'''"'- •- .'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
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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
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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
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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.
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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.
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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
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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.
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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)
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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
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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
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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
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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
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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
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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.
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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
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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
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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.
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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,
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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.
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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
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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
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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.
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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
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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
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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
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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
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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
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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
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