United States      Industrial Environmental Research EPA-600/7-78-140
Environmental Protection  Laboratory         July 1978
Agency        Research Triangle Park NC 27711
A Program for the
Environmental
Assessment of
Conventional
Combustion
Processes
Interagency
Energy/Environment
R&D Program Report

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                RESEARCH REPORTING SERIES

Research reports of the Office of Research and Development, U.S. Environmental
Protection Agency, have been grouped into nine series. These nine broad cate-
gories were established to facilitate further development and application of en-
vironmental technology.  Elimination of traditional grouping was consciously
planned to foster technology transfer and a maximum interface in related fields.
The nine series are:

      1.  Environmental  Health Effects Research
      2.  Environmental  Protection Technology
      3.  Ecological Research
      4.  Environmental  Monitoring
      5.  Socioeconomic Environmental Studies
      6.  Scientific and Technical Assessment Reports (STAR)
      7.  Interagency  Energy-Environment Research and  Development
      8.  "Special" Reports
      9.  Miscellaneous Reports

This report has been assigned to the INTERAGENCY ENERGY-ENVIRONMENT
RESEARCH AND DEVELOPMENT series. Reports in this  series result from the
effort funded  under the 17-agency Federal  Energy/Environment Research and
Development Program. These studies relate to EPA's mission to protect the public
health and welfare from adverse effects of pollutants associated with energy sys-
tems. The goal of the Program is to assure the rapid development of domestic
energy supplies in an environmentally-compatible manner by providing the nec-
essary environmental data and control technology. Investigations include analy-
ses of the transport of energy-related pollutants and their  health and ecological
effects; assessments of, and development of, control technologies for energy
systems; and  integrated assessments of a wide range of energy-related environ-
mental issues.
                           REVIEW NOTICE

 This report has been reviewed by the participating Federal Agencies, and approved
 for publication. Approval does not signify that the contents necessarily reflect the
 views and policies of the Government, nor does mention of trade names or commercial
 products constitute endorsement or recommendation for use.
This document is available to the public through the National Technical Informa-
tion Service, Springfield, Virginia  22161.

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                                     EPA-600/7-78-140
                                              July 1978
A  Program for the Environmental
    Assessment of Conventional
        Combustion  Processes
                        by

       Deepak C. Kenkeremath, C. Grant Miller, and J. Bruce Truett

             The Mitre Corporation/Metrek Division
               1820 Dolley Madison Boulevard
                 McLean, Virginia 22101
            Contracts No. 68-01-3539 and 68-01-3188
                     Task No. 86
               Program Element No. EHE624A
              EPA Project Officer: Wade H. Ponder

           Industrial Environmental Research Laboratory
             Office of Energy, Minerals, and Industry
              Research Triangle Park, NC 27711
                     Prepared for

           U.S. ENVIRONMENTAL PROTECTION AGENCY
              Office of Research and Development
                  Washington, DC 20460

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                                 DISCLAIMER
     This report has been reviewed by the Industrial Environmental Research!
Laboratoryi Research Triangle Park, North Carolina,  U.S.  Environmental
Protection Agency, and approved for publication.   Approval does not signify
that the contents necessarily reflect the views' and  policies of'the U.S.
Environmental Protection Agency, nor does mention of trade names or commer-
cial products constitute endorsement or recommendation for use.
                                     ii

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                                  ABSTRACT
     Fossil fuels are now the nation's principal source of energy for industrial,
commercial, and residential use.  The conventional combustion of fossil fuels
and their derivatives is likely to remain our primary means of obtaining useful
energy for several decades.  EPA has, since its inception, conducted research
on the environmental effects of fossil fuel combustion.  The three principal
purposes of such research are (1) to assess the health and environmental effects
caused by the release of combustion pollutants, (2) to define the need for
technology to control the release of these pollutants, and (3) to develop
standards to limit emissions.

     In the past, much of EPA's environmental effects research has been per-
formed in conjunction with control technology development.  Recently, EPA has
established a program to consolidate the several segments of its research on
the environmental effects of pollutants from conventional combustion processes
into a comprehensive, integrated effort.  This report describes the development
and initial results of the Conventional Combustion Pollutant Assessment (CCEA)
program planning effort.
                                     iii

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                                ACKNOWLEDGMENT


     The wrifcetfs acknowledge with gratitude the many contributions of the
    £rojeet Officer* Mr* Wade Ponder, and Dr. William Thompson and Dr.
William Harrison of the Research Triangle Institute, to the technical content
aafl preagtttatibft fdrffiat of this report.  They wish to thank Mr. David Berg
df EPA's Office of fenergy, Minerals and Industry for his continued Interest
and guidance,  they are pleased to acknowledge the contributions of Mr.
Albert tie Agasio of the MITRE Corporation.                        ,

     The material in this report is also published as a MITRE/Metrek report
with the Baffle title. Report No. M-78-63.
                                     iv

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                              CONTENTS
Abstract	ill
Figures	vi
Tables	viii
   1.  Introduction  	   1
   2.  Purpose of the CCEA Program	   3
   3.  CCEA Program Plan	   6
   4.  Conclusions	   9
   5.  Recommendations	11
   6.  References	14

Appendices

   A.  CCEA Program Planning Effort  	  15
   B.  Description of CCEA Program Plan	26
   C.  Development of CCEA Goals and Objectives	40
   D.  Comprehensive Environmental Assessment Methodology  ....  46
   E.  Demonstration of Matrix Analysis Procedures 	  66
   F.  Alternative Management Structures for CCEA  	  82

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                                  FIGURES

Number                                                                   Page


 A-l  Conceptual diagram of CCEA program planning procedures 	  18

 A-2  Unified conventional combustion environmental assessment
        program planning 	  21

 B-l  Interrelations among long-term goals and intermediate
        objectives	29

 B-2  Comprehensive environmental assessment methodology — principal
        steps	30

 B-3  Comprehensive environmental assessment methodology 	'  .  33

 D-l.  Generalized environmental assessment methodology 	  48

 D-2  Combustion processes and effluent characterization (step one)  .  .  50

 D-3  Assessment of health and ecological impacts (step two) 	  52

 D-4  Health and ecological impacts identification (first activity,
        step two)	54

 D-5  Development of environmental goals and objectives (second
        activity, step two)	56

 D-6  Magnitude of pollution impacts (fourth activity, step two) ....  61

 D-7  Alternative control strategy evaluation (step three) 	  63

 D-8  Comprehensive environmental assessment methodology 	  65

 E-l  Matrix of environmental assessment elements  	  76

 E-2  Project information in matrix format 	  77

 E-3  Areas of apparent programmatic overlaps between projects nos. 2
        and 9	79

 E-4  Areas of apparent programmatic gaps in project nos.  2 and 9  ...  80
                                     vi

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                            FIGURES (continued)

Number                                                                   Page

 F-l  Alternative 1:  Existing structure	  84

 F-2  Alternative 2:  Existing structure plus advisory committee and
        working group	 . .'..  85

 F-3  Division level EA unit	.:-..".  87

 F-4  Alternative 4:  Executive committee and laboratory level 	  88

 F-5  Alternative 5:  Executive committee at headquarters level  ....  90
                                      vii

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                                      TABLES

Number                                                                          gag

 Ajcl Majo,r- Programmatic Areas Addressed  b,y CGEA Program ........  23

 Bpl' Majqr Brggranmatic Areas Addressed  by QCEA Program ....  .  .  .  .  35

 Bp2 Recommended Cqre GCEA  Projects  .  .  ,  ,  .  . .  .  .  .  ....  .  .  .  .  3§

 D^l S ample MEG  Chart . .  .  .  .  .  .  ..................  58

 Djz2 Sample MEG,  Background  Infarmation S.heet  .............  5§
 a-J^" i^,  wi*>*»vrj Jt, «r u .B^».J  u*^. vJ '-^r-" ^ t« •"*?  n^»* * ~J • •<* + -*-.«--••.  . ' • - ^ -_• -•  -. -  -  «  -  '   '  -  '  -  -  -  "  -^ •>

 Ejsl GGEA RrQ^ram Env'iro.nmental Assessment Element Gpde .   .  .  .  ....  67

 E-^2 En\riro,nmental Assessment Elements.   .  .  ......  .   .  .  .  .  .  .  .  68
       IJse S.ecto.r.,  Euels,, Ggmb.ustiQn Prgcess. Ty,p.e, Cp.mb^ustion Technology,
         and Pollutant Gateggries .  .  .  .  .  .  .  ....  .  .  . .  .  .  .  .  .  70,
  -,^,   Po,llutiqn  Gontrql Technology Gategor-ies  . ............  71


  ^5,   Disaggregated Project  Cojitent o,f Thirteen Recqmmended Cqre
  -tft  -*i   -H*-^H^V«'-y7'(S^ T.I^^-'-". W HJ— tl « ~"i"JJ •'-' •*!•«••  ."-"' .i. T- f •• - *» -,.' -  •> ---- •* M **,•.-'•- ' -. t. -^ »' ---- ..... * • V- wi •» «*-^-- — «-'
         Brojjects .  .. .  . .  .  .  .  .  .  .  .  .„  ....  ,  ,  ,  ........  72
                                        viii

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                                 SECTION 1

                               INTRODUCTION
     The United States uses more energy than any other nation—approximately
five times the amount used by Japan, the second largest energy user among
the nations of the free world.  In 1976 more than 74.3 x 1015 Btu (78.4 x 1018
joules) of energy were used in the U.S. to heat and cool buildings, to operate
transportation systems, and to power industry.   By 1985 this energy use is
expected to increase by nearly 20 percent and by the year 2000, the United
States is projected to increase its energy use to more than 100 x 10   Btu
(106 x 1018 joules).8

     Historically, fossil fuels have made up the largest segment of the na-
tion's energy resources.  In 1972, for example, fossil fuels supplied more
than 95 percent of the total U.S. energy use; even with the anticipated
growth in nuclear, solar, and geothermal energy sources, fossil fuels are
still expected to supply approximately 70 percent of the demand by the turn
of the century.   These values serve to illustrate the magnitude of this
country's current and future reliance on fossil fuels to supply its vital
energy needs.

     Conventional methods of converting fossil fuels to usable forms of energy
are not without associated environmental penalties.  The conventional combus-
tion of fossil fuel impacts upon all environmental media—air, land, and
water.  Most conventional combustion processes emit oxides of sulfur, oxides
of nitrogen, oxides of carbon, particulate matter, and other potentially
harmful pollutants to air.  In addition, solid residues from the combustion
processes or from associated control technologies (e.g., ash material or
sludge) pose solid waste disposal problems.  Leaching of chemical compounds
and heavy metals from the solid residues and oxidation of airborne pollutants
by rain may also result in adverse water related health/ecological effects.
To complicate matters, the effects of pollutants on air, land, and water are
not separate and distinct but are interrelated, involving delicate balances
and trade-offs.  For example, flue gas scrubbing to remove S02 and particulates
significantly increases the amount of solid wastes to be disposed.  The
physical and chemical characteristics of this sludge material must be care-
fully considered to insure that the method of disposal will not produce
still other undesired effects on the environment.

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     In addition to the direct environmental impacts mentioned above, indirect
impacts must also be considered in order to understand the total effect of
combustion pollutants on the environment and human health.  As an example,
sulfur dioxide released as a constitutent of the flue gas from many common
combustion processes can be transformed in the atmosphere to sulfates, which
can lodge in the respiratory passages of humans and animals, with deleterious
effects on health.  Comprehensive identification and assessment of these
multimedia and cross-media impacts, both direct and indirect, are essential
to the environmentally wise use and control of conventional, fossil-fueled
combustion processes.

     To meet the need for a comprehensive assessment of the environmental
effects of conventional combustion processes, the Environmental Protection
Agency's Industrial Environmental Research Laboratory at Research Triangle
Park (EPA/IERL-RTP), N.C., established a program for this purpose in February
1977.  This Conventional Combustion Environmental Assessment (CCEA) program
is chartered to assess comprehensively the effects of pollutants released
from conventional combustion processes and associated control technologies
on human health, the ecology, and the general environment, and to recommend
measures for controlling adverse effects within acceptable limits.   The
program concentrates upon stationary conventional combustion processes (SCCP)
in the utility, industrial, residential, and commercial use sectors.

     In the spring of 1977, IERL-RTP contracted with the Metrek Division of
the MITRE Corporation to assist in the preparation of an implementation plan
for the CCEA program.  Within the same time frame, IERL-RTP also designated
substantial segments of three ongoing, operational projects as a nucleus
of the new CCEA program.  Thus by mid-year 1977 the program had been set in
motion with an operational component and a planning activity.  Direction of
the program, since its beginning, has been assigned to the Utility and
Industrial Power Division of IERL-RTP.

     This report describes the development and initial results of the CCEA
program planning effort.
*Until the end of 1977,  the CCEA program was known as the Combustion
 Pollutant Assessment (CPA) program.

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                                  SECTION 2

                           PURPOSE OF CCEA PROGRAM
OBJECTIVES AND SCOPE OF THE CCEA PROGRAM

     The CCEA program is a unified, integrated program aimed at the comprehen-
sive assessment of the environmental, economic, and energy impacts of multi-
media emissions of pollutants from SCCP.  The program integrates relevant,
related R&D efforts into an overall environmental assessment structure, coor-
dinates their activities, and serves as a centralized base of information on
the environmental impacts of SCCP.   Coordination and information exchange
between CCEA activities help reduce duplication of effort and increase the
return from available resources.

     The principal objectives of the CCEA program are to identify and assess
information from all relevant sources in order to:

     (1)  determine the extent to which available information can be utilized
          to assess the total environmental, economic, energy impacts of SCCP.

     (2)  identify and acquire additional information needed for such assess-
          ment .

     (3)  define the requirements for modifications or additional development
          of control technology.

     (4)  define the requirements for modified or new standards to regulate
          pollutant emissions.

The results of the CCEA program are aimed at providing a base of sound infor-
mation for use by energy/environmental decision-makers for:

     •  Standards Setting

     •  Control Technology Development

     •  Policy Formulation

     •  Resource Allocation

     Although the program is comprehensive in its approach and subject matter,
there are some major boundaries that shape and focus the efforts of the program.
The scope of the CCEA program can be briefly delineated as follows:

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     e  The program is concerned with SCCP, and is focused principally on
        equipment and combustion processes used in the utility, industrial,
        commercial/institutional, and residential sectors.

     •  The program addresses environmental effects that result directly from
        the operations of the combustion process itself, as well as those that
        result from the operation of equipment to control the release of
        pollutants from the combustion process, such as leachate from flyash
        impoundment basins.

     •  The program addresses non-environmental criteria such as social,
        economic, and political/institutional effects.

     •  The program also addresses environmental effects from the conventional
        processing and storage of fuels at the combustion site, such as the
        crushing of coal at a power plant.

     •  The program does not address the effects of fuel processing and
        storage prior to delivery to the combustion site, or during trans-
        portation of the fuel.

     •  The program addresses environmental effects of utilizing synthetic
        fuels in conventional combustion equipment.

     •  The program does not address the environmental effects of converting
        fossil fuels to synthetic fuels, whether performed at the combustion
        site or elsewhere; thus it does not include consideration of the
        impacts of low-Btu gasification of coal when the gasification equip-
        ment is within the battery limits of the power plant where the gas is
        burned.

     e  The program is not directly involved in design or development of
        combustion processes or pollution control technologies.

     •  The program is not directly involved in the setting or enforcement of
        emission standards.

     It is expected that as this program succeeds in achieving its objectives,
it will serve as a model for the comprehensive environmental assessments of
other energy and industrial related areas.


DEFINITION OF ENVIRONMENTAL ASSESSMENT

     An Environmental Assessment (EA) is among the new categories of investi-
gative studies being conducted as a result of the growing awareness of the
direct and indirect environmental consequences of modern technology.  The
Energy Assessment and Control Division (EACD) of IERL-RTP has developed a
working definition of an environmental assessment that is gaining wide accep-
tance by the research community.  For EPA and its contractors, an environmental
assessment of fossil-fueled processes is defined as "...a continuing iterative
study aimed at:

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     "(1)  determining comprehensive multimedia environmental loadings and
           environmental control costs,  from the application of existing and
           best future definable sets of control/disposal options,  to a
           particular set of sources, processes, or industries; and

     "(2)  comparing the nature of these loadings with existing standards,
           estimated multimedia environmental goals,  and bioassay specifica-
           tions as a basis for prioritization of problems/control needs and
           for judgment of environmental effectiveness."4

     The CCEA program extends this definition to include the identification
and assessment of the full range of health,  ecological,  and environmental
effects.  Hence under this program, the  environmental assessment includes
socio-economic and institutional effects,  and cross-media impacts and trade-
offs, in addition to the environmental loadings data,  control costs,  disposal
options, bioassay specifications, and other  factors included in the above-
quoted definition.  It must be emphasized, however, that environmental assess-
ment activities of the CCEA program do not involve either the development or
promotion of the combustion process or the development or promotion of tech-
nology to control emissions from the combustion process.

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                                  SECTION 3

                              CCEA PROGRAM PLAN
COMPONENTS OF THE PROGRAM PLAN

     The CCEA program,  in its current stage of development,  consists of
four major components.   These four components are interrelated and should be
considered in the context of the overall CCEA program.

     The first major component is an initial set of long-term goals and inter-
mediate-term objectives for the CCEA program.  These goals and objectives
reflect lERL-RTP's role in EPA's mission to protect human health, ecology,
and the general environment from the adverse effects of conventional combus-
tion.  These goals and objectives have been defined in a manner that provides
clear direction to the CCEA program yet allows the flexibility to address,
within the context of the program, special priority concerns (such as newly
suspected carcinogens or mutagens) as they are identified by the research
community.

     The second major component of the program plan is a methodology for
comprehensively assessing the environmental effects of SCCP and their pollu-
tants.  This methodology, employed within the context of the overall CCEA
goals and objectives, is a blueprint to systematically identify and evaluate
approximately 200 different items of information in conducting an environ-
mental assessment.  It is structured in a manner to maximize coordination and
information exchange between R&D efforts that are simultaneously addressing
different aspects of the subject area.  The time required to conduct a compre-
hensive environmental assessment is thus shortened and the results of the R&D
efforts are used to a wider extent.

     The third major component is a detailed procedure to analyze and compare
the programmatic contents of relevant ongoing and planned R&D projects and to
integrate these projects into the CCEA program.  This analytical procedure
(termed the EA Matrix Analysis Procedure) relies heavily on the environmental
assessment methodology mentioned above in its project analysis and integration
technique.

     The fourth major component of the CCEA program plan is a set of recommen-
dations for implementing the other three components in such a way that together
they will produce a comprehensive assessment of the health, ecological, and
environmental effects of SCCP*  This fourth component is comprised of
four separate but related subcomponents, namely:  (1) recommendations for a
management structure within EPA for administering the CCEA program; (2) recom-
mendations for "core" projects to be initially integrated into the CCEA program;

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(3) recommendations for refining, expanding, and implementing the analytical
techniques/procedures  and methodologies developed in this planning effort,
and (4) recommendations on guidelines for the procurement of a major systems
contractor to assist EPA in conducting the program.   This last subcomponent
has already been submitted to EPA under separate cover and will not be dis-
cussed in this report.

     A brief overview of the four components of CCEA program plan is presented
in Appendix B.  The technical details, rationale, and other salient points
of each of the four components are presented in Appendices C, D, E, and F.
POTENTIAL BENEFITS OF CCEA PROGRAM PLAN

     Each component of the plan has been designed to provide a firm framework
for the conduct of the environmental assessment while containing the degree
of flexibility necessary for the day-to-day implementation of the program
plan.  The major potential benefits of each component of the CCEA program
plan are listed below.

Goals and Objectives

     •  Goals and objectives are structured at two levels:   major, long-term
        goals  and intermediate objectives that contribute toward the accom-
        plishment of major goals.  The products associated with most of the
        objectives represent useful outputs in themselves,  and can be benefi-
        cially used for a variety of purposes.   For example, one objective
        is to establish an SSCP pollutant data base.  This product could be
        widely used for many purposes not directly related to the CCEA program.

     •  The major goals of the program are defined as separate, although
        interrelated, entities that can be addressed by separate projects.
        These projects can, in most instances, be performed concurrently,
        thus reducing the time needed for accomplishing all goals.  The same
        is true for most of the intermediate objectives.

Environmental Assessment Methodology

     •  The methodology provides a generalized structure into which the
        diverse activities associated with environmental assessment can
        be systematically incorporated.  This structure outlines the inter-
        relationships among the various activities that are a part of
        environmental assessment, and provides channels of communication
        for involved scientists and engineers in various disciplines.

     •  The methodology represents a comprehensive approach to environmental
        assessment, in contrast to many earlier programs that addressed only
        limited aspects of environmental assessments.

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         The methodology  is  designed  to  allow many of the various  activities
         that  constitute  an  environmental  assessment  to be  performed  simul-
         taneously,  thereby  reducing  the overall  time needed  to  complete  the
         assessment.  This characteristic  of the  methodology  also  encourages
         the documentation of  intermediate results as they  are completed,
         thereby permitting  timely  dissemination  and  transfer of such results
         to the concerned research  community.

         Although  the methodology is  currently designed for an environmental
         assessment  of  SCCP, it  can readily be modified to  address other  major
         energy and  industrial technologies.  The specific  techniques,  proce-
         dures, and  models developed  for use with SCCP can  possibly be utilized
         immediately in other  major ongoing R&D programs, thus reducing the
         time  and  resources  required.
Environmental Assessment Matrix Analysis Procedure

     •  Two or more similar ongoing or proposed projects can be compared
        with the aid of this procedure to identify potential areas of pro-
        grammatic overlap.   If detailed examination verifies this overlap,
        then actions, including project redirection, could be taken to resolve
        the situation and to increase the return from available resources.

     •  The programmatic content of the complete set of projects included
        in the CCEA program can be compared with the elements comprising the
        comprehensive environmental assessment methodology to identify
        important areas where no R&D effort is currently ongoing or planned.
        Projects to perform the desired activities can then be initiated.

     •  In many cases, the results of one project are a direct input to the
        activities of another.  When the matrix analysis procedure identifies
        two or more projects addressing similar or related areas, the mile-
        stones and schedules can be compared and coordinated to insure that
        necessary information is made available to each project in a timely
        manner.

     •  The matrix format permits decision-makers to quickly and efficiently
        identify all projects in the program that address similar subject
        areas or environmental assessment elements.  Thus, for R&D efforts in
        a specified area, the matrix format could be used to identify all
        current projects and their activities addressing the area.  Such
        information would be useful in the planning effort to utilize the
        results of other projects to a greater extent.

     •  The matrix format also permits decision-makers to quickly and readily
        identify all R&D currently being conducted that relate to a specific
        pollutant, fuel, control technology, combustion technology/process
        or media.  If all data currently being developed on hydrocarbons (HC)
        were needed, for example, the matrix format would quickly identify
        the R&D activities involving HC and the specific projects involved.
        Direct review of these projects and activities would simplify the
        data acquisition and evaluation effort.
                                      8

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                                  SECTION 4

                                 CONCLUSIONS
     In the course of performing the CCEA program planning activity, several
conclusions that significantly focused the development of the overall CCEA
program implementation plan were made.  These conclusions are categorized
into three general activity areas and listed briefly below.   The assumptions
and rationale for these conclusions are discussed in detail in the
appendices.
CONCLUSIONS RELATED TO THE NEED, FUNCTIONS, AND USES OF THE CCEA PROGRAM

     •  A major effort is required to acquire and analyze existing data on
        the impact of pollutants released from SCCP and associated control
        technologies, and to supplement this data base with new or updated
        information to assess fully the total environmental effect.  Examina-
        tion of available sources of information and proposed and ongoing
        research indicates that a substantial base of useful information
        already exists^; however, these sources are quite specialized and
        dispersed, and the data are not of uniform quality for unambiguous
        interpretation.

     •  A comprehensive environmental assessment program must include major
        efforts on health and ecological impacts, environmental economics,
        energy requirements, and social/political/institutional constraints
        and impacts.  Evaluation of relevant projects within IERL-RTP indicates
        that their primary emphases have been control technology evaluation
        and emissions characterization.

     «  An integrated program is indeed required now to coordinate separate
        R&D efforts, to increase information exchange, and to develop needed
        data in a timely manner.  Evaluation of major projects in the environ-
        mental assessment of SCCP indicates that most projects are initiated
        and executed independently of other related or similar efforts; infor-
        mation exchange between these projects is generally minimal.

     •  The goals of a comprehensive environmental assessment program must
        include the assessment of the need for new or modified control
        technologies and emission standards.  The majority of the programs
        in this subject area merely develop data that form the base of
        information.  This information must be analyzed and specific
        recommendations in priority order must be developed to support the
        environmental assessment goals.

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CONCLUSIONS RELATED TO MANAGEMENT ORGANIZATION

     o  The present organizational structure  at  IERL-RTP  is not  ideally suited
        to managing a  broad multi-project program to achieve  the required degree
        of integration and coordination.  Projects  included in the CCEA program
        are currently  being conducted and managed by three divisions within  IERL-
        RTP.  Current  lines of reporting are  too rigid and circuitous  for
        efficient  program implementation and  management.

     •  IERL-RTP has currently not committed  sufficient staff for the  efficient
        and effective  development and implementation of a program of this
        magnitude, complexity, and importance.  The implementation of  this
        program requires the  coordination of  a host of projects as well as
        substantive and constant communication with project officers of EPA
        and non-EPA projects  of relevance to  the program, several contractors,
        and outside experts.  In addition, in-house expertise in a variety of
        subjects is necessary to evaluate and guide the progress of the program.
        Such personnel resources are not currently  available.

     •  Funding channels for  the major portions of  CCEA should be centralized.
        An important option for implementing  and guiding  the  program includes
        the ability to institute modification or redirection  of  ongoing R&D
        projects.  If  funding channels for the major projects are not  central-
        ized the program manager will not have the necessary  support to coor-
        dinate and redirect such projects.


CONCLUSIONS RELATED TO METHODOLOGIES, TECHNIQUES AND PROCEDURES OF THE CCEA
PROGRAM

     •  A detailed and explicit methodology for conducting a  comprehensive
        environmental  assessment of SCCP must be adopted within EPA.   Sub-
        stantial work  has been completed and  is ongoing in developing
        environmental  assessment methodologies.  These various methodologies
        should be  evaluated,  expanded, and supplemented to provide the range
        and degree of  guidance required for a comprehensive,  unified effort.
        The present report describes a methodology that has proved useful in
        developing the CCEA program.

     •  A detailed and explicit procedure to  evaluate and integrate relevant
        projects is necessary to efficiently  implement the CCEA program.  Due
        to the range and depths of topics addressed by the projects included
        in this program, evaluation and comparison between projects is at best
        difficult  and  complex.  An explicit procedure to facilitate compara-
        tive evaluation and project integration is needed.

     •  A technique to rank relevant projects in priority order within the
        context of the CCEA program goals and objectives is also needed.
        External factors such as budgetary constraints, congressional mandates,
        or newly identified health/ecological concerns may effect a change in
        emphasis in program content and direction.  The required priority-
        ranking technique must consider these factors in establishing priori-
        ties among projects.
                                     10

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                                 SECTION 5

                              RECOMMENDATIONS
     The overall goal of this program planning effort is the development of
a set of methodologies, analytical procedures, and recommendations to assist
EPA in the implementation and management of the CCEA program.  As a package,
these outputs comprise the program plan in its current stage of development.
Recommendations that have resulted from the program planning effort are listed
below.  These are arranged under the headings of the four major components of
the program plan identified in Section 3.  The assumptions and rationale
underlying the recommendations are discussed in the appendices.

RECOMMENDATIONS RELATED TO GOALS AND OBJECTIVES OF THE CCEA PROGRAM

     •  The goals and objectives of the CCEA program, as stated in this
        report, should be thoroughly reviewed by EPA management at the
        division (utilities and Industrial Power Division), the laboratory
        (IERL/RTP), and the headquarters (Office of Energy, Minerals, and
        Industry) levels to insure consistency with missions, policies, and
        objectives at each of these organizational levels, and to determine
        whether the stated goals and objectives adequately support such
        missions and policies.

     •  Following the reviews, the CCEA program manager should issue a
        document summarizing the program goals and objectives that received
        concurrence and support.

RECOMMENDATIONS RELATED TO THE COMPREHENSIVE ENVIRONMENTAL ASSESSMENT
METHODOLOGY USED IN THE CCEA PROGRAM

     •  The CCEA program manager should assemble a panel of environmental
        experts to review the EA methodology presented in this report, to
        insure completeness and unity.

     •  The CCEA program manager should initiate efforts to insure that
        detailed (and standardized) analytical tools are available to
        address the various programmatic areas of the EA methodology.

     •  The Director of IERL-RTP should assemble a panel of experts to
        ensure compatibility between the environmental assessment methodology
        employed by the CCEA program and the one developed by EACD, IERL-RTP,
        and to promote the agency-wide adoption of a unified approach.
                                     11

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        The CCEA program manager should initiate an effort to ensure that
        CCEA contractors and other concerned environmentalists are informed
        of and utilize EPA methodologies and standardized analytical proto-
        cols, techniques and procedures where appropriate (e.g., Level 1,
        Level 2, Level 3 Analysis or SAM/IA, SAM/I, SAM/II).5.6

        The CCEA program manager should establish a data base of information
        (from available sources) needed to implement the environmental assess-
        ment methodology described in this report and provide for continued
        updating of this data base.
RECOMMENDATIONS RELATED TO THE MATRIX ANALYSIS PROCEDURE USED IN THE CCEA
PROGRAM

     •  The CCEA program manager should instruct an appropriate contractor
        to modify the matrix analysis procedure developed by the present
        effort for use in a computer system, thereby providing EPA a highly
        useful management tool.  The following actions should be included
        in this effort:

           -  The Project Information Checklist should be revised to
              facilitate information acquisition and computer storage.

           -  A detailed coding for this information should be developed.

           -  The computer system should be programmed by key words,
              programmatic areas, projects, or organization to provide a
              variety of information searches and displays.

           -  The computer system should be programmed to automatically
              ignore impractical or unreasonable combinations of program-
              matic areas in its searching methods (e.g., ignore SOX when
              searching for studies involving the use of SNG in SCCP).

     •  The CCEA program manager should instruct the  appropriate contractor
        to revise the matrix analysis procedure,  as necessary,  to  be
        responsive to the evaluation and integration  of the core projects
        finally selected by EPA for inclusion in the  CCEA program.


RECOMMENDATIONS RELATED TO THE IMPLEMENTATION AND MANAGEMENT OF THE CCEA PROGRAM

     •  EPA should establish an organizational structure for CCEA program
        management that provides:   (1)  a full-time program manager,  fully
        dedicated to the tasks of directing the program, (2) an adequate
        level of staffing to support a program of this size, (3) direct
        liaison with project officers of all EPA projects that fall within
        the purview of the CCEA program, (4) channels of communication
        to principal users of the products of this program, and (5)  an
        advisory group to consult and provide technical and management
        support to the program manager.  A recommended organizational
        structure is described in Appendix B.
                                     12

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•  EPA should obtain the services of a systems support contractor
   to assist in the implementation of the CCEA program.

•  EPA should consolidate the funding of projects and other R&D
   activities that fall within the CCEA program.   This action should
   include provisions for technical and budgetary review and approval
   of such projects/activities by CCEA program management.

•  The present CCEA program management should schedule periodic briefings
   and seminars at IERL/RTP and EPA Headquarters  to inform  management and
   technical personnel of the status and accomplishments of the program.
                                13

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                                 SECTION 6

                                 REFERENCES
1.  Independent Petroleum Association, "Report of the Supply and Demand
    Committee," 1976.

2,  M. Beller, ed, , Spureebppk for Energy Assessment, Brpokhaven National
    Laboratory, BNL-5(3483,""197Y.™ ......................

3.  Energy Researeh & Development Administration, "Inventory of Federal
    Energy-Related Environment & Safety Research for FY 1976," Volume 1,
    April 1977.

4.  R. P. Hangebrauek, "Briefing Notes for Meeting with ERDA, Fossil Energy,"
    in-house document, EPA/ Indus trial Environmental Research Laboratory,
    Researeh Triangle Park, N.C., May 17, 1977.

|.  J. Pprsey, L. Jphnspn, R. Statnick, and C. Lpchmuller, Environmental
    Assessment Sampling and Analysis;  Phased Approach and Techniques for
    Level ..... 171re^60W2^77^^
6.  J. Cl eland and G, Kingsbury, Multimedia Environmental Goals for Environ-
    mental Assessment, Volumes j and~Tl"7TEM^
    PO769T972T6920) , November 1977.

7.  W. E, Thpmpspn and J. W, Harrison, Survey of Prpjects Concerning Conven-
    tional Combustion Environmental Assessment's, lleseareh Triangle Institute,
8,,  Executive Office of the president. Energy Policy and Planning, The National
    Energy Plan, U. S . Gover-nment Printing Office , Washington , D, . C . , April 197 7 .
                                      14

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                                APPENDIX A

                        CCEA PROGRAM PLANNING EFFORT


A.   OBJECTIVES OF THE PROGRAM PLANNING EFFORT

     The general objectives of the program planning effort are to:   (1) develop
a coherent, unified methodology for comprehensively assessing the health, eco-
logical, and environmental effects of burning fossil fuels in SCCP, (2) de-
fine long-term goals and short-term objectives for the CCEA program, and (3)
recommend a management plan for implementing the program.

     Several intermediate objectives for the planning effort were established
as steps toward the accomplishment of the general objectives stated above:

     •   Definition of a comprehensive environmental assessment methodology
         detailing its major components.

     •   Identification of on-going projects, within EPA and elsewhere, having
         components relevant to the environmental assessment of SCCP.

     •   Development and demonstration of a procedure or system for analyzing
         the programmatic contents of on-going and future CCEA-related projects
         to identify areas of overlap or omission, and to integrate such
         projects into the unified CCEA program.

     •   Recommendations for the types of information to be produced by envi-
         ronmental assessment projects.

     •   Identification of major needs and potential uses for environmental
         assessment results.

     •   Development of guidelines for securing a systems contractor to
         assist EPA in implementing the CCEA program.

     •   Recommendations for an organizational structure within EPA for imple-
         mentation and management of the CCEA program.

         The specific program planning approach adopted in this effort is
designed to be responsive to the achievement of the above goals and objectives.


B.   SCOPE OF PROGRAM PLANNING EFFORT

     This program planning effort is in support of the actual implementation

                                     15

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 of the CCEA program.  The present effort does not implement the program, but
rather provides general methodologies, procedures/techniques, and recommen-
dations to be used by EPA and a major systems contractor in accomplishing the
objectives of the overall CCEA program.  These methodologies and procedures/
techniques are demonstrated in this report by application to selected projects.
 Recommaidations are also made in the selection of projects for integration into
the CCEA program.  The final selection, evaluation, and integration are to be
accomplished by EPA through its system contractor.

      Although the major procedures/techniques and methodologies that result
from this planning effort were developed primarily by MITRE, the overall pro-
gram plan represents the combined work and thinking of IERL-RTP (through its
designated CCEA project officer), Research Triangle Institute (RTI), and the
 MITRE Corporation.  The CCEA project officer provided direction and guidance
in focusing the program plan to meet EPA needs, while RTI assumed responsi-
bility in providing necessary information on relevant projects being conducted
in the subject area.

      An initial constraint on the planning effort was that existing data, on-
going projects, analytical techniques, and assessment/evaluation procedures be
incorporated into the CCEA program plan to the maximum extent practical.  This
greatly reduced the amount of detailed work to be done in formulating the en-
vironmental assessment methodology, since substantial progress has been made
in this area.  Similarly, the effort required for conducting the environmental
assessment is greatly reduced, since a substantial base of data is now available
and is currently being expanded through ongoing projects.  However, the process
of developing an implementation plan for efficiently coordinating the ongoing
efforts, both in data development and procedure development, is complicated by
the fact that ongoing projects highly relevant to the CCEA program have varying
objectives and scopes and utilize varying experimental/analytical techniques
and assessment/evaluation procedures.  Analysis and comparative evaluation of
the programmatic contents of these projects to develop a unified program is
hampered by the lack of standard approaches.  The development of a management
structure to administer the program is also complicated by the fact that data
utilized in the CCEA will not only be those within IERL-RTP, but also those in
other parts of EPA. In addition, information developed by projects external to
EPA will also be important in conducting the environmental assessment.
C.   METHOD USED IN FORMULATING THE CCEA PROGRAM PLAN

     At the beginning of the program planning effort, it was clear that IERL-RTP
was performing several R&D projects that would fit totally into the scope of
the unified CCEA program; also portions of other projects would logically be
included.  The number of EPA projects in either category was not clearly identi-
fied when the planning effort began.   Projects of similar nature being per-
formed by other parts of EPA or organizations outside of EPA were even less
clearly identified.  The program planning technique or procedure, therefore,
had to include the full range of activities from identifying relevant studies
to recommendations for administrative management of the overall CCEA program.

     The planning, procedure for the CCEA program is described below both in
conceptual form and in terms of specific task activities actually undertaken
in the planning effort.
                                      16

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1.   Conceptual Description of the Planning Procedure

    The approach used in formulating the CCEA program plan can be described
in terms of the somewhat idealized steps described below.

    First, define goals and objectives of the CCEA program.

    Goals are defined on the basis of existing or anticipated standards for
    regulated pollutants and processes; acceptable ambient or emission
    levels for pollutants not currently regulated; control equipment capa-
    bilities and costs; health and ecological effects; and defined EPA
    responsibilities for controlling the environmental effects of SCCP.

    Second, identify ongoing and planned projects pertaining to a conventional
    combustion environmental assessment within EPA and other organizations.

    This can be done by a survey of R&D work within IERL-RTP, EPA and other
    Federal and non-Federal organizations.  An initial survey of this nature
    was performed concurrent* with the program plan development.

    Third, evaluate the content and anticipated outputs of identified projects
    in terms of their relevancy for achieving defined goals of the CCEA program.

    This step requires a procedure or technique for analyzing and evaluating
    the content of each project relative to the completeness of the CCEA
    program.  Such a procedure was developed in conjunction with the program
    planning effort.  The procedure will also aid in identifying gaps and
    overlaps among selected R&D projects.

    Fourth, integrate the content and anticipated outputs  of selected ongoing
    and planned R&D projects, and compare the overall results with the defined
    goals and objectives of the program.

    This step also requires a procedure or technique for interrelating and
    integrating the anticipated accomplishments of relevant  R&D projects
    and programs, and for comparing their results with the requirements for
    meeting CCEA program goals.

    If the comparison at some specific time indicates that all defined goals
    are met, the program is complete.  In the more likely  circumstance that
    all defined goals are not met by identified projects,  the comparative
    technique will indicate directions for additional R&D  efforts needed to
    accomplish the goals.

    Fifth, redirect R&D effort to fill identified omissions  or to establish
    new R&D directions to more nearly accomplish defined goals.

    The sequence of planning steps is outlined diagrammatically in Figure A-l.
*The survey was conducted by Research Triangle Institute.
                                     17

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      DEFINE GOALS AND
      OBJECTIVES OF
      CCEA PROGRAM
                                                             IDENTIFY ALL CCEA-
                                                             RELATED PROJECTS/
                                                             ACTIVITIES
00
                                                                      ANALYZE CONTENT/OUTPUT OF
                                                                      REVELANT PROJECTS*
                                                                        -individual project basis
                                                                        -aggregated over all
                                                                         projects/activities
COMPARE AGGREGATED PRODUCTS
OF EXISTING/PLANNED
ACTIVITIES VERSUS DEFINED
GOALS AND OBJECTIVES*
                                        IDENTIFY NEW OR
                                        REDIRECTED R&D ACTIVITIES
                                        NEEDED TO MEET GOALS/
                                        OBJECTIVES
                                                               *Requires development
                                                                of analytical methodologies
                      Figure A-l.  Conceptual diagram of CCEA program planning procedure.

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      Each of the above steps can be performed at various levels of detail.
 For example, the first step — defining goals and objectives —  may be con-
 sidered in terms of meeting all applicable existing standards on a nationwide
 basis,  or it may be considered in terms of meeting a set of "Multimedia En-
 vironmental Goals" (MEG)* for a specific chemical compound.  Similarly, the
 third step — evaluation of project content and output — may consider only
 technical factors that affect human health and ecology.  Alternatively, the
 analysis performed in this step may be extended to include second order
 social and economic effects such as increases in the cost of electric power
 that result from the costs of pollution control requirements.

      The planning procedure outlined in the foregoing series of steps and in
 Figure A-l is iterative in nature.   It can be performed initially at a general
 level,  then iterated to more detailed levels as additional information becomes
 available.  It can also be readily adapted to be responsive to new circum-
 stances such as new or revised standards.

      It may be noted that two of the steps listed above require an analytical
 procedure or technique.  In step three, such a procedure is needed for ana-
 lyzing program content.  In step four, an analytical procedure is needed for
 comparing R&D accomplishments with program goals.  The development of these
 procedures, which are described in detail in Appendix E, has constituted
 a substantial part of the program planning effort.

      2.  Detailed Program Planning Procedure

      In practice, the actual planning process for the CCEA program proceeded
 somewhat differently from the highly conceptual approach outlined above.  The
 initial step was the inventory of potentially relevant R&D projects,**and the
 selection of subsets of highly relevant projects for detailed analysis.  Fol-.
 lowing that, a procedure was developed for analyzing, comparing, and inte-
 grating the contents of R&D projects.  The program planning procedure con-
 sisted of eight steps, or tasks:

 1.  Review of Estisting EPA/IERL-RTP CCEA Projects

 2.  Identification and Evaluation of Related Projects by Other Organizations

 3.  Disaggregation by Relevant Project Activities Within Environmental Assess-
     ment Functional Categories

 4.  Structured Aggregation of Relevant Project Activities Within Environmental
     Assessment Functional Categories
 *MEGs are emission or ambient level goals based on either control technology
 capabilities or on health and ecological effects.   IERL-RTP is currently de-
 veloping MEGs for approximately 350 organic and 300 inorganic substances.

**Perforraed by Research Triangle Institute, Final Report available from
 EPA/IERL-RTP.
                                      19

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5.  Current Environmental Information Base

6.  Development of Goals and Objectives for Unified CCEA Program

7.  Evaluation of Integrated Existing CCEA Program

8.  Development of Unified CCEA Program Plan.

Each of the steps involves a number of ancillary activities.  The relation-
ship among the principal steps and their ancillary activities is shown dia-
grammatically in Figures A-2(a) and A-2(b).

     Task 1 involves the review of ongoing CCEA-related projects at EPA/IERL-
RTP to identify their specific objectives, activities, milestones, and
schedules.  Simultaneous with Task 1, Task 2 identified, acquired, and re-
viewed information on past and ongoing combustion assessment-related pro-
jects outside of EPA/IERL-RTP to determine possible informational/program
links with CCEA.  Organizations surveyed within EPA included:  Office of
Energy, Minerals, and Industry (OEMI);  IERL at Cincinnati; Office of Air
Quality Planning and Standards (OAQPS);  and EPA Regional Offices.  Organi-
zations surveyed outside of EPA included:  Department of Energy (DOE) (Energy
Research and Develpment Administration [ERDA]); Electric Power Research Insti-
tute (EPRI);  Tennessee Valley Authority (TVA);  Edison Electric Institute
(EEI);  Department of Commerce (DOC);  Office of Science, Technology, and
Policy (OSTP);  Department of Agriculture (DOA); Department of Health, Educa-
tion, and Welfare (HEW); and the National Science Foundation (NSF).

     The information identified in Tasks 1 and 2 as being relevant to the
unified CCEA program is analyzed in Task 3, where specific activities of the
relevant projects are disaggregated into generic environmental assessment
"functional categories."  Functional categories are specific technical areas
that are addressed by the project(s) being analyzed.  Such categories are
intended to aid in defining the technical content of the project.   Although
the concept of functional categories was established and used early in the
program planning effort, specific functional categories were only vaguely de-
fined at that time.   In later stages of the planning effort, it became neces-
sary to develop concrete lists of functional categories in order to disaggre-
gate and analyze the content of specific projects.  The current listing of
functional categories is shown in Table A-l.   Project activities addressing
similar subjects or involving similar efforts in the various combustion as-
sessment-related projects are then separated for comparative evaluation.

     In Task 4, these activities are assembled into a logical environmental
assessment matrix structure designed to facilitate comparison between indi-
vidual projects, and between the aggregate of all projects and the require-
ments for meeting defined goals and objectives.  By such structured inte-
gration, the basic characteristics of the unified CCEA are delineated and
the relationships between the activities of the various programs identified.

     Concurrent with the integration of relevant projects into environmental
assessment functional categories, two independent tasks were conducted to
develop the goals and objectives of the expanded, unified CCEA.   In Task 5,
                                    20

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TASK

/
           IDENTIFICATION
          MO EVALUATION OF
        RELATED PROGRAMS(OEM).
      IERL-CIM.OAOn.ERDA.TVA. DOC
           . 05TP. EM-REGIONAL
          OFFICE!. OTHERS!
TASK 4

/
                                                                                    I
                                                                                TO TASK  7
                                                                             (Figure A-2(b))
Figure A-2(a).   Unified conventional combustion environmental  assessment  program planning.

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                                                                          TASK 7
  FROM  TASK 4
(Figure A-2(a))
      .1.
NJ
t-0
                                                                                     Modrf.cstton,
                                                                                    Of Existing Propels
                                                                                    -Scirem.nu-OI Work
                                                                                     -Milimnn
                                                                                     -Schtduln
               Figure A-2(b).   Unified  conventional combustion  environmental assessment  program  planning.

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TABLE A-l.   MAJOR PROGRAMMATIC AREAS ADDRESSED BY CCEA PROGRAM

    •  Combustion Process Technology Background
    •  Development of Sampling  and Analysis Techniques
    •  Fuels Characterization
    •  Input-Output Characterization
    •  Field Tests and Surveys
    • . Pollutant Transport,  Transformation, and Fate Models
    •  Dose-Response Data
    •  Ecological Impacts
    •  Epidemiological Data
    •  Bioassay Data
    •  Emissions or Ambient Level Goals
    •  Social/Economic/Political/Institutional Considerations
    •  Statutory Constraints
    •  Ambient Pollutant Levels
    •  Combustion Process Use Projections
    •  Total Pollutant Load Calculations
    •  Synergistic and Multimedia Impacts
    •  Regional Geographic Data
    •  Pollutant Priority Rankings
    •  Control Alternatives
    •  Control Strategy Environmental Impacts
    •  Control Strategy Evaluation
    •  Standards Development Recommendations
    •  Control Technology Development Recommendations
                             23

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an information base of the current environmental background was established.
(The content of this information base is, however, continuously evolving.)
The information base includes data on existing and proposed environmental re-
gulations, health/ecology impacts, state-of-the-art of associated control
technologies, and environmental modeling.  This information was analyzed and
utilized in Task 6 to develop the proposed goals and objectives of the ex-
panded, unified CCEA program.  Goals and objectives for standards recommen-
dations, control technology development recommendations, and technology trans-
fer activities were formulated.  Administrative and organizational goals for
the implementation of the unified CCEA program plan were also developed in
Task 6.
     The aggregated activities of the existing combustion assessment projects
are integrated into functional categories in Task 4 and then evaluated in
Task 7 with respect to the defined CCEA goals and objectives.  By such a com-
parative evaluation, gaps within the coverage of the existing structure can
be identified.  Duplications or overlaps among the various existing projects
as well as possible incompatibilities in scheduling can also be identified
within this task.

     The results of the comparative evaluation of Task 7 provide guidance
for redirecting existing projects to eliminate unwarranted overlaps and for
augmenting the existing program to insure that all critical R&D areas are
addressed.  Identification of duplicate activities, with a view toward eli-
minating unwarranted overlaps, is considered a matter of some urgency, since
it could result in substantial savings of resources.  The use of the afore-
mentioned analytical procedures for this purpose is demonstrated in
Appendix E.

     In Task 8, the comparison is made at a higher level.  Here, the functio-
nal categories and their constituents for all CCEA projects are compared
against the program's goals and objectives to determine whether the current
and planned program content is generally on target and to develop guidance
concerning the adequacy and deployment of resources.  This step has not yet
been performed in a comprehensive manner because of the volume of infor-
mation to be accumulated, processed, and analyzed for its detailed imple-
mentation.  However, the analytical techniques of this planning procedure
were used to review the content of some 30 major projects considered highly
relevant to the CCEA program.  The results of this review and analysis have
provided guidance in formulating a unified and comprehensive program and in
planning for the implementation of the program.   In particular, the results
of the comparative evaluation formed the basis for defining the scope of
work,  including the identification of specific outputs and milestones to
support the achievement of detailed goals and objectives, for a systems sup-
port contractor to assist EPA in conducting the next two years of the CCEA
program.  Also, the comparison provided guidance for the formulation of an
organizational structure for implementing and managing the program.

D.   PRODUCTS OF THE PLANNING EFFORT

     The program planning effort has thus far yielded four principal products
which,  together, constitute the CCEA program plan.


                                    24

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     •  An initial set of goals and objectives for the CCEA program.

     •  A methodology for the comprehensive environmental assessment of
        conventional combustion processes.

     •  Detailed analytical procedures for identifying, evaluating, and
        integrating the programmatic content of R&D projects pertaining to
        the environmental assessment of conventional combustion processes
        into the CCEA Program.

     •  A set of recommendations for implementing the above procedures and
        methodologies, and managing the CCEA Program.

These products are described in the following appendix.
                                    25

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                                 APPENDIX B

                      DESCRIPTION OF CCEA PROGRAM PLAN


     The program planning effort described in Appendix A resulted in the
development of an initial plan for the implementation and management of the
CCEA program.  This initial plan consists of four interrelated components:

     1.  Goals and Objectives of the Program

     2.  A Comprehensive Environmental Assessment Methodology

     3.  A Matrix Analysis Procedure to Evaluate and Integrate Projects

     4.  Recommendations for Implementing and Managing the Program Plan.

Each of the components of the CCEA program plan is briefly described below.
The assumptions and rationale used in developing the plan are discussed in
detail in Appendices C, D, E, and F.


A,   CCEA PROGRAM GOALS AND OBJECTIVES

     1.  Long Term Goals

     The principal goals of the CCEA program may be briefly stated as
follows:

     (1)  To assess comprehensively the effects upon human health, the
          ecology, and the general environment of utilizing fossil or other
          fuels in SCCP.

     (2)  To recommend measures for controlling adverse effects within
          acceptable limits.

The mere determination and assessment of environmental effects is not, in
itself, considered an adequate statement of the program's long-term goals;
the purposes for which the environmental assessment information will be used
must also be reflected in any comprehensive statement of goals.  For the CCEA
program, the EA information is intended for use in making decisions pertaining
to environmental standards and pollution control technology.  More specifically
stated, the long-term goals of the program include:
                                      26

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     •  Assessment of the adequacy of existing technology to control the
        release of pollutants from SCCP.

     •  Assessment of the need for modifications to existing control technology
        or for the development of new control technology  and, if such needs
        exist,providing guidance and recommending priorities for the technology
        development effort.

     •  Assessment of the adequacy of existing emission or effluent standards
        designed to limit the release of pollutants to the environment.

     •  Assessment  of  the need for additional standards or modification of
        existing standards and, if such needs exist, providing guidance and
        recommending priorities of EPA's standard setting activities.

     2.  Intermediate Objectives

     The implementation of the above goals requires the accomplishment of a
number of intermediate objectives in the near- and mid-term.  Principal among
these is a thorough assessment of the effects of combustion pollutants on
human health and the ecology.  This, in turn, is dependent on the development
of key information and the availability of effects-assessment techniques.  In
addition to contributing to the long-term goals, most of these intermediate
objectives represent, in themselves, substantive and useful RD&D products.
The key technical and administrative objectives have been identified and
categorized as follows:

     Combustion Process/Pollutant Characterization Objectives

     •  Develop a unified, comprehensive base of existing data on
        combustion pollutants.

     •  Obtain essential new data from field tests,

     •  Characterize emissions/effluents from each major type of SCCP.

     Health/Ecology/Environmental Impact Assesment Objectives

     •  Estimate quantities of pollutants released from SCCP.

     •  Identify available models and other effects-estimating techniques.

     •  Develop quantitative estimates of health, ecological, and environ-
        mental effects (including associated economic costs) of pollutants
        from SCCP.

     •  Define priority areas for health/ecological/environmental impact
        studies.
                                      27

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     Technology and Information Transfer Objectives

     ©  Determine information needs of current/potential users of environ-
        mental assessment information.

     e  Transfer technical information to appropriate user organizations in
        a timely manner.

     Control Technology Development Objectives

     s  Develop a comprehensive data base on the capabilities of existing
        technology to control the release of combustion pollutants to the
        environment and on the costs of applying such technology.

     •  Identify specific combustion processes and specific combustion
        pollutants for which additional control technology capability is
        needed to meet current standards.

     Standards Development Objective

     •  Identify specific combustion processes and specific combustion
        pollutants for which modified or new standards are needed to limit
        pollutant emission/effluents to acceptable levels.

     The dependence of the major program goals upon these intermediate objec-
tives, as well as the interrelation among the more important of these objectives,
is shown diagrammatically in Figure B-l.  The rationale underlying the selec-
tion of intermediate objectives are discussed in greater detail, together with
other program objectives, in Appendix C of this report.
B.   COMPREHENSIVE ENVIRONMENTAL ASSESSMENT METHODOLOGY

     When the CCEA program was initiated, EPA had in progress several projects
that were considered to be within the purview of the program, either in total
or in part.  The comprehensive EA methodology provides a means to determine
whether the projects and other activities that constitute the CCEA program can
be expected to fulfill the goals and objectives of the program and, if they
do not, to suggest directions for augmentation or modification of program
activities.

     1.  Outline of the Methodology

     The overall procedure involves the following steps to be performed for
each type of combustion process.  The interrelations among these steps are
shown diagrammatically in Figure B-2.  (This procedure, presented here in
highly condensed form, is expected to be further refined and applied to major
SCCP over a period of about five years.)
                                      28

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      ASSESS OVERALL ADEQUACY
           OF EXISTING
        CONTROL TECHNOLOGY
Long-Term
  Goals
   PROVIDE GUIDANCE
      FOR CONTROL
TECHNOLOGY MODIFICATIONS
    AND DEVELOPMENT
ASSESS ADEQUACY
  OF EXISTING
   STANDARDS
PROVIDE GUIDANCE
   FOR NEW OR
    MODIFIED
    STANDARDS
                         Comprehensive Assessment of Health/Ecological/
                                Environmental Effects of  SCCP
 Intermediate
    Goals
                                                Identify combustion
                                                processes and pollutants
                                                for which existing stan-
                                                dards appear inadequate,
                                                and provide  rationale.
                          Identify control technology
                          development needs for specific
                          combustion processes and pollutants
                     Make  quantitative
                     estimates  of  health,
                     ecological, and
                     environmental effects
                     (including economic
                     costs)  at  various
                     levels  of  control
                          Characterize Emissions/
                          Effluents from each Major
                                Type sscp
                                       Identify and fill impor-
                                       tant gaps in existing
                                       information by field
                                       testing or new studies
          Develop data base of
          existing pollutant
          release information
                                Develop  comprehensive data base
                                on  capabilities and costs of
                                control  technology
            Figure B-l.  Interrelations among  long-term  goals  and  intermediate objectives.


                                                29

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       CHARACTERIZE COMBUSTION
       PROCESSES AND EFFLUENTS
ITERATE ON
BASIS OF
ALTERNATIVE
STRATEGY
                 1    REFINE    |
             t_  '  DATA BASE   |
                1 AND ANALYSIS f
                 I	I
                       EVALUATE ALTERNATIVE
                        CONTROL STRATEGIES
                                       IDENTIFY HEALTH, ECOLOGICAL
                                        AND ENVIRONMENTAL IMPACTS
                                                                    DEVELOP ENVIRONMENTAL
                                                                    GOALS AND OBJECTIVES
                                                   MflVRF
                                                   MAYBE
                                                                                (ASSESSMENT COMPLETED)
                                                                 NO
                                             ASSESS MAGNITUDE OF
                                              POLLUTION IMPACTS
                                                 |
                                                 I
I  RECOMMENDATIONS FOR:
I
              -  NEW/REVISED STANDARDS           i
              -  CONTROL TECHNOLOGY DEVELOPMENT  i
          I	1
            Figure B-2.   Comprehensive  environmental assessment methodology—principal steps.

-------
     •  Characterization of Combustion Process (and Related Pollution Control
        Equipment) and Its Emissions/Effluents.

        For each principal type of SCCP the characteristics of fuels, control
        technology, and measurement and analytical techniques are identified.
        In particular, it identifies the quantities and characteristics of
        emissions and effluents.

     •  Identification of Health, Ecological, and Environmental Effects of
        Emissions/Effluents from the Combustion Process.

        This step includes the quantification of combustion pollutants
        (identified in the preceding step) in the ambient environment, and
        anticipated response of the ecology and the exposed population in
        terms of morbidity/mortality rates, media degradation factors and
        other appropriate measures.  Such factors must take into account
        background levels of pollutants from noncombustion sources.

     •  Development of Environmental Goals and Objectives

        In the initial stages of this program, goals will be defined princi-
        pally in terms of established standards or unofficial permissible
        media concentrations.  In later stages,  the set of goals may be
        expanded to include such factors as the promotion of a specific energy
        policy or direction of economic development.

     •  Comparison of Pollutant Emissions, Ambient Levels, and Health/
        Ecological/Environmental Impacts Against Environmental Goals and
        Objectives

        This comparison indicates whether established standards are  being met,
        and other defined goals and objectives are being achieved.

     This comparison may have three outcomes.  (1) If it indicates  that
standards are, in fact, met and other goals and objectives have been met or
can reasonably be expected to be achieved by ongoing R&D activities  relating
to the combustion process under study, then the EA procedure is completed for
this process.  (Repetition of the procedure is required for other processes.)
(2) If there is some question of whether goals and objectives are being achieved,
it may then be necessary to repeat the above three steps, possibly  using better
data or more precise analyses (see Figure B-2).   (3) If the comparison indicates
that goals and objectives are not being achieved, then the EA procedure is
continued as follows:

     •  Determine the Magnitude of Pollution Impacts from the Combustion
        Process

        Quantities of pollutants released from continued use of SCCP at
        projected levels, ambient levels of such pollutants at appropriate
        geographic scales, and the degree of hazard (severity indices)
        associated with continued use of the combustion process are  estimated.
                                     31

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     o  Evaluation of Alternative Control Strategies for Achieving Goals
        and Objectives

        Strategies that will contribute toward achievement of goals and
        objectives may include development of more effective pollution
        control technology or the use of other alternatives such as fuel
        switching and modification of combustion techniques; alternatively,
        the strategy may be to modify the existing standards or other goals/
        objectives.

     This last step would indicate alternative approaches for meeting defined
goals and objectives (e.g., suggested new technological or non-technological
approaches for controlling pollutants from the combustion process under study),
hence it provides new input for iterating the entire EA procedure.  Iterations
may be required for each viable alternative identified.

     The comprehensive EA methodology is a complex and lengthy procedure which
is described above only in general outline.  Additional detail for the major
steps in the procedure are indicated in Figure B-3 and a more  detailed
description of the entire procedure is presented in Appendix D.

     It should be noted that the comprehensive EA methodology described here
is based in substantial measure on an EA methodology developed by the Energy
Assessment and Control Division (EACD) of IERL-RTP.  The  EACD  methodology
has undergone extensive development and has gained widespread acceptance in
the technical community.  The relationship between the CCEA comprehensive EA
methodology and the prototype procedure developed at IERL/RTP is discussed
in Appendix D.


C.  EA MATRIX ANALYSIS PROCEDURE

     The EA matrix analysis procedure is a technique to dissect or disaggregate
each relevant R&D project into basic programmatic (or informational) elements
addressed by it, and then to compare the project with others to identify
potential areas of overlaps.  In addition, the procedure facilitates inte-
gration of selected projects into the overall CCEA program and highlights
important programmatic areas where little or no R&D activities are ongoing
or planned.  The procedure also provides a framework for a computerized
information storage and retrieval scheme that would permit decision-makers
to identify and evaluate CCEA activities in specific programmatic areas.

     It is emphasized that the matrix analysis procedure does not, in any
sense, evaluate or rate either the content or results of any project; rather,
it provides an indication of a project's relevance to the CCEA program.

     The overall approach of the procedure relies heavily on the comprehensive
environmental assessment methodology described in subsections above.  The
basic scheme is to list in detail the R&D programmatic areas addressed by
each project and to compare them against elements of the environmental assess-
ment methodology.  The major programmatic areas into which each project is
                                     32

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COMBUSTION PROCESS TECHNOLOGY
CHARACTERISTICS
• Process state-of-the-art
• Process economics
• tnerqy efficiency

y e and source
h steal haractenstics
hemical haracteri sties
n rgy co tent
u 1 hand ing
v ilabll ty of fuels
| -

INPUT-OUTPUT CHARACTERIZATION ECQ
• Material balance
• Steady-state, transient, and
malfunction pollutant
loadings
,
(COMBUSTION PROCESSES AND |
-r-'
DEVELOPMENT OF SAMPLING AND
ANALYSIS TECHNIQUES
• Sampling techniques
• Analysis techniques
• Bioassay techniques

RECOMMENDATIONS *•_,
• Control technology modifications
• Quantified RiD needs
t Criteria for priorities
1 t
FIELD TESTS AND SURVEYS EP
• Control ystems testing •!
• CombuSti n process testing •!
• Lomprehensive waste stream
Chirac erization
- Leve 1
- Leve 2
- Leve 3

4 	 . 	 i 	

Figure B-3. Comprehensive environmental
assessment methodology .
DOSE-RESPONSE DATA
• ThreshoH limit *aljes '-'•'>
• Life-inortening chrcmc *r-^osurt
• Cancer and leukemia
• Respiratory disease j

LOGICAL IMPACTS
• Ecology related impacts
• Air. water, and land quality
• Quantified rred a degradation
|

FATE MODELS
• IP teoro'ogical and hydrolocv
• Model development
• E-OoSure e-el t-alculaiion*
- i
JHEALTH AND ECOLOGICAL 1
t t
tdustry related health data
creased morbidity and mortality
REFINE D
BIOASSAY DATA
• Standard bioassay techniques
• Bioassay criteria
• Control process it rear- Moassa
ATA BASE ^
	 AND/OR ANALYSIS ^ ' 	 '

CONTROL STRATEG
IMPACTS
t Secondary env
Y ENVIRONMENTAL
options
ronmental impacts

T

• Add-on devices
• Combustion modi 'ication
• Fuel switch/mi .ing

1 ALTERNATIVE CONTROL 1^
STRATEGY tvALUAl ION l~
A
CONTROL STRAT
RiO scale sy
Demonstrate
Economics
Energy requt
Pollutant rei
Operational
Source analy
k
.GY EVALUATION
stem
y ST*
renents f
moval efficiency
availability '
sil models (SAM's '

STATUTORY CONSTRAINTS
• Federal/state sianaares -nc
• "esearci data t»s« 'o'
standards


„


EMISSION OR AMBIENT
LEVEL GOALS
• Permissible media concentration
• Criteria for establishing
priorities
• Control technology limits s
• MATE
*

1 ENVIRONMENTAL GOALS ANDl
OBJECTIVES DEVELOPMENT I

• Data collection and ev



+
aluation


,,J
X
COMBUSTION PROCESS
USE PROJECTIONS
• Current market Si
• Fuel supply/deman
projections
ze
jections
d
+


.1E1
i

r
S
?A
NO
t


SOCIAL/ECONOMIC/POLITICA /
INSTITUTIONAL CONSIDER T10NS
• Nonpollutant impact goal
(energy, social, economi , etc.
• Quantified nonpollutant npacts
• Suing criteria
• Critical materials Impacts


^^ Environmental Assessment
Procedure Completed for
this Combustion Process
TOTAL POLLUTANT
LOAD CALCULATIONS
• Process loading
• Other sources loading
• Natural background
+
MAGNI UDE OF 1
POLLUTION 1
IMPACTS 1
* <
RANK [NG
• Total po 1 luunt toad
• Degree of hazard
(severity indices)
S
1 r
HOARDS DEVELOPMENT
ECOMMENDATIONS
Standards nodifications
iianoaras Development
Criteria for priorities
Time frare


*
DATA
• Demographic t land use
patterns & trends
• Hydrology and
meteorology
YNERGISTIC & MULTIMEDIA
IMPACTS
• Multimedia pol uUnt
distribution loads
• Additive, transformation.
and enhancement effects





-------
disaggregated are shown In Table B-l.  (Each of these areas is divided into
finer detail in the actual procedure.)  The relationships between these pro-
grammatic areas and the functional categories of the EA methodology will be
apparent from a visual comparison of Table B-l and Figure B-3 in the preced-
ing subsection.

     To aid in the disaggregation process, a questionnaire-type checklist was
developed to elicit information regarding the content of each project in each
of the programmatic areas.  The checklist also gathered information on the
fuels, pollutants, control technologies,  use sectors, polluted media, and
specific combustion processes addressed by the selected project.  The check-
list is designed to provide more than a simple yes-no answer as to whether a
given item is addressed.  For some items, it is intended to obtain an indica-
tion of the depth to which the item is investigated, e.g., whether a waste
stream is characterized at_ Levels 1, 2, or 3 as defined by the IERL/RTP
sampling and analysis protocol.  For other elements, the checklist obtains a
narrative description of the related activities.  Since the information
gathered on each project is somewhat extensive, codes were developed to
facilitate ease in data handling.  A checklist was completed by the Research
Triangle Institute for each project considered relevant to the CCEA program.

     The information from the checklist on each selected project is entered
onto a master matrix.  This matrix displays all the R&D activities conducted
by the group of projects in each programmatic area.  Thus, potential overlaps
between projects in R&D efforts will be highlighted by the matrix display.
Similarly, gaps where little or no R&D effort is ongoing or planned will also
be highlighted for condideration by decision-makers.

     It is stressed that this procedure merely highlights areas of apparent
or potential overlaps and gaps in the CCEA program — a definitive determina-
tion must be based on a more thorough analysis of the programmatic contents
of the projects involved.

     A more detailed description of the EA matrix analysis procedure including
a demonstration on the use of this procedure with two selected projects is
given in Appendix E.
D.   CCEA MANAGEMENT STRUCTURE

     MITRE identified a number of alternative organizational structures for
CCEA program management and selected five for detailed examination.   These
are listed below and described with organization charts in Appendix F.

     1. Existing Structure

     2. Existing Structure with Advisory Committee

     3. Division-Level EA Unit

     4. Program Office at Laboratory Level

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TABLE B-l.   MAJOR PROGRAMMATIC AREAS ADDRESSED BY CCEA PROGRAM

•  Combustion Process Technology Background
•  Development of Sampling and Analysis Techniques
•  Fuels Characterization
•  Input-Output Characterization
•  Field Tests and Surveys
e  Pollutant Transport, Transformation, and Fate Models
•  Dose-Response Data
•  Ecological Impacts
•  Epidemiological Data
•  Bioassay Data
•  Emissions or Ambient Level Goals
•  Social/Economic/Political/Institutional Considerations
•  Statutory Constraints
•  Ambient Pollutant Levels
•  Combustion Process Use Projections
«  Total Pollutant Load Calculations
•  Synergistic and Multimedia Impacts
•  Regional Geographic Data
•  Pollutant Priority Rankings
•  Control Alternatives
•  Control Strategy Environmental Impacts
•  Control Strategy Evaluation
•  Standards Development Recommendations
•  Control Technology Development Recommendations
                            35

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     5. Program Office at Interagency (Headquarters) Level,

     Each alternative Is analyzed, compared, and evaluated in terms of its
advantages and disadvantages according to five evaluation criteria identified
in Appendix F.

     On the basis of these evaluations MITRE recommends that EPA adopt, for
the long-term management of CCEA, the third alternative, which is briefly
described as follows:

     Alternative 3.  Program management is centered in a new division-level
     unit with responsibility for managing all environmental assessment
     activities within IERL-RTP.  Policy and overall direction of the CCEA
     program, as one of the principal EA activities within the Laboratory,
     is set by an executive committee chaired by the director of the new
     division-level unit.- Day-to-day activities are directed by a program
     manager who reports to the executive committee chairman.

     The management structure for this alternative provides the communication
channels needed for obtaining the needs, opinions and advice of all major
users of CCEA products as well as communication between all CCEA participants
(i.e., project, officers of CCEA projects, contractors, etc.).  By consolidating
all major environmental assessment activities under a single line management
at the division level, this structure facilitates planning, coordination, and
direction of these activities to the benefit of the CCEA program as well as
other major ongoing or planned EA programs.  More than any other alternative
considered, this one provides the level of managerial leverage and stability
needed for successful implementation of the CCEA program.

     The third alternative is not the most easily implemented, however.  It
involves a significant realignment of workload and responsibilities which
effectively precludes immediate implementation.  MITRE therefore recommends,
as an interim measure, the immediate adoption of the second alternative,
briefly described as follows:

     Alternative 2.  Program management is centered in the existing organiza-
     tion at Utilities and Industrial Power Division, IERL/RTP, but is
     augmented by an advisory board representing a broad spectrum of potential
     users, and a working group representing major participating organizations
     (that is organizations conducting projects that fall within the CCEA
     program).

The structure implied by Alternative 2 provides the mechanism for improved
communication among program management, program participants, and users of
CCEA products (relative to the present management structure of the program)
while not presenting any serious drawbacks.

     The two-step approach to implementation of the long-term management
structure will (1) permit continuous function of the CCEA program,  (2) quickly
provide needed inputs from an advisory committee that includes users of CCEA
                                     36

-------
products, (3) quickly bring project officers of related projects into the
CCEA management process at the working group level, and (4) provide for a
strong, stable, long-term management structure for planning, coordinating,
and directing all environmental assessment activities including CCEA.


E.   CCEA PROGRAM CORE PROJECTS

     The results of the survey to identify ongoing and planned R&D projects
of relevance to the CCEA program yielded a set of over 500 projects.*  The
list included projects not only within IERL-RTP and EPA, but also in
14 different government agencies and other research organizations.  While
analysis of this vast body of information is central to achieving the overall
goals and objectives of the CCEA program, resources currently available to
the program prohibit the undertaking of an effort of such magnitude.  Conse-
quently, a manageable set of "core" projects is recommended for initial inte-
gration into the unified CCEA program.  By application of the methodologies
and analytical procedures described earlier to the set of core projects, the
CCEA program would not only begin immediately to provide tangible results for
use by decision-makers, but would also more fully test the methodology and
facilitate any needed revisions within its various components.

     Several basic selection criteria were developed to reduce the number of
CCEA-related projects for inclusion in the core set.  Since the selection
process was carried out on preliminary data, some judgment in the use of
these criteria had to be exercised.  The five principal criteria used for the
selection of core projects are outlined as follows:

     1. Since those projects funded by EPA are more amenable to influence
        by the CCEA program than non-EPA projects, a greater weighting
        is given to EPA projects in selecting the core CCEA.  In order to
        conduct a unified and coordinated environmental assessment, the CCEA
        program should have the capability to guide or redirect ongoing and
        future studies.

     2. All projects selected should be ongoing or proposed.

     3. Projects chosen should address a wide spectrum of environmental
        assessment areas.  Since the CCEA program planning is an effort
        to develop an overall coordinated structure, the core selection
        should reflect the diversity of information necessary for the
        comprehensive environmental assessment of SCCP.

     4. Projects chosen should reflect the emphasis of current environmental
        assessment R&D efforts.  Priority should be given to heavily funded
        projects since funding levels usually indicate priorities established
        by the funding agencies.

     5. Projects chosen should have substantial information readily available.
        This criterion is utilized after the others have been applied in order
*This survey was conducted by Research Triangle Institute.  Results are reported
 in Reference 7 (listed in Section 6 of this report).

                                     37

-------
to provide a manageable number of R&D efforts for which a detailed analysis
may be carried out.

     The application of criteria 1 through 4 above yielded a set of 32 relevant
projects from which the core CCEA projects were chosen.  Criterion 5 was then
applied to the above set to select 13 core projects for integration into the
unified CCEA.*  Table B-2 shows the title, EPA project officer, and period of
performance of the selected core projects.
*It is stressed here again that the limited set of projects selected for detailed
evaluation is not intended as a complete representation of the wide range of
research being pursued by the many agencies involved in environmental assess-
ment activities.  Rather, it provides a basis for initial implementation of
the CCEA program.  Additional projects will be integrated as manpower and funding
become available.
                                      38

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                                        TABLE B-2.  RECOMMENDED CORE CCEA PROJECTS
TITLE
1. Characterization of Effluents from Coal-
Fired Utility Boilers
2- LG&E Full-Scale Scrubber Testing and
Waster Disposal Program
3- Environmental Assessment of Stationary Source
NOX Control, Technologies

4. Design Optimization, Construction and
Field Optimization of Integrated
Residential Furnace
5. Combustion of Hydrothermally Treated Coal
6. Emissions Characterization of Conventional
Combustion Systesm
7. Evaluation of Emissions and Control Tech-
nology for Industrial Stoker Boilers
8. Environmental Assessment of After-burner
Combustion Systems
9. Test Program for the Full Scale Double
Alkali FGD Utility Demonstration
10 . Evaluation of Alternatives for Disposal
of FGD Sludges
11. Field Testing — Combustion Modifications of
Industrial Combustion Equipment
12. The impact of Coal-Fired Power Plants on
the Environment
13. Comparative Multimedia Assessment: Well-
Controlled Coal-Fired and Oil-Fired Boilers
PROJECT OFFICER
R. A. Venezia

J. W. Jones

J . S . Bowen

i
G. B. Martin


J. D. Kilgroe
R. A. Venezia

J. H. Wasser

J. H. Wasser

N. Kaplan

J. W. Jones

R. E. Hall

G. E. Glass

W. H. Ponder

PERIOD OF PERFORMANCE
1/76-12/79

3/76-9/78

2/77-10/79


1/77-8/78


9/76-10/78
3/77-1/80

3/77-7/79

3/77-12/79

6/77-6/81

6/75-

1/76

7/75-7/78

3/77-12/78

u>
VD

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                                 APPENDIX  C

                DEVELOPMENT OF CCEA GOALS AND OBJECTIVES
A.  RATIONALE

     In the early developmental stages of the CCEA program planning, the
goals and objectives of the program were simply defined.  All of them related
directly to control technology development.  The principal goals were to de-
termine whether additional control technology development is needed, and if
so, to define and recommend among the several alternative courses of develop-
ment.  The interim objectives were to assemble the necessary data, characterize
emissions/effluents from the more prevalent types of stationary conventional
combustion equipment, determine levels of emission control required to meet
standards, and assess whether existing technology is adequate to achieve these
levels of control.

     As the program planning progressed, it soon became apparent that the pro-
gram goals and objectives could not be realistically defined solely in terms
of control technology requirements, in isolation from emission/effluent and
ambient standards, costs of achieving compliance, and at least a rough ap-
proximation of the effects of combustion pollutants on human health, the
ecology, and the general quality of the environment.  Questions immediately
arose pertaining to the criteria against which adequacy of control tech-
nology is to be evaluated.  Should the evaluation be limited to the capa-
bility to control the release of pollutants for which standards currently
exist (or are currently being established)?  If so, how should the release
of other hazardous substances — known toxic or carcinogenic material — be
treated?  And how are emission concentrations of such materials to be mea-
sured .when current field sampling and analysis techniques are not sensitive
to the very low emission concentrations which can be bioaccumulated to levels
known to be hazardous to health?  Also, how should the cost of achieving
compliance be factored into the program's recommendations pertaining to con-
trol technology development?

     The program must address problems beyond the ability of existing con-
trol technology to meet existing standards if its findings and recommen-
dations produced during the latter stages of the program are to be viable
and relevant to conditions at that time.  Moreover, if the program is to be
forward-looking and anticipatory rather than totally reactive, it must take
into account pollutants other than those for which standards have been writ-
ten, and should assume the initiative of recommending other combustion-re-
lated materials for which additional standards and regulations appear war-
ranted.
                                     40

-------
     Another type of problem arose in connection with the highly simplified
goals and objectives defined early in the CCEA planning process.  This involved
technical management, administrative and organizational responsibility of the
work involved, flow of information, and implementation of recommended actions.
The ongoing work on combustion pollutant assessment is now being performed by
different organizational entities within EPA, and some related work is ongoing
within non-EPA organizations.  Through what mechanism could these diverse
efforts be coordinated and their results integrated?  How could the various
participants be kept apprised of one anothers1 objectives and results so as
to minimize duplication of effort, promote utilization of one anothers' results,
and thereby increase the efficiency of the aggregate effort?  If substantive
recommendations were made concerning the needs and priorities for control
technology development or for the development of additional standards, how
could these recommendations be most effectively conveyed to the appropriate
implementing authorities?  What provisions exist for review, feedback, and
redirection among participants in the CCEA program and between CCEA partici-
pants and the users of their products (e.g., the implementing agencies)?  The
program must involve at least a minimal realignment of managerial responsi-
bility if its results are to be effectively utilized and its recommendations
are to be thoroughly evaluated and considered for implementation.

     As a result of the several conceptual and practical problems, both tech-
nical and administrative, that came to light during the development of a pro-
gram plan designed to meet the initial simplified set of objectives, the de-
cision was made to expand the goals and objectives of the program.  These
were to include guidance and recommendations for standards setting as well as
control technology development, and the structuring of an administrative/
managerial system that would enable the diverse elements of the program to
function effectively and to interrelate in a coordinated, mutually supportive
manner.  The supporting objectives were classified and defined in greater de-
tail according to technical or administrative purposes served.

     The subsections that follow identify and briefly describe both the goals
and objectives arranged according to their principal function.


B.  OVERALL OBJECTIVES

    1. CCEA Organizational and Administrative Objectives

    •  Establish a centralized office for administering and directing all
       CCEA-related activities and integrating these into a cohesive program

       This objective is set forth in recognition of the existing dispersion
       within EPA of activities relating to the assessment of pollutants from
       combustion, and the need to coordinate and augment these activities
       into a comprehensive program.

-------
 •  Establish channels for communicating CCEA results to implementing
    organizations, and jror establishing and responding to dialog with
    these organizations

    The CCEA program is designed to develop and analyze data, and to
    make recommendations based on the analyses.  The recommended actions
    are referred to implementing organizations, within EPA or elsewhere,
    to determine which actions are to be taken and to implement them.
    This objective is intended to insure that the implementing organiza-
    tions are continually apprised of developments under the CCEA program
    which might impact their operations, and to insure that recommended
    actions and other outputs of the CCEA program are presented in a
    format, and with clarity and completeness to facilitate the decision-
    making processes of the implementing organizations.

2.   Combustion Process/Pollutant Characterization Objectives

•  Develop a comprehensive base of available data on combustion
   pollutants

   Much of the data and other information required for the CCEA program
   already exists at a variety of locations within CCEA projects and else-
   where while additional information is currently being developed.   One
   of the first tasks scheduled to be undertaken in the CCEA program is
   the compilation of all available data pertaining to pollutants from
   SCCP.  This compilation will include data on the components and quanti-
   ties of emissions/effluents from each type of stationary combustion
   process as well as information on the effects of such materials on
   human health, the ecology, and the general environment.  The compi-
   lation of available data, although a continuing process, is scheduled
   to develop rapidly during the early phase of the CCEA program, and to
   support the accomplishment of other interim objectives as well as long-
   term goals.

•  Obtain essential new data from field tests

   The base of available data developed in achieving the preceding objec-
   tive will permit data gaps to be identified and additional data needs
   •defined.  Principal among these will be data to be obtained by field
   measurement of combustion processes/equipment for which emissions have
   not been fully characterized.  A major effort within the CCEA program,
   as currently planned, is the  acquisition of new information by direct
   measurement on pollutant emissions from major types of combustion equip-
   ment operating under a range of conditions.
                                 42

-------
•  Develop recommendations for existing sampling and analysis methods

   Detection and measurement of combustion pollutants in emission or ef-
   fluent streams and in the atmosphere is necessary both for acquiring
   data to implement the CCEA program and for subsequent routine moni-
   toring and enforcement.  An objective of the program is to examine the
   adequacy of existing sampling and analysis methods for use in the CCEA
   program, and, if not fully adequate, to recommend additional develop-
   ment of methods and procedures for their use.

•  Characterize emissions/effluents from each major type of stationary
   conventional combustion process

   From the field measurements made under the CCEA program plus data
   available elsewhere, pollutant types and quantities released from each
   major category of equipment will be determined during a range of stan-
   dard and non-standard operating conditions.   This comprehensive charac-
   terization is needed as a basis for estimating total aggregate quanti-
   ties emitted from all sources of each type and for estimating the im-
   pacts on health and the environment.  While complete characterization
   of all pollutant species from each major type of source is desired,
   some lesser degree of characterization may be acceptable during the
   early stages of the program as a basis for estimating health and eco-
   logical impacts and for identifying control technology requirements.

   This objective will involve determining the minimum acceptable degree
   of pollutant characterization, and implementing this characterization,
   for each major category of conventional stationary combustion equipment.

3. Health/Ecology/Environmental Impact Assessment Objectives

•  Estimate health, ecological, and environmental effects of combustion
   pollutants

   These effects estimates are to be used as one of the major criteria
   for establishing priorities among the recommended actions for modifi-
   cation or development of control technology and standards. When such
   estimates of effects are not available from other studies, they are to
   be developed under the CCEA program by the use of mathematical models
   or other effects-estimation techniques, used in conjunction with pollu-
   tant emission data and meteorological, hydrologic,  demographic and
   other characteristics of the areas affected by combustion pollutants.
   In stating this -objective, the planners of the CCEA program recognize
   that a tremendous effort would be required if the effects estimation
   were begun anew.  It is their observation that much of the effects in-
   formation is already available, and that existing effects-estimating
   techniques will provide most of the (quantitative)  approximations of
   health, ecological, and environmental impacts that  are needed for de-
   cision-making relative to the development or modification of control
   technology and standards.  Three supporting subobjectives follow,.
                                43

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   -  Estimate quantities of combustion pollutants released

   One necessary step toward developing quantitative estimates of health
   and ecological effects of combustion pollutants is to obtain substan-
   tive estimates of the amounts of pollutants that would be released, as-
   suming projected levels of fuel use for defined applications and vari-
   ous levels of pollution control.  The estimated quantities of pollu-
   tants released will be used as input to effects-estimating techniques
   to obtain quantitative estimates of the impacts of combustion pollu-
   tants on human health, the ecology, and the general environment.

   -  Identify available models and other effects-estimating techniques

   A second requirement for quantitatively estimating the health and eco-
   logical impacts of combustion pollutants is to have appropriate models
   or other techniques for translating quantities of emitted pollutants
   into quantitative measures of health, ecological, and environmental
   effects.  An objective of the CCEA program is to identify the current-
   ly available models, such as the Source Analysis Models (SAM), and to
   assess their applicability and adequacy for producing quantitative es-
   timates of effects with the accuracy and validity needed for decision-
   making.

   -  Define priority areas for health/ecology/environmental impact studies

   All pollutants or potential pollutants are not of equal importance
   from the standpoint of their prevalence or their health and ecologi-
   cal effects.  Some have been much more thoroughly investigated than
   others.  Similarly, all types of SCCP are not of uniform importance
   from the standpoint of their prevalence or impacts.  An objective of
   the CCEA program is to establish a priority ranking for specific pol-
   lutants and specific combustion processes.  This ranking will be used
   to guide the projects and investigations conducted within the CCEA
   program, and will form the basis for recommended areas of study by
   other EPA operational programs and organizational components, parti-
   cularly those concerned primarily with health and ecological effects.

4. Technology and Information Transfer Objectives

•  Transfer technical information to appropriate user organizations

   All principal activities of the CCEA program involve the acquisition
   and analysis of information, and the development of recommendations
   based on the analyses.  If the program is to have practical results
   beyond the scope of an academic exercise, its conclusions and recom-
   mendations must be communicated to a number of key organizations within
   EPA and elsewhere with the responsibility and capability of evaluating
   the recommended actions and implementing those having greatest urgency
   or merit.  If the CCEA program is to have maximum utility, its tech-
   nical data and methods must be communicated to an  even broader audi-
   ence of potential users.  These communications and technology trans-
   fer objectives are to be accomplished by a sequence of periodic pub-
   lications on the status of the program (annual reports), published

                                44

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   technical reports on results of individual CCEA projects, status
   briefings and conferences with EPA management, and general CCEA and EA
   symposia involving the technical community.

5. Control Technology Development Objectives and Goals

•  Identify promising new control technologies applicable to specific
   combustion pollutants and combustion equipment/processes

   The identification of new or improved approaches for meeting established
   pollution control needs is an important output of the program.  The
   results may be in any of several forms such as:  new equipment de-
   signs; specifically identified opportunities for increased control
   efficiency of new or existing equipment; identification of addition-
   al reaction mechanisms not previously used for pollutant emission
   control; or the substitution of less expensive or more effective re-
   actants for those in current use.  These results are needed to sup-
   port the program's major goals pertaining to control technology
   development, namely:

   - to assess the adequacy of existing technology to control the re-
   lease of pollutants from combustion processes,

   - to assess the need for modifications to existing control technology
   and for the development of new control technology, and, if such needs
   exist, to provide guidance and recommend priorities for the technolo-
   gy development actions.

6. Standards Modification and Development

•  The program's major goals relative to standards are:

   - to assess the adequacy of existing emission or effluent standards
   that limit the release of pollutants to the environment,

   - to assess the need for additional standards or modification to
   existing standards and, if such needs exist, to provide guidance
   and recommend priorities for EPA's standard setting activities
   (including identification of specific substances and combustion
   processes and equipment for which new or modified standards appear
   needed).

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                                 APPENDIX D

              COMPREHENSIVE ENVIRONMENTAL ASSESSMENT METHODOLOGY


A.   ENVIRONMENTAL ASSESSMENT DEFINITION AND OBJECTIVES

     The growing awareness of the range of direct and indirect environmental
consequences of modern technology has given rise to new categories of inves-
tigative studies along with new terminology to describe these studies.
Technology Assessments (TAs), Environmental Impact Statements (EISs), Inte-
grated Technology Assessments (ITAs), Environmental Assessments (EAs), etc.,
are being generated every year.   Concise definitions of these terms, however,
are quite difficult to find.  This is especially true for an EA.  Many studies
are called environmental assessments when they are principally emission
characterizations or a single pollutant impact identification.

     The Energy Assessment and Control Division of IERL-RTP has developed a
working definition of an environmental assessment that is becoming accepted
by the research community.  This definition is given in Section 3 of this
report.

     An environmental assessment involves neither the development or
promotion of the combustion process nor the development or promotion of
technology to control emissions from the combustion process.  It is a con-
tinuing process that is carried out simultaneously with technology develop-
ment to identify and evaluate the full range of impacts (including cross-
media impacts and trade-offs) of the combustion process and/or control
technology on the environment.  The findings of an environmental assessment
are aimed at providing a base of sound information for use by energy/
environmental decision-makers for:

     e  Standards Setting

     0  Control Technology Development

     e  Policy Formulation

     o  Resource Allocation

     Outputs from a comprehensive environmental assessment would range from
mere listings of pollutant emissions and descriptions of evaluation techniques
to identifications of quantified environmental impacts and to specific recom-
mendations for decision-making.
                                      46

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B.  FUNCTIONAL ACTIVITIES

     What, then, is the range of activities that must be undertaken in order
to satisfy the objectives of a comprehensive environmental assessment?  What
are the input requirements for these activities, and what are the relation-
ships between the activities?  Where does one draw the boundaries for an
environmental assessment?

     EPA/IERL-RTP has been active for some time in answering the above
questions and in developing a methodology to incorporate EA components into
its major programs.  The environmental assessment methodology employed in
the CCEA program draws heavily on the philosophies of the existing EPA/
IERL-RTP methodology, but has been expanded and modified to be more respon-
sive to the assessment of conventional combustion processes.

     1.  Generalized Environmental Assessment Methodology

     In the most elementary of descriptions, an environmental assessment
consists of three basic iterative steps (see Figure D-l).

     (1) Characterization of the combustion process (including any associated
         pollution control devices) and its effluents.

     (2) Assessment of the health and ecological impacts of the combustion
         process and its effluents on the environment:

            Identification of environmental (health and ecological) impacts.
            Development of environmental goals and objectives.
            Comparison of impacts with environmental goals and objectives.
         -  Assessment of pollution impacts' magnitude.

     (3) Evaluation of alternative control strategies for use with the
         combustion process.

     The first step in an environmental assessment is to characterize
completely the combustion process in terms of a "black box" to identify all
the pollutants emitted from the process, the quantities emitted, and the
nature of the emissions (e.g., media involved, load distribution over time,
and physical/chemical characteristics of the pollutants).

     Once complete information on the effluents from the combustion process
has been obtained, the second step of the environmental assessment is to
determine the impacts of the process and its effluents on the environment.
This process involves four general activities:  (1) identification of the
health and ecological impacts, (2) development of environmental goals and
objectives, (3) comparison of the impacts with the goals and objectives to
determine whether the impacts are acceptable, and (4) assessment of the pol-
lution impacts' magnitude.  If the results of activity three in this step
indicate that the impacts of the combustion process and its effluents on
human health and the ecology are acceptable according to current environ-
mental goals and objectives, then no problem is foreseen and the environ-
mental assessment process has been completed.  If, however, the results

                                     47

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             CHARACTERIZATION OF COMBUSTION
               PROCESS AND  ITS EFFLUENTS
co
ASSESSMENT OF HEALTH AND
  ECOLOGICAL IMPACTS

  o  Identification of environmental
      impacts
  o  Development of environmental
      goals and objectives
  o  Comparison of impacts with
      goals and objectives
  o  Assessment of pollution
      impacts' magnitude
EVALUATION OF ALTERNATIVE
  CONTROL  STRATEGIES
                                                   ENVIRONMENTAL  ASSESSMENT
                                                      AND OUTPUTS

                                                      o Technology transfer documents
                                                      o Standards development
                                                         recommendations
                                                      o Control  technology development
                                                         recommendations
                                    Figure D-l.   Generalized environmental assessment methodology.

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indicate that the impacts of the combustion process or its effluents are not
acceptable according to current environmental goals and objectives, then
the magnitude of the impacts must be assessed in activity four and ways to
ameliorate these impacts must be identified.

     The third step in an environmental assessment is to identify and evaluate
alternative methods of reducing the deleterious environmental impacts and
to select the optimum control strategy for use with the combustion process.

     This entire procedure is repeated for the combination of the given com-
bustion process and the control technology selected in step three and for
each combustion process considered by the environmental assessment.  Techni-
cal reports are developed at every stage in the application of the environ-
mental assessment methodology.  Where impacts of the combustion process or
its effluents on human health or ecology are serious, or where optimum
existing control technologies are inadequate, specific recommendations for
the promulgation of stricter environmental standards or for the development
of additional control technologies are made for consideration by the appro-
priate decision-makers.

Detailed Environmental Assessment Methodology

     A detailed environmental assessment methodology consists of various
functional categories of information which interact to provide the desired
data, information, or results.

     As stated above, the first step in a comprehensive environmental assess-
ment is the characterization of the combustion process and its effluents.
Such a characterization comprises five functional categories of information:

     •  Combustion Process Technology Characteristics

     •  Fuels Characterization

     •  Input/Output Characterization

     •  Development of Sampling and Analysis Techniques

     •  Field Tests and Surveys

Figure D-2 shows the elements of each functional category and the relation-
ship between the characterization of the combustion process and its effluents
and the identification of the health and ecological impacts activity of step
two.  Each functional category in this step is briefly described below.

Process Technology Characteristics is intended to provide detailed technical
and operational information on the SCCP.   Information on the state-of-the-art
of the combustion process including development status and commercial avail-
ability, process economics, energy efficiency, and reliability are considered
in this functional category.
                                     49

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                                                 COMBUSTION  PROCESS  TECHNOLOGY
                                                         CHARACTERISTICS
                                                • Process  state-of-the-art
                                                • Process  economics
                                                • Energy efficiency
                                 FUELS CHARACTERIZATION
                                    Type and source
                                    Physical characteristics
                                    Chemical characteristics
                                    Energy content
                                    Fuel handling
                                    Availabili ty of  fuels
                                             INPUT/OUTPUT  CHARACTERIZATION

                                              • Material  balance
                                              • Steady-state, transient, and
                                                  malfunction pollutant loadings
Ln
O
                        COMBUSTION PROCESSES AND
                        EFFLUENT  CHARACTERIZATION
                                                                                       HEALTH  AND ECOLOGICAL
                                                                                       IMPACTS IDENTIFICATION
                                                                                           (see Figure  D-4)
DEVELOPMENT OF SAMPLING AND
  ANALYSIS TECHNIQUES

 0 Sampling  techniques
 0 Analysis  techniques
 0 Bioassay  techniques
                                                                        FIELD TESTS AND SURVEYS

                                                                          • Control  systems testing
                                                                          • Combustion process testing
                                                                          0 Comprehensive waste stream
                                                                             characterization
                                                                             - Level 1
                                                                             - Level 2
                                                                             - Level 3
                              Figure D-2.   Combustion processes  and effluent characterization  (step one)

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Fuels Characterization includes a description of the type and source of the
fuel, physical and chemical characteristics including potential pollutants,
energy content, fuel handling including methods of delivery and storage, and
availability.

Input/Output Characterization to establish the relationship among the process
variables is an important environmental assessment functional category.
Material balances for the combustion process and potential pollutant loadings
for a variety of operating conditions such as steady-state, transient, and
malfunction or other nonstandard sttates, are developed.

Development of Sampling and Analysis Techniques (including bioassay tech-
niques) are essential for assuring consistent and reliable results for com-
parison of data obtained by various investigators.

Field Tests and Surveys using the standard sampling and analysis techniques
are conducted to fully quantify and characterize the effluents.  These tests
and surveys are conducted on bench, pilot, demonstration, or full scale
plants.  EPA has established a detailed, phased screening, analysis, and
monitoring protocol for various levels of waste stream characterizations.*
The three levels of characterization are:

     Level 1 - Comprehensive Screening (including "Criteria Pollutants").

     Level 2 - Directed Detailed Analysis based on Level 1 findings.

     Level 3 - Process Monitoring on Selected Priority Pollutants based on
               Level 1 and Level 2 findings.

     The second step in an EA, the assessment of the health and ecological
impacts of the combustion process and its effluents, is shown in Figure D-3.
The assessment of health and ecological impacts involves four general
activities.

     1.  Identification of the health and ecological impacts of the combus-
         tion process and its effluents.

     2.  Development of environmental goals and objectives.

     3.  Comparison of the impacts with the environmental goals and objec-
         tives.

     4.  Magnitude of pollution impacts.

     The identification of the health and ecological impacts of the combus-
tion process (including any associated control technology) is the first
activity of the second step.  It includes detailed analysis of the response
of the environment and the exposed population's health to the pollutant
loadings of the process.  This includes data collection and analysis relating
to the air, water and land quality, ecology-related effects, increased
morbidity and mortality rates, and quantified media degradation alternatives.
*See References 4 and 5 in Section 6 of this report.

                                     51

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Ol
NJ
                                                       ^ENWRONMENI'All, GOALS: AND;
                                                       ] OEJEGTVE;S. DEVELOPMENT;
                                                                  /igure> D^-A
                        HEAlTHi AND? EeOlLC)GiIiCAli
                        rMPACTtS;
                          Cse&.Fi
REFINE DATA BASE
AND/OR ANALYSIS
                                                              'MAGNIiTUDE  OF
                                                              '•  POLLUTION
                                                                                Environmental  Assessment Procedure
                                                                                Completed for this Combustion
                                                                                Process
                             Figure D-3;.   Assessment of  health and: ecological impacts  (step two-):..

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     Combustion process and effluent characterization (the first step),
previously discussed, serves as an input in Figure D-4.   Additional inputs to
this activity are provided by the following functional categories:

     •  Ecological Impacts

     •  Dose-Response Data

     •  Pollutant Transport, Transformation, and Fate Models

     •  Bioassay Data

     •  Epidemiological Data

Ecological Impacts identification is necessary to evaluate relevant informa-
tion to quantify such concepts as media degradation.

Dose-Response Data allow the translation of pollution concentrations in the
environment into an estimate of the number and type of specific biological
impacts to be expected in an exposed population.  Dose-response data relate
exposure concentration and exposure time to the probability of observing a
given biological response.  Thus the exposure to a given SC>2 concentration
for 3 hours may be expected to result in a certain number of cases of respir-
atory ailments, or a given average annual S02 concentration may result in an
estimate of increased mortality.  In addition to available dose-response
data such as threshold limit values (TLV) and lethal concentration for 50 per-
cent mortality in the exposed population (LC 50), information in terms of
cancer, leukemia, respiratory disease, or other chronic or acute responses
is often important in identifying the health and ecological impacts of the
combustion process and its effluents.

Pollutant Transport, Transformation, and Fate Models are used in calculating
pollutant concentrations and exposure levels.  Meteorological and hydrologi-
cal data, and pollutant chemical transformation and reactivity data must be
developed for use in the models.

Bioassay Data identifying the effects of varying concentrations of pollutants
on living organisms serve to augment dose-response data.  Included among the
bioassays of interest are those relating to health and ecological effects.
Health effects-related bioassays include:

     •  Microbial bioassays (e.g.,  Salmonella typhimurium bacterial muta-
        genicity screening test).

     •  In vitro bioassays (e.g.,  alveolar  macrophage cytotoxicity tests,
        epithelial cell carcinogenicity screen).

     •  In vivo bioassays (e.g.,  mammalian  toxicity tests,  carcinogenicity
        screen).
                                     53

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                                           DOSE-RESPONSE DATA

                                             •  Threshold  limit values  (TLV)
                                             •  Life-shortening .chronic exposure
                                             •  Cancer and leukemia
                                             •  Respiratory disease
                           ECOLOGICAL IMPACTS

                             • Ecology related  impacts
                             • Air,  water, and  land
                                 quality
                             • Quantified media
                                 degradation
Ul
            COMBUSTION  PROCESSES  AND
            EFFLUENT  CHARACTERIZATION
                 (see Figure D-2)
H
                          TRANSPORT, TRANSFORMATION,
                            FATE  MODELS

                           • Meteorological and hydrologic
                               data
                           • Model development
                           • Exposure level calculations
                           « Transformation chemistry
HEALTH  AND ECOLOGICAL
IMPACTS IDENTIFICATION
                       EPIDEMIOLOGICAL DATA

                     • Industry  related health data
                     9 Increased morbidity and mortality
                              BIOASSAY  DATA

                         • Standard bioassay techniques
                         • Bioassay criteria
                         • Control process stream
                             bioassay
                                                                                                        NO
                                                                                                 (see  Figure D-6)
             Figure  D-4.  Health and ecological impacts identification  (first activity,  step two).

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Ecological effects-related bioassays include:

     •  Laboratory studies on single/multiple plant or animal species
        (e.g., acute toxicity studies, carcinogenicity screening tests).

     •  Microcosm studies of terrestrial,  marine, or aquatic communities.

     •  Field studies of ecosystems.

Epidemiological Data developed from occupational exposure-related health
information are important indicators of potential adverse pollutant impacts.
Examination of vital statistics and data on specific illnesses and diseases
in exposed populations may allow identification of the specific agent
responsible or alert investigators to the possibility of such effects being
associated with a particular process.

     The second activity in the assessment of the health and ecological
impacts (second step) is the development of environmental goals and objec-
tives.  These environmental goals and objectives are developed as standards
or indices of acceptability.  These indices of acceptability are based on
a variety of interrelated factors including health effects, ecological
effects, physical effects, socioeconomics, and institutional/political
and legals constraints.  These environmental goals and objectives may be
expressed in such terms as process/pollutant emission rates, ambient
pollutant concentrations in the various media, or environmental nondegrada-
tion criteria.  As shown in Figure D-5, the four major functional categories
to be addressed in developing the environmental goals and objectives Include:

     •  Statutory Constraints

     •  Emission or Ambient Level Goals

     •  Social/Economic/Political/Institutional Considerations

     •  Ambient Pollutant Levels

Statutory Constraints considered in developing environmental goals and
objectives include:

     o  National Primary and Secondary Ambient Air Quality Standards

     o  State Implementation Codes

     o  OSHA Standards for Air Contaminants

     o  National Emission Standards for Hazardous Air Pollutants

     0  New Stationary Source Performance Standards

     «  National Interim Primary Drinking Water Regulations

     «  EPA Effluent Standards


                                      55

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  STATUTORY  CONSTRAINTS

    •  Federal/state standards
       regulations
    e  Research data base  for
       standards
and
EMISSION  OR AMBIENT
  LEVEL GOALS

 • Permissible media concentration
 • Criteria  for establishing
     priorities
 • Control  technology limitations
 t MATE
                        ENVIRONMENTAL  GOALS AND
                        (OBJECTIVES DEVELOPMENT
 AMBIENT POLLUTANT  LEVELS

• Data collection and evaluation
                SOCIAL/ECONOMIC/POLITICAL/
                   INSTITUTIONAL CONSIDERATIONS

                   •  Nonpollutant  impact goals
                     (energy, social, economic, etc.)
                   •  Quantified nonpollutant  impacts
                   •  Siting criteria
                   •  Critical materials impacts
                                                                                        NO
                                                                                 (see  Figure D-b)
 Figure D-5.   Development  of environmental goals  and objectives  (second activity^  step  two)

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     •  EPA Toxic Pollutant Effluent Standards (proposed)

     0  EPA Pesticide Limits

     •  Criteria for the Evaluation of Permit Applications for Ocean Dumping
        of Materials

Emission or Ambient Level Goals for each of the applicable air, water or land
media may be based on control technology capacilities or on ambient factors.
Goals based on control technology capabilities consider performance data on
Best Available Technology (BAT), Best Practicable Technology (BPT), or
engineering estimates .for developing technologies to establish pollutant
emission level indices.  Goals based on ambient factors are dependent on the
health or ecological effects of the pollutant.  Minimum Acute Toxicity
Effluent (MATE)* values and Ambient Level Goals multiplied by appropriate dilu-
tion factors comprise two sets of emission level goals based on ambient factors.
Ambient level goals reflect current or proposed Federal regulations or cri-
teria or, in the absence of such established control levels, they are estimated
permissible concentrations (EPC's) derived from existing toxicity data through
various models.

Social/Economic/Political/Institutional Considerations in developing environ-
mental goals and objectives include a variety of quantitative and qualitative
factors such as the impact of the combustion process on land use and degrada-
tion, water use, and other factors including energy use patterns, social/
cultural patterns, regional and national economy, aesthetics, siting criteria,
and critical materials impacts.

Ambient Pollutant Levels must be considered in setting such environmental
goals as "no significant deterioration" (elimination of discharge based on
not exceeding natural background levels).   This can best be achieved through
extensive data collection and evaluation.

     EPA/IERL-RTP has established a format for evaluating the information in
each of the functional categories discussed above in order to develop
measures of acceptability for each pollutant.   These measures of acceptability
called Multimedia Environmental Goals (MEGs)*are similar to the Emission
or Ambient Level Goals described earlier,  but include consideration of the
other three functional categories.  An example of a MEG for the compound
2-aminonaphthalene is shown in Table D-l.   Table D-2 shows a background
information sheet summarizing all pertinent information used in developing
the MEG for the compound.  Currently, approximately 350 organic and 300
inorganic substances are on the MEG list.

     The third activity in step two is the comparison of the health and
ecological impacts identified earlier with the goals and objectives developed
above.   If all the health and ecological impacts are acceptable by current
goals and objectives,  then the EA process  is finished.   If there is any
question about the acceptability of the impacts due to  insufficient or un-
reliable data,  a data refinement and re-evaluation interaction may be
necessary to draw final conclusions.   If,  on the 'other  hand, the impacts of
the combustion process and its effluents are unacceptable according to
current environmental goals and objectives, then the magnitude of these
impacts must be assessed and methods to ameliorate or control them must be
identified.
*See References 4 and 6 listed in Section 6 of this report.

                                     57

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                  TABLE D-l.   SAMPLE MEG CHART*
MULTIMEDIA
ENVIRONMENTAL
GOALS
                 x
                10C
2-AMINONAPHTHALENE
EMISSION LEVEL GOALS
Aif. prj/m^
'ppm Vol)
Water, yg/l
(ppmWt)
Land, ;jfl/g
'ppmWrt
t. Bawd on BMI Ttchnologv
A Exi.UngSund.vdt
MS PS. BPT. BAT



B, 0«*«lop>ng TachnolofV
Enpn**ring Eidtntm
Ifl&DGoritl



II. Bawd on Ambient Factor!
A. Minimum AcuU
Toxknv Efflutni
B«*do*>
Htajlih EHMU
1.65E2
2.5E3
5.0EO
BaKdon
CcetofcJl
ENicD

1.0E2
2.0E-1
B. Ambwni Le«*l God*
Ba.don
HM|« EHicn
0.4
6
0.012
Bo«)».
Ecolovul
ENwti

50
0.1
,
C ClimiAMMft el
Di****
Natwrrf BKfcpOM'd*



•To ttt multiplied by dilution factor
AMBIENT LEVEL COALS
Air, p(j/m
(pom Vol)
Wrar. u»/l
Ippm Wtl
Und, tig/g
1 pom Wt|
1. Curr«nt or PropOMd Ambwni
Sundard) or Critirii
A. BMM! on
Hvrftfi EttKn



B. Botdoo
Ecolorc^EHira



II. Tonicity Bavtd Eltimauxl
PermiuiUt Conctflfration
A. Biud o»
M.JO EltKn
59
291
0.6
B Biudoi
CcolofaU Ertacn

50
0.1
III. Z«ro ThmhoM PoltutanU
Eittrrund P*> miuiblc ConotnttaMon
B«ttf Oft Hialtft EHvcn
0.4
6
0.012
 ••See Reference 6  listed in Section  C  of this report.
                                  58

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       TABLE D-2.    SAMPLE  MEG  BACKGROUND   INFORMATION   SHEET*
   CATEGORY:
                                                               WLN:    L66J CZ

                                                               STRUCTURE:
   2-AMIKONAPHTHALENE:  C]()H9N (2-naphthylamine,
     i- na ph thy ] am i ne).
     White crystals that darken en exposure to  light and air; volatile with steam.
    Molecular wt:  143.19; mp:  113; op:  306; d:  1.0614'8; vap.  press.:  1 ran
    at 103' C;  volatile  in steam;  slightly soluble in cold *ater.

   NATURAL OCCURRENCE. CHARACTERISTICS. ASSOCIATES COMPOUNDS:
       
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     The assessment of the magnitude of those pollution impacts not considered
acceptable according to the goals and objectives is the fourth activity in
step two (the assessment of health and ecological impacts).   The major
functional categories in this activity include:

     0  Combustion Process Use Projections

     o  Synergistic and Multimedia Impacts
             x

     9  Total Pollutant Load Calculations

     0  Regional Geographic Data

     •  Pollutant Priority Ranking

These functional categories and their elements are shown in Figure D-6.

Combustion Process Use Projections are used to determine the number and
distribution of the combustion process in use both now and in the future
(to the year 2000).  Factors considered in this functional category include
current and projected market size  and fuel supply/demand projections.
Information developed in this functional category is used for total pol-
lutant load calculations.

Synergistic and Multimedia Impacts are key considerations in comprehensive
quantification of pollution impacts.  For example, S02 emitted to the
atmosphere may react with water to form acid and pollute surface arid ground-
water systems.  Another multimedia effect is the leaching of heavy metals
from solid waste disposal sites.  Synergistic impacts such as the additive,
transformation, or enhancement effects of two or more pollutants are also
included in this functional category.

Total Pollutant Load Calculations are based on three types of information:
(1) process loading, (2) loading from other sources, and (3)'natural back-
ground loading.  Total process loading is calculated in simple terms by
multiplying the pollutant load from each combustion process by estimates of
the number of such processes (determined in the process use projections
functional category).  Similarly, pollutant loadings from other conventional
and nonconventional combustion sources must be determined to calculate the
total pollutant loading from all combustion sources.  In addition, natural
background loading from non-manmade sources must be determined in calculating
the total pollutant .load to the environment.

Regional Geographic Data important in quantifying the environmental impacts
include regional population growth projections, and local hydrology and
meteorology.   These data evaluated in terms of the regional total pollutant
load and health effects data should form the basis of environmental impacts
quantification.

Pollutant Priority Ranking is then developed using the above data and degree
of hazard calculations (severity indices).   This ranking is  useful in
identifying standards or pollution control needs.

                                      60

-------
                                                            (see  Figures  D-4 and  u-5)
                           SYNERGISTIC
                             IMPACTS
& MULTIMEDIA
                             • Multimedia  pollutant
                                 distribution loads
                             • Additive, transformation,
                                 and enhancement effects
       COMBUSTION PROCESS
          USE  PROJECTIONS

         • Current market  size
         • Future market projections
         • Fuel  supply/demand .
             projections
       TOTAL POLLUTANT
         LOAD CALCULATIONS

         • Process loading
         • Other sources loading
         • Natural background
                                 MAGNITUDE OF
                                   POLLUTION
                                    IMPACTS
            POLLUTANT  PRIORITY
              RANKING

             • Total  pollutant  load
             • Degree of hazard
               (severity indices)
                                   NO
       REGIONAL GEOGRAPHIC
          DATA

         • Demographic & land use
             patterns & trends
         • Hydrology &
             meteorology
Figure D-6.  Magnitude of pollution  impacts  (fourth  activity,  step  two).

-------
Standards Development Recommendations result when impacts of the combustion
process or its effluents on human health or ecology are serious and no
government standards exist to control these impacts.  The identification of
a need for modification or development of new standards is one of the major
outputs of comprehensive environmental assessment.  Recommendations for
stricter  (or more lax) standards should be ranked in order of priority and
should be justified by specific data.  Information on the degree of control
desired and a time-frame for promulgation would accompany such recommenda-
tions.

     The  third step in a comprehensive environmental assessment, Alternative
Control Strategy Evaluation, is heavily dependent on the results of the
first two steps.  As shown in Figure D-7, the identification, evaluation, and
selection of optimum alternative strategies or technologies to control un-
acceptable environmental impacts of the combustion process or its effluents
include functional categories of information on:

     o  Control Alternatives

     o  Control Strategy Environmental Impacts

     o  Control Strategy Evaluation

Control Alternatives addressing unacceptable pollutant impacts are identified
based on  existing technologies or on developmental technologies expected to
become available in the near future.  Alternatives considered include not
only add-on control systems, but also such strategies as combustion modifica-
tion or fuel switching/mixing.  All reasonable alternatives are identified
in this functional category for further evaluation and selection.

Control Strategy Environmental Impacts must be considered in order to assess
any secondary environmental problems associated with the operation of the
control system itself.  This is necessary since many control systems emit
substance(s) particular to their operation while others produce wastes
(such as  ash or sludge) as by-products of their operation.  Options for the
environmentally acceptable disposal of these wastes are identified and
evaluated in this category.  Cross-media impacts are also important elements
to consider in evaluating the environmental impacts of the control system.
For example, while flue gas desulfurization (FGD)  reduces gaseous pollutant
emissions, it has a cross-media impact by increasing liquid and solid pol-
lutants that require environmental control.

Control Strategy Evaluation is aimed at determining the optimum pollution
control alternative for the particular pollutant,  effluent/emission stream,
or combustion process.   This evaluation could be applied to both R&D scale
emerging control technology or to demonstration-scale or fully commercialized
systems.   In addition to the pollutant removal efficiencies and operational
availabilities of the systems,  economics (including by-product disposal cost)
must also be considered.   Information on energy penalties imposed by the
control strategy, the specific fuel mix availability,  and industry acceptance
of the strategy are also included in this functional category.   In general,
this evaluation is site-specific since ambient concentration levels and local

                                      62

-------
                                                   CONTROL STRATEGY  ENVIRONMENTAL
                                                      IMPACTS

                                                      • Waste disposal options
                                                      • Secondary environmental
                                                          impacts
                                                      • Cross-media  impacts
u>
CONTROL  TECHNOLOGY DEVELOPMENT
  RECOMMENDATIONS

  • Control technology
     modifications
  • Quantified R&D needs
  • Criteria for priorities
  • Time frame
                                                                                MAGNITUDE OF
                                                                                 POLLUTION
                                                                                  IMPACTS
                                                                               see Figure  D-t
                                                                           CONTROL ALTERNATIVES

                                                                             •  Add-on devices
                                                                             •  Combustion modification
                                                                             •  Fuel switch/mixing
                                                         ALTERNATIVE  CONTROL
                                                         STRATEGY EVALUATION
                                                       CONTROL STRATEGY  EVALUATION
                                                       • R&D scale system
                                                       • Demonstration scale system
                                                       • Economics
                                                       • Energy requirements
                                                       e Pollutant Removal  Efficiency
                                                       0 Operational availability
                                                       • Source analysis models (SAM's)
STANDARDS  DEVELOPMENT
  RECOMMENDATIONS

  •  Standards  modifications
  •  Standards  development
  •  Criteria for priorities
  0  Time frame
                            Figure  D-7.  Alternative control strategy  evaluation (step three).

-------
meteorology and hydrology are important factors.  EPA has developed a set of
Source Analysis Models (SAM's)* to rank sources and effluents in priority
order and to evaluate the environmental effectiveness of control alternatives.
Two  sets of  SAM's have been developed to date:

     SAM/IA 	 For Rapid Screening

     SAM/I  	 For Screening  (draft  procedure under review by EPA.)

Development of third set (SAM II ~ A General Approach to Evaluating any U. S,
Regional Site) is not yet complete.
Control Technology Development Recommendations are logically made when
existing or developmental alternatives for controlling adverse environmental
impacts are inadequate.  The recommendations for additional control tech-
nologies are among the most important outputs of an environmental assessment.
These recommendations should be quantified and ranked in priority order for
technological and managerial decision-makers.  The priority recommendations
should be justified on engineering and environmental bases, and should in-
clude information on degrees of control required, additional R&D require-
ments, developmental cost estimates, and projected developmental schedules.

     When optimum alternatives to control unacceptable environmental impacts
are selected, they are applied to the original combustion process and the
entire environmental assessment procedure is repeated for the combination of
the combustion process and the control technology alternative.  The complex,
interactive and iterative nature of an environmental assessment is illustrated
more clearly by combining each of the various steps and activities shown in
Figures D-l through D-7 into the detailed EA methodology diagram shown in
Figure D-8.  Ideally, the iterative methodology of Figure D-8 is continued
until all impact on human health and ecology caused by the combustion process
falls within acceptable limits of current environmental goals and objectives.
*See Reference 5 as listed in Section 6 of this report.

                                      64

-------
COMBUSTION PflOCESS TECHNOLOGY
  CHABACTEB1ST1C!
.  P™.,, ,t.l«-of-.l*-irt
.  Procc« •coim.lc.
                 DOSE-RESPONSE DATA

                   • Tt,r..l»n li.it ..
FUELS CHARACTERIZATION






Type and
Phyilcal
Che»tcal
Energy CO
Fuel hand
Aral 1*611
ource
rtaractertitlci
haractrrtitlci
tent
Ing
ty of fuels
                  INPUT-OUTPUT CHARACTERIZATION

                    • Hal* rlil tuli nee
                    * Sl«dy-it*te, trinitmt. *nd
                       ••Ifunctton pollutant
                       lOJdtngi
ECOLOGICAL  IMPACTS

   • tcology nlited Imptcti
   • An-,  Mter. tnd Itnd qu*Hty
   • Quantified n*dU d«gr«dition
 [COMBUSTION PROCESSES ANDJ
TRANSPORT, THANSFORrlA
FATE MODELS
• Mrl toroloqical and tv
ntit
a Nudel devfloiment
e Eipoture level L«lcul
e Transformation cneais
I ION,

droloqi-


at ions
trjf

T
ANALYSIS TECHNIQUES
• Stapling techniques
• Analysis technique*
• Bioassay techniques

CONTROL TECHNOLOGY DEVELOPMENT
RECOMMENDATIONS
e Control technology aodtf IcJttons
• Quantified RAD needs
• Criteria for priorities
e Tlo* fre*e
i
' t
FIELD TESTS AND SURVEYS
• Control syitan testing
• Coabustlon process testing
• Covprehemstve «*ste strea*
* Level )



i


TH

EPIDEfllOLOGlCAL DATA
• Industry related health dat
• Increased Morbidity *nd •"

r
L

cmroot.
IBPAC
• u«tt
• Sect*
• Croi

I»
^

                                                                             1 AND ECOLOGICAL 1
                                                                             rs IDENTIFICATION!"
                                                                                       B10ASSAY DATA
                                                                                         • Standard bloaitay technique
                                                                                         • Bloaisay criteria
                                                                                         • Control  proceil Itreiip biaaita
                                                                           REFINE DATA MSE
                                                                             •FINE
                                                                             ID/Oft
                                                                    COHTItOL STBATE6V EJCV IROWEMTAL
                                                                       IMPACTS
                                                                       • Umc dtipoul options
                                                                                           CONTROL ALTERNATIVES
                                                                                            • Add-on de*
-------
                                 APPENDIX E

              DEMONSTRATION OF THE EA MATRIX ANALYSIS PROCEDURE


A.   DETAILED DESCRIPTION OF THE EA MATRIX ANALYSIS PROCEDURE

     Information on the content of selected projects was obtained with the aid
of an information checklist outlining the major elements (activities) of the
comprehensive environmental assessment methodology.  This checklist was used
in identifying which of the EA elements were addressed by each of the projects.
Thus, comparison between the contents of each project could delineate all the
R&D efforts addressing a single EA element.

     To facilitate the comparison between projects and, later, their integra-
tion in the unified CCEA program, a code corresponding to the elements of the
EA methodology was developed and applied to the information in the checklist
(Table E-l).   The code specifies whether the particular project merely identi-
fies existing information on the EA element, develops or designs information
about the EA element,  or performs the activity associated with the environ-
mental assessment element.  As an illustration of the use of this checklist,
the programmatic content of the thirteen core projects recommended in the CCEA
program plan is shown in coded form in Table E-2.  From this table,  it is
readily apparent when a given EA element, or cluster of related elements, is
addressed by more than one project or, alternatively, when a given element is
not addressed by any of the projects.

     In addition to the identification of environmental assessment elements
addressed by each selected project, information regarding the fuels, use
sectors, pollutants, and combustion technologies/processes involved is also
necessary for comparative evaluation and future integration.  Table E-3 lists
the codes used for use sectors, fuels, pollutants, and combustion technologies/
processes; Table E-4 shows the various categories of pollution control tech-
nologies.

     The combination of the fuels (Table E-3), use sector (Table E-3), combus-
tion technology/process (Table E-3) pollution control technology (Table E-4),
media, environmental assessment elements (Table E-l), and pollutants (Table E-3),
describes completely all the areas included in a comprehensive environmental
assessment of SCCP.  It is the goal of the CCEA program planning effort to
integrate ongoing projects and recommend new projects to address all practical
and reasonable combinations of the above categories of information.   Table E-5
shows this above information for the 13 recommended core projects.
                                     66

-------
                    TABLE  E-l.    CCEA  PROGRAM ENVIRONMENTAL ASSESSMENT  ELEMENT  CODE
MATRIX ENTRY NOTATION

JE)	Identify Existing  Information or Define
(0)	Develop Information  or  Design
(A)	Perform Activity  (e.g.,  Field or Lab Tests)
(-)....No,  Negative, Not  Addressed
(X)	Not  clear from  available information
(Ll)...Level 1 Analysis
(L2)...Level 2 Analysis
(L3)...Level 3 Analysis
(LO)...Level Other

        COMBUSTION PROCESS  TECHNOLOGY BACKGROUND

Al...State-of-the-Art  Overview

     DEVELOPMENT OF SAMPLING AND ANALYSIS TECHNIQUES

Bl...Sampling Techniques
82...Analysis Techniques
63...Bioassay Techniques
                 FUELS CHARACTERIZATION
Cl .
C2.
C3.
H.
.Fuel  Characteristics
.Type  and  Source
.Fuel  Handling
.Availability
              INPUT-OUTPUT CHARACTERIZATION
Dl...Material Balance
D2...Steady-State, Transient,  and  Malfunction
       Pollutant Loadings

               FIELD TESTS AND SURVEYS

El...Control System Testing
E2...Combustion Process Testing
E3...Comprehensive Waste Stream Characterization
     -  Level 1 Analysis
     -  Level 2 Analysis
     -  Level 3 Analysis
     -  Other Level of Analysis

POLLUTANT TRANSPORT, TRANSFORMATION.  AND FATE  MODELS

Fl...Modeling
F2...Meteorologic and Hydrologic Data
F3...Transformation Chemistry
F4...Exposure Level Calculations

                   DOSE-RESPONSE DATA

Gl...Dose-Sesponse Data Collection and  Correlations

                  ECOLOGICAL DATA

HI....Ecology-Related Impacts
H2....Air,  Water and Land Quality
H3....Quantified Media Degradation Alternatives

                    EP1DEM10LOG1CAL DATA

 II...Industrial Related Health Data
 12...Increased Moroidity and Mortality

                      BIOASSAY DATA

 Jl...Bioassay  Criteria
 02...Bioassay  Techniques
 J3...Control Process Stream Bioassay Data

             EMISSIONS OR AMBIENT LEVEL  GOALS

 Kl...Permissible  Media Concentration
 K2...Criteria  for Establishing Priorities
 K3...Control Technology  Limitations
 K4...MATE
  SOCIAL/ECONOMIC/POLITICAL/INSTITUTIONAL
    CONSIDERATIONS

  Ll...Nonpollutant  Impact Goals (Energy, Social,
         Economic, etc.)
  L2...Quantified Nonpollutant Impacts and Siting
         Cri teria
  L3.. .Critical Materials Impacts
                  STATUTORY  CONSTRAINTS

Ml...Federal/State Standards and Regulations
M2. ..Research Data Base for  Standards

                Ambient Pollutant Levels

N1...0ata Collection and Evaluation

         COMBUSTION PROCESS  USE PROJECTIONS

01...Market Studies
02...Fuel Supply/Demand Projections

          TOTAL POLLUTANT LOAD CALCULATIONS

PI...Process Load Calculations
P2...Other Sources Load Calculations
P3...Natural Background

          SYNERGISTIC AND MULTIMEDIA  IMPACTS

Ql...Multimedia Pollutant Load Distributions
Q2...Additive, Transformation, and Enhancement

             REGIONAL GEOGRAPHIC DATA

Rl...Demographic Patterns and Trends
R2...Land Use Patterns and Trends
R3...Local Hydrology
R4...Local Meteorology

            POLLUTANT PRIORITY RANKINGS

51...Total Pollutant Load Calculations
52...Degree of Hazard (Severity Indices)

               CONTROL ALTERNATIVES

Tl...Add-on Devices
T2...Combustion Modification
T3...Fuel Mixing/Switching

      CONTROL STRATEGY ENVIRONMENTAL  IMPACTS

111...Haste Disposal Options
U2...Secondary Environmental Impacts of Control
       Strategy
U3...Cross-Media Impacts

            CONTROL STRATEGY EVALUATION

VI...Control Assessment Criteria - Quantified
       Effluents and Costs
V2...Control Systems Economics
V3...By-product Disposal  Costs
V4...Energy Penalties
VS...Fuel Mix Availability
V6...Pollutant Removal Efficiency
V7...Operational Availability
V8...Industry Acceptance
V9...Source Analysis Models  (SAM's)

      STANDARDS DEVELOPMENT  RECOMMENDATIONS

HI...Standards Modifications Recommendations
W2...Standards Development Recommendations
W3...Cri teria of Establishing Priorities
W4...Recommendations for Schedules

   CONTROL TECHNOLOGY DEVELOPMENT RECOMMENDATIONS

XI...Control Technology Modifications Recommendations
X2...Quantified R8D Needs
X3...Criteria for Establishing Priorities
XI...Recommendations for Schedules
                                                            67

-------
                                       TABLE E-2(a).  ENVIRONMENTAL  ASSESSMENT ELEMENTS
^^^^-^^^^ Element
Pruject^^-^*
Title. ^""--— -^^

Effluents from Coal-
Fired Utility Boilers
2. Full Scale Scrubber
Testing and Waste
Disposal Program
3. Environmental Assess-
Source NOK Control
Technologies
4. Design Optimization,
Construction, and
Field Verification of
an Integrated Residen-
tial Furnace
5 . Combustion of Hydro—
thermally Treated
Coals
6. Emissions Characteri-
zation of Conventional
Combustion Systems
7. Evaluation of Emis-
sions and -Control
Tec lino logy for Indus-
trial Stoker Boilers
Energy Assessment of
Afterburner Combustion
Systems
9. Test Program for Full-
Stale Dual Alkali
Demonstration 	 LCE
ID. Evaluation of Alter-
natives for Disposal
of Flue Gas Desulfurl-
zat Ion Sludges
U. Field Testing: Appli-
cation of Combustion
Modification to Con-
trol Pollutant Emis-
sions from Power
Generation Combustion
Systems
12. The Impac of Coal-
Fired Pow r Plants on
the Envlr nment
13. Couparatl c Multimedia
ABuessmeii : Well Con-
trolled Coal-Fired &
Oil-Flred Boilers

Al


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-------
TABLE E-2(b).  ENVIRONMENTAL ASSESSMENT ELEMENTS
-— -— ^__^ Element
~~~~-~-^__ Code
Project ~~~---_
Title ^~~~~~-^^

1. Characterization of Efflu-
ents from Coal-Fired
Utility Boilers
2. Full Scale Scrubber Testing
and Waste Disposal Program
3. Environmental Assessment of
Stationary Source NOX
Control Technologies
6. Design Optimization, Con-
struction, and Field
Verification of an Inte-
grated Residential Furnace
c , . ,. u . .
j. combustion 01 Mydrotner—
mally Treated Coals
6. Emissions Characterization
of Conventional Combustion
Systems
7. Evaluation of Emissions
and Control Technology for
Industrial Stoker Boilers

8. Environmental and Energy
Assessment of Afterburner
Combustion Systems
9. Test Program for Full-Scale
Dual Alkali Demonstration —
LGE
10. Evaluation of Alternatives
for Disposal of Flue Gas
Desulfurl zatlon Sludges
11. Field Testing: Application
of Combustion Modification
to Control Pollutant Emis-
sions from Power Generation
Combustion Systems
12. The Impact of Coal-Fired
Power Plants on the
Environment
13. Comparative Multimedia
Assessment: Well Con-
trolled Coal-Fired &
011-Flred Boilers
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-




-------
TABLE E-3.,  USE SECTOR, FUELS, COMBUSTION PROCESS TYPE, COMBUSTION TECHNOLOGY, AND
            POLLUTANT CATEGORIES
                     USE SECTOR   U... Utility
                             ;     C... Commercial/Institutional
                                  R... Residential
                                  I... Industrial

                     FUELS       RO... Residual Oil
                                 DO... Distillate Oil
                                 AC... Anthracite Coal
                                 BC... Bituminous Coal
                                SBC... Sub-bituminous Coal
                                 LC... Lignite Coal
                                SRC... Solvent Refine Coal
                                  R... Refuse
                                 NG... Natural Gas
                                SNG... Synthetic Natural Gas
                                  W... Wood
                     COMBUSTION
                     PROCESS     1C.
                     TYPE  .      EC.
       Internal Combustion
       External Combustion
                     COMBUSTION
                     TECHNOLOGY
                     POLLUTANTS
 TF.
  T.
 RE.
PWB.
PDB.
  C.
  R.
  0.

  1.
  2.
  3.
  4.
  5.
  6.
  7.
  8.
  9.
 10.
Tangential Fire
Turbine
Recipricating Engine
Pulverized Wet Bottom
Pulverized Dry Bottom
Cyclone
Refuse Burner
Other

Particules
SOX
NOX
Inorganics
Organics
Trace Elements
Ions
General
Thermal
Other
                                       70

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         TABLE E-4.   POLLUTION CONTROL TECHNOLOGY CATEGORIES
Pollution Control  Technologies

•  Uncontrolled
   - Air
   - Water
   - Land
   - Other

•  Gas Treatment
   - Mechanical  Collection
   - Electrostatic Precipitators
   - Filters (fabric,  granular, etc.)
   - Liquid Scrubbers/Contactors
       (aqueous, inorganic,  organic)
   - Condensers
   - Solid Sorbents (molecular
       sieves, activated carbon)
   - Incineration (direct, catalytic)

•  Liquids Treatment
   - Settling, Sedimentation
   - Precipitation, Flocculation,
       Sedimentation
   - Centrifugation and Filtration
   - Evaporation and Concentration
   - Distillation, Flashing
   - Liquid/Liquid Extraction
   - Gas/Liquid Stripping
   - Neutralization
   - Biological  Oxidation
   - Wet Thermal Oxidation
   - Activated Carbon  Absorption
   - Ion Exchange System
   - Cooling Tower (wet & dry)
   - Chemical  Reaction & Separation

•  Solids Treatment
   - Fixation
   - Recovery/Utilization
   - Processing/Combustion
   ,- Chemical  Reaction & Separation
   - Oxidation/Digestion
   - Physical  Separation (specific
       gravity, magnetic, etc.)
•  Final Disposal
   - Pond Lining
   - Deep Well Reinjection
   - Burial and Landfill
   - Sealed-Container Storage
   - Dilution
   - Dispersion
   - Ocean Disposal

•  Process Modification
   - Feedstock Change/Fuel
       Treatment
   - Stream Recycle

•  Combustion Modification
   - Flue Gas Recycle
   - Water Injection
   - Staged Combustion
   - Low Excess Air Firing
   - Optimum Burner/Furnace
       Design
   - Alternate Fuels/Processes

0  Accidental Release Technology
   - Containment Storage
   - Spill Cleanup Techniques
                                71

-------
TABLE E-5(a).   DISAGGREGATED PROJECT CONTENT OF THIRTEEN RECOMMENDED CORE"PROJECTS

PRO
NO.
1




2


3




4



FUELS
, BC




BC


RO.DO,
SO, AC,
BC.SBC,
LC,NG,
SNG.A.H
DO,A,H


USE
SECTOR
U




U


U,I,.
C,R


A
R

COMBUSTION
TECHNOLOGY/
PROCESSES
EC/SWDP
SWWP,
HODP, HOWP,
TOP,' TWP
SK.V.C
EC/ SWOP,,
SWWP,
HODP.HOWP,
TOP, TWP,
; SK,V,C
EC.IC/
TB.RE.SW,,
HO.T.SWDP,
SWWP, HODP,
HOWP, TOP,
TWP , SK, V ,
C,WT,FT,
CIByS.O
EC/WT,
ET,, C1B,
S
POLLUTION
CONTROL
TECHNOLOGY
Not
Specified"



Liquid
: Scrubber,
Final Dis-
posal

Combustion
Modification



Combustion
Modification
,»


MEDIA
Air
Water


•
Air
Water
Land


Air
Water
Land


Air


ENVIRONMENTAL ASSESSMENT
ELEMENTS
: Al, Bl,- B2, C2, E3,. Fl , F3V
: H2',= M2, Nl, PI, Q2, U3



Al,, El, E3,. F2, F3, H3,. K3, Ll
; Nl, PI, Ul,. U2, U3, VI, V3, V6


Al,- Bl, B2, B3, C2, Dl,. El,
E2,- Fl, F2, F3, Gl, HI, H2',
H3, Jl, J2-, Kl, K2,, K3',, K4 ,
Ll, Ml,. M2,. Nl, 01, 02 pi
P21,. P3v Ql,. Q2, Rl,, R2, SI,
S2, T2,. T3, U2, VI,, V2, V3,
: V4,, V5',. V6, V7, V9, XI, X2
Al, C2, Dl,. D2,. E2, E3, K3,
Ll, M2, Nl,. PI, T2, T3, VI,
V4, V6, V7,; XI,. X2

POLLUTANTS
ADDRESSED
7, .8, .9




2,9,10,14


3,5,6,8,9,
10,14



1,3,5,6


-------
TABLE  E-5(a)
(Continued)
5

6



7




8
BC

RO.DO,
AC,BC,
SBC.LC



BC,SBC,
LC



NG.DO
R,C,I

U,R,C,I



C,I




C,I
EC/0

EC/SW,
HO,T,
SWDP,SWWP,
HODO.HOWP,
TDP , TWP ,
SK,V,C,
WT, FT,
C1B, S
EC/SK




EC/WT,
FT.C1B,
S,0
Alternate
Fuels
Uncontrolled



Staged Com-
bustion,
Alt. Fuels


Afterburners
Air

Air
Water



Air
Land



Air
Al, Bl, B2, C2, El, Nl, 02, PI,
T3, Ul, U2, VI, V2, V3, V4 , V7
Al, Bl, B2, Cl, C2, C4, Dl , D2 ,
E3, HI, Jl, J2, J3, Kl, K2, K4 ,
Ml, M2, Nl, 01, PI, Ql, SI, S2,
Ul, U2, V9, X2



Al, Bl, B2, B3, Cl, C2, Dl , D2 ,
El, E2, E3, HI, H2, Jl, J2, J3,
K3, LI, M2, Nl, 01, 02, PI, Ql,
Tl, T2, T3, U2, VI, V4 , V5 , V6,
V7, V8,X1, X2
Al, Bl, B2, B3, C2, D2 , El, E2,
E3, H2, H3, K3, M2 , Nl , 01, PI,
Tl, T2, U2, VI, V4, V6, V7 , X2
1,2,3,9

2,3,5,6,8,9,



1,2,3,4,5,6,9




1,2,3,4,6

-------
TABLE E-5(a)
 (Concluded)
9





10


11


12




13




BC





BC


BC,DO,
NG


BC




BC,RO,
DO, SBC



U





U,I i


u :


U




u,i




EC /SWDP,
SWWP, HODP,
HOWP , TDP ,
TWP


EC /SWDP, SWWP, .
HODP, HOWP,
TDP, TWP, SK


IC,EC/TB,
SW,flO,T,
SWDP , SWWP ,
HODO , HOWP ,
TDP, TWP,
EC/SK.C,
SWDP , SWWP ,
HODP , HOWP ,
TDP, TWP


EC/SK.SW,
HO, T, SWDP,
SWWP, HODP,
HOWP , TDP ,
TWP
FGD





FGD


Combustion
Modification


Uncontrolled
or
Not Specified



Uncontrolled
or
Not Specified


Air
Water
Land



Land


Air


Air
Water
Land



Air
Water
Land


Al, Bl, B2, B3, Cl, El, E2 , E3,
Fl, F2, F3, HI, H2, Jl, J2, J3,
Kl, K2, LI, L2, Ml, M2 , Nl , PI,
P2, P3, Ql, Q2, Rl, R2, R3, RA ,
Tl, T2, Ul, U2, VI, V2, V3, VA,
V7
Al, Bl, B2, B3, E3, Fl, F2 , FA,
Gl, HI, H2, H3, Jl, J2, J3, Kl,
LI, L2, Ml, M2, Nl, PI, Ql , R3,
RA, Tl, Ul, U2, U3, VI, V3, V7,
XI, X2.
Al, Bl, B2, Cl, C2, Dl, D2 , El,
E2, E3, H2, Jl, J2, Kl , K3 , LI,
Ml, M2, Nl, PI, T2, U2, VI, VA ,
V6, V7

Al, Bl, B2, B3, Cl, C2, Dl, D2,
E3, Fl, F2, F3, FA, Gl , HI, H2 ,
H3, 12, Jl, J2, J3, Kl, .K2, LI, '
L2, Ml, M2, Nl, P3, Ql, Q2 , Rl,
R2, R3, RA, SI, S2, Ul , U2 , U3,
VI, V3, V6, X2
Al, Bl, B2, B3, Cl, C2, Dl, D2,
El, E3, Fl, Gl, HI, H2, 11, Jl,
J2, J3, Kl, K2, K3, KA , LI, Ml,
M2, Nl, PI, Tl, U2, U3, VI, V2 ,
VA, V6, V7, V9
1,2,3,8,10,14





2,9,10,1A


1,2, 3, A, 7, 8,
9


1,2, 3, A, 5, 8, 9
13, 1A.




1,2,3,5,6,14





-------
     Figure E-l describes the relationships between each of the above categories.
With the type of CCEA program matrix shown in this figure, R&D being conducted
for any given fuel could be traced for each use sector, combustion technology/
process, pollution control technology, media, environmental assessment element,
and pollutant.  Or, if one were interested in all the research being conducted
by the CCEA program on a particular pollution control technology, the CCEA
matrix would facilitate a trace for any of the other parameters being addressed
in terms of that control technology.

     A specific example is included in the next subsection to illustrate the
matrix analysis procedure and to discuss the uses of the results from this
procedure.


B.  SAMPLE EXERCISE OF PROCEDURE

     The use of the EA matrix analysis procedure is demonstrated below for two
of the projects from the list recommended for inclusion in core CCEA program.
The example describes each^project by using the matrix format and graphically
illustrates how potential areas of overlap between the projects and areas of
programmatic gaps may be identified by this procedure.  It also suggests areas
where coordination and information exchange could benefit both projects.

     The two projects selected for the example are second and ninth on the list
of recommended core CCEA projects.  They were selected here because of the
similarity in their subject areas.  The two projects are sponsored by the
Emissions/Effluent Technology Branch (EETB) of the Utilities & Industrial
Power Division (UIPD), IERL-RTP.  Both the projects deal with the evaluation
of full-scale scrubbers operated by Louisville Gas and Electric.  S02 removal
efficiency as well as the environmental impacts of the waste sludge disposal
are evaluated by these two projects.

     Project number 2 is titled "LG&E Full-Scale Scrubber Testing and Waste
Disposal Program."  The project is conducted by Louisville Gas and Electric
and is funded at approximately $1.8 million for the period covering 3/76 to
9/78.

     Project number 9 is the "Test Program for the Full-Scale Double Alkali
Flue Gas Desulfurization Utility Demonstration."  The contractor is the Research
and Engineering Division of Bechtel Corporation.  The project is funded at
approximately $1.66 million for the period covering 6/77 to 11/80.

     Figure E-2 shows pertinent information on project content for both in
the format used by the matrix analysis procedure.  This information was
extracted from the CCEA Project Information Checklists as completed by the
RTI survey.  The upper portion of the figure indicates that project number 2
is concerned with SOX, trace metals, ions, and other (TDS) pollutants dis-
charged to the air, water and land media by a liquid contact scrubber and its
associated solid waste disposal practices.  This research applies to nine
types of external combustion utility processes using bituminous coal.  The
14 specific programmatic areas addressed by project two are delineated under
the category labeled "E.A. Elements."

                                     75

-------
     Fuels
(13 categories)
_.Use. Sector
'(4 categories)
 Combustion Tech/
Combustion Process
  (15 categories)
Pollution Control
Technology'
 (47 categories)
    Media
(3 categories)
Environmental
 Assessment
  Elements
(72 elements)
•  Pollutants '
  Addressed
(14 categories)
                          Figure  E-l.   Matrix  of  environmental assessment  elements.

-------
FUEL
USE
SECTOR
COMBUSTION
TECHNOLOGY/
PROCESS
CONTROL
TECHNOLOGY
                                                                     MEDIA
                                                                           E.A. ELEMENTS
                                                                                                                     POLLUTANTS
BITUMINOUS
COAL


UTILITY


EC/SWDP.SWWP,
HODP.HOWP.TDP,
TWP,S,K,V,C
                                                                                       A1{E),E1(A),E3(L2),F2(E),
                                                                                       F3(E),H3(E),L1(E),N1(E),
                                                                                       P1(A),R3(E),U1(A),U2(D),
                                                                                       V1(D),V3(E,D)
                                PROJECT NO.  1:
                               LG&E FULL-SCALE SCRUBBER TESTING AND WASTE
                               DISPOSAL PROGRAM

BITUMINOUS
COAL

*

UTILITY



EXT. COMB/
SWDP.SWWP,
HODP.HOWP,
TDP,TWP,SK,
v,c
                                                                                      A1(E),B1(D),B2(D),B3(D),
                                                                                      C1(A),E1(A
                                                                                      Fl(D),F2(E
                                                                                 ,E2(A),E3(L2),
                                                                                 ,F3{E),H1(D)
                                                                                      H2(D),J1(E  ,J2(E),J3(D),
                                                                                      K1(D),K2(E),L1(E),L2(E),
                                                                                      M1(E),M2(E),N1(E),P1(A),
                                                                                      P2(E),P3(E),Q1(0).Q2(E),
                                                                                      R1(E),R2(E),R3(E),R4(E),
                                                                                      T1(E).T2(E.A),U1(A).U2(D)
                                                                                      V1(D),V2(D),V3(D),V4(D),
                                                                                      V7(D)
                                PROJECT NO. 9:
                               TEST PROGRAM FOR THE FULL-SCALE  DOUBLE ALKALI
                               FGD UTILITY  DEMONSTRATION
                                  Figure E-2.  Project  information  in matrix format.

-------
     The programmatic content of project number 9 is shown similarly in the
lower half of Figure E-2.  This project is concerned with participates, SOX,
NOX, organics, ions, and other (unspecified) pollutants to air, water, and
land from a liquid contact scrubber and its associate sludge disposal.  Again,
this is done in the context of nine external combustion utility processes
using bituminous coal, and the 41 specific programmatic areas addressed are
shown under the EA Elements category.

     Comparison of the information matrices for projects 2 and 9 identifies
subject areas common to both projects, as shown diagrammatically in Figure E-3.
Both projects address scrubbers and waste disposal practices of bituminous
coal-fired utility external combustion processes, and both projects study air,
water, and land impacts.  However, only SOX and ions appear to be the pollu-
tants explicitly studied in both.*  In addition, the results of this procedure
indicate that only 10 environmental assessment elements are common to both
projects.  These 10 common elements represent areas of apparent programmatic
overlaps.  This indication should draw the attention of the program managers for
closer examination of those specific activities in order to coordinate, exchange
information, or effect redirection of either or both concerned projects.

     One area of apparent overlap, for example, is EA element Ul—Waste Disposal
Options.  Since both projects address full-scale nonregenerable FGD systems,
sludge disposal is a common problem.  Although the physical and chemical
properties of the two sludges may be slightly different, it is likely that
the process of evaluating final disposal options is quite similar in both
cases.  The results of such an evaluation process in one project would be of
great help to the second project.  Alternatively, if a coordinated generic
evaluation is conducted, then each project would need only to superimpose
site-specific information for its final evaluation.  This would provide a
common or "standard" approach to future sludge disposal options evaluation,
and reduce the effort required by each individual project.

     Similar comments could be applied to EA elements U2 and U3—Secondary
Environmental Impacts of Control Strategy and By-Product Disposal Costs,
respectively.  A more detailed examination would be necessary for any con-
clusions in the apparent overlap of EA element Al—State-of-the-Art Overview
of the combustion process technology background.  The level of detail of each
of the state-of-the-art overviews could differ according to specific project
needs.  Information exchange or a coordinated effort, however, would be highly
desirable since both projects address the same nine types of bituminous coal-
fired utility combustion processes.

     Areas of programmatic gaps are identified by comparing the activities of
project 2 and project 9 against the entire set of activities suggested by the
comprehensive environmental assessment methodology.  Figure E-4 shows the
EA  Elements and pollutants not addressed by either project for the given
common area of fuel, use sector, combustion technology/process, control tech-
nology and media.  This does not imply that no R&D is being conducted anywhere
 It is difficult to identify any other specific pollutants since the checklist
 and matrix analysis procedure coding provide limited classification.

                                     78

-------
FUEL
 USE
SECTOR
CUMDUbllUN
TECHNOLOGY/
PROCESS
                                                        CONTROL
                                                       TECHNOLOGY     MEDIA
E.A.  ELEMENTS
POLLUTANTS

BITUMINOUS
COAL



UTILITY



EC/SWDP,
SWWP.HODP,
HOWP.TDP,
TWP.SK.V,
c
                                                                                          P1(A),R3(E),U1(A),U2(D),
                                                                                          V1(D).V3(D)	
                          Figure E-3.  Areas of apparent programmatic -overlaps  between  project nos. 2 and 9.

-------
FUEL
  USE
SECTOR
                                 COMBUSTION
                                 TECHNOLOGY/
                                 PROCESS
 CONTROL
TECHNOLOGY
MEDIA

BITUMINOUS
COAL

fewlilTTI T TV 1 ^fc


EC/SWDP,
SWWP.HODP,
HOWP.TDP,
TWP.SK.V,
C
E.A. ELEMENTS
                                                                                         ALL  E
                                                                                         ,B1,B2
                                                                                          D2.E1
                                                                                      G1.H1.H2
                                                                                      J3.K1.K2
                                                                                      M1.M2.N1
                                                                                          Q2.R1
                                                                                      T1.T2.T3
                                                                                      V3.V4.V5
                                                                                      W2.W3.W4
                                                                              .A.  ELEMENTS
                                                                              .B3.C1.C2.C3.C4,
                                                                              ,E2,E3.F2,F3.F4,
                                                                              ,H3,I1,I2,J1.J2,
                                                                              ,K3,K4,L1,L2,L3,
                                                                              ,01,02,P1,P2,P3,
                                                                              .R2.R3.R4.S1.S2.
                                                                              .U1.U2.U3.V1.V2,
                                                                              ,V6.V7,V8,V9,W1.
                                                                              .X1.X2.X3.X4)
                                                                                       C2,C3,C4.D1,D2,F4,G1,I1,
                                                                                       I2,K3,D4,L3,01,02,S1,S2,
                                                                                       T3.U3.V5.V6.V8.V9.W1.W2,
                                                                                       W3.W4.X1.X2.X3.X4	

                                                                                       C2,C3,C4,D1,D2,H3,I1,I2,
                                                                                       K3,K4,L3,01,02,S1,S2,U3,
                                                                                       V5,V6.V8,V9,W1,W2,W3,W4,
                                                                                       X1.X2.X3.X4	
                                                                                       B1,B2,B3,C1,C2,C3.C4,D1,
                                                                                       D2,E2,F1,F4,G1,H1,H2,I1,
                                                                                       I2,J1,J2,J3.K1,K2.K3,K4,
                                                                                       L2,L3,M1,M2,01,02.P2.P3,
                                                                                       Q1,Q2,R1,R2,R4,S1,S2.T1,
                                                                                       T2,T3,U3,V2,V4,V5,V6,V7,
                                                                                       V8.V9,W1>W2,W3,W4,X1,X2.
                                                                                       X3.X4	
                                                POLLUTANTS
                                                                                                              Elements
                                Figure E-4.   Areas of apparent programmatic  gaps  in project nos. 2 and 9.

-------
to fill these gaps, but merely that these two particular projects do not
address them.  As other selected R&D projects are integrated through the use
of the matrix analysis procedure, the programmatic gaps would begin to be
filled and a comprehensive environmental assessment of conventional combus-
tion processes would near completion.

     The example above is intended to demonstrate the matrix analysis proce-
dure in broad, simple terms.   The full use of the procedure in the CCEA
program planning effort is somewhat more involved, and the- conclusions drawn
from the procedure are more specific in nature than the ones illustrated here.
                                    81

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                                 APPENDIX F

                 ALTERNATIVE MANAGEMENT STRUCTURES FOR CCEA
A.   ALTERNATIVE MANAGEMENT STRUCTURES

     Development of alternative management structures for the CCEA program
is complicated by three factors.  First, the program encompasses R&D projects
and related activities in various stages of development or completion.  Some
are ongoing and near completion; some are planned and currently being initia-
ted; still others are yet to be defined as a result of CCEA activities.   Second,
the program includes projects being performed (or planned) by different
divisions within EPA/IERL-RTP, by other parts of EPA, and by Federal agencies
other than EPA. The non-EPA projects are funded totally or partially under the
Interagency Energy/Environment R&D Program.  A third important factor relating
to CCEA management is that the products of the program are intended for  use not
only in the field of combustion technology and pollution control, but also in
the area of standards setting and environmental impact analysis.  Hence, the
management of the program would benefit from advice and inputs of the full
spectrum of potential users as well as direct participants in the R&D effort.

     Since the CCEA program seeks not only to coordinate, but possibly to
redirect, existing projects as well as to initiate new R&D activities, the
argument could be advanced that its direction should be placed at a level
that has some degree of managerial or budgetary control over most of the
organizations where CCEA-related activities are performed—for example,  at
the level of the Interagency Energy/Environment R&D Program administered by
EPA's Office of Research and Development.

     On the other hand, the principal consolidated center of interest and
technical expertise in the environmental assessment of SCCP within the
Federal R&D establishment is EPA/IERL-RTP.  This Laboratory is also the  princi-
pal Federal participant in combustion related environmental assessment activi-
ties.  Although this Laboratory is organizationally a part of EPA's Office of
Research and Development, a strong argument can be advanced that CCEA program
management should be centered at IERL/RTP because most of the CCEA activities
take place there.

     In the light of the foregoing conditions and considerations, five alter-
native management structures for CCEA, together with their advantages and
disadvantages, are set forth.
                                      82

-------
Alternative 1.  Existing Organizational Structure

     The CCEA program would be managed within the Process Technology Branch
of the Utilities and Industrial Power Division of IERL/RTP (see Figure F-l).
Major policies of the program would be established by the Division Director
in consultation with the Laboratory Director and the Branch Chief.  All phases
of program activity, from initial planning to publication of results,
including management of contractors, would be carried out under direction of
the CCEA program officer, who would be assisted by a staff of the required
size and would be directly responsible to the Chief of the Process Technology
Branch.

     All communication pertaining to the CCEA program would proceed through
normal Laboratory/EPA channels, with the exception of communication between
the program officer and a liaison officer at the Office of Energy, Minerals,
and Industry at EPA Headquarters, since the OEMI liaison officer would be an
"ex-officio" advisor to the CCEA program manager.

Alternative 2.  Existing Structure Augmented by Advisory and Working Groups^

     The CCEA program would be managed within the Process Technology Branch
of the Utilities and Industrial Power Division of IERL.  However, the Division
Director would chair a CCEA Advisory Committee comprised of representatives
of other offices within EPA as well as other Federal and industry organizations
(see Figure F-2).  As in Alternative 1, CCEA policy would be set by the Division
Director, but in Alternative 2 this would be done in consultation with his
Advisory Committee in addition to the Laboratory Director and Branch Chief.

     All phases of CCEA activity would be managed directly by a program
officer, who would report to the Chief of the Process Technology Branch.
The program officer would again be assisted by a full-dedicated staff of
the required size, and would chair a CCEA Working Group composed of project
officers of all CCEA related projects within EPA  and selected contractor
representatives.  The OEMI liaison officer and the Process Technology Branch
Chief would be "ex-officio" members of the Working Group.

     All CCEA-related communication would, again, flow through normal Labora-
tory/EPA channels.

     Under this alternative, all managerial activities and responsibilities
would remain within the UIPD Division, but advice would be available from
external organizations and program participants.

Alternative 3.  Division Level EA Unit

     This structure would require the formation of a division-level organiza-
tional unit which would manage all environmental assessment activities.  Such
an organizational unit would logically include three component subunits that
would address the three main areas of environmental assessment activity at
IERL:
                                     83

-------
                       EPA HEADQUARTERS
                        OFFICE OF R&D
                 OFFICE OF ENERGY,
               MINERALS AND INDUSTRY
                     IERL
                (LAB DIRECTOR)
                                        EPA Headquarters
                                         OEMI Liaison
                         Process Technology
                          Branch
                         (Branch Chief)
                                   CCEA PROGRAM
                                   (Program Officer)
                                             CCEA SYSTEMS
                                             CONTRACTOR AND
                                             OTHER CONTRACTORS
Figure  F-l.   Alternative 1:   Existing structure.
                           84

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                                         IERL
                                       DIRECTOR
                                    (Lab Director)
                        Utility and
                      Industrial Power
                         Division
                    (Division Director)
                           (CCEA  Policy)
                              Process Technology
                               Branch
                             (Branch Chief)
                                      CCEA  Program
                                       Officer
                                       (Program   L
                                        Execution)
CCEA Advisory Committee
UIPD Director, Chmn.
- Directors of all  IERL/RTP Div.
- Representative of each EPA Office
    Involved in Setting Standards
- DoE
- TVA
- Industry
- Expert Consultants
                    Liaison with
                    Office of
                    Energy, Minerals
                    and Industry
                                                          CCEA WORKING  GROUP

                                                        CCEA  Program  Manager,  Chmn.
                                                        Project Officers of
                                                         Related  Projects
                                                        Selected  Contractors
                                                        PTB  Chief
Figure F-2.   Alternative 2:  Existing structure plus  advisory committee and working group.
                                        85

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     •  Environmental assessment of conventional combustion processes

     •  Environmental assessment of advanced combustion systems, synthetic
        fuel production, and fuels cleaning

     •  Development of environmental assessment methodologies, procedures
        and techniques

     Given the existence of such an organization, the CCEA program would be
managed by an Executive Committee chaired by the director of the division-
level unit and comprised of representatives of other IERL/RTP divisions, other
EPA program offices and the CCEA program manager (see Figure F-3).

     The Executive Committee would establish CCEA policy and review program
goals and objectives in consultation with the Laboratory Director and with
the advise of two Advisory Groups, one of which would include representatives
of EPA program offices and other appropriate organizational units; the other
would consist of non-EPA participants (see Figure F-3).  The intent of this
structure is that all interested EPA components would be represented on either
the Executive Committee or the Working Group; also that issues pertaining only
to EPA could be discussed with the Advisory Group consisting of EPA partici-
pants only, without the need of involving participants from other organizations.

     Day-to-day activities of the CCEA program would be managed by a CCEA
program manager responsible to the Chairman of the Executive Committee.
Logically, the program manager would be the same person that heads the
organizational subunit responsible for conventional combustion environmental
assessment activities.  The program manager would be assisted by a staff of
appropriate size arid expertise, and by a working group of similar make-up to
that in Alternative 2.  A principal function of the working group is to insure
coordination between CCEA program management and the project officers immedi-
ately responsible for the performance of all CCEA-related projects within
EPA.

     Communication between the program manager and any EPA participant in the
CCEA program would be direct.  Communication between the program manager and
OEMI Headquarters would be through the OEMI/CCEA liaison, with information
copies to the Chairman of the Executive Committee.   Communication with any
other component of EPA would go through the Executive Committee Chairman.
Communication with organizations external to EPA would go through the Labora-
tory Director's office.

Alternative 4.  Program Office at Laboratory Level

     The CCEA program would be managed at IERL/RTP Laboratory level by an
Executive Committee chaired by the Director of the Utilities and Industrial
Power Division arid comprised of the Directors of other IERL/RTP divisions
and the CCEA program manager.  The Executive Committee would have two advisory
groups, as in Alternative 3 (see Figure F-4).
                                      86

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                                                                    IERL/RTP
                                                               Laboratory Director
                                                                                                           ENVIRONMENTAL ASSESSMENT
                                                                                                            (Division-Level Unit)
                              ADVISORY GROUP
                              (EPA Offices)
                              - Offices  Involved in
                                 Setting Standards
                              - HERL
                              - Ecological Effects
                              - IERL/CINN
    CCEA EXECUTIVE
    .  COMMITTEE
    (CCEA Policy)
Director of  Environmental
 Assessment,  Chairman
Directors of Other IERL/RTP
 Divisions
CCEA Program Manager
CO
-J
ADVISORY GROUP
  (Non-EPA)
DoE
TVA
EPRI
Industry
Univ. & Technical
 Experts
                                                                                   EA  of Conventional
                                                                                   Combustion (CCEA)
                                               EA of Advanced
                                               Combustion and
                                              Fuels Processing
                                                                                       CCEA WORKING GROUP
                                                                                      Program Manager, Chairman
                                                                                      Project Officers of Key
                                                                                      CCEA Projects Within EPA
                                                                                      Liaison With Key Non-EPA
                                                                                      Projects
                                                                                      Representative of Systems
                                                                                      Contractors
                                                                                      Other Contractors
                                                                                          CCEA Staff
                                                                                          Contractors
                                                          Figure F-3.    Division  level EA  unit.

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                                                                 IERL/RTP
                                                            Laboratory Director
                             Utilities and Industrial
                                 Power Division
                            Industrial Processes
                                 Division
                        Energy Assessment
                       and Control Division
OO
OO
 ADVISORY GROUP
  (EPA Offices)
- Representatives of
   all EPA Offices
   Involved in
   Standards Setting
- HERL
- Ecology Effects
- IERL/CINN
ADVISORY GROUP
  (Non-EPA)
 - DoE
 - TVA
 - EPRI
 - Industry Reps.
 - Univ. & Other
    Experts
                                                                                                   CCEA PROGRAM OFFICE
                                                                                                   Executive Committee
                                                                                                      (CCEA Policy)
                                                                                                   - UIPD Div. Dir.,
                                                                                                      Chairman
                                                                                                   - Directors of Other
                                                                                                      IERL/RTP Divisions
                                                                                                   - CCEA Program Manager
                                                                                                          WORKING GROUP
                                                                                                       (Program Execution)
                                                                                                     CCEA Program Manager,
                                                                                                      Chairman
                                                                                                     Project Officers of Key
                                                                                                      CCEA-Related Projects
                                                                                                      in EPA
                                                                                                     Liaison with Key Non-EPA
                                                                                                      Projects
                                                                                                     Rep. of Systems Contractor
                                                                                                     Other Contractors
                                                                                                           CCEA Staff
                                                                                                           Contractors
                                   Figure F-4.   Alternative 4:    Executive committee  and laboratory level.

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     The Executive Committee would establish CCEA policy in consultation with
the Laboratory Director and with the advice of Advisory Groups composed of
representatives of other Federal agencies,  industry groups, and expert con-
sultants.  These groups would be similar in make-up to those in Alternative 3.

     Day-to-day program activities would be managed by a CCEA program manager
responsible to the Chairman of the Executive Committee.  The program manager
would be assisted by a staff of appropriate size and by a Working Group of
similar make-up to that in Alternative 3.

     Communication between the program manager and any EPA participant of the
CCEA program would be carried out directly.  Communications with any other
component of EPA would go through the Executive Committee Chairman.   All
communications with organizations external to EPA would go through the Labora-
tory Director's special liaison representative on the Executive Committee.

Alternative 5.  Executive Committee at Interagency (Headquarters) Level

     This structure is similar to that of Alternative 4, except that the
Executive Committee is chaired by a representative of the Interagency Energy/
Environment Program and reports to the Deputy Assistant Administrator for
Energy, Minerals, and Industry within EPA's Office of Research and Development
(see Figure F-5).

     Under this arrangement, the policy-making functions of the CCEA program
would be essentially removed from IERL/RTP except to the extent that IERL/RTP
is represented on the Executive Committee.   Day-to-day project management
remains within IERL/RTP, and primarily within UIPD, although the CCEA program
manager is responsible to the Chairman of the Executive Committee for all CCEA
activities.

     Communications between the CCEA program manager and all EPA participants
in the CCEA Program are made directly.  Communications with other EPA components
or with external organizations are made through the Executive Committee Chairman
or through normal OEMI channels.
B.  ADVANTAGES AND DISADVANTAGES OF ALTERNATIVE STRUCTURES

     Each of the management structures identified above has advantages and
disadvantages.   These involve the following factors:


     o  Ease of establishing the organizational structure for program
        management.

        A management structure that can be easily set up would enable the
        program to function almost immediately, while one that is complex
        or administratively difficult to establish could impose unacceptable
        delays.
                                     89

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                         OFFICE OF ENERGY, MINERALS AND INDUSTRY..	
       Energy Processes
          Division
                                                                        I
     Industrial  and
  Extraction Processes
        Division
        I
              CPA WORKING SECTOR GROUP
                    (Advisory)

           (MEMBERS)

           - DOE
           - EPRI
           - TVA
           - lERLs
           - Industry Reps.
           - Outside Experts
       EXECUTIVE COMMITTEE
   (CCEA Policy & Coordination)

(MEMBERS)

- Interagency Energy/Environment
   Program (Chairman)
- IERL Directors
- UIPD Director

- EPA Offices involved in
   Standards Setting
        I
Liaison with
HQ/OEMI
         WORKING  GROUP
      (Program Execution)

 (MEMBERS)
j- UIPD Program Manager,  Chmn.
   CCEA Staff
   Systems  Contractor
   Project  Officers  of  all  Key
    CPA-related Projects  within
    EPA
   EPA Liaison with  all Key
    non-EPA Projects
                                        Contractors
         Figure F-5.  Alternative 5:  Executive committee at headquarters level.
                                          90

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     •  Scope of interests, needs and opinions available to CCEA program
        management.

        While most of the project activities related to CCEA are managed by
        IERL/RTP, many others are managed and performed by other organizations.
        Also, two of the principal goals of CCEA'relate to standards
        development—a non-IERL function.  It is important that the needs
        and opinions of all major participants in CCEA and all major users of
        its products be known to the management of the program.

     o  Ease of communication between CCEA program management and interested
        or participating organizations,  both within and external to EPA.

        Free access  and flow of information on recommended program content,
        user needs and priorities, and project status will permit CCEA program
        management to operate a more responsive, efficiently-run program.
        Also, ready  access of CCEA-information and findings should increase
        the utility  of the program to potential users of its products.

     o  Freedom of CCEA program management personnel from competing demands.

        CCEA is a major, long-term program with the difficult and complex
        function of  integrating and coordinating activities in several organi-
        zations.  It cannot be effectively operated on an intermittant basis,
        but must provide for continuity of effort.  A fully dedicated program
        manager and  support staff is needed for a program of this magnitude
        and comp1exi ty.

     o  Availability of required expertise to program management.

        The program  management of a technically oriented program of this
        nature must  have direct and immediate access to expert technical
        advice and information.

     o  Capability of CCEA program management to influence the direction
        of CCEA-related projects or other activities.

        EPA management or budgetary control at a sufficiently high level
        must be involved to insure that project redirection be implemented
        as needed.

The above criteria are not of equal weight.  Some, such as the "ease of
implementation" criterion, can virtually represent a no-go situation if the
difficulty of implementation implies a long delay (say a year or more) in
implementing a given management structure.  Others,  such as the capability
of CCEA management to influence other projects or programs, have implications
for whether or not the CCEA program can be operationally effective other than
as a scientific data gathering exercise.  The other criteria relate to how
well, or how easily, the program can achieve defined objectives.
                                     91

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     The management alternatives identified in the preceding subsection are
analyzed in terms of the above factors, as follows:

Alternative 1.  Existing Structure

     Advantages:

     -  Can be implemented immediately;

        Technical expertise readily available.

     Disadvantages

        No direct provisions for obtaining expression of needs and interests
        either from participants or potential users.  Information input from
        IERL participants is through existing communication channels —
        not directly.

     -  Communication with non-IERL participants through established channels
        — not directly.

     -  Program officer subject to competing demands from management at Branch,
        Division, and higher levels.

     -  Little opportunity to influence direction of programs outside UIPD,
        except through intervention of Laboratory Director or higher levels
        of management.

Alternative 2.  Existing Structure Plus Advisory Committee (Division Level)
and Working Group (CCEA Program Level)

     Advantages:

        Easily established.

        Required technical expertise readily available.

     -  Provides  a channel of communication for opinions and interests of
        major participants and users.

        Provides  direct communication and liaison with project officers
        of all CCEA-related projects within IERL (but not with those outside
        IERL).

     Disadvantages:

        Inputs from non-UIPD participants is strictly advisory,  with only
        limited potential for affecting program management.

        CCEA influence on projects outside UIPD may require  participation
        of Laboratory Director.
                                      92

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Alternative 3.  Division Level EA Unit

     Advantages:

     -  Consolidates all major environmental assessment activities at IERL/RTP
        under a single line management, thereby facilitating planning, coor-
        dination, and direction of all EA projects within IERL/RTP.

     -  Provides for the direct communication of needs, opinions, and interests
        of all CCEA participants and users at all desired levels.

     -  Provides channels for suggesting redirection of EA projects outside
        IERL/RTP.

        Has separate advisory committees composed of (1) EPA participants
        and (2) non-EPA participants, thereby permitting matters internal
        to EPA to be discussed separately from matters of interest to all
        participants.

     -  Provides the required level of technical expertise at all levels.

        Removes the program manager from competing demands at branch level.

     Disadvantages;

        Requires relatively extensive reorganization of Laboratory activities,
        including creation of a new division-level organization unit with
        attendant re-alignment of work assignments and responsibilities among
        divisions.

Alternative 4.  Program Office at Laboratory Level

     Advantages;

        Provides for direct communication of needs, opinions and interests
        of all participants and users at all desired levels.

     -  Provides a means of directly influencing IERL/RTP project direction,
        as needed, by working through the office of the Laboratory Director.

     -  Provides a means of suggesting redirection of projects outside IERL/RTP.

        Provides the required levels of technical expertise at all levels.

        Removes program manager and staff from competing demands at Branch
        and Division levels.
                                      93

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     Disadvantages:

        Would require establishing a Laboratory-level separate project office
        outside the existing management structure.

Alternative 5.  Executive Committee at Interagency Level (Headquarters)

     Advantages:

        Provides for direct communication of needs, opinions, and interests
        at all desired levels.

     -  Provides a means of directly influencing project direction as needed
        throughout EPA and other interagency organizations.

     Disadvantages;

     -  Extremely difficult to establish the organizational structure — cannot
        be easily implemented because of number of levels of management involved.

     -  Uncertain whether required technical expertise would be readily available
        to program manager.

     -  Uncertain whether program manager would be sufficiently close to the
        scene of major CCEA activity (IERL/RTP) to permit effective program
        operation.


C.  COMPARISONS AMONG ALTERNATIVE MANAGEMENT STRUCTURE

     The five alternative management structures outlined above do not exhaust
the range of alternatives, but are considered to span the range with respect
to complexity and ease of implementation.  Alternative 1 is simplest and most
easily implemented.  Alternative 5 is the most organizationally complex and
probably the most difficult to implement because of the number of levels of
management involved.

     In view of the anticipated problems in implementing Alternative 5
(Headquarters-Level program management), together with its organizational
complexity and tenuous chains of authority, responsibilities, and communica-
tion (within the management structure—not among technical participants of
the Program), MITRE ranks this alternative as lowest among the five considered,
and recommends against its adoption.

     Alternative 1 (Existing Structure), while easily implemented, does not
provide the means of obtaining advice,.suggestion, and expressions of interest
and need from CCEA participants and users of CCEA outputs outside of IERL/RTP.
This lack, together with the other disadvantages cited above, is considered
by MITRE to impair the functioning of the program manager to a degree that
                                      94

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militates against the use of this alternative.  MITRE ranks this as next to
lowest among the five considered, and recommends against its adoption.

     Alternative 2 (Existing Structure Plus Advisory Committee and Working
Group) has many of the desired features, principal among which is its ease
of implementation.  Because it has no crippling disadvantages and can be
implemented almost immediately at the Division level (including the appoint-
ment of the advisory and working groups), MITRE ranks this as an acceptable
transition measure pending implementation of a suitable long-term management
structure.

     Alternative 4 (Laboratory-Level Management) has all of the desired
characteristics with regard to the ease of obtaining user and participant
advice, ability to influence most of the significant efforts, and ease of
communication.   It provides a high level of visibility to the CCEA program
However, this alternative would require development of a new organizational
unit—a program office—attached to the Office of the Laboratory Director.
Also, it does not imply the degree of organizational stability that is generally
associated with a line-management organizational unit.   MITRE ranks this as
second of two acceptable alternatives for the long-term management of the CCEA
program.

     Alternative 3 (Division-Level EA Unit) also provides all of the desired
characteristics with regard to ease of obtaining user and participant advice,
ability to influence the direction of all significant EA projects, and ease
of communication.  Most of these characteristics are achieved without the
need for direct involvement of the Laboratory Director's Office.  In common
with Alternative 4, this alternative also requires the creation of a new
organizational unit.  The attendant restructuring of the organization and
realignment of responsibilities is more extensive than that implied by
Alternative 3,  and could, therefore, introduce serious delays in carrying out
the program.  On the other hand, Alternative 4 provides a more stable and
coherent organizational structure than does Alternative 3.  Consolidation of
all major EA activities into a single organizational unit at the division
level is consistent with the increasing importance of environmental- assessment
activities relative to the overall missions of the Agency.  For these reasons,
MITRE ranks this as first of two acceptable alternatives  for the long-term
management of the CCEA program.
D.   RECOMMENDATIONS FOR CCEA MANAGEMENT STRUCTURE

     MITRE recommends that EPA, in planning the implementation of the CCEA
program, give favorable consideration to the adoption of the organizational
structure described in Alternative 3 (Division-Level EA Unit) for the long-
term management of the program.  Since it would be difficult to implement
immediately, MITRE recommends implementation of Alternative 2 (Existing
Structure Augmented by Executive Committee and Working Group) as soon as
practical, and phasing into the Alternative 3 structure within a year.   This
approach will (1) permit continuous functioning of the CCEA program,  (2) pro-
vide additional needed inputs from a broadly based advisory committee of
principal CCEA participants and potential users of CCEA products, and (3) bring


                                      95

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the project officers of key CCEA-related projects into the CCEA management
process at the working-group level.

     Implementation of the Alternative 3 structure will provide additional
managerial leverage to the project manager as well as enhanced communication
among participants and users of the program's products.  The two stage imple-
mentation of the organizational structure will permit retention of the effec-
tive participants of the Alternative 2 advisory committees while providing an
opportunity to replace those participants whose performance was not satisfactory.
                                     96

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                                TECHNICAL REPORT DATA
                         (Please read Instructions on the reverse before completing)
 1. REPORT NO.
  EPA-600/7-78-140
                                                     3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
A Program for the Environmental Assessment of
 Conventional Combustion Processes
            5. REPORT DATE
              July 1978
            6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
Deepak C. Kenkeremath, C. Grant Miller, and
 J. Bruce Truett
                                                     8. PERFORMING ORGANIZATION FIEPORT NO
                M-78-63
9. PERFORMING ORGANIZATION NAME AND ADDRESS
The Mitre Corporation/Me trek Division
1820 Dolley Madison Boulevard
McLean, Virginia  22101
            10. PROGRAM ELEMENT NO.
            EHE624A
            1 1. CONTRACT/GRANT NO.
            68-01-3539 and
              68-01-3188, Task 86
12. SPONSORING AGENCY NAME AND ADDRESS
 EPA, Office of Research and Development
 Industrial Environmental Research Laboratory
 Research Triangle Park, NC  27711
                                                      13. TYPE OF REPORT AND PERIOD
                                                      Task Final; 3/77-5/78
                                                                           COVERED
            14. SPONSORING AGENCY CODE
              EPA/600/13
15 SUPPLEMENTARY NOTES TERL_RTP project officer is Wade H. Ponder,  Mail Drop 61,
919/541-2915.
is. AssTRACTrpne repOrt describes the development of a program plan for EPA's Conven-
tional Combustion Environmental Assessment (CCEA) Program and presents the
status of the Program 1 year after the planning effort was begun.  The CCEA Program
was established recently to coordinate and integrate EPA's several research and
development efforts for assessing the environmental effects of pollutants from con-
ventional combustion of fossil fuels.  Much of EPA's environmental assessment (EA)
activities have, in the past, been performed in connection with research, develop-
ment, and demonstration projects directed principally toward controlling specific
pollutants from combustion. Overall program goals and objectives are defined, and
existing research and development project involving EA of combustion pollutants are
identified. A procedure for analyzing the content of such projects is described and its
use demonstrated for a selected subset of current projects to identify duplication of
effort or gaps in coverage of areas required for attainment of defined objectives. A
set of recommended actions and milestones,  based  on the analysis of current  pro-
jects and defined Program goals, is  presented.
17.
                             KEY WORDS AND DOCUMENT ANALYSIS
                DESCRIPTORS
                                         b.IDENTIFIERS/OPEN ENDED TERMS
                        c.  COSATI Field/Group
 Pollution
 Combustion
 Assessments
Pollution Control
Stationary Sources
Conventional Combustion
Environmental Assess-
 ment
13 B
21B
14B
13. DISTRIBUTION STATEMENT
 Unlimited
                                         19. SECURITY CLASS (This Report/
                                          Unclassified
                        21. NO. OF PAGES
                             105
                                         20. SECURITY CLASS (This page)
                                          Unclassified
                                                                  22. PRICE
EPA Form 2220-1 (9-73)
                                         97

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