EPA-450/3-74-070
DECEMBER 1974
IMPLEMENTATION PLAN REVIEW
FOR
PUERTO RICO
AS REQUIRED
BY
THE ENERGY SUPPLY
AND
ENVIRONMENTAL COORDINATION ACT
U. S. ENVIRONMENTAL PROTECTION AGENCY
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EPA-450/3-7A-070
IMPLEMENTATION PLAN REVIEW
FOR
PUERTO RICO
AS REQUIRED BY THE ENERGY SUPPLY AND ENVIRONMENTAL COORDINATION ACT
PREPARED BY THE FOLLOWING TASK FORCE:
U. S. Environmental Protection Agency, Recn'on II
26 Federal Plaza
New York, New York 10007
Environmental Services of TRH, Inc.
800 Foil in Lane, SE, Vienna, Virginia 22180
(Contract 68-02-1385)
U. S. Environmental Protection Agency
Office of Air and i-Jaste Management
Office of Air Quality Planning and Standards
Research Trianqle Park, Nortii Carolina 27711
December 1974
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PUERTO RICO
ENERGY SUPPLY AND ENVIRONMENTAL COORDINATION ACT
(SECTION IV - STATE IMPLEMENTATION PLAN REVIEW)
Table of Contents Page
1 .0 EXECUTIVE SUMMARY 1
2.0 IMPLEMENTATION PLAN REVIEW AND CURRENT AIR QUALITY 7
2.1 Summary 7
2.2 Current Air Quality Status of Puerto Rico 8
2.2.1 Definition of Air Quality Control Regions ... 8
2.2.2 Air Quality Standards 8
2.2.3 Air Quality Monitoring 8
2.2.4 Emissions of Sulfur Dioxide and Particulates. . 11
2.2.5 Particulate and S02 Regulations 11
2.2.6 Control Strategy Assessments 11
2.3 General Review of the Current Implementation Plan. . . 12
2.4 Special Considerations 13
3.0 AIR QUALITY CONTROL REGION ASSESSMENTS 15
3.1 Assessment Criteria 15
3.1.1 The Regional Evaluation 15
3.1.2 Power Plant Evaluation 16
3.1.3 Major Industrial and Commercial
Point Source Evaluation 16
3.1.4 Area Source Evaluation 16
3.1.5 Fuels Analysis 17
3.2 Puerto Rico Air Quality Control Region 17
3.2.1 Regional Assessment 17
3.2.2 Power Plant Assessment 17
3.2.3 Other Major Combustion Sources Assessment ... 19
3.2.4 Area Source Assessment 19
3.2.5 Fuels Assessment 20
m
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Table of Contents (Continued)
Page
4.0 REFERENCES 21
APPENDIX A - IMPLEMENTATION PLAN BACKGROUND 23
APPENDIX B - REGIONAL AIR QUALITY ASSESSMENT 33
APPENDIX C - POWER PLANT ASSESSMENT 35
APPENDIX D - INDUSTRIAL/COMMERCIAL/INSTITUTIONAL SOURCE
ASSESSMENT 39
APPENDIX E - AREA SOURCE ASSESSMENT 41
APPENDIX F - FUEL USE ASSESSMENT 43
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1.0 EXECUTIVE SUMMARY
The enclosed report is the U.S. Environmental Protection Agency's (EPA)
response to Section IV of the Energy Supply and Environmental Coordination
Act of 1^74 (ESECA). Section IV requires EPA to review each State Implemen-
tation Fian (SIP) to determine if revisions can be made to control regulations
for stationary fuel combustion sources without interfering with the attain-
ment and maintenance of the National Ambient Air Quality Standards (NAAQS).
In addition to requiring that EPA report to the State on whether control
regulations might be revised, ESECA provides that EPA must approve or dis-
approve any revised regulations relating to fuel burning stationary sources
within three months after they are submitted to EPA by the States. The
States n>dy, as in the Clean Air Act of 1970, initiate State Implementation
Plan revisions; ESECA does not, however, require States to change any existing
plan.
Cor-gress has intended that this report provide the State with informa-
tion on excessively restrictive control regulations. The intent of ESECA
is that SIP's, wherever possible, be revised in the interest of conserving
low sulfur fuels or converting sources which burn oil or natural gas to
coal. EPA's objective in carrying out the SIP reviews, therefore, has been
to try to establish if emissions from combustion sources may be increased.
Where an indication can be found that emissions from certain fuel burning
sources can be increased and still attain and maintain NAAQS, it may be
plausible that fuel resource allocations can be altered for "clean fuel
savings" in a manner consistent with both environmental and national energy
needs.
In many respects, the ESECA SIP reviews parallels EPA's policy on clean
fuels. The Clean Fuels Policy has consisted of reviewing implementation plans
with regards to saving low sulfur fuels and, where the primary sulfur dioxide
air quality standards were not exceeded, to encourage States to either defer
compliance regulations or to revise the SO? emission regulations. The States
have also been asked to discourage large scale shifts from coal to oil where
this could be done without jeopardizing the attainment and maintenance of the
NAAQS.
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To date, EPA's fuels policy has addressed only those States with the
largest clean fuels saving potential. Several of these States have or are
currently in the process of revising SC>2 regulations. These States are
generally in the Eastern half of the United States. ESECA, however, extends
the analysis of potentially over-restrictive regulations to all 55 States
and territories. In addition, the current reviews address the attainment
and maintenance of all the National Ambient Air Quality Standards.
There are, in general, three predominant reasons for the existence of
overly restrictive emission limitations within the State Implementation
Plans. These are (1) The use of the example region approach in developing
State-wide air quality control strategies; (2) the existence of State Air
Quality Standards which are more stringent than NAAQS; and (3) the "hot spots"
in only part of an Air Quality Control Region (AQCR) which have been used
as the basis for controlling the entire region. Since each of these situa-
tions effect many State plans and in some instances conflict with current
national energy concerns, a review of the State Implementation Plans is a
logical follow-up to EPA's initial appraisal of the SIP's conducted in 1972.
At that time SIP's were approved by EPA if they demonstrated the attainment
of NAAQS or more stringent state air quality standards. Also, at that time
an acceptable method for formulating control strategies was the use of an
example region for demonstrating the attainment of the standards.
The example region concept permitted a State to identify the most
polluted air quality control region (AQCR) and adopt control regulations
which would be adequate to attain the NAAQS in that region. In using an
example region, it was assumed that NAAQS would be attained in the other
AQCR's of the State if the control regulations were applied to similar sources.
The problem with the use of an example region is that it can result in exces-
sive controls, especially in the utilization of clean fuels, for areas of the
State where sources would not otherwise contribute to NAAQS violations. For
instance, a control strategy based on a particular region or source can result
in a regulation requiring 1 percent sulfur oil to be burned state-wide where
the use of 3 percent sulfur coal would be adequate to attain NAAQS in some
locations.
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stationary fuel combustion sources constitute the greatest source of S0£
emission and are a major source of TSP emissions.
Part of each State's review was organized to provide an analysis of
the S02 and TSP emission tolerances within each of the various AQCR's. The
regional emission tolerance estimate is, in many cases, EPA's only measure
of the "over-cleaning" accomplished by a SIP. The tolerance assessments
have been combined in Appendix B with other regional air quality "indicators"
in an attempt to provide an evaluation of a region's candidacy for changing
emission limitation regulations. In conjunction with the regional analysis,
a summary of the State's fuel combustion sources (power plants, industrial
sources, and area sources) has been carried out in Appendices C, D, and E.
Puerto Rico's State Implementation Plan has been reviewed for the most
prevalent causes of over-restrictive emissions limiting regulations. The
major findings of the review are as follows:
FORJOo. THE REVIEW INDICATES THAT A POTENTIAL EXISTS FOR REVISING
CURRENT FUEL SULFUR CONTENT REGULATIONS.
FOR PARTICULATES, THE REVIEW INDICATES THAT LITTLE POTENTIAL EXISTS
FOR REVISING CURRENT EMISSION LIMITING REGULATIONS.
The supportive findings of the SIP review are as follows:
The Commonwealth of Puerto Rico has no air quality standard which is
more stringent than any National Ambient Air Quality Standard. Puerto
Rico has not utilized the example region approach since it has only
one AQCR.
Most of Puerto Rico's S02 emissions emanate from major point sources
such as power plants. Puerto Rico is in the process of revising its
sulfur-in-fuel-regulations using a source-by-source diffusion modeling
analysis to determine the optimum sulfur content of fuel which will
attain NAAQS locally. An approach such as modeling individual sources,
complemented with local monitoring, is desirable for protecting the
environment and is also consistent with the intent of Section IV of
ESECA.
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The increased emissions of man-made participates would only aggravate
the existing high concentrations of TSP throughout the island as indi-
cated by reported violations of NAAQS and proposed designations of air
quality maintenance areas. Therefore, little possibility currently
exists for revising the emission limiting regulations for particulates
wHuout jeopardizing the attainment of NAAQS.
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2.0 STATE IMPLEMENTATION PLAN REVIEW
2.1 SUMMARY
A revision of fuel combustion source emissions regulations will depend
on many factors. For example:
t Does the State have air quality standards which are more stringent
than NAAQS?
Does the State have emission limitation regulations for control of
(1) power plants, (2) industrial sources, (3) area sources?
Did the State use an example region approach for demonstrating the
attainment of NAAQS or_ more stringent State standards?
Has the State not initiated action to modify combustion source
emission regulations for fuel savings; i.e., under the Clean Fuels
Poli cy?
Are there no proposed Air Quality Maintenance Areas?
Are there indications of a sufficient number of monitoring sites
within a region?
Is there an expected 1975 attainment data for NAAQS?
Based on (1973) air quality data, are there no reported violations
of NAAQS?
Based on (1973) air quality data, are there indications of a toler-
ance for increasing emissions?
Are the total emissions from stationary fuel combustion sources
proportionally lower than those of other sources?
Do modeling results for specific fuel combustion sources show a
potential for a regulation revision?
t Is there a significant clean fuels savings potential in the region?
The following portion of this report is directed at answering these
questions. An AQCR's potential for revising regulations increases when
there are affirmative responses to the above.
The initial part of the SIP review report, Section 2 and Appendix A,
was organized to provide the background and current situation information
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for the State Implementation Plan. Section 3 and the remaining Appendices
provide an AQCR analysis which helps establish the overall potential for
revising regulations. Emission tolerance estimates have been combined in
Appendix B with other regional air quality "indicators" in an attempt to
provide an evaluation of a region's candidacy for revising emission limiting
regulations. In conjunction with the regional analysis, a characterization
of the State's fuel combustion sources (power plants, industrial sources,
and area sources) has been carried out in Appendices C, D, E.
Based on an overall evaluation of EPA's current information, AQCR's
have been classified as good, marginal, or poor candidates for regulation
revisions. Table 2-1 summarizes the State Implementation Plan Review. The
remaining portion of the report supports this summary with explanations.
2.2 CURRENT AIR QUALITY STATUS OF PUERTO RICO
2.2.1 Definition of Air Quality Control Regions
The entire Commonwealth of Puerto Rico comprises one Air Quality
Control Region (No. 244). As illustrated in Figure 1, it includes the islands
of Puerto Rico, Vieques, Culebra, and the islands surrounding each. Other
information pertaining to the AQCR is presented in the Appendix. The priority
classifications for TSP, S02 and NOX and the counties proposed as Air Quality
Maintenance Areas are given in Table A-l. These data are discussed in more
detail in Section 3.0.
2.2.2 Air Quality Standards
The Federal ambient air quality standards and the Puerto Rico standards
are identical for TSP, S02 and NOX as given in Table A-2.
2.2.3 Air Quality Monitoring
1973 Air quality data, the most currently available for Puerto Rico,
for TSP and S02 are given in Tables A-3 and A-4, respectively. In brief,
these data indicate the following;
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o
Cj
§
I
I
01
Figure 1 Air Quality Control Region in Commonwealth of Puerto Rico
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t As of 1973, Puerto Rico had five monitoring stations reporting
for participates, three violations of both the primary and secon-
dary air quality standards, a priority IA classification for
particulates and required approximately a 72 percent reduction
in particulate emissions to attain the secondary standard.
As of 1973, Puerto Rico had five 24-hr Bubbler monitoring stations
and no continuous monitoring stations for S02. No violations
were reported; however, the AQCR has a Priority IA classification
for S02.
The air quality monitoring network for both TSP and SOo is inad-
equate according to population and AQCR Priority classification
criteria.
2.2.4 Emissions of Sulfur Dioxide and Particulates
The contribution of fuel combustion sources in Puerto Rico to the
total emissions in the AQCR are summarized in Table A-5 for both particu-
lates and sulfur dioxide. Tables A-6 and A-7 provide a categorization in
terms of combustion source type, for example, electricity generation,
industrial-commercial-institutional, and area. The tables tend to indicate;
Fuel combustion sources account for approximately 68 percent of
the AQCR S02 emissions and 35 percent of the particulate emissions.
Fuel combustion sources other than electricity generation contri-
bute approximately 30 percent of the total AQCR particulate
emissions.
t
Electricity generation is the major source of SC>2 emissions con-
tributing approximately 51 percent of the total AQCR S02 emissions,
2.2.5 Particulate and S02 Regulations^
Puerto Rico regulations for control of particulates and S02 from fuel-
burning sources are based on a particulate emission limitation and fuel sulfur
content regulations summarized in Tables A-8 and A-9, respectively. The regu-
lations are discussed in more detail in Section 2.3.
2.2.6 Control Strategy Assessments
Tables A-10 and A-ll, the control strategy assessments for particulates
and S02, respectively, were developed primarily as inputs to the assessments
of Appendix B, which are discussed in Section 3.0. Basically, the tables
represent attempts to examine the following:
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(1) Are the allowable emissions projections made in the original
SIP in reasonable agreement with such estimates based on more
recent data?
(2) Does a tolerance for an emission increase exist within an AQCR?
Table A-10 indicates that there is no tolerance for an increase in partial-
late emissions using current data and Table A-ll indicates the same status
for S02. The detailed assessment of an AQCR's potential for revising com-
bustion regulations which considers many other factors are presented in
Section 3.0.
2.3 GENERAL REVIEW OF CURRENT IMPLEMENTATION PLAN
There are three possible reasons for the existence of overly restrictive
emission limitations in a control strategy.
t "the example region" - as noted in the executive summary, the regu-
lations for one AQCR can be utilized for another AQCR, where a less
restrictive strategy would be adequate.
t "conservative ambient standards" - ambient standards which are lower
than the NAAQS can be promulgated.
"hot spots" - an inordinately high pollutant level in part of an
AQCR can be used as the basis for a region-wide emission rollback
via the proportional approach.
The Puerto Rico Implementation Plan utilizes neither the example region
approach, since there is only one AQCR, nor conservative ambient standards,
since they have adopted the national standards. However, the possibility
exists of basing region-wide emission reductions on high pollutant levels in
parts of the AQCR. A more detailed discussion of the plan is given below:
The Puerto Rico SIP contained control strategies and regulations which
were adequate to attain the national primary and secondary standards for
particulate matter and sulfur oxides on the island.
The Commonwealth regulations for the control of particulate matter
include controls for visible emissions, fugitive dust, incineration, fuel
burning equipment and process industries. The visible emission regulation
12
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limits the emission of visible air pollutants to Ringelmann No. 1 or 20 per-
cent opacity. Participate matter emissions from incinerators are limited to
0.20 1b. of participate matter per 100 pounds of refuse charged. Incinerators
having a capacity of less than 50 tons of refuse per day are allowed to emit
0.40 pound of particulate matter per 100 pounds of refuse charged. All fuel-
burning equipment, using solid fuel, have a particulate matter limitation
of 0.3 lb/10^ Btu of heat input. The Commonwealth's regulation for control
of particulate matter from process sources requires at least 99.9% control.
In addition to limitations on the sulfur content of fuels (1.0%, 0.5%
for critical areas) the Commonwealth limits the emission of hydrogen sulfide
to 10 gr/scf of gas and has an emission limitation of 6.5 Ibs/ton of ^$04
produced from sulfuric acid plants and requires control of sulfur recovery
plants and sulfite pulp mills.
The Commonwealth is in the process of revising its sulfur in fuel regu-
lation. The revised regulation requires a source-by-source diffusional
analysis to determine the applicable sulfur content for each source. The
allowable sulfur content, up to 3.1 percent, will be determined by ensuring
that the contribution of the source itself, in conjunction with the contri-
butions from all other sources, will not exceed 80 percent of the applicable
short-term air quality standard. The 20 percent safety factor designed to
ensure that the standards are protected is based upon the uncertainties
inherent in the modeling.
2.4 SPECIAL CONSIDERATIONS
The visibility of political jurisdictions was found to be a special
problem in this analysis. The delineation between municipalities, counties
and undefined geographical regions was sometimes unclear.
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3.0 AIR QUALITY CONTROL REGION ASSESSMENTS
The purpose of this section is to evaluate the available information
for the Commonwealth of Puerto Rico and determine the feasibility of revi-
sions to the SIP which would result in clean fuel conservation. The first
subsection provides explanations of the methods used in making the regional
assessments. Subsection 3.2 presents the results of the application of the
criteria for the Puerto Rico AQCR.
3.1 THE ASSESSMENT CRITERIA
In determining the potential of the AQCR for emission standard relaxa-
tion, a set of five evaluation criteria has been established:
The Regional Evaluation,
Power Plant Evaluation,
Other Major Fuel-Burning Point Source Evaluation,
t Area Source Evaluation, and
Fuel Use Assessment.
The following paragraphs provide explanations of the use of these
criteria.
3.1.1 The Regional Evaluation
This evaluation is based on a review of regional air quality data,
various regional or subregional categorizations (e.g., priority classifica-
tions or proposed air quality maintenance area (AQMA) designations), and
other information available from EPA. The evaluation must be made for each
pollutant separately and is made on the basis of seven regional indicators:
(1) current air quality violations; (2) expected NAAQS attainment dates;
(3) proposed Air Quality Maintenance Area (AQMA) designations; (4) total
emissions; (5) portion of emissions from fuel combustion sources in Puerto
Rico; (6) regional tolerance for emission increase; and (7) pollutant pri-
ority classification. Tables 8-1 and B-2 tabulate these indicators for each
AQCR for TSP and S02> respectively.
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3.1.2 Power Plant Evaluation
The evaluation of power plants was based upon modeling results con-
tained in the proposed revisions to the Puerto Rico sulfur content regula-
tions. PI ant-by-plant diffusion modeling was done for sources with a design
capacity equal to or greater than 8 million Btu/hr, which included five power
plants. Four are contained in Table C-l, and the fifth will be a new plant.
The allowable sulfur content for each plant contained in the proposed revi-
sions was that sulfur content which would not cause a local violation of an
NAAQS. Table C-2 contains a summary of the power plant S02 emission reduc-
tions under the existing and under the modified 1975 sulfur content regulations,
3.1.3 Major Industrial and Commercial Point Source Evaluation
The evaluation of major industrial and commercial point sources was
carried out according to two scenarios. First, for particulates, since no
modeling data were available for TSP, the analysis was restricted to an esti-
mate of the emissions reduction resulting from the compliance of these sources
with the existing 1975 Puerto Rico emission regulation for solid fuel combus-
tion. These results are given in Table D-l. Second, for sulfur dioxide,
modeling results were available for some sources, and analysis similar to
that carried out for power plants was performed. For these sources, estimates
of emission reductions resulting from both compliance with existing 1975
sulfur content regulations and proposed modified regulations were calculated.
The analysis for sources, for which no modeling results were available, was
restricted to an estimate of the emissions reduction resulting from the com-
pliance with existing 1975 sulfur content regulations. These results are
shown in Table D-2.
3.1.4 Area Source Evaluation
Area source emissions data were available for the AQCR from the
National Emissions Data System (NEDS) summary report. In addition, the
Office of Air Quality Planning and Standards has county summaries. Table
E-l indicates the types of fuel burned by fuel combustion area sources, the
sulfur content and emissions.
16
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As shown in Table C-l, existing sulfur content regulations would
require all power plants to burn either 1.0 or 0.5 percent sulfur fuel,
depending upon their location in non-critical or critical areas (See Table
A-9). The allowable sulfur content for five power plants, also shown in
Table C-l, is based on modeling each plant. Modeling results indicated
that two of the power plants could in 1975 increase the sulfur content
of their fuel. The two plants were :
(1) Puerto Rico Water Authority
Palo Seco Plant, Catano (% S .5->2.5)
(2) Puerto Rico Water Authority
San Juan Plant, San Juan (% S .5-H.5)
Table C-2 indicates the potential S02 emission reductions possible under the
existing 1975 regulations and under the modified regulations. The impact
of existing and modified regulations on AQCR-wide air quality is investigated
by comparing the 1975 emission reductions from Table C-2 with the emission
reduction necessary to meet standards. Existing regulations provide an ade-
quate reduction in power plant emissions alone to meet NAAQS for SOp. The
Puerto Rico AQCR requires an SOp emission reduction of 100,500 tons/yr.
Existing regulations would result in an SOp reduction of 100, 500 tons/yr
from power plants alone. Modified regulations would result in an S02
emission reduction of 39,223 tons/yr from power plants.
It should be rioted that the power plant at Daguao had its allowable
sulfur content reduced under the modified regulations, but it is a small
plant and the impact on regional emissions will be less significant.
As noted previously, data on the Aquirre power plant, is not. included
in Tables C-l or C-2, Supplemental data on the Aquirre power plant is con-
tained in Table C-3. Upon completion in 1974, the Aquirre plant will have a
capacity of approximately 900 MW, the largest in Puerto Rico. The modeled
allowable sulfur content and the proposed regulation for the new plant is 3.1
percent which will mean a considerable increase in AQCR S00 emissions. It will
also mean a clean fuel saving over the situation which would have existed
under the present 1975 regulation allowing the plant to burn 1.0 percent
sulfur oil.
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In summary, the burning of higher sulfur fuel will result in a lesser
AQCR emission reduction for S02 and a potential saving in low-sulfur oil.
Since major point sources were modeled to determine the optimal fuel sulfur
content, it is also necessary that these conversions be monitored to see if,
in fact, air quality standards will be achieved and maintained. Such an
approach would be consistent with Section IV of ESECA.
3.2.3 Other Major Combustion Sources Assessment (Appendix D)
Data on emissions, fuel use and emission reductions for major non-
utility combustion point sources are summarized in Tables D-l and D-2. As
of 1973, these sources accounted for 30 percent and 9 percent of the total
AQCR particulate and S02 emissions, respectively.
Since no modeling data were available for particulates, Table D-l
indicates for the 10 major non-utility sources for particulates, the emission
reductions associated with compliance with the 1975 existing particulate emis-
sion regulation (.3 lb/106 Btu of heat input). The regulation would reduce
the present particulate emissions by 14,382 tons/yr.
Little potential exists for clean fuel saving here because 9 of the
10 sources are burning bagasse, a solid fuel by-product of sugar refining
which is probably readily available on the island. This may, in fact, be
considered an existing clean fuel saving.
As indicated in Table D-2, analysis similar to that used in the power
plant assessment was performed for the six major non-utility combustion sources
for S02 emissions. The existing 1975 sulfur content regulations and the modi-
fied regulations would reduce S02 emissions by 9,773 and 2,375 tons/yr, respec-
tively. Small savings in low sulfur fuel oil may accrue from increases in
allowable sulfur content. However, as was noted in the power plant assessment,
these emission increases should be monitored closely.
3.2.4 Area Source Assessment (Appendix E)
Area fuel combustion sources contribute two percent and nine percent
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to total AQCR particulate and S02 emissions, respectively. As indicated in
Table E-l, distillate oil, residual oil and natural gas are the only fuels
used by fuel combustion area sources. The sulfur content of the distillate
oil burned by these sources is 1%; the sulfur content of residual oil is 2.5%,
which is the sulfur content limit under the proposed 1975 regulations. It
is unlikely that these sources could convert from oil or gas to coal and that
sulfur content increases could result in a significant amount of clean fuel
saving.
3.2.5 Fuels Assessment (Appendix F)
The purpose of this section is to examine the potential for clean
fuel savings based on the previous analyses and actual fuel consumption with-
in an AQCR. If current fuel use indicates low consumption, little benefit
would be derived from relaxing the existing regulations. This is not the case
in Puerto Rico. Table F-l summarizes fuel use indicating that residual and
distillate oil, natural gas and bagasse are the major fuels burned on the
island. The salient features of the table are the amounts of bagasse and
coal-burned on the island. The conversion of oil burning plants to coal might
well be ruled out on the basis of the TSP problem in Puerto Rico but also
because no coal is burned on the island anyway. Instead, bagasse, a solid
residue remaining after sugar cane has been crushed, is burned by most of the
major point sources other than power plants. Conversion from oil to bagasse
would probably be ruled out also because of the TSP problem and the heating
efficiency of bagasse which is considerably less than oil. The burning of
bagasse may be considered an existing clean fuel saving.
The potential for clean fuel saving in Puerto Rico lies in the saving
of low sulfur oil. Table F-l provides no indication of this, however. Modeling
results show that three major power plants and four major point sources could
burn higher sulfur oil without violating NAAQS locally as discussed in Sections
3.2.2 and 3.2.3. Table F-l is also believed to be out-dated and the fuel use
data in Tables C-l and D-l to be more current.
As noted previously, the proposed revisions of Puerto Rico's sulfur
content regulations will result in increases in AQCR S02 emissions which must
be monitored closely to ensure attainment and maintenance of NAAQS.
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4.0 REFERENCES
1. "1972 National Emissions Report," Report No. EPA - 450/2-74-012 U S
Environmental Protection Agency, June 1974. '
2' Ass1dat1oi?C?9}§.Plant Factors/1972>" 23^d ^ition, National Coal
3' -E1ectrical World Directory of Electric Utilities. 81st edition
Mcuraw Hill, inc., New York, N.Y., 1972. - i^eumon,
4-
Retn'eva1 of ^rometn'c Data) computer printouts
7-
8. "Stationary Source Fuel Summary Report," National Emission Data
EnvTronmental Protection Agency, 23 September 1974
9* AtShe'ric '^"^^5 t0 the Regulat1°n for the «>« of
10. "Air Quality Data - 1972 Annual Statistics," Publication No EPA-450
U.S. Environmental Protection Agency, March 1974. '
21
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APPENDIX A
IMPLEMENTATION PLAN BACKGROUND
TABLE A-1 PUERTO RICO AIR POLLUTION CONTROL AREAS
Priority
Classification
Air Quality
Control Region
Puerto Rico
I A classification
predominantly from
Federal
Number
244
based on
a single
Parti-
culatesb
S0ya NO,,
IA IA III
measured or estimated air quality
point source.
Pop.c
1970
(Mill)
2.76
levels
Pop.
Square Density
Miles (Pop./sq.mi )
3435 805
reflecting emissions
Proposed AQMA Desiqnations6
(11 ) Ponce, San Juan,
Guayanilla, Penuelas,
Caguas, Mayaguez,
Laries-Utuado-Adjuntas ,
Aguadilla, Arecibo-
Barceloneto, Guayamo,
Yabucoa
MJv Counties NOv
(10) Ponce, San 0
Juan,
Guanica,
Dorado,
Guayanillo-
Penuelas,
Laries-Utuado-
Adjuntas,
Aguadilla,
Arecibo,
A Guayamo, Yabucoa
Federal Register, August, 1974 SMSA's showing potential for NAAQS violations due to growth.
C1970 Pop.
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TABLE A-2 PUERTO RICO AMBIENT AIR QUALITY STANDARDS
All concentrati
Total Suspended Participate
Annual 24-Hour
Federal Primary
(Nov. 1972)
Secondary
Puerto Rico
(May 30, 1974)
75(G)
60(6)
60(G)
260a
150a
150a
ans in ugms/nr3
Sulfur Oxides f
Annual 24-Hour 3-Hour
80(A) 365a
1300a
80(A) 365a 1300a
Nitrogen Dioxide
Annual
100(A)
100(A)
100(A)
Not to be exceeded more than once per year.
(A) Arithmetic mean
(G) Geometric mean
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TSP Concentration (ug/m3 )
TABLE A-3. Puerto Rico Air Quality Status (1973) TSPa
Number of Stations Exceeding
Ambient Air Quality Standards
Highest Reading
AQCR # Stations
* Reporting Annual 24-Hr
2nd Highest
Reading
24-Hr
Back-
ground
Secondary
Annual 24-Hr Annual
^Reduction
Required
To Meet
Standards0
Standard on
Which
Reduction
is Based
244
138°
222
210
30
20
20
72
Annual
Secondary
60 yg/m3
3 1973 air quality data in National Air Data Bank as of June 7, 1974.
Violations based on 2nd. highest reading at any station.
c Formula:
2nd. Highest 24-Hr - 24-Hr Secondary Standard Annual - Annual Secondary Standard
2nd Highest 24-Hr - Background x 100, Annual - Background : x 100
1973 annual geometric mean not available, 1972 geometric mean used.
Monitoring stations at Bayamon, Catano, Guayanilla, Ponce, San Juan
-------
TABLE A-4. Puerto Rico AQCR Air Quality Status 1973,
S02 Concentration (yg/m3)
Number of Stations Exceeding
Ambient Air Quality Standards
Standard on
Highest Reading 2nd Highest Reading Primary Secondary
AQCR # Stations 24Hr # Stations . .
# Bubbler Reporting Cont. Annual 24-Hr 24-Hr Annual 24-Hr 3-Hr
244 5e 0 19 61 55 000
% Reduction Required
to Meet Standards0
- 321
wmcn
Reduction
is Based
Annual
80ug/m3
1973 air quality data in National Air Data Bank as of June 7, 1974.
Violations based on 2nd highest reading at any station.
Formula:
2nd Highest 24-Hr-Hr Standard
2nd Highest 24-Hr
x 100,
Annual - Annual Standard
Annual
x 100
Monitoring stations at Bayamon, Guayanillo, Ponce, Ponce and San Juan
-------
TABLE A-5 PUERTO RICO COMBUSTION SOURCE SUMMARY
AQCR
No.
No. of
Power
Plants
No. of
Other Fuel Combustion
Point Sources9
AQCR
Total Emissions
(JO3 tons/year)
Emissions from
P.R. Fuel Combustion Sources
Particulates
f'ue?
Pla"tS C°"tHbUte PPn-xIm.t.ly *» of the total P.R. point
-------
TABLE A-6 PUERTO RICO EMISSIONS SUMMARY PARTICULATESa
CO
AQCR Total
AQCR (lp3 tons/yr.)
244 80
Electricity Generation
(IP3 tons/vr.
2
'~ '
Industrial, Commercial,
Institutional Combustion
Point Source1^
(IP3 tons/yr.
24 30
r .
hnnssions in NEDS summary document as of June 1974
Area Source
Fuel Combustion
th. »0ther" category , Table A-5 contributing X*
-------
TABLE A-7 PUERTO RICO EMISSIONS SUMMARY TOTAL SULFUR DIOXIDE3
244
AOPR Tnf^i ci 4. -j. ^ . Industrial, Commercial/ Area Source
<$T5S$h E3ffgP%&^^ Point Source^ Fuel j Combustion .
171 87 51
viu lurib/ir.; 7o ( IUJ Tons/Yr. ) %
16 9 15 9
a Emissions in NEDS Summary Document as of June 1974
r-o
'"
1n
90. or
-------
TABLE A-8
PUERTO RICO PARTICULATE EMISSION REGULATION
FOR FUEL COMBUSTION
All combustion sources
using solid fuel
Allowable Emissions
0.3 lbs/106 BTU of heat input9
Heat input is the aggregate heat content of all fuels whose
product of combustion pass through a stack or stacks.
TABLE A-9
PUERTO RICO FUEL SULFUR CONTENT REGULATIONS5
Critical areas
All Others
Sulfur Content (% by Wt)
After April 1 , 1974
1.5
After Apri 1 1 ,
1975
0.5
1.0
The Commonwealth is in the process of revising its sulfur in fuel
regulation and will hold public hearings in Oct. 1974. The revised
regulation requires a source-by-source diffusional analysis to deter-
mine the applicable sulfur content for each source with a design capa-
city equal to or higher than 8 million BTU/hr. For sources with a
design capacity lower than 8 million BTU/hr, the maximum allowed per-
centage of sulfur in fuel by weight shall be 2.5.
After April 1, 1975, critical areas are the municipalities of San
Juan, Catano, Guaynabo and Bayamen.
30
-------
TABLE A-10 CONTROL STRATEGY ASSESSMENT - PARTICULATES
State Implementation Plan Requirements
Baseline Baseline Allowable Predicted
Air Quality Emissions Emissions 1975 Emissions
AQCR _ (tig/m-3) (Tons/Yr.) (Tons/Yr.) (Tons/Yr.)
Requirements Based on 1972° Data
1972 NEDS Allowable
Air Quality Emissions9 Emissions
Jolerance for
Emission Increase"
(yg/m3) (Tons/Yr.) (Tons/Yr.) (Tons/Yr.
244
204
88,123
14,981
37,908
138
79,646
22,301
-15,607
a From NEDS Summary Document June 1974.
CO
___!
b Difference between 1973 based allowable and predicted 1975 emissions.
c 1972 latest year for which annual geometric mean was available.
-------
TABLE A-11 CONTROL STRATEGY ASSESSMENT - S02
State Implementation Plan Requirements
Baseline Baseline Allowable Predicted
Air Quality Emissions Emissions 1975 Emissions
AQCR (ua/nr) (Tons/Yr.) (Tons/Yr.) (Tons/Yr.)
Requirements Based on 1973 Data
1973 NEDS Allowable
Air Quality Emissions9 Emissions
(pg/m3) (Tons/Yr.) (Tons/Yr.)
Jolerance for
Emission Increase6
(Tons/Yr.)
244
.152°
134,864 70,981
76,673
19
171,501
_d
-100,520
a
h
c
d
From NEDS Summary Document June 1974.
1973 and SIP data do not compare reasonably. Tolerance for Emission Increase was calculated as the difference
bet, SIP Allowable Emissions - 1973 NEDS Emissions = -100,520 tons which represents a reduction of 100,520
tons.
o
Baseline Air Quality of 152 yg/m on which the SIP for S02 is based was derived from modeling results.
The low 1973 SOg levels do not indicate the need for an emission reduction but, instead, indicate an allowaole
increase in emissions of 321%. Therefore, allowable emissions for 1973 were not calculated from these data.
-------
APPENDIX B
REGIONAL AIR QUALITY ASSESSMENT
TABLE B-1 REGIONAL INDICATORS-PARTICULATES
Air Quality
AQCR
244
No. of Sites with
Monitors A.Q. Violations
c; -,
Priority
Classifications
Expected
Attainment Date
For Standards
Emissions
AQMA
Designations
Total
(103 Ton/Yr)
% From
Fuel Combustion
IA
4/75
Yesdl]
35
Tolerance For
Emission Increase
103 Ton/Yr)
-15.6
-------
TABLE B-2 REGIONAL INDICATORS-S02
AQCR
Air Quality
No. of Sites wi th
Monitors A.Q. Violations
Priority
Classification
Expected
Attainment Date
For Standards
AQMA
Designations
Emissions
Total % Fr
(103 Ton/Yr) Fuel Com
T<
om Emi <
bustion (_
Jlerance For
>sion Increase
244
IA
4/75
Yes(IO)
171.5
68
-100.5U
Only 24-Hr, stations, no continuous monitors.
Modeling indicates an S02 problem not indicated by the monitoring system. The Puerto Rico SIP is based on the modeled air quality
The negative tolerance for emission increase is based on the difference between the 1973 NEDS emissions and SIP allowable emissions.
-------
APPENDIX C POWER PLANT ASSESSMENT
TABLE C-l POWER PLANT ASSESSMENT FOR PUERTO RICO
00
01
AQCR Plant
244 Puerto Rico
Water Authority
Palo Seco
(Catano)
Puerto Rico
Water Authority
San Juan
(San Juan)
Puerto Rico
Water Authority
South Coast
(Guayanilla)
PR Water Authority
Palo Seco
(Catano)
PR Water Authority
Covadonga
(San Juan)
PR Water Authority
Victoria
(Aguadilla)
PR Water Authority
Santurce
(San Juan)
PR Water Authority
Guaynabo
(Guaynabo)
PR Water Authority
Daguao
(Ceiba)
PR Water Authority
^au<*\. i I.JT
(106Watts)
645 (FS)
646 (FS)
717(FS)
41 (J)
28(J)
20(J)
14(J)
14(J)
10(J)
28(J)
Fuel Quantity9
oil 253,176(F)
oil 268,254(F)
oil 212,100(F)
oil 17.160(N)
oil 1,180(N)
oil 3,950(N)
oil 1,390(N)
oil 820 (N)
oil 617(N)
oil 16,400(N)
Regulations Allowable0
.5 2.5
.5 1.5
1.0 1.0
.5 .5
1.0
1.0
1.0
.5
1.0 .5
1.0
(Guaynabo)
Estimates are from FPC (F) or NEDS (N) and are expressed in 103 gal/yr.
Existing sulfur in fuel regulations effective April 1, 1975.
Allowable sulfur content is based on modeling results contained in the proposed revisions to
the sulfur in fuel regulations.
Plant type indicated in parenthesis: (FS) fossil steam, (J) jet power pack.
-------
TABLE C-2 PUERTO RICO POWER PLANT ASSESSMENT SUMMARY
1975 Effects of Sulfur Dioxide Regulations
Power 1<
AQCR Plant (10-
244 PRWA
(Palo Seco)
PRWA
(S.J.)
PRWA
(South Coast)
PRWA
(Draguao)
PRWA
(Palo Seco)
PRWA
(Victoria)
PRWA
(Santurce)
PRWA
(Guaynabo)
PRWA
(Covadonga)
PRWA
(Jobos)
Total
?75 Fuel Use
5 gal /yr) (oil)
253,176
268,254
212,100
617
17,160
3,950
1,390
820
1,180
16,400
775,047
Existing
%S
.5
.5
1.0
1.0
.5
1.0
1.0
1.0
1.0
1.0
S02 Emission
Reduction (tons/yr)a %S
41,736 2.5
40,010 1.5
19,980 1.0
- 44 .5
0 .5
-279
- 98
- 58
- 83
-1,159
100,005
Modified
S02 Emission
Reduction (tons/yr)
1,987
18,952
19,980
-19
0
39,223
reduction (tons/yr) = (A%s)(Fuel Use Quantity) (emission factor)
V 2TK5I5/
-------
TABLE C-3
THE PUERTO RICO WATER RESOURCES AUTHORITY
ELECTRICAL SYSTEM (1974) TOTAL CAPACITY
Plant Type (No.) Capacity (IP6 watts) % of Total Capacity
Fossil-Steam (4) 2908 83
(includes Aquirre)
Jet Power Packs (7) 155 4
Gas Turbine (6) 326 9
Hydro Units (6) 96 3
Diesel Unit (1) 1 1
TOTAL 3486 100
The capacity of the total electrical system of the PRWRA
will be approximately 3486 MW upon completion of the power plant
at Aquirre in 1974. Relevant data on the new fossil-steam plant
are given below:
Capacity (106 watts) 450 (1973), 900 (1974)
Fuel Type/Use (1Q3 gal) Oil/501, 510
Sulfur Content (%) Allowable 3.1
S0? Emissions (T/Yr) 123, 459
37
-------
TABLE D-l. MAJOR INDUSTRIAL/COMMERCIAL FUEL COMBUSTION SOURCE ASSESSMENT - PARTICULATES
AO.CR
Name of Plant
244 Central Guanico
(Guanica)
a.
b.
c.
d.
Central Plata
(San Sebastian)
Central Iqualdad
(Mayaguez)
Central Aquirre
(Salinas)
Central Eureka
(Homigueras)
Central Cortada
(Santa Isabel)
Central Juncos
(Juncos)
Central Lafayette
(Arroyo)
Central Los Canos
(Arecibo)
San Juan Cement
(Dorado)
Total
Boiler Size
(106 Stu/Hr.)
240d
1187(6)d
Unknown
ii
H
M
77(3)
II
11
110(3)
130(4)
103(3)
344(1)
Data in this table were in the NEDS files as
Units are: Bagasse - 103
crushed by pressure rolls.
Tons/Yr., Oil - 103
Dry bagasse has a
Type
Oil
Bagasse
Oil
Bagasse
Oil
Bagasse
Bagasse
Oil
Bagasse
Bagasse
Oil
Bagasse
Oil
Bag'asse
Bagasse
Oil
6i1
Bagasse
of June 1974.
Gal./Yr., Gas
heating value
Allowable emissions based on existing particulate regulation
( ) indicates No. of boilers
Fuel Usage
% Ash % S
1
.05
.7
0
1
.05
%
1
.05
0
. b
.05
1.9
0
0
2.5
- 106 Cu. Ft./Yr. Bagasse
of 8,000 to 9,000 BTU/Lb.
effective April 1, 1975,
Quantity
2,050
280
740
319
8320
266
252
9210
153
141
240
120
756
101
69
20,100
41 ,416
1,701
is the solid
of .3 lbs/106
Emissions
Actual
161
3083
8
3512
95
2930
2772
105
1685
1551
3
1320
114
1108
759
231
717
18,720
residue remaining
BTU of heat input.
(Tons/Yr.)
Allowable0
NA
714
NA
813
NA
678
643
NA
390
360
NA
306
NA *
258
176
NA
4,338
after sugar cane has
Reduction
2369
2699
2252
2129
1295
1191
1014
850
583
-
14,382
been
-------
TABLE D-2. MAJOR INDUSTRIAL/COMMERCIAL FUEL COMBUSTION SOURCE ASSESSMENT - S02 a
AQCR Name of Plant
244 Corco Refining
(Guayanilla)
San Juan Cement
(Dorado)
Phillips PR Core
(Aguirre)
Corco Refining
(Guayanilla)
Caribbean Gulf
(Catano)
Central Mercedita
(Ponce)
Total
Boiler Size
(10° Btu/hr) Type %
459 (3) Oil
344 (1) Oil
490 (3) Oil
490 (3) Gas
1840 (2) Oil
31 (3) Oil
258 (1) Oil
Fuel Useage
Emissions (tons/yr.)
Ash % S Quantity5 Actual Allowable Reduction Allowable
% S Existing0 % s Modified"
Reqs Reas
1.86 32,000
2.5 20,100
2.3 178,000
.12 1,173
1.43 12,200
2.5 11,706
2.5 6,040
261,219
4680 1.0 2,516 2,164
3940 1.0 1,576 2,364
3300 1.0 1,435 1,865
68 -
2740 1.0 1,916 824
2303 .5 461 1,842
1190 1.0 476 714
18,261 8,380 9,773
1.0 2,516
3.1 4,885
2.5 3,586
.15 85
1.0 1,916
1.5 1,382
3.1 1,476
15,846
Reduction
2,164
-945
-286
-17
824
921
-286
2,375
a Data in this table were in the NEDS files as of June 1974.
b Units are: Bagasse 103 tons/yr., Oil - 103 gal./yr., Gas - 106 cu. ft./yr.
c Existing sulfur content regulations effective April 1, 1975.
d Modified sulfur content based on modeling contained in proposed revisions to regs.
-------
APPENDIX E AREA SOURCE ASSESSMENT
TABLE E-l
PUERTO RICO FUEL COMBUSTION AREA SOURCES3
AQCR Name
Puerto Rico
rw^v^rv
No.
244
Type
Oil:
Distillate
Residual
Amountb
67,480
53,140
% S
1.0
2.5
% S Regulation
0-2.5
0-2.5
Parti cul ate
1,216
S02
15,22:
Gas:
Natural 10,440
a NEDS data
Coal in tons/yr;, Oil in 1000 gals.; gas in MCF; wood in tons.
c Total AQCR fuel combustion area source emissions.
-------
APPENDIX F FUEL USE ASSESSMENT
TABLE F-l
STATIONARY SOURCE FUEL SUMMARY REPORT
NATIONAL EMISSION DATA SYSTEM
ENVIRONMENTAL PROTECTION AGENCY
AQCR Fuel Report: Puerto Rico
User File Create Date
Saturday September 7, 1974
Area Sources
Residential
Industrial
Comm-Instl
Total
Point Sources
Ext. Comb.
Elec. Gen
Industrial
Comm-Instl
Total
In Process
Internal Comb.
Elec. Gen.
Industrial
Comm-Instl
Total
Grand Total
Point Sources
Ext. Comb.
Elec. Gen
Industrial
Comm-Instl
Internal Comb.
Elec. Gen.
Industrial
Comm-Instl
Eng-Test
Total
Date of Run
CURRENT ANNUAL FUEL SUMMARY 10/23/74
Anth. Coal Bitm. Coal Res id. Oil Dist. Oil Nat. Gas Proc. Gas Coke Wood
Tons Tons 1000 Gals 1000 Gals 10E6 Cu. Ft. 10E6 Cu. Ft. Tons Tons
53140 27860
39620 10440
53140 67480 10440
388603 34770
255136 24327 24 1173
292 72
644031 59169 24 1173
617
9522 175
10139 175
697171 136788 10639 1173
Lignite Bagasse SW/Coal Lig-Petro Diesel Gasoline Jet Fuel
Tons Tons Tons 1000 Gals 1000 Gals 1000 Gals 1000 Gals
2581668 1533
2581668 1533
Grand Total
2581668
1533
* These data are believed to be outdated but provide an idea of the distribution of fuel use among
Stationary fuel combustion sources. Data nn nnwoi- nlant fnol nco rrmtain^ in T = K1« r_i *»«m
-------
1. REPORT NO.
EPA-450/3-74-070
IMPLEMENTATION PLAN REVIEW FOR PUERTO RICO AS
REQUIRED BY THE ENERGY SUPPLY AND ENVIRONMENTAL
COORDINATION ACT
TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing}
2.
7. AUTHOR(S)
9 PERFORMING ORGANIZATION NAME AND ADDRESS
U.S. Environmental Protection Agency, Office of Air
Quality Planning and Standards, Research Triangle
Park, N.C., Regional Office II, New York, New York,
and TRW, Inc., Vienna, Virginia
12 SPONSORING AGENCY NAME AND ADDRESS
U.S. Environmental Protection Agency
Office of Air and Waste Management
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
RECIPIENT'S %CCESSION«NO.
. REPORT DATE
December 1974
' PERFORMING ORGANIZATION CODE
PERFORMING ORGANIZATION REPORT NO.
10. PROGRAM ELEMEiNT NO.
T1. CONTRACT/GRANT NO.
68-02-1385
13. TYPE OF REPORT AND PERIOD COVERED
Final
14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
16. ABSTRACT ir\j*j-'n*.£ ir»"7/l
Section IV of the Energy Supply and Environmental Coordination Act of iy/4,
(ESECA) requires EPA to review each State Implementation Plan (SIP) to determine
if revisions can be made to control regulations for stationary fuel combustion
sources without interfering with the attainment and maintenance of the national
ambient air quality standards. This document, which is also required by Section
IV of ESECA, is EPA's report to the State indicating where regulations might be
revised.
17.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
I). IDENTIFIERS/OPEN ENDED TERMS
Air pollution
State implementation plans
13 DISTRIBUTION STATEMEN1
Release unlimited
19. SECURI TY CLASS (This Report)
Unclassified
COSAT! Field/Group
NO OF PAGES
44
20 SECURITY CLASS (This page;
Unclassified
22 f-R.
~o>-;v 3220-1 (3-73,
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