EPA-450/3-75-015 APRIL 1975 IMPLEMENTATION PLAN REVIEW FOR VERMONT AS REQUIRED BY THE ENERGY SUPPLY AND ENVIRONMENTAL COORDINATION ACT U. S. ENVIRONMENTAL PROTECTION AGENCY ------- EPA-450/3-75-015 IMPLEMENTATION PLAN REVIEW FOR VERMONT AS REQUIRED BY THE ENERGY SUPPLY AND ENVIRONMENTAL COORDINATION ACT PREPARED BY THE FOLLOWING TASK FORCE: U. S. Environmental Protection Agency, Region I J. F. Kennedy Federal Building Boston, Massachusetts 02203 Environmental Services of TRW, Inc. 800 Foil in Lane, SE, Vienna, Virginia 22180 (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 April 1975 ------- VERMONT ENERGY SUPPLY AND ENVIRONMENTAL COORDINATION ACT (SECTION IV - STATE IMPLEMENTATION PLAN REVIEW) Table of Contents Page 1.0 EXECUTIVE SUMMARY 1 2.0 STATE IMPLEMENTATION PLAN REVIEW 5 2.1 Summary 5 2.2 Air Quality Setting State of Vermont 9 2.3 Background on the Development of the Current State Implementation Plan 9 3.0 AQCR ASSESSMENTS BASED ON SIP REVIEW 11 3.1 Champlain Valley Interstate - AQCR 159 11 3.2 Vermont Intrastate - AQCR 221 13 APPENDIX A - STATE IMPLEMENTATION PLAN BACKGROUND APPENDIX B - REGIONAL AIR QUALITY SUMMARY APPENDIX C - POWER PLANT SUMMARY APPENDIX D - INDUSTRIAL, COMMERCIAL/INSTITUTIONAL SOURCE SUMMARY APPENDIX E - FUEL USE SUMMARY ------- 1.0 EXECUTIVE SUMMARY The enclosed report is the U.S. Environmental Protection Agency's (EPA) response to Section IV of the Energy Supply and Environmental Coordination Act of 1974 (ESECA). Section IV requires EPA to review each State Implemen- tation Plan (SIP) to determine if revisions can be made to control regula- tions for stationary fuel combustion sources without interfering with the attainment and maintenance of the National Ambient Air Quality Standards (NAAQS). In addition to requiring that EPA report to the State on whether control regulations might be revised, ESECA provides that EPA must approve or disapprove any revised regulations relating to fuel burning stationary sources within three months after they are submitted to EPA by the States. The States may, as in the Clean Air Act of 1970, initiate State Implementa- tion Plan revisions; ESECA does not, however, require States to change any existing plan. Congress has intended that this report provide the State with informa- tion 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. Hhere an indication can be found that emissions from certain fuel burning sources can be increased and still attain and maintain NAAQS, it may be plausible that fuel resource allocations can be altered for "clean fuel savings" in a manner consistent with both environmental and national energy needs. In many respects, the ESECA SIP reviews parallel EPA's policy on clean fuels. The Clean Fuels Policy has consisted of reviewing 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 S02 emission regulations, The States have also been asked to discourage large scale shifts from coal to oil where this could be done without jeopardizing the attainment and maintenance of the NAAQS. ------- To date, EPA's fuels policy has addressed only those States with the largest clean fuels saving potential. Several of these States have or are currently in the process of revising S02 regulations. These States are generally in the Eastern half of the United States. ESECA, however, extends the analysis of potentially over-restrictive regulations to all 55 States and territories. In addition, the current reviews address the attainment and maintenance of all the National Ambient Air Quality Standards. There are, in general, three predominant reasons for the existence of overly restrictive emission limitations within the State Implementation Plans. These are (1) The use of the example region approach in developing State-wide air quality control strategies;. (2) the existence of State Air Quality Standards which are more stringent than NAAQS; and (3) the "hot spots" in only part of an Air Quality Control Region (AQCR) which have been used as the basis for controlling the entire region. Since each of these 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 (AQCR) and adopt control regulations which would be adequate to attain the NAAQS in that region. In using an example region, it was assumed that NAAQS would be attained in the other AQCR's of the State if the control regulations were applied to similar sources. The problem with the use of an example region is that it can 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 result in a regulation requiring 1 percent sulfur oil to be burned state-wide where the use of 3 percent sulfur coal would be adequate to attain NAAQS in some locations. ------- 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 limi- tations. The findings of this report are by no means conclusive and are neither intended non adequate to be the sole basis for SIP revisions; they. do, however, represent EPA's best judgment and effort in complying with the ESECA requirements. The time and resources which EPA has had to pre- pare the reports has not permitted the consideration of growth, economics, and control strategy tradeoffs. Also, there have been only limited disper- sion modeling data available by which to address individual point source emissions. Where the modeling data for specific sources were found, how- ever, they were used in the analysis. The data upon which the reports' findings are based are the most currently available to the Federal Government. However, EPA believes that the States possess the best information for developing revised plans. The States have the most up-to-date air quality and emissions data, a better feel for growth, and the fullest understanding for the complex problems facing them in the attainment and maintenance of air quality. 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 indus- trial 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, NOX, and HC emissions which occur in fuel switching, and other potential air pollution situations such as sulfates. Although the enclosed analysis has attempted to address the attainment of all the NAAQS, most of the review has focused on total suspended particu- late matter (TSP) and sulfur dioxide (S02) emissions. This is because sta- tionary fuel combustion sources constitute the greatest source of S02 emissions and are a major source of TSP emissions. ------- Part of each State's review was organized to provide an analysis of the S02 and TSP emission tolerances within each of the various AQCR's. The regional emission tolerance estimate is, in many cases, EPA's only measure of the "over-cleaning" accomplished by a SIP. The tolerance assessments have been combined in Section 2 and 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 Appendices C, D, and E. The State of Vermont's State Implementation Plan has been reviewed for the most prevalent causes of over-restrictive fuel combustion emis- sion limiting regulations. The major findings of the review are: FOR TOTAL SUSPENDED PARTICIPATES. THERE ARE NO AQCR'S WHICH INDICATE ANY POTENTIAL FOR REVISING FUEL COMBUSTION SOURCE EMISSION LIMITING REGULATIONS FOR S02, THE CHAMPLAIN VALLEY INTERSTATE AQCR IS RATED AS A POOR CAWDATE FOR REVISING EMISSION REGULATIONS, WHILE THE VERMONT INTRASTATE AQCR IS RATED MARGINAL FOR REGULATION REVISION. The supportive findings of the SIP review are as follows: National Ambient Air Quality Standards for total suspended particulates were exceeded in both of the Vermont AQCRs during 1973. Sulfur dioxide levels during 1973 did not exceed standards in either of the two AQCRs. However in 1974, the 24-hour standard was exceeded in the Champ lain Valley Interstate AQCR. More air quality data for sulfur dioxide are needed in the Vermont Intrastate AQCR as there was only one monitoring station reporting data for 1973. It is possible that additional clean fuel savings could be realized in this region, if more was known about the air quality status. ------- 2.0 STATE IMPLEMENTATION PLAN REVIEW 2.1 SUMMARY A revision of fuel combustion source emissions regulations will depend on many factors. For example: t Does the State have air quality standards which are more stringent than NAAQS? t Does the State have emission limitation regulations for control of (1) power plants, (2) industrial sources, (3) area sources? Did the State use an example region approach for demonstrating the attainment of NAAQS or_ more stringent State standards. Has the State not initiated action to modify combustion source emission regulations for fuel savings; i.e., under the Clean Fuels Policy? Are there no proposed Air Quality Maintenance Areas? Are there indications of a sufficient number of monitoring sites within a region? Is there an expected 1975 attainment date for NAAQS? Based on (1973) air quality data, are there no reported violations of NAAQS? Based on (1973) air quality data, are there indications of a toler- ance for increasing emissions? Are the total emissions from stationary fuel combustion sources proportionally lower than those of other sources? Is there a significant clean fuels savings potential in the region? Do modeling results for specific fuel combustion sources show a potential for a regulation revision? The following portion of this report is directed at answering these questions. An AQCR's potential for revising regulations increases when there are affirmative responses to the above. The initial part of the SIP review report, Section 2 and Appendix A, was organized to provide the background and current situation information for the State Implementation Plan. Section 3 and the remaining Appendices ------- provide an AQCR analysis which helps establish the overall potential for revising regulations. Emission tolerance estimates have been combined in Appendix B with other regional air quality "indicators" in an attempt to provide an evaluation of a region's candidacy for revising emission limiting regulations. In conjunction with the regional analysis, a characterization of the State's fuel combustion sources (power plants, industrial sources, and area sources) has been carried out in Appendices C, D, E. Based on an overall evaluation of EPA's current information, AQCR's have been classified as good, marginal, or poor candidates for regulation revisions. Table 2-1 summarizes the State Implementation Plan Review. The remaining portion of the report supports this summary with explanations. The main factor in determining the candidacy for regulation revi- sion is the air quality status. Any AQCR which has an air quality vio- lation is automatically given a poor rating. On the other hand, a re- gion with no air quality violations, no AQMA designations, low to mode- rate emissions, along with a small percentage of emissions from fuel combustion sources, would receive a good rating. Those AQCR's that have varying indicators would need further evaluation and would be gi- ven a marginal rating. ------- TABLE 2-1 STATE IMPLEMENTATION PLAN REVIEW (SUMMARY) "Indicators" State TSP SO Champ'lain Valley Vermont AQCR 159 AQCR 221 Does the State have air quality standards which are more stringent than NAAQS? Does the State have emission limiting regulations for control of: I. Power plants 2. Industrial sources 3. Area sources Did the State use an example region approach for demonstrating the attainment of NAAQS or more stringent State standards? Has the State not initiated action to modify combustion source emission regulations for fuel savings; i.e., under the Clean Fuels Policy? Are there JTO proposed Air Quality Maintenance Areas? Are there indications of a sufficient number of monitoring sites within a region? Is there an expected 1975 attainment date for NAAQS? Based on (1973) Air Quality Data, are there no reported violations of NAAQS? Based on (1973) Air Quality Data, are there indications of a tolerance for increasing emissions? Are the total emissions from stationary fuel combustion sources proportionally lower than those of other sources? Do modeling results for specific fuel combustion sources show a potential for a regulation revision? Based on the above indicators, what is the poten- tial for revising fuel combustion source emission limiting regulations? Is there a significant Clean Fuels Saving potential in the region? TSP SO; Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes No No TSP SO; Yes Yes Yes No No Yes N.A. Yes Yes Yes Noa No Yes N.A. Yes Yes Yes No No Yes N.A. Yes No Yes Yes Yes No N.A Poor Poor Poor Marg. No Yes Violation occurred in 1974. ------- CHAMPLAIN VALLEY INTERSTATE (NEW YORK- VERMONT) VERMONT INTRASTATE (REMAINING AREA) Figure 2-1 Vermont Air Quality Control Regions ------- 2.2 AIR QUALITY SETTING -- STATE OF VERMONT The State of Vermont is divided into two AQCR's. These are AQCR 159, Champ!ain Valley Interstate AQCR (Vermont and New York) and containing the counties of Addison, Chittenden, Franklin, Grand Isle and Rutland in Vermont; and AQCR 221, Vermont Intrastate AQCR containing the remaining counties in the State of Vermont. A summary of the Federal and Vermont air quality standards for particu- late, S02 and N02 are presented in Table A-3. It should be noted that the standards adopted by the State of Vermont are more stringent than the respec- tive Federal standards in all cases except N02, where none were adopted. Air quality data for 1973 are summarized in Tables A-4 and A-5 for suspended particulates and sulfur dioxide respectively. These data are from the SAROAD data bank as of July, 1974. During 1973, the National Ambient Air Quality Standards were exceeded in the Champlain Valley Interstate AQCR for total suspended particulates. Sulfur dioxide levels in this AQCR did not exceed standards in 1973 but did in 1974. In the Vermont Intrastate AQCR, ambient levels of suspended particu- lates exceeded Federal standards during 1973. There were no violations of the sulfur dioxide standards. 2.3 BACKGROUND ON THE DEVELOPMENT OF THE CURRENT STATE IMPLEMENTATION PLAN The State of Vermont Implementation Plan contains control strategies and regulations for both particulate and sulfur dioxide emissions which will be adequate to attain National Ambient Air Quality Standards. EPA did not have to promulgate any regulations for the State of Vermont. The State regulations for the control of particulate matter include emission restrictions on fuel burning equipment. The regulation is variable depending on the heat input of the equipment, and whether the equipment is ------- new or existing. Regulations limit, visible emissions from existing facil- ities to Ringelmann No. 2, except for 6 minutes in any hour which may be as high as Ringelmann 3. New facilities are limited to Ringelmann No. 1, except that 6 minutes in any hour may be as high as No. 3. On September 10, 1974, the Vermont Agency of Environmental Conserva- tion held a public hearing concerning proposed revisions of the State's regulations concerning air pollution control. One of the proposed revisions was a change in the allowable particulate emission for fuel burning equip- ment rated over 1000 million BTU/hour heat input from 0.02 to 0.06 pounds per hour per million BTU heat input. This revision has been adopted by the State of Vermont, but has not been submitted to EPA for approval as yet. 10 ------- 3.0 AQCR ASSESSMENTS BASED ON SIP REVIEWS The purpose of this section is to evaluate the available information for the State of Vermont and determine the feasibility of revisions to the SIP which would result in clean fuel conservation. The assessments will be made by AQCR addressing each type of fuel combustion source: power plants, large industrial and commercial/institutional sources, and area sources. The assessments must be made for each pollutant separately and are made on the basis of seven criteria: (1) 1973 air quality violations; (2) expected NAAQS attainment dates; (3) proposed Air Quality Maintenance Area (AQMA) designations; (4) total emissions; (5) portion of emissions from Vermont fuel combustion sources; (6) regional tolerance for emissions increase; and (7) pollutant priority classifications. Tables B-l and B-2 tabulate these criteria for each AQCR for TSP and S02» respectively. The AQCR's are grouped into good, marginal, and poor candidates for regulation relaxation based on the evaluation of all the presented informa- tion. Using available data, any AQCR which displays a 1973 air quality vio- lation would probably be given a poor ranking. Conversely, a region with no violations, no proposed AQMA designations, low to moderate emissions, a positive emission tolerance, and/or a small fraction of emissions from Vermont fuel combustion sources would receive a good ranking. All other regions with varying indicators or incomplete or missing data would be evalu- ated separately and grouped in the appropriate class, most likely a marginal ranking. The source type groups are evaluated separately using such variables for criteria as modeling results, emissions data from the SIP and/or NEDS, and air quality data. 3.1 CHAMPLAIN VALLEY INTERSTATE AQCR 159 3.1.1 Regional Air Quality Assessment Air quality monitoring in 1973 in the Champ! ain Valley Interstate AQCR indicated a reduction in TSP will be required to meet the standards. As indicated by other factors in Table B-l, a poor candidate ranking for possible TSP emission regulation relaxation was assigned. 11 . ------- This AQCR is also ranked as a poor candidate for modification of S0? regulations because of an air quality violation which occurred during 1974. Another factor is the high percentage of emissions from Vermont fuel combustion sources. (Table A-6) 3.1.2 Power Plant Assessment Located in the Vermont portion of this AQCR is one 70 megawatt power plant at Burlington. This plant burns 0.98 percent sulfur bituminous coal in three boilers and 0.45 percent sulfur distillate oil in two gas turbines. These turbines have a combined generating capacity of 40 megawatts. No modeling data are available for the plant, and, therefore, it is very dif- ficult to evaluate the impact of increased emissions on the local air qua- lity. It is recommended that modeling be accomplished and the results analyzed prior to any decision to increase emissions. Located at Milton, is a very small power plant of 4 megawatts burning 1.48 percent sulfur residual oil in two boilers and using 0.30 percent sulfur distillate oil for purging. As indicated in Table C-l, power plant sub-stations with diesel generators and gas turbines are included, however, no operating capacity information is available. The plants located at St. Albans, Vergennes and Essex Junction use 0.20 to 0.23 percent sulfur distillate oil for their diesel generators, and also included at the Essex Junction station are two boilers which burn the same distillate oil. Gas turbines using 0.20 percent sulfur distillate oil are located at Rutland and Col- chester. 3.1.3 Industrial and Commercial/Institutional Source Assessment There are no significant fuel combustion particulate sources, and five SOp sources in this category. They contribute five percent of the Vermont portion of the particulate emissions, and one-fifth of the S02. Since both particulate and sulfur dioxide standards were exceeded in this region, there is little potential for allowing an increase in emissions for these sources. 12 ------- 3.1.4 Area Source Assessment Area sources account for about 24 percent of the region's TSP emissions and 78 percent of the SOp emissions. As with the industrial sources, there is no apparent tolerance to increase TSP or S02 emissions. 3.2 VERMONT INTRASTATE - AQCR 221 3.2.1 Regional Air Quality Assessment This region received a poor rating for particulate and a marginal rating for S02 regulation modification. The poor rating for particulates was based primarily on the violation of air quality standards and no tolerance for emission increase. In the case of S02> it was rated margi- nal since there was only one monitoring site providing air quality data. There were no violations at this site during 1973. 3.2.2 Power Plant Assessment There are no power plants located in this AQCR. However, there is one small power substation located in Ascutney. This is a gas turbine burning 0.17 percent sulfur distillate oil. 3.2.3 Industrial and Commercial/Institutional Source Assessment Emissions from significant sources in this category comprise about one-fifth of the regional particulate and about one-third of S02 emissions. Although, there are only two particulate significant source emitters in this region, any relaxation of fuel combustion emission limiting regulations would increase emissions in an already critical area. As stated in Section 3.2.1 for S02, again, no detailed assessment of the regulation modification potential can be made at this time due to limited air quality data. 3.2.4 Area Source Assessment Area sources account for about 10 percent of the region's TSP emissions and 60 percent of the S02 emissions. As with the industrial sources, there is no apparent tolerance to increase emissions for TSP. S02 in this category is the same as that explained in Section 3.2.1. 13 ------- 14 ------- APPENDIX A STATE IMPLEMENTATION PLAN BACKGROUND ------- TABLE A-1 VERMONT AQCR PRIORITY CLASSIFICATION AND AQMA'S AQCR Priority Proposed AQCR Name Champ lain Valley Vermont (Remainder) Number 159C 221 Part II II S0x II II rupu i diiuii 1975& 615,000 253,000 TSP Counties None None SOV Counties None None Criteria based on maximum (or estimated) pollution concentration in area: Priority Sulfur oxide: Annual arithmetic mean 24 - hour maximum Parti culate matter: Annual geometric mean 24 - hour maximum I Greater than yg/m3 100 455 95 325 II From - To yg/m3 60-100 260-455 60-95 150-325 III Less Than yg/m3 60 260 60 150 b Projections of Economic Activity for Air Quality Control Regions," U.S. Department of Commerce, Bureau of Economic Analysis, August 1973 Interstate region ------- TABLE A-2 ATTAINMENT DATES AQCR Champlain Vermont Name Valley AQCR No. 159a 221 TSP Attainment Dates Primary Secondary 7/75 7/75 7/75 7/75 S02 Attainment Dates Primary Secondary 7/75 7/75 7/75 7/75 (Remainder) a Interstate region ------- TABLE A-3 VERMONT AMBIENT AIR QUALITY STANDARDS All concentrations in Total Suspended Particulate Sulfur Oxides Nitrogen Dioxide Federal (Nov. 1972) State Primary Secondary Annual 75(6) 60(6)' 45(6) 24-Hour 260 a 150a 125a Annual 80(A) 57(A) 24-Hour 365a 150a 3-Hour 1300a 1-Hour 285a Annual 100(A) 100(A) a Not to "be exceeded more than once per year. (A) Arithmetic Mean (G) Geometric Mean ------- TABLE A-4 VERMONT AQCR AIR QUALITY STATUS, 1973 TSPd TSP Concentration (ygm/m3) Number of Stations Violating Ambient Air Quality Standards AQCR Name Champlain Valley Vermont Portion New York Portion Vermont (Remainder) a 1973 air quality Interstate c Violations based d r ^ Formula: / AQCR No. 159b 221 data in on 2nd No. Stations Reporting 4 14 3 Highest Reading 2nd Highest Reading Primary Secondary a _.,.....,.... n. ..,_ ,4 Annual 102 56 50 National Air Data Bank as highest reading 24-Hr 24-Hr 212 181 262 211 202 165 of July 28, 1974. Annual 24-Hrc Annual % 24-Hrc % to Meet Standardsd 1 0 2 50 3 75 +58 0 1 -0 3 21 +34 0 0 0 ~ 2 67 +11 at any station \ / \ [2nd Highest 24 Hr - 24-Hr Secondary Standard) 1nn [Annual - Annual Secondary Standard ) inn \ 2nd Highest 24-Hr - Background / x 1UU \ Annual - Background / ------- TABLE A-5 VERMONT AQCR AIR QUALITY STATUS, 1973 S02 SC>2 Concentration (ygm/m3) Number of Stations Exceeding Ambient Air Quality Standards AQCR No. AQCR Name No. Champlain 159b Valley Vermont Portion New York Portion Vermont 221 (Remainder) Station 24-Hr 2 2 0 SRronrtinn Highest Reading 2nd Highest Reading Primary Secondary _.,.....,.,__ .._._, Cont. Annual 24-Hr 24-Hr 2 NA 461 e 453e 1 35 208 96 1 37 117 107 Annual % 24-Hrc % 3-Hrc % to Meet Standards'1 - 1 50 0 - +19 0 - 0 0 - f 0 - 0 0 - f a 1973 air quality data in National Air Data Bank as of duly 28, 1974. b Interstate c Violations based on 2nd Formula: , (2nd Highest highest 24-Hr - reading at any station \ / \ 24-Hr Standard) lnn [Annual - Annual Standard] .. ,, in 2nd Highest 24-Hr 1974 data from the State of Vermont No reduction required Annual ------- TABLE A-6 VERMONT FUEL COMBUSTION SOURCE SUMMARY Other Fuel Combustion Total Emissions % Emissions From Vermont AQCR Name Champlaifi Valley Vermont (Remainder) AQCR No. 159e 221 Plants3 7 1 TSP of 2f S02 5f 9f Sourcesc 5 9 TSP 9.69 9.6 SO? 16.53 10.9 TSP 24 22 S02 49h 94 Vermont power plants only Vermont industrial and commercial/institutional sources in addition to power plants c Full counties, partial counties and towns, Vermont only d AQCR total e Interstate region All significant point sources, when combined with power plants, contribute Lass than point sources ^ No data available for point sources within the New York portion of Champlain Valley (AQCR 159) 93% of these emissions are from Vermont fuel burning sources of the total emissions from fuel combustion ------- TABLE A-7 VERMONT EMISSIONS SUMMARY, TSP AQCR Name AQCR No. Champlain Valley 159 Vermont Portion N.Y. Portion Vermont 221 (Remainder) Total Tons/Year 9,550C 6,444 3,5063 9,635 Percent Fuel Combustion 39C 35a 42a 22 Electricity Generation Point Sources Tons/Year %b 1147° 12C 1147 18a Oc 8 <1 Other Point Source Fuel Combustion Tons/Year 331 c 331 Oc 1,070 %b 3 5a 11 Area Source Fuel Combustion Tons/Year 2,271 811 1,460 1,010 %b 24 42a 10 Percentage based only on the portion within the indicated state Percentage of total emissions c No data available in NEDS for point sources contained in New York portion of Champlain Valley AQCR (159) ------- TABLE A-8 VERMONT EMISSIONS SUMMARY, S02 AQCR Name Champlain VaJley Vermont Portion fJ.Y. Portion Vermont (Remainder) AQCR No. 159 221 Total Tons/Year 16.455C 8,632 7,832C 10,935 Percent Fuel Combustion 93 93a 92a 94 E 1 ectri ci ty Gener ati on Point Sources Tons/Year %b 698C 4 698 8a Oc 7 <] Other Point Source Fuel Combustion Tons/Year 1 ,74C 1 ,764 Oc 3,702 rb 10 11 20a 34 Area Source Fuel Combustion Tons/Year 12,791 5,561 7,230 6,569 _^ 78 64a 92a 60 Percentage based only on the portion within the indicated state. Percentage of total emissions c No data available in NEDS for point sources contained tn New York portion of Champlain Valley AQCR ------- TABLE A-9 VERMONT PARTICULATE EMISSION REGULATION FOR FUEL COMBUSTION Maximum Allowable Heat Input^ Existing Proposed <10 0.5 <300 As determined by Fig. A-l >300 0.1 >1000C 0.02 0.06 a 106 BTU/hr b lb/hr/106 BTU of heat input c Applies to installations constructed after July 1, 1971 Adopted by the State of Vermont, but not submitted to EPA for approval. ------- 1.00. 0.50 -. Z 0.40 . 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"~ 1 1 -p i .0 I-, -^ ^=~ -HT --fij 1 j 1 ;n. :... :;!.;:. ^ :: T;- 'K ill *!- i-: ';"" -.. r:.. ..:) pp in --4:1:1- -jrf 1 iSl IK. j ^>^. h- irh 1- T i -f ' ,,,: r Tl r" MT 4 '< Hi: »-: - -! ^T -nl ^t i! s i | !;:;! ^ f 4- -f : ; t: ri ~ 1: ~ T -1- u-Lf LI - 1 ~ ^ t - -r M ~r 4 i r 1> ----- ^ 4.J- -T »- : ..: : r^tii.; "ts^rri::-:: W -": -_;:. .1: :-,:::[:::: :_u^I|._U4. r -Hi; - 1 1 i 1 1 I"-' rn.: .... 4; '*;: , ; |r:,:f.,: j:-- L-JT- fl'i -^it "7 ti-- IP- t - L ^ r 1 -- ... j... :! -7.3^ :rrh V, r 1 ±j E: :;:: . ; i * ^ J!! -J^: rt.: "TT1 H !; !lj: 'i {- E! ;;:. >'; ;;:' ii- IP; ^ -t- .-. ^ - + - r! -- - i -1 .1.. 1 < i t t 4 j -i i i -t ; I 1 I i 1 1 II 100.0 100C TOTAL ENERGY INPUT mil lions of BTU'y/hour Figure A-l FUEL BURNING EQUIPMENT ------- TABLE A-10 VERMONT SULFUR-IN-FUELS REGULATION Sulfur Content (% by WT) Existing9 Proposed 1.0 1.5b 2.5C a Effective October 1, 1974 Submitted to EPA for approval c Use determined by unavailability of fuels of 1.5% sulfur, refer to proposed revisions to the State of Vermont Air Pollution Control Regulations, Section 5-221(C) of Chapter 5 ------- APPENDIX B REGIONAL AIR QUALITY SUMMARY ------- TABLE B-1 REGIONAL INDICATORS FOR REVISION OF TSP REGULATIONS AQCR Name Champlain Valley Vermont (Remainder) AQCR No. 159a 221 No. of Stations Violating Reporting Standards 18 3 3 1 Expected Attainment Date 7/75 7/75 Any Proposed AQMA Designations? No . No Total Emissions (103 Tons/Year) 9.6 9.6 % Emission From Vt. Fuel Combustion 24 22 Percent Tolerance For Emissions Increase -58 - 4 a Interstate region ------- TABLE B-2 REGIONAL INDICATORS FOR REVISION OF S02 REGULATIONS AQCR Name Champlain Valley Vermont (Remainder) AQCR No. 159a 221 No. of Reporting 7 1 Stations Violating Standards 1 0 Expected Attainment Date 7/75 7/75 Any Proposed AQMA Designations? No No Total Emissions (1Q3 Tons/Year) 16.5 10.9 % Emission From Vt. Fuel Combustion 49 94 Percent Tolerance For Emissions Increase -19 +241 a Interstate region Calculations based on readings occurring at Glens Falls, N.Y. ------- APPENDIX C POWER PLANT SUMMARY ------- TABLE C-l EXISTING VERMONT POWER PLANTS -AQCR Name- AQCR No. Plant Name Champlain Valley 159 Burlington Elec. Lt. Dept. (Chitenden) Milton Steam Plant (Chitenden) Grn. Mtn. Pwr-Essex #19 (Chitenden) Grn. Mtn. Pwr-Col Chester #16 (Chitenden) Grn. Mtn. Pwr-Vergennes #9 (Addison) St. Albans Diesel Plant (Franklin) Rutland Gas Turbined (Rutland) 1975 Capaci ty Mwa 70 4 NA NA NA MA NA Fuel Type Coal Oil NG Oil Oil Oil Oil Oil Oil 1972 Quantity" 33,000 1,713 591 697 296 743 462 148 -1,170 .% S by _ Regulation^ 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 Boiler Also Designed For Coal Yes No Yes No No No No No No Vermont (Remainder) 221 Ascutney Gas Turbine (Windsor) NA Oil 929 1.0 tto Source: Steam Electric Plant Factors, 1973 Edition, National Coal Assn., Washington, D.C. b Coal in 103 tons, oil in 103 gal. NEDS data. [+ Regulation approved by State, but still awaiting EPA approval. Gas turbine plant. NA - Not Available ------- APPENDIX D INDUSTRIAL,COMMERCIAL/INSTITUTIONAL SOURCE SUMMARY ------- TABLE D-l VERMONT SIGNIFICANT SOURCES9 Reduction Under Particu?- NEDS Emissions Existing Regulations r . culai-I: (T/vr) h/vr) Emissions v'/yn ^L/in From Coa15 (before regulations) 33 AQCR Name Champ lain Valley Vermont (Remainder) AQCR No. 159 221 Part. 0 421 976 2296 Part. 0 +333 S02 - 33 +326 a See Table A-6 Only for significant sources not including power plants. ------- TABLE D-2 VERMONT SIGNIFICANT INDUSTRIAL AND COMMERCIAL/INSTITUTIONAL SOURCES Particulate SO? AQCR Name Champlain Valley AQCR No. 159 Plant Name County Vermont (Remainder) 221 Ethan Allen, Inc. Essex Plant Name White Pigment Co. Missisquoi SP Board Div. Univ. of Vermont Medical Center, Mary Fletcher Unit Middleburg College Pownal Tanning Co. Rygate Paper Mill Whitefield Paper Co. Yankee Milk Co. H.P. Hood & Co. Norwich University Vermont State Hosp. Boise Cascade Goodyear Tire & Rubber County Rutland Franklin Chitenden Chitenden Addison Bennington Caledonia Essex Orleans Orleans Washington' Washington Windham Windsor ------- APPENDIX E FUEL USE SUMMARY ------- TABLE E-l FUEL USE SUMMARY' AQCR Name Champ!ain Valley Area Sources Point Sources Total Vermont (Remainder) Area Sources Point Sources Total Coal (IP3 Tons) Anthracite Bituminous 9430 0 9430 Oil (IP3 Barrels) Residual Distillate 3180 2075 5255 0 602 602 2685 218 2903 Gas (106 Cu.Ft.) Natural Process 19.8 0 19.8 3.0 33.5 36.5 695 309 1004 5470 204 5674 5940 1986 7926 0 0 0 2010 0 2010 0 0 0 Source: Stationary Source Fuel Summary Report NEDS. November 1972. ------- TECHNICAL REPORT DATA (Please read Instructions on the reverse before completing) 1. REPORT NO. EPA-450/3-75-015 3. RECIPIENT'S ACCESSION-NO. 4. TITLE ANDSUBTITLE IMPLEMENTATION PLAN REVIEW FOR VERMONT AS REQUIRED BY THE ENERGY SUPPLY AND ENVIRONMENTAL COORDINATION ACT 5. REPORT DATE 6. PERFORMING ORGANIZATION CODE 7. AUTHOR(S) 8. PERFORMING ORGANIZATION REPORT NO. 9. PERFORMING ORGANIZATION NAME AND ADDRESS 10. PROGRAM ELEMENT NO. U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards, Research Triangle Park, N.C., Regional Office I, Boston, Mass., and TRW, Inc., Vienna, Virginia 11. CONTRACT/GRANT NO. 12. SPONSORING AGENCY NAME AND ADDRESS U.S. Environmental Protection Agency Office of Air and Waste Management Office of Air Quality Planning and Standards Research Triangle Park, North Carolina 27711 13. TYPE OF REPORT AND PERIOD COVERED Final 14. SPONSORING AGENCY CODE 15. SUPPLEMENTARY NOTES 16. ABSTRACT Section IV of the Energy Supply and Environmental Coordination Act of 1974, (ESECA) requires EPA to review each State Implementation Plan (SIP) to determine if revisions can be made to control regulations for stationary fuel combustion sources without interfering with the attainment and maintenance of the national ambient air quality standards. This document, which is also required by Section IV of ESECA, is EPA's report to the State indicating where regulations might be revised. 17. KEY WORDS AND DOCUMENT ANALYSIS DESCRIPTORS b.IDENTIFIERS/OPEN ENDED TERMS C. COSATI Field/Group Air pollution State Implementation Plans 13. DISTRIBUTION STATEMENT Release unlimited 19. SECURITY CLASS (This Report) Unclassified 21. NO. OF PAGES 38 20. SECURITY CLASS (Thispage) Unclassified 22. PRICE EPA Form 2220-1 (9-73) ------- |