EPA-450/3-74-067
DECEMBER 1974
IMPLEMENTATION PLAN REVIEW
FOR
OHIO
AS REQUIRED
BY
THE ENERGY SUPPLY
AND
ENVIRONMENTAL COORDINATION ACT
U. S. ENVIRONMENTAL PROTECTION AGENCY
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EPA-450/3-74-067
IMPLEMENTATION PLAN REVIEW
FOR
OHIO
REQUIRED BY THE ENERGY SUPPLY AND ENVIRONMENTAL COORDINATION ACT
PREPARED BY THE FOLLOWING TASK FORCE:
U. S. Environmental Protection Agency, Region V
- 230 South Dearborn
Chicago, Illinois 60604
Energy and Environmental Systems Division
Argpnne National Laboratory
Argonne, Illinois 60439
(EPA-IAG-D5-0463)
U. S. Environmental Protective 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 OHIO
REQUIRED BY THE ENERGY SUPPLY AND ENVIRONMENTAL
COORDINATION ACT
Table of Contents
Page
1.0 EXECUTIVE SUMMARY 5
2.0 OHIO STATE IMPLEMENTATION PLAN REVIEW . 8
2.1 Summary 8
2.2 Air Quality Setting for the State of Ohio 11
2.3 Background on the Development of the Current
State Implementation Plan 16
2.4 Special Considerations for the State of Ohio 21
3.0 AIR QUALITY CONTROL REGION ASSESSMENTS 22
3.1 General Methodology 22
3.2 Cincinnati Interstate AQCR (#79) 24
3.3 Portsmouth-Ironton Interstate AQCR (#103) 26
3.4 Toledo Interstate AQCR (#124) 27
3.5 Dayton Intrastate AQCR (#173) 28
3.6 Cleveland Intrastate AQCR (#174) 28
3.7 Mansfield-Marion Intrastate AQCR (#175) 29
3.8 Columbus Intrastate AQCR (#176) 30
3.9 Northwest Ohio Intrastate AQCR (#177) 31
3.10 Youngstown Interstate AQCR (#178) . . 31
3.11 Marietta Interstate AQCR (#179) 32
3.12 Sandusky Intrastate AQCR (#180) 33
3.13 Steubenville Interstate AQCR (#181) . . 33
3.14 Wilmington-Chillicothe Intrastate AQCR (#182) 34
3.15 Zanesville Intrastate AQCR (#183) 34
TECHNICAL APPENDICES
APPENDIX A - State Implementation Plan Background 37
APPENDIX B - Regional Air Quality Assessment 65
APPENDIX C - Power Plant Assessment 71
APPENDIX D - Industrial, Commercial, Institutional Point
Source Assessment 81
APPENDIX E - Area Source Assessment 99
APPENDIX F - Fuels Assessment 103
REFERENCES . . 109
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IMPLEMENTATION PLAN REVIEW
FOR OHIO
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 estab-
lish 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
iv.h«Jit> thi.s eou.lU he Utxae without jeopardizing the attainment and maintenance of
the NAAQS.
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To date, EPA's fuels policy has addressed only those states with the
largest clean fuels saving potential. Several of these states have or are
currently in the process of revising SCL regulations. These states are
generally in the Eastern half of the United States. ESECA, however, extends
the analysis of potentially over-restrictive regulations to all 55 states and
territories. .In addition, the current reviews address the attainment and
maintenance of all the National Ambient Air Quality Standards.
There are, in general, three predominant reasons for the existence of
overly restrictive emission limitations within the State Implementation Plans.
These are: 1) the use of the example region approach in developing state-wide
air quality control strategies; 2) the existence of State Air Quality Stan-
dards which are more stringent than NMQS; 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 con-
cerns, 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 NMQS 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% sulfur oil to be burned statewide where the use of 3% 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 Imple-
mentation Plans. However, it is most important for those states which desire
to submit a revised plan to recognize the review's limitations. The findings
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of this report are by no means conclusive and are neither intended nor adequate
to be the sole basis for SIP revisions; they do, however, represent EPA's best
judgment and effort in complying with the ESECA requirements. The time and
resources which EPA has had to prepare the reports has not permitted the con-
sideration 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 attain-
ment 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 suit-
able 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, pre-
vention of significant deterioration, increased TSP, NO , and HC emissions
J\.
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 emission and are
a major source of TSP emissions.
Part of each state's review was organized to provide an analysis of the
S0? 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-deaning" 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 Ohio (Air Quality
Control Regions are displayed on Fig. 1-1 ).
. The U. S. Environmental Protection Agency Region V Office is under-
taking a study to propose new regulations for the state. This study
will be consistent with the Clean Fuels Policy and will provide a
much more detailed and definitive analysis of the state's regula-
tions than is provided in this report.
Based on the brief analysis of this review, there appears to be
virtually no tolerance for increased particulate emissions through-
out the state. There are widespread high TSP readings and several
proposed Air Quality Maintenance Areas for particulates.
There are indications that SO- regulation revisions which would
permit the use of higher sulphur local fuels are possible in
some areas without violating the National Ambient Air Quality
Standards. Such a revision would result in significant savings
of clean fuels. The study being conducted by EPA, Region V will
pinpoint the actual extent to which the regulations can be changed
in each region of the state.
Coal blending(i.e. mixing of fuels with high and low sulfur content)
to achieve moderate fuel sulfur content (1-2%) may be required to
realize the clean fuels savings resulting from regulation revision.
Area source emissions play a significant role in the air quality
situation in portions of Ohio. Additional study is needed to
determine a feasible level of control for these sources which is
consistent with both air quality and clean fuels conservation.
2.0 OHIO STATE IMPLEMENTATION PLAN REVIEW
A revision of fuel combustion source emissions regulations will depend on
many factors. For example:
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(#177)
NORTHWEST
OHIO
INTRASTATE
(#124)
METROPOLITAN
TOLEDO
INTERSTATE
(OHIO-
(#175)
MANSFIELD-
MARION
(#174)
GREATER
KTROPOLITAN
CLEVELAND
(#178)
NORTHWEST
PENNSYLVANIA-
YOUNGSTOWN
INTERSTATE
(OHIO-
PENNSYLVA
DAYTON
IHTRASTATE
METROPOLITAN
CINCINNATI METROPOLITAN
INTERSTATE COLUMBUS
(OHIO- INTRASTATE
INDIANA- (#176)
KENTUCKY)
(#79)
HUNTINGTON-
ASHLAND-
PORTSMOUTH-
IRONTON
INTERSTATE
(WEST VIRGINIA-
KENTUCKY-
OHIO) (#103)
WILMINGTON-
CHILLICOTHE-
LOGAN
INTRASTATE
(#182)
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10
Does the state have air quality standards which are more
stringent than
Does the state have emission limitation regulations for control
. of (1) power plants, (2) industrial sources, (3) area sources?
. Did the state use an example region approach for demonstrating
the attainment of NAAQS or more stringent state standards?
. Has the state not initiated action to modify combustion source
emission regulations for fuel savings; i.e., under the Clean
Fuels Policy?
. Are there no_ proposed Air Quality Maintenance Areas?
. Are there indications of a sufficient number of monitoring
sites within a region?
. Is there an expected 1975 attainment date for NAAQS?
. Based on (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 regulation revision?
. Is there a significant clean fuels savings potential in the
region?
. Must the regulations be revised to accomplish significant
fuels switching?
The following portion of this report is directed at answering these ques-
tions. An AQCR's potential for revising regulations increases when there are
affirmative responses to the above.
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.
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11
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 Plan Review. The remaining por-
tions of the report support this summary- with explanations.
2.2 Air Quality Setting for the State of Ohio
2.2.1 Ohio Air Pollution Control Areas
The State of Ohio is divided into fourteen Air Quality Control Regions
(AQCRs), as shown in Fig. 1-1. There are eight intrastate and six interstate
regions. Table A-l gives the pollutant priority classifications for each of
the fourteen regions.
The table also shows population and population density to be largest in
the five metropolitan areas of Cincinnati (#79), Dayton (#173), Toledo (#124),
Cleveland (#174), and Columbus (#176). Based on present conditions and growth
projections for the state, some 23 counties have been designated as Air Quality
Maintenance Areas (AQMAs) for particulates and 13 for sulfur dioxide. These are
indicated in Table A-l and Fig. A-l.
2.2.2 Ohio Ambient Air Quality Standards
Ohio has adapted Federal Secondary Standards for particulates as shown in
Table A-2. The state standards for SO? are more stringent than the federal
standards, but a two-year extension in meeting these standards has been requested.
The analysis herein proceeds under the assumption that federal primary and (where
appropriate) secondary standards are to be achieved by 1975.
2.2.3 Ohio Air Quality Status
The Ohio air quality status is summarized in Table A-3 for TSP and Table.
A-4 for S02. The data is from the SAROAD data bank as of June 1974.
TSP is a widespread problem, requiring significant reductions to meet
secondary NAAQS in all but one AQCR (Marietta, #179) where TSP is currently be-
ing measured. Highest reductions are required in Cincinnati (#79, 811), Dayton
(#173, 64%), Cleveland (W4, 85%), Sandusky (jtl&Q, 84%), and Steubenville
(#181, 84%). These results are generally consistent with the AQMA designations
with the exception of Sandusky, which has only five monitors (indicating the
results may be spurious and would require more detailed analysis). Violations
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Table 2-1. State Implementation Plan Review Summary for Ohio
Portsmouth-
Cincinnati3 Ironton3 Toledo8
AQCR »79 AQCRS 0103 AQCR «124
State
Dayton
AQCR »173
"INI IK AIT IRS"
Docs the State h;ivc air quality standards which arc more
stringent than NA/\QS?
Docs the State have emission liaiiliiig regulations for
control of:
1. Tower plants
2. Industrial smives
3. Arc.*a sources
Did the State use an example region approach for demon-
strating 'the attainment of NAAQS or more stringent State
st:mJards?
lias the State not initiated action to modify combustion
source omission regulations for fuel savings; i.e.,
under the Clean Im-ls I'olicy?
Arc there no proposed Air Quality Maintenance Areas?
Arc there indications of a sufficient number of monitor-
ins sites within a region?
Is t l.o jo an expected 1975 attainment date for MAQS?
Rased on (J973) Air Quality llata, are there no reported
violation:; of NAAQS?
Dased or. (1973). Air Quality Data, arc there indications
of a significant tolerance for increasing emissions?
* Are the emissions from stationary fuel combustion sources
a nlatively small portion of the regional total?
Do ir.odeling results for specific fuel combustion sources
shew 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?
TSI> S02
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Nob
TSI> so2
Example
No
Yes
Yes
No
No
No
NA
Region
Yes
Yes
Yes
Yes
Yes
No
Yes
No
Yes
TSP - Poor
S02 - Poor
TSP S02
Yes
Yes
Yes
No
No'
Yes
NA
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
Yes
TSP - Poor
S02 - Good
TSP S02
No
Yes
Yes
No
No
Yes
NA
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
Yes
TSP - Poor
S02 - Good
TSi1 .SO,
Exampli
No
Yes
Yes
No
No
Y«
NA
Region
No
Yes
Yes
No
No
Jto
Yes
Yes
Yef
TSP - Poor
S02- Marginal
alnterstate
'The State's emission regulations are being rewritten by EPA Region v Office and
Fuels Policy as well as provide a more detailed analysis than provided in this
will reflect the Clean
review.
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Table 2-1. State Implementation Plan Review Summary for Ohio (ContiJ.)
Mansfield-
Cleveland Marion Columbus
AQCR »174 AQCR #175 AQCR #176
Northwest
Ohio.
AQCR #177
Youngstown
AQCR #178
"INIHC/VIOKS"
.r-ius tiio State IKIVC :iir quality standards ivliich arc more
slKinscnt than NAAQS?
inos the State have emission limiting regulations for
tsatcnl of:
I. i'0i:"r plants
J. I.MSI ri:i 1 snt lives
.^* Aiva sources
i-iicL the State use an example region approach for demon-
strating 'the attainment of NAAQS or more stringent State
siMS,.Jards?
isv. the State not initiated action to modify combustion
sscrc'e omission regulations for fuel savings; i.e.,
-Ucr t!-.e Clean l-'uels Policy?
Art t!'.cre no pro|Kiscd Air Quality Maintenance Areas?
rf: there indications of a sufficient number of nonitor-
-;..' sites within a region?
Is SKere an expected 1975 attainment date for NA/V.JS?
3*-«d on (1973) Air Quality Data, arc there no re-ported
relations of NAAQS?
2*;id on (1973) Air Quality Data, arc there Indications
cf A significant tolerance for increasing emissions?
Ars the cnissions from stationary fuel combustion sources
a relatively small |iortion of tlic regional total?
us modeling results for specific fuel combustion sources
?..'* a p.-itcntiul for a regulation revision?
Is there a significant Clean Fuels Saving potential in
tr* rcfion?
.'/jjj the regulations be revised to accomplish signifi-
C-JTf fiscl switchinc?b
r>:»i: 1 m the above indicators, what is the potential for
rev!-. : ,; fuel combustion source emission limiting
r<- .; .ins?
'ISI1 S02
.
Example
No
Yes
No
No
No
No
MA
Region
No
Yes
Yes
Yes
No
No
Yes
YM
Yes
TSP - Poor
SO - Marginal
'ITJI' SO,
Ho
No
Yes
No
No
No
MA
Yes
No
tes
Yes
Yes
No
MA
;jo
Yes
TSP - Poor
S02 - Poor
TSP S02
No
Yes
Yes
No
Ho'
No
NA
Yes
No
Yes
Yes
Yes
No
Yes
V»c
Yes
yep - Poor
S02 - Good
TS1' S<>2
Yes.
No
Yes
--
..
No
NA
Yes
No
Yes
Yes
Yes
No
Yes
Y»«
Yes
^IW"1
TSi» S02
No
Yes
No
No
No
Yes
NA
Yes
Yes
Yes
Mo
No 1
Yes
Yes
Yea
Yes
TSP - Poor
SO2 " Marginal
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Table 2-1. State Implementation Plan Review Summary for Ohio (Contil.)
Marietta
AQCR #179
Sandusky
AQCR #180
Steubenville
AQCR #181
Wilmington-
Chillicothe
AQCR #182
Zanesville
AQCR #183
"iNiHCATnitt"
Docs the State have air quality standards which are more
stringent than NAAQS?
Docs the State have emission limiting regulations for
control oC:
I. Power plan Is
2. liulustrial sources
3. Area sources
QU1 the State use an example region approach lor demon-
strating 'the attainment of NAAQS or more stringent State
scnnJaros?
lias the State not initiated action to modify comlustion
source omission regulations for fuel savings; i.e.,
tsulcr the Clean I'uels Policy?
Arc tiicre no proposed Air Quality Maintenance Areas?
Arc there indications of a sufficient number of monitor-
ing sites within a region?
Is there an expected 1975 attainment date for NAAQS?
3i?ed on (1973) Air Quality Data, are there no reported
violations of NAAQS?
Based on (1973) Air Quality Data, arc there indications
of 3 significant tolerance for increasing emissions?
Are the cnissions from stationary fuel combustion sources
- a relatively small |x>rtion of the regional total?
Do raJeling results for specific fuel combustion sources
shew a potential for a regulation revision?
Is there a significant Clean Fuels Saving potential in
the region?
JJjist the regulations be revised to aco...:plisli signifi-
cant fuel switchinp?b
Based on the above indicators, what is the potential for
revising fuel combustion source emission limiting
regulations?
'(SI1 S02
Yes
No
Yes
Yes
Yes
No
NA
Yes
No
Yes
.-
. __
No
Yes
Yes
Yes .
TSP - Poor
S02 - Marginal
TSP S02
Yes
Yes
Yes
No
No
Yes
NA
Yes
No
Yes
--
__
Yes
NA
No
Yes
TSP - Poor
S02 - Poor
TSP S02
No
Yes
No
No-
No'
No
NA
No
Yes
Yes
No
No
No
Yes
Yes
Yes
TSP - Poor
S02 - Marginal
TS1' S02
Yes
No
Yes
--
-.
No
NA
Yes
No
Yes
--
-.
No
NA
No .
Yes
TSP - Poor
S02 - Poor
TSP SO, .
Exainplt
Yes
No
Yes
-.
--
Yes
NA
- £ ^' -- "
Region
i
Yes j
No
Yes
I
No i
Yes
Yes
Yes
TSP - Poor
S02 - Good
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15 .
of the annual and 24-hr TSP standards, were most widespread in Cincinnati (#79),
Cleveland (#174), and Steubenville (#181), with about half of the stations
recording excesses.
Table A-4 indicates that S02 is of much less concern in meeting and main-
taining NAAQS than TSP. This is encouraging from a clean fuels perspective.
Emission reductions are required to meet the 24-hr NAAQS in Dayton (#173, 541)
and Steubenville (#181, 251). Cleveland (#174) is very close to violation of
the annual NAAQS, with a tolerance for emission increase of only 4%. Youngs-
town (#178) shows a need for emission reduction based on the highest 24-hr
reading (the second highest reading was not available). This is probably er-
roneous since Youngstown has the lowest annual average reading of all AQCRs
and could probably tolerate an emission increase. The remainder of the AQCRs
would seem to have a high tolerance for relaxed S07 emission regulations. It
Lt
should be noted that even in regions which show NAAQS violations only one sta-
tion has recorded an excess of the primary standard; thus significant problems
seem to be localized in nature and would warrant a more detailed analysis.
2.2.4 Ohio Emissions Summary
Emission sources and emission rates in Ohio are tabulated in Tables A-5
to A-8.
Power plants are concentrated in the Cincinnati (#79), Dayton (#173),
Cleveland (#174), and Steubenville (#181) AQCRs. Out of 31 plants in the state,
19 are located in these four regions. Industrial fuel combustion sources are
numerically concentrated in Cincinnati (#79), Cleveland (#174), Mansfield-
Marion (#175), Columbus (#176), and Youngstown (#178). This concentration pat-
tern, however, is not as distinct an indication of emission patterns as the
power plant locations. For example, Cleveland has 38 facilities that consti-
tute 90% of the TSP and S07 emissions, indicating a wide dispersion of sources.
Lt
Youngstown, which has a comparable total emission rate, has only 10 facilities
contributing 90% of the emissions, indicating a much more concentrated location
of sources.
Particulate emissions are highest in Cincinnati (#79), Cleveland (#174),
Youngstown (#178), and Zanesville (#183). These four regions make up 56% of
the total TSP emissions. With the exception of Zanesville (for which there is
no air quality data), all of these regions require substantial emission reduc-
tions to meet the NAAQS. The lowest emissions are from Mansfield-Marion (#175),
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16
Northwest Ohio (#17T), and Wilmington (#182), which combine for only 6% of the
total. Mansfield-Marion has the second lowest requirement for emission reduc- ,
tion and the other two have no air quality data. In all three regions, more
than half of the TSP emissions are from fuel combustion sources, indicating that
any regulation change might have a substantially detrimental effect on air
quality.
Of the six interstate regions (#79, 103, 124, 178, 179, and 181), three
have more than 601 of the emissions coming from Ohio fuel combustion sources.
Changes in Ohio regulations would have major impacts on interstate air quality.
In the other three, less than a third of the emissions are from Ohio fuel com-
bustion sources, and regulation changes would produce a much smaller impact.
S02 emissions are highest in Cincinnati (#79), Portsmouth-Ironton (#103),
Cleveland (#174), Youngstown (#178), Marietta (#179), and Steubenville (#181).
Cleveland, Dayton, and Steubenville are experiencing difficulties with the SOo
standards. The others appear to have a dispersion of emission sources that
enables the region to absorb the emissions without violation. The lowest emis-
sions are in Mansfield-Marion (#175), Northwest Ohio (#177), and Wilmington
(#182). Mansfield and Northwest Ohio have two of the largest tolerances for
emission increase; there is no air quality data for Wilmington.
Of the six interstate regions, only Youngstown (#178) has less than half
(421) of the S02 emissions coming from Ohio fuel combustion sources. All the
others have at least half, indicating that Ohio regulation changes should be
coordinated with those of adjacent states to avoid interstate air quality
violations.
The only inconsistency in the data is that Dayton (#173) has only a moderate
S02 emission rate while showing a violation of the 24 hr standard. The indication
is that the problem may be a local one rather than one that is AQCR-wide.
2-3 Background on the Development of the Current State Implementation Plan
2.3.1 General Information
The State of Ohio originally developed its total suspended particulate and
sulfur dioxide control strategies for stationary sources based on previous
modeling efforts in the Cleveland and Cincinnati AQCRs. Using available ambient
air quality and emission data, the Cleveland AQCR was determined to have the
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17
most severe particulate and sulfur oxide air pollution problem. Using the
"worst" region approach, Cleveland was selected as the example region to demon-
strate attainment of the NAAQS. The achievement of the desired air quality
levels was evaluated by proportional reduction calculations. Since the analysis
indicated that the Cleveland AQCR would not be able to attain the TSP secondary
air quality standards by 1975, the Dayton AQCR was evaluated to demonstrate the
attainment of air quality standards.
In addition to the Cleveland and Dayton AQCRs, proportional reduction ana-
lysis was made for two Priority II example regions: the Zanesville AQCR, to
demonstrate attainment of the particulate standards; and the Cincinnati AQCR,
to demonstrate the attainment of the sulfur oxide standards.
All sources of particulate emissions would have to comply with the most
stringent regulation for stationary sources by July 1, 1975, with the exception
of the Cleveland AQCR. The State is requesting an 18-month extension for sources
in the Cleveland AQCR to attain compliance with the secondary particulate stand-
ards. All sources of sulfur oxide emissions in all regions would have to meet
the most stringent regulations applicable by July 1, 1977. Combustion sources
of 250 million Btu/hr, or greater, of heat input would be required to achieve
the most stringent applicable emission regulation by July 1, 1975.
It was Ohio's aim to comply with the Federal Standards for particulates and
sulfur oxides by 1975 and for oxidants and nitrogen oxides by 1977. The data
indicate carbon monoxide standards are already being achieved. The attainment
of the air quality standards by these dates was predicated on the following
availability and use of low sulfur fuel and availability and application of flue
gas desulfurization (FGD) systems that are usable and economically feasible.
2.3.2 Particulate Control Strategy
The Cleveland and Dayton AQCRs were selected as the Priority I example
regions and the Zanesville AQCR as the Priority II region. Since the selection
of Cleveland as the "worst" region was based on existing air quality data, regu-
lations that achieve the desired air standards in this region were assumed to
achieve these same standards in the other urban regions of Ohio. The secondary
particulate standard was not achieved in the Cleveland region using this ana-
lysis: therefore, the Dayton and Zanesville regions were analyzed to confirm
achievement of the secondary standards, using the existing regulations.
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The maximum annual average and 24-hour value were measured at two separate
sampling stations in Cleveland. Based on the highest annual particulate aver-
age at one station, proportional reduction analysis indicated that a 79% reduc-
tion in particulate emissions was required to meet the federal primary air qual-
ity standard and an 87% reduction required to meet the secondary standard. A
background of 35 yg/m3 was used in this analysis.
The proposed emission regulations were applied to all point sources in the
Cleveland area, and the reductions in emissions were calculated. The regula-
tions used were based on the results of diffusion modeling conducted for the
Cleveland region during 1970. These regulations require strict controls for
both combustion and industrial sources, with more stringent controls required
for the larger sources.
t
The applicable regulations were applied to point and area sources to deter-
mine the expected levels of emissions after compliance with the regulations.
Where the existing emissions were lower than the allowable emissions (calculated
as annual average emissions), the existing emissions were used in place of the
allowable. The application of these regulations achieved an 85% reduction in
emission levels, but due to the projected growth of emissions sources for the
Cleveland area, only an 80% reduction in emissions could actually be attained.
Thus, it appeared that the 87% reduction in emissions required to achieve the
secondary standard would not be met.
2.3.3 Sulfur Oxides Control Strategy
The sulfur oxide control strategy was also developed on the basis of the
example region concept. Emission reduction calculations were made for Cleve-
land, a Priority I region, and for Cincinnati, a Priority II region.
Combustion processes, mainly the combustion of coal, account for 92% of the
S02 emissions in Cleveland. The highest ambient air values for a station in
Cleveland were an annual average of 157 yg/m3 for 24-hour average in 1970.
Using these data, a 49% reduction in emissions was required to meet the primary
standard and a 62% reduction in S02 emissions was required to meet the secondary
standard. No background S02 value was used in the proportional reduction calcu-
lations. The Priority I region regulations applied to Cleveland would achieve
a reduction of S02 emissions of approximately 72*. Allowing for projected growth,
the emissions were calculated to be reduced by 65%, thus current Priority I re-
gion regulations would enable Cleveland to achieve both the federal primary and
secondary standards.
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A 71 reduction in SCs levels was required for the highest station in the
Cincinnati region to meet the secondary standards. Implementation of applicable
regulations would result in an estimated 211 reduction of SOX emissions; thus
this region would be able to meet the applicable federal standards.
The air quality control regions in the state were subsequently re-evaluated,
using either estimated or available air quality data. This analysis resulted in
a reclassification of the AQCRs into 5 categories on a county-by-county basis.
This reclassification is based on annual pollutant concentrations and is applic-
able to combustion sources with a heat input less than 250 million Btu/hr. To
determine the classification of each county, the available air quality data were
compared with estimated air quality levels. The highest annual average concen-
trations for the period were used to determine the county's priority classifi-
cation.
The air quality estimates were developed using the "area" model described
in the CFR, Volume 36, Number 228. The data base used consisted of two major
components, the NEDS printout of annual SO? emissions on a county-by-county
basis and the urbanized area of each county, based on the Census Bureau defini-
tion. The degree of control required for small combustion sources in the reclas-
sified counties were adjusted to a level consistent with the measured or
estimated air quality levels. The concentration levels for each category and
the resulting emission limits are as follows:
County Classification Definition Based
Upon Annual Concentration
Emission Limit31
Classification (Abs S02/106 Btu) S02 Concentration - "X" - in ygm/m3
A 11.0 X > 100
B 11.6 100 > X > 60
C 3.2 60 > X > 45
D 4.0 45 > X > 30
E 4.8 30 > X
sources with less than 250 x 10* Btu/hr heat input
2,3,4 Current Situation
The Buckeye Power Decision of the Sixth Circuit invalidated EPA's approval
of the Ohio implementation plan and enabled Governor Gillyan to withdraw the
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original plan submission. In May, 1974, the Governor resubmitted a new plan
to EPA for review and approval. This resubmission had few changes that affect
large facilities and the regulations applicable to utility power plants and
other large combustion sources went essentially unchanged.
EPA has not approved the proposed revision to the emission regulations
and is conducting an extensive evaluation of the situation in preparation for
proposing alternative regulations. Special emphasis is being placed on
regulations applying to utility power plants. The current situation, there-
fore, is in a state of flux since the State does not have an approved Imple-
mentation Plan while, at the same time, has its own regulations which could,
in theory, be enforced independently.
This review, as required by ESECA, is not intended to supplant or
supersede the evaluation of the Ohio situation that is currently being con-
ducted by EPA, Region V. Rather in complying with the requirements of ESECA,
it will provide a survey of existing information and will indicate some
initial areas on which to focus the detailed analysis. The detailed evalua-
tion may confirm or dispute the findings of this cursory review but will repre-
sent the kind of in-depth analysis that must follow for a SIP revision to be
proposed.
2.3.5 Control Regulations Summary
Based on the above control strategy analyses and current developments,
Ohio now has proposed the emission control regulations that are summarized in
Table A-9. Existing facilities with heat input less than 250 x 10 Btu/hr
heat input and new facilities less than 100 x 10 Btu/hr are subject to the
S09 county emission limit regulation shown in Fig. A-2. Existing facilities
fi
greater than 250 x 10 Btu/hr are required to meet the priority region limits
specified in Table A-10 until July 1, 1975, after which they are required to
meet the 1.0 £bs S02/106 Btu limit. All new facilities greater than 100 x 10
Btu/hr are subject to the county regulation. All fuel combustion facilities
are required to meet the priority region emission limits for participates shown
in Fig. A-3.
Note that these regulations have not been approved by EPA. They are used
here only as an indication of where the detailed evaluation might focus its
attention.
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2.4 Special Considerations for the State of Ohio
In 1972, shipments of coal by Ohio mines averaged 3.41 sulfur by weight,
while shipments to utilities averaged 3.51 sulfur. The enforcement of the
current Ohio SO- regulation for power plants would prevent the use of most
coals now being burned, unless the power plants installed flue gas desulphur-
ization (FGD) systems. Very few of the local coals can comply with the
present SO- control requirements, even with the use of conventional coal
washing facilities. Wholesale installation of FGD systems are necessary if
the power plants are to comply with existing regulations and continue to
burn Ohio coals.
In 1971, Ohio was the nation's largest consumer of bituminous coal,
having consumed 63 million tons (MT). While Ohio is a net importer of coal,
it is also a significant producer (4th in the nation in 1971), having pro-
duced 51 MT; most of this was consumed in the East-North Central Region. Con-
sumption in 1971 was broken down as follows:
Utility 38.6 MT
Coal $ Gas 10.6 MT
Retail 1.3 MT
Industrial § Other 12.6 MT
Total 63.1 MT
This utility consumption level was also the highest in the nation.
In 1972, coal accounted for 99.4% of the fossil fuel burned in Ohio
power plants. Therefore, there is little opportunity to conserve oil or
natural gas through conversions from the use of these fuels to coal.
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3.0 AIR QUALITY CONTROL REGION ASSESSMENTS
3.1 General Methodology
The previous section having set the background for the State Implementa-
tion Plan and evaluated the current air quality situation, this section will
review the available information for each AQCR to determine the feasibility
of relaxing 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 situa-
tion to confirm or dispute any of these findings prior to submitting any
SIP revisions. In Ohio, EPA has already begun this analysis. (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 S02, 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 Mainten-
ance Area designations, (4) total emissions, (5) portion of emissions from
the state's fuel combustion sources, (6) regional emission reduction
required (based on rollback calculations), and (7) pollutant priority
classification. Note that this 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.
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The second consideration for each AQCR is the power plant assessment
and this data is summarized in the tables in Appendix C. All existing and
proposed plants are reviewed to estimate the emission reductions to be
achieved by the imposition of existing regulations. (The proposed Ohio
regulations, although not approved by EPA, are used for this analysis
since they represent the most recent standards.) The clean fuel require-
ment is determined at the same time. Where dispersion modeling data are
available, 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 S02 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 consumption for new units coming 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 nation-
wide 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 deter-
mined 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 data1*,5 are drawn from both
published and unpublished sources.
The third consideration for each AQCR is the assessment of large
industrial/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 Emission Data System (NEDS) file.5 No individual source modeling
data were available.
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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 to be a good candidate for emission limit regulation revi-
sion 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 revi-
sion.
' The detailed evaluation being carried out by EPA will confirm or
correct these assessments. This initial review provides an initial
focus for the detailed study.
3.2 Cincinnati Interstate AQCR (#79)
3.2.1 Particulates
This interstate AQCR accounts for a significant fraction (11% or
269,000 tons/yr) of Ohio TSP emissions, of which 8% or 188,000 tons/yr
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are in the Ohio portion of the region; fuel combustion emissions contribute
86% of the Ohio total, with 40% attributable to power plants.3 Air quality
conditions in the region indicate that a large reduction in fuel combustion
emissions in Ohio is required to meet NAAQS. All four counties in this
AQCR have been proposed as TSP AQMAs.C Existing regulations applied to
power plants and significant point sources appear to be sufficient to
meet much of the required reduction; however, eliminating the required
amount of area source fuel combustion emissions will require replacing
a significant amount of current coal use by clean fuels (oil and/or
o
natural gas). For this reason, it is suggested that this region be
analyzed further to determine: (1) the major factors contributing to
the TSP problem in the region, and (2) the potential for tightening regu-
lations for source categories where source control technology is tech-
nically and economically feasible. Also, such an analysis should assess
the trend toward area source conversions to clean fuels and the various
markets for alternative fuels in the region. Pending further investi-
gation, this region must be classified as a poor candidate for TSP regu-
lation revision.
3.2.2 S02
This AQCR accounts for a significant fraction of the Ohio SO- emissions
(111 or 487,000 tons/yr), of which 7% or 305,000 tons/yr are in the Ohio
portion of the region; fuel combustion sources contribute 93% of the Ohio
total, with 76% attributed to power plants. Air quality conditions in
the region indicate that some tolerance for SO- emissions increase exists,
modeling results show that only small savings in clean fuels could be achieved
to Tables A-5 and A-6.
bRefer to Table A-8.
Slefer to Table A-l.
dRefer to Tables C-2 and D-2.
eRefer to Table E-l.
Refer to Tables A-5 and A-7.
%efer to Table A-4.
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26
if NAAQS are to be met.a Therefore, this region is classified as a poor
candidate for SCL regulation revision.
3.3 Portsmouth-Ironton interstate AQCR (TIP 3)
3.3.1 Participates
This interstate AQCR accounts for a moderate fraction (7% or 167,000 tons/
yr) of the Ohio TSP emissions, of which 31 or 64,000 tons/yr are due to Ohio
sources. Fuel combustion emissions account for only 33% of the Ohio total.
Air quality conditions in the region indicate that a significant fractional
reduction in TSP emissions will be required to meet NAAQS. While power plants
in this region appear to be well controled, the problem is compounded by the
addition of a major new power plant CGavin); this implies, even with existing
regulations, that only a small fractional reduction will be achieved in the
utility sector. Only one major point source of TSP fuel combustion emissions
exists in the region and existing regulations will achieve the required reduc-
tion. Area sources in the region contribute a relatively small fraction of the
regional total TSP emissions and probably will be eliminated by fuel switching
to oil or natural gas. Because the increase in utility emissions due to the
Gavin plant will offset most of the gains made by existing regulations, this
region is classified as a poor candidate for TSP regulation revision.
3.3.2 S02
This AQCR accounts for a significant fraction of the Ohio SO-? emissions
(9% or 401,000 tons/yr), of which 6% or 260,000 tons/yr are in the Ohio portion
of the region. Fuel combustion sources contribute 98% of the Ohio total, of
which 93% are attributable to power plants. Air quality conditions indicate
that the region has a significant tolerance for S02 emissions increase. Also,
modeling results show that some regulation relaxation is possible and
a significant savings of clean fuels can be realized if coal blending is
practiced on a large scale. Therefore, this region can be classified as a
aRefer to Table F-l.
Blending of high sulfur (72%) and low sulfur (< 1%) coal might be necessary
to achieve significant quantities of moderate sulfur (1-21) coal.
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good candidate for S02 regulation revision. The significant amount of coal
consumed in this region for power generation (16.5 x 10 tons/yr) suggests that
it receive close scrutiny in further analyses.
3.4 Toledo Interstate AQCR C#124)
3.4.1 Participates
This interstate AQCR accounts for a moderate fraction of Ohio TSP emissions
(51 or 122,000 tons/yr), of which 3% or 67,000 tons per year are due to Ohio
sources. Fuel combustion emissions contribute 511 of the Ohio total. Air qual-
ity conditions in the region indicate that moderate reduction in these emission
levels is necessary to meet NAAQS. Both counties in this AQCR have been pro-
posed as TSP AQMAs. The two power plants in the region appear to be well con-
trolled and little or no added reduction will be achieved by existing regula-
tions. Further, these plants are contributing an insignificant portion of the
region's total fuel combustion TSP emissions. Large point sources apparently
will achieve the required reduction when existing regulations are applied to
them, but these plants do not appear to constitute the major problem. Small,
distributed industrial/institutional/commercial sources and area sources
appear to constitute the bulk of the problem in this region. These sources
will probably have to be controlled by fuel switching; no opportunity to
relax regulations appears to exist if the required reduction to meet NAAQS is
to be achieved. Therefore, this region is a poor candidate to revise TSP
regulations.
3.4.2 SO,
Lt
This AQCR accounts for a moderate fraction of Ohio S02 emissions (6% or
256,000 tons/yr), of which 41 or 192,000 tons/yr are in the Ohio portion of the
region. Fuel combustion sources account for 77% of the Ohio total, with 41%
attributable to power plants. Air quality conditions in the region indicate
that a large tolerance for S02 emissions increase exists. Modeling results
indicate that a moderate potential for clean fuel savings are possible with
additional savings possible if coal blending is utilized. Therefore, this AQCR
is considered a good candidate for S0? emission regulation revision.
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\
3.5 Dayton Intrastate AQCR (#175)
3.5.1 Particulates
This region accounts for a moderate fraction of the Ohio TSP emissions
(7% or 177,000 tons/yr). Fuel combustion emissions contribute 39% of this
total, with 231 attributable to area sources. Air quality conditions in the
region indicate a significant reduction in fuel combustion TSP emissions is
required to meet NAAQS. Three of the six counties have been proposed TSP
AQMAs in this AQCR. Existing regulations applied to power plants and major
fuel combustion sources appear to be marginally adequate to meet the required
reductions. Area sources are potentially the problem in this region and pre-
sumably will be handled by fuel switching. For these reasons, this AQCR is
judged a poor candidate for TSP regulation revision.
3.5.2 S02
This AQCR accounts for only a small fraction of the S02 emissions in Ohio
(2% or 106,000 tons/yr). Fuel combustion emissions account for 911 of this total
with 611 attributable to power plants. Air quality conditions in the region
would appear to require a significant reduction in S09 emissions to meet NAAQS.
Lt
Three of the six counties in this AQCR have been proposed as S02 AQMAs. This
result appears to be somewhat inconsistent with the relatively small levels of
S02 emissions in the region. Further, modeling, results would indicate that a
substantial clean fuel savings could be realized if emission regulations are
revised. However to achieve these savings, 1971 fuel use patterns which con-
sumed mostly low sulphur coals would have to be reversed. Therefore, this re-
gion is judged to be a marginal candidate for SO, regulation revision pending
the resolution of the inconsistencies in air quality and emission data and a
further investigation of fuel supplies to the region.
3.6 Cleveland Intrastate AQCR (#174)
3.6.1 Particulates
This region accounts for a significant fraction of the Ohio TSP emissions
(15! or 360,000 tons/yr). Fuel combustion emissions contribute a major fraction
of this total (73%), with 42% attributable to area sources. Air quality condi-
tions in the region indicate that a significant reduction in fuel combustion TSP
emissions is required to meet NAAQS. Seven counties in this AQCR have been
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29
proposed as TSP AQMAs. Existing regulations applied to power plants and major
fuel combustion sources in the region do not appear to be adequate to produce
sufficient reductions to meet NAAQS, Likewise, since a significant amount of
high sulphur coal is being consumed by area sources in this region, TSP emis-
sions from these sources must presumably be controlled by a shift to clean fuels
(oil or natural gas). All indications are that TSP regulations cannot be relaxed
if NAAQS are to be met.
3.6.2 S02
This AQCR accounts for a major fraction of S02 emissions in Ohio (17% or
732,000 tons/yr). Fuel combustion emissions account for 92% of this total with
41% attributable to power plants, 30% attributable to major point sources, and
21% due to area sources. Air quality conditions in this region indicate that
there is little tolerance for SOo emission increase. Seven counties in
this AQCR have been proposed as S02 AQMAs although the region does
have a 1975 expected attainment date for S02 standards. However, modeling
results seem to indicate a substantial potential for clean fuel savings, par-
ticularly if coal blending is feasible. These results appear to be somewhat
contradictory and require further analysis. Therefore, this region is
considered a marginal candidate for S02 regulation revision pending further
investigation.
3.7 Mansfield-Marion Intrastate AQCR (#175)
3.7.1 Particulates
This region accounts for a very small fraction of the Ohio TSP emissions
(2% or 46,000 tons/yr). Fuel combustion emissions contribute approximately half
of these emissions with 33% attributable to area sources (no power plants are in
this region). Air quality conditions indicate that a moderate reduction in
these emissions is required to meet NAAQS. One of the nine counties has been
proposed as a TSP AQMA, although only three monitoring stations exist in the
region. Existing regulations appear to be more than adequate to achieve required
reductions. Area sources will presumably be controlled by shifts to clean fuels.
Some relaxation of regulations in this region appears possible but little sig-
nificant fuel savings would result; therefore, this AQCR is classified as a poor
candidate for TSP regulation revision.
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3.7.2 S02
This AQCR accounts for a very small portion of S07 emissions in Ohio (1%
£*
or 52,QOQ tons/yr). Fuel combustion emissions contribute 92% of this total
with. 481 attributable to major point sources (there are no power plants in this
region). Air quality conditions indicate that a large tolerance for S02 emis-
sion exists in this region. Some potential for clean fuel savings exists if
regulations for major point sources and area sources could be relaxed to allow
the burning of high sulphur coals. However, no modeling results are available
at this time to assess the extent of savings or the limits of new regulations
for these sources. Therefore, it is judged as a poor candidate for S02 regula-
tion revision due to the relatively small savings that could be realized even
if regulations were revised in this AQCR.
3.8 Columbus Intrastate AQCR (#176)
3.8.1 Particulates
This region accounts for a moderate fraction of the Ohio TSP emissions
(5% or 110,000 tons/yr). Fuel combustion emissions contribute 751 of this
total with 32% attributable to area sources and 29% attributable to power
generation. Air quality conditions indicate that a substantial reduction in
these emissions is required to achieve NAAQS. One of eight counties have been
proposed as TSP AQMAs in this AQCR. Existing regulations applied to power
plants and major point sources appear to be more than adequate to meet required
emission reductions, while area sources, again, appear to require fuel switching
to achieve required levels of control. Although there appears to be some flex-
ibility to relax TSP regulations applied to major point sources, the existence
of a TSP maintenance area designation in this AQCR would argue against this
action. Therefore, this AQCR is judged as a poor candidate for TSP regulation
revision.
3.8.2 S02
This AQCR accounts for a small fraction of the S02 emissions in Ohio (21
or 96,000 tons/yr). Fuel combustion emissions contribute 95% of this total; they
are evenly distributed between power plants, major point sources, and area sources.
A
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31
modest potential for clean fuel savings exists in this region; therefore, it
is classified as a good candidate for S02 regulation revision.
3.9 Northwest Ohio Intrastate AQCR (#177)
3.9.1 Particulates
This AQCR accounts for only a very small fraction of the Ohio TSP emis-
sions (21 or 47,600 tons/yr). Fuel combustion emissions contribute 791 of
this total with 493 attributable to area sources. No TSP monitoring stations
exist in this region by which to judge air quality. Thus, while no basis now
exists for judging the candidacy of this AQCR for TSP regulation revision,
some moderate savings in clean fuels would result if it could be determined
that area sources in the region could continue to burn high sulphur coal with-
out violating TSP NAAQS. Therefore, this region is judged to be a marginal
candidate for TSP regulation revision.
3.9.2 S02
This region accounts for a very small fraction of the Ohio S02 emissions
(1% or 51,000 tons/yr). Fuel combustion emissions contribute 761 of this total
with 401 attributable to area sources. Air quality conditions indicate that
there is a large tolerance for S02 emissions in this region. Modeling results
indicate that the small amount of power generation coal use in the region could
be high sulphur. If it can be shown that existing area sources can also con-
tinue to consume high sulphur coal without threatening standards, a moderate
clean fuel savings can be achieved. Therefore, this region is judged to be a
good candidate for S02 regulation revision.
3.10 Youngstown Interstate AQCR (#178)
3.10.1 Particulates
This interstate AQCR accounts for a significant fraction of the TSP emis-
sions in Ohio (14$ or 320,000 tons/yr), of which 8% or 189,000 tons/yr are due
to Ohio sources. Fuel combustion emissions account for 57$ of the Ohio total,
with 32% attributable to major fuel combustion point sources. Air quality con-
ditions in the region indicate that a substantial reduction in TSP emissions
will be required to meet NAAQS. Two of three counties in this AQCR have been
proposed as TSP AQMAs. Existing regulations applied to power plants and
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32
major point sources in the region appear to he more than adequate to meet the
required reductions. Area sources will presumably achieve reductions by fuel
switching to clean fuels. While regulations may be somewhat overrestrictive,
little clean fuels savings could result by relaxation. Therefore, this region is
is classified as a poor candidate for TSP regulation revision.
3.1Q.2 S02
This region accounts for a significant fraction of the S02 emissions in
Ohio (12% or 533,000 tons/yr); however, only 5% or 238,000 tons/yr are due to
Ohio sources. Fuel combustion emissions account for 93% of the Ohio total,
with 46% due to power production and 36% attributable to other major point
sources. Air quality conditions in the region indicate that no tolerance for
S02 emissions increase exists. However, this is somewhat misleading as refer-
ence to Table A-4 will indicate. Since the second highest 24-hr reading was
unavailable to estimate tolerance, the highest reading was used which lead to
the conclusion that no emission tolerance was available. However, the highest
annual average air quality concentration in the region is the lowest in the
state which would lead to the conclusion that a large tolerance for emissions
increase probably exists. Further, modeling results indicate that significant
clean fuel savings can be achieved by relaxing emissions. Therefore, conditional
on more definitive air quality results, this region is judged to be a marginal
candidate for S02 regulation revision.
3.11 Marietta Interstate AQCR (#179)
3.11.1 Particulates
This interstate AQCR accounts for a moderate fraction of the Ohio TSP emis-
sions (4% or 91,000 tons/yr), of which 8% or 82,000 tons/yr are due to Ohio
sources. Fuel combustion emissions account for 94% of the Ohio total, with
76% attributable to power generation. Air quality conditions in the region
indicate that a moderate tolerance for TSP emissions increase exists. However,
since area sources consume only a small amount of coal in this region, insig-
nificant fuel savings will result from a regulation revision. Therefore, this
AQCR is. judged a poor candidate for TSP regulation relaxation.
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3.11.2 S02
This region accounts for a significant fraction of the Ohio S02 emissions
(14% or 533,QQG tons/yr), of which 9% or 416,000 tons are due to Ohio sources.
Fuel combustion emis.sions account for virtually 100% of the Ohio total, of which
60% are attributable to power plants and 39% are due to other major point sources.
Unfortunately, no air quality data is available in this region to assess the
potential SO? emissions tolerance. Modeling results indicate that a moderate
amount of fuel savings may be realized. Therefore, this region is classified
as a marginal candidate for relaxation pending further analysis.
3.12 Sandusky Intrastate AQCR (#180)
3.12.1 Participates
This region accounts for a moderate proportion of the Ohio TSP emissions
(4% or 90,000 tons/yr). Fuel combustion emissions account for only 12% of the
Ohio total. Therefore, there is no benefit to be gained from revising TSP regu-
lations in this region and it is classified as a poor candidate for such action.
3.12.2 S02
This region accounts for a moderate proportion of the Ohio S02 emissions
(5% or 226,000 tons/yr). However, only 9% are attributable to fuel combustion
sources in this AQCR. Little clean fuel savings can be derived in this region
due to revision of the S02 regulations.
3.13 Steubenville Interstate AQCR (#181)
3.13.1 Participates
This interstate AQCR accounts for a moderate fraction of the Ohio TSP
emissions (5% or 124,000 tons/yr), of which 4% or 96,000 tons/yr are due to
Ohio sources. Fuel combustion emissions account for 90% of the Ohio total
with 60% attributable to power plants. Air quality conditions in this region
indicate that a significant reduction in TSP emissions is required to meet
NAAQS. Three of four counties in the AQCR have been designated as TSP AQMAs.
Existing regulations applied to power plants and major point sources in the
region appear to be marginally adequate to meet required reductions. Only
insignificant clean fuel savings could result from relaxing regulations on area
sources. Therefore, this region is judged a poor candidate for TSP regulation
revision.
-------
34
3.13.2 S02
This region produces a major fraction of S02 emissions in Ohio (17% or
737,000 tons/yr), of which. 13% or 560,000 tons/yr are due to Ohio sources.
Virtually all S02 emissions in Ohio are due to fuel combustion sources, of
which 93% are attributable to power generation. Air quality conditions in the
region indicate that a moderate reduction in S09 emissions is required to meet
Lf
NAAQS, and three S02 AQMA proposals exist in the region. Modeling results do,
however, indicate a modest potential for clean fuel savings if coal blending
is practiced. This region is considered a marginal candidate for SO- regulation
revision pending further study.
3.14 Wilmington-Chillicbthe Intrastate AQCR (#182)
3.14.1 Particulates
This AQCR accounts for a small fraction of the Ohio TSP emissions (2% or
58,000 tons/yr). Fuel combustion emissions contribute for 63% of the total,
with 471 attributable to major point sources (there are no power plants in this
region). No TSP monitoring stations exist in this region by which to judge air
quality. Very little clean fuel savings would result from TSP revision in this
region; therefore it is judged a poor candidate for such action.
3.14.2 S02
This region accounts for a very small fraction of Ohio S02 regulations
(1% or 47,000 tons/yr). Fuel combustion accounts for only 45% of this total
with 34% due to major point sources. No S02 monitoring stations exist in this
region by which to judge air quality. Very little clean fuel savings could
result from S02 regulation in this region; therefore, it is judged a poor candi-
date for such action.
3.15 Zanesville Intrastate AQCR (#185)
3.15.1 Particulates
This region accounts for a significant fraction of the Ohio TSP emissions
(16% or 383,QQQ tons/yr). However, fuel combustion emissions contribute only
16% of the total, with 13% attributable to power generation. No TSP monitoring
stations exist in the region by which to judge air quality. Little clean fuel
-------
35
savings could result in this region by revising TSP regulations; therefore,
it is judged a poor candidate for such action.
3.15.2 S02
This PQCR accounts for a moderate fraction of Ohio S02 emissions (5% or
203,000 tons/yr). Fuel combustion emissions account for virtually all of the
total, with 891 attributable to power plants. No SC>2 monitoring stations exist
in the region by which to judge air quality. However, modeling results indicate
a significant clean fuel savings potential exists in the region; therefore, it
is judged a good candidate for SC>2 regulation revision.
-------
36
-------
APPENDIX A
State Implementation Plan Background
-------
38
-------
TABLE A-l. Chio Air Pollution Control Areas
Demographic Information
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
Air Quality
Control Region
Cincinnati (Ky.-Ind.)
Portsmouth- Iron ton
(Ky.-W.Va.)
Toledo (Michigan)
Dayton
Cleveland
Mansfield-Marion
Colimbus
Northwest Chio
Youngstown, (Penn. )
Marietta (W. Va.)
Sandusky
SteubenvUle (W.Va.)
Wilmington-Chilli co the-
Logan
Zanesville
Federal
'Number
079
103
124
173
174
175
176
177
178
179
180
181
182
183
Population
1975
(Millions)
.60
.69
1.06
3.38
.49
1.18
.59
1.60
.29
.29
.47
.22
.28
Area
(Square
Miles)
3816
8148
1519
2715
3493
4054
3990
6521
12267
3578
1982
2516
3744
3499
Population
Per Square
Mile
435
74
457
390
969
120
296
91
131
81
144
188
60
79
Priority
Classification
Parti-
culates
I
I
I
I
I
II
I
II
I
I
III
I
III
II
sox
II
III
I
II
I
II
III
I
II
II
III
I
III
II
NOX
I
III
I
I
I
III
I
III
III
III
III
III
III
III
(4)
(0)
(2)
(3)
(7)
(1)
CD
(0)
(2)
(0)
(0)
(3)
(0)
CO)
Proposed
AQMH Designations
TSP Counties
Hamilton, Clermont, Butler, Warren
Lucas, Wood
Montgomery, Greene, Clark
Summit, Portage, Cuyahoga, Lake
Geauga, Stark, Lorain
Richland
Franklin
Trumbull, Mahoning
Jefferson, Belmont ,Colunbiana
SOX Counties
(0)
(0)
CO)
(3) Montgomery, Greene, Clark
(7) Summit, Portage, Cuyahoga, Lake,
Geauga, Stark, Lorain
CO)
(0)
(0)
(0)
(0)
CO)
(3) Jefferson , fielmont , Columbians
(0)
(0)
to
aAs of November 14, 1974
-------
40
-------
41
TSP DESIGNATION
S02 DESIGNATION
LEGEND
() Pl«cet of 100.000 or more mhiMwitt
PlKtl ol 50.000 to 100.000 mlKMtnli
D Ctntnl ot>M ol SMSA i with Ifwif thin 50.0OO
O PlKtt ot 75.0OO lo SO.OOO inhibiUntt outtidt SMSA'i
Sl»nd*d Mttropolilin
Slilnticd IttK ISMSA i|
Fig. A-l. Ohio Air Quality Maintenance Area (AQMA) Designations
-------
42
-------
TABLE A-2. Ohio Ambient Air Quality Standards
All concentrations in ygms/m3
Federal
(Nov. 1972)
State
(May 30, 1974)
Primary
Secondary
Total Suspended
Annual
75 (G)
60 (G)
60 (G)
July 1,
Particulate
24-Hour
260a
150a
150a
1975
Annual
80 (A)
60(A)b
Sulfur Oxides
24-Hour
365a
260b'c
July 1, 1977
3-Hour
1300a
1300
Nitrogen Dioxide
Annual
100 (A)
100 (A)
100 (A)
Not to be exceeded more than once per year.
Based on the original Federal secondary standards which have since been rescinded.
Slot to be exceeded more than II of the time.
(A) Arithmetic mean
(G) Geometric mean
-------
44
-------
TABLE A-3. Ohio AQCR Air Quality Status, TSP3
TSP Concentration
(wgm/m3)
Number of Stations Exceeding
Ambient Air Quality Standards
2nd Highest
Highest Reading Reading Primary
AQCR No. Stations
No. Reporting Annual 24-Hr
1. 79b
2. 103b
3. 124b
4. 173
5. 174
6. 175
7. 176
8. 177
9. 178b
10. 179b
11. 180
12. 181b
13. 182
14. 183
a!973 air quality
blnterstate.
Violations based
'rormula:
55
40
21
28
83
3
14
0
10
3
5
35
0
0
166
96
77
98
177
51
53
...
92
...
187
...
---
450
349
427
367
610
296
326
...
695
124
953
621
---
data in National Air Data Bank as
on 2nd
highest
ft
24-Hr
351
239
203
352
531
262
321
...
561
115
753
574
...
...
Annual 24-Hrc
9
5
2
2
21
0
0
-
1
0
0
15
-
-
2
0
0
1
14
1
1
-
2
0
2
10
-
-
Secondary
Annual %
32
12
3
8
46
0
0
-
1
0
0
16
-
-
58
30
14
29
55
0
0
-
10
0
0
46
-
-
24-Hrc
14
8
5
5
45
2
4
-
5
0
4
25
-
-
4 Reduction Required
to Mset Standards'1
t
25
20
24
18
54
68
29
-
50
0
80
71
-
-
+ 81
+ 59
+ 40
+ 64
+ 85
+ 49
+ 60
-
+ 78
- 44
+ 84
+ 84
-
-
Controlling
Standard
Annual
Annual
Annual
24-Hr
Annual
24 -Hr
24-Hr
24-Hr
24-Hr
24-Hr
24-Hr
of June 7, 1974.
reading at any station.
'2nd Highest 24-Hr -
24-Hr
Secondary
Standard \
x 100.
/Annual
- Annual
Secondary
StandardN f .
,
Cn
ttuc
2nd Highest 24-Hr - Background J V Annual - Background I
Ohio particulate background: 35 wgm/m3 except Cleveland (40 ugm/m3)
-------
46
-------
TABLE A-4. Ohio AQCR Air Quality Status, SO3,
SO, Concentration
AQCR
No.
1. 79b
2. 103b
3. 124b
4. 173
5. 174
6. 175
7. 176
8. 177
9. 178b
10. 179*5
11. 180
12. 181b
13. 182
14. 183
a!973 air quality
Interstate.
""Violations based
hormula:
No. Stations Reporting
24-Hr
3"2
17
3
16
48
1
1
1
4
0
0
14
0
0
Continuous
3
1
6
6
4
0
1
0
1
0
0
0
0
0
data in National Air Data
on 2nd
highest reading at
r
Highest Reading
Annual
55
28
41
117
77
24
-
---
18
...
...
106
...
---
24-Hr
203
429
224
991
414
103
99
131
378
...
432
...
Bank as of June 7,
2nd Highest * Reduction Required Controlling
Reading Primary Secondary to Meet Standards" Standard
24-Hr Annual 24-HrC 3-Hrc
141 00 0
178 00 0
82 00 0
789 11 0
215 00 0
93 00
43 00 0
120 00
378e 01 0
.
.
403 11
.
.
1974.
any station.
\ {2nd Highest 24-Hr -
V 2nd Highest
24-Hr StandardX\ lnn /Annual - Annual Standard \ _ lnn
24-Hr
; * """ V Annual 1 * ""
- 45 Annual
- 105 24-Hr
- 95 Annual
+ 54 24-Hr
- 4 Annual
- 233 Annual
- 749 24-Hr
- 204 24-Hr
+ 3 24-Hr
...
...
+ 25 Annual
Highest reading used because 2nd highest reading was unavailable.
-------
48
-------
TABLE A-5. Olio Fuel Combustion Source Summary
Total Emissions"
% Emissions from
AQCR
No.
79e
103e
124e
173
174
175
176
177
178e
179e
180
181e
182
183
Total
Power Other Fuel Combustion Area (10 3 tons/year) Ohio Fuel Coni
Plants Point Sourcesb Sources TSP S02 TSP
4
2f
2
4
6
0
1
1
2
2
0
5
0
2
31
15
1
5
6
38
11
13
9
10
1
4
4
2
0
119
4
5
2
6
8
9
8
15
3
4
5
4
8
7
88
269
167
122
177
360
46
110
47
320
91
90
124
58
383
2,364
487
401
256
106
732
52
96
57
533
481
226
737
47
203
4,414
60
19
28
39
73
57
75
79
33
85
13
70
63
16
--
>ustion Sources
so2
58
64
57
91
92
98
95
76
42
86
9
75
95
99
--
plants
bOhio plants contributing 90% of the particulate and S02 emissions
C0hio counties
dAQCR total
Interstate
f Additional plant scheduled for 1974-75
-------
50
-------
TABLE A-6. Ohio Bnissions Summary3, TSP
AQCR
79 Ohio
Other
Total
103 Ohio
Other
Total
124 Ohio
Other
Total
173.
174
175
176
177
178 Ohio
Other
Total
179 Ohio
Other
Total
180
181 Ohio
Other
Total
182
183
Total
Total
(103 tons/yr)
188
81
269
64
103
167
67
55
122
177
360
46
110
47
189
131
320
82
9
91
90
96
28
124
58
383
2364
%
8
3
11
3
4
7
3
2
5
7
15
2
5
2
8
6
14
3
1
4
4
4
1
5
2
16
100
Electricity Generation
(103 tons/yr) *
76
56
132
12
86
98
4
18
22
18
31
1
32
7
11
14
25
62
9
71
0
58
25
83
0
49
569
40
69
49
19
83
59
6
33
18
10
9
2
29
15
6
11
8
76
100
.78
0
60
89
67
0
13
24
Indus trial/Commercial/
Institutional Point Source
(103 tons/yr) %
37
3
40
4
4
8
14
13
27
11
78
10
15
7
60
21
81
10
0
10
. 1
18
0
18
27
3
336
20
4
15
6
4
5
21
24
22
6
22
22
14
15
32
16
25
12
0
11
1
19
0
15
47
1
14
Ar.ea Source
(103 tons/yr) %
49
2
51
5
3
8
16
1
17
41
151
15
35
23
36
51
87
S
0
6
11
11
0
11
9
9
474
26
2
19 .
8
3
5
24
2
14
23
42
33
32
49
19
40
27
6
0
7
12
11
0
9
16
2
20
aEmissions in data bank as of June 27, 1974.
-------
52
-------
TABLE A-7. Ohio Bnissions Summary3, SO,
AQCR
79 Ohio
Other
Total
103 Ohio
Other
Total
124 Ohio
Other
Total
173
174
175
176
177
178 Ohio
Other
Total
179 Ohio
Other
Total
180
181 Ohio
Other
Total
182
183
Total
Total
(103 tons/yr)
305
182
487
260
141
401
192
64
256
106
732
52
96
57
238
295
533
416
65
481
226
560
177
737
47
203
4414
%
7
4
11
6
3
9
4
2
6
2
17
1
2
1
5
7
12
9
5
14
5
13
4
17
1
5
100
Electricity Generation
(103 tons/yr)
232
173
405
241
124
365
79
54
133
61
298
7
33
6
110
173
283
248
64
313
3
520
174
694
0
180
2781
%
76
95
83
93
88
91
41
84
52
58
41
13
34
11
46
59
53
60
98
65
1
93
98
94
0
89
63
Industrial/Conmercial/
Institutional
(103 tons/yr)
28
5
33
9
6
15
55
7
62
15
217
25
31
14
86
69
155
161
0
161
5
17
0
17
34
8
792
Point Source
*
9
3
7
3
4
4
29
11
24
14
30
48
32
25
36
23
29
39
0
33
2
3
0
2
72
4
18
Area Source
(103 tons/yr)
23
4
27
5
5
10
13
2
15
20
155
19
28
23
26
49
75
5
1
6
13
19
2
21
11
13
436
*
8
2
6
2
4
3
7
3
6
19
21
37
29
40
11
17
14
1
2
1
6
3
1
3
23
6
10
en
aEmissions in data bank as of June 27, 1974
-------
54
-------
TABLE A-8. Ohio AQCR Required Emission Reduction3
Required Particulate Emission Reduction Required SC>2 Emission Reduction
% 105 tons/year
AQCR
79b
103b
124b
173
174
175
176
177
178b
179b
180
181b
182
183
%
+81
+59
+40
+64
+85
+49
+60
-
+78
-44
+84
+84
-
m*
10 tons/year
+218
+ 99
+ 49
+113
+306
+ 23
+ 66
-
+250
- 40
+ 76
+104
-
- 45
-105
- 95
+ 54
- 4
-233
-749
-204
+ 3
-219
-421
-243
+ 57
- 29
-121
-719
-116
+ 16
+ 25
+185
Biased on a proportional change of emissions to air quality. This type of "rollback1
calculation is not recognized as an accurate measure of emission tolerances; it is
used only as an indicator here.
Interstate
Cn
cn
-------
56
-------
TABLE A-9. Ohio Fuel Combustion Emission Regulations
Existing Facilities New Facilities
so2
< 250 x 106 Btu/hr
County Emission
Limit: Fig. A- 2
> 250 x 106 Btu/hr
Priority Region
Emission Limit:
Table A- 10
> 100 x 106 Btu/hr < 100 x 106 Btu/hr
1.0 lbs/106 Btu County Emission
Limit: Fig. A- 2
Particulates
All Facilities
Priority Region Emission Limit: Fig. A-3
Ol
-------
58
-------
59
CLER-
KS) /"£!"
LEGEND:
=1.0 pounds of sulfur dioxide
per million BTU of heat input
=1.6 pounds of sulfur dioxide
per million BTU of heat input
=3.2 pounds of sulfur dioxide
per million BTU of heat input
4.0 pounds of sulfur dioxide
per million BTU of heat input
4.8 pounds of sulfur dioxide
per million BTU of heat input
Figure A-2. Sulfur Dioxide Emission Limitations Specified in
OEPA Regulations HP-11-13(B)(1) - Table A-9.
-------
60
-------
61
TABLE A-10. Ohio S02 Priority Region Emission Limit for Existing Sources
with > 250 x 106 Btu/Hr Heat Input
AQCR
Emission Limit
(Ibs S02/106 Btu heat input)
103
176
180
182
3.2 (from July 17, 1972 - July 1, 1975)
1.0 (after July 1, 1975
79
173
175
178
179
124
174
177
181
183
1.6 (from July 17, 1972 - July 1, 1975)
1.0 (after July 1, 1975)
1.0
-------
62
-------
10 cii i 11 un
o
-------
64
-------
65
APPENDIX B
Regional Air Quality Assessment
-------
66
-------
TABLE B-l. Ohio PQCR Particulate Summary
Stations with Expected
Air Quality Federal Particulate Air Quality Attainment
Control Region Number Violations Date
Cincinnati3
Portsmouth- I ronton3
Toledo3
Dayton
Cleveland
Mansfield-Marion
Columbus
Northwest Ohio
Youngs town3
Marietta3
San dusky
Steubenville3
Wilmington-Chillicothe
Zanesville
79
103
124
173
174
175
176
177
178
179
180
181
182
183
3
3
2
1
6
2
1
_
3
0
2
4
-
7/75
7/75
7/75
7/75
1/77
7/75
7/75
-
1/77
-
7/75
1/77
-
-
Number of
Counties with
AQMA
Designations
4
0
2
3
7
1
1
0
2
0
0
3
0
0
-Total Particulate
Emissions
(103 tons/yr)
269
167
122
177
360
46
110
47
320
91
90
124
58
383
% Emissions
from Ohio Fuel
Combustion
60
19
28
39
73
57
75
79
33
85
13
70
63
16
Emission Reduction
Required for NAAQS
(103 tons/yr)
+218
+ 99
+ 49
+113
+306
+ 23
+ 66
+250
- 40
+ 76
+104
---
---
Particulate
Priority
1
1
1
1
1
2
1
2
1
1
3
1
3
2
Interstate
-------
68
-------
TABLE B-2. Ohio AQCR S02 Summary
1
Air Quality Federal
Control Region Number
Cincinnati3
Portsraouth-Ironton3
Toledo3
, Dayton
Cleveland
Mansfield-Marion
Columbus
Northwest Ohio
Youngs town3
Marietta3
Sandusky
Steubenville
. Wilmington-Chillicothe
Zanesville
79
103
124
173
174
175
176
177
178
179
180
181
182
183
Stations with SO,
Air Quality
Violations
0
0
0
1
0
0
0
0
1
-
-
1
-
-
Number of
Expected Counties with
Attainment AQMA
Date Designations
0
7/75 0
".
7/75 3
7
0
0
0
7/75 0
0
0
7/75 3
0
0
Total S02
Bnissions
(103 tons/yr)
487
401
256
106
732
52
96
57
533
481
226
737
47
203
% Emissions
from Ohio Fuel
Combustion
59
64
57
91
92
98
95
76
42
86
9
75
95
99
Emission Reduction
Required for NAAQS
(10 3 tons/yr
-219
-421
-243
+ 57
- 29
-121
-719
-116
+ 16
---
...
+185
...
...
Participate
Priority
2
2
1
2
i
1
2
3
1
2
2
3
1
3
1A
a
Interstate
-------
70
-------
71
APPENDIX C
Power Plant Assessment
-------
72
-------
TABLE C-l. Ohio
AQCR Plant
79 Municipal
Light
Beckjord
Miami Fort
West End
103d Gavin
Kyger Creek
Stuart
124 Aoned
Bay Shore
173 Mad River
Piqua
Hutchins
1975
Capacity
(Mw)
133.5
1221.3
893.2
219.3
2600.0
1086.0
2440.6
321.0
* 638.0
75.0
73.0
414
73
Power Plant Assessment
Estimated 1975 % Sulphur
Fuel Use SIP u
Fuel
Coal
Oil
Gas
Coal
Oil
Coal
Gas
Coal
Coal
Coal
Oil
Coal
Oil
Gas
Coal
Oil
Coal
Coal
Oil
Coal
Gas
Quantity Regulations
193.2 .56
46.5
1404.7
2794.1 .55
59.4
2360.1 .52
5470.1
773.8 .30
3051.0 .61
5672.3 .59
41.8
394.0 .6
164.0
863.0
1617.8 .6
20.6
130.1 .9
125.6 .8
.4
677.8 .4
133.5
1 Sulphur
Allowed
by Model
.75
.6
1.4
1.0
2.0
1.3
2.6
1.5
1.6
.9
.9
Tait
448.6
Coal
728.6
1.46
-------
74
-------
75
TABLE C-l. Ohio Power Plant Assessment
AQCR Plant
174 Avon Lake
Edgewater
East Lake
,
Lake Shore
Cleveland
Municipal
Gorge
1975
Capacity
(Mw)
1275
192.9
1257.0
514.0
208.6
87.5
Estimated 1975
Fuel
Fuel
Coal
Oil
Coal
Coal
Oil
Coal
Oil
Coal
Oil
Coal
Use
Quantitya
2475.3
118.7
337.8
2339.2
17.4
1224.7
13.2
190.2
188.5
245.5
(Contd.)
% Sulphur
SIP
Regulations
.56
.70
.43
.62
.57
.58
% Sulphur
Allowed
by Model0
2.7
2.8
2.1
1.3
2.6
175 None
176 Pickaway
177 Woodcock
178d Niles
Ashtabula
179 Poston
Muskingum
River
230.8
37.5
250.0
456.0
232.0
1529.6
Coal
Coal
Oil
Coal
Coal
Oil
Coal
Coal
Oil
271.0
52.1
11.5
1651
805.5
133.2
635.0
4061.9
35.4
.67
.72
.66
.41
.37
.54
2.5
3.0
2.8
3.0
1.3
1.4
180 None
181 Burger
Cardinal
Toronto
Sammis
Tidd
544.0
1230.5
. 175.8
2303.5
226.3
Coal
Coal
Oil
Coal
Coal
Coal
Oil
1243.3
2857.0
53.7
433.3
5241.3
495.8
18.3
.5
.5
.45
.6
.54
.6
1.5
2.4
1.1
.1
-------
76
-------
77
TABLE C-l. Ohio Power Plant Assessment (Contd.)
1975 Estimated 1975 ' '% Sulphur * Sulphur
AQCR Plant Capacity Fuel Use glp .Allowed
^ Fuel Quantitya.Regulationsb'by Model0
182 None
183 Conesville
Philo
1275.5
500.0
Coal
Coal
Oil
2171.0 .47 2.3
678.9 .55 1.1
8.4
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 % S
as was fired in 1972 was assumed for 1975. The maximum allowable % S is assumed to
be the 1971 I S unless the regulations require a lower \ S.
""Maximum allowable I S is assumed to be 1971 \ S unless modeling results show a lower
% S allowable.
Interstate
-------
78
-------
Table C-2. Ohio Power Plant Evaluation Sumnary
AQCR
79
103
124
173
174
175
176
177
178
179
180
181
182
183
SO
1975 Coal Required by 1975
SIP Regulations3 Emissions
(103tons/yr) Reduction^
2*S (103tons/yr)
5,347.4 176
16,461.3 152
2,011.8 64
1,662.1 39
6,812.7 411
0
271.0 18
52.1 " 2
1,456.7 95
4,696.9 385
0
10,270.7 486
0
2,849.9 169
2
1975 Coal Required by Modified 1975
Modified Regulationsc Emission
(103tons/yr) Reduction"1
flfl t"OTl^/VTl
j-Tftc 19JC , 9 8- C ^ * u +-V1 i^/ j 1 j
*-li»o l~i$o ^tto
2,987.3 2,360.1 124
16,461.3 -209
1,617.8 394.0 16
803.4 858.7 4
3,563.9 3,058.6 14S£
00 0
271.0 9
52.1 0
1,456.7 7
4,696.9 301
0
1,739.1 8,098.3 433.3 356
0
678.9 2,171.0 . 71
TSP
1975
Emission Reduction
by SIP Regulationsc
(10'tons/yr)
68
2
0
11
12
0
24
0.5
13
88
0
75
0
61
Fuel requirements based on 1971 fuel use patterns at 1975 consumption rates. If 1971 fuel data were unavailable,
1972 data were used. Coal quantity is 103 tons/yr, oil quantity is 103 gal/yr, gas quantity is 106 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 S as was fired in 1972 was assumed for 1975.
If actual fuels 4 S were unknown, state-wide averages were used.
Sbximum allowable 4 S is 1971 $ S unless modeling indicates a lower $ S. Oil and gas consumption are assumed to
remain constant.
'mission reduction from current emission rate.
eEmission reduction from current emission rates. Plants already at or below SIP requirements are assumed to
remain so. New plants are assumed to meet SIP regulations.
Modeling results not available for all plants.
-------
80
-------
APPENDIX D
Industrial, Commercial, Institutional Source Assessment
-------
82
-------
83
TABLE D-l. Ohio Industrial/Commercial/Institutional Source
AQCR Planta
79e Champion Papers
Air Force Plant
Sorg Paper
Armco
Philip Carey
Diamond
Factory PB
Ford (Sharon)
Proctor § Gamble
Butler Crystal
General Electric
Nat. Distillery
Container Corp.
Fox Paper
103e Allied Chemical
124e Standard Oil
Gulf Oil
Bowling Green
. Libbey-Owens
Toledo State Hospital
Fuelb
Coal
Coal
Oil
Coal
Coal
Coal
Coal
Coal
Coal
Coal
Coal
Coal
Coal
Coal
Coal
Coal
P Gas
N Gas
Oil
Coal
Coal
Coal
Estimated
Fuel
Consumption0
59,300
80,000
200
86,900
100,000
70,000
82,700
34,700
37,000
149,000-
30,000
70,000
13,700
28,000
27,400
150,000
19,875
975
50,850
21,600
61,000
16,000
Assessment
SIP
Regulations
% Sd
0.70
0.80
0.74
0.63
1.13
1.05
1.13
0.93
.71
1.13
1.14
1.15
1.13
1.13
.55
3.82
1.04
2.50
0.71
0.59
-------
84
-------
85
>
TABLE D-l. Ohio Indus trial/Commercial/Institutional Source Assessment (Contd.)
AQCR Planta
173 National Cash Register
Kimberly- Clark
Frigidaire GMC
General Motors
Central States Univ.
St. Regis Paper
174 PPG Industries
Firestone Tire $ Rubber
Goodyear Tire § Rubber
Chrysler Corp.
Republic Steel
(Cuyahaga Co.)
Republic Steel
(Stark Co.)
Transue § Vims.
B. F. Goodrich
Timken Bearings
IRC Fibers Division
B. F. Goodrich - Chm.
Alcoa
Diamond Crystal Salt
Fuelb
Coal
Coal
Gas
Coal
Coal
Gas
Coal
Coal
Coal
Coal
Coal
Gas
Coal
Coal
Oil
P Gas
N Gas
Coal
P Gas
Coal
Oil
Coal
Coal
Coal
Coal
Coal
Coal
N Gas
Estimated
Fuel
Consumption0
85,500
100,000
115,700
41,500
11,500
17,700
1,068,000
254,900
358,200
31,700
158,550
11,200
132,771
560
60,140
490
40,000
3,350
125,200
64,000
220,600
24,900
50,000
60,000
SIP
Regulations
% Sd
1.00
0.88
0.77
1.06
2.41
1.19
1.33
0.61
0.65
0.63
2.63
3.88
4.36
0.67
3.17
0.66
0.58
0.68
0.87
-------
86
-------
87
TABLE D-l. Ohio Industrial/CommerciaL/Institutional Source Assessment (Contd.)
AQCR Planta
174 Uniroyal Chemical
(Contd. )
Fisher Body
Hawthorn
Ford Motor Co.
G.E. Cleve Wire Plant
Standard Oil Ohio
Canton D. Fgs. M.
White Motors
Standard Oil Ohio
Chase Brass § Copper
Portjec Inc.
U.S. Steel
Post Office
Sugardale Foods
Ford Motor Co.
Outwait
Teledyne Rubber
NASA- Lewis Research Cntr.
Fisher Body
Perfection Stove
Fuelb
Coal
Oil
Coal
Coal
Coal
Coal
Gas
Coal
Oil
Coal
Coal
Coal
Gas
Coal
Gas
Lignite
Coal
Coal
Coal
Coal
Coal
Coal
Coal
Oil
N Gas
Coal
Coal
N Gas
Estimated
Fuel
Consumptionc
41,400
1,630
22,000
17,000
31,000
25,000
330
17,000
360
33,660
25,000
10,000
30,000
11,400
10,000
9,730
9,000
35,100
21,000
6,120
4,770
1,147
25,600
4,700
SIP
Regulations
% Sd
2.47
0.68
0.68
3.13
1.03
0.71
2.80
0.68
2.52
1.13
2.92
3.54
3.41
3.19
1.05
0.66
3.25
2.31
1.05
2.21
-------
88
-------
89
TABLE D-l. Ohio Industrial/Commercial/Institutional Source Assessment (Contd.)
AQCR Plant8
174 Union Metal Mfg.
(Contd. )
U.S. Steel
White Engines
Tecumseh Corrug.
V. A. Hospital
175 Package Copp. Am.
Inds. St.
Timken Co.
Mansfield Tire § Rubber
Empire- Detroit Steel
Morton Salt
Marion Power Shovel
Koppers Co.
J. M. Smucker
Apple Cr. St. Inst.
Fisher Body Div.
Central Soya
176 August Wagner Brewery
Defense Const.
Marble Cliffs Quaries
Col. Coated Fabrics
Loroco Ids.
Jeffrey Mining Mach.
Capital City Products
Fuelb
Coal
P Gas
N Gas
Coal
Coal
Coal
Coal
Coal
Coal
Coal
N Gas
Coal
Coal
Coal
Coal
Coal
Coal
Coal
Coal
Coal
Coal
Coal
Coal
Coal
Coal
Estimated
Fuel
Consumption0
13,000
32,100
7,350
12,000
14,610
162,000
11,500
31,950
26,400
70,400
7,730
4,000
6,440
22,000
24,280
10,500
13,200
20,000
16,700
26,800
12,000
13,400
24,900
SIP
Regulations
2.89
3.02
0.65
0.71
.61
3.27
1.02
. 4.73
1.01
2.62
1.01
.92
1.14
1.02
2.63
.63
2.18
3.18
1.84
2.84
1.93
1.92
-------
90
-------
91
TABLE D-l. Ohio Indus trial/Commercial/Institutional Source
AQCR Planta
176 Owens -Corning
(Contd. )
Crovm- Zellerach
Cont. Corp. of Am.
N. Am. Rockwell
Westinghouse Elec.
177 Standard Oil
Campbell Soup
Cooper Tire § Rubber
St. Mary's Municipal
Clark Equipment Co.
Good Year Tire § Rubber
St. Regis Paper
St. Regis Paper
Northern Ohio Sugar
178e Youngs town Sheet- Tube
Republic Steel
Fuelb
Coal
N Gas
Coal
Coal
Oil
Coal
N Gas
Coal
Gas
Oil
Coal
Oil
Coal
Coal
Coal
Coal
N Gas
Coal
Coal
Coal
Coal
Coke
P Gas
ROil
N Gas
Coal
P Gas
N Gas
R Oil
Estimated
Fuel
Consumption0
64,000
1,820
42,200
55,400
2,800
19,900
720
39,900
179,100
2,790
40,000
500
20,000
20,000
18,800
46,900
349
11,000
13,800
28,000
141,600
72,000
10,910
2,520
' 274
103,000
54,532
342
447
Assessment (Contd. )
SIP
Regulations
% sa
1.33
2.34
1.31
4.98
2.02
1.09
1.77
2.18
2.54
0.66
3.30
3.40
3.29
2.37
1.14
1.61
-------
92
-------
93
TABLE D-l. Ohio Industrial/Commercial/Institutional Source Assessment (Contd.)
AQCR Planta
178 Union Carbide
(Contd. )
U.S. Steel Corp.
Republic Steel
U.S. Steel
Wheeling-Pittsburgh
Steel
General Motors
Cabot Titania
Reactive Metals
179e Ohio Power Co.
180 New Deptr. -Hyatt
U.S. Gypsum Co.
Union Carbide
Ford Motor Co.
181e Wheeling- Pittsburgh
Steel
Federal Paper Board
Kaul Clay
Wheeling- Pittsburgh
Steel
182 Mead Papers
U.S. AEC
Fuelb
Coal
Coal
Coal
P Gas
R Oil
Coal
P Gas
R Oil
N Gas
Coal
N Gas
Coal
Coal
N Gas
Coal
Coal
Coal
Coal
Coal
Coal
Coal
Coal
Coal
Coal
P Gas
R Oil
Coal
Coal
Estimated
Fuel
Consumption0
812,000
28,000
34,200
69,211
423
18,200
60,200
5,620
905
15,030
322
9,180
22,000
503
38,400
1,480,000
20,900
22,500
11,000
22,400
56,500
50,000
47,400
45,250
101,610
1,770
381,300
45,900
SIP
Regulations
\ Sd
0.55
0.60
3.33
5.25
1.28
0.69
1.29
0.68
.50
1.06
2.80
2.21
1.05
0.69
0.61
0.71
6.44
0.54
2.87
-------
94
-------
95
TABLE D-l. Ohio Indus trial/Commercial/Institutional Source Assessment (Contd.)
Estimated SIP
Fuel Regulations
AQCR Planta Fuelb Consumption0 % Sd
183 NONE
aOhio plants contributing 90% o£ the AQCR's S02 and particulate emissions,.
Does not include plant or process gas.
cCoal' in 103 tons/yr, oil in 103 gals/yr.
"Tor 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 pri-
marily 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
-------
96
-------
AQCR
79d
103d
124d
173
174
175
176
177
178d
179d
180
181d
182
183
97
TABLE D-2. Ohio Industrial/Commercial/ Institutional
Source Evaluation Summary
Fuel S02
Fuel Required by Existing Regulations3 Emission Reduction^
< 1 %
Coal
Oil
Coal
Coal
Oil
Coal
Coal
Oil
Coal
Coal
Oil
Coal
Oil
Coal
Oil
Coal
Coal
Coal
Oil
Coal
None
512
200C
150
77
216
1255
17687
168
250
2800
19
500
808
9010
1480
154
381
1-2%
356
850
145
1184
152
184
40
2790
282
43
1770
> 2 %
22
12
515
57
163
140
34
45
46
(103 tons/yr)
4
7
3
4
2
88
14
13
0
58
136
2
3
26
0
Does 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.
£
Current SIP regulations require a minimum of 1% S oil.
Interstate
-------
98
-------
99
APPENDIX E
Area Source Assessment
-------
100
-------
TABLE E-l. Area Source Fuel Use
AQCR
79
103
124
173
174
175
176
177
178
179
180
181
182
183
Low Sulfur
(< 1%)
861
5
1
2
59
102
30
251
5
3
2
9
4
7
Coal (10 3 tons/yr)
Moderate Sulfur
d-2%)
195
51
399
821
52
458
97
239
High Sulfur
(> 2%)
68
3,830
276
193 .
499
310
78
224
248
162
238
Distillate Oil
(10 3 gals/yr)
180,440
33,040
67,060
92,490
602,220
68,430
123,400
131,740
80,280
15,810
30,460
41,610
37,290
35,800
Natural Gas
(106ft3/yr)
81,050
8,440
37,090
67,190
208,680
47,020
72,160
43,860
39,800
7,502
16,800
15,940
10,180
14,560
-------
102
-------
103
APPENDIX F
Fuels Assessment
-------
104
-------
TABLE F-l. Ohio Clean Fuels Analysis Summary
AQCR
79e
103C
124C
173
174
175
176
177
178C
179C
180
181C
182
183
Fuel
Goal
Coal
Coal
Coal
Coal
Coal
Coal
Coal
Coal
Coal
Coal
Coal
Coal
Coal
Existing Regulations
< 1% S
5859.4
16611.3
2088.8
1683.9
8067. 7
168.0
521.0
61.1
2344.7
6176.9
10424.70
381.0
2849.9
Clean Fuel Requirements3
1-2% S
356.0
145.0
1184.0
152.0
184.0
40.0
282.0
43.0
Modified Regulations
< 1% S
2987.3
150.0
77.0
1019.4
1255.0
168.0
250.0
19.0
888.0
1480.0
Clean Fuel Requirements15
1-2% S
12716.1
16461.3
1617.8
1003.7
4747.9
152.0
184.0
40.0
282.0
4696.9
43.0
1893.1
8098.3
381.0
678.9
power plant and industrial/commercial/institutional point sources only. Includes only that required and
not entire fuel consumption. Coal in 103 tons/yr.
Based on modeling results. 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
-------
106
-------
TABLE F-2. Projected-1975 Ohio Coal Use2
AQCR
79
103
124
173
174
175
176
177
178
179
180
181
182
183
State
Total
% of
Total
Power Plants
5347
16461
2012
1662
6813
0
271
52
1457
4697
0
10271
0
2850
51893
73
Industrial/Commercial/ Institutional
868
150
99
373
2954
377
974
199
1170
1480
77
199
626
0
8971
13
Area
1056
124
400
823
3889
430
681
902
554
81
226
257
166
245
9779
14
Total
7271
16735
2511
2858
13656
807
1926
1153
3181
6258
303
10727
792
3095
70643
100
% of Total
10
24
4
4
19
1
3
2
5
9
0
15
1
4
100
Rank
4
1
9
8
2
12
10
11
6
5
14
3
13
7
aSources: (1) Steam Electric Plant Factors 1972 (2) NEDS Emission File, Coal use in 103 tons/yr.
-------
108
-------
109
REFERENCES
I. 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, 1973, 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 862 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.
-------
110
------- |