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

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                                                          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

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                                 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

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                         1.0  EXECUTIVE SUMMARY

     The enclosed report is the U.S.  Environmental Protection Agency's (EPA)
response to Section IV of the Energy  Supply and Environmental Coordination
Act of 1974 (ESECA).  Section IV requires EPA to review each State 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.

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     To date, EPA's fuels policy has addressed only those States with the
largest clean fuels saving potential.  Several of these States have or are
currently in the process of revising S02 regulations.  These States are
generally in the Eastern half of the United States.  ESECA, however, extends
the analysis of potentially over-restrictive regulations to all 55 States
and territories.  In addition, the current reviews address the attainment
and maintenance of all the National Ambient Air Quality Standards.

     There are, in general, three predominant reasons for the existence of
overly restrictive emission limitations within the State 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.

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      EPA  anticipates  that a number of States will use the review findings
 to  assist them  in making the decision whether or not to revise portions of
 their State  Implementation Plans.  However, it is most important for those
 States which desire to submit a revised plan to recognize the review's 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.

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     Part of each State's review was organized to provide an analysis of
the S02 and TSP emission tolerances within each of the various AQCR's. The
regional emission tolerance estimate is, in many cases, EPA's only measure
of the "over-cleaning" accomplished by a SIP.  The tolerance assessments
have been combined in 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.

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                  2.0  STATE IMPLEMENTATION PLAN REVIEW


2.1  SUMMARY

     A revision of fuel combustion source emissions regulations will depend

on many factors.  For example:

     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

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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 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.

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                                           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.

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 CHAMPLAIN
 VALLEY
 INTERSTATE
 (NEW YORK-
 VERMONT)
                                         VERMONT
                                         INTRASTATE
                                         (REMAINING
                                           AREA)
Figure 2-1   Vermont  Air Quality  Control  Regions

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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

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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

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               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 .

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       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

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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

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14

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             APPENDIX  A



STATE IMPLEMENTATION PLAN BACKGROUND

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                                              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

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                             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

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                                           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

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                                       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        /

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                                                  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

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                                                                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

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                                                                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)

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                                                               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 ,7€4C
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

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                 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.

-------
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        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

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         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.

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    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

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                    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.

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                                   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)

-------