1
III
ENHANCING THE USE OF EASTERN AND MIDWESTERN COALS BY GAS REBURNING-SORBENT INJECTION
ENVIRONMENTAL MONITORING for Illinois Power Hennepin
PLAN Unit 1
Submitted Energy and Environmental Irvine. California 18 Mason
by Research Corporation
92718
October
1989
CONTENTS 1.0 SUMMARY ........................................................ INTRODUCTION 2.1 Process Background EMP Purpose Overall Material Emissions Purpose Current Construction Operation Post-Operation Permits Schedules Purpose Phase Phase Phase I: II: III: ................................................... Technology ....................................... of Project ........................ .................................... ...................................... ......................................... ................................. .......................................... ........................................ Requirements .......................... ......................................... ............................................. ................................................ ........................................... ................................................ ........................................ ........................................ ............................... .................................. .................................... and Scope .................................................. and History and Scope
l-l
2-1
2.0
2.2 2.3 3.0 3.1 3.2 3.3 4.0 4.1
4.2
2-1 2-1 2-3 3-1 3-1 3-4 3-4 4-1 4-1 4-1 4-5 4-5 4-5 4-6 4-6 4-a 5-l 5-l 5-l 5-4 5-4 5-17 5-17
PROJECT DESCRIPTION Storage
............................................
Description
and Discharges and Scope Monitoring
COMPLIANCE MONITORING
4.3 4.4 4.5 4.6 4.7 4.0 5.0
5.1
Pre-Construction
SUPPLEMENTAL MONITORING
5.2 5.3 5.4 5.5 5.6 6.0
6.1
Pre-Construction Construction Operation
Post-Operation Schedules Purpose Current GR-SI Purpose Sampling Sample Calibration Analytical Data Reduction
........................................... ................................................ .................. at IP Hennepin Stat ....... . ............... ............... on ............
HEALTH AND SAFETY MONITORING and Scope Safety Health
6-l 6-l 6-l
........................ Monitoring
6.2 6.3
7.0 7.1
Program and Safety
DUALITY
ASSURANCE AND CONTROL .................. and Scope Procedures Custody Procedures Procedures ........................................ ...................................... and Frequency
............... ...............
6-2 7-l
7-1 7-1 7-1
7.2 7.3 7.4 7.5 7.6
........................................... ..................... .................................... ............................
7-2 7-2
7-2
and Validation
i
7.7
Internal Performance Preventive Calculation Corrective Duality Purpose Reporting Monitoring A Permit
Duality
Control
Checks Audits
.......................... ............................
7-6 7-7 7-9 7-9 7-12 ............... 7-15 8-l
7.8
7.9 7.10 7.11 7.12 8.0
and System Maintenance of Action Data of
................................... Quality Outside Indicators Organizations ...................
........................................ .................................. ...................................
Assurance and Scope Data
DATA MANAGEMENT AND REPORTING
8.1 a.2
0.3 APPENDIX
........................................
Requirements Review
...................................
8-l a-3 a-4
Operating
NPDES Permit
ii
TABLES
l-l
l-2 4-l
Project Project Hennepin Discharge
Monitoring Monitoring Unit Streams
in in
Phases Phase Permit
I and III in
II
.......................... Requirements NPDES Permit ......................... ......... ..........
1-2 l-4
................................ Monitoring Hennepin Plan
1 Current Emissions
4-3
4-4
4-2 5-l 5-2 5-3 5-4 5-5 5-6 6-l 7-1 7-2 7-3 7-4 7-5
Designated Characterization
Supplemental Solid Continuous
Monitoring
5-2
5-5 5-10
By-Product
.............................. Discharges
Analyzers
........................................... Plan for Aqueous ..........................................
Supplemental Monitoring and Solid By-Products Aqueous Effluent Illinois Worker Calibration Continuous Preventive Critical Program Monitoring Streams General Health
5-13 and 5-14 ................... 5-15 .......................
for Ash Pond Influent ............................................... Use Water Duality Monitoring Plan
Standards
and Safety Procedures
6-5
7-3
......................................... Instruments Procedures Critical ................................ .............................. Measurement Plan ...............
Analysis Maintenance Spare Objectives Parts
7-4
7-10 7-11 7-13
........................................... for
FIGURES
3-1 3-2
5-l
Application for NOxlSOx
of Gas Reburning-Sorbent Injection Control ............................................ During
3-2 3-5 5-7 5-8 7-5 7-14 8-2
Process Flow Diagram for GR-SI Operation Full Load Output ............................................... Continuous Phase Data Data Monitor Sampling Probe and Validation Procedure System Flow Train Discrimination Reduction Action Management
..............................
5-2
7-l
..................................... .................................. .................................... Diagram ............................
7-2
B-l
Corrective
111
.
/
/
Iii
1.0 Energy demonstration fired of utility Department Energy demonstrate realized process. a dedicated prerequisite This at Illinois demonstration cooperative will project. Act health develop to the specific impacts be demonstration
SUMMARY and Environmental to the percent generation pond. evaluate Funding Resources. SOz control of the will Successful Gas Research for the The Corporation project objective and 60 is of percent fly the (EER) being this is conducting for coalby is can (GR-SI) to is a the to be a
project boilers. of and that through Bottom settling to volume Power sites agreement conducted project. since at eventual Energy, Natural 50 ash
an SO2 and NOx control Institute, and the
technology provided project Injection ash will of the GR-SI Plan one of is course a key Illinois NOx control
Gas Research
Department
application
Reburning-Sorbent and of demonstration
be reduced application
be sluiced technology
commercial the
process. (EMP) three required monitoring of aspect not be the of result to used related of sitefor by Unit EER's that GR-SI this Policy in human to 1
presents Company's in the with
Environmental (IP) Hennepin describes Station supplement the standards, of potential of the The
Monitoring Station, the during EMP. which
technology
EER project. DOE,
environmental the is National project or 2) are will
Hennepin will that applicable mitigation for replication
Environmental ensure
monitoring the demonstration monitoring
monitoring to 1) violate for and
Environmental does also detrimental problems independent
documentation which or the a data technology parameters. Monitoring
environment. base
Environmental
environmental technology
will discharges, for
be conducted and other with about
to
characterize and State, GR-SI health
air and
emissions. concerns. local which possible. are
water Monitoring
and are
solid
waste
safety Federal, monitoring the
requirements discussed, to will ment this provide utilize methods volume. Monitoring planning compliance and and
compliance with information which
regulations are IP and described
along further
supplemental EPA measurement no standard
requirements system are whenever available
designed EER in Measure-
performance.
standard for
procedures procedures
is design.
required construction,
during monitoring
all and
three operation. which
phases
of
the
demonstration: summarizes Phase the I and
Table
l-l
supplemental
was conducted
during
l-l
mmmm ECE:T .r .r .r .P+wc, yIv)u)w
.C
‘2 ‘S ‘Z ‘2 Q)aaJal
x r;
.C ::
z s
-he. NNN YYU
1-2
will
be conducted are operation will
during expected will during remain will the that a data Supplemental
Phase to
II
of
the
demonstration the will The same provide parameters I and as
project. current baseline listed Compliance II. major objectives: in
Compliance monitoring data against Table monitoring Supplemental l-2
measurements requirements. which will GR-SI be
remain
measurements be evaluated. Phase the same III. as in
monitored requirements evaluate ensure create compliance to of to U.S. with Statimrv quality Assurance their the
operation. Phases three toward
requirements monitoring . . . The according requirements Duality according in of the
be focused
project's the project for base
success is safe for employees and the environment GR-SI will technology be conducted Protection measurements custody procedures Air Pollution EPA-600/4-77-027b, data will checks are achieved. of will the selected be data input in and all reports potential compliance been procedures by which Agency has will Illinois satisfy (IEPA). been in prepared Section Svstm August be conducted by the This test during may tests. to a of noted 1977. by 3 be followed Power the A
measurements quality Illinois for the of . Specific for will plan EPA's
assurance Environmental supplemental Sample custody for the with be taken goals
procedures.
EPA guidelines. chain AssuranceHandbook Source control Assurance checks Officer action assurance of quality configured formats. derived has to
accordance Qualitv III
as recorded
Volume Internal EER's audits involve
Metho&.
supplemental independent if or
Duality or the
supervisor.
Corrective quality recalculation
deficiencies not repetition data
have
measurements been store, EER will will verified, process. submit on also the emphasis
Once computer of
data
the
system
and output quarterly data copies
a variety
operator-selected data areas. submitted plant's .Data will This data
and annual summaries of period.
environmental problem reports of the
to
DOE with reports status.
These permit be
contain reporting
by IP to
IEPA during
and a description
reviewed results
by will or
EER and be verified to in all
IP
as and
it
becomes appropriate
available. action the EER and taken
Data if addition IP will
showing required. of review
significant
may include parameter,
modification change throughout
monitoring of the
frequency, location. demonstration
a monitoring
monitoring phases
continuously
project.
l-3
1
;
I i
; :
G:rE h... .-aJ)o)al w-U”“rnECCrl T)ooo8 2
: .
A ; : I ==Z.==: c)c(.W+lc(+ .r v .r cn*v)lnv)v I L&EEEE c .r .r .r
.r I
.r I .r
.r I .r
:: .r -
; ; ; I : I
-A^ mmm VVY
VI 2 2 .r h-grnOOO --u-r
s -
LLL ,h,h,h i328 Eg&
” : E
A Monitoring capacity from data for project will and formats. members Certain EER. DOE. the review
Review funding meet at
Committee participants. least on once
will
be established will and its to ongoing that: and the
to comprise
act
in host
an advisory utilities. will include tasks or
monitoring.
The Committee per year,
representatives
demonstration functions
The Committee reporting information.
recommendations Based of the the
for
modifications can recommend
monitoring review of
Committee's
monitoring
Committee tasks techniques quarterly project
(1) (2) (3)
If
monitoring of the
be discontinued, or instrumentation and annual management changes at
modified reports DOE and
or
added: or
New analytical The format are the
be substituted: be changed. EER will
recommendations to
made.
consider
modification
EMP and authorize
as appropriate.
l-6
2.0 Energy demonstration Technology control switching involves will range of be of
INTRODUCTION and program. technology or the other for Environmental as The costly of on coal-fired the Resources. of of this this and section history presents of the a description of project, the GR-SI and the part project pollution gas three full boilers. Gas Research Research of is the utility control with scale reburning Corporation Department to boilers of that sorbent is (EER) demonstrate does injection boilers being and the is an not This conducting Clean SO2 and require CGR-SI). representing co-funded by Illinois technology and the the Coal NOx coal a
project
Energy's
designed
coal-fired
alternatives. utility
combination
demonstrated pre-NSPS of and Energy, Natural
The project Institute,
Department Energy The process, purpose and
Department
remainder the scope
background
demonstration
document.
Gas release reburning hydrocarbon react of into this the in
reburning to is the effective radical fuel-rich furnace. of to
involves produce in species zone, The the
introduction reduction with NO to air injection in which and atmosphere of
of slightly form to
natural
gas
above by the At the
the
main zone.
heat Gas of which end
zone
a homogeneous,
oxygen-deficient nitrogenous intermediates
NOx emissions produce Nz.
reaction
oxygen-deficient sorbent step, CaO. is control and
downstream are injected as a sequential calcines where the sulfate. ash
burnout
calcium-based process the can calcium-based sulfation to form with along
sorbent be viewed step, solid the coal sorbent
coupling dehydrates reacts plant 2.2
an activation produce gas-phase sulfate
or CaO
and
a heterogeneous oxygen removed
with
SOz/SOs
and excess
calcium fly
The calcium
subsequently equipment. &storv
by the
particulate
of
Prolect conducted range of by EER will pre-NSPS Station, boiler Unit focus on three
The technical Illinois . utility Central (net).
demonstration boilers Illinois front wall representing Light fired.
project the
technology: 1: 117 MWe
Company.
Edwards
2-1
. .
Illinois tangentially City (net).
Power Water, cyclone
Company, and
Hennepin Power,
Station, Lakeside
Unit Station,
1:
71 MWe (net). Unit 7; 33 MWe
fired. Light fired. comprises net generating is in percent Power being Preliminary emission of the Hennepin 67.6 two coal-fired of County, 300 steam MWe. Illinois. Station electric Unit fired 1, steam This is generating which unit owned will had a electric and
Hennepin units host facility capacity operated with the GR-SI located factor by the The project and permitting. determine construction the GR-SI
Station
a total
capacity Putnam in (IP). three were discharge system. its of
demonstration. near of Illinois is
a 71 MWe tangentially
1986.
Hennepin
Company in
conducted tests and GR-SI
phases. conducted levels. Phase
Phase during
I includes
this
design phase to of includes
current system and
Phase
II
and startup
III
involves control were being isothermal
operation potential. monitored used flow will in
demonstration has data been
NOxlSOz Air These of
emission emissions data are
Phase boiler system and information During metric. baseline operating against parametric range emissions sorbents information boiler performance and and design
I testing
and about Phase long-term of
completed. recorded.
and GR-SI models
performance thermal
were
providing worker safety testing testing. the The is to
verification computer models. during will First, boiler results will conditions performance, as well. of The injection control. evaluate the of the occur
physical Phase
performance
II
monitoring process. stages: be conducted under will a range provide The over in the
provide
construction in three will GR-SI) tests evaluated. performance resulting and cost. long-term equipment requirements
III.
baseline, to of the
paraestablish selected baseline of operating the of and on
tests these be
performance conditions. which to will GR-SI determine be on the performance. in terms testing reductions,
(without
performance
objective a wide best
system
balance coals will impacts provide
boiler evaluated reliability including of emission
Alternate evaluation and long-term and overall
maintenance
system
2-2
2.3 This IP's the and requirement monitoring operation
LMJ! Puroose document Station, for of of required purposes. Environmental special the is
and Saw? the Environmental in Monitoring with Plan the factors supplemental (EMP) cooperative during site, both for Unit 1 at of
Hennepin
submitted reports. GR-SI by system
accordance
agreement construction compliance for
The EMP provides and health at the permits related and demonstration
a detailed
description
environmental
monitoring research
environmental
monitoring
monitoring to of goals
will determine
be one of the NOX emissions Boiler met. also In and will operating
the
key of without
methods this will
used
by EER and The impacting to be and will Water basis. goal
the is other
funding to effect boiler if
participants control performance project boiler discharge will following
success
project. adversely measurements on a regular operation. of sorbent project and the
SO.? and parameters. have streams to
emissions addition,
be monitored
determine made to solid
been
monitor
performance
characteristics. system
by-product
be monitored GR-SI detailed
Measurements The process process atmospheric monitoring compliance Supplemental required methods discusses health lists sample and the
be made prior section impacts and are currently during or to Section and including for state conduct that will 7. is on
and during a more
provides ancillary in by-product given all required described
description including The Section Station
the goals
GR-SI for the
and
its
systems. disposal. Section at in the of Section 3.3. the This supplemental to Hennepin 5.
storage,
discharges, emission which monitoring monitoring, by any EER will the safety. sampling procedures permit use
4 describes anticipated
phases regulation.
GR-SI is
demonstration monitoring also protection Plan will Section be for the used to monitoring. that
project. is not the 6 worker ensure the describes Section of project,
section ensure
monitoring
be conducted the Duality procedures and data
Assurance which data
analytical audits monitoring
integrity.
OC checks. and the
8 describes format.
management
reporting
2-3
3.0
PROJECT DESCRIPTION DveralLQe5crioti~ Several technologies coal-fired wall-, practices. species strategy. two technologies: boiler of the Since the boiler. for reburning sorbent GR-SI in in-situ the for in-furnace or NOx control convective Figure when applied pass 3-1 to and two are power technology GR-SI and, available plants. which to is reduce generally boilers the is emissions of SO2 and to both be an NOx (GRa wide
from SI) range of acid acid
pulverized is of rain rain cyclone-,
Gas Reburning-Sorbent applicable that are of to
Injection characteristic
a retrofittable design precursor control
and tangential-fired reduces therefore,
pre-NSPS
emissions expected
suspected effective
GR-SI and the of a presents due spatial processes 3.1.1 to
combines of
injection pulverized a simplified capture zones
a calcium-based schematic
furnace process
coal-fired boiler. by within
SO2 removal. by reburning
combined occur in
a tangential-fired
NOx reduction sorbents it is
and SO2 reduction thermal the consider
calcium-based
different to
convenient
separately.
The concept decade. . The overall Main the operate
of
reburning process Release heat under input
for can
NOx control be divided - In this to the boiler fuel-lean into
has
been
recognized zones. namely:
for
over
a
three
Heat total
zone. is
approximately released. and do
80 percent The coal not burners require
of
overall
conditions
modification. . Reburnina natural of heat radicals This the gas total release in Zo~.e is heat zone the by reduced The input. to main the create heat partial reburning and It is zone for injected zone oxidation is the region of of zone. with the reburning intermediates, where the the main NO
injected.
accounts a fuel-rich release
a maximum downstream reburning reacts of reaction
20 percent The fuel.
produced
hydrocarbon
formed produces
nitrogen-containing
3-1
SECONDARY ,;;\
SORBENT
mCOAL-
REBURNINGZONE WIN HEAT RELEASE ZONE
FUfMCE AIR PREHEATER
Figure
3-l.
Application of Gas Reburning-Sorbent For NO,/SO, Control
Injection
3-2
such form
as
amines
and
cyano path
compounds, which can
which
may further by:
react
to
Nz by a reaction CH + NO + HCN + OH + NHi + OH * NH1 + NO +
be summarized
HCN + 0 NH1 + COZ NZ + NO + Hz0 NZ + Hz0 burnout fuel-lean reburning either reburning is the zone gas. to zone maximized. is the region and Nz. where ensure reduced The burnout fuel zone air is added
.
mnout to create oxidation species adjusted
&be of are that t Iniectim
- The overall the in converted
conditions NO or
complete nitrogen and are air so
Remaining and the
stoichiometries
Nz formation .
3.1.2 The use of has of lime, sulfation the utilization . The is is been studied a calcium-based producing zone
calcium-based extensively. sorbent. calcium oxide. solid calcium of of Reactivity is
sorbents which may This calcium in the the the
with be
furnace involves either oxide
injection calcination a carbonate reacts
for or or with parameters
SO2 control dehydration a hydrated SOt in the control
The process
calcium sulfate. sorbent: oxide the to to calcine equilibrium below active sulfur and
producing of the
Two major
reactivity strongly a function
calcium upon sorbent tends due the and negligible the the
formed area as growth. underitions and the
bv calcinatinr! of thermal the the calcine history sorbent
- This which of particle the
dependent
surface type grain decrease
calcine. temperature
.
increased time of time of rate of in
Jhe
residg%s because
.
&Ucive
sulfatlon 2250°F of the sulfation
- Significant becomes important unreacted
sulfation
cannot
occur limitations,
above
approximately and 1600°F. the rate Thus.
approximately within process. ash are this
residence is
particle capture coal fly
temperature
window The gas calcium stream sulfate, prior to
sorbent,
removed
from
the
the
stack
by an electrostatic
precipitator.
3-3
3.1.3 As was means results the coal Thus, levels heat of in described
rnlna in
for
SO2 Control Section level in the 3.1.2. than sorbent gas reburning process fuel available process applying injection with sorbent by the coal. for since is sorbent injection This baseline the primary injection alone. of reduced SO2
SO2 control. a lower of which the is natural
However. SO2 offgas gas of would amount
combining
The combustion input use reduces SO2 control are
reburning be supplied in the
replaces
20 percent SO2 formation.
otherwise sulfur by the
enhanced
reburning
reduced. and IP's 3-2. sorbent Hennepin The remaining streams injection Station. from are discussion the plant being A flow in combined diagram this during for for section GR-SI NOx and the system describes operation. SO2 is
Gas reburning control shown material 3.2 Materials are tests provisions percent the Coal 3.3 A coal-fired and output spent flow to output fuel streams sorbent. rates handle for the these streams. (coal include and bottom include for furnace the sorbent. will be for natural by plant in in Unit Figure storage 1 of
and discharge al
Mami
Storaw
will gas, The and firing be utilized and lime, sorbent unloading. capability. There currently are stored in coal. with will during The lime the or GR-SI used limestone in gas storage coal a silo is Station demonstration in the majority tested appropriate has directly for 100 to gas. with currently provided requirements pile. being project of the for
that natural purposes. loading gas is pipeline.
sorbent be stored Hennepin Natural
hydrated
comparative
no on-site
an on-site
boiler The and bottom ash
incorporating main inputs gas). combustion These 1 in fly Figure ash natural gaseous ash. Unit and
the to and
GR-SI the sorbent
process system. for fly are shown to is not ash
contains as described SO2 capture. ash which with GR-SI in pond.
many
input above, Major the is in the
products, streams 3-2. will GR-SI to the
includes corresponding system
Hennepin materials. ash will
When the
operation. bottom
be sluiced system existing
a new pond operation,
designed
When the be sluiced
ash and fly
3-4
L
!
3-5
3.3.1 At demonstration percent. 4.88 percent regulations from and lb/106 process, trigger 3.3.2 Fly water will pH will Pipe if conditions required, water. pond. on the laden disposal material required to ash from a newly for turbulence for the will The pipe through Hennepin is expected GR-SI Btu (48 but lb/lOs Btu Hennepin. project The current (3758 NOX control. reduction if and Unit to lb/hr the
.
.
.
and emission reduce rate
Cu control the load). to 0.69 the existing from Hennepin The utility Btu Btu to GR-SI in constraint The current lb/106 (534 (217 increase any lb/hr emission due limit strategy 502 emission Unit 1 is will this to at at to rate which for system for the level GR-SI by 50 60 thus rain rate load) load) of the 0.062 GR-SI might
the is lb/hr There could when 1 is be at increase of the
SO2 to at is
SO2 emission full
approximately provide unit, acid full full
no NOx emission are to load) promulgated. 0.28 is Air lb/lOs expected to Act. be
NOx emission
be useful
response lblhr
they reduced full is
NOx emission
approximately
implementation.
The baseline expected
particulate below
requirements
Clean
s Dlscharaes the GR-SI
and Contcnl process on-site to for of will the total time in be sluiced by mixing will in preventing be disposed pond. suspended acid available lowering a chemical with the the build-up into pH. Illinois by sluicing Effluent River. solids. the will the from Treatment discharge provide Treatment polymer fly of into ash to for the the ash with the will piping. adequate TSS. ashnew pond be for
constructed and then by and
disposal
be treated
discharged injection
pH and may be required the residence
Treatment
be provided
sulfuric
H2SO4 to bottom will walls.
be effective ash aid
be accomplished This
cementitious
3-6
4.0
COMPLIANCE MONITORING
EER has project requirements analysis, Station, result monitoring of to
evaluated aid of DOE the that project. in in
the National the
potential
environmental the necessary Policy Information are both this expected
risks Act.
associated to results for and IP The Volume
with of
this this as a
preparing
documentation
satisfy Hennepin
Environmental Environmental effects Nevertheless. to is verify that of of the
documented indicate this will
no adverse
on the
environment supplemental
compliance
be required monitoring for operation regulations. new. the Act. of
conclusion. monitoring are though some required specified are in by State permits
Compliance regulatory obtained imposed In required of meet result specifically definition no significant which is to discharge The at operation, IP (IEPAI facility water permit. requirements requirements 4.2 IEPA emission has source to of the the in by IP
environmental these obligations facility,
obligations. by general general. to Clean meet Air
Most
requirements
modified Certain Significant net addition in trigger required
or
reconstructed modified in air emissions.
sources sources (PSD) control upon
of are
air also
emissions required if from (e)(5)]. of
are to they the and GR-SI
New Source
Performance new or
Standards
(NSPSI
developed
as part
Prevention a significant exempt
Deterioration of pollution is expected
requirements equipment initiation
increase that
However.
EPA regulations
a modification increase would
may trigger
NSPS C40 CFR 60.14
emissions PSD. by the from as well section and of the will this
currently water will remainder implement
Illinois Hennepin
Environmental Unit minor. the project. 1.
Protection Modifications New permits to the existing compliance for existing
Agency to the air a new
monitor
discharges GR-SI of phases
be relatively
be required Station
as modifications describes the anticipated
monitoring monitoring
Hennepin all
during
demonstration
issued and
permits a water
to
IP for discharge
operating source.
Hennepin
Unit
1 as
an air
Compliance
monitoring
4-l
/
/Ii
requirements which will The monitoring been emission submittal copy of the
for
both
permits by this source and SDz. is reports daily
are
summarized
in
Table
4-l
for
the
discharges
be affected air emission for is permit met is quarterly
project. operating reporting The monitoring coal showing in Appendix by issued lists in in the Table pond project water sampling. daily A. the the permit 4-2. will is for pH. this month. the National and enforced monitoring from with It is require The only ash in pond 005 is the Pollution by plant. seven anticipated modification existing discharge, flow includes solids. to The effluent suspended required to Appendix IEPA. Discharge IEPA's Water and are the the permit requirements. requirement The coal usage establishes to reporting and emission verify that limits, limit has this is A
requirements limit of
An emission
established
requirement composition.
provided are (NPDESI The
Water Elimination Pollution allowable three discharge discharge existing which 005. Monitoring determinations monitoring monthly discharge copy of the is
discharges System Division. discharge
regulated permit, for all listed
NPDES permit described are constructed GR-SI
requirements There contributing that of
levels outfalls These
discharges
discharge streams. from
the
newly
NPDES permit, may be affected This discharge required of of reports current oil expected the with by and
creating by the would the grease the to have discharge
a new discharge. experience NPDES permit flow twice of similar rate, per a decrease
discharge number rate. weekly and submit new a
discharge and total IP monitoring
results
requirements.
A contains
NPDES permit. concerning Air Pollution at the standard Pollution property Division. non-attainment emission by IEPA. control fugitive Rules and emissions Regulations. require Further, area shall Hennepin program must be These boundary. are that ensure operated Station is not listed and are no that is in Part
Illinois 212. through emissions a particulate source emissions attainment of subpart IEPA's
regulations K of Air ambient possible control area: the
enforced visible within every an an in under
be observable
operations
fugitive program thus.
particulate approved emissions
a fugitive
required.
4-2
TABLE 4-1.
HENNEPIN UNIT
1 CURRENT PERMIT MONITORING
REDUIREMENTS
I
MEASUREMENT
SAMPLE TYPE
FREDUENCY
LOCATION
Coal composition sulfur. ash, Btu. moisture
24 hr
composite
Daily
Coal
hoppers
WDES Flow
PERMIlI Rate Single reading estimate Grab 24 hr Grab sample composite sample Oncelwk Once/wk Oncelwk Twice/m0 Existing discharge Existing discharge Existing discharge Existing discharae ash pond
PH Total Suspended Solids Oil and Grease
ash pond ash ash pond pond
4-3
II
TABLE 4-2.
DISCHARGE STREAMS DESIGNATED
IN HENNEPIN
NPDES PERMIT
DISCHARGE NUMBER 001
DISCHARGE NAME Condenser Boiler Intake Roof cooling water
001(a)
001(b)
blowdown screen drain backwash discharge #2 and #4 discharge #3 discharge metal cleaning sytem effluent waste
001(C) 003 005
005(a)
Ash lagoon Ash lagoon Chemical treatment
4-4
4.3
Pre-Con5tructioJ.l Hennepin Station I. In of effect of later all Unit Phase the although I. 1 continues EER conducted plant. current during monitoring of the phases These Phase I will program. monitoring and be to operate supplemental measurements required are being available under existing tests were by the for to not air permits assess taken by IP the for as
during operating compliance permits required. test 4.4
Phase
condition purposes, remain in from Records
and NPDES with
conducted
comparison
results
Construction The monitoring during described required Phase in by will Table IEPA remain 4-1. permits the for same as air the emissions current and water
discharges requirements.
II
monitoring
4.5
QDerati on
Additional compliance from the be total measurement requirements the newly required and for NPDES permit from to pH. of will monitoring new ash require constructed for the solids. sample the type existing new pond will be imposed due The oil pond and during to the the near monitoring grease to be the levels. same as as listed test the program new pond. of which measurement the is of The the in
for
the
discharge
and for modification pond.
groundwater
The current discharge anticipated flowrate. frequency monitoring Table 4-l.
addition
discharge and are ash expected
includes
suspended
discharge.
Compliance water from the new ash temperature, calcium, groundwater baseline quarterly until and pond.
monitoring monitoring The total parameters dissolved should of bi-monthly completion
for wells to
groundwater placed be measured sulfate. (TDSI. one the GR-SI round first
will are The prior six
include and pH. boron. to months
grab
sampling from oxygen
of the (DO).
upgradient
downgradient dissolved manganese, for of operation
conductivity. monitoring results.
elevation, solids be for the
magnesium, compliance to obtain and
frequency
operation,
demonstration.
4-5
4.6
Post-Ooeration When the GR-SI which GR-SI to monitoring system for is the demonstration was system of not installed remains in the is for intact, If quarterly will quarterly and post-closure complete. the GR-SI IP IP IP may has the or to operate of to of choice having the operate unit with of it keeping removed. with or GR-SI wells wells is
the If
equipment the system the
system chooses monitoring continue
equipment use the
without
operation. pond discharge
and continue and weekly If will the GR-SI continue
new ash pond. operated. closure
monitoring groundwater
be requirements. period, which
monitoring GR-SI
approximately 4.7
one year. Permits
The only air emission addition boiler for demonstration as the to the ments
permits source project of and
governing operating will
plant permits,
operation both modification a construction for discussed for
currently issued of by these permit disposal below. of requiring the GR-SI type, nature raw operating of application
are IEPA.
the permits
NPDES and The GR-SI as well Require-
necessitate including permits by silo, to permit. are IEPA permit
others,
for
modifications pond.
a construction
an ash
new and modified is is required case the
A permit source. vent. permit. require information and source quantities other data must of to a In this which The
construction for source, for permit including on the sorbent
any
new will
emission have also contain emission expected and a
constructed emission boiler Each equipment, information description the
storage, system
considered modifications the provided. the operating made boiler of In the some to in
a new
a construction will efficiency, the must size. of
construction about be In controlled quantify
proposed addition.
specifications.
including and uncontrolled entire permit any The cases, operation, startup the
materials,
emissions,
procedures.
process. must be reviewed source. a modification for procedures construction this and to and and revised the the GR-SI boiler modification expected operating permits by IEPA when system will must operating are operating
The existing modifications cause permit contain characteristics. changes will be details are
emission application
Since
required.
permit
4-6
issued the
jointly
if
IEPA phase.
perceives
no complications
or
unexpected
problems
in
construction IEPA requires The
a permit application
for
construction must contain: criteria and
of
any
new wastewater
treatment
facility.
permit
1)
2) 3) 4) 51 61 IEPA IP as also
site
assessment
and selection study plans
hydrogeological engineering characterization impacts updated requires to has The for to water the require oil quality permit of for of the of which structural The of joint the an of effluent water an
construction of flow NPDES
specifications
new discharge on receiving diagram permit which for for or operation process would this which require permit permit. be groundwater is of any affects modification essentially The monitored NPDES for new the facility discharge. for the permit pH. wells total for a new same is or waters
modification currently that discharge. expected suspended various
an existing information new facility that and related application
facility required the grease, new
NPDES permit
construction discharge and the
solids.
monitoring
parameters. to (Division Agency which lake, and will or Corps the U.S. of Army Water of take stream. impacts. of Engineers the plan. as also be Corps Water place The in of Engineers, and the Illinois Illinois is floodplain must The pond of contain Illinois as a Class to IDOT and review an state requirements Control)
A joint Department Environmental required or are impact details Department
Transportation Protection any construction river, part of
Resources). Pollution
(Division
a loo-year
a wetland. as could
application No monitoring permit. new ash Periodic a part subject and
construction Transportation require permit Illinois integrity
expected
anticipated dam.
the (IDOT) would
may classify be required would of
III
assure permit.
a maintenance application Department
inspection such to other the
authority federal
Conservation
agencies.
4-7
/
4.0 The provided continued to demonstration months. schedule. choose removed, and either at timetable below. for for various two (Phase will At phases monitoring weeks. after the is end of the GR-SI place demonstration early of to design. during period Phase last outage Unit II. is project Phase I. scheduled The entire 18 load IP may have it is and
Preliminary approximately
took
The construction initiation scheduled on final of the
be completed
about
program other to
16 months
III)
the
approximately schedule. program, 1 or
The exact
schedule details. keep to the them.
depend
demonstration on Hennepin
equipment
installed
no cost
Phase
I - 18 months
Preliminary System Permitting Design (applications) Monitoring
Phase
II
- 16 months (secure permits)
Permitting Construction Phase
III
- 18 months Testing Testing Operation Equipment Removal
Baseline Parametric Long-Te,rm Optional
4-a
5.0
5.1 EER will which This upon is type three not of
SUPPLEMENTAL MONITORING
conduct required monitoring goals:
monitoring for is termed
during with
the
three any
phases or
of
the
test
program
compliance
federal monitoring,
state and will
regulations. be focused
supplemental
major Provide project. Ensure Create this
1.
2. 3.
a basis that a data the or to
for
evaluating
the will and others
success not safety. be
of
the
demonstration to the of
demonstration worker from the health which future.
detrimental for replication
environment technology
base in
may draw
This be
section made during
describes each methods, chase .
the phase and the _
supplemental of the monitoring
measurements demonstration schedule.
which project,
have the
been
and will
corresponding
measurement 5.2
Monitoring mental monitoring other include emissions, addressed beginning are in of parameters took ash
will place will pond worker 6.
be conducted which prior water may to quality. health. Baseline prior 5.4. of studies. the monitoring to All be
to
document by of Phase
baseline the project.
values in
for Some
environof this
affected in
installation Illinois worker water GR-SI
monitoring and
be conducted
II
GR-SI equipment or Phase III.
River safety data the water and will
Phase of
I.
and
Areas quality,
concern gaseous are at the
health
issues
Section Phase in
quality initiation:
be collected
III.
associated
measurements
discussed
Section
Supplemental These and data physical will are
emissions being modeling utilized
NOx. 02 and CO were as system beginning program For design of Additional Phase
measured and baseline
early to Table verify gaseous
in
Phase emission shows
I.
inputs Phase
computer the and
measurements supplemental
be made at
III. I,
5-1
gaseous
as well
as Phases
II
III.
5-
LLLLL 00000
LLL z:fi .r .r .r EEEo ccc SEE WYY
z
5-2
1
;
. i I
I :
:
: :
i
al ;.$ 2 m ‘; ” ti ,h .-
5-3
Other purposes. containing material generated ash was characterization concentration characteristics. listed under The fly ash the in will in
data A major
were
also of
obtained of unreacted in test a new the
during GR-SI and on-site under disposal the inorganic
Phase process pond. spent
I for is sorbent
design the with solid
and fly Phase The
permitting stream This ash was The waste level, leaching ash specified hazardous. Hennepin the GR-SI in ratio the this of and this are pose should ash. I. solid pH
by-product disposed
waste
a mixture be to levels Table 5-2. well a pilot-scale
During GR-SI ash
furnace its on
simulated properties. elements, tests that of all the classify for to the of ash
conditions.
tested
characterize conducted of Specific various
simulated
include and toxicity
characterization results that indicate would to required however, ash mass is the ratio that concentrations similar be
performed wet eight the
on the metals ash as to
The test Leachate below time caution at a water ash indicate is
disposal
no serious GR-SI ash. indicates
problems. ash settling that
RCRA were
values increase will limits: to that disposal
conventional was added that while 17.6:1. satisfy evaluation the rise the
The temperature within during tests for acceptable wet use uses
observed
when water ensure
temperature observed actual Finally, the of III
remains tests expected preliminary specification other project. 5.3
temperature 4:l. may
occurred
approximately GR-SI Further
standard
as a concrete of GR-SI
admixture.
beneficial
ash will
be undertaken
during
Phase
Phase The only
II:
Construction monitoring of performed the Illinois downstream in during River sample of Section will the 5.4.2. the to construction document be taken new pond from discharge. phase baseline the
supplemental will 100 this III: parameters. feet
of river
this at
program for various points of
be sampling upstream are
levels More 5.4
One composite and provided
details
monitoring Ooeratia monitoring emissions, in the detail Illinois
Phase
The supplemental will are include described gaseous in more ambient monitoring
of solid
environmental by-product
parameters discharges.
during water These
Phase discharges,
III
River,
and groundwater.
measurements
below.
5-4
TABLE 5-2.
SO110 BY-PROOUCT CHARACTERIZATION
CHEMICAL Mineral
CHARACTERISTICS. Analysis CaO Carbon Demand
EP Toxicity Free Total Chemical Organic Sulfate Oxygen Phenol Cyanide Chloride Sulfide Paint Filter Test
EHILICAL CHARACTERISTICS Specific Gravity Fineness Pozzolanic Activity Soundness
5-5
.
lSSlQu$
.
The control emissions. operation. particularly will within emissions be the
objective SO2 and In air monitored furnace monitoring emissions 02
of NOx
this emissions
project boiler
is without
to
verify adversely will
that
GR-SI impacting
can
effectively particulate system streams. occurring the gaseous project. include continuous SOz.
addition, of to aid plan to emissions during
performance SOz. the all NOx. and understanding
be evaluated is the 5-1 the the Other
during output
The focus
all in
environmental of GR-SI
measurements particulates. of Table phases during EER will problems of
parameters
processes
operation. three
summarizes demonstration
for
Gaseous NOx. and CO, in-probe COz. monitoring continuous injection . . . . . For gaseous
be monitored to overcome Figure developed Key features
the such a the
test use a
program special
and
hydrocarbons. 5-1
system
designed
as gaseous schematic the system evaluation include:
stratification diagram of of the sorbent
SOz capture. monitoring system boilers. probes to allow
shows by of
EER for
on utility Multiple Rotameters Phase All Zero
accurate probes upstream for to
flow of
rate
balancing removal
discrimination heated gases six flow of This gas operating is the to of regular using separated the potential sampling eliminate each of basis. a Beckman and span
components
moisture calibration
instrument are
measurements, sample. probe separation the from of each
16 probes rotameters Phase Figure
plumbed are used
to to
a mixing provide probes the design by to
manifold an on-line are of used a
to to of phase
provide indication provide the gas
an average inertial with
Glass rate.
discrimination while 5-2 minimizing shows developed prior excess of which between are of is (HC) flame in the
particulate probe has
contacting separate of sample to in with the 250°F zero at
particulate. sample via
discrimination particulate Under particulate This the above system. span economizer greatly particulate and gases insulated Calibration on inlet typical
probe. probe matter reduces in
been effects gas All
EER to percent to heated gas
inertial conditions, from for system. the the the
SO2 measurement. 90 the and or and the A be monitored.
stream
is the
interaction
components
possibility gas monitors
condensation accomplished will be ionization
sample
a
Hydrocarbon 402 heated
measured detector.
5-6
lI I
i
-------------------------Portable I E*k.,,.-t CAdIY”2C
,L-pg/-+q fp=ppJy
Cabinet
---I
I
Stria
I
i
m /iI
I I
L
?
I
I
essan
I I I
L--
__d_
t
~-------.---------,--.
lJnheated.3/8" Teflon Tubing
Orain
I-
3/8"
Heated I--
Teflon
Samole
Line
I Heated Enclosure --1
eated.Line Heated Filters Phase Discrimination Probes I Sampling Duct I I
Figure
5-l.
Continuous 5-7
Monitor
Sampling
Train
. .
.
l
t
.5 2L 1. ‘al ‘; I
. r; k P
separate the 3 lists
single the
point loss or
sampling hang-up to the of
system be used
heated for
to in each
350°F the of the
will sampling
be used system.
to
minimize Table 5-
potential
hydrocarbons
instrumentation of can at system, the sampling SO2 in of the and outlet. the the cause
gases
monitored. is the be difficult of than the SO2 SO2 and all of to
Measurement due to the reaction This exist in moisture. actually measurement sorbent at the outlet the
presence
of unreacted
active
particulate calcium in to
SO2 with higher inlet. possibility EER will Because
presence reported of
SO2 capture Due of perform the at the outlet primarily C02. used to
levels the the interactions
probe the system,
importance primary removes will for be not at diagnostic measured flue the gas
between nearly be the
SO2 measurements subject economizer purposes. to confirm an emissions of checking balance. of 200 ppm if the of CO and
precipitator from also
precipitator
particulate, will
SO2 measurements reactive and will 02. excess on the CO, air fuel be taken of conditions. the to boiler based (HC) a standard
interference
particulate. be used HC. and and is
Measurements
Concentrations boiler indication concentrations the CO and combustion in coal-fired causes fuel-air EER will ments verify once the Both obtained CO2 and during methods the train process burner operating of
will in to
The 02 concentration condition. concentrations CO and in the emissions economizer HC will or
the
provides
convert and a
other mass than
The CO2 provides composition provide of be outlet CO is
a means a carbon
02 measurements hydrocarbon efficiency. boilers.
relative less to
indication determine Also.
The concentration
typically completeness.
monitored can be used
a change across balance. utilize with the
combustion
02 stratification
as an indication
EPA Reference continuous in
Methods monitors. Phase Method will during a modified particulate out-of-stack
to once
verify during
the
emissions 3 will for be
measureused to and of 6. during SO2 to 5 the than testing
EPA Method 7 will be used
02 measurements operation.
III
baseline using testing 6 to is used reduces the outlet
long-term
verification EPA Method and once measure gas. rather the sample to
NOx measurement. operation. interaction with cake,
SO2 measurements be used EER utilizes of train. the active heated The a 4-inch once
be verified baseline Method and filter heated loss of the filter SO2 in
6 and 7 will
long-term minimize sample standard of a filter The Method
sample
A Method build-up system. further
Method
6 sample minimizing will
large at
potential
6 sampling
be conducted
precipitator
5-9
TABLE 5-3.
CONTINUOUS ANALYZERS
I
GAS MEASURED so2 NOx
DETECTION PRINCIPAL NOUV Chemiluminescent Paramagnetic Nondispersive Infrared Nondispersive Flame Ionization
MANUFACTURER Western Research TECO Taylor ANARAD ANARAD Beckman
MODEL NO. 721AT 1DAR OA57D AR5DDR
RANGE O-5000 ppm
D-2.5 ppm to D-IO.000 ppm D-10X. D-25%
02 co CD2 HC
D-500 ppm to D-2.000 ppm D-25%
ARSDDR 402
5-10
minimize regarding
the data Nitrous
potential quality oxide
for
SDz/particulate can be found be measured
interactions. in during until Sampling parametric term the an tests. need opacity during for testing At the additional monitor Phase Section 7.
Additional
details
assurance (NzO) of by kept gas times the to will
baseline, will be will analyzed.
parametric extracted, occur once of this
and dried, during for the time,
long will baseline first results
term for be
testing conducted tests. months
Phase in
III.
Measurements flasks
scrubbed
SO?. then several
sampling during long
NzO analysis monthly monitoring.
chromatography.
and end
three will Opacity
during
be analyzed will This
determine with
be measured instrument
placed through parametric
in the
the flue and
stack gas. long
breeching. Opacity term will testing. Total using size stack the a high because appropriate ESP will measured size baseline long 5.4.2 During Unit also 1 will be term distribution cascade low
measures continuously
light
transmittance
be measured
III
particulate will impactors. flow grain relatively for the low rate
emissions Method also of
will the
be measured ESP outlet at the will will flow cyclonic impactor rate flow will Resistivity
at
the
precipitator Method and at outlet the inlet at the is will entering sample sampler gases Velocity 5. using time
inlet Particle inwith outlet more the be because
EPA Reference
17 and at A Brinks this
using be used
be measured impactor sample loading. a Wahlco Method the 2. and
ESP inlet allow of of of
impactor
sample inlet the
a longer will this the probe. be
loading. high grain using resistivity. once
An Andersen
be used
be measured using
EPA Reference
Measurements velocity as required testing, for
particulate, taken and once once
particle during the during
distribution, operation. operation,
during
parametric
and additionally
diagnostic
purposes.
normal be sluiced to to of the some
operation to the new
of a newly ash
the
GR-SI
system. ash pond.
the pond. The in addition
modified new Section to pond the
fly will 4.7,
ash
from
constructed disposal as described
The bottom
ash will require including compliance
sluiced
modifications monitoring measurements,
NPOES permit. discharge
parameters. monitoring will
In
some supplemental
be conducted.
5-11
Supplemental point. results treatment implementation quality. during the Table at will the for ash be used the will
monitoring pond to discharge gauge
will the ash. the
be conducted point and various and also effect aqueous in the effectiveness to
at of on
the Illinois gravity verify the
sluice River. that Illinois to
line
discharge Monitoring as project water monitored a
sedimentation the River be
GR-SI have lists
no detrimental
5-4
discharges
demonstration. of be and the of ash sluice from thereafter period. will the (35 that Water pond. exceeds Ill. Adm. pollutant Quality for place will at indicate In the in water each for Analysis the the and which location the of first the of the are ash listed as six samples solids event available or limitations treatment the Adm. for Phase River. of upstream a discharge Code which Monitoring 302) soon months from and that pond in as of discharge Table the the both other the or the 5-5. pond the will is influent be Water in
Monitoring conducted samples operation, and and being level Effluent long-term effluent collected of any Standards for Use are will discharge spaced will on the be additional General are will for will
a number monthly testing streams in pollutant
constituents,
collected
parametric pollutants Illinois will
amount unlikely
concentration measures pipe. listed is for baseline of at the testing impact of increases mitigating program ensure that to the The GR-SI of GRin eight in no these
NPDES permit the ash pond (35 of the the Illinois 100 feet will river to During with determine the to Ill.
Code 304).
be implemented General Table specific pollutants operation. ash pond evenly samples system Phase SI any will occurs 5-6
Standards waters the Samples
applicable which take
state
there
designation. Measurements
includes be taken the
beginning
III
from
during a boat sampler. of
and downstream
location. across analyzed
be collected the GR-SI If tests, above are
intervals river
composite effects parametric the
separately will Duality during and Illinois
cross-section. samples Use Water detected
III.
pollutant
be collected parameters. screening outlined River
evaluate significant
on the
appropriate monitoring designed heron
measures no adverse
be identified impact to of the
implemented,
and a routine nearby
be instituted. as a result
The procedures GR-SI
and the
rookery/hatchery
implementation.
5-12
5-13
TABLE 5-5.
AWEOUS MONITORING FOR ASH POND INFLUENT AND EFFLUENT STREAMS
Arsenic, Barium. Boron, Cadmium, Chromium, Iron, Lead, Mercury, Oil
Total Total Total Total Total Total Total Total
and Grease PH Total Total Solids Solids
Selenium, Silver. Sulfates Total Total Dissolved Suspended Zinc
5-14
TABLE
5-6.
ILLINOIS
GENERAL USE WATER DUALITY
STANDARDS
CONSTITUENT Arsenic Barium Boron Cadmium Chloride Chromium Chromium Copper Cyanide Flouride Iron Lead Mercury Nickel Phenols Selenium Silver Sulfate Total Zinc Dissolved Solids (total) (total) (total) (total) (total) (total) (total) (total (total (total) hexavalent) trivalent) (total) (total) (total) (total)
CONCENTRATION
(mgll)
1.0
5.0
1.0
0.05 500.0 0.05 1.0 0.02 0.025 1.4
1.0 0.1 1.0
0.005 1.0 0.1 1.0 0.005 500.0 lDDD.D
Manganese
1.0
5-15
/
A major containing SI ash the system pond. for solid is
by-product of to operating,
of unreacted the
the mixture
GR-SI and spent will the and the Phase by in the
process sorbent ash.
is
the fly in
solid ash.
waste
stream GRand lists on-site
a mixture
with samples properties.
When the
be disposed physical
a dedicated must be obtained Table 5-4
In order
chemical waste the from
characterize plan stage openings screw environment. be analyzed when the stage results purposes of for waste for of
analyzed
constituents
sampling second the with dry will
demonstration
project. testing, Samples and placed will will in be the GR-SI four-ounce labeled and ash
During will with sample stored a scoop in
III.
parametric
be sampled containers a clean.
on a daily
basis lids.
EER personnel. ESP hoppers Sample containers
be obtained
Ash samples the month of the parametric period in be conducted for
screening is on first a monthly
purposes generated. basis to
at for define
the the
beginning will first At trends the and three-
of then end to
testing the
Analysis testing.
screening third period.
Phase will
III.
long-term
three-month appropriate will
be evaluated
determine Tests were carbon listed polynuclear
follow-up
analyses. for Table physical 5-2. which and In chemical addition, characteristics screening on fly ash tests or which for unburned
be performed in hydrocarbons
previously aromatic will analyses and will constituents
may be adsorbed
particles The data
be conducted. will to be used add to to the with present constituent three-month will from will also modification. the aid screening EER in fully limited processes literature in the will period ash. be in tests characterize existing similar data or the have to for if identified long-term been if the data by-product base of GR-SI. consistency. constituents testing. basis. evaluated. handling or to as a future from ash If are Results
the from any
GR-SI the
process, and analyses
composition unexpected at for
characterization be compared are the first the levels, constituents results require
from
present monitoring analyses be Screening disposal
unexpected need. certain when test results After
be conducted
on an as-needed determining
determined
procedures
5-16
5.5 The operation from the effects when this in concern. disposed all claims. the is associated beyond Therefore, program 5.6 the GR-SI will
Post-OI&X&JM supplemental stages operation system already project All is is of after be the monitoring designed the known. generated ash losses end pond. and by-products. complete, to GR-SI field If there identify system. IP conducted effects If does will during EER shall expenses considered is during on the to period, operate no be Phase arising part anticipated of IP elects not the construction resulting Unit operate the the this Illinois from future monitoring compliance when the GR-SI program Power and
environment
1 with
demonstration
environmental equipment effects will against liability requirements monitoring. demonstration of be
environmental of
by-products an on-site damages,
III
indemnify
with Phase
disposal
Groundwater
III
date.are
monitoring
no supplemental complete.
Supplemental construction tests for Phase duration testing. be used provides product for and gaseous Phase of and for long the
monitoring operating emissions two weeks. is defined phases
will of occurred as Table monitoring
be the during the 5-1 of
required demonstration the middle
only of phase the of
during Phase will and schedule and and testing.
the
prelasted during have a
program.
Preliminary
I and
occur will
approximately
No supplemental including
monitoring operating baseline gaseous describes
II.
III
term for
approximately supplemental
18 months,
testing.
parametric which Table solid will 5-4 by-
emissions, aqueous
a schedule discharges.
supplemental
monitoring
5-17
II
HEALTH AND SAFETY MONITORING
6.1
Jwoose
To protect the
and Srppe
safety as well during and health This the section GR-SI as the of plant employees. the safety and some general current safety health safety program
practices at Hennepin will which
must
be followed.
describes project.
Station. be conducted
additional
monitoring
Lurrent
The (DSHAI variety of Federal industry, Sub-parts Surfaces, Hazardous All has of Department produced industries. Regulations. but Means Materials. utilities cover of
Safetv haxinat
of Labor's of These most topics Egress, such These are
IP Hwin
Safety can Title not in are general, Safety Health and
Station
and 29. specific including and Health, Health Part to Administration nationwide to a
Occupational standards specified in General guidelines as which
a set
be applied
1910 of the
each particular utilities. Control, public
Code
industries Occupational
include
Walking-Working and
Environmental
are all IP are
required an additional facilities, used for continually, monthly, to are
to
follow safety including
OSHA's program protection. all potential
standards which
listed ensures Station.
in safe
29 CFR working Several
1910.
different program sessions
but
IP maintains
at is in are approaches progress at weekly, conducted Employees the be all this rules may to in exposed.
conditions
Hennepin
employee and
An extensive hazards with Safety new Data are Mandatory Sheets
education identified training and (MSDSI to the brought which is also about which utility. and
and discussed procedures. which workers available The rules provide by past IP Physicals an extended physical indicate
and quarterly with Material of there the most of safety of
meetings.
familiarize provided and properties
personnel all is the a
equipment
hazards
the regulations which
substances Manual of were
In
addition.
Safety
employees manual as well to for and basis. developed
describing incorporate as suggestions provide all IP
OSHA standards,
safety accidents has are
by IP safety
personnel employees.
a program required absence.
physical
examinations and those that all other
for returning
all to
employees. work after have a
new employees recommends
employees
on a yearly
6-1
6.3
GR-SI I-kaldk
Maintaining the is Power effect. GR-SI at
and
Web and
Monltorlnq safety to In in of the the be general. Safety the all employees the primary safety will of source during management practices remain the course which in of are for
health a top
the
GR-SI
project in
priority
EER project Manual.
team
as well effect
as to currently during safety
Illinois the
management. as described and will
project Hennepin which
guidelines
practices
Station. may occur required and is required anticipated at the for to to plant the due to for abide construction by them. during be required the addition phase this of listed will No additional phase, the in be
Any construction GR-SI 19 informed health except process of and asbestos Boiler asbestos construction contractor contractor's OSHA and air contractor implemented. Prior to the monitoring is will All these safety CFR 1926.
be governed personnel standards monitoring
by OSHA standards
construction,
abatement tubes are will
activities. insulated be required All with to the include proper verify asbestos perform asbestos including disposal that to minimize will containing that asbestos proper heat be loss. conducted material. all applicable guidelines, When are the being removal measures and some by a The
handling qualified
necessary
modifications
during
activities. to work specifications EPA regulations requirements, on site,
asbestos with
removal
will be satisfied, and EER will
a requirement
considerations.
initiation The purpose
of of
Phase this have
III. survey been
a safety is and to
survey ensure will be and are
will that: met.
be conducted
by EER personnel. 1) 2) All related All test In to all GR-SI Monitoring addition. operation will test
OSHA to testing
regulations noise, facilities arrive. of annually for will dust
specifically before
and and
asbestos safety
removal: equipment
available
personnel monitoring and results be conducted
worker hearing
health and
will until pulmonary
be conducted, project function.
both
prior of the
thereafter be maintained
completion. Records throughout
employees'
confidentially
6-2
II
demonstration optional for Noise determine areas process four the the the information fan fourth areas exceed determine beginning the are or
project. IP employees monitoring which areas established, equipment fans indicates These is not these III.
Monitoring expected is of required the area increases will that fans 'action yet equipment fans three will available. noise are plant
will to
be required be associated
for with
all plant (29
EER employees operations. CFR 1910.95) Once a change
and
by
OSHA regulations hearing not noise for noise in level. the levels areas Sound GR-SI is required
to in that
require
protection. unless system. do not
these
monitoring or decreases be required fans level'
EER anticipates below which level will exposure. conducted 85 decibels
additional casing. fan installed where of Phase
Vendor at for to of at the currently
have of
be installed Noise level installed
OSHA noise
85 dB.
information be conducted Monitoring once
monitoring will be
and worker
A hearing will The within annually who have hearing exceed hearing the an equivalent
conservation eight level six months to check of program. governing to mg/ms could or 2.4 coal. hour
program time (higher program of for
must weighted noise requires
be instituted average over monitoring to establish in hearing will exposure of level
if 85 of level.
employee decibels time employee All included
exposure or period). hearing level, in and the employees an
exposure first thereafter, a possibility conservation
a shorter a baseline be
conservation
exposure, a change noise
excessive
OSHA regulations employees coal the visible determine exposure and dust compliance, is dust sorbent. dust limits, anticipated not level that the will employee be exposed of dust
dust
exposure dust level during
(29 CFR 1910.1000)
of time greater weighted system startup. will to will to exceed system areas controls not feasible No additional observed GR-SI than
require 15 mg/ms
that or a is from with to
a total
on an eight-hour be generated fly and If and controls shall ash. workers levels are are be used. engineering During
average. operation areas be evaluated
It
the
be monitored, exposure. administrative When such measures
task
allowable identified full for
be
implemented. protective anticipated.
achieve monitoring
The only include handling
particular of natural
safety gas.
issues sorbent.
which and
are the
unique solid
to
the
GR-SI
project Safety
by-product.
6-3
procedures well good industry
for
transporting All practice.
and hardware Gas
utilizing and controls firing
natural installed no poses
gas
in will
boiler problems
furnaces for
are with this
established.
be consistent
unusual
application. The baseline will caustic According lime but Station familiar available Handling minimize be directly filter safety health mask plants is not be hydrated irritant to the show injurious safe all sorbent lime and that is used in in the GR-SI fine hydrated for use with the powder. will glasses sorbent demonstration to lime system.1 in another Material hydrated systems In lime are addition. be provided with utilization. side be studies can be IP at powder suspendable performed irritating personnel process, Data will workers shields. and and all with be which a lightweight Minimal no additional plant Safety Hennepin form and if at Station that is a in
[CaCOHlz] Lime from lime working dust with the fitting expected considered product particulate have lime the
a fine
(micron-sized)
sufficiently
inhalable. inhaled, Hennepin and Sheets are are will
National dust to handle handling those and to
Association,
on workers
respiratory procedures. suppression powder safety from dry necessary. generated been However, in
currently with for the
posted. who will
procedures exposed and tight are is waste in the
available
human contact
problems monitoring The only
the
process equipment.
is
the This
fly mixture
ashlsorbent contains calcium with will for the of
mixture sorbent oxide. significant
caught particles
collection sulfated will controlled
which oxide release. hydrate other than
as well hydrate when
as some exposed of neutralize 5.4.2.
unreacted to the moisture product the
The calcium heat to is it
material the There material are those
hydration and monitoring in Section
be performed before spent aqueous sorbent
completely no specific
material
disposed.
requirements monitoring
described
discharge. Table 6-1 during shows the worker II during and Phase health III I. and of safety the monitoring which project. will be No
conducting monitoring
Phases
demonstration
was conducted
I National Lime Association, Bulletin 213. National Lime
"Lime Association,
Handling, Arlington. 6-4
Application. VA. 1982.
and
Storage."
TABLE 6-1.
WORKER HEALTH AND SAFETY MONITORING
PLAN
MONITORING PHASE L No monitoring PHASE 11 Safety
PARAMETER
FREQUENCY
LOCATION
Survey
once
All
applicable
areas
of
plant
PHASE LU oust
Worker Health Function Hearing Pulmonary Noise Level
as required annually (1)
Areas N/A
with
visible
dust
once
Near
fans of the
1.
Initial screening must be conducted prior GR-SI system. Annual exams will continue demonstration is complete.
to operation until the
6-5
7.0
DUALITY
ASSURANCE AND DUALITY and Scg~e the Duality
CONTROL
7.1
This project the the 7.2 DA currently section
contains the for at for the
Assurance will has
(DA) described
plan in prepared
for this as
the they
GR-SI are to
concerning procedures practiced
supplemental compliance plant. quality
measurements monitoring This GA plan plans.
document; according
continue been
EPA guidelines Shmplina Sampling
assurance
Prom for each in are have in to the measurement 4 and and where in to 5. be employed The sampling more detail to used each the during the for 5. of Clean prepared wash by samples Samples or GR-SI each which
procedures are described
demonstration sampling measurement. are not standard Reagents the reference containers in sample rinsing are are
Sections procedures, used been
description frequency and procedures in Section
includes
location,
sampling protocol
EPA procedures
appropriate.
described
to
be used are used and rapidly required
measurements grade For chemicals samples. example. are
conform are with air-dried
specifications
methods. appropriate as are
Reagent solutions. all as for is
exclusively. container probe rinsing. preservation
collect containers practical: these
particulate after no special
acetone-rinsed, analyzed times
however. measurements.
holding 7.3
Many involve not sample groups generating and particle accuracy sampling, characterization washes .and the require
of
the of
measurements continuous procedures. related will
to
be employed or work sampling. physical NOx matter substrates. the other closely All compliance
during
the
GR-SI
demonstration which stringent assurance measurements loading verify by-product particulate in SOz and probe NOx the do
use
monitors EER will require
measurement monitoring with The IP's are method collected the test
methods requires quality particle to
custody any
custody on
procedures. compliance that size
supplemental
samples of the and on
custody measurements, on glass
measurements, continuous water include cascade sampling. particulate impactor
EPA reference Samples
SO2 and
solid for filters, for fiber
Samples
7-1
verification solutions. will Qualitv utilize legal AssurV EPA for
are Pond the
liquid effluent "chain
samples and of custody.
containing River procedures
SO2 and samples for are
NOx collected are all aqueous samples listed in
in
aqueous EER by 3 of 111 -
Illinois These
samples. as defined Section
custody" for Air &&a&.
sample
procedures
Pollution M-t EPA-600/4-77-027b. and Freauebcy for in will is each Table
Svstems: Volume August 1977.
7.4 Calibration listed is will to in Table for the 7-l. conducted be used ensure that
. ion
Procedures and is the of
procedures Opacity to system. internally each accuracy
frequency not included system
measurement 7-l since at to the calibration
system calibration
are
instrument. Each the measurement
Standard
procedures a frequency calibration
be calibrated traceable
standards. 7.5 Continuous opacity, These sensitivity instruments provide HC. CO, and will permanent The monitoring measurements and solids own instruments 7.6 Figure collection sampling each independent of and 7-l shows EPA instruments be tical Procem instrumentation and SO2 concentrations selected possible. with a strip results. in 7-2. Table Where 7-l are used the such utilizing with the recorded of test specifically interferences to is be to used described provide Test data chart to analyze in Table the from recorder NOx. 7-2. highest the to
monitoring COz. 02. were minimum documentation standard other will
continuously
procedures listed standard in
given Table procedures.
instruments use analysis
possible, laboratory
remaining as water their
Some measurements
be conducted
by an outside
and calibration tion the to The by the portion test
procedures. and Validation general reporting and each scheme reporting results to verify for of are the results then each results. are measurement Following calculated to subjected from the for an
raw data analysis
validation of preliminary supervisor
measurement,
measurement. check
following:
7-2
7-3
/
TABLE 7-2.
CONTINUOUS ANALYSIS
INSTRUMENTS
I
GAS MEASURED
OETECTION PRINCIPAL Nondispersive Infrared Nondispersive Paramagnetic NOUV Chemiluminescent Flame Ionization Detector CFIDl Light Transmittance
MANUFACTURER ANARAD ANARAO Taylor Servomex Western Research TECO Beckman To Be Determined
MODEL NO. ARSOOR AR500R OA570 721AT 1OAR 402
RANGE O-500 ppm to o-2.000 ppm 0-25X
co
co2 02 so2
0-10x
0-25X O-5000 O-2.5 ppm ppm to ppm
I
NOx
O-10.000
HC Opacity
7-4
Calculation of Results
-
Yes
calculation Errors Made?
Fail
, L
Invalidate Data
I
Quality Control Checks
FIGURE7-l.
DATA REDUCTION VALIDATION AND 7-5
/
. . . Data are obtained then not
Accuracy Proper
of
calculations and analytical experimental sampling are with with then other existing procedures. the criteria performed and analytical independently will The be above used checks to are then data validated are the and added to or results data procedures conditions analytical to are procedures. Results identify subjected to passing potential a double or under the nonchecks check of
sampling
Representative with improper
representative Results calculations
conditions. correlated correlating
invalidated.
outliers.
and measurement passing Specific
Measurements the data base.
validate
following: experimental
1.
2. 3. The and on-site validation that
Measurement conditions. Proper sampling
under
representative procedures utilized.
Calculations Test of the Officer procedures Engineer data. will are
checked. for Supervisor program verifying the results the collection, will that reduction, for Quality data The specified the
be responsible on-site fulfil1 and Test the for that
be responsible the meet
ensuring Assurance handling criteria. 7.7
measurements followed
objectives.
responsible
validation
Internal EER will conduct items: Routine Internal Periodic
Quality
Control
Checks quality control program which will include
an internal
the
following . . . The
calibrations audits quality
and maintenance control checks for data collection of all and will instruments frequency also be and are
engineers/technicians for in routine 7.4. calibration Specific systems. Section
responsible and calibration
responsible measurement discussed
maintenance procedures
7-6
The measurement reauirements The The quality
EER Duality systems are met.
Assurance and These also to
Officer to are audits administer be used and checks gases are
((IAO) ensure discussed
will in
conduct that all Section quality
internal quality 7.8. control
audits assurance
of
procedures
EER (IA0 will control Calibration -
a program listed
of below.
checks.
checks
1.
Standards equipment reagents zero Control blanks spiked surrogate charts samples and span Samples
Devices
2.
Duality -
samples
3. 4.
Replicates Control
7.8
EER will system system analysis, collected. assessment of audit used data the is for System participate an the on-site total audits following: . and ~siblllty are these - Are is it Is used? written to calibration In establish addition, sensor. procedures a review traceability available should of and are be made Are written . Is the quality assurance procedures available data validation and in and conduct and for system review system each and of (sample monitoring performance the quality collection. sensor appraisal or and audits. assurance sample sample include A
inspection measurement etc.) are normally
processing,
a qualitative
1.
2. 3. 4. 5.
Draanlzatlon organization Sample available Samole are Data available . w these of schedule these
operational? Collecti~ and sample-collection as written? analysis of criteria procedures for followed written a list
Analvsis followed and . followed ValldatloD - Are
as written?
as written? used
procedures and data
calibration
by measurement
7-7
6. 7.
Augj& Ireviewed?
- Are
control
charts - Are
for
performance from preventive the OA plan?
audits
reviewed? testing schedule
results the in
interlaboratory maintenance
a.
being Performance auditor analysis 1. 2. 3. These control having the system control should to ensure audits checks the routine or audit of charts be applied that to evaluate system. Sampling Analysis Data are followed audits the
Maias refer quality
-
Is
recommended to audits independent of data
checks produced are
made by the by the total categorized
supervisor sampling as follows:
or and
Performance audits audits
generally
processing performed by the
audits independently of and in addition from sampling into subsequent of external operator/analyst, operating conditions. from several the one The the the or plotting reference if to can the normal be one or of quality by the on
operator/analyst. or, in the case standards and the The knowledge reflect by most - The reference rate use of normal
Independence operator/analyst of
achieved conducting by analysis results standards possible,
made by a different external by the without recorded audits routine of &g.jj, and flow reference comparison supervisor. the results made the
measurements interlaboratory
analysis,
introduction
sampling
Performance conducting following the are
a different may be common type auditor uses
operator/analyst conducted of audits. a separate to check the set in
measurement
ways.
examples
1.
Samolina flow meters a. b.
C.
of
calibrated collection
standards
sample
system: devices calibration calibration auditor is gases, commonly for when applicable provided a portion or instrument instrument Audit& aliquot of several - The
2.
routine
samples
analysis.
7-a
3.
Qata check
Proon calculations. in the data of by review EER's provide in to the internal conduct the
- Data and these quality processing
processing data system
commonly may a dummy
involves be set of
a spotby data raw
validation data. program system and of !&alitv and II. will types
checked
inserting followed As part 7.7, These the audits of will according Pollution 1976 and the appropriate Following them action audits reports. 7.9 Proper ments. preventive ensure equipment procedures to these performance 7.10 The indicator ensure precision, that precision, measurements the quality accuracy, that During Preventive equipment this quality malfunctions. and routine to detect critical maintenance to the will Test be procedures
validated control
discussed performance conformance the Aaudits
in
Section audits. with will the be
EER DA0 will specified
independent OA plan. Svstems. August developed. and Where specified
a comprehensive procedures
evaluation applicable. in I For audits the systems. evaluate identify Section in
requirements conducted for March audit following etc., Air
Measurement EPA-600/4-77-027b. have for each initiated corrective the audit. as been EPA guidelines specific the
Volumes 1977. the
EPA-600/g-76-005. where conducted audit samples, no EPA by be of
measurements
substituting measurement
EER DA0 will If the will audits in
the
results The results
and
report of all
Supervisor. action
DA problems, 7.11. the quarterly
corrective monitoring
discussed
and any
be discussed
Maintenance operation project. and data maintain are Tables spare and allow n of parts EER is essential utilire an 7-3 for inventory and and the of Indlw completeness over are these of the goals of each of of the this Project measurement data quality to for are goals data to 7-4 to obtaining of list critical data standard systems. monitor problems. quality for spare loss In measureroutine parts due addition equipment to to
EER will collected
standard
procedures
minimize
maintenance
measurement continually equipment
procedures,
personnel
correction
DaLRJDal1t.v and
accuracy, will and
be monitored assurance completeness
duration
project
achieved. critical
7-9
TABLE 7-3.
PREVENTIVE
MAINTENANCE
PROCEDURES
EOUIPMENT INSTCalibration Instrument Conditions Leak Check System Clean Tips Sample Filters Sample Flow Rate Probe Probes Gases Operating Sample Filter Verify
PROCEDURE
FREQUENCY
pressure
> 100 psig
Daily Daily Daily
Verify to manufacturer's specifications Vacuum and pressure component check Reverse gas purge compressed air Balance sample each probe Change Verify Verify constant constant flow with in
Daily Daily Weekly, or as required Daily Daily Daily Monthly
System Vacuum/ Pressure Heater and Chiller Temperatures NOx Vacuum Pump Oil
Verify within specifications Change
LABORATORY EOUIPMENT Balances Calibration check Service and calibration by manufacturer Routine service Daily Semiannually As specified manufacturer by
Instrumentation
7-10
TABLE 7-4.
CRITICAL
SPARE PARTS
CONTINUOUS MONITORING INSTRUMENTATION Filters Probe Sample Back Filter Pump Diaphragm Regulator Capillary Sample Flowmeters and Cells Pressure Frits
MANUAL SAMPLING EQUIPMENT Sample Nozzles Pump Oil Manometer Fuses Glass Nozzle Sample Probe "0" Filters and Liners Rings Oil Pump LABORATORY EQUIPMENT Reagents GC Columns Glassware Instrument Combustion Filters Scrubbers Spare Tubes Parts:
Pump Valves, NOx Sample Infrared Valves,
Misc. Tubing Fittings
Thermocouples Lead Wire Glassware Reagents Ash Sampling Containers
7-11
/
listed interval
in
Table will of
7-5 also the
for be results
supplemental determined to will
monitoring for each
parameters. measurement
The to
confidence allow the
significance Duality and to 005. a loss accuracy show any charts Control of
be evaluated. be maintained a loss of or deterioration and maintained to monitor on a daily control in data standard determinations. limit be and 23s established as this review for to for in quality quality and deviation. Control the based necessary project. to determine quality on after the basis for precision and Quality indicate of s. of lines results Measurements cause each each will control of a data
control to trends will charts for be the at +2s will and identify in
charts
immediately improvement will any plotted be utilized measurements. as the the limits is will being the warning will and will
any measurement control. in and to accuracy EPA-600/9-76-
control
be constructed
as described
control
The precision
measurement measurement be established limit. previous base of 7.11 the of exceeding loss
relative
mean of for these
accuracy
Initially, measurement 15 to the of warning control
programs limit before Action occurrences Not Achim
be modified
20 determinations
obtained validated.
be subjected
Corrective The following 1. 98 7.1. 2. 3. between 4. Sianifimions This Audit and/or Goals
will
require - This
corrective includes the criteria
action: failure to achieve in during the
precision,
accuracy
and completeness - Deficiencies audits.
specified
Section systems
Deficiencies performance oratorv similar involves
may be identified - This by separate Reaulated by or the concerns schematically to the attention The the above. and will compare actually includes
CMlparlson samples a
Problm analyzed of
discrepancies group that
laboratories. Unregulated advisory exist. in Figure of GA and the 7-2. EER
determination and health is shown
significant The It Test then goals is the review. to corrective responsibility (TS) determine if
environmental action of any the of what procedure the the data
EER (IA0 to problems are suspect,
bring listed
Supervisor determine
TS and
QAO will project in
specific
QA problem 7-12
cause
a problem
7-13
(IA PROBLEMS GOALS NOT ACHIEVED PRECISION ACCURACY COMPLETENESS EXTERNAL/INTERNAL AUDIT DEFICIENCIES SYSTEHS PERFORMANCE INTERLABORATORY COMPARISON FAILURES OK 4-b
PROBLEMS REPORTEDTO TS BY CIAO
v REVIEW/COMPARE OA AND PROGRAM GOALS AND DEFINE POTENTIALLY INVALID DATA BY TS AN0 QAO
PROB
REVIEW MEASUREMENT SYSTEMS AND PROCEDURE BY PE PRO8 SOLVE PROBLENS BY PE
OK
REVISE (IA AND/OR
VERIFY OPERATION BY CIAO 1 OK t . 1 REvI~~~OVAL j
REPEAT
v EVALUATE REPEAT
I
f REPEAT SELECTED TESTS
1
TO S
OK
BY TS AND OAO
REPORT INCIDENT TO TS AND DOE
I
TS - EER TEST SUPERVISOR PE - EER PROJECT ENGINEER (IA0 - EER QUALITY ASSURANCE OFFICER Figure 7-2. Corrective 7-14 action procedure.
BY OAO
I
achieving stringent, The GA plan If will system problems include remaining EER project
project they will will
goals. then
If
it
is to by the are
determined reflect the
that current
the
GA goals project
are
too
be modified be revised project of the as (PE). solved. will goals subject The required. the
objectives.
GAO accordingly. determined proceed the verify to to be satisfactory, and solve the procedures the that This etc. the to measurement the may Any TS an
the
(IA and review engineer etc., been
delegate problems. have specific
measurement PE will When and/or PE. solution the process
systems PE has
determined results. audits,
EER GAO will systems by the OA plan, review
calibration,
performance
problems
be handled of the and the TS will validation
Following other with specific related the data tests Although valid Significant situations effort possible. characteristics concentrations health process requiring reports. 7.12 In this contract be Quditv some concerns, modification to and
revision actions. reduction must
of (Figure
measurement data 7-l) and
problems in determine
and if
questionable
accordance
be repeated. it actually of operations. nature the application exist be will at taken be will treatment action of high is possible much some In the to that higher substances these problem this levels to boiler. which correct in the the suspect (or lower) could situations. and may If data are than indicate EER will correct simply it is it found to be
unlikely, are GR-SI the cases. GR-SI action or substances concentrations
values during determine In some of of
anticipated. unforeseen make every as soon that as the any or with incident
concentrations
represent found environmental either each of
generate The details
problem, quarterly
technologies. reported
corrective
monitoring
Assurance
of
OuLside will order
. . Oraanuaiarts be obtained and data of plan analyses quality these with performed laboratories from regard to organizations for and these will data
instances, by non-EER the into the
samples personnel, In quality
program
including to verify assurance
both plans
utility
laboratories.
measurements/analysis. incorporated by those supplied
EER quality
assurance
laboratories.
7-15
l
/
8.0 8.1
The any test ensure information be flexible the which The will of depend data. required, Finally, format data
DATA MANAGEMENT AND REPORTING and Ssg,p~ management program. quality. storage enough and the system user for must of They data must They capacity the of requires. management in which acquisition data procedures the data applied are to environmental and upon via the of any data type the which must for user the have been in of data capability generated with a system or to is an integral backups which years. any data functions the has part sufficient must be a well. in may as data of to
be recorded a period to
faithfully months access of
and checks The system which
be stored have
capable
performing have
processing
reproducing
specific upon means: the
data
manner
acquired
Environmental
may be accomplished
following 1. 2. 3. 4.
Direct in field Laboratory results
in-situ
acquisition analysis of
of discrete data
data
(e.g. samples chart on-line
pH meter with
reading
recorded of
logbook). manual recording on laboratory data data on disk. the will directly a hard will procedures logic to copy and is testing is format. the data in an 8-l behind the will the data as manual management for the noted and system. Once data to a data data sheets. on strip by recorders. computer, with data
Continuous Continuous recording
recording acquisition
Figure are have of computer
8-1
illustrates they or system entered. Printouts
generated been
be recorded
either computer, with
manually
subsequent entry After the above. validity for of the
be produced
checked. data
be compared
documentation
validation
recording Once the
hardware. verified system. will also Some required, and corrected Any be stored reports of the as for can and necessary, information data be relevant identification by the The may manner. require generated the data which
data within to data produce
quality the the reporting
will
be stored pertinent As in a to
computer
additional
may be purposes. system processing
user-specified
information
applicable
8-2
computer test 8.2 The performed EER will with reports
system
has
the
capability
for
any
data
processing
necessary
for
the
program.
Beportina communication on submit will a regular quarterly on include: Summaries prior 2. Copies regulatory includes monthly 3. data
Reouirements of basis and process with annual and complete reports and potential measurement reporting of the problem information of all areas. relevant data to must be DOE,
data.
environmental
emphasis
summaries
Iluarterly
1.
of
environmental
monitoring
data
collected
during
the
quarter. of all a one compliance by submission reports. time reports IP during of and analyses previous test submitted quarter. results, data. unregulated comprising to This plus
authorities NPDES monitoring and present concern, from of significant issued of and the
compliance and coal of of
composition and group
Identification substances and health representatives
characterization at concentrations EER and the plant's changes by the problem of permit to the regulatory areas actual, as determined
regulated significant
environmental
by an advisory utilities. status, terms of including permits
4.
Description of any violations
a description or notices of
authorities. encountered anticipated. during or the prior
5.
Identification quarter solutions.
indication
possible
6.
Recommendation defined information. in the
of
modifications Monitoring a basis Plan for
to
or which the
deletion are not
of
specific yielding
tasks useful
including
recommendation.
0-3
Annual
reports
will The fourth Summary and the patterns
include: quarterly of four in the of monitoring previous data report. information quarterly and summary of of from reports, data. or health concern, based all prior including annual reports and
1.
2.
trends
3.
Indication on previous
any
trends which any of
environmental been problem have be taken. been
reports whether or annual measures
have the
submitted. areas identified and, if in previous not, what
4.
Indication quarterly mitigation
reports should
resolved
a.3
Data showing taken addition will project. Data Committee. participants, providing review provided ongoing recommend is host to in review that: Certain monitoring of the tasks techniques quarterly project be discontinued, or instrumentation and annual management changes at reports DOE and modified or added: or will be including sites determine the quarterly of monitoring for if reviewed will EER. the there and on the are annual information. an annual of basis participants. projects. significant reports. members findings Based of on the by a Monitoring from and The main the purpose among the all Review project utilities of the this data can if will required. of review data be reviewed results This will by EER and be reviewed. modification or change all in IP as it to becomes monitoring monitoring of the available. frequency. location. demonstration Data action the EER
significant
verified,
and appropriate
may include parameter.
a monitoring
continuously
throughout
phases
The Committee
be composed funding any demonstration
representatives
Committee's
Committee
1) 2) 3) If
New analytical The format are the
be substituted: be changed. EER will
recommendations to
made,
consider
modification
EHP and authorize
as appropriate.
a-4
I
I
APPENDIX
A
. e
Illinois 217/782-2113
Environmental
Protection
Agency
-
P. 0. BOX 19276. Springlield.
IL 61794.9276
OPERATING PERMIT PERMITTEE Illinois Power Companv Attn: Aric D. Dierick, Supervisor - Environmental Administration 500 South 27th Street 62525 Decatur, Illinois
:“p; pa;Fo: ;,“a; ‘,m;; PP 9 Subject: Hennepin Eoiler I1 -sued: February 22, 1989 Location: P.O. 80x 195. Hennepin
I.D. No.: 155OlOAAA DateReceived: December 23. 1988 Expiration Date: March 31, 1991
Permit is hereby granted to the above-designated Permittee to OPERATEemission source!s) and/or air pollution control equipment consisting of boiler #l with associated electrostatic precipitator as described in the above-referenced This Permit is subject to standard conditions attached hereto application. and the following special condition(s): 1. Emissions of sulfur dioxide from boilers 1 and 2 (caabined) limited to 17,050 lbs in any one hour period. standards is shall be during
Za. Emissions in excess of applicable emission startup, malfunction and breakdown.
allowed
b. Combustion of the chemical metal cleaning waste sludge and waste oils may not be initiated during startup, malfunction or breakdown. If a malfunction or breakdown should occur while the sludge or waste oil is being combusted. the loading of the sludge/coal/waste oil mixture to the bunker shall be discontinued until the malfunction or breakdown is corrected. Records shall be maintained of the hours that the sludge/coal/waste oil mixture was combusted during malfunction or breakdown condftions. 3. The Permittee shall notify the Agency's regional office by telephone as soon as possible during normal working hours upon the occurrence of excess emissions due to malfunctions. or breakdowns. The Pennittee shall comply wfth all reasonable and safe directives of the regional office regarding such malfunctions and breakdowns. Within five (5) working days of such occurrence the Permittee shall give a written follow-up notice to the Agency's regional offfce providing an explanation of the occurrence, the length of time during which operation continued under such conditions. measures taken by the Permittee to minimize excess emissions and correct deficiencies, and when normal operation resumed.
. Q
Illinois Environmental
Protection
Agency
.
P.O.Box 19176.Sprin@isld. IL 61791.9276
Page 2 shall maintain and breakdowns. records OF excess emissions during As a minimum, these records shall or breakdown; of the cause for such emissions; of
4a. The permittee malfunctions (I) (ii) (iii) (iv) Iv)
include:
date and duration a full and detailed
of malfunction explanation emitted
the contaminants emissions;
and an estimate the quantity and
of the quantity of emissions
the measures used to reduce duration of the occurrence;
and the or
the steps taken to prevent similar malfunctions reduce their frequency and severity.
or breakdowns
b. These records shall be retained for at least two years following an event, maintained at a readily accessible locatfon at the plant, and be available to representatives of the Agency during normal wDrkfng and/or operating hours. 5a. Organic liquid by-products or waste oils other than that permitted by Condition #Sb shall not be burned in these fuel combustion emission sources without written approval from this Agency. b. Waste oils fitting the following description not to exceed approximately 10,000 gallons and 2 (combined). (i) (ii) lubricating engines, hydraulic oil fluids. with coal all on the conveyor fuels stored belt leading to from coal mills, may be burned in quantities per year in Hennepin boilers pumps, turbines, 1
fan motors,
and IC
c. The waste oil shall be blended the breaker buildfng. 6. 7. The Agency shall location. be allowed
to sample
at the above of 10,
This permit allows the burning of chemical metal cleaning waste sludge the same general composition as outlined in your letter dated February 1986. The plantwide quantity of sludge to be generated and burned is estimated to be 45,500 gallons every 3 years.
a.
The Pennittee shall analyze one time individual waste oil streams prior to and mixing together for arsenic, cadmium, chromium, lead, flash point. total halogens. The analysis report shall be submitted to the Agency by August 1, 1989.
. . a
Illinois
Page 3
Environmental
Protection Agency
-
P. 0. Box 19276. Spring&Ad. IL 62?44-9276
9.
The Permittee shall also analyze one tfme a representative sample of waste oil to be burned for sulfur, ash, BTU, and bottom sediments and water. The representative sample shall be prepared by mixing individual waste oil streams in the ratio normally expected to be produced. The analysis report shall be submitted to the Agency by August 1, 1989.
shall analyze a representative sample of waste oil to be 10. The Permittee burned for arsenic. cadmium. chromium, lead, flash point, total halogens, The analysis report shall be submitted to the sulfur. and BTU values. Agency with the next permit renewal application. The frequency of sampling may be reduced depending upon the outcome of analytical results. 11. The Permittee shall keep records of the quantity and analyses of waste oil fuel burned for energy recovery and the estimated quantity of chemical metal cleaning waste sludge burned for a period of three (3) years. These records shall be kept on site and shall be made available to Agency personnel on request during normal working and/or operating hours. The Permittee shall report to the Agency the annual quantity of waste oil fuel and chemical metal cleaning waste sludge burned by February 15 of each year. shall submit quarterly reports of the daily tonnage and 12. The Pennittee daily analyses of the coal burned in the above-referenced equipment. For any day in which the SO2 emission rate exceeded 5.8 lbs. per million btu. the maximum hourly heat input to the coal fired boilers shall also be Coal samples shall reflect daily averages of the fuel as burned reported. in each fuel combustion emission source for percent moisture, percent ash, ASM procedures shall be used in percent sulfur and heat content. sampling and analysis of the coal. This report shall be due within 30 days after the end of each calendar quarter.
TAS:WG:jmn/0067K/60-62 cc: Region 2 R; Watson - DLPC
STATE UNOIS OF ENVIRONMENTAL PROlEenON AGENCY 0lw.l0N OFAIR POU”llON CONTROL mm CHVRCHU ROAD SPRINGFIELD. 52706 u.uNOlS
STANDARD
CONDITIONS FOR OPERATING PERMITS
Juiy 1.1935 The Ninois Envimnmenkl Envimnmenkl Prokction The following conditions Proketion Act Clliioia Revised Statutea. Chapkr 111-l/2, Section Agency authority to impose conditiona on permik which it issues. are applicable unle~ aupeneded by ape&l permit condition(s). 1039) grants the
1. The i&ence of thii permit doz, not release the permittee from compliice with akk and federal regulations which e.re pert of the Illinois Skk Implementation Plan, LI well aa with other applicable statutes and regufationr of the United Skka or the Skk of Ninoiq or with applicable local laws, ordinances and regulationa. 2. The Agency has issued this permit based upon the information submitkd by the permitke in the permit application. Any misinformation. false statement or mispresenktion in the application shall be groun& for revocation under 35 Ill. Adrn. Code 201.207.
3. a. The permittee
shall not authorize. uuse, direct or allow any modfflution, u defined in 35 Ill. Adm. Code 201.102. of equipment, opmtione or practioca which are refleckd in the permit application aa mdunitkd unlesll a new application or request for revision of the existing permit is filed with the Agency and unless a new permit or revision of the existing prmitb) is iaaued for mzch modification.
b.
This permit only covers end&on aourcea and control equipment while phyclically present at the indicated plant location(s). Unless the permit specifically pmvides for equipment relocation. this permit is void for an item of equipment on the day it is removed from the permitted location(s) or if all equipment is removed. notwithstanding the expiration dak specified on the permit agent of the Agency, upon the presenktion of credentials. at
4. The permittee shall allow any duly authorized reenonable times: a
to enter the permitke’a property where actual or potential effluent, where any activity ie k be conducted pursuant k thin permit
emia@ion or noise sources are located or
b.
C.
to have access to and k copy any records required k be kept under the krme
and conditions
of tbia permit,
to inspect, including during any hours of operation of equipment constructed or operated under this pen& such equipment and any equipment required to be kept, used, operated. calibrated and maintained under tbii pemif to obtain and remove samples of any discharge or emission of pollutants. to enter and utilize any photographic. recording, testing. preserving, testing, monitoring or recording any activity, and
d e.
monitoring or other equipment for the purpose of discharge or emission authorized by this permit.
5. The issuance of this permit: a. shall not be considered facilities are located, as in any manner affecting the title of the premises upon which the permitted
b.
does not release the permittee from any liability for damage LOperson or property caused by or resulting from the construction. maintenance, or operation of the facilities.
c. d.
does not take into consideration
or attest ta the structural
stability
of any unit or part of the pmject, *nd
: :
in no manner implies or suggests that the Agency (or its offi~en, agents or employees) ~~somes any liobilit directly or indirectly, for any loss due to damage, installation. maintenance, or operation of the proposeu equipment or facility.
6. The facilities covered by this permit shall be operated in such a manner that the dispal of air contaminants collected by the equipment ahall not cause a violation of the Envimnment.al Protection Act or regulations promulgated thereunder. 7. The permittee shall maintain all equipment covered under t&ii permit in such a manner that the performance of ouch equipment shall not cause a violation of the Environmental Protection Act or regulations promulgated thereunder. 8. The permittee ahall maintain a maintenance record on the premises for each item of air pollution control equipment. This record shall be made available to any agent of the Environmental Protection Agency at any time during normal working hours and/or operating hours. As a minimum, this record sball show the dates of performance and nature of preventative maintenance activities. 9. No person ahall cause or allow continued operation during malfunction, breakdown or startup of any emission source or related air pollution control equipment if such operation would cause a violation of an applicable emission standard or permit limitation. Should a malfunction. breakdown or startup occur which results in emissions in excess of any applicable standard or permit limitation, the permittee ahall: a. immediately report the incident to the Agency’s Regional Field Operations Section Office by telephone, ~telegraph. or other method as constitutes the f-test available alternative, and shall comply with all reasonable directives of the Agency with respect to the incidenr; maintain i. ii. the following records for a period of no lew than two (2) years: of malfunction. breakdown or startup.
b.
i
date and duration
full and detailed explanation
of the cause. of emissions. , breakdown or startup, and
iii. contaminants
emitted and an estimate of quantity
iv. measures taken to minimise
the amount of emissions during the malfunction, occurrences and frequency of incidents.
Y. measures taken to reduce future
10. If the permit application contains a compliance program and pmject completion schedule. the permittee shall submit a project completion status report within thirty (30) days of any dati specified in the compliance program and project completion schedule or at six month intervals. whichever is more frequent 11. Beginning one year from the date of :his permit the permittee shall submit an “Annual Emission Report,” form APC-208. as required by 35 Ill. Adm. Code 201.302. (Note: If the permittee has other operating permiLs for this facility, the “Annual Emission Report” for all such permits may be included in a single annual submission.)
“POE5 PermttNO.IL0001554 1lli”OIL E”“ironmntal PrDtectlonAgency Dirtsion Of water Poll”tlo” Control 2ZOD Churchill Road P.O. 00x 19276
SpringField. Illl"OiS 627944276
Nodlfied
(NPOES) Perm,t Issue Date: Effective July 1s. 1965 1989 2. 1989
Explrrtlon
Date:
April
1.
1990
Hod!flc*tlon
"odlficatlon Nuns and Address of Permittee: Facility
0at.s:
ruqurt 14. 19as
Issue Date: ,"ru 2, Effective gate: July and Address:
N&m
Illlnols Power Cmpany 5.00 South 27th Street 62525 Decatur. xllinols gtscharge No. No. No. No. No. No. No. Number and Name:
Illinois power Cmpa"y ncnnepln Power Plant Hcnnepi". Illinois 61327 Putnam county Receiving 111inais uaters RI"W
001 Condenser Cooltng Mater 001(a) Boiler Blowdom 001(b) Intake Screen Uckwlsh 001(c) Roof Drain Discharge 003 Ash Lsgaon "2 and I4 O+scharge 005 Ash ‘lgoon #l and #3 Discharge 005(a) Chemical "eta1 Clernlng "aste
Treatment
System Effluent
the Act. Ylbtttle C Rules above-nerd prrittee recetrlng stru ,n
In cocqllmce rlth the prpvisions of the I111nois En"lromnt.1 Prptcctlm and Regul~tlons of the Illinois Pollution Control Board. and the WPCA. 1s hereby uthorized to discharge at the .bo"e location to the rbove-n-d accordance with the standard Condltlons and l ttachmnts herein. Permittee authortzatlon application days prior Is
I" ores* to I-CCCIVC not authorlzed tp dlsChWgC after the abo"e cxplrrtlon date. tp dtscharqe beyond the explratlon date. the PermIttee shall submit the prwr as rcqutred by the Illlnols En Irormmtal Prote tton