-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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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, ------- 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. ------- 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. ------- 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? ------- 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. ------- 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 ------- 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. 9 ------- 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 ------- 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 11 ------- 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 12 ------- 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. 13 ------- 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. 14 ------- 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. ------- 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. ------- 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) ------- |