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 ------- 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 ------- ------- 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 ------- ------- 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 ------- 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. ------- 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. ------- 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. ------- 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) ------- 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, ------- 11 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 ------- 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. ------- 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 ------- 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 ------- 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. ------- 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 ------- 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 ------- 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. ------- 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) ------- |