EPA-450/3-75-007
FEBRUARY 1975
IMPLEMENTATION PLAN REVIEW
FOR
NEVADA
AS REQUIRED
BY
THE ENERGY SUPPLY
AND
ENVIRONMENTAL COORDINATION ACT
U. S. ENVIRONMENTAL PROTECTION AGENCY
-------
EPA-450/3-75-007
IMPLEMENTATION PLAN REVIEW
FOR
NEVADA
REQUIRED BY THE ENERGY SUPPLY AND ENVIRONMENTAL COORDINATION ACT
PREPARED BY THE FOLLOWING TASK FORCE:
U.S. Environmental Protection Agency, Region IX
100 California Street
San Francisco, California 94111
Environmental Services of TRW, Inc.
(Contract 68-02-1385)
U.SS. 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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NEVADA
ENERGY SUPPLY AND ENVIRONMENTAL COORDINATION ACT
(SECTION IV - STATE IMPLEMENTATION PLAN REVIEW)
Page
1.0 EXECUTIVE SUMMARY 1
2.0 REVIEW OF THE STATE IMPLEMENTATION PLAN AND CURRENT AIR QUALITY 6
2.1 Summary 5
2.2 Air Quality Setting for the State of Nevada 9
2.3 Background on the Development of the Current State
Implementation Plan 9
2.4 Special Considerations for the State of Nevada 10
3.0 AQCR ASSESSMENTS 11
3.1 Clark-Mohave-Yuma AQCR (#013) 11
3.2 Nevada Intrastate AQCR (#147) 12
3.3 Northwest Nevada Intrastate AQCR (#148) 12
4.0 TECHNICAL APPENDICES
APPENDIX A - State Implementation plan Background 14
APPENDIX B - Regional Air Quality Analysis 33
APPENDIX C - PbweH PaaMf Assessment ? 36
APPENDIX D - Industrial, Commercial, Institutional Source
Assessment 40
APPENDIX E - Area Source Assessment 49
BIBLIOGRAPHY 44
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1.0 EXECUTIVE SUMMARY
The enclosed report is the U.S. Environmental Protection Agency's
(EPA) response to Section IV of the Energy Supply and Environmental
Coordination Act of 1974 (ESECA). . Section IV requires EPA to review
each State Implementation Plan (SIP) to determine if revisions can be
made to control regulations for stationary fuel combustion sources
without interfering with the attainment and maintenance of the National
Ambient Air Quality Standards (NAAQS). In addition to requiring that
EPA report to the State on whether control regulations might be revised,
ESECA provides that EPA must approve or disapprove any revised regu-
lations relating to fuel combustion 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 SIP's, wherever possible, be revised in the interest of
conserving low sulfur fuels or converting sources which burn oil or
natural gas to coal. EPA's objective in carrying out the SIP reviews,
therefore, has been to try to establish if emissions from combustion
sources may be increased. Where an indication can be found that
emissions from certain fuel burning sources can be increased and still
attain and maintain NAAQS, it may be plausible that fuel resource
allocations can be altered for "clean fuel savings" in a manner con-
sistent wifeb 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 imple-
mentation plans with regards to saving low sulfur fuels and, where the
primary sulfur dioxide air quality standards were not exceeded, to
encourage States to either defer compliance regulations or to revise the
SCL emission regulations. The States have also been asked to discourage
large scale shifts from coal to oil where this could be done without
jeopardizing the attainment and maintenance of the NAAQS.
1
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To date, EPA's fuel 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 SO^ regulations. These States are
generally in the Eastern half of the United States. ESECA, however, extends
the analysis of potentially over-restrictive regulations to all 55 States
and territories. In addition, the current reviews address the attainment
and maintenance of all the National Ambient Air Quality Standards.
There are, in general, three predominant reasons for the existence of
overly restrictive emission limitations within the State Implementation
Plans. These are 1) The use of the example region approach in developing
State-wide air quality control strategies; 2) the existence of State Air
Quality Standards which are more stringent than NAAQS; and 3) the "hot
spots" in only part of an Air Quality Control Region (AQCR) which have
been used as the basis for controlling the entire region. Since each of
these situations affect many State plans and in some instances conflict
with current national energy concerns, a review of the State Implementa-
tion Plans is a logical follow-up to EPA's initial appraisal of the SIP's
conducted in 1972. At that time SIP's were approved by EPA if they
demonsteited the attainment of NAAQS or. more stringent state air quality
standards. Also, at that time an acceptable method for formulating conteol
strategies was the use of an example region for demonstrating the attain-
ment 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 Jzo attain the NAAQS in the region. In using an
example region, it was assumed that NAAQS would be attained in the other
AQCR's of the State if the control regulations were applied to similiar
sources. The problem with the use of an example region is that it can
result in excessive controls, especially in the utilization of clean fuels,
for areas of the State where sources would not otherwise contribute to
NAAQS violations. For instance, a control strategy based on a particular
region or source can result in a regulation requiring 1 percent sulfur oil
to be burned state-wide where the use of 3 percent sulfur coal would be
adequate to attain NAAQS in some locations.
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EPA anticipates that a number of States will use the review findings
to assist them in making the decision whether or not to revise portions of
their State Implementation Plans. However, it is most important for those
States which desire to submit a revised plan to recognize the review's
limitations. The findings of this report are by no means conclusive and
are neither intended or adequate to be the sole basis for SIP revisions;
they do, however, represent EPA's best judgment and effort in complying
with the ESECA requirements. The time and resources which EPA has had to
prepare the reports has not permitted the consideration of growth, economics,
and control strategy tradeoffs. Also, there has been only limited dis-
persion 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 reports' findings are based is the most
currently available to the Federal Government. However, EPA believes that
the States possess the best information for developing revised plans. The
States have the most up-to-date air quality and emissions data, a better
feel for growth» and the fullest understanding for the complex problems
facing them in the attainment and maintenance of air quality standards.
Therefore, those States desiring to revise a plan are encouraged to verify
and, in many instances, expand the modeling and monitoring data support-
ing EPA's findings. In developing a suitable plan, it is suggested that
States select control strategies which place emissions from 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 emission regulations for combustion sources might have on
their future control programs. This may include air quality main-
tenance, prevention of significant deterioration, increased TSP, NOX,
and HC emissions which occur in fuel switching, and other potential air
pollution problems such as sulfates.
Although the enclosed analysis has attempted to address the attain-
ment of all the NAAQS, most of the review has focused on total suspended
particulate matter (TSP) and sulfur dioxide (S02) emissions. This is
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because stationary fuel combustion sources constitute a major source
of S02 and TSP emissions.
Part of each State's review was organized to provide an analysis of
the S02 and IPS emission tolerances within each of the various AQCR's.
The regional emission tolerance estimate is, in many cases, EPA's only
measure of the "over-cleaning" accomplished by a SIP. The tolerance
assessments have been combined in Appendix B with other regional air
quality indicators in an attempt to provide an evaluation of a region's
candidacy for changing emission limitation regulations. In conjunction
with the regional analysis, a summary of the State's fuel combustion
sources (power plants, industrial sources and area sources) has been
carried out in Appendices C, D and E.
The Hevada State Implementation Plan has been reviewed for the most
frequent causes of over-restrictive emission limiting regulations. The
major findings are as follows:
Although Nevada used the Example Region Approach in developing control
strategies for both TSP and SOg and has a 24-hour SO? air quality standard
more restrictive than NAAQS, there are no clear indications that current
regulations for either SOg or TSP are overly-restrictive.
These findings are supported as follows:
• As in the situation in many western states, high
particulate concentrations are found in all of Nevada's
Air Quality Control Regions. In the arid environment
natural background levels combined with activities such
as agriculture, unpaved roads and construction is
suspected as being the primary cause of ambient
measurements which exceed the national standards. Any
increase in man-made emissions caused by revising the
existing regulations for controlling particulates from
stationary fuel combustion sources would only aggravate
the existing situation. There is currently little
possibility, therefore, of revising particulate
regulations.
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• The majority of S02 emissions in the State emanate from
large point sources such as the copper smelter (mainly process
losses) and power plants. With regard to S02 emissions from
power plants, the review fails to find an abundance of avail-
able modeling or air quality data by which to judge the
restrictiveness of the regulations which apply within any
of Nevada's three AQCR's. Although this review can not suggest
that fuel combustion regulations are overly-restrictive,
additional monitoring and modeling in the vicinity of major
sources such as the Mohave Power Plant are necessary before a
final determination is made concerning the stringency of
regulations.
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2.0 NEVADA 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?
t Does the State have emission limitation regulations for control
of (1) power plants, (2) industrial sources, (3) area sources?
t 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 reported (1973) air quality data, are there indications
of a tolerance for increased emissions?
• Are the total BB*bstons from stationary fuel combustion sources
proportionally lower than those of all other sources?
• Is there a significant clean fuels savings potential in the
region?
• Must emission regulations be revised to accomplish significant
switching?
• Do modeling results for specific fuel combustion sources show
a potential for a regulation revision?
The following portion of this report is directed at answering these
questions. An AQCR's potential for revising regulations increases when
these are affirmative responses to the above.
The initial part of the SIP review report, Section 2 and Appendix A,
was organized to provide the background and current situation information
for the State Implementation Plan. Section 3 and the remaining Appendices
provide an AQCR analysis which helps establish the overall potential for
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revising regulations. Emission tolerance estimates have been combined
in Appendix B with other regional air quality indicators in an attempt
to provide an evaluation of a region's candidacy for revising emission
limiting regulations. In conjunction with the regional analysis, a
characterization of the State's fuel combustion sources (power plants,
industrial sources and area sources) has been carried out in Appendices
C, D and E.
Based on an overall evaluation of EPA's current information, AQCR's
have been classified as good, marginal or poor candidates for regulation
revisions. The following table summarizes the State Implementation Plan
Review. The remaining portion of the report supports this summary
with explanations.
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STATE IMPLEMENTATION PLAN REVIEW
(SUMMARY)
Clark-Mohave- Nevada Intra- Northwest Nevada
STATE Yuma AQCR state AQCR Intrastate AQCR
"INDICATORS"
• Does the State have air quality standards
which are more stringent than NAAQS?
• Does the State have emission limiting regu-
lations for control of:
1. Power plants
2. Industrial sources
3. Area sources
• Did the State use an example region approach
for demonstrating the attainment of NAAQS or
more stringent State standards?
t Has the State not initiated action to modify
combustion source emission regulations for fuel
savings; i.e., under the Clean Fuels Policy?
• Are there no proposed Air Quality Maintenance
Areas?
• Are there indications of a sufficient number
of monitoring sites within a region?
• Is there an expected 1975 attainment date
for NAAQS?
• Based on reported (1973) Air Quality Data,
does air quality meet NAAQS?
• Based on reported (1973) Air Quality Data,
are there indications of a tolerance for
increasing emissions?
• Are the total emissions from stationary fuel
combustion sources lower than those of other
sources?
• Do modeling results for specific fuel combustion
sources show a potential for a regulation revision?
• Must emission regulations be revised to accom-
plish significant fuel switching?
i Based on the above indicators, what is the
potential for revising fuel combustion source
emission limiting regulations?
• Is there a significant Clean Fuels Saving
potential In the region?
TSP S02
Yes
Yes
Yes
Yes
Yes
Yes
Yes1
Yes
Yes
Yes
Yes
Yes5
TSP S02
Nn
Yes
Yes
No
No
Yes
N/A
No
Poor
N/A
Ye*
No
Yes
N/A
N/A
No
N/A
Yes
Mar-
ginal
N/A
TSP S02
Yes
Yes
No
No
No
Yes
N/A
No
Poor
N/A
Yes
No
2
No
6
No
Yes
N/A
Yes
Poor
N/A
TSP S02
No
Yes
No
No
No
Yes
N/A
No
Poor
N/A
Yes
No
3
N/A
N/A
Yes
N/A
Yes
Mar-
ginal
N/A
I
Only for the annual and 24-hour standard
7/75 for priaary, 18 month extension granted for the secondary
Ambient air quality was below the NAAQS when the SIP was written
Only for the annual standard.
The State has relaxed regulations as to power plants and other fuel
combustion sources for the control of sulfur emissions, thus allowing
a greater range of fuel to be used.
Not available for the portion of the AQCR not affected by the Kennecott
Copper Corporation smelter.
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2.2 AIR QUALITY SETTING - STATE OF NEVADA
The State of Nevada is divided into three Air Quality Control
Regions (see Figure A^l): Clark-Mohave-Yuma Interstate (#013), Nevada
Intrastate (#147) and the Northwest Nevada Intrastate (#148). Priority
classifications for TSP, S09 and NO in these AQCR's are given in
£ X
Table A-l. Only two counties, Clark County in the Clark-Mohave-Yuma AQCR
and Washoe County in the Northwest Nevada AQCR, have been designated as
proposed Air Quality Maintenance Areas. Clark County is proposed for
TSP and oxidant, while Washoe County is proposed only for TSP.
Table A-4 illustrates both federal and state standards for the pollutants
under consideration in this report. Both sets of standards are identical,
except Nevada has .more stringent annual and 24 hour S02 standard. A summary
of the most currently available air quality data is shown in Tables A-5 and A-6.
Nine statioas in the Nevada portion of the Clark-Mohave-Yuma AQCR, three
stations in the Nevada Intrastate AQCR and six stations in the Northwest Nevada
AQCR report violations of the national secondary 24 hour particulate standard.
As for S02, the only stations reporting data are located in the Nevada Intra-
state AQCR, where five out of nine monitors recorded violations of the national
24 hour standard.
Emissions of SOp and particulate matter are summarized in Tables A-8 and
A-9. A large proportion of particulate emissions is fugitive dust, while S02
emissions can be attributed mainly to either copper smelter1 process losses or
to power plants.
2.3 BACKGROUND ON THE DEVELOPMENT OF THE CURRENT STATE IMPLEMENTATION PLAN
The State of Nevada adopted an example region approach in writing its
implementation plan. The Clark-Mohave-Yuma AQCR was selected as the example
region for all pollutants except for S02, for which the Nevada Intrastate AQCR
was chosen as the example region. Nevada standards were used in developing
control strategies and a proportional rollback model was applied to calculate
the emission reductions required.
federal secondary TSP standard of 60 >ig/m3 is only a guideline.
9
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The Nevada SIP did not provide a participate control strategy adequate
to attain national standards in the Northwest Nevada and Nevada Intrastate
AQCR's. The plan did not include natural windblown dust and fugitive dust
from various human activities in the emissions inventory, nor did the State
commit itself to the development of land use and/or transportation conteols on
a local basis necessary to solve the problem. EPA is in the process of deciding
what measures are acceptable for the control of man-induced fugitive dust.
Regarding SO-, the control strategy was disapproved for the Nevada
Intrastate AQCR because it did not provide adequate control for the Kennecott
copper smelter at McGill. The Kennecott Copper Corporation will implement
controls with the assistance of recently proposed EPA regulations. Such con-
trols will be sufficient to cause the national standards to be attained and
maintained starting in 1977.
2.3.1 Particulate Control Strategy
Regulations directed towards the control of particulate emissions
include: process weight table rate schedule, control of open burning and fuel
combustion particulate emissions.
2.3.2 S02 Control Strategy
The limitation of SOg emissions is aimed primarily at discharges from
copper smelting process operations and power plants.
2.4 SPECIAL CONSIDERATIONS - STATE OF NEVADA
The Clark-Mohave-Yuma AQCR is classified Priority I for oxidants. The
impact of fuel switching (i.e. natural gas to oil) can only aggravate the
oxidant problem, because hydrocarbon emissions from oil combustion are an
order of magnitude greater than natural gas combustion (see Table C-2). A
similar situation exists for coal combustion hydrocarbon emissions as opposed
to oil or natural gas.
As is the situation in many western states, fugitive dust is a problem in
all Nevada AQCR's and is a primary cause of ambient measurements which exceed
the national standards. In the arid environment, natural background levels
are significant and are aggravated by human activities. Particulate standards
are not likely to be attained and maintained in any Nevada AQCR;.
10
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3.0 AQCR ASSESSMENTS
3.1 CLARK-MOHAVE-YUMA AQCR (#013)
3.1.1 Regional Air Quality Assessment
Participate matter has remained a major problem in this AQCR
since the time the original implementation plan was submitted. A
major source of particulate emissions is wind-blown fugitive dust,
whereas man-made sources include mineral industry operations. There is
limited S02 monitoring data available in the vicinity of the Mohave Power
Plant (the major source of SO- for the region) and in the area of the AQCR
impacted by the three other power plants. Although Clark County's S02
fuel combustion regulations are especially stringent, this review cannot
conclude from available evidence that these regulations are unduly stringent.
Any revision of current regulations would require new evidence gathered from
additional continuous monitoring stations at locations based on new modeling
results.
3.1.2 Power Plant Assessment
There are four power plants in the Nevada portion of the Clark-Mohave-Yuma
AQCR. Two of these facilities, Mohave and Reid-Gardner, have the capability
of burning coal. Mohave is currently on a compliance schedule and Reid-Gardner
is on a variance. The other two plants, Clark and Sunrise, are dual oil-
natural gas fired units and are in compliance with Clark County regulations.
Table C-l illustrates the probable impact of fuel switching on SO,, and parti-
culate emissions at these plants. The term fuel switching means that Mohave
would burn only coal (instead of coal and natural gas or fuel oil) and
Sunrise and Clark would use only oil (instead of oil and natural gas).
V
3.1.3 Industrial/Commercial/Institutional Source Assessment
There are no sources in this category that; are currently burning coal
or have the capability of using coal without extensive modification. An
analysis is performed in Table D-l as to the resulting change in emissions if
a fuel switch from natural gas to oil is made.
11
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3.1.4 Area Source Assessment
The Clark-Mohave-Yuma AQCR was found to have no area sources which
could be analyzed within the context of Section 4 of ESECA.
3.2 NEVADA IJJTRASTATE AQCR (#147)
3.2.1 Regional Air Quality Assessment
The most currently available air quality data indicates frequent
violations of both the S(L and particulate standards (Tables A-5 and A-6).
S02 emissions can be attributed mainly to process losses from the one copper
smelter, while fugitive dust is a major source of particulate matter. EPA
estimates that controls on the smelter will be sufficient to allow the national
standards to be attained and maintained starting in 1977. Particulate matter,
however, will remain a major problem.
There are no indications that the regulations are overly restrictive.
3.2.2 Power Plant Assessments
There are no external combustion power plants in the Nevada Intrastate
AQCR which can be analyzed within the context of Section 4 of ESECA. A 45 MM
steam electric plant at McGill is kept idling at present but may return to
service if out-of-state electricity supplies prove unreliable.
3.2.3 Industrial/Commercial/Institutional Source Assessment
In this category, all sources under consideration within the scope of
this project use either oil or coal as a fuel (Table D-l). The analysis
presented in Appendix D shows the resulting emissions if all the sources were
to emit SCL and particulates at the emission limit.
3.2.4 Area Source Assessment
The Nevada Intrastate AQCR was found to have no area sources which could
be analyzed within the context of Section 4 of ESECA.
3.3 NORTHWEST NEVADA INTRASTATE AQCR (#148)
3.3.1 Regional Air Quality Assessment
As is the situation in the other two Nevada AQCR's, particulate matter
is a major problem. 1973 air quality data indicates that there are frequent
violations of the national secondary standards. Again, fugitive dust emissions
12
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are a major source of particulate matter. There is, unfortunately, no SCL
air quality data available. However, the only major sources of S02 in the
AQCR are two power plants, one in Lyon County (Tracy plant) and one in Storey
County (Ft. Churchill plant).
There are no indications that fuel combustion regulations are
overly restrictive.
3.3.2 Power Plant Assessment
The two external combustion steam electric power plants in this AQCR are
dual oil-natural gas fired and are unable to use coal without extensive
modification. Table C-l illustrates the resulting emissions if these plants
were to burn only oil.
3.3.3 Industrial/Commercial/Institutional Source Assessment
Table D-l illustrates the resulting emissions if this class of sources were
to emit S02 and particulate matter up to the limit allowed by regulations.
3.3.4 Area Source Assessment
The Northwest Nevada Intrastate AQCR was found to have no area sources
which could be analyzed within the context of Section 4 of ESECA.
13
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APPENDIX A. STATE IMPLEMENTATION PLAN BACKGROUND
0 State implementation plan information
• Current air quality information
• Current emission information
Tables in this appendix summarize original and modified state imple-
mentation plan information, including original priority classifications,
attainment dates, ambient air quality standards and fuel combustion
emission regulations. SAROAD data for SO, and TSP monitoring stations
^ 1
are showi for AQCR's in the state. NEDS emission data by AQCR .are tabu-
lated and are broken down into fuel burning categories.
Tables A-10 and A-ll show a comparison of emission inventories in the
original SIP and those from NEDS. An emission tolerance, or emission
tonnage which might be allowed in the AQCR and still not violate national
secondary ambient air quality standards, is shown for SO^ and particulates.
Tolerance was based on either the degree of control expected by the SIP or
upon air quality/emission relationships which are calculated from more
recent data. The value of the emission tolerance provides an indication
of the degree of potential an AQCR possesses for fuel revisions and
regulation relaxation.
Methodology for Increased Emissions Tolerance
A tolerance for increased emissions was determined as follows. First,
an "allowable emissions" was calculated for each AQCR based on the current
NEDS data and the percent reduction (or increase) required to meet the
national secondary ambient air quality standards in that AQCR (worst case
from Tables A-5 and A-6). This "allowable" was then compared to that from
the SIP. If reasonable agreement occurred, then the "estimated emissions"
which would result after implementation of the SIP in that AQCR was tised
to calculate an emissions tolerance. Thus, some credit could be given to
an AQCR which might be restricting emissions more than required by ambient
air quality standards. For instance, emission controls applied to AQCR's
1 "1972 National Emissions Report", EPA - 450/2-74-012, June 1974
14
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for the state may reduce emissions well below the allowables. In the event
that no data existed or was available from the SIP for an AQCR, the
current air quality was used to assign emission tolerances based on pro-
portional rollback or rollup. Current air quality was also the criteria, if
emissions data from SIP and NEDS did not appear to be comparable (this was
often the case).
When no SIP emissions data was available and current air quality levels
were less than one half of the level represented by an ambient air quality
standard, no "rollup" emission tolerance was calculated in Tables A-10
and A-ll. This arbitrary cutoff point was chosen so as not to distort the
emission tolerance for an area. At low levels of, a pollutant, the relation-
ship between emissions and air quality is probably not linear . Although
this cutoff may leave some AQCR's with no quantifiable emissions tolerance,
it was felt that no number at all would be preferable to a bad or misleading
number.
It is emphasized that emission tolerance is a region-wide calculation.
This tolerance obviously makes more sense fi;n, say, an urban AQCR with many
closely spaced emission sources than in a largely rural AQCR with
geographically dispersed emissions.
Low concentrations of pollutants probably indicate a low density of sources
and that the air quality monitors are not located near the sources. Thus
changes in emissions from the sources will not result in a linear change in
air quality readings.
15
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Table A-l Nevada Air Pollution Control Areas
/
Air Quality Control Region
Clark-Mohave-Yumac
Nevada Intrastate
NeirthWest Nevada
Intrastate
Federal
Number
013
147
148
Priority Classification9
Particulate
I
IA
I
S0x
IA
IA
III
NOX.
Ill
III
III
Proposed AQMA Designations15
TSP Counties
(1) Clark
(0)
(1) Washoe
SOY Counties
A
(0)
(0)
(0)
cr>
a Criteria based on maximum measured (or estimated) pollution concentration (jjg/m3) in area
Priority
Sulfur oxide
Annual arithmetic mean
24^hour waxrffMwn
Particulate matter
Annual geometric mean
24-hour maximum
Nitrogen dioxide
I
SfceatfeMthan
100
455
95
325
no
II
From- to
60-100
260-455
60-95
150-325
III
Less than
60
260
60
150
no
b Federal Register, August 1974, SMSA's showing potential for NAAQS violations due to growth
Interstate AQCR
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Washoe
NORTHWEST NEVADA .
INTRASTATE AQCR §
(#148)
Humboldt
Elko
—
T'
-v-J
Pershing
/ I \_
/ Lander! {
\ jEurek^
Churchill ) ' .,. „.
: /White Pine
-r*—^.
\
Mye
...J
Lincoln
Clark
CLARK-MOHAVE-YUMA AQCR
(#013)
NEVADA INTRASTATE
AQCR (#147)
Figure A-l State of Nevada
17
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Table A-2. Nevada Population and Area
Air Quality Control Region County
Clark - Mohave - Yurna3 Clark
Nevada Intrastate Churchill
Elko
Esmeradla
Eureka
Humboldt
Lander
Lincoln
Mineral
Nye
Pershing
White Pine
Northwest Nevada Carson
Interstate , Douglas
Lyon
Storey
Washoe
Area
(Square Miles)
7874
4883
17162
3570
4182
9702
5621
10649
3765
18064
6001
8904
141
723
2010
262
6375
1970
Population
273,288
10,513
13,958
629
948
6,375
2,666
2,557
7,051
5,599
2,670
10,150
15,468
6,882
8,221
695
121,068
Population Density
(Per square mile)
34.7
2.2
0.8
0.18
0.23
0.65
0.48
0.24
1.9
0.31
0.44
1.1
109.7
9.5
4.1
2.7
19.0
00
Interstate; only counties in the Nevada portion are included
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Table A-3 Attainment Dates
AQCR #
013
147
148
AQCR Hume
Clark-Mohave-Yuma
Nevada Intrastate
Northwest Nevada
Intrastate
Participates
Attainment Dates
Primary
7/75
7/75
7/75
Secondary
7/75
7/77
7/77
Sulfur Dioxide
Attainment Dates
Primary
7/75
7/75
c
Secondary
7/75
b
c
Nitrogen Oxides
Attainment Dates
c
c
c
Interstate with Arizona
•b
18 month extension granted
c Ambient air quality below standards when the SIP was written
-------
Table A-4 Nevada Ambient Air Quality Standards
All Concentrations in
Federal
Nevada
Primary
Secondary
Total
Suspended Particulates
Annual
75 (G)
60 (G) b
60 (G)
24-Hr.
260a
150a
150 C
Sulfur Oxides
Annual
80 (A)
60 (A)
24-Hr.
365a
260 c
3-Hr.
1300a
1300°
Nitrogen
Dioxide
100 (A)
100 (A)
100 (A)
(A) Arithmetic mean
(B) Geometric mean
a Not to be exceeded more than one time a year
b This is only a guideline standard (as of September 14, 1973)
c The State has made no specification as to the number of violations of the
24 hour and 3 hour standards which are permissible
-------
Table A-5 Nevada AQCR Air Quality Status, TSP
AQCR Name
Clark-Mohave=
Yuma b
Nevada
Intrastate
Northwest
Nevada
Intrastate
State
Nevada
Arizona
Nevada
Nevada
# Of
Stations Reporting
16
5
'•
9
15
2
TSP Concentration (pg/m )
Highest Reading
Annual
177
109
87
98
24 Hr.
850 -
1101
365
563
2nd
Highest
•Reading
24 Hr.
792
287
327
305
# of Stations Exceeding
Ambient Air Quality Standards
Primary
Annual
6
1
1
6
24 Hr?
3
1
2
2
Secondary
Annual
8
1
2
8
%
47
20
22
53
24 Hrc
9
1
3
6
%
53
20
33
40
Reduction
Required
to Meet d
Standards
81 e
59*
p
54 e
f
52 T
1973 air quality data in National Air Data Bank as of June 7, 1974
Interstate
iolations based on more than one excess of the standard
d Calculated from: 2nd Highest 24hr. Reading - 24hr. Secondary Standard Highest Annual Reading-Annual Secondary Std
__ __ _ __ _ ____ QV»
2nd Highest 24 hr. Reading Highest Annual Reading - Background
e Based on 24 Hr. standard
Based on annual standard
3
NOTE : 24 hour background assumed to be zero. Annual background for all AQCR's = 25 jjg/m
-------
Table A-6 Nevada AQCR Air Quality Status, S02
AQCR Name
Clark-Mohave-
Yuma
Nevada
Intrastate
Northwest
Nevada
Intrastate
State
Nevada
Arizona
Nevada
Nevada-
# of
Stations
Reporting
24-hr.
(Bubbler)
0
1
6
0
# of
Stations
Reporting
(Contin.)
N/A
0
3
0
0
SCL Concen. (pg/m )
Highest
Reading
Annual
N/A
3
257
N/A
24-Hr.
N/A
10
2758
N/A
2nd
Highest
Reading
24-Hr.
N/A
2
2515
N/A
# Stations Exceeding
Ambient Air Quality Stds.
Primary A
L Annual
N/A
0
2
N/A
24-Hr:
N/A
0
5
N/A
Secondary
3-Hr.
N/A
N/A
3
N/A
%
Deduction
Rpniii rpH
To Meet e
Standards
N/A
f
86 9
N/A
ro
ro
a 1973 air quality data in National Air Data Bank as of June 7, 1974.
Interstate
c The 2nd highest readings were given only at 24-hr, stations and not at continuous stations. The values
in this column are from 24. hr. stations and may not be the true 2nd highest reading (since the 2nd highest
reading from continuous stations may be larger in value).
Violations based on more than one excess of the standard
e Calculated from : 2nd Highest 24-hr. Reading - National 24-hr. Std.
2nd Highest 24-hr. Reading
Highest Annual Reading-Annual Secondary Std.
Highest Annual Reading-Background
f Reductions were not calculated because the annual and 24rhr. readings are less than % of the corresponding
standard. It was decided in this case that calculating reductions would yield misleading results.
9 Based on 24-hr, reading
NOTE : Background assumed to equal zero for both annual and 24-hr, concentrations
N/A = Not Available
-------
Table A-7 Nevada Fuel Combustion Source Summary
AQCR
Clark-Mohave-
Yuma c
Nevada
Intrastate
Northwest
Nevada
Intrastate
Nevada
Power Plants
4
1
2
Other Nevada Fuel .
Combustion Point Sources
1
5
1
Total Nevada Fuel
Combustion Emissions
(103 tons/year)
Parti culates
8.856
0.314
0.498
so2
55.603
1.758
1.164
ro
CO
Does not include plants which are only gas turbine or diesel units
Includes all sources in NEDS with SCC codes starting with 101 and 102.
c Interstate
Note- A point source is defined as (a) any stationary source causing emissions in excess
of 100 tons/year of any pollutant for which there is a national standard in a region
containing an area whose 1970 "urban place11 population, as defined by_the U.S. Bureau
of the Census, was equal to or greater than 1 million or (b) any stationary source
causing emissions in excess of 25 tons per year of any pollutant for which there is
a national standard in a region containing an area whose 1970 urban place
population, as defined by bhe U.S. Bureau of Census, was less tban 1 million, or
(c) without regard to the amount of emissions , stationary sources as those listed
in Appendix C of EPA Publication No. APTD-1135 (March, 1973).
-------
Table A-8 Nevada Emissions Summary, Participates'
AQCR
Clark-
Mohave-,
Yuma D
Nevada
Intrastate
Northwest
Nevada
Intrastate
State
Nevada
Arizona
Nevada
Nevada
Total
Da y»+- T pi 1 1 a 4~OC
(tons/yr.)
63,128
1,300
37,189
3,344
Electrical
Generation
tons/yr
8486
15
0
119
% of total
13.4
1.2
0
3.6
Industrial ,
Institutional ,
Commercial
Point- Source
Fuel Combustion
tons/yr
28
0
144
1
% of total
0.04
0
0.38
0
Area Source
Fuel Combustion
tons/yr
342
49
170
378
% of total
0.5
3.8
0.46
11.5
Other
Sources of
Particulate
Emissions
tons/yr
54,272
1,235
36,875
2,846
% of total !
86
95 •
99.2
i
85.1
ro
1972 emissions in data bank as of June 27, 1974
Interstate
-------
Table A-9 Nevada Emission Summary, SO,
AQCR
Clark-Mohave-
Yuma b
Nevada
Intrastate
Northwest
Nevada
Intrastate
State
Nevada
Arizona
Nevada
Nevada
Total
SO?
(tons/yr)
57,024
594
275,264
3,753
Electrical
Generation
tons/yr
54,876
1
0
282
% of total
96.2
0.2
0
7.5
Industrial ,
Institutional ,
Commercial
Point Source
Fuel Combustion
tons/yr
1
0
1435
9
% of total
0
0
0.51
0.26
Area Source
Fuel Combustion
tons/yr
726
50
323
873
% of total
1.3
8.4
0.12
23:3
!
Other Sources
of S09 Emissions
tons/yr
1,421
543
273,506
2,589
% of total
2.5
91.4
99.4
68':9
rxi
en
1972 emissions in data bank as of June 7, 1974
Interstate
-------
Table A-10 Nevada Required Emission Reductions, Participates
AQCR
Clark-
Mohave-
Vuma a
Nevada
Intra-
state
NU
Nevada
Intra-
state
County
Clark
Chur-
chill
White
Pine
Miner-
al
Elko
Nye
Carson
City
Douglas
Lyon
Storey
Washoe
AQ
Measurement
Control, Value
(ug/mj)
137 b
443 c
800 c
338 C
67 c
k
93 D
234 c
265 c
346 c
39 b
349 c
Emissions
(103 tons)
88.99
0.493
8.54
0.472
1.84
1.506
2.091
2.627
0.743
0.283
4.424
Allowable
Emissions
(103 tons)
27.58
0.148
1.386
0.189
1.55
0.768
1.25
1.37
0.29
0.710
1.73
1975
Estimated
Emissions
After Controls
(103 tons)
13.114
0.554
1.136
0.514
1.33
0.715
0.458
0.680
0.743
0.219
2.006
%
Reduction
Required
Based
on 1973
AQ Data
81
54
\
52
/
1972 NEDS
Emissions
(103 tons)
63.1
37.18
3.34
Allowable
Emissions
(103 tons)
11.9
17.1
1.6
Emissions
Tolerance
(103 tons)
-51.2
-20.08
-1.73
Comments
The SIP contained detailed information for only the counties listed.
Although Mineral and Churchill Counties were not projected by the SIP
to meet the standards, EPA has yet to determine what controls will
allow the NAAQS to be attained.
1972 and 1973 AQ and emissions data are for the entire AQCR. ;
(
;
Although Lyon and Washoe Counties were not projected to meet the standards,
EPA has yet to determine what additional controls are required such that
NAAQS can be attained.
1972 and 1973 AQ and emissions data are for the entire AQCR.
a Interstate; counties included are only those in the Nevada portion of the AQCR
b Annual geometric mean
c 24 hour maximum
-------
Table A-ll Nevada Required Emission Reduction,
From SIP
SO,
From 1972 and 1973 Data
AQCR
Clark- Mghave
-Vuma a
Nevada
Intrastate
Northwest
Nevada
Intrastate
County
Clark
Mite
Pine
Carson
City
Douglas
Lyon
Storey
Washoe
AQ
Measurement
Control Value
(ug/m3)
N/A
488 b
N/A
N/A
N/A
N/A
N/A
Emissions
(103 tons)
55.8
252.75
0.207
0.169
0.185
0.016
2.245
Allowable
Emissions
(103 tons)
N/A
133.95
N/A
N/A
N/A
N/A
N/A
1975
Estimated
Emissions
After Controls
(103 tons)
N/A
100.68
\
N/A
N/A
N/A
N/A
N/A
%
Reduction
Required
Based on
1973 AQ Data
N/A
86
N/A
1972 NEDS
Emissions
(103 tons)
57.024
275.264
3.753
Allowable
Emissions
(103 tons)
N/A
38.5
N/A
Emission
Tolerance
(103 tons)
N/A
-236.727
N/A
Comments
At the time the SIP was written, there were no reported violations of the
standards. Thus no control strategy was required. However, this AQCR 1s
classified Priority IA due to planned additional sources
The SIP contained detailed information only for White Pine County.
1972 and 1973 AQ and emissions data are for the entire AQCR.
Because this AQCR 1s classified Priority III for SO., no control strategy
was required in the SIP.
1972 and 1973 AQ and emissions data are for the entire AQCR.
Interstate; only counties in the Nevada portion of the AQCR are included
24 hour maximum
-------
o
X)
Table A-12. Nevada Fuel Combustion Regulations9
Particulate Matter
(1) State of Nevada - No person shall cause, suffer, allow or permit the emissions of particulate matter
resulting from the combustion of fuel in excess of the quantity set forth in the
following table:
Maximum equipment capacity Maximum allowable emissions of particulate matter
rate in million kilogram- in kilograms per hour per million kilogram-
calories per hour calories of heat input
Up to and including 2.5 1.08
25 0.64
250 0.37
2500 0.16
25000 0.044
- For heat input greater than 2.5 million kilogram-calories (10 million Btu's) per
hour, but less than 1,000 million kilogram-calories (4000 million Btu's) per hour,
the allowable emissions shall be calculated using the following equation:
Y=1.34x-°'231 (1.02x-°-231j
X = Maximum equipment capacity rate in million kilogram-calories
(million Btu's) per hour
Y = Allowable rate of emission in kilograms per million kilogram-
calories (pounds per million Btu's)
- For heat inputs equal to or greater than 1000 million kilogram-calories (4000
million Btu's) per hour, the emission shall be calculated using the following
equations
-------
Table A-12. Nevada Fuel Combustion Regulations9 (Continued)
10
(2) Washoe County
(3) Clark County
Y = 13.9 x
-0.568
-0.568
)
X = Maximum eguipment capacity rate in million kilogram-
calories (million Btu's) per hour
Y = Allowable rate of emissions in kilograms per million
kilogram-calories (pounds per million Btu's)
- For purposes of these regulations, the heat input shall be the aggregate heat content
of all fuels whose products of combustion pass through a stack or stacks, or the
equipment manufacturer's or designer's guaranteed maximum heat input, whichever is
greater. The total heat input of all fuel burning units in a plant or on the premises
shall be used for determining the maximum allowable amount of particulate matter which
may be emitted.
- It is unlawful for any person to discharge or cause to be discharged, into the
atmosphere from any source, particulate matter in excess of 0.15 grains per cubic foot
at standard conditions.
- Same as the State.
Su3fiflifu0xides
(1) State of Nevada
No person shall cause, suffer, allow or permit the emission of sulfur compounds caused
by the combustion of fuel in excess of the quantity set forth in the following:
Heat input, million of kilogram-
calories per hour
10
100
1000
10000
100000
Maximum sulfur emission, kilograms
per hour
12.6
72.0
720.0
1890.0
18900.0
-------
Table A-12. Nevada Fuel Combustion Regulations3 (Continued)
Where a source located on contiguous property has a total heat input of less than
63 million kilogram-calories (250 million Btu's) per hour the allowable emission
shall be calculated by the use of the following equation:
Y = 1.26 x (Y = 0.7 x)
X = Maximum heat input in millions of kilogram-calories
(Btu's) per hour
Y = Allowable rate of sulfur emission in kilograms
(pounds) per hour
Where a source located on contiguous property has a total heat input of greater than
63 million kilogram-calories (250 million Btu's) per hour but less than 1.26 foil lion
kilogram-calories (5 billion Btu's) per hour, the allowable sulfur emissions shall be
calculated by use of the following equation:
Y = 0.72 x (Y = 0.4 x)
X = Maximum heat input in millions of kilogram-calories
(Btu's) per hour
Y = Allowable rate of sulfur emission in kilograms
(pounds) per hour
Where a source located on contiguous property has a total heat input of greater than
1.26 billion kilogram-calories (5 billion Btu's) per hour the allowable emission shall
be calculated by the use of the following equation:
Y = 0.189 x (Y = 0.105 x)
X = Maximum heat input in millions of kilogram-calories
(Btu's) per hour
Y = Allowable rate of sulfur emission in kilograms
(pounds) per hour
-------
Table A-12. Nevada Fuel Combustion Regulations3 (Continued)
(2) Clark County
(3) Washoe County
For purposes of these regulations, "sulfur emission" means the sulfur portion of
the sulfur compounds emitted.
No person shall cause or permit the emission of sulfur dioxide from any fuel burning
equipment in excess of the quantity set forth in the following table:
Heat input, millions of Btu's
_ per hour
1000
5000
10000
15000
20000
25000
30000
35000
40000
45000
50000
Maximum allowable rate of emission of S0
_ pounds per hour _
150
750
1500
2250
3000
3750
4500
5250
6000
6750
2500
Maximum allowable emission rate of sulfur dioxide shall be determined by using the
equation
Z = 0.15X where Z = allowable rate of sulfur dioxide emissions
in pounds per hour and
X = Maximum heat input in millions of Btu per hour.
It is unlawful for any person to store, offer for sale, burn, or cause to be burned,
within Clark County at any time, any commercial fuel oil having a sulfur content in
excess of 1.0 percent by weight.
It is unlawful for any person to discharge, or cause to be discharged, into the
atmosphere, any one or more of the following contaminants, in any state or combination
thereof, exceeding in concentration at the point of discharge.
-------
Table A-12. Nevada Fuel Combustion Regulations (Continued)
A. Sulfur compounds calculated as sulfur dioxide (SOp): 0.2 percent, by volume.
B. Combustion contaminants: 0.15 grains per cubic foot of gas calculated at 12%
of carbon dioxide (C02) at standard condition.
- Sulfur content of fuel:
A. Less than 250 million Btu per hour heat input:
It is unlawful for any person to burn, or cause to be burned, within the
District at any time, a fuel having a sulfur content in excess of 1.0%
by weight.
B. For 250 million or more Btu per hour heat input the allowable emissions shall
be calculated by use of the following formula:
Y = 0.105X
X = Miaimum heat input, number of millions of Btu per hour
Y = Allowable rate of sulfur emissions in pounds per hour
C. Fuels with sulfur content exceeding the above limitations may be used if it
can be shown that adequate sulfur removal equipment is present to limit the
sulfur emissions into the atmosphere to the same degree as if fuels with the
proper sulfur content had beer] used.
From Nevada SIP Amendments (9/74), Clark and Washoe County regulations.
-------
APPENDIX B. REGIONAL AIR QUALITY ANALYSIS
Tables B-l and B-2 are the assessment of AQCR's which should be
examined for the fuel switching impact in particulate and SCL emissions.
They also provide an identification for those AQCR's which show little
potential for fuel revision or regulation relaxation if ambient air
standards are to be attained.
The criteria for candidates are (1) the severity and breadth of air
quality violations, (2) the tolerance for emissions increases in the AQCR,
(3) the fraction of total emissions resulting from fuel combustion and (4)
AQMA designations. It should be noted that an AQCR may not necessarily need
relaxation of regulations in order to accomplish fuel switching. Further, a
good candidate in Tables B-l and B-2 may later show little potential for fuel
switching after individual sources are examined. Finally, it is possible
that an AQCR may have air quality levels below standard at present and may
require more strict regulations than currently exist if all fuel burning
sources were converted to dirtier fuels, i.e., "average" emission rates now
may be below "average" regulations.
33
-------
Table B-l. Nevada Candidacy Assessment for Revision of Participate Regulations
AQCR
Clark-Mohave-
Yurna9
Nevada
Intrastate
Northwest
Nevada
Intrastate
# of
Stations
16
9
15
# of Stations Reporting
Violations of National
Secondary Standard
Annual 24 Hour
8
2
8
9
3
6
Expected
Attain-
ment
Date
7/7.5
7/77
7/77
Counties with
Proposed AQMA
Designation
for
Parti culates?
Yes
No
Yes
1972
Total
Emissions
(tons/yr)
63,128
37,189
3,344
% Emissions
from Fuel
Combustion
14
0.8
14.9
Tolerance for
Emission
Increase
in 1975
(tons/year)
-51 ,200
-20,080
- 1,730
Regionwide
Evaluation
Poor
Candidate
Poor
Candidate
Poor
Candidate
Interstate; information included is for the Nevada portion of the AQCR
CO
-------
Table B-2. Nevada Candidacy Assessment for Revision of S02 Regulations
AQCR
Clark-Mohave-
Yumaa
Nevada
Intrastate
Northwest
Nevada
Intrastate
# of
Stations
0
9
0
# of Stations Reporting
Violations of National
Secondary Standards
Annual 24-hour
N/A
2
N/A
N/A
5
N/A
Expected
Attain-
ment
iDate
7/75
7/77
b
Counties. .with
Proposed AQMA
Designation
for
so2?
No
No
No
1972
Total
Emissions
(tons/yr)
57,024
275,264
3,753
% Emissions
from Fuel
Combustion
97.5
0.6
31.1
Tolerance for
Emission
Increase
in 1975
(tons/year)
N/A
-236,727
N/A
Regionwide
Evaluation
Marginal
Candidate
Poor
Candidate
Marginal
Candidate
CO
en
3 Interstate; information included is for the Nevada portion of the AQCR
b Ambient air quality was below standards when the SIP was written
N/A = not available
-------
APPENDIX C. POWER PLANT ASSESSMENT
This section is a review of individual power plants by AQCR. The
intent is to illustrate fuel switching possibilities and particulate and
S02 emissions resulting from these switches on an individual plant basis.
For the purposes here, it is assumed that when a plant is shown to have
dual fuel capability, it is able to use entirely one fuel or the other. A
fuel switch calculation is then made, assuming all natural gas use is replaced
by either oil or coal depending on assumed plant capabilities. Further, oil
use is replaced by coal where possible. The % sulfur in fuel (coal or oil)
assumed when fuels are switched is indicated in Table C-l. A plant was then
assumed to have the same emissions controls as was in effect when the NEDS
emissions were assembled.
Also shown are the regulations which are currently applicable to the
given plant, taken from Table A-12. (Limits are assumed to be based on the
entire heat input of the plant. Actual rules may be different when applied to
to each of several boilers in a power plant or applied on the basis of design
capacity rather than the actual amount of fuel used. )
The fuel switch calculations are intended to show the magnitude of
emission increase accompanying a fuel switch without additional controls.
The exact emissions would depend upon actual fuel mix, amount of sulfur in fuels
and degree of emission controls.
It might be cautioned that AQCR total emissions calculated in the
tables of Appendix C (and also Appendix D) may not agree exactly with total
emissions represented in Appendix A. This is a result of both differing fuel
schedules in 1973 compared to previous years, and the relative "completeness"
of the NEDS data bank.
36
-------
Table C-l Nevada Power Plant Assessment
AQCR
Clark-Mphave-
Yuma °
NW Nevada
Intrastate
Plant
Mohave
Reid-
Gardner
Clark
Sunrise
Ft. Chur-
chill
Tracy
Capacity
(HW)
1520
227
190
82
22
133
Fuel Use0
Type
% 5
% A
Coal
0.51* S
Gas
Coal
0.53% S
8% A
011
Gas
Oil
Gas
011
0.9% S
Gas
Oil
0.8% S
Gas
Annual
Quantity
3276
5315
629
4326
11734
3308
4367
1428
14226
1410
3520
Heat Input
(106 Btu/hr.)
8975
607
1723
74
1339
57
499
24.5
1624
24
402
Emissions'1
Tons/yr.
so2
31743
II/A
6368
172
H/A
131
N/A
101
4
88
1
Part.
3930
N/A
1708
105
H/A
46
N/A
6
107
6
26
Lbs/hr.
so2
7247
N/A
1452
39
N/A
30
N/A
23
20
0.2
Lbs/106 Btu
Part.
0.094
N/A
0.23
0.017
II/A
0.019
N/A
0.056
0.015
0.057
0.015
Emission
Limit
Lb/hr.
so2
1437
258
212
83.4
659
170
Lb/106 Btu
Part.
0.093
0.18
0.19
0.23
0.18
0.25
% S
Assumed
0.51
0.53
II/A
n/A
0.9
0.8
Emissions After
Fuel Switching
Tons/vr.
so2
33890
-
3284
1278
6796
1562
Part.
4196
-
2005
449
404
107
Lbs/hr.
so2
7737
-
750
292
1552
357
Lbs/106 Btu
Part.
0.099
-
0.32
.0.18
0.056
0.057
CJ
-------
Table C-l Nevada Power Plant Assessment (Continued)
a Only steam electric units are considered
Interstate; only power plants in the nevada portion are considered
c Dfcta from the following sources - for Mohave, Reid-Gardner, Clark and Sunrise : 1973 NEDS (as of August 1,11974)
- for Ft. Churchill : 1973 Federal Power Commission data
- for Tracy : 1972 NEDS (as of December 6, 1974)
Heat content of fuels assumed to be : Coal = 24 million Btu per ton
Oil * 150,000 Btu per gallon
Gas == 1000 Btu per scf
3
Coal use in terms of 10 tons
3
Oil use in terms of 10 gallons
6 3
Gas use in terms of 10 ft
d Data from the following sources - for Mohave, Reid-Gardner, Clark and Sunrise : 1973 NEDS (as of August 1, 1974)
- for Ft. Churchill : calculated from Table C-2
- foe Tracy : 1972 NEDS (as of December 6, 1974)
e For power plants using both natural gas and oil: Convert the quantity of natural gas used into an
equivalent quantity of oil with the same sulfur content. Increase the SOp and particulate emissions
by direct proportioning assuming all fuel ased is oil. For plants burning both coal and natural gas
or coal and oil, the same procedure is utilized but assuming all fuel burned is coal.
Or •.,' JiA I rt: '• 13 1 I
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Table C-2. AP-42 Power Generation Emission Factors
oo
VD
Fuel
Particulates
Lbs/Ton Lbs/10° Btu
S°2 6
Lbs/Ton Lbs/10° Btu
Hydrocarbons,-
Lbs/Ton Lbs/10° Btu
NOX (as N02)
Lbs/Ton Lbs/106 Btu
Coan''(Bit.)
General
Wetbottom 10%
Cyclone
1% S
2% S
3% S
Oil'2' .
0.5% S
1.0% S
2.0% S
Gas^3^
(.3 IDS S/
106 Ft3)
160
A 130
20
Same
as
Above
Lb/103 Gal
8
8
8
Lb/106Ft3
15
7.4
7.0
0.9
Same
as
Above
0.058
.058
.058
.015
38
76
114
Lb/103 Gal
79
157
314
Lb/106Ft3
0.57 .
lf.65
3.3
5.0
0.56
1.12
2.24
00057
0.3 0.013 18
30
: 55
0.3 0.13 Same
as
0.78
1.3
2.4
Same
as
Above Above
Lb/103 Gal Lb/103 Gal
2 .014 105
2 .014 105
2 .014 105
Lb/106Ft3 Lb/106Ft3
1 .001 600
0.75
0.75
0.75
0.60
(1) Coal 23 x 106 Btu/Ton
(2) Oil 140 x 103 Btu/Gal
(3) Gas 1000 Btu/Ft3
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APPENDIX D. INDUSTRIAL, COMMERCIAL, INSTITUTIONAL SOURCE ASSESSMENT
Table D-l in this appendix lists individual industrial/commercial/
institutional sources of particulates and SOp emissions which might show
fuel switching potential.
40
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Table D-l Nevada Coronerclal, Industrial and Institutional Source Assessment
AQCR
Clark-Mohave-
Yuma
Nevada
Intrastate
NH Nevada
Intrastate
Plant
Stauffer
Chemical
Foote
Mineral
Baroid
Carl in
Gold
Mining
AEC
Nevada
Test
Site
Kenne-
cott
Copper
Corp.
Nevada
High-
way
Dept.
Type
% S
X A
Gas
011
0.731S
Oil
0.2XS
Oil
0.3%S
on
0.05*5
Oil
0.5XS
Coal
0.7JS
Oil
I.MS
Fuel Use
Annual
Quantity
3080
461
16
310
484
303
100
116
b
Heat
Input
(106Btu/hr)
352
10.3
4.3
17.2
7.7
4.8
526.5
1.85
Emissions0
tons/yr.
Part.
28
2
0
0
0
1
138
0
su2
1
28
0
8
0
6
1402
9
lb/106Btu
Part.
0.018
0.062
0
0
0
0.047
0.12
0
Ib/hr.
su2
0.22
8.9
0
6.3
0
1.37
641.9
2.05
Emission Limit
lb/in6Btu
Part.
0.26
0.59
0.72
0.52
0.56
0.23
0.88
Ih/hr.
*)2
52.8
7.2
3.0
12.04
8.75
210.6
1.3
:uel Sw
tons/
Part.
89
19
0.8
11.2
31
265
7.1
ns After
itch
yr.
so2
1725
22.5
0.8
15.2
3R.3
1
460
/
5.7
Comments
Switch is from gas to lr; S oil.
These figures indicate the
emissions which would result
if the sources were to emit SO,
maximum quantity permitted
(in terms of lbs/106 Btu or
Ibs/hr.) by regulation.
-------
Table D-l (continued)
a Includes only sources with external combustion engines
b 1 974 data in NEDS as of November, 1 974
Note: aO The number of hours of operation are also from NEDS and are as follovs
• Stauffer Chemical = 8760
• Foote Mineral = 6240
• Baroid = 520
• Carl in Gold Mining * 2520
• AEC Nevada Test Si te = 8760
• Kennecott Copper Corporation = 4368
• Nevada Department of Highways = 8760
b) Heat content of fuels assumed to be
Gas = 1000 Btu per ft3
Oil = 140,000 Btu per gallon
Coal = 23 million Btu per ton
c) Gas in terms of million cubic feet
Oil in terms of thousand gallons
Coal in terms of thousand tons
c 1 972 data in NEDS as of November, 1 £74
Interstate; plants included are only those in the Nevada portion
-------
APPENDIX E. AREA SOURCE ASSESSMENT
The State of Nevada was found to have no area sources which could be
analyzed within the context of Section 4 of ESECA.
!43
-------
BIBLIOGRAPHY
(1) "1972 National Emissions Report", U.S. Environmental Protection
Agency, EPA-450/2-74-012.
(2) "Federal Air Quality Control Regions", U.S..Environmental Protection
Agency, Publication No. AP-102.
(3) "Compilation of Air Pollution Emission Factors, 2nd Edition", U.S.
Environmental Protection Agency, Air pollution Technical Publica-
tion AP-42, April 1973.
(4) SAROAD Data Bank, 1973 Information, U.S. Environmental Protection
Agency.
(5) "Monitoring and Air Quality Trends Report, 1972", U.S. Environmental
Protection Agency, EPA-450/1-73-004.
(6) "Air Quality Implementation Plan for the State of Nevada", January
28,1972.
!44
-------
TECHNICAL REPORT DATA
(Please read fHitructions on the reverse before completing)
1. REPORT NO.
EPA-450/3-75-007
2.
3. RECIPIENT'S XCCESSIOWNO.
4.
PLAN REVIEW FOR NEVADA AS
REQUIRED BY THE ENERGY SUPPLY AND ENVIRONMENTAL
COORDINATION ACT
5. REPORT DATE
February 1975
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
U.S. Environmental Protection Agency, Office of Air
Quality Planning and Standards, Research Triangle
Park, N.C., Regional Office IX, San Francisco,
California; and TRW, Inc. Redondo Beach, California
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
,68-02-1385'
12. SPONSORING AGENCY NAME AND ADDRESS
U.S. Environmental Protection Agency
Office of Air and Waste Management
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
13. TYPE OF REPORT AND PERIOD COVERED
Final
14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
16. ABSTRACT
Section IV of the Energy Supply and Environmental Coordination Act of 1974,
(ESECA) requires EPA to review each State Implementation Plan (SIP) to determine
if revisions can be made to control regulations for stationary fuel combustion
sources without 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.
17.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.lDENTIFIERS/OPEN ENDED TERMS
c. COSATI Field/Group
Air pollution
State implementation plans
18. DISTRIBUTION STATEMENT
Release unlimited
19. SECURITY CLASS (ThisReport)
Unclassified
21. NO. OF PAGES
43
20. SECURITY CLASS (Thispage)
Unclassified
22. PRICE
EPA Form 2220-1 (9-73)
45
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