EPA-450/3-74-C75
DECEMBER 1974
IMPLEMENTATION PLAN REVIEW
FOR
NEW MEXICO
AS REQUIRED
BY
THE ENERGY SUPPLY
AND
ENVIRONMENTAL COORDINATION ACT
U. S. ENVIRONMENTAL PROTECTION AGENCY
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EPA-450/3-74-075
IMPLEMENTATION PLAN REVIEW
FOR
NEW MEXICO
REQUIRED BY THE ENERGY SUPPLY AND ENVIRONMENTAL COORDINATION ACT
PREPARED BY THE FOLLOWING TASK FORCE:
U. S. Environmental Protection Agency, Region VI
1600 Patterson - Suite 1100
Dallas, Texas 75201
Environmental Services of TRW, Inc.
(Contract 68-02-1385)
U. S. Environmental Protection Agency
Office of Air and Waste Management
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
December 1974
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NEW MEXICO
ENERGY SUPPLY AND ENVIRONMENTAL COORDINATION ACT
(SECTION IV - STATE IMPLEMENTATION PLAN REVIEW)
TABLE OF CONTENTS
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 New Mexico 10
2.3 Background on the Development of the Current State
Implementation Plan '8
2.4 Special Considerations for the State of New Mexico 19
3.0 AQCR ASSESSMENTS 20
3.1 Regional Air Quality 20
3.2 Power Plant Assessment 23
3.3 Industrial/Commercial/Institutional Source Assessment 25
3.4 Area Source Assessments 25
4.0 TECHNICAL APPENDICES
APPENDIX A A-"1
APPENDIX B B-1
APPENDIX C Ctll
APPENDIX D D'1
BIBLIOGRAPHY
m
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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 inter-
fering with the attainment and maintenance of the National Ambient Air
Quality Standards (NAAQS). In addition to requiring that EPA report to the
State on whether control regulations might be revised, ESECA provides that
EPA must approve or disapprove any revised regulations relating to fuel
burning stationary sources within three months after they are submitted to
EPA by the States. The States may, as in the Clean Air Act of 1970, initiate
State Implementation Plan revisions; ESECA does not, however, require States
to change any existing plan.
Congress has intended that this report provide the State with
information on excessively restrictive control regulations. The intent of
ESECA is that SIPs, wherever possible, be revised in the interest of con-
serving 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 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.
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To date, EPA's fuels policy has addressed only those States with the
largest clean fuels saving potential. Several of these States have revised
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 Statewide
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 con-
trolling 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 SIPs were
approved by EPA if they demonstrated the attainment of NAAQS £r more stringent
state air quality standards. Also, at that time an acceptable method for for-
mulating control strategies was the use of an example region for demonstrating
the attainment of the standards.
The example region concept permitted a State to identify the most
polluted air quality control region and adopt control regulations which would
be adequate to attain the NAAQS in that region. In using an example region,
it was assumed that NAAQS would be attained in the other AQCRs 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
one percent sulfur oil to be burned statewide where the use of a three percent
sulfur coal would be adequate to attain NAAQS in some locations.
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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 avail-
able 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 perspec-
tive with all sources of emissions such as smelters or other industrial
processes. States are encouraged to consider the overall impact which the
potential relaxation of overly restrictive emissions regulations for combustion
sources might have on their future control programs. This may include air
quality maintenance, prevention of significant deterioration, increased TSP,
NO , and HC. emissions which occur in fuel switching, and other potential air
/\
pollution problems such as sulfates.
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 often constitute the greatest source of SCL emissions
and are a major source of TSP emissions.
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Part of each State's review was organized to provide an analysis of
the S02 and TSP emission tolerances within each of the various AQCRs. The
regional emission tolerance estimate is, in many cases, EPA's only measure
of the "over-cleaning" accomplished by a SIP. The tolerance assessments
have been combined in Appendix B with other regional air quality "indicators"
in an attempt to provide an evaluation of a region's candidacy for changing
emission limitation regulations. In conjunction with the regional analysis,
a summary of the State's fuel combustion sources (power plants, industrial
sources, and area sources) has been carried out in Appendix C, D, and E.
The following map of New Mexico shows the State's AQCRs. (Figure A-l).
The major findings of the review are listed below:
• As required by Section IV of ESECA, the SIP for the State of New Mexico
has been reviewed with particular attention to the most frequent causes
of overly restrictive emission limiting regulations. There are a vari-
ety of State and Federal regulations that apply to stationary fuel com-
bustion equipment in New Mexico. However, 1) none of these regulations
apply to equipment using natural gas, 2) only one of the State's oil burning
facilities has a heat input large enough to be subject to the emission regu-
lation that applies to this type of equipment, 3) the requlation that
applies to SO? emissions from the most sizeable of the State's stationary
coal burning facilities does not require compliance until July 31, 1977,
4) based on information available, particulate emissions from New Mexico's
coal burning facilities exceed the limits imposed by the State's parti-
culate regulation, and 5) the State did not use the Example Region app
approach in developing its control strategy. In light of these facts,
it does not appear that the regulations covering particulate and S02
emissions in the State are overly restrictive.
• Fugitive dust, (especially that from unpaved roads), is a significant
contributor to NAAQS particulate violations in most of the States's
AQCRs. Point sources, (namely power plants and smelters), account for
most of the other air pollution problems in the State.
• The coal burning power plants in the New Mexico portion of the Four
Corners AQCR account for more than half of the State's total hourly
heat input at stationary fuel combustion facilities. Essentially all
of the remaining heat input is provided with natural gas, while oil
makes only a minor contribution.
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FIGURE A-l
/
154)
v
U---L-
1 Ja ^
L J
^ _J
® *"T
1 r1
— — • »• i
A A
-r
*~i P-
r s
L_
— i
!
I C
Region 1 Reg
.-I
Region Name
012 Arizona-New Mexico Southern Border
014 Four Corners
152 Albuquerque - Mid Rio Grande
153 El Paso-Las-Cruces-Alamorgordo
154 Northeastern Plains
155 Pecos-Permlan Basin
156 Southwest Mountains-Augustine Plains
157 Upper..Rto.Grande Valley
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2.0 STATE IMPLEMENTATION PLAN REVIEW
2.1 SUMMARY
A revision of fuel combustion source emissions regulations will depend
on many factors. For example:
o Does the State have air quality standards which are more stringent
than NAAQS?
o Does the State have emission limitation regulations for control of
(1) power plants, (2) industrial sources, (3) area sources?
o Did the State use an example region approach for demonstrating the
attainment of NAAQS or more stringent State standards?
o Has the State not initiated action to modify combustion source
emission regulations for fuel savings; i.e., under the Clean Fuels
Policy.
o Are there no proposed Air Quality Maintenance Areas?
o Are there indications of a sufficient number of monitoring sites
within a region?
o Is there an expected 1975 attainment date for NAAQS?
o Based on reported (1973) Air Quality Data, does air quality meet
NAAQS?
o Based on reported (1973) Air Quality Data, are there indications of
a tolerance for increasing emissions?
o Is the fraction of total emissions from stationary fuel combustion
sources higher than those of other sources?
o Do modeling results for specific fuel combustion sources show a
potential for a regulation revision?
o Must emission regulations be revised to accomplish significant
fuel switching?
o Based on the above indicators, what is the potential for revising fuel
combustion source emission limiting?
o Is there a significant clean fuels savings potential in the region?
This report is directed at answering these questions. An AQCR's potential
for revising regulations increases when there are affirmative responses to the
above.
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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 limit-
ing regulations. In conjunction with the regional analysis, a characteri-
zation of the State's fuel combustion sources sources (power plants,
industrial sources, and area sources) has been carried out in Appendix C,
and D.
Based on an overall evaluation of EPA's current information, AQCRs
have been classified as good, marginal, or poor candidates for regulation
revisions. The following table on page 8 summarizes the State Implementation
Plan Review. The remaining portions of the report support this summary with
explanations. The following map of New Mexico shows the State's AQCR,
and outlines the county boundaries (Figure A-l).
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STATE IMPLEICNTATION PLAN REVIEW - HEW MEXICO
SUMMARY TABLE
|. STATE AQCT012 AQBR 014 AOCR 152 AOCR 153 AHCR 154 AflfR 155 «nrR 15r AOCR 157 AOCR
"INDICATORS"
which are nore 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 date
for NAAQS?
• Based on reported (1973) Air Quality Data,
does air quality meet NAAQS?
• Based on reported (1973) Air Quality Data,
are there indications of a tolerance for
Increasing emissions?
t Are the total emissions 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?
• 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 S02
No
Yes'
Yes1
No
No
No
N/A
N/A
N/A
H/A
N/A
N/A
N/A
N/A
N/A
No
Yes1
Yesl
No
No
No
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
TSP S02
Yes
Yes
Yes
No
No
Yes
No
No
Poor
No
Yes
Yes
No
No
No
Yes
No
No
Poor
No
TSP S02
Yes
N/A3
Yes
No
No
No
Ho
H/A9
Poor
No
Yes
N/A3
No
No4
No?
No
No
N/A9
Poor
No
TSP S02
No
Yes
Yes
No
No
Yes
No
Ho
Poor
No
Yes
No
Yes
Yes
Yes
Yes
No
N)
Vood
Yes12
TSP SO.,
No
Yes
No
No
No
Yes
No
No
Poor
No
Yes
No
Yes
Yes
No
Yes
No
No
Poor
Yes"
TSP SO,
Yes
No
Yes
No*
No
Yes
No
No
Poor
No
Yes
No
Yes
Yes
Yes
Yes
No
No
Good
Ho14
TSP SO,
Yes
Yes
Yes
Yes
Yes
Yes
No
No
Good
Yes
Yes
No
Yes
Yes
Yes
Yes
No
No
Good
Yes
TSP SO,
Yes
No
Yes
Yes
Yes
Yes
No
Ho
Good
No15
Yes
No
Yes
Yes
Yes
Yes
No
No
Good
No15
TSP S02
No
Yes
Yes
No*
No
Yes
Ho
No
Poor
No
Yes
Mo
Yes
Yes
Yes
Yes
No
No
Good
Ho15
TSP S0?
CO
Footnotes arc on the following pqe.
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1. The regulations for power plants and industrial sources exist, but most of the State's fuel combustion stationary sources are
either exempt from direct control, or are not currently directly affected by the regulation because the compliance date is
in 1977.
2. Considering the scope and nature of this review, most of the assessments made in response to this question would necessarily
have to be largely subjective. These assessments would also be subject to varying degrees of error, partially because the
sufficiency of a monitoring network depends not only on number, but also on location of the samplers with respect to major
sources. In some New Mexico AQCRs, meteorology and topography have also been found to be important variables. The responses to
this question should be viewed in light of these factors.
3. In this case, "N/A" denotes not answerable with available data. However, it appears that the State's monitoring network is not
providing a representative picture of this AQCR's air quality.
4. This response is based on air quality va.lues calculated using the NOAA diffusion model. The measured air quality data for this
AQCR does not show TSP NAAQS violations.
5. One station violating the 24-hour secondary standard and one violating the 24-hour primary standard.
6. One station violating the 24-hour secondary standard.
7. This response is based on air quality values calculated using the NOAA diffusion model. The limited measured air quality data
for this AQCR does not show S02 NAAQS violations.
8. The only fuel switch which has any practical importance here is a switch from gas to oil at a facility which has a dual fuel
capability. The heat input level for most of the oil burning equipment in New Mexico was not high enough to make that equipment
subject to the State's regulation. Thus a fuel switch could conceivably occur in which additional amounts of oil could be substi-
tuted for gas, but only to such a level that the applicable emission regulation does not take effect.
9. Since coal is already the major fuel used at stationary sources in this AQCR, and this coal is obtained from relatively nearby
deposits, the potential for significant clean fuel savings is extremely limited. The only possibility for any such savings would
be if the relatively low sulfur coal used in this AQCR was considered a 'clean fuel1, and a high sulfur coal was used instead.
10. For this question, the "Poor" response is usually for those AQCRs in which NAAQS violations already occur. And though the cur-
rently applicable regulations are exerting little, if any, direct limitation on emissions from stationary fuel burning sources
in that AQCR, it is felt that relaxation of these regulations may only aggravate the situation. A "Good"response indicates that
the air quality in.,an AQCR is at such a level that additional emissions could be tolerated without causing UAAQS violations.
With some sources, additional emissions could be achieved within the framework of existing applicable regulations. For example,
using high sulfur oil in such a way that the average hourly heat input is less that 114.15 x 106 BTU/hr, and therefore, not
subject to emission regulations for oil burning equipment.
11. Responses to this question must consider a variety of factors. First, there must be a tolerance for emissions increase in the
AQCR. Secondly, there has to be sources in the AQCR which have a capability to switch to fuels that would effect a clean fuel
savings. The extent to which a facility has a dual fuel capability is not known with certainty in all cases. NEDS fuel
schedules were used to provide information on this matter.
12. This AQCR has three power plants, each which burn both oil and gas.
13. This AQCR has only one power plant which burns both oil and gas.
14. The only major source in this AQCR is a coal burning power plant.
15. This AQCR has no major sources. This could possibly be a reason for its relatively clean air.
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2.2 AIR QUALITY SETTING OF THE STATE OF NEW MEXICO
The state of New Mexico is divided into eight AQCRs. These are listed
below:
012(7) Arizona-New Mexico Southern Border Interstate
014(1) Four Corners Interstate
152(2) Albuquerque-Mid Rio Grande Intrastate
153(6) El Paso-Las Cruces-Alamogordo Interstate
154(4) Northeastern Plains Intrastate
155(5) Pecos-Permian Basin Intrastate
156(8) Southwest Mountains-Augustine Plains Intrastate
157(3) Upper Rio Grande Valley Intrastate
The first number in the above listing are the numbers assigned to these
regions by the U. S. Environmental Protection Agency (EPA) as part of a nation-
wide numbering system for AQCRs. The number in parentheses refers to a
designation system used by the State of New Mexico to identify air quality
control regions within its boundaries. Therefore while the numbers 012, 014
and 153 correspond to interstate AQCRs that span the boundaries of two to four
states, the numbers 7, 1 and 6 correspond respectively to only the portions of
these AQCRs that are within the State of New Mexico. For the intrastate AQCRs,
the areas designated by the two numbering systems match. The numbering system
developed by the State is used almost exclusively in the SIP.
Table A-l and A-2 summarize additional general information that relates
to the AQCRs in New Mexico. In Table A-l the following is listed:
1) priority classifications for the pollutants under study
2) demographic information
3) counties within the State that have been designated Air
Quality Maintenance Areas (AQMAs).
Priority classifications give a quick indication of the extent to which
certain pollutants pose air quality problems for the AQCR. A Priority I list-
ing indicates that relatively high ambient concentrations of the pollutant have
10
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been observed, (or estimated, in the absence of air quality data), in the
AQCR, while the Priority III designation reflects that the pollutant is
generally present in concentrations below NAAQS. In those particular
Priority I regions where the air quality reflects emissions predominantly
from a single point source, the IA classification is used. As shown in
Table A-l, two New Mexico AQCRs were classified Priority IA for both par-
ti culates and SO (Arizona-New Mexico Southern Border (012) and Four Corners
X
(014). Two additional AQCRs were classified Priority I for particulates
(Albuquerque-Mid Rio Grande (152) and El Paso-Las Cruces-Alamogordo (153)).
The latter of these two also had a Priority I classification for SO .
J\
Table A-2 presents the dates at which the various ambient air quality
standards are expected to be attained in each of the State's AQCRs. From
this table it can be seen that some AQCRs have attainment dates beyond the
July 1975 date which was originally prescribed for all states. This situation
indicates that there is evidence (as assessed by either the state or EPA) of
problems that will prevent NAAQS attainment within the time period initially
prescribed by law.
A summary of the Federal and New Mexico ambient air quality standards
for the pollutants under study is presented in Table A-3. Unlike the federal
NAAQS example which stipulate both primary and secondary standards, New Mexico
has only one set of standards. For TSP, these standards include the same values
as the federal secondary standard plus two additional standards for seven and
thirty day averaging periods. If the suspended particulates contain either
beryllium, asbestos, or heavy metals, additional limitations will apply.
The 24-hour and annual secondary national standards that were in effect
3
when New Mexico's SIP was being written were 60 and 260 ug/m , respectively.
And although these standards have since been dropped from NAAQS, New Mexico's
standards for S02 consit of the same values.
The SIP for New Mexico gives a rather comprehensive description of the AQCRs
in the State; a description that includes demographic, meteorological and economic
information, as well as discussions of general air quality. In general, the
State's air quality and air pollution problems were described as being quite
varied. The fact that all regions are classified either Priority I, IA, or III
11
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reflects not only the variety of conditions, but also the extremes which are
present. A total of 61% of State's land area, (which contains 41% of its popu-
lation), is located in areas which are designated Priority III for all pollutants
Close to 35% of the land area, containing 25% of the State's population, is
classified Priority I (or IA) for both particulates and S02> The remaining
portions of the State's land area and population is located in an AQCR which
has a Priority I classification for particulates, and is Priority III
classification for SC^.
With respect to the pollutants that are under study, the SIP indicates that
four AQCRs were then experiencing air pollution problems of one sort or another.
Two of these regions are classified Priority IA for both particulates and SO,,.
Both of these involve interstate AQCRs, but the source responsible for the
pollution is located in New Mexico in both cases. The first of these AQCRs is
Arizona-New Mexico Southern Border AQCR (012). A copper smelter is the major S02
source in this AQCR, while the SIP indicates that dust from unpaved roads
accounts for most of the particulate emissions. The second AQCR with problems is
Four Corners (014). Within this region, which contains portions of four states
(Arizona, Colorado, New Mexico and Utah), there are three major coal burning
power plants. There are also plans for additional large coal burning facilities
at other locations in the AQCR. Two of three current facilities are located in
the New Mexico portion of the AQCR. One of these (the Four Corners Generating
Station) has five units, while the other (the San Juan Power Plant) has
recently put one unit (of a proposed two unit plant) into operation. These
two facilities are less than 20 kilometers apart.
The third of the four problem regions in the State also involves an
interstate AQCR0 This is the New Mexico portion of the El Paso-Las Cruces-
Alamogordo AQCR, and it is classified Priority I for both particulates and
S02 (as well as for all other pollutants except N02). The SIP states that
the basis for these classifications was air quality data and estimated
emissions from within the El Paso, Texas metropolitan area, and that levels
of S02 estimated for the New Mexico portions of this AQCR, (not near El Paso),
are below Federal secondary standards. However, with respect to particulate
matter, the SIP indicates that sizeable amounts are emitted as dust from
unpaved roads in the New Mexico portions of the AQCR.
12
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Albuquerque-Mid Rio Grande (152) is the last of the four New Mexico
AQCRs experiencing air pollution problems. This region is classified Priority
I for particulate, but Priority III for SCL. An Emissions Inventory performed
some time prior to the writing of the SIP attributes 84% of the particulate
emissions to transportation activities. A total of 81% of these transportation
associated emissions are due to dust from unpaved roads.
The SIP recognizes that dust from unpaved roads presents a vexing problem
within the State. The magnitude of this problem for each region is shown in
Table A-4 which lists the portion of an AQCRs particulate emission that is due
to road dust. The most obvious solution to this problem, (i.e. paving the
roads) was found to be too expensive for the State's limited budget. Two
possible approaches to solving this problem were mentioned in the SIP. The
first involved obtaining federal funds for an extensive road paving project,
while the second consisted of proceeding with the State's current paving
program as rapidly as possible. The SIP did not express a preference for
either of these approaches, nor was any indication given of what the State
plans to do to solve the dust from unpaved roads problem.
A summary of New Mexico's 1973 Air Quality Status is presented in Tables
A-5 and A-6. As can be seen from this table, New Mexico's air monitoring
network consists of 57 TSP sampler locations, 28 S02 bubbler locations, and
5 S02 continuous locations. For two of the interstate AQCRs, Arizona-N.M. So.
Border and Four Corners the number of TSP monitors located in New Mexico is
generally more than its equal share. (New Mexico has 71% of the stations in
the first of these, a two state AQCR, and 35% of the stations in the four state
Four Corners AQCR). The third interstate AQCR (El Paso-Las Cruces-Alamogordo)
is shared with Texas, however, only 22% of the TSP monitors are within New
Mexico's borders.
The manner in which S02 monitors are distributed between New Mexico
and other states in interstate AQCRs follows the same general pattern as
was described in each of the cases mentioned above (i.e. for the two AQCRs,
New Mexico has more than its share, and for the third, most of the monitors
are in Texas). One intrastate AQCR (S.W. Mtns.-Augustine Plains (156)) has
no S02 monitoring stations. The fact that the TSP readings for this AQCR
are some of the lowest in the State might lead one to expect that S02 levels
would be correspondingly low.
13
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The data presented in Tables A-5 and A-6 also shows (1) the various high
and second high readings, (2) the number of stations exceeding ambient air
quality standards, and (3) the % reduction of emissions required to meet these
standards. This last item was based on applying the proportional model to the
air quality data given. A negative rollback indicates the 1973 air quality
measurements were below the Federal Secondary Standards, and that increases in
emission could possibly take place without causing violations of these standards.
With the notable exception of the Four Corners AQCR(014), the TSP measure-
ments in the regions generally reflect the priority designations for this
pollutant. The highest TSP readings in the State occur in the El Paso-Las CruceS'
Alamogordo AQCR(153), but data shows that even higher levels were recorded in
Texas. Such a finding would be in line with the SIP conclusion that most of the
emissions in this AQCR are due to sources in Texas. All high and second high TSP
readings in the Arizona-New Mexico Southern Border Interstate AQCR (012) were
recorded in New Mexico.
Due to a variety of reasons, the air quality setting in the Four Corners
AQCR is somewhat more complex with respect to the pollutants under study. First
the highest TSP measurement recorded for the New Mexico portion of this AQCR was
below the secondary ambient standard. This is unexpected considering the
massive emissions of the Four Corner's Generating Station, and the existence
of other particulate sources in the New Mexico portion of the AQCR.
Secondly, a set of S02 readings provided by the SAROAD data bank have
since been invalidated by EPA, Region VI. SAROAD reported listings of 4009
and 4008 ug/m , respectively, as the highest and second highest 24-hour
measurements for the Four Corners AQCR (014) in 1973. Though these values
had been obtained using the bubbler method of sample collection, a continuous
monitor at the same location recorded 28 ug/m as the 24-hour maximum for
the year. In light of the two methods used, the two sets of values are
incompatible. Further examination of the day-to-day record of bubbler data fcr
this station was performed by EPA, Region VI. This examination uncovered a
series of highly questionable readings. The 4009 and 4008 values were in-
cluded in this series. Based on this finding, these readings were deemed
14
-------
invalid. With the removal of these values, the highest remaining 24-hour
S02 concentration recorded in the AQCR became 79 ug/m3 (measured on a
continuous monitor located in Mew Mexico).
Thirdly, a special set of circumstances has made it necessary to use
air quality data derived from a diffusion model for the Four Corners AQCR,
rather than to utilize SAROAD data. Thus the air quality values listed in
Table A-6 for the Four Corners AQCR represent maximum S02 concentrations
predicted to occur within the AQCR due to the simultaneous operation of the
San Juan and Four Corners power plants (both located in New Mexico). The
predictions were made using the diffusion modeling developed by the National
Oceanic and Atmospheric Administration (NOAA) for the Southwest Energy Study.
The model was originally used to make predictions of the location and mag-
nitude of the maximum pollutant concentrations that would result from the
operation of coal burning power plants that either currently exist, or are
proposed for the Southwest.
The particular values shown in Table A-6 were obtained from EPA's
Implementation Plan Evaluation Report for New Mexico's SIP. The infor-
mation presented there is reproduced below:
Estimated Maximum Concentrations of Sulfur Oxides
Projected from 1977 Emission Levels
Standard and Predicted Distance from Percent
Averaging Time Concentration* Four Corners Control
(ug/m3) Plant Required
Primary Secondary
Standard Standard
Annual Average 38 50 Km. SW 0% 0%
24-Hour 2670 30 Km. NNE 86%
3-Hour 13300 30 Km. NNE - 90%
*Based on 20% control of Four Corners units 1, 2, 3 from planned wet scrubbers.
15
-------
The "circumstances" that led to use of the model are 1) the relatively
dense concentration of large coal burning power plants that are either now
operating or proposed for the AQCR, 2) the area's topography and meteorology,
and 3) extremely limited and inadequate air quality data for the region.
The lack of adequate S02 air quality data for the Four Corners AQCR
seems to have been a long standing situation. The region's priority
classification (made in November 1971) was based primarily on the level of
emissions, expected from the power plants because measured air quality data
was quite limited.
Reference to limited S02 data is also made in the State's SIP. In the
section where the control strategies for the Four Corners AQCR are being
evaluated, the statement is made, "The sulfur oxide and nitrogen oxide measure-
ments are subject to some question since they were made only at two sites and
over a fairly short time period." Though additional comments were made to
lend credibility to these measurements, the statement does indicate the
existence of limited data for this AQCR.
Although New Mexico's 7 bubbler and 4 continuous monitors (listed in
Table A-6) are substantially more than the two used in the SIP's control
strategy evaluation, it should be noted that a total of nine sites are
actually being monitored, since two locations have both types of monitors.
A number of reasons can be identified as to why air quality data is
limited for the Four Corners AQCR. Most of them revolve around the inability
to place samplers at the locations where maximum concentrations are likely to
occur. This is, in part, due to the terrain of these areas which is quite
rugged, and to a large extent inaccessible. The out-of-the-way location of
these sites also makes it difficult to provide the power needed to operate the
samplers.
The meteorology and topography of the Four Corners AQCR also play a role.
Their interaction with the emission plumes of the region's power plants tend to
produce fumigation effects. That is, instead of emissions being mixed and dis-
persed in the air masses at stack height elevations, conditions are often such
that a stream of only partially diluted pollutants turbulently descends to ground
level. Furthermore, this fumigation effect acts in such a way that location of
the place of highest concentration varies significantly from day to day. Thus
16
-------
sampling could occur over a period of years prior to measuring these high
concentrations.
Though much controversy has developed around the use of NOAA's diffusion
model, it is not unusual for diffusion modeling to be used to predict air
quality levels. The Code of Federal Regulations (CFR) clearly indicates that
such models can be used for this purpose in the absence of air quality data
(40 CFR Part 52). In fact, the Air Quality Display Model (AQDM) was used in
the SIP to provide predictions of pollutant concentration for some of the
AQCR's experienceing air pollution problems. And though these results were
not used in the control strategy evaluation, they did serve to add credence
to the low ambient SOp levels measured by the State's monitoring network.
However, unlike the NOAA model, the model used in the SIP did not take
into account the area's topography. The consideration of a region's topo-
graphical variation is a requirement whenever diffusion modeling is used.
The SIP model also failed to estimate short term SC^ concentrations.
Therefore, it could not determine whether the 3-hour SCL standard would be
violated.
When the NOAA model was used, and topography and short term concentration
levels were considered, the ambient S02 values that were calculated were much
higher than those predicted by AQDM. This finding prompted EPA to require a
greater degree of emission control at the Four Corners and San Juan power plants.
To a large extent, it is this requirement for greater control, (as based
on the NOAA model) which is the cause of the controversy referred to above.
The EPA has prescribed 70% control for the power plants in question, to be
achieved with the use of alkaline scrubbers. The compliance date is July 31,
1977. The power companies concerned do not feel that 70% control is necessary,
and therefore have contested this ruling. (See 39FR 10582 and 38FR 7551.)
Two of the major points of contention in this controversy are: 1) The validity
of assumptions incorporated in the model, 2) the insufficiency of air quality
data available for correlating diffusion model predictions.
However, though realizing that there are drawbacks and uncertainties
associated with using models, EPA's policy is that the result of the NOAA
model are useful in that they indicate potential problem areas and the
17
-------
approximate magnitude of ambient air quality concentrations. In the case of
Four Corners, the substantially high concentrations that are predicted are
sufficient to require application of best available control technology to the
power plants in question. It is also EPA's position that the NOAA model has
sufficiently sound technical basis to justify the requirement that a substan-
tial control of emissions will be necessary for the attainment and maintenance
of NAAQS in the Four Corners area.
2.3 BACKGROUND OF THE DEVELOPMENT OF THE CURRENT STATE IMPLEMENTATION PLAN
The SIP stressed the fact that the different regions of the State had quite
different air pollution problems. To deal with this situation, individual con-
trol strategies were designed to address the particular types of problems that
were present in certain parts of the State. Thus the Example Region approach
was not used in New Mexico.
The foundation of the control strategies consists of a series of State
air pollution control regulations. And though they generally apply statewide,
the regulations are written in such a manner that the desired control is
directed towards specific problematic sources. In this way a regulation, which
limits the amount of particulate material that can be emitted from stationary
coal burning equipment, would obviously have most of its effect on the Four
Corners power plant, which according to 1972 NEDS data, accounts for 99.4% of
coal burned at the State's stationary sources.
Included in the SIP are evaluations of the regulations that have been
developed to deal with the pollution problem in each of the Priority I or IA
AQCRs. These evaluations were made using the emission and available air
quality data in these regions. With respect to point source fuel combustion,
New Mexico has essentially four regulations that relate to the control of S02
and particulate emissions. Two of the regulations apply to each of these
emissions from coal burning equipment, while the other two cover oil burning
equipment. There are no emissions limitations associated with the combustion
of natural gas at stationary sources. These regulations are summarized in
Table A-12.
18
-------
The general conclusion of the SIP was that its evaluation of the control
strategies demonstrated that the New Mexico Air Quality Control Regulations
will be successful in meeting primary and secondary Federal ambient standards
by 1975, except for the problems caused by dust from unpaved roads. In that
little control could be exerted over the particulate emissions associated with
unpaved roads, the SIP predicted that even fully implemented regulations would
not prevent the allowable limits of emissions from being exceeded in two
regions, (New Mexico portions of the Arizona-New Mexico Southern Border and of
El Paso-Las Cruces-Alamogordo AQCRs). And the assumption is that when these
limits are exceeded, violations of the ambient air quality standards (in these
cases, both primary and secondary) will be the result.
2.4 SPECIAL CONSIDERATIONS
Three counties within New Mexico have been proposed as AQMAs, as shown in
Table A-l. It is anticipated that special requirements for these areas will
be developed, and ultimately result in modifications to the SIP.
The State of New Mexico is currently writing new regulations for
particulates and S02 as a result of EPA's disapproval of control strategies for
these two pollutants. In addition, the EPA is writing smelter regulations for
the smelter operation at Hurley. New regulations may have a significant effect
on the State's overall air quality, and therefore on the assessments of this
report.
19
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3.0 AQCR ASSESSMENTS
3.1 REGIONAL AIR QUALITY ASSESSflENT
Using the 1973 air quality data (Tables A-5 and A-6), as a basis, it
is possible to identify AQCRs which are not plagued with relatively severe
air pollution problems. As far as particulates are concerned, these AQCRs
would include Pecos-Permian Basin (155), and Southwest Mountains-
Augustine Plains (156). These are the only regions which have particulate
air quality below the national secondary standards. And though the New
Mexico portion of the Four Corners AQCR has measured TSP air quality cleaner
than NAAQS, it is not included in this list because a region's candidacy is
based on the acceptability of the entire AQCR. For S02> the list would include
all AQCRs except Arizona-New Mexico Southern Borders (012), and Four Corners
(014). The El Paso-Las Cruces-Alamogordo would be a marginal case in that its
air quality is just slightly over the secondary standards, and according to
the SIP, when Texas brings its smelter into compliance, most S02 emissions to
the region will be curtailed.
Table A-7 presents a listing by AQCR of the number of power plants and
other fuel combustion point sources that produce particulate and S02 emissions
in New Mexico. The total given for each of the three interstate AQCRs applies
only to the New Mexico portions of these AQCRs. Inclusion of both NEDS, and
FPC data serves to not only note the existence of more than one source of
information, but also points up. data inconsistencies.
The most current data available was used to compile the S0? and parti-
culate emissions data shown in Tables A-8 and A-9 respectively. These tables
show that the bulk of S02 emissions (98%) are due to three AQCRs: (Arizona-
New Mexico Southern Border, the smelter at Hurley being the main source; Four
Corners, with its power generating units, and the Pecos-Permian Basin with a
sulfuric acid plant and petroleum facilities that emit sulfur compounds.)
In only one of these AQCRs, (Four Corners), is a sizeable percentage of
these emissions due to point source fuel combustion. A similar situation
holds for the particulate emissions as shown in Table A-9.
20
-------
Tables A-10 and A-ll present the result when a proportional model is
applied to 1973 air quality data to estimate the tolerance for emission
increases. This display should be viewed in light of the limitations mentioned
in Section 1.0. It should also be noted that the tolerance for S02 emissions
for the Four Corners AQCR is based on calculated air quality resulting from
the NOAA model.
The magnitude of a negative tolerance for emissions increase, (as shown
in Table A-ll) should not be used as a measure of an AQCR's relative standing
in terms of tolerating more emissions. This magnitude is very much affected by
the total emissions in the AQCR. Thus, the -4800 ton TSP tolerance for the Hew
Mexico portion of the El Paso-Las Cruces-Alamogordo AQCR (153) does not reflect
the fact that this region has higher ambient TSP levels than does the Albu-
querque-Mid Rio Grande AQCR (which has a TSP tolerance of -13,300 tons).
The inclusion of information from the SIP (in Tables A-10 and A-ll) is
meant to summarize some of the State's air quality goals and objectives.
In some instances particulate reductions are minimal even after full controls
are in effect. This reflects some of the problems associated with areas
where a sizeable proportion of the particulate emissions are due to dust from
unpaved roads.
Tables B-l and B-2 provide summaries of the general data that should be
considered when estimating the potential for regulation relaxation. The
overall regional evaluation on this chart is based on the tolerance for
emission increase, and the other, air quality indicators referred to in
Section 2.1.
The conclusions that arise from the data presented in Tables B-l and B-2
is that there are areas in New Mexico where the air is clean enough to tolerate
additional emissions, and, based on the validity of the methodology used,
presumably not violate air quality standards. Note that this does not mean
that regulations can (or should) be relaxed. All that is being said is that
the air is cleaner than federal standards say it has to be.
There could be any one of a myriad of reasons why the air in these regions
is so clean. Over-restrictive regulations is only one possibility. However,
though no definitive conclusions can be. drawn at this time, other bits of
21
-------
information tend to suggest that over-restrictiveness of the regulations is
not the reason for the desirable air quality in the candidate regions.
The first bit of information regards the way the regulations themselves
are written. Since there are no regulations for S02 and particulate emissions
from gas burning equipment, it would appear that these combustion sources are
in no way controlled.
It would also appear that there are no emission limits for oil burning
equipment that has an average heat input of less than 114.15 million Bills/hour.
It is shown in Appendices C and D that only one of the State's stationary sources
uses enough oil to satisfy this requirement. Thus, there are no emission limits
for the remaining 6 stationary fuel combustion sources which use oil.
The result of these two situations is that the fuel combustion that
produces approximately 51% of the State's BTUs from stationary sources (i.e.
that due to oil and gas) is not affected by New Mexico's air pollution control
regulations. (These fuel combustion processes include essentially all power
plants = 11,525 million BTUs/hour and the other major industrial/commercial/
institutional point combustion sources = 604 million BTUs/hour. The San Juan
plant was not included in this calculation.)
The remaining 49% is composed of the two major coal burning sources:
the Four Corners Generating Station and a much smaller power plant with about
1/lOOth the heat input of the Four Corners plant.
New Mexico has regulations on the books that apply to the SCL and
particulate emissions from the State's coal burning facilities. But the emis-
sion regulations that are currently applicable to the coal burning plants that
produce essentially all of the emissions (namely the Four Corners and San Juan
plants) have been promulgated by EPA. As previously noted, these regulations
have a July 31, 1977 compliance date. Therefore, until this date the emissions
from these sources are not subject to limitations.
Thus it would appear most of the State's fuel combustion takes place
without the emissions being limited. There are no emission limiting regu-
lations for gas burning equipment. The State's oil burning facilities do not
have high enough hourly heat inputs to be covered by the emissinn,
regulations for this type of equipment. And though there are S02 emission
22
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limiting regulations for New Mexico's coal burning power plants, the date
for compliance to these regulations is in the future. In light of this
situation, it cannot be concluded that the good air quality in those AQCRs
that exhibit a tolerance for emissions increase is due to overly-restrictive
regulations.
Based on the information presented in Tables B-l and B-2, two AQCRs
in New Mexico have a potential for accepting additional particulate emis-
sions into their atmosphere, and five have a similar potential for accepting
additional SC>2 emissions. The particulate candidates are the Pecos-Permian
Basin (155) and Southwestern Augustine Plains (156) AQCRs. The S02 candi-
dates are all of New Mexico's AQCRs, except Four Corners (014), Arizona-
New Mexico Southern Border (012), and El Paso-Las Cruces-Alamogordo (153).
This last region was not considered a good candidate for increased S02 emis-
sions because it has a negative tolerance for emissions increases, and the
major polluting source is outside of New Mexico's control. However, it
should be noted that once Texas effects proper controls over the El Paso
non-ferrous smelter, the corresponding expected improvement in air quality
might make this AQCR a candidate.
3.2 POWER PLANT ASSESSMENT
There are currently a total of thirteen power plants in New Mexico
according to NEDS printout sheets. (NEDS rank order data shows a total
of 18, while FPC data retrieval from the EPA shows 13. See Table A-7).
Pertinent combustion and emission data relating to these plants (as
obtained from the NEDS sheets) is presented in Table C-l.
The statistics for all other plants are dwarfed by those for the
Four Corners plant. The high annual quantity of coal used (in tons), the
high heat input and massive emissions dominate the power plant sector.
This one plant accounts for more than one-half of the heat input for all
of the State's power plants listed in the Appendices. Note that the heat
input for the San Juan plant was not included in this assessment because
the appropriate data was not available.
23
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It should also be noted that the other much smaller coal burning power
plant is generally much cleaner than the Four Corners plant, and though it
violates New Mexico's existing and future particulate regulations, the S02
emission limits are met.
Outside of the Four Corners plant, most of the heat input for the
State's power plants is provided with natural gas. Oil provides only about
2.4% of the heat input used for all of New Mexico's power plants. Though
the total heat input contribution of oil is small for the power plants, six
of the thirteen plants use oil in addition to gas. If a power plant which now
uses only a small amount of oil, changes so that all of its required heat
input would be provided by oil, then it may be subjected to the S02 and
particulate emission regulations that apply for units with heat inputs
greater than 114.15 x 10 BTU/hour. Based on their current use of oil, some
installations would have difficulty in meeting these SOp regulations depending
on whether their equipment is classified as new or existing. It is expected
that all facilities would have difficulty with the 0.005 lbs/106 BTU
particulate limit.
Six of New Mexico's 13 power plants are currently using oil, in
addition to.th.eir major fuel, natural gas. The total heat input of all fuels
to these six plants is 3873 x 106 BTU/hour (33.6% of the total heat input to
power plants). Therefore, assuming that the combustion equipment at these
plants is technically able to use oil to supply the plant's total heat input
requirements, then these plants represent potential and flexibility for fuel
switching. But based on the emission data presented in Table C-l, it would
appear that such plants could not meet the emission limitation that would be
imposed on them once their heat input passed the 114.15 x 106 BTU/hour mark.
It should be noted that 14% of the total heat input used in New Mexico's
power plants, is associated with plants located in the Pecos-Permian Basin AQCR
(155), a candidate area. Two of these plants use oil in addition to natural
gas.
This analysis does not take into account that the San Juan power plant
(a coal burner) has recently gone on line in New Mexico. Emissions from this
plant may have some impact on air quality, especially in the Four Corners AQCR
where it is located.
24
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3.3 INDUSTRIAL/COMMERCIAL/INSTITUTIONAL SOURCE ASSESSMENT
Table D-l presents the pertinent fuel combustion data for point sources
in the industrial sector. Of the five sources listed, only one uses oil in
addition to natural gas. The remaining ones use gas exclusively.
It is not known to what extent a fuel switch or the relaxation of
regulations can take place in these facilities, but it should be noted that a
total switch from gas to oil in the one industrial facility that burns oil
would result in the S02 and particulate emission regulations for oil burning
equipment to take effect (once a heat input of 114.15 million BTU/hour is
reached).
3.4 AREA SOURCE ASSESSMENTS
There were no area sources in New Mexico which could be evaluated within
the context of Section IV of ESECA.
25
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APPENDIX A
• State implementation plan information
• Current air quality information
• 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 S02 and TSP monitoring stations are shown
for AQCRs in the State. NEDS emissions data by AQCR1 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 S02 and particulates.
The intent of this calculation is to indicate possible candidate regions
for fuel switching. 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:
The "allowable emissions" were calculated for each AQCR based on 1972 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).
The percentages used in this calculation were obtained via the use of
current 1973 air quality data and the proportional rollback model. The
values for background TSP concentrations were the same as those used in the
SIP. This background value was used in all calculations involving the
annual standard, but a zero TSP background was assumed for the calculation
of reductions based on the 24-hour standard. (This was done because back-
ground levels are, in effect, an annual average, and therefore, should be
In1972 National Emissions Report," EPA - 450/2-74-012, June 1974.
A-l
-------
compared with only annual data. It is reasonable to expect that the
"real background" for any particular 24-hour period to be different for
other 24-hour periods.)
The NEDS emissions are subtracted from the "allowables" to determine
the tolerance for emissions increase. A positive value for this result
indicates a potential for increasing emissions.
When the current air quality levels were less than one-half of the
level represented by an ambient air quality standard, no "rollup" emissions
tolerance was calculated in Tables A-10 and A-ll. This arbitrary cutoff
point was chosen so as not to distort the emissions tolerance for an area.
At low levels of a pollutant, the relationship between emissions and air
quality is probably not linear. Although this cutoff may leave some AQCRs
with np_ 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
geographically dispursed emissions.
A word of caution regarding particulates needs mentioning. Emission
source estimates in the NEDS data bank and most state SIP's are for total
particulates. Generally, the control strategies for particulates are
aimed at total particulates, while the high-volume particulate sampling
(SAROAD data) measures only the finer, suspended fraction. A given level
of total particulate emissions control will therefore not translate into
the same level of measured ambient air quality. Some of the larger
particulates being controlled will not remain suspended, and therefore would
not be measured by the High-volume technique. Hence, particulate control
plans may have underestimated the amount of control necessary to achieve
ambient air quality standards.
A-2
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Table A-l. AQCR Priority Classification and AQMAs
I
to
AQCR
Ariz. N.Mex,
So. Border
Four Corners
Albuquerque-
Mid Rio Grande
El Paso-Las
Crues-Alamogord
Northeastern
Plains
Pecos-Permian
Basin
Southwest Mts.-
Augustine
Plains
Upper Rio
Grande Valley
Fed. #
012
014
152
153
154
155
156
157
Part? S0xb NO c
IA 1A III
IA IA III
I III III
I I III
III III III
III III III
III III III
III III III
Demogra
Population
1970
38,470
90,000
353,000
125,619
54,738
233,648
40,880
93,738
hie Information e
Souare
Miles
10,374
12,500
5,000
18,335
22,747
23,749
20,256
6,136
I II III
Priority Greater than From- to Less than
'Sulfur oxide:
Annual arithi
24-hour maxi
Parti cul ate ma
Annual geome
24-hour maxi
netic mean. . 100
num 455 2
tter:
:ric mean . . 95
num 325 1
60-100 60
60-455 260
60- 95 60
50-325 150
Nitrogen dioxide 110 1-1-°-
As indicated in
elnformation obt
Population
Density
3.7
7.2
70. 6f
6.8
2.1
9.8
2.0
13.3
AQMA Designations
TSP Counties
None
None
Bernalillo
Dona Ana
None
None
None
Sants Fe
SOX Counties
Hone9
Flone9
None
None
None
None
None
None
the Proposed Air Quality Maintenance Designations for New Mexico: Background and Rationale, EP
ained from SIP
NOX Counties
Honeh
None
None
None
None
None
None
None
AJ Region VI
Average for the entire region, but the two counties that comprise this region vary widely in population density. One county
(Sandoval) is sparsely populated, while Bernalillo County has 271.5 people per square mile.
9Grant and San Juan counties in AQCRs 012 and 014, respectively, had originally been proposed as SOX AQMAs. However, recent
information (November 1974) from EPA-Region VI indicates that their current thinking favors dropping these proposed
designations.
For New Mexico portion of AQCR only.
-------
Table A-2. New Mexico Attainment Datesb
AQCR #
012
014
152
153
154
155
156
157
Name
Arizona-New Mexico
Southern Border
Four Corners
Albuquerque - Mid Rio Grande
El Paso-Las Cruces-Alamogordo
Northeastern Plains
Pecos-Permian Basin
Southwest Mountains -
Augustin Plains
Upper Rio Grande Valley
Particulates
Attainment Dates
Primary Secondary
7/75
a
7/75
7/75
a
a
a
a
7/75
7/75
7/75
7/77
a
a
a
a
Sulfur Dioxide
Attainment Dates
Primary Secondary
7/75
7/77d
a
7/75
a
a
a
a
c
7/77d
a
7/75
a
a
a
a
Nitrogen Oxides
Attainment Dates
a
a
a
a
a
a
a
a
a) ambient air quality levels did not exceed HAAQS at time attainment dates were formalized
b) based on information supplied by EPA - Durham
c) 18 month extension granted
d) these were originally given as 3/76, but subsequent extensions have been made to the 7/77
date (see 39 FR 10582, March 21, 1974).
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Table A-3. Ambient Air Quality Standards, New Mexico
fall concentrations in
Federal
(Nov, 1972)
Stateb
Primary
Secondary
Total Suspended Parti cul ate
Annual 24 hr.
75 (6)
60 (G)
60 (G)
260a
150a
150
Sulfur Oxides
Annual 24 hr. 3 hr. 1 hr.
80(A)
--
60(A)*
365a
—
260a*
—
1300a
__
Nitrogen
Dioxide
100(A)
100(A)
100(A)
(A) = Annual arithmetic mean
(G) = Annual geometric mean
Not to be exceeded more than once.per year
i O
New Mexico also has two additional standards for TSP: 7 day average = 110 yg/m maximum
30 day average = 90 yg/m maximum
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Table A-4. Regional Particulate Emissions Derived from Unpaved Roads'
AQCRL
012
014
152
153
154
155
156
157
Name
Arizona-New Mexico Southern Border
Four Corners
Albuquerque - Mid Rio grande
El Paso - Las Cruces - Alamogordo
Northeastern Plains
Pecos - Permian Basin
Southwest Mountains - Augustin Plains
Upper Rio Grande Valley
Percent of Particulate
Emissions Derived from
Unpaved Roads
78%
21%
81%
94%
82%
68%
95%
46%
Obtained from New Mexico SIP
interstate AQCRs, percent figure applies only to the New Mexico portion of that AQCR.
'Information obtained from New Mexico SIP.
-------
Table A-5. New Mexico AQCR Air Quality Status, TSPC
AQCR Name
Arizona-New Mexico
Southern border
Four Corners
Albuquerque-Mid
Rio Grande
El Paso-Las Cruces
Al amogordo
Northeastern Plains
Pecos-Permian Basin
S.W. Mountains
Augustine Plains
Upper Rio Grande Val_
AQCR #
01 2b
(New Mex.)
01 4b
(New Mex.)
152
153b
(New Mex.)
154
155
156
-
ley 157
#
Stations
Reporting
14
10
23
8
12
32
7
2
fc
1
9
(ug/m3)
TSP Concentration
2nd
Highest
Highest Reading Readi ng
Annual 24-Hr 24-Hr
72
72
65
-
95
190
104
-
-
32
43
523
523
43&e
116
362
9079
7b9
179
282
185
337
395
395
375e
94
314
71 39^
463
170
102
114
278
# Stations Exceeding
Ambient Air Quality Standards
Primary Secondary
Annual 24-Hrc Annual % 24-Hrc %
0
0
0
-
3
16
2
0
0
0
0
2
2
1
0
2
11
1
0
0
0
1
1
1
1-f
-
5
20
3
0
0
0
0
7
10
4
-
42
62
43
0
0
0
0
8
6
5
0
6
23
3
1
0
0
1
57
60
22
0
50
72
43
50
0
0
11
%
Reduction d
Required
to Meet
Standards
62
62
60
-60
52
79
68
12
-47
-32
46
Standard
on Which %
Reduction
Is Based
24-hr
24-hr
24-hr
24-hr
24-hr
24-hr
24-hr
24-hr
24-hr
24-hr
24-hr
a!973 air quality data is National Air Data Bank as of
blnterstate
2nd Highest 24 Hr - Background
June 7, 1974.
100,
IUU*
- Background
background = 17
* recorded in Arizona
f recorded in Colorado
9 recorded in Texas
-------
Table A-6. New Mexico AQCR Air Quality Status (1973), S02i
00
«)CR Name
1. Arizona - New Mex.
Southern Border
2. Four Corners
3. Albuquerque - Mid
Rio Grande
4. El Paso - Las Cru-
ces - Alamogordo
5. Northeastern
Plain
5. Pecos - Permian
Basin
7. S.W. Mountains
August ina Plains
B. Upper Rio Grande
Valley
AQCR #
01 2b
(N.M)
01 4b
(N.M)
152
153b
(N.M)
154
155
156
157
ir
Stations
Reporting
24-Hr
(Bubbler)
17
10
9
7
1
12
5
1
2
_
2
e'
Stations
Reporting
^Contin. )
9
2
4
4
_
1
-
_
_
_
-
S02 Concentration
(^g/rrv*)
2nd
Highest .Reading
Annual 24-Hr
137
137
389
38g
_
62
62
.
_
-
-
3510
1294
2670 «
79
16
390
390
18
5
_
2
Highest
Reading
24-Hr
1394
1031
' ^
T:
9
285
285
7
2
_
2
# Stations Exceeding
Ambient Air Quality Stds.
Primary Secondary
Annual 24-Hr1- 3-Hr
2*1-
1
0
0
0
0
0
0
0
-
0
91- .
0
0
0
0
0
0
0
-
0
8
2
0
0
_
0
-
_
-
-
-
Reduction
Required
To Meet
Standards
74
65
90f
90f
e
6
6
e
e
-
e
Standard
on Which %
Reduction
Is Based
24 Hr
24 Hr
3 Hr
3 Hr
_
24 Hr
24 Hr
_
_
-
-
?1973 air quality data is National Air Data Bank as of June 7, 1974
"interstate.
Violations based on 2nd highest reading at any station.
d- , , , 2nd Highest 24 Hr - 24 Hr Standard x inn / Annual - Annual Standard} 10Q
Formula [ ( a ^nA. U^hoct It U- > x IUU« ( Annual ' x IUU
Highest 24 Hr
For calculations
Annual Std = 80
24-hour Std = 365
eThe most adverse air quality reading for this AQCR is less than 1/2 the secondary standard, therefore % reductions were
not calculated in order to not mislead the reader with unrealistic percentages.
SO- - background is assumed to be zero.
fThis is based on a model estimated 3 hr S02 maximum of 13,300 mg/m3. The 24-hr value shown on this table would correspond to
an 86% reduction using the proportional rollback model.
?Based on modeling results for New Mexico portion of AQCR.
Is 1 + 1 (i e one bubbler station exceeded standards and one continuous station exceeded standards.
''is sum of six'continuous and three bubbler violations; two of the three bubbler violations occurred at the same station
where two of the six continuous violations were recorded. Thus only a total of seven locations in the AQCR exhibit
Jls'a^sum^tw^continuous and one bubbler violations; the one bubbler violation occurred at the same station where
one of the two continuous violations are recorded. Thus only a total of two locations in N.M. exhibit 24-hour violations.
-------
Table A-7. New Mexico Fuel Combustion Source Summary
AQCR
Arizona - New Mexico
Southern Borders3
Four Corners3
Albuquerque -
Mia Rio Grande
El Paso - Las Cruces a-
Alamogordo
Northeastern Plains
Pecos - Permian Basin
Southwestern Mountains -
Augustine Plains
Upper Rio Grande Valley
AQCR #
012
014
152
153
154
155
156
157
Mev Mexico Power Plants
NEDS& FPCC
1
2
3
1
2
8
0
1
1
2
4
1
0
5
0
0
a
Other Fuel Combustion Point Sources
Parti cul ate S02
6
19
1
3
2
42
6
2
2
1
0 :
0
1
11
1
1
Interstate
^From NEDS data in data bank as of June 1974.
FPC data retrieved from EPA data banks.
-------
Table A-8. New Mexico Emission Summary,
AQCR
Arizona,- New Mexico
Southern Borders'3
(a) New Mexico
(b) Other states
Four Corners
(a) New Mexico
(b) Other states
Albuquerque -
Mid Rio Grande
El Paso - Las Cruces -
Alamogordo"
(a) New Mexico
(b) Other states
Northeastern Plains
Peco - Permian Basin
Southwest Mountains -
Augustine Plains
Upper Rio Grande Valley
3 Total
10° Tons/year
247.0
947.0
113.0
6.4
4.8
1.2
178.8
0.83
119.0
2.7
0.67
TOTAL 1,621.4
Total (New Mexico only) 489.2
Percent from
Fuel Combustion
6.04
0.83
95.2
68.0
24.0
35.7 *
1.7
22.9
6.3
2.2
91.0
Electricity Generation
Point Source
Fuel Combustion
Area Source
Fuel Combustion
l^Tons/Year % ioJTons/Year % 10JTons/Year %
0
0
107.4
3.1
0.93
0.35
1.15
0.14
0.11
0
0
0
0
95.0
48.0
19.4
29.0
0.6
16.9
0.09
0
0
0.072
0.21
0.17
0
0
0
0.4
0
7.2
0
0
0.03
0.02
0.2
0
0
0
0.2
0
6.1
0
0
-
.024
.07
.03
1.28
0.22
0.08
1.52
0.05
0.12
0.06
0.06
0.01
0.01
0.03
20.0
4.6
6.7
0.9
6.0
0.1
2.2
9.0
Emissions in data bank as of June 27, 1974.
Interstate.
-------
Table A-9. New Mexico Emission Summary, Participates'
AQCR
Arizona - New Mexico
Southern Borders
(a) New Mexico portion
(b) Other states
Four Corners''
(a) New Mexico portion
(b) Other states
Albuquerque -
Mid Rio Grande
El Paso - Las Cruces -
Alamogordo"
(a) New Mexico portion
(b) Other states
Northeastern Plains
Pecos - Permian Basin
Southwest Mountains -
Augustine Plains
Upper Rio Grande Valley
TOTAL
Total (New Mexico
only)
Total
103Tons/Year
3.4
19.9
24.6
13.1
25.6
7.0
7.2
11.5
27.4
1.6
12.2
153.5
113.3
Percent from
Fuel Combustion
2.7
0.7
83.6
71.3
2.9
3.2
3.8
4.9
1.6
26.3
3.4
Electricity Generation
Point So
Fuel Combi
103 Tons/Year % 103Tons/Year
.017
.023
20.3
7.1
0.17
0.09
0.14
0.23
0.10
0.18
0
0.5
0.1
82.5
54.2
0.66
1.3
1.9
2.0
0.36
11.3
0
0.03
0.06
.067
.033
0
0
0
0.03
0.14
0
0
urce
jstion
Tir
0.9
0.3
0.3
0.3
0
0
0
0.26
0.51
0
0
Area Source
Fuel Combustion
)3Tons/Year *
.. - --
0.043
0.057
0.2
2.2
0.57
0.13
0.14
0.30
0.19
0.24
0.42
1.3
0.3
0.8
16.8
2.2
1.9
1.9
2.6
0.69
15.0
3.4
Emissions in data bank as of June 27, 1974
Interstate
-------
Table A-10. New Mexico Required Emission Reductions, SO*
SIP
1973 Data
PO
AQCR' .
012
(N.M.
portion)
014
(N.M.
portion)
152
153
(N.M.
portion)
154
155
156
157
AQ
Measurement
Control
Value
100.4
84
Texas will
compliance.
Emissions
(103 tons)
265.389
73.300
197J
Estimated
Allowable Emissions
Emissions After Controls
(103 tons) (103 tons)
158.703
73.300
bring its non-ferrous smelter
Region will then be ok.
Ambient air quality well
ii it
H H
ii H
H H
H H
U II
below secondary
H H
H H
H i
97.686
27.275
into
standards.
U
a
•'
i
Percent
Reduction
Required
Based On
1973 AQ Data
74
65
90
90
b
6
6
b
b
-
b
NEDS
Emissions
(103 tons)
1194.0
247.0
119.4
113.0
4.8
180.0
1.2
0.83
119.0
2.7
0.67
Allowable
Emissions
(103 tons)
310.4
86.4
11.9
11.3
-
169.2
1.1
-
-
-
-
F
Emission
Tolerance
(103 tons)
-883.6
-160.6
-107.5
-101.7
c
-10.8
- 0.1
c
c
c
c
Based on a proportional change of emissions to air quality.
Percent reduction figures were not calculated in these cases because the method used would have called for
unrealistic increases in emissions.
Available air quality data indicates that there is a sizeable potential for allowing the emissions of sulfur oxides
to increase in this region. However, if this data were used to calculate the tolerance for emissions increase, the
results would be unrealistically high.
-------
Table A-ll. New Mexico Required Emission Reductions, Parti culates'
SIP
1973 Data
CO
M
AQCR
012
(N.M.
portion)
014
(N.M.
portion)
152
153
(N.M.
portion)
154
155
156
157
AQ
easurement
Control
Value
171
249
121
559
Ambient
M
ii
•
Emissions
(103 tons)
24.262
125.239
34.782
29.359
air quality well
ii ii
ii H
H H
197J5
Estimated
Allowable Emissions
Emissions After Controls
(103 tons) (103 tons)
21.107
72.639
7.999
7.339
below secondary
II M
II II
II II
25.212
42.314
10.592
28.978
standard
H
i
H
Percent
Reduction
Required
Based On
1973 AQ Data
62
62
60
-60
52
79
68
12
-47
-32
46
NEDS
Emissions
(IP3 tons)
23.3
3.4
37.7
24.6
25.6
14.2
7.0
11.5
27.4
1.6
12.2
Allowable
Emissions
(103 tons)
8.8
1.3
15.1
39.4
12.3
3.0
2.2
10.1
40.3
2.1
6.6
Emission
Tolerance
Q03 tons)
-J4.5
- 2.1
-22.6
14.8
-13.3
-11.2
- 4.8
- 1.4
12:9
0.5
- 5.6
Based on a proportional change of emissions to air quality.
-------
Table A-12. Fuel Combustion Regulations - New Mexico0
Existing Sources
New Sources
Particulates
Smoke - For both existing and new sources, density of smoke is not allowed to
be > #1 on Ringelmann scale for period or periods aggregating more
than 1 minute in any consecutive 30 minute period.
Coal - Maximum emission is:
0.7 lbs/106 BTU if hourly
heat input is 30 x 106 BTUs
or less.
0.5 lbs/106 BTU if hourly
heat input is 31 x 106 BTUs
or greater
Maximum emission varies from
0.56 to .155 lbs/106 BTUs
as described by the equation
E* = 0.96135 I'0'23471
if I* = 1-1000, and
E= 0.52431 I-0'14687
if I = 1000 - 20,000
After December 31, 1974 (for all coal burning equipment)
emissions greater than the following are not allowed:
0.05 lbs/106 BTUs
0.02 lbs/106 BTU for Fines (<2 micron equivalent aerodynamic diameter)
Oil - Maximum emission is:
0.005 lbs/10b BTU
(applies to units having a heat input greater than 10 BTU's/yr
which is equivalent to 114.15 x 106 BTUs/hr)
aApplies to stationary fuel burning sources.
C
*E = maximum allowable emissions of particulate matter and I = heat input in 10 BTUs/hr.
-------
Table A-12. Fuel Combustion Regulations - New Mexico9 (Continued)
Existing Sources
New Sources
SO.
Maximum emissions is:
1 lb/106 BTU heat input
For coal burning equipment, limit applies after Dec. 31,
1974, and only to units that have an hourly heat input
of more than 250 million BTUs.
For oil burning equipment, the same SOX emission limit
listed above applies, but only for units that have heat
inputs of at least 114.15 million BTUs/hour(equivalent
to 1,000,000 million BTUs/year).
Maximum emissions is:
0.34 lbs/106 BTU heat input.
For coal burners, limit appears to apply
as of the day of adoption for the regulation
(March 25, 1972).
For oil, there is no distinction between
the limits that apply to existing or to new
sources.
-------
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 S02 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 general criteria for candidacy is covered by the list of questions
found at the beginning of Section 2.0. Some of the more important criteria
is reflected by the tables in this appendix. These criteria include (1)
the breadth of air quality violations, (2) the fraction of total emissions
resulting from fuel combustion, (3) proposed AQMA designations, (4)
expected attainment dates, (5) total regional emissions, and (6) regional
tolerances for emissions increase.
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.
B-l
-------
Table B-l. Candidacy Assessment for Relaxation of Particulate Regulations
Anrn
A^>i_,K
Air Quality
TT TT
Monitorsb Violations0
Expected
Attainment
Date
Any
Counties
AQMA
Designations?
% Emission
from Fuel
Combustiorfc
Tolerance
for
Emissions
Increase b
(10J tons)
Overall ]
Regional
Evaluation
ca
012
014
152
153
154
155
156
157
10
8
12
7
2
8
1
9
6
0
6
3
1
0
0
1
7/75
7/75
7/75
7/77
a
a
a
a
No
No
Yes (1)
Yes (1)
No
No
No
Yes (1)
2.7
83.6
2.9
3.2
4.9
1.6
26.3
3.4
-2.1
14.8
-13.3
- 4.8
- 1.4
12.9
0.5
- 5.6
Bad
Bad
Bad
Bad
Bad
Good
Good
Bad
a Presently below secondary standards
Interstate, Figure is for New Mexico portion only.
Of secondary standard (24 hr).
-------
Table B-2. Candidacy Assessment for Relaxation of S02 Regulations
co
1973 Violations
of S0? Air
Quality Of Standards
AQCR
Ariz.-N.M. So.
Border
Four Corners
Albuquerque-
Mid Rio Grande
El Paso-L.Cruces
A 1 amogordo
Northeastern
Plain
Pecos-Permian
012
014
152
153
154
155
# monitors
(a)
10
7
1
5
1
2
Iviolations
(b)
1
0
0
0
0
0
Expected
Attainment
Dates
Secondary
7/75c
7/77
d
7/75
d
d
Any Counties
With AQMA S02
Designations 1
no
no
no
no
no
no
% Emission^
from Fuel
Combustion
0.04
95.2
24.0
35.7
22.9
6.3
1973U
Tolerance
for Emissions
Increase
(103 tons)
-160.6
e
e
-0.1
e
e
Overall
Regional
Evaluation
bad candidate
bad candidate
good candidate
bad candidate
good candidate
,
Basin
S.W. Mtns-Augus- 156
tina Plains
Upper Rio Grande 157
Valley
no
no
2.2
91.0
Notes: a. # of bubblers only
bo for interstate AQCRs, listing given is only for portion in New Mexico
c. 18 month extention granted to submit a plan.
d. ambient standards presently below secondary standards .
e Available air quality data indicates that there is a significant potential for allowing the
emissions of sulfur oxides to increase in this region. However, if this data were to be used
to calculate the tolerances for emissions increase, the result would be unrealistically high.
-------
APPENDIX C
This appendix provides a characterization of individual power plants
by AQCR. 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's Steam-Power Plant Factors, listing of power plants and
fuel use in 1972, and (3) emission data in the NEDS data bank as of
June 29, 1974. Fuel schedules for 1973 were extracted from the FPC data
(1 above), and this was used in conjunction with NEDS emission data to es-
timate 1973 emissions for each of the sources. When 1973 fuel schedules
were not available, 1972 schedules were used as extracted from Steam-Power
Plant Factors. S02 and particulates emissions are those associated with the
fuel shown. When actual emissions were not listed in NEDS, AP-42 emission
factors were used to estimate S(L and particulate emissions, based on fuel
schedules.
After the name of each plant is a listing of the fuels for which the
plant was designed (from source 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.
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.)
It might be cautioned that AQCR total emissions calculated in the
tables of Appendix C (and also Appendix D) may not agree exactly with
total emissions represented in Appendix A (Tables A-8, A-9). This is a
result of both differing fuel schedules in 1973 compared to previous years
and the relative "completeness" of the NEDS data bank.
C-l
-------
Table C-l. New Mexico Power Plant Assessment
AQCR Plaint Capacity
12 Community Pub.Ser.
14 Ariz Pub. Ser.
Four Corners
14 Farmington
152 Pub.Serv. of N.M.
Person
152 Pub.Serv. of N.M
<"> Reeves
ro
152 Plains Elec.Gen.
and Trans.
Fuel Use
Type b
% Sulfur Annual
% Ash Quantity
Gas 2224
Coal 3,057,689
0.70X5
22.03SA
Gas 1320
Oil 3,775
0.75XS
Gas 4,418
Oil 7,034
1.25%
Gas 11,151
Oi 1 203
2.03SS
Gas 764
Heat
, Input
(10° BTuYhr)
279**
5924
169
Emissions
(tons/year) (lbs/106 BTU)
S02 Particulates S0£ Particulates
0.67 17
146,614 33,655
0.40 10
61.2 222 14.9
553 1.33 33.1
121 690 27
1,400 3.3 83.6
3.50
97.7
33 2.3
0.23 5.7
f. .01 0.01
19/5 Emission
Limi£
(1bs/10° BTU)
S02 Particulates
None applicable
5.64 1.29 Regulations for this
plant has 1977
compliance date
< .01 0.01
0.83 0.06
< .01 0.0>
1.3 0.05
< .01 0.01
2.15 0.15
< .01 0.01
None applicable
M ii
• ii
1 -00 .005
None applicable
11 it
ii H
•Emissions Calculated using AP-42 factors.
**Used on estimated 1100 BTU/SCF in calculation.
-------
Table C-l. New Mexico Power Plant Assessment (Continued)
AQCR Industry
Type
% Sulfur
% Ash
Fuel Use
Annual
Quantity
Heat
elnput
(10° BTU/hr)
Emissions _ .
Emissions
(tons/year) (lbs/106 BTU)
S02 Particulates S02 Particulates
1975 Emission
Limit
(lbs/106 BTU)
S02 Particulates
153
154
155
o
i
CO
155
155
155
155
El Paso Elec Co.
Raton Pub.Serv.
S.W. Public Serv.
Roswel 1
S.W. Public Serv.
Carlsbad
Lea Co. Elec
N.M.Elec Serv.
S.W. Pub.Serv.
Oil
3.70 %S
Oil
0.973SS
Gas
Coal
0.403SS
19.02A
Oil
0.72XS
Gas
Oil
1.402SS
Gas
Gas
Gas
Gas
63
4,271
9,765
18,857
218
1,249
818
1 ,880
3,117
5,385
1,427
1.03
73.6
1,188
51.7
3.3
143
13.0
215
396
669
163
18.3
if
325.2
2.9*
144
10
0.37*
91
*
0.56
1
2
0.43*
0.25 4.06
*
17.1 1.01
73.2* <.01
246 0.64
1 0.69
9.37* <.01
4 1.60
•£•
14.1 <.01
23 <.01
40 <.01
11 <.01
0.06
0.05
0.01
1.09
0.07
0.01
0.07
0.01
0.01
0.01
0.02
None applicable
ii i
ii ii
None o.5
None applicable
I |
1 1
M I
1 II
II
I I
*Emissions calculated using AP-42 factors.
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APPENDIX D
The Table D-l in this appendix lists individual industrial/commercial/
institutional sources of particulates and SCL emissions which might show
fuel switching potential. The sources are from a NEDS rank order emissions
listing.
It should be cautioned that the percent emissions accounted for is
different than the "% of fuel use accounted for," It is possible that
several potential fuel switch sources could be overlooked by the cutoff point
on the emissions (i.e., a reasonable sized natural gas used may emit below
our cutoff point in the NEDS rank order list).
No information was available for feasibility of any fuel
switching.
D-l
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o
rv>
Table D-l. New Mexico Plant Assessment
Plant
AQCR Capacity
155 Nat. Potash Co.
Type
% Sulfur
% Ash
Gas
Annual0
Quanti ty
339
1975 Emission
Heat Emissions Emissions . Limi£
glnput (tons/year) (lbs/106 BTU) (lbs/10° BTU)
(10° BTU/hr) S02 Particulates S02 Particulatcs S02 Particulates
38.7'
0.1*
< .01
0.02
None applicable
155 Int. Mine & Chem. Gas
1335
152
0.4*
12
< .01
0.02
155 El Paso N. Gas
Gas4
364
44.5
0.1*
< .01
0.02
A-Estm. 1000 BTU/SCF in calculation
*Emissions calculated using AP-42 factors
**Gas Turbine
-------
Table D-l. New Mexico Plant Assessment
AQCR
12
Plant
Capacity
Kennecott
153 El Paso N. Gas
Type
% Sulfur
% Ash
Oil
1.30XS
Gas
Gas
Annual
Quantity
917
2642
463
Heat
..Input
(10° BTU/hr)
10.5**
Emissions
(tons/year)
S02 Particulates
81 7
302 0.79*
56.7 0.14
23.8*
.**
Emissions
(lbs/106 BTU)
S02 Particulates
1.76 0.15
<;.01 0.02
"=.01 0.02
1975 Emission
. LimiJ
(Ibs/10° BTU)
S02 Particulates
None applicable
o
CO
*Estm. 10° Btu/gal in calculation
**Emissions calculated using AP-42 factors
***Gas Turbine
-------
ERRATA
Page A-4 The footnote (c) should read, "18 month extension granted for
submittal of plan."
A-8 Table A-6. The highest 24 hour SCL reading was erroneously
used instead of the 2nd highest reading in the proportional
rollback calculations for the El Paso-Las Cruces-Alamogordo
AQCR (153). The 2nd highest reading is, in fact, below
NAAQS. Using this 2nd highest reading, the reduction required
to meet standards is -28%.
In Table A-10, this figure gives a regional annual allowable
emissions level of 230.4 x 10 tons, and an annual tolerance
for emissions increase of 50.4 x 103 tons. The corresponding
allowables and tolerance for emissions increase for the
New Mexico portion of the AQCR is 1.5 x 103 tons and 0.3 x 103
tons, respectively. Corrections in line with this reassess-
ment are reflected in the Summary Table on Page 8. However,
changes have not been made in either the text, or the appendices
This errata note is meant to present the correct values, and
to indicate that the El Paso-Las Cruces-Alamogordo AQCR should
be considered a "good candidate" for increased SOp emissions.
(This reassessment has no effect on the Review's overall
discussion of the restrictiveness of New Mexico's regulations.)
B-3 The footnote (c) should read, "18 month extension granted to
submit a plan. The 7/75 attainment date refers to the primary
standard only."
C-2 The footnote (b) for these tables should indicate the units
thru C-3 for the fuels used. Units are 106 cubic feet for gas, 10J
gallons for oil, and tons for coal.
There is no footnote (a).
D-2 Same as C-2 and C-3, above.
thru D-3
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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 New Mexico Implementation Plan, submitted January 27, 1972
by Governor Bruce King.
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