EPA-450/3-74-077
DECEMBER 1974
IMPLEMENTATION PLAN REVIEW
FOR
KENTUCKY
AS REQUIRED
BY
THE ENERGY SUPPLY
AND
ENVIRONMENTAL COORDINATION ACT
U. S. ENVIRONMENTAL PROTECTION AGENCY
-------
EPA-450/3-74-077
KENTUCKY
ENERGY SUPPLY AND ENVIRONMENTAL COORDINATION ACT
SECTION IV - STATE IMPLEMENTATION PLAN REVIEW
PREPARED-BY THE FOLLOWING TASK FORCE:
U.S. Environmental Protection Agency, Region IV
1421 Peachtree Street, NE
Atlanta, Georgia 30309
Energy and Environmental Systems Division
Argonne National Laboratory
Argonne, Illinois 60439
(EPA-IAG-D5-0463)
U.S. Environmental Protection Agency
Office of Air and Waste Management
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
December 1974
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IMPLEMENTATION PLAN REVIEW
FOR
KENTUCKY
Required by the Energy Supply and Environmental Coordination Act
Table of Contents
Page
1. EXECUTIVE SUMMARY . 3
2. KENTUCKY STATE IMPLEMENTATION PLAN REVIEW 8
2.1 Summary 8
2.2 Air Quality Setting for the State of Kentucky 11
2.2.1 Kentucky Air Pollution Control Areas 11
2.2.2 Kentucky Ambient Air Quality Standards . . . 11
2.2.3 Kentucky Air Quality Status 11
2.2.4 Kentucky Emission Summary 15
2.2.5 Power Plant Modeling 15
2.3 Background on the Development of the Current
State Implementation Plan 19
2.3.1 General Information 19
2.3.2 Particulate Control Strategy 19
2.3.3 Sulfur Oxide Control Strategy 19
2.3.4 Control Regulations Summary ..... 20
2.4 Special Considerations 25
2.4.1 Planned SIP Revisions ..... 25
2.4.2 Fuels 25
2.4.3 Potential Fuel Conversions 25
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STATE IMPLEMENTATION PLAN REVIEW
FOR
THE STATE OF KENTUCKY
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 control regulations for station-
ary fuel combustion can be revised without interfering with the attainment
and maintenance of the National Ambient Air Quality Standards (NAAQS). In
addition to requiring that EPA advise the State as to whether control
regulations can be revised, ESECA provides that EPA must approve or dis-
approve any revised regulations relating to fuel burning stationary sources
within three months after they are submitted to EPA by the States. The
States may, as under 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 SIPs, wherever possible, be revised in the interest of conserving
low-sulfur fuels or converting to coal sources which burn oil or natural
gas. EPA's objective in carrying out the SIP reviews, therefore, has been
to try to determine if emissions from certain combustion sources may be
increased without interference with the attainment and maintenance of
standards. If so, it may be possible through altered resource allocations
to effect significant "clean fuel savings" in a manner consistent with
both environmental and national energy needs.
In many respects, the ESECA SIP reviews parallel the implementation
of EPA's policy on clean fuels. Under the Clean Fuels Policy, implementation
plans have been reviewed with a view to saving low sulfur fuels. Where
the primary sulfur dioxide air quality standards w.ill not be exceeded, States
have been encouraged to either defer attainment of secondary standards or to
revise the S02 emission regulations. The States have also been asked to
discourage large-scale shifts from coal to oil where this could be done
without jeopardizing the attainment and maintenance of the NAAQS.
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To date, this activity has involved only those States with the largest
clean fuels saving potential. Several of these States have revised or are
currently in the process of revising their SC>2 regulations. These States
are generally in the eastern half of the United States. ESECA, however,
requires the analysis of potentially over-restrictive regulations in all
55 States and territories. In addition, the current reviews address the
attainment and maintenance of all the National Ambient Air Quality Standards.
The adoption of emission limitations which may in'some areas of States
be overly restrictive (or not restrictive enough) resulted largely from
the use of the "example region" approach along with analyses which considered
the "hot spots" of an Air Quality Control Region (AQCR) rather than the
entire region. This type of approach was offered in EPA guidelines for
plan development when States were preparing their original plans. Many
States, such as Kentucky, through concurrence with EPA, adopted the example
region approach, largely because of the short timetable dictated by the
Clean Air Act. Also, in most cases, the original SIPs were designed to
attain and maintain the original NAAQS, some of which have since been
designated as "guides" only or actually rescinded. However, many States
have adopted and retained the original Federal standards or, in a few cases
have adopted more restrictive State standards, and these served as the basis
on which their SIPs were approved. As a result, the requirements of many
State plans conflict with legitimate national energy concerns, and thus a
review of the State Implementation Plans is a logical follow-up to EPA's
initial appraisal (1972) of the SIPs. At that time SIPs were approved by
EPA if they demonstrated the attainment of the original NAAQS or the more
stringent State air quality standards. Also, at that time an acceptable
method for formulating control strategies was the use of an example region
for demonstrating the attainment of the standards.
The example region concept permitted a State to identify the most
polluted air quality control region (AQCR) and adopt control regulations
which would be adequate to attain the NAAQS in that region. In using an
example region, it was assumed that NAAQS would be attained in the other
AQCRs of the State if the control regulations were applied to similar sources.
But use of an example region can result in excessive controls, especially
in the utilization of clean fuels, for areas of the State where sources
would not otherwise contribute to NAAQS violations. For example, a control
strategy based on a particular region or source can result in a regulation
requiring 1 percent sulfur oil to be burned statewide, even though the use
of 3 percent sulfur coal would be adequate to attain NAAQS in some locations.
EPA anticipates that a number of States will use the review findings
to assist them in deciding whether or not to revise portions of their
State implementation plans. However, it is most important for such
States to recognize the limitations of the present review. 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
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EPA's best judgement 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 was found, however, it was 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
used to support EPA's findings. States are encouraged to consider the
overall impact which the potential relaxation of overly restrictive
emissions regulations for combustion sources might have on their future
control programs. This may include air quality maintenance, prevention
of significant deterioration, increased TSP, NOX» and HC emissions which
occur in fuel switching, and other potential air pollution situations.
At present, the Division of Air Pollution for the Commonwealth of
Kentucky, with assistance from EPA, is developing a proposed plan revision
which, if adopted, would be consistent with the intent of the Clean Fuels
Policy and ESECA. This proposal is expected to detail areas where definite
clean fuel savings are possible, but it may point out areas where more
restrictive emission limits will be necessary to provide for continuous
attainment and maintenance of the NAAQS. At the same time, the Division
of Air Pollution Control will recommend that the State's ambient air
quality standards be modified to make them more consistent with the
present NAAQS.
Although the enclosed analysis has attempted to address the attain-
ment of all the NAAQS, most of the review has focused on total suspended
particulate matter (TSP) and sulfur dioxide (SQ2\ emissions. This is
because stationary fuel combustion sources constitute the greatest
source of S02 emissions and are a major source of TSP emissions.
The following are the principle findings for the State of Kentucky
(Air Quality Control Regions are displayed on Figure 1).
The State had adopted ambient standards which are equivalent to
the original Federal National Ambient Air Quality Standards. Two of
these standards are no longer in effect at the Federal level but still
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tVANoVILLt"
LOUISVILLE
INTERSTATE
(KENTUCKY-
METROPOLITAN
CINCINNATI
INTERSTATE
(OHIO-
KENTUCKY-
INDIANA)
(#79)
BLUEGRASS
INTRASTATE
HUNTINGTON -
ASHLAND-
PORTSMOUTH-
IRONTON-
JNTERSTATE
(WEST VIRGINIA-
KENTUCKY-
OHIO)
(#103)
PADUCAH-
CAIRO
INTERSTATE
(KENTUCKY-"
ILLINOIS)
(#72)
HENDERSON
INTERSTATE
(INDIANA-
KENTUCKY)
(#77)
APPALACHIAN
INTRASTATE
(#101)
SOUTH CENTRAL
KENTUCKY
INTRASTATE
C#105)
Figure 1-1. Kentucky Air Quality Control Regions (AQCR)
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exist as State standards. Attainment of these State standards would
require stricter emission controls than would attainment of the present
Federal NAAQS only. The Kentucky Division of Air Pollution Control
will, in the near future, recommend the revising of the State ambient
standards to be consistent with Federal NAAQS.
--The State's SOo regulations were developed using the example region
approach, and emission limits which vary with a region's priority class-
ification were adopted. These limits are to be met by July 1, 1977, in
Priority I regions; July 1, 1978, in Priority II regions; and July 1, 1979,
in Priority III regions. At present, the proposed revision being developed
by the Kentucky Division of Air Pollution would require emission limitations
to be based upon specific area or source constraints rather than on regional
considerations.
Within the framework of this limited review, there appears to be
little possibility for particulate regulation relaxation. High particulate
levels are being measured throughout most of the State.
--The Louisville (78) AQCR seems a poor candidate for S02 regulation
revision due to problems with NAAQS attainment and maintenance and little
clean fuel savings potential based on modeling results in the original State
plan. For two regions, South Central Kentucky (105) and Appalachian (101),
modeling results indicate that more restrictive S02 emission limits may be
necessary in certain counties to provide attainment and maintenance of the
NAAQS. Two other regions, Paducah-Cairo (72) and Bluegrass (102), have
counties where S02 regulations may be relaxed and at the same time other
counties where S02 regulations may need to be tightened, according to
modeling results. Modeling indicates that in the Evansville-Owensboro
AQCR (77), S02 regulations may be relaxed; however, care must be taken
not to disrupt the air quality maintenance planning in the Indiana portion
of the AQCR. The Cincinnati (79) and Huntington-Ashland (103) AQCRs
yielded modeling results which indicate possible regulation revision and
clean fuel savings. Finally, the North Central Kentucky AQCR (104) has
no significant potential clean fuel savings because of low regional fuel
requirements.
--Of 18 power plants scheduled to be on-line in 1975, all are
primarily coal-fired. Almost all of the large industrial point sources
are coal-fired also. Therefore, the major impact of any regulation change
would be in the increased utilization of high sulfur coal.
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2.0 Kentucky State Implementation Plan Review
2.1 Summary
A revision of fuel combustion source emissions regulations will depend
on many factors. For example:
1. Does the State now have air quality standards which are more
stringent than the NAAQS?
2. Does the State have emission limiting regulations for the control
of (1) power plants, (2) industrial sources, (3) area sources?
3. Did the State use an example region approach in demonstrating the
attainment of NAAQS or possibly more stringent State standards?
4. Has the State initiated action to modify combustion source
emission regulations for fuel savings;!'.e., under the Clean
Fuels Policy?
5. What is the approved attainment date for the NAAQS?
6. Are there any proposed Air Quality Maintenance Areas?
7. Are there reported violations of NAAQS?
8. Does available air quality data indicate a tolerance for increasing
emissions?
9. Are the total emissions from stationary fuel combustion sources
proportionally higher than those of other sources?
10. Do modeling results for specific fuel combustion sources in a
region show a potential for a regulation (1) relaxation, (2) tighten-
ing, (3) both, or (4) no change?
11. Is there a significant clean fuels saving potential in the region
if regulations were revised?
The following table of this report is intended to answer the preceding
questions for each region. In the case of interstate AQCRs, answers pertain
to the Kentucky portion of the region only unless specifically noted
differently.
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TABLE 1
STATE IMPLEfOiTATinN PLAN REVIEW SUMMARY FOR KENTUCKY
- -_________^ Region
Ir.dicstor ~~~~~~ -^_____^
Does tha State now have air quality standards
which are more stringent than the NAAQS?
Does the State have emission limiting regulations
for the control of (1) power plants, (2) industrial
sources, (3) area sources?
Did the State use an example region approach in
demonstrating the attainment of NAAQS or possibly
more stringent State standards?
Has the State initiated action to modify combustion
source emission regulations for fuel savings; i.e.,
under the Clean Fuels Policy?
What is the approved attainment date for NAAQS?
,o Are there any proposed Air Quality Maintenance Areas?
Are there reported violations of NAAQS?
Does the available air quality data indicate a
tolerance for increasing emissions?
Are the total emissions from stationary fuel com-
bustion sources proportionally higher than those
of other sources?
Do modeling results for specific fuel combustion
sources in a region show a potential for a regulation
(1) relaxation, (2) tightening, or (3) both (1) & (2) or
f4) no cnanae?
Is there a significant clean fuels saving potential
in the region if regulations were revised?
State
Yss
(1) Yes
(2) Yes
(3) Yes
Yes'
Yes
Paducah-Cairo3
AQCR 72
TSP
75
No
Yes
No
Yes
N/A
S02
Example
Region
Priority
II
78
No
Yesd
Noe
Yes
(3)
Yes
Evans vi lle-Owensboro3
AQCR 77
TSP
75
Yesb
Yes
No
No
N/A
S02
78
Yesb
No
Yes
Yes
(1)
Yes
Louisville3
AQCR 78
TSP
S02
Example Region
Priority I
75
Yes
Yes
No
No
N/A
77
Yes
Yes
No
Yes
W
No
Cincinnati3
AQCR 79
TSP
' 75
Yesc
Yes
No
No
N/A
S02
78
No
No
Yes
Yes
(1)
Yes
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TAfllE 1 (Cont.)
~~ ~~~~~-_^_ Region
Indicator
Does the State how have air quality standards
which are more stringent than the NAAQS?
Does the State have emission limiting regulations
for the control of (1) power plants, (2) industrial
sources, (3) area sources?
Did the State use an example region approach in
demonstrating the attainment of NAAQS or possibly
more stringent State standards?
' Has- the State initiated action to modify combustion
source emission regulations for fuel savings, i.e.,
under the Clean Fuels 'Policy?
What is the approved attainment date for NAAQS?
Are there any proposed Air Quality Maintenance Areas?
Are there reported violations of NAAQS?
i^j
o Does the available air quality data indicate a
tolerance for increasing ainissions?
Are the total emissions from stationary fuel com-
bustion sources proportionally higher than those
of other sources?
Co modeling results for specific fual combustion
sources in a region show a potential for regulation
(1), relaxation, (2) tightening,, or (3) both (1) & (2)
nr (<:/ no charieo?
Is there a significant clean fuels saving potential
in the region if regulations were revised?
Applachi sn
AQCR 101
TSP
Example
Region
Priori t>
75
No
Yes
r;o
Mo
N/A
S02
79
No
No
Yes
Yes
(2)
No
Bluegrass
AQCR 102
TSP
75
No
Yes
No
"Yes
N/A-
so2
79
No
No
Yes
Yes
f3l
Yes
Huntington-Ashlanda
AQCR 103
TSP
-
75
No
. Yes
No
No
N/A
S02
79
No
No
Yes
Yes
(1)
Yes
North Central
Kentucky
AQCR 104
TSP
75
No
Yes
No
No
N/A
S02
79
No
No
Yes
Yes
(4)
Mo
South Central
Kentucky
AQCR 105
TSP
75 .
No
'Yes
No
Yes
N/A
S02
79
No
No
Yes
Yes
(2)
No
a - Interstate AQCR.
b - There are proposed AOMAs in Indian portion of the region.
c - There are proposed AQMAs in Ohio portion of the region.
d - Violations recorded in Illinois portion of the region, believed to be attributed to Kentucky sources.
e - Modeling shows tolerance in portion of region.
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2.2 Air Quality Setting for the State of Kentucky
2.2.1 Kentucky Air Pollution Control Areas
The State of Kentucky is divided into nine Air Quality Control Regions
(AQCRs) as shown in Figure 1; four intrastate and five interstate. Table 2
gives the pollutant priority classifications for each of these regions. The
table also shows population to be highest in Metropolitan Cincinnati (AQCR
#79) and Louisville (AQCR #78). Based on growth projections for the State,
one county has been proposed as an Air Quality Maintenance Area (AQMA) for
sulfur dioxide and particulates. This is indicated in Table 2.
i
2.2.2 Kentucky Ambient Air Quality Standards I
As shown in Table 3, Kentucky has adopted Federal primary and
secondary National Ambient Air Quality Standards (NAAQS) for part-
iculates, sulfur oxides, and nitrogen dioxide. The secondary annual
SOo Standard adopted in Kentucky was the same as the original Federal
standard which has since been rescinded. In addition, the secondary
annual standard for particulates has been redefined as a "guide" for
use in assessing implementation plans to achieve the 24-hour standard.
The Kentucky Division of Air Pollution plans to recommend that the
State standards be revised so as to be consistent with the present
Federal NAAQS. Until this is done, the State ambient standards may
require degrees of control in excess of those required by the NAAQS.
These standards are shown in Table 3.
2.2.3 Kentucky Air Quality Status
The number of air quality monitoring stations for S02 and total
suspended particulates, along with the number of stations reporting
violations in 1973 are summarized by region in Table 4. Particulate
violations have been recorded at more than one station in every region,
showing little possibility of a regulation relaxation.
SC>2 violations of the ambient standards have only been recorded at
sampling stations in the Louisville (#78) AQCR for stations operating
in the Commonwealth of Kentucky in 1973. Since all other regions show
no violations, it would appear there is a tolerance for S02 regulation
revision. However, since not every area of every region can be adequately
monitored, atmospheric diffusion modeling must be considered along with
reported air quality data in order to determine the actual counties suitable
for potential regulation revisions.
11
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TABLE 2. Kentucky Air Pollution Control Areas
Priority Classification
Demographic Information
AQMA Proposed Designations
Population Area Population
Air Quality
Control Region
1.
2.
3.
4.
5.
6.
7.
8.
9.
Paducah-Cairo (111.)
Kentucky Portion
Evansville-Owensboro-
Henderson (Ind.)
Kentucky Portion
Louisvi.lle (Ind.)
Kentucky Portion
Metropolitan
Cincinnati (Ohio, Ind.)
Kentucky Portion
Appalachian
Bluegrass
Hunting ton- Ash land-
Portsmouth- Ironton
(W.Va., Ohio)
Kentucky Portion
North Central Kentucky
South Central Kentucky
Federal
Number
72
77
78
79
101
102
103
104
105
Parti-
culates
I
I
I
I
II
II
I
II
III
S0x '
II
II
I
II
III
III
III
III
III
1970 (square
(Millions) miles)
0.
0.
0.
0.
40
34
50
18
0.82
0.
1.
0.
0.
0.
0.
0.
0.
0.
69
66
29
50
45
59
22
25
32
8012
6478
5704
2688
908
387
3816
1708
7791
4316
8148
4348
4813
7571
per square
mile TSP Counties
50
52
88
67
903
1783
435
170
64
104
72
51
52
42
(0)
(2)
(3)
(3)
(0)
(0)
(0)
(0)
(0)
Varderburg, Ind.
Warrick, Ind.
Jefferson, Ky
Clark, Ind.
Floyd, Ind.
Dearborn, Ind.
Hamilton, Ohio
Clermont, Ohio
S0u Counties
X
(0)
(2) Vanderburg, Ind.
Warrick, Ind.
(1) Jefferson, Ky
(1) Dearborn, Ind.
(0)
(0)
(0)
(0)
(0)
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TABLE 3
AMBIENT AIR QUALITY STANDARDS
Total Suspended Particulate
Primary
Annual
24-Houra
Secondary
Annual
24-Houra
Sulfur Oxides
Primary
Annual
24-Houra
Secondary
Annual
3-Houra
State
(ug/m3)
75(G)
260
60(G)
150
80 (A)
365
60(A)b
1300
Federal
(ug/m3)
75(6)
260
60(G)C
150
80(A)
365
1300
aNot to be exceeded more than once per year.
(A) Arithmetic mean
(6) Geometric mean
bThis standard, which was adopted based upon the original (April 30, 1971) NAAQS,
was rescinded by EPA in July 1973.
cGuide to be used in assessing implementation plans to achieve the 24-hour
standard.
13
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TABLE 4
KENTUCKY AQCR AIR QUALITY STATUS (1973)
TOTAL SUSPENDED PARTICULATES
AQCR
72
77
78
79
101
102
103
104
105
NUMBER OF
STATIONS
REPORTING
25
19
23
22
5
12
14
7
9
NUMBER OF STATIONS SHOWING VIOLATION
ANNUAL STANDARD
PRIMARY
11
10
12
5
3
1
7
0
1
SECONDARY
19
15
17
15
4
4
9
2
3
24-HOUR STANDARD
PRIMARY
0
1
2
0
0
0
0
0
0
SECONDARY
7
9
9
3
1
0
4
0
0
KENTUCKY AQCR AIR QUALITY STATUS (1973)
SULFUR DIOXIDE
AQCR
72
77
78
79
101
102
103
104
105
NUMBER OF
STATIONS
REPORTING
24
18
29
16
4
10
15
7
6
NUMBER OF STATIONS SHOWING VIOLATION
ANNUAL STD
(PRIMARY)
0
0
2
0
0
0
0
0
0
24-HOUR
(PRIMARY)
0
0
0
0
0
0
0
0
0
3-HOUR
(SECONDARY)
0
0
0
0
0
0
0
0
0
14
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2.2.4 Kentucky Emission Summary
Emission summaries showing the percent contribution from major
source categories for each region are shown in Table 5. This data
was taken from the original Kentucky State Implementation Plan which
reflects the 1970 emission inventory. Fuel combustion sources are
the major contributor of particulate emissions only in the Louisville
(#78) AQCR while in every region but the Appalachian (#101) AQCR,
these sources are the major contributor for sulfur oxides.
2.2.5 Power Plant Modeling
Detailed atmospheric diffusion modeling is presently being per-
formed by the Kentucky Division of Air Pollution and the Region IV
Atlanta Office of EPA for major S02 sources in Kentucky as required
to implement a plan revision. At the time of this report, the data
is still under evaluation. However, tentative projections can be
made with regard to the impact of a regulation revision on power
generation fuel usage. Table 6 compares, for each air quality control
region, the power plant fuel consumption and sulfur content (based upon
1973 data) required for complying with existing regulations versus fuel
required under a regulation modification designed to eliminate overkill.
This table shows a significant clean fuels savings in the 1 to 2% and
2 to 3% sulfur range for the entire State. The possibility exists for
the consumption of over 16 million tons of coal with sulfur content of
3% without violating the primary NAAQS. Under existing regulations
this coal could not be consumed.
This table is a tentative projection, but upon completion of this
modeling task, precise clean fuel savings potential will be evident
and the extent of a possible SOg regulation revision assessed.
15
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TABLE 5
KENTUCKY EMISSION SUMMARY^
REGIONAL RELATIVE
Source Category
Particulates
Fuel Combustion
Process Losses
Solid Waste
Transportation
Misc. Area Sources
Total
Sulfur Oxides
Fuel Combustion
Process Losses
Solid Waste
Transportation
Misc. Area Sources
Total
CONTRIBUTION OF SOURCE CATEGORIES
Region
72
13.4
80.6
1.4
1.2
3.4
100.0
98.2
3.4
0.2
1.2
100.0
77
.14.8
81.5
1.0
1.7
0.9
100.0
97.6
0.2
0.1
1.0
1.1
100.0
78
73.8
10.7
11.5
4.0
100.0
98.3
0.7
0.4
0.6
100.0
79
1.2
95.9
1.6
1.3
100.0
62.4
5.3
32.3
100.0
101
2.0
74.2
2.6
0.6
20.6
100.0
10.3
0.4
2.3
87.0
100.0
102
19.9
76.9
2.3
0.8
0.1
100.0
96.7
0.7
2.6
0
100.0
103
10.2
86.6
1.3
0.9
1.0
100.0
94.0
4.2
0.2
1.6
100.0
104
4.1
93.2
1.3
1.1
0.3
100.0
93.8
0.8
5.4
100.0
105
10.1
88.0
1.1
0.5
0.3
100.0
97.1
0.4
1.8
0.7
100.0
aData Taken From Original Kentucky State Implementation Plan.
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TABLE 6
KENTUCKY POWER PLANT EVALUATION SUMMARY
AQCR Fuel
72 Coal
Oil
77 Coal
Oil
78 Coal
Oil
79 Coal
Oil
101 Coal
Oil
102 Coal
Oil
103 Coal
Oil
Fuel Sulfur Content Required By
Existing Regulations3
(Coal - 1000 tons/yr.)
(Oil - 1000 gal./yr.J
<1% S
3,799
3,200
1-2% S
11,764
3,544
1,450
2-3% S
35
2,097
1 ,020
2,442
3% S
Fuel Sulfur Content Required By
Modified Regulations^
(Coal - 1000 tons/yr.)
(Oil - 1000 gal./yr.)
<1% S
4,282
3,799
3,200
35
1-2% S
631
1,020
2-3% S
3% S
7,482
3,544
1,450
1,466
2,442
aFuel requirements based upon 1973 fuel use patterns from Federal Power Commission data (except for new
facilities, not operating in 1973, where fuel tonnage was estimated from megawatt rating through 1978).
^Maximum allowable % S was estimated from modeling results by U.S. Environmental Protection Agency, Region IV
Office.
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TABLE 6 (cont.)
KENTUCKY POWER PLANT EVALUATION SUMMARY
Fuel Sulfur Content Required By
Existing Regulations3
(Coal - 1000 tons/yr.)
(Oil - 1000 gal./yr.)
Fuel Sulfur Content Required By
Modified Regulationsb
(Coal - 1000 tons/yr.)
(Oil - 1000 gal./yr.)
AQCR Fuel
104 Coal
Oil
105 Coal
Oil
Kentucky
" Total Coal
Oil
< r/o s
1-2% S 2-3% S 3% S
No Power Plants
6,999
658
17,416
4,574
1,020
0
< 1% S 1-2% S 2-3% S 3% S
No Power Plants
"658
11,974
631
1,020
0
-
16.384
oo
aFuel requirements based upon 1973 fuel use patterns from Federal Power Commission data (except for new
facilities, not operating in 1973, where fuel tonnage was estimated from megawatt rating).
^Maximum allowable % S was estimated from modeling results by U.S. Environmental Protection Agency, Region IV
Office.
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2.3 Background on the Development of the Current State Implementation Plan
2.3.1 General Information
The Kentucky State Implementation Plan presents a control strategy
for attainment of the NAAQS based upon the example region approach. Two
example AQCRs were used in developing the strategy for particulate matter,
the Louisville Interstate AQCR (#78)(Priority I) and the Appalachian AQCR
(#101)(Priority II). Two example AQCRs were also chosen in developing the
control strategy for sulfur oxides, the Louisville Interstate AQCR (#76)
(Priority I) and the Paducah-Cairo Interstate AQCR (#72)(Priority II).
In each of these control strategies, area sources were projected to
include growth while growth of point sources would be controlled by the
Kentucky permit system. Through this analysis, attainment and maintenance
of the NAAQS were demonstrated for the entire State.
2.3.2 Particulate Control Strategy
The Louisville AQCR (#78) was chosen as the Priority I example region
for particulate matter because it contained (1) the highest measured
particulate concentrations in the State, and (2) a wide variety of source
types. The particulate control strategy for the Priority II example
region, the Appalachian AQCR (#101), demonstrated attainment for all
Priority II regions through a rollback (proportional model) analysis.
No control strategies were evaluated for the Priority III AQCRs, but
adequate particulate matter emission limiting regulations were adopted
by the State for these regions thereby assuring maintenance of the
secondary standards.
2.3.3 Sulfur Oxide Control Strategy
The Louisville AQCR (#78) was chosen as the Priority I example region
for sulfur oxides for the same reasons that it was chosen the example region
for particulate matter. The control strategy demonstration for the Priority II
example region for sulfur oxides (Paducah-Cairo Interstate Region #72) was
not officially submitted as part of Kentucky's plan; however, rollback
(proportional model) calculations received from the Kentucky Air Pollution
Control Commission and verified by the EPA indicate that the national standards
will be attained in this example region. No control strategies were presented
for the Priority III regions, but adequate sulfur oxide emission limiting
regulations were adopted by the State for these regions thereby assuring
maintenance of the secondary standards.
19
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2.3.4 Control Regulations Summary
Table 7 and Figures 2, 3, and 4 summarize the existing Kentucky fuel
combustion emission limitations. Emission limits are applied to new and
existing units on the basis of the heat input of the entire facility.
Different limits for sulfur oxides apply for coal and oil on a pounds of
SC>2 per million basis. The particulate limitation is the same regardless
of the fuel consumed. The emission limits are immediately effective except
for the regulation for the control of sulfur oxide emissions which defer
dates for final compliance as follows: Priority I AQCRs - July 1, 1977,
Priority II AQCRs - July 1, 1978, and Priority III AQCRs - July 1, 1979.
20
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Table 7. Kentucky Fuel Combustion Emissions Regulations
SO,
New Facilities
Liquid Fuel: Priority I Emission Limit: Figure 2
Solid Fuel: Priority I Emission Limit: Figure 3
In addition:
Maximum emission limit for new or modified sources:
Existing Facilities
Liquid Fuel: Priority Region Emission Limit: Figure 2
Solid Fuel: Priority Region Emission Limit: Figure 3
500 tons/day.
Maximum emissions from all sources (individually, 100 tons/yr or more) within a
ten mile radius of a new or modified source: 750 tons/day.
articulates
. Ringleman No. 1 in Priority I regions
upacity. Ringleman No. 2 in Priority II and III regions
New Facilities
New Installation Emission Limit: Figure 4
Existing Facilities
Priority Region Emission Limit: Figure 4
NO
New Facilities Q250xlQ6 Btu/hr)
Gaseous Fuel: 0.2 lbs/106 Btu
Liquid Fuel: 0.3 lbs/106 Btu
Solid Fuel: 0.7 lbs/106 Btu
Existing Facilities Q300xlQ6 Btu/hr)
Gaseous Fuel: 0.3 lbs/106 Btu
Liquid Fuel: 0.3 lbs/106 Btu
Solid Fuel: 0.7 lbs/106 Btu
-------
-100.0
10.0
2.5
1.0
0.1
r
o
c
10
100
1000
10,000
HEAT INPUT (10
-------
100.0
5 C 7 B 9 I
2 3 4567891
2 3 4567031
2 3 '. 5 C 7 R 9 1
Q
tfl
co
ii
s
tr1
to
100 250 " 1,000
HEAT INPUT (106 BTU/HR)
10,000
Figure 3. Kentucky Allowable Sulfur .Dioxide Emissions Based on Heat Input Capacity
-------
o
§
do.is so
0-15 £
i__jo.ii F
10 o
o
100
1,000
10,000
«. 'TOTAL HEAT INPUT, MILLIONS OF BTU PER HOUR
Figure 4. Kentucky Maximum Emission of Particulate Matter for Fuel Burning Installations
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2.4 Soecial Considerations
2.4.1 Planned SIP Revisions
The proposed plan revision under development at this time by the
Kentucky Division of Air Pollution with assistance from EPA will include
detailed atmospheric diffusion modeling in the vicinities of major fuel
combustion sources of sulfur oxides. The impact of a possible regulation
change will be evaluated, and emission limits will be proposed based upon
attainment and maintenance of the National Ambient Air Quality Standards
without excessive overkill, while providing a reasonable margin of growth.
Incorporated as part of this revision proposal, will be a recommendation
to revise the State ambient standards to be consistent with the NAAQS. Enact-
ment of a revision of this nature will allow for significant clean fuel
savings, while at the same time adhering to the requirements of the Clean
A1r Act.
2.4.2 Fuels
Kentucky is a heavy user and producer of bituminous coal. In 1972,
Kentucky was the largest producer of coal, producing 20% of the bituminous
coal mined in the United States. Kentucky power plants' heat input from
coal alone accounted for 98% of the total heat input. The remaining 2%
were the result of oil and gas utilization. Kentucky ranks fourth among
the States in estimated bituminous coal reserves. The percentage of the
reserves with various sulfur contents are:
(a) sulfur content, <1% - 33%
(b) sulfur content, 1-2% - 8%
(c) sulfur content, > 2% - 59%
Despite the large supply of low sulfur coal (33% of the Kentucky total,
most of which is in eastern Kentucky), full development of this resource is
not expected in the short term (3-5 years). Most of the mines operating on
these reserves are small and will not be able to meet the demand for low
sulfur coal in the near future. Also, much of this coal is metallurgical
grade and hence too expensive for use as fuel.
2.4.3 Potential Fuel Conversions
No power plants have been identified as having the capability to convert
from oil to coal by the Federal Energy Administration since all Kentucky power
plants are mainly coal burning facilities.
25
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