EPA-450/3-74-084

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

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                                                         EPA-450/3-74-084
                    IMPLEMENTATION PLAN REVIEW

                                FOR

                           MASSACHUSETTS

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

          U.  S.  Environmental  Protection Agency,  Region I
                J.  F.  Kennedy  Federal  Building
                 Boston, Massachusetts  02203
                Environmental  Services of TRW,  Inc.
            800 Follin 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

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                            MASSACHUSETTS

          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	    7
     2.1  Summary	    7
     2.2  Air Quality Setting	    8
     2.3  Background on the Development of the
          Current State Implementation Plan	12
     2.4  Special Considerations ."....,	....'...  13
3.0  AQCR ASSESSMENTS BASED ON SIP REVIEWS ......  	  15
     3.1  Berkshire AQCR 117	16
     3.2  Central Massachusetts AQCR 118	17
     3.3  Metropolitan Boston AQCR 119	18
     3.4  Metropolitan Providence AQCR 120	20
     3.5  Merrimack Valley - Southern New
          Hampshire AQCR 121 	  21
     3.6  Hartford - New Haven - Springfield AQCR 42	22  -
     3.7  Harvard Modeling Study . .  .	25
APPENDIX A  - STATE IMPLEMENTATION PLAN BACKGROUND  ..........  31
APPENDIX B  - REGIONAL AIR QUALITY ASSESSMENT	  42
APPENDIX C  - POWER PLANT ASSESSMENT	44
APPENDIX D  - INDUSTRIAL, COMMERCIAL, INSTITUTIONAL SOURCE
             ASSESSMENT  	  ........  51
APPENDIX E  - AREA SOURCE ASSESSMENT	54
APPENDIX F  - HARVARD UNIVERSITY MODELING STUDY 	  56

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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 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. V.'here
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.

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     To date, EPA's fuels policy has addressed only those States with the
largest clean fuels saving potential.  Several of these States have or are
currently in the process of revising 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 p_r 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 NAAOS 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 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.  Hhere 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 ($03) emissions.  This  is because sta-
tionary fuel combustion sources constitute the greatest source of S02 emission
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 AOCR'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 Appendix C, D, and E.


     The Commonwealth of Massachusetts' State Implementation Plan has

been reviewed for the most prevalent causes of over-restrictive fuel  com-

bustion, emission limiting, regulations.  The major findings of the review

are:

     FOR SO?, THERE ARE TWO AQCR's. BERKSHIRE AND CENTRAL MASSACHUSETTS,

     WHICH INDICATE SOME POTENTIAL FOR ADDITIONAL REVISION OF FUEL COM-

     BUSTION SOURCE EMISSION LIMITING REGULATIONS.  HOWEVER THESE AQCR's

     HAVE LIMITED POTENTIAL DUE TO RELATIVELY LOW VOLUMES OF TOTAL FUEL
     USED.


     FOR TOTAL SUSPENDED PARTICULATES. THERE ARE NO AQCR's WHICH  INDICATE

     ANY POTENTIAL FOR REVISING FUEL COMBUSTION SOURCE EMISSION LIMITING

     REGULATIONS.
     The supportive findings of the SIP review are as follows:

     Recent actions by  the state of Massachusetts parallel the intentions
     of Section IV of ESECA.  In an attempt to reduce the impact of fuel
     shortages, and to  conserve clean fuels, Massachusetts has recently
     passed legislation mandating a relaxation of all statewide ambient
     air quality standards to the NAAQS levels.  Furthermore, all implemen-
     tation plan requirements are being modified as much as possible under
     this law.  Recognition of possible clean fuel savings has occurred in
     Massachusetts even prior to this most recent legislation with a short-
     term change in the sulfur content requirement for distillate oil. The
     change increased the sulfur content of distillate oil from 0.17 pounds
     per million BTUs to 0.28 pounds per million BTUs. Although this distil-
     late oil relaxation is to expire April 15, 1975, EPA has indications
     that this relaxation will become permanent if no adverse trends in air
     quality are noted.  Also, other changes in sulfur content and particulate
     limitations are expected.

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Massachusetts approved the fuel  conversion from oil  to coal  at four
power plants within the state in 1973.   They were:  Salem Harbor,
Brayton Point (New England Power Co.),  West Springfield, and Mt.  Tom.
The conversion of the West Springfield  plant was disapproved, however,
by EPA due to possible violations of the NAAQS.

In most areas within the state power plants are the  largest  emitter
of sulfur dioxide.  A case-by-case review of the existing regulations
(as done by Harvard University,  Appendix F) may indicate a potential
to save clean fuels if modeling  results for point and area sources
are available.

Like many other areas of the nation, high levels of total suspended
partfculates are currently being found  throughout the State  of
Massachusetts.  Fuel combustion  sources within the state are estimated
to contribute about half of the  TSP emissions, with area wide fuel
combustion sources contributing  about 30 percent.  Although  it may
be possible to relax the particulate limitations regulations in select
cases, indiscriminate relaxations of the regulations would aggravate
the existing situation.

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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:
     0  Does the State have air quality standards which are more stringent
        than NAAQS?
     •  Does the State have emission limitation regulations for control of
        (1) power plants, (2) industrial sources, (3) area sources?
     •  Did the State use an example region approach for demonstrating the
        attainment of NAAOS or^more stringent State standards?
     •  Has the State not initiated action to modify combustion source
        emission reoulations 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 MAAQS?
     t  Based on (1973) air quality data, are there no reported violations
        of NAAQS?
     t  Based on (1973) air quality data, are there indications of a toler-
        ance for increasing emissions?
     0  Are the total emissions from stationary fuel combustion sources
        proportionally lower.than those of other sources?
     0  Is there a significant clean fuels savings potential in the region?
     0  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 SI? 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 tb,e remaining Appendices

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provide an AOCR 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 Appendix 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 SETTING
     The State of Massachusetts is divided into six Air Quality Control
Regions (AQCR's), three of which are interstate regions (Figure 2-1).   The
regions are named as follows:
     •  Berkshire Intrastate AQCR - 117
     t  Central Massachusetts Intrastate AQCR - 118
     •  Metropolitan Boston Intrastate AQCR - 119
     e  Metropolitan Providence Interstate (R.I) AQCR - 120
     •  Merrimack Valley - Southern New Hampshire Interstate (M.H) AQCR - 121
     t  Hartford - New Haven - Springfield Interstate (Conn.) AQCR - 42

     Air quality monitoring in the Berkshire region consists of six stations
for total suspended particulates (TSP) and seven stations for sulfur dioxide
(S02).  Monitoring results for 1973 show no violations of the federal  standards
Emission summaries indicate that about half of the TSP and almost all  of the
SC>2 come from fuel combustion sources.

     In the Central Massachusetts AQCR four of nine reporting monitors indi-
cated violations for the TSP standards in 1973, while there were no violations
for S02 at the ten reporting stations.  The region has been designated as
a proposed Air Quality Maintenance Area (AOMA) for TSP.  Emission summaries

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                                                                           TABLE 2-1

                                                                 STATE  IMPLEMENTATION PLAN REVIEW
                                                                             (SUMMARY)
                     "Indicators"

  t  Does the State have air quality standards
which are more stringent than NAAQS?
  •  Does the State have emission limiting regu-
lations for control of:
     I.  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 m> proposed Air Quality Maintenance
Areas?

  •  Are there indications of a sufficient number
of monitoring sites within a renion?
  •  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 duality Data, are there
indications of a tolerance for increasing emissions?

  *  Are the total emissions from stationary fuel
combustion sources proportionally lower than tlioic
of other sources?
  •  Do modeling results for fuel combustion sources
show a potential for a regulation revls'oir

  •  Must 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
liintting regulations?
  •  Is there a significant Clean Fuels Saving
potential In the region?
   State
TSP    S02
 No
        No
Yes    Yes
Yes    Yes
 No     Ho
Yes    Yes
Ho     No
 Berkshire
 AQCR 117
TSP    S02
   Central
Massachusetts
  AQCR 118
 TSP    S02
Metropolitan
   Boston
  AQCR 119
 TSP    S02
Metropolitan
 Providence
  AQCR 120
 TSP    S02
  Herrimack
   Valley
  Southern
New Hampshire
  AQCR 121
 TSP    S02
                                                                                                      Hartford - New Haven
                                                                                                           Springfield
                                                                                                             AQCR 42
                                                                                                           TSP    S02
Yes
Yes
Yes
Yes
•lo
<0
<•»<;
Yes
Poor
No
Yes
Yes
Yes
Yes
Yes
No
WP«
Yes
Good
llo
No
Yes
Yes
No
Ho
Yes
v»s
Yes
Poor
No
Yes
Yes
Yes
Yes
Yes
Vo
Vet
Yes
Good
No
No
Yes
No
No
Ho
No
Yes
No
Poor
No
No
Yes
No
Yes
Yoi
No
Yes
Yes
Poor
No
No
Yes
Yes
Yes1
No
No
Yes
No
Poor
No
Yes5
Yes
Yes
Yes1
No
No
Yes
Yes
Poor
No
No
Yes
Yes
Yes2
No
No
Yes
Yes
Poor
No
Yes"
Yes
Yes
Yes
Yes
No
Yes
Yes
Poor
No
No
Yes
Yes
No
No
No
Yes
Yes
Poor
No
Yes3
Yes
Yes
No
No
No
Yes
Yes
Poor
No
  There were violations in the Rhode Island Portion of the region
p
  There were violations in the New Hampshire Portion of the region

  There are proposed AQMA's in the Connecticut Portion of the renion

4 Carlisle and Bexford are included In the Boston AQMA.

5 Kent and Providence Counties are designated by the State of Rhode Island. Milford,
  Medway. Bellinghaia. Franklin, Wrentham, Foxboro, and Kingston are included In the
  Boston AQMA.

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BERKSHIRE
IHTRASTATE.
                                         CENTRAL
                                         MASSACHUSETTS
                                         INTRASTATE
MERRIMACK VALLEY-
 IOUTHERN
NEW HAMPSHIRE
INTERSTATE
{MASSACHUSETTS-
NEW HAMPSHIRE)
                                                                                   METROPOLITAN
                                                                                   BOSTON
                                                                                   INTRASTATE
                           HARTFORD-
                           NEW HAVEN-
                           SPRINGFIELD
                           INTERSTATE
                           (CONNECTICUT-
                           MASSACHUSETTS)
                                                  METROPOLITAN'
                                                  PROVIDENCE
                                                  INTERSTATE
                                                  (RHODE ISLAND-
                                                  MASSACHUSETTS)
          Figure  2-1   Air Quality  Control  Regions in  Massachusetts

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indicate that about half of the TSP and almost all of the S02 are emitted
from fuel combustion sources.  The highest TSP readings occurred in Worcester,
where the two largest emitters of particulates (for the region) are located.

     The Metropolitan Boston AQCR showed no violations for S02 in any of
their 30 stations reporting in 1973, although six of 23 stations reported
TSP violations.  The Metropolitan Boston area has been given an 18-month
extension to attain the secondary standards for SQ2 and TSP, and AQMA's
have been proposed for both pollutants.  Two-thirds of the TSP and almost
100 percent of the SQ2 can be attributed to fuel combustion sources. About
40 percent of the S0£ can be attributed to power plants and about 45 percent
to area sources, while nine percent and 46 percent of the region's TSP
emissions can be attributed to power plants and area sources respectively.
Most of the 1973 TSP violations occurred within the 13 cities making up
the Boston core, in which the largest emitters of particulates are located.

     The Metropolitan Providence interstate region monitors TSP in 33 loca-
tions and S02 in 32 locations.  Of these only five TSP and six S02 stations
are located in Massachusetts.  For the entire region there were three moni-
tors recording TSP violations and one reporting S02 violations in 1973.
Although all violations were located in Rhode Island, proposed AQMA designa-
tions include counties in both states for both pollutants.  Massachusetts
contributes about two-thirds of the region's S02 emissions with about three-
fourths of these emissions coming from power plants.  Massachusetts and Rhode
Island each contribute about the same amount of TSP to the region's total,
with approximately half coming from fuel combustion sources.  Massachusetts
pov/er plants contribute about 20 percent of the TSP  to the states total for
the region while area sources contribute about 30 percent.

    In the Merrimack Valley - Southern New Hampshire Interstate AQCR, four
of 30 stations reported TSP violations in 1973 while no violations were
recorded for the 15 S02 reporting stations.  Massachusetts contained eight
TSP monitors, none of which recorded any violations in 1973.  Eight of .the
S02 monitors were located in Massachusetts.  Although the Massachusetts
portion of the AQCR reported no violations,  Essex County (which is contig-
uous with the Metropolitan Boston AQCR) has been proposed as an AQTlAjfor
both pollutants.   Massachusetts contributes a little over a third to the
                                   11

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total TSP emissions for the region with about 37 percent of these emissions
coming from area sources and none from power plants.   Massachusetts  also
contributes about 30 percent of the S02 emissions to  the total  with  about
70 percent of these emissions coming from area sources.   Massachusetts  point
sources contribute about 20 percent of the TSP emissions and 25 percent of
the S02 emissions to the state's total, for that region.

     The Hartford - New Haven - Springfield Interstate AQCR contains 67 TSP
monitors and 34 S02 monitors.  Out of the ten TSP monitors located in
Massachusetts, four showed violations in 1973, while  none of the nine
Massachusetts S02 monitors showed violations.  For the same period Connecticut
accounted for 7 stations violating TSP standards and  one station violating
S02 standards.  Only two Massachusetts counties were  proposed as AOMA's
and only for particulates, while three Connecticut Counties have been pro-
posed for both pollutants.  Massachusetts contributes about 60 percent
of the TSP to the region's total of which approximately 60 percent comes
from fuel combustion sources.  Massachusetts and Connecticut each account
for about half of the region's S02- Approximately 50  percent of the  S02
emissions from Massachusetts are related to power plant operations in the
region.  The Massachusetts stations recording 1973 TSP violations were
located in Chicopee, Holyoke, and two in Springifeld.  While none of the
largest TSP emitters are located in Chicopee, three (power plants) are
located in Holyoke and one in Springfield.

2.3  BACKGROUND ON THE DEVELOPMENT OF THE CURRENT STATE IMPLEMENTATION PLAN
     The control plan developed by the State of Massachusetts for the con-
trol of TSP and S02 contained four distinct parts.  These parts controlled
emissions from:
     •  Stationary fossil fuel combustion facilities
     •  Incinerators
     •  Industrial process operations
     •  Other sourcess including motor vehicle and construction
     Emissions were to be controlled by:
     •  Emission limitation for particulates
     •  Sulfur and ash limitations in fuels
                                    12

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     •  Visible emission limitations
     •  Prohibition of residual oil in certain facilities
     •  Other control divices in lieu of sulfur limitations
     Table A-9 summarizes the regulations which are applicable to fuel  com-
bustion sources.  It should be noted that the state has set stricter standards
in areas of critical concern for both TSP emission limitations and maximum
sulfur content.  Massachusetts has further restricted the size of the facil-
ities allowed to burn residual fuels.  A maximum ash content of nine percent
has been applied to all fuels.

     Visible emissions are limited to Ringleman No. 1 or 20 percent opacity.
Ringleman No. 1 may be exceeded for not more than six minutes per hour, but
Ringleman No. 2 is not to be reached.  The 20 percent opacity standard may
be exceeded for not more than two minutes per hour as long as 40 percent
opacity is not reached.

     Modern control technology and standard operating procedures are used
to control TSP from incinerators.  Emission limitations for TSP and S02
were developed for industrial process sources.  Traffic control plans and
operating procedures will control TSP from motor vehicles and construction
operations.

     Massachusetts evaluated its control plan for each region for which
there were sufficient data.(Table A-10 and A-ll).  Results indicated that
all federal secondary standards would be met on or before July, 1975 in
every region, except the Metropolitan Boston (AQCR - 119).  In May of 1974,
EPA granted an 18 - month extension for compliance with the federal secondary
standards in the Metropolitan Boston AQCR.  In evaluating the control plan
for each region, Massachusetts took what it believed to be the "worst case".
This consisted of the worst ambient air quality readings or projections and
the greatest projected growth in emissions.

2.4  SPECIAL CONSIDERATIONS
     In an attempt to reduce the impact of fuel  cost and shortages,
Massachusetts has recently passed legislation mandating a relaxation of all
ambient air quality standards to federal  levels.   Furthermore, all  implementation
                                    13

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plan requirements must be relaxed as much as possible under this  law.   The
distillate oil requirement has already been changed from 0.17 pounds  per
million BTU's to 0.28 pounds per million BTU's.   This relaxation  expires
April 15, 1975.  However, if no adverse trends in air quality are noted,
it is believed that this relaxation will become permanent.   Other changes
in sulfur content and particulate limitations may be forthcoming.

     In 1973 the state approved conversion to coal at four  power  plants
within the state.  They are:
     «  Salem Harbor                AQCR - 119
     •  Brayton Point               AQCR - 120
        (New England Power Co.)
     •  West Springfield            AQCR -  42
     •  Mt Tom                      AQCR -  42
The conversion of the Hest Springfield plant was disapproved by EPA.
Brayton Point (Unit No. 3) is still burning coal.  An application by  Salem
Harbor to continue coal burning has been rejected by the state.   Although
the state is concerned with the possible increase in TSP, applications
are being considered for Mt. Tom, West Springfield, and Montaup in Somerset.
                                   14

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               3.0  AQCR ASSESSMENTS BASED ON SIP REVIEWS

     The purpose of this section is to evaluate the available information
for the State of Massachusetts 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 Massachusetts fuel combustion sources; (6) regional  tolerance for emis-
sions increase; and (7) pollutant priority classifications.   Tables 8-1
and B-2 tabulate these criteria 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
Massachusetts fuel combustion sources would receive a good ranking.  All
other regions with varying indicators or incomplete or missing data would
be evaluated separately 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.
                                    15-

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3.1  BERKSHIRE AQCR 117
3.1.1  Regional Air Quality Assessment
       Monitoring of S02 for 1973 indicates a potential to increase SOg emis-
sions (Table A-5).  A review of the Massachusetts control  plan (Table  A-ll)
for the region also indicated that there is a potential to increase S02
emissions.  In addition to the above, the Berkshire region has been considered
a good candidate to relax S02 regulations (Table B-2) since it has  a priority
III classification (Table A-l) and there are no proposed AQMA's within the
region (Table A-l).

       There were no violations of TSP within the region in 1973.   However,
air quality was recorded near the secondary standards (Table A-4)  and  cal-
culations suggest only a minor increase in TSP can be permitted (Table A-4).
Only about one-half of the TSP can be attributed to fuel combustion sources,
with area sources accounting for a third of the region's total.  The state
control plan indicated that the secondary standards will just be met in
1975 (Table 3-1).  Although there are no proposed AQMA designations for
the area (Table A-l) a priority classification of II (Table A-l) combined
with the above data have led to a poor candidate evaluation (Table B-l)
for relaxation of any TSP regulations or strategies.

3.1.2  Power Plant Assessment
       There are no power plants located in AQCR 117 and none will  be  in
operation by 1975.  Therefore, any tolerance for S02 could only be realized
by relaxation of regulations pertaining to industrial, commercial, and
institutional point sources as well as area sources.

3.1.3  Industrial/Commercial/Institutional Point Source Assessment
       This category accounts for 22 percent of th.e TSP emissions and  55
percent of the S02 emissions in the AQCR (Table A-7 and 8).  Although  both
1973 air quality and the SIP evaluation show a potential to increase S02
emissions (Table A-ll), they differ in magnitude.  Application of existing
fuel regulations indicates a reduction in S02 (Table 3-2) for those nine
                                    16

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significant sources listed in Table D-2 between 1970 and 1975.  If the fuel
regulations controlling these sources were to be rescinded:
       A)  the resultant emissions may still be below the allowable,
           according to the air quality calculations
       B)  the resultant emissions may exceed the allowable, according
           to the SIP calculations.
       Although this category of sources may not increase their TSP emis-
sions as a whole, individual point sources may be able to increase their
TSP emissions if it can be shown that there would be no adverse effect on
air quality.

3.1.4  Area Source Assessment
       Area sources contribute 31 percent of the TSP emissions and 44 per-
cent of the S02 emissions (Table 7 and 8) to the region's total.  Since a
possible regional increase in area wide S02 emissions may be accepted,
additional S02 emissions from this category would seem possible.

3.2  CENTRAL MASSACHUSETTS - AQCR 118
3.2.1  Regional Air Quality Assessment
       All monitoring sites within the AQCR recorded S02 concentrations
below the standards in 1973 (Table A-5).  Based on these readings, there
is a potential to increase the S02 emissions.  The Massachusetts control
plan for the region will reduce SC^ emissions below the point required by
the regulations (Table 3-2).  Using the same criteria (Table B-2) as in
the previous case (AQCR 117), the Central Massachusetts AQCR was given a
good candidate ranking for possible modification of S02 regulations.

       Since four of nine monitors recorded TSP violations in 1973 (Table
A-4), there is no potential  to increase emissions based on this air quality
data.  SIP results indicate that the secondary standard will be met with
little potential  for increasing emissions (Table 3-1).   Therefore, Central
Massachusetts must be considered a poor candidate for reduction TSP regula-
tions (Table B-l).
                                    17

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3.2.2  Power Plant Assessment
       Th.ere are no power plants located in AQCR 118 and none will be in
operation by 1975.  Therefore, any tolerance for SC^ could only be realized
by relaxation of regulations pertaining to industrial, commercial and
institutional point sources as well as area sources.

3.2.3  Industrial/Commercial/Institutional Point Source Assessment
       This category accounts for about 30 percent of the S02 emissions from
fuel combustion.  Although there is a potential to increase SC^ emissions
(Table A-ll) the 23 significant SC>2 emitters (Table D-2) will collectively
reduce their S02 contribution between 1970 and 1975.  Total relaxation of
the sulfur regulations for these significant sources will bring the S02
emissions up to their allowable maximum according to the SIP (Table 3-2).
However, air quality data (Table A-5) may possibly allow further increases
in S02 emissions (in addition to the relaxation mentioned above).

     Since this category only accounts for about 10 percent of the total
TSP emissions (Table A-7) for the region, modification of the regulations
may be possible under 1973 air quality conditions (Table A-4).  That is,
individual sources may be able to increase their TSP emissions, if it can
be shown that air quality will not be adversely affected.

3.2.4  Area Source Assessment
       Area sources account for about 34 percent of the region's TSP emis-
sions and 67 percent of the S$2 emissions.  Since there seems to be an S02
emission tolerance (Table A-ll) for the entire region, area sources may
increase their emissions without exceeding the standards.  As with the in-
dustrial sources, there is no apparent tolerance to increase TSP emissions
(area sources account for about 34 percent of the region's total).

3.3  METROPOLITAN BOSTON AQCR 119
3.3.1  Regional Air Quality Assessment
       This region has been given a priority I classification for S02 and
TSP and has been granted an 18-month extension to meet the Federal secondary
                                   18

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standards for both pollutants.  Although 1973 air quality (Table A-5) shows
a potential to increase S0£ emissions, this region must be considered a
poor candidate for relaxation of S02 regulations (Table B-2).  There were
six monitoring stations recording violations of the TSP standards in 1973
(Table A-4) and therefore a reduction is needed to meet the standards.
Table B-l shows the criteria which led to a poor candidate ranking for
TSP emission regulation relaxation.

3.3.2  Power Plant Assessment
       The Metropolitan Boston AQCR has 10 power plants which range in
size from 12.5 MW to 760 MW (Table C-l).  One new unit is expected to be
on line in 1975 which will add 587 MW to the AQCR's total (Table C-2).
As of now, no plants are scheduled to burn coal in 1973; although the Salem
Harbor plant was granted permission to burn coal in 1973.  An application
to continue coal burning at Salem Harbor has been rejected.  However,
modeling results indicate that is Salem Harbor switched to 2.5 percent
sulfur coal with an ash content of 15 percent, the standards would not
be violated (Table C-4).
       Although existing power plants are required to reduce their
emissions between 1970 and 1975 under existing regulations, relaxation of
both S02 and TSP regulations based on existing criteria for the entire
AQCR does not seem possible.  However, if modeling results show relaxation
is possible on a case by case basis, there may be some potential for a
clean fuel savings

3.3.3  Industrial/Commercial/Institutional Point Source Assessment
       These sources account for only 10 percent of the region's TSP emis-
sions and only 11 percent of the S02 emissions (Tables A 7 and 8). Emissions
from this category are emitted from relatively few significant sources
(i.e. six for TSP and seven for S02> -Table A-6).   Since these fuel combustion
sources add so little to the region's total emissions, existing regulations
have little impact on emission reduction for the region from these sources
(Table 3-1 and 2).  However, since there are relatively few significant
sources air quality impacts may be substantial in the area surrounding these
                                    19

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sources, if relaxation of regulations occurred.  If air quality  monitoring
continues to show no violations of the SC>2 standards, modeling of these
large sources may show a potential for relaxations of regulations on  a case
by case basis.

3.3.4  Area Source Assessment
       This category is the largest emitter of $03 and TSP in the region.
Since the region is a poor candidate for relaxation of both TSP  and S02
regulations, area sources would be a prime target for further emission
reductions (from an emission standpoint).

3.4  METROPOLITAN PROVIDENCE AQCR 120
3.4.1  Regional Air Quality Assessment
       Air quality monitoring for 1973 indicated that the entire AQCR must
reduce its TSP emissions, and its S02 emissions (Table A-4 and 5). Combined
with the other criteria, listed in Tables B-1 and 2, both the Massachusetts
and Rhode Island protions of the region must be given poor candidate  rankings,
Although Massachusetts contributed about two-thirds of the S02 emissions  and
about one-half of the TSP emission to the region's total, there  were  no
violations of either pollutant standard recorded in Massachusetts. There-
fore, slight modification of the Massachusetts' regulations may  be possible
if it can be shown that no adverse impact would result in any section of
the AQCR.

3.4.2  Power Plant Assessment
       There are seven oil fired power plants located in the Massachusetts
portion of this AQCR, four of which are known to have the capability  to
burn coal (Table C-l).  These plants accounted for 21 percent of the  state's
TSP contribution to the AQCR and 77 percent of their S02 contributions
(Tables A-7 and 8).  One new unit of 560 MW is due to begin operations  in
1975 in Sandwich, Massachusetts (Table C-2).  The present regulations will
require a reduction in S02 and will allow a increase in TSP emissions
(Table C-3).  Monitoring results indicate that switching Unit 3  at the  New
England Power Plant Company's plant in Somerset to 2.5 percent sulfur and
                                  20

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an ash content of 15 percent will not violate the standards at the New England
Power Plant site even with the contribution from Montaup's plant (with the
same switch).  However, the contributions of any modeled New England Power
Plant switch will exceed the standards at Montaup's site if the Montaup
plant also switches (Table C-4)

3.4,3  Industrial/Commercial/Institutional Point Source Assessment
       These sources contribute only seven percent of the TSP and three
percent of the S02 to the state's total for the AQCR (Table A-7 and 8).
In addition to the power plants there are only two significant sources for
each pollutant (Table A-6).  Although the region as a whole may not increase
its TSP and S02 emissions, these particular sources may have a potential  to
increase their emissions without adversely effecting air quality due to
their small contribution to the total regional emission inventory. Evidence
of this exists in Tables 3-1 and 2 which show that applying existing regu-
lations to the sources mentioned above will only account for slight TSP
and S02 reductions between 1969 and 1975.  A case by case study would have
to be conducted to insure maintenance of air quality standards before fuel
switching occurred.

3.4.4  Area Source Assessment
       These nonpoint sources contribute 31 percent of the state's total
TSP emissions in the region and 20 percent of the S02 emissions.  Any relax-
ation of the standards for these sources is not suggested in view of the
air quality assessment.

3.5  MERRIMACK VALLEY - SOUTHERN MEW HAMPSHIRE AQCR 121
3.5.1  Regional Air Quality Assessment
       Since there were no air quality violations for either pollutant in
the Massachusetts section of the region (Tables A-4 and 5), an emission
increase may be possible.
                                  21

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3.5.2  Power Plant Assessment
       There are no power plants operating in the Massachusetts portion of
this region and none are expected by 1975.  Therefore, any tolerance of
emissions must be determined by examining the industrial, commercial and
institutional point sources as well as the area sources.

3.5.3  Industn'al/Commercial/Institutional Point Source Assessment
       This category accounts for 19 percent of Massachusetts'  contribution
of TSP to the region and 27 percent of the S02 emissions (Table A-7 and 8).
Under the existing regulations the significant sources will reduce both
their TSP and S02 emissions between 1970 and 1975 (Table 3-1 and 2).  How-
ever, since these reductions contribute little to the regional  totals and
since there were no violations in Massachusetts in 1973, relaxation of stan-
dards pertaining to these sources may be possible, if it can be proven that
they will not adversely affect air quality.

3.5.4  Area Source Assessment
       The Massachusetts area sources are the largest contributors to both
TSP and SOg emissions in either state, contributing about 14 percent of the
regions total TSP emissions and 21 percent of the S02 emissions (Tables A-7
and 8).  Therefore, relaxation of regulations for this category does not
seem possible.

3.6  HARTFORD - NEH HAVEN - SPRINGFIELD AQCR 42
3.6.1  Regional Air Quality Assessment
       Air quality monitoring for 1973 indicated a reduction in TSP and
S02 will be needed to meet the standards.  Including the other factors in
Table B-1 and 2, a poor candidate ranking for possible emission regulation
relaxation was assigned for both pollutants.  However, it should be noted
that no Massachusetts S02 monitoring station recorded any violations, and
no proposed AQMA's were designated in Massachusetts for S02.

3.6.2  Power Plant Assessment
       There are four power plants located within the state's portion of
the AQCR, each of which has the ability to burn coal.  Three of the four

                                    22

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                                                                TABLE 3-1
                                            ':/>r.S:CIIUSETTS PART1CULATE SUtlARY BY AOCR

Berkshire 117
Central Massachusetts lift
tlutropol itdii tiaslon 119
Metropolitan Providence 120
Hurrlmack Valley 121
Southern Hew Hampsdire
Hartford - ilex Haven - 042
Springfield
Candidate
Dad
Bod
Bad
Bad
Bad
Bad
Necessary Emission1*
Reduction for Entire
AQCR Based on Air Quality
tlO-'T/Yrl
-0.1
6.0
22. U
19.9
14.6
48.7
SIP Required Emission
Reduction (for State)
to Meet Standards
(10 T/Yr)
1.5
6.2
24.6
NA
NA
UA
SIP Projected
Emission Reduction
(for State) 1975
(103T/Yr)
1.5
6.9
1'J.ft
1.9"
NA
NA

State's Fuel Combustion
Emissions to Total AQCH
Emissions
53
4c
66
27
21
37

(see Table A- 10)
(l03T/»r)
.0.1
*0.6
-24.6
- 5.5
- 2.1
-24.9
f 1 i
Reduction Under Existing
Regulations
(103T/Yr>
-
-
- 4.3
- 4.5
«11 2

Significant Point Source
Emission Reduction Under
Existing Regulations
(103T/Yr)
« 0.5
t 0.7
t 0.3
.0.04
t 0.4
t 0.3

Area Sources
Eulssion Reduction Under
Existing Regulations'1
(103T/Yr)
NA
NA
NA
NA
NA
NA







a.   Based  on  1'JW  SIP data.
b.   Data not  available  for this  analysts.   However,  it felt that the reduction will  be of insignificant magnitude.
c.  Total litUS emissions minus allowable emissions based on  1973 air quality.
d.  Tutal !IEbS emissions minus allowable emissions based on  SIP data.
e.  Total NkDS emissions minus projected 1975 emissions after controls.

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                                                                 TABLE  3-2
                                          MASSACHUSETTS SULFUR DIOXIDE  SUMMARY  BY  AQCR
                             Necessary  Emission0       SIP Required  Emission1 SIP Projected6     »Contr1but1on of        Emission Tolerance    Power Plant Emission      Significant Point Source        Are» Sources
                             Reduction  for  Entire       Reduction (for State)  Emission Reduction State's  Fuel  Combustion (see Table A-10)      Reduction Under Existing  Emission Reduction Under  Emission  Reduction under
AOCR Name AOCR No
Berkshire 117
Central Massachusetts 118
Metropolitan Boston 119
Metropolitan Providence 120
Merrlmack Valley 121
Southern New Hampshire
Hartford - New Haven - 042
Springfield
Candidate
Good
Good
Bad
Bad
Bad
Bad
AQCR Based on Air Quality
-39.7
-38.0
-189.0
106.3
60.5
155.02
to Meet Standards
(103T/Yrl
5.5
16.2
253.4
NA
NA
NA
(for State) 1975
OOn/Yr)
7.9
23.5
227.5
92. 4a
NA
NA
Emissions to Total AQCR
Emissions 	
98
97
98
69
29
51
(103T/Yr)
+39.7
+38.0
+189.0
-33.8
+19.4
-62.1
Regulations
(lOn/Yr)
..
-
+84.4
+43.4
-
+30.3
Existing Regulations
(103T/Yr)
+4.0
+7.3
+5.2
+0.3
+4.0
+5.5
Existing Regulations
(103T/Yr)
+2.4/-9.0 f
+ 10.2
+63.8
+11.6
* 8.1
+ 10.6
   a.  Based on 1969 data.
   c.  Total NEDS  emissions minus allowable emissions based on 1973 air quality.
   d.  Total KEDS  emissions minus allowable emissions based on SIP data.
•   e.  Total NEDS  emissions minus projected 1975 emissions after controls.
   f.  First value Is  reduction due to statewide 1* sulfur regulation.   Second value 1s  reduction
       (Increase since less than zero) due to 2,2* S regulation adopted by state for Region 117.

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plants are located in Holyoke where two monitors recorded TSP violations.
These four plants account for 35 percent of the state's contribution of
TSP to the regional total and 48 percent of the state's S02 contribution.
These sources account for about 25 percent of the regional S02 emissions
and about 21 percent of the regional TSP emissions (Tables A-7 and 8).
Modeling results indicate that both the Mt. Tom plant and the West Springfield
plant may be able to burn 2.5 percent sulfur fuel without exceeding the
standards.  According to the air quality information (Tables A-4 and 5) a
reduction in TSP and S02 (Tables A-4 and 5) will be necessary for emissions
to reach their allowable limits.  Therefore, relaxation of regulations  may
not be possible unless a case by case review indicates otherwise.

3.6.3  Industrial/Commercial/Institutional Point Source Assessment
       These Massachusetts sources account for 16 percent of the state's
contribution to the region's total for TSP and 19 percent of S02.  The
significant sources listed in Table A-6 will account for only a minor
reduction in TSP and S02 between 1970 and 1975.  Therefore, it seems likely
that relaxation of the existing regulations in this area may not adversely
effect regional air quality although localized hotspots may occur.

3.6.4  Area Source Assessment
       Area sources contribute only 10 percent of the TSP emissions to  the
Massachusetts total for the region and about six percent to the regional
totals (Table A-7).  These same sources contribute 32 percent of the states
total  S02 emissions in the AQCR and a little over 15 percent of the regional
S0£ emissions.  Since there were no S02 violations in Massachusetts in  1973
and no proposed AQCR designations, there is a possibility that the S02  emis-
sions  from this category may be increased.  It does not seem possible that
relaxation of the TSP regulations would be possible in this category.

3.7  HARVARD MODELING STUDY
3.7.1   Regulations Affecting SO^ Emissions
3.7.1.1   Regulation 5.1.1 (Requires the use of 0.5% sulfur content residual
         oil used in Boston and 12 surrounding cities and towns.)
         This regulation is generally needed in the Metropolitan Boston
District Core Area.  The analysis shows that the majority of the S02

                                  25

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concentrations observed in the Boston central  region result from emissions
in the core towns; these emissions must be controlled in order to achieve
compliance with the standard.  (On the other hand, it is not necessary to
limit the sulfur content of residual  oil  to 1.0% in the outer towns  in the
Boston area.  The annual standards could be met with the use of 1.5% sulfur
content residual oil in the outer towns).

         Although Regulation 5.1.1 is generally necessary for the achieve-
ment of standards in the core area it could be modified in two ways. Residual
oil with 1.0% sulfur content could be used in a six-month summer period by
process and pov/er generation users.  Also, the largest facilities could use
1.0% sulfur oil on an intermittent basis throughout the year, if adequate
monitoring and forecasting systems were in operation.  Both of these modifi-
cations to Regulation 5.1.1 could be implemented, consistent with attainment
of the S02 standards.

         The region of applicability of Regulation 5.1.1 was also investi-
gated in the study.  The present choice of towns in the zone of application
is judged to be appropriate, and no changes in this zone are recommended.

         The relative effectiveness of Regulation 5.1.1 on all 102 cities
and towns in the Metropolitan Boston District is summarized in Table E-1.
This table shows that the regulation has major effectiveness in 17 cities
and towns (in and around the core area), moderate effectiveness in 7 addi-
tional towns (adjacent to the core area), minor effectiveness in 14 towns
(more distant from the core area) and no significant effectiveness in 64
additional towns (at the outer parts of the district).

3.7.1.2  Regulation 5.1.2 (Requires the use of 1.0% sulfur content residual
         oil throughout the state, except for the Boston Region Core [Boston
         and 12 adjoining towns])
         The effectiveness of this regulation must be described separately
for different areas.  With reference to Table F-2, the following findings
can be stated:

3.7.1.2.1  Metropolitan Boston District AQCR 119
           Regulation 5.1.2 has moderate or major effectiveness in 8 towns,
                                    26

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minor effectiveness in 26 towns, and no significant effectiveness  in 68
towns.  The use of 1.5" sulfur oil  outside the 13 core towns  were  consis-
tent with meeting the SC^ standards throughout the District.

3.7.1.2.2  Southeastern Massachusetts District AQCR 120
           The regulation has moderate or major effectiveness in 13 towns.
This results directly from control  of the major electric-generating facilities
in the District.  Generally, 2.0% sulfur oil  could be used throughout the
District, consistent with meeting standards.   However, the impact  of the
largest fuel users in the District would have to be studied in greater de-
tail before they could be permitted to change to 2.0% sulfur oil.

3.7.1.2.3  Central Massachusetts AQCR 118 - Pioneer Valley District AQCR 42
           Regulation 5.1.2 is moderately effective in the core cities in
these Districts, and has minor effectiveness  in the immediately surrounding
towns.  The regulation has no significant effectiveness in the remaining
towns in the Districts, because $03 levels were already low in these towns,
in the absence of the regulation.

3.7.1.2.4  Merrimack Valley AQCR 121 - Bershire District AQCR 117
           Regulation 5.1.2 has only minor effectiveness in the principal
tov/ns in these two Districts, and no significant effectiveness in  the
remainder of the towns.  These districts could be placed on a 2% sulfur
oil allocation, without risk of. violating standards.

3.7.1.3  Regulation 5.1.3 (Requires the use of distillate oil with sulfur
         content not exceeding 0.3%, everywhere in the state)
         Table F-3 illustrates the principal  finding concerning the sulfur
limitations in distillate oil:  the regulation has no significant  effective-
ness anywhere in the state, assuming that 0.5% sulfur distillate oil was
used By all area sources prior to application of the regulation.  This
results because the total S02 emissions from distillate oil combustion are
significantly lower than the emissions associated with residual oil com-
bustion. (However, an important limitation in the model analysis must be
cfted here.  The model calculation grid is 4 x 4 km, and smaller scale
variations in pollutant concentration are not treated by the model.  It
is likely, for example, that S02 emissions from distillate oil combustion

                                  27

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contribute importantly to the observed S02 concentrations at the Kenmore
Square observing station in Boston.  This would not be noted by the model
if all the important emission sources were confined to a very small area.
The model calculations demonstrate that the larger regional scale impact
of the distillate oil sulfur limitation is not important, but the calcula-
tions do not treat the microscale cases.)

         The Massachusetts Department of Public Health has recently proposed
changing the sulfur limit in distillate oil  to o.5%.   The results presented
here indicate that this change can be made without significant regional  im-
pact on 862 concentrations in the state.

3.7.1.4  Regulation 5.4.1 (Requires the use of fuel having ash content of
         no more than 9% of dry weight.  This regulation is often interpreted
         as requiring a change from coal to oil fuel  in the state).
         In Massachusetts the differences in fuel  type and quality and
user characteristics cause an increase in S02 emissions when the change
from coal to oil fuel is carried out on an equivalent BTU basis.  Thus, the
impact of Regulation 5.4.1 upon S02 concentrations is negative.   This  is
illustrated in Table F-4, which shows that the regulation has no significant
(positive) impact upon S02 concentrations.

3.7.1.5  All S02 Requlations (includes the impact of Regulations 5.1.1,
         5.1.2, 5.K3 and 5.4.1)
         Table F-5 summarizes the effectiveness of the total S02 regulation
set upon the entire state.  Outside the Metropolitan Boston District,  all
of the effectiveness is associated with Regulation 5.1.2.  In the Boston
District both Regulations 5.1.1 and 5.1.2 are effective in several towns.
Regulation 5.1.3 is not effective in any town, and Regulation 5.4.1 has
negative impact.

         The S02 regulations generally have important effectiveness in
the Metropolitan Boston District, and in part of the Southeastern District
(associated with the power plants).  They have some effectiveness in the
central cities in the Central Massachusetts and Pioneer Valley Districts,
and little effectiveness elsewhere in the state.
                                   28

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3.7.2  Regulations Affecting Particulate Emissions
3.7.2.1  Regulation 5.4.1 (Limits the ash content of fuel to 9% by weight)
         This regulation has caused a major shift away from coal burning
in the state, and it has had important effectiveness throughout the state
in reducing or elimination of coal use has major effectiveness in all
districts except the Merrimack Valley and Berkshire Districts, where a
smaller number of coal-burning facilities were operating, and where existing
parti oil ate levels have been relatively low.

         Although the elimination of coal, particularly in small burners,
has been very effective in reducing particulate concentrations, this result
does not argue against the use of coal in new, large facilities where adequate
particulate collection devices can be operated.  In view of the lower $62
emissions associated with coal burning, and of the availability of coal  as
the principal domestic energy resources, the use of coal in new power sta-
tions built in Massachusetts should be considered.

3.7.2.2  Regulation 2.5.1 - relative to fossil fuel utilization facilities.
         (Evaluated by the assumption that particulate emissions from
         these facilities are reduced to 80% of existing levels, for
         facilities located in the critical areas of concern).
         Table F-7 shows that this regulation has no significant regional
effectiveness in any town in the state.  As discussed above, microscale
impacts can occur, not noted by the model calculations.  These results
suggest that the critical area of concern designation is not necessary for
fossil fuel utilization facilities; all facilities in the state can effectively
be controlled by a single emission limit.

3.7.2.3  Regulation 2.5.2 - relative to large process sources of particulate
         emissions, (evaluated by the assumption that all large process
         sources in the state are reduced to the emission limit of 25.7  Ibs/
         hour, corresponding to 200,000 Ibs/hour processes in new facilities,
         and in existing facilities in the critical areas of concern.  This
         evaluation illustrates the possible reductions in particulate con-
         centrations resulting from control of individual large facilities).
         Table F-8 illustrates that the control of individual large facilities
has major and moderate effectiveness in a number of cities and towns throughout
the state.-  The model  calculations indicate no effectiveness of this approach
                                   29

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in the Metropolitan Boston District.   However,  the  point  source emission
inventory was available only for the  30 inner towns in  the  District.   If
the point source inventory were available for the outer 72  towns,  it  is
likely that some substantial reductions would have  been found  in this
District also.
                                     30

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                                                                      APPENDIX  A

                                                         State  Implementation Plan Background

                                                 TABLE  A-l  MASSACHUSETTS AIR POLLUTION CONTROL REGIONS
Air Quality
Control Region
shire
:ral Massachusetts
•opolitan Boston
Federal
Number
117
118
119
Priority
Classification"
Partlculates
II
I
I
Spj,
III
II
I
N°_x
III
HI
III
Population
1975
(Millions)
0.16
.68
4.04
                                                                                                                  Proposed
                                                                                                              AQMA Designations1
Metropolitan Providence    120
  (R.I.)
Merrimack Valley
Southern New Hampshire     121
  (N.H.)

Hartford - New Haven -
Springfield                 42
  (CONN.)
Ill
III
III
1.60
 .68
2.54
      TSP Counties

(0)  .
(1)  Worcester

(3)  Suffolk.  Middlesex,
    Norfolk

(3)  Plymouth, Kent,0
    Providence0


(1)  Essex
(5) Hampden, Hampshire,
    Hartford,C New Havenc,
    Middlesex'*
                                         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
I II
Greater than
100
455
95
325
From - To
60-100
260-455
60-95
150-325
III
Less than
60
260
60
260
                                                                                                                                  SOX Counties
(0)

(0)
(3) Suffolk,  Norfolk,
    Middlesex

(3) Plymouth. Kent0,
    Providence0

Carlisle and  Boxford
are Included  in the
Boston AQMA

(3) Hartford0, New HavenC,
    Middlesex1-
                                         Federal  Register, July,  1974 counties  showing potential  for NAAQS violations due to growth.
                                        r
                                         Connecticut counties
                                         Rhode Island counties

-------
                                                    TABLE A-2
                                                ATTAINMENT DATES':
                                               Parti culates
                                             Attainment Dates
                                                             Sulfur Dioxide
                                                            Attainment Dates
117
118
119
120e
121e

 42e
         Name
Berkshire
Central Massachusetts
Metropolitan Boston
Metropolitan Providence
Merrimach Valley -
Southern New Hampshire
Hartford - New Haven -
Springfield
rimary
7/75
7/75
7/75
7/75
7/75
7/75
Secondary
7/75
7/75
b
7/75
7/75
7/75
Primary
a
a
7/75
7/75
7/75
a
Secondary
a
7/75
b
7/75
7/75
7/75
miruycii UAIUCS
Attainment Dates
a
a
a
a
a
a
 Air quality levels presently below standards
 18 - month extension granted
 as of May 1974
 interstate

-------
CO
CO
                                   TABLE  A-3    MASSACHUSETTS  AMBIENT  AIR QUALITY  STANDARDS
                                                All  concentrations  in  ugms/m
Federal
(Nov. 1972)
State

Primary
Secondary

Total Suspended
Annual
75(6)
60(G)
75(6)
Parti cul ate
24-Hour
260a
150a
260a
Annual
80(A)
80 (A)
Sulfur Oxides
24-Hour
365a
365a
3-Hour
1300a
___
Nitrogen Dioxide
Annual
100(A)
100(A)
_ _-. —
     Not  to be  exceeded  more  than  once  per year
    (A) Arithmetic  mean
    (G) Geometric mean

-------
                                              TABLE A-4  MASSACHUSETTS AQCR AIR QUALITY STATUS, 1973 TSPa
                                    TSP  Concentration  (ugm/m  )
Number of Stations Violating
Ambient Air Quality Standards


AQCR Name
Berkshire
Central Massachusetts
Metropolitan Boston
Metropolitan Providence
% Merrtmack Vly. So. N.H.
Hartford - New Haven -
Springfield


No.
117
118
119
120b>e
,zlb,f
42b



Reporting
6
9
23
33
30
27

Highest
Reading 2nd Highest Reading %
Primary
Annual
55
69
92
86
60
117

24-Hr
190
348
423
543
209
420

24-Hr
147
303
301
206
197
396

Annual
0
0
1
1
0
1

24-llrc
0
1
2
0
0
1

Annual
0
2
2
2
0
2

Secondary
% 24-Hrc
0 0
3 4
9 6
6 3
0 4
7 4

Reduction Required
to Meet Standards"
%
0
6
26
9
13
15


-03
+56
+67
+45
+28
+70

 1973 air quality data in National  Air  Data Bank as of June 7, 1974.

blnterstate.

""Violations based on 2nd highest  reading  at any station.
 Formula:
              fend Highest 24  Hr -  24-Hr Secondary StandardA    .nn   Annual - Annual Secondary Standard^
              |\2nd Highest  24-Hr - Background/  * luu>  KAnnual - Background7|
                       x 100
eAll noted values located in  R.I.
 All noted values located in  N.H.

-------
                                                  TABLE A-5  MASSACHUSETTS AQCR AIR QUALITY STATUS. 1973
                                                       Concentration  (ugm/m
Number of Stations Exceeding
Ambient Air Quality Standards

AflCR Name
Berkshire

Central Massachusetts
Metropolitan Boston
Metropolitan Providence
Merrlmack Vly. So. N.H.
Hartford - New Haven -
SnrinnflnlH
AQCR
No.

117
lie
119
120b.e
121b
42b

24 llr

6
9
23
28
13
25

Cont.

1
1
7
4
2
9
Highest
Annual

24
46
51
100
51
32
Reading 2nd Highest Reading
24-Hr

235
319
214
620
248
992
24-Hr

99
178
180
183
141
—
Annual

0
0
0
1
0
0
Primary
I

0
0
0
4
0
0
24-Hrc

0
0
0
1
0
1
%

0

0
4
0
4
Secondary
3-Hrc %

— —
--- --.
... ...
0
0
1
to Meet Standards^


-233
- 74
- 57
+ 20
- 57
*63f
 1973 air quality data In National  Air Data Bank  as  of June  7,  1974
blnterstate
""Violations based on 2nd highest reading at any station.
 Formula:
              2nd Highest 24-Hr - 24-Hr Standard     lnn   Annual  -  Annual  Standard      lnn
                       2nd Highest 24-Hr           x  lul)>          AmiUaT             x  lo°
 All excessive values located in R.I.
f2nd highest unavailable, therefore, highest value used to  calculate  roleback

-------
                                                  TABLE A-6  MASSACHUSETTS FUEL COMBUSTION SOURCE SUMMARY
                                                                                                                                  % Emissions  from
       AQCR Name
Berkshire
Central Massachusetts
Metropolitan Boston
Metropolitan Providence
Merrimack Valley
Southern New Hampshire
Hartford - New Haven -
Springfield
AQCR No.
117
118h
119
120e
121e
42e
Power
Plants3
0
0
10
7
0
4
Other Fuel
Point S
TSP
8f
159
69
2f
8f
2f
Combustion
ourcest"
S02
9f
239
79
2f
199
14f
Area
Sources
32
60
100
60
20
43
Total Emissions
(103 tons/year)
TSP S02
2.89 17.04
10.56
36.76
26.66
19.92
59.40
45.72
331.63
241.29
114.00
191.47
Mass.
Combustic
TSP
53
43
66
27
21
37
Fuel
in Sourc
S02
98
97
98
69
29 '
51
 Mass,  power plants only
 Mass,  plants in addition to power plants
cMass.  townships and cities
dAQCR total
Interstate
 All significant point sources when combined with power plants,  contribute at least 90% of the total  emissions  from fuel  combustion  point sources.
9A11 significant point sources, when combined with power plants  contribute less  than 90% of the total emissions from fuel  combustion point sources.
 The power plant listed in NEDS ceased operations at the end of 1971.

-------
                                          TABLE A-7  MASSACHUSETTS EMISSION SUMMARY3, TSP

AQCR Name
Berkshire
Central Massachusetts
Metropolitan Boston
Metropolitan Providence



Merrlmack Vly.-So. N.H.



Hartford - New Haven -
Springfield



AQCR
117
118
119
120
Mass.
R.I.
Total
121
Mass.
N.H.
Total
42
Mass.
Conn.
Total
Total
(103 tons/yr)
2.89
10.56
36.76

12.25
14.41
26.66

7.34
12.58
19.92

35.57
23.83
59.40
. Electricity Generation
%
2
7
24

8
9
17

5
8
13

23
15
38
(1Q3 tons/yr)
0
0
3.42

2.53
0.47
3.00

0
0.74
0.74

12.56
2.96
15.52
%c
0
0
9

21
3
11

0
6
4

35
12
26
                                                                              Industrial/Commercial/
                                                                            Institutional Point Source
                                                                                (1Q3 tons/yr)    ic
0.63
1.02
3.78
0.80
1.16
1.96
1.36
1.01
2.37
5.60
1.34
6.94
22
10
10
7
8
7
19
8
12
16
6
12
Total
156.19
101
22.68
15
16.7
11
Area Source
(103 tons/yr)
0.89
3.55
16.98
3.81
4.79
8.60
2.74
2.56
5.30
3.65
9.78
13.43
48.75
%c
31
34
46
31
33
32
37
20
27
10
41
23
31
Emissions In data bank as  of June  27,  1974

b% of total for all AQCRS

c% of total for AQCR

-------
                                           TABLE A-8  MASSACHUSETTS  EMISSION SUMMARY3, S02

AQCR Narae
Berkshire
Central Massachusetts
Metropolitan Boston
Metropolitan Providence



Merrimack Vly.-So. N.H.



Hartford - New Haven -
Springfield



AQCR
117
118
119
120
Mass.
R.I.
Total
121
Mass.
N.H.
Total
42
Mass.
Conn.
Total
Total
(1Q3 tons/yr)
17.04
45.72
331.63

168.80
72.49
241.29

34.05
79.95
114.00

98.50
92.97
191.47

%b
2
5
35

18
R
26

4
8
12

10
10
20
Electricity Generation
(103 tons/yr)
0
0
137.18

129.20
23.65
152.85

0
52.10
52.10

46.82
50.36
97.18
%c
0
0
41

77
33
63

0
65
46

48
54
51
                                                                               Indus trial/Commercial/
                                                                             Institutional Point Source
                                                                                 (1Q3 tons/yr)    %c
                                                                                                 Area Source
                                                                                             (103 tons/yr)    %c
9.30
13.79
38.05
4.43
17.51
21.94
9.10
12.04
21.14
18.98
5.77
24.75
55
30
11
3
24
9
27
15
19
19
6
13
7.43
30.62
150.04
33.60
29.35 •
62.95
23.98
16.29
40.27
31.49
32.57
64.06
44
67
45
20
40
26
70
20
35
32
35
33
Total
941.15
100
                                                  439.31
47
128.97
14
                                                                                                355.37
38
 Emissions in data bank as of June 27,  1974

b% of total for all AQCRS

c% of total for AQCR

-------
                                        TABLE A-9  MASSACHUSETTS REGULATIONS



                 Particulate Emissions                                      Sulfur Dioxide
       Existing Sources            New Sources                (controTTeoTy sulfur content of fuels)

       0  15  lbs/106 RTUa      RptwPPn                       Distillate Fuel Oil    Residual Fuel Oil and Coal
       u.i!)  IDS/IO  biu       Between                     (maximum sulfur content)  (maximum sulfur content)

                                3 and 250 106 BTU/Hr         ft „ ..   .1A6 DT11c                  f
                                                             0.17 lbs/10b BTU        0.55  lbs/10e U1U   vs
                                0.10 lbs/106 BTUb             ( 3      fur)             AQCR's except 117

                                                                                       Berkshire)
                              Greater than                                           /, ««
                                      /•                                              (1.0% sulfur
                                250 106 BTU/Hr
\£                                          (•                                         (0.72% sulfur
*                               0.05 lbs/106 BTU                                     „ „„        ,              f
                                                                                     2.2% sulfur (AQCR  117 only)f


       a0.12 lbs/106 BTU in critical areas of concern (See Regulation 2.5.0)

        This regulation also governs sources using equipment  to control sulfur oxides

       cThis regulation has been relaxed to 0.28 lbs/106 BTU until April 15, 1975.

       d0.28 lb/106 BTU in Metropolitan Boston core cities (See Regulation 5.2.1)

       facilities having an input capacity of less than 3 x  106 BTU  (6 / 106 in Metropolitan Boston) are
        prohibited from burning residual fuel oil. The more strigent  limitation for Metropolitan Boston
        is now under review by EPA.

        Passed by State but not yet approved by EPA.

-------
                                               TABLE A-10  REQUIRED EMISSION REDUCTIONS FOR TSP
                                        SIP
.P.
o




AQCR
117
118
119
120

191
1 £ 1
4?

Maximum
Air Quality
Concentration
ugm/m3
87
110
97
not
available
4.





Emissions
(1Q3 tons)
2.57
13.13
26.09
12.226

• i K
aval lab
a u a i 1 a h

a
Allowable3
Emissions
(1Q3 tons)
1.35
4.90
12.14
not
available
i «
l e
1 P
1975
Estimated
Emissions
After Controls
(103 tons)
1.35
4.26
17.78
10. 4e




Percent
Reduction
Requi red
Based On
1973 AQ Data
-03
+56
+62
+45

+28

+70


NEDS
Emissions
(103 tons)
2.89
10.56
36.76
12.25

7.34

35.57

AQCR
Allowable
Emissions '
(1Q3 tons)
2.98
4.65
13.97
6.74

5.29

10.67


Emission
Tolerance
(103 tons)
+ 0.09d
+ 0.64b
-24.62C
- 5.51d
A
- 2.05d
A
-24. 9d
      to maintain secondary standards
      tolerance = difference between SIP allowable and SIP estimated emissions after controls
     ctolerance = difference between SIP allowable and NEDS
      tolerance = difference between NEDS and allowable emissions based on 1973 AQ data
     e!969 data
     fbased on 1973 air quality

-------
                                        TABLE A-ll  REQUIRED EMISSION REDUCTIONS FOR S02
                                  SIP
AQCR
117
118
119
120
ay
Maximum
Air Quality
Concentration
ugm/m3
67
67
not
available
not
available

Emissions
(1Q3 tons)
14.42
44.06
252.81
133.59b
aval lab
Allowable3
Emissions
(1Q3 tons)
11.54
35.24
78.19
not
available
1 r
1 n
1975
Estimated
Emissions
After Controls
(103 tons)
9.11
27.89
104.15
76.45b

Percent
Reduction
Requi red
Based on
1973 AQ Data
-233
- 74
- 57
+ 20
- 57
+ 63
NEDS
Emissions
(103 tons)
17.04
45.72
331.63
168.80
34.05
98.50
AQCR
Allowable
Emissions '
(103 tons)
56.74
79.55
520.66
135.04
53.46
36.45
Emission
Tolerance
(IP3 tons)
+ 39. 7d
+ 33.83d
+189. 03d
- 33.76d
+ 19.41d
- 62.05d
 to maintain secondary  standards
'1969 data
 tolerance = difference between NEDS  and allowable emissions  based  on  1973  AQ  data
 based on 1973 air quality

-------
                                                             APPENDIX  B
                                                   Regional Air Quality Assessment
                                                TABLE B-l  REGIONAL INDICATORS FOR REVISION OF TSP REGULATIONS
Air Quality
f #
AQCR Name Monitors Violations
Berkshire 6 0
117
Central
Massachusetts 9 4
118
Metropolitan
Boston 23 6
119
Metropolitan
Providence 33 3
120e
Merrimack Valley
Southern New
Hampshire 30 4
121e
Hartford
New Haven
Springfield 67 11
42e
Priority
Classification
II
I
I
I
I
I
Expected
Attainment
Date
7/75
7/75
7/75c
7/75
7/75
7/75
Any
Proposed
AQMA
Designations?
no
yes
yes
yes
yes
yes
Total AQCR
Emissions
(103 tons/yr)
2.89
10. 5G
36.76
26.66
19.92
59.40
% Emission
from Fuel
Combustion
53
43
66
27
21
37
Tolerance
for
Emissions
Increase*
(103 tons)
+ 0.09
+ 0.64
-24.62
- 5.51
- 2.05
-24.90
cfor primary standards .that is, 18 month extension given to attain secondary standards
eiriterstate
 see Table A-10

-------
                                                TABLE  B-2   REGIONAL  INDICATORS FOR REVISION OF S02 REGULATIONS
Air Quality
» 11
AQCR Name Monitors Violations
Berkshire 7 0
117
Central
Massachusetts 10 0
118
Metropolitan
Boston 30 0
119
Metropolitan
Providence 32 1
120e
MerMmack Valley
Southern New
Hampshire 15 -0
Hartford
New Haven
Springfield 34 1
42e
Priority
Classifications
.HI
II
I
I
I
I
Expected
Attainment
Date
a
7/75b
7/75c
7/75
7/75
7/75
Any
Proposed
AQMA
Designations?
no
no
yes
yes
yes
yes
Total AQCR
Emissions
(103 tons/yr)
17.04
45.72
331.63
241 .29
114.00
191.47
% Emission
from Fuel
Combustion
98
97
98
69
29
51
Tolerance
for
Emissions
Increase"
(103 tons)
+ 39.70
+ 33.83
+189.03
- 33.76
+ 19.41
- 62.05
 air quality levels presently below standards
 for secondary standards, that is, air quality presently below primary  standards
 for primary standards, that Is. 18 month extension given to attain secondary  standards
 only for Connecticut counties
Interstate
fsee Table A-11

-------
APPENDIX C
Power Plant Assessment
TABLE C-l EXISTING MASSACHUSETTS POWER PLANTS
1975

AQCR
117
118
119
119
119
£ 119
119
119
119
119
119
119


Plant Name
None
None^
Boston Edison
New Boston
Boston Edison
Mystic
Salem Harbor
Station
Boston Edison
Edgar Station
Boston Edison
Mi not
Boston Edison
L Street
Cambridge Electric
Kendall
Cambridge Electric
Blacks tone
Brockton
Edison
Boston Edison Co.


Capaci ty
MW


760
624
802
261
55a
115
67
25
50a
12. 5a


Fuel
Type

oil
oil
oil
oil
oil
oil
oil
oil
gas
oil
oil

Fuel
Quantity
Estimated


6926e
4424e
5260e
2409e
207b
1059e
757e
451^
305d
141C
13b


Regulations Allowable %S
%S by Model ingf


0.5
0.5
1.0 , 2.5
1.0
0.5
0.5
0.5
0.5
N/A
1.0
0.5

Boiler
Designed
For Coal?


no
yes
yes
yes
not
available
yes
yes
no
not
available
not
available
120     Canal  Electric
        Sandwich
1102
oil
5329'
1.0
no

-------
TABLE C-l cont.
                                                     1975
AQCR
120
120
120
120
120
120
121
42
42
42
Capaci ty
Plant Name MU
New England Power
Somerset
Montaup Electric Co.
Somerset
Taunton Municipal
L1ght-Taunton
Taunton Municipal
Light & Mater Taunton
New Bedford Edison
tlew Bedford
Fall River Electric Co.
Fall River
None
ties tern Mass. Electric
Vlest Springfield
llolyoke Hater Power
MT TOM-llolyoke
llolyoke Gas Electric
llolyoke
1097
325
46
118
93
14. 2d

210
136
30
Fuel
Type
oil
oil
oil
oil
oil
oil

oil
gas
oil
oil
gas
Fuel
Quantity Regulations
Estimated %S
146686
3262e
332e
26 3e
725e
97d

1662e
2822e
1366e
282e
950e
1.0
1.0
1.0
1.0
1.0
1.0

1.0
1.0
1.0
1.0
N/A
Boiler
Allowable SS Designed
by Modeling' For Coal?
2.5 yes
2.5 yes
no
yes
yes
not
available

2.5 yes
2.5 yes
2.5 yes
yes
 42     llolyoke Power
        Rlverslde-llolyoke
45
oil
263B
1.0
                                                              yes
"assume 1 MW  10 x  106 BTU
b!970 NEDS data base
C1971 NEDS data base
d!972 data-Steam Electric Plant Factors. 1973 Edition, National Coal Association, Washington. D.C.
e!973 Federal Power Commission data base
 These modeling results, which were completed by EPA (OAQPS), are not an endorsement to switch fuels

-------
                       TABLE C-2  MASSACHUSETTS POWER PLANTS
                                  PLANNED NEW UNITS TO EXISTING
                                  FACILITIES BY 1975C
AQCR          Name

117     None

118     None

119     Boston Edison Co.
        Mystic

120     Canal Electric
        Sandwich

121     None

 42     None
Capaci ty
   MW
   587


   560
 1975

Fuel
Type
 oil


 oil
  Fuel
Quantity
  6611'
  6307'
                                                             Regulation
0.5


1.0
           Allowable
             35S by
           Modeling
abased on MW (9 x 106 BTU/MW Hr)(.9)B(8760 Hr/Yr) f (150 x 106 BTU/1000 gals) -f
 42 gals/BBL = 1000's BBL/Yr
D
 assume efficiency = 90%

cSteam Electric Plant Factors,  1973 Edition, National Coal Association,
 Washington, D.C.

units - oil 1000's bbls
                                       46

-------
                                                 TABLE C-3  MASSACHUSETTS  POWER PLANT SUMMARY  BY AQCR




Sulfur Dioxide TSP
1975 Fuel Required • 1975 Fuel Required 1975 Emission
by Existing Regulations by Modeling' Reductions Based h r
AQCR
Berkshrre
117
Central Massachusetts
118
Metropolitan Boston
119 coal
oil
gas
Metropolitan Providence
120 coal
oil
gas
Merrimach Valley
Southern New Hampshire
121
Hartford-New Haven-Springfield
42 coal
oil
gas


20,448a
305
0
0
0
0
0
3,772
jl.O*S
Nn
Nn
0
7,810
0
0,
24,676a
0
Nn
0
3,573
0
>1.0XS
P 1
P 1
0
0
0
0
0
0
P 1
0
0
0
imc rt c*c i nvc » i n*c i me 00 tXl S 11 RQ "69^ 1 3t • OI1S
|j/o < U.oib I.UZb iy/o /tons/vr^
Emission . Emission iioni/yr;
Reduction Reduction
( tons/y r) ( tons/yr)

0. 0 .
fill Ififi" , N n t A u n i 1 n h 1 n d1?/la
0 0
0 0
«T7nd ... . Mnt Aunllihln . d1?ftd
0 0
0 0
in ?fi? •• • 	 Nnf1 Auailahlo .frll ??*i
0 0
aincludes new facilities
 reduction calculated from NEDS emission rates
 all units on line prior to 1974 were assumed to be considered as an existing facility
 these reductions do not account for Increases due to new units coming on after 1972
eThe Power Plant listed In NEDS ceased operations at the end of 1971
fby EPA (OAQPS)
Units - oil  1000's gals, coal  1000's tons, gas MCF

-------
TABLE C-4  MASSACHUSETTS "MODELING ANALYSIS OF POWER PLANTS FOU FUEL CONVERSION"
                           WALDEN RESEARCH DIVISION OF ABCOR INC."
                                                                                 BY




AQCR Name
Berkshire
Central Massachusetts
Metro. Boston



Metro. Providence
























AQCR No. Plant/Conversion
117 None
118 None
119 Salem Harbor
1972 Operati ons
switch units 1,2,3
no Interactions with other plants
120 New England Power Company
Somerset
1972 Operations
contribution from Montaup
Electric C. - Somerset
total
Switch Unit 3 (I.5SS)
Montaup (with switch)
total
Switch Unit 3 (2.5%S)
Montaup (with switch)
total
Switch Units 1, 2, 3(2. 5SS)
Montaup (with switch)
total
120 Montaup Electric Co.
Somerset
1972 Operations
contribution from New England
Power Company Somerset
total



Nominal
Load



35
163



111
0

111
173
0
T7J
24)
0
MT
487
0
41B7


155

0
T5T
Maximum
SO?
Secondary
Standard Maximum
Exceeded? Load



41
no 193



114
0

no 114
177
0
no 177
243
0
no 247
502
0
yes 50T


181

0
no 181
24-Hour Concentration (ug,

Secondary
Standard Nominal
Exceeded? Load



3
no 17



7
J)

no 7
12
0
no 12"
12
0
no T2~
20
0
yes W


12

0
no 12
'mj)
Particulates
Secondary Secondary
Standard Maximum Standard
Exceeded? Load Exceeded?



3
no 20 no



7
_0

no 7 no
12
0
no T? no
12
0
no f?" no
21
0
no 2T no


14

0
no W no




S02



2
11



6
2

8
8
6
Tf
11
e
17
24
6
35


14

A
T5
Maximum Annual
Concentration (ug/mj)
Secondary
Standard
Exceeded? Particulates



• 1
no 1



. 1
. 1

no •• 1
- 1
2
no 2"
• 1
2
no ~7
1
_2
no 3



• 1

1
no 1


Secondary
Standard
Exceeded?




no






no


no


no


no





no

-------
TABLE C-4  cont.



Haxtu
jin 24-Hour Cono
entratlon (u
SOj
SQ£R Na»e ACCR No. Plant/Conversion
Metro. Providence (cant.) 120 ManUup Electric Co.
Somerset (cont. )
Switch Units 718 (2. SIS)
Hew England Power
(with sultchb)
total
Switch Units 7 1 8 (1. 5JS)
New England Power
(with switch":)
total
Switch Units 718 (2. SIS)
New England Power
(with switch11)
total
Nominal
load


517

0
5T7
517

0
5T7
517

0
5T7
Secondary
Standard
Exceeded?





yes



yes



yes
Maxim™
toad


583

0
567
583

0
501
583

0
681
Secondary
Standard
exceeded?





yes



yes



yes
Nominal
Load


175

0
T75
175

0
m
175

0
m
a/Mj) Maximum Annual
Particulars
Secondary
Standard
Exceeded?





yi!S



yes



yes
Maximum
Load


189

0
TSJ
189

0
TBS
189

0
Ta5
Secondary
Standard
Exceeded?





yes



yes



yes
SOj


47

7
54"
47

9
55
47

20
n
Concentration (uq/n3)
Secondary
Standard
Exceeded?





no



no



yes
Participates


• 1

2
~l
- \

2
~l
• 1

2
~l
Secondary
Standard
Exceeded?





no



no



no
Mcrrlniach  Valley
Southern New Hampshire
llartford-Nuw Haven
Springfield
                              42
"report  lo EPA  9/12/74
bswltch  unit  3  to  2.SIS  coal
Switch  unit  3  to  2.SIS  coal
dswtlch  unit  I. 2. 3 to  2.btS  coal

-------
                                   TABLE C-5
               POWER PLANT CONVERTIBLE UNITS ANALYZED BY  WALDEN*
    Plant
Mason
Salem Harbor
South Street
Schiller
Montville
Brayton Point

Somerset
Unit
No.
3,4
1,2,3
121,122
4,5
1,2,5
1,2,3
3
% Sulfur
Coal
2.5
2.5
2.0
2.5
3.0
2.5
1.5
% Ash
Coal
15
15
20
15
15
15
15
Parti cul ate
Control
Efficiency
80
95
90
90
80
98
98
Estimated
Annual Coal Use*
103 Ton
202
757
271
283
416
2,688
1,431
7,8
2.5
15
85
463
* Coal use estimated on the basis  of equivalent BTU heating  value of  1972
  oil (and gas, if any) used in units designated for possible  conversion.
a report to EPA 9/12/74
                                      50

-------
                                                                   APPENDIX   D
                                             Industrial.  Commercial.  Institutional  Source Assessment

                                                 TABLE  D-l   MASSACHUSETTS SIGNIFICANT SOURCES8
       AQCR Name
Berkshire
Central Massachusetts
Metropolitan Boston
Metropolitan Providence
Merrlmack Valley -
Southern New Hampshire
Hartford - New Haven
Springfield
Reductions Under
NEDS

ICR No.
117
118
119





120
121
42
TSP Emissions
tons/yr
569
1101
Critical Areas

1666
Rest of AQCR
96

532
1136
4775
S0£ Emissions
tons/yr
8602
15439
Boston Core
Cities
1025
Rest of AQCR
8594

826
7997
13240
Existing RegulationsC
TSP
tons/yr
484
746
Critical
Areas
225
Rest of
AQCR
94
38
366
250
SOo
tons/yr
4022 /-244d
7276
Boston Core
Cities
813
Rest of AQCR

4441
346
4004
5488
% NEDS
TSP Emissions
From Coalb
(before Regulations)
0
49
Critical Areas
68
Rest of AQCR
0
\J

96
64
97
"See Table A-6
 only for significant sources not Including power plants
cexcept of AQCR 119 assume 67% of BTU generated were in areas  of critical  concern
 reduction calculated from NEDS data
dfirst value is reduction due to statewide 1% sulfur renulatlon.  Second value is  reduction (Increase since less  than zero)
 due to 2.2% S regulation adopted by State for Region 117.

-------
AQCR Name
AQCR No.
                     TABLE D-2

    MASSACHUSETTS LISTING OF SIGNIFICANT SOURCES

     Significant TSP Sources

Name                    Location
              Significant S02 Sources
        Name                      Location
Berkshire
  117      General Electric Co.
           Rising Paper Co.
           Kimberly Clark Corp.
           Arnold Print Works
           Kimberly Clark Corp.
           Sprague Electric Co.
           Rochester Paper Co.
           Hurl but Papers
                      Pittsfield
                      Great Barrington
                      Columbia Mill, Lee
                      Adams
                      Eagle Mill, Lee
                      N.  Adams
                      Adams
                      Laurel Mill, S. Lee
General Electric Co.
Rising Papers Co.
Kimberly Clark Corp.
Sprague Electric Co.
Arnold Print Works
Kimberly Clark Corp.
Hurl but Papers
Rochester Paper Co.
Williams College
Pittsfield
Great Barrington
Columbia Mill, Lee
N. Adams
Adams
Eagle Mill, Lee
Laurel Mill, S. Lee
Adams
Williamstown
Central Massachusetts






















Metropolitan Boston
Massachusetts




Metropolitan Providence
(Mass. - R.I.)
118 Mass. Electric, Webster
Fitchburg Paper Co.
Cranston Print Works
Norton Co.
Borden Inc. Chem. Div.
Fitchburg Gas & Electric
Heywood-Wakefield Co.
Westboro State Hospital
Romar Tissue Mills
Foster Grant Co.
Barre Wool Combing Co.
Wyman Gordon Co.
Worchester State Hospital
Whitten Machine Works
Worchester Cold Storage








119 Boston Engine Terminal
General Electric
Penn-Central
Eastman Gelatin Corp.
Bird & Son
Tileston & Hollingsworth

120 Otis Air Force Base
.Firestone Rubber
Worchester
Fitchburg
Webster
Worchester
Leominster
Fitchburg
Gardner
Westborough
Hardwick
Leominster
S. Barre
N. Graf ton
Worchester
Whittinsville
Worchester
*







Boston
Lynn
Boston
Peabody
E. Wai pole
Boston

Sandwich
Fall River
Mass. Electric, Webster
Fitchburg Gas & Electric
Cranston Print Works
Norton Co.
Fitchburg Paper Co.
Foster Grant Co.
Wyman Gordon Co.
Worchester Cold Storage
Borden Inc. Chem. Div.
Graf ton State Hospital
Heywood-Wakefield Co.
Romar Tissue Mills
Barre Wool Combing Co.
College of Holy Cross
Westboro State Hospital
Whitten Machine Works
North American Rockwell
Worchester State Hospital
Haywood Schuster Mills
The Felters Co.
Worchester City Hospital
Gardner State Hospital
E. Bernat & Sons Co.
General Electric
Eastman Gelatin Corp.
Tileston & Hollingsworth
Harvard Medical School
Boston Naval Shipyard
Mass. Institute of Tech.
Bird & Son
Firestone Rubber
Texas Instruments
Worchester
Fitchburg
Webster
Worchester
Fitchburg
Leominster
N. Graf ton
Worchester
Leominster
N. Graf ton
Gardner
Hardwick
S. Barre
Worchester
Westborough
Whittinsville
Hopedale
Worchester
E. Douglas
Mi 11 bury
Worchester
Gardner
Uxbridge
Lynn
Peabody
Boston
Boston
Charlestown
Cambridge
E. Wai pole
Fall River
Attleboro

-------
TABLE D-2 cont.

AQCR Name
AQCR Ho.
     Significant TSP Sources

Name                    Location
    Significant S02 Sources

Name                     Location
Merriinack Valley
Southern New Hampshire
  (Mass. - N.H.)
  121      Boston & Maine                 Billerica
           Greater Lawrence Ind.          Lawrence
           Continental Can Co.            llaverhill
           Oxford Paper Co.               Lawrence
           Mead Corp.                     Lawrence
           General Tire - Bolta D1v.      Lawrence
           Western Electric Co.           N. Andover
           Boott Mill                     Lowell
                                           Continental Can Co.             llaverhill
                                           Oxford Paper Co.                Lawrence
                                           Mead Corp.                      Lawrence
                                           Greater Lawrence Ind.           Lawrence
                                           Boott Mill                      Lowell
                                           General Tire - Bolta Div.       Lawrence
                                           Western Electric Co.            N. Andover
                                           Phillips Acad.                  Andover
                                           Lowell General Hospital         Lowell
                                           Tyer Rubber Corp.               Andover
                                           Parkwood Laminates              Lowell
                                           Boston & Maine                  Bellerica
                                           Steam Assoc.                    Lowell
                                           Wamesit Power Co.               Lowell
                                           Rowland Ind.                    Lawrence
                                           Hamel Leather Co.               llaverhill
                                           Joan Fabrics Corp.              Lowell
                                           Corenco Corp.                   Tewksbury
                                           Bon Secours Hospital            Methuen
Hartford - Mew Haven -
Springfield
  (Conn. - Mass.)
  042      University of Massachusetts    Amherst
           Monsanto                       Springfield
                                           University of Massachusetts
                                           Monsanto
                                           Uniroyal Corp.
                                           Uare Industries
                                           Hodges Carpet
                                           Westfield River Paper
                                           Strathmore Paper
                                           Deerfield Glasslne Co.
                                           Northampton State Hospital
                                           Monson State Hospital
                                           Springfield Awning Co.
                                           Chicopee Manufacturing
                                           Smith College
                                           Franklin Paper
                       Amherst
                       Springfield
                       Chicopee
                       Ware
                       Springfield
                       Russell
                       W.  Springfield
                       Monroe
                       Northampton
                       Palmer
                       Springfield
                       Chicopee
                       Northampton
                       Holyoke

-------
     APPENDIX  E

Area Source Assessment

      TABLE E-l
    AREA SOURCES3
                Fuel  Burned
Emissions
AQCR Name AQCR No.
Berkshire 117










Central
Massachusetts 118










Merrimack Valley -
Southern New Hampshire 121









Type
Coal :
Anthracite
Bituminous
Oil:
Distillate
Residual
Gas:
Natural
Process
Wood:


Coal:
Anthracite
Bituminous
Oi 1 :
Distillate
Residual
Gas:
Natural
Process
Wood:


Coal :
Anthracite
Bituminous
Oil:
Distillate
Residual
Gas:
Natural
Process
Wood :
Amount13

1600
900

67890
32790

3480
0
1900



2800
3010

268,740
136,960

16140
0
2900



2990
2160

207,040
107,610

13,530
0
400
% S

0.7
1.5

0.3
2.3

—
—
— — —>



0.7
1.5

0.3
2.3

— _
—
___



0.7
1.5

0.3
2.3

—
—
—
Part.

12
43

403
377

30
0
24
889


21
164

1610
1575

140
0
36
3546


22
110

1244
1238

119
0
	 5
SOg

30
37

1446
5921

0
0
0
7434


52
108

5724
24,728

4
0
1
30,617


55
84

4410
19,429

4
0
0
                                          2738   23,982
           54

-------
TABLE E-l (cont.)
                                                  Fuel  Burned
                                                    Emissions
       AQCR Name
Metropolitan Boston
AQCR No.

  119
Hartford - New Haven
Springfield
   42
Metropolitan
Providence
  120
'Type
Coal :
Anthraci te
Bituminous
Oil:
Distillate
Residual
Gas:
Natural
Process
Wood :

Coal :
Anthracite
Bituminous
Oil:
Distillate
Residual
Gas:
Natural
Process
Wood :

Coal :
Anthracite
Bituminous
Oil:
Distillate
Residual
Wood:

Amountb

14,870
11,250

1,300,240
673,570

81 ,900 °
0
2200


7880
3590

269,140
140,940

15,630
0
4900


1470
2420

280,360
152,360
1800

% S

0.7
1.5

0.3
2.3

___
—
—


0.7
1.5

0.3
2.3


—
—


0.7
1.5

0.3
2.3
___

Part.

109
580

7800
7746

718
0
27
16,980

58
157

1618
1621

136
0
61
3651

11
138

1696
1753
22
3810
S02

275
431

27,695
121,613

23
0
1
150,038

146
157

5733
25,447

4
0
1
31 ,488

27
82

5971
27,508
0
337594
JNEDS data.

3Coal in tons; oil  in 1000 gals.; gas in lO^CF;  wood in tons.
                                            55

-------
en
cr>
                                                   TABLE  F-l

                                       EFFECTIVENESS OF REGULATION 5.1.1

                                       (Number of towns in  each category)
District
Metropolitan Boston AQCR 119
Merrimack Valley- AQCR 121
Southern New Hampshire
Metropolitan Providence AQCR 120
Central Massachusetts AQCR 118
Hartford - New Haven - AQCR 42
Springfield
Berkshire AQCR 117
No Signifi-
cant Effec-
tiveness
64

(Regulatii
the other


Minor
Effec-
tiveness
14

in 5.1.1 is n
k districts)


*
Moderate
Effective-
ness
7

ot applicable


Major
Effective-
ness
17

in


           NOTES:   (1)  Regulation  5.1.1  requires the use of 0.5%  sulfur content
                         residual  oil  in 13 cities and towns surrounding Boston*.
                                                                                                                o>

                                                                                                                <
                                                                                                                EU

                                                                                                                o.

                                                                                                                cr
                                                                                                                3
                                                                                                                _j.


                                                                                                                n>

                                                                                                                to



                                                                                                               $'
                                                                                                                O
                                                                                                                Q-
                                                                                                                fD
                                                                                                               in

                                                                                                               to
                                                                                                               c+
                                                                                                               c

-------
                                       TABLE  F-2

                           EFFECTIVENESS  OF REGULATION  5.1.2.
                           (Number of  towns in  each  category)

District

Metropolitan Boston AQCR 119
Herrimack Valley- AQCR 121
Southern New Hampshire
Metropolitan Providence AQCR 120
Central Massachusetts AQCR 118
Hartford - New Haven - AQCR 42
Springfield
Berkshire AQCR 117
No Signifi-
cant Effec-
tiveness
68
24

34
48
58

30
Minor
Effec-
tiveness
26
4

13
10
7

2
Moderate
Effective-
ness
7
0

7
2
4

0
Major
Effective-
ness
1
0

6
0
0

0
NOTES:  (1)  Regulation 5.1.2 requires  the use of 1.0% sulfur  content
             residual  oil.                                          <

-------
                                                  TABLE F-3

                                      EFFECTIVENESS OF REGULATION 5.1.31
                                      (Number of towns in each category)
tn
00
District
Metropolitan Boston AQCR 119
Merrimack Valley- AQCR 121
Southern New Hampshire
Metropolitan Providence AQCR 120
Central Massachusetts AQCR 118
Hartford - New Haven - AQCR 42
Springfield
Berkshire AQCR 117
No Signifi-
cant Effec-
tiveness?
102
28
60
60
69
32
Mi nor
Effec-
tiveness
0
0
0
0
0
0
Moderate
Effective-
ness
0
0
0
0
0
0
Major
Effective-
ness
0
0
0
0
0
0
           NOTES:    (1)   Regulation 5.1.3 requires  the use  of distillate  oil with  a
                         sulfur content not exceeding  0.3%.

                    (2)   This  conclusion is based on the assumption  that  0.5%  sulfur distillate
                         oil was used by all  area sources prior to application of  the regulation.

-------
                                                  TABLE F-4

                                      EFFECTIVENESS OF REGULATION 5.4.1
                                      (Number of towns in each category)
CJl
IO
District

Metropolitan Boston AQCR 119
Herri mack Valley- AQCR 121
Southern New Hampshire
Metropolitan Providence AQCR 120
Central Massachusetts AQCR 118
Hartford - New Haven - AQCR 42
Springfield
Berkshire AQCR 117
No Signifi-
cant Effec-
tiveness
102
28
60
60
69
32
Minor
Effec-
tiveness
0
0
0
0
0
0
Moderate
Effective-
ness
0
0
0
0
0
0
Major
Effective-
ness
0
0
0
0
0
0
          NOTES:    (1)
Regulation 5.4.1 requires that the ash content of fuel^s not
exceed 9% of dry weight.

-------
                                       TABLE F-5
                           EFFECTIVENESS OF REGULATION(ALL S02 REGULATIONS)
                           (Number of towns in each category)
District
Metropolitan Boston AQCR 119
Merrimack Valley- AQCR 121
Southern New Hampshire
Metropolitan Providence AQCR 120
Central Massachusetts AQCR 118
Hartford - Mew Haven - AQCR 42
Springfield
Berkshire AQCR 117
No Signifi-
cant Effec-
tiveness
39
24
34
47
58
30
Minor
Effec-
tiveness
23
4
14
11
8
2
Moderate
Effective-
ness
17
0
6
2
3
0
Major
Effective-
ness
23
0
6
0
0
0
NOTES:   (1)  This includes  Regulations  5.1.1, 5.1.2, 5.1.3 and 5.4.}.

-------
                                       TABLE F-6

                           EFFECTIVENESS OF REGULATION 5.4.1
                           (Number of towns In each category)
District

Metropolitan Boston AQCR 119
Merrimack Valley- AQCR 121
Southern New Hampshire
Metropolitan Providence AQCR 120
Central Massachusetts AQCR 118
Hartford - New Haven - AQCR 42
Springfield
Berkshire AQCR 117
No Signifi-
cant Effec-
tiveness
28
26
46
55
37
30
Minor
Effec-
tiveness
46
0
7
3
9
2
Moderate
Effective-
ness
19
2
3
1
8
0
Major
Effective-
ness
9
0
4
1
15
0
NOTES:   (1)  Regulation 5.4.1 requires that the ash content of fue\s not
              exceed 9% of dry weight.

-------
cri
rv>
                                                  TABLE F-7

                                      EFFECTIVENESS OF REGULATION  2. EL'1

                                RELATIVE TO FOSSIL FUEL UTILIZATION FACILITIES

                                      (Number of towns in each category)
District
Metropolitan Boston AQCR 119
Merrimack Valley- AQCR 121
Southern New Hampshire
Metropolitan Providence AQCR 120
Central Massachusetts AQCR 118
Hartford - New Haven - AQCR 42
Springfield
Berkshire AQCR 117
No Signifi-
cant Effec-
tiveness
102
28
60
60
69
32
Mi nor
Effec-
ti veness
0
0
0
0
0
0
Moderate
Effective-
ness
0
0
0
0
0
0
Major
Effective-
ness
0
0
0
0
0
0
           NOTES:   (1)  Particulate emissions are assumed to be reduced to
                         regulation levels in the critical areas of concern.
of pre-

-------
OY
CO
                                                TABLE F-8

                                     EFFECTIVENESS OF REGULATION 2.5.2
                          RELATIVE TO' LARGE PROCESS SOURCES OF PARTICULATE EMISSIONS
                                     (Number of towns in each category)

District

Metropolitan Boston AQCR 119
Herrimack Valley- AQCR 121
Southern New Hampshire
Metropolitan Providence AQCR 120
Central Massachusetts AQCR 118
Hartford - Mew Haven - AQCR 42
Springfield
Berkshire AQCR 117
No Signifi-
cant Effec-
tiveness
102
16

55
42
M.D.

29
Minor
Effec-
tiveness
0
7

2
9
M.D.

2
Moderate
Effective-
ness
0
6

1
4
M.D.

1
Major
Effective-
ness
0
3

2
5
M.D.

0
          NOTES:   (1)
Particulate emissions from all  large process sources are
assumed to be reduced to 25.7 Ibs/hour, the allowable emission
rates from a process with a production rate of 200,000 Ibs/hour
in critical areas of concern, according to the process weight
table in Regulation 2.5.2~
                        M.D. Indicates missing data.

-------
                                   TECHNICAL REPORT DATA
                            (Please read Instructions on the reverse before completing)
1. REPORT NO.
  EPA-450/3-74-084
                                                            3. RECIPIENT'S \CCESSION-NO.
4. TITLE AND SUBTITLE
  IMPLEMENTATION  PLAN REVIEW FOR MASSACHUSETTS
  AS REQUIRED  BY  THE ENERGY SUPPLY AND  ENVIRONMENTAL
  COORDINATION ACT
             5. REPORT DATE
                December  1974
             6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
                                                            8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
                                                            10. PROGRAM ELEMENT NO.
  U.S.  Environmental  Protection Agency,  Office of Air
  Quality Planning  and Standards, Research Triangle
  Park, N.C., Regional Office I, Boston, Massachusetts
  and TRW, Inc.,  Vienna, Virginia.	
             11. CONTRACT/GRANT NO.

                 68-02-1385
 12. SPONSORING AGENCY NAME AND ADDRESS
  U.S.  Environmental  Protection Agency
  Office of Air and  Waste Management
  Office of Air Quality Planning and  Standards
  Research Triangle  Park, North Carolina  27711
             13. TYPE OF REPORT AND PERIOD COVERED
                     Final
             14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
16. ABSTRACT
       Section  IV  of the Energy Supply  and Environmental Coordination Act of 1974,
  (ESECA) requires EPA to review each State Implementation  Plan (SIP) to determine
  if revisions  can be made to control regulations for stationary fuel combustion
  sources without  interferring with the attainment and maintenance of the national
  ambient air quality standards.  This  document, which is also  required by Section
  IV of ESECA,  is  EPA's report to the State indicating where  regulations might be
  revised.
17.
                                KEY WORDS AND DOCUMENT ANALYSIS
                  DESCRIPTORS
                                              b.lDENTIFIERS/OPEN ENDED TERMS
                           c. COSATI Field/Group
 Air pollution
 State implementation  plans
18. DISTRIBUTION STATEMENT

  Release unlimited
19. SECURITY CLASS (ThisReport)

  Unclassified	
21. NO. OF PAGES
     66
                                               20. SECURITY CLASS (Thispage)
                                                 Unclassified
                                                                          22. PRICE
EPA Form 2220-1 (9-73)
                                             64

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