EPA-450/2-76-006
       STATE  AIR POLLUTION
      IMPLEMENTATION  PLAN
         PROGRESS REPORT,
JULY 1  TO  DECEMBER  31,  1975
                      Prepared by

          U.S. ENVIRONMENTAL PROTECTION AGENCY
              Office of Air and Waste Management
            Office of Air Quality Planning and Standards
           Research Triangle Park, North Carolina 27711

                         and

              U.S. Environmental Protection Agency
                   Office of Enforcement
                    Washington, D.C.
          U.S. ENVIRONMENTAL PROTECTION AGENCY
              Office of Air and Waste Management
            Office of Air Quality Planning and Standards
           Research Triangle Park, North Carolina 27711

                      April 1976

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This report has been reviewed by the Office of Enforcement and the Office of Air Quality Planning
and Standards of the Environmental Protection Agency and approved for publication.
Document is available to the public through the National Technical Information Service,
Springfield, Virginia 22161.
                            Publication No. EPA-450/2-76-006
                                         11

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                                FOREWORD

      This  is  the  sixth in a continuing series  of reports assessing the
progress made by  states in  implementing the  Clean Air Act,  specifically
section 110.  Although the  report is primarily intended to  cover  the
last six months of calendar year  1975,  more  recent  information is provided
when available.
      The State Implementation Plans were published  -in 1972  with an attain-
ment date, in most cases, of May  1975.   Measurable  increments  of  progress
are  occurring at  a slower rate  than in the first years  these plans were
in effect.  The most readily available procedures and technology  have
now  been implemented for the most part;  remaining problems  are not yielding
as easily  to  solution.   Some of the procedures and  technology  that have
been implemented  have  been  challenged  in court,  and litigation has affected
progress,  both by delaying  implementation and  enforcement and  by  extending
EPA's responsibilities to such programs  as prevention of significant
deterioration and increased attention  to air quality maintenance.   Situa-
tions that were not anticipated when the Clean Air Act was  amended in 1970,
such as the energy  crisis,  have required that  different approaches  be
developed, and this development takes  time.
     This  series,  of reports 3is undergoing a  change in format that reflects
the  changing  direction and  emphasis of EPA 's campaign for clean air.  The
first four reports followed similar formats and generally presented infor-
mation summarised by EPA region with national  totals.   The fifth report in
the  series was the first one to be published after the attainment date,
and  it provided detailed information by state for the first time.   The
series will continue to present data on  the individual states in the
reports for January to June of each year.  Because change is occurring at
a slower rate, however, these detailed reports will be annual rather than
semiannual.  The reports for July to December of each year will instead be,
like this one, primarily summary reports with certain topics singled out
for special focus each time.  The feature topics in this issue are the
current SIP evaluation process and the status of carbon monoxide/oxidant
control strategies.

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                            ACKNOWLEDGMENTS

     The preparation of this report resulted from information provided
by the state and local air pollution control agencies, the Environmental
Protection Agency Regional Offices, and various EPA Headquarters groups.
     As with earlier reports relating to State Implementation Plan
progress, this edition continues to be a joint effort between the
Division of Stationary Source Enforcement, Office of Enforcement, and
the Office of Air Quality Planning and Standards, Office of Air and
Waste Management.
     Information on enforcement activities was provided by the Division
of Stationary Source Enforcement, Office of Enforcement.  Additional
specific information on EPA air programs can be obtained by contacting
the EPA Regional Offices.
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                                CONTENTS
  LIST OF TABLES	    vii

  LIST OF FIGURES	   V1-ji

  ABBREVIATIONS	 . .	     ix

  I.  SUMMARY  ; .	      i

      Development of SIPs  	      i
      SIP Progress	      2
      Air Quality and Emission Data	      3
      Stationary Source Compliance 	      3
      Control Agency Resources 	 	 ...      4

 II.  DEVELOPMENT OF SIPs  .  .	      5

      SIP Evaluation	      5
      Pollutant-Specific Strategies  	      9
      References   	  	 ......     16

III.  OVERVIEW OF CARBON MONOXIDE/OXIDANT CONTROL
       STRATEGIES	     17

      Background	     17
      Reasonably Available Control  Measures  .  . 	     19
      Relationship  of EPA's Transportation Control
       Measures to  Those of Other Federal Agencies  	     26
      References	     29

 IV.  SIP PROGRESS	     31

      EPA-Initiated Actions  	     31
      State-Initiated Actions  	     32
      References	     33

  V.  AIR QUALITY AND EMISSION DATA	     41

      Ambient Air Quality Data	     41
      Trends  in Air Quality,  1970-1974 	     45
      Data Reporting    	     47
      Air Pollution Episodes  	     48
      References   	     48

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                          CONTENTS (continued)
 VI.  STATIONARY SOURCE COMPLIANCE
      Overview   	
      Major Source Categories
      References 	
VII.  CONTROL AGENCY RESOURCES
      Summary of Resources 	
      Progress of State and Local Air Pollution
       Control Programs  	
Page

 51

 51
 54
 61

 63

 63

 63
                                    VI

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                            LIST OF TABLES
 Table

 II-l
 IV-1
 V-l
 V-2
 V-3
VI-1
VI-2
                                                          Page

 Reasonably  Available  CO  and  Hydrocarbon
   Control Measures  	     14

 Status of Selected  Portions  of  the
   State  Implementation Plans  	     34

 National Summary of Air  Monitoring
   Stations  Reporting  1974 Data  to the
   National  Aerometric Data Bank by
   September 1975 .  .	     42

 National Summary of AQCRs Reporting
   Violations of NAAQS to the National
   Aerometric Data Bank for 1974	     43

Air Pollution Episodes for August
   Through December  1975	    49

Compliance Status of Major Emitters
   by Region December 31,  1975	 .    .53

Status of Compliance with Emission Limitations
  Major Polluting Steel  Processes vs. All  Major
  Stationary Source Installations
  February 1976  	 .....                ,59
                                  vn

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                           LIST OF FIGURES
Figure
VII-1
VII-2
State and Loca] Air Pollution Control
  Agency Funds - Actual vs. Need . .
State and Local Air Pollution Control
  Agency Manpower - Actual vs. Need
64


65
                                   viii

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                 ABBREVIATIONS AND SYMBOLS
 AQCR
 AQMA
 CO
 CY
 DOT
 EPA
 FEA
 FHWA
 FGD
 FY
 HC
 I/M
 MPO
 NAAQS
 N02
 OAQPS
 °x
 SIP
 so2
 State

TSM
TSP
UMTA
VMT
 Air Quality Control  Region
 Air Quality Maintenance Area
 carbon  monoxide
 calendar year
 U.S.  Department of Transportation
 U.S.  Environmental Protection Agency
 Federal  Energy  Administration
 Federal  Highway Administration
 flue  gas desulfurization
 fiscal year
 hydrocarbons
 inspection/maintenance
Metropolitan  Planning Organization
National Ambient Air Quality Standards
nitrogen dioxide
Office of Air Quality Planning and Standards
oxidants
                              /
State Implementation Plan
sulfur dioxide
Refers to the District of Columbia and four U.S.
  territories as well as the 50 states
Transportation System Management
total suspended particulate
Urban Mass Transportation Administration
vehicle miles traveled
                             IX

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                               I.   SUMMARY
DEVELOPMENT OF SIPs
     EPA Regional Offices are currently evaluating all State  Implementation
Plans  (SIPs) to identify those that will need revising before the National
Ambient Air Quality Standards (NAAQS) may be attained.  The schedule  is:
     0  July 1, 1976 — EPA Regional Offices will call for revisions
        to SIPs that are determined to be "substantially inadequate"
        to achieve the NAAQS.
     0  July 1, 1977 — States submit revisions that require, as needed,
        all achievable emission limitations.
     0  July 1, 1978 -- States submit revisions, if needed, requiring
     ,   other control measures (generally transportation control and
        land use measures).
     These calls for revision will as a minimum address all areas in which
the SIPs are found to be substantially inadequate for attainment, and all
Air Quality Maintenance Areas (AQMAs).  The evaluation will address each
of the five criteria pollutants  -- total  suspended particulate (TSP),
sulfur dioxide (S02), carbon monoxide (CO), oxidants (Ox), and nitrogen
dioxide (N02).   Preliminary analysis indicates the following:
     0  TSP —  More plan revisions will  problably be required for TSP
        than for any other pollutant.   In some areas, emission limitations
        for traditional  sources,  like fuel  combustion and process emis-
        sions,  are not sufficiently stringent and will  need to be revised.
        In  many areas,  however,  emphasis  is  changing from the  generally
        well-controlled  process  stack emissions  to fugitive emissions
        (those  from material  handling, metallurgical  operations,  etc.,
        that do not come from a  stack or  vent).   Regulations being
        developed  for fugitive emissions  depend  on reasonably  available

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        controls to be effective.  Control programs are also being developed
        for some nontraditional sources of TSP, such as fugitive dust and
        secondary particulates.
     0  S02 — Enforcement of existing regulations is expected to result
        in attainment of S02 standards in most areas, so relatively few
        revisions are anticipated for this pollutant.
     0  CO/0  -- Attainment of CO and 0  standards depends primarily on
            A      .                    X
        control of emissions from transportation-related sources.  In
        addition to the Federal new motor vehicle pollution control pro-
        gram, reasonably available categories of control measures include
        inspection/maintenance, transit improvements, employer incentives,
        and parking and traffic management.  The Department of Transpor-
        tation and the Federal Energy Administration now have transporta-
        tion-related programs that should facilitate further progress in
        this area.  In addition, stationary sources of hydrocarbons may
        be controlled to reduce 0  through such measures as vapor controls
                                 A
        for organic solvent usage and gasoline vapor recovery in market-
        ing operations.
     0  NOp — Valid data, though limited, indicate that the N02 problem
        is much less severe and pervasive than the TSP or 0  problems;
                                                           A
        maintenance of N02 standards will be more of a problem than attain-
        ment.  The vast majority of NO  emissions is produced by fuel
                                      A  «
        combustion in both stationary and mobile sources.  Stationary
        source control measures will become increasingly important as
        additional mobile source control regulations are implemented.
SIP PROGRESS
     The SIPs continue to be amended.  No plan is currently fully approved,
although the degree to which each plan is disapproved varies from state
to state.
     During this report period, EPA proposed regulations for air quality
maintenance, an S02 control strategy for the State of Ohio, and  regula-
tions for certain smelters in Montana and Arizona.  The Agency promulgated
nationally applicable regulations for state programs for continuous
monitoring of emissions from four categories of existing sources.

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Regulations were also promulgated for a copper smelter in Utah, for public
comment provisions for previously published new source review regulations
in five states, and for public availability of data in 24 SIPs.  During
this period, 34 state plan proposals and 26 approvals of state-initiated
actions were published in the Federal Register.

AIR QUALITY AND EMISSION DATA
     The status of air quality in the United States in 1974 was in many
respects similar to that for 1973.  Approximately the same percentages
of reporting stations are still exceeding air quality standards, with one
exception:  an apparent decline in the proportion of stations exceeding the
8-hour CO standard.
     The historical data base is sufficient to determine air quality trends
in many areas for TSP and S02.  Based on composite annual average data from
1096 TSP monitoring sites, the ambient concentrations of TSP have been
reduced by about 17 percent during the period 1970-1974.  Similar data from
258 S02 monitoring sites indicate that ambient concentrations of S02 have
been reduced by approximately 32 percent during the same period.

STATIONARY SOURCE COMPLIANCE
     Enforcement of standards at stationary sources has focused on the
21,670 identified major emitters which account for about 85 percent of all
air pollution from stationary sources.  By December 1975, EPA and the states
had brought 18,327 of them into final compliance or placed them on firm
schedules leading to compliance.  A recent study indicates that since
the passage of the Clean Air Act Amendments of 1970, compliance with
Federal, state and local laws kept over 26 million tons of TSP and 7.6
million tons of S02 out of the nation's air.   However, ambient standards
are still being violated in a number of AQCRs.   The states and EPA are
now conducting extensive analyses to determine the reasons for non-
attainment, including the identification of specific major and minor sources
contributing to the problem.  Analyses have indicated that several  cate-
gories of minor sources (e.g., small boilers, incinerators, etc.)  are
contributing to air quality problems.  In addition, several major source

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categories are not achieving compliance with standards.  These are coal-
fired power plants, integrated iron and steel facilities and coking plants,
and primary smelters.

CONTROL AGENCY RESOURCES
     In 1975, 55 state and territorial agencies and 236 local agencies,
working in coordination with states, expended approximately $148 million
and 7000 man-years to carry out the major portions of the regulatory and
enforcement aspects of the national air pollution control effort.  In
Fiscal Year 1975, state and local funds for air pollution programs
increased 20 percent ($17 million) over FY 74 levels, and Federal support
during this period increased by 2 percent ($1.6 million).

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                       II.  DEVELOPMENT OF SIPs
SIP EVALUATION
     The attainment date for primary National Ambient Air Quality Standards
(NAAQS) for most states was May 31, 1975.  Since that date, EPA has intensi-
fied its efforts to identify those areas that are not now attaining the NAAQS
and that are not expected to attain the NAAQS after full State Implementation
Plan (SIP) implementation, which has been delayed in some cases.  Preliminary
assessments of the areas not expected to attain were given in the previous
report in this series.   EPA Regional Administrators are now examining all
SIPs more closely to identify those that will require revisions before the
NAAQS may be attained.  These evaluations are being performed for all areas
of the nation for each of the five criteria pollutants:  total suspended
particulate (TSP), sulfur dioxide (S02)s carbon monoxide (CO), oxidants
(Ox), and nitrogen dioxide (NOp).
     Section 110(a)(2)(H)(ii) of the Clean Air Act as amended requires that
SIPs provide "for revision, after public hearings, of such plan .  . .
whenever the Administrator finds on the basis of information available to
him that the plan is substantially inadequate to achieve the national
ambient air quality primary or secondary standard which it implements"
(emphasis added).  Prior to July 1, 1976, the Agency plans to call for
revisions to those existing SIPs that are determined to be substantially
inadequate for attainment.  These calls for revisions will specify the
schedule for submission of revisions and require that, to the extent needed
to meet national standards, all achievable emission limitations must be
submitted by the state as SIP revisions by July 1, 1977.  The term
"achievable" is intended to require reasonable "technology forcing" if
necessary, rather than simply "off the shelf" technology.  Any other control

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 measures  (generally referring to transportation  control  and  land  use
 measures)  necessary for attainment and  maintenance must  be submitted  by the
 state by July 1,  1978.   (NOTE:   This  is not  intended  to  imply  that  some land
 use  and transportation  measures  are not considered reasonable.  These
 measures,  though  considered  reasonable, generally require more  time to
 implement  due to  need to obtain  enabling legislation.)
      These calls  for revision will  address as  a  minimum  (1)  all areas in
 which the  SIPs  are  found to  be substantially inadequate  for  attainment, and
 (2)  all Air Quality Maintenance  Areas (AQMAs).   In many  AQMAs,  a  formal
 demonstration of  maintenance will  be  needed.   However, flexibility  is
 necessary  in determining what constitutes an adequate demonstration of
 maintenance.
      In general,  SIPs deficient  in  maintenance provisions should  be cor-
 rected  as  expeditiously as practicable  and at  the same time  as  attainment
 deficiencies  are  corrected.   Nonetheless, action to correct  those mainte-
 nance deficiencies  may  need  to be  deferred if  immediate  action would not
 be sensible  or would interfere with actions  needed to expeditiously correct
 attainment deficiencies.  Similarly,  action  to correct deficiencies in
 plans to attain the secondary NAAQS may need to  be deferred  if that action
would interfere with actions  needed to  expeditiously correct deficiencies
 in plans to  attain  the  primary NAAQS.
     The decision to call for a  plan revision will be made only after
 (1) detailed  analysis of the  status of  air quality, the  restrict!'veness of
the existing  regulations, and the status of major compliance actions; and
 (2) thorough  discussions with all pertinent  program elements in the Regional
Office and with the affected  state and  local  control  agencies.
     The Agency must exercise good judgment in determining whether the
control strategy portion of an approved SIP is inadequate to achieve
national standards on a  timely basis.    It is  the Agency's policy to request
such plan revisions only where they are clearly necessary.   To declare that
a SIP is substantially inadequate will  imply  a need for new and more strin-
gent emission limitations.  It will take some time to develop such limita-
tions.  Pollution sources might use this opportunity  to resist coming into
compliance with existing regulations and, thus, ongoing abatement actions

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 could be inhibited.   Further,  frequent revisions,  particularly  where  they
 affect emission  control  requirements,  are  undesirable  in  that they  confront
 source owners  with  a  "moving target."
      Another factor to be  considered is  that  any plan  revision  submitted
 by  a  state  that  changes  some part  of the SIP  or that adds a new part  could
 result in a challenge by the affected  sources to the changed or added part.
 (Section 307 of  the Act  provides for a process of judicial review of  the
 Agency's action  in  approving or promulgating  any implementation plan  or
 revision thereof.)  Experience indicates that substantial delays in enforce-
 ment  can result  from such  challenges.  Nevertheless, if revisions are
 clearly necessary, EPA will not hesitate to call for them.  The Agency has
 published guidance on criteria to be considered in deciding whether
 revision is  necessary.
      Determining whether a SIP is substantially inadequate to attain
 national standards will,  in general, be a difficult task.  The basic prob-
 lem is to determine whether Air Quality Control  Regions (AQCRs)  are progres-
sing satisfactorily toward attainment of national  standards  as sources come
into compliance with emission limitations contained within the SIP.   The
decision must be based on consideration of the following types of factors:
     1.  Factors favoring a finding that the SIP is not substantially
         inadequate:
         a.   Available data provide a  reasonable expectation  that  NAAQS
             have been or will  be  achieved  by  the currently approved SIP
             under provisions of  the existing  control strategy.
         b.   The  most  recent air  quality  data  are below or not far
             above NAAQS.
         c.   Much abatement work  is  ongoing or yet  to be  completed
             under existing regulations.
         d.   Air  quality  and emission data  are not yet  extensive in
             terms  of  time  and  geographical  coverage.
         e.   Air  quality  levels have varied  erratically up and down
             in recent years and a  clear  trend is not yet determinate.
         f.   Emission  control regulations have been made more stringent
             or more comprehensive in the past 1 to 3 years but  are not
             yet  fully implemented.

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                       g.  Existing regulations are very stringent -- at or bordering
                           on a requirement that all reasonable control measures that
                           can be implemented are being used.
                       h.  Major reductions in emissions have been made in the past
                           year or two and perhaps more reductions are programmed for
                           the near future.
                       i.  The governmental air pollution control program has grown
                           substantially in the past few (1 to 3) years and enforce-
                           ment actions are being intensified.
                       Factors favoring a finding that the SIP ^substantially inadequate:
                       a.  There is good evidence that compliance with existing
                           regulations will not result in achieving NAAQS by the existing
                           attainment data.
                       b.  Recent air quality levels are substantially above NAAQS, and
                           air quality and emission data are generally accurate and
                           extensive as to time series and geographic coverage.
                       c.  Most existing regulations have been fully implemented;
                           future improvement in air quality under existing regulations
                           will not be substantial.
                       d.  Air quality levels over the past few years show an evident
                           trend which, in consideration of anticipated abatement,
                           shows clearly that NAAQS will not be attained by existing
                           control measures.
                       e.  Emission control regulations have not changed greatly in
                           recent years.
                       f.  Existing regulations are not particularly stringent and
                           do not include all emission limitations which it is reasonable
                           to anticipate will be achievable within a reasonable period
                           of time.
                       g.  Air quality has shown little change over the past 1 to 3
                           years (and levels are above NAAQS).
                       h.  Governmental control  activities have been reasonably
                           adequate for the past few years (1 to 3) and regulations are
                           probably enforced well.
_

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      It should be noted that judgments about ambient air quality data can-
 not be based on numbers alone.  The fact that ambient data exceed a national
 standard by 10 or 15 percent does not in itself indicate an immediate
 need for a plan revision.   Clearly, the normal  variation of ambient air
 quality due to meteorological  conditions, etc., may cause such a condition
 to exist.   The requirement of "substantially inadequate" provides the
 Regional Office with flexibility in assessing the need for, and especially
 the timing of, a call  for  plan revision.   In some cases, little or no
 ambient air quality data exist to allow for a determination of the adequacy
 of the SIP.   For example,  in many cases,  nitrogen dioxide data may not be
 available  due to the controversy concerning the original reference method.
 While adequate and sufficient  data should exist in many major urban areas
 (due to the  special  field  projects over the past few years),  sufficient
 data may not be available  for  some areas.   In these cases,  any decision
 on attainment and the  need for plan revisions may have to be  delayed.

 POLLUTANT-SPECIFIC STRATEGIES
      This  discussion of the  current SIP evaluation process  has  thus  far
 dealt only with general  considerations.   In  the actual  analysis  of a  SIP,
 however, the problems  affecting  attainment  and  maintenance  of NAAQS  for
 each  of the  criteria pollutants  must be treated separately.   Described
 below are  pollutant-specific strategies that  may  be  considered  if  a SIP is
 determined to  be  inadequate  for  that pollutant.
 Total  Suspended  Particulate  (TSP)
      As  discussed  in the previous  report in this  series,1 many areas are not
 expected to  attain the  NAAQS for TSP, and EPA anticipates that more plan
 revisions will  be  required for TSP  than for any other pollutant.  The
 regulations  in many cities  do not  now require all reasonably available con-
 trol  technology, and additional measures for making further improvements
 are becoming better understood.  Also, most of the initial abatement efforts
 for TSP are nearing completion, and in most situations SIP revisions should
not interfere with current  control efforts.
      In order to determine  that a SIP is substantially inadequate to attain
the NAAQS for TSP, a preliminary analysis of the problems and possible

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 control  strategies must be made.   This  must be  followed  by  a  more  detailed
 investigation of the factors  affecting  attainment and the efficacy of
 candidate control  strategies.   These investigations  will rely on a variety
 of techniques for determining the factors  affecting  attainment.  A number of
 these  techniques (analysis of ambient and  source  data, modeling, etc.)  have
 been used for some time.   However,  a few techniques  (microscopy, directional
 and short-interval  sampling)  are  newer  and have not  been widely applied.
 They are nonetheless useful and constitute one  input into the decision
 process.
     The first step in  a  problem  investigation  is  a  review  of air  quality
 data.  Trends, variations  between sites and neighborhoods,  meteorological
 influences,  patterns in 24-hour readings between  sites, and wind direction
 when the sample was taken  are  all  useful parameters  in determining  the
 potential  factors  affecting each  site.  A  critical review of  the compliance
 status of industries subject  to present regulations  must then  be made.
 Based on  this  review and  using  data  from stack tests, emission factors  and
 operating parameters, an  inventory of emissions in the area is made.  Point
 sources  are  assigned to grids on  an  area map, and  smaller (area) sources
 and transportation  sources are  apportioned  to these  grids by  population and
 other factors.   Finally, a dispersion model  can be used to  simulate the air
 quality  patterns over the  study area, which  will help predict new air quality
 patterns  due  to  growth  or  due to  changes in  regulations and emissions from
 enforcement.   When  properly evaluated and  interpreted, inventories and
 modeling  are  useful  tools  for air quality planning.
     A second  technique being used is the analytical  and physical  examination
 of filter samples to determine  their elemental, chemical  and morphological
 properties.  Provided that sufficient quality assurance measures are taken,
 these analyses in concert can provide valuable information on the aerosol
 constituents and thus the sources of ambient particles.  These analyses are,
 however, still under development and have not been routinely applied.
     Special field studies are  also being used to determine  sources of
 atmospheric particles.  Particle size sampling,  directional  sampling,  and
sampling for short consecutive time intervals and at  various distances  and
heights from suspected sources provide valuable information.  Unfortunately,
                                   10

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 the long lead time required to set up such a field study and the develop-
 mental  nature of some of the sampling equipment have hindered widespread
 application.
      Studies  within EPA, '  »  while not yet complete, are identifying the
 factors affecting attainment in many urban areas.   Traditional  sources such
 as  fuel combustion and process emissions still  play an important part, but
 nontraditional  sources such as sources of fugitive dust, secondary  particu-
 lates and automotive particulates  are being recognized as a  major element in
 the particulate problem.   In addition, variations  in meteorology play an
 active  role in  determining  regional  variations  in  particulate levels.   The
 impacts of certain parameters  such as rainfall,  windspeed, and heating degree
 days  are being  investigated.
      Through  implementation of existing SIPs, most traditional  sources have
 been  effectively  controlled in many  areas.   In  those areas where regulations
 are less stringent and traditional  sources  are  a significant problem,  the
 regulations will  be strengthened.  Methods  of determining compliance  must
 also  be reviewed  in these same areas.   As more  and more  traditional sources
 are controlled, the emphasis of control  strategies  for TSP in  these areas
 will  be changing  from  control  of traditional sources  to  the  newer issue  of
 control  of nontraditional sources.   The following  sections on  control
 strategy alternatives  outline  some of the possible  strategies which may  be
 considered for  both traditional  and  nontraditional  sources.  Final deter-
 mination  of the most effective  control  strategy  must  be made within each
 area.
 Control  Strategy Alternatives;  Traditional Sources  — Emissions from  tradi-
 tional  sources such as  process  emissions are still  significant contributors
 to  the  particulate  problem, but emphasis is changing  from the generally
well-controlled process stack emissions to fugitive emissions  (emissions
 from material  handling, metallurgical operations, etc., that do not come
 from a  stack or vent).  Most agencies do not yet have specific regulations
 for control of fugitive emissions; they rely on nuisance regulations or
 general  regulations requiring the use of reasonable precautions in abating
these emissions.  A few agencies, however, have used regulations, of more
effective types.  These require the use of proper operating procedures,
                                    11

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control devices or other prescriptive measures.  Both the general and the
specific regulations depend upon the existence of reasonably available con-
trol technology to be effective.
     Other traditional sources such as fuel combustion for power generation
and smaller boilers are generally within existing emission limits for par-
ti cul ate matter; however, some tightening of these limitations could be
applied in selected areas.  For example, small boilers and furnaces burning
fuel oil can improve combustion with good maintenance, and new or replace-
ment units can be designed more efficiently.
     Reasonably available control technology (RACT) may be required for
selected industries and in those areas where traditional source emissions
are a particular problem.
Control Strategy Alternatives:  Nontraditional Sources — Fugitive dust is
the term generally used to describe windblown  dust or nonindustrial dust
generated by human activity, e.g., dust from construction, unpaved roads, and
parking, and resuspended dust from paved roads.  Construction dust may be
partially controlled by minimizing the acreage disturbed and watering the
site.  Watering can also reduce the dust from  demolition areas.  Unpaved
roads  can be paved in inhabited areas with  high traffic densities.  Heavily
used parking areas can be paved, or treated to suppress dust.  Control of
spillage and carryout from muddy, unpaved  surfaces can reduce the amount of
dust on paved  roads, and cleaning by vacuuming may be justified  in extreme
cases.
     Secondary particulates are formed by  the  reaction of gases  in the
atmosphere.  Sulfates, nitrates, ammonium  salts and  organics are commonly
found  secondary particles.  Sulfate, the most  commonly found secondary
particulate, is formed by the atmospheric  oxidation  of S02.  Current  policy
calls  for continuation of existing regulations in  high S0? areas to prevent
                                    c                    t-
increased health  risk from sulfates.   Control strategies for secondary
particulates are  presently being investigated; final  action must wait until
health risks can  be determined.                                        ;
     Total  automotive particulates are reduced significantly by  the  low-
lead and no-lead  gasolines and  will be increasingly  reduced as the per-
centage of  cars which rely on these blends of  gasoline  increases.

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      Other source categories  which will  probably receive less  direct
 regulation are rubber tire fragments,  agricultural  tilling,  and windblown
 dust.
 Sulfur Dioxide (SO,,)
      Non-attainment of NAAQS  for S02 at  this  point  is  considered to  result
 primarily  from delayed implementation  of existing regulations  for emissions
 from power plants and non-ferrous smelters.   The keys  to maintenance of  the
 standards  are  regarded to  be  new source  review,  enforcement  of non-
 significant deterioration  regulations, and optimum  implementation of the
 provisions of  the Energy Supply  and Environmental Conservation Act.   There-
 fore,  relatively  few  SIP revisions  are expected  to  be  necessary for  this
 pollutant.
 Carbon  Monoxide and Oxidants  (CO and 0 )
                                      X
     Oxidant and  carbon monoxide concentrations  are expected to improve
 somewhat in most  areas of  the country as  controlled automobiles  replace
 older,  uncontrolled vehicles.  Even with  substantial improvement  in  air
 quality for oxidants  and carbon  monoxide, however, a large number of AQCRs
 are  expected to experience violations of  the  ambient standards  during the
 next 10 years.  At  least 63 urban areas will  require transportation  control
 measures in order to  attain standards by  1985.   Twenty-nine of  those areas
 currently  are  required to  implement transportation control measures, while
 transportation control measures  are in some stage of development  for nine
 additional  areas  and  are likely  to be required for the remaining  25 areas7
 (see Chapter III).
     Table  II-l presents a list  of reasonably available categories of CO
 and  hydrocarbon control measures,  which are described in more detail in
Chapter III.  The emission reduction potential of each measure varies among
areas,  depending on available technology and the relative contributions of
stationary  and mobile sources.   Feasibility is generally defined  in terms of
cost-effectiveness and ease of implementation (i.e., political, administra-
tive, and technological viability).  The feasibility also varies among
areas -- particularly regarding the transportation measures.   It is impor-
tant to note that the Department of Transportation (DOT) is now requiring
                                   13

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Metropolitan Planning Organizations (MPOs) to develop and implement an
annual Transportation Systems Management (TSM) Plan (see Chapter III) which
should consider the transportation measures listed in Table II-l.   Every
strategy in this table is considered reasonably available and should be ;
included in SIP revisions where necessary for attainment.  However, the most
cost-effective mix of measures must be locally determined.
          Table II-l.  REASONABLY AVAILABLE CO AND HYDROCARBON
                                  CONTROL MEASURES8
       Source control measures
     Transportation measures
1.  Inspection/maintenance
2.  Vapor controls for organic
    solvents
3.  Petroleum refinery, chemical
    plant and other industry controls
4.  Vapor controls for gasoline
    marketing
5.  Heavy duty vehicle retrofits
1.  Transit improvements
2.  Employer incentives

3.  Parking management/restrictions

4.  Traffic management/restraint
     The process for identifying needed SIP revisions in non-attainment
areas is the same for areas with an existing CO/0  SIP as for areas without
                                                 A
such a plan.  Generally, the schedule will require states to submit by  ;
June 30, 1977, reasonably available measures needed to meet the NAAQS.  If
necessary, states will be allowed until June 30, 1978, to submit certain
measures that require longer development and implementation times.  This
special category of reasonably available measures generally includes land
use and transportation control measures that often require longer lead
times to obtain regulatory authority and funding.
     Therefore, during the next several months EPA Regional Offices will
concentrate first on validating and documenting the data base which demon-
strates the need for CO/0  SIP revisions.  Where pervasive oxidant problems
                         A
exist, states may elect to work jointly in developing uniform control
                                   14

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 strategies over a broad multi-station  region.   Where  resources  permit,  the
 regions  are also encouraged to develop draft strategies  jointly with  the
 local  transportation  agencies  responsible for  planning  implementation.  EPA
 is  preparing guidance material  to  assist  states in  formulating  SIP  revisions
 for oxidants.9'10'11
 Nitrogen Dioxide
     On  a national  basis,  the  NCL  problem is much less severe and pervasive
 than the TSP or QX  problems.   Valid  data  indicate that only  a few areas of
 the country have ambient N02 concentrations  in  excess of the NAAQS  for  NCL.
 The typical  N02 problem, where  it  does  exist,  is in an urban area where
 observed N02 concentrations are either slightly above or below  the  NAAQS.
 Such conditions generally  represent  a  potential  problem  for  maintenance
 rather than  for attainment of  the  NAAQS.   Further,  it is now believed that
 continued growth of nitrogen oxide (NO  )  emissions  from  mobile  and  station-
                                       X
 ary sources  in  a number of cases will make it impossible to  maintain
 national  standards, even if they are not  presently exceeded, without
 additional  emission control measures.
     On  a national  basis,  stationary sources and mobile  sources  currently
 contribute 60 percent and  40 percent of the  NO  emissions, respectively.
                                              A
 In  both  emission  categories, the vast majority  of NO  emissions  is  produced
 by  fuel  combustion  (fossil fuel-fired power  plants, industrial  boilers,
 commercial/residential  space heating units,  gasoline-powered automobiles,
 diesel-powered  trucks,  aircraft, etc.).
     Stationary  source  control  measures will  become increasingly important
 as  additional mobile source control regulations are implemented.  Future
 violations of the N02 standard are predicted to occur in some areas  regard-
 less of whether more restictive automotive NO  emission  limitations  are
                                             A
 adopted because  of growth of stationary source emissions.  Control  measures
 are  reasonably available and will  be required (as needed) for utility-type
 boilers.   Additional control measures will be required if necessary;
however,  NO  control techniques are not reasonably available for all source
                                    12
categories.  EPA is writing a manual    on  preparing  SIP revisions for NOp,
and it will contain an assessment  of the methods available  for  controlling
existing  sources.
                                  15

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      Difficulties  with  ambient  N02 monitoring  techniques have been resolved,

 and  the  continuous chemiluminescent measurement principle and associated
 calibration  procedure have  been proposed  as  the new  Federal  Reference

 Method.13

 REFERENCES

 1.   State  Air Pollution Implementation  Plan  Progress Report. January
     1  to June 30,  1975, U.S.  Environmental Protection Agency,
     EPA-450/2-75-008, September 1975.

 2.   Guidelines for Determining  the Need for  Plan  Revisions  to the
     Control  Strategy of the Approved  SIP.  OAQPS Guideline No. 1.2-011,
     November 1975.

 3.   National  Assessment of  Particulate  Problem, study in progress  for
     EPA  by GCA Technology Division.Estimated completion date  April  1976.

 4.   Guideline Development for Reasonable  Control  of  Fugitive Dust, study
     in progress for EPA by  TRW, Inc.   Estimated completion  date July  1976.

 5.   Southwest Pennsylvania  Particulate  Study,  study  in  progress for EPA
     by H.  E.  Cramer.Estimated completion date January 1977.

 6.   Position Paper on  Regulation of Atmospheric Sulfates, U.S.  Environ-
     mental Protection Agency, EPA-450/2-75-007, September 1975.

 7.   Transportation Controls. Part III:   "Air Quality Data," paper  prepared
     by EPA's Office of  Transportation and Land Use Policy for the  Senate
     Committee on Public Works,  January  16, 1976.

 8.   "Policies for the  Inclusion of Carbon Monoxide and  Oxidant  Controls in
     State  Implementation Plans  (TCP  Policy Paper),"  EPA position paper
     prepared by the Office  of Transportation and  Land Use Policy,
     December 1975.

 9.   0 Control Strategy Manual. scheduled for distribution  to Regional
     Uffices, May 19767

10.   "Guidelines for Control of Volatile Organic  Emissions from  Existing
     Stationary Sources," draft scheduled for distribution to Regional
     Offices in April 1976.

11.   "Policy Statement on Use of the  Concept  of Photochemical Reactivity
     of Organic Compounds in SIPs for Oxidant Control,"  distributed
     to Regional Offices January 29,  1976.
12.
NO  Control Strategy Manual, scheduled for distribution to Regional
Wfices May 19/b.
13.  Federal Register. Vol. 41, p. 11252, March 17, 1976.
                                    16

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     III.  OVERVIEW OF CARBON MONOXIDE/OXIDANT CONTROL STRATEGIES

BACKGROUND
     EPA's primary methods of dealing with carbon monoxide and oxidants
(and oxidants1 precursor, hydrocarbons) can be divided into two categories:
stationary source control and transportation control measures.  The primary
emphasis of this chapter will be on transportation control measures.
     Programs for the control of transportation-related air pollution have
had a number of problems from the start—problems which new policies and
proposed amendments to the Clean Air Act will attempt to resolve.  First,
information on the effectiveness, cost, and implementability of transporta-
tion options in 1973 was limited.  The extremely tight court-imposed time
constraints did not allow for the investigation of social and economic
effects on a case-by-case basis.  In addition, experience was lacking at all
levels of government to plan and implement effective measures.  Due to the
time restrictions, many of the transportation control requirements could not
be adapted to the existing institutional framework, to ongoing planning
schedules and processes, and to agency budget cycles.  The 1977 deadline for
achieving health-related national ambient air quality standards also did not
allow credit for long-range measures such as mass transit improvements.
Consequently, the alternatives considered and the effects analyzed were both
limited, and governmental and citizen interaction was insufficient.
     .Litigation has hampered implementation of transportation control
measures.  When required by court decision to develop transportation plans
for many states in 1973, EPA realized that it would be undesirable (and
impractical) to promulgate local transportation control  measures which
would be administered at the Federal level.  EPA thus promulgated implemen-
tation plan regulations requiring state and local agencies to abate
transportation-related pollution.
                                  17

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      Several  states tested the legality of this  approach in the Federal
 Courts.   In 1974, the First and Third Circuit Courts  of Appeal  generally
 supported EPA's promulgations.    In 1975,  however,  three Courts rejected
                                         p
 EPA's promulgations in whole or in part.
      The Fourth and Ninth  Circuits basically ruled  that the Act does  not
 allow EPA to  promulgate regulations which  would  impose  civil  or criminal
 sanctions on  a state or its officials for  failure to  administer EPA-
 promulgated regulations or to provide legislation in  accordance with  those
 regulations.   While these  Courts  technically based  their decisions  on inter-
 pretations  of the Clean Air Act,  they left little doubt that  they would
 view  the Act  as unconstitutional  if it did authorize  EPA to require states
 to  control  such air pollution.   Neither decision suggested  that EPA could
 not directly  control  the polluting activities  or that the states could not
 if  they  chose to do so.
      The decision of the D.C. Circuit took a middle ground  between  the
 Third Circuit on one hand  and the  Fourth and Ninth  Circuits on  the  other
 hand.  The  D.C.  Circuit decision  considered  both the  statutory  and  constitu-
 tional issues  and held  that EPA could require  states  to  conduct certain
 activities  (such as  bus  lanes) because  in  these areas the state was
 effectively the  owner or manager of a pollution source,  e.g., highways.
 But the  Court  said  EPA  could not require states to  pass  legislation neces-
 sary  to  implement programs  regulating private  pollution  sources (e.g.,
 inspection or  retrofit  of  individual  autos).   States  could, however, be
 required  to comply with  rules regulating commerce (e.g., auto registration),
which would result  in helping to enforce EPA regulations.
      Because of  the  conflicting decisions  on this issue, the Justice
Department has asked  for Supreme Court review.  A decision on the cases
appealed will  probably take many months.3
      Prior to the recent judicial decisions concerning EPA's enforcement
authority, EPA had issued notices of  violation under section 113 of the
Act to several state and local governments, particularly for the failure
to  implement periodic emission inspection programs  for in-use vehicles.
Since the judicial decisions have been'rendered,  EPA has not pursued any
of these enforcement actions, although it is not  precluded from doing  so
                                   18

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in several of the affected areas.  Because of these decisions, EPA finds

itself in the situation where the areas most heavily affected by mobile

source-related pollutants have plans on the books to reduce their pollution

problems, but EPA is unable to effectively require these areas to imple-

ment the necessary control measures.

     In all, 29 general areas now require the use of some type of trans-
                          A
portation control measure.
       1.  Boston, Mass.
       2.  Springfield, Mass.
       3.  New York, N.Y.
       4.  Rochester, N.Y.
       5.  Northern New Jersey
             (Newark, N.J.)
       6.  Southern New Jersey
             (Camden-Trenton)
       7.  Philadelphia
       8.  Pittsburgh
       9.  Baltimore
      10.  Washington, D.C.
      11.  Cincinnati
      12.  Indianapolis
      13.  Chicago
      14.  Minneapolis
                                           15.  San Antonio
                                           16.  Houston-Galveston
                                           17.  Dallas-Ft. Worth
                                           18.  Denver, Colorado
                                           19.  Salt Lake City, Utah
                                           20.  Phoenix-Tucson
                                           21.  Fresno
                                           22.  San Francisco
                                           23.  San Diego
                                           24.  Los Angeles
                                           25.  Sacramento
                                           26.  Seattle
                                           27.  Spokane
                                           28.  Fairbanks
                                           29.  Portland
     In addition, the following cities are in some stage of development
of transportation control strategies:
                                            6.  Beaumont, Texas
                                            7.  Corpus Christij, Texas
                                            8.  Albuquerque, N.M.
                                            9.  Las Vegas, Nev.
       1.  Hartford, Conn.
       2.  Providence, R.I.
       3.  New Haven, Conn.
       4.  St. Louis, Mo.
       5.  Tampa, Fla.


REASONABLY AVAILABLE CONTROL MEASURES5

     No entire CO/0  control strategy has been implemented to date, but
                   A
progress has been made in implementing individual control measures.  Several

of these measures, which have been categorized as "reasonably available"

(see Chapter II), are discussed in the following sections.  These measures

include both transportation control measures, such as inspection/maintenance,

transit improvements, employer incentives, traffic management/restraint, and

parking management/restrictions, and stationary source control measures such
as vapor controls for gasoline marketing.
                                  19

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 Inspection/Maintenance
      Motor vehicle inspection and maintenance (I/M)  is a program of periodic
 inspection of vehicles to determine the levels of emissions from the
 vehicles.   I/M is part of the transportation control  strategies  in 27 areas,
 which contain over 30 percent of the nation's automobiles.   Six  areas are
 currently  operating I/M programs:  New Jersey; Chicago;  Cincinnati;
 Portland,  Oregon; Riverside,  California;  and Phoenix-Tucson,  Arizona.
      Under I/M, vehicles found to emit excessive  amounts of pollutants  are
 either required or requested  to be repaired and reinspected.   (Three of the
 six I/M programs currently in operation call  only for voluntary  maintenance.)
 Two types  of inspection tests are used.   An idle  test measures tailpipe
 emissions  by an exhaust gas analyzer while  the vehicle is in  neutral.   In
 the more accurate and more costly loaded  test, the vehicle  is run  under
 simulated  driving conditions  on a dynamometer.
      Air quality improvements from I/M are  difficult  to  quantify,  but some
 emission reduction  figures are  available.   Depending  upon the mix  of
 stationary and  mobile sources in  an  area, it  is estimated that I/M programs
 can obtain 2  to 6 percent  of  needed  reductions  in hydrocarbon emissions and
 5 to 10  percent of  the  needed carbon  monoxide  reductions.6
 Transit  Improvement
      Transit  improvement measures  refer to  any  upgrading of transit  services
 intended to attract additional  ridership.    These measures will, in most
 cases, have an  impact on air  quality.  To attract new  riders, a transit
 system must have  sufficient vehicles  to carry  the new  riders, provide
 service of a quality  comparable to automobiles, and be provided at an
 attractive cost.
     There are  three main  types of transit  improvement measures:
      1.  Fare reduction — Transit has always suffered a significant cost
disadvantage because of the underpricing of automobile use.   This can be
adjusted by reducing fares or increasing the cost  of automobile use.   A
fare reduction from 40 cents to 15 cents in  Atlanta brought  about a 28
percent increase in ridership.  This type  of fare  decrease generally
increases ridership at off-peak times.
                                   20

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     2.  Fleet expansion -- Increases in the number of transit vehicles can
promote ridership increases by allowing for more frequent service on exist-
ing lines and enabling the development of new lines and new types of transit
service.  The Metropolitan Transportation Commission in Minneapolis nearly
tripled its bus fleet between 1970 and 1976, with a resulting ridership
increase from 45,000,000 to 63,000,000.  Service expansion may also include
the use of smaller transit vehicles designed to fill the gap between con-
ventional transit and the private automobile, e.g., demand-responsive
transit.
     3.  Passenger amenities -- Shelters, vehicle design, better schedule
information, and terminal facilities are aspects of transit service that
are most visible to the public.  The potential passenger's attitude toward
transit service, based in large part on these amenities, will influence
his decision between transit and the automobile.
Employer Incentives
     An employer incentive program is one in which employers develop pro-
grams to encourage their employees to participate in carpools, vanpools,
mass transit, etc.  In several areas, such as northern New Jersey and
Boston, employer incentive programs were promulgated as part of trans-
portation control plans.  Generally, they require assistance from the
employers in carrying out pooling programs.
     An effective carpool program can potentially reduce automobile emis-
sions by 5 to 10 percent.  Individuals can save from $200 to $350 per
year in operating costs by participating in a pool and another $500 per
year in ownership expenses if a car can be eliminated.  Vanpooling
programs have similar benefits.  For example, an eight-member vanpool in
which all of the members previously drove 30 miles to work would reduce
vehicle miles of travel by 82,000 per year and save 6,000 gallons of
gasoline per year.  The 3M Company of St. Paul has the most extensive van-
pool program in the country—over 75 12-passenger vans.  A $1 fare per day
per rider covers the full fixed and operating costs.  At the 3M Company,
calculations based on in-use operation of 57 vans showed that these vans
saved over 340 parking spaces, 1.4 million vehicle miles of travel, and
108,000 gallons  of gasoline  each year.   In  addition,  the  company  has  been
able to save close to  $3 million  by eliminating  the  need  for  a  new
parking garage.
                                  21

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Traffic Management/Restraint
     Several traffic management and traffic restraint measures are
available:
     1.  Preferential treatment of high-occupancy vehicles -- EPA views
preferential treatment of buses and carpools as a critical incentive which
must be in use before selective automobile disincentives, such as parking
restrictions, can be considered.  Bus/carpool priorities have been provided
on freeways, urban arterials, and secondary city streets.  Freeway measures
include exclusive lanes (both grade-separated and reserved) and rarnps,
contraflow lanes, and right-of-way bypass privileges at ramps and toll
plazas.  Priority treatment on city streets includes bus-only streets, bus-
only lanes (both median and contraflow), contraflow lanes, and bus preemption
of traffic signals.  Bus priority treatment can attract a significant number
of auto travelers to transit during the peak period, thereby increasing bus
speeds and service reliability and decreasing congestion.
     Cities that have implemented priority bus/carpool measures on freeways
include Washington, D.C., Los Angeles, Seattle, Long Island, and San
Francisco/Oakland.  Preferential treatment for buses on city streets has
been initiated in Philadelphia, Minneapolis, Chicago, New Orleans, and
Washington, D.C., among others.
     2.  Road user charges — Tolls are being increasingly used to spread
out peak-hour traffic and selectively control traffic patterns.  This
trethod of controlling traffic patterns creates a pricing structure for the
use of the road, thereby creating an incentive/disincentive situation.   A
big advantage of road user charges is that the rate can be readily increased
or decreased depending upon the situation and the result desired.  A differ-
ential license road use charge has been used in Singapore with dramatic
decreases in vehicle miles traveled.
     3,  Traffic flow improvements -- Reductions in air pollution are avail-
able through optimizing traffic flow.  Improvements can be made in three
general ways:
     a.  Traffic surveillance and control use various techniques aimed
         at increasing the supply of usable roadway or controlling the
         demand for existing roadways.  This method might include,
                                    22

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         for example, planning, redesigning facilities, monitoring
         ramp usage, roadway surveillance and information communication
         ito individual vehicles.
     b.  Traffic simulation models are planning tools used to predict
         the consequences of various alterations in the pattern of traffic
         flow, either on the macroscopic or microscopic level.
     c.  The maximum use of existing street facilities can be achieved
         through the use of signalization, land use, and directional
         control and channelization of turning traffic.
     4.  Staggered work hours — Staggered work hours can help  reduce
peak loads on transit facilities and vehicle loads on streets and highways
by altering the working hours of employees.  By spreading out the peak
period, transit capacity can be increased.  This measure is primarily a
congestion control device and not a direct air pollution control  device.
However, peak hour pollution may be reduced by changing the emission  pat-
terns of mobile source pollution during these periods.
     The effect of any staggered work hour program on pollution reduction
depends on a variety of factors.  Major factors include the degree of
flexibility of the program, extent of mobile source pollution in  the  area,
and availability of alternative modes of transportation and nearby parking
facilities.  A staggered work hour program may have wide-ranging  effects
on various social institutions, and these impacts should be given full
consideration before any such program is implemented.
     The New York Port Authority directed a staggered work-hour project,
and surveys indicate that congestion decreased significantly in elevators,
transit facilities, and surrounding streets.
     5.  Auto-free zones -- Auto-free zones are geographic areas  which are
partially or fully restricted to vehicular traffic in order to  facilitate
pedestrian flow.  The basic types of zones can be defined as follows:
     Fully pedestrian:  All traffic is banned from the streets  at all
     times, the streets are repaved. to facilitate pedestrian flow, and
     various environmental  improvements are made.
     Partially pedestrian:   Similar to a fully pedestrian zone  except
     that limited vehicular traffic (delivery vehicles, public  transpor-
     tation) is allowed during restricted hours.
                                  23

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      Selected traffic bans:  Selected classes of vehicles  are banned and
      various environmental  improvements are made.
      Occasionally pedestrian:   Total  vehicular ban during  certain  specified
      occasions.
      Because of the nature  of-this air pollution control technique,  the
 various projects should be  instituted in stages to cause as  few disloca-
 tions as possible.   Since vehicular flow is prohibited in  given areas,
 suitable alternative traffic patterns must be established  to accommodate
 the dislocated traffic.
      The extent  of  the  benefits  conferred by this  type of  program  depends
 on  the amount of mobile  source  air pollution in the region,  geographical
 area of the  zones,  and  alternative modes of transportation provided.  CO
 levels and noise pollution  have  been  dramatically  reduced  in several  of
 the cities having auto-free zones.  Significant auto-free  zones  have  been
 created and  are  in  the  process  of  being constructed in major United States
 cities (Minneapolis,  Fresno and  Baltimore,  among others) and abroad
 (Copenhagen,  Cologne, Leeds  and  Montreal).
                                                     \
 Parking Management/Restri ctions
      Parking  control strategies  include  measures that  affect  both the avail-
 ability and the  cost of  parking.   These  strategies  include a wide range  of
 measures which can  be implemented  alone  or  in  combination with other park-
 ing,  transit, and carpool strategies.  Measures  designed to  influence the
 availability  of  parking  include  park-and-ride  lots  at  outlying transit
 stops,  on-street commuter parking  bans,  residential permit systems for
 neighborhoods greatly affected by  on-street  commuter parking, zoning law
 changes where excessive  amounts  of parking are  required with new building
 construction, and review of nev;  proposed parking facilities for air quality
 acceptability.
     Other parking measures  are  designed to directly affect the cost of
 parking and thereby influence the demand for parking.  These measures
 are generally more controversial and politically sensitive  than parking
 availability measures and include parking rate increases,  parking surcharges,
 changes in the parking rate  structure to eliminate the current advantages
given to long-term commuter  parking, and elimination of free or low-cost
employer-subsidized parking  for employees.
                                   24

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      These measures collectively are referred to as parking management.
 Parking management is a relatively new concept designed to partially
 redress traditional nolicies of nearly unrestrained support of the automo-
 bile by helping to achieve a better balance between automobile use on the
 one hand, and ouhlic transit, carpooling, bicycling and walking on the
 other.

 Gasoline V'apor Recovery
      Gasoline vapor control regulations require the control  of evaporative
 hydrocarbon emissions during the storage, transport and dispensing of
 gasoline.   Stage I regulations  require  control  during loading at the bulk
 terminal  and during delivery to the service station storage  tank.   Stage
 II  regulations require control  during the fueling of automobiles at the
 service station.
      Stage I equipment consists  primarily of hoses  and couplings to estab-
 lish  a  "closed loop"  between the delivery tanker  and the  underground storage
 tank.   Stage II  vapor recovery  involves two basic control  approaches.'
 Balance systems  create a  "closed loop"  by achieving a  tight  seal  between a
 gasket  on  the  dispensing  nozzle  and the neck of the vehicle  gasoline tank.
 Vapors  are forced  back to  the underground tank through  a  vapor  return  hose.
 Vacuum-assist  systems, which are more efficient than balance  systems,  use
 a slight vacuum to  capture  the vaoors.  They do not require a tight  seal,
 which is often difficult to achieve because  of the  variety of automobile
 designs.                                                              ,
     Controls  on gasoline marketing operations will capture about  11 pe!r-
 cent of the needed  HC  reductions in most  urban areas and may capture as
much as 20 percent.   In addition, millions of gallons of gasoline will be
saved that would otherwise  evaporate.                               <
     EPA regulations or local regulations require vapor control  in 13
metropolitan areas.  In addition to controlling emissions, these systems
will remove potentially explosive vapors and make service station areas
safer.

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RELATIONSHIP OF EPA's TRANSPORTATION CONTROL MEASURES TO THOSE OF OTHER
FEDERAL AGENCIES7
     In 1973 whej^i -transportation control strategies were first promulgated,
EPA was the only agency requiring such plans.  However, current Congres-
sional review of the Clean Air Act is focusing on closer coordination of
EPA's transportation control requirements with the legal requirements and
regulations of other Federal agencies.
Department of Transportation (DOT) Transportation Improvement Program
Regulation
     On September 17, 1975, DOT issued the Transportation Improvement
Program regulations which govern the planning and programming of all urban
transportation improvements administered by both the Federal Highway Admin-
                                                                         o
istration (FHWA) and the Urban Mass Transportation Administration (UMTA).
     From EPA's viewpoint the most significant aspect of the DOT regulation
is the requirement for the annual preparation of a Transportation System
Management (TSM) element.  The TSM plan is designed to meet short-term
transporation needs and thus emphasizes making efficient use of existing
facilities.  The emphasis on short-range measures is consistent with EPA's
need to achieve the air quality standards as expeditiously as possible.
TSM measures include:  traffic flow improvements, preferential transit
treatment, bike and pedestrian facilities, parking management, work
schedule changes ,_ pricing policies, carpooling programs, auto-free zones,
park-ride bus service, express bus service, etc.   The first plans are due
in March 1976.  In summary, TSM employs a variety of locally conceived
operating, regulatory and pricing policies to bring about a more rational
organization of the public transportation system and a better balanced
use of the private auto.
     The TSM plan is to be developed by the Metropolitan Planning Organi-
zation (MPO) in each urban area.   The MPO will provide a forum for coopera-
tive decision-making by principal elected officials of general -purpose
local government.
     Both UMTA and FHWA planning funds can be used for developing a TSM
plan.  Ttie assistance, however, is funded out of exisiting FHWA and UMTA
programs.   All UMTA and FHWA funding is conditional  on developing a TSM
                                   26

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 plan.   However,  only UMTA funding  will  be  conditional  on  reasonable
 implementation progress.
      DOT and  EPA are currently working  on  development  of  procedural  guide-
 lines  to coordinate,their transportation requirements.  Such  guidelines
 should result in products that better meet the  objectives  of  both  agencies.
 For  example,  DOT could  receive wider agency and citizen support  for TSM  plans
 if such  plans are based on a  process that  explicitly considers air quality
 objectives.   EPA's  regulatory authority and sanctions  could better ensure
 that TSM measures are programmed and implemented.   EPA would  receive trans-
 portation improvement plans that have been locally  generated  and adopted
 by the responsible  decisionmakers;  in many cases these measures  could
 replace  EPA .promulgations.  Parallel Federal  requirements  could  also be
 streamlined and  made more efficient, resulting  in one  integrated process
 and  product.  Ideally EPA and DOT  requirements  should  be merged.
 FHWA 109(j) Consistency Determination Requirement
     Section  109(j)  of  the 1970 Federal-/>1d Highway Act directed DOT to
 develop  and promulgate  guidelines  to ensure that highways  constructed with
 Federal  funds are consistent  with  the State Implementation Plan  for  achieving
 the  air  quality  standards.  The FHWA Regional Administrator,  after  consulta-
 tion with  the EPA Regional Administrator,  is  responsible for  making  the
 annual consistency determination.
     The  109(j)  consistency requirement serves  to formally coordinate on an
 annual basis  FHWA's  highway and EPA's transportation control  planning
 processes.  Consistency determinations  between  proposed highway  and  trans-
 portation  control plans are made for future years depending on the severity
 of the existing  and  future air pollution problem.  Hence, a mechanism is
 established that  exolicitly links highway  and air quality objectives.
 Energy Policy and Conservation Act  (Part C, Section 362, State Energy
 Conservation  Plans)
     This  legislation, signed by the President  in December 1975,  means that
many transportation control measures that  reduce total  vehicle miles
 traveled are now  required by the Federal Energy Administration to be  included
 in State Energy Conservation Plans if the states are to receive  Federal
                                    27

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energy planning assistance.  For example, those states choosing to develop
an energy plan are required to include programs to promote carpools, van-
pools, and public transportation.  Furthermore, these plans may include
transportation controls which are defined as "incentives, disincentives,
restrictions and requirements designed to reduce the amount of energy
consumed in transportation."
Clean Air Act Amendments
     In at least two instances Congress has passed legislation affecting
Federally promulgated transportation control measures.  In 1974 a new
section 110(c)(2) was added to the Act directing EPA to revoke parking
surcharge regulations, delay regulations for preconstruction review of park-
ing facilities, and conduct a study of other types of transportation control
regulations.  In both 1974 and 1975, EPA's appropriations act prohibited the
expenditure of funds during the applicable fiscal years for administering
programs to "tax, limit, or otherwise regulate parking."
     The Committees of the Congress are currently considering several amend-
ments to the Clean Air Act and are proceeding with an awareness of the
recent Circuit Court Decisions.  Partly as a result of these decisions, the
present Senate staff version contains funding provisions and utilizes
funding sanctions to ensure implementation of transportation measures.  The
current Act's method of requiring EPA to promulgate transportation measures
for local communities where the state has failed to do so is not likely to
be retained in the Clean Air Act Amendments.  Rather, decisions will be
left to the local communities with, hopefully, financial incentives/disincen-
tives to spur action.
     The amendment process has been slower than originally anticipated.  It
may well be mid-1976 or later before any law is enacted.  Whatever final
form the new amendments take, it is clear at least that transportation
controls are becoming an important part of air quality management programs
and vn'll have an even larger role as growth becomes a more-critical factor.
                                    28

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REFERENCES
1.

2.
4.

5.

6.



7.


8.
South Terminal Corp. v. EPA and Pennsylvania v. EPA.

Brown v. EPA, 9th Circuit; Maryland v. EPA, 4th Circuit; and D.C. v.
Train, D.C. Circuit.

Transportation Controls, Part I:  "History of Transportation Control
Plans,1' paper prepared by EPA's Office of Transportation and Land
Use Policy for the Senate Committee on Public Works, January 16, 1976,

Ibid., Part III:  "Air Quality Data."

Ibid., Part V:  "Introduction to Individual Control Measures."

A Review of Control  Strategies for In-Use Vehicles, prepared for EPA
under contract by the Environmental  Programs Group of the Aerospace
Corporation, EPA-460/3-74-021, December 1974.

Transportation Controls, Part VII:   "Relationship of Transportation
Control  Plans to Other Federal Programs."

Federal  Register. Vol.  40, p. 42976, September 17, 1975.
                                  29

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                           IV.  SIP PROGRESS

     The SIPs continue to be amended to correct deficiencies found by the
courts as well as to meet technical changes required by emerging issues.
No state plan is currently fully approved although the degree to which each
plan is disapproved varies from state to state.  The most significant
actions of the past 6 months are summarized below.
EPA-INITIATED ACTIONS
Air Quality Maintenance
     On October 20, 1975, EPA proposed regulations for the analysis and
development of plans for Air Quality Maintenance Areas (AQMAs).   These
regulations specify procedures to be used for estimating future air quality
concentrations and for developing new control strategies necessary to ensure
the maintenance of the National Ambient Air Quality Standards (NAAQS).  The
substantive measures needed for this purpose are to be chosen by each state
within the technical and procedural framework of these regulations.  Final
regulations are expected to be promulgated in May 1976.
Continuous Monitoring
     On October 6, 1975, EPA promulgated regulations for the continuous
                                                                 2
monitoring of emissions from four categories of existing sources.   States
must revise implementation plans by October 6, 1976, to include legally
enforceable procedures to assure continuous monitoring of certain large
fossil fuel-fired steam generators, fluid bed catalytic cracking unit
catalyst regenerators, sulfuric acid plants and nitric acid plants.
     All sources subject to these requirements shall have installed all the
necessary equipment and shall have begun monitoring and recording data
within 18 months of either approval of state plan monitoring requirements
for that source or EPA promulgation of such monitoring requirements.
                                   31

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 Non-Ferrous Smelters
      In October 1975, ERA proposed final  regulations for the Anaconda
 copper smelter in Montana  and for all  smelters in the Phoenix-Tucson AQCR
 in Arizona and in the Arizona portion of  the Arizona-New Mexico Southern
 Border AQCR.    Of the seven regulations proposed for copper smelters  in
 Arizona,  four allowed the facility subject to the regulation to attain
 ambient standards through the use of dispersion technology  (i.e.,  tall
 stacks and/or supplementary control  systems).   These dispersion techniques
 are allowed as a  temporary measure until  technology sufficient  to  attain
 the standards becomes available.   In November 1975, the  Agency  promulgated
 emission  limitations  for  the  Kennecott  copper smelter near  Magna,  Utah.5
 New Source Review
      EPA  promulgated  public comment  provisions  in  October 1975  for previ-
 ously published new source review regulations  concerning Arizona,  California,
 Indiana,  Michigan  and Nevada.6                                     '       :
 SOg  Control Strategy-Ohio
      EPA  proposed  a sulfur dioxide control strategy  for the  State  of Ohio
 in  November 1975.   Four public hearings have been  held, and the extensive
 comments  generated by  the  proposed regulations  are  now under review.
 Public Availability of Emission Data
      In November 1975, EPA  published final regulations correcting 24 state
 plans whose confidentiality clauses had not provided for free public access
 to source emission data which has been correlated with air quality data.8

STATE-INITIATED ACTIONS

     During this 6-month reporting period, a number of implementation  plan
actions have been initiated by the states, including the following:
     - EPA has approved Indirect Source Review submissions for New York,
       U.S. Virgin Islands, West Virginia  and Nevada (Clark  County).   New
       Hampshire has  a plan submitted and  under consideration for approval.
     - Oregon  has  gained EPA approval of a plan revision  correcting
       deficiencies in regulation  of public availability  of  emission data.
                                    32

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     - Montana submitted an EFA-approved S02 regulation  for a  smelting
       plant at East Helena.
     - Idaho received partial  approval  of S02 regulations  to control  a
       zinc/lead smelter complex near Kellogg.
     During the period July 1  to December 31, 1975,  34 state plan  proposals
and 26 approvals of state-initiated actions  were published in  the  Federal
Register.  Table IV-1 gives the status  of each state on  three  selected
portions of the SIPs.

REFERENCES
1.  Federal Register, Vol.  40, p. 49048, October 2,  1975.
2.  Ibid., p. 46240, October 6, 1975.
3.  Ibid., p. 48521, October 16, 1975.
4.  Ibid., p. 49362, October 22, 1975.
5.  Ibid., p. 54786, November 26, 1975.
6.  Ibid., p. 50267, October 29, 1975.
7.  Ibid., p. 52410, November 10, 1975.
8.  Ibid., p. 55326, November 28, 1975.
                                   33

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                Table IV-1.  STATUS OF SELECTED PORTIONS

                   OF THE STATE IMPLEMENTATION PLANS
  Region/state
New  source
  review
 Transportation
    measures
 Emission
limitations
Region I
  Connecticut
Approved
  Maine

  Massachusetts
Approved

Approved
  New Hampshire
Approved
 Measures are re-
 quired for Hartford
 New Haven-Spring-
 field AQCR and New
 York-New Jersey-
 Conn. AQCR

 None required

 Boston transpor-
 tation controls
 promulgated
 6/12/75
 None required
Approved
  Rhode Island


  Vermont
Approved


Approved
 Measures  required;
 hearing  11/75

 None  required
Approved

Promulgation for
SO? (12/75-
suifur content
of fuel),
Approved for
other pollu-
tants

Promulgation
for TSP
(11/75),
approved for
other pollu-
tants

Approved
Approved
Region II

  New Jersey
Approved
  New York
Approved
 9/15/75
 Measures  promul-
 gated  for Phil-
 adelphia  and  New
 York,  New Jersey
 and  Conn.  AQCRs
TCP measures needed
for New York-New
Jersey-Conn. AQCR,
Gennessee-Finger
Lakes AQCR, and
Central New York
AQCR
EPA promul-
gation (7/73)
for HC,
approved for
other pollu-
tants

Rulemaking
for S02 (6/75),
approved for
other pollu-
tants
                                  34

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           Table  IV-1  (continued).   STATUS .OF  SELECTED  PORTIONS

                   OF THE  STATE  IMPLEMENTATION  PLANS
  Region/state
 New source
   review
   Transportation
      measures
  Emission
 limitations
Region  II cont.
  Puerto Rico
Approved
 None  required
  U.S. Virgin
     Islands
Approved  for
all  except
public  com-
ment pro-
visions
(9/10/75)
 None  required
 Deficient in
 part for S00
 (9/75),     2
 approved for
 other pollu-
 tants

 Approved
Region III

  Delaware
  District of
   Columbia
  Maryland
Approved
Approved
Approved
None required
Measures promul-
gated for National
Capital AQCR
Measures promul-
gated for
Baltimore and
National Capital
AQCRs
Pennsylvania
Approved
Measures promul-
gated for Phil-
adelphia and
Southwest Pennsy-
lvania AQCRs
                                                         Approved
Approved
TSP limita-
tions proposed
(10/6/75); S02
regulation
amended to
delete reduc-
tion from 1.0
to 0.5% sulfur
fuel for all
AQCRs except
Baltimore where the
reduction is only
deferred until 7/1/76
(12/5/75); aooroved
for other pollutants


State
proposals for
TSP and S02;
approved for
other pollu-
tants
                                  35

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          Table IV-1  (continued).  STATUS OF SELECTED PORTIONS

                    OF THE STATE  IMPLEMENTATION PLANS
  Region/state
New source
  review
  Transportation
     measures
 Emission  ,
limitations
Region III cont.
  Virginia
  West Virginia
Approved
Approved
(11/10/75)
EPA promulgation
for National
Capital AQCR

None required
Approved
Approved
Region IV
  Alabama
  Florida
  Georgia
   Kentucky

   Mississippi

   North  Carolina
Approved
Approved
Approved
 Approved

 Approved

 Approved
None required
None required
None required
 None  required

 None  required

 None  required
Proposal for
S02 (9/75,1/76),
promulgations
for TSP (5/75,
8/75), proposal
for TSP (7/75),
approved for
other pollu-
tants

Promulgation
for S02 (10/75),
Approved for
other pollu-
tants

Promulgation
for TSP
(10/75), pro-
mulgation  for
N02  (5/75),
Approved for
all other
pollutants

Approved

Approved

Approved
                                   36

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Table IV-1  (continued).  STATUS OF SELECTED PORTIONS
          OF THE STATE  IMPLEMENTATION PLANS
Region/state
Region IV cont.
South Carolina
Tennessee
Region V
Illinois
Indiana
Michigan
Minnesota
Ohio
Wisconsin
Region VI
Arkansas
Louisiana
New source
review

Approved
Approved

Approved
EPA promul-
gations
(5/73 & 2/74)
EPA promul-
gation (10/72]
Approved
EPA promul-
gation (4/74)
Approved

Approved
Approved
Transportation
measures

None required
None required

Measures promul-
gated for Chicago
AQCR
EPA promulgation
(4/74) for
Indianapolis AQCR
None required
Measures for
Minneapolis-
St. Paul AQCR
Measures promul-
gated for
Cincinnati AQCR
None required

None required
None required
Emission
limitations

Approved
Approved

CO strategy
disapproved
6/73; approved
for other
pollutants
Approved
Approved
Approved
HC strategy
disapproved,
S02 strategy
proposed
(11/75),
approved for
other pollu-
tants
Approved

Approved
Approved
                         37

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Table IV-1  (continued).  STATUS OF SELECTED PORTIONS
          OF THE STATE  IMPLEMENTATION PLANS

Region/state
Region VI cont.
New Mexico





Oklahoma
Texas





Region VII
Iowa
Kansas
Missouri
Nebraska
Region VIII
Colorado

Montana



North Dakota
New source
review

Approved





Approved
Approved






Approved
Approved
Approved
Approved

Approved

Approved



Approved
Transportation
measures

None required





None required
Measures being
prepared for
Austin-Waco,
Corpus Christi,
Houston-
Gal veston,
Dallas, San
Antonio, El Paso

None required
None required
Measures submitted
for St. Louis AQCR
None required

Measures promul-
gated for Denver
AQCR
None required



None required
Emission
limitations

Revocation
of EPA promul-
gation for SO,
proposed 11/75,
approved for
other pollu-
tants
Approved
EPA promul-
gations for
HC (11/73);
approved for
other pollu-
tants



Approved
Approved
Approved
Approved

Approved

Proposal for
S02 (10/75),
approved for
other pollu-
tants
Approved
                         38

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Table IV-1  (continued).  STATUS OF SELECTED PORTIONS
          OF THE STATE IMPLEMENTATION PLANS
Region/state
Region VIII cont.
South Dakota
Utah








Wyoming
Region IX
American Samoa
Arizona





California






Guam
Hawaii
New source
review

Approved
Disapproved
for TSP in
Wasatch
Front AQCR,
other sec-
tions
approved



Approved

Approved
Approved,
except for
Pima County



EPA promul-
gation (4/73)
for part of
state



Approved
Approved
Transportation
measures

None required
EPA promulgation
for Wasatch Front
AQCR (11/73)






None required

None required
Measures in effect
for Phoenix-
Tucson AQCR



Measures promul-
gated for San
Francisco, Los
Angeles, San
Diego, Fresno,
and Sacramento
AQCRs
None required
None required
Emission
limitations

Approved
EPA promul-
gations for
S09 and TSP
(10/74 and
9/74), TSP pro-
mulgation
(smelter) 11/75,
approved for
other pollu-
tants
Approved

Approved
EPA promul-
gations for
S0? (3/73 and
3/74), TSP (5/73).,
proposal for S02
from smelters (10/75),
approved for other
EPA proposals
for TSP and
promulgation
for HC,
approved for
other pollu-
tants
Approved
Approved
                       39

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          Table  IV-1 (continued).  STATUS OF SELECTED PORTIONS

                   OF THE STATE IMPLEMENTATION PLANS
  Region/state
New source
  review
  Transportation
     measures
 Emission
limitations
Region IX cont.

  Nevada
EPA promul-
gation (4/73)
for Washoe
County
None required
EPA promul-
gation for
S02 (2/75),
disapproved
for TSP (no
promulgation
to date),
approved for
other pollu-
tants
Region X
  Alaska
   Idaho
   Oregon

   Washington
Approved
Approved
 Approved

 Approved
EPA promulgation
for Northern
Alaska AQCR
 None  required
 None required

 Promulgations
 for Seattle
 and Spokane
 AQCRs
Revisions
needed for
CO, approved
for other
pollutants

Promulgation
for S02  (11/75),
approved for
other pollu-
tants

Approved

Approved
                                    40

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                    V.  AIR QUALITY AND EMISSION DATA

      EPA bases its assessments of national air quality to a major extent
 on the data collected by air monitoring networks operated by state and
 local agencies.  Before the formal status of compliance with a standard
 can be determined for an Air Quality Control  Region (AQCR), a reasonable
 history of data (at least one year) must be compiled from a representative
 network of monitors.   A single station reporting a second high value over
 the short-term standard is sufficient to document a violation of that
 standard;  similarly,  a single station reporting an annual  average of values
 that exceeds  the  annual  standard is enough to document a violation of that
 standard.   Compliance must usually be demonstrated by  more extensive
 evidence from a multi-station network.   The target date for completing these
 networks was,  in  most cases,  July  1974.   Table  V-l  summarizes  the progress
 made by the states  through  1974  in completing the  networks  proposed  in their
 SIPs.  The  number of  AQCRs  reporting  second high values  that  violate  the
 standards is  summarized  in  Table V-2.   (This  number of AQCRs  reporting
 violations  is  different  from  the number of AQCRs listed  in  the previous
 report  as  being  unlikely to  attain standards by the statutory date because
 that assessment was based on  a number of factors, only one  of which was air
 quality data.)

AMBIENT AIR QUALITY DATA
     The status of air quality in the United States in 1974 was in many
respects similar to that reported for 1973.  Approximately the same percent-
age of reporting stations are still exceeding air quality standards, with
one exception:  an apparent decline in the proportion of stations exceeding
the 8-hour carbon  monoxide standard.
                                   41

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         Table V-l.   NATIONAL SUMMARY OF AIR MONITORING
          STATIONS  REPORTING 1974 DATA TO THE NATIONAL
             AEROMETRIC DATA BANK BY SEPTEMBER 1975
Air monitoring stations
No. proposed for 1974a
No. reporting minimum data
No. reporting valid annual data
TSP
3,510
3,788
2,004
so2
2,132
2,241
1,030
CO
457
377
-
°x
458
343
-
aNumber of stations proposed by states in their SIPs to be operating
   in 1974.

bAt least three 24-hour values for intermittent monitors or 400
   hourly values for continuous monitors.

cFour consecutive quarters (a calendar year) of statistically valid
   data.  There are no annual standards for CO and QX, so no annual
   averages are calculated.
                               42

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        	  /-2.   NATIONAL  SUMMARY  OF AQCRs  REPORTING VIOLATIONS
        OF NAAQS  TO  THE  NATIONAL AEROMETRIC  DATA BANK FOR 1974
Air Quality Control
Regions (AQCRs)3
No. reporting minimal datab
No. exceeding 24-hour primary
standard
No. exceeding annual primary
standard
No. exceeding 1-hour standard0
No. exceeding 8-hour standard0
TSP
236
99
111
--
—
so2
210
22
11
—
—
CO
92


13
58
0
86


76
—
aTotal number of AQCRs =247.

 At least three 24-hour values for intermittent monitors  or 400
   values for continuous monitors.

 An AQCR must have all reported stations  showing no  violations to  be
   conS1dered an "attainment AQCR."   If a single station  in an AQCR

   AQcT"S a  Vlolat1on'  the  ent1re AQCR 1s considered a "non-attainment
                                43

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     All 247 AQCRs are required to be reporting at least one monitoring
station for total suspended participate (JSP).  Of these, 198 AQCRs had at
least one sampler station reporting enough data to compute a yearly average
(four consecutive quarters of statistically valid data) for the primary
annual TSP standard.  Of the 2004 monitoring stations reporting a valid
year's data, 1537 (77 percent) reported values achieving the annual stand-
ard.  The 460 stations that had readings exceeding the standard were located
in 111 of the 198 AQCRs reporting data sufficient to compute a yearly
average.
     All but 11 AQCRs reported minimal  data for the primary 24-hour TSP
standard.  Of the 3788 monitoring stations in these 236 AQCRs, 3462 (90
percent) reported values achieving the standard.  The 326 stations that had
readings exceeding the standard were located in 99 of the 236 AQCRs sub-
mitting minimal data.
     As with particulates, all 247 AQCRs are required to be operating at
least one sulfur dioxide (S02) monitoring station.  Of these, 155 AQCRs
reported a valid year's data for at least one station.  Of the 1030 monitor-
ing stations reporting a valid year's data, 999 (97 percent) reported values
achieving the primary annual S02 standard.  The 31 stations that reported
values exceeding the standard were located in 11 of the 155 AQCRs submitting
data sufficient to compute a yearly average.
     All but 37 AQCRs reported minimal data for the primary 24-hour S02
standard.  Of the 2241 reporting stations in these 210 AQCRs, 2142 (over
95 percent) reported values achieving the standard.  The 99 stations that
had readings exceeding the standard were located in 22 of the 210 AQCRs
submitting data.
     Carbon monoxide (CO) data were reported from 377 stations in 92 AQCRs
(30 AQCRs are required to have CO monitors).  The 1-hour CO standard was
achieved by 350 stations (93 percent) in 13 AQCRs; the 8-hour CO standard
was achieved by 166 stations (44 percent in 58 AQCRs.
     Oxidant/ozone  (0 /Oz) data were reported from 343 stations in 86 AQCRs
                     X
(55 AQCRs are required to have C^/Oz monitors).  The 1-hour standard was
achieved by 70 of those stations (20 percent) representing 76 AQCRs.
 Minimal data are defined for all pollutants as at least three 24-hour
 samples from a  hi-vol or a bubbler; or 400 hourly values from a continuous
 monitor.

                                   44

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     Nitrogen dioxide  (NCL) measurement methods have been reviewed and
the continuous chemiluminescent measurement principle has been proposed as
the Federal reference method.  Valid annual data for N00 were reported from
        •  '    •- •	    •     '•  .      '     •;<•'>*•',..£.••       r • :   •   :  .-.
582 stations using methods that are deemed candidates for the status of
reference or equivalent methods.  These 582 stations are located in 101
AQCRs.  Only 18 stations in four AQCRs exceeded the annual standard for N02.

TRENDS IN AIR QUALITY, 1970-1974
     Historical trends in air quality levels suggest the rate and extent
of progress in the control of air pollution.  For some pollutants, lack of
historical data on a national basis limits the inferences that may be made.
However, the recent expansion of air pollution monitoring networks is
providing data that will serve as a baseline for future trend assessment.
Currently, a sufficient historical data base on the national level is avail-
able for total suspended parti oil ate and sulfur dioxide primarily in
urbanized areas.  For oxidants, carbon monoxide, and nitrogen dioxide, his-
torical data are limited and the geographical distribution is very sparse.
Therefore, trends for these three pollutants are considered as a series of
special cases.  The present status of historical air quality data reflects
the evolution of air pollution monitoring efforts, which initially were
concentrated on the assessment of total suspended particulate and sulfur
dioxide in center city areas
     Based on composite averages from 1096 sites, TSP levels have decreased
from 1970 to 1974.   During this period, the composite annual average
                           2
declined from 80 to 66 yg/m .  This is an overall decrease of 17 percent, or
slightly less than 5 percent per year.  This improvement was generally
reflected throughout the nation but specific localities are still  experi-
encing TSP levels in excess of the National Ambient Air Quality Standards.
The principal control  problems are fugitive emissions and urban background
(secondary particulates, fugitive dust, and transportation-related emis-
sions).  During this period, the estimated reduction.in particulate
emissions was 29 percent.
     Sulfur dioxide levels have declined from an annual  composite  average
of 38 yg/m3 in 1970 to 26  yg/m3 in 1974.   These averages are based on  data
from 258 sites and represent an overall  decrease of 32 percent,  or
                                  45

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approximately 9 percent per year.  However, over 90 percent of these sites
are located in urbanized areas and caution must be used in generalizing
these results.  During this period, the decrease in estimated emissions was
8 percent.  The much greater reduction in ambient S02 levels may reflect the
shift in S02 emissions away from center city areas.  Thus, the overall
decline in SCL levels may be the combined result of emission reductions and
redistribution of emission patterns.  The principal remaining control
problems are major sources such as power plants and smelters.  Data for 1975
are expected to show some additional decline in S02 in response to the
mid-1975 compliance deadline.
     Carbon monoxide trends in the few cities having historical data suggest
general improvement.  This is consistent with the automobile emission
reductions during the same period.  Data from the States of California, New
Jersey, New York, and Washington show reductions in the percent of time the
8-hour CO standard is exceeded.  The peak hourly values have been relatively
stable, but in the majority of urban areas the 8-hour standard is the more
serious problem and this is where improvement is being shown.  Los Angeles
and New Jersey monitoring data indicate that the percent of time the 8-hour
CO standard was exceeded was reduced by approximately 50 percent from
1970-1971 to 1973-1974 (roughly 12 percent to 6 percent).  The State of
Washington showed consistent progress during the 1971-1973 period, and  New
York State and San Francisco data showed that less than 0.5 percent of the
8-hour values were above the standard.  On a national basis, the number of
CO monitoring sites increased consistently during 1970-1974 from 73 to  377,
more than a 500 percent increase.  The increase from 1973 to 1974 was 25
percent (299 to 377 sites).
     Oxidant trends in California continue to show long-term improvement.
Data in the Los Angeles and San Francisco areas show 20 to 50 percent
decreases in the number of times the 1-hour oxidant standard was exceeded.
However, an important characteristic of the oxidant problem is the recog-
nition of the wide spatial distribution of high oxidant levels.  Recent
studies have focused attention on oxidants as an area-wide phenomenon
extending even to rural areas.  The number of oxidant or ozone monitors
has increased nationally by more than 600 percent between 1970 and 1974
(51 to 343), with a 30 percent increase in 1974 over 1973 (265 to 343).
                                   46

-------
As these sites continue to report data, it will become possible to examine
oxidant trends on a much broader geographical basis.
     Measurements of oxidants at rural stations from Ohio into Maryland and
Pennsylvania through the summer of 1974 have confirmed earlier reports of
high oxidant concentrations remote from urban areas.  The history of air
masses, plus the presence of distinctive man-made pollutants in the air
masses, strongly suggests that the observed oxidant concentrations are the
product of man-made emissions received by the air masses in passing over an
urban area.  These ingredients continue to react, forming photochemical
oxidants, as the air masses move across the countryside.
     Nitrogen oxide emissions have increased nationally since 1970 and
upward trends in MOp have been seen in Los Angeles and Philadelphia.
Because of recent changes in measurement methodology for monitoring nitro-
gen dioxide, very few areas have sufficient historical data to assess NO^
trends during the 1970-1974 period.  However, between 1973 and 1974, the
number of stations reporting a complete year of acceptable fK^ data
increased by almost 800 percent so that future reports should be able to
more accurately assess national trends in N02 levels.
     Nationwide estimates of pollutant emissions from 1970 through 1974 show
steady declines in the tonnages of particulates and carbon monoxide being
emitted into the air.  Emissions of sulfur oxides and hydrocarbons evidence
only slight declines.  Nitrogen oxides show a slight increase in total
emissions.

DATA REPORTING
     Although data reporting is improving, some difficulties persist in
acquiring or reporting a full year's data for many monitoring stations.
This situation continues to handicap the evaluation of the nation's air
quality.  From a preceding section it can be observed that of the 3788
TSP monitoring stations and 2241 SOp monitoring stations reporting
minimal data in 1974, only 53 percent and 46 percent, respectively,
reported data sufficiently complete to permit calculating a valid annual -
mean.  This not only means that the annual standards for these pollutants
can only be evaluated at about half the existing stations, but also that
the incidence of 24-hour standard violations is inconclusive wherever the
                                    47

-------
data record is incomplete.  Thus, expediting the flow of data from the
state and local monitoring agencies to EPA's national data bank is being
given increased emphasis.

AIR POLLUTION EPISODES

     Within this last report period, EPA has established a standardized
reporting system for air pollution episodes.  Table V-3 presents by EPA
region the number and type of episodes that occurred August through
December 1975.  These data may be summarized as follows:
     0  High ozone/oxidant levels were responsible for 111 of the 136
        episodes.  The greatest frequency and highest stage ozone/oxidant
        episodes occurred in the Los Angeles Basin.  The national frequency
        of ozone/oxidant episodes dropped sharply during the 5-month
        period, reflecting the seasonal decrease in photochemical activity.
     0  The national frequency of TSP episodes increased during the
        period August - December, reflecting the seasonal increase in
        periods of air stagnation.  The highest frequency of TSP episodes
        occurred in a four-county area in Eastern Ohio.
     0  The most severe episode was the Emergency Stage episode for
        TSP in Allegheny County, Pennsylvania, during November.
     0  Carbon monoxide episodes occurred during November and December
        only, and were most frequent in Fairbanks, Alaska.
     0  Sulfur dioxide episodes were confined to two counties in
        Arizona and did not exceed Alert Stage levels.  These were
        associated with emissions from non-ferrous smelters.
     0  With minor exceptions, each episode area had only one
        pollutant responsible for all  its episodes.

REFERENCES
1.   State Air Pollution Implementation Plan Progress Report, January 1 "
    to June 30, 1975.EPA-450/2-75-008.September 1975.'
                                   48

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Table V- 3.  AIR POLLUTION EPISODES FOR AUGUST THROUGH DECEMBER 1975*
Area
Region I
Massachusetts
Massachusetts, S.E. portion
Region II
None recorded for any
pollutant
Region III
Pennsylvania
S. Allegheny County'
Region IV
Alabama
Jefferson County
Kentucky
Louisville
Newport
Tennessee
Chattanooga
Region V
Indiana
Floyd, Clark, and
Dearborn Counties
Michigan
Michigan, lower portion
Ohio
Ohio, most of state
Hamilton and Clermont Go's.
Ohio, most of state
Beltmont, Coumbiana, Jef-
ferson, and Monroe Go's.
Lawrence County
Jefferson County
Wisconsin
Wisconsin, S.E. district
and Milwaukee County
Wisconsin, southern third
of state
Racine County
Ozaukee County

Pollutant


0
X





TSP


TSP

0
ox
X
TSP


0
X

0
X
0
ox
TS£
TSP

TSP
TSP

0
X
0
X
0
ox
X
Q
Number of episodes
Aug.


1

0



0


0

0
0

0


0


1

1
0
1C
0

0
0

1"

1

1
1

Sept.


0

0



0


0

1
1

0


1


0

0
1
0
0

0
0

1

0

0 '
0

Oct.


0

0



0


1

0
0

0


0


0

0
0
0
4

0
0

0

0

0
0

Nov.


0

0



0


1

0
0

1


0


0

0
0
0
lc

lc
1

0

0

0
0

Dec.


0

0



lb


1

0
0

0


0


0

0
0
0
1

0
0

0

0

0
0

Total


1

0



1


3

1
1

1


. 1


1

1
1
1
6

1
1

2

1

1
1

                                   49

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   Table V-3  (continued).  AIR POLLUTION EPISODES FOR AUGUST THROUGH DECEMBER 1975£
Area
Region VI
None recorded for any
pollutant
Region VII
None recorded " for any
pollutant
Region VIII
None recorded for any
pollutant
Region IX
California
Los Angeles Co.
Orange Co.
Western San Bernardino
County
Western Riverside Co.
Kern County
Ventura County
San Francisco Bay Area
Santa Barbara
Los Angeles Co.
Lennox
Arizona
Hay den
Miami
Phoenix
Region X
Alaska
Fairbanks
Idaho
Boise
Washington
Spokane
Pollutant











0
ox
ox
X
0
ox
ox
ox
ox
Cx
CO

so
SO2,
CO2


CO

CO

CO
Q
Number of episodes
Aug.

0


0


0



18
1
16C

6
1
1
0
0
0
0

0
0
0


0

0

0
Sept.

0


0


0



11
6
17

4
0
0
1
1
0
0

0
0
0


0

0

0
Oct.

0


0


0



6C
1
6

1
0
0
0
0
0
0

1
1
0


0

0

0
Nov.

0


0


0



1
1
0

0
0
0
0
0
0
1

0
0
1


1

0

0
Dec.

0


0


0



0
0
0

0
0
0
0
0
1
0

0
0
0


3

1

1
Total

0


0


o ^



36
9
39

11
1
1
1
1
1
1

1
1
1


4

1

1
 Criteria for episodes include three main stages that are increasingly hazardous:
 alert, warning, and emergency.  Concentrations at which each stage is attained
 for each pollutant are specified in Appendix L of 40 CFR 51.  If not otherwise
 indicated, episodes are for the alert stage.

 Emergency stage episodes.

 warning stage episodes.
Source:  EPA National Air Data Branch,  Research Triangle Park,  N.  C.
                                          50

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                   VI.  STATIONARY SOURCE COMPLIANCE
OVERVIEW
     The Clean Air Act establishes a stringent timetable for EPA and states
to abate air pollution.  With a few notable exceptions (e.g., sulfur oxide
emission limitations for the States of Ohio, Indiana, and Illinois), all
states now have fully enforceable emission limitations at levels protective
of health and welfare for stationary installations, which are the source of
the large majority of all particulate and sulfur oxide emissions.  The Act
provides 3 years from the date of state plan approval for EPA and states
to enforce SIP emission limitations and achieve health-related air quality
standards.  Except for portions of 16 states, where an extension of up to 2
years has been granted for one or more pollutants, these ambient air quality
standards were required to be met by May 31, 1975.
     To reach the target air quality levels, state, local and Federal
enforcement programs have the responsibility for ensuring that stationary
sources attain and maintain compliance with emission limitations established
by SIPs.  Enforcement responsibilities for state-developed,  EPA-approved
emission limitations are shared by EPA and the states.  The  Clean Air Act
recognizes that states have primary responsibility for achieving clean
air within their jurisdictions.  When states do not enforce  air pollution
standards, however, the Act requires EPA to take action.   In accordance with
the intent of the Act, the EPA air enforcement program is designed to
ensure that all  sources achieve compliance with applicable standards.  EPA
bolsters state air enforcement efforts by supporting state control
agencies through control  agency grants, providing specialized skill  and
expertise or special  contractual  efforts, and by taking enforcement actions
against selected sources  when the states cannot or will  not  enforce.
                                   51

-------
     Enforcement of standards at stationary sources is an immense task since
it is estimated that over 200,000 stationary sources are now subject to SIP
emission limitations.  Of this number, however, nearly 22,000 are major
emitters (facilities individually capable of emitting over 100 tons of a
pollutant each year).  As a class, these sources produce about 85 percent of
all air pollution from stationary sources.  Therefore, enforcement programs
have first focused on ensuring compliance by such emitters in order to have
the greatest impact on reducing emissions in the least amount of time.
Concentrated efforts expended in this area have resulted in a highly suc-
cessful program.  As shown in Table VI-1, by December 1975 EPA and states
had identified 21,670 such major sources and had brought 18,327 (85
percent) of them into final compliance or placed them on firm schedules
leading to compliance in the very near future (16,969 in final compliance
and 1,358 complying with schedules).  Compliance levels are expected to
climb to about 90 percent by the end of FY 1976.  In the past 6 months, EPA
initiated nearly 400 enforcement actions and conducted some 4,500 field
inspections in accomplishing this goal.  At the same time, states undertook
a large part of the compliance program by conducting around 95,600 field
investigations and initiating about 12,000 enforcement actions to bring
major sources into compliance with SIP emission limitations.  These actions,
and those of the past several years, have resulted in substantial achieve-
ments in reducing emissions of TSP and SO  pollutants to the atmosphere.
                                         X
A recent study shows that since enactment of the amendments to the .Clean Air
Act in 1970, industry compliance with Federal, state, and local air pollu-
tion laws had, by 1974, kept over 26 million tons of particulate matter and
7.6 million tons of SO  out of the nation's air.   These reductions in
                      /\
emissions from stationary sources represent achievement of about three-
quarters of the reduction goals needed for full SIP compliance for particu-
lates and about half of the goal for SO^.
     However, 2,464 or 11 percent of major sources still violate emission
standards or compliance schedules, and nearly 900 must now be inspected to
determine their compliance status.  These last violators are expected to
be the most difficult sources to bring into compliance because they are
for the most part such large sources as power plants and steel mills that
have to date demonstrated a great reluctance to make necessary commitments
                                  52

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-------
to curb emissions to the atmosphere.  Thus, despite decided progress in SIP
enforcement, state and Federal tasks with respect to compliance by large
sources are not yet complete.
     Most of the remaining major violators and most of the major sources
of unknown status are located in Air Quality Control Regions (AQCRs) that
are not expected to attain the primary NAAQS for TSP and/or S02 in a
timely way.  Therefore, enforcement against such sources is now of para-
mount importance.  In addition, it is estimated that about 130,000 smaller
emitters (each having potential emissions of between 10 and 100 tons per
year) are located in these areas where standards are not expected to be
met.  States and EPA are now conducting extensive analyses to determine
the reasons for poor air quality in each of the non-attainment areas in the
country.  These analyses will for the most part be complete by July 1976,
and will specifically identify in each AQCR those major and minor sources
that are contributing to non-attainment problems.  Preliminary analysis
indicates that the minor sources making the largest contribution to air
quality problems include such stationary sources as small industrial, com-
mercial, and residential boilers; small incinerators, such as apartment
house incinerators; dry cleaning operations; bulk storage tanks; cement
handling equipment; cotton gins; feed and grain mills; and chemical plants.
As the causes of non-attainment are identified in these complex analyses,
and as the problem categories of sources are pinpointed, strategies will be
worked out for each area to bring violating sources into compliance and
therefore improve air quality in deficient areas of the country.

MAJOR SOURCE CATEGORIES
     Several categories of major sources are still posing substantial
problems across the nation in not achieving compliance with emission stand-
ards within the time limits prescribed by the Clean Air Act.  Notable among
these sources are coal-fired power plants, integrated iron and steel  manu-
facturing plants and coking facilities, and primary smelters.  EPA has set
up special  efforts to achieve compliance by these sources and continues to
pressure owners and operators of these sources to bring their plants  into
compliance with emission limitations.
                                   54

-------
      In general,  these three source categories have the most difficult air
 compliance problems because of the amount of.control  required and the
 associated costs  of the control  techniques that need to be applied.   For
 coal-fired power  plants, control  of sulfur dioxide emissions is  the  major
 concern.   Flue gas  desulfurization systems (scrubbers)  and low-sulfur fuels
.are two major approaches to the  reduction of power plant emissions.   On the
 other hand,  control  of fugitive  particulate emissions  is the most difficult
 problem for iron  and steel  mills  and coke plants.   This problem  is under-
 scored by the large degree  of noncompliance at coking  facilities.  For
 primary copper, lead,  and zinc smelters,  control of sulfur dioxide emissions
 is  a major difficulty;  plants producing  sulfuric acid  are commonly required
 to  remove the sulfur dioxide from stack  gases.  These  industries  accounted
 for about one-third  of the  total  emissions of  particulates  and about  two-
 thirds  of the total  emissions of  sulfur  dioxide in  1974.   For this reason,
 compliance by all of these  sources  is  crucial  to the attainment of the
 NAAQS in  many AQCRs.
 Coal-Fired Power  Plants
      Control  of emissions from power plants  is  essential  to  the attainment of
 the  health-related air  quality standards  for sulfur oxides  in many areas  of
 the  nation.   As a class,  coal-fired  steam electric plants emit about 60
 percent of the total S0x  produced by all  sources.  During the summer of  1973,
 it  became  increasingly  apparent to EPA that  progress to meet  applicable
 state S0x  emission limitations by this sector of industry was lagging
severely.  New supplies of  low-sulfur coal,  the favored approach to reducing
sulfur oxide  emissions, were  becoming increasingly scarce, and utilities
were extremely reluctant to  use flue gas  desulfurization systems  (scrubbers)
to remove  S0x from the stack  after burning high-sulfur coal.
     National public hearings were held in the fall of 1973 to determine the
validity of the utilities' contentions regarding optional means of compliance.
After hearing testimony from  a variety of expert witnesses and other
interested parties, the 1973  Hearing Panel concluded that the basic techno-
logical problems associated with flue gas desulfurization (FGD) had been
solved or were within the scope of current engineering and, further,  that
FGD could be applied at reasonable cost.   A special EPA enforcement program
was then initiated for power plants on the basis of these findings.
                                   55

-------
     At that time it was estimated that approximately 50 percent of some 394
coal-fired power plants in the nation were violating applicable SIP emission
limitations.  Significant progress has been made in improving compliance
levels since these hearings.  Of the total 394 coal-fired power plants in
the country, 261 plants now comply with final emission limitations or abate-
ment schedules, up from an estimated 200 in the fall of 1973.  Forty-seven
of the total U.S. plants are located in Ohio where no SO  plan is now in
                                                        X
effect.  In November 1975, EPA proposed emission limitations for SO  appli-
                                                                   X
cable to power plants, and these regulations are expected to be promulgated
in mid-1976.  Another 29 of these plants are located in Indiana where the
State Circuit Court recently vacated the SO  plan.  The State of Indiana is
                                           X
currently appealina this decision, but EPA, may yet have to promulgate a new
SIP requirement to cover these plants.  An additional 26 of the total 394
plants are in Illinois, where the SO  plan was also vacated recently.  EPA
                                    X
and Illinois are now gathering data in support of a new plan for SO    The
                                                                   X
remaining 31 plants are known to be out of compliance and action is being
taken where possible.  SIP revisions are underway for seven of these plants;
standards for six plants are being challenged under section 307 of the Act;
a legal stay to enforcement is in effect for one plant pending outcome of
litigation; ten of these plants are part of the TVA system, with which EPA
is currently negotiating for a consent agreement; three plants are subject
to conversion orders by the Federal Energy Administration and will require
compliance date extensions; notices of violation have been issued to two
plants; one utility company is in the process of negotiating a consent agree-
ment with EPA; and action is now being planned for the final remaining
source.  The primary compliance problems remaining with power plants center
on resolving the regulatory problems in Indiana, Illinois, and Ohio.
     Another measure of EPA.'s effectiveness in cleaning up SO  emissions
                                                             /\
from power plants is the increased commitment to F6D systems since the 1973
public hearings.  At that time, some 44 units were installed, under con-
struction s or planned around the country, and by December 1975, this figure
had more than doubled to a total of 115 plants, 28 of which are operational,
18 of which are under construction, and 69 of which are in some stages of
planning.  These units total nearly 45,000 megawatts of generating capacity,
about half the estimated need to achieve 100 percent compliance with SO
                                   56

-------
 regulations by  1980.  The number of units now on  line has nearly tripled,
 from  10 to 28,  and the bulk of these  115 units will have started up before
 1980.  Some are scheduled for startup beyond 1980 and others have unknown
 dates because their installations must await the  startup dates of new plants,
 Primary Non-Ferrous Smelters
     Though small in number, the nation's 25 non-ferrous smelters account
 for about 10 percent of the total sulfur oxides emitted by stationary
 sources.  Most of the Agency's problems in assuring compliance by non-
 ferrous smelters have centered in the western U.S., where six State Imple-
 mentation Plans for sulfur dioxide affecting 13 smelters were disapproved
 in 1972 as inadequate to meet the NAAQS unless the smelters were controlled.
 Another smelter was affected when EPA disapproved the entire Ohio SIP for
 S02 in April 1974.  Regulations have  been promulgated for four of these
 smelters and proposed for the remaining ten.  These regulations require
 application of reasonably available retrofit control technology and, if
 necessary, allow the interim use of supplementary control systems (SCS) and
 tall stacks until adequate constant emission control techniques become
 reasonably available.  Each smelter using SCS is further required to conduct
 a research and development program to hasten the development of such tech-
 nology.  One regulation that EPA recently promulgated was upheld by the
 Ninth Circuit Court of Appeals, but this case has been appealed to the
 Supreme Court.  Two other challenges under section 307 of the Clean Air Act
 are still outstanding.  All  five smelters in the eastern U.S. are now in
 compliance with applicable regulations or are on appropriate schedules.   In
 one case, EPA issued an administrative order to enforce the regulations;
 in another, EPA issued a finding of violation.   Generally, however, state
 agencies are responding adequately to the situation and Federal  action ts
not required.
     About half of the primary non-ferrous smelters are located in AQCRs
where statutory attainment dates have been extended to July 1977.   No
major obstacles are anticipated that might prevent achievement of primary
ambient standards in the vicinity of these sources by the mid-1977 dead-
 lines by using SCS; however, installation of some constant control  devices
may not be completed before  the attainment date.   Those subject to mid-1975
deadlines are, for the most  part, nearing compliance.
                                   57

-------
Iron and Steel Mills/Coke Plants
     The iron and steel industry presents one of the most difficult com-
pliance problems for state and Federal air pollution enforcement programs.
There are 246 steel and coke making installations in the United States,  of
which 218 produce iron and steel (and may or may not produce coke), while
the remainder produce solely coke to be used in metallurgical  and other
industries.  Nearly all of these installations are located in  areas where
the health-related ambient air quality standards are not expected to be
attained.
     Within steel facilities are a number of basic processes,  each of which
presents tough technical problems to control.  The processes that are the
greatest sources of air pollution in the industry are by-product coke bat-
teries, blast furnaces, sintering lines, open hearth furnaces, basic oxygen
furnaces, and electric arc furnaces.  There are nearly 1,200 of these major
emitting steel processes; they characterize the basic means of producing
iron and steel and are the subject of intensifying EPA and state enforcement
attention.  As indicated in Table VI-2, the steel industry lags far behind
other stationary sources in complying with SIP requirements; 50 percent
(589) of the industry's 1,178 major polluting processes have yet to comply
with SIP emission limitations while the level of noncompliance for all
major stationary source installations stands at 11 percent.
     To date state, local, and EPA enforcement programs have placed 367  of
the 589 violating steel processes on schedules to achieve final compliance.
As of December 31, 1975, EPA had initiated 79 enforcement actions (43 notices
of violation and 36 enforcement orders or referrals to the Department of
Justice for prosecution) at nearly 50 steel installations.  Reflecting the
increased emphasis EPA has given steel industry compliance, 46 of these
actions were taken in 1975, compared to 25 such actions in 1974 and 8 in
1973.
     While the reasons for continued violations by any of the  major polluting
steel processes are complex and related to unique conditions at each
facility, the steel industry has regularly raised a number of issues to
argue for more time or for relaxation of air pollution control requirements.
A summary of these issues and EPA's position is outlined below:
                                   58

-------
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      1.   Impact of fugitive process emissions — Fugitive process emissions
are pollutants that are formed during industrial processes and escape to
the air without having been ducted to a smoke stack; characteristically,
fugitive  process emissions are emitted from parts of the steel making
operations that are difficult to seal or enclose.  The heart of the steel
industry's complaints about abating air pollution is their contention that
fugitive  process emissions are either harmless or inconsequential.  Over
the past year, however, EPA and state efforts have documented that fugitive
particulate emissions are large in terms of mass and that fugitive particu-
late  emissions have a large impact on ambient air quality.
      2.   Conflicts with proposed OSHA requirements — In June 1975, the Coke
Oven  Standards Advisory Committee (composed of representatives of the steel
companies and unions) within the Occupational Safety and Health Administra-
tion  (OSHA) made a number of recommendations to the Department of Labor
regarding new occupational safety standards for coke oven workers.  One of
these, Resolution #7, called for a complete ban on the construction of coke
oven  sheds (one method of collecting a portion of coke oven fugitive emis-
sions by  enclosing part of the battery with a shed-like structure).  EPA
testified to the committee that the NIOSH (National Institute of Occupational
Safety and Health) test data used to support Resolution #7 was improperly
construed and that it in fact showed that the addition of a coke oven shed
caused no statistically significant increase in worker exposure to air
pollutants.  Data from EPA tests of coke oven sheds also support this
position.  After reviewing the record of the committee, the Department of
Labor agreed with EPA's position and proposed regulations on July 31, 1975,
stating that "... it is OSHA's opinion that the application of well
designed emission control technology will not necessarily preclude the attain-
                                                                         2
ment  of the level of worker health protection provided by this proposal."
      3.   Economic problems— In general, the steel industry has made a
variety of arguments that the costs of controlling air pollution (especially
fugitive emissions) far exceed any benefits.  Nearly all  U.S. steel mills
were  established prior to World War II and many continue to operate older,
less  profitable equipment.  Profits for the steel industry are consequently
among the lowest for principal  U.S. manufacturing industries (typically 5
to 10 percent of net worth).   Much of the problem in air pollution control
                                    60

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 at existing steel  installations, therefore, centers on controlling
 fugitive air pollutants from equipment, such as coke ovens, designed
 prior to the emergence of widespread concern for air quality.
      The industry's complaints  about costs  were summarized in  a report
 prepared for the American Iron  and Steel  Institute which concluded that
 about twice as  much money would be needed to comply with clean air require-
 ments as had been  previously estimated.3  EPA has reviewed its cost studies
 and has  concluded  that the industry's  cost  figures are much too high.   The
 complexity  of the  industry mekes estimates  difficult,  but a comparison of
 industry and EPA abatement cost estimates (in billions of dollars  through
 1983) is summarized below:
 COSTS  FOR ABATING:
 Stack  emissions
 Fugitive emissions
 Total  air pollution
  abatement costs
 EPA
INDUSTRY
$4.27
  $6.88
     4.  Energy issues — The steel industry contends that the large amounts
of energy needed to abate air pollution conflict with national energy policy.
The American Iron and Steel Institute has argued this issue in eight case
studies prepared for the Federal Energy Administration and in the study it
commissioned Arthur D. Little to conduct.  For. each case EPA has shown that
the industry's estimates of energy needs are greatly exaggerated because they
are based on application of the most energy-intensive control techniques
and do not consider the recycling of energy now wasted in heat and combustible
gases.

REFERENCES

1.  Particulate and Sulfur Oxide Reduction Achieved Nationwide for Selected
    Industrial  Source Categories. 1970-1974.   bPA-MO/1 -76-001.   February 1976.
2-  Federal  Register. Vol.  40, p. 32273, July 31, 1975.
3-  Steel and the Environment:  A Cost Impact Analysis,  report prepared by
    the Arthur D.  Little Company for the American Iron and Steel  Institute,
    May 1975.
                                   61

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                    VII.  CONTROL AGENCY RESOURCES

SUMMARY OF RESOURCES
     The total funds (state and Federal) available for air pollution control
in agencies supported by Federal grants or receiving special assistance in
the form of contractor work were approximately $143 million in FY 1975.  In
addition, approximately $7 million of non-Federally supported activities
were carried on at the local and state levels of government, for a total of
$150 million.
     Since FY 73 Federal support of control agencies has remained .relatively
constant at approximately $51.5 million each year.  In FY 75 this amount
increased slightly to $52.7 million, and in FY 76 Federal funds available
for support of state and local air pollution control agencies will approx-
imate $55.2 million.  The contribution of non-Federal funds by state and
local agencies approximated $91 million in FY 75 for those agencies
receiving Federal support, and totaled $98 million when other agencies,
such as local health departments with air pollution control funds, are
included.
     Preliminary estimates indicate that approximately 6700 man-years of
effort  (directly related to SIP activities assisted by Federal support)
were devoted to controlling air pollution at the state and local level in
1975.   It is estimated that all air pollution control activities approxi-
mated 7100 man-years in 1975 when other agencies are included.

PROGRESS OF STATE AND LOCAL AIR POLLUTION CONTROL PROGRAMS
     Figures VII-1 and VII-2 show in terms of both dollars and manpower the
historical growth of the nation's capability to control air pollution.  The
total expenditures for the support of air pollution control programs have
grown at an average annual rate of approximately 28 percent, from
                                   63

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                 65

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 $13.8 million in FY 65 to approximately $150 million in FY 75.  The per-
 centage of these expenditures provided by Federal financial assistance has
 increased from approximately 31 percent in FY 65 to a peak 43 percent in
 FY 72 and has since been on a slight downward trend to approximately 36
 percent in FY 75.
      Since 1965 the man-years of effort in control  work have tripled.   Man-
 power requirements contained in the 55 State Implementation Plans  submitted
 by the states in April  1971  indicated that approximately 8500 man-years
 would be necessary to implement Clean Air Act programs.   However,  state
 and local  agencies have provided some additional  estimates  made  on the
 basis of changing strategies for programs  such as transportation control
 activities,  prevention  of significant deterioration,  and the attainment
 and maintenance  of standards.   A 1973 estimate indicated that 9500
 man-years  would  be required  by  1975 and 10,300 man-years would be  needed
 by 1977  to meet  anticipated  program demands.   On  the  basis  of these
 estimates, the state  and  local  control  agencies had approximately  75 percent
 of the manpower  and funds  stated as  being  needed  in 1975.
      In  1975, 80  percent  of  the  states  (including local  agencies)  expended
 an  effort  in man-years  and dollars  equivalent  to 60 percent or more of
 their stated needs.  The  number  of  states with greater than 60 percent of
 their manpower needs increased from  33  in  1974 to 44  in  1975.  Funding
 increased over 1974 by  approximately  14 percent ($18 million) and man-
years of effort by 9 percent (600 man-years, all sources).  These increases
were approximately the same as in previous years.   Improvement in resources
was principally due to the state and  local increase  in funds of approxi-
mately 20 percent over 1974.
                                   66

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                                   TECHNICAL REPORT DATA
                            (Please read Instructions on the reverse before completing)
 i. REPORT NO.
  EPA-450/2-76-006
                                                           3. RECIPIENT'S ACCESSION-NO.
4. TITLE AND SUBTITLE
State Air  Pollution Implementation  Plan Progress Report,
July 1 to  December 31, 1975
                                                           5. REPORT DATE
                                                            April  1976
                                                           6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
                                                           8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
J.S. Environmental  Protection Agency,  Office of Air and
  .ste Management, Office of Air Quality  Planning and
Standards, Research Triangle Park, N.C.,  and Office of
Enforcement, Washington, D. C.
                                                           10. PROGRAM ELEMENT NO.
                                                            11. CONTRACT/GRANT NO.
 12. SPONSORING AGENCY NAME AND ADDRESS
U.S. Environmental  Protection Agency
)ffice of Air  and Waste Management
)ffice of Air  Quality Planning and  Standards
Research Triangle Park, North Carolina   27711
                                                           13. TYPE OF REPORT AND PERIOD COVERED
                                                              Progress,  7/1  to 12/31/75
                                                           14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
16. ABSTRACT
This report  features two topics:   (1)  the current evaluation  of all  State Implementa-
tion Plans (SIPs)  to determine by  July 1, 1976, those that  are  "substantially inade-
quate" and need revisions to attain  and maintain the National Ambient Air Quality
Standards  (NAAQS); and (2) an overview of EPA's carbon monoxide/oxidant control
strategies,  with an emphasis on control of transportation-related sources of these
jollutants.   Also  included in this report are summaries of  SIP-related actions pub-
lished in  the Federal Register during  this reporting period,  ambient air quality and
trend data for 1974, and stationary  source compliance information.  Since the last
report in  this series (EPA-450/2-75-008, September 1975), the number of major sources
identified has increased by 2,463  to 21,823; 84 percent of  these are now in compliance
  th an emission standard or on an acceptable compliance schedule.
                                KEY WORDS AND DOCUMENT ANALYSIS
                  DESCRIPTORS
                                              b.IDENTIFIERS/OPEN ENDED TERMS
                                                                         c. COSATI Field/Group
 Air pollution
 Air Quality Maintenance Areas
 Air quality monitoring
 Air quality standards
 State Implementation Plans
 Enforcement
13. DISTRIBUTION STATEMENT

 Release unlimited
                                              19. SECURITY CLASS (ThisReport)
                                                Unclassified
                                                                         21. NO OF PAGES
65
                                              20. SECURITY CLASS (Thispage)

                                                Unclassified
                                                                         22. PRICE
EPA Form 2220-1 (9-73)
                                             67
                                                       *U.S.'GOVERNMENT PRINTING OFFICE: 1976-6417317/5505 Rsgioh'.No. 4

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