/Ii
ENHANCING THE USE OF EASTERN AND MIDWESTERN COALS BY GAS REBURNING - SORBENT INJECTION
ENVIRONMENTAL MONITORING For CWLP Lakeside Station,
PLAN Unit 7
Submitted Energy and Environmental Irvine. California 18 Mason
by Research 92718 Corporation
August
23,
1989
CONTENTS
1.0
2.0
SUMMARY ........................................................ INTRODUCTION 2.1 2.2 2.3 Process Background EMP Purpose Overall Material Emissions Purpose Current ................................................... Technology ....................................... of Project ........................ .................................... ...................................... ......................................... ................................. .......................................... ........................................ Requirements .......................... ......................................... ............................................. ................................................ ........................................... . . . . . . . . ....................................... ....................................... ....................................... t ruction ............................... .................................. .................................... and Scope I: II: Pre-Cons Construction Operation . . . . . . . . . . ....................................... and History and Scope
l-1 2-l 2-l 2-l 2-3 3-l 3-l 3-5 3-5 4-l 4-l 4-1 4-5 4-5 4-5 4-5 4-5 4-7 5-l 5-1 5-1 5-4 5-4 5-13 5-13 .............. .............. Sta It ion .......... ........ .............. .............. 6-l 6-l 6-1 6-2 7-1 7-l 7-1 7-l ..................... 7-2 7-2 7-2
3.0
PROJECT DESCRIPTION 3.1 3.2 3.3 Storage
............................................
Description
and Discharges and Scope Monitoring
4.0
COMPLIANCE MONITORING 4.1 4.2 4.3 4.4 4.5 4.6 4.7 4.8
Pre-Construction Construction Operation Post-Operation Permits Schedules Purpose Phase Phase Phase
5.0
SUPPLEMENTAL MONITORING 5.1 5.2 5.3 5.4 5.5 5.6
III:
Post-Operation Schedules Purpose Current
........................................... ................................................ .................... at CWLP Lakeside
6.0
HEALTH AND SAFETY MONITORING 6.1 6.2 6.3 and Scope Safety Program and Safety
......................... Monitoring
GR-SI Health
Purpose Sampling Sample Calibration Analytical Data Reduction
7.0
DUALITY 7.1 7.2 7.3 7.4 7.5 7.6
ASSURANCE AND CONTROL ................... and Scope Procedures Custody Procedures Procedures ........................................ ...................................... and Frequency
........................................... .................................... ............................
and Validation
i
7.7 7.8 7.9 7.10 7.11 7.12 8.0 8.1 8.2 8.3 APPENDIX A
Internal Performance Preventive Calculation Corrective Quality Purpose Reporting Monitoring
Duality and of Action Assurance and Scope Data
Control System Data of
Checks Audits
.......................... ............................
7-6 7-7 7-9 7-9 7-12 7-15 8-l 8-l 8-3 8-4
Maintenance
................................... Quality Outside Indicators Drganirations ................... ................
........................................
DATA MANAGEMENT AND REPORTING .................................. ........................................ ................................... ................................... Requirements Review
Operating
Permit
NPDES Permit
ii
TABLES
l-l
1-2 4-1
Project Project Lakeside Discharge
Monitoring Monitoring Station Streams
in in Permit
Phases Phase
I and
II
........... .......... .... .... .. .... By-Products .... ....... .... .... . ... . ... .... Plan . ... ....
....
III
in
.................
Requirements Lakeside Plan .............. ......... NPDES Permit
Monitoring Monitoring ....................
4-2 5-1 5-2 5-3 5-4 6-l 7-1 7-2 7-3 7-4 7-5
Designated Characterization
Supplemental Solid Continuous Supplemental and Aqueous Worker Calibration Continuous Preventive Critical Program Health
Emissions Gas Analyzers Monitoring Discharges and Safety Procedures Analysis Maintenance Spare Parts for
By-Product
.... .... .... .... .... .... .... .... .... .... .... .... ....
l-3 1-5 4-2 4-4 5-2 5-5 5-10 5-14 6-5 7-3 7-4 7-10 7-11 7-13
Plan for Solid ........................... Monitoring ......................... Instruments Procedures ............................ Critical ................ Plan
.............. Measurement
Objectives
FIGURES ElG!J?L
I!!m
Application for NOxlSOz of Gas Reburning-Sorbent Injection Control . . . . . . . . . . . . . . .._........... ....... .... . ... .. ..... ..... ..... .... .
3-1 3-2 5-l 5-2 7-l 7-2
8-1
....
....
3-2 3-4 5-7 5-8 7-5 7-14 8-2
Process Flow Diagram for GR-SI Operation During Peak Output ........ ........................ .... Continuous Phase Data Data Monitor Sampling Probe Procedure System Flow Train .......... .... Discrimination Reduction Management Action . .... .. .. ... .. ... .. .. .................. . . . . . . . . . . . . . . ..__.. Diagram ............
and Validation
Corrective
.. .. .. ..
. . . .
. . . .
....
iii
1.0 Energy demonstration fired of utility Department Energy demonstrate realized process. transported technology process. This at by Lakeside EER's technology monitoring GR-SI project, Act health develop to the specific impacts
SUMMARY and Environmental to the percent ash an evaluate Funding Resources. SO2 control of generation landfill. to eventual the Gas will Research for the The Corporation project objective and be is and of CEER) being the this is conducting for coalby is can will of of the the to be be the GR-SI a
project boilers. of and that through Bottom to is Energy, Natural 50
an SD2 and NDx control Institute.
technology provided project Injection and fly ash demonstration Illinois NOx control
Gas Research
Department
60 percent reduced
application off-site
Reburning-Sorbent Successful commercial
(GR-SI)
a prerequisite
application
volume Station
presents of
the City sites
Environmental Water in the at Light with
Monitoring and DOE, Power The describes Station monitoring the National project or 2) are
Plan (CWLP),
(EMPI one
for of is
Unit three required of of
7
demonstration cooperative that since which or the a data technology parameters. 1) will
EER project. Lakeside
EMP. which the the a key does will also is
agreement be conducted project. will that applicable mitigation for replication
environmental course aspect not be the this in human to related of site-
during
demonstration documentation to
Environmental supplement the standards, of potential of
monitoring ensure violate for and
Environmental detrimental problems independent to
Policy result used
demonstration monitoring the
environment. base
Environmental
environmental technology
Monitoring solid waste requirements discussed, to provide for utilize methods volume. Monitoring planning and for along further standard which
will discharges.
be conducted and other with
to
characterize and State, GR-SI are health
air and system
emissions, concerns. local which performance. possible. are described
water Monitoring
and are
safety Federal, monitoring the
compliance with information
regulations are
supplemental
requirements whenever available
designed EER will
about
EPA measurement no standard
procedures
Measurement in this
procedures
is design,
required construction,
during
all and
three operation.
phases
of
the
demonstration: summarizes the
Table
l-l
l-l
compliance ducted are will The the
and same
supplemental Phase as baseline listed
monitoring the monitoring
conducted requirements. which l-2 will GR-SI be
during
Phase
I and to
be con-
during provide parameters I and major . . 0
II
of data in
demonstration
project.
Compliance Supplemental will during remain will the
measurements measurements be evaluated. Phase same
current
against Table
operation monitored will
III.
as toward in
operation. Phases three
Compliance
monitoring
requirements
II.
Supplemental
monitoring
requirements
be focused
objectives: evaluate ensure create the that data project's the base project for success is GR-SI will satisfy (IEPA). prepared Section 1977. will goals be followed in Sy&ems. August action assurance Assurance been safe for employees and the environment technology be conducted the A Cluality according in 3 of Volume Internal Officer with if not have or be taken accordance the Qualitv mionarv quality independent deficiencies been achieved. of will the selected be data input in and all reports potential compliance of according of to U.S. with Assurance to CWLP quality the plan EPA's Source control checks are This Illinois for chain . Soeclflc will by the noted may tests. to a of the of
The compliance assurance Environmental supplemental Sample custody for Air Methods. test during involve custody procedures Pollution procedures,
measurements which Agency has will
requirements
Protection measurements procedures
EPA guidelines.
as recorded Measurement Quality quality of quality configured formats.
Assurance checks
III
EPA-6DD/4-77-027b. by EER's or the Corrective
be conducted supervisor. audits
recalculation Once data
derived has to
measurements been store. EER will will the verified, process, submit on also emphasis
repetition data
the
computer of environmental problem reports the plant's
system
and output quarterly data copies period.
a variety
operator-selected data to areas. submitted permit will be
and annual summaries of and
to
DDE with reports IEPA during
These status.
contain
reporting
a description
Data showing taken addition if
reviewed results This
by will
EER and
CWLP as
it to in
becomes monitoring monitoring
available. frequency, location.
Data action the EER
significant required. of
be reviewed, modification or change
verified,
and appropriate
may include parameter,
a monitoring
l-2
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will project.
review
data
continuously
throughout
all
phases
of
the
demonstration
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)
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
3)
If
recommendations to
made.
consider
modification
EMP and authorize
as appropriate.
1-6
2.0
Energy demonstration Technology SOz and technology (GR-SI). representing co-funded Illinois The process, purpose
INTRODUCTION and program. NOx and control the be range of of of this Tew involves produce in species zone. the introduction reduction with NO to air injection in which and excess and atmosphere burnout step, CaO, SOz/SOi is control of form to of slightly natural gas above by At the the the main zone. reaction heat Gas of which end injected or CaO of will the by the Department remainder the involves Environmental as The part project combination demonstrated pre-NSPS of Energy, Research of is the for of on coal-fired the Corporation Department to coal-fired gas reburning full boilers. Gas Research Resources. presents of the a description of project, the GR-SI and the three of utility with scale The (EER) is conducting Clean Coal This injection boilers is being the and effective a
project
Energy's a cost boilers. sorbent utility project Institute,
designed
demonstrate
technology
Department Energy this and
and Natural section history
background
demonstration
and scope i3ocess Gas reburning
document.
2.1
release reburning hydrocarbon react of into this the in
zone is the
to
a homogeneous,
oxygen-deficient nitrogenous intermediates
effective radical oxygen-deficient
NOx emissions produce N2.
downstream are as a sequential calcines where the sulfate.
fuel-rich furnace. of with to
calcium-based process the calcium-based sulfation to form with along the
sorbent sorbent step, solid coal
The sorbent
can be, viewed
coupling dehydrates reacts plant 2.2 The calcium
an activation produce gas-phase sulfate
and a heterogeneous oxygen removed
calcium fly
subsequently equipment.
ash by the
particulate
Backaround The technical demonstration boilers Illinois front wall representing Light fired. project the conducted range of by EER will pre-NSPS Station, boiler Unit focus on three
Illinois .
utility Central (net).
technology: 1: 117 MWe
Company,
Edwards
2-1
e @
Illinois tangentially City (net). Water
Power Light
Company, and
Hennepin Power,
Station,
Unit Station,
1:
71 MWe (net). 7; 33 MWe
fired. Lakeside Unit fired. has a total GR-SI in in two net operational generating is Illinois. normally by City Water coal-fired capacity a 33 This operates Light of steam 66 unit in and MWe. fired electric Unit 7. steam service. (CWLP) of
cyclone Station with the percent is located
Lakeside generating which electric factor Lakeside Springfield. The project and during II obtained demonstration Phase boiler system and information background During metric, baseline operating against parametric range emissions sorbents information boiler performance and and design the includes at permitting this phase this of of will units host facility 24.0 Station
demonstration, Springfield. 1986. and
MWe cyclone cycling
had a capacity Power
owned and operated
is to time. its
being
conducted current startup III
in
three emission of the
phases. Preliminary and GR-SI operation potential. Air
Phase tests discharge system. of the
I includes were levels. Permits GR-SI
design conducted Phase will be and
application determine and Phase
process.
construction
involves control
system
NOx/SOz emission has data providing worker been
I testing and about water
completed. recorded. of the
emissions data are
were being isothermal
monitored used flow will and in
and GR-SI models
performance thermal
were
These
verification computer safety models. during
physical Phase
performance pH levels.
II
monitoring process,
provide about
construction
Phase long-term
III.
of
testing testing. the The boiler results
will First, of will conditions
occur tests these be (without
in
three will
stages: be conducted under will
baseline. to of the a range
paraestablish selected baseline of operating the of and on
performance conditions. which to will GR-SI is determine be on the performance. in terms testing reductions,
GR-SI) tests evaluated. performance resulting and
provide The over
performance to evaluate the boiler
objective a wide best
system
in cost. and
the
balance coals will impacts provide
performance, as well. of The injection control.
Alternate evaluation long-term and overall
evaluated reliability including of
long-term equipment requirements
maintenance
system
emission
2-2
EM Pur!as
This CWLP's ment of tion the document for of is
and F&ae
the Environmental submitted reports. GR-SI by in Monitoring accordance with The EMP provides and health system at related the Plan the factors demonstration permits and (EMP) for Unit 7 at agreeconstrucsite, both
Lakeside monitoring and operation
Station, special of
cooperative during
requirement
a detailed
description
environmental the required purposes. will
compliance monitoring
monitoring for research
environmental
supplemental
Environmental the is other funding to effect boiler if monitor discharge will following and its discharges, emissions the participants control
monitoring to of goals streams
be one of the NOx emissions Boiler met. be to In and also operating
the
key
methods this will
used
by EER and The impacting to be and will Water basis. goal
determine
success
of
without
project. adversely measurements
SO2 and parameters. have will
performance project boiler
emissions addition,
be monitored
determine made to solid
been
performance prior
characteristics. on GR-SI a regular system
monitored
Measurements The process process atmospheric describes the demonstration monitoring section monitoring. ensure Assurance which Section reporting will also anticipated
be made both section impacts and and on
and during detailed
operation. of the goals Section Station of the Section 5. GR-SI is This to GR-SI for 4 and
provides ancillary control is by-product
a more
description including The project 3.3. Lakeside phases in the be 7. state conduct will Section and audits data
systems, disposal. are given during monitoring. any permit use safety. sampling for in
sorbent
storage,
Section at all or to described
monitoring project.
which
currently
required
compliance is not required the of for the to the worker project, ensure
monitoring by the health lists sample
Supplemental methods
that
regulation. conducted the
describes Section
EER will and the integrity, procedures
supplemental Cluality
6 discusses
monitoring
that
protection Plan be used 8 describes format.
analytical
procedures and GC checks. and the data
including monitoring
management
2-3
PROJECT DESCRIPTION 3.1 Several from coal-fired wall-. practices. species strategy. GR-SI and the of fired capture within 3.1.1 The concept decade. * The overall Main the region). conditions . Beburnina natural of heat radicals This such form as the gas total release in Heat total of reburning process Release heat The for can NOx control be divided - In to the burners reauire this boiler into zone, is operate modification. zone for is injected zone is the region of zone. with the may reburning intermediates, further by: react to of where the the main NO has been recognized zones. namely: GO percent (cyclone overall coal fuel-lean of feed for over a a simplified boiler. the boiler, coal-fired schematic Since it by calcium-based is combines of two technologies: for the in-situ GR-SI reburning sorbent SO2 combined by occur to in in the removal. process reburning different the and two for in-furnace or Figure when applied 3-1 to NOx control convective presents a cyclonedue to zones pass a retrofittable cyclone-, design precursor control Qwall . . Descrlotlpn are plants. which reduces therefore, corner-fired GR-SI and, available Gas is generally boilers the is that emissions expected to to reduce emissions Injection to characteristic both be an suspected effective of SO2 and (GR-SII a wide of range acid acid NOx is a of rain rain
technologies power technology and
Reburning-Sorbent applicable are of
pre-NSPS
injection
a calcium-based of
furnace
boiler
NOx reduction sorbents convenient
SO2 reduction and spatial processes
thermal
consider
separately.
three
Zone coal
approximately released under
input
and do not Zone is heat zone the by reduced and The
reburning and It create heat
injected, input. to main the cyan0 path
accounts a fuel-rich release oxidation
a maximum downstream reburning reacts of reaction
20 percent The fuel.
produced
hydrocarbon
formed produces amines
partial
nitrogen-containing compounds, which which
N2 by a reaction
can be summarized
3-1
c-
to
precipitator
I
I I.
III
‘I SudeC- I
t-
I I
Sorbent
c
L Storage
*I
Overfire
air
Natural Gas Feed Cyclone
P
v
Sorbent System
-
L
Figure
3-l.
Application of Gas Reburning-Sorbent for NO,/S02 Control
3-2
Injection
CH + NO -+ HCN + 0 HCN + OH -+ NHi + CO2 NH1 + OH * NHi + NO +
l
NZ + NO NZ + Hz0 burnout fuel-lean reburning either the reburning is in zone gas. to is the region and Nz. and the where air is added
Burnout to create are oxidation species adjusted stoichiometries of
- The overall the converted
conditions NO or zone maximized.
ensure reduced The fuel burnout
complete nitrogen and zone air are
Remaining
so that . . Ini'xbzn
N2 formation
3.1.2
Sprbent The use of
calcium-based extensively. sorbent. calcium oxide. solid calcium
sorbents which may This calcium in the
with be
furnace involves either oxide
injection calcination a carbonate reacts
for or or with
SO2 control dehydration a hydrated SO2 in the control
has of lime,
been
studied
The process
a calcium-based producing zone utilization
0
calcium sulfate. sorbent:
sulfation the
producing of the
Two major
parameters
Jhe readlvltv
is is strongly a function is
of the
dependent of Reactivity increased the
calcium
upon sorbent tends to the
oxide
surface type grain
formed
area as growth. and the
. bv calc1natu.n
of thermal the the calcine history sorbent
- This which of particle the
calcine. temperature
L
decrease
due to
.
.
IV@
tQ
sulfation 2250°F of the sulfation
- Significant because of time rate of in becomes important unreacted
sulfation and negligible the the active sulfur and
cannot below
occur limitations,
above
approximately and 1600°F. the rate Thus.
equilibrium particle capture coal fly
approximately within process. ash are this
residence is
temperature
window The calcium gas 2). stream sulfate. prior to
sorbent.
removed (see
from Figure
the 3-
the
stack
by an electrostatic
precipitator
3-3
;rr ;: -I SF.,k .r f5 E
3.1.3 As means results the coal Thus, levels heat use are of was in described in
r SO2 [;nntml Section level in the otherwise of sulfur by the 3.1.2. than sorbent gas reburning process by fuel available process applying injection with sorbent the is sorbent injection coal. for since This baseline the primary injection alone. of reduced SO2
SO2 control. a lower of which the is
However, SO2 offgas natural would amount gas
combining
The combustion input reduces
reburning be supplied in the reburning
replaces
20 percent SO2 formation.
SO2 control reduced.
enhanced
Gas reburning control is shown material 3.2 Materials are tests provisions to gas. 3.3 A coal-fired and output spent flow sluicing employed the truck fly output fuel streams sorbent. rates the after ash will by a dustless for streams. (coal include and bottom GR-SI include the sorbent. will be for furnace The coal . in in Unit 7 of Figure
and 3-2.
sorbent The
injection remaining streams
are
being A flow
combined diagram this during in
for for section GR-SI
NOx and SO2 the system describes operation.
CWLP's
Lakeside
Station. discussion from the
storage Material
and discharge Storaae will gas. The and plant pipeline. the is
plant
that natural purposes. loading by for
be utilized and lime, sorbent unloading. There coal. with will
during lime Natural are no stored
the or
GR-SI used limestone in will
demonstration in the majority tested with being be provided pile on site.
project of the for
The sorbent be stored
hydrated
comparative
a silo storage
appropriate directly for
gas on-site in
requirements
currently
a coal
and Olscw boiler The and bottom ash incorporating main inputs gas). combustion These 7 to in the natural gaseous ash. Unit stream the to and GR-SI the sorbent are 3-2. ash GR-SI to process system, for fly The pond shown contains as described includes corresponding practice continue is silo. to in unloaded to to operation, a of be SO2 capture. ash which with current will many input above, Major the
products, streams
Lakeside
Figure existing
implementation. unloader, and then
When the pneumatically transported
system
be transported
a storage off-site
an appropriate
3-5
landfill. sluiced to
When the the ash
GR-SI pond.
system
is
not
in
operation,
the
fly
ash
will
be
and CQ&& At demonstration percent. 5.05 The to lb1106 GR-SI the utility 0.95 lb/106 Btu Btu system constraint in Lakeside. project The current (2066 will for the is lb/hr this SO2 to at unit. to lblhr at rate lb/106 emission reduce full 60 acid at full of Btu. and Control discharge effluent the be present ash will of ash streams and upper in normally and water results to to which the runoff drains. of ground is will monitored This 3-6 the the furnace, bottom Phase being in the the is yard less on-site pond actually area to for or will the blown during which Lakeside it is ash. III. may be affected coal pile This and expected will When the disposed to ash, not and transported bottom pond. that by the GRthe rate load). percent thus rain rate full load) 7.33 the control existing from Lakeside based on strategy SO2 emission Unit recent reduction if is and Unit Lakeside and GR-SI lb/lOs 7 is There could when 7 is to (3 will lblhr remain for the level GR-SI by tests. no they NOx are be useful approxibe reduced The at full below 50
SO2 emission provide
approximately is
emissions
NOx control. regulations from through x 10-s load)
emission promulgated. mately to 0.38 is baseline load) the 3.3.2
NOx emission
response Btu (157 to of (392 lblhr emission increase 0.1
The current
NOx emission
expected Btu but
lb1106
implementation.
particulate expected limit Aawous The only two the is sorbent ash sluice the the coal will is
due to
GR-SI
process,
allowable
Discharm aqueous ash pond into will fly
SI the or via is will
system sorbent unreacted bottom in
are
runoff.
Since no spent system This pond the because
injected
be verified GR-SI dry. the
pH measurements
operation, reduce less ash
be handled
quantity no longer
because the fly qualitative
consumed, of pile
be discharged influent discharge The collecting
However, be affected. for
characteristics Lakeside yard and coal
The number storage a rain. runoff one of amount of
discharge the sorbent. coal of
a
building potential on the discharge was spilled.
surrounding the Lakeside
sorbent After pile
silo the point. which of
has the sorbent This is sorbent
spilled be washed weekly will discharge
a number whether
parameters, the water
pH level.
The pH level
indicate
a significant
passes
through
treatment of the 3.3.3 the lake.
plant normal
before discharge
being were
discharged increased,
to it
Lake could
Springfield. be corrected
so even before
if
the
pH
affecting
B-Product When the GR-SI The which unloader becoming dust pulled control. from ash If the for the pond. heat. dusty. The silo will mixes
DiSDOSal system will transport water water is
Svstem operating, the from periodically to fly the is is not GR-SI causes rate system by is control equipment can the ash. lime fly the ash via a-designated preventing in the for and ash GR-SI the ash proper the fly sluiced disposal, system GR-SI will be handled to landfill. the to material hydrate, hydration ash will to is the there not system a fly dry. ash The
The into
ash
will silo.
be transported
pneumatically be emptied the with addition GR-SI this the also material
ESP hoppers
storage dustless from and be will will generating
a dustless
unloader
trucks
The water When the Since additional dry handling the
controlled operational. system means when to of the
ESP hoppers
a hydroveyor current measures fails
existing operating.
be no need be shut down
operate.
until
equipment
be made operational.
3-7
4.0 4.1
COMPLIANCE MONITORING
EER has project requirements analysis, Station, result monitoring of to
evaluated aid of DOE in the that project. in
the National the
potential
environmental the necessary Policy Information are expected both this
risks Act.
associated to results for and The
with of
this this as a
preparing
documentation Volume on the
satisfy
Environmental Environmental effects Nevertheless, to is verify that of of
documented indicate this will
CWLP Lakeside supplemental
no adverse
environment
compliance
be required monitoring operation
conclusion. monitoring are though required specified some are in by State permits
Compliance regulatory obtained imposed In required of of the air
environmental these the obligations facility,
obligations. by CWLP for by general general, to Clean pollution meet Air
Most regulations.
requirements
new, the Act. control
modified However, equipment
or
reconstructed
sources specifically definition of
of
air
emissions exempt addition
are
New Source
Performance from the
Standards
(NSPS)
developed
as part that
EPA regulations
a modification
may trigger
NSPS 140 CFR 60.14(e)(5)]. currently discharges to the to the required by the existing monitoring monitoring the facility permits. requirements requirements to conduct Illinois to monitoring Environmental implement The at GR-SI Lakeside during all remainder at Lakeside Protection will of require this phases and of Unit 7 for Agency some section the the
CWLP is air and water (IEPA). modifications describes anticipated demonstration 4.2 IEPA emission requirements which will
Modifications existing compliance project. Current has source for issued and both
Station
Monitorlna permits a
.
w to are GR-SI CWLP for discharge summarized project. operating source. in Table Lakeside 4-l for Unit the 7 as an air monitoring discharges
water
Compliance
permits by the
be affected
4-1
TABLE 4-l.
LAKESIDE
STATION
PERMIT MONITORING
REQUIREMENTS
MEASUREMENT
SAMPLE TYPE
FREGUENCY
LOCATION
Opacity
In-situ
optical
Continuous
Stack
Flow
Rate
Single estimate Grab 24 hr Grab
reading
Oncefwk Twice/wk Twicelwk Twice/m0 Once/wk
Ash pond Ash pond Ash pond Ash pond Discharge C,';,"ia::;e Discharge Discharge Discharge Discharge
discharge discharge discharge discharge 008 coal 008 008 008 008 pile
PH Total Suspended Solids Oil Flow and Grease
sample composite sample
Rate
Single reading estimate Grab 8 hr Grab 8 hr sample composite sample composite
PH Total Suspended Solids Oil and Grease
Oncelwk Once/wk Oncelwk Once/wk
Iron
4-2
The monitoring been is requirement continuous operators requirements measurements copy of the
air
emission for indicate monitoring there include which permit is
source and particulate, that of may quarterly be
operating reporting but the emission particulate submittal in Appendix discharges System
permit no limit limit A high of averaged A. are
establishes exists for emission a list over of for S02.
emission
limits. limit has met the
requirements. to that
requirements.
An emission particulate reading any problem. and minute all a six is indicates
established
The monitoring being to Reporting opacity A period.
opacity. a
opacity
exceed
30 percent.
provided for water Division.
The Pollutant IEPA's plant. twelve are pond number lime the 008 total rate and copy silo two requirements
regulations Discharge Pollution and There are
determined and lists in in project. water listed Lakeside be affected silo. The Monitoring Monitoring readings Monitoring of solids the of
by the the Table coal ground
the
National through monitoring from the with There the ash of runoff, spills pH will discharge rate, pH. by the flow week. a per
Elimination allowable eleven which number pile around to the affect oil discharge 004.
(NPDES) The levels locations These by the other is for
permit, all are the
implemented discharges permit, 4-2. pile One is by any the of flow required discharge twice
Water
NPDES permit described GR-SI
discharge discharge streams. and runoff the coal the the sorbent pile
contributing discharges 008. which if will any by for discharge,
may be affected discharge
The coal may occur drain spills the solids,
could storage
surrounding
runoff
pond. weekly
indicate
normal includes
discharge. and total per iron.
required suspended once of the per
NPDES permit 004 of and
and grease includes pH and
NPDES permit
discharge readings oil of
determinations suspended month.
week.
measurements entire
grease
twice
Appendix
A contains
NPDES permit. concerning Air at Pollution Division. the property area shall emissions must be fugitive Rules and These boundary. ensure operated County plan is is required. that emissions Regulations. rules require Further, every an an under are listed and that operations source emissions of are in Part
Illinois 212. through emissions any fugitive program particulates Subpart IEPA's
regulations K of Air the Pollution
enforced within possible control area for
no visible
be observable particulate approved by
particulate
non-attainment emission IEPA.
Sangamon
attainment
and no fugitive
4-3
TABLE 4-2.
DISCHARGE STREAMS DESIGNATED
IN LAKESIDE
NPDES PERMIT
DISCHARGE NO. 001
DISCHARGE NAME Lakeside 1 and 2 Condenser Water Outfall Lakeside Equipment Dallman Industrial Ash Pond Dallman Lakeside Dallman Dallman Scrubber Lakeside Ash Pond Turbine Drains, Cooling
RECEIVING Lake Lake Lake Lake Lake Lake Lake
WATERS
Springfield Springfield Springfield Springfield Springfield Springfield Springfield Springfield Springfield Springfield Creek Creek
OOla ,002 005 006 007 008 009 010 011 003 004
Room, Boiler Room and Lakeside 2 Boiler Blowdown Cooling Water Plant Outfall Outfall
1 and 2 Condenser Wastewater Discharge Coal Coal Pile Pile to
Treatment Lake
Springfield
Runoff Runoff Cooling Screen Water Outfall
3 Condenser Plant Surge Storm Intake
Lake Lake Lake Sugar Sugar
Backwash
Pond Overflow Sewer
Discharge
4-4
4.3 Lakeside during operating compliance permits required. test 4.4 The discharges requirements, 4.5 EER expects be imposed 4.6 When the the If equipment the system the are GR-SI which GR-SI expected during results Phase I.
tructiQn Station In of in of later Unit Phase the although effect all phases I. 7 continues EER conducted plant. current during monitoring of the These Phase will program. I monitoring and to operate preliminary measurements required were under tests were by the conducted for existing to not air by permits assess taken the for
condition purposes. remained Records from
and NPDES CWLP as with
be available
comparison
fhmtructirm
monitoring during described required Phase in II will Table by IEPA remain 4-1. permits the for same as air the emissions current and water
monitoring
that the
no additional test program.
compliance
monitoring
requirements
will
demonstration was installed remains in operation. the remain
is for
complete, the GR-SI
CWLP has the system case, or the operate
choice having the before monitoring it unit
of
keeping removed. with requireproject or
equipment system to
intact. same
CWLP may In either as those
without ments
required
the
commenced. 4.7 The air demonstration as the addition Permits only permits source project of governing operating will others, plant permits, operation both modification currently issued of by the are IEPA. air permit the NPDES and The GR-SI as well
emission
necessitate including:
4-5
0
Air
Construction Waste Waste
Permit Hauling Permit Stream Permit are discussed below. of any about be provided. of data and controlled to the quantify ash permits. by the In if phase. from current in water equipment. discharges normally a decrease levels. in than coal the be in The 004 the the plant, quality The and handled quantity consumption. lake. at The the normal streams pH level and or only 008. dry of IEPA when the boiler of no operating details some cases. silo new the In emission proposed addition, including and the will
. . Requirements A source. equipment, information description uncontrolled entire have
Special
Supplemental for
new and modified is required application type. nature raw In this are size, of the by
permits IEPA must for
permit The
construction information
permit on the of
contain
including
efficiency. emission expected procedures, the sorbent new emission
and specifications. source and storage sources reviewed source. modification must other silo quantities
materials, operating case, considered
emissions. which
process. vents
requiring and At revised Lakeside, to must
An existing modifications modifications permit. the the startup construction or The are for
operating made the to GR-SI for and
permit any this expected system
must emission
be
require operating are in the
modifications characteristics. issued jointly construction discharge The changes to will in fly due to being ash plant are
application procedures
permit
contain
and operating unexpected
permits problems
IEPA perceives
complications The details must aqueous The and daily bottom Discharge addition will not Lakeside of fly be the
NPOES permit monitoring if from generated to to to 008 impact plant the the is pond pond normally water the do not Waste solid affected modified
regulates required there additions during are or the landfill, compared will which be treated
each at any
aqueous location. expected
each
NPDES permit
characteristics streams ash flow ash
modification implementation demonstration resulting to current before These reduced
by GR-SI
trucked
a permitted
average
decreased released higher to current for the aqueous
runoff
may have modification permit are is
a slightly changes to required regulated the
discharge. require Hauling
NPDES permit. GR-SI Resource fly ash hauler.
A Special Land use and
waste
disposal
by the
Conservation
4-6
and fossil
Recovery fuel waste GR-SI and
Act
(RCRAI. for pollution State from are a exempt
Currently, power from control of Illinois scale must A permit a manifest on final Stream pilot
high
volume such is Ill. required using
solid as waste fly
wastes ash disposal
generated and flue regulations.
by gas
burning from in
production. process (35 tests is
scrubber Any of special material waste final
sludge, waste is in disposal.
RCRA hazardous
considered Adm. by the CWLP's those waste coal
a non-hazardous Analysis this special to indicates haul generator
the
Code 809.103). who from
ash generated non-hazardous. some cases depending
accompany location. must is
disposal permit This
A Supplemental which stream partially is actually facility. chemical landfill operate in will to receive be accepted completed submitted The properties Illinois and a permit permit in
Waste the
be obtained required for by generate if they in stream this but the
for for
the any permit the
landfill new waste be must disposal waste's Any to
waste. draft and form the as the accept the
permit waste is
by a landfill. permit
The application by the generator, information used to waste waste obtained
application the
waste
application can to
requires process a special particular
about the have
as well
material. a permit
accept
question.
4.8
The timetable provided continued to demonstration months. schedule, may choose it removed. Phase and at below. for for Baseline approximately about program other to no cost (Phase will At the them. details. keep to various two phases weeks. after the is the of took the GR-SI demonstration during period of to design, the on Phase last outage Lakeside II. is project Phase The I. scheduled entire is and
monitoring
place initiation
early
The construction scheduled on final end of installed
be completed
16 months
III)
approximately schedule, program, Unit 7 or
la
load CWLP have
The exact either
schedule
depend equipment
demonstration
I - l&l months
Baseline System Permitting monitoring design (applications)
4-7
Phase
II
- 16 months (secure permits)
Permitting Construction Phase
III
- la months testing testing operation equipment removal
Baseline Parametric Long term Optional
4-a
5.0
SUPPLEMENTAL MONITORING
5.1
EER will which This upon is type three 1. 2. 3. not of conduct required monitoring goals: a basis that a data technology the phase and the I. . is the for evaluating the program health others and success will of not the demonstration to of 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 the this Create
demonstration or to base in the worker which future. from
be detrimental for replication
environment
safety.
may draw
This be
section made during
describes each methods. Phase
supplemental of the monitoring
measurements demonstration schedule.
which project.
have the
been
and will
corresponding
measurement 5.2
Pre _Construction required of of the to document by the baseline in and being modeling be made at values Some of Phase this for environmental monitoring took
Monitoring parameters place prior which to
may be affected installation emissions 5-I shows
project.
GR-SI equipment
NOx. 502. These and data physical will Oz. are
I.
measured plan early for in I design of Phase
Supplemental Phase as well inputs baseline I. Table and to as Phases gaseous
CO were monitoring utilized the
supplemental
gaseous
Phase
II
and
III.
as system beginning
verify emission
computer
studies.
Additional
measurements
III.
Other purposes. containing will ash generated was data A major a mixture in to in tested were of also obtained of the during GR-SI and spent off-site furnace under required Phase process sorbent landfill. simulated to
I for
is with
design the fly GR-SI During solid
and ash. Phase the
permitting stream waste ash was The This
by-product a permitted, test obtain
waste
unreacted
be disposed
I.
a pilot-scale
conditions. supplemental
information
complete
5-l
z r s! 2 .GI-‘+cI o)aIo)Q) -e-F EEEG .r .r .r .r
LLLL alalalal NNNN ‘E ‘E ‘E z 0000 CEEE 0000 “00” wwww
5-2
k G
^--AW”O<< r.(Da-aom -v-v-
_ _
0 2
IA .; .a%:
ci .r
waste admitted pilot-scale indicate
stream to that that test, caution satisfy further ash
permit a landfill. included dry of would increase will be the all
application, The the eight that observed required the of Phase standard during Finally. disposal classify the solid
which waste
is listed
required in no Table under The portion to
when 5-2.
a
new
waste results Leachate well the ash. indicates within GR-SI admixture. GR-SI
is
characterization serious
conducted The test problems. RCRA were ash passed to GR-SI that a concrete uses of the ash remains the
on the
parameters should elements ash there when to as is water ensure
pose
concentrations values filter that
specified hazardous. no that for other this project. liquid the tests was added
below paint The
indicating
temperature acceptable may not However, will
the
temperature indicate use as
limits.
preliminary this III of and
ash ash
specification
evaluation
beneficial
be undertaken
5.3
The only pre-operational sluice sluice water water The system. during stream For units unclear a result will will before if of the supplemental water inlet discharge. Unit To GR-SI example. 7 bottom verify operation. depend if the GR-SI sorbent upon pH level operation is in along III: the with due the this, the stream monitoring The Lake streams is not will (from Both ash the being conducted to and during the for Phase Unit II will be the ash
monitoring.
streams Springfield)
be monitored
including 7 bottom
be analyzed to will be be of during pH level
pH and sulfates. by prior the is sluice water found operation, the lake water to the to GR-SI and water stream. be 8 pH it water supply is or
expected water
affected monitored of the inlet
sluice
However. water of the to and bottom
some sluice 8.5 a rise ash. sluice
characteristics water in water the discharge
characteristics pH units
GR-SI of the
increase
Therefore, discharge.
sluice
be monitored f!hase
ODeratisn monitoring emissions. measurements is described of solid are in environmental by-products. described Section in 6. parameters worker more detail during health, Phase and below.
The supplemental will worker include health gaseous These monitoring discharges.
III
The
water
5-4
TABLE 5-2.
SOLID
BY-PRODUCT CHARACTERIZATION
CHEMICAL CHARACTERISTICS Mineral Analysis EP Toxicity Free Total Chemical Organic Sulfate Oxygen Phenol Cyanide Chloride Sulfide Paint Filter Test Demand CaO Carbon
Specific Pozzolanic
Gravity Activity
Fineness Soundness
5-5
1olxi The control evaluated ments of the is particulates. processes the 1 summarizes demonstration Gaseous NOx. and co, co2. monitoring in-probe continuous injection . . . . . For gaseous objective SO2 and during the of system output Other this project In is The particularly will the furnace to verify of air during plan that boiler all to for emissions aid GR-SI all in GR-SI can effectively will NOx. Table phases of be and 5the measureunderstanding
NOx emissions. operation. streams, parameters within emissions
addition, focus
performance environmental of the three SO2.
be monitored monitoring
occurring gaseous project. emissions 02. SO2 and designed capture. to
operation.
be monitored to overcome Figure developed Key features
during EER will problems 5-l shows of
the such
test use
program a special
include continuous stratification
SO2.
hydrocarbons.
system monitoring on utility Multiple
as gaseous the evaluation include:
a schematic the system
diagram of
of
the
system boilers. probes to allow
by EER for
sorbent
Rotameters Phase All Zero
accurate probes upstream for to
flow of
rate
balancing removal
discrimination heated gases six flow of This gas operating is in the to of using separated the potential sampling eliminate each of basis. a Beckman and span
components
moisture calibration
instrument are
measurements, sample. probe separation the from matter reduces insulated 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 flame in the
particulate probe has
contacting separate of
particulate. sample via
discrimination particulate Under This the above system. span economizer typical greatly particulate and gases Calibration on inlet particulate
probe. probe
been
EER to percent to heated in with measured
inertial conditions, from for system. the the the
effects gas All stream
SO2 measurement. 90 the and or and the A be monitored. gas sample to the 250°F zero at
is the
interaction
components
possibility gas monitors
condensation accomplished be ionization
sample
a regular
Hydrocarbons 402 heated
CHC) will
detector.
5-6
. II
; I I I I I I I zem-&s?an
_____
Exhaust A NO, _/
-----------------__ I
Portable
Cabinet
---_
7 I
I
Unheated.3/8" Teflon Tubing
---e-w
,-Heated ------
Enclosure
Discrimination
Figure
5-1.
Continuous 5-7
tlonitor
Sampling
Train
.
.5
F! 2 z n :: I! 3 : =
.
I
a
2. .a3 ‘5
l
. 5 L I ;:
i Y ;+ I: Y
.
5-8
separate the 3 lists
single the
point loss or
sampling hang-up to the of
system be used
heated for
to each of
350°F of the
will sampling
be used system.
to
minimize Table 5-
potential
hydrocarbons
in the
instrumentation of can at system, the sampling SOz 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
active
particulate calcium in to
SO2 with higher inlet. possibility EER will Because
unreacted SO2 capture Due of perform the at the outlet primarily to
presence reported of
levels the the interactions
probe the system,
importance primary will for not at diagnostic to the
between removes nearly be the
SO2 measurements subject economizer purposes. confirm provides emissions of checking balance. of 200 if ppm the of other mass than Also, boiler an
precipitator from also
precipitator
particulate. will
SO2 measurements reactive and will 02. The boiler based (HC) excess on the a standard be taken of
interference
particulate. be used
Measurements
Concentrations operating 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 conditions. of the to
CO, HC. and 02 air and fuel
CO2 will is
be measured in the flue convert and a
concentration
gas a means
used to
condition. concentration CO and HC will
The CO2 provides composition provides of be outlet CO is
02 measurements hydrocarbon efficiency. boilers.
a carbon relative less to
indication determine
The concentration in emissions the economizer
typically completeness.
monitored can be used
a change across balance. utilire with the
OF combustion
CO and
02 stratification
as an indication
EPA Reference continuous in
Methods monitors. Phase Method will during III
to once
verify during
the
emissions 3 will for
measurebe used to and of 6. during SO2 to 5 the than
EPA Method 7 will be used
02 measurements Operation.
baseline using testing 6 to is used the
testing verification EPA Method and once measure
Tong-term
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
a modified particulate out-of-stack large at potential
sample
gas. rather
A Method the build-up system. further
Method
6 sample minimizing will
reduces outlet
sample to
6 sampling
be conducted
precipitator
s-9
TABLE 5-3.
CONTINUOUS GAS ANALYZERS
I
I
GAS MEASURED so2
DETECTION PRINCIPAL NOUV Chemiluminescent Paramagnetic Nondispersive
Infrared
MANUFACTURER Western Research TECO Taylor ANARAO ANARAO Beckman
MODEL NO. 721AT IOAR OA570 AR500R ARSOOR 402
RANGE O-5000 ppm
I
I
I O-2.5 ppm to O-10.000 ppm I O-IO%. 0-25x
NOx
02
co
co2 HC
O-500 ppm to O-2.000 ppm I 0-25X O-50 ppm to l-l-7!i%
Nondispersive Flame Ionization
5-10
minimize regarding
the data
potential quality oxide of in kept these
for
Sot/particulate can be found
interactions. in Section 7.
Additional
details
assurance (N20) Phase sampling crucial, constituents. will and the end additional emissions Method 17 will impactors. flow grain relatively the low rate will III.
Nitrous long for term S02. then of
be measured Samples flasks since N20 occur monthly of this once for until will
during analysed. to
baseline, Removal be formed will be three will tests.
parametric dried, of all from
and scrubbed
testing particularly
be extracted.
moisture NO in by during the gas times the to
and SO2 is presence during long determine Total using Particle using because time the more entering will particle during the long with outlet the chromatography.
N20 tends analysis during the time,
conducted several be months
Sampling testing, At for need particulate tests.
baseline first results
parametric term the
analyzed
monitoring. will and also of at be measured the outlet at will flow The 2. and the cyclonic velocity rate resistivity flow will testing, of be impactor impactor An Andersen high grain with sample a Wahlco Method loading. be measured this at using the will the precipitator Reference ESP inlet be used allow of will this of probe. at and the inlet Method outlet inlet sample at is gases 5.
EPA Reference size in-stack the low a high because for ESP will using cascade sample inlet
distribution
A Brinks loading.
a longer
impactor
be used sampler the Velocity taken
the
appropriate be measured size baseline term
be measured
EPA Reference resistivity. once during
Measurements
particulate. once during
distribution. operation, operation. Bv-Products by-product of to be operating. must of unreacted the obtained
parametric
and once
5.4.2
Lolid A major
OistLlm!a the GR-SI and spent mixture and will landfill. analyzed process SOFbent be In for is the fly dry to solid ash. in waste a silo stream GRfor the and
containing SI ash, physical system samples subsequent
a mixture is disposal properties.
with stored Order
When the
a permitted
characterire constituents
chemical
During will with a scoop
the from
second on a,daily the
stage openings
of basis
Phase in the
III.
parametric and
testing, Samples placed will
the in
GR-SI four-ounce
ash
be sampled
by EER personnel. ESP hoppers
be obtained
5-11
sample stored beginning will end to
containers in then a clean. of
with dry
screw testing for the third follow-up analyses in Phase with
lids. when stage results
Sample Ash the of purposes Phase will waste
containers samples is III. will first
will be
be
labeled at the trends
and the first At the and
environment. screening
analyred for
parametric period in
generated. basis to define testing.
Analysis
be conducted three-month appropriate preliminary generated verify Tests listed will the will and also screening on fly addition to fully limited ash to a verification
on a monthly long-term be evaluated
three-month of the determine The scale to data to be used require were metals will addition. operation. which major for noted In
period.
analyses. will I. data be waste from for conducted in full These solids. density. aromatic particles will data, from from If are testing, basis, to any present monitoring analyses Screening pFOCedureS the the composition unexpected at need. for test certain when results stream the physical 5-2. the color. for permit, scale tests comparison 5.2. facility include the IEPA is during characteristics analyses Characteristics procedure. specific which Also gravity. may for since with data pilot will GR-SI expected
As described
Section
supplemental be performed in anions, traits tests or pH, such for
and chemical Leaching and
previously
Table using as
constituents
and total
be determined
EPA EP toxicity
be physical
polynuclear carbon of
hydrocarbons be conducted. the data and
be adsorbed In be add from with present constituent three-month will the EER in 5.4.3 During Unit the from disposal 7 will current Lakeside screening used to
unburned
verification the data GR-SI.
pilot-scale of ash
analyses
will and to
ChaFaCteFize existing to for OF if in the data similar ash.
by-product base Results
GR-SI
~process. characterization will
the literature in
processes the will
analyses
be compared are the first from also aid levels, the results will constituents
consistency. constituents long-term been as a future
constituents After
unexpected
be identified
period tests
be conducted determining
on an as-needed have if handling
be determined require
evaluated. or disposal
modification.
normal be handled
operation pond,
of
the of
GR-SI dry.
system. with Units
the the 31.
modified ash will fly 32. ash and by the
fly and 33. IEPA
ash bottom The
from to ash ash
and disposed 8 and Oallman monitoring
The bottom
be sluiced
ash disposal Unit pond has current
and co-disposed Station requirements
imposed
through
5-12
the
National
Pollutant will bottom the remain ash sulfate Unit during to The
Discharge in effect Unit of ash is operation also if of with 7
Elimination during is not injection sluice in Phase near changes in background will ash. discharging--both the
System
CNPOES)
permit.
These
requirements The SOFbent level Phase of is SI measured and
demonstration to
project. contain To verify into the GR-SI water sulfate or effects if relative (by any any this, pond sulfate intake. levels of of the operation levels This the GRor not will unreacted the will pH be in
from the level GR-SI
expected System. discharge
OF products when and
from
sorbent the
7 bottom will indicate are is pH level mixed
before
II
III.
the in
The sluice pH or levels indicate If the action effluent
pH and
Lake
Springfield discharge sulfate (based EER will the If
be measured observed
necessary system.
sluice calcium change unit),
due to
changes the the
discharge bottom
sorbent pH does
on background the maintain GR-SI of relative
pH levels). pH increases watch a close
no further on the pond
OF monitoring more than pH level
be required. re-evaluate
substantially procedures. solid by-products were
1 pH
and will
bottom
ash management for 5-4. both the
A summary discharges 5.5 The operation environment with will Phase program the CWLP does not of no is is
monitoring in Table
and
the in
aqueous Phase
listed
No measurements
conducted
I.
Yost-Ooeratim supplemental stages produced GR-SI system, operate this is monitoring designed by the the the to GR-SI conducted Identify system. If effects when this All off anticipated site during instantaneous CWLP elects will project by-products in when to is already the construction effects operate be complete, generated the on Unit there during facility. demonstration known. and the 7 If
environmental equipment of concern. is be disposed
GR-SI effects will
be no environmental
III
program
a permitted
Therefore,
supplemental
monitoring
complete.
5.6
Supplemental construction baseline lasted tests for and for monitoring operating gaseous phases emissions two weeks. will of be the occurred required demonstration during the only during middle of fOF the Phase preI and
program. monitoring
Preliminary determining
approximately
Supplemental
5-13
5-14
pre-Operational defined months, Table the schedule as 5-1. for the including
water operating
quality phase
levels testing, of
will
occur have the aqueous
during a duration testing, schedule and and solid
Phase of which Table
II.
Phase
III
is 18 for a
and will describes gaseous of
approximately testing. be 5-4 used provides will
baseline earlier, monitoring
parametric
and long-term
presented supplemental
supplemental
emissions,
monitoring
waste
discharges.
5-15
6.0 6.1
HEALTH AN0 SAFETY MONITORING and To protect the &gpe and health This during the section GR-SI at as the of plant describes project. Stand Health be applied 29. specific including and and Health, Part to Administration nationwide 1910 each public of the to a Code employees. the safety and some general current safety health safety program
safety as well
practices at Lakeside will which
must
be followed.
Station, be conducted ljrrrent
additional
monitoring
6.2
The (OSHA) variety of Federal industry, Sub-parts Surfaces. Hazardous All has of
Safety of
Proaram Labor's of These These are
CWLP Lakeside Safety can in are general. Safety Health Title not
Department produced industries. Regulations. but Means Materials. utilities Department including for new cover of
Occupational standards specified in General guidelines as which
a set
particular utilities.
most topics Egress,
industries such Occupational
include
Walking-Working Control. and
Environmental
are
required an which
to ensures Station.
follow safe
OSHA's safety working CWLP's of of sessions indicate all
standards program conditions program
listed through at includes
in the all
29 CFR Human CWLP safety Sheets
1910.
facilities. training (MSDS).
but
CWLP maintains
additional
Resources
Lakeside equipment, and Mandatory Sheets to is utility. which
safety Material are the
availability distribution training and (MSDS) available This additional procedures and fire, Dallman severe which to
Safety manual conducted are In and hazards describing explains by in the and to
Data
and
development handbook.
a safety
an emergency familiarize with is OSHA safety CWLP of an properties there the the CWLP for event safety provided
procedures personnel Material of all the a Safety regulations standards. personnel. employees emergency and other
with Safety Manual of and The at the such
new equipment
Data which the provides emergency Lakeside as flood.
procedures.
Employees
and
substances
workers
may be exposed. employees reiterates provides facilities hazardous manual
addition,
guidelines handbook generating weather,
developed
instructions material
incident,
emergencies.
6-l
CWLP has Physicals an extended 6.3 are
a program required for
to all
provide
physical
examinations and those
for returning
all to
employees. work after
new employees
absence. &R-s1 HUand the is health a top In in will Station. which be governed personnel standards monitoring with and and is may occur required and asbestos plant asbestos construction qualified will be satisfied, and proper EER and CWLP will required anticipated abatement piping at the for to to plant the due to for abide activities are insulated will work include be with including disposal verify that All construction by them. during be required the addition phase this of listed will No additional phase, survey. to the in be be and priority general, the Safety the safety to the primary . .
Maintaining the in GR-SI effect, project as to GR-SI practices
of the
all
employees practices will remain of
during management which in effect guidelines
the are for
course currently during
of
EER project safety source
team
as well the
CWLP management. as described and Lakeside at project
Manual,
safety
Any construction GR-SI informed health except process of and that Boiler minimise necessary will material. applicable guidelines, When the are being Prior heat will All these safety associated tubes loss, modifications The contractor's OSHA and air contractor implemented. to the
by OSHA standards
construction.
19 CFR 1926.
and a safety with required
other some during
asbestos to perform
handling to
activities.
asbestos
removal that all
be conducted
by a contractor EPA regulations
asbestos-containing asbestos proper removal measures
specifications requirements, on site,
a requirement
monitoring is
considerations.
initiation
of
Phase
III.
of
a safety this survey and will and
survey is to be are
will ensure met,
be conducted that: specifically before
by EER and CWLP personnel.
The purpose have dust, arrive. and
1)
2)
All related All test
OSHA to testing
regulations noise, facilities
been safety
and asbestos:
equipment
available
personnel
6-2
to all
In addition, GR-SI operation
will employees' for test project.
monitoring and results
of annually for will who
worker hearing will are
health and
will until pulmonary
be conducted, project function. all
both
prior of the and plant
thereafter be maintained expected
completion. Records throughout
Monitoring demonstration available operations Noise determine areas process three dB. the are or These to
be conducted
confidentially for to be associated
Monitoring basis. is of required the area increases for will be level' installed where Phase of III. program time program months to check of program. governing to could or 2.4,mg/ms of for (higher the plant
be required
EER employees with
CWLP employees
on a regular monitoring which areas established. equipment required blowers determine of the the areas beginning 'action
by
OSHA regulations hearing not noise areas noise are level. which level is required
(29 protection.
CFR 1910.95) Once a change levels currently worker be above will exposure.
to
in that 85 be only
require decreases system in 85 dB.
these
monitoring or installed of GR-SI
unless noise
EER anticipates do not
blowers OSHA noise
may produce Therefore installed noise
exceed
monitoring and required
required Monitoring once at
equipment these fans
will
A hearing will The within annually who have hearing exceed hearing the an equivalent
conservation eight level six hour
must weighted noise requires
be level to
instituted average over monitoring establish in hearing will of
if 85 of level.
employee decibels time employee All included
exposure or period). hearing level, in and the employees an
exposure first
a shorter a baseline be
conservation
exposure,
a change noise
thereafter, a possibility conservation OSHA regulations
excessive
exposure
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 mglms It
that or a is from with to
employees coal the visible determine exposure and dust compliance, is dust sorbent. anticipated
not level
be exposed of the will that dust coal.
a total
on an eight-hour be generated the fly and If and controls shall ash. workers levels are are be used. engineering During
average. operation areas be evaluated
dust limits,
be monitored, exposure. administrative When such measures
task
employee
allowable identified full for
be
implemented. protective anticipated.
achieve monitoring
6-3
The only include procedures well good industry handling for established.
particular of All practice. natural transporting
safety gas. and hardware Gas
issues sorbent. utilizing
which and
are the
unique solid gas in will unusual
to
the
GR-SI
project Safety are with this
by-product. boiler problems furnaces for be consistent
natural installed no poses
and controls firing
application. The baseline will caustic According lime but will is plants not be hydrated irritant to the show injurious for procedures the mask human exposed and tight are is waste in the which oxide release. hydrate than the There those sorbent lime and that to all and contact to the fitting expected considered product particulate have been material However. material are described is used in in the GR-SI fine hydrated working suppression the powder. will glasses sorbent lime from powder safety dry necessary. generated collection sulfated will controlled completely no specific in Section in the process is the This as some exposed of neutralize fly mixture unreacted to the moisture product the for of ashjsorbent contains calcium with will the solid with demonstration to lime system.1 systems be studies can be Material lime are at powder suspendable performed irritating Safety and will all with and side workers shields. available Lakeside form and if Data which a lightweight Minimal no additional Station that is a in inhalable. inhaled, Sheets will be posted. who will
[CaCOH)z] Lime from those dust with the
a fine
(micron-sired)
sufficiently
National dust
Association,
on workers
respiratory
be available
hydrated In addition,
Handling minimize be directly filter safety health
be provided with utilization.
problems monitoring The only
mixture sorbent oxide. significant
caught particles
equipment. as well hydrate when and monitoring 5.4.2.
The calcium heat to is it
hydration
be performed before spent by-product Table conducted safety sorbent
material
disposed. other
requirements monitoring
discharge. 6-l during shows Phases the II worker and III health of the during and Phase safety I. monitoring project. which will be or
demonstration
No health
monitoring
was conducted
1 National Lime Association. "Lime Bulletin 213. Nationals Lime Association,
Handling. Arlington,
Application, VA, 1982.
and
Storage."
6-4
TABLE 6-l.
WORKER HEALTH AND SAFETY MONITORING
PLAN
MONITORING
PARAMETER
FREQUENCY
LOCATION
No monitoring
Safety
Survey
once
All
applicable
areas
of
plant
Dust Worker Hearing Pulmonary Noise 1. Level Function Health
as required annually Cl)
Areas N/A
with
visible
dust
once
Near
fans of the
Initial screening must be conducted prior GR-SI system. Annual exams will continue demonstration is complete.
to operation until the
6-5
7.0 7.1 This project the the 7.2 GA currently
QUALITY
ASSURANCE AND QUALITY
CONTROL
section
contains the for at for the
the
Cluality
Assurance will
(UA) described
plan in prepared
for this as
the they
GR-5.1 are to
concerning procedures practiced
supplemental compliance plant. quality
measurements monitoring This GA plan plans.
document: according
continue
has been
EPA guidelines &mplina Sampling
assurance
Procm for each in are have in to measurement 4 and and where to 5. be employed The sampling in more conform are with air-dried however, measurements. 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 all
the
measurements grade For chemicals samples. example, are
specifications
methods. appropriate as are
Reagent solutions. as is for
exclusively. container probe rinsing. preservation
collect containers practical: these
particulate after no special
acetone-rinsed, analyzed times
holding
Many involve not sample assurance measurements particle to verify analysis. particulate impactor the require
of
the of
measurements continuous procedures. on any
to
be,employed or other work related will measurements, for particulate filters, SO2 and 7-l in All compliance
during
the
GR-SI
demonstration which stringent quality are and on the test ash supplemental method do
use
monitors EER will compliance
measurement monitoring closely sampling. with physical the
methods requires CWLP's The custody
custody groups loading the
custody
procedures. generating accuracy Samples on samples
that
require SOz and
and particle of glass Samples the collected
size
EPA reference NOx measurements, characterization washes are and liquid
continuous fiber for
include cascade samples
matter substrates.
probe
NOx verification
containing sample. defined Section by
SOz and NOx collected EER will 3 of Qualitv utilize legal Athe EPA for sample
in "chain
aqueous of custody.
solutions, These Air
and
the for
ash all are
is
a solid as in listed
custody" for
procedures procedures
samples
Yolume
1977. 7.4
III
_Stationarv .
Source
. Soeclflc
Pollution EPA-600/4-77-027b. m.tmb.
August
Calibration listed system. accuracy 7.5 Continuous OZ. NOx. were interferences recorded test with results. The monitoring measurements analysis outside procedures. 7.6 Figure collection sampling each dent check of and 7-1 of EPA and specifically in of Table Each the
procedures 7-1. system Standard will is
and
frequency at to
for
each
measurement will to be ensure standards.
system used for that
are each the
calibration traceable
procedures a frequency the calibration
be calibrated
measurement 1 Prow monitoring selected possible. a strip
instrumentation is to Test data recorder described the the to from provide
to in
be used Table
to 7-2.
analyze These will
CO. HC. COZ. instruments and minimum of
SO2 concentrations
highest instruments
sensitivity permanent
be continuously documentation
chart
provide
standard use other
procedures listed standard in who aqueous have their in
given Table and 7-2. procedures.
in
Table Where samples Some
7-1
are
used the be and
with such calibration
the as by
instruments parameters
possible, will
remaining
measurements
solid own
conducted
laboratories
instrumentation
tion shows the to portion The test
and Valld&&aa general validation of each to
.
reporting and results verify
scheme reporting are the then
for of results
each results.
measurement Following calculated to
from the for
raw data analysis
measurement.
are
measurement. by the
preliminary supervisor
subjected
an indepen-
following:
7-2
7-3
TABLE 7-2.
CONTINUOUS GAS ANALYSIS
INSTRUMENTS
I
GAS MEASURED
DETECTION PRINCIPAL Nondispersive Infrared Nondispersive Paramagnetic NDUV Chemiluminescent Flame Ionization
MANUFACTURER ANARAD ANARAD Taylor Servomex Western Research TECO Beckman
MODEL NO. ARSOOR ARSOOR OA570 721AT 1OAR 402
RANGE O-500 ppm to O-Z.000 ppm 0-25X
I
co
co2 02 so2
0-10x
0-25X O-5000 O-2.5 ppm ppm to ppm I O-50 ppm to 0-25X
I
NOx
O-10.000
HC
7-4
Sampling and Analysis
NO
I
i Calculation of Results
, Yes calculation,, Errors Made?
Independent Check of Calculations, S&A Procedures, and Experimental Conditions
Pass
Fail
+ L
Invalidate Data
,
I
Correlate with Other Results
Double Check Calculations, S&A Procedures Exp. Conditions
Fail
'I
Invalidate Data
Validate Data and Add to Data Base
I Quality Control Checks
Reporting
I
FIGURE 7-l.
DATA REDUCTIONAND VALIDATION 7-5
b
Accuracy Proper
of
calculations and analytical experimental sampling are with with 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 then or results data procedures conditions analytical to are procedures. Results identify subjected to passing potential a double or under the nonchecks check of
e . Data are obtained then not
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
(lualitv
Control
Checks quality control program which will include
an internal
the
following . . b The
calibrations audits quality
and maintenance control checks for data collect of all an Id Lion will frequency also be and are
engineers/technicians for in routine 7.4. calibration Specific systems. Section
responsible and calibration
responsible measurement discussed
maintenance
instruments
procedures
7-6
The measurement requirements The The quality 1.
EER Duality systems are met.
Assurance and These also to
Officer to are
(DAO) will ensure discussed a program are listed in
conduct that all Section quality
internal quality 7.8. control
audits assurance
of
procedures audits administer be used and checks
EER OAO will control Calibration -
of below.
checks.
checks
Standards equipment reagents zero Control blanks spiked surrogate charts samples and span Samples
Devices
gases
2.
Duality -
samples
3. 4. 7.0
Replicates Control Perfore
EER will system system analysis, collected. assessment 1. 2. 3. 4. 5. of audit used data is for
participate an the on-site total audits following: .
in
and
conduct and for
system review system each
and of
performance the quality collection. sensor appraisal
audits. assurance sample or and sample include
A
inspection measurement etc.) are normally
(sample monitoring
processing, the
System
a qualitative
. Droanizatron organization Sample available Samole are these
and Bpy)nnsibllltY operational? these - Are it Is used? written to Are followed written a list
.
.
-
Is
the
quality
assurance procedures available and
Collectiou and are Analvsb followed
written
sample-collection as written? analysis of criteria procedures a review traceability sensor. procedures for
as written? data available should of validation and are
Data Validat1ou available and is Calibration these of schedule followed procedures and data - Are
calibration In establish addition,
as written? used
be made
calibration
by measurement 7-7
6. 7.
Audj& reviewed?
- Are
control Tests Maintenance
charts - Are Is
for
performance from preventive the DA plan?
audits
reviewed? testing schedule
Lnterlaboratorv &eventive being followed audits the
results the in
interlaboratory maintenance
a.
as recommended refer quality to audits independent of data
Performance auditor analysis to evaluate system.
checks produced are
made by the by the total categorized
supervisor sampling
or and
Performance audits audits
generally
as follows:
1.
2. 3. These control having the audits
Sampling Analysis Data are audit of charts that
processing performed by the
audits independently operator/analyst. or. in the case standards and of the the of and in addition can from sampling into the external subsequent operator/analyst. operating conditions. from several the one The or the to normal be quality by the
checks the routine or
Independence operator/analyst of
achieved by analysis results standards if possible, of
made by a different external by the without recorded audits routine of Audit meters a. b.
C.
one conducting or
measurements interlaboratory
analysis.
introduction system should to on control ensure
reference comparison, supervisor. the results made the
sampling plotting reference
The use of normal
be applied
knowledge reflect by most
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.
&mplina flow system:
- The reference rate
of
calibrated collection
and flow
standards
sample
devices calibration calibration auditor is gases. commonly for when applicable a portion or
instrument instrument Audit& of several - The
2.
Bnalvsis aliquot
provided
routine
samples
analysis.
7-a
3.
Q&a check
Prow on in the
Auditi calculations, data of by review
- Data and these quality
processing commonly involves a spotdata validation may be checked by system data. program system evaluation Where and of discussed performance conformance the AsII, will types EPA-600/9-76-005, where conducted audit samples, no EPA by be of audits in Section audits. with will the be a dummy set of raw data validated control
inserting followed As 7.7, These the audits part of will according Pollotion 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 accuracy, quality that During Preventive equipment this quality malfunctions. and critical routine to detect maintenance to the will Test be procedures
processing
EER's provide
internal conduct in the
EER DA0 will specified to
independent DA plan. Svsu, August developed. and
a comprehensive procedures
requirements conducted for March audit following etc., Air
applicable, in ~&litv I For audits the systems. evaluate identify the and
the
specified Volumes 1977. the
Measurement EPA-600/4-77-027b. have for each initiated the audit, been EPA guidelines specific the
measurements
substituting measurement
EER QAO will If the will audits in
results The results
and
report of all
Supervisor. action
DA problems, 7.11. in the quarterly
corrective monitoring
as discussed
Section
and any corrective
be discussed
Maintenance operation project, and data maintain are Tables spare and allow parts is essential utilize an 7-3 for inventory and and the of m of the each of of the this data Project data quality to for listed goals are to 7-4 to obtaining of list critical data systems. monitor problems. standard quality for spare loss In measureroutine parts due addition equipment to to
EER will collected
standard
procedures
minimize
maintenance
measurement continually equipment
procedures.
EER personnel correction alitv
accuracy, will and
and
completeness over are critical of 7-9 goals
be monitored assurance completeness
duration measurement
project
achieved.
TABLE 7-3.
PREVENTIVE
MAINTENANCE PROCEDURES
EOUIPMENT
PROCEDURE INSTRUMENTATION
FREOUENCY
Calibration Instrument Conditions Leak Check System Clean Tips Sample Filters Sample Flow Probe Probes
Gases Operating Sample Filter
Verify
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 flow with in
Daily Daily Weekly, or as required
Rate
Verify Verify
constant constant
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 EDUIPMENT Sample Nozzles Pump Oil Manometer Fuses Glass Nozzle Sample Probe "0" Filters and Liners Rings Oil Pump LABORATORY EDUIPMENT 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
in
Table
7-5. to
The allow control to identify in will charts for the at
confidence the significance will
interval of
will the
also results
be to
determined be evaluated. basis any for
for
each
measurement Ouality and to 005. a loss accuracy show charts Control of
charts
be maintained a loss of or deterioration and maintained to monitor The
on a daily control in data precision standard in quality quality
precision and Ouality to s. indicate of of lines results each each will control of a data the cause
immediately improvement will any be utilized measurements. as the the limits is will being the warning will and will
measurement control. in and EPA-600/g-76-
any trends
control
be constructed
as described and
control will and Initially, measurement
accuracy
measurement measurement be established limit. previous base of the of exceeding loss
be plotted mean of 22s for these programs limit before 20 determinations
relative limit be
deviation. Control for the based as necessary project. to determine quality on
accuracy
determinations. and 23s established for to this review
be modified
after
15 to the of
obtained validated.
Measurements
warning control
be subjected
7.1.1 The 1.
Larrective
following DA Goals precision. - .
1.1.
Actian
occurrences Not Achieved will require - This corrective includes the criteria action: failure to achieve in during the
accuracy
and completeness - Deficiencies audits.
specified
Section systems
2. 3.
Audit andfor between
Deficiencies performance orv similar
may be identified - This by separate advisory exist. schematically to and will the attention The the above. compare actually that the includes
Quparison samples
Problm analyzed by the
discrepancies significant This
laboratories. Subsgroup that
4.
Sianificantd involves environmental a determination and action of any of what (TS) determine if,the goals. project health procedure the the data If it problems are is concerns is
The It Test then goals achieving is the review, to
corrective responsibility
shown bring listed
in
Figure of the
7-2. EER
EER OAD to suspect.
Supervisor determine
TS and OA and
OAO will project in too are
specific
OA problem determined 7-12
cause
a problem
OA goals
I
QA PROBLEMS GOALS NOT ACHIEVED PRECISION ACCURACY COMPLETENESS EXTERNAL/INTERNAL AUOIT PERFORHANCE INTERLABORATORY COMPARISON FAILURES
I
REVISE DA AND/OR PROGRAMGOALS BY CIAO AND TS
1 SOLVE PROBLEMS 1
I
REVISE DA PLAN BY PE I BY DA0
t
OA PLAN REVIEW/APPROVAL BY DOE
REPEAT -1
EVALUATE NEED TO REPEAT TESTS BY TS AND DA0
OK
t
REPORT INCIDENT TO TS AND DOE
TS - EER TEST SUPERVISOR PE - EER PROJECT ENGINEER OAO - EER DUALITY ASSURANCE OFFICER Figure 7-2. Corrective 7-14 action procedure.
CONTINUE NORMAL TESTING
stringent, The OA plan If will system problems include remaining EER project the
they will
will then
be modified be revised project of the (PE). as solved. will goals subject The required. the
to
reflect
the
current
project
objectives.
by the are
GAO accordingly. determined proceed the verify to to PE has the be satisfactory, and solve procedures the that This etc. the to measurement the may Any TS an
GA and review engineer etc.. been
delegate problems. have specific
measurement PE will When and/or PE. solution the process
systems
determined results, audits,
EER OAO will systems by the GA 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 Qwlitv 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 indic'ate 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 as every as the any or with soon that
concentrations
represent found environmental either each of incident
generate
problem, quarterly
technologies. reported
The details
corrective
monitoring
Assurance
of
Qutside will order be obtained including to verify plans assurance assurance both of and data 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
utility
laboratories.
measurements/analysis. incorporated by those supplied
EER quality
laboratories.
_ 7-15
8.0 8.1
DATA MANAGEMENT AND REPORTING
The management any test program. data quality. storage enough and the which The will of depend data. the system user ensure information be flexible required, Finally. format
of They
data must They
which must for user the
have
been in of data
generated with a system to
is
an integral backups which and has The data functions the
part checks sufficient system as data
of to must be a
be recorded be stored a period to
faithfully months access of
capacity for must the of reauires.
or years. any
have capability
which
may well. in
capable
performing have
processing
reproducing
specific upon means: the
data
management in which data
procedures the data may
applied are
to
environmental and upon via the of any
data type the
manner
acquired
Environmental
acquisition
be accomplished
following
1.
2. 3. 4.
Direct in field Laboratory results
in-situ logbook).
acquisition analysis of
of discrete data
data
(e.g. samples chart on-line
pH meter with
reading
recorded of
manual
recording
on laboratory data data on disk. the will directly a hard will procedures logic to copy
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
behind the will
the
data
management for the above.
system. After of for
Once data entry the the to data data a
generated been
be recorded
either computer,
manually and
subsequent validity
as noted manual
be produced with
checked. data
be compared
documentation
validation
recording Once the
and hardware. is verified will is format. data in and also Some an corrected Any be of reports the stored as necessary, information data be relevant identification by the The may manner. require generated for can and the data which
data within to data produce
quality the the reporting the
will
be stored pertinent As in a to
computer testing
system. required,
additional
may be purposes. system processing
user-specified
information
applicable
8-l
a-2
computer test 8.2 The performed EER will with reports 1.
system
has
the
capability
for
any
data
processing
necessary
for
the
program. krmtina communication on submit will a regular quarterly on include: Summaries prior 2. Copies regulatory monthly measurements. 3. Identification present concern. tives 4. from at and concentrations EER and the of significant issued of and the as determined characterization of utilities. permit to the regulatory areas of actual, status, terms of including permits a description or notices of significant by an advisory of group unregulated environmental comprising substances and health representaof environmental monitoring data collected during the data Reauirements of basis process with and complete reports and potential measurement reporting of the problem information of all areas. relevant data to must be DOE.
data.
and annual summaries
environmental
emphasis
Ouarterly
quarter. of all compliance ~reports during reports previous and and analyses quarter. reports of submitted This excess includes opacity to
authorities NPDES monitoring
Description of any violations
plant's changes by the problem
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.
8-3
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
Data showing taken addition will project. Data Committee. that efforts. participants, providing review provided ongoing recommend 1) 21 3) is if
will required. of data
be
reviewed results This
by will
EER and
CWLP as
it to in
becomes monitoring monitoring of
available. frequency. location. the demonstration
Data action the EER
significant
be reviewed, modification or change all
verified,
and appropriate
may include parameter.
a monitoring
review
continuously
thorughout
phases
will from
be
reviewed meeting the will EER. for if monitoring the Committee
on will
an can
annual in of be
basis the
by early
a part into
Monitoring of future from and the among the Phase all
Review III. project utilities of the this data can so monitoring
The first The host to in review that: Certain Committee including sites determine the
be held
comments
incorporated participants,
be composed DOE. the demonstration there and are annual information, any
representatives The main findings Eased members of on the
funding
projects. significant reports.
purpose
quarterly of
Committee's
Committee
monitoring of the
tasks techniques quarterly
be discontinued. or instrumentation and annual
modified reports
or
added; or
New analytical The format
be substituted: be changed.
8-4
If
recommendations to the
are
made,
project
management changes
at
DOE and
EER will
consider
modification
EMP and authorize
as appropriate.
8-5
APPENDIX A
Illinois 217/782-2113
Environmental
I'roLecIion
Auc*ncy
2200 Churchill Hoad.SprlnnCield. IL 62706
OPERATING PERMIT PERMITTEE City Water Light 8 Power Louis Skibicki Attn: Seventh & Monroe Springfield. IL 62757
Application No.: 84030062 1.0. No.: 16712OAAO Date Received: June 2, 1988 Applicant's Designation: LAKESIDE11 Subject: Lakeside Plant II Units 7&E and ESP msued: August 30, 1988 Expiration Date: August 29, 1990 Location: 3100 Stevenson Drive
Permit is hereby granted to the above-designated Permittee to OPERATE emission source(s) and/or air pollution control equipment consisting of boilers 7 & 8 with associated electrostatic precipitator as described in the above-referenced application. This Permit is subject to standard conditions, attached hereto and the following special condition(s): 1. 2. 3. Particulate Operation startup, matter in excess malfunction emissions shall not exceed 0.10 lbs per million btu. during
of applicable emission and breakdown.
standards
is allowed
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 Permittee shall comply with 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 office 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. The permittee 'system on the each calendar for the last measurements shall maintain and operate a continuous opacity monitoring above-referenced equipment. On or before the 30th day of quarter. the permittee shall submit to the Agency a report preceding calendar quarter of any and all opacity which exceed 30 percent, averaged over a six minute period.
4.
,,.
. 63
Illinois
EnvironmcnLal
Proteclion
Al-~nc>
2200 Churchill
Road. Sprinpfirld.
IL 62706
Page 2 These "excess opacity" reports shall provide, for each such incident. the percent opacity measured as well as the date and span of such incident. These reports shall also specify for each incident whether it occurred If a malfunction is indicated during startup, shut-down, or malfunction. in the report, all corrective actions taken, if any, shall be reported. The reports shall also specify, for each calendar quarter, the date of those periods during which the continuous moni~toring system was not in operation and list the number of hours when at least one boiler was in operation.
Tifs&%!* Nanager, Division
Permit-Section of Air Pollution
Control
TAS:PDD:.imm/5057H/71-72 cc: Region 2
NPOES Permit Illinois Division Environmental
No. IL0024767 Protection Agency Control
of Water Pollution 2200 Churchill Road
Springfield.
Illinois
62706 SYSTEM
NATIONAL POLLUTANT DISCHARGE ELIMINATION Reissued Expiration Oate: August 1. 1991 (NPOESI Permit
Issue Date: September 30, 1986 October 30, 1986 Effective Date: Facility Name and Address:
Name and Address
of Permittee:
~City of Springfield Department of Public Property City Water, Light and Power Environmental Affairs 7th and Monroe Streets Springfield, Illinois 62757 Discharge Number and Name:
City Water, Light and Power 3100 Stevenson Drive Springfield. Illinois 62707 Sangamon County
Receiving
Waters
001 Lakeside 1 and 2 Condenser Cooling Water Outfall 001(a) Lakeside Turbine Room, Boiler Room and Equipment Drains, Lakeside 2 Boiler Blowdown 002 Dallman 1 and 2 Condenser Cooling Water Outfall 005 Industrial Wastewater Treatment Plant Outfall 006 Ash Pond Discharge to Lake Springfield 007 Dallman Coal Pile Runoff 008 Lakeside Coal Pile Runoff 009 Dallman 3 Condenser Cooling Water Outfall 010 Dallman Plant Intake Screen Backwash 011 Scrubber Surge Pond Overflow 003 Lakeside Storm Sewer 004 Ash Pond Discharge
Lake Springfield
Sugar Creek
In compliance with the provisions of the Illinois Environmental Protection Act, Subtitle C Rules and Regulations of the Illinois Pollution Control Board. and the FWPCA, the above-named permittee is hereby authorized to discharge at the above location to the above-named receiving stream in accordance with the standard conditions and attachments herein. Permittee is not authorired to discharge after the above expiration date. In order to receive authoriration to discharge beyond the expiration date, the permittee shall submit the proper application as required by the Illinois Environmental Protection Agency (IEPA) not later than 180 days prior to the expiration date.
Manager, Division TGM:GC:st/0298E .
Permit Section of Water Pollution
Control
ge.2
..'
NPDES Penit Effluent Limitations
No. IL0024767 and Monitoring CONCENTRATION LIMITS mg/l DAY DAILY AVG. MAX.
RAMETER
LOAD LIMITS lbslday DAILY3 DAY MAX. AVG.
SAMPLE SAMPLE FREQUENCY TYPE of the following
From the effective date of this permit until August 1, 1991, the effluent scharge(s) shall be monitored and limited at all times as follows: Outfall(s): is discharge Lakeside Lakeside Lakeside Lakeside Lakeside Lakeside Lakeside
OW
ODl Lakeside
1 and 2 Condenser
Cooling
Water Outfall Approximate 21.3 Flow
consists 1 2 2 2 2 1 2
of:
and 2 Condenser Cooling Water Turbine Rooms 4. 5 and 6 Floor Drains: Turbine Rooms 4; 5. 6. and 7 Roof Drains, Boiler Rooms 5. 6 and 7 Floor Drains Boiler Rooms 5 and 6 Roof Drains and 2 Equipment Drains L Boilers 5. 6, 7 and 8 Boiler Blowdown,
Intermittent Intermittent
Intermittent Intermittent Intermittent Intermittent Daily Continual Continual Grab** Drains, Flow
MGD
nperature ta1 Residual Chlorine
See Special
Condition
No. 3 0.2
Daily Z/Month* Room and Equipment Approximate
Outfall(s): consist of:
001(a)
Lakeside Lakeside
Turbine 2 Boiler
Room. Boiler Blowdown
,is
discharge Lakeside 2 Lakeside 2 Lakeside 2 Lakeside 2 Lakeside 1 Lakeside 2 Yard Drains Miscellaneous
Turbine Rooms 4, 5 and 6 Floor Drains Turbine Rooms 4. 5, 6. and 7 proof Drains Boiler Rooms 5, 6 and 7 Floor Drains Boiler Rooms 5 and 6 Roof Drains and 2 Equipment Drains Boilers 5, 6, 7 and 8 Boiler Blowdown Equipment Drains
Intermittent
Intermittent
Intermittent Intermittent Intermittent
Intermittent Intermittent Intermittent l/Week Single Reading Estimate Grab 24 Hour Composit Grab
OW
I
See Special
Condition
No. 5 15.0 15.0 30.0 20.0
Z/Month Z/Month Z/Month
Ital Suspended Solids '1 and Grease See Special Conditions r See Special Condition No. 4 and No. 9 No. 4 *
:
9
3
NPDES Permit Effluent Limitations
No. IL0024767 and Monitoring CONCENTRATION LIMITS mg/l 30 DAY DAILY AVG. MAX.
.RAPiETER
LOAD LIMITS lbs/day 3 DAY OAILf AVG. MAX.
SAMPLE SAMPLE FREQUENCY TYPE of the following Equipment Approximate 118.3 MGD Flow Continual Continual Grab*
From the effective date of this permit until August 1. 1991, the effluent scharge(s) shall be monitored and limited at all times as follows: Outfall(s): 002 Dallman 1 and 2 Condenser~~and Miscellaneous Cooling Water Outfall
06
Daily See Special Condition No. 3 0.2 No. 4 and 9 No. 4 Daily 2/Month*
imcerature ital Residual Chlorine
See Special Condition : See Special Condition
ige 4 NPDES Permit Effluent Limitations No. IL0024767 and Monitoring CONCENTRATION LIMITS mg/l v AVG. MAX. SAMPLE SAMPLE FREQUENCY TYPE of the following
ARAMETER
LOAD LIMITS lbs/day DAILY 3D DAY MAX. AVG.
. From the effective date of this permit until August 1, 1991, the effluent ischarge shall be monitored and limited at all times as follows: Outfall(s): his 1 discharge Lakeside consists of: 003 Lakeside Storm Sewer
Approximate Intermittent Intermittent Intermittent Intermittent Intermittent Intermittent Intermittent 0.3 MGD 0.1 MGD Intermittent Intemiittent Intermittent l/Week
Flow
1 Turbine Rooms 1. 2 and 3 Floor Drains k Equipment Drains Turbine Rooms 1, 2 and 3 Roof Drains 2, 3 and 4 Boiler Blowdown . Lakeside 1 Boilers . Lakeside 1 Boiler Rooms 2, 3 and 4 Floor Drains A Equipment Drains . Lakeside 1 Boiler Rooms 2, 3 and 4 Roof Drains 2 Turbine Rooms 6 and 7 Roof Drains . lakeside . Lakeside 2 Boiler Rooms 7 and 8 Roof Drains ;. Lakeside 1 and 2. Intake Screen Backwash ** Screen Washings from Public Water Supply Intake b. Spillway Gate Hydraulic Water *** i. Miscellaneous Equipment Drains 2. Public Water Supply Drain** '1 ow
Single Reading Estimat Grab 24 Hour ComposiGrab 003.
IH 'otal Suspended Solids Ml and Grease
See Special
Condition
No. 5 15.0 15.0 30.0 20.0 wastestream
l/Week 1/Week 2iMont.h input to Outfall
c** Compliance
Monitoring
samples
are collected
ahead of this
9e 5
NPDES Permit Effluent Limitations
No. IL0024767 and Monitoring CONCENTRATION LIMITS mg/l DAY DAILY AVG. MAX. effluent
,RAMETER
LOAD LIMITS lbs/day 30 DAY DAILY MAX. AK.
SAMPLE SAMPLE FREQUENCY TYPE of the following
From the effective date of this permit until August 1, 1991, the scharge(s) shall be monitored and limited at all times as follows: Outfall(s): lis discharge consists of: 004 Ash Pond Discharge
Approximate 2.66 MGD 4.32 MGD Intermittent 0.33 MGD Intermittent 0.19 MGD Intermittent l/Week
Flow
Lakeside Plant Fly Ash and Bottom Ash Oallnan Plant Fly Ash and Bottom Ash Non-Chemical Metal Cleaning Wastes *** Lime Sludge From the City Water Purification Flue Gas Desulfurization System Wastes*** Industrial Wastewater Treatment Plant Sludge Water Treatment Plant Yard Drains ow
Plant
Single Reading Estimate Grab 24 Hour Cpmposit Grab
i Ital Suspended Solids il * and Grease This
See Special
Condition
No. 1 15.0 15.0 30.0 20.0 Wastewater Treatment
2/Week 2/Week 2/Month System
wastestream
may be directed
to the
Industrial
.
'age 6 NPDES Permit Effluent Limitations No. IL0024767 and Monitoring CONCENTRATION LIMITS mg/l DAY DAILY AVG. MAX.
'ARAMETER
LOAD LIMITS lbs/day 'Jg DAY DAILY AVG. MAX.
SAMPLE SAMPLE FREQUENCY TYPE of the following
I. From the effective date of this permit until August 1. 1991, the effluent lischargefs) shall be monitored and limited at all times as follows: Outfall(s): This discharge I. ?. 3. 1. :: 7. zlb. Il. 12. 13. 1:: 16. 17. 18. Flow PH Total Suspended Solids Oil Iron and Grease (total) See Special Condition No. 1 15.0 15.0 2.0 0.5 30.0 20.0 4.0 1.0 consists of: 005 Industrial Wastewater Treatment Plant
Outfall Approximate 0.6 MGD 1.0 MGD Intermittent Intermittent 0.001 MGD 0.44 MGD Intermittent Intermittent 1.8 MGD 0.3 MGD 0.85 MGD Intermittent Intermittent Intermittent Intermittent Inteni ttent Intermittent Intermittent Daily Daily l/Week Z/Month l/Week l/Week Contint Contint 24 Hour Composi Grab 24 Hout Composi 24 HOUI Composi Flow
Oemineralizer Regenerant Wastes Lakeside 2 Boilers 7 and 8 Slag Tank Overflow Lakeside 2 Boiler Rooms 7 and 8 Floor Drains Lakeside 2 Turbine Rooms 6 and 7 Floor Drains Lakeside 2 Boilers 5 and 6 Slag Tank Overflow Dallman 1, 2 and 3 Boiler Blowdown, Evaporator and Deaerator Dallman 1, 2 and 3 Roof and Floor Drains Dallmanl, 2 and 3 Condensate Storage Tank Wastes Dallman 1. 2 and 3 Slag Tank Overflow Dallman 1, 2 and 3 Sump Pumps Dallman Plant Pyrite Romoval Wastes Crusher House and Control House Floor Drains Flue Gas Desulfurization System Wastes*Dallman Coal Pile Runoff (See Outfall No. 007) **** Dallman 1 and 2 Precipitator Area Drain Non-chemical Metal Cleaning Wastes Dallman 1, 2 and 3 Equipment Drains Lakeside Coal Pile Runoff (see Outfall No. 0081*-
Blowdown
Copper (total)
**** Discharge to the alternate routing.
Industrial
Wastewater
Treatment
Plant
is an
J"'7 NPDES Permit Effluent Limitations No. IL0024767 and Monitoring CONCENTRATION LIMITS mg/l -30 DAY DAILY AVG. MAX.
RAMETER
LOAD LIMITS lbs/day DAILY 30 DAY AVG. MAX.
SAMPLE SAMPLE FREQUENCY TYPE of the following
From the effective date of this permit until August 1, 1991, the effluent s:harge(s) shall be monitored and limited at all times as follows: Outfall(s): 006 Ash Pond Discharge to Lake Springfield
Approximate Intermittent
OW
Flow 24 Hour Total Grab 24 Hour Composi Grab
l/Week 2/Week*** 15.0 15.0 Outfall(s) 007 Dallman Coal Pile Runoff Approximate 30.0 20.0 2/Week l t*2/Month*****
See Special ta1 Suspended Solids 1 and Grease
Condition
No. 1
iis
discharge Dallman Dallman
consists
of: Area Drain
Flow
Coal Pile Runoff 1 and 2 Precipitator
Intermittent
Intermittent l/Week Single Reading Estimate Grab 8 Hour Composit Grab 8 Hour Composil pump.
low
i Ital Suspended Solids il and Grease
See Special
Condition
No. 1 15.0 15.0 2.0 30.0 20.0 4.0 exercising
l/Week l/Week l/Week l/Week diversion
ron (Total) **Monitor if Discharge Occurs During
the Month excluding
I
,
w 8
NPDES Permit Effluent Limitations
No. IL0024767 and Monitoring CONCENTRATION LIMITS mg/l 3D DAY DAILY AVG. MAX.
RAMETER
LOAD LIMITS lbsfday 30 DAY DAILY AVG. MAX.
SAMPLE SAMPLE FREQUENCY TYPE of the following
From the effective date of this permit until August 1, 1991. the effluent scnarge(s) shall be monitored and limited at all times as follows: Outfall(s): is discharge consists of: Area Runoff 008 Lakeside Coal Pile Runoff
Approximate Intermittent Intermittent Intermittent l/Week
Flow
Coal Pile Runoff Lakeside Plant Precipitator Parking Lot Runoff
Single Reading Estimate Grab 8 Hour Cornposit Grab 8 Hour Cornposit! Cooling
1 )tal Suspended Solids il and Grease
See Special
Condition
1 15.0 15.0 2.0 30.0 20.0 4.0 and Miscellaneous
l/Week l/Week l/Week l/Week Equipment
?on (Total1 Outfall(s):
009 Dallman 3 Condenser Water Outfall
Approximate 151.4 MGD low emperature otal Residual Chlorine See Special Conditions * See Special Condition No. 4 and 9 No. 4 See Special Condition No. 3 0.2 Daily Daily 2/Month*
Flow Continuo Continuo Grab**
.
‘age 9 NPDES Permit Effluent Limitations No. IL0024767 and Monitoring CONCENTRATION LIMITS mg/l 30 DAY DAILY AVG. MAX.
'ARAMETER
LOAD LIMITS lbs/day 30 DAY DA AVG. MAX.
SAMPLE SAMPLE FREQUENCY TYPE of the following
I. From the effective date of this permit until August 1, 1991. the effluent discharge(s) shall be monitored and limited at all times as follows: Outfall(s): 010 Dallman Plant Intake Screen Backwash
Approximate 0.15 MGD -1ow Outfall(s): 011 Scrubber Surge Pond Overflow Approximate Intermittent Intetmittent Intermittent Daily 1 /Week
Flow Estimate
This discharge consist of: pad runoff 1. Scrubber sludge storage Groundwater pumpage from the oil spill Flue gas desulfurization wastes :: Vow
Flow
recovery
well
Single Reading Estimat Grab Grab
>H rota1 Suspended Solids
See Special
Condition
No. 1 15.0 30.0
Daily Daily
.
Page 10 NPDES Permit Special The pH shall No. IL0024767 Conditions
1.
be in the range 6.0 to 9.0. monitorin discharge, requirements % prior to ut
2. Samples taken in compliance with the effluent shall be taken at a point representative of the entry into the receiving stream. 3. The thermal discharge to shall not exceed 99' F more period ending with any month shall not exceed 99' F more period ending with any month 109' F.
Lake Springfield from the Lakeside plant than 5 percent of the hours in the ltmonth and the discharge fram the Dallman plant than 8 percent of the hours in the 12-month and at no time shall any discharge exceed
may not be discharged from each units main cooling 4. Chlorine condensers for more than two hours in any one day. The reported mean concentration and maximum concentration of Total Residual Chlorine shall be based on a chlorine concentration curve. The concentration curve shall be generated using grab samples with an analytical frequency of 5 minutes or less during the respective chlorination period of each unit allowing for lag time between the initiation of chlorination and the point of sampling before the first sample is taken. Concentration curves shall be submitted with monthly Discharge Monitoring Reports. The frequency and duration of the chlorine dosing period plus the amount of chlorine applied shall be reported on the Discharge Monitoring Reports. 5. The pH limitation 003 if the the public be pH 10.0. 6. There associated 7. There shall be in the range 6.0 to 9.0. The pH 9.0 maximum may be exceeded in the following dischar es No. 001(a) and No. elevated pH level is caused by greater t 8 an 9.0 pH levels in water supply to the system in which case the upper limit shall of chemical metal cleaning bfphenyl wastes or
shall be no discharge rinses. shall be no discharge
of polychlorinated
compounds.
8. To calculate the average daily flow for outfalls 001, 002 and 009 during the reporting period, the total number of pump hours observed is divided by the number of days in the month and then multiplied by the pump rate (gallons/hour). The minimum dail flow rate is determined by multiplying the lowest daily pump hour tota i by the pump rate. The maximum daily pump rate is calculated by multiplying the highest daily pump hour total by the pump rate. During maintenance outages calcium hypochlorite may be used to 9. During discharge of chlorinated wastewater passivate the condensers. from passivation of the main-cooling condensers a minimum of three grab samples shall be taken at five minute intervals or less at the
.
'Page 11 NPDES Permit Special No. IL0024767 Conditions
condenser cooling water outfall for each batch discharge allowing for lag time between chlorine discharge and the point of sampling before the The individual values and average value for first grab sample is taken. each set of samples shall be reported with monthly DMR forms including the time samples were collected, the time and duration of chlorine release plus the amount of chlorine applied. 10. The permittee Monitoring Report shall record monitoring results on Discharge Forms using one such form for each discharge each month.
The completed Discharge Monitoring Report forms IEPA no later than the 15th day of the following specified by the permitting authority. Discharge address: Monitoring Reports shall be mailed
shall be submitted to month, unless otherwise IEPA at the following
to the
Illinois Environmental Protection Agency Division of Water Pollution Control 2200 Churchill Road 62706 Springfield, Illinois Attention: Compliance Assurance Section
Additionally, Discharge Monitoring Report forms shall be mailed to United basis. States Environmental Protection Agency in Chicago on a quarterly unless otherwise The permittee shall submit the reports as follows, specified by the permitting authority. Period Jan, Feb. Mar April. May, June July, Aug. Sept Oct. Nov, Dee Reports shall be addressed Agency as follows: Report Due At U.S. Environmental April 28th July 28th October 28th January 28th to United States Environmental Protection Protection Agency
NPDES Compliance Unit United States Environmental Region V 230 South Dearborn Street Chicago, Illinois 60604
Protection
Agency
. -.-