EPA-450/3-74-081
DECEMBER 1974
IMPLEMENTATION PLAN REVIEW
FOR
UTAH
AS REQUIRED
BY
THE ENERGY SUPPLY
AND
ENVIRONMENTAL COORDINATION ACT
U. S. ENVIRONMENTAL PROTECTION AGENCY
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EPA-450/3-74-081
IMPLEMENTATION PLAN REVIEW
FOR
UTAH
REQUIRED BY THE ENERGY SUPPLY AND ENVIRONMENTAL COORDINATION ACT
PREPARED BY THE FOLLOWING TASK FORCE:
U. S. Environmental Protection Agency, Region VIII
1860 Lincoln Street
Denver, Colorado 80203
Environmental Services of TRW, Inc.
(Contract 68-02-1385)
U. S. Environmental Protection Agency
Office of Air and Waste Management
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
December 1974
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TABLE OF CONTENTS
Page
1.0 EXECUTIVE SUMMARY 1
2.0 STATE IMPLEMENTATION PLAN REVIEW 6
2.1 Summary 6
202 Air Quality Setting - State of Utah 8
2.3 Background on the Development of the Current State
Implementation Plan 10
2.4 Special Considerations - Utah 11
3.0 CURRENT ASSESSMENTS BASED ON SIP REVIEWS 13
3.1 Regional Air Quality Assessments 13
3.2 Power Plant Assessments 13
3.3 Industrial/Commercial/Institutional Source 14
Assessment
3.4 Area Source Assessments 14
3.5 Impact of Fuel Switching 14
TECHNICAL APPENDICES
APPENDIX A - State Implementation Plan Background .... 16
APPENDIX B - Regional Air Quality Assessment 31
APPENDIX C - Power Plant Assessment 34
APPENDIX D - Industrial, Commercial, Institutional .... 43
Source Assessment
APPENDIX E - Area Source Assessment 46
APPENDIX F - Other Analyses 47
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1.0 EXECUTIVE SUMMARY
The enclosed report is the U. S. Environmental Protection Agency's
(EPA) response to Section IV of the'Energy Supply and Environmental
Coordination Act of 1974 (ESECA). Section IV requires EPA to review
each State Implementation Plan (SIP) to determine if revisions can be
made to control regulations for stationary fuel combustion sources
without interfering with the attainment and maintenance of the National
Ambient Air Quality Standards (NAAQS). In addition to requiring that
EPA report to the State on whether control regulations might.be revised,
ESECA provides that EPA must approve or disapprove any revised regulations
relating to fuel burning stationary sources within three months after
they are submitted to EPA by the States. The States may, as in the
Clean Air Act of 1970, initiate State Implementation Plan revisions;
ESECA does not, however, require States to change any existing plan.
Congress has intended that this report provide the State with infor-
mation on excessively restrictive control regulations. The intent of
ESECA is that 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
S0? emission regulations. The States have also been asked to discourage
large scale shifts from coal to oil where this could be done without
jeopardizing the attainment and maintenance of the NAAQS.
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To date, EPA's fuels policy has addressed only those States with the
largest clean fuels saving potential. Several of these States have, revised
or are currently in the process of revising.S02 reaualtions. 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 aJT_ 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 deveToping
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 were approved by EPA if they demonstrated the attainment
of NAAQS or_ more stringent state air quality standards. Also, at that time
an acceptable method for formulating control strategies was the use of an
example region for demonstrating the attainment of the standards.
The example region concept permitted a State to identify the most
polluted air quality control region (AQCR) and adopt control regulations
which would be adequate to attain the NAAQS in that region. In using an
example region, it was assumed that NAAQS would be attained in the other
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
NAAQS in some locations.
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EPA 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
limitations. The findings of this report are by no_means conclusive and
are neither intended nor adequate to be the sole basis for SIP revisions;
they djj, however, represent EPA's besj 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, N0,5 and HC emissions which occur in fuel switching, and other potential
A
air pollution problems such as sulfates .
Although the enclosed analysis has attempted to address the attainment of
all the NAAQS, most of the review has focused on total suspended particulate
matter (TSP) and sulfur dioxide (S0?) emissions. This is because stationary
fuel combustion sources constitute the greatest source of SOr, emissions and are
a major source of TSP emissions.
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Part of each State's review was organized to provide an analysis of
the S02 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 E.
FINDINGS
The Utah State Implementation Plan has been reviewed for the
most frequent causes of over restrictive emissions regulations.
Although Utah used the example region approach in developing
control strategies for both TSP and S02, there is no indication
that emission regulations for existing sources are over restric-
tive in the context of Section IV of ESECA.
Utah has a wide spread particulate problem as indicated by re-
ported violations of NAAQS at every monitoring location. Wind-
blown fugitive dust is a large contributor, however, major
"hot spots" are man-induced. Emission regulations for existing
sources are aimed at eliminating localized pollutant problems.
Relaxation of these regulations would make attainment and main-
tenance of NAAQS unlikely in the present "hot spots", and would
be mute in most other areas of the state due to the lack of man-
made emission sources.
t At present Utah has only one significant S02 problem, and it is
caused by process source emissions. Once this source completes
compliance efforts, S02 air quality will probably meet NAAQS
everywhere in the state. The only S02 emission regulation for
existing fuel combustion sources is a sulfur limit on fuel.
(Coal - 1%, Oil - 1.5%). The findings of this analysis indicate
that relaxation of this regulation is unnecessary because virtually
all local coals have lower sulfur contents. Utah presently uses
coal for a large percentage of stationary fuel combustion. Using
the local coals, additional coal utilization can be affected within
the framework of existing regualtions.
Major new coal fired power plants have significant potential for air
pollution impacts in the clean, less inhabited areas of Utah. New
Source Performance Standards may not be sufficient to preclude
localized violation of NAAQS.
It should be noted that every AQCR has proposed Air Quality Maintenance
areas for both S02 and TSP in those locations where significant emission
sources are or will be located.
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WASATCH
FRONT
INTRASTATE
UTAH
INTRASTATE
(REMAINING
AREA)
FOUR CORNERS
INTERSTATE
(ARIZONA-
COLORADO-
NEW MEXICO-
UTAH)
Figure 1. state of Utah
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2.0 STATE IMPLEMENTATION PLAN REVIEW
2.1 SUMMARY
A revision of fuel combustion source emissions regulations will
depend on many factors. For example:
Does the State have air quality standards which are more
stringent than NAAQS?
t Does the State have emission limitation regulations for
control of (1) power plants, (2) industrial sources,
(3) area sources?
Did the State use an example region approach for demon-
strating the attainment of NAAQS £r 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?
Are there no proposed Air Quality Maintenance Areas?
Are there indications of a sufficient number of monitoring
sites within a region?
Is there an expected 1975 attainment date for NAAQS?
Based on (1973) air quality data, are there no reported
violations of NAAQS?
t Based on (1973) air quality data, are there indications
of a tolerance for increasing emissions?
t Are the total emissions from stationary fuel combustion
sources proportionally higher than those of other sources?
0 Is there a significant clean fuels savings potential in
the region?
Do modeling results for specific fuel combustion sources
show a potential for a regulation revision?
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.
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STATE IMPLEMENTATION PLAN REVIEW
(SUMMARY)
FOUR CORNERS
INTERSTATE
_SIATE AOGR
UTAH
INTRASTATE
AQC;E
WASATCH
FRONT
INTRASTATE
ADfR
"INDICATORS"
Does the State have air quality standards
which are more stringent than NAAQS?
Does the State have emission limiting regu-
lations for control of:
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?
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?
« 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?
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?
TSP S02
NO
Yes
Yes
Yes
Yes
Yes
NU
Ypsa
Yesd
Yes
Yes
Yes
TSP S02
NO
Yes
Yes
NO
NO
NO
N/A
NO
Poor
NO
NO
NO
NO
N/A
N/A
TSP S02
NO
NO
Yes
N/A
NO
NO
N/A
NO
Poor
NO
NO
N/A
NO
Poor
NO
NO
NO
Yes
N/A
N/A
NO
N/A
NO
Poor
NO
TSP S02
NO
Yes
NO
NO
NO
NO
N/A
NO
Poor
NO
NO
Yes
NO
NOC
NOC
Yes
N/A
NO
Poor
NO
a) Sulfur limit on fuels for existing sources. 80% control for new sources.
b) None in Utah, 9 in the region
cj Current violations are single source oriented - a copper smelter in MaQna
which will be brought into compliance with EPA emission regulations.
Utah
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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 emis-
sion limiting regulations. In conjunction with the regional analysis, a r
characterization of the State's fuel combustion sources (power plants,
industrial sources, and area sources) has been carried out in Appendix C,
D, and 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 remaining portion of the report support this summary with
explanations.
2.2 AIR QUALITY SETTING - STATE OF UTAH
2.2.1 Air Quality Control Regions
The State of Utah is divided into three AQCR's. These are: Four Corners
Interstate AQCR (14), Utah Intrastate AQCR (219), and Wasatch Front Intrastate
AQCR (220), (Figure A-l1).
2.2.2 Ambient Air Quality Standards
A summary of the federal and Utah air quality standards for the pollutants
under study is presented in Table A-3. It should be noted that Utah duplicates
the federal standards for both S02 and NO,,. The only difference is the Utah
standard for particulate. The TSP standard is less stringent than the federal
standard for annual averages; however, it is stricter for a single 24-hour
measurement. Since federal standards apply nationwide, the state standard is
mute in this case.
tables and figures are in Appendices A through F.
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2.2.3 Air Quality Status
Air quality monitoring in Utah is limited. The Utah air monitoring
network (Table A-4) does not provide measurements in the Utah Interstate
AQCR. Two monitors for suspended particulates are located in the Four
Corners AQCR. The remaining stations are located in the Wasatch Front
AQCR. The network provides measured pollutant levels for suspended
particulates at all 8 sites, S02 data at 5 of the sites, and N02 data at
4 of the sites.
A summary of Utah Air Quality Status is presented in Tables A-5 and
A-6. The number of stations exceeding standards are presented by AQCR. The
highest S02 readings in Utah are around the Kennecott Copper Smelter near
Magna. When this significant source is brought into compliance, all SCL
measurements in the State should be below the SCL ambient standards. The
next highest SCk readings are in Salt Lake City; however, the concentra-
tions are within the standards. The highest particulate readings in the
o
State are in Salt Lake City and Provo. At 325 ug/m (24-hour average),
they are not far from standards and should be within limits by 7/75.
2.2.4 Emissions Summary
A summary of S02 emissions is presented in Table A-9. The summary is
presented in AQCR totals. Table A-8 presents the particulate summary by AQCR.
2
The summaries were prepared from the most current data available. An examina-
tion of the two summaries show that most sources are in the Wasatch Front AQCR.
The bulk of the Four Corners AQCR emissions are not generated in Utah. The most
telling information is a comparison of the total tons/year of pollutant by AQCR,
compared to the percent contribution from fuel combustion.
In general, air pollution problems within Utah tend to be localized and
single source oriented. Due to the State's arid climate, natural fugitive dust
emissions may make compliance with particulate secondary standards difficult even
when sources causing localized pollutant problems meet their present
compliance dates.
NADB information
21974 NEDS: August 5, 1974.
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2.3 BACKGROUND ON THE DEVELOPMENT OF THE CURRENT STATE IMPLEMENTATION PLAN
The SIP control strategies and regulations were based on the example
region approach. Wasatch Front AQCR (220), was used as the example region.
The control strategies and regulations, as submitted by the State, were
inadequate to attain the national standards for particulates and S02 in the
Wasatch Front AQCR. The other two regions were below national standards for
these pollutants.
The State regulations for the control of particulate matter included a
requirement that sources control 85% of potential particulate emissions. The
TSP regulation was disapproved by EPA for the Wasatch Front AQCR because it
was ambiguous and unenforceable.
EPA promulgated particulate matter regulations for the Wasatch Front
AQCR applicable to process sources, incinerators, fuel combustion sources
and by-product coke ovens on May 14, 1973 (38 FR 12709).
The Kennecott Copper Corporation and United States Steel each filed
a petition for reconsideration of these regulations on May 14, 1973. Based
on clarifications and new evidence provided by the corporations, EPA has
modified this regulation as it affects open-hearth furnaces, sintering
plants, copper smelting operations, and by-product coke ovens (9/5/74).
There are no S02 regulations applicable to existing sources, other than
a limit on sulfur content of fuels (\% for coal; 1-1/2% for oil). The State
has a current regulation requiring 80% control of SOp emissions from new
sources, with potential emissions of 500 tons of S02 per year or greater.
A new regulation controlling SOp emissions from copper smelters, the major
S02 emission source in the State, was proposed by EPA on October 18, 1974
(39 FR 37212). A summary of Utah's current fuel combustion regulations is
presented in Table A-12.
The Utah control strategy relies upon reasonably available control
technology for both S02 and particulate control, and upon the enforcement
of three Utah directives pertaining to Notice of Construction, Open
Burning, and Visible Emissions. The control strategy for particulate also
10
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includes a Utah directive pertaining to participate emissions. The S02
control strategy contains two Utah directives pertaining to Sulfur Content
of Fuels and Sulfur Oxide Emissions. It also relies on the Federal New
Source Performance Standards (Federal Register. 40 CFR, Part 60).
Utah does not have regulations controlling N02.
2.4 SPECIAL CONSIDERATIONS - UTAH
Ten counties within the State have been proposed as air quality
maintenance areas (Appendix A). 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 proposed as
AQMA's.
Utah plans to consider the adoption of SOp emissions regulations for
the copper smelters in October. In addition, Utah may drop the present
80% SOg emissions standard and adopt a non-degradation policy as a regulation.
This policy requires new sources in clean air areas to be controlled by best
available technology.
Like much of the Western United States, Utah has an abundance of energy
resources. These resources now have the potential of being developed. As a
source of future supply, coal and oil shale are the most promising resources
for development.
It is estimated that the Unitah Basin of Eastern Utah contains a potential
reserve of 90 billion barrels of oil, in the form of oil shale. For years this
resource has been bypassed in favor of more easily extracted fossil fuels. Two
parcels (approximately 5000 acres each) were leased by the Federal Government to
encourage oil shale development. Successful operations on the leased tracts
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 joint Utah-Colorado 1990
minimum development potential of 750,000 BPD production (estimated split: Utah,-
150,000 - 200,000 BPD; Colorado, 550,000 - 600,000 BPD).
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The most likely near term energy resource development in Utah is coal
Utah has three major deposits of bituminous coal with low sulfur content.
The largest is again in the Unitah Basin, in the eastern mid-third of the
state. Two smaller deposits are in the southern half of Utah.
In 1971, Utah had 22 coal mines, 21 underground and 1 above ground
(strip mine). Those mines produced $34.1 million in revenue. With the
resurgence of coal as the source of domestic power needs, it is expected
that extensive coal mine development will occur.
12
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3.0 CURRENT ASSESSMENTS BASED ON SIP REVIEWS
3.1 REGIONAL AIR QUALITY ASSESSMENTS
The only sites in the State that indicate a significant problem area are
the SOg monitors in the vicinity of the Kennecott Copper smelter near Magna,
Utah. This source is the major emitter of S02 in the State. Once this source
completes compliance efforts, SOp standards will be met throughout the State.
Tables A-10 and A-ll present the tolerance for emission increases on a
regionwide basis. A drawback for using this approach lies in the lack of com-
prehensive air quality data and in the large geographical dispersion of
emission sources in most Utah counties. The analysis does, however, give
some indication of potential candidate areas for relaxation.
Tables B-l and B-2 summarize the general data for each pollutant and
AQCR that must be considered when estimating the potential for regulation
relaxation. The analysis was performed to determine if there were any obvious
combustion source candidates. There is no indication from available data that
overly stringent regulations exist in any region. Areas that essentially
meet air quality standards now do not have stringent existing source regulations
(they also do not have many sources).
3.2 POWER PLANT ASSESSMENTS
At the present time there are fewer than 25 major sites with combustion
sources in the State. Four Corners AQCR (14) and Utah AQCR (219) have one
power plant each. Wasatch Front AQCR (220) contains the remaining sources.
The power plants in Four Corners AQCR (14) and Utah AQCR (219) are 100%
coal fired. There are seven power plants in Wasatch Front AQCR (220). Of
these, one is presently 100% coal fired, two are gas and oil fired with no
possibility of conversion (diesel and gas turbine), one plant and one unit
of another are gas and oil fired with no coal capability, the remainder
(3 plants, 4 units) presently use coal part of the time. Table C-l presents
relevant data for all power plants presently in operation in Utah. All plants
presently comply with emission regulations.
Table C-2 lists all known projected power plants (1974-1985). These are
all large mine mouth coal-fired installations. Most of these power plants
13
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are to be located adjacent to the coal source. The first unit of
Huntington has recently gone into operation.
Table C-3 provides an estimate of air quality impacts from the
proposed plants. This estimate is based on EPA modeling studies and con-
siders NSPS emission limits only. As can be seen,there are potential
violations of the SO^ ambient standards around several of the plants. More
stringent regulations may be required to maintain NAAQS.
Table C-4 lists the present fuel sources for each of the power plants.
The power plants that utilize both coal and other fuels are candidates for
fuel switching. These plants are further evaluated in Appendix F.
3.3 INDUSTRIAL/COMMERCIAL/INSTITUTIONAL SOURCE ASSESSMENT
All major stationary fuel combustion sources other than power plants
were reviewed to identify candidates for fuel switching. There are no major
fuel combustion sources in the Four Corners and Utah AQCR's that do not
presently use coal, or that have an apparent capability to switch to coal.
Table D-l lists the major sources in the Wasatch Front AQCR (220) that
presently use coal for at least part of the time and are candidates for 100%
conversion. These plants are further analyzed in Appendix F.
3.4 AREA SOURCE ASSESSMENTS
The State of Utah 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 the fuel combustion sources was made to determine the
feasibility of conversion to coal and its resulting impacts on emissions and
regulations. The candidate sources for fuel switching identified in
Appendices C and D were evaluated to determine 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. The
emissions resulting from conversion to coal at these candidate combustion
sources were estimated and compared to current emissions (Appendix F).
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Table F-l presents the power plant present and potential emission based
on 100% coal utilization with present control equipment. All power plants
will meet current emission regulations as configured.
Table F-2 presents the candidate industrial source present and potential
emissions based on maximum coal utilization with present control equipment.
The sources would not meet present parttculate regulations.
Table F-3 presents a summary of emissions impact from fuel switching.
Because the particulate emissions from industrial sources were so far out of
line, emissions resulting from the addition of adequate control equipment
were also calculated and included.
The analysis indicated that for SOg (after the Kennecott smelter
completes compliance efforts), the increase in projected emissions due to
fuel conversions would be significant. Ambient air quality standards
would be in jeopardy if further relaxation of regulations were to take
place. For particulates, the analysis indicates that fuel switching will
further aggravate the particulate compliance problem in the Wasatch Front
AQCR. The TSP standard would probably be met by sources complying with
present regulations; however, relaxation of the regulations in this region
would probably put the compliance goals out of reach.
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APPENDIX A
e State implementation plan information
o Current air quality information
o Current emissions information
Tables in this appendix summarize original and modified state imple-
mentation plan information, including original priority classifications,
attainment dates, ambient air quality standards, and fuel combustion emis-
sion regulations. SAROAD data for S02 and TSP monitoring stations are shown
for AQCI& in the state. NEDS emissions data by AQCR are tabulated a,nd
broken down into fuel burning categories.
Tables A-10 and A-ll 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 S02 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 ambient air quality standards in that AQCR (worst case
from Tables A-5 and A-6). 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 AQCR's
In1972 National Emissions Report," EPA - 450/2-74-012, June 1974.
16
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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-10 and A-ll. 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 AQCf& with JTO_ 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.
17
-------
Tab! e A-1. AQCK TrioH ty Cl assi ffcatlbri *nd AQMfts - Utah
00
1
AQCR
Four Corner:
(Ariz.,
Colo., N.
Hex., Utah)
Utah For tier
Utah
Intrastate
(Remaining)
Wasatch
Front
Fed. i
14
219
220
Part.3
1-A
III
I
V
1-A
III
I
NOXC
III
III
I
Demogra
Population
1970,
368,310
54,338
161,701
385,085
>h1c Information
Square
Miles.
109,101
33,103
38,402
10,422
Population
Density
3.4
1.6
4.2
37.0
Proposed AQMA Designations'1
TSP
Counties
(5)Emery,
Garfield
Kane,
Wash.
Wayne
(3)Carbon,
Duchesne,
Uintah
(3)Salt Lake
Utah,
Davis
..B< '
Counties
(5 JEmerv,
Garfield
Kane
Wash.
Wayr>£
(3}Car<,
Duchesne..
Uinttn
(2)Salt Lake
Davis
J9x
Counties
(3)Salt Lekt
Utah,
Davis
Criteria Sued on Maximum Measured (or Estimated) Pollution Concentration In Area
Priori tv
'Sulfur onldo:
Annual arithmetic mean ..
bPart1culate matter:
Annual geometric man ..,
24-hour naslmua
Nitrogen dioxide
I
Greater than
100
455
95
325
110
II
From - To
60-100
260-455
60- 95
150-325
111
Less than
SO
260
60
150
liO
Federal Register, August. 1974 SHSA's showing potential for NA/^S violations due to growth
-------
WASATCH
FRONT
INTRASTATE
UTAH
INTRASTATE
(REMAINING
AREA)
Proposed AQMA's
FOUR CORNERS
INTERSTATE
(ARIZONA-
COLORADO -
NEW MEXICO-
UTAH)
Figure A-l
Utah AQCR's
19
-------
Table A-2. Utah Attainment Dates
AQCR #
14
219
220
AQCR Name
Four Corners
Interstate
(Ariz., Colo., N.M.,
Utah)
Utah Interstate
Wasatch Front
Parti culates
Attainment Dates
Primary
7/75
a
7/77
Secondary
7/75
a
7/77
Sulfur Dioxide
Attainment Dates
Primary
3/76
a
7/77
Secondary
3/76
a
b
Nitrogen Oxides
Attainment Dates
a
1
a-
7/75 |
1
ro
o
Air quality levels presently below standards.
18 months extension granted.
-------
Table A-3. Utah Ambient Air Quality Standards
All Concentrations in H- gms/m3
Federal '
(Nov. 1972)
State
(Nov. 1969)
Primary
Secondary
Total Suspended Particulate..
Annual 24-Hour
75 (G) 260a
60 (G) 150a
90 (A) 200(b)
Sulfur Oxides
Annual 24-Hour 3 Hour
80 (A) 365a
1300a
80 (A) 365a
1300a
Nitrogen Dioxide
100 (A)
100 (A)
100 (A)
100 (A)
(1) Federal Regulations Apply
(A) Arithmetic Mean
(G) Geometric Mean
(a) Not to be exceeded more than once per year
(b) Not more than 1% of time between April 1 and October 31
Not more than 5% of time between Nov. 1 and March 31
-------
Table A-4. Utah Air Sampling Sites
AQCR
Four Corners (14)
Wasatch Front (220)
Utah (219)
SITE
Bullfrog Basin
Wahweap Marina
Kearns
Magna
Salt Lake City
Salt Lake City 1A
Ogden
Provo
-None-
COUNTY
Kane
Kane
Salt Lake
Salt Lake
Salt Lake
Salt Lake
Weber
Utah
22
-------
Table A-5. AQCR Air Quality Status (1973), TSP
AQCR Name
Four Corners
(Ariz, Colo,
N. Hex. Utah)
Utah Portion
Utah
: Wasatch Front
AQCR #
14.b
219
220
#
Stations
Reporting
23 C
2
0
6
(mg/mj)
TSP Concentration
Highest Reading
Annual
65
--
89
24-Hr.
430
254
390
2nd
Highest
"eadi na
24-Hr"
374
186
330
# Stations Exceeding
Ambient Air Quality Standards
Primary
Annua
0
-
0
4
24-Hr.
1
1
-
2
Secondary
Annua
1
-
-
4
%
4
-
-
80
d
24-Hr
8
2
-
6
%
35
100
-
100
%
Reduction
Required to
Meet 'Annual
Secondary
Standard
60
19
--
54
j
! %
! Reduction
{ Required to
! Meet 2nd
24-Hr.
Standard
24-hour
Secondary
Standard
H
H
tv>
OJ
a. 1973 air quality in National Air Data Bank as of July 28, 1974
b. Interstate
c. Violations based on more than one reading in excess of standards
d. Formula: 2nd highest 24-hr ---Secondary 24-hr standard
2nd highest 2'^hr
-------
Table A-6. Utah
AQCR Air Quality Status (1973), S02e
AQCR Name ;
Four Corners
(Ariz, Colo.
N. Mex, Utah)
Utah Portion
Utah
Wasatch Front
. AQCR #
14 b
219
220
#
Stations
Reporting
24-Hr
(Bubbler)
9
0
4
#
Stations
Reporting
IContin.)
4
0
8
S02 Concentration
(Mg/m3)
2nd
Highest
Highest Reading
Annual
2
-
128 5
24T
24-Hr
79
-
-
Reading
24-Hr
28
-
3072^
121T
# Stations Exceeding
Ambient Air Quality Stds.
Primary
Annual
0
-
1
24-Hr1-
1
-
8
Secondary
3-Hr
0
-
4
% A
Reduction0
Required
To Meet
Standards
Presently
Meets
Standards
88
Presently
Meets
Standards
Standard
on Which %
Reduction
Is Based
24-hr
Primary
Standard
ro
a. 1973 air quality in National Air Data Bank as of July 28, 1974
b. Interstate
c. Violations based on more than one reading in excess of standards
d. Formula: 2nd highest 24-hr Primary 24-hr standard ,
2nd highest 24-hr
e. From station located at Bonneville
f. From station in Salt Lake City (typical)
-------
Table A-7.. Fuel Combustion Source Summary - Utah
AQCR Name.
Four Corners
(Utah)
Utah
Wasatch Front
AQCR #
14
219
220
Utah Power Plants
NEDS b
1 '
1
5
, FPCC
1
0
3
Other Fuel Combustion Point Source::-;
Parti cul ate
2
2
6
so2
0
2
4
no
en
a. Only sources in Utah are included
b. All sources from National Data Bank Point Source listing as of June 17, 1974
c. Federal Power Commission information for 1973 of major power plants
-------
Table A-8. Utah Emissions Summary, TSP
AQCR
14 Four Corners
Utah Portion
219 Utah
220 Wasatch
Front
Total
Tons/Year
37,674
1,768
19,164
57,891
Percent
Fuel Combustion1
79.15
44.1
48
43.6
Electricity Generation
Tons/Year %
27,334 72.6
73 ' 4.1
5,200 27.1
588 1.0
Point Source
Fuel Combustion
Tons/Year %
95 0.25
0
74 0.4
7317 12.6
Area Source
Fuel Combustion
Tons/Year %
2395 6.3
714 40.0
3922 20.5
17370 30.0
ro
o*
(a) Emissions in Data Bank as of June, 1974
(b) Interstate
-------
Table A-9. Utah Emissions Summary, ,S02
AQCR
14 Four Corners
Utah Portion
219 Utah
220 Wasatch Front
Total
Tons/Year
119,755
1,717
11,637
154,455
Percent
Fuel
Combustion
93.8
49.6
62.3
16.1
Electricity Generation
Tons/Year %
110,854 92.6%
98 5.7%
3,675 31.6%
7,630 4.9
Point Source
Fuel Combustion
Tons/Year %
175 0.146%
0
659 5.7%
8510 5.5%
Area Source
Fuel Combustion
Tons/Year %
1315 1.1%
754 43.9%
2909 25%
8859 5.7%
(a) Emissions in Data Bank as of June 1974
(b) Interstate
-------
Table A-10. Utah Required Emission Reductions
ro
00
SIP
1973 Data
AQCR I';-
Four
Corner
(014)
Utah
Portion
NDA
Utah NDA
(219)
Wasatch
Front
(220)
AQ
Measurement
Control
Value
85
79
Emissions
(103 tons)
.151
1.8
20.0
33.8
Allowable
Emissions
(103 tons)
.128
30.1
1975D
Estimated
Emissions
After Controls
(TO3 tons)
-
a. Interstate
b. Data not presented in SIP
Percent
Reduction
Required
Based On
1973 AQ Data
65
60
54
NEDS
Emissions
(103 tons)
37.7
1.7
19.2
57.9
Allowable
Emissions
(103 tons)
48.3
1.3
18.9
26.8
Emission
Tolerance
(IP3 tons)
10.6
-------
Table A11. Utah Required Emission Reductions, SCL
F\3
SIP
AQCR
Four
Corners
(014)
Utah
Portion
Utah
(219)
Wasatch
Front
(22Q)
SLC Area
Meets
Standarc
AQ
Measurement
Control
Value
-
-
-
2930C
-
Emissions
(103 Tons)
-
2.0
8.8
345 o 4
-
Allowable
Emissions
(103 Tons)
-
-
-
190
-
197_5 b
Estimated
Emissions
After Controls
(103 Tons)
-
-
-
NC
-
a. Interstate
b. Data not presented in SIP
1973 DATA
Percent
Reduction
Requl red
Based On
1973 AQ Data
91
Meets
Standards
Meets
Standards
88
SLC Area
Meets
Standards
NEDS
Emissions
(103 Tons)
119.4
1.7
11.6
154.5
. -
Allowable
Emissions
(103 Tons)
108
NDA
NDA
18.4
-
Emission
Tolerance
(103 Tons)
311.5
-------
Table A- 12. Fuel Combustion Regulations - Utah
Existing Sources
New Sources
SO,
Coal -1.035 Sulphur by Weight
Oil - 1.5% Sulphur by Weight
(Section 3.3.1. of Utah Code)
80% Control of input
Sulphur from facilities
with potential emissions
of 500 tons of SOo per
year or greater (Section
3.6.1. of Utah Code)
Particulate
co
o
#2 Ringelmann (40% capacity)
(Section 3.2.1.)
#1 Ringelman (20% capacity)
(Section 2.2.2.)
85% control of potential particulate emissions (Section 3.5.1. of Utah Code)
Fuel Burning Sources - Wasatch Fron Range
10 or less 0.6 lb/106 Btu
10 MBtu to
10,000 MBtu...A=0.87C
-0.16
Where A = allowable emission rate in lb/10 Btu
C = total rated capacity in 106 Btu/hr
-------
APPENDIX B
Tables B-l and B-2 are the assessment of AQCR*s 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.
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. Finally,it is possible
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" emission rate now
may be below "average" regulations.
31
-------
B-l. Candidacy Assessment for Relaxation of TSP Regulations
AQCR
014
Utah '
Portion
219
220
Air Quality
#
Monitors
23
2
0
6
#
Violations
8
2
-
6
Expected
Attainment
Date
7/75
7/75
a
7/77
Total
Emissions
(103 ton si
37.6
1.7
19.1
57.9
Any
Proposed
AQMA
Designations?
_
5
3
3
% Emission
from Fuel
Combustion .
79.2
44.1
48
43.6.
Tolerance
for
Emissions
Increase
(103 tons)
10.6
0
0
0
Overall
Regional
Evaluation
Marginal
Poor
Poor
Poor
CO
ro
-------
B-2. Candidacy Assessment for Relaxation of S02 Regulations
AQCR
014
Utah
Portion
219
220
Air Quality
#
13
0
0
12
#
1
-
'
8
Salt Lake City Area
Neglating violations
relating to smelter
source
Expected
Attainment
Date
3/76
a
a
7/77
Total
Emissions
(103 tons)
1.19.8
1.7
11.6
154.5
Any
Proposed
AQMA
Designations?
_
5
3
2
% Emission
from Fuel
Combustion
93.8
49.6
62.3
16.1
Tolerance
for
Emissions
Increase
(103 tons)
0
-
-
0
311.5
Overall
Regional
Evaluation
Poor
--
-
Poor
Good
co
GO
a)Air Quality Levels Presently Below Standards
-------
APPENDIX C
This section is a review of individual power plants by AQCR. The
intent is to illustrate: (1) current S02 and particulate emissions, (2)
fuel switching possibilities, and (3) allowed emissions for power plants
based on current regulations. The total AQCR emissions resulting from
possible fuel 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 FPS (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-5 were used where not known. S(L 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 SCL and particulate
emissions (see Table C-5).
Table(s) C-l also lists allowable emissions calculated by applying current
regulations to the given plant, taken from Table A-12. (Particulate limits are
assumed to be based on the entire heat input of the plant. Actual rules may be
different when applied to each of several boilers in a power plant or applied
on the basis of design capacity rather than actual amount of fuel used.)
It might be cautioned that AQCR total emissions calculated in the tables
of Appendix C (and also Appendix D) may not agree exactly with total emissions
represented in Appendix A (Tables A-7, A-8). This is a result of both differing
fuel schedules in 1973 compared to previous years and the relative "completeness"
of the NEDS data bank. Along the same line, AQCR totals may contain a '"mix" of
1972 and 1973 fuel schedules (and resulting emissions). The intent of the list-
ings is not great precision, but rather to show approximate status relative to
regulations at present.
Table C-2 lists power plants under construction or consideration for the
near to medium term future. No evaluation of these plants is attempted here
since Federal new source performance standards would apply. It is not the
34
-------
purpose of this report to evaluate such standards. Inclusion of new plants is
for background information which might have a bearing on other decisions about
emission regulations in an AQCR.
Table C-4 lists the present fuel sources for each of the power plants. The
power plants that utilize both coal and other fuels are candidates for fuel
switching. These plants are further evaluated in Appendix F.
35
-------
Table C-1A. Utah Power Plant Evaluation
a
AQCR/
County
14
Iron
219
Carbon
220
Davis
220
Davis
Utility
Name
Cal
Pacific
Utility
Utah
Power
£
Light
Plant Name
Cedar City
Carbon #1
Carbon #2
Bountiful
City Power
(Diesel)
Clearfield
Steam Co.
(2 boilers-1 stack)
MW
7.5
75
114
?
?
Fuel
Type
Coal
0.5% S
8.3% A
Coal
0.5% S
6.9% A
Coal
0.5% S
6.9% A
Oil
0.6% S
0% A
Nat'l
Gas
Coal
0.7% S
10% A
Coal
0.7% S
10% A
Amount
103 Tons/Yr
10.3
161
226
146,000
gallons
134 x 166
Cu Ft
6.4
6.4
Heat Input
TO6 Btu/H
100
773
1025
Diesel
Diesel
25
25
Emissions ^ Tons/Yr
so2
Exis. Allow.
98
1530
2150
2
86
86
197
3060
4300
15
15
123
123
TSP
Exis. Allow.
73
75
2650
<1
24
24
108
1420
2000
q
9
58
58
N02
Exis. Allow
93
1450
2030
27
49
49
-
-
-
-
-
oo
en
Taken from NEDS, August 1974; and Steam Electric Plant Factors, 1973 Edition, NCA, January 1974
-------
Table C-1B. Utah Power Plant Evaluation9
AQCR/
County
220
Salt Lake
200
Salt Lake
Taken from
Utility
Name
UP&L
UP&L
UP&L
UP&L
NEDS, A
Plant Name
Jordan
Gats by #1
Gatsby #2
Gatsby #3
MW
25
69
69
114
Fuel
TYPE
Nat'l
Gas
Oil
0.5% S
0% A
Nat'l
Gas
Oil
1 . 25% S
0% A
Nat'l
Gas
Oil
1.26% S
0% A
Coal
0.5% A
6.9% S
Nat'l
Gas
Oil
1 . 26% S
0% A
Coal
0.5% S
6.9% A
Amount
103 Tons/Yr
272 No6CuFt
663x1 O3
gallons
628x1 06CuFt
22. 6x1 O6
gallons
352x1 06CuFt
22. 6x1 O6
gallons
27.3
1 890x1 06Cu Ft
7.2xl06
gallons
173
ieat Input
106 Btu/H
76
76
674
674
717
717
717
1072
1072
1072
Emissions ^ Tons/Year
so2
Exis. Allow.
<1
24
<1
2210
<1
2240
260
<1
713
1650
80
80
2670
2670
3190
3190
3190
4150
4150
4150
TSP
Exis. Allow
2
3
5
90
<1
<1
<6
<1
<1
305
144
144
903
903
950
950
950
1330
1330
1330
N02
Exis. Allow
82
35
188
1180
106
1190
246
568
378
1560
-
-
-
-
-
-
-
-
ugust 1974; and Steam Electric Plant Factors, 1973 Edition, NCA, January 1974
GO
-------
Table C-1C. Utah Power Plant Evaluation3
AQCR/County
220
Salt Lake
229
Utah
220
Utah
Utility Name
City Power
#1
#2
#3
#4
#5
City Power
Utah
Plant
Name
Murray
Provo
Utah
Power &
Light
Fuel
MW
14
44
Type
Oil
0.5% S
0% A
iiat'l
Gas
Oil
0.5% S
0%A
Nat'l
Gas
Oil
0.5% S
0% A
Nat'l
Gas
Oil
0.5% S
0% A
Nat'l
Gas
Oil
0.5% S
0% A
Nat'l
Gas
Nat'l
Gas
Coal
0.7% S
10% A
Coal
0.5% S
6.9% A
Nat'l
Gas
Amount
103 Tons/Yr
67.1xl04
gallons
96xl06CuFt
67.1xl04
gallons
96xl06CuFt
67. 1x1 04
gallons
96xl06CuFt
67.1xl04
gallons
96xl06CuFt
67x1 O4
gallons
,96xl06CuFt
195xl06
13.3xl03
ISxlO3
597x1 03CuFt
Heat Input
106 Btu/H
142
142
142
142
142
142
142
142
142
142
875
24
24
930
Emissions ^ Tons/Yr
so2
Exis. Allow.
<1
-
<1
-
<1
-
<1
-
<1
-
4
177
171
<1
6
6
6
6
6
6
6
6
6
6
253
253
342
342
TSP
Exis. Allow.
<1
-
<1
-
<1
-
<1
-
<1
-
<1
33
42
<1
29
29
29
29
29
29
29
29
29
29
177
177
804
804
N02
Exis. Allow'
4
29
4
29
4
29
4
29
4
29
22
100
162
179
-
-
-
-
-
-
-
-
-
-
-
-
CO
00
aTaken from NEDS, August 1974; and Steam Electric Plant Factors, 1973 Edition, NCA, January 1974
-------
Table C-2. Power Plant Projected Development 1974--1985 >c AQCR 14
CO
County
Emery
Wayne
Garfield
Kane
Washington
Owner
UP&L
IPCA
IPCA
UP&L
IPCA
APS.SPP,
SCE.SDS &E
NP.UP&L
Plant
Huntington
North Emery
Factory Butte
Caineville
Escalante
Escalante
Kaiparowits
St. George
Capacity
845
830
?
3000
2000
?
3000
2500
Estimated Emissions
Tons/Year
NSPS Utah3
Parti cul ate S02 S02
3955
3955
--
13797
9198
--
13797
11498
47479
47479
-_
165564
110376
--
165564
137970
8234
8234
--
28777
19184
--
28777
24002
(a) Based on 80% reduction of S02 over uncontrolled
(b) AH plants are coal fired mine month plants
(c) Based on EPA Technical Supoort for Designation of AQMA's
-------
Table C-3. Estimated Air Quality Impacts for Proposed Power Plants in AQCR 14a'b
Plant
Huntington Canyon
North Emery
Factory Butte
Caineville
Escalante #1
Escalante #2
Kaiparowits
St. George
so2
24-Hr. 3-Hr.
515
4
-
16
11
-
770
13
1285
120
-
440
300
-
2500
370
Particulate
24-Hr. _
27
1
-
2
1
-
17
2
a. Assumes compliance with EPS NSPS, does not account for Utah 80% S02 regulation.
b. Based on EPA modeling results performed on part of the AQMA designation study.
-------
Table C-4. Present Utah Power Plant Fuel Sources
AQCR
Power Plant
Utility
14
219
220
£OAL. ONLY
Cedar City Plant
Carbon #1 & #2
Freeport Center
CPU
UP&L
Clearfield Steam Co.
220
GAS & OIL ONLY
Bountiful
Gatsby #1
Jordan
Murray #1,2,3,4,45
Bountiful City Power
UP&L
UP&L
Murrary City Power
220
Coal & Other Fuel
Gatsby #2 & #3
Provo
Hale
UP&L
Provo City Power
UP&L
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Table C-5. AP-42 Power Generation Emission Factors
Fuel
Coal 0) (Bit.)
General
Wetbottom 10% A
Cyclone
1% S
2% S
3% S
Oil'2).
0.5% S
1.0% S
.2.0% S
Gas 0)
(.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/10b Btu
38 K65
76 3.3
114 5.0
Lb/103 Gal
79 0.56
157 1.12
314 2.24
Lb/105Ft3
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
NOX (as NOz)
Lbs/Ton Lbs/105 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
ro
(1) Coal 23 x 106 Btu/Ton
(2) Oil 140 x 103 Btu/Gal
(3) Gas 1000 Btu/Ft3
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APPENDIX D
MAJOR INDUSTRIAL SOURCES that are CANDIDATES for FUEL SWITCHING
All major stationary fuel combustion sources were reviewed to identity
candidates for fuel switching. There are no major fuel combustion
sources in the Utah and Four Corners AQCR's that do not presently use
coal or that have apparent capability to switch to coal. Table D-l lists
the major sources in the Wasatch Front AQCR that presently use coal for
at least part of the time and are candidates for 100% conversion. These
plants are further analyzed in Appendix F.
43
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Table D-l. Major Industrial Fuel Combustion Sources.with Coal and Other Fuel Capability
AQCR
220
S. L. County
Kennecott
Source #1
#2
#3
#4
Boiler Capacity
106 BTU/Hr
480
480
480
840
Fuel
Type
Nat'l
Gas
Coal
.86% S
8% A
Nat'l
Gas
Coal
.86% S
8% A
Nat'l
Gas
Coal
.86% S
8% A
Nat'l
Gas
Coal
.86% S
8% A
Yearly
Amount
2.3xl09CuFt
30,xl03Tons/Yr
2.57xl09CuFt
2.6xl03Tons
2.52xl09CuFt
29.8xl03Tons
4.03xl09CuFt
53.3xl03Tons
Emissio
Parti c
Exist Allow
15
1430
16
1230
16
1420
3
40
679
679
679
679
679
679
1090
1090
is Tons/Yr
so2
Exist Allow
<1
489
<1
424
<1
489
1
879
570
570
495
495
570
570
1020
1020
25% Parti c
Control
25% Parti c
Control
25% Parti c
V
90% Parti c
-------
Table D-l. Major Industrial Fuel Combustion Sources with Coal and Other Fuel Capability (Continued)
AQCR
220
Utah Co.
U. S. Steel
Source #22
#23
#24
#25
Boiler Capacity
106 BTU/Hr
200
412
412
412
Fuel
Type
Process
Gas
Nat'l Gas
Coal
.7% S
6.5% A
Process
Gas
Nat'l Gas
Coal
.7% S
6.5% A
Process
Gas
Nat'l Gas
Coal
.7% S
6.5%A
Process
Gas
Nat'l Gas
Coal
.7% S
. 6.5% A
Yearly
Amount
400xl06CuFt
400x1 06CuFt
4.9xl03Tons
800x1 06CuFt
800x1 06CuFt
9.75xl03Tons
800x1 06CuFt
800xl06CuFt
9.75xl03Tons
800xl06CuFt
800xl06CuFt
9.75xl03Tons
Emission
Parti c
Exist Allow
3
4
271
6
7
539
6
7
539
6
7
539
334
334
334
597
597
597
597
597
597
597
597
597
s Tons/Yr
so2
Exist Allow
-
<1
65
-
<1
130
-
<1
130
-
<1
130
-
_
-
-
_
-
-
_
-
-
-
-
en
-------
APPENDIX E
Area Source Assessment
There are no area sources which could be evaluated within the context of
section IV of ESECA.
46
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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. All power plants
will meet current emission regulations as configured. The candidate
industrial source present and potential emissions is presented in Table F-2
based on maximum coal utilization with present control equipment. A summary
of emissions impacts from fuel switching is presented in Table F-3. Because
the industrial sources particulate emissions were so far out of line, emissions
resulting from the addition of adequate control equipment were calculated
and included.
47
-------
Table F-l. Emissions Resulting from Fuel Switch to 100% Coal for-
Power Plants with Dual Fuel Capability
AQCR
220
Source
Gatsby #2b
Gatsby #3C
Provo
Hale6
Present En
(Tons
Parti c
16
305
33
42
n'ssions3
/Yr)
so2
2500
2363
177
171
Emissions After
Parti c (Tons/Yr)
Emiss Allow
106
515
51
95
950
1330
177
804
Fuel Switch
so2
Emiss Allow
1734
2788
272
388
21277
7013
390
776
-p.
00
(a) Based on total emissions from each fuel operation.
(b) Gatsby #2 uses coal for 15% of yearly total heat at present. Assume coal could replace natural gas
and oil for an increase in coal utilization of 667%.
(c) Gatsby #3 uses coal for 59% of yearly total heat at present. Assumes coal could replace natural gas
and oil for an increase in coal utilization of 169%.
(d) Provo uses coal for 65% of yearly total heat at present. Assumes coal could replace natural gas for
an increase in coal utilization of 154%.
(e) Hale uses coal for 44% of yearly total heat at present. Assumes coal could replace natural gas for
an increase in coal utilization of 227%.
-------
Table F-2. Industrial Source Emissions Resulting from Fuel Switching to 100% Coal
U. S. Steel b
Source #22
Source #23
Source #24
Source #25
Plant Total emissions
Kennecottc
Source #1
Source #2
Source #3
Source #4
Plant Total Emissions
Present Emissions9
Partic S02
278 65
553 130
553 130
553 130
1937 455
1445 489
1246 424
1436 489
43 879
4170 2281
Emissions After Fuel Switch
Partic
Emiss. Allow
1223e
2433e
2433e
2433e
8522
5621d
4847d
5586d
167
16221
334
597
597
597
2125
679
679
679
1090
3127
so2
Emiss. Allow
286
572
572
572
2002
1902.
1649
1902
3419
8873
-
-
-
-
-
2217
1925
2217
3968
10327
(a) Based on total EMISSIONS FROM EACH FUEL OPERATION.
(b) U. S. Steel uses coal for 15.7% of total heat, natural gas for 53.5% and process gas for 30.8%.
Assumed coal could replace natural gas for an increase in coal utilization of 440%.
(c) KENNECOTT uses coal for 25.7% total heat and natural gas for 74.3%. Assumed coal could replace
natural gas for an increase in coal utilization of 389%.
(d) Based on current 25% control efficiency. Ninety-one (91%) control equipment would be required
to bring it into compliance.
(e) Based on 0% control efficiency - 70%+ would be required to bring in into compliance.
-------
Table F-3. Impact of Fuel Switching AQCR 220
Parti dilates
Present
w/Fuel Switch (a)
w/Fuel Switch (b)
so2
Present
w/Fuel Switch
Total
Tons/Yr
57891
76898
62591
154455
162575
Emissions
% from
Fuel Comb.
43.6
57.4
47.9
16.1
20.1
lc\
Elect Generationv '
Tons/Yr %
588
959
959
7630
7601
1.0
1.2
1.5
4.9
4.7
Point Source
Fuel Combustion
Tons/Yr %
7317 12.6
25953 33.7^
11646 18.6^
8150 5.5
16189 10
Area Source
Fuel Combustion
Tons/Yr %
17370 30.0
17370 22.5
17370 27.8
8859 5.7
8859 5.4
CJl
o
(a) Emissions based on major point sources CONTINUED WITH PRESENT CONTROLS (DO NOT MEET EPA REGS)
(b) Emissions based on major point sources applying controls adequate to meet emission regs
(c) Electricity generation emissions would meet emission regs with present control equipment
-------
TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1. REPORT NO.
EPA-450/3-74-081
2.
3. RECIPIENT'S XCCESSIOI*NO.
I. TITLE AND SUBTITLE
IMPLEMENTATION PLAN REVIEW FOR UTAH 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
20. SECURITY CLASS (Thispage)
Unclassified
22. PRICE
EPA Form 2220-1 (9-73)
51
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