EPA-450/3-75-001

JANUARY 1975
     IMPLEMENTATION PLAN REVIEW
                  FOR
           VIRGIN ISLANDS
             AS REQUIRED
                  BY
          THE ENERGY SUPPLY
                  AND
   ENVIRONMENTAL COORDINATION ACT
     U. S. ENVIRONMENTAL PROTECTION AGENCY

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                                                           EPA-450/3-75-001
                    IMPLEMENTATION PLAN REVIEW

                                FOR

                          VIRGIN ISLANDS

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

          U. S. Environmental Protection Agency, Region II
                         26 Federal Plaza
                     New York, New York   10007
                Environmental Services of TRW, Inc.
           800 Foil in Lane, SE, Vienna, Virginia  22180
                       (Contract 68-02-1385)
               U. S. Environmental Protection Agency
                Office of Air and Waste Management
            Office of Air Quality Planning and Standards
            Research Triangle Park, North Carolina 27711
                            January 1975

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                            U.S.  VIRGIN  ISLANDS

            ENERGY SUPPLY AND ENVIRONMENTAL COORDINATION ACT
            (SECTION IV - STATE IMPLEMENTATION PLAN REVIEW)

                            Table of Contents                          Page
1.0  EXECUTIVE SUMMARY 	   1
2.0  STATE IMPLEMENTATION PLAN REVIEW	   5
     2.1  SUMMARY	   5
     2.2  CURRENT AIR QUALITY STATUS OF  VIRGIN ISLANDS 	   8
          2.2.1   Definition of Air Quality Control Regions	   8
          2.2.2   Air Quality Standards 	   8
          2.2.3   Air Quality Monitoring	   8
          2.2.4   Emissions of Sulfur Dioxide and Particulates	   8
          2.2.5   Particulate and  S02 Regulations 	   9
          2.2.6   Control Strategy Assessments	   9
     2.3  GENERAL REVIEW OF THE CURRENT  IMPLEMENTATION PLAN	   9
          2.3.1   Background To The Development Of The
                  Particulate and  Sulfur  Dioxide Control Strategies .  .  10
3.0  AIR QUALITY  CONTROL REGION ASSESSMENTS	  11
     3.1  FUEL COMBUSTION SOURCE  EVALUATION	11
          3.1.1   Power Plant Evaluation	  11
          3.1.2   Significant Industrial  Point Source Evaluation. ...  11
          3.1.3  Area Source Evaluation	  12
          3.1.4   Fuel Analysis	  12
     3.2  VIRGIN  ISLANDS AIR QUALITY CONTROL REGION	12
          3.2.1   Regional Assessment 	  12
          3.2.2  Power Plant Assessment	  13
          3.2.3  Other Major Combustion  Sources Assessment 	  13
          3.2.4  Area Source Assessment	13
          3.2.5  Fuel Assessment	  14
4.0  REFERENCES
APPENDIX A - STATE IMPLEMENTATION PLAN BACKGROUND
APPENDIX B - REGIONAL AIR QUALITY SUMMARY
APPENDIX C - POWER PLANT SUMMARY
APPENDIX D - INDUSTRIAL/COMMERCIAL/INSTITUTIONAL SOURCE SUMMARY
APPENDIX E - AREA SOURCE SUMMARY
APPENDIX F - FUEL USE SUMMARY

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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 information
on excessively restrictive control regulations.  The intent of ESECA is that
SIP's, wherever possible, be revised in the interest of conserving low sulfur
fuels or converting sources which burn oil or natural gas to coal.  EPA's
objective in carrying out the SIP reviews, therefore, has been to try to
establish if emissions from combustion sources may be increased.  Where an
indication can be found that emissions from certain fuel burning sources can
be increased and still attain and maintain NAAQS, it may be plausible that
fuel resource allocations can be altered for "clean fuel savings" in a manner
consistent with both environmental and national energy needs.

     In many respects, the ESECA SIP reviews parallel EPA's policy on clean
fuels.   The Clean Fuels Policy has consisted of reviewing implementation plans
with regards to saving low sulfur fuels and, where the primary sulfur dioxide
air quality standards were not exceeded, to encourage States to either defer
compliance regulations or to revise the S02 emission regulations.  The States
have also been asked to discourage large scale shifts from coal to oil where
this could be done without jeopardizing the attainment and maintenance of
the NAAQS.

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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 effect many
 State plans and in some instances conflict with current national energy con-
 cerns,  a review of the State Implementation Plans is a logical follow-up to
 EPA's  initial  appraisal of the SIP's conducted in 1972.  At that time SIP's
 were approved  by EPA if they demonstrated the attainment of NAAQS or more
 stringent  state  air quality standards.   Also, at that time an acceptable
 method  for formulating control strategies was the use of an  example region
 for demonstrating the  attainment of  the standards.

     The example region concept permitted a State to identify the most pol-
 luted 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  re-
gulation requiring  1 percent sulfur  oil  to  be burned state-wide where the use
of 3 percent sulfur coal would be adequate  to attain NAAQS in some locations.

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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, how-
ever, represent EPA's best judgment and effort in complying with the ESECA
requirements.  The time and resources which EPA has had to prepare the reports
has not permitted the consideration of growth, economics, and control strategy
tradeoffs.  Also, there has been only limited dispersion modeling data avail-
able by which to address individual point source emissions.   Where the modeling
data for specific sources were found, however, they were used in the analysis.

     The data upon which the reports' findings are based 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 suit-
able plan, it is suggested that States select control strategies which place
emissions for fuel combustion sources into perspective with all sources of
emissions such as smelters or other industrial processes.  States are en-
couraged 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 ($02) emissions.  This  is because sta-
tionary fuel  combustion sources constitute the greatest source of S02 emissions
and are a major source of TSP emissions.

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     Part of each State's review was organized to  provide  an  analysis  of
 the S02 and TSP emission tolerances within  each of the  various  AQCR's.   The
 regional emission tolerance estimate is,  in many cases,  EPA's only  measure
 of the "over-cleaning" accomplished by a  SIP-   The tolerance  assessments
 have been combined in Appendix B with other regional  air quality  "indicators"
 in an attempt to provide an evaluation of a region's  candidacy  for  changing
 emission limitation regulations.  In conjunction with the  regional  analysis,
 a summary of the State's fuel  combustion  sources (power plants,  industrial
 sources, and area sources)  has been carried out in Appendices C,  D, and E.

     The U.S.  Virgin Islands State Implementation  Plan  has  been  reviewed
 for the most prevalent causes  of over-restrictive  fuel  combustion and  emis-
sion  limiting  regulations.   The major findings of  the review  are:
     FOR SULFUR DIOXIDE. THERE ARE INDICATIONS OF  SOME  POTENTIAL  FOR
     RELAXING  EXISTING EMISSION LIMITING  REGULATIONS.
     FOR TOTAL  SUSPENDED PARTICULATES,  THERE ARE NO INDICATIONS
     OF ANY  POTENTIAL FOR REVISING FUEL COMBUSTION SOURCE  EMISSION
     LIMITING  REGULATIONS.
     The supportive findings of the SIP review are as follows:
     Recent  revision  of the Virgin Islands  sulfur  in  fuel  regulations  has
     been withdrawn,  however,  the  Virgin  Islands are  in  the process of
     developing  a  regulation which will be  compatible with  the  intention
    of Section  IV  of ESECA.
     Fuel combustion  sources emit  approximately 13 percent  of all total
    suspended particulate  emissions  in the Virgin Islands.   With air
    quality standards  being exceeded in  1973, relaxation of  existing
    fuel combustion  emission  limiting  regulations would tend to  further
    increase emissions  and  aggravate the existing air  quality  levels.

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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:
     •   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 NAAQS or; more stringent State standards?
     •   Has the State not  initiated action to modify combustion source emis-
         sion  regulations for fuel savings; i.e., under the Clean Fuels Policy?
     •   Are there no proposed  Air Quality Maintenance Areas?
     t   Are there indications  of a sufficient number of monitoring sites
         within a region?
     •   Is there an expected 1975 attainment date for NAAQS?
     •   Based on (1973)  air quality data, are there no reported violations
         of NAAQS?
     •   Based on (1973)  air quality data, are there indications of a toler-
         ance  for increasing emissions?
     •   Are the total emissions from  stationary fuel combustion sources pro-
         portionally lower  than those  of other sources?
     •   Do modeling results for specific fuel combustion sources show a
         potential for a  regulation revision?
     •   Is there a significant clean  fuels savings potential in the region?
     The following portion of  this report is directed at answering these
questions.  An AQCR's potential for revising regulations increases when there
are affirmative responses  to the above.

     The initial  part of the SIP review report, Section 2 and Appendix A,
was organized to provide the background and current situation information
for the State Implementation Plan.   Section 3 and the remaining Appendices
provide an AQCR analysis which helps establish the overall  potential for
revising regulations.

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                                   TABLE 2-1

                       STATE IMPLEMENTATION PLAN REVIEW
                                   (SUMMARY)
                      "Indicators"
                                                                 U.S.
                                                            Virgin Islands
    •   Does the State have air quality standards
  which  are more stringent than NAAQS?                        No      No
    •   Does the State have emission limiting regulations
  for  control of:
       1.  Power plants                                       Yes     Yes
      2.  Industrial sources                                 Yes     Yes
      3.  Area sources                                       Yes     Yes
    t  Did the State use an example region approach for
  demonstrating the attainment of NAAQS or more stringent
  State standards?                                            No      No
   •  Has the State not initiated action to modify com-
  bustion source emission regulations  for fuel  savings;
  i.e., under the Clean Fuels Policy?                          Yes     No
   t  Are there jio proposed Air Quality Maintenance Areas?   Yes     Yes
   •  Are there indications of a sufficient number of
 monitoring  sites  within a region?                           No      No
   e  Is there  an  expected 1975 attainment date for NAAQS?   Yes     Yes
   •  Based  on  (1973)  Air Quality Data, are there no
 reported violations  of NAAQS?                               No      Yes

   •  Based  on  (1973)  Air Quality Data, are there indica-
 tions  of a  tolerance  for increasing  emissions?              No      No

   •  Are the total  emissions from stationary  fuel  com-
 bustion  sources proportionally lower than those of other
 sources?                                                    Yes      No
   •   Do  modeling  results  for specific fuel  combustion
 sources  show a potential  for a regulation revision?         N/A    N/A

   •  Must emission  limiting regulations be revised to
 accommodate significant fuel  switching?                     Yes     Yes

   t  Based on the above indicators,  what is the poten-
 tial for revising fuel  combustion source emission  limiting
 regulations?                                                Poor   Marg.

  •  Is there a significant Clean Fuels Saving  potential
in the region?                                                  Yes

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                        ATLANTIC OCEAN
                    CARIBBEAN SEA
                    U. S. VIRGIN ISLANDS
                                                      miles
Figure  2-1   AIR QUALITY CONTROL REGION  IN  U.S. VIRGIN  ISLANDS

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2.2  CURRENT AIR QUALITY STATUS OF U.S.  VIRGIN  ISLANDS
2.2.1  Definition of Air Quality Control  Regions
       The entire U.S.  Virgin Islands  comprise  one  Air  Quality  Control
Region (No. 247).  As illustrated in  Figure  2-1,  it includes  the  islands
of St. Thomas, St. John, St.  Croix, and  the  islands  surrounding each.  Other
information pertaining to the AQCR is  presented in  the  Appendix.   The  pri-
ority classification for TSP, S02 and  NOX are given  in  Table  A-l.   These
data are discussed in more detail in  Section 3.0.

2.2.2  Air Quality Standards
       The Federal ambient air quality standards  and the  U.S. Virgin  Islands
standards are identical  for TSP, S02,  and NOX as  given  in Table A-2.

2.2.3  Air Quality Monitoring
       1973 air quality  data, the most currently  available  for  the U.S. Virgin
Islands for TSP and S02  are given in  Tables  A-3 and  A-4,  respectively.  In
brief these data indicate the following:
       •  As of 1973, the U.S.  Virgin  Islands had three monitoring stations
          reporting for  particulates,  one violation  of  the  secondary  air
          quality standards,  a Priority  1A classification for parti culates
          and required approximately  a 42 percent reduction in  particulate
          emissions to attain the secondary  standard.
       •  As of 1973, the U.S.  Virgin  Islands had two 24-hr Bubbler monitor-
          ing stations  and no continuous  monitoring  stations  for  S02-   No
          violations were reported; however, the  AQCR has a Priority  1A
          classification for  S02.
       •  The air quality monitoring  network for  both TSP and $02 is  inade-
          quate according to  population  and  AQCR  Priority classification
          criteria.

2.2.4  Emissions of Sulfur Dioxide and Particulates
       The contribution  of fuel  combustion sources  in the U.S.  Virgin  Islands
to the total emissions  in the AQCR are summarized in Table  A-5  for both par-
ticulates and sulfur dioxide.  Tables  A-6 and A-7 provide a categorization
in terms of combustion source type, for  example,  electricity  generation,  in-
dustrial-commercial-institutional, and area  sources.  The tables  tend  to  indica-

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       •  Fuel  combustion sources account for approximately 69 percent of
          the AQCR S02 emissions and 13 percent of the particulate emissions.
       •  Fuel  combustion sources other than electricity generation contri-
          bute approximately 11 percent of the total  AQCR particulate emis-
          sions.
       •  Industrial sources are the major source of S02 emissions contri-
          buting approximately 55 percent of the total AQCR S02 emissions.

2.2.5  Particulate and S0£ Regulations
       Virgin Islands regulations for control of particulates and S02 from
fuel-burning sources are based on a particulate emission limitation and fuel
sulfur content regulations summarized in Table A-8.   The regulations are dis-
cussed in more detail in Section 2.3.

2.2.6  Control Strategy Assessments
       Tables A-9 and A-10, the control strategy assessments for particulates
and S02» respectively, were developed primarily as inputs to the assessments
of Appendix B, which are discussed in Section 3.0.  Basically, the tables
represent attempts to examine the following:
       (1) Are the allowable emissions projections made in the original
           SIP in reasonable agreement with such estimates based on more
           recent data?
       (2) Does a tolerance for an emission increase exist within the AQCR?
Table A-9 indicates that there is no tolerance for an increase in particu-
late emissions using current data and Table A-10 indicates the same status
for S02-  The detailed assessment of an AQCR's potential for revising com-
bustion regulations which considers many other factors are presented in
Section 3.0.

2.3  GENERAL REVIEW OF THE CURRENT IMPLEMENTATION PLAN
     There are three possible reasons for the existence of overly restrictive
emission limitations in a control strategy.
     •  "the example region" - as noted in the executive summary, the regu-
        lations for one AQCR can be utilized for another AQCR, where a less
        restrictive strategy would be adequate.

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      0   "conservative ambient standards" - ambient standards which are low
         than  the NAAQS can be promulgated.
      t   "hot  spots" - an inordinately high pollutant level in part of an
         AQCR  can be used as the basis for a regionwide emission rollbacK
         via the proportional approach.

 The  U.S.  Virgin Islands Implementation Plan utilizes neither the example
 region  approach, since there is only one AQCR, nor conservative ambient
 standards, since they have adopted the national standards.

 2.3.1   Background To The Development Of The Particulate And Sulfur Dioxide
        Control Strategies
        The Virgin Islands SIP contains control strategies and regulations
 which are adequate to attain the national standards for particulate matter
 and  S02  on all three islands.   The Islands'  review procedure for new sources
 and  modifications was deficient and the EPA,  on October 28, 1972, promulgated
 a regulation  to correct this deficiency.

       The Islands'  regulations  for the control of particulate matter include
 opacity  limitations  (Ringelmann  No.  2), fuel  burning limitations (0.6 Ibs/
 10^ BTU for small  sources  to 0.09 lbs/10^ BTU for large sources), incinerator
 restrictions   (0.2  gr/scf),  industrial  process limitations (~99+% control),
 and fugitive  dust restrictions.

       Emissions  of  S02  are controlled through controlling the emissions of
hydrogen sulfide  (0.03 ppm  by  volume)  and through sulfur in fuel limitations
 (0.5% as of April  1,  1974).
                                    10

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               3.0  AIR QUALITY CONTROL REGION ASSESSMENTS

     The purpose of this section is to evaluate the available information
for the U.S. Virgin Islands and determine the feasibility of revisions to
the SIP which would result in clean fuel conservation.  The assessment will
be made for the AQCR by 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 six criteria:  (1) 1973 air quality violations; (2) expected NAAQS
attainment dates; (3) proposed Air Quality Maintenance Area (AQMA) designa-
tions;  (4) total emissions; (5) regional tolerance for emissions increase;
and (6) pollutant priority classifications.  Tables B-l and B-2 tabulate
these criteria for each AQCR for TSP and S02, respectively.

     The Virgin Islands are rated as either a good, marginal, or poor candi-
date for regulation relaxation based on the evaluation of all the presented
information.  Using available data, an AQCR which displays a 1973 air quality
violation would probably be given a poor ranking.  Conversely, a region with
no violations, no proposed AQMA designations, low to moderate emissions and
a positive emission tolerance would receive a good ranking.  If there are
varying indicators or incomplete or missing data, the region would most
likely  receive a marginal ranking.

3.1  FUEL COMBUSTION SOURCE EVALUATION
3.1.1   Power Plant Evaluation
        The evaluation of power plants was based upon an estimate of the emis-
sion reductions resulting from the compliance of these power plants with the
existing Virgin Islands emission regulations for fuel combustion.  Since no
modeling data was available, the analysis was necessarily restricted to this
one method.   Table C-l contains power plant capacity and fuel use for the
two plants located within the Virgin Islands.

3.1.2  Significant Industrial  Point Source Evaluation
       The evaluation of significant industrial point sources was similar
to that carried out for power plants.   Since no modeling data were available
                                   n

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 for both  TSP  and  S02,  the  analysis was restricted to an estimate of the emis-
 sion reductions resulting  from  the compliance of these sources with the existing
 Virgin Islands emission  regulations for fuel combustion.  A summary of these
 results are shown in Table D-l.

 3.1.3  Area Source Evaluation
        Area source emissions data were available for the AQCR from the National
 Emissions  Data System  (NEDS) summary report.  In addition, the Office of Air
 Quality Planning  and Standards  has county summaries.  Table E-l indicates the
 types of  fuel burned by  fuel combustion area sources, the sulfur content and
 emissions.

 3.1.4  Fuel Analysis
        Table  F-1  indicates the  distribution of fuel  use among sources in the
 Virgin Islands.

 3.2   VIRGIN ISLANDS AIR QUALITY CONTROL REGION
 3.2.1   Regional Assessment (Appendix B)
        The regional evaluation of the AQCR indicates that little potential
 exists  for increasing particulate emissions, however, further study is needed
 before  consideration should be given to relaxing S02 emission limits.   The
 indicators may be summarized as follows:
       •  Particulates  - air quality violation,  1A priority classification
          and a zero tolerance for emission increase.
       •  Sulfur Dioxide - no reported air quality violations, 1A priority
          classification and a negative tolerance for emission increase.

However, the 1A classifications  which reflect emissions from a single point
source within  an  AQCR should be noted, especially for TSP for which there
are little air quality  data.   Analysis of other factors to be considered  in
assessing a region's candidacy for emission regulations revision are  carried
out in the following sections.
                                    12

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3.2.2  Power Plant Assessments (Appendix C)
       As indicated in Table C-1, there are only two power plants  in  the
Virgin Islands AQCR with a total  capacity of 88.5 MW plus four gas turbines
as of July 1974.  Between June, 1973 and June, 1974 residual  oil  total  fuel
consumption was 37.8 million gallons.  Distillate fuel  oil consumption  for
the same period was 5.04 million gallons.

       As of 1973, power plants accounted for 2 percent and 10 percent  of
the total AQCR particulate and sulfur dioxide emissions,  respectively.  No
modeling results were available for power plants, and therefore no statement
can be made concerning the maximum sulfur content which would be  acceptable
without exceeding the standards.

3.2.3  Other Major Combustion Source Assessment (Appendix D)
       There are two significant particulate sources, and one S02  source in
this category.  They contribute 11 percent of the particulate emissions, and
55 percent of the S02 emissions.   As shown in Table D-l,  existing  regulations
would allow for some increase in particulate emissions, but a very large de-
crease in S02 emissions.  Again, as in power plants, no modeling  results are
available for sources of this type, and therefore no statement can be made
concerning the maximum sulfur content which would be acceptable without
exceeding the standards.

3.2.4  Area Source Assessment (Appendix E)
       Area fuel combustion sources contribute less than one percent  of the
total AQCR emissions of both particulate and S02-  As indicated in Table E-l,
distillate oil is the only fuel used by area fuel combustion sources.  The
sulfur content of the distillate oil burned by these sources is 0.5 percent.
The existing regulations permits only the use of fuels  with a 0.5 percent
sulfur content, thus any increase in emissions resulting from growth  in the
AQCR would be insignificant.
                                     13

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 3.2.5   Fuel  Assessment  (Appendix F)
        The purpose of this section is to examine the potential for clean
 fuel savings based on the analyses in sections 3.2.1 through 3.2.4 and actual
 fuel consumption in the AQCR.  Table F-l summarizes fuel use in the AQCR.
 It  indicates that residual and distillate oil, natural gas and bagasse are
 the major fuels burned on the island.  The conversion of oil-burning plants
 to  coal might well be ruled out on the basis of the TSP levels in the Virgin
 Islands and  the fact that no coal is burned on the island anyway.  This is
 also true of bagasse, a solid residue remaining after sugar cane has been
 crushed, which is burned by a few point sources.  Conversion to bagasse would
 probably be  ruled out also because of the TSP levels and the heating efficiency
 of bagasse which is considerably less than oil.

        In the Virgin Islands, the potential  for clean fuel savings is the
 saving of low sulfur oil.   The absence of modeling results tends to make the
 evaluation process meaningless in terms of what limits should be placed on
 sulfur in fuels that would not cause emissions to exceed the NAAQS. However,
 any revision to the  existing Virgin Islands  sulfur in fuel regulations will
 cause som,e increase  in  S02 emissions which must be monitored to insure attain-
ment and maintenance of NAAQS.
                                    14

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                       4.0  REFERENCES
1.  "1972 National Emissions Report," Report No. EPA - 450/2-74-012,
    U.S. Environmental Protection Agency, June 1974.

2.  "Steam - Electric Plant Factors/1972," 23rd edition, National
    Coal Association, 1973.

3.  Electrical Worlo^ Directory of Electric Utilities, 81st edition,
    McGraw Hill, Inc., New York, N. Y., 1972.

4.  "Compilation of Air Pollutant Emission Factors,: Publication
    No. AP-42, U. S. Environmental Protection Agency, July 1974.

5.  "Federal Air Quality Control Regions," Publication No. AP-102,
    U. S. Environmental Protection Agency, January 1972.

6.  SAROAD (Storage and Retrieval of Aerometric Data) computer
    printouts for 1973.

7.  "Stationary Source Fuel Summary Report," National Emissions Data
    System, Environmental Protection Agency, 23 September 1974.

8.  "Air Quality Data - 1972 Annual Statistics," Publication No.
    EPA - 450, U. S. Environmental Protection Agency, March 1974.
                                  15

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            APPENDIX  A



STATE IMPLEMENTATION PLAN BACKGROUND

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                                          TABLE  A-l   U.S.  VIRGIN  ISLANDS AIR POLLUTION CONTROL AREA
                                          Priority
Air Quality
Control Region
S. Virgin Islands
Federal
Number
247
Parti -
culates
IA
SOX NOX
IA III
1970
(thousand)
63
Square
Miles
132
Density
(Pop./sq.mi . )
447
AQMA Designations
TSP Counties
Not
SO*.
R e q u
Counties
i r e d
Priority

Sulfur oxide:
Annual arithmetic mean
24-hour maximum
Parti cu,l ate matter
Annual geometric mean
24-hour maximum
I
Greater than

100
455

95
325
II
F'rom - To

60-100
260-455

60-95
150-325
III
Less than

60
260

60
150
Criteria based on measured or estimated air quality levels  reflecting  emissions  predominately from a single point source.

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                                    TABLE A-2  U.S.  VIRGIN ISLANDS AMBIENT AIR QUALITY  STANDARDS
                                                          All  concentrations  in ygm/m
                                        Total Suspended Participate      	Sulfur  Oxides	      Nitrogen  Dioxide
Federal
(Nov. 1972)
U.S. Virgin Islands
Primary
Secondary

Annual
75(G)
60(G)
60(G)
24- Hour
260a
150a
150a
Annual
80(A)
80(A)
24-Hour
365a
365a
3-Hour
1300a
1300a
Annual
100(A)
100(A)
100(A)
aNot to be exceeded more than once per year.
(A)  Arithmetic Mean
(G)  Geometric Mean

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                                              TABLE  A-3   U.S.  VIRGIN  ISLANDS AQCR AIR QUALITY STATUS (1973), TSPa
                                      (ug/m3)
                                 TSP Concentration
AQCR #
2nd
# Highest
Stations Highest Reading Reading
Reporting Annual 24-Hr 24-Hr Background
247 2d NA 316 240 24
a!973 air quality data in National Air Data Bank as of June 7, 1974.
Violations based on 2nd highest reading at any station
cFormula:
(2nd Highest 24-hr - 24-hr Secondary Standard) x 100
or:
2nd Highest 24-hr - Background
(Annual - Annual Secondary Standard) x 100
# Stations Violating Federal Reduction
Ambient Air Quality Standards Required
Primary Secondary to Meet
Annual 24-Hrb Annual % 24-Hrb % Standards1-
NA 0 NA 0 1 50 +42
Standard
on Which
Reduction
Is Based
24-hour
                    Annual  - Background

      whichever is most stringent.

dMonitorinq stations at Charlotte Amalie

NA - Not available

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                                    TABLE  A-4   U.S.  VIRGIN  ISLANDS AQCR AIR QUALITY STATUS (1973), S02a
                                                S02  Concentration
                                                     (ug/m3)


AQCR #
247
#
Stations
Reporting
24-Hr
(Bubbler)
3d
#
Stations
Reporting
(Contin. )
0


Highest
Annual
10


Reading
2T^Rr
73
2nd
Highest
Reading
24-Hr
62
# Stations Violating
Ambient Air Quality Stds.
Primary
Annual
0

24-Hru
0
Secondary
3-Hr
0
%
Reduction
Required
To Meet
Standards0
-100
Standard
on Which %
Reduction
Is Based
Annual
 1973 air quality data in National  Air Data Bank  as  of July  29,  1974

 Violations based on 2nd highest reading at any station.

cFormula:

           (2nd Highest 24-hr - 24-hr Standard) x 100
                      2nd highest 24-hr

     or:    (Annual - Annual  Standard) x 100
                     Annual

     whichever is most stringent.

 Monitoring stations at Charotte Amalie, Christiansted and St.  Croix  County

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                  TABLE A-5  U.S. VIRGIN ISLANDS FUEL COMBUSTION SOURCE SUMMARY


                          Other Fuel Combustion      Total Emissions          % Emissions From
              Power           Point Sourcesa         (103 tons/year)b      Fuel Combustion Sources
AQCR No.      Plants          TS£       SQ_2           TSP_      Sp_2              TSP      S02

  247           2              21            7.6      11.0              9       69


a - All significant point sources, when combined with power plants, contribute at least 90% of
    the total emissions from fuel combustion point sources

b - AQCR total, 1972 National Emissions Report

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                    TABLE A-6  U.S. VIRGIN ISLANDS EMISSIONS SUMMARY-PARTICULATES
                                                       Industrial, Commercial,
                                                      Institutional Combustion        Area Source
AQCR
2^7
nuori j u LCU
(tons/yr.)
7,631
(tons/yr.)
120
%a
2
(tons/yr. )
945
o/a
7o
11
(tons/yr. )
1
%a

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                TABLE A-7  U.S. VIRGIN ISLANDS EMISSIONS SUMMARY-SULFUR DIOXIDE
          AQCR Total
                                                       Industrial,  Commercial,
                                                      Institutional  Combustion         Area  Source
                          Electricity Generation            Point Sources            Fuel  Combustion
AQCR      (tons/yr.)         (tons/yr.)    %a            (tons/yr.)     %a          (tons/yr.)     %a

247         11,004             1,153       10              6,045       55              4          <1
aPercentaae of total emissions

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               TABLE A-8

U.S.  VIRGIN ISLANDS PARTICIPATE EMISSION
     REGULATION FOR FUEL COMBUSTION
Heat Inputa'b
<10
100
1,000
^10,000
Maximum Allowable0
0.60
0.352
0.207
0.090A
 a - Heat input is the aggregate heat content
     of all  fuels whose product of combustion
     pass through a single stack or stacks.
 b - 106 BTU/hour

 c - lbs/106 BTU of heat input

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                                 TABLE A-9   CONTROL STRATEGY ASSESSMENT -  PARTICULATES
            State Implementation Plan Requirements
Requirements  Based on 1973 Data
AQCR
247
Baseline
Air Quality
(yg/m3)
99C
Baseline
Emissions
(Tons/Yr.)
8,856
Allowable
Emissions
(Tons/Yr.)
2,174
Predicted
1975 Emissions
(Tons/Yr.)
2,174
1973
Air Quality
(yq/m3)
d
NEDS
Emissions3
(Tons/Yr.)
7,631
Allowable
Emissions
(Tons/Yr.)
...d
Tolerance for
Emission Increaseb
(Tons/Yr.)
0
a - From NEDS Summary Document June 1974.
b - Difference between 1973 based allowable and predicted 1975 emissions
c - Annual average
d - Annual averaqe for 1973 not available.

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                                      TABLE A-10  CONTROL STRATEGY ASSESSMENT - S02
            State Implementation Plan Requirements
Requirements Based on 1973 Data
AQCR
247
Baseline
Air Quality
(yg/m3)
106C
Baseline
Emissions
(Tons/Yr.)
19,505
Allowable
Emissions
(Tons/Yr.)
3,509
Predicted
1975 Emissions
(Tons/Yr.)
3,509
1973
Air Quality
(yg/m3)
10
NEDS
Emissions3
(Tons/Yr.)
11,004
Allowable
Emissions
(Tons/Yr.)
___d
Tolerance for
Emission Increase
(Tons/Yr.)
-7,495
a - From NEDS Summary Document June 1974.
b - 1973 and SIP data do not compare reasonably.  Tolerance for Emission Increase was  calculated  as  the  difference  bet.
    SIP Allowable Emissions - 1973 NEDS Emission = -7,495 tons which represents  a reduction  of 7,495 tons.
c - Baseline Air Quality of 106 yg/m3 on which the SIP for S02 is based was  converted  from 0.4ppm.
d - The low monitored 1973 Air Quality does not indicate an emission reduction due to  a  possible  malfunction  in  the
    monitoring equipment, therefore allowable emissions for 1973 were not calculated.

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         APPENDIX  B



REGIONAL AIR QUALITY SUMMARY

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B-l   REGIONAL INDICATORS - PARTICIPATES
AQCR
247
No. of
Monitors
2
Sites with
A.Q. Violations
1
Priority
Classification
IA
cA^iei-Leu
Attainment Date
for Stds.
1/75
Kroposea
AQMA
Designations
None
Total
(1Q3 Ton/Yr)
7.6
% From
Fuel Combustion
14
                                                                                Tolerance for
                                                                              Emission Increase
                                                                                 (1Q3 Ton/Yr)

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                                                                   B-2  REGIONAL INDICATORS - S02



          	Al> Qua1ity	                            Expected            Proposed        	Emissions	        Tolerance  for
           No.  of        Sites with           Priority         Attainment Date          AQMA              Total           % from           Emission  Increase
AQCR      Monitors    A.Q.  Violations       Classification         for Stds.         Designations      (IP3 Ton/Yr)    Fuel Combustion          (1Q3 Ton/Yr)

247          1                0                   IA                  1/75                None              11.0               65                   -7.5

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     APPENDIX  C



POWER PLANT SUMMARY

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               TABLE C-1  POWER PLANT ASSESSMENT FOR U.S. VIRGIN ISLANDS
AQCR

247
               Plant
        V.I.  Water & Power
        Authority
        (St.  Thomas)

        V.I.  Water & Power
        Authority
        (St.  Croix)
Capacity      	Fue1  Use   ,	
  (Mw)        Type    Quantity (103/Gals.)
  60.5
  28.0
Oil
                                                              23,580
Oil           19,260

       Total   42,840a
                                  Fuel Sulfur
                                  Regulation
0.5%
                                                                                     0.5%
Includes total of residual oil and distillate oil used between June,  1973 and June,  1974.
Residual oil consumption totaled 37.8 million gallons, distillate oil  totaled 5.04 million
gallons.  Fuel consumption by plant was estimated based on ratio of firing rates;  St.  Thomas-
4278 gals/hr, St. Croix - 3385 gals/hr.

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                    APPENDIX  D



INDUSTRIAL/COMMERCIAL/INSTITUTIONAL SOURCE  SUMMARY

-------
                              TABLE D-l  U.S. VIRGIN ISLANDS SIGNIFICANT SOURCES'
     AQCR Name
U.S. Virgin Islands
    NEDS
TSP Emissions
   (T/Yr)

    909b
    NEDS
SO? Emissions
   (T/Yr)

    5880C
     Reductions Under
Existing Regulations(T/Yr)
       TSP      SO?
      -405
+1594
    % NEDS TSP
Emissions From Coal

         0
a - See Table A-5
b - Harvey Alumina V.I. Inc. and Hess Oil V.I. Corp. on St. Croix
c - Harvey Alumina V.I. Inc., St. Croix only

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    APPENDIX  E



AREA SOURCE SUMMARY

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                   TABLE E-1  U.S. VIRGIN ISLANDS FUEL COMBUSTION AREA SOURCES'
                                                Fuel Burned
Emissions (tons/yr)
n^ur\
AQCR Name No.
Virgin Islands 247




Type
Oil:
Distillate
Residual
Gas:
Natural
Amount^

90
0

0
% S

0.5
2.0

—
% S Regulation

0.5
0.5


Parti cul ate

1
0


SO?

4
0


a - NEDS data
b - Coal in tons/yr; oil in 1000 gals.; gas in MCF; wood in tons.

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   APPENDIX  F



FUEL USE SUMMARY

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                                                     TABLE F-l
                                        STATIONARY SOURCE FUEL USE SUMMARY
                                                U.S. VIRGIN ISLANDS
                  Residual  Oil (1Q3 Gals.)    Distillate Oil (TO3 Gals.)    Natural Gas (1Q3 cu.ft.)    Bagasse (tons)
Area Sources
  Residential
  Industrial
  Comm/Inst.
       Total
Point Sources
  External  Comb.
    Elec.  Gen.
    Industrial
    Comm/Inst.
         Total
  Internal  Comb.
    Elec.  Gen.
    Industrial
    Comm/Inst.
         Total
    GRAND TOTAL
29210
36400

65610
                              100

                              100
65610
 1358
  284
 1642
 6400
26938

33338
35080
5203

5203


  22

  22
5225
18572
18572

-------