EPA-450/5-83-005a
RESIDENTIAL WOOD AND COAL COMBUSTION
TASK 1
Summary of Current and Proposed
State and/or Local Regulatory Activities
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Summary of Current and Proposed
State and/or Local Regulatory Activities
Pertaining to
Residential Wood and Coal Combustion
Prepared by:
DEL GREEN ASSOCIATES, INC.
Environmental Technology Division
P.O. Box 13446
Salem, Oregon 97309
Prepared for:
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Air Quality Planning and Standards
Office of Research and Development
Research Triangle Park, NC 27711
Project Officer
Rayburn Morrison
February 1984
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DISCLAIMER
This report was furnished to the Environmental Protection Agency by
Del Green Associates, Inc., Environmental Technology Division, P.O. Box
13446, Salem, Oregon 97309, in partial fulfillment of Purchase Orders
No. 2D3878YASA and 4D1274NASA. The contents of this report are reproduced
herein as received from Del Green Associates, Inc. The opinions, findings,
and conclusions expressed are those of the authors and not necessarily
those of the Environmental Protection Agency. This report may be reviewed
at EPA libraries, or may be obtained for a fee, from the National Technical
Information Service, 5285 Port Royal Road, Springfield, Virginia 22161.
Publication No. EPA-450/5-83-005a
11
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TABLE OF CONTENTS
page
Executive Summary 1
Introduction 2
Residential Wood Combustion 3
General Regulations That Could Apply 3
Specific Regulations for Residential Wood 4
Combus tion
New England 4
Southwest 4
Pacific Coast 5
Colorado 6
Montana 8
Types of Regulations/Programs for Reducing 8
the Impact of Residential Wood Combustion
Residential Coal Combustion 13
General Regulations 13
Specific Regulations That Prohibit or Restrict 14
Residential Coal Combustion
Appendix I - Jackson County, (Oregon) Board of Commissioners
Findings & Recommendations for a Particulate
Control Strategy, Ordinance No. 82-6, Jackson
County Board of Commissioners
Appendix II - Resolution No. 77-104-Pitkin County, Colorado
(Aspen)
Appendix III - BeaverCreek Resort Company - Regulations
Appendix IV - Oregon Staff Reports - Amendments to Sulfur
Content of Coal Rule
Appendix V - New Jersey State Air Laws - Subchapter 10
Sulfur in Coal
Appendix VI - Maine Air Pollution Laws - Section 603
Low Sulfur Fuel
Appendix VII - Telephone Contacts
111
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LIST OF TABLES
page
Table 1 Summary of Regulations for Woodburning 11
Devices
Table 2 Summary of Existing Control Strategies 12
Table 3 State and Local Air Pollution 15
Authorities Having Sulfur Content
Limitations for Coal
Table 4 Typical Coal Characteristics 16
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EXECUTIVE SUMMARY
Several areas of the country are experiencing significant
increases in air pollution levels as a result of emissions from
residential wood combustion. Areas identified in the West in-
clude parts of Alaska, Washington, Oregon, California, Nevada,
Arizona, Colorado ,and Montana. Several of the New England states
report increases in residential wood combustion, but these reported
increases occur in rural areas where the concentration of homes with
woodburners is not great enough to cause ambient standard violations
The most common regulations or programs dealing specifically with
residential wood combustion involve restricting the number or type
of new combustion units, prohibiting burning during air pollution
episodes, and conducting public education campaigns. Several of
the agencies contacted expressed interest in setting emission stand-
ards and using these to certify stoves, if and when sufficiently ac-
curate source test data become available.
Residential coal combustion was not identified as a current
problem. However, several areas now experiencing high levels of
residential wood combustion are concerned about possible shifts
to coal as wood becomes less available or more expensive. Oregon
has recently placed restrictions on the sulfur and volatile matter
content of coal sold or used, such that currently available coal
is effectively banned. Two Colorado ski communities have totally
banned residential coal combustion. Several metropolitan areas
have also restricted the sulfur content of coal and effectively
banned the residential use of coal, but apparently more as a gen-
eral preventative measure than as a response to an imminent problem.
Numerous states have regulations that were designed to regu-
late industrial and commercial sources that could technically apply
to individual residences. These regulations include opacity stand-
ards, total particulate (pounds per million ETU input), and sulfur
dioxide (pounds sulfur dioxide per million 3TU input). No areas
reported using these regulations for residential combustion sources,
however. A few states specifically exempt residential space heat-
ing from all existing regulations.
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INTRODUCTION
With the rapidly rising prices of conventional fuels, several
areas of the country are seeing a return to wood and coal use for
residential space heating. Residential coal combustion in par-
ticular has been associated in the past with some of the most seri-
ous air pollution episodes recorded. Residential wood combustion
is currently associated with a few areas having visibility impair-
ment and excessive ambient particulate and carbon monoxide levels.
The objective of this study is to review those state or local regu-
lations that either directly or indirectly regulate residential
coal combustion or residential wood combustion.
In order to determine which state and local air pollution
agencies have applicable regulations, a number of information
sources were used. The state regulations (as printed in the En-
vironment Reporter) were briefly reviewed to determine the types
of regulations that might apply. This review was by no means com-
prehensive because of time constraints. Numerous papers and pro-
ject reports (believed .to be essentially all the current litera-
ture) on the subject of residential wood combustion control strat-
egies were reviewed. Based on the information from these two
sources, each of the ten EPA regions were contacted to confirm that
the known regulations were current, and to determine what other
regulations were in effect or under development. State and local
agencies then were contacted as necessary to follow leads and to
resolve any questions. In addition to determining current regula-
tions that affect residential coal and wood combustion, an attempt
was made to determine areas which anticipate significant air pollu-
tion increases due to residential wood and coal combustion (RWCC)
and may be addressing these sources in the near future.
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RESIDENTIAL WOOD COMBUSTION
General Regulations That Could Apply
Almost all state and local air pollution regulations are
designed to control emissions from industrial or commercial
operations, not individual residences. Some of these regulations
could technically be applied to some or all woodburning appliances,
but are rarely if ever used in this way. The three types of regula-
tions that could technically apply are total particulate emissions
(pounds/million BTU), particulate concentrations (grains/standard
cubic foot), and opacity.
Most states have regulations for total particulate emissions
from "fuel burning equipment". The definition provided in each
state's regulations determines whether or not the emission regula-
tion applies to a specific piece of equipment. The state of South
Dakota's definition is typical:
"Fuel burning equipment, a furnace, boiler, apparatus,
stack, or appurtenances to them used in the process of
burning fuel or other combustible material for the pri-
mary purpose of producing heat or power by indirect heat
transfer;"
By this definition, wood fired furnaces and fireplaces with
heatolators would both technically be covered, since they use the
heat from combustion gases to heat air that is then blown into
the areas to be heated. Both these units would produce heat 'by
indirect heat transfer, as would any other wood heating unit having
heating chambers and fans to circulate the warmed air.
Particulate concentration regulations may be applied to fuel
burning equipment in a few states. Compliance with these two
regulations on particulate emissions cannot be determined without
very expensive stack sampling (costing about $1,500 per test) which
is clearly not practical for either an air pollution control agency
or an individual homeowner. There was no indication from any of
the people contacted during this study that these regulations are
used for individual residences, nor are they projected to be used
for residential wood combustion units in the near future.
Opacity regulations are more easily and inexpensively enforced,
requiring only a certified observer and the time necessary to take
the reading. The opacity regulations range from 20% to 40%,
either averaged over a six-minute period or with a time exemption
(i.e., 3 minutes per hour allowed above the opacity limit). These
regulations are probably too stringent to apply to woodstoves.
For example, the Alaska Department of Environmental Conservation
estimates about 20-30% of the wood stoves cannot meet a 70% opacity
standard due to the common practice of burning wet wood. One
major disadvantage to opacity regulations is that they can only be
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enforced during daylight hours, whereas most woodburning occurs
after people return home from work. Again, none of the people
contacted indicated general opacity regulations are being used
for controlling emissions from individual residences.
In a few states, residential fuel burning is specifically
exempted from all air pollution regulations. In some other states,
the particulate emission limits only apply to larger units (i.e.,
greater than one million BTU/hr design capacity). However, most
of the states do not specify exemptions for smaller units. No
list of states exempting small units has been developed because
a detailed, careful reading of each state's regulations and con-
tact with each state would have been required. This was clearly
beyond the scope of this project.
Specific Regulations for Residential Wood Combustion
Many areas across the country reported an increase in residen-
tial wood combustion and some scattered complaints by the public
concerning wood smoke. In contrast to residential coal combustion,
wood combustion has already become widespread in some sections of
the country. Possibly because of the adverse public reception of
regulations on residential wood combustion, the only areas actually
regulating this source are those areas showing non-compliance with
ambient standards and some ski areas dependent on the tourist trade,
A discussion of those areas experiencing problems from high levels
of residential wood combustion and their means of dealing with the
resultant pollutants follows.
.New England
Residential wood combustion, is common in New England, but
occurs largely in rural areas. It has not yet been observed to
contribute to non-attainment in the more populated areas, and no
control strategies are known to be under consideration at this
time. Vermont reports they are developing a public information
program, but no formal control measures.
.Southwes t
Albuquerque, New Mexico suspects residential wood combustion
could be a major factor in their non-attainment status for carbon
monoxide (CO) and Total Suspended Particulate (TSP), but has not
completed the necessary studies to document this. They do have a
voluntary program for curtailing fireplace use during high CO
levels. A light signal atop a downtown building is used during
November through January to indicate when driving and fireplace
use should be limited (red light when CO levels above 13 ppm,
flashing red when CO levels above 26 ppm on an hourly basis).
Washoe County (Reno), Nevada reports that they feel residential
wood combustion contributed to CO and visibility problems but
doesn't expect to go beyond a public education program on proper
burning practices and asking residents not to burn wood during
high pollution levels.
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. Pacific Coast
Fresno County, California has identified residential wood
combustion as a significant contributor (10% of total) to the CO
non-attainment status. The California Air Resources Board is just
starting an emission testing p rogram--they expect to develop con-
trol strategies in a year or more after the testing program is
completed. These possible control strategies would then be avail-
able to Fresno .
Juneau and Fairbanks, Alaska have also experienced high par-
ticulate levels as the result of residential wood combustion.
These areas do not get good ventilation and have approached the
health hazard levels for particulate largely because of residen-
tial wood combustion. A state regulation has been passed effective
November 1, 1982, which limits smoke emissions to 70% opacity for
not more than 20 minutes per hour, but only during an "air quality
alert". An "air quality alert" is defined for the purposes of this
regulation as particulate levels predicted to exceed 375 yg/m .
The highest level seen last winter was 305
One of the major problems identified by the Alaska Department
of Environmental Conservation is the practice of burning green
wood. They estimate 20-30% of residences would exceed the opacity
limit, largely because of the firing of green wood. They are ap-
proaching this problem in two ways: by a public education program,
and by working with the U.S. Forest Service to shift public wood
gathering from the fall to the spring (about 60% of the firewood
burned is from Forest Service land). In the past, the Forest Serv-
ice only marked wood for gathering in the fall, with much of this
wood burned the following winter without proper drying. The Forest
Service is now doing some marking in the spring, and the Alaska De-
partment of Environmental Conservation hopes to shift more of the
marking activities to the spring.
The level of public acceptance and public interest in the
Alaska program is not known at this time. There have been some
newspaper articles on the subject, but no citizens came this past
summer to the public hearing on the regulation.
Oregon has identified residential wood combustion as a sig-
nificant contributor to non-attainment status (for secondary stand-
ards) in Medford and Portland. The Oregon Department of Environ-
mental Quality is prohibited by state law from regulating residen-
tial heating and hence wood combustion, but is expected to try for
authority to certify stoves in the upcoming state legislature ses-
sion (January, 1983).
Jackson County (Medford) Board of Commissioners adopted an
ordinance with the following:
. Mandatory weatherizat ion for homes wishing to install
woods toves
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. Alternate heat source required where woodstoves are
installed
. Prohibit firewood use when suspended particulate exceeds
260 Ug/m^, except for those homes with no alternate heat
source
. Require cost-effective weatherization at time of sale or
rental, after January, 1984, if primary ambient particu-
late standards are not met.
The Jackson County ordinance plus an earlier document on
proposed control strategies are included in Appendix I.
The Seattle area expects residential wood combustion to be
identified as a major air pollution problem in ambient testing
currently being completed. No control strategies will be devel-
oped until this happens.
.Colorado
Different areas in Colorado have enacted regulations affect-
ing residential wood combustion. Most of these areas are ski
communities where ventilation is poor and residential wood com-
bustion is common.
Telluride, Colorado adopted an ordinance four years ago
restricting new solid fuel burners to one per structure, no
matter how many living units are in the structure (i.e., only
one wood stove/fireplace in a 17-unit condominium). The success
of this ordinance has not been evaluated, but it is thought to
have helped. The area still has a serious air pollution problem,
and is looking at further control strategies for this non-attain-
ment area. The major control strategies under consideration are
stricter insulation standards and protecting solar access, and
requiring installation of clean burning stoves of not more than
50% greater emissions than the cleanest available combustion
devices.
Pitkin County (Aspen), Colorado adopted ordinances in 1977
limiting the number of new fireplaces and requiring design stand-
ards for fireplaces including glass doors and outside combustion
air (see Appendix II). Woodstoves were excluded because at the
time it was not known how polluting they were compared to fire-
places, and the use of wood stoves was thought to be preferable
to fireplaces because of their better efficiency. The City of
Aspen did not adopt similar regulations because it was anticipa-
ted that very little additional growth would occur within city
limits. The city is now proposing to regulate woodstoves in ad-
dition to fireplaces during their January 24, 1983, meeting.
Public education is an important part of their program, and pub-
lic acceptance is reported to be very high. Actual performance
standards are much preferred by the City, and once reliable test
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data is available (expected soon) the City intends to switch
over to equipment performance standards.
Vail, Colorado passed an ordinance restricting the number
of new solid fuel burning devices to one per dwelling unit, and
placing restrictions similar to Pitkin County on fireplace con-
struction. Voluntary curtailment is requested when either carbon
monoxide levels or coefficient of haze index exceeds specified
limits.
Snowmass Village, Colorado allows only one solid fuel burn-
ing device per dwelling unit. Also, only one unit is allowed
per restaurant or lodge.
Beavercreek Resort Company (near Avon, Colorado) has adop-
ted regulations for their new development including restrictions
on fireplace construction, prohibitions on starting or continu-
ing fires during adverse air pollution levels, a ban on wood-
stoves, and monitoring requirements for fireplaces. These regu-
lations are to go into effect when 500 units are completed (not
expected before fall, 1983). The elaborate monitoring equipment
is possible since this is a development of very expensive homes.
The specific provisions are included in Appendix III and are
briefly listed here:
, Outside combustion air intake and glass doors for all
fireplaces.
. Fireplaces cannot be installed without the permission
of the company.
. Each fireplace is equipped with a heat sensor wired to
the development's central communication system. Also,
each fireplace must have a light connected to the cen-
tral communication system, for notification to stop
burning.
. No new fires can be started, or new wood added after
the company orders burning stopped. This will occur
when, in the Company's opinion, continued burning could
result in violation of Colorado standards.
. Wood stoves are prohibited.
. Condominiums can have a maximum of one fireplace per
three units .
Crested Butte, Colorado limits woodstoves to one per new
building, provided the building meets very stringent insula-
tion standards (the entire building must meet the standard of
R-22, which requires night insulation or solar shades). This
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strategy basically has stopped the air pollution levels from get-
ting much worse, but is not improving the air quality. The City
is keeping track of developments in stove performance and control
strategies and may require further action in the future.
The Denver area is suspected of being significantly im-
pacted by residential wood combustion. The necessary samples
to "fingerprint" the contribution of wood smoke have been col-
lected, but not yet analyzed.
A citizen panel has been appointed by the Colorado Air
Quality Control Commission and is now evaluating control strat-
egies for residential wood combustion. This study is due in
January or February, 1983. Based on the results of this study,
the state board will determine which, if any, of the strategies
to adopt and where they should apply.
.Montana
Missoula, Montana has adopted some regulations on curtail-
ment of burning at certain particulate levels. At a Stage 1
alert (150 ug/m^), voluntary burning curtailment is requested.
At a State 2 warning (300 yg/m^), curtailment is mandatory. There
were 12 or 13 Stage 1 alerts last year, and it is the County
Health Department's feeling that there was some cooperation.
Since most woodburning occurs after people get home from work
(when it is dark), it is difficult to evaluate the level of
cooperation. A limited survey in 1982 showed about 36% fewer
households burned during the afternoon of a Stage 1 alert. How-
ever, the feeling is that this may be a low estimate, since rela-
tively little burning is done in the afternoons and another sur-
vey shows higher levels of cooperation. In a 1980 survey, 70%
of the respondents said they did not burn during alerts. The
plan for a Stage 2 warning is to tell individuals who are burn-
ing to stop, and then to check after four hours to confirm that
burning has stopped.
Types of Regulations/Programs for Reducing the Impact of
Residential Wood Combustion Currently in Effect
Four major approaches to minimizing the impact of residen-
tial wood combustion were identified in this analysis. These
are :
. Limiting the number of new burners installed.
. Setting design standards or emissions limits.
. Restricting burning during high ambient pollution levels.
. Public education or other voluntary programs to encour-
age proper operation of woodburning units, including
burning properly dried wood.
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The five Colorado ski communities all chose to limit the
number of new fireplaces and/or wood stoves that could be in-
stalled. This approach is reported to be somewhat effective
in reducing the increase in adverse impacts, but does not reduce
the overall wood burning levels. Three of these communities also
have design standards for fireplaces which make the units energy
efficient. This has the effect of reducing overall space heat-
ing requirements, which could presumably reduce the amount of
wood burned—however, the design standards have much more im-
portance as an overall energy conservation strategy than in
reducing air pollution levels.
Alaska is the one area with emission limitations. This
lenient opacity standard only applies during very high particu-
late levels (375 yg/m^) and has not yet been invoked. Opacity
limits have the inherent weaknesses of: only being enforce-
able during daylight hours, whereas much burning occurs in the
evening; needs certified observers; and involves enforcement
against individuals. Several areas expressed interest in emis-
sion levels as a way to certify brands and types of woodburning
devices, but not for individual units. Several groups are doing
extensive stove testing now and in the future (Tennessee Valley
Authority, Oregon Department of Environmental Quality, California
Air Resources Board and U.S. Environmental Protection Agency).
These new emission standards would probably be applied to new,
not existing, units.
Five areas have either voluntary or mandatory bans on wood-
burning when air pollution reaches specific levels. Three of
the areas, Alaska, Pitkin County, and BeaverCreek Resort Company
(Colorado), have not yet invoked their regulations. Missoula,
Montana has reached the triggering ambient levels for voluntary
curtailment. A survey by them of 1,200 homes showed about one-
third of the homes did stop burning wood during a period when
voluntary curtailment was requested. As with the opacity stand-
ards, it is difficult to determine who is burning after dark,
when much of the woodburning normally occurs. Jackson County,
Oregon (Medford) adopted an ordinance requiring mandatory cur-
tailment if 260 ug/m3 particulate level is exceeded, effective
10/24/82.
Public education programs on proper burning techinques are
common in areas with heavy wood burning. Missoula, for example,
has an active program which includes pamphlets, a teacher's packet,
public service announcements, and an active speakers bureau.
Proper operating practices and proper storage and drying of
wood are stressed. While the actual impact of such programs
is difficult to quantify, they have the distinct advantage of
a high level of public acceptance.
In addition to public education encouraging proper drying
of wood, some areas are working with local foresters to shift
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wood gathering activities to the spring. This allows enough
time for the wood to dry before the following heating season,
where fall firewood gathering does not allow enough drying
time. This type of control strategy is relatively easy to
enact, requiring only an interagency agreement between the
air pollution control and forestry agencies. Obviously, it
will be most effective in areas such as Oregon and Alaska that
have public forest lands as the source of most firewood.
The only attempt to quantify the effectiveness of the vari-
ous control strategies found during this study was the Missoula
survey on voluntary curtailment. Other areas either have not
fully enacted their programs, or reported simply that they
thought their programs were slowing down the ambient air qual-
ity degradation. The Jackson County (Medford, Oregon) docu-
ment on proposed control strategies does attempt to estimate
the effect of the various strategies on ambient levels in that
airshed—however, these strategies have not yet been tried and
the actual impact is unknown.
A summary of the woodburning regulations by location is
presented in Table 1, and by type of regulation in Table 2.
10
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RESIDENTIAL COAL COMBUSTION
None of the Regional or state offices contacted reported
an existing air pollution problem with residential coal com-
bustion. Only Region X and a few areas indicated any concern
with a near term potential problem from widespread residential
coal combustion.
Those areas now showing concern are those currently ex-
periencing high pollution levels from residential wood combus-
tion. The reason for this connection between a current wood
combustion problem and fear of a future coal combustion problem
appears to be the number of combination wood/coal burners being
sold, and the fear that as the relative cost/availability of
wood and coal changes, there will be a massive shift to coal.
For example, the Oregon Department of Environmental Quality
cites a recent issue of Wood and Energy journal containing 36
ads for solid fuel stoves, of which 27 were combination wood
and coal burning units. (See Appendix IV). Another factor for
those areas concerned about residential coal combustion is the
difficulty already experienced in regulating a residential heat-
ing practice once it is established--clearly it is easier to
prevent residential coal combustion from getting started than
to try to stop it after coal burners have been installed and
coal merchants geared up for this market. The one area that
shows an increase in residential coal combustion is New England.
However, no one contacted from that area indicated a serious
air pollution problem is expected from coal combustion.
General Regulations
As discussed under the Residential Wood Combustion sec-
tion, most states have regulations designed for industrial and
commercial sources that could potentially be applied to resi-
dential coal combustion. The general types of regulations are:
.Limit on sulfur content for coal sold or used
.Opacity limits
.Particulate limits for indirect fired combustion sources
(pounds particulate/million BTU input)
.Sulfur dioxide limits for indirect fired combustion sources
(pounds sulfur/million BTU)
.Particulate concentrations (grains/standard cubic foot)
The last three regulations require expensive stack sampling
to determine compliance. While emissions could be estimated us-
ing established emission factors and fuel analysis, such an estim-
ation could not be used to actually determine violations. This
ability to accurately determine violations at a "reasonable" cost
13
-------
in money and effort is critical in evaluating possible regula-
tions. Source tests for individual stove stacks clearly is not
practical. No areas reported using these regulations on indivi-
dual residences.
Opacity standards could be applied against residences, but
are not reported to be used. Limiting the sulfur content of
coal could be one means to at least limit the amount of sulfur
dioxide emitted. Table 3 lists the states and local areas hav-
ing sulfur content regulations for coal sold or used. Table 4
lists the sulfur content of different types of coal available
in different areas for comparison purposes. As can be seen,
the sulfur content regulations generally do not have the effect
of banning coal, but rather encourage the use of cleaner coals.
Appendices V and VI contain example coal content regulations for
New Jersey and Maine, respectively.
Specific Regulations That Prohibit or Restrict Residential
Coal Combustion
In some areas, the sulfur content has the effect of pro-
hibiting the use of currently available coal. Oregon has one
of the toughest regulations, and it is aimed directly at stop-
ping residential coal combustion before it can become widespread.
Wood stove sales have been extensive in the last five years.
Over the next twenty years or so, wood availability is expected
to decrease because of a leveling off and decline in logging ac-
tivities (much of the firewood gathered is a by-product of such
activities). At the same time, competition from other uses of
slash (such as for pulp production) is expected to increase which
will have the effect of raising the cost of firewood. While coal
is not currently abundantly available in Oregon, major coal ex-
port facilities are under construction and it is expected that
large amounts of coal from other Western states will start pass-
ing through Oregon. Because of the fear of a widespread switch
from the scarcer, more expensive wood to coal, Oregon has set
restrictions on coal such that currently available coal could
not be used. Appendix IV includes the Oregon Department of En-
vironmental Quality staff papers supporting adoption of this
regulation.
Vail and Crested Butte, Colorado have also experienced ad-
verse air pollution from residential wood combustion, and have
banned any residential burning of coal. Aspen and Telluride
(ski communities in Colorado) have also considered outright bans
on residential coal combustion, in addition to the current limit-
ation on the number of solid fuel burners (see Residential Wood
Combustion discussion). All four of these communities depend on
the natural beauty of their areas to attract tourists, and are
very concerned about practices such as residential wood or coal
combustion that could impair their attractiveness to tourists,
Missoula, Montana, another area heavily impacted by residential
14
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TABLE 3
Stace and Local Air Pollution Authorities
Having Sulfur Content Limitations for Coal
State/Local
Limitation
Region I
Connecticut
Maine
Massachusetts
New Hampshire
Rhode Is land
Vermont
Region II
New Jersey
New York
Region III
Delaware
Washington, 0.C.
Philadelphia
Region IV
NONE
Region V
Wisconsin
Region VI
NONE
Region VII
Missouri
Region VIII
Utah
Region IX
California
Hawaii
Region X
Idaho
Oregon
Washing ton
l.OZ sulfur - entire state
l.OZ to Z.5Z sulfur depending on location
0.28 to 1.21 pounds sulfur/million BTU heat
release protential,depending on location!
1.50 sulfur/million BTU heat release
(after 1970)
0.55 pounds sulfur/million BTU heat release
potential2
22 sulfur
0.2Z to l.OZ depending on type of coal and
location
0.2Z to 1.4Z pounds sulfur/million BTU
potential heat release depending on location
1Z sulfur .in New Castle County
LZ sulfur
0.6Z sulfur for existing units (10/01/80),
0.3Z sulfur for new units
1.110 sulfur/million BTU for southeast
Wisconsin3
2.0Z sulfur - St. Louis metropolitan area
1.0* sulfur/million BTU
0.5Z sulfur - San Francisco, Sacramento,
and San Diego areas
2.0Z sulfur
l.OZ sulfur
0.3Z sulfur, 5.0Z volatile content - Portland,
Eugene-Springfield, Medford-Ashland, and Salem
l.OZ sulfur for rest of state
Seattle area -
2.0Z sulfur
l.OZ sulfur. Northwest area -
Corresponds to 0.35Z t_o 1.5Z sulfur content, assuming 12,500 BTU/pound coal.
2 Corresponds to 0.7Z sulfur content, assuming.12,500 BTU/pound coal.
J Corresponds Co 1.4% sulfur content, assuming 12,500 BTU/pound coal.
15
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