'''"'- •- .'7 STAFF STUDY POTENTIAL SITING PROBLEMS FOR INCREASED COAL USE ************ A County-by-County Analysis of the Administration's Coal Substitution Program Considering Projected A1r Quality for the Year 1985 ************ October 1977 U.S. ENVIRONMENTAL PROTECTION AGENCY Office of Air and Waste Management Office of Air Quality Planning and Standards Research Triangle Park, North Carolina 27711 ------- STAFF STUDY POTENTIAL SITING PROBLEMS FOR INCREASED COAL USE A County-by-County Analysis of the Administration's Coal Substitution Program Considering Projected Air Quality for the Year 1985 ************ October 1977 U.S. Environmental Protection Agency Office of Air Quality Planning and Standards Research Triangle Park, N. C. 27711 ------- Executive Summary This study was conducted by the Environmental Protection Agency, in response to a Congressional request, to analyze air quality constraints on the increased coal use that would result from implementation of the President's National Energy Plan (NEP). The amount of increased coal use analyzed is that associated with the coal substitution program contained in the original NEP, sent to Congress in April 1977. Subsequent actions on the NEP strongly suggest that the final version will increase coal use to a lesser degree than would the original version. A current estimate places the increase at about half of that expected from the original NEP. The NEP encourages increased coal use through economic measures designed to make coal, rather than oil or gas, the preferred fuel for industry and electric utilities. Because the utilities are already showing a strong preference for coal, the NEP primarily affects industrial fuel use; in this study, 87 percent of the increased coal use is in the industrial sector. The NEP also contains fuel conservation measures, not analyzed in this study, estimated to reduce by 15 percent the amount of increased coal use analyzed. New facilities, rather than converted facilities, are expected to account for most (about 90 percent) of the increased coal use. These new facilities would represent both the replacement of old oil- and gas-burning facilities and the expansion associated with growth. These facilities would be sited in currently ------- Industrialized areas where existing air quality problems may constrain industrial activity and in areas where existing air quality would support substantial growth of well-controlled facilities. The major environmental constraints on NEP-iincreased coal use relate to the Clean Air Act requirement to deny the siting of a facility in a location where the pollutant emissions would interfere with the attainment or maintenance of health-related (primary) National ambient air quality standards (NAAQS). This study apportioned the NEP-increased coal use to county-level on the basis of projected county-level 1985 Industrial and utility fuel use under a buslness-as-usual (BAU) scenario, i.e., without a National Energy Plan. For each county analyzed, estimates of 1985 air quality were made by proportional modelling under both BAU and NEP scenarios. These estimates determined whether the facilities that would burn coal as a result of the NEP would .or would not encounter potential siting problems. The term "potential siting problems" was used because the techniques used in the analysis tended to "place" the facilities in the more industrialized area(s) within a county, and the estimated siting problems might be avoided by constructing the facilities in non-industrialized areas within a county. For some counties, the lack of current'air quality data prevented the estimation of 1985 air quality and, therefore, of potential siting problems. Of the 296 million ton increase predicted to result from the NEP, 232 million tons (78 percent) were apportioned to 902 counties where siting problems could be analyzed; 64 million tons (22 percent) were apportioned to 723 counties without current air quality data. ------- Within the limits imposed by the assumptions, methods, and data used to carry out the analysis, the following findings are reported: (1) 81 percent of the counties analyzed present no siting problems for the increased coal use apportioned to them; (2) 14 percent of the counties analyzed pose potential siting problems for BAU growth and therefore present potential siting problems for all of the NEP coal assigned to them; (3) the remaining 5 percent of the counties pose potential siting problems for only a portion of the NEP coal use allocated them; (4) 144 million tons (63%) of the NEP-increased coal use would not encounter potential siting problems; (5) 85 million tons (37%) would encounter potential siting problems resulting from either BAU growth or BAU growth and NEP-encouraged coal substitution; and (6) 32 counties accounted for 75 percent of the 85 million tons of the difficult-to-site NEP coal use. The pollutant most frequently associated with potential siting problems was particulate matter (TSP). In 60 percent of the counties which posed problems, predicted TSP concentrations were the only cause; in 15 percent, both TSP and S02 caused problems; and in 25 percent, S02 was the only cause. Predicted nitrogen dioxide (N02) concentrations were never the sole cause of potential siting problems but, in a few counties, would with TSP and S02 affect siting of facilities. No state contained a preponderance of the 171 counties which posed potential siting problems, and no clear spatial distribution of these counties was evident. As expected, the 171 counties did include many major metropolitan/industrial areas. ------- Table of Contents I. Purpose 1 II. The Potential NEP-Increase in Coal Use 1 III. The Environmental Constraints 4 IV. The Analysis 6 1. Business-as-Usual (BAU) 6 2. NEP Coal Use 9 3. The Air Quality Model 11 4. Current Air Quality 13 5. Current Emissions 15 6. Future (1985) Emissions 16 7. Future (1985) Air Quality 20 V. The Results 21 1. Potential Siting Problems 22 2. Spatial Distribution of Counties with Potential Siting Problems 24 3. Severity of, Potential Siting Problems 25 4. Coal Allocation to Counties with Potential Siting Problems 26 VI. The Results in Perspective 26 Appendix A: Impact of Coal Substitution on a Case Study Region A-l ------- I. Purpose The President's National Energy Plan (NEP) Is Intended, In part, to Increase the use of coal by Industry and electric utilities. In response to a Congressional request, the Environmental Protection Agency (EPA) has conducted this study to determine If there are geographical areas In which air quality requirements could constrain this additional coal use, by Imposing siting restrictions on coal-burning facilities. II. The Potential NEP-Increase In Coal Use The potential coal use increase analyzed in this study is related to the coal substitution program contained in the President's original National Energy Plan. This NEP also contained fuel conservation measures, the potential impacts of which were not analyzed. The original NEP was sent to Congress in April 1977; subsequent events strongly suggest that Congressional actions will result in substantial alteration of the original plan. In August, the House of Representatives passed an energy bill that differed materially from the Administration's original proposal. The House version would reduce the potential for increased coal use under the coal substitution program by about fifty percent as compared with the program in the original plan. The potential coal use increase analyzed in this study is therefore considerably greater than appears likely to result from the 1977 version of the National Energy Plan. The changing nature of the NEP, and time constraints prevented the analysis of alternative forms of the NEP. In this study, references to the NEP relate to the original, April version of the energy plan. ------- Some readers may wish to compare the results of this study with those of a June 20, 1977, study of the impact of NEP-increased coal use on the air environment. The previous study was titled, "Air Pollution Impacts of the Oil and Gas Replacement Program in the Utility and Industrial Sectors," and was conducted jointly by the Executive Office of the President, Energy Policy and Planning, and the Environmental Protection Agency. There are several significant differences between the two studies, The June 20th study predicted the changes in pollutant emissions (not air quality) on a Federal region (multi-State) basis. The current study deals with ambient concentration of pollutants (air quality) on a county basis, The coal use increase analyzed in the June 20th study did not represent the full potential of the NEP's coal substitution program to increase coal use; the potential increase in the industrial sector was reduced by about 30 percent to approximate the constraining effect of air quality requirements. The current study deals with the full potential, i.e., greater coal use, since the purpose of this study is to analyze the constraining effect of air quality requirements. Another, but unintentional, difference is that the current study does not include, because of data problems, the states of Alabama and Florida. For these reasons, the coal use increase numbers contained in the two studies relative to the coal substitution program are not directly comparable. The NEP's coal substitution program (or oil and gas replacement program) requires, with certain exceptions, that all new utility plants and large (greater than 100 million Btu per hour heat input) industrial boilers burn coal or other fuels rather than oil or gas. Authority is also granted to require other new industrial facilities (other than boilers) ------- to use coal. In addition to these regulatory provisions, the program includes (1) taxes on the use of oil and gas by utilities and large industrial firms, and (2) financial incentives (investment tax credits for industry or user tax rebates) for investments in facilities using fuels other than oil or gas and for retirement of existing oil- or gas-burning facilities. The coal use increase predicted to result from implementation of these measures is that which is analyzed in this study, and which is referred to as NEP coal. In addition to encouraging coal substitution, the NEP encourages the conservation of all fuels. The higher costs of oil and gas resulting from some of the measures just discussed, a well-head tax, utility load management and peak-load pricing, and the gas guzzler tax are examples of measures which support fuel conservation. These measures are expected to lessen the impact of fuel-burning on the air environment by decreasing the amounts of fuels used to produce the end result desired, e.g., less industrial fuel used per pound of product, and by decreasing residential and commercial use of oil by making additional gas available to these sectors. Time constraints prevented a county-by-county analysis of the effects of fuel conservation on potential siting problems, but the conservation measures were estimated to reduce by fifteen percent the coal use increase predicted to result from the coal substitution program. The impact of the NEP's coal substitution program on fuel use patterns was predicted by a Federal Energy Administration (FEA) computerized energy model called the Project Independence Evaluation System (PIES). The output of this model expressed the potential increase in coal use, and decrease in oil and gas use, in energy units (British thermal units, or Btu) in a Federal region (multi-State area). For specificity in analyzing air quality ------- impacts, a smaller geographical area was required; counties were selected. The assumptions used to apportion the PIES output to the county level are * critical to the results of this study and are explained later. The total potential Increase In coal use analyzed in this study was 15 6.51 x 10 Btu, or 296 million tons, assuming a heating value of 22 million Btu per ton of coal. The energy model predicted that 87 percent of the coal use increase would occur in the industrial sector and 13 percent in the utility sector. The results of this study, then, are primarily pertinent to industrial coal use. To analyze the air quality constraints on the NEP potential for increasing the use of coal, an -important factor is whether the coal will be burned in new facilities or in existing facilities. Plant locations for new facilities often can be selected so as to minimize their relationships to air quality problems, and it is more practicable for new facilities to achieve higher levels of pollutant emissions control. According to a June 2, 1977, report by the Executive Office of the President, Energy Policy and Planning, titled, "Replacing Oil and Gas with Coal and Other Fuels in the Industrial and Utility Sectors," most of the NEP coal would be burned in new facilities, some of which would be located at existing industrial sites and some at new sites. A numerical estimate supplied for this analysis placed the amount of new-facility NEP coal at over 90 percent of the total increase predicted. III. The Environmental Constraints The most significant air quality constraints on NEP coal use (and other industrial growth) relate to the Clean Air Act requirement to deny the siting of a new facility in a location where the pollutant emissions ------- would interfere with the attainment or maintenance of a health-related (primary) national ambient air quality standard (PNAAQS). The pollutant emissions from coal combustion that are of major concern are particulate matter (TSP), sulfur oxides (S02)> and nitrogen dioxide (N02). This analysis is based on the concept that NEP coal-burners would encounter siting problems if they were to be located such that the emissions of any of these three pollutants would cause or contribute to an ambient pollutant concentration in excess of a primary national ambient air quality standard. Regulations intended to prevent a significant deterioration (PSD) of air quality in areas in which the air is cleaner than required by the NAAQS also represent potential air quality constraints on the siting of new facilities. These regulations specify allowable incremental increases in ambient concentrations of pollutants for classes of areas. Application of these regulations, and an analysis of any siting constraint, requires location- and source-specific data—data not available for this study. Generally, however, the magnitude of these increments would be adequate to accommodate substantial growth of well-controlled sources. For example, as a rough approximation, 6 ten-megawatt industrial boilers with S02 emissions controlled to meet the new source performance standard of 1.2 pounds of S02 per million Btu of heat input, could be collocated in a Class II area. The highest ambient concentration would occur about one mile from the site; reasonable spatial distribution of new industrial facilities in these cleaner areas should result in few PSD constraints.. A third potential environmental constraint is the legal requirement for sources to control pollutant emissions to the degree required by applicable ------- State and Federal enlssfon-1trotting regulations, Thts study assumes that sources would comply fully with such regulations by 1985, IV. The Analysis Basically, the analytical technique used in this study was to (1) determine the current emissions and current ambient concentration of each of the three pollutants (air quality) for each county, (2) estimate the 1985 emissions of each pollutant for each county, and (3) predict 1985 air quality for each county by using an air quality model based on pro- portionality between emissions and air quality, Wherever the 1985 air quality did not conform to the primary national ambient air quality standards, the county was designated as presenting potential siting problems for new facilities. The analysis was conducted for two scenarios: business-as-usual (BAD) and Increased coal use (NEP coal). These scenarios are discussed below. 1. Business-as-Usual (BAU) The potential air quality constraints on the use of additional coal under the NEP must be analyzed in the context of other activities- activities not related to the NEP~-which would impact air quality through 1985. These other activities constitute bustness-as-usual (BAU), and the BAU air quality impacts are analyzed in this study to serve as a baseline from which to analyze NEP coal use, In this study, the emissions changes resulting from BAU include those associated with industrial growth, with swltch-to-coal- orders under the Energy Supply and Environmental Coordination Act (ESECA), with ------- fuel changing caused by natural gas curtailmants, and with compliance by existing sources with emission-limiting regulations. The growth projections (both positive and negative) were developed differently for three categories of polluting sources: (1) electric utilities (power plants), (2) industrial fuel-burners, and (3) industrial facilities other than fuel-burners. Federal Power Commission data on new power plant units planned through 1985 provided county locations, sizes, and fuel types. For the other two categories, county-level growth plans were not available, nor were commonly available growth forecasts applicable to county areas. In this study, growth estimates applicable to geographic areas much larger than counties were applied to counties on the basis of current county-level industrial activity. The techniques used are discussed below. PIES, the energy model described in Section II, was the basic source of data on projected growth in industrial fuel use (category 2) under business-as-usual conditions. These PIES projections for 1985 dealt separately with oil, gas, and coal and applied geographically to Federal regions (multi- State areas). To allocate this regional growth to counties, State-to-region and county-to-State ratios of current industrial fuel use were developed from data obtained from the sources described below. The source of State-level current industrial fuel use, used to allocate regional growth to States, was a published FEA-funded report entitled "Energy Consumption Data Base," or ECDB, dated June 1977. The source of county-level current industrial fuel use, used to allocate State growth to, counties, was EPA's computerized National Emissions Data Summary (NEDS). The NEDS fuel-use data, supplied to EPA by ------- States, were known to contain substantial inaccuracies—NEDS focuses on emissions; a number of corrections were made for this study and, in addition, the use of ECDB data for region-to-State growth allocations suppressed the analytical effects of any remaining inaccuracies. Following is an example of the procedure used to allocate BAU regional growth to States, and to counties: 1985 1985 State BAU _ current State industrial oil use (from ECDB) Federal industrial oil use ~ current Federal region industrial oil useregion BAU (from ECDB) industrial oil use (from PIES) and 1985 1985 county BAU _ current county industrial oil use (from NEDS) State BAU industrial oil use ~ current State industrial oil use (from NEDS) industrial oil use (from Step 1) To estimate county-level growth of industrial facilities other than fuel-burners (category 3), national average annual growth rates applicable to categories of industries were applied to the current magnitude of the appropriate industrial categories as listed in NEDS for each county. The growth rates were taken from data published by the Bureau of Economic Affairs, Department of Commerce, and by Data Resources, Incorporated. The analytical effect of the growth-estimating techniques used for the latter two categories of sources (categories 2 and 3) was to "place" growth in currently industrialized counties, with the magnitude of a county's industrial growth proportipnal to the magnitude of the county's current industrialization. The emission changes estimated to result from ESECA switch-to-coal orders were based on actual orders issued by the Federal Energy Administration. 8 ------- The emission changes estimated to result from natural gas curtailments were based on EPA-funded studies of both the utility and Industrial sectors: "Impact of Natural Gas Curtailments on Electric Utility Plants," dated August 1975, and "Impact of Natural Gas Shortage on Major Industrial Fuel- Burning Installations," dated March 1977. The emission changes estimated to result from existing sources' compliance with emission-limiting regulations is discussed below under the "Future Emissions" section. 2. NEP Coal Use The PIES model was used to predict the NEP increase in coal use and the corresponding decrease in oil and gas use. As with the BAU outputs from PIES, the NEP coal use outputs were available only on a Federal region basis, and it was again necessary to allocate PIES-predicted fuel use changes to county level. The results of this study are relevant to the extent that these PIES-predicted fuel use changes occur at the locations and with the magnitudes assumed in this study. The PIES outputs predicted the decreases in industrial and utility oil and gas use that the NEP coal substitution program would bring about in each Federal region; in each region, the coal use increase equalled the heating value (Btu) of the oil and gas use decrease. Separate PIES outputs were available for the industrial and utility sectors and, as explained below, different region-to-county apportionment techniques were applied to the two sectors. The technique used for the industrial sector was based on the 1985 BAU geographic fuel-use ratios developed under the BAU scenario. For ------- example, the technique used to apportion a Federal region decrease in Industrial oil use to a county was: (1) State NEP-decreased _ State 1985 BAU oil use Federal region PIES- oil use ~ Federal region 1985 BAU predicted decrease In oil use oil use and (2) county NEP-decreased _ county 1985 BAU oil use State NEP-decreased oil use " State 1985 BAU oil use oil use The same technique was used to determine the county-level decrease in industrial gas use. The heating values of the decreased oil and gas use were added together and coal was substituted for this total decrease. The technique applied to the utility sector apportioned the fuel use changes directly from Federal region to county and were based on the 1985 BAU fuel use determined under the BAU scenario. The PIES-predicted increase in utility coal use was assumed to occur in those counties where FPC had reported that new coal-fired units were planned under BAU. The amount of the NEP-increased coal use apportioned to a county was proportional to the size of the new coal-fired units planned for construction under BAU. For example: Federal county NEP-increased _ county 1985 BAU new coal-fired units region PIES- coal use ~ Federal region BAU new coal-fired units predicted increase in coal use The predicted decreases in utility oil and gas use were apportioned on the basis of 1985 BAU utility oil and gas use. For example, for oil: county NEP-decreased _ county 1985 BAU oil use Federal region PIES- oil use ~ Federal region 1985 BAU oil use predicted decrease in oil use These techniques (1) placed NEP industrial coal use in counties where industry currently uses oil and gas, with the amount of NEP coal 10 ------- proportional to the amount of oil and gas currently used, and (2) placed NEP utility coal use in counties where new coal-fired units are planned for construction, with the.amount of NEP coal proportional to the capacity of the new units. In this study, NEP industrial coal (257 million tons) was apportioned to 1595 counties within 48 States; NEP utility coal (39 million tons) was apportioned to 98 counties within 29 States. The apportionment techniques, while having the limitations discussed, ensured the incorporation of a wide range of air quality situations. 3. The Air Quality Model A porportional model was used to estimate the 1985 air quality in each county. This model is particularly applicable to a preliminary screening analysis of air quality (which this study represents) where source- and site-specific data are not available. Stated algebraically, this model is: current air quality _ future air quality current emissions ~ future emissions The basic assumption implicit in this equation is that a percentage change in emissions will result in the same percentage change in air quality. The current air quality value commonly used is the highest valid measured pollutant concentration, and, in this study, the highest valid value for each pollutant in each county was used. The current and future emissions used were annual totals for each county. The estimated future air quality represented a highest value for each county. While appropriate for a screening analysis, this model has limitations, discussed below, that are significant to the interpretation of the results of this study. 11 ------- Proportional modeling results are valid only Insofar as the air quality and emissions are uniform over the area being modeled. In general, these parameters are not uniform throughout a county. The highest measured pollutant concentrations are most likely to be found In the heavily Industrialized area(s) of a county; therefore, the potential siting problems Identified In this study apply primarily to the heavily Industrialized area(s) of a county. It follows that new facilities sited such that their emissions would not Impact the heavily-polluted area(s) would not encounter these potential siting problems. When estimating future emissions to be used In the model, the addition of emissions from large facilities that emit many tons of pollutants each year can lead to over-estimation of the air quality impacts of these sources. This happens because the effective height (stack height plus plume rise) at which large facilities release their emissions causes relatively small ground-level (ambient) air quality impacts per amount of pollutant emitted. To account for this, a point source model was used to estimate the air quality impacts of new utilities. These impacts were then added to the air quality impacts estimated by proportional modeling to occur from all other sources in the county. This adjustment was not possible for new industrial sources because of the lack of source-specific data. Generally, proportional modeling is more appropriate for estimating long-term rather than short-term average pollutant concentrations, e.g., more appropriate for annual averages rather than 24-hour averages. Annual averages are not seriously affected by anomalously high concentrations associated with phenomena like unusually poor dispersion conditions or, 12 ------- in the case of TSP, dust storms or temporary construction sites. In this study, as explained in paragraph 4 below, some 24-hour averages were used for S02. When estimating future TSP concentrations by proportional modeling, adjustments for TSP background concentrations are often used. This is accomplished by subtracting the background value from the current measured level*of TSP concentrations to obtain a value to use in the model and adding this background value to the future concentrations predicted by the model. Only multi-state background values were available for this study. These values were used in a trial analysis and their effects were negligible. On the basis of this sensitivity analysis, background estimates were not directly included in the determination of potential siting problems. 4. Current Air Quality The primary source of the current air quality data used in the proportional model was SAROAD, EPA's computerized file of nationwide air quality. To ensure the currency and validity of the data used in this study, all ten EPA Regional Offices reviewed the data and supplied corrections, additional values, and interpretations of data. Of the 1625 counties to which NEP coal was allocated, air quality data for one or more of the three pollutants were available for 902. These were the counties analyzed in this study. Because of the lack of air quality data, no analysis was conducted for the remaining 723 counties; however, the air quality monitoring networks are well enough constituted to support the general assumption that' counties not monitored with respect to these pollutants have few if any air quality problems associated with these pollutants. 13 ------- For use in the model, a single statistic was selected to represent the concentration of a pollutant 1n a county. Of major Importance was that the values selected relate to the primary (health-related) National Ambient Air Quality Standards (NAAQS). While N02 has only an annual average standard, both TSP and S02 have both annual average and 24-hour average primary NAAQS. In the case of the 24-hour average, the standard reads that it should not be violated more than once per year. In order to ensure public safety and make the greatest use of available air quality data, the highest yearly statistic occurring within a county over the period 1974-1976 was used as the design value. The specific design values selected were as follows: (1) The highest annual arithmetic mean measured in a county in the period 1974-1976 was used as the design value for N02. (2) The highest annual geometric mean measured in a county in the period 1974-1976 was used as the design value for TSP. The annual mean was selected because it is less likely to be influenced by fugitive dust than would be the second highest 24-hour average. (3) Both annual arithmetic and 24-hour average S02 values were examined over the 1974-1976 period because many continuous S02 monitors did not collect sufficient data to meet,the National Aerometric Data Bank's (NADB) validity criteria for calculating an annual mean. The criteria require that at least 75 percent of the total possible hourly data be available to calculate an annual mean. Further, the 24-average NAAQS is more likely to be violated than the annual standard. Therefore, the greatest use of the available data could be made by examining both averaging times. It was decided that the S02 design value should be the maximum ratio of either the annual 14 ------- mean observed divided by the annual NAAQS of 80 yg/m3 or the second maximum 24-hour average observed divided by the 24-hour NAAQS of 365 yg/m3. For nine counties to which NEP coal was apportioned, the TSP annual averages were identified, with assistance from EPA Regional Offices, as being heavily influenced by wind-blown rural dust (rural fugitive dust). These counties were not included in the proportional modeling for TSP. EPA policy on fugitive dust indicates that, where rural fugitive dust leads to high measured concentrations of TSP, the approval for siting of new industrial facilities should not rest on these measured concentrations. 5. Current Emissions The major source of the current emissions data used was EPA's computerized National Emissions Data Summary (NEDS). Data for this system are supplied by States through EPA Regional Offices; for this study, all in-process data were added to NEDS to produce as complete and current a file as possible. The NEDS data represent both measured and approximated emissions. While the data are of varying degrees of completeness and accuracy, reflecting the varying degrees of attention that States can give to their inputs, NEDS is the best available file of national pollutant emissions. For two States, however, Florida and Alabama, the NEDS data were considered to be not sufficiently complete and current for use in this study. NEDS data were not used tar S02 and NOX emissions from utilities. The utility S02 emisssions were calculated by EPA's computerized Energy Data System (EDS). EDS operated on data supplied by the Federal Power Commission (FPC) which showed, for each power plant, the types, amounts, and sulfur contents of the fuels used. Other data from FPC, listing the types of boiler 15 ------- firing mechanisms, were combined with the fuel data In EPA emission factor equations to estimate NO emissions. A 6. Future (1985) Emissions In addition to depending on the magnitude and location of growth, the estimates of future emissions depended upon the extent of emission control assumed. The basic emission control assumption was that all sources, both existing and new, would comply fully with this study's applicable emission- limiting regulations by 1985. This assumption is optimistic; the emission limits used in this study included, in some cases, more stringent emission controls than applicable regulations now require, and not all sources are in full compliance with current regulations. Separate sets of emission control assumptions were developed for emissions resulting from fuel-burning and for emissions resulting from processes other than fuel-burning. These assumptions are shown in Tables 1, 2, and 3; those that are more stringent than required by current regulations do not reflect EPA policy but are estimates made only for this study. Generally, it was assumed that'existing sources would comply with current State Implementation Plan (SIP) regulations or apply reasonably available control technology (RACT), whichever resulted in lesser emissions. Currently, many of the SIPs require less than RACT for existing sources; however, under recent Clean Air Act amendments, the SIPs would be revised, where necessary, to require the degree of RACT needed to attain and maintain the ambient standards. The RACT assumptions used in this study represent controls that States might apply if they wished to minimize potential siting problems for BAU growth and NEP coal use. 16 ------- Table 1. S0j and Partlculate Control Assumptions for Fuel Burners TYPE OF FACILITY AND TIME PERIOD S02 CONTROL PARTICIPATE CONTROL LU _1 Ul^J Coal Fired (>250 MMBtu/hr) 1975-1985 Oil Fired (>250 MMBtu/hr) 1975-1985 702 Control Current SIP 992 Control * Current Emissions •- BOILERS £' I Coal Fired (>250 MMBtu/hr) 1975-1983 1984-1985 Oil Fired (>250 MMBtu/hr) 1975-1985 1.2 Ib-SOy/MMBtu1 802 Control2 0.8 Ib SOz/MMBtu1 0.1 Ib/MMBtu 0.05 Ib/MMBtu1 0.07 Ib/MMBtu2 1 £ LU _J 2 H* 1 x IU Coal Fired (<100 HMBtu/hr) 1975-1985 (100 - 250 MMBtu/hr) 1975-1985 (>250 MMBtu/hr) 1975-1985 Oil Fired 1975-1985 cr Ul i NEW INDUSTRIAL Coal Fired (<100 HMBtu/hr)3 1975-1985 (TOO3 - 250 MMBtu/hr) 1975-1981 1982-1985 (>250 HMBtu/hr) 1975-1982 1983-1985 011 Fired (<250 MMBtu/hr) 1975-1985 (>250 HMBtu/hr) 1975-1985 Current SIP 452 Control1 702 Control Current SIP 942 Control ' 982 Control * 992 Control ' Current Emissions Current SIP Current SIP2 502 Control 1.2 Ib SOz/MMBtu1 802 Control2 Current SIP 0.8 Ib SOz/MMBtu1 942 Control Current SIP] 0.05 Ib/MMBtu 0.1 Ib/HMBtu1 0.5 Ib/HMBtu1 0.07 Ib/MMBtu 0.07 Ib/MMBtu FOOTNOTES: K)r S1p, whichever 1s more stringent. 20r SIP or 1.2 502/MMBtu, whichever Is more stringent 350 MMBtu/hr for partlculates. Wherever a 2 control was used, this was applied to the sulfur or ash content of regionally available coal to produce estimated emissions of S02 and TSP. 17 ------- Table 2. NOX Control Assumptions for Fuel Burners TYPE OF FACILITY AND'TIME PERIOD NOX CONTROL (Lb NOx/MMBtu) EXISTING UTILITY BOILERS Coal Fired (>250 MMBtu/hr) 1975-1985 Cyclone Other Categories Residual Oil Fired (>250 MMBtu/hr) 1975-1985 Natural Gas Fired (>250 MMBtu/hr) 1975-1985 1 0.8 0.7 0.3 0.2 NEW UTILITY BOILERS Coal Fired (>250 MMBtu/hr) (All Categories) 1975-1979 1980-1985 Residual Oil Fired (>250 MMBtu/hr) 1975-1985 Natural Gas Fired (>250 MMBtu/hr) 1975-1985 EXISTING INDUSTRIAL BOILERS NEW INDUSTRIAL BOILERS MOBILE SOURCES Coal Fired 1975-1985 Residual Oil Fired 1975-1985 Distillate Otl Fired 1975-1985 Natural Gas Fired 1975-1985 , Coal Fired 1975-1979 1980-1985 Residual 011 Fired 1975-1985 Distillate 011 Fired 1 975-7985 Natural Gas Fired 1975-1985 Automotive 1975-1976 1977-1980 1981-1985 Other Than Automotive 1975-1985 VMT Growth Rate 0.7 0.6 0.3 0.2 0.7 0.3 0.16 0.2 0.7 0.6 0.3 0.16 0.2 3.1 gm/mile 2.0 gm/mile 1.0 gm/mile Current Regulations Based on OBERS econo- mic population growth (0.5Z to 4X per year) 18 ------- Table 3. SOg and Particulate Control Assumptions for Industrial Sources Other Than Fuel Burners EXISTING INDUSTRIAL FACILITIES Type of Facility Chemical Manufacturing Food and Agricultural Processes Primary Metals Secondary Metals Mineral Products Petroleum Industry Process Gas Comb. FCCU Mood Products Metal Fabrication Other S02 Control 92% 93% 93% 55% 99.65% 0% 78.5% 80% Particulate Control 98% 98.8% 99% 99% 98.9% 85% 93% 97.7 % 50% 90% Type of Facility Chemical Manufacturing Food and Agriculture Primary Metals Secondary Metals Mineral Products Petroleum Industry Process Gas Comb. FCCU Mood Products Metal Fabrication Other NEW INDUSTRIAL FACILITIES S02 Control 95% 95% 95% 80% 99.8% 50% 85% 90% Particulate Control 99% 99% 99.5% 99.5% 99.5% 95% 98% 99% 75% 95% 19 ------- It was assumed that new sources would comply with Federal new source performance standards (NSPS) or SIP regulations, whichever were more stringent. Assumed NSPS limits were used for sources for which NSPS have not yet been promulgated and for possible revisions to currently applicable NSPS. As can be seen 1n Table 1, the control assumptions used for new coal-burners varied with time and with the boiler size; this was done to approximate the applicability of new or revised NSPS. The control assumptions used In this study were, as mentioned, optimistic. The Intent of these assumptions was to estimate the potential for minimizing air quality constraints on NE? coal use through the application of a high degree of emissions control; the Intent was not to estimate the degree of control that will result from current regulatory and enforcement activities, and it is in this sense that the assumptions are optimistic. 7. Future (1985) Air Quality The 1985 pollutant concentrations (air quality) estimated by this study were used to determine whether the BAU growth and/or NEP coal use, as apportioned to counties by this study, would encounter potential siting problems. The areas of the counties represented by the predicted concentrations are, because of the analytical techniques and assumptions used, most apt to be the already industrialized areas of the counties. These estimated concentrations reflect the analytical parameters used in this study, for example: (1) estimations of 1985 emissions were based on total source compliance with the regulatory emission limits, actual and assumed, applied in the study; (2) apportionment of 1985 BAU industrial fuel use from Federal regions to counties was based on current fuel use 20 ------- locations and levels; and (3) analysis of more NEP-1ncreased coal use than Is expected to result from the Congressionally-amended NEP. While the estimated concentrations .served the purpose of this study, they were not Intended to, and do not, serve to Identify areas of future attainment or non-attainment of the NAAQS. The identification of such areas is required by recent amendments to the Clean,Air Act, and separate studies to comply with this requirement are in progress. V. The Results The coal substitution program in the National Energy Plan was estimated to increase industrial and utility coal use by 296 million tons by 1985. This coal would be used primarily in new facilities constructed both to expand capcacity and to replace old oil- and gas-burners. The new facilities would be located both at new and at existing industrial and utility sites. Actual locations at which this NEP-increased coal use would occur were not known, and the coal use was apportioned in this study to 1625 counties in 48 states. The apportionment was based on projected county-level industrial and utility fuel use under business-as-usual conditions, i.e., without implementation of the NEP. Seventy-eight percent of the NEP coal was apportioned to counties for which the availability of current air quality data permitted a projection of potential air quality constraints on the use of this coal. The remaining 22 percent of the NEP coal was apportioned to counties for which no current air quality data were available, preventing the estimation of future air quality that might constrain this coal use. This type of coal-use distribution would be expected in fact to occur. That is, the majority of the increased coal 21 ------- use would likely occur in the more Industrialized areas, areas in which air quality is likely to be monitored, and a lesser increase would likely occur in the less industrialized areas. The following table summarizes the apportionment of the NEP-increased coal use, and the remainder of the discussion of results pertains to the counties for which air quality data were available. Table 4. NEP Coal Apportioned to Counties With and Without Air Quality Data No. of NEP Coal Category Counties Assigned 10s tons With AQ data 902 232 (78%) Without AQ data 723 64 (22%) Total 1625 296 1. Potential Siting Problems Counties were classified as presenting potential siting problems for NEP-increased coal use 1fj projected 1985 air quality did not meet National primary ambient air quality standards. If the standards were not met under the business-as-usual (BAU) projection for a county, all of the NEP coal use apportioned to that county was estimated to encounter potential siting problems. If the standards were met under the BAU projection but contravened under the NEP coal use projection, the amount of coal use associated with the contravention was estimated to encounter potential siting problems. If the standards were met under both the BAU and NEP projections, none of the coal was estimated to encounter potential siting 22 ------- problems. The term "potential siting problem" was used because the results of this study relate to the more industrialized areas within counties, and the air quality constraints on the siting of new facilities would be less severe outside the already industrialized areas. An illustration of this is shown in Appendix A, a case study of the Baltimore, Maryland area. As described, the 902 counties analyzed fall into three categories: Category A, in which none of the NEP-increased coal use would encounter potential siting problems; Category B, in which some would; and Category C, in which all would. The number of counties in each category and the potential siting problems associated with NEP-increased coal use are summarized in Table 5. Table 5. Counties Analyzed for Potential Siting Problems for NEP-increased Coal Use Potential Siting Problems County Number of Category Counties Np_ Yes A 731 (81*) 128 million tons B 48 ( 5%) 19 million tons 34 million tons C 123 (14%) - 51 million tons Total 902 147 million tons 85 million tons (37%) As shown in Table 5, 81% of the counties would not present any potential siting problems for NEP-increased coal use. In 5% of the counties, some of the increased coal use would encounter such problems and some would not. In 14% of the counties, all of the NEP-increased coal use would 23 ------- encounter potential siting problems; this resulted from estimates that, In these counties, buslness-as-usual (BAU) air quality would fall to meet the National standards. The pollutant most frequently associated with potential siting problems was TSP. In the counties with potential problems In siting NEP coal use or In siting both busines-as-usual growth and NEP coal use, 60% of the potential problems were due to TSP, 25% due to S02» and 15% due to both S02 and TSP. A few counties were predicted to encounter difficulty in siting NEP coal use because of N02 concentrations, but all of these counties also present potential siting problems because of S02 and TSP; therefore, there are no counties in which increased coal use encounters potential siting problems solely because of N02 concentrations. 2. Spatial Distribution of Counties with Potential Siting Problems Examination of the 171 counties with potential siting problems for some or all of the NEP coal apportioned to them shows that the counties are rather widely distributed among the 48 states; no single state has a preponderance of counties with difficult-to-site NEP coal. In fact, there are several states with no counties which pose potential siting problems. If there is any spatial pattern to the distribution of the 171 counties, it appears to correlate with historical geographical industrial activity: the Ohio and Mississippi River basins, the western portion of the Gulf Coast, and the far southwest (Southern California and Southern Nevada). Generally, Federal Regions V and VI (which include the states of Arkansas, Illinois, Indiana, Louisiana, Minnesota, Michigan, New Mexico, Ohio, Oklahoma, Texas and Wisconsin) contain about one-third of the counties with 24 ------- potential siting problems for Increased coal use. As expected, the 171 counties Include many major metropolitan/Industrial areas. 3. Severity of Potential Siting Problems Examination of the distribution of the extent to which counties are projected to exceed the ambient air quality standard due to either BAU growth alone or BAU growth with NEP coal Indicates that a number of counties have Industrialized areas with slight to moderate siting problems. This group includes those counties projected to have pollutant concentrations of up to 50% above the standard. A significant number of counties may have industrialized areas with more severe problems, as indicated by projected pollutant concentrations of more than one and one-half times the standard. These results are summarized in Table 6. Table 6. Severity of Potential Siting Problems Percent by Which Air Quality Exceeds the Standard Number of Counties Exceeding Standard by Amount Indicated 0 to 10% 10 to 25% 25 to 50% More than 50% 1975 S0.2 10 18 8 20 BAU Growth Without NEP Coal TSP 72 73 73 69 SOa 8 5 11 26 TSP 29 32 25 27 BAU S0_2 14 10 14 42 Growth With NEP Coal TSP 28 35 29 44 25 ------- 4. Coal Allocation to Counties with Potential Siting Problems Most of the 85 million tons of coal In the 171 counties which have potential siting problems is concentrated in a few counties. For example, Figure 1 shows that 75% of this difficult-to-site coal is in only 32 counties. The coal allocation scheme used in this study is probably biased toward concentration in a few counties because the NEP coal is apportioned to counties which currently have large fuel use and, in many cases, a large emissions base. Resolution of siting problems in those few counties could result in a substantial increase in the NEP coal use that poses no threat to air quality standards. A case study of the Baltimore, Maryland area, described in Appendix A, shows that with projected locations of BAU growth and NEP coal use, substantial portions of the region's capacity to assimilate emissions are under utilized. VI. The Results in Perspective Five basic aspects of this study are summarized below to assist in interpreting the results: (1) The PIES-predicted increase in coal use analyzed in this study relates to the coal, substitution portion, (i.e., conservation techqniues are excluded) of the 'President's original (April, 1977) National Energy Plan. The increase analyzed is estimated at roughly twice that which would result from current versions of the NEP with or without conservation techniques. (2) The reductions in fuel use predicted to result from fuel conservation measures in the NEP are not analyzed in this study. 26 ------- ro 20 40 Figure 1 Cumulative Distribution of Coal In Counties with Siting Problems 60 80 100 Number of Counties 140 160 178 ------- (3) To conduct this analysis, it was necessary to use assumptions which apportioned the NEP coal use and the buslness-as-usual (BAU) growth to counties. The assumptions apportioned BAU growth and NEP coal use by amounts proportional to a county's current industrial activity and current industrial fuel use. (4) The analytical technique used to identify potential siting problems for BAU growth and NEP coal use produced results primarily pertinent to the worst-polluted (generally the most heavily industrialized) area within a county. (5) The degrees of pollutant emissions control assumed in this study represent an optimistically high level of control achievable by 1985. 28 ------- Appendix A A Case Study of Regional Impacts of Coal Substitution As an adjunct to the project a more detailed case study of one air quality control region (AQCR) was undertaken to illustrate the type of analysis which would be necessary to carry the estimates of impacts to a higher level of refinement. The region chosen was the Baltimore, Maryland AQCR, consisting of Baltimore City and Anne Arundel, Baltimore, Carrol, Harford, and Howard Counties. Refinements in the case study relative to the national analysis included: t Diffusion modeling of spatially interrelated sources and receptors in lieu of aspatial proportional models applied to county aggregates of emissions and single point estimates of air quality; and • spatially distributed growth based on projected and planned changes in land use and economic activity. Methodology and Assumptions Projected Activity Levels. Levels of population and economic activity in 1985 were taken from projections prepared by the Bureau of Economic Analysis, Department of Commerce (OBERS/Series E) and Data Resources, Inc. (DRI). Projections of manufacturing activities were disaggregated by Standard Industrial Classifications (SIC). OBERS and DRI industrial projections were modified for the iron and steel category to reflect known expansion plans of one major firm. Electric utility expansions were based on announced plans. A-l ------- Spatial Patterns of Growth. Projected growth in the chemicals (SIC 28), primary metals (SIC 33), and petroleum refining (SIC 2911) categories were assumed to occur at present locations for those Industries. For all other categories, half of the growth was assumed to occur at existing sites and half at sites identified by the Regional Planning Council's (RFC) Master Plan. Non-industrial activity was assumed to follow the RPC plan. Utility growth was sited at announced locations. Fuel Use Assumptions. For the 1985 Business-as-Usual (BAU) scenario, the levels and mix of fuels for industrial use were projected in direct proportion to industrial growth and existing patterns of fuel use. Total industrial fuel use was projected to be 109 x 1012. The mix of fuel use in residential and other sectors were implicitly assumed to remain unchanged while the levels of use were projected in direct proportion to population increases. For the Coal Substitution case, 52 x 1012 Btu supplied by other fuels under the BAU case were replaced by coal. This estimate was derived from the step-down of PIES projections as discussed in the main report. Locations at which substitutions occurred were identified as follows: t All industrial boilers with greater than 10 MM capacity (on an equivalent Btu basis) were assumed to burn coal; • Cement kilns and processes currently utilizing any coal were assumed to use coal exclusively; t All small industrial boilers (<10 MW) were assumed to convert to electricity because direct coal use was not believed to be practical for this size boiler. Electricity requirements (increased by 50% to allow for distribution losses) for these boilers was A-2 ------- assumed to be supplied by coal-fired utility boilers, thereby accounting for the balance of new coal not otherwise allocated to large boilers and processes. Emission and Control Technology Assumptions t Industrial technology was assumed to be unchanged over the time horizon, thereby holding constant emission rates per unit of industrial activity; thus industrial process emissions were projected in direct proportion to industrial activity. • Area source emissions were increased according to populations increases. • New utility boilers were assumed to be controlled by existing NSPS. f New industrial boilers, including those which were assumed to be replaced with coal units by 1985, were assumed to meet the Maryland SIP or NSPS (whichever is more stringent) for S02. • Fugitive emissions and interegional transport of pollutants make some contributions to regional air quality, but they were neglected in this case. t Existing sources not presently meeting emission limitations under the Maryland SIP were assumed to be in compliance by 1985, as were all new sources. Modeling Air Quality (as measured by the annual-average concentrations of TSP and SO at ground level) over the five-county area was estimated for A A-3 ------- existing emissions patterns, the 1985 BAU emission patterns, and the 1985 Coal Substitution case, using EPA's Air Quality Display Model. That model has the capacity to predict changes in air quality at all points in the region that result from modification of emission rates at any given point. Results Base Year. Two areas within the Baltimore AQCR are currently in violation of the TSP standard as shown in Figure 1; all of the region is in compliance with the S02 standard. 1985 Buslness-as-Usual Case. The TSP standard would continue to be violated under the 1985 BAU pattern of emissions as shown in Figure 2; S02 standards would be maintained in a compliance status. 1985 Coal Substitution Case. » With respect to the TSP criterion, the coal substitution program would have little incremental impact relative to the 1985 BAU case shown in Figure 2; the region would remain in violation of TSP standards with the severity and spatial patterns approximately the same as the 1985 BAU case. • Coal substitution at the level of 52 x 1012 BTU and located according to the stated assumptions would lead to violations of the S02 standard as shown in Figure 3. Discussion of Results Because of different assumptions about growth, differences in averaging intervals for air quality, and differences in air quality models, A-4 ------- results of the case study are not comparable to those in the national analysis discussed in the main body of this report. However, both studies identified Baltimore City and Baltimore County as having siting problems for coal substitution with respect to both the TSP and S02 criteria. The case study does reveal that, by the judicious selection of sites at which new growth could occur, the region could accommodate much of the coal conversion program while satisfying air quality standards. An examination of Figures 2 and 3 shows substantial areas in the vicinity of Baltimore that could accommodate new growth; it is when that growth and coal substitution takes place within the existing industrial areas that violations of air quality standards will occur. Thus, the aspatial national level analysis tends to underestimate the level at which coal could be substituted for other fuels in the Baltimore AQCR. Determination of the level at which that substitution could occur is highly dependent on where within the region growth and substitution takes place. A-5 ------- 4410 1 1 1 FIGURE I BALTIMORE AIR QUALITY CONTROL REGION MEASURED TSP CONCENTRATION (;ig/m3 AGM) 400 44!(> - \ ! \ \X «f \ * > I COUNTY COUNTY "**S. ^W LEGEND Area Exceeding Primary Standard, (75pg/m3) Area Exceeding Secondary Guideline, (60>jg/m3) Area Where Concentration Is Greater j Than 1/2 The Primary Standard (38>jg/m3) 4280 -4280 310 _J A-6 400 ------- 4 no FIGURE 2 BALTIMORE AIR QUALITY CONTROL REGION 1985 BUSINESS AS USUAL TSP (jjg/m3) AGM LEGEND Area Exceeding Primary Standard, (75pg/m3) Area Exceeding Secondary Guideline, (60Ajg/mS) Area Where Concentration Is Greater Than 1/2 The Primary Standard (38>jg/m3) 4280- 4260 .110 40O A-7 ------- 310 4410 FIGURE 3 BALTIMORE AIR QUALITY CONTROL REGION 1985 COAL SUBSTITUTION PROGRAM TSP (pg/mS) AGM 400 4410- BALTIMORC COUNTY; LEGEND Area Exceeding Primary Standard, (80>ig/m3) Area Exceeding 60yg/m3 Area Where Concentration Is Greater Than 1/2 The Primary Standard 4280- -4280 310 400 A-8 ------- |