EPA-450/3-75-033
March 1975
IMPLEMENTATION PLAN REVIEW
FOR
MINNESOTA
AS REQUIRED
BY
THE ENERGY SUPPLY
AND
ENVIRONMENTAL COORDINATION ACT
U. S. ENVIRONMENTAL PROTECTION AGENCY
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EPA-450/3-75-033
IMPLEMENTATION PLAN REVIEW
FOR
MINNESOTA
REQUIRED BY THE ENERGY SUPPLY AND ENVIRONMENTAL COORDINATION ACT
PREPARED BY THE FOLLOWING TASK FORCE:
U.S. Environmental Protection Agency, Region V
230 S. Dearborn
Chicago, Illinois 60604
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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MINNESOTA
ENERGY SUPPLY AND ENVIRONMENTAL COORDINATION ACT
SECTION IV - STATE IMPLEMENTATION PLAN REVIEW
Table of Contents
Page
1.0 EXECUTIVE SUMMARY 5
2.0 MINNESOTA STATE IMPLEMENTATION PLAN REVIEW 11
2.1 Summary 11
2.2 Air Quality Setting for the State of Minnesota 12
2.3 Background on the Development of the Current
State Implementation Plan 18
2.4 Special Considerations for the State of Minnesota 20
3.0 AIR QUALITY CONTROL REGION ASSESSMENTS 21
3.1 General Methodology 21
3.2 Central Minnesota Intrastate AQCR (#127) 23
3.3 Southeast Minnesota-LaCrosse Interstate AQCR (#128).. 23
3.4 Duluth-Superior Interstate AQCR (#129) 24
3.5 Metropolitan Fargo-Moorhead Interstate AQCR (#130)... 24
3.6 Minneapolis-St. Paul Intrastate AQCR (#131) 24
3.7 Northwest Minnesota Intrastate AQCR (#132) 25
3.8 Southwest Minnesota Intrastate AQCR (#133) 25
TECHNICAL APPENDICES
APPENDIX A - State Implementation Plan Background
APPENDIX B - Regional Air Quality Assessment
APPENDIX C - Power Plant Assessment
APPENDIX D - Industrial, Commercial, Institutional Point
Source Assessment
APPENDIX E - Area Source Assessment
APPENDIX F - Fuels Assessment
REFERENCES
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STATE IMPLEMENTATION PLAN REVIEW
FOR
THE STATE OF MINNESOTA
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 information
on excessively restrictive control regulations. The intent of ESECA is that
wherever possible SIP's be revised in the interest of conserving low sulfur
fuels or converting sources which burn oil or natural gas to coal. EPA's ob-
jective 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 alloca-
tions can be altered for "clean fuel savings" in a manner consistent with both
environmental and national energy needs.
In many respects, the ESECA SIP reviews parallel EPA's policy on clean
fuels. The Clean Fuels Policy has consisted of reviewing implementation plans
with regards to saving low sulfur fuels and, where the primary sulfur dioxide
air quality standards were not exceeded, to encourage states to either defer
compliance with regulations or to revise 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.
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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 S02 regulations. These states are
generally in the Eastern half of the United States. ESECA, however, extends
the analysis of potentially over-restrictive regulations to all 55 states
and territories. In addition, the current reviews address the attainment
and maintenance of all the National Ambient Air Quality Standards.
There are, in general, three predominant reasons for the existence of
overly restrictive emission limitations within the State Implementation Plans.
These are: 1) the use of the example region approach in developing state-
wide air quality control strategies; 2) the existence of State Air Quality
Standards which are more stringent than NAAQS; and 3) the "hot spots" in
only part of an Air Quality Control Region (AQCR) which have been used as
the basis for controlling the entire region. Since each of these situations
affect many state plans and in some instances conflict with current national
energy concerns, a review of the State Implementation Plans is a logical
follow-up to EPA's initial appraisal of the SIP's conducted in 1972. At that
time SIP's were approved by EPA if they demonstrated the attainment of NAAQS
or_ more stringent state air quality standards. Also, at that time an accept-
able method for formulating control strategies was the use of an example region
for demonstrating the attainment of the standards.
The example region concept permitted a state to identify the most polluted
air quality control region (AQCR) and adopt control regulations which would be
adequate to attain the NAAQS in that region. In using an example region, it
was assumed that NAAQS would be attained in the other AQCR's of the state if
the control regulations were applied to similar sources. The problem with the
use of an example region is that it can 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 where the use of 3 percent sulfur
coal would be adequate to attain NAAQS in some locations.
EPA anticipates that a number of states will use the review findings to
assist them in deciding whether or not to revise portions of their State Imple-
mentation Plans. However, it is most important for those states which desire
to submit a revised plan to recognize the review's limitations. The findings
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of this report are by no means conclusive and are neither intended nor adequate
to be the sole basis for SIP revisions; they do, however, represent EPA's best
judgment and effort in complying with the ESECA requirements. The time and
resources which EPA has had to prepare the reports has not permitted the con-
sideration 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 quality air. 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 combustion sources might have on their future control programs.
This may include air quality maintenance, prevention of significant deteriora-
tion, increased TSP, NOX, and HC emissions which occur in fuel switching, and
other potential air pollution situations 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 (SC>2) emissions. This is because stationary
fuel combustion sources constitute the greatest source of 862 emissions and
are a major source of TSP emissions.
Part of each state's review was organized to provide an analysis of the
S02 and TSP emission tolerances within each of the various AQCR's. The regional
emission tolerance estimate is, in many cases, EPA's only measure of the "over-
cleaning" accomplished by a SIP. The tolerance assessments have been combined
with other regional air quality "indicators" in an attempt to provide an
evaluation of a region's candidacy for changing emission limitation regulations.
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In conjunction with, the regional analysis, a summary of the state's fuel com-
bustion sources (power plants, industrial sources, and area sources) has also
been carried out.
The following are the principle findings for the State of Minnesota.
(Air Quality Control Regions are displayed in Fig. 1-1.)
. The state has adopted the Federal National Ambient Air Quality
Standards for particulates and nitrogen dioxide but has adopted
more stringent standards for SC>2. Attainment of the state SCL
standards would require stricter emission controls than would
attainment of the federal NAAQS only.
. The statewide regulations for particulates and SC^ are based on
the example region approach. Minnesota has not initiated any
changes in the SC>2 regulations under EPA's Clean Fuels Policy.
. Within the framework of this review there appears to be
little tolerance throughout the state for increased particulate
emissions and hence for relaxation of particulate emissions
regulations. This is based on high particulate readings (based
on 1973 data) and several proposed Air Quality Maintenance Area
designations. In Central Minnesota (#127), the only region for
which high particulate levels are not being recorded, regulations
are just barely being met and any particulate emission regulation
relaxation may jeopardize attainment of NAAQS.
For SO 2 there are indications of a substantial margin for increased
S02 emissions in all regions except Minneapolis-St. Paul (#131).
Despite the indications, Central Minnesota (#127), Metropolitan
Fargo-Moorhead (#130), Northwest Minnesota (#132), and Southwest
Minnesota (#133) are rated as having poor potential for SC^
regulation relaxation. This conclusion is based on the fact that
the majority of plants in the region are small and/or there is lit-
tle potential for clean fuel savings. (It should be noted that for
all regions except Minneapolis-St. Paul (#131), small plants
(< 250 x 106 Btu/hr heat input) are unregulated. Southeast Minn-
esota-La Crosse (#128) has some potential for clean fuel savings.
Although the small plants are unregulated in this region, the large
Fox Lake plant has been identified by the Federal Energy Administration
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as having the potential to switch from oil to coal burning
leading to some overall savings of low sulfur oil. Several
large plants are present in the Duluth-Superior region (#129),
but modeling should be performed before any conclusions are
reached regarding clean fuel savings potential. Hence, the
marginal rating for regulation revisions in this region.
For Minneapolis-St. 'Paul (#131) some regulation relaxation
might be possible despite the high S09 levels. This conclusion
£t
is based on the modeling results which indicate that the state's
largest power plant, the A. S. King plant, has the potential
of switching to high sulfur coal leading to a substantial
savings of lower sulfur coal.
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10
(#132)
NORTHWEST
MINNESOTA
INTRASTATE
(#130)
METROPOLITAN'
FARGO-MOORHEAD
INTERSTATE
(NORTH DAKOTA-
MINNESOTA)
(#129)
DULUTH-
SUPERIOR
INTERSTATE
(MINNESOTA-
iNSIN)
(#133)
SOUTHWEST
MINNESOTA
INTERSTATE
(#127)
CENTRAL
MINNESOTA
INTRASTATE
(#131)
MINNEAPOLIS-
ST. PAUL
INTRASTATE (#128)
SOUTHEAST
MINNESOTA-
LA CROSSE
INTERSTATE
WISCONSIN)
Figure 1-1. Minnesota Air Quality Control Regions
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11
2.0 MINNESOTA 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?
. 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?
. 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?
. Must the regulations be revised to accomplish significant
fuels switching?
The following portion of this report is directed at answering these
questions. An AQCR's potential for revising regulations increases when there
are affirmative responses to the above.
The initial part of the SIP review report, Section 2 and Appendix A, is
organized to provide the background and current situation information for the
State Implementation Plan. Section 3, and the remaining Appendices provide an
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12
AQCR analysis which helps establish the overall potential for revising regu-
lations. An evaluation of regional air quality indicators is presented in
Appendix B; power plants, industrial sources, and area sources are analyzed
in Appendices C, D, and E, respectively.
Based on an overall evaluation of EPA's current information, AQCR's have
been classified as good, marginal, or poor candidates for regulation revisions,
Table 2-1 summarizes the State Implementation Plan Review. The remaining
portions of the report support this summary with explanations.
2.2 Air Quality Setting for the State of Minnesota
2.2.1 Minnesota Air Pollution Control Areas
The State of Minnesota is divided into seven Air Quality Control Re-
gions (AQCRs) as shown in Fig. 1-1: four intrastate and three interstate.
Table A-l gives the pollutant priority classifications for each of these
regions. The table also shows population to be highest in Minneapolis-
St. Paul (AQCR #131). A population center also exists in the City of
Duluth in Duluth-Superior (AQCR #129). Based on present conditions and
growth projections for the state, all seven counties in the Minneapolis-
St. Paul AQCR (#131) have been proposed as Air Quality Maintenance Areas
(AQMAs) for both particulates and S02- In addition, the City of Duluth in
the Duluth-Superior AQCR (#129) has been proposed as a AQMA. for particulates.
These are indicated in Table A-l and Fig. A-l.
2.2.2 Minnesota Ambient Air Quality Standards
As shown in Table A-2, Minnesota has adopted the federal primary and
secondary National Ambient Air Quality Standards (NAAQS) for particulates
and nitrogen dioxide. For sulfur oxides, Minnesota has adopted both pri-
mary and secondary standards which are more stringent than the federal stand-
ards. The following analysis will address attainment of the federal NAAQS
only.
2.2.3 Minnesota Air Quality Status
The current air quality status in Minnesota is summarized in Table A-3
for particulates and Table A-4 for S02. The data is from the SAROAD data
bank as of June, 1974.
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TABLE 2-1. State Implementation Plan Review Summary for Minnesota
Southeast
* Central
Minnesota
State . AQCRft 127 AQCW) 128
Minnesota-
LaCrosse
Duluth-
Superior8
129
Metropolitan
Fargo-Moorhead3
AQCR* 130
" INDICATORS"
e Docs the State have air quality standards which are more
stringent than NAAQS?
9 Docs the State have emission limiting regulations for
control of: . . .
1. Power plants
2. Industrial sources '
3. Area sources
• Did the State use ;m example, region approach for demon-
strating the attainment of NA/YJS 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 Puels Policy?
o Arc there no 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?
o Based on (1973) Air Quality Data,, arc there no reported
violations of NAAQS?
. » Based on (1973) Air Quality .Data, are there indications
of a significant tolerance for increasing emissions? .
o Are the emissions from stationary fuel combustion sources
• a relatively small portion of the regional total?
•« Tjfc modeling results for specific fuel combustion sources
"ishow a potential for a regulation revision?
o Is there a significant Clean Fuels Saving potential in
the region?
e Must the regulations be revised to accomplish signifi-
cant fuel switching?
e Based on the above indicators', what is the potential for
revising fuel combustion source emission liniting
regulations? f
'INI' S(>2
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes'
Yes
Yes
Yes
Yes
TSI' S02
.
Yes
Yes
Yes
Yes
No
No
N.A.
Yes
Yes
Yes
Yes
Yes
No
N.A.
No
No
TSP - Poor
S02 - Poor
•TSI' S02
Yes
Yes
Yes
No
Mo
Yes
N.A.
Yes
Yes
Yes
Yes
Yes
>Yes
No
YesC
Yes
TSP - Poor
S02 - Marginal
TSP a>2
Keg ion
Priority
No
Yes
Yes
No
No
No
N.A.
Yes
Yes
Yes
Yes
Yes
No
Nod
Nod
No
TSP - Poor
S02 - Marginal*1
TSI' S02
NoD
Yes
Yes
No
No
Yes
N.A.
Yes
Yes
Yes
Yes
Yes
No
N.A.
No
No
TSP - Poor
S02 - Poor
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TABLE 2-1. State Implementation Plan Review Sunmary for Minnesota (Contd.)
Minneapolis-
St. Paul
AQCRff 131
Northwest
Minnesota
AQCRf 132
Southwest
Minnesota
AQCR3 133
"INWIAIUKS"
e Docs the State have air qinjity standards which are niorc
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 not initiated action to modify combustion
source emission regulations for fuel savings; i.e.,
under the Clean l;ucls .Pol icy?
• Are there no 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 no reported
violations of NAAQS?
o Based on (1973) Air Quality Data, are 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?
o Must the regulations be revised to accomplish signifi-
cant fuel switching?
o Based on the above indicators, what is the potential for
revising fuel combustion source emission limiting
. regulations? £
•iv,i- sc>2
Example Region
Priority I
No
Yes
Yes
Np
No
No
N.A.
No
Yes
Yes
No
. No
No
Yes
Yes
Yes
TSP - Poor
SO - Marginal
TSI' SO,
I*
Yes
Yes
Yes
No
No
No
N.A.
Yes
No
Yes
Yes
Yes
No
N.A.
No
No
TSP - Poor
S02 - Poor
TSi' sn2
Yes
Yes
Yes
No
Mb
No
N.A.
Yes
No
Yes
Yes
Yes
\ "*>
N.A.
No
No
TSP - Poor
S02 - Poor
TSI' S02
•rsi« so2
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TABLE 2-1. State Implementation Plan Review Summary for Minnesota (contd.)
Footnotes
Interstate
There is a proposed AQMA in the North Dakota portion of the region.
p
Based on the fact that the Fox Lake plant has been identified by the F.E.A. as having the potential for
switching from oil to coal.
cme Clay Boswell power plant, which will have the second highest capacity in the state by 1975, has not
been modeled and is presently using low sulfur fuel. Modeling would be required to determine if high sulfur
fuel is useable.
Q
The marginal rating for revising SC^ regulations is given since modeling results indicated that only the
A. S. King power plant (the state's largest plant) has the potential for switching to high sulfur coal.
Good - Air quality indicators show a tolerance to absorb increased emissions and source-by-source evaluations
show a significant clean fuels saving potential.
Poor - Mr quality indicators show little or no tolerance to absorb increased emissions and/or source
evaluations indicate little or no clean fuels saving potential.
Marginal - Air quality and clean fuels savings evaluations are inconclusive or conflicting. More detailed
analysis needed.
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16
Based on the data in Table A-3, only Central Minnesota (#127) is not
showing violations of the particulate standards. Indications are that
severest problems are in Minneapolis-St. Paul (#131), Metropolitan Fargo-
Moorhead (#130), and Duluth-Superior (#129). Particulate AQMAs have been
proposed for all seven counties in the Minneapolis-St. Paul AQCR (#131), for
the City of Duluth in the Duluth-Superior AQCR (#129), and in one county in
the North Dakota portion of the Fargo-Moorhead AQCR (#130). These proposals
are consistent with the measured air quality for the three regions. Overall,
the indications are that there is little room for particulate regulation
relaxation in Minnesota.
Only Minneapolis-St. Paul (#131) is presently reporting violations of
S09 ambient standards and is ,thus the only region, for which data exists,
L*
that does not indicate some tolerance for increased S02 emissions based on
regional air quality. However, the S02 emissions data available from both
Northwest Minnesota (#132) and Southwest Minnesota (#133) is based in each
case on only one 24-hour monitoring station. All seven counties in the
Minneapolis-St. Paul AQCR (#131) have been proposed as AQMAs for S02. This
proposal is consistent with the measured S02 levels for this region. Hence,
except for Minneapolis-St. Paul (#131), the other six AQCRs show an apparent
ability to absorb increases in S02 emissions. Care must be exercised, how-
ever, because of the paucity of monitoring stations in Northwest (#132) and
Southwest (#133) Minnesota. Overall, this is encouraging from the perspective
of clean fuels conservation.
2.2.4 Minnesota Emissions Summary
Emission sources and emission rates are tabulated in Tables A-5 to A-8.
Indications are that all of the regions with the exception of Central Min-
nesota (#127) require reductions in particulate emissions in order to meet
NAAQS. The implication is that any particulate relaxation for fuel combus-
tion sources in areas other than Central Minnesota (#127) should be accom-
panied by a corresponding regulation tightening on other sources in order
to achieve the necessary reduction in emissions. Caution must be exercised
in regard to particulate relaxation even in Central Minnesota (#127), since
this region is just barely meeting NAAQS according to the data in Table A-8.
Minnesota fuel combustion sources account for less than 40% of the par-
ticulate emissions in the seven AQCR area according to the data in Table A-5.
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17
In Central Minnesota (#127) and Southeast Minnesota-La Crosse (#128), Min-
nesota fuel combustion sources contribute more than half of the particulate
emissions. Minnesota electricity generation contributes substantially more
particulate matter than either Minnesota industrial/commercial/institutional
point sources or Minnesota area sources in only Minneapolis-St. Paul (#131)
and Southwest Minnesota (#133). Minnesota industrial/commercial/institutional
point sources are the largest Minnesota contributors in Metropolitan Fargo-
Moorhead (#130) and Northwest Minnesota (#132). Minnesota area sources are
proportionally the largest Minnesota particulate sources in Central Min-
nesota (#127) and Southeast Minnesota-La Crosse (#128). Minnesota electric-
ity generation and industrial/commercial/institutional point sources are
roughly equivalent and greater Minnesota contributors to particulate emis-
sions than Minnesota area sources in Duluth-Superior (#129).
Most (70%) of the S02 emitted in the seven AQCRs comes from Minnesota
fuel combustion sources. Only in Minneapolis-St. Paul (#131) does a major
portion of the Minnesota SCU emissions come from electricity generation. In
Central Minnesota (#127), Southeast Minnesota-La Crosse (#128), Metropolitan
Fargo-Moorhead (#130), Northwest Minnesota (#132), and Southwest Minnesota
(#133), the major Minnesota contributors to SO^ emissions are the Minnesota
area sources. A major portion of the Minnesota SC^ emissions comes from
Minnesota industrial/commercial/institutional point sources only in Duluth-
Superior (#129). The rollback calculations displayed in Table A-8, indicate
that all regions, except Minneapolis - St. Paul (#131) can tolerate SC^ emis-
sion increases. In five of the AQCRs - Central Minnesota (#127), Duluth-
Superior (#129), Minneapolis-St. Paul (#131)., Northwest Minnesota (#132)
and Southwest Minnesota (#133) - Minnesota fuel combustion sources make up
no less than 80% of the SCU emissions (Table A-5). In these regions in par-
ticular any SC^ emissions regulation relaxation should proceed cautiously to
avoid jeopardizing NAAQS maintenance. In Southeast Minnesota-LaCrosse (#128),
Minnesota fuel combustion sources make up less than 30% of the SC>2 emissions.
In this region, any relaxation of regulations for Minnesota fuel combustion
sources should be coordinated with revisions in the regulations in Wisconsin.
Also, although Minnesota fuel combustion contribute 67% of the SC^ emissions
in Metropolitan Fargo-Moorhead (#130), any regulation relaxation should be
coordinated with North Dakota regulation revisions since one county in the
North Dakota portion of this region has been proposed as an AQMA.
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18
2.3 Background on the Development of the Current
State Implementation Plan
2.3.1 General Information
For Minnesota, two methods were used to relate emissions to air qual-
ity. The first was the use of the Air Quality Display Model (AQDM). The
second was the use of the proportional model (rollback), described in the
Federal Register Guidelines.
The AQEM uses annual emission data and annualized meteorological data
to determine annual means of pollutant concentrations through a computer
program. The AQEM was developed for use with particulate and sulfur dioxide
air pollutants. It is generally applied to Priority I Regions. The Min-
neapolis-St. Paul AQCR (#131) is Priority I for these two pollutants. The
AQEM was used to test strategies for sulfur dioxide and particulate air pol-
lutants in the Minneapolis-St. Paul AQCR (#131).
The control plan must apply to the entire state. It was, therefore,
desirable to include more than just one region in the analysis. The Duluth-
Superior AQCR (#129) was chosen for further tests. It is classified Priority
I for particulates. The Duluth emission inventory was not gridded for use'
by the AQEM. Therefore, testing for particulates was done by use of the pro-
portional model.
2.3.2 Particulate Control Strategy
For development of a control strategy to attain and maintain the ambient
air quality standards for particulates, the AQEM was first calibrated. Two
strategies were decided upon for testing in the AQEM. The first strategy
involved the application of existing particulate emission regulations to all
emissions listed in the 1970 Inventory. These re-calculated emissions were
then tested in the AQEM. Net growth of existing particulate emission levels
within the Minneapolis-St. Paul AQCR (#131) during the period of 1970 to
1975 was calculated to be negligible due to the fact of over-control of many
major sources under recently accepted compliance schedules.
The second strategy involved the application of federally proposed par-
ticulate emission regulations to all emissions listed in the 1970 inventory.
The calculated emissions were then tested in the AQEM.
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19
Results of the two strategy tests on an annual basis supported the need
to retain the existing particulate emission limitations. The region was
then examined for acceptable air quality under the 24-hour ambient air qual-
ity standards. Again, the proportional model was employed and the strategy
test was based around the second highest station reading as called for by
the ambient air standard. The percent reduction in emissions calculated was
required by the strategy to assure attainment and maintenance of the primary
24-hour ambient air standard. Such a percent reduction in emissions between
1970 and 1975 is expected through the application of existing particulate
emission limitations.
The Duluth-Superior AQCR (#129) was not gridded, and the AQDM could,
therefore, not be applied to this region. The region is classified Priority
I for particulates. The proportional model was used to test the rollback.
Based on the calculations, it is expected that even the secondary standards
for particulates can be achieved in Duluth through the application of exist-
ing regulations concerning particulates.
2.3.3 Sulfur Dioxide Control Strategy
For development of a strategy to attain the ambient air standard for
SC>2, a sulfur regulation was considered. It was decided to test the AQDM
using an allowable sulfur content in fossil fuels of 2 percent by weight.
Existing SC>2 emissions shown in the emission inventory were recalculated to
reflect such a fuel limitation. Expected growth in SCU emissions during the
period extending from 1970 to 1975 was negligible and, therefore, did not
affect the AQDM test. This recalculated data was then tested in the AQDM.
The maximum expected annual concentration achieved through the applica-
tion of such a strategy is approximately 63 yg/m3. The primary annual am-
bient air standard is 80 yg/m3 and the secondary annual ambient air standard
is 60 yg/m3. The latter was based on the original federal secondary standard
which has since been rescinded.
The strategy must also consider the primary 24-hour ambient air quality
standard of 365 yg/m3 and the secondary 24-hour ambient air standard of
260 yg/m3. Existing 1970 air monitoring data revealed that the 24-hour stand-
ards had been exceeded at some stations. The proportional model was selected
to further test the S02 strategy on a 24-hour basis. Since the maximum can
be exceeded once per year, the second highest value of S02 concentration was
-------
20
selected to look at the effect of higher-than-usual daily averages. A reduc-
tion calculation to achieve air quality standards was made. Based upon these
calculations and the strategy considerations involving the 24-hour air qual-
ity standards, the proposed strategy appeared to be adequate to achieve the
24-hour primary standard.
2.4 Special Consideration for the State of Minnesota
2.4.1 Planned SIP Revisions
Minnesota is presently not considering changing its State Implementa-
tion Plan with respect to fuel combustion sources.
2.4.2 Fuels
Minnesota is a heavy user of coal. For example, in 1971, 67% of
the statewide heat input for power plants from fossil fuels was derived
from coal, 2% was derived from oil, and 31% was derived from gas.^ Min-
nesota does not produce any coal and there are no reserves of coal located
within this state. However, lignite is used by some power plants and indus-
trial/ commercial/institutional sources. Lignite is available in large quan-
tities from nearby North Dakota.
2.4.3 Fuel Conversions
The Federal Energy Administration (FEA) has identified the Fox Lake
Power Plant in Southeast Minnesota-La Crosse (#128) as a plant in Minnesota
7
having the potential to convert from burning oil to coal.
-------
21
3.0 AIR QUALITY CONTROL REGION ASSESSMENTS
3.1 General Methodology
The previous section having set the background for the State Implementa-
tion Plan and evaluated the current air quality situation, this section will
review the available information for each AQCR to determine the feasibility
of relaxing emission regulations in the interest of conserving clean fuels.
Care must be taken in interpreting the results of this analysis and the fol-
lowing caveats must be kept in mind: (1) The analytical procedure is intended
to provide a first approximation to the evaluation of potential regulation
changes (e.g., rollback and single source modeling techniques were used).
The state should conduct a more detailed analysis of the situation to confirm
or dispute any of these findings prior to submitting SIP revisions. (2) In
many instances the necessary data were unavailable or limited in scope.
Where possible, best engineering estimates were used to fill in the gaps.
Where better information is available, the state should use it in developing
SIP revisions.
The analysis encompasses five distinct considerations for each AQCR.
First, the current air quality situation is assessed to determine if the
indicators point to the region's ability to tolerate an emission increase
without violation of any NAAQS. Most of the data necessary for this review
have already been presented in Section 2 and Tables B-l and B-2 summarize
the information for particulates and S02, respectively, in each AQCR. The
assessment is made on the basis of 7 criteria: (1) current air quality viola-
tions, (2) expected NAAQS attainment dates, (3) proposed Air Quality Maintenance
Area designations, (4) total emissions, (5) portion of emissions from the state's
fuel combustion sources, (6) regional emission reduction required (based on
rollback calculations), and (7) pollutant priority classification. Note that
this evaluation is based strictly on air quality considerations. Determina-
tions of whether regulation relaxation would, in fact, result in clean fuels
savings will be made on a source-by-source evaluation.
The second consideration for each AQCR is the power plant assessment and
this data is summarized in the tables in Appendix C. All existing and pro-
posed plants are reviewed and the clean fuel requirement is determined.
Where dispersion modeling data are available, the maximum allowable fuel
sulfur content which would enable the plant to meet the NAAQS in its immediate
-------
22
vicinity is estimated. For the purposes of this report, the SCL modeling
data used1 assumes the power plant fuel use pattern in 1975 will be the same
as that existing in 1971 with, the addition of fuel consumption for new units
coining on-line. The choice of 1971 as the baseline year is based on the
consideration that fuel switching to achieve SIP emission regulations did
not begin nationwide until 1972; therefore 1971 represents consumption
patterns which are not dictated by emission regulations but rather by the
economics of fuel determined from the modeling, the 1971 fuel content is
used as an upper bound. For particulate emissions, plants currently below
required SIP emission levels are assumed to remain so. No particulate
modeling results were available. Fuel use data2'3 and emission data4'5
are drawn from both published and unpublished sources.
The third consideration for each AQCR is the assessment of large
industrial/commercial/institutional point sources and the summary data is
presented in Appendix D. The procedure is effectively equivalent to that
carried out for power plants. Emission and fuel use data were drawn from
the National Emission Data System (NEDS) file.5 No individual source
modeling data were available.
The fourth consideration is area source assessments. The fuel use
patterns and clean fuel requirements determined by existing regulations are
computed for these sources using NEDS data.5 The results are summarized
in Appendix E.
The fifth' consideration is a synthesis of the first four in that the
fuel use requirements that are imposed on all sources in the region are
totaled. Summary tables are in Appendix F.
At this point, an overall assessment of the potential for regulation
revision and resulting clean fuel savings can be made. The findings for
each AQCR have been summarized on Table 2-1 and in Section 1. An AQCR is
determined to be a good candidate for emission limit regulation revision
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 fuels
-------
23
savings potential, then the region is classified as a poor candidate for
regulation revision. If the air quality or the clean fuels savings
evaluations are inconclusive or show conflicting information, then the
region is assessed as a marginal candidate for regulation revision. A
much more detailed analysis must be carried out by the state to resolve
the situation.
3.2 Central Minnesota Intrastate AQCR (#127)
Although there are no reported high particulate levels, the indica-
tions are that a significant ability to absorb increased particulate
emissions does not exist in this region (Tables A-3 and A-8). Any regula-
tion relaxation would have a substantial impact upon air quality, since
Minnesota fuel combustion sources emit a large portion of the particulates
in this region (Table A-5). Hence, this region is a poor candidate for
particulate regulation relaxation (Table 2-1).
The region is also a poor candidate for S09 regulation relaxation
Li
(Table 2-1) even though indications are that there is a significant ability
to absorb increased SCL emissions (Tables A-4 and A-8). There are only
two relatively small power plants which, along with the industrial/
commercial/institutional sources are unregulated. Hence, present regula-
tions already allow the utilization of high sulfur fuels for these smaller
plants.
3.3 Southeast Minnesota - LaCrosse Interstate AQCR (#128)
Based on a sufficient number of monitoring sites, there are indications
of high particulate levels and hence no tolerance for increased emissions
(Tables A-3 and A-8). Hence, the region is a poor candidate for relaxing
particulate emission regulations.
Despite the indications from air quality that there is significant
ability to absorb increased SO- emissions, the region is only a marginal
candidate for SO- emission regulation relaxation (Tables A-4 and A-8).
The many smaller power plants and industrial/commercial/institutional
sources (<_ 250 x 106 BTU/hr) are unregulated and hence regulation relaxa-
tion would be unnecessary for these plants. The marginal rating is given,
however, because the largest power plant in the region (Fox Lake) has been
identified by the F.E.A. as having the potential for switching from oil to
coal. Since this plant is presently using large amounts of oil (Table C-l)>
-------
24
a significant clean fuel savings is a possibility. Although, modeling
results are available for several power plants including the Fox Lake plant,
the results are only for coal use and hence, particularly for the Fox Lake
plant, do not look at total fuel use.
3.4 Duluth-Superior Interstate AQCR (#129)
This region is a poor candidate for particulate emission regulation
relaxation. Air quality data from a large number of stations indicate
high particulate levels (Tables A-3 and A-8). The proposal of an AQMA for
the city of Duluth indicating expected difficulties with maintaining
acceptable air quality reinforces this assessment (Table A-l).
Despite the indications from air quality that there is significant
ability to absorb increased SCL emissions, the region is only a marginal
candidate for SCL emission regulation relaxation. The modeling results
listed in Table C-l are merely an indication of the 1971 %S. The Clay
Boswell power plant, which will have the second highest capacity in the
state by 1975, has not actually been modeled and is presently using low
sulfur fuel as are the Aurora and the Hibbard power plants. Modeling is
necessary before a conclusion can be reached regarding the possibility of
clean fuels savings, hence, the marginal rating.
3.5 Metropolitan Fargo-Moorhead Interstate AQCR (#130)
This region is a poor candidate for both particulate and SCL emission
regulation relaxation. There are indications of high particulate levels
(Tables A-3 and A-8) and there is a proposed particulate AQMA in the North
Dakota portion of this region. In addition, there is little potential for
clean fuel savings since there are no power plants (Table C-l) and only
one significant industrial/commercial/institutional source (Table D-l) in
the Minnesota portion of this region. Further, sources with heat input of
less than 250 x 106 BTU/hr are unregulated; hence, regulation revisions
would be unnecessary for clean fuel savings in the case of smaller plants
and/or area sources.
3.6 Minneapolis - St. Paul Intrastate AQCR (#131)
This region is a poor candidate for particulate emission regulation
relaxation. There are indications of widespread high particulate levels
in this region (Tables A-3 and A-8). In addition, seven counties have
-------
25
been proposed as AQMAs for participates (Table A-l).
Air quality data indicates some high S09 levels in this region
L*
CTables A-4 and A-8). In addition seven counties have been proposed as
AQMAs for SO- (Table A-l). Despite this information, the region is given
a marginal rating for revising SCL regulations. The rating is based on
modeling results which indicate that the A.S. King power plant has the
potential for switching to high sulfur coal (Table C-l). This would
result in a significant clean fuel savings since the A.S. King plant is
the largest capacity plant in the state (Table C-2 and F-l). However,
any regulation revisions should proceed with extreme caution in order to
avoid any worsening of the present air quality problems.
3.7 Northwest Minnesota Intrastate AQCR (#132)
Ihis region is a poor candidate for particulate regulation relaxation
because there are indications of high particulate levels in the region
(Table A-3 and A-8).
The region is also considered to be a poor candidate for SCL emission
regulation relaxation. Although the indications are that there is a
significant ability to absorb increased SO- emissions (Tables A-4 and A-8),
the data is based on only one monitoring station. No modeling has been
performed for this region. The main reasons for the poor potential for
regulation revisions are that small plants (<_ 250 x 106 BTU/hr) are
already unregulated and one of the main fuels being used in this region
by both the power plants and the industrial/commercial/institutional
sources is lignite which is probably locally available from North Dakota
(Tables C-l and D-l). Hence, there would be little reason to change
existing regulations.
3.8 Southwest Minnesota Intrastate AQCR (#133)
There are indications of high particulate levels in this region
(Tables A-3 and A-8) and sources in this region contribute a large portion
of the emissions in this region (Table B-l). Hence, the region is a poor
candidate for particulate emission regulation relaxation.
The region is also a poor candidate for S02 emission regulation
relaxation despite the apparent indications of a significant ability to
absorb increased S02 emissions (Table A-4 and A-8). 'llus data, however,
-------
26
is based on only one monitoring station. No .modeling results are available
for the region and there is little clean fuel savings potential in the
region. Smaller plants Cl 250 x 10s BTU/hr) are already unregulated. The
Minnesota Valley power plant is presently the only plant regulated in the
region. It is using a rather small amount of low sulfur fuel and, hence,
significant clean fuel savings would not be realized by changing regula-
tions for this one plant.
-------
APPENDIX A
State Implementation Plan Background
-------
TABLE A-l. Minnesota Air Pollution Control Areas
Demographic Information
Air Quality Federal
Control Region Number
Cental Minnesota
Southeast Minnesota -
La Crosse (Wise.)
Duluth-Superior (Wise.)
Metropolitan Fargo -
>foorhead (N'.D.)
Minneapolis - St. Paul
Northwest Minnesota
Southwest Minnesota
127
128
129
130
131
132
133
Population Area
1970 (Square
(Millions) Miles)
.25 6,215
1.11
.49
.12
1.88
.40
.30
24
28
2
2
27
12
,073
,557
,794
,820
,450
,011
Population
Per Square
Mile
40
46
17
.43
668
15
25
Priority
Classification
Parti-
culates
II
II
I
II
I
II
III
so*
III
IA
II
III
I
III
III
N&
III
III
III
III
III
III
III
TSP
(0)
(0)
CD
(0)
(7)
(0)
(0)
Proposed
AQMA Designations
Counties SOx Counties
St. Louisb
(City of Duluth)
Hennepin, Ramsey,
Washington, Scott,
Carver, Dakota,
Anoka
(0)
(0)
(0)
(0)
(7) Hennepin, Ramsey,
Washington,
Scott, Carver,
Dakota, Anoka
(0)
(0)
As of November 14, 1974
Only the city of Duluth has a proposed AQMA designation for TSP in St. Louis County.
-------
LEGEND
® Places of 100.000 or more inhabitants
• Places of 50.000 to 100.000 inhabitants
O 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)
The city of Duluth in
St. Louis county has
a proposed TSP
designation
TSP DESIGNATION
S02 DESIGNATION
Figure A-l. Proposed Minnesota Air Quality Maintenance
Area (AQI4A) Designations
-------
Table A-2. Minnesota Ambient Air Quality Standards
All concentrations in ygm/nf
Federal
State
Primary
Secondary
Primary
Secondary
Total Suspended
Annual
75 (G)
60 (G)
75 (G)
60 (G)
Part icul ate
24 -Hr
260a
150a
260a
150a
Sulfur
Annual
80 (A)
—
60 (A)
60 (A)
Oxides
24-Hr
365a
—
260a
260a
3-Hr
—
1300a
655a
655a
Nitrogen Dioxide
Annual
100 (A)
100 (A)
100 (A)
100 (A)
to be exceeded more than once per year.
(A) Arithmetic mean
(G) Geometric mean
-------
TAELE A-3. Minnesota AQCR Air Quality Static, TSP
Number o£ Stations Exceeding
TSP Concentration fcg/nr) Ambisnt Air Quality Standards
AQCR
No.
127
128b
129b
130b
131
132
133
a!973
No. Stations
Reporting
24-Hr
8
17
32
7
32
5
5
Annual
7
11
16
5
23
3
3
Highest Reading 2nd Highest Reading
Annual
59
77
81
81
103
88
58
24-Hr
221
342
522
503
280
618
318
air quality data in National Mr Data
Priuary
24-Hr Annual 24-Hrc
142 0 0
228 1 0
283 3.1
337 1 3
260 4 0
265 1 1
237 0 0
Bank as of June 7, 1974.
Second
Annual
0
3
7
2
11
1
0
1 Reduction Required
lary to Meet Standards
24-Hrc
0 - 3
6 +38
15 + 51
7 +59
14 + 74
2 +47
3 +40
Controlling
Standard
Annual
24-Hr
24-Hr
24 -Hr
Annual
24-Hr
24-Hr
Interstate.
S'iolations based on
^rors.
Mai
-la:
r
2nd highest
(2nd Highest
reading at
24-Hr - 2
any station.
4-Hr Secondary Standard\
/Annual
- Annual Secondary Standard)
x 100
Annual - Background
Minnesota particulate background concern.ration:
AQCR's 127, 130, 132: 20 >ig/m3
AQCR's 128, 129, l-3: 21.4 pg/rt?
AQCR 131: 45
-------
TABLE A-4. Minnesota AQCR Air Quality Status, S02
SO? Concent ration (jugm/nr)
Nu'.iber of Stations Exceeding
Anbient Air Quality Standards
% Reduction Required Controlling
to Meet Standards'1 Standard
No. Stations Reporting Highest Reading 2nd Highest Reading Primary Secondary
AQCR
\'o.
12?
123
120b
13Cb
131
132
133
al?73
Annual 24-Hr
1 2
4 7
1 8
0 2
12 18
0 1
0 1
Cont. Annual 24-Hr 24-Hr Annual 24-HrC 3-Hrc
0 5 146 73 00 - - 400
1 32 610 151 000 . 142
1 22 107 49 000 - 264
0-68 23 0 - 1,487
9 71 985 985e 03 1 +63
0-23 23 - 0 - - 1,487
0-20 20 0 - 1,725
24-Hr
24-Hr
Annual
24-Hr
24-Hr
24-Hr
24-Hr
air quality data in National Aerometric Data Bank as of June 7, 1974.
Interstate.
Violations based on 2nd
d.
rorrr.'
'.la:
Maximum of
highest reading at any station.
1 /2nd Highest 24-Hr - 24-iir Standard! „ -,AA „ /Annual - Annual Standard! nnn |
L V 2nd Highest 24-Hr ) x 10J or 1 Annual / x 10° J
Actual value of second highest reading not available at station rath greatest excesses. Estimate of I reduction required based on highest
24-hour reading.
-------
TABLE A-5. Minnesota Fuel Combustion Source Summary
Total Emissions
Emissions from
AQCR
No.
127
128s
129e
130e
131
132
133
TOTAL
Minnesota plants
Minnesota plants
Slinnescta ccur.ti
AQCR totals
Interstate
Power
Plants3
7
14
6
0
6
3
5
36
contributing 90%
es
Other Fuel Conbustion
Point Sources"
7
5
4
1
7
7
2
33
of the participate and S02 eini
Area
Scurcesc
9
20
7
1
7
25
IS
87
ssio.is, or 1,000 or more
(103
TSP
IS
129
110
21
43
35
43
396
tons per
tons/year)
SO,
16
157
137
6
208
16
20
560
year.
Minnesota Fuel
TSP
93
26
40
29
37
46
35
37
Combustion Sourc*
S02
94
29
80
67
90
88
95
70
-------
Table A-6. Minnesota Emissions Summary,3 TSP
AQCR
127
128 Minnesota
Other
Total
125 i\iinnesota
Other
Total
130 Minnesota
Other
Total
131
132
153
TOTAL
-Total
(iO^ ton?Vr)
15
52
77
T2"9
99
11
TTO-
7
14
21
43
35
43
396
0.
'i)
4
13
19
7-1
25
3
28
2
3
"5"
11
9
11
100
Electrici
(105 tons
1
2
47
45
18
7
2i
<1
0
^T
11
<1
11
92
1 Industrial/Commercial/
ty Generation
/y-) '*
5
4
61
38
Institutional
(103 tons/yr)
1
1
8
~S
18
19
18
1
19
1
2T
4
c ! i
<1 | 5
27
1
2
10
i
25
23
<1
47
Point Source
_j_
6
2
11
7
19
14
18
54
11
25
5
27
<1
12
Area Source
(103 tons/yr)
12
31
15
ra
7
4
TT
2
1
J
3
6
4
85
%
81
60
19
36
7
39
10
25
~5
12
8
16
10
22
Emissions in National Emissions Data System data bank as of Jure 1974.
-------
TABLE A-7. Minnesota Emissions Summary,a 5£>2
AOCR
127
128 Minnesota
Other
Total
129 Minnesota
Other
Total
130 Minnesota
Other
Total
131
132
133
TOTAL
Total
(10-3 tons/yr)
16
47
110
137
120
17
137
4
2
0
208
16
20
360
1
3
8
20
7s
21
3
24
1
<1
1
37
3
4
100
Electricity Generation
(10-5 tons/yr) ' "%
3
14
86
TM
29
8
37
<1
0
-------
TABLE A-8. Vdnnesota Fequired Emissions Reduction
AQCR
127
12Sb
129b
130b
131
132
133
Estimated Particulate
%
- 3
+ 38
+ 51
+ 59
+ 74
+ 47
+ 40
Emission Reduction Required
10"5 tons /year
<- 1
+ 49
+ 56
+ 12
+ 32
+ 16
+ 17
Estimated Sf^ Emission
%
400C
- 142
264
- 1,487C
+ 63
- 1,487=
- 1,725=
Reduction Required
10 tons/year
- 64
- 223
- 362
- 89
+ 131
- 238
- 345
Based en a proportional change of emissions to air quality.
Interstate.
""Exceptionally large negative numbers indicate current air quality is very good. In this range, the proportional
calculations do not give a good picture of allowable emission increases. They are included here only as general
indicators.
-------
Table A-9. Minnesota Fuel Conbustion Emission Regulations
< 250 x 10° Btu/hr > 250 x 10° Btu/hr
Minneapolis-St. Paul (AQCR 1131): 2.0% sulfur by weight 1.5* sulfur by weight
AQCRs other than Minneapolis-
St. Paul (AQCR #131):
These provisions shall not apply under the following conditions:
1. A variance has been gnmted by the Minnesota Pollution Control Agency
2. The following limitation is met: 1.75 Ib SCylO6 Btu.
2.0* sulfur by weight
Particulate
Matter
New installations and installations within Existing installations and installations
the Minneapolis-St. Paul AQCR (*131) and the Minneapolis-St. Paul AQCR (#131) and
the city of Duluth of Duluth
outside
the city
0.4 lb/106 Btua 0.6 lb/106 Btua
In addition, emissions from all facilities are subject to the constraints of Figure A-2
b
Visible .
Air
Contaminants
Existing installations including boats and
ships except existing incineration
No visible emission:
a. Darker than Ringelmann No. 3
b. Darker than Ringelmann No. 2 but
less than Ringelmann No. 3 for
longer than 4 minutes in aggre-
gate in any 60 minutes.
c. Darker than Ringelmann No. 1 but
less than Ringelmann No. 2 for
longer than 4 minutes in aggre-
gate in any 3? minutes
New installations and all incinerators
No visible emissions darker than Ringelmann No. 1
Exception:
A person may discharge from any single source for a period not more than 4 minutes in aggregate
in any 60 minutes air contaminants not darker than Ringelmann No. 2.
aMaximun allowable emission from any stack, plant, or installation regardless of stack height or number of stacks.
This provision of the regulation was not used in the present analysis.
-------
COMBUSTION FOR INDIRECT HEAT EXCHANGERS
!03Lbs/Hr
500 1.000
APPROXIMATE STEAM GENERATION
10 50 100
5.000 10,000
1.0
.9
I*
I -7
" .6
.5
.4
.3
•Maximun emission for existing plants or installations
: outside the Minneapolis-St. Paul Air Quality Control
Region and the City of Duluth.
CD
to
o
o
o
^o
^O
LU
z
• Stack Height (ft)
Above Grade
Maximun emission for Minneapolis-St. Paul Air Quality
Control Region, the City of Duluth, and all new installations
Maximun ground level dust concentration
100 ,ug/m3 for 3-15 min.
50 ,Mg/m3 for 30 min. -1 hr.
25 jug/m3 for 24 hrs.
.2
BASIS
Stack height is physical
stack height.
Graph is for a single stack.
No emission greater than 60
microns diameter allowed.
I I
I II I
10 50 100 500 1,000
TOTAL EQUIPMENT CAPACITY RATING , I06 Btu/Hr INPUT
Figure A-2. Graph for Estimating Allowable Emissions
(Adapted from Figure 2 of ASME Standards "APS-1")
5,000 10,000
-------
APPENDIX B
Regional Air Quality Assessment
-------
TABLE B-l. Minnesota AOCR Candidacy Assessment for Particulate Regulation Relaxation
Stations
with Particu'lite Expected Counties with Total Particulate
Estimated
Emissions Emission Reduction
Federal
AQCR Nunber
Central Minnesota
Southeast Minnesota
La Cross ec
Duluth-Superioi c
Metropolitan Fargo
Mocrheadc
Minnecpolis-
St. Paid
Northwest Minnesota
Southwest Minnesota
127
123
129
130
131
132
133
Air Quality
Violations3
0
6
16
7
16
2
3
Attainment Proposed. Particulate
Date AQMA Designations
6 0
7/75 0
7/75 I8
7/75 0
7/75 7
7/7S 0 '
d 0
Emissions
(103 tons/yr)
15
129
110
• 21
43
35
43
from Minnesota Fuel
Combustion
93
26
40
29
37
46
35
Required for NAAQS
(103 tons/yr)
< -1
+ 49
+ 56
+ 12
+ 32
+ 16
+ 17
Particulate
Priority
II
II
I
II
I
II
III
l number of stations given on Table A-3.
Presently meeting standards.
""Interstate.
Attainment schedule indicates region is below standards; current data indicates violations.
eCnly the city of Duluth has a proposed AQMA designation in St. ^ouis county.
-------
TABLE B-2. Minnesota AQCR Ganoids cy Assessment for S02 Regulation Relaxation
Counties with Estimated
Stations with Expected Proposed Total SC>2 % Emissions Emission Reduction
Federal SC>2 Air Quality Attainment SC>2 AQMA. Emissions from Minnesota Fuel Required for NAAQS SO^
AQCR Number Violations3 Date Designations (10 tons/yr) Combustion (10^ tons/yr) Priority
Central Minnesota 127 0 b 0 16 94
Southeast Minnesota
La CrosseC 128 0 b 0 157 29
Duluth-Superiorc 129 0 b 0 137 80
Metropolitan Fargo- ,
Moorheaic 130 0Q - b 0 6 67
Minneripolis-
St. Paul 131 . 3 7/75 7 208 90
Northwest Minnesota 132 Od b 0 16 88
SouthwestMinr.esota 133 Od b 0 20 95
"^Total rasiiber of stations given on Table A-4.
L'Presontly meeting standards.
clntsrstate.
- 64 III
-223 IA
-362 II
- 89 III
+131 I
-238 II
-345 III
ito annual data.
-------
APPENDIX C
Power Plant Assessment
-------
Table C-l. Minnesota Power Plant Assessment
Estimated 1975
$CR Plant
j27 Whitney
Elk River
12 8d Albert Lea
Fox Lake
Red Wing
Wilmarth
Winona
Austin
Northeast
Blue Earth
Lincoln Street
New Ulm
Owatonna
Silver Lake
1975
Capacity
(MO
20.0
48.0
18.5
104.6
23.0
25.0
17.2
27.5
32.0
4.0
26.5
27.0
34.5
98.4
Fuel
Coal
Gas
Coal
Coke
Oil
Gas
Oil
Gas
Coal
Oil
Gas
Coal
Gas
Coal
Gas
Coal
Coal
Oil
Gas
Coal
Oil
Gas
Coal
Gas
Coal
Oil
Gas
Coal
Gas
Oil
Gas
Coal
Gas
Fuel Use
Quantity3
11
260
19
22
1428
393
924
258
18
12,264
3,198
39
858
26
589
28
10
524
863
12
610
1,004
4
69
10
840
828
22
1,177
3,528
1,093
101
1,973
% S Under % S Allowed
SIP b by
Regulation Model
h
h
h
h
h
h
h
h
2.0 2.1
2.0
h
h
h 2.0e
h
h 2.0e
h
h
h
2.0
2.0
h
h
h
h
h
h
h
h
h
2.0
-------
Table C-l. Minnesota Power Plant Assessment (Contd.)
Estimated 1975
AQCR
I28d
(Contd.)
129d
130d
131
Plant
Sleepy Eye
Springfield
Aurora
Clay Boswell
M. L. Hibbard
Hibbing
Two Harbors
Virginia
No Power Plants
Black Dog
High Bridge
Island
Riverside
Southeast
1975
Capacity
(Mf)
3.3
7.8
116.1
500.0
122.5
19.0
6.0
32.5
486.7
463.8
20.0
455.9
30.0
Fuel
Coal
Oil
Gas
Coal
Oil
Gas
Coal
Oil
Coal
Oil
Coal
Gas
Coal
Gas
Coal
Gas
Coal
Gas
Coal
Oil
Gas
Coal
Oil
Gasf
Gas
Gas
Coal
Oil
Gas
Oil
Gas
Fuel Use
o
Quantity
1
714
112
1
378
172
351
878
1,927
105
293
1,458
104
88
6
131
88
156
554
168
13,096
462
4,035
16,617
655
71
1,012
3,199
5,700
1,092
365
% S Under % S Allowed
SIP b by
Regulation Model
h
h
h
h
h
h
0.9 0.9g
2.0
0.9 0.9
0.3
1.4 1.4g
h
h
h
h
2.0
1.5 1.5g
0.3
1.5 1.5g
0.3
-
1.2 1.2s
0.3
0.3
A. S. King
598.4 Coal
1,337
1.5
3.1
-------
Table C-l. Minnesota Paver Plant Assessment (Contd.)
Estimated 1975
AQCR Plant
132 Crooks ton
Hoot Lake
Alexandria
1975
Capacity
(MV)
10.0
136.9
5.3
133 Minnesota Valley 46.0
Ortonville
Litchfield
Willmar
Worthington
15.0
3.0
30.4
16.5
Fuel Use
Fuel Quantity3
Lignite 35
Gas 52
Lignite 673
Oil 126
Coal 2
Gas 54
Coal 88
Oil 20
Gas 697
Lignite 101
Coal 1
Gas 18
Coal 28
Gas 286
Coal 6
Oil 756
Gas 353
% S Under % S Allowed
SIP b by c
Regulation Model
h
h
0.96
0.35
h
h
1.9
'0.3
h -
h
h
h
h
h
h
h
Coal quantity is 10 tons/yr, oil quantity is 10 gal/yr, gas quantity is 10 ft /yr.
Estimates are based on 1971 fuel use patterns plus planned additions. If 1971 fuel
use data were unavailable, 1972 data were used.
The maximum allowable % S is assumed to be the 1971 % S unless the regulations require
a lower \ S. -
V
'The maximum allowable % S is assumed to be the 1971 I S unless modeling results show
a lower % S is allowed.
d.
Interstate.
Modeling results show that use of even the most stringent regulation applicable in this
AQCR (i.e. 2.0 % S fuel) would result in NAAQS violation.
Manufactured Gas
^Modeling calculations indicate that the 24-hour primary air quality standard may be
exceeded even at SIP.
In AQCR's other than Minneapolis - St. Paul (AQCR #131) the sulfur content of fuels
for installations of less than 250 x 106 Btu/hr is unregulated.
ihis plant has been identified by the FEA as having the capability to switch from oil
to coal as its primary fuel.
-------
Table C-2. Minnesota Power Plant Evaluation Summary
197S Fuel Required by SIP
1975 Fuel Required bv Modified
AQCR
127
128°
129C
130C
131
132
133
Minnesota
Total
Fuel
Coal
Coke
Oil
Gas
• Coal
Oil
Gas
Coal
Oil
Gas
Coal
Oil
Gas
Coal
Lignif.
Oil
Gas
Coal
Lignite
Oil
Gas
Coal
Coke
Lignite
Oil
Gas
Regulations
< 1* S l-2t S
653
131
12,874
12,194
2,278 381
105 87S
1,833
No power plants
3,365.
8,494
36,504
673
126
106
88
2Q
1354
2,278 3,965
•673
8,745 13,752
52,644
> 2t S
30
22
1,428
141
6,908
110
2
35
35
101
756
318
22
136
9,092
, Regulations0
< 11 S l-2t S > 21 S
No modeling results available
54<*.h i8d
2,2786'g 293e»8
2,0288 1,337
No modeling results available
Ho modeling vesults available
2,278 2,375 1,355
'
requirements based on 1971 fuel use patterns at 1975 consumption rates plus any new units. If 1971 fuel use
data were unavailable, 1972 data were used. Coal in 103 tons/yr, oil in 10-5 gal/yr, gas in 10 ft3/yr. Maximun I S
is 1971 4 S unless regulations require a lower IS.
Maximum allowable I S is 1971 I S unless modeling indicates a lower value. Modeling did not reat oil.
Interstate.
*7>iodeling results available for only 3 of the 14 power plants in this AQCR.
Modeling results available for 3 of the 6 power plants in this AJJCR.
Modeling results available for 4 of the 6 power plants in this AQCR. However, for .the 2 power plants which were not
modeled it is estimated that only oil and gas will be used for fuels.
"Modeling calculations indicate that the 24-hour primary air quality standard may be exceeded even at SIP.
''Modeling results show that use of even the most stringent regulation applicable in this AQCR (i.e. 2.0* S fuel)
would result in HAAQS violation.
-------
APPENDIX D
Industrial, Commercial, Institutional Point Source Assessment
-------
Table D-l. Minnesota Industrial/Commercial/Institutional Source Assessment
AQCR
127
128d
129d
Planta
Cambridge State Hospital
St. Regis Paper Co (Plant 2)
Kraft Foods
St. Benedict's College
St. John's University
Burlington Northern, Inc
St. Regis Paper Co (Plant 11)
Wilson Sinclair Co
PPG Industries
Hormel and Co
Archer Daniels
Honeymead Products Co
Northwest Paper Co
Conwed Corp
Erie Mining Co
Boise Cascade
Fuelb
Coal
Oil
Coal
Gas
Oil
Oil
Gas
Coal
Oil
Coal
Coal
Oil
Gas
Coal
Oil
Gas
Coal
Oil6
Oil
Gas
Coal
Oil
Gas
Coal
Coal
Coal
Oil
Gas
Estimated
Fuel
Consumption0
3
183
29
313
548
500
41
32
852
20
22
79
413
6
4,690
969
7
8
1,680
1,280
212
1,184
2,370
17
531
82
480
7
SIP
Regulations
\ Sd
_
-
-
-
- •
-
-
-
.-
-
-
-
2.0
2.0
-
2.0
-
I30d
American Crystal Sugar Co
Lignite
81
-------
Table D-l. Minnesota Industrial/Coramercial/Institutional Source Assessment (Cont.)
AQCR Planta
131 Koch Refining Co
Northwest Refining Co (Plant 12)
University of Minnesota
B. F. Nelson
Hoerner Waldorf Corp
3M Company
Northwest Refining (Plant 3)
132 Burlington Northern
NW Paper Co, Potlatch Forest, Inc
Hennepin Paper
Fergus Falls State Hospital
American Crystal Sugar Co
(Plant 1)
American Crystal Sugar Co
(Plant 2)
King of Spuds, Inc
Fuelb
Oil
Oil
Gas
Coal
Oil
Coal
Oil
Gas
Oil
Gas
Coal
Oil
Gas
Coal
Coal
Gas
Oil
Lignite
Coal
Lignite
Lignite
Lignite
Estimated
Fuel
Consumption0
11,790
6,250
42
37
800
5
153
221
9,200
2,760
28
4,779
3,889
21
29
623
1,150
12
4
78
73
90
SIP
Regulations
a, od
•0 O
2.0
2.0
2.0
2.0
2.0
2.0
1.7
2.0
1.7
-
-
-
-
-
-
-
-------
Table D-l. Minnesota Industrial/Ccmmercial/Institutional Source Assessment (Cont.)
AQCR
133
Planta
Wilmar State Hospital
1st District Assoc
Fuelb
Oil
Oil
Gas
Estimated
Fuel
Consumption0
2,740
150
1,050
SIP
Regulations
_
^•linnesota plants contributing 901 of AQCR's S02 or emitting more than 1000 tons/yr
of SO2.
Does not include plant or process gas. Oil is residual unless otherwise specified.
cCoal in 103 tons/yr, oil in 103 gal/yr, gas in 10 ft3/yr.
Interstate.
cDistillate Oil.
-------
Table D-2. Minnesota Industrial/Commercial/Institutional Source Evaluation Summary
AQCR
127
128d
129d
130d
131
132
133
Fuela
Coal
Oil
Gas
Coal
Oil
Oilc
Gas
Coal
Oil
Gas
Lignite
Coal
Oil
Gas
Coal
Lignite
Oil
Gas
Oil
Gas
< 1% S 1-2% S > 21 S
84
2,083
354
35
6,449
8
2,662
743 99
1,184 480
2,377
81
.70
32,972
6,912
54
253
1,150
623
2,890
1,050
-- . ,
Minnesota
Total
Coal
Lignite
Oil .
Gas
V
813 272
334
34,156 13,060
13,978
^Oil is residual unless otherwise specified.
Does not include plant or process gas. Coal in 103 tons/yr, Oil in 10 gal/yr,
gas in 106 ft3/yr.
cDistillate Oil
Interstate.
-------
APPENDIX E
Area Source Assessment
-------
TABLE E-l. Minnesota Area Source Fuel Use
AQCR
127
12Sa
129s
130a
131
131
133
TOTAL
Coal
(103 tons/yr)
3
215
150
18
36
10
7
439
Residual Oil
(:.03 gals/yr)
6,800
22,630
28,800
4,440
108,450
5,910
5,750
182,780
Distillate Oil
(103 gals/yr)
63,410
244,460
146,030
41,030
258,800
129,460
91,820
975,010
Natural Gas
(106 ft3/yr)
12,220
87,050
74,920
5,300
96,360
8,850
16,060
300,760
Interstate - Fuel use figures are for entire AQCR.
-------
APPENDIX F
Fuels Assessment
-------
Table F-l. Minnesota Clean Fuels Analysis Summary
Minimum Clean Fuel Saving Through
Existing Regulations Clean Fuel Requirements5 Regulation Modification"
AQCR
127
12 8C
129C
130°
131
132
133
Minnesota
Total
Fuel < 1% S 1-2 % S < 1% S 1-2% S
Coal No modeling results
Coal 131 - -36d
Coal 2,278 1,124 - . -
Lignite No modeling results
Coal 3,435 - 1,337
Coal No modeling results
Lignite 673
Coal 88 No modeling results
Lignite
Coal 2,278 4,778 , - 1,301
Lignite 673
alncludes fuel use from power plant (Table C-l) and industrial/conmercial/institutional point source (Table D-l) only.
Coal in 103 tons/yr, oil in 103 gal/yr, gas in 106 ft3/yr.
Based on modeling results for power plants only.
clnterstate.
Regulation modification would require increased use of this low sulfur fuel.
-------
REFERENCES
1. Modeling Analysis of Power Plants for Compliance Extensions in 51 Air
Quality Control Regions, report prepared under Contract No. 68-02-0049
for the U.S. Environmental Protection Agency*, Walden Research Division
of Abcor, Inc., Cambridge, Mass., December 17, 1973.
2. Steam Electric Plant Factors, 1973, National Coal Association, Washington,
D.C., January 1974.
3. Power plant data file, unpublished, U.S. Environmental Protection Agency,
Research Triangle Park, N.C.
4. Power plant SCL emission estimates, unpublished data, U.S. Environmental
Protection Agency, Research Triangle Park, N.C.
5. National Emissions Data Systems data bank, U.S. Environmental Protection
Agency, Research Triangle.Park, N.C.
6. Bituminous Coal Facts, 1972, National Coal Association, Washington, D.C.
7. Federal Energy Administration, unpublished data.
-------
TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1. REPORT NO.
EPA-450/3-75-033
2.
3. RECIPIENT'S ACCESSIOI*NO.
4. TITLE AND SUBTITLE
IMPLEMENTATION PLAN REVIEW FOR MINNESOTA
5. REPORT DATE
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
8. PERFORMING ORGANIZATION REPORT NO,
9. PERFORMING ORG '\NIZATION NAME AND ADDRESS
10. PROGRAM ELEMENT NO.
U. S. Environmental Protection Agency, Office of Air
Quality Planning and Standards, Research Triangle Park,
N. C., Region V Office, Chicago, 111., and Argonne
National Laboratory. Argonne. 111.
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.
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 (This Report!
Unclassified
21. NO. OF PAGES
56
20. SECURITY CLASS (Thispage)
Unclassified
22. PRICE
EPA Form 2220-1 (9-73)
------- |