EPA-450/3-75-030

March 1975
      IMPLEMENTATION PLAN REVIEW
                   FOR
          NORTH CAROLINA
              AS REQUIRED
                   BY
           THE ENERGY SUPPLY
                   AND
   ENVIRONMENTAL COORDINATION ACT
      U. S. ENVIRONMENTAL PROTECTION AGENCY

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                                                       V-450/3-75-030
                    IMPLEMENTATION PLAN REVIEW

                               FOR

                         NORTH CAROLINA

REQUIRED BY HIE ENERGY SUPPLY AND ENVIRONMENTAL COORDINATION ACT
               PREPARED BY TIE FOLLOWING TASK FORCE:

           U.  S.  Environmental Protection Agency,  Region IV

                        1421 Peachtree St.,  NE
                        Atlanta,  Georgia  30309
             Energy and Environmental Systems  Division
                    Argonne National  Laboratory
                     Argonne,  Illinois  60439
                         (EPA-IAG-D5-0463)
              U.  S.  Environmental  Protection Agency
               Office of Air and Waste  Management
           Office of Air Quality Planning  and Standards
           Research  Triangle Park, North Carolina   27711
                          March 1975

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                              NORTH CAROLINA

              ENERGY SUPPLY AND ENVIRONMENTAL COORDINATION ACT
               SECTION IV   STATE IMPLEMENTATION PLAN REVIEW


                              Table of Contents

                                                                             Pago

1.0  EXECUTIVE SUMMARY	    5

2.0  NORTH CAROLINA STATE IMPLEMENTATION PLAN REVIEW	10

     2.1  Summary	10

     2.2  Air Quality Setting for the State of North Carolina	11

          2.2.1  North Carolina Air Quality Control Regions   	   11
          2.2.2  North Carolina Ambient Air Quality Standards 	   15
          2.2.3  North Carolina Air Quality Status    	   15
          2.2.4  North Carolina Emissions Summary 	   15

     2.3  Background on the Development of the Current  State
          Implementation Plan	17

          2.3.1  General Information	17
          2.3.2  Particulate Control Strategy  	   18
          2.3.3  Sulfur Dioxide Control Strategy   	   18

     2.4  Special Considerations for the State of North Carolina ....   18

          2.4.1  Planned SIP Revisions	18
          2.4.2  Fuels	21
          2.4.3  Fuel Conversions	21

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                      STATE  IMPLEMENTATION PLAN REVIEW
                                    FOR
                       THE STATE OF NORTH CAROLINA
1.0  EXECUTIVE SUMMARY

     The enclosed report is the U.S. Environmental Protection Agency's  (EPA's)
response to Section IV of the Energy Supply and Environmental Coordination
Act of 1974 (ESECA).  Section IV requires EPA to review each State Implemen-
tation Plan (SIP) to determine if control regulations for stationary fuel
combustion can be revised without interfering with the attainment and main-
tenance of the National Ambient Air Quality Standards (NAAQS).  In addition
to requiring that EPA advise the state as to whether control regulations can
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 under 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 information
on excessively restrictive control regulations.   The intent of ESECA is that
SIPs, wherever possible, be revised in the interest of conserving low-sulfur
fuels or converting to coal,  sources which burn oil or natural  gas.   EPA's
objective in carrying out the SIP reviews, therefore, has been to try to
determine if emissions from certain combustion sources may be increased with-
out interfering with the attainment and maintenance of standards.   If so,  it
may be possible through altered resource allocations to effect  significant
"clean fuel savings" in a manner consistent with both environmental and
national energy needs.
     In many respects, the ESECA SIP reviews parallel the implementation of
EPA's policy on clean fuels.   Under the Clean Fuels Policy,  implementation
plans have been reviewed with a view to saving low sulfur fuels.   Where the
primary sulfur dioxide air quality standards will not be exceeded, states have
been encouraged to either defer attainment of secondary standards or to revise

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the S02 emission regulations.  The states have also been asked to discourage
large-scale shifts from coal to oil where this could be done without
jeopardizing the attainment and maintenance of the NAAQS.
     To date, this activity has involved only those states with the largest
clean fuels saving potentials.  Several of these states have revised or are
currently in the process of revising their S0? regulations.  These states
                                             i*
are generally in the eastern half of the United States.  ESECA, however,
requires the analysis of potentially over-restrictive regulations in all 55
states and territories.  In addition, the current reviews address the attain-
ment and maintenance of all the National Ambient Air Quality Standards.
     The adoption of emission limitations which may, in some areas of the
state, be overly restrictive (or not restrictive enough) resulted largely
from the use of the "example region" approach along with analyses which
considered the "hot spots" of an Air Quality Control Region (AQCR) rather than
the entire region.  This type of approach was offered in EPA guidelines for
plan development when states were preparing their original plans.  Many states,
through concurrence with EPA, adopted the example region approach, largely
because of the short timetable dictated by the Clean Air Act.  Also, in most
cases, the original SIPs were designed to attain and maintain the original
NAAQS, some of which have since been designated as "guides" only or actually
rescinded.  However, many states adopted and retained the original federal
standards or, in a few cases, adopted more restrictive state standards, and
these served as the bases on which their SIPs were approved.  As a result,
the requirements of many state plans conflict with legitimate national
energy concerns, and thus a review of the State Implementation Plans is a
logical follow-up to EPA's initial appraisal (1972) of the SIPs.  At the
time SIPs were approved by EPA if they demonstrated the attainment of the
original NAAQS or the 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 pol-
luted air quality control region and adopt control regulations which would be
adequate to attain the NAAQS in that region.  In using an example region, it
was assumed that NAAQS would be attained in the other AQCRs of the state if

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 the control regulations were applied to similar sources.  But use of an
 example region can result 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 example, a control strategy
 based on a particular region or source can result in a regulation requiring
 1 percent sulfur oil to be burned statewide, even though 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 deciding whether or not to revise portions of their State
 Implementation Plans.  However, it is most important for such states to
 recognize the limitations of the present review.  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
 judgement 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 was found,  however, it was used in the analysis.
     The data upon which the report's findings are based is that 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.   Therefore,
 those states desiring to revise a plan are encouraged to verify and,  in
many instances, expand the modeling and monitoring data used to support EPA's
 findings.   States are encouraged to consider the overall impact which the
potential relaxation of overly restrictive emissions regulations for
 combustion 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
                 X*
other potential air pollution situations.

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     Although the enclosed analysis has attempted to address the attainment

of all the NAAQS, most of the review has focused on total suspended

particulate matter (TSP) and sulfur dioxide  (SO,) emissions.  This is

because stationary fuel combustion sources constitute the greatest source

of SO- emissions and are a major source of TSP emissions.

     The following are the principle findings for the State of North Carolina.

(Air Quality Control Regions are displayed on Figure 1-1.)

     .  The state has adopted ambient standards for TSP and S02 which
        are equivalent to the original federal Secondary National
        Ambient Air Quality Standards.  Two of these standards for S02
        are no longer in effect at the federal level but still exist
        as state standards. Attainment of these state standards would
        require stricter emission controls than would attainment of
        the present federal NAAQS only.

     .  The state used the example region approach to develop both SO-
        and particulate emission regulations.  This approach was
        supplemented by rollback calculations at three locations where
        particularly high TSP levels were reported.

     .  Within the framework of this limited review, there appears to
        be little possibility for particulate emission regulation
        relaxation.  High particulate levels are being measured through-
        out most of the state.

     .  North Carolina's SO- emission regulation allows fuel switching
        and the simultaneous use of high and low sulfur fuels to meet
        the SO- emission limit.  A reduced emission limit is scheduled
        to be met in 1980.

     .  No SO- NAAQS violations were reported in North Carolina and
        there are indications of a significant state-wide capacity to
        absorb increased S02 emissions.

     .  Significant clean fuels savings could be realized in all AQCRs
        if regulations were relaxed and if higher sulfur fuels were
        available.

     .  Given the last three conclusions, the state of North Carolina
        could consider relaxation of its S02 emission regulations.
        However, even under the present regulations, many sources could
        utilize higher sulfur fuels than they presently burn.  Thus,
        the potential for clean fuel savings exists for some sources
        even within the present regulation.  An overall move to higher
        sulfur fuel use would require regulation revision.  The present
        lack of data indicates that a substantial modeling effort would
        be required to indicate to what extent?  if any, relaxation could
        be allowed.

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WESTERN
MOUNTAIN
INTRASTATE
 (#171)
            (#165)
            EASTERN
            MOUNTAIN
            INTRASTATE
                 (#136)
                NORTHERN
                PIEDMONT
                INTRASTATE
                 (#166)
                 EASTERN
                 PIEDMONT
                 INTRASTATE
    (#168)

    NORTHERN
    COASTAL
    PLAIN
    INTRASTATE
METROPOLITAN
CHARLOTTE
INTERSTATE
(NORTH CAROLINA-
SOUTH. QAROLINA)
SANDHILLS
INTRASTATE
 (#169)
SOUTHERN
COASTAL
PLAIN
INTRASTATE
 (#170)
           Figure 1-1.   North Carolina Air  Quality  Control Regions  (AQCRs)

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                                      10
        The generally poor particulate air quality suggests that
        allowing fuel switching from oil to coal would require
        careful consideration of the local and potential regional
        impact of any proposed switch.

        Present North Carolina regulations generally  require coal
        with less than 2% sulfur and oil with 2-3% sulfur at plants
        burning a single type of fuel.  (About 1% sulfur coal and
        1.51 sulfur oil by 1980.)  A significant amount of coal and
        oil is used in the state.  The major effect of regulation
        relaxation would be to allow the utilization of both higher
        sulfur coals and oils.
2.0  NORTH CAROLINA 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 demon-
        strating the attainment of NAAQS or_ more stringent state
        standards?

     .   Has the state 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?

     .   Is there an expected 1975 attainment date for NAAQS?

     .   Based on (1973) air quality data, are there 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 a relatively small portion of the regional total?

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                                       11
     .  Do modeling results for specific fuel combustion sources
        show a potential for a regulation revision?
     .  Is there a significant clean fuels savings potential in
        the region?
     .  Mist the regulations be revised to accomplish significant
        fuels switching?
     This SIP review has answered these questions based on an overall
evaluation of EPA's current information.  Based on these answers, each
AQCR has been assessed as a good, marginal, or poor candidate for regula-
tion relaxation.  An AQCR is assessed as a good candidate if the air
quality indicators show that the region has a tolerance to absorb increased
emissions and  if the source-by-source evaluations show that significant
clean fuels savings could be effected by such revision.  If the air quality
situation is such that no emission increase could be tolerated and/or
if the source evaluations show little or no clean fuel savings potential, then
the region is classified as a poor candidate for regulation revision.  If
the air quality or clean fuels evaluations are inconclusive or show conflict-
ing information, then the region is assessed as a marginal candidate for
regulation revision and a more detailed analysis is needed to resolve the
situation.  Table 2-1 summarizes the conclusions of this State Implementation
Plan Review and gives the overall candidacy assessment for each AQCR.

     2.2    Air Quality Setting for the State of North Carolina

     2.2.1  North Carolina Air Quality Control Regions
     The state of North Carolina is divided into eight Air Quality Control
Regions as shown on Figure 1-1.  There are seven intrastate regions and one
interstate region.  The Northern Piedmont Intrastate AQCR (#136) and the
Metropolitan Charlotte Interstate AQCR (#167) have significantly higher
population densities than the other regions in the state.  Based on present
conditions and growth projections for the state, Guildford and Forsyth
Counties in Northern Piedmont (#136) and Mecklenburg County in Metropolitan
Charlotte (#167) have been proposed as Air Quality Maintenance Areas (AQMAs)
for particulates as shown on Figure 2-1.

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Table 2-1.  State Implementation Plan Review Stmmary for North Carolina
                        State
Northern Piedmont
   AQCU# 136
Eastern Mountain
   AOCR# 165
Eastern Piedmont
  AQCRJL166
Metropolitan
Charlotte3
 AQCR* 167
"iNitrcATous"
• Does the State have air quality standards which are more
stringent than NAAQS?
• Does the State have emission limiting regulations for
control of:
1. Power plants
2. Industrial sources
3. Area sources
• Did the State use an example region approach for demon-
strating the attainment of NAAQS or more stringent State
standards?
•. Has the State 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 monitor-
ing sites within a region?
• Is there an expected 1975 attainment date for NAAQS?
• Based on (1973) Air Quality Data, are there reported
violations of NAAQS?
• Based on (1973) Air Quality Data, arc there indications
of a significant tolerance for increasing emissions?
• Are the emissions from stationary fuel combustion sources
a relatively small portion of the regional total?
• Do modeling results for specific fuel combustion sources
show a potential for a regulation revision?
• Is there a significant Clean Fuels Saving potential in
the region?
• Must the regulations be revised to accomplish signifi-
cant fuel switching?
• Based on the above indicators, what is the potential for
revising fuel combustion source emission limiting
regulations?
TSI1 S02
No
Yes
Yes
Yes
Yes
No






NA
Yes
Yes
Yes
Yes
Yes
No






NA



TSP S02


b

Yes
Yesc
Yes
Y-s
No
No
NA




No
Yes
Yes
No
Yes
No
NA
Yes
Yes
TSP - Poor
S02 - Marginal
TSP Sf>2




No
Yesc
Yes
Yesd
'No
No
NA




No
Yesc
Yes
Nod
Yes
No
NA
Yes
Yes
TSP - Poor
S02 - Marginal
TSP S02




No
Yesc
Yes
Yes
No
No
NA




No
Yes
Yes
No
Yes
No
NA
Yes
Yes
TSP - Poor
S02 - Marginal
. TSP SO,




Example
Region

Yes
Y*,c
Yes
Yes
No
No
NA

No
Yes
Yes
No
Yes
No
NA
Yes
Yes
TSP - Poor
SC>2 - Marginal

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                                   Table  2-1.  State  Implementation Plan Review Summary for North Carolina (Contd.)
                                                           Northern Coastal
                                                                Plain
                                                              AQCM 168
Sandhills
AQCRff 169
Southern Coastal
     Plain
   AQCR0 170
Western Mountain
   AQCRff 171
"INWCATOkS"
• Docs the State have- air ijuaJity standards wliicli arc more
stringent than NAAQS?
• Docs the State have emission limiting regulations for
control of:
1. Power plants
2. Industrial .sources
3. Area sources
• Did the State use an example region approach for demon-
strating the attainment of NAAQS or more stringent State
standards?
• Has the State 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?
• Arc there indications of a sufficient number of monitor-
ing sites within a region?
• Is there an expected 1975 attainment date for NAAQS?
• Based on (1973) Air Quality Data, are there reported
violations of NAAQS?
• Hasixl on (I'J73J Air Quality Data, arc there indications
of a significant tolerance for increasing emissions?
• Arc the emissions from stationary fuel combustion sources
a relatively small portion of the regional total?
• Do modeling results for specific fuel combustion sources
show a potential for a regulation revision?
• Is there a significant Clean Fuels Saving potential in
the region?
• Must the regulations be revised to accomplish signifi-
cant fuel switching?
• Based on the above indicators, what is the potential for
revising fuel combustion source emission limiting
regulations?
•rsi1 so2




No
Yesc
Yes
Yesd
No
Yes
NA




"' No
Yes
Yes
•No
Yes
No
NA
Yes
Yes
TSP - Poor
SCL - Marginal
TSI' SO,
z




No
Yesc
Yes
Yesd
No
Yes
NA




No
Yesc
Yes
Nod
Yes
No
NA
Yes
Yes
TSP - Poor
S02 - Marginal
TSI' S<>2




No
Yesc
Yes
Yesd
'No
Yes
NA




No
Yesc
Yes
Nod
Yes
Nc
NA
Yes
Yes
TSP - Poor
S02 - Marginal
TSP S02


b

No
Yesc
Yes
Yesd
No
No
NA




No
Yesc
Yes
Nod
Yes
No
NA
Yes
Yes
TSP - Poor
S02 - Marginal
 Interstate.
 Example region modeling supplemented by rollback at high TSP stations in this region.

GThere is a sufficient number of sites but not all of them are reporting an annual average.

 ito annual data.

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                                                                                .    .  ILMINGTON
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                                                                                WILMING
            LEGEND
®   Places of 100.000 or more inhabitants

•    Places of 50,000 to 100,000 inhabitants

D    Central cities of SMSA's with fewer than 50,000 inhabitants

O    Places of 25,000 to 50,000 inhabitants outside SMSA's
            Standard Metropolitan
             Statistical Areas (SMSA's)
                                    TSP  DESIGNATION
                                                               SCALE



                                                         O  IO  2O 3O
                                                                                                                 )	SO MILES
      Figure 2-1.   Proposed  North Carolina Air  Duality  Maintenance Areas
                                                      (AQMAs)

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                                     15
     2.2.2  North Carolina Ambient Air Quality Standards
     All the federal primary and secondary National Ambient Air Quality
Standards for participates, sulfur dioxide, and nitrogen dioxide apply in
North Carolina.  In addition, the state retains annual and 24-hour sulfur
dioxide standards equivalent to federal secondary standards which have been
rescinded by EPA.  These state S02 standards are more stringent than the
present federal primary standards.  North Carolina also has a 24-hour nitrogen
dioxide standard which can be more stringent than the federal standard.
North Carolina air quality standards are summarized on Table 2-2.   This  review
considers only the attainment of the federal NAAQS.

      2.2.3  North Carolina Air Quality Status
      Based on data in the SAROAD data banks as of June, 1974, both the  annual
 and 24-hour particulate NAAQS were being violated in the Northern Piedmont
 (#136), Eastern Piedmont (#166), and Metrpolitan Charlotte (#167)  AQCRs.
 Annual average data is unavailable for Eastern Mountain (#165), Northern
 Coastal Plain (#168), Sandhills (#169) , Southern Coastal Plain (#170) and
 Western Mountain (#171).   Each of these six regions, however, was  recording
 violations of the short-term particulate standards.  Since all regions  are
 significantly above the NAAQS, there are regional indications that overall
 relaxation of particulate regulations would not be possible without disrupting
 NAAQS attainment or maintenance.
      No SCL NAAQS violations were reported in  any of North Carolina's eight
 AQCRs.  However, no annual average data were available from the Eastern
 Mountain (#165), Sandhills (#169), Southern Coastal Plain (#170),  and
 Western Mountain (#171) regions.  There are thus indications based on regional
 air quality that a significant tolerance for increased SCL emissions exists
 throughout North Carolina.

      2.2.4  North Carolina Emissions Summary
      In the eight AQCR region, emissions from  North Carolina fuel combustion
 account for about half of the total particulate and almost 901 of the total
 S02 emissions.  There are no power plants in the Northern Coastal Plain AQCR
 (#168).

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                            Table  2-2.  North Carolina Ambient Air Quality Standards
                                   All  concentrations  in

Federal

State

Primary
Secondary
!
Total Suspended
Annual
75(G)
60 (G)
60 (G)
Particulate
24 -Hour
260a
150a
150a
Sulfur Oxides
Annual 24 -Hour 3 -Hour
80 (A) 365a
— —
60(A)b 260a'b
—
1300a
1300a
Nitrogen
Annual
100 (A)
100 (A)
100 (A)
Dioxide
24 -Hour
—
—
250a
Ttot to be exceeded more than once per year.
 was adopted based on original EPA policy which was  rescinded July, 1973.
(A)  Arithmetic mean
(G)  Geometric mean

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                                   17
     The largest fraction of particulate emissions from fuel burning in
North Carolina comes from electricity generation in the Eastern Piedmont
(#166), Metropolitan Charlotte (#167), and Southern Coastal Plain  (#170)
AQCRs.  Industrial/commercial/institutional point sources contribute the
largest fraction in the Northern Coastal Plain (#168) and Western Mountain
(#171) regions while area sources are the largest contributors in Northern
Piedmont (#136) and Sandhills (#169).  In the Eastern Mountain (#165) region,
both electricity generation and area sources emit large portions of  the
particulates from fuel combustion.
     The largest fraction of the SCL emissions from fuel combustion  in North
                                   Lt
Carolina comes from electricity generation in the Northern Piedmont  (#136),
Eastern Mountain (#165), Eastern Piedmont (#166) , and Metropolitan
Charlotte (#167) AQCRs and from industrial/commercial/institutional point
sources in the Northern Coastal Plain (#168) and Western Mountain  (#171)
AQCRs.  Electricity generation, industrial/commercial/institutional point
sources, and area sources each contribute about the same fraction of
SCL emissions from fuel combustion in the Sandhills (#169) region.   In
the Southern Coastal Plain (#170) region, both electricity generation
and industrial/commercial/institutional point sources emit about the same
amount of SCL and substantially more than area sources.

     2.3    Background on the Development of the  Current State Implementation
            Plan

     2.3.1  General Information
     The example region approach was used to develop the North Carolina State
Implementation Plan.   Metropolitan Charlotte AQCR (#167)  was designated as
the example region.  The Air Quality Display Model was used to demonstrate
the sufficiency of the regulations to meet the SCL and particulate annual
secondary NAAQS. (At that time, the annual and 24-hour secondary NAAQS for S02
were still in effect at the federal level.)  At one or more sites in the
Northern Piedmont (#136)  and Western Mountain (#171)  AQCRs, particulate
concentrations higher than those in Metropolitan  Charlotte (#167)  were recorded.
Rollback calculations were used at these sites to demonstrate the sufficiency
of the proposed regulations.   Considerations of expected growth over a five

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                                     18
year period in Nfetropolitan Charlotte indicated that the standards woul be
maintained.  The sufficiency of the regulations for attainment and maintenance
for the 24-hour participate and S09 and the 3-hour SCL standards was not
                                  &                  L
demonstrated.

     2.3.2  Particulate Control Strategy
     The control strategy for particulate emissions from fuel combustion
sources consists of enforcement of Section II, Regulation No. 2 for visible
emissions and Section IV, §1.10 for particulate matter emissions from fuel
burning sources of the Regulations Governing the Control of Air Pollution of
the North Carolina Board of Water and Air Resources.  These regulations were
 designed to meet the annual secondary NAAQS throughout North Carolina.
They apply to area sources as well as point sources.  Pertinent portions
of these regulations are summarized on Table 2-3 and Figure 2-2.

     2.3.3  Sulfur Dioxide Control Strategy
     Section  IV,   §2.40 of the Regulations Governing the Control of Air
Pollution contains the emissions  limits whose  enforcement consitutes the
S02 control strategy.  These limitations are summarized on Table 2-3.
All sources,  including area sources, are subject to regulations, designed
to ensure attainment of the old annual secondary NAAQS for S09 throughout
                                                             £
the state.   (These standards have been rescinded at the federal level but
remain state  standards.)  For sources existing on July 1, 1971, a more
restrictive standard, equivalent  to the standard for new sources, applies
after July 1, 1980 than applies between 1971 and 1980.  The regulation
allows the mixed firing of high and low sulfur fuels to meet the emission
limit.

     2.4    Special Considerations for the State of North Carolina

     2.4.1  Planned SIP Revisions

     North Carolina is not presently considering changings its  State
Implementation Plan with respect to fuel  combustion sources.

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                         Table 2-3.  North Carolina Fuel Combustion Emission Regulations
                                Existing
                                                                        New
Visible
No emission shall be darker than Ringelmann #2
or equivalent spacity for more than 5 min. in
any one hour or for more than 20 min. in any
24-hour period.
On July 1, 1976, the standard for new sources
shall apply.
                                     No  emission shall be darker  than Ringelmann #
                                     or  equivalent opacity  for more  than 5  min.  in
                                     any one hour or  for more than 20 min.  in any
                                     24-hour period.
                                          Maximum Allowable
                                     j      Emission of
                           Heat Input    Particulate Matter
                           (106 Btu/hr)   (lb-hr/106 Btu)
Particulate
Matter0
Up to and
including
      10
     100
   1,000
> 10,000
0.60
0.33
0.18
0.10
                                                             Same as existing units,
             Between the values listed see Figure A-l.
   SO,
2.3 Ib SCL/106 Btu input per hour6

Existing sources must meet the new source
standard by July 1, 1980 unless a source
demonstrates that ambient air quality stan-
dards in its vicinity will not be contravened.
                                                               1.6 Ib S02/106 Btu input per hour
Constructed after July 1, 1975.

 Exceptions exist during startups using approved procedures or where uncombined water vapor is the only  reason
 for failure to comply.

""Applies to fuels such as coal, coke, lignite and fuel oil, but not wood or refuse.  Separate emission limits
 apply for wood and refuse.

'Total heat input of all fuel burning units in a plant is used to determine maximum allowable emission.
Q
 Lower limit could apply if violations of ambient air quality standards due to a specific source were demonstrated.

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CO
D
o
 to
-Q
 CO
 CO
                                                                                                            TEE
     i.o
3  OJ
o
                                                                                                                        ts)
                                                                                                                        O
                            10
                                               100
1000
10,000
100,000
                                              HEAT  INPUT   (10  BTU/hr)
            Figure 2-2.  Allowab~9 Particulate Emissions from Fuel Combustion Sources in North Carolina

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                                     21
    2.4.2  Fuels
    Compared to large industrialized states, North Carolina is not a large
fuel user.  Coal is the primary fuel in power plants.  Several power plants,
including the large new Belews Creek units, are coal-fired and state-wide
about 60% of the heat input for industrial/coiranercial/institutional point
sources comes from oil and about one-third from coal.  For area sources,
over half the heat input comes from gas and about 40% from oil.

    2.4.3  Fuel Conversions
    The Federal Energy Adminstration has identified the Sutton power plant
in the Southern Coastal Plain (#17) AQCR as having the potential to shift
from oil tocoal.  Due to the indicated poor particulate air quality, such
a change would require careful investigation of the possible effects on
attaining and maintaining the particulate NAAQS.

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   TECHNICAL REPORT DATA
read lmuui:tto>i<; on the reverse hi. ion- c
                                                              tmgf
 1. PEPOHT NO.

  EPA-45Q/3~75-03Q
   iTLE AN6 SUBTITLE
  IMPLEMENTATION PLAN REVIEW FOR NORTH  CAROLINA
  REQUIRED BY THE ENERGY SUPPLY AND ENVIRONMENTAL
  COORDINATION ACT
                                                            3. RECIPIENT'S ACCESSIOI^NO.
                           5. REPORT DATE
                           6. PERFORMING ORGANIZATION CODE
 7. AUTriOfllS)
                                                            8. PERFORMING ORGANIZATION REPORT NO
 9. PERFORMING ORGANIZATION NAME AND ADDRESS^
                                                            1C. PROGRAM ELEMENT NO.
  U.S.  Environmental Protection Agency, Office of Air

  Quality Planning and  Standards, Research Triangle Park
  N.C.  Region IV Office, Atlanta, Ga., and Argonne
  National Laboratory,  Argonne, Til.	
                           11. CONTRACT/GRANT NO.
 12. SPONSORING AGENCY NAME AND ADDRESS
                                                            13. TYPE OF REPORT AND PERIOD COVERED
  U.S.  Environmental Protection Agency
  Office of Air and Waste Management
  Office of Air Quality Planning and Standards
  Research Triangle Park. N.C.   27711	
                           14. SPONSORING AGENCY CODE
 15. SUPPLEMENTARY NOTES
 16. ABSTRACT
       Section IV of the Energy Supply and Environmental Coordination Act of 1974,
  (ESECA)  requires EPA to review each State Implementation  Plan  (SIP) to determine
  if revisions can be made to  control regulations  for stationary  fuel combustion
  sources  without interfering  with the attainment  and maintenance of the national
  ambient  air quality standards.   This document, which is also required by Section
  IV of ESECA, is EPA's report to the State indicating where regulations might be
  revised.
 7.
                                KEY WORDS AND DOCUMENT ANALYSIS
                  DESCRIPTORS
    Air pollution
    State Implementation  Plans
                                              b.lDENTIFIERS OPEN ENDED TERMS
                                         c. COSATI I loki Group
 3. DISTRIBUTION STATEMENT

     Release unlimited
              19. SECURITY CLASS ( This Report)
21. NO. OF PAGES
   21
                                              20. SECURITY CLASS (This pjgf)

                                                 Unclassified
                                         22. PRICE
EPA Form 2220-1 (9-73)

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