EPA-4 50/3-75-003
FEBRUARY 1975
IMPLEMENTATION PLAN REVIEW
FOR
MICHIGAN
AS REQUIRED
BY
THE ENERGY SUPPLY
AND
ENVIRONMENTAL COORDINATION ACT
U. S. ENVIRONMENTAL PROTECTION AGENCY
-------
EPA-450/3-75-003
IMPLEMENTATION PLAN REVIEW
FOR
MICHIGAN
REQUIRED BY THE ENERGY SUPPLY AND ENVIRONMENTAL COORDINATION ACT
PREPARED BY THE FOLLOWING TASK FORCE:
U.S. Environmental Protection Agency, Region V
230 S. Dearborn
Chicago, Illinois 60604
Energy and Environmental Systems Division
Argonne National Laboratory
Argonne, Illinois 60439
(EPA-IAG-D5-0463)
U.S. Environmental Protection Agency
Office of Air and Waste Management
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
February 1975
-------
MICHIGAN
ENERGY SUPPLY AND ENVIRONMENTAL COORDINATION ACT
SECTION IV STATE IMPLEMENTATION PLAN REVIEW
Table of Contents
1.0 EXECUTIVE SUMMARY 5
2.0 MICHIGAN STATE IMPLEMENTATION PLAN 11
2.1 Summary 11
2.2 Air Quality Setting for the State of Michigan 12
2.3 Background on the Development of the Current
State Implementation Plan 17
2.4 Special Considerations for the State of Michigan 18
3.0 AIR QUALITY CONTROL REGION ASSESSMENTS 20
3.1 General Methodology 20
3.2 South Bend-Elkhart-Benton Harbor Interstate AQCR (#82) . . 22
3.3 Central Michigan Intrastate AQCR (#122) 22
3.4 Metropolitan Detroit-Port Huron Intrastate AQCR (#123) . . 23
3.5 Metropolitan Toledo Interstate AQCR (#124) 24
3.6 South Central Michigan Intrastate AQCR (#125) 24
3.7 Upper Michigan Intrastate AQCR (#126) 25
TECHNICAL APPENDICES
APPENDIX A - State Implementation Plan Background
APPENDIX B - Regional Air Quality Assessment
APPENDIX C Power Plant Assessment
APPENDIX D Industrial, Commercial, Institutional Point
Source Assessment
APPENDIX E Area Source Assessment
APPENDIX F Fuels Assessment
REFERENCES
-------
-------
STATE IMPLEMENTATION PLAN REVIEW
FOR
THE STATE OF MICHIGAN
1.0 EXECUTIVE SUMMARY
The enclosed report is the U.S. Environmental Protection Agency's (EPA's)
response to Section IV of the Energy Supply and Environmental Coordination
Act of 1974 (ESECA). Section IV requires EPA to review each State Implementa-
tion Plan (SIP) to determine if revisions can be made to control regulations
for stationary fuel combustion sources without interfering with the attain-
ment 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 disap-
prove any revised regulations relating to fuel burning stationary sources
within three months after they are submitted to EPA by the states. The
states may, as in the Clean Air Act of 1970, initiate State Implementation
Plan revisions; ESECA does not, however, require states to change any existing
plan.
Congress has intended that this report provide the state with information
on excessively restrictive control regulations. The intent of ESECA is that
SIPs, wherever possible, be revised in the interest of 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 regard to saving low sulfur fuels and, where the primary sulfur dioxide
air quality standards were not exceeded, to encourage states to either defer
compliance with regulations or to revise the SO2 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 NMQS.
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 statewide
air quality control strategies; 2) the existence of State Air Quality Standards
which are more stringent than NAAQS; and 3) the "hot spots" in only part of
an Air Quality Control Region (AQCR) which have been used as the basis for
controlling the entire region. Since each of these situations affects
many state plans and in some instances conflicts with current national energy
concerns, a review of the State Implementation Plans is a logical follow-up
to EPA's initial appraisal of the SIPs conducted in 1972. At that time SIPs
were approved by EPA if they demonstrated the attainment of NAAQS or more
stringent state air quality standards. Also, at that time an acceptable
method for formulating control strategies was the use of an example region
for demonstrating the attainment of the standards.
The example region concept permitted a state to identify the most
polluted air quality control region (AQCR) and adopt control regulations
which would be adequate to attain the NAAQS in that region. In using an
example region, it was assumed that NAAQS would be attained in the other
AQCRs of the state if the control regulations were applied to similar sources.
The problem with the use of an example region is that it can result in
excessive controls, especially in the utilization of clean fuels, for areas
of the state where sources would not otherwise contribute to NAAQS violations.
For example, a control strategy based on a particular region or source can
result in a regulation requiring 1 percent sulfur oil to be burned statewide
where the use of 3 percent sulfur coal would be adequate to attain NAAQS
in some locations.
-------
EPA anticipates that a number of states will use the review findings
to assist them in deciding whether or not to revise portions of their State
Implementation Plans. However, it is most important for those states which
desire to submit a revised plan to recognize the review's limitations. The
findings of this report are by no means conclusive and are neither intended
nor adequate to be the sole basis for SIP revisions; they do, however,
represent EPA's best judgment and effort in complying with the ESECA require-
ments. The time and resources which EPA has had to prepare the reports has
not permitted the consideration of growth, economics, and control strategy
tradeoffs. Also, there has been only limited dispersion modeling data
available by which to address individual point source emissions. Where the
modeling data for specific sources were found, however, they were used in
the analysis.
The data upon which the report's findings are based is the most
currently available to the federal government. However, EPA believes that
the states possess the best information for developing revised plans. The
states have the most up-to-date air quality and emissions data, a better
feel for growth, and the fullest understanding for the complex problems
facing them in the attainment and maintenance of quality air. Therefore,
those states desiring to revise a plan are encouraged to verify and, in
many instances, expand the modeling and monitoring data supporting EPA's
findings. In developing a suitable plan, it is suggested that states select
control strategies which place emissions for fuel combustion sources
into perspective with all sources of emissions such as smelters or other
industrial processes. States are encouraged to consider the overall impact
which the potential relaxation of overly restrictive emissions regulations
for 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 particulate
matter (TSP) and sulfur dioxide (802) emissions. This is because stationary
fuel combustion sources constitute the greatest source of 862 emissions and
are a major source of TSP emissions.
-------
Part of each state's review was organized to provide an analysis of
the S02 and TSP emission tolerances within each of the various AQCRs. The
regional emission tolerance estimate is, in many cases, EPA's only measure
of the "over-cleaning" accomplished by a SIP. The tolerance assessments
have been combined 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 also been carried out.
The following are the principal findings for the state of Michigan.
(Air Quality Control Regions are displayed on Fig. 1-1.)
• The federal National Ambient Air Quality Standards for total sus-
pended particulates and sulfur oxides apply in Michigan.
• Michigan's statewide emission regulations for particulate matter
and sulfur dioxide were based on a modified example region approach.
Rollback on the "hot spots" was used in parts of all six Michigan
AQCRs.
• Within the framework of this review, there are indications of little
tolerance for increased particulate emissions throughout the state
due to either high TSP levels (based on 1973 data) or TSP levels
which are just meeting the standards. There appears to be a sufficient
number of particulate air quality monitoring sites to support this
conclusion. Modeling data for particulates is lacking.
• The final sulfur regulations for the state of Michigan to be met by
mid-1978 are more restrictive than those which are to be met by mid-
1975. The more restrictive 1978 limits were designed to insure
compliance with annual and 24-hour secondary NAAQS which were
rescinded by EPA and which were more restrictive than the present
NAAQS. The less restrictive 1975 limits were designed to meet
present S02 NAAQS.
• Under the State Implementation Plan, the Michigan Air Pollution
Control Commission has the authority to delay compliance with
sulfur dioxide emission regulations until January 1, 1980 and beyond
for specific fuel combustion sources provided that such sources are
not subject to federal New Source Performance Standards and can
demonstrate that they do not create or contribute to a violation
of National Ambient Air Quality Standards. This provision has
been used to allow the use of high sulfur coals by various fuel
combustion sources and the potential clean fuels savings from
sources to which the delayed compliance provision does not apply
is small.
-------
(#126)
UPPER MICHIGAN
INTRASTATE
(NORTHERN
PENINNSULA)
(#122)
CENTRAL
MICHIGA
INTRASTATE
(#123)
METROPOLITAN
DETROIT-
PORT HURON
INTRASTATE
(#82)
SOUTH BEND
ELKHART-
BENTON HARBOR
INTERSTATE
(INDIANA-
MICHIGAN)
X
SOUTH CENTRAL
MICHIGAN
INTRASTATE
(#125)
METROPOLITAN
TOLEDO
INTERSTATE
(OHIO-
MICHIGAN)
(#124)
Figure 1-1. Michigan Air Quality Control Regions (AQCR)
-------
10
Under the delayed compliance provision and EPA's Clean Fuels Policy,
Michigan has recently submitted revisions of its State Implementation
Plan requesting compliance extensions until 1980 for six large
coal-fired power plants. EPA has approved revisions for three of
these plants. The state and EPA Region V are currently evaluating
the revisions for the other three plants.
Given the extensive use that the State of Michigan has made of the
delayed compliance provision, there is little reason for the state
to consider regulation relaxation between now and January 1, 1980,
since a mechanism already exists to allow the use of higher sulfur
fuels.
The majority of power plants and industrial/conunercial/institu-
tional sources in Michigan burn coal. The major impact of compliance
extensions has been to conserve lower sulfur coals.
-------
11
2.0 MICHIGAN 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 emission regulations for fuel savings; i.e., under
the Clean Fuels Policy?
• Are there np_ proposed Air Quality Maintenance Areas?
• Are there indications of a sufficient number of monitoring
sites within a region?
• Is there an expected 1975 attainment date for NAAQS?
• Based on (1973) air quality data, are there np_ reported violations
of NAAQS?
• Based on (1973) air quality data, are there indications of a
tolerance for increasing emissions?
• Are the total emissions from stationary fuel combustion sources
a relatively small portion of the regional total?
• 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,
is organized to provide the background and current situation information
-------
12
for the State Implementation Plan; Section 3, and the remaining Appendices
provide an analysis by AQCR which helps establish the overall potential for
revising regulations. An evaluation of regional air quality indicators is
presented in Appendix B; power plants, industrial sources, and area sources
are analyzed in Appendices C, D, and E, respectively.
Based on an overall evaluation of EPA's current information, AQCRs
have been classified as good, marginal, or poor candidates for regulation
revisions. Table 2-1 summarizes the State Implementation Plan Review.
The remaining portions of the report support this summary with explanations.
2.2 Air Quality Setting for the State of Michigan
2.2.1 Michigan Air Pollution Control Areas
The state of Michigan is divided into six Air Quality Control Regions
(AQCRs) as shown in Fig. 1-1. There are four intrastate and two interstate
regions. There is only one county in the Michigan portion of the Metropolitan
Toledo AQCR (#124). Table A-l lists the pollutant priority classifications
for each of these six regions.
The table also shows the population density to be largest in the
Metropolitan Detroit-Port Huron AQCR (#123) and the Metropolitan Toledo AQCR
(#124) with the former having a substantially greater population density.
Based on present conditions and growth projections, three counties in the
Metropolitan Detroit-Port Huron AQCR (#123) have been proposed as Air
Quality Maintenance Areas (AQMAs) for particulates. These counties are
indicated in Table A-l and Fig. A-l. Public hearings are to be held late
in January, 1975 concerning the possible designation of other ACMAs in
Michigan.
2.2.2 Michigan Ambient Air Quality Standards
As shown in Table A-2, all the federal primary and secondary National
Ambient Air Quality Standards (NAAQS) for total suspended particulates,
sulfur oxides and nitrogen dioxide apply in Michigan. The following analysis
addresses the attainment of these standards.
-------
Table 2-1. State Implementation Plan Review for Michigan
South Bend-Elkhart-
State
Metropolitan Detroit- Metropolitan
Benton Harbora Central Michigan Port Huron Toledo
AQCR #82 AQCR #122 AQCR #123 AQCR *124
"INIHCA'IOK.1;11
• Docs the Stale have air quaj i iy standards which arc more
stringent than NAAOS?
• Docs the State have emission limiting regulations for
control of:
1. Power plants
2. Industrial sources
3. Area sources
• Did the State use an example region approach for demon-
strating the attainment of NAAQS or more stringent State
standards?
• ii:is the State not initiated action to modify combustion
source emission regulations for fuel savings; i.e.,
under the Clean Fuels Policy?
» Are there no proposed Air Quality Maintenance Areas?
• Arc there indications of a sufficient number of monitor-
ing sites within a region?
• Is there an expected 1975 attairancnt date for NAAQS?
« Based on (1973) Air Quality Data, are there no reported
violations of NAAQS?
• based en (1973) Air finality Data, -sro there indications
of a significant tolrrance ("or increasing emissions?
i Are the emissions from stationary fuel combustion sources
a relatively small portion of the regional total?
• Do modeling results for specific fuel combustion sources
show a potential for a regulation revision?
« Is there a significant Clo-in Fuels Saving potential in
the region?
• Must the regulations be revised to accomplish signifi-
cant fuel switching?
o Eased on the above indicators, what is the potential for
revising fuel combustion source emission limiting
regulations? h
TSI' SO,
No
Yes
Yes
Yes
Nod
Yes
Nob
Yes
Yes
Yes
Nod
No6
T:;I' so..
Yes
Yes
Yes
No
No
Yes
: NAf
Yes
Yes
Yes
Yes
Yes
Yes
NAf
j, No
f No
[ TSP - Peor
i: S07 - Poor
TSI' SO^
Yes
Yes
Yes
No
Kb
No
NA
Yes
Yes
Yes
No
No
No
No
No
No
TSP - Poor
S02 - Poor
TSI' .'•-,
No
Yes
Yes
No
No
No
NA
Yes
Yes
Yes
No
No
No
NA
.Mo
No
TSP - Poor
S02 - Poor
'i>;i' so,
Yes
Yes
Yes
No
No
Yes
N'A
Yes
Yes
Yes
Yes
Yes
Yes
Xo
Nc
No
TSP - Poor
S02 - Poor
-------
I able 2-1. State Implementation Plan Review for Michigan (Contd.)
South Central
Michigan.
AQCR £125
Upper I'tichigan
AQCR #126
"INDICATORS"
® Docs the State have air quality standards which arc more
scrir.gent than NAAQS?
* Docs the State have emission limiting regulations for
control of: i
1. Power plants
2. Industrial sources
3. Area sources
o Did the State use an example region approach for demon-
strating the attainment of NAAQS or more stringent State
standards?
o Has the State not initiated action to modify combustion
source emission regulations for fuel savings; i.e.,
under the Clean Fuels Policy?
c Arc there MO proposed Air Quality Maintenance Areas?
o Arc there indications of a L -.ff icicnt number of monitor-
ing sites within a region?
\ a Is there ur. expected .1975 attainment date for NAAQS?
* Rased on (Ii>7.->} Air Quality Data, arc there r_o reported
\i iolat ions of NAAQS?
o Based on (1973) Air Quality Data, aro there Iml.i cations
of a significant to l.o ranee for increasing emissions?
;> Arc the emissions from stationary fuel combustion sources
a relatively small portion of the regional total?
o Do modeling results for specific fuel combustion sources
show a potential for a regulation revision?
° Is there a significant Clean l-'uels Saving potential in
the region?
o .Viist the regulations be revised to accomplish signifi-
cant fuel su'j trh in
-------
Table 2-1. State Implementation Plan Review for Michigan (Contd.)
Footnotes
o
Interstate.
Michigan has air quality goals, not standards, more stringent than NAAQS, that apply in the
Michigan-Ontario Transboundary area of the Metropolitan Detroit-Port Huron AQCR #123.
Except for residential units outside Wayne County.
Rollback was used to demonstrate the sufficiency of the regulations in counties comprising
all or part of each AQCR.
The delayed compliance provision of Michigan's S0~ regulation has been used extensively to
allow the use of high sulfur coals on a source-by-source basis. Wayne County is presently
evaluating the need to implement the last step of its sulfur regulation.
No power plants.
^Attainment schedule indicates region is below standards; current data indicates violations.
1 Good - Air quality indicators show a tolerance to absorb increased emissions and source-
by-source evaluations show a significant clean fuels savings potential.
Poor - Air quality indicators show little or no tolerance for increased emissions and/or
source evaluations indicate little or no clean fuels savings potential.
Marginal - Air quality and clean fuels savings evaluations are inconclusive or conflicting.
More detailed analysis needed.
-------
16
2.2.3 Michigan Air Quality Status
The current air quality status in Michigan is summarized in Table
A-3 and Table A-4 for particulates and sulfur dioxide, respectively. All
data come from the SAROAD data bank as of June, 1974.
With the exception of South Central Michigan (#125), all AQCRs partly
or wholly in the state of Michigan show violations of the particulate standards
There are also indications of a sufficient number of monitoring sites in all
AQCRs. The severest particulate problems occur in Central Michigan (#122)
and Metropolitan Detroit-Port Huron (#123) for both of which there are
indications that large overall emissions reductions are required to meet
secondary particulate NAAQS. In Metropolitan Detroit-Port Huron (#123),
this assessment is consistent with the proposal of particulate AQMAs.
Although present air quality is acceptable, there are indications that South
Central Michigan (#125) has little capacity to absorb increased particulate
emissions. Thus, with the possible exception of South Central Michigan (#125)
there are regional indications that particulate emission regulation relaxation
is not possible.
High S02 levels are reported in Central Michigan (#122), Metropolitan
Detroit-Port Huron (#123), and South Central Michigan (#125). In each of
these regions, only one station is reporting the high levels but South
Central Michigan has only four stations. The S02 problem is most severe
in Central Michigan (#122) and the violation in Metropolitan Detroit-Port
Huron (#123) is only slightly above standard. There are indications based
on regional air quality in South Bend-Elkhart-Benton Harbor (#82), Metro-
politan Toledo (#124), and Upper Michigan (#126) that a substantial capacity
to absorb increased S02 emissions exists.
2.2.4 Michigan Emissions Summary
Emission sources and emission rates are tabulated in Tables A-5 to A-7-
In the six AQCR area, Michigan fuel combustion sources account for
about 551 of the particulate and about 81% of the S02 emissions. Michigan
fuel combustion sources contribute more than half the particulate emissions
in South Bend-Elkhart-Benton Harbor (#82), Central Michigan (#122) and
South Central Michigan (#125). Table A-6 shows that the major contributor
-------
17
to Michigan particulate emissions from fuel combustion among electricity
generation, industrial/commercial/institutional point sources, and area
sources varies from AQCR to AQCR. In South Central Michigan (#125), the
only region not showing particulate air quality violations, industrial/
commercial/institutional point sources and area sources emit significantly
more particulate than does electricity generation.
In all AQCRs except South Bend-Elkhart-Benton Harbor (#82) and
Metropolitan Toledo (#124), the S02 emissions from Michigan fuel combustion
sources constitute a relatively large fraction of the regional total
implying that any S02 emission regulation relaxation would have a significant
impact on air quality. Electricity generation emits a large amount of S02
in the other four regions as do industrial/commercial/institutional point
sources in all four except Metropolitan Detroit-Port Huron (#123).
2.3 Background on the Development of the Current State
Implementation Plan
2.3.1 General Information
Instead of using the example region approach, Michigan used rollback in
counties comprising all or part of all six AQCRs. The counties examined in
each region represented the areas with the highest measured or calculated
pollutant levels. Although this approach is not strictly the example region
approach it has the same result of possibly requiring restrictive regulations
in regions or parts of regions where less restrictive regulations might
suffice to attain and maintain NAAQS.
2.3.2 Particulate Control Strategy
The control strategy for fuel combustion sources consists of the
enforcement of the applicable sections of the General Rules of the Michigan
Department of Natural Resources Air Pollution Control Commission throughout
the state except in Wayne County and, in Wayne County, of the enforcement
of the applicable sections of the Air Pollution Control Regulation of the
Wayne Department of Health. These regulations are summarized in Table A-9
and Fig. A-2. For particulate matter, the regulations were designed to
meet both the priinary and secondary particulate NAAQS within ten percent,
-------
18
the accuracy associated with the proportional rollback model. The rollback
for the 24-hour particulate standards was based on the maximum valid 24-hour
value in each county treated.
2.3.3 Sulfur Dioxide Control Strategy
The regulations for S02 emissions are also summarized in Table A-9.
Michigan presented two control strategies. Control Strategy I set emission
limits to be met by mid-1975 and was designed to attain all the primary and
the 3-hour secondary S02 NAAQS throughout the state. Control Strategy II
set emission limits to be met by mid-1978 and was designed to attain the
original annual and 24-hour secondary S02 NAAQS, which have since been
rescinded by EPA, throughout the state with the exception of the 24-hour
standard in Macomb County. Consideration of the meteorological conditions
under which violations occurred in Macomb County indicated that the problem
would abate as sources outside the county were controlled. The SIP also
indicated that the EPA-rescinded secondary standards would be met in most
areas in mid-1975. Since it was unknown how many sources might meet the
Control Strategy II requirements by 1975, and since most would eventually
have to do so, this analysis assumes that the final compliance regulations
apply in 1975.
If a fuel combustion source is not subject to federal New Source
Performance Standards and if it can be shown that it is not contributing to
or causing a violation of the NAAQS, the Michigan regulation provides that
the Commission may delay the compliance date for that source until January
1, 1980. This delayed compliance provision has been used extensively in
Michigan to allow the continued use of high sulfur coals.
2.4 Special Considerations for the State of Michigan
2.4.1 Planned SIP Revisions
Under EPA's Clean Fuels Policy, the state of Michigan has submitted SIP
revisions granting until 1980 for compliance with sulfur dioxide emission
standards for six large coal-fired power plants. EPA has approved the plan
revisions for three plants and the other three are currently undergoing
further evaluation by the state and EPA Region V. Michigan has also made
-------
19
extensive use of the delayed compliance provision of its S02 regulation to
allow the use of higher sulfur coals by various fuel combustion sources
throughout the state.
Wayne County is currently evaluating the need to implement the last
step of its sulfur regulation for fuel combustion sources.
2.4.2 Fuels
Michigan is not a coal producer but is a large coal consumer. Over
80% of the heat input for power plants and industrial/commercial/institutional
point sources comes from coal. Area sources consume primarily natural
gas. Therefore, the major impact of regulation relaxation or delayed
compliance in Michigan would be increased use of higher sulfur coals.
2.4.3 Fuel Conversions
The Federal Energy Administration has identified the River Rouge and
St. Clair power plants in Metropolitan Detroit-Port Huron (#123) as having
the potential to switch from oil to coal.
-------
20
3.0 AIR QUALITY CONTROL REGION ASSESSMENTS
3.1 General Methodology
The previous section having set the background for the State Implementa-
tion Plan and evaluated the current air-quality situation, this section
will review the available information for each AQCR to determine the
feasibility of relaxing emission regulations in the interest of conserving
clean fuels. Care must be taken in interpreting the results of this analysis
and the following caveats must be kept in mind. (1) The analytical procedure
is intended to provide a first approximation to the evaluation of potential
regulation changes (e.g. rollback and single source modeling techniques were
used). The state must conduct a more detailed analysis of the situation to
confirm or dispute any of these findings prior to submitting any SIP revisions.
(2) In many instances the necessary data were unavailable or limited in scope.
Where possible, best engineering estimates were used to fill in the gaps.
Where better information is available, the state should use it in developing
SIP revisions.
The analysis encompasses five distinct considerations for each AQCR.
First, the current air quality situation is assessed to determine if the
indicators point to the region's ability to tolerate an emission increase
without violation of any NAAQS. Most of the data necessary for this review
have already been presented in Sec. 2, and Tables B-l and B-2 summarize the
information for particulates and S02, respectively, in each AQCR. The
assessment is made on the basis of 7 criteria: (1) current air quality
violations, (2) expected NAAQS attainment dates, (3) proposed Air Quality
Maintenance Area designations, (4) total emissions, (5) portion of emissions
from the state's fuel combustion sources, (6) regional emission reduction
required (based on rollback calculations), and (7) pollutant priority classifi-
cation. Note that this evaluation is based strictly on air quality considera-
tions. Determinations of whether regulation relaxation would, in fact,
result in clean fuels savings will be made on a source-by-source evaluation.
The second consideration for each AQCR is the power plant assessment,
and this data is summarized on the tables in Appendix C. All existing and
proposed plants are reviewed to determine the clean fuel requirements imposed
by existing regulations. Where dispersion modeling data are available, the
-------
21
maximum allowable fuel sulfur content that would enable the plant to meet
the NAAQS in its immediate vicinity is determined and compared to that
required by existing regulations. For the purposes of this report, the S02
modeling data used assumes that the power plant fuel use pattern in 1975
will be the same as that existing in 1971 with the addition of fuel consumption
for new units coming on-line. The choice of 1971 as the baseline year is
based on the consideration that fuel switching to achieve SIP emission regu-
lations did not begin nationwide until 1972; therefore 1971 represents con-
sumption patterns that are not dictated by emission regulations but rather
by the economics of fuel availability. In terms of the maximum allowable
fuel sulfur content determined from the modeling, the 1971 fuel sulfur
content is used as an upper bound. No particulate modeling results were
available. Fuel use data ' and emission data ' are drawn from both
published and unpublished sources.
The third consideration for each AQCR is the assessment of large indus-
trial/commercial/institutional point sources, and the summary data is presented
in Appendix D. The procedure is effectively equivalent to that carried out
for power plants in that the sulfur contents of fuels allowed under existing
regulations are determined along with total clean fuels requirements. Fuel
use data were drawn from the National Emission Data System (NEDS) file.
No individual source modeling data were available.
The fourth consideration is area source assessment. The fuel use
patterns for these sources are taken from NEDS data. The results are
summarized in Appendix E.
The fifth consideration is a synthesis of the first four. Fuel use
requirements for power plants and industrial/commercial/institutional point
sources are aggregated by region and for the entire state. Estimates of
potential clean fuels savings are made where modeling data exists. The
sunmary table appears in Appendix F.
At this point, an overall assessment of the potential for regulation
revision and resulting clean fuel savings can be made. The findings for each
AQCR have been summarized on Table 2-1 and in Sec. 1. An AQCR is determined
to be a good candidate for emission limit regulation revision if the air
quality indicators show that the region has a tolerance to absorb increased
emissions and if the source-by-source evaluations show that significant
-------
22
clean fuels savings could be effected by such revision. If the air quality
situation is such that no emission increase could be tolerated and/or if
the source evaluations show little or no clean fuels savings potential, then
the region is classified as a poor candidate for regulation revision. If
the air quality or the clean fuels savings evaluations are inconclusive or
show conflicting information, then the region is assessed as a marginal
candidate for regulation revision. A much more detailed analysis must be
carried out by the state to resolve the situation.
3.2 South Bend-Elkhart-Benton Harbor Interstate AQCR (#82)
Indications of high particulate levels (see Tables A-3 and B-l) and
the small fuel consumption in the Michigan portion of this region (see
Tables C-2, and D-2) make it a poor candidate for particulate emission
regulation relaxation, since only a minimal clean fuel saving would result
even if the regulations were relaxed.
Although regional air quality data indicate a substantial capacity to
absorb increased S02 emissions (see Tables A-4 and B-2) , the small fuel
consumption and the consequent small clean fuels savings potential also make
this region a poor candidate for S02 emission regulation relaxation. Present
Michigan regulations do not regulate small area sources. Thus, higher sulfur
fuels could be used by these sources if available (see Table E-l).
3.3 Central Michigan Intrastate AQCR (#122)
There are indications of existing widespread high TSP levels in this
region (see Tables A-3 and B-l). Emissions from fuel combustion sources also
contribute a relatively large fraction of the region's total particulate
emissions (see Tables A-5 and A-6) implying that any increase in emissions
would have a significant impact upon air quality. Thus, the region is a poor
candidate for particulate emission regulation relaxation.
High S02 levels have been found in this AQCR (see Tables A-4 and B-2)
and based on regional indicators, there appears to be little capacity to
absorb increased S02 emissions (see Tables A-5 and B-2). Michigan has used
the delayed compliance provision of its S02 emission regulation to allow the
use of higher sulfur coals by fuel combustion sources in this region (see
-------
23
Table C-l). This provision could also be used for most other combustion
sources through January 1, 1980 and regulation revision is thus not necessary
to allow the use of higher sulfur fuels. Sulfur emissions from small area
sources are not regulated in Michigan and some small amounts of higher sulfur
fuels, if available, could be used by these small sources (see Table E-l).
3.4 Metropolitan Detroit-Port Huron Intrastate AQCR (#123)
This region is a poor candidate for particulate emission regulation
relaxation. Regional air quality indicators show widespread high particulate
levels and the need for a substantial reduction in overall emissions in order
to attain satisfactory air quality. The proposal of particulate AQMAs also
indicates that the maintenance of acceptable air quality is expected to be
difficult and that there should be no increase in particulate emissions.
In addition, fuel combustion contributes a large portion of the total particu-
late loading meaning that any regulation relaxation would have a substantial
effect on air quality.
The Federal Power Commission has designated the River Rouge and St.
Glair power plants as having the potential to shift from oil to coal combustion.
The indications of poor particulate air quality show that such a shift must
be proceeded by a thorough study of its effects upon the region's particulate
air quality.
Metropolitan Detroit-Port Huron is a poor candidate for S02 emission
regulation relaxation. Although measured S02 levels are only slightly above
the standards, indicating that, on a regional basis, there is no capacity to
absorb increased SC>2 emissions, fuel combustion contributes a large fraction
of the regional S02 emissions and hence any overall regulation relaxation
would have a significant impact on air quality. However, there were no modeling
results available for this study to indicate whether source specific relaxation
might be possible and the magnitude of the indicated air quality problem is
small. Wayne County is presently evaluating the need to implement the last
step of its sulfur regulation and the situation there is thus already being
studied. Outside Wayne County, the delayed compliance provision of the state
regulation could be used for specific sources. S02 emissions from small
area sources in Wayne County are regulated but those from that portion of
this AQCR outside Wayne County are not. Thus, if available, higher sulfur
-------
24
fuels could be utilized by some area sources in that portion of the region
outside Wayne County.
3.5 Metropolitan Toledo Interstate AQCR (#124)
There is only one county in the Michigan portion of this AQCR. Newly
installed units at the Monroe power plant, however, make this county a sub-
stantial coal user. Air quality data show high TSP levels and indicate
little tolerance for increased emissions, making this region a poor candidate
for particulate emission regulation relaxation.
S02 levels are apparently acceptable and there are indications of a
regional capacity to absorb increased S02 emissions. The delayed compliance
provision has already been used to allow the Monroe power plant to fire
high sulfur coal and could be used for other fuel combustion sources in the
region. Regulation revision would thus not be necessary to allow the use
of high sulfur fuels through January 1, 1980, and the region is thus a
poor candidate for S02 emission regulation relaxation. At the Whiting power
plant, modeling by the state indicates that the continued use of II S coal
is necessary. Some small area sources may be able to switch to higher sulfur
fuels if they are available.
3.6 South Central Michigan Intrastate AQCR (#125)
South Central Michigan (#125) is a marginal candidate for particulate
emission regulation relaxation. Although available indications are that
the air quality is acceptable, measured levels are close to the standards
and the regional ability to absorb increased particulate emissions is small.
Since fuel combustion accounts for a large portion of the regional particulate
emissions, regulation relaxation would have a substantial effect on the just
acceptable air quality. Thus, any relaxation would require detailed study
of its probable effects on air quality.
Although there are indications that more S02 air quality data is
needed, there are high reported S02 levels suggesting little regional
capacity to absorb increased S02 emissions. However, compliance extensions
have been granted to several combustion sources in the region and this
mechanism could be used for other sources if any further continued use of
high sulfur fuels is possible. Thus, the regulations would not have to
-------
25
be revised to allow the use of higher sulfur fuels through January 1, 1980.
Under present regulations, small area sources could use higher sulfur fuels,
if available.
3.7 Upper Michigan Interstate AQCR (#126)
Current particulate air quality data indicate that there are high
particulate levels and no regional capacity to absorb increased particulate
emissions in Upper Michigan (#126). Even though fuel combustion contributes
a relatively small portion of the region's total particulate emissions, the
indicated poor air quality makes this region a poor candidate for particulate
emission regulation relaxation.
There are indications of acceptable S02 air quality. Although fuel
combustion contributes a large fraction of the regional S02 load, the
indicated regional tolerance for increased S02 emissions is large. The
state has already granted compliance extensions to several fuel combustion
sources in the region and is presently considering granting extensions to
four more power plants. This mechanism could be used to allow the use of
higher sulfur fuels through January 1, 1980 without regulation revision.
Small area sources could use higher sulfur fuels.
-------
APPENDIX A
State Implementation Plan Background
-------
Table A-l. Michigan Air Pollution Control Areas
Demographic Information
Air Quality
Control Region
South Bend-ElWiart-
Benton Harbor (Ind. )
Central Michigan
Metropolitan Detroit-
Port Huron
>fetropolitan Toledo
(Ohio)
South Central Michigan
Upper Michigan
Federal
Number
32
122
123
124
125
126
Population
1970
CMillions)
.83
2.22
4.33
.69
1.40
.56
Area
(Square
Miles)
4,198
18,053
2,686
1,519
7,873
25,981
Popu- ation
Per Square
Mile
297
223
1,M3
457
178
21
Priority
Classification
Parti -
culates
I
II
I
I
II
III
sox
IA
III
I
I
II
III
NOX
III
III
III
III
III
III
Proposed
AQMA Designations
TSP Counties
CO)
CO)
(3) Macomb, Oak-
land, Wayne
CO)
CO)
CO)
x Counties
CO)
(0)
CO)
CO)
CO)
(0)
As of Xoverier 14, 1974.
-------
PROPOSED TSP DESIGNATION
MUSKEGON MUSKEGON HEIGHTS
MU9CEGON
MUSXfCON
LEGEND
(?) Places of 100.000 of more inhabitants
• Places ot 50,000 to 100,000 inhabitants
Q Central cities ol SMSA's with le*ei than 50 000 inhabitants
O Places ol 25.000 to 50000 inhabitants outside SMSA s
. Standard Metropolitan
Statistical »reas ISMSA si
Figure A-l. Michigan Air Quality Maintenance Area (AOMA) Proposed Designations
-------
Table A-2. Michigan Ambient Air Quality Standards
All concentrations in ygm/m"
Federal
and
State
Primary
Secondary
Total Suspended Particulate
Annual 24-Hr
75 (g) 260a
60 (G) 150a
Sulfur Dioxide
Annual 24 -Hr 3-Hr
80 (A) 365a
1300a
Nitrogen Dioxide
Annual
100 (A)
100 (A)
Not to be exceeded more than once per year.
CA) Arithmetic mean
(G) Geometric mean
-------
Table A-3. Michigan AQCR Air Quality Status, TSP
TSP Concentration Qjgm/m )
Number of Stations Exceeding
Ambient Air Quality Standards
No. Stations
Reporting^
Highest Reading
\QCR
No. Annual 24-Hr Annual 24-Hr
S2b 12 18
89 244
122 35 41 137 783
123 38 43 176 492
124b 3 21
125 8 12
126 13 18
77 427
58 191
60 1408
'\ _ . .. . . Duality data in National Air Data Bank as
Interstate
2nd Highest Reading
24 -Hr
206
743
400
203
136
386
of June 7, 1971.
Primary
Annual 24-Hrc
2 0
3 1
IS 6
2 0
0 0
0 2
Required to , trolling
Secondary Meet Standards Standard
Annual 24-Hrc
4 4 +54
11 9 +84
26 31 + 82
3 5 •» 40
0 0 - 8
0 3 +67
Annual
24-Hr
Annual
Annual
Annual
24-Hr
violations based en 2nd highest reading at any station.
Formula:
f2nd Highest 24 -Hr -
V 2nd Highest
24-Hr Secondary Standard \
24 -Hr - Background )
„ i nrv /'Annual - Annual Secondary Standard^ „ i nn
X 1UU, 1
Annual - Background J
Background TSP concentration: 35 ygm/m
-------
Table A-4. Michigan AQC?. Air Quality Status.
SO,, Concentration (ygm/m
Nurrber of Stations Exceeding
/mbient Air Quality Standards
I Reduction
No.
AOCR
122
123
124b
125
126
Stations Reporting
24-Hr
5
11
9
3
2
4
a!973 air quality
Interstate
""Violations
Formula:
based
Cont.
0
5
16
6
2
0
data in National
Highest
Annual
14
22
82
41
82
19
Reading 2nd Highest Reading Primary Secondary
24-Hr 24-Hr /nnual 24-Hrc 3-Hrc
382 259 000
1148 1148e 010
410 147 100
224 82 0 ' 0
756 756e 111
122 64 00-
Required to _, Controlling
Meet Standards Standard
- 41 24-Hr
+ 68 24-Hr
+ 2 Annual
- 95 Annual
+ 51 24-Hr
- 470 24-Hr
Air Data Bank as of June 7, 1974.
on 2nd highest reading at any
/2nd Highest
station.
24 -Hr - 24 -Hr Standard^ „ ., nn /Annual - Annual Standard \ „ ?nn
^ 2nd Highest 24-Hr / " ""' ^ Annual J - ""
Second highest reading not available at station Adth greatest excesses. First, highest used as a conservative estimate.
Station shows at least 8 violations of 24-Hr standard.
-------
Table A-5. Michigan Fuel Combustion Source Summary
Total Emissions
Emissions from
AQCR
No.
82e
122
123
1246
125
126
Total
Power
Plants a
0
7
13
3
5
7
35
Other Fuel Combustion
Point Sourcesb
1
10
10
2
9
7
39
Area
Sources0
3
29
4
1
13
33
83
(1(P toi
TSP
72
196
378
122
52
88
908
ns/year,) J>
SOj
87
573
815
256
103
55
1,889
iicnigan ruei
TSP
5
66
76
26
66
20
55
L,OmDUi5tJ-Uil outlines
S0_2
7
99
92
24
93
87
81
aMichigan plants
Michigan plants contributing 90% of the particulate and SCU emissions or 1000 tons/year.
Michigan counties
dAQCR total
Interstate
-------
Table A-6. Michigan hnissions Summary , TSP
AQCR
82 Michigan
Other
Total
122
123
124 Michigan
Other
Total
125
126
Total
Total
(1CT tons/yr)
9
63
72
196
378
55
67
122
52
88
908
%
1
7
8
22
41
6
7
13
6
10
100
Electricitv Generaticn
(103 tons/yr) ?
0
39
39
32
68
18
4
22
2
5
168
C
62
54
If
18
33
(
18
4
f
H
Industrial/Commercial/
Institutional Point Source
CIO3 tons/yr) %
.3
4
4
74
186
12
14
26
16
6
312
4
6
5
38
49
23
21
22
31
. . 7
34
, Area Source
CIO-5 tons/yr) 1
3
13
16
24
33
1
16
17
16
6
112
39
21
23
12
9
2
24
14
31
7
12
Emissions in Data Bank as of June 27, 1974
-------
Table A-7. Michigan Emissions Stannary , SCL
AQCR
./Total
(1(T tons/yr)
Electricity Generation
(105 tons/yr)
Industrial/Commercial/
Institutional Point Source
(IP3 tons/yr)
Area Source
(IP'3 tons/yr)
82 Michigan
Other
Total
122
123
124 Michigan
Other
Total
125
126
Total
7
80
87
573 . .
815
64
192
256
103
55
1,889
1
4
5
: ••:30'":.
43
4
10
14
5
3
100 .
0
51
51
.•;.:.. ::307 v •
621
54
79
133 ...
32
. . . .16
. - 1,160
0
64
59
" '. :s4,.- : :;:."
76
85
41
.52.
31
..29
61
1
9
10
. :2i7 : . : , :
70
6
55
.61
41
.21
420
10.
11
11
. .38..
9
10
29
24
39
,.38
22
5
18
23
40
54
2
13
15
24
.11
167
74
23
27
7
7
3
7
6
23
. .20
9
aEmissions in Data Bank as of June 27, 1974
-------
AQCR
Table A-8. Michigan AQCR Required Emission Reduction0
Required Particulate Emission Reduction
Required SCL Emission Reduction
82b
122
123
124b
125
126
%
+ 54
+ 84
+ 82
+ 40
- 8
+ 67
10 tons/year
+ 39
+ 165
+ 310
+ 49
- 4
+ 59
%
- 41
+ 68
+ 2
- 95
+ 51
- 470
10 tons/year
- 36
+ 390
+ 16
- 243
+ 53
- 259
aBased on a proportional change of emissions to air quality
Interstate
-------
Table V-1). Michigan I;uei Combustion E-nission Regulations
Visible
Enissior-s
D-v— - — ••> - -^
Vi-i-.^
'
so.
I'.xistini; Facilities
State8
Kayne
County
Statea'd-e
•,Vsyr.- .
County1
State^ >k
i
Less, Uian Ruiyclionn III or 20 * oji.icity at all times except:
(a) Smoke not darker than Rir.;*elnann »2 or 40^ opacity nay he emitted for 3 min in any
60 nan period but on not more than 3 occasions during any 24 hr period,
(b) Wiere unconbir.ed water vapor is the only reason for £a..lure to comply, or
(c) Khere specifically permitted by the comnission and all other requirements are being met.
Less than Rinjelr^nn '1.5 or 30° opacity at all times except:
(a) For Rin^eLsar.-i SI. 5 or 303 opacity for 3 nin in any 30
(b) When uncombined water vapor is the only rjason for fai
(c) For certain allowed open fires.
Capacity Rating
(1,000 Ib steav/hr)
Pulverised coal 0 - 1,000
(includes cyclone furnaces)
> 1,000
Other modes of firing 0 - 100
100 - 300
> 300
Pulverized co.ilh 0 - 300
(includes cyclone furnaces)
300 - 3,600
All other r.cucs of fuel firing 0 - 100
100 - 300
300 - SOO
> SOO
f'l-.r.t C-.ncity1 M-ixi.-:.:.'. ' S
(:, O.J.I lh st^ar/hr) in i:i:e;l:,n,o
C - 503 1.5
> 500 1.00
Eumir.g fuel that results in an average emission of S02 for any
than -.OS emitted by the sa.-^c cquip-rcnt for the corrt spending cal
prohibited v-athout authorization by the coi^nission.
nin period,
ure to comply, or
Maximum Allovs'able
Emission
(Ib partiailate/
1,000 Ib exhaust gas)
See Fig. A-2
Apply to Commission
for liinit.f
0.6S
0.05 - 0.45s
Apply to Coitnission
for limit. *
0.30 - 0.20s
0.20 - 0.152
0.65
0.65 - 0.45s
0.45 - 0.30s
0.30
calendar month at a rate greater
c.-idar month of the year 1970 is
New Facilitic-s
Steam Generators > 250 x 10° Btu/hr
Tat.nl Ilc.it Tnput!1,11
Less than 20. opacity at all ti.nes except:
(a) that 40^ opacity is allowed for 2 dn
in any hr, or
> (b) fcl-.ere uncoriined water vapor is the
only reason for failure to ccmlv.
Less than 201 opacity at all tir.es except:
(a) that 40'. opacity is allovcU for 2 nia
! in any hr, or
(b) where uncariined water is the only
reason for failure to ccoply.
0.10 lb/10' Btu total heat inputc
0.10 lb/10' Btu total heat inputc
Solid Fuel Licuid Fuel
1.2 lb/106 Btu total 0.8 lb/10' Btu total
heat inputc heat inputc
For dual firing the emission factor is the
average of those for solid ar.d liquid fuels
weighted by tho 1 of the total heat input
supply by each separately.0
-------
Table A-9. Michigan Fuel Combustion Emission Regulations
CContd.)
SO-)
(Con? d. )
Wayne
County"4
Existing F.-.cilities
F7uel Use by ,;,lrl Maximum % S
Electric power plants and ~
central steam generation Pulverized coal
Other coal
Distillate oil
C'1,2)
Other oil (IK, 5, 6)
Residential/commercial Coal
space § water heating
Distillate oil
(#1,2)
Other oil (#4,5,6)
All other uses Coal
Distillate oil
(#1,2)
Other oil (*4,S,6)
in Fuelr
1.00s
0.50
0.30
0.70
0.30
0.30
0.70
0.50
0.30
0.70
All sources are limited to fuels having t_ie same or lesser sulfur
comparable Etu basis than the same source used during
remth of the previous year. The year ending with Jul
base year.
Maximum
ppm S02 in
Exhaust Gasd
550
280
120
280
120
120
280
280
120
280
content on a
the corresponding calendar
' 31, 1971 is
used as a
New Facilities
Steam Generators > 250 10 6 Btu/hr
Total Heat Inputb.°
Solid Fuel Liquid Fuel All Others
1.2 lb/106 Btu 0.8 lb/106 Btu As in the ppm S02
tota. heat input0 total heat inputc in exhaust gas
schedule for exist-
For dual firing the emission factor is ing sources
the average of those for solid and
liquid fuels weighted by the % of the
total heat input supplied by each
separately.0
Liir.it t
aExcept l\a;.Tie County.
bFed£ral New Source Performance Standards apply for these sources.
cTotal heat input from all fuels fired used to calculate allowable emission.
uCal culated to 50$ excess air.
eC'ther raxlr.ur. allowable emission rates can apply if specified by old installation or operating permits or by certain voluntary agreements, performance
, stipulaticri-S, or orders of the coiinission.
be bajcd or. "best technically feasible, practical equipment available."
%mssion lirdtations for specific ratings are determined by linear interpolation between ranges shown.
h.Jiy equir,-ent of this type constructed after March 31, 1972 requires a maxinium allowable emission listing from the Wayne County Dept. of Health.
^'Corrected to 1504 total air and deleting from the total exhaust gases that portion of waeer vapor added for collector or scrubber requirements.
-.-r.flios to structures devoted to steam or electric generation only.
•'• .'Lrioiis exertions to these limitations exist including a delayed compliance program whir.h allows the use of higher S fuel until January 1, 1980.
After January 1, 1980 specific authorization by the commission is the only permissible reason for non-compliance. (See footnote m. )
ITotal steam production capacity of all coal and oil fired equipment.
rnTheie limits are to be met on July 1, 1978. Less strict limits ^re to be met by July 1, 1975.
nAverage sulfur content in all fuels burned at any one time calculated on basis of 12,000 Btu/lb for solid fuels and 18,000 Btu/lb for liquid fuels.
'"-.-• r^ ^ itlc..--; ^rc r.l^o c.<-,rc:;:._J ;n torrs of the equivalent ppi.i of SOz in the exhaust ;;ascs and in terms of the equivalent Ib S02 emitted per 10° Etu
o£~hca: input for solid and' liquid fuels assuming 12,000 3tu/lb for solid fuels and 18,OnO Btu/lb for liquid fuels.
;' Applies to all fuel combustion including space a,id water heating.
'Xlertais exceptions exist for pers^rj operating stack gas desulfurization equipment.
rpersons using a combination of fuels to meet the S02 in exhaust gas schedule are exempt from this provision upon approval by the division. The
alloxsbie emission is based on the value of the schedule for the fuel having the higher iillowable limit.
SA less strict limit is applicable on August 1, 1975.
-------
- 1.0
I °'9
u. 0.8
° °-7
2 1 0.6
o o
CO ? r> c
CO U.O
^ O
<_LJ O
S 0.4
UJ
O UJ
^: cc
x
-------
APPENDIX B
Regional Air Quality Assessment
-------
Table B-l. Michigan AQCR Candidacy Assessment for Particulate Regulation Relaxation
Stations
Air
Quality
Control
Region
South Bsnd-Elkhart-
Benton Harbor (Ind.)
Central Michigan
Metropolitan Detroit-
Port Huron
Metropolitan Toledo
(Ohio)
South Central
Michigan
Upper Michigan
Federal
Number
82
122
123
124
125
126
with
Particulate
Air Quality
Violations
4
13
32
6
0
3
Number of
Expected Counties with
Attainment Proposed AQMA
Date Designations
7/75 0
7/75 0
7/75 3
7/75 0
0
a
- 0
Emission Reduction
Total Particulate
Emissions
.' (103 tons/yr)
72
196
378
122
52
88
% Emissions
from Michigan
Fuel Combustion
5
66
76
26
66
20
Required for
NAAQS
(10^ tons/yr)
+ 39
+ 165
+ 310
+ 49
- 4
+ 59
Particulate
Priority
I
II
I
I
II
III
aAttainr:sirc schedule indicates region is below standards; current data indicates violations.
-------
Table B-2. Michigan AQCR Candidacy Assessment for SCu Regulation Relaxation
Stations
Air
Quality
Control
Region
South Bena-Elkhart-
Benton Harbor (Ind.)
Central Michigan
iletrocolitan Detroit-
Port Huron
Metropolitan Toledo
(Ohio)
South Central
Upper Michigan
Federal
Number
82
122
123
124
125
126
with
S02
Air Quality
Violations
0
1
1
0
1
0
Expected
Attainment
Date
-
7/75
7/75
7/75
_
Number of
Counties with
Proposed AQMA
Designations
0
0
0
0
0
0
Total S02
Emissions
(103 tons/yr)
87
573
815
256
103
55
% Emissions
from Michigan
Fuel Combustion
7
99
92
24
93
87
Emission Reduction
Required for
NAAQS
(103 tons/yr)
- 36
+ 390
+ 16
- 243
+ 53
- 259
so2
Priority
IA
III
I
I
II
III
-------
APPENDIX C
Power Plant Assessment
-------
Table C-l. Michigan Power Plant Assessment
Estimated 1975
AQCR
82d
122
123
Plant
No plants
J. H. Campbell
D. E. Karne
B. C. Cobb
J. C. Weadock
J. deYoung
Harbor Island
Harbor Beach
Conners Creek
Delrayk
Marysville
Pennsalth
River Rouge
St. Clair
Trenton Channel
Wyandottc No.h
1975 Capacity
(Mw)
650.0
1,767.0
510.5
614.5
77.3
20.0
121.0
540.0
375.0
230.0
37.0
933.2
1,905.00
1,075.5
54.1
Fuel
coal
oil
coal
oil
coal
oil
coal
oil
coal
gas
coal
coal
oil
coal
oil
gas
oil.
gas1
coal
gas
coal
oil
coal
oil.
gas1
coal
oilJ
gas
coal
oil
gas
coal
oil
gas
Fuel Use
Quantity3
1,341
727
1,427
14,341
1,534
554
1,452
5,208
259
65
70
266
1,692
950
15,596
6,788
148,677
11,618
750
217
162
354
1,842
36,779
17,158
4,788
24,710
139
2,253
12,306
18,824
321
3,911
1,238
% S Under
SIP
Regulations
3.3°
0.3
3.2°
0.2£
3.3°
0.5
2.8°
0.3
2.8°
—
2.6°
2.9°
0.4
0.75§
0.3
—
0.7
—
1.0
—
0.9
0.3
1.0
0.7
—
1.0
1.1
—
1.0
0.3
—
0.8
0.3
—
9- Q
i> &
Allowed
by Modelc
3.3
0.3
3.2.
0.2*
3.3
0.5
2.8
0.3
2.8
—
2.6
2.9
0.4
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
-------
Table C-l. Michigan Power Plant Assessment (Contd.)
Estimated 1975
AQCR
123
(Contd.J
124d
125
126
1975
Mistersky
Beacon St.
Port Huron
Wyandotte So.h
Wyandotte
J. R. Whiting
Enrico Fermi
Monroe 3 ,
B. E. Morrow
0. E. Eckert3
Ottawa St.
Erickson lm
Coldwater
Advance
Presque Isle
Escanaba
J. H. Warden11
Gladstone
Bayside Station
Shiras
Capacity
(Mw)
174.0
23.0
6.3
18.5
40.0
325.0
158.0
075.2
186.0
386.0
81.5
160.0
11.1
36.0
344.7
23.0
18.8
6.0
35.0
34.5
Fuel
Fuel
coal
coal
coal
coal
gas
coal
oil
oil
coal
oil
oil
gas
coal
coal
coal
coal
coal
oil
coal
oil
coal
coal
gas
coal
coal
gas
coal
gas
Use
Quantity61
324
17
5
14
3,342k
984
65
45,128
8,076
3,945
26,187
8,492
671
102
665
37
129
84
900
823
80
49
731
12
55
321
74q
31201
% S Under % S
SIP , Allowed
Regulations by Model
1.0
0.5
1.5
1.0
— —
1.5 1.0P
0.5 0.5
0.4
2.9° 3.0
0.4 0.4
1.0
— —
1.5 2.1
2.8° 2.8
2.8° 2.8
1.5
1.5r
0.3
1.3° 1.3
0.1 -
1.5r
1.5r
— —
1.5r
1.5
— —
3.4° 3.4
— —
-------
Table C-l. Michigan Power Plant Assessment (Contd.)
Footnotes
aFuel requirements based on 1971 fuel use patterns at 1975 consumption rates.
If 1971 fuel use data were unavailable, 1972 data were used. Coal in 103
tons/yr, oil in 103 gal/yr, gas in 106 ft3/yr.
The maximum allowable % S is the 1971 \ S unless regulations require a lower
I S. Final compliance regulations to be met by July 1, 1978 outside Wayne
County and by August 1, 1976 inside Wayne County were assumed to apply in 1975.
Slaximum allowable coal I S is 1971 \ S unless modeling indicates a lower % S.
Oil I S is SIP IS. At plants where delayed compliance plans exist (see foot-
note o), the coal % S is that specified in the contract or agreement with the
commission.
Interstate.
eNew units in 1974 and 1975.
Projected oil I S content will be below SIP requirements; therefore, the pro-
jected oil % S was used and reported as SIP.
''Assuming steam production equally split between pulverized coal and stoker
units.
Figures include some fuel used for purposes other than electrical generation.
''includes blast gas and natural gas.
•'Also fired light oil.
Actual figure unavailable. Estimated on basis of heat input at other power
plants of similar capacity.
^ew units in 1973 and 1974.
mNew plant in 1973.
New unit in 1974.
°High sulfur coal being burned until January 1, 1980 as allowed by special con-
tract or agreement with the commission under the delayed compliance provisions
of the 862 emission regulations.
PRecent modeling by the state indicates that 1.0% S coal may be necessary at the
Whiting Plant.
1974 consumption figures.
rMichigan is presently considering allowing these plants to burn higher sulfur
coals under the delayed compliance provision: at advance 2.4% S, at Escanaba
1.7% S, at Warden 1.9% S, and at Gladstone 3.1% S.
Commission presently has agreement requiring low S fuel. Plant is now consi-
dering Supplementary Control System.
-------
Table C-2. Michigan Power Plant Evaluation Summary
AQCR
Fuel
82d No plants
122
123
124d
125
126
Michigan
Total
coal
oil
gas
coal
oil
gas
coal
oil
coal
oil
gas
coal
oil
gas
coal
oil
gas
1975
SIP
< 1%
Fuel Required by
Regulations3-*0
1-2% > 21
22,522
65
1,450
217,623
59,324
49,138
8,492
907
1,364
1,450
290,190
69,245
6,349
9,976
24,710
984 8,076
708 767
26,187
1,225 74
12,893 15,266
50,897
1975 Fuel Required by
Modified Regulations b,c
< 1% 1-2% > 2%
6,349
22,522
65
No modeling results
984 8,076e
49,138
1,438£
26,187
8,492
900£ 74£
907
1,364
1,884 15,937
72,567 26,187
9,921
-------
Table C-2. Michigan Power Plant Evaluation Summary (Contd.)
Footnotes
requirements based on 1971 fuel use patterns at 1975 consumption rates.
If 1971 fuel use data were unavailable, 1972 data were used. Coal in 103
tons/yr; oil in 103 gal/yr; gas in 106 ft3/yr. Maximum allowable % S is
1971 I S unless regulations require a lower % S. Final compliance regula-
tions were assumed to apply in 1975.
Maximum allowable coal I S is 1971 % S unless modeling indicates a lower I S.
Oil I S is SIP % S.
cAt plants where delayed compliance plans exist (see Table C-l), the coal % S
is that which is specified in the contract or agreement with the commission.
Interstate.
Modeling results for 96% of 1975 capacity.
Modeling results for 76% of 1975 capacity.
-------
APPENDIX D
Industrial, Commercial, Institutional Point Source Assessment
-------
Table D-l. Michigan Industrial/Commercial/Institutional Source Assessment
AQCR
82e
122
123
Planta
Watervliet Paper
CMC - Buick Motor Div. g
Dow Chemical
Hooker Chemical
S. D. Warren Company
Michigan Sugar
Monitor Sugar
Michigan Sugar- Croswell
Saginaw Steering Gear
Michigan Sugar- Caro
Menasha Corporation
Allied Chemical
Ford Motor
Mueller Brass
Chrysler-Dodge Truck
Assembly
General Motors
Chrysler-Sterling
Stamping Plant
LTV Aerospace
Fisher Body
Kelsey-Hayes
Mobil Oil
Fuelb
Coal
Coal
Coal
Coal
Coal
Coal
Coal
Coal
Coal
Oil
Coal
Coal
Coal
Coal
Gas
Coal
Coal
Coal
Coal
Coal
Coal
Coal
Oil
Gas
Estimated
Fuel
Consumption0
25
256
1,234
109
168
42
40
24
61
7,760
21
29
548
588
9,060
88
44
66
20
21
164
24
13,820
466
SIP
Regulations
%sd
1.5
1.0
1.0
1.5
1.7f
1.5
1.0
1.5
1.0
1.0
1.0
1.5
1.0
1.0
1.5
1.5
0.50
1.5
1.5
1.0
0.50
0.70
-------
Table D-l. Michigan Industrial/Commercial/Institutional Source Assessment (Contd.)
AQCR
1246
125
126
Planta
Ford Motor
Union Camp
Kalamazoo State
Hospital
Weyerhauser
National Gypsum
Simpson Lee Paper
Hercules
Fisher Body
Coldwater State Home
and Training School
Upjohn Company
Michigan State
University
Escanaba Paper
Hoerner Waldorf
White Pine Copper
Morton Salt
American Can
Packing Corporation of
America
Abitibi Corporation
Fuelb
Coal
Coal
Gas
Coal
Coal
Coal
Coal
Coal
Coal
Coal
Coal
Oil
Gas
Coal
Gas
Coal
Coal
Coal
Coal
Coal
Coal
Estimated
Fuel
Consumption
30
126
8,740
164
154
44
32
121
68
24
55
30,400
518
78
5,240
60
330
54
56
56
82
SIP
Regulations
%Sd
1.5
2.6£'h
1.5
1.5
1.5
1.5
1.5
1.5
1.5
1.0
1.0
1.0
1.5
1.5
1.51
1.5
1.5
1.5
-------
Table D-l. Michigan Industrial/Commercial/Institutional Source Assessment (Contd.)
Footnotes
Michigan plants contributing 90% of the AQCR's SO or particulate emissions or
1,000 or more tons/yr. ^
Does not include plant or process gas.
cCoal in 103 tons/yr; oil in 103 gals/yr; gas in 106 £t3/yr.
Since unit-by-unit fuel mix data were unavailable, compliance was required on
a plant-wide basis. Corrected to 12,000 Btu/lb for solid fuels and 18,000 Btu/lb
for liquid fuels. Final compliance regulations to be met by July 1, 1978 in
Michigan outside Wayne County and by August 1, 1976 in Wayne County were assumed
to apply in 1975. At plants where delayed compliance plans exist (see footnote f),
the coal % S is that specified in the contract or agreement with the commission.
Interstate.
High sulfur coal being burned until January 1, 1980 by special contract or agree-
ment with the commission under the delayed compliance provisions of the SCL emission
regulations.
^Currently under review for possible switching to higher sulfur fuel under delayed
compliance provision.
Currently under review. May need to use lower sulfur coal.
''"Michigan is presently considering allowing this plant to burn 3.0% S coal under the
delayed compliance provision.
-------
Table D-2. Michigan Industrial/Commercial/Institutional Source Evaluation Summary
AQCR
Fuel
Fuel
Required by Existing Regulations'
1-21
>2%
82L
Coal
25
122
123
124b
125
126
Michigan
Total
Coal
Oil
Coal
Oil
Gas
Coal
Gas
Coal
Oil
Gas
Coal
Gas
Coal
Oil
Gas
7,760
90
13,820
9,526
8,740
518
5,240
90
21,580
24,024
1,984
1,473
30 126
662
30,400
716
4,890 126
30,400
~~~3 not include plant or process gas.
Coal in 103 tons/yr; oil in 103 gals/yr; gas in 106 ft-yyr.
Percent S in fuel as fired, not corrected to standard Btu/lb values, and assuming
current heating values. Final compliance regulations to be met by July 1, 1978
in Michigan outside Wayne County and by August 1, 1976 in Wayne County were assumed
to apply in 1975.
Interstate.
-------
APPENDIX E
Area Source Assessment
-------
Table E-l. Michigan Area Source Fuel Use
AQCR
82a
122
123
124a
125
126
Total
^Coal
(10 tons/yr)
118
493
567
245
376
112
1,911
Residual Oil
(103 gals/yr)
9,710
74,120
40,700
1,670
31,190
8,990
166,380
Distillate Oil
(103 gals/yr)
175,910
622,240
936,650
101,850
393,210
233,620
2,463,480
Natural Gas
(106 ft3 yr)
75,620
131,920
441,060
58,450
106,510
22,850
836,410
Interstate - Fuel use figures are for entire AQCR.
-------
APPENDIX F
Fuels Assessment
-------
Table F-l. Michigan Clean Fuels Analysis Summary
Existing Regulations Clean Fuel Requirements"
Minimum Clean Fuel Savings Through
Regulation Modification
AQCR
82C
122
123
124C
125
iii>
Michigan
Total
Fuel
coal
coal
gas
coal
oil
gas
coal
rvn 1
gas
coal
r*n T
gas
coal
oil
eas
coal
oil
gas
< 1% S
30 282
fit.
1,540
231,443
68,850
dQ 1 ^8
Q m i
907
A fiP4
3,540
1-2% S > 2% S < 14 S 1-21 S
25 No power plants.
1,984 6,349 0 0
11,449 No modeling results.
2' ,710
1,014 8,202 0 o
1,370 767 0 671d
cf. CQ7 __ _
^94^ 74 00
17,783 15,392 0 671d
P19Q7 "_
Includes fuel use fron power plants (Table C-lj and industrial,'conr.ercial/institutional point sources (Table D-l) only. Coal in 10 tons/yr;
oil in 103 gal/yr; gas in 106'£t3/yr. Final compliance regulations to be net by July 1, 1978 in Michigan outside Wayne County and by August 1,
1976 in Wayne County were assumed to apply in 1975.
bBased on modeling results for coal at paver plants only. Includes potential savings that could be real:zed by present delayed compliance provisions.
"Interstate.
TTiis reflects coal consumption at the Eckert power plant which, has an agreement TjritL the Commission to hum low S coal hut is currently-
considering a Supplementary Control System.
-------
REFERENCES
1. Modeling Analysis of Power Plants for Compliance Extensions in 51 Air
Quality Control Regions, report prepared under Contract No. 68-02-0049
for the U.S. Environmental Protection Agency, Walden Research Division
of Abcor, Inc., Cambridge, Mass., December 17, 1973.
2. Steam Electric Plant Factors, 1973, National Coal Association, Washington,
D.C., January 1974.
3. Power plant data file, unpublished, U.S. Environmental Protection
Agency, Research Triangle Park, N.C.
4. Power plant S02 emission estimates, unpublished data, U.S. Environmental
Protection Agency, Research Triangle Park, N.C.
5. National Emissions Data Systems data bank, U.S. Environmental
Protection Agency, Research Triangle Park, N.C.
6. Federal Energy Administration, unpublished data.
-------
TECHNICAL REPORT DATA
(Please read Inductions on the reverse before completing)
REPORT NO.
EPA-450/3-75-003
3. RECIPIENT'S ACCESSION-NO.
TITLE AND SUBTITLE
5. REPORT DATE
IMPLEMENTATION PLAN REVIEW FOR MICHIGAN
REQUIRED BY THE ENERGY SUPPLY AND ENVIRONMENTAL
COORDINATION ACT
6. PERFORMING ORGANIZATION CODE
AUTHOR(S)
8. PERFORMING ORGANIZATION REPORT NO
PERFORMING ORGANIZATION NAME AND ADDRESS
U.S. Environmental Protection Agency, Office of Air
Quality Planning and Standards, Research Triangle Park
N.C., Region V Office, Chicago, 111., and Argonne
National Laboratory, Argonne, 111.
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
2, SPONSORING AGENCY NAME AND ADDRESS
13. TYPE OF REPORT AND PERIOD COVERED
U.S. Environmental Protection Agency
Office of Air and Waste Management
Office of Air Quality Planning and Standards
Research Triangle Park, N.C. 27711
14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
16. ABSTRACT
Section IV of the Energy Supply and Environmental Coordination Act of 1974,
(ESECA) requires EPA to review each State Implementation Plan (SIP) to determine
if revisions can be made to control regulations for stationary fuel combustion
sources without interfering with the attainment and maintenance of the national
ambient air quality standards. This document, which is also required by Section
IV of ESECA, is EPA's report to the State indicating where regulations might be
revised.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.IDENTIFIERS/OPEN ENDED TERMS
:. COSATI Field/Group
Air pollution
State Implementation Plans
^DISTRIBUTION STATEMENT
Release unlimited
Unclassified
57
20. SECURITY CLASS (This page}
22. PRICE
Unclassified
------- |