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.
------- |