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
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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
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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
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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 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.
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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 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.
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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.
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Part of each State's review was organized to provide an analysis of
the S02 and TSP emission tolerances within each of the various 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.
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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.
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
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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, 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
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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.
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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.
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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
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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
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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
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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
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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
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14
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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 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
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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
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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)
------- |