Document 2JKNbadgz80Yj5nbLeqQDZ2bR
June 30, 1989
Louisiana Gasification Technology, Inc.
fPr. ^ ^ --" -i'' I
P.O. Box 150 5701 Building Plaquemine, Louisiana 70765-0150 (504) 389-8000 FAX: 504-389-8039
Mike Nevill Environmental Services Building 3502-E
RE: ENVIRONMENTAL MONITORING PLAN ANNUAL REPORT
In accordance with Article 7.4(b) of the Price Guarantee Commitment, enclosed herewith is the Environmental Monitoring Plan Annual Report covering the time period between April 1, 1988 to March 31, 1989 for the Dow Syngas Project.
Sincerely,
C.
G. C. LeBlanc Environmental Coordinator
Enclosure
jdg
DO A 111263 CONFIDENTIAL
A Subsidiary of the Dow Chemical Company
ENVIRONMENTAL MONITORING PLAN
ANNUAL REPORT
APRIL 1, 1988 TO MARCH 31, 1989
JUNE 30, 1989
00 -i -t CNFTDFNTTa?
i
ENVIRONMENTAL MONITORING PLAN FOR THE
DOW SYNGAS PROJECT
ANNUAL REPORT
April 1, 1988 - March 31, 1989
Submitted to: Office of Synthetic Fuels Projects
U.S. DEPARTMENT OF TREASURY 1120 Vermount Avenue, N.W.
Suite 680 Washington, D.C. 20220
Submitted By: The Dow Chemical Company and Louisiana Gasification Technology, Inc.
P. 0. Box 150 Plaquemine, LA 70765-0150
For Information Contact: Gretchen LeBlanc
Environmental Coordinator (504) 389-1642
ii DO A 111265 CONFIDENTIAL
Section
TABLE OF CONTENTSJ
Page
1.0 Summary
1-1
v/2.0 Project Status
2.1-1
2.1 Plant
Production Summary
2.1-1
2.2 Plant
Description
2.1-1
2.2.1 Project Overview and Location
2.1-1
2.2.2 Process Description
2.2-3
2.2.2.1 Coal Slurry Facility
2.2-3
2.2.2.2 Gasification, Primary Particulate
Recycle, and Heat Recovery
2.2-3
2.2.2.3 Secondary Particulate Recycle and
Cooling
2.2-6
2.2.2.4 Selectamine H2S Removal, Selecto#
Sulfur Recovery, and Tail Gas
Incineration
2.2-6
2.2.2.5 Existing Gas Turbines
2.2-6
2.2.2.6 Emergency Flare System
2.2-6
2.2.2.7 Process Vastewater Treatment
2.2-7
2.2.2.8 Industrial Solid WasteLandfills 2.2-7
2.2.3 Process Design Changes
2.2-7
2.3 Environmental Monitoring Plan Status
2.2-8
3.0 Source Monitoring 3.1 Discharge Source Monitoring
3.1.1 Gaseous Streams 3.1.2 Aqueous Streams 3.1.3 Solid Streams 3.1.4 Fugitive (Point Source) 3.2 Environmental Control System Monitoring 3.3 Products and By-Products Monitoring
3.1-1 3.1-1 3.1-1 3.1-1 3.1-2 3.1-2 3.1-2
4.0
S' i/5.0
Ambient Monitoring 4.1 Ambient Air Monitoring 4.2 Ambient Water Quality Monitoring 4.3 Ambient Groundwater Monitoring
Health and Safety Monitoring 5.1 Annual Report 5.2 Safety Program 5.3 Industrial Hygiene Monitoring 5.4 Medical Monitoring
4.1-1 4.1-1 4.1-1 4.1-1
5.1-1 5.1-1 5.1-1 5.1-1 5.1-1
6.0 Compliance Monitoring 6.1 Air Permit 6.2 Water Permit 6.3 Solid Waste Permit
6.1-1 6.1-1 6.2-1 6.3-1
7.0 QA/QC Results 7.1 Source Monitoring - Sampling and Analysis 7.2 Gaseous Monitoring - Supplemental Monitoring by Radian
7-1-1 7.1-1
7.1-1
DO A 111266 CONFIDENTIAL
iii
TABLE OF CONTENTS (Continued)
V8.0
Monitoring Problems/Recommendations for Changes
8.1 Problems Encountered 8.2 Solutions 8.3 Recommended Changes to the Environmental
Monitoring Plan
Appendix 1 Appendix 2 Appendix 3 Appendix 4
Groundwater Monitoring Data Notifications to State Agencies Water Permit Modifications Solid Waste Surface Impoundment Modification
Air Permit Permit
8.1-1 8.1-1 8.1-1
8.1-1
Al-1 A2-1 A3-1
A4-1
DO A 111267 CONFIDENTIAL
Table 2.1-0 2.1-1
LIST OF TABLES
Table of Significant Events Key to Monitoring Location Designators
Page 2.1-2 2.2-5
DO A 111268 CONFIDENTIAL
v
LIST OF FIGURES
Figure
1-1 2.1-1 2.1-2
2.1-3
Project and Monitoring Schedules
Project Location
Location of Syngas Project Facilities at the Dow Louisiana Division Site
Process Block Diagram indicating Monitoring Locations
Page 1-2 2.2-1 2.2-2 2.2-4
DO A 111269 CONFIDENTIAL
vi
I 2.0 PROJECT STATUS
2.1 Plant Production Summary
The Dow Syngas Project achieved Commencement of Commercial Production on December 18, 1988. This major project milestone and
contract commitment involved production equating to 60 X of capacity
in a consecutive 90 day period. The plant has operated at daily production rates as high as 91.9 %, limited primarily by operational problems associated with the wastewater treatment system, char recycle handling system, and shutdowns for routine equipment inspection and maintenance.
The plant operated a total of 5307 hours on coal (1348 hours during first quarter 1989), producing a total of 5435 BBtu of on spec product (1446 BBtu during first quarter 1989). During the reporting period, the plant was on line and in service to the
Power Plant over 59 X of the time (58 X during first quarter 1988).
Production during this reporting period was more than double that of the previous annual reporting period. A number of production records were set during the period, including daily, monthly, quarterly and annual records. In addition, on March 29, 1989, the plant began a test run on bituminous coal. (See Table 2.1-0 for a listing of significant events during the reporting period.)
2.2 Plant Description
Design changes completed during this reporting period are described in Section 2.2.3 and are reflected in modifications of the plant description in Section 2.2.2.3. The remainder of Sections 2.2.1 through 2.2.2.8 are unchanged from the Quarterly Report for fourth quarter 1988.
2.2.1 Project Overview and Location
The Dow Syngas Project produces medium BTU synthetic gas (syngas) for consumption by the existing gas turbine power generation units at Dow's Louisiana Division chemical complex in Plaquemine, Louisiana. Figure 2.1-1 shows the location of the Louisiana Division. Figure 2.1-2 shows the location of the Dow Syngas Project facilities at the Louisiana Division site.
At capacity, the Dow Syngas Project will produce 30,000MM BTU of synthetic gas per day from approximately 2,200 tons per day of western sub-bituminous coal from the Powder River Basin in Wyoming. The design-basis coal, used for purposes of sizing equipment, is a lignite coal. The Project will use sub-bituminous coal ir.iHaliy and intends to switch to lignite or other types of coal later on in the project life. All ranges of coal, .'deluding anthracite, bituminous, sub-bituminous, and lignite, may be used if the specific plant design is adapted to that coal type and as
long as the feedstock does not exceed 1.2 X sulfur as allowed
in the air permit for the project.
2.1-1
CDOONFAIDENTIAL
r DATE
TABLE 2.1-0
LIST OF SIGNIFICANT EVENTS APRIL 1, 1988 - MARCH 31, 1989
EVENT
COMMENTS
4-1-88 Gasifier on coal
Continuation of operation from previous quarter
4-7-88 Gasifier on coal
Tail Gas Incinerator opacity exceeds 20 X
4-29-88 Daily Production Record
91.9 X
April 1988
Monthly Production Record 37.8 X
5-3-88 Gasifier on coal
S02 emission from Gas Turbine Stack exceeds permit by 9.2 lbs
5-18-88 Manual trip of gasifier
Trip to avoid release of H2S in excess of reportable quantity for H2S from Tail Gas Incinerator
5-18-88 Gasifier on coal
6-1-88 Manual trip of gasifier
Trip to eliminate incinerator stack emissions in excess of 20 X opacity
6-6-88 Gasifier on coal
Tail Gas Incinerator opacity exceeds 20 X
6-14-88 Annual Production of 1987 exceeded
6-19-88 Trip of Gasifier
Trip to install secondary soot scrubber
Second Quarter 1988
Quarterly Production Record 33.2 X
7-6-88 Gasifier on coal
7-19-88 Gasifier on coal
Tail Gas Incinerator opacity exceeds 20 X
July
Monthly Production Record 53.9 X
2.1-2
DO ft d^t1AL
TABLE 2.1-0 (continued)
LIST OF SIGNIFICANT EVENTS APRIL 1, 1988 - MARCH 31, 1989
DATE
EVENT
COMMENTS
8-29-88 Gasifier on coal
Tail Gas Incinerator opacity exceeds 20 X
8-30-88 Gasifier on coal
Tail Gas Incinerator opacity exceeds 20 X
8-31-88 Gasifier on coal
Tail Gas Incinerator opacity exceeds 20 X
9-1-88 Gasifier on coal
Tail Gas Incinerator opacity exceeds 20 X
Third Quarter 1988
Quarterly Production Record 44.4 X
October Continuous "On-Coal" Record
11-10-88 Gasifier on coal
Tail Gas Incinerator opacity exceeds 20 X
11-23-88 Gasifier on coal
Tail Gas Incinerator opacity exceeds 20 X
11-30-88 Manual trip of gasifier
Major maintenance performed included planned modifications to the wastewater treatment system
November Continuous "On-Coal" Record
1988
Monthly Production Record
79.3 X
12-7-88 Gasifier on coal
12-18-88 Established Commercial Production Status
Fourth Quarter
1988
Quarterly Production Record 64.0 X
1988
Annual Production Record
41.6 X
2.1-3
DO A 111272 CONFIDENTIAL
TABLE 2.1-0 (continued)
LIST OF SIGNIFICANT EVENTS APRIL 1, 1988 - MARCH 31, 1989
DATE
EVENT
COMMENTS
1-1-89 1-28-89
3-10-89 3-30-89
Gasifier on coal
Manual trip of gasifier
Shutdown to coincide with Power Plant outage for Gas Turbine work
Continuous "On-Coal" Record
Gasifier on coal
Test run on bituminous coal begun
2.1-4
* iU273
do
COM
8462
2.2-1
DO A 111274 CONFIDENTIAL
2.2.2 Process Description
The block diagram in Figure 2.1-3 illustrates the process used by the Dow Syngas Project. The environmental monitoring locations designated for the process are listed in Table 2.1-1. The following subsections describe various portions of the project.
2.2.2.1 Coal Slurry Facility
The existing coal slurry facility, which was designed to support the Prototype II coal gasification plant, was expanded to provide the coal slurry feed for the commercial facilities. Coal is delivered in bottom dump hopper cars and discharged from the railcars into unload pit hoppers. Conveyors move the coal from the hoppers to a radial area and keeps dust emission to a minimum. Reclaiming of stacker which distributes coal over the entire stockpile the coal from the stockpile is accomplished by using a bulldozer to feed the coal in to reclaim pit hoppers where it is then ground and slurried with recycled process water and transferred to storage tanks. Coal slurry is transferred to the process site via pipeline into a storage tank located at the process site.
2.2.2.2 Gasification, Primary Particulate Recycle, and Heat Recovery
The Dow Syngas Project gasifier design is proprietary, but can be generally classified as a high-temperature, entrained-flow, slagging design.
The coal slurry is fed to the reactor, where it is mixed with oxygen and the reactor temperature is carefully controlled to maintain a specific narrow range. The coal is almost totally gasified by partial combustion to produce synthetic gas consisting principally of hydrogen, carbon monoxide, carbon dioxide, and water. The sulfur in the coal is converted almost totally to hydrogen sulfide with small amounts of carbonyl sulfide. The nitrogen from the coal is converted primarily to elemental nitrogen with some ammonia (NH3) found and to a lesser degree to hydrogen cyanide
and thiocyanate.
The ash is fused in the flame and is drained as molten slag from the bottom of the reactor by an enclosed system. The slag will be used for commercial purposes, rather than being disposed of as a solid waste.
The gas is passed thicugh a cyclone separator to remove
most of the entrained char. The removed char particles are
slurried with recycled water and the slurry recycled back to
the gasifier. The raw synthetic
containing some
entrained particulates (char) is then cooled in a heat
recovery train, generating steam.
111276
CONFIDENTIAL
2.2-3
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DO A 111277 CONFIDFNTIAL
Location Designator
Proprietary Statu* of Monitoring Data*
1
2
3
4
5
6
7
8 9
10
11
12
13 14 15 16 17 17A 17B 18
18A
19
20
21
NP NP
NP P NP
P
NP P NP
P
NP NP P P NP NP NP NP NP
NP
NP NP
22 23
24
r
L
p
Sp
HP
a hunpropnctary P proprietary
P NP
NP NP
NP
P
NP NP
TABU 2.1-1 KEY TO MONITORING LOCATION DESIGNATORS
Daacription
Coal feedstock Rainwater runoff fro* coal pile Reserved designator (Location 3 was formerly groundwater monitoring wells associated with rainwater impoundment for coal handling are*. However, impoundment has been closed.) Slag from gasifier Raw syngas from gasifier Make-up water from Mississippi River Sour condensate water from syngas particulate recycle and cooling Excess sweet water after waste water treatment Wastewater header from other Louisiana Division process facilities Wastewater discharge from Louisian* Division treatment system
(optional process) Particulate-free tour syngas at inlet to Selectaxune acid gas removal
system Sweet syngas from Soleetamino acid gat removal system
Gas turbine stack gas
e
Acid gas from Selectamine acid gas removal system
Tail gas from Selectox* sulfur recovery unit
Incinerator stack gas Spent Selector catalyst from sulfur recovery unit
Spent Selector catalyst from incinerator
Spent claus catalyst from sulfur recovery unit Groundwater monitoring wells for new Louisiana Division solid waste landfill Groundwater water monitoring walls for Louisiana Division hacardous waste landfill Effluent from rainwater impoundment for process facilities areas Bayou Choctaw ambient air monitoring station Reserved designator (Location 21 was formerly char from syngas particulate recycle system which is considered an Internal stream and will not be monitored) Sour gas from distillation columns Excess sludge from Louisiana Division waste treatment system (optional process) Liquid sulfur from Seleetox sulfur recovery unit
Pugitive area monitoring (gaseous) near Dow syngas Project process facilities Leak detection monitoring (gaseous) near Dow Syngas Project process facilities Heslth and safety monitoring for personnel, during routine operation and during maintenance of process units Slag from oxygen-blown protoplant gasifier Sweet condensate water from oxygen-blown protoplant
2.2-5
DO A 111278 CONFIDENTIAL
2.2.2.3 Secondary Particulate Recycle and Cooling
The syngas passes from the heat recovery train to a vet particulate scrubbing system and the resulting slurry produced is pumped back to the gasifier. Thus, none of the particulate matter or scrubber water is discharged as waste streams.
The final scrubber product gas is then cooled through a series of heat exchangers before entering the hydrogen sulfide (H2S) removal process. Vater condensed from the product gas as it is cooled (sour condensate vater) is stripped of the sour gases and much of the vater recycled back to the process. Any excess vater that has been stripped (sweet condensate vater) will be discharged to the Division canal.
2.2.2.A Selectamine H2S Removal, Selectox Sulfur Recovery, and Tail Gas Incineration
The sulfur in the sour syngas is removed by the Selectamine or GAS/SPEC ST-1 acid gas removal (AGR) process, which is a process licensed from the Dov Chemical Company. The sweetened product gas is suitable as fuel for the gas turbine power generation system, and the extracted acid gas is suitable as feed to the sulfur recovery unit.
Selectox sulfur recovery process is licensed through the Ralph M. Parsons Company, and the liquid sulfur produced by the Selectox process will be sold as a by product.
The tail gas from the Selecto# unit is fed to an incinerator which oxidizes the remaining H2S to S02 and vents it to the atmosphere. Small amounts of acid gas collected from various other points in the process are also disposed through the incinerator.
2.2.2.5 Existing Gas Turbines
The clean syngas stream from the AGR is used to fire the equivalent of one existing gas turbine in the Power II facility at Dow's Louisiana Division. Two gas turbines are expected to be able to switch from natural gas to syngas as well as operate on blends of syngas and natural gas.
2.2.2.6 Emergency Flare System
The location cl the flare s-ack is in an area dedicated for that purpose. Adequate area has been left unoccupied to avoid any hazards when flaring.
DO A 111279 CONFIDENTIAL
2.2-6
2.2.2.7 Process Wastewater Treatment
The water condensed from the product gas as it is cooled is passed through a water treatment system for removal of dissolved gases, primarily H2S and NH3. Much of the condensate from the water treatment system will be recycled to the coal slurry process. Any excess water (90 - 223 gpm; 175-225 gpm for lignite and 90-140 gpm for western sub-bituminous coal) that is not recycled to the process will be discharged to the Louisiana Division canal through a permitted outfall.
The sweet condensate water will be characterized for contaminants that it may contain. If the level of contaminants are above the permitted level for discharge, the excess sweet condensate water will undergo secondary treatment for the removal of the impurities before being discharged. The secondary treatment will consist of treatment by activated sludge in the existing Louisiana Division wastewater treatment facilities.
2.2.2.8 Industrial Solid Waste Landfills
The spent catalysts which are periodically removed from the Selectox sulfur recovery unit will be landfilled. These are the primary solid wastes from the Dow Syngas Project that will be disposed of in landfills. The gasifier slag and liquid sulfur from the Selectox unit will be sold.
The spent Claus catalyst will be landfilled in the solid waste landfill permitted for the Louisiana Division of the Dow Chemical Company.
Spent Selectox catalyst is considered hazardous since it contains vanadium pentoxide, an acutely toxic chemical. It will be disposed in the hazardous waste landfill located within the Louisiana Division.
2.2.3 Process Design Changes
Operational difficulties in the secondary particulate scrubbing area of the process were essentially resolved with the addition of a secondary particulate scrubber during late June 1988. The modification significantly reduced the levels of solids in downstream equipment. Concentration of the char removed in the particulate scrubbers has been found to be lower than expected via Protoplant experience. Plans are to install a test centrifuge during second quarter 1989 to improve char concentration prior to recycle to the gasifier.
Planned modifications to the wastewater treatment system were completed during December 1988. Major equipment added included a new overheads heat exchanger and vent scrubber for the ammonia system. In addition, a spare reboiler was installed on the ammonia stripper column. Preliminary data from stack and aqueous sampling
DO A m20 confidential
2.2-7
performed after these process modifications indicate that the ammonia present in the tank vent system has been significantly reduced.
Some modifications to the reactor slurry feed system were performed to allov demonstration of bituminous coal as alternative feedstock to the gasifier. Initial indications from the coal test are that the system will operate successfully on bituminous coal.
2.3 Environmental Monitoring Plan Status
Implementation of the EMP remained on schedule vith completion of the Commissioning Phase monitoring of the commercial facilities. The Commissioning Phase Preliminary Report issued on September 29, 1988, and was reviewed at the Annual Monitoring Review Committee (MRC) Meeting on October 12, 1988. At the recommendation of the MRC, an Executive Summary to the Preliminary Report issued on January 27, 1989. The Summary further detailed the activities and findings during the Commissioning Phase, thereby finalizing the report.
Monitoring was performed at each of the monitoring locations designated in the EMP during the reporting period. With few exceptions, monitoring followed the schedule specified in the EMP. Gaseous, aqueous, solid, leak detection, health and safety, ambient and compliance monitoring have been conducted with excellent results. Monitoring through the second quarter of 1988 was reviewed and discussed at the Annual MRC Meeting. This data were used in the preparation of the first set of Comprehensive Phase Tests which occurred during fourth quarter 1988. Data from this testing phase will be presented in a future Phase Report. Current plans are to issue the Phase Report prior to the 1989 Annual MRC Meeting tentatively scheduled for mid-September 1989.
2.2-8
DO A 111281 CONFIDENTIAL
5.0 HEALTH AND SAFETY MONITORING
5.1 Annual Report
Since the Annual EMP Health and Safety Report on the Dow Syngas Project for calendar year 1988 will issue, under separate cover, during early third quarter 1989, this report will include only brief summaries of these areas, in addition to any activities associated with first quarter 1989.
The 1988 LGTI Plant Health Team Review was held on May 26, 1988. Representatives from the Safety, Industrial Hygiene and Medical Departments audited the plant with respect to health and safety performance during 1987 and reviewed plans for 1988. The main topics discussed included the plant chemistry/process, a plant tour, 1987 exposure monitoring data, 1988 monitoring plans, the education/training programs and the health surveillance program.
5.2 Safety Program
The Safety Program of the Dow Syngas Project incorporates the guidelines of the Louisiana Division with the specific needs of the LGTI facility. The program focuses on proactive identifi cation and correction of potentially hazardous situations and practices. Progress in the areas of housekeeping, participation in the plant safety program and safe completion of maintenance tasks are used as indicators of the safety performance at LGTI. During first quarter 1989, four potentially serious incidents were proactively investigated at LGTI, with follow up action implemented to prevent actual occurrence.
5.3 Industrial Hygiene Monitoring
In addition to routine industrial hygiene monitoring of both contractor and Dow personnel for hydrogen sulfide, carbon monoxide, dust and noise, monitoring for ammonia and benzene soluble organics was begun. Monitoring was performed using area, personal and portable monitors, as well as surface wipes and Draeger tubes. Monitoring results indicate that exposure to these chemicals are typically well within established exposure limits.
Data from precautionary area sampling for benzene levels were received during first quarter 1989. The samples were taken in areas with the highest potential for benzene vapor based on a review of the process. The results show all levels were less than 10 X of the Permissible Exposure Level for benzene. This confirms that LGTI is not covered under the OSHA Benzene Standard, and therefore, no health surveillance activities relating to potential benzene exposure arc requnod.
5.4 Medical Monitoring
The existing Dow Louisiana Division medical monitoring program is being utilized for monitoring the health of the employees of the commercial Syngas Project. Core examinations
DO A 111282 CONFIDENTIAL
were performed on 63 Dow and 35 contractor employees during 1988. No adverse job-related medical conditions were found. Annual medical monitoring was performed for three years to allow the development of baseline health information. Hereafter, medical monitoring will be performed every two years.
Nineteen industrial injuries occurred during the reporting period; nine involving Dow employees, and ten involving contractor employees. Eight of the injuries were classified as recordables. Recordable injuries are those injuries, which due to their severity, somewhat restrict an employee's activities, but do not result in any lost time from work.. Each of these injuries has been detailed in previous quarterly reports. The remainder of the injuries were minor in nature.
Two minor injuries occurred at the facility during first quarter 1989; both involving Dow employees. The first of the injuries was classified an OSHA recordable, and occurred while an employee was performing housekeeping duties in the process area. Uhile rolling up a utility hose in the plant for proper storage, the employee bumped his elbow on a pressure gauge located in a run of process piping. As follow-up action to prevent recurrence, the need to assess body position and review potential hazards in the work area was recommunicated to operations personnel.
The other injury resulted while a Dow employee was performing a routine shutdown of a process pump. The employee started disconnecting tubing that was still under pressure and suffered a minor thermal burn on the hand when process liquid leaked from the tubing. All personnel were retrained in the importance of utilizing line opening procedures.
00 A 111 283 confidential
8.0 MONITORING PROBLEMS/RECOMMENDATIONS FOR CHANGES
8.1 Problems Encountered
Minor problems encountered with monitoring during the reporting period were usually addressed with re-emphasis of established procedures or method modification. Off-line time resulted in some backward shift of the monitoring schedule. Nevertheless, the shift did not adversely affect the overall Commissioning Phase schedule nor the first Phase of Comprehensive Tests.
8.2 Solutions
Nothing to report.
8.3 Recommended Changes to the Environmental Monitoring Plan
A number of changes to the Environmental Monitoring Plan occurred during the reporting period. The first set of the changes was recommended at the Annual MRC meeting held in October. These modifications primarily focused on changing monitoring schedules described as twice in eight months or four times in eight months to once per quarter. In addition, monitoring schedules associated with compliance sampling were modified to match the frequencies dictated in the permits. Other changes involved the elimination of testing for oxygen and sulfur in pure sulfur, and an update of methods used for testing for metals in aqueous and solid streams. These proposed modifications were officially approved.
Another set of changes to the EMP were submitted to the MRC for comment in a letter dated November A, 1988. In particular, the changes involved trace element analyses and organic characterizations associated a number of aqueous and gaseous streams. Although these modifications have not been formally approved, MRC members recommend acceptance of the changes.
Also recommended by the MRC, is a proposed change in the EMP to allow substitution of routine supplemental monitoring with similar monitoring during demonstration runs on varying feedstocks. This modification could result in two sets of monitoring during a given quarter, with monitoring omitted during another quarter. No change in compliance or health and safety monitoring would result. This change has not been formally accepted by Treasury.
The final set of proposed changes awaiting formal acceptance were included in the Fourth Quarterly Report for 1988. These changes involve modification of EMP testing schedules to reflect testing for all parameters described in the existing water permit.
8.1-1
DO A 111284 CONFIDENTIAL