EPA-450/3-74-066

DECEMBER 1974
      IMPLEMENTATION PLAN REVIEW
                   FOR
               INDIANA
              AS REQUIRED
                   BY
           THE ENERGY SUPPLY
                   AND
   ENVIRONMENTAL COORDINATION ACT
      U. S. ENVIRONMENTAL PROTECTION AGENCY

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                                                    EPA-450/3-74-066
                   IMPLEMENTATION PLAN REVIEW

                              FOR

                            INDIANA

REQUIRED BY THE ENERGY SUPPLY AND ENVIRONMENTAL COORDINATION ACT
              PREPARED BY THE FOLLOWING TASK FORCE:

          U. S. Environmental Protection Agency, Region V
                         230 S. Dearborn
                    Chicago, Illinois  60604
            Energy and Environmental Systems Division
                   Argonne National Laboratory
                    Argonne, Illinois  60439
                        (EPA-IAG-D5-0463)
              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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                          IMPLEMENTATION PLAN REVIEW

                                      FOR

                                    INDIANA

       REQUIRED BY THE ENERGY SUPPLY AND ENVIRONMENTAL COORDINATION ACT


                               Table of Contents


1.  EXECUTIVE SUMMARY  	      5

2.  INDIANA STATE IMPLEMENTATION PLAN REVIEW	     11

    2.1  Summary	     11
    2.2  Air Quality Setting for the State of Indiana	     12
    2.3  Background on the Development of the Current State
           Implementation Plan	     17
    2.4  Special Considerations for the State of Indiana   ....     18

3.  AIR QUALITY CONTROL REGION ASSESSMENTS	     19

    3.1  General Methodology 	     19
    3.2  Metropolitan Chicago Interstate AQCR (#67)  	     21
    3.3  East Central Indiana Intrastate AQCR (#76)  	     23
    3.4  Evansville-Cwensboro-Henderson Interstate AQCR (#77) ...     25
    3.5  Louisville Interstate AQCR (#78)   	     27
    3.6  Metropolitan Cincinnati Interstate AQCR (#79)  	     29
    3.7  Metropolitan Indianapolis Intrastate AQCR (#80)   ....     31
    3.8  Northeast Indiana Intrastate AQCR (#81)	     33
    3.9  South Bend-Elkhart-Benton Harbor Interstate AQCR (#82)   .   .     35
    3.10 Southern Indiana Intrastate AQCR (#83)   	     37
    3.11 Wabash Valley Intrastate AQCR (#84)	     39

TECHNICAL APPENDICES

    APPENDIX A - State Implementation Plan Background	     41
    APPENDIX B - Regional Air Quality Assessment	     55
    APPENDIX C - Power Plant Assessment	     59
    APPENDIX D - Industrial, Commercial, Institutional Point
                 Source Assessment	     65
    APPENDIX E - Area Source Assessment	     71
    APPENDIX F - Fuels Assessment  .	     73

REFERENCES	     75

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                       IMPLEMENTATION PLAN REVIEW
                               FOR INDIANA
    REQUIRED BY THE ENERGY SUPPLY AND ENVIRONMENTAL COORDINATION ACT


1.0  EXECUTIVE SUMMARY

     The enclosed report is the U. S. Environmental Protection Agency's (EPA)
response to Section IV of the Energy Supply and Environmental Coordination Act
of 1974 (ESECA).  Section IV requires EPA to review each State Implementation
Plan (SIP) to determine if revisions can be made to control regulations for
stationary fuel combustion sources without interfering with the attainment and
maintenance of the National Ambient Air Quality Standards (NAAQS).  In addition
to requiring that EPA report to the state on whether control regulations might
be revised, ESECA provides that EPA must approve or disapprove any revised
regulations relating to fuel burning stationary sources within three months
after they are submitted to EPA by the states.  The states may, as in the Clean
Air Act of 1970, initiate State Implementation Plan revisions; ESECA does not,
however, require states to change any existing plan.
     Congress has intended that this report provide the state with information
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 parallel 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 with regulations or to revise the SO- emission regulations.  The
states have also been asked to discourage large scale shifts from coal to oil
where this could be done without jeopardizing the attainment and maintenance
of the NAAQS.

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     To date, EPA's fuels policy has addressed only those states with the
largest clean fuels saving potential.  Several of these states have or are
currently in the process of revising SO- 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 or_ more stringent state air quality standards.  Also, at that time an
acceptable method for formulating control strategies was the use of an example
region for demonstrating the attainment of the standards.
     The example region concept permitted a state to identify the most polluted
air quality control region  (AQCR) and adopt control regulations which would
be adequate to attain the NAAQS in that region.  In using an example region,
it was assumed that NAAQS would be attained in the other 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 example, a
control strategy based on a particular region or source can result in a
regulation requiring 1 percent sulfur oil to be burned statewide where the use
of 3 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 deciding whether or not to revise portions of their State
Implementation Plans.  However, it is most important for those states which

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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 require-
ments.  The time and resources which EPA has had to prepare the reports has
not permitted the consideration of growth, economics, and control strategy
tradeoffs.  Also, there has been only limited dispersion modeling data
available by which to address individual point source emissions.  Where the
modeling data for specific sources were found, however, they were used in the
analysis.
     The data upon which the reports' findings are based is. the most currently
available to the Federal Government.  However, EPA believes that the states
possess the best information for developing revised plans.  The states have
the most up-to-date air quality and emissions data, a better feel for growth,
and the fullest understanding for the complex problems facing them in the
attainment and maintenance of 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
                                                          .A.
which occur in.fuel switching, and other potential air pollution situations
such as sulfates.
     Although the enclosed analysis has attempted to address the attainment
of all the NAAQS, most of the review has focused on total suspended particulate
matter (TSP) and sulfur dioxide (SO^) emissions.  This is because stationary
fuel combustion sources constitute the greatest source of S02 emissions and are
a major source of TSP emissions.
     Part of each state's review was organized to provide an analysis of the
SO- 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-

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cleaning" accomplished by a SIP.  The tolerance assessments have been combined
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 also

been carried out.

     The following are the principle findings for the State of Indiana.  (Air

Quality Control Regions are displayed on Figure 1-1.)

      • The state has adopted  the Federal National Ambient Air Quality
        Standards for particulates but has adopted more stringent standards
        for S02-  Attainment of the state standards would require stricter
        emission controls than would attainment of federal NAAQS only.

      • The statewide regulations for particulates and S02 were based on
        the example region approach.  Indiana has, however, initiated
        changes to the S02 regulations which would result in the applica-
        tion of emission limits based on local considerations rather than
        "worst region" constraints.  This concept is consistent with EPA's
        Clean Fuels Policy analysis and with this ESECA review.

      • Within the framework of this limited review, there are indications
        that there is little tolerance throughout the state for increased
        particulate emissions  and hence relaxed particulate emission
        regulations.  This is  due to high TSP readings (based on the 1973
        data) and several proposed Air Quality Maintenance Area designations.
        There are a sufficient number of air quality monitoring sites to
        warrant this observation.

      • For S02- there are indications that there is substantial margin for
        increased emissions in all regions except Chicago  (#67) and
        Cincinnati  (#79).  The analysis also shows that significant clean
        fuels savings could be effected in all regions, except these two,
        through emission regulation relaxation.  For Evansville  (#77),
        Louisville  (#78), and  Indianapolis  (#80) these evaluations must be
        qualified by the consideration that Air Quality Maintenance Areas
        for SC>2 have been proposed in these regions.  For Wabash Valley
         (#84) a qualification  must be added due to the fact that there is
        only limited SC>2 air quality data available.  The  state, therefore,
        can consider permitting the use of fuels with higher sulfur content
        in several areas.

      • The Chicago AQCR (#67) has been designated as a Priority I region
        for NOX because  of high NOx readings.  Although NOX is not treated
        in depth in this review,  any change in S02 or particulate regulations
        which might be  contemplated for this region must be considered in
        light of the  impact on NOX emissions.  There is little possibility
        that NOX emissions can be increased without hampering NAAQS attain-
        ment and maintenance.

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 METROPOLITAN
 CHICAGO
 INTERSTATE
 (INDIANA-
 ILLINOIS)
 (#67)
WABASH
VALLEY
INTRASTATE
 (#84)
METROPOLITAN
INDIANAPOLIS
INTRASTATE
 (#80)
EVANSVILLE-
OWENSBORO-
HENDERSON .
INTERSTATE
(INDIANA-
KENTUCKY)
 (#77)
                           '  SOUTH BEND-
                             ELKHART-
                             BENTON HARBOR
                             INTERSTATE
                             (INDIANA-
                             MICHIGAN)
                             (#82)
  NORTHEAST
  INDIANA
  INTRASTATE
   (#81)
EAST CENTRAL
INDIANA
INTRASTATE
  (#76)
  SOUTHERN
  INDIANA
  INTRASTATE
   (#83)
METROPOLITAN
CINCINNATI
INTERSTATE
(OHIO-
KENTUCKY-
INDIANA)
(#79)
                                                              LOUISVILLE
                                                              INTERSTATE
                                                              (KENTUCKY-
                                                              INDIANA)
                                                               (#78)
            Figure 1-1.   Indiana Air Quality Control  Regions  (AQCR)

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                             10
Of the 31 power plants scheduled to be on-line in 1975,  all have
coal burning capability.  Likewise, the vase majority of
industrial sources can use coal.  Therefore, the major clean
fuels conservation impact of SO? regulations relaxation  will be
on increased utilization of high sulfur coal.

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                                     11
2.0  INDIANA. STATE IMPLEMENTATION PLAN REVIEW


     2.1  Summary

     A revision of fuel combustion source emissions regulations will depend

on many factors.  For example:

      9 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 demon-
        strating the attainment of NAAQS or more stringent state
        standards?                               J
                                                 I
      • Has the state not initiated action to modify combustion
        source emission regulations for fuel savings; i.e., under
        the Clean Fuels Policy?
                                                 i
      • Are there no proposed Air Quality Maintenance Areas?
                                                  i
      • Are there indications of a sufficient number of monitoring
        sites within a region?

      • Is there an expected 1975 attainment date for NAAQS?
                                                 i
      • Based on (1973) air quality data, are there indications
        of a tolerance for increasing emissions?

      • Are the emissions from stationary fuel combustion sources
        a relatively small portion of the regional total?

      • 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?

      • Must the regulations be relaxed in order to accomplish
        significant fuel switching?

     The following portion of this report is directed at answering these

questions.  An AQCR's potential for revising regulations increases when there

are affirmative responses to the above.

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                                     12
     The initial part of the SIP review report, Section 2 and Appendix A,  is
organized to provide the background and current situation information for  the
State Implementation Plan.  Section 3 and the remaining Appendices provide
an AQCR analysis which helps establish the overall potential for revising
regulations.  An evaluation of regional air quality indicators is presented
in Appendix B; power plants, industrial sources, and area sources are analyzed
in Appendices C, D, and E respectively.
     Based on an overall evaluation of EPA's current information, AQCR's have
been classified as good, marginal, or poor candidates for regulation revisions.
Table 2-1 summarizes the State Implementation Tlan Review.  The remaining
portions of the report support this summary with explanations.

     2.2    Air Quality Setting for the State of Indiana

     2.2.1  Indiana Air Pollution Control Areas
     The State of Indiana is divided into ten Air Quality Control Regions (AQCRs),
as shown in Fig. 1-1.  There are five intrastate and five interstate regions.
Table A-l gives the pollutant priority classifications for each of the ten
regions.
     The table also shows population and population density to be largest in the
four metropolitan areas of Chicago  (#67), Cincinnati (#79), Indianapolis  (#80),
and Louisville  (#78).  Based on present conditions and growth projections for
the state, four counties have been designated as Air Quality Maintenance Areas
(ACMAs) for particulates and for sulfur dioxide.  These are indicated in Table
A-l and Fig. A-l.

     2.2.2  Indiana Ambient Air Quality Standards
     As shown in Table A-2, Indiana has adopted all of the federal primary and
secondary National Ambient Air Quality Standards  (NAAQS) for particulates,
sulfur oxides, and nitrogen dioxide, with some exceptions.  Indiana has maintained
the original federal secondary annual and 24-hour standards for SO-.  These
standards were rescinded by the EPA in July  1973.  The state has  also adopted
a one-hour standard  in addition to  the federal three-hour secondary standard.
In the analysis to follow, however, attainment only of the federal NAAQS will be
considered.

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Table 2-1.  State Implementation Plan Review Summary for Indiana
                  State
Metropolitan
  Chicago
  AQCR #67
East Central
  Indiana
  AQCR #76
Evansville-
 Owensboro
   AQCR #77
Louisville
  AQCR #78
"INDICATORS"
• Docs the State h;ivc ;iir quality standards which arc more
stringent than NAAQS?
• Dous the State have emission limiting regulations for
control of:
1. Power plants
2. Industrial sources
3. Area sources
• Did the State use an example region approach for demon-
strating the attainment of NAAQS or more stringent State
standards?
• Has the State not initiated action to modify combustion
source emission regulations for fuel savings; i.e.,
under the Clean Fuels Policy?
• Are there no proposed Air Quality Maintenance Areas?
• Are there indications of a sufficient number of monitor-
ing sites within a region?
• Is there an expected 1975 attainment date for NAAQS?
• Based on (1973) Air Quality Data, are there no reported
violations of NAAQS?
• Based on (1973) Air Quality Data, arc there indications
of a significant tolerance for increasing emissions?
• Are the emissions from stationary fuel combustion sources
• a relatively small portion of the regional total?
• Do modeling results for specific fuel combustion sources
show a potential for a regulation revision?
• Is there a significant Clean Fuels Saving potential in
the region?
• Must the regulations be revised to accomplish signifi-
cant fuel switching?
• Based on the above indicators, what is the potential for
revising fuel combustion source emission limiting
regulations?
rsr so2

YES
YES
NO
YES
YES








YES
YES
NO
YES
NO










TSP S02




Example
Region

NO
YES
NO
NO
NO
YES
NA

NO
YES
NO
NO
MO
NO
NA
NO
YES
TSP - Poor
SO 2 - Poor
TSP S02




YES
YES
YES
NO
•NO
NO
NA




YES
YES
YES
YES
YES
NO
NA
YES
YES
TSP - Poor
SO 2 Good
TSP SO,




ND
YES
YES
NO
X)
ND
' NA




NO
YES
YES
YES
YES
NO
YES
YES
YES
TSP - Poor
SO 2 - Marginal
TSP S02




Example
Region

YES
YES
YES
NO
NO
YES
NA

N0b
YES
YES
YES
YES
NO
YES
YES
YES
TSP - Poor
S02 - Marginal

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Table 2-1.  State Implementation Plan Review Summary of Indiana  (Contd.)
Northeast South Bend- Southern
Cincinnati Indianapolis Indiana Elkhart3 Indiana
AQCR #79 AQCR #80 AQCR #81 AQCR *82 AQCR »83
"INDICA'IUKS"
• Dues tin; Stale liavr :iir quality stanilards whii'li are more
strinj'.ont th:iu NAAQSV
• Itons the State have (.'mission limit inc. regulal ions for
control of:
1. Power plants
2. Industrial sources
3. Area sources
• Did the State use an example region approach for demon-
strating the attainment of NAAQS or more stringent State
standards?
• lias the State not initiated action to modify combustion
source emission regulations for fuel savings; i.e.,
under the Clean Fuels Policy?
• Arc: there no proposed Air Quality Maintenance Areas?
• Are there indications of a sufficient number of monitor-
ing sites within a region?
• Is there an expected 1975 attainment date for NAAQS?
• Itased on (1973) Air Quality Data, arc there no reported
violations of NAAQS?
• Bused on (1973J Air Quality Data, arc there indications
of a significant tolerance for increasing emissions?
• Arc the emissions from stationary fuel combustion sources
a relatively small portion of the regional total?
• Do modeling results for specific fuel combustion sources
show a potential for a regulation revision?
• Is there a significant Clean Fuels Saving potential in
the region?
• Must the regulations be revised to accomplish signifi-
c;mt fuel switching?
• Hascd on the above indicators, what is the potential for
revising fuel combustion source emission limiting
regulations?
T.SI' S()2




NOC
YES
YES
NO
NO
YES
NA




YES
YES
YES
YES
YES
NO
NO
NO
YES
TSP - Poor
S02 - Poor
TSI' S02




Example
Region

NO
YES
YES
NO
NO
NO
NA

NO
YES
YES
YES
YES
NO
YES
YES
YES
TSP - Poor
S02 - Margina:
TSI' S()2




YES
NO
YES
YES
NO
NO
NA




YES
YES
YI.~
YIS
YES
NO
NA
YES
YES
TSP - Margina]
S02 - Good
TSI' SIX.




YES
YES
YES
NO
NO
NO
NA




YES
YES
YES
YES
YES
NO
YES
YES
YES
TSP - Poor
S02 - Good
TSI' SIX,




YES
YES
YES
NO
NO
NO
NA




YES
YES
YES
YES
YES
NO
YES
YES
YES
TSP - Poor
S02 - Good

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                                      Table 2-1.  State Implementation Plan Review Summary of Indiana (Contd.)

                                                                   Wabash
                                                                   Valley
                                                                  AQCR *84
"INniCATnilS"
• Does the State have :iir quaJity standards which arc more
stringent than NAAQS?.
• Docs the State have emission limiting regulations for
control of:
1. Power plants
2. Industrial sources
3. Area sources
• Did the State use an example region approach for demon-
strating the attainment of NAAQS or more stringent State
standards?
• lias the State not initiated action to modify combustion
source emission regulations for fuel savings; i.e.,
under the Clean Fuels Policy?
• Are there no proposed Air Quality Maintenance Areas?
• Are there indications of a sufficient number of monitor-
ing sites within a region?
• Is there an expected 1975 attainment date for NAAQS?
• Based on (1973) Air Quality Data, are there no reported
violations of NAAQS?
• Based on (1973) Air Quality Data, are there indications
of a significant tolerance for increasing emissions?
• Are the emissions from stationary fuel combustion sources
• a relatively small portion of the regional total?
• Do modeling results for specific fuel combustion sources
show a potential for a regulation revision?
• Is there a significant Clean Fuels Saving potential in
the region?
• Must the regulations be revised to accomplish signifi-
cant fuel switching?
• Bused on the above indicators, what is the potential for
revising fuel combustion source emission limiting
regulations?
•ISP so2




YES
YES
YES
NO
NO
NO
NA




YES
NO
YES
YES
YES
NO
YES
YES
YES
TSP - Poor
S02 - Marginal
Interstate   T'here is a proposed AQMA in the Kentucky portion of the region.   cThere is a proposed AQMA in the Ohio portion of the region.

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                                     16
     2.2.3  Indiana Air Quality Status
     The current air quality status in Indiana is summarized in Table A-3 for
participates and Table A-4 for sulfur dioxide.  All data came from the SAROAD
data bank as of June 1974.
     With the exception of Northeast Indiana  (#81), all AQCRs in the state
show violations of the particulate standards, although neither Northeast Indiana
nor Southern Indiana (#83) has very many reporting stations.  Severest
particulate problems are in the Chicago (#67), Cincinnati (#79), Louisville
(#78), and Evansville  (#77) regions, all of which require lar^e emission
reductions to meet the secondary NAAQS.  The  Jlta are consistent with the AOMA.
designations for particulates.  Indications are that relaxation of particulate
emission regulations will not be possible without disrupting NAAQS attainment.
     Metropolitan Chicago  (#67) is the only region showing SO- violations, but
just 4 stations out of 100 are reporting excesses.  Five of the regions (East
Central Indiana (#76), Northeast Indiana (#81), South Bend-Elkhart-Benton
Harbor (#82), Southern Indiana  (#83), and Wabash Valley (#84)1 have only a
few reporting stations.  The  indications are  that some regions of the state
can absorb increases in SO- emissions without violating the NAAQS, and this is
encouraging from a clean fuels conservation perspective.

     2.2.4  Indiana Emissions Summary
     Emission sources and emission rates are  tabulated in Tables A-5 to A-8.
     In the 10 AQCR area,  Indiana fuel combustion sources account for 33% of
the particulate and 71% of the SO- emissions.  With the exception of Metro-
politan Chicago (#67), Louisville  (#78), and  Cincinnati (#79), Indiana fuel
combustion sources contribute half or more of the particulate emissions.
Since only Northeast Indiana  (#81) is not showing particulate standard violations,
any particulate regulation relaxation would have to be accompanied by a
regulation tightening  in other  sectors  in order to achieve required emission
reductions.  Also, Table A-6  shows that power plants, industrial/commercial/
institutional point sources,  and area sources are roughly equivalent in their
contribution to the particulate emissions in  the 10 region area although one
or the other source may dominate  in  a given region.  Hence,  the lack of margin
for particulate regulation relaxation applies to all fuel combustion sources.

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                                     17
     The rollback calculations for SO- indicate that theoretically all AQCRs
in Indiana except Metropolitan Chicago (#67) might tolerate S02 regulation
relaxation, but since 71% of the regional SO- emissions are from fuel combus-
tion sources in Indiana any relaxation for these sources would have to be
done cautiously.  Furthermore, Chicago (#67), Evansville (#77), and
Indianapolis (#80) all contain counties with AQMA. designations for SO-.  Thus,
                                                                     Lt
any emission relaxation in those AQCRs has the potential for jeopardizing
NAAQS maintenance.
     Table A-7 shows that for SO- emissions, power plants predominate, so that
any change in their emission regulations would be felt strongly in regional
air quality changes.  Area sources are significant SO- sources in Chicago (#67),
East Central Indiana (#76), and Northeast Indiana (#81).

     2.3    Background on the Development of the Current State Implementation
            Plan                                  !
                                                  i
                                                  !
                                                  I
     2.3.1  General Information                   j
                                                  i
     Indianapolis (#80) was chosen as the example region for the development of
                                                  i
the Indiana State Implementation Plan.  Although particulate and SO- control
strategies were based on AQEM and rollback calculations for Indianapolis,
potential strategies were also tried on several interstate Indiana AQCRs.  Indian-
apolis was chosen as the example region because ofj high particulate and SO-
readings and because it contains the only large metropolitan area entirely with-
in the state.                                     j
                                                  |
                                                  i
                                                  i
     2.3.2  Particulate Control Strategy          |
                                                  i
     The State Implementation Plan stipulates that] particulate control strategies
                                                  (
for fuel combustion consist of implementation and (enforcement of Air Pollution
                                                  j
Control Regulations APC 2-7.  For purposes of fuel! combustion, this means enforce-
ment of the revised APC-4, whose provisions are shown in Table A-9 and Fig. A-2.
Stricter particulate emission limits apply in the thicago  (#67) and Indianapolis
(#80) AQCRs than in the rest of the state.  In the original APC-4, only Chicago
had been subject to the stricter regulation.  The present, strategies were
                                                  i
designed to meet primary standards for particulate] air quality throughout Indiana.
Secondary standards would not be met in all parts 'of the state, however.

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                                      18
     2.3.3  Sulfur Oxide Control Strategy
     Indiana S0~ emission control strategies for fuel combustion sources
consist of enforcement of the regulations outlined in Table A-9 and its
accompanying Figure A-3.  These strategies were tested both with AQDM and
with rollback calculations for the Chicago (#67), Indianapolis (#80), and
Louisville (#78) AQCRs.  Such calculations showed that primary SCL standards
could be met by 1975 throughout the state, and that only Chicago (#67) would
probably not be able to meet secondary standards without tighter control of
emissions.

     2.4    Special Considerations for the State of Indiana

     2.4.1  Planned SIP Revisions
     Relevant to fuel combustion, two new regulations have been approved by
the Air Pollution Control Board and are to be considered for acceptance within
the State Implementation Plan by EPA.  In the first regulation, county-wide
Air Quality Basins would be established; they would replace the present Air
Quality Control Regions.  The second regulation would permit higher sulfur
fuel for utilities and industrial boilers in rural areas, while not drastically
changing emission regulations elsewhere.

     2.4.2  Fuels
     Indiana is a heavy user of coal.  For power plants, 94% of the heat input
is derived from coal, only 1% from oil, and 5% from natural gas.  Indiana is
also a large supplier of coal ranking sixth in total coal production.  Most of
the reserves are located in the southwest portion of the state, but  Indiana
lies between two very large coal reserves in Illinois and Western Kentucky-Ohio.
Most of Indiana's coal is of moderate  (1-2%) to high  (>2%) sulfur content as
is the coal in adjacent state reserves.  Therefore, the major  impact  of
regulation relaxation in Indiana would be increased use of high sulfur coal.

     2.4.3  Fuel Conversions
     The Federal Energy Administration has not identified any  potential oil-to-
coal conversion plants in Indiana.

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                                     19
3.  AIR QUALITY CONTROL REGION ASSESSMENTS

    3.1  General Methodology
    The previous section having set the background for the State Implementation
Plan and evaluated the current air quality situation, this section will review
the available information for each AQCR to determine the feasibility of relax-
ing emission regulations in the interest of conserving clean fuels.  Care must
be taken in interpreting the results of this analysis and the following caveats
must be kept in mind:  (1) The analytical procedure is intended to provide a
first approximation to the evaluation of potential regulation changes (e.g.
rollback and single source modeling techniques were used).  The state must
conduct a more detailed analysis of the situation to confirm or dispute any of
these findings prior to submitting any SIP revisions.  (2) In many instances
the necessary data were unavailable or limited in scope.  Where possible, best
engineering estimates were used to fill in the gaps.  Where better information
is available, the state should use it in developing SIP revisions.
                                                  !
    The analysis encompasses five distinct considerations for each AQCR.  First,
the current air quality situation is assessed to determine if the indicators
point to the region's ability to tolerate an emission increase without violation
of any NAAQS.  Most of the data necessary for this review have already been
presented in Section 2 and Tables B-l and B-2 summarize the information for
particulates and SO- respectively in each AQCR.  The assessment is made on the
basis of 7 criteria:  (1) current air quality violations, (2) expected NAAQS
attainment dates, (3) Air Quality Maintenance Area designations,  (4) total
                                                  I
emissions, (5) portion of emissions from the staters fuel combustion sources,
(6) regional emission reduction required (based on rollback calculations), and
(7) pollutant priority classification.  Note that jthis evaluation is based
strictly on air quality considerations.  Determinations of whether regulation
relaxation would, in fact, result in clean fuels savings will be made on a
source-by-source evaluation.                      |
                                                  i
    The second consideration for each AQCR is the jpower plant assessment and
this data is summarized on the tables in Appendix jC.  All existing and pro-
posed plants are reviewed to estimate the emission reductions to be achieved
by the imposition of existing regulations.  The clean fuel requirement is
determined at the same time.  Where dispersion modeling data are available,

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                                     20
the maximum allowable fuel sulfur content which would enable the plant to
meet the NAAQS in its immediate vicinity is determined and the resulting
emission reduction (or increase) is calculated and compared to that produced
by existing regulations and to what the region requires.  For the purposes
of this report, the SCL modeling data used1 assumes the power plant fuel use
pattern in 1975 will be the same as that existing in 1971 with the addition
of fuel comsumption for new units coining on-line.  The choice of 1971 as the
baseline year is based on the consideration that fuel switching to achieve
SIP emission regulations did not begin nationwide until 1972; therefore 1971
represents consumption patterns which are not dictated by emission regulations
but rather by the economics of fuel availability.  In terms of the maximum
allowable fuel sulfur content deteuiiined from the modeling, the 1971 fuel
sulfur content is used as an upper bound.  For particulate emissions, plants
currently below required SIP emission levels are assumed to remain so.  No
particulate modeling results were available.  Fuel use data2,3 and emission
data4,5 are drawn from both published and unpublished sources.
    The third consideration for each AQCR is the assessment of large indus-
trial/commercial/institutional point sources and the summary data is presented
in Appendix D.  The procedure is effectively equivalent to that carried out
for power plants in that resulting emission reductions achieved through the
application of existing regulations are determined along with clean fuel
requirements.  Emission and fuel use data were drawn from the National Emis-
sion Data System (NEDS) file.5  No individual source modeling data were
available.
    The fourth consideration is area source assessments.  The fuel use
patterns, emission reductions, and clean fuel requirements determined by
existing regulations is computed for these sources using NEDS data.5 The
results are summarized in Appendix E.
    The fifth consideration is a synthesis of the first four in that the
emission reductions that are imposed on all sources in the region are totaled
and compared to required reductions.  Fuel use requirements are also aggregated
for the region.  Summary tables are in Appendix F.
    At this point, an overall assessment of the potential for regulation
revision and resulting clean fuel savings can be made.  The findings for each
AQCR have been summarized on Table 2-1 and in Section 1.  An AQCR is determined

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                                     21
to be a good candidate for emission limit regulation revision if the air
quality indicators show that the region has a tolerance to absorb increased
emissions and if the source-by-source evaluations show that significant
clean fuels savings could be effected by such revision.  If the air quality
situation is such that no emission increase could be tolerated and/or if
the source evaluations show little or no clean fuels savings potential, then
the region is classified as a poor candidate for regulation revision.  If
the air quality or the clean fuels savings evaluations are inconclusive or
show conflicting information, then the region is assessed as a marginal
candidate for regulation revision.  A much more detailed analysis must be
carried out by the state to resolve the situation.

    3.2    Metropolitan Chicago Interstate AQCR  (#67)

    3.2.1  Regional Air Quality Assessment
    There are widespread high particulate levels in this AQCR.  Although
Indiana combustion sources are contributing a small portion of the region's
particulate load (181 from Table B-l), this still amounts to a substantial
emission rate (117,000 tons per year from Table A-6).  The regional air
quality, therefore, has virtually no capacity to absorb increased particulate
emissions.
    High SO- levels are also found in this AQCR  (see Table B-2).  Indiana
fuel combustion sources are contributing just less than half of the region's
SO- emissions, and hence any regulation change would substantially affect
regional S02 levels.
    Although not treated in depth in this report, this region, which includes
the City of Chicago, is one of five in the country that is rated as Priority I
for nitrogen oxides.  Emissions are about equally divided between stationary
and mobile sources; hence, any regulation change which impacts on NO  emission
                                                                    X
rates must be considered carefully.

    3.2.2  Power Plant Assessments
    The three Indiana power plants in this region burn coal and gas.  Existing
regulations applied in 1975 would require all coal to be less than 1% S
resulting in an emissions reduction of 169,000 tons per year compared to 1972

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                                      22
values (see Table C-2).  Since rollback calculations indicate that a substan-
tial emissions reduction is necessary (see Table A-8) and since 45% of the SO-
emissions in the Indiana portion of the AQCR (or 24% of the total AQCR emissions)
come from Indiana power plants (see Table A-7), there appears to be little
chance for regulation relaxation.  However, modeling results are not available
and hence no quantitative plant-by-plant assessments were possible.  Such an
analysis might indicate the possibility of local relaxations.
    Existing particulate regulations require no decrease in particulate
emissions at these three plants  (see Table C-2).  Indiana power plants contribute
only 3%  (see Table A-6) of the Indiana portion °- the emissions in the AQCR
(or 1% of the total for the entire AQCR).  However, rollback shows that a 92%
reduction in particulate emissions may be required  (see Table A-8).  Despite
the small overall contribution of the power plants, the large overall reduction
required seems to allow no relaxation of particulate emission regulations in
this sector.

    3.2.3  Industrial/Commercial/Institutional Point Source Assessment
    Eight industrial/commercial/institutional point sources are significant in
this region by virtue of their contribution to the  top 90% of the SO- and
particulate emissions levels  (Table A-5).
    Percentages of sulfur in  the oils burned by industrial, commercial, and
institutional point sources were not available.  It was assumed that all oil
burned had 0.2% S, which is the  state-wide average value for oil fired by
utility power plants.  Actual emission figures show that Indiana point sources
contributed 171 of the total  S02 emissions in the AQCR (Table A-7) .  A reduc-
tion of  530,000 tons per year in emissions is indicated by rollback calculations.
Even considering the reduction of  169,000 tons per year required from power
plants by present regulations, there remains a need for a further reduction of
361,000  tons per year  in SO-  emissions.  Under the  above assumption, present
regulations would permit an increase in emissions from this sector of 134,000
tons per year  (Table D-2), since most of the oil used could have higher than
.2% sulfur.  Given the required  large reduction in  emissions, the  indications
are that there is little margin  for relaxation in the SO- regulations for these
sources.

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                                      23
     The same conclusions can be drawn about the particulate regulations.
Indiana industrial sources contribute 95,000 tons per year to the regional
particulate emission load (Table A-6).  The required emission reduction of
610,000 tons per year leaves little room for relaxing particulate regulations
for these sources.
     3.2.4  Area Source Assessment
     As shown on Tables A-6 and A-7, Indiana area sources are contributing
15,000 and 20,000 tons per year to the regional particulate and SO- emission
rates respectively.  Indiana regulations are not applied to these small
individual sources.  Table E-l gives a fuel use summary.
     3.2.5  Fuels Assessment
     There is no modeling data available to determine the extent of potential
clean fuels savings in this region on a plant-by-plant basis.  Based on the
regional analysis, there appears little tolerance for increased SO- emissions
and hence little margin for a shift to higher sulfur content fuels.  Similarly,
the indications are that the increased particulate emissions resulting from a
shift from oil to coal could not be tolerated in the region.
     3.2.6  Overall Assessment
     This region is a poor candidate for both S02 and particulate regulation
relaxation as shown on Table 2-1.  The regional air quality assessment shows
no tolerance for emission increases and the source-specific assessments show
no potential for clean fuels savings.  In addition, there are both S09 and
                                                                     £i
particulate AQMAs in the region indicating expected difficulties in attaining
or maintaining acceptable air quality and thus supporting the poor candidacy
assessment.
     3.3    East Central Indiana Intrastate AQCR (#76)
     3.3.1  Regional Air Quality Assessment
     High particulate levels are being recorded at only one site in this region
and hence may be a highly localized problem.  More analysis is needed to
determine whether the problem is general or local.
     Low SO- levels are found in this region.  There are also a low S02 emissions
and rollback indicates that the region could absorb a significant emission
increase (see Table A-8).

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                                      24
    3.3.2  Power Plant Assessment
    There  is only one small power plant in this AQCR.  Existing regulations
require the use of moderate (1-2%) sulfur coal for an S0~ emissions reduction
of 4,400 tons per year in 1975  (see Table C-2).  Even though 22% of the S02
emissions  in the AQCR come from this plant (see Table A-7), the large
permissable increase makes regulation relaxation appear feasible.  (This
statement  is made subject to the limitations of available air quality and
emissions  data.)  No local modeling results were available and thus no
estimates  of maximum allowable  % S coal could be made.
    On the other hand, little chance to relax  uie particulate regulations is
indicated.  Rollback shows that a reduction in emissions of 10,000 tons per
year  (see  Table A-8) is necessary.  The present regulations require a
reduction  of 420 tons per year  from the power plant  (see Table C-2) which
contributes 4% of the total emissions in the AQCR  (see Table A-6).  Thus the
plant is just meeting its proportionate share of the required emissions
reduction  indicating little chance of relaxing particulate regulations.

    3.3.3  Industrial/Commercial/Institutional Point Source Assessment
    Eight  sources are significant in this region (see Table A-5).
    All the sources are coal-fired and they contribute 28% of the total SCL
loading for the region.  A reduction in emissions  of 2,000 tons per year is
required under present regulations while a substantial increase might be
tolerable  according to the rollback calculations.  Thus, the possibility of
SO- emissions regulations relaxation exists.  However, even the present
regulations allow the burning of moderate  (1-2%) and high  (greater than 2%)
sulfur coals in this AQCR and the practical results  of regulation relaxation
in terms of the utilization of  higher sulfur fuels would be minimal.
    There  appears to be little  chance for particulate regulation relaxation,
since the  region requires a 25% reduction  in emissions  (Table A-8), and these
sources are contributing  12% to the regional emission load (Table A-6).

    3.3.4  Area Source Assessment
    Area fuel combustion  sources are contributing  33% of the particulate
emissions  and 45% of  the  SO- emissions  in  the  region (Tables A-6 and A-7).
These small sources are not controlled by  Indiana  regulations and hence are
not candidates for  regulation relaxation.

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                                     25
    3.3.5  Fuels Assessment
    There are no modeling results to determine maximum allowable fuel sulfur
contents for power plants and industrial/commercial/institutional sources.
The previous analyses show that existing regulations are already permitting
the use of high and moderate sulfur coals.  As shown on Table F-l, only
208,000 tons of moderate sulfur coal is required while the remainder can be
high sulfur.  Therefore, any SCL regulation revision would have a nominal
impact on clean fuels saving.

    3.3.6  Overall Assessment
    Given the existing particulate air quality, the indications are that the
region is a poor candidate for relaxation of particulate emission regulations
(see Table 2-1).
    The indications based on air quality are that SCL emissions regulations
could be relaxed.  Although only nominal clean fuels saving potential exists
in this region, it is a good candidate for regulation relaxation.

    3.4    Evansville-Owensboro-Henderson Interstate AQCR (#77)

    3.4.1  Regional Air Quality Assessment
    This region is experiencing widespread high particulate levels.  There is
also a proposed particulate AQVIA in this region and 68% of the particulate
emissions come from Indiana fuel combustion sources.  Thus, any regulation
relaxation would have a significant impact on regional air quality.
    Even though there are presently no known SCL problems, the high emission
rate and the high percentage of SCL emissions  (74%) from Indiana fuel
combustion sources indicate that any regulation changes would have a large
effect on air quality.

    3.4.2  Power Plant Assessment
    There are four large power plants and one small plant in the Indiana
portion of this AQCR all of which are predominantly coal-fired.  One large
plant (Ohio River) is an oil-and gas-fired plant.  In addition, the large
(650 Mw capacity) coal-burning Gibson plant will begin operating in 1975.
Present regulations require that all coal and oil be less than 1% sulfur

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                                     26
except at the small Jasper plant where coal with more than 2% sulfur could be
burned.  The application of the present regulations would result in a 217,000
tons per year decrease in emissions.  Rollback indicates that SO- emissions
in the region could increase by 432,000 tons per year.  Modeling indicates
that emissions could increase by 125,000 tons per year by the use of coals
of 1-2% S and greater than 2% S at various plants (see Table C-l) .  (However,
the large Warrick plant was not included in the modeling analysis.)  Thus,
indications are that an increase in SCL emissions could be allowed and
emissions regulations relaxed.
    An additional consideration that must be ta^n into account is that since
power plants in Kentucky emit 24% of the SCL in this region (as compared to
42% for the Indiana plants) , the effects of possible relaxations in Kentucky
must also be evaluated.
    Of the 81,000 tons per year of particulate emissions reduction required
by rollback, only 5,000 tons per year will be obtained in 1975 from power
plants under existing regulations, and these plants emit 36% of the particulates
in the region.  Thus, a reduction of about 76,000 tons per year must come from
other sources and there appears little chance for relaxation of particulate
emissions regulations for power plants.

    3.4.3  Industrial/Commercial/ Institutional Point Source Assessment
    The two industrial sources here are coal -fired.  (The ALCOA- Warrick power
plant has been treated as a utility power plant.)  These plants are significant
sources, contributing 31% of the total SO™ emissions in the AQCR.  Present
regulations require a small emissions reduction from this sector.  Although
rollback indicates that 432,000 tons per year of increased emissions are
allowable  (Table A- 8) and thus makes the present regulations appear too
restrictive there, the same considerations as were evidenced for the power
plants apply here.
    These sources are contributing 171,000 tons per year to be regional SO-
emission rate  (31% of the total, Table A- 7) and any relaxation of regulations
would have a significant impact on air quality.  Additional study will be
required to determine the feasibility of  regulation changes for these sources.
    No particulate regulation  change is tolerable  in this region.

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                                     27
    3.4.4  Area Source Assessment
    Indiana area sources are making only small contributions to the emission
load in this region.

    3.4.5  Fuels Assessment
    As shown on Table F-l, the region has a significant potential for clean
fuels savings through regulation modification based on the modeling results.
Almost 8 million tons of low sulfur coal could be saved by relaxing the SO-
emission standards.  Because of this high clean fuels savings potential, it
is imperative that a more thorough analysis be carried out to determine if,
in fact, the fuel sulfur content increases indicated by the rollback and
power plant modeling can be tolerated.
    Shifts toward increased coal use in place of oil by power plants (Table C-l)
would have to be dealt with cautiously because of the lack of tolerance for
increased participate emissions.

    3.4.6  Overall Assessment
    This region is a marginal candidate for SO- emission relaxation.  Despite
the apparently good SO- air quality, the large potential impact of regulation
relaxation and the existence of a proposed AQMA indicate possible air quality
maintenance problems.  However, the large potential clean fuels savings
indicates the desirability of a more detailed analysis of probable growth
conditions to determine if, in fact, regulation relaxation could be possible.
An alternative to region-wide regulation relaxation might be a selective
granting of variances on a plant-by-plant basis after additional study.
    With the particulate air quality problems and a proposed AO>1A, the region
is a poor candidate for particulate emission regulation relaxation.

    3.5    Louisville Interstate AQCR (#78)

    3.5.1  Regional Air Quality Assessment
    This region has widespread high particulate levels which indicate that even
though only 12% of the particulate emissions originate at Indiana fuel
combustion sources, increased particulate emissions could not be tolerated.

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                                     28
    Reported SO- air quality is good and a substantial capacity for absorbing
increased SO- emissions is indicated.

    3.5.2  Power Plant Assessment
    There is only one power plant  (Gallagher) in the Indiana portion of this
AQCR.  The plant burns mostly coal with a small amount of oil.  Present
regulations would require both fuels to contain less than II S.  Compliance
with these regulations would result in a reduction of 9,000 tons per year in
SO- emissions.  Results of rollback calculations indicate that an increase in
emissions  (Table A-8) is possible.  Modeling ^f- the plant showed no local
problems even if 3.31 S coal were burned which fuel would result in almost no
change over 1972 emissions.  However, the Gallagher plant emits 651 of the
SO- generated in the AQCR.  Since the air quality impact of such a large
source is great and since there is an ACMA in the Kentucky portion of the
region, the apparent potential for emissions regulation relaxation indicated
by modeling and rollback must be examined more closely with particular
emphasis on the possible effects in Kentucky.  There is, nevertheless, a
definite possibility that such a relaxation could be effected.
    The Gallagher plant is in compliance with the present particulate emissions
regulations.  Indications from rollback are that an AQCR-wide reduction of
207,000 tons per year in particulate emissions is necessary.  Even though
Gallagher accounts for less than 1% of the total particulate emissions, there
appears to be little chance of particulate regulation relaxation.

    3.5.3  Industrial/Commercial/Institutional Point Source Assessment
    The only source in the Indiana portion of this AQCR is the Olin Ammo Plant
which burns both coal and oil.  The amount of oil firing is not large enough
to make the assumption as to the % sulfur in the oil critical and the plant
contributes only about 8% of the AQCR-wide SO- emissions.  Present regulations
require an emissions reduction of  6,700 tons per year from this plant but still
allow between 1 and 2% S coal  to be used.  Rollback  indicates that some 52,000
tons per year more S02 could be  absorbed than is presently being emitted.
Given the  small overall  impact of  this source, it appears that regulations
might be relaxed.  However,  the  same  precautions must be taken as for the
Gallagher  power plant.
    No particulate regulation  relaxation  is possible.

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                                     29
    3.5.4  Area Source Assessment
    Tables A-6 and A-7 show that area sources are contributing small amounts
to the regional SCL and particulate emission rates.  A fuel use summary is
in Table E-l.

    3.5.5  Fuels Assessment
    Table F-l shows that almost 1.7 million tons of low sulfur coal could be
conserved through SCL regulation modification based on modeling results.

    3.5.6  Overall Assessment
    The proposed AQMA. in Kentucky makes this region a marginal candiate for
SCL emissions regulation relaxation.  The large potential for clean fuels
savings makes it imperative that the NAAQS maintenance issue be resolved to
determine if regulation relaxation could be implemented.
    The region is a poor candidate for particulate emission regulation
relaxation because of the poor particulate air quality.

    3.6    Metropolitan Cincinnati Interstate AQCR (#79)

    3.6.1  Regional Air Quality Assessment
    There are widespread high particulate levels in this region and no indicat-
ed tolerance for an increase in regional emissions rates.
    The current SO- emissions rate in this region is very high (479,000
tons/year, Table B-2), and a substantial portion (38%) of the emissions come
from Indiana fuel combustion sources.  There are, however, no indications of
high ambient SCL levels.  Regional air quality must be carefully assessed
before widespread regulation relaxation can take place.

    3.6.2  Power Plant Assessment
    There is only one large predominantly coal-fired power plant (Tanners Creek)
in the Indiana portion of this AQCR.  Present regulations call for burning coal
with less than 1% S at the plant by 1975 with a concomitant decrease in SCL
emissions of 150,000 tons per year.  Rollback indicates a capacity to absorb

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                                     30
an increase of 216,000 tons per year.  Modeling results show that virtually
no increase in fuel sulfur content is allowable (Table C-l).  The required
emission reduction appears overly restrictive in terms of the rollback
calculations, but it must be considered in light of the constraint of the
local situation as determined by modeling which indicates little chance of
using higher sulfur fuels.  There appears, therefore, to be no margin for SO-
regulation relaxation for this plant.
    For particulates the conclusion is similar.  Present regulations would
result in a 30,000 tons per year decrease in particulate emissions while
rollback shows a need for a reduction of 207.^00 tons per year.  Since the plant
emits 18% of the particulate matter in the AQCR, there is a large residual
reduction that must come from other sources.  No relaxation of the regulations
appears possible.

    3.6.3  Industrial/Commercial/Institutional Point Source Assessment
    The Jos. E. Seagram plant is the only significant Indiana industrial source
in this AQCR and it uses coal.  Present regulations would require this source
which emits only 1% of the SO- in the AQCR to burn 1.7% sulfur coal and reduce
emissions by 2,700 tons per year by 1975.  A capacity for a large increase
in SO- emissions is indicated by rollback (Table A-8).  Given the small
contribution of this plant, it appears that the chances are good for emissions
regulation relaxation although clean fuel savings would be small.
    There is no margin for particulate regulation relaxation for this source.

    3.6.4  Area Source Assessment
    Indiana area sources contribute only 1,000 tons each of particulates and
S02 and hence  are not now major considerations in regional air quality problems.

    3.6.5  Fuels Assessment
    Based on the modeling results and regional assessment, there is little
potential for  clean fuels savings in this region.

    3.6.6  Overall Assessment
    Although indications from air quality are  favorable, local modeling results
show little potential for power plant regulation relaxation.  Also, there is

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                                     31
no significant potential for clean fuels savings.   Thus,  this region is a poor
candidate for SO- regulation relaxation.
    Based on air quality, the indications are that this region is a poor
candidate for participate emission regulation relaxation.  This conclusion
is strengthened by the proposed TSP AOMA. in the Ohio portion of the region.

    3.7    Metropolitan Indianapolis Intrastate AQCR (#80)

    3.7.1  Regional Air Quality Assessment
    Particulate problems exist at several locations in the region.  Fuel
combustion accounts for 79% of the particulate emission load and hence
regulation relocation would significantly impact upon regional air quality.
    There are no reported SO- problems but fully 95% of the emissions come
from fuel combustion sources indicating that changes in regulations must be
considered carefully.

    3.7.2  Power Plant Assessment
    Three of the four power plants in this AQCR are coal-and oil-fired and
one is coal-fired only.  Rollback calculations indicate that an additional
123,000 tons per year of emissions could be absorbed.  Modeling results also
show that 40,000 tons per year of increased emissions are allowable locally
and that coal with greater than 2% S could be burned at all plants except
E. W. Stout.  The existing regulations require all coal to be less than 1% S
and would produce a decrease in SO- emissions of 28,000 tons per year.  Thus,
the rollback and modeling results both indicate that the SO- emissions
regulations could be relaxed.  Since fully 61% of the SO- emissions in this
AQCR come from power plants, any change in SO- emissions regulations will
have a significant impact on ambient air quality.  Since there is a proposed
SO- ACMA in the region indicating a potential maintenance problem, regulation
relaxation cannot be recommended until the possible effects of such relaxation
on the AQMA have been analyzed.
    For particulates, rollback indicates that an emission reduction of 37,000
tons per year is necessary.  Present regulations should result in a reduction
of 26,000 tons per year from power plants which account for 38% of the
particulate emissions.  Since even this anticipated emissions reduction from

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                                     32
the power plants under, exist ing regulations does not give the required
reduction, there does not appear to be a good chance of allowing regulation
relaxation.

    3.7.3  Industrial/Commercial/Institutional Point Source Assessment
    Several Indiana sources in this AQCR burn significant amounts of oil.   It
was assumed that all oil was 0.3% S which is the average value for all utility
power plants in the Indiana portion of the AQCR.  Under this assumption,
present regulations would allow an increase of 1,700 tons per year in SO-
emissions.  Rollback indicates a sufficient ca-^city to absorb this increase,
showing that 123,000 tons per year more SO- could be tolerated than is
presently being emitted.  Nevertheless, the same maintenance constraints
which prohibit a recommendation to relax SO- emission limits for power plants
apply here also.
    Particulate regulation relaxation is not possible, since the region cannot
tolerate increased emissions.

    3.7.4  Area Source Assessment
    Area sources are contributing significant quantities to the particulate
and SCL emission rates in the region  (20,000 and 31,000 tons per year
respectively, Tables A-6 and A-7).  Indiana regulations are not applied to
these small sources.  Table E-l gives a fuel use summary.

    3.7.5  Fuels Assessment
    Table  F-l  shows  that almost 3 million  tons of low sulfur coal could be
conserved  by modifying the SO-  regulations based on the modeling results.  It
is  therefore imperative that the maintenance  issue be resolved to determine
if, in fact, the margin for SO- emission increase displayed by the rollback
and power  plant modeling can be utilized for  clean fuel conservation.

    3.7.6   Overall Assessment
    Despite the indications of  acceptable  SO- air quality and the potential
for significant clean fuels saving,  the possibility of maintenance problems
as  discussed above make this region  a marginal candidate for SO- emission
regulation relaxation.

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                                     33
    Indications of particulate air quality problems make this region a poor
candidate for particulate emission regulation relaxation.  This conclusion
is supported by the potential air quality problems indicated by a proposed
TSP AQMA in the region.

    3.8    Northeast Indiana Intrastate AQCR (#81)

    3.8.1  Regional Air Quality Assessment
    This region has the lowest particulate emissions rate in the state.
However, the number of stations in the region may be insufficient to assess
air quality and no annual data is available.  The two stations reporting show
no short-term particulate problems.  The indications are that there is a
tolerance for increased particulate emissions.
    There are currently no SO- air quality problems, but since 93% of the
region's SCL emissions come from stationary source fuel combustion, any
relaxation of fuel combustion regulations would have a substantial impact on
regional air quality.

    3.8.2  Power Plant Assessment
    This AQCR contains only one relatively small coal-fired power plant which
contributes 5V of the total SCL emissions in the region.  Present regulations
require 1-2% S coal and a reduction in emissions of about 780 tons per year.
Rollback results indicate that substantial emission increases could be
tolerated.  Thus, the indications are that the regulations could be relaxed
in favor of higher sulfur coal use even though no modeling results are
available.
    Present particulate regulations require a decrease in the power plant
emissions by 2,000 tons per year while rollback indicates that a small emission
increase could be tolerated.  The regulations appear to be overly restrictive
in this situation and might be relaxed in the interest of allowing the plant
to continue to burn coal instead of lower particulate producing oil or gas.

    3.8.3  Industrial/Commercial/Institutional Point Source Assessment
    All three of the sources in this region burn coal.  Present regulations
already permit coal with more than 2% S to be burned at some installations and

-------
require no coal less than 1% S.  Even with these moderate restrictions,
emissions would decrease by 2,800 tons per year by 1975.  Since rollback
indicates that an emissions increase of 416,000 tons per year is tolerable,
the regulations might be relaxed in favor of wider use of high sulfur coal.
That the three sources in the region account for fully 33% of the SCL
emissions indicates that any proposed relaxation must adequately consider
the potential of creating a local SCL problem.  No modeling results were
available to make this determination.
    As with the power plant, it appears that particulate regulations could
also be relaxed in this region to encourage thcco facilities to continue
coal use.

    3.8.4  Area Source Assessment
    Area sources are significant contributors to the particulate and SCL
emissions in this region  (see Tables A-6 and A-7).  Indiana regulations are
not applied to these small sources.  Table E-l gives a fuel use summary.

    3.8.5  Fuels Analysis
    Although the region is a good candidate for regulation relaxation based
on air quality considerations, the potential clean fuels savings is minimal
as shown on Table F-l  (only 116,000 tons of moderate sulfur coal).  The chief
advantage of a relaxation would be to prevent an increase in the demand for
clean fuels over existing levels.

    3.8.6  Overall Assessment
    There are indications that this region is a good candidate for SCL
emission regulation relaxation, but any relaxation has a potentially large
effect on air quality  and must be considered carefully.
    Since the TSP air  quality data is not complete but still indicates
little tolerance for increased emissions, this region is a marginal candidate
for particulate emission regulation relaxation.

-------
                                     35
    3.9    South Bend-Elkhart-Benton Harbor Interstate AQCR (#82)

    3.9.1  Regional Air Quality Assessment
    There are indications of poor particulate air quality in this region.
Although overall particulate emissions are low, a predominant share (78%)
comes from Indiana fuel combustion sources and hence they have a significant
impact on air quality.  S0? air quality appears good with a substantial
tolerance to absorb increased emissions.  This capacity is important, since
90% of the region's emissions come from Indiana fuel combustion sources.

    3.9.2  Power Plant Assessment
    There are two power plants in the Indiana portion of this AQCR and both
use coal as their major fuel.  Present regulations would require a reduction
of almost 15,000 tons per year in SCL emissions by 1975, and the burning of
coal with less than 1% sulfur.  However, rollback based on existing air
quality data indicates that an increase of 36,000 tons per year over present
emissions could be tolerated.  Local modeling results also show that emissions
could increase by about 36,000 tons per year and that some coal with more
than 2% S could be burned.  Present regulations may thus be overly restrictive
and this AQCR is a good candidate for S02 emission regulation relaxation for
power plants.
    Indications are that the region is a poor candidate for particulate
emission regulation relaxation.  Present regulations could result in a
decrease of 33,000 tons per year in particulate matter emissions.  Rollback
calculations show the need for a reduction of 37,000 tons per year leaving
a deficit of 4,000 tons per year to come from reductions at sources other
than power plants.  The power plants are a significant source of particulate
matter accounting for 62% of the Indiana emissions and 54% of the AQCR total.
Thus, there are no indications that the particulate emissions regulations can
be relaxed.

    3.9.3  Industrial/Commercial/Institutional Point Source Assessment
    For this AQCR, it was assumed that the oil burned was of 0.1% sulfur.  If
this assumption is far from the actual situation, the conclusions presented
here are still substantially correct  because the % S in the oil has only a

-------
                                      36
small effect on the overall figures.  Present regulations require a reduction
of 460 tons per year in SCL emissions but still allow coal with more than 2% S
to be burned.  Rollback shows that emissions increases up to 36,000 tons per
year are permissable.  Since Indiana sources in this sector contribute only
about 10% of the total SCL emissions in the AQCR, the SCL emissions regulations
might be relaxed to permit higher fuel sulfur contents.
    The participate regulations  from these sources cannot be relaxed, since the
region cannot tolerate any emission increases.

    3.9.4  Area Source Assessment
    Indiana area sources are contributing significant quantities to the regional
particulate and SCL emission loads.  Indiana regulations are not applied to
these sources.  No change appears necessary for the SCL regulations.  Table E-l
gives a fuel use summary.

    3.9.5  Fuels Assessment
    Table F-l shows that 2.4 million tons of low sulfur coal could be conserved
through SCL regulation relaxation.  Most of this would be shifted only to a
moderate sulfur content, but the savings are still substantial.  It was not
possible to determine how much of the oil and gas used could be replaced by
coal, but it appears that significant savings could be achieved both from the
air quality standpoint and from  technological considerations (all of the facilities
burning oil and gas have coal-burning capability also).  The resulting increase
in particulate emissions from such  conversions, however, might have to be
countered by tighter particulate emission limits.  Overall, the region has good
clean fuels savings potential.

    3.9.6  Overall Assessment
    Indications are that this region is a good candidate for SCL emission
                                                               £i
regulation relaxation even though the air quality impact of any such relaxation
could be substantial.  Only the  1A  SCL priority classification gives cause for
concern; there may be local, single-source problems that need further study
before any general relaxation can be justified.

-------
                                     37
    This region is a poor candidate for particulate regulation relaxation
both because of poor particulate air quality and because of the potential
impact of regulation relaxation on air quality.

    3.10    Southern Indiana Intrastate AQCR (#85)

    3.10.1  Regional Air Quality Assessment
    One station in this AQCR is reporting high TSP levels.  Since there are
no proposed AQMAs and since total emissions are low, this may indicate a
highly localized problem.  The need for more study is indicated.
    Although the emission rate is moderately high, the SCL air quality
appears good and rollback indicates a substantial capacity to absorb increased
SO- emissions.

    3.10.2  Power Plant Assessment
    There is one large coal-fired power plant, Clifty Creek, in this AQCR.
Compliance coal under present regulations must contain less than 1% S and
firing such coal would cause an emissions reduction of 226,000 tons per year.
Rollback estimates indicate that an additional 983,000 tons per year of SO-
might be safely emitted in this AQCR.  Local modeling results show that coal
of more than 2% S could be utilized and still result in a 3,900 tons per year
emissions reduction.  These results indicate that there is a good possibility
for SO- emissions regulation relaxation.  However, the power plant accounts
for fully 89% of the total SO- emissions in this AQCR and hence any
regulation relaxation must be carefully scrutinized especially as to possible
local short-term standards violations.
    The Clifty Creek plant is presently in compliance with SIP particulate
regulations.  However, rollback calculations still show that reduction of
12,000 tons per year in particulate matter emissions must take place in order
to meet the NAAQS.  Since the power plant contributes 251 of the total
emissions, there seems little chance of relaxing particulate emission
regulations.

-------
                                      38
    3.10.3  Industrial/Commercial/Institutional Point Source Assessment
    Only coal is burned by the three sources in this AQCR.  Moderate and high
sulfur coals can be burned under present regulations which require an emissions
reduction of 4,500 tons per year.  Rollback calculations yield a capacity for
a large increase in SO- emissions  (see Table A-8).  Given this required
emissions decrease with such a large emission increase tolerance and given
that these sources contribute only 41 of the SCL in the AQCR, it may be
possible to relax the regulations.
    The particulate regulations have no margin for relaxation.  There is a TSP
problem and rollback indicates no  tolerance for a particulate emission increase.

    3.10.4  Area Source Assessment
    Area fuel combustion sources are contributing more to the regional SO-
and particulate emission load than are the industrial sources (see Tables A-6
and A- 7).  There is probably no need for additional SO- control from these
sources, since rollback indicates  that the region can absorb increased SO-
emissions.  Table E-l gives a fuel use summary.

    3.10.5  Fuels Assessment
    Table F-l shows that almost 4  million tons of low sulfur coal could be
saved through regulation relaxation.  This would come primarily from allowing
the Clifty Creek plant to increase its coal sulfur content.  Since all the
facilities are now using coal, there would be little impact on particulate
emission rates.

    3.10.6  Overall Assessment
    This region is classified Priority 1A for both SO- and TSP indicating
local single-source problems.  In  addition, the poor particulate air quality
and large potential impact of relaxed regulations make this region a poor
candidate for particulate emission regulation relaxation.
    Even though relaxed regulations are likely to have a  significant impact
on air quality, the region has a significant tolerance for increased SO-
emissions and is a good candidate  for regulation relaxation if the local
single-source problem indicated by the IA priority is carefully analyzed.

-------
    3.11    Wabash Valley Intrastate AQCR (#84)

    3.11.1  Regional Air Quality Assessment
    Indications are that particulate air quality might be poor although only
one station is reporting violations.  The effects of any proposed revision
would be widespread, since 781 of particulate emissions come from fuel
combustion sources and thus need to be carefully considered.
     Although there are only few S02 monitoring sites in the region, there
are no indications of high SO- levels.  However, fuel combustion sources are
generating 99% of all SCL emissions and hence have a significant impact on
air quality.

    3.11.2  Power Plant Assessment
    There are three large (above 100 Mw capacity) and six small, predominantly
coal-fired power plants in this AQCR.  In addition, the large coal-fired
Schahfer plant is scheduled to come on-line in 1975.  Assuming that the
Schahfer plant just meets the present requirements, these regulations would
require an emissions reduction of 147,000 tons per year by 1975 and the
firing of coal and oil with less than 1% S except for a small quantity of 1-2% S
coal that could be fired at several of the smaller plants.  Rollback indicates
that SO- emissions could be increased by a large amount.  Modeling
results for the large plants show that some coals above 2% S could be utilized
with almost no change in SCL emissions and no local air quality problems.
However, the modeling studies were not done for the new Schahfer plant or for
the smaller plants.  The power plants have a large impact, since they account
for 81% of the total SO- emissions in the AQCR.  Thus, although both rollback
and local modeling indicate that present emissions regulations might be
relaxed, further study  is necessary  to decide  if such relaxation is possible.
    Rollback for particulates shows the need for a reduction in emissions of
28,000 tons per year.  Meeting present regulations would result in a reduction
of only 300 tons per year from power plants assuming that the Schahfer plant
meets the present emission limits.  The power plants presently emit 58% of the
particulate matter in the AQCR and will probably account for a larger
proportion by 1975 when the new plant begins operating.  Given the large

-------
                                     40
emission reduction necessary and  the small fraction of that reduction to be
obtained from the power plants which are major sources, there appears little
chance of relaxing the particulate matter emissions regulations.

    3.11.3  Industrial/Commercial/Institutional Point Source Assessment
    The six sources in this AQCR  burn coal.  Present regulations can be met
with coals in the 1-2% S range and would produce a decrease in SCL emissions
of 9,000 tons per year.  There is capacity for 759,000 tons per year of
increased emissions based on rollback.  These results show that this AQCR may
be a good candidate for S09 emissions regulatic:. relaxation.  The same
                          It
cautions as were evidenced in the power plant analysis apply here in that
regulation relaxation may detrimentally impact on NAAQS maintenance.
    There is no room for particulate regulation relaxation because of current
particulate air quality problems.

    3.11.4  Area Source Assessment
    Area sources are contributing significant amounts to regional emission
loads although not more than 10%  (see Tables A-6 and A-7).  Indiana regulations
are not applied to these small sources.  Table E-l gives a fuel use summary.

    3.11.5  Fuels Assessment
    Table F-l shows that almost 8 million tons of low sulfur coal could be
conserved through regulation relaxation with about half of this being replaced
by moderate sulfur and the rest by high sulfur coal.  Since the potential fuel
savings are significant, it is imperative that possible maintenance issues be
resolved prior to regulation relaxation.

    3.11.6  Overall Assessment
    Indications of poor particulate air quality with no overall tolerance for
emissions increases and the substantial impact of combustion source emissions
on air quality make this region  a poor candidate for particulate emission
regulation relaxation.
    Even though there  is a significant clean fuel saving potential, the  large
impact of combustion  sources  on  regional  air quality and the insufficient SC^
air quality data base make this  region a  marginal candidate  for SCL emission
regulation relaxation.

-------
                 41
             APPENDIX A



State Implementation Plan Background

-------
                                                  TABLE A-l.  Indiana Air Pollution Control Areas
Demographic Information
Air Quality
Control Region
Chicago (111.)
East Central Indiana
Evans ville-Owensbo ro-
Henderson (Ky.)
Louisville (Ky.)
Cincinnati (Ky. , Ohio)
Indianapolis
Northeast Indiana
South Bend-Elkhart-
Benton Harbor (Mich.)
Southern Indiana
Wabash Valley-
Federal
Number
67
76
77
78
79
80
81
82
83
84
Population
1970
(Millions)
7.78
.55
.51
.83
1.66
1.11
.49
,83
.55
.81
Area
(Square
Miles)
6087
3085
5704
908
3816
3072
3558
4198
8667
10239
Population
Per Square
Mile
1278
179
89
912
435
362
139
197
63
79
Priority
Classification
Parti-
culates
I
II
I
I
I
I
II
I
IA
I
S0x
I
II
II
I
II
I
III
IA
IA
I
N0x
I
III
III
III
III
iTl
III
III
III
III
Proposed ACMA Designations3
TSP Counties
(2) Lake, Porter
(0)
(1) Vanderburgh
(0)
(0)
(1) Marion
(0)
(0)
(0)
(0)
SO
x Counties
(2) Lake Porter
(0)
(1) Vanderburgh
(0)
(0)
(1) Marion
(0)
(0)
(0)
(0)
As of November 14, 1974

-------
                                           43
   GARY-HAMMOND
                      LAFAYETTE WEST LAFAYETTE
                                            TIPTOM
                                                                        TSP  DESIGNATION
                                                                        S02   DESIGNATION
                                                                     LEGEND
                                                          ©   Places ol 100,000 or more inhabitants
                                                          •   Places of 50.000 to  100,000 inhabitants
                                                          D   Central cities ol SMSA s with fewer than 50.000 inhabitants
                                                          O   Places of 25,000 to  50,000 inhabitants outside SMSA's
                                                                   I Standard Metropolitan
                                                                     Statistical Areas (SMSA's)
Figure A-l.    Proposed Indiana Air Quality Maintenance  Areas  (AQMrY)

-------
                          TABLE A- 2.   Indiana Ambient Air Quality Standards
                                  All concentrations in pgms/m

Federal

State


Primary
Secondary
Primary
Secondary
Total Suspended
Annual
75 (G)
60 (G)
75(G)
60 (G)
Particulate
24 -Hour
260a
150a
260a
150a
Annual
80 (A)
—
80 (A)
60 (A)
Sulfur Oxides
24-Hour 3-Hour 1-Hour
365a
1300a
365a
260a --- 1100a
Nitrogen Dioxide
Annual
100 (A)
100 (A).
100 (A)
100 (A)
     to be exceeded more than once per year.
(A)   Arithmetic mean
(G)   Geometric mean

-------
                                             TABLE A-3     Indiana AQCR Air Quality Status, TSP
                                                                                         Number  of Stations  Exceeding
TSP Concentration (ugm/m )
AQCR No. Stations
No. Reporting
67b
76
77b
78b
79b
80
81
82b
83
84
a!973 air quality
Interstate
GViolations based
Formula :
93
7
27
21
55
22
2
18
4
16
Highest
Annual
164
70
144
162
166
70
89
45
67
data in National Air Data


on 2nd highest reading at

( 2nd Highest
I 2nd
Reading
24-Hr
888
165
398
514
450
284
141
244
189
285
Ambient Air
2nd Highest Reading Primary
24 -Hr
611
136
270
437
351
253
129
206
182
130
Annual 24-Hrc
34
0
7
6
9
0
2
0
0
15
0
1
3
2
0
0
0
0
0
Quality Standards %
Secondary
Annual
50
1
13
8
32
1
4
0
1
R
Me
Reduction Con-
equired to , trolling
et Standards Standard
1 24-Hrc %
54 55
14 0
48 11
38 12
58 14
5 9,
0
22 4
0 1
6 0
59
0
41
57
25
41
0
22
25
0
+ 92
+ 25
+ 76
+ 79
+ 80
+ 47
- 21
+ 52
+ 21
+ 21
Annual
Annual
Annual
Annual
Annual
24-Hr
Z4-Hr
Annual
24-Hr
Annual
Bank as of June 7, 1974.

any station.
24-Hr - 24-Hr
Highest 24 -Hr.


Secondary Standard )
- Background /


x 100,


[ Annual
\


- Annual
Annual -


Secondary
Background


Standard \
I


x 100



Background (ugm/m ):   50.7 for AQCR  67
                      33.0 for AQCRs 77, 78, 79, 80, 82, 84
                      30.0 for AQCRs 76, 81, 83

-------
                                                    TABLE A-4.   Indiana AQCR Air Quality Status, SO*
                                                                                          Number of Stations Exceeding
SO-, Concentration (ugm/m )

AQCR
No.
67b
76
?7b
78b
79b
80
81
82b
83
84
No. Stations

24-Hr
76
6
20
21
32
12
2
5
4
5
Reporting

Cont.
24
-
5
8
3
-
-
-
-
-
Highest

Annual
147
-
39
61
55
48
-
14
-
-
Reading

24-Hr
583
96
267
419
203
225
32
382
125
170
2nd Highest

24-Hr
275
86
205
211
141
133
23
259
78
110
Ambient
Air Quality Standards
Reading Primary

Annual
3
0
0
0
0
0
0
0
0
0

24-Hrc
1
0
0
0
0
0
0
0
0
0
Secondary

3-Hrc
0
-
0
0
0
-
-


-
% Reduction
Required to
Meet Standards


+ 46
- 324
- 78
31
- 45
- 67
- 1487
41
- 368
- 232

Controlling
Standard


Annual
24-Hr
24 -Hr
Annual
Annual
Annual
24-Hr
24 -Hr
24-Hr
24 -Hr
a!973 air quality data in National Air Data Bank as of June 7, 1974.

 Interstate

''Violations based on 2nd highest reading at any station.
A
 Formula:
                                   I 2nd Highest 24-Hr - 24-Hr  Standard
                                   >2nd Highest 24-Hr
x 100,
Annual - Annual Standard
        Annual
x 100

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                                               Table A-5.   Indiana Fuel Combustion Source Summary
AQCR
No.
67e
76
77e
78e
79e
80
81
82e
83
84
Power
Plants3
3
1
6£
1
1
4
1
2
1
9f
Other Fuel Combustion Area
Point Sources0 Sources
8
8
3
1
1
14
3
2
3
6
2
8
8
2
2
8
9
5
23
25
Total Emissions
(103 tons/year)
TSP SO,
663
41
107
271
259
78
27
72
55
132
1152
41
554
168
479
183
28
87
267
327
% Emissions from
Indiana Fuel Combustion Sources
TSP SO,
18
49
68
12
20
79
55
78
49
78
43
95
74
76
35
95
93
90
99
99
Total
                       29
                                              49
                                                                       92
1704
3287
                                                                                                                           33
                                                                                                                                        71
alndiana plants
 Indiana plants contributing 90% of the particulate and SO, emissions
""Indiana counties
dAQCR total
Interstate
 Additional plant scheduled for 1975

-------
                                              TABLE A-6    Indiana Emissions Summary  , TSP

AQCR
67 Indiana
Other
Total
76
77 Indiana
Other
Total
78 Indiana
Other
Total
79 Indiana
Other
Total
80
81
82 Indiana
Other
Total
83
84
Total

, Total
(10 tons/yr)
255
408
663
41
80
26
107
42
228
271
51
208
259
78
27
63
9
72
55
132
1704

\
15
24
39
2
S
1
6
3
13
16
3
12
15
5
2
3
1
4
3
8
100

Electricity Generation
(1Q3 tons/yr) %
7
6
14
2
38
4
42.
2
0
2
47
76
123
30
2
39
0
39
14
77
343
3
2
2
4
47
14
39
5
0
1
92
37
16
38
8
62
0
54
25
58
20
Indus trial/Commerical/
Institutional
(103 tons/yr)
95
30
124
5
29
1
30
28
5
33
3
37
39
12
3
4
.3
4
3
13
267
i 	
Point Source
J_
37
7
19
12
36
5
28
67
2
12
5
18
15
15
10
6
4
5
6
10
16

Area Source
(103 tons/yr)
15
120
135
13
6
3
9
3
14
17
1
50
51
20
10
13
3
16
10
13
296

J_
6
29
20
33
7
11
8
7
6
6
1
24
20
26
37
21
39
23
18
10
17
                                                                                                                                                oo
aEmissions in Data Bank as of June 27, 1974.


-------
                                               TABLE A-7     Indiana Emissions  Summarya,  SO-
AQCR
67 Indiana
Other
Total
76
77 Indiana
Other
Total
78 Indiana
Other
Total
79 Indiana
Other
Total
80
81
82 Indiana
Other
Total
83
84
Total
, Total
(10 tons/yr)
622
530
1152
41
413
141
554
128
40
168
171
308
479
183
28
80
7
87
267
327
3287
%
19
16
35
1
13
4
17
4
1
5
5
9
14
6
1
2
0
2
8
10
100
Electricity Generation
(103 tons/yr) 1
279
192
471
9
231
133
364
110
0
110
164
232
396
112
1
51
0
51
237
263
2015
45
36
41
22
56
94
66
85
0
65
96
75
83
61
5
64
0
59
89
81
61
Industrial/Commercial/
Institutional Point Source
(103 tons/yr) %
193
308
SOI
12
171
1
172
13
18
31
5
28
33
31
9
9
.7
9
12
35
846
31
58
43
28
41
1
31
10
46
19
3
9
7
17
33
11
10
11
4
11
35
, Area Source
(10J tons/yr)
20
225
245
19
10
6
16
4
19
23
1
26
27
31
15
18
5
24
17
23
438
%
3
42
21
45
2
4
3
3
48
14
1
8
6
17
55
23
74
27
6
7
13
                                                                                                                                                <£>
Emissions in Data Bank as of June 27, 1974

-------
TABLE A- 8.
AQCR Required Particulate
1 103
67b +92
76 +25
77b . +76
78b . +78
79b +80
80 +47
81 - 8
82b +52
83 +21

84 +21
Indiana AQCR Required
Emission Reduction
tons /year
+610
+ 10
+ 81
+211
+207
+ 37
- 21
+ 37
+ 12

+ 28
Emission Reductiona
Required SCL
%
+ 46
- 324
- 78
- 31
- 45
- 67
-1487
- 41
- 368

- 232

Emission Reduction
10 tons/year
+530
-133
-432
- 52
-216
-123
-416
- 36
-983
o
-759
aBased on a proportional change of emissions to air quality.
 Interstate

-------
                                             Table A-9.    Indiana Fuel Combustion Emission Regulations
                            Existing Facilities
Particulates

In all areas except Lake and Porter
Counties  (*67), and in the Metro-
politan Indianapolis AQCR
In Lake and Porter Counties and
in the Metropolitan Indianapolis
AQCR
Maximum ground level concentration
of 50 ugms/m3 for k - I hour
average limited by a maximum
emission rate of  .8 lbs/106 Btu

Limit determined by Fig. A-2.
                                                                 New Facilities
                                                                                    <. 250 x 1Q6 Btu/hr
Maximum ground level concentration
of 50 y.gms/m3 for h - 1 hour
average limited by a maximum
emission rate of  .6 lbs/10^ Btu

Limit determined by Fig. A-2.
> 250 x 106 Btu/hr


.1 lbs/106 Btu




.1 lbs/106 Btu
SO,
                            Existing Facilities
           Smaller of the emission rates as determined by
           (a) maximum ground level concentration of
           200ugms/m3 or (b) Fig. A-3.
                                                                 New Facilities
                                         < 250 x 106 Btu/hr

                                      Same as for existing facilities.
                                             > 250 x 106 Btu/hr
                                        Federal New Source Performance
                                        Standards

                                            .8 lbs/106 Btu for liquid
                                                                 fuel

                                           1.2 lbs/106 Btu for solid
                                                                 fuel

-------
Q_


CO
CO
CO
        1,0
       0,9

       0,8

       0,7

       0,6


   _  0.5
   Z3

   £  0.4



   =1  0,3
UJ -«.

CD dE


o
_i
_i

-------
CO
en
 CM
o
      10

      9

      8

      7

      6


      5


   5  4
ob
<

o

_i

             T   I  i  i i i ii      I    I  i  i i 11
                                                    T  I I  I M l|     I   I   i Mill)     I   I   i  i i i M
                                                                                                     en
                                                                                                     04
              i   i  i  i 11 ill     i   i  i  11  mi     i   i  i  i i  M il     i   i  i  i 11 nl      i   i  i  i  11

                          10                100              1000              10,000            100,000


                                  TOTAL HEAT INPUT , Qm (MILLIONS BTU/HR)
                                 Figure A-3.  Indiana SO- Emission Limits

-------
               55
          APPENDIX B



Regional Air Quality Assessment

-------
        Table B-l.   Indiana AQCR Candidacy Assessment for Particulate Regulation Relaxation
Stations                Number o£
                        Counties
Emission Reduction
Air
Quality
Control F(
Kh
witn v^-"----
Particulate Expected with Prp-
=>deral Air Quality Attainment posed AQMA
l_u»_ \/,r,iatinn^ Date Designations
Region Nuiiiuci. • -- — — - —
Chicago (111.)
East Central
Indiana

• i -i f rr^ , "\
Evansville (.Ky-J
.. ~"
Louisville (Ky.)
Cincinnati
(Ky., Ohio)

Indianapolis
_ 	 	 —
Northeast
Indiana
South Bend
(Mich.)
Southern Indiana
Wahash Valley
67
76

77
/ /
78
79
80
O\J
—
81
82
83
84
60
1

16
— • -
14
34
9
. 	 	 —
0
4
1
1
_ 	 ••• • — '
1/77
7/75

7/75
— — 	 • 	
7/75
7/75
7/75
	 • 	 • 	 • —

7/75
7/75
7/75

2
o-

I

0
0
1
	 	 	 • 	 "
o

0
0
0
Total Particulate % Emissions
Emissions from Indiana
(103 tons/yr) Fuel Combustion
AA^
DuJ
41
1 A*7
107
,_ — 	 . 	

259
78
. 	 	 	 —
27

72
r r
55
132
18

49
f.0
uo
1?
J-i.
20
79
55

78
4.0
*T-7
78
Required tor
NAAQS
(103 tons/yr)
t61Q

+ 10
+ 81

+211

+207
+ 37
- 21

+ 37
+ 12

+ 28
Particulate
Priority
1

2
1

1

1

2

1
1A



-------
Table B-2.  Indiana AQCR Candidacy Assessment for SO, Regulation Relaxation
Air
Quality
Control
Region
Chicago (111.)
East Central
Indiana
Evans vi lie (Ky.)
Louisville (Ky.)
Cincinnati
(Ky. , Ohio)
Indian apol is
Northeast
Indiana
South Bend
(Mich. )
Southern Indiana
Wabash Valley
Federal
Number
67
76
77
78
79
80
81
82
83
84
Stations
with
S02
Air Quality
Violations
4
0
0
0
0
0
0
0
0
0
Number of
Counties
Expected with Pror
Attainment posed AQMA
Date Designations
1/77 2
0
1
0
0
1
0
0
0
0
Total S02
Emissions
(103 tons/yr)
1152
41
554
168
479
183
28
87
267
327
% Emissions
from Indiana
Fuel Combustion
43
95
74
76
35
95
93
90
99
99
Emission Reduction
Required for
NAAQS
(103 tons/yr)
+530
-133
-432
- 52
-216
-123
-416
- 36
-983
-759
S02
Priority
1 .
2
2
1
2
1
3
1A
1A
1

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           59
      APPENDIX C



Power Plant Assessment

-------
                     60
Table C-l.  Indiana Power Plant Assessment
                   Estimated 1975
                     Fuel Use
S Under        % S
AQCR Plant
67 State Line
Bailly
D. H. Mitchell
76 Whitewater
77e Petersburg
Petersburg (Ratts)
Culley
Ohio River
Warrick
Jasper
Gibsond
78 e Gallagher
79 e Tanners Creek
19 '/S Capacity
(Mw) Fuel
972.0
615.6
529.4
30.0
732.7
233.2
399.7
121.5
300.0
21.5
650
637.0
1,100.3
Coal
Gas
Coal
Gas
Coal
Gas
Coal
Coal
Coal
Oil
Coal
Oil
Oil
Gas
Coal
Oil
Gas
- Coal
Coal
Coal
Oil
Coal
Oil
Quantitya
1,857
15,348
1,037
2,307
1,272
4,418
146
2,019
719
298
1,196
17
2,680
2,109
1,933
151
37
45
2,013
1,679
2,143
1,972
1,344
SIP ,
Regulations
.95
.77
.84
1.41
.7
.7
.20
.7
.10
.20
.7
.10
2.3
.7
.7
.31
.7
.10
Allowed
by Model
-
-
-
-
3.4
2.9
2.6
-
~
1.5
3.3
.8

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61


Table C-l. Indiana Power Plant Assessment (Con'd.)
Estimated 1975
Fuel Use
AQCR Plant
80 Perry K S W
H. T. Pritchard
E. W. Stout
Noblesville
81 Lawton Park
82 e Twin Branch
Michigan City
83 Clifty Creek
84 Breed
Coyuga
Dresser Station
Edwardsport
Wabash River
Frankfort
Logansport
Peru
1975 Capacity
(Mw)
59.1
396.4
838.8
106.0
40.0
394.0
735.96
1,303.6
495.6
1,018.0
167.0
165.0
881.0
32.5
74.2
40.0
Fuel
Coal
Coal
Oil
Coal
Oil
Coal
Oil
Coal
Coal
Oil
Coal
Gas
Coal
Coal
Oil
Coal
Oil
Coal
Oil
Coal
Oil
Coal
Oil
Coal
Oil
Coal
Oil
Coal
Oil
Quantitya
289
640
4,112
1,931
3,373
116
168
51
627
454
1,817
3,718
3,904
979
168
1,866
613
391
1,604
420
420
2,335
4,813
81
1,176
89
840
60
42
% S Under % S
SIP , Allowed
Regulations by Model0
.7 3.2
.7 2.4
.10
.7 1.8
.30
.9 2.9
.31
1.9
.7 2.9
.10
.7 1.4
.7 3.1
.7 3.6
.10
.7 2.3
.31
.7 3.4
.31
.7 1.9
.31
.7 1.5
.31
1.8 o
.20e
1.7
.20e
1.9
.20e

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                                          62
                 Table C-l.  Indiana Power Plant Assessment (Con'd.)
Estimated 1975
AQCR
84
(Cont'd)
1975 Capacil
Plant (Mw)
Crawfordsville
Schah£erd
35.2
520.95
Fuel Use
Ly
Fuel
Coal
Coal
Quantitya
84
1,928
% S Under % S
SIP , Allowed
Regulations by Model
1.7
.7
aCoal quantity is 10  tons/yr, oil quantity is 10  gal/yr, gas quantity is 10  ft /yr.
 Estimates are based on 1971 fuel use patterns plus planned additions.  If 1971 fuel
 use data were unavailable, 1972 data were used.

 In dual coal-oil fired plants, only coal is assumed to change.  Oil of the same I S
 as was fired in 1972 was assumed for 1975.  The maximum allowable % S is assumed to
 be the 1971 % S unless the regulations require a lower I S.


""Maximum allowable % S is assumed to be 1971 % S unless modeling results show a lower
 I S allowable.
     plant in 1975.
'Interstate

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AQCR
67-1
76
773
78^
793
80
81
82^
83
84

Fuel
Coal
Gas
Coal
Coal
Oil
Gas
Coal
Oil
Coal
Oil
Coal
Oil
Coal
Coal
Oil
Gas
Coal
Coal
Oil

1975 Fuel Required by
SIP Regulations
< 1* 1-21 > 2%
4,166
21,873
146
7,880 45
3,146
2,146
1,679
2,143
1,972
1,344
2,976
7,653
51
2,444
454
3,718
3,904
7,919 314
9,676
so2
1975
Emissions
Reductionb
(tons/yr)
169,431
4,438
217,219
9,023
149,500
28,058
776
14,803
226,149
147,019
1975 Fuel Required by
Modified Regulations0
< 1% 1-2% > 21
No modeling results available.

1975
Modified Emissions
Reduction^
(tons/yr)

No modeling results available.
2,013f 3,934f
3,146
2,146
1,679
2,143
1,972
1,344
1,931 1,045
7,653
-125,197f
427
145,670
-39,612
No modeling results available.
1,817 627
454
3,718
3,904
2,755h 3,236h
9,676
-36,467
44,192
Particulates
1975
Emission Reduction
by SIP Regulations6
(tons/yr)
0
420
4,902g
0
29,821
25,971
1,926
32,924
0
-42h • 3001

-------
                                             Table C-2.    Indiana Power Plant Evaluation Summary  (Cont'd.)
al-'uel requirements based on 1971 fuel use patterns at 1975 consumption rates.  If 1971 fuel data were unavailable, 1972 data were used.  Coal
 quanity is 103 tons/yr, oil quantity is IIP gal/yr, gas quantity is 10& ft3/yr.  Maximum allowable I S is 1971 % S unless regulations require
 a lower % S.

 Emission reduction from current emission rates.  Oil of the same % S as was fired in 1972 was assumed for 1975.  If actual fuels % S were
 unknown, state-wide averages were used.

Stoximum allowable % S is 1971 % S unless modeling indicates a lower % S.  Oil and gas consumption are assumed to remain constant.

 Emission reduction from current emission rate.

°Emission reduction from current emission rates.  Plants already at or below SIP requirements are  .jsumed to remain so.  New plants are assumed
 to meet SIP regulations.

 Modeling results available for only 75% of 1975 capacity.

^Emissions available for only 67% of 1975 capacity.

 Modeling results available for only 79% of 1975 capacity.

1Bnissions available for 98% of 1975 capacity.
 Interstate

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                              65
                          APPENDIX D



Industrial,  Commercial,  Institutional Point Source Assessment

-------

66


Table D-l. Indiana Industrial/Commercial/Institutional Source Assessment
AQCR Planta
67e Inland Steel
Atlantic Richfield
American Oil -
(Indianapolis Blvd.)
Youngs town Sheet § Tube
U.S. Steel - Gary
Union Carbide
American Oil - Whiting
Mobil Oil
76 Delco Remy
CMC - Guide Lamp
Anaconda
Johns -Manville
Indiana State Reformatory
Ball State University
GM - Fisher Body
Nicholson File
77e General Electric
Arkla Air Conditioning
Fuelb
Coal
Oil
Oil
Oil
Coal
Oil
Coal
Oil
Coal
Oil
Oil
Coal
Coal
Coal
Coal
Coal
Coal
Coal
Coal
Coal
Coal
Estimated
Fuel
Consumption
1,227
58,599
802,548
1,346,624
216
175,414
224
17,389
137
623,121
44,777
40
62
13
8
18
14
18
9
57
41
SIP
Regulations
* Sd
.84
1.0
1.0
3.36
1.52
1.48
1.0
1.7
2.17
1.82
3.09
3.39
2.79
3.03
2.78
3.38
1.93
2.11
Alcoa - Warwick

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                                   67
Table D-l.  Indiana Industrial/Commercial/Institutional Source Assessment (Cont'd.)

AQCR Plant3
78e Olin-Ammo Plant

79 Jos. E. Seagram -
Lawrenceburg
80 National Starch $ Chemical
Citizens Gas § Coke

Eli Lilly
Bridgeport Brass
Central Soya - Indy
Ford Motor
Fort Benj . Harrison
Rock Island Refining
RCA
Chrysler
Detroit Diesel

Evans Milling
Western Electric
Chevrolet Motor Div.
81 Central Soya - Decatur
Central Soya - Decatur
International Harvester

Fuelb
Coal
Oil
Coal
Coal
Coal
Oil
Coal
Coal
Coal
Coal
Coal
Oil
Coal
Coal
Coal
Oil
Coal
Coal
Coal
Coal
Coal
Coal
Estimated
Fuel
Consumption
150
1,520
75
95
29
297
61
24
19
46
27
36,348
24
27
26
13,970
11
35
26
40
40
65
SIP
Regulations
% Sd
1.44
—
1.71
1.60
2.39
-
1.82
2.49
2.74
2.06
2.39 '•
1.8
2.51
2.39
5.90
-
3.17
2.21
2.39
2.10
2.10
1.82

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                                        68
     Table D-l.   Indiana Industrial/Commercial/Institutional Source Assessment (Cont'd.)
AQCR
82e

83


84





Plant3
University of Notre Dame
Uniroyal
Container Corp. of America
Ind. U. - Bloomington
Muscatatuck State Hosp.
Commercial Solvents
Olin Corp. Film Op.
Pfizer
Purdue U. - Phys. Plant
Weston Paper § Mfg.
Chrysler
Fuelb
Coal
Oil
Coal
Coal
Coal
Coal
Coal
Coal
Coal
Coal
Coal
Coal
Estimated
Fuel
Consumption0
45
3,057
33
40
90
18
83
79
88
115
82
66
SIP
Regulations
I Sd
2.54
2.27
2.11
1.65
2.74
1.71
1.70
1.65
1.48
1.71
1.82
alndiana plants contributing 901 of the AQCR's S02 and particulate emissions.


''Does not include plant or process gas.

~          3                   3
"Coal in 10  tons/yr, oil in 10  gals/yr.


 For plants using both coal and oil, the \ S in the oil was  assumed to remain  at
 present levels.  Within a given plant, there may be particular units  fired primarily
 on oil which would not be in compliance firing such oil.
 Since unit-by-unit fuel mix data was unavailable, compliance was required on  a plant-
 wide basis.


"Interstate
 This plant is a joint industrial-electric utility facility and has been included in
 the power plant category.

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                                      69
Table D-2.  Indiana Indus trial/Commercial/ Institutional Source Evaluation Summary

                                  Fuel                             SCL       ,
                      Required by Existing Regulations     Emission Reduction
AQCR          Fuel       <1%        1-2%        >2%            (tons/yr)
67e
76
77e
78e
79e
80
81
82e
83
84
Coal
Oil
Coal
Coal
Coal
Oil
Coal
Coal
Oil
Coal
Coal
Oil
Coal
Coal
1,227 361, 216
251,402° 2,817,070
62 120
-f 57 41
150
1,520C
75
156, 294
14,267C 36,348a
65 80
78
3,057C
90 58
513
-133,716
2,073
2,001
6,696
2,747
-1,694
2,847
456
4,505
8,976
aDoes not include plant or process gas.
 Coal in 103 tons/yr; oil in 103 gals/yr.
 Since unit-by-unit fuel mix data was unavailable, compliance was
 determined on a plant-wide basis.


 Emission reduction from current rates.
 Does not include any reductions from required desulfurization of process gases.

£»
 For dual coal and oil fired plants the % S in the oil was assumed to remain at
 present levels.


 Current SIP regulations require a minimum of 1% S oil.


eInterstate


 Does not include coal burned at the ALCOA-Warrick plant which is listed as a
 power plant.

-------
           71
      APPENDIX E



Area Source Assessment

-------
                             TABLE E-l.  Indiana Area Source Fuel Use
AQCR
67a
76
77a
78a
79a
80a
81
82a
83
84
TOTAL
Coal
(10 3 tons/yr)
1,412
34
137
380
678
76
43
118
69
94
3,041
Distillate Oil
(10 3 gals/yr)
1,274,170
77,700
48,960
81,440
218,400
184,460
72,580
175,910
88,780
116,990
2,339,390
Residual Oil
(10 3 gals/yr)
468,050
3,230
3,850
14,260
2,070
5,040
2,480
9,710
2,380
3,310
514,380
Natural Gas
(106 ft3/yr)
650,710
60,400
43,570
64,350
131,990
98,620
46,560
75,620
46,670
71,910
1,290,400
                                                                                                                -vl
                                                                                                                K)
Interstate - Fuel use  figures  are for entire AQCR.

-------
        73
   APPENDIX F



Fuels Assessment

-------
                                                 TABLE F-l.   Indiana Clean Fuels Analysis Summary
                                    Existing Regulations Clean Fuel Requirements  I  Modified Regulations Clean Fuel Requirements
1
AQCR
67C
76
77C
78C
79C
80
81
82C
83
84
State
Total
Fuel
Coal
Coal
Coal
Coal
Coal
Coal
Coal
Coal
Coal
Coal
Coal
< 1% S 1-2% S
5,393 361
208
7,880 57
1,679 150
1,972 75
2,976 156
116
2,444
3,904 90
7,919 827
34,167 ' 2,040
< 11 S 1-2% S
d
e
2,070
150
1,972 75
• 2,087
e
1,817
90
3,268
8,781f 9,557f
aFrom power plant, industrial/commercial/institutional point sources.  Includes only that required and not entire fuel consumption.
 Coal in 103 tons/yr, oil in 103 gals/yr, gas in 106 ft-5/yr.
 Based on modeling results.   Since Indiana regulations permit fuel switching for compliance it is a: turned that oil and gas characteristics
 and use will be constant while coal sulfur content is modified.  No modeling results available for industrial/commercial/institutional
 sources; fuel consumption was assumed to remain at SIP requirements.
 Includes only that required and not entire consumption

 Interstate

 Although no modeling results are available, the regional analysis indicates that no shift to higher fuel sulfur content could be
 tolerated.
eAlthough no modeling results are available, the regional analysis indicates that some shift to higher fuel sulfur content could be
 tolerated.
 Incomplete picture of clean fuels savings due to lack of modeling data in all AQCRs.

-------
                                       75


                                 REFERENCES
1.  Modeling Analysis of Power Plants for Compliance Extensions in 51 Air
    Quality Control Regions, report prepared under Contract No. 68-02-0049
    for the U.S. Environmental Protection Agency, Walden Research Division
    of Abcor, Inc., Cambridge, Mass., December 17, 1973.

2.  Steam Electric Plant Factors, 1975, National Coal Association, Washington,
    D.C., January 1974.

3.  Power plant data file, unpublished, U.S. Environmental Protection Agency,
    Research Triangle Park, N.C.

4.  Power plant SC>2 emission estimates, unpublished data, U.S. Environmental
    Protection Agency, Research Triangle Park, N.C.

5.  National Emissions Data Systems data bank, U.S. Environmental Protection
    Agency, Research Triangle Park, N.C.

-------
                                             7b
                                   TECHNICAL REPORT DATA
                            (Please read Instructions on the reverse before completing)
      5(5^-74-066
                              2.
                                                           3. RECIPIENT'S \CCESSI OI*NO.
4.
                 PLAN REVIEW  FOR INDIANA 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. PE
 U.:
   FORMING ORGANIZATION NAME AND ADDRESS
   . Environmental Protection  Agency, Office of Air
Quality Planning and Standards,  Research Triangle
Park, N.C.,  Regional Office  V, Chicago, Illinois
and Argonne.  National Laboratory, Argonne, Illinois
                                                            10. PROGRAM ELEMENT NO.
                                                            11. CONTRACT/GRANT NO.


                                                             EPA-IAG-D5-0463
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
                                                                  Tinal 	
                                                           14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
16. ABSTRACT
      Section  IV of the Energy  Supply and Environmental  Coordination Act of 1974,
 (ESECA) requires EPA to review each State Implementation  Plan (SIP) to determine
 if revisions  can be made to control regulations for  stationary fuel combustion
 sources without interfering with the attainment and maintenance of the national
 ambient air quality standards.   This document, which is also required by Section
 IV of ESECA,  is EPA's report to the State indicating where regulations might  be
 revised.
17.
                                KEY WORDS AND DOCUMENT ANALYSIS
                  DESCRIPTORS
                                              b.lDENTIFIERS/OPEN ENDED TERMS
                                                                        c.  COSATI Field/Group
 Air pollution
 State implementation plans
18. DISTRIBUTION STATEMENT

 Release unlimited
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                                               Unclassified
                                                                          21. NO. OF PAGES
76
                                               20. SECURITY CLASS (Thispage)
                                                Unclassified
                                                                         22. PRICE
EPA Form 2220-1 (9-73)

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