EPA-450/2-75-001
January 1975
       TECHNICAL SUPPORT DOCUMENT -
   EPA REGULATIONS FOR PREVENTING THE
SIGNIFICANT DETERIORATION OF AIR QUALITY
       U.S. ENVIRONMENTAL PROTECTION AGENCY
            Office of Air and Waste Management
         Office of Air Quality Planning and Standards
         Research Triangle Park, North Carolina 27711

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                                           EPA-450/2-75-001
       TECHNICAL SUPPORT DOCUMENT -
    EPA REGULATIONS FOR PREVENTING THE
 SIGNIFICANT DETERIORATION OF AIR QUALITY
   U.S. Environmental  Protection Agency
Office of Air Quality Planning & Standards
       Research Triangle Park, N. C.
               January 1975

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This report is issued by  the Environmental Protection Agency to  report
technical  data of interest  to a limited number of readers.   Copies are
available  free  of charge to Federal employees, current  contractors
and  grantees, and nonprofit organizations  -  as  supplies permit - from
the Air Pollution Technical  Information Center,  Environmental Protection
Agency, Research  Triangle Park, North  Carolina  27711; or,  for  a
fee,  from the National Technical Information  Service, 5285 Port Royal
Road,  Springfield, Virginia 22161.
                   Publication No.  EPA-450/2-75-001

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                                CONTENTS

   1.   BACKGROUND	1
  11.   REASONS FOR SELECTING A THREE-CLASS AIR QUALITY INCREMENT
       PLAN	5
 111.   REASONS FOR REJECTING ALTERNATIVE PLANS  	   10
       1.   Volume Averaging (Sierra Club Plan)  	   10
       2.   Emission Limitation Plan	11
       3.   Emission Charge Plan	12
       4.   Per Capita Emission Plan (NRDC Plan)	14
       5.   Percent Increase Above Existing Air Quality Level   .  .   15
       6.   Local  Definition Plan	17
       7.   Establishment of Absolute Air Quality Levels Below
           the National  Standards 	   18
  IV.   SELECTION OF AIR QUALITY INCREMENTS  	   19
   V.   POLLUTANTS COVERED BY THE REGULATION 	   21
  VI.   SOURCES SUBJECT TO REVIEW  	   27
 VI1.   AIR QUALITY MONITORING REQUIREMENTS  	   29
Vll1.   IMPACT OF THE REGULATIONS ON GENERAL GROWTH AND
       DEVELOPMENT	30
  IX.   IMPACT ON POWER GENERATION AND NEW ENERGY SOURCES  ....   30
   X.   INTERSTATE BOUNDARY CONFLICTS  	   32
  XI.   BEST AVAILABLE CONTROL TECHNOLOGY  	  ...   34
 Xll.   INITIAL CLASSIFICATION AND CRITERIA FOR RECLASSIFICATION  .   35
Xlll.   EFFECTIVE DATE FOR SOURCE REVIEW AND DETERMINATION OF
       SIGNIFICANT DETERIORATION  	   37
       REFERENCE 6   	41
       REFERENCE 11	52
       REFERENCE 12	71
       REFERENCE 13	80
       REFERENCED	81
       REFERENCED	99
       REFERENCE 16	107
       REFERENCE 17	Ill
       REFERENCE 20	115

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     This document provides a detailed discussion of the
technical and policy considerations which form the basis
for EPA's regulations for prevention of significant air
quality deterioration, which were published on December 5,
1974 (39 FR 42510).  Generally, the body of this document
contains a summary of each major issue and references
more detailed materials which have been prepared on that
issue.
I.    Background
     At the time the Administrator was required to approve
or disapprove State Implementation Plans  (SIP's), he
believed that he was required under §110 of the Clean
Air Act (the "Act") to approve SIP's which attained and
maintained national ambient air quality standards promul-
gated under §109 of the Act.  He did not believe that he
had authority to disapprove SIP's which attained and main-
tained national ambient standards but did not prevent
deterioration of existing air qualiry cleaner than the
standards.
     On May 24, 1972, the Sierra Club and other groups
filed suit in the U. S. District Court for the District
of Columbia seeking a declaratory judgment and injunction
requiring the Administrator to disapprove all State imple-
mentation plans which did not contain procedures for pre-
venting significant deterioration in any portion of any
State where air quality is superior to national standards.
On May 30, 1972, the District Court for the District of
                            1

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                          _ 2 —

Columbia granted the plaintiffs"  motion and issued a pre-

liminary injunction requiring the Administrator to review

all State plans and "disapprove any portion of a State

plan which fails to effectively prevent significant deteri-

oration of existing air quality."  (344 F.Supp. 253)  The

preliminary injunction also required the Administrator to

promulgate regulations "as to any State plan which he

finds, on the basis of his review, either permits the signi-

ficant deterioration of existing air quality in any portion

of any State or fails to take the measures necessary to

prevent such significant deterioration."  On November 1,

1972, the decision of the District Court was affirmed by

the U. S. Court of Appeals for the District of Columbia

Circuit on the basis of the District Court opinion.   (4

ERC 1815)  On June 11, 1973, the Supreme Court, by an

equally divided court, affirmed the judgment of the Court

of Appeals; no opinion was issued.  (412 U.S.  541)

     Each State plan has been reviewed in accordance with

the preliminary injunction issued by the District Court.

Although many State plans included regulations which have

the potential for resulting in the attainment  of air

quality better than that required by the national standards,

and although some State plans contained general policy

statements indicating an intent to prevent or  minimize

deterioration of air quality, none was found to contain

explicit and enforceable regulations for implementing such
         1
a policy.

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                          - 3 -




     Accordingly, all State plans were disapproved by the




Administrator on November 9, 1972 (37 FR 23836), insofar




as they failed to provide for the prevention of significant




deterioration.  This disapproval did not affect the status




of any previously or subsequently approved regulations




designed to provide for the attainment and maintenance of




national ambient air quality standards.




     On July 16, 1973  (38 FR 18986), an initial notice of




proposed rulemaking was published which set forth four




alternative plans for preventing significant deterioration,




and which solicited widespread public involvement in all




aspects of the significant deterioration issue.  A series




of public hearings were held and over 300 written comments




were submitted in response to this proposal.  The hearing




records and the written comments are available for inspection




at the EPA Freedom of Information Office, 401 M Street,




S.W., Washington, D. C.




     Since neither the Clean Air Act nor the Court order




define "significant deterioration," the initial proposals



focused on the conceptual basis for regulations.  The com-




ments received on the proposed regulations therefore tended




primarily to discuss conceptual issues such as the roles




of federal and state/local governments, rather than de-




tailed comments regarding implementation of the regulations.




Accordingly, on August 26, 1974  (39 FR 31000), the Adminis-




trator reproposed regulations based on the conceptual




approach he had determined appropriate.  The purpose of

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                          .. 4 -




the reproposal was to focus more clearly on procedural



and technical issues.  Final regulations were published



on December 5, 1974  (39 FR 42510).




     Briefly, the regulations promulgated on December 5,




call for the establishment of "classes" of different



allowable incremental increases in total suspended parti-




culates  (TSP) and sulfur dioxide  (SO^,) .  Class I applies



to areas in which practically any change in air quality



would be considered  significant; Class II applies to areas



in which deterioration normally accompanying moderate



well-controlled growth would be consideired insigificant;



and Class III applies to those areas in which deterioration



up to the national standards would be considered insigni-




ficant.  All areas of the country are designated Class  II




initially, but provisions are included to allow States.  Federal



Land Managers and Indian governing bodie;s to request re-



designation of any area to accommodate social, economic,



and environmental needs.



     The plan is implemented through a preconstruction



review of specified  source categories to determine whether



these sources would  cause a violation of the appropriate



increments.  The regulations also include a provision



requiring the use of best available control technology



on sources covered by the regulation.  Finally, the regu-



lation provides procedures for public comment on each



application  for permission to construct and for delegating

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                          - 5 -



the responsibility for implementing the new source review




procedures to States or local governmental units.








II.  Reasons for selecting a three-class air quality



     increment plan



     The decision to adopt a three-class increment plan



was based on the conclusion that consideration of varying




social, economic, and environmental factors in different



areas would result in varying definirions of what is



"significant."



     Section 109 of the Clean Air Act requires the Admin-



istrator to establish national secondary ambient air quality



standards, "to protect the public welfare from any known



or anticipated adverse effects," including, as specified



by section 302(h), "effects on soils, water, crops, vegeta-



tion, man-made materials, animals, wildlife, weather,



visibility, and climate, damage to and deterioration of



property, and hazards to transportation, as well as effects



on economic values and on personal comfort and well-being."



Such national standards must be based on air quality



criteria which,  under section 108, must "reflect the




latest scientific knowledge useful in indicating the kind



and extent of all identifiable effects on public health



and welfare which may be expected from the presence  (of



air pollutants)  in the ambient air, in varying quantities."



Thus, standard-setting under section 109 protects against



demonstrable or predictable adverse effects which can be

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                           - 6 -

quantitatively related to pollutant concentrations in

the ambient air.

      Limitations on air quality that result in cleaner

air than the national ambient air quality standards cannot

therefore be based on any quantitative measure of harm to

either public health or welfare.  This is not, however,

to say that there are no possible unquantifled adverse

effects on public health or welfare below the levels of the

national standards.  Examples of such unquantified effects

involve the transformation of sulfur dioxide into suspended

sulfates and sulfuric acid aerosols,  resulting in

possible effects on nealth, visibility, climatic changes,
                                                2
acidity of rain, and deterioration of materials.

      Since there is no way to relate "significance" of

deterioration of air quality to any adverse effects re-

sulting from air quality levels cleaner than the national

standards, EPA concluded that the determination of what

is "significant" deterioration must take: into account

factors other than air quality alone.  For example, re-

latively minor deterioration of the aesthetic quality of

the air may be very  significant in a recreational area

in which great pride  (and  economic development) is derived

from  the "clean air".  Conversely, in areas with severe

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                          _ '7 _

unemployment and little recreational value, the same

level of deterioration might very well be considered

"insignificant" in comparison to the favorable impact

-of new industrial growth with resultant employment and

other economic opportunities.

     EPA's belief that any determination of what deteriora-

tion increment should be prohibited as "significant"

must take into account the practical effects of such

determination is supported by the decision directing EPA

to prevent such deterioration and the legislative history

of the Clean Air Act.  In its decision directing EPA to

promulgate regulations preventing significant deterioration

of air quality, the District Court relied heavily on

language in the Senate Report on the bill that became the

Clean Air Act  (S.Rep. 91-1196, at 91st Cong. 2d Sess. at

2, 1970).

          "In areas where current air pollution
     levels are already equal to or better than
     the air quality goals, the Secretary shall
     not approve any implementation plan which
     does not provide, to 'the maximum extent
     practicable, for the continued maintenance
     of sucn amtoient air quality."   (emphasis
     added) *

     The significant deterioration regulations have great

potential impact on the nature, extent, and location of

future industrial, commercial, and residential development
     The requirement in these regulations that all new
     sources in the 18 listed categories use best available
     control technology is also part of the attempt to limit
     air quality deterioration "to the maximum extent
     practicable."

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throughout the United States, and specifically their

impact on the utilization of the Nation's mineral re-

sources, the availability of employment and housing in

many areas, and the costs of producing and transporting

electricity and manufactured goods.  The Administrator

believes that it is most important to recognize and

consider these implications, since the consideration of

air quality factors alone provides no basis for selecting

one deterioration increment over another.

     Although some have argued that economic and social

factors should have no bearing on the definition of signi-

ficant deterioration and that only air quality factors

should be considered in establishing a single nationwide

definition of significant deterioration, none of the
         3,4,5
comments       suggesting changes to the increments pro-

posed by the Administrator, or proposing alternate plans,

offered any justification for the numbers which were

selected.

     It has been argued that the provision for Class III

areas is unresponsive to the court's order in that it

permits deterioration of air to the national standards

in these areas.  Although this result could also occur

in Class I or Class II regions where the difference

between existing air quality and the national standard is

less than the prescribed air quality increment, all such

comments focused on the provision for Class III areas.

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                          _ Q _

Unless "significant deterioration" is defined as a per-

centage of the "unused" air resource, any air quality

increment plan, regardless of how small the increment is,

could allow deterioration up to the national standard in

some instances.  As discussed below, a plan that is dependent

on a knowledge of existing air quality is virtually un-

workable.  Therefore, the fact that air quality could,

in some, instances, increase to the national standard does

not, in the Administrator's opinion, make the regulations

inconsistent with the Court's ruling or the Clean Air Act.

     Since the regulations are based on the premise that

the significance of deterioration must be determined

partially on the basis of the practical effect of the

determination and the present or intended use of the

land  (e.g., pristine recreational area or commercial-indus-

trial area), the Administrator believes that the people

in the area for which the determination is being made

should make the determination of what  level of

deterioration should be considered significant.  EPA

lacks the resources or knowledge to determine what air

quality deterioration would be considered significant

in every area of the country.  However, the Administrator

will not approve requested designations which are arbitrary

or capricious. *
     Redesignations protested by other States or Indian
     Governing Bodies are discussed in Section X, infra.

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                         - 10 -



III. Reasons for rejecting alternative plans



     1.  Volume averaging (Sierra Club Plan)



     The details of this plan are presented in Reference 6.



Under this plan, air quality deterioration would be de-




finded in terms of the concentration of air pollutants



averaged over a one kilometer sphere, the center of which



would be the point emissions are released to the atmosphere.



Although basically an air quality increment plan, the



volume averaging plan is intended to limit the total amount



of pollutants emitted to the atmosphere, rather than



directly limit ground level concentrations.  Although total



atmospheric burden is better related to effects such as




acid rain and visibility reduction than is ground-level



air quality, most other unquantified effects at levels



below the national standards are related to ground or



near-ground level concentrations  (corrosion rates, plant



effects, suspected health effects, etc.).  Since the use



of ground-level air quality at individual points  (as



opposed to spatial averages) is consistent with the way



the national ambient air quality standards  (NAAQS) were



established and the way attainment of the NAAQS is



determined, the NAAQS provide a meaningful range of



values from which to select an appropriate

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                           - 11 -



deterioration increment.  No such "guidance" is avail-



able under the volume averaging plan and the "definition"



of significant deterioration under this plan tends to be



much more arbitrary.



      Furthermore, although the average volumetric concen-



tration is easily calculated for a single source, the ad-



ditive effect of multiple sources is much more dificult



to compute.  Since this plan contains no inherent advan-



tages, yet is technically more difficult to implement than



a ground-level air quality increment plan, a volume averag-



ing plan was not used.



      In addition to the conceptual difficulties with a



volume averaging plan, the specific increments proposed



by the Sierra Club would impose severe growth restrictions,



especially on energy-related facilities.   The Sierra Club



has presented no rationale for these specific increments.



      2.  Emission limitation plan



      A typical emission limitation plan was described



in EPA's initial proposal of July 16, 1973  (38 FR 18986



at 18991).  This plan would have limited total emissions



of TSP and SC>2 over a relatively large area and indirectly



prevented the significant deterioration of air quality.

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                            -  12  -

     Basically, this plan focuses on total atmospheric load-

ing, and as such has many of the same advantages and dis-

advantages as discussed for the volume averaging plan.  It

has a significant advantage in terms of technical simplicity

over an air quality increment plan, in that emission data

are easier to acquire and more reliable than estimates of

air quality computed using atmospheric simulation models.

However, its principal disadvantage is the lack of consistency

between emissions and air quality, particularly on a nation-

wide basis.  As discussed above, a plan which focuses on

ground-level air quality, in accordance with traditional air

quality management practice, is considered preferable to an

average atmospheric burden plan.  In addition, the averaging

of emissions over a large region could permit the creation of

small areas of substantial air quality deterioration.  This

might be inconsistent with the court's order to prevent

"significant deterioration in any portion of any state."

     The growth and development impacts of this plan were
                            7,8,9,10
analyzed in several studies        and are summarized in a
                11
separate report.   These studies indicate that economic growth

would be restricted in a number of instances and that these

restrictions would be most severe for coal-fired power plants.

     3.   Emission charge plan

     The general reasoning behind such a plan is that secondary

NAAQS comprise adequate upper limits on pollutant concentrations,

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                            -  13  -
but air quality superior to those limits is desirable.  The
emission charge would provide a continuous incentive for
sources to seek and apply emission controls to minimize their
emission charges.  The collective effect of these individual
cost minimizations would be to maintain air quality at levels
superior to NAAQS in most areas.  The level of air quality
maintained would be a function of the emission charge rate,
the development potential of the area, and the state-of-the-art
of emission control.
     The major advantages of this plan are that the cost of
emitting would be "internalized:  i.e., it would be taken
into consideration in the normal economic appraisal of plant
design and location alternatives.  Sources would have numerous
options as to control method, cost, and degree of control
from which to make the optimum choice.  The state-of-the-art
of emission control would be continuously advanced.  Finally,
the means of enforcement would be charge collection which  is
relatively easily administered.
     Unfortunately, several problems attend such a plan.
In view of the requirement that  "significant
deterioration of air quality is to be prevented by the emis-
sion charge, some relationship between the charge rate and
the resultant air quality must be found.  Such a relationship
is not presently available.  Even if this relationship were
available, the emission charge rate would have to vary from
place to place to offset the variation in developmental

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                           - 14 -



potential offered by different land areas and the variable




capacity of the air to disperse waste under different meteoro-



logical and topographical conditions.  Also, there is a ques-



tion as to whether the Clean Air Act provides adequate



legal authority for EPA to implement such a plan.  But most



important, an emission charge would not guarantee that sig-



nificant deterioration could not take place in some portions



of some states.  Consequently, the emission charge, while



possessing some desirable attributes, does not appear to



be a practical means of preventing significant deteriora-



tion of air quality, especially on a nationwide basis.



      4.  Per capita emission plan (NRDC plan)



      The Natural Resources Defense Council  (NRDC) proposed



a per capita emission plan.  Under this plan the total



emissions in clean areas, plus a five percent increase,



would be divided by the total population in clean areas to



arrive at the allowed per capita emissions.  The total



emissions allowed in any area would then be calculated as



 (the population in the area) times (the per capita emission



rate).  The primary advantages claimed for this proposal




are the emphasis on omissions rather than air quality, and



the relationship between the level of emissions and the pop-




ulation served.  The latter advantage cited by NRDC would

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                           - 15 -



in many cases represent a major disadvantage.  Because



part of the motivation to prevent significant deteriora-



tion is concern for currently unquantified but suspected



low level effects, it does not seem reasonable to force



new polluting development to locate in areas of high pop-



ulation.  This result would add new pollution in areas



where air quality levels are already relatively high and



would result in many more people being exposed to the



added pollutants than if sources were located in less



populated areas.




      This plan would tend to prevent development of cur-



rently needed natural resources such as low sulfur coal



and oil shale which are located in areas of very low



population.  In addition, the location of many other



facilities such as smelters, paper mills, phosphate rock



processing, and oil shale retorting are determined by the



location of natural resources, not the population served.



Under the per capita emission plan it is unlikely that



facilities such as these could be built.



      5.  Percent increase above existing air quality level



      This approach would limit deterioration to fixed



percentages above existing air quality levels.  The pro-



blem with the plan is in the difficulty of defining



"existing" air quality.  Even with no change in man-made

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                           - 16 -

emissions, air quality levels in "clean" areas can vary

substantially from day to clay, year to year due to changes

in natural emissions and variations in meteorological con-

         12
ditions.*    A further problem with this plan is that air

quality monitoring is presently concentrated in heavily

polluted urban areas, which constitute only a small portion

of the total area of the country.    In the relatively

clean rural areas which are principally affected by the

significant deterioration regulations, there is very

little monitoring being done.  Although atmospheric diffu-

sion modeling could be used to estimate existing air

quality levels, the difficulty in quantifying natural

sources of particulate matter would make the results quite

questionable.  Also, models; for estimating existing

concentrations of reactive pollutants  (nitrogen dioxide

and photochemical oxidants/hydrocarbons) are not available

as discussed below.  In summary, accurate definition of
      "For example, Cape Hatteras, North Carolina, showed a
      yearly average of  (of TSP) 58 ug/m3 in 1968 and  110 ,ag/m
      in 1972.  The station in the Black Hills National Forest,
      South Dakota, had an annual average of 10 /ug/m   in 1968
      and 37 jag/m  in 1964.  The range of 24-hour averages for
      a single station is often from a few micrograms  per cubic
      meter to over 150 jug/m .  For example, in Rio Arriba
      County, New Mexico, the lowest reading was 9 jug/m  and
      the highest 257 jug/irT during 1964..   . . . Although
      attempts to measure SC>  at twenty-eight non-urban
      stations have been conducted over the past six years, the
      results of this effort forced the conclusion that it will
      be essentially impossible to establish any sort  of base-
      line, nationally or area-wide, using the standard reference
      method.  This is largely due to the insensitivity of the
      technique."  (Reference 12 at pp. 5-6).  These data also
      influenced EPA's dicision not to have a single inviolate
      deterioration increment for the whole country.

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                           — T_ 7 —

existing air quality in clean areas of the country is not

available nor can such data reasonably be obtained.*

      6.  Local definition plan

      This plan would have prevented significant deteriora-

tion by requiring local determination, on a case-by-case

basis, of the significance of the air quality impact of

major new sources.  This plan recognized the variability

between areas and called for a subjective decision-making

procedure to be implemented at the local level.  A major

disadvantage is that the local definition plan uses what

is essentially a "sliding baseline," and deterioration is

always measured relative to the current air quality.  Hence,

there is no control over the ultimate level of deterioration,

which could progress in finite increments up to the level

of the secondary standards.  Also, the long range impact

of deterioration is not restricted to the local area.  The

regulations proposed on July 16, 1973, associated with

this plan required public comment from within "the area

significantly affected by the potential emissions".
      The plan selected does not present these difficulties
      although it refers to increases above a baseline level.
      The increases are stated in absolute terms, not as a per-
      centage of the baseline.  Thus, the baseline may be taken
      as zero and subsequent air quality changes determined by
      modeling the air quality effects of increased or decreased
      emissions which were not included within the baseline.

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                          - 18 -



However, it is entirely possible that the cumulative ef-



fects of sources in "growth-oriented" regions could have



a significant impact on the air quality of neighboring



"clean-air oriented" regions, and these neighboring re-




gions would thereby lose control over their own environ-



ment.  Although the State,  rather than the local popu-



lation, has final -authority for the definition of signi-



ficant deterioration (which tends to mitigate this con-



cern) , the impact of sources in one region on the air



quality in neighboring regions remains a problem under



this plan which could be especially serious in interstate



situations.



     7.  Establishment of absolute air quality levels



         below the national standards.



     In effect, this plan would result in more restrictive



air quality "standards" which would plaice an absolute



ceiling on air quality concentrations.  However, the



amount of deterioration which would be permitted under




this plan would vary significantly throughout the countr/



depending on existing air quality le;vels.  In very clean



areas, a substantial amount of deterioration would be



permitted, while in areas that presently exceed the selected



"standard", absolutely no deterioration would be permitted.



Therefore, this plan could be very inequitable, especially



when applied on a nationwide basis.

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                         - 19 -



IV.  Selection of air quality increments



     The Class I increments represent extremely stringent



deterioration criteria, and application of these increments



would prohibit the introduction of even one small fossil


                                               14
fuel fired power plant or municipal incinerator   unless



existing emissions are reduced.  Strong incentives there-



fore exist in Class I areas for improved emission control



technology to reduce existing emissions and for introduc-



tion only of low-pollution development.  Although Class I



could be applied to a semi-urban or urban area in which



it was desired to inhibit further development, it is



anticipated that Class I would normally be applied to



those ultra-clean areas such as national and state forests



and parks, and other recreational areas in which it is



desired to prevent essentially any deterioration of



air quality.



     The Class II increments were established to permit



what, in the Administrator's judgment, constitutes moderate,



well controlled growth.  Large point sources, aggregation



of several moderately-sized sources, and large-scale



general growth would be permitted only in Class III areas.

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                          - 20 -




For example, the power plant size that normally would be



permitted at a single location within a Class II area



is approximately 1000 MW.    Assuming that such a source



used up 90% of the allowable increment in a Class II area,



a similar source could not be located within 25 miles of




the first plant.    Similarly, typical coal gasification



plants, oil shale processing facilities, and petroleum




refineries would not be expected individually to exceed




the Class II increments in most areas.  However, the



Class II increments would prevent the aggregation of




such sources within close proximity of each other.  It



should be noted that the foregoing statements are generali-



zations, since the impact of the Class II increments with



respect to the source size permitted and the distance



which must be maintained between major sources is highly



dependent on the meteorology, topography, and stack heights



applicable in each specific situation.



     Comments were specifically requested in the August 27,



1974, proposal as to whether the Class II increment should



be doubled.  Power companies generally supported such a



change, "Awhile other comments from the industrial sector



indicated that the increments were adequate for well-



controlled growth.  Power companies indicated that many

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                          - 21 -




new plants would be much larger than those which would




be allowed in a Class II area  (approximately 1000 mega-




watts) ,  and that the Class II increment ought to accomo-




date such development.  None of the comments presented




any reasons for permitting such development in a Class II




rather than a Class III area, except that the initial




designation of all areas will be Class II.  The Admin-




istrator continues to feel that a Class II increment should




be compatible with moderate, well-controlled development




in a nationwide context,   and that large-scale develop-




ment should be permitted only in con5unction with a




consicious decision to redesignate tne area as Class III.




V.  Pollutants covered by the regulation




     Many comments have criticized the omission of carbon




monoxide  (CO), nitrogen dioxide  (NO ', Hydrocarbons  (HC),




and photochemical oxidants  (Ox) from the regulations.  As




indicated on July 16, 1973, and August 27, 1974, and




in previous actions involving indirect, source review




(38 FR 29893 at 29894, 39 FR 7270 at 7272, and 39 FR




25292 at 25295), existing mathematical modeling proce-




dures are not adequate to determine rhe impact, prior to




construction, of individual sources on air quality

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                          - 22 -

concentrations of reactive pollutants (NO,, and Ox) .

These pollutants are formed in a complex atmospheric

reaction which is dependent on a number of variables such

as temperature, humidity, solar intensity, concentration

and chemical reactivity of hydrocarbon precursors, and

concentration of nitrogen oxides.  Diffusion/photochemical

models are still in the research stage and generally have

not focused on the impact of individual sources.  There-

fore, the only presently available technique for relating

emissions to air quality ::or these pollutants is the area-

wide proportional model used for demonstrating the adequacy
                      12
of control strategies.

     The proportional model assumes that air quality is

proportional to emissions in the area.  To determine how

much emissions can be increased without increasing ambient

air quality levels by more than a given increment, it is

necessary to know at some point in time both the air

quality and the emission levels in the area involved.  The

permissible emission increase is then equal to the allowable

percentage increase in air quality levels.

     As indicated above, the air quality data which must

be available in order to use the proportional model are

-------
                         - 23 -



very limited in presently clean areas (even more so than




for TSP and S0_).  Furthermore, the lower the levels are



of identified emissions or air quality,  the less accurate



the results that can be obtained from using the proportional



model.  In very clean areas with virtually no baseline




emissions, the addition of a major source may increase



emissions in the area by several orders of magnitude.  In-



creasing available air quality data (assuming that such



data are available) by several orders of magnitude would



yeild highly questionable results, for several reasons.



First, the accuracy of air quality data at low ambient



levels is very poor.  Multiplying very small air quality




levels by several orders of magnitude multiplies the



substantial initial range of error by a similar amount.



Secondly, if air quality is presently below the detection



limit of the measurement method, no prediction can be



made  (i.e., the emission increase would be multiplied



by zero).  Finally, there are natural sources of hydro-



carbons which contribute to the photochemical reaction;



however, the magnitude of these emissions cannot be



adequately quantified at this time.  Thus, identified



emission levels in "clean" areas may be far less than

-------
                         - 24 -




actual emission levels contributing to the air quality in



the area.  In contrast, the proportional model is adequate



for control strategy development in urban areas where



measured air quality data are available and the aggregate



impact of many identified sources is being anlayzed.  How-



ever, it is inappropriate for analyzing the incremental



impact of individual new sources, particularly in "clean"



areas.



     Although CO is stable; and emissions can be ade-



quately related to air quality, CO is almost exclusively



emitted by mobile sources (85% in 1970).  Therefore, in



order to treat CO in the same manner as TSP or S0_, signi-



ficant deterioration considerations would need to be in-



corporated into EPA's indirect source review procedure



(39 FR 25292).  However, Congress has recently expressed



reservations about the indirect source review program



by prohibiting EPA from using fiscal year 1975 funds for



any program which could restrict parking facilities.



Even  if  the question of indirect source review is favorably



resolved, only CO can be adequately dealt with through



this  program.



      Other factors which mitigate against the need  to



specifically  include the automotive pollutants under these

-------
                          - 25 •-



regulations are as follows:



     1.  The Federal Motor Vehicle Control Program will



result in sizeable reductions in emissions on a nation-



wide basis for CO and EC for many years into the future.



This will be true even if the auto emission standards



are frozen for 5 years at the level presently required in



California, as the Administrator has proposed in his re-



commended changes to the Clean Air Act.  That is, the



nationwide emissions of CO and HC will be continually



reduced through the mid-1980's, and the effect of any



suspension of the present statutory standards would only


                                                 1 8
reduce the rate at which emissions are decreased.



     2.  A basic requirement for sources subject to the



regulations is the application of Best Available Control



Technology (BACT).  The Federal Motor Vehicle Control



Program accomplishes this for individual motor vehicles.



New source performance standards (NS?S) have already been



established under Part 60 of this chapter for many of the



source categories subject to the regulation.  Where practi-



cable, emission limitations for CO, NO , and HC have been
                                      X.


promulgated for those sources presently subject to Part 60.



Although some of the source categories are not yet included

-------
                          - 26 -



in Part 60, either (1)  those that are not covered are



not significant emitters of CO, NO ,  or HC; or (2)
                                  X


control technology for these pollutants is unavailable



or an emission limitation is impractical (e.g. since HC



emissions from coke ovens cannot be adequately measured,



a numerical HC emission limitation is not feasible for this



type of source).



     3.  At ambient air quality levels for CO approaching



the national standards, the only known or suspected effects



are those relating to human health.  At such levels, there



are no known effects on plants, animals, materials, visi-



bility, or other non-health related effects. With respect



to the health effects of CO, the National Academy of Sciences



has recently concluded that "(o)n the basis of data avail-



able at this time, we cannot identify any population group



that would be adversely affected by carbon monoxide ex-

                                                         19

posure from ambient air if statutory standards are met".



     An additional step which could be taken to minimize



emissions of CO, NO , and HC appears to be in the area of
                   X


minimizing vehicle miles of travel (VMT).  Plans for re-



ducing VMT and minimizing future VMT growth have been



developed as part of the Transportation Control Plans  (TCP)



submitted by the States or promulgated by EPA.  Since the



TCPs  focus on  major metropolitan  areas, the  flexibility  avail-



able in designing these plans would be more limited when applied

-------
                          - 27 -



to rural and outlying areas.  It is clear, however, that



comprehensive transporation  planning offers an appropriate



mechanism for minimizing VMT growth in such areas.  It



is not clear, however, how EPA might become involved in



comprehensive transportation planning throughout the



country under these regulations, although states may



wish to consider such an approach when developing their



own plans to prevent significant deterioration.  States,



of course, are not precluded from including other more



comprehensive measures for dealing with HC, CO, and NO
                                                      X


in their own plans.



     Some difficult additional questions arise as to how



this concept of VMT minimization could be incorporated



into these significant deterioration regulations.  Would



the addition of a VMT increment, similar to the air



quality increment approach used in these regulations, be



appropriate?  How would it be enforced?  The Administrator



has solicited additional comments on this issue and may



modify the regulation at a later date if workable pro-



cedures in this area can be developed.



VI.  Sources subject to review



     The 18 sources categories which are covered by the



regulation, except for fuel conversion plants, are the

-------
                          - 28 -



largest present emitters of SO- and TSP on a nationwide


      20
basis.    Fuel conversion plants (coal gasification and



liquefication, oil shale processing, etc.) were included



due to their significant growth potential, particularly



in presently clean areas.  The air quality impact of



average-size sources subject to review is analyzed in re-



ferences 10 and 16.  The air quality impact of sources



not included in the 18 categories is taken into account,



since the total air quality deterioration above the base-



line is taken into account when an application to con-



struct a new source in one of the 18 categories is



reviewed.



     Although the preconstruction review of smaller



sources is not so critical during the initial phase of



this program and such review would contribute greatly



to the difficulty of initial implementation of the



program, inclusion will become more important as the air



quality approaches the

-------
                            -  29  -

allowable increment.  Therefore,  the Agency is considering

the addition of'sources to the list, perhaps using the addi-

tion of sources subject to the new source performance standards

under 40 CFR Part 60 as a way of "phasing in" additional sources

to be covered by these regulations.

VII. Air Quality Monitoring Requirements

     The July 16, 1973, proposals included a provision re-

quiring that source owners must install air quality monitoring

instruments to assess the impact of their facility.  This provi-

sion was not included in the final regulations.  The accuracy

of the measurement methods in relation to the air quality

increments and the year to year variability of air quality
                                                           12
data severely limits the usefulness of the data collected.

In addition, the use of air quality monitoring to determine

whether the applicable increments are being maintained assumes

that the baseline air quality from which deterioration is

measured  (i.e., 1974 air quality) is accurately known.  As

indicated in Section III.5 above, such baseline data are not

generally available.  Baseline air quality data are not needed

in order to implement the regulations, since significant

deterioration is defined in terms of air quality increments

rather than absolute air quality levels.

     In actual practice, it is anticipated that assessment of

the available increment will normally be accomplished through
                                                     21,22
an accounting procedure whereby atmospheric modeling      of

individual sources will be used to keep track of the availeble

-------
                            -  30  -




(or "unused")  increment as sources  and emission are increased




or decreased.   After a source has been given permission to




construct based upon a diffusion model, it would be very




inequitable to require the source to shut down because the



EPA or State approved model was inaccurate.  Therefore, air



quality data are not needed either to define an air quality




baseline or to assess the amount of deterioration that has



occurred.




VIII.  Impact of the regulations on general growth and develop-



       ment



     In general, the impact analyses that have been performed



focus on the Class II areas, since the Class I increments are



intended to prohibit all significant growth and no new re-



strictions are created by the Class III "increments."  Reference




9 is a summary of the impacts of the various options proposed



on July 16, 1973, and is based on the date contained in References



7, 8, 9,  and 10. Alternative I discussed in these references



(the single air quality increment plan) is virtually identical



to the final Class II increments.  Additional information on



this issue, including a discussion of whether the regulations



might inhibit development of new communities and increase




urban sprawl and congestion, is contained in Reference 23,



pp.  8-13.



IX.  Impact on power generation and new energy sources



     Reference 15 provides the basis for concluding that a



1000 MW power plant will generally not exceed the Class II

-------
                            - 31 -




increments.  This reference also provides the basis tor in-




creasing the Class II increment for S02 r'rom 300 ug/m^, maxi-




mum 3-hour average, to 700 ug/m3.



     A study was done to determine whether the size of a




power plant that could be constructed in a Class II area



would be affected by the use of flue gas scrubbers to meet



the new source performance standards  (NSPS).  It was concluded




that the ground level concentration resulting from a cold



scrubber plume would be increased by 20-80%, depending on



°the meteorological conditions assumed, as compared to  an



unscrubbed, and therefore warmer, plume.  However, for a hypo-



thetical 1,000 MW power plant meeting NSPS with a scrubber




and assuming no plume reheat, the predicted concentrations



for specific meteorological conditions in the upper Ohio



valley were still well within the Class II increments.



     Reference 16 discusses the long-range transport of pollu-



tants, particularly in relation to the violation of the Class



I  increments by a power plant in an adjacent Class II  area.



It is apparent that a 1000 MW power plant can endanger the



Class I increment for S02 at distances of 50-60 miles  down-



wind, depending on the persistence of poor meteorological



conditions.



     Reference 23, pp. 21-23 summarizes the impact that the



Class II increments  (equivalent to the original Option #1)



would have on the development of new sources of energy.

-------
                            -  32 -





X.   Interstate boundary conflicts



     Calculations have shown that because of the small air



quality increments specified for Class I areas, these levels



can be violated by a source located many miles inside an



adjacent Class II or III area.  For example, a power plant



which just meets the Class II  increment for SO,, could under



some conditions violate the Class I increment for SO,, 60 or
                                                    £


miles away.  Under the significant deterioration regulations,



a source would not be allowed to construct if it would violate



an air quality increment either in the area where the source



is to be located or in any neighboring area in the State.



Therefore, wherever a Class I area adjoins a Class II or III



area, the potential growth restrictions, especially for power



plant development, extends well beyond the Class I boundaries



into the adjacent areas.  A similar situation exists, to a



greater or lesser degree, wherever areas of different classi-



fication adjoin each other.  Therefore, the area with the



less restrictive classification should include an additional



area at the periphery where it is clearly recognized that



development will be somewhat restricted due to the adjacent



"cleaner" area.  As a result, a Class I redesignation could



be fairly limited in size, yet the adjoining Class II or Class



III areas would need to cover a substantial area in order to



fully utilize the Class II or III increment.  Again, it



should be clear that the Class II or III increment could



only be fully utilized toward the center of the area and that

-------
                            -  33  -




at the periphery, permissible  siting of new sources will be




dictated by the adjoining Class I area rather than the Class




II or III increment.



     The distance a large source would need to be located




away from a Class I boundary is more dependent on the



meteorological conditions in the area than the size of the



source.  Where very long pollutant travel times from the



source to the receptor are involved, the assumptions concern-



ing the persistence of wind direction ana atmospheric stability



are critical.  At some point,  it can be assumed that a receptor



will be virtually unaffected by a source, regardless of the



source strength, since the critical meteorological conditions




would not be expected to persist long enough to move the pollu-



tants from source to receptor for any significant period of




time.  This distance is, of course, dependent on local



meterological conditions, but for most areas the maximum



distance would be 60 to 100 miles.




     The regulations include provisions for dealing with



problems created when a State or Indian Governing Body wishes



to designate one or more of its areas in such a way that it



will have a negative impact on other States or Indian Reserva-



tions.  These regulations provide that a State or Indian



Governing Body must take into account the effect of proposed



redesignations on other States, Indian Reservations, and



regional and national interests.  Where no State or Indian



Governing Body protests the redesignation of another State or

-------
                            -  34  -




Indian Reservation,  the Administrator will only review the




redesignation to determine whether it is arbitrary and




capricious.  However, where a State or Indian Governing



Body protests a redesignation to the State proposing the



redesignation and to the Administrator, the Administrator



will take an expanded role of review in which he will balance



the competing interests involved.




XI.  Best available control technology



     In the original proposal, two alternative definitions



of Best Available Control Technology  (BACT) were discussed.



Under both alternatives, a case-by-case review to determine



BACT was required of each source for which new source performance



standards were not applicable,.  Under the first alternative,



the attainment of new source performance standards  (NSPS)



promulgated pursuant to section 111 of the Act would be equiva-



lent to application of BACT for all sources except for sulfur



dioxide emission from fossil fuel-fired steam electric power



plants:  for these plants a C5ise-by-case review was required



to determine if emissions could be reduced to below NSPS,.



Under the second alternative, fossil  fuel-fired steam electric




power plants were treated like all other sources for which



NSPS are applicable.



     In the final regulations, the second alternative is



incorporated:  power plants would not be subjected to the



special BACT review because requiring such a review would be



inconsistent with the NSPS.  Further, the requirement for



application of BACT for control of hydrocarbons, oxides of

-------
                            -  35  -



nitrogen, and carbon monoxide has also been deleted because




this requirement was inconsistent with the restriction of




these regulations to particulate matter and sulfur dioxide.




As discussed in Section V, BACT for these pollutants is already




required, to the extent presently feasible, for the 18 source




types subject to review.




XII. Initial classification and criteria for reclassification




     There was considerable divergence of opinion over the




initial classification of all areas.  Industrial groups




generally supported an initial designation of Class III so




as to minimize disruption of projects scheduled to commerce




construction in the near future.  Environmental groups supported




an initial designation of Class I, fearing that a Class II




or III designation would permit air quality deterioration of




some clean areas before States could act to redesignate areas




to a more restrictive classification.  The Administrator con-




tinues to feel that an initial Class II designation repre-




sents the most reasonable compromise between these widely




differing positions.  Also, since the regulations apply only




to sources which commence construction after June 1, 1975,




the Administrator feels that this deferral should reduce




disruption to the industrial sector while permitting States




sufficient time to consider reclassifying any area either to




Class I or III before requests for approval must be acted upon.




     In order that the Administrator will have an adequate




basis for determining whether an application to redesignate

-------
                            -  36  -





an area should be approved or disapproved,  the regulations




require that the necessary information be a part of the hear-




ing record on the proposed designation.  Specifically, the



hearing record must show that the social, environmental, and



economic effects of the proposed redesignation have been



evaluated for the area being reclassified as well as for



adjacent areas and that regional and national interests have



been considered.  EPA will disapprove a proposed redesignation




if the State has not properly examined the effects of the



redesignation or has arbitrarily and capriciously disregarded



such effects.



     It is not anticipated that there will be large scale



redesignations to Class III, for several reasons.  First,



the initial Class II increment will accommodate most moderate,



well controlled development, as discussed above.  Secondly



since a State must fully discuss the reasons for a proposed



redesignation at a public hearing, a State that proposes a



redesignation to Class III without showing a definite need



for such redesignation would likely meet with considerable



resistence at the public hearing.  Finally, should a State



submit such a proposed redesignation without adequate justi-




fication, EPA would disapprove the proposal as having arbitrarily



and capriciously disregarded the environmental effects of



the redesignation.

-------
                            -  37  -
XIII.   Effective date for source review dnd determination of
       significant deterioration
     The December 5, regulations establish the air quality
concentration during 1974 as the baseline for determining
whether significant deterioration has occurred.  The Sierra
Club has contended that significant deterioration should be
measured from May 30, 1972, the date that the implementation
plans were to be approved or disapproved by the Administrator.
Because of the far-reaching implications of these regulations
on growth and development, it is important that the allowable
deterioration increments be wisely used and that the allocation
of limited air resources be planned and managed with full con-
sideration of the impact on future growth and development.  To
make the baseline for measuring deterioration retroactive to
May 1972 would require that the effect of sources commencing
construction since that date be counted against the allowable
increment.  Yet the States, in granting such sources permis-
sion to construct, had no opportunity to consider the full
implications of their decision (such implications being only
now available).  Furthermore, to subject sources constructed,
or which started construction, during the period from May 1972
to June 1975 to the significant deterioration requirements
(which could result in clofeing those sources violating the
allowable increments) would, in the Administrator's judgment,
be grossly unfair.
     The Sierra Club has suggested that as a minimum, such
sources be required to install BACT on a retrofit basis.

-------
                            - 38 -

There would be relatively little benefit to be gained by

such a requirement, since the overwhelming majority of emis-

sions from sources subject to significant deterioration review

have been subject to new source performance standards since
            12
August 1971.    New source performance standards have been

in effect for the following sources commencing construction

after August 17, 1971:  fossil fuel fired steam electric

generating plants  (by far the most important source category

both in terms of the number of new plants constructed and in

terms of emissions of both pcirticulate matter and SOo) , in-

cinerators, portland cement plants, and sulfuric acid plants.

NSPS have been applicable since June 11, 1973, to petroleum

refinery catalytic regenerators and process gas combustion

and steel mill basic oxygen furnaces.

     For those sources commencing construction since May 1972

and which are not subject to NSPS, emission control equipment

has, in most cases, been incorporated as part of the original

design.  Although such equipment may be quite efficient and

may represent a significant investment, it may not be equivalent

to BACT.  The retroactive application of BACT could then re-

sult in scrapping virtually brand new control equipment in

order to obtain only modest additional emission reduction.

In the Administrator's judgment,  this result is both unwise

and inequitable.

-------
                                    - 39 -
                                  REFERENCES


   1.   "Sierra Club et al  Litigation  -  Significant  Deterioration,"
        B.  J.  Steigerwald, September  27,  1972.

   2.   "Draft Summary  Report on  Suspended Sulfates  and Sulfuric Acid
        Aerosols,"  EPA Office of Research and  Development, March 1974.

   3.   "Summary of  Responses Received Regarding  the Prevention of Significant
        Deterioration."

   4.   "Summary of  Responses Received Regarding  the August 27, 1974, Proposal
        to  prevent  Significant Deterioration of  Air Quality."

   5.    "Summary of State  Responses on  'Significant Deterioration'  Proposal."

 * 6.   "Sierra Club Proposal," November 8,  1973.

   7.   "The Impact  of  Proposed Non-Degradation Regulations on Economic Growth,"
        Volumes 1 and  2, Harbridge House, Inc.,  November  1973.

   8.   "Implications of Non-Degradation Policies  on Clean Air Regions:  A Case
        Study of the Dallas-Ft.  Worth AQCR (215),"  U.S. Dept. of Commerce,
        May 1974.

   9.   "Analysis of the U.S. EPA's Proposals to  Prevent Significant Deterioration
        Relative to the Development Outlook for  New York  State," New York State
        Department  of  Environmental Conservations October 1973.

  10.   "Impact of the  Proposed Non-Degradation Alternatives on New  Power
        Plants," TRW,  Inc.,  September 28, 1973.

* 11.   "Economic Growth and Development  Impacts  of Proposals to Prevent
        Significant Deterioration of Air Quality."

* 12.   "Scientific   Factors  Bearing on  Regulatory Policies to Assure Non-Degradation
        of   Air Quality."

* 13.   "Availability of Air Quality Data  in Areas Generally Below the NAAQS."

* 14.   "Technical Data in  Support of  Significant Deterioration Issue."

* 15.   "Non-Degradation and Power Plant Size," J. A.  Tikvart, August 12, 1974.

* 16.   "Significant Deterioration in  Zone I Areas and the Relative  Location of
        Power Plants," J.  A. Tikvart, October  15, 1974.

* 17.   "Discussion  Paper on  the  magnitude of the Class II Increment in the
        Significant Deterioration Regulations."

  18.   "Air Quality Impact of Alternative Emission  Standards for Light Duty
        Vehicles."

-------
                                   - 40 -
  19.  "Air Quality and Automobile Emission Control,"  National  Academy of
        Sciences, September 1974, Volume 1, p.  32.

* 20.  "Emissions of Sources Subject to Significant Deterioration Issue."

  21.  "Guidelines for Air Quality Maintenance Planning and Analysis,
        Volume 10:  Reviewing New Stationary Sources," EPA, September 1974.

  22.  "Guidelines  for Air Quality Maintenance Planning and Analysis,
        Volume 12:  Applying Atmospheric Simulation Models to Air Quality
        Maintenance Areas," EPA, September 1974.

  23.  "Findings of Task Force on Significant Deterioration," R.  G.  Rhoads,
        December 20, 1973.

  24.  "The Largest Annual Average,, Maximum 24-hour and Minimum 3-hour
        Concentrations of Sulfur Dioxide Produced Per Year by a Modern
        1000-MW Electric Power Plant Meeting the New Source Performance
        Standards for Sulfur Dioxide Emissions," Enviroplan, Inc., 1974.
         References with an asterisk are reprinted  as  attachments  to  this
         document.  The other references, which are too  lengthy  to reprint
         as part of this document, are available for public  inspection  at
         the EPA Freedom of Information Center, 401  M. Street, S.W.,
          Washington,  D.C.,  20460.

-------
                               Reference 6



SIERRA CLUB PROPOSAL                                     8 Nov 1973


     The plan proposed by the Sierra Club to prevent significant deterio-


ration of air quality is based on a volume averaging or mixing zone type


of approach.  (Attachment 1 is the testimony given by Mr. L. Moss at Washington)


Under this plan the pollutant concentrations would be limited to certain


specified incremental levels in a spheroid surrounding the point source.


Figure 1 depicts the situation.  Table 1 shows the allowed increases in con-


centration allowed.  In addition to the incremental increases in the volume


around the sphere, they also recommend that the total emissions over an

                                             2
AQCR be limited to increases of 1 Ton/yr/mile  for all criteria pollutants

                              2
except CO where 20 Ton/yr/mile  would be allowed.


Al 1 cwed_ Emi;;sions Under the Si erra Club Proposal


     The actual allowed emissions under this type of plan will vary from


location to location but if some simplifying assumptions, are made, it is


possible to compute the emissions allowed under the increment. (Attachment 2


shows info nation supplied by Dr.. M. Williams on behalf of the Sierra Club.)_


For purposes of their discussion of potential impact the Sierra Club assumed:


     1.   an annual wine! speed of 6 m/sec (13.2 ra/hr) and


     ?,   a 250 m stack height.


They felt chat both of those assumptions were reasonable for power plants


in the southwest.  While this ts true, it appears that the annual wind speed


may be too high for many areas and the "allowed development' less.


     Following the Sierra Club assumptions the maximum allowed emission rate


is 5.35 T/day or 1950 tons/year.  This is limited by the annual increment
 * ,    -3
of 4 ug/m .
                                   41

-------
                                          42
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-------

43
TABLE 1
INCREASES IN POLLUTANT
ALLClvJ') UNDER SILRKA
cor;ccNTRAV
CLU3 PRul'OS
ALLOWED INCREASE (ug/M
POLLUTANT
TSP
so2
HC
N0x
CO
1 HR
100
TOO
100
100
2000
24 HR
50
50
50
50
1000
; ON*
AL~
3) FOR
ANNUAL
4
4
4
4
80
* All  concentrations are averaged over a one kilometer sphere
around the source

-------
                                    44
Req u ired LcveIs of _C o n_tro 1_ Joohno!ex iy



     In their presentations at. public hearings and in written comments, the



Sierra Club indicated that a large amount of industrial  development would be



allowed. (Attachment 3 shows development the Sierra Club claims is allowed.



Attachment 4 is material submitted by Dr. M. Williams to support these assump-



tions,)  Their assumptions on control technology were reviewed by Control



Technology, OAWP which stated, "For the most part the Sierra Club has assumed



the host of all possible situations—an abundance of natural gas, raw mate-



rials wiuh low pollution potential, and an ability to develop any level of



control technology.  Many of these assumptions are unrealistic particularly



in view of the fuel shortage.  Costs  of control have received no considera-



tion at oil."  Table 2 shows some of the plant types, analyzed under this



procedure, the Sierra Club assumptions on control technology and comments



of EPA engineers.



     The impact on coal fired power plants and petroleum refineries is



e^p^c-'^lly sever*"-;.  For example, if NSPS were applied to a cool fired power



plant the maximum plant size would be 52.8 MW.  If state- of the art stack



gas cleaning (80-05% sufficient) were combined with O.b4% Western coal, the



maximum allowaole plant size would ba 200 MW.  The Sierra Club claims that.



97% SCL removal on 0.5% western coal  is available and as such the sulfur



dioxide limitation would allow a 2200 MVJ power plant to be built.



     A similar situation exists 'if the oxides of nitrogen are considered.



A plant which meets NSPS (0.7 Ibs NO/106 BTU) would be limited in size to
                                    A


about 94 MW.  If NO  emissions are limited to 0.45 lbs/106 BTU (a level



possibly attainable) the plant would be limited to about 150 MW.  If NOV
                                                                       A

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-------
                                     46
if further reduced to 0.3 lbs/10  BTU (a level possibly attainable by one



manufacturer) the maximum power plant size would be 220 MW.



     Thus the maximum coal fired power plant which could possibly be con-



structed under the Sierra Club proposal using loA'-sulfur coal, stack gas



cleaning and ideal furnace design for NO  control is 200-220 MW.  In areas
                                        A


where very low sulfur coal is not available, the maximum plant size would



be less than 100 MW.  Current planning of coal fired power plants estimates



that the average plant size is to be about 600 MW.



Economic Impact of Sierra Club Proposal



     It is extremely difficult to estimate the economic impact of the Sierra



Club proposal, because the actua" allowed emission rate will vary from loca-



tion to location.  However, it appears th:»t many industries and some light



development would bo able to bo undertaken withc-.it a substantial incrocir-c



in cost over what now is required.



     The Sierra Club proposal cioes_ appear to have a \ery substantial imptct.



on the power and oil industries.  If, as described previoi'sly., the maximum



coal fired power plant size is limited to 220 "'.K1., constraining coal fired



plants to these levels would result in either a rapidly decreasing rel'ioi'.ce



on coal and a switch to nuclear po'ver or very large numbers of very small



power plants at a much higher cost.  In dddltion to the-.1 higher capital cost,



the resulting increases in distribution and coal hauling facilities would



also result in considerably higher costs.



     The restrictions applied to the size of new or expanded oil refineries



would also impose a substantial economic burden,  It would result in greater



numbers of small refineries with resulting higher transportation and

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                                      47
distribution costs.  In addition, to build eve;" these small  refineries
would require the consumption of scarce natural gas and thus divert this
from other uses.
     Severe limitations are also placed on conventional copper smelters.
Maximum allowed size under the Sierra Club proposal is 88 T/day or 32,000
T/yr; average design size for smelters is 100,000 T/yr.  The hydrometalur-
gical processes are not available for all types of copper ores.
Technic_a]_ Piffjcul ties i n Implementfng Sierra Club Proposal
     One point emphasized in the Sierra Club proposal was that areas where
existing sources could be controlled there would be much greater room for
the expansion of new industrial processes.  While this is probably true, to
some degree, there are two major technical problems associated with carrying
out the type of proposal suggested by the Sierra Club.  The  first of these
involves the monitoring of pollutants at the low levels and  in the volume
suggested by the Sierra Club.  Current instrumentation for sulfur dioxide,
niv.roqen oxides •, and hydrocarbons operating at stationsrv ground level moni-
toring stations is not sufficiently accurate to distinguish  the proposed
Siena dub increments from random raise associated v/ith the day-to-day
operation of the instrument,  To adequately handle th^ type  of monitoring
required by the Sierra Club would require that monitoring be done from
instrumented helicopters or aircraft.  It is not presently possible to
perform this type of analysis.
     Monitoring could possibly be carried out by remote sensing devices such
as the lider but presently these also do not have sufficient accuracy.

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                                      48
     The second major difficulty with the Sierra Club proposal lies with
the ability to do the type of modeling required.  While as the Sierra Club
states the modeling required under their proposal for a single isolated
source is relatively simple, the extension of modeling to multiple sources
areas becomes extremely difficult.  The current gaussion diffusion models
were developed to predict, concentrations at a point on the ground or in
space.  They are presently accurate to within a factor of two half the time.
The extension of these models to integrate the concentration in a spheroid
some distance removed from the source does not presently appear reasonable.
From an enforcement viewpoint the capability for using reductions from
existing sources probably only exists In the very near vicinity of large
isolated sources which can reduce emissions considerably.
Admi nl s trail ve D;'t f f i cuHi c-s i n Imp! ement i nq SJ_erra_ Cl_i'_b_ Proposal
     The volume average concept espoused by the Sierra Cli.o i:-, an entirely
different process of air quality if'anegem^iit than tbM. currently ongoing for
the attainment ana mp.intfc-iicirice of NAAQS.  To handle both the attainment and
mainte.'.rjncu of NAAOS by means of ground levels concentrations and to  prevent
significant deterioration via the volume average techniques would appear  to
drastically ccpiOuund the administrative burden.
     In addition, the source size selected by the Sierra Club as requiring
review would impose a greater burden on regulatory agencies.  The size
selected was 1 Ton/yr for all pollutants except. CO end 20 Tons/yr for CO.
This size would include all commercial and industrial facilities, develop-
ments of 50-100 homos heated with oil or 75-100 ho.r,cs heated with gas plus

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                                   49
all highway, aiv.l many streets.  It  is impossible  co estimate the number ot



sources whit.li would require review but. it would be a very large increase as



most state regulation cell for review only if the source is greater than



100 T/yr.





Summary



     The pi on proposed by the Sierra Club allows  for small increases in



concentrations over a 1 KM sphere around the. source.  Their calculations



show that this plan would allow sources in a clean area to emit 5.35 T/day



(1950 T/yr) of any pollutant.  Assumptions made by the Sierra Club in



estimating the impact were beyond the state of the art for oil refineriess



power plr.ins and coke ovens.  Monitoring one1 mode ling techniques are not



available i/hiui can be used to keep track of changes in baseline air quality



to alloy/ fj»- inductions in emissions from existing sources.  Plan would



impose adminif Lrc.live buroej'S in using an entirely different procedure for



attainment o.-id maintenance of NAAQS and prevention cf significant deterio-



ration.

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                                      50

COMMENTS ON SIERRA CLUB PROPOSAL
1. Restrictions on Coal Fired Power Plants
     In area where low sulfur fuel (0.5%) is available, new coal fired
power plants would be restricted to 200-220MW assuming that NO  can be held
                                                              A
to 0.3 Ibs/ 10  BTU(may be poosible).  Where low sulfur fuel is not
available plant size would be less than 100 MW.  Both of these sizes are
generally not economical facilities.   Reasonably sized additions to
existing plants may be possible.  Basic thrust of the proposal seems to
be that all new coal fired power plants will have to be built only near
existing facilities.  No consideration has been given to the cost of
control.
2. Restrictions on Oil Refineries
     New refineries would be limited to 65-100,000 bbl/day if all possible
technology is used and no consideration is given to cost.  Since current
construction and mosification averages 150,000 bbl/day, the most feasible
location for new refineries jeems to be near sites occupied by existing
refineries which can be very well controlled.
3.  Monitoring Ability
     Capability decs not currently exist to routinly perform the monitoring
needed to carry out the Sierra Club proposal.  To require that this
monitoring be carried out by aircraft or remote sensing devices is not
presently feasible and if it be becomes feasible would be extremely
expensive.
4. Modeling Ability
     Capability does not exist to perform the type of volume average
modeling in mul tip]? 'scu-'ce areas seemingly required by the Sierra Club

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                                     51
to the degree of accuracy the proposal  would require,




5. Administrative Problems



     Current state strategics for attainment and maintenance of ambient



standards requires conrol technology and plans based on ground level



concentrations.   The Sierra Club proposal  would require a separate procedure



and the resultant monitor ing, modeling  etc.  to be carried out for new



sources.   There  does not seem to be any direct comparison between the



two approaches and a large additional workload would likely result.

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                              Reference  11
     ECONOMIC GROWTH AND DEVELOPMENT IMPACTS OF PROPOSALS TO PREVENT
                SIGNIFICANT DETERIORATION OF AIR QUALITY
     This paper attempts to answer some critical  questions on the extent

and nature of any economic growth limitations,  altered development

patterns, and dislocations that may result from final  promulgation of

three of the four proposed regulations to prevent significant deterior-

ation of air quality.  The conclusions are based upon  the findings of

four studies undertaken by EPA, the Department  of Commerce, the Depart-

ment of the Interior, and the State of New York.   The  extent to which

the studies of selected industries and regions  reflect the impact upon

the nation as a whole must be viewed with caution.  Projected growth,

site peculiarities, changing economics, energy  use, technology and

modeling techniques for assessing air quality impacts  could all alter

the findings.  We have identified these factors where  they are relevant.


I.  Summary of Findings

  A.  Alternative I:  Ambient Air Quality Increment Plan

    1.  Regional Growth Impacts

      a.  The proposed increments appear adequate to allow projected

economic growth in most urbanizing areas to 1980, while significant restric-

tions and/or altered development patterns will  be experienced by 1990.

      b.  Dispersion of development in urban areas in  order to reduce

pollutant concentration could increase transportation-related emissions.

    2.  Isolated Industrial and Energy-Related  Sources

      a.  Careful siting and the use of tall stacks would allow most

isolated industrial development.

                                   S2

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       1 > .   ; . h I i I i ' )i i i I.  e'. ;s t s  ale i nij >' : e( I  I;1 >ei) a n> ",' . - . ) > ;
if. in  e • dar  !:o comply w>tii  the eir guaj.iay inci.va • it it  must:
         t* bui.lo a tailor  st..ck
         o apply stack gas scrubbing for SOp control
         o incur  transportation and land costs where associated
           iridustr j ,;1  activities :nusL;  be separated geographically
           or  where  it uiuo t  move larther from its market,
         f> scale; cio.v'i  its  plnnt.
       c ..   Jncrei^,- at , ; 1  c-eats imposed by  the air quality  JncreramLS
       : ,c -; .  cas^:  j-ej, : ! /• l\  sruil.l .   Incremental costs  Tor ,~>a-\cr
plant:-,  x.liich I'l.-ot X'SPS  or v/nsre power plant size must  be limited
fiub: b/  i.j.ajly.  'iatl  stc.c",s v/ould be a  mjch lower cost alternative
v/c.i. %  I-'-'-';.1  ciii.(.A\'' in  such situations,
      o,   J"i.nirjg o^era i ic>ns afiSL'clr.rted  \vitii new cement / copper,
and  i re n aad. otcraJ plai-ts violate the proposed TSP  increment in

  B.  A! iarr.  i v-   El:   }yni ss aois tJ.-nsi/ty P-I":
       a.   Grov.aaa restrictions can be  severe
         o Dj>3 las-Fort  .Vortli violates  the TSP increment
           in 6 years .
         o Dev"l op> "»ont  is  restricted in  most of New York.
           State by 1980.
       b.   The impact on regional growth varies widely wi th the
sixo o/  the overaglng  area and the existing emission baseline.
Region;;!  inequities  arise with averaging areas significantly
smaller  or larger than the proposed 10,000 square miles.
       c.   Po>.A-r plants absorb a major portion of the allowable
increments in giowth areas, liov/ever,  the restriction of access-
ible etcotiic i. o\.'cr  in turn restricts industrial and commercial
de-- :'loy ,  -na .  Growth restrictions can be severe in such
in.J a r 'a .:. .

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                            54
       d.   Norlhpj i. ("irv.'i  S'l.jin- power complex  •   Id bo
res 1 r it ! c -d.
     2,   ']';o~Jat_f d ."* > <.';'••. M ' L! 1 .JILML 1''"1- r9Y~Iic'J'^i °' <.'(J.uZ.c-L'\i
       a.   An emission  ] i mj 1 ation p.l an impact,;  !.,;>st heavily
upojj powcr : 3"I ;j nl. 13.
       b,   la the abseno •  of baseline aberrations industrial
grov/th ];^/;')ected i.o 19:-jO  would not hu affected by the increment.
         c-  v/ith the exception of power plants,  no new  industrial
          ,sources violate the increment
         «p  most growth  is  in priority I and II regions and
           thus i.u riot  covered by this regulation as proposed.
   C.   A1 L_e r n i t_i \-_o _ IV : _ _ A r e a Classi _t i_c: Qt.i_on_ S_c \ i enie
       Most oi the1 comnie.ij Is pertinent to  Alternative I apply
to IV.  However, it  is difficult to evaluate Alternative IV,
because ve can not anticipate how states will classify  legions.
     -L •   Hen ion61	Orowi ij_ _[1L'LX4£^.S
       a.   Maintaining some  areas at Zone  1 levels while
allowing reasonable and planned growth in adjacent areas
appears  to be  feasible.
       b.   A significant number of exceptions  to zone II  increments
would  be  required by 1990  in high growth  areas.
     2 •  ,Indujs^tji;\i: • 1 and  D j.er_qyj- Rel at ed Sour c e s
       a.   Zone 1 restricts  most industrial activities in  or
near the zone  with the exception of large (1000,000 TPY)
Kraft  pu]p and paper mills  and small,  well controlled power
planes  (150  MW meeting NSPS).

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                              55

II.   C' >}}f I !•• - on;;
  A.   A XC.MI u KJ j) I r ij'i  h !'«_'! oil , i n" o i •' H t'1'  L! iCj ! r.u.M i! ;  \,o ' .1 d
bo luos I  oj it'ctive  in both ] >j o: • i -'j'v.i ' >ii  cloc.n a "J r ai.d  ace v.'iiodaL—
inn  plaiiiji'u  oco':>Oin,ic i.fro~,.'trj.   Po I ~! ov/i.ng ere  tic proposed "..one
d e f i n i t .1 u • • _- :
  1.   A VUT->- retrictj N/O zouy to mninLain  r i r  ^odlity in pristine
areas.
  2.   An  -i j/(j'-'inodj u.'.e zone,  .s.iiailar to A",. Leru,. Li ve  1,  to
p^rro.n' -1: r!;..° ,. - .-;v^:~; iry/vr. rri ixl  c/?velo; •;;.;• r\+- for  .-1 ".iL.;  c:r  economic
sizes.
  3.   A tliivd zone,  a] lov/ing grov/l:h up to the r.ocond :ry
standa': '-j.-J i. o :
     a.  uJl'/.v areas  v;ith e;ic(.)pl;ions to be planned rather than
allo\7 the(i:  Lo be1 developed  p.i ece-inea3  on  Llie  } "i-.is  OL  economic
pressure.';
     b.  avo:d the  unnianagable and  uiinocesr arv burden of. grantinq
e*ACtipL j-OLi..  ' ^ iu.j-j  u^-.v ^.^^wu-^i... j.^-v»<.i.'i - - -j ''-"- a  pi .-T.r ~ c1. ''"zi'C'.*! !"•  r."1   '
  B.   rj'lie ,i n torinedj ate  zone:  should  have an exception r;:ehe;rc
which \/oj I c-  jiorin.it the  consideration  OL othc.-r socio~cc or.o;ric
tradeoffs in (a) industrial  rlant  siting  or  si:--ing  (b)  natural
resource  eevelopraerit (e.g.,  open pit  mining)  cad  (c)  colloca-
tion  of industries.   Such exceptions  should  b.' poss'_b ie
v/ithoxil TI -zoning an  entire  ai ea for degrodatioa ap  to  the
socoiidaj'y standards.   In laany cases the full  i no/• vce I up to
seeoiidarv nnctht not  ]v-  rec[U.ired, or only  a s;n;;il  pr,rtion of  the
xone  m.iqnL  lie affected  by the source.
  C.   Ta.l .1  stacks  arc- the least cost  option  for reducing ground
level  concvntrati oi:s ..
     1.  Doubling stae/..  lieight reduces groand  concentration  by
about 70  jjc'i'cent.
     2.  I1 lore strjngeni  increments v/onld be po. slblc  for indiisl
soure^s :i n  Zone  IT ir ta] 1  stacks were allovrec;.

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                                  55



    3.  The cost of doubling stack height (from 400  to  800  ft.)  is



$4MM while the cost of scrubber may be $50MM,  both for  a  1000  MW power



plant.



    4.  In cases where scrubbing is not possible,  the  incremental  cost



of scaling down from 1000 MW to 300 MW plants  is $123 MM  (per  1000  MW



of total capacity).



  D.  The air quality increments proposed for  Zone  II will  generally



provide an adequate margin for growth through  1980.  The  proposed 24-hr.



particulate increment may require further analysis.

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                            57
III.  Methodoloc
     The analyses that have been used to assess the economic
growth and development impacts of the throe alternative signi-
ficant deterioration regulations cover a v/ide range cf new
development situations.  The studies arc characterized by
two approaches: analysis of impact in specific prototype regions,
and analysis of impact on isolated new industrial and energy-
related sources.  Each approach is diecursed below:
        t
  A.  Prototype Regional Dcvclopmont
     Prototypical regional developments were identified for
study by EPA to reflect (1)  trend development in a growing
metropolitan areas, (2) resource-based development in a clean
air area and (3) development in a rural state.  The regions
which were selected for study are the Greater Boston Metropolitan
Area, the Four Corners Region and the State of Iowa respectively.
Additional information is available on two additional regions:
(a) the Dallas-Fort Worth area in a study undertaken by the
Department of Commerce, and (b) New York State, in a study done
by the State Department of Environmental Conservation.
    1.  EPA Study
        The EPA Study of Boston, Four Corners, and Iowa used
regional economic growth plans and projections to estimate
emissions.  An air quality dispersion model was employed to
estimate the ambient air quality effects of projected emissions.
Both air quality and emission estimates were then compared with
proposed non-degradation increments to determine the extent of
any potential restrictions on regional economic growth.
        This study, performed under contract by Harbridge
House and Environmental Research and Technology, used the
following  methodology:

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                           58

      a.  Planned and projected economic growth to  1980  for
each area was obtained from  several sources including the
Office of Business Economics, Department of Commerce, regional
and state planning councils, the Battelle economic  base  study
for the Four Corners Area, and updated industrial projections
from each of the major source industries.  Growth projections
were derived on a county by  county basis.
      b.  1972 emissions inventories were obtained  from  EPA.
      c.  Emissions from new sources were estimated assuming
attain'rrnt of New Source Performance Standards (NSPS) .  Published
EPA emission factors were used.  Where emission factors  were
unavailable, best available  control technology was  assumed to
lead to a 99 percent reduction in particulate emissions  and a
90 percent reduction in sulfur dioxide emissions.   No control
technology was assumed for open pit operations.  Area source
emissions for Bocton were based on emission factors developed
for the Northeastern U.S.  These factors take residential and
i_Oiiunc-j-1—Lc.i_i_ ii^ciuj.iL
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                            59
    3.  New York State
        The New York State analysis differed from the other
two in the manner in which ambient air quality projections
were made from emission estimates.  No diffusion models were
used.  A linear relationship (or rollback model)  was assumed
between emissions and ambient conditions within each county.
Ground concentrations from planned fossil-fuel power plants
were obtained from available projections.
  B.  Isolated Industrial and Energy-Related Sources*
    1.  EPA Analysis
        Sixteen major new source  categories were identified
in the proposed regulations as the major sources of S02 and
TSP.  However, in reality each major source category tends to be
associated with geographically collocated industrial activity.
An analysis was therefore performed of major source "building
blocks" composed of the base industry and collocated industrial
activity.  In addition, new towns and industrial parks were
analyzed as concentrated new components of urban growth.  The
methodology followed by Karbridge House in developing building
blocks was as follows:
      a.  Principal links between the industries, their
markets, and suppliers were identified using the National Input/
Output Table (U.S. Department of Commerce, 1969)  with appropriate
updating.  An investigation of each industry yielded information
on location decisions and key determinants of the geographic
location of related industrial activities.
      b.  Locations of the building blocks, with the except-
ion of power plants, were determined nationwide by Air Quality
Control Region using industrial growth projections from trade
journals and CBE information.  The emission contribution was
then calculated for each AQCR,  and the emission density was
estimated both for the existing AQCR and for areas the size cf
the suggested 10,000 square mile area.
*See Table I

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                             60
      c.  Ambient air quality diffusion modelling was
performed for 35 facilities of differing sizes in 10 major
source categories.  General:.zed meteorological assumptions were
used for three source categories: iron, and steel, zinc, and
aluminum (i.e., flat terrain and good dispersion character-
istics were assumed).  Seven source categories were modelled
within the three regional analyses.  Therefore we were able
to take into account both the actual meteorological conditions
        i
reflecting the worst case at a specific site (e.g., low wind
and unstable atmosphere) and any interaction with projected
area sources.
    2.  Department of Interior Study
        A study conducted for the Department of Interior by
TRW examined projected emissions from new energy facilities*
to determine if they would be allowed in an emission density
scheme.  TRW also applied generalir-'od factors indicating
the relationships between emissions and air quality for each
geographic region of the country to estimate ambient air
quality impacts.
*See Table 1

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                              61
                       TABLE I
            /
The EPA Analysis examined the 16 industries are listed below:
     c  Power Plants
     © Coal Cleaning Plants  (Thermal Dryers)
     9 Kraft Pulp Mill Recovery Furnaces
     9 Portland Cernen I Plants
     9 Primary Zinc Smelters
     9 Iron and Steel Metallurgical Furnaces
     
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                         62

IV.  Impact Analys i_s of Alt : ornat ijye_ Plans      i
     This section is divided into three parts: a discussion
of the findings from analyses of three of the four proposed
alternatives.  The State Determination alternative is not
susceptible to analysis.  The findings are divided between
regional growth implications and industrial or energy-
related impacts.
  A«  Alternatj^ve^I: Air Quality Increment Plan
    1 .  Regi ona 1 Gr owt h Impac t s
      a.,  The proposed annual EC>2 and TSP increments appear
to be adequate to allow planned and projected economic growth
in most urbanizing areas to 1980.  Some areas would be affected,
however, and the number of ereas which experience limitations
on growth would increase where greater use of high sulfur coal
by existing plants becorres essential in place of low sulfur
fuels .
                            ronr-entrations of SOo reached
      3                          3
5 ug/m  in Boston by 1980; 8 ug/m  in Dallas/Fort Worth by 1930—
both well below the proposed increments.
        • Any constraints on growth in the Boston or Dallas/
Fort Worth areas will be related to restrictions imposed by
secondary TSP standards and not to proposed significant deteriora-
tion levels.
        • Two areas could be affected by the increments in
New York State by 1980, however, the State does not find the
impact on economic development to be significant: (a) the
levels are only slightly above the limits, and  (b) resiting
of a few sources would reduce area concentrations to allowable
limits.  Moreover, because the New York State analysis did not
utilize site-specific diffusion modelling, siting and stack heights
which minimize ground concentrations were not taiken into
account and the numbers reflect higher concentrations than
those achievable.  Specifically:

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                           63
          — The lower Hudson Valley, would appear to exceed
the proposed increments by 1980.
             i. This area exceeds the proposed SC>2 increment
by approximately 3 ug/m3 because of the contribution of new
fossil-fueled power facilities brought on line by 1980.  The
increase could be even greater if another projected plant were
located in the area.
            ii. General population growth and economic develop-
ment  (SO percent increase in the number of households) could
cause the particulate increment to be exceeded by 6 ug/m3.
          — One additional area, the Greater Rochester Urban
area, would approach the allowable SO2 increment by 1980.
(Projections range from 4 to 16 ug/m3).
      b.  Many areas would exceed the proposed increments by 1990
and would experience limitations on future growth after 1990.
        • Neither Dallas/Fort Worth nor Boston would appear to
violate the increments by 1'jyu.
        ® Five areas in New York State may exceed the TSP
increment by 1990.  Increments of up to 20-30 ug/m3 are possible
based upon projected growth.
        • Approximately nine areas in New York State violate
the S02 increment by 1990.
        • Power plant siting and control technology is especially
critical if all reasonable growth is to be accommodated in high
growth areas.   Restriction of accessible electric power, which
absorbs a major portion of the allowable increment, in turn
restricts industrial and comirerical development.
    2.  Indu s t r i a 1 and Em; r cr y - gel a to d, J3our c_eg
      a.  Careful siting and the use of taller than traditional
stacks v/ould allow roost new industrial energy development.
      • The impact of the air quality increment on allowable
plant size is  highly dependent upon stack height.  As stack
height is doubled, ground concentration of pollutant is reduced
by 70 percent  (see Exhibit I).

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                          64
        • With traditional stack heights, the proposed incre-
ments for Alternative I would bo violated by: 1000  MW power
plants, large copper smelters, zinc smeJters, cement  plants,
and iron and steel mills.  (3 hour SC\_ and annual TSP standards)
                                     -?x
        « If taller stacks are used (2 times traditional  heights,
see Exhibit I), copper, cement, and iron and steel  building
blocks still violate the TS.? increments because of  associated
mining operations.  In each case the plant itself causes  no
violation but would have to locat-.e some small distance from
the mine-.  Incremental transportation costs have not  been
assessed.
        o It may be possible to reduce mine emissions below  the
increment in humid areas by wotting the site.  However, in
arid areas there is no technology for reducing mine emissions,
and a violation of the TSP increment would result.
        • The analysis is also dependent upon dispersion  model
-!C.r-;-i-lr«^x4_-J/-^v-lc, ^* f^^r-*^. .3 1 ^^r *^ ,^4- ^ s*y. ^1 ^j^, , -,v^^q 4- ^%~ ^^•^-,.^'U.,.-    7\  ^"| _, ~.l.
C-~	U.	^	-I •'	il J 	'	i- - _.	JL---J-   --  A	—	
located under poor dispersion conditions could cause  ground
concentrations two to four times greater than an identical
plant located under the favorable dispersion conditions
assumed in the modelling effort.  Thus, a fixed deterioration
increment could be considerably mere constraining on  plant
size in areas with poor dispersion characteristics.
      b.  The assumptions on fuel utilization are important in
drawing conclusions on the constraints imposed by the proposed
ambient levels.  The TRW analysis indicated that with the use
of tall stacks (i.e., 800 feet for power plants):
        11 - Power plants burning 3 percent sulfur coal with
           wet scrubbing technology would be limited  in size
           to about 1000 MW in Appalachia and perhaps 1400
           MW in the Rockies; 1500 MW plants could  be built
           in all other areas."

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                           65
        "- Power plants burning 0.7 percent sulfur coal
           without wet scrubbing technology would be
           limited in size to about 800 MW in Appalachia
           and about 1200 MW in Rockies; 1500 MW plants
           could be built in all other areas."
        "- Power plants burning 1.5 percent sulfur coal with
           wet scrubbers and 0.3 percent coal without wet
           scruVbers could be built in .1500 MW units anywhere."
       "Thus,  the  air  quality  increment  plan  does  not appear
    to be  overly restrictive,  particularly  considering  that
    in most  areas  similar  facilities  could  be sited  25-50
    miles  of one another."
      c.  Additional costs are imposed upon a new plant if in
order to comply with the air quality increment it must (a)
build a taller stack than usual; (b)  apply stack gas scrubbing
for SG2 removal (low sulfur fuel burning power plants only);
(c) increase transportation and land costs where associated
industrial activities must be sepairated geographically or it
must move further from the market;  or;  (d)  scale down its plant.
Incremental costs imposed by the air quality increment appear
to be relatively small, with the exception of power plants
forced to add a scrubber while burning fuel which meets NSPS
or power plants limited substantially in size.
        • The cost of a stack approximately quadruples as its
height doubles.  A recent EPA study shows that for a large
power plant the cost of a 400 foot stack (concrete 40 foot
diameter)  is about $1.25 MM while an 800 foot stack costs $5
MM--thus an incremental cost of almost $4 MM.
        ® The cost of adding a stack gas scrubber for SO2
control to a low sulfur coal burning power plant is about
$50 MM.  For plants which could meet NSPS without such a
scrubber,  this would be an incremental cost of meeting tho
nondegradation increment.

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                            66
        « A power plant using coal from an open mine might
also Lave to locate 10-20 miles froru the mine to avoid
violating the T3P increment.  No estimate has yet been developed
for the additional transportation cost.
        e An alternative to building a stack twice as high would
be building a plant only 3C percent as large.  For example, the
construction cost of a 300 KW power plant would be approximately
30 percent more per unit of capacity than for a 1000 MW plant.
The investment cost for a 1000 KW power plant is about $410/kw.
        t
The cost of a 300 MW plant would then be $533/kw or au incre-
mental cost of $123/kw.  Thus the cost penalty is $123 million
for building 1000 KW of total capacity in units of 300 MW rather
than one 1000 MW plant.  In view of the potential magnitude
of such additional cost it is unlikely that a plant would scale
down as long as it has the viable option of building a taller
stack.
        • A further cost of disaggregating a single large power
plant into two smaller facilities is the additional land
required for power transmission rights-of-way and other
facilities that would have to be duplicated,,  It is estimated
that 15 percent additional land would be required as a result
of a second site.  A single 3000 MW coal fired power plant
requires 12,000 acreas.  Thus an additional 1000 acres would
be required.
  B•  Alterna tiye jTIj	Emissions Increment Plan
    1.  Regional Grov/th Impacts
      a.  The impact on regional growth varies widely with
the size of the averaging area and the existing emission base-
line.  Regional inequities arise with averaging areas signifi-
cantly smaller or larger than the propose;d 10,000 square miles.
        » Projected economic growth in the Greater Boston
Metropolitan Area falls within a Priority I area and would not
be subject to this regulation.   However,  projected emission
density growth for both GO2 and particulates  exceeds  the

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                             67
allowable increments by a factor of five.  The entire State
of Massachusetts could not support new power plant growth
projected for the Boston area alone.
        a No growbh restrictions are found for the Four Corners
area c?ven if the large AQCR is disaggregated into 10,000 square
mile  averaging areas.  Large sources are dispersed evenly
throughout the entire region.
        9 Dallas/Fort Worth vio3at.es the TSP emission limitation
in six years under the 120 percent rule.  Extensive controls
applied to area sources as well as complete retrofit of all
industries v/ith BACT would allow projected growth to be
accomcdated for up to eleven or twelve years.
      b.  Power plants absorb a major portion of the allowable
increments in growth areas, however the restriction of accessible
electric power in turn restricts industrial and commercial
        9 The Flan would have critical consequences for develop-
ment in New York State.  The plan would restrict development after
1980 in much of the State (excluding AQCR's or counties with
significant portions at or above Federal secondary standards
with implementation plans in effect) .   The major impact would
be a severe restriction in additional  fossil-fuel power plants
which in turn could curtail growth in industrial and ccmmercial
activity.
        e Planned mine mouth power plant development in the
Northern Great Plains coal formation could not be accommodated
unless the averaging area were expanded to encompass six
adjacent states.
      c.  There are .no identifiable impacts on patterns of
development within a region, as siting is not a consideration
under this plan.

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                               68

    2 .   In du s b. r ia 1 Gr owth and Ene rgy- Re 1 at e d S our c es
      a.  An emission limitation plan impacts most heavily
upon power plants and related fuel development.
        o Power plants account for 84 percent of TSP
emissions and 98 percent of BQ2 emissions from all new
industrial sources.
        o Coal fired power plants in current clean air areas
could be restricted in size to as little as 300 KW or as much
as 1900.MW for every 10,000 square mile area depending upon
the baseline.
      b.  In the absence of baseline aberrations, industrial
growth projected to 1980 would not be affected by the increments,
with the exception of any indirect impacts due to restrictions
in power plant development.
        « Hew industrial development to I960, in its projected
locations, v/ill require only a fraction of the allowable incre-'
rnerrL.
        e Most new industrial sources are projected for
location in the rural and semi-rural areas of Priority I and
II AQCR's and would therefore not be subject to Alternative II
as proposed.
  c•  Alternative IV:  Area Classification Plan
    1.   Regional Growth Impacts
      a.  Maintaining some areas of Zone 1 levels while
allowing reasonable and planned growth in adjacent areas appears
to be feasible.
        9 The State of New York has indicated that in 29 areas
of study they were able to devise a crude area classification
scheme which would maximize allowable growth to 1980 in the
state.   This plan gave 25 areas Zone 1 status for TSP,
13 areas Zone 1 status for SO2 and exemption status to only
two areas.  Exemption status would be required for many more
areas (nine) by 1990.  This zoning is somewhat misleading
in that all areas which currently exceed secondary standards
were"classified as Zone 1.

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        « The Grand Canyon could be designated Zone 1
without .restricting resource development in the Four Corners
Region.
      b.  A significant number of exceptions would be required
by 1990 in high growth areas.  (See Alternative I discussion.)
    2•  Industrial and Energy-Related Sources
        Zone 1 restricts most industrial activities in the
area with the exception of large (100,000 ton per year) Kraft
Pulp and Paper Mills and small, well controlled power plants
(150 MW meeting NSPS).

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                                                            70
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                                Reference 12
                SCIENTIFIC FACTORS BEARING ON REGULATORY
                   POLICIES TO ASSURE NON-DEGRADATION
                             OF AIR QUALITY

I.    Overview
     Most scenarios under which regulatory policies to assure non-
degradation are conceived imply the existence of information and/or
techniques which do not always exist.  Specifically, assumptions are
made as to abilities to measure, within limits of accuracy and precision
which would be the result of the regulatory policy, the concentrations
of the pollutants under consideration.  In addition, it is implied
usually that, once measured, these concentrations can  be  compared with
"baseline" concentrations which are assumed to be known.   Finally,  it
is often assumed that mathematical simulation techniques  can be used to
predict the air quality impact of land use policies sufficiently well
to help define regulatory policy.  It should be obvious that the know-
ledge and techniques mentioned above cannot be perfect and thus that
the limits which exist on our ability to measure, model the transport,
and determine "baseline" levels of the criteria air pollutants must,
in turn, constrain regulatory policy options to some extent.  It is the
purpose of this paper to set forth the limitations which  exist on our
abilities in these areas so as to document the necessity  for discarding
many regulatory options which might otherwise seem obvious.

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                                 72
II.  Measurement Capabilities

     Total  Suspended Participate (TSP):   The federal  reference  method

for this pollutant is both sensitive (to 1  yg/m3)  and has  reasonably

low relative variation *j as shown:

     Ambient Level Measured (yg/m3)      Relative Variation (yg/m3)

                  1                               2
                150                               4.5
                260                               7.8

The technique appears adequate for most  regulatory options related  to

non-degradation.


     Sulfur Dioxide (S02):  The federal  reference method (prosaniline)

for this pollutant is of limited sensitivity and rather poor relative

variation.   The lower limit of sensitivity of the method is on  the  close

order of 30 yg/m3 but has not been rigorously defined.  The relative

variations  tabulated below are quite adequate for many regulatory

purposes, but appear deficient for application to non-degradation of

areas relatively low (below secondary standard) in S02-

     Ambient Level Measured (yg/m3)     Relative Variation (yg/m3)

                 45                               40
                350                               65
               1300                              120

     Carbon Monoxide(CO):  The federal reference method (non-dispersive

IR) for this pollutant is of fair sensitivity (300 yg/m3)  but rather

poor relative variation  as shown:
 V Two measurements differing by an amount less than the relative
    variation cannot be interpreted as being significantly different to
    a 95% level of confidence.

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                                   73
     Ambient Level  Measured (ug/m3)      Relative Variation dig/in3)

                  300                             300
               10,000                            2500
               40,000                            2500

Since ambient concentration in clean environments may range as low as

150 Mg/m3, it seems clear  that the technique would not be applicable

to many non-degradation situations.


Photochemical Oxidants as Ozone:  The federal reference method for this

pollutant has sensitivity to approximately 50 yg/m3.  The relative

variation of the method is reasonably good, as tabulated:

     Ambie_nt_ Level  Measured (yg/m3)      Relative Variation (ug/m3)

                50                                10
               160                                12

At the present time, not enough is known about prevailing ambient levels

to determine whether these performance characteristics are adequate,

but there is some indication that levels below trie sensitivity of the

method are not uncommon.


     Hydrocarbons:   Due to the fact that the present federal reference

method for total hydrocarbons does not distinguish between hydrocarbons

from natural sources (trees, etc.), the levels of which may range widely,

and man-generated hydrocarbons, it would be impossible to substantiate

environmental degradation in the sense of this pollutant using the

federal reference method.


     Nitrogen Dioxide (N02):  A federal reference method for this

pollutant has not been promulgated at this time.  Although there should

be at least one adequate method among the existing interim methods, it

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                                    74
seems essential  to first promulgate a federal  reference method  for use
in this area before attempting to develop regulations.

     Addendum:  While the above performance discussions do define
constraints placed on regulatory policy decisions by the capacity of the
analytic methods, there is a further overlay of parameters which impact
on the performance of field samplers using these methods.   In order to
analyse air quality it is necessary to pass a known  amount of ambient
air through the measurement device in a known period of time.  Ideally,
the air drawn through the device is all of consistent quality and is
also representative of the area under consideration.  This latter
factor may, however, be a function of terrain, climatic conditions and
proximity to sources of interference and thus all of these will bear
on the number of measurements required to determine  air quality to a
desired degree of confidence.  This additional influence on performance
further mitigates against the use of air quality measurements in any
active regulatory role vis-a-vis non-degradation.

III. Baseline Air Quality Information
     TSP:  The available data base on non-urban TSP  levels is more
extensive than that for any of the other criteria pollutants.  Measure-
ments have been taken over the period 1964-1972 at some forty non-urban
National Air Sampling Network (NASN) stations.
     The overall average TSP concentrations at all NASN non-urban
stations for the period 1964-1972 was 35 yg/m3 but the individual 9 year
station averages ranged from 10 yg/m3  (Yellowstone.,  Wyoming) to 68ijg/m3

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                                    75
(Cape Hatteras, N.C.).   Individual  yearly averages,  of course,  show
even more variation and ranged from a low of 8 ;ig/m! (Yellowstone,  1967
and 1968) to a high of 110 ng/m3 (Cape Hatteras,  1972.)  Individual
24-hour values show a very wide variation with a  low of lyg/m3  in  a
number of stations to a high of 312yg/m3 (White Pine County,  Nevada,
1965).
     It is obvious from this information that there  is extreme  variation
in TSP concentration between individual  station annual averages and
between the lowest and highest individual 24-hour value.  Therefore,
any decisions with respect to significant deterioration of air  quality
using these data must be made with  full cognizance  of the variability
discussed above.  Further, there is no significant difference between
TSP data collected at non-urban NASN sites in 1972 and data compiled
from either 1969-1972 or from 1964-1972; hence, 1972 data would be as
good as starting point as any other single year from which to determine
significant deterioration provided it is desirous to establish  a single
nationally applied baseline year.  However, a nationally applied
single-year baseline does not appear to be feasible  because of the
considerable year to year variability in data obtained from specific
non-urban sites.  Data from several years at a given sight are  evidently
necessary to establish a baseline level  with any degree of confidence.
     SO^:   Although attempts to measure SC^ at twenty-eight non-urban
stations have been conducted over the past six years, the results  of
this effort force the conclusion that it will be essentially impossible
to establish any sort of baseline, nationally or area-wide, using  the
standard reference method.  This is largely due to the insensitivity  of
the technique.

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                                    76
     Other Criteria Pollutants:   Although  scattered  data  exist  on
concentrations of the other criteria pollutants  in rural  and  wilderness
areas, these data are in no way  sufficient,  either geographically  or
in terms of span of time covered, to suggest baseline  concentrations for
use in non-degradation enforcement activities.
     Assessment:  Extensive experience with  measurement of suspended
particulates (TSP) shows the danger of attempting to arrive at  a
determination of baseline levels from insufficient information.  Further,
the wide variability over time of concentrations measured at  any  point
make it clear that extensive evidence would  be  required to document.
degradation of air quality from any established baseline.  Although the
standard reference method for TSP appears  adequate to  such a  task, should
it be determined necessary, this i; not the  case with  most other  criteria
pollutants.  In order to develop (as necessary), collaboratively  test,
and then promulgate appropriate analytic methods; and  then apply  them to
determination of baseline air quality, nationally, would  require  the
expenditure of resources on the order of hundreds of millions of  dollars
over a period of five to ten years.  Finally, the use  of  this information
for comparative purposes to show the degradation of  air quality at a
given site or set of sites would require extensive  further measurement
over periods of at least a year and perhaps  more.

IV.  Modelling Capabilities
     In discussing this subject it is first essential  to  point out the
necessity  for excluding all of the photochemical pollutants (hydrocarbons,
nitrogen oxides and oxidants) from any but very  theoretical  consideration.

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At. this time meteorological  dispersion/simulation modelling of these



pollutants is in the research stage only and validated models are not



available.  Previously proposed State Implementation Plans were based



on an empirical  relationship between hydrocarbons and ozone.   Further



research and development in the area of simulation of these pollutants



is confined to atttempts to treat such heavily polluted areas as the



Los Angeles Basin and would need to be drastically redirected to address



relatively clean air regions (to account for hydrocarbons from



vegetation, for example).  In terms of the conservative pollutants



(sulfur dioxide, carbon monoxide, and particulates) the use of mathemat-



ical modelling is often considered in two contexts:  (1) use to



calculate a_ctu_a]_ concentrations of pollutants under a given set of



circumstances and (2) use to calculate the changes in concentrations of



pollutants implied by changed circumstances (such as additional sources).



The former use is the less developed of the two.  For example, there is



virtually no information or applicable past experience from which one



could develop models to predict baseline air quality.  However, the use



of semi-empirical "Gaussian plume" models to relate pollutant concentration



increases to additional sources of emission is reasonably well developed.



These models have been assembled and validated for point, multiple point,



and certain types of area sources.  It should be pointed out, however,



that the accuracy which can be expected of the models decreases as



distance from the source increases and that many non-degradation applications



require extending the application of the models beyond distance limits



(perhaps ten miles) for which they have previously been validated.



Further, the uniformity of meteorology and accuracy with which meteoro-



logical parameters are known over the region being simulated affects

-------
                                  78

the accuracy which can be expected.   In general,  we  would  expect to  be
able to predict the hourly average air quality increment due to
additional point sources to within a factor of two (i.e.,  a  predicted
increment of 10yg/m3,  would have a "range of truth"  of from  5 to 20yg/m3)
at least half tne time.   Predicted annual average increments will  range
within a factor of 1.5 of the observed average increment at  least half
the time.  Thus even in  the best case the possible errors  in the modelling
process due to for example, uncertainties in meteorological  parameters
may overwhelm the air quality increment under consideration.
     Mathematical simulation does, however, provide  a consistant,
reproducible way to estimate "hypothetical" air quality increments for
conservative pollutants.  The development of enforcement scenarios
utilizing mathematical models and controlling against such hypothetical
(but uniformly reproducible) air quality increments, appear  to have
some merit.

V.   Conclusions
     Measurement:  Although the federal reference method for suspended
particulate is evidently adequate, the federal reference methods for
other criteria pollutants at low (clean environment) concentrations
suffer varying degrees of inadequacy.  Extensive modification of existing
methods or the development of new methods would be required  in order
to develop a capacity for determining significant deterioration using a
"ground truth" approach.
       Extant Air Quality Data:  Only data on suspended particulate
concentrations are extensive enough to be meaningful.  The major
conclusion which can  be drawn is that vast numbers of measurements are

-------
                                   79
required to first determine a baseline level  and then further extensive



measurements are needed to establish degradation from that level.



     Model 1ing/Simulation:  The use of simulation techniques  to predict



concentrations of the non-conservative pollutants (oxidants,  hydrocarbons,



and nitrogen oxides)  is scientifically indefensible at the present time.



Simulation techniques may have some utility in non-degradation enforce-



ment in that they allow the establishment of a logically consistent



enforcement posture predicated on limiting the incremental increase in



"hypothetical" concentrations of conservative pollutants.

-------
                          Reference 1 3

             AVAILABILITY OF AIR QUALITY DATA IN AREAS

                     GENERALLY BELOW THE NAAQS


     In order to estimate the number of monitoring stations which

are located in areas which are generally below the NAAQS,  the 1973

Monitoring and Air Quality Trends 'Report (EPA -45C/1-74-007) was

examined to determine the number of urban versus rural sites.  Although

it is probably improper to assume that urban areas are above standards

while all rural areas are below standards, the following table does

illustrate how little monitoring is being done In the rural, generally

clean, areas.
Pollutant

TSP
SOo
CO
Oxidant(03)
NO.,
Total  number
of sites

    3591
    2132
     289
     252
Number of sites
reporting at least
one valid quarter
of data  	

      3390
      1615
       213
       188
       588
Number of valid
ruraj__ s i tes

     136
      55
       0
       0
      40
                                 80

-------
                Reference 14
      TECHNICAL DATA IN SUPPORT
                  OF

   SIGNIFICANT DETERIORATION ISSUE
  ENVIRONMENTAL PROTECTION AGENCY
     Office of Air and Water Programs
Office of Air Quality Planning and Standards
   Research Triangle Park, N.C.  27711

-------
                   TECHNICAL SUPPORTING DATA TO ACCOMPANY
                     PROPOSED RUtE MAKING ON PREVENTION
                  OF SIGNIFICANT AIR QUALITY DETERIORATION
                   FEDERAL REGISTER DATED JULY 16,  1973
                  VOLUME 38, NO. 135, PART IV, PAGE 18985
     All  data presented herein are estimated, based upon typical  con-
ditions.   Many of the specific values represent averages from which
tne range of values exceeds several  orders of magnitude.  Although the
data are  adequate as a guide for impact assessments of alternative plans,
tney are  not intended for use in assessing the impact, on individual
sources,  facilities, or AQCRs.

TABLE 1.   SOURCE CATEGORIES
     All  of the options set forth in the proposed rule making for pre-
venting s iqrr, • u.artt air quality deterioration require review of certa>n
types of  sSdtiorMry sources.  Table 1 identities the sixteen sources
subject to review along with the related information on annual construction
estimates and -,-ource size statistics.  This list represents the Administrator'
best judgmert ,?^ to which sources individually have the potential for causing
"significant deterioration."  The sixteen source categories account fcr
approximately 30 percent of the particulate matter and 75 percent of the
sulfur dioxide emitted into the atmosphere eacn year nationwide, and a:count
for essentially all of these pollutants emitted in clean areas.

TABLE 2.   COMPUTATION OF EMISSIONS FROM SELEcTZD CATEGORIES
     Table 2 shows emissions estimates for the sixteen source categon >s
identified in F, ble 1.  Estimates assume the application of "best available
control technoh gy" .jnd are for an average size facility.

-------
TABLE 3.  CALCULATED MAXIMUM POLLUTANT CONCENTRATIONS FOR SELECTED
          POWER PLANTS USING OBSERVED STABILITY WIND ROSES -  GOOD
          DISPERSION AND TERRAIN ASSUMED

     Table 3 shows the calculated total  suspended particulate (TSP)

and sulfur dioxide ($02) concentrations  associated with fourteen different

power plants.  The list represents a variety of coal burning  power plants

with different capacities, volumes, stack gas temperatures and stack

heights.


TABLE 4.  CALCULATED IMPACT OF SELECTED POWER PLANTS ON SHORT-TERM
          AIR QUALITY

     This table shows the estimated maximum short-term pollutant concen-

trations in the vicinity of five large power plants with various stack

configurations.  The modified values represent those concentrations

corrected to reflect application of best available control technology.


TABLE 5.  CALCULATED IMPACT OF SELECTED AREA SOURCES ON SHORT-TERM
          AIR QUALITY

     Emissions of S02 and TSP from three area sources plus the predicted

impact of these sources on air quality are listed in Table 5.  All sources

are assumed to burn .3% sulfur oil.

TABLE 6.  CALCULATED POLLUTANT CONCENTRATIONS RESULTING FROM POINT
          SOURCES IN HYPOTHETICAL AQCRs

     Table 6 illustrates the impact of five point sources on air quality

in hypothetical AQCRs.  Resulting concentrations assume application of

"best available control technology" and are given for both open and

valley terrain.

TABLE 7.  CURRENT AMBIENT AIR QUALITY STANDARDS

     Table 7 identifies current primary and secondary ambient air quality

standards for TSP and

-------
TABU  8.   ESTIMATED COSTS OF EMISSION CONTROLS  FOR SELECTED  SOURCE
          CATEGORIES

     Table 8 provides an estimate of control  costs for selected  source

categories.   Cost figures assume application  of best available control

technology.


FIGURE 1.  DISTRIBUTION OF PRIORITY III AQCRs BY CAPACITY TO SUPPORT
           INCREASES IN TOTAL S02 EMISSIONS

     Figure 1  is a cumulative distribution of AQCRs based on their

capacity to support additional  S02 emissions.  The distribution  assumes

a maximum allowable increase in emissions of  20% over those  levels  that

existed in a sample baseline year.  Interpretation of the figure is best

illustrated through an example: approximately 40 percent of  all

Priority III AQC^s cannot support a total increase in S02 emissions of

30,000 tons per year.  Alternatively, 60 percent of the Priority Hi
                           «
AQCRs can support a single source, or combination of sources, resulting

in 30,000 tons of annual S0£ emissions.

FIGURE 2.  DISTRIBUTION OF PRIORITY III AQCRs BY CAPACITY TO SUPPORT
           INCREASES IN TSP EMISSIONS.

     This is a distribution similar to Figure 1 but based on TSP emi MODS.

For example, approximately 83 percent of all  Priority III AQCRs  cannot

support a total annual TSP emission increase  of 40,000 tons.  Figure 2  also

assumes a 20 percent allowable increase in TSP emissions over the baseline

values.
NOTF:   Unless specified otherwise, data for power plants are based 0'  the
alternate definition of best available control  technology.

-------
                                         85
                                       TABLE 1

                              SOURCE CATEGORIES REVIEWED
           SOURCE CATEGORY

Fossil Fuel Fired Steam Electric
  Power Plants

Coal Cleaning Plants

Kraft Pulp Mills (Recovery Furnaces)

Portland Cement Plants

Primary Zinc Smelters


Iron and Steel Mill
  Metallurgical Furnaces

Primary Aluminum Ore Reduction

Primary Copper Smelters


Municipal Incinerators

Sulfuric Acid Plants

Petroleum Refineries (Cat. Crackers)


Lime Plants

Phosphate Rock Processing Plants
    (Process Unit)

By Product Coke Oven Batteries

Sulfur Recovery Plants

Carbon Black Plants
  EXPECTED
NO.  PER YEAR

     40
AFFECTED
  SIZE
 SIZE DISTRIBUTION
AVG.          RANGE
 100 MW    600 N!W
           50-1200 MW
9
15
6
2
ALL
ALL
ALL
ALL
                             465 TPH   100-1000 TP^

                             800 TPD   500-1500 TP;

                             100 TPH    75-300 TPH

                             280 TPD   200-900 TPD
                              (Metal)
8 Elec Arc
6 BOP
1
2
25
2
3
7
4
3.5
8
1.4
ALL
ALL
ALL
*
250 TPD
ALL
ALL 10x1
ALL
ALL
ALL
ALL
ALL
200T/heat
480 TPD
260 TPD
(Metal)
300 TPD
750 TPD
04bbl/day
450 TPD
1200 TPD
180 TPH
140 TPD
120 TPD
100-325 T/hea1
95-740 TPD
125-1000 TPD
50-1000 TPD
500-1500 TPD
40-200 x 103
bbl/day
240-600 TPD
550-1650 TPD
70-360 TPH
27-270 TPD
109-270 TPD

-------
                                                 86
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                                             37
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-------
                                     89
                                 TABLE 4

    CALCULATED IMPACT OF SELECTED POWER PLANTS ON SHORT-TERM AIR QUALITY

                             FUEL         MEASURED    MODIFIED*   DISTANCE TO MAX.
SOURCE DESCRIPTION     PRESENT  ASSUMED   1-HR. S02   3-HR.  S02   CONCENTRATION (KM)

1000 MW Plant          1.5%S    0.7%S     1048 yg/m3  273 yg/m3         5-6
Flat Terrain           Coal     Coal
2-450 Ft. Stacks

1500 MW Plant          3%S      0.7%S     2358 wg/ra3  319 yg/m3           4
Flat Terrain           Coal     Coal
10-250 Ft. Stacks

120 MW Plant           1.3XS    0.7%S      733 yg/m3  275 yg/m3          3
2-265 Ft. Stacks       Coal     Coal

455 MW Plant           2.2%S    0.7%5.     825 yg/m3 150.8 yg/m3          3
Rolling Terrain        Coal     Coal
3-400 Ft. Stacks

1700 MW Plant          3.8%S    0.7%S     2600 yg/m3  304 yg/m3         18
Flat Terrain           Coal     Coal
2-600 Ft. Stack
1-800 Ft. Stack
*Modified impact based on measured data X   (i '7) to adjust emissions
 to reflect NSPS.

-------
                              90
                             TABLE 5

CALCULATED IMPACT OF SELECTED AREA SOURCES ON SHORT-TERM AIR QUALITY
SOURCE DESCRIPTION         FUEL

Polo Grounds - NYC         0.3%S
1,614 Units                Residual
Area = 0.9 Sq. Km.         Oil

Parkchester Manor - NYC    0.3%S
12,271 Units               Residual
Area = 0.8 Sq. Km          Oil

Co-op City - NYC           0.3%S
15,375 Units               Residual
Area = 1.1 Sq. Km          Oil
 EMISSION
(TONS/YR.)
S02     TSP

 26   14.1
                                   151   73
                                   376  184
                                                  3-HR S02
                                                   21.5
                35.4
                70.18
1-HR.  TSP
 (pg/m3)

   18
   30
   59

-------
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-------
 3-Hour
24-Hour
 Annual
                            92
                               TABLE 7
                CURRENT AMBIENT AIR QUALITY STANDARDS
TSP
(ug/m3)
—
150**
75*
SO?
(yg/m3)
1300**
365*
80*
 * Primary Standards
** Secondary Standards

-------
                                93

                                 TABLE 8

                   ESTIMATED  COSTS* OF  EMISSION  CONTROLS
                      FOR  SELECTED SOURCE  CATEGORIES
          SOURCE

  Fossil  Fuel  Fired  Steam  Electric
    Power Plants **

  Coal  Cleaning  Plants

  Kraft Pulp  Mills  (Recovery Furnaces

  Portland Cement  Plants

  Primary Zinc Smelters

  Iron  and Steel Mill
    Metallurgical  Furnaces

  Primary Aluminum Ore  Reduction

  Primary Copper Smelters

  Municipal Incinerators

  Sulfuric Acid  Plants

  Petroleum Refineries  (Cat. Crackers)

  Lime  Plants

  Phosphate Rock Processing Plants
      (Process Unit)

  By Product Coke  Cven  Batteries

  Sulfur Recovery  Plants

  Carbon Black  Plants
   COST $(000)

CAPITAL       ANNUAL
25,000
7,150
304
1,467
1,030
14,502
7,400
10,000
39,500
300
551
700
300
800
8,000
800
270
137
450
355
3,990
2,751
1,600
1 2 ,400
106
310
150
70.6
190
N/A **'
224
56
  *Cost estimates are for an average size facility as
    identified  in Table  1 and assume application of
    best available control technology.
 **Assumes the primary  definition of BACT for plants
    requiring stack gas  cleaning.  Costs for the alterna-
    tive definition of BACT would vary from 0 to this
    figure, depending primarily upon availability of
    low sulfur  coal.
***0perating costs are not available for these systems.

-------
   90.
   80..
   70-
 0)
   60..
 o


-------
                                           9b
   90 I
   80  I
   701
   60 J.
o>
c
   501
CD

O
X
  40 4
a:
c_>
cy
2 emissions.   (Allowance  is 20% increase over 1970* emissions.)


       * ]?7Pu1S^ sample year and was selected  because of  data availability
         at the time this figure was prepared.

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                            96
                          REFERENCES
 "Air  Quality  Criteria for Carbon Monoxide,"
 National Air  Pollution Control Administration
 Publication No. AP-62, Washington, D.C.
 March 1970.

 "Air  Quality  Criteria for Hydrocarbons," National
 Air Pollution Control Administration Publication
 No. AP-64, Washington, D.C. , March 1970.

 "Air  Quality  Criteria for Nitrogen Oxides," Air
 Pollution Control  Office Publication No. AP-84,
 Washington, D.C.,  January 1971.

 "Air  Quality  Criteria for Particulate  Matter,"
 National Air  Pollution Control Administration
 Publication No. AP-49, Washington, D.C.,
 January 1969

"Air Quality Criteria for Photochemical  Oxidants,"
 National Air  Pollution Administration  Publication
 No. AP-63, Washington, D.C., March 1970.

 "Air  Quality  Criteria for Sulfur Oxides, "National
 Air Pollution Control Administration Publication
 No. AP-50, Washington, D.C., January 1969

"Atmospheric Emissions from  Petroleum Refineries -
 A Guide for Measurement and Control,"   Public
 Health Service Publication  No. 763, United
 States Government  Printing  Office, Washington,
 D.C., 1960.

 "Atmospheric  Emissions from Sulfuric Acid
 Manufacturing Processes," National Air Pollution
 Control Administration Publication No.  999-AP-13,
 Durham, North Carolina, September  1970.

 "Compilation  of Air Pollutant  Emission Factors,"
 Office of Air Programs Publication No.  AP-42,
 Research Triangle  Park, North  Carolina,
 February 1972.

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                               97
"Control Techniques for Carbon Monoxide Emissions
from Stationary Sources," National Air Pollution
Control Administration Publication No. AP-65,
Washington, D.C., March 1970.

"Control Techniques for Carbon Monoxide, Nitrogen
Oxide, and Hydrocarbon Emissions from Mobile Sources,"
National Air Pollution Control Administration
Publication No. AP-66, Washington, D.C., March 1970.

"Control Techniques for Hydrocarbon and Organic
Solvent Emissions from Stationary Sources.,"
National Air Pollution Control Administration
Publication No. AP-68, Washington, D.C.
March  1970.

 "Control  Techniques for Nitrcgen Oxide Emissions
 from Stationary Sources," National  Air Pollution
 Control Administration Publication  No. AP-67
 Washington, D.C., March 1970.

"Control Techniques for Particulate Air Pollutants,"
National Air Pollution Control Administration
Publication No. AP-51, Washington, D.C .January  1969

"Control Techniques for Sulfur Oxide Air Pollutants,"
National Air Pollution Control Administration
Publication No. AP-52, Washington, D.C., January  1969

Cuffe, S.  T. and Gerstle, R. k., "Emissions from
Coal-Fired Power Plants: A Comprehensive Summary,"
Public Health Service Publication No. 999-AP-35,
Cincinnati, Ohio, 1967.

Kenline, P. A. and Hales, J. K. ,"Air Pollution and
the Kraft Pulping Industry - An Annotated Bibliography,"
Public Health Service Publication No. 999-AP-4,
November 1963.

Kreichelt, T. E., Kemnitz, D. A., and Cuffe, S. T.
"Atmospheric Emissions from the Manufacture of
Portland Cement, "Public Health Service Publication
No. 999-AP-17, Cincinnati, Ohio, 1967.

"National  Emission Standards Study," A Report to
the Congress of the United States by the Secretary
of Health, Education, and Welfare in Compliance
with Public Law 90-148 Clean Air Act, as'Amended,
National Air Pollution Control Administration,
March 1970.

Pooler5F.  Jr., "Potential Dispersion of Plumes
from Large Po^er Plants," Public Health Service
Publication No. 999-AP-16, Cincinnati, Ohio, 1965.

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                            98
Schueneman, J.  J., High, ML  D.,  and Bye,  W.  E
"Air Pollution  Aspects of the Iron and Steel
Industry,"  Public Health Service Publication
No.  999-AP-l,  Cincinnati, Ohio,  June 1963.

Smith, W.  S.,  "Atmospheric Emissions from
Fuel Oil  Combustion,"  Public Health Service
Publication No. 999-AP-2, Cincinnati, Ohio,
November 1962.

Smith, W.  S.  and Gruber, C.  W.,  "Atmospheric
Emissions  from Coal Combustion  - An Inventory
Guide,"  Public Health Service Publication
No.  999-AP-24,  Cincinnati, Ohio, April 1966.

State Implementation Plans as required uv
Section 110 of the Clean Air Act, as amended.

Turner, D.  B.,  "Workbook of Atmospheric
Dispersion Estimates," Office of Air Programs
Publication No. AP-26, Research  Triangle  Park,
North Carolina, July 1971.

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FROM:
TO:
                                     Reference 15


                  UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                     Office of Air Quality Planning and Standards
.iiJiijKCT:   Non-degradation and Power Plant Size
DA'Ilv.
                                                                      AUG i 2 1974
         Joseph A. Tikvart, Chief
         Model Application Section, SRAB

         Richard G. Rhoads
         Special Assistant, OAQPS
         THRU:  Herschel H. Slater, Chief
                Source Receptor Analysis Branch^, MDAD

              At your request, I have reviewed the allowable concentration
         increases applicable to a Class II area designation for prevention
         of significant deterioration.  The size (megawatts) power plant which
         conforms with specified concentration increments was examined.  Simi-
         lar studies by TRW for the Department of the Interior and by Harbridge
         H6use for EPA were also reviewed.

              As a result of this study, I find it likely that an 800 MW power
         plant which meets new source performance standards will not exceed the
         allowable 24-hour concentration increment (100 yg/m3).  Generally, this
         same plant will not exceed a 3-hour concentration increment of 600 ug/m3.
         (A stack height of about 400 feet has been assumed.)  Also, in most
         cases a 1,000 MW plant will not exceed the 24-hour increment.  However,
         for a plant of this size, an allowable 3-hour increment of 750 ng/m3 is
         more appropriate.  The'plant sizes discussed above will increase, if
         greater stack heights or reduced pollutant emissions are considered.
         It should be noted that a power plant in the size ranges discussed here
         may endanger a Zone I increment for a distance of 80 miles downwind under
         poor dispersion conditions.

              As you are aware, the impact of individual power plants on air
         quality is highly variable.  To determine impacts for specific power
         plants, a plant-by-plant analysis is required.  The above plant size
         estimates are general "rules of thumb" only.

              The basis for these findings is documented in the enclosure.

         Enclosure
EPA Form 1320-6 (Rev. 6-72)

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                                 100
         REVIEW OF NON-DEGRADATION  LIMITATIONS  ON  POWER  PLANT  SIZE



TRW Study



     The study by TRW attempts to relate an  allowable  power  plant size



which meets non-degradation requirements to  various  areas  of the United



States.  It concludes that a power  plant with a 400  foot high  stack  and



emissions which meet new source performance  standards  (NSPS) should  be



less than 800 MW in size if located in the Southeastern  United States.



If located in other parts of the United States, a  size less  than 1500 MW



is required.



     Unfortunately, the report does not document the basis for relation-.



ships used between concentration averaging times or  between  regions.



Nor is the basic dispersion model which was  used identified  adequately.



Thus the conclusions of the study can be considered  to be  tenuous, at



best.



Harbridge House Study



     The study by Harbridge House considers  the impact of  power plants



in three regions of the United States, e.g.  Boston,  Four Corners Area,  and



Iowa.  The impact of individual power plants in Boston were  not con-



sidered in this report.  The power  plants considered in  the  Four Corners



Area and Iowa were assumed to meet  NSPS and  to  have  a  stack  height, of



250 feet.  From the concentration estimates  for these  power  plants,  it



was concluded that a plant size ir  the range of 500  to 800 MW allows the



acceptable 3-hour increment to be met.  Concentration  estimates for  an



averaging time of 24 hours were not made.

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                                  101
     It should be noted that the model  used in  the  Harbridge  House
Study is basically applicable to estimating long-term  average pollutant
concentrations.   As such,  the algorithm which determines  the  horizontal
plume dispersion is 3-4 times greater than a similar algorithm used  in
estimating short-term (1  hour) concentrations.   Data collected by TVA
around the Paradise Steam  Plant indicates that  the  ratio  of 3-hour
average concentrations to  the 1-hour average was 0.8 as much  as 20%  of
the time.   The peak, median, and minimum ratios were 0.94,  0.66, and
0.44, respectively.  Thus  it can be concluded that  the 3-hour average
concentrations estimated by Harbridge House may be  low by a factor of
2 to 4.
Source Receptor Analysis Branch (SRAB)  Analysis
     To obtain a crude estimate of the  power plant  size which will not
exceed the allowable concentration increments for a Zone  II area, SRAB
employed the point source  dispersion model described in  "Requirements  for
Preparation, Adoption and  Submittal of  Implementation  Plans—Appendix A"
(FR 36  15494).   This model of limited  mixing is the critical plume  dis-
persion model for sources  with tall stacks.  TVA has indicated that  such
a model may be applicable  at distances  of 5-10  kilometers downwind from
the source.  Meteorological conditions  of a 500 meter  mixing  height  and
a wind speed of 5 m/s were assumed in the model. While  these conditions
severely limit dispersion, they are not uncommon in many  parts of the
United States.  More severe conditions  also occur in many areas.  The
concentration estimates from this model indicate that  a  power plant  of

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                                 102
600-800 MW should not endanger the applicable  increment  for  24-hour



averages; however, the size must be limited  to 400--600 MW  to meet  the



allowable 3-hour increment.  So that a 600-800 MW  plant  could meet both



the 3-hour and 24-hour increments, the allowable 3-hour  increment  would



have to be increased to 400-450 yg/m3.



     A related question is concerned with the  location of  such  a power



plant near a Zone I boundary.  Zone I allowable concentration increments



are only 5-13% of Zone II allowable increments. By using  the limited



mixing model indicated above, it was determined that a plant which just



meets the Zone II increment, may exceed the  Zone I increment for a dis-



tance as great as 80 miles downwind.  Thus it  appears that such a  power



plant should not be located any closer than  80 miles from  the nearest



Zone I boundary.



     To supplement the"basis for assuming that a power plant larger  than



600-800 MW could exceed both the 3-hour and  24-hour Zone II  allowable



increments, data from the EPA funded Wai den  Power  Plant  Study were



employed.  First, all power plants with actual stack heights in the



range of 400 to 600 feet were selected.  The reason for  this selection



is an arbitrary definition of good engineering practice  (GEP) stack



height.  In its simplest form, in flat terrain a GEP stack is one  which



is 2-1/2 times the height of nearby structures. Since nearby structures



routinely include a boiler house the  stack should  be 2-1/2 times  this



structure.  From the data available it appears that typical  boiler houses



on new plants are about 150 feet high; this  would  require  a GEP stack  of

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                                   103
400 feet.  Next, the relationship of stack height  to  surrounding  terrain
was examined.   Only those 15 plants with stacks  300 feet or  higher  than
surrounding terrain were analyzed further.   These  stacks were reviewed
for their impact on 1-hour, 24-hour, and annual  average  concentrations
with the assumption that they met NSPS.   The impact with NSPS was then
compared to the allowable Zone II concentration  increment.
     The attached figures indicate plant size (MW)  versus maximum concen-
trations for 3-hours and for 24-hours for plants assumed to  meet  NSPS.
Lines indicate the relationship between  plant size and concentration  that
is necessary for 2000, 1000, and 800 MW  plants to  meet required increments.
Plants above the line will exceed the allowable  increment;  plants below
will be within allowable concentrations.  For the  24-hour average concen-
trations it is quite apparent that if the plants investigated were 2000  MW
in size, more than half would cause the  24-hour  increment to be exceeded.
A 1000 MW plant would allow most of the  plants to  meet the  allowable  incre-
ment, while a 500 MW plant would insure  that all plants  would meet the
allowable increment.  This is consistent with the  earlier finding that a
600-800 MW plant is required to meet the allowable increment.
     Estimates for 3-hour concentrations were not  available for most  of
the plants considered, only 1-hour averages.  For  3 plants  on which data
were available, the 3 hour/1 hour ratio  varied from 0.44 to 0.69; this
is within the range of observed ratios discussed above.   Thus to be con-
servative, the 3-hour ratio of 0.8 also  discussed  above is  employed here.
The estimated maximum 1-hour concentrations were reduced by 20% to estimate

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                                  104
the 3-hour concentrations.   This  is  done with  the understanding that this



ratio has wide variation.



     For 3-hour average concentrations  it  is clear that any plant larger



than 400 MW can cause the  3-hour  increment  to  be endangered.  Though there



are plants that exceed the allowable increment, none of these plants have



stacks greater than 400 feet.   It appears  that if the allowable 3-hour



increment is doubled to 600 ug/m3, most 800 MW plants should not exceed



the standard.  This estimate is somewhat greater than that obtained from



the limited mixing model analysis.

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                          Reference 16
               Office of Air Quality Pianrrino and Standards
               f'rsrarch Triannle Park, North Carolina   27711
Significant  potcrioration in 7onc I /Yeas and tho              Oct.  IB, IC'7'-
Relative  Location of Po'./or Plants

Joseph A. Tikvart,  Cliiof
f'odel Application Section

The Files

     Tho  7ono  I  allowable ?A hour isvornn^ concentration  increments  1o
prevent significant deterioration for cno and particulate r>attr.r aro
5 iia/n3 and  10 ii'Ym3»  respectively.  It Is nossible  that a  nov;er plant
located in a Zone II or 7.rnc III aron could root the  allov/ablo increment
for these latter areas hut still exceed the allowable increment for
adjacent Zone  I  nrca.   This brief analysis considers  the distance a plant
must to located  frcr - 7rne I nrra to avoid exccedinq the^lTcvMDl a
concentration  incrcmontr>.

     The  concentration that a source causes at a niven dov.-nv/ind distance
depends on the pollutant emissions, physical plant characteristics  rnd
meteorological conditions.  To simplify this analysis a  few nenpraV'zpd
assumptions  arc  made.   "The source is assured to bo a  lOOO'-'l! pover r.rnt
which roots  nc>v  source nerfornnnco standards (iiSPS);  thus its SO.^ and
particulate  emissions  are estirotftJ to be ^pproxinatoly  1000 o/s^and
100 p/s,  respectively.  Tho plant has a 400 foot hich r.tack v/ith a
pluino rise equal  to the stack hninht, o.q., cfrective sback heioht  is
approximately  250 roter^.  It is further assumed that vertical  nixino
of the plunc is  linitfd to 500 raters and that the avorpno  v/ind spend in
5 T'/S (IT. Hlo-^torT. nor Imur): ;--lio conui Liens  ny cct:ur
with a steady  vind  (lir«^ct.i(Mi for periods up lo '~ hours;  i-ov/over, 11;1 '.n:,:
direction itself may persist for considerably lonqor  periods.

     Such peteoroloqicnl condition'; rcsultina in poor dispersion of thn
pollutant arc  not uncornon in ranv parts of the United Slates.   F.'vor: ;n
areas rith ccncrally rood dispcrsun r;or,dit.ion.~t such adverse condition;;
may occur on a limited number of occasions.

     I'ith the  sbc.v*' irdicatrc! plrsit rivd rTtr~or''lor*i>Ttl '"'iji'iitfor'i.  ^!'if>
paxiiur.\ ^-l-l/'-ir  C°^ cr-^c^-'.ri^ic':; rrtr.rij uy Lr:. nlai;t vould  'r  ;i|;pr'.)y"-
pately 100 yn/m3  at r  •!i-tr:r,cn of 3 '.iloivctorr, •!f'7nvirvj  frc~> tho nl:ni:.
Thus the cor.ccntrTjIcr .-Its1: r'::M,<; th^ "'TC IT Allcvnblo  incrr "f-'t,   i'i-c
channc 1n "0   cc:i';cnf'.ral!on \-it!i '.,'1st once dcvn-./ini frcn  i(,n p!>ni. -\:.
shown in  FifL-rr  1,   It can bo s'-on tii^t if mo oVcny  nf SH0  is .-.ssi'^r-''
the concentration roachos a level of r ya/r,i3 at a distance"  of bO-100
kilometers.  If  an  ro,, half-life of 1? or 4 hours is  Assumed, th.o ''eve!
of 5 yQ/m3 is  reached"'closer to the stack.  It. should be noted that
beyond 80 kilorG'tcrs i;i.r concontrr'tion dccroasc-s vorr slov/ly with incrra^r
in distance.   Siiice F1wrc 1 has a scale of 0-100 for concentration, these
                           107

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                             108
                                  ?.
''
values can F~o used as a prrccntriee.  Thr-rcfor^  if  n  sipilar  ?OOP"-'.'
plant in a 7onc III area caused n iraxInuTn concentration  of 200  yn/;n3,
then a concentration of F>&'. of this value or 10  ua/ru3 v:ould result at
a distance of CO-1CO kilometers, 1f there was no 500 decay.   Due  to
tlio relative- stringency of the 7one I  ?4 -hour  ?nn Increment,  it  is  the
rrost difficult to reot.  In rest cases,  if the  ?4-hour  increment  is  mot,
then the 3-hour and arnual incr 'rents  are  a"; so lil'ftly to bo net.

     A distance of lnO Mlrretrvs at a wind srood  of 'J rotors  nor second
requires a travel tin-1 of nearly r> hours.  Thu:;, if  the  phenomena which
causes the significant concentrations at 100 kilometers  also "Insts for
C hours, a persistent wind ^>-r ]? hours  is irplicit  in  the ;»nn'Nsis.
Since tli^.re is Vittln information on dispers'Icn beyond  IPO k1lo!"eters
and any cssunption of persistence for rericds lonoer than 12 hours are.
extrenely tenuous, Fiourc 1 is not extended beyond 100 kiloincters.
Such an extension should be ottenpt^d only for  specific  tonooraphic  and
cl1niatolof|ical conditions and cnly then vn'th orrat care.

     Finure II indicates 24-hour participate concontrationr,  caused by  A
100C-!'.VI plant r.eetinn f'SPS.  It can be seen that such a v-ell  controlled
plant will meet the 7.one I allowable concentration increment of 10 yn/ri3 .
Even 1f S00 viith P. bnlf-life "o'- 4 hours  Is converted entirolv to
sulfate and treated as particu'ate patter, ?. concentration of 10
is reached v.'ithin 10 Mlor^otors downwind of the source.  For laroer
sources a proportional increase in raxinun concentrntion can b>e assumed,
and the percent decrease with distance irpliec!  by  Fini.'re II  used.

     Thus, from the above analysis it can bo concluded  that:  It  is
reasonable to expect a 10QOM1! plant nretinq r'SPS to  endanncr the  Zone  I
SCL Increment to a distance of 50-CO  riles  dov/nv/1nc'.  For larner plants
located for example in a Zone III area this Increment vill be endannereci
for nreater distances dowr.vind,  A ^ens,rate analysis for such silualions
on an individual basis appears ''eslrable,  "bo  Irpact of such sources  on
the pcrticulate increment does not appear to ':-e a  problem.

     It should be noted that the above anr.lvsis is for  o oenrral i?.ed sourc.'",
Thus, conclusions tfrwr about downv:in'J dist.apces at  v.'in'ch  the plant  hrs
a sinnificant effect can Lc considered ''rules t;f thurb", at  best.  If
any changes in the; niiysic-il ciiarncterintics of  the pl?nt or  ^>o rcteoro-
logical conditions are rade, 5;inr,ificantly different concentrations  rw
b"c estimated at dov/nwind distances.  This is especially  irportnnt since
relatively snail channes in concentration arc- critical  in  the consideration
of air quality deterioration.

cc:  K. Perry ,^-~-~

-------
                  109

                Figure  1

  SO-  Concentration  versus  Distance
             Limited Mixing:
             Wind Speed    :
             'C'  Stability :
             Plant size
500 m
5 m/s

1000 MW
                                 No decay
    20  si   ww   si   TO"sir
Downwind Distance (Kilometers)
                                    12 hour half-life

                                         4 hour half-life
        90  TOO

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                   no

                Figure 2

Particulate Concentration versus Distance
            Limited Mixing:  500m
            Wind speed     :  5 tn/s
            "C" Stability  :
            Plant Size     :  lOOOMlN
                                                Addition of S02
                                                converted with a
                                                4-hour half-mile
                                                to (NH4)2 S04
                                                Addition of S02
                                                converted with a
                                                12-hour half-life
                                                to (NH4)2 S04
                                      No conversion
0   10
20  30   4C    50    60   70    80    90   100

 Downwind Distance  (Kilometers)

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                            Reference 17
                          DISCUSSION PAPER ON  THE
                    MAGNITUDE OF THE CLASS II  INCREMENT
                IN THE SIGNIFICANT DETERIORATION REGULATIONS
THE ISSUE
     The draft regulations incorporate the same general  definition  of  the
Class II increment as was incorporated in the proposal  of July 16,  1973,
and incorporate the same provision that this increment  serve as the initial
area classification nationwide.   It has been suggested  that the increment
be doubled.

EXPLANATION

     The primary reason for doubling the increment is to permit a  larger
growth potential - with primary concern for coal-fired  power plants -
during the interim period until  States redesignate their territory.  The
provision for States to redesignate their territory according to local
desires is not an issue.  The provision for EPA to perform an initial
designation as Class II is also not an issue.  The issue is solely
whether the Class II increment should remain as proposed, or whether it
should be doubled.

DISCUSSION

     Point 1.  The Class II increment is adequate to permit normal,
well-controlled, commercial and industrial construction in most areas
of the country.  The current increment was developed to permit the amount
and type of polluting growth which is, in the subjective judgment  of EPA,
generally  "acceptable" to affected populations in most areas, but  to pre-
vent the type of growth (such as very large coal-fired power plants) which
generally creates a strong adverse reaction by many local populations.

     The increment will permit construction of typical  new coal-fired
power plants  (which must meet New Source Performance Standards and must
use stack heights corresponding to good engineering practice) in the range
of from 800 megawatts to 1000 megawatts.  The variation  is due primarily
to differing  terrain features and meteorological conditions in particular
sections of the country, and to specific siting conditions.  These data
were developed by EPA, and are generally consistent with the studies
conducted by  other agencies and contractors.  The data  are somewhat
more precise  than earlier studies because most earlier studies could
not assess the impact of "good engineering practice" stack heights.
                                 Ill

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                                   2

     The increment will  therefore support new power plant units which are
slightly larger than the average individual  units planned for construc-
tion.  Testimony provided by a representative of El Paso Natural Gas
confirmed that the Class II increment would  £.lso not restrict their
planned coal  gassification facility.  Similar analyses indicate that the
Class II increment will  support larger than  Average si/o fatilities oi
other1 major commercial  and in.lustr in I  .utivUies although large f,u ilities
(including oil shale extract!'in), would likely require redesignatiun to
Class III.

     Point 2.  The_ -J^s_s_J_J__jj)cr_ement wo u 1 _d_ (and_ shou 1 d) i nhi bit
           r!_q^
         _r.g.eiPo'l lution-prone facil i ties,  and large cju_sters~p7
smaller facilities.    Data on new fossil-fuel fired power plants currently
planned for construction through 1982 shows  that future plants will be
substantially larger than those to which the public is currently accustomed.
The average new unit size is !>70 MW which is nearly double the average
size of existing plants.  There are 103 new plants planned, with an
average size of 970 MW.   The "argest plant will be 5200 MW.  Six plants
will  be larger than 2500 MW, 22 will be larger than 1500 MW, and 37
will  be larger than 1000 MW.  Most of these plants will be prohibited
from construction in Class II areas.

     The large new plants wil" not be uniformly distributed.  The 11
SERC (Southeast) plants will average 1480 MW each, the 28 ECAR  (East-
Central) plants will average 1160 MW, and the 19 WSSC  (Western) plants
will  average 1050 MW.  This trend toward substantially larger new plants,
and substantial expansion of existing plants, is expected to continue.

     One of the major goals oi the "significant deterioration movement"
has been to insure that these very large plants are properly controlled
and located, but not necessarily prohibited.  The  plans for  "massive
coal-fired power plants" were repeatedly referred  to  in the  public debate
as specific examples of the t>pe of growth on which public attention
should  be focused.   It  is therefore appropriate that  the  Class  II  incre-
ment should be sized to place these large plants in a  category  different
from that of the smaller plants.

     Point 3.  JjT§_J nitial designation as Clas s 11 will not,  di srupt
consjtnj ctj o n of most large povv er plant's due  to~~nT the six-month grace
period  and~f27 the provision  for rapid redes i gnat ion  to CjAS_s_LLL_ The
initial designation  will directly affect only those power plants which
(1) have not received construction approval  prior  to  six months after
promulgation  (prior  to  that time sources are not subject  to  review  for
significant deterioration) and  (2)  have planning schedules which require
construction approval before  the State can consider redesignation  of  the
local area  (after the State has considered redesignation,  it is the State
decision, not  the initial designation, which affects  the  power'  plants).

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                                   113

                                   3

     The regulations do not require a State to redes i
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                                   114
facilities.  In so doing, it is likely that some forms of desirable
growth would also be prohibited as a byproduct.

     Point 6.'  Uojubljixj  the Class II increment wo_ukl _ro<|uire develo])-
nien_t_ of entijej^ new rajjonale ajid_ j_u_s_t i f_u a (.Km _fo_r_ selection of_ the
nl'^1'n^:r^i11§H^-  ^ne current increment permit^ introduction of well-
controlled, moderate sized facilities, and excludes  the very large
pollution-prone facilities which often encounter massive public
resistance.  The Class II increment is intended to apply to areas of
"moderate," "normal," or "average" growth, with populations which have
"typical" attitudes toward balancing of environnertal and other con-
siderations.

     This rationale could not be applied to an increment which would
permit introduction of very large power plants.  These massive facilities
do encounter strong opposition in many areas of the  country.  They are
not "moderate," "normal," or "average," and are not  generally acceptable
to "typical" populations.

     Point 7.  To double the Class  II increment^t this late date
wjthout stronrj_ju_stjfjc_at_i_on would  likely  be viewed  with suspjcion by
the pub 1 i c and ,d j_sf a vo_r_ by the Cput;t. The  current Class II  increment
has received extensive debate and general  acceptance in the public arena.
Although many comments questioned the basic concept  of preventing signi-
ficant deterioration,  there were no major  chal'enges to the philosophy
that the Class II increment should  permit  a reasonable amount, of growth
in most areas of the country, except for challenges  that the increment
is too large.  In fact,  there is nothing in the  public record that
would support doubling of the Class II increment  in  these regulations.

     The Acting Administrator stated in the July  16, 1973,  proposal
that, in his judgment, "Deterioration above the  Zone II levels would
constitute  ... a significant deterioration in  most areas of  the  country."
It is unlikely that  the  Court, and  the public, could be provided any
new data or rationale  which would justify  changing  that, judgment.

     Possibly the most compelling argument against doubh'n
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                              Reference1  ?0

Emissions of Sources Subject to Significant Deterioration  Regulations

     The 1970 emissions for the 17 largest source categories  are  shown
in Table 1.  The total  1970 emissions,  excluding  sources  such as  forest
fires and agricultural  emissions,  were:   22.3 million tons for TSP and
33.3 million tons for SO,,.  Therefore,  existing  sources  of the type
subject to the significant deterioration regulations emitted  about 30%
of the TSP and 75% of the S02 emitted nationwide  in  1970.

Table 1 - 1970 Emissions for the 17 Largest Source Categories, tons/yr.
Source Category                     TSP
                                                                 p
Fossil Fuel Fired Steam          3,000,000                 13,465,000
Electric Power Plants
Coal Cleaning Plants               102,000
Kraft Pulp Mills                   796,000
Portland Cement Plants             280,000
Primary Zinc Smelters               22,000                    140,000
Iron and Steel Mill                817,000
Metallurgical Furnaces
Primary Aluminum Ore                74,000
Reduction
Primary Copper Smelters             71,000                  4,021,000
Municipal Incinerators             450,000
Sulfuric Acid Plants                                        1,757,000
Petroleum Refineries               211,000                  4,393,000
Lime Plants                        523,000
Phosphate Rock Processing          334,000
By Product Coke Oven               153,000                    437,000
Batteries
Sulfur Recovery Plants                                        750,000
Carbon Black Plants                215,000
Primary Lead Smelters                1 ,200                    494,000
     TOTALS                      7,249,000                 25,457,000
                                  115

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                                   TECHNICAL REPORT DATA
                            (Please read Instructions on the reverse before completing)
1. REPORT NO.
                                                           3. RECIPIENT'S XCCESSION'NO.
4. TITLE AND SUBTITLE
   Technical  Support Document
   EPA Regulations for Preventing the
   Significant Deterioration of  Air Quality
             5. REPORT DATE
                 January 1975
             6. PERFORMING ORGANIZATION CODE
                   N/A
7. AUTHOR(S)
                                                           8. PERFORMING ORGANIZATION REPORT NO
   EPA, OAQPS,OAWM
                      N/A
9. PERFORMING ORGANIZATION NAME AND ADDRESS
   Same
                                                            10. PROGRAM ELEMENT NO.

                                                                 547853A991
                                                            11. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS
   Same
                                                            13. TYPE OF REPORT AND PERIOD COVERED
                                                            	 Final
                                                            14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
16. ABSTRACT
  This document provides a detailed explanation of  the technical and  policy
  condiserations which form the  basis for EPA's regulations for preventing the
  significant deterioration of air-quality, which were published in the
  Federal  Register on December 5,  1974.   The document  discusses the reasons
  for rejecting various alternative plans for preventing significant  deterioration
  of air quality; the basis for  the air quality increments selected and  the
  pollutants  and sources covered;  anc the impact of the regulations on general
  growth and  development as well  as on new energy sources.  A number  of  the
  references  are included as  appendices; however, several  of the studies and
  reports  referenced are too  voluminous to include  in  this document.  These
  reports  are available for public Inspection at EPA's Freedom of  Informantion
  Center in Washington, D.C.
17.
                                KEY WORDS AND DOCUMENT ANALYSIS
                  DESCRIPTORS
                                              b.IDENTIFIERS/OPEN ENDED TERMS
                           c. COSATl Field/Group
  Prevention of significant  deterioration
18. DISTRIBUTION STATEMENT
  Release unlimited
19. SECURITY CLASS (ThisReport)
                                                                          21. NO. OF PAGES
                                              20. SECURITY CLASS (Thispage)
                                                                         22. PRICE
EPA Form 2220-1 (9-73)
                                             116

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