EPA-450/3-7 5-016
FEBRUARY 1975
IMPLEMENTATION PLAN REVIEW
FOR
VIRGINIA
AS REQUIRED
BY
THE ENERGY SUPPLY
AND
ENVIRONMENTAL COORDINATION ACT
U. S. ENVIRONMENTAL PROTECTION AGENCY
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EPA-450/3-75-016
IMPLEMENTATION PLAN REVIEW
FOR
VIRGINIA
AS REQUIRED BY THE ENERGY SUPPLY AND ENVIRONMENTAL COORDINATION ACT
Prepared by the Following Task Force:
U.S. Environmental Protection Agency, Region III
6th and Walnut Streets
Philadelphia, Pennsylvania 19106
Environmental Services of TRW, Inc.
800 Follin 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
February 1975
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VIRGINIA
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 7
2.1 Summary 7
2.2 Air Quality Setting - State of Virginia 12
2.3 Background on the Development of Virginia's
Current State Implementation Plan 14
3.0 CURRENT ASSESSMENTS BASED ON STATE IMPLEMENTATION
PLAN REVIEW 17
3.1 National Capital Interstate Air Quality Control
Region 18
3.2 Eastern Tennessee - Southwestern Virginia Air
Quality Control Region 19
3.3 Central Virginia Intrastate Air Quality
Control Region 21
3.4 Hampton Roads Intrastate Air Quality Control Region .... 22
3.5 Northeastern Virginia Intrastate Air Quality Control
Region 24
3.6 State Capital Intrastate Air Quality Control Region .... 25
3.7 Valley of Virginia Intrastate Air Quality Control
Region 26
APPENDIX A - STATE IMPLEMENTATION PLAN BACKGROUND 29
APPENDIX B - REGIONAL SUMMARY 41 ,
APPENDIX C - POWER PLANT SUMMARY 43
APPENDIX D - INDUSTRIAL, COMMERCIAL, INSTITUTIONAL SOURCE SUMMARY 47
APPENDIX E - AQCR FUEL USE SUMMARY 53
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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 Coor-
dination Act of 1974 (ESECA). Section IV required 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
(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.
Where an indication can be found that emissions from certain fuel burning
sources can be increased and still attain and maintain NAAQS, it may be
plausible that fuel resource allocations can be altered for "clean fuel
savings" in a manner consistent with both environmental and national energy
needs.
In many respects, the ESECA SIP reviews parallel EPA's policy on clean
fuels. The Clean Fuels Policy has consisted of reviewing 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 S0£ emission regula-
tions. The States have also been asked to discourage large scale shifts
from coal to oil where this could be done without jeopardizing the attain-
ment 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, four predominant reasons for the existence of
overly restrictive emission limitations within the State Implementation
Plans. These are (1) the state's prerogative to surpass NAAQS; (2) the use
of the example region approach in developing State-wide air quality control
strategies; (3) the existence of the state air quality standards which are
more stringent than NAAQS; and (4) the "hot spots" in only part of an Air
Quality Control Region (AQCR) which have been used as the basis for control-
ling the entire region. Since each of these situations effect 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 strin-
gent state air quality standards. Also, at that time an acceptable method
for formulating control strategies was the use of an example region for demon-
strating the attainment of the standards.
The example region concept permitted a State to identify the most pol-
luted 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 i< similar sources. The
problem with the use of an example region is that ic car result in controls
which are more stringent than needed to attain NAA 3, t penally in the util-
ization of clean fuels, for areas of the State whfre sources would not other-
wise contribute to NAAQS violations. For instance, a control strategy based
on a particular region or source can result in a regulation requiring 1 per-
cent sulfur oil to be burned state-wide where the use of 3 percent .jlfur
coal would be adequate to attain NAAQS in soms 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 nor adequate to be the sole basis for SIP revisions; they
do, however, represent EPA's best judgment and effort in complying with the
ESECA requirements. The time and resources which EPA has had to prepare
the reports has not permitted the consideration of growth, economics, and
control strategy tradeoffs. Also, there has been only limited dispersion
modeling data available by which to address individual point source emissions.
Where the modeling data for specific sources were found, however, they were
used in the analysis.
The data upon which the reports' findings are based are the most cur-
rently available to the Federal Government. However, EPA believes that the
States possess the best information for developing revised plans. The States
have the most up-to-date air quality and emissions data, a better feel for
growth, and the fullest understanding for the complex problems facing them
in the attainment and maintenance of 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 de-
veloping a suitable plan, it is suggested that States select control stra-
tegies 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, NOX,
and HC emissions which occur in fuel switching, and other potential air pol-
lution situations such as sulfates.
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Although the enclosed analysis has attempted to address the attain-
ment of all the NAAQS, most of the review has focused on total suspended par-
ticulate matter (TSP) and sulfur dioxide ($02) emissions. This is because
stationary fuel combustion sources constitute the greatest source of S02
emissions and are a major source of TSP emissions.
Part of each State's review was organized to provide an analysis of
the S02 and TSP emission 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 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 Implementation Plan for Virginia has been reviewed for the
most prevalent causes of over-restrictive fuel combustion limiting regulations.
The major findings of the review are:
FOR TOTAL SUSPENDED PARTICIPATES THERE ARE NO INDICATIONS THAT
EXISTING FUEL COMBUSTION SOURCE EMISSION LIMITING REGULATIONS ARE
OVER-RESTRICTIVE.
FOR SULFUR DIOXIDE THERE ARE INDICATIONS THAT EMISSION LIMITS MAY
BE RELAXED IN SOME AIR QUALITY CONTROL REGIONS WITHOUT EXCEEDING
NATIONAL AMBIENT AIR QUALITY STANDARDS.
The supportive findings of the SIP review are as follows:
Like many other areas of the nation, high le ^ls of total suspended
particulates were found in Virginia. National Ambient Air Quality
Standards were exceeded in each of the seven Air luality Control
Regions during 1973.
Air quality standards for sulfur dioxide we/e exceeded only in the
Eastern Tennessee-Southwestern Virginia AQCR while ambient levels
in the National Capital Interstate AQCR were close to the standards.
There is some potential for revising emission regulations,for "ulfur
dioxide in the Hampton Roads Air Quality Control Region which s
been found to be a good candidate for t^gulation revision.
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Marginal candidates for revision of S02 emission regulations are
the Northeastern Virginia and the Valley of Virginia Air Quality
Control Regions.
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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.
• 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 or_ more stringent State standards?
• Has the State not initiated action to modify combustion source emis-
sion regulations for fuel savings; i.e., under the Clean Fuels Policy?
t 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 in the State
Implementation Plan?
• Based on (1973) air quality data, are there no reported violations
o.f NAAQS?
t Based on (1973) air quality data, are there indications of a toler-
ance for increasing emissions?
t 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?
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.
Based on an overall evaluation of EPA's current information, AQCR's
have been rated as either a good, poor or marginal candidate for revising
emission limiting regulations. These ratings which are shown in Table 2-1
were determined by assessing the following criteria:
Good
1) Adequate number
of air monitoring
sites
2) No NAAQS violations
3) Attainment date of
1975 for NAAQS in
the SIP
4) No proposed AQMAs
5) Modeling results
show a potential
for regulation
revision
Poor
1) Violation of NAAQS 1)
2) Attainment date for
NAAQS later than
1975 2)
3) Proposed AQMA
4) Modeling results
show no potential
for regulation
revision
Marginal
No air quality data
or insufficient number
of monitoring sites
Inconsistent
"indicators"
For an AQCR to be rated as a good candidate, all of the criteria listed
under "Good" would have to be satisfied. The overriding factor in rating an
AQCR as a poor candidate is a violation of either the primary or secondary
National Ambient Air Quality Standards during 1973. However, if any of the
other conditions listed under "Poor" exists, the AQCR would still receive
that rating. The predominant reason for a marginal rating is a lack of suf-
ficient air quality data. In Priority III regions, air monitoring was not
required during 1973, therefore, there may be no data with which to determine
the current air quality status. Marginal ratings ar ; also given when there
are varying or inconsistent "indicators".
After a candidacy has been given to a region, . fo 'ow-up analysis should
be conducted depending on the rating. A region th .t has been indicated to be
a good candidate for regulation revision should be examined in more detail
by the state and the Regional office of th^ EPA including an exami ation of
current air quality, emissions, and fuel use data, with which the st te has
more familiarity. If the state feels that cltan fuels could be save, -'n a
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region rated marginal then an analysis of air quality data that may have
become available since this report should be examined. If current data do
not indicate a potential for regulation revision then further study would
not be warranted. An AQCR that has been indicated to be a poor candidate
would not warrant further study unless the state feels that new information
has become available indicating that the poor rating is no longer valid.
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TABLE 2-1
STATE IMPLEMENTATION PLAN REVIEW
(SUMMARY)
"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?
• Has the State not initiated action to modify
combustion source emission regulations for fuel
savings; i.e., under the Clean Fuels Policy?
• Are there np_ 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 in the State Implementation Plan?
• 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?
t 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?
TSP
No
Yes
Yes
Yes
State
. S02
Noa
Yes
Yes
Yes
National
Capital
AQCR 47
TSP S02
Eastern Tenn.-
Southwestern Va.
AQCR 207
TSP_ S0_2
Central
Virginia
AQCR 222
TSP S02
Hampton
Roads
AQCR 223
Northeastern
Virginia
AQCR 224
State
Capital .
AQCR 225
TSP
SO?
TSP_ S0_2 JIL
SO?
Yes
Yes
No
Yes
Valley of
Virginia
AQCR 226 t>
TSP
SO?
No
Yes
Yes
No
No
Yes
No
Yes
Yes
Yes
Yes
Yes
No
No
Yes
Yes
Yes
No
No
No
N.A.
Yes
Yes
Yes
Nob
No
No
N.A.
No
Yes
Yes
No
No
Yes
N.A.
Yes
Yes
Yes
Yes
Yes
No
N.A.
No
Yes
Yes
No
No
No
No
Yes
Yes
Yes
Yes
Yes
No
Yes
No
Yes
Yes
No
No
Yes
N.A.
Yes
Yes
Yes
Yes
Yes
No
N.A.
No
Yes
Yes
No
No
No
No
Yes
Yes
Yes
Yes
Yes
No
No
No
Yes
Yes
No
No
Yes
N.A.
Yes
Yes
Yes
Yes
Yes
No
N.A.
Poor Poor Poor Pcor Poor Marg. Poor Good Poor Marg. Poor Marg. Poor Marg.
a The State has adopted secondary standards for
b One station in Tennessee exceeded standards.
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EASTERN
TENNESSEE-
SOUTHWESTERN
VIRGINIA
INTERSTATE
(TENNESSEE
VIRGINIA)
VALLEY OF
VIRGINIA
INTRASTATE
NATIONAL
.CAPITAL
INTERSTATE
(WASHINGTON, D.C.-
MARYLAND-
WRGINIA)
NORTHEASTERN
VIRGINIA
lASTATE
CENTRAL
VIRGINIA
INTRASTATE
STATE
CAPITOL
INTRASTATE
HAMPTON
ROADS
INTRASTATE
Figure 2-1 VIRGINIA AIR QUALITY CONTROL REGIONS
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2.2 AIR QUALITY SETTING - STATE OF VIRGINIA
2.2.1 Virginia Air Pollution Control Areas
The State of Virginia has been divided into seven Air Quality Control
Regions (AQCR) as follows:
National Capital Interstate (District of Columbia, Maryland)
Eastern Tennessee-Southwestern Virginia Interstate (Tennessee)
Central Virginia Intrastate
Hampton Roads Intrastate
Northeastern Virginia Intrastate
State Capital Intrastate
Valley of Virginia Intrastate
These regions are also shown on Figure 2-1 and Table A-l, as well as the
priority classifications for total suspended particulates and sulfur dioxide,
an estimate of the 1975 population in each AQCR, and the counties and cities
that have been proposed as Air Quality Maintenance Areas (AQMA). There are
no AQMAs proposed for sulfur dioxide at this time.
2.2.2 Ambient Air Quality Standards
Virginia has adopted ambient air quality standards for suspended par-
ticulates and sulfur dioxide as shown on Table A-2. These standards duplicate
the Federal standards, except the State has. also adopted secondary annual and
24-hour standards for sulfur dioxide, which are identical to the primary
standard.
2.2.3 Virginia Air Quality Status
Air monitoring data for total suspended particulates and sulfur dioxide
for 1973 are summarized in Tables A-4 and A-5 respectively. These data are
from the SAROAD data bank as of July 1974. It shou1J be noted that not all
of the data collected by the state are necessarily -n the data bank.
Ambient air concentrations of total suspend d p? ticulates exceeded
standards in each of the seven Air Quality Contro1 Regions during 1973. Six
of the regions require a significant reduction in the 1973 levels to meet
air quality standards (Table A-4), while one, the Northeastern Vininia AQCR
requires a slight reduction. The highest annuJ geometric mean an., the highest
24-hour value were recorded in the Central Virginia AQCR. All of ti : regions
12
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are classified Priority I for particulates with the exception of the North-
Eastern Virginia AQCR which is classified Priority IA. There appear to be
a sufficient number of air monitors for suspended particulates in each of
the regions.
Ambient levels of sulfur dioxide are not as serious as particulates
which is encouraging from a clean fuels saving standpoint. The annual standard
was not exceeded in any AQCR during 1973, as the maximum annual arithmetic
average was 61 ng/m^» recorded in the State Capital AQCR. The 24-hour standard
was exceeded only in the Eastern Tennessee-Southwestern Virginia Interstate
AQCR. In the National Capital Interstate AQCR, a 24-hour reading recorded in
the District of Columbia was close to the Federal standard, while the Virginia
portion of the AQCR was below the standards. Air quality data for 1973 indi-
cate that except for the Eastern Tennessee-Southwestern Virginia AQCR, all of
the regions have a tolerance for an increase in ambient levels while still
maintaining standards. There is adequate sulfur dioxide monitoring in each
of the regions although monitoring was not required in Priority III regions
until two years after the approval of the State Implementation Plan.
2.2.4 Virginia Emissions Summary
A summary of particulate and sulfur dioxide emissions is presented in
Table A-7 and A-8 respectively. These data are from the 1972 National Emis-
sions Report, June 1974. This report utilizes information from the National
Emissions Data System (NEDS) and has some deficiencies for the purpose of this
report. Some of the information may be outdated, since the emissions inven-
tory was conducted before many sources installed emission control equipment,
and some sources have ceased operations since the inventory was completed.
Stationary source fuel combustion accounts for the majority of the
particulate emissions in only three of the Air Quality Control Regions. These
are the Eastern Tennessee-Southwestern Virginia, the Hampton Roads, and the
State Capital regions. Sulfur dioxide emissions from stationary fuel combus-
tion, on the other hand, are higher than from any other source. In all but
two regions, Central Virginia and the Valley of Virginia, electric power plants
contribute the majority of sulfur dioxide emissions. Any relaxation of the
13
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existing regulations for these sources may have a significant impact on air
quality.
Table A-6 lists the number of power plants in each AQCR and the number
of fuel combustion point sources within the state which together with the
power plants contribute 90% or a significant amount of the particulate and
sulfur dioxide emissions. This information was also taken from the NEDS
inventory. The table also shows the percent of the total regional particulate
and sulfur dioxide emissions that are due to Virginia fuel combustion sources.
2.3 BACKGROUND ON THE DEVELOPMENT OF VIRGINIA'S CURRENT STATE IMPLEMENTATION
PLAN
2.3.1 Control Strategy for Particulate Matter and Sulfur Oxides
Particulate Matter. Virginia's control strategy as submitted on
January 30, 1972, did not provide for attainment and maintenance of the pri-
mary and secondary standards ft ," participate matter in the State Capital Intra-
state Region and the secondary standards for particulate matter in the Hampton
Roads Intrastate Region and was recommended for disapproval. (Such disappro-
val was indicated in the May 31, 1972, Federal Register.)
Using the State Capital Region as an example region (except for the
National Capital Interstate Region), the statewide emission limitations, as
presented in the plan, were strategy-tested by IBM through the use of a pro-
portional model, and the results were presented in the plan. This model
predicted a maximum 1975 concentration of 60 ug/m3 (annual geometric mean).
Major errors, however, were found by the EPA plan manager. After corrections
were made, the control strategy was retested. The resulting proportional
model prediction at the maximum site was 88 ug/m3 af:sr application of the
Virginia emission limitations and 77 ug/m3 after application of reasonably
available control technology. This demonstrated thf .: th State's emission
limitations as adopted January 17, 1972, were inadequate and did not show
achievement of the primary standard by 1975. Since the EPA reviseo the emis-
sion inventory and observed that data were not available for all sources, the
State will be required to update and complete an emission inventory. Since
it was shown that the primary standards for particulate matter could La* attained'
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through application of emission limitations that require reasonably available
control technology, it was recommended that the Administrator propose such
limitations and provide an 18-month extension for submission of the plan to
attain and maintain secondary standards in this Region.
In the Hampton Roads Intrastate Region, EPA's calculations showed a
maximum of 64 yg/m3, after application of the Virginia emission limitations,
and 59 ug/m3, after application of reasonably available control technology.
Since the secondary standards for particulate matter could be met through
application of emission limitations requiring reasonably available control
technology, it was recommended that the Administrator propose such limita-
tions for the secondary standards and that Virginia's limitations be approved
for primary standards.
In the Eastern Tennessee-Southwestern Virginia Interstate Region
ambient air quality data did not indicate a need for emission reductions in
Virginia's portion of the Region.
On May 4, 1972, Virginia submitted a revised particulate matter emis-
sion inventory for the State Capital, Hampton Roads, Central and Northeastern
Intrastate Regions. Based on the revised emission inventory and calculations
performed for the Central and Northeastern Intrastate Regions, it was shown
that the national standards could be obtained by 1975 through application of
the Virginia emission limitations as adopted on January 17, 1972. In the
State Capital Region the adopted Virginia emission limitations were inadequate
to achieve the national standard by 1975 and reasonably available control
technology for fuel combustion sources and incinerators was recommended by
EPA for promulgation to attain the primary standards; however, the secondary
standard could not be attained and an 18 month extension was recommended. In
the Hampton Roads Region EPA's recommended emission limitations would attain
the primary and secondary standards by 1975. The State adopted statewide
reasonably available control technology for fuel combustion sources and incin-
erators on June 12, 1972, thereby meeting the requirements of 40CFR51.13.
Sulfur oxides. Virginia's ambient air quality data (1971) did not
indicate a need for emissions reductions for sulfur oxides in any Region
other than the National Capital Interstate (discussed in the next paragraph).
15
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Virginia's regulations pertinent to existing sources of this pollutant, and
the State's regulatory control of construction and modification of sources
provide adequate methods for insuring that ambient concentrations of sulfur
oxides remain below the national secondary standards.
A separate strategy for particulate matter and sulfur oxides for
Virginia's portion of the National Capital Interstate Region was submitted
on April 20, 1970. The EPA diffusion model predicted concentrations below
the secondary standard for parti cul ate matter and sulfur oxides in the Vir-
ginia portion of the Region. The Administrator approved Virginia's control
strategy in an August 4, 1971, letter to the Governor of Virginia and this
approval was finalized in the Federal Register on February 3, 1972, Vol. 37,
No. 23.
EPA and the State will continue to monitor the air quality readings
in the National Capital Interst'te Region to determine the accuracy of the
diffusion model predictions.
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3.0 CURRENT ASSESSMENTS BASED ON STATE IMPLEMENTATION PLAN REVIEW
The purpose of this section is to evaluate the available information
for the State of Virginia 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 sourc'e: 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) designa-
tions; (4) total emissions; (5) portion of emissions from Virginia fuel com-
bustion sources; (6) regional tolerance for emissions increase; and (7) pol-
lutant priority classifications. Tables B-l and B-2 tabulate these criteria
for each AQCR for TSP and S02, respectively.
Table C-l shows the 1973 fuel use and sulfur content of the fuel for
each power plant. The sulfur content is an average content for the year,
as variations of up to 20% are common. This information is from the Federal
Power Commission and was used in place of the NEDS data since it is more
current. Also shown in this table is the projected fuel use for 1975 for
each plant, and the sulfur content of the fuel as required by the State
Implementation Plan. Table C-2 is a summary of modeling results for power
plants in three AQCRs.1 Although it is realized that there are some limita-
tions to results obtained by modeling, it is presented in this report as
another indicator in assessing the candidacy of a region to revise emission
regulations.
Appendix D shows the fuel use and emissions data for the major fuel com-
bustion sources in each of the AQCRs that were listed in the NEDS inventory
as being the major emitters of particulates and sulfur dioxide. Appendix E
shows the total fuel use for each AQCR.
The modeling analysis of the power plants was performed by the Wai den
Research Division of Abcor, Inc. A single-source and valley model,
developed by the Meteorology Laboratory, EPA, was used. The model employs
a Gaussian plume model and Briggs plume rise equation. Comments on the
use of the model are included in Appendix C.
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3.1 NATIONAL CAPITAL INTERSTATE AIR QUALITY CONTROL REGION
3.1.1 Regional Assessment
Ambient air levels of total suspended particulates during 1973 exceeded
both the annual and 24-hour secondary standards in the Virginia portion of
this Air Quality Control Region as shown in Table A-4. This is a Priority I
region for'particulates and has several counties and cities that comprise a
proposed Air Quality Maintenance Area for this pollutant.
Sulfur dioxide levels during 1973 did not exceed either the annual or
24-hour standard (Table A-5). Although the data indicate a tolerance for
an increase in S02 emissions, relaxation of the emission limits is not recom-
mended since S02 levels in the District of Columbia portion of the AQCR
were close to the 24-hour standard. This is a Priority I region for this
pollutant and has no proposed AQMA's in Virginia, however, the District of
Columbia has been proposed as an AQMA.
3.1.2 Power Plant Assessment
There are two power plants which contribute 11% of the particulate
emissions and 86% of the sulfur dioxide emissions in the Virginia portion
of the AQCR. Both of these plants require a reduction in the fuel sulfur
content during 1973 in order to comply with SIP requirements (Table C-1).
The Potomac River plant in the City of Alexandria burned low sulfur coal
during 1973 (0.84%) and during the first quarter of 1974 (0.92%), however
0.69% sulfur content fuel is required. Although a clean fuel saving poten-
tial exists based on the fuel sulfur content, sulfur dioxide levels in this
region as previously mentioned were close to the 24-hour standard which
precludes a shift to higher sulfur coal.
The Possum Point plant in Prince William Cour cy has been burning high
sulfur content fuel for several years. During 197? the sulfur content of
the oil used at this plant averaged 2.26%, and 2.2'& du ing the first quarter
of 1974. A reduction to 1.04% sulfur content is required by the ZIP at this
plant. There are five generating units at this plant, four of which are con-
vertible to coal. This in itself represents a potential saving of significant
amount of oil, however ambient air levels of suspended particulates id sulfur
18
-------
dioxide in this region again precludes a fuel switch. Table C-2 shows the
results of modeling analysis for this plant and indicates that the emissions
from this plant alone are sufficient to cause violations of the 24-hour S02
standard under certain conditions. Suspended particulate levels would also
be adversely affected as indicated in the table. It is not recommended that
emission limiting regulations for either of these plants be relaxed because
of the existing air quality status.
3.1.3 Industrial, Commercial, Institutional Source Assessment
Major fuel combustion point sources contribute 7% of the particulate
emissions and 4% of the sulfur dioxide emissions in the Virginia portion of
this AQCR. The major sources of these pollutants as listed in the NEDS in-
ventory are shown in Table D-l. The fuels used by these sources consisted
of a maximum of 1% sulfur content for coal and 0.95% for oil. These data
are for the year of the NEDS emission inventory and may not be representative
of the current fuel use. As with power plants, a switch to higher sulfur
fuel or a switch from oil to coal is not feasible because of the air quality
status in this region.
3.1.4 Area Source Assessment
Area source fuel combustion accounts for 7% of both the particulate
and sulfur dioxide emissions in the Virginia portion of this AQCR. Fuel use
by area sources is shown in Table E-l. It is usually impractical for small
residential and commercial sources to switch from either gas or oil use to
coal because of the costs involved in changing combustion equipment. The
only fuel savings that can be normally achieved by these sources is a switch
to a higher sulfur fuel content, however, that is not feasible in this region
because of the existing sulfur dioxide levels.
3.1.5 Fuel Use Assessment
Fuel use by source category is shown in Appendix E.
3.2 EASTERN TENNESSEE-SOUTHWESTERN VIRGINIA INTERSTATE AIR QUALITY CONTROL
REGION
3.2.1 Regional Assessment
Total suspended particulate levels during 1973 exceeded both the annual
19
-------
and 24-hour secondary standards in this region. Although the highest and
second highest 24-hour values were recorded in the Tennessee portion of this
AQCR, the 24-hour secondary standard was violated in Virginia. This is a
Priority I region for particulates and has no proposed Air Quality Maintenance
Areas at this time for either particulates or sulfur dioxide. Ambient levels
of sulfur dioxide exceeded the 24-hour standard at one monitoring site in
Tennessee during 1973, while none of the stations in Virginia recorded vio-
lations. Based on the reading recorded in Tennessee, a significant reduction
in ambient levels is needed to meet air quality standards in this region
(Table A-5). This region is classified Priority I for sulfur dioxide and
1973 data indicate no potential for revising existing S02 emissions regula-
tions. Current air quality data for S02 should be examined to determine if
air quality standards are still being exceeded and if there is a tolerance
for an increase in S02 emissions in the Virginia portion of the AQCR without
jeopardizing the attainment of air quality standards.
3.2.2 Power Plant Assessment
There is one Virginia power plant in this region, the Clinch River
plant in Russell County, which accounts for approximately 39% of the particu-
late emissions, and 63% of the sulfur dioxide emissions in the Virginia por-
tion of the AQCR. During 1973, the average sulfur content of the fuel used
at this plant was 0.71%, while during the first quarter of 1974 it was 0.66%.
The SIP requires 1.58% sulfur at this plant, thereby affording a potential
clean fuel saving. However, as previously mentioned, sulfur dioxide levels
exceeded standards in this region and more detailed study is required.
3.2.3 Industrial, Commercial, Institutional Source Assessment
Major fuel combustion point sources contribui : 20% of the particulate
emissions and 17% of the sulfur dioxide emissions ir the Virginia portion of
the AQCR. The major sources of these pollutants as lis^ d in the NEDS inven-
tory are shown in Table D-l. These sources were bt rnino relatively clean fuels,
however, the quantity of fuel used is relatively low, thereby affording little
potential for a clean fuel savings.
20
-------
3.2.4 Area Source Assessment
Area source fuel combustion accounts for 4% of the particulate emis-
sions and 15% of the sulfur dioxide emissions in the Virginia portion of this
AQCR. Fuel use by area source category is shown in Table E-l.
3.2.5 Fuel Use Assessment
Fuel use by source category is shown in Appendix E.
3.3 CENTRAL VIRGINIA INTRASTATE AIR QUALITY CONTROL REGION
3.3.1 Regional Assessment
Ambient air levels of total suspended particulates exceeded the annual
and 24-hour secondary standards in this region during 1973 (Table A-4). This
region is classified Priority I for particulates and has one proposed Air
Quality Maintenance Area. The annual primary standard was exceeded at four
stations, while the primary 24-hour standard was exceeded at ten stations.
There is virtually no potential for relaxing existing particulate emission
regulations in this region.
Sulfur dioxide levels during 1973 did not exceed any standards in this
region and air quality data indicate that there is a tolerance for an increase
in ambient levels and still maintain standards. This region is classified
Priority III for sulfur dioxide and has no proposed AQMAs for this pollutant.
3.3.2 Power Plant Assessment
There is one power plant in this region, the Brantly plant in Danville.
There are no fuel use and emissions data in the NEDS inventory for this plant,
however, the quantity of fuel used for 1972 is available as shown in Table 2-1.
3.3.3 Industrial, Commercial, Institutional Source Assessment
Point source fuel combustion in this region accounts for 17% of the
particulate emissions and 63% of the sulfur dioxide emissions. There are
several point sources in this region which are listed in Table D-l. The
sulfur content of the coal used by these sources ranges from low to moderate
21
-------
(0.63% - 1.56%), while the oil has a higher sulfur content (1.36% - 2.6%).
Fuel use by these sources based on quantity and sulfur content affords little
potential for significant fuel savings, should relaxation of emission regu-
lations be considered.
3.3.4 Area Source Assessment
Area source fuel combustion accounts for 7% of the particulate emis-
sions and 30% of the sulfur dioxide emissions in this region. Area sources
account for less than 10% of the coal used in this region, but a substantial
proportion of the oil and natural gas used. There is some potential in this
region for saving clean fuels by increasing the sulfur content of the fuel
oils used by the area sources, although the savings will not be considerable.
3.3.5 Fuel Use Assessment
Fuel use by source category is shown in Appendix E. Again, clean fuel
savings in this region would be only moderate because of the quantity of fuel
used.
3.4 HAMPTON ROADS INTRASTATE AIR QUALITY CONTROL REGION
3.4.1 Regional Assessment
During 1973, ambient levels of total suspended particulates exceeded
both the annual and 24-hour standards. The annual secondary standard was
exceeded at eight of the twenty-two sampling stations while the 24-hour stand-
ard was exceeded at nine of the stations (Table A-4). This region is classi-
fied Priority I for parti culates and several cities have been proposed as
Air Quality Maintenance Areas for this pollutant.
Sulfur dioxide standards were not exceeded ir this region during 1973
and air quality data indicate that there is a toler mce for an increase in
the ambient levels while still maintaining air quality standards (Table A-5).
This region is classified Priority II for sulfur cioxide and has no proposed
AQMAs for this pollutant. There is some potential for S02 emission regulation
revision.
22
-------
3.4.2 Power Plant Assessment
There are three power plants in this AQCR contributing 30% of the par-
ticulate emissions and 70% of the sulfur dioxide emissions. Two of these
plants were multi-fuel users during 1973. The Reeves Avenue plant in Norfolk
burned coal and oil, while the Yorktown plant in York County burned coal, oil,
and gas (Table C-l). Both of these plants are projected to be using only oil
in 1975. The average sulfur content of the oil used by these plants during
1973 was 0.21% - 1.0% affording a potential clean fuel savings as these plants
have a projected fuel use in 1975 of approximately 14 million barrels. The
savings can be achieved by using a higher sulfur content of oil, rather than
a switch to coal which would increase the ambient particulate levels, which
are already in violation of standards. Table C-2 shows the contribution to
the ambient particulate and sulfur dioxide levels in the vicinity of the plants
as a result of fuel switching. The Portsmouth plant in Chesapeake burned high
sulfur oil in 1973 (2.3%) and also during the first quarter of 1974 (2.7%),
which eliminates any clean fuel saving potential for this plant. This plant
is presently in compliance with SIP requirements.
3.4.3 Industrial, Commercial, Institutional Source Assessment
Point source fuel combustion accounts for 9% of the particulate emis-
sions and 16% of the sulfur dioxide emissions in this region. The major
sources in this region, most of which are Federally owned, are shown in Table
D-l. Most of these sources burned moderate to high sulfur content oil during
the year that the emission inventory was completed and may not accurately re-
flect the current fuel use. The potential for clean fuel savings by these
sources cannot be determined at this time.
3.4.4 Area Source Assessment
Area source fuel combustion accounts for 21% of the particulate emis-
sions and 9% of the sulfur dioxide emissions in this region. A substantial
amount of oil and natural gas is used by area sources in this region. There
is little potential for savings of natural gas since it is usually impractical
for these sources to switch to a different form of fuel.
3.4.5 Fuel Use Assessment
Fuel use by source category is shown in Appendix E.
23
-------
3.5 NORTHEASTERN VIRGINIA INTRASTATE AIR QUALITY CONTROL REGION
3.5.1 Regional Assessment
Ambient air levels of total suspended participates exceeded only the
24-hour secondary standard during 1973. Of the thirteen monitoring stations
in this region, only two had sufficient data with which to calculate an annual
geometric mean. (Table A-4). This region is classified Priority 1A for par-
ti culates and has one county proposed as an Air Quality Maintenance Areas.
Sulfur dioxide levels did not exceed the 24-hour standard during 1973,
and there were insufficient data to determine an annual average. This is a
Priority III region for sulfur dioxide, therefore, air monitoring was not
required during 1973. There are no proposed AQMAs in this region for sulfur
dioxide. There is a potential in this region for relaxing S0£ emission limits
based on air quality, however, there would be little benefit because of the
low quantity of fuel use.
3.5.2 Power Plant Assessment
There is one power plant in this region, the Bremo Bluff plant in
Fluvanna County. This plant burned 0.9% sulfur coal during 1973, and. 1.65%
is allowed in 1975 by the State Implementation Plan (Table C-l). Although
there is a tolerance for an increase in the sulfur content of the fuel used,
a relaxation of existing emission limits would be of little benefit since the
quantity of fuel used by this plant is low.
3.5.3 Industrial, Commercial, Institutional Source Assessment
Point source fuel combustion accounts for 900 tons (1%) of the particu-
late emissions and 6,000 tons (30%) of the sulfur d oxide emissions in this
region. The major sources in this region which are shown in Table D-l, have
a low quantity of fuel use, and as previously ment oned a relaxation of the
S02 emission regulations would do little to conser/e clean fuel.
3.5.4 Area Source Assessment
Area source fuel combustion accounts for 2,800 (4%) tons per year of
the particulate emissions and 4,000 tons (2050 of the sulfur dioxide- emissions1
-------
in this region. Fuel use by area sources is shown in Table E-l.
3.5.5 Fuel Use Assessment
Fuel use by source category is shown in Appendix E.
3.6 STATE CAPITAL INTRASTATE AIR QUALITY CONTROL REGION
3.6.1 Regional Assessment
Ambient air levels of suspended particulates exceeded both the annual
and 24-hour standards during 1973, in this region which is classified Priority
I for this pollutant. There were 28 monitoring stations in this region during
1973 and the annual secondary standard was exceeded at eight stations, while
the 24-hour secondary standard was exceeded at nine stations (Table A-4).
There are several counties and cities that have been proposed as Air Quality
Maintenance Areas for this pollutant.
Sulfur dioxide levels did not exceed either the annual or the 24-hour
standards in this region during 1973. This region is classified Priority III
for sulfur dioxide and there have not been any proposed AQMAs for this pollu-
tant. Although there is a tolerance for an increase in S02 emissions based
on 1973 air quality, there is not a substantial amount of clean fuel used in
this region. A relaxation of current emission limits is not feasible as there
would be little benefit derived from it.
3.6.2 Power Plant Assessment
Electricity generation accounts for 33% of the particulate emissions
and 72% of the sulfur dioxide emissions in this region. There are two power
plants operating in this region which are listed in Table C-l. The Chester-
field plant in Chesterfield County has been burning high sulfur oil for several
years, burning 2.25% during 1973. This plant has six boilers, four of which
are convertible to coal burning. A substantial amount of oil is consumed at
this plant representing a potential saving of this fuel if a switch to coal
is comtemplated. Table C-2 indicates the contribution to the ambient levels
of particulates and sulfur dioxide if two or all four of the units were to
switch to coal. As indicated this plant would contribute significantly to
existing S02 levels and under certain conditions, the emissions from this
25
-------
plant alone would cause SOg levels in the region to exceed air quality standards,
The Twelth Street plant in Richmond burned low sulfur coal and oil dur-
ing 1973, however, the quantity of fuel used at this plant is so low that a
significant fuel saving cannot be achieved.
3.6.3 Industrial, Commercial, Institutional Source Assessment
Point source fuel combustion accounts for 19% of the particulate emis-
sions and 20% of the sulfur dioxide emissions in this region. The major
sources of these pollutants as listed in the NEDS inventory are shown in
Table D-l. The majority of these sources burned oil, most of it having a
high sulfur content (1.92% - 2.6%). The small amount of coal used by these
sources had a moderate sulfur content (1.0% - 1.14%). There is little poten-
tial for clean fuel savings by these sources.
3.6.4 Area Source Assessment
Area source fuel combustion accounts for 11% of the particulate emis-
sions and 7% of the sulfur dioxide emissions in this region. There is a sig-
nificant amount of oil and natural gas used by area sources in this region
as shown in Table E-l. However, as mentioned earlier in this report, there
is little potential for saving natural gas by switching to a different fuel
because of the increased costs in changing fuel burning equipment.
3.6.5 Fuel Use Assessment
Fuel use by source category is shown in Appendix E.
3.7 VALLEY OF VIRGINIA INTRASTATE AIR QUALITY CONTROL REGION
3.7.1 Regional Assessment
Total suspended particulate levels exceeded the nnual and 24-hour
standards in this region during 1973. This regioi is classified Priority I
for particulates and has three counties and one city proposed as Air Quality
Maintenance Areas. Of the 41 monitoring stations in this region, 5 stations
exceeded the annual secondary standard, and 11 stations exceeded thi 24-hour
secondary standard.
-------
Sulfur dioxide levels did not exceed any standards during 1973 in
this region which has a Priority III classification for this pollutant. There
are no proposed AQMAs for sulfur dioxide. There is a tolerance for an increase
in S0£ emissions in this region while still maintaining air quality standards
based on 1973 air quality data, however, the amount of clean fuels that would
be saved is low as in some of the other regions.
3.7.2 Power Plant Assessment
There are two power plants in this region which account for 10% of
the particulate emissions and 24% of the sulfur dioxide emissions. The Glen
Lyn plant in Giles County burned 0.95% sulfur coal in 1973 and 0.87% during the
first quarter of 1974. The SIP allows 1.58% sulfur at this plant, affording
a potential clean fuel saving, although the saving is not substantial. The
Riverton plant in Warren County is allowed 1.51% sulfur under SIP requirements
which necessitates a significant decrease from the 3.73% sulfur coal used
during 1973. During the first quarter of 1974, 1.3% sulfur was used at this
plant. Fuel oil, containing 0.08% sulfur was used during 1973, and 0.15%
in the first quarter of 1974 was also used at this plant.
3.7.3 Industrial, Commercial, Institutional Source Assessment
Point source fuel combustion accounts for 28% of the particulate emis-
sions and 52% of the sulfur dioxide emissions in this region. The major
sources as listed in the NEDS inventory are shown in Table D-l. The coal
used by these sources at the time of the inventory was of a low to moderate
sulfur content (0.64% - 1.3%), affording some potential savings, whereas the
fuel oil used had a high sulfur content (1.94% - 2.5%).
3.7.4 Area Source Assessment
Area source fuel combustion accounts for 3% of the particulate emissions
and 10% of the sulfur dioxide emissions in this region. Fuel use by area
sources is shown in Table E-l. There is some potential for saving fuel
oil in this region by these sources, by switching to a higher sulfur content.
This finding is based on the fuel use data that are presently available for
this report showing the fuel use at the time of the emission inventory and
may not reflect the current situation.
27
-------
3.7.5 Fuel Use Assessment
Fuel use by area sources are shown in Appendix E.
28
-------
TABLE A-l. APPENDIX A STATE IMPLEMENTATION PLAN BACKGROUND
VIRGINIA AIR POLLUTION CONTROL AREAS
Air Quality Control
Region
National Capital Inter-
State (D.C., MD.)
Eastern Tennessee-
Southwestern Virginia Interstate
(Tenn.)
Central Virginia
Hampton Roads
Northeastern Virginia
State Capital
Valley of Virginia
Federal Classification* Population AQMA P ropes edb
Number TSP SO* NOX (Millions) . TSP Counties
47 I I III 3.16 Arlington, Fairfax, Loudoun, Prince William,
SQX Counties
None
207
222
223
224
225
I
I
IA
I
III
II
III
III
III
III
III
III
0.59
1.13
0.42
0.77
226
III
Alexandria City, Fairfax City, Falls Church City
III 1.61 None None
Amherst, Appomattox, Campbell, Lynchburg City None
James City, York, Hampton City, Newport News None
City, Williamsburg City, Chesapeake City,
Portsmouth City, Suffolk City, Virginia Beach City
Gloucester None
Charles City, Chesterfield, Goochland, Hanover, None
Henrico, Powhatan, Richmond City, Prince George,
Dinwiddie, Petersburg City, Colonial Heights City,
Hopewell City
III 0.70 Botetourt, Craig, Roanoke, Roanoke City, Salem City None
Criteria Based on Maximum Measured (or Estimated) Pollution Concentration in Area
Priority
Sulfur oxide:
Annual arithmetic mean
24-hour maximum .
Parti cul ate matter:
Annual geometric mean
24-hour maximum
I
Greater than
(ug/m3)
100
455
95
325
II
From - To
(ng/m3)
60-100
260-455
60-95
150-325
III
Less than
(pg/m3)
60
260
60
150
Federal Register, July, 1974 counties showing potential for NAAQS violations due to growth.
-------
TABLE A-2
AMBIENT AIR QUALITY STANDARDS
All Concentrations In pg/m3
Total Suspended Particulates Sulfur Oxides Nitrogen Oxides
Annual 24-Hour Annual 24-Hour 3-Hour Annual
Federal Primary 75(6) 260a 80(A) 365a 100
100
Primary
Secondary
Primary
Secondary
75(6)
60(6)
75(6)
60(6)
260a
150a
260a
150a
80(A)
—
80(A)
80(A)
365a
365a
365a
1300a
1300a
State Primary 75(6) 260a 80(A) 365a 100
100
(G) Geometric Mean
(A) Arithmetic Mean
a Not to be exceeded more than once per year
-------
TABLE A-3
AIR QUALITY STANDARDS ATTAINMENT DATES
Attainment Dates
Air Quality Federal Particulates Sulfur Dioxide
Control Region Number : Primary Secondary Primary Secondary
National Capital 47 6/75 6/75 6/72 6/72
(D.C., MD.)
Eastern Tennessee-
Southwestern Virginia 207 6/75 6/75 6/72 6/72
(Tenn.)
- Central Virginia 222 6/75 6/75 a . a
Hampton Roads 223 = 6/75 6/75 6/72 6/72
Northeastern Virginia 224 6/75 6/75 a a
State Capital 225 6/75 7/75 a a
Valley of Virginia 226 6/75 6/75 a a
a - Air Quality Levels Presently Below Standards
-------
TABLE A-4
VIRGINIA AIR QUALITY STATUS (1973), TSPa
TSP Concentration(ug/m3)
# Stations Exceeding
Name
National Capital Inter-
state (D.C., MD.)
Eastern Tennessee-
Southwestern Virginia
Interstate (Tenn.)
Central Virginia
Hampton Roads
Northeastern Virginia
State Capital
Valley of Virginia
AQCR #
47b
207b
222
223
224
225
226
#
Reporting
64
42
29
22
13
28
41
Hiahest
Annual
77
93
150
102
45f
82
95
24-Hr
668
528e
824
490
187
291
636
2nd
Highest
24-Hr
351
433e
548
352
157
271
550
Ambient Air Quality
Primary
Annual
1
2
4
4
0
4
2
24-HrC
3
2
2
2
0
1
4
Annual
7
4
8
8
0
8
5
Standards
Secondary
%
11
10
28
36
0
29
12
24-Hrc
7
8
10
9
1
9
11
*
11
19
34
41
8
32
27
Reduction
Required
fn Meet
Standards'1
+65
+70
+77
+63
+ 6
+50
+77 .
Standard
on Which#
Is Based
24-Hr.
24-Hr.
24-Hr.
24-Hr.
24-Hr.
24-Hr.
24-Hr.
1973 air quality in ILtional Air Data Bank, July 28, 1974
Interstate
GViolations based on more than one reading in excess of standard
Formula: .
(2nd Highest 24 Hr - 24 Hr Secondary Standard]
\2nd Highest 24-Hr - Background/
eReadings recorded in Tennessee portion of AQCR
Only two stations had sufficient data to calculate annual average
Background Values: 40 pg/m3 in National Capital AQCR, 30 yci/m3 in all others
x 100,
'Annual - Annual Secondary Standard\
Annual - Background/
x 100
-------
TABLE. A-.5
VIRGINIA AIR QUALITY STATUS (1973), S0|
Name
National Capita.
state (D.C., MD.)
Eastern Tennessee-
Southwestern Virgi
Interstate (Tenn.)
Central Virginia
Hampton Roads
Northeastern
State Capital
Valley of Virginia
Interstate
Formula:
«
SO,
O
Concentration (yg/m )
Stations # 2nd
Reporting Stations Highest
24-Hr Reporting Highest Reading Reading
AQCR #
il Inter- 47b
I.)
ee- 207b
lrtrt-1 m4 ^
rginia
in.)
a 222
223
rginia 224
225
nia 226
ty data in National Air
id on 2nd highest reading
(Bubbler) (Cofitin.) Annual 24-Hr 24-Hr
26
22
8
16
5
16
10
Data Bank, July
at any station
12
4
0
3
0
2
0
28,
2nd Highest 24-Hr - 24-Hr Standard \ im
34e
13
8
34
—
61
15
1974
(Annual -
35lf
809g
60
290
52
500
172
Annual Standard
322f
5819
34
193
49
196
103
^ V,
2nd Highest 24-Hr
Annual
Reading recorded in Maryland portion of AQCR
Reading Recorded in District of Columbia Portion of AQCR.
9Reading recorded in Tennessee portion of AQCR
100
# Stations Exceeding
Ambient Air Quality Stds.
Primery
Secondary
Annual % 24-Hrc % 3-Hr
0
.
Reduction0
Required
To Meet
Standards
-13
+37
-900
-89
-645
-31
-254
Source: Annual Report on The Quality of the Air in Washington, D.C. 1973
Standard
on Which %
Reduction
Is Based
24-Hr
24-Hr
Annual
24-Hr
24-Hr
Annual
24-Hr
-------
' TABLE A-6
VIRGINIA FUEL COMBUSTION SOURCE SUMMARY
Other Fuel Combustion15
Total Emissions
% Emissions From
47e
207e
222
223
224
225
226
TOTAL
ruwer
Plants3
2
1
I9
3
1
2
_2
12
TSP
2
2
7
3
1
1
4
J3
28
S02
5
4
8
6
3
6
_9
41 .
nr t:a
Sources0
7f
13
18
D
26
12
IS.
i)9
TSP
95
276
88
22
65
53
170
769
S02
262
422
27
105
20
137
• 89
1062
TSP
7
23
24
60
27
63
41
SOj
27
9
93
95
100
99
86 •
AQCR
National Capital
East Tenn.-S.W. Va.
Central Virginia
Hampton Roads
Northeastern Virginia
State Capital
Valley of Virginia
a - Virginia Power Plants Only
b - Virginia Plants, which along with power plants contribute 90% or a significant amount of the emissions
within the state
c - Virginia counties
d - total for AQui\
e - interstate
f - includes tiu.o cities
g - no data available for this plant (Brantly, Danville Uater Gas and Electric)
-------
TABLE A-7
VIRGINIA EMISSIONS SUMMARY,3 TSP
AQCR
National Capital
East Tenn.-S.W. Va,
Central Virginia
Hampton Roads
Northeastern Virginia
State Capital
Valley of Virginia
47 Va.
Other
Total
207 Va.
Other
Total
222
223
224
225
226
Total
(IP3 tons/yr)
28
67
95
100
176
276
88
22
65
53
170
Electricity Generation
% (103 tons/yr) %
4
9
13
13
23
36
11
3
8
7
22
3
37
40
39
47
86
0
6.6
13.8
17.5
16.8
11
55
42
39
27
31
0
30
21
33
10
Point Source Fuel Combustion
(1Q3 tons/yr)
2
4
6
20
. 55
75
15
1.9
0.9
10.1
47
7
6
6
20
31
27
17
9
1
19
28
Area Source Fuel Combustion
(IP3 tons/yr)
2
12
14
4
6
10
6
4.6
2.8
5.7
5.7
7
18
15
4
3
4
7
21
4
11
3
Total
769
100
180.7
23
155.9
20
48.8
Emissions taken from 1972 National Emissions Report, June 1974
-------
TABLE A-8
VIRGINIA EMISSIONS SUMMARY3 SO.
AQCR
T_
National Capital
East Tenn.-S.W Va.
Central Virginia
Hampton Roads
Northeastern Virginia
State Capital
Valley of Virginia
47 Va.
Other
Total
207 Va.
Other
Total
222
223
224
225
226
Total
(1Q3 tons/yr)
74
188
262
41
381
422
27
105
20
137
89
%
7
18
25
4
36
40
2
10
2
13
8
Electricity Genei
(103 tons/yr)
64
136
200
26
245
271
0
73
10
98
21
ratlc
%
86
72
76
63
64
64
0
70
50
72
24
Point Source Fuel Combustion
(1Q3 tons/yr) %
Total
1062
100
673
63
3
9
12
7
48
55
17
17
6
27
46
180
4
5
5
17
13
13
63
16
30
20
52
17
Area Source Fuel Combustion
(103 tons/yr)
5
39
44
6
12
18
8
9
4
10
_9
102
7
21
17
15
3
4
30
9
20
7
K)
10
Emissions taken from 1972 National Emissions Report, June 1974
-------
TABLE A-9
VIRGINIA AQCR REQUIRED EMISSION REDUCTION'
AQCR
National Capital
East Tenn. - S.W. Va.
Central Virginia
Hampton Roads
Northeastern Virginia
State Capital
Valley of Virginia
Required Particulate Emission Reduction
10 tons/year
47b
20 7b
222
223
224
225
226
+65
+ 70
+ 77
+63
+ 6
+50
+ 77
+ 62
+ 193
+ 68
+ 14
+ 4
+ 27
+ 131
Required S09 Emission Reduction
3
10 tons/year
-13
+ 37
-900
-89
-645
-31
-254
c
+ 156
c
c
c
c
c
Based on a proportional change of emissions to air quality (1973)
Interstate
Air quality data indicate tolerance for emissions increase.
-------
TABLE A-10
SUMMARY OF VIRGINIA FUEL COMBUSTION EMISSION REGULATIONS
PARTICULATE MATTER
(1) For operations with total heat input less than 25 million BTU
per hour;
Maximum Allowable Emissions = 0.4 pounds per million BTU input
(2) For operations with total heat input between 25 million BTU and
10 billion BTU per hour;
Maximum Allowable Emissions = 0.8425 H~ ' pounds per million BTU input
H = total heat input in millions of BTU per hour
(3) For operations with total heat input in excess of 10 billion BTU
per hour;
Maximum Allowable Emissions = 0.10 pounds per million BTU input
S'IFUR DIOXIDE
Allowable Emissions in pounds/hour = 2.64K
K = total capacity rating of combustion installation in BTU x 10°/hour
In those regions, districts, or locations where attainment of ambient
air quality standards is required, the following emission performance may
be required by the State Air Pollution Control Board.
(A) Allowable Emissions in pounds/hour = 1.58K
(B) Allowable Emissions in pounds/hour = 1.06K
SUMMARY OF FUEL COMBUSTION REGULATIONS IN
NATIONAL CAPITAL INTERSTATE AQCR (#47)
PARTICULATE MATTER
(1) For operations with total heat input less than 87 million BTU per hour;
Maximum Allowable Emissions = 0.3 pounds per million BTU input
(2) For operations with total heat input between d7 million and 10 billion
BTU oer hour;
Maximum Allowable Emissions = 0.8425 H~°*2314
H - total heat input in millions of BTU per hour
(3) For operations with total heat input in excess of 10 bill-'o, BT State
regulations are applicable.
38
-------
SULFUR DIOXIDE
Allowable Emissions in pounds/hour = 1.06K
K = Total capacity rating of combustion installation in BTU x 106/hour
If necessary to achieve and maintain ambient Air Quality Standards, the
Board will require on or before 1975, emissions standards in accordance with
or more restrictive .than- the "following:
Allowable Emissions = 0.55K
39
-------
APPENDIX B REGIONAL SUMMARY
TABLE B-l
CANDIDACY ASSESSMENT FOR RELAXATION OF PARTICULATE EMISSION REGULATIONS
AQCR
National Capital
East Tenn.-S.-Wf' Va.
Central Virginia
Hampton Roads
Northeastern Virginia
State Capital
Valley of Virginia
47b
207b
222
223
224
225
226
Ai r Qi
Number of
Stations
64
42
29
22
13
28
41
jality
Number of
Violations3
14
12
18
17
i
i
17
16
Parti cul ate
Emissions
103 tons/year
95
276
88
22
65
53
170
% Emissions
From Va. Fuel
Combustion Sources
23
24
60
27
63
41
Emission Reduction
Required For NAAQS
(103 tons/yr)
+ 62
+193
+ 68
+ 14
' t *T
+ 4
' *T
+ 27
+131
TSP
Priori tv
T ( 1 U 1 1 \rj
I
I
T
1
T
1
T A
In
T
1
I
AQMAs
Proposed?
Yes
Wn
nU
»/ _ _
Yes
Yes
Yes
Yes
Yes
aTotal. number of stations exceeding both annual and 24-hour standard
k
Interstate
-------
AQCR
National Capital
East Tenn.-S.W. Va.
Central Virginia
Hampton Roads
Northeastern Virginia
State Capital
Valley of Virginia
TABLE B-2
CANDIDACY ASSESSMENT FOR RELAXATION OF S02 EMISSION REGULATIONS
T
47b
207b
222
223
224
225
226
Air
Number of
Stations
38
26
8
19
5
18
10
Quality
Number of
Violations3
0
1
0
0
0
0
0
S02
Emissions
1(P tons/yr
262
422
27
105
20
137
89
% Emissions
rrom Va. Fuel
Combustion Sources
27
9
93
95
100
99
86
Emission Reduction
Required For NAAQS
(103 tons/yr)
c
+ 156
c
- 93
c
- 42
c
S02
Priority
I
I
III
II
III
III
III
AQMAs
Proposed?
No
No
No
No
No
No
No
a - Total number of stations exceeding both annual and 24-hour standard
b - Interstate
c - Tolerance for emission increase based on air quality data.
-------
TABLE C-l. APPENDIX C POWER PLANT SUMMARY
VIRGINIA POWER PLANT ASSESSMENT3
AIR QUALITY CONTROL REGION
NATIONAL CAPITAL
EASTERN TENN. - SOUTHWESTERN VA.
CENTRAL VIRGINIA
HAMPTON ROADS
-P»
CO
NORTHEASTERN VIRGINIA
STATE CAPITAL
PLANT
POTOMAC RIVER
POSSUM POINT
CLINCH RIVER
BRANTLYd
PORTSMOUTH
REEVES AVENUE
YORKTOWN
BREMO BLUFF
CHESTERFIELD
CAPACITY (MW)
1973
1975
515.0
515.0
490.98
1335.98
712.5
712.5
32.3
649.64
649.64
100.0
100.0
375.0
1220.0
284.26
284.26
1484.44
1484.44
FUEL USE, 1973
Type Annualb
% Sulfur Quantity
Coal 795.0
0.84
Oil 4915.99
2.26
Coal 2202.18
0.71
Coal 27.0
Oil 1.0
Gas 1831.0
Oil 5508.99
2.3
Coal 72.0
0.85
Oil 38.48
0.21
Coal 465.0
1.62
Oil 1203.0
1.0
Gas 2632.64
Coal 474.0
0.9
Oil 12851.97
2.25
1974 Fuel % S
% Sc SIP
0.92 0.69
2.24 1.04
0.66 1.58
— •"•«••" "** •""•• —
2.7 2.7
0.71 1.77
1.1 1.7
1.0
0.74 1.65
2.28 1.68
-------
TABLE C-l (Continued)
AIR QUALITY CONTROL REGION
STATE CAPITAL (Cont.)
VALLEY OF VIRGINIA
PLANT
TWELFTH STREET
GLEN LYN
RIVERTON
CAPACITY (MM)
1973
1975
102.5
102.5
402.5
402.5
34.5
34.5
FUEL USE, 1973
Type Annualb
% Sulfur Quantity
Coal 1.0
0.8
Oil 15.0
0.3
Coal 864.87
0.95
Coal 15.8
3.73
Oil 64.7
0.08
1974 Fuel % S
% Sc SIP
0.7 1.77
0.87 1.58
1.3 1.51
0.15
a - Data from Federa. iVi(v. Commission.
h - Fuel quantities- Coal (103 tons), Oil (1Q3 barrels), Gas (106 cubic feet).
c - Data are for first quarter 1974 only.
d - Data for 1972, Steam Electric Plant Factors, 1973 edition, National Coal Association,
-------
TABLE C-2
SUMMARY OF POWER PLANT MODELING RESULTS*
AQCR
National Capital 47
Hampton Roads 223
01
State Capital 225
Plant
Possum Point
1972 Operations
Fuel Switch
Potomac River
1972 Operations
Fuel Switch(b)
York town
1972 Operations
Fuel Switch #l(c)
Fuel Switch #2(c)
Maximum
S02
Nominal
Load
511
676
436
443
68
66
68
24-Hour
Maximum
Load
416
550
627
643
75
73
73
Concentration
Parti cul
Nominal
Load
II
340
62
62
8
19
19
yg/nr
ates
Maximum
Load
9
277
97
97
7
17
17
Maximum Annual „
Concentration yg/mj
SO
40
52
18
24
4
3
4
? Parti cul ates
1
26
2
2
-------
ADDENDUM TO APPENDIX C
USE AND LIMITATIONS OF MODELING ANALYSIS DATA3
1. The data inputs for the modeling have been extracted from the
appropriate FPC Form 67 and the most representative meteorological data
available. However, to calculate the occurrence of the highest 24-hour
concentration, assumptions as to the daily emission rate are necessary.
The results of the modeling exercise provide a range of the most probable
maximum concentration.
2. It should be recognized that time and data constraints are such
that the model predictions are useful but not omniscient. There are no
data available, in general, to "validate" the model. Therefore, all rele-
vant data, including hard data on actual daily plant operations, should
be obtained, reviewed, and evaluated. In this way, the modeling results
can be used as a logical part of the entire decision-making framework, not
as an arbitrary, dogmatic absolute "answer", divorced from the real situation
involved. In some cases it will be necessary to adjust the model's predic-
tions based upon more complete and detailed information on a particular
plant's operations.
3. Results of these eval1 itions ura not intended to be used in any
legal actions, including both public hearing and court proceedings. The
very nature of atmospheric dispersion modeling is such that results are not
suitable to legally prove (or disprove) a particular modeling result. The
assumptions and judgments necessarily involved in modeling tend to mitigate
against proof in a legal sense.
4. The best use of the data is in negotiations with states or sources
in trying to establish a rational course of action to be followed with reason-
able assurance that the air quality impact will be as indicated by the model.
a Extracted from comments by the Monitoring and Data Analysis Division, OAQPS
46
-------
APPENDIX D INDUSTRIAL, COMMERCIAL, INSTITUTIONAL SOURCE SUMMARY
TABLE D-l
INDUSTRIAL, COMMERCIAL, INSTITUTIONAL SOURCE ASSESSMENT3
AIR QUALITY
CONTROL REGION
NATIONAL CAPITAL
EASTERN TENNESSEE-
SOUTHWESTERN VIRGINIA
CENTRAL VIRGINIA
SOURCE
GSA HEATING PLANT
QUANTICO MARINE
NATIONAL AIRPORT
FORT BELVOIR
ARLINGTON HALL STATION
U.S. GYPSUM
WASHINGTON MILLS
BRUNSWICK CORP.
WONDERKNIT CORP.
DUPONT
BOILER CAPACITY
(106 BTU/HR)
410
183
130
221
92
766
50
29
84
20
175
50
TYPE
Coal
0.8% S
7.7% A
Coal
1% S
8% A
Oil
0.95% S
Oil
0.75% S
Oil
0.9% S
Coal
0.73% S
10.2% A
Coal
0.9% S
4.1% A
Coal
1.12% S
21.6% A
Coal
0.88% S
8.8% A
Coal
1.4% S
9.6% A
Oil
2.3% S
FUEL ,
AMOUNT15
50
30
63.1
45.5
18.2
7.4
7
4.9
6
70
216.2
EMISSIONS
PART.
250
510
30
22
9
259
42
31
132
1874
(TONS/YR.)
SO?
760
569
198
112
54
131
120
103
100
3500
-------
oo
AIR QUALITY BOILER CAPACITY
CONTROL REGION SOURCE (1Q6 BTU/HR)
CENTRAL VA. (Cont.) MEAD CORP. 2 @ 262
OWENS-ILLINOIS 280
DAN RIVER 581
200
BURLINGTON INDUSTRIES 175
(MECKLENBURG CO.)
50
BURLINGTON INDUSTRIES 55
(CAM.-: ELL CO.)
91
RUB ATE X CORP. 78
LANE CO. ' 57
FUEL
TYPE
Coal
1.56% S
9.9% A
Oil
0.0% S
Black Liquor
Coal
1.0% S
8.5% A
Coal
1.2% S
7.1% A
Coal
0.75% S
6.4% A
Coal
0.9% S
6.3% A
Oil
1.36% S
Coal
0.7% S
6% A
Oil
2.6% S
Oil
2.11% S
Coal
0.63% S
8% A
EMISSIONS (TONS/YR.;
AMOUNTb PART. S00
0.094 3240 3100
3.3
1.3 (Solid)
124 1160 2360
48.5 789 1578
32.8
33.2 820 600
7.14
14 113 250
7.38
35.2 17 245
8.3 197 100
-------
TABLE D-l (Continued)
AIR QUALITY BOILER CAPACITY
CONTROL REGION SOURCE (106 BTU/HR)
HAMPTON ROADS U.S. NAVY PUBLIC WORKS 791
CENTER 184
NORFOLK NAVAL SHIPYARD 900
40
DOW BADISCHE 298
NAVAL AMPHIBIAN BASE 300
FORT EUSTIS 2 @ 312
NORFOLK SHIPBUILDING 71
NORTHEASTERN VA. CHESAPEAKE CORP. 464
217
m
UNIV. OF VIRGINIA 72
2 @ 50
HOLLY FARMS 59
STATE CAPITAL DUPONT 714
586
46
FUEL EMISSIONS
TYPE AMOUNTb PART.
Oil
2.2% S
Oil
1.67% S
Oil
2.33% S
Oil
2.0% S
Coal
0.9% S
9.5% A
Oil
1.85% S
Oil
2.1% S
Oil
2.15%
Wood
Coal
1% S
5.4% A
Oil
2.1% S
Coal
1.14% S
9.9% A
Oil
2.38% S
721
721
309.5
190.5
15.4
34.1
35.7
700
75
Total
10
18429
36.1
1129
349
44
149
37
965
17
89
1150
1239
35
9
562
(TONS/YR
SQ2
5250
3964
2380
1260
471
247
2402
56
2458
190
128
9656
-------
AIR QUALITY BOILER CAPACITY
CONTROL REGION SOURCE (10* BTU/HR)
STATE- CAPITAL (Cont.) CONTINENTAL CAN 731
277
HERCULES INC. 610
FIRESTONE 180
SOUTHERN JOHNS- 182
MANVILLE
FEDERAL PAPER BOARD 2 @ 95
VALLEY OF VA. WESTVACO 768
725
516
FMC VISCOSE 846
599
276
CELANESE FIBERS 520
396
316
196
153
DUPONT 2 @ 209
196
183
176
2 @ 209
176
FUEL
TYPE
Oil
2.18% S
Wood
Oil
1.92% S
Oil
2.25% S
Coal
1% S
6% A
Coal
1.735 S
Coal
1.3% S
10% A
Coal
1.2% S
11% A
Oil
2.5% S
Coal
1.15% S
11% A
Oil
Coal
1.22% S
12.2% A
Oil
2.5% A
AMOUNTb
1021
190
714
102
23.6
32
452
323
259.5
400
19.8
163.3
331
EMISSIONS
PART.
563
1620
120
49
1070
76
1471
18286
2961
2717
(TONS/YR.)
so2
7340
143
4590
759
448
517
11150
9490
8740
7497
-------
TABLE D-l (Continued)
en
AIR QUALITY BOILER CAPACITY
CONTROL REGION SOURCE (106 BTU/HR)
VALLEY OF VA. (Cont.) HERCULES, INC. 1000
(RADFORD ARSENAL)
150
MERCK 110
100
BURLINGTON IND. 163
VA. POLYTECHNIC 219
INSTITUTE
REYNOLDS METALS 27
FUEL
TYPE
Coal
1.2% S
12% A
Coal
0.7% S
12% A
Coal
1.06% S
6.9% A
Oil
1.94% S
Coal
0.7% S
7.6% A
Coal
0.75% S
11% A
Coal
0.64% S
4.9% A
. EMISSIONS (TONS/YR.)
AMOUNTb PART. S00
215 7760 5197
22.3
44.7 318 1026
19.8
24 365 319
17 122 242
10.4 127 126
a - Fuel combustion sources which are significant emitters of particulates and sulfur dioxide. Sources are ranked
in order of decreasing S02 emissions.
b - Fuel quantity: Coal is in 103 Tons/Year. Oil is in 103 Bbls/Year.
-------
TABLE E-l. FUEL USE SUMMARY3
APPENDIX E AQCR FUEL USE SUMMARY
en
GO
AIR QUALITY CONTROL REGION
NATIONAL CAPITAL
Area Sources
Point Sources
Total
EASTERN TENN. - SOUTHWESTERN VA.
Area Sources
Point Sources
Total
CENTRAL VIRGINIA
Area Sources
Point Sources
Total
HAMPTON ROADS
Area Sources
Point Sources
Total
NORTHEASTERN VIRGINIA
Area Sources
Point Sources
Total
STATE CAPITAL
Area Sources
Point Sources
Total
VALLEY OF VIRGINIA
Area Sources
Point Sources
Total
COAL (103 TONS)
ANTHRACITE BITUMINOUS
OIL (103 BARRELS)
RESIDUAL DISTILLATE
GAS (106 CU. FT.)
NATURAL PROCESS
>0
0.3
0.3
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
81
4196
4277
381
11849
12230
37
346
383
31
908
939
10
537
547
35
113
148
68
2801
2869
8907
12921
21828
327
170
497
809
326
1135
843
7173
8016
325
743
1068
1033
15758
16791
865
864
1729
9386
252
9638
3144
170
3314
2532
44
2576
4023
362
4385
1881
26
1907
3285
1866
5151
2684
111
2795
108510
1562
110072
34460
12579
47039
16310
3285
19595
32400
1872
34272
8290
0
8290
25030
1508
26538
21570
4344
25914
0
0
0
160
7485
7645
0
0
0
0
0
0
0
0
0
0
0
0
0
66
66
a - Source: Stationary Source Fuel Summary Report NEDS. November 1974.
-------
TECHNICAL REPORT DATA
(Please read lattructions on the reverse before completing)
1. REPORT NO.
EPA-450/3-75-Q16
3. RECIPIENT'S ACCESSION-NO.
4. TITLE AND SUBTITLE
IMPLEMENTATION PLAN REVIEW FOR VIRGINIA AS REQUIRED
BY THE ENERGY SUPPLY AND ENVIRONMENTAL COORDINATION
ACR
5. REPORT DATE
^February 1975
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 III, Philadelphia,
Pa., and TRW, Inc., Vienna, Virginia
11. CONTRACT/GRANT NO.
68-02-1385
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 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.
7.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.IDENTIFIERS/OPEN ENDED TERMS C. COSATI Held/Group
Air pollution
State Implementation Plans
8. DISTRIBUTION STATEMENT
Release unlimited
19. SECURITY CLASS (This Report)
Un class"! fiej±.
21. NO. O PAGES
20. SECURITY CLASS (This pa
Unclassified
_. PRICE
EPA Korm 2220-1 (9-73)
54
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