EPA-450/2-85-009
National Air Audit System
FY 1985 National Report
Control Programs Development Division
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Air and Radiation
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
December 1985
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This report has been reviewed by 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 Service, 5285 Port Royal Road,
Springfield, Virginia 22161.
Publication No. EPA-450/2-85-009
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CONTENTS
I. OVERVIEW OF AUDIT FINDINGS 1-1
II. INTRODUCTION II-l
III. AIR QUALITY PLANNING AND SIP ACTIVITIES
Executive Summary I II-l
A. Air Quality Evaluation II1-4
B. Emissions Inventory 111-10
C. Modeling 111-20
D. SIP Evaluation and Implementation 111-32
IV. NEW SOURCE REVIEW
Executive Summary IV-1
A. Introduction IV-4
B. Summary of Major Findings IV-6
C. Public Notification Procedures IV-12
D. Applicability Determinations IV-14
E. BACT/LAER Determinations IV-18
F. Ambient Monitoring IV-21
G. Ambient Air Quality Analysis IV-22
H. Emissions Offset Requirements IV-27
I. Permit Specificity and Clarity IV-28
V. COMPLIANCE ASSURANCE
Executive Summary V-l
A. Introduction V-2
B. Major Findings and Conclusions V-3
C. Periodic Review and Assessment of Source Data V-4
D. File Review V-6
E. Overview Inspections V-7
VI. AIR MONITORING
Executive Summary VI-1
A. Introduction VI-1
B. Major Findings and Conclusions VI-2
C. Network Design and Siting VI-3
D. Resources and Facilities VI-5
E. Data and Data Management VI-7
F. Quality Assurance/Quality Control VI-9
VII. VEHICLE INSPECTION/MAINTENANCE
Executive Summary VII-1
A. Introduction VII-2
B. Major Findings and Conclusions VII-3
C. Enforcement VII-5
D. Reported Failure Rate VII-6
E. Waiver Rates VII-6
F. Analyzer Quality Assurance VII-7
G. Data Analysis VI1-8
H. Quality of I/M Repairs VII-8
I. Evaluation of the FY 1985 Air Audit Effort VI1-9
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I. OVERVIEW OF AUDIT FINDINGS
The air quality management objectives of the Clean Air Act (CAA) are
to attain the national ambient air quality standards (NAAQS) as expedi-
tiously as practicable, maintain them thereafter, and prevent significant
air quality deterioration. The CAA gives most of the responsibility for
attaining these objectives to the States. Therefore, the overall goal of
the National Air Audit System (NAAS) is to determine if State and local
air pollution control programs are achieving the CAA's air quality manage-
ment objectives. In spite of some minor shortcomings, the FY 1985 audit
effort provided a good assessment of the health of the national air quality
management program.
While it is clear that in FY 1985 the State and local air pollution
control agencies get high marks in some areas, particularly when considering
the difficulty and magnitude of the air quality management task and the
limited resources and tools available to do the job, their overall score
relative to actually meeting all the literal objectives of the CAA shows
room for improvement. Some of the deficiencies are minor. In other cases,
programs are under way at the State or national level to correct the
deficiencies. There are, however, some deficiencies that if left unattended
could threaten the overall health of some air quality management programs.
In order to support this conclusion, it will be necessary to identify those
activities that make up an air quality management program, specify how
those activities are to be conducted as specified by Environmental Protection
Agency (EPA) regulations and guidance or by recognized good practice, and
then compare those activities and practices to what was found during the FY
1985 audit program.
Air Quality Data
The starting point for air quality management is ambient air quality
data. Is the air quality good and, thus, in need of protection against
significant deterioration by potential new sources or is it poor, dictating
the need for additional control of existing sources and offsetting emission
reductions for new sources? In order to make these determinations, it is
necessary to have a sufficient quantity of high quality ambient air
monitoring data available in a timely fashion. The FY 1985 audit showed
that States have done a commendable job in establishing and operating
ambient monitoring networks for criteria pollutants and that good quality
data are generally available. The audit indicates that State and local
agencies have continued their successful performance in operating and
maintaining their State and local air monitoring stations (SLAMS) and
national air monitoring stations (NAMS). No significant or widespread
problems were discovered concerning network design or monitoring siting.
The audit showed that timeliness of data submittal remains a problem
for many agencies, particularly for submission of lead (Pb) data which are
late about 25 percent of the time. Another problem area in the data
management section of the audit was a deficiency by 24 percent of the
agencies in the submittal of the required annual SLAMS report. Corrective
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actions are being taken to resolve these problems. This will be
accomplished by early identification of late data or deficient annual
SLAMS reports and prompt notification of the appropriate Regional Office
for foilow up.
The audit indicates that most of the State and local agencies are
doing a good job of maintaining adequate and up-to-date quality assurance
plans. The only significant problems with respect to the achievement of
quality assurance goals are related to accuracy for nitrogen oxide
(N02) and precision for Pb. The low values for N02 accuracy and Pb precision
are believed to be related to the complexity of the N02 measurement method
and the low ambient Pb levels.
The audit indicated that 82 percent of the audited agencies had a need
for new or replacement of air monitoring or laboratory equipment. The
total equipment needs were approximately $4.6 million with $3.6 million
required for monitoring equipment and $1 million for laboratory equipment.
This finding indicates that data completeness and reliability problems
will be encountered if this area receives no attention. Therefore,
$2.4 million has been included in FY 1986 105 grant funds to replace carbon
monoxide (CO) and ozone (03) monitors and to procure size-selective particu-
1 ate matter monitors. It is anticipated that similar funding levels will be
made available in FY 1987.
Air Quality Evaluation
Once the availability of air quality data is established, it is only
of value if it triggers an appropriate action via the air quality manage-
ment process. After the data are collected, they must be evaluated to
determine the appropriate control action. The FY 1985 audit showed that
over 90 percent of the agencies published annual air quality reports and over
80 percent evaluated attainment and nonattainment area designations based on
those data. The audit and a subsequent survey also showed that action has
been initiated by the audited agencies on all relevant new violations of the
NAAQS. Action, however, generally does not include redesignations under
section 107 of the CAA from attainment to nonattainment. Thus, the viability
of the section 107 designation program as a continuing and comprehensive
planning tool is seriously in question.
Emission Inventory
In order to develop a control strategy, it is necessary to relate air
quality to source emissions using such tools as an air quality model. A
good emission inventory is an absolute prerequisite for such an analysis.
The audit indicated that almost all agencies have inventories for major
point sources, but only 55 percent of the agencies maintain an area source
inventory. Point source inventories are relatively current—and agencies
plan to keep them current via the new source and operating permit programs—
but few agencies routinely modify their inventories to reflect sources'
compliance with regulations. The audit suggests that area source inven-
tories are not as comprehensive as they should be. Some categories are
missing all together. Mobile source inventories seem to be almost neglected
by many agencies that do not have direct responsibility for this inventory.
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Furthermore, only two-fifths of the agencies indicate that they use the
most current factors to update their mobile source emission inventory.
A number of State and local agencies have begun, or are beginning, to
develop inventories of potentially toxic substances, but these are primarily
for point sources and cover groups of sources and pollutants that differ
greatly from agency to agency.
While many point source inventories appear adequate as a starting point
for State implementation plan (SIP) modeling and development of control
strategies, most area and mobile source inventories are receiving less
attention in frequency of updates and periodic reevaluation. This lack of
attention may create problems when dealing with urban ozone problems, where
area source emissions of volatile organic compounds (VOC) may outnumber
point source emissions. This lack of emphasis on area and mobile source
emissions is indicative of a generic transition problem that air pollution
control agencies seem to be experiencing. This problem is one of transition
from a control program focused on the control of stack emissions from a few
big sources with well understood control technology to a program of control-
ling many relatively small and poorly recognized sources with control
technology that has not previously been widely used and to controlling
nontraditional nonstack sources. Accordingly, because of the lesser quality
of some mobile and area source inventories, "reasonable further progress"
tracking is not as precise a tool for monitoring progress toward attainment
of the NAAQS as EPA had originally intended.
Modeling
As noted previously, air quality models are used to relate emissions
to ambient air quality and, hence, to determine the necessary control
measures. The FY 1985 audit indicated that most agencies are knowledgeable
and capable of performing and reviewing most routine modeling analyses.
However, the State/local agencies generally do not follow EPA procedures in
using nonguideline models. The agencies also appear to have problems in
implementing EPA modeling guidance for sophisticated models, as approxi-
mately one-third of all modeling analyses submitted to EPA had to be
returned for revisions. Modeling analyses for emission trades ("bubbles")
fared worse than the average, with over four-fifths being returned to the
States. It is interesting to note that modeling analyses (all types)
performed by industry and submitted to the State/local agencies for concur-
rence had a similar revision rate of approximately one-third; bubble modeling
had a higher return rate of two-thirds.
It is anticipated that the issuance of the revised EPA modeling
guideline, and the increasing availability of updated modeling training
courses, will ease the overall implementation problems currently affecting
State/local agencies. The modeling efforts associated with bubble analyses
appear incomplete, however. This indicates that more advance interaction
is needed among sources, States,.and EPA before any modeling provisions of
a "generic" bubble rule can be made workable.
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SIP Revisions
The CAA clearly envisions that control agencies would periodically
evaluate source/receptor relationships, i.e., the relationship between
air quality data and source emissions data, and revise their SIP control
strategies and resultant emission regulations accordingly. If the State
does not act in these situations, the CAA requires EPA to initiate State
action by calling for revisions to the SIP. The FY 1985 audit found the
following with respect to State and local development and implementation of
their SIP's:
1. While the majority of agencies are making progress in submitting
the required rules, 44 percent of the SIP revisions that were either newly
due or overdue in 1984 had not been completed by the agencies and, of those
completed, 27 percent had not been submitted to EPA.
2. Almost half of the additional studies that the agencies had
committed to complete by the end of 1984 as part of their SIP control
strategies had not been completed and 64 percent of these studies were
behind schedule.
3. Agencies regularly consult with EPA concerning bubbles and other
source-specific SIP revisions. However, the audit and a subsequent survey
of EPA Regional Offices revealed problems with "generic" bubble rules
(i.e., rules in which emission trades are granted by the States directly
without the need for EPA approval). Information available revealed that
some States operated generic bubble rules without prior EPA approval. This
practice places sources that have received such bubbles in jeopardy of
potential EPA action to enforce the EPA-approved SIP limit. Also, the
limited information available indicated problems with many generic bubbles
that had been issued.
4. While most agencies took action (SIP revisions, studies, monitoring,
enforcement) when discrepancies were found between actual source activity
(i.e., increases or decreases in growth) and past projections, many of the
agencies performed these evaluations at intervals greater than 5 years.
It was clear from the audit that a lack of resources and technical
capabilities contribute to some of the SIP problems just mentioned. It was
also clear, however, that in some instances the problems were attributed to
too low a priority being given to SIP development and tracking by some
States. Upcoming efforts to develop and implement the new stack height
regulations, a post-1987 03 policy, and a revised particulate matter standard
should significantly stimulate the SIP development efforts in most States.
I/M Programs
The CAA required that SIP's for 03 and CO nonattainment areas with
attainment date extensions to 1987 provide for vehicle inspection and
maintenance (I/M). The results of the 16 I/M program audits conducted in
FY 1984 and FY 1985 indicate that a number of serious problems exist in
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some I/M programs. These problems must be addressed if I/M programs are
going to achieve the emission reduction targets committed to in the SIP's.
Four of the six problem areas identified—enforcement problems, low failure
rates, high waiver rates, and poor quality repairs—have a direct bearing on
the emission reductions achieved by I/M programs. The other two problem
areas—analyzer quality assurance and data analyses—have more indirect
effects; however, they reflect to an extent the States' ability (or inability)
to assess program performance and improve it when necessary.
Twelve of the 16 programs audited were identified as having critical or
serious operating problems. Nine of these 12 are decentralized programs and
the other three are government-run, centralized programs. The most chronic and
the most challenging problem facing EPA is the issue of low failure rates,
especially in decentralized programs.
The programs audited represent a good cross-section of the types and
sizes of the 33 I/M programs currently operating nationwide. It is, there-
fore, reasonable to expect that many of the programs which have not yet been
audited are experiencing many of these same problems. This position is
supported by current operating data available from some of the other
programs.
The audit results clearly identify the need for EPA to continue its
efforts to work with each State or local I/M program to address problems
identified in audits. In addition, EPA should give a high priority to
conducting I/M audits in the remaining programs as soon as possible.
New Source Review
The CAA anticipates that the review of new sources by the States will
be one of the main mechanisms by which they attain and maintain the NAAQS
and prevent significant air quality deterioration. A State's new source
review (NSR) program must be designed and implemented to prevent a new
source from aggravating an existing air quality problem or creating a new
problem where one does not already exist. The FY 1985 audit verified that
State and local agencies are generally familiar with and have strong support
for the preconstruction review process.
This year's audit findings support and oftentime amplify the findings
from the FY 1984 NSR audit. The findings indicate that most agencies perform
their overall NSR program responsibilities reasonably well, although, in a
number of State and local agencies, problems were identified with respect
to the consistent and adequate application of certain specific program
requirements. In addition, auditors occasionally mentioned that noticeable
improvements had already been observed in the performance of some agencies
where specific deficiencies had previously been found. This is certainly
to the credit of these agencies in their efforts to improve in-house perfor-
mance and to strive for a greater level of national consistency. Overall,
however, EPA auditors often cited the lack of adequate file documentation
as a hindrance to a complete evaluation of the agencies' permit review pro-
cedures. With respect to specific audit topics, EPA continued to find
significant problems with the way that many agencies carried out their
source applicability determination procedures, with the lack of thorough
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ambient air quality impact analyses in some instances, and with the way
that different methods were used to require operating limitations on new
and modified sources. The audit once again noted the overall tendency of
agencies to rely on New Source Performance Standards (NSPS) in defining
best available control technology (BACT). The audit also confirmed the
fact that agencies are typically willing to allow prevention of significant
deterioration (PSD) applicants to use existing data in lieu of new monitoring
data, but raised a new concern when EPA found that the basis for such
actions was not always well documented or in complete conformance with
existing EPA criteria for representative data.
Yet, despite the assortment of problems that the audit was able to
identify, it is still fair to say that most State and local agencies function
in a competent manner and generally have their own individual strong points.
For example, some agencies routinely extend the requirement for BACT to non-
PSD sources, or require BACT for all pollutants once it is determined to be
required for any pollutant. The focus on permit files demonstrated that
most agencies are usually more prone to internal inconsistencies than to
routine malpractice. While not always true, auditors were usually able to
find good examples along with the bad whenever selected permit files were
examined. The EPA hopes that through the audit process many of these
inconsistencies can be identified and then satisfactorily addressed by
agencies within their existing technical and legal frameworks. Where
appropriate, EPA will seek to provide the necessary guidance and training
to support State and local agencies in their NSR efforts.
Compliance
The ultimate success of a State air quality management program relies
on its ability and will to enforce its regulations. Many States and locals
showed one or more strong points characteristic of a successful air
compliance program, such as high source compliance rates supported by high
inspection frequency rates, performance of all required NSPS source tests,
expeditious resolution of violators, and few long-term violators. Other
States had source files that were for the most part well organized,
up-to-date, and complete, reflecting a reasonable profile of each source.
These positive points show that most States are fulfilling compliance and
enforcement responsibilities under the CAA.
Inspection rates for Class Al* SIP sources generally increased over
those reported in last year's audit, although four States are still
unacceptably low (inspection rates of less than 60 percent). Compliance
rates for Class Al SIP sources remained roughly the same as last year. The
NSPS national average for both inspection and compliance rates rose, even
though some individual State rates declined slightly. The NSPS inspection
rates for two States are still seriously deficient, with figures of 33
percent. Overall, inspection rates for National Emissions Standards for
Hazardous Air Pollutants (NESHAP) remained steady while compliance rates
* Class Al includes sources with actual or potential controlled emissions
greater than or equal to 100 tons per year.
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fell slightly. Fourteen States still have NESHAP inspection rates at
or below 55 percent. This information shows that performance did not
change significantly from last year's audit. In the coming fiscal year, the
States and locals will be working to further improve compliance of sources.
The audits also revealed that several State and local agencies, to a
varying extent, still have weaknesses in three areas vital to a strong and
effective compliance program. First, some source files maintained by State
and local agencies do not contain verifiable information reflecting a
reasonable profile of each source. However, there has been some improve-
ment since last year's audits in the condition of States files, where the
percentage of those reviewed that reflected a reasonable profile of the
sources increased from 58 percent to 72 percent. Second, some inspection
reports still are of poor quality (no mention of operating or emission
parameters or pollutants emitted). For some agencies, there was a notice-
able improvement in the quality of inspection reports since the last review,
but there remain significant deficiencies in this area. Third, some of the
reviewed agencies' enforcement efforts are not always effective in reducing
the number of long-term violators by expeditiously returning documented
violators to compliance, although there was a slight drop in the percentage
of reports that indicated sources were not being expeditiously returned to
compliance (from 30 percent down to 26 percent).
Thus, while there are improvements in all of these critical areas,
some States and locals need to heighten efforts on the aforementioned three
areas to further strengthen their compliance programs. Success in these
three areas is vital to the establishment and maintainance of State and
local credibility with EPA and the public.
Next Steps
The EPA Regional Offices are now in the process of working with the
State and local agencies to correct those deficiencies that were identified
in the FY 1985 audit. They will continue this effort into FY 1986. In
addition, EPA intends to use the results of the FY 1985 audit in its program
planning and budgeting cycle in order to assure that resources are directed
to areas of highest need. After the FY 1984 audit, EPA convened a symposium
to develop specific recommendations for future improvements to the air
program based upon what was learned in the audit. The symposium included
representatives from EPA and the State and local air pollution control
agencies. A report on the implementation of these recommendations will be
distributed by EPA early in 1986. A similar report is planned by EPA based
upon the results of the FY 1985 audit.
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II. INTRODUCTION
The NAAS was developed in 1983 through a joint effort of the State and
Territorial Air Pollution Program Administrators (STAPPA), the Association
of Local Air Pollution Control Officials (ALAPCO), and EPA. The NAAS
provides uniform national criteria for evaluating (auditing) State and
local air pollution control programs. Such nationally applicable criteria
minimizes inconsistency of program audits carried out by EPA's ten Regional
Offices.
The need for the NAAS evolved as State and local air pollution
control agencies assumed responsibility under the Clean Air Act (CAA) for
an increasing number of programs. The EPA responded to the concerns of
the STAPPA and ALAPCO members by agreeing to participate in a STAPPA/
ALAPCO/EPA workgroup. The workgroup set forth to develop and direct the
implementation of an auditing system that would ensure the desired national
consistency and would confirm that State and local air pollution control
programs were operating in such a manner as to satisfy the national
requirements of the CAA.
The workgroup decided that the primary goals of the NAAS should be
to identify any obstacles that are preventing State and local agencies
from implementing an effective air quality management program and to
provide EPA with information which can be used to develop more effective
and meaningful national programs. The NAAS should provide audit guidelines
that EPA and State and local agencies can use (1) to meet statutory
requirements; (2) to assist in developing an acceptable level of program
quality; (3) to account for the achievements, shortcomings, and needs of
various air programs; (4) to identify programs needing further technical
support or other assistance; and (5) to manage available Federal, State,
and local resources effectively so that the national ambient air quality
standards (NAAQS) are attained and maintained as expeditiously as possible.
The first audit covered four program areas selected by the workgroup:
air quality planning and SIP activity, new source review, compliance
assurance, and air monitoring. Standardized audit guidelines for each
program area were written by subcommittees appointed by the workgroup.
The subcommittees were chaired by a State agency person with an EPA staff
person serving as a coordinator. Local agencies and the EPA Regional
Offices were also represented on each subcommittee. The workgroup also
developed the protocol for implementing the audit guidelines.
These guidelines were used for conducting the first NAAS audits in
FY 1984 (ending September 30, 1984). A national report (EPA-450/2-84-009)
that summarized the results of the 68 audits performed the first year was
issued in December 1984. The audit guidelines were revised for FY 1985
and vehicle inspection/maintenance was added as a fifth program audit
area.
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The guidelines were used by EPA Regional Offices in FY 1985 to audit
66 State and local air pollution control programs, including all States
except California plus Puerto Rico, the Virgin Islands, and the
District of Columbia. The California State agency was not audited because
the local district agencies in California are responsible for implementing
the various air quality management programs. The local agencies audited
were:* /:
Allegheny County, PA Philadelphia, PA
Asheville, NC South Coast AQMD, CA
Fresno County, CA Southwest APCA, WA
Jacksonville, FL St. Louis, MO
Lane County, OR Tampa, FL
Nashville, TN Toledo, OH
Northwest APA, WA Wayne County, MI
The STAPPA, ALAPCO, and EPA encouraged State/local personnel from one
agency to serve as members of the audit team for another agency. Four
States participated in this activity in FY 1985. The agencies that
participated in the audit exchanges listed the following benefits of the
program:
It provides an opportunity to compare their agencies' programs with
the host State's program to see what improvements can be "transplanted."
It fosters communication with other agencies at the working level so
that common problems can be shared.
It provides general insight into what other agencies are doing.
All of the participating agencies indicated that the exchanges were
beneficial and that they would continue their participation in the future
if resources allow. Such audit team exchanges apparently offer an excellent
opportunity to learn firsthand how other States operate their programs.
The audit teams varied in size; the number of auditors in an agency
at any one time rarely exceeded five. All five of the program areas were
generally not audited at the same time. Also, all program areas were not
audited in each agency because the five activities selected for audit
were not performed by all agencies.
The EPA Headquarters personnel observed ten audits. This served to
*Additional local agencies were included in the air monitoring audits
because of the delegated responsibility of operating local air monitoring
networks.
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provide national overview on the audits and was part of the quality
assurance program to which STAPPA/ALAPCO and EPA had agreed.
The protocol followed by the Regional Office in conducting the
audits included advance preparation prior to the on-site visit, an initial
meeting with the agency director, discussions with agency staff, review
of the agency files, and an exit interview.
The advance preparation involved, among other things, sending a
letter to the agency well in advance of the audit to confirm the date and
time and to identify the individuals performing the audit. The guidelines
and questionnaires were also provided to the agencies with a request to
complete portions of the questionnaire and to return them to the EPA
Regional Offices at least 2 weeks before the scheduled visit.
The site visits were conducted generally in four phases:
0 The audit team met with the agency director and key staff to
discuss the audit goals and procedures to be followed.
0 The auditors discussed the questionnaire with the personnel in
charge of each of the five audited activities.
0 The agency files were reviewed to verify the implementation and
documentation of required activities.
0 An exit interview was held to inform agency management of the
preliminary results of the audit.
The Regional Offices drafted an audit report after each site visit
and requested that each audited agency review it. The individual agency
audit reports were used by EPA to compile and write this FY 1985 national
report.
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III. AIR QUALITY PLANNING AND SIP ACTIVITIES
EXECUTIVE SUMMARY
Four major program components within the air quality planning and SIP
activities area were evaluated in the FY 1985 audit. These components were
air quality evaluation, emission inventories, modeling, and SIP evaluation.
This section of the audit was again in the form of survey questions that
were, for the most part, answered by the audited agencies. Generally, there
was not an actual "audit" conducted in that file reviews were generally not
used to confirm the answers given. A large part of this section does not
lend itself as well to file checks as the other sections (new source review,
air quality monitoring, vehicle inspection/maintenance, compliance assurance),
but some parts might. Air quality evaluation, emission inventories, and
modeling activities could be verified by selected file reviews. In the
future, this section of the audit should probably have a least a minimum
amount of file verification to be a meaningful part of the NAAS.
The FY 1985 audit revealed that the majority of the audited agencies
have sound programs in most of these components, but there are gaps that need
to be filled. Major findings from each of the components are described below.
Air Quality Evaluation
This portion of the audit covers how air quality data are used by State
and local agencies for the purpose of section 107 redesignations, handling
newly measured violations of the NAAQS, and keeping the public informed. The
vast majority of agencies make their air quality data available to the public
in a timely fashion.
Relating ambient data to source impacts is one important area where the
audit revealed improvements. The audit indicated that 90 percent of the
new violations of the NAAQS were investigated to determine the cause or
identify corrective actions. A later survey of the EPA Regional Offices
showed that the agencies were investigating the remaining 10 percent.
The majority of the agencies systematically review section 107 designations
and submit proposed changes to EPA. Emphasis is strongly in the direction of
attainment, however, as less than 1 percent of the requests for redesignations
are from attainment to nonattainment, even though new violations continue to
occur. Most agencies reported that they review their attainment status at
least on a yearly basis.
Emission Inventories
The audit indicated that almost all agencies have inventories for major
point sources, but only one-half of the agencies maintain an area source
inventory. Point source inventories are relatively current, and agencies plan
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to keep them current. Area source inventories are not as comprehensive as
they could be. The majority of agencies use a fully automated or partially
automated storage and retrieval system.
Many State and local agencies have taken the lead in inventorying sources
of toxic substances. There is, however, a lack of national consistency in
the sources and specific toxics being inventoried. It also appears that
area sources of toxic substances are not being included in the toxic inventories
,*"'
.*
This portion of the audit was conducted again in the form of survey
questions. Perhaps next year's audit should use the file review method to
verify the condition of the inventories.
Modeling
Air quality models are used to relate emission to ambient air quality and
hence to determine the necessary control measures. The FY 1985 audit indicated
that most agencies are knowledgeable and capable of performing and reviewing
most routine modeling analyses. However, the State/local agencies generally
do not follow EPA procedures when using non-guideline models. The agencies
also appear to have problems in implementing EPA modeling guidance for sophis-
ticated models as approximately one-third of all modeling analyses submitted
to EPA had to be returned for revisions. Modeling analyses for emission
trades ("bubbles") fared worse than average, with over four-fifths being
returned for revisions to the States. It is interesting to note that general
modeling analyses performed by industry and submitted to the State/local
agencies for concurrence had a similar return rate of approximately one-third.
Bubble modeling performed by industry had an even higher return rate of
two-thirds.
SIP Evaluation
The CAA clearly envisioned that control agencies would periodically
evaluate the relationship between air quality data and source emission data
and, where appropriate, submit timely revisions of their SIP control strate-
gies. The FY 1985 audit found that 44 percent of the due or overdue SIP
revisions had not been completed by the agencies and of those completed, 27
percent had not been submitted to EPA. The audit also showed that only half
of the additional studies that the agencies had committed to complete by the
end of 1984 as part of their SIP control strategies had been completed, and
64 percent of the remaining studies were behind schedule. The audit found
that many agencies are not comparing their current ozone or carbon monoxide
emission inventory with their 1982 SIP projections for the current year.
Continuous emission monitoring is being completely implemented by agencies in
only 59 percent of all cases.
The audit and a subsequent survey of the EPA Regional Offices also
revealed problems with "generic" bubble rules (i.e., rules in which emission
trades are handled at the State level without the need for EPA rul emaking).
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Information available revealed that some States operated generic bubble rules
without ever having received formal EPA approval. This practice places
sources that have received individual bubbles under these State programs in
jeopardy of potential EPA action to enforce the EPA-approved SIP limits.
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A. AIR QUALITY EVALUATION
Introduction
This section contains detailed audit information on how air quality data
are used by State and local agencies for the purpose of section 107
redesignations, trend analyses, prioritization of air program activities, and
public information. Three main areas are covered: air quality reports,
section 107 designations, and new violations.
In the air quality reports area, the audit asked how frequently agencies
published air quality monitoring data, the contents of the air quality reports,
and the time frame between data acquisition and publication.
The second area evaluated whether section 107 attainment status
designations were being reviewed and redesignated, if applicable. The number
of redesignations and methods used to review attainment status were requested.
The third area was intended to determine the number of air monitors that
revealed any new violations and the type of action taken for each violation.
Major Findings and Conclusions
The air quality evaluation part of the audit showed that 92 percent of
all State agencies and 90 percent of all local agencies made air quality
reports available to the public. This is an increase over the FY 1984 audit,
where 83 percent of all State agencies and 78 percent of all local agencies
made air quality reports available. Eighty percent of the agencies reported
that they make their air quality data available to the public within 6 months
of data acquisition.
On a weighted average basis, the time between data collection and report
publication for all agencies that submit reports to the public is between
4 and 5 months. The longest delay reported by any one agency was greater
than 18 months.
Most agencies reported that they use air quality data in reviewing
attainment/nonattainment designations and prioritizing resources. Eighty-three
percent of all State and local agencies systematically review section 107
attainment status designations and submit proposed changes to EPA. Ninety-one
percent of these agencies review attainment/nonattainment status at least on
a yearly basis. During FY 1984, 106 primary and 166 secondary redesignations
were initiated, while 81 primary and 166 secondary redesignations were completed
and submitted to EPA for review. The redesignation efforts are generally uni-
directional; less than 1 percent of all initiated actions and less than
2 percent of all completed and submitted actions were for redesignations from
attainment or unclassifiable to nonattainment. Thus, the viability of the
section 107 designation program as a continuing and comprehensive planning
tool is seriously in question.
Air quality monitoring detected 58 new NAAQS violations in FY 1984. Of
these, investigative action was initiated at 40 sites to determine the cause
of the exceedance, or to initiate enforcement action. Twelve of the remaining
sites had total suspended particulate (TSP) violations that control agencies
III-4
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believe are covered under EPA's rural fugitive dust policy and do not consti-
tute violations of the NAAQS for attainment purposes. No action was taken by
State and local agencies on six violations.
Response to Individual Questions
Air Quality Reports (A.I.)
,-*"The purpose of this audit question is to determine: (1) if State and
local agencies make air quality reports available to the public; (2) the
contents of the air quality reports; and (3) the time frame between data
acquisition and report publication. Specific questions regarding the report's
contents are summarized in Table A-l. Based on a review of individual agency
responses, the same agencies consistently omitted information listed in Table
A-l from their air quality reports.
The audit determined that 46 out of 50 State agencies (92 percent) and 9
of 10 local agencies (90 percent) made air quality reports available to the
public. This is an increase over the FY 1984 audit, where 83 percent of all
State agencies and 78 percent of all local agencies made air quality reports
available.
The time lag between data collection and publication was calculated to
average between 4 and 5 months. All reporting agencies, except one,
published air quality reports within 12 months of data acquisition. Seventeen
agencies (28 percent) reported a 0 to 2 month lag time, 31 agencies
(52 percent) reported a 3 to 6 month lag time, and 11 agencies (18 percent)
reported a 7 to 12 month lag time.
Section 107 Attainment Status Designation (A.2.)
The audit determined that 50 State and local agencies (83 percent)
systematically reviewed section 107 primary and secondary attainment status
designations and submitted proposed changes to EPA. Seven agencies
(12 percent) did not review, and three local agencies (5 percent) reported
not applicable because of systematic review at the State level.
Twenty-nine agencies reported that 253 section 107 reviews were completed
in FY 1984 that did not result in requests for redesignations. Of these reviews,
177 came from one State agency. At the same time, 272 primary or secondary
redesignation actions were initiated and 247 actions were completed and
submitted to EPA. The results are presented in Table A-2. Less than
1 percent of all initiated actions and less than 2 percent of all completed
and submitted actions were for redesignations from attainment or unclassifiable
to nonattainment. This appears low in view of the fact that 18 agencies
reported that 58 sites recorded new violations of the NAAQS in FY 1984.
III-5
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1II-6
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TABLE A-2. NUMBER OF REDESIGNATION BY STATE AND LOCAL AGENCIES
Redesignation
Initiated Completed & Submitted
Primary Secondary Primary Secondary
Attainment or unclassifiable
to nonattainment
Unclassifiable to attainment
Nonattainment to attainment
or uncl assifiable
Total
17
87
106
0
2
164
166
7
70
81
0
1
165
166
The audit then attempted to determine how agencies review attainment
status. Five options were listed: (1) staff notification of violations to
agency management, (2) consideration of air quality data for the past 2 to 3
years, (3) consideration of modeled exceedances, (4) consideration of control
and emission changes, and (5) investigation into cause of violations.
Responses are shown in Table A-3. From Table A-3 it can be seen that all
five methods are used by over half of the audited agencies. The method most
used is the use of air quality data, while modeling is the least used method.
TABLE A-3. METHODS USED TO REVIEW ATTAINMENT STATUS,
Method
Number of Agencies
Yes No N/A
Staff notifications of violations
to agency management
Consideration of air quality data
for the past 2-3 years
Consideration of modeled
exceedances
Consideration of control and
emission changes
Investigation into causes of violations
38
50
28
32
36
10
1
18
15
10
12
9
14
13
14
Figure A-l shows the frequency of attainment status reviews by pollutant,
Most agencies (92 percent) perform attainment status reviews at least on a
yearly basis.
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Z\
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Figure A-l. Frequency of agency attainment status
reviews by pollutant.
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New Violations (A.3.)
The purpose of this audit question was to determine the number of air
quality monitors that revealed any new violations and the type of action
taken for each violation. Eighteen agencies (30 percent) reported 58 new
violations were detected at air quality monitoring sites in FY 1984. Table A-4
lists the type of action taken for each violation. Of the 58 violations
detected, action was initiated on 40 sites (69 percent). Twelve of the remaining
18 sites had TSP violations that control agencies believe are covered under
EPA's rural fugitive dust policy and are not considered violations of the
NAAQS for attainment purposes. No action was taken on 6 sites; however, a
follow up survey of the EPA Regional Offices indicated that the agencies are
investigating these violations.
TABLE A-4. ACTIONS TAKEN FOLLOWING AIR QUALITY MONITORING VIOLATIONS
TotalAction
Actions Action Action submitted
Action Taken initiated completed to EPA
Enforcement action based on 3 3 0 0
existing SIP regulations
Change in an individual 110 0
source permit
Source-specific, local, 741 2
county, or areawide SIP
revisions
Additional monitoring 660 0
Verification by modeling 110 0
studies
Data ignored: a documented 961 2
exceptional event
Microscopic examination 770 0
of filters
Other
Total
6
40
6
34
0
2
0
4
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B. Emission Inventory
Introduction
Fifty-nine State and local agencies were interviewed to determine the
completeness, timeliness and procedures they use to develop, update and
document their emission inventories. Agencies were asked to provide infor-
mation on the status of their point source (both major and minor), area
source and mobile source inventories. Pollutants of primary interest were
particulate matter (PM), sulfur dioxide ($02), CO, VOC, oxides of nitrogen
(NOX)5 and Pb. Information on inventory activities associated with potentially
toxic air pollutants, including sources affected by NESHAP was also obtained.
Major Findings and Conclusions
About 90-95 percent of the 59 agencies maintain an emission inventory
for most criteria pollutants; however, only 75 percent apparently maintain an
inventory for Pb. Point source emissions were the major focus of these
inventories. A smaller number of agencies (55 percent) maintain an area
source inventory.
Most of the inventories are fairly current. Approximately half of the
(point source) inventories were updated in 1984 or later. About three-quarters
have been updated since 1983. Moreover, about 80 percent of the agencies
indicate that they plan to update their inventory within the next year.
Nevertheless, a few inventories have apparently not been updated in 6-10
years.
Some inventories are not as comprehensive as perhaps they could be .
For example, some agencies do not include certain sources in their area
source inventory (e.g., fugitive PM emissions from open dust sources, VOC
emissions from miscellaneous solvent use, Pb emissions from waste combustion).
About 30 percent of the agencies have an inventory of point sources which
emit potentially toxic substances. The number of pollutants, as well as the
specific toxic pollutants inventoried, vary considerably from agency to
agency. In almost every case, area source emissions of toxic substances are
not inventoried.
The majority of agencies use a fully automated or partially automated
data system for storage and retrieval of emissions inventory data. Agencies
using totally manual data processing procedures are mostly agencies that have
a small number of point sources to track.
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Agencies reported using various procedures to check the inventory. About
two-thirds prepare reports documenting the procedures and assumptions they
use to compile the inventory, and about half of these agencies have the
report externally reviewed. Most agencies also have established various
levels of internal review of the inventory data.
Response to Individual Questions
Approximately 90-95 percent of the agencies* indicated they maintain an
emission inventory for PM, S02, CO, VOC and NOX. Seventy-five percent indicated
they maintain an inventory for Pb. There are, however, many differences in
the scope and content of the inventories from agency to agency. For example,
while 90+ percent maintain an inventory of point source emissions, only
55 percent maintain an area source inventory. This is not too surprising,
since there is no general requirement to maintain area source inventories on
a routine basis (unless the agency is reporting on Reasonable Further Progress
(RFP) in a nonattainment area). For mobile sources, most agencies indicated
that an inventory is available for their particular area; however, only 50
percent of these agencies stated it is maintained by their agency. In many
cases, the inventory is maintained by either the local planning or transpor-
tation agency.
Table 1 summarizes the types of inventories maintained by agencies on a
pollutant-by-pollutant basis.
Although 59 agencies were interviewed, a lesser number (50 to 55) responded
to any particular question. Unless indicated otherwise, the percents listed
in this report are based on the number of agencies interviewed (i.e., 59).
To determine the number of agencies responding to a particular question,
simply multiply the percentage by 59.
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Table 1: Number Of Agencies Maintaining Various Types Of Emission Inventories
Number With Point
Source Inventory
Number With Area
Source Inventory
Number With Mobile
Source Inventory
Number Of Agencies
Interviewed
Pollutant
PM S02 CO VOC
56 (93%) 56 (93%) 54 (90%) 54 (90%)
37 (62%) 28 (47%) 32 (53%) 38 (63%)
(a) (a) 45 (75%) 40 (68%)
59 59 59 59
NOX Pb
56 (93%) 44 (75%)
31 (52%) 18 (30%)
29 (43%) (a)
59 59
( ) Number in parentheses is the percent of agencies, based on the number
of agencies interviewed (i.e., 59).
(a) Some, though not all, agencies indicated that they inventory PM,
Pb and S02 emissions from mobile sources.
A few observations are worth noting. First, with the exception of Pb,
there are generally only slight variations in the percents reported among
pollutants. This is a relatively consistent finding that will be seen in
other comparisons. Also of interest is the finding that only 43 percent of
the agencies maintain an NOX inventory of mobile sources. While it is true
there are only a few nonattainment areas for NOX, an NOX inventory may be
useful for modeling analyses in ozone nonattainment areas. As such, a similar
number of VOC and NOX mobile source inventories would have been expected.
Timeliness Of The Inventory
The audit results provide an indication of how current the inventories
are. Information was obtained with respect to when the "complete" inventory
was last updated and Table 2 presents this information. About half of the
agencies report that the complete inventory was updated in 1984, or later,
while about three quarters indicate an update since the beginning of 1983.
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Table 2: Number Of Agencies Indicating When The
Complete Emission Inventory Was Updated
Year Of Update
1984 (or later)
1983
1982
1981
1976-1980
1975 (or before)
No Response
Pollutant
PM
31 (53%)
13 (22%)
7 (12%)
1 ( 3%)
4 ( 6%)
0 ( 0%)
3 ( 5%)
S02
31 (53%)
13 (22%)
7 (12%)
1 ( 3%)
3 ( 4%)
0 ( 0%)
4 ( 7%)
CO
29 (49%)
12 (20%)
8 (13%)
1 ( 3%)
3 ( 5%)
1 ( 3%)
5 ( 8%)
VOC
30 (51%)
15 (25%)
5 ( 9%)
1 ( 2%)
3 ( 5%)
0 ( 0%)
5 ( 8%)
NOX
30 (51%)
14 (23%)
8 (13%)
1 ( 3%)
3 ( 5%)
0 ( 0%)
3 ( 5%)
Pb
18 (31%)
9 (15%)
7 (11%)
1 ( 2%)
9 (15%)
0 ( 0%)
15 (26%)
Mobile Source Emission Factors Used in SIP's
Table 3 provides information with respect to the mobile source emission
factors used in the base year mobile source inventory of the current SIP.
Table 3: Mobile Source Emission Factors
Used In Current SIP's
Mobile 1 Mobile 2 or 2.5
Number of SIP's: 15 (25%) 26 (44%)
Mobile 3 No Response
7 (12%) 11 (19%)
As can be seen, 41 agencies (69 percent) indicated that either Mobile 1,
Mobile 2, or Mobile 2.5 was used to estimate emissions in the current SIP.
This suggests that many mobile source inventories are outdated, since Mobile 3
is now available and revises emission estimates upward considerably, particu-
larly for VOC. Also, only 24 agencies (41 percent) indicated that they now
use Mobile 3 to update the inventory. It is not clear why more agencies
would not use Mobile 3 to update their mobile source inventory.
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Point Source Inventories
The audit obtained information concerning the emission rate cutoff
level which agencies use to define a point source. The survey revealed
that roughly 50 percent of the agencies use 25 tons/year, or less, to define
a point source. Po1lutant-by-po11utant information concerning cutoff levels
is summarized in Table 4.
Table 4: Number Of Agencies Using Different
Emission Rates To Define A Point Source
Cutoff Level
(Tons/Year)
1-5
6-10
11-25
26-50
51-100
> 100
No response
Pollutant
PM
15 (26%)
3 ( 5%)
15 (25%)
1 ( 2%)
8 (13%)
0 ( 0%)
17 (25%)
S02
15 (26%)
4 ( 7%)
11 (18%)
4 ( 7%)
7 (12%)
0 ( 0%)
18 (31%)
CO
13 (22%)
3 ( 6%)
9 (15%)
1 ( 2%)
11 (18%)
2 ( 3%)
20 (34%)
VOC
12 (21%)
4 ( 7%)
9 (15%)
5 ( 8%)
9 (15%)
0 ( 0%)
20 (34%)
NOX
13 (22%)
3 ( 6%)
9 (15%)
5 ( 8%)
9 (15%)
1 ( 2%)
19 (32%)
Pb
25 (43%)
2 ( 3%)
4 ( 7%)
0 ( 0%)
0 ( 0%)
0 ( 0%)
28 (47%)
Similar information was obtained to determine the cutoff level agencies
use to distinguish between a "major" point source and a "minor" point source.
With the exception of Pb, most agencies (approximately 75 percent) indicated
that they considered sources emitting 100 tons/year, or greater, as major
point sources. Most agencies use 5 tons/year, or greater, to define a "major"
source of Pb. The significance of being considered a "major" or "minor"
source is that less attention is generally devoted to minor sources with
respect to obtaining, updating and quality assuring emissions data.
Area Sources
Responses to a number of audit questions provide some perspective with
respect to agency activities regarding area source inventories. Of interest
was whether agencies include certain sources in their area source inventory
(e.g., fugitive particulate emissions, nonreactive VOC's). For example,
of the agencies who reported to have an area source inventory:
27 agencies (73 percent) reportedly include fugitive open sources
(e.g., paved and unpaved roads) of particulate matter.
24 agencies (63 percent) apparently exclude nonreactive emissions of VOC.
29 agencies (76 percent) said that they include VOC emissions from
miscellaneous solvent use.
7 agencies (39 percent) stated that their area source inventories include
lead emissions from waste oil combustion.
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While many agencies include these categories, as they should, others
do not. The lack of consideration of these source categories could have
considerable impact if the inventories were used for control strategy
development purposes in nonattainment areas.
Updating Of Emission Inventory
A number of questions obtained information about agency plans and procedures
for updating inventories. Roughly 80 percent of the agencies stated that
they either plan to update the inventory (at least for major point sources)
during the next year or that they routinely update their inventory on a
continual basis. About 40 percent plan to update minor sources, and 20 percent
plan to do so for area sources over the same time period. Table 5 illustrates
the reduced level of updating activity for area and minor sources compared to
point sources.
Table 5: Number Of Agencies Planning To Update Specified Portions Of
Their Inventory, Either On A Continual Basis Or Within One Year
Portion Of
Inventory
Pollutant
PM
S02
CO
VOC
NOv
Pb
Major Point Sources
Minor Point Sources
Area Sources
43 (72%) 44 (73%) 46 (77%) 44 (74%) 43 (72%) 21 (52%)
23 (38%) 22 (37%) 25 (42%) 25 (42%) 24 (40%) 16 (27%)
13 (22%) 13 (22%) 12 (20%) 11 (18%) 11 (18%) 4 ( 7%)
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Agencies were asked to identify the type of procedures they use to
update their inventories. Agency responses concerning the use of specific
procedures are provided below.
(1) Number of agencies which update point source inventories based on:
Most Of
Always The Time Sometimes Never
No
Response
Source Inspection 14
Source Permit Expiration 17
Source Reporting 26
Source Test 24
Source Permit Application 28
Continuous Emission Monitor Report 6
14
9
13
14
14
3
26
13
16
17
5
21
4
13
3
3
11
22
2
8
2
2
2
8
(2) Number of agencies which update point sources based on:
Changes in Emission Controls
Shutdown of Sources
New Sources
Malfunctions
Change in Source Activity or
Production
New Inspection or Enforcement
Information
Always
42
45
47
7
26
22
Most of
The Time
11
6
7
3
17
10
Sometimes Never
3
5
3
20
12
23
0
1
1
25
2
2
No
Response
4
3
2
5
3
3
(3) Number of agencies which update area and mobile sources based on:
Most Of
Always The Time
Sometimes Never
No
Response
Change in Census or
Population Estimates
Change in Employment Estimates
Change in Fuel Use Estimtes
Change in VMT Estimates
20
9
14
29
9
4
7
2
9
15
12
5
8
16
12
4
14
16
15
20
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It is interesting to note that continuous emission monitoring data are
apparently not used in many cases to update the inventory. It is not clear
why this may be so since continuous monitors conceptually provide the best
estimate of emissions from a source. Of further interest is the fact that
not all agencies reported making changes to the inventory, even in cases when
a point source shuts down.
Inventory of Non-criteria Pollutants
The audit obtained information concerning inventory activities associ-
ated with non-criteria pollutants, including sources emitting (a) potentially
toxic substances; (b) hazardous or toxic pollutants regulated by NESHAP
(mercury, beryllium, asbestos, vinyl chloride, and benzene); and (c) those
pollutants regulated under the section lll(d) of the Clean Air Act. Section
lll(d) pollutants are non-criteria pollutants for which NSPS have been set.
Approximately 30 percent of the agencies compile inventories for various
potentially toxic substances. Virtually all of the inventories focus exclusively
on point sources (i.e., area sources were not inventoried). There is con-
siderable variations with respect to the number of toxic substances inven-
toried. For example, some agencies reported that they inventory around 6-10
pollutants, while others inventory as many as 800-1000 pollutants.
About 40-50 percent of those agencies which have been delegated authority
to regulate NESHAP sources maintain an inventory of those sources. Roughly
30 percent of the agencies indicate that they also inventory sources emitting
pollutants affected by section lll(d) of the Act. This response may be misleading,
since sources of lll(d) pollutants (fertilizer plants, sulfuric acid plants,
kraft pulp mills, and primary aluminum plants) may not be located within each
of the jurisdictions administered by the agencies.
Data Checks
The audit focused on procedures that agencies use to check their inventory.
Many agencies said that they perform a number of activities with respect to
documenting and reviewing the inventory data.
For example, about 75-80 percent of the agencies reportedly perform some
type of edit checks (e.g., extreme value checks) of their point source inventory
data. Similar results were obtained when agencies were asked about consistency
checks of emission factors among source types. About 60 percent of the agencies
indicated these checks are performed on point sources, while 20-25 percent of the
agencies perform these checks on area and mobile sources. Inventory data are
internally reviewed by various staff personnel (e.g., enforcement, planning,
permit staff), as well as by the supervisor in about 60-70 percent of the
agencies.
In addition, about two-thirds of the agencies indicated that they
prepared reports describing the inventory, assumptions and procedures, with
about half of these agencies having the reports reviewed by external groups.
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Computerization And Report Formats
The majority of agencies interviewed indicated that they use a fully
automated or partially automated data system for storage and retrieval of
emission inventory data. Agencies using totally manual data processing
procedures are mostly agencies that have a small number of point sources.
Most States that have automated systems use them for storage of point source
data. Four of the States that do not have an automated system for storing
point source data indicate that they have a need for such a system. Only
about half of the agencies use an automated system for storage of area source
data. Some of these use their system only for limited applications, such as
for storage of data for certain urban areas or for "minor" point sources.
Nine agencies indicated that an area source system is not available but is
needed.
For nearly all cases, computerized data handling systems are capable
of computerized editing of data and are capable of producing an annual
National Emissions Data System (NEDS) report. Most systems operate in batch
mode for storage and retrieval of data. This appears to be a satisfactory
situation for most States. Only two States indicate no need for a batch
retrieval capability, saying instead that they use interactive retrievals
exclusively. Interactive retrieval capability is available for 21 agencies.
Eleven others indicated that they do not have this capability but would find
it desirable. A few comments were provided that interactive retrievals,
although desirable, are not used because of high cost.
About 80 percent of responses indicate that the systems are or should be
sufficiently "user-friendly" to permit non-ADP personnel to use the system.
Roughly the same proportion of responses indicates that systems are, or
should be, able to store both current and historical data for tracking RFP
and should be capable of storing emissions and enforcement/compliance data
in the same file. These are some of the design criteria for the new
Aerometric Information and Retrieval System (AIRS) facility data system to be
developed by EPA. The States' responses indicate that if the AIRS system is
to meet State needs, it should be "user friendly," have the capability to
store both emissions and enforcement data, and be capable of tracking emission
trends. The AIRS should provide both interactive and batch access capabilities,
In order for States to make use of the interactive capabilities, the expense
to the States should not be excessive.
The survey results do not reveal a great deal about the States' level
of satisfaction with their current systems. The greatest needs appear to
be for more "user-friendly" access capabilities, more efficient interactive
retrievals, and merging of emissions with enforcement data in those States
that have not already accomplished this.
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What Conclusions Can Be Drawn From The Audit Responses?
There are a number of observations that can be drawn from the audit.
However, it is important to consider two points while interpreting the
responses to the audit questions.
First, the responses to similar questions did not always result in similar
responses. For this and other reasons, it is recommended that the numbers
and percentages presented in this analysis be viewed more as qualitative
indicators rather than as absolute numbers.
Secondly, the audit sought general information on emission inventory
procedures that are used by 59 different agencies. It is important to
realize that there is no uniform inventory requirement that applies to all
areas. For example, more complete, comprehensive and up-to-date inventories
for point, area and mobiles sources are typically required in nonattainment
areas than in attainment areas. As a result, it is not entirely possible to
conclude from the information provided if agencies are adequately (or inade-
quately) compiling inventories which meet specific requirements. The audit
results should, therefore, be viewed more for general trends in various
inventory activities, rather than to attempt to determine specific gaps or
limitations with ongoing programs. With these caveats in mind, the following
conclusions are presented.
Almost every agency maintains emission inventories for criteria pollutants.
These inventories focus primarily on point sources, although mobile and area
source inventories are included to a lesser degree. Point source inventories
are relatively current, and agencies' plans to keep them current are noteworthy.
Most agencies appear to make reasonable efforts to compile a comprehensive
inventory of point sources. Many agencies use various means to estimate
emissions for a source, even if an emission factor is not readily available.
Most agencies who are required to track RFP believe that their inventory is
useful for performing this function. Further, agencies have incorporated a
number of internal and external checks into the emission inventory system,
which give some confidence that credible emission inventory data bases,
particularly for point sources, are being collected.
On the other hand, some information from the audit suggests that area
source inventories may not be as comprehensive as perhaps they should.
Certain sources may not be included, and some area source inventories may
be outdated. Mobile source inventories may suffer, since, in some areas,
the agency responsible for air pollution control does not have direct
responsibility for the mobile source inventory. Accordingly, the RFP concept
is not as precise a tool for tracking progress toward attainment of the NAAQS
as EPA originally intended.
With regard to toxics, agencies should be applauded for taking a leader-
ship role in inventorying sources of toxic substances. Judging from the
responses however there is an apparent lack of consistency in both the specific
pollutants and number of pollutants being inventoried. Also, it appears that
agencies may be ignoring area sources of toxic pollutants which have been
found to contribute a considerable portion of the total risk within a particular
area. Some effort to foster a greater degree of consistency and completeness
among air toxic inventories appears to be needed.
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C. MODELING
Introduction
This section summarizes the detailed audit information on the air quality
modeling capabilities of State and local agencies. The intent of the audit was
to determine the technical adequacy of modeling analyses and the degree of
nationwide consistency with EPA modeling guidance. In order to make this
determination, the State/local agencies and the EPA Regional Offices were asked
to respond to questions in five areas: (1) training and experience of State/local
agency modeling staff; (2) availability of computer hardware and software for
performing modeling analyses; (3) deviations from recommended EPA modeling
techniques; (4) Regional Office review of State/local modeling analyses; and
(5) State/local agency review of industry modeling analyses.
A key area for assessing the State/local agency's ability to perform
technically adequate analyses is the adequacy of the education and experience
level of the agency's modeling staff. The agencies were asked to describe their
staff's training and experience in meteorology and/or modeling, and to identify
the staff's experience with both simple and complex modeling issues.
A second area for determining the ability of the agency to deal effectively
with modeling problems is the availability of the physical resources (hardware
and software) necessary for performing the analyses. The agencies were asked
to indicate whether they had access to UNAMAP models, and if so, whether they
had the "in-house" expertise to use the models.
The agencies were asked to discuss deviations from EPA recommended models
and data bases that were used for regulatory modeling analyses. Reasons were
solicited for using alternative models or data bases not specifically recommended
in EPA modeling guidance.
The questions in the final two areas concerned the EPA review of State/local
agency modeling analyses and State/local agency review of industry modeling
analyses. The intent of the questions in these two areas was to determine the
degree of consistency with EPA modeling guidance and the technical adequacy of
modeling analyses.
Major Findings and Conclusions
Some general observations about the degree of consistency and technical
adequacy in modeling done by the agencies can be made based upon the responses
to the audit. It is important to realize that the resources required by an
agency for modeling analyses depend on a number of factors and vary widely
from agency to agency. Such factors as the number of modeling problems,
complexity of suitable models, level of detail required for input data bases,
meteorological and topographic features, and other technical issues, determine
an agency's ability to effectively deal with modeling problems. These factors,
along with the case-by-case requirements of many modeling analyses, make it
difficult to assess the specific difficulties that the agencies have in
implementing EPA modeling guidance. For these reasons, the audit responses
should be viewed more for the general problems experienced by the agencies,
rather than an attempt to determine specific limitations of modeling programs.
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Most of the State/local agency personnel responsible for air quality
modeling appear to have adequate training and experience in air pollution
meteorology. About one-third of those performing modeling have a degree in
meteorology, and another 50 percent have an engineering/technical degree
with formal training in air pollution meteorology.
Based upon the audit results, it was not possible to determine whether
the agencies had sufficient personnel resources to deal with their modeling
problems. A review of the complexity of each modeling analysis on a case-by-
case basis would be necessary to make that assessment. One important obser-
vation about the agencies personnel resources is that about one fourth of the
agencies lack a single person with modeling training or experience. Although
these agencies reported very few regulatory modeling applications during
FY 1984, there is a potential for future problems as new modeling issues
arise.
Most agencies have the physical facilities (hardware and software)
available to the staff to perform modeling analyses. Most of the agencies
have access to some of the UNAMAP models, but only 55 percent of the agencies
reported having access to the most current version 5 of UNAMAP. To ensure
consistency, the agencies should all be accessing the most current version of
UNAMAP models.
Although the majority of analyses performed by the State/local
agencies follow EPA modeling guidance, one half of the agencies found it
necessary to use techniques not specifically recommended in EPA guidance at
least once during FY 1984. Twenty-two agencies reported using a non-recommended
model, primarily because the alternative model was judged to be technically
more appropriate for the situation than the recommended model. However,
these agencies rarely employed a performance evaluation to judge the superiority
of the alternative model.
Sixteen out of 59 agencies reported cases where EPA's recommendation for
using 5 years of off-site or 1 year of on-site meteorological data was not
followed. These agencies cited unavailability of data or cost of running
5 years of data as reasons for not following EPA guidance.
Based upon response by the EPA Regional Offices, the State/local
agencies appear to have problems implementing EPA guidance regarding regulatory
modeling. Thirty-two percent of all modeling analyses submitted for review
to the EPA Regional Office by the State/local agency were returned for*revision.
These analyses required revision because the agency did not know, understand
or follow EPA guidance, or because the analysis was considered to be technically
inadequate. Perhaps some mechanism should be provided to promote a better
understanding among the State/local agencies concerning the requirements for
regulatory modeling.
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Responses to Individual Questions
Training and Experience (Questions C.la-f)
Question C.la was asked to determine both the number and the educational
background of staff who normally use air quality models. The intent of the
question was to determine whether the personnel who routinely perform modeling
at the agency had adequate training in the use of air quality models.
The responses to this question show that of the 167 agency personnel
that perform modeling, 55 (34 percent) have a college degree in either
meteorology or atmospheric science, 82 (48 percent) have a college degree in
a technical field and also have had some formal meteorological or dispersion
modeling training, and 27 (18 percent) have a college degree in a technical
field but have no formal training in meteorology or dispersion modeling.
Of the 60 agencies responding to this question, 12 agencies (20 percent)
did not have any personnel with either an atmospheric science degree or formal
training in dispersion modeling. Most of these agencies responded to later
questions that they had few modeling applications, used only screening models,
or had used contractors to perform the analyses. The remainder of the agen-
cies had at least one person with modeling training.
Question C.lb asked for the experience level of the modeling staff. The
results were as follows: 25 percent have less than 2 years of modeling
experience, 22 percent have 2-5 years experience, 37 percent have 6-10 years
experience, and 16 percent have more than 10 years experience.
Part c of Question C.I concerned the agency's capabilities to execute
EPA models. A majority of the agencies (86 percent) had the ability to run
EPA screening models in-house. Most agencies (80 percent) could also run
refined EPA models in simple circumstances. About two-thirds of the agencies
reported the ability to run refined EPA models in-house in all types of
circumstances.
Question C.ld asked the agency to identify the most complex air
quality model that had been used for regulatory applications and the models
most commonly used by the staff. Nearly half of the agencies listed either
the ISCLT or ISCST models as the most complex that they had used. These
agencies typically used the ISC models for PSD review, SIP-related modeling,
and downwash analysis. A smaller number of agencies reported the use of
models such as MPTER or CRSTER as the most complex model used for regulatory
applications. Seven agencies reported using city-specific EKMA for urban
ozone applications, and one agency had used the Urban Airshed Model for a SIP
analysis. Two agencies listed MESOPUFF as their most complex modeling appli-
cation for determining Class I PSD increment consumption and for acid deposition
studies. The models most commonly used were screening models such as PTPLU
and PTMAX.
Question C.le was asked to determine if the agency staff has used EPA's
"Interim Procedures for Evaluating Air Quality Models" for evaluating non-
guideline models. Thirteen agencies responded positively. They employed
the procedures for evaluating nonguideline modeling techniques relating to
urban/rural dispersion coefficients, complex terrain representations, and
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averaging times. Each of these 13 agencies employed at least one staff
person with at least 5 years of modeling experience.
Question C.lf concerned development of nonguideline models. Nineteen
agencies (32 percent) had modified guideline models or had developed new
nonguideline models. There were a variety of reasons for the circumstances
that required use of a nonguideline model. Some of the changes to guideline
models were modifications to the existing model's algorithm for averaging
times, downwash and plume rise computations, dispersion coefficients, and
terrain representations. New nonguideline models were developed for applica-
tions such as area source emissions from toxic waste sites and techniques
for chemical mass balance receptor analyses.
Table C-l contains the information from questions C.I a, b, c, e, and f.
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TABLE C-l
Modeling Training and Experience
Cla What is the training of
the staff that performs
modeling?
Clb What is the experience
level of the modeling
staff?
Meteorology
Degree
34%
25%
Technical Degree Technical Degree
with without
Modeling Training Modeling Training
48%
18%
< 2 Years 2-5 Years 6-10 Years > 10 Years
22%
Yes
37%
No
NA
16%
Clc* Can staff run EPA:
screening models?
refined models in simple
circumstances?
refined models in all
circumstances?
Cle* Has staff used EPA's
procedures for evalu-
ating nonguideline
models?
Clf* Has staff developed
nonguideline models
in-house?
86%
80%
63%
Yes
22%
Yes
32%
7%
13%
27%
No
68%
No
58%
7%
7%
10%
NA
10%
NA
10%
*Percentages are based on the number of agencies audited
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Access, Expertise, and Use (Questions C.2a-c)
The first part of Question C.2a asked for the UNAMAP version number used
by the agency. Fifty-five percent of the agencies accessed Version 5 (most
current), 17 percent accessed Version 4, 3 percent used Version 3, and 25
percent failed to respond.
The second part of Question C.2a asked the agency if they have access to
and expertise in using 22 UNAMAP models, and if so, how many FY 1984 applications
did they have with each model. The models were assigned to four categories:
(1) models recommended in the "Guideline on Air Quality Models (1978)";
(2) models recommended in the "Regional Workshops on Air Quality Modeling: A
Summary Report (1981)"; (3) EPA and other screening techniques; and (4) other
nonguideline models.
Models in the first category included APRAC-1A, AQDM, COM, RAM, CRSTER,
TCM, TEM, and HIWAY. Most agencies (78 percent) had access to these models,
and 68 percent had in-house expertise in the use of these models. There were
about 430 applications of these models in FY 1984, with the COM, RAM, and CRSTER
models having the most applications.
The second group of models included ISCLT, ISCST, MPTER, and CDMQC. Again,
most agencies had both access to and expertise in the use of these models.
There were about 542 applications of these models, with the ISCST being used
the most.
The third group included the screening models PTMAX, PTDIS, PTMTP, PTPLU,
VALLEY, and COMPLEX I, as well as agency-specific screening techniques.
Eighty-eight percent of the agencies had access to and 83 percent had expertise
in the use of screening models. Nationwide in FY 1984 there were about 1,900
uses of either the EPA screening models or agency-specified screening tech-
niques. A majority of these applications used the PT-type models or the
VALLEY model. A few agencies have developed their own algorithms for screening
analysis.
The last category included EKMA, Urban Airshed, PAL, and PLUVUE, along
with other agency-specified models. There were about 300 uses of models in
this category, most of which employed EKMA, CALINE-3, or an agency-specific
model.
The number of modeling applications varied considerably from agency to
agency. The average number of uses per agency was about 52 in FY 1984, with a
range of 0-349. It was not possible to determine the complexity of each
modeling application. From this portion of the audit, therefore, it could not
be determined whether the agency had adequate staff to conduct the number of
applications that were reported.
Question C.2b asked the agencies to identify the method of access to dis-
persion modeling programs. One-half of the agencies had access to an in-
house dedicated computer, 37 percent used telephone lines to access a nonagency
state/local computer, 27 percent used telephone lines to communicate with EPA's
computer, and 7 percent used a private firm's computer. Several agencies had
access to models on more than one system.
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Question C.2c was asked to determine if the agencies had the expertise to
modify the software for UNAMAP models, and, if so, to identify which models had
been modified. Two-thirds of the agencies reported that their staff has the
capability to modify the algorithms of the models. Many of the software modifi-
cations that have been made can be grouped into two general categories: (1) changes
to the input/output format in order to make data entry simpler or report output
easier to read; and (2) changes that were necessary to get the model to compile
and run on the agency's computer. The agencies involved were convinced that
neither of these types of modifications should cause the model to compute
results that are different from the guideline model result. However, a few
agencies made modifications to UNAMAP programs that would significantly change
the results of the model.
Table C-2 contains the information from the questions discussed above.
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TABLE C-2
Accessibility, Expertise, and Use of Models
C2al Which version of UNAMAP does
staff access?
55% 17% 3%
25%
C2a2 Summarize general capabilities
with the following types of
models:
EPA Guideline Models
Models recommended in EPA
Regional Workshop Report
EPA Screening Techniques
Other Models
Expertise # of FY 1984 # of FY 1984
Access to Run Applications Applications
78%
78%
88%
68%
68%
73%
83%
60%
430
542
1792
300
14%
18%
58%
10%
In-House State/Local EPA Private
Computer Computer Computer Computer
C2b How are models accessed?
41%
30%
22%
7%
C2c Does staff have ability
to modify software for
models?
Yes
67%
No
25%
NA
8%
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Nonrecommended Modeling Techniques (Questions C.3a-d)
Question C.3a asked the agencies to report the number of regulatory modeling
analyses performed by the agency in FY 1984 where it was necessary to use techniques
not specifically recommended in EPA guidance. (Note: One State reported a
very high number of modeling analyses. These analyses were not included in the
statistics in this section in order to keep the discussion representative of
the other 59 agencies that responded.) The responses indicated that 352 out of
1,734 modeling analyses used some nonguideline technique. The reasons for
using the nonguideline technique were solicited in Questions C.3b and C.3c,
relating to eight specific nonguideline techniques.
The use of a nonguideline model was reported in 213 cases. For most of
these analyses, the agencies reported that the nonguideline model was judged
to be technically more appropriate for the given situation than the guideline
model. However, in only a small percentage of these cases was the non-
guideline model chosen to be more appropriate because of a detailed performance
analysis of the guideline versus nonguideline model.
There were 16 analyses performed using a guideline model that had been
modified to use a nonguideline technique, 20 cases of using a nonrecommended
option of a guideline model, and 15 cases of using a guideline model outside of
its stated limitations. There were many reasons why nonguideline modeling
techniques were used, but there was not enough detail given to determine if
there were any specific areas where the agencies had problems with the EPA
guidelines.
The agencies were asked to indicate the number of modeling analyses that
did not use recommended EPA guidance in four areas related to meteorological
data, background concentrations, treatment of calms, and design of receptor
network.
There were 135 cases where the agencies did not follow EPA's recommended
use of 5 years of off-site or 1 year of on-site meteorological data. The two
reasons most often cited for not following the EPA's recommendation were that
5 years of off-site or one year of on-site were not available to the agency, or
that the agency had determined a "worst case year" to be used instead of the
full 5-year period. One agency cited the cost of running the models as the
reason for not following EPA guidance.
There were many fewer cases of not following EPA guidance in the other
three areas. Agencies reported 32 cases related to the background air quality
determination, 13 cases related to treatment of calm wind conditions, and 18
cases related to receptor network design. There was not sufficient detail in
the responses to determine specific problems that the agencies had with EPA
guidance.
The final question in this area concerned the degree of concurrence by the
EPA Regional Office with the nonguideline techniques employed by the State/
local agency. Fifty-two of the nonguideline model ing analyses were approved
by EPA without major reanalysis by the agency, and only 10 were not approved by
EPA. EPA concurred with three analyses only after major revisions to the
analyses were made by the agency. Only four analyses involving nonguideline
techniques are still awaiting a decision by EPA. Finally, 115 of the analyses
were never submitted or did not require EPA concurrence.
Table C-3 contains the information discussed above.
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TABLE C-3
Use of Nonrecommended Models
C3a How often were nonguideline
modeling techniques used in
FY 1984?
C3b
C3c
C3d
When nonrecommended models
were used, indicate
how often the following
alternatives were used:
When nonrecommended data
bases were used, indicate
how often the following
aspects of the modeling
analyses were important:
When nonrecommended
techniques were used,
indicate how often EPA
ultimately concurred
with the analysis:
Recommended
Techniques
1,449 (80%)
Nonrecommended
Techniques
352 (20%)
213 Use of nonguideline model
16 Modification of guideline model
20 Use of nonrecommended option of a
guideline model
15 Use of guideline model outside its
stated 1 imitations
16 Other
135 Use of less than 5 years of
off-site or less than 1 year of
on-site meteorological data
logical data
32 Use of nonguideline techniques for
determining background
13 Use of nonguideline techniques for
treatment of calms
18 Use of nonguideline techniques for
design of receptor network
28% EPA concurred without reanalysis
2% EPA concurred after major reanalysis
5% EPA did not concur
2% Awaiting EPA decision
63% EPA concurrence not sought
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EPA Review of Agency Analyses (Question C.4)
The intent of this question was to determine the frequency of approval/
disapproval of State/local agency modeling analyses by EPA when approval or
action by EPA is required. The EPA Regional Office was asked to provide the
number of analyses reviewed by EPA, the number of analyses requiring revision,
and the factors that contributed to requiring a revised analysis. The responses
were grouped into six regulatory areas: (1) bubble (emission trades); (2) sec-
tion 107 redesignations; (3) NSR (including PSD); (4) nonattainment area SIP
analyses; (5) Pb SIP's; and (6) other SIP modeling.
Thirty two percent of all modeling analyses submitted for review to the
EPA Regional Offices were returned to the State/local agency for revision.
For bubble applications, 13 of 15 analyses reviewed by the EPA Regional
Office required a revision to the original analysis. From the responses, it
appears that there is not a particular factor that contributed to requiring a
revised analysis. Rather, it appears that the State/local agency had general
problems understanding and responding to EPA guidance related to modeling for
emission trades.
Twenty-eight percent of the analyses in the other five areas were sent
back to the State/local agency for revision. The primary factor contributing
to requiring a revised analysis was that the original analysis was judged to
be technically inadequate by EPA. There was insufficient detail available from
the survey to identify specific problem areas that required reworking of the
State/local agency analysis.
Table C-4 shows the types of modeling applications and the number that
required revision by the agencies.
TABLE C-4
EPA Review of Agency Analyses
C4 Indicate the number of analyses requiring EPA approval and the results of
EPA's review in the following areas:
# of Analyses # of Analyses
Reviewed Requiring Revision
Bubble (emission trades) 15 13
Section 107 redesignations 68 25
New source review (including PSD) 104 11
Nonattainment area SIP analyses 21 12
Lead SIP's 19 8
Other SIP modeling 33 13_
Totals 260 82
What were the contributing factors that required a revised analysis?
9% Agency did not know or ask for EPA guidance
20% Agency misinterpreted or misunderstood EPA guidance
18% Agency misapplied or did not follow EPA guidance
0% No guidance available from EPA
36% The analysis was judged technically inadequate by EPA
18% Other
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Agency Review of Industry Analyses (Question C.5)
This question asked the State/local agencies to identify the number of
analyses submitted by industry to the agency for review and the result of that
review. The agencies were to list the contributing factors that required a
revised analysis. The responses were grouped into five categories: (1) bub-
bles (emission trades); (2) section 107 redesignations; (3) NSR, including PSD;
(4) Pb SIP's; and (5) other source-specific SIP modeling.
State/local agency review of modeling analyses performed by industry
resulted in 32 percent (124 of 393) of the analyses being sent back to the
responsible party for revision. Every area except Pb SIP's had a high percentage
of the analysis returned for revision. Thirty-six percent of those analyses
requiring revision were considered to be technically inadequate by the reviewing
agency. Forty-eight percent required revision because the responsible party
either was unaware, did not understand, or did not follow agency guidance for
the particular analysis.
Table C-5 shows the types of modeling applications and the number returned
to industry by the agencies.
TABLE C-5
Agency Review of Industry Analyses
C5 Indicate the number of analyses performed by industry requiring concur-
rence by the control agency and the results of the agency's review in the
following areas:
# of Analyses # of Analyses
Reviewed Requiring Revision
Bubble (emission trades) 12 8
Section 107 redesignations 13 11
New source review (including PSD) 268 85
Lead SIP's 15 1
Other source-specific SIP modeling 85 19
Totals 392 124
What were the contributing factors that required a revised analysis?
11% Responsible party did not know or ask for agency's guidance
13% Responsible party misinterpreted or misunderstood agency's
guidance
23% Responsible party misapplied or did not follow agency's
guidance
2% No guidance available from State or local agency
36% The analysis was judged technically inadequate by agency
15% Other
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D. SIP EVALUATION AND IMPLEMENTATION
Introduction
An evaluation of SIP development and implementation activities was designed
to assess whether State plans for attainment are being reasonably carried out.
The evaluation was also designed to identify needs of State and local agencies
in developing and updating SIP's. This section of the report summarizes major
findings in these areas and presents detailed information in each of the audit
areas. Audit questions covered by the SIP Evaluation and Implementation
section of the Air Quality Planning and SIP Activity audit include:
Timeliness of Regulatory Development,
Timeliness of Studies,
Regional Consultation,
Transportation Control Measures,
Reasonable Further Progress,
Source Activity,
Continuous Emission Monitoring, and
Generic Bubbles.
Major Findings and Conclusions
The SIP evaluation and implementation audit identified that 44 percent of
the SIP revisions and strategies due or overdue by the end of 1984 had not been
completed, and of those completed, 27 percent had not been submitted. In
addition, the audit found that 43 percent of the revisions and strategies
incomplete were behind schedule.
Attempts were made to determine causes for delays to SIP revisions and
strategies. Survey results were inconclusive. Questions asked included if
there was a tracking system, and if governmental oversight caused delays.
No correlation was found between those agencies that did not have a for-
malized tracking system and regulatory delays. Likewise, no additional
delay was found for those agencies that reported governmental oversight
problems vs. agencies that did not have governmental oversight. For those
agencies reporting governmental oversight problems, State laws and State
procedures would have to be revised to alleviate the problem.
The audit also determined that a very significant number (48 percent)
of additional studies (such as nontraditional TSP or CO hotspots) due by
the end of 1984 had not been completed, and that 64 percent of these were
behind schedul e.
The audit determined that agencies regularly consulted with EPA Regional
Offices concerning bubbles and other source-specific revisions. Regional
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Offices, however, were only consulted in slightly over half the cases
involving variances. Agency staff personnel responsible for source-specific
revisions stated that they had access to current EPA policy and criteria
concerning SIP revisions.
The audited agencies indicated that an unusually high number (87 percent)
of all transportation control measures required by SIP's were being imple-
mented, while 6 percent of the required TCM's were not being implemented.
Seven percent of the agencies did not respond. Additional review of TCM
implementation and effectiveness may be in order in future audits.
It was found that many agencies are not comparing changes in emission
inventories with projected emission changes given in the 63 or CO RFP curve
in the SIP. For 03, 72 percent of all cases were tracked to ensure reason-
able further progress (RFP). For CO, only 37 percent of all cases were
tracked to ensure RFP. As previously noted under the Emissions Inventory
section, RFP as originally contemplated for long-term tracking and planning
may not be a viable tool.
Continuous emission monitoring required under 40 Part 51.19 was being
completely implemented by State and local agencies in 59 percent of all
cases, partially implemented in 13 percent of all cases, and not implemented
28 percent of the time.
Based upon the data available from this audit and a subsequent follow-
up survey of EPA Regional Offices, it appears that the issue of EPA-approved
generic bubble rules must be clarified. States that are operating generic
programs without EPA approval are placing the "impacted" sources in jeopardy
of potential EPA actions to enforce the original SIP limits. Also, the
submission of approved generic bubble actions to EPA by States should be
increased.
Responses to Individual Questions
Timeliness of Regulatory Development (D.I.)
One of the purposes of the audit was to determine how effective State
and local agencies are in revising and adopting State implementation plans
and lll(d) plans. Questions asked in this regard were intended to identify
if there are delays in regulatory development, and if so, to determine the
type of delays so corrective action could be implemented. EPA Regional
Offices provided to each agency a list of SIP revisions or strategies that were
due or overdue by the end of 1984. The list included Part D plans, non-Part
D plans, and other SIP requirements. States were requested to complete a
table showing whether action had been completed and submitted, completed
and not submitted, not completed but on schedule, or not completed and not
on schedule. National summaries to this question are shown in Table D-l.
Of the 256 revisions or strategies due or overdue by the end of 1984,
States and local agencies responded to approximately 99 percent. Overall,
141 out of 256 revisions or strategies had been completed (55 percent),
while 112 had not been completed (44 percent). Of those not completed, 64
of 112 (57 percent) were on schedule, while 48 (43 percent) were not on
schedul e.
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111-34
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The audit then asked if agencies tracked implementation of these activities
using a management system with key dates and periodic reports, or whether a
staff person was assigned to track all dates on a periodic basis. Seventeen
of 61 agencies (28 percent) reported that they used a management system; 23
agencies (38 percent) assigned a staff member; and 6 agencies (10 percent)
did both. Eight agencies (13 percent) either did not track dates, had no
formal procedures, or used other mechanisms to assure implementation. Eleven
agencies (18 percent) did not respond to the question. No correlation was
observed between those agencies that did not have a formalized tracking system
and regulatory delays.
The audit also questioned whether delays in State action were due to
required approval at a level above the agency, e.g. legislative or executive
branch oversight, and if so, the length of such delays. Twenty-three of
61 agencies (38 percent) reported delays in State action due to oversight,
while 31 agencies (51 percent) reported no oversight delays. For seven
agencies (11 percent), the question did not apply. Of those responding
positively, nine agencies (39 percent) stated that legislative oversight
caused delays, while eight agencies (35 percent) stated executive oversight
(including environmental and pollution control boards, caused delays. The
remainder of the responses did not fix blame with one branch of government
or another.
Figure D-l shows the length of delays for those agencies responding
affirmatively. The weighted average length of such delays was 9 months. One
agency reported a 2 year delay. Again, responses to this question were
compared with regulatory delays to determine whether a correlation existed
between delays in regulations and legislative or executive oversight. No
correlation was observed.
For those agencies that reported delays due to governmental oversight, the
audit questionnaire asked which of the following action would reduce delays:
EPA discussion with appropriate State officials,
Revision to State's internal procedures,
Revision to State regulation,
Revision to State law,
Revision to State constitution, or
Other changes.
Of the 23 agencies that reported delays due to government oversight, 18
agencies responded to the question. Because these questions are not mutually
exclusive, many States responded more than once. Of the 30 suggested actions
received, 3 (10 percent) stated EPA discussion with State officials would help,
8 (27 percent) would need to revise State internal procedures, 1 (3 percent)
would need to revise State regulations, 13 (43 percent) would need to revise
State laws, and 1 (3 percent) would need to revise the State constitution.
There were four other responses, such as no action, or EPA should change its
policy. Figure D-2 graphically presents the responses to the question.
111-35
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Figure D-l. Length of delays due to oversight
111-36
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Figure D-2. Actions to reduce government oversight.
111-37
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Timeliness of Studies (D.2.)
EPA Regional Offices provided to State and local agencies a list of
additional studies, such as nontraditional TSP or CO hot-spots, that were due
by the end of the 1984. As in "Timeliness of Regulatory Development," agencies
were requested to complete a table showing whether action had been completed
and submitted, completed and not submitted, not completed but on schedule, or
not completed and not on schedule. Of the 46 cases listed by the Regional
Offices, 24 had been completed (52 percent) while 22 (48 percent) were not
completed. Of those completed, 6 cases (25 percent) had not been submitted
to EPA. Of those not completed, 14 cases (64 percent) were behind schedule.
Regional Consultation (D.3.)
EPA Regional Office were asked how often State and local agencies consulted
with them formally before submitting SIP revisions. According to Regional
Office responses, State and local agencies consulted on 18 variances and
submitted 31, consulted on 38 bubbles and submitted 38, and consulted on 41
other source specific actions and submitted 41. Although the reported number
of consultations and submittals are the same for bubbles and for other
actions, this does not mean that State and local agencies consulted with
EPA prior to each submittal. In 34 percent of these cases, agencies either
consulted with EPA and did not submit revisions, or submitted revisions
without consultation.
State and local agency officials were then asked if staff personnel
responsible for source-specific revisions had access to all current EPA policy
and criteria concerning SIP revisions. Forty-seven of 61 agencies said yes
(77 percent), one agency said no (2 percent), and 13 agencies either did
not respond, or the question was not applicable (21 percent).
Agency officials were then asked how guidance was disseminated within
each agency. The agencies that answered affirmative to the question above
distributed copies of EPA guidance to the appropriate personnel. Of these,
25 agencies indicated that they also used other methods of disseminating
information, such as using a policy manual, a summary memo, or periodic
staff meetings.
Transportation Control Measures (D.4)
EPA Regional Office supplied State and local agencies with a list of
transportation control measures (TCM's) that were to be implemented in
accordance with the SIP. Agencies were then asked whether the TCM's were
being implemented. Of the 294 measures listed by the Regional Offices, the
agencies stated that 255 measures (87 percent) were being implemented, and
17 measures (6 percent) were not being implemented. This positive
implementation response seems extraordinarily high. No answer was given
for 22 measures.
State and local air pollution control officials were then asked to
indicate how the air pollution control agency tracked TCM implementation.
111-38
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Of 33 agencies required to implement TCM's in accordance with
their SIPs, 28 (85 percent) tracked TCM implementation by receiving reports
from the implementing agencies. Eighteen air pollution control agencies,
some of whom also received reports, had membership on the Metropolitan
Planning Organization (MPO) committee that enabled them to track TCM imple-
mentation.
Reasonable Further Progress (D.5.)
Section 172 of the CAA requires SIP's to provide for revision
and resubmission of emission inventories to ensure RFP toward attainment.
EPA Regional Offices provided a list of of 03 and CO extension areas to
State and local agencies and asked if the agency compared changes in the
emission inventory with projected emission changes given in the 03 or CO
RFP curve in the SIP. Of the 78 03 areas listed by the Regional Offices,
agencies reported that 56 areas (72 percent) were tracked to ensure RFP, 15
areas (19 percent) were not tracked, and 7 areas (9 percent) had no response.
Of the 83 CO areas listed by the Regional Offices, agencies reported that
only 31 areas (37 percent) were tracked to ensure RFP, 46 areas (55 percent)
were not tracked, and 6 areas (7 percent) had no response. Figures D-3 and
D-4 show the 03 and CO responses.
Agencies that answered affirmative to 03 and/or CO tracking were then
asked if they prepared a report of the comparisons, if the report had been
submitted to EPA, and if the report was made available to the public.
Twenty-two agencies indicated that they prepared a report of the comparisons,
18 agencies stated that they submitted the report to EPA, and 8 agencies
made the report available to the public. Based on the response to this
question, the RFP program cannot be considered as viable an effort as
originally contemplated by EPA.
Source Activity (D.6.)
The audit questionnaire asked how often State and local agencies
periodically compared actual source activity (i.e., increases or decreases
in growth) with past projections. Forty-five of 61 agencies responded (74
percent). Of the respondents, 21 agencies compared actual source activity
every 1 to 2 years (47 percent), 9 agencies (20 percent) compared actual
source activity every 2 to 5 years, while 15 agencies (33 percent) compared
actual source activity at intervals greater than 5 years.
Continuous Emission Monitoring (D.7.)
Part 51.19 of EPA's regulations on SIPs requires agencies to adopt
continuous emission monitoring (CEM) for selected categories of existing
stationary sources. These categories include steam generators, nitric acid
(HNOs) plants, sulfuric acid (H2S04) plants, and fluidized bed catalytic
cracking units. Agencies were to respond if they required CEM completely,
CEM partially, or no CEM. These responses are summarized nationally in
Table D-2. For those agencies responding that had sources within their
jurisdiction, 59 percent completely required CEM, 13 percent partially
required CEM, and 29 percent did not require CEM.
111-39
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No response (9.0%)
RFP not tracked (19.2%)
RFP tracked (71.8%)
Figure D-3. RFP tracking for ozone.
No response (7.2%)
RFP not tracked (55.4%)
RFP tracked (37.3%)
Figure D-4. RFP tracking for carbon monoxide.
111-40
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111-41
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Generic Bubble Rule (D.8.)
States and local agencies were asked in the audit questionnaire if they
had a generic emission trading (bubble) rule, if EPA had approved the rule,
and the number of bubbles submitted to the EPA Regional Offices in FY 1984.
Also, in preparing this report, the Office of Air Quality Planning and
Standards has included clarifying information obtained from the EPA Regional
Offices after the individual audit reports were completed.
Nineteen States indicated in the questionnaire that they have generic
bubble rules. Of the 19, only 8 have generic rules which have been formally
approved by EPA. To have operable programs, the remaining States should
either have these overall rules approved by EPA rulemaking or submit indi-
vidual bubble actions to EPA as SIP revisions. If States do not, the
source may be subject to EPA enforcement action (because the source is not
in compliance with the EPA-approved SIP).
Bubbles Issued Under EPA-Approved Generic Rules
State and local agencies were asked in the questionnaire to indicate
the total number of bubbles ever issued under their generic rules. Six of
the agencies with EPA-approved generic rules have issued only four bubbles
(total) under these rules. Two of these four individual bubbles were
submitted to EPA for approval anyway.
The audit results indicated that the other control agencies with
approved generic rules have issued about 31 individual bubbles. Fifteen of
these 31 were granted by one State. Many of these 15 generic bubble actions
have problems. After consultation with the appropriate EPA Regional Office,
it was determined that most if not all, have averaging periods longer than
24 hours, although the State does not have the authority under its EPA-
approved generic rule to issue bubbles with averaging times in excess of 24
hours.
Consultation with the Regional Offices revealed that some of these
same 15 bubbles may also have the following problems:
--Not all VOC bubbles for surface coating operations were calculated on a
solids-applied basis. (This has the effect of making the State emission
limit less stringent than the approved SIP.)
--Some of these bubbles were granted for sources in differing nonattainment
demonstration areas. (This error probably adds emissions to a control
strategy demonstration with no corresponding deduction in that same
area--i.e., there is no bubble.)
The Region has written to this State identifying these problems.
Of the 16 remaining bubbles issued under generic rules by the other
State, two of these were explicitly reviewed by the EPA Region and found
to have problems. The difficulties uncovered were--
111-42
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--revoking the SIP limit on a source (increasing emission) while failing
to tighten the limit on other sources (decreasing emission); and
--failing to identify the sources providing credit and establishing
no source-specific limits on sources providing credit.
The quality of the other 14 bubbles in this State is unknown.
Bubbles Issued under Generic Rules Not Approved by EPA
Forty-eight bubbles were approved by States under generic rules
that were not approved by EPA. All these bubbles should have been sub-
mitted to EPA for formal approval. Three of the bubbles approved by one
State were submitted to EPA for approval. One State refused to submit any
of its 15 bubbles. A second State would not submit any of its 18 bubbles
because it did not see a need to. A third State has been informed that it
needs to submit its 12 bubbles, but has only submitted 2 since the audit.
Lack of formal EPA regulatory action on these individual bubbles again
places the sources in question in jeopardy of EPA enforcement action based
on the approved SIP limits.
The audit could not determine if there are other States with generic
rules that were not reported.
111-43
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IV. NEW SOURCE REVIEW
EXECUTIVE SUMMARY
EPA made a notable change in its method for gathering information for
the FY 1985 new source review (NSR) audit. This change involved the shift
from last year's comprehensive interview of agency staff to an almost exclusive
focus on the examination of agency permit files. This change added a new
dimension to the audit in that while EPA could continue to evaluate the
performance level of the State and local agencies, it is also able to gain
a better perspective of how the problems identified affect the collective
population of permits being issued.
For FY 1985, the NSR audit once again examined the seven major audit
topics originally selected by the NSR audit committee for the FY 1984 audit.
The seven audit topics and an overview of the findings for each topic are
provided below. EPA conducted on-site audits of 64 air pollution control
agencies, including 48 States,1 the District of Columbia, Puerto Rico, the
Virgin Islands, and 13 local government programs.
Altogether, the audited agencies processed approximately 17,150 permits
for new and modified sources of all types and sizes during the time period
upon which this audit report is based. In turn, EPA auditors spent slightly
less than 950 hours examining to varying degrees a total of 748 permit
files. Auditors carried out a comprehensive examination of about 60 percent
of these files by completing detailed questionnaires in accordance with
the FY 1985 NAAS guidance. These questionnaires were then forwarded to EPA
Headquarters, keyed into a computerized audit data base, and analyzed to
prepare this national audit report.
This year's audit findings support many of the findings from the FY 1984
NSR audit. That is, the findings again indicate that most agencies perform
their overall new source review program responsibilities reasonably well,
although, in a number of State and local agencies, problems were identified
with respect to the consistent and adequate application of certain specific
program requirements. In addition, auditors occasionally mentioned that
noticeable improvements had already been observed in the performance of
some agencies where specific deficiencies had previously been found. This
is certainly to the credit of these agencies in their efforts to improve
in-house performance and to strive for a greater level of national consistency.
1 The State of California does not have authority to issue permits and does
not implement a preconstruction review program. Instead, all source permitting
activities in California are performed by local air pollution control
districts. A new source review audit was not done for the State of Hawaii
during FY 1985 because of an EPA Region IX decision not to conduct an
on-site agency visit.
IV-1
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Public Notification Procedures
Overall, agencies generally complied with the public participation
requirements as applied to major sources, although EPA found some incon-
sistencies in the informational content of the public notices. However,
while most proposed permits for NSR/PSD sources were announced to the
public for an opportunity to review and comment, the majority of other
permits were not. This was demonstrated by the fact that EPA found evidence
of public notification in only 38 percent of the non-NSR/PSO permits which
auditors examined. Moreover, more than 40 percent of the agencies reportedly
did not issue public notices for any of the non-NSR/PSD permits which EPA
examined.
Many agencies are reluctant to go through the formal notification
process for each and every permit that they review. EPA agreed, as a result
of last year's similar findings, to reassess the SIP requirement which, when
literally interpreted, requires public notification for all permits. While
this reassessment is being made, EPA plans to continue evaluating and
reporting on each agency's public notification procedures for all permits.
However, EPA will be more critical in its assessment of how well agencies
apply their procedures to major new and modified sources.
Applicability Determinations
A significant number of agencies continued to experience difficulties
with the way that they carry out the source applicablity process. EPA
believes that approximately 15 percent of the audited permits not reviewed
under PSD or NSR requirements probably should have been. In addition, the
lack of sufficient file documentation often precluded EPA's ability to
adequately evaluate the agencies' applicability determinations.
EPA identified various types of problems, but most pertain to the way
that agencies account for a new or modified source's emissions in order to
determine whether a major review would be required under either PSD or
nonattainment area regulations. One particular problem pertains to the
misuse by numerous agencies of the concept of "potential to emit" which
involves the use of Federally enforceable permit conditions to properly
restrict a source's potential emissions (as is often attempted in order to
enable a source to avoid major source review). EPA intends to provide
guidance to agencies providing ways to correctly apply the concept of
"potential to emit." One way in which this will be done is through training
courses beginning in early 1986.
BACT/LAER Determinations
Agencies generally did a good job of applying the BACT requirements to
PSD sources and applicable pollutants. However, EPA concluded that the
quality of the analysis performed to select the level of control defining
BACT on a case-by-case basis could be improved in some instances. As was
the case last year, EPA also found that when a PSD source was subject to
NSPS, agencies had a strong tendency to accept the use of the applicable
NSPS to define BACT. Even though examples of BACT determinations more
stringent than NSPS were identified in PSD permits issued by 12 of 24 agencies,
BACT was established at levels required by NSPS for approximately 80 percent
of the pollutant determinations.
IV-2
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Agencies showed far less tendency to use NSPS for LAER determinations
in nonattainment areas. Slightly over 50 percent of the time, agencies
required pollutants to be controlled at levels more stringent than the
applicable NSPS. Nevertheless, these findings suggest that BACT and LAER
requirements do not yet have the technology-forcing effect that Congress
had envisioned when it established the requirements, and that EPA needs to
provide more explicit guidance for making BACT/LAER determinations.
Ambient Monitoring
This year's audit substantiated a finding that EPA made last year. That
is, agencies commonly allow PSD applicants to comply with the preconstruction
monitoring data requirements by relying upon existing ambient air qualtiy data
instead of new data collected from a special source-operated monitoring
network. EPA accepts the use of such existing data if it can meet certain
criteria for representativeness. Of concern to EPA is the finding that in
almost half of the cases where agencies accepted existing data, the permit
files (a) offered no documented basis for allowing its use, or (b) contained
some description of the data but failed to adequately address or meet all
of the EPA criteria.
Ambient Impact Analyses
EPA verified that agencies generally required ambient impact analyses
to be conducted where needed to ensure protection of the increments and
NAAQS. In addition, most agencies generally used or required the use of
the appropriate models and model options to complete the NAAQS analyses.
However, certain questions arose concerning the quality of these analyses
in a number of cases. With respect to both PSD increment analyses and
NAAQS analyses, agencies did not appear to consistently give thorough
attention to significant emissions from existing sources (major and minor)
located within the impact area of the proposed source. Another key problem
was the lack of sufficient documentation of the details of the analyses.
This prevented EPA from being able to adequately evaluate the adequacy of
the analyses contained in a significant number of files.
Emission Offset Requirements
Only 20 percent of the audited agencies issued NSR permits to major
sources in nonattainment areas during the audit period. EPA's examination
of the NSR permits provided no indication of any nationally significant
problems. As with other phases of the audit, however, EPA encountered
problems with inadequate file documentation and this hindered an adequate
evaluation of the full creditability of some of the emission offsets that
agencies required.
Permit Specificity and Clarity
This year's audit raises the same concern that was originally described
last year about the enforceability, and more specifically the Federal
enforceability, of some of the permits which agencies are issuing. The
acceptable use of physical and operational limitations to restrict the year-
round operation and production capacity of a source hinges upon the Federal
enforceability of the limitations. EPA auditors questioned the enforceability
of such presumed limitations in a number of cases where sources had been
allowed to avoid major source review.
IV-3
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A. INTRODUCTION
For FY 1985, the new source review (NSR) audit examined the ways that
the State and local agencies implement programs for the preconstruction
review of new and modified stationary sources. As was the case for the
previous year, the FY 1985 audit examined the seven basic topics which were
selected by the NSR audit committee. These topics included: (1) Public
Notification Procedures (formerly Administrative Procedures), (2) Applicability
Determinations, (3) BACT/LAER Determinations, (4) Ambient Monitoring (PSD),
(5) Ambient Impact Analysis, (6) Emission Offset Requirements, and (7) Permit
Specificity and Clarity.
While the audit continued to examine the same selected NSR topics, the
approach differed notably in that the FY 1985 audit focused primarily upon
the inspection of State and local agency permit files, instead of gaining
information through the interview of agency staff. Thus, the audit findings
described herein pertain largely to contents of the permit files in contrast
to the focus on agency rules and procedures as described in the FY 1984
audit report.
EPA obtained the information for this audit report through the use of
several types of questionnaires: (1) a permit summary questionnaire which
each audited agency was asked to complete, (2) an NSR audit summary question-
naire which the EPA auditors completed following the actual onsite audit,
and (3) two kinds of permit file questionnaires which were completed by the
EPA auditors during the audit. These questionnaires were used to collect
information found in a selected portion of the total number of State and
local agency permit files which the auditors examined. (Each of the question-
naires was explained in the FY 85 audit guidance manual where copies of
each can be found.)
The NSR audit considered information obtained from 64 air pollution
control agencies, including 48 States*, the District of Columbia, Puerto
Rico, the Virgin Islands, and 13 local government programs. Where a State
program was carried out by one or more offices (i.e., headquarters or
central office plus district offices) and more than one of the offices was
audited, they considered them all as part of one State program (agency).
Local agencies were considered separately, even though there may have been
a dependency on the State agency for certain program operations in some
cases.
For the time period upon which this report is based, the audited agencies
processed approximately 17,150 permits, including 115 PSD and 57 NSR permits.
EPA, in turn, examined 87 percent of the PSD permits, 42 percent of the NSR
permits, and about 4 percent (624) of the other (non-NSR/PSD) permits.
1 The State of California does not have authority to issue permits and does
not implement a preconstruction review program. Instead, all source permitting
activities in California are performed by local air pollution control
districts. A new source review audit was not done for the State of Hawaii
during FY 1985 because of an EPA Region IX decision not to conduct an
on-site agency visit.
IV-4
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While each auditor was encouraged to examine as many permit files as
he or she could, the NAAQS audit guidance did not require the completion of
a questionnaire for each permit file that was examined during the audit.
Instead, a certain minimum number of PSD, NSR, and non-NSR/PSD source
questionnaires was prescribed. The total number of permit file questionnaires
submitted to EPA Headquarters, and subsequently keyed into a computerized
data base and analyzed to prepare the enclosed audit findings, represents
about 60 percent of the number of files actually examined. Reference to a
percentage of the "total number of audited files" as used throughout this
report refers only to those permits which were included in the EPA Headquarters
data base, as follows: 59 PSD permits, 14 NSR permits, 5 permits involving
both PSD and NSR, and 360 non-NSR/PSD permits.
Some findings of general interest are:
0 For 53 of the 64 agencies that were audited, EPA examined all of the
NSR/PSD permits that had been processed during the audit period.
* No NSR/PSD permits at all were issued by 23 of the audited agencies,
while two (2) agencies each issued the highest number (16) of PSD permits;
0 Agencies issued permits to an estimated 1,673 sources whose potential
emissions ranged from 100 to 249 tons per year, but whose preconstruction
review is typically categorized as a "minor" source review. This is because
these sources, locating in attainment or unclassified areas, are not subject
to Federal PSD requirements, i.e., they are not listed under 40 CFR 51.24(b)(1)(i)(2)
Consequently, for them to be classified as "major" PSD sources, each would have
to emit at least 250 tpy of any regulated pollutant.
e EPA auditors spent approximately 945 hours primarily examining agency
permit files. On the average, auditors spent 1-1/4 hours on each permit file
and nearly 15 hours per agency audit. Actual review time for individual
files ranged from 15 minutes to an unusually high 11-1/2 hours.
Finally, auditors were asked, on the audit summary form, to identify
from their own overall perspective, the 5 most significant problems encountered
for each agency audit. From the lists of problems submitted, 4 specific
problem areas stood out as being the most often mentioned. They are:
Problem Area Frequency of occurrence Percent of total
0 Applicability determinations 37 21
0 Permit conditions 29 17
* Documentation 25 14
0 Public participation requirements ZL_ 12_
112 64
Four other problem areas each constituted 5 percent of the total responses:
BACT and LAER determinations, PSD increment analyses, dispersion modeling,
and NAAQS protection.
IV-5
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8. SUMMARY OF MAJOR FINDINGS
This section summarizes the major findings of the 1985 NSR audit. The
findings that are determined to have national implications are discussed in
greater detail than are problems which appear to be more isolated in nature.
For a better understanding of how the major findings were derived, the
reader is referred to Sections IV.C. through IV.I., where a breakdown of
the individual audit questions and reponses is provided.
1. Public Notification Procedures
While most proposed permits for NSR/PSD sources are announced to the
public for review and comment, most other permits are not. EPA found
evidence of public notification in only 38 percent of the non-NSR/PSD source
permits that were examined. Agency rules excluded approximately half of the
minor source permits from the public notification process. (See Figure 1.)
Forty-two (42) percent of the audited agencies did not issue public
notices for any non-NSR/PSD permits which EPA reviewed. One third of the
agencies issued public notices for all permits reviewed, while 25 percent
issued notices for some, but not all, of their audited permits. (See Figure 1.)
Sixty (60) percent of the agencies that issued PSD permits routinely
included the information required by regulation for PSD public notices.
Only half of the public notices for PSD sources included all of the information
required by the PSD regulations. The information most frequently omitted
was the description of the source's estimated ambient impact, including the
amount of PSD increment being consumed.
' Federal Land Managers were not always notified of PSD construction
which might adversely affect Class I areas. Sixteen of 22 PSD permits involving
construction within 100 km of a Class I area were brought to the attention
of the appropriate Federal Land Manager. No record of notification was
apparent in the remaining 6 permit files -- each issued by a different
agency.
2. Applicability Determinations
0 A significant number of agencies are experiencing difficulties in
adequately carrying out the source applicability process. EPA believes that
approximately 15 percent of the audited non-NSR/PSD permit files involved
sources that probably should have been reviewed as major sources. A lack
of adequate file documentation often precluded EPA's ability to adequately
evaluate the agencies' applicability determinations.
* EPA found examples where 13 agencies either failed to consider certain
pollutant-emitting activities at a source, or improperly interpreted an
exemption provision. Only in the latter case, however, were sources enabled
to at least partially avoid major source review. (See Figure 2.)
0 Agencies continue to have problems properly defining a new or modified
source's "potential to emit." Thirty-eight (38) agencies had permit files
which EPA considered to be deficient in some respect concerning the calculation
or use of potential emissions for source applicability purposes. Sometimes,
IV-6
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Figure 1
PUBLIC NOTIFICATION REQUIREMENTS
Agency Performance and Permits Issued
- 42X
Yes. Routinely - 33X
Without P/N - 48X
Undetermined - 14X
Sometimes - 25X
Kith P/N - 3BX
Did Agency Issue P/N's?
X Agencies
How Were Permits Issued?
X Permits
Infornation baaed only on non-NSR/PSO permits
Figure 2
APPLICABILITY DETERMINATIONS
Agency Performance
All Audited Agencies - 100X
Netting' Problems - 31X
Source Problems - 20X
IV-7
Percentages are mutually exclusive.
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but certainly not always, these problems resulted in agencies not subjecting
proposed sources to the correct preconstruction review requirements. (See
Figure 2.)
' EPA identified 20 agencies who either did not require the proper
"netting" procedures to be followed to calculate the change in emissions at
a modified source, or did not provide sufficient file documentation to
enable adequate evaluation of the agency's procedures. In these agencies,
EPA found at least 35 files with procedural or documentation problems.
(See Figure 2.) /-
EPA found no evidence of the improper "double counting" of emission
reduction credits used for netting purposes. Some agencies need to be
more careful about ensuring that each emission reduction credit is made
Federally enforceable--an important criteria for properly using emission
reductions for netting purposes.
3. BACT/LAER Determinations
0 Most agencies routinely complied with the PSD requirement for applying
BACT to each regulated pollutant emitted in significant amounts. EPA found
exceptions in a total of 8 permits issued by 5 agencies. In only 2 agencies
did the problem occur in more than 1 permit.
0 Approximately 85 percent of the agencies who conducted PSD reviews
last year required the evaluation of alternative control strategies as part
of the BACT determination process for at least some of the PSD reviews
which they conducted. However, one-third of the reviews where alternatives
were formally considered failed to fully address the impacts of each alternative
in order to properly demonstrate the rationale for selection of a particular
control technique.
e Twenty-five (25) percent of the agencies who conducted PSD reviews
last year did not appear to consistently check the applicants' BACT analyses
to verify their accuracy. EPA concluded that in some cases little or no
independent agency review was likely to have occurred, while in other
instances it appeared to be more a question of whether the agencies failed
to include documentation of their own analyses.
0 Collectively, agencies showed a strong tendency to accept the use
of the applicable NSPS to define BACT for PSD sources. Even though examples
of BACT determinations more stringent than NSPS were found in PSD permits
issued by 12 of 24 agencies, BACT was established at levels required by
NSPS for approximately 80 percent of the pollutant determinations for BACT
(see Figure 3).
0 Agencies showed far less tendency to use NSPS for LAER determinations
than for BACT. Agencies required emissions limits more stringent than NSPS
to establish LAER in 6 of 11 pollutant determinations, affecting 9 major
nonattainment area sources otherwise subject to NSPS.
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Figure 3
BACT DETERMINATIONS
Relative Stringency of BACT Determinations
Pollutant Determinations
50 r
40
30
20
10
No. of Agencies
Only pollutant determinations for which
KSPS applied were considered
12
Figure 4
AMBIENT AIR QUALITY ANALYSIS
Agency Performance
]Controls none
1 stringent than NSPS
(Controls equal to
I NSPS
Adeq. Analys - 19X
N/A -
.Inadeq. Analys - 16X Typically Adeq - 22X
isuff. Do cum. - iox
N/A - 22X'
consistent - 13X
Insuff. DOCUB - 3X
Inadequate - 22X
PSD Increment
X Agencies
NAAQS Protection
% Agencies
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4. Ambient Monitoring
0 With only a few possible exceptions, agencies typically required PSD
applicants to address the preconstruction montoring requirements where applicable.
Where agencies did exempt PSD applicants from the requirements, permit files
usually provided an adequate demonstration that the proposed sources' impacts
were de minimi's. However, 4 agencies failed to explain why a total of 5 sources
were totally exempted from the monitoring requirements.
Twenty (20) agencies required a total of 34 applicants to comply with
the preconstruction monitoring requirements. Thirty (30) PSD applicants
were allowed to use only existing ambient air quality data. Four (4)
agencies each required 1 PSD applicant to monitor for 1 or more pollutants.
In approximately half of the cases where agencies accepted the use of
existing data, the permit files (a) offered no documented basis for allowing
its use, or (b) contained some description of the data but failed to adequately
address or meet all of the EPA criteria for representative data.
5. Ambient Air Quality Analysis
PSD Increment Analysis—
* Twenty-nine (29) agencies required 46 PSD applicants to meet either
the TSP or S02 increments or both. EPA found no PSD reviews for which an
increment analysis should have been done but was not. However, in more than
half of the affected agencies, EPA found that either: (a) the analyses
did not adequately address existing major and minor source emissions which
also consumed increment, or (b) the permit files did not provide sufficient
information to enable auditors to evaluate the analyses. (See Figure 4.)
* With only one exception, agencies typically gave adequate consideration
to both long- and short-term PSD increments.
0 None of the 16 PSD permits for which agencies required a Class I
increment analysis revealed any problems related to special Class I area
considerations.
NAAQS Protection--
0 EPA did not identify any NSR/PSD permits for which a NAAQS analysis
was completely omitted but should have been required. However, 5 agencies
were found to have (a) incorrectly omitted certain pollutants from analysis,
or (b) lacked a sufficiently comprehensive review of some pollutants.
* Most agencies appear to scrutinize non-NSR/PSD source permit applications
individually to determine whether a NAAQS analysis should be done. However,
18 agencies were found to have issued permits to sources who probably should
have been subjected to NAAQS analyses but were not. Five (5) of these agencies
may not require a NAAQS analysis for any non-NSR/PSD source construction.
8 Thirty-one (31) percent of the agencies had files which typically
(a) lacked sufficient documentation to enable EPA to determine whether and
to what degree source interactions had been considered in the NAAQS analysis,
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or (b) omitted significant emissions from other sources in the vicinity of
the proposed source. (See Figure 4.)
Dispersion Models--
0 Most agencies generally used or required applicants to use the
appropriate models and model options in the NAAQS analyses performed.
However, the lack of sufficient documentation to fully describe the rationale
for the use of particular models and the methods used was a hindrance to
the auditors in many instances.
Apparently, most agencies do not often require minor sources to
perform the modeling analysis. Eighty (80) percent of the time, the minor
source analyses were performed by the agencies themselves; but in the 15
cases where the applicants did submit an analysis, about half of the analyses
did not appear to be adequately checked by the responsible agency.
6. Emission Offset Requirements
0 Thirteen (13) agencies issued NSR permits to major sources in
nonattainment areas. EPA found a few examples of areas where agencies
experienced specific problems but found no examples of emissions offsets
that were not Federally enforceable. Also, agencies typically required
offsets to occur on or before the time of new source operation and to be
expressed in the same manner as emissions used for the demonstration of
reasonable further progress.
0 Four (4) agencies did not provide sufficient information in their
NSR files to enable EPA to adequately evaluate the full creditability of
the emission offsets.
0 Three (3) agencies did not account for area and minor source growth
that had occurred since the last NSR permit and should have been offset
by the proposed source.
7. Permit Specificity and Clarity
Twelve (12) agencies did not appear to routinely state or reference
each source's allowable emissions in the applicable permit. The omission
appeared to be a common occurrence, at least for non-NSR/PSD sources, in
8 of these agencies.
0 At least 15 agencies did not appear to routinely identify each emission
unit along with its allowable emission limit in the permits. In some cases,
it may be agency policy to do so primarily for PSD permits or where needed to
avoid NSR/PSD review.
Nineteen (19) agencies reportedly either did not at all or did not
consistently state or reference compliance test methods in the permits.
Where the practice is not followed consistently, it is not clear what
criteria, if any, agencies use to determine whether the methods are to be
stated or referenced in the permits.
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C. PUBLIC NOTIFICATION PROCEDURES
The audit examined State and local agency procedures for notifying the
public of proposed permit actions. These procedures were reviewed with
specific concern for (1) the types of sources for which notices were issued,
(2) the adequacy of the information contained in the notices, and (3) the
extent to which other agencies and officials are informed of pending permit
actions which could affect their jurisdictions.
1. For which new or modified sources was the public afforded an opportunity
to comment on proposed permits?
The FY 1985 audit findings indicate that while most proposed permits
for NSR/PSD sources are announced to the public for comment, most other
proposed permits are not. Approximately 90 percent of the NSR/PSD permits
examined by the auditors were announced through a public notice, while only
38 percent of the audited non-NSR/PSD permits included public notices. In
terms of the agencies who issue the notices for proposed permits, the findings
support the FY 84 audit results which indicated that approximately one-third
of the agencies routinely notify the public of their proposed permits. This
year's findings reveal that:
0 33 percent of the agencies issued public notices for all of the permits
that were examined;
0 25 percent issued public notices for some, but not all, audited permits;
* 42 percent did not issue public notices for any of the audited non-NSR/PSD
permits.
Of the 77 NSR/PSD permit files examined by the auditors, 3 PSD files
and 4 NSR files contained no evidence that the proposed permits were announced
to the public for review and comment. The three PSD permits were issued by
three separate agencies. In one case, the omission of public notification
was a processing error apparently resulting from the fact that the source
was initially reviewed as a minor source. The second involved a PSD source
whose permit was modified and the State did not consider a public notice
appropriate (although the EPA Regional Office disagreed). No explanation
was provided for the omission of the public notice in the third case. Each
of the identified agencies issued at least one other PSD permit during 1984
and for each the public was properly notified.
Four of the 19 audited permit files involving major review in a nonattainment
area contained no evidence that public notification had been provided. Three
of the four NSR permits were issued by the same agency. Auditors did find
that other permits requiring emission offsets were issued by that agency and
public notices were issued for those other permits.
With respect to the non-NSR/PSD files, auditors found many permits for
which there was no evidence of public notification. Only 38 percent of the
audited permit files clearly indicated that public notification occurred.
Of the remainder, auditors concluded that 46 percent had been exempted from
notification by agency rules, and 2 percent were excluded from notification
as a result of a "processing error." The remaining 14 percent of the
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questionnaires contained no response at all to this question primarily because
of the lack of documentation in the files.
In order to help assess the general value of public notification for
non-NSR/PSD permits, auditors were asked to indicate whether the public
notices resulted in any comments. Of those minor permits for which a
public notice was issued, more than half (55 percent) contained evidence
in the files that public comments had been submitted. Most responses did
not indicate how many comments had been received, nor were the auditors asked
to evaluate the quality of the comments.
2. Do the public notices routinely provide adequate information?
Auditors were asked to determine whether the following items of information,
required under the PSD regulations, were included in the public notices
issued by State and local agencies:
a. Opportunity for written comment;
b. Opportunity for a public hearing;
c. Description of the agency's preliminary determination to approve
or disapprove the permit;
d. Description of the source's estimated ambient impact;
e. Statement of the availability of additional information for public
inspection.
Of the 38 agencies issuing PSD permits during the FY 1985 audit period,
60 percent routinely addressed the information requirements in an adequate
manner. The remaining 40 percent of the agencies were inconsistent at
best. Wherever information was omitted from a notice, a descripton of the
source's estimated ambient impact was always missing. Half the time, other
required information was missing as well. Overall, only half of the public
notices for PSD permits were found to contain all of the required information.
Other types of permits, including those subject to major review in a
nonattainment area typically did not contain all the information items listed
above. The informational content of non-PSD permits is not as clearly
delineated by regulation, so the following is provided primarily for comparative
purposes. Frequently omitted from non-PSD permits was the description of
the source's estimated impact. Eight agencies did address source impact in
some of their notices. Less frequently omitted was the agency's preliminary
determination, yet it was not found in 43 percent of the notices.
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?
Auditors identified 13 agencies where it did not appear that this part
of the notification procedure was being adequately carried out. In some
cases it was not apparent that outside agencies or officials were notified.
In a few cases neighboring States were not informed of a proposed source's
impact when appropriate. Approximately 30 percent of the NSR/PSD permit
IV-13
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files contained no evidence of efforts to notify other agencies and officials,
including EPA.
EPA policy calls for the notification of the appropriate Federal Land
Manager (FLM) when a PSD source would propose construction within 100 km of
a Class I area. Twenty-two (22) PSD permits issued by 14 agencies, involved
construction within such range. Auditors verified that 16 of the 22 PSD
permits were brought to the attention of the appropriate FLM. No record of
notification was apparent in the remaining 6 files—each issued by a different
agency.
D. APPLICABILITY DETERMINATIONS
The specific types of requirements which are to apply to a proposed
new source or modification are generally based on the size of the new source
or modification, expressed in terms of its "potential to emit," and the
geographic location where the proposed construction would occur (attainment
vs. nonattainment area). The task of making the appropriate applicability
determinations depends upon the existence of adequate regulations containing
the proper definitions and applicability criteria, plus the in-house expertise
to correctly apply them to each incoming application for a permit.
EPA auditors examined the selected permit files to evaluate each
agency's ability to adhere to the approved definitions of "source" and
"potential to emit," and how well each agency verified and corrected, where
necessary, the emissions estimates provided by the applicants. As was the
case in last year's audit, the overall findings pertaining to applicability
determinations suggest that a significant number of State and local agencies
are experiencing difficulties in adequately carrying out the source
applicability process. Overall, EPA found that:
8 Approximately 15 percent of the audited non-NSR/PSD permit files should
have been reviewed as major sources in the auditors' judgment.
e Another 5 percent of the audited non-NSR/PSD files, did not contain
sufficient information about the sources' emissions to enable the auditors
to indicate whether the correct applicability determinations had been made.
Described below are the findings as they relate to the various aspects
of the applicability determination process.
1. Does the agency properly apply its approved definition(s) of "source"?
EPA found, in 13 agencies, 20 non-NSR/PSD permits for which certain
pollutant-emitting activities had not been considered in defining the
subject source. However, EPA concluded that none of these sources would
have been required to undergo PSD or NSR review.
EPA did, however, identify other problems that, while not related to
the definition of source, involved other source-related issues. These
source-related problems, affecting 13 agencies, kept sources from being
properly regulated under the agencies' permit requirements. No one problem
was widespread, and correction of each would appear to require greater
attention on the part of each agency to correctly interpret its applicable
regulations. EPA identified the following types of problems:
IV-14
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a. Failure to identify the proper SIC classification for PSD applicability;
b. Exemption of certain pieces of equipment when determining source
emissions increases and decreases;
c. Improper exemption of temporary, portable, and stand-by sources
from PSD review;
d. Omission from PSD review of significantly-emitted pollutants
because of the misinterpretation of "major modification" at a source; and
e. Failure to document all or part of the applicability process, thus
preventing adequate judgment of whether "source" was adequately addressed.
2. Does the agency typically use the best available emissions projections
and Federally enforceable limitations in defining a source's "potential to
emit"?
The PTE is a source's maximum capacity to emit a pollutant under its
physical and operational design. In order for any physical or operational
limitation (e.g., less than 24-hour, year-round operation, fuel usage
restriction) to be considered part of the source's design, thereby restricting
the maximum pollutant-emitting capacity of the source, the limitations must
be Federally enforceable. The major status of new or modified sources must
be determined on the basis of their potential emissions.
Thirty-eight (38) agencies were found to have a problem with their
procedures for establishing a source's "potential to emit" (PTE). Sometimes,
but certainly not always, these problems appear to have resulted in incorrect
applicability determinations. Problems related to the agencies' determinations
of PTE can be broken down as follows:
a. Failure to ensure the Federal enforceability of all physical and
operational limitations used in the PTE calculations;
b. Failure to address the major source status (PTE) of the existing
facility at which a modification is being proposed;
c. Use of emissions factors that are not well-established or well-
documented; and
d. Failure to include quantifiable fugitive emissions where applicable.
For any one or more of these reasons, EPA considered the PTE determination
in approximately 30 percent of the audited non-NSR/PSD source files to be
deficient. More importantly, at least one-fifth of the files where EPA
found deficiencies reportedly should have been reviewed as major sources.
In 36 agencies, EPA found permit files for which the agencies (a) did
not properly ensure the Federal enforceability of all physical and operational
limitations upon which emission estimates were calculated, or (b) did not
adequately consider the potential emissions of existing facilities where a
modification was being proposed.
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EPA identified at least 28 permits where the agencies simply did not
establish permit conditions defining the necessary limitations upon which
the sources' estimated emissions were based. In other permits, some necessary
limitations were either not addressed at all or were inadequately restricted.
Sometimes the limitations were specified in operating permits which EPA
generally does not regard as being Federally enforceable, but which are
usually enforceable by State and local agencies.
It is also important to point out that some agencies consider the
limitations to be enforceable if they are contained in the permit application.
Apparently some agencies include a general condition in permits, which
links the applicants' plans and specifications to the permits. It is not
clear when and how often auditors took this into account when evaluating the
Federal enforceability of the limitations.
In cases where a permit involved a modification to an existing source,
EPA sometimes found that no determination of the existing source's PTE was
made. While it is true that the existing source's PTE is irrelevant for
the immediate applicability determination, when the proposed emission
increases would not exceed prescribed significance levels, it is nevertheless
important to know what the source's cumulative PTE is for consideration in
subsequent modification proposals by that source. Files, in some cases,
did not appear to contain any documentation of the existing source's PTE or
of cumulative emissions for future reference.
Eleven (11) agencies issued 21 permits (6 percent of the audited non-NSR/PSD
source files) that did not adequately address fugitive emissions. Reportedly,
one source likely would have been required to undergo major source review
if the quantifiable fugitive emissions had been included in the emission
calculations. Twice as many non-NSR/PSD source files, i.e., 12 percent, did
not provide sufficient documentation of the emission calculations, to enable
EPA to verify whether fugitive emissions were properly considered.
Finally, in 24 separate agencies, EPA identified 40 non-NSR/PSD source
permits (11 percent of the minor source permit files audited) where they
concluded that well-established or well-documented emissions factors were
not used to estimate source emissions. An additional 32 files did not
provide enough information to allow a good understanding of how the emission
estimates were calculated.
3. Does the agency use as its netting baseline actual emissions expressed
in tons per year?
No specific problems involving the NSR/PSD permit files were found.
Auditors did indicate, however, that insufficient documentation prevented
an affirmative conclusion from being drawn in just a few cases.
With respect to the non-NSR/PSD files, EPA identified 20 agencies who
either did not require the proper procedures to be used to calculate a net
change in emissions, or did not provide enough information to enable the
auditors to determine whether actual emissions were correctly calculated.
In these agencies, EPA found at least 35 examples of specific procedural
problems or documentation problems. The findings indicate that:
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0 Ten (10) agencies allowed proposed modifications to determine their
net change in emissions on the basis of potential or allowable emissions
rather than actual emissions. At least 5 of the agencies permitted new
replacement units, of equal capacity to units being shut down, without
considering the net change in actual emissions.
e Three (3) agencies did not properly determine actual emissions changes--
2 failed to use a tons-per-year emission baseline, while 1 did not use emissions
that were representative of normal source operation.
e Thirteen (13) agencies did not provide sufficient information in
some files to enable the auditors to determine how the emission changes were
calculated.
4. Does the agency check applications for proper use of contemporaneous
emission changes to prevent the "double counting" of emission decreases
for netting purposes?
No evidence of double counting was found in the audited permit files.
Of some concern, however, is (1) the lack of documentation to verify that
double counting has not occurred, and (2) the apparent failure to make the
emission reduction credits Federally enforceable.
The lack of documentation was indicated in seven agencies as the reason
why auditors could not verify that double counting had not occurred. But
it should be noted that there were no suggestions that any problems were
suspected.
EPA requirements stipulate that emission reductions must be made
Federally enforceable. This was reportedly not done in single permits
found in 10 agencies. In 7 of these agencies, emission reduction credits
were not addressed at all in permit conditions, thus raising the question
of whether the reductions are enforceable even by the affected agencies.
Making the emission reductions enforceable conditions of the permit also
helps to ensure that subsequent double counting of such emissions will not
occur inadvertently.
5. Does the agency properly apply the §107 area designations when determining
what type of preconstruction review will be required of major construction?
No clear examples of the misapplication of §107 area designations were
identified. One agency apparently continues to provide for a "clean spot"
exemption in its permit requirements for nonattainment areas. To date,
however, this apparently has not resulted in any applicability determinations
that are inconsistent with EPA requirements.
6. Verify that the agency does not approve major construction projects in
designated nonattainment areas under an EPA-imposed construction moratorium.
The audit findings produced no problems of national significance.
However, auditors questioned two minor source permits issued to sources
locating in nonattainment areas where EPA had imposed construction bans.
One source actually operated at levels below significant emissions rates,
but was a major source in terms of its potential to emit. No corrective
IV-17
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action was recommended because the source had shut down. In the other case,
the source was approved as a minor source apparently because an allowable
(rather than actual) emission baseline was used for the netting calculations.
A recommendation was made in this case to re-evaluate the permit.
E. BACT/LAER DETERMINATIONS
In this section, the audit examined several aspects of the BACT/LAER
control technology requirements that are generally applicable to PSD sources
and major new and modified sources in nonattainment areas. However, more
weight was given to the BACT analysis for this year's audit. With respect
to BACT, emphasis was put on whether agencies were requiring an adequate
analysis of each regulated pollutant emitted in significant amounts.
Prescribed significance thresholds applicable to each pollutant are defined
by the PSD regulations.
In order to get a better idea of how thoroughly the BACT analyses are
being carried out, additional questions were asked to determine whether the
analyses routinely considered more than one possible control technology,
and whether the agency routinely took it upon itself to verify the analyses
submitted by the applicants.
The audit also sought to determine the extent to which the BACT/LAER
requirements are functioning as technology-forcing requirements. This was
accomplished by asking the auditors to determine the relative stringency
of the BACT/LAER determination for each major source audited on the basis
of applicable NSPS and NESHAP standards, which serve as the minimum control
requirements legally allowed for BACT and LAER.
1. Does the BACT analysis consider each regulated pollutant emitted in
significant amounts?
Of the 32 agencies issuing PSD permits, most appear to be complying
with this PSD requirement. The auditors found exceptions, however, in a
total of 8 PSD permits issued by 5 agencies. In only 2 agencies did the
problem occur in more than one permit.
Some pollutants were not considered for BACT because of an apparent
failure on the part of the audited agencies to address potential emissions,
i.e., actual emissions were incorrectly used. It is presumed that in such
instances when this practice is corrected, any pollutants calculated to be
potentially emitted in significant amounts will be properly considered for
BACT.
2. Does the review agency require consideration of more than one BACT
control technology? If so, to what extent are economic, energy, and
non-air environmental impacts considered?
Last year's audit indicated that most agencies appear to require PSD
applicants to analyze more than one control technique as part of their BACT
selection process. Some agencies noted, however, that this requirement
was not always implemented if a particular control technique was regarded
as "obvious" or common for a particular source. A few agencies claimed
that a preapplication meeting with the applicant was used to determine BACT;
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therefore, an analysis of alternatives did not need to be contained in the
PSD application.
This year's audit findings generally support the agencies' claims in
that most (84 percent) of the audited PSD files did address, to some degree,
consideration of alternative control techniques. However, the overall
quality of the BACT analyses was questioned in a significant number of cases.
Specifically, auditors found that:
0 Fifty-three (53) percent of the agencies where PSD permit files were
examined had files in which control alternatives were routinely considered;
0 Thirty-one (31) percent had some files which addressed alternatives
while other files did not; and
0 Sixteen (16) percent of the agencies had no PSD files which addressed
alternative controls for BACT.
0 One-third of the PSD permit files where control alternatives for BACT
were considered failed to adequately address the impacts of each alternative
in order to demonstrate the rationale for selection of a particular control
technique.
Eighteen (18) PSD permits (approximately 30 percent of the PSD permits
audited), issued by 13 agencies, did not address alternative controls at all.
Yet, it could not be determined in every case that the control technique
used to define BACT was always the most "obvious" choice. Auditors noted
that in some cases the applicant claimed the best control(s) had been selected,
but this was rarely confirmed by the auditor. In some cases, auditors noted
that only NSPS were considered. Thus, it would appear that the omission of
other control techniques from consideration may not always be acceptable.
EPA intends to examine this in greater detail in future audits.
Finally, where agencies claim to conduct a preapplication meeting
with the applicant in order to review candidate control options in advance,
EPA recommends that each meeting should be carefully documented to include
a description of the alternatives considered and the basis for them being
eliminated. Agencies should retain this documentation in the appropriate
PSD files as a formal record of the BACT selection process.
3. What checks does the review agency employ to confirm the applicant's
BACT analysis?
Auditors were asked to determine whether each audited PSD file contained
sufficient documentation to show that the reviewing agency had verified the
applicant's calculations and assumptions for BACT. Auditors did not respond
to the question in a few cases, but the overall findings show that:
0 Sixty (60) percent of the agencies consistently verified the applicants'
BACT analysis;
0 Sixteen (16) percent were inconsistent in that some files demonstrated
the agencies' verification efforts while other files did not; and
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0 Nineteen (19) percent provided no evidence in their files that they
had verified the BACT analyses submitted by the applicant.
Auditors found no apparent agency verification of the applicants' BACT
analyses in 18 PSD permit files. This finding was mixed between situations
where only one control technology was considered and others where several
alternatives were considered by the applicant. The auditors concluded in
some cases that little independent analysis was likely to have occurred
because of the questionable nature of the BACT selections. In other instances,
however, it appeared to be more a question of whether the agencies had
failed to adequately document their own analyses.
4. What tendency is there for the agencies' BACT/LAER determinations to
conform exactly to the minimum requirements, i.e., NSPS or NESHAP standards
where applicable?
For this question, applicable PSD files were examined for the application
of BACT and files for major nonattainment area sources were examined for
LAER. The findings are based on 39 PSD files from 24 agencies and 9 major
nonattainment area source files from 8 agencies. Only sources for which
NSPS standards applied were considered.
a. BACT
There is a strong overall tendency for agencies to accept the use of
the applicable NSPS to define BACT for PSD sources. Even though examples
of BACT determinations more stringent than NSPS were found in 12 of 24 affected
agencies, BACT was defined as the applicable NSPS for approximately 80 percent
of the pollutant determinations which agencies made for PSD sources subject
to NSPS.
The audit findings show that:
e Twelve (12) agencies accepted the applicable NSPS for all BACT
determinations. These agencies issued 18 permits for which 32 pollutant
determinations were made.
* Seven (7) agencies defined BACT more stringently than the applicable
NSPS for at least 1 pollutant but typically accepted NSPS for most pollutant
determinations. In the 15 permits that these agencies issued, BACT was set
at levels more stringent than NSPS for 9 pollutants, while NSPS was applied
to 34 pollutant determinations.
0 Five (5) agencies defined BACT more stringently than the applicable
NSPS for all of their BACT determinations. These agencies issued 6 PSD
permits for which 9 pollutants were controlled beyond NSPS.
e Of 39 PSD sources subject to NSPS, 25 were allowed to use NSPS for
all affected pollutants, while 8 were required to meet control requirements
more stringent than BACT for all affected pollutants.
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b. LAER
As might be expected, agencies showed a significantly greater tendency
to define LAER beyond the applicable NSPS than was the case for BACT deter-
minations. For the 9 permits issued, LAER was defined to be more stringent
than NSPS for 6 pollutants, while the control of 5 pollutants was set equal
to NSPS.
Three (3) agencies allowed 4 sources to meet the applicable NSPS to
satisfy the LAER requirement for a single pollutant in each case. The
other 4 agencies required LAER to be set at levels more stringent than NSPS
for 5 sources for all but 1 pollutant.
F. AMBIENT MONITORING (PSD)
This portion of the audit examined the PSD requirement which provides
that PSD sources must collect air quality data and submit it as part of
their application for a construction permit. The PSD regulations contain,
for each pollutant, specific de minimi's ambient concentrations that are to
be used to determine when a PSD applicant does or does not need to gather
ambient air quality data. For those pollutants for which ambient data must
ultimately be reported, EPA guidelines set forth procedures whereby a
source must either (1) establsh and operate an ambient monitoring network
and collect data for 12 months or less, or (2) analyze existing ambient
data which is "representative" (in accordance with specific EPA criteria)
of the air quality in the impact area of the proposed source.
1. Under what circumstances is a source required to submit preconstruction
ambient monitoring data?
The auditors examined PSD files to determine whether agencies had
followed the correct procedures for requiring applicants to submit ambient
air quality data, either from source-operated monitors or from existing
representative data. Thirty-four (34) sources were required to submit
ambient data. Another 20 sources were correctly exempted in accordance
with the criteria for de minimis situations, but 5 did not address the data
requirements.
Because of inadequate documentation, auditors were unable to ascertain
whether the exemption of 5 sources, allowed by 4 agencies, had been handled
properly. For at least 2 of the exemptions, made by 1 agency, the auditors
believed that the sources' impacts were de minimis and ambient data would
not be needed. For one, however, the auditor believed that the source
should have been required to submit air quality data.
In the 20 agencies requiring that the data requirements be addressed,
most applicants were allowed to use existing air quality data rather than
having to establish a monitoring network to collect new data. The findings
indicated that:
30 sources were allowed to use only existing data for a total of
55 pollutants; and
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8 4 sources (involving 4 separate agencies) were required to monitor
a total of 7 pollutants (but agencies allowed 2 of the sources to use
representative data for 1 pollutant each).
2. Under what circumstances may a source submit existing data, rather than
conduct new monitoring?
Where PSD sources were allowed to use existing data to meet the air
quality data requirement, auditors examined the files to determine whether
agencies followed Federal criteria to ascertain that the existing data was
representative of the area of source impact. The air quality data was
checked for adequate consideration of the location of existing monitors, as
well as the quality and currentness of the existing data.
Seven (7) files from 5 agencies (1 agency had 3 affected files) offered
no documented basis for allowing the use of existing data. Seven (7) other
files involving 6 agencies (including 2 of the 5 already mentioned) contained
some description of the data used but failed to adequately consider or meet
all of the criteria for representative data.
For the 32 PSD sources allowed to use existing data for at least 1 pollutant,
auditor responses given to the Federal criteria for represenative data are
as follows:
YES NO CBD
a. Adequate consideration of monitoring site location 61% 16% 23%
b. Adequate consideration of data's quality 61% 10% 29%
c. Adequate consideration of data's currentness 63% 10% 26%
3. Do the source monitoring data adhere to PSD quality assurance requirements?
In the 4 agencies requiring source monitoring, EPA auditors checked
the 4 PSD files and found that only 1 file contained a monitoring plan.
This file contained, among other things, the applicant's quality assurance
procedures that would be followed for the duration of the monitoring effort.
One auditor indicated that a monitoring plan had been submitted for one
source but the plan was not in the permit file. The remaining 2 files did
not provide any evidence that a monitoring plan had been submitted.
In all 4 cases, applicants conducted the monitoring for 12 months as
generally required by the PSD regulations.
6. AMBIENT AIR QUALITY ANALYSIS
For this section, auditors were asked to examine three main areas of
concern. The first—PSD increment analysis—looked at how well agencies
evaluted PSD permit applications to determine the amount of PSD increment
that would be consumed by the proposed source or modification. Auditors
focused on whether the increment analyses (1) addressed the appropriate
emission changes which affect available increments, (2) considered both
long- and short-term increment averaging periods, and (3) gave adequate
attention to Class I area increments.
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The second area of concern pertains to agency procedures for providing
adequate NAAQS protection. Auditors were asked to determine, for all major
and minor source permits, whether and to what extent each source underwent
an analysis to ensure that the national standards (NAAQS) would not be
violated.
Finally, the auditors evaluated the adequacy of the agencies' models
and modeling procedures. Agencies are expected to use models which have
been approved for use by EPA, but also of importance is that the appropriate
model (and model options) is selected for a particular set of modeling
conditions.
PSD Increment Analysis
The audit findings indicate that 29 agencies required PSD applicants
to perform increment analyses. In these agencies, 46 PSD permits included
analyses of either the TSP or SOg increments, or both. These analyses totaled
43 for S02 and 31 for TSP. Auditors did not find any PSD files for which an
increment analysis should have been done but was not.
1. Does the agency consider the baseline concentration and emission changes
which affect increment consumption?
Seventeen (17) agencies were affected by the auditors' findings that
existing major and minor source emissions are not always being adequately
addressed as part of the required increment analysis. In a few cases, it
was apparent that no emissions other than those emissions resulting from
the proposed PSD source were being addressed. Occasionally, only emissions
from other PSD sources were included in the analysis. The key findings
show that:
0 Approximately 33 percent of the PSD applicants required to analyze
PSD increment consumption failed to adequately address existing major and
minor source emissions which contribute to the amount of increment consumed.
e Approximately 15 percent of the files did not provide enough information
to enable the auditors to evaluate the increment analysis that was done.
0 Minor source growth was not adequately addressed in 30 percent of
the S02 analyses and 20 percent of the TSP analyses.
0 Existing emissions from major sources were inadequately addressed in
10 percent of the analyses for SOg and TSP.
2. Are both long- and short-term PSD increments being given adequate consideration
as part of the increment assessment?
The audit findings indicate that agencies adequately consider both the
long- and short-term increments for S02 and TSP. In only one case did an
agency fail to adequately address both averaging periods. The auditor's
remarks indicated that this was a unique circumstance which was not indicative
of the affected agency's typical performance.
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It is interesting to note that agencies tended to be conservative in
their use of modeling results to determine the amount of increment consumed.
Whereas EPA recommends using the highest of the second highest receptor
site concentrations, agencies used the highest concentration in 65 percent
of the TSP analysis and 51 percent of the S02 analyses.
3. Does the agency make an adequate assessment of the new sources and
modifications affecting the Class I increments?
None of the 16 PSD permits for which a Class I increment analysis was
required revealed any specific problems related to special Class I area
considerations. Seven (7) of the permits were included among those found
to be deficient in the consideration of other emissions changes contributing
to increment consumption. It could not be determined whether and to what
degree emissions not addressed by the applicants may have affected the analysis
of Class I increments as opposed to Class II increments also analyzed for
those permits.
In two cases, auditors made general comments indicating that 2 agencies
needed to provide better protection of Class I areas within their own
jurisdictions. No specific deficiency was identified in either case, however.
NAAQS Protection
1. Does the agency routinely evaluate the ambient impact of minor source
construction?
This year's audit information supports last year's finding that most
agencies do not routinely evaluate minor source construction for air quality
effects. Less than 25 percent (81) of the audited minor source files were
required to undergo a NAAQS analysis. Most agencies did, however, appear to
scrutinize minor source applications individually to determine whether an
ambient impact analysis should be done. But some agencies appear to provide
little, if any, review of the ambient effects of minor sources.
Specifically, the audit results indicate that:
0 Twently-six (26) agencies did not require NAAQS analyses for any audited
non-NSR/PSD source permits. In 5 of these agencies, auditors found sources
which they believed should have undergone analysis but did not.
* Eighteen (18) agencies were found to have issued permits to non-NSR/PSD
sources which, in the auditors' judgment, probably should have been subjected
to an ambient impact analysis but were not. EPA identified a total of
40 permits for which this omission occurred. Forty (40) percent of these
permits were issued by only 3 agencies.
c Overall, approximately 10 percent of the audited non-NSR/PSD source
permits which did not consider ambient effects probably should have because
of the sources' potentially significant air quality impacts.
e In 23 percent of the questionnaires, auditors did not respond when
asked whether a NAAQS analysis should have been done, but was not. This may
suggest that information in the files was insufficient to determine the need
for a NAAQS analysis.
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The auditors also examined the NSR/PSD permit files to determine whether
and how well the NAAQS analyses were performed for major sources. The
findings show that most NSR/PSD sources underwent NAAQS analyses where appro-
priate; 61 files (80 percent of the files audited) included a NAAQS analysis.
The findings also indicate that:
0 Auditors did not identify any NSR/PSD permits for which a NAAQS
analysis was completely omitted but, in the auditors' judgment, should have
been required.
0 Five (5) agencies, each having a PSD file that included a NAAQS
analysis, should have required additional analyses, either for omitted
pollutants or for more comprehensive review of considered pollutants.
0 Auditors did not indicate whether a NAAQS analysis was performed for
2 PSD permits involving criteria pollutants. Nor did the auditors indicate
that a NAAQS analysis should have been performed. It is assumed that the
auditor did not have sufficient information available to them to respond
appropriately to the applicable questions.
2. Does the agency's ambient impact analysis provide adequate protection
against the development of "hot spots"?
Adequate NAAQS protection requires that the reviewing agency give
consideration to the interaction of proposed new emissions with emissions
from sources already in existence (including sources which may have already
received a permit to construct but are not yet operating) and to points of
projected maximum ambient concentrations resulting from multi-source inter-
actions rather than just points of maximum concentrations from the proposed
source alone.
Auditors found that many agencies generally provide adequate NAAQS
protection. Oftentimes, however, a lack of file documentation prevented
the auditiors from making a determination. The NSR/PSD source files tended
to contain better documentation than did the non-NSR/PSD source files. The
audit findings reveal the following:
0 Thirty-four (34) percent of the audited agencies were judged to
provide good or acceptable protection of the NAAQS most, it not all, of the
time.
0 Twenty-two (22) percent of the agencies had files which typically
suffered from insufficient documentation. In these cases, auditors could
not determine whether and to what degree source interactions had been
considered in the NAAQS analysis.
* Thirteen (13) percent of the agencies were found to be inconsistent
in that some analyses adequately considered source interactions but others
did not.
0 Nine (9) percent of the agencies typically omitted significant
emissions from other sources in the vicinity of the proposed source.
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8 Almost 60 percent of the non-NSR/PSD source permits reviewed for NAAQS
protection failed to include sufficient documentation to determine the adequacy
of the ambient impact analysis. Fifteen (15) percent were judged inadequate
in terms of considering multi-source interactions.
0 For NSR/PSD permits, 32 percent of the files reviewed for NAAQS
protection had insufficient file documentation. Thirteen (13) percent were
judged to have inadequate analyses for full NAAQS protection.
Dispersion Models
1. Does the Agency use adequate models to carry out the ambient impact
analysis?
EPA examined the modeling techniques used or accepted by agencies to
analyze PSD increment consumption and potential source impact on the NAAQS.
The audit results indicate that agencies generally used or required applicants
to use the appropriate models and model options. However, the lack of
sufficient documentation to fully describe the rationale for the use of
particular models and the methods used was a hinderance to the auditors in
many instances.
Specifically, the audit findings show that:
e Five (5) agencies used or allowed the use of inappropriate models for
the ambient impact analyses contained in 8 permit files. In only 2 of the
agencies did the problem occur more than once.
e The use of inappropriate models was identified in 2 PSD increment
analyses and in 6 NAAQS analyses involving the review of minor sources. In
at least half of these situations, the models used were inappropriate for
the existing terrain features.
e Permits found in 34 agencies (almost 70 percent of the agencies where
ambient impact analyses were included in the files) did not contain sufficient
information to support the use of the models and model options used. However,
in over 40 percent of these situations, auditors concluded that the appropriate
modeling techniques had been applied.
2. Does the agency perform an independent, internal review of the modeling
analyses contained in the permit application?
Most agencies were found to adequately review the applicants' modeling
analyses; but inadequate reviews were identified in 8 agencies for a total
of 10 permit files. Seven (7) of these files pertained to non-NSR/PSD source
permits; the other 3 were for PSD sources. In only 1 agency did the finding
relate to more than 1 file.
Apparently, most agencies do not often require non-NSR/PSD source
applicants to perform the modeling analyses. Eighty (80) permit of the
time, the source analyses were performed by the agencies themselves.
According to the responses provided by auditors, the applicants were required
to submit a modeling analysis for only 15 of the files that were examined.
Thus, the audit results show that in about half those situations the analyses
were not adequately checked by the agency responsible for the permit review.
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H. EMISSION OFFSET REQUIREMENTS
When a major new or modified source is allowed to construct in an area
designated as nonattainment, emission reductions are generally required to
offset the new emissions. These emission reductions or offsets must meet
specific criteria set forth under Part D of the Clean Air Act in order for
the offsets to be creditable. Auditors examined selected files involving
sources subject to the emission offset requirements to determine whether
they met such criteria as described below.
EPA examined, in 13 agencies, 19 major source permit files involving
construction in nonattainment areas. Of these 19 files, 1 permit was denied,
and 2 were issued under policies which excluded the applicants from having
to obtain emission offsets. The remaining files involved sources that should
have obtained offsets, although some apparently did not.
With regard to the examples where offsets were not obtained, the audit
results indicated that:
0 One agency allowed a source (resource recovery facility) to postpone
the acquisition of offsets because none were available at the time. This
action complied with the agency's rules as contained in its Federally-approved
SIP, but the SIP does not meet the current requirements based on Part D of
the Clean Air Act.
0 Two agencies should have required emission offsets, but apparently
failed to do so. The auditors could not explain why 2 permits failed to
address emission offsets for several nonattainment pollutants.
In examining the emission offsets on the basis of the specific criteria
with which they must comply, EPA found only a few examples of areas where
agencies experienced specific problems. EPA identified no examples of
emission offsets that were not Federally enforceable. Similarly, agencies
typically required offsets to occur on or before the time of new source
operation (with the exception of the one case where offsets were allowed to
be postponed) and to be expressed in the same manner, i.e., actual or
allowable emissions, as for the demonstration of RFP.
Some problems did surface in that:
0 EPA auditors had difficulty determining whether offsets were not
otherwise needed to demonstrate attainment or RFP. Agencies often did not
provide documentation ensuring that this criteria had been met, even though
they may have actually done so.
0 Four (4) agencies did not provide sufficient information in their
files to enable EPA to conduct an adequate evaluation of the full creditability
of the emission offsets.
* Three (3) agencies did not account for area and minor source growth
that had occurred since the last permit. These emissions are to be offset
along with the new emissions from the proposed source or modification.
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I. PERMIT SPECIFICITY AND CLARITY
This final section of the new source review audit provides the results
of EPA's examination of information contained in the permits issued to new
and modified sources. Specifically, auditors were asked to examine how,
and whether, permit conditions defining limitations applicable to the approved
source or modifications are being established. Such limitations typically
become the enforceable measures by which a source's construction and operation
is regulated, and the means by which ongoing compliance is determined.
1. Does the agency adequately state or reference allowable emissions rates
in each permit?
EPA identified 12 agencies that did not routinely state or reference
each source's allowable emissions in the permits. The omission appeared to
be a common occurrence, at least for non-NSR/PSD permits, in 8 of these
programs.
An analysis of the individual permit file questionnaires shows that
approximately 30 percent of the non-PSD/NSR construction permits in the
audit data base did not specify the allowable limits. This finding must be
qualified, however, because of the ambiguity of the instructions provided
to the auditors by the questionnaire. Those instructions easily could have
been interpreted by auditors as asking them to provide only the number of
emissions limits actually specified in the permits, and not cases where a
reference was made to a regulation containing the required limit. It is
not clear how many of the responses took referenced limits into account (as
was intended), but it is known that some did not.
The same qualification must be given for the results pertaining to
NSR/PSD permits as well, although the ambiguity did not appear to have much
effect on the findings. There were no permits for which auditors specifically
said no limits were found, but auditors did not respond to the question in
5 cases.
Where limits were specified in the permits, auditors were asked to
evaluate them in terms of their clarity, consistent with measurement techniques,
and Federal enforceability. In most cases, the permits contained more than
one emission limit. Where at least one of the limits was determined to be
inadequate with respect to any of the variables considered, that file was
rated inadequate as a whole. The percentages, as shown below, are based on
the total number of permits which contained emission limits.
a. Clear and precise averaging
periods
b. Emissions rates consistent
with acceptable measurement
techniques
c. Federally enforceable
PSD/NSR Permits
YES. NO CBD_
75% 18% 7%
78% 11% 11%
88% 6% 11%
Non-PSD/NSR
YES NO CBD
76% 18% 6%
72% 17% 11%
78% 12% 10%
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2. Does the agency identify all emission units and their allowable emissions
in the permits?
Auditors reported that at least 15 agencies did not routinely identify
each emission unit along with its allowable emission limit in the permits.
The responses indicated that over half of the agencies "do not" or "generally
do not" appropriately address each emissions unit. In two of these agencies,
it was noted that the emissions units and the emission rates applicable to
those units were identified primarily for PSD permits or where needed to
avoid NSR/PSD review.
For the non-NSR/PSD permit files audited, EPA found 138 (38 percent)
permits that did not address each unit and its allowable emissions. It
would appear that is some cases emissions were "bubbled" under a single or
composite emission limitation. This would make it difficult to enforce the
limit with respect to the emissions coming from any particular unit. Agencies
are advised to avoid any such practice because of the questionable enforceability
of such composite limits.
3. Are the compliance test methods stated or referenced in the terms and
conditions of the permits?
Nineteen (19) agencies reportedly either did not at all or did not
consistently state or reference compliance test methods in the permits.
Where the practice is not followed consistently, it is not clear what criteria,
if any, agencies use to determine whether such information is to be included
in the permit. Compliance test methods are commonly defined in the State
or local agencies' rules and regulations, and many agencies indicated in
last year's audit that specific mention of the test methods in each permit
is not required to enable the agency to use them for compliance determination
purposes.
Of the 252 non-NSR/PSD permits which specified emission limits, 42 percent
stated or referenced all or some compliance test methods; 33 percent did
not. For the remaining permits, it could not be determined from the auditors'
responses how compliance test methods were addressed.
Agencies appeared more consistent in stating or referencing the compliance
test methods in NSR/PSD permits. Sixty-five (65) percent of the permits
included stated or referenced compliance test requirements; only 12 percent
did not. Again, auditors did not respond to the question in a significant
number of cases.
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V. COMPLIANCE ASSURANCE
EXECUTIVE SUMMARY
As was the case in last year's National Air Audit System (NAAS) effort,
many States and locals showed one or more strong points characteristic of
a successful air compliance program, such as high source compliance rates
supported by high inspection frequency rates, performance of all required
new source performance standards (NSPS) source tests, expeditious resolution
of violators, and few long-term violators. These activities were adequately
reflected and validated by the national Compliance Data System (CDS).
Other States had source files that were, for the most part, well organized,
up-to-date, and complete, reflecting a reasonable profile of each source.
A State-by-State analysis of compliance statistics shows that inspection
rates for Class Al* State implementation plan (SIP) sources generally
increased over those reported in last year's audit, although four States
were still unacceptably low, with inspection rates of less than 60 percent.
Compliance rates for Class Al SIP sources remained roughly the same as
last year. The NSPS national average for both inspection and compliance
rates rose, even though some individual State rates declined slightly. The
NSPS inspection rates for two States are still seriously deficient, with
figures of 33 percent. Overall national emission standard for hazardous
air pollutants (NESHAP) inspection rates remained steady while compliance
rates fell slightly. Fourteen States still have NESHAP inspection rates
at or below the 55 percent.
The compliance audits also revealed that several State and local
agencies, to a varying extent, still have weaknesses in three areas vital
to a strong and effective compliance program. First, some source files
maintained by State and local agencies do not contain verifiable information
reflecting a reasonable profile of each source. However, there has been
some improvement since last year's audits in the condition of State files,
where the percentage of those reviewed that reflected a reasonable profile
of the sources increased from 58 percent to 72 percent. Second, some
inspection reports still are of poor quality (no mention of operating or
emission parameters or pollutants emitted). For some agencies, there was
a noticeable improvement in the quality of inspection reports since the last
review, but there remain significant deficiencies in this area. Third,
some of the reviewed agencies' enforcement efforts are not always effective
in reducing the number of long-term violators by expeditiously returning
documented violators to compliance, although there was a slight drop in
the percentage of reports that indicated sources were not being expeditiously
returned to compliance (from 30 percent down to 26 percent).
*C1 ass Al includes sources with actual or potential controlled emissions
greater than or equal to 100 tons per year.
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Thus, while there are improvements in all of these critical areas,
some States and locals need to heighten efforts on the aforementioned
three areas to further strengthen their compliance programs.
A. INTRODUCTION
As in FY 1984, the compliance assurance element of the FY 1985 NAAS
was designed to examine State and local programs which are responsible
for the compliance of sources subject to requirements of SIP's and, where
delegated, standards for new stationary sources (section 111) and national
emission standards for hazardous air pollutants (section 112). Of the
several hundred thousand regulated stationary sources in the nation,
there are approximately 30,000 sources in these categories for which EPA
and State/local agencies share a concern about compliance status and
associated enforcement activities. Compliance activities focusing on
these sources formed the primary basis on which each audit was conducted.
There are three major parts of the compliance assurance audit. The
first is a pre-visit assessment of the State or local agency performed by
examining source data reported to EPA by the agency. For FY 1985, this
included an assessment of how the newly-implemented "timely and appropriate"
guidance was working. The other parts of the element are reviewing
selected State source files and conducting overview inspections.
In accordance with the NAAS guidance, the EPA Regional Offices were
to conduct the pre-visit assessment by obtaining Compliance Data System
(CDS) retrievals for FY 1984 on inspection frequency, compliance rates, and
enforcement activity. The Regions were then to analyze the CDS data for
source compliance status, progress in meeting inspection commitments,
identification of long-term violators and associated compliance activity,
adherence to "timely and appropriate" guidance, identification of long-term
compilers and associated surveillance activity, and identification of
operating NSPS sources without the required 180-day performance test.
Finally, based on this CDS analysis, the Regions were to prepare a summary
of each compliance program and send it to the State or local agency
before the visit. The analysis could have taken the form of a questionnaire
for the agency or could have been a statement of findings to be discussed
for completeness and accuracy during the visit. The pre-visit assessment
was also designed to help in identifying the source files to be reviewed
during the on-site visit.
The next major part of each audit was the on-site visit. The visit
centered on a discussion of the findings in the pre-visit assessment and
on review of 15-20 source files. The files to be reviewed were to consist
of a mixture of SIP, NSPS, and NESHAP sources. A file review checklist
was developed to assure consistency in how the file reviews were implemented.
The goals were to see if the files contained a reasonable profile of the
source, contained written documentation to support the compliance status
reported to EPA, and contained documentation to show that violators are
expeditiously returned to compliance. The State and local audit reports
were envisioned to include a discussion of both the pre-visit assessment
and the status of the files.
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The final component of the compliance audit was to be a program of
overview inspections conducted by EPA of 2-3 percent of the sources in
the CDS inventory (Class A SIP, NSPS, and NESHAP). The purpose was to
verify the compliance status of a source as reported to EPA as well as
review State or local agency inspection practices to see if there were
areas where EPA could increase performance through technical assistance
to the State and local agencies.
This report covers 65 State and local audits. (No report was received
on the compliance program for Hawaii). Ten questions were developed as a
guide in developing a summary of the findings in the State and local
audit reports. These questions represent the key elements of the compliance
portion of the audit, and provide a uniform basis to do a national assessment
of the compliance and enforcement programs.
B. MAJOR FINDINGS AND CONCLUSIONS
As was the case in last year's NAAS effort, many States and locals
showed one or more strong points characteristic of a successful air
compliance program, such as high source compliance rates supported by
high inspection frequency rates, performance of all required NSPS source
tests, expeditious resolution of violators, and few long-term violators.
These activities were adequately reflected and validated by the national
CDS. Other States had source files that were, for the most part, well
organized, up-to-date, and complete, reflecting a reasonable profile of
each source.
A State-by-State analysis of compliance statistics shows that inspection
rates for Class Al SIP sources generally increased over those reported in
last year's audit, although four States are still unacceptably low, with
inspection rates of less than 60 percent. Compliance rates for Class Al
SIP sources remained roughly the same as last year. The NSPS national
average for both inspection and compliance rates rose, even though some
individual State rates declined slightly. The NSPS inspection rates for two
States are still seriously deficient, with figures of 33 percent. Overall
NESHAP inspection rates remained steady while compliance rates fell
slightly. Fourteen States still have NESHAP inspection rates at or below
55 percent.
The compliance audits also revealed that several State and local
agencies, to a varying extent, still have weaknesses in three areas vital
to a strong and effective compliance program. First, some source files
maintained by State and local agencies do not contain verifiable information
reflecting a reasonable profile of each source. However, there has been
some improvement since last year's audits in the condition of State
files, where the percentage of those reviewed that reflected a reasonable
profile of the sources increased from 58 percent to 72 percent. Second,
some inspection reports still are of poor quality (no mention of operating
or emission parameters or pollutants emitted). For some agencies, there
was a noticeable improvement in the quality of inspection reports since
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the last review, but there remain significant deficiencies in this area.
Third, some of the reviewed agencies' enforcement efforts are not always
effective in reducing the number of long-term violators by expeditiously
returning documented violators to compliance, although there was a slight
drop in the percentage of reports that indicated sources were not being
expeditiously returned to compliance (from 30 percent down to 26 percent).**
Thus, while there are improvements in all of these critical areas,
some States and locals need to heighten efforts on the aforementioned
three areas to further strengthen their compliance programs.
The remainder of this report addresses in more detail these findings.
It is organized by the three parts of the audit: pre-visit assessment,
file review, and overview inspections. The aforementioned ten questions,
which represent the key elements of this compliance audit, are discussed
in each appropriate part.
C. PERIODIC REVIEW AND ASSESSMENT OF SOURCE DATA
To assess the adequacy of State and local compliance programs, the
EPA Regional Offices continually review source compliance status and
inspection information submitted by the audited agencies and reflected in
CDS for the SIP, NSPS, and NESHAP programs. The attached Figures 1-8
provide a compliance snapshot of all reviewed State and local air compliance
programs as of September 30, 1984 (the time used for the CDS information
in the FY 1985 audits).
As shown in the four pie charts in Figures 1-4, the national compliance
picture is very respectable. Compliance rates have improved since last
year's audit for Class Al SIP and NSPS sources and declined slightly for
NESHAP sources. The bar charts in Figures 5-8 depict, for each aspect
of the air program, the inspection range, compliance range, and number of
long-term violators range for all State and local agencies audited. As
shown, inspection rates for SIP, NSPS, and NESHAP sources range from
0 percent to 100 percent, with median figures between 67 percent and
89 percent (compared to 62 percent and 80 percent in last year's report).
Compliance rates for SIP, NSPS, and NESHAP sources range from a low of
0 percent in one jurisdiction to a high of 100 percent in another, with
median figures near 95 percent. The number of long-term violators (defined
for this audit as two consecutive quarters or more) in each jurisdiction
was largest for Class A SIP sources, ranging from a low of 0 in some agencies
to a high of 124 in another, with a median figure of 6 sources per jurisdiction.
**"Long-term violators" means sources in violation for two continuous
quarters or more.
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The following question is the first one of the ten developed as
a guide for summarizing the findings in the audit reports.
(1) Based on the findings of the pre-visit program analysis, what
was the Region's overall assessment of the condition of the air
compliance program?
A review of the 65 audit reports shows that some form of pre-visit
assessment was done by the Regions for all but three State and four local
programs. Thirty-one of these reports contained an overall statement
about the particular compliance program based on the CDS analysis:
- Ten (10) air programs were considered very good.
- Twenty-one (21) air programs were considered adequate
(meeting most Clean Air Act requirements).
- None of the air programs were termed seriously deficient.
The remaining 27 audit reports (where a pre-visit assessment was
done) made no definitive statement on the air program based on the CDS
assessment, but positive comments were made in 17 of these reports, such
as "inspection rates are very good" and "compliance rates are good to
excellent." It was not possible to determine anything of substance
relative to the pre-visit assessment from the remaining ten reports.
Careful study of the audit reports for the ten agencies with "very
good" air compliance programs shows several elements contributing to the
success of each compliance program. In general, these agencies:
- routinely complete nearly all the required inspections for SIP
sources, and NSPS and NESHAP sources where delegated;
- have compliance levels for Class A SIP, NSPS, and NESHAP sources
consistently above 90 percent with recent inspections to support
this level;
- address, in a timely manner (and according to "timely and appropriate"
guidelines), sources found to be in violation of applicable emission
limits or permitting requirements resulting in few, if any, long-term
violators (greater than 180 days).
It seems likely that other States have compliance programs as good as
these ten but this was not readily discernible from the description of
the programs in the audit reports.
(2) What is the Region's overall assessment of how the newly-implemented
"timely and appropriate" guidance is working in the State or
local agency?
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Twenty-nine audit reports indicated that the guidance is being followed
and the program is working well, while five reports stated that the guidance
was not being followed (meaning few, if any, violators were resolved
according to the guidelines). Of the remaining reports, 20 had no con-
clusions on the "timely and appropriate" guidance because either: (1)
agreements reflecting the guidance were not reached with the States until
late FY 1984, preventing assessment until later in FY 1985 (11 reports), or
(2) there were no violators subject to the guidance (9 reports). The
other 11 reports did not discuss the guidance in any detail.
To summarize the CDS based pre-visit assessment, 48 (74 percent) of
the 65 State and local compliance programs were found by the Regions to
be either adequate or very good, and no programs were judged seriously
deficient based on that assessment. It was not possible to assign an
overall description of programs from the other 17 (26 percent) reports.
This initial effort identified many good programs and pointed out other
areas where the State and local agencies and EPA should continue to work
together to improve compliance programs.
D. FILE REVIEW
(3) Did the source files reflect a reasonable profile of the sources?
All 65 audit reports contained file review information. Forty-seven
(72 percent) of these indicated that the files reviewed reflected a reasonable
profile of the source, which means they contained the following information:
source compliance status based on recent inspection or source test; an
identification of all air program regulations the source is subject to,
and, within the inspection report, operating parameters, point sources,
and pollutants emitted by the facility. Some common reasons cited in the
13 audit reports (20 percent) where the files were considered deficient
were: inability to determine source compliance status from file contents,
no indication of which air program regulations the source was subject to
(SIP, NSPS, NESHAP), and missing inspection reports or poor quality inspection
reports (no mention of operating or emission parameters, point sources, or
pollutants emitted by facility). The remaining five reports (8 percent)
did not contain a conclusive statement on this question.
(4) Did the files contain adequate written documentation
to support the CDS compliance status?
Thirty-seven (57 percent) of the 65 audit reports indicated that
files reviewed contained some written documentation of compliance status
to support CDS. This represents a drop of 5 percent from last year's
documentation rate of 62 percent. Twenty-six (40 percent) of the audit
reports (up from 24 last year) either cited a lack of any compliance
information in the files, or showed information in the files which conflicted
with CDS. The other two reports did not contain sufficient information
to answer this question.
V-6
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To facilitate a more consistent evaluation on this point, a further
explanation of "adequate written documentation" was agreed upon in April
and will be included in the FY 1986/1987 NAAS guidelines. Since this elabora-
tion on the adequacy of written documentation was only agreed upon at a
meeting with State and local agency representatives in April, it was not
consistently used in this year's evaluation. As a minimum, a file should
contain: (a) documentation that the source was inspected and that the
regulated emission points and pollutants were evaluated, and (b) a deter-
mination of the compliance status of the source and documentation of the
basis for that determination. The compliance status in the file should
agree with the compliance status shown in CDS.
(5) Are violations documented and pursued by agencies to return a
source to compliance expeditiously?
Forty (62 percent) of the 65 audit reports indicated that violations
are documented and pursued to return a source to compliance expeditiously.
Seventeen reports (26 percent) indicated that some sources were not being
expeditiously returned to compliance, in some cases, leading to a number
of long-term violators (greater than 180 days) or untimely, protracted
enforcement actions. Eight reports (12 percent) lacked a definitive
response to this question.
E. OVERVIEW INSPECTIONS
Thirteen of the 65 audit reports reviewed did not contain any
information on overview inspections. Therefore, the following questions
cover the remaining 52 reports:
(6) How many inspections were performed?
The number of EPA overview inspections performed ranged from a low of
2 to a high of 48. The total number of inspections for all 52 reports
was 725, which is acceptable compared to the 600 to 900 inspections
projected for this effort (2-3 percent of the Class A SIP, NSPS, and
NESHAP sources in CDS).
(7) How were sources selected by the Region for the overview inspections?
By far, the most common criteria used by the Regions to select sources
subject to overview inspections were some combination of source size
(preference to Class Al), type of program (to ensure a representative
sample of SIP, NSPS, NESHAP sources), location (primary attention to
impact on nonattainment areas as well as geographic spread), source com-
pliance history, and pollutants. Most of the differences between the
Regions' selection approaches were found in the amount of relative emphasis
placed on each criterion.
V-7
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(8) What did inspections consist of?
Almost all of the overview inspections performed were a joint effort
between EPA and the States. Most began with a review of State source
files and progressed to an on-site visit to the source, with both EPA and
State inspectors conducting separate evaluations of source compliance
status, after which separate reports were written and compared. A summary
of the 52 audit reports with answers to this question appears below:
Joint Inspections - State Lead 30 (406 inspections)
Joint Inspections - EPA Lead 11 (132 inspections)
Joint Inspections - Dual Lead 9 (148 inspections)
Independent EPA Inspections 2 ( 39 inspections)
TOTAL 52 " (725 inspections)
(9) What was the purpose of the overview inspections (that is, to
verify independently State reported compliance, to observe State
inspections practices, or some combination of these)?
Forty-six (90 percent) of the 51 reports stated that the purpose was
a combination of independently verifying State compliance and observing/
critiquing State inspection procedures (including State inspector qualifi-
cations). Of the five other reports, four mentioned simple verification
of compliance status as the only inspection goal, and one explicitly
cited status of overview inspections to train State and local inspectors.
(10) What were the overall results of the overview inspection effort,
including recommendations for resolution of any problems discovered
during the effort?
Thirty-nine of the 45 responses to this question (87 percent) showed
both the expertise of State inspectors and State reported compliance
status to be adequate, which means the State inspectors were experienced
enough to conduct a thorough inspection and determine the compliance
status of a source. Six reports (13 percent) indicated that overview
inspection results did not agree with the compliance status in the State
files or CDS.
Regarding recommendations, five reports suggested that more training
for State inspectors would improve the quality of inspections and result _v
in more accurate inspection data being reported to EPA.
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VI. AIR MONITORING
EXECUTIVE SUMMARY
The 1985 National Air Audit System included air monitoring audits of 73
agencies. Four principal areas within the agencies' air monitoring program
were evaluated. These areas were network design and siting, resources and
facilities, data and data management, and quality assurance/quality control.
The principal conclusions relating to these areas are highlighted below.
The audit reports indicate that State and local agencies have continued
their successful performance in operating and maintaining their State and
Local Air Monitoring Stations (SLAMS) and National Air Monitoring Stations
(NAMS) networks. About 98 percent of the 4300 monitors operated by the
audited agencies are meeting the monitoring regulations. No major or wide-
spread siting problems with monitors were discovered.
The audit reports did disclose that 82 percent of the audited agencies
reported needs for new or replacement of air monitoring or laboratory equipment
totaling $4.6 million. Of this total, $3.6 million were needed for air
monitoring equipment and $1.0 million for laboratory equipment.
Similar to last year's audit, the 1985 audit indicated that timeliness of
data submittal is still a problem for many agencies, particularly for submis-
sion of lead (Pb) data which are late about 25 percent of the time. In
general, the data completeness percentage was good with a low of 84 percent
for nitrogen dioxide (N02) and a high of 92 percent for total suspended
particulate (TSP). Another problem area in the data management section of
the audit was a deficiency by 24 percent of the agencies, in the submittal of
the required annual SLAMS report. Corrective actions, however, are being
taken to resolve this problem.
Quality assurance/quality control aspects of the audit reports indicate
that most of the State and local agencies are doing a good job of maintaining
adequate and up-to-date quality assurance plans. Four agencies need to
substantially revise their plans and 46 had minor revisions pending. With
respect to the achievement of quality assurance goals, for precision
(+_ 15 percent for all pollutants) and accuracy (+^15 percent for TSP, j^ 20
percent for other pollutants) data, the only significant problems are related
to accuracy for N02 and precision for Pb. For N02, the percent of reporting
organizations meeting the accuracy goal was 46. This same percent was indicated
for Pb precision. The low values for NOg accuracy and Pb precision are
believed to be related to the complexity of the N02 measurement method and the
low ambient Pb levels.
A. INTRODUCTION
Ambient air monitoring for State implementation plan (SIP) purposes is
required by section 110 of the Clean Air Act. Furthermore, section 319 of
the Act requires the development and application of uniform air quality
VI-1
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monitoring criteria and methodology, reporting of a uniform air quality
index in major urban areas, and the establishment of a national air moni-
toring system which uses uniform monitoring criteria. To comply with these
requirements, the EPA promulgated ambient air monitoring regulations (40
CFR 58) in 1979, with further revisions in subsequent years. Included in the
Part 58 regulations are requirements for the auditing of State and local air
monitoring programs. These provisions have served as the basis for the
national air monitoring audits which began in 1984. As a result of the
findings and recommendations of the 1984 audits, several changes to the audit
questionnaire were made in preparation for the 1985 air monitoring audits.
The modifications made were not major in content. Instead, they were princi-
pally concerned with reorganization, clarity, and the reduction in requests
for resubmission of data. The 1985 guidance did require, for national consis-
tency, that all EPA Regional Offices use at least the short form questionnaire,
the corrective action implementation request, and the system audit reporting
format. Use of the long form questionnaire was left up to the discretion of
the Regional Quality Assurance (QA) Coordinator with the concurrence of the
State or local agency. The audit team in 1985 consisted of EPA Regional
Office personnel and, in some cases, Headquarters representatives. The
audits included interviews, on-site inspections, and the completion of the
short or long form air monitoring questionnaire. The questionnaires contained
questions covering the following four important topic areas: network design
and siting; resources and facilities; data and data management; and quality
assurance/quality control. Each of these areas and the associated questions
are described in detail below following the discussion of "Major Findings and
Conclusions."
B. MAJOR FINDINGS AND CONCLUSIONS
The air monitoring programs of 73 agencies (48 States, 22 locals, the
District of Columbia, and 2 territories) were audited during 1985. The audit
results indicate that State and local agencies continue to successfully
operate and maintain their respective SLAMS/NAMS networks. About 98 percent
of the 4300 monitors operated by the audited agencies are meeting the Part 58
monitoring requirements. These results are consistent with the periodic
national SLAMS/NAMS status reports which show 97 percent of the 4723 monitors
complying with the regulations.
Concerning the audit findings on resources and facilities, most agencies
indicated that they had adequate space and personnel. However, the audit
showed that 60 agencies or 82 percent did have air monitoring equipment needs.
These needs include pollutant monitors, calibration systems, data processing
equipment, and meteorological equipment. The projected cost to procure the
monitoring equipment is approximately $3.6 million. A need for major labora-
tory equipment to bring the laboratory support to adequate levels was expressed
by 24 agencies. Total cost for this equipment is about $1.0 million.
Similar to last year's audit results, timely data submittal continues to
be a problem for many agencies. The problem is principally lead data submit-
tal s, which are late approximately 25 percent of the time. The percentage
of late submittals for the other pollutants range from 8 to 14. This problem
VI-2
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has received greater attention by EPA and State and local agencies, and a
tracking system has recently been instituted within the EPA's Monitoring and
Data Analysis Division to monitor the progress being made in timely data
submittals. With respect to meeting the National Air Data Bank (NADB) 75
percent data completeness criteria, in general, the results were good. The
audit showed a range of 8 percent, with a low of 84 percent for N02 and 92
percent for TSP. One of the larger problem areas found in the data management
section of the audit was the requirement for submitting the annual SLAMS
report. The audit showed that of the 51 audited agencies required to submit
an annual SLAMS report, 12 agencies or 24 percent were deficient in one or
more of the 4 required elements of the annual report. This problem should be
easily resolved administratively and efforts are underway to correct it.
The QA aspects of the audit reports indicated that 69 of the 73 agencies
had QA plans that were, in general, acceptable. However, 4 agencies need to
substantially revise their plans and 46 had minor revisions to their QA plans
pending. Seventy-two of the 73 agencies were participants in the National
Performance Audit Program, an excellent rate of involvement. The last phase
of the quality assurance program evaluation was the assessment of achievement
of the precision and accuracy goals (precision, +_ 15 percent for all pollutants;
accuracy, +_ 15 percent for TSP, +_ 20 percent for other pollutants) by the
agencies' reporting organizations. The lowest rate for achievement of the
precision goals (based on one quarter of data) was for Pb, with only 46 percent
of the organizations meeting the +_ 15 percent goal. Based on data submitted
to the Environmental Monitoring and Support Laboratory (EMSL) for the 1984
annual precision and accuracy report, 65 percent of the reporting organizations
met the Pb precision goal. This difference of 19 percent is thought to be
principally due to the difference between the time periods used.
The lowest percent of reporting organizations meeting the accuracy goals
was 46 which was for N02- The 1984 accuracy achievement level for NOg based
on the annual data submitted to EMSL was considerably higher, reaching 70
percent. The other pollutants compare fairly well between the two data sets.
The reasons for the lower values for N02 accuracy and Pb precision are believed
to be related to the complexity of the N02 measurement method and its associated
audit methods and the relatively low ambient levels for lead. It is also pos-
sible that the wide confidence intervals (CI's) associated with N02 accuracy
estimates are related to the fact that, for most reporting organizations, there
are actually few N02 sites relative to site counts for the other parameters.
In a statistical sense, the presence of even a few relatively large, but still
"acceptable," individual audit differences are magnified into large quarterly
CI's due to the small number of points actually comprising the statistic.
C. NETWORK DESIGN AND SITING
The network design and siting section of the audit was aimed at assessing
compliance of air monitoring programs with the requirements of Appendices D
and E of 40 CFR Part 58. To assess this topic, five overall aspects were
reviewed. They were as follows:
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0 Network size and written description of the network
0 Network modification during the last year
0 Sites not meeting network design or siting requirements
0 Performance of the annual network review requirements
0 Survey of noncriteria pollutants monitored by agency
Responses to this section of the audit, were intended to serve as a cross-
check and update of existing EPA data on the number of monitors, their
distribution, their conformance with siting requirements, and compliance with
the annual network review provisions. This section also provides an enhanced
perspective on network stability and the variety of noncriteria pollutants
monitored by State and local agencies. In reviewing the audits, there appeared
to be general agreement between State and local agencies in terms of complete-
ness of response or compliance with requirements of the regulations.
The number of sites operated by the 73 agencies audited was 1290 NAMS,
3019 SLAMS, and 867 special purpose monitors (SPM) for a total of 5176 sites.
These totals compare favorably with the 1984 SLAMS status report which indi-
cated that 1345 NAMS and 3378 SLAMS were operating at the end of 1984. The
difference between the 1984 SLAMS report and the audit totals is accounted
for by those sites operated by State and local agencies which were not audited.
An indication of network stability is gained by looking at the number of
reported changes to State and local networks. There were 148 new sites
established, 198 sites discontinued, and 101 sites relocated during 1984 for
a total of 447 modifications. This total affected approximately 10 percent
of the sites covered by the audit and occurred in 52 of the 73 agencies
audited. During 1985, about the same number of agencies are planning network
changes. Due to the short-term nature of SPM monitoring, no attempt has been
made to track these sites on a regular basis.
From the audit reports, it was determined that over 98 percent of the
4309 SLAMS/NAMS operating monitors reported by the 73 agencies audited were
in compliance with 40 CFR 58 Appendices D and E. More than half of the monitors
not in compliance with Appendices D and E are located in two States which are
taking steps to bring these sites into compliance. The remaining sites are
scattered over 14 State or local agencies.
Results of the review for compliance with the SLAMS network description
and annual review requirements of 40 CFR Part 58 show that all agencies
audited maintain a network description and that the descriptions for 7 agencies
(or 10 percent) are deficient in one or more of the items required for the
description. With respect to adherence to the annual network review, seven
agencies did not provide the date of their last review, and eight agencies
indicated that the last review occurred prior to 1984. The remaining 58 (79
percent) of the agencies indicated that network evaluations were conducted
sometime during 1984 or early 1985.
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The audit results pertaining to noncriteria pollutant monitoring showed
that 56 of the 73 agencies monitored for one or more noncriteria pollutants.
This information was collected to provide some initial knowledge of the
variety and magnitude of noncriteria monitoring conducted by the audited
agencies. Based on this information, the most frequently monitored substances
are organic solvents, metals, acid rain, and sulfates/nitrates. The infor-
mation collected is not specific enough for a comparison to EPA's priority
toxic pollutant listing. Future audits could be adjusted to provide additional
information for this purpose. The listing below shows the pollutant monitored
and the number of agencies monitoring for each.
Metals 17 Fine Particulate 5
Acid Rain 11 S04/N03 12
Asbestos 5 Sulfur 1
Solvents 18 Phosphate 1
Formaldehyde 3 Radiation 1
Fluoride 4 Pesticides 2
BaP 4 Freon 1
H2S 7 Chloride 1
NMOC 9
D. RESOURCES AND FACILITIES
The resource and facility section of the audit was developed to provide
additional information about the size of operations, and the adequacy and
condition of various resources of each audited agency. Topics considered in
this section were as follows:
0 Number of nonconforming analyzers
0 Instrument needs
0 Number of man-years of effort
0 Documentation of standard operating procedures for laboratories
and availability of necessary equipment
0 Availability and traceability of laboratory and field (site)
standard reference materials
An analysis of the audit results for the resources and facilities section
of the audits provides the following information. There are 23 nonconforming
pollutant monitors currently in use in the SLAMS network. This amounts to
less than 1 percent of the reported sites. The biggest block of nonconforming
monitors (19 of 23) are hi-volume samplers for TSP or Pb which do not conform
to the new shelter standards.
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Sixty agencies reported various monitoring equipment needs ranging from
spare parts to several new monitors or calibration systems. The equipment
requests have been categorized in four areas: field equipment which includes
such items as pollutant monitors, flow controllers, and shelters; calibration
and quality control (QC) equipment, including items like calibration systems,
gas dilution systems and rootsmeters; data processing equipment, covering
such items as personal computers, data loggers, telemetry equipment, etc.;
and meteorological equipment. The table below indicates the broad categories
of equipment requested, the number of items, and an estimate of the cost to
acquire all of the equipment.
Number of
Equipment Type Items Cost $(000)
Field
(a) Monitors 400 2,800
(b) Shelters, flow 23 97
controllers
Calibration-QC 28 107
Data Processing 88 583
Meteorological 30 46^
TOTAL 569 3,633
The total cost to purchase all of this equipment is estimated at $3.6
million. Twenty-four agencies also requested laboratory equipment. This
equipment (a total of 35 items) included spectrophotometers, humidity-
controlled chambers, microbalances, etc. The estimated cost to acquire these
items is $1.0 million. The total cost to meet the monitoring and laboratory
equipment needs identified by the audits is about $4.6 million. In FY 1986,
$2.4 million in section 105 grant funds were allocated to replace carbon
monoxide (CO) and ozone (03) monitors and procure additional particulate
matter (PMio) samplers. EPA anticipates continuing funding equipment needs at
approximately the same level in FY 1987.
The analysis of agency space and staff indicates that 65 percent of the
agencies felt they had adequate space to operate their program. To establish
a better understanding of the number of people involved in air monitoring,
the agencies were asked to break down the number of work-years associated with
operating various aspects of their programs. Sixty-two agencies provided
tabulated responses to this two-part question. The remaining 11 agencies either
did not respond, provided organizational charts which could not be reduced to
man-years, or simply indicated their space was adequate. The total number of
man-years assigned to 4 specific areas of air monitoring for 63 agencies is
shown below.
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Program Area Number Percent
Network Design & Siting 128 15
Resources & Facilities 347 41
Data & Data Management 172 20
QA/QC 209 24
TOTAL 856 100
The audit showed that 63 agencies or 86 percent of those audited have
adequate laboratory standard operating procedures for air quality measurements.
However, only 67 percent (49 agencies) indicated that they had sufficient
instrumentation available to conduct all necessary laboratory analyses.
The last major area of the facility and resource section audited concerns
standards and traceability for laboratory and field site use. The audit indi-
cated 92 percent of the agencies had and could demonstrate adequate reference
standards for laboratory use. This percentage drops off to 72 percent for
field site standards.
E. DATA AND DATA MANAGEMENT
The principal areas of concern in the area of data and data management
are as follows:
0 Percentage of data submitted on time
0 Percentage of sites submitting less than 75 percent of the data
0 Documentation of changes to submitted data
0 Data changes performed according to a documented standard operating plan
0 Completeness of the annual SLAMS report.
The pertinent findings of the audits for the data and data management
portion of the national audit are discussed below.
Historically, timeliness of data submittal has been a chronic problem;
therefore, each audited agency was asked to provide an estimate of the per-
centage of data submitted within 135 days after the calendar quarter in which
it was collected. In general, this requirement applies to NAMS sites; however,
most agencies submit their SLAMS data to the NADB and have included their
SLAMS in the percentages for data submitted on time. The calculation of data
submitted on time is a time-consuming and sometimes difficult statistic to
develop retrospectively. An analysis of the percentages submitted by quarter
VI-7
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by pollutant from 68 agencies indicates the quarterly average percent submitted
on time varied between 75 percent for lead to 93 percent for carbon monoxide.
These percentages seem to be similar to those percentages reported quarterly
in the Strategic Planning and Management System (SPMS) reports; however, the
audit results are not directly comparable to SPMS numbers because SLAMS sites
are included in the audit report and not in the SPMS.
In addition to timeliness of data, completeness of data submittal is of
great concern to EPA; therefore, the audits examined the percentage of sites
meeting the NADB data completeness criteria (in general, submitting at least
75 percent of the theoretically obtainable data by quarter by pollutant).
Similar to the response on timeliness of data, 68 agencies provided data on
this question. All of the agencies' responses on data completeness were
combined as a national data completeness quarterly audit result compared to
the 1984 percentages from the September 1985 quarterly NAMS status report.
Percent of Sites Meeting NADB Criteria
Sept 1985
Pollutant Audit Results Quarterly NAMS Report
TSP 92 90
S02 85 88
N02 84 76
CO 90 90
03 91 86
Pb 86 75
A direct comparison of the national audit results with the quarterly NAMS
report should be done with caution because the former represents a quarterly
average of approximately 4000 sites, and the NAMS report is an average for
approximately 1300 sites. The two data sets compare reasonably well, the
difference range being 0 (for CO) and 11 percent (for Pb).
The audit indicated that 60 (82 percent) of the audited agencies documented,
in a permanent file, any change to air quality data previously submitted to
EPA. However, the audit reports showed that only 50 agencies (68 percent)
performed these changes according to a documented standard operating procedure.
It is assumed that the other 10 agencies which said they documented changes
either ignored their established procedure or had no standard procedure for
documenting changes to data.
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The last area considered under the data management section of the audit
was the requirement to submit an annual SLAMS report to EPA. This requirement
is applicable to States, the District of Columbia, and United States territories;
therefore, local agencies are not considered here. Four particular aspects
of the SLAMS annual report are needed for a complete SLAMS report. They are
a data summary, annual precision and accuracy information, air pollution
episode information, and certification of the report. Of the 51 agencies
required to produce a SLAMS annual report, 39 (76 percent) audits showed
inclusion of all required elements, while the remaining 12 were deficient in
one or more elements of the report. These results are comparable to findings
based on those received by the Office of Air Quality Planning and Standards.
F. QUALITY ASSURANCE/QUALITY CONTROL
The Quality Assurance/Quality Control (QA/QC) Section of the national
audit program is the last major topic considered in the audits. Consideration
was given to the following portions of the audited agencies' QA/QC programs.
0 EPA approved QA plan
0 Pending revisions to QA plans
0 Agency participation in the National Performance Audit Program (NPAP)
° Attainment of precision and accuracy goals
Information provided in the QA/QC Section of the audit reports is summarized
and discussed below.
Several years ago, EPA approved all of the various agency Quality Assurance
Program plans. However, it was not intended that either a QA program or its
approval would be a static one-time affair. As a result of program reviews
and the changing state of the art, some agency QA programs are outdated or
need modification. This is evidenced in the audit results that show 4 out of
the 73 audited QA plans need to be revised and approved, and 46 (63 percent)
of the audited plans have formal revision proposals pending approval actions.
The number of revisions to the QA program plans is a good indication that
EPA's concern over quality assurance is being taken seriously. Similarly,
the high level of participation in the NPAP, 72 of the 73 audited agencies,
demonstrates the deep interest of State and local agencies in the data quality
of their air monitoring programs.
The last consideration of the QA/QC Section of the national audit was a
measure of the agencies' reporting organizations ability to achieve the
precision and accuracy goals specified in the 1985 audit guidance (precision,
+_ 15 percent for all pollutants; accuracy, +_ 15 percent for TSP, +_ 20 percent
all other pollutants).
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Precision and accuracy data are measures of data quality and are based on
"reporting organizations." Each State must define at least one or more reporting
organization for each pollutant, and each reporting organization should be
defined such that the precision and accuracy data reported among all stations are
reasonably homogeneous. Nationally, there are approximately 150 organizations.
Usable data (in terms of responses to the questionnaire) for precision
were received from 59 agencies, while accuracy data were supplied by 58
agencies. Some of the agencies that did not provide usable data for this
section did provide some indication of success in achieving or failing to
achieve the goals. The 1985 audit guidance directed that achievement of
goals was to be based on each of the last 4 complete calendar quarters prior
to the audit for which precision and accuracy data were available; therefore,
the data received covered a period between July 1983 and December 1984. To
simplify the analysis, a common quarter for all agencies submitting data was
chosen. All of the data for the second quarter of 1984 were reduced to pro-
duce precision goal achievements (Table 1) and accuracy goal achievements
(Table 2).
TABLE 1
FY 1985 AUDIT RESULTS
PRECISION
# Reporting # of Rpt. Org.'s Percent Rpt. Org.'s
Pollutant Organizations Meeting Goals Meeting Goals
(Rpt. Org.)
03 85 66 78
N02 53 31 58
S02 82 60 73
CO 76 67 88
TSP 112 83 74
Pb 59 27 46
VI-10
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TABLE 2
FY 1985 AUDIT RESULTS
ACCURACY
# Reporting # of Rpt. Org.'s Percent Rpt. Org.'s
Pollutant Organizations Meeting Goals Meeting Goals
03 84 65 77
N02 52 24 46
S02 81 57 70
CO 75 58 77
TSP 111 104 94
Pb 58 47 81
Achievement of precision goals by reporting organizations as shown in
Table 1 varies between 46 percent for lead to a high of 88 percent for CO.
The precision of both lead and N02 is noticeably lower than the level of the
remaining pollutants. Similarly, the achievement of accuracy shown in Table 2
ranges between 46 percent for N02 and 94 percent for TSP. The accuracy goals
set in the audit guidance are stringent because they were applied to all four
accuracy audit levels as opposed to meeting only one of the levels. It is
evident that N02 accuracy falls considerably below the level achieved by
other pollutants and has been attributed to the complexity of the NO/N02/NOX
analyzer. It is also possible that the wide CI's associated with N02 accuracy
estimates is related to the fact that, for most reporting organizations, there
are actually few N02 sites relative to site counts for the other parameters.
In a statistical sense, the presence of even a few relatively large, but still
"acceptable" individual audit differences are magnified into large quarterly
CI's due to the small number of points actually comprising the statistic.
To provide further perspective on precision and accuracy performance
nationally, Table 3 for Precision and Table 4 for Accuracy have been assembled
from data submitted to EMSL for calendar year 1984.
VI-11
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TABLE 3
Pollutant
03
N02
S02
CO
TSP
Pb
1984 DATA SUBMITTED TO EPA
PRECISION
Probability Limits (%)
# Rpt. Org.'s
104
66
103
96
138
72
Lower
-16
-20
-20
-14
-19
-25
Upper
+15
+21
+15
+12
+12
+27
Percent of Rpt. Org.'s
Meeting Goal + 15%
85
75
85
90
75
65
TABLE 4
1984 DATA SUBMITTED TO EPA
ACCURACY (AUDIT LEVEL 1)
Probability Limits (%)
Pollutant # Rpt. Org.'s Lower Upper
03 84
N02 43
S02 103
CO 96
TSP* 138
Pb 72
*TSP is based on + 15
-21
-34
-24
-20
-12
-15
+20
+20
+20
+18
+12
+18
Percent of Rpt. Org.'s
Meeting Goal + 20%*
85
70
85
90
95
85
Tables 3 and 4 utilize the entire 1984 data base. The upper and lower
probability values were selected so that the range would include 90 percent
of the reporting organizations for precision and accuracy (audit Level 1).
The last column reflects an estimate of the percent of the reporting organiza-
tions meeting the audit goals for the 1984 precision and accuracy data submitted
to EMSL. The percentage of reporting organizations meeting the audit goals
of +_ 15 percent for precision ranges from 65 percent for Pb to 90 percent for
CO.
VI-12
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The goals for accuracy were +_ 15 percent for TSP and +_ 20 percent for all
other pollutants. The range of percentages for reporting organizations
achieving the accuracy goals in Table 4 is from 70 percent for N02 to 95
percent for TSP. The 1984 values shown in Tables 3 and 4 are about the same
as the 1983 levels.
Tables 1 and 3 or 2 and 4 are not directly comparable to each other because
of the difference in period of record and number of reporting organizations
used. However, it is evident that goal achievement is higher for all pollutants
based on the 1984 annual data submitted to EMSL. Furthermore, the extent of
the range (the percent of reporting organizations meeting the precision and
accuracy goals) for Tables 3 and 4 is smaller than the corresponding Tables
1 and 2.
Based on the two sets of tables, N02 for both precision and accuracy shows
up with lower values than the other pollutants. This may be related to the
complexity of the N0£ instrument and the related instrument audit procedure,
and the limited number of N02 instruments operated by the various reporting
organizations. The low level of achievement for lead may be related to the
procedure which analyzes two strips from the same filter. In general , ambient
lead levels are low. This would magnify any very small differences in the
analytical results between the two strips to rather large percentage differences.
VI-13
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VII. VEHICLE INSPECTION/MAINTENANCE
EXECUTIVE SUMMARY
While the audit process for inspection/maintenance programs did not
become part of the National Air Audit System (NAAS) until FY 1985, E^A
actually started inspection/maintenance (I/M) audits in FY 1984. Eight I/M
programs were audited in FY 1984 and another eight I/M programs were audited
in FY 1985. The results of these sixteen audits are included in this
report.
Enforcement is a problem in some programs with sticker based
enforcement. Five of the 16 programs audited had enforcement problems.
Low reported failure rates are a problem in most decentralized
programs, especially in those using manual analyzers and in some centralized
government-run programs. Nine of the 16 programs audited were experiencing
lower than expected failure rates.
High waiver rates are a problem in some programs, both centralized
and decentralized. In total, 4 of the 16 programs audited had apparent
excessive waiver rates for at least some vehicle categories.
Analyzer quality assurance ranges from excellent in centralized
contractor programs to marginal in both decentralized programs with manual
analyzers and some centralized government-run programs. Ten of the 16
programs audited need improvements in this area.
Data analyses are not being effectively used in most programs to
monitor and improve program performance and the performance of individual
inspection stations. Thirteen of the 16 programs need to improve their
data management programs. The quality of I/M repairs is a problem, to
some extent, in every program audited.
The EPA believes that the resolution of these problems generally rests
with each State/local I/M program developing an overall I/M quality
assurance program to ensure that problems are identified and resolved in
a timely manner. This overall system needs to monitor and assure adequate
enforcement, adherence to procedures for testing and record keeping, and
proper diagnosis and repair of failed vehicles.
VII-1
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Identifying operating problems is an important first step in assuring
quality I/M programs. The results of completed audits are being used by
State/local agencies and EPA to improve I/M programs. The EPA believes
that the I/M audit system and guidelines will continue to be a dynamic
and vital process for achieving environmental results.
A. INTRODUCTION
Auditing of State/local motor vehicle I/M programs was added to the
NAAS in FY 1985. The EPA actually started the I/M audit program in FY 1984
when eight pilot audits were conducted in the spring and summer of 1984.
The results of these FY 1984 audits are being included in this report.
Eight additional audits occurred in FY 1985. Table 7-1 lists the I/M
programs audited in FY 1984 and FY 1985, the dates of each audit, and the
type of I/M program in each State. Table 7-2 (on p. VII-11) summarizes the
operating details of the 16 programs.
Table 7-1
FY 1984/85 I/M Audits
Program
Location Dates Type*
Connecticut 5/14 - 5/16/84 A
Massachusetts 5/16 - 5/18/84 D
Colorado 5/21 - 5/23/84 C
Arizona 5/23 - 5/25/84 A
District of Columbia 6/04 - 6/06/84 B
Virginia 6/06 - 6/08/84 C
Memphis, TN 6/27 - 6/29/84 B
New Jersey 7/10 - 7/13/84 BC
Nevada 10/15 - 10/19/84 C
New York 12/10 - 12/14/84 D
Georgia 1/22 - 1/25/85 C
Missouri 3/04 - 3/08/85 C
Delaware 3/07 - 3/08/85 B
North Carolina 3/18 - 3/22/85 C
Texas 3/26 - 3/27/85 C
4/02 - 4/04/85
Oregon 4/15 - 4/19/85 B
*A = centralized, contractor
B = centralized, government-run
C = decentral ized
D = decentralized with computerized analyzers
VII-2
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The primary purpose of the I/M audit is to allow EPA to ensure that
each State or locality is implementing and enforcing its I/M program in a
manner consistent with its State implementation plan (SIP). Another
objective of the audit is to identify areas where EPA can provide assistance
to strengthen I/M programs. This includes either specific aid to a
particular State or more general assistance aimed at resolving an overall
technical issue. ,,.*"
The I/M audit questionnaire and the audit visit are structured to
allow EPA and the State to determine what, if any, program improvements
may be required to enable SIP goals and commitments to be met. The I/M
questionnaire is in two sections—one dealing with design and intended
operating aspects and the other with actual recent operating experiences.
The on-site audit visit includes various activities designed to
provide an in-depth analysis of the I/M program. These activities include
records reviews, inspection station visits, interviews with program
officials, and special surveys.
B. MAJOR FINDINGS AND CONCLUSIONS
1. Major Findings
The following major findings resulted from the completed I/M audits:
a. Enforcement - EPA auditors found that the rate of compliance
among vehicle owners ranged from greater than 95 percent in
some States to less than 50 percent in other States. The
problems noted were in sticker-based enforcement programs.
b. Reported failure rates - EPA auditors found reported failure
rates as high as 35 percent and as low as 2 percent. Very low
reported failure rates indicate inspection error, or at least
data reporting errors. These problems were prevalent in most
decentralized programs and in some government-run, centralized
programs.
c. Waiver rates - EPA auditors found that waiver rates varied
considerably among the programs audited. A few programs do
not allow waivers. In some States, the waiver rates appeared
excessive.
d. Analyzer quality assurance - EPA auditors found quite a variation
in analyzer quality assurance among the audited programs. In
the centralized contractor programs, analyzer quality assurance
was excellent. In decentralized programs with manual analyzers
and in some centralized government-run programs, analyzer
quality assurance was marginal.
VII-3
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e. Data analyses - EPA auditors found that, with only a few
exceptions, I/M programs are failing to effectively use available
program data to monitor and take steps to improve program
performance and performance of individual inspection stations.
f. Quality of I/M repairs - EPA auditors found that in every
program, to some extent, a problem exists with,respect to the
quality of I/M repairs.
2. Conclusions
EPA believes that the resolution to the problems in operating I/M
programs generally rests with each State/local I/M program developing an
overall I/M quality assurance program to ensure that problems are identified
and resolved in a timely manner. Through such systems, program managers
need to track:
a. The level of noncompl iance among vehicle owners.
This is particularly important in nonregistration enforcement
systems. However, even registration enforcement is not necessarily
exempt from problems.
b. The performance of inspection stations to make sure that
vehicles are receiving fair, equitable, and accurate inspections.
This involves inspection station audit and surveillance activities
as well as tracking performance through data analysis. Obviously,
the latter is possible only if accurate data are collected.
c. The performance of the program itself.
Program data need to be summarized and analyzed to ensure that
cutpoints, failure rates, waiver rates, and other program
statistics are within acceptable limits.
d. The quality of repairs.
Quality repairs are the backbone of I/M. Program data need to
be reviewed to ensure that vehicles are not being improperly
or incorrectly repaired. Retest failure rates and comparisons
of before- and after-repair emissions levels can be useful
indicators to assess the quality of I/M repairs.
VII-4
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C. ENFORCEMENT
Enforcement - EPA auditors found that the rate of compliance among
vehicle owners ranged from greater than 95 percent in some States to less
than 50 percent in other States. Five of the 16 programs audited had
enforcement problems.
Three enforcement methods are currently used in I/M programs:
1. Registration based enforcement.
2. Sticker enforcement.
3. Data-link enforcement.
The I/M audits have not identified any problems in registration
enforcement programs, although these systems have potential problems with
motorists improperly registering their vehicles outside the I/M area to
avoid the program, with police failing to ticket vehicles for expired
license plates, and with clerical errors in the registration process
which might allow uninspected vehicles to be registered. No audits have
yet been conducted for programs which use data-link enforcement.
The enforcement problems that have been identified in the I/M audits
are with sticker-based enforcement. Of the first eight sticker enforcement
programs audited, four had serious levels of noncompl iance (in excess of
20 percent of vehicles in noncompliance).
The problems in sticker-based enforcement programs tend to be caused
by the indifference of police officers to sticker violations and by the
failure of police departments to devote the necessary resources or to
accept the risk to public goodwill. In some cases, there are also problems
because of an inability of police officers to distinguish subject vehicles
from exempt vehicles and to distinguish expired stickers from valid ones.
Limitations are also imposed in some cases because police are not authorized
to ticket parked vehicles.
Another problem area in some programs was sticker accountability.
The EPA auditors found that some programs have very thorough sticker account-
ability procedures while others do not. In order to ensure the proper
disposition of stickers, State/local agencies need to confirm that each
approval sticker has a matching inspection record showing passing results.
(This same confirmation is needed in nonsticker programs for approval
certificates, except where the approval certificates and official inspection
reports are printed automatically by machine.) This confirmation is
accomplished in some current programs by correlating sticker serial
numbers to inspection reports and then reviewing inspection records,
sticker records, and sticker supplies during audits. In programs with
VII-5
-------
automated data collection, sticker serial numbers can be easily recorded
in the inspection report and reviewed through routine data analyses.
Because of the potential for data loss in some of these systems, State/local
agencies need to be cautious about totally relying on the automatic
records. Serial numbers for which no passing test data can be found
should be checked against paper records kept at the inspection station
or centrally. Alternatively, all serial number/passing test verification
can be done manually.
D. REPORTED FAILURE RATES
Reported failure rates - EPA auditors found reported failure rates
as high as 35 percent and as low as 2 percent. Nine of the 16 programs
audited were experiencing lower than expected failure rates.
Reported failure rates were consistently much lower than (less than
half) the designed failure rates in decentralized programs. (One exception
was a decentralized program with computerized analyzers.) Also, there
were low failure rates reported in one government operated, centralized
program. All contractor operated centralized programs had reported
failure rates in the designed range.
There are several reasons for the low failure rates. In a few
cases, the failure rates are low because the I/M cutpoints are too lenient.
However, most of the problems with low reported failure rates, especially
in decentralized programs, are caused by either pre-inspection repairs,
mistakes or cheating by inspectors, or some combination of these three
factors. The EPA believes that a strong inspection station surveillance
program is needed to ensure proper station performance. This surveillance
program should include regular station audits, spot checks with unmarked
vehicles, and the ability to gauge and track station performance through
data analyses. Spot checks with unmarked vehicles set to fail inspection
should be considered an indispensable part of the oversight function in a
decentralized program, particularly a program with manual analyzers.
E. WAIVER RATES
Waiver rates - EPA auditors found that waiver rates varied considerably
among the programs audited. A few programs do not allow waivers. In
some States, the waiver rates appeared excessive (greater than 10 percent
of failed vehicles receiving waivers). In one State, the overall waiver
rate was about 13 percent of failed vehicles. In another case, approximately
50 percent of the 1981 and newer vehicles which failed were receiving
waivers. In total, 4 of the 16 programs audited had apparent excessive
waiver rates for at least some vehicle categories.
VII-6
-------
The reasons for the excessive waivers varies to some extent with the
type of program. In centralized programs and other programs where the
State/local agencies process waiver applications, the problem tends to be
a failure on the part of the agency to adhere to strict processing procedures.
In such cases, vehicles which receive improper or irrelevant repairs are
granted waivers as long as the repair cost ceiling, and other criteria if
any, are met. If repair facilities have learned that owners never have to
return for a better repair, they have much less incentive to perform only
relevant repairs and to perform them correctly. To date, program officials
in centralized programs have not spent the effort to create other motivations
for good repairs and to find the repair facilities most in need of improvement,
In decentralized programs where the inspection stations have the
authority to grant waivers, high waiver rates tend to be caused primarily
by a lack of close scrutiny by the State/local agency. In these cases,
the agencies do not track waiver rates by inspection station and do not
investigate questionable waiver transactions. Waiver rates seem to be
particularly high in those decentralized programs which use mandatory
repair sequences (i.e., all or some failed vehicles must have dwell,
timing, air/fuel ratio, and idle speed adjustments only) rather than cost
1imits.
In decentralized, programs where the State agencies process all
waivers, the waiver rates are surprisingly low. In fact, the waiver
rates in some cases are so low that it reinforces the suspicion that
vehicles are not being failed correctly at reinspection.
In some cases, a secondary problem contributing to high waiver rates
in both centralized and decentralized programs is the use of relatively
low waiver cost ceilings. Over half of the current operating programs
have waiver cost ceilings of $55 or less.
F. ANALYZER QUALITY ASSURANCE
Analyzer quality assurance - EPA auditors found quite a variation in
analyzer quality assurance among the audited programs. In the centralized,
contractor programs, analyzer quality assurance was excellent. However,
in decentralized programs with manual analyzers and in some centralized,
government-run programs, analyzer quality assurance was marginal. This
group included 10 of the 16 programs audited. These problems were caused
by several factors:
1. Lack of a comprehensive program of preventive and corrective
maintenance.
2. Lack of thorough audit/surveillance activities for inspection
stations.
3. In some cases, existing analyzers are rather old.
VII-7
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6. DATA ANALYSES
Data analyses - EPA auditors found that, with only a few exceptions,
I/M programs are failing to effectively use available program data to
monitor and take steps to improve program performance and performance of
individual inspection stations. Of the 16 programs audited, 13 should
improve their data management programs.
In cases where inspection data are collected manually, there are a
number of problems which prevent, or at least limit, the collection of
accurate data. In some cases, records are illegible and therefore unusable.
A more serious problem, and one that is more difficult to resolve, is
that in many cases inspectors do not correctly record data. The EPA
auditors found that manually collected data records often contain easily
identified patterns of record keeping (or other) abuses. In most cases,
however, the State/local agencies tend to categorize the problem of poor
record keeping as inevitable rather than attempting to resolve it.
Abuses which are limited to record keeping of themselves may not be
serious threats to air quality objectives. However, there at least needs
to be a way to analyze the data to distinquish between record keeping
errors and more serious infractions, such as falsification of test results
in order to improperly pass a vehicle with high emissions or to avoid
inspecting a vehicle at all. By screening inspection data, agency field
investigators should be able to identify questionable transactions or
problem stations. Therefore, EPA considers emphasis on collecting and
analyzing valid data to be a high priority.
In cases where data are collected automatically, the data are generally
available to program officials, although there have been problems with
data loss in some cases. The problem in these cases tends to be an
inability to use the data effectively. In some cases, the State/local
agencies have placed little priority on developing computer programs to
analyze data. In other cases, the data are over-analyzed with many useless
reports being generated. This latter situation often leaves the program
managers overwhelmed by the data and confounds their ability to focus on
the useful reports.
H. QUALITY OF I/M REPAIRS
Quality of I/M repairs - EPA auditors found that in every program,
to some extent, a problem exists with respect to the quality of I/M
repairs.
State and local agencies are providing minimal attention to assurance
of quality repairs to failed vehicles. All too often it appears that
vehicles are adjusted to meet I/M cutpoints with a small margin of safety
rather than being adjusted near manufacturer specifications. This results
in much lower emissions reductions being achieved.
VII-8
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I. EVALUATION OF THE FY 1985 AIR AUDIT EFFORT
The eight FY 1984 I/M program audits were intended to test the auditing
concepts planned for the FY 1985 audit guidelines. The eight FY 1985 I/M
audits were more comprehensive in scope and were able to rely on the
established guidelines and questionnaires. The EPA believes that the
FY 1984 and FY 1985 I/M audits were successful in establishing a long term
process for evaluating and improving operating I/M programs.
One measure of the success of the audit program can be obtained by
reviewing feedback from the State/local officials who participated in the
audits. To obtain this feedback, EPA surveyed officials in the eight I/M
programs audited in FY 1985. In summary, the major comments were generally
as follows:
1. On questionnaires, most commenters indicated that they would have
preferred getting the questionnaires sooner than they did. They
felt, in some cases, that EPA should have done a better job of
filling out the questionnaire before it was sent to the State. A
few commenters indicated a preference for a State-specific questionnaire
or a separate questionnaire for decentralized and centralized programs;
however, they agreed that better completion and screening of questions
by EPA would have minimized their problems with the current questionnaire,
2. Most commenters indicated that draft reports should have been sent
to the States sooner or, at a minimum, EPA should formally follow-up
with the State on the major findings of the audit in a timely manner.
Some States indicated that they had no formal contact with EPA on
the audit between the audit exit meeting and the receipt of the
draft audit report. In some cases, this represented a time gap of
up to 6 months. Most commenters felt that better follow-up was
needed in order to focus on problems, to develop reasonable and
timely resolutions, and to set priorities and schedules. Such audit
follow-up activities should be discussed in the audit report to make
the document current at the time of its release.
3. Some commenters indicated that EPA should have had better pre-planning
for site visit activities and better coordination with the State/local
agencies prior to the audit visit. In a few cases, site visit
activities were not planned until the audit team arrived on site.
Some commenters felt that EPA should improve communications and
coordination efforts with the nonair State/local agencies that are
involved with the I/M programs. In some cases, all coordination
efforts with these agencies were inappropriately delegated to the
State/local air agencies.
VII-9
-------
4. One commenter suggested and others agreed that EPA should place more
emphasis on involving officials from other State/local programs on
the audit team. Participating officials from other States/local ities
should be from States/localities with I/M programs similar to the
one being audited.
5. Another suggestion was to involve EPA officials from an EPA Regional
Office other than the one handling the audit. This would help to
ensure consistency and to overcome any biases which may have developed
within the host Region. It was again stressed that the visiting
personnel be familiar with programs similar to the one being audited.
6. A few commenters felt that the State/local officials "evaluating"
the audits was a good way of getting constructive feedback on the
audit process and that EPA should solicit such evaluations as part
of the audit process. It was felt that these evaluations should
occur soon after the audit visit and follow-up activities were
conducted.
In view of the comments received, there was no apparent need for
major revisions to the I/M audit guidelines or questionnaires for FY 1986
and FY 1987. The major need is simply to improve the administrative
process of implementing the guidelines. The EPA believes that the main
reason for the logistical problems experienced in FY 1985 was that the I/M
audits were a new part of the National Air Audit System. This first
year's learning experience by itself will yield improvements for later
years.
Even though no major revisions were apparently needed in the guidelines
or questionnaires, two areas were identified for minor changes in the
FY 1986/87 I/M audit guidelines. One change was to add a short discussion
to the guidelines on audit visit exit meetings. This change was made to
clarify that exit meetings occur at a point in the audit process when
only tentative conclusions can be drawn, since much information and data
cannot be fully evaluated during the audit visit itself.
The other area for minor change was in the instructions for the
audit questionnaires. To avoid some of the logistical problems with the
questionnaires, the instructions were modified to clarify that EPA personnel
are to initially complete as much as possible of the questionnaire and to
clearly mark those questions which do not apply to a particular State/local
program.
Identifying operating problems is an important first step in providing
quality I/M programs. The results of completed audits are already being
used by State/local agencies and EPA to improve I/M programs. The EPA
believes that the I/M audit system and guidelines will continue to be a
dynamic process for achieving environmental results.
VII-10
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Table 7-2
Description of I/M Programs
Audited in FY-84/85
Region/ Program
State/ Areas Start Type
I
CT Statewide 1/83 CC
SE
A
I
MA Statewide 4/83 0
SE
A
I
S
II
NJ Statewide 2/74 H
SE
A
I
S
NY NYC metro: 1/82 D
Bronx SE
Ki ngs A
Nassau I
New York S
Putnam
Queens
Richmond
Rockl and
Suffolk
Westchester
Program Type Key
D decentralized
CL central local-run
CC central contractor
CS central state-run
H cntrl/dcntrl hybrid
Test Mode
I = idleed
L <* loadedeed idle
R » two speed idle
S = safety
Tamper Test
Test Waiver Fee
$
Waiver C 40 10
P,A,S E
E.C.I
R.T
Always C 100 10
I or 10%
1980+ of value
C and
Waiver L
All E
None None 2.50°
C
12°
D
Always L 6.50
1984+
P.A.E
C,I,R
T
Program Type Key
RE registration-enforced
SE sticker-enforced
RS registration & sticker
A annual inspection
B biennial inspection
"Includes safety
Inspection fee.
Vehicles Exemp- Light Duty Cutpoints
Included tions Years CO HC
% ppm
1968+ to M 1968-1969 7.5 750
10,000 Ibs. D 1970 7.0 650
1971 6.0 650
1972 6.0 575
1973-1974 6.0 425
1975-1979 3.0 300
1980 2.5 275
1981+ 1.2 220
Last 15 M 1970-1974 7.0 800
years to D 1975-1979 4.0 400
8500 Ibs. 1980 2.7 300
1981+ 1.2 220
All years M Pre-1968 8.5 1400
to 6000 D 1968-1970 7.0 700
Ibs. 1971-1974 5.0 500
1975-1980 3.0 300
1981+ 1.2 220
All years M Pre-1975 6.5 800
to 8500 D 1975-1977 5.7 700
pounds 1978 4.3 500
1979 3.0 400
1980 2.7 330
1981+ 1.2 220
Tamper Test Key Waiver Key
P PCV C = cost waiver/$
A air injection R = reduction/%
S spark system L * stated repairs
E evap system E * tamper repair
C catalyst costs excluded
I Inlet
T air intake Exemption Key
R EGR M » motorcycles
D - diesels
VII-11
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Table 7-2 (corit.)
Region/ Program
State/Areas Start Type
III
DC city-wide 1/83 CL
SE
A
I
S
DE Wilmington: 1/83 CS
New Castle RE
A
I
S
VA DC suburbs :12/81 D
Arlington RS
Fairfax Co. A
Prince William I
Fairfax S
Al exandri a
Falls Church
Manassas
Manassas Park
IV
GA Atlanta: 4/82 D
Cobb SE
DeKal b A
Fulton I
Gwinnett 1/86
NC Charlotte: 12/82 D
Mecklenburg SE
A
I
S
TN Memphis: 8/83 CL
Shelby RE
A
I
S
Program Type Key
D * decentralized
CL = central local-run
CC = central contractor
CS = central state-run
Test Mode
L * loaded
I = idle
R = two speed idle
S = safety
Tamper Test
Test Waiver Fee
$
None None 5°
None C 75 None
Always C 75 5
All or
devices L
E
Always C 50 3
P.A.S E
E,C,I
R
Always C 50 10°
P.A.C E max
I.R.T
Waiver C 50 None
C,I or
L
E
Program Type Key
Vehicles Exemp- Light Duty Cutpoints
Included tions Years CO HC
% ppm
All years M Pre-1968 12.5 2000
to 6000 D 1968-1970 11.0 1250
Ibs. 1971-1974 9.0 1200
1975-1979 6.5 600
1980+ 1 .5 300
1968+ to M 1968-1970 1100
8500 Ibs. D 1971-1974 800
1975-1979 500
1980 275
1981+ 220
Last 8 M 1977-1979 4.0 400
years to D 1980 2.0 220
6000 Ibs. A 1981+ 1.2 220
Last 10 M 1975-1979 4.0 400
years to D 1980+ 2.5 250
6000 Ibs.
Last 12 M 1973-1974 7.0
years, all D 1975-1978 5.0
vehicles 1979-1980 3.0
1981+ 1.5
All years M Pre-1972 9.9 1990
to 8500 D 1972-1974 9.0 1990
Ibs. 1975-1979 8.5 1990
1980 6.5 1990
1981+ 3.0 1990
Tampering Key Waiver Key
RE » registration-enforced P PCV C = cost waiver/J
SE » sticker-enforced A air injection R - reduction/%
RS = registration & sticker S spark system L * stated repairs
A * annual inspection E evap system E * tamper repair
C catalyst costs excluded
"Includes safety I inlet
inspection fee. R EGR Exemption Key
T air intake D * diesels
A * air-cooled
M = motorcycles
VII-12
-------
Table 7-2 (cont.)
Region/
State/ Areas
VI
TX Houston:
Harris
Program
Start Type
7/84 D
SE
A
T
S
Tamper
Test Waiver
Always None
P,E.A,R,T
1980+:
C.I.L.X
1984+
0
Test Vehicles Exsnp- Light Duty Outpoints
Fee Included tions Years CO HC
$ X ppm
2.75 1968+ to M
1980+ 8500 Ibs. 0
0
None
VII
MO St. Louis: 1/84
St. Charles
St. Louis
St. Louis City
Jefferson
VIII
CO Denver: 1/82
Adams
Arapahoe
Boulder
Denver
Douglas
Jefferson
Colorado Springs:
El Paso
Fort Collins:
Larimer
D
RE
A
I
S
0
SE
A
I
R 81+
Always
P,A,E,R
1981+
C.I
Al ways
1982+
A.C.I
L
1968-80
L 15
1981+
C 100
E
4.50 1971+ to
max 6000 Ibs.
licensed
weight
10 1968+ to
max 10,000 Ibs.
M
D
0
M
0
0
1971-1974
1975-1979
1980
1981+
1968-1971
1972-1974
1975-1976
1977-1978
1979
1980+
7.0
6.0
3.0
1.2
6.0
5.4
5.0
3.4
2.0
1.5
700
600
300
220
1200
1200
800
500
400
400
Program Type Key
D » decentralized
CL = central local-run
CC » central contractor
CS = central state-run
Test Mode
Program Type Key
RE
SE
RS
CM
A
registration-enforced
sticker-enforced
registration & sticker
computer matching
annual inspection
Tampering Key
I = idle
R * two speed idle
L - loaded
T = tanpering
S = safety
p
A
R
E
C
I
0
T
L
X
PCV
air injection
E6R
evap system
catalyst
inlet
oxygen sensor
air intake
PI umbtesmo
repl ace cat if
inlet tampered
Waiver Key
C » cost waiver/$
R » reduction/%
L » stated repairs
E = tamper repair
costs excluded
Exemption Key
M = motorcycles
diesels
other fuels
VII-13
-------
Table 7-2 (cont.)
Region/ Program
State/ Area Start Type
IX
AZ
NV
X
OR
Phoenix: 1/77
Maricopa
Tucson:
Pima
Las Vegas: 10/83
Clark
Reno:
Washoe
Portland: 7/75
Multnomah
Cl ackamas
Washington
CC
RE
A
I
0
RE
A
R
CS
RE
B
R:81+
Irpre
81
Tamper
Test
None
Waiver
1975+
C
Always
1975+
P,A,S
E.C.I
R.T.M.O
1970-74
P.A.E
Waiver
C
R
50
40%
Pre-82
L 14
1982+
C 100
E
None
Test Vehicles Exemp- Cutpnts 4cyl
Fee Included tions Years CO HC
$ % ppm
5.44 Last 13
years, all
vehicles
8 1965+ to
5000 Ibs.
curb wt.
7 Last 20
years
D
M
D
0
M
D
over
8500
Ibs.
1972-1974 6.
1975-1980 2.
1981+ 1.
1965-1967
1968-1969
1970-1974
1975+
0 450
5 250
5 250
7.5
5.0
4.0
3.0
6-8
CO
%
5.5
2.2
1.5
cyl
HC
ppm
400
250
250
Outpoints established by
model year and make,
detailed list available.
Most 1975+ vehicles:
1.0% CO, 225 HC
Program Type Key
D = decentralized
CL * central local-run
CC = central contractor
CS * central state-run
Test Mode
idle
two speed idle
loaded
s afety
tampering
Program Type Key
RE = registration-enforced
SE * sticker-enforced
RS = registration & sticker
CM = computer matching
A * annual inspection
B - biennial inspection
Tampering Key
P * PCV
A = air injection
R = EGR
E * evap system
C * catalyst
I = inlet
M - computer module
T = air intake
S = spark system
0 = oxygen sensor
Waiver Key
C = cost waiver/$
R = reduction/%
L = stated repairs
E = tamper repair
costs excluded
Exemption Key
M = motorcycles
D = diesel fuels
0 » other fuels
This table summarizes characteristics of the 16 I/M programs audited in FY 1984/35. These
characteristics have been derived from statutes and/or rules and regulations promulgated by the
State or locality. The list includes the names of counties, cities, and States implementing
I/M; however, in somes areas only part of the county listed is involved, not the entire county.
The date listed under Program Start is the actual start date of the mandatory I/M program; in
some cases, voluntary programs started earlier. The Program Type column indicates whether the
program is centralized or decentralized, what type of enforcement mechanism is being used, the
test type, and frequency. The Tamper Type column indicates when tampering inspections are
conducted and which components are checked. A key to abbreviations is provided at the bottom
of each page. Test fees may include safety inspection which Is indicated by a degree symbol.
The cutpoints are for light duty vehicles only.
VII-14
-------
TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing/
1. REPORT NO. 2.
EPA-450/2-85-009
4. TITLE AND SUBTITLE
National Air Audit System-FY 1985 National Report
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
Director, Office of Air Quality Planning & Standards
Office of Air and Radiation
U.S. Environmental Protection Agency
Research Triangle Park, North Carolina 27711
3. RECIPIENT'S ACCESSION-NO.
5. REPORT DATE
December 1985
6. PERFORMING ORGANIZATION CODE
8. PERFORMING ORGANIZATION REPORT NO.
10. PROGRAM ELEMENT NO.
13A2A
11. CONTRACT/GRANT NO.
68-02-3892
13. TYPE OF REPORT AND PERIOD COVERED
Final - FY 1985
14. SPONSORING AGENCY CODE
EPA/200/04
15. SUPPLEMENTARY NOTES
16. ABSTRACT
The National Air Audit System, which was jointly developed by EPA and
representatives of State and local air pollution control agencies was implemented
for the first time in FY 1984. In FY 1985, the system audited air pollution control
activities in 68 State and local agencies in the areas of air quality planning and
State implementation plan activity, new source review, compliance assurance, air
monitoring, and inspection and maintenance. The goals of the audit system are to
identify obstacles that are preventing State and local agencies from implementing
effective air quality management programs and to provide EPA with quantitative
information for use in defining more effective and meaningful national programs.
The report for FY 1985 indicated that, for the most part, State and local agencies
have sound programs in each of the four audited areas. Areas of possible
improvement were found, however, which will be the focus of various remedial
activities.
17. KEY WORDS AND DOCUMENT ANALYSIS
a. DESCRIPTORS
Air pollution
Air audit
Air quality planning
New source review
Compliance assurance
Air monitoring
Inspection and maintenance
13. OISTRIBUT1ON STATEMENT
Release unlimited. Available through
NTIS
b.lDENTIFIERS/OPEN ENDED TERMS
Air Pollution Control
19. SECURITY CLASS (This Report)
Unclassified
20. SECURITY CLASS (This page)
Unclassified
c. COSATI Field/Group
13B
21. NO. OF PAGES
129
22. PRICE
EPA Form 2220-1 (9-73)
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