EPA-450/3-7 5-010
APRIL 1975
IMPLEMENTATION PLAN REVIEW
FOR
ARKANSAS
AS REQUIRED
BY
THE ENERGY SUPPLY
AND
ENVIRONMENTAL COORDINATION ACT
U. S. ENVIRONMENTAL PROTECTION AGENCY
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EPA-450/3-75-010
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r
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{| IMPLEMENTATION PLAN REVIEW
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^ ARKANSAS
REQUIRED BY THE ENERGY SUPPLY AND ENVIRONMENTAL COORDINATION ACT
PREPARED BY THE FOLLOWING TASK FORCE:
U. S. Environmental Protection Agency, Region VI
1600 Patterson - Suite 1100
» Dallas, Texas 75201
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
April 1975
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ARKANSAS
ENERGY SUPPLY AND ENVIRONMENTAL COORDINATION ACT
(SECTION IV - STATE IMPLEMENTATION PLAN REVIEW)
TABLE OF CONTENTS
Page
1.0 EXECUTIVE SUMMARY 1
2.0 REVIEW OF THE STATE IMPLEMENTATION PLAN AND CURRENT AIR QUALITY 7
2.1 Summary 7
2.2 Air Quality Setting for the State of Arkansas 12
2.3 Background on the Development of the Current State
Implementation Plan 14
2.4 Special Considerations for the State of Arkansas 18
3.0 AQCR ASSESSMENTS 20
3.1 Regional Air Quality 20
3.2 Statewide Fuel Use for Point Sources 21
3.3 Power Plant Assessment 21
.3.4 Industrial/Commercial/Institutional Source Assessment. . . 23
3.5 Area Source Assessments 25
4.0 TECHNICAL APPENDICES
APPENDIX A A-l
APPENDIX B B-l
APPENDIX C C-l
APPENDIX D D-1
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 (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
SO^ emission regulations. The States have also been asked to discourage
large scale shifts from cool 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 SCL regulations. These States are
generally in the Eastern half of the United States. ESECA, however, extends
the analysis of potentially over-restrictive regulations to all 55 States
and territories. In addition, the current reviews address the attainment
and maintenance of all_ the National Ambient Air Quality Standards.
There are, in general, three predominant reasons for the existence of
overly restrictive emission limitations within the State Implementation
Plans. These are 1) The use of the example region approach in developing
State-wide air quality control strategies; 2) the existence of State Air
Quality Standards which are more stringent than NAAQS; and 3) the "hot spots"
in only part of an Air Quality Control Region (AQCR) which have been used
as the basis for controlling the entire region. Since each of these situa-
tions 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 p_r_ 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 r,oms 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
1imitations. The findings of this report are by no_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
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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 (S(L) emissions. This is because stationary
fuel combustion sources constitute the greatest source of SCU emission and arc
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 revising
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 State Implementation Plan Review has addressed the emissions from
fuel combustion sources in each of Arkansas' seven AQCRs. For the reader's
convenience a map showing Arkansas and its AQCRs is shown on page 6.
The major findings of this review are as follows:
• As required by Section IV of ESECA, the Implementation Plan
for the State of Arkansas has been reviewed with particular
attention to the most frequent causes of overly restrictive
emission limiting regulations. It does not appear that
regulations for TSP and S0?_ are overly restrictive, however
the formats of the regulations do not lend themselves to
definitive analysis of restrictiveness. Arkansas' particulate
and SOo regulations specify a maximum ambient concentration
and/or a maximum fallout rate to be observed beyond the
premises of a source. As a result, it is not possible to de-
termine whether observed air quality is due to regulations
which could limit the use of certain fuels, or to an otherwise
specific level of emissions.
• With the possible exception of the Arkansas AQCR, there are
indications of a widespread particulate problem throughout
the State. Air quality data, combined with the current plans
for air quality maintenance in the Central Arkansas AQCR,
suggest that any increase of emissions in the State would only
aggravate the current TSP situation.
• This review finds no indication that SOo NAAQS are being violated.
However, because the restrictiveness of the State's SOo regula-
tion cannot be evaluated, it is not known if Arkansas' low ambi-
ent S02 levels are the result of an overly restrictive control
of emissions, a low level sulfur content of the fuel used, or to
some other factor such as meteorology.
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There are no indications that Arkansas' major stationary
sources use solid fossil fuels. None of the State's nine
power plants have been designed to utilize such fuels, but
six plants had experience of using both oil and gas in 1973.
Only nine of Arkansas' 53 fuel burning industrial sources
show a capability to use oil in additional to natural gas.
This fact may limit the potential for effective fuel
switching in the industrial sector.
On a statewide basis, natural gas is the major fuel used in
Arkansas' stationary fuel combustion sources. It accounts
for approximately 58% of the hourly heat input to this type
of facility. Oil is the next most used fuel and it provides
about 30% of the State's hourly heat input. Wood and wood
wastes provide the rest of the State's hourly heat input.
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METROPOLITAN
FORT SMITH
INTERSTATE
(ARKANSAS-
OKLAHOMA)
(017)
NORTHWEST
ARKANSAS
INTRASTATE
(021)
SHREVEPORT
TEXARKANA-
TYLER
INTERSTATE
(ARKANSAS
LOUISIANA-
OKLAHOMA-
TEXAS)
(022)
MONROE-
EL DORADO
INTERSTATE
(ARKANSAS-
LOUISIANA)
(019)
NORTHEAST
ARKANSAS
INTRASTATE
(020)
METROPOLITAN MEMPHIS
INTERSTATE
(ARKANSAS-
MISSISSIPPI-
TENNESSEE)
(018)
CENTRAL
ARKANSAS
INTRASTATE
(016)
Figure 1. Air Quality Control Regions in Arkansas
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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?
t 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 limiting regulation. In conjunction with
the regional analysis, a characterization of the State's fuel combustion
sources (power plants, industrial sources, and area sources) has been
carried out in Appendices C, D and E.
Based on an overall evaluation of EPA's current information, AQCRs
have been classified as "good," "marginal," or "poor" candidates for
regulations revisions. These ratings, which are shown in the Summary
Table on page 10 were determined by assessing the following criteria:
Good Poor Marginal
1) Adequate number 1) Violation of NAAQS 1) No air quality
2) No NMQS violations 1975 otorng sites
3) Attainment date of 3) Proposed AQMA ,v T«/.««^< «.*««*
tn-tc f „ hinnnc •_ £) inCOnS I S ten U
1975 for NMQS in 4) Modeling results "indicators"
™e ilK show no potential
4) No proposed AQMAs for regulation
5) Modeling results rev1s1on
show a potential
for revision
For an AQCR to be rated as a good candidate, all of the criteria
listed under "Good" would have to be satisfied. The overriding factor in
rating an AQCR as a poor candidate is a violation of either the primary
or secondary National Ambient Air Quality Standards during 1973. However,
if any of the other conditions listed under "Poor" exists, the AQCR would
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still receive that rating. The predominant reason for a marginal rating
is a lack of sufficient air quality data. Marginal ratings are also
given when there are varying or inconsistent "indicators."
After a candidacy has been given to a region, a follow-up analysis
should be conducted depending on the rating. A region that has been
indicated to be a good candidate for regulation revision should be
examined in more detail by the state and the regional office of the EPA,
including an examination of current air quality, emissions, and fuel use
data, with which the state has more familiarity. If the state feels
that clean fuels could be saved in a region rated marginal, then an
analysis of air quality data that may have become available since this
report should be examined. If current data do not indicate a potential
for regulation revision then further study would not be warranted. An
AQCR that has been indicated to be a poor candidate would not warrant
further study unless the state feels that new information has become
available indicating that the poor rating is no longer valid.
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2.2 AIR QUALITY SETTING FOR THE STATE OF ARKANSAS
The State of Arkansas is one of five States in EPA Region VI (the
others are Louisiana, New Mexico, Oklahoma and Texas). Arkansas is
divided into seven AQCRs. These are listed below:
016 - Central Arkansas Intrastate
017 - Metropolitan Fort Smith Interstate
018 - Metropolitan Memphis Interstate
019 - Monroe - El Dorado Interstate
020 - Northeast Arkansas Intrastate
021 - Northwest Arkansas Intrastate
022 - Shreveport-Texarkana-Tyler Interstate
Tables A-l, A-2 and A-3 summarize information which characterizes the
air quality, and provides other related parameters in the AQCRs. In Table
A-l the following information is presented:
1) Priority classifications for the pollutants under study
2) Demographic data
3) Counties within the State which are proposed Air Quality
Maintenance Areas (AQMAs).
Priority classifications give an 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 have been
either observed, estimated (in the absence of adequate measured air quality
data), or predicted (due to the expected presence of future sources). A
Priority III designation is used when pollutant concentrations are generally
lower than NAAQS.
With respect to the pollutants under study, Table A-l shows Metropolitan
Memphis AQCR (018) as the only Priority I AQCR for particulates. Four of the
other AQCRs have Priority II designations for TSP, while the remaining two
are Priority III. All of the State's AQCRs are designated Priority III for
both SOV and NO.
A A
Proposed Air Quality Maintenance Area (AQMA) designations are a means
of identifying those areas in the State which, due to current air quality
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and/or projected growth rate, may have the potential for exceeding any
national standard within the ten year period 1975-1985. These designations
have been proposed by either the State or by EPA. The Little Rock-North
Little Rock areas have been proposed as AQMAs for TSP.
Table A-2 presents the dates when the ambient level of the pollutants
under study are expected to be within the limits set by NAAQS. These dates
were established at the time the original SIP was approved; however, in some
cases, EPA and the State are currently considering amending these dates.
Table A-3 shows a summary of the federal ambient air quality standards
for the pollutants under study. The Arkansas SIP references these
air quality standards, making the State standards identical to
NAAQS.
The data in Tables A-4 and A-5 provide a more detailed picture of the
State's recent (1973) air quality setting. Table A-4 shows the Northeast
Arkansas AQCR (020) having the highest TPS reading. The Table also shows
particulate matter problems, with NAAQS violations occurring
in all AQCRs except the Northwest Arkansas AQCR.
The S02 air quality data presented in Table A-5 shows generally low
values with the highest Arkansas readings being recorded in the
Metropolitan Memphis AQCR.
The most current data available (namely 1972 emissions obtained from
NEDS data bank, December 1974) was used to compile the particulate and SOp
emissions, respectively. From Table A-7 it can be seen that 51.3% of the
particulate emissions produced within the State originate in the Central
Arkansas AQCR (016). The second highest emissions (22%) are contributed
by the Northeast Arkansas AQCR (020). Most of the State's particulate
emissions are derived from sources other than fuel combustion. The
Arkansas portion of the Monroe-El Dorado AQCR (019) is the only area in
which fuel combustion accounts for more than half of that area's particulate
emissions. Table A-8 shows that SOp emissions in Arkansas come from
basically three AQCRs, Northeast Arkansas, Central Arkansas, and the Arkansas
portion of Monroe-El Dorado AQCRs. Respectively, these areas contribute 35%
22%, and 22% of the S02 emissions produced within the State of Arkansas. In
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two AQCRs (Northwest and Northeast Arkansas), significant proportions of
these emissions result from fuel combustion processes (82.5% and 70.7%
respectively). In each of the remaining AQCRs, the amount of S02 emissions
that result from fuel combustion ranges between 38.9% and 16.3%.
The Arkansas SIP contains a particulate emissions inventory for the
Central Arkansas AQCR (016) which shows the emissions that existed in 1970,
and those that would be expected after implementation of the control stra-
tegy. This information is shown in Table A-9 for the purpose of comparing
1970 emissions data with the 1972 data shown in Table A-7. These emissions
are presented in such a manner that the contribution from Pulaski and
Saline Counties (which are the State's major emitters of particulate matter)
can be viewed separately.
The information shows that fuel combustion from stationary sources
accounted for only 2% of the AQCR's 1970 particulate emissions. Though
there is a discrepancy between this value and the magnitude of the corres-
ponding figure from Table A-7, both are consistent in that they support the
conclusion that fuel combustion was an unimportant source of particulate
emissions in the Central Arkansas AQCR during both 1970 and 1972.
The SIP contained no emissions data for SO^, so there can be no
comparison between 1970 and 1972 levels for this pollutant.
2.3 BACKGROUND OF THE DEVELOPMENT OF THE CURRENT STATE IMPLEMENTATION PLAN
Arkansas' SIP is entitled, "The Arkansas Plan of Implementation for Air
Pollution Control." It was developed by the Arkansas Department of Pollution
Control and Ecology, and was subsequently adopted by the Commission on Pollu-
tion Control and Ecology. Several alternative control strategies were
considered by State officials, but the one selected for detailed evaluation
in the SIP was one based on the statutory and regulatory provisions of the
Arkansas Air Pollution Control Code (hereafter referred to as the Air Code).
This code has been in effect since July 1969. It was amended in January
and July of 1972.
The Air Code includes one set of regulations of general application to
be administered in all portions of the State. However, according to the SIP,
these regulations contain specific internal mechanisms by which more stringent
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controls can be required in those areas where a multiplicity of sources
can potentially produce locally adverse effects.
The SIP brings attention to a series of provisions that have been
built into the control strategy so as to provide an added margin for
NAAQS attainment. This margin is produced by:
1) The use of a conservative value for the TSP background.
In this case "conservative" means use of the relatively
high value of 40 ug/nv* (AAM). Use of a high background
tends to produce a requirement for more stringent controls.
2) Applying the emission reductions of the Air Code only to
those sources that involve process losses during the evalua-
tion of the control strategy.
3) The inclusion of emissions from some of the smaller point
sources into the area source category, and then assume that
all emissions from the area source category would be un-
controllable. This was done in spite of the SIP's indication
that area sources will be controlled.
4) Granting operation permits only if State is con-
vinced that the facility in question will not cause a
violation of the Air Code, or NAAQS. Furthermore, the
applicant has to show that the equipment to be used incor-
porates existing advances in control technology, for the air
pollutants involved.
The SIP states that the combination of the margins of safety, and the
State's ability to require more stringent controls when necessary all serve
to provide adequate assurances that NAAQS can be attained and maintained
throughout the State regardless of future industrial and demographic
patterns. Only two possible problems that may threaten the attainment of
this goal are indicated. They are 1) the unavailability of natural gas as
a major fuel for power generation, and 2) the extent to which some of the
particulate sources are not accounted for in the emissions inventory.
For the development of the State's control strategy, the Example
Region approach was used. The State's most populated and most heavily
industrialized area (Saline and Pulaski Counties) was used for this purpose.
These two counties comprise only 12% of the Central Arkansas AQCRs1 nineteen
county area but they produced more than 50% of the AQCRs' 1970 particulate
emissions. This is shown in Table A-9.
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While the Central Arkansas AQCR is designated Priority II for
participates, another AQCR (namely Metropolitan Memphis Interstate (018)),
has a Priority I designation for this pollutant. However, this AQCR's
Priority I classification is mostly the result of emissions produced in
the large metropolitan and industrial area of Memphis, Tennessee. The SIP
indicates that the air pollution control agencies for the other States
involved in this AQCR expect control of sources under their jurisdiction,
and therefore, decrease the incidence of NAAQS violations within the
Arkansas portion of the AQCR.
The evaluation of the State's control strategy consisted of basically
two steps. First, the appropriate emission limiting provisions of the
Air Code were applied to 1970 emissions in the example region to determine
the level of emissions that would result when selected sources were
controlled (see Table A-9). These controlled emission levels were then
used as inputs for the Air Quality Display Model (AQDM). This model provides
estimates of the air quality that would be expected, given certain emission
levels within an area. Using this method of analysis, an ambient annual
geometric mean (AGM) for TSP of less than 50 ug/m was projected for 1975
within the Saline and Pulaski Counties area. Since the national secondary
TSP standard is 60 ug/m^ (AGM), the above finding demonstrates NAAQS
attainment in this area.
The ambient SOp concentrations projected using AQDM techniques were
below the levels set by NAAQS. The measured S09 levels (of approximately
3
10 ug/m ) as shown in Table A-6 were also below the national standard for
this pollutant. Because of these low S02 levels, Arkansas was not required
to prepare a control strategy for this pollutant.
A summary of the State's regulations that apply to particulate and
SOo emissions from fuel burning equipment is presented in Table A-10. The
particulate regulation corresponds to Section 7 of the Air Code, while the
S02 regulation is Section 8.
The S02 regulation has two sub-sections; the first one sets the maximum
ambient concentration limit (as shown in Table A-10), while the second
sub-section indicates that this maximum concentration can be determined by
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either ambient sampling, or via applying dispersion formulas to stack
concentrations. This second sub-section is not shown in Table A-10.
The particulate regulation is more complex and involved. It has six sub-
sections. The first and second (7(a) and 7(b)) seem to be the only ones which
set limits for fuel burning equipment. These are shown in Table A-10. The
first sub-section is similar to the SCL regulation in that it sets limits for
all equipment capable of emitting air contaminants. It stipulates the maximum
ambient concentrations and maximum amounts of particulate fallout allowed. The
SIP states that experience shows this to be the most stringent sub-section of the
regulation.
While the SIP also implies sub-section 7(b) applies to all equipment, this
portion of the regulation (as written) applies only to equipment which has been
installed, altered, or replaced after the effective date of the Air Code.
(Section 19 of the Air Code indicates that this date is July 7, 1972.) This
sub-section uses a graph (shown in Figure A-2) that relates the allowable emission
level to the potential emission rate. This latter term is defined as the total
weight rate of particulate emissions for any air contamination source which is
operating at maximum rated capacity, and which has no air control apparatus
installed. When a number of such sources (each of which is capable of being
operated individually) are manifolded together so that their emissions are
discharged to a single flue, the potential emission rate and allowable emission
rate for each source shall be determined individually.
Two other sub-sections (7(c) and 7(d)) of the particulate regulation
apply specifically to manufacturing equipment and asphalt mix plants respectively.
An industry for which the limits of sub-section 7(a) are unduly restrictive,
can opt to be subject to be the limits imposed by sub-section 7(c). However,
in that this sub-section specifically excludes gaseous and liquid fuels, only
those fuel burning facilities using wood could possibly be considered.
(Available data shows no fuel burning facilities within Arkansas which utilize
coal.)
Sub-section 7(e) concerns exemptions to the regulations in relation to
visible emissions. Of importance to this review is the exemptions provided for:
outdoor fireplaces connected with residences, non-commercial food preparation,
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and the use of incinerators and heating equipment in residential dwellings
for not more than four families. Thus, these area sources are not covered
by particulate limiting regulations.
Sub-section 7(f) refers to the utilization of methods and formulas
for projecting parameters such as (1) effective stack height, (2) maximum
concentration downwind from the source of emission irrespective of concen-
trations of particulate matter in the atmosphere from sources other than
that of the applicant's and (3) distance from source at which maximum
concentration will occur.
2.4 SPECIAL CONSIDERATIONS
It is impossible, within the context of this review, to accurately
determine the extent to which these sources are in compliance with the
applicable regulations. And for this reason, it is also impossible to
definitively evaluate the restrict!'veness of these regulations. This
situation is in large, due to the format of Arkansas' emission regulations
for particulates and SO,,. The regulations were not specifically designed to
apply to fuel burning equipment; neither of them were stated in the manner
normally used for this type of equipment, (that is, by prescribing the
number of pounds of pollutant that can be emitted for every 10 Btu of
energy produced). Sub-section 7(a) of the particulate regulation and
the S02 regulation are both stated in terms of ambient concentration
observed at any point beyond the premises where the source is located.
Regulations written in this format are sometimes referred to as "property
line regulations," and often have inherent enforcement problems. The
entire situation is further complicated by the fact that sub-section 7(b)
is not applicable to all equipment, but rather only to equipment which has
been installed after the effective date of the regulation.
Without additional detailed information on each source, it would be
impossible to accurately and efficiently determine which of the sources are
covered by this sub-section. For these reasons, sub-section 7(b) has little
usefulness for evaluative purposes within the context of this review.
However, even though this situation allows for little to be said directly
about the restrict!'veness of the State's regulations, available information
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does allow for comment on the possible effects of regulation relaxation.
This topic will be dealt with in Section 3 of this review.
In addition to the regulations listed in Table A-10, the Air Code
contains other regulations which relate to fuel burning sources. The first
of these is sub-section 3(f) in the Air Code which requires the use of
state-of-the-art technology in all equipment for which a permit is necessary.
It also requires fuel burning equipment to operate in a manner such that
optimum combustion is achieved. Sub-section 3(d) indicates that in addition
to other specified equipment, operating permits are not required for 1) gas
fuel and No. 1 and No. 2 fuel oil burning equipment used for space heating,
service water heating and electric power generation (less than 60,000
Ibs/hour steam capacity) and 2) for fuel-burning, refuse-burning and cooking
equipment used in connection with a structure designed and used exclusively
as a dwelling for not more than four families.
A sub-section of another regulation, (Section 13(b) in the Air Code)
makes allowances for the possibility of periods of non-compliance with the
Air Code due to a forced change of fuels, or lack thereof. According to
the SIP, this sub-section was the result of a January 1972 amendment to the
Air Code, and though not specifically mentioned, its intent revolves pri-
marily around the change from natural gas to another (dirtier) fuel due to
the diminishing supply of the former.
The fact that an AQMA designation for TSP has been proposed for the
Little Rock-North Little Rock area has been mentioned earlier. Any changes
to the State's SIP that may result from a formal designation of this area
may be of importance to the content and conclusions of this review, and
therefore, would be additional special considerations.
At the time the plan was approved, the Fort Smith Standard Metro-
politan Statistical Area (SMSA) in the metropolitan Fort Smith AQCR was
listed as a proposed AQMA for particulates. But based on recent thinking
of EPA Region VI, it appears unlikely that this area will be promulgated.
The attainment dates shown in Table A-2 were based on information
published in the Federal Register. However, after a recent analysis of
air quality data, EPA and the State of Arkansas are currently evaluating
the prospect of revising these dates.
19
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3.0 AQCR ASSESSMENTS
3.1 REGIONAL AIR QUALITY
Tables A-ll and A-12 present the results when the proportional model
is used with 1973 air quality data to estimate tolerance for emissions
increase. This display should be viewed in light of the limitations men-
tioned in Section 1.0. The portion of these tables that apply to SIP
information was included as a means of summarizing the emission control
goals of the State. However, Arkansas' SIP contained the necessary
detailed data for only the Central Arkansas AQCR, therefore, comparisons
can be made in this region only.
Tables B-l and B-2 are summaries of a number of the indicators which
should be considered when estimating the potential for regulation relaxation.
Based on the information presented in Tables A-ll and B-l, any
increases in particulate emissions would tend to aggravate an air quality
situation which is typified by TSP violations in all except one of the
State's AQCRs.
Each of Arkansas' AQCRs have a tolerance for increased S02 emissions
without violating NAAQS (see Table A-12 and B-2). To determine an allow-
able level of increased emissions would require an analysis involving
diffusion modeling. However, it should be noted that most of the fuel
switches that could generally be utilized for increasing SO^ emissions
(i.e., use of residual oil, high sulfur oil, or coal instead of gas) would
also produce corresponding increases in particulate emissions, and thus
further aggravate the State's TSP situation.
While the Central Arkansas AQCR (016) was used as the Example Region
for the development of the State's control strategy for particulates, it
is worthwhile to note that 1973 data shows the highest annual and 24 hour
TSP readings occurring in the Northeast Arkansas AQCR (020). In fact, the
ambient TSP air quality in the Central Arkansas AQCR is better than the
corresponding air quality in a variety of the other AQCRs. The cause for
these high TSP levels in AQCRs other than the Example Region is possibly
due to fugitive dust emissions.
20
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3.2 STATEWIDE FUEL USE FOR POINT SOURCES
Table B-3 shows the major fuels in the State can be categorized
as natural gas, oil and wood. Included in this last category is bagasse,
the cellulose material that remains after the processing of sugar cane.
It should be noted that the figures involving the wood category in Table
B-3 are based on the assumption that materials in this category have an
average heat content of 5000 Btu/lb. The heat values of materials in this
category vary widely depending on their composition and moisture content.
The heat contents for relatively dry wood typically range between 6000 and
8000 Btu/lb, the 5000 Btu/lb figure appears to be a relatively conservative
estimate. Due to the variability of heat values, moisture content, and
resultant emissions of the individual fuels in this category, the 5000 Btu/
Ib estimate has been used solely in those calculations aimed at providing
a first approximation of the relative importance of these materials as
fuels within Arkansas.
3.3 POWER PLANT ASSESSMENT
The tables that comprise Appendix C provide a listing of the power
plants in the State along with a general description of each plant's emis-
sion characteristics. This listing and information was obtained from the
NEDS data on individual sources.
As shown in Table C-l, Arkansas has a total of nine power plants.
Information from the Steam-Electric Plant Factors publication show that
their installed generating capacity varies from 27.7 megawatts electric
(Mwe) to 869.6 Mwe. The State's total capacity is 2405 Mwe. It is some-
what surprising to note that 47.7% of this generating capacity was produced
in the Northeast Arkansas AQCR (020), while only 37.8% was produced in the
Example Region.
The State's largest generating capacity power plant (869.6 Mwe) is
located in the Northeast Arkansas AQCR and it has a total hourly heat input
of 3715 x 10 Btu. The State's next largest power plant is in the Central
Arkansas AQCR. (Generating capacity is 693.6 Mwe and heat input is
3742 x 10 Btu/hour.) The Steam-Electric Plant Factors publication indicates
that six of Arkansas' nine power plants were designed to utilize gas and/or
21
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oil as a fuel, while the remaining three plants were designed for gas
only. However, this publication also presents information showing that
these three plants had both oil and gas experience in 1972. Federal
Power Commission (FPC) fuel schedules for 1973 did not include data for
one of these plants, but it did corroborate the dual fuel use for the other
two. As indicated by the information in Table B-3, natural gas accounts
for 51% of total hourly heat input to the State's power plants, with oil
providing the remaining 49%.
The Northeast Arkansas AQCR contains four of the State's nine power
plants. Most (60%) of the hourly heat input to these plants is obtained
from the combustion of oil. This is quite different from the situation
in the Central Arkansas AQCR where 59% of the hourly heat input to power
plants comes from natural gas. Thus assuming the absence of control
equipment (which, according to NEDS data is generally the case for
Arkansas' power plants), one would expect the overall emission level from
power plants in the Northeast Arkansas AQCR to be higher than the corres-
ponding levels in the Central Arkansas AQCR.
The fact that all except one of the State's power plants have a dual
fuel capability increases the potential feasibility of fuel switches aimed
at clean fuel savings. The Northwest Arkansas AQCR (021) is the only AQCR
which has a tolerance for accepting additional particulate
emissions. There is only one power plant in this AQCR, and it did have
both oil and gas experience in 1973. Information in the Table C-l for this
AQCR shows that, based on the plant's oil burning experience, the plant oil
could be substituted for its 1973 supply of natural gas, and still not sur-
pass the 100 ton/yr tolerance for increased particulate emissions calculated
for this AQCR. Any fuel switches which increase SO, emissions would
have to be done in a way so that particulate emissions are not increased.
22
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3.4 INDUSTRIAL/COMMERCIAL/INSTITUTIONAL SOURCE ASSESSMENT
Table D-l presents the pertinent fuel combustion data for point
sources in the industrial/commercial/institutional sector (commonly
referred to as the industrial sector in this review). This information
was obtained from NEDS emission data for the individual sources.
As shown in Appendix D, there are a total of 53 specific industrial
fuel burning sources within the State of Arkansas. Thirty-four of these
use wood only, nine use only gas, one uses bagasse, and the remaining nine
use a combination of either two or three of these fuels. In this last
category three sources use oil, gas and wood; another three use both gas
and wood, and the remaining three use oil and gas only. Industrial sources
are the only major stationary fuel burning installations in the State which
utilize wood as a fuel. Lumber, paper, and furniture companies make up the
bulk of this group that uses wood.
Twenty-six of the State's 53 industrial sources are located in the
Central Arkansas AQCR. Nineteen of these use wood only, and four use only
natural gas. The remaining three use a combination of fuels.
Within the industrial sector, the bulk of the heat input to stationary
fuel burning equipment comes from natural gas. Wood and wood waste products
provide the next largest segment, while oil provides the remaining portion
of the heat input to the State's industrial equipment. Using the 5000 Btu/lb
heat content estimate for wood, (as was done in Table B-3), the contributions
of the various fuels to the total hourly heat input of Arkansas's industrial
equipment would be as follows:
natural gas 67%
wood 24%
011 9%
Because of the uncertainty associated with the 5000 Btu/lb figure, the above
percentages should not be viewed as being absolute, but rather, they repre-
sent an approximation of the relative contributions from these fuels.
Though the Central Arkansas AQCR has the largest number of the wood
burning industrial sources, it did not account for the largest amount of
23
-------
wood used in 1972. While a total of 712,180 tons of wood was used as fuel
in the Central Arkansas AQCR, 870,570 tons were used in the Arkansas portion
of the Monroe-El Dorado Interstate AQCR (019). The AQCR consuming the third
largest amount of wood in the State was the Arkansas portion of the
Shreveport-Texarkana-Tyler AQCR (022).
With regards to a potential fuel switch to achieve clean fuel savings,
only those facilities that have multiple fuel experience should be con-
sidered as candidates. Based on available data on the past fuel experience
of industrial sources, only nine of the State's 53 sources have this
capability. However, it is not known to what extent the various fuels can
be interchanged among all pieces of fuel burning equipment at each of these
facilities. But assuming complete interchangeability of fuels at these
facilities, fuel switches aimed at clean fuel savings could potentially
occur in the following AQCRs since these are the only ones which have
sources that burn fuels other than natural gas.
Central Arkansas (016) - one source burning oil, gas, and
wood, and two sources burning wood
and gas.
Arkansas portion of - two sources burning oil, gas and
Monroe-El Dorado (019) wood, and two sources burning oil
and gas.
Northeast Arkansas - one source burning oil and gas
(020)
Arkansas portion of - one source burning wood and gas
Shreveport-Texarkana-
Tyler (022)
Since the State's only AQCR which can tolerate increased particulate emis-
sions is not in the above list, fuel switches at Arkansas' industrial sources
can be used to accomplish only those clean fuel savings associated with
increasing S02 emissions. However, because of the State's widespread TSP
problems, these fuel switches could not have corresponding increases in
particulate emissions.
24
-------
3.5 AREA SOURCE ASSESSMENTS
Area sources in Arkansas offer little, if any, potential for
achieving clean fuel savings within the context of ESECA.
25
-------
APPENDIX A
9 State implementation plan information
9 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 S09 and TSP monitoring stations are shown
c i
for AQCRs in the State. NEDS emissions data by AQCR are tabulated and
broken down into fuel burning categories.
/
Tables A-12 and A-13 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 S(X, 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
lM1972 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-12 and A-13. 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 nip_ 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-ll. Comparison of 1971 and 1973 Fuel Use in Arkansas Power Plants a
Plant 1
Lynch
Plant 2
Lake Catherine
Plant 3
Bailey
Plant 4
Moses
Plant 5
Ritchie
Plant 6
Fitzhugh
Plant 7
Couch
1000 BBL Oil
1971 1973
332.8 207.75
537.4
i.8
507.90
1078.00
39.80
75.60
2391.12
202.90
753.70
2800.29
162.6
177.63
106 ft3 Gas
1971 1973
5078.44 5464.38
31225.34
4775.31
1072.16
35045.91
2318.79
7004.61
17442.03
959.57
0.00
14342.11
726-OU
6252.39
Totals
2660
6696
86521
45186
a Based on Federal Power Commission fuel schedules as retrieved from EPA data files
July, 1974.
A-18
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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.
B-l
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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 taken from NEDS. SCs 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
S02 and particulate emissions, based on fuel schedules. Those plants which have
emissions data modified by FPC information are marked with an asterisk(*).
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 shov.-n to have dual fuel capability, it is able to use
enti rely one fuel or the other.
Also shown is the 1975 regulations which are currently applicable to
the given plant, taken from Table A-9,. (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.
The units for the annual amounts of fuel used for individual sources in
this Appendix are 103 gallons for oil, and 106 cubic feet for natural gas.
C-l
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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.
The units for the annual amounts of fuel used are as follows:
3
10 gallons for oil
10 cubic feet for natural gas
tons for wood and bagasse.
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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) "Energy Potential from Organic Wastes: A Review of the Quantities and
Sources," Bureau of Mines Information Circular 8549, Department of
Interior, 1972, written by L. L. Anderson.
(12) "Arkansas Plan of Implementation for Air Pollution Control, submitted
January 28, 1972 by Governor Dale Bumpers.
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
i
4.
7
9.
12
15
16
17
a.
REPORT NO. 2. 3. RECIF
EPA-450/3-75-010
TITLE AND SUBTITLE 5. REPO
IMPLEMENTATION PLAN REVIEW FOR ARKANSAS AS REQUIRED
BY THE ENERGY SUPPLY AND ENVIRONMENTAL COORDINATION 6-PERF
ACT.
AUTHOR(S) 8. PERF
PERFORMING ORGANIZATION NAME AND ADDRESS 10. PRO
U. S. Environmental Protection Agency, Office of
Air Quality Planning and standards, Research in angle H.CON
Park, N.C., Regional Office VI, Dallas, Texas, and
TRW, Inc., Redondo Beach, Calif.
. SPONSORING AGENCY NAME AND ADDRESS 13. TYP
U. S. Environmental Protection Agency 14- SP°
Office of Air and Waste Management, OAQPS
Research Triangle Park, North Carolina 27711
. SUPPLEMENTARY NOTES
'lENT'S ACCESSION"NO.
RT DATE
ORMING ORGANIZATION CODE
ORMING ORGANIZATION REPORT NO.
GRAM ELEMENT NO.
TRACT/GRANT NO.
E OF REPORT AND PERIOD COVERED
MSORING AGENCY CODE
. 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.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS b. IDENTIFIERS/OPEN ENDE
Air Pollution
State Implementation Plans
13
DISTRIBUTION STATEMENT 19. SECURITY CLASS (This t
RPIM«P unHmitPd Unclassifi
20. SECURITY CLASS (This /
Unclassifi
D TERMS c. COSATl Field/Group
Report) 21. NO. OF PAGES
ed 75
•>age) 22. PRICE
ed
EPA Form 2220-1 (9-73)
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