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2.3.15
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GLOSSARY
Allowable Emissions
1
Area Source
1
- Allowable emissions are the maximum
emissions of each pollutant, in tons
per year, that the source isallowod to
discharge into the atmospnere uncter tha
most stringent legal conditions
applicable.
- The area source encompass.es human acti-
vity in areas which result in pollution
yet are not covered by the point sources.
An area source 1s a collection of indus-
trial, commercial, mobile, and residential
sources which individually may emit on
small quantities of pollutants but
taken collectively may have a siqni-
ficant impact.
- The calculated emissions are the emission
estimates arrived at using the erussic.,'
factors and activity level for the source.
For estimating methods, 0,1,2, ind 5, the
estimated emissions are transferred to the
calculated emissions. For multi; ' S^'s
a proportioning technique is used and r
single SCC's the values are transferred a,
entered. For estimation methods 3 and 4,
the calculated emissions are computed using
EPA emission factors and the operating rates.
For any SCC for which there is no emission
factor or for which the operating
rate is unknown, a zero
Guide for Compiling a Comprehensive Emission Inventory (APTD-1135)
3.0.1
Calculated Emissions
1
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Emission Estimates
1
Emission Factor
Estimating Method
1
Point Source
1
is entered.
- The emission estimates are the values
for emissions entered on the sourco form.
The estimates may be arrived at by various
methods listed below in Estimating methods.
- The emission factor is a quantitative
estimate of the average rate at which a
pollutant is released to the atmosphere as
a result of some industrial activity,
divided by the level of that activity.
- The method of estimating emissions has
been defined to be in the following
categories:
0 - not applicable
1 - stack - test results or other
emission measurements,
2 - material balance using engineer-
ing knowledge and expertise
of process,
3 - emissions calculated using EPA
emission factors,
4 - guess, and
5 - emissions calculated using a special
emission factor that differs
from the official EPA factor.
- According to the August 14, 1971 Federal
Register, a point source is (a) any
stationary source causing emissions in
excess of JQO tons per year of any pollu-
tant for which there 1s a National
Standard in a region
See Guide for Compiling A Comprehensive Emission Inventory (AHTD-1135)
3.0.2
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• x~" containing an area whose 1970 "urban
place" population, as defined by the
• U.S. Bureau of Census, was equal to
or greater than one million, or (b)
| any stationary source causing emissions
• * in excess of 25 tons per year of any
* pollutant for which there is a National
flj " Standard in a region containing an
area whose 1970 "urban place" popula-
• tion, as defined by the U.S. Bureau
of Census, was less than one million,
• or (c) without regard to quantity, a
m source as listed in Table 1, page 27
•—• [of the August 14 Federal Register],
I or (d) the sources included 1n a com-
prehensive permit or registration ?vs-
J tern already maintained by the agency.
If the states submitting data
• wish to establish a more stringent
•j criteria for point sources, this infor-
mation can be submitted to the Natnv, <
I
Emissions Data Bank.
Region - Region refers to an EPA region.
§ NADB - National Air Data Branch.
»* - »
NEDB - National Emissions Data Bank.
• NFDS - National Emissions Data System
i
I'V. •• f-iiij- fo; Conpi I ing /; Coi;iprehensiv2 Ennssiun Inventory (APrD-1135)
^
3.0.3
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- The Source Classification Codes (SCC)
are Indices to a system developed by
EPA to categorize both specific and
general emission-related activities
of potential point sources or air
pollutants. Four levels of identi-
fication are used, each being a pro-
gressive subcategorization of the first
or general level. They relate to fuel
types, industrial processes, equipment
types and size, products, etc. and
are generally sufficiently well defined
to enable the application of specific
emission estimation factors to the
activity level defined. Units to be
used for the activity level are those
associated with the specific SCC. For
»
the actual code definitions, See Guide
For Compiling A Comprehensive Emission
Inventory.
SIC - The Standard Industrial Classification
(SIC) codes, developed and maintained
by the Office of Management arid Budget,
! are indices to an economy-oriented
system for .categorizing industry com-
position and statistics on a comparable
basis. These codes, which arc rcvi'nd
3.0.4
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•
•
as necessary, cover generalized fields
of economic activity and provide? a
uniform mechanism for use in classification
• of establishments or kind-of-activity
units by the type of economic activity
in which engaged. For actual code
— definitions, See Standard Industrial
Classification Manual .
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APPENDIX I
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APPENDIX II
Explanation of Area Sources Listing
The area source listing uses abbreviations for printing items.
These abbreviations are often difficult for tlie average user to decipher
quickly so below 1s a full listing for a source going down each column.
Abbreviation
EM-EST-PRT
EM-EST-CO
% SULF-RESID-OIL
RES-BITUM
RES-WOOD
CI-RID-OIL
IND-BITUM
IND-N-GAS
RES-OS-INC
RES-OP-BRN
GAS-LT-VEH
DIE-HV-VEH
COUNTY-POP
CIV-AIRCRAFT
VES-DIE-OL
EVAP-SOLVENT
VEH-MI-RURL
DIRT-RD-TRV
ROCK-H-ST
Exploded Text
Emission Estimate-Particulate
Emission Estimate-Carbon Monoxide
% Sulfur Content-Residual 011
Residential Fuel-Bituminous Coal
Residential Fuel-Wood
Commercial and Institutional Fuel-
Residual Oil
Industrial Fuel-Bituminous Coal
idustrial Fuel-Natural Gas
Residential-On Site Incineration
Res idenll til-Open Burning
Gasoline Fuel-Light Vehicle
Diesel Fuel-Heavy Vehicle
County Population
Civil Aircraft
Vessels-Diesel Oil
Evaporation-Solvent Purchased
Measured Vehicle Miles-Rural Roads
Dirt Roads Traveled
Rock* RandHng &• Storing
5.0.1
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Abbreviation
SLASH-BKN-ARE
ORCH-DA-FIRED
COAL-REF-BURN
EM-EST-S02
% SUL'F-ANTH-COAL
% ASH-ANTH-COAL
RES-DIS-OIL
CI-ANTH
CI-N-GAS
INO-COKE
IND-WOOD
IND-OS-INC
IND-OPN-BRN
GAS-HVY-VEH
DIE-OFF-HWY
DENSITY-CODE
COMM-AIRCRAFT
VES-RID-OIL
EVAP-GAS
VEH-MI-SUBAN
DIRT-AIR-STRIPS
FOREST-FIRE-AR
SLASH-BN-QU
STRUCTURE-FIRES
Exploded Tpy.t
Slash Burning-Area
Frost Control-Orchard-Days Fired
Coal Refuse Burning
Emission Estimates-Sulfur Dioxide
% Sulfur Content-Anthracite Coal
% Ash Content-Anthracite Coal
Residential Fuel-Distillate Oil
Commercial & Institutional Fuel-
Anthracite Coal
Commercial & Institutional Fuel-
Natural Gas
Industrial Fuel-Coke
Industrial Fuel-Wood
Iridustt ' 0 Site Incineration
industrial Open Burning
Gasoline Fuel-Heavy Vehicle
Diesel Fuel-Off Highway
Density Code
Commercial Aircraft
Vessels-Residual Oil
Evaporation-GasoIine Marketed
Measured Vehicle Miles-Surburban Roads
Dirt Air Strips
Forest Fires Area
Slash Burning-Area
Structure Fires
6.0,2
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Abbreviations
COMMENTS
EM-EST-NOX
% SULF-BITUM-COAL
% ASH- BITUM- COAL
RES-RID-OIL
CI-BITUM
CI-WOOD
IND-DIS-OIL
IND-PR-GAS
CI-OS-INC
CI-OPN-BRN
GAS-OFF-HNY
DIE-RR-LOC
MIL- AIRCRAFT
VES-BITUM *
VES-GAS
VEH-MI-LA-RD
VEH-MI- URBAN
CONST- LAND
FOR-FIRE-QU
ORCHARD- HEATERS
CRB-SIZE-BK
EM-EST-HC
Exploded Text
Comments
Emission Estimates-Nitrogen Oxide
% Sulfur Content-Bituminous Coal
% Ash Content-Bituminous Coal
Residential Fuel-Residual 011
Commercial & Institutional Fuel-
- Bituminous Coal
Commercial & Institutional Fuel-
Mood
Industrial Fuel-Distillate 011
Industrial Fuel-Process Gass
Commercial & Institutional On Site
Indrv-ration
£i.. lal & Institutional Open Burning
Gasoline Fuel-Off Highway
Diesel hue I-Li*, locomotive
Militor> AI,-...«ft
Vessels-Bituminjus
Vessels-Gasoline
Measured Vehicle Miles-Limited Access
Roads
Measured Vehicle Miles-Urban Roads
Construction Land Area
Forest Fires-Quantity
Frost Central-Orchard Heaters
Coal Refuse Barning-Size of Bank
Emission Estimates-Hydrocarbon
5.Q.3
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Abbreviations Exp1pded_Te_xt
RES-N-GAS Residential Fuel-Natural Gas
CI-DIS-OIL Commercial and Institutional Fuel-
Distillate Oil
IND-ANTH Industrial Fuel-Anthracite Coal
IND-RD-OIL Industrial Fuel-Residual Oil
PART-EMS Participate Enissions (Calculated)
S02-CHS . - Sulfur Dioxide Emissions (Calculated)
NOX-EMS Nitrogen'Oxide Emissions (Calculated)
HC-EMS Hydrocarbon Emissions (Calculated)
CO-EfiS Carbon Monoxide Emissions (Calculated)
NO. 6-EMS. Pollutant US Emissions (Calculated)
NO. 7-EHS Pollutant #7 Emissions (Calculated)
NO. 8-EMS Pollutant. , L.ivnons (Calculated)
NO. 9-EMS fr Mutant #9 Emissions f'alcjlated)
NO. 10-EMS Pollutant #lj D.I. ;,:, ion:, (Calculated)
NO. 11-EMS Pollutant #1 , Limssio-.s (Calculated)
NO. 12-EMS Pollutant #12 Emission, (Calculated)
5.0.4
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NEDS Terminal Users Manual
**»
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j GUIDELINE SERIES
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*sl\
OAQPS NO. 3. o-ooi
May 10, 1973
Questions and Answers Concerning the
Implementation of Section 110 of the
Clean Air Act
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US. ENVIRONMENTAL PROTECTION AGENCY
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina
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•; ENVIRONMENTAL PROTECTION AGENCY
™ '' ' ' Office of Air Quality Planning and Standards ' .
Research Triangle Park, North Carolina 27711
• Rtply to
m Aim of: CPDD/RPS Date: ay 10'
• SubJ"t: Implementation of Section 110 of the Clean Air Act
ITo: • Directors, Air & Water Programs Divisions
Regions I-X - j
g . Enclosed for your information and guidance is a memorandum
• of April 30, 1973 from the EPA Office of General Counsel. In
I this memorandum, several key questions relating to implementation
of the Act have been answered. If you have specific questions
I or need further clarification on these issues, please contact
m Michael A. James, Attorney, OEGC in Washington, D.C.
I ' '
• .tttef
Regional Programs Staff
• Enclosure
Ice: Mario Storlazzi
Conrad Simon
Steve Wassersug
ITommie Gibbs
F. Donald Maddox
Norman Thomas
_ Dewayne Durst
• Norm Huey
" David Calkins
Gary Young
I Michael *iaiupc'
• B. J. Steigerwald
OAQPS Div. Directors
• Donald Walters
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ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C. 204GO
OFFICE OF THE GENERAL COUNSEL
Date: April 30, 1973, fffc?\~
Reply to Michael A. James, Attorney
Attn of: Air Quality and Radiation Division
Subject: implementation of Section 110 of the Clean Air Act
To: Joe Padgett, Director
Strategies and Air Standards Division
Office of Air Quality Planning and
'Standards , OAWP
MEMORANDUM OF LAW
FACTS
Your memorandum of February 27, 1973 to Robert Baum
raises several questions involving subjects discussed at
the Regional Administrators' meeting on power plants.
All of the questions are concerned with EPA's overseeing
ot State implementation plans.
QUESTION 31
If a State has an annro/od emission regulation which
is more stringent than ne.. _ssary to attain the national
standards but refuses to enforce its emission regulation
by obtaining compliance schedules fre.n regulated sources,
may EPA reject the State emission regulation and promulgate
a lens restrictive measure that provides for the aut^inment
of ambient air quality standards?
ANSWER #1
Where EPA has approved a State emission regulation as
part of an applicable plan and the State dc .;s not enlorce
the regulation, EPA's responsibility under the Clean Air Act
is to enforce the approved emission limitation am ' i so
doing, the Agency must provide for compliance with t
approved emission limitation.
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DISCUSSION H
It is helpful to begin with a general d.iscus;sion of|
EPA's authority and responsibility under §§110 and 113
of the Act, since most of the questions raise basic problems
of interpretation of those sections. It is important to'
recognize that we are discussing two separate functions,!
viz approval/promulgation and enforcement. j
EPA's authority to promulgate implementation plan regu-
lations sterns from the disapproval of regulations submitted
by the State, or by the failure of the State to submit
necessary regulations. If State regulations are approved
by EPA, the Agency has no authority to promulgate different
regulations. Under the law, EPA must approve regulations
which are more stringent than those needed to meet the
national standards. Once these regulations are approved,
there is no authority to promulgate less stringent regulations.
This is true even if a State fails to enforce these regulations
With regard to the second function raised by the ques-
tions, i.e. enforcement, EPA is given clear authority to
enforce approved implementation pians or plans promulgated
by the Administrator. As we Ivi"^ previously pointed out,
under §110 (d) , for purposes of _ae Clean Air Act ". . .an
applicable implementation plan is the implementation plan,
or most recent revision thereof which has been' approved
under subsection (a) or promulgated under subsection (c) and
which implements a national primary or secondary ambien . air
quality standard in a State." The words "applicable imple-
mentation plan" are in this case, words of art. Section ]13
authorizes Federal enforcement of an "appliccible implementa-
tion plan." Accordingly, it is clear that it is only approved
or promulgated plans which EPA may enforce.
As you know, the submission by a State with regard to
regulations and compliance schedu].es is really two separate
submissions. On one hand, EPA evaluates the emission
limitations to nake certain that they are sufficient to
achieve the national standards. If the degree of reduction
is sufficient, that emission standard is approved. Many
State plans contain provisions by which they are required to
procure a compliance schedule subsequent to the adoption and
submission of the emission standard. Failure to obtain the
compliance schedules in no way affects the validity of the
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approved emission regulation. Accordingly, EPA does not
have authority to promulgate a different emission regu-
lation. What is left to EPA is the authority to procure
compliance schedules which meet the applicable implementa-
tion plan, in this case, the emission limitations submitted
by the State and approved by EPA.
QUESTION fl 2
When imposing Federal compliance schedules or approving
State compliance schedules for sources subject to approved
State emission regulations which arc more stringent than
necessary to attain the national standards, must EPA require
compliance with the approved regulation or may it impose or
approve instead whatever less stringent requirements are
necessary to achieve the national standards?
ANSWER "f
Unless the State revises its ^D:...oveu regulation and
obtains EPA approval of that rev is i <^n . both the State ?.r.d
EPA are bound by the approve^, regulation when obtaining or
approving complin,.-'o schedule;,.
DISCI;
-2
The premise of
State has submitted
str' • r.t than ncc>' :.
ai^ i _ ^al LL/ standa. ,
submits a complian...
can we accept or pi
dare'1 . r. - rr.us t, we d<
State emission ron ,
to the first one- d • ••
contains an enissi-
the preparation an<.
aside from the requi
would p -.t EPA in the
secure a compliance,-
which does not exist
even if it were possible to try
schedules to meet some number It
in the plan, exactly what that i
.it second question is that rhe
nxssion limitations which are more
:ry to aci.' '• . ,.,L.. .i~J an^^o^!
>, ;iOdule i. •:
; i o on._- v,-.". '
i on3 . '.'!..
'it-.it I.,..
yprova 1 :" i
?;:-.:;ntj; 01 ;
:-osi L a on ^ ;
. t, e ci L, 1 e t L >
(-xco \"> L : .:
Vf '
^ i 1 . .
;_}
r i
v;n i c
C0..,p
llu",
•'•; i-
SUCu, t
EPA
to a
c; s s
UuU...
. ' v.' t C '•
J L „ .'Oil
,-,hi •.
. • i. J v.: ; .
•. .ip-)"'
^ * L ; ,
j . a n -., !,'
:i d i f f
. ,.< ing
0)1 v-iUJ
J i 1 « : S .
v i O p t 0 1
: i i ngen
r would
h o c u i • v • n i , ,
; eve the stan-
: jtf the
- .-. si;, lar
• 1 -• • n n
.ml/ :_..iid,-- f
: .-Medu ' ' :'-i
o : c-nt a.
or trying i,
.-.; i un 1 i.in it a ..j
;;ore spcci^ io
p-rccure compl
t than that an
be in each ca
or
ite
on
ally,
iance
prove
se
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- 4 -
would be su)5joct to question and litigation. Wo .should
point-out that if tho State haw in fact adopted emission
limitations which are more stringent than necessary to
meet the national standards, they can submit a plan revision
with more lenient requirements if they still conform with
the requirements of the Act.
QUESTION 03
Is a change in control strategy by a State (e.g. from
a firm emission limitation to a system of intermittent
control, tall stacks, and/or some other measures) to be
considered a plan revision?
ANSWER 33
Yes. This action would constitute a substantive modi-
fication of the regulatory scheme which carries out the
control strategy to provide for attainment and maintenance
of the national standards.
DISCUSSION
The change in question wo;i
requirements appl . . j.... to a :-><•>
Emission limitation require;"." '
of any plan rnd are srfr.fi
in the plan bv SllOu, 'b> oi
that a substantive ir • :r-alic:.
be conr-'der.: ,1 a pla*, ..<•*-. sion.
(.1 involve the regulatory
ca or class of sources.
are the mc)st critical pares
1 i .-q.ii.'t-d to Le included
the A'H. it is axiomatic
of SUL!, . ecji.irements must
May States revise an approved plan Acquirement because
of the dii'liculty 01 impossibility OL sources meeti. y that
requirement? Where a State makes; cuch a determination, r.;;y
it now apply for an extension of the statutory attainment
date for the national standards?
A State may revise an imp] ...-Mentation plan requirement
in the situation described, if the plan as rrodificd v/ill
Still provide for the attainment of the relevant national
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standards within the attainment date set forth in the plan
approval. If the revision to a plan requirement would j
necessitate postponing the date specified for attainment
of national standards, a revision for that purpose is also
possible under the Act so long as the date is as expeditious
as practicable and does not extend beyond mid-1975. Either
type of revision would have to be approved by EPA. :
•DISCUSSION #4
Where the State, in negotiating compliance schedules
with individual sources, determiners that compliance with
the approved emission regulation by a source or sources
will be difficult or impossible by the prescribed compliance
date, it may revise its plan with respect, to that source or
sources. A source may be granted a variance from the
initially-applicable complin o dat
required to be as expedition .-(.• p.
51.15(b)) and the compliance ,:iU- c
prescribed attainment date lor the
postponement ./•'• v j 110(1} .
Alternative] y r.h.
strategy and cho-,..-• ; revise
reflect the non-a" ^lability
measure? 'e.g. 1 • . Ifur fbv
w; !! s ! i i 1 provi.;. .."or atta.i'
within the presc r i.L..?d attair.i
set back the attf.j r.rv nt date
new date is no 1 ... • - than mi.;
that the new d,-;1 . •.-.re.-ienl:-;
as expeditiously ,. , :>racti;-,i;
OJ
i c
o i f compliance is
, tic-ble (40 CFR
I"'.-: ;iot extend past the
n tiicnul standards.
^' • i ^ > r^ ^-'O^ld >~<"i'~mT_t~r} ^
,, i (40 CFR 51.32 (f) ) .
::'.iy r t::;;:. i,.; ch^ c">ntiol
i-:> t. . - .- ,. regulations to
toe]': c.-jc -y or other control
) . i.-t t u' -ovised regulations
.1' I,,,: r.tiona] .-t..Tidard
i u.,; . ,-c i,\ : , e mriy also
j standard if the
• plan demonstrates
standard
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QUESTION #5
May EPA approve implementation plan provisions which
utilize stack height requirements for emission dispersion
in lieu of measures requiring limitation of emissions?
ANSWER #5
As noted in your memorandum, this question is now being
considered by the Court in the National Resources Defense
Council suit challenging EPA's approval of the Georgia plan,
and we feel it is appropriate for us to defer any action
on the question until the Court makes a decision.
DISCUSSION #5
As you may be aware, a brief ing package on the stack
height' limitation issue is being prepared for the Adminis-
trator's consideration,
QUESTION #6
Does the Act allow a St.ate to
emission regulations adequate to .
but less stringent than t: .• :ip^iovea
emission regulations result- ng rrom a
region from Priority I to rtiDrity III?
vise a plan by adoptin
' the national standn
by E.'A r.r to rescind
recJ a- s i f ication of a
A
Yes, provided the SI a
satisfaction that the ]e • ,
the attainment of the
e demonstrate^ tc> the Administra:
stringent requl;.: .1 ons provide fo:
_..». >.^_v»~ ^..^ «^. reiuViint natioiial stcindard:; as exp> di-
tiously as practicable, bui no later than raid-1975
In the
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- 7 -
case of regional rcclassification, the Administrator cou
approve the recicnian based on a determination that the
controls are not j>r»cessary since the national standard
(N02) is being attained. Where the standard is being
attained only marginally, however, recission of all NOX
controls may threaten maintenance of the standard and
necessitate the Administrator's disapproval of all or part
of the recission.
' D-ISCUSSION 36
In our view, §110 did not require States in the pre-
paration of their plans to make faultless judgments with
respect to the practicability of controlling sources and
attaining the national standards. Reassessments and con-
sequent revisions to plans are approvable by the Adminis-
trator so long as the revised plan demonstrates attainment
of the national standards as expeditiously as practicable
(but no later than mid-1975). As noted in #4 above, in
the case of individual source compliance schedules (includin
variances) , the source must be required to comply as expedi-
tiously as practicable (40 CFR 51.15(b)). The unavailabilit
cf lov,T culfur fuels is an HDoropriate factor for rTinQjc'i^rati
in determining the practicability of control, both as applie
to individual sources (in compliance schedule development)
and to attainment dates.
It should be noted that the Agency is currently engaged
in litigation with the Natural Resources Defense Council
over the question of relaxation of plan requirements,
through either granting of variances or other regulatory
revisions. NRDC argues that the only permissible means of
postponing plan requirements is pursuant to §11') (f) of
the Act, the provision for one-year postponement: upon
specific findings by the Administrator on the record of
a formal hearing.
cc: John R. Quarles, Jr.
Alan G. Kirk, II
Bernie Steigerwald
Dick Wilson
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• " UNIfFDSTATr.SENVIROWMl-.iMTALPnO
• , ovj'':ic;: OP <.;!•: .r\>u\\, rn
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J)i sapprov.'i J of S tal e /inpl omen I atlon ]']anu DAT;'.: liny .1 4 ,
( ) for Fa.i 1 u >"o to.. flnbiii.it Transportation Control
f, v ratp'-r.'(•". /\\
C-'. . V; i J..l.i •• i::, ion
/
TO: All Regional Conns::!
I FKOM: G. V; i J..l.ia'i J'r.lcd;, Attorney
I
II. Cerlain fa'; : i cvj v;hic:h \/ore required to .sub'nlt ttanr,--
povtation cO'Vtro.'l :; traterp e:i eid noi. siibialt the:a on
/April 15 and rre not e::pec tod to .submit .'.= rratop j <:?, .'.,1
— time to be a'.prov'oc; on June I r> . Quar: L ; nnr, have a/Lsvn
• cis to v.'.'v-'the •'" t'haac' plans .should bo di i.nparovcd i i Ldio
' Federal Iv ."-a"' :; tor or \,rliether a prc'f;j;a.t c\.n be in.'..da xrltii-
out a d i .'.;<: p p .r o vo 1 .
• 2. Ssctic.n i:iO(o) or tho CKrn ;\i ;• Act authorl:;o:3 LI'.d
proniulfjaai-.'.or.." in r o distinct s '' •' \ ;. io~... In LM 1C' (<•"•) ("' ) ,
IhPA can prtJ.'>n Icja r •. olien the- ' ' ' >_'j _d. i t r: Lo mabrd. t an .u ,•
plemantat^on plan, Jn 5Jl^(a, "d , d; , cvm pronn J..-./a re :> f
tlie plan r a! -rd td.;r; ie 'uiacU-^i, e. : ;: ,,-e latter r-;.i. ti:; L;o
M ]';PA v/oulc; d.'" t'pprO'
I ( : 3. It 1' OU/ 0,M' ' • ' Li: .-.. . ik.l 1 f. JO ' U ;
init tran~i: j.';t'i,,jc, . - -•!•:• ,., .,. i\ - - •>\roniu ' '•:< ' L- " Ir
PPA will j -. p
I only thin di
ti of t '• e -
i - / ••. • J11 -.>:;,. o .< j ;,.'.• •; !; j
^ r'1'1 -u:i'i'l 'i^,' ;-;' ;, _,_. , t_ , n^OC1 ' 'V ' i T2O "•
tiorm of tli^ ; K i .: f, • , ' . vc- •
sources, r, "•- , .••.•.•• ;- •,''•.' -.;.''•
been sut.;r i , , ; , ; . ; ' -
qiri re the . • \tj f • . ":!..'.• •' aro
ai a te inn PI o.: •..-.?•, :!:.:. '- . , •: .i ,e e i _,:•.',-
• rait the.se pj-e '131.1..,, '. •,•-.•'•, : . ;::,_, r;, , ,- ."an;-?
portion o; fie ;:.ee,r F:>U::O- iclv c..P/er ; ;., -,. de^dc iJ or.laa.da"-
plan is inadequate, not the t inn ;-o, , ,..:,,:-, j.-5 .inadoon'l .•.
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s , ihnt rac't should b:>
i;'iat "The [State] con--
4, For thin roanoh, wo belinvo .it will bo j necessary
that, ds v;as done with UK: oxjtjaua] plan:;. on May 3J ,
1973, % fipacifj.c disapproval will be v.ndo in n section
do: J,'jna tod the control .'itratoore specific,
if popsib'le, than v-;as done in th-.. earJier publication.
Many of the disapproval:-: on that date \/ere r.ier^ly con-
clxasions and did not p.r.oxride much infoy.r.v.l'.ion' on \;hy Lhe
control strategy submitted by' the State Wc'G deera'ed in-
adequate.
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1
.. i « UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
' Research Triangle Park, North Carolina 27711
SUBJECT: Calculation of rollback by "de Nevers1" Model DATE; [r ')
\
Ronald A. Venezia
TO: All Regional Transportation Control Representatives
At the meeting in Kansas City, Mo., February '9, 1973, draft copins
of a paper on the subject model were distributed. This method provides
an improvement in the accuracy of rollback calculation. Dr. B. J.
Steigerwald further advised that the Source Receptor Analysis Branch,
Applied Technology Division, could perform these calculations using
their computer program (similar to samples distributed). In order for
the project to be most expeditiously handled, the following data is
required:
T. The emission inventory, if revised from SIP's submitted previously,
should be submitted for the base year in tons/year for these categories:
. *
Mobile Sources Stationary Sources
Light Duty Vehicles Power Plants
Medium Duty Vehicles Industrial Sources
Heavy Duty Vehic^s Area Sources
2. The Air Quality concentration for the particular pollutant(s)
used 11 the rollback calculation should be specified. Since the NAAQS
is not to be exceeded more than once per year, this is the 2nd highest
value irrespective of the day on which it occurs. If the 2nd highest
value can not.be substantiated the highest value should be used.
3. The growth factor that is considered most appropriate for the
prediction should be specified. Where possible, this, should be for the
Central Business District where the CO standard is a prebleni and the
Standard Metropolitan Statistical Area (SMSA) where Hydrocarbon and NOX
is the problem. Where growth factors are predicted to change in future
years because of some major planned development, they-should be specified
in order to satisfy maintenance provisions of the SIP.
4. The local vehicle age mix and niiles driven per year should be
specified if different from national averages published by the Department
of'Transportation. Metropolitan Areas, particularly in the colder climates,
--/A Form 1320-6 (Rrk. g-72)
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have a larger portion of newer cars and fewer old cars. Registration
data and urban area surveys are useful for this determination. The
average miles driven per vehicle year are more difficult to obtain
without detailed local survey. Some state highway departments are re-
porting these data as a part of safety inspections. The national
average annual vehicle miles as used in "An Interim Report on Motor
Vehicle Emission Estimation" will generally give more miles traveled
than local data in states where there is a large automobile population •
such as California.
it is expected that the computer run for the base case and simple
strategies can be completed subject to computer availability after data
is received. Please send or call the above data to Don Armstrong or
Fred Winkler, (919) 683-8291 and the results will be returned by
telephone and confirmed by memo.
Ronald A. Venezia
Chief
Land Use Planning Branch
| cc: B. Steigerwald
W J. Padgett
]• R. Neligan
H. Slater
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|j ^ ROLLBACK MODELLING, BASIC AND MODIFIED
c • • •'
Noel de Nevers
> August 1972
ABSTRACT
• •
The basis and limitations of rollback modelling are examined.
From this basis, the simple rollback n:odel is extended to include
multiple source categories, and to include a first approximation of
i
the effect o'f stack height and source-receptor distance. /
C
Notice
This document is a preliminary draft. It'has not been formally
released by EPA and should not at, this stage be construed to
represent Agency policy. It is r/eing circulated for connent en
its technical accuracy and policy implications.
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MODELS AND MODELLING <' - '
o . • .' •.-..••••••
.A model is an intellectual construct, which represents reality,
»
and can be manipulated to predict the consequences of various actions.
In recent years'there has been some controversy over what is a model,
and whether we ought to base air pollution regulations, which have the
»
force of law, on models. According to the above definition, simple
rollback is a model, and regulation's based on it (e.g. State Implementation
v
Plans) are ultimately based on modelling. As this paper shows, rollback
is a very simple model, probably the simplest air pollution model which
can be used to make quantitative predictions. Considerable effort has
gone into more complex models (normally caljed^dtffusion models"), whose
/
function is to do the same thing as rollback, but with greater detail
and accuracy, and with greater confidence in the result.
In any modelling effort one is constantly making the tradeoff
between complexity and accuracy. The true physical world is complex;
we will not have models of total accuracy unless they are complex. An
accurate model cannot be simple; a simple model cannot be accurate. We
all strive to produce a modelling breakthrough like Copernicus did, when
• * i
his much simpler heliocentric model of the solar system replaced the
•extremely complex Ptolemaic geocentric model, and produced more accurate
results, i.e. predictions of the positions of the planets. So far
no one has made such a breakthrough in air quality modelling, so our
*
current-choices are complex models of fair accuracy, and simple models
(like rollback) with lesser accuracy. r ' -.
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.... will 4
UNALJ MODELLING
r" \ The simplest and most Intuitively obvious air pollution model is
the qualitative one which says "If you reduce emissions* the air will
* • become cleaner." This 1s the intellectual basis for all air pollution
control regulations enacted until the late 1950's. It fits logically
with the "maximum technology" approach, which simply requires all emitters
to use "good engineering practice" i.n controlling pollutant emissions.
By the late 1950's it became clear that in Southern California emissicns
* « *
from automobiles would have to be'reduced beyond what then constituted
"good engineering practice." (1) To provide a basis for.setting numerical
standards, those active in that area developed the next level of air
pollution model, which in its current form is called "simple rollback"or
* *
•'broportional modellinci1.'
*
In its most basic form rollback assumes that the concentration of
any long-lived pollutant at any point is equal to the background concentra-
tion of that pollutant plus some linear function of the. total emission
rate of that pollutant in the area which influences the concentration at
that point,
C1 = b + ke ' ' '• • (1)
where c^ is the ambient concentration of one specific pollutant at the
3 •'
i-th point, normally expressed in yg/m ,
b is the irreducible background concentration of that pollutant
1 for air uninfluenced by those nearby emitters,which influence the con-
1 centration'at point i, normally in pg/m
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k 1s a proportionality factor, which takes into account the
meteorology, location of all emitters as seen from point,1, and the
other factors which influence the source-receptor interaction at that point
* . •• .
o
Its normal dimensions are (pg/m )/(gm/sec) and
e is the total emission rate of all emitters of that pollutant within
the geographical area modelled, normally in gm/sec.
For standard-setting purposes one normally proceeds by solving
r
eq 1 for e, and defining the allowable emission rate,
Allowable = ^allowable "b)/k (2)
where the "allowable" subscript indicates the allowable emission rate
is that which produces the allowable concentration at the point of interest.
If we further assume that c •,, L1 is the applicable ambient air
allowable • ;
quality standard for that specific pollutant, which we will call std,
I
then we may write
"allowable = (std ' b)/k
(3)
To solve- this equation we need the value of k, From the discu.-. ici of
equation 1 it is clear that k is'not a single constant for a given city,
but is a function of location within the city; it is higher ^"or points
near major emission sources than those far from them. In American air
pollution law the standards must be met at every point, so we. need the
value of k corresponding to the highest value of c. Solving eq (1) for
this value we find
-b)/e (4)
Here c is the highest pollutant concentration in the region of interest.
Substituting the value of k from eq 4 into eq 3, we find . • ,
o ,, ., = e(std - b)/(c -b)
allowable x " v max '
(5)
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Figure 1 Illustrates the relations In eq 5.
(_.} The next manipulation commonly made is to write
Allowable = (P°Pulatlon) (allowable emissions per unit of population)
Here the appropriate population may be a population of residences or
automobiles, or industries, etc. Similarly one replaces"the e in eq (5) with
e * (population at time of measuring cm ) (emission per unit
. max
of population at time of measuring c ). (7)
Dividing both sides of eq 5 by e, and making these substitutions, we find
(population) (alloy/able emissions per unit of population) =
(population at time of measuring c ) (emissions per unit of
population at time etc.)
= (std -b)/(cmax -b) / (8)
We then simplify this by defining ' ' j
gf = growth factor = (population) (9)
( ) "(population at tine of measuring c )
^* ' * ll|O A
and
_ emissjon factor = (alloy/able emission per unit of population)
•{emissions per unit at time of measuring c
)
max
Substituting these into eq 8 and solving for ef we find
ef - (std - b)/gf(Cjnax - b) (11)
Finally we define the required percent reduction in emissions per unit
* *"
of population as
R = 100% (1-ef) I ...
*= 100% (1 - (std - b) , , ' - .
"
100% (gf.cmax - std +bQ-gf)
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Equation 12 (which is the basic result of the linear assumption of
V *\ , . ' ,
equation 1) appeared too complex to the early workers in air pollution,
j
* ' so they simplified it by setting the b(l-gf) in the numerator to zero
* *
' "V
and changing the gf-b in the denominator to a simple b. (This is
equivalent to changing the denominator of eq 11 from gf (r -b)
max
to gf-c , -b Making these changes we find
max •
. R = 100% (3L.C -std) nr
llluA I I J t
< of. c - b
y max
Which is the "simple rollback" or"proportional model" equation used in
previous work in auto emission standard setting, and which is specified
in the guidelines for preparing State Implementation Plans.
One may most easily see the effect of this simplification -by
constructing the ratio
f "" -e U
(1-R) 10 (std -b)/gf{ -b) 9f*c " b (14)
eq it max . ,.,' "aA v '
T*' — R^ — — ~ T^TTi -bi/faf-r -b) Q f • C -gf-b
. eq 13 max
. K i'/t divide both top and bottom, of the right hand side of eq 14
by c v/e see that the ratio of (1-R) for the complete equation to
(1-R) for the simplified equation depends On gf and (b/c " ", Hgure 2
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shows tho values of. this" function for several values, of gf. From it we
' * *••
see that if gf is 1 the two equations givs ths same value, and if b=0 the
• two equations give the same value. For all other values (1-R) for the
complete equation is larger than (1-R) for the simplified equation,
indicating that the simplified equation leads to a more strin-gent set of
•5 '* . •
) '
i • , standards than the complete equation. As long as b/c , is small the.
i i max
*• ' *
ratio is small, but as b/c becomes qrcatcr than- about 0,35 the ratio
InaX
»
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begins to grow rapidly, becoming infinite for b/c equal to 1.0. Thus,
'"*" for areas j'n which growth is low, or background is small compared to the
, • highest measured^ concentration, this simplification ma(ces a small change,
and always makes it in favor of more restrictive standards. For large
values of gf and areas where the background is a large fraction of the
largest measured concentration, this simplification makes the standards much
more restrictive than the complete equation.
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A NUMERICAL EXAMPLE
To illustrate how this equation works (and to compare it with
subsequent equations) v;e will work a numerical example here. This example
~will be expanded and continued in furth2r parts of the paper. The example
considers HOp in New York City. The d?.ta used in this part of the example
1 (. • and the further parts, and the sources of the data are all given in Table 1.
o
For this example, c = 336 pg/m
. _ .. . 3
o = /.D pg/m
- gf = 1.57
std = 100 pg/m . . .
Thus, using equation 13 (simple rollback) we have
- R = 100% (1.57 • 336 - 100) = m% . 427.S = 82 2%
(1.57 • 336 - 7.5) • 52070
i.e.to meet the standard with this growth factor, all emitters must
reduce their emission rate by 82.2%. If we had used eq 12 (.the complete
r . • tf
form of rollback) we would have found,
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R » 100% (1.57 ' 336 - TOO + 7.5(1 - 1.57)) = 100% (4?4.2) = 82.2%
(1.57 ' 336 - 1.57 • 7.5)515.7'
•' * •
In this case, the complete and simple rollback formulae give the same
/ i
result to three' significant figures. . <
THE LIMITATIONS OF SIMPLE ROLLBACK
Simple rollback (equation 13) is widely used because it is simple
and easily understood, and because it requires very little input data. It
has some severe limitations, v/hich are discussed here.
1. It is a purely theoretical model, for v/hich no experimental veri-
fication has ever been attempted in a metropolitan area, and which can
probably never be subjected to experimental verification in a metropolitan
area. The reason that the experirr- ;'al verification for a metropolitan
area hac not bsen attempted,, and probably never will be, is that the
relatir" between concentration and emission rate (eq 1) assumes that all
other factors remain unchanged, including the spatial distribution of
emissions. Thus,- to test the equation one would have to reduce t'-.e
emission of each and every emission source in the area by j},^ same per-
centage. For practical, reasons this does not seem possible in a metropolit
'area. For an area with a single point source of a long-lived pollutant
such an experimental verification might be possible; to my knowledge none
has ever been made.
•
This is not as severe a shortcoming as it might appear, because the
theoretical basis (eg 1) is quite plausible. 'However it cc;'Id be v/rong
1n several ways. If emissions influence climate-.(e.g. by changing the
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t •»
turbidity of the atmosphere) then the linear assumption in eq 1 would
probably prove false. If pollutant disappearance (e.g. by agglomeration
or photochemical reaction) is not a linear function of pollutant concentration
(which it probably is not) then we would expect a non-linear relationship
between emissions and concentration. There are probably other causes
which could lead to non-linearity in this relation as we'll.
2. The application of the equation requires that we know the value of
c , the hn'ghest concentration of pollutant in the area. In general
IlKl A
usage one substrates the highest observed concentration (c ) for c
v max obs max.
These two will only be the same if one of the air quality measuring
stations is located at the point of maximum concentration. This assumption
4 f
is non-conservative, i.e. leads to less stringent regulations than would
• t
be used if the true value of c were known.
max I
3. The growth factor (gf) as used h^e assumes that all emission
rates will grow, without changes in other significant parameters (e.g.
distribution o" emissions, city size, stack heights, etc.). If the value
used here is the projected increase, for example, in vehicle miles per day
per square mile of the downtown part of some city, and there is reason to
believe that the percentage increase in vehicle miles pec day per square
mile will be the same for each square mile of the area of interest, then
t
this is a satisfactory way to use the growth factor. If the value is
simply the projected increase in vehicle population or vehicle miles per
day in the total metropolitan area then there is no reason for believing
that tin's "is a sound use of this model, and there are reasonable grounds
for assuming that the model would give misleading results if used this
» '
way.
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If the standard to be met is a short-term standard, which is most
severely tested by meteorological situations which mix the pollutants
thoroughly 'in a finite volume of air (as for example in a well-mixed
/
f
Inversion situation in a completely enclosed valley) then the growth
factor as shown in the simple model is probably satisfactory if the
boundaries of the area considered are the same as the boundaries of the
area whose emissions are trapped in this body of air. If, on the other
i
hand, the standard to be used is an annual average standard, or some other
standard which does not represent this "thorough mixing of all emissions
in a fixed, finite volume of air" then the growth factor used in simple
rollback should be very conservative', leading to much more restrictive
standards than would be needed for a model which took into account tjrowth
in emissions per unit area in the arees of greatest interest, rather than
total emissions in some arbitrarily defined metropolitan area.
T^ growth factor as defined in eq 12 and 13 is simply the ratio of
the population of emitters (residences or cars or factories etc.) at
the time when the standard is to be met, divided by the population cf
emitters at the time c .„ was measured. There has been some Discussion
max * *
over whether this future population should be obtained by linear or
logarithmic extrapolation of existing population trends.- This is really a
question outside of the basic rollback mo'del. It asks for the value of
the population on the appropriate date; it is the responsibility of the
demographers, planners, etc. to determine the most reliable way of
estimating that value. '
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;• , •• , • ' ' ;•'. i 10
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/ \ 4. Simple rollback is applicable for short-lived pollutants (those
whose "half-life" in the atmosphere is comparable to'their travel time
across a. metropolitan area at the wind velocity of interest) only if the
*
spatial distribution of emissions is unchanged.', This means that any
•x. „_
~~ growth by "expanding into the suburbs" cannot be.modeled for a short-
lived pollutant by simple rollback. Short-lived pollutants can be
modelled by simple rollback for the "complete mixing within a fixed finite
volume o'f.air" situation only if there is instantaneous horizontal mixing
of pollutants over the entire area being modelled.
5. Simple rollback is applicable to the problem of determining the
effect on air quality of a change in emission rate of one emitter
or one class of emitters, without equal percentage changes in the emission
rates of the other classes of emitters, only if one of the following
three situations exist; either (1) The class we are considering is by
far the lariat contributor of the pollutant in question, so that we can
ignore the e'fects of the others, or ignore the inaccuracy of making the
assumption that-their contribution to the concentration at the worst point
has the same factor of proportionality as the contribut.iqn of the source or
group of sources v/e are considering, or (2) The class v/e are considering
has the same temporal, spatial and vertical distribution of emissions as
the average of all the other emissions in the area being modelled, so that
a change in its emission rate has the same effect on emission distribution
in time and space as a properly-scaled reduction in all emissions rates
would have, or (3)-The standard for this polVutant is a short-term
v •' standard, which is most severely tested in periods of excellent mixing'within
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I ...... r. .. -. • i
III,-. ' .
i i ;; ." • ' !
^--; -x ' -. i
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i a limited unchanging air volume, as might occur in a well-mixed layer under
• * an inversion in a completely closed valley with no exchange of air with
the surrounding area.
I If none of these three conditions can be shown or reasonably assumed
_ to exist, then the application of simple'rollback or proportional modelling
* , to the question of the impact of changes in the emission of one class of
V emitters-on ambient air quality is totally without theoretical or experimenl
foundation.
I. .
6. Simple rollback assumes that the meteorological conditions which
j '• date when the standards are to be met. Climate does change without human
I ( ] intervention, and growth of tcitie? a.i growth of energy release does
— I influence climate, so this is not necessarily a sound assumption. The
more -"'••unced models discussed later in this paper generally also :r ;ke this
assumption, so they have this limitation in common with rollback. However
with them one can compute the effects of changes in meteorology, and thus
estimate the sensitivity of the prediction to such changes; with rollback
0
such a sensitivity test does not appear possible.
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existed when c and e were measured are those which will exist on the
max
MORE ADVANCED MODELLING SCHEMES
The previously listed limitations of simple rollback have led air
pollution workers to try to develop modelling schemes which do not have thes
.limitations. Most of these improved models begin with eq 15
c- = b + Ek.. e- . .. ' ; (15)
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12
. .
where c. is the concentration at receptor no 1,
' i ' '
e. is the emission rate for emitter j ';
»'••-..
. and k.. is the source-receptor-interaction for emitter j and
'J
receptor i.* One customarily uses a "source inventory" to find the
individual values of the e- (either source-by-source for large "point sources"
j
i
like pov;er plants, or in aggregates called "area sources" for autos and home
heaters and incinerators). The values of k.. are based on meteorological
' ' 'v
calculations. These meteorological calculations generally fall into tv/o
categories, each of which seems applicable under some meteorological
circumstances. These are: (1) box models, in which pollutants are
assumed to be totally mixed within certain vertically-limited air parcels
which travel with the general wind velocity, and (2) gaussian plume models
which assume that the pollutants are dispersed according to "gaussian
pltime" formulae.
Such models-may be instantaneous, solving for the concentration at
a given point at a given time, taking into account only the current and
recent past meteorology, or long-term, sampling the varibi/s meteorological
conditions and assigning frequencies to each, and then computing the
* ••-
concentrations for each meteorological condition, multiplying this by the
frequency and summing to compute the long-term average concentration.
These more advanced models make more detailed predictions, than
*The k.. shown here is normally shown in the air pollution literature
!J • .. - .
as (X./Q-)- The simple form here is used for case of typing and clarity
I J
of presentation.
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73
!
rollback, which makes it possible.to test their assumptions against ex-
perimental data. They allow one to predict the spatial distribution of
various concentrations of pollutants on a given day, or for some long
time period, which is not possible by simple rollback. These computed
*
distributions can-be compared with measured air quality, and the models
modified to obtain superior agreement. Ir, addition they can make short-tern
predictions for specific meteorological conditions, which can be compared
with observed values. Because these more advanced models have this testing
potential, they have been widely studied and tested. As a result we have
a much greater degree of experimental confirmation of them, and much
more confidence in their predictions than we have for simple rollback.
The relationship between these mo-re advanced models and simple
rollback nay be clarified if we consider tho two circumstances in which
the more advanced models give practically the same answers as the siir.ple
rollback equation. These are: •
*
].
-------
.
14
i
'' ~ / *
i j But if, as assumed, there is no change in the relative spatial and
temporal distribution of emissions then the summation term is a constant,
• ' because none of the factors which influence th,e k.. have changed and the
f
(e.) . . , are constants. Thus we have
— J original
c.j = b + prop, factor • a constant - (19)
which is merely another way of writing eq 1. Thus, in this case both
.' the advanced models and simple rollback indicate that at any point (not
only the most polluted point) the observed concentration for the ap-
propriate time period is a linear function of the proportionality factor ap-
plied to the baseline emission rate. And (2) The situation in which the
standard of interest is a short-terrt one which is most severely tested
during a situation in which we have complete mixing of pollutants within a
/•"""., finite air volume. In this complete mixing situation all the values of
k.. are the same, so that equation 15 becomes
"ci " h " :Sj rej • ' *20'
but le. = e - (21)
w
so that this also rsduces to equation 1, with the further proviso that
the concentration is the same at every point in the air'mass of interest.
For this complete-mixing situation both rollback and the more advanced
models must give this result.
I
EXTENSIONS OF SIMPLE ROLLBACK ' •
As described above, more complicated modelling procedures are
theoretically sounder end better experimentally verified than simple rollbcr''
-------
I i:. ,:, . . • .• .
i .• § • • . • • -•- ....
I ' •: . • ' .
I '"-.:• • ' "
Thus, one might well ask why bother with improved versions of rollback?
| The justifications for so doing are:
• i • 'l. The required input data for rollback is much less than the
; required input data for the more complicated models.
I 2. Only a fey of the best-equipped air-pollution groups in the country
are capable of performing the calculations for the more advanced models,
• / while anyone with a pencil and a sliderule can do rollback calculations.
• 3. Although the more advanced models have been experimentally tested
for S0? and total suspended particulars, they .have not been developed and
I'
tested successfully for photochemical oxidants, NCL or hydrocarbons.
m I Similarly, the area source emission structure used in the models for SCL
and TSP is not necessarily applicable to emissions from motor vehicles,
• ' vy without further work. These shot;"!'1 no* be drawbacks to using the advanced
j models without this verification, if one intends to use instead the totally
B - unven'f, ] rollback model in their place; but in many minds it ?pp<;:ently is.
• For all of these reasons, there appears to be a need for improved and/or
extended rollback models, to use until we have all the necessary data to
use the more advanced models, and we have adequate verification of their
M | . predictive ability, and there exists widespread capability and/or willingness
• to use them.
I
ROLLBACK 1/ITH VARIOUS EMISSION CATEGORIES
The first obvious extension of rollback can be made if we wis'i to
• study the effects of various classes or grotfps of emitters of « single
pollutant. K'e can treat this problem by return-ing to equation 15, ar;
I
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-------
f. , • -. i - • • -; ; r ^ ----- •
i , ' i . ' .- 16
o
assuming that the k. i for the various classes are the same. As discussed
1J i
previously this has no experimental basis and is only theoretically de-
fensible if all the classes have the same spatial, temporal and vertical
(
distribution or if we have a totally-mixed-limited-air-mass situation. If
•
these assumptions can be made then
s- = b * kij Eej . <22>
We may deter/nine this value of k. . from the maximum value of c measured
* J
in the region under study during some baseline period, and the known
emissions during that period. We find
kij = Kiax - baseline "b^ ^ej) baseline (23)
Substituting this value in eq (22) we, find
cmax ° b + (cmax-bascline "b^ Iej/' l(ej^ baseline (24)
We can, if we wish use eq' ?A as a tool for <"reaicting the future maximum
ambient air concentration for a given set of future emissions. Or, we can
transform i1 <:>< nd the required reduction in emissions by the various
groups to meet standards. To do -this we substitute std for c and
max
solve for Ee., finding
- b) z(e.) base11pe -. -.. (25).
'cmax-baseline ~ '
If we then write
ej s (ej> base efj '9fj
where ef and gf has the same meanings as before, we can solve for the
required cf of any group. • For group no. 1 -
, !~(std -b)i(c.) i ~~)
-------
1 ,,. • I -
. '• :'. 1 ' • ' j
' ,.-< ....
1 ^
.".-;•/ N) We can simplify this equation by
'' ^ -i"""**' •
I1' -i-'
'.'/';\ . • and defining
* •* •
'1 (fr )L = (e.) , 1 I
1' /- -, . This then becomes
1 -^5
*
|Pf = n^p /inn? ^ - ^
1 * K,/IUUA ; ij \ Q*
3 ! base ]
M
1' SECOND NUMERICAL EXAMPLE
'•
I ' • 17
. , '
\
dividing top and bo,ttom by z:(e.)
i
^^ base. (28)
m> •
.
(std -h) Lfr } f 71 f
r •• L.\ — ^v''i/u cn°' '9' • v
vcmax-base ~D; 2 J Dase J J|
•
- -. To apply this equation to the. same problem treated in the first
• ~~ numerical example, we add the additional piece of data (shown in Table- 1)
m ' < that the fi'motn-|e in New York is
' ^^ We may now use eq 29 to ask
383!.
what % reduction of mobile source emission
| • -a ^s necessary to meet the standard, if we make no reduction in stationary
': • i
j
_ i .} . stuce emissions. Letting the-1
1 i'1 -
™ ; fj 2 subscript stand for stationary
1:1 for ef,, taking efy to be 1.0.
.U " •
,
subscript stand for mobile sobers and the
*
sources, this means solving equation 29
For want of data we use the o^me v.lue of
•" growth factor for both categories, i.e.
I-. gf, = gf5 ~ 1 .57.
I £•
, '. \
\ Thus
I 1 r
• ef, = 1 (100 -
- . (0.38)(1.57) (336 -
1 I and R.J - 216%.
• '1 Thus we see that according to eq
i .
i i
1 l._ : :„....
• •.T
•» *-
7.5, H"l . _} 1M
7-5) ll0 K5ll
29 we cannot meet the standards ir: Ncv/
. •
•- - •
-------
18
.
York by controlling mobile sources alone; the rollback of greater than
» .
100% means that they would have to be net consumers of N02 rather than
i
producers if we continued to allow stationary sources to emit at their
current rate.
To continue the example, we may ask what fractional reduction
in emissions from mobile sources will be needed if stationary sources
are reduced as suggested by Steigerwald (4). The values are given in
Table 1. This requires us to use three categories, subscript 1 for mobile,
subscript 2 for existing stationary and subscript 3 for new stationary.
The appropriate values are: efp = 0.80, ef3 = 0.50, gfp = 1.0, gf3 = 0.57.
Substituting these in equation 29 v/e find
ef =
(0.38) (1.57)
1 "~ ' "' " *"-"'- ,n cov/n QW1 Q^ _(o.62)(0.5)(0.57)'= -0.64
(336-7.5)
| 4 and R1 = 164%.
1 Thus, even wit,, these assumed control values on stationary sources, equation
1 29 indicates that a rollback of greater than 100X on mobile sources is needed
j
I to meet the standards.
i"' * *
We could consider further refinements here by asking what control of
.!. new and/or existing stationary sources would be needed for sjome assumed
• rollback of mobile sources, etc. However i-t seems pointless to continue
f this example, since as previously discussed this extension of rollback only
has theore.-ti.cal basis for the case of equal spatial and temporal distribution
of. emission sources or perfect mixing, neither of which seem applicable
to annual average N0? in New York. * <• ' ' -•
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I
-..-,'.. ••'••'•.- .. 19
• ! / A SEMI-DIFFUSION FORM OF ROLLBACK
v " ' • • •
I If we wish to treat individual sources or source categories in
;
i . } . rollback, under circumstances in which we cannot reasonably assume that
| j the k.. are the same for all sources or all source categories, we can
M i still make some plausible estimates, if we are willing to accept somewhat
: more complicated formulae. What is proposed is to take a step in the
• - ' direction of meteorological "diffusion modelling" in considering the air
' . quality impact of the various sources or source categories.
I'
: Consider first the formulation of k.. which appears in the most
• J
• ' widely used meteorological "diffusion equation." For source and receptor
: aligned along the wind direction so that the source plume passes directly
| I '• over the receptor the form is:
l_^xp C-dL,.., (30)
| - V .,' • - - uz«y - ^ ^
I:
where u is the wind velocity
• h is the stack height plus plume rise
° is the-horizontal dispersion coefficient and
I ,' . 02 is the vertical dispersion coefficient.
Normally the dispersion coefficients are given by equations of the form
| *= axB ' (31)
'.' . where " and 8 are experimental constants. t
I The values of ° and B in equation (31) are different for different
I L, '•- ' " ' - ; . •
» • "-
I
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• 20
meteorological situations. The most common approach to assigning them
values is to define "stability classes" and assipn values for these.
For the various stability classes in common usage, the values of 3 range
from 0.5 to 1.9. For the purposes of this simplified treatment, we will
assume that an average value of 3 equal to one is an adequate representation.
•This reduces equation 30 to
k =
K..
1J u x exp (h*
Here the const, term includes uvo a's from the denominator, etc.
To apply this value we would also need to know the fraction
of the time that the wind blows with this velocity in the direction ,'
• I
connecting this Source to this receptor, and sum over all such conditions.
In rollback that is done by comparing measured concentrations with total
area-wide emissions for the same period. Thus we may write
u •- js^me Constant which in a function of local conditions /~3v
•3 ' J ij
Then if we substitute this form into eq 15 we have
c^ « b + const, y —*— ? " 2 ^^
Z-'x,- • exp(h- /2ax,.. )
ij J i J
" Proceeding as before to solve for the value of this constant by substituting
c . ,. and (e.) . n. and then substituting back into eq 31 we find
max-baseline v jx baseline ,
i = b + ^Sax-base -b)
-------
1
• -~ ,. •
1 <• •
( \
1
1
w
1
1
I
1
1
1 c
i
1
1
1
IV
1
i
1
1 U
f >
1,
1 1
-. T— - rv»- r\ui.p -vui i ui HIU in
^
t ui uiausr^caMic- 5 nUp -rcu u^ nuw -wrr-t-inc- J
location factor^ = If... = l/(Xlj2exP (hj2/2ax.j2)) (36)
so that equation 35 becomes
i / *,i t f
Cj CD T (C
/ • •'
If we now wish to
. M n i T— ^ -,._.__ jl>- 1.-_.,- / o i \
base r(e ) -If (3?1 '
Mej'base ITij
• • '
consider the required rollbacks for various emission
categories, we must assign a single, typical value to If., for that source
' *l
category. This means
that v/e consider that category to have one (stack
height plus plume rise) and one source-receptor distance, as seen fron the
point of highest concentration. This changes our. If. . terms to If. terms.
• B J J
Then, as in the previ
.
e. = (e.) • ef
0 J base '
we can solve for the al
ef, = (I-RT/IOO*) =
1 !
1
-------
V •
' * ' !
(,. - ** Tb see what the effect of this addition of a "semi-diffusion" term
i • i
is, we need some estimate of the value of this location factor for
1 t i
i various x,. and h.. Fortunately this function is practically proportional
' " v J t
i to the (Xu/Q) function for "C stability" in Turner's "Workbook of
Atmospheric Dispersion Estimates'^ 5). Proportionality is all that is
• required, because as we will see later, the values of this location factor
; only enter as ratios, never as the values themselves. Figure 3 is copied
from Turner': : ..'orkhoo'; . . ." and shows the behavior of this function
j for various values of x. . (distance).h- (stack height), and L (mixing depth)
l 1J J
. ' which we have' not included in the model, but could if we wished. The
pertinent observations to make at this time are that for x^ greater
than 10 km stack height is unimportant, and mixing depth very important,
C , and that for distances less than 2 or 3 H stack height is very important,
and mixing depth unimportant.
•
THE THIRD NHLRICAL EXAMPLE '
To illustrate the use of equation 41, we will continue the same
example used previously (NOp in New York). The additional pieces of in-
formation needed are the appropriate (stack height plus plume rise) values
and source-receptor distances for mobile and stationary sources. Since
the largest stationary sources of NCL are power plants and large high-
temperature combustion sources, it seems reasonable to assign them a
significantly larger stack height and to assign them a greater source
receptor distance from the highest concentration points than we asf.
to mobile sources, which urc highly c.ontr.'nti'i'itcd in the areas of .
measured ambient KCL concentration. A set of values have been ,. .i' '
-------
1
1
1
•
1
r- •. '• /.•••"..- . . i
•\ ..v ' , ' . • • 1
1 > 1 . '
/ • 1
t
'(". • ' ' / - ' i"
N^ , •
i
23
-
•
as shown in Table 1, based on the author's estimates. Using these, we
can compute the values of If. for the two classes of emitters. Using
•• w
--. ^ figure 3, we read, If^.^ * 4 x 10"4, and lfstationary "
I Using these values we compute for mobile sources
•
/ \ •• 4
(frr)mobilc - (0'38! (4 x 10. )
001 (0.38)(4 x 10-4) + (0.62) (1 x 10-4)
| By difference (frrJstat1onary - 1 - 0.71 = 0.29.
Then we can use eq 41 to compute the necessary reduction in
1
1 x 10"4.
= 0.71.
mobile
emissions, if stationary sources are no'c controlled according to these
1 assumptions,
r -,
'. ef, • 1 (100 - 7.5)
I (0.71)0.57) L(336 -?.<;) -(0.2«(1.0)(1.57)
•I . ( ^ ~J
•
„
*
= -0.155.
Again we see that under this set ot assumptions it is not possible to
| ' meet the standard by control of mobile sources alone, because v/2 find
.
1
1
•
* .
•
1
1
a rollback of 115% required.
We may continue the example by assuming that stationary sources will be
controlled as shown in Table 1, and assuming that the If for new and
• . • ' » 4
existing stationary sources will be the same. This results
ef, = 1 RlOO - 7.5)
<0.71)(1.57) |_(336-7.5) <°.29)(0.8)(1.0) - (0
which indicates that a rollback of 103% is needed in mobile
in
-1
,'29)(0.5)(0.57)
sources, if
this is .the degree of control which can be obtained for stationary sources.
At the -end of this long example is seems wise to repeat that the
,
combination of h. and x.. chosen here were chosen by Ouesstimate. They
; j j ij
-------
/ • 24
seemed plausible, and gave large enough differences in the If's to make
-.>. :«[>
the example interesting. Obviously a great deal of thought and effort
will have to go into choosing the right values c\~ these parameters, if
•
we are to use them for standard-setting purposes. (Although v/e have
• '
* -
previously set standards by simple rollback, v/hich ignored them, a process
less likely to be accurate than gjestimating them, as v/as done here.)
SUMMARY OF THE THREE NUMERICAL EXAMPLES
We may recapitulate and summarize the three examples, as follows:
Example 1: by simple rollback v/e find that if all sources reduced thtir
: emissions per unit of population by 82.?.% then the standard v/ould be
*
met. No information can be obtained from this model about the required
• •
C , rollbacks if all sources do not make the ,ank: proportional rollback.
Example 2: by rollback with various emission categories,, not' taking
differer- •-; spatial distribution into account v/e found that if only
mobile sources were to be controlled a rollback of 216% would be needad.
If stationa,; screes were controlled to the degree suggested by
Steigerwald(4) then a mobile source rollback of 164% wouTd'be required.
.Example 3:- by rollback by various emission categories, taking differences
in spatial and vertical distribution into .account, we found that if only
mobile sources 'were controlled a rollback of 115% v/ould be needed, and
t
if stationary sources were controlled as suggested by Steigerwald (4)
a mobile source rollback of 103% v/ould be required.
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C;.
C
. I
In tabular form:
Assumptions
Simple model, all sources (stationary
and mobile) make the same percentage
reduction
4
Category model, stationary sources are
not controlled
Category model, stationary souces
controlled as suggested by Steigerwald (4)
Semi-diffusion model, stationary sources
not controlled
Semi-diffusion, model, stationary sources
controlled as .suggested by Steigerwald (4)
Conclusions and Recommendations
25
% mobile source rollback return
t
\ '
82
216
164
115
103
1. Rollback is simple and widely used. However it has no experimental
basis, and its theoretical basis is restricted to very unusual situations,
I.e. situations in which we either have perfect atmospheric mixing in the
area of interest or all emitters make the same percentage reduction.
2. It is recommended that we continue to use simple rollback for
situations in which we can reasonably assume perfect atmosphei ic mixing
• *
or can assume that all emitters will make the same percentage reduction.
But if these two conditions are not satisfied, then it is reconmended that
* •>•
we not use simple rollback, and that any calculations based on simple
rollback be understood as having no theoretical oc experimental basis.
3.' The semi-diffusion version of rollback makes use of more of the
available information about the area being modelled, and makes use of more
of our accumulated knowledge of meteorological dispersion than simple
rollback. Like simple rollback it has no experimental verification.
-------
- However its theoretical basis allows it to be applied with some confidence
to situations in which we can have no confidence in simple rollback.
4. For situations in which we cannot assume perfect atmospheric
f ,
_ mixing or equal percentage reduction, it is recommended that we use the
semi-diffusion version of rollback as our simple model.
5. In the situations described above we have every reason to believe
that.full diffusion models (like AQDM or IFF) will give more reliable
predictions of the consequences of changes in emission rates and patterns
than simple rollback or semi-diffusion rollback. ' Therefore any result
obtained by semi-diffusion rollback or simple rollback must be considered
\
a "quick-and-dirty" substitute for the more reliable result which we could
obtain with additional energy and effort by a diffusion modelling effort.
O
\M f.'f.
-------
1
1
l^BI
1
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1
1
1
1
1
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•
1
1
" 1 ' '
. ' ; - ; / NOMENCLATURE
'•"•'*• i" . ' i '
b background concentration
L ' c • ambient air concentration * ' i
j •'
e emission rate
ef emission factor (allowable emission rate per
unit of population)/(curpent emission rate
per unit of population )
~ i !
(fr.) fraction of total emissions in class j
(frr.) same as (fr.) but weighted by If
j j
gf growth factor (future population)/ (current
populations) - Population may be households,
cars, industries, etc.
h stack height plus plume rise
•
- k . constant of proportionality between c and e
l
/ ' ' .
| > .. If location factor
<
j R Rollback percentage
std applicable ambient air quality standard
^ .
u wiV.d velocity
• -x distance between source and receptor
. (X/Q) source receptor interaction coef, same as k
i
"i . . • .
• a,e constants in dispersion formulae
o ,oz horizontal and vertical dispersion parameters
; * *•-'
" " '
Subscripts
J • i receptor l
.-• j i- source
... ' ' •
, -.. max- maximum
1 9 ' .
1 allov/able allov/ablc to meet standards
j
i
baseline corresponding to emission rate from which rollback
be calculated
:A
...
3
pg/nr
vg/m
gm/sec
-
"
-
-
m
0
Gig/m-5)/
(gm/sec)
f\
1/m^
-
ng/m
fn/sec
m
•(vg/rn )/
(goi/sec)
-
m
is to
-------
; ." "7 " " • •; "":"" "T
• ' • • i
'REFERENCES
Larson,' R. I. "A Method for Determining Source Reduction Required
/to Meet Air Quality Standards," Aj^A_,^jir_naJ_Tl 71-76 (Feb 1961).
i
"Cumulative Regulatory Effects on the Cost of
Automotive Transportation (RECAT)." Report of the Office of
Science and Technology (Executive Dept. 'USA) Feb 1972.
3. Romanovsky, J. C. "General Assessment of the Air Pollution Problem
and Philosophy Underlying Automotive Emission Controls,"
Appendix I-F to Ref. 2.
4. Steigerwald, B. J. "Explanation of Charts and Summary of Inforira'l
Comments to RECAT on August 30, 1971." Appendix 1-6 to Ref. 2.
5. Turner, D. B. "Workbook of Atmospheric Dispersion Estimates." Office
of Air Programs, Publication Mo. AP-26 1970,
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I
r
u
CO
E
Ol
•r- *CJ
IO
3
4J
C
JQ
10
background
29
eal-lowable e
:; emission rate, gm/sec
Figure 1
Graphical Representation of Equation 1 and the computation
•of Allowable
-------
c
(1-R)
eg 12
°-R) 10
eq 13
C
•/ Trgunrz — ;—-7— ~
Comparison of complete and simplified forms of s'imple
rollback, for'various values of gf and (b/c )
2 .
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1
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11
I j
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I
I
i-
o
c
10
\l:\..::. ••::..-:•!:•-.-:: i/i.i-::. r:::i
d.-ioX^-.i-—.!-.-.:..:.: _•!_:..:.! .LU::
;;!^
IML^f-MaE
.— .. . .,.,.
.....A.. vV\
to
Mo. 3
I i
E .nntor for If This is copied from figure no. 3-5C of Turner's "l/orkboc1-'
I Atmospheric Dispersion estimates." As shown in the text the If. factor is "
j practically proportional to the (Xu/Q) shown he-re. J
of
-------
(•*
32
• TABLE 1. DATA USED IN EXAMPLE
Calculations, all for N02 in New York
G
Paramater '•• Value
cmax (annual arithmetic . -
mean) 336 pg/m'
ft
b 7.5 pg/nT
gf 1.57
*
std 100 pg/nT
% mobile ' 38
\
ef (stationary)(existing) 0.80
ef (stationary) (nev/) 0.50
x mobile 300 m
x stationary 600 m
h mobile 10 m
h stationary 30 m.
Source
(Ref. #]
3
3
3
3
4
4
4
Comments
(mobile only)
Author's guesstimate,
used for illustrative
example only.
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• MAINTENANCE OF NATIONAL AMBIENT AIR QUALITY STANDARDS
• Complex Source Regulations
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| Office of Air Quality Planning and Standards
Control Programs Development Division
« Standards Implementation Branch
I June 1973
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COMPLEX SOURCE REGULATIONS
On April 18, 1973, the EPA proposed amendments to 40 CFR 51 designed
primarily to expand the scope of review prior to construction or modifica-
tion of buildings, facilities, and installations for both direct and indirect
air pollutant source emissions. The EPA received over 70 sets of comments
on the proposed regulations. These comments were received from a wide
spectrum of interest groups; official agencies (Federal, State, and local),
environmental groups, trade associations, contractors, and private citizens.
The EPA promulgated the regulations, with appropriate modifications on
June 18, 1973. The schedule of events is attached (Table 1).
The EPA must now proceed to work with the States in the development
of approvable plans that are to be submitted by August 15, 1973. The
milestones involved between now and August 15 ar° given in Figure 1.
The State should be urged to submit at least six (6) copies of the
plan to the appropriate Regional Office on or before August 15. Figure 2
illustrates the review and processing procedures to be employed in the
approval/disapproval and proposal/promulgation process. In view of the
short scheduled imposed by the Court order, it is urgent that this
procedure be followed.
A draft of available guidelines was prepared and distributed by SIB
to assist the Regional Offices in working with State agencies in this matter.
The guidelines are available as of this date and are attached. Additional
work is underway to provide improved analytical procedures and guidance in
implementing these maintenance (complex source) provisions. As guidelines
are developed, they will be distributed by the Regional Office as expeditiously
as possible.
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Guidelines for Implementing EPA Requirements for Maintenance of Standards
This document is intended to assist the Regional Offices in providing
I guidance to States for developing implementation plan revisions to comply with
the recently promulgated (6/15/73) regulations involving maintenance of the
1 national standards. As indicated in the promulgated regulations, States must
• submit these plan revisions by August 15, 1973. The new requirements 40 CFR
Part 51 are discussed in order below.
I 1. 1 51.11(a)(4) Legal authority
Based upon a poll of state attorney general's offices by the Regional
• Counsels, it si estimated that a majority of states will not have adequate legal
m authority to prevent construction of indirect sources of emissions if they
would result in a violation of an ambient air quality standard. States
• are advised to consider, in addition to statutes pertaining to environmental
rotection, other laws which may provide the necessary legal authority. Such
H laws include land use controls and authority t < local zoning. In the plan
m submission, States are advised to cite their authority and include copies of
applicable statutes
• 2. 1 51.12 Control strategy: Genera]^ paragraphs (e), (f), (g), (h)
f *
Guidelines for compliance with the provisions for maintenance of standards
| under this section are under preparation and will be available at a later date. The
• major submittal required by these paragraphs is not due for 2 years.
3. S 51.18 Review of new sources and modifications paragraphs (a)(b)(c)
• Several techniques are attached which are designed to enable the reviewing
agency to determine which facilities are to be reviewed and to perform the analysis
of carbon monoxide impact from a particular facility. States are not precluded
•j from requiring the developer of a facility to perform his own analysis of impact
^n air quality from his facility. To lessen the agency's workload, such a
• procedure is encouraged. In those cases where the burden an analysis is placed on
the developer, the State should provide an approved technique of impact analysis to be
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-yo, by the developers.
- c h nl RyjLfojL determination of the necessary 1 eyel of jna^sjs^jTab A)
This scheme is in the form of a decision tree which enables one to determine
c level of analysis needed for a particular facility. Required information to
' >. -k-c' :•. ions in this scheme include current air quality, both on the. site and ir
,v:ty of the facility, and pertinent meteorological data. Presented as an
-,'endix to this scheme is a technique for estimating air quality concentrations
: owio'-j and in outlying areas from a "downtown11 air quality measurement, site,
jndj>_e ct_s ou re e ( Tab, B )
This technique, developed by. the Source- Receptor Analysis Branch, incorporates
•'•,£ graphical relationship between emission density, area size and carhon nonox- !-
.oncentrationc- whu.h appeared in Appendix 0 to the " ;era] Reoj_s_ter regim: ' ,,r;£
••f 6/15/73.
4, § 51.18, paragraph (d)
The purpose of this parK,rj;-'h is tc ensure that the new facility "is not
inconsistent with any applicat-'ie control strategy, even though me -ev/ f:icnHy
;i^y not result in a violation of an ambient air quality standard. As an example,
suppose a facility is to be built in an area for which a transportation cor t re!
strategy exists. An analysis of the facility indicates that the air1 quant/ imaact
will not result in a violation of an ambient air quality standard. If, however,
4he facility will cause a significant disruption in traffic patterns which were
Assumed in the transportation control strategy, then the facility would essentially
change that control strategy. Either the facility as designed would have to be
Disapproved, or the control strategy would have to be revised to reflect UP
-^suiting traffic' pattern.
An apparent shortcominq of the review pr.-ress ~'s the level o+' rr-'.iM1 \ '
techniques used to predict the air quality impact of an indirect sour:>:: if
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* emissions. If an analysis indicated that a particular facility would not result
• in a violation of an ambient air quality standard, yet a violation occured after
the facility is put into use, there is obviously no method under the new source
review system for correcting the problem. In such an instance the proper
mechanism for addressing the problem would be to revise the control strategy to
curtail mobile sources, either at the particular facility or in general in an
ft area. This choice of control would depend on whether the violation of the
standard were directly attributable to one particular facility or to a group of
• facilities.
_ 5. I 51.18 paragraph (e)
• This paragraph requires that the agency responsible for meeting the requirements
• of I 51.18 be identified and that if a non-air pollution control agency is given
that responsibility, that agency must consult with the congnizant air pollution
J control agency. The plan should include a discussion of how this will be done,
including the weight given to comments from the air pollution control agency.
• 6. I 51.18 paragraph (f)
ft An illustration of a technique f.or determining the sizes of types of facilities
which should be ? : to review is given in Tab C. Item 1 of the proposed
| Appendix 0 which appeared in the Federal Register of April 18, 1973, suggested
— sizes of shopping center- and sports stadiums, which should generally not be
™ exempted from review. Their sizes were chosen because they might cause a violation
• of ambient air quality standards regardless of their location. These were shopping
centers with gross leasable area greater than 800,000 square feet and sports
Jstadiums with seating capacity greater than 25,000. The deviation of these numbers
_was dependent in part upon a technique which incorporated assumptions which were
• subsequently found to be questionable. Consequently, States are advised to ignore
• those proposed sizes and rely on techniques provided in this guideline for choosing
facility sizes which will be subject to review.
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7. § 51.18 paragraph (g)
Administrative procedures can be depicted in a flow diagram which indicates
time intervals between steps. Such a flow diagram is presented in Tab D.
There were a number of comments on the proposed regulations indicating that
EPA should require the States to act on an application to construct within
a certain period of time. While EPA has no authority to do this, it does seem
reasonable that the review procedures include such a provision.
The plan should also provide a detailed list of the information which the
developer must supply to the reviewing agency. This can be submitted in a
sample application form. Item 2 of Appendix 0 of Part 51 lists some of the
information which should be supplied by the developer in order that an
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evaluation of the air quality impact of a facility can be determined,,
8. I 51.18 paragraph (h)
The State should provide a discussion of how it will provide public noti-
fication of the availability of both the application for approval to construct
and the analysis of the application, including proposed approval or disapproval.
The State might include a copy of a sample notice. The notice might take the
form of a legal notice together with a display advertisement. To help defray
the cost of such advertisement, the States might consider charging a permit
a permit application fee, or billing the applicant directly for advertisement
if these practices are within the legal constraints of the agency.
General
1. As with all plan revisions the State must follow the procedures pertaining
to public notice, public hearing and plan submission as indicated in 40 CFR Part
51, section 51.4, 51.5 and 51.6.
2. If the implementation of the new requirements will significantly increase the
funding and manpower requirements of an angency, States are advised to revise
information which they submitted pursuant to 1 51.20 (Resources). If agencies
other than the air pollution control agency are given responsibility for the
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the review process, the resources which those agencies will allocate for this
I purpose should also be submitted.
3. The States may want to include in their regulations provisions for condi-
• tional permission for construction of indirect sources. Suggested conditions
• which can be imposed on the developer include:
- ambient air quality sampling in the vicinity of the proposed site prior
I to beginning construction,
- estimation of the existing air quality in the vicinity of the proposed
• . site, prior to construction,
• - provision for adequate public transportation to offset an increase in
mobile source activity which would'result in a violation of a standard.
I 4. For areas where ambient air quality standards are presently being exceeded,
but the air quality concentrations projected for the area will be below the
™ standard at the time the facility is put into operation, then the facility
• should be permitted, if it does not result in a violation of standards. Air
quality projections found in state implementation plans can be used for this
I detenrination.
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TAB A - Example Screening Techniques for Review of Indirect Sources
One possible approach to implementing the indirect source review procedures is
to establish a screening technique which can be used to determine the depth of analysis
a source should receive. The major parameters in developing such a technique would be
the existing air quality at or near the proposed location of the source and the relative
size of the proposed source. An example of such a technique is illustrated in general
terms in Figure 1. The terms and parameters used in Figure 1 are discussed below:
1. Measured or estimated air quality at proposed site. States may wish to
require a developer to conduct air quality monitoring in order to accurately define
existing air quality. Alternatively, Appendix I presents a technique for estimating
air quality at agiven site using air quality data from another location in the city.
2. hdicator of induced on-site air quality.
For a shopping center or sports complex, this parameter would likely be the
size of a parking area. However, the same size parking lot at different types of
indirect sources may likely result in different predictors of on-site air quality
/
due to the different operating chara'cteristies of cars (e.g., relatively uniform
traffic flow during the day at a shopping center versus short-term peaks at a
*
sports complex). Using average conditions of assumptions involving the operation
^- •
of vehicles within parking lots, the size of a shopping center parking lot can be rough.
-elated to on-site air quality (see Tab C). For example, the assumptions in Tab C indicate
that a shopping center parking lot of approximately 40 acres would correspond to
on-site air quality that is about 60 percent of the 1-hour standard for CO.
3. Full analysis.
This analysis involves the evaluation of on-site air quality using the techni-
ques of Tab B and as well as an evaluation of the impact of on-site emissions on
air quality "hot spots" in the vicinity of the source. This latter analysis can be
performed using the area source modeling technique described on page 39 of Turner's
workbook.
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• Where the off-site emissions may be significant (e.g., congestion on highways
• leading to the source), the imapct should be analyzed using the line source calcu-
lations on page 40 of Turner's workbook or the HIWAY program.
* 4. On-site analysis
V The on-site analysis can be relatively simple in cases where existing air
quality is very low (i.e., background and nearby source effects are negligible).
| In such cases, the graphical techniques in Tab B can be used for evaluation. Where
_ background values are important, the full 8-step procedure in Tab B should be
• followed.
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Appendix II describes computer modeling techniques which are, or will be,
available to Regional Offices to assist States in evaluating the impact of new
sources.
• Appendix III presents a brief abstract of each of the modeling references
listed in the May 15, 1973S Federal Register.
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|OO
II)
t
V)
O Of
Q <
u) z
60
40
u.
0
tf £
0 7
u. -I
£ *
"S O
§ ^ 10
FU LL_
NONE
ON-8\TE
-SITE
NONE
fefc
ESTIMATED A*R QUALITY
FIGURE -1
DETAIL OF ANALYSIS REQUIRED
AS A FUNCTION! OF SOURCE
S\ZE AND EXISTING AlR C?UAL\TY
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I APPENDIX I
• Meteorological basis of "Nearby Point of High Concentration" Rule
m This rule is intended for the case where measured or calculated
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air quality dataat tne S1'te °f tne Proposed development are not
V available. In that case, if them's an adequate emission inventory
and meteorological information and a computer capacity, the best
jj approach is probably to make a diffusion model estimate of the air
— quality at the site, and a^ second estimate of air quality in the
* site and its surroundings after the complex source is in operation.
• Comparing these, the impact of this source can be determined. However
in most situations this will not be a practical alternative, because
| the agency making the evaluation will not have those capabilities, nor
^ will it have the time to make this kind of evaluation for each site if
* it had the capabilities.
• Therefore the objective of this rule is to obtain a simplified
substitute for that procedure, which w;"l give substantially the same
I results that such a thorough study"would. Since this procedure is not
£ to be used tc rtjc-ct any project, but only to decide what level of
* further study is needed, it should be somewhat conservative, i.e. err
tt on the side of predicting higher rather than lower concentration^.
Because the reviewing agency probably does not have a map wren
| pollutant isopleths of concentration under the worst conditions, but
g probably does not have point values from its downtown measuring stations,
the question we are asking is "If the concentraiton at the city center
8 is A, how much is the concentration B km away?"
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The procedure used is to convert the air flow over the city center
into an equivalent line source, which can then be used in the well-known
line source solution (Turner p. 40). This indicates how the air with the
highest measured concentration (normally the city center) dilutes as it
flows at low wind speed toward an outlying location where the complex
source will presumbably be located. For a line source (normally a highway)
the source strength (q) is normally specified in gm/sec m. The flux of a
pollutant across a line perpendicular to the v/ind at any point is:
q = flux = jT°u "X dh (1)
where u is the wind speed, "X the concentration and h. the height above
w f
the ground. If q is substituted for the source strength in Turner's
line source equation 5.18, we have
^-."«t«.
•\[3T tv. 07
p. •/ rjL\* 1
L ^ v^J J
To simplify this, assume that the wind speed is independent of height,
which brings it out of the integral sign,'and allows it to cancel the wind
speed in the denominator. Next, refer to the'sketch below, which shows
the probable height-concentration plot for a typical city-center pollutant.
The pollutant concentration should be practically uniform for the first
few tens of meters above ground level, and then decrease rapidly. To simply
the integration, this real pattern is replaced with the rectangular pattern shown,
*,«.Tl CO.'
Si
?li Ti't'vlt
OH
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I The rectangular pattern allows us to replace the Integral with
Xiround timejh,. We can also say that H 1n equation 2 1s l/2h, because
• H must represent the average emission height. Making these substitutions,
%C/X ,
and solving for §r^tmg (i.e. the downwind concentration over the city
• center concentration:
I
• To evaluate the probable values of this function, use D stability and the
G£ vs distance relation from Turner's workbook. Several values of h,
I1
have been used, to show the sensitivity of the answer to this estimated
m parameter.
The values obtained using equation 3 are shown in Table 1. Table 1
• shows that" at a distance of 1 km and further tr2 expom.-ntial term is
practically 1 so that the results ere approximately 0.797 h, /T&
m At 1 km the raMo varies from 0.25 to 0.67 for h, assumed from 10 to 30 m, etc.
IThis procedure somewhat underestimates the concentration at the
'
suburban location, because it assumes that the .source strength between the
• city center and the suburb is negligible. Therefore the results shouL
be adjusted upward to take this into account.
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TABLE 1
Computed Values According to Eq(3)
Downwind Distance
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APPENDIX II
UNAMAP
The Users Network for Applied Modeling of Air Pollution (UNAMAP)
is a system of diffusion models which can be accessed on interactive
terminals (time-share option) at the EPA regional offices as well as
the Research Triangle Park offices. Three models are presently available
on this system:
1. APRAC. This is a short-term diffusion model that calculates
the automotive contribution to carbon monoxide concentrations. The model
was developed by Stanford Research Institute (SRI). A users manual is
available on the model (120 pages).
2. HIWAY. This is a line-source model which calculates
pollutant concentrations in the vicinity of a roadway. This model is
self-documenting in that all the necessary instructions appear on the
terminal telling the user what to do next.
3. COM (Climatological Dispersion Model). This is a multiple-
source urban diffusion model. It is a refinement of AQDM, and is on-
line. A users manual will be released in the near future.
Models available for placing on UNAMAP in the near future:
1. Several point source models described in the "Workbook
of Atmospheric Dispersion Estimates" hc.ve been programmed. With a state-
ment of requirement and a modest amount cf reprogramming, they can be
placed on UNAMAP in the near future
2,, A 24-hour point source model is available but needs to be
documented and re; ^ogramme^1 before being placed on UNAMAP.
i The Real-Time Air Quality Modeling (RAM^ is a r^v,u:-
area-poi>f source model vhich is yet to be doci^ente-i. It i: c .^ididate
for UNAM/"; in 4-8 months.
4. The GEOMET multiple source, short-long term mode! -"r due for
final completion by July " 1973. This model will be compatible ,••''"
the Implementation Planning Program and, therefore, will ; ,»...'e a
source-contribution output and enable other features of the IPP model
to be operated. It is capable of being placed on UNAMAP late in
5. A photochemical model is being prepared for UNAMAP.
availability date for UNAMAP is tenuous.
An
Efforts are underway to incorporate the UNAMAP system into INFONET,
an interactive computer system contracted for by GSA. This system would
enable the models to be used by any user having access to appropriate
ADP terminal equipment.
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Appendix III - Abstracts of References Presented in June 15, 1973, Federal Register
1) Turner, D. B.; "Workbook of Atmospheric Dispersion Estimates," PHS No.
999-AP-26 (1969). Useful for estimating concentrations from point sources
(e.g., incinerators) which may be part of the complex. Also, provides
method for estimating area source concentrations.
(2) US EPA; "Compilation of Air Pollutant Emission Factors," GAP No. AP-42
(Feb. 1972). Useful for determining emissions from mobile and stationary
sources, given operating characteristics of the sources.
(3) Briggs, G.A.; "Plume Rise"; TID-25075 (1969), Clearinghouse for Federal
Scientific and Technical Information, Springfield, Va. 22151. Useful to
compute the effective plume height of point source effluents. This is
needed to estimate ground level concentrations from point sources.
'4) Mancuso, R. L.; and Ludwig, F. L.; "Users Manual for the APRAC-1A Urban
Diffusion Model Computer Program," "Stanford Research Institute Report"
prepared for EPA under contract. CPA 3-68 (1-69) (Sept. 1972). Available
at Clearinghouse for Federal Scientific and Technical Information, Spring-
field, Va. 22151. Model which presents -methods for computing CO concentrations.
Can be adapted to estimate CO concentrations in urban street canyons.
(5) Zimmerman, J. R., and Thompson, R. S.; "User's Guide for HIWAY," paper
under preparation, Met. Lab., EPA, RTP, N. C. Self-documenting model which
can be used to compute CO concentrations in the vicinity of at-grade highways.
(6) USGRA: "Proceedings of Symposium on Multi-Source Urban Diffusion Models,"
OAP Publication No. AP-86 (1970). General reference presenting various approaches
to estimating pollutant concentrations. Discusses how to model various types
of sources and the information needed for various models.
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(7) Air Quality Implementation Planning Program, Volume I, Operators Manual,
PB 198-299 (1970). Clearinghouse for Federal Scientific and Technical
I Information, Springfield, Va. 22151. Multi-source urban diffusion model
suitable for predicting long-term (monthly, annual) average concentrations.
• Also estimates costs associated with various strategies of emission controls.
| (8) Hanna, S. R.; "Simple Methods of Calculating Dispersion from Urban Area
m Sources," paper presented at Conference on Air Pollution Meteorology, Raleigh,
N. C. (April 1971). Available at Clearinghouse for Federal Scientific and
• Technical Information, Springfield, Va. 22151. Method which may be used to
compute concentrations resulting from area sources.
I
. (9) ASME: "Recommended Guide for the Prediction of Dispersion of Airborne
J Effluents," United Engineering Center, 345 E. 47th Street, New York, New
_ York 10017 (1968). General treatment discussing the impact of several
™ meteorological phenomena on pollutant Dispersion and methods of calculating
• peak ficen^rat :r, resultir" from these phenomena.
m (10) Slade, D. H. (editor): "Meteorology and Atomic Energy 1968, ,^.rc (1968).
A general reference presenting meteorological and diffusion theory fundamen-
• tals which can be used to ^>timate pollutant-dispersion. Avail at .;: flD-
24190 from Clearinghouse for Federal Scientific and Technical Information,
National Bureau of Standards, U. S. Department of Commerce, Springf.v. , VA
22151.
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TAB B - Technique for Predicting On-Site Air Quality at Complex Sources
This recommended technique requires that one estimate what the maximum impact of
d proposed complex may be over a 1-hour and 8-hour period at a sensitive receptor under un-
favorable meteorological conditions. Meteorological assumptions used in the analysis are
Class D atmospheric stability with a steady wind speed of 1 m/sec from a direction placing
the receptor in such a position to sustain the maximum impact of CO emissions. The recommen-
ded technique requires that the impact of four different types of emissions be assessed
on 1-hour and 8-hour CO concentrations. These concentrations result from:
(1) General background concentrations from sources in the environs of the pro-
posed complex;
(2) concentrations from large point source emissions of CO which would occur
within the proposed complex;
(3) concentrations from sources which are immediately adjacent to the sensitive
receptor, and
(4) concentrations resulting from sources within the complex which are not
immediately adjacent to the sensitive receptor.
An 8 step procedure used to estimate the maximum impact of a proposed complex on 1-hour
and 8-hour CO concentrations. Some of the salient features of this procedure are discussed
in more detail in accompanying enclosure 2. In this procedure, it is assumed that the maxi-
mum impact of the complex will be exhibited at a roadside receptor within or'immediately
adjacent to the complex.
Step 1: Compute Peak Background Concentrations
(a) Require developers of major complexes to rr.nitor CO concentrations at the site
of the proposed complex in a sufficient mannp" to obtain a statistically valid sample.
(b) If it is conrr'c? -eH Impractical to require the developer of a given complex
to monitor CO concentrations, utilize previous observations at tlr? most appropriate loca-
tion to estimate 1-hour and 8-hour CO concentrations. (See Appendix 1 of Tab A)
(c) If neither (a) nor (b) is possible, it-would be necessary for the appropriate
control agency to obtain enough CO measurements to form a statistically valid sample from
which to compute peak background concentrations of CO;"
Step 2: Convert Peak Background Concentrations to an Equivalent Emission
Intensity within the Proposed Complex
Use Figure 1, plotting isoconcentration lines on a graph of source intensity vs.
the complexes' dimension directly upwind from the receptor, and move to the right until
reaching the isoconcentration lines corresponding to those obtained in Step 1 for 1-hour
and 8-hour concentrations. Note the corresponding emission intensities on the abscissa,
Q. . These represent the uniform emission intensities within the complex which would
result in the predicted background concentrations at the receptor under the assumed
meteorological conditions. Figure 1 was derived using a technique similar to one used
by Hanna.^
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Step 3: Estimate Maximum Ground Level Concentration of CO from
Any Large Stationary Point Source of CO Whjch Would be A PartTof
the Complex"
Since large stationary point sources of CO are relatively
unimportant compared to automotive sources, this step and Step 4 could
be skipped frequently. The concentration of CO at the chosen receptor
resulting from a point source which would be part of the proposed complex
should be estimated using Figure 3-5D in the Workbook of Atmospheric
•Dispersion Estimates (PHS Publication 999-AP-26)3. The concentration at
the receptor would be obtained from the xu value resulting from use of
this figure by dividing this value by a "u" of 1 m/sec and multiplying
the peak average emission rate considered likely for the point source
over 8-hour and 1-hour periods.
Step 4: Convert Concentration Estimated from Point Sources to
Equivalent Emission Intensity within the Proposed Complex
This is done using a procedure identical with that described
in Step 2. The result is an equivalent emission intensity Q .
Step 5: Estimate the Concentration at the Chosen Receptor Resulting
From Sources in the Imedia.lL* V 1 c ini ty of the Receptor
Since it is assumed that the maximum impact of the proposed
complex occurs oeside rc.ui, or traffic lanes which will be located within
or ? .\,want to the proposed complex, a line source model fi'T^-v^ ^s
been u.sed to derive Ficure 2 which relates concentration t -~f?ir flow
wht.n ti^ wind blows at /arious angles to the roadway. E* ler F'v-ire 2
on tiit abscissa corresponding to the. estimated peak traffic Vad for
8-hour and 1-hour periods and read the resulting concentration on the
ordinate corresponding to the wind angle giving the highest o : t -tion
A more detailed description of how to use Figure 2 is gi\en in the
examples in Enclosure 1.
Step 6 : Convert Concentrations, Estimated from Nearby Sourc^ o
Intensity within the Proposed Complex """""
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This is done using a procedure identical with that described
in Step 2. The result is an equivalent emission intensity Qn.
Step 7: Determine the Emission Intensity within the Propo^ed^Complex
Corresponding with the 8-Hour and 1-Hour NAAQS
Using Figure 1, follow the appropriate isoconcentra^.v/a line
(9 ppm for 8-hour NAAQS, and 35 ppm for 1-hour NAAQS) until the ordinate
corresponding to the proposed complexes' longest dimension i., reached.
Note the corresponding emission density,
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Step 8: Determine Allowable Emission Intensity within the Complex
and Compare this with the Estimated Emission Intensity
The allowable emission Intensity 1s determined by subtracting
the emission intensities obtained in Steps 2, 4 and 6 from the intensity
obtained in Step 8.
CALLOW " ^std " % ' QP - Qn
CALLOW 1S t^ien comParecI w^n tne emission intensity estimated for the
complex a priori. Suggestions how to make such estimates have already
been supplied to Mr. John Fink for shopping centers and sports complexes
in letters dated March 29 and April 3. Suggestions on how to estimate
the intensities for other complex sources will be supplied in Enclosure 2.
If the proposed complexes' estimated emission intensities exceed
CALLOW or some sPeclfied fraction thereof, provision must be made for
a detailed Environmental Impact Statement in which various design alter-
natives and site locations should be considered.
Edwin L. Meyer, Jr
Engineer
M< . , Application Section
Source Receptor Analysis Branch
Enclosures
(1) Examples of the Fvaluation Technique
(2) Salient Features of the Proposed Technique
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References
1. Larsen, R.I., "A Mathematical Model for Relating Air Quality
Measurements to Air Quality Standards" OAP Publication No. AP-89,
(Nov. 71).
2. Hanna, S.R., "A Simple Method of Calculating Dispersion from Urban
Area Sources" JAPCA 21 pp. Tl 4-777, (1971).
3. Turner, D.B., "Workbook of Atmospheric Diffusion Estimates", USPHS
Publication No. AP-26, (1971).
4. Zimmerman, J.R. and Thompson, R.S., "Users Guide for HIWAY", paper
under preparation, Met. Lab., EPA, RTP, N.C.
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Enclosure 1
Examples Illustrating the Proposed Technique for Evaluating the
Direct Impact of Complex Sources on Air Quality
Example 1. Problem: A housing complex containing 500 living units
is proposed for an area whose peak background concentrations have
been observed to be 11 ppm over a 1-hr, period and 3 ppm over an
8-hour period. It is assumed that the peak concentrations will occur
at a roadside within the proposed complex located as shown. Traffic
on this road is estimated at 300 vph for 1-hr, and 100 vph for 8-hrs.
The dimensions of the complex are also pictured below. There are
no significant point sources of CO contemplated within the complex.
Required: What is the estimated emis.sion density for the complex
above which a detailed EIS and perhaps some re-design may be required?
Solution:_
0) C, , = 11 ppm; p =3 ppm; upwind dimension = 2 km
1-hr ''3-hr
(2) Using Fig. 1, for 1-hr.,
Q. = 1.49 x 10-4 gm/sec-mz
for 8-hr
4.05 x 10 gm/sec-m
(3)-(4) Since there are no large point sources of CO planned
within the complex, Q = 0
\
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(5) Using the 10° wind angle in Fig. 2,
For 1-hr.
C-j = 6.0 ppm
For 8-hr.
Cgc= 1.9 ppm
(6) Frort Fig. 1 ,
For 1-hr., Qn = 8.4 x 10"5 gm/sec-m2
5 ?
For 8-hr., Qn = 2.6x 10 gm/sec-m
(7) For 1-hn, Q = 4.0 x 10" gm/sec-m2
For 8-nr-»Qst(j = 1-1 x 10 gm/sec-m2
(8) For 1-hr.
Qal1ow = 4'° x 10~4 - 1-49 x 10"4 - 0 - * ]Q"5
1-hr. Qar,ow = 1.57 x in"4 gm/sec ?
For 8-hr
Qallow = f 1 x "3"" - 4.05 x 10" J - 0 - 2,6 x 10"b
8-hr. Qallow =4.35 x 10"5 gm/sec-m2
Hence, if the estimated peak 1-hr, emission density for the
complex exceeds 1.67 x 10-4 nn/sec-m^ or the estimated peak 8-hr.
emission density exceeds 4.35 x 10-5 gm/sec-m , a detailed
environmental impact study should be required for the complex
and redesign or relocation may be necessary.
Example 2
Problem: A shopping center is proposed in an area in which 6
ppm and 2 ppm peak 1-hr, and 8-hr, concentrations have been observed.
There are no large noint sources of CO contemplated within the center.
Maximum impact is assumed to occur at residences across the street
from the main entrance to the proposed center. Maximum traffic at
the center's major entrance (road 1) is 300 vph over 1-hr, and 100 vph
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over 8 hrs. Traffic on the adjacent highway (road 2) is estimated
as 1000 vph and 300 vph for 1 and 8-hr.
periods respectively. The
dimensions of the proposed shopping center are as shown.
70 v /"i "*
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1°W
^ cp
©*
Requirement:
^
What is the estimated emission density for the complex above which
a detailed EIS and perhaps some alterations may be required?
Solution:
(1) c, . "= 6 ppm; Cp = 2 ppm
1 hr. o
(2) Using Fig. 1 with an ordinate of 500
,
m,
For 1-hr., Qb = 1.38 x 1C"4 gm/sec-m2
For 8-hr., Q. = 4.6 x 10"5 gm/sec-m2
D
(3) - (4; Qp = 0
.
(5) Maximum concentrations resulting at R-from nearby sources
occur when the wind inakes an angle of 0° with road 1 and 90°
with road 2. Using Fig. 2,
For 1-hr,
C- =(4.25 ppiplad + (7.6 ppm)
1 7
For 8-hr. ,
=11.9 ppm
C8 = 0.5 ppm)road+ (2.3 PPm)road = 3.8 ppm
(6) Using Fig. 1 with an ordinate of 500
For 1-hr., Qn = 2.8 x 10"4 gm/sec-m2
m,
For 8-hr., Qn = 1.90 x lo"5 gm/sec-m2
.
-------
(7) Using Fig. 1, for an ordinate of 700 m
-4 2
For 1-hr., Qstc| = 7.4 x 10 gm/sec-m
-4 2
For 8-hr., Qst(J = 1.9 x 10 gm/sec-m
(8) From Fig. 1,
For 1-hr., Qflllow „ 7>4>x 10-4_1>38xl(r4 _ Q m 2>8 x 1Q-4
Callow = 3.22 x 10"4 gm/sec-m2
For arhr., Q 1>g x 1Q-4 _ 4^ x 1Q-5
Qallow =T- 08 x 10"5 gm/sec-m2
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Enclosure 2
Features of the Proposed Technique to Estimate the Impact of
Complex Sources on Mr Quality
There are a number of assumptions which are made or implied
by the proposed technique for estimating the impact of a complex source
on air quality. Most of these assumptions are conservative ones, and
the end result is a technique which gives a conservative estimate of
the complexe's immediate impact. These assumptions and the rationale
behind them are listed below. Assumptions which are believed to be
conservative are so indicated.
Meteorological assumptions: Class D atmospheric stability,
steady wind of Im/sec and unlimited mixing depth. As a re-
sult of the types of surfaces likely to be encountered in
areas where complexes would be developed, and the mechanical
turbulence generated by vehicles as well as the heat of their
discharges, Class D stability was regarded as the most stable
atmospheric conditions likely to persist during periods when
the impact of traffic generated by the complex was likely to
be greatest. A steady wind of Im/sec is a conservative
assumption, since speeds this low are unlikely to persist
from a single direction (and the direction maximizing the
impact of the complex, at that) for 8, or even 1, hours.
. Assumptions about mixing depth r.re >"obably only important
for estimating background concentrations. Since the technique
eii^r util-'~°s observations directly to estimate background
cor --,'.-.,,. i or es i 'nates background concentrations using
? . "i^TCcH model based, on observations, the effect of
1 ,!>.d „ xing depth is felt to be inherency acco*- ,. c ;
7h .ssurnption, inhe^nt in the technique, that the
(•• iq qg) background concentration, point source centerl ?ne
conctenf ration and maximum contribution from immediately
ad:
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The model upon which Figure 1 (used in Steps 2,4,6 and 7) is based
ignores "edge effects." A more complete analysis could not
necessarily do this. The procedure used in the recommended
technique is justified on the basis that the most severe
impact of the complex will most likely occur at a section
where the edge effects are of minor importance.
The rationale behind Steps 2, 4, 6 and 7 is that CO con-
centrations at the chosen receptor site resulting from
background sources, proposed point sources within the comolex
and sources in the immediate vicinity of the receptor
diminish the emission density which would be allowable from
the proposed complex.
Use of Fig. 3-5D i> the Workbook requires one to first
estimate the effective plume height for the point source.
This requires knowledge of certain operating parameters for
the source which may not be available. Under the meteorological
assumptions assumed with the recommended technique, an
assumption that the effective plume height is twice the physical
stack height would seem reasonable. Such an assumption depends
on the relatively large plume rise resulting with low wind
speeds being compensated for by the low temperature of effluents
likely to result.from stat-.-nary sources of CO.
In constructing Figure 2, needed in S X it was necessary
to use emi?s~:on factors to relate ';rafi ic count to CO emissions.
OAP Publicr' -n !"o. "'M9, "CcT-iiation of Air Pollutant
Emission Fu.ors,' ^Keb. '72; wa* used for this purpose. A
number of u^., jmp". sons were made to derive the emission factors:
(•u; o-'C mix of vehicles—seamed reasonable in view
of the fact that these guidelines are to be applied
to proposed rather than existing complexes;
r' '
(b) urban travel conditions
(c) average vehicle speed 5 mph--it was assumed that the
maximum impact would either occur at an exit to the
complex wher^ traffic was moving very slowly, or at
a traffic signal within or adjacent to a complex.
In constructing Fig. 2 by using the HIVIAY model, a road
length of 200m was assumed in order to be conservative. This
means that a vehicle as far as 200m from the receptor could
contribute slightly to the CO concentration estimated at the
receptor—particularly when the wind angle with the road centerline
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1
is a small one. While vehicles distant from the receptor
make a disproportionately small contribution to the receptor
(.i.e. concentrations resulting from a zero degree wind angle
with a road 100 m long would be much greater than 1/2 those
from a road 200 m long) this assumption may be unduly con-
servative. If experience proves this to be the case, Fiaure
2 could be easily based oji a shorter road segment and redrawn.
Requiring one to use the ordinate in Figure 1 corresponding
to the complexe's longest dimension in Step 7 is not entirely
consistent with Steps 2, 4 and 6 where the ordinate used deoends
on the^orientation of the source and receptor with respect to
the critical wind direction. Step 7 is conservative and also
simplifies the process of evaluation.
Step 8 assumes that an emission intensity has been estimated
a priori for the complex source being evaluated. In order to
be complete, guidelines should suggest ways in which this could
be done. It would seem desirable to require the developer to
provide the States or Regional Offices with a few key design
parameters which could then be used by the States or Regions to
derive estimates for maximum emission intensity likely to occur
over 1-hour and 8-hour periods. Table 1 includes several complex
sources, key parameters which should be supplied by developers
and assumptions wh'ich would have to be inade by State and/or
Regional personnel in estimating emi io,. intensities.
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TAB C - Technique for estimating sizes of facilities subject to review
For estimating the size of a parking lot for a particular facility, above
which will result in a local violation of the carbon monoxide standard, assumptions
must be made concerning the behavior of motor vehicles in that parking lot under
estimated worst conditions. One refernce on parking lot design* gives dimensions
of parking spaces. A parking unit is defined as two parking stalls plus an aisle.
For parking stalls at 90° to the aisle, the maximum dimensions for the unit is 65
feet by 10 feet, for a two-way aisle. This amounts to a space requirement of 650
ft2/2 stalls = 325 ft2/stall.
Automobile behavior in a parking lot can be assumed, although if such behavior
is fenown, the more valid information should be used. Assuming for a worst-case
example that vehicles travel an average of five miles per hour in the lot (which
includes the time they are idling) and the travel is of an urban (stop-and-go)
ther than a rural (more or less steady ee:,) type, Compilation of Air Pollution
Factors** yields an emission facto- jf 60 g CO/vehicle-mile for a 1975 distribution
of automou'... c,jeancjan (extrapolated), speed adjustment factor of 3.0. Therefore,
the emission rate, Q, is:
Q = /bOgCO ^/LEJJes.) /3 0\ - 900 9 CO
\vehicle mi1e/\ hour / c * vchi-c-le hours
Assumptions concerning the behavior of motor vehicles in a parking lot will
depend upon the type o£ facility and the intensity of use over a time p«_-; J. The
following examples are intended to illustrate the types of assumptions necessary to
make determinations concerning air quality and size of a parking lot', since these
assumptions may not be valid, an attempt should be made to acquire more accurate
information. Furthermore, the examples assume zero background CO cora.entrctions.
|KParking in the City Center, prepared by Wilbur Smith and Associates, New Haven,
Connecticut, under commission from the Automobile Manufacturers Association, May 196!
I**Cornpilat,On of Air Pollutant Emission Factors (Revised), U.S. Environmental Pro-
tection Agency, Office of Air Programs, Research Triangle Park, N. C., February 1972
r\ i. ^ •_.«•- *. « •-<• -«
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"or particular areas, compensation should be made for existing air quality.
(1) Parking lots for shopping centers, commercial and industrial developments.
amusement parks, and recreational areas
Activity in terms of trips generated in these facilities will probably be
spread out over an 8-12 hour period, with a peak-to-off-peak hour ratio of
perhaps 2 to 4. Two worst condition analyses will be necessary—one for the
worst peak hour and one for the worst 8-hour period, to determine which standard
(the one-hour standard of 35 ppm or the eight-hour standard of 9 ppm) will be
the limiting standard for the maximum parking area.
(a) Worst peak hour
An estimate must be made of-the number of vehicles running in the
parking lot at any one time during the worst peak hour. For purposes of
illustration, assume that the parking lot contains one vehicle per each
stall (full lot) and that of these , 10 : e; are operating at any
one time. The £missio density, E ;s then calculated as follows:
2
: .t.^g CO. v, /I hr. \/l stalls/I vehicles/10.8 fr
"1-hr . .rYn'^e-hr
= 8.31 x 10"4 g CO/sec-m2
If we assume a constant wind speed of 1 m/sec and constant wind direction
with class "D" atmospheric stability, the graphical relationship given in
Figure 1 of Appendix 0 of 40 CFR Part 51 can be used to determine the
maximum parking area, To achieve a downwind edge concentration of less
than 35 ppm, the area must be no longer than approximately 520 meters on
a side, which corresponds to a square area of approximately 67 acres.
(b) Worst 8-hour
For illustrative purposes, assume that for 8 hours, there are only
three-fourths the number of vehicles as parking stalls and that only 4
percent of these vehicles are operating at any one tiine over the 8 hour
period. The 8-hour emission density, E, is calculated as follows:
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I c /900 g CO \/I hr \/I stall \/0.75 vehicle!/I0.8 ft2) . n„.
™ L8-hr =^yehicle-hr/U600 sec./(.325 Ft^/C 1 stall /IT^2/ (U<04)
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• = 2.49 x 10"4 g CO/sec-m2
From Figure 1 in Appendix 0, to achieve a downwind edge concentration of
I less than 9 ppm (8-hour standard), the lot area must be no longer than
approximately 400 meters on a side, which corresponds to a square area
• of approximately 40 acres.
| Therefore, under the assumptions made above, CO standard would be
£ the 8-hour standard, since the above calculations yielded a smaller area
for the 8-hour condition than for the one-hour condition.
I
2. Parking lots for sports stadiums, and centers which cater to affairs
• in which patrons leave at one time.
£ Maximum mobile source activity from these facilities will probably occur
over a short time period, perhaps an hou,- ur less. Assume, for example, that
8 the parking lot i.- f.,'1 and th>it 15 percent of the vehicles are running at any
one time. The one-hour emission density, E, is then calculated f.', ,,'ws:
I 2
F -/900 9 CO \/l hr )/l stall I/I vehic1e)/10.8 ft.) , 1O '
" "(vehicle-hrA3600 sec/(325 fWX 1 stall J( "m2 "/' ^'l^)
= 1.25 x 10"3 g CO/sec-m2
I From Figure 1 in Appendix 0, to achieve a downwind edge concentration f
less than 35 ppm (1-hour standard), the parking area must be no longer than
I
approximately 260 meters on a side, which corresponds to a square area of
approximately 17 acres.
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Figure 1
COMPLEX SOURCE TIME SCHEDULE
1973
1. U.S. COURT OF APPEALS - DECISION
NRDC v. EPA
2. EPA MET WITH NRDC
PETITION THE COURT - ESTABLISHED
A TIME SCHEDULE FOR ACTIONS
3. DISAPPROVAL OF SIP
4. PROPOSED REGULATIONS FEDERAL REGISTER
5. COMMENTS ON PROPOSED REGULATIONS
6. COMPLEX SOURCE REGULATIONS
»
7. STATE IMPLEMENTATION PLANS
8. APPROVAL/DISAPPROVAL NOTICES AND PLAN PROPOSALS
9. PUBLIC HEARINGS ON PROMULGATION
10. REGIONAL FINDINGS TO CPDD
11. COMPLETION OF FEDER, L REGISTER PROMULGATION
PACKAGE
12. FINAL PROMULGATION
JANUARY 31
MID FEBRUARY
MARCH 8
APRIL 18
MAY 18
JUNE 18
AUGUST 15
OCTOBER 15
NOVEMBER 15-20
NOVEMBER 27
DECEMBER 10
DECEMBER 15
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TAB 0
Applicant submits application
for approval to construct
3 days
Agency returns
application with reasons
Agency advertises
immediate availability
of application and
later availability of
analysis - comments
solicited
I
gency grants
ermit to
onstruct
approv a]
I
I
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quality impact
10 days
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on approval
Agency makes
analysis and
proposed deci-
sion avai iable
30 days
Agency considers
comments - revises
analysis and/or
decision
5 days
decision
on
application
I
Agency notifies EPA
and other air pollution
control agencies in
region
disapproval
Agency informs i
applicant of j
decision and !
states reasons '
conditional
approval
Agency grants
conditional
permit
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I
.; • .-..." ...'• •;-:•. V •>./;'.' ..'. .TITLE 40 -. PROTECTION. OF ENVIRONMENT ' '••-• •-.,.'• '
•• . .... ... .. -. •• .. •-..- ....-..-•- ..-•..'. . • ,...-. • • ;.-•:•-•.
. --..-{.-• • .:--v .1.. Chapter I - Environmental Protection Agency •'-•• • •-. . '
' ' M ' "" ; -
• . .:.,.../.-• -Subchapter C - Air Programs . • -• •
•I—.. .;' """/••..-•••.
. -' . ,. . .-.Part 51..- Preparation, Adopt-ion, and Submittal of Implementation Plans
I Maintenance of National Ambient Air Quality Standards
• On August 14, 1971 (36 FR 15486),- the Administrator of the Environmental
• Protection Agency promulgated as 42 CFR Part 420 regulations for the prepara-
g tion, adoption, and submittal of State Implementation Plans under section 110
m-~-~] ' °f tne clean Air Act> as amended. These regulations v/ere republished
• ' November 25, 1971 (36 FR 22369), as 40 CFR Part 51.
• On April 18/1973 (38 FR 9599), the Administrator proposed amendments
to those regulations- designed primarily to expand the scope of review
'| prior to construction or modification of b ' ;ngs, facilities, and instal-
H lations so as to require consideration of the air quality impact not onlv
.of ,pollutan:r , ttn:' Jirectly from stationary sources (consideration of
I'
. .which was already required by ,J CFR ^1) but also of pollution ans,.-;
. from mobile sous ce activity associated with such buildings, fad ": '"it
I"
and installations. The proposed »mendments were, and still an, ^cnsiderea
• - ' .a necessary addition to the Federal -Slate system for implementing, and Torp
particularly, for maintaining, the national ambient air quality standards.
J . In the preamble to the proposed amendments, the Administrator called
••. - attention to the importance of analyzing the general growth of population,
•.."•• industrial activity, and mobile sources in relation to regional air
ft "• quality. The Administrator did not propose to require such ana'ysi-,
• .';.; . .but urged that States consider t!r use of such procedures A nunier of
I comments were received urging that such analysis be required on the ground
I
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..' that preconstruction review of individual sources could not adequately deal
with' generalized growth and its impact on regional air quality. It
1s the Administrator's judgment that such procedures, in addition to
- • • •'••.*. , * -
review of new or modified sources, are necessary to ensure maintenance of
the national standards, particularly because source-by-source analysis
is not an adequate means of evaluating, on a regional scale, the air
quality impact of growth and development. Consequently, the regulation
•\promulgated below includes the following additional requirements:
\^
1. Within nine months, States must identify those areas (counties,
urbanized areas, Standard Metropolitan Statistical Areas, etc.) which, due
to current air quality and/or projected growth rate, may have the potential
\
.for exceeding any national standard within the next ten-year period.
. \
• 2. Based on this information submitted by States, the Administrator
wiii jjuuiisii ci i iil ui putencidi piobieiu dror /ii.di will ue arialyzeu in
••.more detail by the ^tates; interested Persons will, have an opportunity to
comment on the pi;1^ 3hed list. . .
3. Within 24 ironths of the date of promulgation of these regulations,
States must submit an analysis of the impact on air quality of projected
'» »
growth in each potential problem area designated by the Administrator.
*- •
Where necessary, plans must also be submitted describing the measures that
will be taken to ensure maintenance of the national standards during the
ensuing ten-year period.
The required analysis will have to deal with all the significant
air quality imp!ications of growth and development, including not only
the increased air pollution arising directly from new commercial, industrial,
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I
•',... ...,-,- . v • . . 3
|" ' .'"",.and residential development but also that arising from increases in demand
': '' 'for electricity and heat, motor vehicle traffic, and production of solid
™ . waste. ;..'.. • i
. • ' ' . f
• •••••..• ^^ The'above considerations must be reanalyzed at five-year intervals.
Individual source review generally is more practicable and meaningful
I- '
with respect, to the localized impact of a single source. Furthermore,
• : for pollutants such as hydrocarbons and nitric oxide, which affect air
quality through complex atmospheric reactions resulting in the formation
•• of photochemical oxidants and nitrogen dioxide, analytical tools that can
be used with confidence to "predict the air quality impact of a single source
I '
• are not now availably.
• •. As a result of the comments received, a number of additional changes
have been made to the proposed amendments. The changes, described below,
H a i i cut c:ir > •/1 i-mcn i.ai. i un p i on uMuviiiuns mii-Cil I>tate3 miti nave Co SuuiuiC
™ . . . . it ^,.
_ • • 'by August (5, li*/3, in response to that portion of these renulatiors which
prescribes new and modified source review procedures.
I 1. Where the State designates a governmenta1 agency other : • T
air pollution control agency to carry, out the new source review procedures,
• that agency is required to consult with th-e State air pollution control agency
• prior to rendering its decision. This requirement will assure proper
coordination regarding air pollution matters and appropriate use of existing
I technical expertise. ' • :
2. State plans must describe the basis for determining whirh fncililies
• will be subject to the new source review procedures.
13. State plans must describe the administrative procedures to be
* "
used in implementing the new source review requirements.
I
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• ' • . • • ' • • . . • . 4 ':/''• '•'•.'••'••.•
...'. 4. In States where the specified 30-day period for submittal of
j
public comment conflicts with existing legal requirements for acting
. on requests for permission to "construct or modify, the State may submit
i
for approval a comment period which is consistent with the existing
' \
requirements. • . . •
5. The agency responsible for new source review must notify all
State and local air pollution control agencies with jurisdiction
'within an air quality control region whenever it receives a request
for permission to construct or modify a facility within the region.
This requirement is intended to ensure that such agencies have
. V
adequate opportunity-to comment on a proposed source which is to
be located in another jurisdiction but may affect air quality ^
' in their own jurisdiction. " ...
u. IMC awyytra c'li^.ta y i c v'i OliS ij Hlvi uucU ' in nppcnuiX u n I ui ics^cCt tu
sizes of facilities to oe covered by new source review procedures have been
replaced by a description of a more objective technique which States can
use in making this determination.
Several comments were received which questioned whether EPA has
legal authority to promulgate requirements for review of the indirect
impact of new or modified sources, i.e., the impact arising from associated
mobile source activity. Essentially, the argument was made that EPA's
authority in this regard is limited to requiring an assessment of the air
quality impact of pollutants emitted directly from stationary sources.
EPA believes that this argument is inconsistent with the provisions
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I
J •-. " • .of section 110(a)(2)(D), which requires that'lmplementation plans Include
_,. j... • . V. ..such other measures as may be necessary to Insure attainment and
™ • maintenance of such primary and. secondary standard, Including, but
, »
• '; . -.. . not limited to, land-use and transportation controls." In the
Administrator's judgment, review of the indirect impact of new. or
I modified sources is just as necessary to ensure maintenance of the
• national standards as is review of the direct impact.
A number of comments were received suggesting that the
• • Admini-strator specify or otherwise limit the responsibility for the
" new source review/approval procedure to certain types of governmental
I '
• • agencies (e.g., only the State or only an air pollution control agency).
• • The changes discussed above are designed 1 , oart, to ensure proper
• coordination of, and input from, all appropriate agencies. It is the
1 - ' Administrator's judgment that :he requirement .for consultation with
v' - —
».'.'-. cognizant ai, pollution control agencies is adequate to ensi^"
appropriate consideration of air quality in those ca?e? where ~e \tate
I or local decision-making agency is not itself an air pollution T:;'. :
agency.
I A number of air pollution control agencies suggested that
• the public coimient requirements would impose an unnecessary burden,
since it will involve the public in what they characterized as largely
I a technical judgment. Other groups requested that public participation
be expanded to include opportunity for a public hearing, not j<>st -'^:
• opportunity to_submit written comments. In the Administrator's judgment,
• . the proposed requirement for public comment represented a reasonable
•* "
I
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6 ' ., '
« t
b.alance between these conflicting positions and was consistent with
the emphasis in the Act on public participation in developing and
carrying out the implementation plans. Accordingly, it is not being ;
modified. •
There were a number of suggestions as to the factors, other than the
impact of mobile source activity, that should be examined during the new
source review process, including:
1. The "displaced" stationary source emissions resulting from the
•_, operation of a new facility (e.g., the load a facility places
on existing power plants and incinerators).
2, The construction phase of a facility.
3. Whether the facility itself may, in effect, create a new
receptor point where air quality .standards mast be attained and
maintained (e.g,s it Duiiding constructed over a Treeway or in an
area impacted by an existing stactc plume).
4. Whether :i iacinly shpuld be allowed to "use up" the entire
*
air resource in a given area.
The Administrator believes that 'it is neither necessary nor practicable
to specify in detail the possible considerations which States must examine
in reviewing new facilities. In general, States should consider air
pollution aspects of a new facility which are not adequately covered by
other provisions in the implementation plan. For example, existing
nuisance and fugitive regulations may be adequate to deal with the construction
phase of a facility. "Displaced" stationary source emissions are much more
significant as a by-product of general growth and development, and should be
assessed in that context, rather than in relation to any individual source.
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I
If. .'• : ,; v~ T'
• ' _ Finally, it would seem prudent for a State to avoid a situation whero a
_ , source would "use up" the entire air resource in an area; however, the
•c
• •; .Administrator cannot require that States allocate their air resources in
M \ any given manner.
I
One comment suggested that the Administrator require that States
adopt procedures to implement the authority required under 40 CFR 51.11 (a]
\
\ (4) to prevent operation of a new or existing source which intereferes v/i-
\ attainment or maintenance of a national standard. Under 40 CFR 51.11(a)(2
I.
States already are required to have legal authority to enforce their implc
mentation plans, including'authority to seek injunctive relief. Further-
I \
• more, where an implementation plan is substantially inadsquate to attain
I- • and maintain a national standard, it -t be revised. Accordingly, it is
\
EPA's position that it is not necessary.to require States to adopt additi:
1.1 • procedi. ••-'- for preventing the operation,ot sources.
• '-. . it, is emphasized th"t these regulations are not in!c^ ,'<. .;,d should
| '. not be construed, to mean that the only choices "pen t~ c-tatt and local
Ij agencies are to approve o^ disapprove construction or rodifii i , I .'her;
|
i a facility can be designed and/.or located so as to be compatible with mii:
If
•; nance of national sUndards'or provtded with services, e.g., mass ^ansit:
j - * / * i
Ij that will make it compatible, States and local agencies, as well as facil:
I
o.vnors' and operators, should explore such possibilities.
I.;
'! \ EPA, through its Regional Offices, will provide assistance to -"-.o
1 * i
States in: '
I -
i
; 1. Detenriining types -••nc' sizes of sources v/hich should be subject
•' ' to the nev/ source review procedures;
•I! .. ' "
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8
2. Developing the technical procedures to be used in analzying the
air quality impact of individual sources;
3. Identifying areas which may exceed a national standard within the
next ten years; and
i
•4. Analyzing the impact of general growth and development in such
problem areas.
These amendments are being promulgated pursuant to an order of the
United States Court of Appeals for the District of Columbia Circuit in the
case of Natural Pxesources Defense Council, Inc., et al. v. EPA, case No.
72-1522, and seven related cases, which order was entered January 31, 1973,
and modified February 12, 1973. States will be required to submit their
plan revisions to comply with these new requirements involving new source
'review procedures no later than August 15, 1973. After such submission, the
Environmental Protection Agency will ha-vt' two'liibnths to review and approve
or disapprove the pensions and an additional two months to propose and pro-
mulgate regulations to replace any disapproved State procedures. As discussed
above, the identification of potential problem areas must be submitted within
12 months and the detailed analysis and plan dealing with these problem areas
are due within 24 months of the date of promulgation of these regulations.
These amendments to Part 51 of Chapter I, Title 40, are effective
upon publication.
Authority: Sections 110 and 301(a) of the Clean Air Act, as amended
(42 U.S.C. 1857C-5, 1857g(a)). -
Dated
Administrator
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I
1 . •: 7 .
i» i * »
I • Part 51 of Chapter I, Title 40-of the Code of Federal Regulations is
• amended as follows:
1. In s 51.1, paragraphs (f) and (g) are revised to read as
• ' follows:
1 51.1 Definitions.
I * * * * *
• (f) "Owner or operator" means any person who owns, leases, operates, controls,
or supervises a facility, building, structure, or installation which
g directly or indirectly results or may result in emissions of any
air pollutant for whjch a national standard is in effect.
•' * * * * *
• (g) "Local agency" means any local governp^it agency, other than the State
agency, which is charged with the responsibility for carrying out a portion
of a plan.
vr"
| 2. In 151,5, paragraph (a)(3)is a^ded as follows:
151.5 Subnrisr-'on of plans; pro1 '-in* nary review of plans.
I (a) * * *
• (3) For compl-;?rc^ with the requirements of ss51 .11 (a)(4) and r"M
later than August 15, 1973.
| 3. In I 51.11, paragraph (a) (4) is revised to read as follows:
— I 51. 11 Legal authority.
• (a) * * *
• (4) Prevent construction, modification, or operation of a facility,
building, structure, or" installation, or combination thereof, which '
| directly or indirectly results or may result in emissions of any air"
-* ' f
pollutant at any location which will prevent the attainment or mainte-
•
p$ no
nancp of * n.-ifi r,r,->i ^.,--1 —
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10 . f
4. In £ 51.12, paragraphs (e), (f.), (g) and'(h) are added ar follows:
I 51.12 Control strategy: General
* * * * *
(e) The plan shall identify those areas (counties, urbanized areas, Standard
Metropolitan Statistical Areas, etc.) which, due to current air quality and/or
projected growth rate, may have the potential for exceeding any national standard
within the subsequent ten-year period.
•
(1) For each such area identified, the plan shall generally describe
ttie intended method and timing for producing the analysis and plan
required by paragraph (g).
(2) The area identification and description of method and timing
required by this paragraph shall be submitted no later than nine
months foil owing the effective date .of this paragraph.
(3) At five-year intervals, the area ider .fixation shall be
reassessed to deter.''T, if additi- al areas should be subject to the
requiregents vf paragraph- (g).
(f) Based on the information submitted by the States pursuant to paragraph (e)
of this section, the Administrator will publish, within 12 months of
the effective date of this paragraph, a list of the areas v/hich sha'il be
subject to the requirements of paragraph (g) of this section.
(g) For each area identified by the Administrator pursuant to
paragraph (f) of'this section, the State shall submit, no later than
24 months following the effective date of this paragraph, the following:
(1) An analysis of the impact on air quality of projected growth
and development over the ten-year period from the date of submittal.
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I
I
.;•
I- „
(2) A plan to prevent any national standards from being exceeded
_ over the ten-year period from the date of plan submlttal. Such
plan shall Include; as necessary, control strategy revisions and/or
I other measures to ensure that projected growth and development will be
compatible with maintenance of the national standards throughout such
I ten-year period. Such plan shall be subject to the provisions of
• §51.6 of this part.
(h) Plans submitted pursuant to paragraph (g) shal.l be reanalyzed and re-
vised where necessary at five-year intervals.
• 5. Section 51.18-is revised to read as follows:
I 51.18 Review of new sources and modifications.
• (a) Each plan shall set forth legally enforceable procedures which shall be
• adequate to enable the State or a local -i(, ---cy to determine whether the con-
struction or modification of a facility, building, structure, or installation,
Iv-
or combir.;" "^ thereof, will result in violations of applicable portions of the
control strategy or will interfere with ".ttainrrent or maintenance, of a national
* standard either directly because of emissions from it, or indirectly, because
I of emissions resulting from nobile source activities associated v."iw: i~,,
(b) Such procedures shall include means by.which the State or local agency
| reponslble for final decision-making on an application for approval to v:nstruct
« or modify W1'llprevent such construction or modification if it will result in a
violation of applicable portions of the control strategy or will interfere with
• the attainment or maintenance of a national standard.
(c) Such procedures shall-provide for the submission, by the ownrr or operator
• of the building, facility, structure, or installation to be constructed or modi-
• fled, of such information "on:
(1) the nature and amounts of emissions to be emitted by it or emitted
I
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12 < • •
, . i 1 r
by associated mobile sources; .
(2) the location, design, construction, and operation of such facility,
building, structure, or installation as may be necessary to permit the
State or local agency to make the determination referred to in paragraph
(a) of this section.
(d) Such procedures shall provide that approval of any construction or modifi-
cation shall not affect the responsibility of the owner or operator to comply
with applicable portions of the control strategy.
(e) Each plan shall identify the State or local agency which will be
responsible for meeting the r-equirements of this section in each area of the
State. Where such responsibility rests with an agenc; other than an air
pollution control agency, such agency shall consult with the appropriate State
or local air pollution control agency in carrying out the provisions of this
section.
>.»»--
(f) Such procedures shall identify types and sizes 01 faci tides, buildings,
structures or installations which will be subject to review pursuant to this
section. The plan shall discuss'the basis for determining which facilities
shall be subject to review.
»
(g) The plan shall include the adminisi:ratjye procedures, which will be •.. .-
followed in making the determination specified in paragraph (a) of this section.
(h) (1) Such procedures shall provide that prior to approving or disapproving
the construction or modification of a facility, building, structure, or
installation pursuant to this section, the State or local agency will
provide opportunity for public comment on the information submitted by
the owner or operator and on the agency's analysis of the effect of such
construction or modification on ambient air quality, including the agency's
proposed approval or disapproval.
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I
• » • i13 1 : •
• • (2) For purposes of subparagraph (1) of this paragraph, opportunity for
• public comment shall include, as a minimum:
(1) availability for public inspection in at least one location
| In the region affected of the information submitted by the owner
_ or operator and of the State or local agency's analysis of the
* effect on air quality.
• (ii) a 30-day period for submittal of public comment, and
(iii) a notice by prominent advertisement in the region affected of
| __ the location of the source information and analysis specified in
• subdivision (i) of this subparagraph.
(3) Where the 30-day comment period required ,n subdivision (2)(i?)
I . of this paragraph would conflict with existing requirements for acting
on requests for perr..i'jion to construct or modify, the State may
• submit for approval a comment per. ,J which is consistent with such
V''
• • existing requirements.
(4) , copy of the notice required by subparagraph (2) of this
£ pargr'h "hall also be sent to the Administrator through the Appropriate
— Regional Office, and to all other State and local air pollution control
* agencie" having jurisdiction in the region in which n •>•. r.r.»v or modified
• installation will be located. The notice also shall be sent ^ any
other agency in the region having responsibility for implementing the
| procedures required under this section.
m (i) Suggestions for developing procedures to meet the requirements of
this section are set forth in Appendix 0.
I
I
I
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14 *
In this part, Appendix 0 is added as follows:
Appendix'0
The following guidelines are intended to assist in the development of
regulations and procedures to comply with the requirements of section 51.18.
1. With respect to facilities which would significantly affect air quality
because of emissions arising from associated mobile source activity, reviev/
procedures should cover any facility which can reasonably be expected to
cause or induce sufficient mobile source activity so that the resulting
emissions Plight be expected to interfere with the attainment or maintenance
of a national standard. The likelihood that there will be such interference
w
will vary with local"conditions, such as current air quality, meteorology,
topography, and growth rates. For this reason, it is not practicable to
establish definitive nationally applicable criteria as to the types or sizes
of sucii facilities which should Le revTewed. There are, however, certain
types of facilities which generally should be considered for review. Experier.:
and estimating techniques have indicated that the air quality impact of certis-ir
types and sizes of facilities is potentially significant regardless of their
location. They include major highways and airports, large region?! shopping
centers, major municipal sports complexes or stadiums, major parking facilitie:
and large amusement and recreational facilities. The above examples are not
meant to be exhaustive. Local conditions must be considered in determining
•
which types of facilities will be subject to new source review.
New source review procedures must also consider the impact of a new
or modified source in political jurisdictions other than the one in which
it is located. Construction or modification of that source must be pre-
vented if the impact in another political jurisdiction is great enough to
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I
' .'
• . Interfere with attainment or maintenance of a national standard, whether
or not there is significant impact in the political jurisdiction of the
facility.
2. Frequently, a substantial amount, of information v/ill be needed to make
the determinations required by I 51.18. In addition to general information
• the nature, design, and size of a facility, data on its expected mode of
operation also will be needed in order to estimate the types and amounts of
air pollutant emissions likely to be associated with it. The operational
data needed to make such estimates may include time periods of operation,
anticipated numbers of employees and/or patrons, expected transportation
routes, modes, and habits of employees and/or patrons, and so on.
Data on present ; . r quality, topography, and meteorology and on
emissions from other sources in ti affected area may also be necessary.
I.
§'
j
•
T.n then' r,:ses wrier - on environmental impact statement (EIS) has been o
will be prepared under the National Environmental Policy A>J ,»- similar Stafr
•
p or local laws, the EIS may well be an excellent source of information to aid
« in making the determinations required by § 51.18, According!,, , agencies
m
responsible for new source reviews are encouraged to moke such use of EIS
• wherever possible in order to avoid needless duplication of infon. tion
• gathering and analysis.
•
I
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re
attainment or maintenance of a national sta
*
significant impact 1n the political jurlsdi
2. Frequently, a substantial amount of 1n
the determinations required by i 51.18. In
the nature, design, and size of a facility,
operation also will be needed in order to e
air pollutant emissions likely to be associated v.'ith" it. The operational
socl
inci
I
rd, whether or not there is
ion of the facility.
rmation will be needed to make
ddition to general information on
ata on its expected mode of
imate the types and amounts of
data needed to make such estimates may include tirr.e periods of operation,
anticipated numbers of employees and/or patrons, expected transportation
routes, modes, and"habits of employees and/or patrons, and so on.
/
Data on present .air quality, topography, and meteorology may also be
necessary, as well as total emissions iii the affected region if a sophisticatec
"' /
air quality simulation model is used. /
In those cases v.'here an environmental impact statement (EIS) has been or
will be p'-Y-parsc under the National Environmental Policy Act or similar State
or local u.v.s, the EIS may well be an excellent source of information to aid
- /
1n making the exterminations required by 1 51,18. Accordingly, agencies
responsible for new source reviews are encouraged to make such use of EIS
wherever possible 1n order to avojd needless duplication of information
gathering and analysis.
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I
17
I. I •
•3. Wherever possible, modeling techniques for approximating the effects
• • *
• of facilities with associated mobile source activity on air quality should
be used. A simplified relationship between emission density (pollutant mass/
I , time/area), size of an area (such as a parking lot) and maximum downwind
m concentration of carbon monoxide is given in Figure 1. This relationship was
, derived using a technique similar to one used by Hanna. The relationships
• depicted in Figure 1 are based on assumptions of flat terrain, average atmos-
pheric stability (Class D) with a steady v/ind speed of 1 meter/second, constant
• wind direction, even distribution of emissions at ground level over the area, en,
• insignificant edge effects. Various assumptions are needed to calculate precise'
the emission density from a facility., including vehicle speeds within the aree, "
| distribution of automobile ages (which will determine which vehicle emission
_ factor to use), the average area occupied by a vehicle, the fraction of the
* total area v.rnd nay be occupied by vehicles, and the maximum number of vehicles
• Cunning ciiri'Kan^usly for onr-hour and~"eight-hour periods (to determine if
either c= -boa monoxide ambient air quality standard will be exceeded;.
J Prior to employing the emission density-air quality relationships in Figure
• 1, other factors may first have to be considered in determining wf ther ambient
air quality standards will be exceeded. These factors incWae measured or esti-
' I mated existing air quality, the impact of any point sources planned tr, or near t~
facility and the impact of any traffic routes on or near the facility passing \vi:
• . 1n close proximity of critical receptors. Also, consideration should be given t:
• any factors which differ substantially from the assumptions made in the Figure 1
relationship, such as topography, meteorology, aerodynamic effects, end spatial
I
IHanna, S.R., "A Simple Method of Calculating Dispersion from Urban Area
Sources", Journal of the Air Pollution Ccntrol Association, Vol. 21, pp. 714-
777 (1971)7~
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18
'distribution of motor vehicles, height of emission, and any facility configu-
ration which would constrain the dispersion of pollutants (such as a parking
deck).
In addition to providing an estimate of the impact of individual area
sources, relationships similar to those depicted in Figure 1 can be of value
1n determining which types and sizes of facilities should be subject to review.
A technique incorporating the Figure 1 relationship exists and will be
available to the States and through the Regional Offices. Several additional
techniques to evaluate the impact of indirect sources of
carbon monoxide are currentJy under study and will be made available
v/hen developed.
The following publications are among those describing other available tech-
niques for estimating air quality impact of direct and indirect sources of
emissions:
(1) Turner, D. B.; "Workbook of Atmospheric Dispersion Estimates," PHS
No. 999-AP-26 (1969).
(2) US EPA; "Compilation t)f Air Pollutant Emission Factors'" CAP No.
AP-42 (Feb. 1972).
(3) BHggs, G. A.; "Plume Rise"; TID-25075 (1969), Clearinghouse for
Federal Scientific and Technical Information, Springfield, Va. 22151.
(4) Mancuso, R. L., and Ludwig, F.L.; "Users Manual for the APRAC-1A
Urban Diffusion Model Computer Program," "Stanford Research Institute
Report" prepared for EPA under contract. CPA 3-68 (1-69) (Sept. 1972).
Available at Clearinghouse for Federal Scientific and Technical Informaticr
Springfield, Va. 22151.
(5) Zimmerman, J.R-.; and Thompson, R. S.; "User's Guide for HIl.'AY," papGr
under preparation, Met. Lab., EPA, RTP, N. C.
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. .
— (6) USGRA: "Proceedings of Symposium on Multi-Source Urban Diffusion
•' Models," GAP Publication No. AP-86 (1970).
ft - (7) Air Quality Implementation Planning Program, Volume I, Operators
Manual, PB 198-299 (1970). Clearinghouse for Federal Scientific and
I Technical Information, Springfield, Va. 22151.
• (8) Henna, S. R.; "Simple Mothods of Calculating Dispersion from Urban
Area Sources," paper presented at Conference on -Air Pollution Meteorology,
• Raleigh, N. C. (Apr. 1971). Available at Clearinghouse for Federal
Scientific and Technical Information, Springfield, Va. 22151.
™ (9) ASME: "Re contended Guide for the Prediction of Dispersion of Airborr;
• Effluents," United -Engineering Center, 345 E. 47th Street, New York, New
York 10017 (1968).
1 (10) Slade, D. H. (editor): "KeJ oology and Atomic Energy 1968,"
USAEC (1968).
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GUIDELINE SERIES
OAQPS NO. 1.2-oosA
PLAN RFVISIONS AND
SUPPLEMENTS - PROCEDURES
FOR APPROVAL/DISAPPROVAL
VS. ENVIRONMENT.*! PROTECTION AGENCY
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina
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ENVIRONMENTAL PROTECTION AGENCY
foplvlo
Attn of: OAQPS, CPDD, SIB DaU:
Subjtct: Plan Revision and Supplements—Procedures for Approval /Disapproval
To:
See Below
These guidelines present revised procedures for review and approval/
disapproval of State Implementation Plans. The revisions have been made
1n an effort to streamline existing procedures outlined in the Sanson/Quarles
September 14, 1972, Memorandum of Understanding. These guidelines supersede
pp. 2-4 of the Sansom/Quarles Memorandum. The changes in procedures are
summarized below.
1. Transfers the basic responsibility for Federal Register package
preparation to the Regional Offices.
2. More clearly defines the basic responsibilities of Regional
Offices, OAWP, and OEGC.
3. Streamlines the procedures for handling submittals from states.
Eliminates time consuming delays presently required in the submlttal
of comments and recommendations back and forth between the Regional
Office and headquarters. In non-controversial cases, saves about
one month in processing time for meet actions.
4. Sets forth a mechanism for p.ucessing cases wherein there are
differences of opinion among Regional Offices, OAWP, and OEGC.
The °pqiona1 Offices and OEGC have been given an opportunity to comment
on the revisions. Also, the revisions were presented at a seminar it
Washington on May 11, 197? which was attended by representative of th
Regional Offices.
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Norman G. Edmisten, Chief
Standards Implementation Branch
Control Programs
Development Division
Addressees: Regional Administrator, Regions I - X
Director, Division of Air and Water Programs, Region I-X (2)
Principal Air Contacts, Region I-X (3)
R. Wilson (5)
B. Steigerwald
R. Neligan
J. Padgett
R. Baum
D. Goodwin
SIB Personnel
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• PLAN REVISIONS AND SUPPLEMENTS - PROCEDURES FOR APPROVAL/DISAPPROVAL
(Except compliance schedules -
• See General Enforcement Procedural Guidelines S-5)
| The procedures for review and approval/disapproval of State Implemen-
_ tatlon Plans (1n use since January 1971) are 1n need of extensive modification
™ to Implement the major decentralization of this activity to the Regional
• Offices. The purpose of this section is to outline the procedures that will
be followed for all future plan revisions and supplemental information
] remaining to be submitted.
_ These procedures shall apply to all SIP related actions that involve a
• change or modification in the approved State Implementation Plan except
• compliance type actions (i.e., compliance schedule, enforcement orders, regu-
latory changes, etc.). However^ any compliance schedule, variance, postpone-
g ment request, etc., that extends the d "; cf emission compliance beyond the
_ ambient air quality standard attainment date 1n the applicable SIP or makes
™ a permaner^ ' ange in the allowable emission rate for a source(s) Is considered
• a SIP revision since such actions may affect the achievement of air quality
standards,
• The Regional Offices are responsible for direct interface with the State
in all matters involving the development and submittal of SIP revisions and
» supplements. All SIP materials are submitted by the State to their rev tive
• EPA regional office. The Regional Office, in turn, will distribute the
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submittal s to the EPA headquarter offices for appropriate review and comment.
The regional offices; therefore, are responsible for seeing that all material
germaine to the SIP action or matter at hand has been received from the
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State(s) and 1s available as needed for the review, evaluation, and recom-
mendation process. The OAWP will serve as a focal point for final processing
such as the Administrator's briefing, Steering Committee and Quality of Life
reviews, and Federal Register publications, and preparation of materials for
news releases. It 1s necessary that OAWP coordinate this material for purposes
of publication 1n the Federal Register 1n order to assure that adequate adherence
to national policy 1s maintained. However, the basic responsibility for the
preparation of the Federal Register package is hereafter delegated to
the Regional Offices.. Procedural guidance in the form of personal consultation
and written guidelines will be provided by CPDD-SIB as necessary to assist and
expedite the prompt preparation of Federal Register actions by the Regional
Off1ce(s).
Every attempt must be made by the Regional Office(s) to expedite the
preparation of Federal Register packages. It 1s expected that most actions
will be of a routine and self-explanatory nature. Such action will receive
Immediate concurrence by OAQPS and OEGC and the Regional Office can proceed
almost immediately with the preparation of the Federal Register package. If,
however, the Regional Office has a submlttal or revision priority status, the
OAQPS-CPDD and OEGC-DSSE will accommodate such request and complete the
analysis and recommendations as expeditiously as possible.
Every attempt will be made by the Regional Office to resolve non-concurrence
and positions of difference so a unified position 1s presented 1n the Federal
Register package forwarded to the Administrator. It 1s recognized that there
will be certain Issues where complete concurrence will not be achieved. A
scheme of basic authority is proposed to provide an orderly procedure for
handling such Issues and at the same time providing each organization the
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• opportunity to be heard. The location of basic authority on SIP decisions
1s as follows:
I Primary Responsibility Off1ce
_ Matters of national policy and precedent OAWP
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Legal/Procedural OEGC
Regulatory/non-regulatory where policy and precedent
has been established Regional Office
I In Instances where differences cannot be resolved, the Federal Register
package will be prepared on the assumption that the position .and recommen-
™ datlon of the office having primary responsibility will prevail as the
• final agency position. However, the briefing document will Indicate all
dissenting position with Tab attachments containing the position and
• Information received from the dissenting offices.
™ Following is an item-by-item descr ,,cion of the procedures to be
• followed from the initial submittal of a plan revlslor to final action 1n the
federal Reo ;er.
I 1. Regional Office receives five copies of the SIP supplemental or
proposed SIP revision from State.
• 2. Regional Office reviews proposed revisions and supplement? If
• State submittal is obviously unapprovable, the Regional Office "•• ^e^s
to worl* with the State agency for appropriate corrections of modlfit ans.
J 3. Regional Office, on the basis of review and actions in Step 2, prepares
a brief memorandum outlining preliminary action recommendations. A copy
• of the State submittals and the preliminary Regional Office recommendation
Is forwarded to:
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a. Mr, Jean J. Schueneman, Office of A1r Quality Planning and
Standards, Control Programs Development Division, Research Triangle
Park, North Carolina 27711
b. Mr. Richard Wilson, Office of General Enforcement, Division of
Stationary Source Enforcement, Waterside Mall, Washington, D. C. 20460
c. Mr. Robert Baum, Office of General Council, A1r Quality and
Radiation Division, Waterside Mall, Washington, D. C. 20460, for any
matter Involving decisions on legal authority.
In many Instances, the Issue Involved 1n the State submlttal 1s of minor
non-controversial nature. In such cases, the Regional Office will prepare
a short memorandum so Indicating with brief statements on proposed actions.
In those instances where the Issue Involved 1n the State submittal 1s
technically and/or legally complex, the Regional Office shall provide an
adequate body of information from which L; m,»ke proper comments and recom-
mendations. The submitted material should Include a sunmary of relevant
background •?. formation, a summary by category of testimony at public
hearings, discussion of objections, or determination advocated by parties
concerned, the Regional Office recommendations, and a draft of proposed EPA
regulations, 1f required.
4. A few of the submittals and revisions received by the Regional Office
will be technically or legally complex or may involve sensitive issues.
Where technical or legal assistance or support is needed in the analysis
and preparation of the Federal Register package, such assistance is available
on request from OAQPS and OEGC. The Regional Office should Indicate in the
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I forwarded material the type of assistance or support needed and the
anticipated time that will be required for developing the Federal
• Register package.
J The OAQPS and DSSE will notify the Regional Office by phone within
five working days of receipt of the Information package 1n Step 3 of
™ concurrence or non-concurrence and confirmed by memorandum transmitted
• by TWX or mall as appropriate. In all cases of concurrence, the Regional
Office will proceed Immediately to prepare the Federal Register package
• (briefing memorandum, preamble and regulations). Where non-concurrence
exists, the non-concurring office will have 15 working days from the day
• of report receipt to prepare the necessary background information and
• justification for non-concurrence. This Information will be forwarded
to the Regional Office with a copy to the other Involved off1ce(s). If
I additional evaluation time is needH to prepare the non-concurring position,
it will be negotiated with the Regional Office. The Regional Office will
• make (*\"?ry attempt to develop a mutually agreed position. This may require
• a meeting of the parties concerned to thoroughly discuss the issues and
alternative actions. If mutual concurrence cannot be attained, the Federal
I Register package will be prepared by the Regional Office preserving 'vhe
position and recommendation of the office having primary responsibility.
i» The position and recommendations of the non-concurring office(s) oe
• presented with full TAB attachments to the briefing document.
« 5. The Regional Office will complete the Federal Register package in
final error-free copy (briefing document, preamble, and regulations). The
• original and nine (9) copies will be forwarded to OAQPS-CPDD nd one (1)
copy to OEGC-DSSE.
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6. The CPDD will maintain the official State Implementation Plan files.
In this role, CPDD will make a final review of the completed Federal
Register package to assure consistency with the Intent of the Clean A1r
VMMM^«M^WMI««MB» ^ .
Act. and 1n keeping with national policy, developing technology, and 1n
consistency with other Regional Office activities. Consolidation of Federal
Register packages will be made 1n a few Instances when the Issues are
similar and such consolidation will be to EPA's advantage.
7. CPDD will forward the Federal Register package to OAWP who will
handle all external coordination and reviews. If significant comments and
recommendations are received from these, OAWP will transmit such Information
to the appropriate Regional Office, CPDD, and DSSE. Any proposed changes
will be reviewed by CPDD and DSSE and applicable comments will be phoned
to the Regional Office within three (3) working days of receipt from OAWP
and confirmed by memorandum transmitted bv' f'«JX or mall as appropriate. The
revised error-free Federal Register package (original and nine (9) copies)
will be prrr—ed 1- accordance with Step 4, unless headquarters consensus
stipulate otherwise, and resubmitted by the Regional Office to OAWP with
copies to CPDD and DSSE.
8. OAWP will arrange for the Administrator's review and approval.
9. Federal Register for publication.
10. CPDD will send copies of all plan revisions to the Office of the
Federal Register and the Office of Public Affairs, as required by standard
operating procedures.
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ENVIRONMENTAL PROTECTION AGENCY
llebly to "';•'
Ann of: OAQPS, CPDD, SIB , Ddt: June 22, 1973
Addition to Guidelines Series OAQPS No. 1.2-004, EPA Source Promulga-
tion _-r Rojcord'iocpinn and^Reportinn - Public Availibiiity of Data, March 14,
T8"/3.
To: Se.e Below
A computer program has been developed by the National Air Data Branch
(NADB), Monitoring and Data Analysis Division (MDAD), to provide the
Regional Offices with assistance in implementing the Federal regulation
prolongation for recordkteping and reporting and public availability of
emission d<->to. This program was written in an effort to supply the infor-
mation cHsu'SoCci on pages 7 and 8 of the above mentioned Guidelines docu-
ment. This infonnstion may also be used in dete'rmining those sources to
be contacted for recordkceping and reporting'requirements. An example of
the printout is enclosed showing the information that can be obtained for
soul c^. uy "cnij prugrLiru
The confuted omissions are .the actual emissions referred to in the
Guidelines document as of the year of record. Since emission factors
are often used to estimate emissions, NEDS has the computed emissions
broken down as to the type of process of source category (Source Classi-
fication C>;;',:.:>). In scr;.3 cases, two different source types r,ay be vented
through ll"1 s?"i? stack (point), es in the enclosed nrintcut. Unfortunately,
MCS is r,;'. ;it up -'.c pr:vv;': tivic, SL:, :- b,-ICKL';,.;: fcr "allcwccl emissions",
i.e., the emissions'allowed under the a'-r^oved control strategy. Thus,
the allov;ed emissions when avai uiblo : -'•. ypressed on a per stack basis,
even though the allowed emissions rr.us ce determined on source catagcry
basis. It should be noted that tn-2 allowed emissions and tre applicable
regulations under the approved control strategy have not generally been
ciiU-i cd •' . ....: ..ZC3 sys L^L'I as yet and ,;ill hav~ i^, be entered by i'ii/J
in the iiVLC'i'im.
The printout may be obtained by writing to Jacob Supers, riA!iQ.,
Mutual Enlding, Research Triangle Park, North Carolina 27711, or by
calling £"L -C,^-02S5. Tl'tis infori.iaticn cannot be accessed i!.-:;1. ' t!:i;
computer terminals at the regional offices at this time. The (,'c th
Carolina fc'cility is in the process of changing ccr;utcrs. 7V;. 'h.-nra
should bs crrplctcd by Doccrber 1973. Access throi.rh the R-sgi'-r.a"; Office
co'riNuter t-^imls will be iride ov?il:ble et that tirs if tl-c- (.'"/ J ''^r
information \'arro,nts it. It is important to specify the areas to .
considered in any requests for data. These rray be requested bv EPA
region; State; State-county; State-county-nlant; State-county.-p'iant-po-
orAQCR.
.j
G. Edmi'sten, Chief
Standards Implementation. Branch
Control F;: ;~^ars
DC- •:.lcp,',.int Division
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Addressees:
Regional Administrators, Regions I - X , . .,
Director, Division of Air and 1,'ater Programs, Regions' I - X (3)"
Principal Air Contacts, Regions I - X (3)
R. h'ilson (5)
B. Steigerwald
J. Schuoncrnan '
R. Neligan
0. Padgett
R. Baum
D. Goodwin ' f"
J. Harrjiierle /"
J. Bosch
0. Suvr.ors
SIB Personnel
/ '
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INSPECTION MANUAL FOR THE
• ENFORCEMENT OF NATIONAL EMISSION
• STANDARDS FOR ASBESTOS
I
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I by
m TIMOTHY R. OSAG
GILBERT H. WOOD
• GEORGE B. CRANE
OFFICE OF AIR QUALITY PLANNING AND STANDARDS
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• ENVIRONMENTAL PROTECTION AGENCY
• OFFICE OF AIR QUALITY PLANNING AND STANDARDS
ENGINEERING SERVICES BRANCH
I DOCUMENT DEVELOPMENT SECTION
JULY 1973
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TABLE OF CONTENTS
Page
I LIST OF FIGURES 1v
• LIST OF TABLES v
1. INTRODUCTION 1"1
• 1.1 PURPOSE OF DOCUMENT 1"1
1.2 GOVERNMENT AGENCIES THAT REGULATE ASBESTOS EMISSIONS }~2
I 1.3 ASBESTOS EMISSION STANDARDS 1-4
• 1.3.1 Intent of Standards !'4
1.3.2 Asbestos Sources Covered ^~4
• 1.3.2.1 Asbestos Mills 1-4
1.3.2.2 Roadways !-6
I 1.3.2.3 Manufacturing 1-6
• 1.3.2.4 Demolition 1-7
1.3.2.5 Spraying T'8
• 2. ASBESTOS MILLS 2-1
2.1 PROCESS DESCRIPTION 2-1
I 2.2 EMISSION POINTS 2-3
• 2.3 INSPECTION PROCEDURES 2-4
2.3.1 General Procedure 2-4
I 2.3.2 Inspection Procedure for Baghouses 2-7
2.3.3 Inspection Procedure for Wet Scrubbers 2-17
I 2.4 REFERENCES FOR SECTION 2 2-20
• 3. ROADWAYS 3-1
3.1 DISCUSSION 3-1
I 3.2 REFERENCES FOR SECTION 3 3-2
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Page
4. MANUFACTURING 4'
4.1 ASBESTOS TEXTILES 4'1
4.1.1 Process Description 4~^
4-3
4.1 .2 Emission Points
4.1.3 Inspection Procedures 4~4
4.2 CEMENT PRODUCTS 4'4
4,2.1 Process Description 4"4
4.2.2 Emission Points 4'5
4.2.3 Inspection Procedures 4"^
4.3 FIREPROOFING AND INSULATING MATERIAL 4"7
4.3.1 Process Description 4"7
4.3.2 Emission Points 4"8
4.3.3 Inspection Procedures 4~9
4.4 FRICTION PRODUCTS 4'9
4.4.1 Process Description 4"9
4.4.2 Emission Points 4"^4
4.4.3 Inspection Procedures 4~'8
4.5 PAPER, MILLBOARD, FELT 4'18
4.5.1 Process Description 4"^°
4.5.2 Emission Points 4~20
4.5.3 Inspection Procedures 4~*^
4.6 FLOOR TILE 4'21
4.6.1 Process Description 4~^
4.6.2 Emission Points 4"^^
4.6.3 Inspection Procedures 4"24
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4.7 PAINTS, COATINGS, CAULKS, ADHESIVES, AND SEALANTS 4-24
jj 4.7.1 Process Description 4-24
_ 4.7.2 Emission Points 4-24
™ 4.7.3 Inspection Procedures 4-25
• 4.8 PLASTICS AND RUBBER MATERIALS 4-25
4.8.1 Process Description 4-25
| 4.8.2 Emission Points 4-26
g 4.8.3 Inspection Procedures 4-27
* 4.9 CHLORINE 4-27
I 4.9,1 Process Description 4-27
4.9.2 Emission Points 4-27
| 4.9.3 Inspection Procedures 4-29
_ 4.10 REFERENCES FOR SECTION 4 4-30
* 5. DEMOLITION 5-1
• 6. SPRAYING 6-1
7. INSPECTION RECORDS 7-1
| 7.1 REPORTS 7-1
_ 7.2 CHECKLISTS AND OUTLINES 7-1
" 7.3 REFERENCES FOR SECTION 7 7-7"
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/.,. 2.-7
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LIST OF TABLES
TABLE PAGE
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7-1 Inspection Checklist 7-3
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LIST OF FIGURES
FIGURE PAGE
1-1 Regulatory Responsibilities of Government Agencies for
Controlling Asbestos Emissions 1-3
2-1 Asbestos Milling 2-2
2-2 Unit Type Fabric Collectors, Unsupported Tubular 2-8
Elements
2-3 Screen or Envelope Type Collector 2-9
2-4 Pulse-Jet Cleaning Type Collector 2-10
4-1 Asbestos Textiles 4-2
4-2 Manufacture of Asbestos-Cement Pipe 4-6
4-3 Friction Products: Dry-Mixed Brake Linings 4-10
4-4 Friction Products: Roll-Formed Clutch Facings and
Brake Linings 4-11
4-5 Friction Products: Endless Woven Clutch Facings 4-12
4-6 Friction Products: Woven Brake Linings 4-13
4-7 Asbestos Paper 4-19
4-8 Vinyl-Asbestos Floor Tile 4-22
4-9 Diaphragm Cell, Hooker Type "S-3A" 4-28
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1. INTRODUCTION
1.1 PURPOSE OF DOCUMENT.
| This document has been issued to accompany promulgation of
m National Emission Standards for Hazardous Air Pollutants (NESHAPS).
It is intended to function as an inspection manual for use in
I enforcing national emission standards for asbestos. Regional, State
and other air pollution officials should find it useful for this
| purpose.
I The Federal regulations for asbestos are given and the interface
of EPA with other regulatory agencies is explained. The fabric
• filter or baghouse, is the device commonly used between asbestos
• source and atmosphere, and general procedures for inspecting a bag-
house are presented. It is not possible to cover all details of the
• many kinds of baghouses; therefore the inspector should become
familiar with the installations within his jurisdiction and with any
• unique features of these units.
I Visible emissions to atmosphere from buildings are conceivable.
• Therefore, this manual discusses many sources of asbestos emissions
from asbestos mills and manufacturing establishments. Process flow
• diagrams indicate points of asbestos emissions, and control techniques
applicable to each source are mentioned. This information will help
| the inspector to trace visible emissions back to their source.
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In all cases, inspectors will need to demonstrate the presence of
asbestos In an air emission, or in a construction material. The require-
ments for satisfvino. this need are outlined.
1.2 GOVERNMENT AGENCIES THAT REGULATE ASBESTOS EMISSIONS.
This manual was written for the use of inspectors from the
Environmental Protection Agency or for other air pollution enforce-
ment personnel. However, other Government agencies have jurisdiction
and interests In asbestos air emissions. Figure 1-1 illustrates
those Federal anencies having responsibilities for controlling
asbestos emissions. As the figure shows, these responsibilities are:
a. EPA - regulate and control emissions
to atmosphere.
b. Occupational Safety regulate and control v.-orking
and Health environment, indoors and out.
Administration
c. Bureau of Mines - regulate and control environments
in and around mining properties.
Further information on OSHA and Bureau of Mines may be obtained from:
Occupational Safety & Health Administration
U. S. Department of Labor
1726 M Street N. W.
Washington, D. C. 20210
1-2
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Office of the Deputy Director
Health and Safety
U. S. Bureau of Mines
18th and C Streets N.W.
Washington, D.C. 20240
1.3 ASBESTOS EMISSION STANDARDS.
1.3.1 Intent of Standards
On April 6, 1973, the Administrator promulgated National
Emission Standards for Hazardous Air Pollutants, including asbestos.
The standards are intended to call attention to significant sources
of asbestos air emissions and to control all of them so that an
ample margin of safety for protection of public health will result.
The standards avoid prohibition of essential uses of asbestos and
give due account to operations already under control by other
agencies.
1.3.2 Sources Covered
1.3.2.1 Asbestos mills
The promulgated standards prohibit visible emissions to
the outside air from any asbestos mill. Outside storage of asbestos
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materials is not considered a part of an asbestos mill. As an
B alternative to meeting a no-visible-emission requirement, an owner or
• operator may elect to use the following specified methods to
clean air streams containing particulate asbestos material before the
I air streams are vented to the atmosphere. If this alternative is
elected, the following requirements must be met:
(A) Fabric filter collection devices must be used, except as
| noted in paragraphs (B) and (C). Such devices must be operated at
g a pressure drop of no more than 4 inches water, as measured across
the filter fabric. The air flow permeability, as determined by
I
ASTM Method 0737-69, must not exceed 30 cubic feet per minute per
2 2
square foot (cfm/ft ) for woven fabrics or 35 cfm/ft for felted
12 2
fabrics, except that 40 cfm/ft for woven or 45 cfm/ft for
g felted fabrics is allowable for filtering air from asbestos ore.
driers. Felted fabric must have a weight of at least 14 ounces
I per square yard of material and be at least 1/16 inch thick
throughout. Synthetic fabrics must not contain fill yarn other
J than that which is spun.
• (B) Where the use of a fabric filter would create a fire or
explosion hazard, the Administrator may authorize the use of wet
• collectors designed to operate with a unit contacting energy of at
• least 40 inches water.
g (C) The Administrator may authorize the use of filtering devices
™ other than the specified fabric filters and wet collectors provided
• the owner or operator demonstrates to the Administrator's
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satisfaction that the filtering of participate asbestos is
equivalent to that achieved through the use of the specified
equipment.
(D) All air-cleaning equipment authorized by this section must be
properly installed, used, operated, and maintained. Bypass devices
may be used only during upset or emergency conditions and then only
for so long as it takes to shut down the operation generating
the particulate asbestos material.
1.3.2.2 Roadways
Surfacing roadways with asbestos tailing is prohibited except
for temporary roadways on areas of asbestos ore deposits. The
deposition of asbestos tailings on roadways covered with snow or ice
is considered surfacing.
1.3.2.3 Manufacturing
Any visible emission to the atmosphere from a building or
structure in which any of the following operations are conducted -
or directly from the operation itself if it is conducted outside of a
building or structure - is prohibited.
Affected Manufacturing Qperati ons
(A) The manufacture of asbestos-containing cloth, cord, wicks,
tubing, tape, twine, rope, thread, yarn, roving, lap, or other
textile materials.
(B) The manufacture of cement products.
(C) The manufacture of fireproofing and insulating materials.
1-6
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(D) The manufacture of friction products.
(E) The manufacture of paper, millboard, and felt.
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(F) The manufacture of floor tile.
(G) The manufacture of paints, coatings, caulks, adhesives,
• and sealants.
• (H) The manufacture of plastics and rubber materials.
• (I) The manufacture of chlorine.
_ As an alternative to the no-visible-emissions regulation, the owner
™ or operator of a manufacturing operation may elect to use a
• specified gas cleaning technique (Section 1.3.2.1) to remove asbestos
particulate from air streams before they are emitted to the atmosphere.
1.3.2.4 Demolition
• Operations involving the demolition of any institutional,
commercial, or industrial building (including apartment buildings
• having more than four chvelling units), structure, facility, or
• installation which contains a boiler, pipe, or structural merber that
is insulated or fireproofed with friable asbestos material must
• comply with the following control procedures.
• (A) Friable asbestos materials used as insulation or fireproofing
for any boiler, pipe, or structural member must be wetted
| and removed before the commencement of any demolition operation.
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Asbestos debris must be wetted sufficiently to remain wet
during all stages of demolition and related handling.
(B) Any pipe or structural member that is covered with
friable asbestos insulating or fireproofing material must be
lowered to the ground.
(C) No friable asbestos debris may be dropped or thrown
from any building, structure, facility, or installation to
the ground or from any floor to a floor below. I/hen the
demolition operation involves buildings, structures, facilities,
or installations 50 feet or greater in height, asbestos debris
must be transported to the ground by dust-tight chutes or
containers.
Any demolition operation is exempt from the previously listed
requirements if the building, structure, facility, or installation
is declared by the proper state or local authority to be structurally
unsound and in danger of imminent collapse. Under this circumstance,
the only requirement is the .adequate wetting of asbestos debris prior
to demolition.
1.3.2.5 Spraying
Visible emissions to the atmosphere from the spray application,
to equipment or machinery ,of insulating or fireproofing material
containing more than 1 percent asbestos on a dry weight basis (see
Section 6) are prohibited. As an alternative to the
no-visible-emission regulation, an owner or operator
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may elect to clean emissions from air streams by using the methods
• discussed in Section 1.3.2.1 before such air streams are vented to
the outside air. Spray-on materials used to insulate or fireproof
™ buildings, structures, pipes, or conduits must contain less than 1
• percent asbestos (dry weight basis).
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I 2. ASBESTOS MILLS
I 2.1 PROCESS DESCRIPTION.
• Asbestos ore is transported from the mine to the mill complex
v/here it is treated in a series of primary and secondary crushers
I which produce material with a maximum diameter of 1 5/16 inches for the
wet-ore stockpile. Ore from this stockpile serves as feed for the
I milling operation illustrated in Figure 2-1.
• The wet ore is dried, treated in a fine crushing circuit to
reduce the size tc approximately 1/4 inch diameter, and introduced to a
I rock circuit. The rock circuit is composed of a series of crushing and
screening operations and has the primary function of separating the
I asbestos fibers from the co-existing rock. Air suction hoods
• (aspirators) are used to entrain the asbestos fibers in an air stream
and separate them from the waste rock. The circuit performs the
• secondary function of grading the fibers according to length.
Air streams convey the asbestos fibers from the rock circuit
m to a fiber-cleaning circuit. Cyclone collectors are used to remove the
• entrained fibers. Exhaust air from the cyclones is sent to a fabric
filter before being vented tb the atmosphere. The fiber cleaning
• circuits perform additional fiber opening, classify and separate
opened fibers from unopened fibers and waste material, and permit
• additional fiber grading.
• The final portion of the milling operation is the cleaning and
bagging circuit. In this circuit, fibers receive additional cleaning
• and arc separated into several standard grades before being packaged for
shipping. A more detailed description of the milling operation is
2-1
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DRIED ROCK
STORAGE
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Figuie2-1. Asbestos milling.
2-2
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available in the AP-117 control techniques document for asbestos
• emissions. Inspectors should note Figures 3-4, 3-5, 3-6 and 3-8
and should read this document to become familiar with the processes
I they must inspect.
•
•
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2.2 EMISSION POINTS.
A list of exhaust points for mill ventilation and process air
streams must be obtained on an individual plant basis. This
information can be obtained by contacting the mill owner or operator
prior to the actual inspection. Major sources of emissions within
™ the mill and applicable control techniques are as follows:
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1. Emission Source — open conveyor belts transporting ore or
partially processed ore.
Control Technique -- enclose conveyor and transfer points
I and exhaust to baghouse, or wot the transported material.
I 2. Emission Source -- primary and secondary crushers.
Control Technique — enclose and exhaust crusher inlet
| and outlet to baghouse.
I 3. Emission Source — vibrating and shaking screens.
Control Technique -- enclose screens and exhaust to baghouse.
4. Emission Source -- cyclone exhaust.
| Control Technique — treat exhaust in baghouse.
5. Emission Source — ore-drier exhaust.
Control Technique — treat exhaust in baghouse.
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6. Emission Source -- mills and fiberizers.
Control Technique -- enclose inlets and outlets of mills
and fiberizers and exhaust to baghouse.
7. Emission Source — fiber grading circuits.
Control Technique -- enclose inlet and outlet ends of graders
and exhaust to baghouse.
8. Emission Source -- bagging machines.
Control Technique -- install dust capture hoods and exhaust
to baghouse.
9. Emission Source -- disposal of mill tailings.
Control Technique — enclose conveyors carrying mill
tailings and exhaust to baghouse or wet tailings before transporting.
2.3 INSPECTION PROCEDURES.
2.3.1 General Procedure
A visible emission, as defined by the standard, is any emission
which is visually detectable without the aid of instruments and which
contains particulate asbestos material.
If the no-visible-emission option is chosen, the first step in
the inspection of an asbestos mill should be the visual examination of
all exhaust points (stacks, vents, etc.) for mill ventilation and process
air streams. The inspector should be a qualified smoke reader wt:o has
successfully completed the EPA course on visible emission evaluation
or an equivalent course. The visual examination should be conducted
in accordance with 40 CFR 60, Method 9 of the Appendix.
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_ The visual detection of an emission must be followed by
' confirmation that asbestos material is present in the visible
• gas stream. Further guidance on collection and identification of
asbestos samples will be provided by DSSE.
g Exhaust streams from ore driers are unique, because water vapor
_ in these streams can be sufficient to cause a visible plume. The
™ inspector must read the opacity of the exhaust stream at the point
• where the steam plume disappears. A visible emission at this point
would be considered a violation of the no-visible-emission requirement.
| If the alternative to the no-visible-emission requirement is
« chosen and a baghouse is in use, either the design and operating
specifications must match those presented in Section 1.3.2.1(A), or
I the owner or operator of the mill must demonstrate to the Administrator's
satisfaction that the efficiency of the unit is equivalent to that of
I the specified control system. Design information, such as fabric
•j specifications and operating pressure, can be obtained from the
plant owner or operator. The presence of visible emissions in
• the baghouse exhaust gases is evidence of a probable malfunction.
None of the acceptable baghouses that have been observed have
I exhibited visible emissions when in proper operating condition.
m Visible emissions from baghouses are possible during the start-up
period, but should be eliminated as a filter cake forms on the
I clean cloth.
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Inspection procedures for fabric filters and high-energy wet
scrubbers are presented in the following sections. These procedures
are also applicable to systems used to control emissions from the
affected manufacturing operations or during the spray application of
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2.3.2 Inspection Procedure for Baghouses
Discussion
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asbestos-containing insulation or fireproofing onto equipment or
I machinery and therefore will not be duplicated in Sections 4 or 6.
m Unique situations that would alter the inspection scheme will be
discussed whenever pertinent.
I
Fabric filters are produced by several different manufacturers
I and can have basic design differences. In general, they can be
classified hy (1) type of filter element (supported or unsupported), (2)
• the intended use (continuous or intermittent), and (3) the method of
• removing collected dust from the filter fabric (mechanical shaking,
mechanical rapping, pulse-jet, etc). Examples of three common baghouse
• designs are presented in Figures 2-2 through 2-4. A brief description of
each system is presented in this section. A more complete discussion can
• be obtained from the control techniques document for parti cul ate air
•
pollutants.
The fabric filter shown in Figure 2-2 is an unsupported tubular
| uni-bag tvpe. Bags are supported at their tops by a bag and shaker
support and are attached at their bottoms to a collar sealed into the
• cell plate. The cell plate is the perforated metal plate that
• separates the classified section from the clean air chamber and channels
dust-laden air into the filter elements.
• Dust-laden air enters a classifier section in which the larger
particles are removed by settling. The air then flows upward through the
• bag entrances, passes through the bag fabric and is exhausted to the
• atmosphere. Dust particles accumulate on the inside of the bags and must
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CLEAi; AIR CXIiAIJSl
FILTFi!
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SIR" LA;, 1'"
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BAG SUPPORT
CELL PLATE
Figuie 2-2. Unit type fabiic "inllpctrrs,
unstippoitcd tiibulai oloinonti-. ^
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TOP VIEW OF ONE ROW OF ELEMENTS
------,/- DUSKADLii AIR
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DTf.! AIR
FILTER ClEf.:EKTS
Figuic 2-3. fjci
01 envelop:1 tyjx; cnllcctoi,
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2-10
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be removed by periodic cleaning, usually with a mechanical shaker. The
frequency and length of the cleaning cycle depends upon the specific
«
operation.
I When the filtration process is reversed, with the gas flowing from
the outside to the inside of the filter element, it is necessary to
P support the filter media against the developed pressure. Supported
• filter elements are either of the envelope (Figure 2-3) or the tubular
(Figure 2-4) type. In the case of a screen or envelope type of collector,
V dust-laden air entering the filter encounters a baffle plate that causes
the stream to diffuse over the entire chamber. This diffusion assures
m uniform loading throughout the system and permits the heavier dust
« particles to settle out. The air then passes through the filter media
to the inside of the bag and out the open end of the bag to the clean
• air chamber. Dust particles are deposited on the outside surface of
the bags and must be removed by periodic cleaning. Cleaning is usually
I accomplished by mechanical shaking or rapping.
m A schematic diagram of a fabric filter that utilizes a pulse- jet
cleaning mechanism is presented in Figure 2-4. This system uses tubular-
• type, supported filter elements. The collector consists primarily of a
series of cylindrical filter elements enclosed in a dust-tight housing.
m Dusty air is admitted to the housing and clean air withdrawn from inside
m the filter elements. Periodic cleaning is required to remove dust particles
which accumulate on the outside of the bags. Cleaning is accomplished by
I introducing a jet of high-pressure air into a venturi mounted above each
bag. The reverse flow of air created by the jet pulse is sufficient to
m loosen accumulated dust and clean the the filter media. Cleaning is
• continuous, with a complete cycle every 2 to 5 minutes.
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The existence of several types of fabric filters complicates
the procedure of evaluating specific systems. The inspection scheme
provided in this manual, although somewhat general in nature, is
adequate to allow a full evaluation of most fabric filters. It is
suggested, however, that the inspector make an effort to obtain and
review the operating instructions for the specific unit being examined
whenever possible. Although many vendors do not include a separate
inspection manual with their operating instruction package, the
information provided might suggest some alteration in the listed
procedure.
Procedure
1. Identify the type of fabric filter being used: manufacturer,
model, type of bags, cleaning mechanism, capacity, and source
of gas stream being treated.
2. Compare the fabric specifications of the bags being used
with the referenced specifications. Air flow permeability
(ASTM Method D 737-69) should not exceed 30 cfm/ft2 for woven
2
or 35 cfm/ft for felted fabrics. Permeability is defined
as the air flow in cubic feet per minute passing through a
square foot of clean new cloth with a pressure differential of
0.50 inch water. An exception to this requirement will
be allowed for fabric filters treating air from asbestos ore
2
driers. In this case, an air flow permeability of 40 cfm/ft
2
for woven or 45 cfm/ft for felted fabrics is acceptable. Felted
fabrics must weigh at least 14 ounces per square yard and be at
2-12
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least 1/16 inch thick. Synthetic fabrics must not contain fill
| yarn other than that which is spun. The inspector should de-
^ termine if the user has installed bags differing from those speci-
• fied in the original fabric filter design and the reason for any cnange
m
•
3. Observe pressure drop across fabric filter. The most common
differential pressure instrument used is a simple "U"-tube mano-
meter filled with water or anti -freeze solution and connected across
• the filter media. Other devices that indicate differential
pressure include well-type manometers, bourdon-type gauges, and
• diaphragm-actuated gauges. Pressure drop should be no more than
m 4 inches water . A reading several inches in excess of
this value is a sign that a system malfunction (blinding, etc.)
• exists. A low pressure-drop reading would indicate a bag rupture
or leak.
I
4. Search for bypass lines or ductwork. Determine the justification
g for them. Determine if any alternate atmospheric protection is
available if these bypasses are used.
•^^
5. Inspect fabric filter for leaks. The approach will depend upon
• the collector design. In the case of filters using unsupported
« bags, the inspector can actually enter the collector and evaluate
the condition of the bags. Filter elements should be examined for
• tears, ruptures, leaks, and signs of heavy wear. The inspection
should be scheduled to concur with a period when the unit has
• been removed from service for cleaning. When examining a system
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designed for continuous service, the inspection must be on a
compartment-by-compartmcnt basis.
Dust deposits on the clean air side of the bags or the cell
plate are signs of collector malfunctions. Leaking bags will
frequently have a streak of dust leading from the leak towards
the clean air exit. Leaks in the cell plate are usually
indicated by a small mound of accumulated dust surrounding the
leak. The floor of the clean air chamber should be kept clean
so that any dust deposits observed during an inspection can be
attributed to a collector malfunction. Regular cleaning of the
baghouse cell plate is not common at rnost operations, however,
it is felt that the practice could be introduced without requiring
an unreasonable amount of effort.
Special attention should be given to the inspection of the bags '
around the area where they are attached to the cell plate (collar),
since this is a point of high wear. All bags should be firmly
attached to the cell plate or to the collar attached to the cell
plate. If a bag leak or rupture is located, the bag should be
tied off below the leak or the cell plate entrance capped as a-
temporary measure until the bag can be replaced.
When evaluating fabric filters equipped with supported filter
elements (gas flow from outside of filter element to inside),
visual examination of the interior of the collector is restricted
because of the presence of dust-laden air. Most fabric filters
using supported elements employ continuous cleaning techniques
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m (pulse-jet, reverse jet) and are therefore not normally removed
from service for cleaning (Figure 2-4). The units will have to
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be inspected when the systems are in operation. The major
emphasis should be placed on the baghouse manometer reading
and the cleanliness of the collector exhaust stream. At pulse-jet-
M cleaned units, the inspector should gain access to the upper
plenum chamber (clean air exit) and observe the exhaust stream
• during a cleaning cycle (complete cycle every 2 to 5 minutes).
The presence of a leak in any specific bag is indicated by the
JB discharge of a puff of dust from the venturi immediately
M following the cleaning step.
The presence of dust in the clean air plenum chamber is an
™ indication of a bag leak or to^ Ine chamber should be kept
• free of dust deposits so that any dust accunulation can be
attributed to a collector malfunction. Regular cleaning of
H the clean air plenum chamber is not a common practice at most
~ operations, but could be initiated without too much difficulty.
* Should a baq leak be discovered, the venturi can be capped as a
• temporary measure until the unit can be removed from service
and the bag replaced.
6. Observe bag spacing. Sufficient clearance should be provided
• so that one bag does not rub another. This decreases the
effective filter surface and increases bag wear.
7. Inspect ductwork and collector housing for leakage, wear, corrosion,
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and general state of repair. The general location of leaks
can be determined by the air noise. Leaks in the housing or
ductwork should be sealed either by welding or the use of
epoxy cither on a temporary or permanent basis as conditions
permit.
8. Inspect dust hoppers for accumulation of dust. In most cases,
the hopper should not be allowed to become more than half full
in order to avoid re-entrainment of the collected material.
9. Observe the emptying of dust hoppers, rote the type of waste
containers being usoc! and the presence or absence of visible
emissions. Obtain information regarding ultimate fate of
asbestos waste.
10. Review operating procedures and maintenance schedules. Frequent
inspection and maintenance is essential to the effective operation
of the collector. External maintenance inspection of the filter
housing and system should usually be performed daily, while the
filter elements should typically be inspected once a week. Note
length arid frequency of cleaning cycle. This will vary depending
upon the specific applications.
11. Determine what preventive maintenance procedures are used to
avoid fabric failures and what procedures are used to replace
bags or correct malfunctions.
12. Gas itreams from baghouses servicing asbestos ore dryers may show
visible pluses of steam. The water content results both from the
a-16
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I
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hydrogen in the ore-dryer fuel and from the moisture in the
I asbestos being dried. The inspector should read the opacity at
M the point where the steam plume disappears. Any opacity here
is evidence of a leak or system malfunction.
™ The inspector must remember that the baghouse tt-mperature must
• be held above the dewpoint of the ore dryer exit gas. This
dewpoint will depend upon the fuel being used and the moisture
I in the asbestos to be dried; more exactly, it will depend upon
^ the v;ei<;,nt (or mol} fraction of water vapor in the gas stream.
' For a specific mill, the dewpoint will fall within a limited
• temperature range. The inspector should therefore observe the
condition of the insulation on the baghouse (gas temperature is
| maintained above dewpoint by preventing gas heat loss) and check
— the gas temperature history. A fall below the dewpoint would
* mean trouble for the baghouse operator, by caking, blinding
• and increased pressure drop, through the bags.
I
2.3.3 Inspection Procedure for Het Scrubbers
Discussion
• High-energy wet scrubbers could find application in controlling
asbestos dust. Specifically, scrubbers might be used in situations
• in which the use of fabric filters would create a fire or explosion
• hazard. Low energy (6 to 8 inches water) scrubbers have been used
as a control for asbestos emissions at Johns-f'anville's Hanville,
• Hew Jersey plant; Ravbestos - Manhattan's flanheim, Pennsylvania pl.nt;
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Union Carbide's King City, California mill; and several Canadian
mills. No high-energy scrubbers, however, are known to be in use
as a control technique for asbestos in any of the mills or
manufacturing operations covered by the standard. All existing
scrubbing systems are expected to be replaced by fabric filters.
Procedure
1. Identify the type of wet scrubber being used: manufacturer,
model, type, unit contacting energy, capacity, and source of gas
stream Iziv.'j treated.
2. Compare design specifications with referenced specifications. The
collector must be designed to operate with a unit contacting energy
equivalent to 40 inches water pressure drop. Contacting energy is
that portion of useful energy exuded in producing contact of the
particulate matter with the scrubbing liquid. Unit contacting energy
is equal to the energy per unit weight of gas required to introduce
the gas stream into the contact chamber, plus, the energy per unit
weight of gas required to introduce scrubbing liquid into the
contact chamber, plus the mechanical (shaft) energy per unit
weight of gas applied to effect contact between the scrubbing
5
liquid and the gas stream. In the case of a venturi scrubber, the
most common type of high-energy scrubber, the contribution of the
liquid stream is small and most of the energy for contacting is
derived from the gas stream. The contacting energy is therefore
essentially equivalent to the gas stream pressure drop.
3. Note the design specifications for gas-stream volumetric flow
2-18
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rate, gas-stream pressure drop, liquid-stream volumetric flow
I rate, and liquid-stream inlet pressure. Observe the pressure
drops and flow rates if the necessary instruments have been
I
installed.
• 4. Search for bypass lines or ductwork. Determine the justification
for them. Determine if alternate atmospheric protection is available
in case of tneir use.
™ 5. Inspect ductwork and exterior of scrubber for leaks, wear,
fl| corrosion, and general state of repair.
• 6. Review operating procedures and maintenance schedules. Frequent
inspection arid maintenance is essential to the effective operation
• of the scrubber. Obtain information regarding ultimate fate of
collected asbestos.
7. Determine what procedures are used in cases of scrubber mal-
jp function.
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2-19
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2.4 REFERENCES FOR SECTION 2.
1. Control Techniques for Asbestos Air Pollutants. U. S. Environ-
mental Protection Agency. Research Triangle Park, North Carolina.
Publication Number AP-117. February 1973.
2. Hutcheson, J. R. M. Environmental Control in the Asbestos Industry
of Quebec. 73rd Annual General Meeting of the Canadian Institute
of Mining and Metallurgy, Quebec City, 25 p. 1971. p. 9, 23.
3. Control Techniques for Particulate Air Pollutants. U. S. Depart-
ment of Health, Education, and Welfare. Washington, D. C.
Publication Number AP-51. January 1969. p. 102-126.
4. Types of Fabric Filters. Industrial Gas Cleaning Institute, Inc.
Stamford, Connecticut. Publication Number F-5. August 1972. 8 p.
5. Semrau, K. T. Dust Scrubber Design - A Critique on the State of
the Art. Journal of the Air Pollution Control Association.
13:587-594, December 1963.
2-20
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I
I 3. ROADWAYS
I 3.1 DISCUSSION.
m The inspector should be familiar with sources of asbestos tailings
in his jurisdiction. These sources include asbestos mines and
• mills, which have been and are a source of rock wastes. The
large available quantities of such rock wastes have furnished
Q incentive to use them to surface roads. It is economical to
£ process asbestos rock to a residual asbestos content of about
3 percent. The inspector should maintain enough surveillance over
• mines and mills to be aware of the ultimate fate of such asbestos-
containing solids wastes.
| The inspector can maintain some surveillance over roads by
im visual examination of pieces of rock. Asbestos in such rock will
probably have a color varying from v.;iite, through greenish or
V yellowish white to brownish. It will have a silky, metallic, dull
and opaque luster. Fibres may be coarse or fine and probably are
• parallel with the walls. Sometimes they are felted. It is also
m interesting to note that a suspension of chrysotile in water
has a pH of over 10. This.is alkaline to litmus and to phenolphthalein.
• Although this property is not unique, it is one added test to use
for identification.
™ If the presence of asbestos is suspected, the inspector may take
• samples of rock or of apparently fibrous road materials and submit them
for microscopic examination.
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3.2 REFERENCES FOR SECTION 3.
1. Kirk-Othmer Encyclopedia of Chemical Technology, Second Edition,
Vol. 2., pg. 738, Intersciencc Publishers, N. Y.
3-2
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I
• 4. MANUFACTURING
I 4.1 ASBESTOS TEXTILES.
m 4.1.1 Process Description
The majority of the asbestos fibers received by a textile plant
• are of the milled variety. These fibers have frequently been com-
pressed during packaging and therefore require willowing (fiber
• opening) before being sent to the carding operation.
• Either in a preliminary mixing operation or during carding, small
amounts of a carrier fiber (rayon or cotton) are blended with the
• asbestos fibers to improve the spinning characteristics of the
asbestos. The asbestos content of the mixture will range frrm 80
9 percent to almost 100 percent depending upon the requirements of the
• end-product.
Carding is the preliminary st.p in the manufacture of textiles.
I The asbestos f;oers unde^jo a final opening and cleaning process by
the carding machine, which cor.ibs the fibers into a parallel arrange-
• ment thereby forming a coherent mat of material. This mat is
• separated into untwisted strands and wound onto spindles to form the
roving from which asbestos yarn is produced.
• Roving is converted into yarn by a conventional spinning operation,
The yarn may then undergo a twisting, weaving, or braiding operation
• depending on the desired end-product. Figure 4-1 provides a schematic
• diagram of an asbestos textile plant. Additional information is
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available in the control techniques document for asbestos emissions.
-------
BAGGED ASBESTOS MUCK
UAGGEOSYNTHETIC
ORCELLULOSEFIRER
i.
PUKE/.VSTOS
LAPS AND CELTS
ASULS10S
>.- SYNlliLTK,
-, LAPS AND [ LL.TS
I
SPUN YARN
r.i!Ti::c
"Ll1™
— LIGHT -GJMt,L
REINFORCING i.lICF
TV/ISTED YARN -
V
II.VJLTI PLY
A YARN
R[V:H;DER
"OPTIONAL
BRAIDER
D
i:.
V/EAV1HG L00
IMPREGNATING
V
StALS
PACKINGS
: LOCAl'ION 0!: I'OTI ',ll\M A?L;F SI OS CONTAINING DUST [."ISSIGiJS.
BRAIDED TUBIf.T., r,:V,IDED
ROPE, BRAIUTD C(!';l/
SPINNING
AID
TV/IS! ING
WOVEN TUC'NG,
CLOTH, TAPES
Figure 4-1. Asbestos textiles.
4-2
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4.1.2 Emission Points
| A complete list of all exhaust points (stacks, vents, etc.) for
g plant ventilation and process air streams is necessary for the inspect-
ion of any manufacturing operation. This information must be obtained
I from the plant owner or operator. Major sources of emissions within
a textile plant and appropriate control techniques are as follows:
I 1. Emission Source — opening and emptying of bags of asbestos
m into fiber openers and carding machines.
Control Technique -- install dust capture hoods on bag
• opening stations and carding machines with exhaust to baghouse.
• 2. Emission Source -- carding operation.
Control Technique -- install dust capture hoods with exhaust.
• to baghouse.
• 3. Emission Source -~ spinning and twisting machines.
Control Technique -- enclose spindles with exhaust to
• baghouse or convert to wet process.
Jj 4. Emission Source -- looms and braiding machines.
— Control Technique -- install dust capture hoods with exhaust
™ to baghouse.
• 5. Emission Source — open carts of asbestos fiber, roving,
• or yarn.
Control Technique -- cover carts.
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4-3
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6. Emission Source -- disposal of empty asbestos bags.
Control Technique -- place empty bag in enclosed container
immediately after emptying and deposit in landfill.
4.1.3 Inspection Procedures
Ventilation and process air from the fiber opening (willowing)
and carding machines could have loadings similar to the process gas
streams of asbestos mills. Most of the other gas streams are expected
to have lov/er fiber concentrations. The inspection procedures described for
asbestos mills in Section 2.3 will apply to tne manufacturing of textiles.
4.2 CEMENT PRODUCTS.
4.2.1 Process Description
Asbestos-cement products contain from 15 to 30 percent (by weight)
asbestos, usually of the chrysotile variety. The largest sector of
this industry is involved in the production of asbestos-cement pipe.
Other products include siding shingles and flat or corrugated sheets.
Siding shingles and other sheet products may be produced by
either a dry or wet process. In the dry process, a uniform thickness
of the dry mixture (asbestos fibers, Portland cement, and silica) is
distributed onto a conveyor belt, sprayed with water, and compressed
by rolls to the desired thickness. This asbestos-cement sheet is then
cut to size and sent to the curing operation.
The wet process produces dense sheets of asbestos-cement material
by introducing a slurry into a molH chamber and compressing the mixture
to remove excess water. A setting and hardening period of 24 to 48
hours precedes the curing operation.
-4-4
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I
• The manufacture of asbestos-cement pipe is illustrated in
8 Figure 4-2 With the individual manufacturing steps numbered and
listed on the bottom portion of the figure. Asbestos fibers are
I normally received in pressure packed bags and therefore require fiber
M conditioning (opening) before being sert to the production-line
storage bins. A more detailed discussion of the manufacturing
V operation is available in asbestos control techniques document.
• 4.2.2 Emission Points
Major potential emission sources within the plant and suitable
• control techniques are presented in the following list.
1. Emission Source -- slitting and emptying of bags of
• asbestos into hopper of fiber opener.
• Control Technique -- install dust capture hood over bag
opening and emptying station with exhaust to baghouse.
I
2. Emission Source -- dry mixing of asbestos, cement, and
• silica.
Control Technique -- install dust capture hood over mixing
I operation and exhaust to baghouse.
g 3. Emission Source -- finishing operations (machining, drilling,
cutting, grinding).
• Control Technique -- install hoods over all finishing operations
• and exhaust to baghouse.
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4-5
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-^ "5
A
•«
o
V
. r*•''11
k.. ^~»* -
( LJ OO i
CSJ fV^ « |- LO CO
a
a:
CJ
a, ^J _T1
^ " !V
ogS;:; &2:1ap,!rj?
^ CJ c/i J J Cx"'t3 - j L.i ix <.j '.'.J -.
c- o ~> o- 'J)-1" c>) '- — — ' r-
js t-- <-J [3 i-.j t.^J^J ." : 'f W o r^ n-j
E
OJ
O
I
t/i
O
OJ
cj;U.
O
V-
f->
UJ
ro
Q CJ -
F! ^ '-
ri ^r5 UJ uJ
5 « t-- f-J
rrj uj ti- o
£ p r-1^ "-
^-|-nv<^- '-1
Cr. o «: >. o t 3 •- . ^
_J
, j
(O
<4-
3
03
CD
LU >- ;•-. )-- [,- o ..J -:
_J CK o u) o -r uj -C
UJ C3 O r- - oo 5» H- L--
UJ
4-6
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4. Emission Source -- loading of scrap and rejects into
scrap grinder.
Control Technique -- install dust capture hood over loading
«
area and exhaust to baghouse.
• 5. Emission Source -- disposal of empty asbestos bags.
• Control Technique -- place empty bag in an enclosed
container immediately after emptying and deposit in landfill.
4.2.3 Inspection Procedures
• The inspection procedures discussed for asbestos mills should
be appropriate. Heavy concentrations of asbestos fibers might be
| present in process and ventilation rtreams from fiber opening,
M mixing, and finishing operations.
4.3 FI REPROOFING AND INSULATING MATERIAL.
4.3.1 Process Description
• Molded insulation and spray-applied mixtures used to fireproof
• steel-reinforced buildings are the principal asbestos-containing
insulating and fi reproofing materials. The preliminary step in the
• manufacture of molded insulation is the mixing of diatomaceous silica,
lime, and asbestos with water. This mixture is pumped to a holding
• (gel) tank where the silica reacts with the calcium hydroxide to
• form hydrated calcium silicate which crystallizes around the asbestos
fibers. The calcium silicate - asbestos slurry is then discharged to
• a molding press where the charge is dewatered and pressed into the
desired forms (pipe shells, blocks, etc.). After being removed from
i
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the molds, the pieces are heat cured in a series of autoclaves and
drying tunnels and sent to a finishing operation (sizing, leg
trimming, drilling, etc.) before being packaged for shipping.
Spray-applied fireproofing mixtures are a combination of
asbestos and an inorganic dry bonding agent. The mixing operation
is usually a batch process.
4.3.2 Emission Points
Major end i;si on points in the manufacturing operations together
with effective control measures are listed below.
1. Emission Source -- opening and emptying of bags of asbestos
into fiber openers or mixers.
Control Technique -- install dust capture hoods on bag
opening stations and mixing operations v/ith exhaust sent to a
baghouse.
2. Emission Source — finishing operations (sizing, leg
trimming, drilling, planing, etc.).
Control Technique — install hoods over all finishing
operations and exhaust to baghouses.
3. Emission Source -- packaging of pipe insulation or
fireproofing mixture.
Control Technique — install dust capture hoods over
packaging areas and vent to baghouse.
4-8
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4. Emission Source -- disposal of empty asbestos bags.
Control Technique -- place bag in encloced container
and deposit in landfill.
•i
_ 4.3.3 Inspection Procedures
" Willowinq and mixing operations can produce high fiber concen-
• trations. The inspection procedures suggested for asbestos mills are
applicable.
4.4 FRICTP.'I PRODUCTS.
™ 4.4.1 Process Description
• Brake linings and clutch facings are the major asbestos-contain-
ing friction products. Methods of fabrication include molding (wet
J or dry), two-roll forming, and impse-.nating woven asbestos fabric
— with friction material. Molding and two-roll forming involve the
* preforming of the product under pressure in molds or between rolls.
• The preformed sheets are then cut into product sized segments, formed
into the proper shape, and heat cured. Woven friction products are
I constructed of resin impregnated asbestos fabric that has been cut
_ to length, formed into the desired shape, and heat cured.
* Detailed descriptions of the various manufacturing operations
emissions. Figures 4-3 through 4-6 illustrate these processes.
• are provided in the control techniques document for asbestos
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• 4-9
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, AND
FRIC'ilUH COMPOUND
MOLD
PT; --- rD
STEAM
PREHEAT
PREFORMING
PRESS
STRIPS CUT
TO LENGTH
MOLD
REMOVCD
. i
fell:
PiiL.A
V
i 1
•"•'< * fTJuti" . _.:";,""
ROUGH
GRIKDIf.'G
SHEET Clll I:.'IT
STRIPS
STEAM HEATED
BENDING
CLAWING IN
LUNETTES
BAKING
OVEN
- . n
DRILLING,
PACKAGING
G LOCATION OP POTENTIAL ASBESTOS-CONTAINING DUST EMISSIONS
- >
Figure 4-3. Friction products: dry-mixed
brake linings.
RADIUS
GRINDING
4-10
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1
1
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START: ROI.L FOR','.; D CLUTCH FACINGS
ASBESTOS, SOLVFNT, AND
FRICTION COMPOUND
MU-SHEAR
,',IXER
-H-i
Tit
---
r.^-f
ill
RACKING
, FINISHING
! OPERATIONS
.1
i H
PRESS
1
-
iit
\;
r-i \
PACKAGING I SFEFIG. 29
START. ROLL FOR.V.LD BRAliE LININGS
ASBESTOS,
SOLVENT.
AND
FRICTIC:;
co,v,rai!,n W
3l.
BAKING
OVEN
FORCED-
AIIJDRYiiG1
CKAf:'.!;LR
RACKING
CHOPPER
TY/C ROLL>
MILL
(3 LOCATION OF POTENTIAL ASBFSrOS-COfiTAINING DUST EMISSIONS
Figure 4-4. Friction products: roll-formed clutch
facings and brake linings.
4-11
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1-W
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WIRE REINFORCED
CLOTH ROLL
SLITTING TO
TAP(:S
11
STEAM-HEATED
ROLL
FRICTIOI: cc ,;POJ;,D
BA1 H
WATER-COOLED
ROLL
Vr'INDIiiG
METAL
PLATES
-F
- >r
PRrCL';-;li,G
1, OV1IH
HOT
PRESSING
V
FINISHING OPERATIONS
Fo:-'-.-.rj-;,!R
COOt.i;,G
SANDING
EOGF.
1-iDHiG
8 y
DRILLING.
BRANDING
JL,
*—V»t"~*
1NSPF.CT.ON
PACKAGING
LOCATION OF POTENTIAL ASBESTOS-CONTAINING DUST EMISSIONS
Figure 4-5. Friction products: endless woven
clutch facings.
4-12
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WIRE-REINFORCED
WOVEN TAPE
ROLL
CLAWING IN
LU.'imES
DRYING
OVEN
ROUGH
rjGRInbUG
*«•*•
IMPREGNATING
BATH
ROTARY
CUTTER
PRESS
DENS FIER
BAKING OVEN
I I
I FINISHING OPERATIONS '
SEE FIG. 2-9 I
n
PACKAGING
P
P1 LOCATION OF POTENTIAL ASBESTOS-COI1TAINING DUST (.MISSIONS
Figure 4-6. Friction products: woven brake lininqs.
4-13
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4.4.2 Emission Points
Dry-Mixed Brake Linings
1. Emission Source -- opening and emptying of hags of asbestos.
Control Technique- -- install dust capture hoods over bag
opening area and storage bins.
2. Emission Source -- transfer of asbestos from storage bins to
weighing scales.
Control Technique -- install dust capture hood over weighing
scale- c.-nd exhaust to baghouse.
3. Emission Source -- discharging of asbestos from weighing
scales to mixer.
Control Technique -- enclose discharge area or install dust
capture hood and exhaust to baghcu3e.
4. Emission Source -- discharging of mixer product to molds.
Control Technique -- enclose discharge area and exhaust to
baghouse.
5. Emission Source -- cutting of molded sheet into strips.
Control Technique -- install dust capture hoods and exhaust
to baghouse.
6. Emission Source -- rough grinding of molded strips.
Control Technique -- install dust capture hoods and exhaust
to baghouse.
4-14
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I
•
•
7. Emission Source -- cutting of molded strips to length.
Control Technique -- install dust capture hood and exhaust
to baghouse.
8. Emission Source -- finishing operations (grinding, drilling,
• counterboring) .
Control Tpchninue -- install dust capture hoods and exhaust
| to haohouse.
• 9. Erission Source -- disposal of emntv asbestos bags.
Control Techninuo -- place empty bags in enclosed container
' immediately after emptying and deposit in landfill.
• ^°J_llLP-!j'i0_^ i;ral'° .Lini'lf'Ji
• 1. Emission Source -- opening and emptying of bans of asbestos.
Control Technique -- install dust canture hoods over bag
• opening area and storage bins and exhaust to haohousp.
V 2. Emission Source -- transfer of asbestos from storane bins
to weigh inn scales .
| Control Technique -- install dust canture hoods over weighing
_ scales and exhaust to baohouse.
3. Em's si on Source -- discharging of asbestos from weighing
• scales to mixer.
• Control Technique -- install dust capture hoods over mixer
and exhaust to ban.'iouse.
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• 4-15
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4. Cmissinn Source -- hammer mill.
Control Technique -- enclose discharne area and
exhaust to bainq arr.i and -. toraqe bins and exhaust to baeliouse.
2. [r.is.-.ion Sourcu -- transfer of asbestos from storage bins to
weighing scales.
Control Technique -- install dust capture hoods over
weighing scalcf, and exhaust to baghouse.
3. Emission Source -- discharging of asbestos from weighing
scales to mixer.
Control Technique -- install dust capture hoods over mixer
and exhaust to baghouse.
4-16
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I
4. Emission Source -- finishing operations (sanding, edqe
I grindi nq, drilling, counter-boring, dustinci).
Control Technique -- install dust couture hoods over
| finishing operations and exhaust to bacjhouse.
I 5. (."mission Source -- disposal of empty asbestos baqs.
Control Technique -- place empty bags in enclosed container
• immediately after emptying and deposit in landfill.
• li°Y_cJl l'r_a! :> l-1Jlin3J-L
• 1, emission Source -- cutting of saturated tane.
Control Technique -- install dust caoture hoods and exhaust
I
to baqhouse.
12. Emission Source -- rouqh grinding of taoe.
'
Control Technique -- install dust capture hood and exhaust
to baqhousc.
• 3. emission Source -- finishing operations (sandinq, edge
grindi nq, drilling, counter-boring, dusting).
8 Control Technique -- install dust capture hoods over all
• finishing operations and exhaust to baghouse.
• Endless 1 .(P_ve_n__Clj : JL?_h. _£ acijios_
• 1. emission Source -- slitting of asbestos cloth into tapes.
• - Control Technique -- install dust capture hood and exhaust
to baghouse.
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• 4-17
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2. Emission Source -- finishing operations (sanding, edge
grinding, drilling, counter-boring, dusting).
Control Technique -- install dust capture hoods over all
finishing operations and exhaust to baghouse.
4.4.3 Inspection Procedures
The inspection procedures presented in Section
2-3 can be used. High concentrations of asbestos could be present
in ventilatio,. air from the dry-mixing and finishing (drilling,
grinding, ftc.) operations. Visible emissions might also be detected
from various other process steps (wet-mixing, impregnating bath, etc.)
because of the use of volatile organic solvents. Asbestos emissions
from these sources are expected to be small.
4.5 PAPER, MILLBOARD, FELT.
4.5.1 Irocess Description
Asbestos paper and felt are manufactured on machines of the
Fourdrinier and cylinder types similar to those used to produce
cellulose paper. The cylinder machine is the more v.-idely employed.
Figure 4-7 illustrates the operation of a Fourdrinier paper
machine. Short-fiber asbestos is combined with a binder and water
in a pulp beater to form a mixture containing between 6 and 12
percent fibers. This slurry is fed to a machine chest where it is
diluted to 2 to 4 percent solids. A thin uniform layer of the mixture
is deposited by gravity onto an endless, moving wire screen to form
the paper which is then transferred to a moving felt. Vacuum boxes,
roll presses, and a series of steam heated drum rollers are used to
4-18
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vi en: I-'-1
PRESS
RO'.LS
'>
CALENDER
ROLLS
o r\ /
.- ^ - xr /'tr
h; /'
v«* t
u
DRYERS
CHEATED ROLLS)
--
FINISUri) A'JBLSTOo
PAPER ROLL
HIGH-SPEED
SLITTCR
TAKE-UP
REEL
TAKE-UP REEL
fl LOCATION Of POTENTIAL ASnESTOS-CONTAIIIING DUST EMISSIONS
" J
Figure 4-7. Asbestos paper.
4-19
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dry the paper. This is followed by calendering to produce a smooth
surface and cutting to size.
The operation of a cylinder paper machine includes a mixing
step similar to that described for a Fourdrinier type machine. The
slurry from the machine chest is pumped to one of several vats, each
containing a rotating cylinder screen. Asbestos fibers are collected
on the rotating cylinders and transferred to an endless belt conveyor
to form the paper. The subsequent drying, calendering, and sizing
operations a.-; trie same as these described for the Fourdrinier machine,
f'illLCK-rc! is produced from short fiber asbestos. The asbestos
fibers, water, and a binder are mixed in a pulp beater, subjected to
a screening operation, and pumped to the millboard machine. The
asbestos slurry is fed to u large box containing a rotating cylinder
screen. Fibers are deposited on the rotating cylinder, partially
drained of waters and transferred to a conveyor belt to form the
millbO'Vd shoret. This sheet is then pressed, molded, and cut to the
size of consr.ercial millboard. All remaining water is removed by a
series of pressing and drying operations.
4.5.2 Emission Points
1. Emission Source -- opening and emptying of bags of asbestos
into mixer.
Control Technique — enclose bag opening and emptying
station and exhaust to baghouse, or convert to a wet process
using pulpable bags.
4-20
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_ 2. Emission Source -- slitting and edge-trimming of paper.
Control Technique — install dust capture hoods and exhaust
• to baghouse.
• 3. Emission Source -- disposal of empty asbestos bags.
Control Technique -- place empty bags in an enclosed
g container immediately after emptying and deposit in landfill.
• 4.5.3 Inspection Procedures
The in:rvction procedure developed for asbestos mills should be
• appropriate. The major emission source will be the opening and
• emptying of bags of asbestos.
4.6 FLOOR TILE.
4.6.1 Process Description
• Vinyl-asbestos floor tile is produced from a mixture of asbestos
•j fibers, ground limestone, and a resin binder. The various components
are combined in a high shear mixer as indicated in Figure 4-8 to
• form the base material. After the base material passes through a
two-roll mill, the relatively thick sheet is cut and joined to a
• similar piece that has been previously formed and is in the process
• of being calendered (smoothed and reduced in thickness between two
revolving cylinders). A series of calendering cperations produces
I a tile sheet of the desired thickness and surface finish.
Before the compound can cool and harden, a blanking press die
I cuts the tiles to final size. Haste material is recycled to the
• mixing operation. A more detailed discussion of the manufacture
• 4-21
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BRPM ;
FRA..T.
STHAP
S/: !) ClIHL'K
;AV;:.:AIF.I;IALS
\
Ti-r, noi.i
fmLL
n;/v :. --
STKYP
/•
OIL
|,;OT'i I ! R
RADIANT
WAX AF'PLICATOI?
Buni;r;
..._J
COOLI[-;GCIiA!,;i]ER
OO:-
CALENDER ROLLS
PRESS
fTILES
\
\
\
\
I I'
•t~- —
PACKAGING
COOLIUG Cf!/,,V,bER
Ario;.1 or PGILNTIM ASp.rsros-co;.ri/i.iNiijc DUST [.MISSIONS
Fiqure 4-8. Vinvl-asbestos floor tile.
4-22
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g of vinyl-asbestos floor tile can bo obtained from tho control
techniques document for asbestos emissions.
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4.C.2 Emission Points
Potential sources of asbestos emissions are:
1, Emission Source -- opening and emptying of bags of asbestos.
I Control Technique -- install dust capture hoods over bag
opening and emptying stations and exhaust to baghouse.
2. Em's?ion Source -- transfer of asbestos from storage bins
• to weighing scales.
• Control Technique -- install dust capture hood over weighing
scales anci exhaust to baghouse.
• 3. Emission Source -- disch?rging of asbestos from weighing
• scale to mixer.
Control Technique -- enclose discharge area or install dust
| capture hood over mixer inlet,
• 4. Emission Source -- mixing process.
Control Technique — close mixer inlet.
5. Emission Source — loading of asbestos-containing chips
J into hoppers in preparation for mottling.
_ Control Technique -- install dust capture hood over hoppers
• and exhaust to baghouse.
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4-23
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6. Lrnission Source -- deposition of mottling chips on the
tile shoot ar. it emerges from the two- roll mill.
Control Technique -- install dust capture hood and exhaust
to baghouse.
7. Emission Source -- grinding of scrap in preparation for
recycle.
Control Technique -- install dust capture hoods over
de^ "nlet and outlet and exhaust to baghouse.
8. [.mission Source -- disposal of empty asbestos bags.
Control Technique -- place empty bags in an enclosed
container immediately after emptying and deposit in landfill.
4.6.3 Inspection Procedures
Asbestos emissions are limited primarily to the introduction
of asbestos into the process and to the mixing step. The inspection
procedures outlined in Section 2.3 will be applicable.
4.7 PAINTS, COATINGS, CAULKS, ADHESIVES, AND SEALANTS.
4.7.1 Process Description
Most asbestos-containing paints, coatings, caulks, adhesives,
and sealants are either asphalt or oil -based mixtures produced by
batch mixing operations. A high percentage of short-fiber asbestos
may be used.
4.7.2 Emission Points
Emissions are possible from the bag opening operations and
4-24
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from the introduction of asbestos into the process.
| 1. Emission Source -- opening and emptying of bags of
B asbestos into storage bins or receiving hoppers.
" Control Technique -- install dust hoods over bag opening
I and emptying stations and exhaust to bagliouse.
• 2. Emission Source -- transfer of asbestos from storage bins to
weighing scales.
I Control Technique -- enclose discharge area and exhaust to
baghouse.
3. Emission Source -- discharging of asbestos from the
| weighing scales to the mixer.
w Control Technique -- enclose discharge area or install dust
capture hood over mixer.
• 4. Emission source -- disposal of empty asbestos bags.
• Control Technique -- place bags in an enclosed container
immediately after emptying and deposit in landfill.
4.7.3 Inspection Procedures
I The inspection procedures provided in Section 2.3 are appropriate.
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4.8 PLASTICS AND RUBBER MATERIALS.
4.8.1 Process Description
Asbestos-reinforced or-filled plastics and rubber materials
• may be produced by both batch and continuous operations and may
make extensive use of both short and long fibers. Process
4-25
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descriptions must be obtained on an individual basis from the plant
owner or operator.
4.8.2 Emission Points
1. Emission Source -- opening and emptying of bags of asbestos
into storage bins or receiving hoppers.
Control Technique -- install dust capture hoods over bag
opening and emptying stations and exhaust to beghouse.
2. Emission Source -- transfer of asbestos from storage bins
to v/eigning scales.
Control Technique — enclose discharge area and exhaust to
baghouse.
3. Emission Source -- discharge of iisriestos fron the weighing
scales to the mixer.
Control Technique -- enclose discharge area or install
dust capture hood over mixer.
4, Emission Source -- grinding of sheets of asbestos-
reinforced plastic to form molding compound.
Control Technique -- enclose inlet and outlet of grinder
and exhaust to baghouse.
5. Emission Source -- disposal of empty asbestos bags.
Control Technique -- place bags in an enclosed container
immediately after emptying and deposit in landfill.
4-26
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• 4.0.3 Inspection Procedures
Potential enission sources are the bag opening and the mixing
I operations. Mo alteration in the inspection procedures listed in
Section 2.3 should be required.
4.9 CHLORINE.
4.9.1 Process Description:
I Host chlorine is produced by the electrolysis of aqueous
solutions of alkali-metal chlorides. All cell designs for this
• electrolytic process are variations of either the diaphragm cell
• (Figure 4-9) or of a cell which uses mercury metal as an inter-
mediate cathode. In the diaphragm cell, an asbestos diaphragm
• separates the anode from the cathode. The diaphragm is applied by
inmersing the cathode into a bath of asbestos slurried in cell
m liquor and then applying a vacuum to the cathode. Asbestos is
• deposited on the steel-screen fingers of the cathode.
« 4.9.2 Emission Points
1. Emission Source --.opening and emptying of bags of asbestos.
• Control Technique — install dust capture hoods over bag
opening and emptying stations with exhaust to baghouse, or convert
| to wet process using pulpable bags.
I 2. Emission Source -- disposal of empty bags of asbestos.
Control Technique -- place empty bags in enclosed container
• immediately after emptying and deposit in landfill.
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- 4-27
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l-
QJ
O
O
cu
O
CD
(O
J-
^;
en
o
CTl
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cn
u.
4-28
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4.9.3 Inspection Procedures
I
Visible emissions of asbestos can occur during the bag
0 opening and emptying operation. The inspection procedures developed
for asbestos mills should be suitable.
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4.10 REFERENCES FOR SECTION 4.
1. Control Techniques for Asbestos Air Pollutants. U. S.
Environmental Protection Agency. Research Triangle Park, North
Carolina. Publication Number AP-117. February 1973.
2. Shreve, R. M. Chemical Process Industries. New York, McGraw-Hill
Book Company, 19C7. p. 234.
4-30
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• 5. DEMOLITION
I A rewrite of the Demolition Section is being prepared by D5SE
• and will be distributed no later than at the July 19 NESHAPS seminar
in Dallas, Texas.
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5-1
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6. SPRAYING
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The only spray applied insulation or fireproofing now being
I produced that is known to contain more than 1 percent asbestos is
_ MK 111 produced by the Zonolite Construction Products Division of the
• W. R. Grace Company. MK 111 contains from 10 to 12 percent asbestos.
• The Fireproofing Products Division of Carboine Co. of St. Louis
manufacturers Pyrocrete I and Pyrocrete II. These are cement-piaster-
• asbestos mixtures used for structural steel fireproofing. They are
no I spray applied.
The asbestos limitation of 1 percent by weight for drv spray
I material applied to buildings, structures, pipes, or conduits suggests
that the inspector may often want to check supplies allegedly contain-
| ing less than 1 percent asbestos. Quantitative analysis for asbestos
• in a mixture is an extremely difficult procedure. Available methods
arc based on electron microscopy used by highly trained specialists.
I Determining asbestos content with these methods costs approximately
$300, and the results are accurate within plus or minus 50 percent.
p The few available U. S. locations that have the required facilities
I
and expertise include the following:
Battelle Columbus
I Attention: Mr. William Henry
505 King Avenue
Columbus, Ohio 43201
I California State Department of Health
Attention: Dr. Peter K. Mueller
2151 Berkeley l.'ay
Berkeley, California 94704
I
_ McCrone Associates, Inc.
• 493 East 31st Street
™ Chicago, Illinois 60616
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6-1
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Mt. Sinai School of Medicine
City University of Mew York
Attention: Dr. Irving J. Selikoff
Environmental Sciences Laboratory
5th Avenue and lOOlh Street
New York, New York 10029
Johns f'onville Research and Engineering Center
Attention: Dr. Sydney Spi°l
Denver, Colorado
Obviously, speedy analysis, although highly desirable, will
not normally be possible. However, the submission of samples at
least serves r>s a deterrent to a contractor who would misrepresent,
since action could be taken against him later if the analysis showed
more than 1 percent asbestos.
In cases involving the spray application of asbestos containing
insulating or fireproofing material containing n.ore than 1 percent
asbestos to equipment or machinery, the inspection procedures listed
in Section 2.3 would be appropriate.
6-2
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I . 7. INSPECTION RECORDS
• 7.1 RtPORTS.
Each stationary source of asbestos emissions must report the
I following information to the Environmental Protection Agency:
• A. Name and address of owner or operator
B. Location of source
I C. A description of the source and its operations with identifi-
cation of all points of asbestos emissions
• D. A description of control equipment for each emission point
• E. The average weight per month of asbestos processed for the 12
months preceding the report date
• These reports will provide most of the background data for on-site
inspection of each source. The initial inspection should verify in-
• formation in tho reports.
§ 7.2 CHECKLISTS A;
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a checklist or outline of the inspection can be made. It may be
unnecessary to prepare an outline or checklist for sorrc? sources. A
list of major Items to observe or discuss and a sketch showing nuir.sion
points will probably suffice for small, relatively simple processes.
The primary function of a checklist or outline is to prevent the
inspector from overlooking any emission point during the inspection.
Table 7-1 presents an outline which may be used as a guide. It will
probably be necessary to modify the outline for each source, such as,
omit the wot collector section or add instrument readings. On any
checklist, outline or inspection log, the source being inspected
should be completely identified. Code numbers should be included to
allow easy reference to the HAREMS computerized data handling system.
Comments on weather conditions or process operations affecting the
inspection should be made. Any equipment failures (T replacements
affecting cnissior rates and any use of control equipment bypasses
should b:.- listed.
7-2
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TABLE 7-1. INSPECTION CHECKLIST
I
Inspector
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Date
Company Name
Address
HAPEI1S Source Number
Source Description (e.g., Asbestos cement pipe plant)
Persons Interviewed
• GENERAL OBSERVATIONS
Ductwork Leaks
Piping Leaks
Collector Housing Leaks
Apparent Condition cf Equipment
Disposal of Collected Material
Accumulated Dust or Fiber
Visible Emissions Ref. TM 9
(Average Opacity)
Locations of Visible Emissions
(HAPEIIS point numbers)
•Samples Taken at Locations
of Visible Emissions
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7-3
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TABLE 7-1. (CONTINUED)
HAPEMS Source No.
Date
CONTROL DEVICES
I. Baghouse
HAPEMS Point Number
Gas Stream Description (e.g., exhaust from bagging machine
hood)
Baghouse Manufacturer
Model
Fabric Description (type, pomesbility, etc.)
Length and Frequency of Cleaning Cycle
Baghouse Interior
Bag Conoition: Torn
Leaking
Ruptured
Heavily Horn
Other
Dust on Floor
Baghouse Hopper
Unloading Frequency
Dust Generated by Unloading
Final Dust Disposal
Operating Variables
7-4
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II.
TABLE 7-1. (CONTIIJUFD)
HAPEfIS Source No.
Date
Specificntlon
Observed '• Comment
Temperature
Pressure Drop
Gas Flowrate
If any recordings instruments are used, examine the charts
to discover abnormal situations.
Comments
(Bag replacements,_ eouijpmen_t faijures, equiprent channqs,
addi t i on ;il i ns trumentati on, etc._)
Wet Collectors
HAPEMS Point Number
Gas Stream Descriotion
Type of Collector (e.g., venturi scrubber)
Collector Manufacturer L
Model
Operating Variable
Pressure Drop
Gas Flowrate
Liquid Flov/rate
Liquid Inlet Pressure
Unit Contcct.ing Energy
7-5
Specification
Observed
i
Comment
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TABLE: "/-i. (CONTINUED)
IIAPLIIS Source No.
Date
If recording instruments are used, examine the charts to
discover abnormal situations
Comments and recommendations
7-6
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ENVIRONMENTAL PROTECTION AGENCY
DAMP, OAQPS, CPUJ, SIB Dale_ July 10> 1973
Kegul at iotis for Indirect Sourc0 ''cview
See Below
As yt u »•'.-. ' 1 , SIP distributed TO t:,e Region! Offices on June 15
a dn :: -v, c.,i-'c'c : , 'V- ,.\-»'... i •"• , inte1'1 i ivj assist ''on in working ,vith
!L., •: n, ation -.'lens, In addition,
<:,. , J the Rc_, u, ,->,.>. 1 Office stair
:ra: i, ;f>eting, v:e promised additional
erit. In this regard, we arc
icn whicfi TPA ^ould promulgate
..^ac: ;, P' •.'•ordures for deteninning the i.iiniinum
v^' • r i.: ~ i-.iP,j' i. i,n new source review regulations.
) ,>,'p ,v: :)',?•; 01 i i'O'-'idrig guidance to the States in
' i~-j .\ sc-o". e re<.u i a ,icns , It should be noted, eowever.
^•p.M:,.] u- oi'era :i,ig characteristics of motor v'enicief
are • ithe'r arhin py at this f,oint. The exa^p^e calcu-
•-.e ;,,ee of a^i/sis that could be presented to sirp; rt
;,T rvi w s of eeneern.
i a>;> also e. P .inp eo:^;C'> of + he •, iina schedule for developr'en i:,
propo..-"! and ; • ?.• •_ .!.]•,, f ; 1^1 - ,•; .,-.cordance with the court scipulated
dates ,." f:^ ^. "'•, is ( o.. e-rne-d, .;„": dates or Cciober 15 for Approval/
disappre1'1:! d- .' j •. ; .;• 1!) r;r i'^1-.! 'jroinulgation must be met. . ;-o
CPDD/SIli w.:jl -i p .-,, P.te rec • .BV • • an.; coniiiient you would neve 01, ;~ie
enclosed repu a'-v,)-, by July 23, 19/3. We would make the desired changes
and send copies of the revised regni ;tions back to the Regional Offices
to assist you in r-> - DP-'pa* i ion c^ p.ar.s where the states have ' il^.-i
to respond. P.. wa , c:is^u9',e' in P^icipv, the Regions! Office wi '
for proposal and prcniul
'C/j must
e ;"(;;•. 'j Lion for the briefing aee^^eni:
and pre(\:elo. ':.}:- ,,'ili as- :•" one F e :i e r a 1_ Reg i s t e r package e'.d forward
to He: e "]'iar cer s f-r ;. ro:e:>s : -,g. Please note that comments on the proposed
plans would ',:-: v* ,i to the respective Regional Office similar to the
transportation .]~u procedure. Since SIB will be functioning in a
coordinating/supporting role, it is urgent that we be kept appraised of
the status of plan development so we can prepare accordingly. Please
advise us if our principal contact in I he Regional Office for this matter
is other than teat individual designated as principal air contact.
_
You n^i-cl not sp^ini r.ne error' Lo prepare' the error-free copy tr.ii
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It is further recognized that many, if not most, states lack adequate
legal authority and will not be able to correct this deficiency tn time to
submit an aoprovanlj plan. This situation might tend to discourage many
states from proceed ing with p1-?n development activities. I would suggest
that you encourage '• '•'>•' states to develop the kind of plan necessary to
address the c c f, \ riot:-, c,rid need; sf tnc-ir area. If the basic plan is
acceptable ,:n to be
cf, •-. i .^',r \.-.it: Li.. ,,.•.•, i . : 'Assent requires^r ts oi 40 (.rR 51. we
wi 1"; fr'r-i.c this ciri:i->: •"•. • •" • ..• ~-' rh:.' comolf'X source schedule, If you
have any com eni-, as ir. otlvr , -j^v Mie ..tv.igcs, please ;e-r; us know.
Ue \/ould appreci ,te on;.' orient-, yo; :;'ay hove on the enclosed material
If you have any id^oS or p^occ-..m'cs that would bo of benefit to the other
,../• ;:,«.- r ' ,
i\or;.:'an G. r.dfinsten, Chief
^' Implementation Branch
Control Programs
lev el opine nt Division
Enclosures
Addressees:
Director, Ji vision of .'ir LC-\ '^i2r :• • oyrams , Regions 1 - X (3)
Principal /ur Contacts, ,-;:g!ens I - X ,,3)
J. Schu enema n
.
W. Frici:
E. Reich
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• Basis for Deterrnination of Facilities
Subject to New Source Review
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I. Pirect sourcesof emissigns
All stationary sources of emissions, with the exception of the
I
exemptions listed are subject to review. The cutoff sizes for fuel
• burning equipment were chosen because the maximum amounts of emissions
from these exempted sourers are considered insignificant. These cutoffs
« depend on the type of fuel burned:
• (1) Equipment • i nac. a heat input of not more than 250 million
B.t.u. per hour and which burn gaseous fuel containing not more
• than 0.5 grains. H?S per 100 standard cubic feet would emit negligible
particulate matter and 1 _ 5 t.nan jiwo ton: of sulfur dioxide per year.
™ (2) Equipment "•*;,:r> nas a hfai inpu of not more than 1 million B.t.u.
• per hour ,; ;d , burns cf'fi .','dte oil would emit negligible
partlcMU •• ' ,r and approximately two tons of .--jlfur dioxide per
f year.
— (3) Equi-nient which has a heat input of not more than 35u,jGO E t.u.
* per hour ..nd wfiich burn; s-x> other fuel rauld emH betwe/:- ivc to
• seven tons of sulfur dioxide per year.
II. Indirect sources of emissions
_ The criterion which was used in the selection of sizes of facilities
• was that a facility would be subject to review if its associated motor
vehicle activity resulten i-i local CO concentrations in excess oi lb percent
of the national ambient air qua! it': standard,
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(1) Facilities with parking facilities
For estimating the size of a parking lot for a particular
facility, above which will result in local carbon monoxide concen-
trations which exceed 10 percent of the carbon monoxide standard,
assumptions must be made concerning the behavior of motor vehicles
In that parking lot under estimated worst conditions. One reference
on parking lot design* gives dimensions of parking spaces.. A
parking unit is defined as two parking stalls plus an aisle.. For
parking stalls at 90° to the aisle, the maximum dimensions for the unit
is 65 feet by 10 feet, for a two-way aisle. This amounts to a space
2 2
requirement of 650 ft /2 stalls = 325 ft /stall. This arrangement permits
a capacity of 135 cars per acre. -
Assumptions were made concerning automobr ! .avior in a parking
lot. Assuming for a worst-case example that vehicle; travel a = 900 g CO
^ ~lvehicle mi lei I hour j ^ ' ~ vehicle hours
Assumptions concerning the behavior of motor vehicles in a parking
lot depend upon the type of facility and the intensity of use over a time
*Parking in the City Center, prepared by Wilbur Smith and Associates, New Haven,
Connecticut, under commission from the Automobile Manufacturers Asso., May 1965.
**Compi1ation of Air Pollutant Emission Factors (Revised), U.S. Environmental
Protection Agency, Office of Air Programs, Research Triangle Park, N. C.,
February 1972, Publication No. AP-42.
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period. Assuming a constant wind speed of 1 m/sec, and constant
I
wind direction with class "D" atmospheric stability, the graphical
I relationship given in Figure 1 of Appendix 0 of 40 CFR Part 51 can be
used to determine the maximum parking area for a given downwind concen-
• tration and a given emission da,-it/. Interpolation between curves was
• necessary to determine t^ fv'Ut; ,>n jhips for the conditions of 10 per-
cent of the CO ambient air quality standards (i.e., 0.9 p.p.m. and 3,5
J p.p.m.).
The following calculations yield a size of two general categories
• of complex sources above which should be subjt- r TO <•.-« ew 1 facilities
• whose associated motor- vehicle activity i- surt-a- o^t i-r.-i1 the period
of a day and facilities wrv- ;nted ou^i enirlt; activity occurs
I over a short period. The sizu for :•= th -s is t> acres,
(a) £^.riilii£.Jjil?. l£L tlhr-' ' '* J:li?iL_'?:i-';-v--j.hi!;'^ jdrj! 'iifllSj6.
activit; is spread out GJ ' ' "c £6£JJ?jf -"*" "'-:'"''
« ' These facilities '-«i' . - ' -dt; >hot, '• = •• riru'"^'. ,
commercial and indusif.i' • • ,-•*, -'U • . ,t- i,-. o .> if j
fl recreatlona1 ar> ,>. ~ * • - • - •? •
these facilfcfi:-. -. • - . . .. ,r . j;: --. ,. ••» • of: '>ttn
| a peak-to-off-p'-ur • ^' ..-? iH->»d;-.- ; !.;. 4^ ,-..' •:'!•" • \ <:'-ndiLU
M analyses wi M r?e fsec-'- T, ,, . ?ut J'",-, h,.-i :•,r, i/f^- is^r and ore for
the worst 8-nour perio-..
• (i) Worst peak [a^n p'-'^.-i
Assun'iC- thai :r,c t.'jiri(,tj lot cont.-J:i • <•.',<•*: ^er -
I (full lot) and uar f
• time. The emissioc u
F (900 g CO Vl hour
1-hr ~ Vvehicle
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* ^ i
= 1.8 x 10"4 a C0/<;pr-m2
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From Figure 1 in Appendix 0, to achieve <•> d^Mv.irK edg<; con-
centration of less than 10 percent of the one hour CO standard
(10% of 35 p.p.m. = 3.5 o.p.m,}, the a ret must be ic lorger
than approximately K,J outers on a side;i which corr^sf-ond'
to a squar-u area c-t jp;»n."-. v :aU •• -i acr>- (o/., stalls).
• • \ , r\ ,
{t"\) Worst 8-h, • '• 10--
Assume t'.at lor 8 hour:,, the 'r^rkitK, li,t coiilair.s only
three-fourths the number j- vehicles d, pdirKi ,,, tails and
that oniy 0.7 percent of th -se vehicle:'-, are f-ocr^tinq at
any one time over IMC- 8- .-:,;,•• pe.-io! . .> , • v.ion
dens: "v, f ' . ,3]; L
i' VJ r.D'.ir
-8-hr "VveMcTe"^jv/V:;^r™:yV • -.-/••
= 4.4 ; , '
From
trati:, -
of 9.^. tj.,
than appr.!>, ,
area of a(.., ; -• •. ,JT:.
'. (b) _
ove_r a short pen; ^ £_e':'at? JR MOIT os .:•
These facilities include .->; ' < ts it;':';!;1;?, ,,r: i "'p^, ,,'rncn
cater to affairs f^on, v,-(.:r.h n^ir -.> k'av. .1!. , ,• r, i-..; ,-^s,,;x;
that the lot is rui, ,, ,r:r«;.^--, ^..rk in , > n'1 i
of 2.2 pen.f:rif -^ ! .- - > . - •'.<• •
period, ^iti, -..(in t;,t- n ,\ .,. . . >i .. nj
much hi-:he- t^an ? ?f n~ •> •• -':' ; cipate-i tf..if r, ;. j
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I empty In much less than an hour, thus, reducing the average
number of cars running during the hour to 2.2%. The one-hour
| emission density, E, is then calculated as follows:
IP _/900 g CO Vl hour Vl stalA/ vehicleVlO.8 ft.2) ,n n?9.
Ll-hr ^vehicle hour/\3600 sec./\325 ft2/\} stall /Y^2 / {U'(}^)
m = 1.8 x 10~4 g CO/sec-m2
_ From Figure 1 in Appendix 0, to achieve a downwind edge con-
™ centration of less than 10 percent of the 1-hour standard
• (10% of 35 p. p.m. = 3.5 p. p.m.), the parking area must be no
longer than approximately 40 meters, which corresponds to a
•
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square area of approximately 5 acres.
(2) Highways
To estimate the sizes of highways abcv wHch will result in local
CO concentrations which exceed 10 percent of the carbon monoxide
standard, th^ '< ' -° -.. v-ce model HIWAY* was used to develop Figire 1
(enclosed) which depicts CO concentration as related to traffic on the
•
roadway. The ^ollcwing assumptions were made in the development of
• Figure 1:
- 1 lane roadway of 400 m in length
• - Receptor located as indicated in the diagram in Figure 1, at
2 m above ground,
• - Angle between the direction of the wind and the roadway 20 degrees,
- Mobile sources emitting CO at 0 m above ground,
r~-
• - Flat terrain,
"
- Class "D" atmospheric stability,
- Wind speed of 1 m/sec,
- Vehicle speed of 30 mph,
- 1975 automobile age and use distribution operating under urban
conditions.
*Zimmerman, J.R., and Thompson, R. S., "User's Guide for HIWAY", paper under
• preparation ,Met. Lab., EPA, Research Triangle Park, N.C.
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Although the assumption of a 1 lane roadway was used, this was
done solely for calculation purposes. The HIWAY model has an option
for entering the total line source density rather than the traffic
1n each lane--this option was chosen with the value set at 0.0031
grams/second-meter for the one lane. This value corresponds to 100
vehicles per hour for the 1975 vehicle age and use distribution operating
at 5 mph under urban driving conditions. To obtain the concentrations
corresponding to the 30 mph condition, the concentrations were multiplied
by a factor of 0,33.
For a 1-hour CO concentration of 3.5 p.p.m. (10% of 35 p.p.m.),
Figure 1 yields a maximum roadway volume of approximately 700
vehicles/hr. For an 8-hour CO concentration of 0.9 p.p.m. (10% of
9 p.p.m.), Figure 1 yields a maximum roadv/cv vc ume of approximately
180 vehicles/hr 'i.e ,. 1440 vehicl0 over 8 hours),
These volu,.,as will be periodically revised to r-fleet changing
vehicle emission factors resulting from changes in vehicle age and use
distributions which will occur after 1975.
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(b) Regulation for review of new or modified Indirect sources
(1) Definitions:
(1) "Indirect source " means a facility, building, structure,
or Installation, or combination thereof, which causes emissions
to be generated through associated mobile source activity.
(11) "Modification" means any change to an Indirect source which
Increases the vehicle capacity of such facility.
(2) The requirements of this paragraph are applicable to the following
Indirect sources in the State of , the construction or modifi-
cation of which is commenced after the effective date of this paragraph:
(1) Any new facility with an associated parking area with a
capacity of 700 or more cars.
(1i) Any modified facility which:
(aj Increases parking caf tcily from less than 700 cars to
700 cr more cars, or
(b_) Increases existing parking capacity which is in
excess of 700 cars by more than 25 percent, or more than 700
cars, whichever is less.
(111) Airports served by regularly scheduled airlines,
(1v) Roads with a maximum expected traffic volume within ten
years of completion of:
(a) 1440 vehicles in eight hours» or
(b_) 700 vehicles in one hour.
(3) No owner or operator of an indirect source subject to this para-
graph shall commence construction or modification of such source after
the effective date of this paragraph without first obtaining approval from
the Administrator of the location and design of such source.
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I
(1) Application for approval to construct or modify shall be
| made on forms furnished by the Administrator, n>- ny f.>:r mtans
• prescribed by the Administrator, w-.: ihall Inc1. .,, -ul lowing
Information:
• (a) The name and address .• - ---...,'• .-., c
(b_) The location -f T. , • i .
• (£) The total n.c., : v,,i . , i.y b; : , ..' .iu>' U.t-
• constructi . ^.odlf ii--tn • <-..' the facillt-
(d_) The normal hocy. • CM- ' ;r cf tnr; ; ' ' : , -a
•
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the enternr^es ." • a, * . U. .'• It se* -•
(1) •
tne .
(3) '
fro-.
fact
tne •-
(h) ,'•;,
I for carbu -...
(1) An 65
I resulting i /•«.
• calculate-
(i) Ar- e i
|
• subparagr - -
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(11) A separate application 1s required for each Indirect source.
(111) Each application shall be signed by the owner or operator,
which signature shall constitute an agreement that the applicant will
assume responsibility for the construction, modification or
operation of the source 1n accordance with applicable rules and
regulations, and the design submitted in the application.
(iv) Any additional information, plans, specifications, evidence
or documentation that the Administrator may require shall be
furnished upon request.
(4) No approval to construct or modify will be granted unless the
applicant shows to the satisfaction of the Administrator that:
(1) The source will be operated without causing a violation of
the control strategy which is part of the applicable plan, and
(1i) The emissions resulting from the mobile source activity
associated with the facility will not prevent or interfere with
the attainment or maintenance of the national ambient air quality
standard for carbon monoxide.
(5) Within 30 days after receipt of an application, the Administrator
will notify the public by prominent advertisement in the region
affected, of the opportunity for public comment on the Information
submitted by the owner or operator.
(i) Such Information, including the Administrator's analysis of
the effect of the facility on air quality and the Administrator's
proposed approval or disapproval, will be available in at least
one location 1n the region affected.
-------
I
(11) Public comnents submitted within 30 days of the date
I such Information 1s made available will be considered by the
M Administrator 1n making his final decision crt the application.
(111) The Administrator will take final c;, ttor on an application
• within 30 days after the ri of the nt'S' •.: c: :< r-ri period. The
Administrator will ratify \>.< -u-'plieanr, ir, rvnm,*] of n;s approval,
• conditicral appi^.il, .' ? • ff the ,: , i.^ticr,, and will set
m forth his rtasuiu for ~uuM ticnal approva: cr denial.
(6) The Administrator ;: , impusi- if, reasond;--1 - -,c^' ions on an
• approval, including • .difu.ns ;, ' in-..' t»'(. ',..•..•.• ovrfr or crf ratoif
to conduct airibiert ai / quality • •,.'i r..,! ing in 1M • vic'-.-.t^- of trie site
• of the source for a rp.-sonaM; r- " ' ;.'ri;r •. • --' .-„ r,-.\\-
m struction or nnodificn- ^r., dr.,.,,, f*.-. , -:'.•>. ""<•- ^ • the
facility '.as commence': op-,'"^
• (7) Approval to co,-,.-" ;"ut i :•)• ;;uoi -.rr11 '•-•>'•. . ;/ .. - o>"
operator of the re. por-.".,]','•,_. '•.'*••. • . ;.
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and all lo."?!
applicable D>
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Figure 1
COMPLEX SOURCE TIME SCHEDULE
1973
1. U.S. COURT OF APPEALS - DECISION
NRDC v. EPA
2. EPA MET WITH NRDC
PETITION THE COURT - ESTABLISHED
A TIME SCHEDULE FOR ACT I, -N,S
3. DISAPPROVAL r- M"
4. PROPOSED REGULATION? l ;-_;•:-•-
-------
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1
1
[Inclosed
model "HIWAY".
by the actual
Exampje Aj)j>1 i cation of IIIUAY Model
is a sample run of fJPA's interactive line source diffusion
A brief description of this program is given first, folio, /ed
run. In this example, a roadway of 1 kilometer was chosen,
with a receptor located half-way down the roadway, 15 meters from the side
1
1
of the road on
density ("line
the downwind side and 2 meters above ground. The emission
source strength vector") of .00308 grams/second-metes* corresponds
to a traffic volume of 100 vehicles/hour travelling at 5 miles per hour in
urban traffic
conditions. Assumed is a 1975 vehicle age and use distribution,
class "D" atmospheric stability, a wind speed of 1 meter/second. The angle
1
1
between the di
concentration
rection of. the wind and the roadway is 20 degrees. »The resulting
of 1.529 p. p. in. carbon monoxide can be multiplied by the
following factors to obtain the correct concentration corresponding to other
vehicle speeds
'
Vehicle Speed (moh) Factor
1
1
1
1
1
1
1
1
1
For the 30 mph
obtain a plot
use two endpoi
vehicles/hr).
10 0.70
15 0.50
20 0.40
30 0.33
50 0.30
condition, the resulting concentration is .505 p. p.m. To
of CO concentration in p. p.m. vs. traffic in vehicles per hour,
nts of (.505 p. p.m., 100 vehicles/hr), and (5.05 p. p.m., 1000
!**•
'
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EPA/RTCC/RTP NC Time Sharing System
TSL- Time Sharing Library System is now released.
READY
h i wa y
DO YOU WANT A DESCRIPTION OF THE EPA "HIWAY" MODEL
BEFORE APPLYING IT?(YES OR NO)
yes
,THE EPA "HIV/AY" MODEL COMPUTES INERT POLLUTANT CONCENTRATIONS
VICINITY OF A ROADWAY ON A SHORT TERM BASIS (HOURLY AVERAGES)
THE GAUSSIAN PLUME FORMULATION. IF MORE THAN ONE ROADWAY IS P
SUPERPOSITION APPLIES. THE MODEL CAN BE USED FOR AT GRADE AND
SECTIONS.
IN
US I:
ES:1
CUT
.THE COO I
WEST TO
RELATED
ID I NATE SYSTEM IS ARRANGED SUCH THAT THE X-AXIS INCREASES F!
EAST
WHI LE
TO HIGHWAY
THE Y-AXIS INCREASES
MEASUREMENTS AP.E IND
FRCf! SOUTH
CATED BY A
USER UNITS
TO
FACTOR
KILOMETERS
UNITS
KlLOMETERS
METERS
FEET
MILES
UNITS APPLY
THE MOST FREQUENTLY
SCALE FACTO,<
1.0
0.001
0.000305
1.61
EXCEPT WHEN OTHER UNITS
TO NORTH. THE UI
SCALE FACTOR O
USED FACTORS ARE-.
ARE SPECIFICALLY
SCALE
REQUESTED.
.THE EMISSION DATA IS DEPENDENT ON VEHICLE SPEED,TYPES AND NUMBER
VEHICLES,AND EMISSION CONTROL DEVICES.THE PROGRAM WILL GENERATE A
EMISSION RATE BASED ON AN ESTIMATE OF AVERAGE ROADWAY SPEED AND
VOLUME OF TRAFFIC.ALTERNATIVELY,THE USER CAN ELECT TO SPECIFY HIS
OWN EMISSION RATES IN GRAMS PER SECOND-METER. TilF LATTER APPROACH
HIGHLY PREFERABLE SINCE THE INTERNALLY GENFRATED RATE IS CASED; UP
A SPECIFIC AUTOMOBILE MIX WHICH DOES NOT APPLY ACCURATELY IN MOST
INPUTS ARE ENTERED FOR EACH LANE STARTING WITH THE DOWNWIND LANE.
.COORDINATES OF THE ROAD CORRESPOND TO THOSF OF A LINE ON THE DO1,.1:!
EDGE. WIND DIRECTION IS DERIVED BY
OF
DUE NORTH.(E.G.,WIND FROM NORTH
THE PROGRAM
RECEPTOR
-YOU MUST
, FOR MOST
CONTAINS THE OPTIO
MEASURING CLOCKWISE(EAST) FRO,'
0 DEGREES;EASTERLY WIND IS 90
EVALUATE' ANY NUMBER OF
ROADS.
TO
LOCATIONS AND/OR TYPES OF
SEPARATE MULTIPLE INPUTS WITH COMMAS.
APPLICATIONS,THE HEIGHTS OF THE RECEPTOR AND
SOURCES
ARE ASSUMED TO BE THE SAME
ENTER SCALE FACTOR.
HITER LINE(ROAP) ENDPOI NTS.(ORDERED PA IRS:X1,Yl,X?,Y?)
-------
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0, 0, 0, 0
CUTER EMISSION III'. I GMT. (METERS)
•>
0
ENTER WIND DIRECTION (DEG). NORTH IS ZERO.
7
250
ENTER WIND SPEED (METERS/SEC).
'i
I
ENTER MIXING HEIGHT (METERS).
7
3000
ENTER PASQUI LL-TURNER STABILITY CLASS (1-5).
7
It
ENTER THE NUMBER OF LANES.
7
1
OC, ,'OU WISH TO ENTER YOUR OWN EMISSION RATES?(YES OR NO)
yos
ENTER LINE SOURCE STRENGTH VECTOR. (A VALUE FOR EACH LANE)
?
.00308
IS THIS A CUT SECTION? (YES OR NO)
no
ENTER HI WAY WIDTH (METERS) .
ENTER WIDTH OF CENTER STRIP (METERS)
ENTER NUMBER OF RECEPTOR LOCATIONS DES I RED . (MAX I MUM OF 25)
rj
1
IKJ5l»017A TERMINAL ERROR, REENTER INPUT
1
ENTER RECEPTOR COORDINATE SETS.U&Y IN SCALE FACTOR UNITS;Z IN METERS)
?
.5, .015, 2
END POINTS OF THE LINE SOURCE
0.0 , 0.0 AND 1.000, 0.0
EMISSION HEIGHT IS 0.0 METERS
EMISSION RATE (GRAMS/SECOND*METER) OF 1 LANE(S)
0.003
WIDTH OF AT-GRADE HIGHWAY IS 5.000 METERS
WIDTH OF CENTER STRIP IS 0.0 METERS
WIND DIRECTION IS 750. DEGREES
WIND SPEED IS 1.0 METERS/SEC
STABILITY CLASS IS k
HEIGHT OF UP IT ING LID 15 3000.0 METERS
THE SCALE FACTOR IS l.OOOOKM.
-------
R
E
C
EPTOR LOCATION HEIGHT CONCENTRATION
X Y Z (M) UGM/CU METER PPM
0.5000 0.0150 2.0000 1757.417 1.529
YOU HAVE THE OPTION TO RUN THE MODEL FOR A NEW RECEPTOR LOCATION
(LOC),OR TO CHANGE THE ROADWAY TYPE,OR TO END THE PROGRAM.
ENTER LOG, OR TYPE, OR END.
end
READY
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I
UNITED STATES ENVIRONM€NTAL PROTECTION AGENCY
•Office of A1r Quality Planning and Standards
Research Triangle Park, North Carolina 27711
UBJECT: Additional Programs which are now Available DATE: July 11, 1973
• . Qgrjrtd NehlSj Cn1ef
Data Management Section
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Upon request we can send card decks and operating instructions
for the following programs.
TO: NEDS/SAROAD Contacts
We have some programs which are now operational in a batch
mode. Since we shall be devoting most of. our efforts to conversion
over the next 5-8 months, we shall not be able to add these to the
ISO system. However, we would like to make them available to you
so that you can run them on your RJE terminal if you so desire.
Program #1: SAROAD hourly ' isriny.
Lists all data with a samiHiny l^tervcu >n 12 hours or
less, Also creates running qy^rfyt
Program #2: NEDSemlss'u^i ^.-^iary
Summarizes emissions •;• :/ Various cat^gor es fc-r county,
— state, AQCR, and '.ation,
™ Prooran; #2: ^'-:- •• ;: '-t sour;-,-
I
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•Present^ * • •'-' •• ;.....,- „ !tJ, ,.- jc; io- o»-
the nation, a .-:., -ji. qud!1t/ • nrtr-c-i rpqio;:
Program ^b: hijj'^ -, . ,
I
'..1 i>*"S Sfe i fci, vfid
meters MI reel ?r yv;
encloseu-
Program
Counts the '-.unt-J! ,•' ,; , •*, plant-pr. = .',•!:,
point-SCC's by sr.ate.
Program #6: A1 K- ..o ,-,> j _f£
Lists for a plar-.i : ..-• ; u t. and SCC cho
EPA Form 1320-6 (Rev. 6-72)
-------
vs allowed emissions. A memo defining the availability of
this program should have been sent to the regional offices
by the Standards Implementation Branch.
We are enclosing sample outputs.
If you want any or all of these programs and their documenta-
tion, please contact either Carolyn Chamblee or me.
There are two other programs which we are now developing and
hope to make available to you by the end of August.
1. Emissions/Air Quality report
A report by AQCR containing the following information:
AQCR population
Land area of AQCR
Priority of pollutants in AQCR
Point and area source emission totals by pollutant
For a year or multiple of years and by pollutant
the number of stations, maximum value, and max^-
mum yearly average for the stations meeting criteria.
2. Standards exception reporting system
A report defining the number of obser.ations and the
number of times the standards have bean exceeded by sampling
site.
Enclosure
-------
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Request for Condensed Point Source Listing
The first card Image shown on the accompanying form 1s used to
supply control Information which Is used by the job throughout one
computer run. Basically, there are six Hems of Information con-
tained on this card. The information is:
1) Pollutant. The user must select one pollutant to base the
run on. The computed emissions for this pollutant are
used in the value check against the specified minimum.
2) Minimum Value. The user can specify a value to be used in
the comparison to select only records for which the
computed emissions for the specified pollutant are
greater than or equal to the value entered. Zero
is used if no value is entered which causes all
records satisfying other criteria to be selected.
3) Sort Information. A maximum of 20 sort parameters can be
specified by the user. The order the parameters are
entered controls the order of the output. For example,
if the user wanted to list all plants within a state
in alphabetical order by name, the code 01 would be
entered in the two columns uncL SOr.T 01" and 10
would be entered in the 1>'o columns under "SORT 02".
The possible sort codes are listed on the form.
4) Confide'-- .ity. This option was allowed for future use
• >JT: :> net currently implemented. Currently all data
is selected regardless of confidentiality and should
be considered confidential. When the status of con-
fidentiality has been determined, this option will
be revised so that the user will have to specify
confidential data to receive that data in a request.
5) Significant Digits. This option allows the user to specify
the number of significant digits to be printed for
each number. If a value is not entered, three is used.
6) Units. If the units field is blank, the emissions are listed
in English units, i.e., short tons. If one is entered
the metric units, megagrams, are used.
Following the control card, the user can enter any number of
selection cards. The selection cards allow the user to specify state,
-------
county, plant number» point number, any or all of the four parts of
the source classification code (SCO), ownership, standard industrial
classification code (SIC), estimation method, and Air Quality Con-
trol Region (AQCR) to select on. Any one of these fields can be
specified or valid combinations can be specified. For example,
if the user was interested in retrieving information for all feder-
ally operated plants in Tennessee, he woujd enter 44 in the first
two columns and an "F" in column 21.
Please note that when you are specifying a county retrieval
you must enter both the state and county. Also when requesting a
particular plant number you must enter state, county, and plant.
To request a point you must specify state, county, plant, and point.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Kesearcn iriangie HarK, Nortn uronna 'iin\
NASN Decentralization
July 23, 1973
Robert E. Nellgan, Director i, ...nil signed by
Monitoring and Data Analysis Division (,Vi.,t i Nejjg3n
Surveillance and Analysis Division Directors
Regions I-X
The enclosed 11st Identifies the NASN station 1n your Region
which should be maintained, at least through calendar year 1975.
It 1s the same listing that was distributed during my April visits
to most of your offices and It was also Included fn the material
that I distributed at the Las Vegas meeting.
I believe that there 1s a consensus that the continuation of
the NASN program 1s vital to EPA. I also believe that we jointly
agreed to continue the operation of these sites and that any termi-
nations would only be-done by mutual agreement. If 1t becomes
necessary to terminate any of these sites, please Inform us 1n
writing Immediately. In our discussions, I stated that 1f 1n your
opinion that some of these sites should be turned over to the States,
that this would be acceptable. The only criteria that we asked 1s
that the States desire the transfer and have sufficient resources
to provide timely valid data.
Data obtained from most of these stations were used in prepara-
tion of the "trends" report which summarized national pronress in
reducing ambient levels of SOg and TSP. Continued collection of
these data should greatly assist EPA 1n tracking additional progress
in achieving standards and 1n relating causative factors (regulations
and emission reductions) to nationwide and regional air improvements.
Currently, the NASN provides the only data which can be used to
present these long-term historical air quality assessments. Further-
more, the NASN stations 1n some cases were used 1n the design of the
control strategy for the State Implementation Plans. Thus, continued
operation of these stations will enable EPA to detect If the SIPs are
effective in reducing the high concentrations. In addition, 1t will
enable us to verify and assess whether the air quality models used
are effective, predictive tools.
Because of the value of these data, 1t 1s hoped that a high
priority will be given to maintaining these stations and that commen-
surate priority will be given to assure accurate analysis of the
collected samples.
• CONCURRENCES
•*XH \
SWNAMI ^
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Region I (13 urban, 4 non-urban) (8 S02/N02)
07 0060 001 A01* Conn., Bridgeport
07 0420 001 A01* Hartford
07 0700 001 A01* New Haven
07 1240 001 A01* Waterbury
20 0960 002 A01 Me., Portland
22 0240 001 A01* Mass., Boston
22 0580 002 A01 Fall River
22 2160 002 A01* Springfield
22 2640 001 A01* Worcester
30 0120 001 A01 N. H., Concord
41 0120 001 A01 R. I., E. Providence
41 0300 001 A01* Providence
47 0140 001 A01 Vt., Burlington
20 0010 001 A03 Me., Acadia National Park
30 0140 001 A03 N, H., Coos County
41 0380 002 A03 R. I., Washington Co.
47 0360 001 A03 Vt., Orange Co,
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Together, the ten Regional lists contain a total of 183 urban
stations. At 102 of these stations (Identified by asterisks), the
SO? bubbler samplers should also be maintained. The ten lists contain
a total of 31 separately Identified as nonurban stations. These
stations are of unique Importance and should remain under direct EPA
operation Indefinitely, not only for the continuity of rural or back-
ground trends but also for the singular opportunity to analyze the
samples for background 1evela, of trace constituents.
Enclosure
cc: A&W Division Directors /
Dave Shearer
Elbert Tabor
Hl)AD:RENel1gan:lwr~rm 634, NCM Bldg., X447-7-23-73
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Region III (28 urban, 3 non-urban) (13 S02/N02)
08 0140 001 A01* Del., Newark
09 0020 001 A01 D. C., Washington
09 0020 003 A01 Washington
21 0120 001 A01* Md., Baltimore
39 0120 001 A01* Penn., Allentown
39 0140 001 A01 Altoona
3D 0780 002 A01 Bethlehem
39 3060 002 A01 Erie !
39 3880 001 A01 Harrisburg [
39 3960 001 A01 Hazleton !
3s 4450 001 ADI* Johnstown
39 7140 001 A01* Philadelphia
39 7260 001 A01* Pittsburgh
39 7620 001 A01* Reading
39 8040 001 A01* , Scranton
39 9160 001 A01* Warminster
39 9430 001 A01 Wilkes Barre
39 9560 001 A01* York
48 0920 001 A01 Va., Danville
48 1440 001 A01 Hampton
48 1840 001 A01 Lynchburg
48 2120 001 AC! New Port News
48 2140 001 A01* Norfolk
48 2440 001 A01 Portsmouth
48 2660 002 A01* Richmond
48 2700 001 A01 Roanoke
50 0280 001 A01* W. Va., Charleston
50 1760 001 A01 S. Charleston
39 1760 001 A03 Penn,, Clarion Co.
48 2890 001 A03 Va., Shenandoah National Park
48 3440 001 A03 Wythe Co.
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Region II (20 urban, 1 non-urban) (11 S02/N02)
31 0660 002 A01* N. J., Burlington Co. (Marleton)
31 0720 001 A01* Camden
31 1300 002 A01 Elizabeth
31 1700 001 A01* Glassboro
31 2320 001 A01* Jersey City
31 3480 001 A01* Newark
31 4140 001 A01* Paterson
31 4220 001 A01 Perth Amboy
31 5400 001 A01 Trenton
33 0660 001 A01* N. Y., Buffalo
33 4680 001 A01* ' New York City
.3 4740 001 A01 Niagara Falls
33 5760 001 A01* Rochester
33 C620 001 A01 Syracuse
33 6880 001 A01 , Utica
40 0380 002 A01* P. R., Bayamon
40 0550 002 A01 Catano
40 1080 002 A01* Guayanilla
40 1920 002 A01 Ponce1
40 2140 001 A01 San Juan
33 3340 001 A03 N. Y., Jefferson Co.
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Region V (40 urban, 2 non-urban) (24 S02/N02)
14 1220 001 A01 111., Chicago
14 1220 002 A01* Chicago
14 5620 002 AOI N. Chicago
14 5080 001 A01 Peoria
14 6700 001 A01 Rock Island
14 7280 001 A01 Springfield
15 1180 001 AOI* Ind., E. Chicago
15 1300 001 A01* Evansville
15 1380 001 A01 Fort Wayne
15 1520 001 AOI* Gary
15 1780 001 A01* Hammond
Ib 2040 001 ADI* Indianapolis
15 2980 002 A01* New Albany
15 3880 002 AOI* South Bend
15 4080 001 A01 Terre Haute
23 1180 001 A01* Mich., Detroit
23 1580 001 AOI* Flint
23 1820 001 A01* Grand Rapids
23 2840 001 AOI* Lansing
23 4860 001 A01* Saginaw
23 5120 001 AOI Trenton
24 1040 001 AOI Minn., Duluth
24 2260 001 AOI* Minneapolis
24 2320 001 AOI Moorhead
24 3300 001 AOI St. Paul
.36 0060 001 AOI* Ohio, Akron
36 1000 001 AOI* Canton
36 1220 001 AOI* Cincinnati
36 1220 002 AOI* Cincinnati
36 1300 001 AOI* Cleveland
36 1460 001 AOI* Columbus
36 1660 001 AOI* Dayton
36 6600 001 AOI* Toledo
36 7760 001 AOI* Youngstown
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Region IV (24 urban, 3 non-urban) (14 S02/N02)
01 1480 001 A01 Ala., Gaclsden
01 1860 001 A01 Huntsville
01 2460 001 A01* Montgomery
10 1960 002 A01 Fla., Jacksonville
10 2700 002 A01* Miami
10 3980 002 A01* St. Petersburg
10 4360 002 A01* Tampa
11 0200 001 A01* Ga., Atlanta
11 1280 001 A01* Columbus
11 4500 001 A01* Savannah
18 0080 002 A01 Ky.s Ashland
18 0320 001 A01 Bowling Green
18 0800 001 A01* Covington
18 2300 001 AQ1* Lexington
18 2380 002 A01* , Louisville
34 0700 001 A01 N. C., Charlotte
34 1160 001 A01 Durham
34 1740 001 A01* Greensboro
34 4460 002 A01 Winston-Salem
42 1180 001 A01 S. C., Greenville
44 0380 001 A01* Tenn., Chattanooga
44 1740 002 A01 Knoxville
44 2340 001 A01* Memphis
44 2540 001 A01* Nashville
10 1680 001 A03 Fla., Hardee Co.
34 0590 001 A03 N. C., Cape Hatteras
44 0680 001 A03 Tenn., Cumberland Co.
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Region VI (13 urban, 4 non-urban) (9 S02/N02)
04 1440 001 A01 Ark, Little Rock
04 2740 001 A01 W. Memphis
19 0230 001 A01 La., Baton Rouge
19 2020 002 A01* New Orleans
19 2740 001 A01 Shreveport
32 0040 001 A01* N. M., Albuquerque
37 2200 001 A01* Okla., Oklahoma City
37 3000 001 A01* Tulsa
45 1310 002 A01* Tex., Dallas
45 1880 00.1 A01* . Fort Worth
45 2560 001 A01* Houston
45 4060 002 A01* Pasadena
45 4570 001 A01* San Antonio
04 1760 001 A03 Ark., Montgomery Co.
37 0480 001 A03 Okla., Cherokee Co.
45 3530 001 A03 Tex., Matagorda Co.
45 5200 001 A03 Tom Green Co.
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Region V (Cont'd)
51 0840 002 A01 Wise., Eau Claire
51 1540 001 A01 Kenosha
51 1860 001 A01 Madison
51 2200 001 A01* Milwaukee
51 2880 001 A01 Racine
51 3480 001 A01 Superior
15 2800 001 A03 Ind., Monroe Co.
15 3260 001 A03 Parke Co.
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Region VIII (7 urban, 4 non-urban) (3
06 0580 001 A01* Colo. Denver
35 0100 001 A01 N. D., Bismark
43 1480 001 A01 S. D., Sioux Falls
46 0680 001 A01 Utah, Ogden
46 0920 001 A01* Salt Lake City
52 0120 001 A01* Wyo., Casper
52 0140 001 A01 Cheyenne
06 1530 002 AG3 Colo., Mesa Verde National Park
27 0570 001 A03 Mont., Glacier National Park
43 0110 00.1 A03 . S. D., Black Hills National Forest
52 0860 001 A03 Wyo., Yellowstone National Park
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Region VII (11 urban, 2 non-urban) (5 S0z/N02)
16 0640 001 A01 Iowa, Cedar Rapids
16 1060 001 A01 Davenport
16 1180 001 A01* Des Moines
17 1800 002 A01 Kan., Kansas City
17 3560 001 A01 Topeka
17 3740 001 A01* Wichita
26 2380 002 A01 Mo., Kansas City
26 4280 001 A01* St. Louis
26 4280 002 A01* St Louis
28 1560 002 A01 Neb., Lincoln
?8 18F;0 001 A01* Oniana
26 4480 002 A03 Mo., Shannon Co.
28 2480 001 A03 Neb., Thomas Co.
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• .Region X (6 urban, 3 non-urban)(1 S02/N02)
102 0040 003 A01 Alas., Anchorage
13 0220 001 A01 Ida., Boise
38 1460 001 A01 Ore., Portland
I 49 1840 001 AQ1* Wash., Seattle
49 2040 001 A01 Spokane
| 49 2140 001 A01 Tacoma
• 13 0340 001 A03 Ida., Butte Co.
* 33 0440 001 A03 Ore., Curry Co.
• 49 0980 002 A03 Wash., King Co.
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Reg-ton IX (21 urban, 5 non-urban) (14 S02/N02)
03 0440 001 A01 Ariz., Maricopa Co.
03 0600 002 A01* Phoenix
03 0860 001 A01* Tucson
05 0230 001 A01* Cal., Anaheim.
05 0740 001 AQ1* Berkley
05 0900 002 A01 Burbank
05 21J40 001 A01* Glendale
05 410C 001 A?l* Long Beach
05 4180 001 A01* Los Angeles
05 5300 001 A01* Oakland
05 t,>:/- GDI A01 Ontario
05 5,-:0 001 A01* Pasadena
05 6400 001 A01 Riverside
05 6580 001 A01 Sacramento
05 6080 001 A01* . San Bernardino
05 6800 001 A01* San Diego
05 6930 003 A01* San Jose
05 7180 001 AQ1* Santa Ana
05 8260 001 A01 Torrance
12 0120 001 A01 Haw., Honolulu
03 0370 001 A03 Ariz., Grand Canyon National Park
05 3300 001 A03 Cal., Humboldt Co.
29 0560 001 A03 Nev., White Pine Co.
12.0080 001 A03 Haw., Hawaii Co. (Top)
12 0030 001 A03 Hawaii Co. (Bottom)
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ENVIRONMENTAL'PROTECTION AGENQJ
» *
1
Atin'of: OAQPS, CPDU, SIB • Dot,.- July 30, 1973
Subject: Requirement for Public Comment on Application for Construction or
Modification of New Sources
To: Director, Division of Air and Water Programs, Regions I - X
Principal Air Contacts, Regions I - X
The purpose of this memo is to einphasi7e the necessity for changes
to the States' new source review procedures mandated by the changes to
40 CFR 51.18 promulgated on June 18, 1973. In particular, the public
comment provisions (paragraph h) and the discussion of the basis for
determining which facilities should be subject to review (paragraph f)
apply to stationary sources as well as indirect sources. Thus, even
if a State cannot submit a plan for indirect source review due to
inadequate legal authority, the State should at least modify the
requirements for sto'.ionary source review to be consistent with the
revised require,!,?; Is of § 51,18.
The provisions for a public comment period must be in regulatory
form. As with any plan revision, these procedures must be the subject
of a public hearing. While the minimum requirements for public comment
are stipulated by § 51.18(h), the opportunity must be provided for
interested parties to express their desire for more comprehensive
public comment requirements, or for additional time for comment.
Care should be exercised to insure \,hat any time periods presently
specified in a State regulation for review of new construction or modifi-
cation applications are consistent with the required 30 day public comment
period (or t!-? public comment period established by the State—see
§ bl.lC(:.)(•:)).
We have received several inquiries as to whether the States can
utilize the diffusion modeling programs contained in the User's Network
for Applied Modeling of Air Pollution (UNAMAP) in implementing their
indirect source review procedures. The enclosed attachment describes
procedures by which States can access the UUAMAP programs.
n
D. Kent Berry
Standards Implementation Branch
Contro'i Programs
Development Division
Enclosure
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ENVIKONMCNTAl PROTECTION AC-i-NCY
National Env i mnnent al Research Center
Meteorology Laboratory
Research Triangle Park, North Carolina 27711
May 23, 1973
Thin is t .-, i.iforn you of the foi'iuataon of a Users' Network for
Applied ;kr>"! • ig of Air Pollution (UNAMAP) . 'ihe purpose of UNAMAP
is to avail O,-,LT<-nt air quality simulation models to both EPA and
non-EPA users via a teleprocessing network. The models involved are
all in the fr.n.i of computer programs acces.sable from remote terminals
connected to a central computer facility by telephone lines.
The Meteorology Laboratory with the support of the EPA Research
Triangle Co:.yp-:l er Center has availed UNAMAP to the EPA Regional
Offices via a teleprocessing network connected to an IBM 360/50
Eiainfrr.-.c at Research Triangle I'ark, M. C. The success of this
network har; pro:;.pt:ed tiic Meteorology Laboratory to extend the UNAMAP
to non-LTA •„!.-; ers via a corir.ercLal tcJeprocessi ng network. The
Computer Sciences Corporation (CSC) network (INl'ONET) has been
selected :.- fie ::;n--MY. outlet for UXA'IAP. CSC ras r. GSA contract
for teleprocessing services. The cost for this service is based
upon the resources used (i.e., computer time, storage, connect time,
etc.). Users will pay for taeir service through a direct agreenent
with CSC. EPA will assume the responsibility for storing the models
in a readily accessable node, updating the models and model inventory,
and providing a message service to the users concerning any UNAMAP
changes.
Several of the models can be executed "on-line" by a user who
interactively enters the control parameters specific to his problem
(i.e. wind speed and direction, source strength, stack height, etc.).
Other models require more extensive input data which involve developing
a data set separate from the program.
Currently, UNAMAP consists of the following models:
1) APRAC - The Stanford Research Institute APRAC-1A model
computes the hourly averages of carbon monoxic'e as a function of
extraurban diffusion from automotive sources in upwind cities,
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Intraurban diffusion from roadway :>ources, and local diffusion within
a street canyon. The model requires an extensive emission or traffic
inventory for the city of intercut. Kc-qtii remeiits and technical details
are documented in "User's Manual fur the APR \C-.l A Ur' an Diffusion
Mode] Computer Program" which is available from Nl'IS (accession number
rL'~213-C'Jl) .
2) 11IWAY is an interactive program which computes the short tern
(hourly) concentration of non-reactive pollutants downwind of roadways.
It is applicable when uniform wind conditions and level terrain exist.
It is best; suited for at-grade highways, but also can be applied to
depi es:>fd highways (cut sections).
3) CDM - Thr flimatological Dispersion Model (COM) determines
long term (sea^-:,,] or annual) qnaiu-stable pollutant concentrations
at any grf'.inc' ]• •-•' receptor using average emission rates fron
point (-.}• :. arc ' -• -itces and a joint frequency distribution of wind
direct .10,-. s ":r, • jpeed , and stability for the same period. This model
differs iro^, L.'I? Air QviaJity Display Model (AQD:i) primarily in the
way in which concentrations are determined from area sources, the use
of Brigp.s1 p-on-.e rise, and t'ue use of an exponential increase in wind
speed with height dependent upon stability. CDM uses a separate data
set for the area of interest.
A) FTMAX is an interactive program which performs an analysis of
the maximum, .-/aort-tenr. conerntraiion from a point source as a function
of stability di-i] wind spc-fd,
5) rii'I:- is an j nteract ive program \;hich computes short-term
concent rat J.r>ns do"."! wind from a point source at distances specified
by tbr r"--r.
6) PTMJP is an interactive program which computes, at multiple
receptors, short term concentrations resulting from multiple point
sources,
All the. interactive models arc documented as the programs are executed.
The CDM mode"! requires a source listing for a user to understand the
data i .' I" for its. ".inual.-. for the ;-ho\'C' mod.'ls are in preparation and
should be available ny .'.u'Mist 1973. (Al'KAC is now available as
previously mentioned).
The models listed in the previous paragraph are installed on
INl'OKET and ready for access. Other models will be added as they are
validated. This inventory will eventually include models in the
area of photochemistry, estimating concentrations in areas of complex
terrain, and estimating concentrations under stagnation conditions.
*) NTIS — National Technical Information Service, U.S. Department of
. Commerce, Springfield, Virginia 22151
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If you are. :: nt crested ir. accessing UNAVIAP via i:\TOXnT, contact
I Mr. Peter Lou:; of r;.;c (703-527-6080). For other inlormat ion relative
to (!K- imU'Js tii'\ ".I-] ves co'.;Lac! Mr. I). I'mce Turner or tlio v;riter
at the ] cttcrluTu] r.
• Sinccrciy yours,
. / <--"
' -• 7
* - V G, •
Ronald E. Ruff
I Chief
Computer Techniques Group
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GUIDELINE SERIES
OAQPS NO. 1.2-005
August 1973
GUIDELINES FOR EVALUATING
STATt. MND LOCAL AIR POLLUTION
CONTROL AGENCIES
•••^ ••/in..
3OC
US. ENVIRONMENTAL PROTECTION AGENCY
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina
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GUIDELINES FOR EVALUATING
STATE AND LOCAL AIR POLLUTION
CONTROL AGENCIES
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9 Control Programs Development Division
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_ July 1973
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f Information from Workshop
* • Research Triangle Park, North Carolina 27711
• December 5-6, 1972
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CONTRIBUTORS
Evaluation Process Don Smith
Type of Evaluation Dan deRoeck
Evaluation Criteria (Workshop Sessions)
Management Ray Morrison, Stu Roth
t
Engineering Tom Donaldson, Dan deRoeck, Greg Glahn
Enforcement Tom Wi11iams, Tom Cooper
Technical Services Frank Noonan, Neil Berg, Rick White
WORKSHOP PARTICIPANTS
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I
Section 1. The Evaluation Process ,
Background ,
I
State and local air pollution control agencies are encouraged
I through Federal financial assistance to develop effective programs
for the prevention and control of air pollution. The award of this
• assistance is intended not only to aid in the continued development
• of these programs but is also structured to support those agencies
demonstrating their ability to maintain a comprehensive control scheme
j| for reduction and abatement of air pollution. The Federal Register,
— Title 40, Part 35, State and Local Program Assistance Grants, provides
™ authority, criteria, and eligibility requirements for awarding of
• these grants. Three types of grants will be awarded in support of an
air pollution control program--pre-maintenance, maintenance, and
£ interstate planning. Grants may he made in amounts up to two-thirds
^ • • of the cost for pre-maintenanc? programs, three-fifths of the costs
™ supporting a maintenance program, and for amounts up to 75 percent
• of the estimated air quality planning program costs. The agencies
qualifying for support under the program can be municipal, regional,
| state, or interstate. However, limitations are placed on the number
_ of years that an agency can receive pre-maintenance support based on
the type of agency and number of budget periods (three or more or less
I than 3) the agency received support for between the years July 1, 1968
and July 1, 1972.
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A survey of State and local air pollution control agencies
conducted in the spring of 1971 indicates approximately 264 agencies
are operating programs that could receive some type of grant support.
The number of agencies currently receiving grant support range from
16 in Region X to 45 in Region V.
In determining the desirability of continuation of support, a
(
program evaluation must be made of these agencies' program objectives
and program performance. These program evaluations are to be scheduled
at least annually by the Environmental Protection Agency Regional
Offices and are to be conducted no later than 120 days before the
beginning of a new grant period. The effectiveness of these evaluations
and ultimately their impact on the agency and the meeting of the Clean
Air Act objectives depends critically on the purpose for which they
are conducted as well as how they are conducted.
The level of effort at which the Federal government.in cooperation
with State and local control agencies, conduct these evaluations could
consist of either (1) a checklist review of the application with
control agency personnel to be sure al'l items mentioned as criteria
in the regulations are addressed or a combination of limited review
of the submitted application; (2) an agency financial audit; and/or
(3) a complete study of agency operations with recommendations for
improvement.
APPLICABILITY OF AGENCY EVALUATION
The application of the evaluation program could thus take many
varied forms, entail many different procedures for conduct of the
evaluations, and could generally result in a non-uniform application
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of the grant's criteria and subsequent grant funding between the EPA
• regional offices. It is important, therefore, that established procedures
• and available criteria be provided so that consistent evaluation techniques
are applied to ARC agencies. The primary responsibility for conducting
g these agency evaluations is with the regional offices. The time involved,
— personnel required, writing of reports with recommendations and follow-up
™ of these recommendations will probably require expertise and personnel
i
• training requirements beyond that presently available in the regional
offices for making such evaluations. The purpose of this document then
| is to provide soin.. guidance and definition to the regions concerning the
g type of evaluations they should conduct and the procedures and criteria
™ to be utilized in any evaluation.
• COMPONENTS OF EVALUATION PROCEDURE
The regional office evaluation procedure should result in the
| ' resolution of conflicting interests between the pollution control agencies
f . within a state; an allocation of available funds and other resources that
will achieve the most effective contol of enforcement operation; establish-
• ment of a priority system for review and analysis of agency programs; and
of course cooperation between the Federal, State, and local governments
| in conducting specific programs that will result in eventual overall
w program improvement and achievement of national goals.
The overall mission of the grant process is to provide resources to
I State and local agencies to assist them in solving their air pollution
problems. The specific evaluations and analyses made of an air
| pollution agency must be directed toward improving the use of those
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resources to provide efficient operations that achieve control of air
pollution sources within the control program's jurisdiction.
In establishing an evaluation procedure to effectively and
efficiently serve this purpose, the Regional Office should consider
the following components as a part of its evaluation process:
1. Development of a screening mechanism to select agencies
' for review.
2. The use of adequate guidelines (criteria) for evaluation of
agencies that:
a. Reduces the time involved in the review process
b. Assures an adequate .estimate of the level of the
effectiveness of the agency.
3. The setting up of more adequate instruments for the collection
1 of data pertaining to the evaluation process.
4. The assessment of factors involved in evaluation of an agency
that affects national standards, implementation plan accomplish-
ment, budgetary considerations, and best means of assuring
control.
5. The extension of the evaluation procedure beyond appraisal
i
of effectiveness by assuring identification of agency needs
and formulation of programs for assistance to the agency.
Agency evaluations should not be exclusively the outgrowth of the
grants program, but should extend to the ARC agency an opportunity and
recommendations on which to base program development, planning objectives,
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resource needs, and criteria for reporting and measuring effectiveness.
A specific objective can be related to the different levels of analysis
• to be performed for an agency.
• The regional office should select a review technique, based on
criteria, that has as its aims:
• 1. The continual development of a review technique suitable for
, selecting agencies for intensive evaluation based on criteria
• that provides for follow-up to the agencies.
• 2. Includes the optimum means of evaluation, including subjective,
judgmental, or statistical methods.
I 3.. Documents the problems involved in the evaluation process as
well as documenting the ARC agencies' shortcomings.
• In general, the types of evaluation and analysis assistance that
• will be made available to the State and local air pollution control
agencies will fall into the following categories:
• 1. Grant evaluation - The evaluation made in conjunction with the
agency's grant application to review the agency's goals and
• program. This type of assistance should be geared to providing
• the agencies assistance in defining goals, outlining project
(milestones and accomplishments, and coordinating Federal program
| requirements with the agency so that the grant application can
provide an accurate estimate of each agency's needs and goals.
* These evaluations are performed for each agency on a yearly
V basis.
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2. Agency Performance Review - This evaluation is a complex
analysis and detailed review of the functions and activities
. of an air pollution control agency. It is intended to serve
the agency by providing recommendations for improvement of
operations; assist the agency in qualifying for maintenance
support; and when necessary, provide new direction, organization,
or program planning concepts on which to base a long-term
1 viable air pollution control program. This type of evaluation
should be continuous, and if possible, performed yearly to
supplement the grant evaluation review.
Section 2. EVALUATION AND ANALYSIS GUIDELINES
The purpose of this document is to present-the general guide of
factors that should be considered and the types of studies of an
agency that should be undertaken to assure that proper evaluation and
assistance is being provided to improve the agency's operation.
The guides present an indication of minimum investigative elements
connected with the review of agency program progress. It should be
recognized that each type of evaluation can be associated with the
agency's acceptability for grant award and its ability to carry out
enforcement provisions as outlined in the Clean Air Act.
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I Federally funded programs will be held more accountable for
demonstrating the effectiveness and efficiency of their operations. The
I program evaluation then, either through mechanisms of review of the grant
• application or actual observation of program operations, should provide
information to assist in making informed judgments concerning their
• termination, continuation, modification or the refocusing of an agency's
programs. The evaluation itself should provide the agency with a review
• report on which it can take corrective action concerning the strengths
• and weaknesses in its plans and activities.
Consideration of which evaluation to use at which time in an agency's
• stage of development will depend upon your ability (regional office
personnel) to recognize such need and the particular agency's ability
• to adopt and adjust to any requirements or recommendations that might
• result from such an evaluation. These guides will cover the following
areas of concern: (1) frequency of re iew criteria, (2) basic agency
I evaluation criteria, (3) specific program criteria, and (4) use of report.
I FREQUENCY OF REVIEW CRITERIA
Reviews of control agencies should be made to improve program operation
I and efficiency, to determine level of grant support, and to measure the
m overall capability of the agency to adequately implement a program of
enforcement to achieve national ambient air standards. The reports can
• then be broken into classifications, based on these reviews, such as
program improvement (grant evaluations), and agency program operation
I (performance). Under the classification of reviews for "program
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improvement could be placed planning assistance, pre-maintenance
reviews, and agency analysis reports. Agency program operations
(performance) would be (1) review of reports submitted by the agency
to fulfill implementation requirements, and (2) program analysis to
determine capability of the agency to adequately carry out and enforce
applicable implementation plans, new source performance standards, or
hazardous air pollutant emission standards. The type of report can
thus be classified as follows:
Report Program improvement Program operations
(grant evaluation)
Planning X
Pre-maintenance X
Maintenance X
Analysis X X
The frequency at which the various reports should be conducted
generally depends on the stage of development of the agency programs.
However, Federal Register requirements for grant support, and imple-
mentation plan timetables provide some guidelines on which to base the
frequency of reports for grant evaluation and program performance.
Evaluation, including application assistance, should be a continuing
program of the regions and should provide assistance to the agency in
determining the requirements of the Federal government. In addition,
factors of circumstance, opportunity, and individual agency requests
must be considered. The criteria for frequency of agency review for
each type of report can then be summarized as in Table II.
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I COOPERATIVE RESPONSIBILITY FOR PROGRAM REVIEWS AND ANALYSES
The responsibility for awarding program grants lies with each of
• the ten EPA regional offices. The primary responsibility for carrying
• out enforcement tasks also rests with the regional offices. The assistance
to the regional offices from cooperating groups should be directed to
• ^ providing a basis for regional office decision-making in these areas.
. Thus, the reasons for cooperative efforts with a regional office
• centralized group in formalizing evaluation reports are to (1) provide
• uniform guidelines and procedures for each regional office, (2) consolidate
expertise in a small centralized group that has program, administrative,
• and technical skills for conducting such evaluations, and (3) provide
an independent viewpoint to agency operations within a region, that may
• either reinforce or alter the recommendations, considerations, or views
• of that agency as held by EPA enforcement and technical regional office
personnel.
| A centralized regional cf "ice group cannot be expected to have the
^ personnels expertise, and resources necessary to perform all the
* evaluations and types of evaluations necessary for the effective program
• development of State and local agencies. To provide some guide for the
workload that can be expected and the criteria that must be considered
Q the following table is presented to represent the cooperative relationship
^ that each regional office should consider as useful in making a review
* of a control agency program.
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Cooperative responsibility
Report writing
Request Visit Interviews recommendations
Grant
evaluation E.G. E.G. E.G. E.G. & T.P.
Program
operation E.G. & E.G. &
evaluation E.G. T.P. T.P. E.G. & T.P.
E.G. - Evaluation Group
T.P. - Technical personnel
The participation level in the evaluations between the evaluation
group and other technical personnel depends on the lines of communication
established in the regional office and the support provided the
evaluation group by the other divisions. The level of participation
guidelines are the following:
1. Evaluation group coordinates and requests all evaluations.
Evaluation group prepares preliminary iiforniation concerning
problems anu needs for specific type of evaluations at selected
agencies.
2. Evaluation group has responsibility for reporting on all
pre-maintenance evaluations. Any assistance provided by technical
personnel would be directed at a specific program area such as
air monitoring and data handling,identified during review of grant
applications or visits to the agency.
3. The evaluation office should probably request outside review
assistance for all agencies requesting maintenance support to
reinforce or to provide program support regarding conditions for
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• rejection or acceptance of maintenance grant award. Criteria
• for maintenance grant awards are set forth in regulations, so the
evaluation office could theoretically provide this evaluation of
I an agency. However, judgment and interpretation of specific
program operations may require assistance from individuals skilled
" in enforcement, engineering, or technical services activities.
•"»--
• 4. Agency operation reviews should be considered as a cooperative
effort with maximum participation of regional office personnel,
• bpth qualifier technical personnel, and evaluation personnel.
_ These eval. rjUons are intended to develop statewide programs
* that will result in effective enforcement of State implementation
I plans or be a part of the procedure for involving EPA state
strategy for enforcement of implementation plans.
0 5. Assistance on specific progr^ 2re*»s identified during any
•t evaluation can be obtained a"i30 from headquarters components. As
expertise and documentation in areas of enforcement, permit
• systems, laboratory operations, and other agency functions are
developed, they are generally made available in form of procedure
• documents and/or guidelines.
• An agency evaluation essentially requires the scheduling of
activities as shown on Table I. If the evaluation involves only a
• review of the grant application then such items as field visits and
field work may be eliminated for that activity. Although it is strongly
• recommended that conferences be held with the State and local agency
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during the grant evaluation review to define goals, discuss agency
problems, and coordinate Federal program requirements. In some regions,
it may be important to establish a priority system which assists in
determining the specific evaluation activity that will be conducted and
provides for the explicit type of data that will be collected for any
evaluation review [operations (performance), or program improvement
(grant application review)]. In establishing this priority system,
factors that also pertain to overall criteria associated with program
objectives should be considered in addition to the guidelines summarized
in Table II pertaining to purpose, frequency of review and basis for review.
BASIC PROGRAM CRITERIA
In the evaluation of any air pollution control agency, consideration
must be given by the evaluator to the following basic influences that
affect control program operations:
1. The requirements of the approved implementation plan which
must be satisfactorily implemented to support national ambient
air quality standards.
2. The structure of State and local activities designed to achieve
the objectives in the State plan and to meet the Federal
reporting requirements for enforcement of the plan.
When making visits to local agencies, for the purpose of evaluation,
it is important that representatives of the State agency participate to
assure the above influences are satisfactorily addressed and any
problems that exist are fully discussed. Likewise, if possible, it
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would be profitable to have local agency representatives present during
• the evaluation visits to the State agencies, as the exchange of infor-
mation often resolves conflicting areas of program responsibility.
• In general, when reviewing the agency, the following criteria
• objectives should be considered as being important to satisfactorily
implement the State's plan:
• _ 1. Appropriate role of State agency in areas of direct involvement
in enforcement activities.
^ 2. Eliminate inefficient duplication of equipment, personnel,
• . and activities by seeing that agreements of understanding
exist between State and local agencies.
• 3. Determine that objectives move toward establishing minimum
— monitoring network for State and that special monitoring
• requirements above the minimum network are adequately justified.
• 4. Develop reporting data techniques on a statewide basis that
integrate into Federal report: ,^ requirements.
£ 5. Adequately define role of State and local agencies in regard
« to items such as enforecement authorities, permit systems, etc.
™ Criteria are provided in Table III and IV to assist in classification
tt of regional air pollution control programs and in defining the roles of
State and local agencies pertaining to specific agency operations.
| Complicating the overall evaluation of local air pollution control
_ programs is the reorganization of State programs usually a consolidation
" of environmental programs. Program consolidations often result in a
I redirection of priorities and sometimes change or mesh the familiar
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activities of the air program. Generally then, the level of effort in
terms of resources, objectives, and program activity are difficult to
obtain in the traditional program concepts by the evaluator. However,
applying the above criteria objectives enables the evaluator to at best
inform the agency of what is expected in carrying out activities to
achieve the implementation plan. In addition, when evaluating either
the grant application or performance of an agency the evaluator must
encourage and look for objectives that may accomplish long-range goals
and foster the continued development and enforcement of the SIP. These
include programs associated with:
1. Land use and transportation controls.
2. Review and development of impact statements.
3. Operation of permit systems.
4. Planning and growth considerations affecting air pollution
control.
5. Data systems that will assist in efficient agency operations
and provide for adequate reporting of data on statewide basis
compatible with Federal requirements.
Agency effectiveness is an essential consideration in the evaluation
of any air pollution control agency. Once a decision has been made that
an agency has developed adequate goals and objectives (perhaps the first
step of an evaluation), then key indicators of success (or failure) are
the measurable results which occur through actions taken to achieve
such goals and objectives. Therefore, measurements of agency effectiveness
should precede a comprehensive agency evaluation.
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The ultimate achievement of air quality goals is theoretically
scheduled for!975, or 1977, or sooner. Obviously, attempts to measure
• results prior to then must focus on intermediate objectives, or mile-
stones, that must be met. Progress reports, now required on a periodic
• basis from each State, provide an excellent means of documenting program
• achievements which may subsequently be measured.
If an agency's objectives are closely examined, three classes of
• measurable results can generally be formulated—air quality improvement,
emissions reduction, and source compliance. Realistically, each class
• has some cause and effect relationship to the remaining two, but from
• an evaluation standpoint there is measurable data which can be readily
obtained and which can be attributed to specific agency functions and
• actions.
For example, improvements in air quality will be documented by
• data collected through air monitorinn rctv.'ities. While air quality
• improvements may be indirectly inferred from actions resulting in
emission ructions and source compliance, air monitoring data provides
• a direct measure of improvement. Similarly, it may be reasoned that a
widespread improvement in air quality should infer that emissions are
• being successfully reduced; however, the direct measure of reduced
• emissions is provided through source testing activities and the develop-
ment of an emission inventory.
• The type of program evaluation, and the degree of effort which
should be devoted, can be determined by analyzing each agency's progress
• (measurable agency output), revealing difficulties or insufficiencies,
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and determining the relative urgencies of all agencies within a given
state, region, etc. Furthermore, it is possible to direct the evaluation
effort towards specific agency operations on the basis of any given area
of ineffectiveness where agency output does not demonstrate positive
progress or favorable results.
Program Elements for which State is generally responsible:
1. Basic statewide plan development and evaluation.
2. Basic operating procedures (forms, reporting formats, etc.).
3. Training (smoke scnools, skills upgrading, etc.).
4. Public Information program. (Partly.)
5. Special engineering skills. (Some localities require specialized
inspection and engineering .skills.)
6. Laboratory support (in particular special hardware and analytical
facilities). Local activities may be required for collection
of samples, and maintenance of sampl'ruj equipment, etc.
7. Major data handling facilities. Local data collection,
analys-'s, and reporting also require facilities and personnel.
8. Meteorological support.
9. Progress evaluation.
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Table I. AGENCY EVALUATION ACTIVITY SCHEDULE
PRELIMINARY
PREPARATION
FIELD WORK
ANALYSIS AND
REPORT
DEVELOPMENT
5.
6.
IMPLEMENTATION
7.
8.
SETTING
EVALUATION
PRIORITIES
SCHEDULE
FIELD VISIT
3.
OFFICE
PREPARATION
4. [SUE VISlTl
EVALUATION
CRITIQUE
REPORT PREPARATION
A.
B.
C.
SORT AND CATALOGUE
INFORMATION
ANALYSIS AND
DIAGNOSIS
PRELIMINARY DRAFT
AGENCY j
REVIEW
PROGRAM
ASSISTANCE
19
-Federal Register Requirements (Grants)
-Implementation Plan deficiencies
(Program development)
-Coordination with State and local
agencies for visit
-Preparation of agendas, request for
preliminary information regarding
agency activities, schedule for
interviews
•Selection of team members
•Study of agency information—review
and summarize--SIP, Quarterly &
semi-annual report, compliance
reports, and grant.
-Thorough study of agency operations,
interviews with agency support
personnel
-Obtain appropriate information and
material
-Meet on final day of visit with "key"
agency personnel to summarize
preliminary finding and conclusion
-Additional information is obtained
and existing information verified
wherever questionable
-Review recommendations in regional
office
-Copies of draft report are forwarded
to agencies involved
-Consultation and discussion with
agency. Joint review of report
increases agency receptivity,
adds clarification, and improves
report effectiveness
-Follow-up on final report recommendation
to provide additional assistance
and guidance in implementing
program recommendations
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Table II. GUIDELINES FOR EVALUATION OF AGENCIES
Grant
purpose
Pre-NaLntenance
Maintenance
•
•
Efficiency
review
Purpose
Program Improvement
Grant Evaluation
m
Program Improvement
Grant Evaluation
Program Operation
Frequency of
Review
Once per year
Once per agency
and updating of
baseline review
on a yearly
basis
Once per year
with follow-up
of recommenda-
tions « .,d SUD-
eequent reviews
as necessary
and requested
to improve pro-
gram operations
Basis for Review
1) Approval of grant
2) Consistency with
implementation plan
1) Perform baseline
review of agency
operations 18 months
prior to grant sub-
tnittal
2) Review for grant
approval 120 days
prior to grant
period
1) Program development
of local and State
program on Statewide
basis
2) Review of Statewide
program to measure
enforcement effec-
tiveness
3) Reorganization on a
Statewide basis
4) State programs
requesting maintenance
or extension of pre-
maintenance grant
time
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Table IV. CRITERIA FOR PROGRAM ORGANIZATION
AND ASSIGNMENT OF RESPONSIBILITIES
Program
level
Comprehensive
State and/or local
Moderate: local
Minimal
local
taffing3
^level
(Staffing level > 20)
(Staffing level=6 to 20)
(Staffing level < 6
ogram
enent
inagement
• Adminis t rat ion
(supervisory and
fiscal matters)
•Policy and planning
•Program Evaluation
•Public and inter-
governmental
relations
•Long-range studies
(land-use and
transportation;
•Evaluate environmental
impact studies
•Training
'Promulgate regulations
•Administer hearing
and variances
•Grant aipl i c?.'.icr.?
•tpisode and emergency
operations
•Clerical
'Minimal staff time
allocated to management
•Activity limited t,
direct staff
category. Mostly involves supervisors and
direct staff supervision
on program matters
• Some_ local and State
intergovernmental
liaison
•Grant applications
•Clerical
clerical support
'Liaison with State
agency
'Grant applications
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Table IV. (con't.)
Program j
•activity}
Comprehensive
State and/or local
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:nforce-
ent
ngi-
eering
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•Area surveillance
Source registration
Source inspections
and reports
Source data gathering
•Case documentation
•Legal actions
•Permit support
activities
•Complaint investigation
•Episode and emergency
activities
•Clerical support
•Permit systems
construction permits
operation permits
'Plan revitw
•Emission inventory
'Source testing
•Site inspections and
consul LoLion
•Regulation development
•Special tc-chnical
studies
•Cleric:. 1 svpport
Moderate: local
Minimal c: local
•Area surveillance
Source registration .
Source inspection
and reports
Souce data gathering
•Case documentation
•Legal actions
•Limited permit support
activities
•Complaint investigation
•Episode and emergency
activities
•Reporting as required by
State
•Clerical support
•Area surveillance
Source registration
Specified source
inspections and
reports
Data gathering
•Case documentation
•Legal actions
•Initial complaint
investigation
i
•Emergency and episode
activities
•Reporting as required
by State
•Clerical support
•Limited perr^c activity
for specified
pollutant source
categories
•Emission inventory
•Site inspections and
consultation for
specified source
categories
• Report, ir.g as required
by State
•No activities or
responsibilities
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Table IV. (con1t.)
Pro .m
activity
Technical]
support
Comprehensive
State and/or local
•Laboratory operations
, -Air monitoring
1 network
•Instrument maintenance
and calibration
•Source testing support
•Data handling
•Meteorology
•Special studies
•Legal documentation
•Clerical support
Moderate: local
•Laboratory operations
(very limited)
•Air monitoring network
Primarily servicing and
sample collection
Instrument maintenance
Limited calibration
•Limited data reporting
as required by State
•Assistance to State in
special studies
Minimal c: local
'Sample collection
limited instrument
maintenance
a Staffing level is the total equivale
designated agency.
man-years of effort in each
The degree of activitiy in local comprehensive programs for certain
functions would bo specified (for exc^ple, ail laboratory operations
would probably not be undertaken by a local comprehensive agency and
certain large source enforcement activities may be preempted by the
State agency).
The allocation of responsibilities would be specifically detailed by
the State agency. In general program activities. vuuld b« limited to
enforce.enc. activities associated wic-n area sources and the less
complex industrial scurcc-s. '
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FUNCTIONAL ALLOCATION OF MANPOWER RESOURCES
ON A STATEWIDE BASIS
Percent of Total
Functional Area Staff
!
Management - - 20 to 25
Enforcement • 25 to 35
Engineering 20 to 30
Technical Operations 15 to 20
• 10 to 20 percent of each area is
for clerical support
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In either a review of an agency's application for grant funds or an
"In depth" evaluation, the evaluator should seek to answer some basic
questions that pertain to operations. These questions can be structured
by functional activity as given by the example protocol document Appendix 1
In evaluating an agency, answers to the following overall questions should
be sought:
1. Statistics - Does the agency have the programs that define the
extent of the problems and program operation? This question requires
an agency to have programs such as emission inventory and air
monitoring networks. These data can be provided by the agency or
performed in conjunction with other agencies, but the system should
include proper reporting of the data.
2. Planning - Does the agency have the capability to adequately
analyze the data and develop a program with definitive program goals
and objectives?
3. Available Resources - Does the agency have the skilled manpower,
budget, facilities and/or a plan to obtain these resources to carry
out its role and responsibility under the SIP?
4. Necessary Action - Does the agency have the authority (rules
and regulations), legal assistance, and procedures required to take
enforcement action? Does the agency operate the preventive and
enforcement programs that are required to achieve ambient air
standards? These activities include planning programs associated
with growth characteristics of an area, land use and transportation
activities, impact statements, preparation and review, inspection
programs, and permit system operation.
/
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• 5. Assumption of National Programs - Has the age'ncy asked for
'and received the delegation to carry out national programs
I such as the enforcement of national new source performance
• standards, and hazardous pollution standardsT What Federal
action has been necessary by the Federal Government to enforce
• the ambient air standards, promulgated regulations, or specific
"~ implementation plan strategy (transportation controls) in the
• State or within the local area? The local and State control
• . agencies should be encouraged to avoid Federal enforcement
except in partnership considerations beneficial to both
• governmental levels.
Rating the above areas undoubtedly are judgmental on the part of
8 the evaluator unless he carefully uses the definitive criteria to measure
m the agency against. An experienced evaluator skilled and knowledgeable
— in a control agency's operation can deve.~p important recommendations by
I asking a few critical questions. However, uniformity and perhaps eventually
measures of cost effectiveness can be obtained from agency evaluations
I by structuring specific questions and formulating data collection systems.
• REPORTS
As the regional offices develop their evaluation, analysis and
• review techniques, the State and local agencies should be encouraged to
document their records, procedures, and guidelines. In any on-site visit
• to an agency the evaluator should ask to see copies of records, agency
• activities, and of statistical concrete results. Agency documentation
should include such things as:
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-Description of functions and activities carried on by the agency.
-State and local agreements as to respective functions and
responsibilities.
i
-The agency's goals and objectives with dates for achievement.
-A compilation of agency policy statements.
-A compilation of agency procedures used in program operation.
The agency should be requested to keep these records, procedures
in a standard operating manual. This manual should be compiled and
updated in a manner that keeps it available for review. Records of
this type serve as an evaluation tool for external evaluation and it
also aids the agency in conducting a self-evaluation. Records of this
type, if presented properly, would give an adequate picture of the
agency's general plan, delineate responsibilities, and set schedules
and assignments. It would be helpful if the regional EPA offices suggest
to the agencies a general format for the manual which could be set up
along the following lines:
1. Definition of the scope and objectives of the effort.
2. • Definition of roles and responsibilities under the SIP.
3. Categorical program description that defines measurements made
and data output specifications. Include:
a. Air quality measurements
b. Meteorology measurements
c. Calibration procedure
d. Emission inventory
e. Permit system
f. Management data.
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II
4. Description of personnel, equipment, and resources committed to
• effort and effort contributed by other organizational components.
In case of a State agency this may be district offices or agreements
I with local agencies. i
5. Schedule of operation pertaining to the activity including:
• a. "In-house" and field operations (inspections)
• b. Number and frequency of samples, analyze
— c. Data reduction and summary
• d. Frequency and dates for report.
— 6. Procedures that describe roles, responsibilities, and
" relationship for the activity including:
• ' a. Administrative support-obligation of the respective agencies
in terms of personnel, budget.
| b. Respective duties assigned to each agency in regard to
• maintenance and operation of equipment, inspection priority
—- (class or type of industry or e iprnent) and enforcement a'
I authority).
c. Liaison performed between respective agencies and overall
I responsibility for project supervision.
• 7. Outline of procedures and responsibilities of data collection
and interpretation including:
i
I a. Forms
b. Tabulation
• c. Distribution procedures and schedule of distribution
• d. Major uses of data
e. Brief description of data output and if data system involves
• participation of other agencies, a description of what those
data are.
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When the agencies have this type of information available, the
agency will find that they operate more efficiently. Also, the job of
the evaluator becomes much easier. In order to give emphasis to this
type of reporting system by the agencies, the regional offices could
format their findings and recommendations in a similar manner.
Thus, the suggested format for evaluation reports would follow
along the same lines as the operational manual and consist of the
following components:
1. Comparison of objectives against SIP and Federal program
requirements and regional or national operating norms.
Recommendations for new objectives and timetables are
necessary.
2. Recommendations regarding cooperative operation of activities,
new and more efficient organization of activities, joint
protocol documents, allocation of resources and elimination
of unproductive duplicative efforts.
3. Analysis of resources committed to effort.
4. Recommendations regarding data collection and handling systems.
5. Recommendations regarding scheduling of operations.
6. Analysis of district and local operations if they reflect
on agency.
7. Recommendations concerning data reporting and collection system.
8. If appropriate recommendations associated with long-range
planning for meeting anticipated Federal requirements regarding
stationary and mobile pollution sources.
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Section II
.AIR POLLUTION CONTROL AGENCY EVALUATION
Specific Criteria
As the State and local control agencies move clpser to the deadlines
imposed for meeting ambient air standards it will become increasingly
important to have data which measures an agency's effectiveness in
utilizing their program operations and resources. It appears that the
funding for such agency operations from the Federal viewpoint will not
be sufficient to support all activities that Statt? and local programs
have need for or would like to carry on. As pointed out previously in
these guidelines, the Federal guidance and support to State and local
agencies should then be directed to strengthening those skills and
capabilities that will achieve national standards, and enforce regulations
and strategies designed to carry out .implementation plans.
The specific evaluation procedures should be designed to identify
agency operations and make recommendations for improvement. Eventually,
it should be possible to allocate the available resources, State and local,
on the basis of priority and need. Then ~e, the specific criteria
given for each area of an air pollution control agency's operation,
administration, engineering, enforcement, and technical services are
intended to provide information on a comparable manner from agency to
agency. Eventual refinement of the system, if used either on a nationwide
or regional basis, should provide a data base for comparison of agencies
against a regional or national norm, provide a measure of efficiency,
and as historical, air monitoring, emission data, and growth data trends
are established give some picture of the cost effectiveness of the dollar
expenditure by the control program.
In Section I, basic program criteria were provided to give the
evaluator an understanding of the influence national priorities should
play in the evaluation of State and local programs. These objectives
31
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must be kept in mind and are indicated as priority objectives on the
report form for each program area. The evaluation data collection
procedure obtains data in several ways: ,
1. Quantitatively - for measurement against operating norms
of the programs within a region or on a nationwide base.
2. Qualitatively - subjective judgments made by the evaluator, and
3. Use of rating number or priority for operation and comparison
to its importance for achieving implementation plans, or
other Federal priorities.
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Schedule A
AIR POLLUTION CONTROL AGENCY
EVALUATION DATA REPORT
General Information
Agency Name
Fiscal Year
to
EPA Region
AQCR Name
(if not state agency)
Evaluation Date:
Review
Visit
AGENCY DESCRIPTORS:
I. Jurisdiction
II.
A.
B.
Population served
Growth rate %
1.
Operating Resources
A. Total Staff
1. Positions
2.
Population
(annual)
Sources (annual)
Industrial
C.
D.
Mobile
Area served (m
Value mfg. $ x 10
2. Man-year estimate
Total Budget
1. Personnel
2. Operating exp.
6
3.
Equip. & contractual
services
Implementation Plan Resource
1975 1977
1. Staff
2. Budget
Criteria Measurement
Operating Cost/Man-year
PROBLEM DESCRIPTORS:
I. Air Quality
Annual Highest
average value
Particulate
Sulfur dioxide
Nitrogen dioxide
Carbon monoxide
Hydrocarbons
Oxidants
Other-specify
ugm/m"
*i
ugm/nf
f
ugm/nT
*•
ugm/nf
ugm/nf
f
ugm/nf
f
ugm/m"
II. Emission Data
(Annual tons/yr.)
Particulate
Sul/fur dioxide
Nitrogen dioxide
Carbon monoxide
Hydrocarbons
Other-specify
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Schedule A, pg. 2
Schedule A
General Information
Suggested Sources of Data
AGENCY DESCRIPTORS:
I. Jurisdiction - Department of Commerce, Bureau of Census
Population Reports - 1970 and Interim Year Reports.
Department of Commerce, Bureau of Census
Manufacturing Census - 1967 Data - Update with
data from Agency Emission Inventory Permit System
and other local sources.
II. Operating Resources - Agency grant application - update
through contacts with agency.
PROBLEM DESCRIPTORS:
I. Air Quality - Semi-annual and annual reports - quarterly reports
are principal source of air quality data.
EPA data reporting system SAROAD, CDHS, etc.
Agency reporting records.
II. Emission Data - EPA data reporting system - NEDS (State)
Agency Emission Inventory.
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| Schedule B 'AIR POLLUTION CONTROL AGENCY
1
EVALUATION DATA REPORT
Management Function
Definition of Responsibilities:
I I. Program responsibili
Implementation plan
1 ^ Implementation plan
ties defined for agency activities in: (encircle one)
and interagency agreements - 5
(approved) - 4 Grant application - 3
Interagency agreements - 2 Not defined or poorly defined - 0
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III. Program Responsibil
1 Enter one: State
only 1
•Planning
.
Criteria score
ity Summary Management:
Shared with Delegated Partial Other,
state 2 by state 3 delegation 4 specify 5
Services Evaluation
SIP review, revision, etc. Training by Impact reviews
I— Land use controls
__ Transportation controls
I
• Complex Sourcp Siting
Special Action Plan
initiation
Outside (emergency, SCS)
agency
Program Review
Informational
(library, public, and
inf. retrieval and
dissemination)
I Region's Estimate of Responsibility Priority I, II, III,
1
1
1
1
1
1
IV, V
•
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schedule B, pg. 2
Program Objectives: (Select one)
I. Objectives are consistent with following:
Achieving and maintaining Federal or other applicable air quality
standards as defined in the approved implementation plan, and
maintenance support as defined in the Federal Register 5
Achieving only the Federal or applicable air quality standards 4
Achieving only maintenance support as defined in the
Federal Register 3
Achieving none of the above 0
Criteria score
II. Review and Evaluation of Objectives: (subjective) Select one.
Clearly defined 5
Poorly defined (indicate areas) 3
Incomplete or unrealistic 1
Not defined 0 Criteria score
III. Program Plans for Achieving Goals indicate following:
Specific target dates and resource requirements 3
Resource requirements only 1
Target dates only 1
None of above '' 0
1 Criteria score
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Schedule B, pg. 3
Resource Criteria: Enter estimate of resources needed by agency as given
in SIP or by other estimating procedure. Circle approximate % that
current resources represent.
I. Needs (Total agency)
% Estimate of Achievement of Need
SIP
1975
1977
Other (manpower model, etc.)
1975 1977
% Budget
Budget
Man-years
% man-years
If lt)0% indicate here
50, 75, 90
50, 75, 90
50, 75, 90
50, 75, 90
50, 75, 90
50, 75, 90
50, 75, 90
50, 75, 90
Also describe needs outside implementation plan
Criteria score
>75% - 4
<75% - 0
II. Per>unr
A.'ministrat\ve Services Staffing Pattern (man-years)
Total Legal Policy
General Information Planning & eval. _
Training Financial Other
III. Vacancy rate - (Total agency)
Number
vacant
% of total positions
vacant
Budgeted positions
Man-years
Turnover rate - circle one
5% 10%
Criteria score: 5 4
15%
0
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Schedule B, pg. 4
IV. Organization
Agency has: Y_es_ No_
1. Organization chart 1 0
2. Functional statements 1 0
3. Agency procedures that clearly
define responsibilities 3 0
Criteria score
V- Facilities - circle applicable criteria score for each agency operation
Sq. footage per person
150
100
75
Administration (per person)
Engineering
Enforcement
Technical Services lab
Data handling
Enter total ft2 available
5
4
4
3
5
4
3
3
2
4
0
2
2
0
0
Administrative Services
I. Training - Current Fiscal Year
A. Total number man-weeks
New employees
Existing employees
New staff
Criteria score
Man-weeks avg.
(1-2) (3-5) 1-3) 1
5 3 1
5 3
B. Program
Yes
Written, formal training program
Orientation for new employees
Outside training program
Identifies new training need?. & skills
No
0
0
0
0
Existing staff
0
0
0
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Schedule B, pg. 5
II. Public Information and Education(circle answer)
A. Program Criteria Yes No
Budgeted, with functional statement 1 0
Full-time or part-time employee assigned 1 1
B. Program Services
Criteria score
Reports
Annual
Quarterly
Monthly
Yes No
0
0
0
News Media
Yes No Number
News release 1
Radio & TV release 1
Radio & TV
appearance 1
0
0
Distribution List
Speakers
Civic & school
Citizen groups
Industry
Yes No Number
0
0
0
Publications
Number distributed
Number of kinds
Special Status Reports Yes No
Compliance 1 0
Air monitoring 1 0
Special problems
(new regulations) 1 0
Criteria measurement
Number/100,000 population
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Schedule C
AIR POLLUTION CONTROL AGENCY
EVALUATION DATA REPORT
Engineering Activities
Program Responsibility
I. Program Responsibility Summary Engineering
Enter one: State Shared with Delegated Partial Other,
only 1 state 2 by state 3 delegation 4 specify 5
Information gathering Enforcement Support Planning
Emission inventory Source testing Regulations
Permit system Source inspections Special Studies
Other, specify Permit Land use
Transp.
Compliance sched. Complex source
review & preparation Other
II. Engineering Services Staffing Pattern (man-years)
Total Emission Inventory Permit System
Source testing Source Construction Planning
Other (Insp. & compliance)
Program Operations
I. Emission Inventory Sources inventoried F.Y. Total
% Sources not inventoried 0-10% 10-50% 50-100%
criteria score 5 3 0
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1
_ Schedule C, pg.2
1
I
1
•
I~
•.
1
1
1 "
1
1
1
1
1
II. Permit System Agency responsibility review approve
Total permits issued FY Total sources
% Sources operating without permit 0-10% 10-50% 50-100%
criteria score 5 3, 0
Review: Enter total number Const. Operation Limitations*
Size Class
Type: Incinerator
Fuel burning
Ind. process
Other
Criteria score 5 5
* Limitation on agency by agreement, reg., responsibility, etc. for review
or approval of permit.
Review Criteria:
% pt. sources reviewed 100% 75%' 50% <25%
(calculations, consultations,
emissions, collection, system,
control system)
Criteria score 543 1
New construction caught by checkoff system Yes No
Criteria score 1 0
Where: Ex. Bldg. Dept., Zoning agency, other
III. Source Tests Number source tests
Conducted by this agency for agency by
State Contractor Other
f
Criteria measure
Enter % sources tested in compliance
1
1
41
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Schedule C, pg. 3
IV. Compliance Activities
Number of sources on compliance schedules
% of
% of
% of
sources required to reduce
Emissions (Implementation Plan) on schedules
Criteria score
sources on schedule ( 18 month)
Criteria score
sources not on schedule (not in compliance)
Criteria score
100%
5
100%
5
50
0
75
3
75
3
25
3
<150
0
<50
0
•£10
5
V. Regulations and Legislation (check, if yes)
A. State and local regulations cover
1. Controlling visible emissions (open burning)
2. Permit system
3. Emission standards
4. Emission monitoring by owners
5. Inspections and tests
6. Enforcement procedures
7. Emergency episode controls
B. There are differences between state and local regulations
and EPA regulations and standards
Specify (attach copy of regulations with differences noted)
Criteria score:
If applicable state and local regulations cover all above categories - 5
at least five - 3
less than five - 0
If applicable state and local regulations comply with implementation
plan and are not deficient in legal authority - 5
If deficient in emission limitations only - 3
If deficient in emission limitation and other
areas, ex. record keeping, prevent const., etc.- 0
42
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Schedule C, pg. 4
Program Inf orma11on C riteria
I. Emission Inventory: Check if applicable. Recommendations should be made
~T>y evaTulftor concerning these areas, if not satisfactory.
Data source: permit_
agency survey
other (specify)
National Emission Data System (NEDS)
Emission factors used:
EPA AP-42 factors
Area source emission estimated by:
Rapid Survey Techniques (AP-29)
Other (specify)
APTD 1135
Formats
Appendices D, E, F, G of Federal Register (11/25/71)
(*) National Emission Data Systems (NEDS)
Other (specify
Other
Point sources included over: 100 tons/yr
Inventory is updated by means of:
Permit system application
Surveillance and investigation activities
Other (.specify)
Data is computerized:
By agency
By state
50
25
other
E.I
Other (specify)
. is used for:
Control strategy
Abatement action
Inspection priorities
Other (specify)
Recommend, if not used by agency.
43
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Schedule C, pg. 5
11. Permit System I
T
Reviews and calculations are made to determine volume and
composition of emissions
The capacity of the air pollution collection system
Effectiveness of control equipment
Other (specify)
Source1 tests are prerequisite for new or modified sources
Inspections are prerequisite for renewals
Fees are collected
(Fee schedule (specify))
44
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1
1
1
1
1-
1
1
1
1
I
1
1
.
1
1
1
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C. EVALUATION OF ENGINEERING FUNCTION
Introduction
An evaluation of engineering should determine performance, in
terms of activities carried out and results achieved—including air
quality levels and emission rates. It should also determine capability,
1n terms of staff experience and education, understanding of Federal,
state and local requirements and objectives, and knowledge and skill
in applying techniques for achieving these objectives. Five basic
activities should be evaluated: (1) emission inventory, (2) permit
system, (3) source testing, (4) regulations development, and (5) special
studies and reports.
Since a limited amount of time will be available for on-site
interviews, much of the information needed for the evaluation should be
obtained in advance. This will enable the evaluator to make the best
use of his time at the agency arid concentrate on areas which need
clarification. It also gives the agency an opportunity to review their
activities, organize their information and respond effectively to the
interview.
The evaluation process involves three steps: (1) information
gathering, (2) site interviews, and (3) appraisal and report.
Step 1: Information Gathering
A summary of emission inventory and source compliance data can be
tabulated on a form similar to that shown in Figure 1. This provides a
summary of emissions by source categories as well as a summary of
45
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work to be done. Compliance data should be relative to requirements
of the SIP.
Some of this information can be obtained from the agency's semi-
annual reports and grant applications. Some may have to be obtained
by means of a questionnaire directed to the agency and completed prior
to the site visit.
Step 2. The Site Visit and Interviews
Interviews should be limited to investigating specific problems
confronting the agency and determining the dimensions of and reasons
for these problems. The evaluator must adapt his questions accordingly.
For example, if information received in Step 1 above shows that there
are a large number of sources requiring emissions reductions, but a
»fff
small number of these are on compliance schedules, the reasons for the
discrepancy must be found and corrective action taken.
As another example, if the emission inventory is not yet complete,
it should be determined specifically what plans there are for completing
it and how much manpower will be assigned.
Not all kinds of information can be reduced adequately to a data
form, such as: How are job priorities established, work assignments
made, and how are engineering records filed and retrieved. It is
important to ask these types of questions during the interview, especially
when trying to discover the reasons for poor performance in specific areas.
The evaluator should be thoroughly familiar-with the agency's
responsibilities under the implementation plan. He should determine,
in the course of the interview, how well the agency understands their
role and what specific plans they have for meeting these responsibilities.
(i.e., How they are going to complete the emission inventory, bring all
/
sources into compliance, etc.)
46
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I
Step 3. Appraisal. and Report
Basically the objective in evaluating the agency should be to
I examine areas in which the agency is having or will have problems in
• meeting the requirements of the state implementation plan, and then
recommend the steps necessary to meet those requirements.
M_ The results of the evaluation will depend partly on judgments
formed during the interviews as well as appraisal of the data submitted
• prior to that time.
• It will be of help to the evaluator to use some system of rating
numerical information.
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Schedule D
AIR POLLUTION CONTROL AGENCY
EVALUATION DATA REPORT
Enforcement Activities
Program Responsibility:
I. Program responsibility summary - Enforcement
Enter one: State
1 only 1
Shared with Delegated Partial Other,
state 2 by state 4 delegation 4 specify 5
Area Source Surveillance
Transportation control
Source inspection
Incineration
processes
fuel burning
Complaint handling
Episode program
SCS implementation
Input for preparation
of legal case
Prosecution of violators
II. Enforcement Services Staffing Pattern (man-years)
Total staff Field patrol Complaint handling
Legal proceedings
Source inspection
Data & report preparation (consultation)
Other
Program Operations ;
I. Source identification
Number of sources under surveillance (total)
open burning
fuel burning
incinerators
process (total)
process particulate
gaseous
other sources (specify)
49
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Schedule D, pg. 2
Criteria:
Source listing (circle only one)
Includes all sources subject to regulations and SIP 5
Includes sources over 25 tons/yr. emissions 3
No source listing 0
Source listing update (circle only one)
Annually 3
Every 2 years 2
Every 5 years 1
Never 0
Source listing usage (circle both if applicable)
Develop and/cr update emission inventory 3
Start and continue permit system 3
II. Inspections
(Enter number of sources)
Subject to emission regs.
In violation of emission
regulations (total)
On compliance schedules
Legal action has been
started on
In compliance
In violation with no
compliance schedule and
no legal action started
Enter no. FY corrections by:
Staff
Board (if applicable)
Court
Fuel Inciner Industrial^ Open Other,
burning ation burning specify
Enter participate sources in (a) and gaseous sources in (b)
50
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1 Schedule D, pg. 3
-
•
1
-
•
1
1
fl
1
1
1
1
1
1
Criteria:
Compliance Schedule Activity (circle all applicable)
Agency enters into legally enforceable compliance
schedule agreements (milestone dates) 5
Conducts on-site inspections
verification
Scheduled inspections (circle al
Conducts periodic scheduled i
Inspection frequency based on
and/or emission potential
Comprehensiveness of inspection
for progress
3
1 applicable)
nspections 5
industry type
3
(circle all applicable)
Flow diagra..ij are made, reviewed or changed 1
Production ngi.res obtained
1
Equipment list compiled, changed, and updated 1
Operating parameters noted
Maintenance program reviewed
Do not conduct comprehensive
1
1
on-site inspections 0
III. Field Patrol and Complaint Handling
Number of complaints receivec
*Number of complaints acknowle
Number of violations observed
per year
dged
*Number of violations corrected
*Criteria for scoring
Acknowl
>75% -
edged % corrections
5 ' > 90% - 5
50% - 74% - 4 . 75% - 90% - 3
4.50% -
1
1
0 475% - 0
1
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Schedule D, pg. 4
Criteria:
Observed violations are written up and documented 5
Area divided into districts for uniform coverage 4
24 hour response capability . 3
A communication system between headquarter and
field personnel 2
IV. Emergency Episode Program (Criteria)
A communication system that can locate a responsible
agency official is in effect. 4
An episode manual outlining responsibility of
1
agency personnel has been prepared. 3
The episode program has been coordinated with law
enforcement and civil defense agencies. _
V- Administrative Procedures (Criteria)
Written standard operating procedures for
field enforcement personnel 4
Standardized field forms ir. use 3
Granting of a variance requires a compliance
schedule 2
Enforcement Records (check all applicable)
Master file on all sources 5
Files in alphabetical order 4
Files are cross-referenced 2
No master file on all sources 0 »
52
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Schedule D, pg. 5
Pror.i ' !.! mn
work.rr;
Pinv/ i
;;n
Ler.s than
.'f-.-i.'.n..'! prr>, id-^ '>• .;t for
c.l ' ••-•)'
<••••••• '• . • '. 1. -j..;! .v,,, -,f:l !'!.;V;
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D. EVALUATION OF ENFORCEMENT ACTIVITIES
Enforcement is the "activities conducted by an air pollution control
agency to secure certain and continuing control over the sources of air
pollution." The mission of an enforcement program then must be to implement
the plans that have been adopted to achieve acceptable levels of air quality.
Enforcement therefore overlaps many agency program activities such as
the permit system, source inventory, source testing, and air monitoring if
property line concentrations are a part of the regulations.
Since successful enforcement plays such a key role in improving air
quality, it is important that a careful evaluation be made of this activity.
An agency may have the best air monitoring network in the country or
the best laboratory, or the best source inventory, but if it is not bringing
sources into compliance with the emission regulations, then the agency
cannot justify the use of Federal grant money on its program.
An agency's program grant application must reflect SIP goals with
milestone dates, otherwise the evaluator has little to measure the
agency's performance against.
• A field operations (enforcement) program consists of key activities
for which objectives should be specified in the grant application. These
program activities and their significance are discussed below.
Source Identification - The agency must know how many sources it has and
where they are located before effective planning can take place. Source
identification is even a prerequisite to a comprehensive emission
'inventory. Source identification must be considered the highest priority
54
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1—— — :
i
activity of a new or young agency because it is the basic starting point
I or common denominator from which all other agency activities should be
built upon.
• Established agencies without a comprehensive source listing could
• experience difficulty in their emission inventory, permit system operations,
and inspection programs.
J Compliance Schedule Inspection - An on-site inspection of sources
— to verify milestone dates in the legally enforceable compliance schedule.
* Through a permit, system or emission inventory the agency should have a
fl , close estimate of sources not meeting the emission regulations. The agency
should then have on file compliance schedules for these sources. The
I compliance schedules should include milestone dates to reflect periodic
• progress toward completion of the schedule. The field enforcement officers
should verify this by on-site visits . the source shortly after each
• milestone date has passed.
Scheduler I- sppctlons - Inspections conducted by a certain date on
• an annual or other frequency basis. Inspection scheduling may be
• bas'ed on source registration, emission inventory, permit system, complaints,
or other information systems. Ideally, scheduled inspection frequencies
f should be proportional to the emission potentials of the source. The
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— scheduling process should not be completely automated*'.; It must rely
™ heavily on the recommendations of the field enforcement officer.
I Field Patrol - Sometimes referred to as surveillance activities. Vehicle
patrol is the principal surveillance method. The enforcement officer
I should patrol in a manner that will bring the greatest area of his district
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under view while taking the shortest route. When a questionable visible
t
;
emission or violation is observed, the enforcement officer takes a reading
and/or investigates. All observed violations are written up according to
prescribed agency procedure. A communication system will allow the agency
to respond quickly to complaints and emergencies. If necessary, agencies
should have 24 hour a day field patrol capability.
Complaint Handling - An agency should respond quickly to complaints received.
The number of complaints received is influenced by many factors, such as
number of sources, agency publicity, air quality levels, public awareness
of agency, magnitude of emissions, meteorological conditions, etc. Many
of these factors cannot be related to the agency's effectiveness, therefore,
evaluation of complaint handling cannot be related to number of complaints
received. The capability to respond, response, time, percent of complaints
responded to, and use of the complaint information, are the important
considerations in evaluating the complaint handling activities of an agency.
Emergency Episode Program - An agency should have the ability to respond
to a meteorological episode or upset involving hazardous pollutants. This
program must be coordinated with law enforcement and civil defense agencies.
An emergency episode procedure manual should be available to all involved
personnel.
Administrative Procedures - This includes agency procedure manuals written
for field enforcement officers, field forms such as violation notices,
inspection reports, citations, etc., and the entire spectrum of how the
agency conducts its enforcement program. An agency must have standard
operating procedures for enforcement. Without, standard operating procedures
there cannot be consistent enforce'....-•.: practices.
56
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Enforcement Records - The agency should have documentation on all violators.
I
• Source 'records should be filed in such a way that access to the information
• requires a minimum of effort. All inspection sheets should be on file
along with any documentation for legal action.
I Legal Action - Successful prosecution of violators after all other remedies
g for relief have failed. The state attorney general or local prosecuting
attorney will usually have responsibility for prosecution before an
• administrative body or the courts. It is most important to the agency to
have attorneys familiar with environmental law assigned to air pollution
• cases rather than have to start out with a new attorney on each case.
• Agency personnel should be informed as. to what documentation is needed for
a legal brief and should work closely with the prosecutor on case
J preparation.
_ Two basic questions that must be addressed in evaluating the legal
• i
* || action aspects of an enforcement program are: (1) Does the agency follow
_ ''
• " i up on sources that are in violation of emission regulations?, and (2) Is
1 the agency able to successfully prosecute violators?
I:
. A numerica^ value can be assigned to sub-elements under each of the
• above program functions. The total points given an agency can then be used
to rank the enforcement activities of all agencies under consideration.
I The importance of the total enforcement points scored by an agency
would have to be considered in light of the enforcement role assigned that
• agency by the state implementation plan.
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AIR POLLUTION CONTROL AGENCY
EVALUATION DATA REPORT
Technical Services Activities
Program Responsibility
I. Program responsibility summary - Technical Services
Enter one: State
only 1
Shared with
state 2
Delegated Partial Other,
by state 3 delegation 4 specify 5
Laboratory Servi ces
Pollutants Analyzed
Criterial
Hazardous
Trace elements
Material, fuel
qual., etc. _
Special studies
Equipment
maintenance
Instrument
calibtation
Enforcement Support
Source testing
Special Analytical
studies
Data Handling
Collection _
Storage and
analysis _
Source ident. Report prep.
Part, ident.
Odors, etc.
Air Monitoring
Minimum F.R.
network
Special, complex
source,
transportation
control
Meteorology
Data acquisition
Forecasts
SCS (modeling)
Eval. of source _
Eva!. area source
Land Use planning
II. Summary of Staff - Technical Services (man-years)
Total Air monitoring network Laboratory operations
Data processing Special study 'Other
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Program Operations
I. Air Monitoring
Type: (check one)
State
AQCR
Portion of AQCR Other monitoring
Not under SIP
Enter number in network: (FY ) Hi-vols
>2
Bubbler & sequential
Tape samplers S00 cont. Ozone cont.
HC cont.
CO cont.
Other (specify)
Enter number of days equipment out of operation due to failure:
Hi-vols Bubbler & sequential Tape samplers
S0~ cont. Ozone cont. _, HC cont.
CO cont. Other (specify)
II. Laboratory Operations
Number of samples analyzed: Total Criteria pollutants
Hazardous materials ____ Fuel Special (FL, Pb, etc.)
Other
Criteria:
Amount of data validated and reported
90% of possible
90% to 70%
70% or less
Don't know
Good 5
_Fair 3
Unacceptable 0
Unacceptable 0
If unacceptable is marked the evaluator should go on to the followi
ng:
59
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Instrument maintenance and calibration is performed:
1. On a predetermined schedule, based on past experience,
to minimize the data from being out of control good 5
2. Every 3 to 6 months routinely fair 3
3. Once per year, or whenever equipment malfunctions poor 2
4. Never unacceptable 0
Quality Control
Agency
Maintains Quality Control by (check all applicable)
replicate samples blanks spiking
Constructs control chars on critical parameters. Yes No_
Criteria:
The Quality Control Program is:
1. Routinely carried out and adequately documented 5
2. Haphazardly carried out and/or poorly documented 3
3. Not done at all 0
III. Data Processing
Data is reported in format acceptable to EPA for quarterly and
semi-annual reports. Yes 5 No 0
Format used - SAROAD State accepted Other
Data report identifies: (check applicable descriptors)
Site Number of samples Sampling interval maximum
Averages Deviations
Data report summaries identify: (check applicable descriptors)
Relationship of values to standards Trends
Agency provides daily pollution report to public. Yes No_
Criteria Score:
Turnaround time on data reports:
<1 month - 5 1 to 3 months - 3 >3 months - 0
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Schedule E, pg. 4
IV. Specjal Studies and Reports
A.
B.
C.
D.
E.
Mobile source emissions
Transportation controls
Lard use alternatives
(complex sources)
Other (specify) SCS, and
large point source (SCk)
Technical guides written
(List)
Number of
studies
being made
Network
No. Comp.
Sites Pollutant date
Emergency Episodes
Number of sites designated _ Frequency of operation
Are meteorological forecasts being made? Yes _ No _
Are supplementary control
planned?
Can sampling be affected for sources?
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SUBJECT:
FROM:
TO:
4 AUG 1973
UNITED STATES ENVIRONMENTAL PROTECTION AGCNCY
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
DATE:
Report on Potential Problems in Priority
II and III Regions with Respect to NAAQS
/? i /"'- 'V'/ P ' tJ
Robert E. Neligan, Director f.f- &<>i&- /(.•<••« f'-
Monitoring and Data Analysis Division
Air and Water Division Directors
Environmental Protection Agency, Region I-X
Through intense efforts made by the Regional Offices,
there is now sufficient data in the National Aerometric
Data Bank to initiate further evaluation of the data
received. OAQPS most certainly appreciates the labors
that have been and are continuing to be made in the
collection and processing of air quality data. Now
that the first phase of data collection has been
completed, we must now proceed into a continuing
program for the evaluation and verification of
certain portions of the data received. This report is
the first of a continuing series that will be issued
periodically.
OAQPS is currently developing an air quality
tracking system to flag significant departures from
expected air quality based on emission projections
and SIP regulations at each of the monitoring sites
stored in the NADB. A flow chart for this system,
which employs statistical techniques, is given in
Figure 1. Unfortunately, this system will not be
operational until late this year. Therefore, 1972
air quality data have been screened for values that
suggest a higher priority classification for an AQCR
than that presently assigned. While this alone may
not be sufficient for reclassification, it affords a
convenient screening technique. The data are presented
in Attachment 1 for CO, TSP, S02, and Ox and lists
those sites within Priority II and III AQCR's which
show 1972 air quality levels to be in excess of the
primary standards. All of these data are from the
NADB files. More details may be obtained by accessing
the data with the usual time-sharing program, if
desired. It is requested that the Regiona.1 Offices
review the data for their particular region selected
by this screening in order to verify that these values
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accurately reflect ambient air quality levels in these
AQCR's. (It should be noted, however, that if a site
within an AQCR is high in reference to its priority
classification, this may well be altered when state
regulations are completely effected in 1975. Thus, a
Priority II or III Region, in excess of the primary
standards in 1972, could be well under that standard
in 1975).
T-he maximum reported concentration was used in
developing the list of sites that exceeded the primary
standards. Since the short-term air quality standards
are written as concentrations which are to be exceeded
no more than once, many of the sites identified by this
procedure are not technically violating the air quality
standard. However, many of these sites which exceeded
the standard only once, were sampling too infrequently
to state with assurance that a second or third violation
was unlikely. Thus, it was decided to utilize the
maximum value for determining if the data from a site
should be examined. Pollutants for which an annual
standard are applicable (TSP and SO;?) were screened
by comparison of annual averages H~~> the annual primary
NAAQS, in addition to the screening of the maximum
concentrations.
In screening carbon monoxide, it was found that
19 out of 21 Priority III AQCR's, for which we have
data in 1972, exceed the primary standard. These high values ;
may necessitate the development of additional transportation j
control strategies. To better evaluate this CO problem, \
Attachment 2 (Obtaining Information on CO Monitoring) is j
enclosed. We feel that the collection of the suggested ;
information is vital to both the Regional Offices and ]
OAQPS in order to better define the CO problem.
In addition to CO, we are suggesting that you
evaluate the other pollutants indicated in Attachment 1.
To provide assistance in this evaluation process,
Attachment 3 (Guidelines for Evaluation of Suspect Air
Quality Data) is enclosed with this report. This attachment
can be used to determine if these data accurately represent
air quality levels in the AQCR or whether appropriate
modifications should be made.
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In following the guidelines (Attachments 2 and 3),
the Regional Offices, being more familiar with the
different sites and sampling conditions, may alter or
add to the questions and procedures for validating
data points. Any additional facts associated with this
validation will be appreciated.
Since this data verification process is an essential
component of our overall evaluation of progress towards
achieving the National Ambient Air Quality Standards,
a response within 30 days of receipt of this report by
the Regional Offices will be appreciated.
Any questions concerning the air quality data or
evaluation guidelines should be referred to Mr. William F. Hunt
at 919/688-8351.
3 Attachments
cc: Surveillance and Analysis Division Directors
R. Sansom
B. Steigerwald
J. Schueneman
J. Padgett
. E. Tuerk
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AQCR PROGRESS
SATISFACTORY
NO ACTION
REQUIRED
AIR QUALITY DATA
FROM STATES, ETC,
EPA REGIONAL
OFFICES
FLAGGING
TECHNIQUE FOR
SIP
PROGRESS
ADDITIONAL
DATA VALIDITY
CHLJK
NO
DATA VERIFICATION
PROCEDURES
DATA
REVISION
t
N
QUERY TO
REGIONAL OFFICE
FLAG
REAPPLY
VLAC.GING
sTSCH
FOG
AQCR PROGRESS
NOT SATISFACTORY'
ALERT CONTROL
PKVELOPi-ENT
DIVISION, OAQPS
ALERT REGIONAL
OFFICES
REEVALUATE SI?
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Attachment 1
The following computer printout lists by pollutant and
measurement method those sites by Priority II and III AQCRs
which are exceeding the primary standards. The printouts
are essentially self explanatory. The footnotes at the
bottom of the printout indicate the data point in question
and the reason why. It should be noted that in some cases
the highest value exceeded the short-term primary standard,
while the second highest did not. Technically then, the
AQCR is not in violation of the standards, but since it
is classified as a Priority II or III region, it is in
potential violation.
Finally, when examining the printout related to sus-
pended particulate and sulfur dioxide, it can be seen that
the annual mean (geometric or arithmetic) is not always
calculated. This occurs because one or more quarters are
lacking sufficient data with respect to the SAROAD validity
criteria.
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