REVIEW OF THE
POLLUTION CONTROL GUIDANCE DOCUMENT
FOR
LURGt-BASFD INDIBHCT LIQUEFACTION FACILITIES
July 31, 19*1
Science Advisory Board
n,s, Fnvlronmental Protection Aqency
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SPA NOTICE
This report has been written as a part of the activities
of the Agency's Science Advisory Board, a public advisory qroup
providing extramural scientific information to the Administrato
and other officials of the Environmental Protection Agency* Th
Board is structured to provide a balanced expert assessment of
scientific matters related to problems facincj the Agency. This
report has not been reviewed for aporoval by the Aaencyf and
hence its contents <3o not necessarily represent the views and
policies of the Environmental Protection Agency.
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SOBCOMMIVTPF PFVIFW OF THF
"POLLUTION CONTROL nUIDANCF: DOCUMENT
POP
LOPGI-BASFD INDIRFCT LIOtTRFACTlON FACILITIES"*
SUMMAPV OF THE PEVIFW OF TPB DOCUMENT
The Document* is a comprehensive oualitative presentation,
in that
a) it provides in one place a great amount of data that
are believed to reflect the best information currently
available in the public domain?
b) it focuses on many possible ways to process the Lurqi
erases, e.q. the Pocument discusses 41 process and
product streams and 105 discharge streams;
and, even more importantly,
c) it organizes and prioritizes its conclusions, For the
eiqht (8) discharge streams that are considered to
provide the most significant pollution problems,
commercial or near-commercial methods to render
these streams environmentally acceptable at rational
costs are presented.
The Document is not a quantitative presentation. That is,
it does not present incontrovertible data, precise costs, and
precise pollution predictions. Indeed, KPA stresses that the
data are fragmentary and, further, that the "guidance" is the
result of best engineering judgment which, in order to he
implemented must take into account local conditions and the
development of new and better data. The Document has no leqal
implications and contains no mandatory guidelines.
* May 1 draft except for Section 2 which was the May 15 draft.
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The Review Subcommittee (members listed below) recognizes
the significant qualitative assistance of this enormous
pioneering effort, but it also suggests in its review general
and specific areas that can he strengthened at this time.
Review Subcommittee
Principal Members:
Dr, Albert Gomezplata
Dr* Cecil Lue-tting
Dr. Francis McMichael (ex officio)
Mrs. Marion Monet
Dr. James H. Porter
Asa isting _Cgnsul tants ;
Mr. Allen Cywin
Dr. Simon Goren
Dr. W« Leigh Short
Dr. Paul Spaits
Specific Areas of Concern
General, Water, Costing
General, Water, Solid Wastes
General*-Costing
General, Toxic Substances
General, Air, Costing
General, Water, Solid Wastes,
Regulations
Air
General, Air
General, Air, Costing
111
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ORGANIZATION OF THE REVIEW
SUMMARY OP THE REVIEW il
MEMBERS OP TRE REVIEW SUBCOMMITTEE ill
ORGANIZATION OP TH.E REVIEW - a TABLE OF CONTENTS Iv
FOREWORD: ABSTRACT of the EPA DOCUMENT V
A. The Purpose of the Document v
B* Ttie Technology v
C. **odel Plants Approach v
D. Pollution Control Considerations & Guidance v
Eiaure 1: Model Plant Configuration vi
Eiaure 2; Key Waste Streams of Environmental Concern vi
THE REVIEW
A. neneral Review 1
B. specific Areas 2
1. Air 4
2, Water 5
3, Solid Wastes 7
4. Costing 9
5. Toxic Substances Control Act 11
6. Regulations 11
C. Conclusions anr? Comments 13
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5/I»/8l)
VI
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A,. General Review
The draft Document* is a successful effort to
organize a complex, often uncharted area. This
organization shows the difficulty of controlling emissions
from such a large integrated facility, before the facility
is fully conceived. Also, this organization shows how to
recognize the important effluent streams and how to
prioritize them.
This Document is not a "cookbook" or a "compliance
document" which must he followed step-by-step. The
Document is a "how to." book to allow its users to nake
judgments" "for 'themselves on how to approach an evaluation,
how to recoqnisje the problems, and how to effect
reasonable solutions for their own specific problems.
The results presented in this Document have done
much to put the technology into better environmental
perspective. The model plant approach conveys an
understanding of the total "system" that could not be
gained from study of individual processes. And,
individual discharges with their associated pollution
potential have been assessed to estimate their relative
importance. This Document plus an understanding of
special local constraints can orovide a preliminary base
from which to begirt interactions toward development of
pollution control technology and compatible permits. This
clarification of important areas should help permittors,
constructors, and concerned residents.
The possibility of using multi-media trade-offs is
suggested qualitatively. This is timely advice in the
development of control technology for these plants to
achieve cost-effective controls.
* May 1 draft except for Section 2 which was the May IS draft.
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This noeument has an encyclopedic compendium of data
related in greater or lesser deqree to the Lurgi Indirect
Liquefaction of coal process and to its attendant
discharge streams with various degrees of polluting
potential. The collection of this much data is of
siqnificant value; although, in later specific areas of
our review some regrettable omissions are mentioned*
Although this numerical data base exists in the
Document, users should not feel that the resultinq numbers
are more than qualitative approximations. The data, which
are also of uneven quality, have come from
a) pilot plants usinq coal but without integrated
pollution control systems;
h) full-scale foreign installations without
siqnificant pollution controls? and
c) data from related industries, such as petroleum
refining.
There are no data from full-scale Lurgi indirect coal
liquefaction plants operating with any of the proposed
control systems. Also, no mention is made in the Document
of consistency checks of the data -- e.q., for the
emissions qases of the Lurgi gasifier, the composition of
the qases can he checked for consistency by employing
chemical equilibria calculations.
Specific Suggestions and Comments
a) Section 2 is a strong summary of Volume I. This is
not immediately apparent from the Table of Contents
or from the flection itself. Section 2 should he
highlighted or perhaps rewritten to make it more
obvious to the user.
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b) At least cwo flow diagrams are needed in the
Document;
i) Flow diagram of the model plant configuration
(gasifier using 3 coals, 3 product syntheses, ^nd
2 control levels)? and
ii) Plow diagram showing key waste streams (and where
they originate) of primary environmental
concern.
Note; We have included a suggested form for such
diagrams on page vi cf this report.
c) Some future high priority needs are
i) development and demonstration of nore effective
and lower-cost control systemsj and
ii) development of additional exposure and effects
data to improve assessments of relative risk in
order to specify control level options,
d) The Document is written, with few exceptions, in
metric units. Current professional usage, with few
exceptions, utilizes British units. The usage in the
Effluent Guidelines Documents includes both British
and metric units.
e) In Volume I of the Document, the use of acronyms for
terms used only once or twice should he minimized.
f) The philosophy and implications of Option I and
Option II controls are not discussed in detail in
any one place perhaps Section' 2 would be a
suitable place for this to he discussed explicitly.
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g5 The Document should clearly indicate the imp
assumptions or philosophies user? during evaluation
and interpretation of the data. For example.
What is the implied meaning of "general practice in
cost estimating" in the presentation of cost
estimates? Or, What are the assumptions behind
"reasonable" for pollution control costs?
h) The conclusion about Noise {Volume 2t Section 3*5}
should he included in Volume I: noise from a Lurqi
facility will not be of sufficient level to disturb
either humans or animals beyond the confines of the
plant site*
i) The references in Volume III should be improved to
allow the source of the data to be documented, The
references should he specific, identifiable sources.
B»1, Air Pollution Control Considerations
"Review of the air pollution content of Volume I
revealed no problems associated with the technical
content or its quality, as far as this can be judged front
the information in Volume I.
Specific Suggestions and Comments
a. There was general agreement that pollution control
costs, expressed as cost per unit of coal input, would
he a useful addition to the cost data presented.
b« In Section II, the Summary Section, some information
on pollution concentration before and af-er control
(i.e., relative efficiency lev%15 would be helpful
along with the cost and volume data presented.
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c. Section 4.1 mentions fugitive dust problems
associated with coal storage and handling, and
perhaps crushing and grindina. More emphasis
could he aiven to this dust problem.
d. A clear statement is needed to indicate how the
engineering analysis was carried out,
e. The most important pollution control costs should he
identified and more fully discussed, including the
accuracy of the cost estimates for individual
devices.
f. It possible from the present data, total mass flows
and concentration levels of all pollutants emitted
from the gasifier should be specified.
P. 2. Water Pollution Control Considerations
The Document states, "If adequate control over
aqueous discharges in these plants is to he achieved, the
early demonstration of the technical and economic
viability of the candidate controls identified in this
document ».. is desperately needed. *' This is indeed true,
The authors 'state that, "Most of these processes
(water pollution control) have not been applied directly
to the control of indirect liquefaction plant wastewaters.
Evaluations of the applicability, performance, and costs
of these controls have been based upon experience gained
primarily in the byproduct coking industry, petroleum
refineries, and the electrical utility industry* .Also,
extensive use was made of conceptual information developed
by designers and potential operators-' of future Lurgi
facilities," mhis leads to the great strength and the
weakness of the Document*
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"he approach to permit design flexibility in
with site- and process-specific effects is commendable.
The Document is useful in outlining the problem areas
and in providing access to the related information.
However, the material is not satisfactory for design
considerations. One of the major principles in
environmental enqineering is that wastewaters from similar
processes can he very different from one another. One
cannot extrapolate and assume that the unit process
performance on a particular wastewater will he identical
for another wastewater. Several of the recommended unit
processes should he piloted before adoption, and a caveat
to that effect should he included.
Spec i f i c _ S uqq e s t i on s _a nd Corome nt s
a. Volume I/ page 8; Include flow diaqrams for key
waste streams.
b. Volume I, page 12: The statement relative to
control levels defined by Options I and II
as being achievable at reasonable cost and
with conventional equipment is Questionable.
The statement contradicts the Agency's admission
that wastewater treatment pilot plant data, both
desiqn and operational, were not available for
evaluation,
c. Volume I/ paqe 14; The 0.02 mq/1 total phenol level
should be checked. This appears to he a severe
limitation on the effluent and may not he
necessary even to protect primary surface drinkinq
water sources.
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d. volume I, page 24s The limits for both Option I
and II appear to he technology based. !tie
Pocuroent should recognize the fact that water
quality criteria will control in the absence of
Federal regulations.
e. Volume 1t ps
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could represent a significant portion of total
disposal costs, especially if the solid wastes
tnust he disposed of as hazardous wastes.
c. Volume I, page 30, Section 2.3.3.2 (See also page
179, the Section on Sulfur.)
i) We recommend a more critical analysis of
whether it is more cost-effective to
dispose of sulfur-containing streams
directly or to recover sulfur and dispose
otherwise,
ii) Following sulfur recovery, would the
vanadium, thioeyanate, etc, present in
the residues still reauire disposal as a
hazardous waste?
iii) If the residues following sulfur recovery are
hazardous, what are the cost implications
relative to total costs of solid waste
management or disposal?
d. Volume I, page 30:
The assumption of an economic break-even
operation with "income balancing recovery operation
costs" should be based upon a cost estimate made for
more than one geographic region of the country when
one considers the cost of transportation for
marketing heavy bulk materials such as dry ash and
sulfur.
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e. Volume I, page 3D:
It is recommended not only for bio-sludge hut for
all solid wastes that the proposed list of hazardous
materials in hazardous waste streams, issued by the U.S.
EPA under Section 3001 of RCR£, should be double
checked for relevancy'.
f. Volume I, page 30;
Land treatment of bio-sludge may not be
universally applicable for reasons such as soil type,
ground water, or climate conditions.
B»4 Costing
The Document, as a qualitative presentation of areas
of concern, presents a very helpful approach to the
estimation of costs for pollution control equipment.
Data, developed for both the pollution control
eauipment costs and for the uncontrolled process equipment
costs, are in Volume III-A and in Volume III-P. The
comparison of all pollution control unit operations costs
to the base cost of an uncontrolled plant may be
misleading.
Specific Suggestions and Comments
a. The method of presenting costs is awkward and does
not follow typical practice. Costs should he
presented on several bases in Volume I and Volume
III!
i) as a percentage of total plant costs?
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ii) as Collars of capital costs per unit plant
feedstock capacity, e.g., S/tpn of coal; and
iii) as dollars of annualized costs per unit of
feedstock processed, e.g., S/ton of coal/day.
For items ii) and iii), it is important also to
report the removal efficiencies for key pollutants,
Column headings for the tabulation might he as
follows:
Control process description
input treated stream capacity
Capital cost
8
s/ton
% of total plant
Annualized cost
S/ton
% of total plant annualized cost
Removal efficiency
Volume I, page 11: It is stated that the cost
estimates are judged to be accurate to +50%. This is
a qualitative ranqe within a qualitative document,
Also, the authors are not consistent in treating
this value as the range for each component of the
cost estimate or as the range for the totalled costs.
It makes a difference. In addition, the consequences
of these uncertainties on pollution control costs
should be identified.
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R.5 Requirements for Toxic Substances Control (Volume I,
page 52, Section 3.4)
TSCA situation is described well for Section 5 of
the Act, Premanufacture notification (PMN). As more
Sections of TSCA are put into effect, they should be
followed assiduously because many of the streams are of
interest under TSCA. One example is TSCA, Section 4 -
Testinq Guidelines.
The Discussion of ^P*NS should also mention
"intermediate streams » * tinder the present interpretations
of Section 5, any stream that is sent to storage, even
though it is processed on the plant site at a later time
(even one day later) , is subject to PMN,
advice of the Document, to maintain a
liaison with the Synfuels/Toxics Workgroup (S^WG) of the
EPA Office of Toxic Substances, is the best possible advice
at this time.
B. 6 Reg u 1 a t ions
Specific Suggestions and Comments
a. Air Pollution Regulations (Volume I, page 37,
Sections 1 and 3*1)
The Section on air regulations appears to be
adequate.
b. Water Pollution Regulations (Volume I, page 40,
Section 3.2)
/
V
i) Itie Criteria Pollutants listed in Section 307a
in the Clean Water Act of 1977 should be
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compared to those effluent pollutants frotr a
Lurai plant because these will be used In thrs
next series of water Quality standards.
il) It is likely that state water quality standards
will be the basis for most permits. Perhaps
this point can be addressed by a site
specific example,
iii) Tlhe Document needs to ha^e a discussion of the
applicability of water quality standards
and/or those based upon technology, and when-
one set of standards or the other applies.
iv) The date for technology-based effluent
standards (July 1, 1QS3) is no loncrer
applicable* This should be updated.
v) Table '3-3 f Volume I, paqe 42) should be upqraded
to indicate the requlations under Sections
31fi'a) and 316(b) of the Clean Water Act.
Solid and Hazardous Waste (Volume I, paae 4fi,
Section 3,3)
regulations under Section 3001 of PCPA (listina
hasnrdous waste data, hazardous waste metals
and chemicals, and hazardous waste substances)
are omitted. These were available in pro
form sinc^ December of 1Q7R and Auaust
and part were promulqated In May of i
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ii) A number of RCRA regulations were promulgated as
this Document went to press, It is assumes?
that the lists on pages 43 and 50 of Volume I
will he updated,
d. Suoerfund
Under the Clean Water Act and now under Superfund,
every plant of this type and size will be subject to
severe penalties for spills of oils and/or chemicals,
It btjhooves every plant to have a "fip.il!. Prevention
and Control Program." Mention should be made of
this.
C. Conclusions end Comments
The qreat strength of the Document is that it has
taken a complex and tentative technology and provided a
qualitative quide for considering the environmental
implications of the plant. Itie Document will be worth the
effort of its production if its timely, tentative, non- -
bindinc perspective and organization could
a) provide a tentative basis for discussion between
regulators and constructors;
h) encouraae the design and installation of cost-
effective pollution controls at the time of
plant construction;
c) reduce permitting delaysj
cl) reduce requlatory uncertainty and risks of costly
retrofits; and
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e) promote public confidence in the environmental
safety of first-generation plants.
Although individual details can be challenqed, the
results are Qualitatively useful for guiding analyses of
pollution streams and control. tfie engineering approach,
including the engineering judgments user! to bridge the
areas of incomplete data, are valid, although probably
never optimal. The model plant aoproach allows for
combinations Q process steps and allows for estimating,
albeit roughly, the pollution potentials of waste streams,
The concepts are presented to allow early decisions on
multi-media choices -- the trade-offs between
air/water/solid wastes pollutant streams to be treated.
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