EPA-450/3-74-076

DECEMBER 1974
     IMPLEMENTATION PLAN REVIEW
                  FOR
                KANSAS
              AS REQUIRED
                   BY
          THE ENERGY  SUPPLY
                  AND
   ENVIRONMENTAL COORDINATION ACT
     U. S. ENVIRONMENTAL PROTECTION AGENCY

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                                                    EPA-450/3-74-076
                   IMPLEMENTATION PLAN REVIEW

                              FOR

                            KANSAS

REQUIRED: BY THE ENERGY SUPPLY AND ENVIRONMENTAL COORDINATION  ACT
             PREPARED BY THE FOLLOWING TASK FORCE:
      U.  S.  Environmental  Protection Agency,  Region VII
                   1735 Baltimore Avenue
               Kansas City, Missouri  64108


            Environmental  Services of TRW, Inc.
                  (Contract 68-02-1358)
          U.  S.  Environmental  Protection Agency
            Office of Air and  Waste Management
         Office  of Air Quality Planning and Standards
        Research Triangle Park, North Carolina  27711
                         December 1974

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                         TABLE OF CONTENTS
1.0  EXECUTIVE SUMMARY	1

2.0  STATE IMPLEMENTATION PLAN REVIEW 	   5

     2.1  Air Quality Setting - Kansas  	   8

     2.2  Kansas Participate Emissions	9

     2.3  Kansas S02 Emissions  	   9

     2.4  Background on Kansas SIP	10

3.0  AQCR ASSESSMENTS BASED ON SIP REVIEW AND CURRENT AIR QUALITY  .  12

     3.1  AQCR 094 - Metro Kansas City Interstate	12
                                     i
     3.2  Eastern Kansas AQCR's 095 (North East)  and  098 (South
          East)	14

     3.3  AQCR 099 (South Central)	16

     3.4  Western AQCR's 096, 097, and 100	17

     3.5  Special Consideration - Fossil  Fuels (Table F-3)	17



     APPENDIX A - Background Information  on SIP,  Air  Quality,
                  Emissions . . .	18

     APPENDIX B - Candidacy Assessments for Relaxation of
                  Regulations/Fuel Switch Potential  	  32

     APPENDIX C - Power Plant Assessments 	.35

     APPENDIX D - Industrial Commercial Sources Assessment  ....  53

     APPENDIX E - Area Source Assessment	62

     APPENDIX F - Regulation Evaluation and Fuel  Statistics  ....  64
                                     in

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                         1.0 EXECUTIVE SUMMARY

     The enclosed report is the U. S. Environmental  Protection Agency's
(EPA) response to Section IV of the'Energy Supply and Environmental
Coordination Act of 1974 (ESECA).  Section IV requires EPA to review
each State Implementation Plan (SIP) to determine if revisions can be
made to control regulations for stationary fuel combustion sources
without interfering with the attainment and maintenance of the National
Ambient Air Quality Standards (NAAQS).  In addition to requiring that
EPA report to the State on whether control regulations might.be revised,
ESECA provides that EPA must approve or disapprove any revised 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 infor-
mation on excessively restrictive control  regulations.  The intent of
ESECA is that SIP's, wherever possible, be revised in the interest of
conserving low sulfur fuels or converting sources which burn oil or
natural gas to coal.  EPA's objective in carrying out the SIP reviews,
therefore, has been to try to establish if emissions from combustion
sources may be increased.  Where an indication can be found that
emissions from certain fuel burning sources can be increased and still
attain and maintain NAAQS, it may be plausible that fuel resource
allocations can be altered for "clean fuel savings" in a manner con-
sistent 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 imple-
mentation plans with regards to saving low sulfur fuels and, where the
primary sulfur dioxide air quality standards were not exceeded, to
encourage States to either defer compliance regulations or to revise the
SO.;, emission regulations.  The States have also been asked to discourage
large scale shifts from coal to oil  in  cases  where, such  shifts  are  not
 required for the attainment and maintenance of the  NAAQS.

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     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 S(L 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 a_1J_ the National  Ambient Air Quality Standards.
     There are, in general, three predominant reasons  for  the existence of
overly restrictive emission limitations within the State Implementation
Plans.  These are 1)  The use of the example region approach in developing
State-wide air quality control strategies; 2)  the existence of State Air
Quality Standards which are more stringent than NAAQS; and 3) the "hot spots"
in only part of an Air Quality Control  Region (AQCR) which have been used
as the basis for controlling the entire region.  Since each  of these situa-
tions affect many State plans and in some instances conflict with current
national energy concerns3 a review of the State Implementation Plans is a
logical follow-up to EPA's initial appraisal of the SIP's  conducted in 1972.
At that time SIP's were approved by EPA if they 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
AQCR's 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 re-
sult in excessive controls, especially in the  utilization of clean fuels,
for areas of the State where sources would not otherwise contribute to NAAQS
violations.  For instance, a control strategy based on a particular region or
source can result in a regulation requiring 1 percent sulfur oil  to be burned
state-vrido where the use of 3 percent sulfur coal would be adequate to attain
NA';QS in some locations.

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     EPA anticipates that a number of States will  use the review findings
to assist them in making the decision whether or not to revise portions  of
their State Implementation Plans.   However, it is  most important for those
States which desire to submit a revised plan to recognize the review's
limitations.  The findings of this report are by no_means conclusive and
are neither intended nor adequate to be the sole basis for SIP revisions;
they do, however, represent EPA's best judgment and effort in complying
with the ESECA 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 emissions.
Where the modeling data for specific sources were found, however, they were
used in the analysis.
     The data upon which the reports' findings are based is the most
currently available to the Federal Government.  However, EPA believes that
the States possess the best information for developing revised plans.  The
States have the most up-to-date air quality and emissions data, a better
feel for growth, and the fullest understanding for the complex problems facing
them in the attainment and maintenance of air quality standards.  Therefore,
those States desiring to revise a plan are encouraged to verify and, in
many instances, expand the modeling and monitoring data supporting EPA's
findings.   In developing a suitable plan, it is suggested that States select
control strategies which place emissions for fuel combustion sources into
perspective with all sources of emissions such as smelters or other industrial
processes.  States are encouraged to consider the overall impact which the
potential  relaxation of overly  restrictive emissions regulations for combus-
tion sources might have on their future control programs.  This may include
air quality maintenance, prevention of significant deterioration, increased
TSP, NO  ,  and HC emissions which occur in fuel switching, and other potential
        A
air pollution  problems such as sulfates   .
     Although the  enclosed analysis  has attempted to  address  the  attainment  of
all the NAAQS, most  of  the  review has  focused on total  suspended  particulate
matter  (TSP) and sulfur  dioxide  (SCL)  emissions.  This  is because stationary
fuel  combustion  sources  constitute  the greatest source  of SO- emissions and are
a major source of  TSP  emissions.
 * Other than data currently being processed by EPA
                                      3

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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 AQCR's.  The

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

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

have been combined in Appendix B with other regional air quality "indicators"

in an attempt to provide an evaluation of a region's candidacy for changing

emission limitation regulations.  In conjunction with the regional analysis,

a summary of the State's fuel combustion sources (power plants, industrial

sources, and area sources) has been carried out in Appendix C, D, and E.


                              FINDINGS


     •   The  Kansas State  Implementation Plan has been reviewed for
        the  most  frequent causes of over-restrictive emission limiting
        regulations.   The particulate and sulfur dioxide regulations
        which now apply in  Kansas do not appear overly restrictive Tn
        the  context of Section IV of ESECA.

     •   The  State of Kansas used Metro Kansas City as the example region
        to demonstrate attainment of particulate NAAQS, using an air
        quality display model  rather than linear rollback.  Kansas has not
        adopted air quality standards more strict than the federal
        standards and  has not designated any AQMA's to date.  Current
        monitoring data shows TSP to be a widespread problem throughout
        Kansas, although  fuel combustion  is a minor contributor in many
        areas.  Current fuel use practices result in most sources
        emitting  well  below particulate regulations at present, especially
        in Central and Western Kansas.  Clean fuel savings is thus possible
        under existing regulations, with NAAQS being the limiting factor.
       Thus, Kansas fuel burning particulate regulations should not be relaxed.

     •   S02  levels in  Kansas were well below NAAQS when the Kansas SIP
        was  written.   The plan demonstrated that source growth would
        not  cause NAAQS tb be violated in Kansas City and thus n£ SC^
        regulation was established.  Kansas has since adopted a state-
        wide S02  regulation on large fuel burning sources.  All sources
        are  in apparent compliance with this regulation, particularly in
        Central and Western Kansas where natural gas is the predominant
        fuel.  Current S02 monitoring indicates very low SOp levels in
     •  outstate  Kansas,  with somewhat higher levels in Wicnita and
        Kansas City.   There is an indication that, at least in Kansas
        City (AQCR 094),  NAAQS for SC-2 may be violated if all fuel sources
       were to emit exactly .at. the .Kansas..S02 regulation.  In Kansas' other
       AQCR's, NAAQS might not "be violated, if fuel switching were to occur.
        Since some such fuel switching can.occur .without regulation change,
        revision  of the Kansas..$Q?:.emission-.regulation is not recommended.

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           2.0  STATE IMPLEMENTATION PLAN REVIEW


     SUMMARY.

     A revision of fuel combustion  source  emissions regulations

will depend  en nany  factors.   For example:- -

     *  Does the  State  have  air  quality  standards v/hich  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 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?
      e
         Are there no proposed Air Quality Maintenance Areas?
      *   Are there indications of a sufficient number of monitoring
         sites within a region?

      *   Is there an expected 1975 attainment date for NAAQS?

      *   Based on (1973) air quality data, are there no reported
         violations of NAAQS?

      *   Based on (1973) air quality data, are there indications
         of a tolerance for increasing emissions?

      •   Are the total  emissions  from stationary fuel combustion
         sources proportionally  lower than those of other sources?

      0   Must emission  regulations  be revised to accomplish signifi-
         cant fuel switching?

      6   Is there a significant  clean fuels savings potential in
         the region?

      *   Do modeling results  for specific  fuel combustion sources
         show a potential  for  a  regulation revision?

      The following portion of this report is directed at answering these

questions.   An AQCR'.s potential  for revising regulations increases when
there are affirmative responses  to  the  above.

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      The initial part of the SIP review report,  Section 2 and Appendix
A, was organized to provide the background and current situation information
for the State Implementation Plan.   Section 3 and the remaining Appendices
provide an AQCR analysis which helps establish the overall potential  for
revising regulations.  Emission tolerance estimates have been combined in
Appendix B with other regional air quality "indicators" in an attempt to provide
an evaluation of a region's candidacy for revising emission limiting regula-
tions.  -In conjunction with the regional analysis, a characterization of the
State's fuel combustion sources (power plants, industrial sources, and area
sources) has been carried out in Appendix C, D, E.  Finally, candidates from
Appendix B are examined in Appendix F for adequacy or overrestrictiveness of
emission regulations.
      Based on an overall evaluation of EPA's current information, AQCR's
have been classified as good, marginal, or poor candidates for regulation
revisions.  The  following table summarizes the State Implementation Plan
Review.  The remaining portion of the report support this summary with explana-
tions.                     •

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KANSAS STATE IMPLEMENTATION PLAN REVIEW
(Metro (SUMMARY)
Kansas City) (N. East) (N. Central) (N. West) (S. East) (S. Central) (S. West)
094 095 096 097 098 099 100
STATE AQ8R AQSE AQCR AQCR AQCR AQCR AQCR
"INDICATORS"
• Does the State have air quality standards
which are more stringent than NAAQS?
• Does the State have emission limiting regu-
lations for control of:
1. Power plants
2. Industrial sources
3. Area sources
• Did the State use an example region approach
for demonstrating the attainment of NAAQS or
more stringent State standards?
t Has the State initiated action to modify
combustion source emission regulations for fuel
savings; i.e., under the Clean Fuels Policy?
• Are ther£ proposed Air Quality Maintenance
Areas?
• Are there indications of a sufficient number
of monitoring sites within a region? 0)
• Is there an expected 1975 attainment date
for NAAQS?
• Based on reported (1973) Air Quality Data,
does air quality meet NAAQS?
• Based on reported (1973) Air Quality Data,
are there Indications of a tolerance for
increasing emissions?
« Are the total emissions from stationary fuel
combustion sources lower than those of other
sources?
• Do modeling results for specific fuel combustion
sources show a potential for a regulation revision?
• Must emission regulations be revised to accom-
plish significant fuel switching?
• Based on the above Indicators, what is the
potential for revising fuel combustion source
emission limiting regulations?
• Is there a significant Clean Fuels Saving
potential in the region?
TSP S02
'No
Xes
Yes
Yes
Yes
No
no
Yes








No
¥8
No
yes
No
no;
Yes








TSP S02






Yes
No
No
Yes


No
Poor
No






Yes
Yes
Yes
No


No
Poor
Yes2)
TSP S02






Yes
No
No
Yes


No
Poor
No






Yes
Yes
Yes
No


No
Margi-
nal
Yes
TSP S02





'Yes
No
No
Yes
model In
No
Poor
No






Yes
Yes
Yes
Yes
g resul
No
Margi-
nal
Yes
TSP S02






Yes
No
No
Yes
ts aval
No
Poor
No



''•-^


Yes
Yes
Yes
Yes
lable f
No
Margi-
nal
Yes
TSP S02






Yes
No
No
Yes
>r Kans
No
Poor
No






Yes
Yes
Yes
Yes
is sour
No
Margi-
nal
Yes
TSP S02






Yes
No
No
.Yes


No
Poor
No






Yes
Yes
Yes
Yes


No
Margi-
nal
Yes
TSP S02






Yes
No
No
Yes


No
Poor
No






Yes
Yes
Yes
Yes


No
Margi-
nal
Yes
(1)   An analysis  tool  oily and does  not  reflect  SIP  requirements.
                                                                      '•  Additional  SO? emissions can occur in all  Kansas  AQCR's  without violatingelther
                                                                         NAAQS or existing regulations.  Thus some clean fuels could in principle
                                                                         be saved in Kansas via fuel switching within the existing legal framework.

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2.1  AIR QUALITY SETTING - KANSAS
     Kansas has been divided into seven (7) Air Quality Control Regions:
          1.  AQCR 094 - Metro Kansas City Interstate
          2.  AQCR 095 - North East Kansas
          3.  AQCR 096 - North Central Kansas
          4.  AQCR 097 - North West Kansas
          5.  AQCR 098 - South East Kansas
          6.  AQCR 099 - South Central Kansas
          7.  AQCR 100 - South West Kansas
These AQCR's are shown in Figure A-l.  Ambient air quality standards for
SO^ and TSP in Kansas are identical to federal standards and are shown in
Table A-3.

2.1.1  Suspended Particulates
     Table A-4 summarizes Kansas TSP data from the SAROAD Data Bank for 1973.
TSP appears adequately monitored in Kansas with Metro Kansas City (AQCR 094)
and South Central Kansas (AQCR Q99) having the greatest number of monitors.
All AQCR's in Kansas experience some type of TSP problems, with Metro Kansas
City (094) and South Central (Wichita - AQCR 099) showing the highest annual
geometric means. AQCR's 096 (North Central), 097 (North West), 098 (South East),
and 100 (South West) show annual means below the primary particulate standard.
These same four AQCR's appear to have localized particulate problems rather than
regionwide problems.  All  AQCR's in Kansas show violations of the 24 hour
secondary standard and only AQCR 100 (South West) has no violations of the
                          \
primary 24 hour standard.  As elsewhere in the western half of the United States,
fugitive dust probably contributes to short term particulate problems.
     Table A-4 is intended to show both the intensity and breadth of TSP
problems in Kansas.   Included are calculations of the percentage of stations
exceeding the standards as well as the percentage reduction required to meet
both the annual and short term standards at the worst station in each AQCR.

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2.1.2  Sulfur Dioxide
     Table A-5 summarizes S02 monitoring data of Kansas AQCR's.  The
number of monitors in each AQCR appears adequate relative to emission and
population densities.  AQCR's 096, 097, 098, and 100 have levels of 10% to
25% of the federal standards (both annual and 24 hour).  South Central (099)
and North East (095) have concentrations about 65% and 30% of the S02 standards
respectively.  Metro Kansas City indicates S02 levels of around 80% of the
24 hour standard on the Kansas side, although the highest annual average in
Kansas City is only 35% of the annual standard.
     The range of S02 concentrations seen in Kansas suggests relatively high
levels in localized spots.  Also, concentrations are more likely to approach
the short term standard than the annual average,standard.
2.2  KANSAS PARTICULATE EMISSIONS
     Table A-8 lists particulate emissions in the 1972 NEDS Data Bank for
Kansas.  All AQCR's show a minority of particulate emissions resulting from
fuel combustion.   Even Metro Kansas City Interstate has only 15% of its
total particulate emissions from fuel combustion (Kansas side).  Further,
only in North East (AQCR 095) and South East (098) does a large fraction of
the fuel emissions result from electric power generation.   Area source fuel
combustion generally dominates the fuel combustion fraction of particulate
inventories in the largely rural Kansas AQCR's (094, 096,  097, 099, and 100).
2.3  KANSAS S02 EMISSIONS
     Table A-7 summarizes 1972 NEDS data for S02 emissions.  About 70% of S02
emissions result from fuel combustion in the Kansas side of AQCR 094 (Metro
Kansas City), although the largest fraction of total S02 in 094 originates in
Missouri.  In AQCR 095 (North East Kansas) about 90% of S02 emissions result
from fuel combustion, primarily from electric power generation.  AQCR's 096
to 10.0 show S02 emissions resulting from fuel combustion to be less than half
of the total, and only AQCR 098 (South East) has significant electric power
contributions.  As was the case with particulates, area fuel use is the jnajor
contributor of S02 to the fuel portion of the inventory in all Kansas AQCR's.

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2.4  BACKGROUND ON KANSAS SIP
     Kansas air quality data for 1969 and 1970 was used for SIP preparation.
Table A-9 lists the maximum particulate level reported in the SIP for each
AQCR.  Notice that only AQCR 098 (South East) did not exceed the annual
secondary particulate standard at that time.  S02 levels (1970 and 1971)
found in the Kansas SIP are shown in Table A-10 (only AQCR's 094, 095, and
099 had monitoring data).  SO, levels even in Metro Kansas City were well
                                                            3
below ambient S02 standards.  Oxidant levels (about 200/yg/m , 1 hour
average) in AQCR 094 and 099 were above the ambient air quality standards
(160  g/m^, 1 hour average) during 1971.  N02 levels were below the federal
standard in 1970 and 1971 in Kansas.  Based on the above levels the
priorities for AQCR's listed in Table A-l were assigned.
2.4.1  Particulates
     The Kansas SIP used AQCR 094 (Metro Kansas City) as the example region
for particulates.  Emission estimates from both point and area sources, and
expected reductions under plan implementation were developed for AQCR 094.
Rather than rollback of total emissions proportional to air quality, the
Kansas City region was shown to meet ambient air standards using a diffusion
model.  It was expected that implementation of the example region particulate
control regulations elsewhere in the state would be adequate to attain air
quality standards.  Existing particulate fuel burning regulations are shown
in Table A-ll.
2.4.2  Sulfur Dioxide
     Although Kansas S02 levels were (and still are) below standards, the
Kansas State Board of Health adopted S02 regulations.  Fuel burning sources
are limited to 3 Ibs S02/106 Btu heat input.  This regulation applies to all
sources that would increase their S02 emissions by a factor of 2 or more from
their.base year (.1971).  Most new S02 emission sources were assumed to be
controlled by Federal New Source Performance Standards (Table A-ll).  Estimated
total S02 emissions in 1970 (from the SIP) are shown in Table A-10 for
AQCR 094.
                                      10

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2.4.3  Oxidant
     The Kansas SIP calculated a 31% hydrocarbon emission reduction in
South Central (099) and a 24% reduction in Metro Kansas City (094) by 1975
as a result of the federal motor vehicle control program.  These reductions
were deemed sufficient to attain ambient air quality standards.   No additional
hydrocarbon controls were seen necessary, although some regulations on petroleum
storage, etc. were imposed.  The total hydrocarbon emission inventories in 1970
from the SIP were:  094 (Kansas City) - 180 x 103 tons, 099 (South Central) -
72 x 103 tons.
2.4.4  NOV
         X
     Although N02 levels were below ambient air quality standards in 1970 in
Kansas, NOV regulations have been imposed on fuel burning sources (Table A-ll)
          X
in Kansas.
                                       11

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     3.0  AQCR ASSESSMENTS BASED ON SIP REVIEW AND CURRENT AIR QUALITY

     The purpose of this section is to examine fuel switching in each of
Kansas' seven AQCR's and the adequacy or over-restrictiveness of current
regulations for attaining and/or maintaining ambient air quality standards.
Tables A-9 and A-10 are an attempt to assign a regional emissions tolerance
for Kansas AQCR's.  Appendix B uses this "tolerance," along with such factors
as the breadth and depth of air quality violations and percent of emissions
resulting from fuel combustion to rate each AQCR as a "good," "marginal," or
"bad".candidate for fuel switching potential :and regulation relaxation.
     Power plants, industrial sources, and area sources are investigated in
Appendices C, D, and E respectively for fuel use, emissions, and current
regulations.  Some calculations of emissions resulting from fuel switching
are included for power plants.  Appendix F is a rough emissions inventory
which could hypothetically result if all fuel burning sources emitted exactly
at regulation levels.  This inventory is the final test of current regulations
relative to air quality.
     Although each AQCR is treated separately in the appendices, some AQCR's
are lumped together in this section because their situation is similar and
thus final conclusions concerning regulations are similar.
3.1  AQCR 094 - METRO KANSAS CITY INTERSTATE
3.1.1  Candjdacy Assessment for Fuel  Switch Potential
     AQCR 094 shows several violations of TSP standards, both in Kansas and
in Missouri  with the highest concentrations being indicated in Kansas (Table A-4).
Particulate emissions are about evenly distributed between the two states
(Table A-8), although a much smaller fraction of total emissions results from
fuel combustion in Kansas than in Missouri.  The original  Kansas SIP gave no
indication that particulate regulations would more than meet air quality
standards in AQCR 094.   Therefore,  Metro Kansas City is rated as a bad
candidate for fuel switching and regulation relaxation from a particulates
standpoint.
     S02 levels are slightly below ambient air quality standards in 094 (Metro
Kansas City), with somewhat higher readings in Kansas than in Missouri (Table A-5),
                                        12

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As might be expected, most of the SCL results from fuel combustion in 094,
especially in Missouri  (Table A-7).  The Missouri contribution to total SOp
emissions is much higher than that of Kansas.  AQCR 094 is assigned a
45000 ton regionwide tolerance for increased SO,, emissions, based on a 22%
rollup of air quality levels to standards.  Table A-10 distributes this
tolerance between Missouri and Kansas, in proportion to existing emissions.
Table B-2 rates AQCR 094 as a good initial candidate for fuel switching and
regulation relaxation relative to S.Op.
3.1.2  Emission Source  Examination
     The three large power plants in the Kansas portion of AQCR 094 all use
some coal at present (Table C-l).  SOp emissions from these plants are only
about 30% of those allowed under existing regulations.  Likewise, particulate
emissions are well below existing regulations, reflecting the natural gas con-
tribution to the fuel mix.  Industrial sources listed in the NEDS data bank show
no coal use by this sector at present.  A comparison of existing and allowable
emissions for industrial sources (Table D-l) reveals that considerably
increased emissions of  both SOp and particulates could occur under existing
regulations.
     A small amount of  coal is currently used by area sources in AQCR 094,
but large scale fuel switching is probably not practical for many of non-coal
users.(Table E-l).  Further, existing regulations would exempt many of the
smaller sources from controls (mainly due to size).  A similar situation exists
for other Kansas AQCR's and thus no further evaluation of area source fuel
switching in Kansas will be pursued, since regulation changes would not be
required to accomplish  fuel switching.  Table E-l shows that 42% of total
energy use in Kansas is by area sources.
3.1.3  Regulation Examination
     The analysis in Table F-l for AQCR 094 suggests that existing regulations
on fuel burning sources alone could .create more particulate emissions than would
be required to meet the NAAQS. Of course, the emission tolerance from Table A-8
could be redistributed  to allow more emissions in Kansas and less in Missouri,
but very strict controls on non-fuel emissions would still be required if
particulate standards are to be attained in AQCR 094.  Therefore no particulate
regulation relaxation is justified in 094.

                                        13

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      Table F-2 for AQCR 094 shows  that S02  emissions  from fuel  burning
 sources could more than double under the  existing  SCL regulations.   This
 increase alone would exceed the Kansas "allowed  emissions"  in Tables A-9  and
 F-2.   A large portion of the S02 emissions  in AQCR 094 do  originate  in
 Missouri  however,  and controls in Missouri  could allow additional emissions in
 Kansas.   From a strictly "Kansas" standpoint, however, fuel S02 regulations in
 094 may not be strict enough for major fuel changes,  since:CD no regulations on
 S02 emissions  from non-fuel  sources  in Kansas are  in  effect (except  smelters),
 and (2)  total  S02  emissions  would be considerably more than allowable if all
 sources  emitted at regulation  levels and area source  fuel conversions could
 occur without  regulation  change, increasing S02 (and  particulate) emissions.
 It is therefore concluded than  no room for S02 regulation relaxation exists
 in the  Kansas  portion  of AQCR  094.
 3.2  EASTERN KANSAS AQCR's 095  (NORTH  EAST)  AND 098 (SOUTH EAST)
3.2.1   Candidacy Assessment
     Table A-4 shows the two eastern AQCR's  to have violations  of both annual
and 24 hour particulate standards.   Both AQCR's  would require  approximately
46% reduction of emissions in order to meet  the  24 hour secondary standard.
AQCR 095 (North East) is further from the annual  standard (72%)  than 098 5
 (South East) with 19%.  Reported emissions in Table B-l  are relatively high
in these twoMQCR's, although fuel  combustion contributes only  a small  fraction
of the total emissions.  AQCR's 095 and 098  are  rated as  bad candidates  for fuel
switch'potential land particulate regulation  relaxation in Table  B-l.
     S02 levels in the two eastern  AQCR's, and the rest of Kansas as well, are
below standards at present.   In Table B-2 therefore,  all  Kansas  AQCR's
 (including AQCR 094) are rated as good candidates for fuel switch examination
from an S02 standpoint.  An emission tolerance (Table A-10) was  not assigned,
since it was felt that such a calculated rollup  of emissions was unrealistic
in Kansas.
3.2.2  Emission Source Examination
     AQCR's 095 and 098 both have coal burning power plants (Table c-1).
Particulate emissions from these plants are  somewhat below regulations at
present.  S02 emissions are quite a bit below regulations  in  AQCR 098 because
gas makes up the bulk of fuel used  tn power  plants and in AQCR 095 because of
both gas use and S02 controls at the.Lawrence,,Kansas, plant.

                                            14

-------
     Industrial sources in 095 use no coal according to the NEDS data
(Table D-l) and both S(L and particulate emissions are well below what
regulations would allow.  In 098, coal use by industrial sources causes
particulate regulations to be exceeded (Table D-2).  Fuel switching abilities
of individual sources is not known for either AQCR 095 or 098„ and therefore
only a comparison of existing and allowed emissions is shown in Appendix D.
     Area sources consume large quantities of coal in AQCR's 095 and 098
(Table E-l).  Regulations do not apply to most small fuel users so that fuel
conversions are probably limited by other considerations.
3.2.3  Regulation Evaluation
     AQCR's 095 and 098 are dominated by non fuel particulate emissions
(Table F-l).  Some additional  particulate emissions from fuel burning sources
could occur under existing regulations in 095, while in 098 sources are very
nearly emitting at average regulations.   Large reductions from non-fuel
emitters are required to reach "allowed emissions," regardless of fuel burning
emissions.  It is concluded that no room for particulate regulation
relaxation exists in AQCR's 095 and 098.
     Table F-2 evaluates current SOp emissions relative to the existing r
regulations.  Since "allowable" emissions based on current air quality could
not be realistically calculated for AQCR's 095 and 098, a "rollup" ratio was
calculated instead.  It can be seen that five times more S02 emissions in
AQCR 095 and 1.6 times more emissions in 098 could occur under existing
regulations.
     To the extent that a regional approach is valid, AQCR 095 can probably
not tolerate more SOg emissions than current regulations wouJd already allow.
Therefore, rio SOp regulation relaxation is recommended in 095.   AQCR 098 is
more of an SOp fuel regulation relaxation prospect, depending on non-fuel S02
controls.  098 may be considered for S02 regulation relaxation, although
vastly increased coal use could occur in power plants without regulation
changes.
                                        15

-------
3.3  AOCR 099  (SOUTH CENTRAL)
3.3.1  Candidacy Assessment
     Suspended participate violations (Table A-4) of both annual and short
term standards are widespread in AQCR 099.  Although most of the emissions
are non-fuel related, this AQCR is rated a bad candidate for particulate
regulation relaxation for fuel switching purposes (Table B-l).
     S02 levels are about 60% below standards at the 2nd highest station
in AQCR 099 (the 2nd highest value at the highest station was not available),
suggesting about 19000 tons allowable regionwide emissions in Table A-10.
AQCR 099 is rated a good candidate for fuel switch investigation relative
to S02.
3.2.2  Emission Source Evaluation
     Power plants (Table C-l) use no, coal at present in AQCR 099 and
very little oil.  The large natural gas use allows S02 and particulate
emissions to be well below regulations (Table C-2).   Industrial sources
likewise use mostly gas and their emissions are low relative to S02 and
particulate regulations.
3.3.3  Regulation Evaluation
     Table F-l shows that non-fuel sources dominate the particulate emissions
total in 099, and that fuel particulate emissions could increase considerably
without regulation changes.  More over, particulate emissions from all fuel
sources burning at regulations alone would exceed the regional requirement for
air quality.  Particulate regulations should not be relaxed in AQCR 099.
     S02 regulations (Table F-2) applied to all fuel sources results in
drastically increased regional emissions.  The allowed 19000 tons
estimated from air quality (Table A-10) is exceeded by a factor of five.  It
is recommended that S02 regulations not be relaxed in AQCR 099.
                                       16

-------
3.4  WESTERN AQCR's 096, 097 ,„ and 100
3.4.1  Candidacy Assessment
     Particulate violations are generally of short term nature and are
somewhat localized in AQCR's 096, 097, 100 (Table A-4).  The percent of
participate emissions from fuel combustion is low in these AQCR's.  In
Table B-l, then, AQCR's 096, 097, and 100 are rated as marginal candidates
for regulation examination and fuel switching.
     S02 levels are very low in the western AQCR's and AQCR's 096, 097, and
100 are rated as good candidates for regulation examination (Table B-2).  A
quantitative estimate of allowed SO^ emissions is not possible, however.
3.4.2  Emission Source Examination
     Natural gas is the major fuel for both industry and power plants in
western Kansas (Table C-l and D-l).  SOp and particulate emissions are
therefore low relative to regulations (C-2 and D-2).  No coal is known to be
used by either category of fuel user.
3.4.3  Regulation Examination
     Particulate emissions from fuel sources can substantially increase in
western Kansas without regulation changes (Table F-l).   Relaxation of
regulations on fuel burners could be considered vf non-fuel sources are
more strictly controlled.
     S02 emissions could increase more than 10 times in western Kansas without
violation of existing regulations.  Although regional SOp allowed emissions
were not calculated (and might have little meaning in any case for such widely
dispersed emissions), it would seem unlikely that local violations would not
occur somewhere if S02 emissions increase by such a magnitude.  It is
recommended that S02 regulations not be relaxed in western Kansas.
3.5  SPECIAL CONSIDERATION - FOSSIL FUELS (TABLE F-3)
     Kansas has large reserves of coal, oil  and natural gas.  Currently Kansas
produces more of all three fuels than is consumed internally.  It would seem
that fuel switching would not be constrained by reserves or production from a
purely Kansas viewpoint.  Much of Kansas coal  does tend to be high in sulfur,
however.
                                      17

-------
                               APPENDIX A
          BACKGROUND INFORMATION ON SIP, AIR QUALITY  EMISSIONS

     e  State implementation plan information
     •  Current air quality information
     e  Current emissions information
     Tables in this appendix summarize original  and modified state imple-
mentation plan information, including original  priority classifications,
attainment dates, ambient air quality standards, and  fuel  combustion emis-
sion regulations.  SAROAD data for S0~ and TSP  monitoring  stations are shown
                                     *-              I
for AQCRs in the state.  NEDS emissions data by AQCR  are  tabulated and
broken down into fuel burning categories.
     Tables A-9 and A-10 show a comparison of emission inventories in the
original SIP and those from the NEDS.  An emission tolerance, or emission
tonnage which might be allowed in the AQCR and  still  no+ violate inational
secondary ambient air quality standards, is shown for S02  and particulates.
The intent of this calculation is to indicate possible candidate regions
for fuel switching.  Tolerance was based on either the degree of control
expected by the SIP or upon air quality/emission relationships which are
calculated from more recent data.  The value of the emission tolerance pro-
vides an indication of the degree of potential  an AQCR possesses for fuel
revisions and regulation relaxation.
Methodology for Increased Emissions Tolerance
     A tolerance for increased emissions was determined as follows.  First}
an ".allowable emissions" was calculated for each AQCR based on the current
NEDS data and the percent reduction (or increase) required to meet the
national secondary ambient air quality standards in that AQCR (worst case
from Tables A-4 and A-5).  This "allowable" was then compared to that from
the SIP.  If reasonable agreement occurred, then the "estimated emissions"
which would result after implementation of the SIP in that AQCR was used
to calculate an emissions tolerance.  Thus, some credit could be given to
an AQCR which might be restricting emissions more than required by ambient
air quality standards.  For instance, emission controls applied to AQCR's
 lM1972 National  Emissions  Report," EPA - 450/2-74-012, June 1974.

                                   -   19    '     -,

-------
other than the example region for the state may reduce emissions well  below
"allowables."  In the event that no data existed or was available from the
SIP for an AQCR, the current air quality was used to assign emissions  toler-
ance based on proportional  rollback or rollup.   Current air quality was also
the criteria, if emissions  data from SIP and NEDS did not appear to be com-
parable (this is often the  case).
     When no SIP emissions  data was available,  and current air quality
levels were less than one half of the level represented by an ambient  air
quality standard, no "rollup" 'emissions tolerance was calculated in Tables
 \
A-10 and A-10.  This arbitrary cutoff point was chosen so as not to distort
the emissions tolerance for an area.  At low levels of a pollutant, the
relationship between emissions and air quality  is probably not well  defined.
Although this cutoff may leave some AQCRs with  np_ quantifiable emissions
tolerance, it was felt that no number at all would be preferable to a  bad
or misleading number.
     It is emphasized that  emissions tolerance  is a region-wide calculation.
This tolerance obviously makes more sense in, say, an urban AQCR with  many
closely spaced emissions sources than in a largely rural AQCR with geograph-
ically dispursed emissions.
                                       20

-------
ro
                              NORTHWEST
                              KANSAS
                              INTRASTATE
 NORTH CENTRAL
 KANSAS
 INTRASTATE
NORTHEAST
KANSAS
INTRASTATE
                        SOUTHWEST
                        KANSAS
                        INTRASTATE
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                                                                                                                       METROPOLITAN
                                                                                                                       KANSAS CITY
                                                                                                                       INTERSTATE
                                                                                                                       (KANSAS
                                                                                                                      'MISSOURI)
                                                                                                                        094
SOUTH CENTRAL
KANSAS
INTRASTATE
  SOUTHEAST
  KANSAS
  INTRASTATE
                                                           figure  A-l.    Kansas AQCR's

-------
                                                         Table  A-l.   Kansas  AQCHPriority Classification and AQMAs
AQCR
Metro Kansas
City
Interstate
Northeast
North Central
Northwest
Southeast
South Central
Southwest
\
Fed. 1
094
095
096
097
098
099
100

Priorities
Part.3
I
I
I
I
III
I
I

V
III
III
III
III
III
III
III

NOXC
III
HI
III
III
III
III
III

Demographic Information.
Population
1970
Kansas
450,258
Missouri
953,923
371 ,227
267,137
162,642
263,679
570,018
154,110

square
Miles
1094
3117
8656
11632
19773
10336
9955
20378

population
Density
411
306
43
23
8
26
57
7.6

AQMA Designations
TSP Counties
None
None
None
None
None
None
None
None

SOX Counties

-
-
-
-
-
-

NOX Counties
-
. -
-
-
-
-
-

ro
ro
                                                       Criteria Based en KaxlBM featured (or EitlMted) Pollution Concentration In Area


•Sulfur oxide:
Annual arithoctle nan ..


^articulate natter:
Annual oeonetrlc Bean ...
24-hour iaxlaum 	

'Nitrogen, dioxide
I
Greater than

too
455


95
325

110

Fro» - To

60-100
260-455


60- 95
150-325



Lest than

60
*fin


60
ISO

110
                                                       Federal Register. August. 1974 SXSA's showing potential for FIAAWS violations due to jroirth

-------
                                                   Table A-2.  Kansas Attainment Dates

AQCR 1
094
095
096
097
098
099
ioo

Name

Metro Kansas City Interstate
Northeast
North Central
Northwest
Southeast
South Central
Southwest
Parti culates
Attainment Dates
Primary

7/75
7/75
7/75
7/75
a
7/75
7/75
Secondary

7/75
7/75
7/75
7/75
a
7/75
7/75
Sulfur Dioxide
Attainment Dates
PrTmary

4
a
a
a
a
a
a
Secondary

a
a
a
a
a
a
a

Nitrogen Oxides
Attainment Dates

a
a
a
a
a
a
a
ro
CO
            a)  Already below standards.

-------
                                             Table A-3.  Ambient Air Quality Standards - Kansas
                                                             (Expressed as;ug/m )
Federal Primary
. Secondary
Total Suspended Participate
Annual

75 (6)
60 (G)
24 hr.

260a
150a
Sulfur Oxides
ArinuaT

80 (A)
24 hr.

365a
3 hr.

1300a
Nitrogen
Dioxide
100 (A)
100 (A)
State Same as Federal
ro
         a) Not to be exceeded more than once per year.
         A) = Annual arithmetic mean.
         G) = Annual geometric mean.

-------
                                           --U* Table A-4. Kansas; AQCR Air Quality  Status (1973), TSR-;
                                                                                                      5


U}CR Name

Metro K.C. Interstat«
Kansas AJ.-=
4 . ."" ^ . . „
Missouri
Northeast
North Central
Northwest
Southeast
South Central
Southwest


AQCR $
-- - - *
094
095
096
097
098
099
100

#
Stations
Reporting

14
J9_
33
10
6
5
6
15
5
( g/m3)
TSP Concentration
2nd
Highest
Highest Reading Reading
Annual 24-Hr Z4-Hr

128 479 442
?P 440 254
91 277 276
70 682 501
66 345 294
67 382 279
105 365 340
.71 303 243

# Stations Exceeding
Ambient Air Quality Standards
Primary - Secondary tf
Annual 24-Hr6 Annual % 24-Hr* %

64 7 50 9 64
P 0 P -_ 12 _63
.7 4 8 - 21 63
11 3 33 3 33
01 1 17 1 \7
01 1 20 2 40
01 1 17 4 67
11 4 27 5 33
00 1 20 1 20
Reduction
Required
to Meet
Annual
StandardsS

I
7P
sP
sP
19®
8


-------
                                                  Table A-5.  Kansas S02 A1r Quality Status1




AQCR Name
Metro K.C. Kansas
Missouri

Northeast
North Central
Northwest
Southeast
South Central
Southwest




AQCR 1
094


. 095
096
097
098
099
100

#
Stations
Reporting
24-Hr
(Bubbler)
7
5
TI
10
3
4
3
3
2


. 1
Stations
Reporti ng
(Contin.)
" 4
2
~6~
1
1
1
-
3
-
. •*•*.
:~ "C/ig/niS")'
2nd
Highest
Highest Reading Reading
Annual 24-Hr 24-Hr
28 32fr 300 '
N/A 251 ' • N/A
TB' 320" 300"
20 249 77
9 64 43
15 80 60
91 63 56
27 290 228
13 68 68


i Stations Exceeding
Ambient Air Quality Stds.
Primary . Secondary
Annual 24-Hr- 3-Hr
00 a


0 0 -
00
00
00
00
0 0
i
Reducti on
Required
to Meet
Annual
Standards
•• a


a
a
a
8
a
a

%
Required
to Meet •
24 Hour
Standard
-22
a

a
a
a
a
-60
a
ro
       1
        SAROAD data bank, June 1974.
       aAlready below standards.

-------
                                                 Table  A-6.   Kansas  Fuel  Combustion Source Summary0
AQCR
Metro K.C.
Missouri
Northeast
North Central
Northwest '
Southeast
South Central
Southwest
AQCR i
094
095
096
097 .
098
099
100
Kansas Power Plants
NEDSb FPCC

2 3
9 10
3 2
5 2
9 2
6 3
9 5
4 3
Other Fuel Combustion Point Sources
Parti cul ate S0£

3 3
15 15
6 6
4 3 ;
4 2
10 6
14 8
5 0
ro
             "Kansas  sources, only.
             bNEDS  data  bank, June  1974.
             cln  EPA  data  bank, September  1974,
             FPC stands for Federal Power Commission.

-------
                                         Table A-7.       Kansas Emissions ^Summary, S0|
AQCR Name
Metro Kansas Ci t.
Kansas
Missouri
Total
Northeast
North Central
Northwest
Southeast
South Qentral
Southwest
, Total
AQCR 1 10JTons/.Year
'094 ...
28.4
176
204
095 14.4
096 4.2
097 ' 2.3
098 32.9
099 11.9
100 1.8
Percent
Fuel Combustion
68
. 94
90
89
38
43
25
42
47
Electricity Generation
Point Source
Fuel Combustion
Area Source
„ Fuel Combustion
TO*Tons/Year % logons/Year % lOTons/Year %
,10.3 36
156 89
166 81
10 69
0.18 4.3
.06 2.6
3.8 11.6
0.32 2.7
.03 1.7
0.4 1.4
9.1 5.1
9.5 4.6
.28 1.9
.03 • 0.71
.06 2.6
.80 2.4
.52 4.4
0 0
8.6 3.0
1.0 0.6
9.6 4.7
2.6 18
1.4 33
0787 38
3.5 11
4.1 35
0.82 47
ro
oo
     *1972 National Emissions  Report EPA  -  450/2-74-012, June 1974.

-------
                                          Table A-8.      Kansas  Emissions Summary, Participates8
AQCR Name
Metro Kansas C
Kansas
Missouri
Total
Northeast
North Central
Northwest
Southeast
South Central
Southwest
AQCR J ••
ity 094

095
096
097
098
099
100 .
.Total
'l(r Tons/Year
42.2
35.7
77.9
44.3
23.4
13.4
184
40.1
37.1
Percent
Fuel Combustion
15
55
33.7
7.8
4.0
. : 5.1"
2.8
8.0
1.7
Electricity Generation
Point Source
Fuel .Combustion
Area Source
Fuel Combustion
logons/Year % iQ^Tons/Year % ^Tons/Year %
0.625 1.5
16.86 47
17.5 22
2.2 5.0
.05 0.2
'.77 1.3
3.3 1.8
0.54 1.3
0.10 0.3
.054 0.1
1.78 5.0
1.8 2.3
.12 .3
.18 .8
.04 .3?
0.70 .4
0.19 .5
.03 .1
5.8 14
1.1 3.0
6.9 8.9
1.1 2.5
0.70 3.0
0.47 3.5
1.1 0.6
2.5 6.2
0.50 1.4
ro
     *1972 National  Emissions Report, EPA - 450/2-74-012, June 1974.

-------
                                              Table A-9.   Kansas  Required Emission Reductions  - Particulates
                                        SIP
1973 Data
CO
O
AQ
Measurement
«. Control,
AQCR :, Value ^/M-*)
094 (KC)
Total
(KC+Mo.)
095 (NE)
096(NC)
097(NW)
098 (SE)
099 (SC)
100(SW)
197(AGMP
150
99
124
60
184
107
Emissions
(103 tons)
104
N/A
N/A
N/A
NKA
N/A
N/A
Allowable
Emissions
(103 tons)
7.4«.
-
-
-
-.
-
-
1975.
Estimated
Emissions
After Controls
(103 tons)
AQDfP
used
'

-
-
-
-
Percent
Reduction
Required
Based On
1973 AQ Data
85 Kansas
Missou
72
70
49
46
80
35
NEDS
Emissions
dO3 tons)
42.2
i 35.7
"TO ,
44
23
13
184
40
37
Allowable
Emissions
(103 tons)
6.3
5.4
TT7
12.2
6.9
6.6
100
8
24
                                                                                                                           Emission
                                                                                                                           Tolerance
                                                                                                                           (IP3  tons)
                         £>


                          ,€>•
          ^articulate example region for Kansas was AQCR 094.  Strategy development based upon AQDM.  Allowable emissions in this
          table for 094 is based on proportional rollback with 48 jjg/irr background.
          \GPl = annual geometric mean.
          Current NEDS total emissions are less than SIP total emissions suggesting progress on controls.  Calculated "allowable"
         emissions are comparable between NEDS and SIP.  No information is availeble to suggest emissions will be less than
          'allowable" after plan is implemented so that zero tolerance is assignee! to AQCR 094.
          .ack of SIP information dictates that all Kansas AQCRs be assigned zero tolerance for particulate emissions based
         on current air quality.

-------
                                             Table A-10.    Kansas Required Emission Reductions  -  S02
                                         SIP
1973 Data
CO
AQCR :,
094 (KC)
095 (NE)
096(NC)
097(NW)
098(SE)
099(SC)
100 (sw;
AQ
Measurement
Control -
Value. (ug/M3)
100 (24
Hr Ma^
20 (AAMP
19 (24 Hr
Wax)
^
-
-
17 (24 Hr
Max)
Emissions
(103 tons)
119
™
—
_
"
Allowable
Emissions
(103 tons)
435'




197J
Estimated
Emissions
After Controls
(103 tons)
(AQDM~I
used J



•
Percent
Reduction
Required
Based On
1973 AO Data
Kansas
_2p Missour
0
0
0
0
-60
0
NEDS
Emissions
(103 tons)
, 1.8
1 m
14.4 •
4.2
2.3
329
11.9
1.8
Allowable
Emissions
(103 tons)
2T§
759"
a
a
a
a
19.0
a
                                                                                                                           Emission
                                                                                                                           Tolerance
                                                                                                                          (IP3 tons)
                                                                                                                               6
                                                                                                                              39
                         b

                         b

                         b

                        7.14

                         b
             = annual arithmetic mean.

        Allowable emissions are not known for these AQCRs, since proportion "rollup" from current air quality results  in
         unrealistically high emissions allowed.
         Increased emissions can be allowed in these AQCRs but exact amount cannot be quantified with  data  available for
         this report.
        cThis is a regionwide emission tolerance  for increased emissions base on proportional  rollup  to air quality standard.

         Allowed  emissions  are  distributed  to  each  state  in  the AQCR  proportional  to  existing emissions.

-------
                                                  Table A-11.  Kansas Fuel Combustion Regulations
                                                              (Effective January 1, 1974)
oo
ro

. Parti culates


so2
80X

Existing Sources
Heat Input
106BTU/hr(I)
10
10,000
A = 1.026 I'-233
Allowable
Emlsslons(A)
lb/100 BTU
0.60
0.12

3.0: Ibs S02/106 BTU
Gas i 011
(>250 x 106 BTU/hr)
Coal
(>250 x 106 BTU/hr)
0.3 Ib N02/106 BTU
0.9 Ib N02/106 BTU
New Sources
2
Power Plants
0,1 lbs/106 BTU
Other sources same as existing Kansas
regulations.

0.8 Ibs S02/106 BTU - oil2
1.2 Ibs S02/106 BTU - coal
2
Power Plants ,
Gas = 0.2' Ibs N02/100 BTU
Oil = 0.3' Ibs N02/106 BTU
Coal - 0.7 lbs;N02/106 BTU
                   Having heat input greater than:
                   1  (A) Coal-350 x 103 BTU/hour
                      (B) Heavy oil-350 x 103 BTU/hour
                      (C) Light oll-l x 106. BTU/hour
                      (0) Gas-100 x 106 BTU/hour
                   2  Federal new source performance  standards, 36 Fed. Reg. 24876, Dec.  26, 1971.

-------
                                APPENDIX  B
 CANDIDACY ASSESSMENTS FOR RELAXATION OF  REGULATIONS/FUEL SWITCH  POTENTIAL
     Tables B-l and B-2 are the assessment  of AQCRs which  should  be examined
for the fuel switching impact on particulate and SOp emissions.   They also
provide,  an identification of those AQCRs which show little potential for
fuel revision or regulation relaxation if ambient air standards  are to be
attained.
     Those AQCRs designated "good" or "marginal" here will  be examined in
later appendices where an attempt will be made to estimate the emissions
resulting from an assumed fuel schedule different from the present, or the
emissions which might result if all fuel  burning sources emitted  up to
their "allowables."
     The criteria for candidates are:(l)  the severity and  breadth of air
quality violations, (2) the tolerance for emissions increased in  the AQCR,
(3) the fraction of total emissions resulting from fuel  combustion, and
(4) AQMA designations.  It should be noted  that an AQCR may not necessarily
need relaxation of regulations in order to  accomplish fuel  switching.
Further, a good candidate in Tables B-l and B-2 may later  show little
potential for fuel switching after individual sources are  examined.  Finally
it is posssible that an AQCR may have air quality levels below standard at
present and may require more strict regulations than currently exist if all
fuel burning sources were converted to dirtier fuels, i.e., "average" emis-
sion rate now may be below "average" regulations.
                                     33

-------
                                     B- 1  Candidacy  Assessment for Relaxation of Participate  Regulations/Fuel  Switch Potential

AqcR
)94
Cans as
Missouri
• -,
095(NE)
096(NC)
097 (NW)
098(SE)
099 (SC)
100(SW)
Air Quality
	 # Monitors
jr Showing

14 9 -
19 12
33 2T
10 3
6 1
5 2
6 4
15 .5
5 . 1

Expected
Attainment
Date

7/75


7/75
7/75
7/75
7/75
7/75
7/75

Total
Emissions
(103 tons)

42
36
7E
44
23
13
184
40
37
r.
Any
Counties
AQMA
Designations?

Mo


No
No
No
No
No
No

% Emission
from Fuel
Combustion

15
55-
3T
8
4
5
3
8
2
Tolerance
•fn y
Emissions
Increase
(10J tons)

0


0
0
0
0
0
0

Overall
Regional
Evaluation

Poor Candidate


Poor Candidate
Marginal candidate
Marginal candidate
Poor Candidate >
Poor Candidate
Marginal candidate
CO

-------
                                      B-2.   Candidacy Assessment for Relaxation of S02 Regulations

094
Kansas
Missouri
095 (NE)
096(NC)
097(NH)
098(SE)
099(SC)
100
Air Quality
# Monitors
ff Showing
n o
i? 0
T8
IT 0
4 0
5 0
3 0 '
6 Q
2? 0
Expected
Attainment
Date.
a
a .
a
a
a
a
a
Total
Emissions
(103 tons)
28
176
20T
14. ft
4.2
2.3
,32.9
11.9
1.8
Any
Counties
AQMA
Designations?
No
No
No
No
No
No
No
% Emission
from Fuel
Combustion
68
94
90
89
38
43
25
42
47
Tolerance
for
Emissions
Increase
(10J tons)
6
39
45
b
b
b
b
7.14
b
Overall
Regional
Evaluation
Good candidate
G6dd candidate
Good candidate
Good candidate
Good candidate
Good candidate
Good candidate
co
en

-------
                                  APPENDIX C
                            POWER PLANT ASSESSMENTS
     This section is a review of individual  power plants by AQCR.   The
intent is to illustrate:  (1) current SOg and particulate emissions, (2)
fuel switching possibilities, and (3) allowed emissions for power plants
based on current regulations.  The total AQCR emissions resulting from
possible fuel switches is then calculated.
     Current power plant information used to prepare Table C-l  were obtained
from three main sources:  (1) Federal Power Commission computerized list-
ings of power plants and their associated fuel use, (2) the National Coal As-
sociation "Steam Tables" listing of power plants and fuel use in 1972, and
(3) NEDS Emissions data.1  For those plants listed by the FPC (1 above), the
1973 fuel schedule was assumed, otherwise, fuel use is for 1972.  Heat inputs
are those based on actual fuel values where known, and average  values shown
in Table C-3 were used where not known.  SOg and particulates emissions are
those associated with the fuel use shown.  In the case of particulates,
emissions were calculated using NEDS emissions factors applied  to the listed
fuel schedule (in both tonnage and lbs/10  Btu).  When a plant  was not listed
in NEDS, AP 42 emission factors were used to estimate SO^ and particulate
emissions (see Table C-3).
     Table(s) C-l also lists allowable emissions calculated by  applying current
regulations to the given plant, taken from Table A-12.  (Particulate limits are
assumed to be based on the entire heat input of the plant.  Actual rules may
be different when applied to each of several boilers in a power plant or ap-
plied on the basis of design capacity rather than actual amount of fuel used.)
     Total fuels, emissions, and allowables are summed for each AQCR at the
bottom of Table(s) C-l,and are shown again in Tables C-2 for comparison after
fuel switch.  Plants are switched entirely to coal where possible,and to 2.0%
sulfur oil if a plant cannot use coal.  The fuel switch calculations are in-
tended to show the magnitude of emissions increase accompanying a fuel switch
without additional controls.  The exact emissions would depend  upon actual
fuel .mix, amount of sulfur in fuels, and degree of emissions controls accompany-
ing a fuel switch.
]NEDS Data Bank 1974
                                       37

-------
     It might be cautioned that AQCR total  emissions  calculated in the
tables of Appendix C (and also Appendix D)  may not agree exactly with total
emissions represented in Appendix A (Tables A-7, A-8).   This is a result of
both differing fuel  schedules in 1973 compared to previous years and the
relative "completeness" of the NEDS data bank.  Along the same line, AQCR
totals may contain a "mix" of 1972 and 1973 fuel schedules (and resulting
emissions).  The intent of the listings is  not great  precision, but rather
to show approximate status relative to regulations at present, and to show
results of fuel switching where possible.
     Table C-4 lists power plants under construction  or consideration for the
near to medium term  fiiture.  No evaluation  of these plants is attempted here
since Federal new source performance standards would  apply.  It is not the
purpose of this report to evaluate such standards.  Inclusion of new plants is
for background information which might have a bearing on other decisions about
emission regulations in an AQCR.
                                    38

-------
                                       Table C-l.   Kansas Power Plant Characterization - AQCR 094
AQCR
094
-



094

^970
Plant Name
Kaw
151 MW

Quindaro #2

Quindaro #3


TOTALS

103 tons; (
controls for
Fuel Use
Type (CS Heat
% Sulfur AnnuaH7 Input
{ Ash Quantity (106Btu/hr)
Coal 72.1 -199
3.85
12. 8A
Gas 7092 808
Coal 13.8 37.5
Gas 2774 316
757
Coal 187 487
2. OS
11. 5A
Gas 7615 868
T35T

Coal 273 724
Gas 17481 1992
27T7
il - 103 BBL; Gas - 106 ft3
parti culates applied to 1973
Emissions
S02
Existing
tons/yr lbs/106Btu
5323 1.21

965 0.62

7290 1.23


13578

fuel schedule
Allowable
tons/yr lbs/106Btu
13230 3.0

4638 3.0

17780 3.0


35648 3.0


Parti culates
Existing
tons/yr lbs/10 Btu
347
53
4W .09
2&
21
47 .03
30(P
57
357 .06

800


Allowable
tons/yr lbs/10 Btu
926 0.21

401 0.26

1128 0.19


2455


^ame degree of control assiiw*. as Guindaro #2
CO

-------
Table C-l.  Kansas Power Plant Characterization - AQCR 095
AQCR
095





095


Plant Name
Lawrence
613 MW


Tecumseh
346 MW


Municipal
Power Plant
(Brown Co.)

TOTALS


^0, control 985%
Fuel Use
Type , Heat
% Sulfur Annual' Input
% Ash Quantity (106Btu/hr)
Coal 172 477
3.9S
12. 8A
Oil 287 192
2. IS
Gas 24415 2787
Coal 142 397
3.9S
12. 9A
Oil 70 47
1.9S
Gas 8321 949
T39T
.Oil 5.2 3.5
l.OS
Gas 7300 830
S3T

Coal 314 874
Oil 363 242
Gas 40036 4556
§61?

Emissions
SO?
Existing
tons/yr lbs/106Btu
203(F 0.99
29


-------
Table C-l.  Kansas Power Plant Characterization - AQCR 096
AQCR
096
096
Plant Name
Abiline
34 MW
McPherson 1
26 MW
McPherson 2
32 MW
Clay Center
12.5 MW
TOTALS '
Fuel Use
Type , ' Heat
% Sulfur Annual1 Input
Z Ash Quantity (106Btu/hr)
Oil 21 . 14-
1.9S
Gas 1707 195
259"
Oil 0 0
Gas 249 29
29"
Oil 8 5.4
2. OS
Gas 1819 207
717
Oil 1 0.7
2. OS
Gas 485 55.3
56
Oil 3Q 20
Gas 4270 486
Emissions
S02
Existing
tons/yr lbs/106Btu
127 0.14
T27
0
"ff
53 .06
5J
7 .03
—
187
Allowable
tons/yr lbs/106Btu
2746 3.0
381 3.0
2786 3.0
736 3.0
6649 3.0
Parti culates
Existing
tons/yr lbs/106Btu
4 .019
13
T7
.02
2
T
1 .02
14
TT
0.17 .02
4
4
38
Allowable
tons/yr Ibs/lCTBtu
265 0.29
60 0.47
270 0.29
98 0.40
693

-------
Table C-l.   Kansas Power Plant Characterization - AQCR 097
AQCR
097

097
Plant Name
Mullergren
119 MW
Ross Bch 1
13 MW
Hays
19 MW
Colby
12 MW

TOTALS
Fuel Use
Type .. Heat
% Sulfur Annual Input
% Ash Quantity (106Btu/hr)
Oil 34 23
1.4S
Gas 6571 749
772
Oil 17 12
2. OS
Gas 3146 359
ITT
Oil —
Gas 1259 144
TO"
Oil 7 5
2. OS
Gas 1034 118
T2I

Oil 58 40
Gas 12010 1370
Emissions
SO?
Existing
tons/yr lbs/106Btu
158 .05
112 .07
"
46 .09

316
Allowable
tons/yr lbs/106Btu
10145 3.0
4875 3.0
1892 3.0
1616

18530
Parti culates
Existing
tons/yr 'Ibs/lCTBtu
6 .02
49
55
3 .02
24
27
.01
9
"9
1 .02
8
T

100
Allowable
tons/yr lbs/10°Btu
750 0.22
422 0.26
201 .32
178 .33

1551

-------
                                        Table C-1.   Kansas Power Plant Characterization - AQCR 098
AQCR
098






Plant Name
Riverton
155 MW


Neosho
113 MW


Coffeville
40 MW

Chanute
19 MW

lola
14MW
Fuel Use
Type 1 Heat
% Sulfur Annual1 ^put
% Ash Quantity (106Btu/hr)
Coal 39 _ 112
3.8S
11. 6A
Oi 1 39 26
2.2S
Gas 5246 598
736
Coal 1.0 2.6
2.6S
11. 2A
Oil 104 70
2S
Gas 4494 512
58T
Oil 9 6
2. OS (est)
Gas 1611 184
T90"
Oil 6 4
2. OS
Gas 850 97
ToT
Oil
Gas -180 21 •
7T
Emissions
S02
Existing
tons/yr lbs/106Btu
2904 0.99
282
3ll6
50
703
"753
59 ?31
59
40 .09
W
— ••
Allowable
tons/yr lbs/106Btu
9672 3.0


7687 3.0


2497 3.0

1330 3.0

275 3.0
Particulates
Existing
tons/yr 1bs/106Btu
1100
6.6
39
TW .36
80
17
34
T3T .05
2 .02
12
IT
1 .02
6
~J
.01
1
Allowable
tons/yr lbs/10°Btu
709 .22


589 .23


250 .30

154 .35

46 .50
CO
          098   TOTALS
                             Coal
                             Oil
                             Gas
 .  40
  158
12381
 115
 106
1412
                                                          4038
                                     21462
                                            1299
1748

-------
AQCR
099
Plant Name
Evans
539 MW
GUI
348 MW
Ripley
87 MW
Hutchlnson
257 MW
Winfield
45 MW
s
Wellington
14 MW
Fuel Use
Type , "eat
% Sulfur Annual1 Input
X Ash Quantity <106Btu/hr)
Oil 4.6 - 3
1.2S
Gas 27394 3123
3T26"
Oil 97 65
1.1S
Gas 14913 1700
T7BT
Oil 5.0 3.4
2.0 (est)
Gas 3807 ' 434
417
Oil 91 61
1.7S
Gas 16149 1841
TW
Gas 1117 127
Oil 0 0
Gas 760 87
8T
Emissions
S02
Existing
tons/yr lbs/106Btu
17 .001
T7
350 .20
350"
33 .08
499 .06
_« __
—
Allowable
tons/yr lbs/106Btu
41000 3.0
23192 3.0
5742 3.0
24992 3.0
1670 3.0
1143 3.0
Parti culates
Existing ,
tons/yr lbs/10 Btu
1 .02
205
2G6V
16 .02
117
T3J
8 .02
28
35-
15 .02
121
73S
8 .01
-8~
.01
6
6"
Allowable
tons/yr lbs/106Btu
2190 .16
1391 .18
479 .25
1500 .18
.83 .33
137 .36
099   TOTALS
                    Oil
                    Gas
  198
64140
 132
7312
                    899
                        97739
515
5880

-------
Table C-l.  Kansas Power Plant Characterization - AQCR 100
AQCR
100

100
Plant Name
Cimarron
50 MW
Judson
Large
180 MW
Garden City
27 MW
Pratt
28 MW
Larned
1.3 MW

TOTALS
Fuel Use '
Type . Heat
% Sulfur Annual1 Input
* Ash Quantity (106Btu/hr)
Gas 3485 397
Oil 130 87
0.77S
Gas 6591 751
836~
Oil
2.0
Gas 1135 129
T29~
Oil 1 0.7
2. OS
Gas 614 70
7T
Oil 0.5 0.3
2. OS
Gas 480 55
/...... 	 ' 55"


Oil 131 88
Gas 12305 1402
Emissions
S02
Existing
tons/yr lbs/106Btu
—
326 .09

7 .02
3 .01

336
Allowable
tons/yr lbs/106Btu
5217 3.0
11011 3.0
1695 3.0
933 3.0
723 3.0

19579
Particulates
Existing
tons/yr Ibs/KTBtu
26 .01
26
21 .02
49
70-
.01
.02
5
¥
.08 .02
4
T

113
Allowable .
tons/yr lbs/106Btu
415 .25
771 .21
186 .33
118 .38
96 . .40

1586

-------
C-2 Kansas
,  AQCR 094   Fuel Switch Evaluation (Rower Plants)
Fuel
Coal
Oil
Gas
Emissions
sb2
Parti culates
(1) fCoal - 1
> V
Present Use
Quantity^ho9 BTU/Y
273 6340
0 0
17481 17481
23821
Tons/y Lbs/106 Btu
13578 1.14
800 .067
) tons
\3 BBl
)6 ft3
Gas & Oil} to coal
Quantity 109 BTU/y
1026 23820
0 0
0 0
23820
Tons/y Lbs/106 Btu
56680 4.76
2892 0.24.
• #
Gas to oil (2-.3K S) only
Quahtity 109 BTU/y



.






•

AI lowaoie
Emissions
Under Existing
Regulations
Tons/y Lbs/106 Btu
35648 3.0
2455 0.21


-------
                                        C-2  Kansas
, AQCR 095   Fuel Switch Evaluation(Power  Plants)

Fuel
al
1
5



Emissions
s62
rtitulates
Present Use
Quantity 109 BTU/y
314 7660
364 2120
40035 40036
49816


Tnn<:/y IbS/lQ6 BtU
13456 0.54
2886 0.12
Gas & Oil } to coal
Quantity 109 BTU/y
1830 42500
1250 7500
\ 0 0
49816
•

Tons/y Jb«/m6 Rtu
61270 2.46
9790 0.39-
Gas to oil only
Quantity 109 BTU/y













Allowable
Emissions
Under Existing
Regulations
Tnnc/« 1 he/in" Rtn
74674 3.0
4197 0.17
Oil





Gas

-------
                                             C-2  Kansas         . AQCR   096 Fuel Switch Evaluation  (Power Plants)

Fuel
Coal
on
Gas




. Emissions
so2 '
Parti cul ates
Present Use
Quantity 109 BTU/y
0 0
30 175
4270 4270
4445



Tons/y Lbs/106 Bti
187 .084
38 * .017
Gas & Oil} to coal
Quantity 109 BTU/y
0 0
- '

4445
..




.
Gas to oil only
Quantity 109 BTU/y
0 0
762 4445
0 0
4445



Tons/y Lbs/106 Btu
4978 2.2
• 129 .058




Allowable
Emissions
Under Existing
Regulations
Tons/y Lbs/106 Btu
6650 3.0
693 0.31
00

-------
C-2 Kansas         , AQCR 097   Fuel Switch Evaluation  (Power Plants)

Fuel
Cdal
Oil
Gas





Emissions
l
so2
Particulates
Present Use
Quantity 109 BTU/y
0 0
58 338
12010 12010
12350




Tons/v Lbs/106 Btu

316 .05
100 ' .016
. Gas & Oil} to coal
Quantity 109 BTU/y
0 0
-


• :
".




-
J4.
Gas to oil (2.0% S) only
Quantity 109 BTU/y
0 0
2120 12350 •
o; o
12350




Tons/v Lbs/106 Btu-

14019 2.3
363 .06





Allowable
Emissions
Under Existing
Regulations
Tons/v Lbs/lQ6 Btu

18530 3.0
1551 0.24

-------
C-2  Kansas
,  AQCR  098  Fuel Switch Evaluation  (Power Plants)
Fuel
Coal
Oil '
Gas
Emissions
so2 '
Parti culates

Present Use
Quantity 109 BTU/y
40 1008
158 928
12381 12381
14317
Tons/y Lbs/106 Btu
4038 0.56
1298 - .18
•
Gas & Oil} to coal
Quantity 109 BTU/y
500 11589
15 88
2640 2640
14317
Tons/y Lbs/106 Btu
30,450 4.25
25,000 3.5
?*-
Gas to oil only
Quantity 109 BTU/y
-



Allowable
Emissions
Under Existing
Regulations
Tons/y Lbs/106 Btu
21462 3.0
1748 .24-


-------
C-2    Kansas        , AQCR  099  Fuel Switch  Evaluation (power Plants)

Fuel
:oal
Ml
Jas




Emissions
X
sb2
"ticulates
Present Use
Quantity 109 BTU/y
0 0
198 1156
644140 64140
65294



Fons/y Lbs/106 Btu
899 .027
5t5 .016
Gas & Oil} to coal
Quantity 109 BTU/y
-
-


( *




•
Gas to oil only
Quantity 109 BTU/y
0 0
11184 65294-
0 =0
RC7Q/1



Tons/y Lbs/106 Btu
73,770 2.3
1,910 .058




Allowable
Emissions
Under Existing
Regulations
Tons/y Lbs/106Btu
97,740 3.0
5,880 .18

-------
                                                 C-2  Kansas         ,  AQCR  TOO  Fuel  Switch Evaluation  (Power  Plants)
ro

Fuel
Coal
Oil
Gas





Emissions
\
sb2
Parti culates
Present Use
Quantity 109 BTU/y
0 0
131 771
12305 12305
13076




Tons/y Lbs/106 Btu
336 .05
113 .017
Gas & Oil} to coal
Quantity 109 BTU/y
-



•
-. ~



-
'' '
Gas to oil only
Quantity 109 BTU/y
0 0
2222 13076
0 • 0
13076




Tons/y lbs/106 Btu
15,070 2.30
390 .06




Allowable
Emissions
Under Existing
Regulations
Tons/y Lbs/106 Btu
19,600 3.0
1,586 %23

-------
                                           Table C-3. AP-42 Power Generation Emission  Factors
en
oo
Fuel
CoalWfeit.)
General
Wetbottom 10% A
Cyclone
1% S
2% S
3% S
011<2> .
0.5% S
1.0% S
2.0% S
Gas'3)
(.3 Ibs S/
fi -3
105 Ft3)
Hart
Lbs/Ton
160
130
20
Same
as
Above
1 culates
Lbs/10° Bti
7.4
7.0
0.9
Same
as
Above
Lb/103 Gal
8
8
8
Lb/106Ft3
15

0.058
.058
.058

.015

S0£
j Lbs/Ton L



38
76
114
Lb/103 Gal
79
157
314
Lb/106Ft3
bs/106 Btu



K65
3.3
5.0
Hydrocarbons/.
Lbs/Ton Lbs/10° Btu
0.3

.
0.3


0.013


0.-OT3


Lb/103 Gal
0.56
1.12
2.24

2
2
2
Lb/106Ft3
0.57 .00057 i



.014
.014
.014

.001

NO*
Lbs/Ton
18
30
55
' Same
as
Above
(as N02]
Lhs/"ifl6 Rtn
UU3/ 1 V O LU
0.78
1.3
2.4
Same
as
Above
Lb/103 Gal
105
105
105
Lb/106Ft3
600

0.75
0.75
0.75

0.60

         (1) Coal  23 x 106 Btu/Ton


         (2) Oil  140 x 103 Btu/Gal

         (3) Gas 1000 Btu/Ft3

-------
                              Table C-4.  Kansas New and Proposed Power Plant2

AQCR
098

sched

sched
095



sched





Plant Name
Lacygne #1
840 MW
(1973)
#2
630 MW
(1977)
Kansas Power
& Light
(Topeka)
700 MW
(1978)
'



Fuel Use
Type , Heat
I Sulfur Annual1 InP"t
t Ash Quantity (106Btu/hr)
Coal 2200® 6027
4.1
19. 7A
Coal 1700^
3W

Coal 2350^




-


-
Emissions
S02
Existing
tons/yr lbs/106Btu
17lfl>


NA


NA







Allowable
tons/yr lbs/106Btu
31680 1.2


NA

1.2








Parti cu ates
Existing
tons/yr lbs/10 Btu
2820


NA


NA







Allowable
tons/yr lbs/106Btu
2640® 0.1


NA

0.1








^Approximate coal  usage  at  start up ."Assessment of the Impact of Air Quality Requirements on Coal  in  1975,  1977,  1980,"
 U.S.  Bureau of Mines, January  1974.  Emissions are from NEDS.
"tPA data  bank  listings,  Sept.  1974

-------
                                   APPENDIX D
                    INDUSTRIAL COMMERCIAL SOURCES ASSESSMENT

     The Tables D-l in this appendix list individual  industrial/commercial/
institutional sources of particulates and S02 emissions which might show
fuel switching potential.  The sources are from a NEDS rank order emissions
listing.  Tables D-l account for at least 95% of a total emissions (both
fuel and non-fuel sources) in the AQCR, since not all  industrial  sources
could be listed in this report.  It should be cautioned that the  percent
emissions accounted for is different than the "% of fuel use accounted for."
It is possible that several potential fuel switch sources could be over-
looked by the cutoff point on the emissions (i.e., a reasonable sized
natural gas used may emit below our cutoff point in the NEDS rank order
list).
     Fuel switch emissions calculations were not made for industrial sources,
since no information was available for feasibility of any fuel switching.
Current fuels and emissions are listed along with the emissions which would
be allowed by existing regulations.
                                    55

-------
                 Table 0-1.   Industrial-Commercial  Fuel  Combustion Point Source Characterization  £ansas
'. " ' 1
AQCR
094
094
.
094
_
Totals
Plant Name
GM Assembly
Direct Fuel
Combustion
Delco-Remy
j
Mftnnl ii
UUUl !•» CO%/A>y
[ * zooo
••
It
1


l
Fuel Use
Type
% Sulfur
% Ash
Oil^
Gas'2'
Oil
1.82 S
Gas
Oil*
2.42
Gas
Oil
1.52 S
Gas

Oil
Gas
Annual (1]
Quantity
9174
840
225
576
585
705
2560
183

3370
1464
Heat
Input
(106 Btu/hr)
147
95.9
3.6
65.8
~59~
9.3
80.5
40.9
20.9
~go

53.9
167
Emissions
SO?
Existing | Allowable
tons/yr

32
"37
111
TTT
241
24T

384

lbs/10*
Btu

0.08
0.28
0.89



1
tons/yr

907
1189
812

3201

lbs/10*
Btu

3.0
3.0
3.0



Particulates
Existing
tof)
        (l)|Coal - tons

          [Oil - 10^ gallons
           Gas - 106 ft3
(2)   Inprocess  fuel  use

-------
          Table  0-1.    Industrial-Commercial Fuel Combustion Point Source Characterization Kansas
AQCR
095
095
095
095
Totals
Plant Name
Atchison, Topeka,
Santa Fe
Mode C. Day
Co-op Farm
Chemical
Midwest Solvents

Oil
Gas
Fuel Use
Type
% Sulfur
% Ash
Oil
0.5X S
Gas
Gas
Gas
Gas<2>
Oil
1.65XS
Gas



Annual
Quantity
560
858
3500
1600
315
735
1638

1295
7596
Heat
Input
(106 Btu/hr)
8.9
97.9
1U6~
400
183
36.0
11.7
187
231—

20.7
867
Emissions
S02 | Particulates
Existing | Allowable | Existing
tons/yr
22
1
132
65
~6T

??n

!bs/10<
Btu
0.05
<.01
0.16
0.06



tons/vf
1390
5256
2405
3090

i?i an

lbs/10f
Btu
3.0
3.0
3.0
3.0



tons/vf
6
8
W~
32
18
114
9
15
T38"
•
202

lbs/10C
Wu
0.03
0.02 _,
0.02
0.13



Allov/able
tons/y
163
438
240:
298

11,19

lbs/10f
Btu
0.35
0.25
0.30
0.29


i
(2)   Inprocess Fuel Use

-------
                Table D-l.   Industrial-Commercial Fuel Combustion Point Source Characterization
                                                                                                 Kansas
AQCR
096
096
096"
•Totals
Plant Name
"0002"
Supersweet Feeds
Northern Gas
Products
-
Gas

Fuel Use
Type
% Sulfur
% Ash
Gas
Gas
Gas



Annual
Quantity
5250
5080
9793

20123

Keat
Inout
(106 Btu/hr)
599
580
1118

9707

Emissions
S02
Existing | Allowable
tons/yr
2
2
0

a.

lbs/10*
Btu
<.01
<.01




tons^yr
7870
7620
14690

10180

fbs/10*
Btu
3.0
3.0
3.0



Particulates
Existing 1 Allowable
tons/vr
47
46
70

163

lbs/10e
Btu
0.02
0.02
0.01

fcbs/10*
tons/^r! Btu
603
584
979

12166 i

0.23
0.23
0.20
i

i
op

-------
                Table D-l.    Industrial-Commercial Fuel Combustion Point Source Characterization  -
AQCR
097
097
097
Totals
Plant Name
Sherman Co.
CRA
Centr. Tel. and
Utilities
:
Oil
Gas
Fuel Use
Type
% Sulfur
% Ash .
Oil
1.0%S
Gas
Gas
Oil
0.18%
Gas



Annual
Quantity
345
948
1400
• 4
2320

349
4668
Heat
Input
(106 Btu/hr)
5.5
108
160
0.06
265
265—

5. ft
533
Emissions
S02 | Parti culates
Existing j Allowable | Existing j Allowable
tons/yr
27
—
-

77

lbs/10<
Btu
0.05





tons/vr
1498
2100
3480

7080

lbs/10f
Btu
3.0
3.0
3.0



tons/vr
3 .
9
T2~
11
17

35

lbs/10*
Btu
0.02
0.02
0.01



Lons/yr
170
217
324

!bs/106
5tu_.
0.34
0.31
0.28
i
71?

10

-------
                Table  D-l.    Industrial-Commercial  Fuel  Combustion Point Source Characterization


AQCR

098




098




098






- Total s




Plant Name

Gulf Oil Chem.




Gulf Oil Corp.




Kansas Army
Ammo. Plant





Coal
nil
Gas
Fuel Use .

Type
% Sulfur
% Ash
Coal
3.5XS
12. OS A
Gas

Coal
3.1XS
1.2XA
Gas

Coal
3.27%S
9.0% A
Oil
2.0XS




	
Annual
Quantity

4560

931


2000

938


1980


1112


R54n
1112
1869
Heat
Input
(106 Btu/hr)

12.0

106
178 	

5.3

107
TF2 —

5.2


17.8
23 .D

77 a.
17 fl
213
Emissions
S02 | Particulates
Existing | Allowable | Existing J Allowable
tons/yr

303

_


118

_


123


227
3lO~

77T


lbs/10*
Btu


0.59




0.24




3.5







i
tons/vr


1541




1471




300




3312


lbs/10e
Btu


3.0




3.0




3.0







tans /XT

465

8
47T

146
/»
8
T54"

23


34
~57

fiftd


lbs/10f
Btu


0.92




0.31




0.57




tons/^i


175


s

168




49




•?Q9




lbs/10*
_ltiL_


0.34




0.34




0.49




•


Ot
G3

-------
Table D-l.    Industrial-Commercial Fuel Combustion Point Source Characterization  KaPsas
AQCR
099
099
099
totals
Plant Name
Sedgwick Co.
Sedgwick Co.
Skelly Oil



Fuel Use
Type
% Sulfur
% Ash
Oil
2.0XS
Gas
Oil
l.XS
Gas
Oil
0.702S
Gas

nn
Gas
Annual
Quantity
1102
833
4644
507
3390
2690

9136
4030
Heat
Input
(106 Btu/hr)
17.6
95.1
112.7
74.2
57.9
132.1
54.2
307
3TTT2"

Idfi
460
Emissions
S02 | Particulates
Existing
tons/yiq
125
181
168
«*

47*

lbs/10*
Btu
0.25
0.31
0.11



Allowable | Existing j Allowable
tons/yr
1500
1752
4582

7834

lbs/10e
Btu
3.0
3.0
3.0



tons/vr
10
13~
40
4
44
25
24
W

106

lbs/10£
Btu
0.03
0.08
0.03



tons/y
168
190
411

769

lbs/106
&ta_.
0.34
0.33
0.26




-------
                    Table  D-1.    Industrial-Commercial  Fuel  Combustion Point Source Characterization  -  Kansas
AQCR
100
100
100
!
_
Totals
Plant Name
Farmland Ind.
Inc.
Colomeian Carbon
Cent. Telephone
and Utilities
(
i
•


Fuel Use .
Type
% Sulfur
% Ash
Gas
Gas
Oil
l.OXS
Gas

Oil
Gas'
Annual
Quantity
990
900
319
6230

31 
-------
                                   Table D-2.  Major  Industrial  Fuel  and Emissions Summary for Kansas
AQCR

094
095
096
097
098
099
100
Stlte Totals*
Fuel Acounted For •
Coal
Tons
0
0
0
0
8540
0
0
8540 '
103 Gal.
Oil
3370
1295
0
349
1112
9136
319
15587
106 ft3
Gas
1464
7596
20123
4668
1869
4030
8120
47870
so2
Existing
Emissions
(Tons)
384
220
4
27
771
474
27

Al 1 owed
Emissions
(Tons)
3200
12140
30000
7080
3312
Z834
12245

Particulates
Existing
(Tons)
...51
202
163
35
684
106
65

Allowed
(Tons)
390
1140
2166
712
392
769
1016

en
CO
             Only major emission sources are accounted for in totals.

-------
                               APPENDIX E
                         AREA SOURCE ASSESSMENT

     Table E-l shows area source fuel use for the State of Kansas by AQCR.
The approximate energy values are compared for each fuel along with tbe
percent of overall energy derived from each fuel.  Data are those in NEDS
as of November 1, 1974.  State area source totals are calculated and the
percent of energy derived from each fuel shown.
     Area source fuel use is then compared to total fuel use in Kansas.  The
bottom row entitled "all fuels, all sources" may not match totals from
Appendices A, C, and D exactly, since neither the NEDS or individual appendix
totals are all-inclusive.
                                       65

-------
                                              Table E-l.  Area Source Fuel  Use
Kansas
en

AQCR
094
(Kan + Missouri)
. 095
096
097
098
099
100
1


Area Source Total
Percent
Coal
Tons
76750

20680
11430
7270
34060
22500
5450



78140

109 Btu
1765

476
263
167
783
518
140



4112
(l.tt)
Oil
103 bbl
737

421
239
155
245
666
206



2669

109 Btu
4334

2475
1405
911
1441
3920
1210



15696
Gas
1C3 ft3
109290

46730
39970
28720
39100
93620
29370



386810
(3.9*) j
109 Btu
. 109290

46730
39970
28720
39100
93630
29370



38681.0
(95. OX)
Total
1012 Btu
115.4

49.7
41.6 '
t
29.8
41.3
98.1
30.7

i
I
407 i
100% j
State Total (all fuels, all sources) 996 x 10"B1^
                      1) NEDS data bank, Nov. 1, 1974.
                      Notes- 42X of fuel use 1n Kansas 1s by area sources.

-------
                                 APPENDIX F
                  REGULATION EVALUATION AND FUEL STATISTICS

     The Tables F-l and F-2 illustrate the effect on emissions of particu-
lates and S02 when power plant and industrial  fuel burning sources listed
in Appendices C and D are allowed to emit up to the amounts that existing
regulations would allow.  It is assumed that heat input remains the same,
and existing regulations are applied to gross heat input for each power plant
and industrial source.  The column in Table F-l labeled "Allowable Total Emis-
sions" is the tonnage from Tables A-9 and A-10 which the region can tolerate
while still not violating ambient air quality standards.  In Table F-2 (SOp
Evaluation) the analogous column indicates the ratio of emissions resulting
when all sources are emitting at regulations to emissions at present.
   Area fuel burning sources are assumed to remain unchanged, since SOp
and particulate regulations generally do not apply to these sources.  Non-
fuel emission estimates from Tables A-7 and A-8 are included in the balance.
Since the degree of control which will be achieved on non-fuel particulate
sources was not known for this report, the particulate totals serve mainly
to show magnitudes relative to tonnage allowed by air quality considerations.
For SOp the non-fuel estimate would, in many AQCR's, remain about the same
due to lack of other SO- regulations (except oil smelters).  Thus,the S02
"roll up ratio" is not too far from that which would be possible under exist-
ing regulations.
   A regional approach is implicitly assumed to have some validity in this
exercise, so that any conclusions from the numbers in Tables F-l and F-2
will have to be temperated for AQCR's with widely dispersed emissions.
   Lastly, it is emphasized that these tables are hypothetical in that no
fuel mix may exist to allow all sources to emit exactly at regulation levels.
The calculations do give some insight into adequacy of existing regulations for
allowing air quality standards to be achieved if a fuel schedule different from
the one at present were in effect.
   A Table F-3 is included in this appendix to summarize gross consumption and
production of fossil fuels in Kansas.
                                        67

-------
                                         Table F-l.   Particulate Regulation Evaluation - Kansas
,00
AQCR
094 (Kansas only
Power Plants
Industry
Area Sources

Non-Fuel
Total
095
Power Plants
Industry
Area Sources

Non-Fuel
Total
096
Power Plants
Industry
Area Sources

Non-Fuel
Total
1012 Btu

23.8
1.95
44.2

0
141.15

49.8
7.78
49.7

0
107.28

4.45
20.1
41.7

0
66.25
Current Emissions
Tons/yr

800
51
5800
6651
35900 J
42,551

2886
202
1100
4188
40800
44,988

38
163
700
901
22500
23,401
Regulations
lbs/106 Btu

~0.2
.2 - .5


__,


«0.2
.2 - .5





~0.3
.2 - .5




Emissions
with All Sources
Emitting at Reg's

2455
390
5800
8645
39S900
44,545

4200
1140
1*00
6440
40800
47,240

693
2166
700
3559
22500
26.059
Estimate Allowable
Emissions in AQCR
tons/yr






6300






i
12,200 !
!





6,900

-------
Table F-l.  Particulate Regulation Evaluation -  Kansas (Continued)
AQCR
097
Power Plants
Industry
Area Sources

Non-Fuel

Total
098
Power Plants
Industry
Area Sources

Non-Fuel

Total
099
Power Plants
Industry
Area Sources

tfon-Fuel
'

Total
i
1012 Btu

12.3
4.7
29.8

0

46.8

14.3
2.22
41.3

0

57.8

65.3
5.35
98.1

0


168.75
Current Emissions
Tons/yr

•100
35
470
605
12700

;13i305

1300
684
1100
3084
179,000

182,084

515
106
2500
3121
' 36,900


40,021
Regulations
lbs/106 Btu

.24
.2 - .5






/v.24
.2 - .5






.2
.2 - .5





•" - --:
Emissions
with Al 1 Sources
Emitting at Reg's

1550
712
"470
2732
12700

,115,432

1750
392
1100
2242
179.000

182,242

5880 .
769
2500
9149
36.900


46,049
Estimate Allowable
Emissions in AQCR
tons/yr






i
6,600







100,000 ]
(
1

i
I
(
i
•;
•
i
8,000

-------
Table F-l.  Participate Regulation Evaluation - Kansas (Continued)
AQCR
100
Power Plants
Industry
Area Sources

Non-Fuel
j Total
Power Plants
Industry
Area Sources

N'on-Fuel
Total
Power Plants
Industry
Area Sources

Hon-Fual
Total
1012 Btu
13.1
8.17
30.7

0
51.97








Current Emissions
Tons/yr
113
65
500
678
36,500
37.178








Regulations
lbs/106 Btu
.23
.2 - .5











Emissions
with All Sources
Emitting at Reg's
1590
1016
500
31flfi
36,500
39,606








Estimate Allowable
Emissions in AQC?>
tons/, r


.
24.000




!




-------
Table F-2.  SCL Regulation "Evaluation - Kansas
AQCR
094
(Kansas Only)
Power Plants
Industry
Area Sources

I:,-/- -Fuel
Total
i
i
095
Power Plants
Industry
Area Sources

flon-Fuel
Total
096
Power Plants
Ir.dustry
Area Scurcc-s

Non-Fuel
Total
1012 Btu

23.8
1.95
44. 2 ^

0
141.15



49.8
7.78
49.7

0
107.28

4.45
20.1
41.7

0
66.25
Current
Emissions
tons/year

13578
384
8600
22562
9090
31,652



13456
220
2600
16276
1580
17,856

187
4
1400
' 1591
2600
4,191
Reg'i
lbs/106
Btu

3.0








3.0






3.0





Emissions
with All Sources
Emitting at Reg's

35648
3200
8600
47448
9090
56,538



74674
12140
2600
89414
1580
90,994

6650
30000
1400
38050
2600
40,650
Estteted Allrwable
Emissions fo.
AQCR
Kansas Only






34,000
Ratio of Ec.fssions at
Regulat ons to Current
Emissions






+ 1.78
f



N/A






N/A











+ 5.10






+ 9.7

-------
Table F-2.  SO, Regulation"Evaluation - Kansas (Continued)
AQCR
097
Power Plants
Industry
Area Sources

Non-Fuel
Total
098
Power Plants
Industry
Area Sources

fl on -Fuel
TctaT
099
Power Plants
Industry
Area Sources

Non-Fuel
Total
i
1012 Btu

112S3
4.7
29.8

0
46.8

14.3
2.22
41.3

0
57.82

65.3
5.35
98.1

0
168.75
Current
Emissions
tons/year

316
27
870
1213
1310
2523

4038
771
3500
8309
24675
32,984

899
474
4100
5473
• 6900
12,3731
Reg's
lbs/106
Btu

3.0






3.0






3.0





Emissions
with All Sources
Emitting at Reg's

18530
7080
870
26480
1310
27790

21462
3312
3500
28274
24675
52.949

97740
7834
4100
109674
6900
116,574
Estimated Allowable
Emissions for
AQCR


N/A






N/A










19.000
Ratio of Emissions at
Regulations tc Current
Emissions






* 11.0 i





1
+ 1.6


t
•'
1

+ 9.4

-------
Table F-2.  S02 Regulation"Evaluation  -  Kansas  (Continued)
ACCR
100
Power Plants
Industry
Area Sourcas

•:';ri-Fu9l
".otal
Power Plants
Industry
Area Sources

Non-Fuel
Total
Power Plants
Industry
Area Sources

lien-Fuel
Total
1012 Btu

13.1
8.17
30.7

0
51.97












Current
Emissions
tons/year

336
27
820
1183
950
2*133












Reg's
lbs/106
Etu

3.0

















Emissions
with All Sources
Emitting at Reg's

19600
12245
820
32665
950
33,615












Estimated Allc- ^Lle
Emissions for
AQCR


N/A
















Ratio . f Env.'ssions at
Regulations to Current
Emissions
I




i
> IS~.8





(


i

I
1
I

-------
                                           Table F-3.  Kansas Fossil Fuel Summary*(1972)
-si

Coal
103 tons
011
106 bbl
Gas
109 ft3
Production
1227
104
889
Consumption
495
56
633
                  All oil and gas values are from "Fuel and Energy Data: U.S. by States and Regions," 1972
                  (U. S. Bureau of Mines).  Coal consumption figure obtained from "Assessment of Impact of
                  A1r Quality Requirements on Coal 1n 1975, 1977, and 1980," (U. S. Bureau of Mines).

-------
                              BIBLIOGRAPHY
 (1)   "1972 National Emissions Report", U.S. Environmental Protection
      Agency, EPA-450/2 -74-012.

 (2)   "Projections of Economic Activity for Air Quality Control Regions",
      U.S. Department of Commerce, Bureau of Economic Analysis, Prepared
      for U.S.  EPA, August 1973.

 (3)   "Monitoring and Air Quality Trends Report, 1972", U. S. EPA - 450/1-
      73-004.

 (4)   "Steam-Electric Plant Factors/1072", 22nd Edition National Coal
      Association.

 (5)   "Federal  Air Quality Control Regions" U.S. EPA, Pub. No. AP-102.

 (6)   "Assessment of the Impact of Air Quality Requirements on Coal in
      1975, 1977 and 1980", U.S. Department of the  Interior, Bureau of
      Mines, January 1974.

 (7)   "Fuel and Energy Data", U.S. Department of Interior Bureau of Mines,
      Government Printing Office, 1974, 0-550-211.

 (8)   "Compilation of Air Pollutant  Emission Factors, 2nd Edition", U.S.
      EPA, Air  Pollution Tech, Pub.  AP-42, April 1973.

 (9)   SAROAD Data Bank, 1973  Information. U.S. EPA.

(10)   Federal  Power  Commission, U.S. Power Plant Statistics Stored in  EPA
      Data Bank, September  1974.

 (11)  "State  of Kansas  Implementation Plan for the Attainment and
      Maintenance of National Air Quality Standards," Kansas State
      Department of  Health, January  1972.

 (12)  "Air Pollution Emission Control Regulations," State of Kansas,
      January 1, 1974.
                                    75

-------
                                   TECHNICAL REPORT DATA
                            (Please read Instructions on the reverse before completing)
1. REPORT NO.
  EPA-450/3-74-076
                              2.
                                                            3. RECIPIENT'S \CCESSIOf*NO.
4.
                  PLAN REVIEW FOR KANSAS AS
  REQUIRED BY THE ENERGY SUPPLY AND  ENVIRONMENTAL
  COORDINATION ACT
             5. REPORT DATE
                  December 1974
             6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
                                                           8. PERFORMING ORGANIZATION REPORT NO.
  PERFORMING ORGANIZATION NAME AND ADDRESS
  U.S. Environmental  Protection Agency,  Office of Air
  Quality Planning  and Standards, Research Triangle
  Park, N.C., Regional Office VII,  Kansas  City, Missouri,
  and TRW,  Inc.,  Redondo Beach, California.
                                                            10. PROGRAM ELEMENT NO.
             11. CONTRACT/GRANT NO.
                  68-02-1385
 12. SPONSORING AGENCY NAME AND ADD.RESS.
  U.S. Environmental  Protection Agency
  Office of Air and  Waste Management
  Office of Air Quality Planning and  Standards
  Research Triangle  Park, North Carolina  27711
             13. TYPE OF REPORT AND PERIOD COVERED
                    Final
             14. SPONSORING AGENCY CODE
 15. SUPPLEMENTARY NOTES
16. ABSTRACT
       Section  IV of  the Energy Supply and  Environmental Coordination Act of 1974,
  (ESECA) requires  EPA to review each State Implementation Plan  (SIP) to determine
  if revisions  can  be made to control regulations for stationary fuel combustion
  sources without interfering with the attainment and maintenance of the national
  ambient air quality standards.  This document, which is also required by Section
  IV of ESECA,  is EPA's report to the State indicating where regulations might be
  revised.
17.
                                KEY WORDS AND DOCUMENT ANALYSIS
                  DESCRIPTORS
                                              b.IDENTIFIERS/OPEN ENDED TERMS
                           c. COSATI Field/Group
 Air  pollution
 State  implementation  plans
18. DISTRIBUTION STATEMENT
 Release unlimited
19. SECURITY CLASS (ThisReport)
  Unclassified
21. NO. OF PAGES
     76
                                              20. SECURITY CLASS (Thispage)
                                                Unclassified
                                                                         22. PRICE
EPA Form 2220-1 (9-73)
                                             7.6
                                          7*,

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