EPA-450/3-75-053-a
July 1975
NATIONAL SUMMARY
OF
STATE IMPLEMENTATION PLAN REVIEWS
(SECTION 4 ESECA)
VOLUME I
SYNOPSIS
U. S. ENVIRONMENTAL PROTECTION AGENCY
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EPA-450/3-75-053-a
NATIONAL SUMMARY OF
STATE IMPLEMENTATION PLAN REVIEWS
(SECTION 4 ESECA)
VOLUME I
SYNOPSIS
Prepared by:
Energy and Environmental Systems Division
Argonne National Laboratory
9700 South Cass Avenue
Argonne, Illinois 60439
U.S. Environmental Protection Agency
Office of Air and Waste Management
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
July 1975
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11
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TABLE OF CONTENTS
1.0 PURPOSE AND SCOPE 1
2.0 REVIEW APPROACH 3
3.0 FINDINGS 6
4.0 STATE SUMMARIES 14
LIST OF TABLES AND FIGURES
Page
Table 1. Summary Findings of SIP Reviews 8
Figure 1. States in Which Regulation Revision Could
Encourage Clean Fuels Savings 12
Figure 2. States in Which Regulation Revision Could
Encourage Clean Fuels Savings But Which Have
Not Initiated SIP Revisions 13
111
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IV
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NATIONAL SUMMARY OF •
STATE IMPLEMENTATION PLAN REVIEWS
(SECTION 4 ESECA)
VOLUME I
SYNOPSIS
1.0 PURPOSE AND SCOPE
The purpose of this Synopsis and accompanying Technical Support
Document is to summarize the review of the State Implementation Plans (SIPs)
required by Section 4 of the Energy Supply and Environmental Coordination
Act of 1974 (ESECA). In compliance with ESECA, the U.S. Environmental Pro-
tection Agency (EPA) has completed a review of each SIP with respect to
emission limiting regulations for stationary fuel combustion sources. The
SIPs have been examined to determine if regulations may be revised without
jeopardizing the attainment and maintenance of any National Ambient Air
Quality Standard (NAAQS).
As required by law, findings of individual SIP reviews have been
reported to each state and territory. The main objective of the reports has
been to stimulate a change of regulations that generate unnecessary demands
for clean fuels.
States desiring to submit a plan revision have been informed that
ESECA provides that EPA must approve or disapprove the revision within three
months. The states have also been informed, however, that the SIP review
reports provided to them were designed to be advisory in nature and to pri-
marily highlight "indications" of unnecessarily stringent regulations. In
this regard, EPA has stated that ESECA does not require a change to any
existing plan and that the ESECA reviews are only the first step of an
official SIP revision process.
The time and resources available to prepare the SIP reviews did not
permit the consideration of growth, economics, and control strategy trade-
offs. The states have been clearly advised that the findings of the reports
are by no means conclusive and were neither intended nor adequate to be the
sole basis for SIP revisions. For those states that use the report as a
vehicle for deciding to submit a plan revision, EPA has indicated the neces-
sity of verifying and expanding the modeling and monitoring data supporting
the review and has suggested that the states consider issues such as air
quality maintenance, prevention of significant deterioration, and increased
sulfate, total suspended particulate, and hydrocarbon levels that might occur
in fuel switching.
In many respects, the ESECA reviews have paralleled previous pro-
grams established under EPA's Clean Fuels Policy, which addressed sulfur
dioxide (SOa) regulations. The efforts consisted of reviewing SIPs and
encouraging states to defer compliance with stringent SOa emission limits
for coal-fired power plants where this could be done without hampering NAAQS
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attainment. Also, states were asked to discourage large-scale shifts from
coal to oil or gas where possible. The Clean Fuels Policy addressed states
with the largest clean fuels savings potential and several of these states,
generally in the eastern half of the nation, have initiated or completed
SOg regulation revisions.
The ESECA reviews have gone beyond the Clean Fuels Policy by analyz-
ing unnecessarily restrictive regulations in every state and territory. In
addition, the reviews addressed the attainment and maintenance of all primary
and secondary NAAQS affected by emissions from not only power plants but in-
dustrial sources and area sources as well. Since stationary fuel combustion
installations constitute the greatest source of SOz emissions and are a major
source of total suspended particulate matter (TSP), the analysis in each re-
view focused mainly on TSP and SOz emissions. Hydrocarbon (HC) and carbon
monoxide (CO) regulations were not addressed in the reviews because they do
not -- with regard to stationary fuel combustion sources -- constitute a
major part of the strategy to attain and maintain NAAQS or pose a roadblock
to fuel use. Also, only limited analysis was conducted on the attainment and
maintenance of the annual NOz standard. The selected reviews for N02 were
dictated by a limited and inconsistent data base, a basic belief that viola-
tions are currently confined to only a few metropolitan centers, and an
understanding that NQx emission control regulations are not generally a sig-
nificant fuel-use constraint. In addition, in 1973 EPA relaxed the classifi-
cation of 43 Air Quality Control Regions and at that time indicated most
emission limiting regulations could be rescinded or modified.
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2.0 REVIEW APPROACH
In conducting the ESECA reviews, EPA recognized four predominant
reasons for the existence of unnecessarily restrictive emission limiting
regulations:
1. The state's prerogative to adopt emission limits more
stringent than those required to achieve the NAAQS;
2. The adoption of State Ambient Air Quality Standards
more stringent than the NAAQS;
3. The use of the example region approach to develop
statewide regulations; and
4. The large, isolated sources in an Air Quality Control
Region (AQCR), which have been used as the basis for
controlling the entire region.
In the first two situations, many states have simply exercised options
available to them under the Clean Air Act. The State Implementation Plans, at
a minimum, are required to demonstrate the attainment and maintenance of NAAQS.
Under provisions of the Clean Air Act, however, additional controls, either
in the form of stringent emission limits or stricter ambient air quality stan-
dards , can be developed at the discretion of the state. In several cases,
states adopted the NAAQS, which were in effect when the SIPs were submitted
in 1972. Some of the standards (e.g., the annual secondary 862 standard and
the 24-hour guide to achieve that standard) have been rescinded by EPA, but
not all states have revised the corresponding state standards. These stan-
dards, depending upon the location of the source, may be more restrictive
than the current NAAQS.
In the last two instances, many states initially developed control
strategies based only on a portion of a state or on a single large source.
This approach, at the time the plans were approved by EPA, was acceptable
mainly due to the short time for developing plans mandated by the Clean Air
Act. The example region concept permitted a state to identify the most pol-
luted Air Quality Control Region (AQCR) and adopt control regulations that
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
that are more stringent than needed to attain NAAQS, especially in the utili-
zation 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 one
percent sulfur oil to be burned statewide where the use of three percent
sulfur coal would be adequate to attain NAAQS in some locations.
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EPA has conducted the review of emission regulations by examining
the four predominant statewide situations mentioned above as well as other
factors that are germane to the control of stationary fuel combustion sources
in each Air Quality Control Region. For example:
Does the state have air quality standards that are
more stringent than NAAQS?
Did the state use an example region approach for
demonstrating the attainment of NAAQS or_ more
stringent state standards?
Does the state have emission limitation regulations
for control of 1) power plants, 2) industrial sources,
3) area sources?
Has the state initiated action to modify combustion
source emission regulations for fuel savings; i.e.,
under the Clean Fuels Policy?
Are there any 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?
Are there reported violations of NAAQS?
Are there indications of a significant tolerance for
increasing emissions?
Are the total emissions from stationary fuel combus-
tion sources a small portion of the total?
Do modeling results for specific fuel combustion
'sources show a potential for regulation revision?
Is there a significant clean fuels savings potential
in the region?
The reviews were directed at answering the above questions and using
them as "indicators" of whether there is a potential for relaxing regulations.
These indicators were addressed on an AQCR basis and regions were classified
as good, marginal, or poor candidates for regulation revision.
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AQCR ratings were determined by assessing the following criteria:
Good
1) Adequate number of
air monitoring
sites
2) No NAAQS violations
3) Attainment date of
1975 for NAAQS in
the SIP
4) No proposed AQMAs
5) Modeling results
show a potential
for regulation
revision
Poor
1) Violations of NAAQS
2) Attainment date for
NAAQS later than 1975
3) Proposed AQMA
4) Modeling results show
no potential for regu-
lation revision
Marginal
1) No air quality data
or insufficient
number of monitor-
ing sites
2) Inconsistent
"indicators"
For an AQCR to have been rated as a good candidate, all of the
criteria listed under "Good" were satisfied. The overriding factor in rating
an AQCR as a poor candidate was a violation of either the primary or secondary-
National Ambient Air Quality Standards. However, if any of the other condi-
tions listed under "Poor" existed, the AQCR would have still received that
rating. The main reason for a marginal rating was a lack of sufficient air
quality data. In Priority III regions, air monitoring was not required during
1973; therefore, in many cases there were no data with which to determine the
current air quality status. Marginal ratings were also given when there were
varying or inconsistent "indicators."
In some areas, sufficient data were available to determine if
regulation revision might result in significant clean fuels savings. This
information was used to further modify the AQCR assessments. Lack of clean
fuels savings potential was interpreted as an indication that regulation
revision, even though possible from an air quality standpoint, was not neces-
sary since little was to be gained. An evaluation of a clean fuels savings
potential, when made, was based on a state's own fuel consumption pattern
and not on national patterns. The combination of a significant clean fuels
savings potential and air quality indications for possible regulation
revision reinforced the "good candidate" status.
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3.0 FINDINGS
It is important to note that the SIP reviews have been conducted on
an AQCR basis. While subdivision of the United States into 247 regions rep-
resents a high degree of resolution, air quality and source emissions are
often highly localized. In such cases, policies and regulations based on
an entire AQCR analysis may not be representative of local conditions.
For the 55 states and territories that were reviewed, all 247 AQCRs
were evaluated for both TSP and SOa. The analysis conducted for particulate
and SOa regulations addressed monitoring data, NAAQS attainment dates, pro-
posed Air Quality Maintenance Areas, and in some cases, modeling results.
Also, regulations for the control of NOa were evaluated for a limited number
of AQCRs in the following states: New York, Maryland, Illinois, California,
and Utah. The reviews found that emission limiting regulations for NOa are
necessary for the attainment and maintenance of the NOa standard in those
states and are not unnecessarily restrictive in the context of Section 4 of
ESECA.
In general, the reviews found little indication that particulate
emission limiting regulations are overly restrictive. In many areas of the
country, widespread emissions of TSP from stationary and mobile sources, as
well as the natural and man-made background levels of particulates, were
found to be challenging the effort to meet the national air quality standards.
Relaxing particulate regulations in most areas of the country would only tend
to aggravate the existing problem. Of the 247 AQCRs, 30 were found to be
good candidates for revising TSP regulations, 5 AQCRs were found to be mar-
ginal candidates, and the remaining 212 AQCRs were found to be poor candidates.
Only Delaware and American Samoa displayed indications for being
able to accept increased particulate emissions throughout most of the state.
However, even in these locations there was estimated to be no clean fuels
savings associated with a TSP regulation change. In all other states and
territories, less than half of the AQCRs showed any potential for absorbing
emission increases without jeopardizing NAAQS attainment and maintenance.
In most of the reviews, the data were not adequate to determine if local
conditions in portions of an AQCR would possibly warrant a TSP regulation
revision; nevertheless, it was clear that states wishing to change particu-
late regulations must do so with extreme caution and only after significant,
additional study.
With regard to the limitations placed on SOz emissions, the reviews
found the EPA's Clean Fuels Policy of encouraging states to revise unnecessarily
restrictive emission regulations has already reduced much of the "overcleaning"
required by the original SIPs. Four states were found, as a result of the
Clean Fuels Policy, to have completed SIP revisions. In addition to these
four states, the ESECA reviews found 17 states having indications of both
a clean fuels savings potential and unnecessarily restrictive SOa regulations;
however, 13 of these states currently have revisions underway. Only the states
of New Jersey, Virginia, North Carolina, and Minnesota were found to have
some potential for regulation revisions, but have not initiated SIP revisions.
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The four states that have been identified as SOa revision candidates
in the SIP reviews can be subdivided into two general fuel-use categories.
With regard to power plants, New Jersey is primarily an oil-burning state,
while Virginia, North Carolina, and Minnesota, for the most part, burn coal.
New Jersey, like many northeastern states, is heavily oil dependent.
New Jersey currently restricts combustion sources to 0.2% or 0.7% sulfur
depending on the location of the sources. New Jersey is currently granting
variances to a large number of combustion sources allowing them to burn higher
sulfur fuels. This action has essentially relaxed fuel regulations for spe-
cific sources throughout the state.
In Virginia, SOa NAAQS were found to be exceeded only in one inter-
state AQCR. Ambient air quality levels were also close to the standard in
the National Capitol AQCR. The other AQCRs in Virginia showed indications
for increasing SOa emissions. Virginia's SOa regulations, given in pounds
per hour, translate to an approximate coal sulfur content of 0.7% in certain
areas and 1.71 in cleaner areas of the state; for oil, these restrictions
become 1.0% and 2.5%. There are no proposed AQMAs. Minimal air quality
attainment and maintenance problems, modeling data, and estimates that regu-
lation revision will encourage a clean fuel conservation, indicate that
Virginia might be a candidate for regulation revision.
The state of North Carolina could also consider relaxation of its
SOa emission regulations. Even under the present regulations, many sources
could possibly utilize higher sulfur fuels than they presently burn. Thus,
the potential for clean fuels savings exists for some sources even within the
present regulations. An overall move to higher sulfur fuel use would require
regulation revision. The present lack of modeling data, however, indicates
that a substantial review and evaluation effort would be required to indicate
to what, extent, if any, relaxation could be allowed.
With regard to Minnesota, there are indications of a substantial
margin for increased SOa emissions in all regions except Minneapolis-St. Paul.
Modeling results from the state's largest power plant, the A. S. King Plant,
indicate a potential for switching to higher sulfur coal despite the high SOa
levels in Minneapolis-St. Paul. The large Fox Lake Plant has been identified
as having the potential to switch from oil to coal. Modeling results plus
other positive air quality indications existing in Minnesota were found to
provide a basis for reconsideration of the state's SOa regulations for large
fuel-burning sources. Additional localized study, however, is necessary to
fully determine the impact of any regulation revision.
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Table 1. Summary Findings of SIP Reviews
Review Evaluation
o
Air Quality Assessment
AQCR
REGION I
Connecticut
Maine
Massachusetts
New Hampshire
Rhode Island
Vermont
REGION II
New Jersey
New York
Puerto Rico
Virgin Islands
REGION III
Delaware
Dist. of Columbia
Maryland
Pennsylvania
Virginia
West Virginia
Total
Number
of
AQCRs
4
5
6
3
1
2
4
8
1
1
2
1
6
6
7
10
Number of AQCRs
Indicating a Potential
for Increasing Emissions
TSP
1
2
0
1
0
0
0
0
0
0
1
0
1
0
0
3
S02
1
0
3
2
0
0
1
4
0
1
1
0
5
0
4
8
Is Regulation
Revision Likely to
Encourage Significant
Clean Fuels Savings ?°
No
No
Yes
No
No
No
Yes
Yes
Yes
Yes
No
No
Yes
Yes
Yes
No
SIP Status
No Apparent
Action to Revise
Regulations
X
X
X
X
X
. X
X
SIP Revisions
Underway or
Completed
Underway
Underway
Underway
Underway
Underway
Underway
Underway
Underway
Completed
co
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Table 1. (Contd.)
Review Evaluation
Air Quality Assessment0
SIP Status
Number of AQCRs
Total Indicating a Potential Is Regulation
Number for Increasing Emissions Revision Likely to No Apparent SIP Revisions
AQCR
REGION IV
Alabama
Florida
Georgia
Kentucky
Mississippi
North Carolina
South Carolina
Tennessee
REGION V
Illinois
Indiana
Michigan
Minnesota
Ohio
Wisconsin
REGION VI
Arkansas
Louisiana
New Mexico
Oklahoma
Texas
AQCRs
7
6
9
9
4
8
10
6
11
10
6
7
14
8
7
3
8
8
12
TSP
1
2
1
0
1
0
1
0
3
0
0
0
2
0
0
0
2
0
0
S02
5
3
6
1
3
8
8
4
3
5
3
4
8
5
7
3
6
8
11
J_U,i\~l/ll.J. O.g*> U J-^llJ. J_J-^CU.J.L-
Clean Fuels Savings ?b
No
Yes
No
Yes
No
Yes
No
No
Yes
Yes
No
Yes
Yes
No
c
c
No
c
No
r\^ (- _LWH uw ixv^ v j.ot>
Regulations
X
X
X
X
X
X
X
X
UlAX-i-tii. WO-^ WJ.
Completed
Completed
Underway
Underway
Underway
Completed
Completed
Underway
Underway
Underway
Underway
Underway
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Table 1. (Contd.)
Review Evaluation
0
Air Quality Assessment
AQCR
REGION VII
Iowa
Kansas
Missouri
Nebraska
REGION VIII
Colorado
Montana
North Dakota
South Dakota
Utah
Wyoming
REGION IX
American Samoa
Arizona
California
Guam
Hawaii
Nevada
Total
Number
of
AQCRs
12
7
.5
4
8
5
2
4
3
3
1
4
11
1
1
3
Number of AQCRs
Indicating a Potential
for Increasing Emissions
TSP
1
0
0
0
0
1
0
0
0
0
1
0
3
0
0
0
S02
11
7
4
4
7
2
1
4
0
2
1
0
0
0
0
1
Is Regulation
Revision Likely to
Encourage Significant
Clean Fuels Savings ?b
Yes
No
No
No
d
No
No
No
No
No
No
No
No
No
No
Yes
SIP Status
No Apparent
Action to Revise
Regulations
X
X
X
X
X
X
X
X
X
X
X
X
SIP Revisions
Underway or
Completed
Underway
Underway
Underway
Underway
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Table 1. (Contd.)
Review Evaluation
Air Quality Assessment'
Number of AQCRs
SIP Status
AQCR
REGION X
Alaska
Idaho
Oregon
Washington
1 U Uct J.
Number f(
of
AQCRs
4
4
5
6
LliU.-Ll-ClL.LlLg d rU UCllt, J-dJ. J.3 I\CgUJ.ClUXUJl
:>r Increasing Emissions Revision Likely to
'C-ne-m 1-1-0 /TQ CT ^n-> T -P-? ^o-r>-f-
TSP S02
0 4
0 3
2 4
0 3
Clean Fuels Savings?'3
No
No
No
No
No Apparent
Action to Revise
Regulations
X
X
X
X
SIP Revisions
Underway or
Completed
aBased on air quality monitoring, modeling results, attainment dates, proposed AQMA designations, and
emissions.
This evaluation is made relative to the state's own fuel consumption and not relative to national clean
fuel consumption.
cNot possible to evaluate due to form of regulation.
regulations have been withdrawn pending revision.
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D HAWAII
D GUAM
D AMERICAN SAMOA
Form of regulation makes evaluation difficult.
Fig. 1. States in Which Regulation Revision Could Encourage Clean Fuels Savings
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D HAWAII »
GUAM
D AMERICAN SAMOA
Fig. 2. States in Which Regulation Revision Could Encourage Clean
Fuels Savings But Which Have Not Initiated SIP Revisions
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4.0 STATE SUMMARIES
The fG-Liowing are condensed versions of the ESECA review findings
for each state and territory. These summaries are broken down by EPA Regions.
For additional data, the reader is referred to the accompanying Technical
Support Document. Also, for a detailed picture of an individual state, the
reader may consult the individual SIP Review Report.
Region I
Connecticut
For particulates, there are indications that little potential exists
for revising emission limiting regulations. Likewise, 862 regulations show
only a limited potential for revision. Eastern Connecticut and Northwestern
Connecticut Intrastate AQCRs are the most likely areas for an SOz revision;
however, clean fuel savings are estimated to be minimal.
Maine
Maine currently uses little coal for fuel combustion, relying heavily
on oil. For TSP, only Metropolitan Portland shows limited potential for pos-
sible regulation revision. SOa levels in Androscoggin Valley and Down East
AQCRs indicate potential for regulation revision. Considerably more data,
however, is needed concerning air quality in Maine.
Massachusetts
Recent actions by the state of Massachusetts parallel the intentions
of Section 4 ESECA. In an attempt to reduce the impact of fuel shortages and
to conserve clean fuels, Massachusetts has recently passed legislation mandat-
ing a relaxation of all statewide ambient air quality standards to NAAQS
levels.
New Hampshire
Almost all fuel combustion sources in the state of New Hampshire use
fuel oil. Although little coal is used, only one AQCR (Central New Hampshire)
shows a potential for TSP regulation revision. Two AQCRs (Androscoggin Valley
and Merrimack Valley) indicate a potential for S02 regulation revision.
Rhode Island
Due to high levels of TSP and S02, there is little potential for
revising fuel combustion source emission limiting regulations in Rhode Island.
Vermont
Recent actions by the state of Vermont are compatible with the inten-
tions of Section 4 ESECA. To reduce the impact of shortages and to conserve
clean fuels, Vermont is considering a revision to its sulfur-in-fuels regula-
tion with a sulfur content of 1.5% allowing 2.51 based on the unavailability
of 1.51 sulfur fuels.
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15
Region II
New Jersey
Two of New Jersey's AQCRs have the potential for clean fuels savings.
Metropolitan Philadelphia (AQCR #45) and New Jersey Intrastate (AQCR #150)
both have some areas that could likely absorb emission increases. However,
significant fuel switching must proceed cautiously since the existing major
sources are in areas of high industrial growth and activity. Potential clean
fuels savings are likely to result from increased use of higher sulfur oil in
place of distillate oil.
New York
While there is little indication for potential TSP regulation revi-
sion, four AQCRs indicate a limited potential for SOa regulation revision.
These are Central New York, Genesee-Finger Lakes, Southern Tier East and
Southern Tier West AQCRs.
Puerto Rico
Existing high levels of TSP indicate little potential for regulation
revision. Puerto Rico is in the process of revising its sulfur content regu-
lations using source-by-source diffusion modeling to determine optimal sulfur
content to attain NAAQS. This activity is compatible with the intent of ESECA.
Virgin Islands
For TSP there are no indications of overly restrictive regulations.
The Virgin Islands are in the process of developing sulfur content regulations
that are compatible with the Clean Fuels Policy and thus Section 4 of ESECA.
Region III
Delaware
In the Southern Delaware AQCR, there were no reported violations of
NAAQS for either particulates or SOa. However, there currently are no regu-
latory limits on fuel sulfur content in this region.
District of Columbia
For both TSP and S02, there is little indication that current emis-
sion regulations are overly restrictive.
Maryland
Recent action by the state of Maryland parallels the intention of
Section 4 of ESECA. In an attempt to reduce the impact of fuel shortages,
the state has proposed a plan revision that would postpone the date of fuel
oil sulfur content limits until 1980.
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16
Pennsylvania
Statewide, there is little indication that existing fuel combustion
regulations are overly restrictive. Locally, recent action of the state par-
allels the Clean Fuels Policy and Section 4 of ESECA. A plan revision was
submitted and approved postponing the date of fuel sulfur content regulations
for Philadelphia.
Virginia
For TSP, there are no indications that existing fuel combustion
source emission regulations are overly restrictive. SOa regulations may,
however, have a potential for relaxation in certain areas such as Hampton
Roads, Northeastern Virginia, and the Valley of Virginia Intrastate AQCRs.
West Virginia
Due to high TSP levels, any relaxation of particulate regulations
could only serve to aggravate NAAQS attainment. In an effort to reduce the
impact of fuel shortages and to conserve clean fuels, West Virginia submitted
a plan to relax existing SOa regulations. A revision to the West Virginia
SIP was approved on August 12, 1974, which allowed a maximum discharge of
S02 from 32,000 to 45,000 Ib/hr from all sources in a given facility. This
revision affected only one large power plant, the John E. Amos Plant in the
Kanawha AQCR.
Region IV
Alabama
Alabama has previously revised its SOa regulations to allow for con-
siderable clean fuels savings. Considering available modeling data, air
quality data and current fuel sulfur contents, the potential for further regu-
lation relaxation exists only in portions of the Tennessee River Valley -
Cumberland Mountains Interstate (AQCR #7).
Florida
Bade, Broward, and Palm Beach counties have substantially more re-
strictive air quality standards than NAAQS. Although there appears to be
little support for revision of TSP regulations, S02 regulations could be revised
to allow burning of higher sulfur oil in all regions except Jacksonville-
Brunswick and West Central Florida. Of 40 power plants on line in 1975, only 5
are coal burning. Florida is currently reviewing its fuel combustion regula-
tions .
Georgia
The Georgia SIP emission limiting regulations are presently under
litigation in the 5th Circuit Court of Appeals (Natural Resources Defense
Council, Inc. vs. Environmental Protection Agency, Case No. 7-2402). These
regulations allow for the consumption of up to 3% sulfur fuels (or equivalent
emissions). EPA has determined these regulations are adequate to protect
NAAQS at all but three power plants.
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17
Kentucky
The Commonwealth of Kentucky is presently considering revising its
ambient standards to be identical with NAAQS. Also, the S02 emission limita-
tions are being proposed for revision at this time. The potential for regu-
lation relaxation exists in portions of five of the nine Kentucky AQCRs.
However, the emission limits may need to be strengthened in portions of four
Kentucky AQCRs.
Mississippi
The Mississippi ambient standards are presently more restrictive
than NAAQS. There are indications that certain AQCRs have a tolerance for
S02 emission increase in Mississippi, but the consumption of higher sulfur
fuels is presently allowable under the state's regulations.
North Carolina
The state of North Carolina could consider relaxation of its S02
emission regulations. However, even under the present regulations, many
sources could utilize higher sulfur fuels than they presently burn. Thus,
the potential for clean fuels savings exists for some sources even within the
present regulations. An overall move to higher sulfur fuel use would require
regulation revision. The present lack of data indicates that a substantial
modeling effort would be required to indicate to what extent, if any, relaxa-
tion could be allowed.
South Carolina
South Carolina recently revised its emission regulations for fuel
combustion sources. The new S02 regulations allow for an emission limit based
on local conditions rather than regionwide considerations.
Tennessee
Tennessee has previously revised its S02 regulations to allow for
considerable clean fuels savings. The potential for further S02 regulation
relaxation exists in all areas of the state except in portions of two AQCRs.
Tennessee is presently considering further revisions to its S02 emission
limitation.
Region V
Illinois
Illinois' statewide regulations are based on the example region
approach. The state has adopted federal standards for particulates, and
limited analysis indicates little tolerance for making these restrictions
more lenient. This is due to high TSP readings in areas where a significant
clean fuels savings potential exists. S02 regulations are substantially more
stringent in the major metropolitan areas (MMAs) of Chicago, Peoria, and St.
Louis than in other areas of the state. These urban regulations were success-
fully challenged by a utility, and the case is now being appealed by the Illinois
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Pollution Control Board before the Illinois Supreme Court. In addition, the
Illinois Environmental Protection Agency has proposed that power plants out-
side the three major metropolitan areas not be required to install control
equipment and that supplementary control systems be installed in the interim.
Only the Burlington-Keokuk Interstate (AQCR #65) would provide a significant
clean fuels savings by utilization of high sulfur coal.
Indiana
Indiana has initiated changes to its S02 regulations, which would
result in the applications of emission limits based on local considerations
rather than "worst region" constraints. This concept is consistent with
EPA's Clean Fuels Policy analysis and with this ESECA review.
Michigan
Michigan's statewide emission regulations for TSP and S02 were based
on a modified example region approach. A program of delayed compliance
exists and has been used regarding specific fuel combustion sources. No
changes in SOa regulations have been initiated since the Michigan Air Pollu-
tion Commission is using the delayed compliance provision.
Minnesota
For TSP, there appears little support for regulation revision. There
are indications in all regions except Minneapolis-St. Paul that S02 emissions
could increase substantially. Clean fuels savings potential are significant
in some areas.
Ohio
EPA is currently developing fuel combustion regulations in the state
of Ohio. This program will be consistent with the Clean Fuels Policy and
national environmental goals.
Wisconsin
Wisconsin used a modified example region approach to develop particu-
late regulations. Except for Southern Wisconsin, all AQCRs report high
particulate levels. Such levels suggest that existing regulations should not
be relaxed. Most of the coal used by Wisconsin does not regulate the sulfur
content of combustion fuels.
Region VI
Arkansas
Any relaxation of Arkansas' particulate regulations would only serve
to aggravate the state's already serious TSP situation. Ambient SOa concen-
trations in the state are generally low. Natural gas accounts for about half
of the fuel heat input with oil contributing about a third of the total.
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19
Louisiana
Natural gas is the major fuel for the state's fuel combustion sources
and accounts for 93% of all heat input. Such a large proportion of gas con-
sumption is not due to overly restrictive environmental regulations but the
availability of natural gas. Widespread TSP violations and sources operating
well below current regulations preclude the potential for regulation revision
in Louisiana.
New Mexico
New Mexico did not use an example region approach to develop its
SIP control strategy. Fugitive dust from unpaved roads is a significant con-
tributor to NAAQS particulate violations in most areas of the state. With
the exception of the Four Corners Region, essentially all the state's combus-
tion fuel is natural gas. Due to the specific nature of New Mexico's regula-
tions and current fuel use, it does not appear that the state's regulations
covering TSP and S02 are overly restrictive.
Oklahoma
Though the example region approach was utilized, the state's regula-
tion for existing SOa sources is based on ambient air (SOa) concentrations
observed beyond the emitter's property line. Violations of TSP NAAQS have
been reported in every Oklahoma AQCR. In the context of Oklahoma's fugitive
dust problem, the state's particulate emission regulation does not appear
overly restrictive. Because of its low ambient levels, Oklahoma was not
required to prepare an SOa control strategy.
Texas
It does not appear that regulations in Texas are overly restrictive,
but state regulations make analysis of restrictiveness difficult. Although
natural gas is the major fuel used in the state's 73 identified power plants,
65 of the plants also use oil.
Region VII
Iowa
For particulates, there is little indication that existing fuel
combustion emission regulations are overly restrictive. For SOa there is
good indication that existing fuel combustion emission regulations may be
overly restrictive. Iowa is currently in the process of revising its SOa
emission regulation.
Kansas
Metropolitan Kansas City was used as an example region to demonstrate
attainment of NAAQS, using an air quality display model rather than linear
rollback. Current fuel use practices result in most sources emitting below
particulate regulations at present. SOa emission regulations also allow some
fuel switching to occur without regulation change. Given the current air
quality, Kansas is not a likely candidate for regulation revision.
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20
Missouri
Missouri used Kansas City as the example region and separated the
St. Louis Metropolitan AQCR to demonstrate NAAQS attainment. The TSP regula-
tions do not appear to be overly restrictive. Current air quality sampling
data for St. Louis indicate an isolated portion of the region exceeds the SOa
standards. S02 sources other than power plants are in this area, and the
emission regulations for these sources may have to be tightened. There are
no indications that emissions from power plants in the Missouri portion of the
St. Louis AQCR are causing violations of the air quality standards. Outside
St. Louis all sources are controlled by ambient air quality levels only.
Nebraska
Nebraska used the example region approach in developing statewide
control strategies for TSP and SOa. Preliminary study indicates that while
Nebraska's fuel combustion regulations may be overly restrictive to meet am-
bient air quality standards, TSP and SOa regulations are not roadblocks to
the use of higher sulfur fuels. Many TSP monitoring stations currently exceed
NAAQS. Much of the state's TSP problem can be attributed to windblown fugi-
tive dust. Thus, while many sources in Nebraska are emitting below what regu-
lations would allow, any increase in such emissions would be detrimental to
the attainment of NAAQS. Nebraska's SOa concentrations are below NAAQS, and
the state has adopted statewide regulations that appear more restrictive than
air quality dictates. However, such regulations allow for considerable S02
emission increases via fuel switching within the limits of the regulations.
REGION VIII
Colorado
Colorado used the example region approach and has more stringent air
quality standards than NAAQS. Colorado's plan revision was approved on Octo-
ber 18, 1974 to better balance the SIP. The SOa regulations were withdrawn.
Montana
Montana has indications of a widespread TSP problem with violations
in all but the Great Falls AQCR. Since most fuel combustion sources are
operating within current regulations, any relaxation could only aggravate
attainment of NAAQS. For SOa, emission regulations may be overly restrictive
in only the Great Falls and Miles City AQCRs.
North Dakota
North Dakota used a statewide approach to develop control strategies.
Although North Dakota's air quality standards for TSP and SOa are more strin-
gent than federal standards, preliminary analysis indicates that current regu-
lations are not overly restrictive. Substantial emissions from agriculturally
related industries could present TSP attainment problems throughout the state.
Combustion TSP increases would make attainment problems more difficult. SOa
levels are sufficiently below state air quality standards to allow an increase
in emissions within the limits of present regulations.
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21
South Dakota
South Dakota utilized the statewide approach to develop its control
strategies. While the state has adopted more stringent air quality standards
than the federal government, there are no indications that resultant regula-
tions are overly restrictive. Three of South Dakota's four AQCRs appear to
have TSP attainment problems. Such problems result primarily from agricul-
turally related industries. Relaxation of TSP regulations would make the
possibility of attainment more difficult. South Dakota's SOa concentrations
are currently below NAAQS. While initial study indicates SOa regulations may
appear overly restrictive in the context of SOa concentrations, there exists
sufficient potential for fuel switching within the limits of current regula-
tions .
Utah
There are no indications that Utah has overly restrictive TSP and
SOa emission regulations in the context of Section 4 of ESECA. Utah presently
uses local coal for a large percentage of stationary fuel combustion. Addi-
tional utilization can be effected within the framework of existing regulations.
Wyoming
Wyoming has indications of a widespread TSP problem with violations
occurring in all AQCRs. Therefore, any relaxation of particulate matter
regulations could interfere with attainment of NAAQS. In the absence of
modeling results, the recently adopted SOa regulations may be more stringent
than necessary to maintain NAAQS.
Region IX
American Samoa
The example region approach was not used in American Samoa. Because
of the limited number of stationary sources, there are no indications of NAAQS
violations or overly restrictive regulations.
Arizona
Although Arizona used an example region approach to develop its SIP
control strategy and has a 24-hour SOa standard more restrictive than NAAQS,
there are no indications that current regulations are overly restrictive.
California
California is currently in the process of reviewing its SIP with
respect to air quality and fuel combustion sources throughout the state.
Guam
The example region approach was not used in developing control strate-
gies for TSP and S02. There are no indications that Guam's regulations are
overly restrictive.
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22
Hawaii
Agricultural burning and bagasse combustion boilers contribute sig-
nificantly to Hawaii's particulate problem. Because of high. TSP levels and
high local S02 levels, Hawaii does not appear to have overly restrictive
emission regulations.
Nevada
Although Nevada utilized the example region approach and has a 24-
hour SOa air quality standard, the state's emission regulations, because of
limited data, have not been found to be overly restrictive. Fugitive dust
and S02 emissions from large point sources, such as copper smelters, contrib-
ute to a widespread TSP problem and a locally high SOa level.
Region X
Alaska
Fugitive dust suspended by traffic and other activities is a major
contributor to Alaska's high TSP levels. Such high levels preclude signifi-
cant increases in particulate emissions. In many cases SOa emissions are
significantly below Alaska's regulatory limit allowing clean fuels savings
within the constraints of state regulations. Additionally, regulations appear
to also have the potential for revision and still provide for the attainment
and maintenance of NAAQS.
Idaho
Particulate fuel combustion regulations do not appear overly restric-
tive in Idaho. Although S02 fuel combustion regulations appear overly re-
strictive, significant increases in S02 emissions may occur within the limits
of current regulations. In addition, SOa fuel combustion regulations appear
overrestrictive in most areas of the state.
Oregon
Because of locally high particulate levels, regulations appear overly
restrictive only in the Central Oregon AQCR. Other AQCRs show potential in
cleaner portions of the regions. SOa regulations appear overly restrictive
in all regions except the Northwest AQCR and the Portland Interstate. Due to
the use of natural gas and low sulfur fuel oils, most sources are currently
operating significantly below regulatory ceilings.
Washington
Washington's particulate levels are such that any significant increase
in particulate emissions would make attainment and maintenance of NAAQS diffi-
cult. S02 emissions, on the other hand, may increase significantly in all
AQCRs except Puget Sound. Washington's regulations are such that SOa emissions
can increase without violating current regulations. A potential, additionally,
may exist for the revision of S02 regulations.
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1. REPORT NO.
EPA-450/3-75-053-a
3. RECIPIENT'S ACCESSIOI>NO.
4. TITLE AND SUBTITLE
NATIONAL SUMMARY OF STATE IMPLEMENTATION PLAN REVIEWS
(Section 4 ESECA)
VOLUME I, SYNOPSIS
5. REPORT DATE
July 1975
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 § Standards, Research Triangle Park,
NC and Argonne National Laboratory, Argonne, IL
11. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS
U.S. Environmental Protection Agency, Office of Air §
Waste Management, Office of Air Quality Planning and
Standards, Research Triangle Park, NC 27711
13. TYPE OF REPORT AND PERIOD COVERED
Final
14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
16. ABSTRACT
Section 4 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. Although not required by ESECA, this document is a national summary of
each state and territory SIP review. This document is intended by EPA to answer a
number of anticipated questions arising from the review of the SIPs.
17.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.IDENTIFIERS/OPEN ENDED TERMS
c. COS AT I Field/Group
Air Pollution
State Implementation Plans
13. DISTRIBUTION STATEMENT
Release Unlimited
19. SECURITY CLASS (ThisReport)
Unclassified
21. NO. OF PAGES
27
20. SECURITY CLASS (Thispage)
Unclassified
22. PRICE
EPA Form 2220-1 (9-73)
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