SAB-EEC-86-Q12
BEPOST
of the
ENVIBOKMENTMi ENGINEERING QDMMETHE
SCIENCE ADVISORY BOARD
0. 8. ENVnOWEHERL PROTECTION AGENCY
on their review of the
"SAMPLE" RESEARCH PLSNS OP
OFFICE CF ENVTOMffiNTAL ENGINEERING AND
October, 1985
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INTRODUCTION AND HISTORY
At a meeting of the Environmental Engineering Committee of the Science
Advisory Board on February 26, 1985, Mr. Carl Gerber, Director of the Office
of Environmental Engineering and Technology (OEET) briefed the Committee on
a program of research planning being undertaken by OEET. .He explained that
five-year research plans are being prepared for 27 topics currently wader
study by OEET* These Include 10 topics on hazardous wastes and Superfund
programs, 8 topics on water and toxics/ pesticides programs, and 9 topics on
air/energy programs.
The purpose of these five-year research plans will be to describe the
EPA/OSD programs to EPA program offices, the scientific and engineering
community, and other interested groups. They will also serve as the basis
for budget discussions and defense, although they are not intended to be
budget documents themselves. They are intended to provide a technical per-
spective of what research is necessary to support the Agency's current and
future mission and regulatory needs.
At his February 26, 1985 briefing session, Mr. Gerber presented drafts
of three of these five-year research plans; namely, the Hazardous Waste -
Land Disposal research plan, the Drinking Water research plan, and the Lime-
stone Injection Multistage Burner (LIMB) research plan. He requested the
Environmental Engineering Committee to review these as examples of the plan-
ning process and to provide comments, particularly on the overall approach*
The Environmental Engineering Committee has had a deep concern for the
engineering and technology component of the SFA/ORD research program. The
Committee prepared a resolution highlighting its concern about the reduced
emphasis on control technology research in EPA and recommending to the Admin-
istrator that the trend be reversed. This resolution was approved by the
SAB Executive Committee and submitted to Administrator William B. Ruekelshaws
on October 13, 1983. The Committee was therefore quite ready to take on the
review requested by OEIT. A subcommittee of three committee members was
asked to review the "sample" plans and report back to the full committee.
Dr. Ben B« Ewlng reviewed the Hazardous Waste - Land Disposal plan. Dr.
Charles I. O'Mella reviewed the Drinking Water research plan. Mr, George P.
Green reviewed the LIMB research plan. Their written comments were circula-
ted to the full committee and the review was discussed at the Environmental
Engineering Committee meeting on June 13 & 14, 1985, The following comments
summarise the review*
GENERAL COMMENTS
The Committee applauds OEET for Its development of these and the other
five-year research plans. The three which were reviewed are sensitive to
the Agency program offices* needs. They are well done and will be helpful
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in describing the present and future research of OEET to the program offices
and to the scientific and engineering coosaunlty. The five-year planning
period Is appropriate in that It provides for some continuity which is
compatible with the Federal budgeting cyclej yet it does not extend so far
Into the unseen future as to lose its reality.
The plans do focus on present activities and those studies needed in
the next few years to continue progress in current directions. Perhaps
they should also include a. speculative component designed to identify poten-
tial new problems and their solutions.
HAZARDOUS WASTE RESEARCH PLAN
The draft of the Hazardous Waste Research Plan - Land Disposal is one
of a series of plans dealing with hazardous waste research. Without the
opportunity of reviewing the companion plans, it is difficult to determine
just what is properly included In this plan an? what apparent omissions may
actually be covered in other plans. Comments on the draft as It was pre-
sented will be made first, and then some comments will be made about addi-
tional topics which are important but which may be scheduled for some other
part of the planning process.
HAZARDOUS WASTE-LAND DISPOSAL PLAN
1. It Is not clear that the research plan has taken into
tion the provisions of the recent amendment to ROM, and particu-
larly the banning of land disposal of hazardous wastes.
2, Fage 2» paragraph 4; "The program will also develop user friendly
artificial Intelligence systems that will standardize the review
of applications submitted to the Agency. These systems will be
based on the experience of experts and field proven techniques..,"
Also page 7, last paragraph; "Calculations to determine the ade-
quacy are difficult for the uninitiated* As part of the overall
program to provide permit writers with the latest technology, a
user friendly Interactive computer program with default values
will be developed.*.." we recognize the practical importance of
evaluating large numbers of permit applications with rapid turn-
around, aad the constraints on permit writers. We are leery of
the complete dependence on a computer system or artificial intel-
ligence when evaluating such complex systems of social Importance.
Great caution is necessary in this situation. Perhaps the computer
program should be designed to throw out any unusual results and
flag them so the permit application can be referred to an expert
or a panel of experts. The computer program could screen permit
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applications which are not routine so that they could be subject
to special audit, In the manner of the IIS income tax return pro-
cessing,
3. Page 5, paragraph 2; One other area with research potential Is the
use of genetic engineering to develop biological cultures for
treatment of leachates or for detoxification of wastes, particular-
ly liquid wastes, as part of the waste modification program.
4. Page 6, paragraph 3; Previous experience with attempts to correlate
laboratory porosity or permeability with field conditions have not
been encouraging. The research effort is Important and justified,
however.
5. Page 7, paragraph 2; Techniques for detection of leaks in liners
and repair of damaged liners are very important to insuring the
integrity of the containment and thus very important to maintenance
of public confidence and acceptance of land disposal facilities.
This program should be emphasized.
Additional Comments
There are some additional research needs which have not been covered
in this research plan. OEST may intend to cover them In one or more of the
related hazardous waste research plans. In that event discussion of them
here nay be superfluous. They are raised for discussion, however.
There is need for further research to define hazardous wastes,
particularly In view of the RCSA amendments. Can the EP Toxiclty
extraction procedure be demonstrated to be reliable in predicting
leachabillty of wastes under field conditions? Can bioassay tech-
niques be developed to establish the toxlcity for a wide range of
systemic toxins, carcinogens, mutagens, teratogens, neurotoxlns,
lanunotoxins, etc.?
2. Improved monitoring techniques are needed. Better sampling methods
to avoid cross-contamination of samples should be developed. Im-
proved analytical methods, particularly for part-per-trillion con-
centrations in complex mixtures, are needed, as ate quality control/
quality assurance procedures. Monitoring protocols for long-term
surveillance need to be developed. The Importance of being able
to monitor for leaks in flexible membrane liners or clay liners
without waiting for ground-water contamination to detect It has
been commented on above*
3, Waste reduction, recycle, and recovery Is not discussed in the
research plan. There Is need both for research to develop new
technology and research to Improve understanding of motivation for
implementation of waste-reduction measures.
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New incentives oust be discovered and better understood in order
that they can be used to enhance waste reduction opportunities*
4, The plan does not discuss alternative technologies for ha«ardous
waste disposal, such as incineration, chemical oxidation, neutral-
isation, or precipitation, demineralization, photolysis, or
biological waste treatment. Again, comments above dealt with the
application of genetic engineering to improve biological treatment
processes for refractory compounds and mixtures.
5. The Hazardous Waste - Land Disposal plan does not discuss the need
for research to develop siting criteria and methods of assessment
of sites. It also seems to neglect the control of subsidence of
the landfill site after closure. Finally it does not deal with
the problems of synergtsm, antagonism, or interaction of mixtures
of complex wastes,
6, The plan does not deal with research aimed at Improved control of
pits, ponds and lagoons. There are many of these existing through-
out the country. Technology for solidification, or (even better)
fixation, is needed.
DRINKING WATER TREATMENT RESEARCH PLAN
Four topics for future research are addressed. In approximate order
of importance they are (1) trace organic substances, (2) disinfection
byproducts, (3) microbiological contaminants, and (4) small water supplies.
The report includes summaries of present work In these areas and also for
inorganic substances and radionuclides in water. Future proposed studies
emphasise organic chemicals, and include a significant amount of activity
at field scale.
The plan is well formulated to continue present directions, with
emphasis on moving to field scale testing. Without being comprehensive in
suggesting additional directions, the following are suggested for consider-
ation*
1. Field scale testing is as expensive as it is necessary. The
problems addressed and the sites selected require considerable
expertise and deliberation. If not presently available, criteria
for these selections could be developed; participation in funding
could be a. factor,
2, A goal of the research plan is to contribute to the development
of "a defensible basis for standards that apply to public water
systems." More stringent standards for contaminants presently
regulated (e.g., turbidity) and new standards for unregulated
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contaminants can be expected. This suggests needs for new tech-
nology and adaptations of present practice. These are not addressed
in sufficient depth in the plan.
3. Raw water supplies comprise a very diverse sat of problems. Both
water quantities (demands) and water qualities -(types and concen-
trations of contaminants) vary widely from place to place and» at
many locations, from time to tine. The treatment systems appropri-
ate to transform these diverse supplies Into potable waters meeting
a uniform set of standards can also be expected to differ appre-
ciably among themselves. As our recognition of problems broadens
and our regulatory standards expand to meet these newly perceived
needs, it Is reasonable to expect that treatment technology should
diversify considerably. The proposed research plan does not appear
to address this need adequately.
LIMB RESEARCH PLAN
The LIMB Research Plan is a very good plan and stands an excellent
chance of having a definite impact on the commercial sector* Even though
the Plan appears to be very good^ some hopefully beneficial comments are
presented.
Page 2, last paragraph. "The utility industry will not accept this techno-
logy, etc,..,"
There is generally the feeling that the industry would prefer to have
technology fully demonstrated. However, when considering air quality
control equipment, there is more the tendency to move ahead on new
technologies prior to successful demonstration. It is unfair to
proceed on the basis that the technology would not be used until LIMB
has been successfully demonstrated. There Is an opportunity at the
present tine for OEET to get directly Involved with at least nine
separate furnace injection demonstrations, and of these nine, six are
in the category of 100 megawatts or larger. These utilities have
already Indicated their interest to the Department of Energy for parti-
cipation in prototype tests of sorbent injection as a response to
BQI's solicitation under the clean coal technology exercise. Each
one of these utility proposals may represent a unique project that
would enhance EPA's efforts and aid in the financial support of the
technology. SPA support of sone of these projects would be appropriate,
either in conjunction with or in lieu of, DOE support and definitely
has merit in cooperation with the utilities' coal and sorbent suppliers,
boiler manufacturers, state agencies and the Electric Power Research
Institute. Our understanding of the interest that has been expressed
on behalf of the utilities is that the LIMB technology is feasible.
The real1 question to be resolved is one of economics, A. part of SPA
s long-range plan should be an expression of Interest in the projects
that have already been proposed as part of the DOE solicitation.
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Page 3, first paragraph under Generic Research and Development.
The Plan has stated that the research required for achieving the de-
sired levels of NOx removal has been completed, OSET should address
this question further as NOx levels may have been demonstrated; however,
for a long-term operation of utility boilers within the U.S., the
question of slagging and fouling has not been properly resolved* The
efforts to provide an understanding of the fly ash/sorbent mixtures
should continue to be reviewed for both the continued work on S02 and
NOx.
Page 4, paragraph 1 "...tests have indicated that the LIMB S02 removal goals
can be met with at least two alternate approaches..."
Caution is merited here since other, apparently equally promising,
approaches have not always lived up to their expectations.
Page 4, paragraph under Prototype Testing*
The benefit of extensive testing in large-scale laboratory furnaces Is
questionable. The chemical processes of sorbent activation, deactlva-
tion, and sulfation. can be extrapolated from pilot to full-scale sys~*
terns, so the primary remaining performance issue is mixing/dispersion.
Some intermediatescale testing would be useful, but only If conducted
on units with representative cross-sectional temperature and velocity
distributions, not just correct temperature-time histories.
Page 5, paragraph under Technology Generalization.
The joint EPA/IPEI Conference on LIMB which was held in November 1984,
was very successful and the Research Plan should contain some specific
references to continuation of the technology transfer and future con-
ferences.
Page 5, last paragraph, Level of effort to "...understand the enhancement
mechanism.•*"
The projected budget seems high (over SIM for FY86-88 beyond the $3M
spent in FY.84-85, according to the second line item under PPA 01). A
measured, phased approach may produce a more cost-effective R&D program
(i.e., a building block approach instead of parallel activities), and
losses would be minimized if the proposed enhancement mechanism is
found to be less effective than expected or more difficult to apply.
Downplaying the concern about potential inhibition of the sorbent
mechanisflt due to talneral matter interaction is also recommended. This
apparent effect has not been observed by all researchers. Further,
even if real, its importance is probably diminishing with the current
trend towards injection into the upper furnace*
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*
Page 6,
Significant conceptual process design and analysis Is strongly urged
before committing to experiments on sorbent recycle or utilization.
The primary near-term emphasis should probably be on waste character-
ization and feasibility studies of the concept. Because of the commer-
cial potential of the spent sorbent,, industry should participate tech-
nically and financially in the utilization efforts as the market place
now will accept the techrology and the need for the furnishing of
these sorbents.
Prototype plans -- We agree in principle, but only if the test units
have the same thermal profiles and aerodynamics as typical large boilers.
Demonstration plans -*~ It is not yet clear that the S02 part of the
LIMB process will behave differently la tangential- than wall-fired
units. The differences nay be no greater than the site-specific varia-
tions between different designs of wall-fired boilers (e.g., divided
wall, front versus opposed firing, connective pass design, coal proper-
ties that affect the optimum location for injection). Hence, the
decision to conduct full-scale demonstrations on both wall- and tan- __
getitial-fired units should await the outcome of the field tests on
smaller (e.g.,, 20 to 60 MW) units.
The technology generalization and process modeling is very good; how-
ever, a greater emphasis should be placed on the use of existing hollers
rather than spending too much money in attempting to develop a purely pre-
dictive model based on early research. Models should be developed to be
largely correlative.
The approach is very good and the program should be directed toward
the acceptance and commercialization of the technology. Future efforts
should be carried out in close cooperation with the ultimate users, namely,
the utilities and EP1.I* The time frame to achieve this work appears real-
istic; however, there Is always the basic question "Are there sufficient
funds available?"
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