SUBCHAPTER 19SUBCHAPTER 19 APPENDICES C AND G

SC 19 StudySC 19 Study

• Where do the numbers come from?Where do the numbers come from?

• Re-evaluate the basis of the numbers.Re-evaluate the basis of the numbers.

• How would you come up with the numbers How would you come up with the numbers today?today?

APPENDICES C AND GAPPENDICES C AND G

CHRONOLOGICAL HISTORYCHRONOLOGICAL HISTORYo 19701970 – 1970 FEDERAL CAA: SEC. 111 – 1970 FEDERAL CAA: SEC. 111

NSPS AND SEC. 112 NESHAPNSPS AND SEC. 112 NESHAP o 19701970 – APPENDIX C AND G ADOPTED IN – APPENDIX C AND G ADOPTED IN

ORIGINAL SIP AS FIGURE 1 AND TABLE 1 ORIGINAL SIP AS FIGURE 1 AND TABLE 1 RESPECTIVELYRESPECTIVELY

o 19711971 – NSPS FIRST PROPOSED, – NSPS FIRST PROPOSED, INCLUDING STANDARDS FOR STEAM INCLUDING STANDARDS FOR STEAM GENERATING UNITS (0.2 LB/MMBTU)GENERATING UNITS (0.2 LB/MMBTU)

o 19751975 – NSPS FINAL – NSPS FINAL

1. Documentation includes a stack test protocol (1974) and a letter (1976).

2. The sole living developer of the Subchapter 19 appendices has stated that the standards contained in the appendices included both filterable and condensable PM when originally adopted.

3. EPA has confirmed that if the 1970 Oklahoma SIP had excluded back-half, it would not have been approved.

APPENDIX CAPPENDIX CCOMPARISON TO OTHER STATES COMPARISON TO OTHER STATES

o Arkansas No state standardo Colorado W/O condensables: allowables

are about 1/3 of Appendix Co Iowa 1. Outside any standard

metropolitan area = 0.8 Lb/MMBTU

2. Inside a standard metropolitan area = 0.6 Lb/MMBTU

3. New fossil fuel fired steamgenerating unit:

A. (150–250 MMBTUHr = 0.2 Lb/MMbtuB. Less than 150 MMBTUHr

= 0.6 Lb/MMBTU4. Separate allowables for asphalt batch plants, cement kilns, cupolas for metallurgical melting, electric furnaces for mm, sand handling, grain handling, lime kilns, meat smokehouses, phosphate plants, Portland cement batch plants, incinerators and paint and surface coating.

o Kansas Same as Appendix Co Louisiana W/condensables: 0.6 Lb/MMBTUo Minnesota Tables not available on lineo Missouri W/condensables: same as

Appendix Co Nebraska 1. 10 MMBTUHr or less - same as

Appendix C2. Greater than 10 MMBTUHr and less than 10,000 MMBTUHr -

slightly higher than Appendix C3. 10,000 MMBTUHr or more = 0.12 Lb/MMBTU

o New Mexico W/condensables: same as Appendix C

o Texas W/condensables: Up to 0.3 Lb/MMBTU for EGU’S rated at 2500 MMBTUHr or more (solid fuel fired - 2 hr average) and 0.1Lb/MMBTU for oil or gas fired EGU’s

APPENDIX GAPPENDIX GCOMPARISON TO OTHER STATESCOMPARISON TO OTHER STATES

o Arkansas No state standardo Bay Area Same as Appendix Go Colorado W/O condensables: about 73%

of Appendix Go Iowa Same as Appendix Go Kansas 1. Same as Appendix G for feed

rates of 60,000 Lb/Hr or less2. 73% of Appendix G for feed rates greater than 60,000 Lb/Hr

o Knox Co., Tenn. 1. Existing sources same as Appendix G2. New sources same as Minnesota

o Louisiana Same as Appendix Go Minnesota 1. Slightly less than Appendix G

up to 60,000 Lb/Hr feed rate2. Less than Appendix G for 60,000 Lb/Hr feed rate or more

o Missouri Same as Appendix Go Nebraska Same as Appendix G

oNew Mexico Specific allowables for each industry. pumice, mica, perlite, non-ferrous smelters, oil-burning equipment, potash, salt, sodium nitrite, lime mfg plants.

o South Dakota Same as Appendix Go Texas W/condensables:

1. Less than Appendix G for 5000 Lb/Hr feed rate or less2. Greater than Appendix G for greater than 5000 Lb/Hr feed rate

EGU'S IN OKLAHOMA EMISSION TEST

0

0.050.1

0.150.2

0.25

1 2 3 4 5 6 7 8 9 10 11

EGU'S

Lb/M

MBT

U

APPENDIX C NSPS (D OR Da) EMISSIONS

VARIOUS FACILITIES IN OKLAHOMA EMISSION TEST

0

20

40

60

80

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15

FACILITIES

LB/H

R

APPENDIX G EMISSIONS

October AQC MeetingOctober AQC Meeting

• How would you come up with the numbers How would you come up with the numbers today?today?

• Summary of studySummary of study

• Recommendation of optionsRecommendation of options