EPA-450/3-75-022
MARCH 1975
IMPLEMENTATION PLAN REVIEW
FOR
WYOMING
AS REQUIRED
BY
THE ENERGY SUPPLY
AND
ENVIRONMENTAL COORDINATION ACT
U. S. ENVIRONMENTAL PROTECTION AGENCY
-------
EPA-450/3-75-022
IMPLEMENTATION PLAN REVIEW
FOR
WYOMING
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
-------
TABLE OF CONTENTS
Page
1.0 EXECUTIVE SUMMARY 1
2.0 STATE IMPLEMENTATION PLAN REVIEW 5
2.1 Summary 5
2.2 Air Quality Setting - State of Wyoming 9
2.2.1 Wyoming AQCR's 9
2.2.2 Wyoming Air Quality Standards 9
2.2.3 Air Quality Monitoring and 1973 TSP and S02 Levels . 9
2.3 The Wyoming State Implementation Plan and Current Emission
Regulations 11
2.3.1 Particulates 11
2.3.2 S02 11
2.3.3 NOV 11
/\
2.4 Wyoming Air Quality Maintenance Areas 12
3.0 AQCR ASSESSMENTS BASED ON SIP REVIEW AND CURRENT AIR QUALITY . . 13
3.1 Regional S02 and Particulate Emissions 13
3.2 Candidacy Assessment for Regulation Relaxation 13
3.2.1 Particulates 13
3.2.2 S02 14
3.3 Power Plant Examination 14
3.4 Industrial and Area Sources 15
3.5 Wyoming NOX Regulations 15
3.6 Wyoming Energy Supply 15
TECHNICAL APPENDICES
APPENDIX A A-l
APPENDIX B B-l
APPENDIX C C-l
APPENDIX C D-l
APPENDIX E E-l
BIBLIOGRAPHY
in
-------
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 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 (NAAQS). In addition to requiring that EPA report to the State
on whether control regulations might be revised, ESECA provides that EPA
must approve or disapprove any revised regulations relating to fuel burning
stationary sources within three months after they are submitted to EPA by
the States. The States may, as in the Clean Air Act of 1970, initiate
State 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 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.
1
-------
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 available by which to address individual point source emissions.
Where the modeling data for specific sources were found, however, they v/ere
used in the analysis.
The data upon which the reports' findings are based is 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
perspective with all sources of emissions such as smelters or other industrial
processes. States are encouraged to consider the overall impact which the
potential relaxation of overly restrictive emissions regulations for combus-
tion sources might have on their future control programs. This may include
air quality maintenance, prevention of significant deterioration, increased
TSP, NO , and SCL emissions which occur in fuel switching, and other potential
n £ ">
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 particulate
matter (TSP) and sulfur dioxide (SO^) emissions. This i.s because stationary
fuel combustion sources constitute the greatest source of SO,, emissions and are
a major source of TSP emissions.
-------
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 SO^ 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, 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 developing
State-wide air quality control strategies; 2) the existence of State Air
Quality Standards which are more stringent than NAAQS (reflecting a state's
desire to attain or maintain air quality levels below 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 ti-ne SIP's 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 fcr demonstrating the attainment of the standards,
The example region concept permitted a State to identify the most
polluted air quality control region (AQCR) and adopt control regulations
which would be adequate to attain the NAAQS in that region. In using an
example region, it was assumed that NAAQS would be attained in the other
AQCR's of the State if the control regulations were applied to similar
sources. The problem with the use of an example region is that it can re-
sult in excessiv: 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 1 percent sulfur oil to be burned
state-wide where the use of 3 percent sulfur coal would be adequate to attain
NAAQS in some locations.
-------
Part of each State's review was organized to provide an analysis of
the S02 and TSP emission tolerances within each of the various AQCR's. The
regional emission tolerance estimate is, in many cases, EPA's only measure
of the "over-cleaning" accomplished by a SIP. The tolerance assessments
have been combined in Appendix B with other regional air quality "indicators"
in an attempt to provide an evaluation of a region's candidacy for changing
emission limitation regulations. In conjunction with the regional analysis,
a summary of the State's fuel combustion sources (power plants, industrial
sources, and area sources) has been carried out in Appendices C, D, and E,
FINDINGS
The Wyoming Implementation Plan has been reviewed for frequent
causes of overly restrictive emission regulations. The Wyoming
fuel burning particulate regulation does not appear overly res-
trictive in the context of Section IV of ESECA. The recently
adopted Wyoming S0£ emission regulation may be more restrictive
than necessary to maintain NAAQS for S02.
Ambient levels for TSP were reported to exceed NAAQS in all
Wyoming AQCR's during 1973. The Wyoming SIP demonstrated
attainment of NAAQS for TSP only in the Cheyenne AQCR,
although SIP particulate regulations were to apply state-
wide. The Casper and Wyoming AQCR's have counties
designated as maintenance areas for TSP. Although fugitive
dust no doubt contributes to TSP levels in Wyoming,
increases in man made emissions will aggravate the
situation. There is little indication that Wyoming
particulate emission regulations are overly restrictive.
Although Wyoming did not propose fuel burning SO? emission regu-
lations in the original SIP, the state has recently adopted such
regulations. Limited S02 monitoring data show SC>2 levels to be
well below NAAQS throughout Wyoming. Wyoming established ambient
SOp standards more stringent than the Federal standard. Sweetwater
County (Wyoming AQCR) was recently designated as a maintenance area
for SOp. In the absence of modeling results, the recently adopted
S02 regulations do appear more stringent than necessary to maintain
the Federal ambient air quality standards.
Large power plants in Wyoming currently use only coal as fuel.
Limited data suggests little coal use by the industrial sector.
The feasibility of fuel switching for smaller sources is unknown.
-------
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?
Does the SIP have emission limiting regulations fo.r control
of existing (1) power plants, (2) industrial sources, and
(3) area sources?
Did the State use an example region approach for demonstrat-
ing the attainment of NAAQS or more stringent State standards?
Has the State initiated action to modify combustion
sources emission regulations for fuel savings; i.e., under the
Clean Fuels Policy?
Are there 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?
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?
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 accomplish
significant fuel switching?
Based on the above indicators, what is the potential for
revising fuel combustion source emission limiting regulations?
t Is there a significant Clean Fuels Saving potential in the
region?
-------
The initial part of the SIP Review Report, Section 2, Appendix A,
was organized to provide the background and current situation information
for the State Implementation Plan. Section 3 and the remaining Appendices
provide an AQCR analysis which helps establish the overall potential for
revising regulations. 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
regulations. In conjunction with a regional analysis, a characterization
of the state fuel combustion sources (power plants, industrial sources, and
area sources) has been carried out in Appendices C, D, and E.
Based on overall evaluation of EPA's current information, AQCR's have
been classified as good, marginal, or poor candidates for regulations
revisions. These ratings, which are shown in the Summary Table on Page 8
were determined by assessing the following criteria:
Good Poor Marginal
1) Adequate number 1) Violation of NAAQS 1) No air quality data
2) No NAAQS violations 1975 2) Inconsistent
3) Attainment date of 3) Proposed AQMA "indicators"
1975 for NAAQS in 4) Modeling
M show no potential
4) No proposed AQMAs for regulation
5) Modeling results revision
show a potential
for regulation
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
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."
The following table summarizes the State Implementation Plan Review.
The remaining portion of the report supports this summary with
explanations.
-------
Wyoming Implementation Plan Review
Summary Table
STATE <
AQCR AQCR AQCR
241 242 243
(CASPER) (CHEYEHNE) (WYOMING)
"INDICATORS"
t Does the State have air quality standards
which are more stringent than NAAQS?
Does the State have emission limiting regu-
lations for control of:
1. Power plants
2. Industrial sources
3. Area sources
Did the State use an example region approach
for demonstrating the attainment of NAAQS or
more stringent State standards?
t Has the State initiated action to modify
combustion source emission regulations for fuel
savings; i.e., under the Clean Fuels Policy?
t Are there proposed Air Quality Maintenance
Areas?
t Are there indications of a sufficient number
of monitoring sites within a region?
t 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 indications 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?
Must emission regulations be revised to accom-
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?
TSP
NO
YES
YES
YES
NO1
NO
110 M
so?
YES
YES
YES
NO
NO
110
)DELING
TSP S02
YES
YES
NO
HO
NO
NO
DATA A
NO2
POOR
NO2
NO
NO
YES
YES
YES
NO
VAILABL
NO
GOOD
NO3
TSP SO,,
NO
YES
YES
HO
HO
YES
E FOR V
HO2
POOR
NO2
NO
NO
YES
YES
YES
YES
Y.OHING
NO
GOOD
HO3
TSP SO^
VES
YES
NO
NO
NO
YES
SOURCE!
NO2
POOR
NO2
YES
NO
YES
YES
YES
NO
NO
GOOD
NO3
]AQCR 242 (Cheyenne) was used to demonstrate attainment of HAAQS for particulates.
All large Wyoming power plants use coal at present, some industrial fuel switching could
occur within existing regulations.
Regulation relaxation would allow use of higher sulfur content coal, however,
savings would not be substantial due to present lack of major users in the state.
-------
2.2 AIR QUALITY SETTING - STATE OF WYOMING
2.2.1 Wyoming AQCR's
The State of Wyoming was divided into three Air Quality Control
Regions - AQCR's. They are as follows:
241 - Casper Intrastate Air Quality Control Region
242 - Cheyenne Intrastate Air Quality Control Region
243 - Wyoming Intrastate Air Quality Control Region
Figure 2.1 shows the boundaries of Wyoming AQCR's.
2.2.2 Wyoming Air Quality Standards
A summary of the federal and Wyoming Ambient Air Quality Standards
for the pollutants under study is presented in Table A-3. The Wyoming
standards for particulates and N02 are identical to the federal secondary
standards. The Wyoming SOp air quality standards for both the annual
average and 24 hour maximum are more stringent than the Federal Air
Quality Standards.
2.2.3 Air Quality Monitoring and 1973 TSP and SO? Levels
Thirteen TSP monitoring stations reported data to the SAROAD bank for
1973. Table A-4 shows violations of the annual secondary TSP standard in
all Wyoming AQCR's. In addition, violations of the secondary 24 hour
standard were reported in each AQCR. Only one Wyoming monitoring station
(AQCR 243-Wyoming) reported violations of the primary TSP standard.
Fugitive dust may be a factor in Wyoming TSP levels, particularly
short-term violations of NAAQS.
S02 levels appear to be well below NAAQS in 1973, although S02
monitors are few and widely spaced (5 monitoring stations reported data
in 1973). The low S02 levels in Table A-5 may partially reflect lack of
source orientation. Additional SOp and TSP monitors have been recently
added to Wyoming's network, which now includes 24 total TSP monitors and
eight total S02 monitors.
-------
WYOMING
INTRASTATE
(REMAINING
AREA)
AQCR 243
CASPER
INTRASTATE
AQCR 241
METROPOLITAN
CHEYENNE
INTRASTATE
AQCR 242
Figure 2-1. Air Quality Control Regions in Wyoming
-------
2.3 THE WYOMING STATE IMPLEMENTATION PLAN AND CURRENT EMISSION
REGULATIONS
Table A-l lists the original priority classifications for Wyoming
AQCR's. All AQCR's were classified priority III for S02 and N02. Casper
(241) and Cheyenne (242) were classified priority II for suspended
participates, while Wyoming (243) was classified priority III.
2.3.1 Particulates
The Wyoming SIP demonstrated attainment of NAAQS for particulates
in AQCR 242 (Cheyenne). Application of particulate regulations to one
major point source (a cement plant) alone in the Cheyenne AQCR was
calculated to achieve a 2/3 reduction of inventoried emissions in that
region. Although a 93% reduction in emissions in AQCR 242 was necessary
for NAAQS attainment based upon rollback proportional to air quality
levels, the source oriented nature of the high ambient TSP measurements
and the 98% expected control of the major source was determined to be
adequate for demonstrating attainment of NAAQS. The Wyoming plan proposed
the application of particulate control regulations statewide so that AQCR's
241 (Casper) and 243 (Wyoming) would also maintain air quality below NAAQS
for TSP. Particulate control regulations applicable in Wyoming for fuel
combustion sources are summarized in Table A-10.
2.3.2 Sulfur Dioxide
All AQCR's in Wyoming were classified priority III for SO,,. The Wyoming
SIP proposed SOp emissions controls only for sulfuric acid plants. Recently,
however, Wyoming has adopted S02 emission regulations for both existing coal
burning sources and new coal and oil burning sources (Table A-10).
2.3.3 NOV
11' " /\
Wyoming also adopted NOX regulations for oil and gas fired equipment
(Table A-10). Wyoming's three AQCR's were classified priority III for N02,
so that these regulations were not required for demonstrating attainment of
NAAQS. Wyoming NO regulations do not apply to coal users.
/\
11
-------
2.4 WYOMING AIR QUALITY MAINTENANCE AREAS
Wyoming has designated three Air Quality Maintenance Areas for TSP:
1) Converse County in AQCR 241 (Casper), 2) and 3) Campbell and Sweetwater
Counties in AQCR 243 (Wyoming). (See Table A-l). Sweetwater County has
been designated as an S02 maintenance area. It is anticipated that special
requirements for these areas will be developed by the State and submitted
to EPA as a modification to the State Implementation Plan.
12
-------
3.0 AQCR ASSESSMENTS BASED ON SIP REVIEW AND CURRENT AIR QUALITY
The purpose of this section is to examine fuel switching in each of
Wyoming's three AQCR's and the adequacy or over-restrictiveness of current
regulations for attaining and/or maintaining ambient air quality standards.
Table A-9 is an attempt to assign a regional particulate emission tolerance
for Wyoming AQCR's. Appendix B uses this "tolerance," along with such
factors as, the breadth and depth of air quality violations, AQMA designations,
and percent of emissions resulting from fuel combustion to rate each AQCR
as a "good," "marginal," or "poor" candidate for fuel switching potential and
regulation relaxation.
Power plants and industrial sources, are investigated in Appendices
C, & D, respectively for fuel use, emissions, and current regulations.
Some calculations of emissions resulting from new Wyoming power plants are
included. Appendix E summarizes fuel use by sectors and Wyoming fuel
production.
3.1 REGIONAL S02 AND PARTICULATE EMISSIONS
Tables A-7 and A-8 present S02 and particulate emission summaries for
Wyoming AQCR's. About 50% of inventoried particulate emissions come from
fuel combustion sources on a statewide basis. The emissions are unequally
distributed between source types, however, with fuel combustion accounting
for 88% of the Casper AQCR emissions and only 11% of Cheyenne AQCR parti-
culate emissions. Fuel combustion sources contribute two-thirds of total
S02 emissions on a statewide basis.
Table A-9 presents an estimate of allowable particulate emissions for
each AQCR based on 1973 air quality. Allowable SOp emissions are not
calculated since low ambient S02 levels and scanty monitoring make any
"roll up" estimate questionable.
3.2 CANDIDACY ASSESSMENT FOR REGULATION RELAXATION
3.2.1 Particulates
Table B-l combines information in Appendix A into an evaluation of an
AQCR's potential for relaxation of the Wyoming particulate regulations.
Ambient TSP levels exceed NAAQS in all three Wyoming AQCR's. The Casper
13
-------
(241) and Wyoming (243) AQCR's have counties designated as maintenance
areas for TSP. Cheyenne (AQCR 242) has a low percentage of inventoried
particulate emissions resulting from fuel combustion. Particulate
regulation relaxation potential is rated as poor in all three of Wyoming's
AQCR's.
3.2.2 S02
All Wyoming AQCR's show SOp levels to be well below NAAQS. One
county in the Wyoming AQCR has been designated an AQMA for S02 and there-
fore, has to be rated as a poor candidate for regulation relaxation. The
remaning AQCR's are rated as good candidates.
3.3 POWER PLANT EXAMINATION
Table C-l lists fuel use and emissions for individual power plants in
Wyoming. Only two of the State's AQCR's (Casper and Wyoming) contain power
plants. The 1972 and 1973 fuel schedules indicate that the large power
plants in Wyoming have been recently using coal for all of their fuel
requirements. The data also indicate that Wyoming particulate regulations
were not met in 1973 based upon NEDS emissions inventories. There appears
to be little fuel switch potential for Wyoming power plants, and there is
no indication that Wyoming particulate regulation applied to power plants
will restrict emissions to levels much below the amount necessary to attain
and maintain NAAQS.
All Wyoming AQCR's have been rated as good candidates for increased
SOp emissions in Table B-2 based upon 1972 and 1973 air quality data. The
recently adopted Wyoming S02 emission regulation would apparently not have
been met if it had applied the 1972 and 1973 fuel schedules of the large
Wyoming coal fired power plants (Johnson and Naughton). The limited S02
monitoring data in the SAROAD Bank suggest that the present S02 regula-
tions on both existing and new sources may not be required for
maintenance of NAAQS. Verification of "non-violation" of NAAQS would, of
course, require a case by case examination and perhaps diffusion modeling.
14
-------
3.4 INDUSTRIAL AND AREA SOURCES
Little coal is apparently used at present by industrial and area
sources in Wyoming (Tables D-l and E-l). However, NEDS S02 and parti-
culate emission information available for this report is incomplete. It
does appear that some increased industrial coal use could occur within
existing particulate and S02 regulations. The physical limitations of
existing facilities (boiler design, internal combustion sources, etc.) are
probably the more limiting factor for fuel switching than the inability to
meet emission regulations.
3.5 WYOMING NOY REGULATIONS
A
NOX regulations for existing sources in Wyoming apply to oil and gas
users. Since large Wyoming power plants currently use coal, the NO
/\
regulations have little bearing on electric power generation. New power
plants will be subject to New Source Performance Standards (NSPS) for NOX,
as shown in Table A-10.
3.6 WYOMING ENERGY SUPPLY
Wyoming has extensive crude oil and natural gas fields in the central
and eastern portion of the State. In addition, Wyoming has sub-bitumunous
coal deposits in the Powder River and Green River Basins. Wyoming is also
a major uranium producer in the United States. Although Wyoming possesses
oil shale deposits in the Washakie Basin, near term commercial exploitation
of the shale resource is not expected. Table E-2 summarizes 1972 energy
production and domestic consumption for Wyoming. Fuel availability would
not appear to be a constraint for potential fuel substitution for Wyoming
sources.
15
-------
APPENDIX A
State implementation plan information
Current air quality information
Current emission information
Tables in this appendix summarize original and modified state imole-
mentation plan information, including original priority classifications,
attainment dates, ambient air quality standards, and fuel combustion emis-
sion regulations. SAROAD data for S09 and TSP monitoring stations are shown
1
for AQCR's in the state. NEDS emissions data 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
standards, is shown for particulates in Table A-9. The intent of this
calculation is to indicate possible candidate regions for fuel switching.
Tolerance was based on either the degree of control expected by the SIP
or upon air quality/emission relationships which are calculated from
more recent data. The value of the emission tolerance provides an indi-
cation of the potential an AQCR possesses for fuel switching and regu-
lation relaxation.
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 emissions sources than in a largely rural AQCR with geo-
graphically dispersed emissions.
No regional tolerance for emissions was calculated for SOp in Wyoming.
Low ambient S02 levels throughout the state make "rollup" calculations
appear unrealistic.
1l!1972 National Emissions Report," EPA 450/2-74-012, June 1974
A-l
-------
3=-
ro
WYOMING
INTRASTATE
(REMAINING
AREA)
AQCR 243
Washakie
Hot'
Springs
CASPER
INTRASTATE
AQCR 241
METROPOLITAN
CHEYENNE
INTRASTATE
AQCR 242
Figure A-l. Air Quality Control Regions in Wyoming
-------
Table A-l. AQCR Priority Classification and AQMAs- Wyoming
AQCR
Casper
Cheyenne
Wyoming
Fed. 1
241
242
243
Part.
II
II
III
soxa
III
III
III
c
NOX
III
III
III
Demographic Information
Population
1970
85554
100162
147200
Square
Miles
18819
11265
67122
Population
Density
4.5
8.9
2.2
AQMA Designations'1
TSP
Counties
(1 )Converse
None
(2)Campbell,
Sweetwater
S0x
Counties
None
None
(D
Sweetwater
NOX
Counties
None
None
None
Criteria Based on Maximum Measured (or Estimated) Pollution Concentration In Area
Priority
'Sulfur oxide:
Annual arithmetic mean ..
Parti cul ate matter:
Annual geometric mean ...
cN1trogen dioxide
I
Greater than
100
455
95
325
110
II
From - To
60-100 '
260-455
60- 95
150-325
III
Less than
60
260
60
150
110
Federal Register, August, 1974 SMSA's showing potential for MAVIS violations due to growth
-------
Table A-2. Attainment Dates- Wyoming
AQCR *
241
242
243
AQCR Name
Casper
Cheyenne
Wyoming
^articulates
Attainment Dates
Primary
a
a
a
Secondary
9/30/76
1/31/74
5/15/76
Sulfur Dioxide
Attainment Dates
Primary
a
a
a
Secondary
a
a
a
Nitrocen Oxides
Attainment Dates
a
a
a
-------
TIUTe~A-3. "Ambient A1r Quality Standards - Wyoming
Federal
(Nov. 1972)
State
Primary
Secondary
Total
Suspended Parti culate
Annual
75(6)
60(6)
60(6)
24-Hr.
260 2
1502
1502
Sulfur Oxides
Annual
80(A)
60(A)
24-Hr.
365 2
260 2
3-Hr.
13002
1300 2
Nitrogen
Dioxide
100(A)
100(A)
100(A)
1. Federal regulations apply
(G) Geometric Mean
(A) Arithmetic Mean
2Not to be exceeded more than once per year
-------
Table A-4. AQCR Air Quality Status (1973), TSPa - Wyoming
AQCR Name
Casper
Cheyenne
Wyomi ng
AQCR 1
241
242
243
Stations
Reporting
3
4
6
(M9/m3)
TSP Concentr
Highest Reading
Annual
68
74
118
24-Hr.
221
196
321
stion
2nd
Highest
Reading
24-Hr
192
155
277
1 Stations Exceeding
Ambient Air Quality Standards
Primary
Annua
0
0
1
Secondary
h iAnnual
,24-Hr.
0
0
1
2
1
1
%
67
25
17
24-Hrb.
3
1
2
%
100
25
33
% c
Reduction
Required to
Meet Annual
Secondary
Standard
29
41
74
% d
Reduction
Required to
Meet 2nd
24-Hr.
Standard
22
3
46
(§) 1973 air quality data in the SAROAD data bank, June 7, 1974.
O Violation based on the 2nd highest recorded 24 hour concentration.
© Formula % reduction = Annual Geometric Mean (AGM) - annual secondary STD
AGM - Background
2 3
Wyoming background TSP assumed to be 40' ug/M
<3) No background assumed for 24 hour levels.
-------
Table A-5. Wyoming AQCR Air Quality Status (1973), S02C
AQCR Name
Casper
Cheyenne
Wyoming
AQCR #
241
242
243
#
Stations
Reporting
24-Hr
(Bubbler)
2
1
2
#
Stations
Reporting
(Contin.)
N/A
N/.A
N/A
S02 Concentration
(A^g/m^)
2nd
Highest
Highest Reading Reading
Annual 24-Hr 24-Hr
8 16 14
6 22 n
7 12 10
# Stations Exceeding
Ambient Air Quality Stds.
Primary , Secondary
Annual 24-Hr0 3-Hr
00 0
00 0
00 0
%
Reduction
Required
To Meet
Standards
Presently
Meets
Standards
Presently
Meets
Standards
Presently
Meets
Standards
d!973 air quality in National Air Data Bank as of June 7, 1974
Violations based on more than one reading in excess of standards
-------
Table A-6. Fuel Combustion Source Summary* - Wyomi
ng
oo
AQCR Name
Casper
Cheyenne
Wyoming
AQCR f
241
242
243
Power Plants
NEDSa
1
0
4
FPCb
1
0
2
Other Fuel Combustion Point Sources b
Parti cul ate
4
3
8
so2
3
1
6
All sources from National Emission Data Bank Listfng as of December 6, 1974.
Federal Power Commission information for 1973 of major power plants
-------
Table A-7. Wyoming Emissions Summary, S09 (TO3 tons/yr), 1972
AQCR
Casper - 241
Cheyenne-242
Wyoming -243
, Total
10 J Tons/ Year
(1972 data)
33.0
13.7
29.8
Percent
Fuel Combustion
70.3
20.4
83.8
Electricity Generation
(103 Tons/Year)
19.6
0
20.1
% of
Total
Emission
59.4
0
67.4
Point Source
Fuel Combustion
(103 Tons/Year)
1.3
1.1
1.8
% of
Total
Emission
3.9
8.0
6.0
Area Source
Fuel Combustion
(103 Tons/Year)
2.3
1.7
3.1
% of
Total
Emission
7.0
12.4
10,4
I
UD
Table A-8. Wyoming Emissions Summary, Particulates (103 tons/yr), 1972
ADPR
Casper - 241
Cheyenne-242
Wyoming -243
, Total
(103 Tons/Year;
(1972 data)
21.9
4.3
57.0
Percent
Fuel Combustion
88.3
10.7
37.9
Electricity Generation
(103 Tons/Year)
18.6
0
20.0
% of
Total
Emission
84.9
0
35.1
Point Source
Fuel Combustion
(103 Tons/Year)
0.23
0.09
0.60
Total
Emi ssion
l.l
2.1
1.1
Area Source
Fuel Combustion
(103 Tons/Year)
0.50
0.37
0.99
% of
Total
Emission
2.3
8.6
1.7
-------
Table A-9. Wyoming Particulate Emission Tolerance
I
o
AQCR
Casper
(241)
Cheyenne
(242)
Interstate
(243)
Percent
Reduction
Requ i red
Based On
1973 AQ_Data
291
41 ]
741
NEDS
Emissions
(103 Tons)
21.9
4.3
57.0
Allowable
Emissions
(103 Tons)
15.5
2.5
14.8
Emission 2
Tolerance
(103 Tons)
0
0
0
1 Based on AGM with 40 ug/m background.
2 Current air quality data do not indicate particulate emission tolerance for Wyoming AQCRs,
-------
Table A-l 0. Wyoming Fuel Combustion Regulations
PARTICULATES
SULFUR OXIDES
NITROGEN OXIDES
Existing Sources:
Emissions In
Lbs/106 Btu
0~6
0.6
0.4
0.2S
0.2
Input Million
Btu/hr
__
10
100
1000
10000
Existing Sources:
(Before Jan 1, 1975)
For coal use;
Heat Input Ibs S09/106 Btu
250 x 10
2500 x 1
5000 x 1
5000 x 10
No limit
1.2
0.5
0.3
Applies to new, existing or
modified sources.
tatBM * ** m»\**uM~
1) Gas-fired equipment: Shall be
limited to 0.2 pounds per million
Btu of heat input
2) Oil-fired equipment: Shall be
0.3 pounds per million Btu of
heat input.
Industrial sources & nower plants
Shall be limited to 0.10 pounds per
million Btu maximum 2 hr average
Power^Plants: (1)
0.8 lbs/106" Btu (liquid
fuels)
1.2 lbs/106Btu (solid
fuels)
Industrial Sources
(After Jan 1, 1975)
Coal 0.2 Ibs S02/106 Btu
Oil 0.8 lbs/106 Btu
NSPS for
Power Plants \\)
0.7 lbs/106 Btu (solid
fuels)
1) Federal New Source Performance Standards (NSPS), 36 Fed. Reg. 24876, Dec 23, 1971
2) Adopted Jan 31, 1975
-------
APPENDIX B
Tables B-l and B-2 are the assessment of AQCR's which should be
examined for the fuel switching impact on particulate and S02 emissions.
They also provide an identification of those AQCR's 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) expected attainment dates for NAAQS, (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 Tables B-l and B-2 may 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" emission rate now
may be below "average" regulations.
B-l
-------
Table B-l. Candidacy Assessment for Relaxation of Participate Regulations - Wyoming
AQCR
Casper
241
Cheyenne
242
Wyoming
243
Air Quality
# # Violations'
Monitors Primary Secondary
303
4 0 1
6 1 2
Expected
Attainment
Date
9/30/76
1/31/74
5/15/76
Any
Counties
AQMA
Designations?
1
0
2
% Emissions
from Fuel
Combustion
88.3
10.7
37.9
Tolerance for
Emissions Increase
(103 tons)
0
0
0
Overall
Regional
Evaluation
Poor
Poor
Poor
EX!
I
ro
1
# Monitors exceeding either annual or 24 hour NAAQS for particulates.
-------
Table B-2. Candidacy Assessment for Relaxation of S02 Regulations - Wyoming
Air Quality
# #
AQCR Monitors Violations
Casper
241
Cheyenne
242
Wyoming
243
2 -0
1 0
2 0
Expected
Attainment
Date
(a)
(a)
(a)
Any
Counties
AQMA
Designations?
0
0
1
% Emission
from Fuel
Combustion
70.3
13.7
29.8
Tolerance
for
Emissions
Increase
(103 tons)
b
b
b
Overall
Regional
Evaluation
Good
Good
c
Poor
Air quality presently meets standards
b Present air quality is less than one-half the standard. Emission tolerances were not calculated
in this case because it was felt that the results would be misleading. However, additional S02
emissions could be tolerated in all Wyoming AQCR's.
cThis "Poor" rating is based on the fact that this AQCR contains a Designated AQMA.
-------
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.
Current power plant information used to prepare Table C-l was obtained
from three main sources: (1) Federal Power Commission computerized listings
of power plants and their associated fuel use, (2) the National Coal Asso-
ciation "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 footnotes of Table C-l were used otherwise. SCL and particulates
emissions are those associated with the fuel use listed. In the case of
particulates, emissions were calculated using NEDS emissions factors applied
to the listed fuel schedule (in both tonnage and lbs/10 Btu). When a plant
was not listed in NEDS, AP-42 emission factors were used to estimate SOp and
TSP emissions (Table C-3).
National Emissions Data System Information, retrieved December 1974.
C-l
-------
Table C-l. Wyoming Power Plant Fuel Combustion and Emission Summary
County
&
AQCR
Lincoln
AQCR
243
Converse
AQCR 241
Campbel 1
AQCR 243
Sweetwater
AQCR 243
Weston
AQCR 243
Plant Name
3
Naughton
707MW
Johnston
758MW
3
Niel Simpson
28MW
Trona
16MW
Osage 3
35MW
Fuel Use
Type
% Sulfur
% Ash
Coal,0.5%S
5.0% Ash
Coal,0.6%S
9.3%A
Coa 1,0.4%$
5.0% Ash
Oil (1% S)4
Gas
Coal 0.4%S
5.2% Ash
2
Annual
Quantity
2327
2897
198
94
2500
219
Heat
Input
(106 Btu/hr)
4280
4880
360
62
285
347
400
Emissions
S02
Existing j Allowable
tons/yr
22,600
33,000
1390
310
310
1590
lbs/10<
Btu
1.20
1.54
0.9
1.12
0.2
0.90
5
tons/vr
9400
13,700
1850
No Re<
2100
Particulates
Existing I Allowable .
lbs/10*
Btu ftons/vr
0.5
0.5
1.2
ulatio
1.2
21,700
20,OOC
14.60
i 16
20
36
673
lbs/106
Btu
1.16
0.93
0.9
.06
.02
.03
0.4
tons/y
4100
4700
490
360
500
lbs/10(
Btu
0.22
0.22
0.3
0.3
0.3
1 Power plants having 1QMW or greater generating capacity.
2 Coal 103 tons, Oil 1CT BBLS, Gas 106 ft3,
3 /1973 fuel schedule & emissions used, for Nauqhton, Johnston Plants
-------
Table C-2. Power Plant Projected Development
AQCR
Wyoming (243)
Cambell Co.
Wyoming (243)
Sweetwater Co.
Wyoming (243)
Sweetwater
County
Platte County
Owner-
Black Hills Power 5
Light
Pacific Power &
Light
1
Plant
Wyodak #la
(1977)
Jim Bridger #la
(1974)
Jim Bridger #2a
(1975)
Jim Bridger #3a
(1976)
Naughton
#4
#5
Basin Electric
1, 2, 3
MW
330
508
508
508
860
1500
Estimated Emissions NSPS - Tons/Yr
Participates
1168
1798
1798
1798
N/A
N/A
so2
14032
21600
21600
21600
N/A
N/A
N0y
8184
12598
12598
12598
N/A
N/A
-------
Table C-3. AP-42 Power Generation Emission Factors
Fuel
Coal(1) (Bit.)
General
Wetbottom 10% A
Cyclone
1% S
2% S
3% S
on'2)
0.5% S
1.0% S
2.0% S
Gas'3'
(.3 Ibs S/106 Ft3)
Participates
Lbs/Ton Lbs/106 Btu
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
Lb/106Ft3
15 .015
so2
Lbs/Ton Lbs/106 Btu
38 1.65
76 3.3
114 5.0
Lb/103 Gal
79 0.56
157 1.12
314 2.24
Lb/106Ft3
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/106Ft3
1 .001
f!0x (as N02)
Lbs/Ton Lbs/106
18 0.78
30 1.3
55 2.4
Same Same
as as
Above Above
Lb/103 Gal
105 0.75
105 0.75
105 0.75
Lb/106Ft3
600 0.60
(1) Coal 23 x 106 Btu/Ton
,3
(2) Oil 140 x 10
(3) Gas 1000 Btu/Ft
Btu/Gal
3
-------
APPENDIX D
The Table D-l in this Appendix lists individual industrial/commercial/
institutional sources of particulates and SCL emissions which might show
fuel switching potential. The NEDS data available for this report is
incomplete, and no attempt is made to comprehensively list Wyoming
industrial sources.
D-l
-------
Table D-1. Wyoming Industrial-Commercial Fuel Combustion & Emissions Summary
County
^(atrona
AQCR
241
Carbon
Weston
Plant Name
Size, and -
Fuel Design
Little
American
Oil
Petronics
Tesoro
Petroleum
Fuel Use
Type , Heat
% Sulfur Annual Ir.put
% Ash Quantity (1G5Btu/Hr)
Gas 425 49
Oil 7.2 4.8
0.3%
Oil 9.5 6.3
0.5%
Gas -46 51
Etiiiss
SO-,
AlicwaD'e hnnssions
(Be sea on
Existina Regulations Limits)
Tons/Yr Lfas/'106Stu Tons/Yr Lbs/10°Btu
1 No. Reg.2
6 No. Reg.
13 No. Reg.
1 No. Reg.
i ons
TSP
|A1 iowable Emissions
(Based on
Existing , Regulations Limits)
Tons/Yr Lbs/ltTBtu Tons/Yr Lbs/105Btu
4 128 0.6
2 13 0.6
33 16 0.6
38
o
I
ro
1 *(0il - 103 bbls
(Gas - 106 ft3
2 See Table A-10, SOg regulations for oil and gas users apply only to new sources (after January 1, 1974)
-------
APPENDIX E
A summary of Wyoming fuel use totalized from the NEDS data bank
is presented in Table E-l. Table E-2 lists fuel production and consump-
tion figures for Wyoming (1972).
E-l
-------
Table E-l. Wyoming Stationary Source Fuel Summary
Point Sources
Electric Generation
Industrial
Commercial /Institutional
Area Sources
Resources
Industrial
ji
Commercial /Institutional
State Total
(102 BTU)
'ercent of Total
inergy Supplied
Coal (103tons)
4114
4
-
34
-
-
4219
83
(43%)
Oil (io3 bbls)
10
1210
-
103
1390
386
3070
18.1
(9%)
Gas (106 ft3)
V
43
29574
119
17500
27360
18350
93212
93
(48%)
i
Wood (tons)
!
10100
10,100
0.1
-
-------
Table E-2. Energy Statistics for Wyoming
Coal
(TO13 Tons)
Oil,
(1(T BBL)
Gasfi ^
(10b FT3)
Uranium
fl03 ibs]
I.U3°8 J
Production
10928
140,011
375,059
8,544
Consumption
4802
17,491
121,226
*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).
-------
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) Environmental Quality Council of Wyoming, "Air Quality Standards
and Regulations" Sections 1-20. Effective April 9, 1973,
amended June 2, 1974. Sulfur oxide regulation adopted Jan 3, 1975.
-------
TECHNICAL REPORT DATA
(Please read Jaamctions on the reverse before completing)
1. REPORT NO.
EPA-450/3-75-022
2.
3. RECIPIENT'S ACCESSION-NO.
4. TITLE AND SUBTITLE
5. REPORT DATE
IMPLEMENTATION PLAN REVIEW FOR WYOMING 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 VIII, Denver, Colorado,
and TRW. Inc.. Redondo Beach. Calif. 9Q278
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.
17.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.lDENTIFIERS/OPEN ENDED TERMS C. COSATI Field/Group
Air pollution
State Implementation Plans
18. DISTRIBUTION STATEMENT
Release Unlimited
19. SECURITY CLASS (ThisReport)
Unclassified
21. NO. OF PAGES
39
20. SECURITY CLASS (Thispage)
Unclassified
22. PRICE
EPA Form 2220-1 (9-73)
------- |