PILOT POLLUTION PREVENTION PROGRAM REPORT · ACKNOWLEDGMENTS This Pilot Project was funded in part by grant NP-996188-01-0 from the U.S. Environmental Protection Agency, Region VI,

S I C 49-11 -F

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PILOT POLLUTION PREVENTION PROGRAM FOR ELECTRIC UTILITIES

FINAL REPORT

MEASUREMENTS, RESULTS AND RECOMMENDATIONS E

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Prepared for: . . . I

United. States Environmental Protection Agency ,

RegionVI' .. 1445 Ross Avenue, Shite 1200

Dallas, Texas 78703

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Prepared by: . ' \

- LOWER COLORADO RIVER AUTHORITY. ,.

P.0.~ Box 220 Austin,'Texas 78767-0220 ' ~ '

. , October 1996

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EPA Assistance Agreement No. NP-996188-01-0 LCRA Project No. lBACOOOC50018 *

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. . Joedentley I \

Pollution Prevention Coordinator . . Sr. .Environmental Coordinator.

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TABLE OF CONTENTS

ACKNOWLEDGMENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . i

. . . EXECUTIVE SUMMARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . U-iU

PILOT POLLUTION PREVENTION PROGRAM FINAL REPORT . . . . . . . . . . . . 1 . 30

1.0 Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 - 5 1.1 currentstatus . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 1.2 Baseline Waste Generation Data . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 1.3 Baseline Air Emission Data . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

2.0 Evaluation Methodology For Measuring Pollution Prevention . . . . . . . . . . . . . 6 . 10 2.1 Solid Waste Evaluation Methods . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 2.2 Air Emission Evaluation Methods . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10

3.0 Zvaluation of Pollution Prevented . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 . 24 3.1 Fayette Power Project . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 3.2 Si Gideon Power Plant . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 3.3 3.4 Dalchau Service Center . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21 3.5 General Office Complex . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21 3.6 Hydroelectric Facilities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23 3.7 Other Facilities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24

Thomas C . Ferguson Power Plant . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20

4.0 Other Pollution Prevention Program Activities . . . . . . . . . . . . . . . . . . . . . . . . 25 . 27 4.1 Pollution Prevention Program Elements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25 4.2 Management Support . . . . . . . . . . . . . . . . . . . . . . . . . . . . ' . . . . . . . . . . . . . . . . . . 26 4.3 PollutionPreventionTeams . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26 4.4 EducationofTheOrganization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27 4.5 Other Program Elements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27

Estimated Cost Savings and Financial Expenditures . . . . . . . . . . . . . . . . . . . . 28 -29 5.1 Estimated Cost Savings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .:: . . . . . . . . . . 28 5.2 Financial Expenditures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29

6.0 Recommendations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30

5.0

.

List of Tables

Table I

Table I S

Table IU

FY 1993 Solid Waste Baseline Data . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

Stack Emissions Baseline Data For LCRA Power Generating Facilities . . . . . . . . 4

1992 “Other Sources” Emission Baseline Data For LCRA Power Generating Facilities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .5

List of Figures

Figure 1 Fiscal Year 1996 Hazardous Waste Composition . . . . . . . . . . . . . . . . . . . . . . . . 8

Figure 2 Fiscal Year 1996 Class I Waste Composition . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

Figure 3 Current Hazardous Waste Generation Performance vs. Goal . . . . . . . . . . . . . . 12

Figure 4 Current Class I Waste Generation Performance vs. Goal . . . . . . . . . . . . . . . . . . 14

Figure 5 Current Air Emission Performance vs. Goal . . . . . . . . . . . . . . . . . . . . . . . . . . . 15

Figure 6 FPP Citms Solvent Reductions . . . . . . . . . . . . . . . . . . . _:_ . . . . . . . . . . . . . . . 17

Figure I SGPRagandPadReductions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19

Figure 8 DSC Paint Waste Reductions

Avvendices

Appendix A Solid Waste Data, Charts and Graphs

Appendix B Air Emission Data, Charts and Graphs

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e

ACKNOWLEDGMENTS

This Pilot Project was funded in part by grant NP-996188-01-0 from the U.S. Environmental Protection Agency, Region VI, Pollution Prevention Incentives for States Program. In-kind support was received from the Texas Natural Resource Conservation Commission Office of Pollution Prevention and Recycling and the Lyndon B. Johnson School of Public ABEiirs at The University of Texas at Austin. The project appreciated the advice, assistance and involvement of all employees at the Lower Colorado River Authority. These persons include:

Bob Barton, Joe Bentley, Joe Bricker, Jemal Brown, Gail Byler, Robert Cervenka, Clark Conely, Kim Conky, Jerry Cunningham, Ross Crysup, Dennis Daniel, Kent Dawson, Henry Eby, Randy Eden, Jean Ferrer, Mario Flores, Bob Foster, Tony Hambus, Willard Harlow, Dennis Haverlah, Evelyn Herzog, Tommy Hi@, David Hmphreys, Cassandra Jordan, Jobaid Kabiir, Barney Kneese, Marc Koch, Ken Koehler, Brett Kowald, Mike Larson, Ken Launius, Steve Leinweber, Mike Lewis, Missy Mandell, Jerry Matthews, Jeanne McConnell, Dale Meinardus, Paul Mikulin, Lupita Mireles, Allan Mitchuson, Virginia Moreno, Daniel Neiser, Marion Nichols, Jody Oliver, Raleigh ON&, Eddie Oppermann, Gary Pavalock, Kathy Payne, Dudley Piland, Jackie Ploch, Jennifer Prihoda, Tim Psencik, Robert Quintadla, Gene Richardson, Ken Riorden, Ken Ronsonette, Michael Schiller, Alfred Schmitz, Andrew Sumner, Ken Taylor, Randy Tobey, Ray Treadway, Bobby Ugiansky, Charles Urdy, Joe Wegenhoft, Dudley Wenzel, Ralph Williams, and Donald Wood.

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EXECUTIVE SUMMARY

The Lower Colorado River Authority (LCRA) has pursued the elimination of waste and conservation of namral resources since its creation by the Texas Legislature in 1934. Waste reduction is saving the LCRA and its customers money, providing a safer work place for employees, and improving the environment. The LCRAwill continue to diligently pursue pollution prevention (P2) opportunities.

On September 16, 1993, LCRA received approval for federal assistance in support of the development of a comprehensive pollution prevention program for electric utilities. The federal assistance was received from the United States Environmental Protection Agency @PA) under the Pollution Prevention Incentive For States (PPIs) 1993 Grant Program. The PPIs grant program provides matching hnds to states to support pollution prevention programs and develop state P2 programs.

The program began with the creation of a hll-time staff position for the coordination and implementation of the company pollution prevention programs.. The LCRA then prioritized its facilities and established two P2 teams, one consisting of facility employees and the other of management level staff.

Calendar year 1992 was initially used as a baseline to measure the success of the program and set waste reduction goals. From the base year, the LCRA set a goal of a 50 percent reduction in the volume of both hazardous and class I nonhazardous waste by the year 2000: Goals for the reduction of air emissions from LCRA steam electric generating facilities were not set; however, emissions reductions were measured on a pounds per net megawatt basis.

To make baseline data more representative and make waste reduction goals meaningful, the 1992 baseline data for hazardous and class I nonhazardous waste was modified to include additional wastes which were not reported in 1992 but reported in 1993, 1994 and 1995 (i.e., lead abatement wastes). The baseline adjustments involved an increase of the hazardous waste baseline volume of 78 tons (due to lead abatement) and a decrease ofthe class I nonhazardous waste baseline to 1,038 tons (removal of re-classiiied waste). The wastes were also tracked on a fiscal y& basis. The modified data reflects that the LCRA has reduced hazardous waste generation by 68 percent when compared to the new base year (FY 1993). Class I non-hazardous waste increased by approximately 1,000 tons in FY96 due to the remediation of historic oil spius. Prior to FY 1996, the LCRA had achieved more than a 40 percent reduction of Class I waste.

In FY 1996, the LCRA reported a generation of approximately 25 tons of hazardous waste and 2,065 tons of class I nonhazardous industrial solid waste, costing more than $314,786 in waste management and disposal costs. In fiscal year 1993, the LCRAgenmted an estimated 78 tons of hazardous waste and 30,820.62 tons of class I nonhazardous waste with total estimated waste management and disposal costs of $1.9 million. Cumulative cost-savings from pollution prevention activities associated with the pilot program have been conservatively estimated to be worth more than $1.4 million.

ii WMRCOWL4D3FS%RAIJIHORIN

During calendar years 1995-96, the LCRA cooperated with the Lyndon B. Johnson School of Public AfFairs at the University of Texas at Austin (UTA) to provide an independent audit of the LCRA’s pilot P2 program. The audit revealed that waste reduction through P2 was observed in all categories ofwaste and considerable cost savings could be claimed. The independent audit also indicated that theLCRA pilot program had implemented all basic elements of the pilot P2 work plan and had been successful -erring the information and raising awareness among managers and employees. The UTA audit also identified several problems the LCRA had experienced associated with the measurement, tracking, and reporting of waste reductions. Like the LCRq UTA found that although annual waste summaries, air emission inventories, and discharge monitoring reports provided good sources of data, they did not accurately measure pollution prevented. The manipulation of this data to unmask and measure source reduction and waste “ k a t i o n activities over time proved difficut and time consuming for both the LCRA and UTA.

Clearly, the LCRA has encountered some problems associated with the implementation of a pilot program for an entire industry. The LCRA’s inability to develop an accurate and detail oriented accoUnting system to measure the P2 program’s cost savings is part of the problem. Had the program been able to make more of a busiiess case, the program could have made broader gains. As an electric utility, the LCRA is favored in some respects and handicapped in others by the nature of the industry. Given its one product, the LCRA is favored by having a discrete set of processes to manage. On the other hand, as an entity which is both a public agency and a marketer of electricity, the LCRA institutional structure tends to be monolithic. This phenomena is in part suggested by the problems that were encountered during the implementation of Facility Improvement Teams. These teams were intended to be the primary agents of LCRA’s P2 efforts but were slow to take shape and were rarely implemented as planned.

Total financial expenditures for this project from October 1, 1993 through October 30,1996 total $203,869. The LCRA share of these cost total $140,202. The federal share of finds received by the LCRA under the PPIs program total $63,667.

In conclusion, the LCRA pilot P2 program successfilly implemented all elements of a pollution prevention program. The pilot program had upper management support, d&eloped a company-wide P2 policy, set meaningfd waste reduction goals, prioritized facilities, implemented Facility Improvement Teams, performed P2 assessments, identilied solutions, made recommendations, implemented projects, measured results, and transferred information to other electric utilities. The results of LCRA program and the UTA audit clearly show that significant reductions in all waste categories were achieved and that significant cost savings can be claimed.

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PILOT POLLUTION PREVENTION PROGRAM FINAL REPORT

1.0 Introduction

This final pilot pollution prevention (P2) program report for the Lower Colorado River Authority (LCRA) corporate operations meets the programmatic requirements of the United States Environmental Protection Agency (EPA) Pollution Prevention Incentives For States (PPIs) grant program. This final report documents the measurements and results of LCRA’s pilot program and also illustrates the LCRA’s commitment to protecting the environment while maintaining cost effective electric power production.

This report is the third in a series of three “final reports” prepared under the EPA grant. The first report, ‘%lIution Prevention Work Plan of the Lower Colorado River Authority,” descriies the process in which the LCRA set up the development and implementation phase of the program. The second report, “Lower Colorado River Authority Proposed Pollution Prevention Projects and Pilot Studies,” summarizes the activities and projects accomplished during the grant assistance period and the pilot program. This report, “Meusurements, Results and Reeommendations,” provides a critique of LCRA’s efforts thus far to successfully implement LCRA‘s work plan, attain goals, measure results and to exemplify LCRA’s mission statement and P2 policy. The LCRA cooperated with the Lyndon B. Johnson School of Public AfFairs at the University of Texas at Austin (UTA) to provide assistance with the final report and perform an independent audit of the LCRA’s pilot P2 program.

1.1 Current Status

On October 30,1996, the LCRA completed the pilot P2 program for electric utilities. The results of the project indicated that significant reductions in all categories of waste had been achieved through P2 and that considerable cost savings could be claimed.

During the project period (October 1, 1993 through October 30, 1996) the LCRA pollution prevention (P2) program recommended approximately 53 P2 projects for consideration. Forty-six of the recommended projects were implemented and only seven were rejected’. The implementation of the projects have resulted in a 68 percent overall reduction of hazardous waste. Despite a 67 percent decrease in class I nonhazardous waste fiom operations and maintenance (O&M) activities, an 88 percent overall increase in class I nonhazardous waste was recorded. The increase in class I nonhazardous waste

1 WWER COLDRACQ RIVER AUIHORIN

PILOT POLLUTION PREVENTION PROGRAM FTNAL REPORT

occurred due to the clean-up of several historical oil spills and two large boiler cleaning projects.

A system-wide reduction of air emissions has also been achieved-through various P2 initiatives such as heat rate improvements and amiliaty load reductions. Although LCRA's gas-fired utility plants have increased air emissions despite their P2 initiatives, the LCRA's coal-fired facility has reduced air emissions significantly. This difference is mainly the result ofthe LCRA's prioritization and more aggressive handling of P2 at the largest power producing facility. The coalifired facility produces most electricity, generates the most solid wastes, and releases the most pollutants to the atmosphere when compared to other LCRA facilities.

1.2 Baseline Waste Generation Data

Both hazardous and class I nonhazardous industrial solid waste data were initially measured and reported on a calender year basis and used 1992 as the base year. The LCRA measured, reported, and segregated wastes into either routine O&M or one-time corrective actiodabatement activities. In 1992, the LCRA only tracked and reported 22 hazardous waste streams from O&M activities. In 1993, the LCRA was required to track and report more than 100 waste streams from both O&M and one-time corrective actioq or abatement activities. The LCRA found that by using fiscal year (FY) 1993 (July 1- June 30) as the base year and then measuring, tracking, and reporting hazardous waste, the baseline data more accurately reflected the LCRA's waste generating activities.

In addition to tracking hazardous and class I nonhazardous waste on a fiscal year basis, it was also noted that the class I waste reduction goals set at the beginning of the pilot program were achieved in 1993. The LCRA started using reverse osmosis (R.O.) technology to remove dissolved solids from boiler feed waters at allpwer plants. The technology was responsible for avoiding the generation of 26,066 tons or 73 percent of the total class I nonhazardous waste that had been reported on the LCRA's 1992 annual waste summaries. In 1994, the same waste stream became re-classified and was no longer reported on annual waste summaries. Consequently, the LCRA removed the large waste stream from the baseline data. The adjusted baseline information used to compare and measure P2 from solid waste reduction activities has been provided in the Table 1.

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LOWER COWRADO RMRAWOIUTY 2


Facility ID. HYDRO

FPP

I TABLE I: FY 1993 SOLID WASTE BASELINE DATA

Hazardous Waste (tondyr) Class I Waste (tondyr)

43.01 - 2.85

7.18 122.12

DSC 4.91 306.74

TCF 0.38 77.92

GOC 17.53 12.64

SR€ 0.21 3.51

PBM 1.59 4.37 ,I

other 0.3 1 64.46

TOTAL

1.3 Baseline Air Emission Data

78.29 1095.58

Establishing 1992 baseline data and reduction goals for emissions from the combustion of fossil fuels involved the evaluation of several contributing factors. Primary factors such as gross power generation, customer demand, and peak load determine fuel requirements, flue gas sulfur dioxide removal efficiencies, and total emissions (stack and other sources). Because electric power generation is the most significant variable, baseline data for stack emissions are expressed as a ratio of pounds of pollutants released per gross megawatts generated ~bs/Mwh(g)]. The LCRA's program goal is to maintain stack emissions vs. generation ratios at or below 1992 levels for the six primary constituents of concern listed below:

Particulate Matter @M) - Sulfur Dioxide (SO3 Nitrogen Oxides (NO2 Volatile Organic Compounds (VOC)

3 LDWERCOLORADORIVERAUIHORln


Carbon Monoxide (CO) Sulfuric Acid &SO,)

In 1992, LCRA generated 11,529,453 gross megawatt hours wwh(g)] of electrical power and reported the release of approximately 46,794 tons of air pollutants from three coal- &ed units with a total capacity of approximately 1,650 Mw and four gas-fued units with approximately 1,090 Mw total capacity. Using 1992 Air Emissions Inventories and LCRA's internal Availabihty-Operahg (AVOP) Statistics Reports, ratios were established on Ibs/Mwh(g) basis for P w VOC, SO, NO,, CO and Hzso4. The constituents were evaluated to insure that the baseline ratios represented only emissions proportional to electric power production. Because one of LCRA's coal-fued units utilizes a flue gas d a on (FGD) system, an annual scrubber efEciency average was incorporated into the unit's Ib/Mwh(g) calculation (Table II).

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TABLE II: 1992 STACK EMISSION BASELINE DATA FOR LCRA POWER

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AU utility stack emissions ratios for the following years were compared to the 1992 data to reflect P2 reductions and FPP Unit 3 FGD removal efficiency.

The 1992 baseline data for the six primary constituents of concem from other emission sources (point and fugitive) were established on a tons per year (tonsly) basis. Examples of "other sources" include VOCs from painting and &el storage. The emissions from other sources are not directly related to power generation (Table III).

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PILOT POLLUTION PREVENTION PROGRAM FJNAL REPORT

TABLE m: 1992 "OTHER SOURCES" EMISSION BASELINE DATA FOR LCRA

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2.0 Evaluation Methodology For Measuring Pollution Prevention

As a practical matter, the Texas Natural Resource Conservation Commission (TNRCC) and the EPA already collect documents that can be used to evaluate the LCRA’s quantitative pollution prevention performance, such as annual waste summaries for solid waste, air emission inventories for air pollutants, and annual discharge monitoring reports for waste water. Although these reports are good sources of data, they do not provide adequate data to determine if any pollution was prevented’.

Both the LCR4 and UTA quantified the volume of solid waste reduced through pollution prevention and waste minimization activities. The analysis involved the review of annual waste summaris, actual measurements taken from LCRA’ s Environmental Management Information System (EMIS) and other LCRA intemal waste tracking documents. Copies of the intemal waste tracking documents, charts, graphs, and other supplemental information related to solid waste have been included in Appendix A.

Many problems were encountered during the data collection and manipulation process. It was discovered that solid wastes were consistently reported in various units requiring conversions. When comparing merent waste streams over time, it was necessary to be aware of regulatory changes that modified waste code numbers or reporting requirements (Le., lead acid batteries and demineralizer regeneration waste). Tracking of these wastes over time proved dficult and time consuming. In an effort to identify true pollution prevention and unmask paper reductions, the LCRA also tracked solid waste based on composition

2.1 Solid Waste Evaluation Methodologies

At the end of each year, hazardous and class I nonhazardous industrial solid waste data were first segregated into either routine O&M or one-time correctiveactiodabatement activities. This allowed the LCRA to identify weather waste generation was an annual reoccuning waste or a onetime event such as asbestos removal and lead abatement. This analysis allowed the LCRA to idenbfy reductions that had been achieved at the O&M level. Wastes were then grouped into seven general waste stream categories currently required by the TNRCC to characterize industrial solid wastes’. The following waste categories

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were used during the pilot project to determine both hazardous and class I waste categories:

LabPacks * Inorganic Liquids * OrganicLiquids * Inorganicsolids

- Inorganic Sludges organicsolids

Organic Sludges

Analysis of these waste categories over time indicated that between FY 1993 and FY 1994 organic solids and liquids made up the majority of hazardous waste generated at the LCRA The wastes were the result of several large lead-abatement and painting activities. In FY 1996, the organic solids only represented 11 percent of the total hazardous waste streams. Organic liquids and inorganic solids currently account for more than 72 percent of L C W s total hazardous waste (Figure 1). Analysis of the w e waste categories for Class I nonhazardous waste indicated that inorganic liquids made up the majority of the wastes (acid cleaning wastes, caustic wastes, and other aqueous wastes). In FY 1996, this single waste category accounted for more than 80 percent of all class I waste generated (Figure 2).

In an attempt to reduce the level of effort associated with tracking more than 200 individual waste streams, the LCRA also categorized waste according to the following major waste categories:

Cleaning Solutions Paint Waste Batteries Aqueous Waste Caustic Liquid Petroleum Contaminated Solids Solvents Lead Abatement Waste Laboratory Waste MisceU~eous Waste (i.e., lamps and unused materials)

Figure 1: Fiscal Year 1996 Hazardous Waste Composition

Organic Solids

Organic Lab Sludges Packs inorganic

7% Liauids

cn m m

- m 0 M ii .. cy Q)

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PlLOT POLLUTION PREVENTION PROGRAM FINAL REPORT

An analysis of these waste categories over the project period revealed that the primary waste streams responsible for hazardous waste generation were lead abatement waste, paint related wastes, solvents, and miscellaneous wastes. The primary waste streams responsible for class I waste generation were aqueous wastes, petroleum contaminated substances (soils), and spent petroleum products.

All information gathered for the solid waste data analysis was taken directly fiom the LCRA's EMIS, operational records, and annual waste summaries.

2.2 Air Emission Evaluation Methodologies

The most " n o n method to judge the performance of a power plant is to look at the net heat rate. Net heat rate is a good evaluator of efficiency in that it measures theamount of he1 [ i British thermal units @tu)] the plant needs to bum in order to generate one unit of electricity (Le., kilowatt hour). Thus, the lower the heat rate, the more efficient the power plant, in that it takes less he1 to produce electricity. Theanly problem with using the heat rate is that it only measures the efficiency of the boiler and does not consider efficiency losses due to auxiliary load (the energy required to run the facility).

To analyze the P2 progress , it is necessary to examine more than gross air emissions (air emissions inventories) and net heat rate. Reductions in emissions can be seen after they have been adjusted by the plants gross electrical generation and normalized to reflect a constant generation rate. This was done by dividing the number of pollutant tons by the gross amount of electricity generated (IbMwh) for each year. Ratios were then established on lbs/Mwh(g) basis for PM, VOC, SO,, NO,, CO, and &.so4. To make reductions independent of electric generation, emission data was then normalized to reflect a constant generation rate (1992 generation data as the base line for measuring reductions). The ratios that were established for each year were then simply applied to the 1992 gross generation. Spreadsheets, charts, and graphs used to track LCRA air emissions can be found in Appendix B.

10 LOWERCOLORACOIUMRAUIHORIIY


3.0 Evaluation of Pollution Prevented

Recalculation of waste generation data has provided the basis for the pilot P2 program's substantial source reductions and waste minimization results, rather -than masked paper reductions. Waste reductions were observed in all categories of waste, although there were specific incidences of increased waste generation during certain years. These trends were largely the result of one-time events and do not reflect the P2 programs effod.

In FY 1996, the LCRA generated 25.42 tons of hazardous waste company-wide. Approximately 20.43 tons of hazardous waste were the result of routine O&M activities and 5 tons were ftom onetime corrective action and/or remediation activities. Examples of corrective action activities include lead paint abatement, asbestos removal, and clean-up of the LCRA's land resources. Using FY 1993 as the baseline for comparing hazardous waste generation, a 68 percent or 52.86 ton overall reduction of hazardous waste has been achieved (Figure 3). The largest single hazardous waste reduction was achieved through the use of innovative technologies that reduced lead abatement wastes by more than 97 percent. Other measurable hazardous waste reductions included a 71 percent decrease in hazardous paint related wastes, a 34 percent reduction in laboratory wastes, and a 37 percent reduction in caustic and acid wastes.

In FY 1996, the LCRA generated a total of 2,065.23 tons of class I nonhazardous industrial solid waste. Approximately 1,743.54 tons were from routine O&M activities and 321.69 tons were f7om onetime Corrective action and/or remediation activities. Once again, using FY 1993 as the baseline for waste generation, an 89 percent increase in class I nonhazardous waste generation has been documented (Figure 4). To make reduction goals meaningfid and unmask paper reductions associated with the re-classification of the demineralizer regenerate waste, it was excluded ftom the baseline data. Ifthe waste had been included in the baseline data, the LCRA would show a 97 percent reduction in class I waste. It is also important to note that before the reclassification to a non-reportable waste, the R.O. technology reduced the d e m i " regeneration waste by 73 percent or 14,848 tons annually. It is also important to note that despite the overall increase in the generation of class I nonhazardous waste, a 67 percent decrease in the generation of waste from O&M activities were achieved.

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350

300

250

200

150

100-

50

0-

Figure 3: Current Hazardous Waste Generation Performance vs. Goal . . . . . . . . . . . . . . . . . .-.-. ____ .... . . . . ........ . . . . .. . . . ...... . . . . . -

. . ........... ......... .................. . -- /-..-

. . . . . .......... . ......... . ... . .. .......... ............... .___ - / ........

...... . . . . . - - .- -. . . . . . ... . . . . . . . . ....

. ... .... . . . . . .......... . ..... . . ....... . .... . .-. .- - .....

.... . . . . . . . ,-- . . . . . . . . .- . . . . . .

.. - ............. .- ...... . . . .. . . . . . .

Fiscal Year

PILOT POLLUTION PFU3VENTION PROGRAM F I N a REPORT

The LCR4's P2 program goal was to maintain stack emission vs. generation ratios at or below 1992 levels for six primary constituents of concern (I'M, SO,, NO,, VOC, CO and H2S04). In calendar year 1995, the L a g e n e r a t e d 13,818,206 Mwh(g) of electrical power and reported the release of approximately 50,605 tons of air pollutants &om the stack of three coal-fired units and four gas-fired units. when compared to 1992, the data indicates a 20 percent increase in electric power generation and a nine percent increase in reported stack emissions released to

the atmosphere. When the same data is n o r " l to 1992 generation rates and then measured on a Ibs/MwhCg) basis, the LCRA shows a net decrease of seven percent, avoiding the release of an additional 3,270 tons of air pollutants to the atmosphere. Improvements in &el combustion and emission measurement technology, provided by continuous emission monitors (CEMs) at LCRA's fossil fuel-hred units, are primarily responsible for the emission rate reductions (Figure 5). Primary pollutants reduced were SO2 and NO, Some reductions were also observed in PM VOCs and CO emissions.

The LCRA has targeted the majority of its P2 efforts towards the reduction SO, emissions From its coal-fued units. It is also important to note that on a IbsiMwh(g) basis, SO, emissions dropped by 9 percent despite a 4.68 percent decrease in scrubber removal efficiency. Ifthe scrubber had been operated at the 1992 operating efficiency, an additional 2 percent or 690 tons of SO, may have been removed.

Although the other two LCRA power plants analyzed in the following sections of this report have not shown progress in reducing emissions, this is not by accident. The other two plants are gas-fired and only bum oil as a secondary fuel. The natural gas is much cleaner than coal; consequently, the gas-fired facilities release sisnificantly fewer pollutants to the atmosphere. Air emission data, charts, and graphs for all LCRA operations can be found in Appendix B.

3.1 Fayette Power Project

The Fayette Power Project (FPP) is the largest LCRA facility It consists of three large coal-fired generating units and regularly produces the largest volume of hazardous waste From routine O&M activities within the LCRA In FY 1996, FPP generated a total of 10.54 tons of hazardous waste. Using FY 1993 as the baseline for comparing hazardous waste generation, a 46 7 percent or 3.36 ton increase in hazardous waste generation is

13

Figure 4: Current Class 1 Waste Generation Performance vs. Goal . . . . . ..... . . ... ....... . . . . . .. . . ....... ,.. -. ^ ....

2,500

2,000

1,500

1.000-

500-

0-

Year Woes not represent demin. waste

Figure 5: Current Air Emissions Performance vs. Goals

1MXK)

0

-npproxhnaed s

Total LCRA Air Emissions

9

- D TCF

/SSGP

47000

46wo

45ooo

39oM)

38ooo

37000

Normalized Total LCRA Air Emissions

86.WA' n

1992 1% 1994 1995

PlLOT POLLUTION PREVENTION PROGRAM FINAL REPORT

reflected despite the implementation of many P2 initiatives. The primary reasons for the increase in hazardous waste generation when compared to the base year are regulatory changes and an increase in the total number of wastes reported. FPP has prevented the generation of an additional 15 tons of hazardous waste since 1994 through source reduction and waste " i z a t i o n . Employee training and contractor awareness reduced the generation of hazardous metal cleaning wastes by 94 percent or 9.84 tons. Nonhazardous citrus solvents that became hazardous due to the introduction of heavy metals were reduced by 82 percent or 2.89 tons by using closed loop ultrdtration. The remaining waste was then .pinimbed by using a solvent distillation unit (Figure 6).

FPP has made signiscant progress in reducing class I nonhazardous waste. In FY 1996, FPP generated a total of 65.72 tons of class I waste. Approximately 43.55 tons were eom routine O&M activities and 22.17 tons were &om one-time corrective action andor remdation activities. Once again, using FY 1993 as the baseline for waste generation, a 46 percent decrease has been documented. The reductions were primarily the result of projects aimed at reducing wastes from routine O&M activities. The primary class I wastes reduced included sewage treatment sludge, miscellanwus paint lab packs, and spill material contaminated with hydraulic oils.

Total air pollutant emissions for FPP have dropped over the years due primarily to a decrease in production rates of SO, and NQ . In calendar year 1995, FPP generated 10,854,276 Mwh(g) of electrical power and reported the release of approximately 46,862 tons of air pollutants from the stacks of three coal-&ed units. When compared to 1992,the data indicates a 15 percent increase in electric power generation and a five percent increase in reported stack emissions released to the atmosphere. When the same data is normalized to reflect 1992 generation rates and measured on a lbs/Mwh(g) basis, FPP shows a net decrease ofnine percent, avoiding 4,203 tons of air pollutants released to the atmosphere. The primary reasons for these reductions can be attributed to heat rate improvements, improved measurement technology, operator training, and several energy ef6ciency projects targeted at reducing station load. It should be noted that these reductions were achieved despite a 4.68 percent decrease in scrubber efficiency. In 1992, FPP operated its scrubber at 89.68 percent and in 1995 it was operated at 85 percent.

16

PILOT POLLUTION PREVENTION PROGRAM FINAL. REPORT

3.2 Sim Gideon Power Plant

The Sin Gideon Power Plant (SGP) is the second largest LCRA facility. It operates three gas-fired units. Fuel oil is only burned during emergencies such as natural gas curtailments. SGP is one ofLCRA's cleaner burning power plants because it relies on natural gas .as the primary source of fuel and it is used to produce electricity when necessary rather than on a continual basis.

In FY 1996, SGP generated a total of 1.63 tons of hazardous waste. Using FY93 as the baseline for comparing hhzardous waste generation, a 44 percent or 1.27 ton decrease in hazardous waste generation was achieved. The primary projects responsible for hazardous waste reductions included aerosol reduction and solvent filtration.

In FY 1996, SGP generated a total of 1,881.74 tons of class I waste. Approximately 201.40 tons were ftom routine O&M activities and 1680.40 tons were fiom non-routine activities and one-time corrective action and/or remediation activities. Although SGP does not show any overall reductions of class I nonhazardous waste since the base year, significant reductions of waste generation from O&M activities have been achieved. Unfortunately, they are masked by a large boiler cleaning project that generated 375 tons of waste in FY 1996. Progress was made reducing oil contaminated rags and pads (Figure

7).

white the efficiency of SGP's boilers (net heat rate) has improved since 1992, the volume of pollutants generated fiom the facility have actually increased. The increase is not significant on a corporate basis, as the amount of electricity and corresponding pollutant volume is relatively small when compared to FF'P. In calendar year 1995, SGP generated 1,926,457 Mwh(g) of electrical power and reported the release of approximately 2617.8 tons of air pollutants &om the stacks ofthree gas-fired units. When compared to 1992, the data indicates a 95 percent increase in electric power generation and a 217 percent increase in reported stack emissions released to the atmosphere. When the same data is normalized to 1992 generation rates and measured on a Ibs/Mwh(g) basis, SGP shows a 63 percent increase in emissions, releasing an additional 5 17 tons of air pollutants to the atmosphere. The primary reasons for these increases may be attributed to heat rate improvements. They have improved dramatically over the last few years, meaning the facility is more efficient

18 LOWERCOWRAWRIVERAUIHORIN

0 m n cd

n. c3 fn .. IC

0 0 0 0 0 0 0 0 0 0 0 0 0 In 0 tn 0 In 0 0

m N N 7 - tn 0 m


today than it was three years ago. Unfortunately, the decrease in the units’ net heat rate may have increased NO, emissions. The relationship between NO, emissions and heat rate isnon-hear and currently being investigated. The reported increase may also be the result of technology improvements in measuring pollutants. A CEM was installed on each unit in 1994. In 1992 the emissions were estimated using questionable emission factors.

3.3 Thomas C. Ferguson Power Plant

The Thomas C. FergusonPower Plant (TCF) is the third largest LCRA facility. It consists of one large gas-fied generating unit and has the potential to produce a signiscant volume of waste from routine O&M activities. TCF’s P2 efforts have successfully reduced substantial volumes of both hazardous and class I waste, especially where lead abatements are concerned. In FY 1996, TCF generated a total of 2.94 tons of hazardous waste. Using N 1993 as the baseline for comparing hiuardous waste generation, a 95 percent or 57.49 ton decrease in hazardous waste generation was achieved. The primary projects responsible for hazardous waste reductions include the use of nonhazardous solvents and innovative lead abatement technologies. TCF also generated a total of 2.94 tons of class I waste from routine O&M activities in FY 1996. When compared to the base year, TCF shows a 96 percent or 74.98 ton reduction in class I waste. Progress has been made reducing all categories ofwaste and it should be noted that most waste generation at TCF was driven by large asbestos and lead abatement projects. The use of innovative lead abatement technologies in F Y 1996 prevented the generation of approximately 28 tons of hazardous blast media.

TCF is similar to SGP in that it relies mainly on natural gas and therefore, does not produce large volumes of air pollutants. On the other hand, the facility is a one-unit generating facility used less frequently than SGP to produce electricity for the LCRA. While TCF only produces a small volume of air pollutants, they also have increased over the last few years despite several heat rate improvements. Like SGP, the increase is not significant on a corporate basis, as the amount of electricity and corresponding pollutant volume is relatively small when compared to FPP. In calendar year 1995, TCF generated 1,037,473 Mwh(g) of electrical power and reported the release of approximately 1,124.8 tons of air pollutants from the stack of the single gas-iired unit. When compared to 1992, the data indicates a 9 percent decrease in electric power generation and a 37 percent increase in

5

20 LOWER COWRAW RIVER AUIHOWN


reported stack emissions released to the atmosphere. When the same data is normalized to 1992 generation rates and measured on a lbs/Mwh(g) basis, TCF shows a 51 percent (414 ton) increase in stack emissions. The primary reasons for these increases may be similar to that of SGP.

3.4 Dalchau Service Center

The Dalchau Service Center (DSC) is LCRA’s transmission line and fleet vehicle maintenance facility. The implementation of the P2 pilot program at DSC has resulted in waste generation decreases for both hazardous and class I nonhazardous wastes.

In FY 1996, DSC generated a total of 4.43 tons of hazardous waste. Compared to the FY 1993 base year, a 10 percent or 0.48 ton decrease in hazardous waste generation was achieved. Hazardous paint and paint related wastes were reduced the most (Figure 8). They were reduced by using some nonhazardous solvents, high volume low pressure (HVLP) spray paint guns, water-based paints and “closed loop” ultrafiltration systems on solvent parts washers. The DSC also generated a total of 110.77 tons of class I waste in Fy 1996. Approximately 70.40 tons were generated from routine O&M activities and an additional 40.36 tons were generated fiomthe remdation of petroleum contaminated soils &om historical spills at several substations. When compared to the base year, DSC shows a 64 percent or 195.97 ton reduction in class I waste. Reductions fiom routine O&M activities when compared to the base year reflect more than a 73 percent or 200 ton reduction.

Although this facility does not report any air emissions, the facility has taken voluntary steps to reduce the amount of VOC’s released to the atmosphere &om solvent parts washing, painting, and abrasive blasting. Wormation from these preventive activities were not measurable.

3.5 General Office Complex

The General Office Complex (GOC) consists of LCRA’s corporate headquarters, a print shop, hydroelectric facility, carpentry shop, and environmental laboratory. The

21

Figure 8: DSC Paint Waste Reduction

, . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

9,000

8,000

7,000.

6,000

5,000

4,000

3,000

2,000

1,000

0

/ ..................... .......... . . . . . . . . .... ,

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ............ ..............................

. . . . . . . . . . . . . . . . . . . . . . . . . ............................ .... ..,." .

.......

................................. ............................. ..__,_ ......... . . . . . . . . . . . . . . . . . . . . . . . . .

............ ,. . . . . . . . . . . . . . . . . . . . . . . . . . . . ... .

. . . . . . . . . . . . . . . . . . ., . l_._____̂_-l.. .............. ......__._,.._________ . . . . .

.......................... ............I.......... ................ ~-

1.992 1993 1994 1995 1996*

Year 'represenls nrsl6 monlhs only

i I 1 I I ' I


implementation of the P2 pilot program at GOC has reduced both hazardous and class I nonhazardous wastes.

In FY 1996, GOC generated a total of 2.47 tons of hazardous waste fiom O&M activities. Compared to the FY 1993 base year, an 86 percent or 15.06 ton overall decrease in hazardous waste generation was achieved. The primary projects responsible for hazardous waste reductions include the use of innovative lead abatement technologies and the distillation and reuse of solvents. The GOC print shop has also taken measures to use altemative solvents. The GOC also generated a total of 0.44 tons of class I waste in FY 1996. When compared to the base year GOC shows a 97 percent or 12.2 ton reduction in class I waste. This facility does not report any air emissions.

3.6 Hydroelectric Facilities

The LCRA's Hydroelectric (Hydro) operations consists of Six dams located along the Cobrado River between Lake Buchanan and Lake Austin, Texas. The implementation of the P2 pilot program initially focused great attention on Hydro as they were the largest hazardous waste generating division within the LCRA. In FY 1993, Hydro accounted for more than 54 percent of all hazardous waste generation within the LCRA. Since the implementation of the pilot P2 program at the LCRA, Hydro has achieved signiscant reductions in both hazardous and class I nonhazardous wastes.

In FY 1996, Hydro generated a total of 5.05 tons of hazardous waste, 5 tons were &om lead abatement activities, and 0.05 tons were &om routine O&M activities. Compared to the FY 1993 base year, an 88 percent (37.96 ton) overall decrease in hazardous waste generation was achieved. The primary projects responsible for hazardous waste reductions involved the use of paint contract revisions, innovative lead-abatement technologies, and moisture-cured urethane coatings. Hydro also generated a total of 227 tons of class I waste in FY 1996. When compared to the base year, Hydro also achieved a 23 percent or 0.65 ton reduction in class I waste. This facility also does not report any air emissions.

23


3.7 Other LCRA Facilities

Other LCRA operations consists of a rail-car maintenance facility (SRF), an underground gas storage fkcility (HGG) and various land resources located within the LCRA's service area. These facilities historically generated v q little waste compared to the rest of LCRA and consequently, were given a low priority. Despite the low priority, these facilities have experienced some decreases in hazardous and class I nonhazardous waste generation.

InFY 1996, the other facilities generated a total of 0.37 tons ofhazardous waste. When compared to the Ey 1993 base year, a 53 percent (0.42 ton) decrease in hazardous waste generation was achieved. The primary P2 projects responsible for hazardous waste reductions were related to employee training and the use of an aerosol depressurizing device at SRF. When compared to the base year, the other facilities also achieved a 98 percent or 71 ton reduction in class I waste. Most of these reductions were related to the closure of an LCRA owned lignite mine and not P2 activities.

24

PILOT POLLUTION PREVENTION PROGRAM FLNAL REPORT

4.0 Other Pollution Prevention Program Activities

This section of the report discusses the results of the LCRA’s efforts to implement a pilot P2 program and the ability to follow a work plan strategy that was developed at the be-g of the pilot project with the assistance of the TNRCC’s Office of Pollution Prevention and Recycling4. The progress towards these goals were also evaluated independently by UTA. The results of the UTA evaluation have been prepared in a separate report and submitted independently to the EPA.

4.1 Pollution Prevention Program Elements

Information gathered by LCRA and verified by an independent survey performed by UTA indicated that the LCRA has implemented the following eight elements of a P2 program’:

- ManagementSuppolt * SelectaTeam

Select a Team Leader Educate Orgauktion BrainstonnIdeas EvaluateIdeas JmplementIdeas ContinuetheProcess

These elements were implemented on both the corporate a d facility level. The P2 program was implemented at the facilities in an order pre-determined by a prioritization matrix that identified facilities with the greatest impact to the environment and opportunities for cost savings. The pilot program was then implemented at these facilities first. This phased approach was evident when UTA performed a survey to evaluate the progress made at each facility. Among other things, the survey reflected that management support and waste reduction goals at the DSC facility were not well established. On the other hand, the survey results indicated that employees at FPP had management support and well established facility specific waste reduction goals.

25


4.2 Management Support

Information gathered by E R A and an independent survey performed by the UTA indicated that the LCRA had strong upper management support in-that company-wide waste reduction goals and a policy on P2 had been developed and implemented. However, support from management at the facility level was selective, indicating the need for stronger corporate commitment.

4.3 Pollution Prevention Tqms

The pilot P2 program at the LCRA began with the creation of a full-time staff position for the coordination and implementation of all P2 activities. The LCRA then established two P2 teams. The l j r t team implemented was at the corporate level and consisted of managers ftom the various LCRA departments. The team was known as the Core Pollution Prevention Group (CPPG) and was responsible for identifying and eliminating internal barriers to P2. The CPPG was also responsible for overseeing progress and encouraging facility management participation. The CPPG met on a quarterly or as needed basis and received updates on progress fiom the P2 coordinator. The CPPG was effective in that it proclaimed management support for the P2 program; however, it’s abiity to Convince mid-level management of the benefits associated with the pilot program were not as favorable.

The other P2 teams, known as Facility Improvement Teams (FITS) were formed &om stafF and management at each facility. The FITS were charged with the responsibility of identifjing all w&te generating activities and developing ideas for process improvement, operational efficiency and waste reduction. The FITS were intended to be the primary agents of LCRA’s .P2 efforts. The teams were slow to take shape and were rarely implemented as intended’. The ability of FITS to meet on a regular basis and complete assignments were the biggest factors that affected the progress of the entire pilot P2 project. The UTA survey reported that the largest LCRA facility (FPP) had been successfuk however, employees at smaller facilities reported the inabiity to find time to attend FIT meetings. It was noted by the smaller facilities (SGP) that there were diminishing returns on investment. Jnstead of usig a FIT, SGP management chose to give


its environmental staff the additional responsibility of developing P2 ideas for implementation.

4.4 Education of the Organization

The P2 pilot program fust educated members of P2 teams at both the corporate and facility level through workshops and a P2 training course that was developed intemdy with the assistance of the TNRCC's Office of Pollution Prevention and Recycling. Once trained, FITS were further educated by facility P2 assessments. The idormation gained *om the P2 assessments were then transferred to the CPPG, facility management, and the rest of the facility. The independent survey conducted by UTA found that the P2 program had been generally successful in raising awareness among employees of the need to reduce pollution. The survey also revealed that most FlTs had an understanding of the benefits and the processes involved with P2 activities at individual facilities.

4.5 Other Program Elements

The LCRA had good success identifying and evaluating opportunities that would result in waste reductions and signifcant cost savings. These opportunities were identitied by LCRA employees, transferred from other industries or provided by the TNRCC Office of Pollution Prevention and Recycling's site assistance program. The LCRA implemented projects that required little investment fist. These projects were then followed by P2 projects that required significant investment. AU P2 projects wefe prioritized at the facility level and some were pilot tested before being implemented. A total of 46 projects out of 53 were actually implemented during the pilot project'.

27 WWER COWRADO RNERAWUORIIY


5.0 Estimated Cost Savings and Financial Expenditures

This section of the report summarizes cost savings and financial expenditures associated with the management ofthis project through October 30,1996. Although considerable cost savings can be claimed, the LCRA clearly experienced some diflidw measuring tracking, and reporting cost savings associated with the pilot P2 program. The LCRA was unable to develop an accurate and detailed accounting system that would track and measure the effects of P2 activities that were implemented during the P2 project.

5.1 Estimated Cost Savings

All cost savings associated with waste reductions were estimated with the use of an average cost multiplier that reflected the disposal and waste management cost for that particular waste stream category in a given year. The changes in costs were compared to the base year to reflect savings. Cumulative savings were calculated by subtracting the estimated disposal costs &om the baseline cost multiplied by the number of years being evaluated. In addition to the cost savings associated with waste reductions, certain projects that were used to highlight successes used total cost accounting techniques to capture additional cost savings from reduced labor and materials.

Total savings from the pilot P2 project have been estimated to exceed $1.4 million. In FY 1996, t h e m spent an estimated $314,786 on hazardous and class I waste management and laboratory analysis. Approximately $107,712 was spent an managing and disposing of hazardous waste and the remaining amount was spent on managing class I wastes. In FY 1993, the LCRA spent an estimated $363,060 in hazardous waste management and an additional $417,743 in class I waste management (does not include an estimated $1.1 million in demineralizer waste management costs). Using FY 1993 as the baseline for determining waste management cost, the LCRA has avoided an estimated $1,189,057 waste management and analytical costs. An additional $200,000 was saved by using an innovative lead abatement technology at the Wirtz Dam painting project.

28


5.2 Financial Expenditures

The total expenditures for the pilot project between October 1, 1993 and October 30, 1996, were $203,869. The EPA share received from the LCRA at the time of this report totals $63,667. It is expected that an additional $14,822 will be received ftom EPA upon receipt of a final financial report. The project was under budget by approximately $28,841.

29

PILOT POLLUTION PREVENTION PROGRAM FINAL m P O R T

6.0 Recommendations

The LCRA recognizes a need to make specific changes to its P2 program to make it sustainable and achieve additional reductions. The foUowing recommendations will be made to the CPPG and LCRA management:

Storage and retrieval ofwaste data is a weakness that needs to be improved. The current EMIS used by the LCRA requires extensive effort by individuals who are tasked with gathering, interpreting, and reporting the data. The availability and use of this data is Critical to the evaluation of any P2 program. For this reason, it is recommended that the LCRA take steps to streamline and revamp its EMIS data storage system.

A recommendation has been made to evaluate and develop a system of cost accounting. Wahout such a tool, it is hard to track actual cost savings fiom P2 activities. Although the LCRA has started to use activity based management, it is too soon to tell if it will provide any usekl information associated with determining cost savings.

As the impIementation of FITS at LCRA facilities had limited success, LCRA management must work harder to encourage employee involvement and move away fiom a top down management approach. To help stimulate employee involvement, it has been recommended that LCRA management explore new ways to support the program.

30 WWERCOWRhDo RlVER ALrmOwly


NOTES

1 The Lower Colorado River Authority, “Proposed Pollution Prevention Projects and Pilot Studies.” Austin, Texas, 1996.

The University of Texas at Austin, “An Evaluation of Pollution Prevention at the Lower Colorado River Authority.” Austin, Texas, 1996.

2

The Texas Natural Resource Conservation Commission, “Industrial Solid Waste, Self- Classification.” Austin, Texas, 1993.

3

The Lower Colorado River Authority, “Pollution Prevention Work plan of the Lower Colorado River Authority.” Austin, Texas, 1995.

4

The Texas Natural Resource Conservation Commission, “Permanent Pollution Prevention Program.” Austin, Texas, 1994.

5

LOWER COLORADO RMRAVIHOWrY


APPENDIX A

WWERCOLDRADORNERAWHORJIY

160

140

120

100

80

60

40

20

0

Original Hazardous Waste Generation Performance vs Goal . . . . . . . . . . . . . . . . . . . . . . . . . . . ....... -~ . . ....

.. . . . . . . . . . . . . . . . . . .

. . . . .

........

~ - - - . .

Year , --: ........ . . . . . . . . . . . . . . . . . .......... ', Base Line Waste Streams Additional Waste Streams]

............. ........... ........... .

'represents first 6 months only

~ I I

35,000

30,000

25,000

20,000

15,000

10,000

5,000

0

/ ...I... Original ........ Class . 1 .I---- Waste . . . . . . . . Generation . . Performance ......I .___I ... vs. ... Goal .. ...................

. . . . . . . . . . . . . . . . . . . . . . . . . . . . .... .................. ......... . ."

............ . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. ........

..... ... . ........

............................ 15,414 -.

.......... . . . . . . .. . ... . . . .L . . .

.....I____._ . ... ...... .... .............

I I I

1992 1993 1994 1995" 1996 1997 1998 1999 2000

Year

"represents first 6 months only

11/13/96

FPP Hazardous Waste

1C

14

12

10

Generation (tons) 6

6

4

2 .

0-

, . .. ...,

Fiscal Years

FPP Class 1 Waste

.I.-..--_-.__._._-. _I___

-_I__-̂ .. . _.I' i

14C

120

100

80 Generation (tons)

a,

40

20-

0- PI 1993 FY 1994 FY 1995

Fiscal Years FY 1996

SGP Hazardous Waste

Generation

FY 1993 FY 1994 FY 1995

Fiscal Years PI 1996

SGP Class I Waste

Generation (tons)

PI 1993 FY 1994 FY 1995

Fiscal Years FY 1996

0.5

0.f

0.i

0.6

Generation (tons) 0.5

0.4

0.3

0.2

0.1

0

TCF Hazardous Waste

FY 1993 FY 1994 FY 1995 FY 1996

fiscal Years

TCF Class I Waste

FY 1993 FY 1994 FY 1995 FY 1996

Fiscal Years

Generation (tons) 34

I I

! 14

1

21 !

DSC Hazardous Waste

j

0 1

F d Years

DSC Class 1 Waste

Generation (tons)

FY 1994 N 1995 PI 1996 N 1993

Fiscal Years

Generation (ton

z

2i

15

10

5

FY 1994 FY 1995 N 1996 FY 1993

Fseal Years

GOC Class 1 Waste

Generation (tons)

FY 1- N 1995 PI 1996 FY 1993

Fiscal Years

0.4

0.35

0.3

0.25

Generation (tons) 0.2

0.15.

0.1.

0.05-

0-

FY 1994 FY 1995 FY 1996 FY 1993

Fiscal Years

SRM Class 1 Waste

3.51

i 31

I 2.54

Generation (tons)

1 . S i

i ‘3 0.5 j

Fiscal Years

HYDRO Hazardous Waste

Generation (tons)

FY 1994 N 1995

Fiscal Years

FY 1996

HYDRO Class 1 Waste

Gf ration (ton!

FY 1993 FY 1994 FY 1995 FY 1996

Fiscal Years

I 7.18 P I 1.77 C I 4.91 K I 2.14 U I 1.59

I nll.

11.12 14.01 10.M I I 3.356 46.74% 6.46 5.91 1.63 I -0.141 .7.97% 4.29 5.26 4.43 I 4.w .9.85% 267 291 247 I 0.326 15.23% 0.10 o m 0.00 I -1.690 -100.00% n *L1 n M n -7 I ".~- I

0.00 . 0.00 0.00 0.00 I P 1.13 1.13 0.00 0.00 I -1.125 -100%

0.00 0.00 0.00 0.00 0 . m C 15.39 17.68 0.29 0.00 I -15.390 -100% ~

1 0.00 0.00 0.00 0.00 0.m I "- I "- n- "- . ^ _ _ _ .

(i I 0.n I (1.27 I u.m I 0.00 Imr I 0.75 I 1.50 I 1.34 0.05 F I 0.38 I . 0.28 0.43 I 0.95 IOI I 0.00 I 0.00 I 0.00 0.00 * I 1920 I 26.95 I 29.96 I 20A3

LuuwlulllDousmAIEclMm*m

5 I 0.00 I 0.00 I 0.00 I 0.00 I I I I I 0 . m I lros I 42.226 I 58.12 I 16.95 I 5.00 I I I I -37.265 I -88% - I nl). I .- "- *.."

I I I I 4.270 I I I I -0.705

I I I I 0.m I 0.574 lW.92%

I I I 1229 6- WIblE TRIamG ClIAnl

I ".W I ".W I ".W I 0.00 I I I I I o.Oo0 I I I w.0) I n.01 I 17.71 I 5.00 I I I I I 41575 I -70%

I .".W I 3Y.W I IWW I S".W I I I I 0.00 I 0% 1 I SuQ.382.W I $200.175.00 I $176.431.00 I $105.879.32 1 I I I I -W.502.681 46%

luuJpolD WAslEmECnvE

I v.- , Y . W Y.W ".W I I ".W I I 641.25 I 641.25 I 0.00 I 0.00 I I I I I 1641.251 I -100% I 0.00 I 0.00 I 0.00 0.00 I 0.00 I I 8.772.30 I 10.077.60 I 1M.U I 0.00 I I I I I @,772.301 I -100ib

I I 0.00 I 0.00 I 0.W I 0.W I 0.00 I I "Y I ^Y ^Y ^Y . __. . I 0.00 I 0.00 I 0.00 I 0.00 I I I I I 0.00 I

~

.oI I 24.M8.20 I 33,1228.40 I 6.110.55 I 1.833.17 I I 122.255.041 I -92% If I 176.70 I 615.60 I 28259 I 0.00 I I I I I 1176.701 1 -100%

I 78.29 I 1W.S6 I e7.66 I 25.42 I I I I I 152861 I %a% cmt I $363,oM) I S2446B I $182.931 I $107.712 1 I I . IU .XIoJS I UVYQJ

. .. . .

Hazardous Lab Wastes

..... ~ . - . - .- ". ... -.- . . _. ,. ,

Generation (pounds)

FY1994 FY1995 FYI996 FYI 993

Fiscal Years

Hazardous Cleaning Solutions

,r- .-.---..~~-.------.-.---.-----...-.I__ ~ _._.._.I__,_._._._.,.___I. ., .

Generation (pounds)

FYI994 FYI995 FYI996 FY1993

Fiscal Years

Hazardous Caustic &Acid Wastes

..I.-x--..̂ ._ I ~ _,.__...___I___

Generation (pounds)

FYI994 FY1995 FY1996 FYI993

Fiscal Years

Hazardous Batteries

.................. ...... ... ........ ......... I I-I 1 , .

Generation (pounds)

FYI 995 FYI996 FY1933

I Fiscal Years

~.

Hazardous Petroleum Cont. Solids

. -- ... ^ _ _ ll_l_l.._._.l__, ..... ...... ./ : . . .

1% Generation ~ D O U ~ ~ S )

looC

500

0

.. ,

FY1994 FYI995 F Y I 9 9 6 FYI933

Fiscal Years

Hazardous Lead Abatement Wastes

,’ : .I .

Generation (pounds)

FYI994 FY1995 FYI“ FY1993

Fiscal Years

Hazardous Misc. Wastes

Generation (pounds)

FYlS93 F Y l W FY1995

Fiscal Years

I

Generation

Hazardous Aqueous Wastes

F-1 Years

Hazardous Paint and Paint Related Wastes

Fiscal Years

Hazardous Solvents

Fiscal Years

Hazardous Lab Packs

Generation (pounds)

Fiscal Year

Hazardous Inorganic Liquids

Generation (pounds)

Fiscal Years

Hazardous Organic Liquids

e----

0

Fiscal Years

I

Hazardous Inorganic Solids

Generation (pounds)

Fiscal Years

Hazardous Organic Solids

Generation (pounds)

F H Years

Hazardous Organic Sludges

~ - . -..--l.l_-__ ~ 1

Generation (pounds)

FYI996

Fiscal Years

r

Class I Paint and Paint Related Wastes

Generation (pounds)

Fiscal Years

Class I Aqueous Wastes

Gemeration (pounds)

FYI994 FYI595 FYI933 FYI993

F W Years

Class 1 Cleaning Solutions

--- -. --.. ,.,' i

Generation (pounds)

FYI994 FYI595 FYI996 Fiscal Years

c

Generation (pounds)

Class 1 Petroleum Cont. Substances

i

FY1994 FYI995 FY1996 FYI933

Fiscal Ywrs

Class 1 Batteries

Generation (pounds)

FYI994 FYI995 FYI996 F Y l W

F i i Years

Class 1 Caustic Liquids

Generation (pounds)

FY1993 FY1944 FYI995 FY1996

Fiscal Years

I

Class I Asbestos

Generation

Fiscal Years

Class 1 PCB Contaminated Substances

F s e s l Years

Class 1 Petroleum Product Wastes

Fiscal Years

E

Class 1 Misc. Wastes

Generation (pounds)

FYI994 FYlS9S

Fseal Years

Class 1 Organic Solids

Fiscal Years

Class 1 Inorganic Sludges

11__1114_-.___._̂ ____ ,,,q-----

FYI933 FY1994 FYl995 FY1996 Fiscal Years

Class 1 Organic Sludges

Generation(p0und.s) ~MXMO

FY1W FYI996

Fiscal Years

Class 1 Inorganic Liquids

Generation (pounds)

~

FYI993 FYI994 FYI995 FYI996

A d Years

Class 1 Organic Liquids

r-

Generation (pounds)

FYI993 FYI994 FY1995 FYI996

Fiscal Years

Class 1 Inorganic Solids

i

FYI994 FYI995

Fixd l Years

M* I 0.15 I 2.19 I 4.00 I 1.95 I I I I I 1.81 I F I 58.43 8.91 I 6.82 2.94 I I I -57.49 I -95.13% 1 I S66.42 1 679.97 I SlS.21 1 321.69 I I I 1 645.73 I 4 6 . W

L e R L Q I M l ~ A C m y wIJIETR*cI.KicwRT

. .


APPENDIX B

. .

Utility Stack Emissions vs. Power Generation

4.60 T - OI 4.50 - - f 4.40; z 4.30- a s 4.20

a 9" 3.90- E I w 3.80 7

3.70 ! 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 XMO

Year

4.50 7 - - m 4.001 I f 3.50T

5 3.w T

s 2.50+ = 2.001 - 0 1.50- a a 1 . w -

I id

S

g 0.50- 0.00 :

1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 XMO

Year

0.35

0.34-

3 0.33 - z

- s u) 0.30 + E 0 .291

c

a

S p 0.32 -

0.31 L . . -

a

tu

- __ i 0.28 -

1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2WO

Year

Utility Stack Emissions vs. Power Generation e4

0.0360 I

0.0335 - 0.0330 f 0.0325 - 0.0320 4

--- 8 8 VOC -_

1990 1991 1592 L 1993 1994 1995 1996 1997 1998 1999 2ooo

Year

,a - 025 -

Year

1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 xxx)

Year .

LCRA SOX Emissions

25wo

24000

1992 1993 1994 1995

1992 PouerGmwatm 11.529.453 ~ n m Years 'npwOXnnaled scrubber Emiellcy

LCRA NOx Emissions

.., .. . . .......... ... . ..

-

1992 1993 1994

Years 15%

Normalized LCRA NOx Emission

-- .-.l_..-l.-.-̂ -__..-_l_ .... . .

1992

'22 Povnr Generation 1 I.529.453 WM?

1993 1994

Years

LCRA CO Emissions

............. ................ .. .ll._._,__.___...ll. ~ ..... ........... . . ,I .

I i i fq !

i O&

1995

Normalized LCRA CO Emissions

1992 1993 1994

Years

LCRA VOC Emissions

..- . ... ~ -

300

250

200

150

100

50.

0- 1992 1993 1994 1995

Years

m m SGP

'OFPP

Normalized LCRA VOC Emissions

I ,..-. ....................................... ~

_.. .

200

195

190

185

180.

175- 1992 1993 1994

Years

Q POW Generathn 71529.453 Mvw,

,mSGP QFPP L

1992 1993 1994 1995

YearS

1992 1993 1994 1995

Years I992 P o w Generatmn 11,529.453 m

LCRA PM Emissions

. -

1300

1280

1260

1 240

1220

1m-

1180.

llso.

/oTcF JDSGP , f3 FPP -

E

LCRA H2S04 Emissions

192 PowerGenwalDn 11.529.453 &%

1M)

50

0. 1992 1993 1994

YearS

Normalized LCRA H2S04 Emissions

,I ,... ;

--.- I_ ~

0 1 932 1993 1994

Years

1995

OSGP 1 , D FPP -

I I I I I I I I I I I

-9% -0.89 -9% -4202.P"

9.15 8.63 120.45 40575.57 *

I I I I I I I I I GCD I I I I I I 1 - s

1424 1641.1 2617.6 217% 1793.2 63% 1.048 63% 517.6666

Tons 824.6 lbslmwh 1.67 1.889 2.105 2.718

987687 824.6 932.8704 1039.541 1342.267 *

9% 4182 TOTALS 46422.7 56202.6 49518.3 50604.7 TOTALS' 46422.7 43678.7 44943.95 43151.85 -7% -3270.85

I I I I I I I I I I I I'Normalized at 1992 geneartion rates (gross Mwh) I I I I I I I I I I I

I

TCF SGP FPP ISubtotal

TCF SGP FPP

[Subtotal

TCF SGP FPP tunit 1 + 2)

1,138,390 1,092,606 16.9 0.030 0.031 14.4 0.029 0.030

0.267 0.282 9,403,376 8,874,048 1253.2 1 1,529,453 10 ,911,248 1284.5 0.223 0.235

voc 1,138,390 1,092,606 7.9 0.014 0.01 4

987,687 944,594 6.7 0.014 0.014 9,403,376 8,874,048 183.3 0.039 0.041

11,529,453 10 ,911248 197.9 0.034 0.036

987,687 944,594

sox 1,139,390 1,092,606 3.4

987,687 944,594 2.9 6,928,779 6,553,999 24232.0

FPP (unit 3: 89.68%FGD) /Subtotal

0.006 0.006 6.995

2.474.597 2,320,049 1183.0 0.956 1.020 11,529,453 1 0,911248 25421.3 4.41 0 4.660

NOx

0.006 0.006 7.395

FPP

[Subtatal

~~~

9,403,376 8,874,048 16043.0 3.412 3.616 L 1 1.529. 10,911,2 2.98 . 6

co

TCF SGP

TC F SGP FPP Eubtotal

1 1,138,390 1,092,606 566.5 987.687 944,594 608.3

1.1 38,390 1,092,606 224.9 0.395 0.412 987.687 944,594 192.3 0.389 0.407

9,403,376 8,874,048 1573.0 0.335 0.355 11,529,453 10.91 1,248 1990.2 0.345 0.365

ff2S04

0.995 . 1.232 1.037 1.288

TCF SGP

1,138,390 1,092,606 0.0 I 987,687 944,594 0.0 0.000 0.000

0.000 0.000

I

-..,. ~,~... . . ........, ., .. , ... ....... .......... PM

TCF 1,050,396 1,008,463 15.8 -6.675 0.030 1.144 0.031 1.112

TCF 1,050,396 1,008,463 2.222 ' . 0.015 2.190 SGP 1,507,494 1,444,049 10.7 58.395 0.01 4 3.778 0.015 3.61 1

TCF 1,050,396 1,008,463 3.2 -6.873 0.006 0.928 0.006 0.897 SGP 1 507 494 1 444 049 4.5 57.431 0.006 3.146 0.006 2.980 FPP funk 1 +2)

TCF SGP FPP pubtotal

TCF SGP FPP Subtotal Grand Total

TCF SGP

1,050,396 1,008,463 21 0.4 -6.427 0.401 1.412 0.417 1.381 1,507,494 1,444,049 302.1 57.098 0.401 2.928 0.41 8 2.763

12,119,480 11,500,410 2024.0 28.671 0.334 -0.165 0.352 -0.71 3 , , 13,952,922 2536.5 27.453 0.346 0.117 0.364 -0.331

1,050,396 1,008,463 0.0 0.000 0.000 0.000 0.000 0.000 1,507,494 1,444,049 0.0 0.000 0.000 o.ooo* 0.000 0.000

14,677,370 13 ,952,922 359.0 15.345 0.049 -9.393 0.05 1 -9.800

H2S04

12.1 19.480 11,500,410 359.0 15.345 0.059 -10.505 0.062 -10.996

56202.7 21.067

1 1,050,396 1,008,463 550.8 -2.770 1.049 5.376 1.092 5.343 1,507,494 1,444,049 1084.0 78.202 1.438 16.755 1.501 16.567

FPP 12,119,480 11,500,410 20314.0 26.622 3.352 -1.755 3.533 -2.295 ,952.922 21948 .a 27.477 2.991 0.137 3.146 -0.31 2

co

I

TCF SGP FPP ISubtotal

TCF SGP

.. ....... .... .,.. PM

1.393.617 1,343,196 21.2 24.926 0.030 2.047 0.031 1.620

10,235,442 9,726,018 1328.2 5.828 0.259 -2.775 0.273 -3.442 1,559,225 1,494,830 23.1 60.278 0.030 1.528 0.031 1.281

13,188,284 12 ,564,044 1370.5 6.690 0.206 -6.729 ' 0.218 -7.345 voc

1,393,617 1,343,196 10.0 26.429 0.01 4 3.275 0.01 5 2.842 I 1,559,225 1,494,830 10.9 . 61.218 0.014 2.123 0.015 1 .A75 FPP (Subtotal

10,235,442 9,726,018 198.9 8.506 0.039 -0.315 0.041 -0.999 13,188,284 12 ,564.044 219.7 11.011 0.033 2.952 0.035 -3.592

sox TCF 1,393,617 1,343,196 4.2 24.779 0.006 1.927 0.006 1.500 SGP 1,559,225 1,494,830 4.6 60.069 0.008 1.396 0.006 1.149 FPP (unit 1 + 2)

TCF 1,393,617 1,343.1 96 SGP

TCF SGP

0.000 0.000 0.000 TCF SGP

TCF SGP FPP

(Subtotal

. ............. .... .............. PM

I 1,926,457 1,837,760 28.7 99.563 0.030 2.31 5 0.031 2.574 1,037,473 996,745 16.3 -3.771 0.031 5.590 0.033 5.484

10,854,276 10,323,471 1395.0 11.319 0.257 -3.561 0.270 -4.310

voc ; ,818.20 ,1573 .1 . 8 ' 0.219 -7. 33

TCF SGP

[subtotal

TCF SGP FPP (unit 1 f 2)

FPP

1,037,473 996,745 7.7 -2.637 0.01 5 6.834 0.01 5 6.727 1,926,457 1,837.760 13.5 100.828 0.01 4 2.984 0.01 5 3.224

13,818,206 13 ,157,976 233.6 18.050 0.034 -1.503 0.036 -2.107 10,854,276 10,323,471 212.4 15.899 0.039 0.406 0.041 -0.374

sox 1,037,473 996,745 3.3 -3.885 0.006 5.464 0.007 5.359 1.926.457 1,837,760 5.8 101.913 0.006 3.520 0.006 3.782 7,509,610 7,163,045 25871.4 6.765 6.890 -1.492 7.224 -2.31 2

FPP (unit 3: 85 %FGD) ISubtotal

TCF 70.515 1.766 70.344 SGP

6.005 0.436 5.899 2.147 0.417 2.405

TCF 0.000 0.000 0.000 SGP 1,926,457 1 B37.760 0.0 0.000 n nnn' n nnn n nnn

- 3,344,666 3,160,426 1764.5 49.155 1.055 10.355 1.117 9.494 13,818,206 13,157,976 27645.0 8.747 4.001 * -9.265 4.202 -9.821

NOx

-.--- -."-- . ._.

FPP I 10,85.4,276 10,323,171 472.2 51.730 0.087 31.448 0.091 30.427

Grand Total I 50fi05 1 9 nnq (Subtotal I 13 ,818,206 13,157,976 472.2 51.730 0.068 26.599 0.072 25.822

I I

I

Documents

PILOT POLLUTION PREVENTION PROGRAM REPORT · ACKNOWLEDGMENTS This Pilot Project was funded in part by grant NP-996188-01-0 from the U.S. Environmental Protection Agency, Region VI,