EPA-450/3-75-024
February 1975
IMPLEMENTATION PLAN REVIEW
FOR
LOUISIANA
AS REQUIRED
BY
THE ENERGY SUPPLY
AND
ENVIRONMENTAI COORDINATION ACT
U. S. ENVIRONMENTAL PROTECTION AGENCY
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EPA-450/3-75-024
EPA U:.;, r
RTPNC 27711
IMPLEMENTATION PLAN REVIEW
FOR
LOUISIANA
REQUIRED BY THE ENERGY SUPPLY AND ENVIRONMENTAL COORDINATION ACT
PREPARED BY THE FOLLOWING TASK FORCE:
U. S. Environmental Protection Agency, Region VI
1600 Patterson - Suite 1100
Dallas, Texas 75201
Environmental Services of TRW, Inc.
(Contract 68-02-1385)
U. S. Environmental Protection Agency
Office of Air and Waste Management
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
February 1975
i
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TABLE OF CONTENTS
LOUISIANA
1.0 .EXECUTIVE SUMMARY ......................... 1
2.0 REVIEW OF THE STATE IMPLEMENTATION PLAN AND CURRENT AIR QUALITY
2.1 Summary ............. . ............ 7
2.2 Air Quality Setting for the State of Louisiana ..... . . 10
2.3 Background on the Development of the Current State
Implementation Plan .................... 13
2.4 Special Considerations for the State of Louisiana ..... 15
3.0 AQCR ASSESSMENTS .
3.1 Regional Air Quality .......... .......... 18
3.2 Statewide Fuel Use . . .-, ................. 20
3.3 Power Plant Assessment ................... 21
3.4 Industrial/Commercial/Institutional Source Assessment ... 22
3.5 Area Source Assessments .................. 23
4.0 TECHNICAL APPENDICES
APPENDIX A ......... ...... . ...... ..... A-l
APPENDIX B ..... ...................... B-l
APPENDIX C ....... .................... C-l
APPENDIX D ........................... D-l
BIBLIOGRAPHY
iii
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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
SO,, emission regulations. The States have also been asked to discourage
larcfe scale shifts from coal to oil where this could be done without
jeopardizing the attainment and maintenance of the NAAQS.
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To date, EPA's fuels policy has addressed only those States with the
largest clean fuels saving potential. Several of these States have or are
currently in the process of revising SCL 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 aVI_ 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 pjr 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
AQCRs of the State if the control regulations were applied to similar
sources. The problem with the use of an example region is that it can 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 one percent sulfur oil to be
burned state-wide where the use of three percent sulfur coal would be
adequate to attain NAAQS in some locations.
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EPA anticipates that a number of States will use the review findings
to assist them in making the decision whether or not to revise portions of
their State Implementation Plans. However, it is most important for those
States which desire to submit a revised plan to recognize the review's
limitations. The findings of this report are by no_means conclusive and
are neither intended nor adequate to be the sole basis for SIP revisions;
they do, however, represent EPA's best judigment 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
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
A
air pollution problems such as sulfates
Although the enclosed analysis has attempted to address the attainment of
all the NAAQS, most of the review has focused on total suspended particulate
matter (TSP) and sulfur dioxide (SCL) emissions. This is because stationary
fuel combustion sources constitute the greatest source of SOg emission and are
a major source of TSP emissions.
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Part of each State's review was organizaed to provide an analysis of
the S02 and TSP emission tolerances within each of the various AQCRs. The
regional emission tolerance estimate is, in many cases, EPA's only measure
of the "over-cleaning" accomplished by a SIP. The tolerance assessments
have been combined in Appendix B with other regional air quality "indicators"
in an attempt to provide an evaluation of a region's candidacy for changing
emission limitation regulations. In conjunction with the regional analysis,
a summary of the State's fuel combustion sources (power plants and indus-
trial sources) has been carried out in Appendix C and D.
The State Implementation Plan Review has addressed the emissions from
fuel combustion sources in each of Louisiana's three AQCRs. For your
convenience, a map showing Louisiana and its AQCRs is shown. The major
findings are as follows:
t As required by Section IV of ESECA, the Implementation Plan
for the State of Louisiana has been reviewed with particular
attention to the most frequent causes of overly restrictive
emission limiting regulations. Even though the Example
Region approach was used in the development of the control
strategy, the regulation applicable to particulate emissions
does not appear to be overly restrictive. Furthermore,
there is evidence that substantial increases in particul ate
emissions could occur without relaxation of the existing
regulations. NAAQS violations for TSP occur in each of the
Louisiana AQCRs. In addition, the Shreveport area has been .
proposed as an AQMA. Also, with the exception of one source,
all of the State's stationary fuel burning facilities are
operating well within the emission limits established by the
Louisiana particulate regulation.
t Based on 1973 air quality data, this review finds that S02
concentrations are below NAAQS. However, a determination
that the current regulation for S02 is overly restrictive is
beyond the scope of this review. The manner in which
Louisiana regulates S02 is not directly related to the sulfur
content of fuel. Instead, the S02 regulation specifies a
maximum concentration to be observed beyond the premises
where this source is located and/or in the stream to be dis-
charged from the facility. It is not possible, therefore, to
determine whether currently low ambient S02 levels are due
to an overly restrictive regulation which could limit the use
of certain fuels, or to an otherwise low level of SO?
emissions. Also, EPA cannot help but suspect that the wide
use of natural gas throughout Louisiana is not caused by the
S02 regulation* but by the availability of natural gas.
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Natural gas is the major fuel used for the State's
stationary fuel combustion sources, and accounts for
93% of all heat input to these types of facilities.
Oil contributes 5%, while wood waste and other waste
products provide the remaining 2%. Coal is not used
as a fuel for any of these facilities.
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SHREVEPORT
TEXARKANA-
TYLER
INTERSTATE
(ARKANSAS-
LOUIS I ANA-
OKLAHOMA-
TEXASJV
MONROE-
EL DORADO
INTERSTATE
(LOUISIANA-
ARKANSAS)
SOUTHERN
LOUISIANA-
SOUTHEAST
TEXAS
INTERSTATE
Figure A-l. Air Quality Control Regions in Louisiana
Region I
019
022
106
Region Name
Monroe-El Dorado Interstate
Shreveport-Texarkana-Tyler Interstate
"Southern Louisiana-Southeast Texas Interstate
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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?
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 no. proposed Air Quality Maintenance Areas?
Are there indications of a sufficient number of monitoring sites
within a region?
Is there an expected 1975 attainment date for NAAQS?
f 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?
Is the fraction of total emissions from stationary fuel combustion
sources higher than those of other sources?
Do modeling results for specific fuel combustion sources show a
potential for a regulation revision?
t Must emission regulations be revised to accomplish significant
fuel switching?
Based on the above indicators, what is the potential for revising
fuel combustion source emission limiting?
Is there a significant clean fuels savings potential in the
region?
This report is directed at answering these questions. An AQCR's potential
for revising regulations increases when there are affirmative responses to the
above.
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The initial part of the SIP review report, Section 2 and Appendix A,
was organized to provide the background and current situation information
for the State Implementation Plan. Section 3 and the remaining Appendices
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 and industrial sources)
has been carried out in Appendix C and D.
Based on an overall evaluation of EPA's current information, AQCRs have
been classified as good, marginal, or poor candidates for regulation revisions.
These ratings which are shown in the Summary Table on Page 9 were determined
by assessing the following criteria:
Good
1) Adequate number of air
monitoring sites
2) No NAAQS violations
3) Attainment date of
1975 for NAAQS in the SIP
4) No proposed AQMAs
5) Modeling results show
a potential for regulation
revision
Poor
1) Violations of NAAQS
2) Attainment date for
NAAQS later than 1975
3) Proposed AQMA
4) Modeling results show
no potential for regu-
lation revision
Marginal
1) No air quality data
or insufficient num-
ber of monitoring
sites
2) Inconsistent
"indicators"
For an AQCR to be rated as a good candidate, all of the criteria listed
under "Good" would have to be satisfied. The overriding factor in rating an
AQCR as a poor candidate is a violation of either the primary or secondary
National Ambient Air Quality Standards during 1973, However, if any of the
other conditions listed under "Poor" exists, the AQCR would still receive
that rating. The predominant reason for a marginal rating is a lack of suf-
ficient air quality data. Marginal ratings are also given when there are
varying or inconsistent "indicators."
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STATE IMPLEMENTATION PLAN REVIEW - LOUISIANA
SUMMARY TABLE
STATE
AQCR OT9 AQCR 022
AQCR lUb
"INDICATORS"
Does the State have air quality standards
which are more stringent than NAAQS?
t Does the State have emission limiting regu-
lations for control of:
1 . Power plants
2. Industrial sources
3. Area sources
t Did the State use an example region approach
for demonstrating the attainment of NAAQS or
more stringent State standards?
t Has the State not initiated action to modify
combustion source emission regulations for fuel
savings; i.e., under the Clean Fuels Policy?
Are there no proposed Air Quality Maintenance
Areas?
i Are there indications of a sufficient number
of monitoring sites within a region?
Is there an expected 1975 attainment date
for NAAQS?
« Based on reported (1973) Air Quality Data,
does air quality meet NAAQS?
Based on reported (1973) Air Quality Data,
are there indications of a tolerance for
increasing emissions?
t Are the total emissions from stationary fuel
combustion sources lower than those of other
sources?
Do modeling results for specific fuel combustion
sources show a potential for a regulation revision?
( Must emission regulations be revised to accom-
plish significant fuel switching?
Based on the above indicators, what is the
potential for revising fuel combustion source
emission limiting regulations?
Is there a significant Clean Fuels Saving
potential in the region?
TSP
NO
-<-<-<
m m m
CO CO CO
YES
YES
S0?
YES*
YES2
YES2
YES2
YES
YES
TSP
YES
YES
YES
NO
NO
YES
N/A3
NO
>OOR
NO5
S0?
YES
YES
YES
YES
YES
YES
N/A3
NO
N/A4
YES
TSP
NO
YES
YES
NO
NO
YES
II/A3
NO
POOR
NO5
S0p
YES
YES
YES
YES
YES
YES
N/A3
NO
N/A4
YES
TSP
YES
YES
YES
NO
NO
YES
N/A3
NO
POOR
NO5
S0p
YES
YES
YES
YES
YES
YES
N/A3
NO
N/A4
YES
Unless otherwise noted, N/A stands for "not applicable."
*
Louisiana has secondary standards for S02 which are more stringent than the current
federal standards for this pollutant.
The State's particulate regulation for stationary fuel burning equipment does not explicitly limit
itself to the kinds of equipment to which it applies. Therefore, one can only assume that it applies
to all such equipment, including area fuel burning sources.
Louisiana uses an ambient concentration property line regulation to control its S02 emissions, and it
also places a limit on the maximum concentration of S02 that can be emitted. It appears that this
regulation would apply to all sources not otherwise specifically covered (and therefore, area sources).
But because of inherent enforcement difficulties of the property line portion of the regulation, its
effectiveness for limiting emissions is decreased.
There is no modeling data available which could serve as'a basis for regulation revision decisions.
There is no way to make a direct connection between the restrict!veness of the State's S02 regulation,
and the resultant emissions using the methodology established for this review. Thus the air quality
indicators referred to by the questions on this table cannot be used as a basis for decisions to revise
emission limiting regulations.
In. that there are already NAAQS TSP violations in this AQCR, there is no potential for fuel switches
aimed at effecting clean fuel savings.
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2.2 AIR QUALITY SETTING FOR THE STATE OF LOUISIANA
The State of Louisiana is one of five states in EPA Region VI (the
others are Arkansas, New Mexico, Oklahoma and Texas). Louisiana is divided
into three AQCRs. These are listed below:
019 - Monroe - El Dorado Interstate
022 - Shreveport - Texarkana- Tyler Interstate
106 - Southern Louisiana - Southeast Texas Interstate
;
The three digit number in the above listing has been assigned by EPA
as a part of a nationwide numbering system for all AQCRs. The boundaries
of an AQCR are designed to enclose an airshed. All of Louisiana's AQCRs
have boundaries which cross State lines, (i.e., are interstate AQCRs).
Tables A-l, A-2 and A-3 summarize additional general information that
helps characterize the air quality and provides other related statistics
about the AQCRs. In Table A-l the following information is presented:
1) Priority classifications for the pollutants under study
2) Demographic data
3) Parishes within the State that are proposed Air Quality
Maintenance Areas (AQMAs).
4) The States with which Louisiana shares its interstate AQCRs.
Priority classifications give a quick indication of the extent to which
certain pollutants pose air quality problems for the AQCR. A Priority I
listing indicates that relatively high ambient concentrations of the
pollutant have been either observed, estimated (in the absence of adequate
measured air quality data), or predicted due to expected future sources.
A Priority III designation is used when pollutant concentrations are
generally lower than NAAQS. Table A-l indicates that the Southern Louisiana-
Southeast Texas (106) AQCR is classified Priority I for S02, while the other
two AQCRs have Priority III classifications for this pollutant. With regards
to particulates, all AQCRs are designated Priority II.
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The SIP describes the Southern Louisiana-Southeast Texas (106) AQCR
as the most heavily industrialized in the State with most of the activity
centering around the oil and gas industry. The industrial activities in
this AQCR may account for its high pollutant levels.
The demographic characteristics of the AQCRs are included in Table A-l
to further describe the various regions.
Proposed Air Quality Maintenance Area (AQMA) designations are a way of
identifying those areas in the State which, due to current air quality and/or
projected growth rate, may have the potential for exceeding any national
standard within the ten year period 1975-1985. These designations are pro-
posed by either the State, or by the Regional EPA office, If an area
ultimately becomes an AQMA, it is likely that more restrictive changes will
have to be made to existing regulations and/or air pollution control plans.
It will be noted that the Shreveport area has been proposed as an AQMA for TSP.
Table A-2 presents the dates when the ambient level of the pollutants
under study is expected to be within the limits set by NAAQS. The fact
that none of the dates are delayed from the July 1975 date originally
prescribed by law indicates that no major problems are foreseen for the
achievement of NAAQS.
A summary of the Federal and Louisiana ambient air quality standards
for the pollutants under study is presented in Table A-3. With the exception
of the secondary annual and 24-hour standards for S02» all State standards are
equivalent to NAAQS.
Compared to the general air quality information presented in
Tables A-l and A-2, the data in Tables A-4 and A-5 provides a more detailed
picture of the State's recent (1973) air quality setting. In Table A-4
there is evidence of a widespread particulate problem that did not seem to
be present during 1971 when the SIP was being written. Though the SIP
originally reported an annual geometric mean (AGM) of 119 >jg/m , further
investigation after submittal of the plan showed the correct recorded value
11
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3 *3
was 89 jjg/m . Data from 1973 shows the annual level to be 138 ;jg/m ,
while the 24-hour high was 747 >ig/m3. And though these (the State's
highest) values were recorded in the Southern Louisiana-Southeast Texas
AQCR (106), NAAQS TSP violations occurred in each of the other two AQCRs.
On the other hand, S02 levels measured in 1973 (and shown in Table
A-5) are generally quite low. None were in excess of the highest SO, value
n &
reported in the SIP (220 >ig/m , AAM). The highest annual reading reported
3
for 1973 was 16 ug/m . The highest ambient SO, value measured anywhere in
3
the three AQCRs was 205 >jg/m , a 24-hour measurement made in Texas. Louisiana's
highest SO, measurement was a 24-hour reading of 83 jjg/m. The one consistent
factor about the high SO,, readings from the SIP and those recorded in 1973 was
that they all occurred in the Southern Louisiana-Southeast Texas AQCR.
Table A-6 provides a listing by AQCR of the number of the State's power
plants and other fuel combustion point sources that produce particulate and
S02 emissions. The total given for each of the AQCRs applies to only those
portions which lie within Louisiana. Inclusion of both NEDS, and FPC data
serves to not only note the existence of more than one source of information,
but also points up data inconsistencies. It can also be seen that a number
of power plants are planned for future operation in the State.
The most current data available was used to compile the SO, and parti-
culate emissions data shown in Tables A-7 and A-8, namely emissions from
the NEDS data bank. The Southern Louisiana-Southeast Texas AQCR (106) accounts
for most of the emissions that originate within the State (88% of the S02
emissions, and 83% of the particulate emissions).
Information presented in the SIP indicates that most of the emissions
in this AQCR result from process sources. For parti culates, 89% of the
emissions were said to be due to process sources, while all other sources
supplied the remaining 11%. The breakdown for S02 was 91% for process
sources, 7% for transportation, and 2% for other contributors. It should be
pointed out that these figures represent the emissions mix that existed
prior to January 1972 when the SIP was submitted. It is not known how
accurately this breakdown exemplifies 1973 or current emissions. However,
examination of the 1972 data presented in Tables A-7 and A-8 tends to suggest
12
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continuance of a similar trend. While this data does not indicate the
proportion of emissions that are due to process sources, it does show that
only 16.9% of the S02 emissions, and 8.5% of the particulate emissions, are
due to fuel combustion. Because of their relatively small contribution of
emissions on a statewide basis, it is very possible that fuel combustion
processes would have a correspondingly small effect on air quality when
compared with the effect of process sources. A more detailed study would
be required to determine the extent of this assumption. However, fuel
combustion sources could have significant localized effects on air
quality.
2.3 BACKGROUND OF THE DEVELOPMENT OF THE CURRENT STATE IMPLEMENTATION PLAN
According to the SIP, the basis of Louisiana's air pollution control
activity is the State's Revised Statutes 40:2201 et. seq. including amendments,
This document, known as the Louisiana Air Control Law, established the
Air Control Commission which periodically adopts and promulgates rules and
regulations aimed at controlling air pollution.
The SIP describes Louisiana's control strategy for the attainment and
maintenance of NAAQS in terms of a series of strategems. These are listed
below to give the reader a general feel for Louisiana's approach to air
pollution control.
1. Compliance with existing emission standards, or with
proposed standards after they have been adopted.
2. Where compliance with existing standards is proven to be
infeasible (as is sometimes the case with older plants),
accept only the best demonstrated levels of emissions of
similar processes in plant scale operations found in
Louisiana, as well as in other portions of the United
States.
3. Concentrate actions on principle emitters for emission
reductions.
4. Require all emitters in violation of standards or regulations
to reduce emissions regardless of source size.
5. Require similar or like processes to attain technologically
equal reductions.
6. Use a statewide uniform approach.
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7. Resort to limited control of land use pertaining to air
pollution emissions through permit system when other
strategems do not give adequate reduction.
8. Consider financial hardship in requiring emission
reductions particularly with older plants.
9. For new sources, require compliance with emission limitations
attainable with reasonable available technology as given in
the Federal Register.
10. Control automobile exhaust emissions in principle urban areas
where needed to meet ambient air standards or in case of
emergency air pollution episodes.
The SIP anticipates that the combination of strategems 1 and 2 will
result in bringing air quality in Louisiana to a level that is in compliance
with NAAQS. The SIP includes a demonstration of this compliance by using the
proportional rollback and Air Quality Display models as applied to the
emissions of an Example Region.
Considering the area's many sources, high emission levels, and NAAQS
violations, it is no surprise that the Southern Louisiana-Southeast Texas
AQCR (106) was used as the Example Region. When the proportional rollback
model was applied to the highest TSP and SOg values recorded in this AQCR,
it was ascertained that emission reductions of 50 and 64 per cent respec-
tively would be required to attain NAAQS. Calculations were performed to
predict the magnitude of emission reductions expected from applying State
emissionsregulations. For particulates this was done for three metropolitan
areas within the Southern Louisiana-Southeast Texas AQCR. The results are .
shown below:
Anticipated Percentage Reduction
Area by Applying State Regulations
A. New Orleans ' 60%
B. Baton Rouge 84%
C. Lake Charles 54%
It can be seen that the 50% reduction needed to achieve secondary TSP
standards is attained in all three areas.
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The S02 emissions rollback of 64% was based on an ambient measurement
of 220 jjg/m3 (AAM) in the Baton Rouge area. (The ambient S02 levels in the
other areas were below NAAQS.) It was shown that application of the State's
regulations in the Baton Rouge area would result in an emission reduction
of 61%. This value was sufficiently close to the 64% requirement to assume
adequacy of the regulation. EPA approved the SIP's control strategies for
both S02 and particulates.
The State's emission limiting regulations for fuel burning equipment are
summarized in Table A-9. While the regulation for particulates applies
specifically to fuel burning equipment,.the applicable SOp emission regulation
has subsections which apply to each of differing industries. These subsections
state specific limits for 1) refineries (and other industries that have process
gas streams containing hydrogen sulfide), 2) sulfuric acid production plants,
and 3) sulfur recovery plants. An additional subsection gives the limit for
all other S02 emitters which are not otherwise specifically covered by the
other subsections. Fuel burning equipment falls into this category.
Attention should be brought to the differences between the formats of
the regulations for particulates and S02. The particulate regulation relates
the amount of allowed emissions directly to the amount of fuel burned (pounds
of particulates per million Btu). The SOp regulation is stated in terms of
ambient S02 concentrations observed at any point beyond the premises where
the source is located. Regulations written using this format are sometimes
referred to as "property line regulations," and they are often considered to
have inherent enforcement problems. However, of greater importance here is
the fact that the format of this type of regulation precludes evaluation of
its restrict!'veness using the methodology established for this review. Thus,
little can be said about whether the low ambient S02 levels observed in
Louisiana are due to the applicable regulation, to low baseline emissions, or
to some other factor.
2.4 SPECIAL CONSIDERATIONS
In accordance with 40 CFR Part 51, maintenance of National Ambient Air
Quality Standards, published in the June 18, 1973 Federal Register, States
15
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were to submit by March 18, 1974, proposals for Air Quality Maintenance
Area (AQMA) Designations. This requirement was not met by the State of
Louisiana. Thus, the responsibility fell to EPA to propose AQMA designa-
tions for the State. Officials in the Regional EPA Office used air quality
data for the years 1972 and 1973 to arrive at the proposed AQMA designations
referred to in Section 2.2 of this review.
Many of Louisiana's air pollution control regulations have subsections
which restrict the degradation of the existing emission or air quality levels
that are better than -the regulation requires. A non-degradation provision is
a part of the regulation which establishes the State's air quality standards.
It is also included in each of the regulations which stipulate particulate
and SOg emission limits for fuel burning equipment. Thus, Louisiana's current
regulations have provisions which specifically restrict the kinds of emission
increases (and corresponding air quality changes) that would be a part of the
clean fuel savings being discussed in this review. Therefore, these and other
similar provisions of Louisiana's Air Control Law may pose additional problems
for any plans aimed at relaxing emission regulations.
According to the particulate control strategy section (revised May 5,
1973) of the SIP, the Chalmette works of the Kaiser Aluminum and Chemical
Company, located in AQCR 106), is not expected to have its pollution abatement
facilities completed until after May 31, 1975. But based on their emission
figures (from 1970, and 1972), Kaiser's proposed emission reduction plan is
expected to achieve the rollback required to attain primary standards as
predicted by the proportional model. However, this section of the SIP did
not deal with whether this facility would be able to achieve the rollback that
would be necessary for compliance with secondary standards. Recent review of
emission data and application of rollback procedures indicate that secondary
standards can be achieved by the required date.
EPA has not yet approved Louisiana's smelter regulation. And though
this does not relate directly to fuel burning facilities, it does represent a
part of the SIP that is not approved. Also, since process sources are the
16
-------
major emitters in the State, the manner in which any one of them is
controlled may have a substantial effect on the air quality in the
immediate area of the source. Conceivably, if emissions from process sources
can be decreased sufficiently, then the corresponding attainment of air
quality may allow for increased emissions from fuel combustion sources so
that clean fuel savings could be achieved.
17
-------
3.0 AQCR ASSESSMENTS
3.1 REGIONAL AIR QUALITY
Tables A-10 and A-ll present the results when the proportional model is
used to estimate tolerance for emissions increase. This display should be
viewed in light of the limitations mentioned in Section 1.0. The portion of
these tables that apply to SIP information was included as a means of
summarizing the emission control goals of the State. However, Louisiana's
Plan lacked the detailed air quality and emissions data necessary for this
type of analysis.
Tables B-l and B-2 are summaries of some of the indicators which should
be considered when estimating the potential for regulation relaxation. The
overall regional evaluations listed on these tables are based upon considera-
tion of these indicators, and on the more comprehensive summary of indicators
referred to in the beginning of Section 2 of this report.
Based on the information presented in Tables A-ll and B-l, it can generally
be said that any increase in particulate emissions would tend to aggravate an
air quality situation which is typified by TSP violations in each of
Louisiana's three AQCRs.
Furthermore, there is evidence that substantial increases in particulate
emissions could occur without relaxation of the existing emission regulations.
Data presented in Appendices C and D shows that virtually all of the State's
major power plants and industrial sources are operating well within the limits
of Louisiana's particulate emission regulation. Thus, oil (which has particulate
emissions which are substantially higher than gas on a per million Btu basis),
could be substituted for gas in those plants which have dual fuel capability.
This would result in a significant increase in parttculate emissions, and based
on the State's 1972 emission levels of this equipment, this switch could be
made without exceeding the 0.6 lbs/10 Btu limit set by the regulation. So
considering that TSP violations are widespread and that sizeable particulate
emission increases could occur within the limits of the existing regulation, it
does not appear that this regulation is overly restrictive.
18
-------
Tables A-10 and B-2 both show that each of Louisiana's AQCRs have a
a tolerance for increased SO^ emissions. However, as it was stated previously,
the format of Louisiana's SCL emission regulation does not lend itself to an
evaluation of its restrictiveness using the methodology established for this
review. Thus, it cannot be said, at this time, whether the low levels are due
to the over restrictiveness of the regulation. But it should be noted that
the problems associated with the enforcement of property line regulations tend
to lessen that regulation's overall restrictiveness, and this is in spite of
any intended stringency of the numerical limits of these regulations. Further-
more, an emission control regulation for which the numerical limit is an
ambient concentration does not really set an emission limit. This is because
the prescribed ambient concentration maximum could result from a wide range
of emission levels depending on factors such as those listed below:
the way the fuel is burned
areal topography
location of monitors
meteorology
stack heights
characteristics of the exhaust gases
(e.g. exit velocity, temperature, etc.)
Thus the above discussion tends to suggest that the low SOg levels are not due
to the over restrictiveness of the State's emission control regulations. A
low level of baseline emissions is another possible cause, but analysis of this
point is outside the scope of this review.
The fact that there is a tolerance for increased SCL emission in the State
of Louisiana suggests that clean fuel savings involving this pollutant could
possibly be achieved by switching to a fuel with a higher sulfur content. This
may involve using residual oil or high sulfur oil rather than natural gas or
distillate oil. Some equipment may even be able to utilize coal as a heat
source. The degree to which such a switch could take place and still not cause
NAAQS S02 violations is unknown. A more extensive study (most likely requiring
modeling data) would have to be performed to answer this question. However, it
should be noted that most of the fuel switches that could generally be utilized
19
-------
for increasing S02 emissions (i.e. use of residual oil, high sulfur oil, or coal
instead of gas) would also produce corresponding increases in parti oil ate
emissions, and thus further aggravate the State's TSP situation.
3.2 STATEWIDE FUEL USE
According to NEDS emission information listed for the individual
stationary fuel burning sources in Louisiana, the major fuels can be categorized
as: natural gas, oil (including distillate and residual oils), and wood and
waste fuels (including wood waste products, bagasse, and waste from other
processes). Table B-3 summarizes the contributions of each of these fuels to
the State's total heat input budget. Natural gas undoubtedly provides the
major segment of the heat input to the State's stationary fuel burning equip-
ment. On a Btus/hour basis, natural gas accounts for 93% of the State's total
heat input. Oil contributes a total of 5%, while the general category of wood
and waste fuels provide the remaining 2%. This last group is composed pri-
marily of the recoverable combustible materials that accumulate as waste from
various industrial and agricultural processes within the State. It appears
that wood is the major fuel in this category. The SIP indicates that lumber
and pulp mills are relatively numerous in the Monroe-El Dorado and Shreveport-
Texarkana-Tyler AQCRs. (The former has two pulp mills and 43 lumber mills,
while the latter has two pulp mills and 66 lumber mills.) Presumably, some of
these facilities burn wood waste products in boilers to produce process steam.
Bagasse is the cellulose material that remains after the processing of sugar
cane. This is also used as a fuel in some of the State's industrial sources.
Though the SIP indicates the major economic activity in the Southern
Louisiana-Southeast Texas AQCR (106) centers around the oil and gas industry,
it should be noted that 74% of all the wood and waste fuel which is used in
the State's fuel combustion equipment is consumed in the Southern Louisiana-
Southeast Texas AQCR.
Louisiana's industrial facilities are the only stationary fuel com-
bustion sources in the State which utilize wood and other waste products as
fuel. In calculating the contribution of these materials to the State's
heat input budget, a value of 5000 Btu/lb was used as a very rough estimate
of their average heat content. The heat value of the different fuels that
-------
comprise wood and waste fuel categories vary widely depending on their
composition and moisture content. For relatively dry wood, heat contents
typically range between 6000-8000 Btu/lb. At the other end of the scale
are crop wastes and other organic materials which have heat values ranging
from 3000 to 6000 Btu/lb. Because of the variability of heat values,
moisture content, and resultant emissions of the individual fuels in this
category, the 5000 Btu/lb estimate has been used solely in those calcula-
tions aimed at providing a first approximation of the relative importance of
these materials as fuels within Louisiana. Therefore, no attempt will be
made either in the following assessment sections, or in the Appendices, to
discuss the impact that combustion of the materials would have on emissions
and air quality, or whether the equipment using these materials are
operating within the State's emission regulations.
3.3 POWER PLANT ASSESSMENT
The tables that comprise Appendix C provide a listing of the power
plants in the State along with a general description of each plant's emission
characteristics. This listing and information was obtained from the NEDS data
on individual sources. It should be noted that there is a discrepancy
between this listing and that obtained from other sources of data, (namely,
NEDS rank order listing, the Steam-Electric Plant Factors publication, and the
FPC data retrieved from EPA data banks).
The discrepancy includes not only differences in the total number of
plants, but also in how they are distributed among the AQCRs. No attempt will
be made to resolve this discrepancy. It is mentioned here only to bring to the
reader's attention the fact that data discrepancies do occur. For the purpose
of this review, the information presented in Appendix C will be the basis for
all further discussion and computations.
As shown in Table C-l, the State of Louisiana has a total of 21 power
plants, ranging in size from 25 megawatts electric (Mwe) to 1884 Mwe. The
State's total capacity is 10,185 Mwe. As indicated previously, natural gas
is the major fuel used, providing 88.7% of the heat input to all power plants
21
-------
in the State. Residual oil is the second most utilized fuel for power plants,
while distillate oil makes up the remainder. NEDS data shows no coal burning
power plants in the State. Information obtained from Steam-Electric Pliant
Factors shows that Louisiana's existing power plants were originally designed
for oil and gas, or gas alone. This publication also shows that of the new
plants planned for operation between 1974 and post-1978 (see bottom of
Table A-6), most are designed for a gas-oil dual fuel capability. There is
only one coal-burning power plant planned for Louisiana.
Power plants seem to be concentrated in the Southern Louisiana-Southeast
Texas AQCR (106). This one AQCR accounts for 9195 Mwe of the State's total
10,185 Mwe capacity, a total of 90.2%. This figure reflects not only the much
higher population density of this area, but also the high level of economic
and industrial activity mentioned in an earlier Section of this review.
While the particulate emissions from the oil burning equipment in
power plants is generally greater than emissions from its gas burning coun-
terparts, Louisiana's power plants all seem to have been operating we31
within the limits imposed by the State's particulate emission regulation.
Furthermore, the general emission level of power plants seems to be lower
than that of the industrial sources. Because of the property line format of
Louisiana's S02 emission regulation, it cannot be ascertained whether
individual sources are in violation.
3.4 INDUSTRIAL/COMMERCIAL/INSTITUTIONAL SOURCE ASSESSMENT
Table D-l presents the pertinent fuel combustion data for point sources
in the industrial/commercial/institutional sector (commonly referred to as
the industrial sector in this review). This information was obtained from
NEDS emission data for the individual sources.
There are 13 specific sources listed in Table D-l. However, there are
numerous other fuel burning facilities in Louisiana that would fall into the
industrial category. Because of their number, it was decided to list only
those industrial sources which had particulate or S02 emissions greater than
100 tons per year. The remaining industrial sources were grouped together
according to the type of fuel used, and the relevant characteristics (fuel
use, heat input, emissions, etc.) were totalled for each of these groups.
22
-------
As with other stationary fuel burning facilities within the State,
natural gas 1s the major fuel used for Louisiana's Industrial sources.
Three of the thirteen Identified sources utilize oil as a fuel, but in each
of these cases natural gas provides most of the plant's heat input.
It is not known to what extent any of the remaining sources (both those
individually listed 1n Table D-l, and those unlisted) can effectively switch
to a dirtier fuel.
In general it can be said that the State's industrial sources are all
operating within the emission limits Imposed by the applicable particulate
regulation. In fact, the only place where a violation is indicated is for
the aggregated emissions (from the unlisted sources) due to residual oil
combustion in the Shreveport-Texarkana-Tyler AQCR (022).
With regards to the SOp regulation, the comments made in the power plant
assessment section of this review also apply for industrial sources.
3.5 AREA SOURCE ASSESSMENTS
The provisions of ESECA were aimed at power plants and other major
stationary fuel combustion sources. For this reason, area fuel burning
sources offer little, if any, potential for achieving clean fuel savings
within the context of ESECA.
23
-------
APPENDIX A
State implementation plan information
Current air quality information
t 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 SO, and TSP monitoring stations are shown
c 1
for AQCRs in the State. NEDS emissions data by AQCR are tabulated and
broken down into fuel burning categories.
Tables A-10 and A-11 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 SCL 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
provides 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:
The "allowable emissions" were calculated for each AQCR based on 1972 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).
The percentages used in this calculation were obtained via the use of
current 1973 air quality data and the proportional rollback model. The
values for background TSP concentrations were the same as those used in the
SIP. This background value was used in all calculations involving the
annual standard, but a zero TSP background was assumed for the calculation
of reductions based on the 24-hour standard. (This was done because back-
ground levels are, in effect, an annual average, and therefore, should be
lM1972 National Emissions Report," EPA - 450/2-74-012, June 1974.
A-l
-------
compared with only annual data. It is reasonable to expect that the
"real background" for any particular 24-hour period to be different for
other 24-hour periods.)
The NEDS emissions are subtracted from the "allowables" to determine
the tolerance for emissions increase. A positive value for this result
indicates a potential for increasing emissions.
When the 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-10 and A-ll. 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 np_ 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
geographically 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
particulates being controlled will not remain suspended, 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.
A-2
-------
Table A-l. AQCR Priority Classification and AQMAs
AQCR
Monroe -
El Dorado
(Ark-La)
Shreveport-
Texarkana-
Tyler (Ark.-
La-Okla-Texi
Southern
Louisiana-
S.E. Texas
(La-Tex)
I AQCR#,
019
022
106
Priority Classification
Part.b
II
II
II
S0xa
III
III
I
MOXC
III
III
III
Demographic Information0
Poo'jlation
1970
319,722
519,669
2,801,915
Square
Miles
8,284
9,424
27,226
Population
Density
38.6
55.1
102.9
Proposed AQMA Designations6 |
TSP Parishes
Nonef
Bossier,
Caddo and
Webster.
Nonef
SOX Parishes
Nonef
Nonef
f
None1
N(y>arf shies
Nonef
None^
Nonef
CJ
I
Priority Greater than
a Sulfur oxide:
Annual arithmetic mean..
Parti cul ate matter:
Annual geometric mean...
Nitrogen dioxide
Based on information provided in the
the Louisiana portion of the AQCRs.
p
As indicated in the Proposed Air Qual
100
445
95
325
110
II
III
From-To Less than
60-100
260-455
60- 95
150-325
SIP. These statistics apply only
ity Maintenance
Area Designations
60
260
60
150
110
to
for
Louisiana background and Rationale, EPA, Region VI
For the Louisiana portion of the AQCR
only
-------
Table A-2. Attainment Dates - Louisiana
AQCR f?
019
022
106
AQCR Name
Monroe - El Dorado
Shreveport-Texarkana-Tyl er
Southern Louis iana-S.E. Texas
Particulates
Attainment Dates
Primary
7/75
7/75
7/75
Secondary
7/75
7/75
7/75,
i
Sulfur Dioxide
Attainment Dates
Primary
a
a
7/75
Secondary
a
a
7/75
Nitroqen Oxide;*
Attainment Dates
a
a
a
a) Air Quality was better than levels indicated by secondary standards at the time these attainment
dates were formalized.
b) Based on information supplied by EPA-Durham
-------
Table A-3. Ambient Air Quality Standards - Louisiana
(.Expressed as
Federal
(Nov. 1972)
State b
Primary
Secondary
Primary
Secondary
Total
Suspended Parti cul ate
Annual
75(6)
60(6)
75(6)
60(6)
24-Hr.
260a
150a
260a
150a
Sulfur Oxides
Annual
80 (A)
-
80 (A)
60CA)
24-Hr.
365a
-
365a
260a
3-Hr.
1300a
..
1300a
Nitr.'.._-n
P«4 ... - : ..
U I «,-A i Ob
100(A)
100(A)
10QCA)
ioo(AI
f
vn
(A) = Annual arithmetic mean
(G) = Annual geometric mean
a Not to be exceeded more than once per year
b As revised Nov. 21, 1972, Louisiana's ambient air standards for the above pollutants
were identical to the Federal Standards that existed before EPA dropped the secondary
standards for S-
-------
Table A-4. Louisiana AQCR Air Quality Status (1973), TSPa
(w/m3)
TSP Concentration
AQCR Name
1. Monroe - El Dorado
2. Shreveport -
Texarkana -
Tyler
3. Southern
Louisiana -
Southeast Texas
AQCRJ
01 9b
(La.)
022b
(La.)
106b
(La.)
#
Stations Highest
Reporting Annual"
8
3
11
3
18
6
63
63
81
-
138
77
Reading
24-Hr
254
254
580
237
747
250
2nd
Highest
Readi ng
24-Hr
217
217
168
167
505
166
# Stations Exceeding
Ambient Air Quality Standards
Primary . Secondary
Annual
0
0
1
-
3
1
24-Hr"
0
0
0
0
1
0
Annual % 24-Hr
1
1
3
-
9
1
12
33
27
-
50
17
4
3
4
2
7
2
C %
50
100
36
67
39
33
d
Reduction Standard
Required on Which %
to Meet Reduction
Standards Is Based
25
25
38
4
70
33
24-hr
24-hr
annual
24-hr
24- Hr
annual
1973 air quality data is National Air Data Bank as of June 7, 1974.
Interstate
Violations based on 2nd highest reading at any station
^Formula [ ( 2n<* Highest 24 Hr - 24 hr Secondary Standard > x
/ Annual - Annual Secondary Standard * ,00 ,
TSP - Background = 25 pg/m3 as used in SIP
-------
Table A-5. Louisiana AQCR Air Quality Status (1973), S02a
S00 Concentration
AQCR Name
2. Shreveport -
Texarkana -
Tyler
3. Southern
Louisiana -
Southeast Texas
Interstate.
°
_,_ ,
Formu1a
AQCR
ado 01 9b
(La.)
022b
(La.)
106b
:as (La->
ty data is
ed on 2nd
Stations
Reporting
24-Hr'
# Bubbler)
3
1
7
2
19
13
National Air
ff
Stations
Reportirv
(Contin.
-
-
-
5
4
Data Bank
highest reading at any
2nd Highest 24 Hr - 24
g Highest
) Annual
3
3
7
7
16
16
G*g/m*
Raadi na
24- Hr
61
11
25
25
205
83
2nd
Highest
Reading
24-Hr
60
10
13
13
63
35
i? St
ations i
Arrbient Air Qi
Primary
Annual
0
0
0
0
0
0
24-Hrc
0
0
0
0
0
0
as of June 7, 1974.
station.
Hr Standard \ 1Qf
. / Annual - Annual Standard *
:eeding Reduction
lity Stds. Required
Secondary To Meet
3-Hr Standards
2nd Highest 2 r ' nnual
0
0
e
e
e
e
e
e
Standard
on Which %
Reduction
Is Based
For calculations, National Standards were used.
eThe most adverse air quality reading for this AQCR is less than 1/2 the applicable standard, the re fore % reductions were
not calculated in order to not mislead the reader with unrealistic percentages.
- background is assumed to be zero.
-------
Table A-6. Louisiana - Fuel Combustion Source Summary
00
AQCR Name
Monroe-El Dorado3
Shreveport-Texarkana-
Tylera
Southern Louisiana-
S. E. Texas a
AQCR #
019
022
106
Louisiana Power Plant
b
NEDS
2
3
18
c
FPC
2
2
17
d
2 (1974)
1 1975)
1 1976)
1 1978)
1 (after
1978)
Other Fuel Combustion Point Sources"
Parti cul ate
9
13
80
"X,.
so2
9
8
34
a) Interstate
b) From NEDS data in bank as of June 1974 (Rank Order Listing).
c) FPC data retrieved from EPA data banks.
d) Number of power plants planned to go on line on the dates indicated.
-------
TabTe A-T. Emissions summary. SU2 - Louisiana
AQCR
lonroe-El Dorado
019
Xa. Portion Only)
Sheeveport-
Texarkana-Tyler
022
(La. Portion Only)
Southern Louisiana
S. E. Texas
106
(La. Portion Only)
Total Emissions
La. Total Only
, Total
(10-3 Tons/ Year
24.5
15.0
65.8
6.35
299
162
389.3
183.4
t From
Fuel
Combust
18.4
5.49
7.3
18.1
10.5
16.9
Emission
I from
Fuel
JCombusti
K103 Tons
4.5
.824
4.8
1.15
31.4
27.4
40.7
29.4
Electricity Generation
i
(103 Tons/Year)
2.2
.006
1.0
.006
10.1
10.1
13.3
10.1
%
9.0
.04
1.5
0.09
3.4
6.2
Point Source
Fuel Combustion
(103 Tons/Year)
1.8
.391
1.8
.314
16.3
13.2
19.9
13.9
%
7.3
2.6
2.7
4.9
5.5
8.1
Area Source
Fuel Combustion
(103 Tons/Year)
0.5
0.427
2.0
.827
5.0
4.1
7.9
5.4
%
2.0
2.8
3.0
13.0
1.7
2.5
aBased on NEDS 1972 National Emissions Report
-------
Table A-8. Louisiana Emissions Summary, Particulatesc
1
0
AQCR
Monroe-El Dorado
019
(La.Portion Only)
Shreveport-
Texarkana-Tyler
022
(La.Portion Only)
Southern Louisiana
S. E. Texas
106
(La.Portion Only)
Total Emissions
La. Total Only
, Total
(l(r Tons/Year
29.8
16.2
162
53.2
_395
350.
586.8
419.4
% From
Fuel
Combust.
45.6
34.2
5.8
9.9
10.1
8.5
Emissions
from
Fuel
Combustic
(103 Tons
yr)
13.6
5.54
9.40
5.27
39.9
29.8
62.9
40.6
Electricity Generation
>n
' (103 Tons/Year)
0.3
.154
1.2
.140
3.80
3.20
5.3
3.5
%
1.0
1.0
0.74
0.26
0.96
0.91
Point Source
Fuel Combustion
(103 Tons/Year)
12.5
4.84
5.9
3.89
30.5
21.6
48.9
30.3
%
41.9
29.9
3.6
7.3
7.7
6.2
Fu
do3
Area Source
Fuel Combustion
(103 Tons/Year)
0.8
0.554
2.3
1.24
5.4
4.90
8.5
6.7
%
2.7
3.4
1.4
2.3
1.4
1.4
aBased on NEDS 1972 National Emissions Renort
-------
Table A-9. Fuel Combustion Regulations - Louisiana
Existina Sources
New Sources
Particulates
The applicable regulation makes no distinction between new and existing sources,
nor between different kinds of fuels ,
Particulate emissions limited to 0.6 lbs/10 Btu heat input
Same limits apply when products or by-products of a manufacturing process are
burned in conjunction with any fuel.
SO
The part of the sulfur oxides emissions ccntrol regulations for fuel burning
equipment applies to both new and existing equipment.
Two limits on emissions are in effect:
There should be no emissions which:
1) Cause ambient air beyond the premises where the source is located
to exceed federal ambient air quality standards for S02-
2) Have discharge gases with S02 concentrations greater than 2000 PPM by
volume at standard conditions.
a) As described in the following sections of the Louisiana Air
Control Commission's, Air Control Regulations (reprinted Aug. 16, 1973)
Particulates: Sections of Regulation 21.0 (Emission of Particulate Matter from Fuel Burning
Equipment)
Sulfur Oxides: Sections of Regulation 24.0 (Emission Standards for Sulfur oxides)
specifically Section 24.7.4.
-------
Table A-10. Required Emission Reductions - SO,, Louisiana
I
ro
SIP
1972 DATA
AQCR
019
(La.
Portion:
022
(La.
Portion!
106
(La.
Portion]
AQ
Measurement
Control
Value
"
220 (AAM)
Emissions
(1C3 Tons)
Allowable6
Emissions
(103 Tons)
-
1975
Estimated
Emissions
After Controls
(103 Tons).
-
Percent
Reduction
Required
Based On
1973 AQ Data
a
a
a
a
a
a
'
NEDS
Emissions
(1C3 Tens)
24.5
15.0
65.8
6.35
299
162
1
AT 1
Err.i
(1C
b~issicn
Tolerance
.} j (TO3 Tens)
f~
c
C
a. It was arbitrarily decided to not calculate % reduction in those cases where the air quality measurement was less than
1/2 the standard because the emission increases projected by this method would be unrealistically high.
b. Based on a proportional change of emissions to air quality.
c. Available air quality data indicates that there is a sizeable potential for allowing the emissions of sulfur oxides to
increase in this region. However, if this increase was quantified using the proportional model, the results would be
unrealistically high. Therefore, no calculation was made.
-------
Table A-11. Required Emission Reductions - Particulates, Louisiana
SIP
1972 DATA
_J
CO
AQCR
019
(La.
Portion
022
(La.
Portion
106
(La.
Portion
AQ
neasurement
Control
Value
-
95 (AGM)
Emissions
(103 Tons)
-
-
Allowable
Emissions
(103 Tons)
-
-
1975
Estimated
Emissions
After Controls
(103 Tons).
-
-
Percent
Reduction
Required
Based On
1973 AQ Data
25
25
38
4
70
33
NEDS
Emissions
(103 Tons)
29.8
16.2
162
53.2
395
350
!
I
A';
Err.
(1
1
1
2
22.4
12.2
100.4
51.1
118.5
234.5
a !
7cHrer.ce
(103 Tons)
- 7.4
- 4.0
- 61.6
- 2.1
-276.5
-115.5
a. Based on a proportional change of emissions to air quality.
-------
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 SOg emissions.
They also provide an identification of those AQCRs which show little
potential for fuel revision or regulation relaxation if ambient air standards
are to be attained.
The general criteria for candidacy is covered by the list of questions
found at the beginning of Section 2.0. Some of the more important criteria
is reflected by the tables in this appendix. These criteria include (1)
the breadth of air quality violations, (2) the fraction of total emissions
resulting from fuel combustion, (3) proposed AQMA designations, (4)
expected attainment dates, (5) total regional emissions, and (6) regional
tolerances for emissions increase.
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 possible
that an AQCR may have air quality levels below standard at present and may
require more strict regulations than currently exist if all fuel burning
sources were converted to dirtier fuels, i.e., "average" emission rate now
may be below "average" regulations.
B-l
-------
Table B-l. Candidacy Assessment for Relaxation of Particulate Regulations'
AQCR
019
022
106
Air Quality k
#
Stations
3
3
6
# with"
Violations
3
2
2
Expected
Attainment
Datec
7/75
7/75
7/75
Any
Counties
AQMA
Designations?
No
Yes
No
Total
Emissions
103 tons/yr
16.2
53.2
350
% Emission
From Fuel
Combustion
34.2
9.9
8.5
Tolerance
for
Emissions
Increase
(103 tons)
-4.0
-2.1
-115.5
Overall
Regional
Evaluation
Bad Candidate
4
II II
a) For interstate AQCRs, information on this table applies only to portions inside Louisiana.
b) Violations of secondary standards (24 hr)
c) Attainment of secondary standards
-------
Table B-2. Candidacy Assessment for Relaxation of S02 Regulations3
CO
co
AQCR
019
022
106
Air Quality
Stationsb
3
1
7
# with
.Violations
0
0
0
Expected
Attainment
Date
c
c
7/75
Any
Counties
AQMA
Designations?
No
No
No
Total
Emissions
103 tons/yr
15.0
6.35
162
% Emission
From Fuel
Combustion
5.49
18.1
16.9
Tolerance
for
Emissions
Increase
(103 tons)
d
d
Overall
Regional
Evaluation6
Good Candidate
M II
d
f
r
a. For interstate AQCRs, information on this table applies only to portions inside Louisiana.
b. Number of stations with bubbler monitors.
c. At the time attainment dates were formalized, air quality in this region was better than that required
by air quality standards.
d. Available air quality data indicates that there is a sizeable potential for allowing the emissions of
sulfur oxides to increase in this region. However, if this increase was quantified via the proportional
model, the results would be unrealistically high. Therefore, no calculation was made.
e. For Louisiana -the evaluation here relates to an AQCR's candidacy for increasing SOg emissions.
Due to the format of the State's emission regulation for this pollutant, it cannot be determined
whether this regulation should be a candidate for relaxation.
-------
Table B-3. Statewide Fuel Use at Fuel Combustion Point Sources - Louisianaa
Power Plants
Fuel (heat input - 106 Btu/hr)
Natural Gas 45780
Oil 5839.8
distillate 1484
residual 3647.6
oil type
unknown 708.2
Wood and Waste
fuel (includes
wood, bagasse,
and other
assorted
process waste
products)
51620 total heat
input to
power plants
Industrial -Commercial Sources
(heat input - 106 Btu/hr)
77863
784.5
26.7
757.8
2457.3*
81105 total heat input
to industrial-
commercial sources
Total
123693
6624.3
2457.3
132725 **
03
* Based on a rough estimate of 5000 Btu/pound for wood and wastes used as fuel, and on an annual total
of 2,152,500 tons of wood and other wastes being combusted.
**Total heat input to all stationary point source fuel combustion facilities in Louisiana.
-------
APPENDIX C
This appendix provides a characterization of individual power plants
by AQCR. Current power plant information used to prepare Table C-l was
obtained from three main sources: (1) Federal Power Commission computerized
listings of power plants and their associated fuel use, (2) the National
Coal Association's Steam-Power Plant Factors, listing of power plants and
fuel use in 1972, and (3) emission data in the NEDS data bank as of
June 29, 1974. Fuel schedules for 1973 were extracted from the FPC data
(1 above), and this was used in conjunction with NEDS emission data to es-
timate 1973 emissions for each of the sources. When 1973 fuel schedules
were not available, 1972 schedules were used as extracted from NEDS.
S02 and particulates emissions are those associated with the fuel
shown. When actual emissions were not listed in NEDS, AP-42 emission
factors were used to estimate SCL and particulate emissions, based on fuel
schedules.
i
After the name of each plant is a listing of the fuels for which the
plant was designed (from source 2). For the purposes here, it is assumed
that when a plant is shown to have dual fuel capability, it is able to use
enti rely one fuel or the other.
Also shown is the 1975 regulations which are currently applicable to
the given plant, taken from Table A-9. (Particulate limits are assumed to
be based on the entire heat input of the plant.)
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 "completeness" of the NEDS data bank.
The units for the annual amounts of fuel used by individual sources
3 6
in this Appendix are 10 gallons for oil, and 10 cubic feet for natural gas,
C-l
-------
Table C-l. Power Plant Fuel Combustion Point Source Characterization - AQCR 019
County
Ouachita
Plant Name
L.A. Power &
Light
352 m G
Monroe Utility
Comm. p
166 MW
Fuel Use
Type
% Sulfur
% Ash
Gas
Oil
1.0%S
Gas
Annual
Quantity
25721
1176
5467
Heat
Inout
(i06 Btu/hr)
3083
20.1
655
Emi ssions
S02 j Particulates
Existing
itqns/y_r
7
92
1
Allowable
ibs/106
Btu ltons_/yj
<.01
1.04
<.01
'V.
lbs/]0c
Btu
N/A
N/A
N/A
Existing
jibs/106
tons/vrl Btu
194
5
41
0.01
0.06
0.01
Allowable
i ^2/10^
tons/vj. Btu
0.6
0.6
0.6
i
PO
-------
Table C-l. Power Plant Fuel Combustion Point Source Characterization - ftQCR
County
Caddo
Minn
Plant Name
Southwest El.Pwr.
Arsenal Hill
170 MW G
Southwest E.Pwr.
Lieberman
277 MW G
Mi nden g
25 MW
Fuel Use
Type
% Sulfur
% Ash
Gas
Gas
R.Oil
1.02%S
Gas
Annual
Quantity
3592
9547
521
977
Heat
Input
(106 Btu/hr)
431
1144
8.9
117
Emissions
S02
Existing J Allowable
tons/yr
1
3
.
42
<1
Ibs/106
Btu |tons/VT
<.01
<.01
1.07
_
Ibs/10^
Btu
N/A
N/A
N/A
N/A
Parti culates
Existing
itons/yr
26
71
2.1
7
!bs/10£
Btu
0.01
0.01
0.05
0.01
Allowable
itons/^_
Ibs/106
Btu
0.6
0.6
0.6
0.6
o
I
CO
-------
Table C-l. Power Plant Fuel Combustion Point Source Characterization - AQCR 106
County
Rapides
St. Charles
Evangel ine
St. Mary
Orleans
Iberville
Plant Name
Alex Power Plant
178 MW #2
G
LA Power & Light
1251 MW OG
Central LA Elec.
Co.
483 MW G
Municipal Stm.
33.4 MW OG
Central LA Elec -
868 MW Teche
G
N.O. Pub Service
Market St. 96 MW
OG
Glf. St. Utl. Willow
1590 MW QG
Fuel Use
Type
% Sulfur
% Ash
Oil
0.1%S
Gas
Oil
0.1%S
Gas
Oil
0.1 3%S
Gas
Oil
1.0%S
Gas
Gas
Gas
R.Oil
0.5%S
Gas
Annual
Quantity
370
4547
630
63148
2142
16784
185
0
17645
1481
137718
41563
Heat
Input
(106 Btu/hr)
6.3
545
10.8
7569
36.7
2012
3.2
2115
178
2358
4982
Emissions
S02
Existing
tcns/yr
3
1
5
1'9
22
5
15
0
5
<1
5405
12
Allowable
!bs/106
Btu |tons/v
0.11
<.01
0.10
<.01
0.14
<.01
1.08
-
<.01
-
0.52
<.01
\
ibs/10(
Etu
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Parti culates
Existing
tons/v
1.5
34
3
474
8.6
278
1
0
134
11
551
313
Allowable
lbs/105. jibs/106
Btu ttons/yr[ Btu
0.05
0.01
0.06
0.01
0.05
0.03
0.07
-
0.01
0.01
0.05
0.01
0.6
0.6
0.6
0.6
0.6
0.6
0.6
-
0.6
0.6
0.6
0.6
-------
Table C-1. Power Plant Fuel Combustion Point Source Characterization - AQCR 106 (.Continued^
County
Jefferson
Lafayette
Orleans
St. Landry
Calcasieu
Plant Name
LA. Power & Light
1884 MW OG
Lafayette Util.
System G
143 MW Walker
Lafayette Uti 1 .
System G
43 MW Pinhook
N.O. Pub.Serv.
218 MW Paterson
OG
N.O. Pub. Serv.
959 MW Michould
OG
City of Opelousas
G
Lake Charles*
G
Fuel Use
Type
% Sulfur
% Ash
Oil
0.2%S
Gas
Oil
o.ms
Gas
Gas
R.Oil
1.0%S
Gas
R.Oil
1.54%S
Gas
Gas
Gas
Annual
Quantity
36246
79046
588
4748
975
20454
4240
33054
-23102
1142
1000
Heat
Input
(106 Btu/hr)
621
9475
10.1
569
116
350
508
566
2769
137
120
Emissions
S02 | Parti culates
Existing | Allowable
tons/yr
569
24
5
1
<1
1606
1
3996
7
< 1
4
lbs/10(
Btu
0.21
<.01
0.11
<.01
-
1.05
<.01
1.61
<.01
_
-
i
5
tons/yr
bs/10£
Btu
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Existing
itons/vt
145
592
2
37
6
82
32
132
173
9
8
Allowable
lbs/106,
Btu (tons/yr
1
0.05
0.01
0.05
0.01
0.01
0.05
0.01
0.05
0.01
0.29
.01
0.02
!bs/10£
_Jliu_
0.6
0.6
0.6
0.6
0.6
0.6
0.6
0.6
0.6
0.6
0.6
r»
*Not found in FPC, NEDS only for 1972
-------
Table C-1. Power Plant Fuel Combustion Point Source Characterization - AQCR 106 (Continued)
County
Calcasieu
East Baton
Rouge
.
Plant Name
Glf.St.Utl.
982 MW nr
Ub
Glf St.Util.Sta#2
175 MW QG
Glf.St.Ut1l.Sta#l
253 MW
OG
Fuel Use
Type
% Sulfur
% Ash
D.Oil
0.06%S
Gas
R.Oil
1.1XS
Gas
R.Oil
2.0%
Gas
Annual
Quantity
86688
23776
17514
10007
3780
43437
Heat
Input
(106 Btu/hr)
1484
2850
300
1199
64.7
5206
Emissions
S02
Existing
tcns/y_r
408
7
1512
-
3
593
13
Parti culates
Allowable | Existing
ibs/105
D LU jtons/y
0.06
<.01
1.15
<.01
2.09
!bs/lo6 jibs/106
Btu [ccns/vrj Btu.
N/A
N/A
N/A
N/A
N/A
N/A
347
179
70
75
15
15
0.05
0.01
0.05
0.01
0.05
Allowable
tons/v
ibs/106
Btu
0.6
0.6
0.6
0.6
0.6
o
I
(ft
-------
APPENDIX D
The Table. D-l in this appendix lists individual industrial/commercial/
institutional sources of particulates and SO^ emissions which might show
fuel switching potential. The sources are from a NEDS rank order emissions
listing.
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 overlooked 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).
No information was available for feasibility of any fuel
switching.
The units for the annual amounts of fuel used by individual sources
are as follows:
3
10 gallons for oil
10 cubic feet for natural gas
tons for wood and other wastes
used as fuels
D-l
-------
Table D-l. Industrial-Commercial Fuel Combustion Point Source Characterization - AQCR 019
1
County
Ouachita
Union
Morehouse
All
'
Plant Name
Commercial
Solvent
Texico, Inc.
Int'l. Paper Co.
Other
Fuel Use
Type
% Sulfur
% Ash
Gas
Gas
R. Oil
0.95%S
Gas
Gas
Wood,
Waste fu
Annual
Quantity
28100
17500
2030
83000
26944
270760
1
Heat
Input
(106 Btu/hr)
3368
2098
34.8
9947
3230
309*
Emissions
S02
Existing | Allowable
tons/yr
8
5
151
.
25
223
1792*
T &
Btu
<.01
<.01
1.0
<.01
0.02
-
5
tons/vr
!bs/10{
Btu
N/A
N/A
N/A
N/A
N/A
N/A
Parti culates
Existing
tons/yi
253
157
23
747
7
3658
|
I Btu
0.02
0.02
0.15
0.02
<.01
-
Allowable
tons/y
i g
. Btu,...
0.6
0.6
0.6
0.6
0.6
0.6
CD
I
ro
*Includes Bagasse, process gas, other not specified
-------
Table D-l. Industrial-Commercial Fuel Combustion Point Source Characterization - AQCR 022
County
Webster
All
Plant Name
Int'l. Paper
Other
Fuel Use
Type
% Sulfur
% Ash
Gas
R. Oil
Gas
Wood, waste
fuel
Annual
Quantity
13000
379
18311
280800
Heat
Input
(106 Btu/hr)
1558
6.5
2195
320
Emissions
S02
Existing
tons/yj^
4
4
5
211
Allowable
Ibs/106
Bt" Itons/v
<.01
0.34
<.01
Parti culates
Existing
lbs/W6. «bs/106
Btu ftons/yjl_Bti»
N/A
N/A
N/A
N/A
132
88
159
3483
0.02
3.09
0.02
Allowable
tons/y1
!bs/10^
Btu
0.6
0.6
0.6
. I
10
-------
Table D-l. Industrial-Commercial Fuel Combustion Point Source Characterization - AQCR 106
County
Ascension
Beauregard
Iberville
LaFourche
St. Charle;
St. James
Washington
Calcasieu
All
Plant Name
Borden, Inc.
Triad Chemical
Boise Southern
Dow Chemical
The South Coast
Shell Chemical
Kaiser Alum&Chem
Crown Zellerbach
01 in Corp.
Total Other
Total Wood, waste
Fuel Use
Type
% Sulfur
% Ash
Gas
Gas
R. Oil
0.6%
Gas
Gas
Gas
Gas
Gas
Gas
Gas
R. Oil
0.6%S
Gas
D. Oil
R. -Oil
fuels, etc.
Annual
Quantity
25000
13200
4820
2570
13200
97900
2912
19400
11700
13690
36960
263185
1670
60
1601000
Heat
Input
(106 Btu/hr)
2997
1582
82.5
308.0
1582
11735
349
2325
1402
1641
633
31546
26.7
1.03
1828
Emissions
S02
Existing j Allowable
tons/yr
8
4
227
<1
4
29
1752
6
4
3
1742
40
14
6
8497
lbs/10<
Btu
<.01
<.01
0.62
-
<.01
<.01
1.15
<.01
<.01
<.01
0.63
<.01
0.12
1.33
tons/yr
lbs/10e
Btu
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Parti culates
Existing j Allowable
jibs/106
tons/vd Btu
225
119
132
132
119
881
262
175
105
123
425
2401
10
<1
18690
0.02
0.02
0.37
0.10
0.02
0.02
0.17
0.02
0.02
0.02
0.15
0.02
0.09
0
i
tons/y
ibs/10(
Btu
0.6
0.6
0.6
0.6
0.6
0.6
0.6
0.6
0.6
0.6
0.6
0.6-
0.6
0.6
*Includes Bagasse, process gas, other not specified
-------
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. "Energy Potential From Organic Wastes: A Review of the Quantities and
Sources", Bureau of Mines Information Circular 8549, Department of
Interior, 1972, written by L. L. Anderson.
12. The Louisiana Air Control Implementation Plan, submitted January 28,1972
by Govenor John J. McKeithen.
-------
TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1. REPORT NO.
EPA-450/3-75-024
3. RECIPIENT'S ACCESSIOWNO.
4. TITLE AN
PLAN REVIEW FOR LOUISIANA AS REQUIRED
BY THE ENERGY SUPPLY AND ENVIRONMENTAL COORDINATION
ACT.
8. REPORT DATE
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
8. PERFORMING ORGANIZATION REPORT NO.
0. PERFORMING ORGANIZATION NAME AND ADDRESS
U. S. Environmental Protection Agency, Office of
A1r Quality Planning and Standards, Research Triangle
Park, N.C., Regional Office VI, Dallas, Texas, and
TRW, Inc., Redondo Beach, Calif.
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS
U.S. Environmental Protection Agency
Office of A1r and Waste Management
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
13. TYPE OF REPORT AND PERIOD COVERED
14. SPONSORING AGENCY CODE
16. SUPPLEMENTARY NOTES
16. ABSTRACT
Section IV of the Energy Supply and Environmental Coordination Act of 1974,
(ESECA) requires EPA to review each State Implementation Plan (SIP) to determine
if revisions can be made to control regulations for stationary fuel combustion
sources without interferring with the attainment and maintenance of the national
ambient air quality standards. This document, which 1s also required by Section
IV of ESECA, 1s 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
Air pollution
State Implementation Plans
18. DISTRIBUTION STATEMENT
Release unlimited
19. SECURITY CLASS (ThisReport)
Unclassified
21. NO. OF PAGES
20. SECURITY CLASS (TMfJMSt)
Unclasslffea
22. PRICE
EPA Form 2220-1 (9-73)
------- |