EPA-450/3-74-078
DECEMBER 1974
IMPLEMENTATION PLAN REVIEW
FOR
FLORIDA
AS REQUIRED
BY
THE ENERGY SUPPLY
AND
ENVIRONMENTAL COORDINATION ACT
U. S. ENVIRONMENTAL PROTECTION AGENCY
-------
EPA-450/3-74-078
IMPLEMENTATION PLAN REVIEW
FOR
FLORIDA
REQUIRED BY THE ENERGY SUPPLY AND ENVIRONMENTAL COORDINATION ACT
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
-------
IMPLEMENTATION PLAN REVIEW
FOR FLORIDA
REQUIRED BY THE ENERGY SUPPLY AND ENVIRONMENTAL COORDINATION ACT
Table of Contents
1.0 EXECUTIVE SUMVIARY 5
2.0 FLORIDA STATE IMPLEMENTATION PLAN REVIEW 10
2.1 SUMMARY 10
2.2 AIR QUALITY SETTING FOR THE STATE OF FLORIDA 13
2.2.1 Florida Air Pollution Control Areas 13
2.2.2 Florida Ambient Air Quality Standards 13
2.2.3 Florida Air Quality Status 13
2.2.4 Florida Emissions Summary 16
2.2.5 Power Plant Modeling 17
2.3 BACKGROUND ON THE DEVELOPMENT OF THE CURRENT
STATE IMPLEMENTATION PLAN 17
2.3.1 General Information 17
2.3.2 Particulate Control Strategy 19
2.3.3 Sulfur Oxide Control Strategy 19
2.3.4 Control Regulations Summary 19
2.4 SPECIAL CONSIDERATIONS FOR THE STATE OF FLORIDA 21
2.4.1 Planned SIP Revisions 21
2.4.2 Fuels 21
2.4.3 Potential Fuel Conversions 22
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IMPLEMENTATION PLAN REVIEW
FOR FLORIDA
REQUIRED BY THE ENERGY SUPPLY AND ENVIRONMENTAL COORDINATION ACT
1.0 EXECUTIVE SUMMARY
The enclosed report is the U.S. Environmental Protection Agency's
(EPA's) response to Section IV of the Energy Supply and Environmental
Coordination Act of 1974 (ESECA) . Section IV requires EPA to review each
State Implementation Plan (SIP) to determine if control regulations for
stationary fuel combustion can be revised without interfering with the
attainment and maintenance of the National Ambient Air Quality Standards
(iJAAQS). In addition to requiring that EPA advise the state as to whether
control regulations can 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 under the Clean Air Act of 1970, initiate State Implemen-
tation Plan revisions; ESECA does not, however, require states to change
any existing plan.
Congress has intended that this report provide the state with
information on excessively restrictive control regulations. The intent of
ESECA is that SIPs, wherever possible, be revised in the interest of con-
serving 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 interfering with the attainment and maintenance
of standards. If so, it n^y 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, implementati^
plans have been reviewed with a view to saving low sulfur fuels. Where the
primary sulfur dioxide air quality standards will 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.
5
-------
To date, this activity has involved only those states with the
largest clean fuels savings potentials. Several of these states have revised
or are currently in the process of revising their SOo regulations. These
states are generally in the eastern half of the United States. ESECA, how-
ever, 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, 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 adopted and retained the
original federal standards or, in a few cases, adopted more restrictive
state standards, and these served as the bases 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 Implemen-
tation Plans is a logical follow-up to EPA's initial appraisal (1972) of the
SIPs. At the 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 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 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 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. 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.
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 (SCL) emissions. This is
because stationary fuel combustion sources constitute the greatest source
of SCL emissions and are a major source of TSP emissions.
7
-------
The following are the principal findings for the State of Florida.
(Air Quality Control Regions are displayed in Figure 1-1.)
. The state has adopted the federal secondary ambient air
quality standards for particulates except in Bade,
Broward and Palm Beach Counties. In these counties more
stringent standards have been adopted. The ambient air
quality standards for S02 are equivalent to the original
federal secondary' standards which have since been rescinded.
The standards arc substantially more restrictive in Dade,
Broward and Palm Beach Counties.
. Control strategies for particulates and SO? were developed
using the example region approach. SIP revisions are cur-
rently in progress which would base emission limits on
local constraints rather than "worst region" considerations.
The state had incorporated a variance procedure into its
regulations which would modify emission limits upon receipt
of substantiating documentation of unavailability of low
sulfur content fuel. However, this provision expired
July 1, 1974. This procedure could have been used to
establish emission limits that are more reflective of
local conditions.
Based on this limited analysis there appears to be Little
room for relaxation of particulate emission regulations.
Only Central Florida (#48) and Southwest Florida (#51)
demonstrate any potential margin for absorbing increased
emissions. All other regions have high TSP readings (based
on 1973 data) and no tolerance for emission increases.
. Within the framework of this limited analysis the indications
are that Florida could consider relaxing its S0? emission
limits to permit the burning of higher sulfur oil in all
regions except Jacksonville-Brunswick and West Central
Florida. Significant savings of low sulfur oil can be
achieved through this revision, some of which might be
diverted to the above two regions to relieve their SCL
problems.
Of 40 power plants scheduled to be on-line in 1975 only 5
have coal-burning cpability. The remainder are oil- and
gas-fired. There are no significant industrial/commercial/
institutional sources using coal; all are using oil and
gas. Therefore, the major impact of regulation relaxation
on clean fuels conservation will be reduced requirements
for low sulfur oil.
Fuel conversions from oil to coal will have little impact
on oil conservation. To date only the Crystal River power
plant in Inglis have been identified as having potential
coal conversion capability. In addition, increased use
of coal would have to be accompanied by addition of control
equipment to meet particulate emission regulations.
8
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JACKSONVILLE-
BRUNSWICK
INTERSTATE
(FLORIDA-
GEORGIA)
(#49)
MOBILE
FENSACOLA-
PANAMA CITY
SOUTHERN
MISSISSIPPI
INTERSTATE
(ALABAMA-
FLORIDA) .
(#5)
CENTRAL
FLORIDA
INTRASTATE
(#48)
WEST CENTRAL
FLORIDA
INTRASTATE
SOUTHWEST
FLORIDA
INTRASTATE
(#51)
Figure 1-1. Florida Air Quality Control Regions (AQCR)
SOUTHEAST
FLORID"
INTRA'TATE
(#50)
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2.0 FLORIDA STATE IMPLEMENTATION PLAN REVIEW
2.1 SUMMARY
A revision of fuel combustion source emissions regulations will
depend on many factors. For example:
. Does the state have air quality standards which are more
stringent than NAAQS?
. Does the state have emission limitations 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 initiated action to modify combustion
source emission regulations for fuel savings; i.e., under
the Clean Fuels Policy?
. Are there any proposed Air Quality Maintenance Areas?
. Is there an expected 1975 attainment date for NAAQS?
. Based on (1973) air quality data, are there indications
of a tolerance for increasing emissions?
. Are the total emissions from stationary fuel combustion
sources a relatively small portion of the regional total?
. Do modeling results for specific fuel combustion sources
show a potential for a regulation revision?
. Is there a significant clean fuels savings potential in
the region?
. Must the regulations be revised to accomplish significant
fuel switching?
The following portion of this report is directed at answering
those questions. Based on an overall evaluation of EPA's current infor-
mation, AQCR's have been classified as good, marginal, or poor candidates
for regulation revisions. Table 2-1 summarizes the State Implementation
Plan Review. The remaining portions of the report support this summary
with explanations.
10
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Table 2-1. State Implementation Plan Review Summary for Florida
Mobile- Central Jacksonville- Southeast
Pensacola Florida Brunswick Florida
State AQCR »5 AQCR »48 AQCR #49 AQCR »50
"iNmc/vmie;"
• Docs the State h;ivc air quality standards which arc more
stringent than NAAQS?b
• Does the State have emission limiting regulations for
control of:
1. Power plants
2. Industrial sources
3. Area sources
• Did the State use an example return approach Tor doiiKju-
strating the attainment of NAAQS.or more stringent State
standards?
• Has the State initiated action to modify combustion
source emission regulations for fuel savings; i.e.,
under the Clean l-'ucls l'olicy?c
* Are there anv nronosed Air Oualitv Maintenance Areas?
• Are there indications of a sufficient number of monitor-
ing sites within a region?
• Is there an expected 1975 attainment date for NAAQS?d
• Based on (1973) Air Quality Data, are there any reported
violations of NAAQS?
• Based on (1973) Air Quality Data, arc there indications
of a significant tolerance for increasing emissions?
• Are the emissions from stationary fuel combustion sources
• a relatively small portion of the regional total?
9 Do modeling results for specific fuel combustion sources
show a potential for a regulation revision?
• Is there a significant Clean Fuels Saving potential in
the region?
• Must the regulations be revised to accomplish signifi-
cant fuel switching?
• Based on the above indicators, what is the potential for
revising fuel combustion source emission limiting
rcRulatlons? . (
TSP S02 .
YES
YT-S
YES
NO
YES
NO
YES
YliS
YES
NO
YF5
YES
.
1
•i-si' s>2
NO
YES
YES
YES
NO
YES
N.A,
NO
YES
YES
NO
YES
NO
YES
YES
YES
TSP - Poor
S02 - Good
TS1' .SO.,
NO
YES
YES
NO
YES
YES
N.A,
NO
NO
YES
NO
YES
NO
N.A.
YES
YES
TSP - Good
S02 - Good
TSP S02
YES
YES
YES
YES
NO
YES
N.A.
YES
YES
Yii3
YES
NO
NO
N.A.
NO
YES
TSP - Poor
S02 - Poor
TSP SOg
NO
YES
YFS
YES
NO
NO
N,A.
NO
YES
YES
NO
YES
NO
N.A.
YES
YES
TSP - Poor
S02 - Good
y
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Table 2-1. State Implementation Plan Review Summary for Florida (Contd.)
Southwest
Florida
AQCR #51
West Central
Florida
AQCRJ52
"INIWYVmitS"
• Docs the State have air quality standards which ar? more
stringent than NAAQS?
• Docs the State have emission limiting regulations for
control of:
1. Power plants
. 2. Iiulus trial sources
3. Area sources
• Did the State use an example region approach for demon-
strating the attainment of NAAQS or more stringent State
st;indards?
• Has the State initiated action to modify combustion
source emission regulations for fuel savings; i.e.,
under the Clean Fuels Policy?
* Are there any proposed Air Quality Maintenance Areas?
• Are there indications of a sufficient number of monitor-
ing sites within a region?
• Is there an expected 1975 attainment date for NAAQS?
* Based on (1973) Air Quality Data, are there any reported
violations of NAAQS?
• Based on (1973) Air Quality Data, are there indications
of a significant tolerance for increasing emissions?
• Are the emissions from stationary fuel combustion sources
• a relatively small portion of the regional total?
* Do modeling results for specific fuel combustion sources
show a potential for a regulation revision?
• Is there a significant Clean Fuels Saving potential in
the region?
• Must the regulations be revised to accomplish signifi-
cant fuel switching?
• Based on the above indicators, what is the potential for
revising fuel combustion source emission limiting
regulations?
•fSP S02
5
NO
• YES
YES
NO
YES
NO
N:A.
NO
MO
YES
NO
. YES
NO
N.A.
YES
YES
TSP - Good
S02 - Good
TSP S02
Exai
Re
YES
YES
YES
YES
NO
NO
N.A.
iple
;ion
YES
YES
YES
YES
NO
NO
YES
YES
YES
TSP - Poor
S02 - Poor
Interstate
'in Dade, Broward, and Palm Beach Counties, more strijigent S02 standards *ere adopted through public demand, The state's SO
standards
cScheduled for early 1975.
'cased on supplemental data from.local sources
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2.2 AIR QUALITY SETTING FOR THE STATE OF FLORIDA
2.2.1 Florida Air Pollution Control Areas
The State of Florida is divided into six Air Quality Control Regions;
four intrastate and two interstate (Fig. 1-1). Table 2-2 shows population
to be highest in Southeast Florida (#50) and Mobile-Pensacola (#5). Based
on growth projections for the state, 4 counties have been proposed as Air
Quality Maintenance Areas (AQMAs) for particulates and for sulfur dioxide.
These are Polk, Hillsborough, and Pinellas Counties in West Central
Florida (#5) and Duval Couunty in Jacksonville-Brunswick (#49).
2.2.2 Florida Ambient Air Quality Standards
As shown on Table 2-3, with the exception of Bade, Broward, and
Palm Beach Counties in Southeast Florida (#50), the state has adopted the
federal secondary National Ambient Air Quality Standards (NAAQS) for annual
and 24-hour particulate concentrations and 3-hour SO- concentration.
Standards equal to the original federal secondary annual and 24-hour SO-
concentrations have also been adopted. The EPA has since rescinded these
standards and maintained only the 3-hour secondary standard for S02- The
state may consider following this same procedure. For Bade, Broward, and
Palm Beach Counties, the annual particulate standard is somewhat more
stringent than the federal limit, and the 24-hour standard must be met for
all periods. The SO- standards are substantially more stringent than
federal standards. These were adopted as a result of public hearings held
during the Implementation Planning Program. Strategies designed to achieve
these standards would, of necessity, have to be more restrictive than those
designed for federal standard attainment. The following analysis will
address attainment of the federal NAAQS only.
2.2.3 Florida Air Quality Status
Based on the 1973 data in the SAROAD (Storage and Retrieval of
Aerometric Data) system, only Central Florida (#48) and Southwest Florida
(#51) are not showing violations of the particulate standards. It should
be noted that these two regions have only a limited number of stations
reporting and the data may not be representative. Indications are that the
13
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Table 2-2. Florida Air Pollution Control Areas
Demographic Information Priority Classification
Proposed .
AQMA Designations"
Air Quality
Control Region
Mbbiie-Pensacola-
Pdnama City-Southern
Mississippi
(Ala., Miss.)
Central Florida
Jacksonville-
Brunswick (Ga.)
Southeast Florida
Southwest Florida
West Central Florida
Federal
Number
5
48
49
50
51
52
1970
Population
(Millons)
2.1
.9
1.3
2.4
.4
1.5
Area
/thousand's
\sq. mi. )
33.6
5.6
-j
24.2
8.7
7.7
8.0
Population
Density
/people peA
\so. mi. )
63
167
55
279
46
180
Particulates
1
2
1
2
3
1
SOx
1
3
2
3
3
1
NQx
3
.3
3
3
3
3
TSP Counties
(0)
(0)
(1) Duval
.
(0)
(OJ
(3) Polk, Hillsborough,
*>x
' (0)
(0)
(1)
(2)
(0)
(3)
Counties
Duval
Polk,
Pinellas
Hillsborough;
Pinellas
4As of November 26, 1974.
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Table 2-3. Florida Ambient Air Quality Standards
.' • *'
>.'•'«&•.
Federal
vt^4 'I'; - "•
State
Bade, Broward
Counties
Ptimary
Secondary
Except Bade,
Broward, Palm
Beach Counties
y Palm Beach
Total Suspended
Annual
75CG)
60 (G)
60(G) .
50
Particulate
24 Hr
260a
150a
150a
180
All
Annual
80 (A)
• «- r
60 (A)
8.6(A)
concentraticrs in ygms/m9
Sulfur Bioxide
24-Hr 3-Hr 4-Hr 1-Hr
365a
1300a --.-
b 260a'b 1300a —
28.6 --- 57,2 286
Nitrogen Dioxide
Annual
100 (A)
100 (A)
100 (A)
100 (A)
to be exceeded more thar once per year.
adopted based on original EPA policy which was rescinded. July, 1973.
(A) Arithmetic mean
(B) Geometric mean
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severest problems are in Jacksonville-Brunswick (#49) and Mobile-Pensacola
(#5) requiring large emission reductions to meet the secondary NAAQS. Based
on the 1973 emissions data, the indications are that relaxation of particulate
emission regulations will not be possible without hindering NAAQS attainment
and maintenance.
Based on 1973 air quality data in the SARQAD system, Jacksonville-
Brunswick (#49) is the only region showing an S02 violation. Additional data
from local sources indicates that there are high S02 readings reported in
Hillsborough County in West Central Florida (#52) also. The exceptionally
low S02 concentrations in Southwest Florida (#51) and Central Florida
(#48) are suspect in that only one station is reporting in each region.
Notwithstanding the lack of comprehensive SC^ air quality data in all
regions, the apparent ability of 4 out of 6 regions to absorb increases in
SC>2 concentrations without violating the NAAQS is encouraging from the
perspective of clean fuels conservation. The indication is that there is
a tolerance for regulation relaxation; however, the state would have to
review all existing air quality data prior to changing any regulations.
2.2.4 Florida Emissions Summary
Regionwidei Florida fuel combustion sources are contributing 31%
of the particulate and 841 of the SO? emissions. Based on rollback calcu-
lations, control of particulate emissions from these sources alone will
probably not be sufficient to attain the NAAQS in the 4 regions requiring
air quality improvement. The implication is that any particulate regulation
relaxation for fuel combustion sources in these areas should be accompanied
by a corresponding regulation tightening on other sources in order to achieve
the necessary reduction of emissions. In Central Florida (#48) and Southwest
Florida (#51), the limited data indicate a possible tolerance for emission
increase. This is supported by the fact that these two regions have the
lowest TSP emission rates in the state.
The data review shows that all regions except Jacksonville-Brunswick
(#49) and West Central Florida (#52) can tolerate SO- emission increases.
Since Florida fuel combustion sources make up no less than 751 of the S09
L*
emissions in every region, regulation relaxation must proceed cautiously
to avoid jeopardizing NAAQS attainment. Although the data indicate a signifi-
cant margin for relaxation, it should be reemphasized that this is based on
16
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limited air quality data and a more thorough analysis would be required
to determine the actual allowable emission increase.
Comparison of the emissions from various source categories indicates
that power plants and industrial/commercial/institutional point sources are
roughly equivalent in their contributions to the state's particulate emission
load although one or the other may dominate in individual regions. Any
regulation revisions must, therefore, consider both categories on an equiva-
lent basis. Area sources are not significant sources in any region. For
SO-, the power plants are overwhelming in their contribution. It can,
therefore, be said that regulation revisions for power plants will have
the primary impact on regional SO- air quality. As before, area sources
are not significant sources.
2.2.5 Power Plant Modeling
Only very limited modeling data was available for Florida power
plants. Table 2-4 gives a summary of potential clean fuel savings based
on the available information. In Mobile-Pensacola (#5) there is significant
low sulfur coal savings potential. The data in West Central Florida region
(#52) is based on the Crystal River plant.
2.3 BACKGROUND ON THE DEVELOPMENT OF THE CURRENT STATE
IMPLEMENTATION PLAN
2.3.1 General Information
The Florida State Implementation Plan proposed control strategies
for particulates and S02 based on example region calculations for the West
Central Florida AQCR (#52). This region was chosen because of the high
TSP and S02 concentrations measured in Hillsborough County in 1970 and
because of the diversity of emission sources. (Hillsborough County con-
tains the city of Tampa.) Control strategy development was predicated on
the assumption of a "no growth" policy in Hillsborough County which would
minimize the influx.of new industrial sources. Growth of commercial,
institutional, and residential sources was anticipated to have little TSP
and S09 air quality impact since natural gas would be the primary fuel
17
-------
oo
Table 2-4. Florida towel- Plant Evaluation Siiiuiary
9t)2 '
AQCR
5C
4s
49C
SO
51
52
Florida
Total
Fuel
Coal
Oil
CMS
Coal
Oil
Gas
Coal
Oil
Gns
Coal
Oil
Gas
Coal
'Oil
Gas
Coal
Oil
Gas
Coal
Oil
Gas
1975 Fuel Required- by
lixistina Regulations8
< 1%
2,782
46,769
21,143
, 198', 575
50,732
. 612,948
13,026
33,080
97,342
1,718
4,945
222,633
7,727
1,114,005
183,961
1-2% 2-3* > 31
218
197
199,641
166,992
727,301
173,376
548,838
218
1,816,345
1975 l-'ucl Required by
Modified Regulations"
< i\ 1-24 2-31
218 2,011
NA -NA
> 31
771
No modeling results available.
No modeling results available.
No modeling results available. .
. No modeling results available.
4,237
222,633
708d
Incomplete data.
aFuel requirements based on 1971 fuel use patterns at 1975 consumption rates. Coal in 10 tons/yr, oil in 10
gals/yr, gas in 106 ftVyr.
alloxvable I S is 1971 % S unless modeling indicates a lower value, bata from Modeling Analyses of
Power Plants for Compliance Extensions in 51 Alf Quality Control Regions, U.S. EPA, Waldcn Div7 Abcor, Inc. ,
Dec. 17, 1972". : : '
Interstate.
Tfata from Ntode ling Analysis of Power Plants for Fuel Conversion, U.S. E. P. A. , Walden Research Division of
Abcor Inc. June 1974. .
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used. Based on the air quality in other regions in Florida, normal growth
was not expected to create any problems in TSP and SO- NAAQS attainment
and the control strategies developed for West Central Florida would be
adequate to meet the standards.
2.3.2 Particulate Control Strategy
The particulate control strategy required approximately 40%
reduction in TSP emissions in the example region. This was achieved
through the application of a 60% emission control by potential sources
and a 90% control of fugitive dust emissions. (The SIP inventory showed
that approximately 40.4% of the regional TSP emissions came from a limited
number of fugitive dust sources.) EPA considered the fugitive dust
regulations to be enforceable and hence accepted the presented strategy
as valid.
Separate rollback calculations were performed for Bade, Broward,
Palm Beach, and Polk Counties. These calculations showed attainment of
the NAAQS.
2.3.3 Sulfur Oxide Control Strategy
Several SO- control strategies were evaluated and the chosen one
demonstrated an emission reduction of 67.7% from 1970 S02 air quality
levels. The "no growth" policy in Hillsborough County along with the
emission limit regulations showed NAAQS attainment.
Separate calculations were carried out for Polk, Dade, Broward,
and Palm Beach Counties. A no-growth policy was adopted for Palm Beach
County to assure NAAQS attainment there, while the other counties showed
attainment under normal growth conditions.
2.3.4 Control Regulations Summary
Table 2-5 summarizes the Florida fuel combustion emission regula-
tions. Emission limits are applied only to new and existing units of
greater than 250 x 10 Btu/hr heat input. All smaller boilers are con-
trolled by the application of "latest reasonably available technology"
as determined by the Department of Pollution Control.
19
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Table 2-5. Florida Fuel Combustion Emission Regulations0
SO
Existing Sources
V 250 x 106 Btu/hr > 250 x 106 Btu/hr
Latest reasonably 1.1 lbs/106 Btu for liquid fuel,
available technology 2 hour average
1.5 lbs/106 Btu for solid fuel,
2 hour average
Opacity of Ringelmann #1; Ringleman #2
permitted for 2 minutes per hour.
Particulates
i~
T-
Latest reasonably
• available technology .1 lbs/106 Btu, 2 hr average
New Sources
<_ 250 x 106 Btu/hr
Latest reasonably
available technology.
> 250 x 106 Btu/hr
.8 lbs/106 Btu for liquid fuel
2 hour average
1.2 lbs/106 Btu for solid ffoel
2 hour average
Opacity of Ringelmann #1; Ringelmann #2 permitted
for 2 minutes per hour.
Latest reasonably
available technology
,1 lbs/106 Btu, 2 hr average
ii Til*
a
to fossil fuel steam generators,
b ••• A
A^atiance procedure is included in the regulations (Section 17-2.11) which gives the Florida Department
% of Pollution Control authority to modify sulfur oxide emission limits for fossil fuel steam generators
••_£ uptift receipt of sufficient evidence documenting the unavailability of low sulfur fuels.
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As written, the regulations do not allow the meeting of emission
standards by fuel switching from coal to oil since a different limit applies
to each fuel use. Also, the limit must be met on a 2-hour average and
cannot be weighted over annual consumption rates. Fuel switching is a
compliance method only when the change is made to gas for which there
is no emission limit. In most cases, the combustion of oil will not
require controls to meet the particulate emission limitation.
The Florida Department of Pollution Control had a variance pro-
cedure to deal with the unavailability of low sulfur fuel. Upon receipt
of appropriate supporting documentation, the Department could modify emis-
sion limits for a given facility to enable it to use a higher sulfur con-
tent fuel. However, this provision expired on July 1, 1974 after seeing
only limited use during the winter fuel shortage of 1973-74.
Within the framework of this review the existing Florida regula-
tions are not incompatible with the requirements for clean fuels conservation.
No restrictions are placed on smaller fuel combustion sources, and the
variance procedure could be reincorporated into the regulatory process. This
would give the state sufficient flexibility to adjust to fluctuating clean
fuels availability.
2.4 SPECIAL CONSIDERATIONS FOR THE STATE OF FLORIDA
2.4.1 Planned SIP Revisions
There are now three formal revisions to the Florida SIP in progress.
Revision to sulfuric acid plant emission limits in Jacksonville-Brunswick
(#49), and proposed sulfur recovery controls are planned which could increase
S02 levels, thus reducing some of the potential for gaining clean fuel
leverage. A third revision (in the planning stages) deals with addressing
the clean fuels policy and is expected to begin full scale study in early
1975.
2.4.2 Fuels
Florida is not a heavy user of coal. Most of the state's fossil
fuel is in the form of oil and natural gas. Power plant Btu consumption
averages about 17% from coal, 45% from oil and 38% from gas. Proximity
21
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to the Gulf Coast oil and gas supplies virtually assures continued con-
sumption of these fuels in preference to coal. Thus, while the air quality
data indicates a tolerance for S07 emission increases, the fuel consumption
patterns indicate that only a small low sulfur coal savings would be
effected through regulation relaxation. However, there is a potential for
the conservation of some low sulfur oil. While this is not as pressing a
constraint on clean fuels availability as is low sulfur coal, the process-
ing of oil to a lower sulfur content requires additional refining steps
which result in increased fuel costs. Also, to achieve a lower sulfur
fuel oil the mix of remaining by-products from the refinery is altered.
This change often represents an economic penalty.
2.4.3 Potential Fuel Conversions
The Federal Energy Administration has identified only one power
plant in the State of Florida as having the necessary equipment to be able
to convert from oil to coal; that is the Crystal River plant in Inglis
(West Central Florida AQCR, #52). Of the remaining 39 plants scheduled
to be on-line in 1975, only 4 will have the capability to burn coal. Hence
fuel conversions are not expected to have an impact on clean fuel conserva-
tion.
22
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1. REPORT NO.
EPA-450/3-74-078
2.
3. RECIPIENT'S ACCESSIOWNO.
4. TITLE AND SUBTITLE
IMPLEMENTATION PLAN REVIEW FOR FLORIDA
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.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
10. PROGRAM ELEMENT NO.
U.S. Environmental Protection Agency, Office of Air
Quality Planning and Standards, Research Triangle Park,
N.C. Region IV Office, Atlanta, Ga., and Argonne
National Laboratory, Argonne, 111.
11. CONTRACT/GRANT NO.
/'EPA-IA6-D5-0463
12. SPONSORING AGENCY NAME AND ADDRESS
13. TYPE OF REPORT AND PERIOD COVERED
U.S. Environmental Protection Agency
Office of Air and Waste Management
Office of Air Quality Planning and Standards
Research Triangle Park. N.C. 27711
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.
7.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.lDENTIFIERS/OPEN ENDED TERMS C. COSATI Field/Group
Air pollution
State Implementation Plans
18. DISTRIBUTION STATEMENT
Release unlimited
19. SECURITY CLASS (ThisReport)
Unclassified
21. NO. OF PAGES
20. SECURITY CLASS (Thispage)
Unclassified
22. PRICE
_22_
EPA Form 2220-1 (9-73)
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