EPA-450/3-74-080
DECEMBER 1974
     IMPLEMENTATION PLAN REVIEW
                  FOR
              COLORADO
              AS REQUIRED
                   BY
          THE ENERGY  SUPPLY
                  AND
   ENVIRONMENTAL COORDINATION ACT
      U. S. ENVIRONMENTAL PROTECTION AGENCY

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                                           EPA-450/3-74-080
                   IMPLEMENTATION PLAN REVIEW

                               FOR

                            COLORADO

REQUIRED BY THE ENERGY SUPPLY AND ENVIRONMENTAL COORDINATION  ACT
              PREPARED BY THE FOLLOWING TASK FORCE:
      U. S. Environmental Protection Agency, Region VIII
                       1860 Lincoln Street
                    Denver, Colorado  80203
               Environmental  Services of TRW, Inc.
                      (Contract 68-02-1385)
            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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                                COLORADO
            ENERGY SUPPLY AND ENVIRONMENTAL COORDINATION ACT
             (SECTION IV - STATE IMPLEMENTATION PLAN REVIEW)
                            Table of Contents
1.0  EXECUTIVE SUMMARY	  .    1
2.0  STATE IMPLEMENTATION PLAN REVIEW 	    6
     2.1  Summary	    6
     2.2  Air Quality Setting - State of Colorado 	    8
     2.3  Background on the Development of the Current State         10
          Implementation Plan 	
     2.4  Special Considerations - Colorado 	   11
3.0  CURRENT ASSESSMENT BASED ON SIP REVIEW   	   12
     3.1  Regional Air Quality Assessment 	   12
     3.2  Power Plant Assessments 	   12
     3.3  Industrial/Commercial/Institutional  Source Assessment .  .   13
     3.4  Area Source Assessment	   13
     3.5  Impact of Fuel Switching	   13
     TECHNICAL APPENDICES
     APPENDIX A - State Implementation Plan Background 	   15
     APPENDIX B - Regional  Air Quality Assessment 	   29
     APPENDIX C - Power Plant Assessment  	   32
     APPENDIX D - Industrial/Commerical, Institutional                40
                  Source Assessment 	
     APPENDIX E - Area Source Assessment	   45
     APPENDIX F - Other Analyses  	   46
     BIBLIOGRAPHY 	   48
                                m

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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, regjjire 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
SOp emission regulations.  The States have also been asked to discourage
large scale shifts from coal to oil where this could be done without
jeopardizing cne attainment and maintenance of trie 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  SCL 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]J_ 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 concerns, 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 wsre approved by EPA if they demonstrated  the attainment
of NAAQS pjr more stringent state air quality standards.   Alsos 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-wide  where the use of 3 percent sulfur  coal would be adequate to attain
NAAOS  in some  locations.

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     EF'A 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
1 imitations.  The findings of tjiis report are by no_means conclusive and
are neither intended nor adequate to be the_ _sp_1_e basis for SIP revisions;
they do, however_L_re_£)resent 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
        X
 air pollution  problems such as sulfates   .
     Although the  enclosed analysis  has attempted to  address the  attainment  of
 all the NAAQS, rr.ost  of the  review has  focused on total  suspended  particulate
matter  (TSP) and sulfur dioxide (SO,.,)  emissions.  This  is because stationary
 fuel combustion  sources constitute  the greatest source  of SO^ emissions  and  are
 a  major source of  TSP  emissions.

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     Part of each State's review was organized to provide an analysis of

the SO,, 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 L7.

     •  The Colorado State Implementation Plan has been reviewed for the
        most frequent causes of over-restrictive emission limiting regula-
        tion.  Although Colorado used the Example Region approach in develop-
        ing control strategies for both TSP and S02 and has  TSP and S02
        air quality standards which are more stringent than  NAAQS, there
        are no indications that current regulations are overly restric-
        tive in the context of Section IV of ESECA.

     •  S02 emission regulations for existing sources were recently with-
        drawn from the State Implementation Plan.  The approval by EPA of
        Colorado's request to withdraw the regulation is an  indication
        of EPA concurrance with findings that the current state regula-
        tion is more stringent than required to meet NAAQS for S02-
        Additionally, there were no areas proposed as designated AQMA's
        for S02 as of August 1974.

     0  There are indications of widespread TSP problems throughout the
        state of Colorado.  All AQCR's in the state have reported viola-
        tions of NAAQS for particulates.  In addition, five of the eight
        Colorado AQCR's have been proposed as AQMA's for particulates,
        and three AQCR's  (Metro Denver, Pawnee, and San Isabel) have had
        NAAQS attainment dates delayed until 1977.  Wind-blown fugitive
        dust accounts for most of Colorado's TSP problem, however, there
        are significant emissions (>30%) from stationary fuel combustion
        sources in the Metro Denver, Pawnee, San Isabel, and Yampa AQCR's.
        Any increase in man-made TSP emissions would only aggravate the
        current high level of particulates.  Therefore, the stationary
        source fuel combustion particulate emission regulation is not a
        good candidate for revision in any Colorado AQCR.

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                                                                            METROPOLITAN
                                                                            DENVER
                                                                            INTRASTATE
                                                                                            PAWNEE
                                                                                            INTRASTATE
YAMPA
INTRASTATE
GRAND MESA
INTRASTATE
                                              \ Jackson      Larimer
                                                                           AaPahoe
                           	,---	^
                                                                                           Lincoln)	
                           81 ta   !                phaffee/
                           	1     Gunnison    I       r	
Montrose  y-	-,  J
            ^~    'i
San Miguel
                           rQuray?  i

                            \_   .Alin
                                  Saguache
                                                 Custer  ;     Pueb1°
               r,  ,          -VX^an
              ^°1o^s_	^Juan,
             Montezuma
        FOUR CORNERS
        INTERSTATE
                                •	L
                         La Plata j  Archuleta L   Cone.j0
                         _,JU._.
Mineral"'"l_ 	     	 	j
      I   "      ! "Alamosa/^^ Huerfano
      jRio Grande)
                                                                                      Crowley
                                                                                             .n—-""r"
h	r-
          1    Bent   !
   Otero  i          i  Prowers
                                SAN LUIS
                                INTRASTATE
                               Figure 1-Colorado AQCR's
                                                                                         Las Animas
                                                                      Baca
                                              SAN ISABEL
                                              INTRASTATE
V
                           COMANCHEE
                           INTRASTATE

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                    2.0  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 SIP have emission limiting regulations for control
        of existing (1) power plants, (2) industrial  sources, and (3)
        area sources.

     •  Did the State use an example region approach  for demonstrating
        the attainment of NAAQS or more stringent State standards?

     •  Has the State not initiated action to modify  combustion
        sources emission regulations for fuel savings; i.e., under
        the Clean Fuels policy?

     •  Are there JTO 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 indica-
        tions of a tolerance for increasing emissions?

     0  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 accomplish signifi-
        cant 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?

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                                                                              COLORADO
                                                                     STATE  IMPLEMENTATION PLAN REVIEW
                                                                                (SUMMARY)

"INDICATORS"
• Does the State have air quality standards
which are more stringent than NAAQS?
* Does the SIP have emission limiting regu-
lations for control of existing:
1. Power plants
2. Industrial sources
3. Area sources
• Did the State use an example region approach
for demonstrating the attainment of NAAQS or
more stringent State standards?
• Has the State not initiated action to modify
combustion source emission regulations for fuel
savings; I.e., under the Clean Fuels Policy?
t Are there no proposed Air Quality Maintenance
Areas?
t Are there indications of a sufficient number
of monitoring sites within a region?
t 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?
t 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?
t 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?
Four Corners Commanche Grand Mesa Metro Denver Pawnee Sari Isabel Sar Luis Yampa
STATE AQGR14 AQBR 34 AQCR 35 AQCR 36 AQCR 37 AQCR 38 AQCR 39 AQCR 40
TSP
Yes
Yes
Yes
No
Yes
Yes










S0?
Yes
Noa
No
No
Yes
Noa










TSP S02




Yes
Yes
Yes
;io
Yes
llo
il/A
Yes
/
Hi




Yes
;io
Yes
Yes
No
Ho
il/A
Hoa
a

TSP S02




Yes
Yes
Yes
No
No
Yes
N/A
Yes
Poor
111



Yes
No
Yes
tl/A
N/A
No
N/A
Noa
a

TSP S02



No
Yes
Yes
•No
No
Yes
N/A
Yes
Poor
N




Yes
No
Yes
N/A
N/A
No
N/A
Noa
a

TSP S02




Ho
Yes
No
Ho
No
Yes
N/A
Yes
Poor





Yes
Yes
Yes
Yes
Yes
No
N/A
Noa
a
0
TSP S02




No
Yes
No
No
Ho
No
Il/A
Yes
Poor
III




Yes
No
Yes
N/A
N/A
llo
N/A
Noa
a

TSP S02




Mo
Yes
No
No
No
Yes
N/A
Yes
Poor
III




Yes
No
Yes
,VA
N/A
No
H/A
Noa
a

TSP S02




Yes
Yes
Yes
No
No
No
N/A
Yes
Poor
Mi




Yes
No
Yes
N/A
il/A
No
N/A
llod
a

TSP S02




No
Yes
Yes
No
No
No'
H/A
Yes
Poor
1




Yes
No
Yes
N/A
N/A
No
N/A
Noa
a
0
aPresent state reguletion has been withdrawn from SIP and public hearings  are being held to consider revisions.

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     The following portion of this report is directed at answering these
questions.  An AQCR's potential for revising regulations increases when
there are affirmative responses to the above.
     The initial part of the SIP review report, Section 2 and Appendix A,
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
regulations.  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.
     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 re-
maining portion of the report support this summary with explanations.

2.2  AIR QUALITY SETTING -  STATE OF COLORADO
     The State of Colorado  was divided into eight air-quality control
regions - AQCR.   They are as  follows:
     14  Four Corners interstate air quality control  region
     34  Comanche intrastate  air quality control  region
     35  Grand-Mesa intrastate air quality control  region
     36  Metropolitan Denver  intrastate air quality control  region
     37  Pawnee intrastate  air quality control  region
     38  San Isabel  intrastate air quality control  region
     39  San Luis intrastate  air quality control  region
     40  The Yampa intrastate air quality control  region
See Figure A-l.
     A summary of the Federal  and Colorado air quality standards for the
pollutants under study is presented in Table A-3.   The Colorado  standard
for particulate parallels the federal  standard.   The  Colorado particulate

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standard is based on an annual  geometric mean.  The Colorado air quality
standard for S0? is more stringent than the federal S02 standard.  Colorado
does not have an existing ambient standard for NC^.
     Colorado has an extensive monitoring network for suspended particulate
matter.  The network consists of 75 stations located throughout the state..
The distribution of the monitoring sites parallels the distribution of the
population in the state.  Almost a third of the sites are in the Metropolitan
Denver AQCR, which contains approximately half of the state's population.
Remaining sites are distributed throughout the state with the Comanche AQCR
having the least number of sites (two).  Ambient monitoring of S02 is limited
within the State of Colorado.  According to the most recent NEDS information,
the State of Colorado has two monitoring sites located in the Metro Denver
AQCR.  The remaining seven AQCRs in Colorado are not currently being monitored
for S02 ambient concentration.

     Summaries of Colorado air quality status in 1973 are presented in Table
A-4 for particulates and A-5 for SCL.  The number of stations exceeding stan-
dards are presented by air quality control regions (AQCR).  The highest
particulate readings in the state are in the Metro Denver AQCR.  Five of the
eight Colorado AQCRs violated the primary annual and 24-hour standards for
particulates in 1973.  All AQCRs violated the secondary standards for both
annual average and 24-hour levels.
     Colorado has three priority one AQCRs for TSP.  They are Metro Denver
(36), Pawnee (37), and San Isabel (38).  At the time of submitting the
Colorado State Implementation Plan the State was able to demonstrate attain-
ment of the primary standard by July 1974-  The attainment  data  for secondary
standards in those three AQCRs has been deferred 18 months.  Additional studies
by both EPA and Colorado have demonstrated the possibility of attaining pri-
mary standards for particulate in the Pawnee and San Isabel AQCRs by 1975.
For the Metro Denver AQCR, however, the probability of 1975 primary standard
attainment is very remote.  Additionally, even with the incorporation of
strict fugitive dust regulations "it is still  doubtful  that the secondary
standards will be achieved in the three AQCRs.  The major problems in achiev-
ing the standards are the large contribution of fugitive dust total  particulate

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emissions in the regions and the low control efficiencies attainable for
most fugitive dust sources.'
     A summary of S09 emissions is presented in Table A-5 by AQCR totals.
                                                                 2
The summaries were prepared from the most current data available.  There has
been insufficient monitoring to evaluate ambient SCL  levels  in all  regions
of Colorado except Metro Denver.
2.3  BACKGROUND OF THE DEVELOPMENT OF THE CURRENT STATE IMPLEMENTATION PLAN
     The State Implementation Plan control  strategy and regulations were based
on the example region approach.  Metropolitan Denver  (AQCR 36) was used as the
example region.  The control  strategies and regulations as submitted by the
State were adequate to attain the national  standard for particulates  in  the
Denver AQCR.  The other regions violating the total particulate standards
were presumed to meet the National Ambient Air Quality Standards by 1975
using the same strategies proposed for the example region.
     The State regulation for the control of particulate matter includes a
schedule of emissions from fuel combustion sources based on total heat input
in 10  Btu's, in addition to 20% opacity standard for stationary sources.
These regulations apply to existing sources.  The federal New Source Perfor-
mance Standards will be applicable for new sources.  The state has adopted
fugitive dust emissions regulations from unpaved roads, earth and construction
material moving and excavating, and open mining types of operations.  There
are no EPA enforceable  SOg regulations applicable to existing sources since
the emission standards were recently withdrawn from the state implementation
plan by EPA at the request of the state.  The state is currently holding public
hearings on its present SOp regulations to determine if modification or elimi-
nation is appropriate.  In any case, the approval by EPA of Colorado's re-
quest to withdraw the stringent existing source SO- regulation from the SIP
is an  indication of   EPA concurrance with findings that the present regula-
tion is more restrictive than required to meet NAAQS for SO^.  Since this
study is a review of the state implementation plan, the following analyses
^'Colorado Fugitive Dust  Investigation" by PEDCO Environmental of Cincinnati
 Ohio, under contract of  the Environmental Protection Agency.
21974 NEDS, July 28, 1974
                                       10

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will proceed as if there were no SOp regulations for existing sources in the
state.  New source regulations remain in force.  A summary of Colorado fuel
combustion regulations may be found in Table A-ll.
     Colorado does not have regulations controlling NOp emissions.
2.4  SPECIAL CONSIDERATION - COLORADO
     Portions of five AQCRs within the state have been proposed as designated
air quality maintenance areas (Table A-l).  It is anticipated that special
requirements for these areas will be developed by the state and submitted
to EPA as modifications to the Implementation Plan.  Virtually all major  .•
present and planned fuel combustion  sources are located in the counties where
portions of AQCRs are proposed as designated AQMAs.
     Energy Supply Potential
     There is an estimated 500 to 600 billion barrels of oil in the oil shale
deposits of the Green River formation of the Rocky Mountains.  The richest
deposits are in the Colorado Piceance Creek Basin.  For years the resources
have been bypassed in favor of more easily extracted fossil fuels.  Two parcels
(approximately 5000 acres each) were leased by the Federal  government to en-
courage oil shale development.  Successful operations on the leased tracks
should produce 50,000 BPD (barrels per day) of crude oil from each lease by
1980.  If the oil (kerogen) extraction process proves to be economically
viable, the Federal Energy Administration (FEA) has projected a 1990 minimum
development potential of 550 thousand barrels per day for Colorado.
     The nearest term energy resource in Colorado is coal.   Colorado has two
major deposits of low sulfur bituminous coal.  Again, the largest is in the
Piceance Basin in western Colorado, with the other in northeastern Colorado.
A smaller deposit is located on the Southern border of Colorado.  The eastern
reserves of coal in Colorado may be developed using a coal  gasification
process.  The Metro Denver AQCR is scheduled to have a 250 million scf/d coal
gasification plant on line before 1985.
     In 1971, Colorado had 41 coal minesj 32 underground and 9 above (strip
mine).  Those mines produced $33.8 million in revenue.  With the resurgence
of coal as a source for domestic power needs, it is expected that extensive
coal development will occur.
                                       11

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                3.0  CURRENT ASSESSMENT BASED ON SIP REVIEWS

3.1  REGIONAL AIR QUALITY ASSESSMENTS
     The only sites in the state that monitor SO- (Metro Denver AQCR), indicate
levels well below standards.  This was the justification for withdrawal  from
the SIP of SOp emission regulations from existing sources.
     Tables A-7 and A-8 present the emission summaries for Colorado.   They
indicate a significant fraction (30%+) of total  suspended particulates come
from electrical generation and point source fuel combustion in all  but 3
AQCRs.  The majority of particulate emissions come from fugitive dust sources.
Fuel combustion sources are the major contributors to total SO- emissions on
a statewide basis.
     Table A-9 and A-10 present the results of estimating what the  Colorado
emissions would be on a region wide basis. The largest drawback for using
this approach lies in the large geographical dispersion of emission sources
in the Colorado AQCRs.  The analysis is intended to give an "indication" of
potential areas for relaxation.
     Tables B-l and B-2 summarize the general data for each pollutant by AQCR
that must be considered when estimating the potential for regulation  relaxa-
tion.  The analysis was performed to determine if there were any obvious com-
bustion source candidates.  There is no indication from available data that
regulations are too stringent in any region.
3.2  POWER PLANT ASSESSMENTS
     At the present time there are 14 power plant sites in the state.  All
AQCR's have at least one power plant.  Pawnee (AQCR 37) has two; Metro Denver
and San Isabel AQCR\ have four each (Table A-6).

      Two  power plants  in  the State  of Colorado  are  100%  coal  fired.   The
 first is  the  Hayden  Power Plant  (AQCR 40);  the  other is  the  Nucla  Power
 Plant (AQCR  35).   Eight  power plants  in  Colorado  are partially  coal-fired,
 with  a mixture of other  fuels.   The remaining four  power plants  use  only
 oil  or natural  gas  as  fuel,  with  no possibility of  conversion.   Table C-l
 presents  relevant  data  on  all  power  plants  presently in operation in Colorado.
                                     12

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All plants are on compliance schedules to meet emission regulations.  Coin-
cidental ly, power plants in those three AQCRs now projected to have diffi-
culty in meeting the primary standards, generally  exceed total suspended
particulate allowable emissions.
     Table C-2 lists all known projected power plants (1974 thru 1985).
These are large coal fired installations.  Many of these plants are to be
located adjacent to the coal source.
     Table C-3 lists the energy development related power plants.  The first
is a coal gasification plant that is slated for development sometime between
1975 and 1985 in the Metro Denver AQCR.  The lower portion of the table
gives estimates of the kind of generating facility that would be required
to support the operation of a 50,000 barrel-per-day oil shale development
plant.
3.3  INDUSTRIAL/COMMERCIAL/INSTITUTIONAL SOURCE ASSESSMENT
     All major stationary fuel combustion sources in the State of Colorado
were reviewed.  Thirty-one of those sources presently do not use coal or do
not have the apparent capability to switch to  coal.    The  remaining
three stationary fuel combustion sources are located in the Denver AQCR.
Since that AQCR has been demonstrated as being unable to meet the primary
particulate standard in 1975, and those three sources are not significant,
additional analysis was not performed.
3.4  AREA SOURCE ASSESSMENT
     The State of Colorado was found to have no area sources which could be
evaluated within the context of Section 4 of ESECA.
3.5  IMPACT OF FUEL SWITCHING
     An analysis of fuel combustion sources was made to determine the feasi-
bility of conversion to coal and its resulting impacts on emissions and regula-
tions.  The candidate sources for fuel switching identified in Appendix C
were evaluated to determine the potential for relaxation of regulations.
The percentage of coal utilized was estimated by translating all fuel used
into total annual heat input and directly proportioning on the basis of the
                                        13

-------
percent of annual heat input contributed by each fuel type.  The emissions
resulting from conversion to coal at these candidate combustion sources
were estimated and compared to current emissions (Appendix F-l).
     Table F-l presents the power plant present and potential emissions
based on 100% coal utilization with present control equipment.  All power
plants would not meet current particulate emission regulations without addi-
tional controls.
     In general, the analysis indicated that for total suspended particulates,
the increase in projected emissions with fuel conversion will be significant.
Ambient air quality standards will probably not be met.   Consequently, further
relaxation of regulations should not take place.  The analysis indicated that
fuel switching will further aggravate the particulate compliance problem in
the Denver, Pawnee and San Isabel AQCR's.  There are indications that the TSP
Air Quality standards may not be met even if all sources comply with present
regulations because many sources presently emit well under requirements.
Relaxation of the regulation in these regions would probably put the compli-
ance goal out of reach.  Without sufficient monitoring data, it is impossible
to assess the impact of the fuel switching on the ambient levels of S0-
                                       14

-------
                               APPENDIX  A

     e  State implementation plan information
     e  Current air quality information
     •  Current emissions information
     Tables in this appendix summarize original  and modified state imple-
mentation plan infomation, including original  priority classifications,
attainment dates, ambient air quality standards, and fuel  combustion emis-
sion regulations.  SAROAD data for SO, and TSP monitoring  stations are shown
                                     *•              1
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 not violate .national
secondary ambient air quality standards, is shown for SCL  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 arrJbient 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 were 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 AQCRs
 1"1972  National  Emissions  Report,"  EPA  - 450/2-74-012, June 1974.

                                     15

-------
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-9  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 linear.
Although this cutoff may leave some AQCR's with n£ 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.
                                        16

-------
                                  Table  A-l.
AQCR Priority Classification  and  AQMAs
AQCR
Four Corners
(Ariz, Utah,
Colo.N.Mex)
Colorado
Portion
Comanche
Grand Mesa
Metro Denver
Pawnee
San Isabel
San Luis
Yampa
	 1 	
Fed. # Part? S0xb N0tc
014

034
035
036
037
038
039
040
•IA
IA
III
III
I
I
I
III
III.
IA
IA
III
III
III
III
III
III
III
III
III
III
III
III
III
III
III
III
Demographic Information
Population Square Population
1970 Miles Density
368,310
37,356
72,728
130,470
1,242,027
239,784
423,551
37,466
23,877
109,101
6,558
17,926
19,045
5,045
15,842
17,360
8,180
13,812
3.38
5.70
4.06
6.85
246.19
15.14
24.40
4.58
1.73
AQMA Designations
TSP Counties SOX Counties MOX Counties



(2) Garfield,
Mesa
(8) Adams,
Arapahoe, Boulder,
Clear Creek,
Denver, Douglas,
Gil pin, Jefferson
(2) Larimer, Weld
(2) Puelbo, El
Paso

(1) Rio Blanco













(8) Adams,
Arapahoe, Boulder,
Clear Creek,
Denver, Doug! as,
Gil pin, Jefferson




Criteria Based on Maximum Measured (or Estimated)  Pollution  Concentration  in Area
Priority

aParticulate matter:
Annual geometric mean. ..
24-hour maximum 	

Sulfur oxide:
Annual arithmetic mean. .
24-hour maximum 	

°Nitrogen dioxide
I
Greater than

95
325


100
455

no
II
From - To

60-90
150-325


60-100
260-455


III
Less than

60
150


60
260

110
 Federal Register, August 1974, SMSA's showing potential  for NAAQS violations
 due to growth

-------
oo
                                                                      •'PAWNEE
                         ; Y A M p A [sss*.—>
GRANDjMESA

       -j
        i
        i
        i
                                           '       L '   '
                                           ..	f~,    i
                                           *- rorNAOMT   •— .H^-—«r
                                                                         i  COMANCHEJ

                                                                         A-^**•••~"-"'"*"^'™"'^'f«»*^*«(r»«i   '
                                     S A N SL U I
                         I ABCMUUCTA
                         j



              / FOUR  CORNERS
          Proposed AQMA's
                 COLORADO AIR QUALITY CONTROL REGIONS

                           Fiaure 1

-------
                               Table  A-2.
Attainment Dates
AQCR #
14
•
34
35
36
37
38
39
40
Name
Four Corners
Comanche
Grand Mesa
Metro Denver
Pawnee
San Isabel
San Luis
Yampa
Parti culates
Attainment Dates
Primary
7/75
a
7/75
7/75
7/75
7/75
a
a
fc
Secondary
7/75
a
7/75
b
b
b
7/75
a
Sulfur Dioxide
Attainment Dates
Primary
a
a
a
a
a
a
a
a
Secondary
a
a
a
a
a
a
a
a
Nitrogen Oxides
Attainment Dates
a
a
a
a
a
a
a
a
aair quality presently below  standards
 18 months extension granted

-------
                        Table  A-3.   Ambient Air Quality Standards    Colorado
Expressed as pg/nf

Federal Primary
(flov. 1972)
Secondary
State Designated area (Metro
Denver, other state
designated areas)
1973 Standards
1976 Standards
Hon-designated area
1973 Standards
Total Suspended Parti cul ate
Annual

75(6)
' 60(G)

70(A)
55 (A)
45 (A)
24 hr.

260a
150a

200
180
150
Sulfur Oxides
Annual

80(A)
	

60(A)
25(A)
	
24 hr.

365a
	

300a
150a
15a
3 hr.

	
1300a

	
	


1 hr.

	
	

800a
300b


Nitrogen
Dioxide

100(A)
100(A)




PO
o
           Federal regulations apply
          (G)Geometric mean
          (A)Arithmetic mean
          anot to be exceeded more than once per year
          Jnot to be exceeded more than once per month

-------
                                   Table A-4.   Colorado  AQCR  Air  Quality  Status, TSP





AQCR Name

Four CornersD(Utah,
Colo, Ariz, M.Mex)

Colorado Portion
Comanche
Grand Mesa
Metro Denver
Pawnee
San Isabel
San Luis
Yampa





AQCR #

014



034
035
036
037
038
039
040



#
Stations
Reporting

23


6
2
10
24
13
11
5
4
(|ug/m3)
TSP Concentration
2nd
Highest
Highest Reading Reading
Annual 24-Hr 24-Hr

65 430 374


65 234 189
66 217 197
93 339 291
129 930 587
113 415 413
109 469 371
71 227 187
108 469 348


# Stations Exceeding
Ambient Air Quality Standards
Primary Secondary
Annual 24-Hrc Annual % 24-Hrc %

0 1 1 4 8 35


0 1 1 17 2 33
0 0 1 50 2 100
3 4 4 40 9 90
15 18 18 75 24 10d
8 9 9 69 11 85
5 5 7 64 9 82
0 0 1 20 3 60
1 1 3 75 3 75

%
Reduction
Required
to Meet d
Standards

60


21
24
48
74
64
60
20
57


Standard
on Which %
Reduction
Is Based

24-hr
Secondary
Standard








a1973 air quality in'National  Air Data Bank as  of July 28,  1974
 Interstate
Violations based on more than one reading in excess  of standards
 Formula: 2nd highest 24-hr-Secondary 24-hr standard
                      2nd highest 24-hr.

-------
                                                Table A-5.  Colorado AQCP, Air Quality Status, S02



AQCR Name
Four Corners
(Ariz, Utah,
Colo.N.Mex)
Colorado
Comanche
Grand Mesa
Metro Denver

Pawnee
San Isabel
San Luis
Yampa



AQCR 1
014



034
035
036

037
038
039
040

Stations
Reporting
24-Hr
(Bubbler)
9


0
0
0
2

0
0
0
0

#
Stations
Reporting
(Contin.1
4


0
0
0
7

0
0
0
0
SO- Concentration
Ivg/m') 2n(j
Highest
Highest Reading Reading
Annual 24-Hr Z4-Hr
2 79e 28e


0 00
0 00
0 00
NDA 308 53

0 0 0
0 00
0 00
0 00

# Stations Exceeding
Ambient Air Quality Std.
Primary Secondary
Annual 24-Hr1- 3-Hr
0 1 0


00 0
00 0
00 0
00 0

00 0
00 0
00 0
00 0

% .
Reduction
Required
To Meet
Standards
presently
meets stds.

0
0
0
presently
meets stds
0
0
0
0

Standard
on Which %
Reduction
Is Based












PO
           1973 air quality in National  Air  Data Bank as of July 28, 1974
           Interstate
          Violations based on more than one reading  in excess of standards
          ^Formula: 2nd highest 24-hr-Secondary 24-hr standard
                                2nd highest  24-hr.
          Measurements confirmed by EPA, Region VI,  October  24, 1974

-------
                                  Table A-6.
Colorado
Combustion Source Summary
AQCR
Four Corners
(Colorado)
Comanche
Grand Mesa
Metro Denver
Pawnee
San Isabel
San Luis
Yampa
AQCR 1
014
034
035
036
037
038
039
040
Colorado Power Plants
NEDS& FPCC
0
1
2
4
1
4
1
1
0
0
2
4
0
3
0
0
Other Fuel Combustion Point Sources
Parti cul ate S02
1
4
1
25
10
7
0
0
1
1
1
22
6
6
0
0
CO
              Only sources  in  Colorado are included
              All  sources from National Emission Data Bank Point Source listing as of June 17, 1974
             cFederal  Power Commission information for 1973 of major power plants

-------
                                     Table A-7.   Colorado Emissions Summary, TSPe
AQCR
Four Corners
Colorado
Comanche
Grand Mesa
Metro Denver
Pawnee
San Isabel
San Luis
Yampa
AQCR #
014

034
035
036
037
038
039
040
Total
Tons /year
37.7
1.6
1.8
8.0
39.3
11.6
149.0
0.42
10.4
Percent
Fuel Combustion
79.2
29.62
15.0
26.63
49.1
49.9
3.05
59.6 '
96.4
Electricity Generation
Tons/Year %
27.6 72.6
0 0
0 0
0.12 1.5
8.7 22.1
0.5 4.3
0.95 0.64
0.02 4.8
9.5 91.3
Point Source
Fuel Combstion
Tons/Year %
0.10 0.3
.03 .02
0.02 1.1
0.01 0.13
1.8 4.6
4.1 35.3
0.76 0.51
0 0
0 0
Area Source
Fuel CcfTibustion
ions/Year %
2.4 6.3
J46 29.6
0.25 13.9
2.0 25
8.8 22.4
1.2 10.3
2.9 1.9
0.23 54.8
0.53 5.1
 Emissions in Data Bank as of June 1974
bColoraao Portion of AQCR 014 only

-------
                                               Table A-8.     Colorado Emissions Summary, SO?'
AQCR
Four Corners 014
Colorado*3
Comanche 034
Grand Mesa 035
Metro Denver 036
Pawnee 037
San Isabel 038
San Luis • 039
Yampa 040
Total
103 Tons/year
119.4
.4
0.45
2.9
. 33.5
2.3
8.8
0.40
5.3
Percent
Fuel Combustion
93.74
78-. 1
42.2
85.5
50.1
71.7
61.0
60.0 ,
98.3
Electricity Generation
10^ tons/yr . %
110.5
0
0.01
0.95
11.5
0.07
3.0
0.15
4.8
92.5
0
2.2
32.8
34.3
3.0
34.1
37.5
90.6
Point Source
Fuel Combustion
103 tons/yr »
0.17
.002
0
0.03
0.90
0.83
0.56
0
0
0.14
4.5..
0
1.0
' 2.7
36.1
6.4
0
0
Area Source
Fuel Combustion
Tf)3 ton<;/yr ''"
1.31
.32
0.18
1.5
4.4
0.75
1.8
0.13
0.41
1.1
73.6
40.0
51.7
13.1
32.6
20.5
32.5
7.7
ro
en
         Emissions in Data Bank as  of June  1974


         bData not available

-------
                                   Table A-9.
Required Emission Reductions
                               SIP
                                    1973 Data
AQ
%a
AQCR Meas. Red.

Four Corners
014
(Colorado) 85 15
Comanche
034 57 +66
Grand Mesa
035 118 55
Metro Denver
036 122 51
Pawnee
037 100 36
San Isabel
038 137 58
San Luis
039 NDA
Yampa
040 NDA
Emissions
(103 tons)

.151
.033
1.15
13.4
2.15
3.0
..042
2.44
Allowable b
Emissions
(103 tons)

.128
.054
.518
6.57
1.38
1.26


1975.C
Estimated
Emissions
After Controls
(103 tons)




6.15




AQ
'Meas.:
«a
* a
Red.
NEDS
Emissions
(103 tons)
Allowable
Emissions
dO3 tons)

65
65
66
93
129
113
109
71
108
+28
+28
+25
34
55
46
43
+13
48
37.7
1.6
1.8
8.0
39.3
11.6
149.0
0.42
10.4
48.3
2.05
2.25
5.28
17.8
6.26
84.9
.47
5.41
abackground 30 jjg/m3 in regions  014,  034, 036, 037, 038; background 40 /jg/m3 in regions 035, 039, 040

bnot calculated in SIP, calculated  and  presented for comparison.

ccalculated only for example  region
                                                                                                                  Emission
                                                                                                                  Tolerance
                                                                                                                 (103  tons)
                                                                                                                    10.6
                                                                                                                      .45

                                                                                                                      .45

                                                                                                                     0

                                                                                                                     0

                                                                                                                     0

                                                                                                                     0


                                                                                                                      .05

-------
                                         Table  A-10. Colorado  Required Emission Reductions ,
                                     SIP
1973 Data
l\3
AQ 24-hr
Msrmt.
Control
AQCR Value
Four Corners
014
(Colorado)
Cotnanche
034
Grand Mesa
035
Metro Denver
036
Pawnee
037
San Isabel
038
San Luis
039
Yampa
040
NDa

ND
ND
99
ND
ND
ND
ND
197_
Estimated
Allowable Emissions
Emissions Emissions After Controls
(103 tons) (103 tons) (103 tons)
.15 -

.03 - -
1.15
20.1 54.0 NAb
2.15
3.0
>
.04
2.44
     ano data available
     t>not required in SIP, so not calculated
     CS02 emission regulation for existing sources withdrawn
     dnot calculatable
Percent
Reduction
Required
Based On
1973 AQ Data
91
ND
ND
ND
increase
ND
ND
ND
ND
NEDS
Emissions
(103 tons)
119.4
.4
.45
2.9
33.5
2.3
8.8
0.40
5.3
Allowable
Emissions
^103 tonsj
108J
NCd
NC
NC
125
NC
NC
-
-
                                                                                                                        Emission
                                                                                                                        Tolerance
                                                                                                                       (IP3  tons)
                                                                                                                          91.5

-------
                                          Table A-ll .
                         Colorado  Fuel Combustion  Regulations
                                              Existing Sources
                                                        New Sources
ro
oo
            Particulate
Fuel Input
106 BTU/hr
    0.1
    1.0
   10.0
  100.0
  500.0
 1000.0
Particulate Emissions
     Lbs/106 BTU
        0.5
        0.5
        0.27
        0.15
        0.10
        0.10
New Source Performance Standard's
            SO,,
  Regulations for existing sources
  withdrawn fromSIP, see Federal
  Register, October-18, 1974a
                          Emission rate not greater than 5 I/day,
                          shall  not exceed 150 ppm stack concen-
                          tration.
                          Uncontrolled emissions greater than
                          5 T/day, controlled to less than 5 T/
                          day, shall  not exceed 500 ppm stack
                          emission concentration.
            Opacity
 20% not to be exceeded more than 3 nrinutts in any 60 consecutive minutes
             State currently holding public hearings on present S02 regulation. Until completed, present
             regulation can be enforced by state, withdrawal of regulation from SIP precludes EPA enforcement
             action.

-------
                               APPENDIX  B

     Tables B-l  and B-2 are the assessment of AQCRs which should be examined
for the fuel switching impact on particulate and SCL 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  "high" or  "medium"  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.  Finallyj
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.
                                      29

-------
                                        B-l.  Candidacy Assessment for Relaxation of TSP  Regulations
AQCR
014
Coloradi
034
035
036
037
038
039
040
Air Quality
TT Tt
Monitors Violations
23 8
i 6 2
2 2
10 9
24 24
13 11
11 9
5 3
4 3
Expected
Attainment
Date
7/75 (7/75)
7/75 (7/75)
a (a)
7/75 (7/75)
7/75 (b)
7/75 (b)
7/75 (b)
a (7/75)
a (a)
Any
Counties
AQMA
Designations?

0
0
2
8
2
2
0
1
% Emission
from Fuel
Combustion
79.2
29.62
15.0
26.63
49.1
49.9
3.05
59.6
96.4
Tolerance
for
Emissions
Increase
(10J tons)
10.6
.45
.45
0
0
0
.0
.05
0
Overall
Regional
Evaluation
Marginal
Poor
Poor
Poor
Poor
Poor
Poor
Poor
Poor
00
o
        Air quality below standards
        18 months extension

-------
B-2. .Candidacy Assessment for Relaxation  of
                                                                                   Regulations
AQCR
Four Corners 014
Colorado 0
Comanche 034
Grand Mesa 035
Metro Denver 036
Pawnee 037
San Isabel 038
San Luis 039
Yampa 040
1973 Violations
of S02 Air
Quality Standards
# monitors #violations
13 1
0 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0
Expected
Attainment
Dates
Primary (Secondary)
a
a
a
a
a
a
a
a
Any Counties
With AQMA S02
Designations
0
0
0
0
0
0
0
0
% Emission
from Fuel
Combustion
93.74
78.1
42.2
85.5
50.1
71.7
61.0
60.0
98.3
1973b
Tolerance
for Emissions
Increase
0
-
-
91.5
-
-
-
-
Overall
Regional
Evaluation
Marginal
-
-
Good
-
-
-
-
presently meets standards
     emission regulations for existing  sources  withdrawn

-------
                                    APPENDIX C
     This section is a review of individual  power plants by AQCR.   The
intent is to illustrate fuel switching possibilities and particulate and
SOp emissions resulting from these switches  on an individual plant basis.
The total AQCR emissions resulting from such 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
Association "Steam Tables" listing of power plants and fuel use in 1972,
and (3) NEDS Emissions data.   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-4 were used where not known.  S02 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 TSP emissions (see Table C-4).
]NEDS Data Bank 1974
                                           32

-------
                                                  C-l A  Colorado Power Plant Evaluation3

Plant/
AQCR/Number/County Capacity
b
Comanche c
034 Comanche
(Otero) 350
Grand Mesa
035 Nucla
(Montrose) 34.5
Grand Mesa
035 Cameo #1
(Mesa) 77.4
Cameo #2
Cameo #3
Cameo #4
Metro Denver
036 Valmont #1
(Boulder) 281.8
Valmont §2
Valmont §3
Fuel
Type
Oil
0.3% S
0 % A
Gas
Coal
.67% S
1.5% A
gas
oil
0.5% S
0 % A
gas
oil
0.5% S
Coal
.75% S
8.3% A
gas
Coal
.75% S
8.3% A
Jjas
Coal
.75% S
8.3% A
gas
Amount
103ton/yr
398,000
gallons
1 MCF
65.5
146
MCF
1,000,000
gallons
291 MCF
2,190,000
gallons
386
6,610
MCF
.213
300 MCF
22.3
1160 MCF
Heat
Input
10°BTU H
150
per 1 ,000
gal
862
121
830
140
per 1000
£als
830
140
per 1000 e
21
815
21
815
21
815
Emissions Tons/yr
S02
Exist Allow
9
«1
115
<1
40
<1
als 79 *
5500
2
3
*1
317
<1
-
-
-
-
_

-


TSP
Exist Allow
2
834
-=1
^1
^1
2
6350
12
15
2
1200
9
4.5
<1
673
7.9
10
12
15
405
269
^1
13
23
47
CO
GO
            Emissions in Data Bank as of June 1974.

            NEDs shows this plant in OTERO County-actually located in Pubelo County (San Isalue AQCR)
           cComanche 2 has recently gone on line and is coal  fired.

-------
                                                            C-l  B  Colorado Power Plant Evaluation
CO




AQCR/Number/County
Metro Denver
036
(Denver)
Metro Denver
036
(Denver)
Metro Denver
036
(Denver)
Plant/
Capacity
Cherokee #1
801.3
Cherokee #2
Cherokee #3
Cherokee #4
*Zuni #1
115.3
Zuni #2
Arapahoa #1
250.5
Arapahoa K
Arapahoa #3
Arapahoa #4
Fuel
Heat
Amount Input
Type 103ton/yr 106BTU H
Coal
.53
8.8% A •
gas
Coal
.53% S
8.3% A
gas
Coal
.53 % S
8.0% A
gas
Coal
.53% S
8.0% A
gas
Oil
1.0% S
0.% A
gas
Coal
.37% S
1 5.8% A
Coal
.26% S
5.0% A
gas
Coal
.26% S
7.2% A
gas
Coal
.26% S
7.2% A
gas
Coal
.26%
7.2% A
gas
37
780 MCF
37
780 MCF
49.5
792 MCF
112
2420 MCF
17,600,000
gallons
1450 MCF
55
14,7
1840 MCF
83.2
1.620 MCF
70
4470 MCF
4.26
9160 MCF
22
850
22
850
22
850
22
850
150 per
1000 gallc
848
18
10
848
10
848
10
848
10
848
Emissions Tons/yr
S02
Exist Allow
373
< 1
373
*1
499
^1
1130
<1
1270
ns
<~[
2
72
-= 1
411
^ 1
345
•^1
892
117
-

;
;
~
-
-

'
;
TSP
Exist Allow
189
< 1
63
< 1
152
<1
344
<1
11
2
37
98
2
36
^1
32
<1
120
32
41
33
41
33
54
34
123
103
171
80
50
8.1
86
46
76
39
208
2
388
                     Emissions in Data Bank as of June 1974.
                     *FEA considering Zuni plant to go all  coal

-------
                                                C-l  C  Colorado Power Plant Evaluation

AQCR/Number/County
Pawnee
037
(Larimer)
Plant/
Capacity
Ft. Collins #1
8.0
Ft. Collins #2
Ft. Collins #3
Ft. Collins #4
Fuel
Type
Coal
1.0% S
15.1% A
gas
Coal
1.0% S
15.1% A
gas
Coal
1.0% S
15.1% A
gas
Coal
1.0% S
15.1% A
gas
Amount
I03ton/yr
.61
40 MCF
.61
40 MCF
.97
78 MCF
1.71
139 MCF
Heat
Input
105BTU H
19
840
19
840
19
840
19
840
Emissions Tons/yr
S02
Exist Allow
12
<1
12
^1
19
<1
32
<1
;
;
;
;
TSP
Exist Allow
78
<1
78
<1
125
<1
219
<1
1.2
3.4
1.2
3.4
1.7
5.9
2.6
9.3
GO
on
         aemissions in Data Bank as  of June  1974.

-------
                                      C-l  D  Colorado Power Plant Evaluation3

AQCR/Number/County
San Isabel
038
(Fremont)
San Isabel
038
(El Paso)
San Isabel
(038)
(El Paso)
San Isabel
038
(Pueblo)
San Luis
039
(Alamosa)
Yampa
040
Plant/
Capacity
Clark #1
38.5
Clark n
Drake #1
150
Drake #2
Drake #3
Drake #4
Birdsall #1
62.5
Birdsall #2
Birdsall #3
Pueblo #1
30.0
Pueblo #2
Alamosa
18.9
Hayden #1
163.2
Fuel
Type
Coal
.70% S
15.7% A
gas
Coal
.70% S
15.7% A
gas
Oil
1.02% S
0% A
Coal
.82% S
12.2% A
gas
Coal
.82% S
12,2% A
gas
Coal
70% S
14.0% A
Oil
1.0% S
gas
Oil
1.0% S
gas
Oil
1.0% S
gas
Coal
.70% S
15.0% A
oil
3% S
0%
gas
Coal
.70% S
15% A
gas
Oil
0.5% S
gas
Coal
.47% S
10.4% A
Amount
103ton/yr
26.9
871 MCF
17.9
580 MCF
-
39.4
2270 MCF
60
4600 MCF
494
1,900,000
gallons
886 MCF
1,900,000
gallons
886 MCF
2,540,000
gallons
1180 MCF
1.47
176000
gallons
2140 MCF
.90
866 MCF
3,810,000
gallons
365 MCF
540.5
Heat
Input
105BTU H
20
981
20
981
149
21
840
21
840
9300
148 per
1000 gals
840
148 per
1000 gal
840
148 per
1000 gal.
840
20
142 per
1000 gals
846
20
846
135 per
1000 gals.
840
1371
Emissions Tons/yr
S02
Exist Allow
357
<1
238
^1
0
614
<1
1250
1
0
149
<1
149
<1
199
^1
20
4
<}
12
<1
151
* 1
6220
~

-
~

5420
-
-
-
-
""
-
-
TSP
Exist
192
< 1
128
< 1
0
500
3
63
< 1
0
8
7
8
7
10
9
13
^ 1
^1
2
•^1
15
3
1643
Allow
35
56
23
37
0
95
84
193
459
18
48
18
48
23
59
1.9
16
108
1.3
55
31
18
?
Emissions  from Data Bank as of June 1974.
                                                   36

-------
                                         Table C-2.  Power Plant Projected Development  1975-1985
AQCR
038 San Isabel



040 Yampa


Unassigned ^
Unassigned
Unassigned
County
El Paso
El Paso
El Paso
Pueblo
Moffat

Routt



Owner
Dept. Pub. Util.
Dept. Pub. Util.
Dept. Pub. Util.
Pub. Ser. Co.
Colo.Ute. Ass'n.

Colo.Ute. Ass'n.
Pub. Ser. Co.
Pub. Ser. Co.
Pub. Ser. Co.
Plant
Martin Drake #7
na
na
Comanche #2
Craig #1
Craig #2
Hayden #2
Unassigned
Unassigned
Unassigned
MU
127
180
200
350
350
350
250
500
500
500
Estimated Emissions NSPS
TSP
450
637
708
1208
1208
1208
885
1770
1770
1770
so2
5400
7654
8504
14882
14882
14882
10630
21260
21260
21260
NOX
3150
4464
4960
8680
8680
8680
6200
12400
12400
12400
CO
        All plants are coal  fired.
        Unassigned power plants.

-------
                                         Table C-3.  Energy Development Power Plants
AQCR
036 Metro Denver

035 Grand Mesa
040 Yampa
Owner
Tri State

-
-
Type
Coal Gassification
Produces
^Generates)
250 MCF per day
Emissions, NSPS
TSP
Na
S02
Na
NOX
Na
Oil Shale Development (50,000 BPD Plant)3
Coal/Process Gas
Goal/Process Gas
200 MW
200 MW
708
708
8504
8504
4960
4960
OJ
co
          Estimates provided by EPA, Region VIII.

-------
                                       Table C-4.  AP-42 Power Generation Emission Factors
Fuel
CoalW(B1t.)
General
Wetbottom 10% A
Cyclone
1% S
2% S
3% S
Oil<2>.
0.5% S
1.0% S
2.0% S
Gas (3)
(.3 Ibs S/
106 Ft3)
Parti culates
Lbs/Ton Lbs/10° Btu
160 7.4
130 7.0
20 0.9
Same Same
as as
Above Above
Lb/103 Gal
8 0.058
8 .058
8 .058
Lb/106Ft3
15 .015
S02 6
Lbs/Ton Lbs/10° Btu



38 K65
76 3.3
114 5.0
Lb/103 Gal
79 0.56
157 1.12
314 2.24
Lb/106Ft3
0.57 .00057
Hydrocarbons/.
Lbs/Ton Lbs/10° Btu
0.3 0.013


0.3 0.13


Lb/103 Gal
2 .014
2 .014
2 .014
Lb/106Ft3
1 .001
MOX (as N02]
Lbs/Ton Lbs/106 Btu
18 0.78
30 1.3
55 2.4
Same Same
as as
Above Above
Lb/103 Gal
105 0.75
105 0.75
105 0.75
Lb/106Ft3
600 0.60
CO
10
      (1) Coal  23 x 105 Btu/Ton

      (2) Oil  140 x 103 Btu/Gal

      (3) Gas  1000 Btu/Ft3

-------
                                   APPENDIX D

      The D-l Tables in this appendix list individual industrial/commercial/
institutional sources of particulates and SC^ emissions which might show
fuel switching potential.  The sources are from a NEDS rank;>order emissions
listing.  At the top of D-l  Tables is the percent of total emissions (both
fuel and non-fuel sources) accounted for in the AQCR, since not all 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).
                                        40

-------
                        Table D-l.   Major Industrial  Fuel  Combustion  Sources with  Multi-Fuel  Capability
AQCR
035 Grand Mesa
036 Metro Denver















County
Montrose
Boulder

Boulder

Arapahoe

Adams

Adams

Adams

Adams

Adams

Source
#5
#2

#11

#11

#11

#24
(01)
#24
(02)
#24
(03)
#24
(04)
Boiler Capacity
106 BTU/Hr
Na
Na

Ha

80

Na

110

no

110

no

Fuel Type
Oil .5% S
Gas
Coal .2*5
8.3%A
Oil °%f
Gas
Oil 1.1% S
Gas
Oil 0.6%S
Gas
oil i.i%s
Gas
Oil .62% 5
Gas
Oil .62% 5
Gas
Oil .62% «
Gas
Oil .62% S
Gas
Annual Amount
800,000 gal.
394 MCF
46,200
160,000 gal.
286 MCF
70,000 gal.
382 MCF
136,000 gal.
85 MCF
260,000 gal.
1,910 MCF
88,000 gal.
150 MCF
88,000 gal .
150 MCF
88,000 gal.
150 MCF
88,000 gal.
150 MCF
Emissions
TSP
Exist Allow3
9
4
489
<-!
<1
^1
3
1
<^1
3
17
1
1
1
1
1
1
1
1
-
-
-
-
-
1.9
5.3
-

1.2
9.3
1.2
9.3
1.2
9.3
1.2
9.3
so2
Exist Allowb
31
-^1
176
13
^1
6
<1
6
<1
22
<1
4
<1
4
<-!
4
^.1
4
<1
-
-
-
-
-
-
-
- .

-
-
-
-
-
-
-
-


85% TSP
Control















Information insufficient for calculation.
S02 emission regulations for existing sources withdrawn.

-------
                            Table  D-l.  Major  Industrial Fuel Combustion Sources with Multi-Fuel  Capability  (Cont'd)
AQCR
036 Metro Denver
















County
Adams

Denver


Denver

Denver

Denver

Denver

Jefferson

Jefferson

Source
#30

#12


#19

#21

#28

#42

#7

#8
(01)

Boiler Capacity
106 BTU/Hr
55

680


5

Na

600

250

450

30

Fuel Type
Oil .6-% S
Gas
Oil 1.0% S
Oil .6% S
Gas
Coal .5% S
Gas
Oil .6% S
Gas
Oil .6% S
Gas
Oil .6% S
Gas
Oil 1.0%S
Gas
Coal 1.0%S
12.2XA
Oil .6XS
Gas
Emissions
TSP
Annual Amount Exist Allow3
384,000 gal.
431 MCF
538,000 gal.
2,510,000 gal.
2,000 MCF
75 Tons
20 MCF
818,000 gal.
3,600 MCF
266,000 gal.
277 MCF
187,000 gal.
762 MCF
312,000 gal.
905 MCF
4000 Tons
216,000 gal.
166 MCF
4 4.6
4 .04
2 3.6
10 19888
15 83
7 .1
<1 2.5
9
34
2 2.5
3 11.5
1 2.1
7 38
4 2.1
8 .1
317 7.6
2 3.1
2 13.8
Exist2Allowb
18
-M -
42
108
^1
.1 -
<1
39
1
IT
*1 -
8
^1
24
^1
76
9
^1
Information insufficient for calculation.
 S02 emission regulations for existing sources  withdrawn.

-------
                       Table  D-l.   Major  Industrial  Fuel  Combustion  Sources with  Multi-Fuel  Capability  (Cont'd)

AQCR
036 Metro Denver













037 Pawnee






County
Jefferson

Jefferson

Jefferson

Jefferson

Jefferson

Jefferson

Jefferson

Weld

Larimer




Source
#8
(02)
#8
(03)
#8
(04)
#20
(01)
#20
(02)
#20
(03)
#20
(04)
#3

#6
(01)
#6
(02)

Boiler Capacity
106 BTU/Hr
30

30

30

250

250

250

505

250

210

120


Fuel Type
Oil .6% S
Gas
Oil .6%S
Gas
Gas

Gas

Oil .25%S
Gas
Oil .25%S
Gas
Oil .25%S
Gas
Oil 1.0%S
Gas
Oil .75%S
Gas
Oil .75%S
Gas

Annual Amount
216,000 gal.
166 MCF
216,000 gal.
166 MCF
30 MCF

744 MCF

780,000 gal.
744 MCF
780,000 gal.
744 MCF
1 ,560,000 gal .
1490 MCF
1,550,000 gal
238 MCF
1,010,000 gal.
710 MCF
500,000 gal.
354 MCF
Emissions
TSP
Exist Allow3
2
2
2
2
^1

7

6
7
6
7
12
13
18
2
12
e
6
3
3.1
13.8
3.1
13.8
.01

37

6.6
37
6.6
37
11
63
12.6
12
7.9
36
3.6
16
S02 h
Exist All owb
9
^1
9
<1
<1

<1

14
<0
14
<1
28
<1
122
<1
59
^1
29
•cl
_
-
-
-
-

-

-
-
-
-
-
-
_
-
-
-
-
-
Information insufficient for calculation.
S02 emission regulations for existing sources withdrawn.

-------
                      Table D-l.  Major Industrial Fuel Combustion Sources with Multi-Fuel Capability  (Cont'd)

AQCR
038 San Isabel














County
Pueblo


Pueblo

Lake

El Paso

El Paso

El Paso

El Paso

Source
#1


#4

#1

#1
(01)
#1
:co2)
#1
(01)
#1
(02)
Boiler Capacity
106 BTU/Hr
4540


Na

80

36

120

380

60

Fuel Type
Oil .60%S
Gas
Annual Amount
1,050,000 gal.
10,200 MCF
Process Gas 71,200 MCF
Oil .3% S
Gas
Oil .7%S
Gas
on. IMS
Gas
oil .ms
Gas
Oil .7%S
Gas
Oil .7%S
Gas
80,000 gal.
400 MCF
5,000,000 gal.
346 MCF
600,000
160 MCF
1,800,000 gal.
240 MCF
2,780,000 gal.
551 MCF
1,150,000 gal.
17 MCF
Emissions
TSP
Exist Allow3
12
92
534
^1
4
38
3
5
2
14
2
32
5
13
±1
7.5
428
2990
-
-
53
22
80
12.8
14
11
21
25
11.6
1.1
S°2 K
Exist Allow0
50
3
?
2
^1
249
^1
8
*-\
23
<1
153
<1
63
<1
_
-
-
-
-
-
-
-
-
-
-
-
-
-
-
 Information  insufficient for calculation.
DS02 emission regulations for existing  sources  withdrawn.

-------
                                   APPENDIX E
     The state of Colorado was found to have no area sources which could
be evaluated within the context of Section 4 of ESECA,
                                    45

-------
                               APPENDIX F
                        IMPACT OF FUEL SWITCHING

The candidate sources for fuel switching identified in Appendices C and D
were evaluated to determine the potential effect on emission and to estimate
the potential for relaxation of regulations.  The percentage of coal utilized
was estimated by translating all fuel usage into total annual heat input
and directly proportioning on the basis of the percent of annual heat
input contributed by each fuel type.  Table F-l presents the power plant
present and potential emissions based on 100% coal utilization with present
control equipment.
                                     46

-------
              Table F-l.  Emissions Resulting from  Fuel Switch  to  100%  Coal  for  Power  Plants  with  Dual  Fuel  Capability
AQCR
036










037



038





Source
Valmont #1
#2
#3
Cherokee #1
#2
#3
#4
Arapahoe #1
#2
#3
#4
Ft. Collins #1
#2
#3
#4
Clark #1
#2
Drake #2
#3
Pueblo #1
#2
Present
Emissions3
TSP
6362
17
1209
189
63
152
344
100
36
32
152
78
78
125
219
192
128
503
63
14
2
so2
5502
3
317
373
373
499
1130
72
411
346
1009
12
12
19
32
357
238
614
1251
24
12
%
Coal
60
1
33
55
55
62
55
9
38
16
1
26
26
22
22
39
39
30
30
2
2
%
Gas
40
99
67
45
45
38
45
91
62
84
99
74
74
78
78
61
61
70
70
97
98
%
Oil
_
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
1
-
% Full
Coal Utilization
167
10000
303
182
182
162
182
1111
263
625
10000
385
385
455
455
256
256
333
333
5000
5000
Emissions after Fuel Switch
TSP
Emission Allow
10605
1500
70
344
115
246
626
1089
95
200
12000
300
300
569
996
491
328
1665
210
650
100
674
13
70
74
74
88
226
94
122
247
390
4.6
4.6
7.6
11.9
91
60
136
277
126
56
S02 .
Emission Allow
9185
300
961
679
679
808
2057
989
1752
1806
3800
46
46
86
146
914
609
2045
4162
100
600
_
-

-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
I
-
-
 Based on total  emissions from each fuel operation.
DS02 emission regulations for existing sources withdrawn.

-------
                              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.
                                    48

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                                   TECHNICAL REPORT DATA
                            (Please read Instructions on the reverse before completing)
 1. REPORT NO.

   EPA-450/3-74-080
                              2.
                                                            3. RECIPIENT'S \CCESSIOWNO.
4. TITLE AND SUBTITLE
   IMPLEMENTATION PLAN REVIEW FOR  COLORADO 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.
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.,  Regional Office VIII,  Denver, Colorado,
   and TRW,  Inc..  Redondo Beach, California
             11. CONTRACT/GRANT NO.

                68-02-1385
 12. SPONSORING AGENCY NAME AND ADDRESS
   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.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

     48
                                              20. SECURITY CLASS (Thispage)
                                                  Unclassified
                                                                         22. PRICE
EPA Form 2220-1 (9-73)
                                             49.

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