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 I
 I
                                    SOME ASPECTS OF EMISSION CONTROL
 •                                               IN THE
                                        BY-PRODUCT COKE INDUSTRY
 I
 I
 I
 I
                                             George B. Crane
 I
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      ENVIRONMENTAL PROTECTION AGENCY
Office of Air Quality Planning and Standards
        Engineering Srr^ioes Branch

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I
•                                           Introduction
B                This  document has been issued as an aid to enforcement personnel of
                  Region  V and should be useful to other EPA engineers.  It constitutes
•     ,           partial coverage of control of air pollution from by-product coke ovens.
                  The subjects covered are:   (1) coke quenching and the effect of foul
I                water on air and water pollution emissions, and (2) coke plant control
_                equipment manufacturers and their capabilities to install necessary
                  control systems.
B                Subject (2) was investigated by telephone contacts with vendors.
•                In most cases, company literature was available in time to be considered
                  in the  report.  Some company contacts were uncertain about the existence
•                of control  applications within the United States.  Otherwise subject  (2)
                  Identifies  all significant  coke plant control equipment manufacturers located
'                in the  U. S. or licensed  to do business here, along with the controls
•                installed or contracted,  and date of startup if now  under construction.  The
                  summary of  U. S. control  is current as of February 1973.
                  Although coke quenching is  described in subject (1), the available quenching
I                controls are identified and located as described in  subject  (2).  The
                  ordinary quench tower is  not covered in this document.
                  It was  not  possible  in the  time available to estimate the number of  ovens  that
|                a vendor could rehabilitate or the number of control systems that he  could
                  install within a given time.  However, the vendors'  U. S. control
•                installations have been identified to indicate their capabilities.
I

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                             Coke Quenching

 If a  coke  oven  contains 13 tons of coke, and if this is pushed into a car        |
 and quenched  from  2200 to 400°F using 4,000 gallons of water at ambient          «
 temperature,  about 14,000 pounds or 40 percent of the water will be
 evaporated.   This will generate about 370,000 cubic feet of steam.              I
 Quenching  is  done  by water sprays in approximately 2 minutes.
                                                                                 I
 Measurements  on actual quench towers by U. S. Steel show that the vapor
 velocity and  temperature reach a maximum of about 36 feet per second             £
                                                      2
-(ft/sec) and  160°F, respectively, early in the quench.   During the
 remainder  of  the quench, there is a nearly linear drop to about 32 ft/sec
 and 150°F.  A volume of about 900,000 cubic feet of steam and air are
 discharged from the tower during each quench.  The air rushes into the
 bottom of  the quench tower as the hot steam and gases flow upward and out
 the top.  The gas  velocity was measured-by dividing the cross section of
 the quench tower into  16 equal area zones and taking pitot tube traverses.
 Temperature was also measured in each zone.
 Liquid entrainment by  the above steam-air mixture should commence at a
 gas velocity  approaching 10  ft/sec and indeed, considerable mechanical
 carry-over of quench water is always observed.  There is a distribution
 of particle sizes  and  the coarse drops fall out near the quench tower.
 The net result  is  that more  than 40 percent of the quench water is carried
 out; the total  amount  released is that vaporized plus that mechanically
 carried out.  The  latter may amount to 5 - 10 percent of the quench water

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                                                 I
                                                 I
 •            Tato of Chemicals 1n Quench Water
                            i
 m            It has been common practice for coke makers to quench v/ith waste water
               from coke oven by-product recovery plants.  Coking coals contain varying
 I     .       amounts of chemically combined nitrogen, sulfur, and chlorine.   These are
               largely volatilized in the coke oven as organic compounds and occur in the
 I            waste waters from the by-product recovery plant.  The chlorine shows up
 M            as a chloride, and part of the sulfur appears as sulfate.  It is costly to
               remove these from the water waste.  Many organic compounds also appear in
 tt            the water waste, to a degree depending on their degree of separation in
               the by-product recovery plant.  These organic chemicals can be removed by
 m            proper treatment of the water waste.  Ammonia can occur in the free form
 m            (NH4OH) and in the fixed or chemically combined form (NH^CI and NH^SC^).
               If lime is added by operation of the "fixed still" in the recovery
 I            plant, CaCl2 and CaSO^ will be in solution, the latter to the extent of
               its solubility of about 2 grams/liter.
 I
               It is evident that many chemical compounds can be present in the v/aste
 J            water sent to quench.  Because of the highly transient phenomena and the
               short time intervals involved, and because of the three-phase quenching
 •             system, one cannot calculate the chemical emissions due to quenching,  neither
 •             adiabatic flash nor isothermal flash assumptions will give an accurate
               picture of the situation.  A rough estimate would simply say that if 40
 J             percent of the quench water is evaporated and 10 percent is mechanically
               carried out, then 50 percent of the chemicals are evolved - perhaps somewhat
 •             greater for low boilers and somewhat less for the high boilers.

I

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                                                        T.FVISFD:  2/20/73
Table 1 gives the standard raw waste level  of a coke plant, defined as
the quantity pf chemicals in the raw waste before any treatment.   Obviously,
the range can be enormous, and for this reason, subsequent values that
                            ;
I discuss may not agree with the averages of Table 1.  The BOD5 item
is obtained by a standard test using v?aste-consuming bacteria and is a
measure of total organic matter that can be thus consumed.  The figure
3.5 pounds represents an oxygen demand to convert to COp and H^O by bacterial
oxidation.
Table 2 shows the total coke plant effluent with the best available
treatment, i.e., the highest degree of treatment that has been reliably
achieved in an actual treatment.facility within the steel industry.  This
degree of treatment may be costly for some segments of the steel industry.
Ammonia in the solution is stripped out in the "free still."  Ammonia is
liberated from sulfate and chloride salts by treatment with lime and stripping
in the "fixed still."  All waste streams are combined in the biological
treatment or "bug" plant.  Cooling towers are employed to reduce the volume
of water to be treated.  The cooling tower blowdown is sent to the biological
plant  to dilute the still waste.
Table  3 shows the major waste components in an actual coke plant and their
total  estimated daily flow after specified treatment.  This treatment was
not  the oest available.  The free and  fixed ammonia  stills were  to operate
with addition of  lime to effect a 90-percent  removal of  ammonia.  This
seems  like  low  removal but it corresponds to  0.00016  mol fraction
 (100 parts  per million by weight) in  the still bottoms.   The  combined  flows  of
550  gpm were to go to a  trickling filter for  an  assumed  phenol removal  of
 '". " /•• ,  .'u:]t.  It ;!,i :"..!•./. ;...'   • - '	• <.-

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1 Table 1. STANDARD RAN LIQUID WASTE
-3
LOAD COKE MANUFACTURING"3
• • (Basis = 1 ton dry coal coked)
1 Parameters Range
~~
Water flow, gal 1400 - 4200
1
Phenol, mg/liter 5-35
| lb 0.125 - 0.875
• Cyanide, nig/liter 0.10 - 155
lb 0.0025 - 3.88
1
NH3, nig/liter 1.0 - 78
| lb 0.025 - 1.95
• BOD5, ing/liter 7 - 600
Ib - 0.175 - 15
1
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Average
3000

22
0.55
12
0.30

14
0.35
150
3.5

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                                                        REVISED:  2/2IV/3
              Table  2.   TOTAL  COKE PLANT LIQUID
                     WITH  BEST AVAILABLE TREATMENT
                    (Basis s 1  ton dry coal coked)
Water flow, gal
Phenol, Ib
Cyanide, Ib
Ammonia, Ib
BOD5, Ib
                                                      500
                                                      0.002
                                                      0.003
                                                      0.020
                                                      0.045
any effect on chlorides  or sul fates.   Oxidation  of  sul fides  increases
the amount of sul fate.
Properly designed and operated bug plants  can  effect much  greater phenol
removal than 60 percent.   Recoveries  of 90 to  95 percent can also
be made by liquid extraction,  by operating on  phenol -containing  streams
early in the process before they are  diluted with other aqueous  wastes.
Whenever bug plants are used,  some parallel standby or other provision
must be made for continuity of phenol removal  if the phenol-consuming
bacteria are killed by shock loads, poisons, or other  process irregularities.

From the data above, it is evident that economical  treatment of  coke
plant aqueous wastes may still  leave  sufficient amounts of phenols  and
organics that the water is unacceptable for use in  quenching. More important,
perhaps, is the fact ttiat the treatments mentioned  do  not  remove inorganic
salts.  Table 3 indicates that there  are about 29,000  Ib/day of  calcium
chloride and sulfate in the treated waste.  In quenching with this

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I
            Component
            H~0 gpm



            Phenols



            Ammoni a



            Sulfide



           jSulfaue
           /


            Cyani de
           i

           I
            Cyanatcs



            Chlorides



            Calcium
                             Table  3.   PROPOSED  TREATMENT FOR LIQUID WASTE

                                      FROM AN  ACTUAL  COKE PLANT4


                                (Basis =  8600  tons/day dry coal  coked)
Haste. Ib/day
Before treatment
540
4,000
13,400
3,200
4,400
1,000
2,200
10,000
_
After treatment
550
.1,600
1,340
250
5,240
150
1,700
10,000
13, POO

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they are also carried out in the 5'to 10 weight-percent  portion  of
qucnchwater leaving as droplets,  The material  settling  to the ground
1s washed to the rivers by rain.  The same 1s true of organlcs.   Also,
             I               '
a significant amount of material - especially these inorganic salts  -
remains on the cooled coke.  They are transferred to the blast furnace  and are
more or less volatilized out of the cool top, going to the blast furnace gas
washer.   This is a water washer to remove particulates  from the blast
furnace gas.  Volatilized organics and inorganics (CaCl2> etc.)  go Into
the wash water and eventually to disposal whence they find their way into .
streams.  Sulfates which do not volatilize are  reduced to sulfides and
enter the blast furnace slag.  On weathering, part of this slag  sulfide
can be released to air as H^S.
In summary, coke quenching mainly redistributes most of the pollutants
which are originally in the quench water.  A portion goes to air, part
goes to ground and thence to watercourses, part goes to blast furnace
slag and thence to air.  Both air and water pollution result.
Estimated Air Pollutant Emissions During Quenching
A United Nations study gives some quench emissions based upon experiments
with aqueous wastes from byproduct coke plants.   In one case, the volume
of steam was known and samples - Including condensate - were analyzed.   In
the other case, a material balance was made or, the quench water.  These
data are from Europe, and the quench water composition probably differs
from that In many U. S. plants.  Nevertheless, I have worked the emission
figures over onto the bases of Table 3, which is 8600 tons/day of dry
coal coked.  The results are shown in Table 4 and represent air emissions
                                  8

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from a 11. S. plant coking B600 tons/day of coal 1f the quench water and
other conditions were comparable to pages 17 and 30 in reference 6.
From the same study, the probable performance of the U. S. plant with
respect to parti culates might be:

P articulate Tb/day.
Grit
No control 1,100
Control 260
Droplets
No control 22,000
Control 2,200

This amounts to about 75 percent control on grit and 90 percent control
on aqueous droplets. The study data are based on:
a. Area deposition measurements, and
b. Collection on greased plates above the quench tower.

Table 4 and the above values are all based on extrapolation of European
estimates, but they give the best estimates of which I am aware, based
on any published data. Measurements 'In the United States are needed.


.
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Pollutant
Table 4.  AIR EMISSIONS WHEN QUENCHING
 WITH COKE PLANT WASTE WATER IN U.  S.
(Basis = 8600 tons/day dry coal coked)

                       Emissions, lb/daya
Phenol
Naphthalene
NH3
H2S
HCN
Tar
Cl-
Page 17
2100
360
1500
1000
120
120
360
Page 30
820

820
2000
4


50
                 960
 ^Assuming conditions are equivalent to those in reference 6, pages 17 and 30.
                                1U

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                                                                          •REVISED:   3/12/73
                                                  i

 I
 •                              United States Suppliers  of Coke Ovens  and
                                  Associated Emission Control  Equipment
                             i               i
                                            II
                Time requirements for building a grassroots coking facility,  including
 •              by-product recovery plant and associated air and water pollution controls,
                may be assessed by the actual requi rements for the 87  oven battery at
 I              Brown's Island, Weirton Steel Division of National Steel  Corporation.
                The time used was:
                     1.  Scope of work, specifications and request for bids       3 months
 |                   2.  Bid response and evaluation of bids                      4 months
 m                   3.  Company decision to build                                3 months
                     4.  Select 2 contractors (engineer and construct)
 I                       and award contracts                                      9 months
                     5.  Construct facilities                                    27 months
 I                       Total                                                   46 months
 I              Extensive repair, alteration or construction of coke oven facilities in
                the United States is limited by the availability of silica brick, now
 •              available from only two U. S. sources, Harbison Walker and General Refractories,
 •              With en average projected demand of over 50,000 tons/year, the 42,000 ton/yr
                U. S. manufacturing capacity is about 10,000 tons/yr deficient.  Little
 J    .          if any import from Europe, or even from Japan, seems possible.   The silica
                brick shortage is due to loss of the silica brick market by the disappearance
"              of open hearth furnace users, and from retirement of skilled brick-shrtpe
 •              mold makers, who are not being replaced.

I

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                                                   y  \REVISED:   3/12/73

Koppcrs Company Inc.

Koppers Company is the largest United States  supplier of coke  ovens
and by-product coke oven gas plants as well  as associated air  and
water pollution control equipment.   The company is  reported to have
built about 70 percent of the total U. S.  coking capacity.   During
World War I and II, Koppers had the capacity  to build about a  dozen
batteries at one time, although, this activity would not be entirely
simultaneous.  There would be some  staggering.

The following sections describe Koppers1 activities and capabilities and
do not constitute an exhaustive coverage.   Only emission control  methods
are identified; the reader may find descriptions and drawings  in  many
              q
other sources.
     1.  EPA - AISI smokeless charging concept; gravity feed Tarry  car
     on a battery with single collecting main.  Jones & Laughlin  Steel
     Corporation, Hazelwood, Pennsylvania; Granite City Steel  Company,
     Granite City, Illinois (latter for 1973 startup).
     Further developments in EPA -  AISI smokeless charging with a screw-
     feed larry car plus other mechanical  refinements, on ovens with 2
     collecting mains.  Donner Hanna Coke Corporation, Buffalo, Kew York;
     Bethlehem Steel Company, Burns Harbor, Indiana; Colorado Fuel  and,
     Iron Corporation, Pueblo, Colorado.  Weirton Steel Division  of National
     Steel Corporation.  (Target date for startup - in spite of explosion
     at site of ovens - is now June 1973.  )

     Retrofit of EPA - AISI concept on existing larry car at Ford Motor
                                   12

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                                                   REVISED:  3/12/73
hydraulic controls by overheating clue to limitations on physical
location suggest the unsatisfactory nature of this type of retrofit.
I                  2.   Pipeline  charging.   Building  56  new 20-foot ovens  with capacities
Q                  of 2500  tons  per  day  of coke.   Inland Steel  Company,  Indiana Harbor;
*         ,         Indiana  (1974 startup).
9                  3.   Smoke  transfer pipe.   Supplemental  suction  is  created to pull
•                  the emissions from the  oven  being charged into  an  adjacent,Oven,
                    where, under  oven suctions,  they  are collected  by  the  oven gas collecting
•                  main.  Jones  & Laughlin Steel  Corporation.

I                  4.   Emission  control  during  pushing.  Traveling quench car hood,  directing
                    to a smoke collection main and scrubber.   Ford  Motor Company, Dearborn,
|                  Michigan.
I                  b.   Emission  control  during  pushing.  Coke side hood  extending
                    for the  total length  of the  battery  with  overhead  exhauster main
•                  going to water scrubber.   Inland  Steel  Company, Indiana Harbor, Indiana.
|                  6.   Control of pushing  emissions  by  "one spot"  transfer car and
f                  smoke scrubber on gas cleaning locomotive system.   WelrtOR Steel
                    Division,  Weirton, West Virginia   (1973 startup).
•                  7.   Continuous controlled quenching  from a closed  coke receiving hopper.
•                  Weirton  Steel Division  of National Steel, V.'airton, Heft Virginia
                    (1973 startup).            '                             ;   ' ,

                    8.   Koppers vacuum carbonate process for removal of mlfur ffojn
•                  '"',"i!;P PVC !"i  r>":<;. "!!-!<•  prOC01"'* •"' '  ' "-"v»v* <••• "•?• G? MCP^ffnlfe df ft-^
                    from coke  oven gas, and there 'is  no  water pollution
                                                   13

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                                                                  3/1,7/73
     It operates  1n conjunction with  a  Claus  sulfur  recovery plant.  The
     only installation  currently  operating  is  at Donner llanna Coke,
     Buffalo,  New York.   One  at the Heirton Steel  Division  of National
     Steel  Corporation  is scheduled for startup in June 1973.  Other
     installations have been  built by other firms  than Koppers.

     9.   Ammonia destruction process.   This  removes  NFL  ion from aqueous
     waste by  stripping out as NH^, followed  by incineration to  form N2
     and HpO.   Weirton  Steel, Weirton,  West Virginia  (1973  startup);
     Inland Steel Company, Indiana Harbor,  Indiana (1973  startup).
    10.   Biological treatment.   This process  removes phenols and certain
     other organics from coke plant aqueous wastes.   A biological oxidation
     occurs.  Koppers claims  99 percent phenol  removal is possible.  They
     also estimate 75 to 85 percent  removal of CN.  Among the plants
     having this  system is Weirton Steel,  Weirton, West Virginia (1973
     startup).
Wilputte Corporation
Wilputte is another old-line  firm that  has been building  coke ovens  in  the
United States  since early in  the  century.   Until  1970,  it was owned  by
Semet Solvay,  a subsidiary of Allied  Chemical Corporation.   It  is now
owned jointly by Salem Corporation of Pittsburgh  and Gibbons  Brothers
Ltd. of England.
Wilputte is a fully integrated engineering and contracting  firm specializing
in design and construction of coke ovens,  coke oven  machinery,  and  by-product
-.      i . !•: c- ".-•..     :.-.?.
Since  1966, over 1200 large-capacity coke ovens have been completed.
                                   14

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  I

  I
  _              Among Wilputte's  services  to industry  are:
                      a.   Planning studies  and capital  budgeting  for coke production
  •                   requirements.

 |                   b.   Coke plant facility studies and  survey  reports for  pollution
 _                   abatement.

                      c.   Coke oven  battery inspection.

                      d.   Project  management and field  supervision  for coke oven
 |                   battery rehabilitation.

 •                   e.   Preventive maintenance programs.

 •              The following sections describe Wilputte's  pollution  control  capabilities.

 •                   1.   Automotive lid lifter and programmed charging, for  most
                      existing coal  charging cars.   One now  operating  at Great Lakes
 I                   Steel  Division, Detroit, Michigan.

 I                   2.   Smoke transfer pipe.  A supplemental suction is created  to
                      pull the emissions from the oven  being charged into an  adjacent
 |                    oven,  where, under oven suction,  they  are collected by  th* oven
 g                    gas collecting main.   This has been  tested  only  at the  Dormer Hanna
                      works.

 •                    3.   Mobile rotary continuous  quencher.  Prototype operated at
 •                    Clairton plant of U.  S. Steel. Wilputte says this quencher  can
                      be  built for existing battery installations.
I
I                                                  '»                       ,

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                                                        REVISED: 2/28/73
     4.   Pipeline charging.   Semet Solvay  Division of Allied Chemical,
     Detroit, Michigan.   Battery  of 70  ovens..  Startup  1973.  Scmet
     Solvay Division prototype at Ironton, Ohio.  Completed in  1970.
     Another is being built  for Alabama By-Products  Corporation for startup
     in late 1973.   It will  service 78  ovens.

     5.   Ammonia destruction.  No installations to date,  but Wilputte  is
     bidding on several  units.

     6.   Vacuum carbonate coke oven gas desulfurization,  with Claus
     process to recover  elemental sulfur.   Clalrton  unit  of U.  S.  Steel
     is operating.   Several  were  built  but not  now operating, including
     units for Republic  Steel at  Chicago and Warren, Ohio.

     7.  Phenol recovery.  Light  oil extraction process.  About a  dozen
     units built within  past 25 years.   Also solvent extraction process
     licensed by Jones & Laughlin Steel Corporation.
Coaltek Associates  (Division of Allied  Chemical Corporation)

Pipeline charging.   As of February 1973, Coaltek  has licensed  all  coke
oven builders in the world,  except one, to construct pipeline  chargers.
After licensing, their services to the  contractor include monitoring
of process flow sheets,  P and I diagrams, plant layout, specifications,
and other general guidance.

Table 5 shows the U. S.  installations of pipeline charging  built  and
building.  According to  Coaltek,  several studies  concerning other
,o-   !•'.: -iii,'.,' .<. '  ...  .:.:  :c. :     •   .  V,         ,;  ::  ,
confidence that industry has in pipeline charging.
                                16

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                      Table 5.   U.  S.  PIPELINE CHARGING
                      INSTALLATIONS LICENSED BY COALTEK
     Company
     Ovens
Number   Status
          Number of
            6-1nch
          pipelines
Semet Solvay,
 Ironton, Ohio
Semet Solvay,
 Detroit
Inland Steel,
 E. Chicago
Alabama By-
Products,
 Birmingham
  24
  70
  56
Existing
New
  Pre'rieaters
Number  Tons/hr
        of coal
         each
                                40
          80
         100
  Startup
  78
Existing
          80
                     1970
   1973
February 1974
 March 1974
  Coaltek claims that their process  can readily be installed on batteries

  built within the past 6 years;  they say such  ovens  have the charging

  pipeline entrances built in.  They also Insist,.outside statements  to

  the contrary notwithstanding, that pipeline charging can be Installed on

  most existing ovens, although it cannot be jusitifed for ovens more

  than about 20 years old.
                                 17

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Arthur G.  McKee

McKce is a large engineering and construction firm which has joined with
Dr. C. Otto and Company of West Germany and Otto Construction Company of
New York to provide design, engineering, and construction services for
coke and coke by-product plants.  McKee has designed numerous major
facilities for metals processing and for petroleum, chemicals, and
minerals processing.

Otto has operated in Germany for over a century and has built about
65,000 coke ovens throughout the world during that time.  For the U. S.,
available information shows the followinq Otto construction:  85 ovens
in 1969 for Great Lakes Division, National Steel, Detroit; 63 ovens in
1959 for U. S. Steel at Fairfield, Alabama.

Pollution control offerings include the following:

     1.  Coaltek pipeline charging.

     2.  Otto quench car hood on the coke side.  The hood covers the entire
     length of the quench car track.  The hood is compartmented for five
     ovens per compartment and a stationary wet scrubber.
     3.  Three-stage movable quenching machine.  For new batteries.

     4.  Dry coke cooling system.  Pushed coke is cooled by inert gas
     and auxiliary quenching.

     5.  Miscellaneous designs for sulfur removal from coke oven gas,  for
     ammonia destruction, and for phenol removal from waste water.

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              Ihcro Is  little Information  about  items  3 and  4  above.   Further Invostiration
              is warranted.
^            In operational responsibility, Otto handles  electrical,  instrumentation,
•            and ordinary materials handling systems.   McKee supervises construction
              and Otto supervises startup.
              The Iron and Steel Division of McKee has  responsibility for coke plants.
I            This office is in Cleveland and has about 1000 men; however, this office
              also contains the Petroleum Refining and  Chemical Divisions.
I
M            J. E. Allen and Associates

—            This company is involved in a hooded-car  quench system.   The first unit
•          '  was developed jointly by the above; Interlake Inc. Technical Center,
•            Chicago; Hanby-Allen Pollution Control Systems, Inc. (HALCON), Chicago;
              and Aronetics Division of Thermotics, Inc., Houston.

              Two specially equipped'cars are coupled together.  The hooded quench
•            car is intended to capture emissions from pushing.  These are drawn
              into the cleaning system on the trailer by the draft induced by a two-
•            phase jet scrubber.
J            A test of the unit was made in Houston using a smoke bomb.  The unit has
^            been shipped to the Interlake plant, Chicago, where the first test will be
*            made on actual coke ovens in April 1973.
I
              Mitsubishi  Chemical Industries Ltd.

              i-iilsuuisiii  started in I(JJ4 as a prouuccr  01  coke and tar products, but is
•            now a combination of business enterprises including metal production, petroleum,

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chemical1.,, nuclear equipment, construction i qui|'.v.?rit, <,;id several  others.
Mitsubishi has devolop"(i some rather olirctivp coke own controls  which
seem to be available ior licencing with the UniU'H .cilni':s, hut  I hove  few
details.  They do, hcv:evor, have a liaison office in New York at 277 Park
Avenue.  The emission controls described by Mitsubishi .ire as follows:
     1.  Smokeless charging.  Charging car with Movable but  unspecified
     dust collector system to prevent emissions from charging hole and
     ascension pipe.  According to color photographs sent by Mitsubishi,
     control is excellent.

     2.  Smokeless pushing.  A hood is attached to a coke guide to
     cover the quenching car.  This hood attached to a suction  duct
     extending the length of the battery, at a sport in the  duct
     depending on the oven being pushed.  Gases and dust go  to  a
     nearby scrubber.  Clean gas goes to stack.  Color photographs
     sent by Mitsubishi indicate excellent emission control. Great Lakes
     Steel Division, National Steel, Detroit, Michigan.  Startup 2njd quarter
     of 1973.
American Waegner-Biro Company, Inc.
Dry coke quenching was developed in Europe m?ny years ai;o and used to  a
limited extent where .coal was costly and air pollution was not  tolerated.
I have references to about four plants in Europe for coke capacities  in
the 500 to 900 tons psr day range.  A few plants in Switzerland, by other
makers, arc also applying this principle to  coke or to other products.
 '., •• -  \*  , ,-  t .  :  ...  --:,, ,.'.U . '.    .   , . ...      ' -.   ,   .-•-•'. ..'.   ......
 the direct cooling iirSiiiUiii and uLi.uincs> y.cuCij-  h^wt-u  ui  Jiy  piucesiJ.
                                 20

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 ™  -                                             '                    REVISED:   3/12/73
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 M          Heat is then recovered from the hot exit gas  by indirect hoat exchange
             to water, forming useful  steam.
 •          The Waagiuer-Biro dry coke quenching system has  not been tried in the
 •          United States.   Some critics contend there is a serious dust problem
             with the product, calling for wetting and increased water to the blast
 •          furnaces.  Others think that it can eventually  become important because
             of the saving of heat from the pushed coke.
             To illustrate the heat savings available by gas cooling and steam
 |          generation, the savings may be calculated as  a  percentage of the heat
 £          used in firing the coke ovens themselves.   The heat saved by dry cooling
             of coke from, say 1832° to 572°F, amounts to  nearly 18 percent of that
 I          used to fire the ovens.  The overall heat transfer efficiency was taken as
             85 percent.
 I
 m           Tailor and Company, Inc.
             This company 1n Bettendorf,  Iowa, is developing a  pneumatic  preheated coal, oven
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injection process, including a locking, self-cleaning oven charge port.   The
process seems complex and, to my knowledge^it has  not vet been

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                                                             REVISED:  3/12/73
 1.   Crane,  G.  B.  to  Megonnell, W. H.  Trip Report:  Fairfield Works of
     U.  S. Steel  Corporation  at Birmingham, Alabama.  October 7, 1971.
                              /'
 2.   Fuller-ton, R.  H.   Impingement Baffles to Reduce Emissions from Coke
     Quenching.  JAPCA  V7:  12, 807 -  809  (1967).
 3.   Industry Profile StuJy on Blast  Furnace and Basic Steel Products.
     Contract 68-01-0006.   Water Quality  Office, Environmental
     Protection Agency.   December  1971.
 4.   Crane,  G.  B.  to  Megonnell, W. H.  Meeting  Report:  U. S. Steel and OAP
     Personnel  at Raleigh,  December 29, 1971.
 5.   Crane,  G.  B.  to  Cuffe, S. T.  Trip Report:  Meeting with United
     States  Steel  Personnel at Department of Justice, Washington,  D. C.
     November 2, 1971.
 6.   United  Nations Study ST/ECE Coal  26, pp.  17 and  30.
 7.   Personal communication,  Norman Plafcs, CSD, OAQPS,  EPA.
 8.   Personal communication,  Edward Gibbs, Marketing  Manager,  Koppers
     Company.
 9.   Edgar,  W.  D.  Coke Oven  Air Emissions Abatement.   Iron  and  Steel
     Engineer., pp. 86  - 94 (October  1972).
10.   Brochure, Sulzer Dry Coke  Cooling, Sulzer Brothers  Limited,
     Winterthur (Switzerland).
                                  22

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GUIDELINE SERIES
          OAQPS NO.  1.2-002
          GUIDANCE FOR WRITING OF

         TRANSPORTATION CONTROL PLANS
                                                 5OC
   VS. ENVIRONMENTAL PROTECTION AGENCY
     Office of Air Quality Planning and Standards
      Research Triangle Park, North Carolina

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                  UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                    Office of Air Quality Planning and Standards
                    Research Triangle Park, North Carolina 27711

 rajECT:    Transportation Controls                             DATE:  March 12,  1973


FROM-.      Ronald A. Vonezia, Chief    ,   /
           Land Use Planning Branch  A m

TO:        Air and Water Program Directors
           Regions I-X

                At the Kansas City regional meeting on February 9, 1973, it was
           indicated that the OAQPS would assist the Regions with guidance in
           the preparation of transportation control plans that must be proposed
           and promulgated by EPA.

                A review of the SIP task schedule sent to you on February 23
           points out the extremely short time period available for the prepara-
           tion of EPA plans after a decision is made as to whether or not the
           State plan is acceptable.  To fully think out, prepare, review, and
           announce on June 15 an EPA plan proposal with only one month lead
           time is very difficult.  To assure adequate preparation and review of
           EPA proposed plans, the following is recommended.

                The regional offices should prepare a contingency EPA proposal
           for transportation controls in each Region requiring these controls
           to meet NAAQS by 1975.  OAQPS 1.2-002, "Guidance for Writing Transpor-
           tation Plans," is provided to assist the Regions in writing the plans.
           This information should serve only as a guide.  EPA policy on use
           of gasoline rationing and the extent to which states will be required
           to enforce EPA promulgated regulations are not yet finalized.  There-
           fore, to the extent sample regulations imply a particular enforcement
           policy or a preferred strategy, they should be considered preliminary
           until further policy guidance is recommended.

                Included is a list of items that should be included in the pream-
           ble.  It is important that all  these points be covered for the prepara-
           tion of a comprehensive preamble.  Preambles for Regions' proposals
           will be coordinated by the Land Use Planning Branch  for the single
           preamble to cover all EPA plans proposed on June 15.  The Land Use
           Planning Branch is developing an additional listing  of strategies and
           priorities which can be used  in EPA plans, and will  attempt to
           identify preferred strategies that would be most appropriate for EPA
           proposal and promulgation in  each Region.
                                                                         *
                Close attention should be  given to the memorandum "Enforceability
           of Transportation Control Strategies," 3-2-73, Shutler to Regional Air
           and Water Programs Division Directors.  Mr. Graham prepared an excellent
           analysis of the potential for state and/or Federal enforcement.  It is
           intended that the sample plan be modified to suit each particular
           Region using Mr. Graham's work  and the preferred strategies from the
EPA Form 1320-6 (Rev. 6-72)

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Land Use Planning Branch.   This information will  be available
March 20.  At that time the Region should review the proposal,
determine if it suits regional  needs and prepare an  outline of the
"back-up" EPA plan for each AQCR.   This will be held in reserve to
finalize as an EPA proposal if states do not submit an adequate plan.

     Mr. Frick, of OGC, is preparing a document on the basis for ex-
tensions to meet the NAAQS.  It is expected it will be available by
March 20.

     The following policy issue papers are now in preparation by the
Land Use Planning Branch for consideration by the Administrator.
These issues will become an integral part of EPA policy to achieve
transportation controls.

     1.  Should an EPA promulgated plan make maximum use of
         gasoline rationing?  How much rationing can be
         effected without severe community impact?

     2.  Should EPA write regulations to force the states to
         act or should EPA act directly?

     It  is anticipated that we will be able to discuss these issues
in  some  depth at the March 20 meeting.  A decision will be reached
as  soon  as possible.

     An  evaluation report must be prepared for transportation and or
land use plans that are received from the States.  The Land Use
Planning Branch has prepared a checklist (OAQPS 1.2-003) which can be
used in  the evaluation of  the plans and serve as the basis of writing
the evaluation report.  A copy of this report should be sent to the
Land Use Planning Branch no later than May 15, 1973.

     For your  review of the State plans, your attention is called to
the following  references:

     1.  "Requirements for Preparation, Adoption and Submittal  of
         Implementation Plans."   (36  FR 15486) August  14, 1971.

     2.  "Criteria for Review of Transportation Control Measures."
         OD/OAQPS January  30, 1973.

     3.  "Proposed Transportation Control Measures."   (38 FR 1464)
         January  12,  1973.

     If you  have  further  questions  on  transportation  controls,  please
contact the  Land  Use  Planning  Branch  (919)  688-8291 or 8270.

Attachments
OAQPS  1.2-002
OAQPS  1.2-003

 cc: Transportation  representatives

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•                                                                   March 12, 1973

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£                                  OAQPS NO. 1.2-002

•                              Guidance for Writing of
                              Transportation Control Plans

                This appendix includes the following sections:
I
           I.  Items to be Included in the Preamble
•        II.  Suggested Wording for Opening of Preamble
         III.  Sample Wording for Possible Regulations
•        IV.  Current Studies and Guidelines Applicable to Plan Preparation
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•                       I.  Items to be included in Preamble

•              The preamble to the control regulations should contain the following
im         items:
                1.  Percent pollutant reduction required:  a statement as to the
I                  percent reduction required of oxidants or carbon monoxide
                    to meet the national primary ambient air quality standard
I                  by May 31, 1975.
a              2.  Background:  a brief description of the history and  legislation
                    leading to the requirement for EPA to promulgate a control  plan,
I                   (See  Section II).   Also a description of the  topography  and
                    meteorology of the  region in question and a statement describing
|                  the reason  (health  basis) for the NAAWS.  Describe the base air
M                  quality data and  compare it with the national standards.
                3.  Transportation and/or  land use control alternates:   describe the
I                  control strategies  available for the region in question  such
                    as  (a)  stationary source controls  (restrictions on organic  solvent
|                  use,  gasoline vapor recovery systems for service  stations,  a
•                  change in  the  substance used for degreasing operations,  and a
                    vapor recovery system  that prevents  evaporation of  solvents from
•                   dry  cleaning  operations;)  (b) hardware  type mobile  source controls
                     (inspection and maintenance, retrofit  and  fuel conversion,
•                   evaporative controls to  prevent  evaporation  of gasoline during
•                   the  filling of the gas tank;  (c)  reduction of vehicle miles
                     traveled  (increased use  of  mass  transit,  increased  car pooling,
I                   gasoline  rationing, increasing cost of motor vehicle use,  limiting
                     the number of automobiles registered,  land use controls or a
'                   combination of these.) I

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                                 2

     4.  The specific transportation and/or land use control strategy

         proposed to meet NAAQS by May 31, 1975.

     5.  Include a table summarizing the effect of each element of the

         proposed strategy as is shown on page 2196 of the January 22,

         1973 proposed plan for Los Angeles, 38 FR (2194).


For the following items see the January 22, 1973 Federal Register:


     6.  Discuss legal and administrative procedures to implement the

         plan.

     7.  Include compliance schedules.

     8.  Discuss surveillance and monitoring procedures.

     9.  Economic and social impact of the  (name of Region)  transportation

         and/or land use plan.

    10.  Direct costs to the public.

    11.  Effect on the economic fabric of the community.

    12.  Tax revenue implications.
                f
    13.  Summary of impacts.

    14.  EPA efforts to mitigate the effects of proposed regulations

    15.  The need for mass transit  (if applicable).

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1

                      II.   Suggested Wording  for Opening of Preamble

                             ENVIRONMENTAL PROTECTION AGENCY
 •                                  [40 CFR Part  52]
                    Approval and Promulgation of  Implementation Plans
 •                          Notice of  Proposed Rule Making

 I
                On May 31,  1972 (37 FR 10842), pursuant to section 110 of the Clean
 |         Air Act and 40 CFR Part 51, the Administrator approved, with specific
 •         exceptions, State plans for implementation of the  national  ambient air
           quality standards.  On this date,  the  Governor  of  	
 •         was advised that in order to complete  the  requirements of  § 51.11 (b)
           and 51.14,  a transportation and/or land use control strategy was to be
 |         submitted to the Administrator by  February 15,  1973.
                On January 31, 1973,  the United States Court  of Appeals for the
           District of Columbia Circuit found that the Administrator  did not conform
 •         to the strict requirements  of the  Clean Air Act of 1970 in permitting
           several states to delay submission of  transportation control portions
 I         of their implementation plans until February 15, 1973, and in granting
 m         extensions  until mid-1977 for attainment of the national primary ambient
           air standard without following the procedures established  in Section
 I         110 (3) 42  V.S.C. § 1857 c-5 (e).   Accordingly  the court ordered that the
           Administrator rescind the extension granted the states for implementation
 •         of the transportation and/or land  use  control portion of their imple-
 •         mentation plans.  The affected states  were required to submit a control plan
           by April 15, 1973.  The plan was to show attainment of the national ambient
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air quality standards for oxidant and/or carbon monoxide as expeditiously
as possible but no later than May 31, 1975.
     On this day the Administrator approved, with specific exceptions,
transportation and/or land use control plans submitted in response to
the January 31, 1973 court order.  This proposal results from the failure
of the State of 	 to submit an acceptable control
plan for the attainment and maintenance of the national primary ambient
air quality standard for oxidants and/or carbon monoxide.

            III.   Sample  Wording for  Possible  Regulations

       The  following sample  regulations  should be modified  to  fit  the AQCR
  in question.   This also induces  the paragraph numbering  system.  Example
  regulations  follow the  format  shown in (38 FR 2194)  dated January 22,  1973.
       a.   The preferred  approach to  be  used by EPA in promulgating regula-
           tions such as  those on gasoline rationing (Section  II  f) have not
           been finalized.   Therefore these regulations and the strategy
           implied by their  use  may be revised as EPA policy on preferred
           strategies arid enforcement are further developed.
       b.   Subpart  (name of state)
           Section  	 is  amended by adding paragraphs	
           through 	, as follows:  § 52 	 control strategy and
           regulations:   Photochemical oxidants and/or carbon  monoxide,
           	 AQCR.

           Regulation for control of  evaporative emissions.
       (1)  For purposes of this paragraph:
       (i)   "Evaporative control  device" means a  device installed on a
             motor vehicle  to prevent the escape of gasoline  vapor from
             the gasoline tank  and carburetor.

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™              (ii)  "Registered" as applied to a motor vehicle, means that such
•                    motor vehicle,                               is duly licensed
                      for general operation on public roads or highways by the
|                    appropriate agency of the Federal Government or by the State.
^              (2)   This regulation is applicable in those portions of 	
                      Counties contained within the Metropolitan	
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                      Air Quality Control Region (AQCR) in the State of
                      The  requirement  of  this  regulation  shall be  effective

                      commencing  up  to _        •
_                (3)   Prior  to     (date)  _ ,  an  evaporative  control  device of at

                       least  85  percent  efficiency which  is  approved by the
I                     Administrator shall be properly installed,  in good working
                       order,  and in operation  on  all registered light-duty
|                     gasoline-powered  vehicles of model years 1966 through 1969

m                     and all registered  heavy-duty gasoline  vehicles of model

                       years  1966 through  1972.  Approved evaporative  control
•            -         devices shall be  installed  on a schedule determined by the

                       Administrator.
•               (4)    After     (date)     ,  the following shall apply  in the areas
•                     specified in paragraph (b)  (2), of this section:
                       (i) The State of _ shall  not register light-duty
•                         vehicles which do not  comply with  the provisions of
                           paragraph (b)  (3) of this section.
•                     (ii)  No owner of light-duty vehicles shall operate or allow

•                           the operation of such vehicles which do not comply with

                             the provisions  of  paragraph (b) (3) of this section.

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c.  Regulation for gaseous fuel conversion.




    (1)   For  purposes  of  this  paragraph:




    (i)    "Fleet  vehicle" means any  one of  ten (10)  or more light-and




          heavy-duty vehicles  operated by the same person (s)  or




          business and used  principally in connection with the same




          occupation or related occupations.




    (ii)   "Gaseous fuel"  means liquified  or pressurized petroleum




          or  natural gaseo which are used as  fuel  for light-duty




          vehicles.



    (2)    This regulation is applicable in  those portions of 	
          Counties contained within the Metropolitan 	 Air




          Quality Control Region (AQCR) in the State of	,




          The requirements of this regulation shall be effective




          commencing on   (date) .




    (3)    All registered gasoline-powered fleet vehicles of model years




          prior to 1975 shall be equipped for and operated on gaseous




          fuel by the effective date of this regulation.  Conversion of




          such fleet vehicles for use of gaseous fuel  shall be on a




          schedule determined by the Administrator.




    (A)    After   (date)    , the following shall apply in the areas




          specified in paragraph  (c) (2) of this section:




          (i)  The State of 	 shall not register vehicles




               which do not comply with the provisions of paragraph




               (b) (3) of this section.

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 |                      (ii)   No owner of fleet vehicles shall operate or allow the



 _       '                     operation of such vehicles which do not comply with the




                              provisions of paragraph (c) (3)  of this section.




 I         d.      Regulation for yearly inspection and maintenance.




                  (1)   For purposes of this paragraph:



 |                     "Inspection and maintenance" means a program to reduce



 •I                     emissions from in-use vehicles through identifying vehicles



                       that need emissions control related maintenance and requiring




 •                     that maintenance be performed.



                  (2)   This regulation is applicable in those sections of 	




 •                     Counties contained within the 	Air Quality




 •                     Control Region (AQCR) in the State of 	.  The



                       requirements of this regulation shall be effective commencing




 •                     °n   (date)



                  (3)   All registered gasoline-powered light- and heavy  duty vehicles




 •                     shall be inspected annually for emissions and, as necessary,



 •                     maintained by the owner in order to pass the inspection.  This



                       shall be done by personnel, facilities and procedures which shall




 •                     be proposed and promulgated by the Administrator.



                  (4)   After    (date)    , the following shall apply in the areas



 ^                     specified in paragraph (d) (2) of this section:



 •                     (i)   The State of 	 shall not register light-duty



                             vehicles which do not comply with the provisions of



 •                           paragraph (d) (3) of this section and procedures promul-



                             gated pursuant thereto.



™                     (ii)  No owner of light-duty vehicles shall operate or allow



•                           the operation of such vehicles which do not comply with



                             the provisions of paragraph (d) (3) of this section.




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                                   8





       Regulation  for oxidizing catalyst.




       (1) For purposes of this paragraph:




           "Oxidizing catalyst" means a device installed  in  the  exhaust




           system  of the vehicle that utilizes a  catalyst and, if




           necessary, an air pump  to reduce emissions of  hydrocarbons  and




           carbon  monoxide from that vehicle.




       (2)  This regulation is applicable in  those sections  of 	
            Counties contained within the 	AQCR  in  the  state




            of 	.  The requirements  of  this regulation  shall




            be effective  commencing on   (date)	.




        (3)  All registered gasoline-powered light- and heavy   duty motor




            vshicles of model years 1966 through 1974, shall be equipped




            with an appropriate oxidizing catalyst exhaust  retrofit in




            accordance with paragraph (e) (2)  of this section, approved




            by the Administrator.




        (4)  After,	, the following shall apply.in the areas




            specified in paragraph (e)  (2)  of this section:




            (i)   The State of 	 shall not register light-




                  duty vehicles  which do not comply with the provisions




                  of paragraph (e)  (3)  of this section.




            (ii)   No owner of light-duty vehicles shall operate or allow




                  the operation  of such vehicles which do not comply with




                  the provisions of paragraph (e)  (3) of this section.




f.      Regulation for purchase of gasoline.




       (1)  For purposes  of this paragraph:




       (i)  "Control period"  means a portion of a calendar year in which




            gasoline sales are regulated.

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                  (11) "Retail outlet" means any service station, filling station,


                       garage, store or other place of business at which gasoline


<•                     is transferred directly to consumers in the regular course


|                       of business.


'•                (2)  This regulation is applicable in those portions of 	
|_                     Counties contained within the 	Air Quality Control


'•                     Region (AQCR) in the State of 	.  The


 •                     requirements of this regulation shall be in effect commencing

j ^*
                         (date)    and shall remain in effect through    (date)


                       The regulation shall be effective in the same control periods


,_                     during each calendar year thereafter, until such time as the


                       Administrator determines the regulation to be no longer


:•                     necessary for the attainment and maintenance of the national


                       standard for photochemical oxidants (hydrocarbons and/or


i |                     carbon monoxide.)


:•                (3)  During the control periods, as specified in paragraph (f)


                       (2) of this sections the sale of gasoline to retail outlets


 •                     and to the owners and operators of motor vehicles shall be


S                       controlled by directions of the Administrator, EPA.


.I               (4)  The amount of gasoline to be controlled shall be determined
/

1•                    by the Administrator no later than 30 days prior to the


                       effective date of a control period.  This determination shall


 •                    be based on the hydrocarbon emission reduction required for


                       the attainment and maintenance of the national standard for


 •                    photochemical oxidants and/or carbon monoxide in the AQCR.




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                                 10






g.     Volatile organic compound loading facilities.




       (1)  This regulation is applicable in those portions of




                          Counties contained within the
            Air Quality Control Region (AQCR) in the State of




            	.   The requirement of paragraph (g) (2) of




            this section shall be effective commencing 	
       (2)  No person shall load or allow the loading of volatile organic




            compounds having a vapor pressure of 1.5 pounds per square




            inch absolute or greater, under actual storage conditions,




            into any tank truck or trailer, railroad tank car, loco:mctive,




            aircraft, stationary storage tank with a capacity greater




            than 5 gallons from any loading facility unless such tank or




            loading facility is equipped with a vapor collection and




            disposal system, or its equivalent, properly installed, in




            good working order, and in operation.  Loading shall be




            accomplished in such a manner that all displaced vapor and air




            will be vented only to the vapor disposal system.  A. means



            shall be provided to prevent liquid organic compound drainage




            from the loading device when it is removed from the hatch, or




            to accomplish complete drainage before such removal.  The




            vapor disposal portion of the system shall consist of one




            of the following:




            (i)   An absorber system or condensation system with a minimum




                  recovery efficiency of 90 percent by weight of all the




                  volatile organic compound vapors and gases entering such




                  disposal system.

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 I
11
 •                 (11)  A vapor handling  system which directs all  vapors  to  a


                         fuel gas  system.

                                                               I'
                    (111) Other  equipment of  at  least  90 percent  efficiency,


 •                      provided  plans for  such equipment  are submitted to and


                         approved  by  the Air Pollution Control Officer.


 •                 Intermediate storage vessels may be used prior to disposal


                    of  vapors under paragraph (g)  (2)  (1) , (ii) , or  (ill) ,


 •                 provided they are  so designed as to prevent release of


 •                 vapors at any time during use.


               (3)   Notwithstanding paragraph (g)  (2)  of  this section,  no person


 •                 loading or allowing the loading of the above  specified


                    compounds in the above. specified storage vessels from the


 I                 above specified loading facilities, any  of which were in


 V                 existence on the effective date of this  regulation,  or  in


                    the procers  of  being installed  for use on said effective date,


 •                 shall be subject to the provisions of paragraph  (g)  (2)

                    of  this section until      (date)     .  Provided  however,


 Jj                  that such person is hereby required to file on or before


 _                   (date)     a  compliance schedule with  the Administrator


                    showing how  the person  will  bring  this operation into


 I                  compliance with paragraph (g)  (2)  of  this section on or


                    before    (date)   . Failure to file  such compliance


 |                  schedule or  abide  by its  items shall render  the


m                  prohibition  contained in  paragraph (g)  (2) of this section


                    immediately  applicable  to such  person on _ (date) _ ,


 •                  or  on the date  of  said  person's failure  to abide by said


                    compliance schedule, whichever  is  later.


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                            12
h.   Control of drycleanlng solvent evaporation.




     (1)   For the purposes of this paragraph:




           "Drycleaning operation" means that process by which an




           organic solvent is used in the commercial cleaning of




           garments and other fabric materials.




     (2)   This regulation is applicable in those portions of




           	 Counties contained within the
           Air Quality Control Region (AQCR) in the State of




           	.  The requirements of this regulation shall




           be effective commencing on   (date) .




     (3)   No person shall operate a drycleaning operation unless the




           uncontrolled organic emissions from such operation have




           been reduced at least 85 percent.



      (4)  Drycleaning operations emitting less than three (3) pounds




           per hour and less than 15 pounds per day are exempt from




           this regulation.




      (5)  If incineration is used as a control technique, 90 percent




           or more of the carbon in the organic compounds being




           incinerated must be oxidized to carbon dioxide.




 i.   Decreasing operations.




      (1)  For the purpose of this paragraph:




           "Degreasing" means the operation of using an organic solvent




           as a surface cleaning agent prior  to fabricating,  surface




           coating, electroplating or any other process.

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                                           13
I

*              (2)  This regulation is applicable in those portions of 	
I                   Counties contained within the 	 Air Quality
                     Control Region (AQCR) in the State of 	
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|                   The requirements of this regulation shall be effective

_                   commencing on   (date)  .

                (3)  No person shall use trichloroethylene (TCE) degreaser as a

•                   degreasing solvent.

           j.   Organic Solvent Usage.

|              Contact the Land Use Planning Branch for additional information

«              on this subject.  Work is currently being done to revise

                Appendix "B" of the August 14, 1971, Federal Register.  36 F.R.

•              (15486.)


            IV.   Current Studies and Guidelines Applicable to Plan Preparations
          The EPA has published the  following  studies  and  guidelines:
                a.  "Prediction of the Effects of Transportation  Controls  on Air

•                  Quality in Major Metropolitan Areas"  and "Evaluating Controls

                    to Reduce Motor Vehicle Emissions in  Major Metropolitan Areas,"

|                  November 1972.  Both of these documents are generally  known as

«                  the "Six Cities Study."

                b.  "Transportation Controls to Reduce Motor Vehicle Emissions in

•        .          Major Metropolitan Areas," December,  1972.  This document is a

                    summary of 14 cities that were studied with the view of

•                  recommending specific transportation  control  strategies.

•                  Separate reports for each of the 14 cities will also be

                    available alo.ig with the Six Cities Study and  the document

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                           14



    listed in b above from the Office of Technical Information and




    Publications, Research Triangle Park, North Carolina 27711.




c.  "Control Strategies for In-Use Vehicles," November, 1972.  This




    report is available from EPA, Mobile Source Pollution Control




    Programs, 401 M St.S.W., Washington, D.C. 20460.




d.  "Proposed Transportation Control Plans," Federal Register




    (38 FR 1464) January 12, 1973.




e.  "An Air Pollution Impact Methodology for Airports and




    Attendant Land Use," dated January, 1973.  Copies available




    from Land Use Planning Branch, EPA, Research Triangle Park,




    North Carolina 2771.1.




f.  "Criteria for a Review of Transportation Control Measures"




    OD/OAQPS Memo, January 30, 1973.




g.  "An Interim Report on Motor Vehicle Emission Estimation" Kircher




    and Armstrong, October, 1972 and available from the Land Use




    Planning Branch, EPA, Research Triangle Park, North Carolina 27711.

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GUIDELINE SERIES
          OAQPS NO.  1.2-003
        CHECKLIST FOR EVALUATION OF

           TRANSPORTATION PLANS
                             DOC
   US. ENVIRONMENTAL PROTECTION AGENCY
     Office of Air Quality Planning and Standards


      Research Triangle Park, North Carolina

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                  UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                    Office of Air Quality Planning and Standards
                    Research Triangle Park, North Carolina 27711
SUBJECT:   Transportation Controls
DATE:  March 12,  1973
FROM:      Ronald A. Venezia, Chief   .->  .,
           Land Use Planning Branch   *•  l

TO:        Air and Water Program Directors
           Regions I-X

                At the Kansas City regional meeting on February 9, 1973, it was
           indicated that the OAQPS would assist the Regions with guidance in
           the preparation of transportation control plans that must be proposed
           and promulgated by EPA.

                A review of the SIP task schedule sent to you on February 23
           points out the extremely short time period available for the prepara-
           tion of EPA plans after a  decision is made as to whether or not the
           State plan is acceptable.  To fully think out, prepare, review, and
           announce on June 15 an EPA plan proposal with only one month lead
           time is very difficult.  To assure adequate preparation and review of
           EPA proposed plans, the following is recommended.

                The regional offices  should prepare a contingency EPA proposal
           for transportation controls in each Region requiring these controls
           to meet NAAQS by 1975.  OAQPS 1.2-002, "Guidance for Writing Transpor-
           tation Plans," is provided to assist the Regions in writing the plans.
           This information should serve only as a guide.  EPA policy on use
           of gasoline rationing and  the extent to which states will be required
           to enforce EPA promulgated regulations are not yet finalized.  There-
           fore, to the extent sample regulations imply a particular enforcement
           policy or a preferred strategy, they should be considered preliminary
           until further policy guidance is recommended.

                Included is a list of items that should be included in the pream-
           ble.  It is important that all these points be covered for the prepara-
           tion of a comprehensive preamble.  Preambles for Regions' proposals
           will be coordinated by the Land Use Planning Branch for the single
           preamble to cover all EPA  plans proposed on June 15.  The Land Use
           Planning Branch is developing an additional listing of strategies and
           priorities which can be used in EPA plans, and will attempt to
           identify preferred strategies that would be most appropriate for EPA
           proposal and promulgation  in each Region.

                Close attention should be given to the memorandum "Enforceability
           of Transportation Control  Strategies," 3-2-73, Shutler to Regional Air
           and Water Programs Division Directors.  Mr. Graham prepared an excellent
           analysis of the potential  for state and/or Federal enforcement.  It is
           intended that the sample plan be modified to suit each particular
           Region using Mr. Graham's  work and the preferred strategies from the
 EPA Form 1320-6 (Rev. 6-72)
 I

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Land Use Planning Branch.   This information will  be available
March 20.  At that time the Region should review the proposal,
determine if it suits regional  needs and prepare an  outline of the
"back-up" EPA plan for each AQCR.   This will be held in reserve to
finalize as an EPA proposal if states do not submit an adequate plan.

     Mr. Frick, of OGC, is preparing a document on the basis for ex-
tensions to meet the NAAQS.  It is expected it will be available by
March 20.

     The following policy issue papers are now in preparation by the
Land Use Planning Branch for consideration by the Administrator.
These issues will become an integral part of EPA policy to achieve
transportation controls.

     1.  Should an EPA promulgated plan make maximum use of
         gasoline rationing?  How much rationing can be
         effected without severe community  impact?

     2.  Should EPA write regulations to force the states to
         act or should EPA act directly?

     It  is anticipated that we will be able to discuss these  issues
in some  depth at the March 20 meeting.  A decision will be reached
as soon  as possible.

     An  evaluation report must be prepared  for transportation and or
land use plans that are received from the States.  The Land Use
Planning Branch has prepared a checklist (OAQPS 1.2-003) which can be
used in  the evaluation of the plans and serve as the basis of writing
the evaluation report.  A copy of this report should be sent  to the
Land Use Planning Branch no later than May  15, 1973.

     For your review of the S.tate plans, your attention is called to
the following references:

     1.  "Requirements for Preparation, Adoption and Submittal of
         Implementation Plans."  (36 FR 15486) August  14, 1971.

     2.  "Criteria for Review of Transportation Control Measures."
         OD/OAQPS January 30, 1973.

     3.  "Proposed Transportation Control Measures."   (38 FR  1464)
         January 12,  1973.

     If you have further questions  on  transportation  controls,  please
contact the Land Use  Planning Branch  (919)  688-8291 or 8270.

Attachments
OAQPS  1.2-002
OAQPS  1.2-003

cc:  Transportation  representatives

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•                                    OAQPS NO.   1.2-003
-                                CHECKLIST FOR  EVALUATION OF
'                                    TRANSPORTATION  PLANS
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                                         March 12,  1973
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                                                                   3/12/7J
                        APPENDIX B
            Checklist for Evaluation of Plans

                       INTRODUCTION

     The following check list for use in review of State Air
Quality Implementation Plans was compiled and edited from infor-
mation available from the following sources:
     Federal Register, Volume 36, Number 228 (11/25/71)
     Sierra Club v. Ruckelshaus, U.S. District Court, D.C.,
     Number 1031-72 (6/2/72)
     Federal Register, Volume 38, Number 8  (1/12/73)
     Natural Resources Defense Council, Inc., et al. v.
     Environmental Protection Agency, U.S. Ct. Appeals, D.C.,
     Number 1522-72, et al. (1/31/73)
«                    Federal  Register,  Volume  38,  Number  21 (2/1/73)
                      The check list  retains  the  Code of Federal Regulations
article numbering system and part and subpart headings.  Where
reference is made within a check list item to appendices or
articles not presented in the check list that inforamtion will
be found in the November 25, 1971, Federal Register unless
noted otherwise.

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Subpart B - Plan Content and
Requirements
§ 51.10 General requirements.
(b) Each plan implementing a pri-
mary standard shall provide for the
attainment of such standard as ex-
peditiously as practicable, but in no
case, except as otherwise provided by
Gv.bpnrt C of this part, later than
May 31, 1975. The projected date of
attainment of such standard shall be
specified in the plan.
(c) Each plan implementing a sec-
ondary standard shall provide for the
attainment of such standard by a speci-
fied date, which shall be within a rea-
sonable time after the date of the
Administrator's approval of such plan.
(d) The plan for each region shall
have adequate provisions to insure that
pollutant emissions within such region
will not interfere with attainment and
maintenance of any national standard
in any portion of an interstate region
or in any other region
(e) Each plan shall provide for pub-
lac availability of emission date re-
ported by source owners or operators or
otherwise obtained by a State or local
agency. Such emission data shall be
correlated with applicable emission
limitations or other measures. As
used in this paragraph, "correlated"
means presented in such a manner as to
show the relationship between measured
or estimated amounts of emissions and
the amounts of such emissions allow-
able under the applicable emission
limitations or other measures.

Not
Applicable






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Covered in
Transportation Plan






Missing






2
Remarks

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§ 51.11 Legal authority.
(a) Each plan shall show that the
State has legal authority to carry out
the plan, including authority to:
(1) Adopt emission standards and
limitations and any other measures
necessary for attainment and main-
tenance of national standards.
(2) Enforce applicable laws, regu-
lations, and standards, and seek
injunctive relief.
(3) Abate pollutant emissions on
an emergency basis to prevent sub-
stantial endangerment to the health
of persons, i.e., authority compare-
able to that available to the Admin-
istrator under section 303 of the Act.
(4) Prevent construction, modifica-
tion, or operation of any stationary
source at any location where emissions
from such source will prevent the
attainment or maintenance of a national
standard.
(5) Obtain information necessary to
determine whether air pollution sources
are in compliance with applicable laws,
regulations, and standards, including
authority to require recordkeeping and
to make inspections and conduct tests
of air pollution sources.
(6) Require owners or operators of
stationary sources to install, main-
tain, and use emission monitoring
devices and to make periodic reports
to the State on the nature and amounts
of emissions from such stationary
sources; also authority for the State
to make such data available to the
public as reported and as correlated
with any applicable emission standards
or limitations.

Not
Applicable








Covered in
Original Plan








Covered in
Transportation Pis








Missing








3
Remarks

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(b) Where a plan sets forth a control
strategy that provides for application
of (1) inspection and testing of motor
vehicles and/or other transportation
control measures or (2) land use
measures other than those referred to
in § 51.11 (a) (4), such plan shall set
forth the State's timetable for obtain-
ing such legal authority as may be
necessary to carry out such measures.
(c) The provisions of law or regula-
tion which the State determines provide
the authorities required under the sec-
tion shall be specifically identified,
and copies of such laws or regulations
shall be submitted with the plan.
(d) (1) Except as otherwise provided
by paragraph (b) of this section, the
plan shall show that the legal authori-
ties specified in this section are
available to the State at the time of
submission of the plan.
(2) Legal authority adequate to
fulfill the requirements of paragraph
(a) (5) and (6) of this 'section may be
delegated to the State pursuant to
section 114 of the Act.
(e) A State governmental agency other
than the State air pollution control
agency may be assigned responsibility for
carrying out a portion of a plan: Pro-
vided, That such plan demonstrates, to
the Administrator's satisfaction, that
such State governmental agency has the
legal authority necessary to carry out
such portion of the plan or, pursuant
to paragraph (b) of this section, has a
timetable for obtaining such authority.
(f) The State may authorize a local
agency to carry out a plan, or portion
thereof, within such local agency's
jurisdiction: Provided, That such plan
demonstrates, to the Administrator's
satisfaction, that such local agency has
the legal authority necessary to implement
such plan, or portion thereof, and further:
Not Applicable






Covered in
Original Plan






Covered in
Transportation Plan






Missing






4
Remarks

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Provided, That such auth'
not relieve the State of
under the Act for carryL
or portion thereof.

§ 51.12 Control strategy
  (a)  In any region wlv
(measured or estimated)
of a pollutant exceed tb
by an applicable nation
plan shall set forth a
which shall provide I
emission reduction necu.
ment and maintenance of
standard, including the
sion reduction necessar-
sion increased that can
expected to result from
of population, industri,
vehicle traffic, or oth,
cause or contribute to  '<
  (b)  In any region w.i
estimated ambient level:
are below the levels sp.
plicable secondary star
shall set forth a contr
shall be adequate to pi
pollution levels from I
deteriorated.

  (d)  For purposes of
trol strategy, data del-
men ts of existing ambJc
pollutant may be adjust
extent to which occasic.
accidental phenomena, <
forest fires, industri.
demonstrably affected
levels during the measu















,hall
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Remarks

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§ 51.14 Control strategy: Carbon mon-
oxide, hydrocarbons, photo-
chemical oxidants, and nitrogen
dioxide.
(a) Priority I Regions. (1) Each plan
f c r a region classified Priority I with
respect to carbon monoxide, photochemical
oxidants, or nitrogen dioxide shall set
forth a control strategy which shall
provide for the degree of emission reduc-
tion necessary for attainment and main-
tenance of the national standard for each
such pollutant after consideration of the
emission reductions that will result from
the application of Federal motor vehicle
emission standards promulgated pursuant
to section 202 of the Act.
(2) Unless specific data are available
for a region, a State shall assume that
such Federal motor vehicle emission
standards will result in the emission
reductions shown in Appendix I to this
part. If specific data are vised, such
data must be submitted in the plan for
such region. (Refer to F.R.)
(3) The plan shall contain:
(i) A description of enforcement
methods including, but not limited to
procedures for monitoring compliance
with the selected traffic control measures,
procedures for handling violations, and a
designation of enforcement responsibili-
ties (j.e., air pollution control agency,
State police.)
(ii) Proposed or adopted rules and
regulations pertaining to the selected
transportation control measures.
(iii) A description of administra-
tive procedures to be used in imple-
menting all selected transportation
control measures.

Not Applicable







Covered in
Original Plan







Covered in
Transportation Plan







Missing







6
Remarks







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(iv) A schedule designating dates by
which legal authority necessary to imple-
ment the plan will be obtained, other
significant steps in the implementation
of the plan will be achieved, and each
control measure will be implemented.
(h) Control strategy development. In
a region in which attainment and main-
tenance of a national standard will
require emission reductions in addition
to those which will result from applica-
tion of the Federal motor vehicle emis-
sion standards, the control strategy
c^'iall provide for application or such
oi:ier meaiujj es as may be necessary for
attainment and maintenance of such
national standard.
(c) Adequacy of control strategy (1)
The plan shall demonstrate, by means of
a proportional model or diffusion/photo
chemical model or other procedure which
is adequate and appropriate, that the
control strategy included in each plan
for a region classified as priority I
is adequate for attainment and mainte-
nance of the national standard (r) to
which such control strategy applies.
Control measures shall not result in an
increase in the concent ration of any
pollutant. The plan shall include
provisions as necessary to prevent such
increases in concentrations as a result
of traffic increases that may be stim-
ulated by transportation control
measures.
(2) With respect to control of
carbon monoxide and nitrogen oxides, the
proportional model which may be used
for purposes of this paragraph is described
in § 51.13 (e) (2): Provided, With
respect to the national standard for
nitrogen dioxide, that the degree of air
quality improvement indicated to be
necessary by the proportional model will
be achieved by a corresponding degree of
reduction of total nitrogen oxides
emissions from stationary and mobile
sources. (Refer to F.R.)

Not Applicable





Covered in
Original Plan





Covered in
Transportation PI;





Missing





7
Remarks

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(3) In any region where the degree
of nitrogen oxides emission reduction
necessary for attainment and mainte-
nance of the national standard for
nitrogen dioxide is greater than that
which can be achieved by the applica-
tion of (i) the Federal motor vehicle
^mission standards promulgated under
section 202 of the Act, (ii) reason-
ably available control technology to
nitrogen oxides sources, and (iii) any
transportation control measures which
may be necessary for attainment and
maintenance of the national standards
for carbon monoxide and photochemical
oxidants, the plan shall provide for
the degree of hydrocarbon emission
reduction attainable through the appli-
cation of reasonably available control
technology. In any such region, a
control strategy which provides for
such hydrocarbon emission reduction
shall be deemed adequate for attain-
ment of the national standard for
nitrogen dioxide.
(4) With respect to hydrocarbons and
photochemical oxidants, it may be assumed
that (i) there is no background concen-
tration of photochemical oxidants and
(ii) the degree of total hydrocarbon
emission reduction necessary for attain-
ment and maintenance of the national
standard for photochemical oxidants will
also be adequate for attainment of the
national standard for hydrocarbons. The
proportional model to be used to deter-
mine the necessary hydrocarbon emission
reduction is set forth in Appendix J to
this part. (Refer to F.R.)



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Remarks









































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(5) The plan shall show that the con-
trol strategy including transportation
control measures will result in the degree
of emissions reduction indicated to be
necessary by a proportional model, diffu-
sion model , or other procedure which is
adequate and appropriate. The plan shall
contain a .'•ummary of the computations,
assumptions, and judgments used to deter-
nii-v.- the i;,.-.riions reductions that will
iesu.lt fro;:1 application of the control
strategy to each point source, and each
group of area sources. Su>-h summary shall
In-- inrlu'l'd i"i a table similar to that
• • .,. .; \up i x '"> L . 'Vis part. The
(> ' an ai.;.o t.i.all Contain a summary oi the
data, computations, assumptions, and
judgments used to develop any transporta-
tion control measures that are a part of
the control strategy. Such a summary
shall as a minimum contain the material
described in Appendix M to this part. The
detailed computations and data shall be
retained by the State and made available
for inspection by the Administrator at his
request. (Refer tr F.R. F. 36, No. 228
and F.R. V. 38, No. 8.)
(6) If a diffusion/photochemical model is
used, the plan shall include a description
of such model.
(d) Emission data. Emission data on
carbon monoxide, hydrocarbons, and ni-
trogen oxides shall be submitted in
accordance with the requirements of
§ 51.13 (f). (Refer to F.R.)
(a', Air 4jaiity data. Data showing
existing air quality levels shall be
presented in accordance with this
section:
(1) For Priority I regions, data on
carbon monoxide, nitrogen dioxide, and
photochemical oxidants shall, as a mini-
mum, include the results of measurements
made during a period of approximately
3 months in accordance with the
following procedures.

Not Applicable






Covered in
Original Plan






Covered in
Transportation






Missing






Remarks

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(2) For Priority I regions, only avail-
able air quality data for hydrocarbons
must be submitted.
(4) Air quality data required by this
subparagraph shall be submitted in the
form similar to that shown in Appendix
H to this part. (Refer to F.R.)
(f) Motor vehicle emission factors.
The States required to submit .transpor-
tation control plans must, except as
noted below, use current emission factors
and methodology to calculate emissions
from gasoline powered motor vehicles.
The current emission factors and method-
ology are presented in "Compilation of
Air Pollutant Emission Factors," EPA
report No. AP-42, revised semiannually,
and in superseding EPA interim reports.
These are available from the EPA, Office
of Air Quality Planning and Standards,
Research Triangle Park, N.C. 27711. If
emissions other than those presented in
the EPA report are used, the substantiat-
ing justification must be submitted with
the transportation control measures.
(g) Air Quality baseline. The concen-
trations of carbon monoxide and photo-
chemical oxidants set forth in the State
plan as approved and promulgated on
May 31, 1972 (37 FR 10842) (40 CFR
Part 52) may and should be used as the
air quality baselines for computation of
the emissions reductions through trans-
portation control measures required to
meet national standards. More recent air
quality data may be used where adequate
and appropriate. However, such data must
be compatible with the emissions inven-
tory for the region involved and justifi-
cation submitted for the appropriateness
of its use. Revised air quality data
should be submitted to the appropriate EPA
regional office at the earliest possible
date for evaluation and approval to
preclude plan disapproval resulting from
the use of faulty air quality data.

Not Applicable















































Covered in
Original Plan















































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Transportation 1















































plissing j















































10
Remarks















































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