EPA-450/3-74-083
DECEMBER 1974
IMPLEMENTATION PLAN REVIEW
FOR
OKLAHOMA
AS REQUIRED
BY
THE ENERGY SUPPLY
AND
ENVIRONMENTAL COORDINATION ACT
U. S. ENVIRONMENTAL PROTECTION AGENCY
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EPA-450/3-74-083
IMPLEMENTATION PLAN REVIEW
FOR
^ OKLAHOMA
§ REQUIRED BY THE ENERGY SUPPLY AND ENVIRONMENTAL COORDINATION ACT
CO
* PREPARED BY THE FOLLOWING TASK FORCE:
uj
-s.
^ U. S. Environmental Protection Agency, Region VI
1600 Patterson - Suite 1100
Dallas, Texas 75201
Environmental Services of TRW, Inc.
(Contract G8-02-1385)
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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TABLE OF CONTENTS
Page
1.0 EXECUTIVE SUMMARY 1
2.0 REVIEW OF THE STATE IMPLEMENTATION PLAN 6
2.1 Summary 6
2.2 Introduction 7
2.3 Air Quality Setting - State of Oklahoma 7
2.4 Background on the Development of the Current State
Implementation Plan 14
2.5 Special Considerations - Oklahoma 17
3.0 AQCR ASSESSMENTS 19
3.1 Regional Air Quality 19
3.2 Power Plant Assessment 22
3.3 Industrial/Commercial/Institutional Source Assessment. . 23
3.4 Area Source Assessments 23
TECHNICAL APPENDICES
APPENDIX A - State Implementation Plan Background A-l
APPENDIX B - Regional Air Quality Analysis B-l
APPENDIX C - Power Plant Assessment C-l
APPENDIX D - Area Source Assessment D-l
BIBLIOGRAPHY
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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 (NAAQSs). 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 SIPs, 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
SO^ emission regulations. The States have also been asked to discourage
largo 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 revised
or are currently in the process of revising S(L 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 al_l_ the National Ambient Air Quality Standards.
There are, in general, three predominant reasons for the existence of
overly restrictive emission limitations within the State Implementation
Plans. These are: 1) the use of the example region approach in developing
State-wide air quality control strategies; 2) the existence of State Air
Quality Standards which are more stringent than NAAQS; and 3) the "hot spots"
in only part of an Air Quality Control Region (AQCR) which have been used
as the basis for controlling the entire region. Since each of these situa-
tions 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 -SIPs were approved by EPA if they demonstrated the attainment
of NAAQSs or more stringent state air quality standards. Also, at that time
an acceptable method for formulating control strategies was the use of an
example region for demonstrating the attainment of the standards.
The example region concept permitted a State to identify the most
polluted air quality control region (AQCR) and adopt control regulations
which would be adequate to attain the NAAQS in that region. In using an
example region, it was assumed that NAAQS would be attained in the other
AQCRs 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
limitations. Jhe findjngs of this report are bynq_means conclusive and
are neither intended nor adequate to be the sole basis for SIP revisions;
they do, however, represent EPA's best judgment and effort in complying
with the ESECA requirements. 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 restrictive 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
J\
air pollution problems such as sulfates .
Although the enclosed analysis has attempted to address the attainment of
all the NAAQSs, most of the review has focused on total suspended particulate
matter (TSP) end sulfur dioxide (SCL) emissions. This is because stationary
fuel combustion sources often constitute the greatest source of SO,, 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 AQCRs. The
regional emission tolerance estimate is, in many cases, EPA's only measure
of the "over-cleaning" accomplished by a SIP. The tolerance assessments
have been combined in Appendix B with other regional air quality "indicators"
in an attempt to provide an evaluation of a region's candidacy for changing
emission limitation regulations. In conjunction with the regional analysis,
a summary of the State's fuel combustion sources (power plants, industrial
sources, and area sources) has been carried out in Appendix C, D, and E.
The following map of Oklahoma shows the State's AQCRs. (Figure A-l).
The major findings of the study are:
a As required by Section IV of ESECA, the SIP for the State of
Oklahoma has been reviewed with particular attention to the
most frequent causes of over-restrictive emission limiting
regulations. Even though the Example Region approach was used
in the development of the control strategy, the regulation
covering particulate emissions does not appear to be over-
restrictive"! Due to low ambient S02 levels, the State did
not have to prepare a control strategy for S0£ in its SIP.
Even though there is no delay in scheduled attainment dates
for parti culates, there are indications of widespread parti-
culate problems. NAAQS violations for TSP were reported in
every Oklahoma AQCR. In addition, the State has two
proposed TSP AQMAs.
t The State's regulation for existing SOg sources is based on
ambient air (S02) concentrations observed beyond the polluter's
property line. For this reason, evaluation of its restric-
tiveness was precluded using the methodology established for
this review. Therefore, it is not definitely known whether
Oklahoma's low ambient S02 levels are due to an overly res-
trictive emission regulation, to a low level of overall
baseline emissions, or to some other factor.
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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
(1) power plants, (2) industrial sources, (3) area sources?
Did the State use an example region approach for demonstrating the
attainment of NAAQS or_ more stringent State standards?
Has the State not initiated action to modify combustion source
emission regulations for fuel savings; i.e., under the Clean Fuels
Policy?
Are there no proposed Air Quality Maintenance Areas?
Are there indications of a sufficient number of monitoring sites
within a region?
Is there an expected 1975 attainment 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?
Is the fraction of total emissions from stationary fuel combustion
sources higher than those of other sources?
Do modeling results for specific fuel combustion sources show a
potential for a regulation revision?
Must emission regulations be revised to accomplish significant fuel
switching?
Based on the above indicators, what is the potential for revising fuel
combustion source emission limiting
Is there a significant clean fuels savings potential in the region?
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 limit-
ing regulations. In conjunction with the regional analysis, a character-
ization of the State's fuel combustion sources (power plants, industrial
sources, and area sources) has been carried out in Appendix C, D, E.
Based on an overall evaluation of EPA's current information, AQCRs
have been classified as good, marginal, or poor candidates for regulation
revisions. The following table on page 8 summarizes the State Implementation Plan
Review. The remaining portions of the report support this summary with
explanations.
2.2 INTRODUCTION
The purpose of this section is to summarize and review the development
and the essential content of Oklahoma's State Implementation Plan (SIP). The
SIP is designed to show how the state plans to achieve and maintain national
ambient air quality standards. These standards were promulgated by EPA on
April 30, 1972. The Clean Air Act required the SIPs to be submitted no later
than January 30, 1972. Therefore, the air quality and emission data used in
the development of such a plan would necessarily be of the 1970 or 1971
vintage.
Since 1973 air quality data was assembled, reference will occasionally be
made to this data to illustrate the continuance or discontinuance of any rela-
vant trends.
2.3 AIR QUALITY SETTING - STATE OF OKLAHOMA
The State of Oklahoma is divided into eight Air Qualtiy Control Regions
(AQCRs). These are listed below.
017(7) Fort Smith Interstate
022(8) Shreveport-Texarkana-Tyler Interstate
184(1) Central Oklahoma Intrastate
185(4) North Central Oklahoma Intrastate
186(2) Northeastern Oklahoma Intrastate
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187(6) Northwestern Oklahoma Intrastate
188(3) Southeastern Oklahoma Intrastate
189(5) Southwestern Oklahoma Intrastate
The first number in the above listing is the number assigned to the
regions by the U. S. Environmental Protection Agency as part of a numbering
system for all regions in the United States. The number in parentheses is the
number that the State of Oklahoma uses in its system for designating air
quality control regions within its boundaries. Therefore, while the numbers
017 and 022 correspond to interstate AQCRs that span the boundaries of at
least two states, the numbers 7 and 8 correspond only to the respective por-
tions of those AQCRs that are within Oklahoma's boundaries. For the intrastate
AQCRs, the two numbering systems designate identical areas. Figure A-l shows
the regions and their geographical relationship. Table A-l lists the AQCRs in
Oklahoma and also includes:
1) Priority classifications for pollutants under study
2) demographic information, and
3) portions of the State which have been designated Air
Quality Maintenance Areas (AQMAs)
Priority classifications give a quick indication of the extent to which
certain pollutants pose air quality problems for the AQCR. A Priority I listing
indicates that relatively high ambient concentrations of the pollutant have been
observed (or estimated, in the absence of air quality data) in the AQCR, while the
Priority III designation reflects the pollutant is generally present in concen-
trations below NAAQSs. At the time the SIP was written, a detailed survey of the
then current air quality data showed that two pollutants warranted a Priority I
classification. These were particulates and photochemical oxidants, and this was^only
for two AQCRs (Northeastern and Central Oklahoma).
The listing of an area as a proposed AQMA indicates there is evidence
that there may be problems associated with the area maintaining NAAQS. Such
problems could be due to the expected addition of new major sources in the
future, or to predictions of accelerated growth in the area. If an area ultim-
ately becomes an AQMA, it is likely that special, more restrictive changes,
will have to be made to existent regulations and/or air pollution control plans.
Table A-l indicates only two AQCRs have proposed AQMAs. These are for TSP,
and correspond to the State's two major urban areas (around Tulsa and Oklahoma
City). AQMAs for S02 had also been proposed in these same two areas, but recent
(approximately 11/20/74) information received from EPA-Region VI indicates that
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these proposed designations have been dropped.
Table A-2 presents the dates at which various ambient air quality
standards are expected to be attained in the AQCRs in Oklahoma. From this
it can be seen that none of the AQCRs have attainment dates past the July
1975 date which had been originally prescribed for all states. Having attain-
ment dates that occur after July 1975 indicates there is evidence (as
assessed by either the state or by EPA) of problems which will prevent MAAQS
attainment within the time period initially prescribed by law.
A summary of the Federal and Oklahoma ambient air quality standards for
the pollutants under study is presented in Table A-3. As noted, these stan-
dards are equivalent to the National Primary and Secondary Air Qualtiy Stan-
dards.
Of the pollutants under study, the SIP gives air quality data only for
particulates, and only for the Northeastern and Central Oklahoma regions.
To obtain this data for the SIP, state officials used a network which monitored
approximately 10 locations in the Northeastern AQCR (186)- The sampler loca-
tion having the highest measured concentration (that was deemed valid) recorded
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an Annual Geometric Mean (AGM) of 129/ig/m . The corresponding secondary
3
standard is 60yug/m . The sampling period was from January 1, 1970 to December
29, 1970. A total of 104 samplers were used to obtain this result.
A somewhat less extensive network was set up to monitor approximately
nine locations in the Central Oklahoma AQCR (184). Twenty-four samplers were
used during the period from April 5, 1971 to November 28, 1971. In this sampl-
ing program the sampler location with the highest concentration showed a
reading of 116.4 (AGM).
These results can be compared with 1973 air quality data. Summaries of
Oklahoma's 1973 Air Quality status for TSP and SOp are presented in Tables
A-4 and A-5, respectively. Examination of Table A-4 reveals that there seems
to have been a switch between the Northeastern and Central AQCRs as to which
has the most adverse air quality with respect to particulates. While both
regions continue to violate the secondary annual standard, the Northeastern
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AQCR (186) exhibits a drop of 40/ig/m from its annual high in 1970. The
Central region shows only a 2.4^ug/m drop since the readings made in 1971,
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The overall result is that the Central AQCR (184) has a highest annual
reading which is 25/ig/m3 higher than that observed in the Northeastern
AQCR (186). Table A-4 also shows that the second highest 24-hour TSP
reading in the Central Oklahoma AQCR, is more than three times the second
highest reading in any other AQCR in the State.
The SIP did not include air quality data for SC^ therefore, comparisons
cannot be made with 1973 data. However, review of Table A-5 can lead to
some possibly relevant observations. Most of the AOCRs exhibited SCk air
quality which was better than that required by national ambient standards.
Information supplied to EPA-Region VI by Oklahoma air pollution control officials
indicates that the State's highest reported ambient S02 concentrations (high and
2nd highs of 396 and 249 jbg/m3 for the North Central AQCR-185) were more than
likely due to a smelter which has since been closed. It was also indicated to
Region VI that the S02 concentrations reported to the SAROAD air quality data
bank for the Northeastern AQCR (186) were in error. The numbers gtven in Table
A-5 reflect the correction which was due to a misplaced decimal. (SAROAD
indicates highest and 2nd highest readings of 1227 and 729/ig/m3 respectively.
The corrected values are 123 and 73 ng/m3).
Examination of Table A-5 also shows that the AQCR with the largest number
of stations reporting (Central Oklahoma) has relatively good S02 air quality.
On the other hand, the AQCR which has the highest S02 readings in the State
(North Central Oklahoma - AQCR 185) has only one monitor. This is particularly
striking because at the time the SIP was written, a non-ferrous smelter located
in the North Central AQCR accounted for 75% of all S02 emissions in the State.
The Oklahoma SIP contains results of a statewide emission inventory which
included SOp and particulates. The inventory was performed by GEOMET Incorporated
under contract to EPA in conjunction with the Air Pollution Control Division,
Oklahoma State Department of Health. This inventory is considered representative
of the 1970 calendar year, and though not meant to be interpreted as absolute
values, it is to be considered a realistic estimate. A listing of these overall
emissions by AQCR for each of the major air pollutants is shown in Table A-6
in Appendix A. It should be noted that this inventory is not identical to that
which appeared in the original SIP, but is based on a revised inventory (dated
10/16/72) which was resubmitted along with other portions of the SIP that had
been disapproved by EPA. The differences between the two versions was significant
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increases in the amounts of point source particulate emissions listed for
Northeastern Oklahoma (AQCR 186) and for North Central Oklahoma (AQCR 185).
The new estimates were 2.8 and 3.7 times the original emissions in those
two respective regions. It would appear that for interstate AQCRs, the
inventory applies only to portions of the AQCR within Oklahoma.
According to that inventory, process sources account for most of the
particulate emissions in all of the regions, with the exception of the Shreve-
port-Texarkaka-Tyler Interstate AQCR (022). (The Oklahoma portion of the
Shreveport-Texarkana-Tyler Interstate AQCR contributes only 0.2% of total
particulate emissions in the statewide inventory, so its effect on overall
state trends is minimal.)
In most of the regionSjprocess sources comprise approximately 80% of
the particulates. As can be seen in Table A-6, the overwhelming majority
(90.3%) of particulates come from point sources.
Oxides of sulfur emissions primarily come from the following three
major sources categories: fuel combustion, process sources, and transpor-
tation. The percent from each category is fairly evenly distributed through-
out all regions except North Central Oklahoma (AQCR 185). In this region
a single non-ferrous smelter produces 75% of the S02 emissions in the entire
state. Point sources contributed 85,6% of the State's sulfur oxide emissions,
while the remaining 14.4% come from area sources.
Figure A-2 shows the breakdown of emissions for the two AQCRs for
which the SIP provided air quality data, Northeastern (186) and Central (184)
Oklahoma. It should be noted that the percentage breakdown for particulates
in the Northeastern AQCR is based on the emissions figure for that region as
presented in the original SIP. This figure was 33,874 tons. The revised
emissions inventory for that AQCR (dated 10/16/74) shows emissions totalling
up to 109,210 tons. Thus, the percentage breakdown shown in the figure below
for Northeastern Oklahoma may vary depending on how the extra 75,336 tons
were distributed among the various categories.
Table A-7 summarizes the fuel combustion sources in the State by AQCR.
Inclusion of data from both the National Emission Data Bank System (NEDS),
and from a Federal Power Commission printout not only provides current infor-
mation about power plants in the State, but also points up some of the data
inconsistencies that exist.
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The most current data available was used to compile the particulates
and S02 emissions information shown in Tables A-8 and A-9. These tables show
that the largest proportion (45%) of the particulates emitted in the State
originate in the Northeastern AQCR, while 62% of the State's S02 emissions
come from the North Central AQCR, The emission inventories included in the
SIP also indicated that the Northeastern AQCR accounted for 45% of the State's
particulate emissions, but the North Central AQCR's contribution of the State's
S02 emission was listed as being 78%. Thus,with respect to the State's total
S02 emissions, the North Central AQCR has actually accomplished a significant
decrease since the writing of the SIP.
The particulate emissions shown for the Central AQCR in Table A-8 do not
reflect the high TSP measurements recorded in that region as shown in Table
A-4.
Tables A-8 and A-9 also show that the emissions which result from fuel com-
bustion are a relatively small component of total emissions, and that most of
the emissions from interstate AOCRs do not originate in the Oklahoma portions.
2.4 BACKGROUND ON THE DEVELOPMENT OF THE CURRENT STATE IMPLEMENTION PLAN
Oklahoma's control strategies were based on the Example Region approach.
Two AQCRs were used for this purpose, Northeastern (186) and Central Oklahoma
(184). The SIP developed control strategies for particulates and photochemical
oxidants, and demonstrated its effectiveness via application to estimated
emissions from these two example regions. In development of the control strategy,
the proportional model was used to determine the amount of rollback necessary
to meet the required standards.
Oklahoma's control strategy is based on compliance with selected regula-
tions which have been promulgated pursuant to the Oklahoma Clean Air Act. There
are a total of 18 regulations which cover a wide variety of pollutants,
including S02 and particulates emissions resulting from fuel-burning and other
processes. A summary of current regulations which relate to emissions from fuel-
burning processes in Oklahoma is presented in Table A-10. The reader will note
that the emission limit for particulates from fuel-burning .equipment is dependent
upon the level of hourly heat input to that equipment. The higher the heat input,
Information in NEDS as of July 27, 1974
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the lower the level of allowed emissions. However, in no case are particulate
emissions allowed to be greater than 0.6 lbs/10 Btu.
From the way the regulation is written,it appears that the emission limit
applies to the pollutants coming from each stack. Thus,the applicable
emission limit Is based on the heat input to all fuel burning equipment which
supplies this stack, and to determine this limit, the number of fuel burning
units per stack would have to be known for each facility. This level of detail
is beyond the scope of this anlaysis, therefore, the aggregated heat input
to all fuel burning equipment at a facility (as based on NEDS data) was used
to determine the applicable emission limit.
As shown in Table A-10, Oklahoma has differing S02 emission regulations for
new and existing sources. The regulation for existing sources is stated in terms
of ambient S02 concentrations observed beyond the property line of the polluter.
It is reasonable to expect that most of the State's stationary fuel burning S02
emitters fall into the existing sources category. Therefore, this property line
regulation provides the bulk of Oklahoma's control over S02 emissions.
This regulation is quite different from Oklahoma's S02 emission regulation
for new fuel burning sources which specifically relates the amount of emissions
allowed directly to the amount of fuel burned (pounds of SO per million Btu).
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The Federal New Source Performance Standards (which applies almost exclusively
to new power plant facilities) is also written using this same format.
In effect,Oklahoma's ambient concentration property line regulation does not
constitute an emission limiting regulation, mainly because it does not specify
an emission limit. The ambient S02 concentration maximum stated in the regula-
tion could result from a wide variety of differing emission levels depending on
the fuel combustion process,meteorology, monitoring sites and a host of other
factors. Furthermore, (and more within the context of this review), it is diffi-
cult to address the restrictiveness of a regulation which does not perform a
regulatory function. Thus, in light of these points, and also the fact there
are no S02 NAAQS violations in the State, (thus implying that there may not be
a need for a stringent S02 emission regulation), it is assumed in this review
that Oklahoma has no S02 emission limiting regulations for most of the State's
stationary fuel combustion sources. It is recognized that new fuel burning sources
do have specifically stated emission limits as the result of an Oklahoma regula-
tion for these sources. It is also recognized that new steam generating facilities
will have to comply with the S09 emission limits imposed by the Federal New Source
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Performance Standards. But, it seems reasonable to expect that the emissions
from these new sources will be small in comparison to those from existing
sources.
The preferred control strategy for particulates as developed in the SIP
was based on the following regulations:
Regulation No. 1 - Prohibition of Open Burning
Regulation No. 6 - Pertaining to the Control of the Emission
of Particulate Matter from Fuel-Burning
Equipment
Regulation No. 8 - Pertaining to the Control of the Emission of
Particulate Matter from Industrial and Other
Processes and Operations
Regulation No. 9 - Control of Fugitive Dust
For the purpose of control strategy testing as presented in the SIP,
it was assumed that there would be additional reductions of particulate
emissions as required by the Federal Automotive Emission Control Program,
and from increased aircraft utilization of smoke reducing engines. This
assumption was teamed up with the first three of the above regulations to
form a combined strategy. When this strategy was applied to the emissions
of the example region (Northeastern, AQCR 186), the SIP demonstrated that
secondary air quality standards could be achieved, and maintained through
1980. When applied to the Central Oklahoma AQCR, similar results were ob-
tained, with the exception that the secondary standard was 3% short of being
maintained for 1980. However, the additional (but difficult to quantify)
emission reductions that would result from Regulation No. 9 (Control of
Fugitive Dust), is expected to provide the extra margin needed.
Since S02 did not present a major air pollution problem in the state
at the time the SIP was written, (all regions were then classified Priority
III for S02), the State was not required to formulate a control strategy for
this pollutant.
It should be noted that the bulk of the emission reductions fall into
the Process Source category. For the Northeastern AQCR, total emissions were
given above (including the transportation source reductions for autos and
aircraft) results in a total reduction of 106,094 tons/year. These reductions
are broken down as shown below:
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Process Source Reductions 101,754 tons/year
Fuel Burning Source Reductions 743 tons/year
Open Burning Source Reductions 2,588 tons/year
Transportation Source Reductions 1,009 tons/year
106,094
Thus, approximately 96% of the emission reductions are via limitations on
process sources while only 0.7% are due to controls on fuel- burning
equipment.
2.5 SPECIAL CONSIDERATIONS - OKLAHOMA
As indicated in Table A-l, two areas in Oklahoma have been proposed
as AQMAs for TSP. The two areas comprise Tulsa and its surroundings (in the
Northeastern AQCR), and the Oklahoma City area (in the Central Oklahoma AQCR).
Such a designation indicates special requirements may have to be developed
for these areas, and when approved by EPA, may result in modifications on
the SIP.
The regulations which comprise the basis of Oklahoma's control strategy
for particulates were all supposed to be in effect as of October 15, 1972.
Thus, one'would expect emissions in Oklahoma to have been controlled as of
this date in the same manner they would be controlled at the State's latest
expected attainment dates (7/75). The only exceptions to this statement
would be: (1) those sources which are presently operating under variance, and
(2) the existence of any more stringent regulation which has a later full
compliance date. Information from the EPA Region VI office indicates there
are only three variances which have been given to major sources in Oklahoma.
They were:
1. National Zinc (Bartlesville)
2. Blackwell Zinc
3. Sun Oil Company
Of these, National Zinc will be operating in compliance May 31, 1975:
Blackwell Zinc has shut down; and Sun Oil is expected to be in compliance
as of December 31, 1974. Thus, unless the emissions from these sources were
massive, their operation should not have posed a major threat to adversely
alterning the State's air quality.
17
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With regard to the second exception, it appears that the sulfur
oxide emission limits on new, liquid fuel burning equipment, is the only
regulation involving more stringent regulation taking effect after
October 16, 1972. This regulation allows 0.8 lbs/106 Btu before July 1,
1975, but only 0.3 lbs/10 Btu after that date. However, the burning of oil
(or other liquid fuels) at stationary installations in the State account for
only a fraction of the total emissions.
Thus, Oklahoma currently has in effect essentially all of the controls
which the SIP prescribes for the attainment and maintenance of National
Ambient Air Quality Standards. Any indication of attainment being off
schedule should be viewed seriously, in that it suggests either a lack of
enforcement or an inadequate level of control. Such a situation would be
of special importance to any assessment of Oklahoma's ability to relax
regulations. In light of these facts, 1973 air quality data for TSP would
not allow revisions that would result in less restrictive regulations.
18
-------
3.0 AQCR ASSESSMENTS
3.1 REGIONAL AIR QUALITY
Tables A-ll and A-12 present the results when a proportional model
is used to estimate tolerance for emission increase. This display should
be viewed in light of the limitations mentioned in Section 1.0.
The magnitude of negative tolerance for emissions increases, (as shown
in Table A-ll) should not be used as a measure of an AQCR's relative stand-
ing in terms of tolerating more emissions. This magnitude is very much
affected by the total emissions in the AQCR. Thus, the -5280 ton TSP
tolerance for the Central Oklahoma AQCR (184) does not reflect the fact that
this region has ambient TSP levels which are higher (i.e. is dirtier) than
does the Northeastern Oklahoma AQCR (which has a TSP tolerance of -25,740 tons).
The inclusion of information from the SIP in Tables A-ll and A-12 is meant
to summarize (to the best extent possible with the limited data) the air quality
goals of the SIP. However, Oklahoma's SIP lacked the necessary air quality data
for either this type of analysis, or for comparison with 1973 data to any large
degree. Nevertheless, the SIP data presented does give an idea of the types of
reductions which were expected in two AQCRs (Central and Northeastern) once the
emission controls were in effect.
Tables B-l and B-2 provide summaries of some of the indicators which should
be considered when estimating the potential for regulation relaxation. The
overall regional evaluation of this chart is based upon consideration of these
indicators, and on the more complete summary of indicators found at the
beginning of Section 2 of this report.
With regards to particulates, the overall assessment >s that on an AQCR
basis, any increase in particulate emissions would tend to aggravate a
situation where NAAQS TSP violations already occur in each of the 8 AQCRs which
involve Oklahoma.
19
-------
Table B-l highlights one definable area which has an air quality
which could tolerate additional particulate emissions. This is the
Oklahoma portion of the Fort Smith Interstate AQCR (017), and its good
air quality is probably related more to the absence of major point sources
rather than to over-restrictiveness of regulations. Examination of
Tables A-7, A-8, and those in Appendix D show there is only one fuel
combustion point source in this portion of the Fort Smith AQCR. As
indicated on Table A-8, this source accounts for only 0.11% of all parti -
culates emanating from fuel combustion in the Oklahoma portion of this
AQCR.
The information presented in Table B-2 indicates there is room for
increasing S02 emissions, to varying degrees, in each of Oklahoma's AQCRs.
The tolerance for SOp emission increases was calculated for the North Central
(185) and Northeastern (186) AQCRs, but was not calculated for other AQCRs
because the results would indicate unrealistically high tolerances.
The fact that Oklahoma has a tolerance for increased emissions is
mainly due to the State's relatively good ambient S02 air quality. This
good air quality is evidenced by 1) the absence of S02 NAAQS violations, and
the absence of proposed S02 AQMA designations in the State, and 2) NAAQS
attainment expected or achieved before July 1975. The methodology
established for this review precludes any definite statement about whether
the State's low ambient SOp levels are due to overly restrictive emission
regulations, to low baseline SOp emissions, or to some other factor.
The extent to which significant clean fuel savings could be achieved is
somewhat limited by the relatively small percentage of total SOp emissions due
to fuel combustion in most of the AQCRs. And in those AQCRs where a sizeable
percentage (30-40%) of the emissions are from fuel combustion, the total tonnage
of emissions is small. As shown in Table A-9, most of these emissions are due
to area sources which may have limited usefulness within the context of the
clean fuel savings of ESECA.
The degree to which these S02 emissions can be safely increased will
require more detailed study which, more than likely, will have to include
modeling. But in light of the State's TSP problems, any attempt at clean fuel
savings which allowed an increase in SOp emissions could not have an associated
increase in particulate emissions.
20
-------
It should be noted that particulate limiting regulations do not
necessarily have to be relaxed to achieve increased particulate emissions.
NEDS point source emission data indicates that significant particulate emission
increases could occur within the framework of existing regulations. NEDS
data for power plants and industrial fuel combustion facilities is shown in
Appendices C and D. In every case where gas is the only fuel burned, the
particulate emission regulation is met. Usually these emissions are so low
that they could be increased by a factor of ten or more, and still be within
the constraints of the applicable regulation. (The situation when fuels other
than natural gas are consumed, will be discussed in the following section.)
It is not being suggested that the particulate emissions should be
increased, for this would only tend to aggravate the adverse TSP air quality
problem in the State. However, the point is being made here only to emphasize
the apparent fact that Oklahoma's particulate emission regulations are not
overly restrictive.
Since there are indications that Oklahoma's particulate emission
limiting regulations are not achieving the air quality goals that the SIP
had originally set, it was deemed best to classify any region with a
negative tolerance as a "bad candidate." If additional evidence shows
that Oklahoma's particulate emission regulations are being (or can be)
enforced, and its particulate control strategy is adequate to meet
its desired goals for air quality, then three other AQCRs could possibly
be moved to the "marginal candidate" classification. These would be
Northwestern (187), Southeastern (188), and possibly North Central (185). Such
a designation would be based on the air quality in those regions (actual readings
and number of violations), and the relatively small proportion of the emissions
that come from fuel combustion. The rationale here was that if Oklahoma's
regulations can effectively control the major emitters (process sources), there
may be room for increase emissions from the relatively small fuel combustion
sources in these regions.
21
-------
3.2 POWER PLANT ASSESSMENT
Table C-1 gives relevant data (by AQCR) for power plants now operating
in the State of Oklahoma. This listing shows a total of 18 plants varying
in size from 40 to 945 megawatts electric (MWe). There are no other major
fuel-burning power plants expected to come on line in Oklahoma before 1975.
Most of the plants (13) burn only natural gas. For the remaining five, natural
gas still provides most (>98% in all cases) of the heat input. With three of these
plants the remaining heat is provided with oil, while coal is used in the other
two. Two-thirds of the State's 18 power plants are located in three AQCRs
(Central (184), North Central (185), and Northeastern (186)).
Based on the information contained in NEDS, power plants utilize
approximately 28,460 x 106 Btus of the 31,684 x 106 Btus of heat liberated
every hour from stationary fuel combustion sources in Oklahoma. This corres-
ponds to 89.8%. The remaining 3224 x 106 Btus/hour are due to sources in the
industrial category. Thus, it would appear that any sizeable savings of clean
fuels would have to involve the power plant sector.
As was indicated in an earlier discussion, the plants which are burning
natural gas only, all seem to be in compliance with the applicable emission
regulation for particulates. However, when a facility also uses oil or coal,
not enough information is available to determine whether the particulate
emission regulation is being met. The missing information is whether the
emissions from the oil or coal exit through a separate stack, or whether these
emissions are mixed with the exhaust gases resulting from the combustion of
the natural gas. If the former is the case, then the coal burning facilities
are definitely exceeding the particulate emission limit, but the oil burners
are in compliance. However, rf each facility has only one stack for all of
its combustion emissions, and the applicable emission limit is based on the
aggregated heat input to the entire plant, then all facilities (both power
plants and industrial installations) in the State are within the emission
limits set by the particulate regulation.
A comparison of the emissions and corresponding limits on emissions for
those facilities which burn fuels other than natural gas is shown in Table C-2.
22
-------
For participates,this table also supplies the State's maximum emission
limit, (0.6 lbs/10 Btu). Since this limit applies to units having an
hourly heat input of less than 10 Btu, it gives the applicable limit if the
coal or oil burning facilities were treated as being separate from the gas
burning portions of the plant. For the sake of comparison, SOp emission
limits for new sources are also included in this table, as well as in other
tables of Appendices C and D.
Consideration of a possible fuel switch must devote some attention to
identifying those locations where such a switch would be technically possible.
Data obtained from Electric Steam Plant Factors has provided information
relating to the fuel which power plants were designed to use. This informa-
tion is included in Table C-l. Only two plants were designed for coal, and
those are the same two that, according to the NEDS data presented, have
experienced coal use. These are the Ponca City (40 MWe) and Mustang (509 MWe)
plants operated by the Oklahoma Gas and Electric Company. These plants are
in the North Central (185) and Central (184) AOCRs, respectively. Essentially
all of the power plants in Oklahoma were designed to burn both oil and gas.
Thus, a gas to oil switch would provide greatest flexibility in Oklahoma to
effect clean fuel savings.
3.3 INDUSTRIAL/COMMERCIAL/INSTITUTIONAL SOURCE ASSESSMENT
As indicated in the previous section, only 11.2% of the point source
Btu liberation are from sources in this category. Three of the 28 identified
sources in this category are currently using oil in addition to their major
fuel, natural gas. It is not known to what extent any of the other 25 sources
can effectively switch to a dirtier fuel. Information relating to these
sources are given in Table D-l.
Table D-2 summarizes the emissions from the three installations which
burn oil. It indicates that these oil burners are generally not as clean
as power pi ants which use oil.
3.4 AREA SOURCE ASSESSMENTS
There were no area sources in Oklahoma which could be evaluated within
the context of Section IV of ESECA.
23
-------
APPENDIX A
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*-
si on regulations. SAROAD data for S09 and TSP monitoring stations are shown
^ -\
for AQCRs in the State. NEDS emissions data by AQCR are tabulated and
broken down into fuel burning categories.
Tables A-ll and A-12 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 standards, is shown for SCL and particulates.
The intent of this calculation is to indicate possible candidate regions
for fuel switching. Tolerance was based on either the degree of control
expected by the SIP or upon air quality/emission relationships which are
calculated from more recent data. 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:
The "allowable emissions" were calculated for each AQCR based on 1972 NEDS
data and the percent reduction (or increase) required to meet the national
secondary ambient air quality standards in that AQCR (worst case from
Tables A-4 and A-5).
The percentages used in this calculation were obtained via the use of
current 1973 air quality data and the proportional rollback model. The
values for background TSP concentrations were the same as those used in the
SIP. This background value was used in all calculations involving the
annual standard, but a zero TSP background was assumed for the calculation
of reductions based on the 24-hour standard. (This was done because back-
ground levels are, in effect, an annual average, and therefore, should be
In1972 National Emissions Report," EPA - 450/2-74-012, June 1974.
A-l
-------
compared with only annual data. It is reasonable to expect that the
"real background" for any particular 24-hour period to be different for
other 24-hour periods.)
The NEDS emissions are subtracted from the "allowables" to determine
the tolerance for emissions increase. A positive value for this result
indicates a potential for increasing emissions.
When the 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-ll and A-12. 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 np_ 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
geographically dispursed emissions.
A word of caution regarding particulates needs mentioning. Emission
source estimates in the NEDS data bank and most state SIP's are for total
particulates. Generally, the control strategies for particulates are
aimed at total particulates, while the high-volume particulate sampling
(SAROAD data) measures only the finer, suspended fraction. A given level
of total particulate emissions control will therefore not translate into
the same level of measured ambient air quality. Some of the larger
particulates being controlled will not remain suspended, and therefore would
not be measured by the High-volume technique. Hence, particulate control
plans may have underestimated the amount of control necessary to achieve
ambient air quality standards.
A-2
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Table A-6. Oklahoma State and Regional Area and Point Source Emission Totals
Region
017 Area
Point
Total
022 Area
Point
Total
184 Area
Point
Total
185 Area
Point
Total
1 86 Area
Point
Total
187 Area
Point
Total
188 Area
Point
Total
189 Area
Point
Total
State Area
Point
Total
Tons c
Part
967
3,786
4,753
269
100
369
6,811
8,588
15,399
951
9,755
10,706
5,754
103,456
109,210
1,580
7,343
8,923
3,470
37,003
40,473
3,668
47,524
51,192
23,470
217,555
241,025
so2
377
0
377
164
0
164
5,538
430
5,968
1,106
96,790
97,896
6,030
5,525
11,555
889
6
895
2,149
1,915
4,064
1,847
2,600
4,447
18,100
107,262
125,362
f Air Contaminant Per Year
CO j
33,791
1,440
35,231
1,731
151
1,882
366,559
106
366,665
61,242
116,391
177,633
235,553
120,067
355,620
67,384
4
67,388
136,403
24,630
161,033
93,929
2,334
96,263
996,592
265,123
1,261,715
HC
7,850
460
8,310
774
33
807
81 ,232
6,185
87,417
22,283
7,418
29,701
87,858
12,077
99,935
15,863
465
16,328
31,355
3,234"
34,589
47,308
3,460
50,768
294,523
33,332
327,855
NOX
6,341
44
6,385
478
63
541
48,403
26,200
74,003
8,234
8,543
16,777
35,892
27,163
63,055
12,998
19,299
32,297
25,806
37,967
63,773
14,764
25,646
40,410
153,916
144,925
298,841
A-8
-------
Fuel Combustion
56.4%
Waste 1.6%
Transportation
42.0%
Fuel
Combustion
12.6%
Transportatio
25.6%
SO,
Partlculates
Region 184 - Central Oklahoma
Fuel Combustion
40.5%
Transportatio
15.1%
Transportation
2.0%
Partlculates
Region 186 - Northeastern Oklahoma
Figure A-2. Emissions by Source Category
A-9
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APPENDIX B
Tables B-l and B-2 are the assessment of AQCRs which should be
examined for the fuel switching impact on particulate and SC^ emissions.
They also provide an identification of those AQCRs which show little
potential for fuel revision or regulation relaxation if ambient air standards
are to be attained.
The general criteria for candidacy is covered by the list of questions
found at the beginning of Section 2.0. Some of the more important criteria
is reflected by the tables in this appendix. These criteria include (1)
the breadth of air quality violations, (2) the fraction of total emissions
resulting from fuel combustion, (3) proposed AQMA designations, (4)
expected attainment dates, (5) total regional emissions, and (6) regional
tolerances for emissions increase.
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.
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APPENDIX C
This appendix provides a characterization of individual power plants
by AQCR. Current power plant information used to prepare Table C-l was
obtained from three main sources: (1) Federal Power Commission computerized
listings of power plants and their associated fuel use, (2) the National
Coal Association's Steam-Power Plant Factors, listing of power plants and
fuel use in 1972, and (3) emission data in the NEDS data bank as of
June 29, 1974. Fuel schedules for 1973 were extracted from the FPC data
(1 above), and this was used in conjunction with NEDS emission data to es-
timate 1973 emissions for each of the sources. When 1973 fuel schedules
were not available, 1972 schedules were used as extracted from Steam-Power
Plant Factors. SC^ and particulates emissions are those associated with the
fuel shown. When actual emissions were not listed in NEDS, AP-42 emission
factors were used to estimate SCL and particulate emissions, based on fuel
schedules.
After the name of each plant is a listing of the fuels for which the
plant was designed (from source 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.
Also shown is the 1975 regulations which are currently applicable to
the given plant, taken from Table A-10. (Particulate limits are assumed to
be based on the entire heat input of the plant.)
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-7, A-8). This is a
result of both differing fuel schedules in 1973 compared to previous years
and the relative "completeness" of the NEDS data bank.
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APPENDIX D
The Table D-l in this appendix lists individual industrial/commercial/
institutional sources of particulates and S02 emissions which might show
fuel switching potential. The sources are from a NEDS rank order emissions
listing.
It should be cautioned that the percent emissions accounted for is
different than the "% of fuel use accounted for," It is possible that
several potential fuel switch sources could be overlooked by the cutoff point
on the emissions (i.e., a reasonable sized natural gas used may emit below
our cutoff point in the NEDS rank order list).
No information was available for feasibility of any fuel
switching.
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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 Oklahoma Air Quality Control Implementation Plan, originally
submitted January 28, 1972 by Governor David Hale.
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