EPA-450/3-75-017 FEBRUARY 1975 IMPLEMENTATION PLAN REVIEW FOR MARYLAND AS REQUIRED BY THE ENERGY SUPPLY AND ENVIRONMENTAI COORDINATION ACT U. S. ENVIRONMENTAL PROTECTION AGENCY ------- EPA-450/3-75-017 IMPLEMENTATION PLAN REVIEW FOR MARYLAND AS REQUIRED BY THE ENERGY SUPPLY AND ENVIRONMENTAL COORDINATION ACT Prepared by tjie Following Task Force: U. S. Environmental Protection Agency, Region III 6th and Walnut Streets Philadelphia, Pennsylvania 19106 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 February 1975 ------- MARYLAND ENERGY SUPPLY AND ENVIRONMENTAL COORDINATION ACT (SECTION IV - STATE IMPLEMENTATION PLAN REVIEW) Table of Contents Page 1.0 EXECUTIVE SUMMARY I 2.0 STATE IMPLEMENTATION PLAN REVIEW 2.1 Summary 5 2.2 Air Quality Setting For the State of Maryland 10 2.3 Background on the Development of Maryland's Current State Implementation Plan 13 3.0 CURRENT ASSESSMENTS BASED ON STATE IMPLEMENTATION PLAN REVIEW 15 3.1 National Capital Interstate Air Quality Control Region 16 3.2 Central Maryland Intrastate Air Quality Control Region 17 3.3 Cumberland-Keyser Interstate Air Quality Control Region 18 3.4 Eastern Shore Intrastate Air Quality Control Region 20 3.5 Metropolitan Baltimore Intrastate Air Quality Control Region 21 3.6 Southern Maryland Intrastate Air Quality Control Region 23 APPENDIX A - STATE IMPLEMENTATION PLAN BACKGROUND APPENDIX B - REGIONAL SUMMARY APPENDIX C - POWER PLANT SUMMARY APPENDIX D - INDUSTRIAL, COMMERCIAL, INSTITUTIONAL SOURCE SUMMARY APPENDIX E - AQCR FUEL USE SUMMARY ------- 1.0 EXECUTIVE SUMMARY The enclosed report is the U.S. Environmental Protection Agency's (EPA) response to Section IV Of the Energy Supply and Environmental 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 inter- fering with the attainment and maintenance of the National Ambient Air Quality Standards (NAAQS). In addition to requiring that EPA report to the State on whether control regulations might be revised, ESECA provides that EPA must approve or disapprove any revised regulations relating to fuel burning sta- tionary sources within three months after they are submitted to EPA by the States. The States may, as in the Clean Air Act of 1970, initiate State Implementation Plan revisions; ESECA does not, however, require States to change any existing plan. Congress has intended that this report provide the State with 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. ------- 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 S0£ 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 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 controlling 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 0£ more stringent state air quality standards. Also, at that time an acceptable method for formu- lating 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 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 AQCRs of the State if the control regulations were applied to similar sources. The problem with the use of an example region is that it can result in controls which are more stringent than needed to attain NAAQS, especially in the util- ization of clean fuels, for areas of the State where 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 sulfur coal would be adequate to attain NAAQS in some locations. ------- EPA anticipates that a number of States wilt 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 desira to submit a revised plan to recognize the review's lim- itations. 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 emis- sions. Where the modeling data for specific sources were found, however, they were used in the analysis. The data upon which the reports' findings are based 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 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 attain- ment of all the NAAQS, most of the review has focused on total suspended particulate matter (TSP) and sulfur dioxide (S02) emissions. This is because stationary fuel combustion sources constitute the greatest source of SO? 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 AQCRs. The regional emission tolerance estimate is, in many cases, EPA's only measure of the "over-cleaning" accomplished by a SIP. The tolerance assess- ments have been combined in Appendix B with other regional air quality "in- dicators" 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 Maryland has been reviewed for the most prevalent causes of over-restrictive fuel combustion emission limiting regulations. The major findings of the review are: FOR TOTAL SUSPENDED PARTICULATES. THERE IS LITTLE INDICATION THAT CURRENT EMISSION REGULATIONS ARE OVER-RESTRICTIVE. FOR SULFUR DIOXIDE. THERE ARE INDICATIONS THAT CURRENT EMISSION LIMITS MAY BE REVISED IN SOME OF THE AIR QUALITY CONTROL REGIONS. The supportive findings of the SIP review are as follows: Like many areas of the nation, high levels of total suspended partic- ulates were found in Maryland during 1973. Federal air quality standards were exceeded in all but the Southern Maryland Air Quality Control Region which has been rated as a good candidate for revision of par- ti culate emission regulations. Ambient levels of sulfur dioxide during 1973 did not violate either the annual or 24-hour Federal standard in any AQCR. The State standards which are more stringent were violated in some of the AQCRs. The Eastern Shore AQCR and the Southern Maryland AQCR are rated as good candidates for revision of current S02 emission limits. Marginal candidates for revision are the National Capital, Central Maryland and Cumberland-Keyser regions. Recent action by the State of Maryland parallels the intention of Section IV of ESECA. In an attempt to reduce the impact of fuel shortages, the State has proposed a plan revision which would post- pone the date of fuel oil sulfur content limits until 1980. The regulation requiring 0.5% sulfur content is scheduled to go into effect July 1, 1975. ------- 2.0 STATE IMPLEMENTATION PLAN REVIEW 2.1 SUMMARY A revision of fuel combustion source emissions regulations will depend on many factors. 0 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 p_r 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? 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 of NAAQS? t 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? Do modeling results for specific fuel combustion sources show a potential for a regulation revision? The following portion of this report is directed at answering these questions. An AQCR's potential for revising regulations increases when there are affirmative responses to the above. The initial part of the SIP review report, Section 2 and Appendix A, was organized to provide the background and current situation information for the State Implementation Plan. Section 3 and the remaining Appendices ------- provide an AQCR analysis which helps establish the overall potential for revising regulations. Based on an overall evaluation of EPA's current information, AQCRs 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 2) Attainment date for NAAQS later than 1975 3) Proposed AQMA 4) Modeling results show no potential for regulation revision Marginal 1) No air quality data or insufficient number of monitoring sites 2) 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. However, in Maryland there are sufficient data for all of the regions. Marginal ratings are also given when there are varying or inconsistent "indicators". After a candidacy has been given to a region, a follow-up analysis should be conducted depending on the rating. A region that 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 the EPA, including an examination of current air quality, emissions, and fuel use data, with which the state has ------- more familiarity. If the state feels that clean fuels could be saved in a 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. ------- TABLE 2-.1 STATE IMPLEMENTATION PLAN fiEVIEW (SUMMARY) "Indicators" State TSP SO, National Capital AQCR 47 TSP SO? Does the State have air quality standards which are more stringent than NAAQS? Does the State have emission limiting regula- tions 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? Do modeling results for specific fuel combustion sources show a potential for a regulation revision?3 Based on the above indicators, what is the poten- tial for revising fuel combustion source emission limiting regulations? Yes Yes Yes Yes Yes Yes Yes Yes No Yes No Central Maryland AQCR 112 TSP SO? Cumberland Eastern Keyser Shore AQCR 113 AQCR 114 Metropolitan Southern Baltimore Maryland AQCR 115 AQCR 116 TSP SO, TSP SO, TSP SO, No Yes Yes No No Yes Yes Yes Yes Yes Yes Yes Yes No No Yes Yes Yes Yes Yes No Yes Yes No No Yes Yes Yes Yes Yes Yes Yes Yes No No Yes Yes Yes Yes Yes No No Yes Yes No Yes N.A. N.A. TSP SO? No No Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes No Yes Yes Yes No Yes Yes Yes Yes No No No Yes No Yes No N.A. N.A. No Yes N.A. N.A. Yes Yes Poor Marg. Poor Marg. Poor Marg. Poor Good Poor Poor Rood' Good Modeling data available for power plants only. ------- METROPOLITAN BALTIMORE INTRASTATE CUMBERLAND- KEYSER INTERSTATE (MARYLAND- J»EST VIRGINIA) CENTRAL MARYLAND INTRASTATE EASTERN SHORE INTRASTATE NATIONAL CAPITAL INTERSTATE (WASHINGTON, D.C. MARYLAND- VIRGINIA) SOUTHERN MARYLAND INTRASTATE Figure 2-1 MARYLAND AIR QUALITY CONTROL REGIONS ------- 2.2 AIR QUALITY SETTING FOR THE STATE OF MARYLAND 2.2.1 Maryland Air Quality Control Regions The State of Maryland has been divided into six Air Quality Control Regions. The Federal designations of these regions and the other states that comprise the interstate regions are as follows: National Capital Interstate (Virginia, District of Columbia) Central Maryland Intrastate Cumber!and-Keyser Interstate (West Virginia) Eastern Shore Intrastate Metropolitan Baltimore Intrastate Southern Maryland Intrastate These regions are also listed in Table A-l as well as the priority classi- fications for total suspended particulates and sulfur dioxide, an estimate of the 1975 population in each region, and proposed Air Quality Maintenance Areas. 2.2.2 Ambient Air Quality Standards Maryland has adopted ambient air quality standards for both total suspended particulates and sulfur dioxide. As shown on Table A-2, the State standards are more stringent than the Federal standards for both of these pollutants. A one-hour standard for sulfur dioxide has also been adopted by the State although there is not a Federal standard for this time interval. 2.2.3 Air Quality Status Air monitoring data for total suspended particulates and sulfur dioxide are summarized in Tables A-4 and A-5 respectively. These data are from the "Maryland State Yearly Air Quality Data Report, 1973" and the SAROAD data bank as of July, 1974. During 1973, ambient levels of total suspended particulates exceeded Federal standards in all but the Southern Maryland AQCR. Significant reduc- tions in the 1973 levels are needed for these regions to meet standards, with the greatest reduction required in the Metropolitan Baltimore region. This region recorded the highest annual and second highest 24-hour average in the State. The annual primary standard was also exceeded in the Central Maryland and Cumberland-Keyser regions, indicating that these regions have experienced 10 ------- sustained periods of high suspended particulate levels. Sulfur dioxide levels during 1973 did not exceed either the annual or 24-hour Federal standard in any of the Air Quality Control Regions. The highest annual average, and the second highest 24-hour average were recorded in the Metropolitan Baltimore AQCR. The Eastern Shore and Southern Maryland regions are classified Pri- ority III for sulfur dioxide, and although air monitors were not required during 1973, there are adequate air quality data for both of these regions. 2.2.4 Emissions Summary A summary of particulate and sulfur dioxide emissions for each region is presented in Tables A-6 and A-7 respectively. These data are from the Maryland Bureau of Air Quality Control emission inventory. Fuel combustion sources, as shown in Table A-8, account for the ma- jority of particulate emissions in all but the Central Maryland and Metro- politan Baltimore Air Quality Control Regions. These sources do however, contribute the majority of sulfur dioxide emissions in all of the regions. Particulate and sulfur dioxide emissions from power plants and other point sources are shown in Appendices C and D respectively. 2.3 BACKGROUND ON THE DEVELOPMENT OF MARYLAND'S CURRENT STATE IMPLEMENTA- TION PLAN 2.3.1 Control Strategy For Particulate Matter And Sulfur Oxides A. Maryland portion of the National Capital Interstate Region The January 28, 1972, Implementation Plan indicated that Maryland's control strategy when combined with Virginia's and the District of Columbia's was adequate for attainment of the primary standards by 1975 but was not adequate for attain- ment of the secondary standards. However, the EPA evaluation of Maryland's existing plan (May 28, 1970, and addendums) entitled "Evaluation of Maryland's 'Existing' Sulfur and Particulate Matter Implementation Plan for the National Capital Interstate Air Quality Control Region (NCIAQCR)," July 29, 1971, in- dicated that the combined control strategies of Virginia, the District of 11 ------- Columbia and Maryland were capable of reducing emissions sufficiently to allow attainment of the secondary standards for particulate matter and sul- fur oxides throughout the National Capital Interstate Region by 1975. The Administrator approved Maryland's control strategy in his August 4, 1971, letter to the Governor of Maryland, and this approval was finalized in the Federal Register of February 3, 1972, Vol. 37, No. 23. EPA and the State will continue to monitor the air quality readings in the National Capital Region to determine the accuracy of the diffusion model predictions. B. Central Maryland Intrastate Region Maryland demonstrated the attainment of national standards by creating a sub-region around the only large town in the Region, Frederick City. This urban area represents the largest center for industry and population in the Region, and is the area expected to have the greatest increase in pollutant concentrations. Maryland used growth factors and proportional modeling to show that concentrations of sulfur oxides and particulate matter will be reduced below the national standards by 1975. C. Cumber!and-Keyser Interstate Region Because of the mountainous terrain and complex meteorology, Maryland divided the region into three sub- regions: the Hagerstown area, the Cumberland area, and the Luke area. A proportional rollback was used to project future (1975) air quality levels, after application of the State's adopted emission limitations, for sulfur oxides and particulate matter in each sub-region. Growth factors were in- cluded in these calculations. This proportional rollback predicted air quality levels for 1975 which are well below secondary standards for both pollutants. D. Eastern Shore Intrastate Region (Particulate matter) After considering the rural character of this Region, Maryland divided it into three sub-regions which are located around the three large towns of Elkton, Cambridge, and Salisbury. These three towns represent the largest concen- trations of industry and population in the Region and are the areas where the greatest concentration of particualte matter accumulates. Proportional modeling techniques were employed to predict the degree of emission reduc- 12 ------- tions needed in each sub-region to meet the national standards. The pro- portional rollback for the Elkton sub-region and the Cambridge sub-region predicted that air quality levels would be well below the secondary standards by 1975. The proportional rollback for the Salisbury sub-region predicted that air quality levels would attain the secondary standards for particulate matter by 1975. Thus, with growth factors applied, the proportional model indicated that the secondary standards for particulate matter would be attained. (Sulfur oxides) The Eastern Shore Intrastate Region is classified Priority III for sulfur oxides. Current emissions of sulfur oxides will be significantly reduced by Maryland's sulfur-restrictions-in-fuels regulation. E. Metropolitan Baltimore Intrastate Region EPA approved the con- trol strategy in Maryland's "existing" plan (December 23, 1970, and adden- dums). This plan included a control strategy that was judged adequate for attainment of the secondary standards for particulate matter and the primary standards for sulfur oxides. This approval was documented in EPA's July 29, 1971, "Evaluation of Maryland's 'Existing' Sulfur oxides and Particulate Matter Implementation Plan for the Metropolitan Baltimore Intrastate Air Quality Control Region (MBIAQCR)." The Administrator's approval was final- ized in the Federal Register of February 3, 1972, Vol. 37, No. 23. The Jan- uary 28, 1972 Implementation Plans (and addendums) referenced EPA approval of the December 23, 1970 "Existing" Plan. The emission limitations which were part of the "existing" plan remain in effect, and in some cases are more stringent. Thus, the control strategy is capable of reducing emissions sufficiently to allow attainment of the secondary standards for particulate matter and of the primary standards for sulfur oxides. F. Southern Maryland Intrastate Region This Region is classified Priority III for both sulfur oxides and particulate matter. Maryland applied its control strategy to the sources emitting pollutants in the Region, and projected substantial reductions in emissions of both pollutants. 2.4 PROPOSED STATE IMPLEMENTATION PLAN REVISION The State has proposed a plan revision which would postpone the sul- fur-in-fuel limits for fuel oil until 1980. The current regulations re- quire 1% or less sulfur for residual oil which is to decrease to 0.5% on and after July 1, 1975. 13 ------- 14 ------- 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 Maryland 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) designa- tions; (4) total emissions; (5) portion of emissions from Maryland 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. As mentioned previously, regional air quality data for 1973 are pre- sented in Tables A-4 and A-5 for total suspended particulates and sulfur dioxide respectively. Table C-l shows the 1973 fuel use and sulfur content of the fuel for each of the Maryland power plants. The sulfur content is an average content for the year, as variations of up to 20% are common. Table C-2 is a summary of modeling results for power plants in three AQCRs.1 Although it is realized that there are some limitations 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 Air Quality Control Regions. Only those sources emitting 100 tons per year or more of particu'lates or sulfur dioxide are listed. Appendix E shows the total fuel use for each AQCR. The modeling analysis of the power plants was performed by the Walden Research Division of Abcor Inc. The model used was a Gaussian plume model developed by the Meterology Laboratory, EPA, and was based on 1972 plant operations. Detailed information can be found in; Modeling Analysis of Power Plants for Fuel Conversion, (Group III) September 9, 1974. 15 ------- 3.1 NATIONAL CAPITAL INTERSTATE AIR QUALITY CONTROL REGION 3.1.1 Regional Assessment During 1973, suspended particulate levels in the Maryland portion of this AQCR equalled the Federal annual secondary standard and exceeded the 24-hour secondary standard (Table A-4). The annual and 24-hour pri- mary standards were exceeded in the other jurisdictions within this AQCR. The Maryland portion has been proposed as an Air Quality Maintenance Area for particulate matter. This region has been rated as a poor candidate for relaxing particulate emission regulations. Sulfur dioxide levels in this region did not exceed the Federal annual or 24-hour standards during 1973, although readings recorded in the District of Columbia were close to the 24-hour standard (Table A-5). Air monitoring data for Maryland indicate that S0£ levels were well below the Federal standards and exceeded only the lower limit of the more adverse range of the State standard for a 24-hour period. There is no proposed AQMA for sulfur dioxide in the Maryland portion of this region, however the District of Columbia has been proposed as an AQMA. This region has been rated as marginal for regulation revision. 3.1.2 Power Plant Assessment There are two Maryland power plants in this region, the Dickerson plant in Montgomery County, and the Chalk Point plant in Prince Georges County (Table C-l). The Dickerson plant has been burning coal with an average sulfur con- tent of 1.64% during 1973 and is operating under a variance pending comple- tion and successful operation of a flue gas desulfurization system. The Chalk Point plant is also operating under a variance which in- cludes a schedule for installation of a flue gas desulfurization system contingent upon the success of the system at Dickerson. There are some modeling data presented in Table C-2 which show the maximum contribution to the ambient suspended particulate and sulfur dioxide levels that are attrv buted to the plant. The data indicate that at maximum load, the plant will contribute approximately 155 ng/m3 to the ambient levels of sulfur dioxide 16 ------- under certain conditions which may occur 5% of the time. These concentra- tions would not cause violations of the Federal SC^ standards in the Mary- land portion of the region based on 1973 air quality data, although they may cause violations of the State standards. It should be noted that these modeling results do not consider the operation of the additional 660 MW unit at this plant. 3.1.3 Industrial, Commercial, Institutional Source Assessment The Maryland fuel combustion sources in this region which emit 100 tons or more per year of either particulate matter or sulfur dioxide are listed in Table D-l. All of these sources are firing oil with a sulfur con- tent of 1% or less. A switch to coal by these sources is not feasible since particulate standards were exceeded in this region during 1973. The use of higher sulfur oil may be possible depending on current air quality anal- ysis. Point source fuel combustion excluding power plants accounts for approximately one-percent of the particulate and sulfur dioxide emissions in the Maryland portion of the region. 3.1.4 Area Source Assessment Fuel use by area sources in this region is shown in Table E-l, and consists of primarily oil and natural gas as would be expected. Area sources afford little potential for clean fuel savings because of the economic con- siderations in changing fuel burning equipment. The primary means of achie- ving clean fuel savings by the sources that are firing coal or oil is a switch to a higher sulfur content fuel. Since this region is a marginal candidate for S02 emission relaxation, further study would be needed before any revisions are considered. Area source fuel combustion in the Maryland portion of this AQCR accounts for an estimated seventeen percent of the par- ticulate emissions and four percent of the sulfur dioxide emissions. 3.1.5 Fuel Use Assessment Fuel use by the region is shown in Appendix E. 3.2 CENTRAL MARYLAND INTRASTATE AIR QUALITY CONTROL REGION 3.2.1 Regional Assessment This region consists only of Frederick County and has no proposed AQMA for either particulate matter or sulfur dioxide. 17 ------- Suspended participate levels during 1973 in this region exceeded both the Federal annual and 24-hour standards (Table A-4). There is vir- tually no potential of relaxing particulate emission regulations and this region has been given a poor rating. Sulfur dioxide levels during 1973 were well below both the Federal and State standards, and there is a tolerance for an increase in SCL emis- sions without violating standards (Table A-5). This region has been rated as marginal for relaxation of SCL emission limits although few sources would derive any benefit from a revision. 3.2.2 Power Plant Assessment There are no power plants in this Air Quality Control Region. 3.2.3 Industrial, Commercial, Institutional Source Assessment The sources emitting 100 tons or more per year of either particulates or sulfur dioxide are listed in Table D-l. There is little potential for a clean fuel savings afforded by these sources although a switch to higher sulfur content oil may be possible. Point source fuel combustion accounts for an estimated four-percent of the particulate and twenty-six percent of the sulfur dioxide emissions in the region. 3.2.4 Area Source Assessment As shown in Table E-l, area sources account for a majority of the distillate oil use and all of the natural gas use in this region. As with point sources, there is little clean fuel savings potential. Area sources contribute an estimated nineteen-percent of the particulate emissions and thirty-seven percent of the sulfur dioxide emissions. 3.2.5 Fuel Use Assessment Fuel use data for the region are presented in Appendix E. 3.3 CUMBERLAND-KEYSER INTERSTATE AIR QUALITY CONTROL REGION 3.3.1 Regional Assessment Suspended particulate levels during 1973 exceeded the Federal annual 18 ------- and 24-hour standards (Table A-4). There are two counties that comprise a proposed Air Quality Maintenance Area for particulate matter in the Mary- land portion of this region. There is little potential for revising par- ticulate emission regulations in this region and has been rated as a poor candidate. Sulfur dioxide concentrations were not in violation of either the Federal or State annual and 24-hour standards during 1973. There is no proposed Air Quality Maintenance Area in this region for sulfur dioxide and is rated as a marginal candidate for relaxation of S0£ emission regulations. 3.3.2 Power Plant Assessment There is one Maryland power plant in this region, the R.P. Smith plant in Washington County. This is a coal fired plant, therefore, it does not have a fuel switch case. The average fuel sulfur content at this plant was less than 1% during 1973, and a possibility exists of allowing a higher sulfur content fuel to be used. There are no modeling data however, to de- termine the maximum allowable fuel sulfur content that could be used with- out violating air quality standards. This plant accounts for approximately nine percent of the particu'late emissions and sixteen percent of the sulfur dioxide emissions in the Maryland portion of the region. 3.3.3 Industrial, Commercial. Institutional Source Assessment There are several major fuel combustion sources in this region which are listed in Table D-l. Many of these sources are using high sulfur coal, affording little potential for clean fuel savings. Point source fuel com- bustion contributes approximately thirty percent of the particulate emissions and over seventy percent of the sulfur dioxide emissions in the region. 3.3.4 Area Source Assessment Area sources account for a small percentage of the fuel use in this region (Table E-l), but a significant amount of the particulate and SC>2 emis- sions. Again, there is little potential for clean fuel savings afforded by these sources. 19 ------- 3.3.5 Fuel Use Assessment Fuel use data by the region are presented in Appendix E. 3.4 EASTERN SHORE INTRASTATE AIR QUALITY CONTROL REGION 3.4.1 Regional Assessment Suspended particulate levels during 1973 exceeded only the secondary 24-hour standard at one monitoring site (Table A-4). However, this site is located near the northeast corner of the State and may not be representative of the AQCR. Ambient levels of sulfur dioxide did not exceed either the annual or 24-hour Federal and State standards, and based on the air quality data, there is a tolerance for an increase in S0£ levels without violating standards. There are no proposed Air Quality Maintenance Areas in this region for either particulate matter or sulfur dioxide and is rated as a good candidate for revision of S0£ emission limits. 3.4.2 Power Plant Assessment There are two power plants in this region, Vienna in Dorchester County, and Easton Utilities in Talbot County. These are both oil fired facilities, however the latter plant has very low fuel use. The Vienna plant has four boilers, three of which are convertible to coal. During 1973, the fuel oil sulfur content averaged 0.9%, increasing to 1.44% during the first part of 1974, during which time the plant operated under a variance. Since particulate levels in this region did exceed stan- dards during 1973, a switch to coal is impractical as particulate control at this plant is limited. Modeling results as shown in Table C-2 indicate that with a switch to coal, particulate emissions from this plant alone, under certain conditions, could cause violations of the 24-hour standard. The table also shows the maximum 24-hour S02 concentration that could be expected with a switch to 4% sulfur coal, indicating that Federal S0£ stan- dards would not be violated. There may be a possibility of allowing a higher sulfur content oil to be used at this plant than that used during 1973, how- ever more recent air quality data would have to be analyzed before any revision to existing emission limits are considered. 20 ------- 3.4.3 Industrial, Commercial, Institutional Source Assessment The major particulate and sulfur dioxide sources in this region are listed in Table D-l. Most of these sources are oil fired facilities, however with particulate standards having been exceeded, there is little potential for switching to coal. The use of higher sulfur fuel may be possible depending upon current air quality. Point source fuel combustion contributes approximately fourteen percent of the particulate emissions and a small amount of the sulfur dioxide emissions. 3.4.4 Area Source Assessment Area source fuel combustion accounts for approximately thirty-five percent of the particu'late emissions and twenty-three .percent of the sulfur dioxide emissions in this region. Fuel use by area sources is shown in Table E-l, indicating that these sources account for the majority of the distillate oil and natural gas use in the region. 3.4.5 Fuel Use Assessment , Fuel use data for the region is presented in Appendix E. 3.5 METROPOLITAN BALTIMORE INTRASTATE AIR QUALITY CONTROL REGION 3.5.1 Regional Assessment This region has been proposed as an Air Quality Maintenance Area for both particulate matter and sulfur dioxide. During 1973 suspended particulate levels were in violation of both the Federal annual and 24-hour primary standards. Both of these standards were exceeded at several locations in this region and a significant reduc- tion in these levels is needed to meet standards (Table A-4). This region has been rated as a poor candidate for relaxation of particulate emission regulations. Sulfur dioxide levels did not exceed the Federal annual or 24-hour standard during 1973 although the State standards were exceeded. Although the air quality data (Table A-5) indicate a tolerance for an increase in SOg levels, the region is rated as a poor candidate for regulation revision 21 ------- since it has been proposed as an AQMA for sulfur dioxide. 3.5.2 Power Plant Assessment There are twelve power plants in this region having a combined gen- erating capacity of over 2500 MW. These plants are primarily oil fired, although the H.A. Wagner plant fired coal and oil, and two plants fired blast furnace gas and coke oven gas. (Table C-l) Since there is a substantial amount of fuel oil used by these plants, there is a potential fuel saving. However, a switch to coal is precluded by the fact that particulate levels are exceeding standards in this region and may be further aggravated unless there is high particulate collection efficiency at these plants. Sulfur dioxide emissions could be increased based on air quality data, however the region has been rated poor as pre- viously discussed. Electricity generation accounts for approximately nine percent of the particulate emissions and forty-five percent of the sulfur dioxide emis- sions in the region. 3.5.3 Industrial, Commercial, Institutional Source Assessment There are several major fuel combustion sources in this region which are listed in Table D-l. All of these sources are firing oil, the majority of the fuel having a sulfur content of 0.8% or less. As with power plants, there is a clean fuel saving potential, however there is virtually no poten- tial for switching to coal or increasing the fuel sulfur content for the reasons mentioned above. Point source fuel combustion accounts for a small percentage of the particulate and sulfur dioxide emissions in the region. 3.5.4 Area Source Assessment Area sources contribute approximately thirty-three percent of the particulate emissions, and seventeen percent of the sulfur dioxide emissions in the region. Fuel use by area sources is shown in Table E-I indicating that these sources account for most of the distillate oil and natural gas use in the region. 22 ------- 3.5.5 Fuel Use Assessment Fuel use data for the region is presented in Appendix E. 3.6 SOUTHERN MARYLAND INTRASTATE AIR QUALITY CONTROL REGION 3.6.1 Regional Assessment There are no proposed Air Quality Maintenance Areas for either par- ti cul ate matter or sulfur dioxide in this region. Ambient levels of suspended particulates and sulfur dioxide did not exceed either the Federal or State standards during 1973, and air quality data indicate a tolerance for an increase in ambient concentrations while still maintaining air quality standards (Table A-4, A-5). This region has been rated as a good candidate for revision of both particulate and sulfur dioxide emission limits. 3.6.2 Power Plant Assessment There is one power plant in this region, the Morgantown plant in Charles County. This is a dual fired (coal and oil) facility burning a mix- ture of 75% oil and 25% coal. The sulfur content of the fuel averaged 1.7% during 1973 for both fuels. Since there is a tolerance for an increase in ambient particulate and sulfur dioxide levels in this region, a fuel savings potential exists either by a switch to full coal firing or the use of higher sulfur fuel. The plant has tall stacks (700 feet), high particulate collection efficiency and is located in a largely rural area without terrain features that would inhibit dispersion. Table C-2 shows the results of modeling analysis indicating the maxi- mum contribution by the plant to ambient particulate and sulfur dioxide levels. Based on 1973 air quality data, the emissions from the plant when using 3% sulfur coal would not cause violation of the Federal primary or secondary annual and 24-hour standards, for either pollutant, although the more adverse range of the State 24-hour standard would be violated. 23 ------- This plant accounts for a large percentage of the participate and sulfur dioxide emissions in the region as there are few other fuel combus- tion sources. 3.6.3 Industrial, Commercial, Institutional Source Assessment The major particuI ate and sulfur dioxide sources in this region are shown in Table D-I. The fuel used by these sources'is predominantly 0.8% sulfur oil affording a clean fuel saving potential although it is not sub- stantial. A switch to coal or higher sulfur oil may be possible since there is a tolerance for an increase in both particulate and S02 levels. 3.6.4 Area Source Assessment Area sources in this region do not afford a significant clean fuel saving potential. Area source fuel use is shown in Table E-l. 3.6.5 FueI Use Assessment Fuel use data for the region is presented in Appendix E. 24 ------- APPENDIX A STATE IMPLEMENTATION PLAN BACKGROUND ------- TABLE -A-l MARYLAND AIR POLLUTION CONTROL AREAS Air Quality Control Region National Capital Inter- State (D.C., Va.) Central Maryland Cumber land- Keys er Inter- state (W.Va.)c Eastern Shore Metropolitan Baltimore Federal Number 47 112 113 114 115 Classification3 TSP S0y NOX I I II II I I II III I I III III III III III Population 1975 (Millions) 3.16 0.09 0.23 0.22 2.23 rru(juseu , AQMA Designations0 TSP Counties Montgomery, Prince Georges None Allegany, Garrett, Cumberland City Hagerstown City None Anne Arundel , Baltimore County, Carroll SOX Counties None None None None Same Counties Southern Maryland 116 III III III 0.13 County, Harford County, Howard County, Baltimore City None As For Particulates None Criteria Based on Maximum (or Estimated) Pollution Concentration in Area Priority Sulfur Dioxide: Annual arithmetic mean 24-hour maximum Particulate 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 Federal Register, July, 1974 counties showing potential for NAAQS violations due to growth. c Originally designated as Interstate Abatement Conference Area ------- Federal State TABLE A-2 AMBIENT AIR QUALITY STANDARDS Total Suspended Particu1ates(ug/nr) Sulfur Dioxide(ug/rtr) Annual 24-Hour Annual 24-Hour 3-Hour 1-Hour Primary Secondary Serious Level More Adverse Range Upper Limit Lower Limit 75(G) 60(6) 75(A) 75(A) 65(A) 260a 150a 160a 160a 140a 80 (A) 79(A) 79(A) 39(A) 365a -- 262a 262a 131a _ _ _«_ _ 1300a 525b 525b 262b (G) Geometric mean (A) Arithmetic mean a - Not to be exceeded more than once per year b - Not to be exceeded more than once per month ------- TABLE A-3 AIR QUALITY STANDARDS ATTAINMENT DATESe Attainment Dates Air Quality Control Region National Capital Central Maryland Cumberland-Keyser Eastern Shore Metropolitan Baltimore Southern Maryland Federal Number 47 112 113 114 115 116 Parti Primary 7/75 7/75 7/75 b 7/75 b culates Secondary 7/75 7/75 7/75 7/75 7/75 b Sulfur Primary 7/75 a 7/75 b 7/75 b Dioxide Secondary 7/75 7/75 7/75 b 7/75 b From State Implementation Plan Air quality levels below standards ------- TABLE A-4 MARYLAND AIR QUALITY STATUS (1973), TSPa TSP Concentration (yg/m3) Air Quality Control Region National Capital Central Maryland Cumber! and- Keyser Eastern Shore Metropolitan Baltimore Southern Maryland # Stations Reporting 64 8 6 7 31 4 Highest Annual 85d 60f 85 85 60 132 38 Reading 24-Hr 668e 366f 210 423 207 415 120 2nd 24-Hr 351e 21 8f 197 185 206 403 102 Pri Annual 2 1 2 0 5 0 # Stations Exceeding Ambient Air Quality Standards mary Secondary 24-Hrb 3 0 0 0 5 0 . Annual 7 2 5 0 13 0 % 11 25 83 42 k 24-HrD 7 2 4 1 17 0 % 11 25 67 14 55 -- % Reduction Required to Meet Standards +65 +51 +51 +35 +80 -67 Standard on Which % Reduction Is Based 24-Hr. Annual Annual 24-Hr. Annual 24-Hr. Source: National Air Data Bank, July 28, 1974; Maryland State Yearly Air Quality Data Report, 1973 Violations based on more than one reading in excess of standard. Formula: Highest 24 Hr - 24 Hr Secondary Standard 2nd Highest 24-Hr - Background l) x 100, (i Annual - Annual Secondary Standard! ,nn Annual - Background ' x IUU Reading recorded in District of Columbia portion of AQCR, source: Annual Report on the Quality of the Air in Washington D.C. 1973 e Reading recorded in Virginia portion of AQCR Highest reading in Maryland Background Levels: 36 yg/m3 in National Capital, Central Maryland and Cumberland-Keyser AQCRs 46 yg/m3 in Eastern Shore AQCR 42 yg/m3 in Metropolitan Baltimore AQCR 30 yg/m3 in Southern Maryland AQCR ------- TABLE A-5 MARYLAND AIR QUALITY STATUS (1973), S023 SOo Concentrat1on(vig/rn # Stations Exceeding Air Quality Control Region National Capital Central Maryland Cumber! and-Keyser Eastern Shore Metropolitan Baltimore Southern Maryland Stations Reporting 24-Hr (Bubbler) 26 7 6 5 21 4 1 Stations Reporting (Contin. ) 12 0 2 0 9 0 Highest Annual 63d 34e 18 29 19 51 11 Reading 24-Hr 351d 202e 144 562 73 295 66 2nd Highest Reading 24-Hr 322d 1746 79 104 66 224 41 Ambient Air Quality Stds. Primary Secondary Annual 0 0 0 0 0 0 % 24-Hrb % 0 0 0 0 0 0 3-Hr 3 0 0 0 0 0 Reduction Required To Meet Standards - 13 -344 -176 -321 - 57 -627 Standard on Which % Reduction Is Based 24-Hr. Annual Annual Annual Annual Annual Source: Maryland State Yearly Air Quality Data Report, 1973; Annual Report on the Quality of the Air in Washington D.C. 1973 Violation based on 2nd highest reading at any station Formula: (2nd Highest 24-Hr - 24-Hr Standard \2nd Highest 24-Hr x 100, Annual - Annual Standard Annual Reading recorded in District of Columbia portion of AQCR Highest reading in Maryland l) x 100 ------- TABLE A-6 MARYLAND PARTICULATE EMISSIONS SUMMARY a Air Quality Control Region National Capital0 Central Maryland Cumber! and-Keyserc Eastern Shore Metropolitan Baltimore Southern Maryland Total Total (103 tons/yr) 14.1 2.7 5.7 4.9 36.8 7.4 71.6 % 20 4 8 7 51 10 100 c ieui.i i LI uy uener (103 tons/yr) 5.6 0 0.5 0.3 3.2 5.9 a \f 1 uii % 40 0 9 6 9 80 rumk ouurue ruei ou (IP3 tons/yr) 0.2 0.1 1.7 0.7 1.8 0.3 IllUUb L IUII % 1 4 30 14 5 4 nrea ouurue ruei uu (103 tons/yr) 2.4 2.5 1.8 1.7 12.1 0.4 MUUi % 17 19 32 35 33 5 Source: Maryland Bureau of Air Quality Control Emission Inventory Excludes emissions from electricity generation. c Figures are for Maryland portion of AQCR only. Includes emissions from major sources in Table D-l only. ------- TABLE A-7 MARYLAND SULFUR DIOXIDE EMISSIONS SUMMARY3 Air Quality Control Region National Capital0 Central Maryland Cumberl and-Keyser Eastern Shore Metropolitan Baltimore Southern Maryland Total Total (IP3 tons/yr) 131.8 2.7 27.2 13.7 1 36, 3 63.8 375.5 % 35 1 7 4 36 17 100 c leuu 11.1 \,y uener {103 tons/yr) 122.4 0 4.4 6.1 61.3 59.2 a i, iuii % 93 0 16 45 45 93 rum I juune ruei IAJ (103 tons/yr) 1.5 0.7 19.4 0.3 13.5 1.7 IHUUi t 1 UN % 1 26 71 2 10 3 nr ca ouur uc r uc i uu (103 tons/yr) 5.7 1.0 3.3 3.2 23.5 0.8 IIIULO % 4 37 12 23 17 1 a Source: Maryland Bureau of Air Quality Control Emission Inventory Excludes emissions from electricity generation. Includes emissions from major sources in Table D-l only. c Figures are for Maryland portion of AQCR only. ------- TABLE A-8 MARYLAND FUEL COMBUSTION SOURCE SUMMARY Air Quality Control Region National Capital Central Maryland ^ Cumberland-Keyser Eastern Shore Metropolitan Baltimore Southern Maryland Total ( Power Plants9 2 0 1 2 12 _]_ 18 )ther Fuel Combustion Point Sources Part. 1 0 3 1 1 _[ 7 so? 6 2 5 2 19 _2 36 Total Emissions0 10-3 tons/yr Part. SO? 14.Tc 131.8 2.7 2.7 5.7° 27.2 4.9 13.7 36.8 136.3 7.4 63.8 71.6 375.5 % Emissions From Maryland Fuel Combustion Sources Part. SO: 58 23 71 65 47 89 98 63 99 70 72 97 Maryland power plants only Maryland sources, which contribute 100 tons or more per year of particulate or sulfur dioxide emissions c Emissions from Maryland portion of AQCR only ------- TABLE A-9 SUMMARY OF MARYLAND FUEL COMBUSTION EMISSION REGULATIONS I Particulates A. Metropolitan Baltimore, National Capital Interstate AQCRs Insta11ation Description Residual oil burning; all installations up to 200 million BTU per hour heat input Residual oil burning; existing and modified installations Residual oil burning; new fuel burning equipment Distillate oil burning; all installations Solid fuel burning; all installations Max. rated heat input in million BTU per hour per furnace Less than 10b Less than 10 10-50 10-50 51-200 51-200 Greater than 200 Greater than 200 All sizes 200 or less Greater than 200 Max. Allowable Emission of particulate matter gr/SCFD No requirement 0.03 No requirement 0.025 No requirement 0.02 0.02 0.01 No requirement No requirement 0.05 0.03 Max. Allowable emission; Shell Bacharach smoke spot test number9 6 4 6 4 6 4 3 2 No requirement No requirement The method used for measurement of both residual and distillate oil burning equipment shall be in accordance with method D-2156 published by the American Society for Testing and Materials. Construction of Residual oil fired units of less than 5 million BTU/hour prohibited after February 21, 1971 B. Cumber!and-Keyser, Central Maryland, Southern Maryland, Eastern Shore AQCRs (1) Installations built before January 17, 1972 See Figure A-l ------- Figure A-l Maximum Allowable Discharge of Particulate Matter From Existing and Modified Fuel Burning Installations (Installations Built Before January 17, 1972) OJ -C 01 t/j c 5£ O) ^ a s- -u U O 3 i- Q. C. 4-> C S- cy ii ro -M a. <9 -4-> r- 13 T3 3 O) V o ;c i rc < Q. E v> 3 "O E C r- 3 X O fa a. 10 100 1000 10000 Total Input - Millions of BTU Per Hour ------- (2) Plants built on or after January 17, 1972 Installation Description Residual oil burning0 Distillate oil burning Solid fue,l burning Max. rated heat input in mi 11 ion BTU per hour per furnace 5-10 10-51 51-200 greater than 200 all sizes all sizes Max. allowable emissions of particulate matter qr/SCFD 0.03 0.025 0.02 0.01 no requirement 0.03 Max. allowable emission; Shell Bacharach Smoke Spot test number3 4 4 4 4 no requirement The method used for measurement of both residual and distillate oil burning equipment shall be in accordance with method D-2156 published by the American Society for Testing and Materials. No new coal burning plants having a rated heat input of less than 250 million BTU per hour are allowed No new residual oil burning plants having a rated heat input of less than 5 million BTU per hour are allowed. ------- II Sulfur Oxides A. Metropolitan Baltimore AQCR 1) All fuels are to contain 1% or less sulfur by weight 2) Distillate fuel oils to contain 0.3% or less sulfur by weight 3) Residual fuel oils to contain 0.5% sulfur by weight on and after July 1, 1975 4) Process gases used as fuel in existing installations to contain 0.3% or less sulfur by weight B. National Capital AQCR Same as 1, 2, 3, above C. Cumberland-Keyser, Central Maryland, Southern Maryland, Eastern Shore AQCRs 1) All solid fuels burned on a premise where the sum total maximum rated heat input of all fuel burning equipment loc'ated on the premises is 100 million BTU/Hour or greater, shall contain 1% or less sulfur by weight. 2) All residual fuel oil shall contain 1% or less sulfur by weight until July 1, 1975 at which time the fuel shall contain 0.5% or less sulfur by weight. 3) All distillate fuel oil shall contain 0.3% or less sulfur by weight. ------- APPENDIX B REGIONAL SUMMARY ------- TABt£ B-l REGIONAL INDICATORS FOR REVISION OF PARTICULATE EMISSION REGULATIONS Air Quality Control Region National Capital Central Maryland Cumberland-Keyser Eastern Shore Metropolitan Baltimore Southern Maryland Air Number of Stations 64 8 6 7 31 4 Quality Number of Violations 14 4 9 1 30 0 Parti cul ate Emissions (IP3 tons/yr) 14.1 2.7 5.7 4.9 36.8 7.4 % .Emiss-ions From MD. Fuel Combustion 58 23 71 65 47 89 TSP Priority I II I II I III Attainment Dates 7/75 7/75 7/75 7/75 7/75 b AQMAs Proposed? Yes No Yes Yes Yes No a Total number of violations of annual and 24-hour secondary standard Air quality levels below standards ------- TABLE B-2 REGIONAL INDICATORS FOR REVISION OF SULFUR DIOXIDE EMISSION REGULATIONS Air Quality Control Recrion National Capital Central Maryland Cumberl and-Keyser Eastern Shore Metropolitan Baltimore Southern Maryland nil L; Number of Stations3 38 7 8 5 30 4 Number of Violations 0 0 0 0 0 0 SO 2 Emissions (103 tons/yr) 131.8 2.7 27.2 13.7 136.3 63.8 % Emissions From MD. Fuel Combustion 98 63 99 70 72 97 S02 Priori ty I II I III I III Attainment Dates 7/75 . 7/75 7/75 b 7/75 fa AQMAs Proposed? No No No No Yes No Total 24-hour bubbler and continuous monitoring stations Air quality levels below standards ------- APPENDIX C POWER PLANT SUMMARY ------- TABLE C-l POWER PLANT TUEL USE SUMMARY* Fuel Use Emissions(Tons/Year) nil v^ u a i i ujr Control Region National Capital Cumber! and-Keyser Eastern Shore Metropolitan Baltimore Plant Chalk Point Dickerson R.P. Smith Vienna Easton Utilities C.P. Crane Gould Street H.A. Wagner Riverside Westport Perryman Phi ladelphia Rd. Notch Cliff Spring Garden Terminal B Streetd i :? / o oajjai, i uy (MW) 728.0 660. Oc 586.5 109.5 256.5 23.0 399.79 173.5 980.0 333.5 194.0 220.0 60.0 120.0 Type Coal Oil Coal Oil Coal Oil Oil Oil Oil Coal Oil Oil Oil Oi 1 Oil Gas Oil Gas Oil Gas Oil Gase % S 1.64 1.7 1.64 0.92 0.9 0.54 0.93 0.9 0.96 0.95 0.93 Quantity" 1,500 112 1 ,400 74 232 2,332 54 4,181 1 ,440 749 5,190 2,270 1 ,007 464 245 1,471 76 808 90 1,684 306 39,584 Part. 3,357 2,253 512 308 34 368 81 1,782 482 294 82 43 27 46 SO? 62,861 59,528 4,399 6,122 30 10,820 2,544 32,439 7,317 2,716 402 219 60 85 967 ------- TABLE C-l cont. Air Quality Control Region Metropolitan Baltimore (cont.) Southern Maryland Fuel Use Plant Penwood" Morgantown Emi ssi ons(Tons/Year) i y / o oajjau i \,y (MW) 1451.0 Type Oil Gase Gasf Coal Oil % S 0.8 1.72 1.73 Quantity13 1,190 96,848 3,375 550 7,229 Part. S09 3,748 5,882 59,185 Source: Maryland Registration Survey, Bureau of Air Quality Control, Dec. 31, 1974 Fuel Quantity: coal is in I03 tons, oil is in 103'barrels, gas is in I06 cu. ft. c Additional unit presently operating Plants located at Bethlehem Steel, Sparrows Point e Blast furnace gas Coke oven gas ------- Air Quality Control Jtegion National Capital Eastern Shore Southern Maryland TABLE C-2 SUMMARY OF POWER PLANT MODELING RESULTS3 Maximum 24-Hour Concentration(pg/m^) S02 Particulates Maximum Annual Plant Chalk Point 1972 Operations Fuel Switch13 Vienna 1972 Operations Fuel Switch0 Morgantown 1972 Operations Fuel Switch b Nominal Load 108 146 13 166 94 178 Maximum Load 114 155 17 226 51 no Nominal Load 3 21 3 371 2 40 Maximum Load 3 22 4 505 2 39 Concentration (yg/nr) SO? 5 7 1 11 2 4 Parti culates <1 1 <1 24 <1 <1 Source: Modeling Analysis of Power Plants For Fuel Conversion (Group III) Maiden Research, Sept. 9, 1974 Switch to 3.0% sulfur coal Switch to 4.0% sulfur coal ------- ADDENDUM TO APPENDIX. C USE AND LIMITATIONS OF MODELING ANALYSIS DATA9 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 situa- tion involved. In some cases it will be necessary to adjust the model's predictions based upon more complete and detailed information on a partic- ular plant's operations. 3. Results of these evaluations are 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 reasonable 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 ------- APPENDIX D INDUSTRIAL, COMMERCIAL, INSTITUTIONAL SOURCE SUMMARY ------- TABLE D-l INDUSTRIAL, COMMERCIAL, INSTITUTIONAL SOURCE ASSESSMENT' Air Quality Control Region National Capital Central Maryland Cumber Iand-Keyser Source National Naval Medical Center Andrews AFB National Institutes of Health Agricultural Research Center Naval Ordnance Lab Fort Detrick Mount St. Mary's College West Virginia Pulp & Paper Kelly-Springfield Western Maryland R.R. PPG Industries Maryland Correctional Number of Boi lers _ _ 12 4 13 4 5 2 3 3 2 3 3 Boi ler Capacity (IQ6 BTU/Hr) _.. 21-66 60 8-55 23-59 44-165 8-15 338 590 785 135 40 45 36-100 Type Oil Oil Oil Oil Oil Oil Coal Oil Coal Coal Oil Coal Coal Coal Fuel % S 0.6 1.0 0..3 0.6 0.9 0.8 2.41 0.6 2.7 2.4 0.8 2.6 1.5 2.45 Amount'3 215 171 48 42 47 141 8 256 168 216 276 11 22 80 Emissions Part. 105 23 60 28 23 67 51 1 ,206 66 151 210 80 (Tons/Yr) S02 571 434 276 134 122 363 333 17,467 728 530 405 252 Institute ------- TABLE D-l INDUSTRIAL, COMMERCIAL, INSTITUTIONAL SOURCE ASSESSMENT' Air Quality Control Region National Capital Central Maryland Cumber Iand-Keyser Source National Naval Medical Center Andrews AFB National Institutes of Health Agricultural Research Center Naval Ordnance Lab Fort Detrick Mount St. Mary's College West Virginia Pulp & Paper Kel ly-Springfield Western Maryland R.R. PPG Industries Maryland Correctional Number of Boi lers __ 12 4 13 4 5 2 3 3 2 3 3 Boi ler Capaci ty (106 BTU/Hr) __. 21-66 60 8-55 23-59 44-165 8-15 338 590 785 135 40 45 36-100 Type Oil Oil Oil Oil Oil Oil Coal Oil Coal Coal Oil Coal Coal Coal Fuel % S 0.6 1.0 0.3 0.6 0.9 0.8 2.41 0.6 2.7 2.4 0.8 2.6 1.5 2.45 Amount13 215 171 48 42 47 141 8 256 168 216 276 II 22 80 Emissions Part. 105 23 60 28 23 67 51 1 ,206 66 151 210 80 (Tons/Yr) S02 571 434 276 134 122 363 333 17,467 728 530 405 252 Institute ------- TABLE D-l cont. Air Quality Control Region Eastern Shore Metropolitan Baltimore Source Firestone Plastics Eastern Shore Rendering Chesapeake Plywood Bethlehem Steel FMC Corp. American Sugar Co. AMOCO Oil Co. EXXON Chevron Asphalt Co. Allied Chemical Proctor & Gamble Springfield State Hospital Fort Meade Baltimore City Number of Boilers 2 4 3 4 2 3 2 2 2 2 16 4 Boiler Capacii (106 BTU/Hr) 93 24-28 ___ 44-97 130 75 121 68 42-50 80-125 85 7-57 71 . H\/ ty Type Oil Oil Oil Wood Gas #3 Oi 1 #4-6 Oil Oil Oil Oil Oil Oil Oil Oil Oil Oil Oil Fuel % S 0.8 0.8 0.8 0.8 0.8 0.8 0.8 0.8 0.8 0.8 0.3 0.8 Amount^ 56 44 1.5 52 1,519 1,905 2 ,000 189 200 96 143 120 105 131 85 217 54 Emissions Part. 27 24 650 1,133 51 33 29 48 58 19 12 32 69 35 (Tons/Yr) SO? 146 132 17 8,830 566 528 511 395 319 250' 250 228 196 196 Hospital 203 North Avenue Complex 180 Oi 0.8 142 35 190 ------- TABLE D-l cont. Air Quality Control Region Metropolitan Baltimore (cont.) Southern Maryland Number of Source Boilers Simkins Industries Bethlehem Steel D.C. Children's 8 Center Spring Grove State 3 Hospital Edgewood Arsenal Aberdeen Proving Grounds Maryland Shipbuilding . 4 & Dry Dock Naval Ordnance Station 6 Patuxent Naval Air 4 Station POT T o y* fir^ioT "^ \/ DU 1 Icr LdpaCI Ly (106 BTU/Hr) Type Oil fl-2 Oil #4-6 Oil 15-40 Oil 75 Oil Oil Oil 8-22 Oil 20-180 Oil Coal 14-65 Oil Oil Fuel % S 0.8 0.8 0.3 0.8 0.8 1.0 0.3 0.8 Amount'3 71 0.6 69 53 119 132 146 45 474 0.6 29 138 Emissions Part. 35 33 47 10 42 44 20 236 75 (Tons/Yr) SOp 186 179 139 138 124 122 II 9 1,321 392 Sources which emit 100 tons or more per year of particulates or sulfur dioxide. Sources are listed in decreasing order of S02 emissions. Data taken from Maryland Registration Survey, Bureau of Air Quality Control, Dec. 31, 1974 Fuel Quantity: coal is in 10^ tons/year, oil is in 103 BBLS/year, gas is in lO^ cu. ft. ------- APPENDIX E AQCR FUEL USE SUMMARY ------- TABLE E-l FUEL USE SUMMARY' Air Quality Control Region National Capital Area Sources Point Sources Total Central Maryland Area Sources Point Sources Total Cumberland-Keyser Area Sources Point Sources Eastern Shore Area Sources Point Sources Total Total Metropolitan Baltimore Area Sources Point Sources Total Southern Maryland Area Sources Point Sources Total Coal (103 tons) Anthracite Bituminous Oil(103 Barrels) Residual Distillate Gas(106 cu.ft.) Natural Process 9 1 10 3 0 3 35 0 35 3 0 3 21 0 21 0.3 0 0.3 81 4,444 4,525 1 105 106 5 240 245 3 7 10 24 934 958 0.1 540.6 540.7 8,246 13,601 21,847 58 276 334 151 759 910 257 2,859 3,116 2,510 11,761 14,271 48 7,710 7,758 7,009 280 7,289 521 34 555 0 0 0 1,645 118 1,763 8,136 2,066 10,202 555 350 905 108,510 1,214 109,724 2,020 0 2,020 9,870 108 9,978 6,710 945 7,655 68,600 27,890 96,490 1,610 0 1,610 0 0 0 . 0 0 0 0 0 0 0 0 0 0 843 843 o 0 0 Source: Stationary Source Fuel Summary Report (NEDS) December, 1974 ------- TECHNICAL REPORT DATA (Please read laslntctions on the reverse before completing) 1. REPORT NO. EPA-450/3-75-017 3. RECIPIENT'S ACCESSION-NO. 4. TITLE AND SUBTITLE 5. REPORT DATE IMPLEMENTATION PLAN REVIEW FOR MARYLAND AS REQUIRED BY THE ENERGY SUPPLY AND ENVIRONMENTAL COORDINATION ACT 6. PERFORMING ORGANIZATION CODE 7. AUTHOR(S) 8. PERFORMING ORGANIZATION. REPORT NO. 9. PERFORMING ORGANIZATION NAME AND ADDRESS 10. PROGRAM ELEMENT NO. U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards, Research Triangle Park, N.C., Regional Office III, Philadelphia, Pa., 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 277H 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 EPA1s 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 18. DISTRIBUTION STATEMENT Release unlimited 19. SECURITY CLASS (This Report) Unclassified 21. NO. OF PAGES 53 20. SECURITY CLASS (This page) Uncl assified 22. PRICE EPA Form 2220-1 (9-73) ------- |