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 ------- 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 ------- 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 ------- 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. ------- 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. ------- 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. ------- 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. ------- 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 ------- 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? ------- 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. ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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. ------- |