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

992
PLANNING FOR NEW PROCESSES: ENVIRONMENTAL ASPECTS
INTRODUCTION
Planning for a major new facility must address the envi-
ronmental impact of both the construction and operational
phases of the project. It is essential to optimize alternatives,
while evaluating performance relative to regulated emis-
sions and ambient standards and to develop a cost effective
permitting strategy.
For large scale projects, Quig (1980) recommends a
highly integrated project approach for environmental com-
pliance early in the planning stage based upon historical
siting, licensing, engineering and construction experience
with similar sized plants.
Strong emphasis on early process work is necessary to
understand environmental impacts. This and other front-end
engineering and planning should be executed in very close
coordination with the staff charged with documenting the
licensing effort. Extensive use of specialists is generally
required.
The major federal acts to be addressed are:
1) National Environmental Policy Act, (NEPA), 1969.
2) Clear Air Act Amendments, revised 1990.
3) Federal Water Pollution Control Act Amendments,
1972 (FWPCA).
4) Resources Conservation and Recovery Act (RCRA),
1976.
5) National Historic Preservation Act of 1966.
6) Historical and Archaeological Preservation Act of
1974.
7) Endangered Species Act, 1973.

These federal and selected state environmental acts
essentially address the following: Land Use Aspects (fuel
storage, exclusion or buffer zones, waste disposal, zoning,
and demography); Water Resources (availability and com-
petitive uses, wastewater complexities and water quality,
hazardous wastes, and waste heat); Air Quality/Meteorology
(attainment/nonattainment areas, in terms of offset policy
and lowest achievable emission rate; newsource perfor-
mance standard for particulates; NO


x


and SO
2
; prevention
of significant deterioration in Class I, II, III; stack height
credit; hazardous wastes; minor meteorologic changes);
and Regulatory (multiple lead agency involvement, licens-
ing strategy, feasibility of concept, permit requirements, and
federal/state implementation).
The environmental, health safety, and socio-economic
impacts discussed above highlight the areas of concern
which must be considered in the site characterization studies
and subsequent reporting of the project compatibility with
the proposed location. Baseline conditions must be identi-
fied in the areas of potential impact. The characterization of
the environment, the definition of the process operations and
the identification of the potential impacts are the elements

required for input to a comprehensive program of facility
design for impact mitigation. As such, the development of
an environmental statement of the project serves as feedback
to the design effort with the result being a facility licensable
from the environmental viewpoint.
To illustrate the procedure we shall present a typical
example, namely planning a new coal gasification plant.
Technical details of gasification are discussed elsewhere in
this Encyclopedia under Coal Gasification Processes. The
example will focus on regulatory requirements and siting
considerations.
REGULATORY REQUIREMENTS
The first step in any program of this nature is to define the
regulatory requirements associated with the construction and
operation of the proposed facility. This will define specific
limitations and establish generally the study requirements
for the program as they relate to the environmental, safety,
health, and socioeconomic aspects of the development.
AIR QUALITY RELATED REGULATORY
REQUIREMENTS
Federal Requirements
At the Federal level, this project will be required to comply
with the following air quality regulations and requirements.
Primary and Secondary National Ambient Air Quality
Standards (NAAQS) A demonstration showing compliance
with NAAQS must be made to EPA for approval to com-
mence construction. This would involve modeling the
anticipated plant emissions and imposing the resultant con-
centration increases on representative ambient air quality
conditions and comparing these with NAAQS. Information

necessary for this demonstration would include the facility
emissions as discussed earlier and the ambient air quality
C016_007_r03.indd 992C016_007_r03.indd 992 11/18/2005 11:01:29 AM11/18/2005 11:01:29 AM
© 2006 by Taylor & Francis Group, LLC
PLANNING FOR NEW PROCESSES: ENVIRONMENTAL ASPECTS 993
developed from a monitoring program or from representative
data as available.
New Source Performance Standards (NSPS) The proposed
air quality control system (AQCS) for the facility must be
designed to comply with existing NSPS for the coal prepara-
tion facilities (e.g., particulates), the gas turbine component
(e.g., NO


x


) and the auxiliary boiler (e.g., SO
2
) of the plant.
Since NSPS do not exist for the coal gasification compo-
nent, appropriate AQCS Best Available Control Technology
(BACT) evaluations will be performed to select the con-
trol system. In addition the AQCS design will have to be
reviewed with the EPA for approval to construct.
Prevention of Significant Deterioration (PSD) No con-
struction can commence until the PSD permit has been
obtained. The report and application for the permit would have
to consider the following: the emissions from the total facility;
a BACT review for any regulated pollutant (NAAQS, allow-

able increments, NESHAP), which the plant emties above
“de minimis” values, an air quality review for all pollutants
emitted, after controls are applied, over the “de minimis” emis-
sion rates unless it were demonstrated that the air impacts of
those emissions would not exceed the air quality impact “de
minimis” values. As part of these demonstrations ambient air
quality monitoring would have to be conducted for the same
pollutants for which BACT demonstrations would be required
unless representative monitoring data are available.
National Emission Standards for Hazardous Air Pollutants
(NESHAP) The discharge to the atmosphere of pollutants
regulated under NESHAP is not anticipated for this type of
facility. However, tracking of EPA’s continued development of
NESHAP should be carried out to ensure compliance with the
regulations as they develop.
New stationary sources and modifications to major sta-
tionary sources are required by the Clean Air Act to obtain
permits prior to construction of a new process facility. The
stringency of permit requirements depends on the regional
status of its compliance with ambient standards for particu-
lar pollutants. For example, in zones having acceptable air
quality referred to as “attainment areas” for a specific pollut-
ant, the permits are of the prevention of significant deterio-
ration (PFD) type. The code of federal regulations, US EPA
Title 40 CFR, 51.166, specifies the set of minimum PSD air
quality permit requirements to warrant approval by the US
EPA. The primary objective of PSD is to insure new major
sources and modifications of existing sources comply with
NAAQS. Specific public notice requirements and subse-
quent hearings allow for public comment to be part of the

PSD review process. On the other hand, in a non-attainment
area, NAA permits are required. NAA permits address area
improvement of pollutant levels and falls under the state’s
supervision, through a State Implementation Plan (SIP)
enforced by the US EPA and DOJ. Either type of permit is
subject to New Source Review (NSR). The physical change
triggering regulation of pollutants is usually 100 or 250 tons
per year, depending on the industrial source category. As of
early 2005 the definition of major modification for coal fired
power plants has come under dispute in the courts (see the
discussion at the end of this article for further information).
State Requirements
The state may have air quality related requirements which
will affect the proposed project.
State requirements may include a permit to construct a
facility if the construction of operation of the facility will
release air contaminants into the atmosphere. The appli-
cant must submit a completed application for Approval of
Emissions and an Emission Inventory Questionnaire (along
with a copy of the PSD Application) which show compli-
ance with state air quality standards, toxic substance limita-
tions and emission control requirements.
WATER QUALITY RELATED REGULATORY
REQUIREMENTS
Federal Requirements
At the Federal level, the major laws affecting the discharge
of liquid effluents from the proposed facility are as follows:
Clean Water Act (CWA) Under the CWA, the proposed
project will require a National Pollutant Discharge Elimination
System (NPDES) permit before commencing construction and

operation. The application to the EPA for these permits would
be based on the conceptual design of the wastewater control
systems which could ensure compliance with effluent limita-
tions and water quality standards. Where effluent limitations
are not specified for discharges from certain facilities, limi-
tations on discharges from similar operations would be used
as a guideline for design of the wastewater control systems.
These designs would be used to support the application for an
NPDES permit. The NPDES permit and the work effort neces-
sary for its preparation will also address the discharge of toxic
pollutants listed on the Section 307(a) toxic pollutants list and
any other toxics discharged from the plant.
A section 404 permit is required by the Corps of
Engineers for the discharge of dredge or fill material in the
navigable waters of the United States. This permit is required
for the river structures associated with the facility and would
be prepared and obtained concurrently with the Section 10
permit required under Rivers and Harbors Act (see discus-
sion below) and the NPDES permit.
Application for either an NPDES permit from the EPA or
a Section 404 permit from the Corps will trigger the NEPA
review process and is the basis upon which the preparation
of an environmental report (ER), in support of a Federal EIS,
is considered necessary.
Rivers and Harbors Act of 1899 (RHA) Under Section 10
of the RHA, any construction activity in a navigable waterway
requires a permit from the Corps of Engineers. This permit
will be required for the construction of the intact and discharge
structures and the barge loading/unloading facilities. It would
be submitted jointly as a common permit application with the

Section 404 Dredge and Fill Permit application.
State Requirements
The state often has water quality related regulations and
requirements which must be complied with before approval
C016_007_r03.indd 993C016_007_r03.indd 993 11/18/2005 11:01:29 AM11/18/2005 11:01:29 AM
© 2006 by Taylor & Francis Group, LLC
994 PLANNING FOR NEW PROCESSES: ENVIRONMENTAL ASPECTS
to commence construction and/or operation of the proposed
project can be obtained. They are typically as follows:
A state regulatory agency may require that a certificate of
approval be obtained prior to construction of a treatment facil-
ity for handling industrial wastes. A report containing detailed
information about the operation of the treatment facility must
be developed and submitted prior to construction.
Regulations may also require the submission of a permit
application prior to discharge from an industrial source. The
State may also issue a certification in accordance with the Clean
Water Act which confirms that discharges from the facility will
comply with effluent limitations and water quality standards.
SOLID WASTE RELATED REGULATORY ACTIVITIES
Federal Requirements
The major Federal law governing the handling and disposal of
solid waste is the Resource Conservation and Recovery Act
of 1976 (RCRA). The most significant sections of RCRA are
Subtitle C, which deals with Hazardous Waste Management
and Subtitle D, which deals with Non-hazardous Waste
Management. Regulations pursuant to Subtitle C of RCRA
address identification and listing of hazardous waste, stan-
dards applicable to generators, transporters, and owners and
operators of hazardous waste treatment, storage and disposal

facilities and permit requirements for treatment, storage or dis-
posal of hazardous waste. The project will require a permit for
disposal of any solid wastes determined to be hazardous by
the criteria in Section 3001 regulations. Operation practices
of the solid waste management facility are also regulated. In
this regard the work necessary to determine the nature of the
solid waste generated by this facility must be carried out. If the
wastes are determined to be hazardous (Section 3001 Criteria)
the applicable requirements of Subtitle C or RCRA must be
incorporated into the facility design.
Regulations promulgated under Subtitle D or RCRA
establish criteria for the development of State plans for
management of solid waste. No requirements are directly
imposed at the Federal level.
State Requirements
State plans for the management of solid waste (Hazardous
and Non-hazardous) may be at varying stages of develop-
ment. An application for a permit to operate a hazardous
waste management facility may be filed with the state’s DNR
if any solid wastes to be generated at the proposed facility
can be classified as hazardous.
NATIONAL ENVIRONMENTAL POLICY ACT (NEPA)
The major provision of NEPA which significantly impacts
the planning and scheduling for major industrial facilities
is the need for Federal agencies contemplating major actions,
such as issuing permits, to prepare an environmental impact
statement (EIS).
In the case of this coal gasification facility, the requirement
for a Federal EIS would be triggered by the application for
an NPDES permit from EPA and/or a Section 404 or Section

10 permit from the Corps of Engineers for anticipated river
structures. Upon designation of the lead agency based on
discussions with the various Federal agencies and submit-
tal of applications for permits, the EIS would be prepared
according to CEQ final regulations.
SITING THE PROJECT
Geology, Topography, and Soils
Geology studies should be performed to describe the soils,
geologic and topographic setting of the site, particularly with
respect to structural and topographic control of the local and
regional groundwater flow systems. A secondary, albeit very
important, purpose is the identification of potential geologi-
cal hazards within the site area.
Information sought includes physical and chemical
soil characteristics, general topography, paleontology, and
geological framework. Descriptions are sought for aquifer
systems and characteristics including their name, thickness,
depth, stratigraphy, and areal extent. Mineral production and
unique geologic/geomorphic features will be documented.
Pertinent data is summarized in tabular and/or graphic
format.
The results of the geology studies primarily define the
soils, topographic, and geologic setting of the site. Potential
impacts references these descriptive settings to evaluate
impact magnitudes. The impact of plant site preparations
and construction or localized site topography, soils and ero-
sion characteristics, and site physical and economic geology
are assessed. Geological hazards discussed include exces-
sive slopes, unstable soils and fault zones.
Groundwater Hydrology and Water Use

The purpose of the groundwater studies is to understand the
physical and chemical characteristics of the groundwater
regime. This allows for an accurate assessment of groundwater
impacts resulting from the proposed action in addition to for-
mulation of mitigative measures to help alleviate these impacts.
In addition, information necessary for the design of solid waste
handling facilities as prescribed under RCRA is developed.
Information sought includes general topography and
geological framework, description of aquifer systems and
characteristics including their name, thickness, depth, stra-
tigraphy, and areal extent; seasonal groundwater levels, rate,
and direction of flow; aquifer hydraulic properties including
permeability, transmissivity, and storativity; surface water/
groundwater inter-relationships; location of aquifer recharge
and discharge areas; ground water quality; and domestic,
industrial, and municipal groundwater well distribution and
characteristics. Long and short term regional and site specific
(within 5 miles of the site) data is sought. Special efforts are
made to document the location of contaminated areas.
C016_007_r03.indd 994C016_007_r03.indd 994 11/18/2005 11:01:29 AM11/18/2005 11:01:29 AM
© 2006 by Taylor & Francis Group, LLC
PLANNING FOR NEW PROCESSES: ENVIRONMENTAL ASPECTS 995
Groundwater sampling can be conducted in conjunction
with surface water sampling. Samples are taken quarterly
from monitoring wells.
This information can then be evaluated in light of the
projected facility emissions and demands on the area’s
resources. The issues and concerns to be addressed include:
1) Use of groundwater by the plant, and the effects of
lowering water levels or pressures for this reason

or for construction purposes.
2) Changes in water quality, or effects on rocks/
deposits, caused by accidental leaks or spills, efflu-
ent discharge, slag or scrubber sludge pits, surface
water and the like. The potential impacts identi-
fied are evaluated in light of their magnitude and
importance. Extra attention is paid to those judged
significantly high in either value.
By early identification of stresses that might affect the natu-
ral systems, steps can be taken to minimize the impacts or
alleviate them to an acceptable degree. Mitigative measures
that can be taken during plant design, construction or opera-
tion, such as adding clay liners, for example, can be evaluated
and described.
Using the results of plant design, the initial impact eval-
uation and the adopted mitigative measures, a final evalua-
tion is made of the effects of the construction and operation
of the proposed plant and ancillary facilities on the natural
environmental systems.
This activity evaluates expected effects of the proposed
plant both during and after construction of the groundwater
hydrologic environment. Each effect is evaluated as to its
unavoidable adverse effects and favorable effects.
Surface Water Hydrology and Water Use
The purpose of the surface water studies is to determine,
develop and present the surface water quantity and quality
characteristics of the site and its surrounding environs. These
data and information are analyzed and evaluated in recognition
of the proposed facility’s operation and construction related
characteristics to determine and project potential effects and

impacts on the surrounding surface water. Specifically, the
objectives are:
1) To provide a quantitative description of the hydro-
logic setting of the site and its vicinity including
any stream flow characteristics (i.e., flood and low
flow frequencies, seasonal ranges, averages, and
historical extremes), and the physical and chemical
water quality characteristics of source and receiving
waters. Annual and seasonal ranges and averages
are developed.
2) To identify the other water uses (withdrawals as
well as discharges) and users including the loca-
tion and quantities involved;
3) To identify the existing water quality criteria and
regulations affecting plant discharges, and
4) To evaluate the impact of construction and opera-
tion of the proposed plant on adjacent surface
waters, with regard to the applicable water quality
criteria, and related permit requirements.
The data and information needed for the description of the
hydrologic setting of the surface waters of the site and evalu-
ation of the plant’s impact include the following:
1) Geographic and topographic maps of the site area
containing varying degrees of local and regional
details to delineate the drainage basin and its
drainage patterns.
2) Watershed characteristics such as geometry,
slope, vegetation types and density, and soil types
to derive rainfall-runoff relationships (empirical
runoff coefficient).

3) Records of rainfall events to estimate overland
flow.
4) Records of stream flows from gaging stations on
local water courses. These data are used in defin-
ing statistical stream flow characteristics.
5) Meteorological data including air temperature,
relative humidity, solar radiation, wind speed and
evaporation data, and thermal plume calculations
(as needed).
6) Records of various water users, locations of with-
drawal, quality, and quantities involved.
7) Proposed plant site location map, grade elevation,
drainage pattern, character of soil types, and cover.
8) The physical and chemical water quality charac-
teristics of the surrounding surface waters.
9) The facility description and operational characteris-
tics relating to the discharge quantity and quality. In
addition, construction procedures, methods, sched-
ules, and erosion control features are needed.
In addition to a water quality characterization program, the
required data is collected through existing sources. This
would involve a thorough search, review, and compilation
of the existing hydrological data base. Appropriate Federal,
State, and local agencies are contacted and interviewed and
published regulatory materials is reviewed to gain informa-
tion regarding other water users and water laws affecting the
plant construction and operation.
A field monitoring program is carried out to obtain water
quality characteristics of intake and discharge waters. Water
quality samples are taken quarterly from selected stations.

A hydrological assessment of the construction phase is
undertaken to:
1) identify changes in drainage patterns and possible
effects on flooding potential,
2) identify changes in riparian terrestrial habitat areas,
3) identify the potential for erosion and local soil
losses.
These impact areas are addressed, and mitigating measures
are specified for their control.
C016_007_r03.indd 995C016_007_r03.indd 995 11/18/2005 11:01:29 AM11/18/2005 11:01:29 AM
© 2006 by Taylor & Francis Group, LLC
996 PLANNING FOR NEW PROCESSES: ENVIRONMENTAL ASPECTS
For the operational phase, the various aqueous discharges
from the plant are inventoried and evaluated. Results of
plume analyses, if appropriate, are critiqued with respect
to compliance with applicable water quality criteria and
standards. Recommendations concerning the potential opti-
mization of the plant water management plan are made to
reduce or eliminate environmentally objectionable dis-
charges. Consumptive water use for the plant is identified
to determine the effects of plant operation on intake waters
and downstream users. Recommendations concerning opti-
mization of the plant water management plan and the use
of alternate or supplemental sources of water are made, if
warranted.
Ecology
The ecological studies are designed to generate and assemble
pertinent data to determine the status of threatened and
endangered species, and commercially or recreationally
important wildlife species, and to identify and locate sen-

sitive, unique, and critical aquatic, riparian, and terrestrial
habitat areas in the site area. Additionally, the status of com-
mercially or recreationally important fish in any site intake
and discharge waters is determined. The biological setting is
then analyzed in light of the proposed plant construction and
operational characteristics to arrive at assessments of impact
potential.
Terrestrial Ecology
In evaluating the impact of the project on the terrestrial
environment, the work objective is to assess both construc-
tion and operation of the facility utilizing “baseline” data
developed and secured from field programs, literature, and
agency contacts. Animal species, occurrence, abundance,
distribution, and preferred habitat associations and principal
ecological interactions are determined. Habitats are identi-
fied and described as natural plant communities within the
site. Additionally, discussions and data gathering activities
focus on vertebrates and prominent otherwise important
plant community components.
Construction-related effects largely result from veg-
etation and habitat removal, which often constitutes the
major impact of a major industrial facility on terrestrial
communities.
Assessment of vegetation loss due to land clearing is
based on previous identification and mapping of regionally
productive rare, or otherwise important vegetation types.
In this regard, the role of plants in soil stability warrants
detailed consideration. Effects of facility construction on
wildlife is also evaluated in terms of important habitat areas.
Attention is focused on those species which appear sensitive

to habitat loss (e.g., species already limited by factors relat-
ing to habitat availability), which function as critical compo-
nents of a community, or which are considered “important.”
The latter category refers to wildlife designated uncommon,
threatened or endangered, or wildlife of recreational or eco-
nomic value.
An assessment of project operation including existing
and proposed effects on vegetation must consider stack and
cooling tower emissions. Predicted ground-level concentra-
tions of stack emissions and cooling tower salt are compared
to exposure levels considered thresholds for possible injury
or damage, and to exposure levels documented as injurious
under filed conditions.
Potential effects of facility operation (existing and pro-
posed units) on wildlife from stack emissions, dust, increased
human activities, and noise are evaluated. Additionally, the
potential for bird collisions with plant components is evalu-
ated. The magnitude of a potential bird-collision problem is
evaluated from data compiled during field studies. Included
in the impact assessment analysis is the use of the plant
site by wildlife during station operation. Collecting ponds
and other waste bodies provide habitat for waterfowl and
amphibians, while areas cleared during construction and
allowed to revegetate (or which are replanted) potentially
provide habitat for a variety of species.
Aquatic Ecology
The aquatic ecology of the site intake and discharge waters
as well as habitat removal associated with barge facilities is
addressed, habitat and food web relationships of the system
characterized and potential impacts to the system estimated.

Data requirements are met by literature review, interviews,
and discussions with local fishermen and scientists and field
collections. While data gathering focuses on fish species,
particularly the commercially or recreationally important
species, other biotic elements of the lotic and lentic environ-
ments are identified.
Evaluation of potential impacts of the construction and
operation of the proposed facility consist of projecting the
effects of the various activities on the description of existing
environmental conditions developed as a result of the field
program, literature review and agency contacts described
above.
The primary construction impacts likely to affect the
aquatic habitat are those associated with the construction
of the intake facility and secondarily increased erosion due
to construction. Impact assessment of construction activi-
ties centers primarily on habitat lost or denied due to actual
physical placement of structures and habitat degradation.
Attention is focused on those species which appear sensi-
tive to habitat loss; which function as critical components of
the aquatic community; or are considered “important” (rate,
threatened or endangered, or of commercial or recreational
value).
Assessment of operational impacts centers on the effects of
water withdrawal and the associated losses to the fish commu-
nity due to entrainment and impingement. Potential changes
in the population structure all addressed. Losses are estimated
from population densities and from the field sampling program.
Entrainment losses are expressed as “adult-equivalents” if war-
ranted for important species. Potential discharge effects (ther-

mal and chemical) are based on information developed from
the literature review and input of engineering parameters.
C016_007_r03.indd 996C016_007_r03.indd 996 11/18/2005 11:01:29 AM11/18/2005 11:01:29 AM
© 2006 by Taylor & Francis Group, LLC
PLANNING FOR NEW PROCESSES: ENVIRONMENTAL ASPECTS 997
Land and Waterway Use
The purpose of the land and waterway use—demographics
effort is to:
1) determine the existing land use of the site and
existing and future land and waterway use pat-
terns in the surrounding area in order to assess
any conflicts which may exist and to evaluate any
impacts on land use that may occur from the con-
struction and operation of the plant; and
2) determine the population growth patterns of the
area in order to assess the impact the plant will have
on nearby towns and communities in the area.
Based on the existing land uses, and the analysis performed
by other disciplines such as terrestrial and aquatic ecology
and air quality, impacts upon adjacent land uses caused
by construction and operation are estimated. This impact
assessment includes the impact of storage pond construc-
tion, noise, dust, plant appearance, stack emissions, cool-
ing tower fogging and salt depositions, and construction
stage traffic activity on residential, recreational, agricul-
tural, and other adjacent land uses in the area, as well as
the compatibility of the proposed plant with local land
use plans, aesthetics, and regulations. Specific attention
is given to the type and relative value of the land uses to
be preempted or adversely affected by plant construction

and operation.
The impacts of the increase in activities on a river if
applicable is estimated including additional barge traffic
staging in the area and the impact of these activities on exist-
ing movements and facilities in the vicinity of the area.
The demographic impact assessment consists of com-
paring the population projections for the study area to the
expected population influx to be caused by plant construc-
tion and operation. The comparison is done by taking the
estimated plant-related population influx as a percentage of
the total projected population of the area to be affected by
the incoming workers and families.
Socioeconomics
The purpose of the socioeconomics studies is to deter-
mine and describe the existing socioeconomic base for the
plant region and surrounding major towns and to assess the
changes, either positive or negative, which would occur as a
result of the construction and operation at the proposed site.
The existing socioeconomic based is described for those
areas likely to be impacted by the influx of construction and
operational employment for the plant. Information required
to describe the socioeconomic base of the area includes the
following:
1) peak number of construction workers by craft
during each year of plant construction;
2) estimate of the number of immigrant construction
workers expected during construction of the plant;
3) existing and future capacity of the schools, hospi-
tals, fire, sewer, etc., facilities in site area;
4) local government fiscal capabilities and local tax

structure and tax bases;
5) employment and income statistics; and
6) economic base studies.
Socioeconomic impacts can result from the influx of
immigrant construction workers to the area around the
plant. This occurs when the construction force required to
build the plant is fairly large and there are a number of
large construction projects competing for the labor supply
in the area.
The socioeconomic demand analysis qualitatively com-
pares the demand for service facilities, and employment
during the construction and operation of the plant with the
baseline socioeconomic projections. Any perceived increases
in demand for local facilities is qualitatively evaluated with
respect to the cost of the facilities and the ability of local
units to finance them.
Impacts associated with plant operation to be assessed
include an evaluation of the change in local tax structure as
a result of a large influx of new tax revenues to the local
governments and the impact associated with the relocation
of plant operating personnel into the area.
Noise
The purpose of this effort is to sample the existing ambi-
ent noise levels surrounding the proposed site, and to esti-
mate the environmental noise impact produced by the plant
operation.
In order to properly assess the noise environmental
impact, plant noise emissions should be evaluated in terms
of any State or local noise regulations. Consequently, vari-
ous State and local regulatory agencies are contacted to

determine the status of the regulatory constraints that might
be imposed on the plant operation and construction noise
emissions. In the absence of any such constraints, US EPA’s
guidelines for the protection of “Public Health and Welfare,”
as indicated in the “Levels Document” (550/9-74-004) are
followed.
A literature review is conducted to assist in identifying
the major sources of noise of the plant and in quantifying
them. The search includes various professional journals,
other environmental reports, and manufacturers’ publica-
tions. Construction schedule, equipment list, general arrange-
ment drawings, project description manual, and operational
parameters of major plant equipment (Forced Draft Fans,
Turbine Generator, Pumps and Motors) are obtained from
the appropriate sources.
The facility noise levels are then evaluated and
assessed in terms of existing regulations or guidelines and
any potential restrictive conditions in either the working
environment or the general site environment are identified.
In addition, potential limitations to equipment are identi-
fied as are appropriate mitigative measures.
C016_007_r03.indd 997C016_007_r03.indd 997 11/18/2005 11:01:30 AM11/18/2005 11:01:30 AM
© 2006 by Taylor & Francis Group, LLC
998 PLANNING FOR NEW PROCESSES: ENVIRONMENTAL ASPECTS
Cultural Resources
Cultural resource studies involve a review of appropriate
records, and site-related literature to identify sensitive archaeo-
logical, historical, recreational, and aesthetic resources in the
project area.
Most of the information required for cultural resource

studies is available from State and Federal cultural resource
agencies and societies. An on-site survey is conducted
to locate any cultural resources eligible for the National
Register of Historic Places.
Project components which affect significant cultural
resources are identified and the magnitude of the impact
evaluated. Mitigation alternatives are addressed. If seri-
ous impacts are discovered they should be brought to the
attention of the developers promptly so that policy deci-
sions can be made at the earliest opportunity to rectify the
situation.
Air Quality/Meteorology
The purpose of this program is to obtain and analyze Air
Quality/Meteorology data so that: the site can be charac-
terized; the air quality implications of the facility can be
evaluated; mitigative and control measures can be devel-
oped; and an Environmental Report and PSD application
can be prepared.
The data required for the Air Quality/Meteorological pro-
gram work efforts relate to: (1) The air quality/meteorological
characterization of the existing site and region; and (2) The
facility’s atmospheric emissions and operating characteristics.
Specifically, the existing site and region must be characterized
in terms of the regulated pollutant such as SO
2
, Particulates,
NO


x

, CO, Photochemical Oxidants, and the local meteorol-
ogy, including winds, stability, and other physical charac-
teristics. In addition, the facility’s emission characteristics
including their quantity and quality must be developed so that
their impacts can be established.
To establish the required data base it is necessary to
gather and update existing emission inventory information,
collate meteorological and air quality data, review present
and proposed PSD Class I and nonattainment areas, evaluate
topographic influences and monitor the region’s air quality
characteristics.
The task of establishing adequate meteorological and
air quality data bases includes evaluating any existing local
meteorological and air quality data. The validity of the data
and its representativeness with respect to the proposed site
must also be assessed. As required, data from other sources
is evaluated as a basis for comparison with local data, or as
a supplement to local data where necessary. The objective is
to establish meteorological and air quality data bases which
are most representative of the proposed site.
A report should be prepared to provide technical sup-
port for a construction permit application under the PSD
provisions of the Clean Air Act of 1977. Described in
the report are the data bases, methodologies and models
utilized in the analyses. The PSD report also includes
appropriate maps, summary tables and figures necessary
to display relevant information such as locations of plant
sites, PSD Class I and nonattainment areas, and resultant

pollutant concentrations.
An atmospheric impact assessment of the proposed
and alternative cooling tower types is included in the ER.
Operational impacts of the tower to be considered include
elevated visible plumes and deposition of cooling tower
drift. Computer modeling is utilized to predict the impact of
these occurrences.
Ground level fogging/icing is also addressed. Computer
modeling is utilized to predict the frequency and duration
of ground level fogging and icing for the alternative cooling
towers. The potential for interaction of the cooling tower and
stack plumes must also be addressed.
National Weather Service (NWS) data can be supplemented
by any available meteorological data to the fullest extent pos-
sible to develop the estimates of cooling frequencies, and salt
deposition rates are given on an area basis and include more
detailed information, as necessary, for any sensitive receptors.
Health Implications
The purpose of this work effort is to identify and evaluate
the potential health concerns, including estimates of offsite
exposures that may result from facility operation at the site.
Once the concerns are identified, the need for controls and
the feasibility of the gasification plant at a particular site from
a public health perspective can be evaluated. Changes in coal
type, process or waste treatment systems can be addressed
if needed to mitigate a potential health concern. This allows
and insures that alleviation of potential health problems is an
integral part of the facility planning.
The health implications to the offsite population are iden-
tified and assessed. Specific analytical measurements from

pilot plant studies, available information from similar indus-
trial plants, and other existing studies regarding the health
implications from coal conversion processes are used. The
overall approach involves scaling the results of specific pilot
plant runs and other study results to approximate a commer-
cial size facility; applying standard air dispersion models and
waste dilution criteria in order to predict exposure concen-
tration; and evaluating the predicted concentration against
known information on the toxicity of each contaminant.
The identification of potential public health concerns
requires not only the estimation of exposure levels but also
the evaluation of the relative toxicity of each chemical species.
Consequently, a review of the toxic properties of each iden-
tified chemical substance or chemical group is required. At
the conclusion of this evaluation each contaminant or chemi-
cal group is categorized into one of four groups—potentially
significant health problems, potentially minor health problem,
no expected health problem, and those for which insufficient
information is available.
The results of this evaluation is then utilized to develop
control systems and/or mitigative actions for the facility. In
addition, the results are presented in the ER and discussed in
terms of a cost/benefit framework.
C016_007_r03.indd 998C016_007_r03.indd 998 11/18/2005 11:01:30 AM11/18/2005 11:01:30 AM
© 2006 by Taylor & Francis Group, LLC
PLANNING FOR NEW PROCESSES: ENVIRONMENTAL ASPECTS 999
With regard to occupational health, worker exposure to
toxic substances is a potentially serious problem which could
significantly lessen and limit the benefits of alternative fuel
technology. As such, its implications must be carefully eval-

uated in the planning and design phases of this project. The
Occupational Safety and Health Act (OSHA) contains basic
worker protection guidelines and specific regulations which
establish industry procedures for the protection of work-
ers from exposure to potentially toxic or health impairing
substances.
However, the current regulations do not specifically
address a coal gasification process and only limited operat-
ing experience is available from existing gasification plants.
Consequently, identification of potential occupational health
problems must be done in an indirect manner through com-
parison with other industries.
This occupational hazard analysis yields identification
of potential hazards, definition of possible control measures
for as many of those hazards as possible, and identification
of areas of concern where insufficient knowledge or control
methodologies exist. In addition it provides input to:
1) design of worker protection programs to be imple-
mented at the plant,
2) design of engineering controls to minimize work-
er exposure to hazardous substances, for example,
isolation of process steps, ventilation changes,
pressure control, etc.
Most of the procedural information, repeated from the arti-
cle by Quig and Granger (1983) remains valid today. For a
more quantitative treatment of the effluent emissions observed
during plant operation the reader is referred to the study of Holt
(1988) on the Cool Water plant and to the current Encyclopedia
article, Coal Gasification Processes.
PERMITTING FOR LANDFILL GAS ENERGY

RECOVERY
Purpose
New York State Air Guide 41 (1996) provides guidance on the
permitting of emissions from municipal solid waste landfills,
including the use of landfill gas for energy recovery, flares and,
also, passive venting, as per the following:
Background
Landfill gas (LFG) is generated by the decomposition of
wastes in all municipal solid waste landfills, regardless of
age or size. The total volume of gas generated is a direct
function of the quantity of wet, decomposable refuse available;
however, the rate of gas generation can vary greatly over
time, depending on numerous factors (such as the volume
of waste, the depth of the landfill and the amount of rain-
fall the landfill receives), most of which are uncontrollable.
Landfills the accept waste water treatment plant sludge for
disposal tend to generate more LFG than those that do not.
LFG is not generated until the available oxygen supply has
been consumed and the decomposition process becomes
anaerobic. The typical composition of LFG is essentially the
same at all landfills and at all points within the landfill. The
typical composition of LFG is:
Methane 50–58%
Carbon Dioxide 35–45%
Hydrogen 1–2%
Oxygen 1–2%
Nitrogen 2–5%
Non Methane Organic Compounds 3–5%
(NMOCs)
1

LFG can, and should, be used for energy recovery. The energy
content of LFG comes entirely from the methane component,
which has a basic heating value of 1,000 Btu/standard cubic
foot (scf). Since the nominal concentration of methane in LFG
is approximately 55%, the heating value of raw LFG is approx-
imately 550 Btru/scf, although this figure can, and will, vary
somewhat. By comparison, natural gas is composed of 95%
methane, giving it a basic heating value of 950 Btu/scf.
At the majority of landfills in New York State, LFG is
currently uncontrolled or passively vented to the atmosphere.
Recovering and combusting such gas into useful energy will
virtually eliminate harmful emissions from a fuel that is oth-
erwise wasted. This also prevents the pollution associated
with the use of fossil fuels (i.e., SO
2
). If LFG is not com-
busted, it will still escape to the atmosphere through the path
of least resistance (diffused from landfill, vented or flared).
Federal Regulations
Air In accordance with the Clean Air Act, the U.S.
Environmental Protection Agency (EPA) has proposed New
Source Performance Standards (NSPS) under 40 CFR 60
Subpart WWW for municipal solid waste landfills. These
NSPS will affect landfills that began construction or modifi-
cation after the standard was proposed (5/30/91) or existing
landfills that have accepted waste since November 8, 1987.
It must be noted that this proposed rule is currently being
developed. The rule is subject to change and it is possible that
it will not be released. However, the guidelines contained in

this proposed rule should be used in developing a permit for
the use of landfill gas. Additional information regarding this
proposed rule is included in Appendix A.
In a recent Federal court case in Pennsylvania (Ogden
Products Inc. vs. New Morgan Landfill Co.), the court ruled
that the landfill in question is subject to New Source Review
since it has the potential to emit more than 50 tons per year
of volatile organic compounds. This decision, combined with
the NSPS for landfills proposed by the EPA, will make all
new landfills subject to the requirements of the CAA, partic-
ularly if the landfill has the potential to emit volatile organic
compounds at levels exceeding air quality standards.
Hazardous Waste When LFG is recovered, it tends to
cool, and some condensate is formed. It is stated in Section
C016_007_r03.indd 999C016_007_r03.indd 999 11/18/2005 11:01:30 AM11/18/2005 11:01:30 AM
© 2006 by Taylor & Francis Group, LLC
1000 PLANNING FOR NEW PROCESSES: ENVIRONMENTAL ASPECTS
124 of the Superfund Amendments and Reauthorization Act
(SARA) of 1986 that if the aqueous or hydrocarbon phase
of the condensate removed from the gas recovered from
a landfill meets any of the characteristics of a hazardous
waste (i.e., it fails the TCLP test), the condensate shall be
considered hazardous waste and regulated accordingly. This
section is an amendment to the Resource Conservation and
Recovery Act (RCRA), but is not part of RCRA. Since this
provision of SARA is not actually part of RCRA and there
are no implementing regulations in 40 CFR, it may be bind-
ing upon EPA, but RCRA-authorized states (such as New
York) are not obligated to enforce its requirements. This
issue could arise if LFG is to be recovered from a munici-

pal landfill that meets the size and NMOC criteria cited in
Appendix A and is included on the Superfund priority list of
inactive hazardous waste sites.
State Regulations
Solid Waste 6 NYCRR Part 360 has requirements for the
control of LFG during both the active life of the landfill and
after the landfill is closed. While the landfill is in operation,
the owner must periodically (i.e., quarterly) monitor for the
presence of LFG at or above 25% of the lower explosive limit
(LEL) at on-site structures and any off-site areas. When the
landfill is closed, an LFG control system must be included
in the closure plans to prevent the migration of concentrated
LFG away from the site and to prevent damage to a landfill
cap. LFG is lighter than air and will tend to rise causing the
overlying cap to rise also. Generally the LFG is allowed to vent
to the atmosphere through a porous gas vent layer that leads
to gas vent risers spaced at approximately one vent per acre.
Part 360-2.16 contains the regulations regarding LFG
recovery facilities. These regulations require that anyone
proposing an LFG facility obtain a permit to construct and
operate the facility. The application for a permit must con-
tain an engineering plan, engineering report and an opera-
tion and maintenance plan.
Hazardous Waste As cited above, some LFG condensate
may exhibit hazardous waste characteristics. In an October
20, 1992 declaratory ruling applying to the Freshkills Landfill,
the Department excluded landfill gas condensate from being
regulated as a hazardous waste.

This ruling was based on the

grounds that the LFG was derived from a household waste and
therefore excluded from hazardous waste regulation under New
York State law. However, if the landfill received both munici-
pal and industrial or hazardous waste, the condensate may be
hazardous. The condensate would need to be analyzed using
the TCLP method to determine if it is a hazardous waste.
Air NYSDEC’s proposed Part 201 operating permit
program (proposed to comply with the federal Clean Air
Act Amendments of 1990) contains an exemption for LFG
emissions vented directly (i.e., without a flare or energy
recovery device) to the atmosphere that fall beneath major
source thresholds as long as the facility is operating in
compliance with 6 NYCRR Part 360. Such an exemption
will not apply to landfills subject to NSPS or National
Emissions Standards for Hazardous Air Pollutants.
A number of landfills in New York State currently use
flares or energy recovery for control of their LFG. These
emission sources must have a permit from the Division of
Air Resources. These permits are issued under 6 NYCRR
Part 201. All energy recovery projects produce NO


x


in the
combustion of the LFG. These projects must control NO


x

emissions as required under Part 227-2. For example, if a
lean burn internal combustion engine running on LFG is
used for energy recovery, the emission limit for NO


x


is 9.0
grams/brake horse power-hour (Part 227-2.4(f)).
LFG recovery projects would be affected by either
Prevention of Significant Deterioration (PSD) or New
Source Review in Nonattainment Areas (Part 231) regu-
lations depending on the location of the project. Projects
in nonattainment areas are likely to be affected by NO


x



and CO requirements (Note: the entire state is nonattain-
ment for VOC and NO


x

because the state is in the ozone
transport region). This is because recovering energy with a
combustion unit will create NO


x


and CO that often require
emission offsets to be obtain and the installation of Lowest
Achievable Emission Rate (LAER) technology.
The EPA has issued interim guidance stating that sources
may be exempt from New Source Review (NSR) provided
that the project is environmentally beneficial and there are
no adverse air quality impacts. This exemption from NSR is
referred to as a pollution control project. The EPA presently
expects to complete rulemaking on an exclusion from major
NSR for pollution control projects by mid 1996. However, in
the case of nonattainment areas, EPA believes that the state
or the source must provide offsetting emission reductions for
any significant increase in a non-attainment pollutant from a
pollution control project.
Presently, 6NYCRR Part 231 allows a Pollution con-
trol project exemption only at existing electric utility steam
generating units (Ͼ25 megawatts of electrical output).
Consequently, LFG projects which exceed the applicability
thresholds, would have to obtain NO

x


offsets at a ratio of 1.3
or 1.15 to 1, depending on the location of the project (i.e., in
a severe non-attainment area or in a moderate non-attainment
area), and would be required to install LAER technology.
Please note that this may change if the EPA determines that
this type of project is eligible to become a pollution control
project.
Approach to Permitting—DAR
When the economics of an energy recovery project using
LFG are favorable, these projects are to be encouraged. The
following is the hierarchy of preferred LFG uses:
1. Gas cleaning and upgrade to pipeline quality gas;
2. Energy recovery with gas pretreatment or conver-
sion to a reusable chemical product;
3. Energy recovery without gas pretreatment;
4. Flares with high combustion efficiency (i.e., 98%
or greater);
5. Vents, if no economically feasible use for the gas
is available.
C016_007_r03.indd 1000C016_007_r03.indd 1000 11/18/2005 11:01:30 AM11/18/2005 11:01:30 AM
© 2006 by Taylor & Francis Group, LLC
PLANNING FOR NEW PROCESSES: ENVIRONMENTAL ASPECTS 1001
The following procedure will be used for permitting of
energy recovery facilities that utilize LFG:
If the LFG Is Pretreated (i.e., if the constituents other
than methane are removed from the gas), then permit as
a combustion source with no further emission testing or

ambient modeling necessary to satisfy toxic concerns. The
permit should address traditional combustion contaminants
such as NO


x


and CO. However, the permit application for
this type of option must include a detailed description of
the method(s) to be used for gas pretreatment. LFG can
contain up to 50%, by volume, CO
2
(35–45%) and air
toxics (1–2%). The pretreatment employed must remove
these compounds before the LFG can be permitted for just
the traditional combustion contaminants. Note that gas
pretreatment will minimize toxic products of incomplete
combustion and minimize system corrosion.
If the LFG Is Not Pretreated, then permit as a combus-
tion source and use the total concentration of NMOC emit-
ted to address toxic issues. Note that if the gas is burned,
either by a flare or energy recovery process, generally the
air toxics will be destroyed. It will be easier and more effi-
cient to regulate the NMOC (or total VOCs) than trying to
identify and regulate all contaminants of LFG emissions,
since they can vary greatly depending on the waste dis-
posed at the landfill. The permit should address traditional
combustion contaminants such as NO

x


and CO. The EPA
proposed standard of 20 ppmvd NMOC should be used as
BACT for the control of untreated LFG used as a combus-
tion source. Periodic stack testing of the emissions is rec-
ommended at the discretion of the permit writer.
With regard to compliance with Part 231, the LFG
facility may need to obtain NO


x


and CO offsets at the
ratio applicable to its location (i.e., 1.3 or 1.15 to 1). This
requirement may change if the EPA decides that LFG-type
facilities are eligible for a pollution prevention exclusion.
The permit reviewer will need to exercise judgment to
determine if the LFG facility is required to obtain these
offsets. As stated above, an LFG facility can be used for
energy recovery. While a combustion turbine or internal
combustion engine is not normally considered add-on pol-
lution control devises, they do serve the same function as a
flare, namely to reduce VOC emissions at the landfill with
the incidental benefit of producing useful energy (energy
that would otherwise be produced using higher polluting
fossil fuels). For an LFG facility the reviewer should pro-

ceed as follows:
1. Verify that the NO


x


increase has been minimized
to the extent practicable;
2. Confirm (through modeling or other appropriate
means) that the actual significant increase in NO


x



emissions will not violate the applicable NAAQS,
PSD increment or adversely impact any air qual-
ity related value;
3. Apply all otherwise applicable SIP and minor source
and permitting requirements and ensure that NO
x

offsets are provided in an area in which nonattain-
ment review applies to NO


x

emissions increases.
Coordination within the Department
The use of LFG will require coordination of efforts
between the Divisions of Air Resources (DAR) and Solid
and Hazardous Materials (DSHM). If a landfill meets the
criteria cited above and the emissions from the site must
be controlled, the proposed plan for this control should
be submitted to both Divisions. DSHM should focus their
review of the proposal, based on the requirements of Part
360-2.16. DAR should focus their review on evaluating and
permitting the combustion sources that utilize the LFG, as
outlined in the previous section. Both Divisions must keep
in mind that LFG can be a valuable resource for energy
generation and that using this resource will conserve the
use of other fossil fuels and permit the re-use of material
otherwise considered waste. Further, the respective project
managers handling a particular facility’s permit applica-
tion should maintain communication to ensure that there
are no unnecessary delays on developing a permit for an
LFG facility.
APPENDIX A OF AIRGUIDE 41
NSPS for Municipal Solid Waste Landfills
In accordance with the Clean Air Act, the U.S. Environmental
Protection Agency (EPA) has proposed New Source
Performance Standards (NSPS) under 40 CFR 60 Subpart
WWW for municipal solid waste landfills. These proposed
NSPS will affect landfills that began construction or modi-
fication after the standard was proposed (5/30/91) or exist-
ing landfills that have accepted waste since November 8,

1987. It must be noted that this proposed rule is currently
being developed. This proposed rule would require landfills
to install active gas collection and control systems if they
exceed both of the following criteria:
• design capacity in excess of 2.500,000 Mg
(2,700,000 tons); and
• NMOC emission rate in excess of 50 Mg per year
(50.05 tpy).
Landfills closed prior to November 8, 1987 or having design
capacities less than 2.5 million metric tons will be exempt
once this rule is finalized.
The NMOC emission rate is determined by the following
equation:
M
NMOC
= 2 L
0
R (1Ϫe
– kt
) C
NMOC
(3.595 ϫ 10
– 9
) where,
M
NMOC
= mass emission rate for NMOC, Mg/yr
L
0
= refuse methane generation potential, m

3
/Mg
refuse (default value = 170 m
3
/Mg)
R = average annual acceptance rate, Mg/yr
k = methane generation rate constant, 1/yr
(default value = 0.05/yr)
t = age of the land fill in years
C016_007_r03.indd 1001C016_007_r03.indd 1001 11/18/2005 11:01:30 AM11/18/2005 11:01:30 AM
© 2006 by Taylor & Francis Group, LLC
1002 PLANNING FOR NEW PROCESSES: ENVIRONMENTAL ASPECTS
C
NMOC
= concentration of NOMOC, ppmv as hexane
(default value= 4,000 ppm)
3.595 ϫ 10
Ϫ 9
= conversion factor
(Note: In the absence of site specific data, use the given default
values to determine NMOC emission rate.)
Each landfill of design capacity greater than or equal
to 2,500,000 Mg must determine its NMOC emission rate,
using the above equation. If the NMOC mass emission rate
is less than 50 Mg/yr, the landfill owner would submit this
information to the NYSDEC as part of the Part 360 permit.
No further action regarding control of the landfill emission
would be required. The emission rate will be recalculated
annually, with a report submitted to the Department. This
report must be submitted to the Department within 90 days

of the issuance of a construction or operating permit or ini-
tial acceptance of refuse, whichever is earlier.
If the NMOC mass emission rate is greater than 50 Mg/yr,
the landfill owner must submit a design for, and install a col-
lection and control system at the landfill. This control system
must be designed to reduce, in accordance with 40 CFR 60
Subpart WWW, the emission of NMOCs by 98% by weight.
Wehland and Earl (2004) present the inconsistencies in
legal and enforcement interpretations of the PSD requirement
for NSR major modifications and hence the criteria by which
to determine the need for a PSD permit and the installation
of BACT. There is no need to install equipment if the modifi-
cations are of the routine maintenance, repair or replacement
without increase in unit capacity. For each of the four cases
involving coal fired power plants in which decisions were
reached prior to 2004, the court’s conclusions were different,
and in some cases significantly different. In U.S. vs. Southern
Indiana Gas & Electric Co. (S.D. Ind. 2003), the district court
ruled that the utility had fair warning about EPA’s decision to
review the records of the affected unit, only, in determining if
the maintenance was routine, but deferred its final determina-
tion to the more general NSR applicability. In U.S. vs. Ohio
Edison (S.D. Ohio 2003), the court concluded that fair warning
was given to the utility in the plain language of the CAA.
The court gave weight to establishing the routine nature
of the maintenance by analyzing the all of the factors below
for the projects:
(1) budgeting and accounting,
(2) purposes and costs, and the
(3) net emissions increase

In U.S. vs. Duke Energy (M.D. N.C. 2003), the district court
ruled that EPA’s past practices in other cases require that
industry-wide rather than the individual unit’s past practices
were the criteria to be followed. Also the court favored an
increase in emissions analysis to be on a “Projected actual”,
rather than on a “future potential” basis. They also indicated
that when determining the applicability of a modification,
the NSPS rule of not increasing the maximum hourly emis-
sions rate should be followed.
In the case, Tennessee Valley Authority vs. U.S. (11
th
Cir.
2003), the decision by the circuit court side-stepped the pri-
mary differences and ruled against the EPA because of its
use of an administrative procedures that deprived TVA of its
rights to a hearing. In October 2003 the EPA defined a rou-
tine project as one that would cost less than 20% of the total
cost of replacing an emitting unit. The new rules and lack
of enforcement were being challenged as of 2004. An alter-
native to the current regulations offered by the authors, “is
to eliminate the NSR and incorporate plant-wide emission
limits in operating permits.” They also recommend model-
ing and employing maximum achievable control technology
(MACT) when modeling results determine controls are nec-
essary to protect the air quality.
REFERENCES
Holt, N.A., EPRI Report AP-5467, Feb. (1988).
Quig, R.H., Chem. Eng. Prog., 76, 47–54, March (1980).
Quig, R.H. and Granger, T., Encyc. Of Env. Sci. & Eng. Vol. 1, 103–113
(1983).

NYS Department of Environmental Conservation, Albany, New York, Air
Guide 41, p. 1–5, March (1996).
USEPA TITLE 40 CFR 52.01–52.2, P. 9–55 US Government Printing
Office, Washington DC: July 1, 2000.
Ibid Title 40 CFR 51.166, p. 167–186
Wehland C. and L. Earl, Clearing the Air, Environ. Protection, p. 20–22, 66,
ROBERT H. QUIG
THOMAS GRANGER
Ogden Products, Inc.
EDWARD N. ZIEGLER
Polytechnic University
C016_007_r03.indd 1002C016_007_r03.indd 1002 11/18/2005 11:01:30 AM11/18/2005 11:01:30 AM
© 2006 by Taylor & Francis Group, LLC
June 2004. gen/wkshpman.pdf