EPA-450/3-74-065
DECEMBER 1974
IMPLEMENTATION PLAN REVIEW
FOR
WASHINGTON
AS REQUIRED
BY
THE ENERGY SUPPLY
AND
ENVIRONMENTAL COORDINATION ACT
U. S. ENVIRONMENTAL PROTECTION AGENCY
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EPA-450/3-74-065
IMPLEMENTATION PLAN REVIEW
FOR
WASHINGTON
REQUIRED BY THE ENERGY SUPPLY AND ENVIRONMENTAL COORDINATION ACT
PREPARED BY THE FOLLOWING TASK FORCE:
U. S. ENVIRONMENTAL PROTECTION AGENCY, REGION X
1200-6th Avenue
Seattle, Washington 98101
Environmental Services of TRW, Inc.
(Contract 68-02-1385)
U. S. Environmental Protection Agency
Office of Air and Waste Management
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
December 1974
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TABLE OF CONTENTS
1.0 EXECUTIVE SUMMARY 1
2.0 REVIEW OF THE STATE IMPLEMENTATION PLAN AND CURRENT 7
AIR QUALITY
2.1 Air Quality Setting - State of Washington 8
2.2 Background on the Development of the State 12
Implementation Plan
2.3 Special Considerations 23
3.0 AQCR ASSESSMENTS 25
3.1 Assessment by Regional Air Quality Indicators" 25
3.2 Assessment by Source Analysis of Power Plant/Industrial- 27
Commercial/Area Sources
TECHNICAL APPENDICES
APPENDIX A - State Implementation Plan Background A-l
APPENDIX B - Regional Air Quality Assessment B-l
APPENDIX C - Power Plant Assessment C-l
APPENDIX D - Industrial, Commercial, Institutional Source D-l
Assessment
APPENDIX E - Area Source Assessment E-l
APPENDIX F - Other Analyses F-l
111
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1.0 EXECUTIVE SUMMARY
i
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 requites EPA to review each
State Implementation Plan (SIP) to determine if revisions can be made to
control, regulations for stationary fuel combustion sources without inter-
fering 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 consistent with both environmental and national energy needs.
In many respects, the ESECA SIP reviews parallels EPA's policy on clean
fuels. The Clean Fuels Policy has consisted of reviewing implementation 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 SOg emission regulations. The States
have also been asked to discourage large scale shifts from coal to oil where
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this could be done without jeopardizing the attainment and maintenance
of the NAAQS.
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 SOp 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
situations affect many State plans and in some instances conflict with current
national energy concerns, a review of the State Implementation Plans is a
logical follow-up to EPA's initial appraisal of the SIP's conducted in 1972.
At that time SIP's were approved by EPA if they demonstrated the attainment
of NAAQS oir more stringent state air quality standards. Also, at that time
an acceptable method for formulating control strategies was the use of an
example region for demonstrating the attainment of the standards.
The example region concept permitted a State to identify the most
polluted air quality control region 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 result 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
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result in a regulation requiring one percent sulfur oil to be burned state- v
wide where the use of three percent sulfur coal would be adequate to attain
NAAQS in some locations.
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. 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 emis-
sions. 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 belives 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 quality air. 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 combustion 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 air pollution problems such as sulfates.
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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 (S02) emissions.
This is because stationary fuel combustion sources constitute the greatest
source of S0? emissions and are a major source.of TSP emissions.
Part of each State's review was organized to provide an analysis
of the S^2 and TSP emission tolerances within each of the various AQCR's.
The regional emission tolerance estimate is, in many cases, EPA's only
measure of the "over-cleaning" accomplished by. a SIP. The tolerance
assessments have been combined in Appendix B with other regional air quality
"indicators" in an attempt to provide an evaluation of a region's
candidacy for changing emission limitation regulations. In conjunction with
the regional analysis, a summary of the State's fuel combustion sources
(power plants, industrial sources, and area sources) has been carried out
in Appendix C, D, and E.
The major findings evolving from the study are:
• The review indicates that S02 emission regulations may be
revised in all the regions except the Puget Sound AQCR
without jeopardizing attainment and maintenance of NAAQS.
The review also indicates that present fuel burning
practices are in over-compliance with S02 emission regulations
(due to the use of low sulfur fuels and natural gas), and that
there is room to increase SOg emissions before violating the
emission regulations in each of the AQCRs.
t Particulate emission regulations appear to be overly res-
trictive in only the Northern Washington AQCR. However, in
the Eastern Washington-Northern Idaho, Portland Interstate,
and the Olympic-Northern Washington AQCR's, it is possible
that emission regulations are over-restrictive for significant
areas within the region. These areas are known to possess a
significant portion of the region's major fuel combustion
particulate emission sources. Revision of particulate
emission regulations in both the Puget Sound and South Central
Washington AQCR would only aggravate the current TSP air
pollution situation.
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t Due to natural gas curtailments, and conversions from wood
burning, the use of fuel oils 1s expected to Increase
dramatically 1n the State of Washington in the next few years.
This fuel schedule change may aggravate the $63 problem in the
Puget Sound AQCR, but 1s not expected to conflict with clean
air goals in other regions.
• The impact of plausible fuel switches for clean fuel savings
in the State of Washington would appear to be relatively in-
significant insofar as particulate emissions increases are
concerned. The review indicates the impact of such fuel switches
on S02 emissions would be significant, but would probably not
jeopardize the attainment of S02 air quality standards In.any of
the AQCRs except possibly the Puget Sound Region.
• Areas in which S02 or particulate emission regulations may
be revised without jeopardizing attainment of federal air
standards, are candidates for clean fuel savings. In additions
there are regions where significant fuel savings may be accompli*
shed within the constraints of the regulation emission limits, and
without jeopardizing attainment of federal air standards. The
review analysis Indicates that S02 emissions may be increased
significantly (to obtain clean fuel savings) without violation of
emission regulations or Interference with attainment of air quality
standards in all the regions ..except the Puget Sound AQCR. The
analysis also shows that particulate emissions could not be increased
significantly in any of the AQCRs before violating emissions
regulations. Hence, potential clean fuel savings programs which
would result from fuel switches causing increased emissions of
particulates would be in conflict with both the emission regulations
as well as the ambient air quality standards.
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OLYMPIC-
NORTHWEST
WASHINGTON
INTRASTATE
PUGET SOUND
INTRASTATE
NORTHERN WASHINGTON
INTRASTATE
Okanogan "i Ferry / I
, (Stevens
Clallam :
Jefferson
, tKitsap
Franklin,.
v. .x Walla
Benton'X
EASTERN
WASHINGTON-
NORTHBHN
IDAHO
INTERSTATE
PORTLAND
INTERSTATE
(WASHINGTON-
OREGON)
SOUTH CENTRAL
WASHINGTON
INTRASTATE
Figure 1-1. Air Quality Control Regions in Washington
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2.0 STATE IMPLEMENTATION PLAN REVIEW
A revision of fuel combystion source emissions regulations will
depend on many factors. For example:
f 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 Gr_ more stringent State standards?
• Has the State initiated action to modify combustion
emission regulations for fuel savings; i.e., under the Clean
Fuels Policy?
• Are there proposed Air Quality Maintenance Areas?
t Are there indications of a sufficient number of monitoring sites
within a region?
• Is there an expected 1975 attainnent date for NAAQS?
• Based on repotted (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?
• Based on the State Implementation Plan, are there indications of
a tolerance for increasing emissions in 1975?
• Are the total emissions from stationary fuel combustion sources
less than those from all other sources?
• Must emission regulations be revised to accomplish significant
fuel switching?
• Do modeling results for specific fuel combustion sources show a
potential for a regulation revision?
• Is there a significant clean fuels savings potential in the region?
The following portion of this report is directed at answering these questions.
An AQCR's potential for revising regulations is then determined by a consideration
of the air quality indications represented in the responses to the above questions^
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
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Table 2-1. State Implementation Plan Review (Summary)
oo
"INDICATORS"
which are more stringent than NAAQS?
• Does the State have emission limiting regu-
lations for control of:
1. Power plants
2, Industrial sources
3. Area sources
for demonstrating the attainment of KAAQS or
• Are there proposed Air Oualltv Maintenance
Areas?
• Are there indications of o sufficient number
of monitoring sites within a region?
• Is there an e»pected 1975 attainrent date
for NAAQS?
• Based on reported 1973 Air Quality Data,
do air quality levels meet the NAAQS?
• Based on reported (1973) Air Quality Data,
increasing emissions?
• Based on the State Implementation Plan, are
there indications of a tolerance for Increasing
emissions in 1975?
fro» stationary fuel combustion sources lower
• Do modeling results for specific fuel cc**ustior,
sources show a potential for a regulation revision?
t Oo emission regulations need to be relaxed
to obtain clean fuel savings?
• Is there a significant Clean Fuels Savingd
potential in the region?
STATE
No
Yes
Yes
NO
Yes
Yes
Yes
„ c
'.0
EASTERN WASH.
NORTHERN IDAHO PORTLAND NORTHERN
INTERSTATE INTERSTATE WASHINGTON
AQCR AQCR AQCR
Yes
Yes
Yes
No Yes
No
Yes'
Yes
Yes
Yes
No
Good
Yes
No
No
Yesa
-
No
Margi-
nal
No
Yes
Yes
Yes
So
Margi-
nal
Yes
No
No
Yes
nodel
Good
No
Ves
Yes
Ves
ng res
Good
OLYMPIC-
NORTHWEST
WASHINGTON
AQCR
No
Ves
No
No
res'
Us av
"naT"
No
No
Yes
Yes
liable
PUGET
SOIM
AQCR
No
_ . ,
Yes
Yes
No
No
Poor
No
Yes
"
Yes
No
No
*>T
No
SOUTH
CENTRAL
WASH.
AQCR
No
r,o
Yes
No
No
Poor
No
No
,0
No
Yes
Yes
No
^
Good
Yes
AQCR
These counties are removed from the "hot spot" areas where worst air quality levels are recorded.
without jeopardizing attainn»er,t of federal air standards.
oo sen a e ss o to e ance i ,9 S.
K" refers to the replacement of current fuel schedules with "dirtier fuels, (v-herever erissiors f-or *ue> byrnino sources can i
! jeooirSMng a!taTn™n!of NAAQ5. it ray be riausitTe that fuel resource allocations car be altered fo- clear fuel savinos.")
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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 characteri-
zation of the State's fuel combustion sources (power plants, industrial
sources, and area sources) has been carried out in Appendix C, D and E.
Based on an overall evaluation of EPA's current information, AQCR's
have been classified as good, marginal, or poor candidates for regulation
revisions. The following table summarizes the State Implementation Plan
Review. The remaining portion of the report supports this summary with
explanations.
2.1 AIR QUALITY SETTING - STATE OF WASHINGTON
The following discussion provides a characterization of the various
QQCR's in terms of air quality. It includes an examination of ambient air
standards, emission inventories, and air-monitoring networks.
2.1.1 Air Quality Control Regions
The State of Washington has been divided into six federal air quality
control regions to provide a basis for the adoption of regional air quality
standards and the implementation of these standards. Two of these regions
are interstate and include adjacent counties of Idaho or Oregon. The six
regions and their boundaries are shown in Figure A-l.
The State's most prominent physical feature is the Cascade Mountain
Range, a wide and high topographical and climatic barrier which separates '
the State into two distinct physiographical regions, eastern and western
Washington. Five of the six federal air quality control regions have the
Cascade crest or divide as their north-south boundary.
The topographical and climatological features of the State, while quite
different in eastern and western Washington, present a combination of natural
conditions which at times create an accumulation of air pollutants. In
western Washington, the significant features include: peculiar local and
regional wind regimes; abundance of moisture; fog; and stable atmospheric
conditions with accompanying low-level inversions. In eastern Washington,
the most significant feature affecting the accumulation of air pollutants
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is the occurrence of stable atmospheric conditions, which often persist for
extended periods in the populated valleys.
The priority classification for each of the air quality control regions
for particulates, SCL, and NO , is presented in Table A-2. Table A-2 also
provides an identification of counties which have been designated as Air
Quality Maintenance Areas. The most pressing air pollution problem in the
long term involves particulates. Three of the six AQCRs have been designated
as AQMAs. Only one county has been designated as an AQMA for SOp.
2.1.2 Ambient Air Quality Standards
Ambient Air Standards for the State of Washington are as shown in
Table A-4. The particulate standards are equivalent to the federal secondary
standards, with the exception that east of the Cascade Mountain Crest the level
of the 24-hour standard increases over 150 ug/m according to the same amount
the background partiuclate level exceeds 30 ug/m . For SO , Washington has
adapted more stringent standards than the federal government.
2.1.3 Air Quality Status
/
The 1973 air quality fctatus for the various AQCRs is given in Table A-5.
Table A-5 summarizes the worst cases of air quality for each of the regions
in 1973. Violations of the federal air standards for suspended particulates
occurred in each of the AQCRs, and were more severe in terms of the 24-hour
basis. Three of the regions (Puget Sound, Eastern Washington-Northern Idaho
Interstate and the South Central Washington AQCR) will require more than a 48%
reduction in region-wide emissions to attain the standards from 1973 air quality
levels. Almost all of the AQCRs are subject to heavy source loading in a single
hot spot area. This causes consistent high particulate measurements at the
source-oriented monitoring site, while the remainder of the region may reflect
a much lower particulate profile. Figures A-3 through A-8 demonstrate the
variance in air quality values at different sites within an AQCR. The data
clearly demonstrate the important role of monitoring site selection in
regional air quality characterization. For example, in the Puget Sound AQCR,
separate air quality readings within a few miles perimeter were found to be
markedly different.
Data from the air monitoring networks (Table A-6) of the various AQCRs
indicate that violations of the air quality standards for S02 are not as
frequent as violations of the TSP standard. In 1973, the available data
10
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indicated air quality of all AQCRs except Eastern Washington-Northern Idaho
Interstate and Puget Sound was within attainment of the S02 standards. In
the Washington portion of the Eastern Washington-Northern Idaho Interstate
AQCR, levels of S02 are low and within the national standards. Annual SCL
levels are not reported for the Portland Interstate AQCR, where the imple-
mentation strategy has formulated reductions in SCL emissions to achieve
the State air quality standards in the Clark County portion of the Portland
Metropolitan AQMA. However, the 24-hour averages reported for this region
indicate compliance with federal air standards, and based on historical
trends, it is suspected that the annual average is within compliance of
federal standards also.
The air monitoring network for measurement of ambient S02 concentrations
is illustrated in Figures A-3 through A-8. Measurement of SCL is performed at
21 sites throughout the State. Using this monitoring network, atmospheric
SCL has been evaluated as an air pollution problem under the strict
state ambient air standards. However, actual violations of the federal ambient
air standards for S02 have occurred only in the Puget Sound AQCR. Measurements
from some 9 stations in this region show that Seattle sustained the highest
o
annual SCL level (90 ug/m ) for the State in 1973. A reduction in emissions
in this area of 11% would be required to achieve attainment with the federal
air quality standards.
2.1.5 Emissions Summary
Although it is nearly the. smallest AQCR in area (Table A-2), the
Puget Sound AQCR is (troubled by the greatest quantity of particulate emissions.
Table A-8 shows both the South Central and the Washington portion of the
Eastern Washington-Northern Idaho Interstate contain the smallest particulate
emission rates. However, because of the distribution of these sources in
concentrated masses, the worst air quality measured in these two regions
indicates a substantial emission rollback required to attain the ambient air
standards. Table A-8 also indicates that fuel combustion emission sources
contribute from 6% to 37% of the total particulate emissions in the various
regions (Washington portion only). Most of the fuel combustion particulate
emissions arise from industrial-commercial point sources. Because the greatest
portion (97%) of electrical energy consumed by the State of Washington is
generated by hydroelectric power plants, particulate emissions generated from
i
electrical generating facilities are relatively insignificant in all the AQCRs
11
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except the Washington portion of the Portland Interstate, where 22% of the
emissions of particulates originate from power plants. Particulate emissions
generated by area sources are also relatively small, ranging from 1.0% to
5.2% of the combustion source category particulate emissions.
Table A-7 lists the number of combustion emission sources in each of
the AQCRs. These are the number of emission sources which have been inventoried
in the NEDS and/or the Federal Power Commission Data System. Only 7 power
plants have been identified as significant emission sources throughout the
State. (Three of these are in the Puget Sound AQCR.) There are far moce
industrial-commercial fuel combustion sources, and most of these are wood
burning units. These units would not be likely candidates for fuel revision.
Table A-9 provides a summary of S02 emissions generated throughout the
various Washington AQCRs. The role of fuel combustion in S02 emissions varies
markedly from region to region. In the Washington portion of the Pottland
interstate AQCR, fuel combustion sources account for 88% of the total S02
emissions, while in the Washington AQCR, only 9.4% of the S02 emissions
originate from fuel burning. As expected, very little S02 is generated from
power plant activity (predominantly hydorelectric) except in the Washington
portion of the Portland Interstate AQCR, where 76% of the emissions of S0«
L
originate from power plants. In most AQCRs, combustion area sources account
for the most substantial portion of the SOp emissions inventory. This arises
primarily from residential space heating and the burning of fuel oils. The
quantity of S02 emissions from industrial-commercial sources varies from region
to region. In the Northern Washington and the Washington portion of the
Eastern-Washington-Northern Idaho AQCR, there are virtually no significant S02
emissions arising from industrial combustion sources. The impact of fuel
revisions or relaxation of combustion source emission regulations would have
very minor effects on the air quality in these areas. However, in the Olympic
Northwest AQCR, 23.3% of the S02 emissions generate from industrial sources,
and it is expected that air quality could be affected by either a change in fuel
burning schedules, or a relaxation in regulations.
2.2 BACKGROUND ON THE DEVELOPMENT OF THE STATE IMPLEMENTATION PLAN
This section provides a characterization of the Implementation control
strategies, a reconciliation evaluation between air quality/emissions
relationships assumed at the time of the strategy development and those which
12
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can be assumed from more recent data, and an evaluation of the tolerance each
of the AQCRs possesses for increased emissions of particulates and SCL.
2.2.1 General
The State of Washington developed a control plan for achievement of
the federal air standards for particulates and SCL by addressing the specific
air pollution problems in each of the AQCRs separtely. Candidate control
strategies were investigated by developing projected emission inventories,
and calculating emission reductions. The plans were developed cooperatively
and included consideration of sources within the jurisdiction of individual
local air quality control agencies and the Department of Ecology.
The pil'.an development relied in general on simple proportional model
roll-back calculations to demonstrate attainment for each of the regions. It
was recognized that such calculations do not reflect the influence of topo-
graphy, the distribution of emission sources, and stack heights. In many
cases, air quality data used for the roll-bafck calculations were obtained at
stations strongly affected by large point sources. Where this is the case,
special consideration was applied to "isolate out" the hotstop in the analysis,
and to specify adequate controls for those sources which would reasonably
contribute to the air quality measurements at the source oriented monitoring
stations.
The EPA judged the Implementation Plan of Washington to be adequate for
attainment of standards for particulates and S02- State and local regulations
have been enacted to assure attainment of the standards by 1975. Table A-3 is
a summary of the attainment dates for each region.
2.2.2 Particulate Control Strategy
The EPA assessment of The Washington Implementation Plan determined it
was adequate for achievement of the national secondary standards for
particulates and S02. The analysis of the implementation plan development
shows that the secondary standard for particulates will be difficult to meet
in three of the six AQCRs. Diffusion modeling performed for the Puget Sound
AQCR indicates that secondary standards will be met in the region, but with
little allowance for growth in the Seattle-Duwamish area. Provisions will be
made to restrict new sources in that area. In the South Central and Eastern
Washington-Northern Idaho regions, the contribution of dust as a result of
'land preparation and harvesting op«rit1ons has not been determined. A study
13
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has been Initiated to determine the degree and extent of this problem. Should
agricultural operations prove to be a major contribution to the particulate
loading in these regions, specific measures will be designed to reduce this
source and insure achievement of secondary standards.
Table A-10 summarizes pertinent data used in the development of
particulate control strategies for the various AQCRs. It should be recognized
that those air quality measurements selected as the controlling value for
rollback determinations were all annual means, and did not represent the most
severe values of ambient air standard violations in most of the regions.
Table A-10 shows the worst air quality was measured as a 24-hour average in
all AQCRs except the South Central Region. Since the control strategies were
formulated on the basis of the annual readings rather than the worst violation
values, it follows that the control strategies are under-designed and may not
be adequate for attainment of the secondary standards. This deficiency is
evident in Table A-10 when a comparison is made between 1975 forecasted
emissions and the maximum allowable region-wide emissions for attainment.
However it should also be remembered that the Washington plan was formulated
with special consideration to control of hot spots. Greater emission
reductions are to be realized in areas of high emission density. Hence
while forecasted region-wide emissions may exceed those total emissions, which
are calculated as allowable region wide, it is perfectly plausible that air
quality standards may still be achieved simply by implementing more complete
emission control in the area of worst air quality.
The following discussion provides a description of the control strategy
for particulates, and its forecasted impact for each of the AQCR's, as formulated
in the State Implementation Plan.
o Eastern Washington - Northern Idaho Interstate:
The Washington portion of this region is classified as
Priority I for suspended particulates, and emission reduction
requirements formulated in the plan indicate that a 49 percent
reduction in emissions will be needed to meet the secondary
standard. An overall reduction of 34 percent in particulate
emissions by 1975 has been calculated for this region through
enforcement and application of both new and existing regulations.
However, by considering only the emission sources which may
14
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reasonably be expected to contribute to the site of maximum
concentration (those within Spokane County), a 50 percent
reduction in emissions will be achieved by applying Washington's
adopted regulations. Spokane County accounts for 45 percent of
the total particulate matter emissions in the Region. Of the
remaining particulate matter emmissions no more than 12 percent
of the total are concentrated in any one county. The plan
indicates that a large portion of the emissions outside
Spokane County are attributed to small grain handling operations
scattered throughout the Region. These sources are to be
controlled under State regulations and do not affect the
maximum site.
The required reduction calculations are based on measure-
ments at a single location in downtown Spokane. Subsequent
measurements during the year 1970 at this station indicate that
the primary standard is now being met through the enforcement
of local agency regulations and the activation of a Smoke
Management Plan to control agricultural burning. The additional
25 percent reduction required to meet the secondary standard
should be met with continued enforcement of both State and
local agency regulations. An additional station was installed
in Spokane in the spring of 1971, Measurements taken at that
location are strongly influenced by the largest point source of
particulates in the area, the aluminum mills. Data for less
than a year from that station indicates that about a 60 percent
improvement is needed to meet the secondary standard. On the
assumption that the levels there are the result of particulate
emissions from the aluminum mill, the 65 percent reduction in
emissions from that plant by 1975 should be adequate to provide
the needed air quality improvement.
It is strongly suspected that dust from agricultural
activities and dusty roads within the region id a major source
of particulates.
A special study of particulate loadings 1n the Spolane County
area, 1973, and a second special study of particalate loading, as
related to agricultural practices in eastern Washington, was sbbeduled
for completion by December 1973. When these studies are completed,
the State will evaluate: the effett of more stringent regulations
on stationary sources; the possibility of dust suppression procedures
on dusty roads and fields; and the possibility of control of agricultural
practices to reduce the amount of wind erosion that does occur. The
evaluation of the control strategy should be completed by the fall of
1974. It is assumed that the implementation of dust suppression techni-
ques may take as long as two years. Tjie State will develop a cooperative
program with the Soil and Water Conservation Districts for improved
agricultural practices. This may include sponsorship of State legisla-
tion to limit soil loss by regulation. If this type of limitation 1s
Sufficient, the secondary standard could be achieved by 1980.
15
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• Portland Interstate
The region is classified as a priority II region for suspended
participates based upon a sampling site in Longview.
Under the enforceable regulations of the Implementation Plan,
reduction in process loss particulates will occur primarily as
State-controlled kraflt pulp mills, sulfite pulp mills and aluminum
mills come into compliance. There have been significant increases
in fuel combustion particulates in the region as a result of the
coal-burning steam-electric power plant which was put into operation
at Centralia in late 1972.
The three sources under State jurisdiction in the Longview area
will reduce emissions of particulate matter 72 percent from 11,000
tons per year in 1970 to less than 4,000 tons by July 1, 1975. The
two sources under State jurisdiction in the Vancouver-Camas &Kea
will reduce emissions of particulate matter 64 percent from about
5,800 tons per year in 1970 to less than 1,600 tons per year by
July 1, 1975. These reductions will enable the secondary standards
to be met in this region.
• Northern Washington:
Priority classification and reduction requirements in this
region were based on measurements at one station onj'y - Wenatchee.
A number of other stations have since been established to provide
better coverage of the area. The single station analysis of the
base year indicated the region is Priority II for suspended
particulates. A reduction of 19 percent in particulate emissions
is needed to meet the secondary standard.
A large ferro-alloy plant located near Wenatchee will reduce
particulate emissions by more than 97 percent prior to 1975. This
reduction, coupled with substantial reductions in emissions from
wigwam burners, should result in the needed improvement in air
quality prior to 1975. An overall total reduction of at least 50
percent is projected for this region.
9 Olympic - Northwest Washington:
The State estimated an emission reduction of 27 percent as the
requirement to meet the secondary national standard for suspended
parti culates. The statidard was exceeded at only one station within
the Region - Port Angeles. This is predominantly a logging and
lumbering region and high levels of particulates have been noted
at this station during periods of extensive slash burning. The
Smoke Mangement Plan and Olympic Authority's Regulation I are ex-
pected to result in a 33 percent reduction in patticulates from
these sources. Decreases in emissions from wigwam burners will also
aid in reducing particulate levels in this region. In addition to
insuring future compliance with standards, a Smoke Management Plan
has been initiated by the Northwest APCA for the control of agri-
cultural buring in its area.
16
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• Puget Sound:
Because it was not clear on the basis of simple rollback
calculations whether the secondary standard could be achieved
in the Duwamish area when all sources were in compliance with
current regulations, the Puget Sound Air Pollution Control
Agency used an air quality diffusion model in the region to
demonstrate attainment of the national particulate matter stan-
dards. The modeling results indicated that the secondary stan-
dards would be met in all areas with application of the State
and local regulations. The plan indicates that additional
modeling will be performed to determine if more stringent
regulations are necessary to ensure maintenance of the national
secondary particulate matter standards. Additional regulations
which would be considered are; 1) an evaluation of other control
strategies such as a more stringent process weight rule, the
use of dust suppression on unpaved roads, and dusty parking lots;
2) the effect of short-term curtailment during an episode; and
3) the effect of strict limitation on any future growth.
• South Central Washington:
The suspended particulate data aaailable for determining the
priority and the emission reduction requirements for this area
were from the Yakima Valley only. The available 1970 data
indicated a reduction requirement of 39 percent in order to meet
the national secondary suspended particulate standard. The plan
indicates an overall 21 percent reduction in.particulate emissions
will'be achieved by the enforcement of the State and local regula-
tions specified by the control strately.. However, by considering
only emission sources which may reasonably contribute to the site
of maximum concentration, a 50 percent reduction in emissions will
be achieved. Of the remaining particulate matter emissions in the
Region out-site of Yakima County, 49 percent are concentrated in
Walla Walla Coynty, with no other county having more than 8
percent of the emission sources. Half of the emissions in Walla
Walla County are attributed to one point source which will be 82%
controlled by State regulations in 1975. Since the remaining
particulate emissions are distributed throughout the region, the
particulate control strategy is considered adequate for attainment
and maintenance of the national standards. ' *'
2.2.3 Sulfur Oxides Control Strategy ' , f
The analysis of the State Implementation Plan shows that the required
reductions of sulfur oxides will be achieved in all regions. In the Puget
Sound AQCR, the only region in Washington not measured to be in attainment
with federal standards, reduction requirements are based on Tacoma measure-
ments where the primary source of S02, the Tacoma smelter, is located. A 51
percent reduction in SO emissions from the smelter is required by the local
agency by the end of 1973, Rollback calculations indicate this will result
in air quality levels meeting the federal secondary standard at that time.
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Table A-ll summarized pertinent data used in the development of S0?
I f-
control strategies for the various AQCRs. The air quality measurements
selected as the controlling value of rollback determination were constitu-
ted on the maximum 24-hour values rather that the highest violation value
(the highest second highest reading within a region). This factor, plus
the fact the strategy was geared to the more stringent State ambient air
standards (see table A-3), has yielded a strategy which is probably more
severe than necessary to assume attainment of the federal air quality
standards.
The following discussion summarizes the considerations employed in the
Implementation Plan analysis to demonstrate attainment of standards for S09
i L.
levels in the various AQCRs.
9 Eastern Washington - Northern Idaho Interstate:
The Eastern Washington-Northern Idaho AQCR has been classified
lAfor sulfur oxides on the basis of Idaho measurements and a
determination that the majority, of the S02 emissions result from
the smelter in Northern Idaho. Air quality levels of S02 in the
Washington portion of the region are low and well within the
national standards. AQCR wide attainment of standards should be
achieved upon compliance of the Idaho smelter with EPA regulations.
• Portland Interstate:
This region was classified as Priority IA because of the results
obtained by a lead candle sampler at Camas. The calculated
reduction needed to meet the secondary standard is 85 percent. The
pulp mill at Camas would be required to reduce emissions of sulfur
dioxide at least 87 percent, from 11,500 tons per year to less than
1,500 tons per year, because of the State sulfite mill regulation.
The new power plant at Centralia will result in an actual increase
of sulfur dioxide emissions for the region. A study has been made
by a consultant funded by the Environmental Protection Agency which
shows that the effect of this new power plant will be an increase of
about 1.5 ppb (parts per billion) for the annual average sulfur dio-
xide concentration in the region.
18
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• Northern Washington:
Sulfur oxides emissions in this region are minimal. Air quality
levels as measured by lead candle are well within the standards.
The region is classified Priority III for this pollutant. No
increases in sulfur emissions are anticipated.
• Olympic-Northwest Washington:
A 23% reduction in sulfur oxides emissions is estimated based on
lead candle measurements in the March Point area. Diffusion modeling
has been selected by the local authority to estimate air quality ,
levels and evaluate control strategies. A 31 percent reduction in S02
emissions from the oil refineries and a 50 percent reduction from
the sulfite pulp mill in Anacortes - the major sources in this area -
are projected by 1975 with the enforcement of local agency regulations
and the secondary standard should be met well before 1975. S02 }
measurements in other areas do not indicate levels in excess of either
the primary or secondary standard.
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• Puget Sound:
The Puget Sound Air Pollution Control Agency attempted the use
of an air quality diffusion model to demonstrate achievement of
national sulfur oxides standards, but was unable to validate the
model due to the unique topography in this Region. The plan
identifies the Tacoma smelter as the major source of sulfur
dioxide in the Region. This smelter was shown to affect air
quality in both Tacoma and Seattle„ Based on the highest 24-hour
average, rollback calculations indicate a 47 percent reduction
in sulfur oxides emissions is required to meet these standards.
Since SOo levels in Tacoma and Seattle are affected mainly by
the single point source, it has been estimated that the
51 percent SCL emission reduction resulting from implementation
of the control strategy will attain the secondary standard. In
addition, the smelter will be required to have a total reduction
in sulfur oxides emissions of 90 percent in 1976. This will
ensure that the national sulfur oxides standards will be maintained.
*
• South Central Washington:
Emissions of S02 within this region are negligible. All
measurements of S02 in the ambient air indicate levels well within
the national standards.
2.2.4 Emission Tolerance Evaluation
Table A-10 and A-ll provide an assessment of the tolerance which each of
the AQCRs possesses for increased emissions of particulates or SC^. If a
region has a tolerance for more emissions, then this indicates;: 1) it is
possible that fuel burning schedules may be revised so that clean fuel savings
may be accomplished, and 2) it is possible that fuel combustion emissions
regulations may be (but not necessarily) relaxed. The methodology used in
calculating the emission tolerance is explained in detail in Tables A-10 and
A-ll. There are basically two ways in which the tolerance is derived: 1) by
a comparison of the allowable region wide emissions with the actual emissions
forecast in 1975, using the data from the Implementation Plan analysis, or
2) by a comparison of allowable region wide emissions with the actual 1973
emissions as determined using 1973 air quality/emissions data. The former
method is chosen when the Implementation plan forecasts appear to be
reconciliable with recent air quality/emissions data. In this case, forecasts
of the plan are considered valid, and used to develop an emissions tolerance.
If justified, this method is preferable, since the emission tolerance developed
in this way reflects the full impact of the control strategies after their
20
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implementation is complete in 1975. The emission tolerance becomes a measure
of the degree of "over-cleaning" accomplished by the plan, or in cases where
the region was already within air quality standards and did not require additional
pollution controls, the tolerance is an expression of the degree of degradation
possible before federal air quality standards are jeopardized. However, if
irreconcialiabilities exist from the comparison of Implementation Plan forecasts
with more current air quality and emissions data, it will be necessary to abort
the first approach discussed above, and determine the emission tolerance based
on 1973 air quality status in the region, which reflects the estimation
before any substantial controls have been implemented from the control strategy.
Table A-10 provides a summary of the data used to generate a particulate
emission tolerance in each of the AQCRs. Only one of the regions (Northern
Washington) possesses tolerance for increased emission of particulates. In
this region, it would appear that current fuel combustion emissions (1972)
could be tripled without jeopardizing attainment of the federal air standards.
In three of the remaining regions showing no emission tolerance, there is a
possibility that some tolerance may exist in geographic areas removed from the
hot spots. Whereas proportional rollback control is achieved by the control
strategies in the regions of high emission density, it is not necessary to
achieve this level of control throughout the rest of the region. Hence.the
overall degree of control indicated for the entire region may be less than
required by rollback calculations predicated on the worst air quality in the hot
spots, but the level of control attained in both the hot spot area, and the areas
removed from the hot spots, may be perfectly adequate, or even more than adequate,
for attainment of the air standards. Figures A-2 through A-7 give some indication
of the breadth of the particulate air pollution problem in the various AQCRs.
The Eastern Washington-Northern Idaho Interstate, the Portland Interstate, and
the Olympic-Northwest Washington AQCRs contain several counties which have not
experienced violations of the federal air standards. Unfortunately, the
population and emission source activity is rather limited in these counties, so
that despite the fact these counties may possess substantial particulate emission
tolerances, the impact of a fuel savings plan in these areas would probably be
insignificant.
The remaining two regions (Puget Sound and the South Central Washington
AQCR) not discussed above, each appear to possess no particulates emission
tolerance. The source emissions are fairly evenly distributed in these
21
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regions, and air standard violations are more widespread. The air
quality in Puget Sound has worsened since 1970, yet modeling analysis
used in the Implementation Plan development demonstrated attainment
of the secondary air standards by the end of 1973. In the South
Central Region, the air qua!ityftemissions relationship has changed
markedly since 1970, indicating an allowable emissions level of 4.3
tons/yr.particulates now compared to 16.3 tons/yr indicated by the
plan.
Table A-ll provides a summary of the data used to develop an SOg
emission tolerance in the various AQCRs. Substantial tolerances appear
to exist in five of the six regions. These large tolerances are due to:
1) the development of overly-stringent controls based on maximum 24-hour
values rather than the highest second-highest 24-hour values, 2) the fact
most of the regions are currently in attainment with the S02 federal air
standard. In three of the regions (Eastern Washington-Northern Idaho,
Northern Washington, and the South Central AQCR), S02 emission,tolerances
are estimated large enough to permit present combustion emissions to
double. No emission tolerance could be assigned to the Puget Sound
AQCR under the analysis scheme. It is suspected however, that implementation
of controls over the major SOg point sources in the Tacoma-Seattle area in
1975 could result in significant emission tolerances for the Puget Sound
Region.
2.2.5 Fuel Combustion Regulations Summary
Table A-12 provides a summary of the fuel combustion emission regulations
which have been adopted as the control strategy of the State Air Program
Implementation Plan. The regulations are fairly consistent throughout the
AQCRs. S02 emissions are limited to 1000 ppm from the stack of combustion
units (1.94 Ib of S02/106 Btu heat input) throughout all AQCRs except the
Northern Washington region, where the S02 stack emission limit is 1.5 Ib/
106 Btu/hr. Particulate stack emissions are limited to .1 grain/SCF in all
regions (this is equivalent to =11 Ib TSP/106 Btu/hr.).
22
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2.3 SPECIAL CONSIDERATIONS
This section provides a brief narrative on special considerations which
may impact to some degree the final assessments to be developed in this report.
2.3.1 Planned Revisions to the Implementation Plan
The EPA has approved the portions of the Washington air pollution
control strategy for participates and S02= It has been recognized that
limited air quality measurements were available at the time of the strategy
formulation, and that the plan provides for on-going development of control
strategies as may be indicated appropriate by new data obtained from an
expanding air monitoring network and special study efforts. This is
exemplified in a current study effort to quantify the impact of agricultural
practices on particulate loadings west of the Cascade Mountains. As a result
of this study, the State will evaluate the effect of more stringent regulations
on stationary sources (including combustion sources), the possibility of dust
suppression procedures on dusty roads and fields, and the possibility of control
of agricultural practices to reduce wind erosion. In another continuing analysis
which may lead to revisions in the present control strategy for particulates,
modeling is being performed in the Puget Sound AQCR to ensure maintenance of the
federal air standards., This study may lead to a definition of the degree of
limitations required for future growth.
2.3.2 Special Problems
The enforcement of regulations limiting particulate emissions from all
fuel combustion sources to .1 grain/SCF will force: 1) the use of control
equipment on wood burning boilers, or 2) the use of alternative fuels.
Currently there are numerous variances to burn wood in violation of the
regulation limits because of a fuel shortage problem in Washington. It is
expected that most wood burning operations will be adapted for compliance
with particulate regulations by installation of new boiler equipment and
coversion to fuel oil.
Coal burning combustion equipment currently meets sulfur oxides
emission regulations by burning low sulfur coals of 1% sulfur content or
less. The new Centralia Power Plant will use more coal than all other sources
23
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in Washington combined. If low sulfur coal cannot be obtained in the future,
coal burning sources would be required to install flue gas S02 removal systems
to comply with regulations.
2.3.3 Fuels and Anticipated Fuel Conversions
The vast majority of energy consumption in the State of Washington is
produced by hydroelectric power plants. Of the current fuel used in the State
of Washington in 1972, 68% was petroleum, 28% was natural gas and the
remainder was coal or wood.* This distribution of fuel usage is expected to
change substantially over the next few years. First, the use of coal will
increase 700%, due mainly to the new coal-burning power plant scheduled to go
on-line in the Portland Interstate AQCR in 1975» Secondly, the use of fuel
oils is expected to increase drastically due to1;: 1) fuel switching from wood
burning to meet particulate emission regulations, and 2) increasing curtail-
ment of Canada.'s supply of natural gas to Washington. A recent survey**rof
industrial firms'indicated that fuel oils would comprise 89% of all fuel
energy consumed in 1975, with the remainder being coal, natural gas, and wood.
If these fuel schedule forecasts are correct, it would indicate that a
significant portion of the fuel combustion equipment in Washington will be
converted to burn fuel oil, and consequently, emissions of S02 and particulates
will increase substantially. Hence it appears likely that clean fuel savings
will occur in Washington due to natural gas curtailments, but it is unclear
whether the industry will be capable of providing the controls needed to
comply with the emission regulations of the control strategies. Of course
this uncertainty is present even if fuel schedules do not change, as many
industries are now operating in variance with regulations until they can
provide control installations. Particulate control devices can probably be
supplied in time to meet the compliance deadline, but it is uncertain whether
flue gas desulfurization systems can be made available and installed in
accordance with attainment schedules. If S02 control cannot be provided,
low sulfur fuel oils will be.needed-in their place -to jneet the regulations.
It is clear, however, that there will be a shortage of the low sulfur fuels
as compliance requirements near.
*L. Crump, C. Readling, Branch of Interfuels and Special Studies, "Fuel and
Energy Data: United States and Regions, 1972."
**Personal communidation with EPA, District X, Seattle, Washington.
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3.0 AQCR ASSESSMENTS
This section provides: 1) an assessment, of the feasibility for
accomplishing clean fuel savings in the various AQCRs, and 2) an assess-
ment of fuel combustion emission regulations to determine if they are
overly restrictive for the attainment of National Ambient Air Quality
Standards in the various AQCRs. . " • ' .
The first assessment is carried out with an evaluation of various
regional air quality indicators developed in Section 2 and compiled in
Appendix B (and then again by evaluation of the impact of a reasonable
fuel switch as determined in Appendix F). The regional air quality indicators
considered are comprised of criteria shown in Table B-l and B-2, and include:
1) the breadth of air quality violations, 2) expected attainment dates,
3) AQMA designations, 4) total regional emissions, 5) portion of emissions
from fuel combustion, 6) and regional tolerance for emission increase. The
emission tolerance possibly provides the most important indicator, since, if
it is known, it provides a measure of the over-cleanliness of the region,
now or projected, and indicates how much additional pollution (from dirtier
fuels) can be permitted.
The assessment of the restrict!'veness of fuel combustion regulations
was performed with an evaluation of the impact of fuel burning operations on
air quality when those operations emit at a level equivalent to the ceiling
limit of the emission regulations. These emissions are calculated in
Appendices C, D, and E for power plants, industrial/commercial point sources,
and area sources, and then summarized in Appendix F.
The assessment of the various AQCRs is discussed below.
3.1 ASSESSMENT BY REGIONAL AIR QUALITY INDICATORS
Table B-2 indicates that only one of the six AQCRs can be considered a
good candidate for clean fuel savings (or possibly regulation relaxation).
This is the Northern Washington AQCR, and is designated so primarily because
of its tolerance to accept particulate emissions increases in 1975 greater
than those now generated by all combustion sources in the region. Three
25
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regions, the Eastern Washington-Northern Idaho Interstate (Washington portion),
Portland Interstate (Washington portion) and the Olympic Northwest Washington
AQCR, have been assigned as marginal candidates. These regions do not possess
a particulate emission tolerance, but do possess substantial geographic entities
which do not experience violation of the federal air standards. The air quality/
emissions relationships governing the rollback and emissions tolerance deter-
minations for these regions are based on worst air quality readings in the
vicinity of an emissions hot spot. The fraction of counties shown violating
the air standards in Table B-2 reflects the breadth of the air pollution problem
and Figures A-2 through A-7 suggest that some areas, or counties may be
considered as good candidates, while those possessing the hot spots probably
should not. In the Puget Sound and South Central Washington AQCRS, particulate
emissions are reported to be spread more extensively (although monitoring stations
in the South Central AQCR are not extensive enough to confirm this quantitatively).
This factor, coupled with the fact neither AQCR possesses any emission tolerance,
and the fact that the AQMAs have been designated within the Puget Sound Region,
demonstrate the assignment of these two AQCRs as poor candidates for clean fuel
savings or particulate emission regulation relaxations.
Table B-l shows that, unlike the assessment related to particulate emissions,
most of the AQCRs can be assigned as good candidates to accomplish clean fuel
savings when they are constrained by attainment of the S02 air standards only.
This evaluation results from the fact that the five good candidate AQCRs are
presently demonstrating attainment with the standards, and that substantial S02
emission tolerances exist in the five regions (the Washington portion of
Washington - Northern Idaho, Northern Washington, Olympic Northwest, South
Central, and the Washington portion of the Portland Interstate AQCR).
The Puget Sound AQCR is rated as a marginal candidate to accomplish clean
fuel savings because of its possible over-attainment of the air standards by
1975. With the major portion of the region's control strategy yet to be
enforced (large smelter in Tacoroa-Seattle area), and with an improving air
quality wfotbh is now near attainment, a significant S02 emission tolerance may
develop by 1975.
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3.2 ASSESSMENT BY SOURCE ANALYSIS OF POWER PLANTS/INDUSTRIAL-COMMERCIAL/AREA SOURCES
As 96% of all power generation in Washington is hydro-electrically produced,
there are only a limited number of fuel burning power plants in the State of
Washington. Fuel use and emission data for the four major fuel burning power plants
in Washington is shown in Table C-l. These plants are all oil fired except for
plants in the Portland Interstate Region which presently burn wood or coal.
Generally the emissions of S02 and particulates arising from operation of power
plants is relatively insignificant in the overall emission inventories of the
various AQCRs. However, in the Washington portion of the Portland Interstate
AQCR, the new coal fired power plant in Centralia plays a significant role in
the inventory of emissions of SOp and particulates in that AQCR. Table C-l
includes a tabulation of SOp and particulate emissions presently emitting from
the power plants, and a computation of the emissions which are allowable at the
emission regulation limits. It can be seen that by burning low sulfur fuels
( 1.7%S for oil and .8%S in coal) the plants are able to comply with S02 emission
regulations. However the plants are not presently meeting the emission regulations
for particulates.
Table D-l provides a summary of the major industrial/commercial fuel
combustion point sources in the various AQCRs. The number of these sources
which have been identified in the NEDS emission inventory is reported on Table
A-7. In Table D-l, wood burning plants have been aggregated together as a single
source, since it was not expected that clean fuel savings objectives would be
applicable to wood burners. The emissions summary of Table D-l shows that
industrial sources of all AQCRs are in substantial compliance with the S02
emission regulations. This is achieved through a combination of tire burning
of natural gas and low sulfur fuel oils. With respect to compliance to
particulate regulations however, the point sources are found to be substantially
deficient. Compliance of these sources with particulate regulations may not
be necessary in some regions (or areas) for the attainment of ambient air
27
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standards. For example, since the Northern Washington AQCR would permit
an additional 3,500 tons/yr of participate emissions, it is evident that
the present wood burning operations, which constitute nearly 100% of the
fuel combustion emissions, can be maintained at status quo without, the need of,
additional air pollution controls to attain the standards. For those AQCRs
listed as marginal candidates, it may be possible to relax regulations in
those areas which appear to be removed from the hot spots. For example,
it is evident that it would have minor impact on the air quality in most of
the Olympic-Northwest Washington AQCR if all the sources listed in Table D-l,
except for the two in Cl all urn County, were allowed to continue present burning
practices. This would require the availability of about 3.8 tons/yr of emission
tolerance in the "clean" counties of this AQCR. Since these counties are already
meeting the air quality standard, it is obvious they possess this tolerance.
The case for the Eastern Washington-Northern Idaho Interstate AQCR is similar.
Wood buring operations are scattered throughout that region, and the only
non-wood burning fuel combustion source is located in the relatively
clean County of Grant. Since the air quality measurements prove that Grant
County, and other counties or areas in this region, would tolerate the non-
compliance of the present fuel burning operations, it is evident that fuel
combustion emission regulations could be relaxed in these areas.
The significance of the area source depends greatly on the degree of
industralization of the area (Tables A-8 and A-9). In rural areas such as
the South Central Washington and Northern Washington AQCRs, area source fuel
combustion accounts for 47% and 30% of the S02 emissions inventory. In
industralized areas such as the Puget Sound AQCR, S02 emissions from area
sources amount to 50% of the inventory. The same trend is true of particulate
emissions, although their relative significance varies from only 1.3% to 5.2%
of the overall inventory. Area sources are comprised essentially of residential
space heating units, burning distillate fuel oils. These units are exempt from
emission control, except in the AQCR of Puget Sound, where sulfur content of
the fuel is restricted. Therefore it does not appear, for the most part, that
substantial fuel savings can be accomplished from the area source sector of
the fuel consuming sources.
Table F-l and F-2 combine the analysis of Appendix C, D, and E (power
plants, industrial/commercial, and area sources) to provide an assessment of
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the restrictiveness of fuel burning emission regulations. The assessment
is carried out by evaluating the difference between the projected fuel
combustion emissions in 1975 and those emissions which are emitted at the
level of emission regulations. This difference constitutes the additional
emissions which would result if, after compliance with regulations in 1975,
all fuel burning sources were to alter fuels or operations, causing emissions
to rise up to the level of the regulations. It is clear that if the addi-
tional emissions calculated are more than the emission tolerance compiled
for the region (Tables A-10 and A-ll), the emission regulations are not
overly restrictive, and they should not be relaxed.
In Table F-l it can be seen that particulate emission regulations appear
to be overly restrictive for only the Northern Washington AQCR. However,
it is possible that emission regulations are overly restrictive in certain
counties or areas of the AQCR which do not experience air quality violations.
In the Eastern Washington-Northern Idaho Interstate, the Portland Interstate,
and the Olympic-Northwest Washington AQCR, these geographic areas may include
substantial territory, and can be seen by examination of Table D-l, they may
encompass a substantial portion of the fuel combustion emission source
inventory.
In Table F-2, it is demonstrated that it would be possible to incur
substantial relaxation of the SCL emission regulations in practically all
the AQCRs without interfering with attainment of ambient air quality objectives.
Since it is projected that 1975 SOp emissions will be predicated on the same
fuels used today (which includes low sulfur oils and coal, and natural gas),
it is seen that a high degree of over-compliance is exhibited with respect to
meeting S02 emission regulations in 1975. This is exemplified by the fact that
a substantial increase of emissions is caused by burning up to the SCL
regulation limits. In all the AQCRs, tbere is substantial room to increase S02
emissions without interfering with emission regulations, and then, in all the
AQCRs except the Puget Sound Region, there is still more room to relax the regu-
lations to permit still more SCL emissions before emission tolerances would
^ ! '
be used up. This suggests that significant clean fuel savings can be
accomplished without the need of revising regulations, at least with
29
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regard to those fuels which emit low S02 emissions on burning (low sulfur
fuel oils, natural gas, and low sulfur coal). However, caution should
be applied in evaluating the restrict!'veness of regulations, especially in
the Puget Sound AQCR. If fuel burning practices in this region were modified
so that combustion equipment would emit at rates equivalent to the ceiling of
the emission regulations, total S02 emissions in the region would increase by
19%, and combustion emissions would more than double (see Table F-2). While
the region appears to be exhibiting progress toward compliance with regulations
(in other sectors of emission sources as well as combustion) and air standards,
and while it seems that over-attainment of air quality goals may be plausible
in this region, the data does not indicate that S02 regulations can be relaxed,
nor that clean fuel savings are possible without jeopardizing the federal air
quality standards.
The impact of a feasible fuel switch to obtain clean fuel savings in the
State of Washington is summarized in Table F-3. It was assumed that all gas
burning combustion equipment would be converted to burn high sulfur (2% S)
fuel oil, and that all coal burning equipment which presently burns oil or gas
also, would be switched to a complete coal-burning schedule. The switch is
assumed to occur in 1975, after compliance with emission regulations has been
attained. For those units which are converted for the fuel switch, it is
assumed that no additional emission control equipment is installed. Hence,
for all units converted from gas only to fuel oil, there will undoubtedly be
accompanying emission violations. While such a conversion scheme is obviously
imaginary, it would theoretically constitute a reasonable fuel switch, result-
ing in only minimal economic dislocation. The switch would accomplish clean
fuel savings for low sulfur oils and natural gas. Table F-3 shows that, with
regard to particulate emissions, the impact of the fuel switch is only slightly
greater than the impact caused by fuel burning which emits at the ceiling rate
of the emission regulation (Table F-l). In other words, the suggested fuel
switch of Table F-3 would result in only minor violations of the particulate
emission regulations. The relatively insignificant impact of the fuel switch
(amounting to a regional particulate emissions increase of about 1 to 2%) is due
mainly to the fact that there is a relatively small portion of the total heat
input generated by gas-burning, and hence only a small portion of the conversion
would occur on fuel burning equipment not already equipped with adequate emission
controls. On the basis of the preliminary findings of Table F-3, it would appear
30
-------
that the resonable fuel switch outlined here could be accomplished without
seriously jeopardizing the attainment of secondary standards for particulates.
The impact of the fuel switch on SCL emissions in the various AQCRs is
shown to be accomplished with relatively minor violations of the SOp emission
regulations. These violations occur because of the use of an assumed fuel
oil sulfur content of 2%, which is higher than the lower sulfur fuels now
available to the State of Washington, and slightly higher than the 1.75%
fuel oil sulfur content needed to meet the 1000 ppm emission regulation in
the different regions. The net increase of S02 emissions caused by the fuel
switch is actually less than the increase which would result if all combustion
equipment were to emit at the ceiling of the S02 regulation (shown in Table
F-2). Hence the fuel switch can be accomplished without jeopardizing air
quality attainment goals in all of the regions except the Puget Sound AQCR.
There is no emission tolerance for this region, and the increase of
13,600 tons/yr of S02 caused by the fuel switch in this region will likely
aggravate the S09 problem.
31
-------
APPENDIX A
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
emission regulations. 1973 SAROAD data for S02 and TSP monitoring
stations are summarized for the various AQCRs in the State. NEDS emissions
data are tabulated for the various fuel burning categories in each of the
AQCRs.
Tables A-10 and A-ll show a comparison of emission inventories in the
original SIP and those from the NEDS. An emission tolerance which might be
allowed in the AQCR without violation of national secondary ambient air
quality standards, is calculated for SO^ and particulates. The intent of
this calculation is to indicate possible candidate regions for clean fuel
savings. The tolerance was based on .either the degree of control expected
by the SIP or upon air quality/emission relationships which are calculated
from the more recent NEDS and SAROAD data. The value of the emission
tolerance provides an indication of the degree of'potential an AQCR
possesses for clean fuel savings and regulation relaxation.
Methodology for Increased Emissions Tolerance
A tolerance for increased emissions was determined as follows. First,
an "allowable emissions" was calculated for each AQCR based on the current
NEDS data and the percent reduction (or increase) required to meet the
national secondary ambient air quality standards in that AQCR (worst case
from Tables A-5 and A-6). This "allowable" was then compared to that from
the SIP. If reasonable agreement occurred, then the "estimated emissions"
which would result after implementation of the SIP in that AQCR was used
to calculate an emissions tolerance. Thus, some credit could be given to
an AQCR which might be restricting emissions more than required by ambient
air quality standards. In the event that no data existed or was available
1|I1972 National Emissions Report," EPA-450/2-74-012, June 1974.
A-l
-------
from the SIP for an AQCR, the current air quality was used to assign
emissions tolerance based on proportional rollback or rollup. The current
air quality was also used to assign emissions tolerances when emissions data
from the SIP and the NEDS did not appear to be comparable (this is often the
case).
It is emphasized that emissions tolerance is based on region-wide
emission figures. It is evident that the calculation and use of this
tolerance is more appropriate for an urban AQCR with many closely spaced
emissions sources, than a largely rural AQCR with geographically dispursed
emissions.
A-2
-------
OLYMPIC-
NORTHWEST
WASHINGTON
INTRASTATE
PUGET SOUND
INTRASTATE
NORTHERN WASHINGTON
INTRASTATE
Whatcom
S*n) |
Clallam
Jefferson
I
J Adams | whitman
~
Franklin, .
} f
/
, D . ^.
Benton X
EASTERN
WASHIHGTON-
NORTHERN
IDAHO
INTERSTATE
PORTLAND
INTERSTATE
(WASHINGTON-
OREGON)
SOUTH CENTRAL
WASHINGTON
INTRASTATE
Figure A-l. Air Quality Control Regions in Washington
-------
1.75/1.28-TSH
1.73/NA-TSP |
1.44/1.26-TSPI
PO K A NE
.66/0.81-TSc
I N C 0 L N
64/0.48-TSP
GRANT
•4//0.53-TSP
.95/i.OO-TSP
WHITMAN
1.47/1.08-TSP
The worst measured air quality
is indicated as a ratio with
the secondary standard:
2nd high 24-hr ave./annual ave.
2nd high 24-hr ave.
/
60
annual
ave.
80
for TSP
for SC2
The ratios are plotted in geographic
proximity of the monitoring stations.
NA = not available
U.32/NA-S02
1.35/NA-TSP
Violation of TSP _^
Standard.
Violation of TSP
and S02 Standard.
Figure A-2
1973 AIR QUALITY MEASUREMENTS
AT .MONITORING STATIONS IN
EASTERN WASHINGTON
NORTHERN IDAHO
INTERSTATE AIR QUALITY
CONTROL REGION
POPULATION 526,550
-------
CJI
Violation of TSP
Standard.
Violation of TSP
and SC>2 Standard.
1.10/0.93-TSP
The worst measured air quality
is indicated as a ratio with
the secondary standard:
2nd high 24-hr ave. /annual ave.r Tt;D
T50 / 60 Tor ' ^
. /a
/
2nd high 24-hr ave. annual
361 80"
.r^^
Tor
The ratios are plotted in geographic
proximity of the monitoring stations.
NA = not available
Figure A-3
1973 AIR QUALITY MEASUREMENTS
.AT .MONITORING STATIONS IN
NORTHERN WASHINGTON
INTRASTATE AIR QUALITY
CONTROL REGION
POPULATION 111,094
-------
CTl
Oo33/NA-S02
S K A G I T
GRAYS
MaRBO" L A
0.52/0.56-TSP
P.75/NA
Violation of TSP
Standard.
Violation of TSP
and SOg Standard.
The worst measured air quality is
indicated as a ratio with the
secondary standard:
2nd high 24-hr ave./annual ave.
150 / —55 —
2nd high 24-hr ave. /annual ave.
365
80
for TSP
for SOc
The ratios are plotted in geographic
proximity of the monitoring stations.
NA = not available
Figure A-4
1973 AIR QUALITY MEASUREMENTS
AT MONITORING STATIONS IN
OLYMPIC-NORTHWEST WASHINGTO
INTRASTATE AIR QUALITY
CONTROL REGION
POPULATION 383,790
-------
0.041/NA-SO?
1.11/0.88-TSP
.49;
0.51-TS
K I T S A P
97/NA-TSP
ING
55/0.70-TSP
.68 /0.60 TSP
•76/0.91-TSOK
1.04/0.96-TSP
The worst measured air quality is
indicated as a ratio with the
secondary standard
2nd high 24-hr, ave./annual ave.
150 / 60
high 24-hr ave
365
§.-/£!
/'
for TSP
annual
80
ave.
for S02
The ratios are plotted in geographic
proximity of the monitoring stations.
NA = not available
Violation of TSP
Standard.
Violation of TSP
and S0 Standard.
Figure A-5
1973 AIR QUALITY MEASUREMENTS
AT MONITORING STATIONS IN THE
PUGET SOUND INTRASTATE
AIR QUALITY CONTROL REGION
POPULATION 1,93-1,CC8
-------
I
oo
.92/0.60-TSPS-
BENTON
The worst measured air quality
is indicated as a ratio with
the secondary standard:
2nd high 24-hr ave./annual ave.
150
2nd high 24-hr ave
363
naar<
•/
/
for TSP
60
annual ave.
80
for S02
WALLA WALLA
.85/0.76-TSP
The ratios are plotted in geographic
proximity of the monitoring stations.
NA = not available
Violation of TSP
Standard.
'violation of TSP
and S02 Standard.
Figure A-6
1973 AIR QUALITY MEASUREMENTS
AT MONITORING STATIONS IN
SOUTH CENTRAL WASHINGTON
INTRASTATE AIR QUALITY
CONTROL REGION
POPULATION 317,680
-------
29 /NA-TSP
LEWIS
I
VD
! 1.13/l.lO-TSP
.90/1.00-TSP
0.22/NA-SO?-Highest
CLARK
0.22/NA-S02
.59/0.60-TSP
,.83/0.88-TSP
S K A M A N I A
Violation of TSP
Standard.
Violation of TSP
and S02 Standard.
The worst measured air quality is
indicated as a ratio with the
secondary standard:
2nd high 24-hr ave
150
2nd high 24-hr ave
365
The ratios are plotted in geographic
proximity of the monitoring stations.
NA = not available
;./annual ave.for TSP
/ 60
i./annual ave.for S02
Figure A-7
1973 AIR QUALITY MEASUREMENTS
AT MONITORING STATIONS IN
PORTLAND INTERSTATE AIR
QUALITY CONTROL REGION
(WASHINGTON-OREGON)
POPULATION 1,727,358
-------
Table A-l. Washington Air Pollution Control Areas
Air Quality
Control Region
(AQCR)
(062) Eastern Washington-
Northern Idaho
Interstate
(193) Portland Interstate
(227) Northern Washington
(228) Olympic-Northwest
Washington
(229) Puget Sound
(230) South Central
Washington
Priority Cl
Parti culates
I
I
II
II
I
I
assifi cation
S02
I
I
III
II
I
III
NOX
III
III
III
III
III
III
Air Quality
Area (AQMA)
TSP Counties
Spokane
Clark
King, Pierce
Snohomish
Maintenance .
Designations
S0? Counties
Clark
•
I
o
^Criteria Based on Maximum Measured (or Estimated Pollution Concentration in Area
Priority
Sulfur oxide:
Annual arithmetic mean ..
Parti cul ate matter:
Annual geometric mean ...
24-hour maximum
Nitrogen dioxide
I
Greater than
100
455
95
325
110
II
From-To
60-100
260-455
60-95
150-325
III
Less than
60
260
60
150
110
bFederal Register, August 1974 SMSA's showing potential for NAAQS violations due to growth
-------
TABLE A-2
REGIONAL SUMMARY INFORMATION
Ai r Qual i ty
Control Regions
Puget Sound
Intrastate
01 ymp i c-Nor thwes t
Intrastate
Portland-Southwest
Washington
Interstate*
Northern Washington
Intrastate
Eastern Washington**
Northern Idaho
Interstate
South Central
Washington
Intrastate
Number of
Counties
1»
9
5
6
8
6
1970
Populat ion
1 ,934,628
383,790
251, 971*
111 ,09*»
410,003
317,680
Area
Square Mi les
6,300
12,326
6,165
16,155
13,016
10,200
Largest
City
Seattle
Bel 1 ingham
Vancouver
Wenatchee
Spokane
Yak! ma
* Interstate Regions Include only Washington State Data.
-------
Table A-3.Air Quality Attainment Dates
>
ro
AQCR ,
Eastern Washington - Northern Idaho
Interstate (062)
Portland Interstate (193)
Northern Washington (227)
Olympic-Northern Washington (228)
Puget Sound (229)
.South Central Washington (230)
Parti culates
Attainment Dates
Primary Secondary
7/75
7/75
a
7/75
12/73
7/75
7/75
7/75
a
7/75
7/75
7/75
Sulfur Dioxide
Attainment Dates
Pjr i ma ry Secern da ry
a
7/75
a
a
1/75
a
a
7/75
a
7/75
1/75
a
Nitrogen Oxides
Attainment Dates
a
a
a
a
a
a
a Air quality levels presently within standards,
-------
Table A-4. Federal and State Ambient Air Quality Standards
Federal
State
Primary
Secondary
3
All Concentrations in/"gms/m
Total Suspended Participate
Annual
75 [G]
60 [G]
60 [G]
24-Hour
260a
150a
150a'c
Sulfur Dioxide
Annual
80 I'A]
-
53 [A]
24-Hour
365a
-
266a
3-Hour
1300a
-
1-Hour
-
106a
665b -'
a Not to be exceeded more than once per year
b Violation is based on exceeding this value more than twice in any 7 day period.
c East of the Cascade Mountain Crest, the 24-hour State Standard is 120 + (background level on days when
background exceeds
[A] Arithmetic mean
[G] Geometric mean
-------
Table A-5 Summary of 1973 Air Quality3 Status for Particulates
(ug/m3)
Particulate Concentration
AQCR
Eastern Wash. -Northern
Idaho Interstate (062)
Washington Portion
Portland Interstate (193)
Washington Portion
Northern Washington (227)
Olympi a-Northwest
Washington (228)
Puget Sound (229)
South Central
Washington (230)
#
Stations
Reporting
17
9
68
7
3
4
15
6
Highest
2nd
Highest
Highest Reading Reading
Annual 24-Hr 24-Hr
140 638 497
77 638 263
66 265 205
66 216 170
56 315 163
63 235 185
111 463 329
73 496 ' 462
# Stations Exceeding
Ambient Air Quality Standards
Primary Secondary
Annual 24-Hr* Annual 24-Hrb
568 13
213 6
00 2 9
001 1
000 .1
001 1
142 2
012 1
Emission Reduction c
Required to Meet
Secondary Standards^
Annual 24-hour
73 74
36 48
12 29
12 13
d 10
6 21
53 57
30 72
I
-p»
acompiled from 1973 air quality data in National Air Data System as of June 7, 1974.
bviolations are based on readings which exceed the value of the NAAQS after the first time.
c% Reduction required = ^ x 100. Where A = 2nd highest measured air quality for period of standard
B = the background concentration (15 /ug/m^ west of cascades,
and 30 pg/rn^ east of cascades)
C = the concentration value of the standard
dair quality presently in attainment with standards
-------
Table A-6. Summary of 1973 Air Quality3 Status for S02
S02 Concentration
(ug/mj)
AQCR
Eastern Wash. -Northern
Idaho Interstate (062)
Washington Portion
Portland Interstate (193)
Washington Portion
Northern Washington (227)
Olympia-Northwest
Washington (228)
Puget Sound (229)
South Central
Washington (230)
Stations
Reporting
24-Hr
(Bubbler)
7
3
5
0
1
1
3
1
a
Stations
Reporting
(Contin. )
5
1
5
2
-
3
6
-
Highest
2nd
Highest
Highest Reading Reading
Annual 24-Hr 24-Hr e
40 1498 1248
40 165 120
235 115
81
135 115
234 120
90 182 73
95 90
? Stations Exceeding
Ambient Air Quality Stds.
Primary Secondary
Annual 24-Hrb 3-Hrb
03 4
00
00 0
0
0
0 0
1 0 0
0
Emission Reduction c
Required to Meet
Seconder/ Standards ,%
Annual 24-hour
d 71
d d
d
d
d
d
11 d .
d
I
Ol
1. Blanks (-) indicate value is indeterminate due to absence of air quality data.
^compiled from 1973 air quality data in National Air Data System as of June 7 1974.
Dviolations are based on readings which exceed the value of the NAAOS after the first time.
A C
c % reduction required = -r— x 100. Where A = 2nd highest measured air quality for period of standard.
C = the concentration value of the standard.
d Air quality presently in attainment with standards.
e It should be recognized that those stations utilizing continuous SOg monitoring equipment do not report the
2nd highest 24 hour value. Hence it is possible, from the available data, that the annual SOg average for
a region may be given as higher than the highest 2nd high S02 24 hour value (See Puget Sound above).
-------
Table A-7. Fuel Combustion Source Summary
CTi
AQCR
Eastern Washington - Northern
Idaho Interstate (062)
(Washington portion only)
Portland Interstate (193)
(Washington portion only)
Northern Washington (227)
Olympia-Northwest Washington
(228)
Puget Sound (229)
South Central Washington
(230)
Number of
Power Plants
1
2
0
0
3
1
Number of Industrial
or Commercial
Point Sources
TSP
3
14
8
16
32
7
S02
0
8
0
8
32
2
a This represents the total number of combustion point sources inventoried in the
NEDS 1973 Rank-order Source summaries. Only emission sources of 1 ton/year or
greater are reported.
-------
Table A-8. Fuel Combustion Emissions Summary, Particulates'
AQCR
Eastern Wash.
Northern
Idaho Inter-
state (062)
Washington
Portion
Portland
Interstate
(193)
Washington
Portion
Northern
Washington
(227)
Olympic-
Northwest
Washington
(228)
Puget Sound
(229)
South Central
Washington
(230)
103 Tons/Year
24.1
11.6
131.4
47.9
28.2
29.4
56.0 .
15.4
Total from
Fuel Combustion
10 tons/yr
8.7
1.1
26.6
17.7
1.7
4.4
14.9
1.7
Percent from
Fuel Combustion
36.1
9.6
20.2
36.9
6.1
14.8
26.6
10.7
Electricity Generation
103 Tons/Year %
0 0
0 0
.8 .6
10.4 21.7
0.4 1.4
0 0
0 0
0 0
Indust-Commercial
Point Source
Fuel Combustion
103 Tons/Yr %
7.5 31.1
.5 4.4
16.2 12.3
6.8 14.2
0.8 2.9
3.4 11.6
12.2 21.8
1.1 7.1
Area Source
Fuel Combustion
103 Tons/Yr %
1.2 5.0
.6 5.2
9.6 7.3
.5 1.0
0.5 1.8
1.0 3.2
2.7 -4.8
0.6 3.6
Emissions figures extracted from NEDS, "1972 National Emissions Report", and from additional information provided by
the EPA Region X regarding emissions from Centralia Power Plant in the Portland Interstate (the plant went on-line
in late 1972 and is not included in the NEDS)
-------
Table A-9. Fuel Combustion Emissions Summary, S0?a
AQCR
Eastern Wash.
Northern
Idaho Inter-
state (062)
Washington
Portion
Portland
Interstate
(193)
Washington
Portion
Northern
; Washington
(227)
Olympia-
Northwest
Washington
(228)
Puget Sound
(229)
South
Central
Washington
(230)
103 Tons/Year
46.4
11.7
42.3
74.9
2.0
60.1
206
3.1
Total from
Fuel Combustion
103 tons/yr
3.7
2.4
29.9
65.7
.6
15.9
23.8
1.7
Percent from
Fuel Combustion
7.9
20.2
S7.6
87.9
30.0
26.5
11.6
53.9
Electricity Generation
10-s Tens/Year %
0.16 0.3
.16 1.4
0.25 0.59
56.8 76.0
0.01 0.5
0 0
0 0
0 0
Indust-Commercial
Point Source
Fuel Cofibustion
10-* Tons/Yr %
0.53 1.1
0 0
10.4 24.6
8.0 10.7
0 0
14.0 23.3
13.3 6.5
0.17 5.5
Area Source
Fuel Combustion
103 Tons/Yr %
3.0 6.5
2.2 18.8
19.2 42.4
.90 1.2
0.59 29.5
1.9 3.2
i
10.5 ,5.1
1.5 47.4
I
00
SOo emissions were extracted from NEDS, "1972 National Emissions Report", and from additional information provided by
EPA Region X regarding emissions from Centralia Power Plant in the Portland Interstate AQCR (the plant went on-line
in late 1972 and is not included in the NEDS).
-------
Table A-10. Assessment of Emission Tolerance, Particulates
ACCR
.aste--- *a$-.-'.crt- e™
,»ai' -ret;- rji'tir- '•
P:rt's-: I^te'-staie "i?3~
;ip: ::'-':•;;£:
:-..- •-,.,,:
wost Severe
vs ~ * e
ze:
:i.-—
%;..,
I i---.r
,--
~ "• • i- '
-.
s~:'-e-"'cr
V-.-SCU «.••
2e
5-
"
..
39
-i'f.-'j' a- =
-C 5e!e:tefl
eS ^:r,;--;:
*-'•- il<5 "'
!!«.5-
i"1-j"
"s-n^a"
.«"..•'•
a -_. ,
-;
S-«-iS-i- '-
'or -ttai'
-«r,t raseC
-?
'?
-j
,._,.,„ ,f;
Bise.ear
,lj3tons.'yr)
'?.:-
,.,
y.i
,->.
., ^
>•> c
;•>,:•,,
•-:ss-;-s
"tiai-— eHa
,-tC-S ..r
3."
35. e
23.;
r :
-;.7
•" recaszeo
" T -.-•
i -13":-
\ " tors .v
"
23. e
•- I
:e.3
are= -- >eates- '-ca'*
a-r; -es-- -e--=t -^ -eacv-c :.. .'-1.. ",
"?":. '6.: =ver=:' er-ssic- re--j;;icr,
;"=:';- ;!™rr.-:;'';i''!e;i =;fr' s
r,z.;:<~ <',-,.. ;. -ct ,:.--..
owe' 3_" re^jctior cf "S? -'- area o*
Cont-c* :* la-ce :;i't screes :;
/ielc ar cvera'l rec:cr-»iae e^issirr.
red.:t'Cf cf 32' r-. 1375. *t3e'.
res-'ts S'O* a:tj-'ir*r,t :• '?73.
Cc-f^'i :<= erer =j";r.? arc i~rrcvee
recu:ti;r. IcricuUjrai ccrtrols tc
'-,",1:
-e;e: =•'
r0""?' " ' Se:.~'ec
' -- a-"3in-e't
.:-! -r
,,' '3'
^£5 21
-<•" C-F-
^r.
4e. 72^
^.r^;-;u;
3egior-».iae
lfljtcns -r
* 1.7
47.;-
<3.2
29.4
«.:
15.4
-'lowac'.e
1 Colons /r
41.6
25.4
'^
24.1
*.2
Sjrra'y o* £-issior "oleraice a* iCC°-
Clejr.er ca-rtles outs:=e ict sac; .Spokane
Cc-nt.. ; -s^ ::ssess s;-« e-iss':-- to'ere-ct.
c..*.:*ie 'rcicate: .-4.4 * i:->tons,..r r/
'eg'c'- wide 3'i\ >*'•*. Son« tslera-ce
r^ar]. sessile *r .parv'ic Decree
R.:-rie-«fitat1or a:aesrs :- targe:.
re;*c"-*l3e ;ase 1373 SS50AC irforrat-cr. tiis ray ce tne -eai;r..
-'-» ras's '?•• assess'':: 5 --ere''; t:"s--a':e fcf e^is5J:' ;-:'ease ^; ce:er-;tec b> a j-;:er-e--- 3f t-e oe;--ee ;r re;3',c'Iiatior.
retnee- t-e S:r T-*;r-.at-;' ar; t-e T?" '.;?: 5--"-r :ate. I* t-e iHc^aSe e^'ssi:'* iete^-"-e: -nde' :-e SIP aeve'o3"ent is
'•* sccj'd (--'fi' 2C--.' «'t- t-e aT'owarle ar'ss'r's ca'^ljtec *ro- 1?"3 »•"• -^al^:.. a-c e^Jss;-:- =ata, t-e forecasts cf tre
-------
Table A-ll. Assessment of Emission Tolerance, SO,,
Ease/ear a-.d rorecastec i-'cnavo' f?y State i-c"
;da"-c Interstate C62)
"crt'.and Interstate (193'
Sorferr •din. (22"
^-'S"1
?-;e: So-rc ,229
s::;: :*"-ral """•
Most Severe
Violation
of fiAAQS
(f,g '-3} 3
iece
346 e
-ax.
•;•»..••
240 '
5C5 e
=:,,=..
of NAAQS('ljasi
on ^ost seve1
violation )
0
0'
G
0
-:
j
Level of
A; Selected
o as Control
130 ^
34c
24-nr
rax.
5.-,,,r,
24C
-a*.
5;!—
W>
Seauired
for attain-
ment cased
on selectee
Value
C
85"
o-
^
Segion--ide
Baseyear
Emissions
(103tonyyr
12.1
27.1
t.9
59.0
213
= --
UlowaMe
Erissions JOT
(10- tons/yr)
2-.£
2S.£
7.3
.152
'"
13?
Missions fore-
casted for A5C3
-nder SIP In
!i^et(mw,r>
11. D
122
2.5
•15.6
1-f
...
Conments O1" Control Strategy and
irea 3* Greatest l-.oact
S'ignt SO? emission reductions will
Strategy achieves 6?. control of o.lc
cf worst a'r c^ality. Region *(de
erissions t; increase dje tc new
oower plant ty 1975.
St^ates* w^ll na^e rs e"ect o*-
tC- SO; e~:s*icr.s ir t-is recic'.
••iCjction '--c" ojl- re^ine^ies en;
50 ff?- =jl: -''1 r> 1?75 1r a-ea
cf -C'st 50: solljticr.
5^ co'tro' a* S}; er;ss;c--5 *--o-
i^ "• "aco!-a an; Sea::'e •ne'-e «srst
•-•ssions of SO; •»:!! i'crease
Level of
Worst Air
GulllU i"
1973|
40
{anraal /
81
(24 ,r:
11£
120
90
!24 rr)
fr?- SflROA: and VEDSh
Rea-ctlor
Peoui^ea j 1eg1on-»ide
AttaJrment j 103tons
Pecion-wide
Allomble
E-iSSiOflS
C. | 11.7 | 2,.-
'.'. , 7«.9
t
:• ; 2.0 ~
5 60. 1
11 20c
: , ;.i
115
"=••
1S3
'2.0
SuTav of Erissfon Tolerance of i'3Cfid
J,R. 41.1 x 1C3 tDns/yr.f
VS. 3.4 x ie3tons'y.
••R. 34.1 x 103tons'yr.
'.R. \or.e IncicateQ ~-j aralysU, out
si.:s:an;iai tolerar.ce snoulc res-It
VR. 9 x !03WfW.yr.
ro
o
portion ;* tie =crtla--3 I'-te'-state -C-:=. is a
»-jl-e jsed i" the lr-lenentatic-r. ^lar) »"-;n cc'-'-esco'-cs t; attain-*--: ;f :^e feoera. .
:"ne con"cl \iijei C"osen fcr **e SI= ae.e'o^^nt «.ere ccist'tutea o" tne ~^n---u- 2A-"r -Bines ratne-- man iie
"•cnest'-.H-'latU-'n 'ft'-e \fat is, :-e '.i;ies*. :-cJ -i;nes: reaa*-; -itn-r, a 'esion). Tn-s *acto', =l-s tne 'act
fa: fe st'-ateg-. «ss scares t; tie -o'e strirje'.: state a-rent a'-- statca'ds, nas /-elaed a strategy **.-:" -s
rrc^ael/ 'cre"se'.e--e *"an necessa^,. tc assure attj'nne-t j* tne *ece--a' ajr suslUy s:anaar*s. "••is -ou'C iraics
•ne I'.^Uiooa tnat e^'ssici tc^e'-a'-ces -*.> re st'V I'-este*' tha- si-oi.- sccve.
r; 3^: -ot ca.se .
?Fe*ers — -i-'es- Zna »iy H -c,- averaoe .al^e
co"st-:t>.es :-e *sr»t *^ :-al--... -ela'-'.-t *-: tte
'
-eg'cr., or tc "c^est 'n'-a' -el-e -^eas-rec in tre region iwMcne.
'' stardar;. See Ta:'e --- *:r at'^Uio- c' feoe-al sir 5jalUy
S data MS avsila:le '--or liE:s *:- :*ie yeer
-------
Table A-12. Fuel Combustion Emission Regulations in Washington
Governing Authority
State of Washington
Dept. of Ecology
Puget Sound Air
Pollution Agency
Spokane County
Air Pollution
Control Authority
Northwest Air
Pollution
Authority
Southwest Air
Pollution Control
Authority
Olympic Air
Pollution Control
Authority
Yakima County
Clean Air Authority
Applicable Region
State of Washington
Puget Sound
Interstate AQCR
Eastern Washington
Northern Idaho
Interstate AQCR
Northern
Washington AQCR
Portland
Interstate AQCR
Olympic-Northwest
Washington AQCR
South Central
Washington AQCR
S02 Emission Regulations
1000 ppm
1000 ppm
.3-":' Sulfur, *1 fuel oil
. 5\ sulfur, r2 fuel oil
1.5 lb/106Btu heat
input/hr
1500 ppm
1500 ppm (also,- ambient
air standards must be
off property. )
Compliance
Date
July 1, 1975
currently
effective
currently
effective
currently
effective
currently
effective
TSP Emission Regulations
.1 grain/SCF
.1 grain/SCF existing
sources
.05 grain/SCF, new sources
.20 grain/SCF, existing wooc
burning sources
.10 grain/SCF, new wood
burning sources
.10 grain/SCF
40 Ib/hr max
.1 grain/SCF existing
sources
.05 grain/SCF new sources
.1 grain/SCF
.2 grain/SCF, existing
sources
.2 grain/SCF, existing |
sources /
.1 grain/SCF, new sources'
Compl iance
Date
July 1, 1975
currently
effective
currently
effective
currently
effective
July 1, 1975
currently
effective
currently
effective
currently
effective
i
ro
Note: When regulations of the State of Washington and a local governing authority are in conflict, the more stringent
regulation is enforced.
-------
APPENDIX B
The purpose of Appendix B is to provide an assessment of the feasibility
for accomplishing clean fuel savings and regulation relaxation. This assess-
ment is carried out with an evaluation of various regional air quality indi-
cators developed in Section 2 and compiled in Appendix A. The regional air
quality indicators considered are comprised of criteria shown in Table B-l
and B-2, and include : (1) the breadth of air quality violations, (2) expected
attainment dates for NAAQS, (3) AQMA designations, (4) total regional emissions,
(5) portion of emissions from fuel combustion sources, and (6) regional toler-
ance for emissions increase. When it is quantifiable and suitably applied,
the emission tolerance possibly provides the most important indicator, since
it provides a measure of the over-cleanliness of the region, now or projected,
and indicates how much additional pollution (such as from dirtier fuels) can
be permitted without resulting in violations of federal air standards.
B-l
-------
Table B-l. Candidacy Assessment for: Clean Fuel Savings/Relaxation of S02 Regulations
AQCR
Eastern Washington-Northern
Idaho Interstate (062)
(Washington portion)
Portland Interstate (193)
(Washington portion)
Northern Washington (227)
Olympic Northwest
Washington (228)
Puget Sound (229)
South Central
Fraction
of Counties
in AQCR
With Air
Quality
Violations
in 1973°
0/8
0/5
0/6
0/9
1/4
0/6
Expected
Attainment
Date
a
a
a
a
1/75
a
Counties
with
AQMA
Designations
none
Clark
none
none
none
none
Total S02
Emissions
in
AQCR
103 tons/yr.
11.7
74.9
2.0
60.1
206
3.1
% Emission
from Fuel
Combustion
20.2
87.9
30.0
26.5
11.6
53.9
Tolerance
for S02
Emissions
Increase
(Table A-10)
(103 tons/yr)
13.6
41
3.4
34
none
9.0
Overall
Regional
Evaluation
good
candidate
good
candidate
good
candidate
good
candidate
marginal
candidate
good
candidate
CO
I
ro
aAir quality levels within standards in 1973 and expected to remain so through 1975.
blt should be noted that air monitoring stations do not exist in several of the counties. The location and number of
air monitoring sites in the various AQCRs is given in Figures A-2 through A-7.
-------
Table B-2. Candidacy Assessment for: Clean Fuel Savings/Relaxation of Participate Regulation
AQCR
Eastern Washington-Northern
Idaho Interstate (062),
(Washington Portion)
Portland Interstate (193)
(Washington Portion)
Northern Washington (227)
Olympic-Northwest
Washington (228)
Puget Sound (229)
South Central Washington (230
Fraction
of Counties
in AQCR
With Air
Quality
Violations
in 1973°
4/8
1/5
1/6
1/9
3/4
2/6
Expected
Attainment
Date
7/75
7/75
7/75
7/75
7/75
7/75 .
Counties
with
AQMA
Designations
Spokane
none
none
none
King, Pierce
Snohomish
none
Particulate
Emissions
in
AQCR
103 tons/yr.
11.7
47.9
28.2
29.4
56.0
15.4
% Emission;
from Fuel
Combustion
9.6
36.9
6.1
14.8
26.6
10.7
Tolerance
for
Particulate
Emissions
Increase
(Table A-ll)
(10J tons/yr.)
none3
none3
3.5
none3
none
none
Overall
Regional
Evaluation
marginal
candidate
marginal
candidate
good
candidate
marginal •
candidate
poor
candidate
poor
candidate
ro
to
3No emission tolerance was indicated by the region wide analysis shown in Table A-ll. However, since air quality for this
region is characterized by one or two emission hot spots, significant area in the AQCR away from the hot spots will possess
an emission tolerance.
blt should be noted that air monitoring stations do not exist in several of the counties. The location and number of
air monitoring sites in the various AQCRs is given in Figures A-2 through A-7.
_
-------
APPENDIX C
This section provides a characterization of individual power plants by
AQCR. Current power plant information used to prepare Table C-l were obtained
from three main sources: (1) Federal Power Commission computerized listings
of power plants and their associated fuel use, (2) the National Coal Associa-
tion "Steam Tables" listing of power plants and fuel use in 1972, and (3)
emission data in the NEDS data bank as of 1974. 1973 fuel schedules were
extracted from the FPC (1 above) data, or when this was not available, 1972
fuel schedules were reported in Table C-l from values extracted from the
Steam Tables. Heat inputs were calculated based on the fuel heating values
obtained from either (1) or (3) above. The S0? and particulates emissions
reported in Table C-l correspond to the fuel schedules reported, and were
extracted from (1) or (3) above. When emissions and fuel schedule figures
were not available for the same year, emissions were scaled proportionately
to reflect the 1973 fuel schedule.
Also shown in Table C-l are the 1975 regulations which are currently
applicable to the given plant, taken from Table A-12.
It might be cautioned that AQCR total emissions calculated in the tables
of Appendix C (and also Appendix D) may not agree exactly with total emissions
represented in Appendix A (Tables A-8, A-9). This is a result of both differ-
ing fuel schedules in 1973 compared to previous years and the relative "complete-
ness" of the NEDS data bank.
C-l
-------
Table C-l. Power Plant Characterization
County
Plant Name
Size, and
"uel Design
PORTLAND INTERSTATE AQCR
Cowlitz
Central! a
PUGET SOW
King
King
Pierce
Cowlitz
26.6 MW
Coal, Oil
Wood
Centrali a
Coal, Oil
D AQCR (#229)
Shuffleton
86 Mw
Oil
Lake Union
30.0 Mw
Oil
Steam
54.0 MW
Oil
TOTAL
Fuel Use
Type Heat
£ Sulfur Annual Incut
% Ash Quantity (106Btu/Hr)
(WASHINGTON PORTION):
Wood 30000 41 . 1
Coal 3740 9820
.8%S
ISXash
Oil 2772 44.3
.3%S
Diesel 966 15.4
Oil 7900 126.0
1 . 79SS
Oil 4788 76.4
1 . 55SS
Oil 5922 94.2
1.655JS
Emissions
S0?
Existino
Tcns/Yr Lbs/106Btu
23 0.13
56848 1.3
65.3 0.3
-1
1097 1.99
575 1.71
760 1.84
2432
Al lovable Emissions
(Eased en
Regulations Limits)
. Tons/Yr Lbs/106Btu
343 1.94
84834 1.94
376 1.94
1.94
1069 1.94
652 1.94
801 ' 1.94
2522
IS?
• Existing ,
'Tons/Yr Lbs/10c5tu
412 2.29
9900 .23
11.1 0.06
3.9 0.06
101 0.18
48,0 0.15
59.2 0.15
209
Allowable Emissions
(Based on
Regulations Limits)
Tons/Yr Lbs/106Btu
20.2 .112
4739 .11
20.3 .11
7-1 .11
i
62.8 .11
35.8 .11
44.2 .11
,1
143
b Oil - 103 gallons, Gas - 103 MCF, Coal - 103 tons
1. Data was extracted from information in NEDS as of 1972, with exception of data reported for the Centralia Power Plant,
which began operation in late 1972. 1973 fuel use data for the Centralia Power Plant was provided by the EPA Regional
Office in Region X, and emissions was calculated by use of emission factors from EPA Document AP-42.
-------
APPENDIX D
This section provides a characterization of individual industrial/
commercial/institutional fuel combustion emission sources. The data was
derived from a NEDS rank order emissions listing, and from emissions data
in the NEDS, data bank as of June 1974.
D-1
-------
Table D-l. Industrial-Commercial Fuel Combustion Point Source Characterization
County
Fuel Use
Plant Name ' Type Heat
Size, and ; % Sulfur Annual Input
Fuel Design | % Ash Quantity (106Btu/Hr)
EASTERN WASHINGTON - NORTHERN IDAHO INTERSTATE (#62)
Grant
Utah, Idaho
Sugar
All plants
burning wd.
Coal 8450 183
LOSS
7.0SA
Gas 3640 . 416
93366 128
Emissions
SOp
Existina
Tons/Yr Lbs/106Btu
896 1.1
1 5xlO~4
216.7 0.08
TOTAL 943.7
PORTLAND
Clark
Cowlitz
Cowl i tz
Clark
Cowlitz
Cowlitz
• Allowable Emissions
(Based on
Regulations Li.mits)
Tons/Yr Lbs/10bBtu
1580 1.94
3880 1.94
1132 1.94
6592
INTERSTATE AQCR (#193)
Ft Vancouver D. Oil 40 0.68
Plywood
Kalama Chem.
Longview
Fiber Co.
Weyerhauser
Vancouver
Weyerhauser
Power
Longview
Longview
Fiber
0.32%S
Waste Tar 4200 tons
R.Oil 1001 17.1
1 . 5SS
Gas 923 111
R.Oil 1720 29.5
1 . 75SS
R.Oil 304 5.2
2.65;S
D.Oil 40 0.64
1.6SS
Gas 785 94.1
R.Oil 9296 159
1 . 75SS
Gas 6120 734
R.Oil 13740 235
2.9SS
Gas 3 0.36
0.91 0.30 .
„
118 1.58
0.28 <.01
236 1.83
5.9 1.94
1.94
145 1.94
543 1.94
250 1.94
62.0 2.72 44.2 1.94
4.5 1.61
0.24 <.01
1277 1.8
1.8 <.01
3128 3.04
0.029 0.02
5.4 1.94
466 1.94
1376 1.94
3492 1.94
1996 1.94
2.8 1.94
TSP
Existing . •
Tons/Yr Lbs/10°Btu
131 0.2
30 0.02
700 1.2
861
0.3 0.10
92.0
11.5 0.15
8.3 0.02
19.8 0.15
-
3.50 0.15
0.30 0.11
7.1 . 0.02
106 0.15
58.1 0.02
158 0.15
0.001 <.01
Allowable Emissions
(Based on
Regulations Limits)
Tons/Yr Lbs/105Bt
73.4 .11
168 .11
65.3 .11
306
0.34 .11
.11
8.6 .11
46.5 .11
14.8 .11
2.6 .11
0.3 .11
39.8 .11
79.9 • .11
325 .11
118 .11
.112 .11
o
I
ro
-------
Table D-1. Industrial-Commercial Fuel Combustion Point Source Characterization
J
County
Clark
Clark
Plant f>'ame
Size, ar.d
Fuel Design
Boise
Cascade
Vancouver
Crown
Zellerback
Power
All sources
combusting
wood
TOTAL
NORTHERN WASHINGTON INTE
Sources
combusting
wood
OLYMPIC - NORTHWEST WASH
Grays
Harbor
Rayonier.Inc.
Weyco,
Cosmop
Grays
Harbor
Veneer
Fuel Use
Type Heat
2 Sulfur Annual Input
£ Ash Quantity (10°Btu/Hr)
R.Oil 1729 29.6
2.5:=S
Gas 953 114
R.Oil 10690 183
2.5?,S
Gas 5988 718
1071474 1470
MATE (#227)
Wood 136300 187
NGTOil AQCR (£228)
R.Oil 28749 473
4. OSS
R.Oil 5884 96.7
1 . 26%S
Gas 80 9.1
Emissions
Existinc
Tons/Yr Lbs/lC6Btu
339 2.6
0.29 <.01
2098 2.6
1.8 <.01
536 0.08
7804
68 .08
9027a 4.36
582 1.37
0 0
50? TS? |
Allowable Emission:
(Based on '
Regulations Limits
Tons/Yr Lbs/10bBtu
t
253 1.94
563 1.94
1565 1.94
3492 1.94
12998 1.94
27197
1275 1.5
4017 1.94
824 1.94
1.94
Existina fi
Tons/Yr Lbs/10b6U
19.9 0.15'
8.6 0.02
123 0.15
53.9 0.02
8036 1.2
8707
1023 1.2
331a 0.16
60 0.14
1 0.03
Allov/aole Emissions
(Based on
Regulations Lir.its)!
Tons/Yr Lbs/1063U
14.9 .11
48.2 .11
91.8 .11
302 .11
750 .11
1843
95.5 .11
232 .11
48.0 .11
3.7 .11
o
I
CJ
-------
Title.D_-l. Washington Industrial-Commercial Fuel Combustion Point Source Characterization
o
i
County
Shagit
Clallam
Jeffer-
son
Plant Name
Size, and
Fuel Design
Fuel Use
Type Heat
•".. Sulfur Annual Input
% Ash Quantity (10°Btu/hr)
Publisher's . R.Oil 285 4.88
Forest 1.8SS
Prods Gas 10 1.14
Rayonier P. R.Oil 17769 292
Angeles 1.5;;S :
Crown Zeller-
back
P.Angeles
Crown Zeller-
back
P. Townsend
All sources
burning
wood
TOTAL
PUGET SOUND (?229)
Pierce Regis Kraft
R.Oil 11608 191
1 . 7aS
R.Oil 609 10.0
3.0iS
576000 789
R.Oil 9508 101
1.45,5
Gas 783 93.4
Emissions
SO.;
Existing
tons/yr lbs/106BTU
40. 3a 1.89
0.09a 0.18
2091 1.63
1549a 1.80
143 3.26
288 .08
13666
635a 1.44
0.23a <.01
Allowable
tons/yr lbs/106BTU
41.4 1.94
0.97 1.94
2489 1.94
1616 1.94
43.9 1.94
6984 1.94
16016
858 1.94
446 1.94
7S3
Existinn
tons/yr Ibs/liniTll
3.3a 0.15
0.0038 <.01
204 0.16
133a 0.16
7 0.16
4320 1.3
5059
109a 0.25
7.1a 0.02
Allowable
tons/yr lbs/10bBTU
2.5 .11
0.34 .11
1 43 .11
93.1 .11
4.9 .11
322 .11
900
48.8 .11
39.8 .11
-------
Table D-l. Washington Industrial-Conmercial Fuel Combustion Point Source Characterization
o
i
Ul
County
King
Pierce
Pierce
Snohamish
Snohomish
Plant Name
Size, and
Fuel Design
Weyerhauser
Shoq. Falls
Port of
Tacoma
McChord
AFB
Scott Paper
Everett
Plywood
Fuel Use
Type Heat
1 Sulfur Annual Input
2 Ash Quantity (106Btu/hr)
R.Oil 300 5.14
1.4SS
R.Oil 49 0.75
1.2%S
Gas 6 0.72
Coal 20200 57.6
0.6%S
1.2%A
R.Oil 1086 18.6
1.6%S
D.Oil 169 2.7
0.27%S
Gas '57 6.8
R.Oil 2335 40.0
1.4SS"
R.Oil 1834 31.4
1 . 5XS
Gas 3681 441
R.Oil 66 1.13
1 . 2%S
Gas 174 20.8
Emissions
SO
Existing
tons/yr lbs/106BTU
33. Oa 1.44
4.1a 1.2
0.0053 0.02
230a 0.91
136a 1.7
3.2a 0.27
. 0.02a <.01
257 1.47
216 1.57
1.1 <.01
6.2a 1.25
0.05a <.01
I _ _„, 1
Allowable
tons/yr lbs/10°BTU
4.9
490
155
23.0
38.8 1.94
339 1.94
267 1.94
2134 1.94
9.6 1.94
97.0 1.94
Existino
tons/yr lbs/10f)i:TII
3.5a 0.15
0.5a 0.15
0.002a <.01
502 1.99
12. 5a 0.15
1.3a 0.11
0.5a 0.1
26.9 0.15
21.1 1.57
33.1 0.02
0.8a 0.16
1.57a 0.02
-$?
Allowable
tons/yr lbs/10bBTU
2.6 .11
0.4 .11
0.2 .11
28.3 .11
9.3 .11
1.3 .11
0.6 .11
20.1 .11
1.5 .11
185 .11
0.6 .11
3.6 .11
-------
Table D-). Washington Industrial-Commercial Fuel Combustion Point Source Characterization
o
i
CT)
County
Snohomish
Pierce
Plant Name
Size, and
Fuel Design
Weyerhauser
Everett
U.S. Army,
Ft Lewis
All sources
burning
wood
TOTAL
Fuel Use
Type Heat
% Sulfur Annual Input
* Ash Quantity (10°Btu/hr)
R.Oil 1800 30.8
1 . 4%S
Gas 1062 127
R.Oil 9868 169
1 . 36SS
D.Oil 9458 151
0.27:55
1651433 2262
SOUTH CENTRAL AQCR (#230)
Walla-
Walla
Boise Cascade
All sources
burning wood
TOTAL
Oil 651 11.1
3.2%S
Gas 2557 305
169700 232
Emissions
SO?
Existing
tons/yr lbs/106BTU
198a 1.47
0.32a <.01
1054a 1.42
181a 0.27
826 .08
4116
159 3.27
• 0.77 .01
85 0.08
285
Allowable
tons/yr lbs/10bBTU
261 1.94
621 1.94
1440 1.94
1301 1.94
20031 1.94
28567
94.3 1.94
1494 1.94
2061 1.94
3639
TSP
Existinn
tons/yr Ibs/lirlSTU
20. 7a 0.15
9.6a 0.02
113a 0.15
70. 9a 0.11
12385 1.3
13319
7 0.14
21 0.02
1273 1.3
1301
Allowable
tons/yr lbs/105BTU
15.5 .11
53.8 .11
84.4 .11
72.2 .11
1067 .11
1635
5.6 .11
118 .11
110 .11
234
Calculated based on emission factors from "Compilation of Air Pollutant Emission Factors," Document AP-42, April 1973.
bOil - 103 gallons, Gas - 103 MCF, Coal - 103 tons
Notes:
1. Data was extracted data in NLDS data bank as of June 1974.
-------
APPENDIX E
Table E-l shows area 'source fuel use for the-entire state of Wash-
ington. The approximate energy values are compared for each fuel along
with the percent of overall energy derived from each fuel. The bottom
row entitled "all fuels, all sources" may not match totals from
Appendices A, C, and D, exactly, since neither the NEDS or individual
appendix totals are all-inclusive. Also fuel schedules may change from
one year to the next.
E-l
-------
Table El. Total State Area Fuel Use
ro
Source
(Area Only)
Residential
Industrial
Commercial/
Institutional
Total (Area
Sources)
% By Fuel
Total (All
Fuels, All
Sources)
% By Fuel
COAL
103 tons 109 Btu
4.86 112
0 0
0 0
4.86 112
0.1
89.4 2060
0.7
RESID. OIL
103 gal 109 Btu
0 0
0 0
0 0
0 0
0
161727 22640
7.3
DIST. OIL
103 gal 109 Btu
479100 67078
0 0
0 0
479100 67078
35.5
482550 67555
21.9
GAS
106 ft3 109 Btu
35460 35460
69830 69830
14340 14340
119630 119630
63.3
170000 170000
55.1
WOOD
103 tons 109 Btu
177.4 2126
0 0
0 0
177.4 2126
1.1
3875.7 46444
15.0
TOTAL
109 Btu
104776
69830
14340
188946
308698
Fuel use figures are taken from data in NEDS data bank as of September 1974.
-------
APPENDIX F
The Tables F-l and F-2 illustrate the effect on emissions of particu-
lates and S02 when power plant and industrial fuel burning sources listed
in Appendices C and D are allowed to emit at the ceiling rate permitted by
emission regulations. It is assumed that heat input remains the same, and
existing regulations are applied to gross heat input for each AQCR. It is
emphasized that this table is hypothetical in that no fuel mix may exist to
allow all sources to emit exactly at regulation levels. The calculations do
give some insight into adequacy of existing regulations for allowing air
quality standards to be achieved if a fuel schedule different from the one at
present were in effect.
F-l
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Table F-l. Assessment of Restrictiveness of Particulate Emission Regulations for Fuel Burning Equipment
AQCR
Eastern Washington-
Northern Idaho
Interstate (62),
Washington Portion
Portland Interstate
(193), Washington
Portion
Northern Washington
(227)
Olympic-Northwest
Washington (228)
Puget Sound (229)
South Central
Washington (230)
Fuel Burning
Emissions, 1972a
lO'Hons/yr
1.1
17.7
1.7
4.4
14.9
1.7
Fuel Burning
Emissions
Projected for
1975 b
10 tons/yr
.56
8.23
.68
1.37
3.87
.66
1975 Fuel
Burning Emissions
at Regulation
Limit Rates c
10^ tons/yr
.66
9.02
.68
1.37
4.12
•74
Increase in 1975 Emissions in
AQCR When Fuel Burning Units
Emit at Regulation Limits
103
tons/yr
.10
.79
0
0
.25
.09
in % of Total
Emission Inventory
Allowable for
Attainment of j
Standards in 1975
1.6
2.4
0
0
1.0
2.1
Tolerance for
Particulate
Emissions Increase
in AQCR in 1975
103 tons/yr
None except in
areas away from
hot spots.
None except in
areas away from
hot spots.
3.5
None except in
clean areas away
from hot spots.
None.
None.
Assessment of Restrictiveness
of Fuel Burning Emission
Regulations e
Not overly restrictive for
sources contributive to hot
spot air quality. Over-
restrictive in clean areas
away from hot spots
Not overly restrictive for
sources contributive to hot
spot air quality. Over-
restrictive in clean areas
away from hot spots.
Overly-restrictive. Regula-
tions can be relaxed sub-
stantially.
Not overly restrictive for
sources contributing to poor
air quality areas.
Not overly restrictive.
Not overly restrictive.
ro
Calculated from Table A-8.
bFuel burning emissions with controls in 1975 were assumed to be the same as those tabulated in Appendix C, D, and E with the following adjustments: (1)
Those sources which were out of compliance with emission regulations were assigned a 1975 level equivalent to source operation at the emission regulation
limit, and (2) the total emissions tabulated for the source categories of Appendix C, D, and E were corrected to reflect the total fuel combustion emis-
sions inventory as reported by NEDS (1972 National Emissions Report) and included here in Table A-8. The total emissions calculated in the tables of
Appendix C, D, E differ from that in Table A-8 because of (1) the unmatched dating fuel schedule information between the two NEDS publications which were
needed to develop the tables of this report, and (2) the omission in Appendices C and D of process/combustion point sources which emit combustion and
process emissions together, and do not lend well to quantitative separation.
cThese emissions have been calculated in Appendices C and D.
dThis value is taken from the one of the two indicated "allowables" shown in Table A-10 which is judged more reliable on the basis of the reconcilation
scheme outlined on the table.
eThe restrictiveness of the combustion emission regulations is judged by comparing the increase in 1975 fuel burning emissions caused by operation at regula-
tion limits with the "emission tolerance" the AQCR is appraised to have (Table A-10). If the increase exceeds the emission tolerance, then it is clear
that the regulations are not overly restrictive. When the increase does not exceed the emission tolerance, the regulations may be relaxed to allow higher
emission rates without interfering with the attainment of federal air standards.
-------
Table F-2. Assessment of Restrict!veness of Fuel Burning S09 Emission Regulations
Increase in 1975 Emissions in I
AQCR When Fuel Burning Units
Emit at Regulation Limits
Fuel Burning 1975 Fuel in % of Total j
Emissions Burning Emissions Emission Inventory Tolerance for S02
Fuel Burning Projected for at Regulation Allowable for Emissions Increase Assessment of Restrictivenessi
Emissions, 1973a 1975 b Limit Rates c , Attainment of ri in AOCR in 1975 of Fuel Burning Emission ;
AQCR 1QJ tons/yr 103 tons/yr 10J tons/yr 10 tons/hr 1975 Standards 1QJ tons/yr Regulations e
Eastern Washington-
Northern Idaho
Interstate (62)
Washington Portion
Portland Interstate
(193), Washington
Portion
Northern Washington
(227)
Olympic-Northwest
Washington (228)
Puget Sound (229)
South Central
Washington (230)
2.4
66.7
0.6
15.9
23.8
1.7
2.20
110.6
0.59
10.03
23.67
1.57
6.16
133.1
K67
17.12
58.23
4.80
3.96
22.53
1.08
7.09
34.56
3.23
17
19
20
7.5
19
27
13.6
41.1 x 103 tons/
yr.
3.4
34
None
9.0
Overly restrictive. Subr
stantial relaxation
possible.
Overly restrictive. Sub-
stantial relaxation
possible.
Overly restrictive. Sub-
stantial relaxation possible.
Overly restrictive. Sub-
stantial relaxation possible.
Not overly restrictive.
Overly restrictive. Sub-
stantial relaxation possible.
"From Table A-9.
bFuel burning emissions with controls in 1975 were assumed to be the same a.s those tabulated in Appendix C, D, and E with the following adjustments: (1)
Those sources which were out of compliance with emission regulations were assigned a 1975 level equivalent to source operation at the emission regulation
limit, and (2) the total emissions tabulated for the source categories of Appendix C, D, and E were corrected to reflect the total fuel combustion emis-
sions inventory as reported by NEDS (1972 National Emissions Report) and included here in Table A-8. The total emissions calculated in the tables of
Appendix C, D, E, differ from that in Table A-8 because of (1) the unmatched dating fuel schedule information between the two NEDS publications which were
needed to develop the tables of this report, and (2) the omission in Appendices C and D of process/combustion point sources which emit combustion and
process emissions together, and do not lend well to quantitative separation.
cThese emissions have been calculated in Appendices C and D.
dThis value is taken from the one of the two indicated "allowables" shown in Table A-10 which is judged more reliable on the basis of the reconcilation
scheme outlined on the table.
eThe restrictiveness of the combustion emission regulations is judged by comparing the increase in 1975 fuel burning emissions caused by operation at regula-
tion limits with the "emission tolerance" the AQCR is appraised to have (Table A-10). If the increase exceeds the emission tolerance, then it is clear
that the regulations are not overly restrictive. When the increase does not exceed the emission tolerance, the regulations may be relaxed to allow higher
emission rates without interfering with the attainment of federal air standards.
-------
Table F-3. Fuel Switch Evaluation
Fuel
AQCR Source Category Type
Eastern. Washington Industrial & Coal
Northern Idaho Commercial Gas
Interstate (62). Plants
Washington portion
Total
Portland Power Plants Coal
Interstate (193), Wood
Washington portion Industrial Pints Oil
& Commercial Gas
Wood
Total
Northern Industrial & Wood
Washington (227) Commercial
Plants
Olympia - Industrial & Oil
Northern Commercial Gas
Washington (225) Plants Wood
Total
Puget Sound (229) Power Plants Oil
Industrial & Coal
Commercial pints Oil
Gas
Wood
Area Distil
late 0
Total
South Industrial & Oil
Central (230). Commercial pints Gas
Wood
Total
Projected Usage in 1975
Heat Emissions
Input tons/yr
Quantity3 105 Btu/hr TSP S02
8450 183 73.4 896
3640 416 30 1
599 103.4 897
1,160,000 3046 7000 104000
30,000 41.1 20.2 23. C
38,520 659.7 331 5497
14,772 1,771 136 4.4
1,071,474 1,470 750 536
6,988 8,237 110,060
136,300 187 0.11 O.C
64,907 1,068 523 8,251
90 10.24 1.0 0.0
576,000 789 372 280
1,867 896 8,531
18,610 296.6 105.7 2,404
20,200 57.6 28.3 230
36,468 551.5 254.7 2,766
5,763 689.7 51.9 . 1.8
1,651,433 2,262 1,067 826
- 292,250 4,700 2,250 6,340
il
651 11.1 5.6 94.3
2,557 305 21 0.7
169,700 232 85 110
Gas & Oil Switch to Coald
Increased
Heat Emis.from
Quantity Input Switch, tons/yr
Switched 10° BTU/hr TSP S02
3640 416 136 3006
416 136 3006
3
1
3
3
1,255 21.3 10.5 153.9
57 6.8 3.4 49.1
28.1 13.9 203. C
7
Gas Switch to Oil, Oil to 2% S Oilc
Increased
Heat Emis.from
Qty Input Switch, tons/yr
Switched 10B Btu/hr. TSP S02
8,520 660 0 783
4,772 1,771 753 17,376
2,431 753 18,159
64,904 1,068 0 1,200
10 1.14 4.9 11.2
1,069 4.9 1,212
18,610 297 0 336
5,706 682.9 270 6,700
'92259 4,700 C 6,340
270 13,376
651 11.1 0 26
2,557 305 153.9 2,992
316 154 3,018
Increase in AQCR
Emissions Due to
Fuel Switch
tons/yr
TSP S02
136 3,006
136 3,006
136 3,006
753 18,159
753 18.159
0 0
4.9 1,211
4.9 1,211
0 ' .336
10.5 153.9
273 6.749
0 6,340
284 13,579
C 26
153.9 2,992
154 3,018
a q n o
Quantity is units as follows: Oil -10 gallons, gas -10 CF, Coal - 10 tons.
The projected usage and emissions for fuel burning sources in 1975 are the same as in those tabulated in Appendix C, D, and E except 1) emissions
are adjusted for compliance in 1975, and 2) usage and emissions reflect new fuel sources anticipated on-line in 1975. Growth was assumed to
be non-increasing, based on non-employment trends in the State.
cln switching to oil, a 2% Sulfur content is assumed for residual oils, and 18 for distillates in area sources.
Conversions to coal were considered only for those plants presently using coal and oil or gas.
-------
r
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) SAROAD Data Bank, 1973 Information U.S. EPA.
(4) "Steam-Electric PJant Factors/1972", 22nd Edition National Coal
Association.
(5) "Federal Air Quality Control Regions" U.S. EPA, Pub. No. AP-102.
(6) Federal Power Commission, U.S. Power Plant Statistics Stored in EPA
Data Bank, September 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.
F-5
-------
TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1. REPORT NO.
EPA-450/3-74-065
2.
3. RECIPIENT'S \CCESSIOWNO.
4. TITLE AND SUBTITLE
IMPLEMENTATION PLAN REVIEW FOR WASHINGTON AS
REQUIRED BY THE ENERGY SUPPLY AND ENVIRONMENTAL
COORDINATION ACT
5. REPORT DATE
December 1974
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
10. PROGRAM ELEMENT NO.
U.S. Environmental Protection Agency, Office of Air
Quality Planning and Standards, Research Triangle
Park, N.C., Regional Office X, Seattle, Washington,
and TRW, Inc., Redondo Beach, California
11. CONTRACT/GRANT NO.
68-02-1385
12. SPONSORING AGENCY NAME AND ADDRESS
U.S. Environmental Protection Agency
Office of Air and Waste Management
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
13. TYPE OF REPORT AND PERIOD COVERED
Final
14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
16. ABSTRACT
Section IV of the Energy Supply and Environmental Coordination Act of 1974,
(ESECA) requires EPA to review each State Implementation Plan (SIP) to determine
if revisions can be made to control regulations for stationary fuel combustion
sources without interfering with the attainment and maintenance of the national
ambient air quality standards. This document, which is also required by Section
IV of ESECA, is EPA's report to the State indicating where regulations might be
revised.
17.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.IDENTIFIERS/OPEN ENDED TERMS
c. COS AT I Field/Group
Air pollution
State implementation plans
18. DISTRIBUTION STATEMENT
Release unlimited
19. SECURITY CLASS (This Report)
Unclassified
21. NO. OF PAGES
69
20. SECURITY CLASS (Thispage)
22. PRICE
EPA Form 2220-1 (9-73)
F-6
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