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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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. ------- 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 ------- 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. ------- 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. ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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. ------- 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 ------- |