United States - Copy No May 1979
Environmental Protection
Agency
Standard Support Draft
Plan For
Technologies For For
Producing Synthetic Internal
Fuels From Coal EPA Use
Only
Prepared by:
FueS Process Branch
Energy Assessment ami Control Division
Industrial Environmental Research laboratory
Office of Research and Development
US Environmental Protection Agency
Research Triangle Park NC 27711
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C. 20460
DATE: June 15, 1979
SUBJECT: Request for Review of Standard S pport Plan for Technologies for
Producing Synthetic Fuels fromF al
FROM: Steven R. Reznek (RD-68 1)
Deputy Assistant Administrator for Energy, I rals
and Industry
TO: Distribution
One of my goals is to make our activities more responsive to the needs
of other parts of the Agency. In this regard, the Industrial Environmental
Research Laboratory at Research Triangle Park has, with the help of the
Program Offices, put together a Standard Support Plan (SSP) which is aimed
at improving the flow of information from ORD to the Program Offices for
the emerging synfuels technologies. A main purpose of the SSP is to indi-
cate the type and schedule of certain key reports to be prepared by ORD
and how these reports relate to future Program Office plans and needs. All
are*s fo _ ii r*PA hat potential regulatory responZ fbf1ity are covered.
By doing this it is hoped that in addition to helping OEM! plan its long
range R&D outputs, the information contained in the SSP will aid in coor-
dination of regulatory development throughout the Agency.
This material was reviewed In detail with the Program Offices’ representa-
tives at the January 25, 1979 meeting at Research Triangle Park, N. C.
Coniiients received during, and after that meeting have been incorporated
in this review copy. The exchange of ideas at that meeting was most help-
ful for our activities.
Areas of particular concern that were reviewed In the January 25, 1979
meeting, and on which your special emphasis is requested are the Environ-
mental Assessment Report (EAR), the Pollution Control Guidance Document
(PCGD), the standards schedule, and the specific discussion of your pro-
gram office. With regard to the EAR and PCGD, ORD would like to know if
the indicated content will be useful to your office, whether additional
information should be Included, and If the structure or format of the re-
ports is suitable for your needs. Based on ORD’s understanding of the
schedule, ORD outputs and schedules have already been changed in order
to provide more timely input to regulatory action. Your coimients on this
are needed if the reports are to be effective.
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2
I look forward to your coments as another iterative step forward in our
growing communication, and I thank you for your cooperation in these
efforts.
Your response by July 13, 1979 directly to William J. Rhodes (MD-61);
Program Manager, Synthetic Fuels; U.S. Environmental Protection Agency;
Industrial Environmental Research Laboratory-RIP; Research Triangle Park,
North Carolina, 27711, will be appreciated.
Distribution:
Don R. Goodwin, OAQPS
Robert B. Schaffer, OWPS
Alan Levin, OWS
John D. Lehman, 0 5W
We rren Muir, OTS
Floyd L. Galpin, ORP
William A. Mills, ORP
Henry E. Thomas, ONAC
Edward Reich, OGE
Leonard A. Miller, OWE
William R. Adams, Jr., Region I
Eckardt C. Beck, Region II
Jack Schramm, Region III
John White, Region IV
John McGuire, Region V
Adelene Harrison, Region VI
Kathleen 0. Camin, Region VII
Alan Merson, Region VIII
yPaul DeFalco, Jr., Region IX
Donald P. Dubois, Region X
Kenneth Mackenthun, OWPS
William E. Bye, OWS
Gary McCutchen, OAQPS
Mark Mercer, OSW
Eugene Wyszpolski, ONAC
David Duncan, ORP
David Shaver, OPE
George Stevens, OGE
Tom Murphy, OALWU
Bill Rosenkranz, OALWU
Gordon Robeck, MERL, Cincinnati
Dave Stephan, IERL, Cincinnati
Roger Cortesi, OHEE
Paul Altschuller, ESRL, RIP
Dale Denny, TERL, RIP
Dan Cahill, HERL, RIP
Tom Duke, ERL, Gulf Breeze
Mike Waters, HERL, RTP
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3
Information Copies to:
John K. Burchard, IERL, RIP
Norbert Jaworskl, IERL, RIP
John 0. Smlth/W. Gene lucker, IERL, RTP
Frank Prlnciotta, OEMI
Morris Altschuler, OEMI
Gregory Ondich, OEMI
Representatives at January 25, 1979 meeting:
Charles Sedman, OAQPS
John Lum, OWPS, EGD
Mark Mercer, OSW
Roman W. Kuchkuda, OTS
Charles G. Amato, ORP
James Herlihy, OE
Joel Schwartz, OPE
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025651
Copy No. May 1979
FOR INTERNAL EPA USE ONLY
DRAFT
STANDARD SUPPORT PLAN
FOR
TECHNOLOGIES FOR PRODUCING SYNTHETIC FUELS FROM COAL
Prepared by
Fuel Process Branch
Energy Assessment and Control Division
Industrial Environmental Research Laboratory
Office of Research and Development
U.S. Environmental Protection Agency
Research Triangle Park, N.C. 27711
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CONTENTS
1 INTRODUCTION
1
1.1 Purposes
1.2 Preparation and Update
1.3 OR&D Environmental Assessment Reports .
4
5
5
2 DEFINITION OF THE TECHNOLOGIES
9
2.1 Coal Gasification Technology Overview .
2.2 Coal Liquefaction Technology Overview .
2.3 Pollutant Emissions and Conventional Control
Technologies
9
11
12
3 THE STANDARDS SUPPORT SCHEDULE
4 DISCUSSION OF THE STANDARDS SUPPORT SCHEDULE
20
25
4.1 Status and Projected Development of Synthetic
Fuels Industry
4.1.1 Department of Energy Support for
Commercialization
4.1.2 Status of Low/Medium—Btu Gasification
4.1.3 Status of High-Btu Gasification
4.1.4 Status of Coal Liquefaction
4.2.1
4.2.2
4.2.3
4.2.4
4.2.5
4.2.6
4.3.1
4.3.2
4.3.3
4.3.4
4.3.5
4.3.6
Air Programs
Water Programs
Solid Waste
Toxic Substances
Radiation Programs
Noise Program
25
30
30
41
50
51
52
53
53
55
57
58
60
61
61
4.2 EPA Regulatory Approaches
26
27
30
30
4.3 EPA Plans for Regulatory Activities/R&D Needs
Office of Air Quality Planning and Standards
Office of Water Planning and Standards . .
Office of Solid Waste
Office of Toxic Substances
Office of Radiation Programs
Office of Noise Abatement and Control . .
11
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4.3.7 Office of Enforcement . 61
4.3.8 Relationships to Other Regulatory Activities . . . 62
4.3.8.1 Introduction 62
4.3.8.2 Occupational Safety and Health
Administration (OSHA) . . 63
4.3.8.3 Mine Safety and Health Adminis-
tration (MSHA) 63
4.3.8.4 Office of Surface Mining Reclamation
and Enforcement 64
4.3.8.5 State and Local Regulations 64
4.4 EPA Research and Development Activities 65
4.4.1 Current Process Technology Background 65
4.4.2 Control Technology Assessment 67
4.4.3 Environmental Data Acquisition 71
APPENDICES . . 75
A References for Further Detail on Technologies . . . . . . 76
B EPA Personnel Involved in Synthetic Fuels Technology
Environmental Assessment, Standards, and Enforcement . . . 77
C Example Pollution Control Guidance Document Outline 79
0 Example Environmental Assessment Report Outline 81
E Example Outline for Environmental Assessment Source
Test and Evaluation Report 85
111
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LIST OF FIGURES
1 Processes for Gasification Systems 10
2 Module Diagram for Coal Liquefaction Systems 13
3 Pollutant Types, Control Schemes, Residuals and Emission
Fates for Coal Conversion Process 14
4 Preferred Standards Path Analysis Flow Chart for Air
Quality Programs 38
5 Preferred Standards Path Analysis Flow Chart for Water
Quality Programs 46
6 Regulatory Path Analysis Flow Chart for Groundwater
Protection 49
7 Preferred Standards Path Analysis Flow Chart for
Radiation Hazard Evaluation and Regulation . 54
8 Analysis Methodology for Characterizing Streams from
Synthetic Fuels Sources 74
iv
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LIST OF TABLES
1 Total World Fossil Fuel Reserves as of Year
Ending 1976
2 Estimated Life of World Fossil Fuel Resources at
Various Demand Growth Rates
3 Pattern of U.S. Energy Consumption 1950-1990
4 Distribution of U.S. Coal Demand 1960-1990
5 Standard Support Document Schedule
6 Pollutants from Operations Used in Synthetic Fuels
Technologies
7 Comparison of Program Office Standards Development
Schedules with OR&D Report Schedules for Low-Btu
Gasification Technology Processes
8 Comparison of Program Office Standards Development
Schedules with OR&D Report Schedules for High-Btu
Gasi fication Technology Processes
9 Comparison of Program Office Standards Development
Schedules with OR&D Report Schedules for Coal
Liquefaction Technology Processes
10 Commercialization Goals for Synthetic Fuels Gasifi-
cation Technologies Recommended by DOE Task Forces
11 Status of U.S. and Foreign Low- and Medium-Btu
Gasification Systems
12 Promising Low- and Medium—Btu Gasification
13 Proposed High-Btu Gasification Commercial and Demon-
stration Projects and Pilot and Bench PDU Programs
14 Status of Coal Liquefaction Systems
15 National Ambient Air Quality Standards
16 National Emission Standards for Hazardous Air
Pollutants (NESHAP)
2
2
3
3
7
15
21
22
23
• . . 27
• . • 28
• 29
31
33
35
36
V
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17 Principal Air Pollution Regulatory Options for
Synthetic Fuels Industry Regulation 39
18 Maximum Permissible Increments for Sulfur Dioxide
and Particulate Matter Concentrations in Ambient
Air for Each PSO Class Compared to NAAQS Values 40
19 Conventional Pollutants Subject to Best Conventional
Control Technology (BCT) by July 1, 1984 . . . . 42
20 Toxic Pollutants Subject to Best Available Control
Technology Economically Available (BATEA) . 43
21 Principal Water Quality Options for Synfuels
Industry Regulation 47
22 Principal Ground Water Protection Options for
Synfuels Industry Regulation 48
23 Schedule for Promulgation of Regulations on Waste
Management . . . . 59
24 Project Titles, Contractors, and EPA Project Officers
in OR&D Environmental Assessment Program . . . . 66
25 Recent Reports on Low/Medium—Btu Gasification . . . . . . . 68
26 Recent Reports on High-Btu Gasification 69
27 Recent Reports on Coal Liquefaction Technology . . . 70
28 Recent Reports on Environmental Control Techniques
for Gasification and Liquefaction Technologies . . . . . . . 72
vi
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SECTION 1
INTRODUCTION
Although there are significant variations from country to country,
there nevertheless is a very strong correlation between the gross national
product per capita and the energy consumption per capita for the worlds
industrial nations. Now, and for the foreseeable future, the major source
of this energy is fossil fuel. Total world fossil fuel reserves are
limited, as can be seen from the data presented in Tables I and 2.
Between 1960 and 1978 the world growth rate for energy usage was
about 2 percent. According to the data of Table 2, if this growth rate is
maintained, proven reserves will be within 10 years of exhaustion in about
forty years. Scenario B in Table 2 is more optimistic, whereas Scenario C
appears wildly optimistic in view of the recent tragedy at Three Mile
island and the very slow development of solar energy alternatives.
This is the world setting. Because of the present U.S. dependence
upon oil and natural gas, the depletion of these fuels and increasing com-
petition for them in world markets presage a future that is equally stark.
The trend in U.S. energy consumption over the past thirty years is
illustrated in Table 3. The growth in the use of oil and natural gas has
resulted in massive capital investments in distribution systems and equip-
ments which use these fuels. During this time the amount of coal used has
been comparatively static, undergoing a slight decline and then recovering
to the point where 1977 use was slightly above that in 1950. However, as
can be seen, the use of coal is expected to more than double by 1990. The
historical and anticipated distribution in the use of this coal is illus-
trated in Table 4.
Included in the industrial/nonenergy category for the 1990 entry in
Table 4 is an estimated 75 million tons of coal per year, 5 percent of
expected U.S. production, to be used in synthetic fuels production. It
is conceivable that this estimate may be too conservative.. In 1977
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TABLE 1. TOTAL WORLD FOSSIL FUEL RESERVES AS OF YEAR ENDING 1976*
Natural Gas
2.2 -
2.5
9.4 —
9.8
Natural Gas
Liquids
0.2 -
0.3 (est.)
1.0
Crude Oil
3.1 -
3.5
8.7 -
10.7
Syncrude
1.6
14.0
Coal
Total
13.7
107.3 —
122.4
20.8 -
21.6
140.4 -
157.9
*
Scenari Os:
*
Proved and Currently
Recoverable, i 18 Btu
Estimated Rema qing
Recoverable, 10 Btu
Data from H. R. Linden, et al. , “Perspectives on U.S. and World Energy
Problems,” Institute of Gas Technology, February 1979.
TABLE 2. ESTIMATED LIFE OF WORLD FOSSIL FUEL RESOURCES
AT VARIOUS DEMAND GROWTH RATES*
Annual Growth
Rate,
/°
Date When Remaining
Ratio Decreases
A B
2005 2050
to
10
Reserve/Production
Years
C
2067
4
3
2010 2067
2090
2
2017 2097
2130
A -— Proved reserves only
B -— Using total remaining recoverable reserves
C -- Effective doubling of B Resources by use of
sources.
Data from H. R. Linden, et al. , “Perspectives on U.S. and World Energy
Problems,” Institute of Gas Technology, February 1979.
nonfossil
2
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TABLE 3. PATTERN OF U.S. ENERGY CONSUMPTION 1950-1990
Consumption in Quads (1015 Btu) by Year
Source 1950* 1960* 1970* 1977* 199O
Hydro, Nuclear
1.43 1.6 2.9 5.1 14.6
Dry Natural Gas
6.15 12.7 22.0 19.6 19.1
Petroleum Liquids
13.5 20.1 29.5 37.1 48.2
Coal
12.9 10.2 12.7 14.1 30.3
Total, Quads (lO 15 Btu)
34.0 44.6 67.1 75.9 112.2
Average Growth Rate (%)
2.75 4.17 1.78 3.05
*
Data from U.S. Bureau of Mines cited in H. R. Linden et al. , “Perspec-
tives on U.S. and World Energy Problems,” Institute of Gas Technology,
February 1979.
** U
Data from Exxon Company, U.S.A., Energy Outlook 1978-1990, May 1978.
TABLE 4. DISTRIBUTION OF U.S. COAL DE 1AND 1960-1990
Sector
Consumption in Quads (1015
1960 1977
Btu) by Year*
1990
Electric Utility
4.45
10.2
22.6
Industrial/Nonenergy
4.65
3.7
7.7
Residential/Commercial
1.1
0.2
Total Quads
10.2
14.1
30.3
*
Data from Exxon Company, U.S.A., “Energy Outlook 1978-1990,’ May 1978.
3
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imports accounted for about 45 percent of the 19.1 million barrels/day
used. The projected figures for 1990 are that imports will account for
51 percent of some 22 million barrels/day consumed in the U.S. In 1978
oil imports dramatically escalated the U.S. trade deficit to over 28 bil-
lion dollars. The economic burden of imports will escalate still further.
Compared to that around 1940, per capita (worldwide) energy consumption
will double by 1980, creating increasing demand, hence prices, in the oil
market. These economic forces, plus the impacts of geopolitical events--
witness the oil embargo of 1973 and the more recent interruption of oil
production in Iran--will probably accelerate the development of processes
and an industry to produce synthetic fuels from coal.
As of now there are very few operating synthetic fuels plants in the
United States. The pollution potential of these and those development
and demonstration units coming on line will be small for several years to
come. Justifiably so, the EPA program offices are presently concerned
with many other sources of far more serious environmental impacts than
those of the nascent synthetic fuels activity. As these other sources
are brought under control and the pollution potential of synfuels plants
increases, however, it appears highly probable that regulatory attention
will be turned to these technologies. On the basis of research work
already done, it is apparent that the pollution potential of such unregu-
lated sources would be large. Although many control methods have been
identified, there are still many areas where improvements must be made.
Goals for guiding these improvements must be developed now if R&D pro-
grams are to be structured to attain effective controls to implement
standards.
\j tij s document surveys for synthetic fuels technologies the existing
program office activity and plans, anticipated R&D needs, and IERL R&D
activity and presents a plan for the provision of necessary R&D support
by IERL to the program enforcement and regional offices.
1.1 PURPOSES
The purposes of this Standards Support Plan (SSP) are
1. To briefly describe the technical and economic information the
OR&D (IERL/RTP) can provide to the program enforcement and
4
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regional offices to support the development or enforcement of
standards;
2. To establish a time schedule for transmission of this information
to the standards-setting and enforcement offices; and
3. To serve, at least initially, as a negotiating document between
OR&D and the program offices for determining what information
is to be developed by OR&D and the schedule required.
Eventually the Agency may want to publish a finalized version of this SSP
for the benefit of developers and users of synthetic fuels technologies.
1.2 PREPARATION AND UPDATE
The interaction between OR&D and the program and enforcement offices
is an iterative process.
This first version of the SSP for synthetic fuels technologies
reflects the present perception of OR&D regarding
1. The present pace of technology development and the priorities
for addressing individual technologies;
2. The present plans and schedules of the program and enforcement
offices for standards development and enforcement; and
3. The information needs of the program and enforcement offices.
The first version will be circulated for comment to the program and
enforcement offices or, alternatively, to a comittee of their represen-
tatives. Several iterations of this process may be required before final
agreement is reached. Subsequently, due to changes in policies or tech-
nology development trends, revisions will be made as required, perhaps on
a periodic review basis.
1.3 OR&D ENVIRONMENTAL ASSESSMENT REPORTS
At this time it appears that many of the program and enforcement
offices needs for R&D information for standards development for the
synthetic fuels industry can be met through a series of documents gen-
erated by OR&D. These include Pollution Control Guidance Documents (PCGD),
Environmental Assessment Reports (EAR), and Source Test and Evaluation
Reports (STER). Pollution Control Guidance Documents (PCGD) are specific
to a given energy technology such as low-Btu gasification. The PCGD
5
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summarizes what is known about the environmental effects of known pollu-
tants from systems encompassed within the energy technology, the techniques
available for the control of these pollutants, and suggested pollutant
discharge limits, among other topics. An example outline for a PCGD is
given in Appendix C, and the present schedule for publication of such
reports is given in Section 4.4.4. The PCGD will be prepared with the
active participation and concurrence of the program offices. In reviewing
this Standards Sqpport Plan, the program offices are asked to give special
attention to this outline to determine its completeness in providing neces-
sary information for their standards development activities .
The Environmental Assessment Reports are designed to provide a com-
prehensive overview for a specific system within an energy technology
such as the Lurgi system for low— and medium-Btu gasification. An EAR
dealing with alternative modules which comprise a given system within a
technology is prepared by drawing together technical, economic, and
environmental impact data for that system. The major topics addressed are
process description, characterization of input materials, products and
waste streams, performance and cost of control alternatives, analysis of
regulatory requirements, and environmental impacts. An example outline
for such a report is given in Appendix D, and the present schedule for
publishing these reports for the various systems is given in Section 4.4.4.
In reviewing this Standards Support Plan, the program offices are asked to
give special attention to the completeness of this outline for insuring
the availability of their information needs .
Environmental Assessment Source Test and Evaluation Reports (EA-STER)
provide data obtained from specific plants employing a given system. The
specific processes and operating parameters, sampling points and methodol-
ogy, and analytical procedures are described. Test results are summarized
and discussed. The conclusions drawn from these are presented, and recom-
mendations for further work, such as improvements in sampling or analysis
methods, for example, are given. Appendix E provides an example outline,
and the present schedule for production of such reports is given in
Section 4.4.4.
The present schedule for these standards support documents is given
in Table 5.
6
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TABLE 5. STANDARD SUPPORT DOCUMENT SCHEDULE
Technology
Report
1979
1980
1981
1982
1983
Synthetic Fuels
SsP
1/79
Low/Medi um-Btu
Gasification
EA-STER
Weliman—Galusha
Wiliputte Chapman
Foster-Wheeler/Stoic
6/79
(10/78)
3/80
EAR
Weilman-Galusha
Will putte-Chapman
Foster—Wheeler/Stoic
3/79
3/80
3/81
6/82
6/83
PCGD
6/79
6/80
High-BtuGasifi—
cation
EA-STER
Lurgi
Hygas
Slagging Lurgi
3/80
6/82
6/82
AR
Lurgi
Hygas
] ging Lurgi
4/79
9/80
6/81
PCGD
5/80
Coal Liquefaction
EA-STER
SRC (I and II)
H-Coal
scher—Tropsch
EW
12/79
12/80
6/82
12/83
SCR (I and II)
H-Coal
scher-Tropsch
6/80
3/81
3/82
6/83
PC D
5/8O
678T
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Additionally it is anticipated that special or supplementary reports
will be generated as required by program office needs. Establishment of
rapid communication channels to ascertain and respond to these needs is
one of the objectives of this Standards Support Plan.
8
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SECTION 2
DEFINITION OF THE TECHNOLOGIES
The technologies covered in this document include only those in which
coal is extracted and then converted. The in situ processing technologies
and problems are not included.
2.1 COAL GASIFICATION TECHNOLOGY OVERVIEW
Techniques for gasifying coal have been developed since the early part
of the twentieth century. All the various systems utilize three primary com-
ponents or process operations: coal pretreatment, coal gasification, and gas
purification. These operations and their relationships to other parts of the
gasification process are shown schematically in Figure 1.
Prior to being gasified, the coal is pretreated if necessary so that it
can be more efficiently utilized. Following the pretreatment, the coal is
gasified under high temperature and, for some processes, high pressure to
form a product that contains primarily carbon monoxide, hydrogen, and some
methane. Other substances in this gas may include carbon dioxide, nitrogen,
water vapor, hydrogen sulfide, ash, and coal dust.
To produce low-Btu gas, the coal is reacted with steam and air. The
resulting gas has nitrogen in it, which limits its heating value and may
cause the release of nitrogen oxides (NOt) if the gas is burned as a fuel.
If oxygen and steam are utilized, a medium-Btu gas that contains no nitrogen
is produced. High—Btu gas is made from medium—Btu gas by adjusting the
ratio of hydrogen to carbon monoxide by means of the water—gas shift reac-
tion. Following the reaction, the acid gases, mainly hydrogen sulfide and
carbon dioxide, are removed; and the remaining hydrogen and carbon monoxide
are combined to form methane and water. The water is then removed, leaving
a methane—rich gas that is essentially the same as natural high-Btu gas.
Generally any coal can be gasified if proper pretreatment and gas
cleaning processes are employed; however, certain gasifier designs are
better suited to some coals than others.
9
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- COAL PIlL IIILAIMLNI OPERATION —--- --——-—---—-—- 4-—COAL GASIFICATION OPLIIAIION —--1-— —---—--- -GAS PURIFICATION OPERATION — — —
(HAll M i LI 1
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A(M I IAP (llIl(I , — IN 5(11 I I IMA IJ A HA N
51 Al,l 1 lNl. I - - ((l w Al,A
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11 1 1 51(1 S INI II IAIS I IAIM I ISPII1II IC (
( ‘AS M I (MANA((AN C — — -
IM 1 I I I I IML II, .l —
(il;A [ i;i uiiJI
I IIMIIAAI lA S
Figure 1. Processes for Gasification Systems.
-------
Many types of gasifiers have been developed and are usually classified
according to their distinguishing mechanical characteristics. This basis of
classification is also significant from an assessment viewpoint since varia-
tions in gasifier design account for many of the differences which are
observed in the impacts of different gasification systems. Among the impor-
tant characteristics in this regard are the following:
• Reactor type
- Fixed or supported bed (includes moving bed designs)
- Fluidized bed
- Entrained bed
• Operating conditions
- Pressure: atmospheric or pressurized
- Temperature*
• Heat transfer
- Internal: autotherrriic, cyclic, or heat-carrying fluids or solids
- External
• Gasification media
— Reactants: steam, air, oxygen, hydrogen, other additives
- Coal feed/reactant ratios
- Mode of reactant introduction
Coal feeding type
- Mode: continuous or intermittent
- Mechanism: lock hopper, slurry, screw, etc.
- Location: top or center of gasifier
• Ash removal system
- Mode: continuous or intermittent
- Ash condition: dry or slagged (fused)
- Location: from the gasifier or from the product gas stream
*Operating temperature is primarily determined by the reaction rate
process, including the feed rate of reactants.
2.2 COAL LIQUEFACTION TECHNOLOGY OVERVIEW
As with gasification, either hydrogen has to be added or carbon removed
from the compounds in the coal to produce liquid fuels. Only the ratio of
carbon to hydrogen in the end product is changed. Though liquid fuels are
11.
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usually of most interest, liquefaction processes can produce a gaseous or
liquid product or, in some instances (e.g., solvent-refined coal), a low-
melting solid fuel.
There are three primary operations used in producing liquid fuels from
coal: coal pretreatment, coal liquefaction, and product purification. The
various modules used in these operations, as well as auxiliary processes
used, are shown schematically in Figure 2.
Two basic paths to liquefaction can be traced on this diagram. The
first uses a coal-solvent slurry feed, which is hydrogenated to produce a
mixture that is subsequently treated to obtain carbonaceous solid residues
and hydrogen synthesis gas, both of which are recycled back through the
slurrying module, and a liquid product which is fractionated and hydrotreated
to yield a refined hydrocarbon liquid product. The second path subjects dry
sized coal feed to a process module that produces a raw gas, which is
cleaned and used to produce liquid via catalytic synthesis, and a liquid
product directly. These liquid fractions are fractionated and hydrotreated
to yield a refined hydrocarbon liquid product.
2.3 POLLUTANT EMISSIONS AND CONVENTIONAL CONTROL TECHNOLOGIES
The types of emissions from pretreatment facilities, coal conversion
units, and associated treatment facilities include sulfur (S 2 , S 4 . H 2 S, SON,
COS, CS 2 , mercaptans, thiophenes); nitrogen (NO NH 3 , HCN, thiocynates);
particulate matter (debris, fines, ash, chars); trace elements; wastewaters;
organics; spent catalysts; thermal effluents; noise; carbon dioxide; and
radioactivity. Generally the types of emissions will be similar for both
gasification and liquefaction.
Figure 3 details the sources of these potential emissions from the
various operations performed in coal conversion facilities. Possible treat-
ment processes to control these potential emissions are shown in Table 6.
It should be recognized that these control methods are in varying stages of
development (some still in the conceptual stage) and efficiency with regard
to application to the synthetic fuels processes. Selection and guidance of
development will be heavily influenced by regulatory limits imposed on the
residuals from these processes. These limits, in turn, will be influenced
by OR&D information on pollutant loadings, health and ecological effects,
12
-------
PRETREATMENT , —COAL LIQUEFACTION — -F*-——-—-——- —— --ruMu -ICAII U W-- -—-— --—-- - - -—-----—---— --—— --— -—--. .. ..n
N
Ed NE
RAW
E. EOtJlU
E I N
)LIL)S II
E()c L
CAJALYT FEE I8A ON J - ‘I, J
__ __ _
[ ± IIJ J J EI E ____ LwAiti:]
lIVENEd IN VIE f E1 4fl NLIINE 20 h is : 1 f’
E XI I EAC I ION (EASI S OIL WA I
________ J ()t C I SLPANAEI0 J SUE LOS I RACE IONAIIUN 11 —
COAL R iI i2J N( ftfl4A1 IO JO 1
CAIALVII( SILAM&P OW I I E
SYNTI1fSISi J ___ - — _________
L
Figure 2. Module Diagram for Coal Liquefaction Systems.
-------
Figure 3. Pollutant Types, Control Schemes, Residuals and Emission Fates
for Coal Conversion Process
C
C
C
LAND OR WATER ENVIRONMENT
-------
TABLE 6. POLLUTANTS FROM OPERATIONS USED IN SYNTHETIC FUELS TECHNOLOGIES
*
Coiiimercially used but not on coal
conversion.
I -.
0 ,
Operation
Waste Streams/Pollutants
Possible Control Methods
Coal storage
Water runoff/organics, minerals,
ions, suspended solids
Dusts and fines/particles
*Collection neutralization, deminerali-
zation, ion exchange, settlement
Coal preprocessing
(washing, grinding,
dry i n g)
Solid wastes/sludge, fines, ash,
rock
Liquid wastes/organics, minerals,
ions, suspended solids
Airborne wastes/particles, SO 2
*Landfill minefill
Collection, settlement, neutralization,
demineralization, ion exchange
Cyclones, baghouse, wet scrubbers,
electrostatic precipitators
Utility and steam
producti on
Solid wastes/ash, sludge
Liquid wastes/organics, minerals,
ions, suspended solids
Airborne wastes/particles, SO 2 ,
NOx
*Landfill niinefill
Collection, settlement, neutralization,
demineralization, ion exchange
Cyclones, bagnouse, wet scrubbers,
electrostatic precipitators, combustion
modification
Conversion
.
H 2 S
Acid gas scrubbed, Stretford, Giarumarco
Vetrocoke, and Takahax (1-step removal);
Amine, Economine, Alkazid, Benfield,
Catacarb CO 2 removal, Purisol, Adip,
Fluor, Selexol, Rectisol, Sulfinol,
SNPA-DEA processes (2-step removal
requiring Claus-based sulfur recovery
units)
(continued)
-------
TABLE 6 (continued)
Operation
Waste Streams/Pollutants
Possible Control Methods
Conversion NO Venting, Continuous Catalytic Absorp-
(continued) tion, Modified Alkalized Alumina,
equipment design modification
CO 2 Stack gas cleanup of sulfur and combust-
thies, venting
COS, CS 2 Recovered in some scrubbing processes
for H 2 S; fugitive emission from sulfur-
recovery unit tail gas
NH 3 *Stripped by Phosam or Chevron unit for
resale recovery; residual NH 3 treated
in wastewater
I — . *
HCN Follows ammonia to wastewater treatment
Miscellaneous gases (HF, HC1, *Wet scrubbed from product gas stream
CO) and volatile trace elements and transferred to wastewater treatment
processes such as biological oxidation
ponding or lime neutralization for
removal
Trace metals Recovered in ash, tars, chars, and
wastewater
Ash *Electrostatic precipitators, minefill
landfill, possible resale options
* .
Particulate matter Cyclone separators, fabric filters,
negative pressure grinders, wet scrub-
bers, electrostatic precipitators
*Ci]]d but not on (continued)
coal conversion.
-------
TABLE 6 (continued)
Operation
Waste Stream/Pollutant
Possible Control Methods
Conversion Char Recycled as gasifier, steam, or utility
(continued) fuels; requires sulfur recovery before
or after combustion; wastewater treat-
ing potential
Tar Hydrodesulfurized for fuel oil, gasi-
fied, or combusted; residual treated in
wastewater
Oils Hydrodesulfurized for fuel oil;
residual treated in wastewater
Gaseous hydrocarbons May be scrubbed into wastewater for
activated carbon or biological oxida-
tion pond removal
Phenols *Stripped by Phenosolvan for recovery
and resale; residual removal by active
carbon absorption, biological oxidation
ponding, or solar evaporation
Process wastewater NH 3 and phenol stripping (Chevron,
Phenosolvan, Phosam), lime neutraliza-
tion, active carbon absorption, biolog-
ical oxidation ponding, residual tar
and oil removal, evaporation, zeolite
treatment
Conversion, control
Spent catalysts
Regeneration, disposal in landfill or
treatment
niinefil]
*Cill used but not on
coal conversion. (continued)
-------
TABLE 6 (continued)
Operation
Waste Streams/Pollutants
Possible Control Methods
Control and treat-
ment
Sulfur recovery tail gas
Beavon, Cleanair, Chiyoda, IFP
(Institut Francais de Petrole), Aqua-
claus, SCOT (Shell Claus Offgas Treat-
ing), venting, or combustion
Control treatment
generated (limestone
processes)
Slag
*Granulated for landfill, minefill, or
resale
*CoI]lfllercially used but not on
coal conversion.
-------
and control method evaluation. This iterative, reciprocal information
exchange must be rapid and continuous if these control methods are to make
the transition to candidate methods for Best Available Control Technology.
19
-------
SECTION 3
THE STANDARDS SUPPORT SCHEDULE
Based on current plans of EPA program offices and OR&D, Table 7 shows a
comparison of schedules for producing standards in the program offices
specific to low— and rnedium-Btu gasification processes and the schedules for
various supporting reports from OR&D. Similar comparisons are shown in Table 8
for high—Btu gasification processes and in Table 9 for liquefaction processes.
The background for these schedules is given in Section 4.
Two observations should be stated with regard to these schedules. The
first is that the program offices are at present assigning a very low priority
to synfuels sources p se. Only OAQPS has considered a synfuels source type
in detail——the Lurgi gasification process-—and because of the press of activity
mandated by the Clean Air Act Amendments of 1977, reduced its effort from
preparation of an NSPS to issuance of a control guidance document. As a
result of the low priorities assigned by the program offices, the Enforcement
Office and regional offices have little definitive information to guide their
considerations in permitting actions. In view of the few extant sources this
has not yet posed a problem. However, as is discussed in Section 4.1, there
is significant process development activity; and it appears that commercial
use will greatly broaden in the next decade.
The second observation, based on information presented in Section 4.2, is
that the program offices each have a different approach to regulation. The
media-specific offices OAQPS and OWPS have similar approaches in setting media
criteria and standards for specific pollutants, in developing strategies to
control these pollutants from manifold sources distributed over wide geograph-
ical areas, and in setting source—specific standards. These program offices
are, of course, the oldest in EPA. ORP has only recently directed attention
to coal combustion or conversion. The Office of Noise Abatement and Control
has to date only a very limited legal charter, primarily concentrating on
controlling noise from sources used in transportation. In contrast, the
20
-------
TABLE 7. COMPARISON OF PROGRAM OFFICE STANDARDS DEVELOPMENT SCHEDULES WITH OR&D REPORT SCHEDULES FOR
LOW-BTU GASIFICATION TECHNOLOGY PROCESSES
Calendar Year
Office/Item
78
79
80
81
82
83
84
85
86
87
OR& D
PCGD
OAQPS
OwP S
OS W
OT S
ORP
3 / 80
6 / 80
No current plans
No current plans for
No current plans for
6/83
6 / 83
source-speci fi c
I I
source-speci fi c
source-specific
6/86
standards
standards
standards
•Control of coal preparation operation wastes
(addressed under SSP for coal cleaning)
Raw and acid gas cleanup evaluations
•Wastewater treatability
•EA-STER
Weilman Galusha
Wiliputte Chapman
Fosfer—Wheeler
• EAR
Weilman Galusha
Wiliputte Chapman
Foster-Wheeler
N)
A
A
A
A
1O/7
A
A
6/79
3/79
3/80
6/82
3/81
for
1 - I - - J I
-------
• PCGD
OAQPS
OW PS
OSw
UT S
ORP
No
No
No
6/79
4/79
9/80
5 / 80
current plans for
current plans for
current plans for
5/83
source-specific
I I
source-specific
source-specific
I I I
5 / 86
standards
standards
standards
TABLE 8. COMPARISON OF PROGRAM OFFICE STANDARDS DEVELOPMENT SCHEDULES WITH OR&D REPORT SCHEDULES FOR
HIGH-BTU GASIFICATION TECHNOLOGY PROCESSES.
Calendar Year
Office/Item
78
79
80
81
82
83
84
85
86
87
OR&D
• Control of coal preparation operation wastes
(addressed under SSP for coal cleaning)
• Raw and acid gas cleanup evaluations
• Wastewater treatability
• EA-STER
Lurgi
Hy gas
Slagging Lurgi
• EAR
Lurgi
Hy gas
Slagging Lurgi
N)
N)
A
A
A
A
A
A
A
A
3 / 80
6 / 84
6 / 82
6/82
6 / 86
A
A
6/81
-------
SRC (I and II)
H-Coal
Fl sher-Tropsch
• PCGD
OAQPS
OwP S
05W
OTS
ORP
5 / 80
No current plans for
I 4---- -- I
No current plans for
No current plans for
12/8:
6 / 83
3/82
6/83
source-specific
I I
source-specific
source-specific
TABLE 9. COMPARISON OF PROGRAM OFFICE STANDARDS DEVELOPMENT SCHEDULES WITH OR&D REPORT
COAL LIQUEFACTION TECHNOLOGY PROCESSES
Calendar Year
Office/Item
78
79
80
81
82
83
84
85
86
87
SCHEDULES FOR
OR& D
• Control of coal preparation operation wastes
(addressed under SSP for coal cleaning)
• Wastewater treatability
• EA-STER
SRC (I and II)
H-Coal
• EAR
( )
A
12/7
A
6/82
A
3/81
12 / 8(
6 / 80
A
standards
standards
standards
-------
Office of Solid Waste and the Office of Toxic Substances both have been
recently given very extensive legal mandates. However, their approach is
still more pollutant specific than source specific; and their programs are
still in the formative stages.
At this time, then, it appears that there is essentially no detailed
planning in the program offices on a source-specific basis for the
synthetic fuel industry.
It is OR&D’s position that the program offices should at least at this
time join in a planning activity that would forecast the regulatory approaches
that appear most likely for synfuels sources and assist OR&D in pacing its
research programs to develop the information necessary to support these
approaches in a timely manner. Just as important, the program offices should
consider the kinds of information-—content and format-—needed to scope the
problems from the point of view of their particular office and then, at a
later date, to identify the appropriate control methods and performance charac-
teristics necessary to limit emissions to levels that achieve the media
quality criteria values.
Because of the magnitude and nature of environmental problems that
existed before EPA was created, the Agency has of necessing reacted and
imposed ex post facto standards and controls on existing sources. Even
though generally acknowledged as desirable and necessary by the public,
source operators have generally adopted a grudgingly defensive attitude.
EPA would have much to gain in cooperation if it identified and publicized
potential problems while technologies are in the emergent stage so that plant
designs could be guided to incorporate effective control methods prior to
construction. We suggest that such gains would outweigh the present inconve-
niences of extracting time for planning synfuels source regulatory strategy
from the presently heavily committed program office schedules.
24
-------
SECTION 4
DISCUSSION OF THE STANDARDS SUPPORT SCHEDULE
This section first presents OR&D’s current perception of the status and
projected development of synthetic fuels technologies, both under private
funding and with Federal assistance. Then EPA’s regulatory approaches under
existing statutes is surveyed, followed by a description of the current
plans of EPA program offices for regulations directed specifically toward
the synthetic fuels industry related to activities of other regulators. The
current research program of OR&D for environmental assessment and controls
for synthetic fuels technologies is briefly described. Finally, OR&D ’s per-
ception of the program offices’ R&D needs are presented.
4. 1 STATUS AND PROJECTED DEVELOPMENT OF SYNTHETIC FUELS INDUSTRY
The commercial development of synthetic fuels processes is a function
not only of the technological feasibility of the processes but also of the
economic environment in which a plant is built and operated. The price of
oil, natural gas prices and availability, interest rates, coal prices and
availability, and Federal government support (or lack of it) are key factors
influencing both the rate and degree of commercialization.
Section 4.1.1 discusses commercialization from the Department of
Energy’s (DOE) perspective. The determination of which programs to support
and emphasize is a technical decision made within a political context. Con-
sequently, DOE schedules of commercialization and funding levels must be
continually revised to reflect the latest funding decisions.
Section 4.1.2 reviews the current status and anticipated development
of low/medium Btu gasification; Section 4.1.3, high—Btu gasification
processes; and Section 4.1.4, liquefaction processes.
25
-------
4.1.1 Department of Energy Support for Commercialization
The Department of Energy has recently prepared draft reports on
commercialization strategy recommendations. These are available as
follows:
Commercialization
TID Number Title Task Force Chairman
28851 Commercialization Strategy Report for Russell Bardos
Low—Btu Gasification
28850 Commercialization Strategy Report for Russell Bardos
Medium-Btu Gasification
28849 Report of the Commercialization Task Phillip Gallo
Force for High—Btu Gasification
28846 Commercialization Strategy Report for Elwood A. Lloyd
Coal Liquefaction
The Low—Btu Task Force recommended the following commercialization
goals:
• Sufficient application to industry by 1983 and to the utility
sector by 1988 to make low—Btu gas an attractive and acceptable
alternate fuel.
• Stimulate and provide incentives for switching from natural
gas to coal-derived low-Btu gas through Federal policy, legis-
lative means, and taxes.
Use of low—Btu gasification by industry at the minimum growth
rates indicated in Table 10.
26
-------
TABLE 10. COMMERCIALIZATION GOALS FOR SYNTHETIC FUELS GASIFICATION
TECHNOLOGIES RECOMMENDED BY DOE TASK FORCES
Tech
nol
ogy
1985
Year
1990
2000
Low—Btu
No. Plants
Quads
30
0.012
400-500
0.16 -0.2
2,500
1.0
Med-Btu
No. Plants
Quads
4
0.04
30 - 50
0.3-0.5
80 - 100
1.0-4.4
High-Btu
c
No. Plants
Quads
2 — 3
0.1-0.2
5 - 10
0.4-0.9
25 - 30
2.0-2.5
For medium-Btu gasification the first two goal statements are essen-
tially the same as those stated above for low-Btu gasification. The
recommended goals for industrial growth are as indicated in Table 10.
For high-Btu gasification the goals for market penetrations are as
indicated in Table 10.
For coal liquefaction-derived fuels the following percentage market
penetrations are forecast:
1985 1990 2000
Liquid boiler fuels 0.04 5.1 15.9
Gasoline 0.05 1.6 7.8
All of these schedules are predicated on a vigorous DOE effort to stimu-
late and press the development of a viable synfuels industry. However, in
view of recent budget limitations on the commercialization program, the goals
appear to be overly optimistic.
4.1.2 Status of Low/Medium-Btu Gasification
Table 11 summarizes the status of U.S. and foreign low- and medium-Btu
gasification systems. OR&D environmental assessment contractors have identi-
fied 14 systems as likely candidates for near-term commercial development in
this country; these are identified in Table 12.
27
-------
TABLE 11. STATUS OF U.S. AND FOREIGN LOW- AND MEDIUM-BTU GASIFICATION SYSTEMS
[ urgi
We) hitan—Galusha
Woodal 1 -Duckhani/
Gas Integrale
koppers— lotzek
Wink i cr
Chapniaii (WI Iputte)
Riley Morgan
Weilnian Incandescent
t (GC/Lurqi Slogging
(Ii -Gas
Foster Wheeler/Stoic
Pressurized Wellinon—
Galusha (MFRC)
(;FIRC Slagging
1 exaco
O cR I ow—iltu
Coitihus t ion Engineering
Ilygas
Syn thane
CO 2 Acceptor
Foster Wheeler
Babcock & WI Icox
U-Gas
Licenser/developer
Lurgi Mineral iltechnik Guitbll
WlJowell Weilnian Engineering Co.
Woodall-Duckharuu ((ISA), Ltd.
Koppers Company, Inc.
Davy Powergas
Wilptu tte Corp.
Riley Stoker Corp.
Applied lechnology Corp.
tin Li sit Gas Corp. and lurgi
Mineralol techuulk Gebil
Ri tuunl nous Coal Research, Inc.
Foster Wheeler/Stoic Corp.
[ BOA
[ BOA
Texaco Devol opulent Corp.
Di luuuui ruous Cos 1 Resea rch • I tic
Combus t I on Luugi neeri ng Corp.
Ins Li Lu to of Gas Technology
[ BOA
Fore i go
05/ Foreign
Foreign
Ford go
Foreign
‘is
US
US/Foreign
I Oreigul
iJS
(is
- (IS
- its
1* (iS
- 1 15
- US
- US
- Us
- (is
- (IS
- us
- (IS
US
US
Couuiiie rc I a I
Coimue rc I a I
Conimercial
Coiu iniercial
Coinuiue rc I a)
Cou;iuie rc Ia 1
Comiiercial
Couuinerc Ia 1 /
l)euiiouts tra Lion
OeIin)ns Ira Li on
I)euuiotis tra lion
(lesions tro lion
Demon s Irat ion
t)eniouis trat ion
(lemons Ira lion
l)cmmiou istration
Llemmmons Ira Li on
(lesions trot ion
(Iii yh — II tu
I) ummorus tra Li on
(Ill giu—B tu
Iieinons tra Li out
(Ill gh— B Lu)
Pilot
Pilot
Piiot (400
lb/hr coal)
Pilot
Pilot
Number of gasifiers currently operating (No. of gasifiers built)
tow- F Medium- I Synthesis I
! 9 _L j Location Scale
(22)
(8)**
(39)**
6(14)
N.)
5 (39)
8( 15(}) -
(72) 5* -
- (23)**
2(12) -
I —
(.*)*a
1
- 1
1 —
1* -
— 1
— 1
— I
1( 1k)
Foster Wheeler Energy Corp.
Ihe babcock & Wilcox Co.
I is Ii Lute of Gas 1 echnoloqy,
Phillips Petroleum Corp.
Westinghouse E icc tn c Corp.
I ocx Resources , Inc.
Wes tin qiu ouce
Coo lox
5 Under cons Iructi on.
Lleiumonstration scale indicates 2000 to 1(1,000 lb/hr cool feed.
Pilot scale indicates 400 to 1500 lb/hr coal feed.
55 Udt tied number overseas curreul t ly in operati on.
Source: Low- and Mediuni- Din Gas III cation Sys(ems Technology Overview, [ PA-imOO/7-18 -06 I , March (9 1G.
-------
TABLE 12. PROMISING LOW— AND MEDIUM-BTU GASIFICATION*
First Group’
Second Group 2
Third Group 3
Weilman-Galusha
Chapman (Wilputte)
Pressurized Weilman—
Galusha (MERC)
Lurgi
Riley Morgan
Woodall Duckham/
BGC/Lurgi Slagging
Gasifier
Gas Integrale
Texaco
Koppers-Totzek
Bi-Gas
Wi nkler
Coalex
Wellman Incandescent
Foster Wheeler/Stoic
1 Cormiercially available; significant number of units currently operating
in the U.S. or in foreign countries.
2 Commercially demonstrated in limited applications.
3 Commercial— or demonstration—scale units operating or being constructed;
technology is promising and should be monitored.
*
Source: ‘ 1 Low— and Medium-Btu Gasification Systems: Technology Overview,’
EPA-600/7-78-061, March 1978.
29
-------
4.1.3 Status of High—Btu Gasification
Currently there are no high-Btu gasification facilities producing
substitute natural gas either in the U.S. or abroad. Table 13 provides a
summary of the status of proposed commercial and demonstration projects, and
pilot and bench/process demonstration units.
4.1.4 Status of Coal Liquefaction
Table 14 summarizes the status of coal liquefaction systems in the U.S.
As of June 1978 the only plants in operation were two solvent refined coal
(SRC) pilot facilities. An H—Coal pilot plant is presently under construc-
tion in Catlettsburg, Kentucky, but will not be operational until late 1979.
4.2 EPA REGULATORY APPROACHES
The EPA program offices have the responsibility for the development of
criteria and standards for air, water, and land protection. The Office of
Enforcement has the responsibility for national enforcement of those criteria
and standards that have been promulgated into the Code of Federal Regulations.
The EPA regional offices have the responsibility for guidance to the states
in their respective regions, compliance monitoring, and enforcement. The
role of each of these offices with respect to EPA ’s possible regulatory
approaches for synthetic fuels technology point sources will now be
considered.
4.2.1 Air Programs
The statutory authority for the regulatory activities of the Office of
Air Quality Planning and Standards (OAQPS) is the Clean Air Act, Public Law
88—206, 77 Stat. 392 (1965), U.S.C. 1857 et seq. , as amended by the Air
Quality Act of 1967, Public Law 90-148; the Clean Air Act Amendments of 1970,
P.L. 91-607; Public Laws 92-157, 85 Stat. 431, 93-15, 87 Stat. 11, 93-319,
88 Stat. 146; the Clean Air Act Amendments of 1977, P.L. 95-95, 91 Stat. 685;
and P.L. 95-190, 91 Stat. 1393. Th ese are collectively referred to as the
“CM” in what follows.
The regulatory mechanisms authorized in these statutes are as follows:
30
-------
TABLE 13. PROPOSED HIGH-BTU GASIFICATION COMMERCIAL AND DEMONSTRATION PROJECTS
AND PILOT AND BENCH PD$J PROGRAMS*
Process Sponsor/1)eveloper Deslgner/ Location Capacity Status
P r pos e d cthmne rc Ia! P ro ec ts
Burnhaiui Project El Paso Natural Gas Co., El Paso Natural Northwest New Mexico 2MM Nm 3 /D (72 MMSCFD) FERC application pending; plant
Pacific Gas & Electric, Gas Co. site lease under negotiation.
and an unnamed third
partner
Dunn Center Project Natural Gas Pipeline NGPCA Dunn County, ND 7MM Nm 3 /D (250 MMSCFL)) Water permit application denied
Co. of America (NGPCA) in June 1916; new application
under development.
WESCO Project Texas Eastern lrans iuijs- TE l-PLC Northwest New MexIco 1MM Nm 3 /D (250 I’VISCFD) Project pending per FERE. certifi-
sion arid Pacific i.ight- cation, project firninciny, and
ing Corp. (1(1-PLC) plant site lease.
Mercer County American Natural ANG, PGC Fiercer County, ND 7MM Nm 3 /l) (260 MMSCFD) Plans tentative due to lack of
Project Resources Co. (ANG) and Federal approvals and loan
Peoples Gas Co. (PGC) guarantee to fi riance construction.
Proposed demons tratlon Projects
Slagging Lurgi VOL and CONOCO Coal Foster-Wheeler Noble County, Oil 3450 tpd (3800 ton/ 22-month contract for engineering
Development Co. Energy Corp. day) arid technical SU 1 )port awarded by
DOE in mid-1977. Construction
phase (30 inos) and operation
phase (42 was). Contracts to be
awarded at later date.
Cogas VOL arid Illinois Coal Dravo Corp. Perry County, II. 2000 tpd (2200 tonI 21-month con tract for conceptual
Gasification Group day) design awarded mid-1977 by DOE.
ilyqas DOE- Insti lute of Gas I’rocon, inc. $7. 5M contract l for conceptual
Technology design of 7MM Nirr 3 /D (250 MMSCFD)
conmiercial facility plus a smaller
single-train demonstration
facil ity.
Pilot Projects
iiygas DOE, Institute of Gas institute of Gas Chicago, II 13 tpd (80 ton/day) Operational since 19/3. Will corn-
rechnology and American Technology tirnue through 1978. Successfully
Gas Associ a ti on tes ted noru.ak I nq Montana lignite
and subbi luminous and caking
Illinois bituminous coals.
Synitliarie DOE (P [ RC) I unions Co. I3ruceton , PA 65 tpd (12 ton/day) Opera tional since iiiid- 19/6.
Opera ti on to coot I flue through
Sept. 1918. Nonaqylomerating
coals successfully tested. Opera-
tions plagued by a number ol
mocha iii cal prol) 1 ems
-------
TABLE 13 (continued)
Recently constructed; limited
testing conducted to date includ-
ing Independent operation of the
burner and gasifler up to 130 hrs.
Approximately 2 yrs additional
testing needed for complete pro-
cess evaluation.
Slagging Gasifier
I)OE (GFERC)
Stearns-Roger, Inc.
Grand Forks • ND
0.91 tpd (1.0 ton/day)
Operated from 1958-65 under
Bureau of Mines. DOE contract
awarded to Stearns .-Royer in Oct.
1977 Involves modification and
operation of the pilot plant
using bituminous coals.
Conoco, BGC, etc.
BGC
Westfield, Scotland
3-year prograril haS Involved modi-
ficatlori of a lurgi yasifler and
its operation under slayging COIl-
ditlons. Ohio No. 9 and Pitts-
burgh No. 0 coals have boen tested.
(0 2 -Acceptor DOE and CONOCO Coal
Development Co.
9.1 tpd (10 ton/day)
Ilydrane P011; 0.23 tpd
(0.25 ton/hr) bench-
scale hydroyasifica-
tion reactor
Constructed In 19/2; 4? runs con-
ducted to date on a variety of
coals and two types of acceptors.
Jesting was completed In fall
1977, hayIng demons tra ted techni -
cal leasibillty of the process.
Ilydrane PDU recently built by
Dravo for DOE; a bench-scale
Rocketdyne hydrogasi ficatlon
reactor Is also being tested for
DOE and appears to be superior to
the Hydrane unit. Rocketdyne
contract to expire in 1978.
Garrett Process
Exxon Process
Occidental Research
& Development Co.
Exxon Co.
Occidental Research
& Development Co.
Exxon
CaVerne, CA
3.2 tpd (3.6 ton/day)
0.45 tpd (0.5 ton/day)
Plant has operated with West
Keptucky co4ls to produce 229
100 kcal/Nn’ (/00 fltu/scf) gas.
Small—scale testing is continuing.
Des iyner/
. —-
Self-Agglomerating
DOE,
Battelle Memorial
Battelle Memorial
Ash
Gas
InstItute, and
Association
American
Institute
West Jefferson, Oil
Capacity Status
23 tpd (25 ton/day)
N)
i lydrane DOE (PERC) and
Rocketdyne
CONOCO
Dravo Corp.
Rocke tdyne
36 tpd (40 ton/day)
Rapid City, SC
Bruceton, PA
ASource. Environmental I\ssessiaent Data Base for Hiqh -Btu Gasification lechnology: Volume 1. lechnical Discussion, EPA-600/1-/8-lU6a, September 1978.
-------
TABLE 14. STATUS OF COAL LiQUEFACTION SYSTEMS*
Process Sponsor/Developer locatIon Capacity Status
CSI DOE/Fluor Fluor/Liquefled Cresap. WV Operational.
Coal 0ev. Corp.
Pilot Plants
Catalytic Coal Gulf R&D Gulf R&D I tpd Work on CCL discontinued.
Liquefaction
Exxon I)onor Exxon, DOE Carter Oil 250 1PIJ Construction proceeding; startup
Dec. 1979.
Solvent EPRI, etal. (Exxon)
il-Coal DOE, EPRI, etal. Ashland Oil Catlettsburg, KY 600 tpd Construction procee(I rig; startup
late 1979.
SRC DOE/Pittsburgh arid PMCMC Ft. Lewis, WA 50 tpd (SCR I) Operating.
Midway Coal Mining Co. 35 tpd (SCR II)
SCO D OE/EI’R I/Southcrn Southern Company Wi 1 sonvi lIe, At 6 tpd (SCR I) Operating.
Company Services, Inc. Services, Inc.
Bench/POD— Scale
Co-Steaur 1)01 (GFERC) GIERC University of 5 pph Opera ti rig.
North Dakota
Doe/Luriiuus Co. Lu inrurus 30 pph Operating.
Rocketdyne DOE/Rockwell mt. Rockwell --- 500 pph Operating.
(Rocketdyne Div.)
*Source: “Synthetic Fuels Quarterly Report.” Volume IS. Number 4, December 1978, Cameron Engineers, Inc.
-------
1. National Ambient Air Quality Standards (NAAQS) - These are
established by EPA under Sections 108 and 109 of the CAA. The
current criteria pollutants are shown in Table 15 along with
their maximum permissable concentrations in ambient air and
the time over which actual ambient air concentrations are to
be averaged for comparison to the NAAQS values. The primary
standards are those requisite to protect public health. The
secondary standards are those requisite to protect public
welfare from any known or anticipated adverse effects.
In addition to these, the EPA Administrator has been
directed by the CM Amendments of 1977 to consider promulgation
of standards for cadmium, arsenic, polycyclic organic matter
(POM), and radioactive pollutants if these are found to cause
or contribute to air pollution and endanger public health.
These may, if appropriate, be regulated instead through NSPS
or NESHAP, as explained below.
2. State Implementation Plans (SIP) - Under Section 110 of the
CAA, states must submit for EPA approval plans for the imple-
mentation, maintenance, and enforcement of each NAAQS (primary
and secondary) in each air quality control region (AQCR) or
part thereof in the respective states. If a state fails to
enforce its plan, EPA may enforce it.
One key element in state control over stationary sources
is the use of a permit procedure specifically limiting emis-
sions for given sources. Permit applications are reviewed by
both state agencies and EPA regional offices. During the review
process, control techniques documents reviewing methods for
each of the criteria pollutants are used to ascertain the ade-
quacy of proposed controls by the permit applicant.
3. New Source Performance Standards (NSPS) - Section 111 of the CAA
requires EPA to set standards of performance for new or modified
stationary (point) sources. These are nationally applicable
direct emission limitations for specific source types (e.g.,
fossil fuel-fired steam generators). This limitation reflects
34
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TABLE 15. NATIONAL AMBIE 1T AIR QUALITY STANDARDS
Pollutant
Averaging I
Time I
Primary
Standards
Secondary
Standards
Particulate matter*
Annual (geometric
mean)
75 ig/m 3
260 ig/m 3
60 i .ig/m 3
150 i.ig/m 3
Sulfur dioxide
24—hour I 260 g/m 3
Annual (arithmetic 80 ig/m 3
mean) (0.03 ppm)
24—hour 365 ig/m 3
(0.14 ppm)
3—hour —-—
150 ig/m 3
---
--—
1300 iig/m 3
(0.5 ppm)
Carbon monoxide
8-hour
1-hour
10 mg/rn 3
(9 ppm)
40 mg/rn 3
(35 ppm)
Same as primary
Photochemical
oxidants
1-hour
160 ‘ig/m 3
(0.08 ppm)
Same as primary
Hydrocarbons
(nonmethane)
3—hour
(6 to 9 am)
160 g/m 3
(0.24 ppm)
Same as primary
Nitrogen dioxide
Lead
Annual (arithmetic 100 pg/m 3
(mean) (0.05 ppm)
Calendar quarter L 1.5 g/m 3
Same as primary
Same as primary
*The secondary annual standard (60 i g/m 3 ) is a guide to be used in assess-
ing implementation plans to achieve the 24-hour secondary standard.
Expressed as ozone by the Federal Reference Method. Proposed change to
•ozone published June 1978. Proposed new primary standard 0.1 ppm.
This NAAQS is for use as a guide in revising implementation plans to
achieve oxidant standards.
This standard is currently under review by the EPA Administrator to deter-
mine whether an AAQS for NO 2 based on a 3-hour average would be more
appropriate for public health protection. Discussion of this was scheduled
for publication in the Federal Register in January 1979.
35
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the percentage reduction achievable through use of the best
technological system of continuous emission reduction (taking
into account cost, non-air quality health and environmental
impact, and energy requirements) which the EPA Administrator
determines has been adequately demonstrated. In those cases
where it is not feasible to prescribe or enforce a standard of
performance, the Administrator may instead promulgate a design,
equipment, work practice, or operational standard, or a combina-
tion of these, which has been determined to adequately demonstrate
the best technological system of continuous emission reduction
(taking into account cost, non-air quality health and environ-
mental impact, and energy requirements). These NSPS regulations
must be reviewed and revised, if appropriate, every four years.
4. National Emission Standards for Hazardous Air Pollutants (NESHAP) -
Section 112 of the CAA defines a hazardous air pollutant as one
for which no NAAQS is applicable and which, in the judgement of
the Administrator, causes or contributes to air pollution in a
manner that may result in an increase of mortality or irreversible
or incapacitating reversible illness. This section authorizes
the Administrator to set emission standards for these hazardous
substances which are applicable to any new source or modified
existing sources. Table 16 lists the hazardous substances for
which NESHAP values have been promulgated.
TABLE 16. NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP)
Pollutant
Re
gui
ation
Asbestos
40
CFR
61,
Subpart
B
Beryllium
40
CFR
61,
Subpart
C
Mercury
40
CFR
61,
Subpart
E
Vinyl Chloride
40
CFR
61,
Subpart
F
36
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The procedures of Air Quality Programs Office by which environmental
standards are developed will be reviewed. Figure 4 shows the analysis and
decision—making procedure used by OAQPS. The initial decision is based on
adverse health or ecological effects. If these are found to be significant,
there follows a branching chain of possible actions based on the answers to
definitely posed questions. Each “yes” or “no” answer to these questions
must be conclusive. Answers such as “significantly,” “maybe,” “perhaps,”
“could be,” or conclusive opposites to the indicated answer follow the
undesignated path between question points. The end points of this question-
ing procedure are preferred regulatory approaches.
The key features, information requirements, and time required to develop
standards for the various options are shown in Table 17. In the NSPS column,
it should be noted that, with the new four-year review deadlines imposed by
the Clean Air Act Amendment of 1977, it is probable that the NSPS preparation
time will be considerably shortened, perhaps to 18 to 24 months. Because of
their nationwide implications, the NAAQS are the most time consuming to
establish, document, and implement. Not shown here or on the chart of Figure 4
is the option for a “prevention of significant deterioration” approach. This
is authorized under Part C of the CM. Table 18 shows the maximum permissible
increase in concentration above baseline values under various averageable
conditions for Class I, Class II, and Class III areas. The 1977 Amendments
designate the following mandatory Class I Federal areas: international parks,
wilderness areas in excess of 5000 acres, national memorial parks in excess
of 5000 acres, and national parks in excess of 6000 acres. Initially all
other areas are designated as Class II, but the States may, under certain
conditions, re—designate certain areas toward either the more pristine Class I
or the dirtier Class III. However, the latter requires an extensive public
hearing procedure.
By August 1979 the EPA Administrator must promulgate similar classifica-
tion incremental values for hydrocarbons, carbon monoxide, photochemical
oxidants, and nitrogen oxides. For any other pollutant for which NMQS are
established, EPA must promulgate classification incremental values within two
years of promulgation of the standard.
37
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PROBLEM
ASSESSMENT
PREFERRED
REGULATORY
APPROACH
DECISION
PROCESS
( )
Figure 4. Preferred Standards Path Analysis Flow Chart for Air Quality Programs.
-------
TABLE 17. PRINCIPAL AIR POLLUTION REGULATORY OPTIONS FOR SYNTHETIC FUELS INDUSTRY REGULATION
If pollucant is neither a criteria poHutant under Section 08-110 nor a hazardous pollutant
under Section 112, states must apply similar control to existing sources of the same indus-
trial type based on best available control technology.
Regulatory process is usually expedited due to public pressure to eliminate health hazards.
‘ .O
PRINCIPAL
STRATEGY
National Ambient Air
Quality Standard
erormance
National Emissions Standard
for Hazardous Air Pollutants
CLEAN AIR ACT
SECTIONS
INVOLVED
108, 109, 110
111(b), (d)
112
KEY FACTORS
Pollutant oriented.
Most difficult to write;
requires control of all
emission sources; acts
via state implementation
plans.
Source oriented.
Specific to
industry.
Pollutant oriented.
Health effect involves mor-
tality, serious, irreversible,
or incapacitating reversible
human illness.
EPA
LEAD ORGANIZATION
FOR IMPLEMENTATION
S t
ta es
EPA
INFORMATION
REQUIREMENTS
Health and welfare
information; control
technologies and costs;
effect of emission
reductions on air
quality.
Administrative
judgement of con-
tribution to air
pollution; infor-
rnation on effec-
tiveness and costs
of control
techniques.
Knowledge or emission level
providing ample margin of
public safety
TIME REQUIRED
TO DEVELOP
REGULATION
2-6 years or more; addi-
tional time is required
to develop and implement
state implementation
plans.
Typically 3 years.
Typically 2 years (see Note 2).
I
Notes: 1.
2.
-------
TABLE 18. MAXIMUM PERMISSIBLE INCREMENTS FOR SULFUR DIOXIDE AND PAR-
TICULATE MATTER CONCENTRATIONS IN AMBIENT AIR FOR EACH PSD
CLASS COMPARED TO NAAQS VALUES
Pollutant
Period for
Averaging
Maxi mum Concentra
(Quantities
Class I Class II
ti on Increme
in iig/m 3 )
Class III
nts
NAAQS 1
SO 2
Annual
2 20
40
80
24-hour
8 91
182
365
3-hour
25 512
700
(1,300)
TSP
Annual
24-hour
5 19
10 37
37
75
75,(60)
260,(150)
‘Secondary standards indicated in parentheses
In order to protect Class I areas, no major emitting facility can be
constructed without a permit establishing emission limitations. Prior to the
issuance of such a permit, EPA must require an analysis of the ambient air
quality and visibility, climate and meteorology, terrain, soils, and vegeta-
tion, both at the site of the proposed facility and in the area potentially
affected by emissions from the facility, for each pollutant regulated under
this Act. Furthermore, EPA must determine the degree of continuous emission
reduction which could be achieved by the facility.
Another regulatory approach has been made possible under Part D of the
CM. This deals with “non—attainment areas,” i.e., those which are polluted
above the levels necessary to protect health and welfare. It puts into
effect an offset policy which, in effect, can regulate industrial growth in
such areas. In order to issue a permit to a major new source, which seeks
to locate in the non-attainment area, the State must show that the total
emissions from all sources in the area will be sufficiently less than the
total emissions allowed for existing sources prior to construction of the
major new source. In other words, the baseline for calculating offset is
the total emissions allowed in the SIP without taking the new source into
consideration. As a condition for permitting major new stationary sources to
locate in non-attainment areas, the States are required to obtain EPA approval
for revised SIPs which include provision for attainment of the primary NAAQS
values (health—related standards) no later than December 31, 1978, except for
40
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photochemical oxidant and carbon monoxide, for which attainment is delayed
until December 31, 1987. Among other things, the new SIP must include a per-
mit program for new stationary sources in which they must operate at the
“lowest achievable emission rate’ reflecting the most stringent emission
limitation contained in SIP for any such class or category of source or
the most stringent emission limitation which has been achieved in practice,
whichever is most restrictive.
Because of the short time which has elapsed since the Clean Air Act
Amendments of 1977 have become law, it is still too early to forecast how
these newer regulatory approaches will incluence the location and pace of
growth of coal gasification and liquefaction facilities.
4.2.2 Water Programs
The statutory authority for the regulatory activities of the Office of
Water Planning and Standards (OWPS) and the Office of Water Programs (OWP) is
the Federal Water Pollution Control Act of June 30, 1948 Ch. 758, as amended
by P.L. 92-500; P.L. 93—207, December 28, 1973; P.L. 93—243, January 2, 1974;
P.L. 93-611, January 2, 1975; P.L. 94-238, 90 Stat. 250, March 23, 1976; and
by P.L. 95-217, 91 Stat. 1566, December 27, 1977. These are collectively
referred to as FWPCA in what follows.
The regulatory mechanisms authorized in the FWPCA which would apply to
synthetic fuels plants in Tital III Standards and Enforcement are as follows:
1. Effluent Guidelines - Section 301 divides pollutants in industrial
water discharges into three categories, each with a specific
level of control to be imposed by a specific date. First, there
are “conventional” pollutants, which are listed in Table 19.
These are subject to “best conventional pollutant control tech-
nology” (BCT) with a deadline for achievement of July 1, 1984.
All other pollutants not identified as conventional or toxic are
designated “non-conventional.” They require BATEA with a dead-
line of three years after an effluent limitation is established
or by July 1, 1984, whichever is later. Section 304 directs the
EPA Administrator to develop and publish, with appropriate updat-
ing, criteria for water quality and information on measurement,
classification, restoration, and maintenance of water quality.
41
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TABLE 19.. CONVENTIONAL POLLUTANTS SUBJECT TO BEST CONVENTIONAL
CONTROL TECHNOLOGY (BCT) BY JULY 1, 1984
Suspended
solids
Oil and
grease*
Biological
oxygen
demanding
Phosphorous*
pH
Chemical
oxygen
demanding*
Fecal coil
form
*
Proposed
Section 306 lists 27 industrial categories, at a minimum, for
which new sources must meet nationally applicable standards of
performance to be promulgated by EPA. States may apply standards
of performance if these and their enforcement is at least as
stringent as the national standard. Section 302 allows the appli-
cation to a point source or a group of such sources of effluent
limitations (including alternative effluent control strategies)
which may differ from the Section 301 specifications if such a
change is necessary to achieve and maintain water quality in a
specific portion of the navigable waters of the Nation.
2. Toxic and Pretreatment Effluent Standards - Section 307 deals
specifically with the substances in Table 20 and those which may
be added later to this category by the EPA Administrator. The
standards imposed, after suitable hearings, may include complete
prohibition of the discharge of one or more of these substances.
This Section also authorizes EPA to establish standards for pre-
treatment of industrial streams prior to their discharge into
municipal or industrial treatment works.
3. Water Quality Ambient Standards - Section 303 authorizes EPA to
establish water standards in those cases where States have failed
to promulgate and enforce an acceptable standard.
4. Permits and Licences — In those cases where there exists no
Federal emission limitati6n or standard, certain States (30 now
quality) may accept application and certification of any activity
which proposes to discharge into navigable waters. The State
applied to must notify EPA for a determination that the activity
42
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TABLE 20. TOXIC POLLUTANTS SUBJECT TO BEST AVAILABLE CONTROL
TECHNOLOGY ECONOMICALLY AVAILABLE (BATEA)
1. *acenaphthene
2. *acrolejn
3 *acrylonjtrile
4
5 *benzjdjne
6. *carbon tetrachloride
(tetrachioromethane)
*chlorjnatedbenzenes (other than
dichlorobenzenes)
7. chlorobenzene
8. 1,2,4-trichlorobenzene
9. hexachlorobenzene
*chlorinated ethanes (including 1,2—
dichloroethane, 1,1,1-trichioro-
ethane, and hexachioroethane)
10. 1,2-dichloroethane
11. 1,1,1-trichioroethane
12. hexachloroethane
13. 1,1-dichioroethane
14. 1,1,2-trichloroethane
15. 1,1,2,2—tetrachloroethane
16. chloroethane
*chloroalkyl ethers (chloromethyl,
chioroethyl, and mixed ethers)
17. bis(chloromethyl) ether
18. bis(2-chloroethyl) ether
19. 2—chloroethyl vinyl ether (mixed)
*chlorinated naphthalene
20. 2-chloronaphthalene
*chlorinated phenols (other than
those listed elsewhere; includes
trichlorophenols and chlorinated
cresols)
21. 2,4,6—trichiorophenol
22. parachlorometa cresol
23. *chlorofoy . .m (trichloromethane)
24. *2_chiorophenol
*di chlorobenzenes
25. 1,2-dichlorobenzene
26. 1,3-dichlorobenzene
27. 1,4-dichlorobenzene
*dj chl orobenzi dine
28. 3,3-dichlorobenzidine
*djchloroethylenes (1,1-dichloro—
ethylene and 1,2-dichloroethylene)
29. 1,1-dichloroethylene
30. 1,2-trans-dichloroethylene
31. *24_dichlorophenol
*djchloropropane and dichloro-
propene
32. 1,2-dichloropropane
33. 1,2-dichloropropylene (1,3-
di chioropropene)
34• *2 ,4-di methyl phenol
*dj ni trotol uene
35. 2,4-dinitrotoluene
36. 2,6-dinitrotoluene
37 *1,2_djphenylhydrazjne
38. *ethylbenzene
39 *fluoranthene
*haloethers (other than those
listed elsewhere)
40. 4-chlorophenyl phenyl ether
41. 4-bromophenyl phenyl ether
42. bis(2-chloroisopropyl) ether
43. bis(2-chloroethoxy) methane
*halomethanes (other than those
listed elsewhere)
44. methylene chloride (dichioro-
methane)
45. methyl chloride (chloromethane)
46. methyl bromide (bromornethane)
47. bromoform (tribromomethane)
48. dichlorobromomethane
49. trichlorofluoromethane
50. dichlorodifl uoromethane
51. chl orodi bromomethane
52. *hexachlorobutadjene
53. *hexachlorocyclopentadjene
54 *isophorone
55 *naphthalene
56. *njtrobenzene
*nitrophenols (including 2,4-
dinitrophenol and dinitrocresol)
57. 2-nitrophenol
58. 4-nitrophenol
59• *2,4djnitrophenol
60. 4,6-dinitro-o-cresol
*flj trosami nes
61. N-nitrosodimethylamine
62. N-nitrosodiphenylamine
63. N-nitrosodi-n-propylaniine
64. *pentachl orophenol
65. *phenol
*phthalate esters
66. bis(2-ethylhexyl) phthalate
*Specific compounds and ch rnical classes as listed in the consent decree.
(continued)
43
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TABLE 20 (continued)
98. endrin
99. endrin aldehyde
*heptachlor and metabolites
100. heptachlor
101. heptachior epoxide
*hexachlorocyclohexane (all isomers)
102. a—BHC-Aplha
103. b-BHC-Beta
104. 4-BHC(lindane)-Gamma
105. g-BHC-Delta
*polychlorinated biphenyls (PCB’s)
106. PCB-1242 (Arochlor 1242)
107. PCB-1254 (Arochlor 1254)
108. PCB-1221 (Arochlor 1221)
109. PCB-1232 (Arochior 1232)
110. PCB-1248 (Arochior 1248)
11].. PCB-1260 (Arochlor 1260)
112. PCB-1016 (Arochior 1016)
113. *toxaphene
114. *antjmony (total)
115. *arsenic (total)
116. *asbestos (fibrous)
117. *berylljum (total)
118. *cadmjum (total)
119. (total)
120; *copper (total)
121. *cyanjde (total)
122. *lead (total)
123. *mercury (total)
124. *njckel (total)
125. *selenjum (total)
126. *sjlver (total)
127. *thalljum (total)
128. *zjnc (total)
129. **2 ,3,7 ,8-tetrachl orodi benzo-p-
dioxin (TCDD)
130. ammonia as NN3
131. manganese
*Specific compounds and chemical classes as listed in the consent decree.
**This compound was specifically listed in the consent decree. Because of the
extreme toxicity (TCDD) EPA recommends that laboratories not acquire ana-
lytical standard for this compound.
67. butyl benzyl phthalate
68. di-n—butyl phthalate
69. di-n—octyl phthalate
70. diethyl phthalate
71. dimethyl phthalate
*polynuclear aromatic hydrocarbons
72. benzo(a)anthracene
(1,2-benzanthracene)
73. benzo(a)pyrene (3,4-benzopyrene)
74. 3,4-benzofluoranthene
75. benzo(k)fluoranthene (11,12-
benzofl uoranthene)
76. chrysene
77. acenaphthylene
78. anthracene
79. benzo(ghi )perylene (1,12-benzo-
peryl ene)
80. fluorene
81. phenanthrene
82. dibenzo(a,h)anthracene (1,2,5,6-
di benzanthracene)
83. indeno(1,2,3—cd)pyrene (2,3-o—
phenyl enepyrene)
84. pyrene
85. *tetrachl oroethylene
86. *toluene
87. *trjchloroethylene
88. *vjfly1 h1 r.jd (chloroethylene)
pesticides and metabolites
89. *aldrjn
90.
91. *chlordane (technical mixture and
metabol i tes)
*DDT and metabolites
92. 4,4’-DDT
93. 4,4’—DDE (p,p’—DDX)
94. 4,4’—DDD (p,p’-TDE)
95. a—endosulfan—Alpha
96. b-endosulfan- Beta
97. endosuifan sulfate
44
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will not degrade water quality of another State. Following
approval of the application, a permit or license may be issued
to the activity. For activities in States other than those
qualified, EPA must be the agency to which application is made.
Permits are issued for terms not exceed five years and may be
terminated or modified for cause. The authority and conditions
for the permit programs are in Sections 401 and 402 of the FWPCA.
5. State Guidelines - Section 208 of the FWPCA authorizes the
Governor of each State to designate areas within that State as
being under area—wide waste treatment management. The State must
then establish and operate such a management program following
EPA approval of its regulatory plan. Guidelines developed for
such programs would not have national applicability.
6. Ocean Dumping - Under the Marine Protection, Research and Sanctu-
aries Act of 1972, EPA is authorized to designate ocean dumping
sites, issue permits for ocean dumping (which may include imple-
mentation plans to phase out such dumping, and assess penalties
for improper ocean dumping.
The method of analysis used by OWPS in determining the regulatory approach
to be used is illustrated in Figure 5. Table 21 summarizes the regulatory
options.
Groundwater protection is provided by regulations promulgated by EPA
under the authority of the Safe Drinking Water Act, P.L. 95-523, 86 Stat.
1660 as amended by P.L. 95—190, 21 Stat. 1393. Environmental protection is
administered under this law through the Office of Water Supply.
Protection of underground sources of drinking water is provided by
Part C of the SDWA, which establishes a mechanism for the permitting of
underground injection by industry only under environmentally safe circum-
stances, to be decided by EPA. The key factors and time period involved are
shown in Table 22.
Note that as of now there exists no specific Federal authority over the
extraction of water from wells.
Figure 6 shows the decision pathway used to determine the best regulatory
approach for groundwater protection under SWDA.
45
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PROBLEM ASSESSMENT
SUPPORTING
INFORMATION
DEVELOPMENT
NO AC ION
REUIJII4Et)
DE1EFIMINI EFFLUENT
OUALI1Y AND QUANTITY
CHAR ACT E I t IS IICS
00 EFILUENES POSE
A IHULAI 10 WATER
OUALII Y?
DECISION
PROCESS
PREFERRED
REGULATORY
APPROACH
DETERMINE REEl THEAIMENT/
CIJN1 ROL TEChNOLOGY AND
RESULTANT EFFLUENT QUALITY
I DEVELOP INt)USEHY POE LUIANT
J PROFILES INCLUDING NATURE
] AND EXTENIOF ENVIRONMENtAL
CONTAMINAI ION
-—
I DETERMINE CONCENTRATION
J AND DOSE EFFECT RELATION-
SHIPS FOR WATER-ASSOCIATED
PLANTS, ANIMALS, AND HUMANS
-I
DEFERMINE ECONOMIC
IMPACT OF IHEAIMEIJT/
CONTROL OPTIONS
WASTE CONSTITUENTS
IS PNOBLLM UI NA1 IONAL -JCONSIDUI LI-ELOENI
CONCERN’ [ GOIOEI INF S
-j
DEVELOP ENVINONMEN IAL FAtE
ANT) EFFLCE DATA
-
Figure 5. Preferred Standards Path Analysis Flow Chart for Water Quality Programs.
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TABLE 21. PRINCIPAL WATER
QUALITY OPTIONS FOR SYNFUELS INDUSTRY REGULATION
REGULATORY
APPROACH
Water Quality
Ambient Standards
State has primary
unless it fails to
write an acceptable
standard.
Effluent
Guidelines
Focuses on point
sources of efflu-
ents; requires con-
siderable EPA
support.
Toxic and
Pretreatment
Effluent Standards
Burden of proof on
EPA for establishing
criteria safe
levels. Requires
preliminary proposal
as a toxjc substance.
Control via Sectiorì
208 Agencies
Relies on state
agencies to establish
adequate control tech-
nology guidelines so
would not have national
applicability.
KEY FACTORS
FEDERAL WATER
POLLUTION CON-
TROL ACT SECTION
303
301,302,304,306,
402
307
301,302,208
INFORMATION
REQUIREMENTS
Health and environ-
mental effects.
Identification of
potential uses for
specific body of
water.
Health and environ-
mental effects,
Treatment technology
and costs
Health effects;
emission level with
margin of safety.
Treatment technology
and costs.
Health and environ-
mental effects.
TIME REQUIRED
TO DEVELOP
REGULATION
About 1 year
2½ to 3½ years.
Toxic: 2½-3½years
Pretreatment: 1-4
years.
EPA guidance could be
developed in 6 to 18
months.
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TABLE 22. PRINCIPAL GROUND WATER PROTECTION OPTIONS FOR SYNFUELS INDUSTRY REGULATION
INJECTION OPERATIONS EXTRACTION OPERATIONS
REGULATORY APPROACH
Permit issuance under
Administrator’s
Decision No. 5
Permit issuance under
40 CFR 146.
No specific Federal
authority exists; must be
addressed under State
authority over extractive
wells.
KEY FACTORS
Requires mandatory sub-
mission of data regard-
ing proposed well design,
operation, relation to
other wells and geologic
structures, etc.
Similar data required,
but some items are at
the option of the per-
mit issuing authority,
Fluid extraction may
affect drinking water
aquifers or may cause
subsidence in certain geo—
logic structures.
INFORMATION
REQUIREMENTS
Application of existing regulations requires knowl-
edge of compatibility of injected fluids with
formations and possibilities for pretreatment.
TIME REQUIRED TO
DEVELOP IMFORMATION
Eighteen months to determine problem boundaries and
point out areas of specific concern. Some required
information is site-specific and will need deter-mi-
nation on an individual basis as part of permit
issuance.
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PROBLEM ASSESSMENT
SUPPORTING
INFORMATION DECISION REGULATORY
DEVELOPMENT PROCESS APPROACH
[ NO ACTION HEUUII ]
DETERMINE WHETHER NON
TREATABLE WASTE WATER
CAN BE INJECTED INTO SUB
YL S ________
I [ ATL
______________ I APPLICATION FOR TREAT
‘I MINT AND DISCHARGE
UNDER NPDIS
Figure 6.
Regulatory Path Analysis Flow Chart for Groundwater Protection.
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As will be discussed below, the Office of Solid Waste will soon publish
regulations that will enhance strongly EPA’s mission of protecting both
surface and ground waters.
4.2.3 Solid Waste
The program for environmentally safe disposal of solid waste is
administered by the Office of Solid Waste (OSW) under the statutory authority
of the Resource Conservation and Recovery Act of 1976, P.L. 94-580, 90 Stat.
2795. This is abbreviated to RCRA in the following discussion.
Under the RCRA an essential distinction is made between hazardous solid
wastes and nonhazardous solid waste. OSW is currently planning promulgation
in 1979 of standards for the criteria and test procedures to be used in det&r-
mining whether or not solid waste is hazardous. Among the criteria are
flaniiiabi ii ty, corrosi vi ty, reactivity, radioactivity, toxicity and potential
for bioaccumulation, persistence, and causing disease. OSW will publish in
1979 a list of hazardous solid waste substances. In addition to the EPA
listing, the RCRA allows the Governor of any State to pe tition EPA to identify
or list additional substances. OSW will promultage in 1979 proposed nationally
applicable standards for generators, transporters, and owners and operators
of hazardous waste treatment, storage, and disposal facilities. Also in 1979
OSW will promulgate regulations for a Federal permit system applicable to
owners and operators of hazardous waste treatment, storage, or disposal sys-
tems. In addition, in 1980 05W will promulgate guidelines to assist the
States in the development of State hazardous waste programs.
State or regional plans for the management on nonhazardous wastes are
administered under Subtitle D of the RCRA. In 1979 OSW will publish guide-
lines for the identification of regions, guidelines for State plans, and
criteria for sanitary landfills.
Forthcoming regulations from OSW for hazardous waste handling, storage,
and disposal will set objectives for the protection of air, surface water, and
groundwater. These objectives will be attianed through EPA’s enforcement of
mandatory standards and procedures The objectives, standards, and procedures
will be specified in 40 CFR 250 when promulgated.
The media protection strategies being considered in OSW regulations are
as follows: Both new and existing waste treatment, storage and disposal
50
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facilities will be subject to essentially the same rules. Thus NPDES per-
mitted facilities, such as publicly or industrially owned wastewater treatment
plants, which handle hazardous wastes (determined by one or more of the
previously mentioned criteria) could be covered. The air protection strategy
would be to require compliance with all standards promulgated under the CAA
and to adopt, on an interim basis, other existing standards for substances
not yet regulated under the CAA, with such standards based primarily on
ACGIH/OSHA TLV’s. Surface water protection will be based on EPA ’s Quality
Criteria for Water , published under the FWPCA. Groundwater protection strategy
will be based on the maxim that a facility owner/operator cannot degrade the
groundwater on his property to such an extent that it will endanger ground-
water in usable (as defined in the regulations) aquifiers off his property.
The impact of these regulations on wastes from synthetic fuels plants
must be determined with IERL compares the published hazardous waste criteria
and standards to what is known from prior R&D activity about the nature of
such wastes.
4.2.4 Toxic Substances
The Toxic Substances Control Act (TSCA), P.L. 94-469, 71 Stat. 8501,
became effective on January 1, 1977. It imposes on EPA, through the Office
of Toxic Substances (OTS), many duties, including promulgating rules and
regulations, reviewing of premarket notifications and tests, regulation of
chemical substances and mixtures, compilation of lists of toxic (and possibly
hazardous) substances, and, through the enforcement branches of EPA, enforce-
ment of the Act.
The coverage of TSCA is extremely broad, covering over 70,000 substances
now manufactured for commercial purposes and an estimated 4 million more sub-
stances currently in various stages of research and development. Obviously,
a systematic approach must be implemented for identifying and sorting through
this huge population. EPA’s initial efforts will concentrate on testing (or
specifying tests to be carried out by substance generators) under Section 4
of TSCA and listing of those substances known or found by test to be toxic.
Manufacturers will be required under Section 8 of TSCA to notify EPA of toxic
substances they now produce or plan to produce (premarket notification).
51
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Priorities will be set by estimated risk potential; determined by two
principal factors: substance toxicity and estimated exposure. An initial
screening will determine whether (1) no further action is justified at the
time of consideration, (2) more information is needed, or (3) regulatory
control is required for the substance considered. In assessing toxicity,
cardiovascular, respiratory, immunological , derniatological , and reproductive
effects that are not reversible or are only slowly reversible and debilitating
will be considered. Among these are oncogenic, mutagenic, teratogenic, and
neurotoxic effects. Only generally accepted test methods that have predic-
tive value for these effects will be used.
The impact of TSCA on the substances generated by synfuels plants must
be determined by comparing IERL test data to the listing prepared by OTS.
Alternatively, IERL data may be used by OTS to augment its list of toxic
substances.
4.2.5 Radiation Program
There fs no single act which establishes the authority for EPA s
radiation abatement and control program. Under Reorganization Plan No. 3 of
1970, which established EPA, certain broad authorities were transferred to
EPA. These, together with authorities vested under other Federal acts but
applicable to the EPA radiation program, provide the legal basis for estab-
lishment and enforcement of regulations in the following areas:
1. Standards and Guidelines - Under Reorganization Plan No. 3 the
functions of the Federal Radiation Council were transferred to
EPA. EPA issues radiation protection guidance to all Federal
agencies. In addition, under the Atomic Energy Act of 1954,
EPA was transferred the function of the Atomic Energy Commission
to establish generally applicable environmental radiation pro-
tection.
2. Monitoring and Analysis — Under the Public Health Service Act,
(42 USC 241) Section 301, EPA has the authority to monitor
radiation levels in the environment.
3. State Assistance — The Public Health Service Act, (42 USC 243)
Section 311, provides the authority to assist States in radiation
control efforts; the Federal Radiation Guidance authorizes the
establishment of cooperative programs with States.
52
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4. Ocean Dumping - The Marine Protection Research and Sanctuaries
Act of 1972 provides EPA with the authority to control the
ocean disposal of radioactive wastes.
The general analysis method by which a particular regulatory approach is
considered is shown in Figure 7. From this diagram it can be seen that the
ORP can impose regulations through the mechanisms used in OAQPS, OWPS, and
Osw.
4.2.6 Noise Program
The Noise Control Act of 1972, P.L. 92-574, 86 Stat. 1234 as amended
by P.L. 94—301, 90 Stat. 590, May 31, 1976 directs EPA to identify products
which are major sources of noise and to establish noise emission standards as
necessary to protect public health and welfare, taking into account technology
and costs. The Act also empowers EPA to enforce these standards. As presently
written, the Act limits EPA’s jurisdiction to transportation sources (aircraft
and airports, railroads, and interstate motor carrier sources) and certain
manufactured products distributed in commerce. Consequently, it does not
appear that there will be any impact on synthetic fuels or coal-cleaning
technology operations.
4.3 EPA PLANS FOR REGULATORY ACTIVITIES/R&D NEEDS
Coal gasification and coal liquefaction technologies are still in the
“emerging technology” stage as far as the program offices are concerned.
There are very few plants in the U.S. The pace of R&D has not been rapid
in spite of ERDA/DOE’s efforts to interest private concerns. Private invest-
ment capital has not been attracted because these technologies are still
seen as economic risks.
As a consequence the pollution potential represented by such plants is
still seen by the EPA program offices as being realizable only well into the
future. There are many more pressing concerns now for the program offices,
and this is reflected in the relatively minor level of regulatory develop-
ment activity in these offices, whtch is summarized in this section.
53
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PROBLEM
ASSESSMENT
PREFERRED
REGULATORY
APPROACH
Figure 7.
Preferred Standards Path Analysis Flow Chart for Radiation Hazard
Evaluation and Regulation.
DECISION
PROCESS
01
EVALUATE RESULTS OF
IEH ADENCY ACTIVITIES
)INA1E ACTIVITIES WITH
hR AGENCIES SUCH AS
• DOE
• ORD
• EPHI
• OTHER A( LNCIES
-------
Also provided in this section are statements of OR&D’s perception of the
R&D needs of the respective program offices. The regulations promulgated by
the various program offices are based on extensive background research. The
pollutant limitations are firm numbers that are established based on health
effects, technological capability (for measurement and control of the pollu-
tants), economic, and energy considerations. The rationale for establishing
these limitations must be carefully documented. The data supporting the regu-
lations must be obtained by methods that are well defined, with the measure-
ments made in a manner that will stand up under objective scrutiny, frequently
in the process of litigation. Where control technologies are involved, it is
preferred that operational data come from demonstration units. Extrapolation
of performance to plant size from bench scale, or even pilot scale, facilities
may be tenuous and hard to support under adverse criticism.
R&D data supporting standards must be able to stand up not only under
traditional peer review but also under court review.
4.3.1 Office of Air Quality Planning and Standards
Under the Clean Air Act Amendments of 1977, the EPA Administrator has
been directed to review major pollutant emission sources-—i.e., those emitting
greater than 100 tons per year (TPY) of a given pollutant-—and develop a list
for which NSPS are to be established within four years. These sources are in
addition to those for which NSPS have already been set. The proposed list has
been published (Federal Register 43, August 31, 1978). Furthermore, the
recent Act directs a review and updating, if appropriate, of each NSPS every
four years. Since six NSPS were promulgated in 1971 and nine in March 1974,
this requirement, along with the new NSPS list, has imposed a major workload
on OAQPS. At present no synthetic fuels source can be considered a major
pollutant source; hence consideration of these sources has been postponed.
OAQPS has prepared a document which was originally intended to be an
NSPS for high—Btu gasification sources, specifying emission limitations for
sulfur and hydrocarbons. However, this document has been released as a
documentation of available controlmethods in order to provide guidelines for
EPA regional offices and State regulators. As of now, no definite EPA air
programs regulatory activity is scheduled for low- and medium-Btu gasification
or coal liquefaction sources.
55
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OAQPS prepares a ‘Standards Support and Environmental Impact Statement”
(SSEIS) document to back up its regulation activity. This document addresses
a specific source category——e.g., Lurgi high-Btu gasifiers. It reviews
1. The process and its emissions
2. Emission control techniques, including process modifications
or reconstructions and “add-on” control systems
3. Environmental impacts on air and water and those of solid
waste disposal
4. Energy impacts
5. Economic impacts.
The methods used in emissions measurement must be documented. Where EPA
reference methods are used, citation of the appropriate part of Appendix A,
40 CFR 60 is sufficient. Where these methods have been modified or new emis-
sions sampling and/or analysis methods used, these must be clearly defined
and discussed. OR&D input on appropriate continuous monitoring devices is
desired.
R&D Needs -- To support its preparation of the SSEIS documents and subsequent
guidelines and regulation development, OAQPS needs data and information in
three major areas: chemical analyses of airborne pollutants, physical analyses,
and available control technology. Under the heading of chemical analyses,
quantitative measurements of the criteria pollutants are needed for each source
type. In addition, identification and quantification of other potentially
harmful pollutants such as sulfur species, organics (e.g., POMs), trace ele-
ments, and radionuclides is desired.
Under the heading of physical measurements, quantification of stream
rates released to the atmosphere is necessary along with the aforementioned
chemical analyses to determine release rates for the various pollutants.
Particulate matter loadings and size distributions are also desired.
Under the heading of available control technology, data are needed on the
control effectiveness for normal and transient operation and operational
characteristics for existing (demonstrable) methods. The identification and
characterization with respect to rates and compositions, including pollutant
species, of liquid and/or solid waste streams resulting from operation of
these control processes is also necessary. In addition, the capital and
operating costs of control processes are needed in order to quantitate cost/
benefit comparisons of various control options.
56
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Although OAQPS cannot presently devote effort to considering the proper
regulatory approach and to developing regulations along the chosen path, it
could benefit from a joint planning effort which would specify the types of
data needed and the format desired. These inputs on source emission rates
and control technology would be useful in setting air quality criteria,
determining BACT in PSD classified areas, determining LAER in non-attainment
areas, in deciding whether or not an NSPS approach would be justified, or
whether the synfuels sources emit hazardous substances at rates that justify
establishment of NESHAPS regulation.
4.3.2 Office of Water Planning and Standards
With regard to water regulatory programs, there is at present no
activity with regard to synthetic fuels sources per se . Effluent guidelines
are being prepared establishing limitations on effluent from coal mines and
coal preparation facilities. These are scheduled to be proposed in December
1979 and promulgated in June 1980. As with the air programs, attention is
being given to items of much higher priority. In June 1976 a consent decree
settlement was reached between EPA and representatives of four environmental
advocacy groups which called for a sweeping review of a variety of chemical
substances that could possibly be discharged into navigable waters or public
water treatment works from a variety of industrial sources. Among other
requirements, some 124 chemical species were identified (Table 17) for which
EPA was directed to publish water quality criteria by June 30, 1978, giving
maximum permissible concentrations commensurate with the safeguarding of
human health and taking into account the effect on aquatic organisms. Regu-
lations applying to effluent discharges from 42 industrial point source
categories, none of which included coal gasification of liquefaction, are
required to be promulgated on a tight schedule commencing in September 1978
arid ending in December 1979. This workload has preempted most of the
resources of the Water Programs Office. Current plans call for the award of
a mission contract in March or April 1979 that will include a specific task
on synthetic fuels technology. Ho iever, this will probably not be activated
until late in 1979.
57
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R&D Needs -— In support of guidelines development OWP needs data and informa-
tion in three major areas: chemical analyses, physical analyses, and control
technology. Under the heading of chemical analyses, identification of the
presence of and subsequent qualification of concentrations for (if present)
the 129 priority pollutants is required as well as quantification of the
criteria pollutants, COD, BOD, pH, phosphorous, and grease/oils. In addition,
identification and quantification of other potentially harmful pollutants is
desired.
Under the heading of physical measurements, quantification of output
liquid streams is desired along with the TSS content. Under the heading of
available control technology data are needed on the control effectiveness for
normal and transient operation and operational characteristics for existing
(demonstrable) methods. The identification and characterization with respect
to rates and compositions, including pollutant species, of liquid and/or solid
waste streams resulting from operation of these control processes is also
necessary. In addition, the capital and operating costs of control processes
are needed in order to quantitate cost/benefit comparisons of various control
options.
Although OWPS has no definite plans to consider effluent guidelines for
synfuels sources, in the meantime, OR&D could be developing, through EAR docu-
ments and other special reports, data on effluents and control alternatives
which could aid OWPS in its decision as to the most suitable regulatory
approach, whether through NPDES permits, toxic and pretreatment effluent
standards, NSPS or effluent guidelines. In order to develop this information,
OR&D needs OWPS participation in planning the schedule and formats of desired
outputs.
4.3.3 Office of Solid Waste
With regard to solid waste, regulations pertaining to the criteria
for determining whether or not a waste is hazardous, methods for handling,
transportation, and disposal of hazardous and non—hazardous solid wastes are
being published and promulgated this year. The schedule for these regula-
tions is shown in Table 23. These regulations will, of course, apply to the
solid wastes generated by synthetic fuels plants. These wastes must be tested
and classified as either hazardous or non-hazardous and disposed of in accor-
dance with the applicable regulations.
58
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Guidelines for Solid Waste
Management
Hazardous Waste Criteria,
Testing and Listing
Toxic 1 1aste Screening Tests
Standards for Generators of
Hazardous Waste
Standards for Transporters
of Hazardous Waste
Facility Regulations
Permit Regulations
State Program Guidelines
Notification Regulation
Guidelines for Regional
Identification
Guidelines for State Plans
Criteria for Sanitary Landfills
Notification for Citizen Suits
*EPA schedule. Currently under litigation.
**Resource Conservation and Recovery Act of 1976.
TABLE 23. SCHEDULE FOR PROMULGATION OF REGULATIONS Oft WASTE MANAGEMENT*
Perti nent
Promul gati on
Topic Section Date
of RCRA**
1008 1/31/80
3001 12/31/79
3001
3002
12/31 / 79
12/3 1/7 9
3003 12/31/79
3004
3005
3006
3010
4002(a)
4002(b)
4004
7002
12/31/79
10/ 3 1/79
10/ 3 1/79
7
5/77
6 / 30j 79
7/ 3 1/79
10/7 7
59
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R&D Needs -- The OSW needs data and information in three major categories:
chemical analyses, biological analyses, and physical analyses. Under the
heading of chemical analyses, for those solid wastes or other waste streams
sent to land disposal sites, OSW needs identification of the presence of and
concentration quantification for pH, reactivity (explosion potential), radio-
nuclides, leachate species such as heavy metals (As, Cd, Pb, Se, Ba, Cr, Hg,
Ag), and toxic organics.
Under the heading of biological analyses, OSW needs quantification of
the mutagenicity, bioaccumulativity, and toxic organic (LD-50) potential for
leachate from solid wastes or waste streams sent to land disposal sites.
Under the heading of physical measurements OSW needs data on solid waste
or liquid stream rates to land disposal as well as data on flash point and
corrosion potential.
The broad scope of the hazardous waste classification criteria will
doubtless require the promulgation of regulations which apply to synthetic
fuels plants. Wastes (including “by-products and residuals, liquid or solid)
from these facilities must be classified using the standard criteria tests
promulgated by OSW. OR&D will need to support OSW in its development of air,
ground water, and surface water protection strategies and controls applicable
to specific locations and problems. In addition, OSW will need OR&D support
in its development of guidelines for owners/opex ators and for enforcement and
agencies at the local, State, and Federal levels.
4.3.4 Office of Toxic Substances
Regulatory activity under the Toxic Substances Control Act has cen-
tered on compiling data on the quantity and distribution of thousands of
chemical species from manufacturers in this country and the development of
tests to ascertain toxicity of substances. At present it appears that TSCA
will be applied to the synthetic fuels industry through the premarket notifi-
cation requi rement.
R&D Needs -- OTS will need information on toxicity and exposure potential of
pollutants in the product and by-p ’oduct streams of synfuels plants to guide
its regulatory efforts. Although OTS will rely on the other program offices
(OAQPS, OWPS, and OSW) to regulate waste streams and residuals, it will
probably serve in an advisory capacity to guide efforts of these offices
relative to toxic substances.
60
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4.3.5 Office of Radiation Programs
The ORP is currently conducting a measurement program to develop back-
ground data on Thorium radioactive emissions from coal piles, conventional
combustion sources and their related ash piles to support OAQPS in their
decisions concerning setting NAAQPS for radioactive materials by August 1979,
as required by the Clean Air Act Amendments of 1977.
In addition, ORP is providing support to OSW, looking at radionuclides
in coal wastes from coal preparation and cleaning to determine whether or not
these should be handled as hazardous wastes under the RCRA.
Based upon what is found in this measurement program, the ORP may turn
its attendion to synthetic fuels technologies in FY 1980.
R&D Needs -- Because of the expertise required to accurately quantitate
radioactive emissions from various sample forms, ORP prefers to perform such
measurements in-house. However, it does need representative samples from
various process feed and waste streams that can be obtained by EA contractors.
Test plans for OR&D field projects should include provision to acquire such
samples and coordination with ORP to have these assayed. These data, along
with information on particulate loadings in gas streams and flow rates for
liquid and solid wastes, enable quantification of degree of hazard.
4.3.6 Office of Noise Abatement and Control
There is no current or projected activity in this office which could
be expected to impact synthetic fuels plants.
R&D Needs - Although ONAC does not currently have a legal mandate which
allows development of regulations for synfuels sources, the trends in environ-
mental, safety, and health protection legislation may eventually provide this
mission. Alternatively, certain states might opt to pass controlling legis-
lation but may rely on Federal agency data to establish the need and methods
of monitoring and enforcement. With ONAC guidance, OR&D could include noise
monitoring in its data base EAR Efforts.
4.3.7 Office of Enforcement
The Office of General Enforcement, Stationary Source Enforcement
Division provides support to the EPA regional offices and State environmental
61
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regulators as needed to maintain and enforce regulations and provisions of
the Clean Air Act. Since permits for synthetic fuels plants would be issued
through joint State and regional office actions, SSED would probably be
involved only in an advisory capacity.
The Office of Water Enforcement, Enforcement Division enforces compli-
ance with water quality standards and effluents limitations. The Permits
Division works with States authorized to issue discharge permits in an
advisory capacity and for those States not so authorized (20 and of 50) , has
the responsibility of application review and permit issuance. Since these
permits are issued on a case—by—case basis, there are no plans or schedules
for synthetic fuels plants.
R&D Needs -- Both the Office of Enforcement and the regional offices need
reliable information on pollutant emission rates and control methods to aid
in their guidance for permitting and monitoring stationary sources. Although
synthetic fuels plants may eventually be regulated by an NSPS approach for
air and surface water protection, the initial development of the industry
will probably be under an individual permitting basis. The determination
of appropriate control guidance for regulated (and unregulated) pollutants
as toxic and hazardous pollutant, or waste characterization, will require
that data be on hand if the permitting process is not to introduce intoler-
able delays in plant construction and start-up. Planning input now by the
enforcement and regional offices would help to assure the availability of
this information when needed.
4.3.8 Relationships to Other Regulatory Activities
4.3.8.1 Introduction
In addition to EPA, there are other regulatory agencies whose
activities may affect, directly or indirectly, the cost, location, operation,
and/or maintenance of a synthetic fuels plant. Workers inside the plant are
under the jurisdiction of the Occupational Safety and Health Administration
(OSHA). Workers involved in mining the coal are covered by the Mine Safety
and Health Administration (MSHA, formerly MESA). Mining activities on the
surface and their impact on the environment are under the jurisdiction of
62
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the Office of Surface Mining Reclamation and Enforcement in the Department
of the Interior. The activities of these agencies relative to synthetic
fuels plants are discussed in the following sections.
4.3.8.2 Occupational Safety and Health Administration (OSHA )
Currently OSHA has not promulgated any standards and regulations
that deal specifically with synthetic fuels plants. However, many of the
Administration’s existing standards and regulations do apply, particularly
those dealing with physical hazards and chemical hazards.
In order for a plant to meet existing OSHA standards and regulations,
engineering controls may be required for various processes. Such controls
may affect not only the levels of substances in the occupational environment
but also may increase or decrease the amount of substances released via air,
water, or solid residuals. Consequently, the impact of existing, proposed,
or completely new OSHA standards on EPA-mandated control technologies must
always be considered.
As the extent, nature, and timing of the commercialization of synthetic
fuels plants become clearer, it is expected that OSHA will either utilize
existing standards and regulations or develop new ones to regulate the new
industry.
The National Institute of Occupational Safety and Health (NIOSH), which
advises OSHA on the need and scientific basis for new or revised standards,
is currently developing a criteria document for recommended standards for
occupational exposures in coal gasification plants. In addition, NIOSH has
published recommended industrial hygiene practices for coal gasification
plants and is also participating in the Interagency Energy/Environmental R&D
Program.
4.3.8.3 Mine Safety and Health Administration (MSHA )
MSHA is responsible for the health and safety of all miners, both
surface and underground. Though not directly affecting most synthetic fuels
plants, MSHA regulations for coal ruining will influence the cost and type of
coals available as feedstock.
63
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In addition, MSHA has jurisdiction over any coal gasification, liquefac-
tion, or other coal processing facilities that are directly and physically
connected to a mine——e.g., via a comon haulage system. Thus certain gasi-
fication or liquefaction plants may be under the jurisdiction of MSHA, rather
than OSHA, for occupational safety and health standards and regulations.
4.3.8.4 Office of Surface Mining Reclamation and Enforcement
This Office was created by the Surface Mining Control and Reclamation
Act of 1977 primarily to oversee reclamation of mined lands. Regulations
promulgated by it will influence how, when, and where solid residuals from
synthetic fuels plants can be disposed of, if those plants are integrally
located at or near the mine itself.
If the plant is located away from the mine, regulations of the Office
of Surface Mining Reclamation and Enforcement do not apply. They will only
impact synthetic fuels plants indirectly to the extent that coal prices are
increased by the costs of compliance with reclamation and disposal practices.
4.3.8.5 State and Local Regulations
For each synthetic fuels plant site, there may be a variety of
state and local regulations that will affect plant siting, design, and opera-
tions. The cost and mode of compliance with these regulations will impact on
the regulations within EPA’s purview. The primary areas potentially impacted
by these regulations are land use and taxation.
The Department of Energy estimates that for a unit synthetic fuels plant
producing 250 million standard cubic feet (SCF) per day, approximately 400 to
900 acres of land will be required for the plant plus 15 to 50 acres per year
for residual disposal. 1 Consequently, the siting of any such facility on a
commercial basis will have continuing impacts on the land use within a com-
munity or region. Local or state regulations, ordinances, or laws that may
be used to control the land use impacts of a plant include (1) zoning require-
ments; (2) land use management plans; (3) areawide wastewater management plans
(Section 208 of P.L. 92-500); (4) ity, county, or regional master plans;
(5) “701” comprehensive plans financed by the Department of Housing and Urban
Development (HUD); and (6) any conservation or water district requirements or
plans.
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The question of how a community, county, or state will tax a synthetic
fuels plant and its product is not resolved. The mode of taxation, if any,
may impact the ways in which a plant can meet EPA regulatory requirements.
Because there are no commercial plants currently operating in the United
States, there are no precedents for such actions. Each plant site will have
to be considered separately. Questions that may arise include
Will the product gas or liquid be taxed? If yes, on what
basis——e.g., Btu, SCF, or pounds?
How will the residual disposal areas be taxed? Is the value
of the area (or adjacent lands) reduced by the residuals?
If any product is stored on site, will it be subject to an
inventory tax, if applicable?
Will local government pollution control bonds be used to help
finance portions of the plant that control emissions?
4.4 EPA RESEARCH AND DEVELOPMENT ACTIVITIES
Recent and current research and development activities of EPA have
focused on the current process technology background, control technology
assessments, and environmental data acquisition for synthetic fuels tech-
nologies. Table 24 gives a list of current projects, contractors, and
project offices in the synthetic fuels technology environmental assessment
program.
4.4.1 Current Process Technology Background
For an adequate understanding of the potential environmental impacts
of various synthetic fuels processes, it is necessary to compile and keep
current detailed information on the various process designs. This has been
done for low/medium—Btu gasification, high—Btu gasification, and liquefac-
tion as follows.
Low/Medium-Btu Gasification . A library of approximately 10,000 cita-
tions and 3,500 full—text documents is being maintained at the Radian
Corporation under OR&D sponsorship: Radian has also recently published a
two-volume document, uEnvironmental Assessment Data Base for Low/Mediuni-Btu
Gasification Technology 1 ’ (EPA—600/7-77-125 a and b, October 1977), which
65
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TABLE 24. PROJECT TITLES, CONTRACTORS, AND EPA PROJECT OFFICERS
IN OR&D ENVIRONMENTAL ASSESSMENT PROGRAM
Project Title Contractor EPA Project Officer
Environmental Assessment of
Low/Medi um—Btu Gasification
(March 1976—March 1979)
Radian Corporation
William J.
IERL-RTP
Rhodes
Environmental Assessment of
High-Btu Gasification
(April 1977—April 1980)
TRW, Inc.
William J. Rhodes
Environmental Assessment of
Coal Liquefaction
(August 1976—August 1979)
Control Technology for
Products/By-Products
(Sept. 1976—Sept. 1979)
Hittman Associates
Catalytic, Inc.
William J.
Rhodes
WilliamJ. Rhodes
Control Technology for
Converter Output
(January 1977-January 1980)
Hydrocarbon Research,
Inc.
William 3. Rhodes
Waste Stream Disposal and
Utilization
(April 1977-April 1980)
Pullman-Kellogg
Research and Develop-
ment Center
William 3. Rhodes
Acid Gas Cleaning Bench
Scale Unit
(Oct. 1976—Sept. 1981)
(Grant)
North Carolina State
University, Department
of Chemical Engineering
N. Dean Smith
IERL-RTP
Water Treating Bench
Scale Unit
(Nov. 1976—Oct. 1981)
(Grant)
University of North,
Department of Environ-
mental Sciences and
Engineering
N. Dean Smith
Pollutant Identification
from a Bench Scale Unit
(Nov. 1976—Oct. 1981)
(Grant)
Research Triangle
Insti tute
N. Dean Smith
66
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contains (1) process descriptions; (2) process constraints imposed by product
gas end uses; (3) air, water, and solid waste streams generated by the vari-
ous processes; and (4) the pollution control techniques which appear
applicable to these waste streams. In addition, Radian has recently published
uIn Situ Coal Gasification Status of Technology and Environmental Impact
(EPA-600/7-77-045). This includes process descriptions and problem assess-
ments and sun arizes activities of several U.S. and foreign in-situ projects.
Other documents on low- and medium—Btu gasification are listed in Table 25.
High—Btu Gasification . TRW has prepared technology overview reports
covering HYGAS, BI-GAS, CoGAS, Hydrane, Synthane, Texaco, C0 2 -Acceptor,
Self-Agglomerating Ash, and Lurgi systems. These are listed in Table 26.
Liquefaction . Hittman has compiled information of 14 liquefaction
processes, which has been summarized in the report “Environmental Assessment
Data Base for Coal Liquefaction Technology (EPA-600/7-78-184a). Of these,
four processes were selected for more thorough study based on the criteria
stage of development, potential hazard for residual emissions, and energy
efficiency. These are the Solvent Refined Coal (SRC), H-Coal, Exxon Donor
Solvent, and Synthoil processes, which are discussed in Volume 2 of the
report (EPA—600—7—78—184b). These and other current reports on liquefaction
are listed in Table 27.
4.4.2 Control Technology Assessment
In addition to process design information, it is essential that the
waste streams from and pollution control technology for these processes be
evaluated to determine whether or not adequate control for environmental
protection already exists or must be developed. Highlights in this assess-
ment are as follows.
Control Technology Overview . Catalytic, Inc., is reviewing those tech-
nologies being considered for product and by-product streams from a variety
of coal conversion processes to determine data gaps and R&D needs. Hydrocarbon
Research, Inc. (HRI) is concentrating on the state—of-the-art for control of
industrial gasifier waste streams. -
Control Engineering Handbook . This has been compiled by Cameron Engi-
neers (EPA—600/7-78—187). It catalogs commercially available control units,
67
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TABLE 25. RECENT REPORTS ON LOW/MEDIUM—BTU GASIFICATION
Report Number Date Title
EPA-600/7-77-045 May 1977 In—Situ Coal Gasification: Status
of Technology and Environmental
Impact
EPA—6OO/7—77-1 25a November 1977 Environmental Assessment Data Base
for Low/Medium-Btu Gasification
Technology: Volume 1. Technical
Discussion
EPA-600/7-77—125b November 1977 Environmental Assessment Data Base
for Low/Medium-Btu Gasification
Technology: Volume II. Appendices
A- F
EPA-600/7-77-141 December 1977 Analyses of Grab Samples from Fixed
Bed Coal Gasification Processes
EPA-600/7-77-142 December 1977 Environmental Assessment of Low!
Medium-Btu Gasification: Annual
Report
EPA—600/7-78-061 March 1978 Low and Medium Btu Gasification
Systems: Technology Overview
EPA-600/7-78-088 June 1978 Fuel Gas Environmental Impact:
Final Report
EPA—600/7-78-202 October 1978 Environmental Assessment: Source
Test and Evaluation Report--Chapman
Low-Btu Gasi fi cation
68
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TABLE 26. RECENT REPORTS ON HIGH-BTU GASIFICATION
Report Number
Date
Title
EPA-600/7- 78-025
February
1978
Envi ronmental Assessment of Hi gh-Btu
Gasification: Annual Report
EPA-600/7--78-186a
September
1978
Environmental Assessment Data Base
for High-Btu Gasification Technology:
Volume I. Technical Discussion
EPA-600/7-78-186b
September
1978
Environmental Assessment Data Base
for High-Btu Gasification Technology:
Volume II. Appendices A, B, and C
EPA-600/7-78-186c
September
1978
Environmental Assessment Data Base
for High-Btu Gasification Technology:
Volume III. Appendices D, E, and F
69
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TABLE 27. RECENT REPORTS ON COAL LIQUEFACTION TECHNOLOGY
Report Number Date Title
EPA—600/7—78—O19 February 1978 Environmental Assessment of Coal
Liquefaction: Annual Report
EPA-600/7-78-091 June 1978 Standards of Practice Manual for
Solvent Refined Coal Liquefaction
EPA-600/7—78-129 July 1978 Evaluation of Electrostatic Precipi-
tator During SRC Combustion Tests
EPA-600/7-78-159 August 1978 Catalyst Evaluation for Denitrogena-
tion of Petroleum Residual and Coal
Liquids
EPA —600/7—78—184a September 1978 Environmental Assessment Data Base
for Coal Liquefaction Technology:
Volume I. Systems for 14 Liquefac-
tion Processes
EPA—600/7-78-184b Sepbernber 1978 Environmental Assessment Data Base
for Coal Liquefaction Technology:
Volume II. Synthoil, H-Coal, and
Exxon Donor Solvent Processes
EPA—600/7—78—185 September 1978 Analysis for Radionuclides in SRC
and Coal Combustion Samples
EPA-600/7-78-203 October 1978 Air Quality Impacts Using SRC Versus
Conventional Coal in Power Plants
EPA—600/7-78-223a November 1978 SRC Site-Specific Pollutant Evalua-
tion: Volume 1. Discussion
EPA—600/7—78—223b November 1978 SRC Site—Specific Pollutant Evalua-
tion: Volume 2. Appendices
70
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provides technical and economic data for these, and provides a list of sup-
pliers or licensors of the various units.
Acid Gas Removal Processes . HRI has reviewed a group of 16 acid gas
removal processes to establish a priority list of six for detailed evaluation,
considering their application on high pressure (1000 psig) gasification for
SNG manufacture, medium pressure (400 psig) gasification for turbine fuel
manufacture, low pressure gasification for either fuel gas or synthesis gas.
A bench—scale acid gas cleaning unit has recently been installed and
started up at North Carolina State University. The gasifier is a fluidized
bed with a throughput of up to 50 lbs/hour of coal. Following a raw gas
cleaning system (cyclone and two scrubbers in cascade) is an absorption unit
and stripper column. The absorption unit operates over a temperature range
from -30°F to 300°F and a pressure range from atmospheric to 1000 psi to
allow operations to match existing commercial removal techniques.
Water Treatment . A bench-scale unit for evaluating various water treat-
ment control methods is in operation at the University of North Carolina. In
this work the biodegradability and the physical/chemical treatability of
selected organic constituents in wastewater from synthetic fuels production
from coal are being studied. Animal toxicological studies are being used to
evaluate the potential health impacts of treated and untreated wastewater
constituents. Alternative treatment technologies are being evaluated to
develop design criteria for continuous treatment of synthetic fuels process
was tewaters.
A list of current reports dealing with various aspects of pollution
control methods for synthetic fuels technologies is given in Table 28.
4.4.3 Environmental Data Acquisition
Early assessments of synthetic fuels technologies have revealed that
more extensive and precise information on pollutant species and concentra-
tions must be obtained. Programs with this objective are as follows.
Low/Medium-Btu Gasification . The Radian Corporation has prepared a
document, 11 Guidelines for Preparing Environmental Test Plans for Coal
Gasification Facilities (EPA-600/7-78—134), and is gathering data from
facilities at the Holston Army Ammunition Plant (Tennessee), Kosovo Kombinat
71
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TABLE 28. RECENT REPORTS ON ENVIRONMENTAL CONTROL TECHNIQUES
FOR GASIFICATION AND LIQUEFACTION TECHNOLOGIES
Report Number
Date
Title
EPA-600-7-78-190
October 1978
Applicability of Petroleum Refinery
Control Technologies to Coal Con-
version
EPA-600/7-78-171
August 1978
Pollutants from Synthetic Fuels
Production: Facility Construction
and Preliminary Tests
EPA-600/7-78-181
September 1978
Assessment of Coal Conversion Waste-
waters: Characterization and
Preliminary Biotreatability
EPA-600/7-78-187
September 1978
Multimedia Environmental Control
Engineering Handbook: Methodology
and Sample Summary Sheets
EPA-600/7-78-197a
October 1978
Water-Related Environmental Effects
in Fuel Conversion: Volume I.
Summary
EPA-600/7-78-197b
October 1978
Water-Related Environmental Effects
in Fuel Conversion: Volume II.
Appendi ces
72
-------
(Yugoslavia), Glen Gery Brick Co. (Pennsylvania), and the University of
Minnesota. These will include Lurgi, Weliman—Galusha, and Foster Wheeler!
Stoic gasifier processes. During visits to several potential test sites,
Radian obtained grab samples of selected liquid and solid discharge streams.
Analysis results for these are summarized in “Analyses of Grab Samples from
Fixed-Bed Coal Gasification Processes” (EPA-600/7--77-141). Data from the
Chapman gasifier has been published in “Environmental Assessment: Source
Test and Evaluation Report—-Chapman Low—Btu Gasification” (EPA-600/7-78-202).
High-Btu Gasification . TRW will collect data from a Koppers process
(South Africa). Plans to obtain data from the HI-GAS and SYNTHANE processes
have been postponed due to changes in the DOE schedule. Data from the C0 2 -
Acceptor process (North Dakota) will be made available by DOE, but this plant
has been shut down, eliminating the possibility of getting additional data.
Liquefaction . Hittman has collected data from a test burn of SRC in a
commercial utility plant in Georgia and has prepared a test plan, in coopera-
tion with DOE, for gathering data at an SRC plant in Ft. Lewis, Washington.
Laboratory Gasifier . The Research Triangle Institute is performing a
parametric evaluation of pollutants from a laboratory gasifier. Parameters
investigated include coal type, grind size, pretreatment, bed depth, tempera-
ture, pressure, stream flow rates, residence time, catalysts, and additives.
The general methodology applied in the environmental assessment of syn-
thetic fuels sources is shown in Figure 8. On this diagram ‘PDOH” signifies
Potential Degree of Hazard, and “PTUDR” signifies Potential Toxic Unit Dis-
charge Rate. The PDOH for a given pollutant species is the ratio of the
measured pollutant concentration to the minimum acute toxic concentration
determined from MEG values. The PTUDR is obtained by multiplying PROH by
the respective stream flow rate.
73
-------
Gas, Unstable or
Screening Sample
Organic On-Site
(TOO, R V, IR) Analyses
P/:ULJ
(Priority (Criteria
Poliutants) Pollutants)
ORP (Particle
E nissions and
Size Dis-
Thminate AEG
Comoounds PDOH15 rng
rng
Eii inate MEG
Compounds ?DCH<1
4
Calculate
Max. POONs
Stabilized Stat szicaily
Representative Samole
Stabilized
Statistically
Representative
Sample
OWP/ EGO
(Priority Pollu-
tants)
OTS (Toxic Sub-
stances)
PRIORITIZE STREAMS — — —
Cutout
Detailed lest
Plan
Long—Terni
Monitoring
On Site
Figure 8.
Analysis Methodology for Characterizing Streams
from Synthetic Fuels Sources.
Inor ni c
(SSMS, C TICN,
:Sw
(RCRA)
Fracti onate
(TCO, RAV,
IR, LRMS)
Si cass ay
.AMES, RAT,
Cytotoxi city
OTS
(Health
Effects)
OSW
(RCRA)
Calculate Calculate
?DCHs PDOHs
+
PRIORITIZE COI1POUNDS
V
Calculate PTUDR
Output PRIORITIZE STREAtiS
*
Detailed Characterization Test Plan
Addi ticnai
SamQling
Organic
(GC/Ms, etc.)
POOH S
Inorganic
(AA, etc.)
Bioassay
OTS
(Health
Effects)
POOH’s
PRIORITIZE COMPCLNCS — — — — ,
PTUDR ’ s
74
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APPENDICES
75
-------
APPENDIX A
REFERENCES FOR FURTHER DETAIL ON TECHNOLOGIES
The references listed below provide additional information on synthetic
fuels technologies to supplement that available in the EA reports listed in
Tables 19-22.
1. Energy Research and Development Administration (Now DOE), Alternative
Fuels Demonstration Program , Final Environmental Impact Statement
ERDA—1547, Volumes 1 and 2, NTIS, Springfield, Virginia, September
1977.
2. H. M. Braunstein, E. D. Copenhaver, and H. A. Pfuderee, Editors,
Environmental, Health, and Control Aspects of Coal Conversion: An
Information Overview , Volume 1, Prepared for Energy Research and
Development Administration (Now DOE) by Information Center Complex,
Information Division, Oak Ridge National Laboratory, Oak Ridge,
Tennessee, April 1977.
3. Office of Energy, Minerals, and Industry, Advanced Fossil Fuel and
the Environment: An Executive Report , EPA Report No. 600/9—77—013,
U.S. Environmental Protection Agency, Office of Research and Develop-
ment, NTIS, Springfield, Virginia, June 1977.
4. Energy Alternatives: A Comparative Analysis , Prepared for CEQ,
et al. , by The Science and Public Policy Program, Normal, Oklahoma,
U.S. Government Printing Office, Washington, D.C., May 1975.
5. Oak Ridge National Laboratory, Balanced Program Plan, Volume 4:
Coal Conversion , ERDA 76—116, Division of Biomedical and Environ-
mental Research, Energy Research and Development Administration,
NTIS, Springfield, Virginia, May 1976.
6. Energy Research and Development Administration, Coal Research,
Development and Demonstration Program, Draft Environmental Impact
Statement , ERDA-1557-D, Washington, D.C., September 1977.
7. F. A. Ayer and M. F. Massoglia, Editors, Symposium Proceedings:
Environmental Aspects of Fuel Conversion Technology, III , EPA
Report No. EPA-600/7-78-063, U.S. Environmental Protection Agency,
Office of Research and Development, NTIS, Springfield, Virginia,
April 1978.
76
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OR&D, IERL RTP Energy
Assessment and Control
Division
Office of Air Quality
Planning and Standards,
Emission Standards and
Engineering Division
Office of Water Planning
and Standards, Effluent
Guidelines Division
Office of Water Supply,
State Programs Division
Office of
Solid
Waste,
Hazardous
Waste
Management
Division
Office of Toxic Substances,
Office of Testing and
Evaluation Assessment
Division
R. P. Hangebrauck
MD-61
629-2825
D. R. Goodwin
MD- 13
629-5271
R. B. Schaffer
WH-552
426-2576
A. Levin
WH-550
426-8290
3. D. Lehman
AW-465
755-9185
W. Muir, DAA
OlE
755-4894
T. K. Janes, Fuel
Process, MD-61
629-2851
S. T. Cuffe, Indus-
trial Studies
MD-13
629-5295
J. R. Farmer,
Standards Develop-
ment, MD-13
629-5477
W. Telliard, Energy
and Mining, WH-552
426-2726
T. Belk, Groundwater
Protection, WH-550
426-3934
W. W. Kovalick,
Guidelines, AW-465
755-9187
F. Kover, Dir.
Assessment, TS-792
755-2110
W. 3. Rhodes
MD-61
629-2851
C. B. Sedman
MD-13
629-5301
G. W. Smith
MD-13
629-5421
3. Lum
WH-552
426-4617
W. E. Bye
WH-550
426-3934
A. Corson
AW-465
755-9187
R. Kuchkuda
TS-792
755—2112
Unit Division Branch Project
-Q
-o
rn
CD
rn
x,.
CD
r n
rn-a
—I
>-o
i-rn
v ’c
(J )
rn
u-rn
(t,r
rn’-’
CD
I-
Lfl-<
-I
rn
CD-I
m c )
rn-n
(Dc
arn
C-)’-
rn(J)
rn—I
rn
-HC)
CD
I-
CD
GD
-------
Unit Division Branch Project
Office of Radiation Pro- F. Galpin P. Magno C. G. Ainato
grams, Environmental AW-461 Surveillance, ANR-461 ANR-461
Analysis Division 557-8217 557-8320 557-7930
Criteria and Standards Dr. W. A. Mills J. E. Fitzgerald
Division AW460 AW460
557-0704 557-8224
Office of Noise Abatement H. E. Thomas K. E. Feith, Gen.
and Control, Standards and AW-471 Products, AW-471
Regulation Division 557-7743 557-2710
Office of General Enforce- E. Reich Dr. F. J. Biros,
ment, Stationary Source EN-341 Tech. Support, EN-341
Enforcement Division 755-2550 755-2560
Office of Water Enforce- L. A. Miller J. W. Jordan, md.
inent, Permits Division EN-336 Permits, EN-336
755-2545 472-3665
-------
APPENDIX C
EXAMPLE POLLUTION CONTROL GUIDANCE DOCUMENT OUTLINE
(For a Specific Technology)
1
1
2
5
6
10
• . 15
• 15
• 16
16
• . . 18
• . . 18
18
23
IV. LOW-BTU SOURCES AND POLLUTANTS
Coal Preparation Operation
Gasification Operation
Gas Purification Operation
Noise Derived from Low-Btu Operations
V. ENVIRONMENTAL EFFECTS OF KNOWN POLLUTANTS
General
Water Pollutants
Air Pollutants
Noise Pollution
Land-Disposed Wastes
Radiation
VI. POLLUTION CONTROL TECHNOLOGY
Air Pollution
Water Pollution . .
Pollution by Solid Waste
Noise
VII. SUGGESTED POLLUTANT DISCHARGE LIMITS • . . 102
General . . . 102
Air Pollutant Limitations . . . • . . 102
Water Pollutant Limitations . . . . . 105
Land-Disposed Waste Limitations . . . 108
Noise Limitations • . . 109
VIII. FUTURE DEVELOPMENT OF EFFLUENT AND EMISSION STANDARDS . . 110
I. SUMMARY AND CONCLUSIONS
Perspective
EPA Regulatory Approach
Low—Btu Sources and Pollutants
Environmental Effects of Known Pollutants
Pollution Control Technology
II. RECOMMENDATIONS
Suggested Pollutant Limitations
Monitoring
Control Technology and Regulatory Development Needs
III. INTRODUCTION
Objectives
Background
EPA Pollution Control Regulatory Approach for
Low-Btu Sources
29
29
33
36
39
43
43
45
54
57
58
58
60
60
71
99
99
79
-------
• 110
• 114
• 116
• 117
• 119
• 121
.121.
• 122
REFERENCES CITED . . . . . . 123
APPENDIX - Summary of Laws Requiring or Related to
Pollution Control for Low—Btu Sources 128
80
IX. EFFLUENT AND EMISSION MONITORING
Air and Water Point Source Monitoring
Ambient Air Monitoring
Ambient Water Monitoring
Ground Water Monitoring
Land-Disposed Wastes
Noise Monitoring
Baseline Air and Water Monitoring .
-------
APPENDIX 0
EXAMPLE ENVIRONMENTAL ASSESSMENT REPORT* OUTLINE
LURGI SYSTEMS
FOR
PRODUCING LOW- AND MEDIUM-BTU GAS FROM COAL
Abstract
List of Figures
List of Tables
Nomencl ature
1.0 SUMMARY
1.1 Overview of Lurgi Gasification Systems
1.2 Waste Streams and Pollutants of Major Concern
1.3 Status of Environmental Protection Alternatives
1.4 Data Needs, Recommendations, and Suggested Pollutant Discharge Limits
1.5 Issues and Areas of Concern by Program Offices
2.0 PROCESS DESCRIPTION OF LURGI GASIFICATION SYSTEMS
2.1 Technical Overview of Lurgi Systems
2.1.1 Status of Development
2.1.2 Industrial Applicability of Lurgi Systems
2.1.3 Input Materials, Products, and Byproducts
2.1.4 Energy Efficiencies
2.1.5 Capital and Operating Costs
2.1.6 Commercial Prospects (Projected National Capacity, Locations,
and Size)
2.2 Description of Processes
2.2.1 Generalized Process Flow Diagram
2.2.2 Coal Pretreatment
2.2.3 Coal Gasification
2.2.4 Gas Purification
2.2.5 Auxiliary Processes
2.3 Process Areas of Current Environmental Concern
2.3.1 Coal Pretreatment
2.3.2 Coal Gasification
2.3.3 Gas Purification -
2.3.4 Auxiliary Processes
*
These reports will be prepared for selected energy systems and updated to
reflect significant changes in status of development or knowledge of environ-
mental impacts. Lurgi low— and medium-Btu systems have been used as an
example to illustrate the general outline of EA reports.
81
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3.0 CHARACTERIZATION OF INPUT MATERIALS, PRODUCTS, AND WASTE STREAMS
3.1 Summary of Sampling and Analytical Activities
3.1.1 IERL/RTP Environmental Assessment Activities
3.1.2 Non-IERL/RTP Site Evaluations
3.2 Input Materials
3.2.1 Coal Pretreatment and Handling
3.2.2 Coal Gasification
3.2.3 Gas Purification
3.2.4 Auxiliary Processes
3.3 Process Streams
(same format as section 3.2)
3.4 Toxic Substances in Products and Byproducts
(same format as section 3.2)
3.5 Waste Streams to Air
(same format as section 3.2)
3.6 Waste Streams to Water
(same format as section 3.2)
3.7 Waste Streams to Disposal Sites
(same format as section 3.2)
4.0 PERFORMANCE AND COST OF CONTROL ALTERNATIVES
4.1 Procedures for Evaluating Control Alternatives
4.2 Air Emissions Control Alternatives
4.2.1 Coal Pretreatment and Handling
4.2.2 Coal Gasification
4.2.3 Gas Purification
4.2.4 Auxiliary Processes
4.3 Water Effluent Control Alternatives
(same format as section 4.2)
4.4 Solid Waste Control Alternatives
(same format as section 4.2)
4.5 Toxic Substances Control Alternatives
82
-------
4.7
4.8
4.9
5.0 ANAL
5.1
4.6 Summary of Most Effective Control Alternatives
4.6.1 For Emissions Control
4.6.2 For Effluents Control
4.6.3 For Solid Wastes Control
4.6.4 For Toxic Substances Control
Multimedia Control Systems
Regional Considerations Affecting Selection of Alternatives
Summary of Cost and Energy Considerations
YSIS OF REGULATORY REQUIREMENTS AND ENVIRONMENTAL IMPACTS
Environmental Impact Methodologies
5.1.1 Multimedia Environmental Goals
5.1.2 Source Analysis Models
5.1.3 Bioassay Interpretations
5.2 Impacts on Air
5.2.1 Summary of Air Standards and Guidelines
5.2.2 Comparisons of Waste Streams with Emissions Standards
5.2.3 Impacts on Ambient Air Quality
5.2.4 Evaluation of Unregulated Pollutants and Bioassay Results
5.3 Impacts on Water
5.3.1 Summary of Water Standards
5.3.2 Comparisons of Waste Streams with Effluent Standards
5.3.3 Impacts on Ambient Water Quality
5.3.4 Evaluation of Unregulated Pollutants and Bioassay Results
5.4 Impacts of Land Disposal
5.4.1 Summary of Land Disposal Standards
5.4.2 Comparisons of Waste Streams with Disposal Standards
5.4.3 Evaluation of Unregulated Pollutants and Bioassay Results
5.5 Product Impacts
5.5.1 Summary of Toxic Substances Standards
5.5.2 Comparisons of Product Characterization Data with Toxic
Substances Standards
5.5.3 Evaluation of Unregulated Toxic Substances and Bioassay
Results
5.6 Radiation and Noise Impacts
83
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5.7 Summary of Major Environmental Impacts
5.7.1 Air Impacts
5.7.2 Water Impacts
5.7.3 Impacts of Solid Wastes
5.7.4 Impacts of Toxic Substances
5.7.5 Other Impacts (Noise, Radiation, Land Use)
5.8 Siting Considerations for Gasification Plants
6.0 SUMMARY OF NEEDS FOR ADDITIONAL DATA
6.1
Data Needs
6.1.1 To Support Standards Development and Enforcement
6.1.2 To Support Effects and Control Technology R&D
6.2 Data Acquisition by Ongoing Environmental Assessment Activities
RE FERENCES
APPENDICES
A Glossary of Environmental Assessment Terms
B Etc.-—Other Appendices as Appropriate
84
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APPENDIX E
EXAMPLE OUTLINE FOR ENVIRONMENTAL ASSESSMENT SOURCE TEST
AND EVALUATION REPORT
Abstract
Figures
Tables
Acknowledgements
11
v iii
x
xiv
INTRODUCTION
1.1 PROGRAM SUMMARY
1.2 CONCLUSIONS
1.3 RESULTS OF THE SOURCE TEST
1.4 RECOMMENDATIONS
PLANT DESCRIPTION
2.1 PROCESS DESCRIPTION
2.2 PLANT OPERATION
2.3 PROCESS FLOW RATE AND MASS BALANCE
SAMPLING METHODOLOGY
3.1 DESCRIPTION OF SAMPLING POINTS
3.2 SAMPLING METHODOLOGY
ANALYTICAL PROCEDURES
4.1 INORGANIC SPECIES ANALYSIS .
4.2 ORGANIC SPECIES ANALYSIS
4.3 BIOASSAY ANALYSIS
TEST RESULTS
5.1 METHODOLOGIES
5.2 RESULTS
CONCLUSIONS AND RECOMMENDATIONS .
6.1 WASTE AND PROCESS STREAMS .
6.2 LEVEL 1 METHODOLOGY
1
1
8
15
31
• . • 39
39
• . . 45
45
• . . 49
• . . 49
54
72
80
96
• • . 104
• • . 110
110
• . . 112
153
153
161
REFERENCES 168
APPENDIX - BIOASSAY, INFRARED SPECTROPHOTOMETRY, LIQUID
CHROMATOGRAPHY AND LOW RESOLUTION MASS SPEC-
TROMETRY DATA FOR A CHAPMAN GASIFICATION
FACILITY
85
EVALUATION
1.0
2.0
3.0
4.0
5.0
6.0
DETERMINATIONS
169
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