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

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                                                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

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                                  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

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                        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

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 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.

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       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.

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      Part of each state's review was organized to provide an analysis of

the S02 and TSP emission tolerances within each of the various AQCRs.   The

regional emission tolerance estimate is,  in many cases, EPA's only measure

of the "over-cleaning" accomplished by a  SIP.   The tolerance assessments

have been combined 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.

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                                                 (#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)

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                              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.

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                                      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

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                                      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.

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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?
ป 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?
ซ 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?
ซ 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

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I able 2-1.  State Implementation Plan Review for Michigan  (Contd.)
                                                 South Central
                                                   Michigan.
                                                  AQCR ฃ125
Upper I'tichigan
  AQCR #126
"INDICATORS"
ฎ 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?
ฐ 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
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              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.

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                                       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

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                                      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,

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                                       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

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                                     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.

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                                      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

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                                      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

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                                       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

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                                      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

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                                       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

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                                      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.

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             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.

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          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 ปreas ISMSA si
Figure A-l.    Michigan  Air Quality Maintenance Area (AOMA) Proposed  Designations

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                              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

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                                                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 •ป 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

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                                                     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.

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                             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

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                                               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

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                                                 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

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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

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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 ป2 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 ฃa..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 30ฐ 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 10ฐ 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

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                                                                  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 ง 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.ฐ

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.
bFedฃral 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 10ฐ  Etu
 oฃ~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  ฐ'9
   u.  0.8

   ฐ  ฐ-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

3.3ฐ
0.3
3.2ฐ
0.2ฃ
3.3ฐ
0.5
2.8ฐ
0.3
2.8ฐ
—
2.6ฐ
2.9ฐ
0.4
0.75ง
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
2.9ฐ 3.0
0.4 0.4
1.0
— —
1.5 2.1
2.8ฐ 2.8
2.8ฐ 2.8
1.5
1.5r
0.3
1.3ฐ 1.3
0.1 -
1.5r
1.5r
— —
1.5r
1.5
— —
3.4ฐ 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.

ฐHigh 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
1,438ฃ
26,187
8,492
900ฃ 74ฃ
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
2.6ฃ'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 ฃt3/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'ฃt3/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

-------