EPA-450/3-75-032
March 1975
IMPLEMENTATION PLAN REVIEW
FOR
WISCONSIN
AS REQUIRED
BY
THE ENERGY SUPPLY
AND
ENVIRONMENTAL COORDINATION ACT
U. S. ENVIRONMENTAL PROTECTION AGENCY
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EPA-450/3-75-032
IMPLEMENTATION PLAN REVIEW
FOR
WISCONSIN
REQUIRED BY THE ENERGY SUPPLY AND ENVIRONMENTAL COORDINATION ACT
PREPARED BY THE FOLLOWING TASK FORCE:
U. S. Environmental Protection Agency, Region V
230 South 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
March 1975
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WISCONSIN
ENERGY SUPPLY AND ENVIRONMENTAL COORDINATION ACT
SECTION TV - STATE IMPLEMENTATION PLAN REVIEW
Table of Contents
Page
1.0 EXECUTIVE SUMMARY 5
2.0 WISCONSIN STATE IMPLEMENTATION PLAN REVIEW 11
2.1 Summary 11
2.2 Air Quality Setting for the State of Wisconsin 12
2.3 Background on the Development of the Current
State Implementation Plan 17
2.4 Special Considerations for the State of Wisconsin .... 19
3.0 AIR QUALITY CONTROL REGION ASSESSMENTS 20
3.1 General Methodology 20
3.2 Metropolitan Dubuque Interstate AQCR (#68) 22
3.3 Rockford-Janesville-Beloit Interstate AQCR (#73) .... 22
3.4 Southeast Minnesota-La Crosse Interstate AQCR (#128) . . 23
3.5 Duluth-Superior Interstate AQCR (#129) 23
3.6 Lake Michigan Intrastate AQCR (#237) 24
3.7 North Central Wisconsin Intrastate AQCR (#238) 24
3.8 Southeastern Wisconsin Intrastate AQCR (#239) 25
3.9 Southern Wisconsin Intrastate AQCR (#240) 26
APPENDICES
APPENDIX A State Implementation Plan Background
APPENDIX B - Regional Air Quality Assessment
APPENDIX C - Power Plant Assessment
APPENDIX D - Industrial, Conmercial, 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 WISCONSIN
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 Implemen-
tation 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 dis-
approve 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
wherever possible SIPs 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, of encouraging states to
either defer compliance with regulations or to revise the S02 emission regu-
lations. The states have also been asked to discourage large-scale shifts
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from coal to oil where this could be done without jeopardizing the attain-
ment and maintenance of the NAAQS.
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 con-
ducted 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 suJ fur coal would bo 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, how-
ever, represent EPA's best judgment and effort in complying with the ESECA
requirements. The time and resources which EPA has had to prepare the
reports has not permitted the consideration of growth, economics, and
control strategy tradeoffs. Also, there has been only limited dispersion
modeling data available by which to address individual point source emis-
sions. 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 that 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 from fuel combustion sources into
perspective with all sources of emissions such as smelters or other indus-
trial processes. States are encouraged to consider the overall impact which
the potential relaxation of overly restrictive emissions regulations for
combustion sources might have on their future control programs. This may
include air quality maintenance, prevention of significant deterioration,
increased TSP, NOX, and HC emissions which occur in fuel switching, and
other potential air pollution situations such as sulfates.
Although the enclosed analysis has attempted to address the attainment
of all the NAAQS, most of the review has focused on total suspended paniculate
matter (TSP) and sulfur dioxide (S02) emissions. This is because stationary
fuel combustion sources constitute the greatest source of S02 emissions and
are a major source of TSP emissions.
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Part of each state's review was organized to provide an analysis of the
S02 and TSP emission tolerances within each of the various 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 limita-
tion 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 principle findings for the State of Wisconsin.
(Air Quality Control Regions are displayed on Fig. 1-1.)
• The state adopted the original federal National Ambient Air
Quality Standards for both total suspended particulates and
sulfur dioxide. Two of these standards for sulfur dioxide
are no longer in effect at the federal level but still exist
as state standards. The state, however, is currently con-
sidering deleting the two standards. After the deletion,
the state standards would be equivalent to the federal
standards.
• Wisconsin used a modified example region approach to develop
particulate regulations. Southeastern Wisconsin (#239) was
used as an example region to demonstrate primary annual stan-
dard attainment throughout the state. A dispersion model was
used there and also showed that the secondary annual standard
would be met. In subregion 1 (Brown, Outagamie, and Winnebago
Counties) of the Lake Michigan AQCR (#237), rollback was used
to show that under the proposed regulations the secondary annual
standard would be attained. In the other six AQCRs, the Rock
County portion of the Rockford-Janesville-Beloit AQCR (#73) served
as an example region to demonstrate attainment of the secondary
annual particulate standard. Only Southeastern Wisconsin (#239)
showed the need for sulfur dioxide emissions controls and disper-
sion modeling was used there to demonstrate the sufficiency of
the regulations"^~
• In all Wisconsin AQCRs there are reported high particulate levels
(based on 1973 data except in the Southern Wisconsin AQCR #240
where more recent local data was used) or levels sufficiently
close to the standards to indicate only a small margin for an
emission increase. There appears to be a sufficient number of
monitoring sites to support this conclusion but in Rockford-
Janesville-Beloit (#73) some sites did not report an annual
average.
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DULUTH
SUPERIOR
INTERSTATE
(MINNESOTA
WISCONSIN)
(#129)
(#238J
NORTH CENTRAL
WISCONSIN
INTRASTATE
(#237)
LAKE MICHIGAN
RASTATE
SOUTHEAST
LA CROSS
INTERSTATE
(MINNESOTA-
WISCONSIN)
(#128)
METROPOLITAN
DUBUQUE
INTERSTATE
(ILLINOIS-
IOWA-
WISCONSIN)
(#68)
SOUTHERN
WISCONSIN
INTRASTATE
(#240)
ROCKFORD-
JANESVILLE-
BELOIT
INTERSTATE
(ILLINOIS-
(#239)
SOUTHEASTERN
WISCONSIN
INTRASTATE
WISCONSIN) (#73)
Figure 1-1. Wisconsin Air Quality Control Regions (AQCRs)
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10
Except in the Southeastern Wisconsin AQCR (#239) where the state
regulation prohibits coal burning for small (less than 250 million
BTUs per hour) fuel combustion sources, the state particulate
regulations would not keep a large source from switching from oil
or gas to coal, since the particulate emissions limits can be
met with suitable control equipment. In Southeastern Wisconsin
(#239), high particulate levels suggest that the existing
regulations should not be relaxed.
There are indications (based on 1973 data) of a significant
tolerance for increased sulfur dioxide emissions in all AQCRs
in Wisconsin. The number of monitors appears to be sufficient
but there are no annual average data from Metropolitan Dubuque
(#68) and North Central Wisconsin (#238).
The state of Wisconsin does not regulate the sulfur content of
normal fuels for existing, unmodified fuel combustion sources
except when such sources can be shown to contribute substantially
to the violation of an air standard. New and/or modified sources
with heat inputs greater than 250 million BTUs per hour must meet
a limit equivalent to the federal New Source Performance Standards.
The sulfur content of standby fuels is regulated but proposed
regulation revisions would place this limitation in effect only
for the Southeastern Wisconsin AQCR (#239).
Most of the coal used by Wisconsin power plants and industrial/
commercial/institutional point sources is already high (greater
than 2 percent) sulfur coal. Only in the Southern Wisconsin
AQCR (#240) does a large fraction of the projected coal consumption
for these sources contain 1 percent or less sulfur, and there the
low sulfur coal is programmed to be used at the large Columbia 1
power plant scheduled to come on line in 1975.
Given the last two conclusions, there is little reason for Wisconsin
to consider revising its sulfur regulations.
Some fuel burning installations in Wisconsin have already converted
from clean fuels to coal and plans for other conversions are underway,
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2.0 WISCONSIN 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 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?
• Must the regulations be revised to accomplish significant fuels
switching?
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
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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12
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 Wisconsin
2.2.1 Wisconsin Air Pollution Control Areas
The state of Wisconsin is divided into eight Air Quality Control
Regions as shown in Fig. 1-1. There are four intrastate and four interstate
regions. Table A-l gives the pollutant priority classifications for each
of these eight regions. This table also shows the population and population
density to be largest in the Southeastern Wisconsin AQCR (#239). Based on
present conditions and growth projections for the state, some ten counties
have been proposed as Air Quality Maintenance Areas (ACMAs) for particulates
and seven for sulfur dioxide. These are shown in Table A-l and Fig. A-l.
2.2.2 Wisconsin Ambient Air Quality Standards
As s-hown in Table A-2, Wisconsin has adopted all the original federal
primary and secondary National Ambient Air Quality Standards for particulates,
sulfur dioxide and nitrogen dioxide. Since the adoption of these standards
the secondary annual and 24-hour sulfur dioxide standards have been rescinded
at the federal level but remain in effect at the state level. The state is,
however, currently considering deleting these two standards so that the state
and federal standards would be equivalent. In the analysis to follow,
however, only attainment of the present federal NAAQS will be considered.
2.2.3 Wisconsin Air Quality Status
The current air quality status in Wisconsin is summarized in Table A-3
for particulates and in Table A-4 for sulfur dioxide. All data came from the
SAROAD data bank as of June, 1974.
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Table 2-1. State Implemer.tation Plan Review Summary for Wisconsin
State
Metropolitan Rockford-Janesville- Southeast
Dubuquea Beloita Minnesota-LaCrossea Duluth-Superior3
AQCR>68 AQCR £73 AQCRS12S AQ.CR #129'
"INDICATORS"
• Does the State Iiave air quality standards which are more
stringent than NAAQS?
• Does 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?
• 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 monitor-
ing sites within a region?
• Is there an expected 1975 attainment date for NAAQS?
• Based on (1973) Air Quality Data, are there no reported
violations of NAAQS?
• Based on (1973) Air Quality Data, are there indications
of a significant tolerance for increasing emissions?
• Arc the emissions from stationary fuel combustion sources
a relatively small portion of the regional total?
• Do modeling results for specific fuel combustion sources
show a potential for a regulation revision?
• Is there a significant Clean Fuels Saving potential in
the region?
• Mu^t the regulations be revised to accomplish signifi-
cant fuel switching?
• B;ised on the above indicators, what is the potential for
revising fuel combustion source emission limiting
regulations?
TSP S02
No
Yes
Yes
Yes
Yes
Yes
Yes1
No
No
No
Nob
Yesn
TSP S02
Yesf
Yes
Yes
No
No
No
N.A.
Yes
v h
Yes
Yes
Yes1
Yes
No
N.A.
No
No
TSP - Poor
S02 - Poor
TSP S02
Example
Region0
Yes
Yesh
Yes
Yes1*
No
Yes
N.A.
Yes
Yes
Yes
Yes
Yes
No
N.A.
No
No
TSP - Poor
SO, - Poor
TSP S02
Yes
Yes
Yes
No
No
No
N.A.
Yes
Yes
Yes
Yes
Yes
No
No
No
No
TSP - Poor
SO - Poor
TSP S02
Yesg
Yes
Yes
No-
No
Yes
N.A.
Yes
Yes
Yes
Yes
Yes
Yes
N.A.
No
No
TSP - Poor
SO - Poor
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Table 2-1. State Implementation Plan Review Summary for Wisconsin (Contd.)
North Central Southeastern . Southern
Lake Michigan Wisconsin Wisconsin V.'isconsin
AQCR #237 AQCR "2.38 AQCP. J239 AQCR f 240
"INDICATORS"
• Docs the Stafe have air quality standards which arc more
stringent th;m NAAQS?
• Does '.he State have emission limiting; regulations for
control of:
1. Power plants
2. Industrial sources
3. Area sources
• Did the State use an example I'cgion approach for demon-
strati.ng the attainment of NAAQS or more stringent State
standards?
• lias 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 monitor-
ing sites within a region?
• Is there an expected 1975 attainment date for NAAQS?
• Based on (1973) Air Quality Data, are there no reported
violations of NAAQS?
• Based on (1973) Air Quality Data, are there indications
of a significant tolerance for increasing emissions?
• Are the emissions from stationary fuel combustion sources
a relatively small portion of the regional total?
• Do modeling results for specific fuel combustion sources
show a potential for a regulation revision?
• Is there a significant Clean Fuels Saving potential in
the region?
• Must the regulations be revised to accomplish signifi-
cant fuel switching?
• Based on the above indicators , what is the potential for
revising fuel combustion source emission limiting
regulal ions?
TSP S02
d
No
Yes
Yes
No
No
No
N.A.
Yes
Yes
Yes
Yes
Yes
No
N.A.
No
No
TSP - Poor
S02 - Poor
T.SI1 SO
L,
Yes
Yes
Yes
No
No
No
N.A.
Yes
Yesh
Yes
Yes1
Yes
No
N.A.
No
No
TSP - Poor
S02 - Poor
TSP so^
Hxainple
Region0
No
Yes
Yes
No
No
No
N.A.
!
i
i
No
Yesh
Yes
Yesk
Yesk
No
No
No
Yes^
TSP - Poor
S02 - Poor
TSP S0?
Yes
Yes
Yes
Yes
Yesm
No
N.A.
Yes
Yes
Yes
Yes
Yes
No
No
No
No
TSP - Poor
S02 - Poor
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Table 2-1. State Implementation Plan Review Summary for Wisconsin (Contd.)
Footnotes
Interstate .
Only the Southeastern Wisconsin AQCR (#239) required control of sulfur oxides.
Tlock County used as example region to demonstrate secondary standard attainment in all
AQCR's except in Lake Michigan (#237) and Southeastern Wisconsin (#239) .
Tlollback used to demonstrate secondary standard attainment.
G
Example region to demonstrate primary standard attainment in all AQCR's.
There is a proposed AQMA in the Iowa portion of this region.
%here is a proposed AQMA in the Minnesota portion of this region.
uiere are indicators of a sufficient number of monitors but not all are reporting
an annual average.
"""No annual data. i-1
, en
-'Present regulation allows no coal burning for sources < 250 x 10 BTU/hr in this AQCR.
iVfore recent local air quality data indicate that there are NAAQS violations in this
region.
Wisconsin is presently considering adopting S02 standards equivalent to the NAAQS.
M^re recent local air quality data indicate that the tolerance for increased emissions
may be small.
fuel burning installations have already converted from clean fuels to coal. Plans
for other conversions are underway.
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16
Violations of paniculate NAAQS are found in all regions except
except Southern Wisconsin (#240). In the other seven AQCRs, high particu-
late levels show little regional ability to absorb increased particulate
emissions. This conclusion is strengthened by the proposed particulate
AQMAs in the Lake Michigan (#237) and Southeastern Wisconsin (#239) AQCRs,
indicating expected problems in maintaining acceptable air quality. There
is also a proposed particulate AQMA in the Iowa portion of Metropolitan
Dubuque (#68) and another in the Minnesota portion of Duluth-Superior (#129),
showing expected maintenance problems in these regions. Thus, with the
exception of Southern Wisconsin (#240), there are indications that particulate
emission regulation relaxation will not be possible without disrupting NAAQS
attainment and maintenance (see Table 2-1).
There are no above standard S02 levels recorded in the SAROAD data for
the state of Wisconsin. However, annual average data is lacking from Metro-
politan Dubuque (#68) and North Central Wisconsin (#238). There are thus
indications of a significant tolerance for increasing S02 emissions in all
Wisconsin's AQCRs. In Southeastern Wisconsin (#239), however, this result
must be qualified by the proposed S02 AQMAs indicating potential problems in
maintaining acceptable S02 air quality (see Table 2-1) .
2.2.4 Wisconsin Emissions Summary
Emission sources and emission rates are tabulated in Tables A-5 through
A-7.
In the eight AQCR area of which Wisconsin is a part, Wisconsin fuel
combustion sources account for over half of the total particulate emissions.
Except in Rockford-Janesville-Beloit (#73) and Duluth-Superior (#129), they
also contribute more than half of the total particulate emissions in each
region (see Table A-5). Electricity generation accounts for the largest
portion of the particulate emissions from Wisconsin sources in Metropolitan
Dubuque (#68) and Southeast Minnesota-La Crosse (#128) (see Table A-6).
Area sources contribute the largest fraction in Rockford-Janesville-Beloit (#73),
Duluth-Superior (#129), and Southern Wisconsin (#240). In the Lake Michigan
(#237) and Southeastern Wisconsin (#239) AQCRs both electricity generation
and area sources contribute about the same fraction of the particulate
emissions which fraction is substantially greater than that contributed by
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17
industrial/commercial/institutional point sources. Electricity generation,
industrial/commercial/institutional point sources, and area sources each
account for about the same fraction of particulate emissions in North
Central Wisconsin (#238).
Almost three quarters of the total SC>2 emissions come from Wisconsin
fuel combustion sources throughout the eight AQCR area. Electricity
generation emits the predominant fraction of the S02 from Wisconsin sources
in all AQCRs except North Central Wisconsin (#238) and Southern Wisconsin
(#240) (see Table A-7). In the former, industrial/commercial/institutional
point sources are the largest emitters; in the latter, area sources are the
largest emitters.
2.3 Background on the Development of the Current
State Implementation Plan
2.3.1 General Information
Wisconsin used a modified example region approach to demonstrate attain-
ment of particulate NAAQS. Three control strategies, P-l, P-2, and P-3, in
order of increasing stringency, were developed and modeled by an AQDM disper-
sion model in the Southeastern Wisconsin AQCR (#239). Strategy P-l was found
sufficient to attain the primary annual standard in this region which was then
taken as an example region to show that strategy P-l would insure primary
annual standard attainment throughout the state. Application of strategy P-3
was shown to result in meeting the secondary annual particulate NAAQS in
Southeastern Wisconsin (#239). Growth projections indicated that the NAAQS
would be maintained through 1975. In the Lake Michigan AQCR (#237), rollback
was used in the cities of Green Bay and Appleton to demonstrate the sufficiency
of strategy P-2 for attaining the annual secondary particulate standard. The
regulations contained in this strategy were to be applied in subregion 1
(Brown, Outagamie, and Winnebago Counties) of the region. In the remaining
six Wisconsin AQCRs, the Rock County portion of the Rockford-Janesville-
Beloit AQCR (#73) was used as an example region to demonstrate attainment of
the secondary annual particulate standard. Proportional rollback was used
in Rock County to show that the standard would be attained there. Only
in Southeastern Wisconsin (#239) were there indications of a necessity for
SO-/ emissions controls. In this region, an AQDM dispersion model was used
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18
to show attainment of the secondary annual S02 NAAQS. Control of a coke
plant and conversion of one large boiler from coal were shown sufficient
to attain the primary annual standard. To attain the secondary annual
standard which has since been rescinded at the federal but not the state
level, conversion of small and medium sized boilers from coal, as required
to meet the particulate regulations, was shown to be necessary. The
Wisconsin SIP addressed neither the attainment nor the maintenance of the
short term TSP and S02 NAAQS.
2.3.2 Particulate Control Strategy
The control strategy for particulate emissions from fuel combustion
sources consists of enforcement of the applicable sections of the Air
Pollution Control Rules of the Wisconsin Department of Natural Resources.
Specific rules apply to both visible emissions and mass emissions rates.
These regulations are summarized in Table A-9 and Fig. A-2 and were designed
to meet both the primary and secondary annual particulate NAAQS. More
stringent limits apply in subregion 1 (Brown, Outagamie, and Winnebago
Counties) of the Lake Michigan AQCR (#237) and in the Southeastern Wisconsin
AQCR (#239) than apply in the remainder of the state. No coal can be used
by small (< 250 million BTUs per hour) sources in Southeastern Wisconsin
(#239). There is a provision for the imposition of more stringent limitations
if air standards are violated.
2.3.3 Sulfur Dioxide Control Strategy
The regulations for S02 emissions are summarized in Table A-9. Specific
emission limits apply only to new and modified sources. These limits are
equivalent to the federal New Source Performance Standards. The sulfur
content of standby fuels is regulated but revised rules would place this
limitation in effect only in the Southeastern Wisconsin AQCR (#239). Fuel
conversions necessary to attain standards in Southeastern Wisconsin (#239)
could come about when small and medium sized boilers switched from coal to
meet particulate standards. Specific limitations could be imposed on an
existing source by demonstrating that it contributed substantially to
exceeding an air standard. Wisconsin's SIP showed that these regulations
would result in meeting the annual secondary NAAQS, which has since been
rescinded at the federal level, throughout the state.
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19
2.4 Special Considerations for the State of Wisconsin
2.4.1 Planned SIP Revisions
Wisconsin is presently not considering changing its State Implementation
Plan with respect to fuel combustion sources.
2.4.2 Fuels
No coal is mined in Wisconsin and the state is not a large fuel user
compared to large industrialized states. Statewide, about 90% of the
heat input for power plants and over three quarters of the heat input for
industrial/commercial/institutional point sources come from coal. For
area sources, over 25% of the heat input comes from oil of which almost
95% is distillate oil and over two thirds of the heat input comes from
natural gas.
2.4.3 Fuel Conversions
The Federal Energy Administration has identified the Weston power
plant in North Central Wisconsin (#238) as having the potential to switch
from oil burning to coal burning.
Some fuel burning installations in Wisconsin have already converted
from clean fuels to coal. Plans for other conversions are underway.
-------
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 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 Section 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
classification. Note that this evaluation is based strictly on air quality
considerations. 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 in the tables in Appendix C. All existing and
proposed plants are reviewed to determine the clean fuel requirements
imposed by the existing regulations. Where dispersion modeling data
-------
21
are available, the maximum allowable fuel sulfur content which 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 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 regulations did not begin nationwide until 1972; there-
fore 1971 represents consumption patterns which 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 data ' and emission data ' are
drawn from both published and unpublished sources.
The third consideration for each AQCR is the assessment of large
industrial/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 assessments. 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 for 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
summary table is 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 Section 1. An AQCR
is determined to be a good candidate for emission limit regulation revision
-------
22
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 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 evalua-
tions 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 Metropolitan Dubuque Interstate AQCR (#68)
Metropolitan Dubuque (#68) is a poor candidate for particulate
regulation relaxation. Based on regional air quality data there are high
particulate levels and rollback indicates that a significant reduction in
emissions is needed to attain acceptable air quality (see Tables A-3, A-8,
and 2-1). Although there are no proposed AQMAs in the Wisconsin portion
of the region, one has been proposed in Iowa showing existing or expected
air quality problems in the region (see Tables B-l and 2-1).
This region is also a poor candidate for relaxation of S02 emission
regulations. Although there are indications of a significant capacity to
absorb increased S02 emissions, no annual average data is available (see
Tables A-4, A-8, and 2-1) and the major point sources in the region are
already using high sulfur coal (< 2% S, see Table F-l). Wisconsin does not
regulate the sulfur content of the fuels for existing, unmodified sources
or small (< 250 million BTUs per hour) new sources. Small area sources
are not regulated and fuel use figures for these sources are given in
Table E-l.
3.3 Rockford-Janesville-Beloit Interstate AQCR (#73)
Although there are no reported high particulate levels in SARQAD the
indications are that a significant ability to absorb increased particulate
emissions does not exist (see Tables A-3, A-8, and 2-1). Annual average
data is unavailable in SAROAD and recent local data indicate that there
are NAAQS violations. Even though the emissions from fuel combustion are
-------
23
a relatively small fraction of the regional total (see Tables A-5 and
2-1), there is little potential to shift from oil to coal (see Table F-l).
The region is thus a poor candidate for particulate emission regulation
relaxation.
Although there are indications of acceptable S02 air quality and a
significant tolerance for increasing emissions (see Table A-4, A-8, and
2-1), this region is a poor candidate for S02 emission regulation relaxation.
All major point sources already burn high (> 21) sulfur coal (see Table F-l).
No specific sulfur emission limits presently apply to existing unmodified,
and small (< 250 million BTUs per hour) new sources. Fuels with any sulfur
content may be used as long as air standards are not violated. Small area
sources are not regulated and fuel use figures for these sources are given
in Table E-l.
3.4 Southeast Minnesota LaCrosse Interstate AQCR (#128)
Existing high particulate levels and rollback estimates showing that an
overall large emission reduction is required to attain the NAAQS make this
region a poor candidate for particulate emission regulation relaxation.
The region is also a poor candidate for SC>2 emission regulation relaxa-
tion. Modeling results for specific power plants indicate that high (> 3%)
sulfur coal (see Table C-l) can continue to be used. Almost all coal presently
used is high (> 2%) sulfur content. No specific sulfur emission limits apply
to existing and small (< 250 million BTUs per hour) new sources. Fuels with
any sulfur contents may be burned providing air standards are not violated.
3.5 Duluth-Superior Interstate AQCR (#129)
There are indications of high particulate levels in this AQCR. Although
there are no proposed particulate AQMAs in the Wisconsin portion of the region,
there is one in the Minnesota portion, suggesting existing or anticipated
problems in maintaining acceptable air quality. Even though Wisconsin fuel
combustion sources contribute only a small fraction of the regional particulate
emissions, the large percentage reduction needed to meet the ambient standards
suggests that regulations should not be relaxed. The region is a poor candi-
date for particulate emission regulation relaxation.
-------
24
The Duluth-Superior region shows no high S02 levels and a substantial
ability to absorb increased SC>2 emissions based on rollback calculations.
However, since Wisconsin does not regulate the sulfur contents of fuels for
existing and small (< 250 million BTUs per hour) new fuel combustion sources
and since most of the coal used by point sources is already of high (> 21)
sulfur content, there is little reason to consider relaxing the regulations.
Small area sources are not regulated. Fuel use by area sources is given in
Table E-l.
3.6 Lake Michigan Intrastate AQCR (#257)
High particulate levels are reported in this region and rollback calcu-
lations suggest that a reduction in regional emissions is necessary to meet
the particulate NAAQS. Particulate ACMAs have also been proposed indicating
expected problems in maintaining low particulate levels. Since fuel combus-
tion accounts for over 90% of the region's particulate emissions, any
relaxation would have a significant impact on air quality- The region is
thus a poor candidate for particulate emission regulation relaxation.
This AQCR is a poor candidate for S02 emission regulation relaxation.
About 85% of the coal used by power plants and industrial/commercial/
institutional point sources is already high sulfur coal (> 21 S) . Although
rollback indicates an ability to absorb increased S02 emissions, there are
no regulations limiting emissions for existing and small (< 250 million BTUs
per hour) new sources unless a source is contributing to an air standard vio-
lation. Table E-l gives fuel use figures for small area sources whose fuel
contents are not regulated.
3.7 North Central Wisconsin Intrastate AQCR (#238)
High particulate levels have been recorded in this region and rollback
indicates that a substantial reduction in regional particulate emissions is
necessary to attain acceptable air quality. Almost three quarters of the
region's particulate emissions come from fuel combustion sources which
thus have a significant impact on air quality. Therefore, the region is
a poor candidate for particulate emission regulation relaxation.
-------
25
The Federal Energy Administration has identified the Weston power
plant as capable of switching from oil to coal firing. Such a switch
would have to be thoroughly investigated in view of the indications of
high particulate levels.
In this region there appears to be a significant tolerance for
increased S02 emissions but no annual average data are available. Fuel
combustion sources account for over 75% of the region's S02 emissions making
them an important factor in determining S02 air quality. Over 80% of the
coal burned by point sources is high (> 2%) sulfur coal and the sulfur con-
tent of fuels is not regulated for existing, unmodified sources and small
(< 250 million BTUs per hour) new sources. Thus, North Central Wisconsin
is a poor candidate for S02 emission regulation relaxation. Small area
sources are not regulated and fuel use figures for them are given in Table F-l.
3.8 Southeastern Wisconsin Intrastate AQCR (#239)
There are indications of high particulate levels in this region and
rollback calculations show no regional tolerance for increased emissions.
The proposal of particulate AQMAs reinforces the suggestions of existing or
expected particulate air quality problems. Fuel combustion sources should
have a significant impact on air quality, as they contribute almost three
fourths of the regional particulate emissions. Coal burning is presently
prohobited for small (< 250 million BTUs per hour) combustion sources in
this region. In view of the poor air quality and large potential impact of
increased emissions, this region is a poor candidate for particulate emission
regulation relaxation.
Southeastern Wisconsin (#239) is a poor candidate for S02 emission
regulation relaxation. All the coal presently being burned by power plants
and large industrial/commercial/institutional point sources has high (> 2%)
sulfur content. Modeling results do indicate, however, that some violations
of the primary 24-hour S02 NAAQS may occur in the vicinity of some power
plants with present coals (see Table C-l). Further analysis of this
situation is indicated particularly since the proposal of S02 AQMAs suggests
expected difficulties maintaining acceptable air quality. Although no high
S02 levels are reported in SAROAD, more recent local air quality data show
violations of NAAQS. Also, the fact that over 90% of the region's S02
-------
26
emissions come from fuel combustion reinforces the expectation of a
maintenance problem. The sulfur content of fuels for existing, unmodified
and small (< 250 million BTUs per hour) new sources is not presently regulated
by the state of Wisconsin. Small area sources cannot burn coal but the
sulfur content of their fuels is unregulated. Fuel use figures for these
sources are given in Table E-l.
3.9 Southern Wisconsin Intrastate AQCR (#240)
Although there are indications of acceptable air quality and although
rollback suggests a tolerance for increased particulate emissions based on
data in SAROAD, the insignificant clean fuels saving potential makes this
region a poor candidate for particulate emission regulation relaxation. In
addition, recent local air quality data indicate that TSP levels are quite
close to NAAQS and that the tolerance for increased particulate emissions
may be small. Little oil and gas are used in power plants and industrial/
commercial/institutional point sources in Southern Wisconsin (#240) (see
Tables C-2 and D-2). Hence, little saving of these fuels would be gained
by switching to coal. Although area sources are not prohibited from using
coal, it is unlikely that many of them possess coal burning capability.
This region is unique among Wisconsin AQCRs in showing a significant
use of low sulfur coal (< 1% S) by 1975. This coal is programmed for use
in the new Columbia 1 power plant. This plant falls into the group of large,
new plants for which Wisconsin has S02 emission limits. Air quality is
acceptable and rollback indicates a significant regional tolerance for
increased emissions. Modeling results for the Columbia plant suggest that
the programmed coal should not cause air quality problems. However, since
the plant will probably have to meet federal New Source Performance Standards,
there is little to be gained by changing the emissions regulations. For
existing, unmodified and small (< 250 million BTUs per hour) new sources,
Wisconsin does not limit S02 emissions and they are already using mostly
high (> 2%) sulfur coal. The region is thus a poor candidate for S02
emission regulation relaxation. Area sources are not regulated as to S02
emissions and area source fuel use figures are given in Table E-l.
-------
APPENDIX A
State Implementation Plan Background
-------
Table A-l. Wisconsin Air Pollution Control Areas
Demographic Information
Air Quality
Control Region
Metropolitan Dubuque
(111., la.)
Rockford-Janesville-Beloit
(111.)
Southeast Minnesota-
La Crosse (Minn.)
Duluth- Superior (Minn.)
Lake Michigan
North Central Wisconsin
Southeastern Wisconsin
Southern Wisconsin
Federal
Number
68
73
128
129
237
238
259
240
Population
1970
(Millions)
202.7
568.8
1,113.6
486.5
915.8
328.3
1,762.1
581.1
Area
(Square
Miles)
3,788
3,485
24,073
28,557
10,415
9,840
2,622
6,841
Populat i.on
Per Squire
Mile
54
163
46
17
88
33
672
85
Priority
Classification
Parti-
culates
I
II
II
I
II
II
I
II
sox
III
III
IA
II
III
III
II
III
N0x
III
III
III
III
III
III
III
III
Proposed
AQMA Designations3
SO
TSP Counties x Counties
CO)
CO)
CO)
CO)
(3) Brown, Outagamie,
Winnebago
CO)
(7) Kenosha, Milwaukee,
Ozaukee, Racine,
Walworth, Washington,
Waukesha
CO)
CO)
CO)
(0)
CO)
(0)
CO)
(7) Kenosha, Mil-
waukee, Ozaukee,
Racine, Walworth,
Washington,
Waukesha
CO)
As of January, 1975.
-------
LEGEND
® Places of 100,000 or more inhabitants
• Places ol 50,000 to 100,000 inhabitants
D Central citits of SMS* j Kith le«er thin 50.000 inhabitants
O Pieces of 25,000 10 50,000 inhabitants outside SMS* J
I Standard Metropolitan
Statistical Areas ISMS* s)
DULUTH SUPERIOR
OUUTN®:
DESIGNATION
DESIGNATION
LA CROSSE
*a
I* CBOSU-3
[w graa
•MTMTTI I ?JIJ"lOWD "" WCO
Figure A-1. Proposed Wisconsin Air Quality Maintenance Areas (AQMAs)
-------
Table A-2. Wisconsin Ambient Air Quality Standards
All concentrations in ygm/nr
Federal
State
Primary
Secondary
Primary
Secondary
Total Suspended
Annual
75 (G)
60 (G)
75 (G)
60 (G)
Particulate
24 -Hr
260a
150a
260a
150a
Sulfur Dioxide
Annual 24-Hr 3-Hr
80 (A]
80 (A)
60 (A)
365a
365a
260a
1300a
1300a
Nitrogen Dioxide
Annual
100 (A)
100 (A)
100 (A)
100 (A)
Not to be exceeded more than once per year.
(A) Arithmetic mean
(G) Geometric mean
-------
Table A-3. Wisconsin AQCR Air Quality Status, TSP
TSP Concentration (pgrn/m )
Number of Stations Exceeding
Ambient Air Quality Standards
AQCR
No.
68b
73b
128b
129b
237
238
239
240
No. Stations
Reporting
24-Hr Annual
6 1
4 0
17 11
32 16
17 11
6 3
30 19
9 7
Highest Reading
Annual 24-Hr
31 215
190
77 342
81 522
64 192
28 656
81 359
47 138
a!973 air quality data in National Air Data Bank
Interstate
violations
Formula:
Maximum of
2nd Highest Reading
24-Hr
206
141
228
283
159
633
297
129
as of June 7, 1.974.
Primary
Annual 24-Hrc
0 0
0
1 0
3 1
0 0
0 1
1 1
o o'
Secondary 1 Reduct
Annual
0
-
3
7
1
0
4
0
to Mee
24-Hrc
2 +
oe
6 +
15 +
3 +
1 +
7 +
Of
ion Required Controlling
t Standards" Standard
33 24-Hr
f 24-Hre
42 Annual
54 ' 24-Hr
14 Annual
81 24-Hr
56 24-Hr
23 f 24-Hr
based on 2nd highest reading any any station.
(2nd Highest
\ 2nd
24-Hr - 24-Hr Secondary Standard j
Highest 24-Hr - Background / X IOJ>
[Annual
\
- Annual
Annual
Secondary Standard j
- Background / x 10°
Wisconsin particulate background concentration: 36'ugm/m0
T>tore recent local air quality data indicate that there are TSP >JAAQS violations in this region.
More recent local air quality data indicate that TSP levels may be close to NAAQS.
-------
Table A-4. Wisconsin AQCR Mr Quality Status, SO*
SO 3
2 Concentration (ugm/m )
Number of Stations Exce
Ambient Air Quality Standards
^Reduction Required , Controlling
to Meet Standards^ Standard
AQCR No
. Stations
Reporting
No. Annual 24-Hr Cont.
68b
73b
12 8b
129b
237
238
239
240
^973 air
0
1
4
1
3
0
2
6
quality
3
2
7
8
9
2
5
7
0
1
!
1
0
0
5
0
Highest
Annual
14
32
22
26
—
53
41
Reading
24-Hr
40
140
610
107
274
47
272
432
data in National Aerometric Data
2nd-Highest Reading Prinarv Secondary
2^-Hr Annual 24-Hr 3-Hrd
27 — 0 — -1,252 24-Hr
79 000 - 362 24-Hr
151 0 r 0 - 142 24-Hr
49 000 - 264 Annual
269 00 — - 36 24-Hr
45 — 0 — - 711 24-Hr
53 0 Oe 0 - 51 S Annual6
204 00 — - 79 24-Hr
Bank as of June 7, 1974.
Interstate.
'"Violations based
Formula:
Maximum oi
on
2nd highest
(2nd Highest 24-Hr
1 V
reading
at any station.
- 24-Hr Standard^
2nd Highest 24 -Hr
100 (Annual - Annual Standard) OQ
100 \ ' Annual / x 1UUJ
recent local air quality data indicate a possible NAAQS violation in this region.
-------
Table A-5. Wisconsin Fuel Combustion Source Summary-
Total Emissions
I Emissions from
AQCR
No.
68e
73e
128e
129e
237
238
239
240
Total
Power
Plants
2
2
4
2
4
2
7
3
26
Other Fuel Combustion Area
Point Sources Sources
0 1
2 1
3 16
4 10
9 17
9 11
0 7
3 9
30 72
(1(H t
TSP
22
33
129
110
117
60
140
27
638
ons/year)
S0?
58
69
157
137
195
77
279
31
1,003
Wisconsin Fuel Com!
TSP
45
50
55
6
91
75
70
78
58
)ustion Sources
S0?
78
45
69
10
98
78
91
97
73
TVisconsin plants.
Wisconsin plants contributing 90% of the particulate and SO,, emissions or 1,000 or more tons per year.
'"Wisconsin counties
dAQCR total
elnterstate.
-------
Table A-6. Wisconsin Emissions Summary , TSP
68 Wisconsin
Other
Total
73 Wisconsin
Other
Total
128 Wisconsin
Other
Total
129 Kiscoiisin
Other
Total
237
253
239
240
Total
Total
(105 tons/yr)
10
12
22
12
21
33
77
52
129
11
99
110
117
50
140
27
638
%
2
2
4
2
3
5
12
8
20
2
16
18
18
9
22
4
100
Electricity
(103 tons/yr)
9
2
11
2
5
7
47
2
49
2
18
20
38
16
52
1
194
Generation
90
21
52
17
22
20
61
4
38
19
18
.8
32
26
37
6
30
Industrial/Commercial/
Institutional Point Source
(104 tons/yr) %
0
1
1
1
< 1
1
9
1
10
1
19
20
24
15
4
1
0
10
5
6
2
3
11
2
7
14
19
18
20
25
3
5
76 U
Area Source
(103 tons/yr)
1
1
2
7
9
16
15
31
46
4
7
11
45
13
42
19
194
*
7
5
6
64
43
51
19
60
36
39
7
10
38
22
30
68
30
Emissions in National Emissions Data System data bank as of June 19'74.
-------
o
Table A-7. Wisconsin Emissions Summary , SCL
AQCR
68 Wisconsin
Other
Total
73 Wisconsin
Other
Total
12 S Wisconsin
Other
Total
129 Wisconsin
Other
Total
237
23S
239
240
Total
Total
(10 3 tons/yr)
45
13
58
32
37
69
110
47
157
17
120
137
195
77
279
31
1,003
4
1
5
3
4
7
11
5
16
2
12
14
19
8
28
3
100
Electricity
(10 tons/vrl
44
7
SI
22.
19
41
86
14
100
8
29
37
114
16
211
9
579
Generation
97
56
88
70
51
60
78
30
64
49
24
27
59
21
75
28
58
Industrial/ Commercial/
Institutional Point Source
(103 tons/yrl $
0
3
3
3
2
5
8
3
11
1
65
66
42
33
5
4
169
0
22
5
11
5
8
7
7
7
9
54
48
22
43
2
12
i;
Area Source
{103 tons/yr) *
1
2
3
6
15
21
15
28
43
5
15
20
36
11
37
17
188
2
14
5
18
40
30
14
59
27
27
13
15
19
15
13
55
19
^Emissions in National Emission Data System data bank as of June 1974
-------
Table A-8. Wisconsin Required Emissions Reduction0
AQCR
68b
73b
128b
129b
237
238
239
240
Estimated Particulate
1
+ 33
- 9
+ 42
+ 54
+ 14
+ 81
+ 56
- 23
Emission Reduction Required
10 3 tons /year
+ 7
- 3
+ 54
+ 59
+ 16
+ 49
+ 78
- 6
Estimated S02
%
- 1,252C
- 362°
142
264
36
711C
51
79
Emission Reduction Required
10 3 tons /year
- 726
- 250
- 223
- 362
- 70
- 547
- 142
- 24
Biased on a proportional change of emissions to air quality.
Interstate.
exceptionally large negative numbers indicate current air quality is very good. In this range, the
proportional calculations do not give a good picture of allowable emission increases. They are
included here only as general indicators.
-------
Table A-9. Wisconsin Fuel Coiibustion Emission Regulations3
Visible
Particulate
Matter
S02
Source ,
Category
I, III, IV
II
I
II
III
IV
Existing
New or
Modified
Normal Fuel
< Ringelmann #1 or 201; opacity except:
a. When equipment is being cleaned or a new fire started and then not to exceed
Ringelman #4 or 80$ opacity for 5 min in an) liour.
Limited to 3 times per day.
b. For equipment failures reported to the regulat.ing authority.
c. When uncorabined water vapor is the only reason for non-
comp] iance .
d. When permitted by t~, ' regulating authority.
e. Mien a stack test shows the applicable mass enission limits
are being met. In this case, a visible limit 0.5 Ringelmann
numbers or 104 opacity above the average opacity reading
during the test will apply.
< Ringelmann #2 or 40% opacity with same exceptions as for
Categories I, III, and IV.
- 250 x 106 BTU/hr > 250 x 106 BTU/hr
rv *. -j «™-n »->7nd Maximum of
Outside AQCR #239 Q_ls lb/1()6 BTO 0_lfl lb/1()6 ^
to any stack to any stack
Within AQCR £239 No coal and maximum of n ,„ nl,/in6 n-ni
0.10 lb/10' BTO w any sLk
to any stack to 3ny stacK
See Figure A-2 with a maximum limitation of 0.60 lbs/106 BTU to any stack
irrespective of height.
See Figure A-2 with a maximum limitation of 0.30 lbs/106 BTO to any stack
irrespective of height
< 250 x 10e BTU/hr > 250 x 106 BTU/hr
No coal arid maximum of Maximum of
0.15 lb/105 BTO C.15 lb/106 BTO
No person shall cause, suffer, allow, or permit emission of sulfur or
sulfur compounds into the ambient air which substantially contribute
i. 250 x 106 BTU/hr s 250 x 106 BTU/hr e
liquid fuel As f°r existing sources. 0.80 Ib SC^/IO6 BTO
solid fuel AS f°r existing sairces. 1.2 Ib S02 /106 BTU
Standby Puelc
Same as Category II, normal fuel.
contribute to the exceeding of
an standard or create air pollution.
Fuel Maximum t S
Distillate oil 0.70
aStricter ] units can apply where a source can be shown to contribute substantially to exceeding an air standard in a localized area.
I. Xciv- or modified sources throughout the state which were constructed or modified after April 1, 1972.
II. .All existing sources throughout the state.
III. Existing sources in subregion I of the Lake Michigan Intrastate AQCR *237: Brown, Outagamie, and Winnebago counties.
IV. Existing sources in the Southeast Wisconsin Intrastate AQCR #239.
cFuel normally used less than 15 days per year.
Southeast Wisconsin AQCR #239.
eThese are equivalent to the federal New Source Performance Standards. Based on total heat input from all fuels. For dual firing,
allowable emissions are average using these emission factors weighted by percentage of heat input from appropriate fuel category.
-------
1.5
1,0 —
i I i
i I i i i 11
CD
O
ce
UJ
Q_
CO
O
O
Q_
co
CO
CO
Z3
O
0,5
CATEGORY JI MAXIMUM__EMI^SION_LIM[T
(O,60lb/I06 Btu)
£ATEGORY_ m_ MA^IMUM^ EMISSION JJMIT
(O,30lb/I06 Btu)
ADAPTED FROM FIGURE 2 OF ASME
STANDARD NUMBER APS-I
0,1
I I I I I 11II I I I I I I II
STACK KEIGHT(FT)
ABOVE GRADE
I III I I 111 I II
10'
10'
TOTAL EQUIPMENT CAPACITY RATING (MILLION Btu PER HOUR INPUT)
Figure A-2. Allowable Particulate Emissions from Category II and Category III
Fuel Combustion Sources in Wisconsin.
-------
APPENDIX B
Regional Air Quality Assessment
-------
Table B-l. Wisconsin AQCR Candidacy Assessment for Particulate .Regulation Relaxation
AQCR
Nurber of
Stations Counties with
with. Particulate Expected Proposed Par- Total Particulate % Emissions Emission Reduction
Federal Air Quality Attainment ticulate Emissions from Wisconsin Fuel Required for NAAQS Particulate
Number Violationsa Date AQMA Designations (103 tons/yr) Combustion (103 tons/yr) Priority
Metropolitan
Dubuqueb
Rockford-Janes-
ville-Beloitb
Southeast Minnesota-
La Crosseb
Duluth-Superior
Lake Michigan
North Central
Wisconsin
Southeastern
Wisconsin
Southern
Wisconsin
68
73
128
129
237
238
239
240
2
. Oc'e
6
16
4
1
8
0
7/75
d
7/75
7/75
7/75
7/75
7/75
d
0
0
0
0
3
0
7
0
22
33
129
110
117
60
f
140
27
45
30
55
6
91
73
70
78
+ 7
- 3
+ 54
+ 59
+ 16
+ 49
+ 78
- 6
I
II
II
I
II
II
I
II
aTotal number of stations given on Table-A-3.
b.
Interstate.
cXo annual data.
A
Presently meeting standards.
recent local air quality data indicates that there are particulate NAAQS violations in this region.
-------
Table B-2. Wisconsin AQCR Candidacy Assessment for SO, Regulation Relaxation
Number of
Counties with
AQCR
Metropolitan
Dubuque D
Rockford- ,
Janesvil le-Beloit°
Southeast Minnesota-
LaCrosseb
Duluth-Superior!3
Lake Michigan
North Central
V'isconsin
Southeastern
Wisconsin
Southern
Wisconsin
Stations with
Federal S02 Air Quality
Number Violationsa
68 Oc
73 0
128 0
129 0
237 0
238 Oc
239 O6
240 0
Expected
AttaL. iient
Date
d
d
d
d
d
d
d
d
Proposed
S02 AQMA.
Designations
0
0
0
0
0
0
7
0
Total SC-2
Emissions
(10 3 tons/yr)
58
69
157
137
195
77
279
31
1 Emissions Emission Reduc-ion S02
from Wisconsin Fuel Required for NAAQS Priority
Combustion (103 tons/yr)
78
45
69
10
98
78
91
97
-726
-250
-223
-362
- 70
-547
-142
- 24
III
III
IA
II
III
III
II
III
iotal number of stations given in Table A-4.
'"Xo annual data.
Presently meeting standards.
eMore recent local air quality data indicate a possible S02 NAAQS viclation in this region.
-------
APPENDIX C
Power Plant Assessment
-------
Table C-l. Wisconsin Power Plant Assessment
AQCR
68d
73d
128d
129d
Plant
Nelson Dewey
Stoneman
Blackhawk
Rock River
Edison
French Island
Alma
Genoa #3
Bay Front
Wins low
1975
Capacity
(Mw)
227
52
50
150
6.5
25
188
346
80
25
-US LJJIlclLCU J.» / 3
Fuel Use
Fuel
Coal
Oil
Coal
Oil
Coal
Gas
Coal
Oil
Coal
Coal
Coal
Oil
Coal
Oil
Coal
Oil
Gas
Coal
Oil
Gas
Quantity a
565
13
124
104
7
2,523
378
34
2
33
562
288
723
1,073
383
588
1,486
3
6,090
51
% S Under % S Allowed
SIP b by c
Regulations Model
3.3
0.33
3.3
0.30
3.1
-
3.0
0.33
3.5
3.1 3.1
3.1 3.1
0.30
3.7 3.7
0.30
2.7
0.31
-
2.7
0.31
-
-------
Table C-l. Wisconsin Power Plant Assessment (Contd.)
AQCR
237
238
239
Plant
Edgewater
Pulliam
Manitowoc
Menasha
We s ton
Wildwood
Commerce St.
East Wells St.
Lakeside
North Oak Creek
Port Washington
South Oak Creek
1975
Capacity
477
392
69
29
135
42
35
15
310
500
400
1,192
uscxJiifctucu ±y i D
Fuel Use
Fuel
Coal
Oil
Coal
Oil
Gas
Coal
Coal
Coal
Oil
Gas
Coal
Oil
Gas
Coal
Oil
Oil
Gas
Coal
Oil
Coal
Coal
Oil
Quantity^
1,221
168
1,003
593
1
134
62
209
120
2,969
89
1,126
2,202
5
42
21,461
6,268
830
461
682
2,305
2,908
\ S Under % S Allowed
SIP b by
Regulations Model0
2.4
0.33
2.6
0.30
2.5
2.5
3.3
0.30
3.3
0.45
2.4
0.31
0.34
2.1 2.1f
0.30
3.0 3.0
2.1 2.1£
0.30
-------
Table C-l. Wisconsin Power Plant Assessment (Contd.)
AQCR
239
(Contd.)
240
Plant
Valley
Blount St.
Richland Center
Columbia 1^
1975
Capacity
(Mw)
239
196
14
527
us L_uiia.L«
Fuel
Fuel
Coal
Gas
Coal
Oil
Gas
Coal
Coal
3U. JL ^ / 0
Use
Quantity a
669
168
149
1,037
8,305
22
1,523
I S Under
SIP b
Regulations
3.1
3.1
0.28
-
3.1
0.7
% S Allowed
by c
Afodelc
3.1
_
-
-
-
0.6h
aCoal quantity in 103 tons/yr; oil quantity in 103 gal/yr; gas quantity in 106 ft3/yr. Estimates based
on 1971 fuel use patterns plus planned additions. If 1971 fuel use data were unavailable, 1972 data
were used.
Wisconsin regulations do not specify a %S limitation for existing, unmodified plants. The 1971 %S was
reported as SIP. If %S figures were unavailable the average for the Wisconsin portion of AQCR was used.
If the AQCR-wide average was unavailable the state-wide average was used.
cState of Wisconsin regulations do not specify a coal percent sulfur limitation for existing plants;
therefore, 1971 coal sulfur content was used and reported.
Interstate.
elncludes some fuel usage for uses other than electricity generation.
^Modeling calculations indicate that the 24-hour primary air quality standard may be exceeded even at SIP.
gNew plant in 1975.
Programmed coal %S is less than SIP requirements; therefore, programmed coal %S used.
-------
Table C-2. Wisconsin Power Plant Evaluation Summary
AQCR Fuel
68C Coal
Oil
73C Coal
Oil
Gas
128C Coal
Oil
129C Coal
Oil
Gas
237 Coal
Oil
Gas
238 Coal
Oil
Gas
239 Coal
Oil
Gas
1975 Fuel Required by
SIP Regulations a
< 1% 1-2% > 2%
689
117
385
34
2,523
1,320
1,361
386
6,678
1,537
2,420
761
1
298
120
2,969
4,491
25,998
8,638
1975 Fuel Required by
Modified Regulations b
< 11 1-2% > 2%
No modeling results available.
No modeling results available.
l,318d
No modeling results available.
No modeling results available.
No modeling results available.
4,486e
-------
Table C-2. Wisconsin Power Plant Evaluation Summary (Contd.)
AQCR Fuel
240 Coal
Oil
Gas
Wisconsin Coal
Total Oil
Gas
1975 Fuel Required by
SIP Regulations3
< n 1-2% > 2%
1,523 171
1,037
8,305
1,523 10,160
36,106
23,973
1975 Fuel Required by-
Modified Regulations^
< 1% 1-2% > 2%
1,523£
1,523 5,804
aCoal quantity in 103 tons/yr; oil quantity in 103 gal/yr; gas quantity in 106 ft3/yr. Estimates based on
1971 fuel use patterns plus planned additions. If 1971 fuel use data were unavailable, 1972 data were
used. Wisconsin regulations do not specify a IS limitation for existing, unmodified plants. The 1971 %S
was reported as SIP.
State of Wisconsin regulations do not specify a coal percent sulfur limitation for existing plants;
therefore, 1971 coal sulfur content was used and reported.
Interstate.
No modeling results available for small Edison plant with less than 2% of 1975 generating capacity in AQCR.
^o modeling results available for two small plants with 13% of the AQCR's 1975 generating capacity. Modeling
calculations indicate that the 24-hour primary air quality standard may be exceeded even at SIP.
f
At new (1975) Columbia 1 plant, programmed coal %S is less than SIP requirements; therefore, programmed coal
%S was used.
-------
APPENDIX D
Industrial, Commercial, Institutional Point Source Assessment
-------
Table D-l. Wisconsin Industrial/Commerical/Institutional Source Assessment
AQCR
68d
73d
128d
129d
237
Planta
No plants
Colt Industries
GM Assembly Division
St . Regis Paper
Foremost Foods Co.
Uniroyal Inc .
universal Oil Products
American Can Co.
Twin Ports Coop Dairy
Peavey Paper Mills
Nicolet Paper Co.
Fort Howard Paper Co.
Charmin Fox River Mill
Foremost Foods
Niagr a -Wisconsin
Paper Co.
Kimberly-Clark
Thilmany Pulp and
Paper Co.
Kohler Co.
John Strange Paper -
board
Fuel
Coal
Oil
Gas
Coal
Gas
Coal
Oil
Gas
Coal
Oil
Gas
Coal
Oil
Gas
Coal
Coal
Oil
Gas
Coal
Gas
Coal
Coal
Coal
Coal
Oil
Gas
Coal
Coal
Coal
Oil
Gas
Coal
Oil
Gas
Coal
Coal
Estimated
Fuel ,
Consumption
29
20
30
43
663
16
429
413
13
72
173
47
945
218
3
6
113
152
1
144
12
35
231
46
4,117
1,090
7
105
116
565
1,510
123
296
1,873
50
55
SIP
Regulations
% Sc
2.8
0.2
2.3
2.1
2.8
-
2.0
0.4
-
2.5
2.6
-
2.0
0.7
1.6
-
2.5
2.3
0.8
0.8
2'9e
0.3e
2.8
2.6
0.9
2.0
3.2
2.0
0.8
2.9
-------
Table D-l. Wisconsin Industrial/Commercial/Institutional Source Assessment (Contd.)
AQCR
238
239
240
Planta
Owens-Illinois Forest
Products Division
Ward Paper Co.
American Can Co.
Nbsine Paper Corp.
St. Regis
Consolidated Papers -
Biron Division
Consolidated Papers
Nekoosa Edwards
Nekoosa Edwards
No plants
Capitol Heat and
Power Plant
Oscar Mayer and Co.
Mendota State Hospital
Fuel
Coal
Oil
Gas
Coal
Coal
Oil
Coal
Oil
Gas
Coal
Coal
Coal
Coal
Gas
Coal
Gas
Coal
Coal
Oil
Gas
Coal
Estimated
Fuel ,
Consumption
92
1,495
873
11
167
3,050
62
167
390
55
139
153
9
1,680
87
32
10
35
240
530
17
SIP
Regulations
0, c
It O
2.8
1.2
2.3
2.7
3.0
2.1
3.5
-
0.7
3.8
1.0
2.9
-
2.9
1.9
2.9
1.0
-
1.9
Wisconsin plants contributing 90% of the AQCR's S02 or particulates or emitting
more than 1,000 tons/yr.
bCoal in 103 tons/yr; oil in 103 gal/yr; gas in 106 £t3/yr.
Sfisconsin regulations do not specify a percent sulfur in fuel limit for existing,
unmodified sources. The sulfur contents reported here are those presently being
used.
dT
Interstate
0
Average value for all oil consumed.
One of two Nekoosa Edwards plants in the AQCR.
-------
Table D-2. Wisconsin Industrial/Commercial/Institutional Source Evaluation Summary
Fuel
Required by Existing Regulations^
AQCR
68b
73b
128b
129b
237
238
239
240
Wisconsin
Total
Fuel
No plants
Coal
Oil
Gas
Coal
Oil
Gas
Coal
Oil
Gas
Coal
Oil
Gas
Coal
Oil
Gas
No plants
Coal
Oil
Gas
Coal
Oil
Gas
< 1%
20
693
72
804
6
296
432
4,117
4,473
55
2,975
530
493
4,209
9,771
1-2%
13
3
113
861
153
1,495
27
240
196
2,709
> 2%
72
63
1,374
13
336
567
3,217
35
1,086
4,591
Coal in 103 tons/yr; oil in 103 gal/yr; gas in 10 ft /yr. Wisconsin regulations
do not specify a percent sulfur in fuel limit for existing, unmodified sources.
The sulfur contents reported here are those presently being used.
Interstate
-------
APPENDIX E
Area Source Assessment
-------
Table E-l. Wisconsin Area Source Fuel Use
Coal
Residual Oil
Distillate Oil
Natural Gas
AQCR
68a
73a
128a
129a
237
238
239
240
Total
(103 tons/yr)
23
186
215
150
550
165
484
245
2,018
(10 3 gals/yr)
890
8,070
22,630
8,510
10,740
2,520
20,560
4,960
78,880
(10 3 gals/yr)
38,340
78,920
244,460
148,220
172,560
75,900
270,830
118,220
1,147,450
(10 6 ftVyr)
8,890
44,730
87,050
74,920
57,610
15,390
103,860
29,500
421,950
Interstate - Fuel use figure is for entire AQCR.
-------
APPENDIX F
Fuels Assessment
-------
Table F-l. Wisconsin Clean Fuels Analysis Summary
Existing Regulations Clean Fuel Requirements0
Minimum Clean Fuels Savings ,
Through Regulation Modification
AQCR
68C
73C
128C
129C
237
238
239
240
Wisconsin
Total
Fuel
Coal
Oil
Coal
Oil
Coal
Oil
Coal
Oil
Coal
Oil
Coal
Oil
Coal
Oil
Coal
Oil
Coal
Oil
< 1% S
117
54
1,433
6
6,678
432
4,878
55
120
25,998
1,523
1,037
2,016
40,315
1-2% S
13
3
113
861
153
1,495
27
240
196
2,709
> 21 S
689
457
1,383
1,374
399
2,756
865
3,217
4,491
206
11,246
4,591
< 1% S
No modeling
No modeling
No modeling
No modeling
No modeling
0
0
1-2% S > 2% S
results available
results available
0
results available
results available
results available
Od
0
0
aFor power plants (Table C-l) and industrial/commercial/institutional point sources (Table D-l) only. Coal in
10^ tons/yr; oil in 10^ gal/yr. Wisconsin regulations do not specify a fuel \ S limitation for existing,
unmodified plants. The 1971 \ S was used and reported as SIP. If 1971 data was unavailable, current I S was
hused.
Based on modeling results for power plants only. State of Wisconsin regulations do not specify a coal per-
cent sulfur limitation for existing plants; therefore, 1971 coal sulfur content was used and reported.
^Interstate
iVfodeling calculations indicate that the 24-hour primary air quality standard may be exceeded even at SIP.
-------
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, Wai den Research Division
of Abcor, Inc., Cambridge, Massachusetts, 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 SOa 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 Instructions on the reverse before completing)
1. REPORT NO.
EPA-450/3-75-032
2.
4. TITLE AND SUBTITLE
IMPLEMENTATION PLAN REVIEW FOR WISCONSIN
REQUIRED BY THE ENERGY SUPPLY AND ENVIRON
COORDINATION ACT
7. AUTHOR(S)
3. RECIPIENT'S ACCESSION-NO.
5. REPORT DATE
1ENTAL 6. PERFORMING ORGANIZATION CODE
8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORG "VNIZATION NAME AND ADDRESS
U.S. Environmental Protection Agency, Offi
Quality Planning and Standards, Research 1
N.C., Region V Office , Chicago, 111., and
National Laboratory, Argonne, 111.
12. SPONSORING AGENCY NAME AND ADDRESS
U.S. Environmental Protection Agency
Office of Air and Waste Management
Office of Air Quality Planning and Standai
Research Triangle Park, N.C. 27711
10. PROGRAM ELEMENT NO.
ce of Air
riangle Park, 11. CONTRACT/GRANT NO.
Argonne
13. TYPE OF REPORT AND PERIOD COVERED
14. SPONSORING AGENCY CODE
ds
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 CSIP) 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
a. DESCRIPTORS
Air pollution
State Implementation Plans
13. DISTRIBUTION STATEMENT
Release unlimited
b. IDENTIFIERS/OPEN ENDEDTERMS
19. SECURITY CLASS (This Report)
Unclassified
20. SECURITY CLASS (This page)
Unclassified
c. COS AT I Field/Group
21. NO. OF PAGES
56
22. PRICE
EPA Form 2220-1 (9-73)
------- |