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
-------
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.
-------
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
-------
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
-------
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
-------
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
-------
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.
1-1
-------
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.
1-2
-------
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.
1-3
-------
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.
1-4
-------
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
1-5
-------
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.
1-6
-------
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,
2-1
-------
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."
2-2
-------
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:
2-3
-------
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?
2-4
-------
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.
2-5
-------
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
2-6
-------
" 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.
2-7
-------
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 PolicyTechnical
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.
2-8
-------
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.
2-9
-------
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?
2-10
-------
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;
3-1
-------
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.
3-2
-------
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.
3-3
-------
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
3-4
-------
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.
3-5
-------
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.
3-6
-------
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.
3-7
-------
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?
3-8
-------
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
3-9
-------
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.
3-10
-------
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.
3-11
-------
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.
3-12
-------
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
3-13
-------
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.
3-14
-------
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.
3-15
-------
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.
3-16
-------
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.
3-17
-------
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.
3-18
-------
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.
3-19
-------
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.
3-20
-------
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,
4-1
-------
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:
4-2
-------
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.
4-3
-------
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?
4-4
-------
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
4-5
-------
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.
4-6
-------
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.
5-1
-------
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;
5-2
-------
* 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.
5-3
-------
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,
5-4
-------
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.
5-5
-------
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,
5-6
-------
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,
5-7
-------
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
------- |