EPA-450/3-74-069
DECEMBER 1974
     IMPLEMENTATION PLAN REVIEW
                  FOR
                HAWAII
              AS REQUIRED
                   BY
          THE ENERGY SUPPLY
                  AND
   ENVIRONMENTAL COORDINATION ACT
     U. S. ENVIRONMENTAL PROTECTION AGENCY

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                                                             EPA-450/3-74-069
                                  IMPLEMENTATION PLAN REVIEW

                                            FOR
                                           HAWAII

               REQUIRED BY THE ENERGY SUPPLY AND ENVIRONMENTAL COORDINATION ACT
\
's
o
                             PREPARED BY THE FOLLOWING TASK FORCE:


                         U. S. Environmental Protection Agency, Region
                                    100 California Street
                                San Francisco, California 94111


                             Environmental Services of TRW, Inc.
                                  (Contract 68-02-1385)
                            U. S. Environmental Protection Agency
                             Office of Air and Waste Management
                         Office of Air Quality Planning and Standards
                         Research Triangle Park, North Carolina 27711
                                         December  1974

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                                    HAWAII
                  ENERGY  SUPPLY  AND ENVIRONMENTAL  COORDINATION  ACT
                  (SECTION  IV  -  STATE  IMPLEMENTATION  PLAN  REVIEW)
                                                                           Page
 1.0   EXECUTIVE  SUMMARY   	   1
 2.0   STATE  IMPLEMENTATION  PLAN  REVIEW  	   5
      2.1  Summary	   5
      2.2  Air Quality Setting - State of Hawaii   	 6
      2.3  Background on  the Development of  Hawaii's  Control
*  r    -  Strategy	   8
      2.4  Special Considerations  -  Hawaii	   9
 3.0   AQCR ASSESSMENTS	10
      3.1  Regional  Air Quality  Assessments  	  10
      3.2  Power Plant Analysis  	  10
      3.3  Area  Source Assessment    	11
      3.4  Industrial/Commercial/Institutional Source Assessment  	  11
      3.5  Fuel  Assessments	11

      APPENDIX A - State  Implementation  Plan Background  	  12
      APPENDIX B - Regional Air  Quality  Analysis   	  29
      APPENDIX C - Power  Plant Assessment-   	  32
      APPENDIX D - Industrial, Commercial, Institutional Source
                  Assessment	37

      BIBLIOGRAPHY   	  40
                                     Hi

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                         1.0 EXECUTIVE SUMMARY

     The enclosed report is the U. S. Environmental Protection Agency's
(EPA) response to Section IV of the'Energy Supply and Environmental
Coordination Act of 1974 (ESECA).  Section IV requires EPA to review
each State Implementation Plan (SIP) to determine if revisions can be
made to control regulations for stationary fuel combustion sources
without interfering with the attainment and maintenance of the National
Ambient Air Quality Standards (NAAQS).  In addition to requiring that
EPA report to the State on whether control regulations might be revised,
ESECA provides that EPA must approve or disapprove any revised regulations
relating to fuel burning stationary sources within three months after
they are submitted to EPA by the States.  The States may, as in the
Clean Air Act of 1970, initiate State Implementation Plan revisions;
ESECA does not, however, require States to change any existing plan.
     Congress has intended that this report provide the State with infor-
mation on excessively restrictive control  regulations.  The intent of
ESECA is that SIP's, wherever possible, be revised in the interest of
conserving low sulfur fuels or converting sources which burn oil or
natural  gas to coal.  EPA's objective in carrying out the SIP reviews,
therefore, has been to try to establish if emissions from combustion
sources may be increased.  Where an indication can be found that
emissions from certain fuel burning sources can be increased and still
attain and maintain NAAQS, it may be plausible that fuel resource
allocations can be altered for "clean fuel savings" in a manner con-
sistent with both environmental and national energy needs.
     In many respects, the ESECA SIP reviews parallel  EPA's policy on
clean fuels.  The Clean Fuels Policy has consisted of reviewing imple-
mentation plans with regards to saving low sulfur fuels and, where the
primary sulfur dioxide air quality standards were not exceeded, to
encourage States to either defer compliance regulations or to revise the
S02 emission regulations.   The  states  have also been asked to discourage
large scale shifts  from  coal  to oil where this could be done without
jeopardizing the attainment and maintenance of the NAAQS.

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     To date, EPA's fuels policy has addressed only those  States  with the
largest clean fuels saving potential.   Several of these States  have  or are
currently in the process of revising S02 regulations.   These  States  are
generally in the Eastern half of the United States.  ESECA, however, extends
the analysis of potentially over-restrictive regulations to all  55 States
and territories.  In addition, the current reviews address the  attainment
and maintenance of alj_ the National  Ambient Air Quality Standards.
     There are, in general, three predominant reasons  for the existence of
overly restrictive emission limitations within the State Implementation
Plans.  These are:l)  The use of the example region approach  in developing
State-wide air quality control strategies; 2)  the existence  of State Air
Quality Standards which are more stringent than NAAQS; and 3) the "hot spots"
in only part of an Air Quality Control Region (AQCR) which have been used
as the basis for controlling the entire region.  Since each of  these situa-
tions affect many State plans and in some instances conflict  with current
national energy concerns, a review of the State Implementation  Plans is a
logical follow-up to EPA's initial appraisal of the SIP's conducted  in 1972.
At that time SIP's were approved by EPA if they demonstrated  the attainment
of NAAQS oir more stringent state air quality standards.  Also,  at that time
an acceptable method for formulating control strategies was the use  of an
example region for demonstrating the  attainment of the standards.
     The example region concept permitted a State to identify the most
polluted air quality control region (AQCR) and adopt control  regulations
which would be adequate to attain the NAAQS in that region.   In using an
example region, it was assumed that NAAQS would be attained  in  the other
AQCR's of the State if the control regulations were applied  to  similar
sources.  The problem with the use of an example region is that it can re-
sult in excessive controls, especially in the  utilization of clean  fuels,
for areas of the State where sources would not otherwise contribute  to NAAQS
violations.  For instance, a control strategy based on a particular  region or
source can result in a regulation requiring 1 percent sulfur  oil to  be burned
state-wide where the use of 3  percent  sulfur coal would be adequate to attain
NAAQS in some locations.

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     EPA anticipates that a number of States will use the review findings
to assist them in making the decision whether or not to revise portions of
their State Implementation Plans.  However, it is most important for those
States which desire to submit a revised plan to recognize the review's
1 imitations.  The. findings pf_ this regojrt_are_by_np.jpeans conclusive and
are neither intended nor adequate to be the sole basis for SIP revisions;
they_dp, however, represent EPA's best judgment and._effort_in__comp_lyjjTg
with ,the_ESECA..jce^uij^mejits.  The time and resources which EPA has had to
prepare the reports has not permitted the consideration of growth, economics,
and control strategy tradeoffs.  Also, there has been only limited dispersion
modeling data available by which to address individual point source emissions.
Where the modeling data for specific sources were found, however, they were
used in the analysis.
     The data upon which the reports' findings are based is the most
currently available to the Federal Government.  However, EPA believes that
the States possess the best information for developing revised plans.  The
States have the most up-to-date air quality and emissions data, a better
feel for growth, and the fullest understanding for the complex problems facing
them in the attainment and maintenance  of air  quality standards.   Therefore,
those States desiring to revise a plan are encouraged to verify and, in
many instances, expand the modeling and monitoring data supporting EPA's
findings.  In developing a suitable plan, it is suggested that States select
control strategies which place emissions for fuel combustion sources into
perspective with all sources of emissions such as smelters or other industrial
processes;  States are encouraged to consider the overall impact which the
potential relaxation of overly restricitive emissions regulations for combus-
tion sources might have on their future control programs.  This may include
air quality maintenance, prevention of significant deterioration, increased
TSP, NO , and HC emissions which occur in fuel switching, and other potential
       y\
air pollution  problems such as sulfates  .
     Although the enclosed analysis has attempted to address the  attainment of
all the NAAQS,  most of the  review  has focused on total suspended particulate
matter (TSP)  and  sulfur dioxide  (SO-) emissions.  This is because stationary
fuel combustion sources constitute  the  greatest source of S02 emissions and are
a major source  of TSP emissions.

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     Part of each State's review was organized to provide an analysis of

the S02 and TSP emission tolerances within each of the various AQCR's.  The

regional emission tolerance estimate is, in many cases, EPA's only measure

of the "over-cleaning" accomplished by a SIP.  The tolerance assessments

have been combined in Appendix B with other regional air quality  "indicators"

in an attempt  to provide an evaluation of a region's candidacy for changing

emission limitation regulations.   In conjunction with the regional analysis,

a summary of the State's fuel combustion sources (power plants, and industrial
sources) has been carried out in Appendix C and D.


The findings of this report are as  follows:

     •  The State of Hawaii  has been reviewed  for the most  frequent causes
        of over-restrictive emission limiting  regulations.   Even  though
        the State ambient air quality standards  are more strict than  the NAAQS,
        there  is no indication that current TSP and SOg regulations  are
        overly restrictive within the context of Section IV of ESECA.

     •  Although air quality data collected by EPA  and  the  State  of  Hawaii
        show no SO? violations of the NAAQS, monitoring results by the
        Hawaiian Electric Company indicate one case where  S02 air quality  is
        exceeding the NAAQS.  However, any contemplated revisions of  emission
        limiting regulations should consider sources  on an  individual basis,
        as SOo is more a local than regional problem  in the State.

     •  Particulate matter is a problem in the State  of Hawaii, as there are
        reported violations of the NAAQS.   Emissions  result from  bagasse
        combustion boilers and agricultural burning.   Wind blown  fugituve
        dust may also be a major source and EPA is  currently collecting this
        data,  as the SIP did not include fugitive dust  in its inventory.
        Any increase in particulate emissions can only aggravate  existing
        conditions.  There is currently little possibility, therefore, of
        revising stationary source fuel combustion  emission regulations.

     •  The State new source review system permits  existing sources  to switch
        to a higher sulfur fuel without going  through the  review  procedure.
        Such switching may or may not result in air quality violations.

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               2.0  STATE IMPLEMENTATION PLAN REVIEW

2.1  SUMMARY

     A revision of fuel combustion source emissions regulations
will depend on many factors.  For example:

     •  Does the State have air quality standards which are
        more stringent than NAAQS?

     •  Does the State have emission limitation regulations
        for control of:(l) power plants, (2) industrial sources,
        (3) area sources?

     •  Did the State use an example region approach for demon-
        strating the attainment of NAAQS o£ more stringent State
        standards?

     •  Has the State not initiated action to modify combustion
        source emission regulations for fuel savings; i.e.,
        under the Clean Fuels Policy?

     t  Are there no proposed Air Quality Maintenace Areas?

     •  Are there indications of a sufficient number of monitoring
        sites within a region?

     •  Is there an expected 1975 attainment date for NAAQS?

     •  Based on reported (1973) air quality data, does air quality
        meet NAAQS?

     •  Based on reported (1973) air quality data, are there
        indications of a tolerance for increasing emissions?

     •  Are the total emissions from stationary fuel combustion
        sources proportionally lower than those of all other
        sources?

     •  Is there a significant clean fuels savings potential in
        the region?

     •  Must emission regulations be revised to accomplish
        significant fuel switching?

     •  Do modeling results for specific fuel combustion sources
        show a potential for a regulation revision?

     The following portion of this report is directed at answering these
questions.  An AQCR's potential for revising regulations increases when

there are affirmative responses to the above.

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      The initial  part  of the  SIP  review  report, Section 2 and Appendix A,
 was  organized to  provide the  background  and current situation information
 for  the State Implementation  Plan.  Section 3 and the remaining Appendices
 provide an AQCR analysis which  helps  establish the overall potential for
 revising regulations.   Emission tolerance  estimates have been combined in
 Appendix B with other  regional  air quality "indicators" in an attempt to
 provide an evaluation  of a region's candidacy for revising emission
 limiting reflations.   In conjunction with the regional analysis, a
 characterization  of the State's fuel  combustion  sources  (power  plants  and
 industrial sources) has been  carried out in Appendix  C and  D.

      Based on an  overall evaluation of  EPA's  current  information, AQCR's
 have been classified as good, marginal,  or poor  candidates for  regulation
 revisions.  The following table summarizes the State  Implementation  Plan
 Review.  The remaining portion  of the report  supports this  summary with
 explanations.
 2.2  AIR QUALITY SETTING - STATE OF HAWAII
      The entire State of Hawaii is contained  within  one Air Quality  Control
 Region  (#060, see Figure A-l).   At present, the  city  and  county of  Honolulu
 has been proposed as an Air Quality Maintenance  Area  for  total  suspended
 particulates, but EPA may possibly drop this  proposal in  the near  future.
 The priority classifications  for the AQCR are shown  in Table A-l.
      Table A-4 illustrates the  Federal  and State Ambient  Air Quality Standards
 for S0?, TSP and NO .   As can be seen,  the state standards  are  in all  cases
       ^            /\
 more stringent than the corresponding federal  standards.  The attainment data
 for meeting the federal primary and secondary TSP standard  is July  1975.
 Since S02 air quality at the  time of the SIP  submittal was  below the national
 secondary standard, no attainment data  was required.
      From the most currently available  air quality data collected  by EPA and
 state agencies (1973),  it is  apparent that TSP remains a  problem (Table A-5),
 while S02 concentrations have stayed well  below NAAQS.  Sources of  particulate
' emissions include the combustion of bagasse as a fuel and agricultural  burning,
 while power plants contribute the majority of S02 emissions.

-------An error occurred while trying to OCR this image.

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203  BACKGROUND ON THE DEVELOPMENT OF HAWAII'S CONTROL STRATEGY
     The Hawaii SIP is rather unique in that the control  strategy employs an
"example island" approach, with Oahu being the selected island.  This appro-
ach is supported by the fact that 82% of the State's population resides on,
and over half of the State's emissions of TSP, S09 and NO  emanate from that
                                                 C.       X
island.  The achievement of desired air quality levels was evaluated by
proportional reduction calculations.
     Two sets of control strategies are actually presented in the SIP - one
for attaining the State ambient air quality standards and one for attaining
national standards.  The Governor requested that EPA consider only the control
strategies to attain national standards and those other portions of the SIP
necessary to comply with EPA requirements.

2.3.1  Particulate Matter Control Strategy
     The control strategy to meet national primary and secondary standards is
comprised of the following measures:
     (1)  Process weight table.
     (2)  Bagasse burning boiler limitation of 0.4 lbs/100 Ibs of bagasse
          as burned.
     (3)  Incineration limitation of 0.2 lbs/100 Ibs of refuse as charged.
     (4)  Open burning ban, except for backyard (which is banned on Oahu).
     (5)  Agricultural burning controlled through a permit system.
     EPA anticipates  the  reevaluation of this strategy through the use of
diffusion modeling because of some doubt as to the applicability of the
"rollback" method of relating emissions to resulting air quality on an island-
wide basis.

2.3.2   Sulfur Oxides Control Strategy
     At the time of submission of the original SIP, it appeared that all S02
standards were being met and therefore, no control strategy was required to
attain the national standards.  To maintain the standards, the State adopted a
new source review system.  This strategy was approved by EPA.  The definition
of "new sources" in these regulations does not include modification at existing
                                   8

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facilities such as fuel switching.  Therefore, existing sources can switch
to higher sulfur content fuel, which may or may not cause air quality viola-
tions, without going through this review procedure.
     Although not part of the SIP, the State also has a fuel  sulfur content
regulation, comprising of a limitation of 0.5% for units larger than 250
million Btu/hour heat input and a maximum of 2.0% sulfur for units less than
250 million Btu/hour heat input.

2.4  SPECIAL CONSIDERATIONS - HAWAII
     There appears to be two problem areas in the SIP control strategies.
The technique used to quantify the effects of the particulate strategy on
ambient concentrations is limited and possibly not suited for use in Hawaii.
This is because the islands are not single airsheds with uniform mixing.  Also,
the SIP did not include fugituve dust in the emission inventory.  EPA is
presently funding the collection of this data.
     Although air quality data collected by EPA and the State indicate no  S02
violations of the NAAQS, a monitoring study conducted by the Hawaiian Electric
                                                                3             3
Company in May, 1973 show 24 hour S02 concentrations of 418 ^ig/m  and 207  )ig/m
in the vicinity of the Kahe Power Plant on Oahu.

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                           3.0  AQCR ASSESSMENTS

3.1  REGIONAL AIR QUALITY ASSESSMENTS
     Any assessments of TSP air quality for the State of Hawaii  should be done
on an individual Ssi and basis, rather than considering the AQCR  as a whole.
This is because particulate matter is an areawide problem on each island and
the emissions and air quality on any given island have very little influence
on the emissions and air quality of another.  S0? air quality should be
evaluated on an individual source basis, as it is a localized problem.  H&wever,
insufficient TSP and SOp air quality data on such a fine scale precluded these
approaches.  As a result the analysis presented in this report is done on an
AQCR basis.
     Tables B-l and B-2 summarize the data which provide a number of indications
for deciding whether or not emission limiting regulation revisions can be made.
A word of caution must be mentioned concerning the particulate regulations.
Even though the analysis indicates that the regulations need not be revised, it
must be remembered that fugitive dust emissions were not accounted for in the
SIP and no fugitive dust control strategy was devised.

3.2  POWER PLANT ANALYSIS
     There are presently eight power plants in the State of Hawaii, all of
which are oil fired and do not have the capability of burning coal without
extensive modification.  Consequently, no analysis was made in regard to
switching to coal as a fuel, only on the effects of utilizing oil with charac-
teristics different from what is presently  being burned.
     Because there are no regulations governing the emission of particulate
matter from power plants, no analysis was carried out for particulates.  The
only regulation regarding S02 emissions is a fuel sulfur content limitation.
Although this rale was promulgated to assure maintenance of the state S02 air
quality standards, the analysis for the maintenance of the national secondary
standard was made with this regulation as a guideline.  Since the state S02 air
quality standard is stricter than the corresponding national standard, adherence
to the fuel sulfur content rule should assure that national staridards will not
be exceeded.
                                         10

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     Table C-l illustrates the results of the analysis.  As can be seen,
there would be a net reduction in S02 emissions if the power plants were to
use the maximum permissible sulfur content oil  under state regulation.

3.3  AREA SOURCE ASSESSMENT
     The State of Hawaii was found to have no area sources which could be
evaluated within the context of Section 4 of ESECA.

3.4  INDUSTRIAL/COMMERCIAL/INSTITUTIONAL SOURCE ASSESSMENT
     This category of point sources in the State of Hawaii are rather unique
in that a large number of these sources utilize bagasse as a fuel.  However,
this is not surprising, considering that agriculture is an extremely important
industry in the State.  No analysis was done for those sources burning bagasse,
since no fuel  savings can be realized by switching to a fossil fuel.   For sources
using residual oil (the only other type of fuel burned), no evaluation of the
consequences of changing to a different sulfur content oil on particulate
emissions was  carried out, since particulate emissions from residual  oil combus-
tion comprises less than 3% of the total fuel combustion particulate emissions
(the remainder is from burning bagasse).  As was the case with power plants,
the State fuel sulfur content regulation is used to assess the effects of fuel
switching.
           i
     Table D-l presents the changes in emissions which would occur if 95% of
the major point industrial, commercial and institutional sources were in com-
pliance.  The  net result is a reduction in S02 emissions.

3.5  FUEL ASSESSMENTS

3.5.1  Energy  Supply Potential
     The State of Hawaii has no indigeneous supplies of fossil fuel.   There is
the possibility of potential supplies of geothermal  power.
                                      11

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             APPENDIX A - STATE IMPLEMENTATION PLAN BACKGROUND

     •  State implementation plan information
     •  Current air quality information
     •  Current emissions information
     Tables in this appendix summarize original  and modified state imple-
mentation plan information, including original  priority classifications,
attainment dates, ambient air quality standards, and fuel  combustion emis-
sion regulations.  SAROAD data for S00 and TSP  monitoring  stations are shown
                                     ^              1
for AQCRs in the state.   NEDS emissions data by AQCR  are  tabulated and
broken down into fuel burning categories.
     Tables A-lOa and A-lOb show a comparison of emission  inventories in  the
original SIP and those from the NEDS.  An emission tolerance, or emission
tonnage which might be allowed in the AQCR and  still not violate national
secondary ambient air quality staddards, is shown for SOp  and particulates.
Tolerance was based on either the degree of control expected by the SIP or
upon air quality/emission relationships which are calculated from moce recent
data.  In the former case, a tolerance is calculated from:
       (allowable emissions (as calculated in the SIP) to  meet national
        secondary standards) - (SIP predicted emissions at the attainment
        date)
In the latter case, a tolerance is calculated from:
       (Allowable emissions (as calculated from current air quality data)
        to meet national standards) - (current  emissions (as obtained
        from NEDS)}
The value of the emission tolerance provides an indication of the degree  of
potential an AQCR possesses for fuel revisions  and regulation relaxation.
Methodology for Increased Emissions Tolerance
     A tolerance for increased emissions was determined as follows.  First,
an "allowable emissions" was calculated for each AQCR based on the current
NEDS data and the percent reduction (or increase) required to meet the nation-
al secondary ambient air quality standards in that AQCR (worst case from
Tables A-5 and A-6).  This "allowable" was then compaeed to that from the SIP.
If reasonable agreement occurred, then the "estimated emissions" which would
result after implementation of the SIP in that  AQCR was used to calculate an
emissions tolerance.  Thus, some credit could be given to  an AQCR which might
be restricting emissions more than required by  ambient air quality standards.
For instance, emission controls applied to AQCRs other than the example region
In1972 National Emissions Report, " EPA - 450/2-74-012, June 1974.
                                       13

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for the state may reduce emissions well  below "allowables."   In  the event
that no data existed or was available from the SIP for an  AQCR,  the current
air quality was used to assign emissions tolerance based on  proportional
rollback or roll up.  Current air quality was also the criteria,  if emissions
data from SIP and NEDS did not appear to be comparable (this is  often  the
case).
     When no SIP emissions data was available, and current air quality
levels were less than one half of the level represented by an ambient air
quality standard, no "rollup" emissions tolerance was calculated in Tables
A-10 and A-T-T.  This arbitrary cutoff point was chosen so as not to distort
the emissions tolerance for an area.  At low levels of a pollutant, the
relationship between emissions and air quality is probably not linear.'
Although this cutoff may leave some AQCRs with n£ quantifiable emissions
tolerance, it was felt that no number at all would be preferable to a bad
or misleading number.
     It is emphasized that emissions tolerance is a region-wide calculation.
This tolerance obviously makes more sense in, say, an urban AQCR with many
closely spaced emissions sources than in a largely rural AQCR with geograph-
ically dispursed emissions.
 Low concentrations of pollutants probably indicate a  low density of sources
 and that the air quality monitors are not located near  the sources.   Thus
 changes in emissions from the sources will  not result in a linear change  in
 air quality readings.
                                     14

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              APPENDIX B - REGIONAL AIR QUALITY ANALYSIS

     Tables B-l  and B-2 are the assessment of AQCRs which should be
examined for the fuel switching impact on particulate and S02 emissions.
They also provide an identification of those AQCR^  which show little
potential for fuel revision or regulation relaxation if ambient air
standards are to be attained.
     The criteria for candidates are:(l)  the severity and breadth of air
quality violations, (2) the tolerance for emissions increased in the AQCR,
(3) the fraction of total  emissions resulting from  fuel combustion, and
(4) AQMA designations.   It should be noted that an  AQCR may not necessarily
need relaxation  of regulations in order to accomplish fuel switching.
Further, a good  candidate in Tables B-l and B-2 may later show little
potential for fuel switching after individual sources are examined.
Finally, it is possible that an AQCR may  have air quality levels below
standard at present and may require more  strict regulations than currently
exist if all fuel burning sources were converted to dirtier fuels, i.e,,
"average" emission rate now may be below  "average"  regulations.
                                     29

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-------
                APPENDIX C - POWER PLANT ASSESSMENT

     This section is a review of individual power plants by AQCR.  The
intent is to illustrate fuel switching possibilities and particulate and
SOp emissions resulting from these switches on an individual plant basis.
     Current power plant information used to prepare Table C-l were
obtained from three main sources: (1) Federal Power Commission computerized
listings of power plants and their associated fuel use, (2) the National
Coal Association "Steam Tables" listing of power plants and fuel use in 1972,
and (3) NEDS Emissions data.1  For those plants listed by the FPC (1 above),
the 1973 fuel schedule was assumed, otherwise, fuel use is for 1972.  Heat
inputs are those based on actual fuel values where known, and average values
shown in Table C-2 were used where not known.  SO^ and particulates
emissions are those associated with the fuel use shown.  In the case of
particulates, emissions were calculated using NEDS emissions factors applied
to the listed fuel schedule (in both tonnage and lbs/10  Btu).  When a plant
was not listed in NEDS, AP 42 emission factors were used to estimate S02 and
particulate emissions (see Table C-2).
     For the purposes here, it is assumed that when a plant is shown to have
dual fuel capability, it is able to use entirely one fuel or the other.  A
fuel switch calculation is then made, assuming all natural gas use is
replaced by either oil or coal depending on assumed plant capabilities.
Further, oil use is replaced by coal  where possible.  The % sulfur in fuel
(coal or oil) assumed when fuels are switched is indicated in Table C-l.
A plant was then assumed to have the same emission controls as was in effect
when the NEDS emissions were assembled.  The resulting emissions which would
then accompany such fuel switches are tabulated in both tonnage and
lbs/106 Btu.
]NEDS Data Bank 1974
                                     33

-------
     Also shown is the 1975 regulations which are currently applicable to
the given plant, taken from Table A-ll.  (Particulate limits are assumed
to be based on the entire heat input of the plant.   Actual  rules may be
different when applied to each of several  boilers in a power plant or
applied on the basis of design capacity rather than actual  amount of fuel
used.)
     The fuel  switch calculations are intended to show the  magnitude of
emissions increase accompanying a fuel  switch without additional controls.
The exact emissions would depend upon actual fuel mix, amount of sulfur in
fuels, and degree of emissions controls (particulates).
     It might be cautioned,that AQCR total emissions calculated in the
tables of Appendix C (and also Appendix D) may not agree exactly with total
emissions represented in Appendix A (Tables A-8, A-9).  This is a result of
both differing fuel schedules in 1973 compared to previous  years and the
relative "completeness" of the NEDS data bank.
                                      34

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     APPENDIX D - INDUSTRIAL, COMMERCIAL, INSTITUTIONAL SOURCE ASSESSMENT
                /

         Table D-l  in this appendix lists individual  industrial/commercial/
institutional sources of particulates and SOo emissions which might show
fuel switching potential.  The sources are from a NEDS rank order emissions
listing.   A fuel switch emissions calculation is then made similar to that
performed for power plants.
                                    37

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                               BIBLIOGRAPHY
 (1)    "1972  National  Emissions  Report," U.S. Environmental Protection
       Agency,  EPA-450/2-74-012.

 (2)    "Projections  of Economic  Activity for Air Quality Control Regions,"
       U.S. Department of  Commerce, Bureau of Economic Analysis, Prepared
       for U.S.  EPA, August  1973.

 (3)    "Monitoring and Air Quality Trends Report, 1972," U.S. EPA-450/1-
       73-004.

 (4)    "Steam-Electric Plant Factors/1072," 22nd Edition National Coal
       Association.

 (5)    "Federal  Air  Quality  Control Regions," U.S. EPA, Pub. No. AP-102.

 (6)    "Assessment of  the  Impact of Air Quality Requirements on Coal in
       1975,  1977 and  1980," U.S. Department of the Interior, Bureau of
       Mines, January  1974.

 (7)    "Fuel  and Energy Data," U.S. Department of Interior Bureau of Mines,
       Government Printing Office, 1974, 0-550-211.

 (8)    "Compilation  of Air Pollutant Emission Factors, 2nd Edition," U.S.
       EPA, Air Pollution  Tech., Pub. AP-42, April 1973.

 (9)    SAROAD Data Bank, 1973 Information, U.S. EPA.

(10)    Federal  Power Commission, U.S. Power Plant Statistics Stored in EPA
       Data Bank, September  1974.

(11)    "State of Hawaii  Air  Pollution Control Implementation Plan,"
       January  11, 1972.
                                      40

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                                   TECHNICAL REPORT DATA
                            (Please read Instructions on the reverse before completing}
1. REPORT NO.
  EPA-450/3-74-069
                              2.
                                                            3. RECIPIENT'S ^CCESSION'NO.
4. TITLE AND SUBTITLE
  IMPLEMENTATION PLAN  REVIEW FOR HAWAII AS
  REQUIRED BY THE ENERGY SUPPLY AND ENVIRONMENTAL
  COORDINATION ACT
                                                            5. REPORT DATE . _ ,
                                                              December 1974
             6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
                                                            8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
  U.S.  Environmental  Protection Agency, Office of Air
  Quality Planning and Standards, Research  Triangle
  Park, N.C., Regional  Office IX, San Francisco,
  California, and TRW.  Inc.. Redondo Beach. California
                                                            10. PROGRAM ELEMENT NO.
             11. CONTRACT/GRANT NO.

                68-02-1385
12. SPONSOR I N.G AGENCY NAME AND ADDRESS
  U.S.  Environmental  Protection Agency
  Office of Air and Waste Management
  Office of Air Quality  Planning and Standards
  Research Triangle Park, North Carolina  27711
              13. TYPE OF REPORT AND PERIOD COVERED
                    Final
             14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
16. ABSTRACT
       Section IV of the  Energy Supply and  Environmental Coordination Act of 1974,
  (ESECA) requires EPA  to review each State Implementation Plan  (SIP) to determine
  if revisions can be made to control regulations for stationary fuel combustion
  sources without interfering with the attainment and maintenance of the national
  ambient air quality standards.  This document, which is also required by Section
  IV of ESECA, is EPA's report to the State indicating where  regulations might  be
  revised.
17.
                                KEY WORDS AND DOCUMENT ANALYSIS
                  DESCRIPTORS
                                              b.lDENTIFIERS/OPEN ENDED TERMS
                           c. COSATI Field/Group
 Air pollution
 State implementation  plans
18. DISTRIBUTION STATEMENT


  Release unlimited
19. SECURITY CLASS (ThisReport)
  Unclassified
21. NO. OF PAGES
      40   >
20. SECURITY CLASS (Thispage)

  Unclassified	
                           22. PRICE
EPA Form 2220-1 (9-73)
                                             41

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