SUBCHAPTER 19 APPENDICES C AND G

1. SUBCHAPTER 19 APPENDICES C AND G

2. SC 19 Study • Where do the numbers come from? • Re-evaluate the basis of the numbers. • How would you come up with the numbers today?

3. APPENDICES C AND G CHRONOLOGICAL HISTORY 1970 – 1970 FEDERAL CAA: SEC. 111 NSPS AND SEC. 112 NESHAP 1970– APPENDIX C AND G ADOPTED IN ORIGINAL SIP AS FIGURE 1 AND TABLE 1 RESPECTIVELY 1971 – NSPS FIRST PROPOSED, INCLUDING STANDARDS FOR STEAM GENERATING UNITS (0.2 LB/MMBTU)

4. 1975 – 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.

5. APPENDIX C COMPARISON TO OTHER STATES Arkansas No state standard Colorado W/O condensables: allowables are about 1/3 of Appendix C Iowa 1. Outside any standard metropolitan area = 0.8 Lb/MMBTU 2. Inside a standard metropolitan area = 0.6 Lb/MMBTU

6. 3. New fossil fuel fired steam generating unit: A. (150–250 MMBTUHr = 0.2 Lb/MMbtu B. Less than 150 MMBTUHr = 0.6 Lb/MMBTU 4. 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.

7. Kansas Same as Appendix C Louisiana W/condensables: 0.6 Lb/MMBTU Minnesota Tables not available on line Missouri W/condensables: same as Appendix C Nebraska 1. 10 MMBTUHr or less - same as Appendix C 2. Greater than 10 MMBTUHr and less than 10,000 MMBTUHr - slightly higher than Appendix C 3. 10,000 MMBTUHr or more = 0.12 Lb/MMBTU New Mexico W/condensables: same as Appendix C

8. 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

9. APPENDIX G • COMPARISON TO OTHER STATES • Arkansas No state standard • Bay Area Same as Appendix G • Colorado W/O condensables: about 73% of Appendix G • Iowa Same as Appendix G • Kansas 1. Same as Appendix G for feed rates of 60,000 Lb/Hr or less • 2. 73% of Appendix G for feed rates greater than 60,000 Lb/Hr

10. Knox Co., Tenn. 1. Existing sources same as Appendix G • 2. New sources same as Minnesota • Louisiana Same as Appendix G • Minnesota 1. Slightly less than Appendix G up to 60,000 Lb/Hr feed rate • 2. Less than Appendix G for 60,000 Lb/Hr feed rate or more • Missouri Same as Appendix G • Nebraska Same as Appendix G

11. New Mexico Specific allowables for each industry. pumice, mica, perlite, non-ferrous smelters, oil-burning equipment, potash, salt, sodium nitrite, lime mfg plants. • South Dakota Same as Appendix G • Texas W/condensables: • 1. Less than Appendix G for 5000 Lb/Hr feed rate or less • 2. Greater than Appendix G for greater than 5000 Lb/Hr feed rate

14. October AQC Meeting • How would you come up with the numbers today? • Summary of study • Recommendation of options