I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
GUIDELINE  SERIES
          OAQPS NO.  1,2-077
      GUIDELINE FOR IMPLEMENTATION OF THE

       STANDARDIZED SIP FILING SYSTEM
   US. ENVIRONMENTAL PROTECTION AGENCY
    Office of Air Quality Planning and Standards


      Research Triangle Park, North Carolina

-------
I
I
I
I
I
                        'ED STATES ENVIRONMENTAL PROTECTION AGENCY
         6 f JUL Wl
  DATE:

SUBJECT: SIP Filing System
    o  Walter C. Barber, Director
    /Olif-fice of Air Quality Planning ancHStandards

    T°: Directors, Air and Hazardous Materials Division, Region I, III-X
       Director, Environmental Programs Division, Region II


            A number of Regions have initiated programs to improve SIP filing
       systems and have suggested that OAQPS provide guidance to develop a
       measure of uniformity in the filing system.  In addition, the Office of
       General Counsel has urged that required SIP filing standards be estab-
       lished to assure convenient public availability of documents and to
       ensure effective management of the contents of each SIP.  My staff has
       been working with your respective staffs to develop a standardized
       filing system.  Based on the comments received, guidelines for a standard-
       ized SIP filing system have been completed.

            Basically, the standardized filing system consists of the three
       elements identified below.  The enclosed guideline, which should be
       employed when implementing the standardized filing system, allows maximum
       consistency among headquarters' and Regional Offices' files yet adequate
       flexibility to accommodate specific Regional needs.

            Part 1.  A Chronological File contains all SIP revisions in a
       chronological, dated form.

            Part 2.  A Master Log Sheet (MLS) has been developed as a standard-
       ized topical index for all files.  The MLS index references submissions
       within the Chronological File, but the subject list can be expanded and
       altered according to Regional needs.

            Part 3.  Subject Files are a compilation of the regulations and
       updates pertaining to one subject category.

            Regions may implement the new system at their own discretion.
       However, you should be aware of the requirement contained in the House's
       version of the Clean Air Act (CAA) amendments which requires this Agency
       to assemble and publish on an annual basis a document setting forth all
       requirements of each State's implementation plan.  It is anticipated
       that these documents will be the responsibility of each Regional Office.
       The format will be consistent with this filing system.

            I trust that you will find this new system suitable for your needs.
       Any questions regarding the new system should be referred to Charles
       Pratt or Bob Schell, (629-5365).

       Enclosures
   EPA Form 1320-4 (Rev 3 -761

-------
                 GUIDELINE FOR IMPLEMENTATION OF THE

                   STANDARDIZED SIP FILING SYSTEM
Introduction
     These guidelines are intended to provide a standardized format to
organize documents related to State Implementation Plans (SIPs).  It is
being offered as an optional system for use by all Regional and head-
quarters offices.  The system was developed in cooperation with the
Regional Offices' participation and comments have been included in this
system.

     Both the Chronological and Subject Files should be organized in
three-ring notebooks, for maximum ease in updating and xeroxing sections,
Regions may elect to bind the Chronological File periodically.  A list
of the subjects with their numeric identifiers (see Table I) should be
included inside the front cover, as well as any pertinent instructions
for file usage.

Submission Date

     Both the Chronological File and Master Log Sheet (MLS) require a
date as the organizational key.

     An official date must be determined from the material submitted.
The date on which the Governor submitted the package to the Regional
Administrator or the date of the proposed promulgation for Federal
actions normally serves as the official date.  Exceptions to this
general requirement should be noted and explained (i.e., in cases where
the Administrator bypasses proposed rulemaking and promulgates a regu-
lation, then the promulgation date would be used).  If in the unlikely
event that two or more revisions are sent by a Governor on the same
date, each will have a different letter of the alphabet added to the
date as a suffix.

Identifiers
     A numerical key has been developed to codify all the MLS topics.
Each number is broken into a maximum of four sections as follows:

                     a.b.c.d  (ex., 5.0.1.1)

     a = general subject area contained in file.  These ranging from 1
to 19, are enumerated in Table I; numbers can be added whenever the file
requires expansion.

     b = Area within the State to which a regulation pertains.

-------
                                   - 2 -


     c = subtopic within the major file subject area.

     d = subdivision under a subtopic.

     Ex., 6.1.5  (a.b.c)

     6 = Regulations:  the file subject area

     1 = San Diego County, California:  the location

     5 = Hydrocarbon:  the subtopic

Some States have no regional areas and the "b" space would be 0; i.e.,
all SOp regulations throughout Maine would be identified by 5.0.2.   But,
where counties or other delineated areas with a State have separate regu-
lations and control strategies, the SIP files must utilize an established
number for each area.  These numbers should be permanently established
and listed at the beginning of the files.

-------
                    CONTENTS OF NEW FIL-ING SYSTEM


Part 1.  CHRONOLOGICAL FILE

     This file"stores each action by date.  It will contain all official
materials and Federal Register actions (i.e., letters from the Governor,
letters from the Regional Administrator, Federal Register packages,
etc.).


Part 2.  MASTER LOG SHEET (MLS)

     The MLS indexes important topics contained within every submission
with a numeric code from 1.0 to 19.0.  New topics will be added as
future needs dictate.

     The following descriptions briefly outline the pertinent submissions
and their respective codification.

General Definitions (1.0.)

     Most SIPs have a section which contains definitions of terms to be
standardized in usage throughout the document.  It may be referred to as
a Glossary or Definition Section.  For example, in the case of the
Wyoming SIP, pages G 1 and 2 are indexed as 1.0. at the date 12/15/74.
Specific definitions pertaining to the emission regulations would,
however, be indexed as 6.0.0.

Attainment Dates and Extensions (2.0.)

     The Clean Air Act (CAA) provided an option to those States with
extremely difficult problems to extend the attainment date for a pollutant
for specified periods of time.  Although, most of the attainment dates
have or will have passed in the near future, some States may seek an
extension for meeting the attainment date for new criteria pollutants.

Classification of Regions (3.0.)

     Classification and designation of Air Quality Control Regions
(AQCRs) and Air Quality Maintenance Areas (AOMAs) should be referenced
here.

Public Availability of Emissions Data_ (4.0.)

     This category should contain the statute or regulation providing
for the public availability of emissions data.

-------
Legal Authority (5.0.)

     This category should contain the statute  which  provides  legal
authority for carrying out the requirements  of the State's  CAA.

Control Strategy (6.0.)

     All of the control strategy materials will  be referenced as  6.
This file has a three number code:   (i.e., 6.—represents  the file
number; the second number—represents the area of impact within the
State; and, the third digit-indicates the pollutant  for which the
strategy was developed.)  Pollutant specific control  strategies are
listed under the third level identifier in the following order:
.l.~particulate (TSP); .2.—sulfur dioxide  (S0?);  .3.—carbon monoxide
(CO); .4.—oxidants (0 ); .5.—oxides of nitrogen (NO ); and, .6. —is
reserved for lead (Pb)?

Rules and Regulations (7.0.)

     The section containing  the rules and regulations has  been subdivided
into many parts.  File 7.0.0.  contains the definition and  administrative
portion of the control regulations.   For instance, this would include
the description of the agency, the description of the duties  of the
director, definition, administrative procedures, etc.  If  desired, a
fourth level identifier could be used to separate the identifiable
nonenforceable items in the  control  regulations.  Due to the  variety of
styles found in control regulations, the Rules and Regulations file must
be modified vo meet the needs of each State.

     As explained in the previous section, the third level  identifier  is
used to indicate the particular pollutant or type of regulation to be
filed in each section.  In the first seven subfiles  the third level
identifiers are the same as  the third level  identifier for the control
strategy file, i.e., .1.—TSP; .2.—S02; .3.—CO; .4. —HC;  .5.--NO  ;
and, .6.--Pb.  Additional categories may be  needed by some States:
.7.--malfunctions; .8.—source specific (i.e., a power plant); .9.—odor
regulations; .10.—supplementary control system.  Fourth
level identifiers pertain to subdivisions of the third level  iden-
tifiers; visible emissions (7.0.1.1.) and process weight  (7.0.1.2.)
fall under particulates.

Compliance Schedules (File 8.0.)

     This category contains  the revision related to  source compliance
schedules.

New Source Review (9.0.)

     Review of new and modified sources regulations  and permits will be
referenced under this section.  Subfile would include 9.0.1.—stationary
sources and 9.0.2.—indirect sources.

-------
Episodes (10.0.)

     Episode Control Plans would be referenced as 10.0.

Continuous Emission Monitoring (11.0.)

     Source Surveillance procedures and regulations would be filed under
11.0.

Air Quality Surveillance (12.0.)

     Air Quality Surveillance Plan and procedures would be referenced
under this section.

State Ambient Standards (13.0.)

     This topic contains the State Ambient Standards.

Prevention of Significant Deterioration (14.0.)

     Number 14.0. refers to all the information on the Prevention of
Significant Deterioration (PSD) regulations and plans.

Maintenance Plans (15.0.)

     This category includes all maintenance plans developed pursuant to
40 CFR Part 51.

Request for One-Year Postponements (16.0.)

     Request and information on applications for one-year postponements
to the applicable control regulations are filed in this section, (and
hearing records and completed applications from sources, if desired).

Variances (17.0.)

     Applications and actions related to the granting or denial  of
variances.

New Source Performance Standards (NSPS) (18.0.)

     State NSPS regulations are referenced in this section.

National Emissions Standards for Hazardous Air Pollutants (NESHAPS^ (19.0.)

     This section pertains to State NESHAPS and any supportive materials.

-------
Part 3.  SUBJECT FILES

     Subject files are a compilation of the regulations and updates
pertaining to one subject category (ex., 1 file for SCL related documents;
1 file for New Source Review, etc.).  Establishment of these files is
recommended whenever such a reference file might be useful  to the Region.
The files contain full texts (not just reference numbers as in the MLS),
but only pertain to actual submissions.  Subject files may  be useful for
accumulating specific documents for one State or also within an entire
Region, depending upon need.

     Because of the labor input and funding involved, systemized subject
files cannot be required.  In most cases. Regions already have their own
filing categories which pertain to Regional needs.  Because of the
increasing number of questions raised with certain issues,  we recommend
that each Region set up the following subject files:

     Public Availability of Emissions Data
     Regulations - Administrative
                   Particulates
                   SO,
                   C(T
                   HC
                   NO
                   Pbx
                   New Source Review
                   Continuous Emission Monitoring
                   Prevention of Singificant Deterioration

This represents a minimal number of subject files that we feel are
important to maintain.  Hopefully, others will be added from the MLS
list as time and manpower become available.

-------
                               TABLE I
                           MASTER LOG SHEET
                      (Suggested Topical Index)
1.0.     — GENERAL DEFINITIONS
2.0.     —ATTAINMENT DATES AND EXTENSIONS
3.0.     — CLASSIFICATION OF REGIONS
4.0.     — PUBLIC AVAILABILITY OF EMISSIONS DATA
5.0.     — LEGAL AUTHORITY
6.0.     — CONTROL STRATEGY
   6.0.1.   —Participates
   6.0.2.   — S02
   6.0.3.   —CO
   6.0.4.   — Ox
   6.0.5.   — NOX
   6.0.6.   — Pb
7.0.     — RULES AND REGULATIONS
   7.0.1.   — Particulates
      7.0.1.1.  —Visible Emissions
      7.0.1.2.  —Process Weight
   7.0.2.   — S02
   7.0.3.   —CO
   7.0.4.   —HC
   7.0.5.   — NOX
   7.0.6.   — Pb
   7.0.7.   —Malfunctions
   7.0.8.   — Source Specific
   7.0.9.   — Odor Regulations
   7.0.10.  —Supplementary Control System
8.0.     — COMPLIANCE SCHEDULES

-------
9.0.     — NEW SOURCE REVIEW
   9.0.1.   —Stationary Sources
   9.0.2.   — Indirect Sources
10.0.    T— EPISODES
11.0.    —CONTINUOUS EMISSION MONITORING
12.0.    —AIR QUALITY SURVEILLANCE
13.0.    —STATE AMBIENT STANDARDS
14.0.    — PREVENTION OF SIGNIFICANT DETERIORATION
15.0.    — MAINTENANCE PLANS
16.0.    — REQUEST FOR ONE-YEAR POSTPONEMENT
17.0.    —VARIANCES
18.0.    — NEW SOURCE PERFORMANCE STANDARDS
19.0.    —NATIONAL EMISSIONS STANDARDS FOR HAZARDOUS AIR POLLUTANTS

-------
                                             State
                          MASTER LOG SHEET
Submission Dat6
                Identifiers
ex. 4/20/72
5.0., 7.0.5.
                              (The above example would be interpreted
                               as follows:   Under April  20, 1972, a
                               submission was entered containing
                               Legal Authority & State Statutory
                               Provisions,  and Hydrocarbon Regulations.)

-------