EPA-450/3-75-039
MARCH 1975
IMPLEMENTATION PLAN REVIEW
FOR
DISTRICT OF COLUMBIA
AS REQUIRED
BY
THE ENERGY SUPPLY
AND
ENVIRONMENTAL COORDINATION ACT
U. S. ENVIRONMENTAL PROTECTION AGENCY
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EPA-450/3-75-039
IMPLEMENTATION PLAN REVIEW
FOR
DISTRICT OF COLUMBIA
AS REQUIRED BY THE ENERGY SUPPLY AND ENVIRONMENTAL COORDINATION ACT
Prepared by the Following Task Force:
U. S. Environmental Protection Agency, Region III
6th and Walnut Streets
Philadelphia, Pennsylvania 19106
Environmental Services of TRW, Inc.
800 Foil in Lane, SE, Vienna, Virginia 22180
(Contract 68-02-1385)
U. S. Environmental Protection Agency
Office of Air and Waste Management
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
March 1975
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DISTRICT OF COLUMBIA
ENERGY SUPPLY AND ENVIRONMENTAL COORDINATION ACT
(SECTION IV - IMPLEMENTATION PLAN REVIEW)
Table of Contents Page
1.0 EXECUTIVE SUMMARY 1
2.0 IMPLEMENTATION PLAN REVIEW 5
2.1 Summary 5
2.2 Air Quality Setting - District of Columbia 10
2.3 Background on the Development of the District
of Columbia's Current Implementation Plan 11
3.0 CURRENT ASSESSMENTS BASED ON IMPLEMENTATION PLAN REVIEW. . . 12
3.1 District of Columbia Portion of the National
Capital Interstate Air Quality Control Region 13
APPENDIX A - IMPLEMENTATION PLAN BACKGROUND
APPENDIX B - REGIONAL SUMMARY
APPENDIX C - POWER PLANT SUMMARY
APPENDIX D - INDUSTRIAL, COMMERCIAL, INSTITUTIONAL SOURCE LISTING
APPENDIX E - FUEL USE SUMMARY
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1.0 EXECUTIVE SUMMARY
The enclosed report is the U.S. Environmental Protection Agency's
(EPA) response to Section IV of the Energy Supply and Environmental Coor-
dination Act of 1974 (ESECA). Section IV required EPA to review each
State Implementation Plan (SIP) to determine if revisions can be made to
control regulations for stationary fuel combustion sources without inter-
fering 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 sta-
tionary 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, informa-
tion on excessively restrictive control regulations. The intent of ESECA
is that SIP's wherever possible, be revised in the interest of conserying
low sulfur fuels or converting sources which burn oil or natural gas to coal.
EPA's objective in carrying out the SIP reviews, therefore, has been to try
to establish if emissions from combustion sources may be increased. Where
an indication can be found that emissions from certain fuel burning sources
can be increased and still attain and maintain NAAQS, it may be plausible
that fuel resource allocations can be altered for "clean fuel savings" in
a manner 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 regulations or to revise the S0? emission regula-
tions. The States have also been asked to discourage large scale shifts
from coal to oil where this could be done without jeopardizing the attain-
ment 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, four predominant reasons for the existence of
overly restrictive emission limitations within the State Implementation
Plans. These are (1) the state's prerogative to surpass NAAQS; (2) the use
of the example region approach in developing State-wide air quality control
strategies; (3) the existence of state air quality standards which are more
stringent than NAAQS; and (4) 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 effect many State plans and
in some instances conflict with current national energy concerns, a review
of the State Implementation Plans is a logical follow-up to EPA's initial
appraisal of the SIP's conducted in 1972. At that time SIP's were approved
by EPA if they demonstrated the attainment of NAAQS or_ more stringent state
air quality standards. Also, at that time an acceptable method for form-
ulating control strategies was the use of an exanple region for demonstrat-
ing the attainment of the standards.
The example region concept permitted a State to identify the most pol-
luted Air Quality Control Region. (AQCR) and adopt control regulations which
would be adequate to attain the NAAQS in that region. In using an example
region, it was assumed that NAAQS would be attained in the other AQCRs of
that 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 controls
which are more stringent than needed to attain NAAQS, especially in the util-
ization of clean fuels, for areas of the State where sources would not other-
wise contribute to NAAQS violations. For instance, a control strategy based
on a particular region or source can result in a regulation requiring 1 per-
cent sulfur oil to be burned state-wide where the use of 3 percent sulfur
coal would be adequate to attain NAAQS in some locations.
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EPA anticipates that a number of States will use the review findings
to assist them in making the decision whether or not to revise portions of
their State Implementation Plans. However, it is most important for those
States which desire to submit a revised plan to recognize the review's lim-
itations. 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 judgment and effort in complying with the
ESECA requirements. The time and resources which EPA has had to prepare
the reports has not permitted the consideration of growth, economics, and
control strategy tradeoffs. Also, there has been only limited dispersion
modeling data available by which to address individual point source emis-
sions. 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 are the most cur-
rently 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 suppororting 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 indus-
trial 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 deterioration,
increased TSP, NOV, and HC emissions which occur in fuel switching, and
A
other potential air pollution situations such as sulfates.
Although the enclosed analysis has attempted to address the attain-
ment of all the NAAQS, most of the review has focused on total suspended
particulate matter (TSP) and sulfur dioxide (SOo) emissions. This is
because stationary fuel combustion sources constitute the greatest source
of SCL emissions and are a major source of TSP emissions.
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Part of each State's review was organized to provide an analysis of
the SOg and TSP emission tolerances within each of the various AQCRs.
The regional emission tolerance estimate is, in many cases, EPA's only
measure of the "over-cleaning" accomplished by a SIP. The tolerance
assessments have been combined in Appendix B with other regional air
quality "indicators" in an attempt to provide an evaluation of a region's
candidacy for changing emission limitation regulations. In conjunction
with the regional analysis, a summary of the State's fuel combustion
sources (power plants, industrial sources, and area sources) has been
carried out in Appendices C, D and E.
The Implementation Plan for the District of Columbia has been reviewed
for the most prevalent causes of over-restrictive fuel combustion emission
limiting regulations. The major findings of the review are:
FOR BOTH TOTAL SUSPENDED PARTICULATES AMD SULFUR DIOXIDE, THERE
IS LITTLE INDICATION THAT CURRENT EMISSION REGULATIONS ARE
OVER-RESTRICTIVE.
The supportive findings of the SIP review are:
Like many areas of the nation, high levels of total suspended partic-
ulates were found in the District of Columbia during 1973. National
Ambient Air Quality Standards were exceeded in the 5istrict of
Columbia and also in the surrounding jurisdictions within the
National Capital Interstate Air Quality Control Region.
Sulfur dioxide levels during 1973 exceeded the annual National Ambient
Air Quality Standard in the District of Columbia.
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2.0 IMPLEMENTATION PLAN REVIEW
2.1 SUMMARY
A revision of fuel combustion source emissions regulations will de-
pend on many factors:
Does the State have air quality standards which are
more stringent than NAAQS?
t Does the State have emission limitation regulations
for control of (1) power plants, (2) industrial sources,
(3) area sources?
Did the State use an example region approach for demon-
strating the attainment of NAAQS p_r more stringent State
standards?
t Has the State not initiated action to modify combustion
source emission regulations for fuel savings; i.e.,
under the Clean Fuels Policy?
Are there no proposed Air Quality Maintenance Areas?
0 Are there indications of a sufficient number of monitoring
sites within a region?
Is there an expected 1975 attainment date for NAAQS in the
State Implementation Plan?
Based on (1973) air quality data, are there no reported
violations of NAAQS?
Based on (1973) air quality data, are there indications
of a tolerance for increasing emissions?
Are the total emissions from stationary fuel combustion
sources proportionally lower than those of other sources?
Do modeling results for specific fuel combustion sources
show a potential for a'regulation revision?
The following portion of this report is directed at answering these
questions. An AQCR's potential for revising regulations increases when
there are affirmative responses to the above.
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The initial part of the SIP review report, Section 2 and Appendix A,
was organized to provide the background and current situation information
for the State Implementation Plan. Section 3 and the remaining Appendices
provide an AQCR analysis which helps establish the overall potential for
revising regulations.
Based on an overall evaluation of EPA's current information, AQCRs
have been rated as either a good, poor or marginal candidate for revising
emission limiting regulations. These ratings which are shown in Table 2-1
were determined by assessing the following criteria:
Good
1) Adequate number
of air monitoring
sites
2) No NAAQS violations
3) Attainment date of
1975 for NAAQS in
the SIP
4) No proposed AQMAs
5) Modeling results
show a potential
for regulation
revision
Poor
1) Violation of NAAQS
2) Attainment date for
NAAQS later than
1975
3) Proposed AQMA
4) Modeling resutts
show no potential
for regulation
revision
Marginal
1) No air quality data
or insufficient number
of monitoring sites
2) Inconsistent
"indicators"
For an AQCR to be rated as a good candidate, all of the criteria listed
under "Good" would have to be satisfied. The overriding factor in rating.an
AQCR as a poor candidate is a violation of either the primary or secondary
National Ambient Air Quality Standards during 1973. However, if any of the
other conditions listed under "Poor" exists, the AQCR would still receive
that rating. The predominant reason for a marginal rating is a lack of suf-
ficient air quality data. In Priority III regions, air monitoring was not
required during 1973, therefore, there may be no data with which to determine
the current air quality status. Marginal ratings are also given when there
are varying or inconsistent "indicators".
After a candidacy has been given to a region, a follow-up analysis
should be conducted depending on the rating. A region that has been
6
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indicated to be a good candidate for regulation revision should be examined
in more detail by the State and the Regional office of the EPA, including
an examination of current air quality, emissions, and fuel use data, with
which the state has more familiarity. If the state feels that clean fuels
could be saved in a region rated marginal then an analysis of air quality
data that may have become available since this report should be examined.
If current data do not indicate a potential for regulation revision then
further study would not be warranted. An AQCR that has been indicated to
be a poor candidate would not warrant further study unless the state feels
that new information has become available indicating that the poor rating
is no longer valid.
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TABLE 2-1
DISTRICT OF COLUMBIA
IMPLEMENTATION PLAN REVIEW
(SUMMARY)
"Indicators" TSP SO;
Does the District of Columbia have air quality
standards which are more stringent than NAAQS? Yes Yes
Does the District of Columbia have emission
limiting regulations for control of:
1. Power plants Yes Yes
2. Industrial sources Yes Yes
3. Area sources Yes Yes
t Did the District of Columbia use an example region
approach for demonstrating the attainment of NAAQS or
more stringent standards? No No
Has the District of Columbia not initiated action
to modify combustion source emission regulations for fuel
savings; i.e'., under the Clean Fuels Policy? Yes Yes
Are there no_ proposed Air Quality Maintenance Areas? No No
t Are there indications of a sufficient number of
monitoring sites within the region? Yes Yes
Is there an expected 1975 attainment date for
NAAQS in the Implementation Plan? Yes Yes
Based on (1973) Air Quality Data, are there no
reported violations of NAAQS? No No
Based on (1973) Air Quality Data, are there indi-
cations of a tolerance for increasing emissions? No No
t Are the total emissions from stationary fuel
combustion sources proportionally lower than those of
other sources? No No
Do modeling results for specific fuel combustion
sources show a potential for a regulation revision?3 No No
Based on the above indicators, what is the poten-
tial for revising fuel combustion source emission
limiting regulations? Poor Poor
a Modeling results available for power plants only.
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MONTGOMERY
COUNTY
LOUDOUN
COUNTY
ASHING
nc
PR INC
GEORGE'
COUNTYj
FAIRFAX
COUNTY
PRINCE
WILLIAM
COUNTY
FIGURE 2-1 NATIONAL CAPITAL INTERSTATE AIR QUALITY CONTROL REGION
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2.2 AIR QUALITY SETTING - DISTRICT OF COLUMBIA
2.2.1 Air Quality Control Region
The District of Columbia is a part of the National Capital Inter-
state Air Quality Control ^Region which also comprises the suburban counties
of Maryland and Virginia. This region has been classified Priority I for
both suspended particulates and sulfur dioxide and the District of Columbia
portion of the AQCR has been proposed as an Air Quality Maintenance Area
for these pollutants.
2.2.2 Ambient Air Quality Standards
The District of Columbia has adopted ambient air quality standards
for both.total suspended particulates and sulfur dioxide. As shown on
Table A-2, these standards are more stringent than the Federal standards
for both of these pollutants/ except for the annual standard for suspended
particulates which is identical. .
2.2.3 Air Quality Status
Air quality data for 1973 are summarized in Tables A-4 and A-5 for
suspended particulates and sulfur dioxide respectively. These data are
from the "Annual Report on the Quality of the Air in Washington, D.C. 197.3"
and the SAROAD data bank as of July 1974. The District of Columbia has a
comprehensive air monitoring network with which to determine the air quality
status.
Both the annual and 24-hour Federal primary standards for suspended
particulates were exceeded in the District of Columbia during 1973.
Sulfur dioxide levels exceeded the Federal annual standard in the
District of Columbia portion of the AQCR during 1973. No other violations
of the Federal S02 standard occurred in the region.
2.2.4 Emissions S umrna_ry_
A summary of particulate and sulfur dioxide emissions are presented
in Table A-6 and A-7 respectively. This information is from the "1973
Regional Emissions Inventory" compiled by the Metropolitan Washington Counci
of Governments.
10
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Fuel combustion sources within the District of Columbia contribute
approximately sixteen percent of the particulate and seventeen percent of
the sulfur dioxide emissions in the region. The number of fuel combustion
sources and the emissions attributed to these sources are shown in Table
A-8, and also Appendix D.
2.3 BACKGROUND TO THE DEVELOPMENT OF THE DISTRICT OF COLUMBIA'S CURRENT
IMPLEMENTATION PLAN x
2.3.1 Control Strategy For Particulate Matter And Sulfur Oxides
On August 4, 1970, the District of Columbia submitted an implemen-
tation plan, under the requirements of the 1967 Amendments to the Clean
Air Act, which was designed to attain the District's ambient air quality
standards for sulfur oxides and particulate matter in the National Capital
Interstate Air Quality Control Region. This implementation plan was eval-
uated by EPA to determine the extent to which it was consistent with the
1970 Amendments to the Act. On August 4, 1971, the Administrator forwarded
to the Honorable Walter E. Washington, Mayor of the District of Columbia,
a detailed evaluation of those portions of the District of Columbia's
implementation plan which were approved and those portions which required
changes in order to meet the requirements of the 1970 Amendments. The
approvability of the control strategies was determined by use of the Imple-
mentation Planning Program (IPP) and the associated diffusion model. This
modeling was used to predict the reductions in ambient concentrations of
pollutants achieved by the combined control strategies of the District,
Virginia, and Maryland.
The control strategies set forth by the District for particulate
matter and sulfur oxides were approved. Some of the emission limiting
regulations included in the approved strategies were adopted while some
were proposed.
11
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3.0 CURRENT ASSESSMENTS BASED ON IMPLEMENTATION PLAN REVIEW
The purpose of this section is to evaluate the available information
for the District of Columbia and determine the feasibility of revisions
to the SIP which would result in clean fuel conservation. The assessments
will be made by AQCR addressing each .type of fuel combustion source: power
plants, large industrial and commercial/institutional sources, and area
sources. The assessments must be made for each pollutant separately and
are made on the basis of seven criteria: (I) 1973 air quality violations;
(2) expected NAAQS attainment dates; (3) proposed Air Quality:Maintenance
Area (AQMA) designations; (4) total emissions; ..(&) portion of emissions
from District of Columbia, fuel combustion sources; (6) regional tolerance
for emissions increase; and .(7) po11utant priority classifications. Tables
B-I and B-2 tabulate these criteria for TSP and S02, respectively.
.As mentioned previously, regional air quality data for 1973 are pre-
sented in Tables .A-4 and Ar5 for total suspended particulates and sulfur
dioxide respectively. Table C-l shows the 1973 fuel use and fuel sulfur
content for the two District of Columbia power plants. The sulfur content
is an average content for the year, as variations of up to 20% are common.
Table C-2 ,is a summary of .modeling results for one of the power plants .
Although it is realized that there are some limitations to results obtained
by modeling, it is presented in this report as another indicator in assessing
the candidacy of a region to revise emission regulations.
Appendix D shows the fuel use and emissions data for the major fuel
combustion sources. Only those sources emitting 100 tons per year or more
of either particulates or sulfur dioxide are listed. Appendix E shows the
total fuel use for the District of Columbia.
The modeling analysis of the power plants was performed by the Walden
Research Division of Abcor Inc. The model used was a Gaussian plume model
developed by the Meterology Laboratory, EPA, and was based on 1972 plant
operations. Detailed information can be found in; Modeling Analysis of
Power Plants for Fuel Conversion, (Group III) September 9, 1974.
12
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3.1 DISTRICT OF COLUMBIA PORTION OF THE NATIONAL CAPITAL INTERSTATE
AIR QUALITY CONTROL REGION
3.1.1 Regional Assessment
The District of Columbia has been rated as a poor candidate for
revision of either participate or sulfur dioxide emission regulations.
During 1973, ambient levels of total suspended particulates exceeded
the Federal primary annual and 24-hour standards in the District of Colum-
bia (Table A-4). Violations of Federal standards also occurred in the
Maryland and Virginia portions of the AQCR, affording virtually no poten-
tial for increasing particulate emissions. The National Capital Interstate
AQCR has been proposed as an Air Quality Maintenance Area for particulate
matter.
Sulfur dioxide levels violated the Federal annual standard in the
District of Columbia portion of the AQCR during 1973 (Table A-5), while
24-hour values were close to the standard. There is no potential for in-
creasing sulfur dioxide emissions in the District of Columbia.
3.1.2 Power Plant Assessment
There are two power plants in the District of Columbia portion of
this region, the Buzzard Point and Benning plants. During 1973 Buzzard
Point fired oil, while the Benning plant fired both oil and coal (Table C-l),
These plants contribute approximately eight percent of the particuI ate»
and nine percent of the sulfur dioxide emissions in the region.
There are some modeling data for the Buzzard Point plant presented
in Table C-2 which show the maximum contribution to the ambient suspended
particulate and sulfur dioxide levels that are attributable to the plant.
The data indicate that with a switch to 3.0% sulfur coal, ambient levels
of sulfur dioxide would be severly impacted, thereby eliminating the pos-
sibility of a fuel switch.
3.1.3 Industrial, Commercial, Institutional Source Assessment
The major fuel combustion sources other than power plants are listed
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in Table D-'l, along with their emissions. Fuel use data where available
indicate that these sources are primarily oil fired, affording some poten-
tial clean fuel savings. However, as mentioned previously, there is no
potential for increasing either particulate or sulfur dioxide emissions,
therefore a switch to coal, or a higher sulfur content fuel oil is not
feasible. Point source fuel combustion contributes a minima.! amount of
the particulate and sulfur dioxide emissions in the region.
3.1.4 Area Source Assessment
Area source fuel combustion accounts for approximately five percent
of the particulate and sulfur dioxide emissions in the region. Fuel use
by area sources is shown in Table E-l. There does not appear to be a sig-
nificant clean fuel savings afforded by these sources.
3.1.5 Fuel Use Assessment
Fuel use data for the District of Columbia are presented in Appendix
E.
14
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APPENDIX A
IMPLEMENTATION PLAN BACKGROUND
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TABLE A-l
District of Columbia Air Pollutant Priority Classification
Air Quality Control
Regi on
National Capital Interstate
(Maryland, Virginia)
Priority .
Classification
Part. SO,
1975
Population
(Millions)
3.16
Proposed ,
AQMA Designations
The District of Columbia
has been proposed as an
AQMA for both TSP and S02
Criteria Based on Maximum Measured (or Estimated) Pollution Concentration in Area
Priority
II
III
Sulfur Dioxide:
Annual arithmetic mean
24-hour maximum
Particulate matter:
Annual Geometric mean
2 4'-hour maximum
Greater than
100
455
95
325
From - To Less than
(yg/m3) (yg/m3)
60 - 100 60
260 - 455 260
60 - 95 60
150 - 325 150
Federal Register, August, 1974, SMSA's showing potential for NAAQS violations due to growth.
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TABLE A-2
Ambient Air Quality Standards
Total Suspended Particulates(yg/m3) Sulfur Dioxide(yg/m3)
Federal
District of
Columbia
Primary
Secondary
Primary
Secondary
Annual
75(G)
60 (G)
75(G)
60(G)
24-Hour
260a
150a
160a
140a
Annual
80 (A)
75(A)
57(A)
24-Hour 3-Hour
365a
1300a
285a
225a
1-Hour
-
860a
715a
(G) Geometric mean
(A) Arithmetic mean
a - Not to be exceeded more than once per year
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TABLE A-3
AMBIENT AIR QUALITY STANDARDS ATTAINMENT DATES3
DISTRICT OF COLUMBIA
Particulates Sulfur Dioxide
Primary Secondary Primary Secondary
7/75 7/75 7/75 7/75
Attainment dates as submitted in State Implementation Plan.
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TABLE A-4
DISTRICT OF COLUMBIA AIR QUALITY STATUS (1973), TSPa
TSP Concentration
AQCR
National Capital Inter-
state (VA, MD)
DC Portion of AQCR
#
Stations
Reporting
64
11
a Sources of data: National Air Data
Highest
Annual
85
85
Bank, July
Reading
24-Hr.
66 8d
456e
28, 1974
Violations based on more than one reading in excess of
C Formu1a: [2nd Highest
24-Hr - 24 Hr
Secondary
>
Standard
2nd
Highest
Reading
24-Hr.
351 d
415e
; Annual Report
standard
Ambient Air
Primary
Annual 24-Hr&
2 3
1 2
on The Quality of
Quality Standards
Secondary
Annual % 24-Hrb %
7 11 7 11
2 18 6 55
the Air in Washington, D.C., 1973
Reduction
Required
to Meet r
Standards'"
+65
+71
Standard
on Which %
Reduction
Is Based
24-Hr
24-Hr
1 v inn (Annual - Annual Secondary Standard] lnn
Background Value: 40 yg/m
Reading recorded in Virginia portion of AQCR
Values can be attributed to fugitive dust emissions rather than fuel burning emissions
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TABLE A-5
DISTRICT OF COLUMBIA AIR QUALITY STATUS (1973),
AQCR
National Capital Inter-
#
Stations
Reporting
24-Hr
(Bubbler)
26
S00 Concentration
#
Stations
Reporting Highest
(Contin.) Annual
12e 12
Reading
24-Hr.
351
(pg/m ) i Stations E>
2nd Ambient Air Qua
Highest
Reading Primary
24-Hr Annual % 24-Hrb
322 1 25 0
needing %
ility Stds. Reduction
Required
Secondary To Meet
% 3-Hr Standards
N.A. +14
Standard
on which %
Reduction
Is Based
Annual
state (VA, MD)d
a Sources of Data: National Air Data Bank, July 28, 1974: Annual Report on The Quality of the Air in Washington, D.C. 1973
b
Violation based on 2nd highest reading at any station
Formula:
2nd Highest 24-Hr - 24-Hr Standard] ,nn (Annual - Annual Standard
1 2nd Highest 24-Hr I x wu, y Annual
xlOO
Values shown are for D.C. portion of AQCR
Includes four stations in D.C.
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TABLE A-6
DISTRICT OF COLUMBIA PARTICULATE EMISSIONS SUMMARY6
Air Quality
Control Region
National Capital
Dist. of Columbia
Other (Md. & Va.)
Total
Total
(103 tons/yr) %
7.2
27.1
34.3
21
79
100
Electricity Generation Point Source Fuel
(103 tons/yr) % (103 tons/yr)
2.6 36
10.3 38
12.9
1.3
0.8
2.1
Combustion
%
18
3
Area Source Fuel Combustion
(IQ3 tons/yr) %
1.6
1.6
3.2
22
6
Source: 1973 Regional Emissions Inventory, Metropolitan Washington Council of Governments, March 3, 1975
Excludes emissions from electricity generation
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TABLE A-7
DISTRICT COLUMBIA SULFUR DIOXIDE EMISSIONS SUMMARY3
HI r guai i ty
Control Region
National Capital
District of Columbia
Other (Md. and Va.)
Total
lUld 1
(103 tons/yr)
41.1
196.3
237,4
%
17
83
100
(103 tons/yr) %
20.3 49
173.5 89
193.8
(103 tons/yr) %
7.2 18
4.2 2
11.4
(103 tons/yr)
12.4
16.0
28.4
%
30
8
a Source: 1973 Regional Emissions Inventory, Metropolitan Washington Council of Governments, March 3, 1975
Excludes emissions from electricity generation
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TABLE A-8
DISTRICT OF COLUMBIA FUEL COMBUSTION SOURCE SUMMARY
Other Fuel Combustion District of Columbia Emissions Total AQCR Emissions0 % Emissions From ,
p Point Sources9 (103 tons/yr) (IQ3 tons/yr) D.C. - Fuel Combustion
Plants Part. SO? Part. S0_2_ Part. SO? Part. S0_2
2 5 15 5.5 39.9 34.3 237.4 16 17
a Sources other than power plants which emit more than 100 tons per year of the specified pollutant.
Emissions from fuel combustion only
0 Emissions from all sources
Percent of total AQCR emissions
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TABLE A-9
DISTRICT OF COLUMBIA FUEL COMBUSTION EMISSION
LIMITING REGULATIONS
Parti cul ate Matter
A. For instal lations using less than 3.5 x 10^ BTU/hour total
heat input, emissions are not to exceed 0.13 pounds/hour.
B. For installations using more than 3.5 x 10^ but less than
10,000 x 10° BTU/hour total heat input, emissions are not
n
to exceed 0. I7455H" ' ^ pounds/hour where H equals the
total heat input in I06 BTU/hour. (Figure A- I )
C. For installations using more than 10,000 x 10° BTU, emissions
are not to exceed 0.02 pounds/hour.
II. Sulfur Oxides
A. Fuel oils limited to 1% or less sulfur by weight. On and
after July I, 1975, the sulfur content of such fuel oil is
limited to 0.5% or less sulfur by weight.
B. Coal sulfur content is limited to 1% or less by weight. On
and after July I, 1975, the sulfur content of such coal
shall not exceed 0.5% by weight: provided that when the
Commissioner certifies that the combustion - gas - desulfuri-
zation system used at a stationary source results in sulfur
oxide emissions no greater than the emissions normally result-
ing from the burning of coal with 1% sulfur content and,
after July I, 1975 with 0.5% sulfur content, coal of a higher
sulfur content may be burned at such stationary source.
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X
to
FIGURE A-l
ALLOWABLE PARTICULATE EMISSIONS FROM FUEL COMBUSTION SOURCES
ivi
.01
3.5
100 1,000
Total Heat Input (TO6 BTU/Hour)
10,000
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APPENDIX B
REGIONAL SUMMARY
-------
TABLE B-1
SUMMARY OF INDICATORS FOR REVISION OF PARTICULATE EMISSION REGULATIONS
A1r Qua11ty Particulate % Emissions
Number of Number of Emissions , From D. C. TSP Attainment AQMA
Stations Violations (103 tons/yr) Fuel Combustion Priority Date Proposed?
National Capital
Interstate AQCR 64 14 7.2 16 I 7/75 Yes
a Violations of secondary standards
District of Columbia sources only
c Percent of total region emissions
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TABLE B-2
SUMMARY OF INDICATORS FOR REVISION OF S02 EMISSION REGULATIONS
Al>
National Capital
Number of
Stations
38
Number of
Violations
1
S0?
Emissions
(10-3 tons/yr)
41.1
% Emissions
From D. C. .
Fuel Combustion
17
S0£
Priority
I
Attainment
Date
7/75
AQMA
Proposed?
Yes
District of Columbia sources only
Percent of total region emissions
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APPENDIX C
POWER PLANT SUMMARY
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TABLE C-l
DISTRICT OF COLUMBIA POWER PLANT FUEL USE SUMMARY3
Plant
Benning
Buzzard
Point
1973 Capacity
(MW)
718.
270.
34
0
1973 Fuel Use
Type
Coal
Oil
Oil
%
0.
0.
0.
s
9
9
9
Quantity5
260
4122
1225
1974
%
0.
0.
0.
Fuel
, S
83
80
96
SIP
% S
1.
1.
0
0
a Source: FPC Form #67 May 1, 1974. Steam-electric air & water quality control data for
year ending Dec. 31, 1973.
Coal quantity is in 103 tons, oil is in 103 barrels.
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TABLE C-2
SUMMARY OF POWER PLANT MODELING RESULTS3
Maximum 24-Hour Concentration
Plant
Buzzard Point
1972 Operations13
Fuel Switch0
Nominal
Load
128
445
S02
Maximum
Load
246
808
Parti culates
Nominal Maximum
Load Load
15 26
17 34
Maximum Annual
Concentration (yg/m3)
S02 Parti culates
15 1
45 2
a Source: Modeling Analysis of Power Plants For Fuel Conversion, Group III Wai den Research
Sept. 9, 1974
Based on 0.9% sulfur residual oil
c Switch to 3.0% sulfur coal
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ADDENDUM TO APPENDIX C
USE AND LIMITATIONS OF MODELING ANALYSIS DATA3
1. The data inputs for the modeling have been extracted from the
appropriate FPC Form 67 and the most representative meteorological data
available. However, to calculate the occurrence of the highest 24-hour
concentration, assumptions as to the daily emission rate are necessary.
The results of the modeling exercise provide a range of the most probable
maximum concentration.
2. It should be recognized that time and data constraints are such
that the model predictions are useful but not omniscient. There are no
data available, in general, to "validate" the model. Therefore, all
vant data, including hard data on actual daily plant operations, should
be obtained, reviewed, and evaluated. In this way, the modeling results
can be used as a logical part of the entire decision-making framework, not
as an arbitrary, dogmatic absolute "answer", divorced from the real situation
involved. In some cases it will be necessary to adjust the model's predic-
tions based upon more complete and detailed information on a particular
plant's operations.
3. Results of these evaluations are not intended to be used in any
legal actions, including both public hearing and court proceedings. The
very nature of atmospheric dispersion modeling is such that results are not
suitable to legally prove (or disprove) a particular modeling result. The
assumptions and judgments necessarily involved in modeling tend to mitigate
against proof in a legal sense.
4. The best use of the data is in negotiations with states or sources
in trying to establish a rational course of action to be followed with reason-
able assurance that the air quality impact will be as indicated by the model.
Extracted from comments by the Monitoring and Data Analysis Division, OAQPS
-------
APPENDIX D
INDUSTRIAL, COMMERCIAL, INSTITUTIONAL SOURCE LISTING
-------
TABLE D-l
INDUSTRIAL, COMMERCIAL, INSTITUTIONAL SOURCE LISTING0
Fuel Use
Source
Central Heating Plant
West Heating Plant
Washington Navy Yard
Capitol Power Plant
Saint Elizabeth's Hosp.
Washington Terminal Co.
Naval Research Lab
Walter Reed AMC
Howard Univ.
Washington Hosp. Center
D.C. General Hosp.
U.S. Soldiers Home
Anacostia Naval Station
Boiling AFB
Georgetown Univ.
Type Quan ti tyb
Emissions (Tons/Year)
Coal
Coal
Oi
Oi
Oi
Oil
Oil
120
100
204
87.9
36.7
40.5
51.5
Part.
102
259
405
270
58
121
49
47
34
29
22
22
19
19
19
SO?
1558
1084
927
562
399
356
341
319
215
199
153
150
130
130
103
Sources listed are those that emitted 100 tons or more of either
particulate matter or sulfur dioxide during 1973. Data are from
D.C. Emission Inventory (May I, 1974) except for fuel use data
which are from NEDS.
Coal is in 10^ tons, oil is in 10^ barrels.
-------
APPENDIX E
FUEL USE SUMMARY
-------
TABLE E-l
DISTRICT OF COLUMBIA FUEL USE SUMMARY*
Coal (IP3 tons)
Anthracite Bituminous
Oil (IP3 Barrels)
Residual
Distillate
Gas (1Q6 Cu. Ft.)
Natural Process
Area Sources
Residential
Indust., Comm.,
Inst.
Total
0
0
3
280
283
1,524
2,814
4,338
1,037
629
1,666
17,226
11,817
29,043
0
0
Point Sources
External
Elec. Gen.
Indust., Comm.,
Inst.
Total
Grand Total
0
0
0
0
260
223
483
766
5,347
800
6,147
10,485
0
162
162
1,828
0
545
545
29,588
0
0
0
0
Source: 1973 Regional Emissions Inventory, Metropolitan Washington Council of Governments,
March 3, 1975
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
\. REPORT NO.
EPA-450/3-75-039
3. RECIPIENT'S ACCESSIONING.
4. TITLE AND SUBTITLE
IMPLEMENTATION PLAN REVIEW FOR DISTRICT OF COLUMBIA
AS REQUIRED BY THE ENERGY SUPPLY AND ENVIRONMENTAL
COORDINATION ACT
5. REPORT DATE
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
8. PERFORMING ORGANIZATION REPORT NO
9. PERFORMING ORGANIZATION NAME AND ADDRESS
10. PROGRAM ELEMENT NO.
U.S. Environmental Protection Agency, Office of Air
Quality Planning and Standards, Research Triangle
Park, N.C., Regional Office III, Philadelphia,
Pa., and TRW, Inc., Vienna, Virginia
11. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS
U.S. Environmental Protection Agency
Office of Air and Waste Management
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
13. TYPE OF REPORT AND PERIOD COVERED
Final
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 interferring 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
b.lDENTIFIERS/OPEN ENDED TERMS
c. COSATI Field/Group
Air pollution
State Implementation Plans
8. DISTRIBUTION STATEMENT
Release unlimited
19. SECURITY CLASS (This Report)
Unclassified
21. NO. OF PAGES
38
20. SECURITY CLASS (Tills page)
Un c1assified
22. PRICE
EPA Form 2220-1 (9-73)
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