies addressed in this report are: oil shale, direct coal liquefaction,
medium BTU gas and indirect coal liquefaction. Resource constraints
considered are the availability of water and the location of known deposits
of coal and oil shale. Environmental constraints addressed relate current
and future waste discharge and disposal regulations to wastes generated by
each technology. Finally, generic solutions and their potential effects are
addressed as intermedia constraints.
Resource Constraints
The major resource constraint for synfuels development is the availa-
bility of sufficient water. Primary water uses in synfuels production
include: (1) shydrogenation, (2) cooling and other process uses, (3) mining
and residuals disposal; Water is consumed in hydrogenation to improve the
hydrogen to carbon ratio of the product fuel. Cooling is often the major
consumptive water use-in synfuels production. Various, degrees of dry (or air)
cooling may. .be employed to reduce this consumption at a higher initial cost.
Dust control in mining and crushing operations can consume significant quanti-
ties of water, particularly in surface mining. Revegetation may also require
significant amounts of water as may the compaction of spent shale. Other
water uses include service, sanitary and potable consumption. The net water
consumed will depend on many factors, including the composition of the feed
coal or oil shale, the process type and the climate.
The rich oil shale deposits of the Green River Basin and much of the
western coal reserves are located in some of the most arid regions of our
country. Much of the limited water supply is currently utilized for agri-
cultural production and other purposes such as municipal and power generation.
Surface water supplies are characterized by poor quality and are subject to
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highly variable flows. Major use of the region's groundwater (which is
often of poor quality) to augment surface supplies could ultimately affect
the hydrologic cycle, resulting in a possible depletion of groundwater
reservoirs and/or a reduction in surface water flows. Only a detailed
regional hydrologic investigation can project the ultimate effects of
synfuels production. The development of a significant fossil fuel industry
in such a water limited environment requires techniques beyond what would
be dictated in a water sufficient region. For example, greater incentives
for water recycle/reuse, dry or wet/dry cooling and attainment of zero
discharge exist. Also, acquisition of water rights or development of
additional reservoirs may be justified. Other options include the exporta-
tion of the fossil fuel resource and/or the importation of water to alleviate
water limited situations.
In other areas such as the eastern coal regions (Appalachian and
Illinois coal regions) water availability is less likely to be a major
constraint to synfuels development. In such cases water conservation and
reuse would not be economically justified to the degree warranted by a
water limited situation. Rather, effluent discharge regulations may
dictate the degree of water conservation, recycle and reuse.
However, away from the major rivers in the East, surface water supplies
are much less reliable, and water may be a limiting factor in these regions.
The same incentives for-minimum water usage would apply here as would
apply in the West.
In certain locations an excess of water may be generated. This could
result, particularly for the case of modified-in situ oil shale conversion,
from excessive mine drainage. Here the problem becomes disposing of the
excess water in an environmentally acceptable manner, and the incentive
for water conservation and recycle/reuse is diminished. Disposal options
might include subsurface injection, land application, discharge to receiving
waters or storage in reservoirs for future use after appropriate treatment.
Possible intermedia constraints resulting from the solution of specific
water resource constraints will be discussed in the final section of this report.
Environmental Constraints
Introduction
During the past decade Congress has enacted strong pieces of legisla-
tion to control air, water and solid waste discharges. Among those laws
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which could constrain the development of a synthetic fuels industry are
provisions of the Clean Air Act, Clean Water Act, Safe Drinking Water Act
and Resource Conservation and Recovery Act. In addition, state laws
sometimes exceed the discharge requirements of Federal regulations.
Federal and state standards affecting air, water and solid waste
discharges are listed in this section together with the major coal and oil
shale resource regions in an attempt to show where and how a synfuels
industry could be constrained. Specific pollutants which may be present
in synfuel waste streams are then related to regulated pollutants.
It should be noted that additional environmental legislation exists
which could affect synfuels development, but which does not pertain directly
to controlling waste discharges. Such legislation includes the Toxic
Substances Control Act (which could affect the transportation of syncrude),
the Occupational Safety and Health Act, the Endangered Species Act, the
Surface Mining Control and Reclamation Act and the National Environmental
Policy Act. We will limit this analysis to regulatory constraints relating
directly to the control of waste streams.
Air Emission Constraints
The Clean Air Act of 1970 and the Clean Air Act Amendment of 1977
provide the basis for air emission regulatory authority. Major provisions
include: (1) promulgation by the EPA of National Ambient Air-Quality
Standards (NAAQS) for_six major pollutants, CO, HC, O , NO , S0_ and
X X £
particulates; -(2) establishment by the EPA of National Emission Standards
for hazardous -pollutants-and standards of performance for new sources;—(3)
prevention .of significant deterioration where air quality is -better than
NAAQS through establishing the permissible incremental increase in ambient
concentrations from new sources.
Two sets of ambient quality standards are required; primary standards
for health considerations and secondary standards for environmental considera-
tions. Primary standards become effective 12/31/82, while secondary
standards are to be achieved as soon as possible thereafter. Areas which
exceed the primary standards are designated as "non-attainment" areas.
To obtain permission to locate in a non-attainment area, a new source must
show that the total emissions in the area will not be increased. In other
words, he may be required to finance air emission improvements to other
facilities to offset his emissions.
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A hazardous pollutant is one for which no NAAQS is applicable and
which, in the judgment of the EPA, causes or contributes to air pollution
resulting in an increase of mortality or incapacitating illness. The EPA
is authorized to set emission standards .for these substances. To date
standards have been promulgated for asbestos, beryllium, mercury, vinyl
chloride, radionuclides and benzene. Other hazardous substances under
consideration for emission standards are arsenic and polycyclic organic
matter (POM).
In addition, the EPA may establish standards of performance for
sources emitting noncriteria and nonhazardous pollutants which in its
judgment contribute to the endangerment of public health or welfare. Such
designated pollutants which might affect the synfuels industry include
NH , H S, COS, HCN, mercaptans and Ni (CO) . The designation of additional
pollutant discharge limitations may affect PCGD documents and permitting
requirements and is, therefore, addressed herein.
Table 1 lists the major regulations, status and current limits autho-
rized by the Clean Air Act which could impact the synfuels industry. Many
state ambient standards are more stringent than federal standards in one
or more pollutants. Figure 1 compares state standards with coal resources.
Notably the states of Kentucky, West Virginia and Virginia in the Eastern
Coal Region are not more stringent than Federal ambient air quality standards.
Table 2 presents a summary of states which are .more.stringent than Federal
ambient air quality standards by pollutant.
The richest oil shale deposits in the United States are located in
the Green River Basin of Colorado,- Utah and Wyoming. Figure 2 shows eight
designated Class I air quality areas in the region. -Note that the eight
areas approximately encircle the Piceance Creek portion of the Basin,
where most of the oil shale is located.
On September 5, 1979 the EPA proposed comprehensive amendments to the
PSD portion of the Clean Air Act . The proposals include guidelines for.
minimum emission rates in tons per year and corresponding minimum ambient
air quality concentrations for 17 pollutants. These values, termed de
minimus values, reflect emissions well below that considered harmful, and
are intended to provide a systematic means of exempting insignificant
sources from PSD requirements. The proposed de minimus emission rates and
corresponding ambient concentrations are presented in Table 3.
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TABLE 1. FEDERAL AIR QUALITY REGULATIONS
Provision of
Clean Air Act
Hew Source Performance
Standards (NSPS)
Prevention of Significant
Deterioration (PSD)
Non Attainment (NA)
Areas
Status
No NSPS set for synfuels.
Fossil fuel powered electric
utility NSPS would apply to
boilers, as shown.
Air quality increments for
SO. and particulates are
established to date
Sources locating in areas
exceeding Nat'l. Ambient
Air Qual. Standards must
utilize lowest achievable
emission rate technology
6 offset emissions by
cleaning up existing .
sources.
Current Limits
SO, Particulates NOx
lb/10
1
Area*
Class I
Class II
Class III
" Min. »
Btu Removal
.20 90 (initial
demo. plants
-80)
SO, (ug/m )
lb/106 Btu
0.03
Annual 24~hr/max 3 hr/max
2 5
20 91
700 182
National Ambient Air Duality
Classification
Primary
SO,
3 hr/ 24 hf/
Max Max
365
25
512
40
Standards
Annual
Mean
80
lb/106 Btu
0.50
Particulates (Mg/m )
24 hr Annual
10 5
37 19
75 37
(Ug/m3)
Particulates
24 hr/ Annual
Max Mean
260 75
(Eff. 12/31/82)
Secondary 1300
(Eff. asap after 12/31/82)
365
80
150
60
Visibility
Hazardous Pollutant
Emission Standards
Sources affecting a Class I
area's visibility may be req.
to implement controls exceed-
ing BACT, even though source
may not be located in Class X
area.
No hazardous pollutant emission
standards for synfuel facilities
have been developed. Hazardous
pollutants regulated which could
relate to synfuels include beryllium
and mercury.
To be decided on a case by case basis.
Hazardous
Pollutant
Beryllium
Mercury
Mercury
Industries
Ore and
Battery
Extraction,
Mach. Shop,
& Ceramics
Sludge
Emission
Standard
(24 hrs)
10 gin
2300
3200
Ambient
Standard
(Mq/nt3 )
0.01
None
None
Incineration
*Class I includes most national parks, national wilderness areas, national memorial parks and international parks;
currently there are no Class III areas, so all areas not designated Class I are Class II.
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LEGEND
.States where
standards are more
stringent
than Federal
Air Quality
Standards for SO,,
particulates and/or
Coal Resources (10 Tons)
O 10+
o 1-10
« 0.1-1
NO
LOCATION OF COAL RESOURCES WITH RESPECT TO AMBIENT AIR QUALITY STANDARDS
FIGURE 1
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TABLE 2
STATES V7HERE AMBIENT AIR QUALITY STANDARDS EXCEED FEDERAL STANDARDS
STATE
SO,
POLLUTANT
Particulates
NO
Alabama
Alaska
Arizona
Arkansas
California
Colorado
Connecticut
Delaware
Florida
Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
New York
North Carolina
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Washington
West Virginia
Wisconsin
Wyoming
TOTAL
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
24
X
X
X
X
X
25
X
X
X
X
X
Base data source: 1979 Yearbook and Product Reference Guide.
Pollution Engineering 10(12), Technical Publishing Co., Greenwich, Conn.
7
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0 25 50 100
Scale Miles
Areas of oil shale deposits
Designated Class I areas
1 Flat Tops Wilderness
2 Mount Zirkel Wilderness
3 Maroon-Bells-Snowmass Wilderness
4 West Elk Wilderness
5 Black Canyon of the
Gunnison Wilderness
6 Colorado National Monument
7 Arches National Park
8 Dinosaur National Monument
RELATIONSHIP OP OIL SHALE RESOURCE AREAS TO CLASS I AIR QUALITY AREAS
FIGURE 2
8
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TABLE 3. PROPOSED DE MINIMUS VALUES
Pollutant
Carbon Monoxide
Nitrogen Dioxide
Total Suspended
Particulates
Sulfur Dioxide
Ozone
Lead
Mercury
Beryllium
Asbestos
Fluorides
Sulfuric Acid Mist
"Vinyl Chloride
Hydrogen Sulfide
Methyl Mercaptan
Dimethyl Disulfide
Carbon Disulfide
Carbonyl Sulfide
Emission
Rate (Tons
per Year)
100
10
10
10
*
1
•0.2
0.004
1
0.02
1
1
1
1
1
10
10
Correspondng
Ambient Impact
(mg/m )
500
1
Average Time
Use for Ambient
Impact Determination
8 hour
Annual
24 hour
5
*
0.03
0.1
0.005
1
0.01
1
'1
1
0.05
2
200
200
24 hour
*
3 month
24 hour
1 hour
24 hour
24 hour
Maximum value
1 hour
1 hour
1 hour
1 hour
1 hour
1 hour
* Although no specific de minimus values are proposed for ozone, an
emission of 100 tons per year of total volatile organics subject to
PSD would require an impact analysis including ozone.
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The specific pollutants emitted in any of the basic processes consid-
ered herein will depend upon many factors including resource characteristics,
process design, equipment selection and emission controls. Only detailed
mass balance calculations can predict stream characteristics. For purposes
of identifying possible .constraints we have tabulated the regulated and
potentially regulated pollutants with respect to air emissions for each of
the technologies considered. This information is shown in Table 4.
Wastewater Discharge Constraints
Provisions of the Federal Water Pollution Control Act of 1972 and the
Clean Water Act of 1977 include the National Pollutant Discharge Elimination
System (NPDES), the establishment of instream water quality criteria, and
the development of of Best Management Practices (BMP).
Under NPDES, the EPA is authorized to set effluent limitations and
standards by specific industrial category. In addition a court settlement
between the EPA and several environmental groups requires the EPA to set
standards for specific toxic pollutants. NPDES discharge criteria may
vary for existing sources, new sources (NSPS) or sources discharging to
publically owned treatment works (POTW's).
Effluent guidelines for synthetic fuels facilities do not yet exist.
Effluent guidlines for coal conversion systems are in the early planning
stages, with promulgation expected to be staggered between late 1981 and 1984
Aqueous discharges from these facilities, however, are subject to provisions
of NPDES. As such, applications from synfuel plants must be reviewed by
state regulatory personnel. Criteria on which such reviews may be based are
summarized herein.
Existing effluent guidelines address conventional pollutants and are
based upon best practicable control technologies (BPT). Conventional
»
water quality pollutants include: biological oxygen demand (BOD), bio-
chemical oxygen demand (COD), oil and grease, total suspended solids
(TSS), fecal coliform, total phosphorus and pH. Future effluent limita-
tions for these parameters effective 7/1/84 will be based on best conven-
tional pollutant control technology (BCT).
Limitations for toxic pollutants effective 7/1/84 will be based on
the more stringent best available technology economically achievable
(BAT). There are currently 129 pollutants listed as toxic by the EPA.
10
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TABLE 4. SUMMARY OF SELECTED POTENTIAL AIR EMISSION CONSTRAINTS
LEGAL AUTHORITY
Constraint
so2
Particulates
NO
X
Asbestos
Beryllium
Mercury
Vinyl Chloride
Radio Nuclides
Benzene
POM
Ammonia
Hydrogen Sulfide
COS
HCN
Mercaptans
NiCO.
4
CO
Ozone
Lead
Fluorides
SO Mist
Dimethyl Sulfide
Carbon Bisulfide
Carbonyl Sulfide
Non-Hazardous
NAAQS/PSD Hazardous Non-Criteria De Minimus
X X
X X
X X
X X
X X
X X
X X
X
X
X
X
X
X
X
X X
X
X
X
X X
X
X
X
X
X
X
11
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Pollutants such as color which are not specifically identified as conven-
tional or toxic are classified as non-conventional. These must also be
considered by the EPA in establishing NPDES limitations.
Although there are no effluent guidelines established for synthetic
fuels production, standards exist for similar industries as presented in
Table 5.
In 1976 the EPA established instream water quality criteria to attain
the goal of fishable, swimmable waterways. Most states have since adopted
these criteria, and in some instances have set more stringent standards.
Among the latter are salinity standards for western rivers, particularly
for the Colorado River.
Stream segments may be designated as "water quality limited" by
states. Industries discharging to segments so designated are subject to
more stringent NPDES permitting requirements. Although dissolved oxygen
is the primary consideration, currently there is no uniform procedure by
which states designate segments as water quality limited . As a result
the same stream may be water quality limited on the upstream side of a
state border but not on the downstream side. Also, many states have not
yet acquired sufficient data to designate stream segments as water quality
limited. For example, no streams in the oil shale rich Green River Basin
have yet been designated as water quality limited by Colorado, but a final
determination on this matter is still under investigation by the state.
Four key fossil fuel states which have made water quality limited-
designations are -Pennsylvania, West Virginia, Kentucky and Utah. River
basins with water quality limited segments-in these four states are listed
4
below :
State Basin with Water Quality Limited Segments
Pennsylvania Delaware R., Susquehanna R., Ohio R., Lake Erie
West Virginia Kanawa R., Monongahela R., Ohio R., Little Kanawa R.
Kentucky Big Sandy R., Cumberland R., Green R., Kentucky R.,
Licking R., Mississippi R., Ohio R., Tradewater R.,
Salt R., Tenneco R.
Utah Great Salt Lake, Lower Colorado R., Green R.
Figure 3 illustrates the geographic relationship of these basins to
coal resources. The effect of a water quality limited designation, however,
12
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TABLE 5. CURRENT EPA EFFLUENT STANDARDS FOR SOURCES SIMILAR TO SYNTHETIC
FOSSIL FUELS PLANTS
Category
Coal Mining
(Expressed in mg/1
except pH)
Iron and Steel
Manufacturing
(Expressed in
XgAfcg of product.
except pH)
Petroleum Refining
For Typical lube
refining
(expressed in mg/1)
Organic Chemical
Manufacturing
Steam Electric Power
Generating
(Expressed in mg/1
except pH)
Subcategory
Coal preparation
plants and mine
Byproduct
Coxing
Topping ( for
discharge
other than
runoff or
ballast)
Processes with
process water
contact as
steam diluent
or absorbent
Generating Unit
Basis
BPT
BAT
BPT
BAT, DSPS
BAT
BAT.NSPS
BPT •
BAT
Pollutant or
Effluent
Characteristics
Total Fe
Total Na
TSS
pH
As in BPT
except for Fe
NH3
Cyanide
Oil/grease
Phenol
TSS
PH
Cyanide amenable
to Chlorination
Oil/Crease
Phenol
Ammonia
Sulfide
TSS
pH
BOD
TSS
COD
Oil/grease
Phenolic compounds
Ammonia (as N)
Sulfide
Total Chromium
COD
BOD
TSS
pH
pH
Polychlorinated
Biphenyl Compounds
TSS
Oil/Grease
Total copper from
metal cleaning or
boiler blowdown
Total iron from
metal cleaning or
- boiler blowdown
Free available
chlorine from
. cooling tower
blowdown
From cooling
tower blowdown
Zinc
Chromium
Phosphorus
Free available
chlorine from
cooling tower
blowdown
Materials added for
Maximum
Day
7.0
4.0
70.0
6.0 - 9.0 at
6.0
0.2736
0.0657
0.0327
0.0045
0.1095
6.0 - 9.0
0.0003
0.0124
0.0006
0.0126
0.0003
0.0312
6.0 - 9.0
2.3
2.4
10.0
0.5
0.012
0.68
0.055
0.126
7.8
0.37
0.94
6.0 - 9.0
6.0 - 9.0
Maximum
30-day
Average
3.5
2.0
35.0
Idle stream only
3.0
0.0912
0.0219
0.0109
0.0015
0.0345
0.0001
0.0042
0.0002
0.0042
0.0001
0.0104
2.0
2.0
8.0
0.4
0.0060
0.51
0.035
0.105
4.2
0.27
0.50
No discharge
100.0
20.0
1.0
1.0
0.5
Same as BPT except
as shown below
1.0
0.2
5.0
30.0
15.0
1.0
1.0
0.2
1.0
0.2
5.0
0.0 except for 2 hr period/day
Limits to be esl
.ablished
corrosion inhibition on a case-by-case basis
in cooling tower
blowdown
Heat from main
condensers
None except under special
circumstances
Source: Bureau of National Affairs, Inc.
Environmental Reporter, Washington, D.C.
(as updated through 2/1/80)
13
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LEGEND
Hill Selected basins
9
Coal Resources (10 tons)
O 10+
o 1-10
• 0.1-1
FIGURE 3. SELECTED DRAINAGE BASINS WITH WATER QUALITY LIMITED SEGMENTS NEAR MAJOR COAL REGIONS
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is specific to that river segment. It is, therefore, of particular
significance that the entire oil shale rich Uinta Basin and the lower
4
Green River in Utah (Figure 2) are designated as water quality limited .
The USEPA in cooperation with the various states is currently acquiring
and assessing instream water quality data. Efforts to date indicate that
some water quality problems exist in portions of most basins in the United
States. This is evidenced by compilations of data for suspended solids
and toxics as shown in Figure 4 and 5 respectively . As further data is
acquired and assimilated, the potential constraints to fossil fuel con-
version systems should become more apparent.
As with gaseous emissions effluent stream characteristics depend upon
many variables. A detailed mass balance for a particular site and plant
are required to accurately predict pollutants and flows. We have prepared
Table 6 for the purpose of illustrating potential regulatory constraints
on synfuels effluent discharges.
It is noteworthy that some pollutants with known toxic effects such
as C -alkylphenol, dihydrobenzene and phthalates have been reported in
•* g
coal gasification condensate , but are not currently listed as priority
pollutants. Such pollutants are subject to consideration as future additions
to the priority list.
Underground Injection Constraints -
The Safe Drinking Water Act provides for underground injection guide-
lines to be developed for wastewater -discharges. Currently- specific
technical and operational-requirements have riot been-proposed. The EPA
has recently required that states submit regulatory .requirements for
underground injection to the EPA within 270 days from July 24, 1980.
Until such regulations are approved, underground injection of hazardous
wastes is to be controlled under the Hazardous Waste Management Program.
The underground injection guidelines will apply to all underground
sources of drinking water which are not designated as sole source aquifers.
An underground source of drinking water means an aquifer which (1) supplies
drinking water for human consumption or contains fewer than 10,000 mg/1
dissolved solids and (2) is not an "exempted aquifer".
The Safe Drinking Water Act authorizes the designation of certain
aquifers as sole or principal drinking water sources. Underground injec-
tion of wastes is prohibited in aquifers so designated. Currently there
15
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From Nonpoint Sources
* in whole or in part
Note: Affected basins are shaded
FIGURE 4. BASINS AFFECTED* BY EXCESS SUSPENDED SOLIDS
Source: USEPA, National Water Quality
Inventory, EPA-440/4-78-001, October 1978.
16
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From Point Sources
From Nonpoint Sources (Pesticides only)
From Nonpoint Sources (Toxics other than
pesticides)
* In whole or in part
Note: Affected basins are shaded
FIGURE 5. BASINS AFFECTED* BY TOXIC POLLUTANTS
Source:. USEPA, National Water Quality
Inventory, EPA-440/4-78-001 Oct. 1978.
17
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TABLE 6. SELECTED POTENTIAL WASTEWATER DISCHARGE CONSTRAINTS
Legal Authority
Parameter Conventional Priority Non-Conventional In-Stream
BOD X
COD X
TSS X
Fecal Coliform X
Phosphorus X
Oil and Grease X X
Arsenic X
Beryllium X
Cadmium X
Copper X
Cyanide X
Lead X
Mercury X
Nickel X
Selenium X
Silver X
Thallium X
Zinc X
Phthalates X
C2-Alkyl Phenol X
C -Alkyl Phenol X
Napthalene X
Cresol X
Dihydrobenzene X
Acenaphthalene X
Benzoperylene X
Phenol X
POM x
Arsene X
Metal Carbonyls X
Ammonia X X
COS X
Alcohols X
Dissolved Gases X
Trace-OrganicB X
Alkalinity
Iron
Manganese
TDS X
Sulfides X
pH X
Temperature X
18
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are seven sole source aquifers in the United States: (1) San Antonio,
Texas, (2) Spokane/Rathdrum Valley, Washington, (3) Fresno County, Cali-
fornia, (4) Biscayne Aquifer, Florida, (5) Buried Valley, New Jersey, (6)
Ten Mile Creek, Maryland and (7) Nassau/Suffolk Counties, New Jersey.
None of these sole source aquifers are located in the vicinity of.major
coal or oil shale resources.
An aquifer may be exempted if it does not currently and cannot in
the future serve as a source of drinking water because (1) it is mineral,
hydrocarbon or geothermal producing, (2) water recovery for drinking
purposes is economically or technologically impractical, (3) contamination
has made it impractical to render its water fit for human consumption or,
(4) it is subject to subsidence or catastrophic collapse. To date no
aquifers have been determined to be exempt.
The EPA is currently raising the attention given groundwater protection
due in part to recent catastrophies such as Love Canal. As a result, the EPA
is holding a series of groundwater quality workshops in order to formulate
future policy alternatives. Depending on ultimate policy directives, regulatory
constraints on groundwater injection of synfuel wastes may be increased.
Solid Waste Constraints
The primary Federal law governing solid waste disposal is the Resource
Conservation and Recovery Act of 1976 (RCRA). Although RCRA is aimed at
proper disposal of all solid waste, its major emphasis and intent is the
control of hazardous materials. Criteria for identifying a waste as
hazardous are shown below:
Hazardous Nature Criteria
Ignitability Flash point < 140°F (60°C)
Corrosivity 2.0 ^ pH $: 12.5
Reactivity Explosive
Toxicity 24 hr leaching test in pH =
5.0 solution. Leachate must
not exceed 100 times drinking
water standards.
(Extraction Procedure, EP)
19
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The toxicity EP test is of most significance for synfuels solid wastes. The
pollutants and maximum allowable concentrations in the EP test are shown in
Table 7. It is probable that the EPA will expand this pollutant list in the
future. Also of significance is that the EP dilution factor may be reduced
from 100 to 10. For wastes not identified as being hazardous by the EPA, the
burden is on the generator to test and report his wastes.
The EPA has listed certain solid wastes as hazardous. Unless proven
non-hazardous from an individual facility, generators must comply with
strict identification, transportation and disposal procedures. Currently
no synthetic fuels wastes are listed as hazardous; however, the following
petroleum refinery wastes are listed.
Petroleum Refinery Wastes Listed as Hazardous
Dissolved Air Flotation (DAF) Float
Slop Emulsion Solids
Heat Exchanger Bundle Cleaning.Sludge
API Separator Sludge
Tank Bottoms (leaded)
TABLE 7.' "MAXIMUM CONCENTRATION'OF CONTAMINANTS .FOR
CHARACTERISTIC OF EXTRACTION PROCEDURE TOXICITY
Pollutant .Max. Concentration
Arsenic 5.0 mg/1
Barium 100.0
Cadmium 1.0
Chromium '5.0
Lead 5.0
Mercury 0.2
Selenium 1.0
Silver 5.0
Endrin 0.02
Lindane 0.4
Methoxychlor 10.0
Toxaphene 0.5
Dichlorpheroxyacetic acid 10.0
2-4-5 TP Silvex 1.0
20
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There is little or no available data concerning the toxicity of .solid
wastes from fossil fuel conversion systems. It is anticipated that the
larger volume wastes such as spent shale and ash will pass the EP toxicity
test while spent catalysts will probably not pass due to their high heavy
metal content. It is possible that wastes which pass all the hazardous test-
ing criteria may still be listed by EPA. Spent shale is a candidate for
such a waste for the following reasons: (1) possibility of carcinogens,
(2) trace metals, (3) concern over carbonized shale and (4) thermal charac-
teristics. The requirements for disposal in this case could be less stringent
than those for hazardous wastes not passing the testing criteria. For example
disposal requirements might include quenching, compaction and separate
disposal sites. Non hazardous solid wastes will still be subject to disposal
requirements, though less stringent.
Certain exclusions contained in RCRA affect synthetic fuels production.
These are listed below:
Selected Exclusions Contained in RCRA
Excluded Waste
Overburden intended for
return to mine site
In situ mining wastes
All hazardous wastes generated
at less than 1000 kg/mo
Hazardous solids entrained in air
or wastewater streams
Remarks
Except for uranium and phosphate
mining, overburden has been
specifically excluded as a
hazardous waste
Materials which are not removed
from the ground are specifically
excluded under RCRA
EPA plans to extend coverage
to 100 kg/mo within 2-5 yrs
Such materials are specifically
excluded since they are covered
by other laws.
Certain other items contained in RCRA and EPA's interpretation of them
are of significance to the synthetic fuels industry. These are listed below:
21
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Other Signficant Items of -RCRA
Item Significance
Recycle/Reuse Hazardous waste recovery and/or reuse is
considered a management technique, and
does not exempt the waste from RCRA
regulations
Economic Impact RCRA makes no mention of cost or economic
impact. EPA's interpretation is:
1. Cost is not a basis for lessening
standards to protect health or the
environment.
2. Cost/effectiveness may be used in
choosing among alternatives meeting RCRA
requirements.
The volume and nature of solid wastes generated will vary from site to
site. Information in Table 8 is presented to identify the relative quantity
of each solid waste generated and its likelihood of being subject to
hazardous waste regulations under RCRA.
Intermedia Constraints
Introduction
In the previous sections we have discussed specific potential resource
and environmental constraints for fossil fuel conversion systems. We will
now present alternative general solutions to each of the identified con-
straints and their potential impact on constraints in other media or other
consequences. By this approach a desirable balance of resource, environ-
mental or other impacts and the optimum level of production can be deter-
mined. Each alternative presented will require evaluation on a case by
case basis for a specific course of action to be recommended.
Discussion
A summary of identified constraints, generic solutions and associated
intermedia impacts and other aspects is presented in Table 9. In the
following commentary selected items in the table are expanded and applied
to specific cases.
22
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TABLE 8. POTENTIAL SOLID WASTE DISPOSAL CONSTRAINTS
Relative Quality*
Likelihood of
Hazardous
Classification*
Indirect
Liquefaction
0)
^1 ^ .(d .p
Q) EH O (00)
•H S Cn
U-i H 4-> 0) T3
•H 0) C -P 3
W -P i m a)
H rH t,
P4 CO H
222
2 2 2
MED, BTU
Gas
£
in
<: a)
en
n -r) -P
0) -P 3 in
•H 5 to -H w
O *Tj »^
tO Q) M -P
C Q) fl M
^i 0 iQ U Q)
•P 4J ^ -H
•H W 3 -P "+H
rH 0) M C -H
•H E U -i o -—
>i U -H >i
d) rH M rH -P rH
rH (d *H n] E3 *o «
id 4J < > O M O
x; id in o no)
en QJ tn O JH
1 1 ^ i ^| frt p^ '^ y) rtj
Q) (D^JrHrHrH^J CC(d
ft ft (d W -H W O -H -H PJ
W W S O U CM *•'
122 22 2
312 23 2
to
w
*Key: Relative Quantity: 1, major; 2, minor.
Likelihood of being classified as hazardous: 1, high; 2, medium; 3, low
-------
TABLE 9. INTERMEDIA CONSTRAINTS
Resource/Environmental
Constraint
Generic Solution
Potential Intermedia Impact
Other Aspects
Limited Water Supply
Import water across basin boundaries
Off site processing
Acquire local water rights
Develop additional surface supplies
Develop groundwater supplies
Alteration of. climate or vegetation
Implement dry(air) cooling processes
Apply water recycle/reuse technology
Use treated sewage for cooling or
other uses
Use saline cooling towers
Additional air, water & solid wastes
from increased production
Potential air, water & solid wastes
constraints at ultimate processing site
Additional air, water £ solids wastes
from increased production
Additional air, water & solid wastes
from increased production
Additional air, water 6 solid wastes
from increased production
Additional air, water fr solid wastes
from increased production
Reduced water requirements & wastewater
flow
Reduced water requirements 6 wastewater
flow
Possible release of viruses or other
contaminants from treated sewage into
the atmosphere; reduced fresh water
requirements, pretreatment sludge
Reduced fresh water requirements
Possible legal constraints;
reduction of water supply in
source basin; economic fc environ-
mental costs associated with
water transport
Economic 6 environmental impacts
associated with fuel transport
Constraint on water availability
for other uses such as agriculture
Costs £ environmental impact
associated with reservoir devel-
opment
Possible aquifer depletion &
reduced surface water flow
Environmental alterations, limited
chance of success
Higher capital costs
Higher capital costs
Pretreatment of sewage
New technology
Excessive Water
Dispose of excess water with spent
fuel for compaction/cementation
Treat s discharge excess water
Subsurface injection . .
Evaporation (solar or induced)
Increased leaching
Increased wastewater discharge and
treatment sludge
Aquifer contamination
Reduced effluent discharge; solids
residual, leaching
Longer disposal site life
Economic costs
Practice could be affected by
sole source or exempted aquifer
designation and/or injection
guidelines
High land and/or energy require-
ments
New Source Air Emission
Performance Standards
Install BAT technology to meet
standards
Selective development of low sulfur
deposits
Additional sludge generation & water
generation
Concentrated development may cause
localized air, water or solid waste
constraints
Less impact on ambient air quality
resulting in more production prior
to reaching NAAQS
Reduced total production
-------
TABLE 9. (Continued)
Resource/Environmental
Constraint
Prevention of Significant
Deterioration
Non Attainment
Visibility (Class I Areas)
Hazardous Pollutant
Emission Standards
NPDES Permit
(Conventional Pollutants)
NPDES (Priority or Non-
conventional Pollutants)
Instream Water Quality
Criteria and/or Water
Quality Limited Designation
Hazardous Listing of Low
Volume Waste such as
Spent Catalysts
Hazardous Listing of High
Volume Waste such as
Spent Shale
Non-hazardous Classifica-
tion of Wastes
Generic Solution
Install more efficient emission controls
Install higher stacks
Selective development of resources
away from Class I areas
Off site processing
Exceed BAT technology (i.e. LAER)
Use dry cooling to reduce evaporation
Improve emission control efficiency
Off site processing
Apply necessary technology
Selective resource development
Apply BCT technology and/or best
management practices (BMP)
Apply wastewater to spent shale or ash
Attain zero discharge '
Apply BAT technology and/or BMP
Attain zero discharge
Apply appropriate treatment
Zero discharge
Implement RCRA requirements
Recover catalysts for reuse
non-hazardous (encapsulation, fixation)
Implement RCRA requirements
Insitu oil shale retorting to reduce
Implement non-hazardous waste
disposal requirements
Potential Intermedia Impact
Increased sludge and/or water require-
ments
Hone
Concentrated development may cause
increased local resource/environmental
Decentralization could lessen local
consumption
Reduced water consumption S blowdown
Increased sludge fi/or water requirements
Decentralization could lessen localized
resource a environmental constraints
Increased sludge production and/or water
consumption
Centralization could increase local
resource/environmental constraints
Additional sludge production
Possible groundwater contamination
Reduced water requirements
Additional sludge* spent carbon or
other solid wastes
Reduced water requirements
Possible air & groundwater impacts
Additional sludge production
Reduced water requirements
Possible air fi groundwater Impacts
Reduced groundwater impact
None
Reduced groundwater impact
Reduced groundwater impact. Possible
air emissions fi land use impacts
Reduced water requirements i aquifer
contamination by residual organics .
Reduced groundwater impact. Possible
air emissions and land use impacts
Other Aspects
costs
More pollutants emitted
Reduced tota 1 production
Costs 6 environmental impact
tation
Reduced development due to
Increased total cost
Economic cost
Economic costs
Reduced overall production
Economic cost
Cementation may seal landfill
More feasible in dry climates
Economic cost
More feasible in dry climates
Increased economic cost
Increased economic cost;
More feasible in dry climates
Economic costs
Economic costs
Economic costs
Economic costs
Developing technology
Reduced economic cost over that
required for hazardous classification
K)
in
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As discussed previously, the primary resource related constraint is
water supply. Numerous imaginative approaches or combinations can resolve
this constraint. Some of these are listed in the table. The specific
approach selected will depend in part upon whether the Riparian or Appropri-
ation Doctrine of water rights applies, the availability and competition
for existing and potential fresh water supplies or the proximity to a
significant supply of salt water or of treated sewage. Humm has prepared
a detailed summary of eight specific limited water supply situations and
resolutions of energy developers. These approaches include:
1. Contracting directly with Indian tribes to obtain access to a
superior water supply which was independent of the appropriative rights
governing most supplies in the state,
2. Aguisition of existing irrigation water rights.
3. Negotiating mutually beneficial arrangements to augment or fully
utilize existing supplies,
4. Utilizing saline cooling towers, and
5. Using sewage effluent as a water source.
The latter two approaches are particularly attractive in that areawide
fresh water requirements are not increased.
Although it has received only limited use in the United States,
treated sewage is often used for cooling in other countries, including
South Africa and England. A major constraint to the practice is., calcium
phosphate scale formation resulting from high sewage phosphorus concentra-
tions. However, various physical, chemical or biological means are avail-
able for phosphorus removal . Such treatments usually result in addi-
tional sludge production which may impact solid waste constraints. The
potential release of viral or bacterial organisms in drift could be a
problem. This possibility is minimized, however, by chlorination and
biological activity in the cooling tower as well as exposure to sunlight.
In some cases it may be desirable to transport treated sewage or raw fossil
fuel some distance to take advantage of this potential water supply.
An inherent potential impact of resolving or improving a limited
water supply constraint is that the increased allowable fossil'fuel
production will produce proportionately more air, water and solid wastes,
which could .accentuate the environmental constraints in any or all of
these areas.
26
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Other areas of concern with development or acquisition of additional
water supplies (either in appropriation or Riparian states) is the potential"
injury to other users and/or the potential development of other water
dependent industries. Such factors must be considered in determining the
desired balance of impacts resulting from synfuels development.
Certain air emission control technologies such as scrubbers and wet
electrostatic precipitators generate sludge and/or consume water, which may
impact solid waste disposal or water resource constraints. Other technologies
such as the use of dry cooling equipment may improve emissions without imposing
constraints, but at a higher capital cost.
Plant siting options including off site processing and selective
development of coal deposits may improve air emissions and permit development
away from environmentally sensitive or non-attainment areas. Again economic,
social and other aspects must also be considered in recommending a balanced
resolution.
Wastewater treatment technologies may produce potentially hazardous
wastes such as sludge, spent carbon or ion exchange resin and may consume
water. Therefore, solid waste or water resource related constraints may
be impacted. Zero discharge may be required by regulations, or may be the
most cost effective means of achieving discharge requirements. If zero
discharge is attained by recycle/reuse options, pretreatment could produce
solid wastes and/or consume water as just mentioned. If evaporation is
accomplished by ponding; groundwater quality may be impacted and a solids
residual produced. Induced evaporation could consume large amounts of energy
and would also produce a solids residual.
Disposal of solid wastes by landfill or deep well injection could
ultimately affect groundwater quality. Detailed reporting and disposal
requirements for hazardous and non-hazardous wastes should minimize this
impact. Although insitu retorting of shale may exempt the inplace spent
shale from regulation under RCRA, the potential exists for groundwater
contamination by residual organics. This is especially true if groundwater
is in direct contact with the spent shale after the operation is abandoned.
Groundwater monitoring would minimize the risk of unchecked contamination
in this case.
27
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The potential of groundwater contamination may be increased by the
disposal of wastewater on ash or spent shale piles. However, the addition
of wastewater will suppress dust at the disposal site, allow for greater
compaction and longer site life and may cause a cementation reaction to
occur which could effectively seal the landfill. The adverse and beneficial
effects of this practice must be determined on a case by case basis.
Conclusions
This discussion illustrates that almost all of the solutions to the
identified resource and environmental constraints impact at least one
other area of constraint. In some cases the impact may be sufficient to
significantly increase the magnitude of the impacted area of constraint.
Therefore, each of the identified generic solutions and intermedia constraints
should be carefully considered for each site to achieve the desired balance
of impacts.
REFERENCES
1. Humm, W. R. and Seleg, E, Water Availability for Energy Industries in
Water Scarce Areas. U.S. Department of Energy, Contract No. EE-77-C-02-4534,
March, 1979.
2. USEPA, Process Design Manual for Phosphorus Removal, EPA 625/1-76-OOla,
April, 1976.
3. Peters, Terry, USEPA Criteria and Standards Division, Personal
Communication; July 29, 1980.
4. Wilber, Ruth EPA Monitoring and Data Division, Personal Communication;
July 29, 1980.
5. USEPA, National Water Quality Inventory, EPA-440/4-78-001, October, 1978.
6. Rudy, Dennis, USEPA Effluent Guidelines Division, Personal Communication,
July 31, 1980.
7. Environmental Protection Agency. Proposed Rules. Federal Register.
September 5, 1979, 44(173), p. 51924.
8. Page, Gordon C. and Hall, R., Continuous Monitoring for Specific Pollu-
tants in Coal Gasification Wastewaters. Presented at the Symposium on
Instrumentation and Control for Fossil Energy Processes, Virginia Beach,
Va., June, 1980.
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