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

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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

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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

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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

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             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

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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

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                                        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

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                                                                        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

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                                                                        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

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                                                                     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.

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                                                                     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.

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                                                     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

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                                   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 i—i
 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.

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   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

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                                                           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)

-------