EPA-450/3-75-023
February 1975
IMPLEMENTATION PLAN REVIEW
FOR
MISSOURI
AS REQUIRED
BY
THE ENERGY SUPPLY
AND
ENVIRONMENTAL COORDINATION ACT
U. S. ENVIRONMENTAL PROTECTION AGENCY
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IMPLEMENTATION PLAN REVIEW
FOR
MISSOURI
REQUIRED BY THE ENERGY SUPPLY AND ENVIRONMENTAL COORDINATION ACT
PREPARED BY THE FOLLOWING TASK FORCE:
U. S. Environmental Protection Agency, Region VII
1735 Baltimore Avenue
Kansas City, Missouri 64108
Environmental Services of TRW, Inc.
(Contract 68-02-iD385)
U. S. Environmental Protection Agency
Office of Air and Waste Management
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
February 1975
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TABLE OF CONTENTS
Page
1.0 EXECUTIVE SUMMARY !
2.0 MISSOURI SIP REVIEW 6
2.1 Summary 6
2.2 Air Quality Setting in Missouri 7
2.2.1 State Ambient Air Quality Standards 7
2.2.2 Suspended Particulate Air Quality - 1973 7
2.2.3 S02 Air Quality - 1973 10
2.3 Missouri Emissions - 1972 NEDS Inventory 10
2.3.1 Particulates 10
2.3.2 S02 11
2.4 Background on Missouri SIP 11
2.4.1 Particulates 11
2.4.2 S02 11
2.4.3 Oxidant and N02 11
3.0 AQCR ASSESSMENTS BASED ON SIP REVIEW AND CURRENT AIR QUALITY . . 12
3.1 AQCR 070 - Metro St. Louis Interstate 12
3.1.1 Candidacy Assessment for Fuel Switch Potential - . . 12
Particulates
3.1.2 Candidacy Assessments for Fuel Switch Potential - S02 13
3.1.3 Emission Source Examination 13
3.1.4 Regulation Examination - Particulates 14
3.1.5 Regulation Examination - S02 14
iii
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TABLE OF CONTENTS (Continued) Page
4
3.2 AQCR 094 - Metro Kansas City Interstate 15
3.2.1 Candidacy Assessment for Fuel Switch Potential .... 15
3.2.2 Emljssion. Source Examination 16
3.2.3 Regulation Examination - Particulates 16
3.2.4 Regulation Examination - SOg 16
3.3 Outstate Missouri AQCR's 137, 138, and 139 17
3.3.1 Candidacy Assessment - Particulates 17
3.3.2 Candidacy Assessment - S02 17
3.3.3 Emission Source Examination 17
3.3.4 Regulation Examination > 18
APPENDIX A - Background Information on SIP, Air Quality, Emissions . . 19
APPENDIX B - Candidacy Assessments for Relaxation of Regulations/Fuel
Switch Potential 34
APPENDIX C - Power Plant Assessments 37
APPENDIX D - Industrial Commercial Sources Assessment 47
APPENDIX E - Area Source Assessment 52
APPENDIX F - Regulation Evaluation and Fuel Statistics 55
BIBLIOGRAPHY 61
iv
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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 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 infor-
mation 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 con-
sistent 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 imple-
mentation plans with regards to saving low sulfur fuels and, where the
primary sulfur dioxide air quality standards were not exceeded, to
encourage States to either defer compliance regulations or to revise the
S0? emission regulations. The States have also been asked to discourage
large scale shifts from coal to oil In cases where such shifts are not
required for attainment and maintenance of the NAAQS.
1
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To date, EPA's fuels policy has addressed only those States with the
largest clean fuels saving potential. Several of these States have or are
currently in the process of revising SOp 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 aJM_ 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; 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 situa-
tions 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 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 for 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 excessive 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.
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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. Jhe 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 were
used in the analysis.
The data upon which the reports' findings are based is the most
V*
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 HC emissions which occur in fuel switching, and other potential
X
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 oil ate
matter (TSP) and sulfur dioxide (S02) emissions. This is because stationary
fuel combustion sources constitute the greatest source of SO,, emission and are
a major source of TSP emissions.
* except data currently being processed by EPA
3
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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 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 Appendix C, D, and E.
The State Implementation Plan for Missouri has been
reviewed for the most prevalent causes of over-restrictive
fuel combustion emission limiting regulations. The major
findings of the review are:
FOR PARTICULATES, THERE IS LITTLE INDICATION THAT
EXISTING REGULATIONS FOR FUEL COMBUSTION SOURCES
ARE OVERLY-RESTRICTIVE. FOR SULFUR DIOXIDE. THERE
ARE INDICATIONS THAT EMISSION LIMITING REGULATIONS
FOR VERY LARGE FUEL BURNING SOURCES MAY BE
OVERLY-RESTRICTIVE.
The Kansas City and St. Louis Metropolitan areas were
originally evaluated separately by the State of Missouri.
Kansas City was used as the example region for the three
out-state Missouri AQCR's. Missouri also has adopted
ambient air quality standards different from the Federal
Standards.
§ Suspended particulates appear to be a widespread problem
in Missouri. Metro St. Louis has recently been proposed
a maintenance area for suspended particulates. There are
no indications that current fuel burning regulations are
overly-restrictive in the Metropolitan areas of Kansas
City and St. Louis, or in outstate Missouri. A limited
amount of fuel switching could occur without particulate
regulation changes. However, should all sources now burning
natural gas, for example, switch to coal, more stringent
emission limiting regulations would be necessary to meet
TSP air quality standards.
Missouri has direct fuel combustion regulations for SO,,
only in the Metropolitan St. Louis Area. Except in St.
Louis, therefore, fuel switching is not hindered by SOp
emissions regulations, Current air quality sampling data
for St. Louis indicate nigh isolated S02 concentrations in
the Missouri portion of the metropolitan area. However,
sources of SO? other than power plants are in the immediate
vicinity of these "hot spots." Since these sources are
presently meeting existing emission regulations, there are
strong indications that regulations affecting these sources
must be tightened.
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There are currently no indications that S02 emissions from
power plants in the Missouri portion of the St. Louis area
are causing violations of S02 air quality standards. In the
context of ESECA, these regulations may be revised. With re-
gard to power plants, should the State of Missouri decide to
revise the current SOp emission limiting regulations, EPA
strongly suggests that the changes be closely coordinated
with the State of Illinois.
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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 State have emission limitation regulations for
control of (1) power plants, (2) industrial sources,
(3) area sources?
Did the State use an example region approach for demonstrating
the attainment of NAAQS 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 proposed Air Quality Maintenance Areas?
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 (1973) air quality data, are there no reported
violations of NAAQS?
Based on (1973) air quality data, are there indications
of a tolerance for increasing emissions?
Are the total emissions from stationary fuel combustion
sources proportionally lower than those of other sources?
Must emission regulations be revised to accomplish significant
fuel switching?
t Is there a significant clean fuels savings potential in the
region?
Do modeling results for specific fuel combustion sources
show a potential for a regulation revision?
The following portion of this report is directed at answering these
questions. An AQCR's potential for revising regulations increases when
there are affirmative responses to the above.
The initial part of the SIP review report, Section 2 and Appendix A,
was organized to provide the background and current situation information
6
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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 the regional analysis, a characterization
of the State's fuel combustion sources (power plants, industrial sources, and
area sources) has been carried out in Appendix C, D, and E. Finally, candi-
dates from Appendix B are examined in Appendix F for adequacy or over-
restrictiveness of emission regulations.
Based on an overall evaluation of EPA's current information, AQCR's
have been classified as good, marginal, or poor candidates for regulation
revisions. The following table summarizes the State Implementation Plan
Review. The remaining portion of the report supports this summary with
explanations.
2.2 AIR QUALITY SETTING - MISSOURI
Missouri has been divided into five (5) Air Quality Control Regions:
(1) AQCR 070 - Metro St. Louis Interstate
(2) AQCR 137 - Northern Missouri
(3) AQCR 138 - South Eastern Missouri
(4) AQCR 139 - South Western Missouri
(5) AQCR 094 - Metro Kansas City Interstate
2.2.1 State Ambient Air Quality Standards
Missouri's AQCR's are shown geographically in Figure A-l. Missouri has
adopted ambient air quality standards different .from the federal standards.
Table A-3 shows that State SOp standard for Missouri are somewhat more strict
than federal standards, although averaging time differences make comparison
uncertain. For particulates, the State standards are identical to federal
secondary standards, except for the less stringent standards set for
St. Louis. (AQCR 070).
2.2.2 Suspended Particulate Air Quality - 1973
Table A-4 summarizes Missouri SAROAD data for suspended particulates in
1973. All five Missouri AQCR's appear to have adequate TSP monitoring. Sus-
pended particulates seem to be a widespread problem throughout Missouri. Less
7
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Missouri State Implementation Plan Review
(Summary)
"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:
I. 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 proposed Air Quality Maintenance
Areas?
Are there indications of a sufficient number
of monitoring sites within a region? (1)
* Is there an expected 1975 attainment date
for NAAQS?
t 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 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?
(Metro (Metro (North (S.E. (S. W.
St. Louis)Kansas City) Missouri) Missouri) Missouri)
070 094 ' 137 138 139
STATE AOCR ' AQCR . AQCR AQCR AOCR
TSP
YES
YES
YES
so?
YES
YES
YES
<
TSP S02
NO
YES
YtS
YES
YES
YES
YES
NO
NO
YES
NO MOD
NO
POOR
NO
YES
YES
YES
NO
YES
YES
NO
NO
NO
ELING R
YES
MARGI-
. HAL2
NO
TSP S02
NO
YES
YES
NO
NO
YES
YES
NO
NO
YES
ESULTS
NO
POOR
YES
NO
"NO
NO
NO
NO
YES
YES
YES
NO
AVAILAE
NO
N/A3
YES
TSP S02
NO
YES
YES
NO
NO
YES
YES
NO
NO
NO
LE FOR
YES
POOR
YES
NO
NO
NO
'
NO
NO
YES
YES
YES
NO
MISSOUI
NO
N/A3
YES
TSP S02
NO
YES
YES
NO
NO
YES
YES
NO
NO
YES
I SOURC
NO
POOR
YES
NO
NO
NO
NO
NO
YES
YES
YES
YES
ES<-
NO
N/A3
YES
TSP S02
NO
YES
YES
NO
NO
YES
YES
NO
NO
YES
»
NO
POOR
YES
NO
NO
NO
NO
NO
YES
YES
YES
NO
NO
N/A3
YES
Only an .analysis tool «nd is not indicative of SIP Requirements.
See Section 3.1.5.
No applicable SO- regulation which could be revised
See Section 3.1.5
8
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NORTHERN
MISSOURI
INTRASTATE (137)
METROPOLITAN
KANSAS CITY
INTERSTATE
(KANSAS-
KISSOURI) (094)
METROPOLITAN
LOUIS
INTERSTATE
ILLINOIS
(070)
SOUTHWEST
MISSOURI
INTRASTATE
(139.)
SOUTHEAST
MISSOURI
INTRASTATE
(138)
MISSOURI AQCR's
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urbanized Northern and Southern Missouri mainly have problems relative to
the short term standard, while Metro Kansas City and Metro St. Louis report
around half of stations violating the secondary annual TSP standard in addi-
tion to many violations of the secondary 24 hour standard. The AQCR's 137,
138 and 139 appear to have more localized TSP problems than the Metropolitan
AQCR's 070 and 094.
2.2.3 S02 Air Quality - 1973
The only 1973 violation of Federal ambient air quality standards
appeared in the St. Louis AQCR (Table A-5). The first page of Table A-5 lists
SAROAD data for 1973. Additional S02 air monitoring data for Metro St. Louis
(AQCR 070) is shown on the second page of Table A-5. AQCR 070 seems to have
o
annual average SOp levels at around 50 )jg/m at several locations. Two sta-
tions in Missouri and two in Illinois appear to have SOp levels above
70 )jg/m3, with one St. Louis station indicating an annual average of
118 jjg/m3.
2.3 MISSOURI EMISSIONS - 1972 NEDS INVENTORY
Although individual source emissions from more recent NEDS data was
available for this report, the tables in Appendix A and the discussion below
refer to 1972 NEDS data. This was mainly for convenience and simplicity.
Table C, D and E reflect more recent emissions information, however.
2.3.1 Particulates
Fuel combustion accounts for about a third of reported particulate
emissions in Missouri (Table A-7). Particulate emissions from power p.lants
dominate the particulate inventory only in Kansas City (094). In St. Louis,
industrial and area source emissions are important contributors, while area
sources account for the largest fraction_of emissions in outstate Missouri
(AQCR 137, 138, and 139). The 1972 NEDS particulate inventory shows the
Illinois portion of St. Louis (AQCR 070) to contribute most of the reported
emissions. The NEDS indicates that Kansas and Missouri sources contribute
about equally to particulate emissions in AQCR 094 (Metro Kansas City).
2.3.2 Sulfur Dioxide
Table A-8 shows that reported S02 emissions originate largely from fuel
combustion in Missouri, and the largest fraction of S02 in the fuel combustion
10
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category is from power plants. 1972 reported S02 emissions originating in
the Illinois portion of AQCR 070 (St. Louis) are higher than those originating
in Missouri, especially from power plants. In Metro Kansas City, S02 emissions
are largely from power plants; the Missouri portion of AQCR 138 has only one
power plant and no reported industrial S02 emissions (1972).
2.4 BACKGROUND ON MISSOURI SIP
Table A-l lists the original priorities for S02 and particulates for
Missouri AQCR's. Metro St. Louis (070), Metro Kansas City (094), and Northern
Missouri were Priority I for particulates. All Missouri AQCR's but St. Louis
were Priority III for SOp, St. Louis being Priority I.
2.4.1 Particulates
The Metro Kansas Ctiy Interstate Region (AQCR 094) was used as the
particulate example region for Missouri, except for St. Louis (AQCR 070).
Particulate emissions regulations are not the same for 094 and outstate
Missouri, however (see Table A-ll). An Air Quality Display type model was
used to demonstrate attainment of the secondary federal particulate standards
in both Kansas City and in St. Louis. In addition to the regulations for
large particulate emission sources in St. Louis (Table A-ll), the SIP indicated
that area source particulate controls would be instituted.
2.4.2 S02
S02 was Priority I only in St. Louis and attainment of federal ambient air
quality standards was demonstrated using an AQDM type model. Both point and
area source S02 emission controls were adopted (Table A-ll) for St. Louis.
No S02 regulations were adopted for Missouri's other AQGR's. In the
SIP, Kansas City was used as an example region to show that source growth
would not cause S02 problems, with clean fuels being an inherent assumption
in this projection.
2.4.3 Oxidant and N02
Both Kansas City (094) and St. Louis had oxidant violations at the time
the SIP was written. The Federal Motor Vehicle Control Program was shown to
be adequate for attainment of the oxidant standard without additional hydro-
carbon controls.
Althouth St. Louis was originally Priority I for N0p> AQCR 070 has since
reel;
Missouri. 11
been reclassified to Priority III, and no NO controls have been instituted in
A
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3.0 AQCR ASSESSMENTS BASED ON SIP REVIEW AND CURRENT AIR QUALITY
The purpose of this Section is to examine fuel switching in Missouri's
five AQCR's for over-restrictiveness of current emission regulations
for attaining and/or maintaining ambient air quality standards. Tables A-9
and A-10 are an attempt to assign a regional emissions tolerance for Missouri
AQCR's. Appendix B uses this "tolerance", along with such factors as the
breadth and depth of air quality violations 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, industrial sources, and area sources are investigated in
Appendices C, D, and E respectively for fuel use, emissions, and current
regulations. Some calculations of emissions resulting from fuel switching
are included for power plants. Appendix F is a rough emissions inventory
which could hypothetically result if all fuel burning sources emitted exactly
at regulation levels. This inventory is the final test of current regulations
relative to air quality.
Although each AQCR is treated separately in the appendices, Missouri's
outstate AQCR's are lumped together in this section because their situation
is similar and thus ftnal conclusions concerning regulations are similar.
3.1 AQCR 070 - METRO ST. LOUIS INTERSTATE
3.1.1 Candidacy Assessment for Fuel Switch Potential - Particulates
AQCR 070 shows several violations of TSP standard both in Missouri and
.in Illinois. Although 1972 NEDS data reported Illinois particulate emissions
to be much larger than those from Missouri, the sample air quality maintenance
(13)
plan for St. Louisv ' shows expected 1975 particulate emissions to be of
similar magnitude between the two states (Table A-9). AQCR 070 is assigned a
zero increased particulate emissions tolerance in Table A-9 since the data do
not indicate that emissions will be "over controlled" relative to
attainment of NAAQS. Further, both Illinois and Missouri counties have been
proposed as maintenance areas for TSP. Thus AQCR 070 receives a poor candidacy
rating in Table B-l for particulate regulation revision and fuel switch potential
12
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3.1.2 Candidacy Assessment for Fuel Switch Potential - SOp
In Table A-10, the worst station S02 air quality reading in 1973 was
applied to the 1972 NEDS inventory for AQCR 070, and the allowable emissions
distributed between Missouri and Illinois in proportion to existing emissions.
The NEDS 1972 inventory does not appear comparable to the 1975 estimated from
the sample air quality maintenance plan for St. Louis. New power plant
emissions may account for some of the difference of relative emission contri-
butions from Illinois and Missouri. It should be commented that S02 levels
elsewhere in Metro St. Louis are lower than the level used to calculate
"allowable emission" in Table A-10, and the 118 yg/m annual average S02
concentration represents a "hot spot". The approach in this report is a
regional one and the numbers merely reflect the data base; the regional
assumption about the air quality emissions relationship and the propor-
tional allocation of "allowable" emissions between Missouri and Illinois.
Although total S02 emissions in AQCR 070 for 1975 appear lower than
those in the 1972 NEDS, the tonnage is larger than the calculated "allowable"
emissions. It is uncertain foow comparable the two emissions inventories
really are. AQCR 070 is assigned a zero tolerance for increased SOp
emissions, and rated as a poor candidate in Table B-2 for fuel switch
potential from an S02 standpoint.
3.1.3 Emission Source Examination
Missouri power plants in AQCR 070 use predominately coal at present
(Table C-l). The three large power plants (Sioux, Labadie, and Meramac) are
using coal of higher sulfur content than allowed by existing regulations
(without stack gas S02 removal). Table C-2 indicates aggregated S02 emissions
to be about twice the amount which existing regulations would allow,
Particulates are generally controlled to below the amounts which regulations
would allow. Power plant "fuel switching" possibilities in AQCR 070 are
mainly limited to the use of higher sulfur coal.
Industrial emission sources (Table D-l) in AQCR 070 (Missouri) use coal
for around one third of their .gross heat input. Coal currently used would have,
if used alone, more sulfur than allowed by existing regulations. Aggregated
S02 emissions (Table D-2) are slightly below allowed emissions, however, so that
individual users may be able to increase coal under existing regulations.
Aggregated industrial particulate emissions are indicated to be more than the
13
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amount regulations would allow. Industrial fuel switching in St. Louis
would require lower sulfur coal than is currently used and more parti-
culate emission controls to meet existing regulations.
Area sources in AQCR 070 (Table E-2) are subject to S02 and particulate
emission limitation by virtue of sulfur and ash requirements for coal used
(winter months only). Coal in the NEDS inventory for St. Louis area sources
was reported higher in sulfur than regulations would allow. Since only a
small portion of total heat input by area sources is supplied by coal, some
additional coal could in principle, be used, although the ability of many
small sources to convert to coal is not known. It might be commented from
Table E-2 that increased SOg and particulate emissions would result from gas
and oil conversions to coal even under existing regulations.
3.1.4 Regulation Examination - Particulates
Table F-l is a rough emissions inventory for the Missouri portion of
AQCR 070, showing present emissions and those which might result if all
sources were allowed to emit according to regulations. Although the expected
degree of control for non-fuel particulate sources is not known, particulate
regulations do not appear over-restrictive in Missouri, regardless of the
manner in which "allowable" emissions are distributed between Missouri and
Illinois. Considering that St. Louis has been propbsed as a maintenance
area for particulates and that no source growth was considered in Appendix F,
fuel burning particulate emission regulations should not be relaxed if air
quality is to be attained and maintained.
3.1.5 Regulation Examination - SOp
Table F-2 evaluates the effect of regulation compliance on total S02
emissions from Missouri sources in AQCR 070. The rough emissions analysis
indicates that existing fuel burning SOp regulations applied to existing
sources results in a Missouri SOp emissions total about equal to the
"allowable" emissions assigned to Missouri from Table A-10 (based on worst
case air quality in the region). On a regional basis, this suggests that
S02 regulations are not overly restrictive in St. Louis. Close agreement
of the "emissions at regulations" column (Table F-2) and the "estimated
allowable" column is not intended to imply any particular accuracy to
Table F-2.
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However, modeling studies were conducted to predict the relationship
between power plant SC^ emissions and ambient air concentrations. The
modeling results indicated that the S02 emissions from power plants located
in Missouri were not responsible for the reported ambient air quality viola-
tions in downtown St. Louis. Local SOp emissions from smaller industrial
fuel combustion sources were apparently the cause of NAAQS violations. Thus,
there is some tolerance for an increase in SO,, emissions from the existing
Missouri power plants in AQCR 070. On the other hand, S02 emissions from
small fuel combustion sources in the area of the "hot spot" must be reduced
to attain the standards.
3.2 AQCR 094 - METRO KANSAS CITY INTERSTATE
3.2.1 Candidacy Assessment for Fuel Switch Potential
AQCR 094 shows several violations of TSP standards, both in Kansas and
in Missouri with the highest concentrations being indicated in Kansas (Table
A-4). Particulate emissions are about evenly distributed between the two
states (Table A-8), although a much smaller fraction of total particulate
emissions results from fuel combustion in Kansas than in Missouri. The
original Kansas and Missouri SIP's gave np_ indication that particulate
regulations would more than meet air quality standards in AQCR 094. There-
fore, Metro Kansas City is rated as a bad candidate for fuel switching and
regulation relaxation from a particulates standpoint.
SOg levels are slightly below ambient air quality standards in 094
(Metro Kansas City), with somewhat higher readings in Kansas than in
Missouri (Table A-5). As might be expected, most of the S02 results from
fuel combustion in 094, expecially in Missouri (Table A-7). The Missouri
contribution of total S02 emissions is much higher than that of Kansas.
AQCR 094 is assigned an approximate 45,000 ton regionwide tolerance for
increased S02 emissions, based on a 22% roll up of air quality levels to
standards. Table A-10 distributes this tolerance between Missouri and Kansas,
in proportion to existing emissions. Table B-2 rates AQCR 094 as a good
initial candidate for fuel switching.
15
-------
3.2.2 Emission Source Examination
Coal is the dominant fuel for electric power generation in the Missouri
portion of AQCR 094 (Tables C-l and C-2). Power plants in the Kansas portion,
in contrast, use mostly natural gas. According to NEDS information,
aggregated particulate emissions are larger than the amount allowed by
regulations in the Missouri portion of AQCR 094. No direct sulfur regulation
applies to power plants (or other fuel burning sources). The reported sulfur in
coal used by 094 power plants varies from 1.5 to 3.7%.
No coal is reportedly used by major emission sources in the Missouri
portion of AQCR 094 (Table D-l). Consequently, particulate emissions are
generally below regulations (Table D-2).
Table E-l shows that Missouri area sources use only small amounts of
coal compared to Kansas area sources in AQCR 094. Still, coal is a minor
area source fuel on a total energy basis in AQCR 094 (Table E-2). Although
a few area sources would be governed by particulate emission regulations in
Kansas City, many are too small to be covered. The large natural gas use at
present, implies that, even if emission regulations.were.to.apply.to area sources,
total S02 and particulate emission increases would accompany almost any
gas to coal switching. The extent to which fuel conversions by industrial
and area sources is feasible is unknown at this time.
3.2.3 Regulation Examination Particulates
Table F-l shows the calculated particulate emissions which might result
if all sources were to exactly meet existing fuel burning regulations. In
the Kansas portion of 094, total particulate emissions could increase without
violation of existing regulations, In Missouri, total particulate emissions
would decrease as power plants meet the regulations. Note that uncontrolled
non-fuel particulate emissions dominate the inventory in both Kansas and
Missouri. Despite either a) the degree of control one might assume for non-
fuel sources, or b) the manner in which "allowable" emissions might be distributed
between Kansas and Missouri, fuel burning particulate emission regulations
could not be judged overly restrictive by the simple test of Appendix F.
3.2.4 Regulation Examination - S02
No direct SOg emission regulation applies to fuel burning sources in
the Missouri portion of AQCR 094. In Kansas (094), where an S02 regulation
16
-------
has been adopted, additional emissions could occur from fuel switching
within the Kansas regulation. The emissions comparison in Table F-2 indi-
cates that additional SCL emissions might occur in the Missouri portion of
AQCR 094 without air quality violations.
3.3 OUTSTATE MISSOURI AQCRs 137, 138, and 139
3.3.1 Candidacy Assessment - Particulates
Table A-4 indicates particulates to be a localized problem in out-
state Missouri. Kansas City was considered the particulate example region
for Missouri (other than St. Louis), although current regulations are not
those which apply in Kansas City. Since there is no indication of over-
control of particulates in outstate Missouri, either from the SIP or from
recent data, a zero increased particulate emissions tolerance is assigned
to outstate Missouri in Table A-9. Table B-l rates the AQCRs 137, 138,
and 139 as poor candidates for the switch potential.
3.3.2 Candidacy Assessment - SO,,
Scanty S02 monitoring data in outstate Missouri makes generalizations
difficult. No SO- ambient air quality violations are reported. As far as
fuel switching, no direct SO^ fuel burning emission regulations apply, so
that Table B-2 rates the outstate AQCRs as good potentials for fuel switching
from an S02 standpoint.
3.3.3 Emission Source Eacatnination
Although coal currently dominates electric power production in outstate
Missouri, some additional coal might be substituted for natural gas (Table
C-l). Many of the power plants have some particulate emission controls at
present, so that aggregated particulate emissions are not dramatically above
the allowed emissions (Table C-2).
Industrial sources in AQCR 137 would appear to have some gas to coal
fuel switch potential (Table D-l). Although existing particulate emissions
are not greatly above those allowed by regulations, further particulate
controls would be necessary to meet existing regulations if additional coal
was to be used by this industrial sector. AQCR 139 has no reported
industrial coal use at present.
17
-------
Table E-l lists area source fuel use in outstate Missouri. Natural
gas ts seen to dominate the total. Little is known about the ability of
area sources to switch fuels, but particulate regulations generally apply
only to larger sources and hence may not be a major factor in fuel
conversions.
3.3.4 Regulation Evaluation
Although regional aggregation of emissions has doubtful meaning in
outstate Missouri, Table F-l indicates that emissions resulting from all
sources just meeting the particulate regulations would exceed the tonnage
estimated from rollback (proportional to worst case air quality). To the
extent that the regional approach is valid, there is no indication of over-
restrictive particulate regulations in outstate Missouri.
No direct SCL emission regulations apply to outstate Missouri, and
no regulation test was used in Table F-2 for outstate Missouri.
18
-------
APPENDIX A
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. SAROAD data for S09 and TSP monitoring stations are shown
1
for AQCRs in the state. NEDS emissions data by AQCR are tabulated and
broken down into fuel burning categories.
Tables A-9 and A-10 show a comparison of emission inventories in the
original SIP and those from the NEDS. 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 S0? and particulates.
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 pro-
vides an indication of the degree of potential an AQCR possesses for fuel
revisions and regulation relaxation.
Methodology for Increased Emissions Tolerance
A tolerance for increased emissions was determined as follows. First,
an ".allowable emissions" was calculated for each AQCR based on the current
NEDS data and the percent reduction (or increase) required to meet the
national secondary ambient air quality standards in that AQCR (worst case
from Tables A-4 and A-5). This "allowable" was then compared to that from
the SIP. If reasonable agreement occurred, then the "estimated emissions"
which would result after implementation of the SIP in that AQCR was used
to calculate an emissions tolerance. Thus, some credit could be given to
an AQCR which might be restricting emissions more than requined by ambient
air quality standards. For instance, emission controls applied to AQCRs
1(11972 National Emissions Report," EPA - 450/2-74-012, June 1974,
19
-------
other than the example region for the state may reduce emissions well below
"allowables." In the event that no data existed or was available from the
SIP for an AQCR, the current air quality was used to assign emissions toler-
ance based on proportional rollback or rollup. Current air quality was also
the criteria, if emissions data from SIP and NEDS did not appear to be com-
parable (this is often the case).
When no SIP emissions data was available, and current air quality
levels were less than one half of the level represented by an ambient air
quality standard, no "rollup" emissions tolerance was calculated in Tables
A-9 and A-10. 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 r\o_ quantifiable emissions
tolerance, it was felt that no number at all would be preferable to a bad
or misleading number.
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 geograph-
ically dispursed emissions.
A word of caution regarding particulates needs mentioning. Emission
source estimates in the NEDS data bank and most state SIP's are for total
particulates. Generally, the control strategies for particulates are aimed
at total particulates, while the high-volume particulate sampling (SAROAD data)
measures only the finer, suspended fraction. A given level of total particulate
emissions control will therefore not translate into the same level of measured
ambient air quality. Some of the larger oarticulates being controlled will
not remain susoended, and therefore would not be measured by the High-volume
technique. Hence, particulate control plans may have underestimated the amount
of control necessary to achieve ambient air quality standards.
20
-------
ro
NORTHERN
. , MISSOURI
l"^C 'NTRASTATE (137)
METROPOLITAN
KANSAS CITY
INTERSTATE
(XANSAS-
KISSOURI) (094)
SOUTHWEST
MISSOURI
INTRASTATE
(139J
KETROPOLITAN
ST. LOUIS
INTERSTATE
(ILLINOIS-
MISSOURI)
j JM.OISO^ _o.| ^ ^
o' J^/ \*/A /SOUTHEAST
' i ;*° .j^^S^XH-'SOURI
vsco^jC |KTRASTATE
(138)
MISSOURI AQCR's
Figure A-l. Missouri AQCR's
-------
Table A-1.. AQCR Priority Classification and AQi-'Ac
ro
IV)
AQCR 1 Fed. #
Metro
St. Louis
Missouri
Illinois
N. Missouri
S.E.Missour
S.W.Missour
Metro Kansa;
City
Missouri
Kansas
i
070
137
138
139
094
1
b
Part.
1
1
II
III
I
a-
SOX
1
III
III
III
III
c
mx
in
in
in
in
in
Demographic Information
Peculation
1970
1,827,681
642-.450
647,653
451,147
797,565
953,923
460,258
Square
Miles
2713
3758
24182
14486
24502
3117
1094
Population
Density
674
171
27
31
33
306
421
Proposed AQMA Designations01
TSP Counties
Yes
4e
3
None
None
None
None
None
SO Counties
A
No
0
3
None
None
None
None
None
i
0 'Counties
A
Yes
4
3
None
None
None
i
None I
None j
j
Criteria Based on Maximum Measured (or Estimated) Pollution Concentration in Area
Priority
aSulfur oxide:
Annual arithmetic mean . .
bParticulate Matter:
Annual Geometric Mean . . .
cNitrogen 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 NAAWS violations due to growth
Includes St. Louis City
-------
Table A-2. Attainment Dates
ro
OJ
AQCR #
070
i
137
138
139
094
AQCR Name
Metro St. Louis
N. Missouri
S. E. Missouri
S. W. Missouri
Metro Kansas City
Parti culates
Attainment Dates
Primary
7/75
7/75
7/75
a
7/75
Secondary
7/75
7/75
7/75
a
7/75
Sulfur Dioxide
Attainment Dates
Primary
7/75
a
a
a
a
Secondary
7/75
a
a
a
a
Nitrogen Oxides
Attainment Dates
a
a
a
a
a
Already Below Federal Standards
-------
Table A-3. Ambient Air Quality Standards - Missouri (Expressed as M g/rrr5)
Federal
State
Primary
Secondary
St. Louis
Kansas City
All Outstate
AQCRs
Total
Suspended Parti cul ate
Annual
75(G)
60(6)
75(6)
60
60
24-Hr.
260a
150a
200b
150
150
Sulfur Oxides
Annual
80:(A)
40(6)
40
i
24-Hr.
365a
200b
160ib
3-Hr.
3100a
1 Hour
i i ^^ i
933
667
Nit
Dio
IOC
IOC
100(A)
(A) Arithmetic Mean
(6) Geometric Mean
Not to be exceeded more than once per year
Not to be exceeded more than one day in 3 month period
-------
Table A-4. Missouri AQCR Air Quality Status (1973), TSP '
AQCR Name
Metro St. Louis
Missouri
Illinois
N. Missouri
S. E. Missouri
S. W. Missouri
Metro Kansas City
Missouri
Kansas
AQCR #
070
137
138
139
094
i
Stations
Reporting.
28
1
29
9
10
13
19
14
33
G*g/mJ)
TSP Concentration
Highest Reading
Annual
116
109
50
54
77e
128
24-Hr.
-
484
202
323
878
312
440
479
2nd
Highest
Reading
24-Hr
326
172
289
580
179
254
442
# Stations Exceeding
Ambient Air Quality' Standards
Primary
Annual
6
-
6
1
0
_F
le
6
7
24-Hr.
1
0
1
1
2
0
0
4
4
Secondary
Annua'
14
H
1
0
0
le
7
8
%
50
--
50
11
0
0
__
50
24-Hr
10
1
11
2
3
3
12
9
21
%
36
--
36
18
33
23
63
64
63
%
Reduction
Required to
Meet Annual
Secondary
Standard
83a
83
59C
!
%
Reduction
Required to
Meet 2nd
24-Hr.
Standard
54d
13
54
48
i
0
of
i
74
16
e 41
85 66
85 66'
1
rv>
en
Background Missouri 070 & 094 =48.5
Background Illinois 070
= 40
Background AQCR's 137,138,139 = 26
No Background assumed on 24 hour levels
Insufficient data for annual geometric mean in most Missouri States in AQCR 094
Only one station unit sufficient data for geometric mean in AQCR 139
In SAROAD Data Bank, June 1974
2nd Highest 24 hour reading
-------
Table A-5. Missouri AQCR Air Quality Status (1973), S02
ro
cr>
AQCR Name
Metro St. Louis
Missouri
Illinois
N. Missouri
S. E. Missouri
'
S. W. Missouri
Metro Kansas City
Missouri
Kansas
AQCR #
070
137
138
139
094
#
Stations
Reporting
24-Hr.
(Bubbler)
4
0
0
0
4
5
7
12
x. . . a
Stations
Reporting
(Contin.)
8
4
12
0
5
0
2
4
SCL Concentration
M9/m
Highest Readina
Annual
49
--
--
N/A
28
1st
24-Hr.
487
217
26
251
326
2nd
24-Hr.
250
24
129
300
cf
# Stations Exceedino r ---!"cti~r
Ambient Air Quality St^ . Wf^ir~d'
P ri ma ry
Annual
0
-
-
-
0
0
24-Hr.
0
-
-
-
0
0
Secondary I0 --S'c
3_Hr Standard.
N/A -22
N/A
J
-68
0
-45
-22
-22
SAROAD Data Bank, June 1974
Based on 1st High Reading
-------
Table A-5. (Continued) Missouri AQCR Air Quality Status (1973), SO,
_ t . ___... _ i L ______ _ _ ,-i ,--T._.- _ /
AQCR 070 S02 Levels St. Louis Area 1973 (
(1)
ro
MISSOURI SITES (AQCR 070) D^..^,_ .
MONITORING SITE
Linferry & Lindberg
Route 67 & 1-270
55 Hunter Avenue
St. Charles Rock Rd.
215 South 12th
305 Weidman Road
Chain of Rocks
Water Department
River Des Peres
1 Sulfer Avenue
Shreve & 1-70
8227 S. Broadway
ANN. ARITH. MEAN
50
50
45
45
77
35
52
48
55
118
MAX. 3 HR. AUG.
667
613
560
1253
667
773
___
N.A.
MAX. 24 HR. AV.
155
251
211
507
256
227
N.A.
To Annual STD
,
+ 32
ILLINOIS SITES (AQCR 070)
Granite City
Cahokia Downs
316 N. 8th-East
E.St. Louis Fed. Bldg.
Wood River
27
29
72
72
___
1867(373)*
720
(1) Source: Region VII EPA
* 2nd highest 3 hour reading
-------
Table A-6. Fuel Combustion Source Summary
po
00
AQCR Name
Metro St. Louis
(Missouri Only)
North Missouri
South East Missouri
South West Missouri
Metro Kansas City
Missouri
Kansas
AQCR #
070
137
138
139
094
Power Plants
NEDS3
4
4
0
3
9
2
, FPCb
4
1
1
3
10
3
Other Fuel Combustion Point Sourc-'-
Particulate
10
15
1
3
15
3
so2
9
15
1
1
15
3
a) NEDS Data Bank, June 1974
b) Federal power commission listings obtained from EPA data bank
-------
Table A-7. Missouri Emissions Summary, Particulates
ro
VD
AQCR
070 (St. Louis)
Missouri
Illinois
137
138
139
094
Metro Kansas City
Missouri
Kansas
, Total
(10J Tons/Year
44
310
354
64
25.5
53.3
35.7
42.2
77.9
Percent
Fuel Combustion
57
22
32
66
39
40
55
15
34
Electricity Generation
(103 Tons/Year)
4.1 .
43.1
47.5
9.0
0
1.8
16.8
0.625
17.5
%
9.3
14
13.4
14
0
3.4
47
1.5
22:
Point Source
Fuel Combustion
(103 Tons/Year)
5.5
12.2
17.2
4.7
0
.03
1.78
.054
1.8
%
13
3.9
5.0
7.0
.63
.06
5.0
.1
2.3
Area Source
Fuel Combustion
(103 Tons/Year)
15.5
8.4
23.9
28.8
9.9
19.6
1.1
5.8
6.9
%
35
2.7
6.8
45
39
37
3.0
14
8.9
-------
Table A-8. Missouri Emissions Summary, SO-
CO
o
AQCR
070
Missouri
Illinois
137
138
139
094
Missouri
Kansas
^ Total
(10° Tons/Year
514
720
1234
298
40.3
242
176
28.4
204
Percent
Fuel Combustion
72
93
84
83
23
99
94
68
90
Electricity Generation
(103 Tons/Year)
333
607
940
201
0.06
224
156
10.3
166
%
65
84
76
67
.15
93
89
36
81
Point Source
Fuel Combustion
(103 Tons/Year)
18
41
59
20
0
.05
9.1
0.40
9.5
%
3.5
5.6
4.7
6.7
0
0
5.1
1.4.
4.6
Area Source
Fuel Combustion
(103 Tons/Year)
18.5
20.3
38.8
27.5
9.3
15.3
1.0
8.6
9.6
at
/o
3.5
2.7
3.2
9.2
>
23; j
)
i
6.3
0.6
3.0
4.7
-T mJ
-------
Table A-9.Missouri Required Emission Reductions - Particulates
co
SIP
AQCR
070
Missouri
Illinois
137
138
139
094
Missouri
Kansas
AQ
Measurement
Control
Value
Emissions
(103 Tons)
Allowable
Emissions
(103 Tons)
[Air Quality Display type model 1
used to show NAAQS attainment in
Saint Louis 1
AQDM type nodel used to show
NAAQS attainment in Kansas
City, AQCR 094, which serve
as example region for AQCR's
137, 138, 139
197 ;ug/m
[Annual
Geometric
Mean
(1) St. Louis
(2) Allowable
104
7.4
1975
Estimated
Emissions
' After Controls
(103 Tons)
36.8
52.7,
S57F1
N/A
N/A
N/A
N/A
Percent
Reduction NEQS (1972) Allowable Emission
Required ^.^0,,$ Emissions Tolerance
1973SAQ°Data ^ Tons) 0°3 Tons) (io3 Tons)
83 44 7.5
310 52.7,
T54~ . "SSTT B~(2)
48 64 33 0 '*)
74 25.5 6.6 0 '4'
16 53 44 0 -
85 35.7 5.4 0 ^
42.2 6.3
7775" TT7T
sample Air Quality Maintenance Plan Interim Report, July 1974, Prepared for U.S. EPA.
emissions were proportioned between Missouri and Illinois according to existing emissions.
1975 estimated emissions on an AQCR basis are above those allowed according to 1973 NED'S/SAROAD
rollback. The compatability of reference (1) emission inventory and NED'S is not known but the
indication is that no regional tolerance for additional emissions exists.
(3) No estimate of 1975 emission in Kansas City (AQCR 094) was available. The 1973 NED'S inventory
is somewhat lower than the original SIP inventory, suggesting perhaps some progress on controls.
Based on 1973 data and the severity of paniculate violations in Kansas City, zero emissions
tolerance for particulates is assigned for AQCR 094.
(4) AQCR'S 137, 138, and 139 are assigned zero particulate emission tolerance base solely on current
air quality.
-------
Table A-10. Missouri Required Emission Reductions-SOg
oo
ro
SIP
AQCR
070
Missouri
Illinois
137
138
139
094
Missouri
Kansas
AQ
Measurement
Control
Value
Emissions
(103 Tons)
Allowable
Emissions
(103 Tons)
Air Quality Display type
model used to show NAAHS
attainment in St. Louis.
Kansas City was example
region :for AQCR's 137,
138, 139. AQDM typt
model used to demonstrate
that S02 would not ex-
ceed standards in AQCR
094
100
(24
hw*
nr
max)
20
JAG
L ' _
119
435
1975
Estimated
Emissions
After Controls
(103 Tons)
f. 138
1027
N/A
N/A
N/A
N/A
Percent
Reduction
Required
Based On
1973 AQ Data
32
N/A
-68
N/A
-22
NEDS (1972)
Emissions. .
(103 Tons)
514
720
1234
298
40
242
176
28
204
Allowable
Emissions
(103 Tons)
363
509
872
N/A
68
N/A
215
34
249
Emission
Tolerance
(103 Tons)
O2
JL
0
N/A<3>
28
-
6
39
(1) S02 data from "St. Louis Sample Air Quality Maintenance Plan" Interim report, July, 1974.
(2) Table A-6 (continued) shows additional S02 data for St. Louis other than SAROAD. The 32
is based on the highest station in Missouri. The highest station in Illinois shows
annual levels around four percent below standard.
(3) No S02 monitors in AQCR 137 according to SAROAD data.
(4) Very low S02 levels make rollup calculations unrealistic for AQCR 138.
(5) Rollup 1n AQCR 094 is proportional according to existing emissions in Kansas and Missouri.
-------
Table A-ll Fuel Combustion Regulations - Missouri
070 m
St. Louisu;
(State
Regulations)
094 (iy
Kansas Cit/u
(State
Regulations)
(Also Indepen-
dence and
Springfield)
Missouri
(Other AQCRs)
Existing Sources
S02 Particulates
2.3 lbs/106- Btu
( 2000x10° Btu/hr)
Coal must be less
than 2.0% sulfur
for sources less
than 2000x1 O6
Btu/hr (Approx
3.3 Ibs/lQD Btu)
Based on ambient
air criteria, does
not relate direct-
ly to lbs/106 Btu
or perceat sulfur
in fuel (6) '
Ambient air /3\
criteria only * '
Heat Input Allowed(A)
(I) (106 (lbs/106
Bty/hr Btu) '
10 0.60
10,000 0.18
A = 0.89I"V174
6m (AI?
10° Btu/hr lbs/106Btu
10 0.60
10,000 0.12
- 233
A = 1.026 I "J
Same as for Saint
Louis ;
New Sources
S02 Particulates
(2^
Power PI ants v '
Oil-0.8 Ibs S02/106
Btu
Coal -1.2 Ibs SOo/106
Btu
Other sources same
as existing
regulations
Same as Existing
except power
Plants
Same as existing
except power
plants
(2}
Power PI ants v; j
0.1 lbs/106 Btu
Other sources same
as existing
regulations
Same as Existing
except power
plants
!
1
i
I
Same as existing
except power
plants
CO
co
(1) Local regulations are slightly different, State regulations are used for purposes of this report.
(2) FED new sourcesperformance standards, 36 FED. Reg. 24867, Dec. 26, 1971.
(3) SO., concentration in ambient air not to exceed:
3
Concentration (jjg/m ) Averaging Time
667 (0.25PPM) 1 hour
187 (0.07PPM) 24 hour
Applies only beyond premises of emitter.
Maximum Allowable
Once in any 4 days
Once in any 90 days
-------
APPENDIX B
Tables B-l and B-2 are the assessment of AQCRs which should,be examined
for the fuel switching impact on particulate and SCL emissions. They also
provides an identification of those AQCRs which show little potential for
fuel revision or regulation relaxation if ambient air standards are to be
attained.
Those AQCRs designated "good" or "marginal" here will be examined in
later appendices where an attempt will be made to estimate the emissions
\
resulting from an assumed fuel schedule different from the present, or the
emissions which might result if all fuel burning sources emitted up to
their "allowables."
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 Tables B-l and B-2 may later show little
potential for fuel switching after individual sources are examined. Finally
it is posssible 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.
34
-------
Table B-1. Candidacy Assessment for Relaxation of Participates Regulations/Fuel Switch Potential - Missouri
AQCR
070
Missouri
Illinois
137
138
139
094
Missouri
Illinois
Air Quality
ji
IT
on i tors
28
1
29
9
10
13
19
11
33
. 7?
Violations
10
1
11
2
3
3
12
_9
21
Expected
Attainment
Date
7/75
7/75
7/75
7/75
7/75
Total
Emissions
(103 tons)
44
310
354
64
26
53
36
42,
78
Any
Counties
AQMA
Designations?
Yes
No
NO
No
No
% Emission
from Fuel
Combustion .
57
'22.
32
66
39
40
55
15.
34
Tolerance
for
Emissions
Increase
(10° tons)
None
None
None
None
None
Overall
Regional
Evaluation
Poor
Poor
Poor
Poor
'
Poor
CO
en
-------
Table B-2. Candidacy Assessment for Relaxation of S09 Regulations/Fuel Switch Potential
AQCR
070
Missour
Illinoi
Missour
Illinoi
137
138
139
094
Missour
Kanse.s
Air Quality
#
Stations
SAROAD
12
P
16
Others
10
; 4
0
5
4
i 7
li
18
#
Violations
SAROAD
0
0
0
Others
1
1
-
0
0
0
0
0
Expected
Attainment
Date
7/75
7/75
7/75
7/75
7/75
Any
Counties
Proposed
AQMA
Designations?
Ho
No
No
No
No
Total
Emissions
103 tons/yr
514
720
1234
298
40
242
176
28
204
% Emission
From Fuel
Combustion
72
93.
84
83
23
99
94
68
90
Tolerance
for
Emissions
Increase
(103 tons)
Overall
Regional
Evaluation
\
t
0
(a)
28
(a)
6
39.
45
-
Poor
-G'ood
Good
Good
Good
CO
(a) Emission Tolerance is not quantifiable in AQCR's 137 and 139
-------
APPENDIX C
This section is a review of individual power plants by AQCR. The
intent is to illustrate: (1) current SC^ and particulate emissions, (2)
fuel switching possibilities, and (3) allowed emissions for power plants
based on current regulations. The total AQCR emissions resulting from
possible fuel 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 As-
sociation "Steam Tables" listing of power plants and fuel use in 1972, and
(3) NEDS Emissions data.1 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 (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 particulate
emissions (see Table C-3).
Table(s) C-l also lists allowable emissions calculated by applying current
regulations to the given plant, taken from Table A-12. (Particulate limits are
assumed to be based on the entire heat input of the plant. Actual rules may
be different when applied to each of several boilers in a power plant or ap-
plied on the basis of design capacity rather than actual amount of fuel used.)
Total fuels, emissions, and allowables are summed for each AQCR at the
bottom of Table(s) C-l and are shown again in Tables C-2 for comparison after
fuel switch. Plants are switched entirely to coal where possible and to 2.0%
sulfur oil if a plant cannot use coal. The fuel switch calculations are in-
tended to show the magnitude of emissions increase accompanying a fuel switch
without additional controls. The exact emissions would depend upon actual
fuel mix, amount of sulfur in fuels, and degree of emissions controls
accompanying a fuel switch.
]NEDS Data Bank 1974
37
-------
It might be cautioned that AQCR total emissions calculated in the
tables of Appendix C (and also Appendix D) may not agree exactly with total
emissions represented in Appendix A (Tables A-7, A-8). This is a result of
both differing fuel schedules in 1973 compared to previous years and the
relative "completeness11 of the NEDS data bank. Along the same line, AQCR
totals may contain a "mix" of 1972 and 1973 fuel schedules (and resulting
emissions). The intent of the listings is not great precision, but rather
to show approximate status relative to regulations at present, and to show
results of fuel switching where possible.
Table C-4 lists power plants under construction or consideration for the
near to medium term -future. No evaluation of these plants is attempted here
since Federal new source performance standards would apply. It is not the
purpose of this report to evaluate such standards. Inclusion of new plants is
for background information which might have a bearing on other decisions about
emission regulations in an AQCR.
38
-------
Table C-l. Missouri Power Plant Fuel Combustion Point Source Characterization
AQCR
70
70
70
Plant Name
Union Electric
Sioux Station
1100 MW
Union Electric
Ashley Station
70 MW
Union Electric
Meramac Plant
923 MW
Union Electric
Labadie
2417 MW
Total
(1) Coal - 10? T
Fuel Use
Type
% Sulfur
% Ash
Coal
2.78%S
12.9%A
Oil
0.3XS
Oil
2.002SS
Coal
1.47XS
11.7*A
Oil
1.0*5
Gas
Coal
3. 08*5
10. HA
Oil
0.3%S
Coal
Oil
Gas
ons
Annual ']
Quantity
1590
42
;
26460
1624
252
109
4359
2184
7573000
28938
109
011 - 10^ Gallons
Gas - 106 Ft3
Heat
Input
(106 Btu/hr
4050
7
4057
424
424
4458
4
UA
44.74
11132
35
1TI67
19640
429
12.4
20081
Emissions
502 1 Particulates
Existing
tons/y
. 84605
,1
4108
46361
20
<1
256407
51
387373
4179
*1
391552
lbs/10
Btu
4.77
_.
2.21
2.37
1.14
5.26
0.33
4.50
2.22
4.45
Allowable | Existing | Allowable
tons/v
40795
4108
45011
112168
202082
lbs/10
Btu
2.3
2.3
2.3
2.3
2.3
tons/v
103
«1
103
106
106
2470
,1
<1
247C
1429
8.7
4002
115
«1
4117
bs/10? ibs/10(
Btu tons/gf_BJu
0.01 2472
I
0.06 636
0.13 4560
--.
0.03 9556
0.06
0.05
0.06
0.05 17224
0.24
0.36
0.24
0.20
0.20
39
-------
Table C-l. Missouri Power Plant Fuel Combustion Point Source Characterization
AQCR
94
Plsnt flame
Sibley
519 MW
Missouri City
40MW
Ralph Green
50 MW
Pleasant Hill
«
94
94
94
St. Joseph L 8 P
Edmond Street
43 MW
St. Joseph L S P
Lake Roaed
151- MW
,
KCPL Hawthorne
910 MW
KCPL Grand Avenue
127 MW.
KCPL Northeast
133 MW
ndependence
Power S Light
115 MW
TOTALS
TOTAL
(1) Assumed
Fuol Use
Type
2 Sulfur
* Ash
Coal ^'
3.66%S
Oil
2.23JS
CoalO
3.66%S
10JA
Coal
Gas
Oil
1 . 5715
Gas
Coal
3.19XS
10. 0*A
Oil
Gas
Coal
1.6*5
9.7»A
Gas
Coal
3.72XS
10. 4«
Oil
0.3'.S
Gas
Oil
0.3*5
Gas
Coal
3.56%S
13.0*A
Oil
0.59SS
Gas
COAL
OIL
GAS
Annual
Quantity
897000
2310
14100
129
4771
3192
1718
108000
2730
11534
1290000
14245
172000
462
1197
241
1995
78500
205
4859
2559729
9140
40319
Heat
Input
ilG6 Btu/hr
2430
37
36
0.3
549
51
196
257
44.0
1317
3064
1626
487
7.4
136
3.9
228
197
3.2
555
6471
147
4607
11225
Emissions
S02
Existing | Allowable
tons/yr
63024
400
1004
.1
9
<'
389
< 1
6699
308
2
31566
4
12399
11
< 1
6
<]
5427
9
< 1
120128
1123
6
121257
lbs/10
Btu
5.92
2.47
6.37
...
0.02
...
1.74
5.95
1.60
i.Ol
2.35
<.01
5.81
0.34
--
0.35
...
6.29
0.64
...
4.24
1.74
< .01
2.47
_
No
!bs/10e
Btu
.9
No Reg
Participates
Existing . Allowable
tons./"!
71760
9.2
1128
<1
14
12. (
a.;
5956
13.9
28
10028
107
24
bs/106 Ws/106
Btu tons/yr 8tu_
6.74 1704 0.16
0.06 65.9 1 0.43
7.15 232 j 0.27
|
553 I 0.26
.02 i
0.06 303 0.28
0.01 ]
1
5.29 '
0.07 1268 ;0.18
..0.
0.75 2620 0.14
0.02
0.01
2 0.06 634 0.22
9.0 0.02 :
1
33
791
^ 1
2
89687
38.9
194
89920
0.06 313 0.28
0.03
1
0.92
i
0 747 ! 0.21
.01
1
3.2 .
0.06 .
0.01
1.83 8440 I 0.17
j
40
-------
Table C-1. Missouri Power Plant Fuel Combustion Source Characterization
!j Fuel Use
' j
AQCR j! Plant Name j Type
1 I Sulfur
l| % Ash
.1
137 :Jn1vers1ty of Coal
[Missouri Power
Mexico Gas
1 |;19 MW
Annual
Quantl ty
171,000
2039
i ;JFulton Coal j 21000
11.5 MW 1 3*S j
.; 10»A !
' i
(1)
i .Hammbal I Coal
34 MW i 3%S
' i I Gas
i .'Marshall ' Coal1"
: 130.5 MW I 9PIS
i IOTA
! ! i Gas
i 137 fchlllicothe j Coal
,Wunc1p1al Utility -3.7*5
{150 MW 1 9.8M
I
9000
61
8000
913
. 38000
! '; i "' '
i [Central Electric Coal : 69600
Power i 2.70IS |
,,59 MW j 10.7UA
i .Associated Elect. { Coal i 1339000
.'Corporation ' 4.32*5 '
.470 MW ; 14.2%A ',
'Missouri Power i Coal ! 8770
i-Llght 4.0*5 i
.Jefferson City 12.0*A j
: j Gas i 550
; Columbia Water I ' Coal
'Light , 3.6JS
! 10.6*A
if. Gas
hameron ; Coal'"
0 MW 3JS
! i tolA
! South River Gas
.115 MW
il
' TOTALS COAL
1 OIL
i I! GAS
| TOTAL
425,000 '
355
31000
86
2120370
0
4004
Heat
Input
[106 Btu/hr)
449
233
52.7
22.6
7.0
20.1
104
113
Emissions
SOj ("articulates
Existing
jlbs/lc
tons/yr Btu
*
13000 6.61
j
273 1.18
Allowable j Existing
tops/yr
117 1 1.18
104 ; 1.18
2671 5.40
Allowable
ibs/M jibs/101! Jibs/10^
Btu Itons/^r, fltu 'tons/ytj fltu.
i
183 .' 3570 j 4.45 j |
1050
15
384
165
* 1
146
6.8
8.5
1580
. , . ., 1
3014 1112335 8.51 200,
i i
23.0
62.8
1116
42.6
77.8
9.8
5071
0
459
( 5530
667 6.62
29100 . 5.95
i
[
403 1.18
i
162240 7.30
0 i
i
.
162240j 6.70 ;
t . ! ! . _ . _
105
4
3510
567
£ 1
9447
0
25.8
9473
0.53
0.05
1.66
693
120
118
1.66 ! 56.7
1.65
0.01
0.08
338
217
1.97 329
0.15 3335
1.04
0.01
0.72
1.66
0.43
0.01
0.39
235
1462
i
|
164
7068
0.35
0.40
0.51 |
0.57
0.44
!
0.45
0.41
i
0.25
0.47 I
0.30
0.48
0.60
0.29
(1) Coal - Tons
(2) 011 - 103 gallons
(3) Gas - 106 ft3
(4) Assumed for those plants not listed
1n NEDS, no partlculate control assumed.
41
-------
o>
n>
o
i
ro
-
AQCR
138 '
!
1
139
1
]
i
Plant Name
Federated
j Electric Corp.
Empire District
Electric Company
Springfield
Utilities
253 MM
KCPEL Montrose
Plant
213 MW
TOTAL
TOTAL
Fuel Use
Type
% Sulfur
% Ash
Coal
3.«S
10.0SA
Coal
5.233SS
27.33SA
Coal
3.45*S
13.62SA
Gas
Coal
COAL
GAS
Annual
Quantity
4,160,000
660,000
105,000
8588
1,697,000
2,462,000
8588
Heat
'Input
.(100 Btu/hr)
9498
1508
300
981
5036
6844
981
7825
i
i
Emissions
S02 Parti culates
Existing j Allowable j Existing j Allowable
jibs/106 W/IO5, 1bs/106 WlO^
tons/yr; Btu itons/yr Btu tons/yr Btu itons/yr. Btu j
283000
65570
8185
<1
200016
273771
O
273772
6.8
9.93
6.23
.01
9.07
8.0
4,170
361
1229
6.1
1319
2909
6.1
2915
0.10
... -
0.05
0.94
^.01
0.06
0.09
1
i
8757 ;0.21
i
1
2094 j 0.29
1 J
1 i
i !
1512 '; 0.29
t
j
! i
:
5079 j 0.23 i
^ >
i
!
8685 i 0.25
VI
to
o
c
-s
i
n>
ft)
O
O
cr
c
to
o
o »
oo
o
c.
-$
o
o>
O)
o
r+
n>
-5
N'
O)
-------
Table C-2. AQCR Emissions Comparison with Fuel Switch (Power Plants Only)
AQCR _70
Fuel
Coal
on
Gas
Present Use
Quantity 1 ' ) ,109 Btu
7573 172046
689 3758
109 109
175913
Gas 8 011 to Coal
Quantity 1Q9 Btu
7593 172502
625 3411
0 0
175913
Gas to Oil Only
Quantity 109 Btu
AQCR 94
soz
Particulate
Emissions (Tons /Y)
391552
4117
, Emissions (Tons/Y)
392193
4116
Emissions (Tons/Y)
Allowable
erosions (3)
202082
17224
so2
Partlculatf
Lbs/106 Btu
4.45
0.05
lbs/106 Btu
4.46
0.05
Lbs/106 Btu
2.3
0.2
Fuel
COAL
OIL
GAS
Present Use
Quantity 10s Btu
2559.7 56686
218 1288
40319 40357
98331
Gas & Oil to Coal
Quantity )Q9 Btu
4236 93810
1 36 806*
3712 3715*
98331
Gas to Oil Only
Quantity 109 Btu
2559.7 56686
3823 22592
19035 19053
98331
,S°2
Paniculate
Emissions (Tons /Y)
121257
89920
Emissions (Tons/Y)
199475
148462
Emissions (Tons/Y)
139825
90461
Al lowable
Emissions (3)
NO REG.
8440
so2
Particular
(1)
Lbs/106 BTU
2.47
1.83
4.06
3.20
2.84
1.84
Lbs/106 BTU
NO REG.
0.17
* No switching indicated because there are some plants with no coal burning capabilities.
Coal - 10, tons
011 - lOf BBLS
Gas - 10° ft3
43
-------
Table C-2. AQCR Emissions Comparison with Fuel Switch (Power Plants Only)
AQCR 137
Fuel
COAL
GAS
so2
Paniculate
so2
Particular
Present Use
Quantity ICr Btu
2120.4 44422
4004 4021
Emissions (Tons /Y)
162240
9473
Lbs/106 BTU
6.70
0.39
Gas & Oil to Coal
Quantity 1Q9 Btu
2210 46309
2126 2134
48443
Emissions (Tons/Y)
169132
9862
6.98
0.41
V. ..-.Me
:.:-.;-:-..-o (3)
NO REG.
7068
Lbs/106 BTU
0.29
AQCR 138
Fuel
COAL
so2
Participate
so2
Particular
Present Use
Quantity 10a Btu
4160 83202
83202
Emissions (Tons /Y)
283,000
4,170
Lbs/106 Btu
6.8
0.10
Gas & Oil to Coal
Quantity ,09 Btu
Emissions (Tons/Y)
.. I^-^MJ)
NO REG.
8757
Lbs/106 Btu
NO REG.
0.21
AQCR 139
Fuel
COAL
GAS
SO,
Particulate
so2
Particular
Present Use
Quantity 109 Btu
2462 59953
8588 8594
68547
Emissions (Tons /Y)
273772
2915
Lbs/106 Btu
8.0
0.09
Gas 1 Oil to Coal
Quantity 1Q9 BUj
2815 68547
0 0
68547
Emissions (Tons/Y)
313013
3326
9.13
0.10
.V,iv.::bie
i.J:*-;w (3)
NO REG.
8685
Lbs/106 Btu
NO REG.
0.25
44
-------
Table C-3. AP-42 Power Generation Emission Factors
->
tn
Fuel
Coal(1)(Bit.)
General 7
Wetbottom ViO% A
Cyclone J
1% S
2% S
3% S
Oi1<2>.
0.5% S ' :
1.0% S
2.0% S
Gas<3>
(.3 Ibs S/
105 Ft3)
Parti culates
Lbs/Ton Lbs/10D Btu
160 7.4
130 7.0
20 0.9
Same Same
as as
Above Above
l.b/103 Gal
8 0.058
8 .058
8 .058
Lb/106Ft3
15 .015 ?
S02 6
Lbs/Ton Lbs/10° Btu
38 . K65
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/10D Btu
0.3 0.013
0.3 0.013
Lb/103 Gal
2 .014
2 .014
2 .014
Lb/106Ft3
1 . 001
NOX (as N02) .
Lbs/Ton Lbs/10° Btu
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 10& Btu/Ton
(2) Oil 140 x 103 Btu/Gal
(3) Gas 1000 Btu/Ft3
-------
Table C-4. Missouri Proposed Power Plant Characterization
\QCR
138
070
139
"
Plant Name
New Madrid
#1
#2
(.600MW)
Rush Island
#1
#2
(55.5MW)
Southwest
(Springfield)
194MW
Fuel Use
Type Annual Heat
% Sulfur Quantity Input
% Ash 103 Tons (l06Btu/hr)
Coal 1942^ . 6000
Coal 1797^ 5550
Coal 628^ 1940'
LMlbblUNS
bU2 Particulates
Existing
tons/yr lbs/106Btu
Unknown
Unknown
Unknown
Estimated
Allowable
tons/yr lbs/10uBti
31500 1.2
29000 1.2
10200 1.2
I
Existing
Estimated
Allowable
tons/yr lbs/10°Btu
2630 0.10
2430 0.10
850 0.10
en
* ' Estimated from MW rating @ 85% capacity, 30% generating efficiency, and 23 X 106 Btu/Ton for coal
-------
APPENDIX D
The Tables D-l in this appendix list individual industrial/commercial/
institutional sources of particulates and SC^ emissions which might show
fuel switching potential. The sources are from a NEDS rank order emissions
listing. Tables D-l account for at least 95% of a total emissions (both
fuel and non-fuel sources) in the AQCR, since not all industrial sources
could be listed in this report. It should be cautioned that the percent
emissions accounted for is different than the "% of fuel use accounted for."
It is possible that several potential fuel switch sources could be over-
looked by the cutoff point on the emissions (i.e., a reasonable sized
natural gas used may emit below our cutoff point in the NEDS rank order
list).
Fuel switch emissions calculations were not made for industrial sources,
since no information was available for feasibility of any fuel switching.
Current fuels and emissions are listed along with the emissions which would
be allowed by existing regulations.
47
-------
Table D-l. Missouri Industrial-Commercial Fuel Combustion Point Source
Characterization
\l
AQCR. | Plant Name
ll
ii
70 I V. A. Hospital
i ii
j!
Fuel Use
Type
* Sulfur
I Ash
011
1.91S
Gas
Annual <"
Quantity
154
34
|| Chrysler Assembly Gas 800,
j :; Emerson Electric Gas
L
1
i! Me Donald Douglas; Oil i 10
0.3*5 j
Gas i 766
i i
! > *
1 . National Lead
' Titanium
i
70 j. Anheuser Busch
; ii
jj
QUAD Chassis
Side
Coal
1 3.3*S
| 9.6*A
Oil
1 0.7*S
Gas
Gas<*>
Coal
3.6*S
10.6JA
Oil
1 .90JS
Gas
Coal
2.92*S
10.2*A
Gas
_ Gas
j Mousanto
70 i Washington
University
ij
ll
|j P.P.G. Glass
j
t
jj U. S. Steel
| TOTAL
i
1 TOTAL
Coal
2.8*S
8.2JA
Gas
_
Coal
3.25*S
9.7JA
Gas
Coal
3.0*S
10.0*A
Gas
011
2.0*5
Gas
COAL
OIL
GAS
\ 99780
3081
1374
580
31230
93
2388
26050
996
Heat
Input
(106 Btu/hr
2.7
4.0
TJ
Emissions
S02
Existing
tons/yr
r=J£,
23
-1
jibs/10
LSSL.
1.94
91.3 '1
24.7
-1
...
0.16 -1 j
91.8 «1
92.0
; j
251
53.5
165
33.1
503
78.4
1.49
-221
353
68.4
119
T87
1250 143
1
138760
486
7510
440
18.800
109
1216
642
322130
4554
10081
T
364
419
19.7
52.7
72.4
47.2
13.1
60.3
20.7
75.1
829
78.6
1141
6250
170
2)39
14
'1
1445
-1
-1
7378
-1
463
-1
1070
1
190
-1
18745
397
5.68
0.73
6.23
2.15
4.82
...
4.63
5.37
5.18
2.10
5.16
1.15
""" !
r^=
tons/vr
NO
NO
NO
NO
7263<2
5100(2
2703^
NO
6056
1046
867
NO
«ble
lbs/10*
Btu
!EG.
IEG.
Participates
Ext
tons/*
2
-1
7
Sting
lbs/10
Btu
0.17
Allowable
lbs/106
6
0.60
0. 02 ! 1.58 0.45
!EG. '1 ; ; 54 .5
!EG.
3.3
3.3
3.3
REG.
3.3
3.3
3.3
EG.
3.3
2049 119142 2.13 (23035 >*.
-1
7
650
2
-1
-1
245
1
21
28
-1
12
4187
5
355
3
18.8
-1
14
6
8660
19
61
161 0.46
0.02 |
1
0.59
0.01
0.71
0.15
0.02
456
519
0.35
i
0.37
0.09 128 0.41
i
i
0.02 258 i 0.43
i
2.63
0.02
4.11
0.01
0.91
663
185
103
0.15; 181
0.02|
2139
0.06
0.02
0.36
0.48
0.50
0.16
8740 i 0.97 2820 ! 0.31
(1) Coal - tons
011 - lOf gallons
Gas - 106 ft3
(2) Assumes all coal used.
(*) Coke gas prod. 500 Btu/SCF
48
-------
Table D-l. Missouri Industrial-Commercial Fue1 Combustion Point Source
Characterization
. AQCR
94
i
94
i ;
|
j
! i
1
5
I
I
i
1
1
Plant Mane
AM Oil
!
American Paving
ARMCO Steel
Bench x Plant
AEC
KCPL
Richards Gebaur
AFB
CPC Internationa]
1
TOTALS
1
i
Fuel Use
Type
*"Sul"fur.
t Ash \
Oil
2.49*5
Gas
Gas *
1.75*5
Gas *
Gas
011
1.5*S
Gas
011
2.0*S
Gas
Oil
2.49XS
Gas
Gas *
1.75*5
011
1.25SS
Gas
011
1.5*S
Gas
COAL j
OIL
GAS
Annual ' '
Quantity
52600
3004
1110
5449
102
'
1610
11
1360
2281
15300
876
325
1818
155
1050
2710
0
73859
16025
Heat
Input
(106 Btu/hr)
901
343
342
653
11.6
Emissions
SO 2 | Part1culates|
Existing i Allowable j Existing
tons/yr
3115
-1
279
'I
25.4 189
f
1.3 -1
lbs/10
Btu
0.79
0.19
I
1.70
23.3 214 2.10
1
260 i -1
262
105
100
30.1
17.7
1
18.1
309
0
1262
2133
TOTAL j j | 3395
3000
270
159
-1
2550
17
0
9235
566
2.61
0.62
1.21
32.3*
0.01
0
1.67
0.06
9801 i 0.66
j.
tons/y
NO R
lbi/106j dbs/106
Btu j-tons/yrl. Btu"
i
LG.
i
1
488
26
9
1
0.12
0.02
0.01
. Allowable
fibs/10*
tons/yr] Btu j
j
1002
1
-1 i
I
18
Nd
i
REG.
16
21
176
8
2
12
1
270
544
0
980
611
0.16
0.16
0.02
0.15
0.02
.00!
0.09
0.01
3.4
0.40
0.18
0.07
j 1591 0.11
1 !
- 1
0.16
i
j
0.56
51.8 0.46
j i
i
311
473
0.27
0.24
I
93.3 j 0.40
374.2 j 0.26 j
i
2305
J 1
!
1) Coal - tons
2) Oil - 1000 gallons
3) Gas - 10« ft3
* Process Gas
49
-------
Table D-l. Missouri Industrial-Commercial Fuel Combustion Point Source
Characteristization
1
i
AQCR 1 Plant Name
i
137 ' Central Electric
!
1 !!
!i Hercules Inc.
i 1
[ TOTALS
i
1
1.
j TOTAL
i
138 Lapierre-Sawyer
' '. AMAX Lead Co.
1
| TOTAL
139 i Springday Co.
!
{j Smith Flooring
i! Atlas Powder
:j Company
J
i.
1
1
I
t TOTAL
f
j
Fuel Use
Type
t Sulfur
1 Ash
Coal
2.70*5
10.7*A
Coal
1.7*S
7.1*A
Gas
COAL
OIL
GAS
i=--=~.~1-"~'
Coal
3*S*
10*A*
Annual
Quantity
(1)
188000
174900
24874
362900
0
24874
" =-=---
11,300
Coal 3000
1 .0*5 ; '
6.0SA j
COAL
Oil
2.3*5
Gas
Wood
Oil
0.4*5
Gas
Oil
0.1*5
Gas
OIL
GAS
11,600
250
363
1200 Ton
6
331C
60
192
316
3893
I TOTAL
Heat
Input
(106 Btu/hr)
494
459
2981
953
0
2981
3934
_= ^_
28.4
7.88
36.3
4.3
41.4
0.10
387
0.99
21.9
5.4
453
458.4
Emissions
S02
Existing | Allowable
tons/yr
9640
4700
5640
14340
0
5640
lbs/10
Btu
4.46
2.34
0.43
3.44
o
0.43
19980 1.16
:
8
57
65
45
1
-1
-1
1
-1
45
0.06
1.65
0.41
2.39
1.9
>
tons/yr
NO
Particulates
Existing
jlbs/106, jibs/10
Btu [tontMi Btu
r~
(EG.
i
I
NO
...
REG.
t
i
1
i
NO
45 j 0.02 ;!
REG.
402
1967
2367
2369
0
2367
4736
,55
"
155
3
3
16
27
1
2
3 !
48
51
1
II i i
0.19
0.98
0.18
0.57
0
0.18
0.27
1.25
Allowable
\ lbs/106
tons/yr'. ;Bt.uJ
741 0.35
1 i
3789 0.25 j
'
:
i
4530 0.26 |
; I.
70.7 ! 0.57
: !
1
..j ... j 0.71
1.25| 70.7 0.44 j
i i
0.16
0.02
0.02
0.02
0..13
0.02
88.5 0.53
;
486 0.36
59.0 0.59
1
i
0.03 634 0.32 j
;
I
(1) Coal - tons
011 - 1000 gallons
Gas - 106 ft3
50
-------
Table D-2. Major Industrial Fuel and Emissions Summary _ Missouri
AOfR
70
94
137
138
139
STATE
F
Coal
Tons
322.1
0
362.9
11.6
0
707
uel Acounted
103 Gal.
Oil
108
1759
0
0
7.5
1875
For
106 ft3
Gas
10081
16025
24874
0
3893
54873
S
Existing
Emissions
(Tons)
19142
9801
19980
65
45
°2
Al lowed
Emissions
(Tons)
23035
No Reg
No Reg
No Reg
No Reg
Pa
Existing
(Tons)
8740
1591
4736
155
51
»
1
!
Particulates
Allowed
(Tons)
2820
2305
4530
70.7
634
-------
APPENDIX E
Table E-l shows area source fuel use for the State of Missouri by AQCR.
The approximate energy values are compared for each fuel along with the per-
cent of overall energy derived from each fuel. Data are those in NEDS as of
November 1, 1974. State area source totals are calculated and the percent of
energy derived from each fuel shown.
Area source fuel use is then compared to total fuel use in Missouri. The
bottom row entitled "all fuels, all sources" may not match totals from Appendices
A, C, and D exactly, since neither the NEDS or individual appendix totals are
all-inclusive.
A Table E-2 shows area source fuel use and SOp and particulate emissions
in St. Louis (AQCR 070). Also indicated are S02 emissions when the 2% sulfur
in coal regulation is met.
52
-------
Table E-l. Missouri Area Source Fuel Use
en
GO
L_
AQCR
Missouri
070
Missouri
Illinois
TOTAL
094 \
Missouri j
| Kansas j
TOTAL
j Coal
j Tons
220820
139760
360580
i
i
2280
74470
76750
137 i 405310
t
138 ! 158530
139 !
i
AREA SOURCE
! AQCR TOTAL
102470
109 Btu
5079
3214
8293
52
1713
1765
9322
3646
2357
i
Oil
| 103 bbl
2519
2436
4955
453
283
736
1587
850
1654
i !
1,103,640
i
PERCENT
STATE TOTAL j
i (Missouri Only) jj 889,580
||
i
1
|
25,383 i 9782
!
5.1%
20,460
7044
lO9 Btu
14812
14324
29135
2664
1664
43.28
9332
4998
9726
Gas
103 ft3
113570
39440
153010
68500
40790
109290
54220
33130
73300
"
57519
11.5%
41419
422,950
354,530
TO9 Btu
113570
39440 '
153010
68500
40790
109290
54220
33130
73300
422,950
84.3%
345,530
s
i
Tote!
1012 Btu
i
!
190.4
71.2
44.2
115.4
72.9
41.8 |
85.4
i
501.6 !
1
100%
I
1
i
1
-------
Table E-2. AQCR 070 Area Source Fuel Use - Missouri Portion (St. Louis)
en
Current
Coal Used
2.8%S
(Coal AT
regulation
(2.0*5)
OIL
GAS
WOOD
TOTALS (Current)
FUEL
Amount
221
XI O6 tons
221X106tons
106X106gal
114X109Ft3
9800 Tons
109 BTU
5080
5080
14800
114000
113
133993
APPROXIMATE EMISSIONS
SOo
tons/Yr
12400
8860
7000
1980
Karticu lates
tons/Yr
18000
18000
500
850
N/A.
21180
-------
APPENDIX F
The Tables F-l and F-2 illustrates the effect on emissions of participates
and SCL when power plant and industrial fuel burning sources listed in Appendices
C and D are allowed to emit up to the amounts that existing regulations would
allow. It is assumed that heat input remains the same, and existing regulations
are applied to gross heat input for each power plant and industrial source. The
column in Table F-l labeled "Allowable Total Emissions" is the tonnage from
Tables A-9 and A-10 which the region can tolerate while still not violating
ambient air quality standards. In Table F-2 (SCL Evaluation) the analogous column
indicates the ratior.of emissions resulting when all sources are emitting at
regulations to emissions at present.
Area fuel burning sources are assumed to remain unchanged, except in AQCR
070 since S02 and particulate regulations generally do not apply to these sources
outside St. Louis. Non-fuel emission estimates from Tables A-7 and A-8 are
included in the balance. Since the degree of control which will be achieved on
non-fuel particulate sources was not known for this report, the particulate totals
serve mainly to show magnitudes relative to tonnage allowed by air quality con-
siderations. For SOp the non-fuel estimate would, in many AQCR's, remain about
the same due to lack of other SOp regulations (except for smelters). Thus the S02
"ratio" is not too far from that which would be possible under existent regulations.
A regional approach is implicitly assumed to have some validity in this
exercise, so that any conclusions from the numbers in Tables F-l and F-2 will
have to be temperated for AQCR's with widely dispersed emissions.
Lastly, it is emphasized that these tables are hypothetical in that no fuel
mix may exist to allow all sources to emit exactly at regulation levels. The
calculations do give some insight into adequacy of existing regulations for allowing
air quality standards to be achieved if a fuel schedule different from the one at
present were in effect.
A Table F-3 is included in this appendix to summarize gross consumption and
production of fossil fuels in Missouri.
55
-------
Table F-l. Missouri Particulate Regulation Evaluation
i AQCR
i
70
(Missouri Only)
Power Plants.
Industry
Area Sources
Non-Fuel *
Total
I
137
1012 Btu
_.
176
17.9
190
-
. .
Current Emissions
Tons/yr
4117
8740
21180
34037
18300
52337
Regulations
lbs/106 Btu
.20-. 36
.35-. 60
N/A
Emissions
with All Sources
Emitting at Reg's
17224
2820
21180*
41224
18300 Uncontrolled
59524
. Estimate Allowable
Emissions in AQCR
tons/yr j
Missouri - 7500
Total AQCR - 60,000
>
Power Plants 48.4 j 9473
Industry
Area Sources
Non-Fuel
34.5
73
!
i
i Total
138
Power Plants
Industry
Area Sources
83.2
0.3
42
i " ~ ' i '
Non-Fuel
.
Total
4736
28800
43009
21800
64809
.25-. 57
.25-. 35
7068
4530
28800
i 40398
I
4170
155
9900
.21
.57-. 71
21800 Uncontrolled
62198
8757
71
9900
14225 _j j 18728
15600
29825
j 15600
34328
i
jj
"
33000
- ;
i
6600
-------
Table F-l. Missouri Participate Reaulation Evaluation
en
i
i j
AQCR TO12 Btu
i . ?
S
139
Power Plants 68. 5
Industry 4.0
i Ares Sources 85
i
i - - i
(Ion-Fuel !
Total
i
94 |
(Missouri Only) 1
Pov'er Plants 98.3
Industry 29.7
Araa Sources 71
!
;ior>-Fiiel i
Total
j
09.4
(Kansas Only)
Fewer Plants 23.8
Industry 1.95
Area Seurces 44
/ ^;~-;- ;:'''
.
Total .
[ Current Emissions
Tons/yr
| '
2915
51
19600
22566
32000
.
54566
89920
1591
1100
92bll
16100
108711
800
51
5800
6651
scQnn
ooyuu i
B
24,551
\
t
i
| Regulations
j lbs/106 Btu
.23-. 29
.36-. 84
!
'
.14-. 43
.16-0.60
N.A
0.2
. 2-. 5
N/A
!
Emissions
with All Sources
Emitting at Reg's
8685
634
19600
28919
32000
60919
8440
2305
1100
11855
16100 Uncontrolled
27955
2455
390
5800
8645
o cnnn
obyOO
i
44,545 !
.!
j Estimate Allcv/cib.Ta
Emissions in AQCR
tcns/yr
' !
:
44000
i
I
}
1
I
i
I
i
i
'
i
.5400 j
i
*
j
t
?.
1
1
^
i
6300
-------
Table F-2. Missouri S02 Regulation Evaluation
en
oo
<"" ^JM.^
;
j
AQCR
70
(Missouri Only)
Power Plants
Industry
Area Sources
Non-Fuel
Total Missouri
Total AQCR
137
Power Plants
Industry
| Area Sources
Non-Fuel
,
Total
i
138
Pov/er Plants
Industry
Area Sources
! i
f< on -Fuel
Total
i
1012 Btu
176
17.9
190;
0
48.4
34.5
73
83.2
0.3
42
Current
Emissions
tons/year
391552
19142
19800
430494
144000
574494
162240
19980
27500
209720
50700
260420
, ,
283000
65
9300
292365
31000
323365
1 Reg's
lbs/106
Btu
2.3
3.3
3.3
'
..... .....
r
Emissions
with All Sources
Emitting at Reg's
202082
12376
16000
230458
144000
364458
NO REG.
.
NO REG. '
Estimated Allcv/eble
Emissions for
AQCR
(Missouri Only)
363,000
872,000
N/A
68,000
Ratio of Em'ssions at
Regulations to Current
Emissions
j
;
1
0.63 |
i
I
i
j
*
j
?
(
j
I
i
. i
i
i
t
i
-------
Table F-2. Missouri S02 Regulation Evaluation
en
vo
AQCR
139
Power Plants
Industry
Area Sources
'ion-Fuel
, -0_.
Total
94
Missouri Only
Power Plants
Industry
Art- a Sources
.
.
i;on -Fuel
Total
094
(Kansas Only)
Power Plants
Industry
Area Sources
N on -Fuel
Total
I
1012 Btu
68.5
4.0
85
98.3
29.7
71
23.8
1.95
44
Current
Emissions
tons /year
273772
45
15300
289117
2400
291517
121257
9801
1000
132058
10600
142658
13578
384
8600
22562
9090
31*652
Reg's
lbs/106
Btu
3.0
I
1
Emissions
with All Sources
Emitting at Reg's
NO REG.
NO REG.
35648
3200
8600
47448
9090
56538 |
Estimated Allowable
Emissions for
AQCR
N/A
215,000
34000
' ' ' ' !
Ratio of Emissions at
Regulations to Current
Emissions
i
1
1
i
,
i
i
i
i
0.91
-------
Table F-3. Missouri Fossil Fuel Summary
FUEL
PRODUCTION
CONSUMPTION
Coal
4.55 X 10U Tons
15.24 X 10" Tons
Oil
0.06 X 10U BBL
109. 7 X 106 BBL
Gas
.009 X 109 Ft3
433 X 109 Ft3
-------
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) (a) "State of Missouri, Kansas City and Out-state Air Quality Control
Regions Implementation Plan."
(b) "Implementation Plan for the Missouri Portion of the St. Louis
Interstate Air Quality Control Region."
(12) Missouri Air Conservation Commission, Jefferson City, Missouri,
(a) "Regulation S-X, Restriction of Emission of Sulfur Compounds,"
(b) "Regulation S-VI Maximum Allowable Emissions of Particulate Matter
from Fuel Burning Equipment Used for Indirect Heating," adopted
February 24, 1971.
(13) "St. Louis Sample Air Quality Maintenance Plan Development," Interim
Report, July 1974, prepared for U.S. EPA under contract #68-02-1388.
(14) Davis, D. D. et al, "Trace Gas Analysis of Power Plant Plumes via Air-
craft Measurement," Science, Vol. 186, No. 4165, p. 733-6, November 22,
1974.
61
-------
TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1. REPORT NO.
EPA-450/3-75-023
3. RECIPIENT'S XCCESSION-NO.
4. TITLE AND SUBTITLE
IMPLEMENTATION PLAN REVIEW FOR MISSOURI AS REQUIRED
BY THE ENERGY SUPPLY AND ENVIRONMENTAL COORDINATION
ACT.
5. REPORT DATE
February 1975
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
U. S. Environmental Protection Agency, Office of Air
Quality Planning and Standards, Research TriangJe
Park, N.C., Regional Office VII, 1735 Baltimore Ave.
Kansas City, Mo and TRW, Inc. Redondo Bch, Calif.
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
68-02-1385
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 Tn'annlp Park. North r.arnlina ?7711
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.IDENTIFIERS/OPEN ENDED TERMS C. COSATI Field/Group
18. DISTRIBUTION STATEMENT
Release Unlimited
19. SECURITY CLASS (ThisReport)
Unclassified
21. NO. OF PAGES
61
20. SECURITY CLASS (Thispage)
Unclassified
22. PRICE
EPA Form 2220-1 (9-73)
62
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