Activated Carbons and Manufactured
Gas Plants
A Presentation To The GTI
Conference, TIGG Corp.
Authored
by:
|
Michael
Hasel
PPL Service Corp.
|
Anthony Mazzoni
TIGG Corp.
|
Johyn Mahfood
Corp. Env. Solutions
|
From the early 1800’s through the
mid-1900’s gas for lighting, heating and cooking was produced from coal or oil
at manufactured gas plants (MGP). The MGP sites were built on the outskirts of
towns that have since grown. Therefore, the sites are often located in
inner city areas.
The process that was used yielded
residues that included tars, sludge, light oils, spent oxide waste and other
hydrocarbon products. Although many of these byproducts were recycled, excess
residues remained at the site. The residues contain polyaromatic
hydrocarbons (PAH) which are present in the base contaminant, which is
coal tar.
Approximately 1500 MGP sites have
been designated to be cleaned up. The clean up is triggered by regulatory
pressure, mainly state agencies, property transfers and re-development as well
as releases via ground water migration. Due to de-regulation, site
clean-up may also be triggered by sale of a utility or of a specific utility
site to other utilities.
When considering the remediation of
a MGP site, the owner desires to have few or no problems, at the lowest cost,
with the neighbors or government agencies, during the remediation operation. To
achieve this goal there are many factors that need to be considered. These
include, but are not limited to owner costs, public and government relations,
present and future liabilities and type of remediation protocol to use.
The purpose of this paper is to
discuss the pros and cons related to each of these factors when using one of
three accepted options in conjunction with the “hog and haul” method of
remediating a site. The options are the use of (1) minimal controls, (2)
extensive onsite monitoring and (3) a fabric structure with limited air
testing.
As we are all aware, the government
continues to react to public and media pressures relating to real or perceived
environmentally caused health problems. Therefore, there is the possibility
that new regulations will require more stringent guidelines for controlling
emissions during the remediation operations and minimizing the need for further
action in the future.
Regardless of the regulatory
oversight and except for the most unusual of settings most MGP sites require a
standard site investigation, risk evaluation and remediation often consisting
of soils/materials excavation. At a minimum, the normal practice is to remove
the extremely impacted (e.g. tar tanks, holders) soils for disposal/treatment.
It is these soils that have the greatest impact to the environment and the
neighborhood during a remedial action.
The complete remedial design is no
longer limited to the evaluation of what technology, and their associated
risks, to use for cleaning the site, but must also include the development of a
comprehensive public relations campaign involving the neighbors, the media and
the local government officials. Satisfying neighbor concerns is the
center of the public relations effort. Their concerns are normally
related to health, both during and after the clean-up, noise and property
values.
The health concerns during
remediation are usually related to odors and seeing personnel in moon suits.
This is an indication to them that something is bad in the air. Both of
these issues must be addressed or the public will be upset. This then
leads to more media coverage, more government scrutiny, an adverse impact on
the company’s image, and is likely to extend the time of the operation and
increase costs.
Failure to manage risks for a single
remediation could negatively impact the owner in many ways. This could
lead to extensive regulatory review, negative P.R., and possible impacts on the
stock value, applications for future permits, and future job sitting (e.g. substation,
power plants etc.). For regulated industries, it could even impact the
rate case and reduce the ability to collect all or a portion of the costs from
the ratepayer.
There are many technologies that are
used to remediate MGP sites. Some of these are bio remediation, capping and
slurry walls, stabilization, sheet piling and thermal treatment of the soil.
However, the excavation and hauling technique, commonly referred to as “hog and
haul”, is an old idea but is still a core tool and is used alone or in
conjunction with other technologies.
Whatever technology is used there
are still factors that affect the success of the overall remedial operation.
The weather, i.e. rain, snow, heat, wind and cold can cause delay in the
operation if the site is not covered. Also hours of operation could be
limited by complaints about noise.
Following is a comparison of the
three options that are used with the “hog and haul” technology:
1. Excavation with
Limited Monitoring of Air
In this option there are minimal
measurements of VOC emissions. Foam or plastic may be put down to help control
vapor emissions and reduce complaints by residents. Monitoring may include the
use of hand held PIDs.
Pros:
- This is the lowest cost approach
- Probably appropriate for rural areas and industrial
complexes
Cons:
- Work delays due to weather or uncovering unexpected
“hot spots”
- Variation in emissions could go undetected by monitor
but detected by neighbors and thus complaints
- Lawsuits due to perceived health effects
- Regulatory control when done in suburban and urban
areas
- Delays due to having to put down foam or plastic
- Extra costs due to change orders because of delays
- Public can be upset by odors and seeing moon suits
2. Excavation with Extensive Real
Time Monitoring of Air Emissions
Real time VOC monitors are installed
around the site. When the monitors detect a contaminant work activity is slowed
or stopped. Monitors provide individual gas constituents.
Pros:
- Extensive monitoring can detect fugitive emissions
- Provides legally defensive monitoring data
- Can be used in suburban and urban settings
Cons:
- Work delays due to weather or uncovering unexpected
“hot spots”
- Lawsuits due to perceived health effects
- Regulatory control when done in suburban and urban
areas
- Delays due to having to put done foam or plastic
- Extra costs due to change orders because of delays
- Public can be upset by odors and seeing moon suits
3. Excavation under Fabric Structure
and Limited Monitoring of Air
In this option a fabric structure is
erected over the most contaminated area of the site. Garage doors, large
enough to allow heavy equipment to enter the structure, along with mandoors and
lighting are installed in the structure.
The size and orientation of the
structure is site specific and must take into account the work plan and truck
traffic pattern. In addition to the structure, a well-designed air handling and
purification system must be installed to capture VOC emissions generated within
the structure and to allow workers to wear minimal personnel protection
equipment. Generally the air purification system should be sized to provide 2-5
changes per hour. Once erected and operational a fabric structure with a
properly sized air purification system enables work to proceed in most weather
conditions and prevents escape of contaminated air.
Pros:
- Not affected by weather conditions
- Organics adsorbed on activated carbon so no odors
released to atmosphere
- No visibility of operations
- Minimal visibility of personnel in moon suits
- Same cost as real time monitoring option
- Less noise
- Minimizes risk of lawsuits
- Structure can be moved to various locations on the site
- Better control of costs and schedule
- Much easier and more effect public relations
Cons:
- Presence of large visible structure
- A visible depiction of the foregoing discussion is
presented in the accompanying table. The code for interpreting the
presentation is as follows:
- Meets or exceeds objectives
- Meets objectives
- May not meet objectives
As is obvious from the chart, the
most solid black circles are shown under the structure option. The activities
that are involved with this option are discussed below.
Objective:
Determine which and then select the
operational option, when using the “hog and haul” technology, that would
satisfy the Owner/Client, Regulators and public to complete the R/A with
minimal problems.
Conclusion:
The use of a fabric structure in a
residential setting: allowed for the successful completion of the core goals
and objectives of the remedial design.
Benefits of Using a Fabric
Structure:
- A remedial plan to meet
regulatory compliance
- Balances project cost with
current and future liability controls
- Easier public and local buy-in
for successful project completion
- Better control of costs and
schedules versus other options
- No odors released to
atmosphere
- Minimizes risk of lawsuits
- Not affected by weather
conditions
For more information on this topic visit www.TIGG.com
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