EPA-450/3-75-012
MARCH 1975
IMPLEMENTATION PLAN REVIEW
FOR
OREGON
AS REQUIRED
BY
THE ENERGY SUPPLY
AND
ENVIRONMENTAL COORDINATION ACT
U. S. ENVIRONMENTAL PROTECTION AGENCY
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EPA-450/3-75-012
IMPLEMENTATION PLAN REVIEW
FOR
OREGON
REQUIRED BY THE ENERGY SUPPLY AND ENVIRONMENTAL COORDINATION ACT
PREPARED BY THE FOLLOWING TASK FORCE:
U. S. Environmental Protection Agency, Region X
1200 6th Avenue
Seattle, Washington 98101
Environmental Services of TRW, Inc.
(Contract 68-02-1385)
U. S. Environmental Protection Agency
Office of Air and Waste Management
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
March 1975
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TABLE OF CONTENTS
Page
1.0 EXECUTIVE SUMMARY 1
2.0 STATE IMPLEMENTATION PLAN REVIEW 7
2.1 Air Quality Setting - State of Oregon 9
2.1.1 Air Quality Control Regions 9
2.1.2 Ambient Air Quality Standards 10
2.1.3 Air Quality Status 10
2.1.4 Emissions Summary 11
2.2 Background on the Development of the State Implementation
Plan 13
2.2.1 General 13
2.2.2 Particulate Control Strategy 14
2.2.3 Sulfur Oxide Control Strategy 16
2.2.4 Emission Tolerance Evaluation 18
2.2.5 Fuel Combustion Emission Regulations Summary .... 20
2.3 Special Considerations 21
2.3.1 Planned Revisions to the Implementation Plan .... 21
2.3.2 Special Problems 22
2.3.3 Fuels and Anticipated Fuel Conversions 22
3.0 AQCR ASSESSMENTS 24
3.1 Assessment of Clean Fuel Savings Potential by Regional Air
Quality Indicators 25
3.2 Assessment of Clean Fuel Savings Potential by Source
Analysis of Power Plants/Industrial-Commercial/Area Sources. 26
3.3 Assessment of Restrictiveness of Fuel Combustion Emission
Regulations 28
3.4 Assessment of the Impact of Probable Fuel Switches 34
TECHNICAL APPENDICES
APPENDIX A - State Implementation Plan Background A-l
APPENDIX B - Regional Air Quality Assessment B-l
APPENDIX C - Power Plant Assessment C-l
APPENDIX D - Industrial, Commercial, Institutional Source
Assessment D-l
APPENDIX E - Area Source Assessment E-l
APPENDIX F - Other Analyses F-l
iii
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1.0 EXECUTIVE SUMMARY
i
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 submitted to
EPA by the States. The States may, as in the Clean Air Act of 1970, initiate
State Implementation Plan revisions; ESECA does not, however, require States
to change any existing plan.
Congress has intended that this report provide the State with infor-
mation on excessively restrictive control regulations. The intent of ESECA
is that SIP's, wherever possible, be revised in the interest of conserving
low sulfur fuels or converting sources which burn oil or natural gas to coal.
EPA's objective in carrying out the SIP reviews, therefore, has been to try
to establish if emissions from combustion sources may be increased. Where
an indication can be found that emissions from certain fuel burning sources
can be increased and still attain and maintain NAAQS, it may be plausible
that fuel resource allocations can be altered for "clean fuel savings" in a
manner consistent with both environmental and national energy needs.
In many respects, the ESECA SIP reviews parallels EPA's policy on clean
fuels. The Clean Fuels Policy has consisted of reviewing implementation plans
with regards to saving low sulfur fuels and, where the primary sulfur dioxide
air quality standards were not exceeded, to encourage States to either defer
compliance regulations or to revise the SOp emission regulations. The States
have also been asked to discourage large scale shifts from coal to oil where
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this could be done without jeopardizing the attainment and maintenance
of the NAAQS.
To date, EPA's fuels policy has addressed only those States with
the largest clean fuels saving potential. Several of these States have or
are currently in the process of revising SCL regulations. These States are
generally in the Eastern half of the United States. ESECA, however, extends
the analysis of potentially over-restrictive regulations to all 55 States and
territories. In addition, the current reviews address the attainment and
maintenance of 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 Implementation
Plans. These are: 1) the use of the example region approach in developing
State-wide air quality control strategies; 2) the existence of State Air
Quality Standards which are more stringent than NAAQS; and 3) the "hot
spots" in only part of an Air Quality Control Pxegion (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 instances conflict with current
national energy concerns, a review of the State Implementation Plans is a
logical follow-up to EPA's initial appraisal of the SIP's conducted in 1972.
At that time SIP's were approved by EPA if they demonstrated the attainment
of NAAQS or more stringent state air quality standards. Also, at that time
an acceptable method for formulating control strategies was the use of an
example region for demonstrating the attainment of the standards.
The example region concept permitted a State to identify the most
polluted air quality control region and adopt control regulations which
would be adequate to attain the NAAQS in that region. In using an example
region, it was assumed that NAAQS would be attained in the other AQCR's of
the State if the control regulations were applied to similar sources. The
problem with the use of an example region is that it can result in excessive
controls, especially in the utilization of clean fuels, for areas of the
State where sources would not otherwise contribute to NAAQS violations. For
instance, a control strategy based on a particular region or source can
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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 most important for those
States which desire to submit a revised plan to recognize the review's
1 i mi tati ons . TheJMndi ngjij^J^ijs^ report are^j^
are neither intended _J!PJi,aj^iiatj_j,o be the, s_ple basis for SIP ravisjonsr;
anc* eff°rt 'in complying with
the ESECA requi rements . The time and resources which EPA has had to prepare
the reports has not permitted the consideration of growth, economics, and
control strategy tradeoffs. Also, there has been only limited dispersion
modeling data available by which to address individual point source emis-
sions. Where the modeling data for specific sources were found, however,
they were used in the analysis.
The data upon which the reports' findings are based is the most
currently available to the Federal Government. However, EPA believes that
the States possess the best information for developing revised plans. The
States have the most up-to-date air quality and emissions data, a better
feel for growth, and the fullest understanding for the complex problems
facing them in the attainment and maintenance of 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 overall 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 significant deterioration,
increased TSP, NO , and HC emissions which occur in fuel switching, and
/\
other potential air pollution problems such as sulfates.
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Although the enclosed analysis has attempted to address the attainment
of all the NAAQS, most of the review has focused on total suspended parti -
culate matter (TSP) and sulfur dioxide (S02) emissions. This is because
stationary fuel combustion sources constitute the greatest source of SOp
emissions and are a major source of TSP emissions.
Part of each State's review was organized to provide an analysis of
the SCL and TSP emission tolerance within each of the various AQCR's. The
regional emission tolerance estimate is, in many cases, EPA's only measure
of the "over-cleaning" accomplished by a SIP. The toleran.ce assessments
have been combined in Appendix B with other regional air quality "indicators"
in an attempt to provide an evaluation of a region's candidacy for changing
emission limitation regulations. In conjunction with the regional analysis,
a summary of the State's fuel combustion sources (power plants, industrial
sources."and area sources) has been carried out in Appendix C, D, and E.
The major findings evolving from the study are:
9 The review indicates that S02 emission regulations may be
revised in all the regions except the Northwest AQCR and the
Portland Interstate (Oregon portion) without jeopardizing
attainment and maintenance of NAAQS. For the Portland Inter-
state, it is probable that S02 emission regulations can be
revised in areas removed from the Portland Metro AQMA. The
review also indicates that present fuel burning practices
are in significant over-compliance with SCL emission regulations
(due to the use of natural gas and fuel oils with sulfur
content significantly below the allowable ceiling levels),
and that there is room to increase S02 emissions before
violating the emission regulations in each of the AQCRs.
Clean fuel savings policies which would result in permittable
increase in S02 emissions should be implemented with caution
in regions where attainment and maintenance problems exist for
particulate ambient air standards. Increased particulate
emissions, and increased levels of secondary particulates from
S02 precursors, resulting from use of higher sulfur fuels, would
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jeopardize maintenance or attainment problems for parti -
culate ambient air standards in the AQMAS of the Portland
Interstate and Southwest AQCRS, and in the area of worst
air quality in the Eastern AQCR. Therefore, policies which
would allow use of higher sulfur fuels would also necessitate
additional control equipment to counter the increased
particulate emissions.
Particulate emission regulations appear to be overly res-
trictive only in the Central AQCR. Air standards maintenance
and attainment problems in the Portland Interstate, Southwest,
and Eastern AQCRS indicate that fuel combustion emission
regulations should not be revised there, except possibly for
sources in cleaner portions of the regions removed from the
areas of worst air quality. Revision of particulate emission
regulations in the Northwest AQCR would only jeopardize main-
tenance of the federal air quality standards there.
Due to natural gas curtailments, and potential conversions
from wood burning, the use of fuel oils is expected to in-
crease dramatically in the State of Oregon in the next few
years. This fuel schedule change will hasten maintenance
problems for compliance with SCL air quality standards in the
Northwest AQCR, and the Portland Interstate AQCR, but is not
expected to conflict with clean air goals in other regions;
The impact on air quality of plausible fuel switches for
clean fuel savings in the State of Oregon would appear to
be relatively insignificant insofar as particulate emissions
increases are concerned. However, such fuel switches would
hasten air quality maintenance problems in all regions ex-
cept the Central and Northwest AQCRS. The review indicates
the impact of such fuel switches on SOp emissions would be
significant, and would probably jeopardize the maintenance
of SCu air quality standards in both the Portland Interstate
AQCR and the Northwest AQCR.
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Areas in which SCL or participate emission regulations may
be revised without jeopardizing attainment or maintenance
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 regulation 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 emission
regulations or interference with attainment of air quality
standards in all regions except the Portland Interstate and
Northwest AQCRS. The analysis also shows that by 1975,
particulate emissions may be increased significantly in the
Central and Northwest AQCRS, and probably in portions of
the Portland Interstate, Eastern, and Southwest AQCRS before
violating emissions regulations. Hence, potential clean fuel
savings programs which would result from fuel switches
causing increased emissions of particulates could be devised
to be compatible with both the emission regulations or the
ambient air quality standards in all regions (or in portions
of regions).
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2.0 STATE IMPLEMENTATION PLAN REVIEW
A revision of fuel combustion source emissions regulations will
depend on many factors. For example:
Does the State have air quality standards which are more
stringent than NAAQS?
Does the 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 demonstrating
the attainment of NAAQS o_r_ more stringent State standards?
Has the State initiated action to modify combustion
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?
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?
Are the total emissions from stationary fuel combustion sources
less than those from all other sources?
Must emission regulations be revised to accomplish significant
fuel switching?
t Do modeling results for specific fuel combustion sources show a
potential for a regulation revision?
Is there a significant clean fuels savings potential in the region?
The following portion of this report is directed at answering these questions.
An AQCR's potential for revising regulations is then determined 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
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Table 2-1. Summary of State Implementation Plan Review for Oregon
STATE
PORTLAND
CENTRAL EASTERN NORTHWEST INTERSTATE SOUTHWEST
AQCR AQCR AQCR AQCR AQCR
"INDICATORS"
t 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?
t 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?
Is there an expected 1975 attainment date
for NAAQS?
Based on reported (1973) Air Quality Data,
does air quality meet NAAQS?
Based on reported (1973) Air Quality Data,
are there indications of a tolerance for
increasing emissions?
t Based on the State Implementation Plan, are
emissions in 1975?
t 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 and the analysis
contained in the report, what is the potential for
revising fuel combustion source emission regulations?
Is there a significant Clean Fuels Savingd
potential in the region?
TSP S02
Nof
Yes
Yes
Yes9
Yes
Mo
Yes
Yes
Yes
Yes
Yes
No
TSP
No
Yes
Yes
No
No
Yes
Yes
Good
Yes
S0?
No
Yes
Yesc
Yes
Yes
Yes
No
Good
Noe
TSP S02
No
Yes
Yes
No
No
Yes
No
Yes
Yesc
Yes
Yes
Yes
TSP S02
No
Yes
Yesc
Yes
Yes
Yes
Yes
No
Yes
Yesc
Yes
Yes
Yes
Yes
1
Modeling Results Available
Yes
llargi-
nalb
No
No
Good
Noe
No
Good
Yes
No
Poor
Yes
TSP S02
Yes
.Yes
Yes
No
No
Yesa
Yes
Yes
Margi-
nalb
No
Yes
Yes
Yesc
Yes
Yes
Yes
Yes
No
Margi-
nal*1
Yes
TSP S02
Yes
Yes
Yesc
Yes
Yes
Yes
Yes
Yes
Itaroi-
nalb
No
No
Yes
Yesc
Yes
Yes
Yes
Yes
No
Good
Yes
XX^^'^^IJ^ <" «"»««» °f ^ ""'on are able to tolerate
'This refers to AQCRs where ambient concentrations are already (as of 1973) in compliance with federal air quality standards.
"Clean fuel savings" refers to the replacement of current fuel schedules with "dirtier" fuels (Whenever emissions from fuel
Ca7o^aneredSfoarn"cle:"Cfuea!esa:;ntS?UV'eOPardl2ln9 ^"^ * "^ " ^ "' "1"Slble *"'' »« location.
e
eA "No" assessment has been assigned because a relatively insignificant quantity of the regional SO, fuel combustion emission.;
are generated by controllable point sources (nearly all S02 emissions are generated by contrSl abll point source (near yal
teSr^e'^SZS cSra'^nsT '""" ^ SOUree "***"' the "W °f ^ e«*>" from'cTroV"
The State has adopted a single set of standards for ambient particulate concentrations which are the same as the federal
secondary standards.
9Area source fuel combustion emission regulations apply to commercial boilers. Many area fuel burning sources (residential
space heating units) are exempt from particulate emission control.
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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 characteri-
zation 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, AOCR's
have been classified as good, marginal, or poor candidates for regulation
revisions. The following table summarizes the State Implementation Plan
Review. The remaining portion of the report supports this summary with
explanations.
2.1 AIR QUALITY SETTING - STATE OF OREGON
The following discussion provides a characterization of the various
AQCR's 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 Oregon has been divided into five 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 Oregon. The
five regions and their boundaries are shown in Figure A-l.
Implementation of control measures to accomplish the federal air quality
standards throughout the State of Oregon is a shared responsibility of the
Department of Environmental Quality and two air pollution authorities
(the Mid-Willamette Valley Air Pollution Authority and the Lane Regional
Air Pollution Authority). The ju'risdictional areas of these air
pollution authorities are all contained within the Oregon portion of
the Portland Interstate Air Quality Control Region. The remaining
Implementation of control strategies in air quality control regions is a
responsibility of the State Department of Environmental Quality.
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The air pollution priority classification for each of the air quality
control regions for particulates, S02, and NOX, is presented in Table A-l.
Table A-l also provides an identification of counties which have been
proposed as Air Quality Maintenance Areas. The data indicate the most pres-
sing air pollution problem in the near term and long term involves
particulates. Two of the five AQCRs have been proposed as AQMAs for parti-
culates, and only one of the AQCRs was demonstrating air quality meeting
federal standards when the air program implementation plans were being
formulated. Table A-3 lists the expected attainment dates for federal air
quality standards in the various AQCRs.
It should be noted that the Priority I classification for SOg in the
Portland Interstate AQCR is based on air quality in the Washington portion
of the AQCR. Oregon monitoring data, obtained in Portland at the nearest point
to the high readings observed in Washington, and other data in the Oregon
portion of the Portland Interstate, would indicate a Priority III classification.
However, a recent analysis by the Oregon Department of Environmental Quality
indicates S02 standards will be exceeded by 1977 in the Portland Metro Area
(considering projected growth and gas curtailments).
2.1.2 Ambient Air Quality Standards
Ambient Air Standards for the State of Oregon are as shown in Table A-4.
The state standards for ambient levels of particulate matter are equivalent
to the federal secondary standards. The state standards for atmospheric SOp
are more stringent than 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 parti-
culate concentrations for each of the regions in 1973. Violations of the
federal air standards for suspended particulates occurred in three of the five
AQCRs, and were more severe in terms of the 24-hour basis. Based on region-
wide proportional rollback criteria, the regions of Central, Eastern, and the
Portland Interstate (Oregon Portion) will each require almost a 30% reduction
in region-wide 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 Oregon are subject to uneven distributions of source loading. The
uneven distribution causes consistent high particulate measurements at
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monitoring sites in the areas of greatest emission density, while the
remainder of the region usually reflects a much lower particulate profile.
Location of the monitoring site is therefore an important factor in the
characterization of regional air quality. If several monitoring sites exist
throughout a region, it may be possible to distinguish between areas of
different air quality, and further, to formulate separate control strate-
gies applicable to areas within the region.
Data from the air monitoring networks (Table A-6) of the various AQCRs
indicate that no violations of the air quality standards for S02 occurred
in 1973. The highest second highest 24-hour concentrations of S02 recorded
in any site throughout the State of Oregon was 234 ug/m^ in the Portland
Interstate AQCR. This concentration is well within the allowable level of
o
365 ug/m permitted by the federal air quality standards. In the remaining
four AQCRs, the highest second high 24-hour concentration was 13 ug/nr*.
Although the data was insufficient to permit an assessment of the annual
3
average, it is evident that the 80 ug/m° annual standard was not violated
in any of the AQCRs.
Measurement of S02 is performed at nine sites throughout the State.
Five of the sites are located in the Portland Interstate AQCR, where sources
of S02 are more concentrated than anywhere else in the State. Because sour-
ces of S02 emissions are nearly insignificant in the remaining AQCRs, only
one monitoring station is now employed to measure S02 in each of these
AQCRs.
2.1.4 Emissions Summary
Table A-8 provides a summary of the quantity of particulate emissions
generated in each of the AQCRs. The Oregon portion of the Portland Inter-
state receives substantially more emissions from particulate generating
sources than any of the other AQCRs. The Northwest AQCR contains the
smallest particulate emission rate, resulting in relatively low concentrations
of particulates, well within federal air quality standards. While emissions
of particulates in the largest AQCRs, the Central and Eastern Regions, are
also relatively small (Table A-8), the manner of distribution of these emissions
results in measured air quality indicating a 30% emission rollback require-
ment to meet standards.
11
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Table A-8 also provides a summary of the quantity and types of fuel
combustion particulate emissions in the various AQCRs. It is seen that
fuel combustion sources account for 14 to 24% of the total particulate
emissions in the various regions. Most of the fuel combustion particulate
emissions arise from industrial and commercial point sources. Because
nearly all electrical energy consumed by the State of Oregon is generated
by hydroelectric power plants, particulate emissions generated from
electrical generating facilities are relatively insignificant in all the
AQCRs. The quantity of particulate emissions generated by area sources is
also relatively small, ranging from 3.5% to 5.5% 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 inventoried
in the NEDS and/or the Federal Power Commission Data System. Only three
power plants have been identified as significant emission sources throughout
the State. (All of these are in the Portland Interstate AQCR). There are
far more industrial-commercial fuel combustion sources, and most of these
are wood burning units (which accounts for the fact there are far fewer
sources of S02 fuel combustion sources listed in Table A-7). Because the
burning of waste woods provides a very economical energy source, the wood-
burning units would not be likely candidates for fuel revision.
Table A-9 provides a summary of S02 emissions generated throughout the
various Oregon AQCRs. The role of fuel combustion in S02 emissions varies
somewhat from region to region. In the Northwest AQCR, fuel combustion
sources account for 72.5% of the total S02 emissions, while in the Central
AQCR, about 45% of the S02 emissions originate from fuel burning. As expected,
very little S02 is generated from power plant activity (predominantly hydro-
electric). In most AQCRs, combustion area sources account for the most sub-
stantial portion of the S02 emissions inventory. This arises primarily from
residential space heating and the burning of fuel oils. The quantity of S02
emissions from industrial-commercial sources varies from region to region.
In the Central and Eastern AQCRs, there are virtually no significant S02
emissions arising from industrial combustion sources. The impact of fuel
revisions or relaxation of combustion source emission regulations would have
12
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very minor effects on the air quality in these areas. However, in the
Northwest, Southwest, and Portland Interstate (Oregon portion) AQCRs, 50%,
26%, and 10 %, of the S02 emissions, respectively, generate from
industrial and commercial emission sources, and it is expected that air
quality in these regions could be affected by either a change in fuel
burning schedules, or a relaxation in regulations.
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 Oregon developed a control plan for achievement of the
federal air standards for particulates and SOp by addressing specific air
pollution problems in "example regions" possessing the poorest air quality.
The impact of candidate control strategies were investigated by developing
projected emission inventories, and calculating emission reductions expected
to result from application of the strategies. Control strategies which
were proven adequate for the example regions (Portland Interstate and South-
west AQCRs) were applied to the remaining regions, with the assumption they
would also be adequate to achieve standards there.
The plan development relied in general on simple pronortional model
roll-back calculations to demonstrate attainment for each of the regions. It
was recognized that such calculations do not reflect the influence of topo-
graphy, meteorology, the distribution of emission sources, and stack heights.
Because the required emissions rollback for region-wide emissions is based
on the measurement of air quality in an area possessing the poorest air
quality, it follows that the control strategy to accomplish this rollback is
overly restrictive for those areas of the state which are: 1) significantly
cleaner than the area of worst air quality, and 2) remote from the area of
worst air quality.
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A special feature of the Oregon air quality implementation plan is the
consideration it provides in recognizing the distinction between "fine" and
"total" particulates. Emissions inventoried as fine particulate are considered
to be directly related to the measured levels of suspended particulate matter
which indicate rollback requirements. Total particulates are considered to
include coarse particles which are present in substantial quantities in emission
source stack plumes, but which settle and fall out soon after their discharge
to the atmosphere. The Oregon air program addresses the control of fine
particulates, establishing control measures which will reduce these quantities
of particulates by the required rollback percentages. In employing this
procedure, the Oregon plan provides for direct control of measured levels
of suspended particulate emissions. Typically, most state plans address
the total inventory of particulate tonnages, crediting the elimination of
the coarse portion (which falls out of the atmosphere)- to their control
strategy, and to the required emission reduction . Since many emission
sources are comprised of large amounts of coarse particles which have
substantial impact on tabulated emission tonnages, it follows that the
Oregon control strategy is significantly more stringent than others developed
by more typical plan formulation procedures.
2.2.2 Particulate Control Strategy
The EPA judged the Implementation Plan of Oregon to be adequate for
attainment of standards for particulates and SOp. State and local regula-
tions have been enacted to assure attainment of the standards by 1975^
Table A-3 shows a summary of the attainment dates projected for each region.
The analysis performed by the State of Oregon in the formulation of the
Oregon Implementation Plan shows that the secondary standard for particulates
will be most difficult to meet in the Eastern AQCR. Based on proportional
model rollback calculations performed for the vicinity of worst air quality
in the region (Umatilla County), and on crude assumptions of background dust
'levels, the control strategy of the example region (Southwest AQCR) is ex-
pected to provide a 24% reduction of fine particulates, and 46% for total
particulates, by mid-1975. A particulate emission reduction of 35% is
estimated to be necessary to achieve the standards. The State included as
14
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a portion of the air-program a plan to evaluate monitoring background
levels in the area of worst air quality and to apply this information to
modify the Implementation Plan for Eastern Oregon if necessary.
Recent analysis by the Oregon Department of Environmental Quality
indicates that the particulate control strategy of the Implementation Plan
will not be as successful as originally anticipated within the Portland
Metro Air Quality Maintenance Area. The annual particulate standard
was projected to be achieved by 1975 but the maximum daily standard was
projected not to be met. After 1975, air quality is now expected to
worsen steadily with the annual particulate standard being exceeded by 1977.
This depreciation of air quality will arise from growth of emission sources,
and increased use of fuel oils due to gas curtailments. Until the 10-year
AQMA plan has been developed for the Portland Metro AQMA, the Department
has adopted interim regulations to restrict particulate and S02 emission
increases. These regulations include restrictions on economic growth, and
use of cleaner fuels in proposed installations.
Table A-10 summarizes pertinent data used in the development of the
Implementation Plan particulate control strategies. It should be recognized
that those air quality measurements selected as the controlling value for
rollback determinations were all annual means, which may not represent the
most severe values of ambient air standard violations in all of the regions.
Measurements of 24-hour averages reported in the Implementation Plan analysis
indicate greater violations of the air standards occur on a 24-hour basis.
Since the control strategies were formulated on the basis of the annual
readings rather than the worst violation values, it follows that the control
strategies may reflect an element of "under-design." However it should also
be remembered that the Oregon plan was formulated with special consideration
to control of fine particulates. This special aspect of the plan provides a
significant degree of control greater than that exemplified in other State
Implementation Plans judged adequate to attain standards.
The most significant control measure of the overall control strategy
adopted by the State of Oregon concerns the control of industrial process
emissions. In the example region of the Portland Interstate AQCR, control
15
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of process emissions in the wood products industry alone will achieve the
required emissions rollback to meet air quality standards. The Oregon
analysis also shows that similar reductions will result from enforcement
of industrial process emission regulations in the remaining regions.
2.2.3 Sulfur Oxide Control Strategy
The State of Oregon control strategy for SO^ differs greatly from that
for particulate matter, owing to the fact that virtually all of the regions
were in compliance with the national air quality standards for S0? when the
air program was formulated. The areas where air quality levels most nearly
approach the SOp standards are in the immediate vicinities of sulfite pulp
mills in Salem, Oregon City, and Newberg in Oregon, and Camas, Washington.
These areas are all contained within the Portland Interstate AQCR, which has
been designated as the example region for S02 control strategy development.
The control strategy for, sulfur dioxide addresses the two primary
sources of S0?: sulfite pulp mills, and fuel combustion equipment. The
principal control measures include:
* Best-technology control of sulfite pulp mill emissions to reduce
ambient air sulfur dioxide levels in the specific problem areas.
Limitations on the sulfur content of fuels, designed to minimize
future increases in sulfur dioxide emissions from fuel burning.
* New-source emission standards for large new fuel burning equip-
ment, plus general SOp emission standards of the regional
authorities.
Although no violations of federal air quality standards for S0? have
been documented in Oregon, the occurrences of 15 minute averages above the odor
3
threshold of 1300 ug/m are a significant and commonplace air quality pro-
blem in Oregon. These occurrences are directly attributable to blow pit
exhaust of sulfite pulp mills, estimated at approximately 80 pounds sulfur
dioxide per ton of pulp produced. Under the provisions of the State air
program, sulfite pulp mill emissions will be limited to 20 pounds per ton
of pulp, with the additional limitation on blow pit exhaust to 0.2 pounds
sulfur dioxide per minute per ton of pulp.
16
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The effect of control measures for sulfite mills will result in
reduction of blow pit emissions by approximately 97%, and overall olant
emissions by about 75%. Compliance with the emission standard is re-
quired by July, 1974.
In addition to SC^ emissions from sulfite pulp mills, emissions from
combustion of fuel oil are a major source of atmospheric SCL. In some
areas containing fuel combustion sources, an increasing trend has been
demonstrated for atmospheric levels of SO*. The control strategy of the
Oregon air program provides for limitation on the sulfur content (1.75%S)
of residual fuel oils to mitigate the trend of increasing SC^ emissions.
Taken as a whole, the Implementation Plan control strategy for sulfur
dioxide is expected to be adequate for the purposes of correcting major
point-source problems: sulfite pulp mills and the rate of increase of sul-
fur dioxide emissions from fuel burning. Total sulfur oxide emissions in
the Oregon portion of the Portland Interstate AQCR are projected to
decrease 6.1% by 1975, primarily as a result of large reductions in the
sulfite pulping industry. Similarily, emissions of S02 are expected to
decrease in each of the remaining AQCRs, although the reductions will be
minimal owing to the fact that few significant sources of SO^ exist in these
regions.
It should be noted that, due to growth and gas curtailments, ambient
S02 levels are expected to exceed the federal standards in the Portland Metro
Area by 1977. Interim emission regulations (to be replaced by provisions
of the 10-year AQMA plan now being formulated), restricting economic growth
and fuel usage, will be employed to mitigate effects of new source S02
emissions.
Table A-ll summarizes pertinent data used in the development of the
Implementation Plan SOp control strategies. The air quality measurements
selected as the controlling value for rollback determination were consti-
tuted on annual values estimated from a mathematical model for all regions
except the Portland Interstate, where S02 monitoring data was available.
17
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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 participates or
S0?. 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 the 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 reconciliable with recent air
quality/emissions data. In this case, forecasts of the plan are con-
sidered 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 com-
parison 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 quality
status in the region, which reflects the estimation before many substantial
controls have been implemented from the control strategy.
Table A-10 provides a summary of the data used to estimate a particulate
emission tolerance for each of the AQCRs. For three of the regions (the
Central, Northwest, and Portland Interstate AQCRs), Implementation Plan
forecasts appeared to be reconcilable with recent air quality/emissions
data. Hence, for the Central and Northwest regions, forecasts of the plan .
18
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were considered valid and used to develop an emissions tolerance. For
the assessment of the Portland Interstate emissions tolerance, the plan
forecast was not used in favor of more recent and reliable information
contained in a recent analysis by the State (the analysis showed that
there would be no emissions tolerance indicated for the Portland Metro
AQMA). For the remaining regions (the Eastern and Southwest AQCRs),
recent air quality/emissions data indicates that regionwide allowable
particulate emissions are substantially greater than that supposed in the
original plan development. Hence, for these regions, emission tolerances
were estimated based on 1973 air quality/emissions status.
The tabulations of Table A-10 show that three of the regions (Central,
Northwest, and Southwest AQCRs) possess a tolerance for increased emission
of particulates. Of these three regions, both the Southwest and Northwest
AQCRs were in compliance with federal air standards in 1973. The Central
AQCR is expected to come into compliance with air quality standards by 1975,
and acquire the emission tolerance shown in Table A-10 by that time. The
magnitude of emission tolerance for the Central and Northwest regions is
substantial. For example, in the Northwest AQCR, it is estimated that fuel
combustion emissions (1973) could be increased by a factor of five without
jeopardizing maintenance of the federal air standards.
It should be noted that, due to growth and other factors, ambient
levels of particulates are expected to increase and exceed the secondary
air quality standards in the AQMA (Medford-Ashland) of the Southwest AQCR.
Hence, while there is an indicated tolerance for increased particulate
emissions in the Southwest region in 1975, this tolerance will diminish
and be non-existent before 1985.
In the Eastern and the Portland Interstate (Oregon portion) AQCRs,
there are no emission tolerances indicated. However in each of these
regions, and for the Southwest region as well, there is a possibility that
some tolerance for increased particulate emissions may exist in geographic
areas removed from the areas of poorest air quality. The overall degree of
required control indicated for the entire region is predicated on the value
of the worst air quality in the entire region. In certain areas of "cleaner"
19
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air quality, remote from significant influence of the emissions arising
in the areas of worst air quality, the required rollback control is pro-
bably more severe than necessary for attainment (or maintenance) of
standards. Hence, it is plausible that some emission tolerance would be
possessed by these cleaner areas. (The quantification of these emission
tolerances within a region, on an area by area, or source by source basis,
are outside the scope of this study.) Unfortunately, the population and
emission source activity is often rather limited in these areas, so that
despite the fact these areas may possess substantial particulate emission
tolerances, the impact of a fuel savings plan in these areas would often
be insignificant.
Table A-11 provides a summary of the data used to estimate an S02
emission tolerance for each of the AQCRs. Implementation Plan forecasts
appeared to be irreconcilable with the more current 1973 air quality/
emissions data for all regions except the Central AQCR. Hence, the S02
emission tolerance for these four regions has been estimated based on 1973
emissions/air quality information, and does not reflect additional emission
reductions which may be achieved by the control strategy by 1975.
Since all regions were in substantial compliance with S02 air quality
standards, both in 1973 and the baseyear, substantial emission tolerances
have been estimated for each of the regions. The estimations of Table A-ll
show that SOp emission tolerances are large enough to permit present fuel
combustion source emissions of SOp to increase several times over present
levels.
It should be noted that, due to growth and gas curtailments, ambient
S02 levels are expected to increase steadily and exceed the federal standards
in the Portland Metro Area by 1977. Hence, while the emission tolerance in
this region may be substantial at the present time, it will diminish and be
non-existent by 1977.
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 Oregon State Air Program Implementation Plan. The regulations are
20
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fairly consistent throughout the state. In all AOCRs except the Portland
Interstate, SC^ emissions from combustion units are limited according to
the size of the unit (by heat input) and the fuel type burned. In addition
to stack emission limitations, sulfur content in fuels is restricted. In
the Portland Interstate AQCR, all fuel combustion units are limited by a
single rule - a 1000 ppm stack emission limitation (1.94 Ib of 502/10^ Btu
heat input). Particulate emissions from existing fuel combustion equipment
are limited to .2 grain/SCF (.3 lbs/10^ Btu heat input) in all regions except
in the counties of Clackamas, Columbia, Multnomah, and Washington in the
Portland Interstate AQCR, where a special limitation applies 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 may impact to some degree the final assessments to be developed in
this report.
2.3.1 Planned Revisions to the Implementation Plan
The EPA has approved the portions of the Oregon air pollution control
strategy for particulates and S02. It has been recognized that limited air
quality measurements were available at the time of the strategy formulation,
and that the plan provides for on-going development of control strategies as
may be indicated appropriate by new data obtained from an expanding air
monitoring network and special study efforts. This is exemplified in current
study efforts to quantify the impact of background dust levels on particulate
loadings in the Eastern AQCR. As a result of this study, the State will
evaluate the adequacy of regulations scheduled to be implemented under the
control strategy of the State air program.
The state of Oregon is developing a 10 year AQMA plan for proposed
AQMAs (see Table A-l) in the Southwest and Portland Interstate AQCRs.
Regulations evolving from this plan may replace less stringent restrictions
(Table A-12) now applicable to the AQMA areas. In the interim, the State has
adopted interim regulations to control particulate and S02 emissions in
21
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the Portland Metro Area. The interim restrictions apply to all new
proposed sources, and in the case of certain proposals for construction
of new oil refineries, it appears that the use of cleaner fuels will be
mandatory to meet the interim emission restrictions.
2.3.2 Special Problems
The enforcement of regulations limiting particulate emissions from
all fuel combustion sources to .2 grain/SCF will force: 1) the use of con-
trol equipment on wood burning boilers, or 2) the use of alternative fuels.
Currently there are numerous variances to burn wood in violation of the
regulation limits because of a fuel shortage problem in Oregon. It is
expected that most wood burning operations will be adapted for compliance
with particulate regulations by installation of boiler stack emission
control equipment.
2.3.3 Fuels and Anticipated Fuel Conversions
The vast majority of energy consumption in the State of Oregon is
produced by hydroelectric power plants. Of the current fuel energy used
in the State of Oregon in 1972, 33% was petroleum, 45% was natural gas and
the remainder (22%) 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 increasing
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 Oregon 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 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 regu-
lations 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 trend toward shortage of low sulfur fuel oils
22
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may create difficult S02 regulation compliance problems since increas-
ingly large quantities will be needed (in place of curtailed gas) to meet
the regulations. Flue gas desulfurization systems loom as a future S0?
emission control alternative, but because of their limited application to .
date, these systems are not expected to be available as a means of meeting
the 1975 compliance deadlines.
23
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3.0. AQCR ASSESSMENTS
The fundamental objective underlying the review conducted in this
report is to establish if fuel combustion emission levels may be increased
without jeopardizing the attainment or maintenance of federal ambient air
quality standards. The pursuit of this objective is a necessary pre-
requisite to the reasonable implementation of national energy goals. If it
is determined that emissions from certain fuel burning sources can be
increased throughout a given region, then it may be plausible that fuel
resource allocations can be altered for "clean fuel savings" in a manner
consistent with the national energy needs, and yet not so as to jeopardize
clean air goals. For those regions which demonstrate a potential for clean
fuel savings, an important related issue must be examined: the restrict!'ver
ness of fuel combustion emission regulations. Are the regulations more
restrictive than necessary to allow the permittable emissions increases as
determined by this review? That is, are the regulations overly restrictive
for the attainment of secondary ambient air standards?
The initial part of this review was organized to provide a determination
of the emissions tolerance which the various AQCRs are expected to possess
by the time the implementation plan is complete in 1975. This tolerance was
developed by consideration of the emissions/air quality data and an evalua-
tion of the implementation plan itself. The background information for the
tolerance assessment is contained in Section 2 and Appendix A. The
emissions tolerance is a measure of the degree of "over-cleaning" accom-
plished by the plan, or in cases where the region already conforms to air
quality standards, the tolerance is an expression of the degree of degradation
possible before federal air quality standards are jeopardized. The tolerance
assessment is combined in Appendix B with other regional air quality
"indicators" to provide an overall evaluation of a region's candidacy for
clean fuel savings (Section 3.1).
A detailed characterization of fuel combustion sources was carried
out in Appendix C, D, and E (and discussed in Section 3.1). This basic data
from these compilations was used in Appendix F to assess the restrictiveness
of emission regulations with respect to attainment of air quality standards.
24
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This was established by an assessment of the impact of combustion
operations on air quality when these operations emit at a level equiva-
lent to the ceiling rate of the emission regulation. The procedure for
this evaluation is outlined in Section 3.3. Finally, the basic source
data compliled in Appendix C, D, and E was also utilized to forecast the
impact of a possible fuel switch to accomplish clean fuel savings in the
State of Washington (Section 3.4).
3.1 ASSESSMENT OF CLEAN FUEL SAVINGS POTENTIAL BY REGIONAL AIR QUALITY
INDICATORS
The feasibility for accomplishing clean fuel savings was evaluated
by consideration 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 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, 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 identification of AQMAs is also important, since this pro-
vides an indication of those areas where the emission tolerance is expected
to diminish until non-existent in future years.
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.
Table B-l indicates that two of the five regions (the Central and
Northwest AQCRs) can be considered a good candidate for clean fuel savings
(or possibly regulations relaxation) without jeopardizing compliance with,
25
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or maintenance of, particulate ambient air quality standards. These
regions have been assessed as good candidates to obtain clean fuel
savings primarily because of their tolerance to accept substantial
particulate emissions increases in 1975 (see Table A-10) and in following
years. The Eastern, Southwest, and Portland Interstate AQCRs are judged
to be marginal candidates for clean fuel savings based on a combination
of two principal factors: 1) the uncertain adequacy of the present control strategy
to attain or maintain standards in the areas of poorest air quality, and 2) the
possibility that certain counties remote from the area of worst air quality
may possess a tolerance for increasing particulate emissions.
Table B-2 shows that each of the AQCRs except the Portland Interstate,
can be assigned as good candidates to accomplish clean fuel savings when
they are constrained by attainment of the S02 air standards only. This
evaluation results from the fact that these AQCRs are presently demonstra-
ting "over compliance" with the standards, and that substantial SOp emission
tolerances exist (and will be maintained) in these regions. In the Portland
Interstate (Oregon portion), levels of ambient SC^ are expected to increase
steadily in the Portland Metro Area until air quality standards are
exceeded in 1977. Therefore, the S02 emission tolerance of this AQCR will
also diminish steadily until it will no longer be feasible to increase SOp
emissions in the Portland Metro AQMA. However, because there may be areas
in the Portland Interstate removed from the Portland Metro AQMA where SOp
emissions may be increased without jeopardizing maintenance of current com-
pliance with S02 air quality standards, the region has been assessed as a
marginal candidate for clean fuel savings in Table B-2.
3.2 ASSESSMENT OF CLEAN FUEL SAVINGS POTENTIAL BY SOURCE ANALYSIS OF
POWER PLANTS/INDUSTRIAL-COMMERCIAL/AREA SOURCES
As over 99% of all power generation in Oregon is hydro-electrically
produced, there are only a limited number of fuel burning power plants in
the State of Oregon. Fuel use and emission data for the two major fuel
burning power plants operating in Oregon in 1973 is shown in Table C-l.
These plants are predominantly gas-fired, and the emissions of SOp and
particulates arising from their operation is virtually insignificant in the
overall emission inventories of the affected AQCRs.
26
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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 in
Table A-7. In Table D-l, wood burning plants in each county have been
aggregated as a single source, since it was not expected that clean fuel
savings objectives would be applicable to wood burners (due to economic
penalties associated with transport of waste woods for disposal or
combustion elsewhere). 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 regula-
tions, the point sources are found to be substantially deficient in all
regions except the Northwest AQCR. Based on the assessment of emission
tolerance in the various AQCRs, compliance of these sources with particulate
regulations may not be necessary in some regions (or areas) for the attain-
ment of ambient air standards. For example, since the Central AQCR would
permit an additional 3600 tons/yr of particulate emissions, it is evident
that the present wood burning operations, which generate nearly 100% of the
3400 tons/yr of fuel combustion particulate emissions, can be maintained at
status quo without the need of.additional air pollution controls to attain
the standards. For those AQCRs listed as marginal candidates (Portland
Interstate, Eastern and Southwest AQCRs) for regulation revisions, it may be
possible to relax regulations in those areas which appear to be removed from
the areas of poorest air quality. For example, it appears evident that it
would have minor impact on the air quality in most of the Eastern AQCRs if
all the sources listed in Table D-l, except for those in Umatilla and Union
Counties, were allowed to continue present burning practices. This would
require the availability of about 1.3 tons/yr of emission tolerance in the
"clean" counties of this AQCR. Since these counties are already meeting
the air quality standards, it is apparent they possess this tolerance. In
the Northwest AQCR, particulate emission sources are in substantial over-
compliance with emission regulations due to the use of large amounts of gas
used in boilers at the Georgia Pacific Plant. Emissions of particulates for
this region would be 17 times greater if residual oil were used at the plant.
27
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In fact, if fuel oils were used instead of gas, the regulations would
probably not be sufficient to provide for maintenance of air quality
standards in this region.
The significance of the fuel combustion area source varies greatly
from region to region (Tables A-8 and A-9), but generally accounts for a
large portion of the S02 emission inventory. For example, fuel combustion
area sources in the Eastern AQCR accounted for 58% of the SCL emissions
inventory and over 40% of the S02 emissions in the Central and Portland
Interstate (Oregon Portion) were generated by area fuel combustion sources.
The relative significance of the area source in the generation of parti-
culate emissions is far less pronounced, varying from 3.3% to 5.5% of the
overall particulate inventory. Area sources are-comprised largely of
residential and industrial space heating units, and small industrial and
commercial boilers, burning distillate and residual fuel oils. Most of these
units are exempt from emission control, and are not constrained to consume
"clean" fuels. Therefore, it does not appear that significant fuel savings can
be accomplished from the area source sector of the fuel consuming sources.
3.3 ASSESSMENT OF RESTRICTIVENESS OF FUEL COMBUSTION EMISSION REGULATIONS
Table F-l and F-2 combine the analysis of Appendix C, D, and E (power
plants, industrial/commercial, and area sources) to provide an assessment
of the restrictiveness of fuel burning emission regulations. The assess-
ment is carried out by evaluating the difference between the projected fuel
combustion emissions in 1975 and those emissions which are emitted at the
level of emission regulations. This difference constitutes the additional
emissions 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 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 restrictivess 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
28
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these allowable levels corresponds to the total region-wide emissions
which are generated when all regulated fuel combustion sources emit at
the celing level of the emission regulations, and the other allowable
level corresponds to the maximum region-wide emissions which can be
permitted 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 standards
(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 combustion emission
regulations are possibly less stringent than necessary to insure compliance
with the standards.
C
o
CO
CO
-------
In Table F-l, it can be seen that for the year 1975, participate fuel
combustion emission regulations appear to be overly restrictive in the
Central, Southwest, and Portland Interstate (Oregon portion) AQCRs. The
analysis indicates that in these regions it would be possible for fuel
combustion equipment to emit at the ceiling rate of the particulate emis-
sion regulations without jeopardizing attainment of the air quality
standards for ambient particulate concentrations. However, as mentioned
previously, air quality in the AQMAs of both the Southwest and Portland Inter-
state regions is projected to worsen steadily after 1975, therefore current fuel
combustion regulations cannot be judged overly-stringent for maintenance
of air quality standards in the vicinity of the AQMAs. In certain counties
or portions of the Portland Interstate, Southwest, and Eastern AQCRs, where
air quality is projected to remain in compliance with federal standards,
it is possible that particulate fuel combustion emission regulations could
be relaxed without threatening violation of standards.
In the Northwest AQCR, the analysis shows it is possible that emissions
of particulates could, despite the constraints of the emissions regulations,
increase beyond the allowable tolerance of the region, thus jeopardizing the
air quality standards without violating the present emission regulations.
Hence, fuel combustion emission regulations for particulates should not be
relaxed in the Northwest AQCR.
Figures 3-2 provides an approximate portrayal of the findings extracted
from Table F-l and information presented :in previous sections. These profiles
are presented as an aid in depicting the general relationship between:
1) allowable emissions permitted when fuel burning equipment emits at
regulation limits, 2) maximum allowable emissions permitted for compliance
with the NAAQS, and 3) the actual (past and projected) emissions level.
It should be recognized that the curves of Figure 3-2 reflect a region-
wide assessment based on the relationship between total regional particulate
emissions and the worst air quality measured within the region. Hence, the
portrayal of restrict!'veness of regulations may not be representative of
areas significantly cleaner than the area of worst air quality. Information
30
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Central AQCR
1975
1985
Regulations are more restrictive than necessary for
maintenance of secondary ambient air standards.
Regulations may be relaxed.
Eastern AQCR
1975
1985
Regulations are not too restrictive for attainment of
secondary ambient air standards.
Regulations should not be relaxed, except possibly in
cleaner areas of region.
Parti cul ate
Emissions
Northwest AQCR
1975
1985
Regulations are not too restrictive for maintenance of
secondary ambient air standards.
Regulations should not be relaxed.
i O
3->-
(J V)
i- yl
4J -r-
!- E
fO
Q.
Portland Interstate
(Oregon portion)
1975
1985
Regulations are not too restrictive for attainment of
secondary ambient air standards.
Regulations should not be relaxed, except possibly in
cleaner areas of region which are removed from AQMAs.
O
^3-r-
U c/1
Southwest AQCR
Regulations are not too restrictive for maintenance of
secondary ambient air standards.
Regulations should not be relaxed, except possibly in
cleaner areas of region which are removed from AQMA.
1975 1985
LEGEND:
Emissions allowable for compliance with secondary ambient air standards
Actual emissions (past and projected)
Emissions allowable when fuel burning sources emit at regulation limits
Figure 3-2. Restrict!veness of Fuel Combustion Particulate Emission
Regulations in Oregon AQCRs.
(Note: The profiles above are intended as conceptual
portrayals only, and should not be scaled.)
31
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available in this study did not permit a detailed assessment of air quality in
various geographic areas within each AQCR, nevertheless, it was clear that
significant portions of some of the regions would be able to permit more
lenient particulate emission regulations than those determined necessary
by the regionwide analysis. These regions are the Southwest, the Portland
Interstate (Oregon portion) and the Eastern AQCRs.
Table F-2 provides an assessment of S02 fuel combustion emission
regulations, and Figure 3-3 provides a graphical portrayal of this assess-
ment. It is demonstrated that it would be possible to incur substantial
relaxation of S02 fuel combustion emission regulations in all the regions
except the Northwest and the,Portland Interstate AQCRs without interfering
with attainment or maintenance of ambient air quality objectives. Since
the analysis of Table F-2 projects 1975 S02 emissions on the basis of con-
tinued use of present fuel schedules, it is estimated that the current high
degree of over-compliance will prevail with respect to meeting S02 emissions
regulations in 1975. Table F-2 shows a substantial increase of emissions
would be caused if combustion equipment emitted at the SOp regulation limits.
In all the regions, there is substantial room to increase S02 emissions
without violating emission regulations. This suggests that significant clean
fuel savings (in low sulfur fuel oil and natural gas) can be accomplished
without the need of revising regulations. Moreover, in all the regions
except the Northwest and Portland Interstate AQCRs, there is room after
relaxing emission regulations to permit additional SCL emissions before
emission tolerances would be used up, and maintenance of S02 air quality
jeopardized.
In the Portland Interstate, there may be significant geographic areas
removed from the Portland AQMA in which S02 fuel combustion emission regula-
tions may be overly-stringent for maintenance of the S02 standards.
In the Northwest AQCR large quantities of natural gas are used to meet
the fuel demands of the region. If combustion units were to emit at ceiling
rates allowed by emission regulations for the probable fuel substitute,
residual oil, total S02 emissions of the region would increase many times
and the overall S02 emissions inventory would exceed that whtch is allowed
32
-------
so?
Emissions
Portland Interstate AQCR
(Oregon portion)
1975
1985
Regulations are not too restrictive
for maintenance of secondary ambient
air standards.
Regulations should not be relaxed,
except possibly in cleaner areas
of region which are removed from
AQMA.
so2
Emissions
Central, Eastern, and
Southwest AQCRs
1975
1985
so2
Emissions
Northwest AQCR
1975
1985
Regulations are more restrictive
than necessary for maintenance
of secondary ambient air standards.
Regulations may be relaxed.
Regulations are not too restrictive
for maintenance of secondary ambient
air standards.
Regulations should not be relaxed.
LEGEND:
Emissions allowable for compliance with secondary ambient air standards
Actual emissions (past and projected)
Emissions allowable when fuel burning sources emit at regulation limits
Figure 3-3. Restrictiveness of S02 Fuel Combustion Emission
Regulations in Oregon AQCRs.
(Note: The profiles above are intended as
conceptual portrayals only, and should
not be scaled.)
33
-------
for the region to maintain the S(L air quality standards. Hence the
analysis for the Northwest AQCR indicates that air quality standards would
be violated before emission regulations and that SC^ emission regulations
are certainly not overly restrictive.
It should be noted that increases in S02 emissions from fuel combustion
sources have significant implication with respect to particulate pollution
problem in the various AQCRs. The burning of fuel oils of higher sulfur
content results in higher levels of ambient particulate jnatter by two
mechanisms: 1) increased emissions of particulates arising from higher
sulfur fuels (particulate emissions are directly related to sulfur con-
tent of fuels), and 2) S02 acting as precursors for formation of sulfate
particulates. If clean fuel savings are to be accomplished by the use of
higher sulfur fuels (made possible by relaxation of fuel combustion regu-
lations or by fuelischedule revisions within regulation allowances), care
should be taken to insure that particulate emission regulations are upheld
in the process. This is especially important in the Eastern, Portland
Interstate, Northwest, and Southwest AQCRs, where particulate emissions,
although in compliance with emission regulations, are jeopardizing the
attainment and maintenance of particulate air quality standards.
3.4 ASSESSMENT OF THE IMPACT OF PROBABLE FUEL SWITCHES
The impact of a feasible fuel switch to obtain clean fuel savings in
the State of Oregon is summarized in Table F-3. It was assumed that all gas
burning combustion equipment would be converted to burn relatively high sul-
fur (2% S) residual fuel oil, and that all use of residual fuel oil would be
converted to this higher sulfur (2% S) content. The switch is assumed to occur
in 1975, after compliance with emission regulations has been attained (by parti-
culate 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 from gas only
to fuel oil, there will undoubtedly be accompanying emission regulation
violations. Also, since it was assumed that SOp 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 regulation violations.
34
-------
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, the overall region-wide impact of the
fuel switch is far less than the impact 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 potential overall impact of this switch
on air quality is diminished by the degree of over-compliance of other com-
bustion sources (wood, oil) non-affected by the switch. Only a relatively
small portion of the total heat input generated in the region is produced by
the burning of gas, and hence only a small portion of the fuel conversion
would occur on fuel burning equipment not already equipped with adequate
emission controls. On the basis of the preliminary findings of Table F-3,
it would appear that the reasonable fuel switch outlined here could be
accomplished without seriously jeopardizing the attainment of secondary
standards for particulates in the Central AQCR, and in portions of the
Southwest, Portland Interstate (Oregon portion), and Eastern AQCRs removed
from the area of worst air quality. Table F-3 shows that for the case of
the Northwest AQCR, the clean fuel savings scheme would result in a region-
wide particulate emissions increase of 7,922 tons/yr, exceeding the estimated
emission tolerance of 7100 tons/yr for this region. Also, the switch would
aggravate attainment and maintenance problems for particulate standards in
the AQMAs of the Portland Interstate and Southwest AQCRs, and in the area of
worst air quality in the Eastern AQCR.
The impact of the fuel switch (Table F-3) on S02 emissions in the
various AQCRs is substantial. Violations of the emission regulations for
SOp will occur for all fuel combustion sources presently burning residual
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 Oregon, and slightly higher than the fuel oil sulfur con-
tent needed to meet the emission regulation in the various regions. The net
35
-------
increase of SOp emissions caused by the fuel switch is less than the SOp
emission tolerance in each of the regions except the Northwest AQCR, and
the Portland Interstate. Hence, the fuel switch can be accomplished with-
out jeopardizing air quality attainment goals in all of the regions except
the Northwest AQCR, and the Portland Interstate. In the Portland Interstate
region, it may be possible, however, to carry out the fuel switch in areas
removed from the Portland Metro AQMA without affecting maintenance of
NAAQS. In the Northwest AQCR, fuel consumption is predominantly natural
gas, and conversion to residual oils would cause an increase in SOg emissions
over the 1975 compliance level of about 120,000 tons/yr (this is far in
excess of the allowable S02 emission tolerance of 14,500 tons/yr).
36
-------
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 SOp 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
-------
r\>
NORTHWEST^
OREGON
INTRASTATE
PORTLAND
INTERSTATE
(OREGON-
WASHINGTON)
SOUTHWEST
OREGON
INTRASTATE
CENTRAL-
OREGON
INTRASTATE
EASTERN
OREGON
INTRASTATE
Figure A-l. Air Quality Control Regions In Oregon
-------
Table A-l. Oregon Air Pollution Control Areas
f
CJ
Air Quality Control Region
Central (#190)
Eastern (#191)
Northwest (#192)
Portland Interstate
(#193), Oregon Portion
Southwest (#194)
Priority Classification3 Proposed AQMA Designations0
Parti cul ate
II
II
III
I
II
S0x
III
III
III
IA
III
NOX
III
III
III
III
III
' TSP Counties
-
-
-
Clackmas,
Multnomah,
Washington,
Lane
Jackson
SOg Counties
-
-
-
Clackmas,
Multnomah,
Washington,
'
Criteria based on Maximum measured (or estimated pollution concentration in area) as shown below:
Priority
*" Sulfur oxide:
Annual arithmetic mean..
"" Particulate matter:
Annual geometric mean...
24-hour maximum
" Nitrogen dioxide
I
Greater than
100
445
95
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 NAAQS violations due to growth
-------
Table A-2. Regional Summary Information
Air Quality Control Region
Central (#190)
Eastern (#191)
Northwest (#192)
Portland Interstate
. (#193), Oregon Portion
Only
Southwest (#194)
Number of
Counties
8
10
3
10
5
Area
(Square Miles)
25,734
41 ,035
2,906
13,778
12,731
1970
Population
140,798
131,502
72,262
1,449,607
271,5431
Population Density
(Per square mile)
5.5
3.2
24.9
105
21.3
Source: Newspaper Enterprise Association, World Alamanac, 1973.
-------
Table A-3. Air Quality Attainment Dates
AQCR Name
Central (#190)
Eastern (#191)
Northwest (#192)
Portland Interstate (#193)
Oregon Portion Only
Southwest (#194)
\
Parti culates
Attainment Dates
Primary Secondary
a 5/75
5/75 5/75
a a
5/75 5/75
5/75 5/75
Sulfur Dioxide
Attainment Dates
Primary
a
a
a
a
a
Nitrogen Oxides
Attainment Dates
a
a
a
a
a
in
JAir quality levels are currently meeting the federal air standards.
-------
Table A-4. Federal and State Ambient Air Quality Standards
t
0*
All Concentrations in Mgms/m
Total Suspended Parti cul ate
Annual 24-Hour
Federal Primary 75 [G] 260a
Secondary 60 [6] 150a
State Standard 60 [G] 150a
Sulfur Dioxide
Annual 24-Hour 3-Hour
80 [A] 365a
1300a
60 260 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
Central
Eastern
Northwest
Portland Interstate
Southwest
# Of
Stations Reporting
5
4
1
68
6
TSP Concentration Cflg/m )
Highest Reading
Annual
66
6
24 hr
295
243
100
265
154
Highest
2nd
Highest
Reading
Z4 nr
205
202
96
205
145
Number of Stations Exceeding
Ambient Air Quality Standards
Primary Secondary
Annual
0
0
0
0
n
24 hrh
0
0
0
0
0
Annual
0
o
0
2
0
24 hrb
1
2
0
9
0
Emission
Reductions
Required to
Meet Secondary
Standards0
Annual ?d-hr
30%
29%
d
11.5% 29%
d d
1. Blank (-) indicates value is indeterminate due to absence of air duality data.
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.
Deduction required = £4 x 100. Where A = 2nd highest measured air quality for period of standard
A-B B = the background concentration
C = the concentration value of the standard.
dAir quality presently in attainment with standards.
-------
Table A-6. Summary of 1973 Air Quality Status for S02C
00
AQCR Name
^m
Central
Eastern
Northwest
Portland Interstate
Southwest
f
Reporting
24-Hr.
(Bubbler)
=====
1
1
1
5
1
*
Stations
Reporting
(Contln.)
=====
0
0
0
5
0
S02 Concentration
H g/m^
Highest Rearflna
Annual
=====
-
-
-
-
-
24-Hr.
=====
73
13
13
235
13
2nd
Highest
13
13
13
234C
13
1 Stations Exceeding
Ambient Air Quality Stds..
Primarv
Annual
=
-
-
-
-
-
24-Hr6.
=====
0
0
0
0
0
Secondary
3-Hr5
=====
-
-
-
-
Emission
Reduction
Reoui red
To Meet
24-Hour
Standard0
j
^^^"""^ -- "'a
d
d
d
d
d
1. Blanks (-) indicate value is indeterminate due to absence of air quality data.
aCompiled 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.
c A-C
% reduction required = ^- x 100. Where A = 2nd highest measured air quality for period of standard.
C = the concentration value of the standard.
Air quality presently in attainment with standards (no emission reductions are necessary).
e
It should be recognized that those stations utilizing continuous S02 monitors do not report the
second highest 24 hour value to the SAROAD system. The 234 ug/m3 figure reported here was obtained
by separate input from the Oregon Department of Environmental Quality for a SAROAD station employing
a eron-t-i nuous SO^ moiri "tor-
-------
Table A-7. Fuel Combustion Source Summary
AQCR Name
Central (#190)
Eastern (#181)
Northwest (#192)
Portland Interstate
(#193) Oregon
portion only
Southwest (#194)
Number of Power Plants3
0
0
0
3
0
Number of Industrial
Point Sources9
Particulates
22
15
7
66
38
or Commercial
for
so2
2
0
5
17
5
I
vo
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, Particulatese
AQCR
Central (#190)
Eastern (#191)
Northwest (#l«)
Portland Inter-
state (#193),
Oregon portion
only
Southwest (#194)
, Total
(l
-------
Table A-9. Fuel Combustion Emissions Summary for 1973, SCLa
AQCR
Central (#190)
Eastern (#191)
Northwest (#192
Portland
Interstate
#193), Oregon
portion only
Southwest (#194
, ToUl
(10J Tons/ Year
3.4
2.6
2.8
24.2
7.7
Total from;;:
Fuel Combustion
(103 Tons/Yr)
1.5
1.5
2.0
12.9
4.1
Percent
Fuel Combustion
44.7
57.7
72.5
53.3
53.7
Electricity Generation
(103 Tons/Year)
0
0
0
.25
.03
%
0
0
0
1.0
.4
; Industrial -Commercial
Fuel Combustion
(103 Tons/Year)
.12
0
1.4
2.4
2.0
%
3.5
';0
50.0
9.9
26.0
Area Source
Fuel Combustion
(103 Tons/Year)
1.4
1.5
.63
10.2
2.1
%
41.2
57.7
22.5
42.2
27.3
SO- emission figures were extracted from NEDS, "1972 national Emissions Report."
-------
Table A-10. Assessment of Emission Tolerance, Particulates
Baseyear and Forecasted Information from State Implementation Plan
Level of Air
Quality
Selected as
(ug/m3)
Central (»190) 69
(Annual)
Eastern (9191) 76
Northwest (0192) 36
(C192) (Annual)
Portland Inter- 76
state (J193) (Annual)
Oregon portion
Southwest 78
(1194) (Annual)
Emission
Reduction
Required
for
Attainment
Value
23*
35*
0*
25*
28*
Region-wide
Baseyear
(1970)
Emissions
(103 tons/yr)
15.7
10.8
6.5
87.7
54.8
Allowable
Region-wide
Emissions
(Total
Particulates)
Attainment3
(103 tons/yr)
12.1
7.0
13.6
65.7
39.4
Region -wide
EmissionfTota
Particulates!
Forecasted
Under SIP in
1975
(103 tons/yr)
12.1
7.0
6.5
35.0
21.1
Comments on Control Strategy and
Area of Greatest Impact
Application of control strategy of
example region (southwest) expected to
to attain standards.
Reduction of 24* of fine particulate
air quality (Umatilla County). Ade-
when background concentrations
are assessed.
ample region (Southwest) which are to
be applied to this region.
Overall emission reductions of 44* of
fine particulates to be achieved
region-wide, including area of worst
air quality (Portland). Reduction
achieved principally by control of
wood products industry.
Overall emission reduction of 54* of
fine particulates to be achieved
region-wide. A 30* reduction is
quality, Jackson.
Air Quality and Emissions Data from SAROAD and NEDSd
Level of
Worst Air
Quality
in 1973C
(ug/m3)
205
(24-hr)
202
96
(24-hr)
205
(24-hr)
145
(24-hr)
Emission
Reduction
Required
for
Attainment
29. 7Z
28.6*
0 *
28.81
0 *
Region-wide
Emissions
(Total
Particulates
in 1972)
(103 tons/yr)
16.6
13.7
8.0
93.5
55.0
Region-wide
Allowable
Emissions
(Total
Particulates)
(103 tons/yr)
11.7
9.8
13.3
66.5
57.1
R. 3.6 x 103 tons/yr tolerance on region-
wide basis.
NR. Hone indicated in vicinity of poorest air
exist in other counties.
R. 7.1 x 103 tons/yr tolerance on region-
wide basis.
R. No tolerance is indicated, based
on special assessment (see Note 3 below).
However, significant tolerance may exist
and persist in areas removed from AQMA.
BR. 2.1 x 103 tons/yr tolerance on region-
wide basis and diminishing to zero in near-
term. However, significant tolerance may
AQHA.
Allowable emissions for attainment of secondary standards are computed with the assumption that the overall
emissions within the entire AQCR contribute proportionally to the air quality at the state reporting the
most severe air quality violations. The allowable level is then calculated using the rollback from the most
severe violation which is needed to obtain federal standards.
The basis for assessing a region's tolerance for emission increase is determined by a judgment of the
degree of reconciliation between the SIP information and the 1973 NEDS/SAROAD data. If the allowable emis-
sions determined under the SIP development is in accord (within 20%} with the allowable,emissions calculated
from 1973 air quality and emission data, the forecasts of the SIP are considered valid, and emission tolerance
can be computed by taking the difference between allowable emissions and those emissions forecast for 1975.
However, in the case where reconciliation of the two data sources is difficult, it is assumed that the SfP
may be based on untenable grounds, and that the more current MEDS/SAROAD data is a more valid indicator of
the air quality/emissions relationship. In this case the emission tolerance expected in 1975 can only be
roughly estimated based on the 1973 air quality-emission status. Hence, in a sense, the emissions
tolerance is tabulated for either the year 1975 (based on forecast of Implementation Plan) or for 1973
(based on 1973 air quality/emissions data). Mote: NR indicates "not reconcilable," and R indicates
"reconcilable."
Refers to the 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 standards.
Air quality data is for the year of 1973 from SAROAD. Emissions data was available from NEDS for the year
1972.
Because^the forecasted emission levels are substantially less than those necessary to achieve the level of
allowalae region-wide emissions, it appears that the control strategy is designed for "over-attainment" of
air stmdards. This degree of apparent over-design is due to the formulation of the control strategy
based on control of fine particulates (thought to be more representative of measured levels of suspended
particulates}, rather than total particulates. as expressed above.
Notes:
1. The control strategy of SIP was based on limited air quality data from a monitoring network which has
since been expanded to include more sites. Hence if the air quality to emissions relationship from
the 1970 baseyear is irreconcilable with the 1973 SAROAD information, this may be a reason.
2. The control values selected for the SIP development were based solely on annual values of particulate
concentrations despite the fact 24-hour values were observed to constitute more severe violators of
the federal air standards. Hence this may be one reason why the air quality/emissions relationship
from the 1970 baseyear is irreconciliable with the 1973 SAROAD information.
3. Recent analysis by the State indicates secondary particulate standards may not be achieved in the
Portland Metro Area by 1975, and that air quality will steadily worsen after 1975. This recent
analysis updates the information presented above, and has provided the basis for the Portland Interstate
emission tolerance evaluation above.
-------
Table A-ll Assessment of Emission Tolerance for S02
Baseyear and Forecasted Information from State Implementation Plan
AQCR
Central (f!90)
Eastern (1191)
Northwest (S192)
Portland Interstate
(1193) Oregon Portion
Southwest (-194)
Level Of
Selected
As Control
SIP.
(cg/» )
13
(Annual )
33
37
(Annual )
190C
(24-hr)
8
(Annual )
Emission
Required
for
Cased On
Selected
Values
Ot
01
OJ
Ot
0*
Region-wide
Emissions
(103tons/yr)
3.6
2.6
2.8
25.5
8.2
Allowable
Region-wide
Emissions
For
Attainment"
22.2
6.3
6.1
49.0
82.0
Region-wide
Emissions
Forecasted
For AQCR
Under SIP
For 1975
(10 tons/yr)
3.6
2.6
2.8
24.0
8.2
Comments on Control
Strategy
Strategy will minimize increases in SO., emis-
sions in this region.
Same as above
Same as above
Controls for sulfite pulp mill S02 emissions are
projected to yield a 6X decrease Tn overall SOp
emissions in Oregon portion of region.
Strategy will minimize increases in S02 emis-
sions in this region.
Air Quality and Emissions Data From SAROAD and NEDS"
Level of
worst Air
Quality
In 1973
-------
Table A-12. Fuel Combustion Emission Regulations in Oregon
Governing Authority
Oregon Department of
Environmental Quality
Mid-Willamette
Air Pollution
Authority
Lane Regional Air
Pollution Authority
Columbia-Willa-
mette Air Pollution
Authority3
Applicable Region
Central AQCR
Eastern AQCR
Northwest AQCR
Southwest AQCR
Counties of Yamhill,
Polk, Benton, Marion,
and Linn in the
Portland Interstate
AQCR
County of Lane in the
Portland Interstate
AQCR
Counties of Clackamas,
Columbia,
Multnomah and Washing-
ton in the Portland
Interstate AQCR
S02 Emission Regulations
For combustion units 150 x 106 Btu/hr
1.4 Ib S0,/10? Btu input of liquid fuel
1.6 Ib SOg/lO0 Btu iflpaf for solid fuel
For combustion units 250 x 10 Btu/hr
.8 Ib SO,/10J? Btu inout of liquid fuel
1.2 Ib SO^/IO0 Btu input of solid fuel
Sulfur content in Fuels:
1.75% S - Residual fuel oils
.3% S - Distillate fuel #1
.5% S - Distillate fuel K
1.0% S - Coal
1000 ppm stack emission limit
n n ii n
ii n n n
Compliance
Date
Immediate
"
"
July 1, 1972
11
11 .
n
Immediate
n
n
TSP Emission
Regulations
.2 grains/SCF existing
sources
.1 grains/SCF new
sources
Same as Department
of Environmental
Quality
regulation.
II II M
See Figure A-2.
Compliance
Date
Immediate
Immediate
"
ii
I
-p>
aThe CWAPCA has been eliminated since the formulation of the State Implementation Plan, however, the regulations established by this authority
remain as part of the approved plan.
-------
C7I
(ft
G
o
CO
to
LiJ
1C
4-> CJ
S- 00
03 -^
D_
-------
APPENDIX B
The purpose of Appendix B is to provide an assessment of the
feasibility 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 i:
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. Hhen it is quantifiable and
suitably applied, the emission tolerance possibly provides the most important
indicator, since it provides a measure of the over-cleanliness of the region,
now or projected, and indicates how much additional pollution (such as from
dirtier fuels) can be permitted without resulting in violations of federal
air standards. The identification of AQMAs is also important as it indicates
which areas are expected to lose their tolerances for increased emissions in
the future.
B-l
-------
Table B-1. Candidacy Assessment for Clean Fuel Savings/Relaxation of Particulate Regulation
AQCR
Central
(#190)
Eastern
(#191)
Northwest
(#192)
Portland
Interstate
(#193)
Oregon
portion
Southwest
(#194)
Fraction
of Counties
in AQCR
with
Air Quality
Violations
in 1973b
1/7
1/10
0/3
2/11
0/5
Expected
Attainment
Date
a
5/75
a
5/75
5/75
Counties
with
Proposed
AQMA
Designations
None
None
None
Clackmas,
Multonomah,
Washington,
Lane
Jackson
Total
Particulate
Emissions
in
AQCR (1973)
103 tons/yr.
16.6
13.7
8.0
93.5
55.0
%
Emission
from Fuel
Combustion
23.8
22.3
16.2
14.0
21.9
Tolerance
for
Particulate
Emissions
Increase
(Table A-10)
(103 tons/yr)
3.6
None3
7.1
30. 7C
2.1C
Overall
Regional
Evaluation
Good Candidate
Marginal Candidate^
Good Candidate
Marginal Candidated
d
Marginal Candidate
D3
I
ro
aWhile no emission tolerance was indicated by the regionwide analysis shown in Table A-ll, significant tolerance may
exist in counties away from the areas of worst air quality.
blt should be noted that air monitoring stations do not exist in several of the counties.
cThis emission tolerance is expected to diminish after 1975 (due to growth and other factors) until
non-existent.
dThe region has been rated "marginal" rather than "poor" because some portions (or counties) of the region may be able
to tolerate additional emissions of particulate matter without jeopardizing attainment or maintenance of air quality
standards.
-------
Table B-2. Candidacy Assessment for Clean Fuel Savings/Relaxation of S02 Regulations
AQCR
Central
(#190)
Eastern
(#191)
Northwest
(#192)
Portland
Interstate
(#193)
Oregon
Portion
Southwest
(#194)
Fraction
of Counties
in AQCR
with
Air Quality
Violations
in 1973
0/7
0/10
0/3
0/11
0/5
Expected
Attainment
Date
a
a
.a1
a
a
Counties
with
Proposed
AQMA
Designations
None
None
None
Clackmas,
Multnomah,
Washington
None
Total S02
Emissions
AQCR (1973)
103 tons/yr
3.4
2.6
2.8
24.2
7.7
% Emission
from Fuel
Combustion
1.5
1.5
2.0
12.9
4.1
Tolerance
for S02
Emissions
Increase
(Table A-10)
(10J tons/yr)
18.6
13.4
14.5
52-. 6C
39.6
Overall
Regional
Evaluation
Good Candidate
Good Candidate
Good Candidate
Marginal Candidate01
Good Candidate
aAir quality levels within standards in 1973 and expected to remain so through 1975.
It should be noted that air monitoring stations do not exist in several of the counties.
cThis emission tolerance is projected to diminish steadily after 1975 until non-existent in 1977.
dThe region has been rated "marginal" rather than "poor" because some portions (or counties) may be able to
tolerate additional S02 emissions without jeopardizing attainment or maintenance of S02 air quality standards,
-------
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 "Steam 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 S02 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
"completeness" of the NEDS data bank.
C-l
-------
Table C-l. Power Plant Characterization
o
ro
Plant Name
Size, and
County Fuel Design
Portland Pacific Power
Interstate & Light
AQCR 36 MW
(Oregon n,, -
Portion): Oll» Gas
Multnomah
Portland General
Electric Co.
76 MW
Gas
Fuel Use
Type ; Heat
% Sulfur Annual Input
% Ash Quantity6 (106 Btu/hr)
Oil 8400 144
O.US
Gas 1855 212
Gas 564 64
Emissions
s°2
Existing r Allowable ,
Ibs/lO0 Ibs/lO0
tons/yr Btu tons/yr Btu
66 0.10 637 1.94
1 - 938 1.94
1 - 283 1.94
Parti culates
Existing . Allowablear
lbs/10° Ibs/lO0
;ons/yr Btu tons/yr Btu
96 0.15 139 .22
17 0.02 2Q4 .22
4 0.01 70.1 .25
Allowable emissions refers to the maximum emissions permitted by emission regulations. Fur fuel burning equipment
operating on gas, the allowable emissions were considered to be those which would be permitted if the equipment
used residual oil instead.
bOil - 103 gallons, Gas - 103 MCF, Coal - 103 tons.
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,
Electric Light and Power, July 1974.
-------
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
CENTRAL AQC
Klamath
Lake
i
Wasco
Crook
Plant Name
* (#190):
Wood Burning
Plants
Eastern Oregon
Pine
Fremont Sawmill
Wood Burning
Plants
Harvey Alum Co.
Wood Burning
Plants
Consolidated
| Pine
Wood Burning
Plants
Fuel Use
Type
% Sulfur
% Ash
Wood
R. Oil
1.0%S
D. Oil
'1.2J5S
Wood
Gas
Wood
R. Oil
1.5%S c
Wood
Annual
Quantityb
419200
1140
300
21000
259
7000
16000
51000
Heat
Input
(106 Btu/hr)
574
19.5 .
4.8
29
29.6
9.6
274
70
Emissions
S02
Existing | Allowable9
tons/yr
210
' 91
26
.10.5
1
3.5
1884
26
!bs/10<
Btu
.OR
1.07
1.24
.08
.08
1.6
.08
5
tons/yr
210
119
.8.4
10.5
182
3.5
942
26
bs/10£
Btu
.OR
1.4
0.4
.08
1.4
.08
0.8
.08
Particulates
Existing
tons7v
2520
13 .
3
126
2
12
96
171
lbs/106
Btu
1.06
0.15
0.13
0.99
0.02
0.29
0.08
0.56
Allowable?
tons/y
754
25.6
6.3
38.1
38.9
12.6
360
92.0
ibs/106
JLtSL.
.3
.3
.3
.3
.3
.3
.3
.3
-------
Table D-l. Industrial-Commercial.. Fuel Combustion Point Source Characterization .
County
Deschutes
Hood
River
Jefferson
EASTERN AQC
Baker
Grant
U Matill a
Plant Name
Wood Burning
Plants
U.S. Plywood
Corporation
Wood Burning
Plants
Wood Burning
Plants
TOTAL
I (#191):
Ellingson Lumber
Wood Burning
Plants
U.S. Gypsum
Fuel Use .
Type .
% Sulfur
% Ash
Wood
Gas
Wood
Wood
Wood
R. Oil
1,5%S c
Wood
Gas
Annual .
Quantity^
299000
250
4000
25800
9000
22000
147000
285
Heat
Input
(106 Btu/hr)
410
28.5
5.5
35
12.3
1501.8
377
201
32.5
Emissions
S02
Existing | Allowable3
tons/'yr
150
1
2
13
4.5
2421
2591
74
1
lbs/10
Btu
.08
.08
.08
.08
1.57
.08
--
5
tons/yr
3000
175
2
13
4.5
4697
2310
74
114
Parti culates
Existing I Allowable3
lbs/10^
Btu ftons/v
1.6
1.4
.08
.08
.08
1.4
.08
0.8
310
?
7
108
54
3424
132
912
3
!bs/106
Btu
0.17
o.nj?
0.29
0.70
1.00
0.79
1.04
0.02
tons/y)
539
37.4
7.2
46.0
16.2.
1974
49.9
264
42.7
lbs/10g
Btu
.3
.3
.3
.3
.3
.3
.3
.3
-------
Table D-1. Industrial-Commercia.l Fuel Combustion Point Source Character!zatic:,
County
U.Mat ilia
Union
Wai Iowa
Wheeler
NORTHWEST At
Plant Name
Wood Burning
Plants
Boise Cascade
Wood Burning
Plants
Wood Burning
Plants
TOTAL
CR (#192):
1
Clatsop a Wood Burning
I Plants
i
Crown Zell
Fuel Use
Type
% Sulfur
% Ash
Wood
Gas
Wood
Wood
Wood
Wood
R. Oil
2.0%S
Gas
Annual
Quantity13
53000
132
115400
10000
31000
24000
2910
2720
Heat
Incut
(106 Btu/hr)
72.6
15.0
158
13.7
42.5
912.3
32.9
49.8
311
Emissions
S02
Existing
jibs/101
tons/yrj_Btu
26.5
1
57.7
5.0
15.5
2770
12.0
463
1
.08
» _
.08
.08
.08
.08
2.12
.01
Allowable*
Participates
Existing
Allowable3
5 jibs/106 jibs/ 106
tons/vr! Btu [tons/vJ Rtu f.nns/vr
26.5
92.0
1154
5
15.5
3791
'
12
306
1090
.08
1.4
1.6
.08
.08
.08
1.4
0.8
318
1
692
60
1.00
0.02
1.0
1.0
i
186
2304
21
15
20
1.0
0.15
0.07
0.01
95.4
19.7
2.1
18.0
55.8
548
43.2
65.4
409
!bs/106
Btu
F
.3
i
i -3
.3
.3
.3
.3
.3
.3
-------
Table D-l. Industrials-Commercial Fuel Combustion Point Source Characterization
County
Lincoln
Tillamook
1
PORTLAND IN
t
Benton
Clackamas
i
»t
Plant Name
Georgia Pacific
Wood Burning
Plants
Publishers Pacer
Ore. Wash. Mwd.
*
TOTAL
TERSTATE (#193),'0
Georgia Pacific
Evans Products
Publishers Paper
Fuel Use
Type
% Sulfur
% Ash
R. Oil
1.7%S
Gas
Wood
R. Oil
1.3%
R. Oil
2.0%S
REGON PORTIOI
Gas
Gas
Gas
Annual
Quantity5
3860
112270
31300
2320
230
56
300
1380
Heat
Input
(106 Btu/hr)
66.1
12817
42.9
39.7
3.9
13363.3
6.4
34
158
Emissions
S02
Existing j Allowable9
fibs/1 0*
tons/yr[ Btu
500
34
15.7
240
37
1303
1
3
1
1.7
.01
.08
1.38
2.17
--
0.02
!
5
tons/yr
412
44910
15.7
243
-
23.9
47013
28.3
150
6-9
!bs/10£
Btu
1.4
0.8
.08
1.4
1.4
1.94
1.94
1.94
Particulates
Existing I Allcv.'able9
ttons/yr
19
674
179
28
3
959
3
12
34
bs/10^
Btu |tons/y_
0.07
0.01
0.95
0.16
0.18
0.11
0.08
n.05
86.9
16842
56.4
52.2
5.1
17560
8.4
44.7
166
!bs/106
Btu
.3
.3
.3
.3
.3
.3
.3
.24
-------
Table D-l. Industrials-Commercial Fuel Combustion Point Source Characterization
County
Clackamas
(cont1 )
Lane
Linn
Plant Name
Publishers Paper
Boise Cascade
Wood Burning
Plants
Bohemia Lbr.Co.
Giustina Bros. PI
Weyerhaeuser Co.
Wood Burning
Plants
Boise Cascade
Fuel Use
Type
% Sulfur
% Ash
R. Oil c
1.5%S '
R. Oil C
1 . 5%S
Gas
Wood
R. Oil
1.5%S
Gas
R. Oil
1.5%S
Gas
Wood
Gas
Annual
Quantity13
510
4074
2010
25954
35000
1500
1360
1010
530340
378
Heat
Input
(106 Btu/hr)
8.7
69.8
229
35.6
599
171
23.3
115
727
43.2
Emissions
S02
Existing
tons/yr
60
485
' 1
13
4121
1
162
1
265
1
Allowable9
ibs/106
Btu jtons/j/r
1.57
1.59
.08
1.57
1.59
--
.08
__
38.6
308
1013
13
-
866
757
103
509
265
191
lbs/10£
Btu
1.94
1.94
1.94
.08
1.94
1.94
1.94
1.94
.08
1.94
Particulates
Existing
i
tons/v
8
46
18
156
210
14
16
9
4840
3
lbs/106
Btu
0.21
n.15
0.02
1.00
0.08
0.02
0.16
0.02
1.52
0.02
Allcv;ablea
tons/yr
11.4
82.5
221
46.8
787
225
30.6
151
Q55
56.8
lbs/105
Btu
.3
.27
.22
.3
.3
.3
.3
.3
.3
.3
-------
Table D-l. Industrial-Commercial. Fuel Combustion Point Source Characterization
County
Linn
(cont1 )
Plant Name
Vancouver Plywd.
American Can
Crown Zellerbach
!
1
Western Kraft
u
J Wood Burning
1 Plants
1
Marion p Burkland
Boise Cascade
1
Fuel Use .
Type
% Sulfur
% Ash
Gas
R. Oil
Gas
Wood
Oil
R. Oil
1.3%S
Gas
Wood
R. Oil
1.3%S
Gas
R. Oil
1 . 5%S
Gas
Annual
Quantity b
775
895
130
73000
273
2769
1680
274000
91
1370
2509
1661
Heat
Input
(106 Btu/hr)
88.5
15.3
14.8
100
4.7
47.4
192
375
1.6
156
43.0
190
Emissions
S02
Existing | Allowable9
tons/y_r
1
107
1
36.5
33
290
1
137
9
1
300
1
Ibs/106
Btu [tons/yr
_
1.60
_
.08
1.60
1.40
--
.08
1.28
1.59
-_
392
68
36.5
20.9
209
849
137
7.1
691
191
841
Particulates
Existing
Ibs/10^
B_ly_ t°ns/z
1.P4
1.94
.08
1.94
1.94
1.94
.08
1.94
1.94
1.94
1.94
7
10
1
438
3
28
16
1279
1
12
29
16
!bs/106
Btu
0.02
0.15
0.02
1.00
0.15
0.13
0.02
0.78
0.14
0.02
0.15
0.19
Allov/able3
tons/vr
116
20.1
19.4
131
6.2
62.3
252
493
2.1
205
56.5
250
lbs/10^
Btu
.3
.3
.3
.3
.3
.3
.3
.3
.3
.3
.3
.3
-------
Table D-l. Industri all-Commercial Fuel Combustion Point Source Characterization
County
Multnomah
Polk
i
Plant Name
i
Mayflower Farms
Linnton Plywood
Pioneer Flintkot
Union Oil
Standard Oil
Shell Oil
Wood Burning
Plants
Ore American
Standard
Fuel Use
Type
% Sulfur
% Ash
R. Oil
1.55KS
Gas
R. Oil
1.5J5S
; R. Oil
1 . 5%S
R. Oil
1.4%S
R. Oil
1.4%S
R. Oil
1.435S
Wood
Gas
Annual L
Quantity
,248
110
1010
1202
1390
1260
1950
143849
275
Heat
Input
(106 Btu/hr)
4.2
12.6
17.3
20.6
23.8
21.6
33.4
197
31.4
Emissions
S02
Existing
tonsjyr
30
1
. 120
125
150
136
211
72
1
Allowable9
ibs/106
Btu (tons/vr
1.63
1.58
1.39
1.44
1.44
1.44
.08
--
18.6
55.8
76.5
90.9
105
95.3
148
72
139
Parti culates
Existing
ibs/10°
Btu_jtons/yj
1.94
1.94
1.94
1.94
1.94
1.94
1.94
.08
1.94
3
1
12
14
10
9
14
866
3
Btu
0.16
0.02
0.16
0.16
0.10
0.10
0.10
1.00
-.02
Allov/ablea
tons/vj
5.5
16.5
22.7
27.1
31.3
28.4
42.4
259
41.3
Btu
.3
.3
.3
.3
.3
.3
.29
.3
.3
-------
Table D-l. Industrial-Commerical Fuel Combustion Point Source Characterization
County
Polk
(cont1)
Washington
Yamhill
i
I
Tillamook
!
Plant Name
Boise Cascade
Wood Burning
Plants
Wood Burning
Plants
Publishers Paper
Wood Burning
Plants
Tillamook
VNR Co.
Wood Burning
Plants
TOTAL
Fuel Use .
Type
% Sulfur
% Ash
Gas
Wood
Wood
Gas
R. Oil
1 . 5%S
Wood
R. Oil
2.0%S
Gas
Wood
Annual
Quantity^
315
1 40000
13000
1250
840
42981
1050
2500
26000
Heat
Input
(106 Btu/hr)
36.0
192
17.8
143
14.4
58.9
18.0
285
35.6
4610.9
Emissions
S02
Existing j Allowable9
tons/yr
1
70
- 6.5
1
100
21.5
168
1
13
7246
lbs/106
Btu itons/yr
.08
.08
1.59
.08
2.13
.01
.08
139
70
6.5
633
63.5
21.5
83.7
412
13
10343
Particulates
Existing
Allov;ablea
lbs/106! Jbs/10^
Btu |tons/yH Btu ftons/.yr
1.94
.08
.08
1.94
1.94
.08
1.94
1.94
.08
3
840
78
11
10
258
12
23
156
9532
0.02
1.00
1.00
0.02
0.16
1.00
0.15
0.02
1.00
47.3
252
23.4
188
1.8.9.
11 A
23.7
374
46,8
5926
!bs/10c
Btu
.3
.3
.3
.3
.3
.3
.3
.3
.3
-------
Table D-l. Industrial-Commercial Fuel Combustion Point Source Characterization
County
SOUTHWEST A
Coos
Curry
Douglas
|
Plant Name
1CR (#194): '
Wood Burning
Plants
Wood Burning
Plants
Nordic Plywood
Drain Plywood
i
i International
Paper Gardiner
Jackson i Carolina Pacific
| Plywood
r
i
Kogap Mfg.
Wood Burning
Plants
Fuel Use
Type
% Sulfur
% Ash
Exempt Wood^
Non-Ex. Wd.
Wood
Gas
R. (Ml.
1 . 5%S
R. Oil
1 . 5%S
Gas
D. Oil
1.2%S c
Wood
Annual ,
Quantity0
102000
394000
93000
207
1560
14700 .
V
2700
258
1378870
Heat
Incut
(106'Btu/hr)
140
540
127
23.6
26.8
251
308
4.1
1889
Emissions
S02
Existing | Allowable3
tons/yr
51
197
46.5
1
184
1750
1
22
689
!bs/10l
Btu
' .08
.08
.08
1.57
1.6
.01
1.23
.08
Parti culates
Existing
Allowable a
> jibs/106, jibs/105. libs/10^
cons./yjl Btu Icons /vr! Ptu jtons/vn Btu
51
3940
46.5
145
164
875
1079
7.2
689
.08
1.6
.08
1.4
1.4
0.8
0.8
0.4
.08
1
343
1326
558
2
16
74
24
2
3429
0.56
0.56
1.00
0.02
0.14
0.07
0.02
0.14
0.41
]
184
710
167
31.0
35.2
330
405
5.4
2482
.3
.3
.3
.3
.3
.3
.3
.3
.3
-------
Table D-l, Industrial^Commercial Fuel Combustion Point Source Characterization
County
Josephine
Plant Name
Wood Burning
Plants
TOTAL
Fuel Use '.
Type
% Sulfur
% Ash
Wood
Annual j
Quantity6
171820
Heat
Input
(106 Btu/hr)
235
2412
Emissions
S02
Existing | Allowable'2
tons/yr
86
327.1
Ibs/10<
Btu
.08
5
tons/yr
86
7327
I'bs'/lO*
Btu
.08
Parti culates
Existing I Allowable*
tons/vr
997
8841
bs/10£
Btu
0.97
tons/yr
309
5537
!bs/10?
SliL.
.3
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 - 103 MCF, Coal - 103 tons.
°Value for sulfur content was not available and was assumed to be equivalent to state average for the fuel type used.
d,,
Exempt" and "non-exempt" refer to the applicability of emission regulations. The non-exempt wood burning is constituted of
plants with boilers of greater than 150 x 10^ Btu/M heat input.
NOTES:
1. Data was extracted from information in NEDS as of 1974. 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.
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APPENDIX E
Table E-l shows area source fuel use for the entire state of Oregon.
The approximate energy values are compared for each fuel along with the
percent of overall energy derived from each fuel. The bottom row entitled
"all fuels, all sources" may not match totals from Appendices A, C, and D,
exactly, since neither the NEDS or individual appendix totals are all-
inclusive. Also fuel schedules may change from one year to the next.
E-l
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Table E-l. Total State Area Fuel Use9, Oregon
Source
AREA SOURCES t
Residential
Industrial
Commercial/
Institution^"
AREA SOURCESt
Total
% By Fuel
AREA AMD
POINT SOURCES
Total Fuel
Use
% By Fuel
COAL
O3 tons TO9 Btu
10.2 235
0 0
2006 462
30.26 697
0.4
99.22 2287
0.6
RESID. OIL
103 gal !09 Btu
0 0
178230 24950
105530 14773
283760 39723
21.1
400143 56016
15.9
oisr. OIL
103 g?.1 109 Btu
1
266230 37274
79770 11168
22350 3129
368350 51571
27.4
430882 60327
17.1
GAS
lO6 ft3 109 Etu
~ i
27760 27760
45730 45730
17880 17880
91370 91370
48.6
157946 157946
44.8
WOOD
103 tons 109 Btu
284.6 3411
114.1 1367
1.2 14
390,0 47Q2
2.5
6356.2 76166
21.6
TOTAL
1C9 Btu
68680
83215
36258
i 188153
352742
Fuel use figures are taken from data in NEDS data bank as of September 1974.
-------
APPENDIX F
The Tables F-1 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 is 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 different from the one at
present were in effect.
F-1
-------
Table F-l. Assessment of Restrict!veness of Participate Emission Regulations for Fuel Burning Equipment
AOCR
Central (#190)
Eastern (#191)
Northwest (#193)
Portland Interstate
(#193), Oregon
Portion
Southwest (#194)
Fuel Burning
Imissions, 1972
103tons/vr
3.4
2.3
1.0
9.7
8.8
Fuel Burning
Emissions
Projected for
1975b
103tons/yr
1.4
.5
.8
3.1
4.9
1975 Fuel
Burning Emissions
at Regulation
Limit RatesC
103tons/yr
2.0
.6
17.6
6.3
5.5
Increase in 1975 Emissions in
AQCR When Fuel Burning Units
Emit at Regulation Limits
103
tons/yr
.6
.1
16.8
3.2
.6
Percentage of
Total Emission
Inventory
1973
3.6%
.7%
210%
3.4%
1.1%
Tolerance for
Particulate
Emissions Increase
in AQCR in 1975
103tons/yr
3.6
None
7.1
None
2.1 but
diminishing
to none in
near term.
Assessment of
Restrictiveness
of Fuel Burning
Emission Regulations"
Overly restrictive. Signi-
ficant relaxation appears
possible.
Not overly restrictive for
sources contributing to are;
of worst air quality. Pro-
bably over-restrictive in
"cleaner" counties.
Not overly restrictive.
Not overly restrictive for
sources contributing to air
quality, but probably over-
restrictive in cleaner area;
Overly restrictive for
attainment in 1975, but not
for maintenance in near term.
Regulations may be over-
restrictive for cleaner
areas removed from AQMA.
I
ro
Calculated as sum of point sources from Appendix C and D.
bProjected 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 neolected in the assessment as they were expected to remain constant. Also
zero growth was assumed to apply to all point sources.
°These 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 mav be re-
laxed to allow hiqher emission rates without interfering with the attainment of federal air standards.
-------
Table F-2. Assessment of Restrict!'veness of S02 Emission Regulations for Fuel Burning Equipment
AQCR
Central (#190)
Eastern (1191)
Northwest
(#192)
Portland Inter
state (#193),
Oregon Portion
Southwest
(#194)
Fuel Burning
Emissions, 1972a
103tons/yr
2.4
2.8
1.3
7.3
3.3
Fuel Burning
Emissions
Projected for
1975^
103tons/yr
1.5
2.5
1.0
3.2
2.4
1975 Fuel
Burning Emissions
at Regulation
Limit RatesC
lO^tons/yr
4.7
3.8
47.3
12.5
7.9
Increise in 1975 Emissions in
AQCR When Fuel Burning Units
Emit at Peculation Limits
103
tons/yr
3.2
1.3
46.3
9.3
5.5
Pertentage of
Total Emission
Inventory
1973
94%
50%
16503!
28%
72%
Tolerance for
S02
Emissions Increase
in AQCR in 1975
103tons/yr
18.6
13.4
14.5
37.8, but dimi-
nishing to zero
by 1977
39.6
Assessment of
Restrict! veness
of Fuel Burning
Emission Regulations"
Overly restrictive
Overly restrictive
Not overly restrictive
Not overly restrictive
for sources contributing
to area of worst air
quality, but probably
overly restrictive in
areas removed from AQMAs
Overly restrictive
I
CO
Calculated as sum of point sources from Appendix C and D.
bProjected 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.
GThese emissions have been calculated as "allowable emissions" In Tables C-l and D-l.
'H'he restrict!veness 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.
-------
Table F-3. Fuel Switch Evaluation
AQCR
Central
(*1«0)
Eastern
(1191)
northwest
(1192)
Portland
Interstate
(1193),
)regon
IH>rtion
Southwest
(1194)
Source Category
Industrial and
Cownercial
TOTAL
Industrial and
Commercial
TOTAL
Industrial and
Commercial
TOTAL
Power Plants
Industrial and
Counter leal
TOTAL
Industrial and
Commercial
TOTAL
Fuel
Type
an
Gas
011
Sas
011
Gas
on
Gas
Oil
Gas
011
Gas
Projected Usage In 1975b
Quantity"
17440
509
22000
417
9320
114990
8400
2419
54631
16791
16518
2907
Heat Input
10* Btu/hr
298
58
356
377
47.5
425
160
13128
13288
144
276
966
1905
3291
281
332
613
Emissions
TSP
112
4
116
50
4
54
65
694
759
96
21
432
186
735
92
26
118
(Tons/yr)
S02
1041
1
1041
2310
1
2310
982
35
1017
66
1
2472
4
2542
1046
1
1047
Gas Switch to 2*S R. 011. R. Oil to 2*S R. Oil
Qty. Switched
17140
509
22000
417
9320
114990
8400
2419
56431
16791
16260
2907
Heat Input
106 Btu/hr
293
SB
351
377
47.5
325
160
13128
13288
144
276
966
1905
3291
277
332
609
Resulting
TSP
0
35
35
0
25
25
0
7922
7922
0
145
0
672
817
0
198
198
Emission Increase1"
S02
1650
533
2183
1144
435
1579
481
120004
1Z04R5
1253
2728
6388
17466
27835
1S07
3059
4S66
"Quantity is in units as follows: Oil -103 gallons, gas -1fl9 CF, Coal - 103 tons.
n'he projected usage for fuel burning sources in 1975 are the same as in those tabulated in Appendix C, and D. Growth was
assuned to be non-Increasing, based on non-employment trends in the State.
°The emissions Increase due to the fuel switch 1s calculated by comparing the projected compliance emissions tn JJ!lRcli'rnSr?iiXnt
fuel type with those that occur when fuel switches are made ( .calculated by utilization of emission factors from EPA Document
type
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 Goal
Association.
(5) "Federal Air Quality Control Regions," U. S. EPA, Pub. Mo. 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) Department of Environmental Quality, Air Quality Control Division,
"Report on Designation of Air Quality Maintenance Areas,"
March 1974.
-------
TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1. REPORT NO.
EPA-450/3-75-012
2.
3. RECIPIENT'S ACCESSION-NO.
4. TITLE AND SUBTITLE
5. REPORT DATE
IMPLEMENTATION PLAN REVIEW FOR OREGON AS REQUIRED
BY THE ENERGY SUPPLY AND ENVIRONMENTAL COORDINATION
ACT.
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 90278.
11. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS
13. TYPE OF REPORT AND PERIOD COVERED
U. S. Environmental Protection Agency
Office of Air and Waste Management
Office of Air Quality Planning and Standards
Research Triangle Park. North Carolina 27711
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
b.IDENTIFIERS/OPEN ENDED TERMS C. COS AT I Field/Group
DESCRIPTORS
Air pollution
State Implementation Plans
13. DISTRIBUTION STATEMENT
Release Unlimited
19. SECURITY CLASS (ThisReport)
Unclassified
21. NO. OF PAGES
82
20. SECURITY CLASS (Thispage)
Unclassified
22. PRICE
EPA Form 2220-1 (9-73)
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