EPA-450/3-75-021
March 1975
IMPLEMENTATION PLAN REVIEW
FOR
MONTANA
AS REQUIRED
BY
THE ENERGY SUPPLY
AND
ENVIRONMENTAL COORDINATION ACT
U. S. ENVIRONMENTAL PROTECTION AGENCY
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EPA-450/3-75-021
IMPLEMENTATION PLAN REVIEW
FOR
MONTANA
REQUIRED BY THE ENERGY SUPPLY AND ENVIRONMENTAL COORDINATION ACT
PREPARED BY THE FOLLOWING TASK FORCE:
U. S. Environmental Protection Agency, Region VIII
1860 Lincoln Tower Building
Denver, Colorado 80203
Environmental Services of TRW, Inc.
(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
March 1975
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ii
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TABLE OF CONTENTS
MONTANA
Page
1.0 EXECUTIVE SUMMARY 1
2.0 REVIEW OF THE STATE IMPLEMENTATION PLAN AND CURRENT AIR QUALITY . t 6
2.1 Summary 6
2.2 Air Quality Setting for the State of Montana • • • 10
2.3 Background on the Development of the Current State Imple-
mentation Plan 13
2.4 Special Considerations for the State of Montana 14
2.5 Energy Supply Potential of Montana 14
3.0 AQCR ASSESSMENTS 15
3.1 Regional Air Quality Assessments 15
3.2 Power Plant Assessments 16
3.3 Industrial/Commercial/Institutional Source Assessments .... 17
3.4 Area Source Assessments 18
3.5 Stationary Fuel Source Summary 18
4.0 TECHNICAL APPENDICES
APPENDIX A A-l
APPENDIX B B-l
APPENDIX C C-l
APPENDIX D D-l
APPENDIX E E-l
BIBLIOGRAPHY
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1.0 EXECUTIVE SUMMARY
The enclosed report is the U. S. Environmental Protection Agency's
(EPA) response to Section IV of the Energy Supply and Environmental
Coordination Act of 1974 (ESECA). Section IV requires EPA to review each
State 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 stationary sources within three months after they are sub-
mitted to EPA by the States. The States may, as in the Clean Air Act of
1970, initiate State Implementation Plan revisions; ESECA does not, how-
ever, require States to change any existing plans.
Congress has intended that this report provide the State with infor-
mation on excessively restrictive control regulations. The intent of
ESECA is that SIPs, wherever possible, be revised in the interest of con-
serving 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 NAAQSs
it may be plausible that fuel resource allocations can be altered for
"clean fuel savings" in a manner consistent with both environmental and
national energy needs.
In many respects, the ESECA SIP reviews parallel EPA's policy on clean
fuels. The Clean Fuels Policy has consisted of reviewing implementation
plans with regards to saving low sulfur fuels and, where the primary sulfur
dioxide air quality standards were not exceeded, to encourage States to
either defer compliance regulations or to revise the S02 emission 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 re-
vised or are currently in the process of revising S02 regulations. These
states are generally in the Eastern half of the United States. ESECA,
however, extends the analysis of potentially over-restrictive regulations
to all 55 States and territories. In addition, the current reviews ad*
dress the attainment and maintenance of all the National Ambient Air Quality
Standards.
There are, in general, three predominant reasons for the existence of
overly restrictive emission limitations within the State Implementation
Plans. These are: (1) the use of the example region approach in develop-
ing statewide air quality control strategies; (2) the existence of State
Air Quality Standards which are more stringent than NAAQS; and (3) the "hot
spots" in only part of an Air Quality Control Region (AQCR) which have been
used as the basis for controlling the entire region. Since each of these
situations affect many State plans and in some instances conflict with
current national energy concerns, a review of the State Implementation Plans
is a logical follow-up to EPA's initial appraisal of the SIP's conducted
in 1972. At that time SIPs were approved by EPA if they demonstrated the
attainment of NAAQS or more stringent state air quality standards. Also,
at that time an acceptable method for formulating control strategies was
the use of an example region for demonstrating the attainment of the stan-
dards.
The example region concept permitted a State to identify the most
polluted air quality control region 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 exces-
sive controls, especially in the utilization of clean fuels, for areas of
the State where sources would not otherwise contribute to NAAQS violations.
For instance, a control strategy based on a particular region or source
can result in a regulation requiring one percent sulfur oil to be burned
statewide where the use of a three percent sulfur coal would be adequate
to attain NAAQS in some locations.
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EPA anticipates that a number of States will use the review findings
to assist them in making the decision whether or not to revise portions of
their State Implementation Plans. However, it is most important for those
States which desire to submit a revised plan to recognize the review's
limitations. 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 avail-
able by which to address individual point source emissions. Where the modeling
data for specific sources were found, however, they were used in the analysis.
The data upon which the reports' findings are based in the most currently
available to the Federal Government. However, EPA believes that the States
possess the best information for developing revised plans. The States have
the most up-to-date air quality and emissions data, a better feel for growth,
and the fullest understanding for the complex problems facing them in the
attainment and maintenance of air quality standards. 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 perspec-
tive with all sources of emissions such as smelters or other industrial
processes. States are encouraged to consider the overall impact which the
potential relaxation of overly restrictive emissions regulations for combus-
tion 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 problems such as sulfates.
Although the enclosed analysis has attempted to address the attainment
of all the NAAQS, most of the review has focused on total suspended parti-
culate matter (TSP) and sulfur dioxide ($02) emissions. This is because
stationary fuel combustion sources often 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 assessments
have been combined in Appendix B with other regional air quality "indicators"
in an attempt to provide an evaluation of a region's candidacy for changing
emission limitation regulations. In conjunction with the regional analysis,
a summary of the State's fuel combustion sources (power plants, industrial
sources, and area sources) has been carried out in Appendix C, D, and E. A
map showing Montana'and its AQCRs is shown on the following page.
FINDINGS
The Montana Implementation Plan has been reviewed for the
most frequent causes of over-restrictive emission limiting
regulations. Although a statewide approach was used in
developing control strategies for TSP, and Montana has
slightly more stringent air quality standards than the NAAQS,
there are no indications that current TSP regulations are
overly restrictive in the context of Section IV of ESECA.
There are indications of generally widespread TSP problems
in the State, with NAAQS TSP violations occurring in all
AQCRs except Great Falls. Since the State's fuel combustion
sources are generally operating well within the State's TSP
emission regulations, increases in particulate emissions could
occur without relaxation of the existing regulation. Any
increase in particulate emission levels would tend to aggravate
the current.TSP situation. Therefore, Montana's particulate
emission regulation for fuel burning sources is not a good
candidate for revision.
There are tolerances for increased SCL emissions in the Great
Falls and Miles City AQCRs. The State's fuel combustion
sources are generally in compliance with the State's S0? emis-
sion regulation. Thus, there are indications that this
regulation may be overly restrictive in these two AQCRs.
The Helena AQCR contains three counties with AQMA designations
for SCL, and this AQCR also exhibits NAAQS violations for this
pollutant. Therefore, it has no tolerance for increased S02
emissions and should not be a candidate for regulation relaxation.
For the remaining two AQCRs (Billings and Missoula), there is
insufficient S0£ air quality data to determine whether they have
a tolerance for emissions increase.
Little clean fuel savings are possible from Montana power plants
since coal is the predominant fuel used in these facilities.
Natural gas is the main fuel used by the State's major industrial
fuel burning sources, but the feasibility of these facilities
switching to other (dirtier) fuels is unknown.
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(141)
GREAT FALLS
INTRASTATE
(143)
MILES CITY
INTRASTATE
en
(144)
MISSOULA
INTRASTATE
(142)
HELENA
INTRASTATE
(140)
BILLINGS
INTRASTATE
Figure 1. Air Quality Control Regions in Montana
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2.0 STATE IMPLEMENTATION PLAN REVIEW
2.1 SUMMARY
A revision of fuel combustion source emissions regulations will
depend on many factors. For example:
• Does the State have air quality standards which are more
stringent than NAAQS?
t Does the SIP have emission limiting regulations for control
of existing (1) power plants, (2) industrial sources, and
(3) area sources.
t 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
sources emission regulations for fuel savings; i.e., under
the Clean Fuels Policy?
• Are there Air Quality Maintenance Areas?
• Are there indications of a sufficient number of monitoring
sites within a region?
• Is there an expected 1975 attainment date for NAAQS?
• Based on reported (1973) Air Quality Data, does air quality
meet NAAQS?
• Based on reported (1973) Air Quality Data, are there indica-
tions of a tolerance for increasing emissions?
• Are the total emissions from stationary fuel combustion
sources lower than those of other sources?
t Do modeling results for specific fuel combustion sources
show a potential for a regulation revision?
t Must emission regulations be revised to accomplish signifi-
cant fuel switching?
t Based on the above indicators, what is the potential for
revising fuel combustion source emission limiting regulations?
• Is there a significant Clean Fuels Saving potential in the
region?
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The following portion of this report is directed at answering these
questions.
The initial part of the SIP Review Report, Section 2 and Appendix A,
was organized to provide the background and current situation infor-
mation for the State Implementation Plan. Section 3 and the remaining
Appendices provide an AQCR analysis which helps establish the overall
potential for revising regulations. Emission tolerance estimates have
been combined in Appendix B with other regional air quality "indicators"
in an attempt to provide an evaluation of a region's candidacy for revising
emission limiting regulation. In conjunction with the regional analysis, a
characterization of the State's fuel combustion sources (power plants,
industrial sources, and area sources) has been carried out in Appendices C,
D and E.
Based on an overall evaluation of EPA's current information, AQCRs have
been classified as "good," "marginal," or "poor" candidates for regulations
revisions. These ratings, which are shown in the Summary Table on Page 9
were determined by assessing the following criteria;
Good Poor Marginal
1) Adequate number !);•Violation of NAAQS 1) No air quality data
of air monitoring 2) Attainment date for or insufficient number
sites . NAAQS later than of monitoring sites
2) No NAAQS violations 1975 2) Inconsistent
3) Attainment date of 3) Proposed AQMA "indicators"
1975 for NAAQS in 4) Modeling results
tne MK show no potential
4) No proposed AQMAs for regulation
5) Modeling results revision
show a potential
for revision
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
7
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other conditions listed under "Poor" exists, the AQCR would still receive
that rating. The predominant reason for a marginal rating is a lack of
sufficient air quality data. 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 indi-
cated to be a good candidate for regulation revision should be examined in
more detail by the state and the regional office of the EPA, including an
examination of current air quality, emissions, and fuel use data, with which
the state has more familiarity. If the state feels that clean fuels could
be saved in a region rated marginal, then an analysis of air quality data
that may have become available since this report should be examined. If
current data do not indicate a potential for regulation revision then
further study would not be warranted. An AQCR that has been indicated to be
a poor candidate would not warrant further study unless the state feels that
new information has become available indicating that the poor rating is no
longer valid.
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STATE IMPLEMENTATION PLAN REVIEW
(SUMMARY TABLE)
(110) (140 (142) (143) (144)
Billings Great Falls Helena Miles Citv Missoula
"INDICATORS"
• Does the State have air quality standards
which are more stringent than NAAQS?
• Does the State have emission limiting regu-
lations for control of:
1. Power plants
2. Industrial sources
3. Area sources
• Did the State use an example region approach
for demonstrating the attainment of NAAQS or
more stringent State standards?
« Has the State not initiated action to modify
combustion source emission regulations for fuel
savings; i.e., under the Clean Fuels Policy?
• Are there Air Quality Maintenance
Areas?
t Are there indications of a sufficient number
of monitoring sites within a region?
• Is there an expected 1975 attainment date
for NAAQS?
I Based on reported (1973) Air Quality Data,
does air quality meet NAAQS?
• Based on reported (1973) Air Quality Data,
are there indications of a tolerance for
increasing emissions?
t Are the total emissions from stationary fuel
combustion sources lower than those of other
sources?
• Do modeling results for specific fuel combustion
sources show a potential for a regulation revision?
• Must emission regulations be revised to accom-c
plish significant fuel switching?
• Based on the above indicators, what is the
potential for revising fuel combustion source
emission limiting regulations?
• Is there a significant Clean Fuels Saving
potential in the region?
STATE AQCP. AQCR AQCR AQCR AQCR
TSP
Yes
Yes
Yes
No
Yes
SD?
Yes
Yes
No
II 0
Yes
TSP
Yes
Yes
Yes
do
Do
Yes
b
No
Poor
No
S
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2.2 AIR QUALITY SETTING FOR THE STATE OF MONTANA
The State of Montana is one of four states in EPA Region VIII. (The
other states are Colorado, Utah and Wyoming.) Montana is divided into five
AQCRs. These are listed below:
140 - Billings Intrastate
141 - Great Falls Intrastate
142 - Helena Intrastate •
143 - Miles City Intrastate
144 - Missoula Intrastate
The three digit number in the above listing has been assigned by EPA as a part
of a nationwide numbering system for all AQCRs. Figure A-l shows the boundaries
of Montana's AQCRs, and outlines the State's counties. None of the AQCRs have
boundaries which cross state lines.
Tables A-l, A-2 and A-3 summarize additional general information which
characterizes Montana's air quality, and provides other parameters concerning
the AQCRs. In Table A-l the following information is presented:
1) Priority classifications for the pollutants under study.
2) Demographic data
3) Counties within the State which have been designated Air
Quality Maintenance Areas (AQMA).
Priority classifications give an indication of the extent to which
certain pollutants pose air quality problems for the AQCR. A Priority I list-
ing indicates that relatively high ambient concentrations have been either
observed, estimated (in the absence of adequate measured air quality data), or
predicted (due to the expected presence of future sources). In those Priority I
areas where the air quality reflects emissions predominantly from a single
point source, the I-A classification is used. A Priority III designation is
used when pollutant concentrations are generally lower than NAAQS. A Priority II
designation indicates intermediate pollutant levels.
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With respect to the pollutants under study, Table A-l indicates the
existence of air quality problems in the Helena AQCR since it is classified
I-A for both parti culates and SO,,. The only other AQCRs where potentially
serious problems are indicated are the Great Falls AQCR (141) which is
classified I-A for S02, and the Missoula AQCR (144) which is designated
Priority I for particulates.
AQMA designations are a way of identifying those areas in the state
which, due to current air quality and/or projected growth rate, may have the
potential for exceeding any national standard within the ten year period
1975-1985. These designations are proposed by either the state, or by the
Regional EPA Office. As an AQMA, it is likely that more restrictive changes
will have to be made to existent regulations and/or air pollution control
plans. Montana has acted to formally designate six areas in the State as
AQMAs. The counties comprising these designated areas are listed in
Table A-l.
Table A-2 presents the dates when the ambient levels of the pollutants
under study is expected to be within the limits set by NAAQS. The only AQCR
with an attainment date later than the July 1975 date originally prescribed
by law is the Helena AQCR. Due to the operation of two smelters, attainment
of the primary S02 standard in this AQCR was delayed until July 1977. In
addition, EPA granted the State an 18-month extension of the statutory time-
table for submission of the plan for attainment and maintenance of the
secondary standards for sulfur oxides in this AQCR.
A summary of the federal and Montana Air Quality Standards for the
pollutants under study is presented in Table A-3. The Montana annual standard
for particulates is identical to the Federal Primary Standard, while the level
required by the State's 24-hour standard is midway between the Federal Primary
and Secondary Standards. The Montana Air Quality Standards for S02 are more
stringent than the federal S02 standards. Montana does not have an NO,,
standard.
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As shown on Table A-4, the Montana Monitoring Network for suspended
particulate matter consists of 35 stations. There are at least four moni-
toring sites in each Montana AQCR. Ambient monitoring of S02 is limited
within the State. According to 1973 National Aerometric Data Bank (NADB)
information, Montana has a total of 10 SOp monitoring sites. Seven of
these sites use the bubbler method of analysis (West-Gaeke sulfamic acid
24-hour bubbler), while the remaining three sites use the continuous
(coulometric) method of analysis. None of the State's monitoring sites have
both types of equipment.
Tables A-4 and A-5 also present summaries of Montana's particulate and
S02 air quality status for the year 1973. These summaries include highest
and second highest recordings, number of stations exceeding NAAQS, and the
emission reductions required to meet federal ambient air quality standards.
Table A-4 shows particulate NAAQS violations in all except the Great Falls
AQCR (141). Three of the monitors in this AQCR recorded TSP levels which
exceeded the national secondary standard, but since only one excess was
measured at each of three stations, no NAAQS TSP violation was recorded.
(Violations are based on more than one excess at each station.) Based on
existing monitoring, only the Helena AQCR (142) showed a violation of NAAQS
$62 standards.
Table A-6 provides a tabulation of power plants and fuel burning point
sources that produce particulate and S(L emissions. The information obtained
from the National Emission Data System (NEDS) and Federal Power Commission
(FPC) show agreement. However, recent information from the EPA Regional Office
indicates additional power plants in the State. These additional facilities
include plants which are small (less than 10 megawatts electric) and also
diesel powered plants. The three plants identified by the NEDS and FPC
listings comprise the State's major power plants and for that reason are the
ones of most interest for the purposes of this review.
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2.3 BACKGROUND OF THE DEVELOPMENT OF THE CURRENT STATE IMPLEMENTATION
PLAN
The State Implementation Plan control strategies and regulations were
based on a statewide approach. Demonstration of the attainment of the
particulate standards was done on a region-by-region basis. The control
strategies and regulations as submitted by the State were adequate to
attain NAAQS for particulates in Montana.
The State did not include a discussion of its control strategy for
sulfur oxides in the submitted plan, however Montana does have a regulation
controlling the sulfur content of solid, liquid and gaseous fuels. EPA
evaluated the adequacy of this regulation for achievement of NAAQS in all
AQCRs. Except for the Helena AQCR, this regulation was found adequate to
achieve NAAQS for SO,, in the State of Montana.
The attainment and maintenance of all national standards for S02
could not be demonstrated by applying this regulation to sources in the
Helena AQCR. There are two significant sources for sulfur oxides in this
AQCR: the first is a lead smelter in East Helena and the second is a copper
smelter in Anaconda. The Environmental Protection Agency used a diffusion
model and ambient air quality monitoring to determine that more than
reasonably available control technology would be required for the Anaconda
smelter to reduce emissions enough to attain and maintain the primary SOg
standard by 1975. It was on the basis of this finding that EPA granted
the two year and 18-month extensions mentioned in the previous section.
Adequate sulfur oxides control regulations applicable to non-ferrous
smelters were not included in the SIP; however, both EPA and the State are
developing such regulations.
Montana's fuel combustion source emission control regulations are
summarized in Table A-10. The regulation for the control of particulate
matter uses a sliding scale format and the maximum level of allowable
emissions is stated in terms of pounds of particulate matter per million
Btu heat input. Differing limits apply to new and existing sources.
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The State regulation to control S02 from fuel combustion sources
places limits on the sulfur content of fuels used in these sources. This
regulation is applicable to new, existing and modified sources in the
State of Montana.
2.4 SPECIAL CONSIDERATIONS FOR THE STATE OF MONTANA
A total of 16 counties and one Indian reservation have been designated
by the State as AQMAs for TSP, and 14 counties and one Indian reservation have
been designated as AQMAs for S02 (see Table A-l). Thus, it is probable that
more strict changes will have to be made to existing regulations and/or air
pollution control plans in these areas.
2.5 ENERGY SUPPLY POTENTIAL OF MONTANA
Montana has sizeable fossil fuel resources in the form of coal, oil
and natural gas. The oil and natural gas deposits are spotted throughout
Montana.
Montana has extensive deposits of lignite coal, as well as equally
large deposits of sub-bituminous coal along the eastern border of the state.
Additional sub-bituminous coal, along with deposits of bituminous coal are
found in the mountainous areas of Montana. Some of this potentially strippable
coal is slated for a major power plant in Montana. It is also possible that
this coal could be used for coal gasification. Montana lignite has been
successfully converted to pipeline quality gas using a process developed by
the Institute of Gas Technology of the Illinois Institute of Technology in
Chicago.
. Table E-2 presents fuel production and consumption data for the State
of Montana. These statistics show Montana produces more oil and coal than
it consumes, but uses more than 2.5 times as much gas as is produced within
the State.
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3.0 AQCR ASSESSMENTS
3.1 REGIONAL AIR QUALITY ASSESSMENTS
Tables A-7 and A-8 present the emissions summaries for Montana. They
indicate a small fraction (29%) of particulates come from fuel combustion
sources statewide. Only in the Miles City AQCR (143) are fuel combustion
emissions high (77%) compared to total emissions. Fuel combustion sources
are minor contributors to SOg emissions on a statewide basis (approximately
15%). Again, in the Miles City AQCR, fuel combustion emissions contribute
55% of S02 emissions.
Table A-9 presents the results when the proportional model is used to
determine the tolerance for emissions increase in each AQCR. The largest
drawback of this approach lies in the large geographical dispersion of the
emission sources in Montana. Therefore, this analysis is intended to give
an "indication" of potential areas for regulation relaxation.
Retrievals of 1973 air quality data from the NADB did not include infor-
mation on S02 levels in the Billings (140) and Missoula (144) AQCRs.
Therefore, a tolerance for emissions increase cannot be calculated for these
areas.
Tables B-l and B-2 summarize the general data that must be considered
when estimating the potential for regulation relaxation. The analysis was
performed to determine if any regions were obvious candidates for regulation
relaxation. There is no indication from available data that Montana's regu-
lations are too stringent for suspended particulate emissions, and with the
exception of the Great Falls AQCR, all regions have been classified as poor
candidates for particulate regulation relaxation. In the Great Falls AQCR,
the air quality control measurement value is identical to the secondary
standard, therefore, the tolerance for emissions increase is zero. However,
since it is conceivable that particulate emissions from fuel burning sources
in this AQCR could be increased if controls on other sectors achieved an
overall decrease in emissions, it seemed appropriate for the Great Falls
AQCR to be classified as a marginal candidate.
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There is potential for the relaxation of S02 fuel combustion emission
regulations in the Great Falls and Miles City AQCRs, however, this is not
indicated in the Helena AQCR. Because of insufficient S02 air quality
data in the Billings and Missoula AQCRs, they have been classified as
marginal candidates.
Based on 1973 air quality and emissions data, the Helena AQCR (142)
exhibits NAAQS violations for SCL, therefore, any increase in S02 emissions
in this AQCR would tend to aggravate this situation. However, as shown in
Table A-6, and in Appendices C and D, there are no major S02 emitting
stationary fuel combustion sources in this AQCR.
3.2. POWER PLANT ASSESSMENTS
In the context of the fuel switches being considered, information
available for this review shows three major power plants in the State of
Montana. Other power plants in the state are either too small (less than
10 megawatts electric (Mwe)), or they use diesel power which is outside
the purview of this review. Two of the three major plants are in the
Billings AQCR (140), while the remaining one is in Miles City (143).
Table C-l provides a listing of the power plants in the State along with
a general description of each plant's emission characteristics.
Federal Power Commission fuel schedules for 1973 show Montana's major
power plants use a variety of fuels. The J. Corette Power Plant has the
State's largest steam power generating capacity (172 Mwe), and is located
in the city of Billings. This plant, and also a smaller plant (Lewis and
Clark) located in the city of Sidney, have coal as their principal fuel,
with gas making a small contribution to the overall heat input. The State's
third power plant (the Frank Bird facility located in Billings) uses mostly
oil, but also substantial quantities of gas.
Also shown in Table C-l is a listing of the existing and allowable
emission rates for the State's steam generating power plants. The allow-
ables were based on the applicable state regulation. For particulates,
an equation was dervied which corresponds to the graph shown in Figure A-2.
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This equation is shown below:
E - 0.9I-0'17609
• where
E = the maximum particulate emission level in pounds of particulate
matter per million Btu
I = total heat input in millions of Btu per hour
This equation was used to compute the allowable particulate emission rate
fqr the fuel combustion sources discussed in this review. The allowable
rate was based on the total heat input to a facility. A comparison of
the existing and allowable emission rates show that Montana's three major
power plants are generally operating within the limits of the State's
emission regulations. Only the Lewis & Clark station shows a violation
of Montana's particulate regulation.
The fact that coal already provides most of the heat input to the
State's power plants lessens the chance that substantial clean fuel sav-
ings could be achieved by additional switches to this fuel.
Table C-2 lists all known projected power plants (1974-1985). This
is a coal fired power plant that is scheduled to go on line in stages
from 1975 through 1980.
Table C-3 is a summary of power generation emission factors (AP-42)
and average fuel heat contents used in this review.
3.3 INDUSTRIAL/COMMERCIAL/INSTITUTIONAL SOURCE ASSESSMENTS
Emission and fuel use characteristics of all major stationary fuel
combustion sources (other than power plants) in the State of Montana
identified by NEDS listings are presented in Table D-l. One of those
sources presently uses 100% coal, the remaining sources use 100% wood,
oil, or gas. None use a combination of fuel sources. It is also not
known to what extent industrial sources using gas can effectively switch
to coal.
The combustion of wood by the State's industrial sources is included
in Appendix D because it represents a significant contribution to the
State's overall heat input budget (equal to one half of the heat input
provided by coal), and it also can be a substantial source of particulate
emissions.
17
-------
3.4 AREA SOURCE ASSESSMENT
The state of Montana was found to have no area sources which could
be evaluated within the context of Section 4 of ESECA.
3.5 STATIONARY SOURCE FUEL SUMMARY
Table E-l presents a summary of stationary source fuel use within the
State. This information reflects data in the NEDS files as of December 6,
1974. On a statewide basis, natural gas is obviously the most important
fuel, providing 62% of the heat input supplied to the State's stationary
source fuel combustion sources. Area sources using natural gas provide
the largest contribution to the state's heat input budget. Even among the
State's point sources, natural gas provides more heat input than any of
the other fuels. However, much of this gas is utilized by the State's
industrial sector, and it is not known to what extent these sources can
switch to other (dirtier) fuels.
18
-------
APPENDIX A
t State implementation plan information
• Current air quality information
• Current emissions information
Tables in this appendix summarize original and modified state imple-
mentation plan information, including original priority classifications,
attainment dates, ambient air quality standards, and fuel combustion emis-
sion regulations. National Aerometric Data Bank data for SCL and TSP moni-
toring stations are shown for AQCRs in the State. National Emission Data
System information by AQCR are tabulated and broken down into fuel burning
categories.
An emission tolerance, or emission tonnage which might be allowed in
the AQCR and still not violate national secondary ambient air quality stan-
dards, is shown for particulates and S02 in Table A-9. The intent of this
calculation is to indicate possible candidate regions for fuel switching.
Tolerance was based on air quality/emissions relationships which are calcu-
lated from more recent data. The value of the emissions tolerance provides
an indication of the potential an AQCR possesses for fuel switching and
regulation relaxation.
When current air quality levels were less than one half of the level
represented by an ambient air quality standard, no "rollup" emissions toler-
ance was calculated in Table A-9. This arbitrary cutoff point was chosen so
as not to distort the emissions tolerance for an area. At low levels of a
pollutant, the relationship between emissions and air quality is probably
not linear. Although this cutoff may leave some AQCRs with no quantifiable
emissions tolerance, it was felt that no number at all would be preferable
to a bad or misleading number.
"1972 National Emissions Report," EPA-450/2-012, June 1974.
A-l
-------
It is emphasized that emissions tolerance is a region-wide calculation.
This tolerance obviously makes more sense in, say, an urban AQCR with many
closely spaced emission sources than in a largely rural AQCR with geograph-
ically dispersed emissions.
A-2
-------
(141)
GREAT FALLS
INTRASTATE
(143)
MILES CITY
INTRASTATE
co
(144)
MISSOULA
INTRASTATE
(142)
HELENA
INTRASTATE
(140) V
BILLINGS J
INTRASTATE
Figure A-l. Air Quality Control Regions in Montana
-------
Table A-l AQCR Priority Classification and AQMAs, Montana
AQCR
Billings
Great Falls
Helena
Miles City
Missoula
Fed. #
140
141
Part.3
II
I'll
142 I I-A
143
144
III
I
v 1 <
II III
Demographic Information
Population
1970
135,263
I-A III 144,070
I-A III 167,100
III III
III
III
93,221
154,691
Square
Miles
25,625
24,082
28,430
47,852
19,339
Population
Density
5.28
5.98
5.88
1.95
8.0
AQMA
TSP
Counties
Big Hornf
Carbon
Stillwater
Sweet Grass
Yellowstone
None
Deer Lodge
Silver Bow
Carter
Custer
Fallon
Powder River
Rosebud
Treasure
N. Cheyenne
Indian Res.
Flathead
Lake
Missoula
Designations >e
[ so.
Counties
Big~Hornf
Carbon
Stillwater
Sweet Grass
Yellowstone
None
Deer Lodge
Silver Bow
Lewis & Clark
Carter
Custer
Fallon
Powder River
Rosebud
Treasure
N. Cheyenne
. Indian Res.
None
.
NO
Counties
None
1
None
None
None
None
Legend Follows
-------
Table A-l. AQCR Priority Classification and AQMAs, Montana (Continued)
Criteria Based on Maximum Measured (or Estimated) Pollution Concentration
In Area (Expressed as ug/nP)
in
Priority
aParticulate matter
Annual geometric mean
24-hour maximum
Sulfur oxide:
Annual arithmetic mean
24-hour maximum
cNitrogen dioxide
I
Greater Than
95
325
100
455
110
II
From - To
60 - 90
150 - 325
60 - 100
260 - 455
III
Less Than
60
150
60
260
no
dFederal Register, August 1974, SMSA's showing potential for NAAQS violations
due to growth.
eAs developed by the State of Montana and submitted to the Regional EPA Administrator
on January 24, 1975.
fExcluding the Northern Cheyenne Indian Reservation
-------
Table A-2. Attainment Dates - Montana
AQCR
140
141
142
143
144
AQCR Name
Billings
Great Falls
Helena
Miles City
Missoula
Parti culates
Attainment Dates
Primary
7/75
a
7/75
a
7/75
Secondary
7/75
a
7/75
a
7/75
Sulfur Dioxide
Attainment Dates
Primary
a
7/75
7/77
a
a
Secondary
7/75
7/75
b
a
a
Nitrogen Oxides
Attainment Dates
a
a
a
a
a
cn
aAir quality presently below standards.
bEPA granted an 18-month extension of the statutory timetable for submission
of the plan for attainment and maintenance of the secondary standards for
sulfur oxidesi in this AQCR.
-------
Table A-3. Ambient Air Quality Standards - Montana (Expressed as ug/m )
Federal1
(Nov. 1972)
Primary
Secondary
State
Total
Suspended Parti cul ate
Annual
75(6)
60(G)b
75(6)
24-Hr.
260a
150a
200C
Sulfur Oxides
Annual
80 (A)
60(A)
24-Hr.
365a
260d
3 Hr.
—
1300a
—
1 Hr.
—
650e
Nitrogen
Dioxide
Annual
100(A)
100(A)
V
1
Federal regulations apply
(G) Geometric Mean
(A) Arithmetric Mean
Not to be exceeded more than once per year
This level is not a formalized standard but is rather meant to
be used in SIPs as a guide to help in the attainment of the
24-hr standard. See FR, September 14, 1973 for additional de-
tails.
°Not to be exceeded more than one percent of days a year.
dNot to be exceeded more than one percent of days in any three
month period.
eNot to be exceeded more than one hour in any four consecutive days.
-------
Table A-4. Montana AQCR Air Quality Status (1973), TSP'
00
AQCR
Name
Billings
Great Falls
Helena
Miles City
Missoula
AQCR
" #
140
141
142
143
144
#
Stations
ieportinc
8
4
4
7
12
(ug/m3)
TSP Concentration
Highest Reading
Annual
78d
18
73d
87d
118d
24-Hr.
180
204
200
394
592
2ND
Highest
Reading
24-HR.
158
150
195
357
512
# Stations Exceeding
Ambient Air Quality Standards
Primary
Annual
e
0
0
0
0
W
0
0
0
1
2
Secondary
Annual
e
0
0
0
0
'
-
0
0
0
17
24-Hrb
0
3
2
1
6
•
Reduction
Requi red
To Meet
National
Standards
37.5
75 0
i
50 : 30.2
14
50
58.0
70.7
Standard
On Which
Reduction
Is Based
Annual
i
24-Hr.
Annual
24-Hr.
24-Hr.
a!973 air quality in National Air bata bank as of July 28, 1974.
Violations based on more than one reading in excess of standards.
°Formula: tnu highest i;4 hr - i:4 hr Secondary Standard -,,.,. Annual - Annual Secondary Standard
Highest 24 hr
Annual - Background
The values listed here were provided by tPA Region VIII. The 1973 air quality information retrieved
from the National Aerometric Data Bank (NADB) did. not provide annual values for this AQCR.
SMROAD data for 1973 did not include this information, however, the annual air quality data provided by
the bPA Region VIII office shown in this Table indicates that there was at least one station which ex-
ceeded the secondary standard. A TSP background of 30 ug/rrr (as used in the SIP) ,was used in calcula-
tions of the reductions based on annual readings.
-------
Table A-5. Montana AQCR Air Quality Status (1973) SOJ
AQCR NAME
billings
Great Falls
Helena
Miles City
Missoula
AQCR #
140
141
142
143
144
#
Stations
Reportinc
24-Hr "
(Bubbler'
NDA
1
6
NDA
NDA
#
Stations
Reportinc
(Contin.)
0
NDA
2
1
NDA
SO,, Concentration
ug/m3 2nd
Highest
Highest Reading Reading
Annual
NDA
NDA
NDA
NDA
NDA
24-Hr
—
10
882
13
—
24-Hr
—
10
565
—
—
# Stations Exceeding
Ambient Air Quality Stds.
Primary L Secondary
Annual
NDA
NDA
NDA
NDA
NDA
24-Hr"
—
NDA
5
0
—
3-Hr
—
NDA
0
0
—
%
Reduction
Required
To Meet
Standards
_-
Presently
Meets
Standards
35.4
Presently
Meets
Standards
—
Standard
On Which %
Reduction
Is Based
—
Primary
24-Hr.
Standard
Primary
24-Hr.
Standard
Primary
24-Hr.
Standard
--
1973 air quality in National Air Data Bank as of July 28, 1974
Violations based on more than one reading in excess of standards
°Formula: 2nd highest 24 hr - Primary 24 hr standard
2nd highest 24 hr
x 100
NDA - No Data Available
-------
Table A-6 Fuel Combustion Source Summary-Montana
AQCR NAME
Billings
Great Falls
Helena
Miles City
Missoula
AQCR #
140
141
142
143
144
Power Plants
NEDS3 FPCb
2 2
0 0 •
0 0
1C 1
Od 0
Other Fuel Combustion
Point Sources^
Particulate S02
4 3
1 0
7 0
2 2
10 10
All sources from National Emissions Data System Listing as of December 6, 1974.
""Federal Power Commission information for 1973 of major power plants as retrieved from
EPA data banks.
•*
"More recent information received from the EPA Regional Office shows three power plants in
this AQCR.
More recent information received from the EPA Regional Office shows one power plant in this
AQCR.
-------
•j •
Table A-7 Montana Emissions Summary, S02 (10 tons/yr)c
AQCR
billings
Great Falls
Helena
Miles City
Missoula
140
141
142
143
144
Total
103
Tons/Yr
633
5.4
30b
7.3
6.9
Percent
Fuel b
Combustion
1.5
25.9
0.5
77.3
39.0
Electricity
Generation
103 Tons/Yr
4.7
0
0
4.3
0
Xb
0.74
0
0
58.90
0
Point Source
Fuel Combustion
lO^ons/Yr
3.4
0
0
0.24
0.69
%b
0.54
0
0
3.29
10.00
Area Source
Fuel Combustion
103Tons/Yr
1.7
1.4
1.7
1.1
2.0
%b
0.27
25.90
0.55
15.10
29.00
abased on NEDS 1972 National Emissions Report.
Represents the percent of the year's total S02 emissions.
CNEDS data shows one ton per year.
-------
Table A-8. Montana Emissions Summary, TSP (10 tons/yr)'
ro
AQCR
Billings
Great Falls
Helena
Miles City
Missoula
140
141
142
143
144
Total
T03Tons/Yr
220 .
3.9
33.4
6.5
37.1
Percent
Fuel
Combustion*3
1.4
10.3
2.3
54.7
7.3
Electricity
Generation
103'Tons/Yr
0.75
0
0
3.20
0
*b
0.34
0
0
49.20
0
Point Source
Fuel Combustion
103Tons/Yr
1.80
oc
0.09
0.04
1.90
%b
0.82
0
0.27
0.62
5.10
Area Source
Fuel Combustion
103 Tons/Yr
0.56
0.40
0.67
0.32
0.80
Xb
0.25
10.30
2.00
4.90
2.20
Based on NEDS 1972 National Emissions Report.
^Represents the percent of the year's total particulate emissions.
'NEDS show 2 tons of emissions per year.
-------
Table A-9. Montana Required Emission Reductions, Particulates, SO,
AQGR
Billings
Great Falls
Helena
Miles City
Missoula
PARTICULATES
1973 AO
Measure-
ment
Control
Value
78b
150C
73b
357C
51 2C
Percent 1
Reducti on
Requi red
Based on
1973 AQ
Data?
37.5
0
30.2
58.0
70.7
i!972
NEDS
Emissions
103 Tons/
Yr
220
3.9
33.4
6.5
18.1
Allowable
Emissions
103 Tons/
Yr
1.37.5
3.9
23.3
3.4
12.7
Emissions
Tolerance
103 Tons,/
Yr
-82.5
0
-10.1
-3.1
-24.4
so2
Percent
Reduction
Required
Based on
1973
AO Data
NDA
Meets Stds.
35.4
Meets Stds.
NDA
1072
NEDS,
Emissions
TO3 Tons/
Yr
633
5.4
308
7.3
6.9
Allowable
Emissions
103 Tons/
Yr
NCa
199.0
NCa
Emissions
Tolerance
103 Tons/
Yr
a
-109.0
a
I
CO
Available air quality data indicates that there is a potential for allowing substantial increases
of the emissions of sulfur oxides in this region. However, if the proportional model is used to
quantify this increase, unrealistically high values would result. Therefore, no calculation was made.
bData provided by EPA, Region VIII, annual geometric means.
C1973 air quality data in National Aerometric Data Bank as of July 28, 1974, 24-hour readings.
Background of 30 yg/m3 used in the SIP, repeated here for consistency.
NC - Not calculated
NDA - No data available
-------
Table A-10. Summary of Montana Regulations Concerning Fuel Combustion
Particulate Emissions
Maximum Allowable Emissions of Particulate Matter
in Pounds Per Million Btu
I
£
Heat Input in
Million Btu/hr*
Up to and including 10
100
1,000
10,000 and above
Existing Equipment
(Ibs/hr)
0.60
0.40
0.28
0.19
New Equipment
(Ibs/hr)
0.60
0.35
0.20
0.12
* For heat inputs not listed, see Figure A-2 for allowable emissions.
Regulation of sulfur in fuel:
Gaseous Fuel: Commencing July 1, 1971, no person shall burn any gaseous fuel containing
sulfur compounds in excess of 50 grains per 100 cubic feet of gaseous fuel,
calculated as hydrogen sulfide at standard conditions.
Liquid or
Solid Fuel: Commencing July 1, 1972, no person shall burn liquid or solid fuels con-
taining sulfur in excess of one (1) pound of sulfur-per million Btu fired.
-------
cn
3
Q.
10 4->
E ea
£5 0.8
I/I
10 3
E QO
LU
O) O
3 -
o
(O
•1- i.
X (O
tO Q.
to
•o
c
3
O
Q_
0.6
0.4
0.2
-H
4-
10 100 1000
Total Input - Millions of Btu/Hour
10000
Figure A-2. Maximum Emission of Particulate Matter
for Existing Fuel Burning Installations
-------
APPENDIX B
Tables B-l and B-2 are the assessment of AQCRs which should be exam-
ined for the fuel switching impact on particulate and S02 emissions. They
also provide an identification of those AQCRs which show little potential
for fuel revision or regulation relaxation if ambient air standards are
to be attained.
The criteria for candidates are (1) the severity and breadth of air
quality violations, (2) the tolerance for emissions increased in the AQCR,
(3) the fraction of total emissions resulting from fuel combustion, and
(4) AQMA designations. It should be noted that an AQCR may not necessarily
need relaxation of regulations in order to accomplish fuel switching.
Further, a good candidate in Table B-l and B-2 may later show little
potential for fuel switching after individual sources are examined. Finally
it is possible that an AQCR may have air quality levels below standard at
present and may require more strict regulations than currently exist if all
fuel burning sources were converted to dirtier fuels, i.e., "average" emis-
sion rate now may be below "average" regulations.
B-l
-------
Table B-l. Montana Candidacy Assessment for Relaxation of Participate Regulations
AQCR
billings
140
Great Falls
141
Helena
142
Miles City
143
Missoula
# of
Stations
8
4
4
7
12
# of Stations
Reporti ng
Violations
of National
Secondary
Standards
ANNUAL
0
0
0
0
24 HR
1
0
1
1
5
Expected
Attainment
Dates3
Secondary
Standards
7/75
a
7/75
a
7/75
Counties
With AQMA
Designa-
tions for
Parti cu-
lates
5b
0
2
6C
3
1972
Total
Emissions
!03Tons/Yr
220
3.9
33.4
6.5
37.1
%
Emissions
From Fuel
Combustion
1.4
10.3
2.3
54.7
7.3
1972
Emissions
From
Fuel
Combustion
103Tons/Yr
3.10
0.40
0.77
3.60
2.70
Tolerance
for
Emissions
Increase
103Tons/Yr
-82.5
0
-10.1
- 3.1
-24.4
Regionwide
Evaluation
Poor
Marginal
Poor
Poor
Poor
When the attainment dates were formalized, air quality in this region was Letter than standards require.
Excluding the Northern Cheyenne Indian Reservation.
cPlus the Northern Cheyenne Indian Reservation.
-------
Table B-2 Candidacy Assessment for Relaxation of SC Regulations in Montana
00
I
co
AQCR
billings
140
Great Falls
141
Helena
14*
Miles City
143
Missoula
144
# of
Stations
Bubbler
NDAb
1
6
NDAC
NDAb
Continu-
gus
NDAb
NDAC
2
1
HDAb
# of Stations
Reporting Violations
of
National Standards
Annual
^
NDAd
NDAd
.
_
24 Hr
_
0
3e
0
_
3 Hr
_.
.
0
0
.
xpected
Attain-
ment
Date
Secon-
dary
Stan-
dards
7/75
7/75
f
a
a
ounties
With
AQMA
esigna-
tions
for
S02
5g
0
3
6h
0
1972
Total
Emis-
sions
103Tons,
Yr
633
5.4
308
7.3
6.9
%
missions
From
Fuel
Combus-
tion
1.5
25.9
0.5
77.3
39.0
197?
missions
From
Fuel
Combus-
|— tlflQ.
103Tons/
Yr
9.5
1.4
1.5
5.6
2.7
%
Tolerance
for
Emissions
Increase
103 Tons/
Yr
—
i
-109.0
i
.
Regionwide
Evaluation
Marginal
Good
Poor
Good
Marginal
When attainment dates were formalized, air quality was better than standards require.
Based on information retrieved from the National Aerometric Data Bank, there was no 1973 S0? air quality data
for these AQCRs.
cUata from the 'National Aerometric Data Bank did not include information for this particular type of monitor
located in this AQCR.
Data from the National Aerometric Data Bank did not include annual SOg air quality information for this AQCR.
eTwo violations were recorded at bubble monitors, and one violation at a continuous monitor. All 3 monitors
were at different sites.
EPA granted Montana an 18 month extension of the statutory timetable for submission of the plan for attainment and
maintenance of the secondary standards for sulfur oxides in this AQCR.
^Excluding the Northern Cheyenne Indian Reservation.
Plus the Northern Cheyenne Indian Reservation
Available air quality indicates there is a potential for allowing substantial increases of the particulate
emissions in this region. However, if the proportional model is used to quanitfy this increase, an unrealistically
high value would result. Therefore, no calculation was made.
-------
APPENDIX C
This section is a review of individual power plants by AQCR. The
intent is to illustrate fuel switching possibilities and particulate and
SOp emissions resulting from these switches on an individual plant basis.
The total AQCR emissions resulting from such switches is then calculated.
Current power plant information used to prepare Table C-l were obtained
from three main sources: (1) Federal Power Commission computerized list-
ings of power plants and their associated fuel use, (2) the National Coal
Association "Steam Tables" listing of power plants and fuel use in 1972,
and (3) NEDS Emissions data. For those plants listed by the FPC (1 above),
the 1973 fuel schedule was assumed, otherwise, fuel use is for 1972. Heat
inputs are those based on actual fuel values where known, and average
values shown in Table C-3 were used where not known. S02 and particulates
emissions are those associated with the fuel use shown. In the case of
particulates, emissions were calculated using NEDS emissions factors applied
to the listed fuel schedule. When a plant was not listed in NEDS, AP-42
emission factors were used to estimate S02 and TSP emissions (see Table
C-3).
C-l
-------
Table C-l. Montana Power Plan Fuel Combustion Point Source Characterization (1973)
o
ro
AQCR
140
140
143
Plant Location
(Plant Name)
Size, and
Fuel Design
Billings (Corette)
172 MU
Coal
Gas
Billings
(Bird)
70 MW
Oil
Gas
Sidney
(Lewis & Clark)
bO MM
Coal
Gas
Fuel Use
Type Annual* Heat
% Sulfur Quantity InP"t
% Ash (106
Btu/Hr
Coal
0.7 Sulfur 576 1130
8% Ash
Gas 433 50
[" Emissions
1 so2
Allowable '
Emissions (Based l
Existing On Regulations Existin
Lbs/ Limits)
Tons/Yr io6BUi frons/Yr Lbs/10°Btu Tons/Yr 1
7610 1.5 j 10100 2.0 1230
-
1180 1 7610 1.5
Oil 233 155 1025 1.19 1700 2.0 39
1.4% S
Gas 401 42 : - - -
197 ! 1025 1.19
Coal 306 453
.55% S
Gas 44 5
458
*
Totals: -,
Coal 882 x 10^ tons
Oil 233 x 10? barrels
Gas 878 x 10° cu. ft.
3260 1.62 4080 2.0 j 3060(Est)
3260 1.60 '
TSP
Allowable
Emissions (Basec
9 On Regulations
Lbs/ Limits)|_bs/
DDBtu Tons/Yr 10° Bti
0.23 1500 .26
.04 400 .35
1.52 620 0.31
-------
Table C-2. Montana Power Plant Projected Development
AQCR/Number/County
Miles City/1 43/Rosebud
Owner
Montana Power
aCoal fired plants; dates refer to
expected start-up times.
Plant3
Col strip #1
7/75
Col strip #2
7/76
Col strip #3
7/80
Col strip #4
7/79
MW
350
350
700
700
Projected Emissions NSPS
(tons/year)
Particulates
1239
1239
2478
2478
so2
14,882
14,882
29,764
29,764
NOX
8,680
8,680
17,360
17,360
Coal use in 1975 = 340 x 103 tons
Coal use in 1977 = 1780 x loHons
Coal use in 1980 = 5545 x 103 tons
o
oo
Expected use of coal at the Colstrip facilities in the years indicated.
-------
Table C-3 AP-42 Power Generation Emission Factors
Fuel
Coal(1) (Bit.)
General
wetbottom 10%A
Cyclone
1% S
2% S
3% S
Oil (2)
0.5% S
1.0% S
2.0% S
Gas'3)
(.3 Ibs S/
lOW)
Parti culates
Lbs/Ton Lbs/lO^ti
160 7.4
130 7.0
20 0.9
Same Same
as as
Above Above
Lb/103 Gal
8 0.058
8 .058
8 .058
so2
Lbs/Ton Lbs/106Bti
38 1.65
76 3.30
114 5.00
Lb/103 Gal
79 0.560
157 1.12
314 2.24
Lb/106 Ft3 U/106 Ft3
15 .015 0.57 .00057
Hydrocarbons
Lbs/Ton Lbs/106 Btu
0.3 0.013
0.3 0.013
Lb/103 Gal
2 .014
2 .014
2 .014
Lb/106 Ft3
1 .001
NOX (as N02)
Lbs/Ton Lbs/106 Btu
18 0.78
30 1.30
55 2.40
Same Same
as as
Above Above
Lb/103 Gal
105 0.75
105 0.75
105 0.75
Lb/106 Ft3
600 0.60
o
I
(1) Coal 23 x 10 Btu/Ton
(2) Oil 140 x 103 Btu/Gal
(3) Gas 1000 Btu/ft3
-------
APPENDIX D
The Tables D-l in this appendix list individual industrial/commercial/
institutional sources of particulates and SCL emissions which might show
fuel switching potential. The sources are from NEDS point source listings
retrieved from EPA data banks in December 1974. All fuel combustion sources
included in this data are listed in Table D-l, however, this Table does
not purport to comprehensively list all of Montana's industrial sources.
D-l
-------
Table D-1 Montana Industrial-Commercial Fuel Combustion Point Source Characterization
o
County
&
AQCR
b ig Horn
140
Fergus
140
Yel lows tone
14U
Yellowstone
140
Yel lows tone
140
Yel lowstone
140
Cascade
141
Beaver head
142
Gellatln
14k:
Gellatln
14,:
Powel 1
142
Silver Bow
142
Silver Bow
14<:
Powder River
143
Richland
143
Plant Name
holly Sugar
U.S. Gypsum
Great Western
Sugar
Continental
Oil
Fnirs . Union
Cntl. Ex.
Montana
Sulfur
Phillips
Petroleum
Pfizer
Ideal
Cement Co.
united
Sierra Talc
Rocky Mt.
Phosphate
Anaconda
Stauffer
Cheni.
Bell Creek
Gasol ine
holly Sugar
Fuel Use
Type
:- Sul fur.
% Ash -
Coal
0.09% S
8.7% A
Gas
Gas
Gas
Oil
0.34% S
Gas
Oil
4.b% S
Gas
Gas
Gas
Gas
Gas
Gas
Gas
Oil
Gas
Gas
Gas
Annual
Quantity
27
14b
153b
4950
180
880
246
8
230
114
2000
205
171
662
184
4bO
717
1734 .
Heat 2
Input
(106Btu/
Hr)
b2
16.9
17b
565
120
100
164
0.9
26.3
13.0
228
23.4
19. b
75.6
122
51.4
81.8
198
Emissions
SO, 1 TSP
Existing
Tons/Yr Ibs/lflS
Btu
47
1
<. 1
1
201
< 1
3174
< 1
1
<1
<1
1
<1
1
NDA
a
1
1
0.21
0.01
_
0.07
2.70
_
.01
_
_
.01
_
-
<0.01
<0.01
<0.01
(Allowable! (Allowable
Emissions] Existing (Emissions
Baspd On!
Requlat'ns
Limits)
Lbs/lFBti
2.0
N/A3
N/A3
N/A3
2.0
N/A3
2.0
N/A3
1VA3
N/A3
H/A3
N/A3
N/A3
N/A3
2.0
N/A3
N/A3
N/A3
Tons/Yr lbs/'n6
Btu
1540 6.80
1 0.01
14 0.02
45 0.04
67
12 0.11
120
< 1
2 0.02
<1
18 0.02
2 0.02
2 0.02
6 0.07
58
4 0.02
6 0.02
15 0.02
(Based on
tegulation;
Limits)
hs/106Btu
0.45
0.55
0.36
0.29
0.34
0.60
0.51
0.57
0.35
0.52
0.53
0.3b
0.45.
0.41
0.35
-------
Table D-l. Montana Industrial-Commercial Fuel Combustion Point Source Characterization (Continued)
CO
County
&
AQCR
Roosevelt
143
Valley
143
Lake
144
Lincoln
144
Lincoln
144
Missoula
144
hissoula
144
Missoula
144
Missoula
144
f Ravalli
144
f Sanders
144
Plant Name
Spruce Oil
Corp.
AVCO
Economic Sys.
Dupuis Bros.
Lumber Co.
St. Regis
Paper Co.
W.R. Grace
Vermiculite
Anaconda
Forest Prod.
Evans Prod.
Intermouatain
Lumber
Hoener
Waldorf
Intermountain
Lumber
Dale
Lumber
Fuel Use
Type .
% Sulfur
% Ash
Gas
Oil
Oil
2.0% S
Wood
Wood
Oil
2.7% S
Wood
Wood
Wood
Gas
Wood
Wood
Wood
i
Annual
Quantity
63
0.57
35.7
10.8
368
25.7
96
lb.1
25
2691
52.3
12.4
30
Heat2
Input
c
(ltr
7.19
0.38
23.80
17.30
588
17.1
153
24.1
40.0
307
83.6
19.8
47.9
Emissions
S02 | TSP
[Allowable!
Existing (Emissions! Existing
|( Based Onl
Reoulat'ns
6[
Tons/Yr Lb|^u10
1
1
236
8
276
229
72
11
69
1
39
9
23
0.06
2.30
0.11
0.11
3.10
0.11
0.10
0.39
0.02
0.10
0.11
Limits)
LbsJiQ6/
6tu
N/A3
2.0
2.0
2.0
2.0
2.0
2.0
2.0
2.0
N/A3
2.0
2.0
2.0
ih /in
ons/Yr 'n^
1 0.03
< 1
18 0.17
74 0.99
507 0.20
12 0.16
660 0.98
15 0.14
113 0.64
1 <0.01
5
68 0.78
413 1.97
Allowable
Emissions
iBased On
Reaulat'ns
Limits)
bs/106Btu
0.60
0.52
0.54
0.29
0.55
0.37
0.51
0.47
0.31
0.53
0.46
1. Quantities experessed as follows:
Coal = 103 tons
Oil = 103 bbls
Gas = 106 ft3
Wood = 103 tons
2. Based on the following average heat
contents for the respective fuels:
1000 Btu/ft3 for gas
7000 Btu/lb for gas
140,000 But/gal for oil
For coal, the heat content used in
calculations correspond to the values
included in NEDS Point Source Listing
(file created 12/6/74).
In these cases, N/A refers to
"not available." The regula-
tion covering sulfur in gaseous
fuels expresses the limit as a
maximum sulfur content in the
fuel. NEDS information did not
include the sulfur content of
natural gas. However, it should
be pointed out that if all of
the sulfur content of natural
gas appeared as SOj in the emis-
sions, then the State's emission
regulation would correspond to an
S02 emission limit of 0.14 Ibs per
million Btu.
-------
APPENDIX E
A summary of Montana fuel use totalized from the NEDS data bank
is presented in Table E-l. Table E-2 lists fuel production and
consumption figures for Montana (1972).
E-l
-------
Table E-l. Montana Stationary Source Fuel Summary
m
i
ro
Point Sources
Electric Power
Industrial
| Commercial/
1 Institutional
1
j Area Sources
} Residential
] Industrial
] Com/Ind
i
State Totals
1012 Btu/Year*
% of Total Btu
Coal
(103 tons)
668
27
36
86
65
882
18
14%
Oil
(103 bbls.)
670
853
' 1 ,424
; 554
3,502
20.6
17%
Gas
(106 Ft3)
980
16,792
26,810
10,540
21,650
76,772
77
62%
Wood
(103 tons)
610
50
-
660
9.0
7%
Calculation of heat inputs is based on the following average heat contents:
Gas - 1000 Btu/Ft3
Oil - 5.88 x 106 Btu/bbl.
Coal - 20 x 106 Btu/Ton
Wood - 14 x 106 Btu/Ton'
Information is obtained from Neds Files as of 12/6/74.
-------
Table E-2. Energy Statistics* for Montana (1972)
Fuel
Coal
Oil
Gas
Production
8.221 x 106 tons
33.9 x 106 bbl.
33.5 x 109 ft3
Consumption
1.3 x 106 tons**
22.6 x 106 bbl.
85.3 x 109 ft3
oo
*A11 oil and gas values are from "Fuel and Energy Data: U.S.
by States and Regions," 1972 (U.S. Bureau of Mines). Coal
consumption figure obtained from "Assessment of Impact of Air
Quality Requirements on Coal in 1975, 1977, and 1980," (U.S.
Bureau of Mines).
**
Includes Idaho
-------
BIBLIOGRAPHY
1. "1972 National Emissions Report," U.S. Environmental Protection
Agency, EPA-450/2-74-012.
2. "Projections of Economic Activity for Air Quality Control Regions,"
U.S. Department of Commerce, Bureau of Economic Analysis, prepared
for U.S. EPA, August 1973.
3. "Monitoring and Air Quality Trends Report, 1972," U.S. EPA-450/1-73-
004.
4. "Steam-Electric Plant Factors/1072," 22nd Edition National Coal
Association.
5. "Federal Air Quality Control Regions," U.S. EPA, Pub. No. AP-102.
6. "Assessment of the Impact of Air Quality Requirements on Coal in
1975, 1977 and 1980," U.S. Department of the Interior, Bureau of
Mines, January 1974.
7. "Fuel and Energy Data," U.S. Department of Interior, Bureau of Mines,
Government Printing Office, 1974, 0-550-211.
8. "Compilation of Air Pollutant Emission Factors, 2nd Edition," U.S.
EPA, Air Pollution Tech., Pub. AP-42, April 1973.
9. SAROAD Data Bank, 1973 Information, U.S. EPA.
10. Federal Power Commission, U.S. Power Plant Statistics Stored in EPA
Data Bank, September 1974.
11. "Implementation Plan for Control of Air Pollution in Montana," sub-
mitted March 22, 1972 by Forrest H. Anderson, Governor.
12. "Implementation Plan Evaluation Report for the State of Montana,"
EPA, July 28, 1972.
-------
TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1. REPORT NO.
EPA-450/3-75-021
2.
3. RECIPIENT'S ACCESSION-NO.
4. TITLE AND SUBTITLE
IMPLEMENTATION PLAN REVIEW FOR MONTANA AS
REQUIRED BY THE ENERGY SUPPLY AND ENVIRONMENTAL
COORDINATION ACT
5. REPORT DATE
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
10. PROGRAM ELEMENT NO.
U. S. Environmental Protection Agency, Office of Air
Quality Planning and Standards, Research Triangle
Park, N.C., Regional Office VIII, Denver, Colorado,
and TRW, Inc., Redondo Beach, Calif. 90278
11. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS
13. TYPE OF REPORT AND PERIOD COVERED
U. S. Environmental Protection Agency
Office of Air and Waste Management
Office of Air Quality Planning and Standards
Research Triangle Park. North Carolina 27711
14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
16. ABSTRACT
Section IV of the Energy Supply and Environmental Coordination Act of 1974,
(ESECA) requires EPA to review each State Implementation Plan (SIP) to determine
if revisions can be made to control regulations for stationary fuel combustion
sources without interfering with the attainment and maintenance of the national
ambient air quality standards. This document, which is also required by Section
IV of ESECA, is EPA's report to the State indicating where regulations might be
revised.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.IDENTIFIERS/OPEN ENDED TERMS
c. COS AT I Field/Group
Air pollution
State Implementkm Plans
8. DISTRIBUTION STATEMENT
Release Unlimited
19. SECURITY CLASS (This Report)
Unclassified
21. NO. OF PAGES
20. SECURITY CLASS (Thispage)
Unclassified
22. PRICE
EPA Form 2220-1 (9-73)
------- |