EPA-450/2-83-007
        National  Air Audit
System  Guidelines for FY 84
        Control Programs Development Division
      U.S. ENVIRONMENTAL PROTECTION AGENCY
          Office of Air, Noise, and Radiation
       Office of Air Quality Planning and Standards
       Research Triangle Park, North Carolina 27711

               November 1983

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This report has been reviewed by the Control  Programs Development Division
of The Office of Air Quality Planning and Standards,  EPA,  and approved for
publication.  Mention of trade names or commercial  products  is not intended
to constitute endorsement or recommendation for use.   Copies of this report
are available through the Library Services Office (MD-35), U.S. Environmental
Protection Agency, Research Triangle Park, North Carolina  27711; or, for a
fee, from the National Technical Information  Services, 5285  Port Royal
Road, Springfield, Virginia 22161.

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                           FOREWORD
     The National Air Audit System is a unique example of a
program that was conceived as a State/local/EPA cooperative effort
and has remained so throughout its development period.  This
audit guideline document was prepared under a process that
exemplifies a cooperative effort among all levels of government--
Federal, State, and local.  Developing and implementing programs
in partnership with States and local air pollution control agencies
has been a stated EPA goal for a long time, and the National Air
Audit System is one of our best results to date.  I believe that
the phrase "State/local/EPA partnership" has been shown to have
true meaning in the development of the National Air Audit System,
and I hope that this initiative can serve as a model for the
development of other shared programs.

     This year's effort will be the pilot phase of what should
become a dynamic, on-going cooperative program.  We will learn
from our initial auditing efforts and improvements in the program
will be a goal for future years.

     I look forward with interest to reviewing the progress made
in implementing these National Audit Guidelines.  We must all
strive to build the best possible air pollution control agencies
at every level of government.  The National Air Audit System will
be a useful tool to help us all improve the management of our
programs and to provide the best possible environment for all of
our citizens.
                                 Joseph A.  Cannon
                          Acting Assistant  Administrator
                               for Air and  Radiation

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                                 CONTENTS
Forward	Hi
Acknowledgements 	    v
List of Contributors	vi

     1.  Introduction	1-1
              Goals and Objectives of the National  Audit System.  .  1.3
              Audit Protocol	1-4
              Audit Report and Use of Audit Data	1.5
              Future NAAS Activities 	  1_6
     2.  Air Quality Planning and SIP Activity Audit Criteria.  .  .  2-1
              Introduction 	  2-1
              Air Quality Evaluation 	  2-1
              Emission Inventories 	  2-3
              Modeling	2-5
              SIP Evaluation and Implementation	2-7
     3.  New Source Review	3-1
              Introduction 	  3-1
              Audit Protocol	3-1
              Administrative Procedures	3-2
              Applicability Determinations 	  3-5
              BACT/LAER Determinations 	  3-9
              Ambient Impact Analysis	3-12
              Emissions Offset Requirements	3-16
              Permit Specificity and Clarity 	  3-18
     4.  Compliance Assurance	4-1
              Introduction 	  4-1
              Periodic Review and Assessment of Source Data.  .  .  .  4-1
              File Review	4-3
              Overview Inspections 	  4-6
     5.  Air Monitoring Audit Guideline	5-1
              Introduction 	  5-1
              Audit Protocol	5-2
              Air Monitoring Audit Questionnaire 	  5-4
                                  IV

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                             ACKNOWLEDGEMENTS
     A well earned note of thanks to the following people who  contributed
time and energy to make these audit guidelines  a  reality.
                   PROJECT MANAGEMENT AND  COORDINATION
                   Bill Becker
                   John Calcagni
                   Tom Helms
                   Darryl Tyler
                   Tom Williams
                      STAPPA/ALAPCO
                      EPA, OAQPS
                      EPA, OAQPS
                      EPA, OAQPS
                      EPA, OAQPS
                                 AUTHORS
Ai r Quality Planning
and SIP Activities

   Dan Goodwin  State of Illinois
              Chai rman
Bill Baker
Dave Calkins
Bob French
Bob Offutt
John Pratapas
Dave Redic
Steve Rothblatt
EPA, Region II
EPA, Region IX
State of Delaware
Louisville, KY
EPA, OAQPS
Dayton, OH
EPA Region V
Compliance Assurance

    Bill Meyer  State of Virginia
              Chairman
John Crenshaw
Wayne Cropp

John Hepola
Curt Marshall
Robert Miller
John Phil brook
John Rasnic
Jim Wilburn
EPA, OAQPS
Chattanooga-Hami Iton
  Co., TN
            VI
EPA, Region
Dayton, OH
State of Michigan
EPA, Region VIII
EPA, OAQPS
EPA, Region IV
                           New Source  Review

                              Robert Col lorn  State  of Georgia
                                          Chai rman
                            Michael  Bradley
                            Dan deRoeck
                            Clark Gaulding
                            Norm Glazer
                            Stan Meiburg
                            John Paul
                            Roger Pfaff
                            Mike Trutna

                           Air Monitoring
                       NESCAUM
                       EPA,  OAQPS
                       EPA,  Region X
                       Philadelphia,
                       EPA,  OANR
                       Dayton, OH
                       EPA,  Region IV
                       EPA,  OAQPS
                              William Sylte  State of California
                                          Chairman
Don Arkell
Vic Guide
John Helvig
Jim Lents
Bob Ostrowski
Don Porteous
Stan Sleva
Darryl von  Lehmden
Lane Co., OR
EPA, Region III
EPA, Region VII
State of Coloradc
Philadelphia,  PA
EPA, Region I
EPA, OAQPS
EPA, ORD

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                          LIST OF CONTRIBUTORS
     A special  thanks to  the following people who were involved in the  development
of the program  and/or who reviewed and commented on the guideline drafts.

                               Reviewers
G. Able
S. Ballou
E. Bell
K. Bell
J. Bosch
E. Chase
R. Colby
F. Cordner
P. Cosier
R. Cunningham
K. Dalton
A. Dammkoehler
J. Daniel
A. Davis
L. Davis
T. Davis
D. DeBruyn
B. DeSpain
T. Devine
J. Dicke
D. Drake
J. Elston
J. Farmer
L. Fleckenstein
D. Gower
K. Hagg
J. Hambright
S. Hitte
G. Mailman
H. Hovey
D. Johnson
EPA, Region X
State of Iowa
State of Texas
EPA, OAQPS
EPA, OAQPS
Fairfax, VA
Chattanooga, Tennessee
State of Utah
EPA, OANR
EPA, Region III
State of New York
PSAPCA, WA
State of Virginia
EPA, Region VI
State of New York
State of New York
EPA, Region X
EPA, Region VIII
EPA, Region IV
EPA, OAQPS
State of Michigan
State of New Jersey
EPA, OAQPS
EPA, OPPE
State of New York
State of Massachusetts
State of Pennsylvania
EPA, OAQPS
NWAPA, WA
State of New York
EPA, Region VI
F. Johnson
B. Kramer
H. Laing
G. Lauderdale
L. Murphy
G. Murray
G. Neighmond
R. Neligan
N. Nikkila
R. O'Meara
L. Paley
R. Parker
0. Rami rez
L. Rowe
M. Sanderson
J. Silvasi
C. Simon
S. Simon
M. Stenburg
B. Stewart
J. Stuart
W. Swietlik
J. Sydnor
D. Tudor
B. Walsh
C. Walter
R. Watman
E. Weathersbee
R. Westman
R. Wood
H. Wortreich
State of North Carol
EPA, Region III
EPA, Region I
State of Colorado
EPA, Region I
State of North Carol
State of New York
EPA, OAQPS
State of Missouri
EPA, Region I
EPA, OAQPS
Dayton, OH
EPA, Region VI
State of Arizona
EPA, Region VII
EPA, OAQPS
EPA, Region II
EPA, Region I
EPA, Region IX
State of Texas
SCAQMD, CA
Fairfax Co., VA
EPA, Region III
State of Maine
EPA, OAQPS
EPA, Region VII
EPA, Region III
State of Oregon
Allegheny Co., PA
State of Wyoming
State of New Jersey

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                             1. INTRODUCTION
     This audit manual was developed through the joint  efforts  of State
and Territorial Air Pollution Program Administrators (STAPPA),  Association
of Local Air Pollution Control Officials (ALAPCO),  and  Environmental
Protection Agency (EPA).  The project was directed  by a work  group composed
of members from the three organizations.  The audit guidelines  in this
manual were written by four subcommittees of this work  group.  The program
areas selected by the work group for development of audit  guidelines
were:  (a) air quality planning and SIP activity, (b) new  source review,
(c) compliance assurance, and (d) air monitoring.  The  subcommittees  were
chaired by State agency personnel with EPA staff serving as  expediters.
All State agencies, local agencies, EPA Regional Offices,  and EPA Head-
quarters were provided an opportunity to comment on a draft  version of
these audit guidelines.  This manual, from concept  to finished  product,
is the result of a cooperative effort between State agencies, local
agencies, and EPA.  While it necessarily reflects a compromise  between
the competing interests of depth of analysis, breadth of review, and
resources to accomplish the audit, it does represent the "real  world"
ideas of people who actually implement the duties.

     The need for a National Air Audit System (NAAS) became  apparent  with
the increased delegation of responsibility to State and local air pollution
control  agencies.  As a first step in developing the audit program,  repre-
sentatives of STAPPA, ALAPCO, and EPA met in late 1982  to  discuss the
concept.  In April 1983, the group met again to identify the  essential
elements and appoint the subcommittees to write the audit  guidelines.
The work group met for a third time in October 1983 to  discuss  the imple-
mentation of the FY 84 National  Air Audit System.

     Auditing of State and local agencies is not a  new  activity as the
EPA Regional Offices have been conducting some form of  evaluation and
audit for many years.  However,  the frequency, depth, and  procedures  for
conducting these audits have varied greatly from Region to Region within
EPA and even State to State within the Regions.  This was  reflected  in  a
survey report that EPA's Office of Air Quality Planning and  Standards
(OAQPS)  issued on the EPA Regional Office air audit programs  (Survey  of
Regional Air Audit Programs, June 1983).  Prior to  this survey, however,
the State and local agencies had begun expressing concern  over  the Regional
inconsistency of the oversight programs.  The general tenor  of  the comments
was that EPA should develop uniform evaluation criteria that  would be
applied on a national basis.  From this beginning came  the National Air
Audit System and the FY 84 audit guidelines contained in this document.
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     The three meetings  mentioned earlier resulted  in  important  guidance
agreements that will  formulate EPA policy in  initially  applying  these
guidelines.  These agreements are discussed below:

     *   EPA will  hold multi-Regional  workshops  to  ensure  Regional  consis-
         tency in  the performance of  the  audits  (tentatively  scheduled
         for mid-January 1984).

     *   EPA Regional Offices will select the composition  of  the audit
         teams.  A crossover team approach (State/local  and outside Regional
         Office representatives)  is possible  for FY 84  if  Regions  and
         affected  States so desire.

     *   Regional  Offices will audit  all  State agencies  in FY  84 and
         local agencies  that are  funded directly by EPA  with  Section 105
         grant funds.  All four audit  guidelines will  be applied to each
         audited agency  (to the extent that the  agency  is  responsible for
         the four programs).

     •   Corrective actions for deficiencies  uncovered  will be initiated
         through existing mechanisms,  i.e., 105  grants,  Stat°/EPA agreements,
         etc.

     *   The national FY 84 schedule  calls for the  audits  to  be  conducted
         by April  30, 1984, for EPA Regional  Offices to  forward  a draft
         report for review and comment by the State and  local  agencies  by
         June 30,  1984,  and a final report prior to September 30,  198-1.

     *   Regions will use uniform questionnaires compiled  from the audit
         guidelines.   (These will be  available in January  1984).

     •   The OAQPS will  prepare a national report based  upon  the results
         of all Regional audits.   The  national report will not rank
         agencies  or focus on deficiencies of specific  agencies.  Drafts
         of the national report will  be reviewed by EPA  Regions  and
         representatives of STAPPA and ALAPCO.

     *   The NAAS  will replace current Regional  Office  air program audit
         activities.   It may not, however, replace  the  105 grant evalua-
         tions that are  specified in  the  grant regulations.   Regions have
         the flexibility to expand the audit  to  address  additional  topics
         or to explore specific areas  in  more detail,  subject  to negotia-
         tions with individual States.

     •   When fully developed, the NAAS will  eliminate  the need  for much
         of the "item by item" Regional Office oversight on certain State
         and local agency programs.  However, the NAAS  will not  be a
         substitute for  the necessary  flow of communications  between
         State/local  agencies and EPA  Regional Offices.
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GOALS AND OBJECTIVES OF THE NATIONAL AIR AUDIT SYSTEM

     The purpose of developing national  audit guidelines  is  to establish
standardized criteria for the EPA Regions'  audit of State air program
activities.  The primary goals of this program are to determine the
obstacles (if any) which are preventing the State or local  air pollution
control agencies from being as effective as possible in their air quality
management pfforts and to provide EPA with  quantitative information on
how to define more effective and meaningful national programs.  States
are playing a larger role than ever in the  planning and implementation of
complex, and often controversial, air pollution control strategies.  EPA
oversight of these and related activities is necessary for assuring
national consistency and for assisting the  States in resolving identified
problems.  The EPA and States can also use  these audit results to assure
that available resources are being focused  toward identified needs (e.g.,
attainment and maintenance of standards, adoption of regulations, imple-
mentation of regulations and technical analyses to support  control strategy
development).

     The EPA also hopes to share the results of these audits in a manner
that permits the "cross-fertilization" of innovative approaches and
systems across States and Regions.  Only through this national exchange
can we hope to benefit from the invaluable  experiences gained to date by
control agencies in carrying out the requirements of the  Clean Air Act.

     This audit guideline outlines a program which EPA, State, and local
air pollution control agencies can jointly  use to:

     ' Meet statutory requirements;

     • Assist in developing at least a minimally acceptable  level of
       program quality;

     * Allow an accounting to be made to the Congress and the public of
       the achievements and needs of air pollution control  programs;

     * Enable EPA, States, and local agencies to agree on needed technical
       support and areas where program improvements (including regulatory
       reform) should be made.  This includes improvements  to both EPA
       and State/local programs; and

     * Maximize and effectively manage available resources,  within the
       State and local agencies and EPA, resulting in expeditious attain-
       ment and maintenance of ambient air  quality standards as soon as
       possible.

     State, local, and EPA Regional Offices, working together, may identify
items in addition to those of the national  program which  are worthy of
further audit attention.  In making such an identification,  both the EPA
Regional Office and the State/local agency  should understand in advance
what the reasons are and what the objectives and expected result(s) of
this expanded review will  be.  Also, the NAAS is not intended to preclude
EPA Regions from dealing,  on a case-by-case basis, with significant
deficiencies which are identified during the course of the  audit.


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     The NAAS builds upon oversight  procedures  already  in  use  in  EPA
Regional Offices.  In addition,  the  guidelines  and  the  audit  itself are
not a substitute for the necessary  daily  flow  of  communication between
State/local agencies and EPA Regional  Offices.   It  is expected that the
preparation for the audit (see Audit Protocol)  will  utilize  reports
currently available from State and  local  agencies to EPA as  fully as
possible, and that EPA will  work to  minimize the  demands on  State or
local staff time in conducting the  audit.   It  is  also expected that each
State and local agency will  cooperate with  EPA  during the  onsite  audit
visit.

     EPA, State, and local  agencies  should  keep in  mind that  the  audit  is
intended to improve the overall  quality  of  air  pollution control  programs.
This intent of improving overall performance needs  to be clearly  understood.
The standards of performance outlined by  these  guidelines  are  not so
rigid that they eliminate the flexibility  afforded  by the  Clean Air Act.
Also, these guidelines should not be construed  to establish  performance
standards which must absolutely  be  achieved in  practice   Moreover, while
participating agencies will  use  the  audit  to point  out  where  opportunities
exist for State or local improvements, the  audit  is  not expected  to
address every problem.  However, EPA will  continue  to search  for  and
disseminate information about better ways  of consistently, effectively,
and efficiently implementing a comprehensive air  pollution control program.
This includes possible reforms of EPA's  requirements wher? feedback from
the audits suggests that certain requirements  detract from program
effectiveness.

AUDIT PROTOCOL

     Each Regional Office must tailor the structure  of  the audit  according
to the particular characteristics of the  State  and  local agencies in  the
Region and its own operating procedures.   However,  certain elements and a
number of procedural steps  have  been found  useful by most  Regions in
conducting a successful audit.  These are discussed  below.

Advance Preparation

     A letter should be sent to  the  agency  well in  advance of  the audit.
The letter should confirm the date and time of  the  audit  (see  Onsite
Visit), and describe what resources  the  State  is  expected  to provide,
such as office space and staff time.  This  letter should also  identify
the name and title of each  individual  who will  comprise the  audit team.
The EPA Region will provide the  control  agency  with  a nationally  prepared
checklist or questionnaire  to supplement  the audit  guidelines. This
should be sent to the State or local agency about a  month  in  advance  of
the audit and, thus, will allow  the  agency  to  better prepare for  the
audit.  It is recommended that the State  or local agency fill  out the
questionnaire in advance, as a time  saving measure,  <=ven though the
auditor will go over the questionnaire during  the audit.   This audit
information should be readily available,  although  it may  require  time to
gather and compile, and should be given  to the auditors when they arrive
at the agency.
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Onsite Visit
     The primary purposes of the onsite visit are to:
     • Engage in a broad discussion with agency staff to gain insight
       into any recent changes in the structure of the organization,
       discuss specific problem areas of the agency,  and become acquainted
       with the staff in order to better open up channels of communication;

     * Discuss answers to the questionnaire;

     • Review onsite documents that are too cumbersome to transmit such
       as permits, modeling runs, and supporting files;  and

     * Interview personnel  responsible for the daily  operations of programs
       for air monitoring,  compliance assurance, new  source review,  and
       air quality planning and SIP activities.

     Typically, the audit is conducted in four phases:

     * The EPA auditors for all programs meet with the State agency
       director and top staff to discuss the goals of the audit and  to
       "break the ice."  This meeting usually sets a  cooperative tone for
       the visit;

     * The EPA auditors conduct a discussion of the questionnaire with
       the person(s) in charge of each of the four activities to be  audited;

     * A review of the files will provide the auditors with an opportunity
       to verify that the implementation of required  activities is properly
       documented.  The files to be reviewed would include:  permits,
       compliance records,  air monitoring records, and SIP planning
       documents.  More detailed information on file  selection and review
       is provided in the following chapters.

     * An exit interview is held as a wrap-up session to inform agency
       management of the preliminary results of the audit.  This promotes
       harmony between EPA  and the State by giving immediate feedback of
       the results in a face-to-face meeting between  the people actually
       performing the audit and those responsible for the programs being
       audited.

     The time which the audit team spends to complete the various phases
of the onsite visit generally should not exceed three days.  However,
this general rule will be difficult to adhere to in certain instances,
such as when satellite facilities of the agency being audited must also
be visited.  In any event,  the duration of the onsite visit should be
mutually agreed upon in order not to create an undue  burden to the agency
being audited.


AUDIT REPORT AND USE OF AUDIT DATA

     Each State or local  agency audit report should contain the findings
for each of the four audited areas.  The Regional Office should give  the

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State or local agency an opportunity  to comment  on  a  draft  of the report
before it is released outside of EPA.   This  allows  misunderstandings  and
errors to be discovered before the report is finalized.   Major deficiencies
identified during the audit should be highlighted  in  a  separate section
(such as the summary of the report).   This  enables  the  Region to detail
all the findings of the audit without  causing the  reader  to confuse  minor
points wit^ major problems.  It also  identifies  to  the  audited agency
those deficiencies considered most serious.   Where  an agency disagrees
with the conclusions of the audit, they should provide  to EPA written
comments outlining their perspective.   These will  be  incorporated as  an
appendix to the final report.  The report should also highlight outstanding
and/or innovative program procedures  that are identified.

     The audit would be of limited use without some mechanism for rectifying
identified deficiencies.  Therefore,  it is  important  that the report
recommend measures or steps to treat  the causes  for these inadequacies.
Lead responsibilities for implementing these recommendations and anticipated
resource requirements should also be  considered.

     A National Report compiling the  findings of the  audits conducted by
the EPA Regions will be compiled by EPA Headquarters.  This analysis  will
be based on the reports prepared by the EPA  Regions as  discussed above.   It
will present the status of implementation of the audit  programs throughout
the nation and will highlight areas where innovations have  resulted  in
substantially superior performance.  It will not rank agencies or focus
on specific deficiencies in individual programs.  While it  will address
areas of conflict between EPA guidance and  implementation experience, it
will not he a forum for addressing unresolved issues  between audited
agencies and EPA.  The specific content of  the national  report will  be
defined by the STAPPA/ALAPCO/EPA audit work  group  in  the  spring of 1984,
after some initial experience in conducting  the  audits.

FUTURE NAAS ACTIVITIES

     This initial implementation of the NAAS is  a  first step of a "phased-in"
procedure.  The FY 84 site visits should be  viewed  as an  opportunity  to
discover and identify differences between the EPA  policy  as reflected in
the audit guidelines and actual practices in the field.   The first visit
should not be used to pass judgment or grade the adequacy of currently
used procedures, but to establish a baseline.  Subsequent site visits
should then be used to measure progress in  achieving the  ideal program
operation.

     EPA plans to make mid-course corrections as NAAS experience grows.
This would include, in the short term, improvements in  each of the four
guidelines.  A spring 1984 meeting for the  STAPPA/ALAPCO/EPA work group
is planned for this very purpose.

     The NAAS initiative is designed  as a partnership effort to help  EPA
and State and local agencies each do  their  respective jobs  better.  It  is
our hope that it can become the foundation  which all  involved can use to
make solid progress in protecting and enhancing  the quality of our Nation's
ai r.
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           2.  AIR QUALITY PLANNING AND SIP ACTIVITY AUDIT CRITERIA
INTRODUCTION

     Four major program areas in air quality planning and State Implementation
Plan (SIP) activity have been singled out for evaluation in the FY 84 National
Air Audit System (NAAS).  These areas are:

     • Air Quality Evaluation
     • Emission Inventories
     * Modeling
     • SIP Evaluation and Implementation

     Audit criteria are provided below for each program area.   Each topic is
prefaced by a brief discussion of what activities it encompasses and what we
generally hope to accomplish through the audit review.  The audit guidelines
are organized to address the broader aspects of each program area in the
"numbered" questions.  Following each "numbered" question are  supplemental
questions that are intended to provide the bases for supporting and documenting
the responses.  A simple yes or no answer will not be considered an adequate
response to the numbered questions.  Where appropriate, responses should  be
supplemented with examples.

AIR QUALITY EVALUATION

     States are continuously gathering air quality data to satisfy various
statutory requirements and air management needs.  The adequacy of these
ambient measurements is addressed in a separate audit area dealing with
monitoring requirements.  This audit topic is concerned with the demonstrated
State capabilities to perform air quality evaluations.  This includes the
ability to systematically consider available air quality data  for the purpose
of trends analyses, Section 107 redesignations, prioritization of air program
activities, and public information.  The specific areas that should be evaluated
in this audit category are discussed below.

Audit Questions

     1.  Does the State/local agency systematically review air quality
monitoring data and perform updated air quality analyses in order to track
progress or compare actual air quality relative to past projections?  If  no,
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explain why.  If yes,  briefly  describe the  procedures,  content,  frequency,
and nature of this review.jY

     a.  Is there an annual  publication of  air quality  monitoring  data  with
         comparisons to the  national  ambient  air  quality  standards  (NAAQS)?
         Either include a recent  copy of this report  or indicate what  it
         contains and what period of  data is  covered.   We are  also  interested
         in the timeliness of  the report, i.e.,  "What  is  the  lag time  between
         data retrieval and  publication?"

     b.  Does the State/local  agency  perform  periodic  reviews  of Section  107
         attainment status designations and submit  proposed changes  to  EPA?
         Describe the review process  used by  the  State/local  agency  and list
         the actual number of  redesignations  submitted  from October  1,  1982,
         to September 30, 1983.   In  general terms,  comment on  how well  the
         agency conforms with  regulations and policy when submitting these
         requests to EPA.

     c.  Is a mechanism in place  so  that any  results  of monitoring  studies
         that are done either  by  permit applicants  or  for special purposes
         can be systematically considered and included  in periodic  SIP  updates
         when that data conflicts with other  current  information?  Indicate
         how often this occurred  and  for what cases during the audit period.

     2.  To what extent are  air quality monitoring  results and modeling
studies used to focus State/local agency attention  and  resources on  priority
problems?

     a.  For instance, are statistics on the  frequency  and severity  of  NAAQS
         exceedances used in any  formal way to determine  program priorities
         on a geographic basis?   Give examples of studies where  this has  been
         done and how the results were used.

     b.  Are criteria and a  plan  established  to  relate  emission  source  data
         to ambient impacts?  For instance, to what degree is  air quality
         monitoring used to  identify  individual  emission  sources or  source
         categories that need  increased regulatory  or  enforcement attention?
         Cite any recent experiences.
\J EPA guidance on the data analysis  aspects  involved  in  the  interpretation
   of NAAQS is provided in the following:
   • "Guideline for the Interpretation of  Air Quality  Standards"  -  OAQPS  No.
     1.2-008 (1974 - Revised 1977).
   * "Guideline for the Interpretation of  Ozone  Air Quality Standards"  -  OAQPS
     No. 1.2-108 (1979).
   * Memorandum dated May 27,  1983,  from Richard Rhoads,  Director,  Monitoring
     and Data Analysis Division,  OAQPS to  Gary O'Neal,  Director,  Environmental
     Services Division, Region X  - "Summary  of NAAQS Interpretation."
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EMISSION INVENTORIES

     The emission inventory provides information concerning source emissions
and defines the location, magnitude, frequency,  duration,  and relative
contribution of these emissions.  An inventory is useful  in designing air
sampling networks, predicting ambient air quality, designing control  strategies,
and interpreting changes in monitored air quality data.   Plans  for attaining
and maintaining NAAQS's are dependent on a complete and  accurate emission
inventory.

     In the implementation of a nationwide program of air quality management,
consistent methods of inventory compilation are  essential.   An  adequate
emissions inventory must be accurate, complete,  and provide for consistency
in planning between metropolitan areas, States,  and Regions.

Audit Questions

     1.  Is there a centralized group/contact and does the  State/local  agency
have a satisfactory system for acquiring and maintaining  comprehensive up-to-
date °missions inventory for all criteria pollutants, precursors (e.g.,
reactive VOC), and sources affected by national  emission  standards for hazardous
air pollutants (NESHAPS)?

     a.  Are there emission estimates and related essential  data (e.g., stack
         parameters) for each major source of criteria pollutants (including
         new source performance standards sources)?

     b.  Are there emission estimates and related essential  data (e.g., operating
         rate) for all  regulated minor point sources of  criteria pollutants
         in nonattainment areas?

     c.  Are there emission estimates and related essential  data for  all
         NESHAPS sources over which the agency being audited has authority?

     d.  Are there current estimates of unregulated minor  point and area
         sources for nonattainment areas?

     e.  Where sources  below an appropriate cutoff level  (e.g., five  tons per
         year for lead) are excluded from the point source  inventory,  are
         they accounted for, in aggregate, in the area inventory?

     f.  Is there a mobile source inventory which is reflective of currently
         acceptable methods, emissions factors,  and assumptions recommended
         by EPA (e.g.,  MOBILE 2)?

     g.  Are inventory  data regularly updated by a well-defined, ongoing
         process, and can the year of last update be easily  determined?
         Minimum updating frequencies are:
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              • Every  two-three years  for  criteria  pollutants  in  nonattainment
                areas  and NESHAPS  sources,  and three-five years for  criteria
                pollutants in  attainment areas,  or

              * As  often  as  necessary  to reflect  start-ups,  shutdowns, major
                process modifications,  control device  changes, updated
                emissions factors,  and  to  assure  consistency with  compliance,
                permit, or other  agency files.

     2.   Is  the methodology  employed  in compiling the  inventory such that
inventory outputs are  accurate, complete,  and  in  conformance with  appropriate
guidance?

     a.   Are point  and area  source  data obtained  and compiled  to  the most
         recent EPA guidance documents  (AP-42, APTD 1135, EPA-450/2-77-028,
         EPA-450/4-80-16)?

     b.   Are transportation  data  consistent with  the State DPT's  or  local
         MPO's, and do growth  projections  comport with  Section 208 water
         project estimates?

     c.   Is  sufficient documentation  of inputs (emission factors,  stack tests,
         traffic counts)  and calculation methods  available to  permit verification
         of  the accuracy  and appropriateness of  the approach employed?

     d.   Does the system  have  the  capability of  providing both actual and
         allowable  emission  rates?

     e.   Are quality assurance procedures  in place  and  implemented including:

              * Validity  checks  (internal  as well as external, the latter
                possibly  by  sending the point  source records to plant management
                for review and updating)?
              * Checks for missing sources?
              * Comparison between  enforcement,  planning, and  NSR  records?

     3.   Is  the information  contained  in the inventory  retrievable in an
appropriate  format, and in sufficient  detail to  be  compatible  with the essential
planning responsibilities of the  agency?

     a.   Is  the inventory computerized and operational?

     b.   Are a variety of reports  producible from the  inventory system
         including:

              • Various category  aggregations?
              ' Various geographical  aggregations?
              • Effects of changes  in  control  measures  or process  modifications?
              * Annual submittal  to NEDS to meet  SIP requirements?
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     c.
Do emissions output data provide sufficient temporal  and spatial
resolution for use in modeling and SIP analysis?
     d.  Is emission inventory output compatible with  methods  used to
         demonstrate reasonable further progress (RFP)?

     4.  What was the last date of a submittal  to NEDS?  Is  there a mechanism
and/or specific contact to resolve problems  and identified deficiencies?


MODELING

     Air quality models are being used more  extensively in the conduct  of  day-
to-day activities in the planning and SIP program area.  These activities
include such things as attainment demonstrations, major source compliance
determinations, new source review, evaluations  of "bubbles," and  assessing
attainment status.  Most State agencies should  have the EPA  reference models
on-line that are available for use in these  and other  types  of applications.
The modeling audit is intended to gather information regarding the agency's
demonstrated expertise and capability to perform necessary air quality  modeling
analyses consistent with accepted EPA procedures.2_/

     In accomplishing this objective, the auditor will  find  it necessary to
review some actual modeling applications performed or  evaluated at the  State/
local program.  Because the Region will have already reviewed  specific  modeling
analyses submitted (during the audit period) to support planning  and SIP
activities, it would be advisable to review  the results of these  evaluations
when assessing the demonstrated modeling capability of the agency being
audited.  As a starting point for this effort,  the auditor should have  the
State or local program prepare a list of the modeling  analyses performed or
reviewed during the audit period and the purpose of the modeling  (e.g.,
permit, SIP revision, variance, enforcement  action).  Prior  to the onsite
visit, the auditor and the State/local agency should pre-select which specific
modeling analyses will be audited.

     Specific areas that should be evaluated during the audit  include:

     1.  Does the State/local agency possess the capability  for conducting
and/or reviewing air quality modeling necessary to carry out its  SIP develop-
ment and evaluation role?  Specifically,

     a.  Are there sufficient staff available with training  or experience  in
         the use of EPA reference models and the modeling guidelines?
         Summarize staff levels and experience  and indicate  the proportion of
         required modeling done in-house versus contractor for different
2J EPA guidance is provided in "Guideline  on  Air Quality  Models,"  EPA-450/2-78-027,
   April  1978.   This report is currently undergoing revision.  Additional  guidance
   is also provided in "Regional  Workshops On Air Quality Modeling:   Summary Report,
   OAQPS, April 1981 and "Guideline for Use of City-Specific EKMA  In  Preparing
   Ozone SIP's," EPA-450/4-80-027,. March  1981.
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         types of studies.   Provide a listing of  or estimate the types  and
         number of modeling analyses performed by a source (or its  contractor)
         that were reviewed by the State or local agency  during the audit
         period.

     b.  Does the State/local  agency have access  to an  assortment of models
         and data bases (e.g., computerized files of ambient monitoring data
         and meteorological data)  which  is appropriate  to its air quality
         analysis needs and responsibilities?  How accessible are they, i.e.,
         university, State, or in-house?  List on-line  models available to
         the modelers.

     2.  Has the State/local  agency consistently  demonstrated in its submittals
to EPA the ability and willingness to assure satisfaction of the spirit and
intent of the EPA modeling  guidelines both in work performed by its own staff
and in its review and approval of  work performed  by others?  In making  this
determination, it is recommended that the auditor consider the following:

     a.  Does the agency routinely follow modeling procedures recommended  by
         EPA?

     b.  In what situations have they deviated from EPA guidance?

     c.  Does the agency routinely contact EPA for approval  prior to
         implementing nonreference procedures?

     d.  Is such contact documented?

     e.  Do the deviations  have a  sound  technical basis?

     3.  Some actual modeling analyses should be  reviewed.  The number  and
types of studies evaluated  should  be tailored to  properly reflect each  State
or local program's level of effort.  Auditors should look to a paper trail  of
the analysis done.  To aid  audit case selection,  the agency should provide
the auditor with a list of  recent  modeling actions taken.  The auditor  will
decide the number of cases  to be reviewed based on available time and the  number
of cases modeled.  The following are typical modeling issues and are provided
as a guide for the audit Co address, as  appropriate:

       EPA Approved Models
       EPA Modeling Guidelines
       Screening Techniques
       Independent Review
       GEP Stack Height Criteria
       Complex Terrain
       Background Data
       Emission Inventory
       Actual/Allowable Emissions
       Significant Impacts
       Fugitive/Secondary Emissions
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     " Receptor Sites
     * Meteorological  Data
     * Noncriteria Pollutants
     * Worst-Case Operating Conditions
     • Downwash Considerations
     • EKMA Modeling

     In summarizing the findings  from this  review,  the  auditor  should  also
address the following  questions:

     a.  How well is each air  quality analysis  documented  and  retained?

     b.  Are the reviews of outside analyses  (industrial or  contractor)
         documented and retained?

     c.  Is the documentation  sufficient  to allow  another  modeler  to  replicate
         the analysis?

SIP EVALUATION AND IMPLEMENTATION

     An evaluation of  SIP development and implementation activities  is necessary
to assess whether State plans  for attainment  and maintenance of standards
remain responsive to identified needs and are being reasonably  carried out.
For this first year attempt at  implementing a National  Air Audit System,
certain key elements (see audit questions)  of specific  SIP strategies
have been singled out  for evaluation.  As discussed in  the preamble to this
document, focusing the NAAS review on these areas  is not intended  to  preclude
the auditor from evaluating other aspects of  major SIP  activity in an  air
program.  Nor does it  imply that  all  other SIP  responsibilities are considered
less important.  Rather, it represents  an attempt  to isolate a  manageable
number of SIP-related  efforts  for national  review  and comparison.

     Additionally, although there are no  specific  questions  to  follow  on this
subject, another important  aspect of this audit topic involves  the determination
of whether responsibilities within the  State/local  program are  adequately
defined to assure the  timely adoption and implementation of  SIP requirements.
In general, this requires that  a  particular individual  (or group)  be  designated
at the State and local agencies to maintain adequate coordination  among the
various SIP planning and implementation groups  (i.e., ambient  monitoring,
modeling, engineering, enforcement).  The responsible person(s) must  be
capable of taking the  output from these departments through  the administrative
process that typically leads to adoption  of control measures in the SIP.
Accordingly, where a review of  the audit  criteria  results  in a  negative
response, the auditor  should not  only identify  the specific  deficiency but
also attempt to explore and locate where  the  breakdown  occurs.   The audit  is
intended to provide more than  a compilation of  shortcomings  of  the air program.
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Audit Questions

     1.  Have all required regulations  and  emission  limits  for  stationary
sources of criteria and Section  lll(d)  pollutants  relied  upon in  the proposed
or approved SIP strategy (e.g.,  RACT  for  sources of  VOC covered by CTG's and
other 100-ton sources,  RACT for  TSP)  been submitted,  or is  satisfactory progress
occurring?  List required submittals  that were  not  received during the  reporting
period and indicate what progress  was made.

     2.  Have additional studies (e.g., nontraditional TSP,  CO  hot-spots)
approved as part of SIP control  strategies  been carried out? List the  ones
that came due during the review  period, identify the  stated objective,  and
indicate whether they were completed  on schedule and  in a satisfactory  manner.

     3.  Has each variance, bubble, or other  site-specific  SIP  revision been
developed consistent with EPA criteria?^/  Identify  problems (if  any) and
list any actions of this nature  by the State  or local  agency that should have
been submitted to EPA as SIP revisions  but  were not.

     4.  If the SIP contains any approved generic  emissions  trading provisions,
have individual transactions been  processed in  accordance with  those require-
ments?  The following documents  and memorandum  provide guidance and establish
policy on emissions trading.

     * Emissions Trading Policy, Statement  and  Issues.  Document, April 7,
       1982, 47 FR 15076.

     * Memo from Sheldon Meyers, Director,  OAQPS to  Regional  Air  Division
       Directors, February 17, 1983.   Emissions Trading Policy—Technical
       Clarifications.

     * Guidelines for Oversight  of State  Generic Emissions  Trading Rules:
       (draft), October 15, 1982,  Regulatory  Reform  Staff,  Office of Policy
       and Resource Management.

     5.  If applicable, are transportation  control measures  being implemented
in accordance with the SIP?  What  are they? Highlight  how the State/local
agency maintains involvement to  assure implementation.
3/ The "Air Programs Policy and Guidance Notebook"  prepared  by  OAQPS  provides
  the current EPA policies applicable to these  types  of  actions.
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     6.  Where credit for an inspection and maintenance (I/M)  program has
been claimed, is the program being implemented in  a  manner  consistent
with the claimed emission reductions  in the approved SIP?   Specific
program areas to be considered include:4_/

     • inspection test procedures;

     * emission standards;

     * inspection station licensing requirements;

     * emission analyzer specification and maintenance/calibration
       requirements;

     * recordkeeping and record submittal  requirements;

     * quality control, audit, and surveillance procedures;

     * procedures to assure that noncomplying vehicles  are  not
       operating on the public roads;

     * any other official program rules, regulations, and procedures;

     * public awareness plan; and

     ' mechanics training program if  additional emissions  reduction
       credits are being claimed for  mechanics training.

     7.  In the case of Part D SIP's  that  have been  "conditionally  approved"
or "approved with the understanding,"  have the schedules contained  in the
plan for rule adoption and implementation  been adhered  to?   List  the  schedules
that the State or local agency are on  and  summarize  status/progress,  as
appropriate.

     a.  If schedules have been missed, is slippage  reasonable and  justifiable?

     b.  Is someone responsible for assuring that  no further slippage occurs?

     c.  Was any consideration given  regarding the impact on the  attainment
         date?
4/ The Office of Mobile Source Air Pollution  Control  (Ann  Arbor,  Michigan)  can
   be contacted for additional guidance on  specific audit  procedures/considerations
   for each of these program elements.
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     8.  For extension areas,  does  the  State/local  agency  have  a  satisfactory
system for tracking RFP for ozone and carbon  monoxide?   Please  describe.   In
particular, what is the mechanism for documenting  emission reductions  claimed
in the required RFP report  and assuring that  they  are consistent  with  inventory
and/or enforcement data?

     9.  Are there activities  to substantiate that  the  emission reductions
claimed in the SIP are in fact being  achieved in practice  (e.g.,  VMT surveys
for TCM's and emission reduction verification inspections  for major VOC
categories)?

    10.  Does the State/local  program periodically  determine  if the growth
projections contained in the SIP occur?  Are  they  considering whether  area,
major, and non-major point  source growth are  within the SIP's projections?
If growth is exceeding projections, what additional  measures are  going to  be
implemented to make up this shortfall?

    11.  For areas lacking  a fully  approved attainment  strategy,  are the
State/local agencies taking necessary steps toward  correcting the deficiencies
considering the magnitude of the ambient air  quality problem and  the nature
of the deficiencies?  List  areas falling into this  category and describe
State/local program efforts to reconcile the  problem.

     a.  Is the State/local agency  aggressively  pursuing correction of each
         substantive deficiency for those areas where actual  violations of
         primary NAAQS's are believed to be occurring?   Please  describe.

     b.  Where deficiencies of a minor  or nonsubstantive nature are present,
         is there an agreed-upon plan for eventual  correction?   Give examples.

     c.  Where litigation or other  legal problems  are a major obstacle to
         correction of SIP  deficiencies, does the  State/local agency appear
         to have adequate legal representation or  to otherwise  be involved in
         a fashion likely to contribute to early resolution of  the issues?
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                  3.  NEW SOURCE REVIEW AUDIT GUIDELINE
INTRODUCTION

     The preconstruction review of new and modified stationary sources is
an important part of an effective air pollution control program.  By
ensuring that potential new and modified sources of air pollution meet
stringent standards of control, the preconstruction review supports
efforts to improve air quality in nonattainment areas, and serves to
prevent the recurrence of old air quality problems and the creation of
new ones.

     Under the Clean Air Act, preconstruction reviews are conducted primarily
by State and local air pollution control agencies.  This is consistent
with Section 101(a)(3) of the Act which says that the prevention and
control of air pollution at its source is the primary responsibility of
State and local government.  However, the Act in Section 301(a)(2) also
imposes a concurrent responsibility on EPA to ensure that such reviews
are conducted in an effective manner throughout the Nation, so that the minimum
requirements of the Clean Air Act are met.  These mutual obligations
require EPA, State and local governments to treat their responsibilities
seriously and with respect for each other's proper role.

     Some of the audit questions raised in this section involve, in whole
or in part, issues that could be affected by proposed EPA rulemaking or
ongoing litigation [e.g., CMA agreement rulemaking proposed on August 25,
1983 (48 FR 38742)].  These particular questions, identified by an asterisk [*],
identify those current requirements which are potentially impacted by
regulatory amendment.  Should changes to the affected requirements be
promulgated, EPA will issue revised guidance as to how the audit should
handle them.  Until such time that the existing federal requirements and
the State rules developed pursuant to these 40 CFR Part 51 provisions can
be changed, this guideline will assume that all rules will continue to be
implemented under the requirements presently in effect.

AUDIT PROTOCOL

     As discussed in the general introduction to the FY 84 NAAS guidance,
one of the recommended phases of the audit process is the file review
which occurs during the onsite visit.  For the new source review audit,
permit files should be selected on the basis of permit action type,
source type and size, source location, public concern, and other factors
geared to selecting a variety of permitting actions and decisions by the
agency.  Selection criteria to consider include:

          * Review new plants, replacements, and expansions;

          * Review both large (major) and small (minor) sources;

          * Review both PSD and non-PSD sources;
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          • Review sources which escaped PSD by  permit  restrictions
            on hours of operation or capacity;

          * Review some of the most  common source types  in  that  State
            (for example,  boilers and asphalt  plants),  but  also  review
            a variety of other source types;

          * Review a PSD source near a Class I area;

          * Review some sources in nonattainment and  sanctioned  areas,
            if applicable; and

          * Review a controversial permit, a permit  of  high public
            interest, or one that would be of  particular interest  for
            reasons other than those described above.

     By combining several  of these factors in  one permitting action,  all
the criteria above could be satisfied with only  a few  (less than 20)  permits.
It is advisable that, during the file review,  persons  responsible  for
reviewing permit applications be available to  answer  questions.   Ideally,
the individual permitting engineer would be available.

ADMINISTRATIVE PROCEDURES

     Administrative procedures are important in  the  preconstruction  review
process because they guarantee, to both sources  and  the  general  public,
that due process shall  be followed in the review. Moreover, especially
for major sources, specific statutory or regulatory  requirements govern
the procedures in such  areas as public notice.

     General agency procedures which affect the  following issues should
be discussed with the State or local agency at the time  of  the audit.
In addition, evidence that these procedures were actually followed should
be looked for in the course of the permit *ile  review.

Audit Topics

Public Participation and Notification --

     Public participation requirements for review of  new and modified
sources are set forth under 40 CFR 51.18(h) and  5l.24(q).  These requirements
call for the issuance of a public notice which  informs  the  public  of  a
pending permit action and of the opportunity for public  comment  or hearing
prior to final agency action on a source application.   The  auditor should
evaluate various phases of the agency's public participation procedures
to determine whether adequate opportunity for  public  participation is
being afforded.
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     The following inquiries on public participation  and notification  should
be made:

     1.  For which new or, modified sources  was  the  public afforded  an  opportunity
to comment on proposed permits?

     While the public participation requirements  under 40 CFR  51.24(q)
apply only to major PSD sources, §51.18(h)  specifies  no source cutoff
which would limit the public participation  process  to a specific  size
source or larger.  It is believed, however, that  in practice most State
and local agencies do not attempt to provide public notice for each
permit issued.  This would be particularly  true of  the minor sources
whose impact on the ambient air quality would be  minimal.  In  an  effort
to advise EPA of the appropriateness of the State or  local  agency's  current
procedures, the auditor should determine what criteria the agency uses to
subject a permit review to public scrutiny.  In particular, the auditor
should determine whether, at a minimum, all major source permits  as  defined
in Parts C and D of the Clean Air Act are required  to undergo  public
review prior to the issuance of their final permit.

     2.  Do the public notices routinely provide  adequate information  to
satisfy the agency's public participation requirements?

     The public notice should inform the public of  the availability  for
their inspection of the application submitted by  the  source, the  estimated
impact of the source on ambient air quality, and  the  agency's  proposed
action to approve or disapprove the permit.  Instructions for  submitting
comments, as well as the opportunity for a  public hearing,  should also be
addressed.  The auditor should verify that  notices  issued by the  agency
adequately inform the public of the permit  being  considered and of their
opportunities to provide input to the final determination.

     3.  Were other State and local air pollution control agencies and other
officials whose jurisdictions might be affected by  the proposed new  or
modified source adequately notified of the  proposed action?

     In addition to providing adequate notice to  the  public in general,
certain parties are to receive specific notification  of proposed  permit
actions where those parties would be directly affected by the  proposed
source.  The auditor should verify that the agency  has, and uses, a mechanism
for notifying the appropriate government officials  when the proposed
source may affect their jurisdiction.  The  auditor  should particularly
note, in the case of PSD sources, whether and at  what point in the process
the Federal Land Manager (FLM) is notified  of any pending agency  action
on a source locating within 100 km of a Federal Class I area.   In addition,
the auditor should identify, for information gathering purposes,  any
other criteria used to determine whether FLM notification is necessary.
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Application Documentation and Determination  of  Completeness  --

     Good documentation concerning PSD  determinations  is  necessary  because
of the obligation in Section 165 of the Clean Air Act  to  facilitate the
potential review of all relevant information  by the  public and  to limit
the processing time for PSD permits to  one year.   However, it  is  generally
good practice in any event to notify all  permit applicants promptly both
of deficiencies in their application and of  the satisfaction of these
deficiencies when this occurs.

     The following questions on application  documentation and  completeness
should be asked:

     1.  Is there a review to see if a  company's  permit application is
complete?  If so, is the company informed promptly concerning the status
of its application?

     For PSD, the Clean Air Act in Section  169  uses  the submittai date
of a complete application as the basis  for  establishing the  baseline
date.  The agency is also expected to notify  the PSD applicant  within a
reasonable time period as to the completeness of the application  or any
deficiency in the application.  The auditor's primary  concern  is  to determine
whether routine completeness checks are made  on PSD  permits  and whether
the applicant is notified of the status of  the  application.

     2.  Is a formal record kept on file which  documents  agency action with
respect to a permit application (e.g.,  receipt, completeness determination,
technical staff review, preliminary staff determination,  final  determination)?

     Recordkeeping procedures will vary from agency  to agency;  however,
there should be some formal method of recording the  progress of an  application
through an agency's formal review process.   In  addition,  the agency
should be able to demonstrate an ability to  gather information  in a
timely fashion from its files to support the  critical  decisions made for
a given permit.  Such recordkeeping can be  useful  to the  agency itself
for minimizing the review time for each permit  and for streamlining the
review process where desirable.

Conformance with Part D Requirements for Compliance  by Existing Sources
Owned by the Applicant --

     1.  For major new or modified sources  which are subject to Part D
of the Clean Air Act (nonattainment area major  sources),  has the  agency
ensured that other sources owned by the applicant are  in  compliance, or
on a compliance schedule, with applicable SIP  requirements?

     Section 173(3) of the Clean Air Act contains the  provision concerning
compliance by other sources owned by an applicant for  a permit  to construct
and operate a major source in a nonattainment  area.   Generally, the
applicant must demonstrate that this provision  is satisfied.   Although no
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EPA policy has been provided as to how Statewide compliance must  be  demon-
strated, the auditor should verify that evidence exists  in the permit
file that the applicant has made such a determination.   Information
collected will be used in part to assess whether policy  guidance  in  this
area should be issued.
APPLICABILITY DETERMINATIONS

     State and local agencies are expected to strive for the level  of
consistency needed to satisfy the minimum Federal  requirements  for  subjecting
new and modified major sources to preconstruction  review.  Specific audit
objectives are:  (1) to determine whether the permit agency is  subjecting
major source construction to at least the minimum  Federal requirements  of
PSD and NSR regarding source size and geographic location;  (2)  to determine
what requirements may apply to sources exempted  from all or part of the
permit review and what measures exist to protect against permit circumvention;
(3) to gather information pertaining to methods agencies use to discover
proposed construction projects which may be subject to permit review; and
(4) to determine whether major projects were approved for construction  in
designated nonattainment areas subject to the construction  moratorium
(40 CFR 52.24).

Audit Topics

Source Discovery System --

     1.  What are the formal mechanisms used by the agency  to ensure that
applicable sources submit construction plans for formal  review  and  approval
prior to beginning their proposed construction?

         For this audit category, the auditor should collect information
pertaining to the permit agency's source discovery system and information
pertaining to the system's benefits in subjecting  sources to permit review.
Where no formal discovery system exists, the discussion  should  focus on
reasons why the agency feels a formal discovery system is not needed.
EPA will compile this information, and make it available to all State and
local air pollution control agencies.  EPA will also assess the need for
a formal requirement in this area.

Review Applicability --

     State and local governments are expected to regulate both  "major"
and "minor" construction of air pollution sources.  The  auditor should
verify, through discussions with agency personnel  and the review of
selected permit files, that the appropriate levels and detail  of review
are being made.
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     1.  Does the agency apply  the proper Federal  definition(s)  of  "source"?

     Agencies must use,  as a minimum,  the appropriate  Federal  definitions
of "source" to make applicability  determinations.   The number  of definitions
used by any particular agency will  depend upon  the specific  Federal  NSR
requirements being implemented  by  that Agency under an approved  SIP  or
delegated authority.   The auditor  should  consider  the  following:

     For PSD, the agency should use a  reasonable  grouping  of emissions
units as one stationary  source, classified according to its  primary  activity,
ii .e., same two-digit  SIC code.   The industrial  grouping will determine
the applicable emissions threshold (100/250 TPY)  governing major source
status.

     For nonattainment areas, including areas where the construction
ban (40 CFR 52.24) is in effect, one of two possible definitions of  source
should apply.  That is,  either  the plantwide definition, as  described  for
PSD above, or the dual definition  which considers  a "source" to  be  both
the plant and each of its individual pieces of  process equipment.   Because
of the August 17, 1982 (NRDC v. Gorsuch), court ruling against EPA's
October 14, 1981, rulemaking to delete the dual source definition  and  the
pending review of this case by  the Supreme Court,  this year's  audit  will
stress adherence to a source definition wh^ch is  at least  as stringent
as the definition contained in  the agency's approved SIP,  i.e.,  plantwide
or dual source definition.  The auditor,  in any event, should  identify
the definition actually  being used by  the agency  and report  it for
information gathering purposes.

     For NSPS and NESHAPS, the  applicable "sourc0" is  defined  by various
subparts of 40 CFR Parts 60 and 51, respectively.   The auditor should
verify that the NSPS/NESHAP applicability determinations are made  independ-
ently of the PSD or nonattainment  NSR  determinations.   This  is particularly
important where the PSD  or nonattainment  NSR requirements  do not apply,
e.g., "minor sources," "major sources," but de minimi's  net  increases  for
the pollutant of concern, or where exemptions from the PSD or  nonattainment
NSR requirements are otherwise  granted by the agency.

     The following should be emphasized for major  sources:

     2.  Does the agency use typically the best available  emissions
projections and federally enforceable  restrictions)!*]  in defining a  new
major source's (or unit's) "potential  to emit"?

     The permit agency should screen routinely  the pmissions calculations
and related information  provided by the applicant.  Emissions  should be
calculated using reliable emission factors.  In addition,  permit restrictions
that limit design capacity utilization should be  documented  clearly  and
made an enforceable part of the permit.
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     3.  Does the agency routinely use an existing source's "potential  to
emit" to determine major source status for proposed modifications?

     Major source status must be based on a source's maximum design
capacity, which may take into account all control  equipment and operating
restrictions which are federally enforceable.[*]  (See PERMIT SPECIFICITY:
Permit Conditions, #4.) The potential to emit  may  be overlooked,  particularly
when actual emissions are significantly less than  the applicable major
source cutoff size. The auditor should inquire about agency policy and
procedures in this regard and review several permits for modifications
which did not undergo review for PSD or nonattainment NSR.

     4.  Does the agency use as its netting baseline actual, TPY emissions?!!*]

     Once the major status of the existing source  has been  affirmed,  the
applicability review of proposed modifications should be based on the net
change in actual emissions on a tons-per-year  basis.  Actual emissions
estimates generally should be based on either:  (1) reasonable engineering
assumptions regarding actual emissions levels  and  representative facility
operation over a two-year period, or (2) federally enforceable emissions
limitsC*] which are determined on a site-specific, case-by-case basis so as
to be representative of actual source emissions.  Where an  emissions  unit
has not begun normal operations, the potential to  emit of the unit should
be used.

     5.  Verify that the agency does not allow for "double  counting"  of
emissions decreases used for netting purposes.

     Adequate safeguards should be taken by the agency to prevent the
use of contemporaneous decreases in actual  emissions if the decreases are
not creditable.  For one, contemporaneous emissions decreases should  be
surplus and not credited more than once.  No decrease previously relied
on by a PSD source can be considered again in  determining the net change
of a current or future modification.  In addition, no emissions reduction
which has occurred or is scheduled to occur pursuant to the SIP's attainment
strategy can also be counted for netting purposes.  Finally, in nonattainment
situations, no reduction relied on previously  to meet the reasonable
further progress requirement of Part D of the  Clean Air Act can be used
for calculating emissions.  The auditor should inquire about the agency's
policy and procedure for preventing double counting and should request
any examples of situations in which double counting was disallowed.  It
may be difficult and tedious for the auditor to discover independently
any cases involving double counting; therefore, such efforts are not
recommended.

     6.  Does the agency adequately address fugitive emissions[*] in
calculating the "potential to emit" and the "net emissions  increase"?

     Fugitive emissions, to the extent they are quantifiable and
emitted by any of the 28 listed source categories, should be included in
the emissions calculations for determining whether a source is major.
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For other source categories,  the source first  must  be  considered  major
before fugitive emissions are counted in the potential  to  emit.   The
auditor should verify that the emissions factors  used  to calculate  fugitive
emissions are documented and  reviewed by the agency  independently from
any use of such factors by the applicant.

     The following questions  should be asked concerning geographic
applicability.

     7.  Does the agency properly apply the §107  area  designations  when
determining what type of preconstruction review will  be required  of major
construction?

     In general, all  major construction should be required to undergo
PSD review for all regulated  pollutants emitted in  significant  amounts
when the area of proposed construction is designated  as attainment  or
unclassifiable in the SIP for at least one criteria  pollutant.  Exceptions
to this rule apply to exempted sources and pollutants.   In the  latter
case, nonattainment NSR requirements would apply  for  each  nonattainment
pollutant emitted in  major quantities.

     8.  Verify that  the agency does not approve  major construction
projects in designated nonattainment areas under  an  EPA-imposed
construction moratorium.

     While minor source growth is not affected by the  imposition  of
a construction moratorium, new major sources or major  modifications (i.e.,
major with respect to the nonattainment pollutant)  must not be  permitted
to construct during the effective period of the moratorium.  Exceptions
to this rule that are found to exist should be identified.

     For minor source categories, the following question should be  asked.

     9.  Does the agency issue permits to "minor" construction?

     The permit agency should have some program to  review  new and
modified projects whose emissions do not require  a  "major" review  .  The
designation of "minor" would  include sources whose  net emissions, after
considering the appropriate contemporaneous emissions  changes,  do not
exceed the prescribed significance levels and, therefore,  are not subject
to PSD or nonattainment NSR requirements prior to approval.  The  auditor
should identify the typical level of review given to  "minor"  construction.

     The following questions  should be asked concerning permit  exemptions.

     10.  For sources exempted from both PSD and  nonattainment  NSR  requirements,
does the agency continue to apply other permit requirements?
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     11.  Are all exempted sources subject to some type of registration
system?

     A number of legitimate exemption provisions exist.  Examples of
such exemptions include nonprofit health and education institutions (when
requested by the Governor); existing sources undergoing routine maintenance,
repair, or replacement; and existing major stationary sources where construc-
tion results in no significant net emissions increase.  Even though these
exemptions may be allowed, other preconstruction review and permit require-
ments generally apply to major sources.  The permit agency should at
least account for such sources in the emissions inventory and be aware of
the control devices in use, as well as specific source operating conditions.
The auditor should verify that the agency employs reasonable mechanisms
to ensure at least a minimal review of "exempted" sources.

Permit Circumvention --

     The audit should verify that the following practices are not allowed:

     Fragmented permit applications -- Can a source divide its construction
plans into a series of applications in order to avoid major review?

     Permit modifications -- Can the substantive conditions within
the construction permit be overridden without new analyses of the affected
provisions or public notification?  EPA will also be collecting information
on the appropriate criteria for processing proposed permit modifications
and the need to formalize such criteria.
BACT/LAER DETERMINATIONS

     The primary objective is to assure that good,  well-supported,  BACT/LAER
determinations are made across the nation.  Secondary objectives  are to
measure the frequency of BACT/LAER determinations set equal  to existing
new source performance standards, and to determine  the amount  of  legitimate
attention being given by review agencies to the requirement  for the
application of LAER on new and modified major sources constructing  in
nonattainment areas.

Audit Topics

Pollutant Applicability --

     1.  Does the BACT analysis consider each regulated  pollutant emitted  in
significant amounts?

         Pollutants regulated under the Clean Air Act are subject to a
BACT analysis if they would be emitted in significant amounts  by  the source
construction subject to PSD.  A pollutant subject to regulation under the
Clean Air Act generally has had a standard of performance under 6111 or
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112 and/or NAAQS promulgated for it.   The analysis  for the subject  source
should address both fugitive and nonfugitive emissions.   The auditor
should verify that the BACT analysis  considers  all  significant  emissions
increases rather than being restricted to criteria  pollutants  or major
emissions changes.

Control Strategy Alternatives for BACT --

     1.  Does the review agency require the  consideration of more than
one control  alternative? To what extent are  economic,  energy,  and non-air
environmental impacts considered in  the BACT analysis?

         In selecting BACT, the applicant generally should consider more
than one control strategy,  unless it  can be  demonstrated  that  the single
proposed strategy clearly represents  the highest  degree  of continuous
emissions reduction available.  In all cases, the control strategies
considered should be technically feasible and should address the economic,
energy and environmental impacts of  the particular  alternative.  Quantifiable
impacts should be identified.  The auditor should verify  that  adequate
alternative control strategies are included  where appropriate.

     2.  What checks does the review  agency  employ  to confirm the BACT
analysis?

         In each case, the BACT analysis submitted  by the applicant must
be reviewed independently by the permit agency.  In particular, candidate
control equipment should be assessed to ensure  that reasonable performance
claims, including consideration of continuing compliance, are  being made.
Where the alternative representing the most  stringent emission  reductions
is not selected, the permit agency should review  carefully the  alternatives
to ascertain that the most appropriate one was  used.  The agency should
routinely check to see whether any technically  feasible  alternatives were
not considered, and why.  The auditor should verify that  the agency
performs an adequate independent review of the  BACT analysis submitted by
the applicant.

BACT/LAER Baseline --

     1.  What tendency is there for the agency's  BACT/LAER determinations to
conform exactly to minimum EPA requirements?

     For each permit reviewed, which  was subject  to BACT  or LAER, the
auditor should note the regulatory baseline  assumed by the review agency.
In how many instances do the agency's BACT/LAER determinations  conform
exactly to existing SIP, NSPS, or NESHAP requirements?  The auditor should
verify that adequate documentation is provided  for those  determinations
which simply meet the minimum requirements.   For  cases where LAER deter-
minations conform exactly to NSPS, the auditor  should examine the reasons
why LAER was not determined to be a  more stringent  limitation.
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     2.  Does the review agency make use of  the  BACT/LAER  clearinghouse?
Has the clearinghouse been found to provide  useful  information?

         The BACT/LAER Clearinghouse is  intended to serve  a  number  of
useful  purposes,  namely, (1) to provide  State  and local  agencies with
current control  technology determinations,  (2) to summarize  recent  deter-
minations for sources of similar size and nature, and  (3)  to  provide data
on the emission  limits imposed on new and modified sources.   For the
purpose of providing feedback to EPA, the auditor should get  information
from the agency  regarding the extent to  which  the clearinghouse  is  used,
ways to improve  it,  and the reason(s) for any  decision  not to participate
in the program.   As  participation in the clearinghouse  is  voluntary, the
auditor must avoid any criticism of nonparticipation.

AMBIENT MONITORING

     The audit of ambient monitoring procedures  is important  in  order  to
achieve a level  of consistency which assures compliance with  minimum
Clean Air Act requirements for the submittal of  preconstruction  ambient
monitoring data  by PSD sources.

Audit Topics^

Data Submittal Criteria --

     1.  Under what  circumstances is a source  required  to  submit preconstruction
ambient monitoring data?

         Every PSD source with significant  emissions of a  particular criteria
pollutant, where  both the existing air quality and the  impact of the source
or modification  are  significant, must submit data,  unless  exempted  under
provisions for temporary emissions or compliance with the  Offset Policy.
Only PSD sources  are required to submit  such data.   The auditors should
check enough files to audit at least one source  where the  preconstruction
lln general,  State and local  agencies  should  implement  air  monitoring
procedures for PSD in a manner consistent  with  EPA's  "Ambient Monitoring
Guidelines for Prevention of  Significant Deterioration  (PSD),"  as  revised
February, 1981.  The air monitoring audit  topics  for  FY  84  touch on  only
a limited portion of those contained in the PSD Monitoring  Guideline.
However, in addition to covering the three specific audit topics identified
herein for FY 84, the auditor should discuss  the  monitoring guideline
with each audited agency in order to evaluate its adequacy,  and to
identify specific air monitoring topics that  would be appropriate  for
the FY 85 audit.
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monitoring requirement was likely  to have applied.   In  addition,  for PSD
sources not required to submit data, the applicable  exemption  should be
clearly stated in the preliminary  determination.

Representative Data vs. Source Monitoring --

     1.  Under what circumstances  may a source  submit  representative
existing data, rather than conduct new monitoring?

     Use of representative data is restricted  by  the criteria  described
in the Ambient Monitoring Guidelines for PSD.   Generally,  only new
sources in remote areas may use existing data  gathered  at  sites greater
than 10 km away.  For all sources  in flat terrain, monitors  within
10 km are acceptable.  For complex terrain the  guidelines  are  very
difficult to meet, and new data is almost always  required.   In addition to
the monitor location criteria, there are also  restrictions  concerning
data currentness and quality.   The auditor should be familiar  with  the
guidelines concerning representative data and  verify that  the  audited
agency is following them.

Quality Assurance of PSD Ambient Monitoring Data  --

     1.  Do the source monitoring  data adhere  to  PSD quality assurance
requi rements?

     The Ambient Monitoring Guidelines for PSD  contain  minimum quality
assurance requirements for PSD monitoring. The detailed criteria for
quality assurance should not be audited by the  new source  review  auditors.
The Regional ambient monitoring staff should audit quality  assurance
procedures.  It is important that  the two groups  discuss in  advance the
division of responsibility of  audited areas, to avoid  overlap  or  omissions.
The new source review auditor  should determine:   (1) whether a monitoring
plan was submitted by the source and evaluated  by the  permitting  agency;
(2) whether a quality assurance plan was submitted by  the  applicant; and
(3) whether the permitting agency  evaluated the data for compliance with
40 CFR 58 Appendix B.

AMBIENT IMPACT ANALYSIS

     Before a permit is granted, the permit agency must verify that no
national ambient air quality standards will be  violated.  In the  special
case of a PSD permit, the agency must further  verify that  no allowable
PSD increment will be exceeded by  the source under review.   In both cases,
the ambient impact analysis must be reviewed carefully  by  the  permit agency
responsible for managing the ambient air quality  levels.  The  auditor should
determine the adequacy of the  ambient air analysis performed as part of  the
preconstruction review.
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Audit Topics

PSD Increment Consumption —

     Allowable PSD increments exist only for SC>2 and TSP at the present
time.  There are a number of important considerations that the permit
agency must routinely take into account in order to ensure that the maximum
allowable increments are not exceeded.  The permit agency must give the
proper attention to such things as the baseline concentration, the appropriate
emissions changes for increment consumption purposes, long and short-term
increment averaging periods, and special Class I area impacts.

     1.  Does the agency adequately consider the baseline concentration and
emission changes which affect increment consumption?

     The baseline concentration generally reflects actual emissions
occurring at the time of receipt of the first complete PSD application in
the §107 attainment or unclassifiable area.  This ambient concentration
is adjusted to include projected emissions of major sources commencing
construction before January 6, 1975, but not in operation as of the baseline
date, and to exclude the impacts of actual emissions changes resulting from
construction at a major stationary source commencing after January 6, 1975.

     Changes in emissions contributing to the baseline concentration
from any source subsequent to the baseline date and from any major source
construction commenced after January 1, 1975, can either consume or
expand the PSD increment.  Where actual emissions cannot be used,  i.e.,
the source has not yet begun to operate, or sufficient operating data is
not available, then allowable emissions must be used.  The auditor should
verify that the agency considers the appropriate emissions changes relative
to the baseline concentration.

     2.  Does the agency perform or have plans to perform periodic assess-
ments of PSD increment consumed?

     Often the increment assessment is done only on the sources that
have been subject to PSD.  Periodically, the reviewing agency should
assess the increment consumption of all increases in emissions, including
minor and area sources.  Frequency of such assessment will depend  to a
large degree on the growth rate of the area involved.  Also, prior to any
SIP relaxations involving a change in emission limitations, the emissions
changes must be assessed to verify that the PSD increment(s) would not be
violated.

     3.  Are long and short-term PSD increments being given adequate
consideration as part of the ambient impact analysis?

     Both TSP and S02 have long and short-term averaging periods for
which PSD increments have been established.  These maximum allowable increases
are not to be exceeded more than once per year for other than an annual  time
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period.  The auditor should verify  that  the  application  considers  each
averaging period with complete documentation in  the  permit  file.

     4.  Does the agency allow any  exclusions  from increment  consumption?

     Agencies with PSD rules in their SIP  may  consider the  exclusion
of certain emissions from the increment  analysis.   These exclusions  are
described in 40 CFR 51.24(f).  The  auditor should  verify that  where
exclusions are granted they are implemented  consistent with the  federal
criteria.

     It should also be noted that an  agency  which  conducts  the PSD program
under authority delegated by EPA cannot  utilize  the  exclusion  provisions
unless a request from the governor  to do so  was  made before May  7, 1981.
(See 45 FR 52719, August 7, 1980.)  The  auditor  should verify  that only
eligible agencies are utilizing the provisions for excluding  certain
emissions from increment consumption.

     5.  Does the agency make an adequate  assessment of  new sources  and
modifications on the Class I area increments?

     For sources proposing to locate  near  a  Class  I  area, an  increment
analysis may be required under conditions  that would not trigger  an  analysis
in any other locations.  Any emissions from  a  proposed source  should  be
considered significant when the source would locate  within  10  km  of  the Class
area and cause an ambient impact equal to  or greater than 1 ug/m3  (24-hour
average).  Generally, sources locating within  100  km of  a Class  I  area
should be screened to determine their impact on  the  Class I area.

NAAQS Protection --

     1.  What emissions baseline does the  agency require to be used  to
evaluate the impact on the NAAQS of new  and  modified sources?

     States may differ as to the emissions baseline  used to protect
the NAAQS.  In some cases, the allowable emissions from  all sources  must
be used for modeling air quality.   In other  cases, the modeled allowable
emissions from the proposed source  or modification are added  to  the  back-
ground air quality which is based solely on  monitoring data.   The auditor
should identify the emissions baseline required  by the agency  and  gain an
understanding of the specific approach utilized  to estimate the  impact of
a new or modified source.  This information  will be  used to assess current
practices and for consideration of  future  policy development.

     2.  Does the agency routinely  evaluate  the  ambient  impact of  minor
source construction?

     Minor source construction is  not likely to  undergo  rigorous  ambient
analysis, even when required to obtain a permit.  Yet the cumulative
impact of numerous minor sources could result  in significant  air  quality
concentrations.  The auditor should determine  the  extent to which  minor
source growth is analyzed routinely in order to  protect  the NAAQS.
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     For FY 84, the audit of modeling procedures focuses on the model
selection process which should be done consistently with the modeling
guideline.  In addition to covering this specific topic for FY 84,  the
auditor should discuss the modeling guideline with each audited agency in
order to evaluate its adequacy, and to identify specific modeling topics
that would be appropriate for the FY 85 audit.

     3.  Does the agency's ambient impact analysis provide adequate protection
against the development of "hot spots"?

     In evaluating the NAAQS, the ambient impact analysis should
determine the maximum long-term and short-term impacts of the proposed
new source or modification beyond its property line.  However, maximum
ambient impact may occur actually at other locations when the impacts  of
other sources and background data are taken into account.  Hot spots may
also occur where growth resulting from minor sources or sources otherwise
exempted from detailed permit review are not subjected to a rigorous ambient
analysis.  The auditor should verify that the agency performs a detailed
analysis of a source's maximum ambient impact beyond those areas of maximum
impact of the source alone.

Dispersion Models2 --

     1.  Does the agency use adequate models to carry out the ambient
impact analysis?

     2.  Does the agency perform an independent, internal review of the
modeling analysis contained in the permit application?

     EPA has recommended the use of a number of models for specific types
of applications and has stated its preference for certain new models for
analyzing the impact of sources on ambient air quality.  However,  utilization
of any particular model should be consistent with the design and intent
of the model itself.  Some models are very specific as to terrain  and
applicability.  The auditor should verify that impact analyses are  being
performed with the appropriate models, and that the permit agency  conducts
2EPA guidance is provided in "Guideline on Air Quality  Models,"  EPA-450/2-
78-027, April 1978.  This report is currently  undergoing revision.   Additional
guidance is also provided in "Regional  Workshops  on Air Quality  Modeling:
Summary Report," OAQPS, April  1981 and  "Guideline for Use of City-Specific
EKMA in Preparing Ozone SIP's,"  EPA-450/4-80-027,  March 1981.   EPA's
"Guideline on Air Quality Models" includes, among other things,  guidance
on the selection of air quality dispersion models.
     For FY 84,  the audit of modeling procedures  focuses on  the  model
selection process which should be done  consistently with the modeling
guideline.  In addition to covering this specific topic for  FY 84,  the
auditor should discuss the modeling guideline  with  each audit agency in
order to evaluate its adequacy, and to  identify specific modeling topics
that would be appropriate for  the FY 84 audit.
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its own independent review of the source's  analysis  to ^nsure con^ormance
to accepted procedures.  In addition,  the auditor should  verify  that  all
PSD modeling is in accordance with EPA guidance,  or  EPA approval  in the
case of nonguideline models, prior to  their usage.


EMISSIONS OFFSET REQUIREMENTS

     Part D of the Clean Air Act intends  that  certain  stringent  requirements
be met by major sources approved for construction in nonattainment  areas.
One such stringent requirement calls for  the proposed  source or  modification
to get emission reductions (offsets) from existing sources  in the area  such
that there will be reasonable further  progress toward  attainment  of the
applicable NAAQS.  In its FY 84 audit, EPA  intends to  ensure that State
and local agencies are carrying out the emissions offset  requirements in  a
manner consistent with the Act mandate.  The specific  objectives  are:
(1) to assure that reviewing agencies  are requiring, where  appropriate,
adequate emissions offsets as a condition to authorizing  major construction
in designated nonattainment areas; and (2)  to  assure that emissions offsets
are being obtained in a manner consistent with RFP.

Audit Topics

Enforceabi1ity --

     1.  Does the agency require that  all offsets be federally enforceable!!*]?

     All emissions reductions used to  offset proposed  new emissions must
be made enforceable.  This is true whether the offsets are  obtained from
another source owned by the applicant  or  from  a source not  under  common
ownership.  In either case the offsets should  be fully agreed upon  and
documented, preferably within the permit  of the source from which the
offset is obtained.  In addition, federal enforceability  requires that
an external offset be made a part of the  applicable  SIP.   This would  require
a specific SIP revision if the offset  is  not made part of a permit  issued
pursuant to the State's construction permit requirements  approved pursuant
to 40 CFR 51.18 or 51.24.  Conditions  to  State or local operating permits
are not always considered to be part of the applicable SIP(s).  The
auditor should verify that all offsets are  well documented, which includes
well-defined emissions limits pertaining  to the emissions offset.

Consistency with RFP --

     1.  Does the agency routinely ensure that the emissions offsets  are
not otherwise needed to show RFP or attainment?

     The proposed emissions offset cannot be otherwise needed to  show
RFP toward attaining the NAAQS.  To use the same emission offsets for two
different purposes would result in "double counting" those  emissions  with
the net result being subsequent deterioration  of air quality. The  auditor
should seek assurance from the agency  that  compliance  with  annual RFP
increments is independent of the offsets  being obtained from proposed new
or modified sources.
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     2.  Does the agency require that the emissions baseline for offsets
is expressed in the same manner as for RFP?

     In order for the system for getting offsets to be consistent with
the demonstration of reasonable further progress, they must both be expressed
in the same emissions terms, i.e., actual or allowable emissions.  Section
173(1)(A) of the Clean Air Act sets the emissions offset baseline as the
"allowable" emissions of the source, but also requires that the offsets
must be sufficient to represent RFP.  Consequently, where the RFP demonstration
is based on an actual emissions inventory, EPA requires that offsets to  be
attained by a proposed new or modified source also be based on actual
emissions.  The auditor should verify that there is consistency in the
emissions baseline for offsets and the RFP demonstration.

     3.  Does the agency's offset requirement cover other emissions
increases since the last offset review?

     In order to comply with the Act requirement that emissions offsets
must be sufficient to represent RFP, any increases in area and minor source
growth not considered in the approved RFP demonstration must be covered  by
offsets required of the proposed new or modified source.  Failure to account
for these emissions increases would result in air quality deterioration
just as in the case of "double counting."  The auditor should verify that
area and minor source growth considerations are made in order to establish
the offset level, particularly when more than one year has passed since  the
last offset.

Timing of Offsets --

     1.  Does the agency require that offsets occur on or before the time  of
new source operation?

     Section 173(1)(A) of the Clean Air Act requires that offsets be
obtained and in effect "by the time the [new or modified] source is to
commence operation."  No specific guidance is available to identify when
a source has officially "commenced" operation.  Some agencies may allow  a
shakedown period similar to the shakedown provision allowed for net emissions
increases in 40 CFR 51.18(j)(1)(vii)(f).  The auditor should focus primarily
on whether agencies routinely seek to get offsets in effect in a timely
manner, which may include for replacement facilities a shakedown period
not to exceed 180 days, and whether the effective date for the offsets is
documented in the agency's files.

     2.  Does the agency allow offsets resulting from early source shutdowns
or production curtailments?[*]

     In general, an agency should not allow emissions reduction credit
for source shutdowns or curtailments which occur before the date of the  new
source application.  The main exception would occur in cases where the new
unit is a replacement for a unit shut down or curtailed at the same plant.
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The auditor should also be aware of other possible  allowances  for shutdowns
under any applicable EPA-approved State emissions  banking or trading rules.
The auditor should attempt to verify that offsets  are actually granted in
accordance with all  specific criteria governing offsets  for shutdowns.

Permanence of Offsets --

     While there is  no clear language in the Clean  Air Act or  in  any
pursuant EPA regulations requiring that emissions  offsets be permanent,
it is clear that emissions used for offset purposes cannot be  allowed
to recur and interfere with a SIP maintenance strategy.   One particular
area of concern is now existing offsets are handled in the event  that a
nonattainment area is subsequently designated attainment.  The auditor
will identify agency policy, for information gathering purposes,  regarding
the permanence of offsets by pursuing the following two  questions:

     1.  Under what  conditions would emissions  offsets not be  considered
permanent?

     2.  What type of source (permit) review would  be required pursuant
to a SIP relaxation  involving emissions offsets?


PERMIT SPECIFICITY AND CLARITY

     This phase of the audit focuses on the final  permit issued by  the
State or local agency to the proposed new source or modification.  The
objectives are:  (1) to assure that permits are issued in a form  which is
clear, concise, and  enforceable; (2) to determine  the extent to which
special terms and conditions are used in the permits;  and (3)  to  assess
the need for federal guidance concerning the specificity and clarity of
permits.

Audit Topics

Source Identification --

     1.  Does the agency identify all emissions units and their allowable
emissions on the final permit(s)?

     Agencies may vary in the number of permits that they issue to  a
source having more than one emissions unit.  No federal  requirements exist
to govern the number of permits which may apply to  any source. What is
important, however,  is that each emissions unit is  identified  clearly along
with its allowable emissions rate, or design, equipment, work  practice or
operational standard, as may be appropriate for the particular source.
It is particularly important, when an agency issues one  permit to a large
complex, that each emissions unit is identified separately along  with its
allowable emissions  rate, as opposed to a singular  composite emissions
rate for each pollutant.  The auditor should verify that, for  each  permit
issued, there is separate and clear identification  of the affected  emissions
units and their corresponding allowable emissions.
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Permit Conditions --

     1.  Does the agency have an established format detailing the compilation
of special terms and conditions?

     Permits issued to certain sources  may entail  special  terminology
unique to that type of source.  These terms may  need to be  defined so that
they may be readily understood.  Also, special  conditions  (such  as those
limiting the way that the source is operated,  specifying how it  and its
required control devices are to be maintained,  addressing  the use of continuous
emissions monitors, or certifying Statewide compliance) may require special
attention in the permit.  These conditions are  essential in that they are
an enforceable means to ensure that the permitted source will  meet its
NSR obligations.  Therefore, they must be added  to  any standard  conditions
which typically accompany the permits issued by  State or local agencies.
The auditor should identify the formats in use  so that EPA  can make such
information available for others to consider using.

     2.  Are the allowable emissions rates stated or referenced  in the
permit conditions?

     In addition to identifying the allowable  emissions, equipment or
other standard for each separate emissions units, it is important that
such limitations be addressed adequately in conditions to  the permit(s)
for a new or modified source.  The auditor should examine  the adequacy of
the conditions in terms of their clarity and enforceabi1ity.  The auditor
should pay close attention to the use of clear  and  precise  averaging periods
over which the various pollutant emissions are  to bp measured.   Also, the
emissions rates  must be consistent with acceptable measurement  procedures;
otherwise, compliance will be difficult if not  impossible  to ascertain
and the conditions would be unenforceable.

     For those situations where emissions limitations are  different from
those specified in the SIP and are not identified in the permit,  the auditor
should note exactly how the allowable emissions  are specified.   The auditor
should seek to determine whether the method used is sufficient to inform
the source and the general public of the binding allowable  emissions
1 imitations.

     3.  Are the compliance test methods stated  or  referenced in the
permit terms and conditions?

     Test methods that will be used to determine compliance of the
source with its allowable emissions rates should be clearly defined or
referenced in conditions to the final permit.   These compliance  tests
should be specific to the individual emissions  units to which  they are to
apply.  The auditor should verify the documentation of the  compliance
test methods and their adequacy for covering each applicable emissions
unit for which allowable emissions rates are defined.  Where test methods
are not specified in the permit, the auditor should determine whether the
SIP specifications are otherwise applicable and  sufficient.
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     4.  If a source's  calculated potential  to  emit  is  based  on  less  than
full  design capacity and continuous,  year-round operation,  are all  limiting
restrictions clearly identified in the permit?

     If the source's calculations assume  less than design  capacity  or
fewer than 8,760 operating hours  per  year,  then any  limits  which  restrict
the operating rate,  or  hours  of operation,  or both,  must  be included  as
permit conditions.  Such conditions are to  be federally  enforceable!]*]
before they can be accepted to lower  the  source emissions.  The  auditor
should verify that all  assumptions made to  limit the operation of the
source below capacity and 8,760 hours per year  are clearly  stated as
requirements in the permit.

     5.  Is the information accompanying  the permit  application  considered
to be enforceable?

     Generally, information contained in  the permit  application  should
be considered an enforceable part of  the  final  permit.   That  is,  a  failure
to meet the source specifications and information provided in the permit
application could represent a violation and therefore invalidate  the  applicable
permit.  In fact, the source's approval to  construct and to operate is
based on information developed pursuant to  the  source-specific information
provided by the applicant.  The auditor should  determine the  method(s)
routinely used by the agency  to incorporate information  from  the  application
i nto the permit.
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                         4.  COMPLIANCE ASSURANCE
INTRODUCTION
     The compliance assurance element of the National  Air Audit System
will examine State and local programs which are responsible for the compliance
of sources subject to:  requirements of State Implementation Plans adopted
to meet national ambient air quality standards (Section 110);  and, where
delegated to the States and local agencies, standards  of performance for
new stationary sources (Section 111); and national  emission standards for
hazardous air pollutants (Section 112).  There are  approximately 30,000
sources in these categories for which EPA shares  a  concern as  to their
compliance status.  Compliance activities directed  to  these sources form
the primary basis for which this audit should be  conducted.

     In order to achieve the goals of the Clean Air Act, it is vital that
State and local agencies are implementing programs  to  periodically assess
the compliance status of these sources and are taking  necessary actions
to return violators to compliance.  The compliance  assurance audit will
examine the success of State and local agencies'  efforts to meet these
goals.

     The major parts of the compliance assurance  element are:

     • Periodic review and assessment of source data

     * Fi le review

     * Overview inspections


PERIODIC REVIEW AND ASSESSMENT OF SOURCE DATA

     Through its Compliance Data System (CDS), EPA  will continue its
present practice of ongoing review of State and local  compliance activities.
It is important that EPA, States, and local agencies continue  a systematic
flow of information into the CDS.  EPA believes that annual review for
detecting violations is too infrequent to properly  ensure that violating
sources are identified and corrected.  Thus, EPA  reviews information on
State and local compliance and enforcement activity at least quarterly.

     Information submitted by State and local agencies for EPA review
should include at a minimum for all Class A^, NSPS, and NESHAP sources:
I/A Class A source is defined as any stationary SIP source whose potential
  uncontrolled emissions while operating at design capacity are equal  to
  or exceed 100 tons per year for any regulated pollutant.  Design capacity
  may be limited through enforceable permit conditions to restrict the
  hours of operation or through physical limitations such as climate or
  season,
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     • The date an inspection or source  test was  conducted  at  a  source
       and the compliance status of  the  source  found  during the  inspection.

     • Identification of any new sources that should  be  added  to the
       inventory and sufficient  information for CDS entry.

     • Any administrative order, consent agreement, or civil or  criminal
       action issued to or brought  against a source in the  CDS inventory
       including any compliance  schedule with increments  of progress.

     * Any compliance status change  of any source in  the  CDS inventory.
       A source is considered to be  "in  violation"  if it  is found to  be
       operating with emissions  in  excess of an air pollution  requirement
       or any substantive requirement of work practice,  operation of
       equipment, or monitoring.

     * Progress in meeting a compliance  schedule  including  any increments
       issued to any Class A, NSPS,  or NESHAPS  source in  the CDS inventory.

     To assess the progress that State or local agencies  are making in
inspecting sources in the CDS inventory, EPA should review  the data
submitted by each State and local  agency. Progress should  be  assessed by
comparing the data with the inspection effort scheduled  at  the beginning
of the year, usually during the  Section  105 grant award  process.  This
agreement should specify the percentage  and type  of source  (A1-A2) that
wi11  be inspected.

     EPA should review data on source compliance  status  changes  submitted
during the quarter.  Special attention should be  given to those  sources
that remain in violation for two consecutive quarters with  no  associated
enforcement action or schedule for  returning them to  compliance.

     Monitoring of State and local  activities and associated compliance
changes in the inventory should  give EPA a basis  for  determining the
effectiveness of a State or local  program.  A State or local program  that
routinely inspects its sources,  identifies violators, initiates  compliance
actions, and shows violating sources moving into  compliance usually has a
normally operating compliance and enforcement program.   A State  or local
program that does not show this  type of  pattern may be experiencing
problems with some part of its program.   This should  be  investigated
thoroughly during the annual visit  to the State or  local  agency  for the
file review portion of the audit.

     In addition to the previously  discussed ongoing  review, and before
the annual audit visit, the EPA Regional Office should furnish each State
or local agency a summary of the status  of sources  in its program for
review and comment concerning the summary's completeness  and representation
of the compliance picture within that  agency.   This summary should be
based on CDS information available  to EPA just  before the annual visit
and consists of:
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     • Progress in meeting agreed upon source inspection targets.

     * Sources whose compliance status has  changed.

     • Progress of sources meeting compliance schedules.

     * Efforts to return violating sources  to compliance.

     After discrepancies are resolved, this compliance summary  should  be
used to describe the status of compliance for sources  in the  audit  report.


FILE REVIEW

     An effective State and local compliance program must have  a well
documented file on each source.  This file  should be available  for  use by
management and field personnel.  The structure and location of  files  are
optional as long as any needed data can be  supplied  upon request.   The
files should contain information supporting the compliance status  of  each
source.  The audit team should review representative samples  of files
kept on sources in that State or local agency.  The  following questions
are examples of information that may be sought.

Organization of Files

     1.  Can the reviewer, from information available  in the  file,  determine
the programs to which the source is subject?  If not,  why?  The various
programs are SIP general, PSD, NSPS and NESHAPS.

     2.  From the information available in  the files,  can the source's
compliance status be determined for all regulations  to which  it is  subject?

Check For Each File

     1.  Does the file contain documentation supporting the source's
compliance status?^  (At a minimum, the date of the  last visit  or  excess
emission report review, person making the compliance determination, and
what that determination was).

     2.  Are all major emission points identified and  each point's
compliance status indicated?
2/For the purposes of this report, the term source is synonymous  with
  facility and consists of one or more emission points or processes.
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     3.  Does the file identify  which  emission  points  are  subject  to  NSR,
NSPS, PSD, and NESHAPS requirements?   If  yes, are  regulated  continuous
emission monitoring (CEM)  requirements  or permit conditions  shown  to  be
in compliance and documented? Are  required  start-up performance tests
included?

     4.  Does the file identify  special  reporting  requirements  to  which  a
source may be subject (i.e.,  excess emission reports from  a  malfunction
or a CEM requirements) and are any  such  reports found  in the file?

     5.  Does the file include technical  reviews,  source tests, CEM
performance specification  tests, permit  applications,  correspondence  to
and from the company, and  other  supporting documentation?

     6.  What methods of compliance documentation  are  used (e.g.,  source
test, CEM, fuel sampling and  analysis,  inspection,  certification,  engineering
analysis, etc)?

     7.  Was the method used  to  ascertain compliance the most appropriate
one for the type of source being documented? Is the method prescribed by
NSPS, NESHAPS or SIP? If not, explain.

     8.  If the documentation includes  an inspection,  does the  report
contain control equipment  parameters  observed during the inspection
(pressure drops, flow rates,  voltages,  opacities)? Were observed  control
equipment operating parameters or CEM emission  levels  compared  to  permit
conditions, design parameters, or baseline observations?   Were  plant
operating parameters recorded?

     9.  If documentation  is  by  a stack  test, were visual  emission
observations or CEM emissions levels  and  operating parameters recorded
during the test?  Was there a quality assurance procedure  used  with a
stack test?  Who conducted, observed,  and reviewed the test?

    10.  Are enforcement actions contained in the  file?

    11.  Are compliance actions  taken in  a timely  manner?  Do any  take
longer than 30 days from the  time of  violation  detection?   If yes, how
long?

    12.  Is there documentation  to  support the  enforcement action?

    13.  Is there documentation  to  show follow-up  to the enforcement
action (reinspection, letter, etc.)?

    14.  Are citizens' complaints documented in the file and followed up?

    15.  What action does  the Agency  take with  respect to  excess emission
reports?
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Checklist For File Reviews

1.  Source Name/Location 	Compliance Status
    State Identification Number
2.  Organization of Files

    • multiple files?  all  programs  identified?
    * chronological index to file (document name/date)
    * missing documents:   	

3.  Sequence of Actions
                                                                  Yes*   No*
    • Is there a logical  sequence,  e.g.,  inspection,  30-day
      follow-up inspection, State NOV,  State order?  Litigation?   	 	
    * Periods of delay?                                           	 	
    • Multiple final  compliance date extensions?                  	 	
    * Repetitive actions?  Increased intensity  of enforcement
      response?                                                   	 	

4.  Adequacy of Inspection Report(s)

      Process and operating parameters  defined?                   	 	
      Regulation and emission limit specified?                     	 	
      Compliance method or inspection procedure specified?        	  	
      Quality assurance identified?                               	 	
      VE readings in accordance with Method 9?                     	 	
      Actual emissions quantified?   If  yes, by  what method?        	 	
      Can compliance be determined?
       For individual points                                      	 	
       For different programs                                     	 	
       For the entire source?                                     	 	
      CEM monitor and recordkeeping procedures  inspected?          	 	
5.  Compliance Status

    * Does file information agree with historical  CDS?
    * What is the current compliance status  in  the file?
6.  State or Local  Actions

    * Timeliness of State or local  action?
       Number of days to take formal  action?
      Action in conformance with formal  State  or
      local procedures?
      State or local  action effective?
      Is compliance logically achieved?
* When appropriate,  provide amplifying remarks  on  back

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7.  Enforcement Actions                                   Yes*   No*

    • What is the most prevalent  enforcement  response?

    • Are penalties considered?                           	   	
    * Is there a reasoned basis for action  or inaction?
8.  Citizen Complaints

    * Adequate follow-up?
     The review team should summarize  their findings  following  the  file
review.  The summary should,  at  a  minimum,  address  the  following  questions.

     1.   Do files exist that reflect  a  reasonable  profile  of the source?

     2.   Do the files contain adequate  written  documentation to  support
the compliance status reported to  EPA?

     3.   Are violations documented and  pursued  to  return the source  to
compliance expeditiously?


OVERVIEW INSPECTIONS

     In order to provide quality assurance  for compliance data  in State
or local files furnished to EPA, and to  promote  effective working relation-
ships between EPA and State or local agencies, EPA  should implement an
overview inspection program.   This program  should ensure consistent
application of regulations and policies.

     EPA should select approximately 2-3 percent of the sources in  the
CDS inventory for an inspection.  EPA  should notify the State and local
agencies of its intent at least  30 days  before the  inspection is  to take
place.  The inspection should be an independent  verification of the
source's compliance status and should  review the State  and  local  inspector1;
procedures for determining compliance  at a  source.   The inspection  should
also be an opportunity for State/local and  EPA inspectors to share  their
skills, to identify their differences, and  to gain  a  better understanding
of the operation and uniqueness  of sources.

     A summary of the results of these inspections  and  State/local  overview
procedures should become a part  of the compliance assurance audit report.
  When appropriate, provide amplifying remarks  on  back.
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                    5.  AIR MONITORING AUDIT GUIDELINE
INTRODUCTION
     An air monitoring quality assurance (QA)  audit program is an integral
part of any effective air monitoring program.   This audit guideline can
be used by an air pollution control  agency  to  increase the effectiveness
of its air monitoring program.  The  air monitoring QA audit program
provides a means to independently check an  air pollution control  agency's
quality control procedures.  Adherence to a comprehensive QA program will
help assure that air monitoring data are representative, complete,
comparable, and of adequate quality  to meet the monitoring objectives.

     Quality assurance audits are conducted pursuant to Federal  regulations
presented in 40 CFR Part 58.  This audit guideline outlines a base  level
program which EPA, State, and local  air pollution control agencies  can
use jointly to:

     * Meet EPA data quality assessment requirements per 40 CFR  Part 58;

     * Minimize loss of air quality  data due to malfunctions or  out of
       control conditions; and

     * Agree on areas where air monitoring  improvements should be made.

Evaluation of an air monitoring program is  accomplished through  the
combination of performance and system audits.

     Performance audits are independent checks to evaluate the quality  of
data produced by the total sampling  and analysis system.  Performance
audits establish individual instrument and  overall agency accuracy.
Performance audits are conducted on  a minimum  of 25 percent of a reporting
organization's* instruments every quarter so that each instrument is
audited at least once a year.  Performance  audits enable a quantitative
appraisal of data quality.

     System audits are on-site inspections  and reviews of an agency's
entire QA program.  It is a qualitative appraisal of an organization,
their written procedures, records, and documentation procedures.  A system
audit may be conducted at any time.

     Each air monitoring agency should establish their QA program according
to their particular needs and to meet the requirements of 40 CFR  Part 58.
It is recommended that each air monitoring  agency develop standard  operating
  See 40 CFR Part 58 for explanation of reporting organization.
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procedures (SOP's) for air quality  monitoring  and  performance  audits.
Written copies of SOP's should be available  to field  station operators
and auditors.  SOP's should be followed consistently  and  updated
periodically.


AUDIT PROTOCOL

Advance Preparation

     Performance and system audit schedule planning  should  be  conducted
well in advance.  A preliminary performance  audit  schedule  listing  the
sites to be audited should be sent  through the appropriate  management
channels of the affected agencies.   The auditor should  then  contact the
individual(s) responsible for the instrument to be audited  at  the  beginning
of each calendar quarter to confirm the scheduled  audit date.   The  auditor
should call again shortly before the scheduled audit  date to arrange the
time and meeting place.  For systems audits, a letter suggesting an audit
date should be sent to the appropriate contact at  least six weeks  in advance
of the audit.  This also should be  followed  up by  a  telephone  call  prior
to the scheduled audit date to confirm time  and a  meeting place.

On-site Visit

Performance Audits--

     The purposes of an on-site performance  audit  are to:

     * Assure that the air monitoring network  design  and  siting is  in
       conformance with 40 CFR Part 58;

     * Assure that an agency's quality control procedures are  being
       followed and are adequate;

     ' Check the instrument's response to known standards to establish
       accuracy;

     • Assure that the instruments  are designated  and operated as  reference
       or equivalent methods in accordance with 40 CFR  Parts 50, 53, and 58;  and

     • Provide the accuracy assessment reports required by  40  CFR  Part 58.

System Audits--

     The purposes of the on-site visit for systems audits are  to:

     * Review the entire quality assurance program;

     * Determine adequacy of staff, laboratory facilities,  and test
       procedures;
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     * Determine if the agency's Quality Assurance Manual  is up to date
       and approved;

     • Determine the adequacy of data processing equipment and facilities;
       and

     * Review the chain of custody of data,  determine whether the official
       air quality data records are secure,  and whether data record alterations
       are formally documented.

On-site visits also allow the auditing staff to become better acquainted
with field personnel and improve communications.

     It is desirable to conduct the on-site  system audits  in the following
distinct phases:

     • Hold an introductory meeting between  the auditors and local agency
       staff.  The purpose of the meeting is to discuss the goals and
       objectives of the audit.  This meeting is to set a  cooperative
       tone and communicate the idea that the purpose of the audit is to
       enable collection of the most reliable ambient air  data;

     * Discuss and/or complete the audit questionnaire (see attached)
       with the person(s) in charge of air monitoring and  data analyses;

     * Review air monitoring files for chain of custody of the collected
       data, documentation of corrective actions,  air monitoring station  logs,
       data processing procedures, etc.;

     * Provide suggestions and provide for a cooperative effort wherever
       possible; and

     * Conduct an exit interview to wrap up  the audit visit and inform
       management of the preliminary results of the audit.

     The time spent by the audit team will vary from agency to agency
depending upon the distance between the sites,  network size, location of
laboratory facilities, etc.

     * Submit a draft system audit report to the local agency with the
       findings of the audit.  This will provide the agency staff opportunity to
       comment at an early stage and resolve any misunderstandings before the
       report is finalized.

     * Provide the appropriate agencies a final report on  the audit with
       comments and/or suggestions.
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AIR MONITORING AUDIT QUESTIONNAIRE

     The purpose of this questionnaire is  to provide an overview  and
summary assessment of an ambient air monitoring program.  It  is  not
intended as a substitute for either the detailed and comprehensive systems
audit recommended by the EPA (Quality Assurance Handbook for  Air  Pollution
Measurement Systems, Volume II,  Ambient Air Specific Methods)  or  for the
systems audit developed by various EPA Regions  and States.  However, this
questionnaire should be used as  a guide to the  systems  audit  to  ensure
national consistency of subjects addressed in the audit.  This questionnaire
can be completed during or upon  completion of the audit.

     It is assumed that the staffs of agencies  that operate the SLAMS
have a working knowledge of EPA  air monitoring  regulations  (40 CFR 50,
53, and 58) and of the references therein.  Compliance  with the  regulations
provides reasonable assurance that the data are adequate for  regulatory
purposes such as determination of attainment or nonattainment. Accordingly,
a number of the questions that follow are  aimed at determining if the air
monitoring regulations are being followed.  If  an answer indicates
noncompliance, then a brief summary of the deficiencies is  requested.
1
Network Size
     How many SLAMS are operated for each  of the criteria  pollutants
listed below?

               Pollutant                         Number

               Ozone                             	
               Nitrogen Dioxide                  	
               Sulfur Dioxide                    	
               Carbon Monoxide                   	
               Total Suspended Particulates       	
               Lead
2.   Network Design and Siting

     Is the air monitoring network design and siting in  conformance  with
40 CFR 58 Appendices D and E,  and EPA's  Quality  Assurance  Handbook?*	
3.   Network Review

     Is the SLAMS network reviewed annually  with  each  station  being
assigned a SAROAD number, operating schedule,  spatial  scale, and
monitoring objective?*	
* If answer is NO, give a brief summary  of the deficiencies,
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4.   Instruments and Methods

     Are the agency's SLAMS instruments  designated  as  reference  or
equivalent methods by the EPA and operated  in  accordance  with  40 CFR  50,
53, and 58?*    	
5.   Data Processing and Submittal

     Does the agency have staff and data processing facilities  adequate
to process and submit to SAROAD air quality  data  as specified in  40  CFR
58.35 and Appendix F?*	  What fraction of  the data  submitted  are
more than 45 days late?	%
6.   Data Review

     What fraction of the SLAMS sites  (by  pollutant)  reported  less  than  75
percent of the data (adjusted for seasonal  monitoring and  site start-ups
and terminations)?

                                               Percent of  Sites
               Pollutant                       < 75%  Data  Recovery

               Ozone                               	
               Nitrogen Dioxide                    	
               Sulfur Dioxide                      	
               Carbon Monoxide                     	
               Total Suspended Particulates        	
               Lead
7.   Status of Quality Assurance Manual

     Does the agency have a quality assurance  manual  (QAM)  and,  if  so,
has the QAM and any change thereto been  approved by  the  EPA under 40 CFR
58 Appendix A?*	  Are the agency's  air monitoring  practices
consistent with the QAM?*
8.   Data Correction

     Are the corrections/deletions  to preliminary  ambient  air  data
performed according to the QAM and  noted on  the  revised  documents?
Is the basis of any revision to final  ambient  air data  (i.e.,  submitted to
SAROAD or published) formally documented in  a  permanently  maintained
file?*
  If answer is NO, give a brief summary  of the deficiencies.
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9.   Staff and Facilities

     Does the agency have trained staff,  adequate  facilities,  and ready
access to NBS traceable gas and flow standards  and test  equipment needed
to conduct biweekly precision checks and  quarterly performance (accuracy)
audits as specified in 40 CFR 58 Appendix A?*	


10.  Laboratory Facilities

     Does the agency's laboratory have procedures, staff,  and  facilities
adequate to conduct the tests and analyses needed  to  implement the agency's
SLAMS monitoring and quality assurance plans?*	
11.  Audit Participation

     Does the agency participate in  independent  and/or interagency  audits?*
            Does the agency participate in  the  National  Performance and
System Audit Programs required under 40 CFR  58 Appendix A?*__
Briefly describe findings and any actions  taken as  a  result.
12.  Noncriteria Pollutants

     Does the agency provide quality assurance measures  for noncriteria
pollutant monitoring?*	  What measures  are taken?
13.  Accuracy and Precision

     As a goal, the 95 percent probability  limits  for precision  and
accuracy should be less than jH5 percent  and +20 percent,  respectively.
How do the precision and accuracy of the  agency's  instruments  compare to
this goal for the following pollutants in the last two years?

                                       Precision           Accuracy
        Pollutant                       19    /19           19    /19
        Ozone
        Nitrogen Dioxide
        Sulfur Dioxide
        Carbon Monoxide
        Total Suspended Particulates
        Lead
* If answer is NO, give a brief summary of the deficiencies,
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14.  Annual  Report

     Is the agency submitting an annual  summary report as required in 40
CFR 58.26?*
     How do any deficiencies noted in this summary questionnaire or noted
elsewhere in the audit affect the accuracy and reliability of the ambient
data collected in the agency?  What limitations  or precautions should be
observed when using these data?


RECOMMENDATIONS AND ANALYSIS

     The following steps are recommended to improve the agency's air
quality monitoring program:   (The expected benefits of each recommendation
should be listed as well.)
* If answer is NO,  give a brief summary  of the  deficiencies,
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1 REPORT NO. ' 2.
EPA-450/2-83-007
4. TITLE AND SUBTITLE
National Air Audit System Guidelines for FY '84
7. AUTHOR(S)
9 PERFORMING ORGANIZATION NAME AND ADDRESS
Office of Air Quality Planning and Standards
U.S. Environmental Protection Agency
Research Triangle Park, North Carolina 27711
12. SPONSORING AGENCY NAME AND ADDRESS
DAA for Air Quality Planning and Standards
Office of Air, Noise, and Radiation
U.S. Environmental Protection Agency
Research Triangle Park, North Carolina 27711
3. RECIPIENT'S ACCESSION NO.
5. REPORT DATE
November 1983
6. PERFORMING ORGANIZATION
8. PERFORMING ORGANIZATION
CODE
REPORT
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
68-02-3510
13. TYPE OF REPORT AND PERIOD COVER
14. SPONSORING AGENCY CODE
EPA/200/04
15. SUPPLEMENTARY NOTES
16. ABSTRACT
     The purpose  of  developing national  air audit system guidelines is to establish
standardized  criteria  for  EPA  Regions  to follow when auditing State air program
activities.   This  document,  prepared jointly by the State and Territorial Air
Pollution Program  Administrators  (STAPPA), the Association of Local Air Pollution
Control Officials  (ALAPCO),  and the Environmental Protection Agency, provides
national air  audit guidelines  for air  quality planning and SIP activities, new
source review,  compliance  assurance, and air monitoring.
17. KEY WORDS AND DOCUMENT ANALYSIS
a. DESCRIPTORS
Air pollution
Air audit
Air quality planning
New source review
Compliance assurance
Air monitoring
18. DISTRIBUTION STATEMENT
Unlimited
b. IDENTIFIERS/OPEN ENDED TERMS
Air Pollution Control
19. SECURITY CLASS {This Report;
Unclassified
20. SECURITY CLASS (This page/
Unclassified
c. COSATl F;ie!d/Grou[
13B
21. NO. OF PAGES
56
22. PRICE
EPA Form 2220-1 (Rev. 4-77)   PREVIOUS EDITION is OBSOLETE

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