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Air Quality and Stationary Source Emission Control CHAPTER 12 CONTROL OF AMBIENT SULFUR DIOXIDE CONCENTRATIONS WITH TALL STACKS AND/OR INTERMITTENT CONTROL SYSTEMS (Chapter 12 was written by Robert W. Dunlap under the general supervision of the committee, which reviewed the work at several stages and suggested modifications which have been incorporated. While every committee member has not necessarily read and agreed to every detailed statement contained within this report, the committee believes that the material is of sufficient merit and relevance to be included in this report.) INTRODUCTION Air quality implementation plans were enacted by the states in 1972 to bring about local compliance with national ambient air quality standards (AAQS). Not surprisingly, sulfur dioxide emission limitations for electric utility power plants varied widely in these plans. Much of the variation can be ascribed to regional fuel availability considerations, to state-imposed air quality standards or timetables, and to differing methodologies for relating emissions and air quality. Some of the variation, however, represents moot recognition of the different capacities of regional atmospheres to safely assimilate specific emission levels. For example, Pennsylvania’s regulations (Table 12–1) allow about an eightfold difference in emission rates, dependent upon source location. These allowed spatial differences in emission rates, with all rates designed to meet the same sulfur dioxide
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Air Quality and Stationary Source Emission Control TABLE 12–1 Pennsylvania Sulfur Dioxide Regulations for Steam Power Plants (Existing Sources) Area Allowed Lbs SO2/10° BTU Allowed Coal % S* Philadelphia - 0.3 Allegheny County (Pittsburgh) 0.6–1.0 0.4–0.6 Beaver Valley, Monongahela, and SE Pennsylvania Air Basins 0.6–1.0 0.4–0.6 Allentown-Easton, Erie, Harrisburg, Johnstown, Lancaster, Reading, Scranton-Wilkes Barre, York Air Basins 1.8–3.0 1.1–1.9 All Other Regions 4.0 2.5 * Assumes 12,500 BTU/Lb Coal.
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Air Quality and Stationary Source Emission Control AAQS, are understandable in terms of different numbers of sources, background sulfur dioxide levels, meteorological characteristics, and topography for Pennsylvania’s air basins. Temporal variations in emission limitations were not part of most states’ implementation plans, except as part of emergency episode criteria. However, the situation here is roughly analogous to the spatial variation situation. At any given emission rate, it can be generally stated that carefully chosen temporal fluctuations about that rate will provide air quality benefits, since variability in meteorological conditions causes significant changes in the air quality impact of any given level of emissions. With temporal controls, when dispersive characteristics of the atmosphere are unfavorable, minimum emission rates are demanded; when optimal atmospheric dispersion conditions exist, higher emission rates than the base rate are permitted. This air quality management concept, i.e., that emissions can be spatially and temporally varied to achieve compliance with air quality standards, has only been partially accepted by regulatory agencies over the past several years. In particular, temporal emission controls for sulfur dioxide, here termed intermittent control systems (ICS), have been recognized in this country only in specific situations, and have been a focal point of a lively debate between regulatory agencies and some parts of the electric utility industry.1 This position paper details some of the aspects of this debate in order to assess current and future public policy concerning ICS programs.
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Air Quality and Stationary Source Emission Control TALL STACKS AND ICS PROGRAMS An intermittent control system can be defined as “…system whereby the rate of emissions from a source is curtailed when meteorological conditions conducive to high ground-level pollutant concentrations exist or are anticipated” (FR 1973). For power plants, two intermittent control strategies are potentially available: (a) fuel switching, i.e., using a temporary supply of low sulfur fuel; (b) load shifting, i.e., shifting a portion of the electrical load to an interconnected generating station with capacity in excess of demand. Tall stacks are closely associated with ICS programs, since increased stack height can yield decreased needs for intermittent emission reductions, assuming that control of ambient sulfur dioxide concentrations is the sole objective. For example, TVA’s comparison of estimated maximum ground level concentrations of sulfur dioxide associated with different meteorological dispersion conditions and stack heights between 60–360 meters is shown in Figure 12–1 (Carpenter 1971). Three critical meteorological conditions are depicted, each corresponding to a different plume transport condition: coning, inversion breakup, and trapping (mixing depths between 760–1065 meters).2 For coning and inversion breakup conditions, an inverse relationship between stack height and concentration applies. For trapping conditions, concentrations are primarily determined by the elevation and magnitude of the subsidence inversion or stable layer aloft; stack height does play a role if the plume emitted from the stack penetrates the layer of stable air and is not trapped below it (concentrations for plume penetration cases are approximately zero and are not shown in Figure 12–1). Based on dispersion model results such as these, as well as ambient air quality data, TVA suggests the anticipated requirements for ICS measures at its Kingston steam plant will drop from 55 days per year (7-hour average duration) for the plant’s current stack configuration (four 250-foot stacks and five 300-
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Air Quality and Stationary Source Emission Control FIGURE 12–1: Maximum Relative Concentration of SO2 as a Function of Meteorological Conditions and Stack Height (Carpenter et al. 1971)
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Air Quality and Stationary Source Emission Control foot stacks) to zero days per year for two 1000-foot stacks (TVA 1973). Two basic types of tall stack-ICS programs are thus apparent. In the first, stacks of sufficient height are built so that ground-level concentrations do not abrogate standards, even without use of ICS measures. This approach is advocated in Great Britain (Stone and Clark 1967, Lucas 1974), and also by some utilities in this country for plants located in relatively flat terrain where no limitations on stack height (e.g., limitations imposed by flight safety requirements near airports) exist (Frankenberg 1970, Smith and Frankenberg 1974). In the second approach, applicable where ambient sulfur dioxide standards cannot be met simply by increasing stack height, tall stacks are coupled with ICS measures to control ground-level sulfur dioxide concentrations. Controversy has existed over whether tall stacks alone can adequately control ground-level sulfur dioxide concentrations. It seems clear, however, that as stack height increases, the required frequency of use of ICS measures decreases for most, if not all, given control situations. The frequency of ICS use is also dependent on emission rate, other stack parameters (stack gas velocity, temperature), meteorological conditions, and topography. Regulations proposed by the Environmental Protection Agency (EPA) do not accept increases in stack height beyond levels of “good engineering practice” as acceptable air quality control measures, unless this is accomplished as part of an approved ICS program (FR 1973). These same proposed regulations impose stringent limitations on the types of sources and situations for which ICS programs are acceptable, and include the following constraints: The ICS program must be a supplement to constant emission controls; the source must undertake research and development programs to accelerate development of applicable constant emission reduction technology. The system must exhibit a high degree of reliability (ability to protect against violation of AAQS) and must be legally en-
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Air Quality and Stationary Source Emission Control forceable. Elements of such an ICS are shown in Figure 12–2 (PEDCO 1974) and include: A sulfur dioxide monitoring network sufficient to allow calibration of a dispersion model, as well as interpolation between samplers. An operating model which relates meteorological inputs, emission rates, source data, terrain and location factors to current and future air quality. Meteorological inputs suitable for use in air quality forecasting. Objective rules for emission control, relating air quality predictions to controlled emission schedules. A requirement for continuous evaluation and systematic improvement of ICS reliability (upgrade system). Figure 12–2 indicates the two different modes in which an ICS may be operated: (1) open-loop emission control, in which the decision to reduce emissions is made based on the output of the predictive model; and (2) closed-loop emission control, an emergency operating mode, in which real-time measurements from the air quality monitoring network are used to override the operating model in making the control decision. The closed-loop mode occurs when the open-loop mode of operation has failed, i.e., when ambient air quality measurements exceed specified threshold values and/or AAQS. From the system diagram presented in Figure 12–2, ICS reliability and performance depend on a number of factors: The adequacy and accuracy of monitoring the pertinent emissions, air quality, and meteorological parameters; The ability to forecast meteorological inputs to the operating model, including transition periods between different types of weather and potential interactions between meteorology and terrain; The adequacy of the air quality forecast model or models, which must represent all possible meteorological conditions, account for terrain and location factors, and estimate anticipated emission rates;
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Air Quality and Stationary Source Emission Control FIGURE 12–2: Elements of an Intermittent Control System (PEDCO 1974)
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Air Quality and Stationary Source Emission Control The ability to control source emissions in a timely manner in order to meet forecast objectives; The ability to combine elements (1)–(4) into an operational system with adequate flexibility to meet the objectives of the system. Each of the system requirements can be achieved with some probability of success; however, the likelihood of attaining a given degree of system performance will depend upon the ability to satisfy all of the system requirements concurrently. Typically, a factor of safety must be invoked to insure adequate system response. This factor of safety is usually embodied within the threshold values of the system; i.e., those forecasted levels of sulfur dioxide which necessitate control measures. The upgrade system is then applied as part of an ongoing effort to select proper forecast values, so that curtailment of emissions are invoked often enough to meet the ambient standards, but are not put into effect unnecessarily often. System performance and reliability are clearly related to the number and severity of forecasted sulfur dioxide levels estimated to occur in excess of the standards; the ICS approach has the greatest chance for success where the required number of curtailments of emissions is low. LEGAL BACKGROUND The suggestion that tall stacks be used with or without intermittent controls to meet sulfur dioxide standards is a highly controversial one. On the one hand, these techniques have been shown to be effective, at relatively low costs, for reducing ground-level concentrations of sulfur dioxide in the vicinity of power plants burning high sulfur coal (Frankenberg 1970, Smith and Frankenberg 1974, Montgomery et al. 1973, Montgomery and Frey 1974, TVA 1974). On the other hand, the application of these techniques normally provides, over an extended length of time, only a negligible reduction in the amount of pollutants emitted. Primarily for this reason EPA “…considers constant emission
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Air Quality and Stationary Source Emission Control reduction techniques, such as flue gas desulfurization, far superior to dispersion techniques and has proposed regulations that limit the use of such dispersion techniques to situations where constant emission reduction controls are not available” (EPA 1974). EPA further claims “…the concept is not compatible with the Clean Air Act requirement that constant emission limitations be used whenever possible” (EPA 1974b). In the most important legal decision on this subject, Natural Resources Defense Council v. EPA, the 5th Circuit Court of Appeals held that the Clean Air Act requires Georgia to attain national ambient air standards primarily through actual emission reductions rather than dispersion enhancement techniques; application of dispersion techniques is allowed only if exclusive reliance on emission control is infeasible (48a F. 2d. 390, 1974). In reaching this decision, the court determined that the section of the 1970 Clean Air Act amendments which requires that state implementation plans “include emission limitations, schedules, and timetables for compliance with such limitation, and such other measures as may be necessary to insure attainment and maintenance of such primary or secondary standards” (42 USC 1857c-5(a) (2)b) indicates a Congressional intent that emission reduction is the preferred method of meeting ambient air quality standards. Therefore, Georgia’s tall stack strategy for controlling power plant sulfur oxide emissions could be included in its implementation plan “only (1) if it is demonstrated that emission limitation regulations included in the plan are sufficient, standing alone, without the dispersion strategy, to attain the standards; or (2) if it is demonstrated that emission limitation sufficient to meet the standard is unachievable or infeasible, and that the state has adopted regulations which will attain the maximum degree of emission limitation achievable.” This decision suggests that utilities which want to implement tall stack-ICS strategies rather than flue gas desulfurization (FGD) must convince state control agencies that FGD
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Air Quality and Stationary Source Emission Control technology is commercially or technically infeasible. TVA is presently bringing a suit (TVA v. EPA) in the 6th Circuit Court of Appeals which involves this issue as well as the issues of fact and law considered in the Georgia decision. If the 6th Circuit decision differs from NRDC v. EPA, ultimately the Supreme Court may have to resolve the conflict. Two previous cases, Appalachian Power Co. et al. v. EPA and Pennsylvania v. Pennsylvania Power Co., reached opposite conclusions regarding FGD technology. In the first of these, the U.S. Circuit Court of Appeals for the District of Columbia rejected a claim by several power companies that technology was not available to meet EPA’s new source performance standards. The court, ruling in September 1973, said the evidence “…convinces us that the systems proposed are adequately demonstrated, that cost has been taken into consideration, and that emission standards are achievable.” The court added, however, that EPA’s consideration of the sludge disposal problem was insufficient, and remanded the record in the case to EPA for further explanation of sludge effects; EPA has not yet responded with the information. In the Pennsylvania Power case, a Pennsylvania state court upheld a county court opinion that adequate scrubbing technology does not exist. In a February 1974 decision, the court concluded that “flue gas scrubbing devices…are available in theory only, and are not available and proven from an operational or practical viewpoint.” A Lawrence County, Pennsylvania court had previously determined that “the only conclusion to date…is that the most feasible present method is high stack control.” Recently, a September 1974 Ohio EPA hearing examiner’s report favored the tall stack-intermittent control approach, stating that “flue gas desulfurization is not a presently available, technologically feasible method of sulfur dioxide control…” and that “tall stacks, either alone or in combination with supplementary control systems, are a technologically feasible and economically reasonable means of meeting ambient air quality standards for sulfur dioxide” (Ohio EPA 1974).
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Air Quality and Stationary Source Emission Control TABLE 12–9 Estimated Capital and Annual Costs for ICS Programs at Nine TVA Coal-Fired Power Plants (Montgomery and Frey 1974, TVA 1974, Frey 1974) Capital Costs Amount Development, installation of ICS programs and monitoring networks at nine plantsa $ 5 million New tall stacks at three plantsb 47 million Coal switching capability at three plantsc 8 million Additional reserve capacityd — Total Capital Cost $ 60 million $ 3.80/KW1 Annual Costs Capital charges, $60 million at 9.64 per cent $ 5.8 million Capital charges, additional reserve capacitye - Operation and Maintenance 3.0 million Monitors & ICS Programs $2.1 million Stacks 0.9 million Replacement power chargesf 1.1 million Incremental costs for low-S coal 0.6 million Fuel costsg $0.3 million Transportation & handling 0.3 million Total Annual Costs $10.5 million 0.13 mills/KW-Hrh a Total 9-plant capacity, 15713 MW. b Kingston (2 @ 1000'); Shawnee (2 @ 800'); Widows Creek (1 @ 1000'). c Colbert, Cumberland, Johnsonville plants. d Option not selected by TVA and costs not estimated. e Five plants, 55.5×103 MWH @ 20 mills/KWH, purchased. f Three plants, 52×103 MWH. g Average load factor, 0.61.
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Air Quality and Stationary Source Emission Control an alternate means of attaining and maintaining existing AAQS, an important capability given uncertainties or capacity limits regarding other control strategies. Tall stack dispersion is closely related to ICS control, since increased stack height decreases the need for intermittent emission reductions, assuming control of ambient sulfur dioxide concentrations is the sole objective. In the most important legal decision concerning the use of dispersion techniques to meet AAQS, Natural Resouces Defense Council v. EPA, the 5th Circuit Court of Appeals ruled that emission reduction is the preferred method of meeting ambient standards. A case involving similar issues of fact and law (TVA v. EPA) is now being litigated in the 6th Circuit. A spectrum of potential applications of ICS technology exist, with individual situations requiring different forecasting, modeling, and monitoring efforts and capabilities. The frequency and extent of emission reductions necessary to maintain national AAQS with ICS control appear to be simple indicators which demonstrate the degree of difficulty associated with a given use of this technology. Tall stacks and ICS methods have generally proven effective in reducing the number and extent of excess concentrations of sulfur dioxide in the vicinity of single isolated sources. Reliability (i.e., ability to meet AAQS) of existing systems is as follows: At TVA’s Paradise Steam-generating Plant, ICS reliability appears good; national AAQS have been met since initiation of ICS controls in 1969. Emission reductions are necessary at Paradise 0.5 percent of the year. At ASARCO’s Tacoma smelter, system reliability is inadequate to meet local AAQS, although performance has been improving. However, national AAQS have not been exceeded since March 1971 at this installation. Average yearly load curtailment at Tacoma due to ICS control is 15–17 percent of full output. At ASARCO’s El Paso smelter, based on operating results for a 36-day period in 1971, performance characteristics indicated a
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Air Quality and Stationary Source Emission Control substantial improvement in air quality due to ICS controls, but system reliability was inadequate to consistently meet national or local AAQS. Average yearly load curtailment at El Paso due to ICS control is 27–35 percent of full output. System reliability in an ICS program is a function of the accuracy of air quality forecasts. One set of forecasted air quality predictions for a multi-source, urban area (Greater Boston) appears relatively accurate. Other comparisons of forecasted and actual air quality are not available. A need exists for a fully-documented study of an operating ICS system. Such a study should examine information about source data, meteorological data, and actual as well as forecasted air quality measurements in order to permit a definitive analysis of system reliability under various conditions. A 120-day study of a power plant burning high sulfur eastern coal and applying ICS measures is suggested. This concept, if adopted for eastern power plants with ICS controls, would severely limit potential applications of the technology. A recent EPA memo indicates only 18 plants in 15 eastern states have emissions which constitute 90 or more percent of total emissions within their restricted geographical area (U.S. Environmental Protection Agency 1974). TVA suggests the designated liability area concept should be applied as an alternative to emissions-based enforcement procedures, rather than as an additional requirement (Montgomery 1975). Use of the ICS approach with load shifting to reduce emissions during adverse meteorology has a number of implications: Additional reserve requirements are needed; preliminary assessments by TVA indicate these requirements may be as high as 3–4 percent of peak power system load. The efficacy of load shifting can be limited when large-scale, adverse meteorology affects more than one plant in a given region. Over a one-year time period, TVA noted the potential need for simultaneous generation
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Air Quality and Stationary Source Emission Control reduction at two of five plants on 17 of 100 days. Because of plant operating conditions, simultaneous reductions were necessary on only three of the 17 days. The ability of an individual plant to load shift for ICS purposes depends on its particular situation, i.e., location, power system, and pool arrangement. For some plants, no serious constraints exist; for other plants, interim or long-term power pool arrangements to allow load shifting for ICS purposes could be difficult to bring about. The practicality of implementing control actions which demand load reductions can be questioned. Two competing objectives—reliable sulfur dioxide control and reliable power—could presumably conflict if large scale load reductions are needed for implementation of programs. These constraints do not apply if emission reductions occur through fuel switching as part of ICS programs. The constraints which are applicable to ICS systems using fuel switching to reduce emissions during adverse meteorology include the following: Many coal-fired plants will require major modifications in coal handling and feeding systems in order to provide a fuel switching capability based on low sulfur coal. The time required to effect a fuel switch to low sulfur coal may prevent the reliable attainment of short-term AAQS in some situations. Operating problems with low-sulfur coal may be encountered in units not designed for this fuel. These problems include increased particulate emissions, reduced generating capacity, and increased slagging. Burning of low sulfur fuel oil as an alternate fuel in units with dual firing capabilities eliminates these problems. However, converting units without this capability to a dual firing capability is costly ($12–$40/kw), and assured supplies of low sulfur oil may not be available. These constraints do not apply if emission reductions occur through load shifting.
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Air Quality and Stationary Source Emission Control Technical efforts to initiate and operate an ICS program are significant for all systems, but of differing orders of magnitude depending on the complexity of the system. The following constraints exist: If ICS programs are installed in highly compex situations (e.g., ASARCO-El Paso situation) for many sources, trained personnel and firms needed to deliver ICS services may be in short supply. More significant constraints, which are applicable to all ICS programs, could be hardware needs (monitoring equipment) and the time requirements for full operation of the ICS program. Costs for implementing the tall stack-ICS approach are significantly less than comparative costs for FGD systems, both in terms of capital and annual expenditures. Based on TVA experience, with an expanded range of costs to account for increased reserve requirements and application to smaller plants, costs can be expected to be as follows: Capital Costs: $4–10/kw Operating costs, including annualized capital charges: 0.15–0.4 mills/kwh Regulatory agency expenses for monitoring and enforcement of ICS programs represent hidden costs of control, not included in the above estimates. Defraying these costs by licensing and imposition of fees appears equitable. Much of the controversy surrounding implementation of the tall stack-ICS approach is associated with the impact of this technology on acid-sulfate aerosol formation, and effects of these aerosols on health, welfare, and aesthetics. Major disagreements exist in interpreting the limited data base available for understanding this issue. A potential compromise position regarding public policy toward implementation of tall stack-ICS technology can be identified. The technology could be rejected as a permanent control technique, on the basis of the proba-
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Air Quality and Stationary Source Emission Control bility of substantial potential risks associated with increassed atmospheric loadings of sulfur dioxide. At the same time, the technology could be accepted for carefully defined situations as an interim control technique, because of its ability to meet AAQS during implementation of FGD systems and because of its role in reducing the current clean fuels deficit. An important issue regarding implementation of ICS technology concerns the legal enforceability of these systems. Regulations proposed recently by EPA for ICS control emphasize enforcement of prescribed emission limitations included within an approved operational manual for each ISC system, in addition to enforcement based on AAQS. Enforcement based on this dual strategy should be more effective than enforcement based on AAQS alone, since most of the critical elements of the enforcement procedure can be established by the regulatory agency prior to approval of the ICS installation. FOOTNOTES 1 These systems are variously referred to as intermittent control systems, closed-loop systems, dynamic emission control systems, and sulfur dioxide emission limitation systems. ICS is used here as a generic term for these concepts. 2 These plume transport conditions are briefly described as follows: (2) Coning: Near neutral stability conditions, moderate-to-high wind speeds, generally occurring on cloudy and windy days or windy nights. Inversion breakup or fumigation: Stable atmosphere, transport of plume downwind with minimum vertical dispersion, followed by uniform dispersion to ground by thermally induced vertical mixing. Trapping or limited mixing layer dispersion: Subsidence inversion or stable air aloft, uniform dispersion to surface.
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Air Quality and Stationary Source Emission Control 3 Locations and number of monitoring stations have not remained fixed. Data are compared on the basis of equal numbers of observations at different locations before and after implementation of the ICS program. The monitoring network has included from 4 to 14 sulfur dioxide monitors, located in a 22.5 degree area northeast of the plant, at distances ranging from 3 to 17 kilometers from the plant; currently 9 monitors are in operation. 4 Until mid-1974, ASARCO operated under a variance which allowed violations of the lppm-5 minute standard. Civil penalties have been repeatedly assessed for violations of the 1-hour standards (24 penalties in 1972 for violations at 4 PSAPCA stations; 16 penalties in 1973 for violations at 4 PSAPCA stations) (Dammkoehler 1974). 5 Dispatch of power refers to the scheduling of power generation from an interconnected network of plants. Normally, plants are scheduled to operate so as to minimize the total cost of producing electricity. 6 TVA estimates a system for one of their plants would require 16–18 months to become fully operational, including field study, design, and installation phases (Montgomery et al. 1974). PEDCO quotes a 12–24 month period for full operation, with some systems then requiring 1–2 years to achieve reliability (PEDCO 1974). 7 Jimeson et al. (1974) cite costs for a 1000-MW plant of $0.88, and 7.6×106/year, using three ICS strategies. An operating factor of 0.65 was assumed to compute costs per kwh. 8 This concept, if adopted for eastern power plants with ICS controls, would severely limit potential applications of the ICS technology. For example, a recent internal EPA memo indicates only 18 plants in 15 eastern states have emissions which constitute 90 or more percent of total emissions within their “liability area” (EPA 1974).
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Air Quality and Stationary Source Emission Control LITERATURE CITED Altshuller, A.P. (1973) Atmospheric Sulfur Dioxide and Sulfate, Environmental Science and Technology 7(8):709–712, August. Carpenter, S.B. et al. (1971) Principal Plume Dispersion Models: TVA Power Plants, Journal of the Air Pollution Control Association, 21(8):491–495, August. Congressional Record (1974) Senate, June 12. Dammkoehler, A.R. (1974) Puget Sound Air Pollution Control Agency, Seattle, Washington, private communication, December 6. Environment Reporter (1974) Train Reports Administration Accord on Permanent Controls for Power Plants, 5(32):1232–1233, December 6. Federal Energy Administration (1974) The Clean Fuels Deficit—A Clean Air Act Problem, August. Federal Register (1973) Use of Supplementary Control Systems and Implementation of Secondary Standards, Volume 38, No. 178, pp. 25697–25703, Friday, September 14. Federal Register (1974a) 39(195):36018ff, Monday, October 7. Federal Register (1974b) 39(209):38104ff, Tuesday, October 29. Finklea, J.F. (1974) Keynote Address to Symposium on Flue Gas Desulfurization, U.S. Environmental Protection Agency, Atlanta, Georgia, November 4–7. Frank, N.H. (1974) Temporal and Spatial Relationships of Sulfates, Total Suspended Particulates, and Sulfur Dioxide, paper #74–245, Annual Meeting of the Air Pollution Control Association, Denver, Colorado, June 9–13. Frankenberg, T.T., I.A.Singer, and M.E.Smith (1970) Sulfur Dioxide in the Vicinity of the Cardinal Plant of the American Electric Power System, Proceedings of the Second International Clean Air Congress, Washington, D.C. Frey, J.W. (1974) Tennessee Valley Authority, Muscle Shoals, Alabama, private communication, November 1.
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Air Quality and Stationary Source Emission Control Gaertner, John P. et al. (1974) Analysis of the Reliability of a Supplementary Control System for Sulfur Dioxide Emissions from a Point Source, Environmental Research and Technology, Inc., Lexington, Massachusetts, June, under contract to EPA. Gaut, Norman E. (1975) Environmental Research and Technology, Inc., Concord, Massachusetts, private communication, January 6. Gaut, Norman E. et al. (1973) Dynamic Emission Controls: A Cost Effective Strategy for Air Quality Control, Annual Conference of the Instrument Society of America, Houston, Texas. Jimeson, Robert M. et al. (1974) Fossil Fuels and Their Environmental Impact, Symposium on Energy and Environmental Quality, Illinois Institute of Technology, Chicago, Illinois, May 10. Lucas, D.H. (1974) The Effect of Emission Height with a Multiplicity of Pollution Sources in Very Large Areas, Ninth World Energy Conference, Detroit, Michigan, October. MacDonald, B.I. (1973) Conserving Energy Resources, in A Seminar on an Innovative Air Quality Control Strategy for Stationary Sources, Office of Environmental Affairs, U.S. Department of Commerce, Washington, D.C., July. Montgomery, T.L. (1975) Tennessee Valley Authority, Muscle Shoals, Alabama, private communication, February 12. Montgomery, T.L. (1974) Tennessee Valley Authority, Muscle Shoals, Alabama, private communication, December 4. Montgomery, T.L. and J.W.Frey (1974) Tall Stacks and Intermittent Control of Sulfur Dioxide Emissions—TVA Experience and Plans, American Mining Congress, Las Vegas, Nevada, October 7–10. Montgomery, T.L. et al. (1973) Controlling Ambient Sulfur Dioxide, Journal of Metals 25(6):35–41, June. Nelson, K.W. (1974) American Smelting and Refining Company, New York, New York, private communication, December 11.
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Air Quality and Stationary Source Emission Control Nelson, K.W., M.A.Yeager, and C.K.Guptill (1973) Closed-Loop Control System for Sulfur Dioxide Emissions from Non-Ferrous Smelters, American Smelting and Refining Company, New York, New York. Ohio Environmental Protection Agency (1974) Consolidated Electric Utility Hearing Examiner’s Report and Recommendations, Columbus, Ohio, September 6. PEDCO Environmental (1974) Assessment of Alternative Strategies for the Attainment and Maintenance of National Ambient Air Quality Standards for Sulfur Oxides, Preliminary draft report to USEPA, December 6. Schweppe, F.C. (1974) Massachusetts Institute of Technology, Boston, Massachusetts, private communication, December 6. Slater, H.H. (1974) Environmental Protection Agency, Research Triangle Park, North Carolina, private communication, November 26. Smith, M.E. and T.T.Frankenberg (1974) Improvement of Ambient Sulfur Dioxide Concentrations by Conversion from Low to High Stacks, September, in press. Stone, G.N. and A.J.Clarke (1967) British Experience with Tall Stacks for Air Pollution Control on Large Fossil-Fuelled Power Plants, Combustion, 39:41–49, October. Tennessee Valley Authority (1973) Technical Presentation on TVA’s Program for Meeting Ambient Sulfur Dioxide Standards, Chattanooga, Tennessee, September 14. Tennessee Valley Authority (1974a) Tennessee Valley Authority Programs for Sulfur Oxide Control at Electric Power Plants, Knoxville, Tennessee, July, (Draft). Tennessee Valley Authority (1974b) Summary of Tennessee Valley Authority Atmospheric Dispersion Modeling, Conference on the TVA Experience at the International Institute for Applied Systems Analysis, Schloss, Laxenburg, Austria, October. U.S. Environmental Protection Agency (1974a) Report of the Hearing Panel, National Public Hearings on Power Plant Compliance with Sulfur Oxide Air Pollution Regulations,
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Air Quality and Stationary Source Emission Control Washington, D.C., January. U.S. Environmental Protection Agency (1974b) National Strategy for Control of Sulfur Oxides from Electric Power Plants, Washington, D.C., July 10. U.S. Environmental Protection Agency (1974) Implications of Alternative Policies for the Use of Permanent Controls and Supplemental Control Systems (SCS), November 18. Welch, R.E. (1974) American Smelting and Refining Company, Tacoma, Washington, private communication, December 6.
Representative terms from entire chapter: