EPA-450/3-74-074 DECEMBER 1974 IMPLEMENTATION PLAN REVIEW FOR MAINE AS REQUIRED BY THE ENERGY SUPPLY AND ENVIRONMENTAL COORDINATION ACT U. S. ENVIRONMENTAL PROTECTION AGENCY ------- EPA-450/3-74-074 IMPLEMENTATION PLAN REVIEW FOR MAINE AS REQUIRED BY THE ENERGY SUPPLY AND ENVIRONMENTAL COORDINATION ACT PREPARED BY THE FOLLOWING TASK FORCE: S. Environmental Protection Agency, Region I J. F- Kennedy Federal Building Boston, Massachusetts 02203 Environmental Services of TRW, Inc. 800 Foil in Lane, SE, Vienna, Virginia 22180 (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 ------- MAINE ENERGY SUPPLY AND ENVIRONMENTAL COORDINATION ACT (SECTION IV - STATE IMPLEMENTATION PLAN REVIEW) Table of Contents Page 1.0 EXECUTIVE SUMMARY 1 2.0 STATE IMPLEMENTATION PLAN REVIEW 5 2.1 Summary 5 2.2 Air Quality Setting -- State of Maine 6 2.3 Background on the Development of the Current State Implementation Plan 9 3.0 AQCR ASSESSMENTS BASED ON SIP REVIEWS 11 3.1 Androscoggin Valley Interstate AQCR 107 11 3.2 Aroostook Intrastate AQCR 108 14 3.3 Down East Intrastate AQCR 109 15 3.4 Metropolitan Portland Intrastate AQCR 110 16 3.5 Northwest Maine Intrastate AQCR 111 18 APPENDIX A - State Implementation Plan Background APPENDIX B - Regional Air Quality Assessment APPENDIX C - Power Plant Assessment APPENDIX D - Industrial, Commercial/Institutional Source Assessment APPENDIX E - Area Source Assessment ------- 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 Implemen- tation Plan (SIP) to determine if revisions can be made to control regula- tions 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 Implementa- tion Plan revisions; ESECA does not, however, require States to change any existing plan. Congress has intended that this report provide the State with informa- tion on excessively restrictive control regulations. The intent of ESECA is that SIP's, wherever possible, be revised in the interest of conserving low sulfur fuels or converting sources which burn oil or natural gas to coal. EPA's objective in carrying out the SIP reviews, therefore, has been to try to establish if emissions from combustion sources may be increased. Where an indication can be found that emissions from certain fuel burning sources can be increased and still attain and maintain NAAQS, it may be plausible that fuel resource allocations can be altered for "clean fuel savings" in a manner consistent with both environmental and national energy needs. In many respects, the ESECA SIP reviews parallel EPA's policy on clean fuels. The Clean Fuels Policy has consisted of reviewing implementation plans with regards to saving low sulfur fuels and, where the primary sulfur dioxide air quality standards were not exceeded, to encourage States to either defer compliance regulations or to revise the S02 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 S02 regulations. These States are generally In the Eastern half of the United States. ESECA, however, extends the analysis of potentially over-restrictive regulations to all 55 States and territories. In addition, the current reviews address the attainment and maintenance of all the National Ambient Air Quality Standards. There are, in general, three predominant reasons for the existence of overly restrictive emission limitations within the State Implementation Plans. These are (1) The use of the example region approach in developing State-wide air quality control strategies; (2) the existence of State Air Quality Standards which are more stringent than NAAQS; and (3) the "hot spots" in only part of an Air Quality Control Region (AQCR) which have been used as the basis for controlling the entire region. Since each of these situations affect many State plans and in some instances conflict with current national energy concerns, a review of the State Implementation Plans is a logical follow-up to EPA's initial appraisal of the SIP's conducted in 1972. At that time SIP's were approved by EPA if they demonstrated the attainment of NAAQS or_ more stringent state air quality standards. Also, at that time an acceptable method for formulating control strategies was the use of an example region for demonstrating the attainment of the standards. The example region concept permitted a State to identify the most polluted air quality control region (AQCR) and adopt control regulations which would be adequate to attain the NAAQS in that region. In using an example region, it was assumed that NAAQS would be attained in the other AQCR's of the State if the control regulations were applied to similar sources. The problem with the use of an example region is that it can result in excessive controls, especially in the utilization of clean fuels, for areas of the State where sources would not otherwise contribute to NAAQS violations. For 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 limi- tations. 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 pre- pare the reports has not permitted the consideration of growth, economics, and control strategy tradeoffs. Also, there have been only limited disper- sion modeling data available by which to address individual point source emissions. Where the modeling data for specific sources were found, how- ever, they were used in the analysis. The data upon which the reports' findings are based are 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. 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 indus- trial processes. States are encouraged to consider the overall impact which the potential relaxation of overly restrictive emissions regulations for combustion sources might have on their future control programs. This may include air quality maintenance, prevention of significant deterioration, increased TSP, NOX, and HC emissions 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 particu- late matter (TSP) and sulfur dioxide (SC^) emissions. This is because sta- tionary fuel combustion sources constitute the greatest source of SC>2 emission and are a major source of TSP emissions. ------- Part of each State's review was organized to provide an analysis of the S02 and TSP emission tolerance 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 Section 2 and Appendix B with other regional air quality "indicators" in an attempt to provide an evaluation of a region's candidacy for changing emission limitation regulations. In conjunction with the regional analysis, a summary of the State's fuel combustion sources (power plants, industrial sources, and area sources) has been carried out in Appendices C, D, and E. The State Implementation Plan for the State of Maine has been reviewed for the most prevalent causes of over-restrictive fuel combustion, emission limiting, regulations. The major findings of the review are: FOR SO?. THERE ARE TWO AQCR's. ANDROSCOGGIN VALLEY AND DOWN EAST WHICH INDICATE SOME POTENTIAL FOR REVISION OF FUEL COMBUSTION SOURCE EMISSION LIMITING REGULATIONS. FOR TOTAL SUSPENDED PARTICULATES, THERE IS ONLY ONE AQCR. METROPOLITAN PORTLAND, WHICH INDICATES ANY POTENTIAL FOR REVISING FUEL COMBUSTION SOURCE EMISSION LIMITING REGULATIONS. HOWEVER, THIS POTENTIAL IS LIMITED DUE TO THE RELATIVELY LOW VOLUME OF FUEL BURNED IN THE REGION. The supportive findings of the SIP review are as follows: Maine currently uses very little coal for fuel combustion. Almost all fuel combustion in the State uses fuel oil. In most cases the use of low sulfur coal and existing emission control technology would be more consistent with national energy policies. Considerably more data are needed concerning the air quality in Maine, particularly in the Aroostook and Northwest Maine AQCR's. It is highly possible that additional clean fuel savings could be realized in these regions if more were known about their air quality status. ------- 2.0 STATE IMPLEMENTATION PLAN REVIEW 2.1 SUMMARY A revision of fuel combustion source emissions regulations will depend on many factors. For example: Does the State have air quality standards which are more stringent than NAAQS? Does the State have emission limitation regulations for control of (1) power plants, (2) industrial sources, (3) area sources? t Did the State use an example region approach for demonstrating the attainment of NAAQS or^ more stringent State standards? Has the State not initiated action to modify combustion source emission regulations for fuel savings; i.e., under the Clean Fuels Policy? Are there no proposed Air Quality Maintenance Areas? t Are there indications of a sufficient number of monitoring sites within a region? t Is there an expected 1975 attainment data for NAAQS? Based on (1973) air quality data, are there no reported violations ff NAAQS? t Based on (1973) air quality data, are there indications of a toler- ance for increasing emissions? Are the total emissions from stationary fuel combustion sources proportionally lower than those of other sources? Is there a significant clean fuels savings potential in the region? t 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. The initial part of the SIP review report, Section 2 and Appendix A, was organized to provide the background and current situation information for the State Implementation Plan. Section 3 and the remaining Appendices ------- provide an AQCR analysis which helps establish the overall potential for revising regulations. Emission tolerance estimates have been combined in Appendix B with other regional air quality "indicators" in an attempt to provide an evaluation of a region's candidacy for revising emission limiting regulations. In conjunction with the regional analysis, a characterization of the State's fuel combustion sources (power plants, industrial sources, and area sources) has been carried out in Appendices C, D, E. Based on an overall evaluation of EPA's current information, AQCR's have been classified as good, marginal, or poor candidates for regulation revisions. Table 2-1 summarizes the State Implementation Plan Review. The remaining portion of the report supports this summary with explanations. 2.2 AIR QUALITY SETTINGSTATE OF MAINE The State of Maine is divided into five AQCR's. These are AQCR 107, Androscoggin Valley Interstate (Maine and New Hampshire); AQCR 108, Aroostook Intrastate; AQCR 109, Down East Intrastate; AQCR 110, Metropolitan Portland Intrastate; and AQCR 111, Northwest Maine Intrastate (Figure 2-1). A summary of the Federal and Maine air quality standards for particu- lates, S02, and N02 is presented in Table A-3. It should be noted that the standards adopted by Maine are more stringent than the respective Federal standards in all cases except N02 where they are identical. Air quality monitoring in Maine is limited, particularly in AQCR's 108 and 111 where there is no monitoring. There are only six continuous S02 monitors in the entire state, one each in Augusta and Lewiston (AQCR 107), two in Bangor (AQCR 109), and two in Portland (AQCR 110). There are 21 additional stations in the state with both particulate and S02 24-hour bubbler monitors. These, however, are distributed throughout only three of the five regions: 107, 109, and 110. One additional particulate moni- toring station is located in Portland (AQCR 110). A summary of Maine Air Quality Status is presented in Tables A-4 and A-5. The number of stations exceeding the standards are presented by AQCR. It is significant to note from the tables that during 1973, there were no violations of any particulate standards within the State of Maine. All ------- TABLE 2-1 STATE IMPLEMENTATION PLAN REVIEW (SUMMARY) "Indicators" Maine TSP SO, Androscoggin Valley AQCR 107 TSP SO? Aroostook AQCR 108 TSP SO? Down East AQCR 109 TSP SO? Metropolitan Portland AQCR 110 TSP S02 Northwest Maine AQCR 111 TSP SOj 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 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 data for NAAQS? Based on (1973) Air Quality Data, are there no reported violations of NAAQS? Based on (1973) Air Ouality Data, are there indications of a tolerance for increasing emissions? Are the total emissions from stationary fuel combustion sources proportionally lower than those of other sources? Do modeling results for fuel combustion sources show a potential for a regulation revision? "ust emission limiting regulations be revised to accomodate significant fuel switching? Based on the above indicators, what is the poten- tial for revising fuel combustion source emission limiting regulations? Is there a significant Clean Fuels Saving potential in the region? Yes Yes Yes Yes Yes Yes No Yes Yes Yes Yes Yes Yes Yes Yes Yes1 No Yes NA No Poor N< Yes Yes Yes Yes Yes No No Yes Good D Yes No Yes NA NA Yes NA Yes Marg Yes No Yes NA NA No NA Yes . Marg. No Yes Yes Yes Yes ^ Yes NA Yes Marg . Yes Yes Yes Yes Yes No NA Yes , Good No Yes Yes Yes Yes Yes Yes MA Yes Good No Yes Yes Yes No No No NA Yes Poor Yes No Yes NA NA No NA No Marg. M Yes No Yes NA NA No NA Yes Marg lo 1 There were violations in the New Hampshire Portion of the reaion. '"Not a significant amount ------- Figure 2-1 MAINE AIR QUALITY CONTROL REGION NORTHWEST MAINE INTRASTATE AROOSTOOK INTRASTATE DOWN EAST INTRASTATE ANDROSCOGGIN VALLEY INTERSTATE (MAINE- NEW HAMPSHIRE) METROPOLITAN PORTLAND INTRASTATE ------- participate violations in AQCR 107 occurred in New Hampshire. Only one violation of an S02 standard (annual) occurred in Maine. That violation, at a site in Portland, only exceeded the standard by less than seven percent. A summary of significant Maine emission sources is presented in Table A-6. The table shows the number of sources by type and AQCR, as well as the total particulate and S0£ emissions. The percentage of the total emis- sions contributed by Maine fuel combustion sources is also shown. Tables A-7 and A-8 follow from Table A-6 by giving a more detailed analysis of existing emissions . It is interesting to note that the Maine portion of AQCR 107 contributes by far the greatest quantity of emissions, while the highest air quality measurements occur in the more highly populated Metropolitan Portland AQCR (110). In general, Maine's air pollution tends to be concentrated in the southern and south-central portion of the state. A high percentage of SOo emissions are accounted for by fuel combustion sources, while about two- thirds of the particulate emissions can be attributed equally to fuel com- bustion, and the wood products industry. 2.3 BACKGROUND ON THE DEVELOPMENT OF THE CURRENT STATE IMPLEMENTATION PLAN The SIP control strategies and regulations were based on the example region approach. Example regions are used when ambient air quality data is available for one but not all of several air quality control regions that have similar emissions. The strategies and regulations thus developed are then applied to the similar regions as well as the example region. The Metropolitan Portland AQCR was used as the example region for the entire state for particulate matter. The City of Augusta was selected as the example region for S02 in the Androscoggin Valley and Down East AQCR's. This region was selected because ambient air quality data were available and this region contains a sulfite pulp mill, a primary source of sulfur dioxide. The Metropolitan Portland AQCR was considered separately for S02 control All emissions data taken from NEDS. ------- since this region has no single large source of sulfur dioxide. The regulation adopted for the control of particulate matter from fuel combustion sources is based on the rated capacity of the fuel burning equip- ment. The regulation is applicable to all fuel burning equipment in the state with a rated capacity greater than three million BTU per hour, and is displayed graphically in Figure A-l. A sulfur content limitation is used to control sulfur dioxide emissions from fuel combustion sources in Maine. Sources in the Metropolitan Portland AQCR are limited to a maximum of 1.5 percent sulfur in all fuels burned; the maximum is 2.5 percent for sources in the other four regions. Maine has no regulations for the control of N02. 10 ------- 3.0 AQCR ASSESSMENTS BASED ON SIP REVIEWS The purpose of this section is to evaluate the available information for the State of Maine and determine the feasibility of revisions to the SIP which would result in clean fuel conservation. The assessments will be made by AQCR addressing each type of fuel combustion source: power plants, large industrial and commercial/institutional sources, and area sources. The assessments must be made for each pollutant separately and are made on the basis of seven criteria: (1) 1973 air quality violations; (2) expected NAAQS attainment dates; (3) proposed Air Quality Maintenance Area (AQMA) designations; (4) total emissions; (5) portion of emissions from Maine fuel combustion sources; (6) regional tolerance for emissions increase; and (7) pollutant priority classifications. Tables B-l and B-2 tabulate these cri- teria for each AQCR for TSP and S02> respectively. The AQCR's are grouped into good, marginal, and poor candidates for regulation relaxation based on the evaluation of all the presented informa- tion. Using available data, any AQCR which displays a 1973 air quality vio- lation would probably be given a poor ranking. Conversely, a region with no violations, no proposed AQMA designations, low to moderate emissions, a positive emission tolerance, and/or a small fraction of emissions from Maine fuel combustion sources would receive a good ranking. All other regions with varying indicators or incomplete or missing data would be evaluated separ- ately and grouped in the appropriate class, most likely a marginal ranking. The source type groups are evaluated separately using such variables for criteria as modeling results, emissions data from the SIP and/or NEDS, and air quality data. 3.1 ANDROSCOGGIN VALLEY INTERSTATE AQCR 107 3.1.1 Regional Air Quality Assessment The Androscoggin Valley AQCR is ranked as a poor candidate for modi- fication of particulate regulations for several reasons. Primary among these is the fact that there were high levels of TSP reported in 1973. Most high 11 ------- levels occurred in the New Hampshire portion of the region. Since the ori- ginal basis used by EPA in establishing the AQCR's was that air quality at any point in a region is affected only by sources in the region, Maine's sources may be having an adverse effect on the air quality levels in New Hampshire. Therefore, further analysis is required. If and only if it can be proven that New Hampshire's air quality is independent of Maine's sources, then this region would probably have the potential for regulation modification. Other negative factors include the relatively large total regional emissions, and a negative tolerance for emissions increase. This AQCR is ranked as a good candidate for modification of S02 regula- tions mainly because of its high tolerance for S02 emissions increase based on 1973 air quality data. Other influencing factors are: no proposed AQMA designations and a relatively low percentage of emissions due to fuel com- bustion. 3.1.2 Power Plant Assessment There are three electric generation facilities in the region. One is a residual oil burning gas turbine in New Hampshire. One is a distillate oil-fired gas turbine located at Farmingdale, Maine, and used only for emer- gency peaking use. The third plant is a 147 megawatt residual oil fired steam generating plant located at Wiscasset, Maine. The plant at Wiscasset, Central Maine Power Company's Mason Plant, is currently burning 2.2 percent sulfur oil. Even though the Maine air pol- lution control regulations allow this plant to burn 2.5 percent sulfur fuel, modeling results indicate that maximum ground level concentrations of S02 may exceed the air quality standards if units three and four switch to 2.5 percent sulfur fuel. The following table shows these results. 12 ------- Table 3-1. Mason Plant Modeling Results (yg/m3)a Maximum Maximum 24-hr Concentration Annual Concentration TSP S02 TSP S02 Nominal Load 172 768 48 8 Maximum Load 175 924 a Modeling Analysis of Power Plants for Fuel Conversion (Group IV), Walden Research Division of Abcor Inc., Sept. 12,1974 Since the Mason Plant burns oil, the Maine particulate regulation allows it a large increase in particulate emissions. However, air quality measurements (as discussed in the regional assessment, Section 3.1.1) pro- hibit any increase in particulate emissions. 3.1.3 Industrial and Commercial/Institutional Source Assessment There are 14 significant fuel combustion particulate sources, and six S02 sources in this category. They contribute one tenth of the Maine portion of the particulate emissions, and one half of the S02. Existing regulations allow an increase in both particulate and S02 emissions, but again the air quality data indicate that this would only be reasonable in the case of S02. No modeling results are available for sources of this type, and therefore no statement can be made concerning the maximum sulfur content which would be acceptable without exceeding the standards. 3.1.4 Area Source Assessment In this region, Maine fuel combustion area sources contribute about five percent of the particulate emissions and about 20 percent of the S02 emissions from sources in Maine. As explained in Section 3.1.1, the air quality prohibits any increase in particulate emissions in this region. There is, however, some room for an increase in S02 emissions, but without detailed area source data and modeling results, it is impossible at this time to make a final assessment of the regulation modification potential for area sources. 13 ------- 3.2 AROOSTOOK INTRASTATE AQCR 108 3.2.1 Regional Air Quality Assessment This region received a marginal rating for both particulate and S02 regulation modification. This rating was based on the fact that there are no air quality monitors located in the region, and therefore it is impossible to evaluate the impact of any fuel switching plan. The region is classified Priority 3 for both pollutants and has no proposed AQMA designations, both indicative of a good regulation modification candidate. Total emissions are also low for both pollutants but fuel combustion sources contribute a rela- tively high percentage of the emissions, particularly for SC^. For these reasons, the region appears qualitatively to be a very good candidate; how- ever, some air quality data must be obtained before a quantitative judgment can be reached. 3.2.2 Power Plant Assessment There is one small (19 megawatt) power plant located in AQCR 108. This is an oil burning steam generation plant currently burning 2.27 percent sul- fur residual oil. Switching the fuel at this plant to the maximum allowable (2.5 percent) sulfur content would increase the S02 emissions by approximately 10 percent, but the impact on air quality cannot be estimated due to the lack of any air quality monitoring data. There is an allowable increase in par- ticulate emissions, but again the impact of this change cannot be evaluated without air quality data. 3.2.3 Industrial and Commercial/Institutional Source Assessment About one sixth of the particulate emissions and almost one half of the 502 emissions in AQCR 108 can be attributed to significant sources in this category. Existing Maine fuel combustion regulations allow an increase in both particulate and S02 emissions from industrial and commercial/insti- tutional sources. It would be unwise, however, to state without qualifica- tion, that the regulations could be modified until air quality data and modeling results are available for analysis. 14 ------- 3.2.4 Area Source Assessment Area sources in this region account for one fifth and one third of the particulate and S02 emissions, respectively. Without detailed area source fuel parameter information, it is impossible to estimate the impact of compliance with existing regulations. Even if this data were available, the advisability of regulation modification cannot be assessed without air quality data. 3.3 DOWN EAST AQCR 109 3.3.1 Regional Air Quality Assessment AQCR 108 was given a marginal rating for particul ate and a good rating for S02 regulation modification. Even though there were no 1973 violations of the particulate standards, no proposed particulate AQMA designations, and only moderate particulate total emissions, the tolerance for emissions increase is very small and, therefore, it was felt that this region was only a marginal candidate for particulate regulation modification. There were no violations of the S02 standards in 1973, no proposed S02 AQMA designations, moderate total emissions, and a high tolerance for S02 emissions increase. Therefore, this region was rated as a good candidate for S02 regulation modification in spite of its somewhat higher than average contribution of total emissions from fuel combustion sources. 3.3.2 Power Plant Assessment One 57.5 megawatt power plant is located in AQCR 109. The plant burns 2.28 percent sulfur residual oil in five boilers, and 0.05 percent sulfur distillate oil in a gas turbine. Maine air pollution control regulations allow an increase in both particulate and S02 emissions from this plant. No modeling data is available for the plant, and, therefore, it is very difficult to evaluate the impact of increased emissions on the local air quality. It is recommended that modeling be accomplished and the results analyzed prior to any decision to increase emissions from this plant. As was discussed in the air quality assessment for this region, the tolerance (based on 1973 air quality data) for increased particulate emissions is very small, but it may be possible, due to the plant's location and prevailing meteorology, that increased emissions will not affect an already critical area. 15 ------- 3.3.3 Industrial and Commercial/Institutional Source Assessment Significant sources in this category contribute about one third of the region's particulate emissions and almost three quarters of the S02 emissions. They are similar to the power plant discussed above in that compliance with existing regulations would result in increased particulate and S02 emissions. These sources are also similar to the power plant in that modeling is required before any definite policy of increased emissions can be formulated. 3.3.4 Area Source Assessment The area source contribution is about ten percent of both the parti- culate and S02 total. No assessment of the feasibility of regulation modi- fication can be made at this time due to a lack of detailed area source data. 3.4 METROPOLITAN PORTLAND INTRASTATE AQCR 110 3.4.1 Regional Air Quality Assessment The Metropolitan Portland AQCR is ranked as a good candidate for modi- fication of the particulate regulations and a poor candidate for S02. The particulate ranking is based on no 1973 air quality standard violations, no proposed AQMA designations, moderate total emissions, a low ratio of fuel combustion emissions to total emissions, and a relatively high tolerance for emission increase. The only negative aspect of the particulate assessment is the Priority 1 classification, but this is overshadowed by the fact that there were no reported air quality violations in 1973. There is an S02 problem in this region. Because of this, the existing state regulations are more stringent on sources located in this region; imposing a maximum sulfur content limitation of 1.5 percent as opposed to 2.5 percent for the remainder of the state. In this study, AQCR 110 is rated as a poor S02 candidate for three primary reasons: (1) an air quality violation during 1973; (2) a high contribution of S02 emissions from fuel combustion; and (3) a negative tolerance for increased S02 emissions. 3.4.2 Power Plant Assessment There are two power plants in this region, the Cape Plant and the Wyman Plant, both operated by Central Maine Power Co. The Cape Plant is 16 ------- a 22.5 megawatt oil fired plant, burning 2.2 percent sulfur residual oil (there are also two oil fired gas turbines at the plant). The plant is currently exceeding the maximum of 1.5 percent sulfur fuel, a reduction to which would lower S02 emissions by over 1000 tons per year. Strict compliance with the particulate regulation would increase the Cape Plant's particulate emissions by almost 500 tons per year. The Hyman Plant is a much larger plant with a generating capacity of 214 megawatts. It burns 2.17 percent sulfur residual oil, with the capability of burning coal. Changing this plant to the maximum allowable sulfur content of 1.5 percent would decrease S02 emissions by over 5000 tons per year. The Wyman Plant can increase its particulate emissions by over 2000 tons per year and still be within the Maine particulate regulations. 3.4.3 Industrial and Commercial/Institutional Sources A comparison of the emissions from the significant sources in this category with the emissions allowed by the regulations indicate that there would be a negligible reduction in particulate emissions (no significant particulate sources) and a large reduction in S02 emissions. With no modeling results, it is again impossible to ascertain whether or not strict compliance with existing regulations is necessary to prevent violation of the standards. It may be true for these sources as well as for the power plants that the S02 regulation could be modified and the resultant air quality still meet the standards assuming every source complied with the less stringent regula- tion. But this possibility can only be explored by a thorough analysis of air quality data, modeling results, and the interactions between plants influencing the air quality in critical areas. 3.4.4 Area Source Assessment Area sources in this region contribute about one tenth of the regional particulate emissions and almost one third of the S02. Sufficient area source data are not available to make a complete analysis of the potential for regu- lation modification from this category of sources. 17 ------- 3.5 NORTHWEST MAINE INTRASTATE AQCR 111 3.5.1 Regional Air Quality Assessment The Northwest Maine AQCR was given a marginal rating for both partic- ulate and S02 due primarily to the fact that no air quality data is available. All criteria indicate qualitatively that the region would be an excellent candidate for both particulate and SC>2 regulation modification. The region is classified Priority 3 for both pollutants; no AQMA's are proposed for either pollutant; total emissions are both extremely low; and the fuel com- bustion contribution of both pollutants to the total is moderate. However, without the benefit of air quality data, a quantitative assessment is impos- sible at this time. 3.5.2 Power Plant Assessment There are no power plants in this AQCR. 3.5.3 Industrial and Commercial/Institutional Source Assessment Emissions from significant sources in this category comprise almost two thirds of the regional particulate and SC>2 emissions. Enforcement of the existing regulations would produce reduction in particulate emissions, but no reduction in S02. The latter is due to the fact that all significant industrial and commercial/institutional emissions are from the combustion of wood and bark. Again, no detailed assessment of the regulation modifica- tion potential can be made at this time due to the lack of air quality data. 3.5.4 Area Source Assessment Area source emissions in this region are unavailable for both parti- culates and S02. 18 ------- APPENDIX A State Implementation Plan Background ------- TABLE A-l MAINE AQCR PRIORITY CLASSIFICATION AND AQMA'S AQCR Priority AQCR Name Androscoggin Val1eyb Aroostook Down East Metro. Portland Northwest Maine Fed # 107 108 109 110 111 Part9 1 3 1 1 3 SO/ 1 3 1 2 3 NO/ 3 3 3 3 3 rupu i ciiiun 1975 358,000 96,400 200,500 359,200 84,800 Proposed AQMA Designations TSP Counties 0 0 0 0 0 SOX Counties 0 0 0 0 0 Criteria based on maximum measured (or estimated) pollution concentration in area: Priority Sulfur oxide: Annual arithmetic mean 24 - hour maximum Particulate matter : Annual geometric mean 24 - hour maximum 1 Greater than 100 455 95 325 2 From - 60 - 260 - 60 - 150 - To 100 455 95 325 3 Less than 60 260 60 150 Interstate region ------- TABLE A-2 ATTAINMENT DATES AQCR # Name Particulate Attainment Dates Primary Secondary Sulfur Dioxide Attainment Dates Primary Secondary 107 108 109 no in Androscoggin Valley Aroostook Down East Metropolitan Portland Northwest Maine 7/75 (a) 7/75 7/75 (a) 7/75 (a) 7/75 7/75 (a) 7/75 (a) 7/75 7/75 (a) 7/75 (a) 7/75 7/75 (a) a Air quality levels presently below standards b Interstate region ------- TABLE A-3 AMBIENT AIR QUALITY STANDARDS (yg/m3) Total Suspended Sulfur Oxides Particul ate Nitrogen Oxides Annual 24 hr Annual 24 hr 3 hr Annual Federal Primary 75^ 260(2) Secondary 60^ 150(2) 1300(2) 100(3) Maine Primary Secondary 100 57(3) 230 1150 100(3) (1) Annual Geometric Mean (2) Maximum concentration not to be exceeded more than once a year (3) Annual Arithmetic Mean ------- TABLE A-4. I1AINE AQCR AIR QUALITY STATUS (1973), TSPe (u9/m3) TSP Concentration Name Androscoggin Valley^' Aroostook Down East Metropolitan Portland Northwest Maine 2nd j Stations Violating Federal Reduction # Highest Ambient Air Quality Standards Required Stations Highest Reading Reading Primary Secondary to Meet AQCR # Reporting Annual 24-Hr 24-Hr Annual 24-Hr^ Annual % 24-HrC % Standardsd 6 107 13 83 291 231 10 1 8 3 23 +39 108 0 -- -000000- 109 8 NA 150 138 NA 0 NA - 0 0 -11 110 9 43 185 99 00 0000 -69 1110 -- -000000- Standard on Which Reduction Is Based Annual - 24-hour 24-hour - a 1973 air quality data in National Air Data Bank as of June 7, 1974. b Interstate c Violations d Formula: or: region . based on 2nd highest reading at any station. (2nd Highest 24-hr - 24-hr Secondary Standard) x 100 2nd Highest 24-hr - Background (Annual - Annual Secondary Standard) x 100 Annual - Background whichever is most stringent. e All noted values occurred in New Hampshire. NA Not available. ------- TABLE A-5. I1AINE AQCR AIR QUALITY STATUS (1973), S02a SO, CONCENTRATION Name Androscoggin Valleyb Aroostook Down East Metropolitan Portland Northwest Maine a b c d 1973 air quality AQCR # 107 108 109 110 in data in # Stations Reporting 24-Hr (Bubbler) 8 0 8 8 0 National (u9/m # Stations Reporting Highest Reading (Contin.) Annual 24-Hr 3 NA 173 0 2 NA 82 2 85 391 0 Air Data Bank as of July 29 3) 2nd Highest Reading 24-Hr 66 - 74 96 - , 1974. % # Stations Violating Reduction^ Ambient Air Quality Stds. Required Primary Secondary To Meet Annual 24-Hrc 3-Hr Standards NA 0 NA -453 000 NA 0 NA -393 10 NA +6 000 Standard on Which % Reduction Is Based 24-Hr - 24-Hr Annual - Interstate region. Violations based Formula: (2n(J on 2nd Highest highest reading at any station. 24-hr - 2nd highest 24-hr Standard) x 100 24-hr or: (Annual - Annual Standard) x 100 Annual whichever is most stringent. NA Not available ------- TABLE A-6 MAINE FUEL COMBUSTION SOURCE SUMMARY Other Fuel Combustion Total Emissions %Emissions From Maine Power Point Sources'3 Area (10^ Tons/Year)d Fuel Combustion Sources AQCR NAME AQCR No. Plants3 TSP SO? Sourcesc TSP SO? TSP S0_2 Androscoggin Valley6 107 2 149 69 8 30.0 68.6 18 69 Aroostook 108 1 4f 3f 1 2.6 7.2 34 96 Down East 109 1 69 89 4 12.1 49.0 41 92 Metropolitan Portland 110 2 O9 59 8 11.8 47.1 21 97 Northwest Maine 111 0 2f 2f 6 0.2 0.01 66 62 a - Maine power plants only b - Maine plants in addition to power plants c - Full counties, partial counties and towns, Maine only d - AQCR total e - Interstate region f - All significant point sources, when combined with power plants, contribute at least 90% of the total emissions from fuel combustion point sources g - All significant point sources, when combined with power plants, contribute less than 90% of the total emissions from fuel combustion point sources ------- TABLE A-7 MAINE EMISSIONS SUMMARY, TSP Total AQCR Name AQCR No. Tons/Year Androscoggin Valley 107 29,979 Maine Portion 27,464 N.H. Portion 2,515 Aroostook 108 2,560 Down East 109 12,128 Metropolitan Portland 110 11,796 Northwest Maine 111 235 Percent Fuel Combustion 20 20 a 21 a 34 41 21 66 Electricity Generation Point Sources Tons/Year %b 645 459 186 32 98 139 0 7a 1 1 1 0 Other Point Source Fuel Combustion Tons/Year 3536 3349 187 349 3778 927 155 Area Source Fuel Combustion Tons/Year 12 1 2a 7a 14 31 8 66 1 ,853 1,708 145 478 1,057 1,388 0 6 6a 6a 19 9 12 0 a - Percentage based only on the portion within the indicated state b - Percentage of total emissions ------- TABLE A-8 MAINE EMISSIONS SUMMARY, S02 AQCR Name AQCR No. Androscoggin Valley 107 Maine Portion N.H. Portion Aroostook 108 Down East 109 Metropolitan Portland 110 Northwest Maine 111 Total Tons/Year 68,618 56,413 12,205 7,200 48,986 47,099 13 Percent Fuel Combustion 85 84 a 94a 96 92 97 62 18,997 10,966 8,031 1,438 4,385 20,672 0 Electricity Generation Point Sources Tons/Year %b 28 iga 663 20 9 44 0 Other Point Source Fuel Combustion Tons/Year %b Area Source Fuel Combustion Tons/Year %b 29,191 26,660 2,531 3,159 36,113 11,376 8 43 47a 21 a 44 74 24 62 10,430 9,517 913 2,326 4,791 13,616 0 15 173 7a 32 10 29 0 a - Percentage based only on the portion within the indicated state. b - Percentage of total emissions ------- TABLE A-9 MAINE FUEL COMBUSTION EMISSION REGULATIONS3 Region Name Androscoggin Valley Aroostook Down East Northwest Maine Region No. Particulates 107 Fig. A-l for all fuel- 108 burning equipment that is 109 fired at a range of 3 million 111 BTU per hour or greater regardless of fuel type SO Maximum sulfur content of any fuel is 2.5% Metropolitan Portland 110 Fig. A-l for all fuel- burning equipment that is fired at a range of 3 million BTU per hour or greater regardless of fuel type Maximum sulfur contect of any fuel is 1.5% a From Maine Air Pollution Control Laws as amended by Public Laws of 1971, 1972 and 1973 ------- Figure A-1 MAINE PARTICULATE ALLOWABLE EMISSIONS 10 or less 4 5 6 7 6 9 100 1000 3 4 6 b ' b 10,000 or more Equipment Capacity Rating (106 BTU/Hr. Input) ------- APPENDIX B Regional Air Quality Assessment ------- TABLE B-l REGIONAL INDICATORS FOR REVISION OF TSP REGULATIONS AQCR Name Androscoggin Valley3 Aroostook Down East Metropolitan Portland Northwest Maine AQCR No. 107 108 109 no m No. of Stations Violating Reporting Standards 13 0 8 9 0 3 0 0 0 0 Expected Attainment Date 7/75 b 7/75 7/75 b Tolerance Any for Proposed Total % Emission Emissions AQMA Emissions from Maine Fuel Increase Designations? (lO^Tons/Year) Combustion (!03Tons/Year) No No No No No 30.0 2.6 12.1 11.8 0.2 18 34 41 21 66 -11.7 - +1.3 +8.1 - a Interstate region b Air quality levels presently below standards ------- TABLE B-2 REGIONAL INDICATORS FOR REVISION OF S02 REGULATIONS AQCR Name Androscoggin Valley3 Aroostook Down East Metropolitan Portland Northwest Maine AQCR No. 107 108 109 no in No. of Reporting 8 0 8 8 0 Stations Violating Standards 0 0 0 1 0 Expected Attainment Date 7/75 b 7/75 7/75 b Any Proposed AQMA Designations? No No No No No Total Emissions (10JTons/Year) 68.6 7.2 49.0 47.1 0.01 % Emission from Maine Fuel Combustion 69 96 92 97 62 Tolerance for Emissions Increase (103Tons/Year +310.8 - +192.6 -2.8 _ a Interstate region b Air quality levels presently below standards ------- APPENDIX C Power Plant Assessment ------- TABLE C-l EXISTING MAINE POWER PLANTS AQCR Name AQCR Androscoggin Valley 107 Aroostook Down East 107 108 109 Metropolitan Portland 110 Northwest Maine 110 111 Plant Name Central Maine Power Co. Mason Central Maine Power Co. Farmingdale Maine Public Service Co. Caribou Bangor Hydroelectric Co. E. M. Graham Central Maine Power Co. Cape Central Maine Power Co. Wyman None 1975 Capacity MW 147 c 19 57.5 22.5 214 Fuel Type oil oil oil oil oil Est. 1975 Quantity 103 Bbl 1662 129d 582d 21 8d 2442 %S by Regul ation 2.5 2.5 2.5 1.5 1 .5 Al lowable I Sa 2.2b NA NA NA NA Boi ler Also Designed for Coal? No No No No Yes S will violate standards. a Determined by modeling results b Currently operating on 2.2% S oil. Modeling results indicate an increase to 2.E c Distillate oil gas turbine. Emergency use only. d 1972 data from Steam Electric Plant Factors, 1973 Edition, National Coal Association, Washington, D. C. ------- TABLE C-2 MAINE POWER PLANT SUMMARY BY AQCR so AQCR Name Androscoggin Valley 107 Aroostook Down East Northwest Maine 108 109 Metropolitan Portland no m 1975 Fuel Required Fuel Type coal oil gas coal oil gas coal oil gas coal oil gas coal oil gas by Regulations3 1-2%S 0 0 0 0 0 0 0 0 0 0 2660 0 0 0 0 2%S 0 1662 0 0 129 0 0 582 0 0 0 0 0 0 0 Emission Reduction Tons/Year0 -2150 -146 -424 6417 0 1975 Fuel by Model 1-2%S 0 0 0 NA NA NA NA NA NA NA NA NA 0 0 0 Required ing° >2%S 0 1662 0 NA NA NA NA NA NA NA NA NA 0 0 0 Emission Reduction Tons/Year^ NA NA NA TSP 1975 Emission Reduction From Existing Regulations (Tons/Year) -1457 -153 -465 -2661 a Coal in tons/year, oil in 103 bbl/year, gas in 10 cu. ft./year b Currently operating on 2.2% S oil. Modeling results indicate an increase to 2.5% S will violate standards. c Based on application of existing regulations. d Based on modeling results. NA Not available ------- APPENDIX D Industrial, Commercial/Institutional Source Assessment ------- TABLE D-l MAINE SIGNIFICANT SOURCES3 NEDS TSP Emissions NEDS S0 Emissions Reduction under existing regulations (T/Yr) % NEDS TSP Emissions AQCR NAME Androscoggin Valley Aroostook Down East Metropolitan Portland Northwest Maine AQCR No 107 108 109 110 in (T/Yr) 3331 335 3193 0 155 (T/Yr) 16,716 3,065 30,246 8,313 8 TSP -1129 - 281 - 510 0 + 121 so2 -3042 -1572 -1297 +2663 0 From Coalb (before regulations) 0 52 0 0 0 a See table A-6. b Only for significant sources not including power plants. ------- TABLE D-2 MAINE SIGNIFICANT INDUSTRIAL AND COMMERCIAL/INSTITUTIONAL SOURCES AQCR Name AQCR No. Androscoggin 107 Valley6 Aroostook 108 Down East 109 Metropolitan 110 Portland Northwest Maine 111 Particulate Sources3 Plant Name Scott Paper Co. International Paper Co. (Androscoggin Mill) Oxford Paper Co. Diamond Match Diamond Match Forster Mfg. Co. (Strong) Statler Industries Marine Colloids Forster Mfg. Co. (East Wilton) International Paper Co. (Otis Mill) Dirigo Dowel , Inc. Stowell - MacGregor Burnham Div. of Ethan Allen Stowell Silk Spool Co. Loring A.F.B. Vahlsing Inc. Sherman Lumber Co. U.S. Gypsum Co. G. Pacific Corp. Great North - Nekoosa Paper (Millinocket) Great North - Nekoosa Paper (E. Millinocket) Penobscot Co. Lincoln Pulp and Paper Forster Mfg. Co. County Kennebec Frank! in Oxford Kennebec Oxford Frankl in Kennebec Knox Franklin Franklin Somerset Oxford Waldo Oxford Aroostook Aroostook Aroostook Androscoggin Washington Penobscot Penobscot Penobscot Penobscot Penobscot No significant points J. M. Huber Corp. Forster Mfg. Co. Penobscot Frankl in SO,, Sources3 Plant Name International Paper Co. (Androscoggin Mill ) Oxford Paper Co. International Paper Co. (Otis Mill) Statler Industries Keyes Fiber Co. Marine Colloids Vahlsing Inc. Loring A.F.B. U.S. Gypsum Co. Great North - Nekoosa Paper (Millinocket) County Franklin Oxford Franklin Kennebec Kennebec Knox Aroostook Aroostook Androscoggin Penobscot Great North - Nekoosa Paper (E. Millinocket) Ga. Pacific Corp. Penobscot Co. St. Regis Paper Lincoln Pulp and Paper Eastern Fine Paper Co. Eastland Woolens Co. Scott Paper Portsmouth Naval Yard Pejepscot Paper Pepperell Brooks Woollen Co. J. M. Huber Corp. Forster Mfg. Co. Washington Penobscot Hancock Penobscot Penobscot Penobscot Cumberland York Sagadahoc York York Penobscot Frankl in Listed in descending order of emissions. ------- APPENDIX E Area Source Assessment ------- APPENDIX E Table E-l presents area source fuel combustion data as contained in NEDS. In the cases where a Maine county is partially contained in two or more AQCR's, it appears that the entire county's data are listed as if the county was contained totally in the lower numbered AQCR. Since AQCR 111, Northwest Maine, is both the highest numbered AQCR in Maine and also is composed entirely of counties which are also located in other (lower num- bered) AQCR's all area source data for the region appear in NEDS as zero. ------- TABLE E-1 MAINE AREA SOURCES3 Fuel Burned Emissions AQCR Name Androscoggin Valley AQCR No. Type 107 Coal: Anthracite Bituminous Oil: Distillate Residual Gas: Natural Process Wood : Amountb 3,160 1,000 165,570 30,960 1,430 0 36,700 % Sc Range of % S 0.7 0.6 0.4 0.2-0.5 2.2 1.9-2.3 ___ __ _ _ TSP 24 28 828 356 13 0 459 1708 S02 41 12 4086 5370 0 0 9 9518 Aroostook 108 Coal: Anthracite Bituminous Oil: Distillate Residual Gas: Natural Process Wood: 960 0 44,530 6,670 380 0 13,500 0.7 0.3 2.6 6 0 223 77 4 0 13 0 948 1361 0 0 169 3 479 2325 ------- TABLE E-l (cont.) Fuel Burned Emissions AQCR Name AQCR No. Type Down East 109 Coal: Anthracite Bituminous Oil: Distillate Residual Gas: Natural Process Hood : Metropolitan Portland 110 Coal: Anthracite Bituminous Oil: Distillate Residual Gas: Natural Process Wood : Northwest Maine 111 Coal: Anthracite Bituminous Oil: Distillate Residual Gas: Natural Process Wood: Amountb % Sc Range of % S 1,850 0.7 0 97,780 0.4 0.2-0.4 16,150 2.3 2.0-2.4 580 0 29,000 - 4,150 0.7 0 145,480 0.7 0.3-0.9 39,400 2.1 1.8-2.2 1,560 - 0 13,100 0 0 0 0 0 0 0 TSP 15 0 489 186 5 0 362 1057 30 0 727 452 15 0 164 1388 0 0 0 0 0 0 0 0 SO? 26 0 1808 2949 0 0 7 4790 54 0 6991 6567 0 0 3 13615 0 0 0 0 0 0 0 0 dNEDS data. DCoal in tons; oil in 1000 gals.; gas in MCF; wood in tons, cAverage weighted sulfur content. ------- |