-75 -011
MARCH 1975
IMPLEMENTATION PLAN REVIEW
FOR
IDAHO
AS ICUUUIUE'U*
BY
THE ENERGY SUPPLY
AND
ENVIRONMENTAL COORDINATION ACT
U. S. ENVIRONMENTAL PROTECTION AGENCY
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EPA-450/3-75-011
IMPLEMENTATION PLAN REVIEW
FOR
IDAHO
REQUIRED BY THE ENERGY SUPPLY AMD ENVIRONMENTAL COORDINATION ACT
PREPARED BY THE FOLLOWING TASK FORCE:
U. S. Environmental Protection Agency, Region X
1200 6th Avenue
Seattle, Washington 98101
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
March 1975
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TABLE OF CONTENTS
Page
1.0 EXECUTIVE SUMMARY 1
2.0 REVIEW OF THE STATE IMPLEMENTATION PLAN AND CURRENT
AIR QUALITY 6
2.1 Air Quality Setting - State of Idaho 8
2.2 Background on the Development of the State
Implementation Plan 12
2.3 Special Considerations 16
3.0 AQCR ASSESSMENTS 19
3.1 Assessment by Regional Air Quality Indicators .... 19
3.2 Assessment by Source Analysis of Power Plant/
Industrial-Commercial/Area Sources 20
TECHNICAL APPENDICES
APPENDIX A - State Implementation Plan Background A-l
APPENDIX B - Regional Air Quality Assessment B-l
APPENDIX C - Power Plant Characterization C-l
APPENDIX D - Industrial, Commercial, Institutional
Source Characterization D-l
APPENDIX E - Area Source Assessment E-l
APPENDIX F - Other Analyses F-l
iii
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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 inter-
fering 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 sub-
mitted to EPA by the States. The States may, as in the Clean Air Act of
1970, initiate State Implementation Plan revisions; ESECA does not, how-
ever, 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 SIPs, wherever possible, be revised in the interest of con-
serving 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 consistent 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 encour-
age States to either defer compliance regulations or to revise the S02
emission regulations. The States have also been asked to discourage
large scale shifts from coal to oil where this could be done without
jeopardizing the attainment and maintenance of the NAAQS.
1
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To date, EPA's fuels policy has addressed only those States with the
largest clean fuels saving potential. Several of these States have or
are currently in the process of revising S02 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 all the National Ambient Air Quality
Standards.
There are, in general, three predominant reasons for the existence
of overly restrictive emission limitations within the State Implementa-
tion 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 situations affect many State Plans and in some in-
stances conflict with current national energy concerns, a review of the
State Implementation Plans is a logical follow-up to EPA's initial ap-
praisal of the SIPs conducted in 1972. At that time SIPs 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 demon-
strating the attainment of the standards.
The example region concept permitted a State to identify the most
polluted air quality control region and adopt control regulations which
would be adequate to attain the NAAQS in that region. In using an example
region, it was assumed that NAAQS would be attained in the other AQCRs
of the State if the control regulations were applied to similar sources.
The problem with the use of an example region is that it can result in
excessive controls, especially in the utilization of clean fuels, for areas
of the State where sources would not otherwise contribute to NAAQS viola-
tions. For instance, a control strategy based on a particular region or
source can result in a regulation requiring one percent sulfur oil to be
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burned state-wide where the use of three percent sulfur coal would be
adequate to attain NAAQS in some locations.
EPA anticipates that a number of States will use the review findings
to assist them in making the decision whether or not to revise portions
of their State Implementation Plans. However, it is more 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 con-
clusive and are neither intended nor adequate to be the sole basis for
SIP revisions; they do, however, represent EPA's best judgment and effort
in complying with the ESECA requirements. The time and resources which
EPA has had to prepare the reports has not permitted the consideration of
growth, economics, and control strategy tradeoffs. Also, there has been
only limited dispersion modeling data available by which to address indi-
vidual 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 cur-
rently 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 quality air.
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 over-
all impact which the potential relaxation of overly restrictive emissions
regulations for combustion sources might have on their future control
programs. This may include air quality maintenance, prevention of signi-
ficant deterioration, increased TSP, NOV, and HC emissions which occur in
X
fuel switching, and other potential air pollution problems such as sulfates,
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Although the enclosed analysis has attempted to address the attain-
ment of all the NAAQS, most of the review has focused on total suspended
particulate matter (TSP) and sulfur dioxide (SC^) emissions. This is
because stationary fuel combustion sources constitute the greatest source
of S02 emissions and are a major source of TSP emissions.
Part of each State's review was organized to provide an analysis of
the S02 and TSP emission tolerance within each of the various AQCRs. 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 "indica-
tors" 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.
The major findings evolving from the study are:
« The review indicates that SOo fuel combustion emission
regulations may be revised in the Idaho and Metropolitan
Boise AQCRs without jeopardizing attainment and maintenance
of NAAQS. In addition, it is possible that S0£ fuel com-
bustion emission regulations are over-restrictive for most of
of the area within the Eastern Idaho and Eastern Hashington-
Morthern Idaho (Idaho portion) AQCRs. The review also
indicates that present fuel burning practices are in over-
compliance with S0£ emission regulations (due to the use
of low sulfur fuels and natural gas), and that there is
room to increase S02 emissions before violating the emis-
sion regulations in each of the AQCRs.
Particulate fuel combustion emission regulations do not
appear to be overly restrictive in any of the four Idaho
AQCRs. In each of the regions, fugitive dust, suspended
by traffic, construction, and industrial activities, is
the major contributor to high levels of suspended parti-
culate matter. In rural areas, where fugitive dust does
not pose the same problem as in urban areas, it may be
possible to revise particulate emission regulations from
fuel burning sources. However, revisions of particulate
regulations in areas of worst air quality (urban areas)
would only aggravate the existing and projected air pol-
lution problems for particulates.
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Areas in which S02 or particulate fuel combustion emission
regulations may be revised without jeopardizing attainment
of federal air standards, are candidates for clean fuel
savings. In addition, there are regions where significant
fuel savings may be accomplished within the constraints of
the regulations emission limits, and without jeopardizing
attainment of federal air standards. The review analysis
indicates that S02 emissions may be increased significantly
(to obtain clean fuel savings) without violation of emis-
sion regulations or interference with attainment of air
quality standards in the Idaho and Metropolitan Boise
AQCRs, and in most of the Eastern Idaho and Eastern Wash-
ington-Northern Idaho AQCRs. The analysis shows that
particulate emissions may be significantly increased
without violation of combustion emission regulations in
all regions by 1975, but that potential clean fuel sav-
ings programs which would cause such an increase in parti-
culate emissions would probably conflict with air quality
attainment goals in the urban areas of all regions.
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2.0 STATE IMPLEMENTATION PLAN REVIEW
A revision of fuel combustion source emissions regulations will de-
pend on many factors. For example:
Does the State have air quality standards which are more
stringent than NAAQS?
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 demonstra-
ting the attainment of NAAQS or_ more stringent State
standards?
t Has the State initiated action to modify combustion emis-
sion regulations for fuel savings; i.e., under the Clean
Fuels Policy?
Are there 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 reported (1973) air quality data, does air quality
meet NAAQS?
Based on reported (1973) air quality data, are there indi-
cations of a tolerance for increasing emissions?
Based on the State Implementation Plan, are there indica-
tions of a tolerance for increasing emissions in 1975?
Are the total emissions from stationary fuel combustion
sources less than those from all other sources?
Must emission regulations be revised to accomplish signi-
ficant fuel switching?
Do modeling results for specific fuel combustion sources
show a potential for a regulation revision?
t Is there a significant clean fuels savings potential in
the region?
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Table 2-1. State Implementation Plan Review (Summary) for Idaho
IDAHO
PORTION, METRO-
EASTERN E.WASH. POLITAN
STATE IDAHO N.IDAHO IDAHO BOISE
"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 initiated action to modify
combustion source emission regulations for fuel
savings; i.e., under the Clean Fuels Policy?
Are there proposed Air Quality Maintenance
Areas?
* 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?
Based on the State Implementation Plan, are
there indications of a tolerance for increasing
emissions in 1975?
Is the fraction of total emissions arising
from stationary fuel combustion sources lower
than from all other sources combined?
Do modeling results for specific fuel combustion
sources show a potential for a regulation revision?
Do emission regulations need to be relaxed
to obtain significant clean fuel savings?
Based on the above Indicators, what is the
potential for revision fuel combustion source
emission limiting regulations?
Is there a significant Clean Fuels Saving6
potential in the region?
TSP S02
No
Yes
Yes
No
No
No
No
Yes
Yes
Mo
No
MO
TSP S02
No
Yes
Nod
No
No
Yes3
Yes
No
Margi-
nal11
No
No
No
Yes
f
f
Yesa
Yes
TSP S02
No
Yes
Nod
No
No
Yesa
No
No
Yes
No
No
No
Yesa
Yes
NO MODELING RESULTS t
No
Margi-
nal
Yes
No
Margi-
nal
Ho
No
Margi-
nalb
Yes
TSP S02
No
Yes
Nod
No
No
Yesa
Yes
VAILABL
No
Margi-
nal
No
No
No
Yesc
f
f
Yesa
No
No
Good
Yes
TSP S02
No
Yes
Nod
No
No
No
Yes
No
Poor
No
No
No
Yesc
f
f
Yesa
No
No
Good
Yes
aA "yes" assessment in these instances indicates there are various counties within the region which are expected to
possess an emission tolerance in 1975. These counties are removed from the areas where worst air quality levels are
recorded.
The region has been rated "marginal" rather than "poor," because some portions (or counties) of the region are able
to tolerate regulation revisions without jeopardizing attainment of federal air standards.
cThis refers to AQCRs where ambient concentrations are already (as of 1973) 1n compliance with federal air quality standards.
The plan includes a control strategy which aims for attainment by 1975, but 1t is not clear whether the plan can provide
the required degree of control for fugitive dust to meet the standards. Additional controls will be added 1f necessary,
but it is doubtful they would be Implemented in time to meet the 1975 deadline.
e"Clean fuel savings" refers to the replacement of current fuel schedules with "dirtier"'fuels. (Whenever emissions from
fuel burning sources can be Increased without jeopardizing attainment of NAAQS, 1t may be plausible that fuel resources
allocations can be altered for "clean fuel savings.")
No SOj monitoring data was reported for these regions.
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The following portion of this report is directed at answering these
questions. An AQCR's potential for revising regulations is then deter-
mined by a consideration of the air quality indications represented in the
responses to the above questions.
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 limit-
ing regulations. In conjunction with the regional analysis, a character-
ization 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, AQCRs
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 supports this summary with
explanations.
2.1 AIR QUALITY SETTING - STATE OF IDAHO
The following discussion provides a characterization of the various
AQCRs in terms of air quality. It includes an examination of ambient air
standards, emission inventories, and air-monitoring networks.
2.1.1 Air Quality Control Regions
The State of Idaho has been divided into four federal air quality
control regions to provide a basis for the adoption of regional air quality
standards and the implementation of these standards. One of these regions
is interstate and includes adjacent counties of Washington and Idaho.
The four regions and their boundaries are shown in Figure A-l.
The geographical limits of the Eastern Idaho AQCR contains 14 counties
in the southeastern part of Idaho, 23 percent of the area of the state,
and 30 percent of the population. The major population centers are located
8
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along the Snake River Valley which runs southwestward from Idaho Falls
(population - 35,776) to Pocatello (population - 40,036). The region is
classified Priority I for particulates. In addition to the generally
high particulate levels within the urban centers of the valley, regions
of maximum concentration are located in the vicinity of the FMC and J. R.
Simplot Company phosphorus and fertilizer plants near Pocatello, and in
the vicinity of Becker Industries in Conda. The Eastern Idaho AQCR is
classified 1A for sulfur dioxide because of the release of $$2 from (1)
the two sulfuric acid plants operated by Simplot, and (2) the Becker
industrial complex in Conda.
The Idaho portion of the Eastern-Washington-Northern Idaho Interstate
AQCR contains five Idaho counties which comprise 8 percent of the area of
the state and contain approximately 15 percent of the population. The
largest cities are Lewiston (population - 26,068), Coeur d'Arlene (popula-
tion - 16,228) and Moscow (population - 14,146). The region is classified
Priority I for particulates. The largest known sources of particulates
are from solid waste disposal, principally slash burning and conical
burners, and from operations at the Potlatch Forest, Inc. mill in Lewiston
and the Bunker Hill Company smelters in Kellogg. Lesser amounts are con-
tributed by the processing of agricultural products, grass burning, and
other agricultural activities. The region is classified 1A for sulfur
dioxide because of the high concentrations of the gas found in the Coeur
d'Arlene valley near the Bunker Hill Company smelters.
The principal sources of particulates within the Idaho AQCR are solid
waste disposal (slash burning and conical burners) and fuel combustion
(coal and wood burning). The region is classified priority III for sulfur
dioxide. The principal city of concern in the region is Twin Falls, with
a population of 21,914. The largest single known source of particulates
in the vicinity of Twin Falls is the Amalgamated Sugar Plant.
The areas of principal concern in the Metropolitan Boise AQCR are
the cities of Boise (74,990), Nampa (20,768), and Caldwell (14,219). The
largest sources of particulates by category are fuel combustion and process
losses. The region is classified priority III for sulfur dioxide, and
II for particulates.
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The air pollution priority classification for each of the air quality
control regions for particulates, S02 and NOX, is presented in Table A-2.
Table A-2 also provides an identification of counties which have been pro-
posed as Air Quality Maintenance Areas. The data indicate that the most
pressing air pollution problem involves particulates. Three of the four
AQCRs have been designated as priority I for particulates, and none of
the regions are presently in compliance with the federal secondary stan-
dards for particulates. Table A-3 shows the expected attainment dates
for federal air quality standards in the four AQCRs. It can be seen that
there is uncertainty regarding the attainment schedules for both parti-
culates and S02-
2.1.2 Ambient Air Quality Standards
Ambient Air Standards for the State of Idaho are as shown in Table
A-4. The state standards for particulates and S02 are equivalent to the
federal standards.
2.1.3 Air Quality Status
The 1973 air quality status for suspended particulates in the various
AQCRs is given in Table A-5. Table A-5 summarizes the worst cases of
particulate concentrations for each of the regions in 1973. Violations
of the federal air standards (on a 24-hour and annual basis) for suspended
particulates occurred in all the AQCRs. Based on proportional model
criteria, each of the regions will require more than 60% reduction in
emissions to attain the standards based on the 1973 air quality levels.
As is typical of regions containing both rural and urban areas* the
AQCRs in Idaho are subject to uneven distributions of source loading.
The uneven distribution causes consistent high particulate measurements
at monitoring sites in the areas of greatest emission density, while the
remainder of the region usually reflects a much lower particulate profile.
Monitoring studies performed throughout the State of Idaho have shown that
the particulate problem is a city-wide phenomena, and that rural locations
experience substantially lower concentrations of particulates which are
generally in compliance with the federal standards.
10
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The surveillance network for S02 is characterized by the use of sul-
fation plates in all AQCRs except the Eastern-Washington-Northern Idaho
Interstate. Data from these sulfation plate networks is not reported
through the SAROAD system, and therefore air quality status for S02 levels
is somewhat unclear through most of Idaho. In the Idaho portion of the
Eastern-Washington-Northern Idaho Interstate AQCR, the highest second
highest 24-hour concentration of S02 recorded was 1248/Kj/m3. This con-
centration indicates an emission reduction of 71% is necessary to attain
the standards in this Interstate AQCR. Due to the absence of S02 air
quality data, it is not known if S02 levels in the Eastern Idaho AQCR are
also presently in violation of S02 federal air standards. Therefore, the
degree of emissions reduction now needed to attain S02 standards in the
Eastern Idaho AQCR is not precisely known. While recent measurements of
atmospheric levels of S02 in the Idaho and Metropolitan Boise AQCRs are
also unavailable, emissions of S02 are known to be relatively insignifi-
cant in these regions, and it is presumed that S02 levels there are in
substantial compliance with federal standards.
While Table A-8 does not provide a complete summary of the particulate
emissions generated in the Idaho regions (the inventory does not include
fugitive emission sources), it does include an indication of the quantity
and types of fuel combustion particulate emissions in the various regions.
It is seen that fuel combustion sources account for 9 to 60% of the total
inventoried particulate emissions in the various regions. Most of the
fuel combustion particulate emissions arise from industrial and commer-
cial point sources. Because nearly all electrical energy consumed by the
state of Idaho is generated by hydroelectric power plants, particulate
emissions generated from electrical generating facilities are insignifi-
cant in all the AQCRs. The quantity of particulate emissions generated
by area sources is also relatively small, ranging from 4.4% to 8.1% of
the combustion source category particulate emissions.
Table A-7 lists the number of combustion emission sources in each of
the AQCRs. These are the number of emission sources which have been in-
ventoried in the NEDS and/or the Federal Power Commission Data System.
Only one power plant has been identified as a significant emission source
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throughout the State. The most substantial portion of the fuel burning
emission sources are industrial-commercial fuel burning units.
Table A-9 provides a summary of S02 emissions generated throughout
the various Idaho AQCRs. The role of fuel combustion in S02 emissions
varies greatly from region to region. In the Eastern Idaho and Eastern
Washington-Northern Idaho Interstate AQCRs, fuel combustion sources
account for 10 to 12% of the total S02 emissions, while in the Idaho and
Metropolitan Boise AQCRs, 72 to 80% of the S02 emissions originate from
fuel burning. As expected, very little S02 is generated from power plant
activity (predominantly hydroelectric). In all the AQCRs, combustion area
sources account for the most substantial portion of the fuel combustion
S02 emissions inventory. The area source emissions arise primarily from
residential space heating and the burning of fuel oils in small commercial
applications.
The actual quantity of S02 emissions from fuel combustion sources
is relatively insignificant throughout the regions. In the two regions
designated priority I for S02, fuel combustion emissions exercise a minor
role in the buildup of ambient S02 levels, accounting for only 2.2 tons
(out of a total of 18.4 tons) of S02 in the Eastern Idaho AQCR, and 3.5
tons (out of a total of 34.7 tons) of SOp in the Eastern Washington-
Northern Idaho AQCR. The impact of fuel revisions or relaxation of com-
bustion source emission regulations on atmospheric levels of S02 in these
areas would be very minor.
2.2 BACKGROUND ON THE DEVELOPMENT OF THE STATE IMPLEMENTATION PLAN
This section provides a characterization of the Implementation control
strategies, a reconciliation evaluation between air quality/emissions
relationships assumed at the time of the strategy development and those
which can be assumed from more recent data, and an evaluation of the
tolerance each of the AQCRs possesses for increased emissions of particulates
and S02«
2.2.1 General
The State of Idaho developed a control plan for achievement of the
federal air standards for particulates and S02 by addressing the specific
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air pollution problems in each of the regions. Special focus was directed
to the various "hot spots" of each AQCR. Emission reductions were sought
for those local sources which could be demonstrated as contributors to the
worst air quality of the regions. The impact of candidate control stra-
tegies were investigated by developing projected emission inventories,
and calculating emission reductions expected to result from application
of the strategies. These emission reductions were then related to the
expectant air quality by means of proportional model rollback calculations
and area model diffusion calculations.
2.2.2 Particulate Control Strategy
In the development of the control strategy for attainment of the
ambient air standards for particulates, the State of Idaho discovered that
known inventoried sources of particulates are not entirely responsible for
the high ambient particulate levels throughout the state. Modeling tech-
niques were used to determine the contribution of inventoried emission
sources to the measured particulate levels. These models showed that only
a small percentage of the total measured particulate values in any area
could be accounted for in terms of known (inventoried) emissions.
A recent study by the State has indicated that the major source of
high ambient particulate levels is fugitive dust. Accordingly, the most
recent amendments to the Idaho air program implementation plan include pro-
visions for control of fugitive dust sources. This control strategy is
directed at the control of 1) industrial fugitive dust sources, 2) dust
from construction and demolition operations, and 3) dust from unpaved
streets. This strategy, in addition to available control technology which
will be applied to known existing sources, is to be applied in all four
AQCRs in an attempt to attain the federal air standards by 1975. However,
in-view of the analytical difficulties associated with the quantification
of fugitive dust sources and the reductions expected to occur as a result
of the newly adopted strategies, it is not possible to show clearly that
the secondary standards for particulates will be achieved by 1975 (Table
A-3) in any of the regions.
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Table A-10 summarizes pertinent data used in the development of
particulate control strategies for the various AQCRs, and identifies the
major known emission sources of the "hot spot" which are to be selectively
controlled with reasonable available control technology.
2.2.3 Sulfur Oxide Control Strategy
The control strategy for SCL addresses the area in the state where
the federal standards for ambient SCL levels are violated: (1) in the im-
mediate vicinity of the Simplot Fertilizer Company near Pocatello, (2)
in the vicinity of the Bunker Hill Company smelters at Kellogg, and (3)
in the vicinity of the Becker Industrial complex in Conda.
In the Eastern Idaho AQCR, the most difficult S02 pollution problem
will be mitigated by an S02 emission reduction of 45% by the Simplot
Company acid plants. (Reduction of other S0£ emissions in the Pocatello
area would incur insignificant impact on the SOg air quality levels in the
vicinity.) A compliance program implementing the necessary reduction of
S02 emissions through installation of a scrubbing system, or equivalent
emission reduction measure, will be negotiated with the company. This
control plus other measures applied to the Becker Industrial Complex in
Conda, should enable the region to meet the Federal ambient S02 standards.
In the Idaho portion of the Eastern Washington-Northern Idaho Inter-
state AQCR, S02 emission reductions of 85% would be required by the Bunker
Hill smelters to meet the secondary standards in-the area of worst air
quality. The current control strategy to attain the SCL standard consists
of 1) application of reasonable available control technology, and 2) imple-
mentation of plant operational changes. It is doubtful that the control
strategy can achieve the standards by 1975, since present technology is
inadequate to provide the degree of emission control needed, and the
impact which plant operational changes will have on air quality is unclear.
Because emissions of SCL are insignificant in the Idaho and Metropolitan
Boise AQCR (classified priority III with respect to S02), the control
strategy for SCL there consists only of fuel specifications limiting sulfur
content in fuel oils and coal.
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Table A-ll summarizes pertinent data used in the development of S02
control strategies for the various AQCRs. The air quality measurements
selected as the controlling value for rollback determination for the Eastern
Idaho AQCR were constituted on annual values estimated from a mathematical
model. Air quality data for S02 in the Idaho and Metropolitan Boise was
known to be in compliance with S02 standards, based on modest sulfation
plate data obtained in the region.
2.2.4 Emission Tolerance Evaluation
Table A-10 and A-ll provide an assessment of the tolerance which each
of the AQCRs possesses for increased emissions of particulates or S02. If
a region has a tolerance for more emissions, then this indicates: 1) it
is possible that fuel burning schedules may be revised so that clean fuel
savings may be accomplished, and 2) it is possible that fuel combustion
emission regulations may be (but not necessarily) relaxed. The methodology
used in calculating the emission tolerance is explained in detail in
Tables A-10 and A-ll. There are basically two ways in which the tolerance
is derived: 1) by a comparison of allowable region wide emissions with the
actual emissions forecast in 1975, using the data from the Implementation
Plan analysis, or 2) by a comparison of allowable region wide emissions with
the actual 1973 emissions as determined using 1973 air quality/emissions data.
The former method is chosen when the Implementation Plan forecasts appear
to be reconcilable with recent air quality/emissions data. In this case,
forecasts of the plan are considered valid, and used to develop an emissions
tolerance. If justified, this method is preferable, since the emission
tolerance developed in this way reflects the full impact of the control
strategies after their implementation is complete in 1975. The emission
tolerance becomes a measure of the degree of "over-cleaning" accomplished
by the plan, or in cases where the region was already within air quality
standards and did not require additional pollution controls, the tolerance
is an expression of the degree of degradation possible before federal air
quality standards are jeopardized. However, if irreconcilabilities exist
from the comparison of Implementation Plan forecasts with more current air
quality and emissions data.it will be necessary to abort the first approach
discussed above, and determine the emission tolerance based on 1973 air
15
-------
quality status in the region, which reflects the estimation before many
substantial controls have been fully implemented from the control strategy.
Table A-10 provides the summary of data used to generate a particulate
emission tolerance in each of the AQCRs. None of the regions possess a
tolerance for increased emission of particulates in the vicinity of the
areas of worst air quality. However, air monitoring studies throughout
the State of Idaho indicate that rural areas possess air quality in com-
pliance with ambient air standards. It is probably therefore, that rural
areas within the regions possess a significant tolerance for increased
particulate emissions. However, the existence of these "rural tolerances11
would carry limited implications for the regions existing sources, most
of which are located in the vicinity of urban areas.
Table A-11 provides a summary of the data used to determine an S02
emission tolerance in the various AQCRs. Substantial tolerances appear
to exist throughout the Idaho and Metropolitan Boise AQCRs, and the same
would appear to be true in the Eastern Idaho and Eastern Washington-
Northern Idaho Interstate AQCRs, with the exception of areas in the vicin-
ity of the hot spots. Data was unavailable to permit the quantification '
of the S02 tolerances.
2.2.5 Fuel Combustion Emission Regulations Summary
Table A-12 provides a summary of emission regulations for,fuel com-
bustion equipment which have been adopted as a part of the control strategy
of the Idaho State Air Program Implementation Plan. The regulations are
applicable throughout the state. SCL emissions from combustion units are
limited by restricting the sulfur content in fuels. Particulate emissions
from existing fuel combustion equipment are limited according to the size
of the combustion equipment (see Figure A-2).
2.3 SPECIAL CONSIDERATIONS
This section provides a brief narrative on special considerations
which effect final assessments to be developed in this report.
16
-------
2.3.1 Planned Revisions to the Implementation Plan
It has been recognized that limited information was available to
characterize the fugitive dust problems throughout the urban areas of Idaho
at the time of the control strategy formulation. Therefore, allowances
have been made in the plan to provide for ongoing development of control
strategies as may be indicated appropriate by new data obtained from an
expanding air monitoring network and special study efforts. This policy is
exemplified by current study efforts to quantify the impact of fugitive
dust sources on particulate loadings in each of the AQCRs, and to assess the
impact of candidate control measures designed to eliminate these dust load-
ings. As a result of these studies, the State will evaluate the
adequacy of regulations scheduled to be implemented under the control
strategy of the State air program, and revise them as needed to insure
attainment of federal air standards.
2.3.2 Special Problems
The enforcement of regulations limiting particulate emissions from all
fuel combustion sources will force: 1) the use of control equipment on wood
burning boilers, or 2) the use of alternative fuels. It is expected that
most wood burning operations will be adapted for compliance with parti-
culate regulations by installation of boiler stack emission control equip-
ment.
2.3.3 Fuels and Anticipated Fuel Conversions
The vast majority of energy consumption in the State of Idaho is pro-
duced by hydroelectric power plants. Of the current fuel energy used in
the State of Idaho in 1972, 17% was petroleum, 46% was natural gas and the
remainder (tt%) was coal or wood (see Table E-l). This distribution of
fuel usage is expected to change substantially over the next few years.
The use of fuel oils is expected to increase drastically due to increas-
ing curtailment of Canada's supply of natural gas to the Northern States.
This would indicate that a significant portion of the fuel combustion
equipment in Idaho will be converted to burn fuel oil, and consequently,
emissions of S02 and particulates will increase significantly.
Under the imposed gas curtailments (which in effect, amounts to
clean fuel savings), it is unclear whether industry will be capable of
17
-------
providing the controls needed to comply with the emission regulations of
the control strategies. (Of course this uncertainty is present even if
fuel schedules do not change, as many industries are now operating in
variance with regulations until they can provide control installations.)
Particulate control devices can probably be supplied in time to meet the
compliance deadline for particulate control, but a current trend toward
shortage of low sulfur fuel oils may create difficult fuel compliance
problems since increasingly larger quantities of the low sulfur fuel will
be needed (in place of curtailed gas) to meet the regulations. Flue gas
desulfurization systems loom as a future emission control alternative
(as opposed to fuel sulfur limitations) for S02 emissions, but because of
their limited application to date, these systems are not expected to be
available as a means of meeting 1975 attainment deadlines.
18
-------
3.0 AQCR ASSESSMENTS
This section provides: 1) an assessment of the feasibility for ac-
complishing clean fuel savings in the various AQCRs, and 2) an assessment
of fuel combustion emission regulations to determine if they are overly
restrictive for the attainment of National Ambient Air Quality Standards in
the various AQCRs.
The first assessment is carried out with an evaluation of various
regional air quality indicators developed in Section 2 and compiled in
Appendix B (and then again by evaluation of the impact of a reasonable
fuel switch as determined in Appendix F). The regional air quality in-
dicators considered are comprised of criteria shown in Table B-l and B-2,
and include: 1) the breadth of air quality violations, 2) expected attain-
ment dates, 3) proposed AQMA designations, 4] total regional emissions,
5) portion of emissions from fuel combustion, 6) and regional tolerance
for emission increase. The emission tolerance possibly provides the most
important indicator, since, if it is known, it provides a measure of the
over-cleanliness of the region, now or projected, and indicates how much
additional pollution (from dirtier fuels) can be permitted.
The assessment of the restrict!veness of fuel combustion regulations
was performed with an evaluation of the impact of fuel burning operations
on air quality when those operations emit at a level equivalent to the
ceiling limit of the emission regulations. These emissions are calculated
in Appendices C,D, and E for power plants, industrial/commercial point sources,
and area sources, and then summarized in Appendix F.
The assessment of the various AQCRs is discussed below.
3.1 ASSESSMENT BY REGIONAL AIR QUALITY INDICATORS
Table B-l indicates that three of the four AQCRs can be considered a
marginal candidate for clean fuel savings (or possibly regulations relaxa-
tion) without jeopardizing compliance with particulate ambient air quality
standards. These regions are marginal candidates because their potential for
clean fuel savings depends on the specific area of consideration within the
region. Urban areas are poor candidates for fuel savings because of the un-
certain adequacy of the present control strategy to attain standards in these
hot spots (urban areas), and rural areas are godd candidates because they
19
-------
possess significant tolerance for increased participate emissions. (It
should be noted that a relatively small number of significant particulate
combustion sources are located in the rural areas of these regions, hence,
the impact of clean fuel savings programs there would probably be minimal.)
The Metropolitan Boise AQCR is judged to be a poor candidate for clean
fuel savings because of the relatively even distribution of particulate
emission sources which contribute to consistently high ambient particulate
levels throughout this small region.
Table B-2 shows that both the Idaho and Metropolitan Boise AQCRs
appear to be good candidates to accomplish clean fuel when they are con-
strained by attainment of the SCL air standards only. This evaluation
results from the fact that these AQCRs are presently demonstrating attain-
ment with the standards, and that substantial SCL emission tolerances
exist in these regions. The remaining regions have been judged marginal
candidates for clean fuel savings or possibly, regulations relaxation. In
these regions, there are areas in the vicinity of the single hot spot of
each region where an attempt to develop clean fuel savings would jeopardize
attainment of the standards there. However, in the remainder of these
regions, it appears there is a potential for clean fuel savings since
substantial tolerance for increased $03 emissions exists there.
3.2 ASSESSMENT BY SOURCE ANALYSIS OF POWER PLANTS/INDUSTRIAL-COMMERCIAL/
AREA SOURCES
As over 90% of all power generation in Idaho is hydro-electrically
produced, there are only a limited number of fuel burning power plants in
the State of Idaho. Fuel use and emission data for the only significant fuel
burning power plant in Idaho is shown in Table C-l. This plant is coal
fired, and the emissions of SO^ and particulates arising from their opera-
tion is virtually insignificant in the overall emission inventories of the
affected AQCRs.
Table D-l provides a summary of the major industrial/commercial fuel
combustion point sources in the various AQCRs. The number of these sources
which have been identified in the NEDs emission inventory is reported on
Table;,A,-7» In Table D-l, wood burning plants in each county have been
aggregated together as a single source, since it was not expected that clean
20
-------
fuel savings objectives would be applicable to wood burners. The emissions
summary of Table D-l shows that industrial sources of all AQCRs are in
substantial compliance with the SCL emission regulations. This is achieved
through a combination of the burning of natural gas and wood. With respect
to compliance to particulate regulations however, the point sources are found
to be significantly deficient in all regions. However, based on the assess-
ment of emission tolerance in the various AQCRs, compliance of those sources
located in the rural areas with particulate regulations may not be necessary
for the attainment of ambient air standards. For example, the relatively large
emission of particulates generating from the county of Bonneville in the
Eastern Idaho AQCR may possibly be maintained at status quo without the need
of additional air pollution controls to attain the standards. The same
example can be made for rural portions of the Eastern Washington-Northern
Idaho Interstate and Idaho AQCRs.
The significance of the fuel combustion area source varies greatly from
region to region (Tables A-8 and A-9), and often accounts for a large portion
of the SQy emissions inventory. The relative significance of the area source
in the generation of particulate emissions is far less pronounced (Table A-8).
Area sources are comprised largely of residential and industrial space
heating units, and small industrial and commercial boilers, burning distil-
late and residual fuel oils. These units are exempt from emission control,
and are not constrained to consume "clean" fuels. Therefore, it does not
appear that significant clean fuel savings can be accomplished from the
area source sector of the fuel consuming categories.
Table F-l and F-2 combine the analysis of Appendix C and D (power plants
and industrial/commercial point sources) to provide an assessment of the
restrict!veness of fuel burning emission regulations. The assessment is
carried out by evaluating the difference between the projected fuel combus-
tion emissions in 1975 and those emissions which are emitted at the level
of emission regulations. This difference constitutes the additional emis-
sions which would result if, after compliance with regulations in 1975, all
fuel burning sources were to alter fuels or operations, causing emissions to
rise up to the level of the regulations. It is clear that if the additional
21
-------
s
Ol
emissions calculated are more than the emission tolerance compiled for the
region (Tables A-10 and A-ll), the emission regulations are not overly
restrictive, and they should not be relaxed.
The concepts associated with the assessment of restrictiveness of
fuel combustion regulations are illustrated in Figure 3-1. It can be seen
that there are two distinct levels of emissions which are "allowable."
One of these allowable levels corresponds to the total region-wide emis-
sions which are generated when all regulated fuel combustion sources emit
at the ceiling level of the emission regulations, and the other allowable
level corresponds to the maximum region-wide emissions which can be per-
mitted before air quality standards would be violated. In Figure 3-1, the
emissions allowable when fuel burning equipment emits at the level of the
fuel combustion regulations (Curve C) are shown to be less than that emis-
sion total which would jeopardize compliance with the federal air stan-
dards (Curve A). This would constitute a case in which fuel combustion
emission regulations may be relaxed. Depending on the circumstances of
an AQCR, it may be possible for curve C to be above or below the curves
A and B in Figure 3-1. When curve C is above A after 1975, fuel combus-
tion emission regulations are possibly, less stringent than necessary to
insure compliance with the standards.
Emissions tolerance 1n 1975
Measure of "over compliance" with fuel combustion emission regulations
Measure of restrictiveness of fuel combustion emission regulations
LEGEND:
_ (A) Emissions allowable for compliance with secondary ambient air standards
(B) Actual emissions (past and projected)
(C) Emissions allowable when fuel burning sources emit at regulation limits
1975
1985
Figure 3-1. Evaluation of Restrictiveness of Fuel Combustion
Emission Regulations
22
-------
In Table F-l, it can be seen that fuel participate emission regulations
for fuel combustion operations appear to be overly restrictive only in the
rural areas of the Eastern Idaho, Eastern-Washington-Northern Idaho, and
Idaho AQCRs. In these regions (the rural areas) it may be possible for
fuel combustion equipment to emit at the ceiling rate of the particulate
emission regulations without jeopardizing attainment (or maintenance) of
the air quality standards for ambient particulate concentrations. In the
Metropolitan Boise AQCR, high particulate levels exist throughout the
region, and it does not appear that particulate emission regulations should
be relaxed to any extent in this region.
In Table F^2, it is demonstrated that it would be possible to incur
substantial relaxation of the SOg emission regulations in the Idaho and
Metropolitan Boise AQCRs without interfering with attainment of ambient air
quality objectives. It also appears that regulations may be overly res-
trictive in areas removed from the single SOp hot spots of the Eastern Idaho
and Eastern Washington-Northern Idaho AQCRs. Practically all the regional
S02 emissions are concentrated in the two hot spots, hence the remaining
portions of the region possess a significant tolerance for increased SCL
emissions. In addition, due to a high degree of over-compliance with
regulations, stemming from the use of natural gas and wood as fuels, there
is substantial room to increase SOp fuel combustion emissions without vio-
lating emission regulations. Tfiis suggests that significant clean fuel
savings (in low sulfur fuel oil and natural gas) can be accomplished without
the need of revising regulations.
The impact of a feasible fuel switch to obtain clean fuel savings in the
State of Idaho is summarized in Table F-3. It was assumed that all gas burn-
ing combustion equipment would be converted to burn high sulfur (2%S)
residual fuel oil, and that all use of residual fuel oil would be converted
to the high sulfur (2%S) type. Plants operating with both coal and gas were
assumed to be convertible to 100% coal use. The switch is assumed to occur
in 1975, after compliance with emission regulations has been attained (by
particulate emission controls and use of low sulfur fuels). For those units
which are converted for the fuel switch, it is assumed that no additional
emission control equipment is installed. Hence, for all units converted
23
-------
from gas only to fuel oil, there will undoubtedly be accompanying emission
regulation violations. Also, since it was assumed that S02 emission
compliance is attained in 1975 through use of low sulfur fuels, conversion
of these fuels to higher sulfur (2%S) oil will also incur emission regula-
tion violations. While such a conversion scheme is obviously imaginary, it
would theoretically constitute a reasonable fuel switch, resulting in only
minimal economic dislocation. The switch would accomplish clean fuel savings
for low sulfur oils and natural gas. Table F-3 shows that, with regard to
particulate emissions in three of the regions, impact of the fuel switch is
less thafl that which would be caused by all fuel burning sources in the
region emitting at the ceiling rate of the emission regulation (Table F-l).
In other words, while the suggested fuel switch of Table F-3 would result
in violations of the particulate emission regulations for the emission
sources switched, the overall impact of this switch is diminished by the
degree of over-compliance of other combustion sources (wood, oil) non-affected
by the switch. On the basis of the preliminary findings of Table F-3, it
would appear that the reasonable fuel switch outlined here could be accom-
plished with only minor impact on the attainment of secondary standards
for particulates in all regions except possibly the Eastern Idaho AQCR.
Table F-3 shows that for the case of the Eastern Idaho AQCR, the clean fuel
savings scheme would result in a regionwide particulate emissions increase
of 3,356 tons/yr, far in excess of the aggregate emissions increase allowable
under the ceiling rate of the emission regulations. This increase in
particulate emissions would undoubtedly jeopardize the attainment of air
quality standards in the urban areas of the Eastern Idaho AQCR.
The impact of the fuel switch (Table F-3) on S02 emissions in the various
AQCRs is less than that which would result if all fuel burning sources in the
region emitted at the ceiling rate of the emission regulations (Table F-2).
If the fuel switch were implemented, violations of the emission regulations
for S02 would occur for all fuel combustion sources presently burning resi-
dual oil or gas. These violations occur because of the conversion to a fuel
oil with sulfur content of 2%, higher than the lower sulfur fuels now
available to the State of Idaho, and slightly higher than the fuel oil sulfur
content needed to meet the emission regulation in the various regions. The
24
-------
net increase of S02 emissions caused by the fuel switch is probably less than
the S02 emission tolerance in each of the regions except possibly the
limited portion of the Eastern Idaho and Eastern Washington-Northern Idaho
AQCRs in the vicinity of the S02 hot spots. Hence, it appears that the
fuel switch can be accomplished without jeopardizing air quality attainment
goals in practically all of the State of Idaho.
-------
APPENDIX A
Tables of this appendix provide a summary of original and modified
state implementation plan information, including original priority classi-
fications, attainment dates, ambient air quality standards, and fuel
combustion emission regulations. 1973 SAROAD data for SCL and particulate
monitoring stations are summarized for the various AQCRs in the state. NEDS
emissions data are tabulated for the various fuel burning categories in each
of the AQCRs.
Tables A-10 and A-ll show a comparison of emission inventories in the
original SIP and those from the NEDS. The tolerance a region possesses for
measuring emissions without violation of national secondary ambient air
quality standards is calculated for S02 and particulates. The intent of
this calculation is to indicate candidate regions for clean fuel savings.
The tolerance estimate was based on either the degree of control expected
by the SIP or upon air quality/emission relationships which are calculated
from the more recent NEDS and SAROAD data (see Section 2.2.4). The value of
the emission tolerance provides an indication of the degree of potential an
AQCR possesses for clean fuel savings and regulation relaxation.
A-l
-------
EASTERN
WASHINGTON
NORTHERN
IDAHO
INTERSTATE
METROPOLITAN
BOISE
INTRASTATE
IDAHO .
HNTRASTATE
EASTERN
IDAHO
INTRASTATE
Figure A-l. Air Quality Control
Regions in Idaho
A-2
-------
Table A-l. Idaho Air Pollution Control Areas
Air Quality Control Region
Eastern Idaho (#61)
Eastern Washington-
Northern Idaho
Interstate (#62)
Idaho (#63)
Metropolitan Boise (#64)
Priority Classification
Parti cul ate
I
I
I
II
S0x
IA
IA
III
III
NOX
III
III
III
III
Proposed AQMA Designations
TSP Counties
None
11
ll
SO Counties
None
II
tl
H
co
Criteria Based on Maximum measured (or estimated pollution concentration in area) as shown below:
Priority
' Sulfur oxide:
Annual arithmatic mean..
Participate matter:
Annual geometric mean...
24-hour maximum. ........
Nitrogen dioxide
I
Greater than
100
445
S5
325
no
II
From-To
60-100
260-455
60- 95
150-325
III
Less than
60
260
60
150
no
Federal Register, August 1974 SMSA's showing potential for KAAQS violations due to growth.
-------
Table A-2. Regional Summary Information
Air Quality Control Region
Eastern Idaho (#61)
Eastern Washington-
Northern Idaho
Interstate (#'62),
Idaho Portion
Idaho (#63)
Metropolitan Boise (#64)
Number of
Counties
14
5
23
2
Area
(Square Miles)
18,852
6,580
55,555
1,621
1970
Population
201,179
116,554
221 ,586
173,518
Population Density
(Per square mile)
10.7
17.7
4.0
107
*Source: Newspaper Enterprise Association, World Almanac, 1973.
-------
Table A-3. Air Quality Attainment Dates
AQCR Name
Eastern Idaho (#61)
Eastern Washington-Northern
Idaho (#62)
Idaho (#63)
Metropolitan Boise (#64)
Participates
Attainment Dates
Primary
7/75
7/75
7/75
7/75
Secondary
b
b
b
b
Sulfur Dioxide
Attainment Dates
7/75
7/77c
a
a
Nitroaen Ox Idee
Attainment Dates
a
a
a
a
in
Air quality levels are currently meeting federal air quality standards
Attainment dates cannot be ascertained until studies can be performed to:
1) develop reliable emissions estimates of the fugitive dust sources believed
to be contributing significantly to the particulate air quality problem, and
2) determine the degree of emission reduction attainable from the control
strategy for fugitive dust control.
Attainment of federal air standards for SC>2 cannot be attained solely by application
of reasonable available technology in this region. Attainment will therefore be
delayed until improved technology is available.
-------
Table A-4. Federal and State Ambient Air Quality Standards
I,
en
All Concentrations in Mgms/m
Total Suspended Particulate Sulfur Dioxide
Annual 24-Hour
Federal Primary
Secondary
State Primary
Secondary
75
60
75
60
[G] 260a
[G] 150a
[G] 260a
[G] 150a
Annual 24-Hour 3-Hour
80 [A] 365a
1300a
80 [A] 365a
1300a
a Not to be exceeded more than once per year
[A] Arithmetic mean
[G] Geometric mean
-------
Table A-5. Summary of 1973 Air Quality Status for Suspended Particulates'
AQCR Name:
Eastern Idaho (161)
Eastern Washington-
Northern Idaho (162),
Idaho Portion
Idaho (163)
Metropolitan Boise (164)
I Of
Stations Reporting
7
8
3
7
TSP Concentration (ug/m )
Highest
2nd
Highest Reading
Annual
85
140
126
24 hr
656
558
508
452
Highest
jteading
452
497
390
363
Number of Stations Exceeding
Ambient Air Quality Standards
Primary Secondary
Annual
1
3
0
4
24 hr1
5
5
2
4
Annual
1
4
-
4
24 hr5
6
7
2
7
Emission
Reductions
Required to
: Meet Secondary
Standardsc
^nflual 24-hr
45.5% 71.3*
72.7% 74.3%
66. 7X
68.8% 64.0%
1. Blank (-) indicates value is indeterminate due to absence of air quality data.
Compiled from 1973 air quality data in National Air Data Systems as of July 7, 1974.
Violations are based on readings which exceed the value of the NAAQS after the first time.
Deduction required = jJEf x 100. Where A = 2nd highest measured air quality for period of standard
B = background concentration (30 jjg/m3 was assumed as a representative
value for all four AQCRs. An ongoing research program being
conducted by the State, will provide more accurate estimates for
background levels)
C = the concentration value of the standard.
-------
Table A-6. Summary of 1973 Air Quality Status for S02°
AQCR Name
Eastern Idaho (#51)
Eastern Washington-
Northern Idaho (#62),
Idaho Portion
Idaho (#63)
Metropolitan Boise (#64)
1
Stations
Reporting
24-Hr.
(Bubbler)
0
4
0
0
1
Stations
Reporting
(Conttn.)
0
4
0
0
SO- Concentration
wg/m3
Highest Reach
Annual
40
--
1st
24-Hr.
1498
np
2nd
Highest
24-Hr.
--
1248
.
--
# Stations Exceeding
Ambient Air Quality Stds..
Primary
Annual
-
_
-
- :
24-Hr?
-
4
-
-
Secondary
3-Hrb
-
4
-
-
Emission Reduction
Required to Meet
24-Hour Standard0
d
71%
d
d
1. Blanks (-) indicate value is indeterminate due to absence of air quality data. However, for the Idaho and
Metropolitan Boise AQCRs, the plan indicates that air quality is in substantial compliance with the federal
air standards for S02-
Compiled from 1973 air quality data in National Air Data System as of June 7, 1974.
Violations are based on readings which exceed the value of the NAAQS after the first time.
% reduction required =
x 100. Where A = 2nd highest measured air quality for period of standard.
C = the concentration value of the standard.
n. .
Air quality presently in attainment with standards (no emission reductions are necessary).
-------
Table A-7. Fuel Combustion Source Summary
AQCR Name
Number of Power Plants'
Number of Industrial or Commercial
Point Sources9 for
Particulates
SO,
vo
Eastern Idaho (#61)
Eastern Washington
Northern Idaho
Interstate (#62)
Idaho Portion
Idaho (#63)
Metropolitan Boise
(#64)
0
0
1
0
6
10
14
2
5
9
14
1
This represents the total number of combustion point sources inventoried in the NEDS 1973 Rank-Order Source
Summary. Only emission sources of 1 ton/year or greater are reported.
-------
Table A-8. Fuel Combustion Emissions Summary for 1973, Particulatesc
AQCR
Eastern Idaho
(#61)
Eastern
Washington-
Northern
Idaho (#62),
Idaho Portion
Idaho' (#63)
Metro pol itan
Boise (#64) '
^Total
10J Tons/Year
17.5
12.5
25.0
6.2
'*
Total from
Fuel Combustion
(103 Tons/Year)
1.6
7.6
6.6
1.1
Percent
Fuel Combustion
9.3%
60.. 8%
26.4%
17.8%
Electricity Ger
1CM Tons/Year
0
0 -
0
0
eration
%
0%
0%
0%
0%
Indust-Commercial
Fuel CciTib'jstior, .
"I CM Tons/Yr
.8
7.0
5.5
.6
4.7%
56.0%
22.0%
9.7%
Ar;:: 5-C'jrce
r ''_:;" If'L'. TClCri
10^ Tc.'s/Yr
.8
.6
1.1
.5
4.6%
4.8%
4.4%
8.1%
o.
L'mission figures were extracted from ilEDS, "1972 ,'lational Emissions Report."
-------
Table A-9. Fuel Combustion Emissions Summary for 1973,
AQCR
Eastern
Idaho (#61)
Eastern
Washington-
Northern
Idaho (#62),
Idaho Portion
Idaho (#63)
Metropolitan
Boise (#64)
103 Tons/Year
18.4
34.7
4.3
2.5
Total from
Fuel Combustion
(103 Tons/Year)
2.2
3.5
3.1
2.0
Percent
Fuel Combustion
12.1%
10.1%
72.1%
80.0%
Electricity Generation
103 Tons/Year
0
0
0
0
%
Q%
0%
0%
0%
Indust-Commercial
Fuel Combustion
m* Tons/Yr
.9
.5
1.5
.9
%
5.0!!
1.43
34. 93
36.03
Area Source
Fuel Combustion
1QJ Tors/Yr
1.3
3.0
1.6
1.1
>
A>
7. IX
8.7%
37.2%
44 %
S02 emission figures were extracted from NEDS, "1972 National Emissions Report."
-------
Table A-10. Assessment of Emission Tolerance, Participates
rv>
Baseyear and Forecasted Information from State Implementation Plan
AQCR
Eastern Idaho (#61)
Eastern Washington-
northern Idaho
Interstate (#62),
Idaho portion
Idaho (#63)
Metropolitan
Boise (*64)
Level of
Air Quality
Selected
Value for
SIP,
(ug/m3)
154
(Annual )
104
(Annual)
109
{Annual )
99
(Annual )
Emission
Reduction
Required
for
Based on
Selected
Values
765S
60S
62%
61*
Region-wide
Baseyear
1970
Total
Particulate
(10 tons/yr)
8.9C
16. Oc
32. Oc
3.1C
Allowable
Region-wide
Emissions
. (Total
Particulates)
for
Attainment
(1CT tons/yr)
Indeterminate
Indeterminate
Indeterminate
Indeterminate
3Refers to the highest 2nd high 24 hour average value in region, or to hi
.quality relative to the air standard). See Table A-4 for definition of
cflir quality data is for the year of 1973 for SAROAD. Emissions data wa
contribute to only
more study is need
federal air standa
Adjustments for gr
a portion of the measured particulate
levels. Fugit
rds.
Dwth were not considered in the forecasted projections
Region-wide
Emissions
(Total
Particulates)
Under SIP
In 1975
(10J tons/yr)
4.7c'd
6.?-"
13.6c'd
1.4c'd
Comments on Control Strategy
and Area of Greatest Impact
Selective control of two largest point sources (Simplot
Fertilizer and FMC Phosphorous Plant) will reduce emis-
sions in the area of worst air quality (Pocatello). The
overall control strategy, including state regulations
for other large sources, will reduce known regional
emissions by 47?-, and a control program has recently
been adopted in the Implementation Plan to mitigate
the significant effect of fugitive dust emissions on
hioh ambient particulate levels in the urban hot spots
of this region. Additional controls which may be
needed for attainment will be formulated under the
orovisions for ongoing studies outlined in the
implementation Plan.
Selective control of two largest point sources (Bunker
Hill Smelters, Potlatch Forests Pulp Mill) will reduce
quality (Kellogg & Lewiston). The overall control
strategy, including state regulations for other
sources, will reduce known regional emissions by 601
Implementation Plan to mitigate the significant effect
levels in the urban hot spots of this region. Addi-
outlined in the Implementation Plan.
Control of slack burning and replacement of conical burn-
ers with improved technology will provide most substan-
tial reduction in area of worst air quality (Twin Falls)
The overall control strategy will achieve a 58°- reductio
of known regional emissions, and a control program has
recently been adopted in the Implementation Plan to miti
this region. Additional controls which may be needed fo
going studies outlined in the Implementation Plan.
Fuel combustion and process controls provide the most
significant reductions of emissions anticipated in the
area of worst air quality (Boise-Nampa-Caldwell). The
overall control strategy will achieve a 55< reduction of
recently teen adooted in the Implementation Plan to miti
gate the sionificant effect of fugitive dust emissions o
attainment will be formulated under the provisions for o
going studies outlined in the Iniplementation Plan.
ghest annual value measured in the region {whichever constitutes the wor
s available from NEDS for the year 1972.
evel of
Quality
In 1925
(ug/m3)
452
(24 hr)
497
(24 hr)
390
(24 hr)
126
(Annual )
st air
ve dust is believed to contribute substantially to ambient particulate evels, but
s the adequacy of the complete control strategy proposed for attainment of the
Reduction
Requi red
Attainment
72J
If'.
67;,
i
1
Region-wide
(Total
Particulates)
(1CH tons/yr)
17. 5C
12.5°
25. Oc
j
6.2C
i
i
i
From SAPOAD and HEDSe
Region-wide
Allowable
Emissions
(Total
(10* tons/yrj
Indeterminate
Indeterminate
Indeterminate
Indeterminate
AQCR for Total Particulates
None indicated in vicinity of
areas of worst air quality.
However it appears that sub-
stantial emission tolerance ma
exist in areas removed from
pollution of hot spots. These
"clean" rural areas comprise a
significant portion of the geo-
graphic area of the State.
Same as above.
Sane as above.
None indicated throughout the
region.
-------
Table A-ll. Assessment of Emission Tolerance for SO,
AQCR
Eastern Idaho (#61)
Eastern Washington-
Northern Idaho-
Interstate (#62),
Idaho portion
Idaho (#63)
Metropolitan
Boise (#64)
Baseyear and Forecasted Information from Hate Imlewntation Plan
Level of
Air Quality
Selected
As Control
Value for
SIP .
(ug/m3)
93C
26609
Not
available1
Not
avail ab>e
Reduction
Required
for
Attainment
Based on
Selected
Values
36*
85£
Q%
OS
Region-wide
Baseyear
Emissions
1CT tons/yr)
85. 9h
Allowable
Re 5 ion- wide
Emissions
for
Attainment3
(103 tons/yr)
12.9
Indeterminate
Indeterminate
Region-wide
Emissions
Forecasted
for AQCR
Under SIP
for 1975
(10J tons/yr)
21.3
Not
Not
available
Comnents on Control Strategy
SG*2 emissions by 45'* in the
(Pocatello). The other hot
spot (Becker Industries in
Conda) will also be controlled
Selective control of the pri-
mary S0£ emission source
(Bunker Hill Smelters, re-
presenting 99* of all S02
air quality) by application
.of reasonable available tech-
nology and plant operational
chanaes may enable ambient
air standards for SO? to be
met. Emissions of S0;> in
are not significant.
Limitations on sulfur con-
maintenance of air quality
standards for SO^ in this
reel on.
Limitations on sulfur con-
tent i'n fuels will insure
standards for SO- in this
Air flualitv and Emissions Data fror S/^POAn and tlEOSe
Level of
Quality
In 1975
(ug/m3)
Not
12^3
(24 hr)
Not 1
avai lable
Not j
available
Emission
Required
for
Attainment
Indeter-
71 i
Oi
0\
Emissions
.In 1972
(ICr tons/yr)
18.4
34.7
4.3
2.5
Region-wide
Allowable
Emissions*
(103 tons/yr)
Indeterminatef
10.1
Indeterminatef
Indeterminate"
Summary of Emission Tolerance
of AQCR for S026
NR. No emissions tolerance in area of
worst air quality (Pocatello). Mow-
ever tolerance is probably substantial
in all other areas of region (where
emissions of SO, are relatively
insignificant. c
R. No emissions tolerance In vicinity
of worst air quality (Kellogg). Toler-
ance is probably substantial In all
other areas of region (where emissions
of 502 are relatively insignificant).
NR. Not quantifiable because of absence
of air quality data. Emission tolerance
is probably substantial in view of
relatively insignificant emissions of
S02 in this region.
I1R. Same as above.
aAllowable emissions for attainment of secondary standards are computed by assuming that applicable emissions contribute proportionately to tne air quality
at the site reporting the worst air quality readings. The alienable level is calculated using the reduction (or increase) fror the worst air quality
led by a judgment of the degree of reconciliation between the SIP information
.reading which corresponds to attainment of the federal air quality standards.
The basis for assessing a region's tolerance for emission increas is determim
ng a regi
and the 1973 UEDS/SAROAD data.
If the allowable emissions determ
calculated from 1973 air quality and etrission data, the forecasts
difference between allowable emissions and those emissions foreca
cult, it is assumed that the SIP may be based on untenable around
emissions relationship. Hence, the emissions tolerance is tabula
(based on 1973 air quality/emissions data). In this case the emi
ned after the SIP development is in accord (within 20°t) with the allowable emissions
of the SIP are considered valid, and emiss
can be computed by taking the
t for 1975. However, in the case where reconciliation of the two data sources is diffi-
, and that the more current flEOS/SAROAD data is a more valid indicator of the air quality/
ed for either the year 1975 (based on forecast of the Implementation Plan), or for 1973
sion tolerance expected in 1975 can only be rouohly estimated based on the 1973 air quality
quality-emissions status. Note: NR indicates "not reconcilable," and R indicates"reconcilable".
C6ased on diffusion modeling estimates for the area containing the primary S02 emission sources.
^Refers to highest 2nd high 24 hour average value in region, or to highest annual value measured in the region (whichever constitutes the worst air
quality relative to the air standard). See Table A-4 for definition"of federal air quality standard violations.
eAir quality data is for the year of 1973 from SAROAD. Emissions data was available from KEOS for the year 1972.
^Indeterminate due to absence of air quality data.
9Based on continuous monitors located in vicinity (Bunker Hill) of worst air quality in Kellogg.
hThese are emissions arising from activities of Bunker Hill plants, and comprise all but approximately H of the SO? emissions affecting the air guality in
the region.
Mir Quality known to be in compliance with ambient air quality standards for S02.
-------
Table A-12. Fuel Combustion Emission Regulations in Oregon
Governing Authority
Applicable Region
S0? Emission Regulations
Compliance
Date
TSP Emission
Regulations
Compliance
Date
Idaho Department
of Health
All AQCRs in Idaho
Sulfur content limitation in fuels
1.75 % S residual oil
.3 % S distillate #1
.5 % S distillate #2
KO % S coal Jan. 1973
Jan. 1974
Jan. 1973
Jan. 1973
See Figure A-2
April 1972
-------
3=-
I
CO
2:
o
CL
C
_I crt
ID "-)
O ff
h- CD
CK _
£ I
Q.
UJ
(
CD
I I
d =
§ a
-£ _T_T
^E o
V ^
^>» ^?
< rt
2 ^
I I I I I 11 I I I I I
L_l_l_JLLIll 1
= 0.20 -
0.10
50 100
50O !,OOO
0.!2
5POO £.000 3O.OCO
TOTAL HEAT INPUT (millions of BTUs./hr)
Figure A-2. Maximum Allowable Particulate Emissions for Fuel Combustion Equipment
-------
APPENDIX B
The purpose of Appendix B is to provide an assessment of the feasi-
bility for accomplishing clean fuel savings and regulation relaxation.
This assessment is carried out with an evaluation of various regional air
quality indicators developed in Section 2 and compiled in Appendix A.
The regional air quality indicators considered are comprised of criteria
shown in Table B-l and B-2, and include: (1) the breadth of air quality
violations, (2) expected attainment dates for NAAQS, (3) proposed AQMA
designations, (4) total regional emissions, (5) portion of emissions from
fuel combustion sources, and (6) regional tolerance for emissions increase.
When it is quantifiable and suitably applied, the emission tolerance
possibly provides the most important indicator, since it provides a mea-
sure of the over-cleanliness of the region, now or projected, and indi-
cates how much additional pollution (such as from dirtier fuels) can be
permitted without resulting in violations of federal air standards.
B-l
-------
Table B-1. Candidacy Assessment for Clean Fuel
Savings/Relaxation of Particulate Regulation
AQCR
Fraction
of Counties
in AQCR
with
Air Quality
Violations
in 1973
Expected
bAttainment
Date
Counties
with
AQMAs
Proposed
Total
Particulate
Emissions in
- AQCR (1973)
IP3 tons/yr.
% Emission
from Fuel
Combustion
Tolerance for
Particulate
Emissions
Increase
(Table A-10)
(103 tons/yr)
Overall
.. Regional
Evaluation
Eastern Idaho (#61)
Eastern-Washington-
Northern Idaho
Interstate (#62),
Idaho portion
Idaho (#63)
Metropolitan Boise
(#63)
2/14
3/5
1/23
2/2
None
17.5C
c
c
None
None
None
12.5a
25.03
6.2a
9.3% None in area of
worst air quality,
but substantial
tolerance in rest
of the region.
60.8% Same as above
26.4% Same as above
17.8% None
Marginal
Marginal
Marginal
Poor
Candidate
This includes only those emission sources known and inventoried at the time. Area model calculations indicate these
sources contribute to only a portion of the measured ambient particulate levels.
3It should be notedthat air monitoring stations do not exist in several of the counties. In most of these counties* air
quality is believed to be in compliance with federal air standards.
"Attainment dates are uncertain until new control strategies proposed by the state for control of fugitive dust may be
assessed.
A marginal rating has been assigned because the candidacy varies depending on the specific area within the region.
(Emissions, of particulates should not be increased in the hot spot areas, while it is feasible that emissions may be
increased in the remaining areas of the region.)
-------
Table B-2. Candidacy Assessment for: Clean Fuel
Savings/Relaxation of SC>2 Regulations
AQCR
Fraction
of Counties
in AQCR
with
Air Quality.
Violations
in 1973
Expected
Attainment
Date
Counties
with'
AOMAs
Proposed
Total S02
Emissions
in
AQCR(1973)
IP3 tons/yr.
% Emission
from Fuel
Combustion
Tolerance
for S02
Emissions
Increase
(Table A-10)
(103 tons/yr)
Overall
Regional
Evaluation
Eastern Idaho (#61)
Eastern Washington -
Northern Idaho Inter-
state (#62), Idaho
portion
Idaho (#63)
1/14C
1975
None
1/5
0/23
1977
Metropolitan Boise (#64) 0/2
None
None
None
18.4
34.7
4.3
2.5
12.1%
10.1%
72.1%
80.0%
None in area of Marginal
worst air quality, Candidate
but substantial
i tolerance through-
out rest of
region
Same as above
Marginal .
Candidate
Not quantifiable Good
but believed to Candidate
be appreciable
throughout region
Same as above.
Good
Candidate
aAir quality levels were within standards in 1973 and are expected to remain so through 1975.
It should be noted that air monitoring stations do not exist in several of the counties. However, in most counties where
air monitoring is not performed, it is believed that air qualitv there is in compliance with the federal air standards for
S02.
°No monitoring data was available to characterize ambient levels of S02 in 1973, but based on compliance scheduling, it
was believed that violations were still occurring in the vicinity of the Simplot Co. acid plants near Pocatello.
A marginal rating has been assigned because the candidacy varies depending on the specific area within the region.
(Emissions of S02 may be increased throughout the region, except in the area of the hot spot).
-------
APPENDIX C
This section provides a characterization of individual power plants by
AQCR. Current power plant information used to prepare Table C-l were obtained
from three main sources: (1) Federal Power Commission computerized listings '
of power plants and their associated fuel use, (2) the National Coal Associa-
tion "Stearn Tables" listing of power plants and fuel use in 1972, and (3)
emission data in the NEDS data bank as of 1974. 1973 fuel schedules were
extracted from the FPC (1 above) data, or when this was not available, 1972
fuel schedules were reported in Table C-l from values extracted from the .
Steam Tables. Heat inputs were calculated based on the fuel heating values
obtained from either (1) or (3) above. The SOg and particulates emissions
reported in Table C-l correspond to the fuel schedules reported, and were
extracted from (1) or (3) above. When emissions and fuel schedule figures
were not available for the same year, emissions were scaled proportionately
to reflect the 1973 fuel schedule.
Also shown in Table C-l are the 1975 regulations which are currently
applicable to the given plant, taken from Table A-12.
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-8, A-9). This is a result of both differ-
ing fuel schedules in 1973 compared to previous years and the relative "complete-
ness" of the NEDS data bank.
C-l
-------
Table C-l. Power Plant Characterization
County .
IDAHO AQCR (
-El more
Plant Name
P63):
Mountain Home
Air Force Base
Fuel Use
Type
% Sulfur
% Ash
Coal
0.6%S
4.1XA
Annual
Quantity
15000
Heat
Input
(106 etu/hr)
30.8
Emissions
S02
Existing | Allowable
tons/yr
104
lbs/10<
Btu
0.77
Jbs/10*
Btu
205
1.52
Parti culates
Existing I Allowable
tons/vr
83
bs/10*
Btu
0.62
tons/yr
62.1
lbs/10(
Btu
0.46
o
ro
Allowable emissions refers to the maximum emissions permitted by emission regulations.
NOTE:
Data was extracted from information in NEDS as of 1974, from Federal Power Commission tabulations of power plant fuel
use, and from the National Coal Association "Steam Tables." Calculation and conversion of units of emission rates
were facilitated by reference to "How to Convert Air Pollution Data with Seven Simple Curves," KVB Engineering, July
1974 issue of Electric Light and Power.
-------
APPENDIX D
This section provides a characterization of individual industrial/
commercial/institutional fuel combustion emission sources. The data was
derived from a NEDS rank order emissions listing, and from emissions data
in the NEDS data bank as of June 1974.
D-l
-------
Table D-l. Industrial-Commercial Fuel Combustion Point Source Characterization
County
Plant Name
EASTERN IDAHO AQCR (#61):
Bonneville
Butte
Caribou
Freemont
Power
Utah Idaho Sugar
U.S. Atomic
Energy Corran.
Monsanto
Wood Burning
Plants
FMC Corporation
JR Simplot
TOTALS
Fuel Use
Type
% Sulfur
% Ash
Coal
0.72%S
4. 5%A
Gas
R. Oil
1.7XS
D. Oil
0.42%S.
Gas
Wood
Gas
D. Oil
0.2%S
Annual .
Quantity
20000
2090
4488
117
72
34000
239
600
Heat
Input
(106 Btu/hr)
57.1
251
76.8
1.9
8.6
38.8
27.3
9.6
471.1
Emissions
S02
Existing | Allowable3
tons/yr
274
1
607
14
1
26
1
9
930
lbs/10f
Btu
1.10
1.80
1.68
0.15
0.21
5
tons/vr
380
2012
617
3.3
68.9
26
219
17.0
3343
Parti culates
Existing 1 Alloy/able3
lbs/106(
Btu ftons/vr
1.52
1.83
1.83
0.4
1.83
0.15
1.83
0.4
765
19
30
1
1
9
2
5
830
lbs/106.
Btu [tons/y
3.06
0.02
0.09
--
0.05
0.02
0.12
100
307
124
5.0
22.6
74.8
56.2
25.2
715
libs/10^
Btu
0.40
.0.28
0.37
0.6
0.6
0.44
0.47
0.6
-------
Table D-l. Industrial-Commercial Fuel Combustion Point Source Characterization
County
EASTERN WAS
Benewah
Kootenai
Latah
Nez Perce
-
Plant Name
Fuel Use
Type
% Sulfur
% Ash
Annual .
Quantity
Heat
Input
(106 Btu/hr)
Emissions
S02
Existing j Allowable3
bons/vr
4INGTON-NORTHERN IDAHO INTERSTATE (IDAHO PORTION) AQCR (#62):
Wood Burning
Plants
Burns Yaak Inc.
Wood Burning
Plants
Bennett Lbr.
Wood Burning
Plants
Potlatch Forests
-
Wood
Gas
Wood
D. Oil
0.2%S
Wood
Wood
Other
R. Oil
1.2%S
Gas
Wood
80000
155
329800
141
12400
73000
548000
3400
2405
862800
91.3
18.5
376
2.3
14.2
83.3
813
58
288
985
60
"1
2547
2
9
55
13
320
1
647
lbs/106
Btu (tons/yr
0.15
1.55
0.20
0.14
0.15
.01
1.26
0.15
60
148
2547
4.0
9
55
6517
467
2308
647
Parti culates
Existing
fibs/106. jlbs/10e
Btu ftons/vH Btu
0.15
1.83
1.55
0.4
0.14
0.15
1.83
1.83
1.83
0.15
385
1
247
1
85
674
404
39
22
4054"
0.96
0.01
0.15
1.37
1.84
0.11
0.15
0.17
0.94
Allowable a
tons/y
144
42
428
6.0
34
135
783
101
341
906"
ibs/lO^
Btu
0.36
0.52
0.26
0.6
0.55
0.37
0.22
0.40
0.27
0.21-
-------
Table D-l. Industrial-Commercial Fuel Combustion Point Source Characterization
County
Shoshone
IDAHO AQCR A
Idaho
Lemhi
Lewi s
Minidoka
Twi n Fal 1 s
Plant Name
Bunker Hill
TOTALS
OCR (#63):
Wood Burning
Plants
Wood Burning
Plants
Wood Burning
Plants
Amalgamated
Sugar
Amalgamated
Sugar
Fuel Use .
Type
% Sulfur
% Ash
Gas
Wood
Wood
Wood
Coal
0.72%S
8. 0%A
Coal
0.75XS .
8. 0%A
Annual
Quantity^
252
57800
6070
544800
42500
30350
Heat
Input
(106 Btu/hr)
30.2
2759.8
66.0
6.9
622
121
86.6
Emissions
S02
Existing | Allowable9
tons/yr
1
3653
44
5
408
581
432
lbs/10(
Btu
0.15
0.16
0.15
1.10
1.14
$
tons/_yr
242
13004
469
50.0
4352
807
577
Parti culates
Existing
Ibs/lO^
Btu ftons/v
1.83
1.6
1.6
1.6
1.52
1.52
1
5912
514
17
606
735
2341
Allowable3
lbs/10^
Btu }tons/y
0.01
1.78
0.56
0.22
1.39
6.17
60.8
2981
113
18.1
627
180
137
lbs/10(
Btu
0.46
0.39
0.6
0.23
0.34
0.36
-------
Table D-l. Industrial-Commercial Fuel Combustion Point Source Characterization
County
Valley
Boise
Bonner
Boundry
Clearwater
Plant Name
Wood Burning
Plants
Wood Burning
Plants
Louisiana
Paci f i c
Merritt Brothers
Wood Burning
Plants
Wood Burning
Plants
Potlatch Forest
Potlatch Corp.
Fuel Use
Type
% Sulfur
% Ash
Wood
Wood
Gas
D. Oil
0.2%S
Wood -
Wood
Gas
Wood
R. Oil
1.2XS
Wood
Annual
Quantity"3
36500
37500
176
1500
44000
524000
268
354000
740
152000
Heat
Input
(106 Btu/hr)
62.5
42.8
21.0
25.7
50.2
598
32.1
404
12.7
174
Emissions
S02
Existing
tons/y_r
28
28
1
21
33
393
1
266
70
114
Allowable3
!bs/106
Btu fcons/vr
0.10
0.15
0.19
0.15
0.15
0.15
1.26
0.15
448
28
168
42.6
352
393
257
266
101
114
Btu
1.6
0.15
1.83
0.4
1.6
0.15
1.83
0.15
1.83
0.15
Particulates
Existing
fbs/lO6
^ons/yji_Btu
90
15
2
11
65
468
1
1114
3
732
0.33
0.08
0.02
0.10
0.30
0.18
--
0.63
0.05
0.96
Allowable3
tons/y
107
80.6
46.0
54.0
90.1
602
64.7
442
31.7
236
ibs/106'
Btu
0.39
0.43
0.50
0.48
0.41
0.23
0.46
0.25
0.57
0.31
-------
Table D-l. Industrial-Commercial Fuel Combustion Point Source Characterization
I
County
Gen
METROPOLITAN
Canyon
Plant Name
Wood Burning
Plants
TOTALS
BOISE AQCR (#64):
JR Simplott
Amalgamated
Sugar Nampa
TOTALS
Fuel Use
Type
% Sulfur
% Ash
Wood
Gas
Coal "
0.72%S
8. 0%A
Gas
Annual
Quantity13
72000
2281
68500
v 16
Heat
Input
(106 Btu/hr)
123
2448.5
260
195
29.2
484.2
Emissions
S02
Existing | Allowable3
tons/yr
55
2478
1
937
1
937
lbs/10f
Btu
0.10
1.10
tons/vr
55
8480
2084
1301
234
3619
Parti culates
Existing I Allowable3
Ibs/lO6. jibs/10*
Btu ftons/vrl Btu
0.10
1.83
1.52
1.83
133
6846
21
681
1
702
0.25
0.02
0.08
tons/y^
178
3007
319
256
60.1
635
Ibs/iO6
Btu
0.33
0.28
0.30
0.47
I
CTi
Allowable Emissions refers to the maximum emissions permitted by emission regulations. For fuel burning equipment operating
on gas, the allowable emissions was considered to be those which would be permitted if the equipment used residual oil instead.
bOil - 103 gallons, Gas - TO3 MCF, Coal - 103 tons.
NOTES:
1. Data was extracted from information in NEDS as of 1974. Calculation and conversion of units of emission rates were facili-
tated by reference to "How to Convert Air Pollution Data with Seven Simple Curves." KVB Enaineerinq, July 1974 issue of
Electric Light and Power.
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APPENDIX E
Table E-l shows area source fuel use for the entire state of Oregon.
The approximate energy values are compared for each fuel along with the
percent of overall energy derived from each fuel. The bottom row entitled
"all fuels, all sources" may not match totals from Appendices A, C, and D,
exactly, since neither the NEDS or individual appendix totals are all-
inclusive. Also fuel schedules may change from one year to the next.
E-l
-------
Table E-l. Total State Area Fuel Usea, Idaho
Source
AREA SOURCES
Residential
Industrial
Commercial/
Institutiona
AREA SOURCES
Total
% By Fuel
AREA AND
POINT SOURCE!
Total Fuel
Use
% By Fuel
COAL
TO3 tons 109 Btu
94.3 2174
0 0
0 0
1
94.3 2174
2.8
270.7 6238
4.7
RESID. OIL
TO3 gal 109 Btu
0 0
0 0
5020 703
5020 703
0.9
13177 1845
1.4
DIST. OIL
103 gal 109 Btu
98170 13745
32350 4529
14000 1960
144520 20234
26.5
147070 20591
15.5
GAS
TO5 ft3 109 Btu
13160 13160
26530 26530
12950 12950
52640 52640
' 68.9
60847 60847
45.8
WOOD
103 tons 109 Btu
54.4 652
0 0
0 0
54.4 652
0.9
3617.1 43348
32.6
i
TOTAL
TO9 Btu
29731
31059
15613
76403
132869
m
i
a Fuel use figures are taken from data in NEDS data bank as of September 1974.
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APPENDIX F
The Tables F-l and F-2 illustrate the effect on emissions of particu-
lates and S02 when power plant and industrial fuel burning sources listed
in Appendices C and D are allowed to emit at the ceiling rate permitted
by emission regulations. It was assumed that heat input remains the same,
and existing regulations are applied to gross-heat input for each AQCR.
It is emphasized that this table is hypothetical in that no fuel mix may
exist to allow all sources to emit exactly at regulation levels. The
calculations do give some insight into adequacy of existing regulations
for allowing air quality standards to be achieved if a fuel schedule dif-
ferent from the one at present were in effect.
Table F-3 shows the impact of a feasible fuel switch to obtain clean
fuel savings in the State of Idaho. It was assumed that all gas burning
combustion equipment would be converted to burn high sulfur (2%S) residual
fuel oil, and that all use of residual fuel oil would be converted to the
high sulfur (2%S) type. Plants operating with both coal and gas were
assumed to be convertible to 100% coal use. The switch is assumed to occur
in 1975, after compliance with emission regulations has been attained (by
particulate emission controls and use of low sulfur fuels). For those
units which are converted for the fuel switch, it is assumed that no addi-
tional emission control equipment is installed. Hence, for all units con-
verted from gas only to fuel oil, there will undoubtedly be accompanying
emission regulation violations. Also, since it was assumed that S02 emis-
sion compliance is attained in 1975 through use of low sulfur fuels, con-
version of these fuels to higher sulfur (2%S) oil will also incur emission
regulation violations. While such a conversion scheme is obviously imag-
inary, it would theoretically constitute a reasonable fuel switch, result-
ing in only minimal economic dislocation. The switch would accomplish
clean fuel savings for low sulfur oils and natural gas.
F-l
-------
Table F-l. Assessment of Restrictiveness of Participate Emission Regulations for Fuel Burning
Equipment
AQCR
Eastern Idaho (#61)
Eastern Washington-
Northern Idaho
Interstate (#62),
Idaho portion
Idaho (#63)
Metropolitan
Boise (#64)
Fuel Burnina
Emissions, 1972a
103 tons/yr
.8
5.9
6.9
.7
Fuel Burninq
Emissions
Projected for
1975 b
103 tons/yr
.2
1.9
2.6
.3
1975 Fuel
Jurning Emissions
at Regulation
Limit RatesC
103 tons/vr
.7
3.0
3.1
.6
Increase in 1975 Emissions in
HQCR When Fuel Burning Units
Emit at Regulation Limits
103 tons/yr
.5
1.1
.5
.3
Percentage of
Total Emission
Inventory
1973
2.9%
8.8%
2.0%
4.8%
Tolerance for
Particulate
Emissions Increase
in AQCR in 1975
103 tons/yr
None except in rural
areas of region
None except in rural
areas of region
None except in rural
areas of region
None throughout
region.
Assessment of Restrictiveness
of Fuel Burning Emission
Regulations^
Hot overly restrictive, except
possibly in rural areas.
n u ii it
it n n n
Not overly restrictive.
I
ro
Calculated as sum of point sources from Appendix C and D.
Projected fuel combustion emissions for 1975 were assumed to be the sum of those tabulated for point sources in Appendix C and D with the following
adjustment: Those sources which were out of compliance with emission regulations were assigned a 1975 level equivalent to source operation at the
emission regulation limit. Emissions from area sources (Appendix E) were neglected in the assessment as they were expected to remain constant.
Also, zero growth was assumed to apply to all point sources.
dTh:se emissions have been calculated as "allowable emissions" in Tables C-l and D-l.
The restrictiveness of the combustion emission regulations is judged by comparing the increase in 1975 fuel burning-emissions caused by operation at
regulation limits with the "emission tolerance" the AQCR is appraised to have (Table A-10). If the increase exceeds the emission tolerance, then
it is clear that the regulations are not overly restrictive. When the increase does not exceed the emission tolerance, the regulations may be
relaxed to allow higher emission rates without interfering with the attainment of federal air standards. When no emission tolerance has been
determined, a qualitative assessment of the regulations is included.
-------
Table F-2. Assessment of Restrict!veness of S02 Emission Regulations for Fuel Burning Equipment
AQCR
Eastern Idaho
(#61)
Eastern Washing-
ton-Northern
Idaho Inter-
state (#62),
Idaho portion
Idaho ##63)
Metropolitan
Boise (#64)
Fuel Burning
Emissions, 1972a
TO3 tons/yr
.9
3.7
2.6
.9
Fuel Burning
Emissions
Projected.for
1975b
103 tons/yr
.9
3.7
2.6
.9
1975 Fuel
Burning Emissions
at Regulation
Limit Rates0
103 tons/vr
3.3
13.0
8.7
3.6
Increase in 1975 Emissions in
AQCR When Fuel Burning Units
Emit at Regulation Limits
Percentage of
- Total Emission
10 Inventory
tons/yr 1973 "
2.4 13.1%
9.3 26.8%
6.1 142 %
2.7 108 %
Tolerance for
Particulate
Emissions Increase
in AQCR in 197b
103 tons/yr
Probably substan-
tial in all areas
except near hot
spot (Pocatello
and Conda)
Probably substan-
tial in all areas
except near hot
spot (Kellogg)
Probably substan-
tial throughout
region
Probably substan-
tial throughout
reaion.
Assessment of
Restricti veness
of Fuel Burning
Emission H
Requlations"
Probably overly
restrictive ex-
cept in area of
hot spots.6
Probably overly
restrictive ex-
cept in area of
hot spot.6 |
Probably overly
restrictive.6
Probably overly
restrictive.6
I
CO
Calculated as sum of point sources from Appendix C and D.
Projected fuel combustion emissions for 1975 were assumed to be the sum of those tabulated for point sources in Appendix C and D
with the following adjustment: Those sources which were out of compliance with emission regulations were assigned a 1975 level
equivalent to source operation at the emission regulation limit. Emissions from area sources (Appendix E) were neglected in the
assessment as they were expected to remain constant. Also, zero growth was assumed to apply to all point sources.
cThese emissions have been calculated as "allowable emissions" in Tables C-l and D-l.
dThe restrictiveness of the combustion emission regulations is judged by comparing the increase in 1975 fuel burning emissions
caused by operation at regulation limits with the "emission tolerance" the AQCR is appraised to have (Table A-10). If the
increase exceeds the emission tolerance, then it is clear that the regulations are not overly restrictive. When the increase
does not exceed the emission tolerance, the regulations may be relaxed to allow higher emission rates without interfering with
the attainment of federal air standards. When no emissions tolerance has been determined quantitatively, a qualitative assess-
ment of the regulations is included above.
6Fuel combustion operations are presently emitting SO, well below the ceilino permitted by regulations. In raising these
emisions to ?he regulation limit (by the use of hioner sulfur fuels), substantia increases of S02 would be re eased to
the atmosphere Based on the assumption that atmospheric levels of S02 are very low in all areas except the hot spots, it
appear that these increases may be tolerated without jeopardizing maintenance of air ouality standards in the clean
areas.
-------
Table F-3. Fuel Switch Evaluation
AQCR
Eastern Id«ho
(f«l)
Total
E«ttm »ash-
tng ton-North* r
*rn Idaho
Interstate
(162) Idaho
wtlon
Total
Idaho (*63)
Total
Metropolitan
Boise (164)
Total
Source Category
Industrial and
Commercial
Industrial and
Conerclal.
Industrial and
Commercial
Power Plant
Industrial and
Commercial
Fuel
Type
Coal
011
Gas
Wood
on
Gas
Wood
Other
Coal
011
Gas
Wood
Coal
Coal .
Gas
Projected Usage In 1975b
Heat Input Emissions (Tons/Yr)
Quantity3 10°Btu/Hr TSP SO?
20000 57.1 765 274
5205 88.3 35 619
2401 286 21 1
34000 38.8 9 26
470.2 830 919
3541 60.3 39 322
2812 337 24 1
1358000 1550 1466 3318
548000 813 404 13
2760.3 1933 3653
72850 207 3076 1013
2240 38.4 14 91
444 53.1 2 1
1828670 2149 2120 1205
15000 30.8 83 104
2478.3 5295 2413
68500 195 681 937
2297 289 21 1
484 702 937
Gas and Oil Switch to Coal
luantity. Heat Input Resulting Em1s. Incr.
Switched 106 Btu/Hr TSP S02
2090 251 3343 1204
3343 1204
16 29.2 102 140
102 1204
Gas and Oil Switch to 2% S Oil
Quantity Heat Input Resulting Emis.Incr.c
Switched 106 Btu/Hr TSP SO,
5205 88.3 0 - 198
311 35.9 13.2 403
13.2 601
3541 60.3 0 221
2812 337 203 3099
203 3320
2240 38.4 0 131
444 53.1 10.5 488
619
2281 260 40 2388
40 2388
Tons/Yr
Emission Increase
in AQCR Due to
Fuel Switch
TSP «i-
0 157
3356 1607
3356 1764
0 221
203 3099
203 3320
0 131
10.5 488
10.5 619
142 2528
142 2528
"Quantity 1s 1n units as follows: Oil - 103 gallons, gas - 109 CF. Coal - 103 tons.
^he projected usage for fuel burning sources 1n 1975 are the same as in those tabulated in Appendix C, and D. Growth was assumed to be non-increasing,
based on non-enploynent trends in the State.
°The missions Increase due to the fuel switch is calculated by comparing the projected compliance emissions in 1975 for a given fuel type with those that
occur when fuel switches are made (calculated by utilization of emission factors from EPA Document AP-42).
-------
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. SAROAD Data Bank, 1973 Information U.S. EPA.
4. "Steam-Electric Plant Factors/1972," 22nd Edition National Coal
Association.
5. "Federal Air Quality Control Regions," U.S. EPA, Pub. No. AP-102.
6. Federal Power Commission, U.S. Power Plant Statistics stored in EPA
Data Bank, September 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. "How to Convert Air Pollution Data with Seven Simple Curves," KVB
Engineering, Electric Light and Power, July 1974.
10. "State of Idaho Clean Air Act Implementation Plan," Department of
Environmental and Community Services, January 1972.
11. "Attainment of Ambient Particulate Matter Standards in Idaho,"
Charles Findley and David Bray, Region X, U.S. EPA, November 1973.
-------
TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1. REPORT NO.
EPA-450/3-75-011
2.
3. RECIPIENT'S ACCESSION-NO.
4. TITLE AND SUBTITLE
Implementation Plan Review for Idaho as
Required by the Energy Supply and Environmental
Coordination Act.
5. REPORT DATE
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 X, Seattle, Washington,
and TRW, Inc. Redondo Beach, California.
11. CONTRACT/GRANT NO.
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
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 interferring 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)
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