EPA-450/3-75-041

APRIL 1974
      IMPLEMENTATION PLAN REVIEW
                   FOR
              TENNESSEE
              AS REQUIRED
                    BY
            hi i!-:  .  • ':  :  si -i  a -
                   AND
   ENVIRONMENTAL COORDINATION ACT
      U. S. ENVIRONMENTAL PROTECTION AGENCY

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EPA-450/3-75-041

APRIL 1974
     IMPLEMENTATION PLAN REVIEW
                  FOR
             TENNESSEE
             AS REQUIRED
                  BY
          THE ENERGY SUPPLY
                  AND
   ENVIRONMENTAL COORDINATION ACT
     U. S. ENVIRONMENTAL PROTECTION AGENCY

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                                           EPA-450/3-75-041
                      TENNESSEE

 ENERGY SUPPLY AND ENVIRONMENTAL COORDINATION ACT

   SECTION IV - STATE IMPLEMENTATION PLAN REVIEW
      PREPARED BY THE FOLLOWING TASK FORCE:

   U.S. Environmental Protection Agency, Region IV
              1421 Peachtree Street, NE
               Atlanta, Georgia 30309

    Energy and Environmental Systems Division
           Argonne National  Laboratory
            Argonne, Illinois 60439
                (EPA-IAG-D5-0463)


     U.S. Environmental Protection Agency
      Office of Air and Waste Management
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
                     April  1975

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                         IMPLEMENTATION PLAN REVIEW

                                    FOR

                                 TENNESSEE

      Required by the Energy Supply and Environmental  Coordination Act

                              Table of Contents

                                                                       Page

1.0  EXECUTIVE SUMMARY	    1

2.0  TENNESSEE STATE IMPLEMENTATION PLAN REVIEW  	    6

     2.1   Summary	    6

     2.2   Air Quality Setting for the State of Tennessee 	   10

          2.2.1   Tennessee Air Quality Control  Regions 	   10
          2.2.2   Tennessee Ambient Air Quality Standards 	   10
          2.2.3   Tennessee Air Quality Status.	10
          2.2.4   Tennessee Emissions Summary 	   13

     2.3   Background on  the Development of the Current
          State  Implementation Plan	13

          2.3.1   General  Information 	   13
          2.3.2   Particulate Control  Strategy  	   14
          2.3.3   Sulfur  Dioxide Control  Strategy  	   14
                                    m

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                       IMPLEMENTATION PLAN REVIEW
                                  FOR
                         THE STATE OF TENNESSEE
       REQUIRED BY THE ENERGY SUPPLY AND ENVIRONMENTAL COORDINATION ACT

1.0  EXECUTIVE SUMMARY
     The enclosed report is the U. S. Environmental  Protection Agency's
(EPA's) response to Section IV of the Energy Supply  and Environmental
Coordination Act of 1974 (ESECA).  Section IV requires EPA to review each
State Implememtation Plan (SIP) to determine if control regulations for
stationary fuel combustion can be revised without interfering with the
attainment and maintenance of the National Ambient Air Quality Standards
(NAAQS).  In addition to requiring that EPA advise the state as to whether
control regulations can be revised, ESECA provides that EPA must approve
or disapprove any revised regulations relating to fuel burning stationary
sources within three months after they are submitted to EPA by the states.
The states may, as under the Clean Air Act of 1970,  initiate State Implemen-
tation Plan revisions; ESECA does not, however, require states to change
any existing plan.
     Congress has intended that this report provide  the state with
information on excessively restrictive control regulations.  The intent of
ESECA is that SIPs, wherever possible, be revised in the interest of con-
serving low-sulfur fuels or converting to coal, sources which burn oil or
natural gas.  EPA's objective in carrying out the SIP reviews, therefore,
has been to try to determine if emissions from certain combustion sources
may be increased without interfering with the attainment and maintenance
of standards.  If so, it may be possible through altered resource allocations
to effect significant "clean fuel savings" in a manner consistent with both
environmental and national energy needs.
     In many respects, the ESECA SIP reviews parallel the implementation
of EPA's policy on clean fuels.  Under the Clean Fuels Policy, implementation
plans have been reviewed with a view to saving low sulfur fuels.  Where the
primary sulfur dioxide air quality standards will not be exceeded, states
have been encouraged  to either defer attainment of secondary standards or
to revise the S0£ 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.
                                    1

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     To date, this activity has involved only those states with the
largest clean fuels savings potentials.   Several  of these states have revised
or are currently in the process of revising their S02 regulations.   These
states are generally in the eastern half of the United States.   ESECA, how-
ever, requires the analysis of potentially over-restrictive regulations in
all 55 states and territories.  In addition, the current reviews address
the attainment and maintenance of all the National Ambient Air Quality
Standards.
     The adoption of emission limitations which may, in some areas  of the
states, be overly restrictive (or not restrictive enough) resulted  largely
from the use of the "example region" approach along with analyses which
considered the "hot spots" of an Air Quality Control Region (AQCR)  rather
than the entire region.  This type of approach was offered in EPA guidelines
for plan development when states were preparing their original  plans.  Many
states, through concurrence with EPA, adopted the example region approach,
largely because of the short timetable dictated by the Clean Air Act.  Also,
in most cases, the original SIPs were designed to attain and maintain the
original NAAQS, some of which have since been designated as "guides" only
or actually rescinded.  However, many states adopted and retained the
original federal standards or, in a few cases, adopted more restrictive
state standards, and these served as the basis on which their SIPs  were
approved.  As a result, the requirements of many state plans conflict with
legitimate national energy concerns, and thus a review of the State Imple-
mentation Plans is a logical follow-up to EPA's initial appraisal (1972) of
the SIPs.  At the time, SIPs were approved by EPA if they demonstrated the
attainment of the original NAAQS or the more stringent state air quality
standards.  Also, at that time an acceptable method for formulating control
strategies was the use of an example region for demonstrating the attainment
of the standards.
     The example region concept permitted a state to identify the most
polluted air quality control region and adopt control regulations which would
be adequate to attain the NAAQS in that region.   In using an example region,
it was assumed that NAAQS would be attained in the other AQCRs of the state
if the control regulations were applied to similar sources.  But use of an
example  region can result in excessive controls, especially in the utiliza-
tion of  clean fuels, for areas of the state where sources would not
                                    2

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otherwise contribute to NAAQS violations.   For example, a control  strategy
based on a particular region or source can result in a regulation  requiring
one percent sulfur oil to be burned statewide, even though the use of three
percent sulfur coal would be adequate to attain NAAQS in some locations.
     EPA anticipates that a number of states will use the review
findings to assist them in deciding whether or not to revise portions of
their State Implementation Plans.  However, it is most important for such
states to recognize the limitations of the present review.  The findings  of
this report are by no means conclusive and are neither intended nor adequate
to be the sole basis for SIP revisions; they do, however, represent EPA's
best judgment and effort in complying with the ESECA requirements.  The time
and resources which EPA has had to prepare the reports has not permitted
the consideration of growth, economics, and control strategy tradeoffs.  Also,,
there has been only limited dispersion modeling data available by  which to
address individual point source emissions.  Where the modeling data for
specific sources was found, however, it was used in the analysis.
     The data upon which the reports' findings are based is the most
currently available to the federal government.  However, EPA believes that
the states possess the best information for developing revised plans.  The
states have the most up-to-date air quality and emissions data, a  better
feel for growth, and the fullest understanding for the complex problems
facing them in the attainment and maintenance of air quality.  Therefore,
those states desiring to revise a plan are encouraged to verify and, in
many instances, expand the modeling and monitoring data used to support
EPA's findings.  States are encouraged to consider the overall impact which
the potential relaxation of overly restrictive emissions regulations for
combustion sources might have on their future control programs.  This may
include air quality maintenance, prevention of significant deterioration,
increased TSP, NOX, and HC emissions which occur in fuel switching, and
other potential air pollution situations.
     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 (SOg) emissions.  This is
because stationary  fuel combustion sources constitute the greatest source
of SO  emissions and are a major source of TSP emissions.

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     The following are the principle findings  for  the  State  of Tennessee
(Air Quality Control  Regions  are displayed  in  Figure  1-1):
     •  The State has adopted the federal National  Ambient Air Quality
        Standards for particulate matter and SCL.   In  addition, the
        State has retained the former federal  secondary  annual  S02
        standard and  has  a secondary 24-hour S02 standard which is
        slightly more stringent than the federal primary S02 standard.
     •  The original  particulate and sulfur dioxide emission limitations
        were developed under  the example region concept.  In November of
        1973 the sulfur dioxide fuel  combustion regulations  were revised,
        based upon individual analyses for  each major  power  generating
        facility.   EPA approved this  revised regulation  as a plan revision
        in August of  1974 except for the Kingston  Steam  Plant,  located
        in Roane County and the Johnsonville Steam Plant, located in
        Humphreys County  where the original emission limit remains in
        effect.
     •  Within the framework  of this  limited analysis, there appears
        little margin for relaxing particulate fuel combustion  emission
        regulations in any of the Tennessee AQCR's, as all AQCR's in
        the State report  violations of the  particulate NAAQS.
     t  Based on modeling results and reported air quality violations,
        no potential  exists for S02 regulation relaxation in the
        Tennessee  portion  of  the  Eastern Tennessee-Southwestern
        Virginia Interstate (#207)  AQCR.  In the Middle Tennessee
        Interstate (#208), modeling results for major fuel combus-
        tion  sources  indicate a  potential for  regulation relaxation in
        all  areas  except  in the  vicinity of the Johnsonville  Steam
        Plant in Humphreys County.  Based on reported air quality data,
        the potential  for  regulation  revision  exists in the  Metropolitan
        Memphis  Interstate (#18),  Tennessee Valley-Cumberland Mountains
        Interstate (#7),  Chattanooga  Interstate (#55) and the Western
        Tennessee  Intrastate  (#209).   However, since only limited model-
        ing data is currently available  for these  regions, a  detailed
        analysis is necessary to  determine  the degree of relaxation and
        its  consequences  in Clean  Fuels Savings.
                                    4

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WESTERH
TENNESSEE
INTRASTATE
     \ (#209)
    TENNESSEE RIVER VALLEY
    CUMBERLAND MOUNTAINS
    INTERSTATE (ALABAMA-TENNESSEE)
(#18)
CHATTANOOGA INTERSTATE
(GEORGIA- TENNESSEE)
    (#55)
                                                                        (#207)
     Figure 1-1.   Tennessee Air Quality  Control Regions (AQCRs)

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2.0  TENNESSEE STATE IMPLEMENTATION PLAN REVIEW
2.1  SUMMARY
     A revision of fuel combustion source emissions regulations will  depend
on many factors.   For example:
     •  Does the state have air quality standards which are more
        stringent than NAAQS?
     •  Does the state have emission limitation regulations for
        control of (1) power plants, (2) industrial sources, (3)
        area sources?
     •  Did the state use an example region approach for demon-
        strating the attainment of NAAQS ojr more stringent state
        standards?
     •  Has the state inditiated action to modify combustion
        source emission regulations for fuel savings; i.e., under
        the Clean Fuels Policy?
     •   Are there proposed Air Quality Maintenance Areas?
     •  Are there indications of a sufficient number of monitoring
        sites within a region?
     •  Is there an expected 1975 attainment date for NAAQS?
     •  Based on (1973) air quality data, are there reported
        violations of NAAQS?
     t  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?
     t  Is there a significant  clean fuels savings potential in
        the region?
     This SIP  review has answered these questions  based on an overall
evaluation of  EPA's current information.  Based on these answers, each AQCR has
been assessed  as good, marginal, or poor candidate for regulation relaxation.
Table 2-1 summarizes the conclusions of this State Implementation Plan Review
and gives the  overall candidacy assessment for each AQCR.

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     The 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 data of
   1975 for NAAQS in
   the SIP
4) No proposed AQMAs
5) Modeling results
   show a potential
   for regulation
   revision
        Poor
Marginal
1) Violation of NAAQS  1)  No air quality data or
2) Attainment data for    insufficient number of
   NAAQS later than       monitoring sites
   1975                2)  Inconsistent "indicators"
3) Proposed AQMA
4) Model results show
   no potential for
   regulation
   revision
     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  sufficient
air quality data.  In Priority III regions, air monitoring  was not  required

during 1973; therefore there are little if any data  with which to determine

the current air quality status.  Marginal  ratings  are  also  given when  there

are varying or inconsistent "indications".

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                                  Table  2-1.   State  Implementation Plan  Review  (Summary)
                                                                  TENNESSEE
                                                                  RIVER VALLEY
                                                                  -CUMBERLAND   METROPOLITAN
EASTERN
TENNESSEE
-SOUTHWESTERN   MIDDLE
WESTERN

"INDICATORS"
• Does the State have air quality standards
which are more stringent than NAAQS?
• Does the State have emission limiting regu-
lations for control of:
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 initiated action to modify
combustion source emission regulations for fuel
savings; i.e., under the Clean Fuels Policy?
• Are there proposed Air Quality Maintenance
Areas?
• Are there indications of a sufficient number
of monitoring sites within a region?
• Is there an expected 1975 attainment date
for NAAQS? 5
• Based on reported (1973) Air Quality Data,
does air quality meet NAAQS?
• Based on reported (1973) Air Quality Data,
are there indications of a tolerance for
increasing emissions?
• Are the total emissions from stationary fuel
combustion sources lower than those of other
sources?
• Do modeling results for specific fuel combustion
sources show a potential for a regulation revision?
• Based on the above indicators, what is the
potential for revising fuel combustion source
emission limiting regulations?
• Is there a significant Clean Fuels Saving
potential in the region?
MOUNTAINS MEMPHIS CHATTANOOGA VIRGINIA TENNESSEE T^.c^lr
INTERSTATE INTERSTATE INTERSTATE INTERSTATE INTRASTATE INTRASTATE
STATE AQCR # 7 AQCR # 18 AQCR # 55 AQCR # 207 AQCR # 208 AQCR # 209
TSP S02
NO
YES
YES
YES
YES
NO









YES1
YES
YES
YES
4
YES









TSP S02




NO
YES
YES
NO
NO
NO
NDA
Poor
N/A




NO
YES
2
YES
YES
NO
NDA
Good
NDA
TSP S02




NO
YES
YES
NO
NO
YES
NDA
Poor
N/A




NO
YES
2
YES
YES
NO
YES
Good
NDA
TSP S02




YES
YES
YES
NO
NO
YES
NDA
Poor
N/A




NO
YES
2
YES
YES
NO
NDA
Good
NDA
TSP S02




NO
YES
YES
NO
NO
NO
NDA
Poor
N/A




NO
YES
YES
NO
NO
NO •
HO
Poor
NO
TSP S02




YES
YES
YES
NO
NO
NO
NDA
Poor
N/A




NO
YES
2
YES
YES
NO
YES
Good
YES
TSP S02




NO
YES
YES
NO
NO
YES
NDA
Poor
N/A




NO
NDA
3
NDA
N/A
NO
NDA
Margi-
lal
NDA
CO

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                   Table  2-1.   State  Implementation  Plan  Review  (Summary)   (Continued)
         The  State  has  secondary  annual  and  24-hour  standards which  are more  stringent than  the
         federal  primary  standards.

        2
         Presently  meeting  standards

        2
         Attainment schedule  indicates  region  is  below standards;  current  data  is  unavailable

        4
         The  revised control  strategy considered  modeling  for individual power  plants



         Based  on approved  attainment dates  in the Federal  Register  (May 31,  1972)



        NDA =  No data available


10       N/A =  Not  available

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 2.2  AIR QUALITY SETTING FOR THE STATE OF TENNESSEE

 2.2.1  Tennessee Air Quality Control  Regions

      The State of Tennessee is divided into six Air Quality Control  Regions
 as shown in Figure 1-1.   There are four interstate and two intrastate
 regions.  Only two regions -- the Tennessee River Valley-Cumberland  Mountains
 Interstate (#7) and the  Western Tennessee Intrastate (#209) -- have  a rela-
 tively small  population  density (less than 75 people per square mile).
 Based on present conditions and growth projections for the state, two
 counties in Tennessee -- Davidson County in the Middle Tennessee Intrastate
 (#208) and Hamilton County in the Chattanooga Interstate (#55) -- have
 been designated as proposed Air Quality Maintenance Areas (AQMAs) for
 particulate matter.  No  Tennessee counties have been proposed as AQMAs
 for sulfur dioxide.
2.2.2  Tennessee Ambient Air Quality Standards
     All the federal primary and secondary National Ambient Air Quality
Standards (NAAQS) for particulates, sulfur dioxide and nitrogen dioxide
apply in Tennessee.  In addition the state has an annual sulfur dioxide
standard equivalent to the old federal annual secondary sulfur dioxide
standard which has been rescinded by EPA.  Tennessee also has a secondary
24 hr S02 standard of 364 ;jg/M .  These state S02 standards are more
stringent than the present federal primary standards.  Tennessee air
quality standards are summarized in Table 2-2.  This review considers
only the attainment of the federal NAAQS.
2.2.3  Tennessee Air Quality Status
     Based on data in the SAROAD data banks as of June, 1974, both the
annual and 24 hour particulate NAAQS are being violated in all regions
except for the Eastern Tennessee - Southwestern Virginia Interstate (#207)
and the Western Tennessee Intrastate (#209).  In these two AQCR's, the
24 hour NAAQS is being violated.
     S02 air quality data is unavailable for the Western Tennessee Intra-
state (#209) and no annual data is available for the Tennessee River Valley-
Cumberland Mountains Interstate (#7), Metropolitan Memphis Interstate (#18)
                                    10

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                                     NASHVILLE-DAVIDSON
                                          CHATTANOOGA
               SCALE
          O 1O  20  3O 40 SO MILES
          I •  I  I   I   I  -I
                                                                                LEGEND

                                                    DESIGNATION     ®   Places of lOO.OOO or more inhabitants
                                                                     O   Places of 25,000 to 50,000 inhabitants outside SMSA's
                                                                               Standard Metropolitan
                                                                                Statistical Areas (SMSA's)
Figure  2-1.   Proposed Tennessee Air Quality Maintenance Areas   (AQMAs)

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                                  Table 2-2.   Tennessee Ambient Air Quality Standards
                                             All Concentrations in yg/nT

Federal
State

Primary
Secondary
Primary
Secondary
Total Suspended
Annual
75 (G)
60 (G)
75 (G)
60 (G)
Particulate
24 -Hour
260a
150a
260a
15 Oa
Sulfur Oxides
Annual 24 -Hour 3 -Hour
80 (A) 365a
1300a
80 (A) 365a
60 (A)b 364a 1300a
Nitrogen Dioxide
Annual
100 (A)
100 (A)
100 (A)
100 (A)
     to be exceeded more than once per year.


 Was adopted based on original EPA policy which was rescinded July, 1973

(A)     Arithmetic mean
(G)     Geometric mean

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and the Eastern Tennessee - Southwestern Virginia Interstate (#207).  The
only reported violation of any standard occurred in the Eastern Tennessee-
Southwestern Virginia Interstate (#207), where the 24 hour S02 NAAQS
is exceeded.
2.2.4  Tennessee Emissions Summary
     Tennessee fuel combustion sources account for less than 50% of the
total particulate emissions in all AQCR's except for the Middle Tennessee
Intrastate (#208).  The largest fraction of particulate emissions from
fuel burning in Tennessee comes from industrial/commercial/institutional
point sources in the Chattanooga Interstate (#55) and the Eastern Tennessee-
Southwestern Virginia Interstate (#207), area sources in the Tennessee
River Valley - Cumberland Mountains Interstate (#7), Metropolitan Memphis
Interstate (#18) and the Western Tennessee Intrastate (#209) and power
plants in the Middle Tennessee Intrastate (#208).
     In all AQCR's in which there are Tennessee power plants, these sources
contribute over 50% of the total S02 emissions.  For regions without power
plants, the largest fraction of Tennessee fuel combustion S02 emissions
emanate from area sources in the Tennessee River Valley - Cumberland
Mountains Interstate (#7) and the Western Tennessee Intrastate (#209) and
industrial/commercial/institutional point sources in the Chattanooga
Interstate (#55).
2.3  BACKGROUND ON THE DEVELOPMENT OF THE CURRENT STATE IMPLEMENTATION PLAN ,
2.3.1  General Information
     The example region approach was used to  develop the original Tennessee
State  Implementation Plan.  The Eastern Tennessee - Southwestern Virginia
Interstate (#207) was selected as the example region for both suspended
particulates and sulfur dioxide.  The control stragegy for particulates
was tested with the Air Quality Display Model (AQDM) and the proportional
model.  The AQDM was utilized in Knoxville and Nashville while the pro-
portional model was applied in Memphis and Chattanooga.  As for sulfur
dioxide, the AQDM and/or the proportional model were applied, depending
on the individual counties within the example region.   The S02 control strategy
was revised in November of 1973, with the revision based on the AQDM, pro-
portional modeling and the analysis of individual power plants.
                                    13

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2.3.2  Particulate Control Stragegy
     The control stragegy for participate emissions from fuel combustion
sources consists of enforcing Section 2 of Chapter VI of the Tennessee
Air Pollution Control Regulation.  The regulations are designed to meet
the annual secondary NAAQS throughout Tennessee and consist of two sections-
one for existing and one for new sources.  The pertinent portions of the
regulations are summarized in Table 2-3 and Figure 2-2.
2.3.3  Sulfur Dioxide Control Straqeqy
     The original control strategy for SOp fuel combustion emissions was
amended by the Tennessee Air Pollution Control Board in  November of 1973.
The revised strategy assigns each county in the state a  classification of
either Class I, Class II or Class III based on the following criteria:

                                           Class I      Class II  Class III
                                         Greater than   From-to   Less than
        Annual arithmetic mean Cug/M3)      100          60-100     60
        24 hour maximum (.ug/M3)             455         260-455    260
         3 hour maximum (xig/M )                            1300
        A                                 3
         Any concentration above 1300 pg/M

Emmision standards for each class of counties are as follows:

        Class IA	1.6 lb/106Btu
        Class I	1.6 lb/106 Btu
        Class II	3.0 lb/106 Btu
        Class III	4.0 lb/106 Btu
The classification system placed Polk County in Class IA; Maury, Roane and
Sullivan Counties in Class I; Humphreys County in Class  II; and all other
 counties  in Class  III.   Control  strategy testing was performed for each Class
 IA,  I  and II county, as well  as  for each individual  power plant.   EPA approved
 this  revision except for boilers and furnaces with a maximum rated heat input
 exceeding 1000 million  Btu  per hour and located  in Roane and Humphreys Counties,
 where  the old regulation of 1.2  Ib S02 /106  Btu  heat input still  aoolies.
          Table 2-3  presents  the  relevant portions of the regulations.
                                     14

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        Table 2-3.   Tennessee Fuel  Combustion  Emission  Regulations


Parti oil ate Matter

     A.   Choice of Standards - Existing Fuel  Burning  Equipment

        The owner or operator of existing fuel  burning  equipment  may

        elect to be regulated by emission limits  established  by either

        Subsection 1 or 2 of this section unless  otherwise  indicated.

        After July 1, 1975,  all  existing fuel  burning installations

        shall be required to comply with the  emission regulations as

        given in Subsection  2.  The owner or  operator of a  facility

        in existence on or before the effective date  of this  regulation

        must designate, in writing, to the Technical  Secretary, not
        later than July 1, 1972, which Subsection is  selected.  In the

        event the owner or operator makes no  selection  within the pre-

        scribed time period, Subsection 2 will  be applicable.

        1.  Diffusion Equation

            For existing installations up to  and  including  4000 million
            Btu per hour total plant heat input,  the  maximum  allowable
            particulate emission shall be as  determined by  the following
            equation, provided,  however, that  no  emission in  excess of
            six tenths (0.6) pounds per million Btu shall be  permitted
            from any installation.   Such limit shall  be achieved  by
            August 9, 1973.
                      n _ 20650 a h
                           gO-75
            in which D is the maximum allowable particulate emission
            in pounds per million Btu heat input, h is the stack height
            in feet, a is a diminsion'less factor of 0.67 for stacks
            of 200 feet height and less, and 0.80 for stacks in excess
            of 200 feet, and Q is the combined heat input in Btu per hour
            to the entire fuel burning installation.
                                     15

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            Table 2-3.  Tennessee Fuel Combustion Emission Regulations
                        (Continued)

             When more than one stack of the same height serves a given
             installation, the allowable emission limit as determined
             by the above equation shall be further reduced by dividing
             the emission limit so obtained by n^-25, where n is the
             number of stacks of equal height.   Stacks varying in height
             may be construed as being of equal  height provided a weighted
             average stack height is used in computing the allowable
             emission limit.'

         2.  Heat Input

             The maximum allowable particulate emission limits as given
             in this Subsection are based upon the total  plant rate of
             input to one or more stacks.

             For existing installations up to and including 4000 million
             Btu per hour total plant heat input, the maximum allowable
             particulate emission shall be determined from Figure 2-2,
             existing curve,  shall be achieved by August 9, 1973.

             Emission limits  for all existing fuel burning installations
             in excess of 4000 million Btu per hour will  be determined
             by Figure 2-2, existing particulate curve, up to 10,000 million
             Btu per hour heat input.  Emission  limits from existing
             installations in excess of 10,000 million Btu per hour will
             be determined from Figure 2-2.  This allowable emission
             standard must be attained on or before July 1, 1975.

     B.  New Fuel  Burning Equipment

         For fuel  burning installations constructed after the effective

         date of this regulation, the maximum allowable particulate emission
         shall be determined  from Figure 2-2, new particulate curve, based

         upon the total plant rate of heat input to one or more stacks.
         This allowable emission standard must be attained at the time such

         fuel burning installation begins operation.

Sulfur Dioxide

     A.  On or after July 1,  1975, the owner or  operator of an air contaminant

         source located in a  Class I County shall not cause,  suffer, allow

         or permit the emission from that source of sulfur oxides (calculated

         as sulfur dioxide) in excess of 1.6 pounds per million Btu heat

         input, maximum 2 hour average.

     B.  On or after July 1,  1975, the owner or  operator of an air contaminant

         source located in a  Class II County shall not cause, suffer, allow

         or permit the emission from that source of sulfur oxides (calculated

                                     16

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    Table 2-3.   Tennessee Fuel  Combustion Emission Regulations
                (Continued)
    as sulfur dioxide) in excess of 3.0 pounds  per million  Btu
    heat input maximum 2 hour average.
C.  On or after July 1, 1975, the owner or operator of an air contaminant
    source located in a Class II I County shall  not cause,  suffer,  allow
    or permit the emission from that source of  sulfur  oxides  (calculated
    as sulfur dioxide) in excess of 4.0 pounds  per million  Btu  heat
    input, maximum 2 hour average.
D.  After January 1, 1973, fuel burning installations  with  a rated
    capacity of 250 million  Btu per hour or less heat  input, constructed
    after April 3, 1972, shall  not cause, suffer,  allow or  permit the
    emission of sulfur oxides (calculated as sulfur dioxide) in excess
    of those limits specified in A), B) and C)  above.
E.  After January 1, 1973, the  owner or operator of an air  contaminant
    source with more than 250 million Btu per hour heat input,  constructed
    after April 3, 1972, shall  not cause, suffer,  allow or  permit the
    emission from that source of sulfur oxides  (calculated  as sulfur
    dioxide) in excess of the following:
    a.  0.08 Ibs per million Btu heat input, maximum 2 hour average,
        when liquid fossil is burned.
    b.  1.2 Ibs per million  Btu heat input, maximum 2  hour  average,
        when solid fossil fuel  is burned.
    c.  Where different fossil  fuels are burned  simultaneously  in
        any combination, the applicable standard shall  be determined
        by proration.  Compliance shall be determined  by using  the
        following formula:

                           Y(0.80) + 1(1.2)
                             X  + Y + Z

        where:    X = % of total heat input derived from gaseous
                     fossil  fuel
                 Y = % of total heat input derived from liquid
                     fossil  fuel
                 Z = % of total heat input derived from solid
                     fossil  fuel
                                17

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                                  100 250
1000
10,000
                              Heat Input in 106 Btu/hr
            Figure 2-2  Maximum Allowable  Partlculate Emission

                        Standards for  Fuel  Burning  Installations
                                         18

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                                  TECHNICAL REPORT DATA
                           (Please read Instructions on the reverse before completing)
 REPORT NO.
  EPA-450/3-75-041
                                                           3. RECIPIENT'S ACCESSION-NO.
 TITLE ANDSUBTITLE
                                                           5. REPORT DATE
   IMPLEMENTATION  PLBN REVIEW FOR TENNESSEE AS
   REQUIRED BY THE ENERGY SUPPLY AND  ENVIRONMENTAL
   CONATION  ACT	
             6. PERFORMING ORGANIZATION CODE
 AU
             8. PERFORMING ORGANIZATION REPORT NO.
 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 IV, Atlanta, Georgia, and
   Aroonne National  Laboratory, Argnnnp,  THinnis	
             11. CONTRACT/GRANT NO.
2. 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  ?7711
6. SUPPLEMENTARY NOTES
                                                           13. TYPE OF REPORT AND PERIOD COVERED
             14. SPONSORING AGENCY CODE
6. 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.
                               KEY WORDS AND DOCUMENT ANALYSIS
                 DESCRIPTORS
b.IDENTIFIERS/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
                                21
20. SECURITY CLASS (Tills pagef

   Unclassi
                                                                         22. PRICE
IPA Form 2220-1 (9-73)

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