EPA-450/3-74-072
DECEMBER 1974
IMPLEMENTATION PLAN REVIEW
FOR
ARIZONA
AS REQUIRED
BY
THE ENERGY SUPPLY
AND
ENVIRONMENTAL COORDINATION ACT
U. S. ENVIRONMENTAL PROTECTION AGENCY
-------
EPA-450/3-74-072
IMPLEMENTATION PLAN REVIEW
FOR
ARIZONA
REQUIRED BY THE ENERGY SUPPLY AND ENVIRONMENTAL COORDINATION ACT
PREPARED BY THE FOLLOWING TASK FORCE;
U. S. Environmental Protection Agency, Region IX
100 California Street
San Francisco, California 94111
Environmental Services of TRW, Int.
(Contract 68-02-1385)
U. S. Environmental Protection Agency
Office of Air and Waste Management
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
December 1974
-------
ARIZONA
ENERGY SUPPLY AND ENVIRONMENTAL COORDINATION ACT
(SECTION IV - STATE IMPLEMENTATION PLAN REVIEW)
Page
1.0 EXECUTIVE SUMMARY 1
2.0 REVIEW OF THE STATE IMPLEMENTATION PLAN AND CURRENT AIR QUALITY. . . 6
2.1 Summary 6
2.2 Air Quality Setting for the State of Arizona 9
2.3 Background on the Development of the Current State
Implementation Plan 10
2.4 Special Considerations for the State of Arizona n
3.0 AQCR ASSESSMENTS 13
3.1 Arizona - New Mexico Southern Borders AQCR (#012) 13
3.2 Clark - Mohave - Yuma AQCR (#013) 14
3.3 Four Corners AQCR (#014) 15
3.4 Phoenix - Tucson AQCR (#015) 16
4.0 TECHNICAL APPENDICES
APPENDIX A - State Implementation Plan Background 18
APPENDIX B - Regional Air Quality Analysis 34
APPENDIX C - Power Plant Assessment 37
APPENDIX D - Industrial, Commercial, Institutional Source
Assessment 43
BIBLIOGRAPHY . 45
TECHNICAL REPORT DATA SHEET 46
111
-------
1.0 EXECUTIVE SUMMARY
The enclosed report is the U. S. Environmental Protection Agency's
(EPA) response to Section IV of the'Energy Supply and Environmental
Coordination Act of 1974 (ESECA). Section IV requires EPA to review
each State Implementation Plan (SIP) to determine if revisions can be
made to control regulations for stationary fuel combustion sources
without interfering with the attainment and maintenance of the National
Ambient Air Quality Standards (NAAQS). In addition to requiring that
EPA report to the State on whether control regulations might be revised,
ESECA provides that EPA must approve or disapprove any revised regulations
relating to fuel burning stationary sources within three months after
they are submitted to EPA by the States. The States may, as in the
Clean Air Act of 1970, initiate State Implementation Plan revisions;
ESECA does not, however, require States to change any existing plan.
Congress has intended that this report provide the State with infor-
mation on excessively restrictive control regulations. The intent of
ESECA is that SIP's, wherever possible, be revised in the interest of
conserving low sulfur fuels or converting sources which burn oil or
natural gas to coal. EPA's objective in carrying out the SIP reviews,
therefore, has been to try to establish if emissions from combustion
sources may be increased. Where an indication can be found that
emissions from certain fuel burning sources can be increased and still
attain and maintain NAAQS, it may be plausible that fuel resource
allocations can be altered for "clean fuel savings" in a manner con-
sistent with both environmental and national energy needs.
In many respects, the ESECA SIP reviews parallel EPA's policy on
clean fuels. The Clean Fuels Policy has consisted of reviewing imple-
mentation plans with regards to saving low sulfur fuels and, where the
primary sulfur dioxide air quality standards were not exceeded, to
encourage States to either defer compliance regulations or to revise the
SOg emission regulations. The States have also been asked to discourage
large scale shifts from coal to oil where this could be done without
jeopardizing the attainment and maintenance of the NAAQS.
-------
To date, EPA's fuels policy has addressed only those States with the
largest clean fuels saving potential. Several of these States have or are
currently in the process of revising SCL regulations. These States are
generally in the Eastern half of the United States. ESECA, however, extends
the analysis of potentially over-restrictive regulations to all 55 States
and territories. In addition, the current reviews address the attainment
and maintenance of all^ the National Ambient Air Quality Standards.
There are, in general, three predominant reasons for the existence of
overly restrictive emission limitations within the State Implementation
Plans. These are 1) The use of the example region approach in developing
State-wide air quality control strategies; 2) the existence of State Air
Quality Standards which are more stringent than NAAQS; and 3) the "hot spots"
in only part of an Air Quality Control Region (AQCR) which have been used
as the basis for controlling the entire region. Since each of these situa-
tions affect many State plans and in some instances conflict with current
national energy concerns, a review of .the State Implementation Plans is a
logical follow-up to EPA's initial appraisal of the SIP's conducted in 1972.
At that time SIP's were approved by EPA if they demonstrated the attainment
of NAAQS ojr more stringent state air quality standards. Also, at that time
an acceptable method for formulating control strategies was the use of an
example region for demonstrating the attainment of the standards.
The example region concept permitted a State to identify the most
polluted air quality control region (AQCR) and adopt control regulations
which would be adequate to attain the NAAQS in that region. In using an
example region, it was assumed that NAAQS would be attained in the other
AQCR's of the State if the control regulations were applied to similar
sources. The problem with the use of an example region is that it can re-
sult in excessive controls, especially in the utilization of clean fuels,
for areas of the State where sources would not otherwise contribute to NAAQS
violations. For instance, a control strategy based on a particular region or
source can result in a regulation requiring 1 percent sulfur oil to be burned
state-wide where the use of 3 percent sulfur coal would be adequate to attain
NAAQS in some locations.
-------
EPA anticipates that a number of States will use the review findings
to assist them in making the decision whether or not to revise portions of
their State Implementation Plans. However, it is most important for those
States which desire to submit a revised plan to recognize the review's
limitations. The findings of this report are by no means conclusive and
are neither intended nor adequate to be the sole basis for SIP revisions;
they do, however ^represent EPA's best judgment and effort in complying
with the ESECA requirements. The time and resources which EPA has had to
prepare the reports has not permitted the consideration of growth, economics,
and control strategy tradeoffs. Also, there has been only limited dispersion
modeling data available by which to address individual point source emissions.
Where the modeling data for specific sources were found, however, they were
used in the analysis.
The data upon which the reports' findings are based is the most
currently available to the Federal Government. However, EPA believes that
the States possess the best information for developing revised plans. The
States have the most up-to-date air quality and emissions data, a better
feel for growth, and the fullest understanding for the complex problems facing
them in the attainment and maintenance of air quality standards. Therefore,
those States desiring to revise a plan are encouraged to verify and, in
many instances, expand the modeling and monitoring data supporting EPA's
findings. In developing a suitable plan, it is suggested that States select
control strategies which place emissions for fuel combustion sources into
perspective with all sources of emissions such as smelters or other industrial
processes; States are encouraged to consider the overall impact which the
potential relaxation of overly restrictive emissions regulations for combus-
tion sources might have on their future control programs. This may include
air quality maintenance, pravention of significant deterioration, increased
TSP, NO , and HC emissions which occur in fuel switching, and other potential
/\
air pollution problems such as sulfates .
Although the enclosed analysis has attempted to address the attainment of
all the NAAQS, most of the review has focused on total suspended particulate
matter (TSP) and sulfur dioxide (S02) emissions. This is because stationary
fuel combustion sources constitute the greatest source of S02 emissions and are
a major source of TSP emissions.
-------
Part of each State's review was organized to provide an analysis of
the SOp and TSP emission tolerances within each of the various AQCR's. The
regional emission tolerance estimate is, in many cases, EPA's only measure
of the "over-cleaning" accomplished by a SIP. The tolerance assessments
have been combined in Appendix B with other regional air quality "indicators"
in an attempt to provide an evaluation of a region's candidacy for changing
emission limitation regulations. In conjunction with the regional analysis,
a summary of the State's fuel combustion sources (power plants and industrial
sources) has been carried out in Appendix C and D.
The State Implementation Plan Review has addressed the emissions from
fuel combustion sources in each of Arizona's four Air Quality Control
Regions (AQCR's). For your convenience the Arizona AQCR's are shown on the
following page. The major findings are as follows:
The Arizona State Implementation Plan has been reviewed for the most
frequent causes of over-restrictive emission limiting regulation.
Although Arizona used the Example Region approach in developing control
strategies for both TSP and S02 and has an annual and 24 hour S02 air
quality standard more restrictive than NAAQS, there are no indications
that current regulations are overly restrictive in the context of
Section 4 of ESECA.
0 Most of Arizona's particulate emissions originate from wind-blown
fugitive dust. In the arid environment, natural background levels
are significant and this natural tendency is aggravated by human
activity, mainly agriculture, unpaved roads and construction. Such
fugitive dust from non-point sources is the primary cause of ambient
measurements which exceed national standards. There is currently
little possibility, therefore, of revising existing regulations for
controlling particulate emissions from stationary fuel combustion
sources.
0 The majority of SC^ emissions in the State come from large point
sources such as copper smelters (mainly process losses) and power
plants. With the exception of the Four Corners AQCR, Arizona is
currently developing regulations which are directed towards the
control of individual sources. In the Four Corners AQCR, EPA has
promulgated emission control for the Navaho Power Plant. However,
as these regulations were based upon unvalidated diffusion modeling,
EPA is now engaged in a joint air quality test program with Salt
River Project to determine more precisely the amount of emission
control necessary. It is expected that the State and EPA regulations
will be adequate to attain and maintain NAAQS by the required dates,
despite current SOg violations in three AQCR's (Phoenix - Tucson,
Southern Borders and Four Corners). Regulations which are oriented
towards specific sources of emissions are consistent with fuel savings
and with regards to Section IV of ESECA, Thus, they need no modification.
-------
Apache
iGraham
--I
I
GreeHlee
fr&fr
Pinal! ,4?
"T^^s^U
I ^%F :
A
-------
2.0 ARIZONA STATE IMPLEMENTATION PLAN REVIEW
2.1 SUMMARY
A revision of fuel combustion source emissions regulations will
depend on many factors. For example:
Does the State have air quality standards which are
more stringent than NAAQS?
t 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?
t Has the State not initiated action to modify combustion
source emission regulations for fuel savings; i.e., under
the Clean Fuels Policy?
Are there no proposed Air Quality Maintenance Areas?
t Are there indications of a sufficient number of monitoring
sites within a region?
Is there an expected 1975 attainment date for NAAQS?
t Based on reported (1973) air quality data, does air quality .
meet NAAQS?
0 Based on reported (1973) air quality data, are there
indications of a tolerance for increasing emissions?
Are the total emissions from stationary fuel combustion
sources proportionally lower than those of all other
sources?
t Is there a significant clean fuels savings potential in
the region?
t Must emission regulations be revised to accomplish significant
switching?
Do modeling results for specific fuel combustion sources
show a potential for a regulation revision?
The following portion of this report is directed at answering these
questions. An AQCR's potential for revising regulations increases when
there are affirmative responses to the above.
6
-------
The initial part of the SIP review report, Section 2 and
Appendix A, was organized to provide the background and current
situation information for the State Implementation Plan Section 3
and the remaining Appendices provide an AQCR analysis which helps
establish the overall potential for revising regulations. Emission
tolerance estimates have been combied in Appendix B with other regional
air quality "indicators" in an attempt to provide an evaluation of a
region's candidacy for revising emission limiting regulations. In
conjunction with the regional analysis, a characterization of the State's
fuel combustion sources (power plants and industrial sources) has been
carried out in Appendix C and D.
Based on an overall evaluation of EPA's current information, AQCR's
have been classified as good, marginal, or poor candidates for regulation
revisions. The following table summarizes the State Implementation Plan
Review. The remaining portion of the report supports this summary with
explanations.
-------
STATE IMPLEMENTATION PLAN REVIEW
(SUMMARY)
STATE
ivrn Cjarl<-Mohave-Four Corners Phoenix-Tucson
New Mexico Yuma AQCR AOCR AOCR
AQCR(#012) (#013) '"-- - " ^ '
"INDICATORS"
« Does the State have air quality standards
which are more stringent than NAAQS?
* Does the State have emission limiting regu-
lations for control of:
1 . Power plants
2. Industrial sources
3. Area sources
t jid thij State use an example region approach
for demonstrating the attainment of NAAQS or
rare 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 np_ proposed Air Quality Maintenance
Areas?
Are there indications of a sufficient number
of monitoring sites within a region?
« Is there an exaected 1975 attainment date
for '(AAQS?
Based on reported (1973) Air Quality Data-,
does air quality rr.eet NAAQS?
e Based on reported (1973) Air Quality Data,
are there indications of a tolerance for
increasing enissions?
* Are the total emission's from stationary fuel
combustion sources lower than those of other
sources?
* Do modeling results for specific fuel combustion
sources show a potential for a regulation revision?
Must emission regulations be revised to accom-
plish significant fuel switching?
c Based on the above indicators, what is the
potential for revising fuel combustion source
emission limiting regulations?
Is there a significant Clean Fuels Saving
potential in the region?
TSP S0?
No
Yes
Yes
YP<:
Yes
Yes
-
-
-
-
-
-
-
-
-
-
Yes1
Yes
Yes
YP«;
Yes
Yes
-
-
-
-
-
-
-
-
-
-
TSP S0?
-
_
-
-
Yes
N/A
Yes
No
No
Yes
N/A
No
Poor
N/A
t-
_
-
-
Yes
N/A
No
No
No
Yes
N/A
No
Poor
N/A
TSP S02
-
_
-
-
Yes
N/A
Yes
No
No
Yes
N/A
No
Poor1
N/A
-
_
-
-
Yes
No
Yes
Yes
Yes
Yes
N/A
No
larg-
inal
N/A
TSP S02
-
_
-
-
Yes
N/A
Yes
J No
No
No
N/A
No
Pooi
N/A
-
_
-
-
Yes
No
No
Yes4
Yes
No
N/A
No
Poor
N/A
TSP S02
-
_
-
-
Yes
N/A
No^
No
No
Yes
N/A
No
oor
/A
-
_
-
-
Yes
N/A
No
No
No
Yes
N/A
No
Pooi
N/A
- = not applicable
N/A = not available
1 = only for the annual and 24-hour S02 standard
2 = 7/75 for'primary standard and 7/77 for secondary standard
3 = no air quality data is available for the Nevada portion of this AQCR
4 = violations are reported in the New Mexico portion of this-AQCR
-------
2.2 AIR QUALITY SETTING - STATE OF ARIZONA
The State of Arizona is comprised of four Air Quality Control Regions
(see Figure A-l): Phoenix-Tucson Intrastate (#015), Four Corners Interstate
(#014), Clark-Mohave-Yuma Interstate (#013) and the Arizona-New Mexico
Southern Borders Interstate (#012). Priority classifications for TSP, S02
and NO in these AQCRs is given in Table A-l. There are no proposed Air
/\
Quality Maintenance Area designations for TSP and S02<
Table A-4 illustrates both the Federal and State standards for the pollu-
tants under consideration in this project. As can be seen, Arizona has more
stringent annual and 24 hour standards for S02. A summary of the most currently
available air quality data is shown in Table A-5 and A-6. Particulate matter
is a major problem in all AQCRs, while violations of the SOp standard in Arizona
are due to the presence of copper smelters in Phoenix-Tucson arid Southern
Borders AQCR's.
Emissions of S02 and particulate matter are summarized in Tables A-7
and A-8. A large proportion of the particulate emissions in fugitive dust,
while S02 emissions can be attributed mainly to either power plants or copper
smelters.
There are five copper smelters in the Phoenix-Tucson AQCR and two in the
Arizona-New Mexico Souther Borders AQCR (Arizona portion). All are on compli-
ance schedules and all are expected to attain standards by 1977. In the
interim, all smelters are operating on conditional permits from the State,
except Kennecott-Hayden which is essentially in compliance with State S02
emission requirements and has already been granted a full operating permit.
All except for two power plants (Navaho and Choi la in the Four Corners
AQCR) burn natural gas or oil and are assumed to be attaining standards. These
sources have been granted operating permits from either the State or County.
There are nine power plants in the Phoenix-Tucson AQCR, one in the Clark-Mohave
AQCR, one in the Southern Borders AQCR and two in the Four Corners Region.
Choi la (Unit #1) has been granted an operating permit from the State. The
Navaho facility is on an EPA compliance schedule with attainment set for 1977.
-------
2.3 BACKGROUND ON THE DEVELOPMENT OF THE CURRENT STATE IMPLEMENTATION PLAN
The State of Arizona adopted an example region approach in writing its
implementation plan. The Phoenix-Tucson AQCR was selected for this purpose
because: the highest concentrations of pollutants were measurdd in this
region; nearly 81 percent of the population resided in the region; and most
types of emission sources found in the State are present in the region.
Arizona standards were used in developing control strategies and a proportional
rollback model was applied to calculate the emission reductions required.
The Arizona SIP did not provide a SO^ control strategy adequate to attain
national standards. The plan did not set emission limits on copper smelters in
the Phoenix-Tucson Intrastate Region and the Arizona portion of the Arizona-New
Mexico Southern Borders Interstate Region; nor did the plan provide for adequate
control of S02 emissions from the Navaho Power Plant in the Four Corners Inter-
state Region.
On March 23, 1973, EPA promulgated substitute regulations for Navaho (Units
1, 2 and 3) which included S02 emission limits based on 70% removal of the sulfur
content of local coals. If higher sulfur coal is used, the same emission limit
must be met, even though control in excess of 70% might be necessary. The intent
of EPA was to promulgate the amount of emission control calculated to be necessary
for attainment of the national secondary standard. However, as this calculation
was based on unvalidated diffusion modeling, EPA is now engaged in a joint air
quality test program with Salt River Project to determine more precisely the
amount of emission control necessary for attainment. EPA is committed to the
careful consideration of adequate data issuing from the program. There is
litigation regarding the Navaho regulations but it may be dismissed as a result
of the joint test program.
The State has submitted revised regulations for the control of SO^ emissions
from power plants in the Phoenix-Tucson AQCR. The regulation allows variances
for existing power plants if only high sulfur fuel oil (greater than 0.9% sulfur
by weight) is available, with the condition that the facility has contingency
plans to avert violations of SOp standards. EPA will be evaluating this regula-
tion to determine if it is adequate in view of earlier reports from the State
that SOp standards will be violated in the Phoenix-Tucson area if power plants are
to burn oil with a sulfur content between 0.9% and 2.0% (maximum allowable under
Arizona regulations).
10
-------
Regarding particulate matter, the control strategy was disapproved for
the Phoenix-Tucson AQCR because it did not provide adequate control for process
industries. On May 14, 1973, EPA promulgated the Federal Process Rate Table.
AH counties within the Phoenix-Tucson AQCR have adopted or soon will adopt
EPA's process table, as will the State.
2.3.1 Particulate Control Strategy
Regulations directed towards the control of particulate emissions include:
process weight table rate schedule, control of road dust emissions, controls
for agricultural practices and tailing piles, and fuel combustion particulate
emissions.
2.3.2 S02 Control Strategy
The limitation of S02 is aimed mainly at discharges from copper smelting
process operations and power plants.
2.4 SPECIAL CONSIDERATIONS - STATE OF.ARIZONA
The Phoenix-Tucson AQCR is classified Priority I for oxidants. The
impact of fuel switching (i.e. natural gas to oil) can only aggravate the
oxidant problem, because hydrocarbon emissions from oil combustion are an order
of magnitude greater than natural gas combustion (see Table C-2). The similar
situation exists for coal combustion hydrocarbon emissions as opposed to oil or
natural gas.
The original implementation plan was written assuming that the fuel mix
used in 1969 would remain the same in the future. However, due to energy
shortages, this assumption is no longer correct. Many states, including Arizona,
either have or will experience difficulties in obtaining clean fuels such as
natural gas to satisfy all consumer denands. If deliveries of natural gas to
oil/gas fired power plants is curtailed (as in the case in many states), these
facilities would be forced to switch to fuel oil. Appendix C illustrates the
results of a "worse case" switch, assuming that 1) all fuel used is oil and
2) the sulfur content of the oil used is the same as that which is currently
being burned. (See Footnote d of Table C-l for an explanation of how the
switching calculation is made) As can be seen, SO,, emissions would increase by
almost a factor of two. The results also show that current S0£ emission limits
will not be violated even with this increase in emissions.
11
-------
Pursuant to Arizona regulations, S02 standards must be achieved in the
vicinity of the seven copper smelters by July 1977. These regulations
require constant emission reduction to meet the annual standard and allow the
use of Supplementary Control Systems (SCS) to meet the 24 - and - 3 hour
standards. However, these regulations have not been approved. EPA is currently
drafting substitute regulations to be proposed in the near future. The
primary difference between State and EPA proposed regulations will revolve
around the use of SCS. As noted, State regulations allow permanent use of SCS
to attain standards. EPA proposed regulations will allow SCS only under certain
circumstances, only after available constant emission control technology is
employed, and only on a temporary basis.
Regarding particulate matter, standards are not likely to be attained in
any of the Arizona AQCR's. In the arid environment, natural background levels
are significant. This natural tendency is aggrevated by human activities,
mainly agriculture, unpaved roads and construction. Such fugitive dust from
non-point sources is a primary cause of ambient measurements which exceed the
national standards. Point sources, including process industries, are adequately
controlled.
Supplementary control systems are those which limit pollutant emissions
during periods when meteorological conditions are condusive to ground
level concentrations in excess of the NAAQS.
12
-------
3.0 AQCR ASSESSMENTS
3.1 ARIZONA-NEW MEXICO SOUTHERN BORDERS AQCR (#012)
3.1.1 Regional Air Quality Assessment
Both SOp and participates have remained a major problem in this AQCR since
the time the original implementation plan submittal (see Tables A-5 and A-6).
Participate emissions are due mainly to fugitive dust, while copper smelters in
Morenci and Douglas are the source of over 95% of the SOp emissions. (The majority
of the S02 emissions from smelters is due to process losses, rather than fuel
combustion) It has estimated that the S02 air quality standards will be achieved
by the expected attainment dated (July 1977) through the imposition of stringent
controls on the smelters.
Tables B-l and B-2 present the information which should be considered when
estimating the potential for regulation revision. There is no indication that
the regulations are overly restrictive.
3.1.2 Power Plant Assessment
There was insufficient fuel use and emission data to carry out an analysis
for the one plant in this AQCR (Table C-l).
3.1.3 Industrial/Commercial/Institutional Source Assessments
There are no sources in this category which presently use coal or have
the capability of using coal without extensive modifications. An analysis is
performed in Table D-l as to the resulting change in emissions if a fuel switch
from natural gas to oil is made. The results indicate that because the majority
of the sources in this category currently burn natural gas as their primary fuel,
such a switch would increase fuel combustion SOp and fuel combustion particulate
emissions.
3.1.4 Area Source Assessments
The Arizona-New Mexico Southern Borders AQCR was found to have no area
sources which could be analyzed within the content of Section 4 of ESECA.
3.1.5 Fuel Assessments
The only assessment of fuel switching made was in reference to the
industrial point sources discussed in Section 3.1.3. The possibility of using
higher sulfur content oil than is presently used was not carried out because
this AQCR is expected to just marginally attain the S02 standard.
13
-------
3.2 CLARK-MOHAVE-YUMA AQCR (#013)
3.2.1 Regional Air Quality Assessment
Of the two pollutants under consideration, only particulate matter is
a problem in the Clark-Mohave-Yuma AQCR (Table A-5). Again, fugitive dust
emissions are the main culprit. No violations of the SCL standard has occurred,
mainly because there is only one small power plant in the Arizona portion of
the region. EPA expects little difficulties in maintaining the SCL standard.
However, the presence of the Mohave Power Plant in the Nevada portion of this
AQCR should be noted. If SCL controls at Mohave are not adequate, attainment
of the standard could be jeopardized in the Arizona portion of this AQCR as well.
Controlling TSP in the form of fuitive dust will remain a difficult air pollution
situation.
It does not appear that the regulations are over-restrictive.
3.2.2 Power Plant Assessments
There is only one power plant in this region. The Yucca Power Plant in
Y,uma is a relatively small one (75 Mw) and uses both oil and natural gas. It
has no capability of burning coal without extensive modifications. Table C-l
summarizes the pertinent fuel use and emissions data, as well as the effects of
a fuel switch to using oil only.
3.2.3 Industrial/Commercial/Institutional Source Assessment
The Clark-Mohave-Yuma AQCR was found to have no sources belonging to this
category which could be analyzed within the context of Section 4 of ESECA.
3.2.4 Area Source Assessment
The Clark-Mohave-Yuma AQCR was found to have no area sources which could be
evaluated within the context of Section 4 of ESECA.
3.2.5 Fuel Assessments
An analysis has performed on the effect of having the Yucca Power Plant
burn only oil (Table C-l). The results indicate a fivefold increase in both
S02 and particulate emissions as a consequence of this fuel switch. Although
the region wide air quality indicates that this increase in SCL can be tolerated
(i.e. based on proportional rollback), it is highly doubtful that SCL standards
in the vicinity will not be violated. In addition, the increased particulate
emissions can only serve to further aggrevate the currently high particulate
levels.
14
-------
3.3 FOUR CORNERS AQCR (#014)
3.3.1 Regional Air Quality Assessment
At present, only participate matter is an air quality problem in the Four
Corners AQCR (Table A-5). As in the other three AQCRs in Arizona, fugitive
dust emissions are the main cause of TSP levels. There have been no reported
violations of the S02 standards in the Arizona portion of the AQCR. Even with
the advent of a 2300 Mw coal fired power plant coming on line near Page,
EPA expects the S02 standard can be maintained.
There are no indications that the emission 1 Smiting regulations for this
AQCR are over-restrictive.
3.3.2 Power Plant Assessments
The Cholla Power Plant located near Joseph City is a coal fired 114 MW
unit. Plans are underway to add two new 250 Mw units and EPA is in the process
of evaluating their impact. Table C-l shows the resulting emissions at the
present Cholla unit if the maximum permissible sulfur content coal (in terms of
Ibs SOp/lO Btu) is Burned. The only other power plant in the AQCR is Navaho,
which is also coal fired. With one 750 Mw unit presently on line and two more
750 Mw units scheduled to do so in the near future, Navaho has already generated
considerable controversy as to the degree of control required such that national
S02 standards are not violated. The EPA promulgated 70% control regulation
(39 FR 176, September 10, 1974) has been disputed in court by the Salt River Pro-
ject. The most recent action in the controversy was the initiation of a joint air
quality monitoring study to determine the actual degree of control required.
3.3.3 Industrial/Commercial/Institutional Source Assessments
The Four Corners AQCR was found to have no sources in this category which
could be evaluated within the context of Section 4 of ESECA.
It should be noted that two companies, U.S. Lime and Phoenix Cement, are in
the process of converting to coal.
3.3.4 Area Source Assessment
The Four Corners AQCR was found to have no area sources which could be
evaluated within the context of Section 4 of ESECA.
15
-------
3.3.5 Fuel Assessments
The analysis of fuel switching was carried out only for the Choi la Power
Plant (Table C-l). The evaluation was made in terms of increasing the sulfur
content of the coal used (in terms of 10 Btu/lb) up to the state emission
limitSo
3.4 PHOENIX-TUCSON AQCR (#015)
3.4.1 Regional Air Quality Assessment
The most currently available air quality data indicated frequent violations
of both the SO,, and particulate standard (Tables A-5 and A-6). SO^ emissions are
attributed mainly to either copper smelters or power plants, while particulates
emissions emanate from fugitive dust and process losses. EPA estimates that
when all smelters are brought into compliance (July 1977), the SOp standards will
be attained. These SOo emissions are primarily the result of sulfur released
from the copper during the smelting process; very little of the total S0£
emissions from smelters are the result of sulfur in the combustion fuel.
There are no indications that the regulations are over-restrictive.
3.4.2 Power Plant Analysis
There are more power plants in the Phoenix-Tucson AQCR than in all the
other three Arizona AQCRs combined. Every one of these plants is oil and gas
fired, with no capability of using coal without extensive modifications. Table
C-l illustrates the results of fuel switching (i.e. burning oil only) at these
plants.
3.4.3 Industrial/Commercial/Institutional Source Assessments
Only two industrial sources are found to deserve analysis (Table D-l).
(One additional company, Arizona Portland Cement, is in the process of converting
to coal). As was the case in the other three AQCRs, an evaluation of the effects
of fuel switching was made. The results indicate that S02 and particulate
emissions would increase by a factor of twelve.
3.4.4 Area Source Assessment
The Phoenix-Tucson AQCR was found to contain no area sources which could
be evaluated within the context of Section 4 of ESECA.
16
-------
3.4.5 Fuel Assessments
The consequences of a fuel switch in the Phoenix-Tucson AQCR are shown in
Table C-l: SC^ emissions will increase by over 17,000 tons/year and particu-
late emission by over 1700 tons/years.
17
-------
APPENDIX A
t State implementation plan information
t Current air quality information
t Current emissions information
Tables in this appendix summarize original and modified state imple-
mentation plan information, including original priority classifications,
attainment dates, ambient air quality standards, and fuel combustion emis-
sion regulations. SAROAD data for S00 and TSP monitoring stations are shown
1
for AQCRs in the state. NEDS emissions data by AQCR are tabulated and
broken down into fuel burning categories.
Tables A-10 and A-ll show a comparison of emission inventories in the
original SIP and those from the NEDS. An emission tolerance, or emission
tonnage which might be allowed in the AQCR and still not violate national
secondary ambient air quality standards, is shown for SC^ and particulates.
Tolerance was based on either the degree of control expected by the SIP or
upon air quality/emission relationships which are calculated from more
recent data. The value of the emission tolerance provides an indication
of the degree of potential an AQCR possesses for fuel revisions and
regulation relaxation.
Methodology for Increased Emissions Tolerance
A tolerance for increased emissions was determined as follows. First,
an "allowable emissions" was calculated for each AQCR based on the current
NEDS data and the percent reduction (or increase) required to meet the
national secondary ambient air quality standards in that AQCR (worst case
from Tables A-5 and A-6). This "allowable" was then compared to that from
the SIP. If reasonable agreement occurred, then the "estimated emissions"
which would result after implementation of the SIP in that AQCR was used
to calculate an emissions tolerance. Thus, some credit could be given to
an AQCR which might be restricting emissions more than required by ambient
air quality standards. For instance, emission controls applied to AQCRs
1"1972 National Emissions Report," EPA - 450/2-74-012, June 1974.
18
-------
for the state may reduce emissions well below "allowables." In the event
that no data existed or was available from the SIP for an AQCR, the current
air quality waa uo< >.- !". emissions f^rance based on proportional
rollback or roll up. Current air quality was also the criteria, if emissions
data from SIP and NEDS did not appear to be comparable (this is often the
case).
When no SIP emissions data was available, and current air quality levels
were less tnan one nan oT u.e level reprtoCM^c- by cr. d-bicr.t *** quality
standard, no "rollup" emissions tolerance was calculated in Tables A-lOa
and A-lOb. This arbitrary cutoff point was chosen so as not to distort the
emissions tolerance for an area. At low levels of a pollutant, the relation=
ship between emissions and air quality is probably not linear. Although this
cutoff may leave some AQCRs with JTO_ quantifiable emissions tolerance, it was
felt that no number at all would be preferable to a bad or misleading number.
It is emphasized that emissions tolerance is a region-wide calculation.
This tolerance obviously makes more sense in, say, an urban AQCR with many
closely spaced emissions sources than in a largely rural AQCR with geograph-
ically dispursed emissions.
Low concentrations of pollutants probably indicate a low density of sources
and that the air quality monitors are not located near the sources. Thus
changes in emissions from the sources will not result in a linear change in
air quality readings.
19
-------
Table A-l. Arizona Air Pollution Control Areas
Air Quality Control Region
Arizona - New Mexico
Southern Border0
Clark-Mohavec
Four Corners0
Phoenix-Tucson
Federal
Number
012
013
014
015
Priority Classlficat
Parti cul ate
IA
I
IA
I
S0y
IA
I
IA
I
ona
NOX
III
III
III
III
Proposed AQMA Designations
TSP Counties
(0)
(0)
(0)
(0)
SOX Counties
(0)
(0)
(0)
(0)
ro
o
Priority
Sulfur oxide
Annual Ari thematic mean
24 hour maximum
'articulate matter
Annual geometric mean
24 hour maximum
I
Greater than
100
455
95
325
II
From- to
60-100
260-455
60-95
150-325
III
Less-than
60
260
60
150
aCriteria based on maximum measured (or estimated) pollution concentration (pg/m ) in area.
Federal Register, August 1974, SMSA's showing potential for NAAQS violations due to growth.
Interstate AQCR.
-------
I"
7
./-v
/
I Mohave j
Apache |
Greerjlee
Figure A-l State of Arizona
21
-------
Table A-2. Arizona Population and Area
ro
ro
AQCR
Arizona - New Mexico
Southern Borders3
Clark - Mohave
Yumaa
Four Corners3
Phoenix-Tucson
County
Cochise
Graham
Green lee
Mohave
Yuma
Apache
Coconino
Navajo
Yavapai
Gil a
Mari copa
Puma
Pinal
Santa Cruz
Area
(Square miles)
6256
4618
1879
13217
9983
11171
18540
9910
8091
4748
9155
9240
5364
1246
Population
61918
16578
10330
25857
60827
32304
48326
47559
37005
29255
968487
351667
68579
13966
Population Densii
(per square mile
9.9
3.6
5.5
2.0
6.1
2.9
2.6
4.8
4.6
6.2
105.8
38.1
12.8
11.2
Interstate - counties listed are those in Arizona only.
-------
Table A-3. Attainment Dates
ro
CO
AQCR Name
01 2a Arizona - New Mexico
Southern Borders
01 3b Clark - Mohave - Yuma
01 4C Four Corners
015 Phoenix - Tucson
Parti cul ate
Attainment Dates
Primary Secondary
7/75 6
7/75e
7/75e
7/75e
7/75e
7/75e
7/75e
7/7T6
Sulfur Oxides
Attainment Dates
Primary Secondary
7/77
7/75
7/77
7/77
7/77
7/75
7/77
7/77
Nitrogen Oxides
Attainment Dates
d
d
d
d
Interstate with New Mexico
Interstate with Nevada
clnterstate with Utah, Colorado and New Mexico
Air quality levels presently below standards.
elt is unlikely that the standards will be attained by the required
dates. See Section 2.4.
-------
Table A-4. Arizona Ambient Air Quality Standards
ro
Federal
Arizona
Primary
Secondary
Total Suspended
Parti culates
Annual
75 (6)
60 (G)
60 (G)
24-hour
260a
150a
150
All Concentrations in yg/m3
Sulfur Oxides
Annual
80 (A)
-
50 (A)
24-hour
365a
-
260
3-hour
_
1300*
1300
Nitrogen Dioxide
Annual
100 (A)
100 (A)
100 (A)
Not to be exceeded more than one time a year.
(A) Arithemetic mean
(G) Geometric mean.
-------
Table A-5. Arizona AQCR Air Quality Status (1973), TSPa
TSP Concentration
#
Stations
AQCR Name
Highest Reading
State Reporting Annual
Arizona - New Mexico Arizona
Southern Border
Clark - Mohave
Vi int*t *
- Yuma
Four Corners'5
ro
01
Phoenix - Tucson
New Mex.
Ari zona
Nevada
Ari zona
New Mex.
Utah
Colorado
Arizona
3
10
5
16
7
6
2
8
32
N/A
72
109
177
58
65
15 .
N/A
215
24-Hr
475
523
1101
850
430
234
254
116
1005
2nd
Highest
Readi ng
24-Hr
215
395
287
792
375
228
186
104
777
# Stations Exceeding
Ambient Air Quality Standards
Primary Secondary .
Annual 24-Hr
0
0
1
6
0
0
0
N/A
7
0
2
1
3
1
0
0
0
6
Annual
N/A
1
1
8
0
1
0
N/A
10
% 24-Hrw
N/A
10
20
47
0
17
0
N/A
29
2
6
1
9
3
1
1
0
26
Reduction Standard
Required on Which
to Meet d Reduction
% Standards Is Based
50
60
20
53
43
17
50
0
76
3U
62
59
81
60
34
19
-44
82
24 hr
24 hr
Annual
24 hr
24 hr
24 hr
24 hr
24 hr
Annual
1973 air quality data in National Air Data Bank as of June 7, 1974.
Interstate.
cViolation based on more than one excess of the standard.
alculate from:
2nd Highest 24 Hr Reading - 24 Hr Secondary Standard
2nd Highest 24 Hr Reading"
Note: 24 hour background assumed to be zero for all states.
Annual background: Arizona = 26 /ig/m.
Colorado = 30 jug/nr
Hew Mexico =17
Utah = 18.8
N/A = Not available.
or
Annual Reading - Annual Secondary Standard
Annual Reading - Background
-------
Table A-6. Arizona AQCR A1r Quality Status (1973), S02a
S02 Concentration
ro
State
Arizona
New Mex.
Arizona
Nevada
Arizona
New Mex.
Utah
Col orado
Arizona
Stations
Reporting
24-Hr
(Bubbler)
7
10
1
0
2
7
0
0
17
#
Stations
Reporting
(Contin.)
7
2
0
N/A
0
4
0
0
12
Highest
Annual
86
137
3
N/A
2
N/A
N/A
N/A
219
Readi ng
24-Hr
3510
1294
10
H/A
9
79
N/A
N/A
2373
2nd # Stations Exceeding Reduction
Highest Ambient Air Quality Stds. Required
Reading Primary , Secondary To Meet
24-Hr
2335
1032
2
N/A
9
N/A
N/A
N/A
2319
Annual
1
1
0
N/A
0
0
N/A
N/A
1
24-Hru
6
3
0
N/A
0
0
N/A
N/A
7
.3-Hrd
6
2
N/A
N/A
N/A
0
N/A
N/A
8
Standards
84
65
f
N/A
f
f
N/A
N/A
84
Standard
on Which %
Reduction
Is Based
24 hr
24 hr
N/A
N/A
N/A
N/A
N/A
N/A
24 hr
AQCR Name
Arizona - New Mexic
Southern Border*5
Clark - Mohave -
Four Corners'5
Phoenix - Tucson
a!973 air quality data in National Air Data Bank - June 7, 1974
Interstate
°The 2nd_ highest readings were only given at 24 hr stations and not continuous stations. The values reported 1n this
column are from 24 hr stations and may not be the true 2nd_ highest reading (since the 2nd highest reading from con-
tinuous stations may be larger in value).
Violations based on more than one excess of standard.
Calculated from:
2nd Highest 24 Hr Reading - National Secondary 24 Hr Standard Annual Reading - Secondary Ann'1 Std.
'
2nd Highest 24 Hr Reading
or
nnual Reading
Reductions were not calculated because the annual and 24 hr readings are less than 1/2 of the corresponding standard.
It was decided in this case that calculating reductions would yield misleading figures.
Note: Background assumed to equal zero for both annual and 24 hr concentrations.
N/A = Mot available.
-------
Table A-7. Arizona Fuel Combustion Source Summary
ro
AQCR
Arizona - New
Mexico -
Southern
Borders8
Clark - Mohave -
Yumaa
Four Corners*
Phoenix -
Tucson
Arizona
Power Plants
1
1
2
9
Other Arizona Fuel Combustion
Point Sources0
3
0
0
8
Total Arizona Fuel Combustion
Emissions (10^ tons/year)"
Parti ciiflates
.163
.064
7/9
1.97
S02
.282
.051
3.6
3.06
a
Interstate.
5From Arizona SIP.
cFrom NEDS rank order.
Emissions in data bank as of June 27, 1974.
-------
Table A-8. Arizona Emissions Summary,Participate3
co
Industrial, Institu-
tional , Commercial
Total
Particulates
AQCR
Arizona - New
Mexico -So.
Borders'5
Clark - Mohave
Yumab
i uiiia
Four Corners'5
Phoenix -
Tucson
State
Arizona
New Mex.
Arizona
Nevada
Arizona
New Mexico
Utah
Colorado
Arizona
(tons/year)
19,900
3,400
1,300
63,130
9,700
24,600
1,800
1,560
49,200
Electrical
Generation
tons/yr
44
17
15
8,486
6,900
20,295
73
0
564
% of total
0.2
0.5
1.2
13.4
70
82.5
4.1
0
1.1
Point Source Fuel
Combustion
tons/yr
55
104
0
28
0
66
0
29
75
% of total
0.3
3.1
0
0.04
0
0.3
0
18.5
0.1
Area
Source
Fuel Combustion
tons/yr
64
43
49
340
1,000
200
714
463
1,300
% of total
0.3 :
1.3
3.8
0.5
10.3
0.8
40
30
2.6
Other Sources Parti
culate Emissions
tons/yr
19^741
3,233
1,235
54,292
1,730
4,034
1,006
803
47 ,290
% of total
99.2
95.1
95
86
18.7
16.4
55.9
51.5
96.2
aT972 Emissions in data bank as of June 27, 1974.
Interstate.
-------
Table A-9. Arizona Emission Summary,
Electrical
Industrial, Institu-
tional, Commercial
Point Source Fuel
Area Source
Other Sources of
ro
10
AQCR
Arizona - New
Mexico So.
Borders'*
Clark - Mohave
Yumab
Four Corners'"
Phoenix -
Tucson
State
Arizona
New Hex.
Arizona
Nevada
Arizona
New Mexico
Utah
Coloardo
Arizona
Total S02 Gem
(tons/year) tons/yr
947,000 2
247,454 1
594
57,000
4,300
113.264
119,756
440
899,232
1
54,900
3,400
107,374
110,854
0
473
sration Combustion Fuel Combustion S02 Emissions
% of total tons/yr % of total tons/yr % of total tons/yr % of total
.0002
0
0.2
96
79
95
93
0
0.06
206
116
0 .
1
0
175
175
2
189
0.02
0.05
0
0
0
0.2
0.1
0.5
0.02
66.0
24
50.0
726.
206
31
1,315
324
2,400
0.007
0
8.4
1.3
4.7
0.03
1.1
73.6
0.27
946,726
247,313
543
1,539
746
5,403
6,946
114
896,123
99.9
99S95
91.4
2.7
16.3
4.77
5.8
25.9
99.7
a!972 Emissions in data bank as of June 27, 1974.
Interstate.
-------
Table A-10. Arizona Required Emission Reductions, Participate
SIP
AQ
Measurement Allowable
Control Emissions Emissions
AQCR Value (103 tons) (103 tons)
Ariz, 240 jig/m3 c>f 63. 8d 10.2d>e
N.Mex
So.Bord.3
Clark- 144 Mg/m3 b>f 48. 9d 51.3d'e
Mohave-
Yumaa
Four 15.2 ng/m3 c'f 113. 2d g
Corners
Phoenix- 265 ng/m3 c 123.8 17.3e
Tucson
00
o
a Interstate
24 hour average
c Annual geometric mean
1971
Estimated
Emissions
After Controls
(103 tons)
N/A
. N/A
N/A
44.3
Emissions from Arizona portion of interstate AQCR
e Emissions required to meet national secondary standards
Based on air quality data in Arizona portion of
9 Allowable emissions were not calculated because
N/A = not available
interstate AQCI
air quality is
less t
Percent
Reduction
Required NEDS Allowable
Based On Emissions Emissions
1973 AQ Data JlO3 tons) (103 tons)
30f 19. 9f 13.9d'e
59f 1.3d 0.5d'e
60f 9.7d 3.9d'e
82C 49.2 8.9e
lan one-half the standard.
Emission
Tolerance
(IP3 tons)
-6.0
^0.8
-5.8
-40.3
-------
Table A-11. Arizona Required Emission Reductions, SO.
SIP
AQ
Measurement Allowable
Control Emissions Emissions
AQCR Value (103 tons) (103 tons)
012a 1717 /ig/rn3 b>f 853. lc 179c>d
01 3a N/A ,9C N/A
014a 54.6 M9/m3 b>f 6.9C g
015 4550 »ig/m3 b 1029.8 56. 6d
a Interstate
24 hour average
1975
Estimated
Emissions
After Controls
(103 tons)
N/A
N/A
N/A
N/A
>
c Emissions based on Arizona portion of Interstate AQCR
Emissions required to meet national secondary
e Present air quality is less than one-half the
was felt that the results would be misleading
Air Quality in Arizona portion of interstate
standards
standard. Emiss
AQCR
9 Air quality was less than one-half the standard. Allowable en
felt that the results would be misleading.
ion to
ission
Percent
Reduction
Required NEDS Allowable
Based On Emissions Emissions
1973 AQ Data {103 tons) (103 tons)
84b>f 947° 152c'd
e 0.6C e
e 4.3C e
84b 889 142d
lerances were not calculated in this case
> were not calculated in this case because
Emission
Tolerance
(TO3 tons)
-795
e
-747
>ecause it
it was
-------
Table A-12. Arizona Fuel Combustion Regulations
CO
ro
Sulfur Oxides
A. Steam power generating installations which are new sources shall not emit more than 0.80 Ibs
of S02, maximum two hour average, per million Btu heat input when oil is fired. Steam power
generating installations which are existing sources shall not emit more than 1.0 Ibs of S02,
maximum two hour average, per million Btu heat input when low sulfur oil is fired.
B. Steam power generating installations which are existing sources shall not emit more than 2.2 Ibs
of S02, maximum two hour average, per million Btu heat input when high sulfur oil is fired.
C. For purposes of this regulation, low sulfur oil means fuel oil containing 0.90 percent or more
by weight of sulfur.
D. Steam power generating installations which are new sources shall not emit more than 0.80 Ibs
of S02> maximum two hour average, per million Btu heat input when coal is fired. Steam power
generating installations which are existing sources shall not emit more than 1.0 Ibs of
maximum two hour average, per million Btu heat input when coal is fired.
E. Any permit issued for the operation of an existing source, or any renewal or modification
of such a permit, shall include a condition prohibiting theuse of high sulfur oil by the
permittee, except that if the applicant demonstrates to the satisfaction of the director:
(1) That sufficient quantities of low sulfur oil are not available for use by the source,
and (2) that it has adequate facilities and contingency plans to ensure that the sulfur
dioxide ambient air quality standards set forth in Regulation 7-1-2.2 will not be violated.
The terms of the permit may authorize the use of high sulfur oil under such conditions as
are justified. In cases where the permittee is authorized to use high sulfur oil it shall
submit to the department monthly reports detailing its efforts to obtain low sulfur oil.
When the conditions justifying the use of high sulfur oil no longer exist, the permit shall
be modified accordingly.
-------
CO
00
Table A-12. Arizona Fuel Combustion Regulations3 (Contd)
Parti cul ate Matter
Particulate matter emissions from fuel combustion sources are restricted by the following table:
Heat Input (1Q6 Btu/hr) Lbs/hr (24 hour arithmetic average)
0.599
50 0.413
100 0.352
,25 °'243
1000 0.207
4000 0.153
8000 0.103
10,000 0.0909
20,000 0.0613
40,000 0.0414
50,000 0.0364
100,000 0.0246
For heat inputs not given above, use the following formulas:
10 x 106 Btu/hr < Heat Input < 4000 x 106 Btu/hr y = 1.02 x ~0>23
c ,-, -0.568
4000 x 106 Btu/hr < Heat Input y = 17 x
where y = Ibs/hr of parti cul ate matter
x = equipment capacity rate (10^ Btu/hr)
aFrom: Semi Annual Report (SIP) for Arizona (January-June 1974)
-------
APPENDIX B
Tables B-l and B-2 are the assessment of AQCRs which should be
examined for the fuel switching impact on particulate and SCL emissions.
They also provide an identification of those AQCRs which show little
potential for fuel revision or regulation relaxation if ambient air
standards are to be attained.
The criteria for candidates are (1) the severity and breadth of air
quality violations, (2) the tolerance for emissions increased in the AQCR,
(3) the fraction of total emissions resulting from fuel combustion, and
(4) AQMA designations. It should be noted that an AQCR may not necessarily
need relaxation of regulations in order to accomplish fuel switching.
Further, a good candidate in Tables B-l and B-2 may later show little
potential for fuel switching after individual sources are examined. Finally
it is possible that an AQCR may have air quality levels below standard at
present and may require more strict regulations than currently exist if
all fuel burning sources were converted to dirtier fuels, i.e., "average"
emission rate now may be below "average" regulations.
34
-------
Table B-l. Arizona Candidacy Assessment for Revision of Participate Regulations
CO
in
of
Stations Annual
AQCR
Arizona-New Mexico
Southern Bordera
Clark-Mohave-
Yumaa
Four Corners8
Phoenix-Tucson
"Interstate
Arizona portion of interstate AQCR
Tolerance
for
# of Stations Rpt'g Counties with 1972 Emission
Violations of Nat'l Expected Proposed AQMA Total % Emissions Increase
Secondary Standard Attainment Designation for Emissions from Fuel in 1975 Regionwlde
24 Hour Date Particulates? (tons/year) Combustion (tons/yr) Evaluation
19,900°
1,300°
9.700°
49,200
1.3
*L
23
32
1
9
T
10
8
10
5
26
7/75
7/75
7/75
7/77
No
No
No
No
0.8b
5
81. 3b
3.8
-6000
- 800
-5800
-40,300
Poor
Candidate
Poor
Candidate
Poor
Candidate
Poor
Candidate
-------
Table B-2. Arizona Candidacy Assessment for Revision of S02 Regulations
oo
Air Quality Summary
AQCR
Tolerance
for
# of Stations Rpt'g Counties with 1972 Emissions
Violations of Nat'l Expected Proposed AQMA Total % Emissions Increase
# of Secondary Standard Attainment Designation Emissions from Fuel in 1975 Regionwide
Stations Annual 24 Hour Date for SQ?7 (tons/year) Combustion (tons/yr) Evaluation
Arizona-New Mexa
Southern Border
Clark-Mohave-
Yumaa
Four Corners3
Phoenix-Tucson
17
1
9
17
2
0
0
1
9
0
1
7
7/77
7/75
7/77
7/77
1.
No
No
No
No
947,000b
594b
4300b
889,000
2.7b
8.6b
83. 7b
0.3
-795,000 Poor Candida
c Marginal
Candidate
c Poor Candida
-747,000 Poor Candida
"Interstate.
Arizona portion of interstate AQCR.
°Not calculated, see Table A-ll for explanation.
-------
APPENDIX C
This section is a review of individual power plants by AQCR. The
intent is to illustrate fuel switching possibilities and particulate and
S02 emissions resulting from these switches on an individual plant basis.
Current power plant information used to prepare Table C-l was
obtained from three main sources: (1) Federal Power Commission computerized
listings of power plants and their associated fuel use, (2) the National Coal
Association "Steam Tables" listing of power plants and fuel use in 1972, and
(3) NEDS Emissions data.1 For those plants listed by the FPC (1 above), the
1973 fuel schedule was assumed, otherwise, fuel use is for 1972. Heat inputs
are those based on actual fuel values where known, and average values shown
in Table C-2 were used where not known.. SCL and particulates emissions are
those associated with the fuel use shown. In the case of particulates,
emissions were calculated using NEDS emissions factors applied to the listed
fuel schedule (in both tonnage and lbs/106 BtU). When a plant was not listed
in NEDS, AP-42 emission factors were used to estimate SC^ and TSP emissions
(see Table C-2).
For the purposes here, it is assumed that when a plant is shown to have
dual fuel capability, it is able to use entirely one fuel or the other. A fuel
switch calculation is then made, assuming all natural gas use is replaced by
either oil or coal depending on assumed plant capabilities. Further, oil use
is replaced by coal where possible. The % sulfur in fuel (coal or oil)
assumed when fuels are switched is indicated in Table C-l. A plant was then
assumed to have the same emission controls as was in effect when the NEDS
emissions were assembled. The resulting emissions which would then accompany
such fuel switches are tabulated in both tonnage and lbs/10 Btu.
]NEDS Data Bank 1974.
37
-------
Also shown is the 1975 regulations which are currently applicable to
the given plant, taken from Table A-12. (Particulate limits are assumed
to be based on the entire heat input of the plant. Actual rules may be
different when applied to each of several boilers in a power plant or
applied on the basis of design capacity rather than actual amount of fuel
used.)
The fuel switch calculations are intended to show the magnitude of
emissions increase accompanying a fuel switch without additional controls.
The exact emissions would depend upon actual fuel mix, amount of sulfur in
fuels, and degree of emissions controls (particulates).
It might be cautioned that AQCR total emissions calculated in the
tables of Appendix C may not agree exactly with total emissions represented
in Appendix A (Tables A-8, A-9). This is a result of both differing fuel
schedules in 1973 compared to previous years and the relative "completeness"
of the NEDS data bank.
38
-------
Table C-l. Arizona Power Plant Analysis
co
vo
AQCR
Arizona - New
Mexico Southern
Border
Clark - .tohave -
Yuma
Four Corners
Phoenix - Tucson
Plant
Douglas
Yucca
Choi la
Uavaho
, under
const' n
Octlllc
Phoenli
Saguan
Agua Frla
Capacity
20 Hn
75 IV;
114 Mw
2250 Nu
227 MM
110 ItN
250 Mw,
390 Hw
Fuel Use8
Type Heat
X Sulfur Input
* Ash Annual Quantity (10°Btu/hr)
N/A
011
0.99*5
Gas
Coal
0.44XS
Coal
011
0.81XS
Gas
011
0.7K
Gas
011
' 0.7«
Gas
011
0.63K
Gas
fl/A
N/A
4410 x 103 gal ! 70.4
2548 x 106 ft3 290
452 x 103 tons
N/A
36036 x 103 gal
5342 x 106 ft3
6006 x 103 gal
1218 x 106 ft3
42714 x'lO3 gal
4288 x 103 ft3
105504 x 103 gal'
8923 x 106 ft3
1066
N/A
575
609
96
139
681
489
1683
1017
Emissions
1975 Emission
Limit
1
> Emissions after
£. Fuel Switching^
(tons/Yr) (lbs/106 Btu) (lbs/106Btu)j "> tons/year lbs/10°Btu
SO? Part. SO, Part. SO, Part. >»; SO, Part. SO, .Part.
N/A N/A
!
339 :17.6
0.8
3860
N/A
2265
2
325
0.4
2321
1.3
5159
2.7
19.1
N/A
N/A
144
40
24
9.1
171
32
422
67
N/A
1.1
0.83
N/A
0.89
0.77
0.77
0.7
N/A
.057
N/A
N/A
.057
.057
.057
.059
N/A
2.2
1.0
0.8
1
1
1
1
N/A
0.215 0.9!
0. 34210. 4<
O.llli -
:
0.235
.213
0.126
1738
4651
-
0.81 4664
0.7
0.7
0.212J0.6
796
3988
! 8276
90.1
N/A
-
296
59
294
677
1.09
0.99
-
0.86
0.77
0.77
0.69
0.06
N/A
-
0.06
0.06
0.06
0.06
-------
Table C-l. Arizona Power Plant Analysis (Continued)
AQCR
Phoenix - Tucson
Plant
Cross Cut
Hyrene
Demos s
Petrle
Irving ton
North Loo|
Capacity
30 Mw
108 Hw
105 Hw
505 Itw
75 Mw
Fuel Use"
Type Heat
X Sulfur Input
Z Ash Annual Quantity (ICTBtu/hr)
011
0.77XS
Gas
011
0.75XS
Gas
011
0.73XS
Gas
011
0.6*5
Gas
011
0.4XS
Gas
857 x 103 gal 13.7
813 x 106 ft3
24276 x 103 gal
2844 x 106 ft
93.3
387
324
1
10626 x 103 gal ' 170
4220 x 106 ft3
07352 x 103 gal
f% t
23647 x 10° ft3
2728 x 103 gal
24 x 106 ft3
481
1713
1442
46
2.9
Emissions
(tons/Vr) (lbs/106 Btu)
SO? Pert. SO, Part.
51
0.2
414
0.9
601
1.3
1993
3.E
77C
0
3.4
6.1
97
21.3
42.5
31.7
»29
95
0
0.85
0.83
0.81
0.67
.056
.057
.057
1975 Emission
Limit
(lbs/10°Btu)
S0? Part.
1
1
1
.057 1
0.38 .059 1
i
i
o!
jji Emissions after
i «: Fuel Switching^
i "> tons/year lbs/10°Btu
»: SO, Part. SO, Part.
i
1
0.339'O.J
0.21
0.211
398
i j
I 0.75 2C98
0.7J3 23011
i
0.18^ O.fi 9196
N/A
'
; ,
i
! 1
i
0.4 82
27
178
163
790
13
'
0.85
0.83
0.81
0.38
0.06
0.06
0.06
0.06
0.06
-------
Table C-1. Arizona Power Plant Analysis (Continued)
a!973 data from Federal Power Commission except for North Loop, where data is for 1972 and is from NEDS.
Heat content of natural gas assumed to be 1000 Btu/ft ; for oil, 140,000 Btu/gallon
For emissions from oil:
S02 - 1973 data from FPC.
Particulates - applying EPA emission factors (AP-42) to 1973 fuel use data.
For emissions from natural gas:
S02 and particulates - applying EPA emission factors (AP-42) to 1973 fuel use data.
C1972 data from NEDS
For power plants burning both oil and natural gas in 1973: Convert the amount of natural gas used to an
equivalent quantity of oil with the same sulfur content as used in 1973. Increase the S02 and particulate
emissions by direct proportioning assuming all fuel used is oil.
Example: Yucca Power Plant in Clark - Mohave - Yuma AQCR
fi o
(1) Amount of natural gas used = 2548 x 10 ft
(2) 2548 x 106 ft3 x 1000 Btu/ft3 = 2548 x 109 Btu.
9
(3) 1.4 X2165 btu/ Bt"; = 18«200 x 1(j3 gallons of "equivalent" oil.
(4) Total oil,used = 4410 x 103 + 18,200 x 103 = 22,610 x 103 gallons.
(5) New S09 emissions = 22'610 x ]93 9a110"s x 339 tons/yr = 1738 tons/yr of SO,.
* 4410 x 10J gallons i
For power plants burning coal in 1973: Increase 1973 emissions by the factor a975 Em1ss1on L1m1t <1bs£10 Btu>
1973 Emissions (lbs/105 Btu)
-------
Table C-2. AP-42 Power Generation Emission Factors
Fuel
Particulate
Lbs/Ton Lbs/100 Btu
S02
Lbs/Ton Lbs/10 Btu
Hydrocarbons,-
Lbs/Ton Lbs/10° Btu
NOX (as N02)
Lbs/Ton Lbs/106 Btu
Coal W (Bit.)
General
Wetbottom 10%
Cyclone
1% S
2% S
3% S
Oil «2) .
0.5% S
1.0% S
2.0% S
Gas'3'
(.3 Ibs S/
106 Ft3)
160
A 130
20
Same
as
Above
Lb/103 Gal
8
8
8
Lb/106Ft3
15
7.4
7.0
0.9
Same
as
Above
0.058
.058
.058
.015
38
76
114
Lb/103 Gal
79
157.
314
Lb/106Ft3
0.57 .
It. 65
3.3
5.0
0.56
1.12
2.24
00057
0.3 0.013
:
0.3 0.13
Lb/103 Gal
2 .014
2 .014
2 .014
Lb/106Ft3
! .001
18
30
55
Same
as
Above
0.78
1.3
2.4
Same
as
Above
Lb/103 Gal
105
105
105
Lb/106Ft3
600
0.75
0.75
0.75
0.60
(1) Coal 23 x 10° Btu/Ton
(2) Oil 140 x 103 Btu/Gal
(3) Gas 1000 Btu/Ft3
-------
APPENDIX D
Table D-l in this appendix lists individual industrial/commercial/
institutional sources of particulates and SOp emissions which might show fuel
switching potential. A fuel switch emissions calculation is then made similar
to that performed for power plants.
43
-------
Table 0-1. Industr1al/Commerc1al/Institut1onal Point Source Assessment
AQCR
Arizona - Hen
Mexico So.
Border
Phoenix -
Tucson
Plant
Phelps Dodge,
Horenci
Phelps DOdge,
Cochrse
Phelps Dodge,
Douglas
D.C. Speer
Const.
Ameri can
Smelting &
Refining,
Fuel Use
Type Heat
% Sulfur Annual . Inputb
* Ash Quantity (106Btu/hr)
Oil
0.553SS
Gas
Oil
0.37ZS
Gas
Oil
1.2XS
Gas
Oil
0.33SS
Oil
0.35ZS
Gas
Hayden
3069 x 103 gal
8906 x 106 ft3
715 x 103 gal
380 x 106 ft3
1215 x 103 gal
4456 x 106 ft3
Q
544 x 10J gal
1267 x 103 gal
2773 x 106 ft3
49
1016
11.4
43.4
19.4
509
8.7
20.2
317
' "5
Emissions0
(tons/yr) (lbs/106Btu)
S02 Part. S02 Part.
120
3
21
0
121
1
12
32
1
23
80
6
0
15
40
39
10
25
-0.561
.0006
0.42
0
1.4
.0004
0.3
0.36
.0007
O.il..:
0.02
0.12
0
0.18
0.02
1.02
0.11
0.02
1
(A
CO
M
0.55
0.37
1.2
-
0.35
Emissions after Fuel
Switch^
(tons/year)
S02 Part.
2608
101
3296
-
500
29
409
~
534
167
aFrom NEDS (1973)
Heat content of oil assumed to be 140,000 Btu/gallon. Heat content of natural gas assumed to be 1000 Btu/ft2.
eCalculated from fuel use data and EPA emission factors (AP-42)
Convert the amount of natural gas used to an equivalent quantity of oil with the same sulfur content as used In 1973.
Increase S02 and particulate emissions by direct proportioning assuming all fuel used is oil.
-------
BIBLIOGRAPHY
(1) "1972 National Emissions Report," U.S. Environmental Protection
Agency, EPA-450/2-74-012.
(2) "Projections of Economic Activity for Air Quality Control Regions,"
U.S. Department of Commerce, Bureau of Economic Analysis, Prepared
for U.S. EPA, August 1973.
(3) "Monitoring and Air Quality Trends Report, 1972," U.S. EPA-450/1-
73-004.
(4) "Steam-Electric Plant Factors/1072," 22nd Edition National Coal
Association.
(5) "Federal Air Quality Control Regions," U.S. EPA, Pub. No. AP-102.
(6) "Assessment of the Impact of Air Quality Requirements on Coal in
1975, 1977 and 1980," U.S. Department of the Interior, Bureau of
Mines, January 1974.
(7) "Fuel and Energy Data," U.S. Department of Interior Bureau of Mines,
Government Printing Office, 1974, 0-550-211.
(8) "Compilation of Air Pollutant Emission Factors, 2nd Edition," U.S.
EPA, Air Pollution Tech., Pub. AP-42, April 1973.
(9) SAROAD Data Bank, 1973 Information, U.S. EPA.
(10) Federal Power Commission, U.S. Power Plant Statistics Stored in EPA
Data Bank, September 1974.
(11) "State of Arizona Air Pollution Control Implementation Plan,"
January 1972.
(12) "Semi-Annual Report (SIP) for Arizona, January-June 1974."
45
-------
TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1. REPORT NO.
EPA-450/3-74-072
2.
3. RECIPIENT'S \CCESSION>NO.
4. TITLE AND SUBTITLE
IMPLEMENTATION PLAN REVIEW FOR ARIZONA AS
REQUIRED BY THE ENERGY SUPPLY AND ENVIRONMENTAL
COORDINATION ACT
5. REPORT DATE
December 1974
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
10. PROGRAM ELEMENT NO.
U.S. Environmental Protection Agency, Office of Air
Quality Planning and Standards, Research Triangle
Park, N.C., Regional Office IX, San Francisco,
California, and TRW, Inc., Redondo Beach, California
11. CONTRACT/GRANT NO.
68-02-1385
12. SPONSORING AGENCY NAME AND ADDRESS
U.S. Environmental Protection Agency
Office of Air and Waste Management
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
13. TYPE OF REPORT AND PERIOD COVERED
Final
14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
16. ABSTRACT
Section IV of the Energy Supply and Environmental Coordination Act of 1974,
(ESECA) requires EPA to review each State Implementation Plan (SIP) to determine
if revisions can be made to control regulations for stationary fuel combustion
sources without interfering with the attainment and maintenance of the national
ambient air quality standards. This document, which is also required by Section
IV of ESECA, is EPA's report to the State indicating where regulations might be
revised.
17.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.IDENTIFIERS/OPEN ENDED TERMS
c. cos AT I Field/Group
Air pollution
State implementation plans
18. DISTRIBUTION STATEMENT
Release unlimited
19. SECURITY PLASS (ThisReport/
Unclassified
21. NO. OF PAGES
53
20. SECURITY CLASS (Thispage)
Unclassified
22. PRICE
EPA Form 2220-1 (9-73)
46
------- |