ENCYCLOPEDIA OF ENVIRONMENTAL SCIENCE AND ENGINEERING - PLANNING FOR NEW PROCESSES: ENVIRONMENTAL ASPECTS pptx

These federal and selected state environmental acts essentially address the following: Land Use Aspects fuel storage, exclusion or buffer zones, waste disposal, zoning, and demography; W

INTRODUCTION

Planning for a major new facility must address the

envi-ronmental impact of both the construction and operational

phases of the project It is essential to optimize alternatives,

while evaluating performance relative to regulated

emis-sions and ambient standards and to develop a cost effective

permitting strategy

For large scale projects, Quig (1980) recommends a

highly integrated project approach for environmental

com-pliance early in the planning stage based upon historical

siting, licensing, engineering and construction experience

with similar sized plants

Strong emphasis on early process work is necessary to

understand environmental impacts This and other front-end

engineering and planning should be executed in very close

coordination with the staff charged with documenting the

licensing effort Extensive use of specialists is generally

required

The major federal acts to be addressed are:

1) National Environmental Policy Act, (NEPA), 1969

2) Clear Air Act Amendments, revised 1990

3) Federal Water Pollution Control Act Amendments,

1972 (FWPCA)

4) Resources Conservation and Recovery Act (RCRA),

1976

5) National Historic Preservation Act of 1966

6) Historical and Archaeological Preservation Act of

1974

7) Endangered Species Act, 1973

These federal and selected state environmental acts

essentially address the following: Land Use Aspects (fuel

storage, exclusion or buffer zones, waste disposal, zoning,

and demography); Water Resources (availability and

com-petitive uses, wastewater complexities and water quality,

hazardous wastes, and waste heat); Air Quality/Meteorology

(attainment/nonattainment areas, in terms of offset policy

and lowest achievable emission rate; newsource

perfor-mance standard for particulates; NOx and SO 2 ; prevention

of significant deterioration in Class I, II, III; stack height

credit; hazardous wastes; minor meteorologic changes);

and Regulatory (multiple lead agency involvement,

licens-ing strategy, feasibility of concept, permit requirements, and

federal/state implementation)

The environmental, health safety, and socio-economic impacts discussed above highlight the areas of concern which must be considered in the site characterization studies and subsequent reporting of the project compatibility with the proposed location Baseline conditions must be identi-fied in the areas of potential impact The characterization of the environment, the definition of the process operations and the identification of the potential impacts are the elements required for input to a comprehensive program of facility design for impact mitigation As such, the development of

an environmental statement of the project serves as feedback

to the design effort with the result being a facility licensable from the environmental viewpoint

To illustrate the procedure we shall present a typical example, namely planning a new coal gasification plant

Technical details of gasification are discussed elsewhere in this Encyclopedia under Coal Gasification Processes The example will focus on regulatory requirements and siting considerations

REGULATORY REQUIREMENTS

The first step in any program of this nature is to define the regulatory requirements associated with the construction and operation of the proposed facility This will define specific limitations and establish generally the study requirements for the program as they relate to the environmental, safety, health, and socioeconomic aspects of the development

AIR QUALITY RELATED REGULATORY REQUIREMENTS

Federal Requirements

At the Federal level, this project will be required to comply with the following air quality regulations and requirements

Primary and Secondary National Ambient Air Quality Standards (NAAQS) A demonstration showing compliance

with NAAQS must be made to EPA for approval to com-mence construction This would involve modeling the anticipated plant emissions and imposing the resultant con-centration increases on representative ambient air quality conditions and comparing these with NAAQS Information necessary for this demonstration would include the facility emissions as discussed earlier and the ambient air quality

developed from a monitoring program or from representative

data as available

New Source Performance Standards (NSPS) The proposed

air quality control system (AQCS) for the facility must be

designed to comply with existing NSPS for the coal

prepara-tion facilities (e.g., particulates), the gas turbine component

(e.g., NOx) and the auxiliary boiler (e.g., SO 2 ) of the plant

Since NSPS do not exist for the coal gasification

compo-nent, appropriate AQCS Best Available Control Technology

(BACT) evaluations will be performed to select the

con-trol system In addition the AQCS design will have to be

reviewed with the EPA for approval to construct

Prevention of Significant Deterioration (PSD) No

con-struction can commence until the PSD permit has been

obtained The report and application for the permit would have

to consider the following: the emissions from the total facility;

a BACT review for any regulated pollutant (NAAQS,

allow-able increments, NESHAP), which the plant emties above

“de minimis” values, an air quality review for all pollutants

emitted, after controls are applied, over the “de minimis”

emis-sion rates unless it were demonstrated that the air impacts of

those emissions would not exceed the air quality impact “de

minimis” values As part of these demonstrations ambient air

quality monitoring would have to be conducted for the same

pollutants for which BACT demonstrations would be required

unless representative monitoring data are available

National Emission Standards for Hazardous Air Pollutants

(NESHAP) The discharge to the atmosphere of pollutants

regulated under NESHAP is not anticipated for this type of

facility However, tracking of EPA’s continued development of

NESHAP should be carried out to ensure compliance with the

regulations as they develop

New stationary sources and modifications to major

sta-tionary sources are required by the Clean Air Act to obtain

permits prior to construction of a new process facility The

stringency of permit requirements depends on the regional

status of its compliance with ambient standards for

particu-lar pollutants For example, in zones having acceptable air

quality referred to as “attainment areas” for a specific

pollut-ant, the permits are of the prevention of significant

deterio-ration (PFD) type The code of federal regulations, US EPA

Title 40 CFR, 51.166, specifies the set of minimum PSD air

quality permit requirements to warrant approval by the US

EPA The primary objective of PSD is to insure new major

sources and modifications of existing sources comply with

NAAQS Specific public notice requirements and

subse-quent hearings allow for public comment to be part of the

PSD review process On the other hand, in a non-attainment

area, NAA permits are required NAA permits address area

improvement of pollutant levels and falls under the state’s

supervision, through a State Implementation Plan (SIP)

enforced by the US EPA and DOJ Either type of permit is

subject to New Source Review (NSR) The physical change

triggering regulation of pollutants is usually 100 or 250 tons

per year, depending on the industrial source category As of

early 2005 the definition of major modification for coal fired

power plants has come under dispute in the courts (see the

discussion at the end of this article for further information)

State Requirements

The state may have air quality related requirements which will affect the proposed project

State requirements may include a permit to construct a facility if the construction of operation of the facility will release air contaminants into the atmosphere The appli-cant must submit a completed application for Approval of Emissions and an Emission Inventory Questionnaire (along with a copy of the PSD Application) which show compli-ance with state air quality standards, toxic substcompli-ance limita-tions and emission control requirements

WATER QUALITY RELATED REGULATORY REQUIREMENTS

Federal Requirements

At the Federal level, the major laws affecting the discharge

of liquid effluents from the proposed facility are as follows:

Clean Water Act (CWA) Under the CWA, the proposed

project will require a National Pollutant Discharge Elimination System (NPDES) permit before commencing construction and operation The application to the EPA for these permits would

be based on the conceptual design of the wastewater control systems which could ensure compliance with effluent limita-tions and water quality standards Where effluent limitalimita-tions are not specified for discharges from certain facilities, limi-tations on discharges from similar operations would be used

as a guideline for design of the wastewater control systems

These designs would be used to support the application for an NPDES permit The NPDES permit and the work effort neces-sary for its preparation will also address the discharge of toxic pollutants listed on the Section 307(a) toxic pollutants list and any other toxics discharged from the plant

A section 404 permit is required by the Corps of Engineers for the discharge of dredge or fill material in the navigable waters of the United States This permit is required for the river structures associated with the facility and would

be prepared and obtained concurrently with the Section 10 permit required under Rivers and Harbors Act (see discus-sion below) and the NPDES permit

Application for either an NPDES permit from the EPA or

a Section 404 permit from the Corps will trigger the NEPA review process and is the basis upon which the preparation

of an environmental report (ER), in support of a Federal EIS,

is considered necessary

Rivers and Harbors Act of 1899 (RHA) Under Section 10

of the RHA, any construction activity in a navigable waterway requires a permit from the Corps of Engineers This permit will be required for the construction of the intact and discharge structures and the barge loading/unloading facilities It would

be submitted jointly as a common permit application with the Section 404 Dredge and Fill Permit application

State Requirements

The state often has water quality related regulations and requirements which must be complied with before approval

to commence construction and/or operation of the proposed

project can be obtained They are typically as follows:

A state regulatory agency may require that a certificate of

approval be obtained prior to construction of a treatment

facil-ity for handling industrial wastes A report containing detailed

information about the operation of the treatment facility must

be developed and submitted prior to construction

Regulations may also require the submission of a permit

application prior to discharge from an industrial source The

State may also issue a certification in accordance with the Clean

Water Act which confirms that discharges from the facility will

comply with effluent limitations and water quality standards

SOLID WASTE RELATED REGULATORY ACTIVITIES

Federal Requirements

The major Federal law governing the handling and disposal of

solid waste is the Resource Conservation and Recovery Act

of 1976 (RCRA) The most significant sections of RCRA are

Subtitle C, which deals with Hazardous Waste Management

and Subtitle D, which deals with Non-hazardous Waste

Management Regulations pursuant to Subtitle C of RCRA

address identification and listing of hazardous waste,

stan-dards applicable to generators, transporters, and owners and

operators of hazardous waste treatment, storage and disposal

facilities and permit requirements for treatment, storage or

dis-posal of hazardous waste The project will require a permit for

disposal of any solid wastes determined to be hazardous by

the criteria in Section 3001 regulations Operation practices

of the solid waste management facility are also regulated In

this regard the work necessary to determine the nature of the

solid waste generated by this facility must be carried out If the

wastes are determined to be hazardous (Section 3001 Criteria)

the applicable requirements of Subtitle C or RCRA must be

incorporated into the facility design

Regulations promulgated under Subtitle D or RCRA

establish criteria for the development of State plans for

management of solid waste No requirements are directly

imposed at the Federal level

State Requirements

State plans for the management of solid waste (Hazardous

and Non-hazardous) may be at varying stages of

develop-ment An application for a permit to operate a hazardous

waste management facility may be filed with the state’s DNR

if any solid wastes to be generated at the proposed facility

can be classified as hazardous

NATIONAL ENVIRONMENTAL POLICY ACT (NEPA)

The major provision of NEPA which significantly impacts

the planning and scheduling for major industrial facilities

is the need for Federal agencies contemplating major actions,

such as issuing permits, to prepare an environmental impact

statement (EIS)

In the case of this coal gasification facility, the requirement for a Federal EIS would be triggered by the application for

an NPDES permit from EPA and/or a Section 404 or Section

10 permit from the Corps of Engineers for anticipated river structures Upon designation of the lead agency based on discussions with the various Federal agencies and submit-tal of applications for permits, the EIS would be prepared according to CEQ final regulations

SITING THE PROJECT

Geology, Topography, and Soils

Geology studies should be performed to describe the soils, geologic and topographic setting of the site, particularly with respect to structural and topographic control of the local and regional groundwater flow systems A secondary, albeit very important, purpose is the identification of potential geologi-cal hazards within the site area

Information sought includes physical and chemical soil characteristics, general topography, paleontology, and geological framework Descriptions are sought for aquifer systems and characteristics including their name, thickness, depth, stratigraphy, and areal extent Mineral production and unique geologic/geomorphic features will be documented

Pertinent data is summarized in tabular and/or graphic format

The results of the geology studies primarily define the soils, topographic, and geologic setting of the site Potential impacts references these descriptive settings to evaluate impact magnitudes The impact of plant site preparations and construction or localized site topography, soils and ero-sion characteristics, and site physical and economic geology are assessed Geological hazards discussed include exces-sive slopes, unstable soils and fault zones

Groundwater Hydrology and Water Use

The purpose of the groundwater studies is to understand the physical and chemical characteristics of the groundwater regime This allows for an accurate assessment of groundwater impacts resulting from the proposed action in addition to for-mulation of mitigative measures to help alleviate these impacts

In addition, information necessary for the design of solid waste handling facilities as prescribed under RCRA is developed

Information sought includes general topography and geological framework, description of aquifer systems and characteristics including their name, thickness, depth, stra-tigraphy, and areal extent; seasonal groundwater levels, rate, and direction of flow; aquifer hydraulic properties including permeability, transmissivity, and storativity; surface water/

groundwater inter-relationships; location of aquifer recharge and discharge areas; ground water quality; and domestic, industrial, and municipal groundwater well distribution and characteristics Long and short term regional and site specific (within 5 miles of the site) data is sought Special efforts are made to document the location of contaminated areas

Groundwater sampling can be conducted in conjunction

with surface water sampling Samples are taken quarterly

from monitoring wells

This information can then be evaluated in light of the

projected facility emissions and demands on the area’s

resources The issues and concerns to be addressed include:

1) Use of groundwater by the plant, and the effects of

lowering water levels or pressures for this reason

or for construction purposes

2) Changes in water quality, or effects on rocks/

deposits, caused by accidental leaks or spills, efflu-ent discharge, slag or scrubber sludge pits, surface water and the like The potential impacts identi-fied are evaluated in light of their magnitude and importance Extra attention is paid to those judged significantly high in either value

By early identification of stresses that might affect the

natu-ral systems, steps can be taken to minimize the impacts or

alleviate them to an acceptable degree Mitigative measures

that can be taken during plant design, construction or

opera-tion, such as adding clay liners, for example, can be evaluated

and described

Using the results of plant design, the initial impact

eval-uation and the adopted mitigative measures, a final

evalua-tion is made of the effects of the construcevalua-tion and operaevalua-tion

of the proposed plant and ancillary facilities on the natural

environmental systems

This activity evaluates expected effects of the proposed

plant both during and after construction of the groundwater

hydrologic environment Each effect is evaluated as to its

unavoidable adverse effects and favorable effects

Surface Water Hydrology and Water Use

The purpose of the surface water studies is to determine,

develop and present the surface water quantity and quality

characteristics of the site and its surrounding environs These

data and information are analyzed and evaluated in recognition

of the proposed facility’s operation and construction related

characteristics to determine and project potential effects and

impacts on the surrounding surface water Specifically, the

objectives are:

1) To provide a quantitative description of the

hydro-logic setting of the site and its vicinity including any stream flow characteristics (i.e., flood and low flow frequencies, seasonal ranges, averages, and historical extremes), and the physical and chemical water quality characteristics of source and receiving waters Annual and seasonal ranges and averages are developed

2) To identify the other water uses (withdrawals as

well as discharges) and users including the loca-tion and quantities involved;

3) To identify the existing water quality criteria and

regulations affecting plant discharges, and

4) To evaluate the impact of construction and opera-tion of the proposed plant on adjacent surface waters, with regard to the applicable water quality criteria, and related permit requirements

The data and information needed for the description of the hydrologic setting of the surface waters of the site and evalu-ation of the plant’s impact include the following:

1) Geographic and topographic maps of the site area containing varying degrees of local and regional details to delineate the drainage basin and its drainage patterns

2) Watershed characteristics such as geometry, slope, vegetation types and density, and soil types

to derive rainfall-runoff relationships (empirical runoff coefficient)

3) Records of rainfall events to estimate overland flow

4) Records of stream flows from gaging stations on local water courses These data are used in defin-ing statistical stream flow characteristics

5) Meteorological data including air temperature, relative humidity, solar radiation, wind speed and evaporation data, and thermal plume calculations (as needed)

6) Records of various water users, locations of with-drawal, quality, and quantities involved

7) Proposed plant site location map, grade elevation, drainage pattern, character of soil types, and cover

8) The physical and chemical water quality charac-teristics of the surrounding surface waters

9) The facility description and operational characteris-tics relating to the discharge quantity and quality In addition, construction procedures, methods, sched-ules, and erosion control features are needed

In addition to a water quality characterization program, the required data is collected through existing sources This would involve a thorough search, review, and compilation

of the existing hydrological data base Appropriate Federal, State, and local agencies are contacted and interviewed and published regulatory materials is reviewed to gain informa-tion regarding other water users and water laws affecting the plant construction and operation

A field monitoring program is carried out to obtain water quality characteristics of intake and discharge waters Water quality samples are taken quarterly from selected stations

A hydrological assessment of the construction phase is undertaken to:

1) identify changes in drainage patterns and possible effects on flooding potential,

2) identify changes in riparian terrestrial habitat areas, 3) identify the potential for erosion and local soil losses

These impact areas are addressed, and mitigating measures are specified for their control

For the operational phase, the various aqueous discharges

from the plant are inventoried and evaluated Results of

plume analyses, if appropriate, are critiqued with respect

to compliance with applicable water quality criteria and

standards Recommendations concerning the potential

opti-mization of the plant water management plan are made to

reduce or eliminate environmentally objectionable

dis-charges Consumptive water use for the plant is identified

to determine the effects of plant operation on intake waters

and downstream users Recommendations concerning

opti-mization of the plant water management plan and the use

of alternate or supplemental sources of water are made, if

warranted

Ecology

The ecological studies are designed to generate and assemble

pertinent data to determine the status of threatened and

endangered species, and commercially or recreationally

important wildlife species, and to identify and locate

sen-sitive, unique, and critical aquatic, riparian, and terrestrial

habitat areas in the site area Additionally, the status of

com-mercially or recreationally important fish in any site intake

and discharge waters is determined The biological setting is

then analyzed in light of the proposed plant construction and

operational characteristics to arrive at assessments of impact

potential

Terrestrial Ecology

In evaluating the impact of the project on the terrestrial

environment, the work objective is to assess both

construc-tion and operaconstruc-tion of the facility utilizing “baseline” data

developed and secured from field programs, literature, and

agency contacts Animal species, occurrence, abundance,

distribution, and preferred habitat associations and principal

ecological interactions are determined Habitats are

identi-fied and described as natural plant communities within the

site Additionally, discussions and data gathering activities

focus on vertebrates and prominent otherwise important

plant community components

Construction-related effects largely result from

veg-etation and habitat removal, which often constitutes the

major impact of a major industrial facility on terrestrial

communities

Assessment of vegetation loss due to land clearing is

based on previous identification and mapping of regionally

productive rare, or otherwise important vegetation types

In this regard, the role of plants in soil stability warrants

detailed consideration Effects of facility construction on

wildlife is also evaluated in terms of important habitat areas

Attention is focused on those species which appear sensitive

to habitat loss (e.g., species already limited by factors

relat-ing to habitat availability), which function as critical

compo-nents of a community, or which are considered “important.”

The latter category refers to wildlife designated uncommon,

threatened or endangered, or wildlife of recreational or

eco-nomic value

An assessment of project operation including existing and proposed effects on vegetation must consider stack and cooling tower emissions Predicted ground-level concentra-tions of stack emissions and cooling tower salt are compared

to exposure levels considered thresholds for possible injury

or damage, and to exposure levels documented as injurious under filed conditions

Potential effects of facility operation (existing and pro-posed units) on wildlife from stack emissions, dust, increased human activities, and noise are evaluated Additionally, the potential for bird collisions with plant components is evalu-ated The magnitude of a potential bird-collision problem is evaluated from data compiled during field studies Included

in the impact assessment analysis is the use of the plant site by wildlife during station operation Collecting ponds and other waste bodies provide habitat for waterfowl and amphibians, while areas cleared during construction and allowed to revegetate (or which are replanted) potentially provide habitat for a variety of species

Aquatic Ecology

The aquatic ecology of the site intake and discharge waters

as well as habitat removal associated with barge facilities is addressed, habitat and food web relationships of the system characterized and potential impacts to the system estimated

Data requirements are met by literature review, interviews, and discussions with local fishermen and scientists and field collections While data gathering focuses on fish species, particularly the commercially or recreationally important species, other biotic elements of the lotic and lentic environ-ments are identified

Evaluation of potential impacts of the construction and operation of the proposed facility consist of projecting the effects of the various activities on the description of existing environmental conditions developed as a result of the field program, literature review and agency contacts described above

The primary construction impacts likely to affect the aquatic habitat are those associated with the construction

of the intake facility and secondarily increased erosion due

to construction Impact assessment of construction activi-ties centers primarily on habitat lost or denied due to actual physical placement of structures and habitat degradation

Attention is focused on those species which appear sensi-tive to habitat loss; which function as critical components of the aquatic community; or are considered “important” (rate, threatened or endangered, or of commercial or recreational value)

Assessment of operational impacts centers on the effects of water withdrawal and the associated losses to the fish commu-nity due to entrainment and impingement Potential changes

in the population structure all addressed Losses are estimated from population densities and from the field sampling program

Entrainment losses are expressed as “adult-equivalents” if war-ranted for important species Potential discharge effects (ther-mal and chemical) are based on information developed from the literature review and input of engineering parameters

Land and Waterway Use

The purpose of the land and waterway use—demographics

effort is to:

1) determine the existing land use of the site and

existing and future land and waterway use pat-terns in the surrounding area in order to assess any conflicts which may exist and to evaluate any impacts on land use that may occur from the con-struction and operation of the plant; and

2) determine the population growth patterns of the

area in order to assess the impact the plant will have

on nearby towns and communities in the area

Based on the existing land uses, and the analysis performed

by other disciplines such as terrestrial and aquatic ecology

and air quality, impacts upon adjacent land uses caused

by construction and operation are estimated This impact

assessment includes the impact of storage pond

construc-tion, noise, dust, plant appearance, stack emissions,

cool-ing tower foggcool-ing and salt depositions, and construction

stage traffic activity on residential, recreational,

agricul-tural, and other adjacent land uses in the area, as well as

the compatibility of the proposed plant with local land

use plans, aesthetics, and regulations Specific attention

is given to the type and relative value of the land uses to

be preempted or adversely affected by plant construction

and operation

The impacts of the increase in activities on a river if

applicable is estimated including additional barge traffic

staging in the area and the impact of these activities on

exist-ing movements and facilities in the vicinity of the area

The demographic impact assessment consists of

com-paring the population projections for the study area to the

expected population influx to be caused by plant

construc-tion and operaconstruc-tion The comparison is done by taking the

estimated plant-related population influx as a percentage of

the total projected population of the area to be affected by

the incoming workers and families

Socioeconomics

The purpose of the socioeconomics studies is to

deter-mine and describe the existing socioeconomic base for the

plant region and surrounding major towns and to assess the

changes, either positive or negative, which would occur as a

result of the construction and operation at the proposed site

The existing socioeconomic based is described for those

areas likely to be impacted by the influx of construction and

operational employment for the plant Information required

to describe the socioeconomic base of the area includes the

following:

1) peak number of construction workers by craft

during each year of plant construction;

2) estimate of the number of immigrant construction

workers expected during construction of the plant;

3) existing and future capacity of the schools, hospi-tals, fire, sewer, etc., facilities in site area;

4) local government fiscal capabilities and local tax structure and tax bases;

5) employment and income statistics; and 6) economic base studies

Socioeconomic impacts can result from the influx of immigrant construction workers to the area around the plant This occurs when the construction force required to build the plant is fairly large and there are a number of large construction projects competing for the labor supply

in the area

The socioeconomic demand analysis qualitatively com-pares the demand for service facilities, and employment during the construction and operation of the plant with the baseline socioeconomic projections Any perceived increases

in demand for local facilities is qualitatively evaluated with respect to the cost of the facilities and the ability of local units to finance them

Impacts associated with plant operation to be assessed include an evaluation of the change in local tax structure as

a result of a large influx of new tax revenues to the local governments and the impact associated with the relocation

of plant operating personnel into the area

Noise

The purpose of this effort is to sample the existing ambi-ent noise levels surrounding the proposed site, and to esti-mate the environmental noise impact produced by the plant operation

In order to properly assess the noise environmental impact, plant noise emissions should be evaluated in terms

of any State or local noise regulations Consequently, vari-ous State and local regulatory agencies are contacted to determine the status of the regulatory constraints that might

be imposed on the plant operation and construction noise emissions In the absence of any such constraints, US EPA’s guidelines for the protection of “Public Health and Welfare,”

as indicated in the “Levels Document” (550/9-74-004) are followed

A literature review is conducted to assist in identifying the major sources of noise of the plant and in quantifying them The search includes various professional journals, other environmental reports, and manufacturers’ publica-tions Construction schedule, equipment list, general arrange-ment drawings, project description manual, and operational parameters of major plant equipment (Forced Draft Fans, Turbine Generator, Pumps and Motors) are obtained from the appropriate sources

The facility noise levels are then evaluated and assessed in terms of existing regulations or guidelines and any potential restrictive conditions in either the working environment or the general site environment are identified

In addition, potential limitations to equipment are identi-fied as are appropriate mitigative measures

Cultural Resources

Cultural resource studies involve a review of appropriate

records, and site-related literature to identify sensitive

archaeo-logical, historical, recreational, and aesthetic resources in the

project area

Most of the information required for cultural resource

studies is available from State and Federal cultural resource

agencies and societies An on-site survey is conducted

to locate any cultural resources eligible for the National

Register of Historic Places

Project components which affect significant cultural

resources are identified and the magnitude of the impact

evaluated Mitigation alternatives are addressed If

seri-ous impacts are discovered they should be brought to the

attention of the developers promptly so that policy

deci-sions can be made at the earliest opportunity to rectify the

situation

Air Quality/Meteorology

The purpose of this program is to obtain and analyze Air

Quality/Meteorology data so that: the site can be

charac-terized; the air quality implications of the facility can be

evaluated; mitigative and control measures can be

devel-oped; and an Environmental Report and PSD application

can be prepared

The data required for the Air Quality/Meteorological

pro-gram work efforts relate to: (1) The air quality/meteorological

characterization of the existing site and region; and (2) The

facility’s atmospheric emissions and operating characteristics

Specifically, the existing site and region must be characterized

in terms of the regulated pollutant such as SO 2 , Particulates,

NOx, CO, Photochemical Oxidants, and the local

meteorol-ogy, including winds, stability, and other physical

charac-teristics In addition, the facility’s emission characteristics

including their quantity and quality must be developed so that

their impacts can be established

To establish the required data base it is necessary to

gather and update existing emission inventory information,

collate meteorological and air quality data, review present

and proposed PSD Class I and nonattainment areas, evaluate

topographic influences and monitor the region’s air quality

characteristics

The task of establishing adequate meteorological and

air quality data bases includes evaluating any existing local

meteorological and air quality data The validity of the data

and its representativeness with respect to the proposed site

must also be assessed As required, data from other sources

is evaluated as a basis for comparison with local data, or as

a supplement to local data where necessary The objective is

to establish meteorological and air quality data bases which

are most representative of the proposed site

A report should be prepared to provide technical

sup-port for a construction permit application under the PSD

provisions of the Clean Air Act of 1977 Described in

the report are the data bases, methodologies and models

utilized in the analyses The PSD report also includes

appropriate maps, summary tables and figures necessary

to display relevant information such as locations of plant sites, PSD Class I and nonattainment areas, and resultant pollutant concentrations

An atmospheric impact assessment of the proposed and alternative cooling tower types is included in the ER

Operational impacts of the tower to be considered include elevated visible plumes and deposition of cooling tower drift Computer modeling is utilized to predict the impact of these occurrences

Ground level fogging/icing is also addressed Computer modeling is utilized to predict the frequency and duration

of ground level fogging and icing for the alternative cooling towers The potential for interaction of the cooling tower and stack plumes must also be addressed

National Weather Service (NWS) data can be supplemented

by any available meteorological data to the fullest extent pos-sible to develop the estimates of cooling frequencies, and salt deposition rates are given on an area basis and include more detailed information, as necessary, for any sensitive receptors

Health Implications

The purpose of this work effort is to identify and evaluate the potential health concerns, including estimates of offsite exposures that may result from facility operation at the site

Once the concerns are identified, the need for controls and the feasibility of the gasification plant at a particular site from

a public health perspective can be evaluated Changes in coal type, process or waste treatment systems can be addressed

if needed to mitigate a potential health concern This allows and insures that alleviation of potential health problems is an integral part of the facility planning

The health implications to the offsite population are iden-tified and assessed Specific analytical measurements from pilot plant studies, available information from similar indus-trial plants, and other existing studies regarding the health implications from coal conversion processes are used The overall approach involves scaling the results of specific pilot plant runs and other study results to approximate a commer-cial size facility; applying standard air dispersion models and waste dilution criteria in order to predict exposure concen-tration; and evaluating the predicted concentration against known information on the toxicity of each contaminant

The identification of potential public health concerns requires not only the estimation of exposure levels but also the evaluation of the relative toxicity of each chemical species

Consequently, a review of the toxic properties of each iden-tified chemical substance or chemical group is required At the conclusion of this evaluation each contaminant or chemi-cal group is categorized into one of four groups—potentially significant health problems, potentially minor health problem,

no expected health problem, and those for which insufficient information is available

The results of this evaluation is then utilized to develop control systems and/or mitigative actions for the facility In addition, the results are presented in the ER and discussed in terms of a cost/benefit framework

With regard to occupational health, worker exposure to

toxic substances is a potentially serious problem which could

significantly lessen and limit the benefits of alternative fuel

technology As such, its implications must be carefully

eval-uated in the planning and design phases of this project The

Occupational Safety and Health Act (OSHA) contains basic

worker protection guidelines and specific regulations which

establish industry procedures for the protection of

work-ers from exposure to potentially toxic or health impairing

substances

However, the current regulations do not specifically

address a coal gasification process and only limited

operat-ing experience is available from existoperat-ing gasification plants

Consequently, identification of potential occupational health

problems must be done in an indirect manner through

com-parison with other industries

This occupational hazard analysis yields identification

of potential hazards, definition of possible control measures

for as many of those hazards as possible, and identification

of areas of concern where insufficient knowledge or control

methodologies exist In addition it provides input to:

1) design of worker protection programs to be

imple-mented at the plant, 2) design of engineering controls to minimize

work-er exposure to hazardous substances, for example, isolation of process steps, ventilation changes, pressure control, etc

Most of the procedural information, repeated from the

arti-cle by Quig and Granger (1983) remains valid today For a

more quantitative treatment of the effluent emissions observed

during plant operation the reader is referred to the study of Holt

(1988) on the Cool Water plant and to the current Encyclopedia

article, Coal Gasification Processes

PERMITTING FOR LANDFILL GAS ENERGY

RECOVERY

Purpose

New York State Air Guide 41 (1996) provides guidance on the

permitting of emissions from municipal solid waste landfills,

including the use of landfill gas for energy recovery, flares and,

also, passive venting, as per the following:

Background

Landfill gas (LFG) is generated by the decomposition of

wastes in all municipal solid waste landfills, regardless of

age or size The total volume of gas generated is a direct

function of the quantity of wet, decomposable refuse available;

however, the rate of gas generation can vary greatly over

time, depending on numerous factors (such as the volume

of waste, the depth of the landfill and the amount of

rain-fall the landfill receives), most of which are uncontrollable

Landfills the accept waste water treatment plant sludge for

disposal tend to generate more LFG than those that do not

LFG is not generated until the available oxygen supply has been consumed and the decomposition process becomes anaerobic The typical composition of LFG is essentially the same at all landfills and at all points within the landfill The typical composition of LFG is:

Carbon Dioxide 35–45%

Non Methane Organic Compounds 3–5%

(NMOCs) 1 LFG can, and should, be used for energy recovery The energy content of LFG comes entirely from the methane component, which has a basic heating value of 1,000 Btu/standard cubic foot (scf) Since the nominal concentration of methane in LFG

is approximately 55%, the heating value of raw LFG is approx-imately 550 Btru/scf, although this figure can, and will, vary somewhat By comparison, natural gas is composed of 95%

methane, giving it a basic heating value of 950 Btu/scf

At the majority of landfills in New York State, LFG is currently uncontrolled or passively vented to the atmosphere

Recovering and combusting such gas into useful energy will virtually eliminate harmful emissions from a fuel that is oth-erwise wasted This also prevents the pollution associated with the use of fossil fuels (i.e., SO 2 ) If LFG is not com-busted, it will still escape to the atmosphere through the path

of least resistance (diffused from landfill, vented or flared)

Federal Regulations

Air In accordance with the Clean Air Act, the U.S

Environmental Protection Agency (EPA) has proposed New Source Performance Standards (NSPS) under 40 CFR 60 Subpart WWW for municipal solid waste landfills These NSPS will affect landfills that began construction or modifi-cation after the standard was proposed (5/30/91) or existing landfills that have accepted waste since November 8, 1987

It must be noted that this proposed rule is currently being developed The rule is subject to change and it is possible that

it will not be released However, the guidelines contained in this proposed rule should be used in developing a permit for the use of landfill gas Additional information regarding this proposed rule is included in Appendix A

In a recent Federal court case in Pennsylvania (Ogden Products Inc vs New Morgan Landfill Co.), the court ruled that the landfill in question is subject to New Source Review since it has the potential to emit more than 50 tons per year

of volatile organic compounds This decision, combined with the NSPS for landfills proposed by the EPA, will make all new landfills subject to the requirements of the CAA, partic-ularly if the landfill has the potential to emit volatile organic compounds at levels exceeding air quality standards

Hazardous Waste When LFG is recovered, it tends to

cool, and some condensate is formed It is stated in Section

124 of the Superfund Amendments and Reauthorization Act

(SARA) of 1986 that if the aqueous or hydrocarbon phase

of the condensate removed from the gas recovered from

a landfill meets any of the characteristics of a hazardous

waste (i.e., it fails the TCLP test), the condensate shall be

considered hazardous waste and regulated accordingly This

section is an amendment to the Resource Conservation and

Recovery Act (RCRA), but is not part of RCRA Since this

provision of SARA is not actually part of RCRA and there

are no implementing regulations in 40 CFR, it may be

bind-ing upon EPA, but RCRA-authorized states (such as New

York) are not obligated to enforce its requirements This

issue could arise if LFG is to be recovered from a

munici-pal landfill that meets the size and NMOC criteria cited in

Appendix A and is included on the Superfund priority list of

inactive hazardous waste sites

State Regulations

Solid Waste 6 NYCRR Part 360 has requirements for the

control of LFG during both the active life of the landfill and

after the landfill is closed While the landfill is in operation,

the owner must periodically (i.e., quarterly) monitor for the

presence of LFG at or above 25% of the lower explosive limit

(LEL) at on-site structures and any off-site areas When the

landfill is closed, an LFG control system must be included

in the closure plans to prevent the migration of concentrated

LFG away from the site and to prevent damage to a landfill

cap LFG is lighter than air and will tend to rise causing the

overlying cap to rise also Generally the LFG is allowed to vent

to the atmosphere through a porous gas vent layer that leads

to gas vent risers spaced at approximately one vent per acre

Part 360-2.16 contains the regulations regarding LFG

recovery facilities These regulations require that anyone

proposing an LFG facility obtain a permit to construct and

operate the facility The application for a permit must

con-tain an engineering plan, engineering report and an

opera-tion and maintenance plan

Hazardous Waste As cited above, some LFG condensate

may exhibit hazardous waste characteristics In an October

20, 1992 declaratory ruling applying to the Freshkills Landfill,

the Department excluded landfill gas condensate from being

regulated as a hazardous waste. This ruling was based on the

grounds that the LFG was derived from a household waste and

therefore excluded from hazardous waste regulation under New

York State law However, if the landfill received both

munici-pal and industrial or hazardous waste, the condensate may be

hazardous The condensate would need to be analyzed using

the TCLP method to determine if it is a hazardous waste

Air NYSDEC’s proposed Part 201 operating permit

program (proposed to comply with the federal Clean Air

Act Amendments of 1990) contains an exemption for LFG

emissions vented directly (i.e., without a flare or energy

recovery device) to the atmosphere that fall beneath major

source thresholds as long as the facility is operating in

compliance with 6 NYCRR Part 360 Such an exemption

will not apply to landfills subject to NSPS or National

Emissions Standards for Hazardous Air Pollutants

A number of landfills in New York State currently use flares or energy recovery for control of their LFG These emission sources must have a permit from the Division of Air Resources These permits are issued under 6 NYCRR Part 201 All energy recovery projects produce NOx in the combustion of the LFG These projects must control NOx emissions as required under Part 227-2 For example, if a lean burn internal combustion engine running on LFG is used for energy recovery, the emission limit for NOx is 9.0 grams/brake horse power-hour (Part 227-2.4(f))

LFG recovery projects would be affected by either Prevention of Significant Deterioration (PSD) or New Source Review in Nonattainment Areas (Part 231) regu-lations depending on the location of the project Projects

in nonattainment areas are likely to be affected by NOx and CO requirements (Note: the entire state is nonattain-ment for VOC and NOx because the state is in the ozone transport region) This is because recovering energy with a combustion unit will create NOx and CO that often require emission offsets to be obtain and the installation of Lowest Achievable Emission Rate (LAER) technology

The EPA has issued interim guidance stating that sources may be exempt from New Source Review (NSR) provided that the project is environmentally beneficial and there are

no adverse air quality impacts This exemption from NSR is referred to as a pollution control project The EPA presently expects to complete rulemaking on an exclusion from major NSR for pollution control projects by mid 1996 However, in the case of nonattainment areas, EPA believes that the state

or the source must provide offsetting emission reductions for any significant increase in a non-attainment pollutant from a pollution control project

Presently, 6NYCRR Part 231 allows a Pollution con-trol project exemption only at existing electric utility steam generating units (
25 megawatts of electrical output)

Consequently, LFG projects which exceed the applicability thresholds, would have to obtain NOx offsets at a ratio of 1.3

or 1.15 to 1, depending on the location of the project (i.e., in

a severe non-attainment area or in a moderate non-attainment area), and would be required to install LAER technology

Please note that this may change if the EPA determines that this type of project is eligible to become a pollution control project

Approach to Permitting—DAR

When the economics of an energy recovery project using LFG are favorable, these projects are to be encouraged The following is the hierarchy of preferred LFG uses:

1 Gas cleaning and upgrade to pipeline quality gas;

2 Energy recovery with gas pretreatment or conver-sion to a reusable chemical product;

3 Energy recovery without gas pretreatment;

4 Flares with high combustion efficiency (i.e., 98%

or greater);

5 Vents, if no economically feasible use for the gas

is available

The following procedure will be used for permitting of

energy recovery facilities that utilize LFG:

If the LFG Is Pretreated (i.e., if the constituents other

than methane are removed from the gas), then permit as

a combustion source with no further emission testing or

ambient modeling necessary to satisfy toxic concerns The

permit should address traditional combustion contaminants

such as NOx and CO However, the permit application for

this type of option must include a detailed description of

the method(s) to be used for gas pretreatment LFG can

contain up to 50%, by volume, CO 2 (35–45%) and air

toxics (1–2%) The pretreatment employed must remove

these compounds before the LFG can be permitted for just

the traditional combustion contaminants Note that gas

pretreatment will minimize toxic products of incomplete

combustion and minimize system corrosion

If the LFG Is Not Pretreated, then permit as a

combus-tion source and use the total concentracombus-tion of NMOC

emit-ted to address toxic issues Note that if the gas is burned,

either by a flare or energy recovery process, generally the

air toxics will be destroyed It will be easier and more

effi-cient to regulate the NMOC (or total VOCs) than trying to

identify and regulate all contaminants of LFG emissions,

since they can vary greatly depending on the waste

dis-posed at the landfill The permit should address traditional

combustion contaminants such as NOx and CO The EPA

proposed standard of 20 ppmvd NMOC should be used as

BACT for the control of untreated LFG used as a

combus-tion source Periodic stack testing of the emissions is

rec-ommended at the discretion of the permit writer

With regard to compliance with Part 231, the LFG

facility may need to obtain NOx and CO offsets at the

ratio applicable to its location (i.e., 1.3 or 1.15 to 1) This

requirement may change if the EPA decides that LFG-type

facilities are eligible for a pollution prevention exclusion

The permit reviewer will need to exercise judgment to

determine if the LFG facility is required to obtain these

offsets As stated above, an LFG facility can be used for

energy recovery While a combustion turbine or internal

combustion engine is not normally considered add-on

pol-lution control devises, they do serve the same function as a

flare, namely to reduce VOC emissions at the landfill with

the incidental benefit of producing useful energy (energy

that would otherwise be produced using higher polluting

fossil fuels) For an LFG facility the reviewer should

pro-ceed as follows:

1 Verify that the NOx increase has been minimized

to the extent practicable;

2 Confirm (through modeling or other appropriate

means) that the actual significant increase in NOx emissions will not violate the applicable NAAQS, PSD increment or adversely impact any air qual-ity related value;

3 Apply all otherwise applicable SIP and minor source

and permitting requirements and ensure that NO x offsets are provided in an area in which nonattain-ment review applies to NOx emissions increases

Coordination within the Department

The use of LFG will require coordination of efforts between the Divisions of Air Resources (DAR) and Solid and Hazardous Materials (DSHM) If a landfill meets the criteria cited above and the emissions from the site must

be controlled, the proposed plan for this control should

be submitted to both Divisions DSHM should focus their review of the proposal, based on the requirements of Part 360-2.16 DAR should focus their review on evaluating and permitting the combustion sources that utilize the LFG, as outlined in the previous section Both Divisions must keep

in mind that LFG can be a valuable resource for energy generation and that using this resource will conserve the use of other fossil fuels and permit the re-use of material otherwise considered waste Further, the respective project managers handling a particular facility’s permit applica-tion should maintain communicaapplica-tion to ensure that there are no unnecessary delays on developing a permit for an LFG facility

APPENDIX A OF AIRGUIDE 41

NSPS for Municipal Solid Waste Landfills

In accordance with the Clean Air Act, the U.S Environmental Protection Agency (EPA) has proposed New Source Performance Standards (NSPS) under 40 CFR 60 Subpart WWW for municipal solid waste landfills These proposed NSPS will affect landfills that began construction or modi-fication after the standard was proposed (5/30/91) or exist-ing landfills that have accepted waste since November 8,

1987 It must be noted that this proposed rule is currently being developed This proposed rule would require landfills

to install active gas collection and control systems if they exceed both of the following criteria:

• design capacity in excess of 2.500,000 Mg (2,700,000 tons); and

• NMOC emission rate in excess of 50 Mg per year (50.05 tpy)

Landfills closed prior to November 8, 1987 or having design capacities less than 2.5 million metric tons will be exempt once this rule is finalized

The NMOC emission rate is determined by the following equation:

M NMOC = 2 L 0 R (1e– kt ) C NMOC (3.595  10– 9 ) where,

M NMOC = mass emission rate for NMOC, Mg/yr

L 0 = refuse methane generation potential, m 3 /Mg refuse (default value = 170 m 3 /Mg)

R = average annual acceptance rate, Mg/yr

k = methane generation rate constant, 1/yr

(default value = 0.05/yr)

t = age of the land fill in years