GUIDELINE SERIES
OAQPS NO. 1.2-047
JAN 1977
OOOR77007
CONTROL STRATEGY PREPARATION MANUAL
FOR
PHOTOCHEMICAL OXIDANT
US. ENVIRONMENTAL PROTECTION AGENCY
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina
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1tate distribution of future updates to this manual and
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that the below card be filled out and mailed to:
U.S. Environmental Protection Agency
Plans Guidelines Section
Control Programs Development Division
MD-15
Research
If additional
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This 1s
Triangle Park, NC 27711
copies are necessary please note 1n the appropriate space.
1/77
to request that future updates of the Control Strategy
Preparation manual be sent to the below named person
NAME:
ADDRESS:
In addition please send additional copies of the Control
Strategy
Preparation Manual for Photochemical Oxldant for further
distribution.
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INTRODUCTION
| The Clean A1r Act, as amended, provided that for each national
ambient air quality standard (NAAQS) promulgated by the EPA, a State
Implementation Plan (SIP) was to be developed which was to contain
fl emission control measures that would provide for attainment and main-
tenance of such national standards, generally within three years of
I the approval of the SIP. Experience has shown that not all SIP's
developed by the States 1n early 1972 were adequate to provide for
m attainment and maintenance of the photochemical oxidant standard by
July, 1975. Further, it is now known that violations of the photo-
chemical oxidant standard are more pervasive than were originally
thought a few years ago.
Consequently a major activity of EPA within Fiscal Year 1976 was
I the review of each SIP to determine its adequacy to provide for attain-
ment and maintenance of national standards. When a SIP was determined
to be substantially Inadequate, the State was advised by EPA that a
fl SIP revision was needed. States are required to submit a revised
SIP, where necessary, by July 1978. At that time, all needed achiev-
0 able control regulations for stationary sources shall be submitted.
_ In cases where additional controls are needed, generally land use and
* transportation measures, they shall be submitted by July, 1978. The
< revised SIP will be required to contain adequate measures to provide
for attainment and maintenance.
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This Control Strategy Preparation Manual for Photochemical Oxidant
has been prepared to provide guidance to State and local control agencies
JAN 1977
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on the development of an approvable control plan. The procedures out-
lined 1n this document should be followed by States, or EPA where
necessary, 1n developing an approvable control strategy for photo-
chemical oxldant.
There are three notable issues which are not covered by this manual.
These are:
(1) Substitute for the Appendix 0 relationship.
(2) The use of photochemical reactivity in SIP development, and
(3) The definition of the area that should be considered for control.
OAQPS is currently investigating these three issues. A task force has
been developed on substitutes for Appendix J and considerable review both
within and out of the agency has proceeded with the expected date of
culmination approximately April 1977. A public meeting was held on the use
of photochemical reactivity in October 1976 and a policy is being developed
on the basis of information gained there and through other reviews. The
expected date of reissuance of policy on this subject is April 1977. The
definition of the area over which controls should be applied has been
difficult to determine because of the many variables involved. Review of
the policy 1s currently underway with completion expected in approximately
April 1977. As these issues are resolved, the policy papers will be dis-
tributed through direct mailing to Regional Office personnel for distri-
bution to State and local agencies as appropriate. Additionally, the
appropriate pages of this guideline will be modified as explained on page
1v. Also, the entire guideline will be included 1n the OAQPS Guideline
Series; thus making the Information available to State and local agencies
from the Regional Office libraries.
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While these three issues are important to the development of a
J control strategy much work can proceed without a full definition of the
policy on these three issues. This manual discusses most of the other
aspects of photochemical oxidant problems and their relationship to con-
trol strategy development. The work that can proceed includes updating
emission inventories, projection of growth and Its resulting emissions,
and allocating resources to develop control strategies.
The reader will note that throughout this document the term
"organic compound" is used in Heu of the more common term "hydrocarbon."
The term "hydrocarbons" was initially used by EPA to include all organic
compounds. Some confusion has resulted from use of this term with
ft regard to which carbon containing compounds should be considered for
control. To further explain, the term "hydrocarbons" specifically
| refers to those compounds containing only carbon and hydrogen while
. organic compounds refer to all compounds containing carbon except for
carbon monoxide and carbon dioxide and a few other compounds. Therefore
the term "organic compounds" has been used 1n this document to more
explicitly define the compounds to be considered for control.
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JAN J977
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FORMAT
The Control Strategy Preparation Manual for Photochemical Oxldant
1s separated Into four sections. Section I provides an overview of
the various factors to be considered 1n the development of an approvable
control strategy for photochemical oxidant. Section II sets forth a
fairly concise step-by-step procedure that a control strategy developer
should follow in preparing an approvable control strategy. Section III
provides, 1n quest!on-and-answer format, additional Information to
provide a more detailed explanation of the recommended procedures out-
lined 1n Section II. Section IV includes additional information on
existing inspection/maintenance programs.
This manual will be revised from time to time to take account of
new information. To facilitate the revision procedure the manual has
been punched so as to allow insertion into a looseleaf binder. Addi-
tionally the pages are numbered according to section and are dated.
When revisions to this document are received they may easily be inserted
in the appropriate place simply discarding the old pages.
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I
TABLE OF CONTENTS
I Page
Section I: Overview of Factors Affecting Attainment of
National Photochemical Oxidant Standards 1-1
Section II: Summary of Procedures Required for the Review
and/or Development of a State Implementation Plan
Control Strategy for Photochemical Oxidant .... II-l
I
{Section III: Questions Frequently Raised Concerning Photo-
chemical Oxidant III-l
(A) Attainment of the National Standards III-A-1
* - Is there a NAAQS for HC and must it be attained? . . III-A-1
- What 1s the NAAQS for Oxidant? III-A-1
- Is the NAAQS for Oxidant valid? III-A-2
, (B) Control Strategy Development III-B-1
- For what reasons must SIP's be revised? III-B-1
m - What is Agency policy regarding calls for SIP
revisions? III-B-1
^ - How frequently should plans be updated? III-B-3
- How much air quality data are needed as a basis for
V a control strategy? III-B-3
- Why should measured data, rather than statistically
f generated second maximum 1-hour concentrations be
used in the control strategy? III-B-4
_ - What meteorological data should be considered 1n the
control strategy? III-B-5
- What geographic area should be considered 1n the
A control strategy? III-B-5
- What is the definition of rural and urban areas? . . III-B-6
| - Should AQCR boundaries be modified? III-B-6
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- Is Appendix J still required? III-B-6
- Should ant lent background concentrations of photo-
chemical oxidant be considered in the control stra-
tegy? III-B-7
- Should transport be accounted for 1n the control
strategy? III-B-8
- What, if any, is the impact of fuel switching due to
ESECA? III-B-9
- To what extent does growth information have to be
coordinated with other planning agencies? III-B-10
- What effect will the amendments to the Clean A1r Act
have on automobile emission rates? III-B-11
- What action is being taken to control automotive
evaporative emissions? III-B-12
- How should higher deterioration rates be taken into
account? III-B-12
(C) Control Technology for Sources of Organic Compound
Emissions III-C-1
- What is RACT? III-C-1
- Which organic compounds react 1n the photochemical
oxidant process and what is the Agency's approach
to controlling organic emissions? III-C-2
- What regulations for the control of organic compounds
from stationary sources are considered available at
the present time? III-C-3
- If control of all organic compounds is needed, why
does the Agency require use of substitution type
regulations? III-C-4
- What are considered available controls for trans-
portation-related sources? III-C-4
- What NMOC Reduction is expected to occur from imple-
mentation of various transportation control mea-
sures? III-C-5
- What are the costs associated with Inspection/
Maintenance programs? III-C-8
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- What 1s the fuel savings due from Inspection/
« Maintenance programs? III-C-11
- What operational experience has been gained with
Inspection/Maintenance programs? III-C-12
- What 1s meant by Stage I and Stage II vapor re-
covery? III-C-17
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- What criteria must be met to ensure air quality
measures are implemented as part of the transpor-
tation planning process? III-C-19
* - What is emulsified asphalt paving? III-C-20
| (D) Air Quality Monitoring for Photochemical Oxidant . . III-D-1
- What is the reference method for determining oxidant
M 1n the ambient air? III-D-1
- What other measurement methodologies are being used
to monitor photochemical oxidant? Are these metho-
j dologies valid? III-D-1
- Must a correction factor be applied to relate data
* from the various acceptable methods to the FRM? . . . III-D-4
- Because of data collection inaccuracies, must his-
torical data be adjusted to provide a more accurate
M level of ambient concentrations? III-D-4
- Where are maximum ambient concentrations of oxidant
observed? ..................... III-D-4
- How does the NO/NCL split influence the design of
m the oxidant monitoring network? .......... III-D-5
- What type of review should be performed to determine
_ 1f an adequate monitoring network exists for oxidant?
When should this review be done? .......... III-D-6
(E) Emission Data .................... III-E-1
J» - What are the major sources of organic emissions in
the nation? ..................... III-E-1
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- f'ust emission inventories contain information on the
reactivity characteristics of the organic compound? . . III-E-2
- What sources and source information should be in-
cluded in organic compound emission inventories? . . . III-E-2
- Are emission factors available for natural sources
of HC? III-E-5
- How are vehicular emissions calculated for organic
compounds? III-E-6
(F) Chemistry of Photochemical Oxidant III-F-1
- What is the difference between oxidant and ozone? . . . III-F-1
- When and how rapidly is 03 formed? III-F-2
- How is oxidant formed/depleted? III-F-3
- What is the interrelationship between organics and
NOV in oxidant formation? III-F-5
A
- What are the meteorological factors affecting oxidant
levels? III-F-6
Section IV: Inspection/Maintenance Operation Experience
References
V111
J/M 1977
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I
OVERVIEW OF FACTORS AFFECTING ATTAINMENT OF
NATIONAL PHOTOCHEMICAL OXIDANT STANDARDS
e
£ The following statements summarize the pertinent facts concerning
the nature and extent of the photochemical oxidant problem and the
fl technical information available to assist in the analysis and develop-
ment of approvable photochemical oxidant control strategies.
3 1. The National Antient Air Quality Standard (NAAQS) for photo-
o
^ chemical oxidant (Ox) is 160 ug/m (0.08 ppm) one-hour average not
to be exceeded more than once per year.
11 2. Photochemical oxidant is not a specific compound but a broad
group of diverse compounds with ozone (0,) - being by far the most
I abundant single component - selected as the indicator for pollution
control purposes. Photochemical oxidant is not emitted directly but
is formed 1n the atmosphere with its primary precursors being non-
f methane organic compounds (NMOC) and oxides of nitrogen.
3. Violations of the ambient photochemical oxidant standard are
more pervasive than originally believed. In addition to high concen-
trations observed in many urban areas, studies 1n the Midwest and East
m have found high levels of oxidant 1n rural areas.
f4. Preliminary analysis of special study data Indicates that
high oxidant levels in rural areas can generally be attributed to long
I range transport of oxidant and its precursors from urban areas. Further,
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this condition also occurs in conjunction with specific weather patterns.
While the Agency suspects high rural oxidant levels result from trans-
port of man-made emissions from urbanized areas, further study is needed
and is being conducted.
5. There is at times a significant natural background which on
some occasions may exceed levels of more than half the national standard.
However it is believed that the contribution of natural sources is gen-
erally small in urban areas in relation to peak oxidant concentrations.
6. The current Federal Reference Method (FRM) calibration method
for photochemical oxidant is difficult to use and a 5 to 10% positive
bias exists even when great care is taken in the procedure. The Agency
is in the process of testing new calibration procedures. As an interim
measure, field operators have been provided with improved instructions
for using the current calibration method which will minimize the error.
In addition, another study showed that the FRM monitoring system, even
when used by experts, probably underestimates the true ambient oxidant
concentrations. The magnitude of the negative bias 1s generally larger
than the positive bias associated with the calibration method.
7. NO is known to both destroy and produce Ox. Smog chamber
A
and mathematical modeling studies Indicate that the effect of NO upon
A
oxidant formation interacts with the organic compound effect resulting
1n extremely complex ox1dant-organ1c-NO relationships. Notwithstanding
A
such complexities, 1t has been established that the relative levels of
NMOC and NO 1n ambient air are such that the most effective approach
A
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to oxidant reduction is based upon maximum NMOC control. In some
cases it may be beneficial to control NO sources to minimize Ox,
however at the present time, because of limited information, it is
m too premature to require such controls. Additional investigation
is continuing.
m 8. Organic compounds are emitted from both stationary and
m mobile sources. On a national basis, approximately 50% are from
stationary sources (e.g., chemical manufacturing, evaporation, solid
ff waste disposal, etc.) and 50% from mobile sources (e.g., autos,
trucks, aircraft, etc.). Of course, this distribution of emission
1 sources will vary within any given area, with many urban areas
M having more mobile source emissions than stationary source emissions.
9. Emissions of organic compounds from light-duty vehicles,
fl light-duty trucks and heavy-duty vehicles are regulated by statute
on time schedules independent of that for attainment of national stan-
£ dards. The 94th Congress considered modifications to current auto-
^ motive emission rates. It is anticipated that some Congressional
action on this subject will be taken in the near future. Thus, precise
estimates of growth in automotive emissions Into the 1980's are dif-
ficult to make at the present time.
10. Reevaluatlons of smog chamber studies indicate that given
enough time nearly all non-methane organic compounds will react in
* the photochemical oxidant process. Previously, 1t was believed that
only certain, more "reactive" organics participated in the process.
This new Insight will require a change 1n the historical regulatory
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J/i/V 1977
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philosophy of control of organic compounds to one of minimizing all
NMOC, rather than only those organics previously thought to be "reac-
tive."
11. At the present time, few control regulations are available
to implement a "total" non-methane organic control strategy. Regulatory
approaches are needed and are under development at the present time.
In recognition of these factors, and in accordance with the need
to attain and maintain the national photochemical oxidant standard,
the following points should be considered in developing an approvable
control strategy for photochemical oxidant where needed:
(A) Where an existing State Implementation Plan (SIP) 1s sub-
stantially inadequate to provide for attainment and maintenance of
the national photochemical oxidant standard, the plan must be revised.
(B) In recognition of transport from urban areas (Statement 4),
the control of photochemical oxidant should primarily center upon
sources within an urban area. Actions Instituted 1n urban areas will
produce benefits in outlying areas and in the more distant downwind
areas as well. However, the Agency encourages State Initiated organic
emission reduction actions over broad geographical areas such as those
considered at the Multi-State Conference at Moodus, Connecticut in
September, 1975.
(C) In recognition of our limited knowledge on the Impact of
control of NO on photochemical oxidant at the present time, a control
/\
strategy to minimize ambient photochemical oxidant concentrations in
urban areas should Include reductions in man-made non-methane organic
emissions and should not necessarily include NO emission control regu-
^
latlons.
1-4 JAN 1977
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(D) In order to determine the degree of control possible by
sources, It may be necessary to obtain specific emission Information
concerning the type and amounts of non-methane organic compounds
emitted from the source. Applicable control techniques may vary
from source to source, depending upon the chemical and physical
ii properties of the organics emitted. Hence, such information, in
addition to the "total" non-methane organic compounds emitted may
be needed.
(E) The degree of non-methane organic compound control needed
to provide for attainment of the photochemical oxidant standard should
be estimated using Appendix J (or an acceptable substitute). Though
» there are acknowledged deficiencies with Appendix J, 1t is, at this
time, the recommended source/receptor relationship for photochemical
I oxidant. The Agency is evaluating and validating a wide range of
photochemical oxidant models and in early 1977 will publish alter-
£ native(s) to Appendix J. The new techniques will attempt to accom-
fmodate transport and the effect of NO .
X
(F) Where needed to provide for attainment and maintenance of
ft the Ox standards, all achievable control measures for non-methane
organic compound sources shall be required. Those measures which are
f achievable for stationary sources and transportation and land use
_ related sources are Identified in paragraphs (I) and (K) below.
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(G) The determination of control measures for stationary sources
1s under rather extensive review at the present time. The existing
example organic compound control regulations published in Part 51,
Appendix B,* are no longer considered as describing available technology
for such sources.
(H) In recognition of the fact that all organics will react
1n the photochemical process, control of all non-methane organic
compounds rather than just the more reactive organic compounds will
be needed to provide for attainment of national standards in many
areas. Unfortunately, in the near term, a substantial reduction of
all non-methane organic emissions from stationary sources is not
generally achievable. Because of the different physical and chemical
properties of the organic compounds emitted from processes, it 1s
usually unworkable to draft control regulations which encompass a
wide variety of emission source categories. In the future, it will
usually be necessary to establish control regulations applicable to
individual source categories.
(I) Definitions of available control technologies for certain
stationary sources are presently under investigation. Activities spe-
cific to the control of organics for coating operations for existing
plants are proceeding within the following source categories: the paper
industry, the fabric industry (coating and rubberizing), the can and
coil industries, and the assembly of auto and light truck industry.
A final document containing information on available control
*Append1x B to CFR, Part 51, may soon be revoked.
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technologies for these sources will be distributed to the Regional
Offices as an OAQPS Guideline shortly. In addition, similar work
has begun on the following source categories: the film and
foil coating industries, the dry cleaning industry and those opera-
m tions using organic compounds for degreasing. Information such as
the degree of achievable control, the costs involved, the time
required to install or modify a process is being considered and
documented.
(J) In those areas where the reactivity definition included in
the Los Angeles Rule 66 has been adopted, States should be encouraged
_
to continue to require source compliance with its provisions.
ft (K) Available control measures for transportation and land use
related sources include: (1) Inspection/Maintenance, (2) Vapor Con-
| trols for Gasoline Marketing, (3) Heavy Duty Vehicle (HDV) Retrofit,
_ (4) Transit Improvements, (5) Employer Incentives, (6) Parking Manage-
» ment/Restrictions, (7) Traffic Management/Restrictions, and (8) Ship
f and Barge Controls. Two measures are considered not reasonably avail-
able. They are gasoline rationing and retrofit for light-duty vehicles.
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Review of Control Strategies for In-Use Vehicles. EPA 460/3-74-021,
Dec., 1974.
I 2
Evaluation of Retrofit Devices for Heavy Duty Vehicles - NYC Dept. of
Air Resources, Bureau of Motor Vehicle Pollution Control, ERA Grant
# S-802909, Dec., 1975.
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(L) Attainment of the national photochemical oxldant standard
in certain areas of the nation with very high population densities,
and/or which are affected by summer air stagnation conditions will
be difficult. However, control agencies must reduce oxidant levels
to the lowest practicable level, as quickly as possible. If needed, all
achievable controls must be adopted to provide for improvement in air
quality toward the eventual attainment and maintenance. However, the Agency
does not intend to require States to adopt unachievable or unreasonable
regulations (e.g., gas rationing). Amendments to the Clean Air Act
to support such a position were considered by the 94th Congress.
(M) The Boston CO/Ox SIP (40 CFR Part 52, June 12, 1975, FR 25152)
should serve as a prototype for revised oxldant SIP's where achievable
controls are inadequate to provide for attainment and maintenance.
Where all achievable control regulations submitted by the States are
inadequate to attain standards, the submittal should be considered
an interim plan, with other control measures being explored and adopted
as they become available. Although the plan would not contain a
demonstration that the standard will be attained, there should be a
demonstration of the effect of the promulgated regulations 1n relation
to the final degree of control needed. The plan shall also identify
those additional actions that will be taken in the future.
(N) Because all achievable regulations will probably be needed
1n many areas of the nation to attain and maintain the national stan-
dard for photochemical oxldant, the adoption of achievable control
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measures should be relatively uniform nationwide; however, the sequence
and time of implementation of these measures may be somewhat different
in different areas for good cause and will require judgment by the
State and EPA Regional Office.
(0) The Agency program for oxidant reduction is complex and
broad and is not limited to SIP's. Development of new source perfor-
mance standards (NSPS) and the Federal Motor Vehicle Control Program
(FMVCP) are key features in controlling growth of organic emissions. To
date, New Source Performance Standards for organic compounds require
the installation of a floating roof on petroleum storage tanks.^ '
Recently, an Internal EPA Task Force has been organized in an attempt
to accelerate the pace of development of NSPS for organic chemical
manufacturing sources.
The following is a 11st of sources for which 1t is anticipated
that new source performance standards will be developed or revised and
the expected year of proposal.
Year Source Categories
1977 Petroleum storage and transfer of crude oil and gasoline
1977 Gasoline marketing regulations (terminals)
1977 Dry cleaning
1977 Coating of automobiles and light trucks on assembly
lines
1977 Solvent degreasing
1978 Stationary internal combustion engines
^39 FR 9317, March 8, 1974.
JAN 1377
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1978 Storage and transfer of organic liquids other than
gasoline and crude oil
1978 Petroleum refineries
1978 Waste solvent disposal
1978 Car coating
1978 Paper coating
1978 Coil coating
1978 Fabric coating
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§ SUMMARY OF PROCEDURES REQUIRED FOR THE REVIEW AND/OR DEVELOPMENT
OF A STATE IMPLEMENTATION PLAN CONTROL STRATEGY
* FOR PHOTOCHEMICAL OXIDANTS
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Scope and Objectives
p The development of an air pollution control strategy designed to
attain and maintain the National Ambient A1r Quality Standards (NAAQS)
m requires an analysis of current and possible future air quality pro-
m blems. It 1s the objective of this section to briefly present the
quantitative and qualitative procedures used in developing an acceptable
plan for the control of photochemical oxldant. The amount of work
Involved in each step will vary from area to area depending on available
I data, magnitude of the oxldant problem, types of emissions sources,
M etc. These steps can be summarized as follows:
STEP 1: Review available Ox air quality data to determine 1f sufficient
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data is available to determine the adequacy of the SIP.
STEP 2: Determine the validity of available air quality data.
STEP 3: Determine the second highest ambient 1-hour concentration.
STEP 4: Analyze the adequacy of the SIP to attain/maintain national
* standards .
STEP 5: Determine the geographic area to be considered 1n the analysis.
STEP 6: Determine the sources of organic compound emissions 1n the area.
STEP 7: Determine the degree of control needed to attain the NAAQS.
STEP 8: Determine expected growth in emissions.
JAN 1977.
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STEP 9: Determine emission reduction required to attain/maintain the
national standards.
STEP 10: Determine whether existing emissions will be reduced by
compliance with existing regulations.
STEP 11: Where additional control measures are necessary, consider
application of available control measures.
STEP 12: Determine most expeditious date of attainment.
«-2 JAN 1977
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I STEP 1: Review available Ox air quality data to determine if sufficient
data are available to provide evidence that the national stan-
dards are not being attained or will not be maintained. Are
n 2}
jj sufficient data available to make such a judgment? Valid datav * '
from at least one oxidant "season" (i.e., April to October)
fl should be available, however, 3 or more years data are preferable.
Data should also be available from areas of expected maximum
I concentrations (i.e., 10 - 30 miles downwind of concentrations
of emission sources), however lack of such data should not pre-
clude the development of a control strategy 1f available data,
though limited indicate valid violations of national standards.
STEP 2: If data exist to indicate a potential attainment or maintenance
£ problem, review the ambient air quality data to determine its
validity and representativeness.
I (3)
(a) Review the location of the Ox monitors/ ' Are they pro-
perly located in accordance with siting criteria? Are sites
biased toward local interferences such that they do not represent
areawlde problems? Local source interference could be consi-
derable for photochemical oxidant. Monitors should not be located
too close to major roadways or point sources of NO , since such
A
« sources may have a scavenging effect on Ox, thereby Indicating
lower maximum concentrations than existing in the general area.
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_ OAQPS 1.2-008, August 1974.
^Guidelines for the Evaluation of Air Quality Data. OAQPS 1.2-015,
Feb., 1974.
Guidelines for the Interpretation of Air Quality Standards.
1.2-008, August 1974.
Guidance for Air Quality Monitoring Network Design and Instru-
ment Siting. OAQPS 1.2-012 (Revised. Sept.. 1975.
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(b) Determine if a satisfactory measurement procedure was used
to collect Ox data being reviewed. The following measurement
procedures are acceptable: Coulometric (SAROAD Method Code
13 and 15); Neutral KI Colorimetric (SAROAD Method Code 14);
and Chemiluminescence (SAROAD Method Code 11). Data collected
by other methods are unacceptable and data from such measure-
ment techniques should not be used for control strategy pur-
poses. (See page III-D-1.)
(c) Analyze the available Ox air quality data to assure its
validity and reliability.
(1) Determine if the data were collected by monitors that
are properly operated, maintained, calibrated, and that adequate
quelity control procedures were utilized to assure validity of
data.^ ' If it is believed that the data would not survive
the scrutiny of a source challenge, then such data should be
rejected.
Guidelines for the Evaluation of Air Quality Data. OAQPS
1.2-015, Feb. 1974.
Quality Assurance Handbook for Air Pollution Measurement
Systems. Vol. 1 - Principles - EPA-600/9-76-005, January 1976.
(2)
v 'It is recognized that the calibration method may result in
a positive 10% bias. Further, it is recognized that a tech-
nical study indicates that a generally larger negative bias
has been observed among experts following established cali-
bration and monitoring procedures. On the surface, these
studies tend to discredit all oxidant measurements, however
upon examination, the 10% bias is relatively small in areas
greatly in excess of the standard. Further, the generally
larger negative bias among experts indicates that the actual
ambient levels are worse (not better) than actually measured
such that additional controls are probably needed beyond that
indicated with measured data. Hence, oxidant measurements
probably underestimate the true concentrations. Data pro-
perly colTected under established procedures are good quali-
tative Indicators of the minimum degree of control that is
needed to attain national standards.
"-4 JAN
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(2) Review specific data for determination of abnormal
values. Obtain frequency distributions of Ox data. Inspec-
tion of the higher percentile values may identify abnormally
H high values. Also a review of when the maximum concentrations
were measured may suggest abnormal or suspect data (e.g.,
nighttime vs. daytime). Where necessary, this review should
include:
(a) Strip charts and laboratory reports.
I (b) Field log books for notations concerning
operations and maintenance activities.
(c) Basic data to assure temporal balance of air
quality data (e.g., a missing quarter of air
quality data).
(d) Changes made in sampling methodology, main-
tenance procedures, calibration procedures or
. quality control practices.
(e) Meteorological conditions at time of maximum
concentration.
tt (3) If abnormally high values have been measured and
are considered suspect, 1t may be useful to review operating
£ parameters for other instruments at the same monitoring site
. to determine whether electrical problems or heat1ng/a1r con-
d1t1on1ng problems may have caused abnormal values.
fl (4) Where available, review data from nearby monitoring
sites and compare the concentrations measured by the other
| . Instruments at those sites with the high concentrations measured
by sampling instruments at the site 1n question.
11-5 JAN 1977
I
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(5) If data are acceptable from a sampling point of view,
to the degree possible explore unusual or non-reoccurring
external problems that may have caused high oxidant concentrations.
(d) To determine if Ox air quality concentrations are represen-
tative, review the Ox air quality trend at each site for the
area being studied.
(1) Review the Ox trend at each site to identify fluc-
tuations in Ox levels.
(2) Review parameters that would help explain trend. '
Review organic and NO emissions inventory, and compliance
/\
information to determine if any significant changes (increases
or decreases) in regional emission of organic compounds and/or
NO have taken place.
J\
NOTE: The purpose of Step 2 is to insure that the data which
will be used as the basis of a control strategy and costly
regulations are valid, or can reasonably be assumed to be valid.
If it is believed that the data are questionable and factors
exist that could reasonably challenge the data validity, then
such data should not be used as the basis of a control strategy.
If on the other hand, all reasonable measures have been followed
in the collection of the data, and unless the validation efforts
prove the data to be Invalid, then such data should be assumed
valid and useable.
H"6 JAN 1977
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STEP 3: Determine the second highest measured ambient 1-hour con-
centration that best represents ambient air quality levels
in the area. For most areas, it will be equal to the
second highest 1-hour average that occurred in a calendar
year over the last 2 or 3 years. Measured data in lieu of
statistically derived concentrations should be used as the
basis of the control strategy (see pages III-B-3 and III-B-4).
STEP 4: If the second highest 1-hour ambient air quality concentration
is equal to or above the national standard, it will be neces-
sary to analyze the adequacy of the existing Ox control stra-
tegy to determine its ability to provide for attainment and
maintenance of the NAAQS for photochemical oxidant.
STEP 5: Determine the geographic area to be considered in the analysis.
From available data, determine the geographic area where emission
sources need to be controlled. Evidence exists which Indicates
that oxidant and its precursors can be transported 100 miles
or more. It is believed that a substantial portion of high
oxidant measurements in non-urban areas result from transport
of oxidant and its precursors from urban areas. Therefore,
the control strategy should primarily concentrate on sources
within the urban area. Control in such areas should reduce
ambient concentrations in the urban and the surrounding area
and more distant downwind areas.
II-7
JAN 1977
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STEP 6: Determine the sources of organic compound emissions in the area.
This includes both mobile and stationary sources. Data are
needed for two purposes: (a) to generally assess where the
ambient oxidant problem originates; and (b) to determine the
emissions reduction impact of various possible control regula-
tions on source emissions.
Available emission data have been shown to be generally
adequate to provide for the assessment of the organic compound
emissions in an area, however, these data may not in all cases
be adequate for possible control strategy evaluation. Since
the control strategy is designed to minimize high oxidant con-
centrations in the "summer" months, emission estimates on a
daily basis (seasonally adjusted) rather than annual data are
desirable. Further, for control strategy design purposes, it
may be necessary to have the following information:
(1) Specific organic compounds emitted - This information
may be necessary when determining the applicability of control
regulations.
(2) Emission variability - Due to the nature of many
organic emissions (evaporative loss), organic usage and emissions
may vary by season, whereas the process may not. Also some
sources of organic may have a greater operating rate during the
April to October period and therefore have a greater impact on
ozone/oxidant levels than a source of the same size which operates
at a constant level all year.
II-8
JAN 1977
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(3) Process equipment - In some cases of solvent usage,
the operating conditions of the process can be adjusted to
reduce emissions. A requirement for sources to operate
equipment at a lower temperature or to place lids on vats of
solvents may reduce the solvent usage and thereby decrease
organic compound emissions.
Mobile sources also account for a large percentage of
the organic compounds emitted to the atmosphere and must be
inventoried. The inventory should include emission estimates
for:
(a) Light Duty Vehicles (LDV)
(b) Light Duty Trucks (LOT)
(c) Heavy Duty Gas Vehicles (HDGV)
(d) Heavy Duty Diesel Vehicles (HDDV)
(e) Motorcycles
(f) Aircraft and others.
In order to calculate emissions for vehicles, the fol-
lowing information is needed:
(a) The age distribution of vehicles and average VMT
by age 1n the area. In Heu of this, the national age dis-
tribution (contained within AP-42*) can be used.
(b) VMT by vehicle category.
(c) Expected growth rate 1n VMT by vehicle category.
(d) Average speed, temperature and the frequency of cold
starts to hot starts in operating motor vehicles. (National
averages are contained within AP-42.)
Compilation of Air Pollution Emission Factors, and various
supplements, EPA AP-42. j/\N 1977
II-9
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Emission estimates will need to be adjusted to reflect
emission reductions that have occurred from source compliance
with adopted regulations (see also step 10).
STEP 7: Using a source/receptor relationship, determine the degree of
control needed to attain and maintain the NAAQS. In the near
future, EPA will make available alternative models to Appendix
J which may be used to determine the degree of control required.
In those cases where a determination of the degree of control
necessary is required Appendix J should be used. For oxidant
concentrations above 0.28 ppm, a proportional relationship can
be used to extend the Appendix J curve. This may be accom-
plished by the following procedure:
(a) determine second highest concentration - assume 0.42 ppm
for this example,
(b) 0.42 - 0.28 = 50% reduction needed to attain 0.28 ppm,
0.28
(c) 0.28 ppm requires 92% reduction to reach 0.08 ppm, and
(d) 50% + 92% (100% - 50%) = 96% control required at 0.42 ppm.
APPENDIX J
MXWIN HEAIUBEO I hour PHOTOCHEMICAL OHIOAHT CCNCEHmilON nil
»1! OB 0 Zi
NOTE NO HYDROCARBON OR PHOTOCHEMICAL.
OXIOANT BACKGIIOUN5 ASSUMED
mo :» rao )ifl no
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Procedure
Using the second highest 1-hour ozone/oxldant concen-
tration determined in Step (3), determine the percent reduc-
tion (R) in organic emissions necessary to attain the stan-
dard from Appendix J or an appropriate alternative model.
Multiply the total base year emissions (Ej) determined in
Step (6) by the necessary percent reduction required. This
will yield the emission reduction (ER) to existing sources
required to provide for attainment.
(R) (ET) - ER
Example
If organic emissions in the base year were 50,000 tons
and the 2nd highest 1-hour oxidant concentration was 0.15 ppm,
determine the emission reduction needed to provide for attain-
ment of the Ox standard.
(1) From Appendix J for 0.15 ppm, a 50% reduction 1n
organic emissions is needed.
(11) 50£ x base year emissions = (ER) emission reduction
needed. 0.50 x 50,000 tons = 25,000 tons reduction
in existing emissions needed to provide for attainment.
STEP 8: Determine the future growth of emissions of organic compounds
(Eg) in 5-year increments generally over the next 20 years;
this period and the increments may be less 1n certain cases;
see 40 CFR 51.42 published in the Federal Register of May 3,
1976 at 41 FR 18382.
11-11
JAN 1977
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Various guidelines have bt.en prepared vr'th regard to
obtaining and projecting growth in emissions and allocating
such growth. The techniques presented therein are too detailed
to summarize here. The reader is referred to the following
volumes of the Guidelines for Air Quality Maintenance Planning
and Analysis.
(a) Vol. 7. Projecting County Emissions, EPA 450/4-74-008.
(b) Vol. 13. Allocating Projected Emissions to Subcountv
Areas. EPA 450/4-74-014.
An excellent synopsis of the entire Air Quality Planning
process is found in the Air Quality Analysis Workshop: Volume 1 -
Manual. EPA 450/3-74-080-a, November 1975. Growth of stationary
and mobile sources should be obtained on the most detailed level
available commensurate with resources and other aspects of SIP
development. Because of the areawide nature of photochemical
oxidant which exists due to the time required to form ozone/
oxldant, allocation of organic emissions to subareas is not as
critical as suballocation might be for other pollutants, hence
it 1s generally not necessary. Subregional allocation is useful,
however, in determining the geographic impact of the control
strategy.
11-12
OH,< 1977,
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STEP 9: Determine the organic compound emission reduction necessary
to attain and maintain the NAAQS for oxldant. Adding the
required emission reductions (ED) obtained 1n Step 7 and the
R
growth in emissions (Eg) determined in Step 8 provides the
total reductions (Ej^) necessary to attain and maintain the
standard over the time period considered.
I ETR ' ER + EG
STEP 10: Determine whether existing emissions will be reduced by source
fl compliance with already adopted control regulations.
(a) Consider the impact of the FMVCP over the time period
I (see page III-B-11 for discussion of vehicular emission rates for
^ light-duty motor vehicles to be used prior to Congressional
action.)
(b) Consider the impact on organic emissions (both Increases
and decreases) that may result from (1) compliance with adopted
jj organic emission control regulations, or the regulations adopted
^ primarily to minimize emission of another pollutant but which
may have an effect on organic compound emissions, such as
ft various transportation control measures (TCM) or Inspection/
Maintenance (I/M) programs for CO that may Increase or reduce
organic compound emissions and (2) ESECA or other fuel switches
that may increase or reduce organic emissions.
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STEP 11: When additional controls are needed to provide for attainment
and maintenance of NAAQS, consider the application of available
control measures.
Specifically the control strategy should consider where
needed (1) the full range of achievable stationary source
controls for the urban area as a minimum; and (2) all
reasonable transportation control measures (Including an
Inspection and Maintenance Program) for the central city and
for adjacent areas of high vehicle density where these controls
can be effective. See Section III-C for description of achievable *
controls for mobile-related and stationary sources. To the
extent possible alternative control strategies should be developed
and tested. The strategy selection should be made on the basis
of adequacy of achieving desired goals as well as on the effec-
tiveness and implementability of the various control schemes.
STEP 12: Considering the type of controls that are needed for attainment
of NAAQS, determine the most expeditious date when NAAQS can
be attained. This shall be within 3 years except 1n certain
specific cases. If it is found that the application of all
available control technology will not result 1n attainment,
application of all available control technology must proceed as
expedltiously as practicable. As other measures become available,
they must be applied also.
, JAN 1977
11-14
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Ill
QUESTIONS FREQUENTLY RAISED CONCERNING PHOTOCHEMICAL OXIDANT
Factors that are of Interest and which should be considered 1n
the development of a control strategy for photochemical oxldant are
presented 1n the following pages 1n question and answer format. Most
of the answers are brief; however, one or more references are generally
provided for more specific Information. In some cases, copies of the
more pertinent references are Included 1n Section IV of this manual.
The questions/answers are subdivided by topic. Topics are discussed
1n the following order:
Sub-Chapter Topic Pases
III-A Attainment of National Standards III-A-1 to III-A-3
III-B Control Strategy Development III-B-1 to III-B-14
III-C Control Technology for Sources of
Organic Compound Emissions III-C-1 to III-C-20
III-D A1r Quality Monitoring for Photochmlcal
Oxldant III-D-1 to III-D-7
III-E Emission Data III-E-1 to III-E-7
III-F Chemistry of Photochemical Oxldant III-F-1 to III-F-7
III-l
JAN 1977
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III-A
fl - ATTAINMENT OF THE NATIONAL STANDARDS -
QUESTION - Is there a national ambient air standard for hydrocarbons?
m Must it be attained?
ANSWER - The Agency promulgated an ambient air quality standard
I for non-methane hydrocarbons. Theoretically it represented EPA's
judgment of the maximum level of non-methane HC that would not
I cause a violation of the 0.08 ppm oxidant standard under optimum
conditions of sunlight and NO . However, EPA has historically
I
based the need for HC control on the magnitude of the oxldant
problem rather than on the hydrocarbon concentrations in the air. State
implementation plans (SIP's) are not required to meet the hydrocarbon
£ "guideline", nor does EPA require measurement of hydrocarbons 1n the
_ ambient air. However, where monitors are available, ambient hydrocarbon
data can provide valuable information. The hydrocarbon guideline need
not be considered for purposes of control strategy decisions.
QUESTION - What 1s the National Ambient Air Quality Standard (NAAQS)
I for photochemical oxldant?
ANSWER - The NAAQS for photochemical oxldant is 160 micrograms per cubic
B meter (0.08 ppm) - maximum 1-hour concentration not to be exceeded more
than once per year as measured by the Federal Reference Measurement
Principle and Calibration Procedure (FRM).
I
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JAN 1977
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ADDITIONAL INFORMATION - (1) Code of Federal Regulations, Title 40 -
Protection of Environment, Subpart C - A1r Programs, Part 50 - National
Primary and Secondary Ambient A1r Quality Standards, Section 50.9 codi-
fied from Volume 36 of the Federal Register, page 22384 dated November 25,
1971, (2) A1r Quality Criteria for Photochemical Oxidants - AP-63.
QUESTION - Is the NAAQS for oxldant valid?
ANSWER - Yes, it was based upon the best available information at the
time of promulgation. Continuing study and revaluation of the standard
1s proceeding, however recent studies have found no basis for revising
the standard. A report by the National Academy of Science (NAS) to
Congress, September 1974, stated, "In general, the evidence that has
been accumulated since the promulgation of the Federal ambient air
quality standards by the EPA Administrator on April 30, 1971, supports
those standards. Hence, on balance, the (NAS) panels found no substan-
tial basis for changing the standards."
A recent report by the World Health Organization also reached the
following conclusion.
It 1s apparent that any primary protection standard
between .05 and .10 ppm will provide the narrowest margin
of safety against some possible detrimental effects 1n the
more susceptible segments of the population. There would
seem to be little justification for exceeding .10 ppm for
a primary protection standard, and the fact that the thres-
hold limit value for occupational exposures in the United
States 1s .10 ppm should reinforce the conclusion that this
is the upper limit for a primary protection standard for
the general population.
III-A-2
JAN 1977
-------
I
ADDITIONAL INFORMATION - (1) NAS Report to Congress. "Health Effects of
§ A1r Pollutants," Serial 93-24, Volume 2; Sept. 1974. (2) The Health
m Inplications of Photochemical 0x1dant A1r Pollution to Your Corpunl ty;
EPA 450/2-76-015 (Aug. 1976). (3) Environmental Health Criteria for
M Photochemlcal 0x1dant, World Health Organization, Draft Report
EHE/EHC/WP/75.5, March 20, 1975.
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JAN 1977
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III-B
- CONTROL STRATEGY DEVELOPMENT -
QUESTION - For what reasons must SIP's be revised?
ANSWER - Section 110(a)(2)(H) of the Clean Air Act, as amended requires
that SIP's provide "for revision, after public hearings, of such plan
(1) from time to time as may be necessary to take account of revisions
of such national primary or secondary ambient air quality standard; or
| the availability of improved or more expeditious methods of achieving
g such primary or secondary standard; or (ii) whenever the Administrator
* finds on the basis of information available to him that the plan is
ft substantially inadequate to achieve the national ambient air quality
primary or secondary standard which it implements."
QUESTION - What is Agency policy regarding requests for State Imple-
_ mentation Plan (SIP) revisions to attain and maintain the NAAQS for
" photochemical oxidant?
ANSWER - One major air activity in FY 1976 was the review of all SIP's
to identify those which are substantially inadequate for attainment
g and maintenance of national standards.
The results of these activities have been consolidated 1n calls
for plan revisions Issued by the Regional Administrators in July, 1976.
These calls for revision addressed areas in which the SIP was found to
be substantially Inadequate for attainment.
I
I
IIII-B-1.
I
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SIP revisions for oxldant must be submitted by July 1, 1978.
This submission ought to include ("} a control strategy, (2) emission
limit regulations for industries, (3) transportation measures that
are currently practicable. However, in areas where attainment is
not demonstrated, the states should be made aware that their SIP
is not fully approved and that additional measures must be submitted
as soon as an adequate technical basis is developed. This will
include (1) RACT for all industries where possible and (2) many
additional transportation measures. In many areas, the application
of all the measures outlined above will not result in attainment
and maintenance of the oxidant standard. In these areas, the SIP
will need to be revised periodically to include additional control
as technology improves and new transportation and land use measures
become feasible.
ADDITIONAL INFORMATION - (1) Nov. 12, 1975, Memo from Roger Strelow/
Stan Legro to All Regional Administrators, Subj: Agency Policy Regarding
Calling for Plan Revisions to Approved State Implementation Plans that
are Substantially Inadequate to Attain National Standards; (2) Mar. 16,
1976, Memo from Roger Strelow to Regional Administrators, Subj: Regional
Air Quality Attainment/Maintenance Activities; (3) Guidelines for
Determining the Need for Plan Revisions to the Control Strategy Portion
of the Approved State Implementation Plan, OAQPS 1.2-011 (Revised).
HI-B-2
-------
QUESTION - How frequently should plans be updated to reflect new
information with respect to air quality measurements, emissions data
and modeling techniques?
| ANSWER - In cases where the adopted control strategy is clearly in-
g adequate to attain national standards for photochemical oxidant, the
* plan should be revised as new technology becomes available. Efforts
ft are currently underway within OAWM to define this technology for
both mobile and stationary sources of organic emissions. In those
cases where the plan is believed adequate to attain national standards
or Is marginally inadequate to attain national standards, it may be
prudent to delay new calls for SIP revisions until the impact of full
implementation of the control strategy can be assessed.
QUESTION - How much ambient air quality data are necessary to serve as
a basis for a control strategy?
ANSWER - One oxidant season of data from at least one monitoring sta-
tion 1s generally needed, but where possible three or more years of moni-
toring data should be examined prior to defining a SIP design value.
While it is beneficial to have many years of data at numerous sites,
the development of a control strategy should not be postponed if
minimal valid data exist that indicate substantial violations of the
| national standards.
Measured data, not statistically derived concentrations should
be used as the basis of the control strategy. When using any oxidant
air quality data, it should be remembered that the late spring to early
I
JAN 1977
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fall period is the most important when assessing the adequacy of a plan
for oxidant. While violations of the oxidant standard may be observed
at other times of the year, they are generally not of the frequency
and magnitude of violations observed during the summer.
QUESTION - Why should measured data, rather than statistically generated
second maximum one-hour concentrations be used for photochemical oxidant
control strategy development purposes?
ANSWER - Occasions of peak concentrations are relatively infrequent and
may result from non-typical conditions. Because of the nature of these
events, they are generally unpredictable. Use of statistical techniques
to predict infrequent short-term events 1s not technically sound. While
statistical techniques are generally useful in predicting long-term
averages, the precision of such techniques for predicting short-term
peak situations is limited. A statistical technique might predict the
maximum for an "average" year but the confidence interval on such a
prediction would be broad and the interpretation of an average year 1s
somewhat vague. Further, from a practical point of view, valid measured
data can provide a sound legal basis for control purposes. Though 1t
is true that measured data will generally not exist for every hour
within a year, and that some probability exists for not measuring
worst case conditions, use of properly maintained continuous monitors
for measuring ambient photochemical oxidant concentrations can provide
data for well over 80% to 90% of the hours within a year. Hence, it
can be reasonably expected that worst case conditions will be measured.
III-B-4 JAN 1977
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Even if peak conditions are not measured, use of available measured
data are more defensible and generally more acceptable than statis-
tically generated data. Additionally, due to the precursor-pollutant
relationship it is difficult to predict the necessary values.
QUESTION - What meteorological data should be considered in determining
representative ambient photochemical oxidant concentrations?
ANSWER - At the present time, meteorological parameters cannot be
explicitly considered in recommended source/receptor relationships.
Models are now under development that may provide a mechanism to
consider transport and other meteorological factors, however until
these methods are available, such parameters cannot be explicitly con-
sidered.
QUESTION - What geographic area should be considered in the control
strategy? Should control strategies include broad geographic areas
such as entire AQCR's, multl-AQCR's?
ANSWER - While it is true that high ambient levels of photochemical
oxidant are observed over broad areas of the nation, at the present
time it is recommended that the control of organic emissions be centered
primarily in urban areas. EPA believes that much of the high rural
levels of oxidant are caused by transport of urban oxidant and precursors.
Hence for areas where the SIP has been determined to be substantially
Inadequate, the metropolitan area should be the primary area of concern
since these areas generally have the highest concentrations and also
contribute significantly to the area-wide problem. Additional guidance
will be forthcoming to assist 1n the determination of the area size
that should be considered for control. Reducing emissions 1n these
areas will minimize oxidant concentrations in the urban and surrounding
areas and will minimize transport of oxidant and Its precursors to
more rural areas. j/\M 1977
III-B-5
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ADDITIONAL INFORMATION - Control of Photochemical Oxldants - Technical
Basis and Implications of Recent Findings, July 75, EPA-450/2-75-005.
QUESTION - What is the definition of rural and urban areas?
ANSWER. - The distinction between rural and urban areas for control of
oxidant is difficult to establish. Guidance will be provided 1n the
near future on how to make this determination. It appears that the
criteria will be based on examination of the area population, NMOC/NO
/\
ratio, and ambient levels of NO .
/\
QUESTION - Should AQCR boundaries be modified for photochemical oxidant
due to the transport phenomena of photochemical oxidant?
ANSWER - No. While there is evidence of long-range transport, many
questions exist about the extent and origin of transported oxidant and
its precursors. More important is the question of how to minimize
existing violations of the photochemical oxidant standards. Recognition of
transport and acceptance of responsibilities for contribution to down-
wind concentrations is essential. Interstate and Intrastate coordination
is necessary on the transport question regardless of AQCR boundaries.
Further, any geographic area can be used as the basis of a control
strategy, e.g., more than one AQCR, or less than one complete AQCR.
QUESTION - Is the Appendix J calculation still the required method of
determining the degree of organic emission control needed to attain the
Ox standard?
ANSWER - Appendix J, based on non-methane organic compounds, 1s still
acceptable and is the standard method; it is acceptable to replace it
III-B*6
f
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with a different technique using local data with adequate documentation.
Although Appendix 0 was the best possible approach 1n 1971, 1t clearly
1s not adequate for a number of situations. EPA 1s evaluating several
models and during early 1977 will publish the results of the review and
suggest possible alternatives to Appendix J. These alternative models
will attempt to accommodate transport and the effects of NO . For
A
immediate decisions the use of Appendix J modified by proportional
rollback for Ox levels greater than 0.28 ppm 1s recommended if local
data are not available (see Section II., Step 7).
ADDITIONAL INFORMATION - (1) An alternative to the Appendix J method
for Calculating Oxidant - and N02 - Related Control Requirements,
Dr. B. Dimitriades; (2) The Use of Trajectory Analysis for Determining
Empirical Relationships Among Ambient Ozone Levels and Meteorological
and Emissions Variables, Dr. E.L. Meyer, et al.; (3) Combined Use of
Modeling Techniques and Smog Chamber Data to Derive Ozone Precursors
Relationships, Dr. M.C. Dodge. NOTE: All of the above papers were
presented at the International Conference on Photochemical Oxidant
Pollution and its Control, Sept. 17-22, 1976, Raleigh, N.C.
QUESTION - Should ambient background concentrations of photochemical
oxidant due to emissions from natural sources be considered 1n the
development of a control strategy, and 1f so, how?
ANSWER - At the present time, no method exists to explicitly consider
ambient natural background concentrations of photochemical oxidant 1n
III-B-7
' JAN 1977
-------
the control strategy. Natural background levels of oxldant due to
natural sources occur on some occasions 1n the range of 0.04 to 0.05 ppm.
Some of the natural sources of organlcs Include vegetation, biological
action, geothermal areas, coal fields, natural gas and petroluem fields
and natural fires. Natural ozone may also be of stratospheric origin,
however, its contribution to overall ozone levels during periods of
high ozone concentrations is minimal.
It is believed that the contribution of natural sources 1s generally
small in urban areas in relation to peak oxldant concentrations. Not
explicitly considering background concentrations in the control strategy
will tend to underestimate the degree of control needed to provide for
attainment and maintenance.
ADDITIONAL INFORMATION - (1) R.M. Angus and E.L. Martinez, Rural Oxidant
and Oxidant Transport, presented at the Conference on State-of-the-Art
of Assessing Transportation Related Air Quality Impacts, Oct. 22, 1975,
(2) Control of Photochemical Oxidants - Technical Basis and Implication
of Recent Findings - July, 1976, EPA-450/2-75-005, and (3) Air Quality
Criteria Document for Hydrocarbons, AP-64.
QUESTION - Should transport of oxidant and Its precursors be accounted
for 1n the development of a control strategy?
JAN 1977
-------
ANSWER - Ideally, yes, but unfortunately at the present time there
1s no available procedure or analytical method available to adequately
consider transport 1n a control strategy. EPA 1s presently attempting
to develop alternatives to Appendix J which may Include the effects
of transport of oxldant and its precursors. In the Interim, only a
limited consideration of transport can be made. For example, transport
may be considered in a limited way by using measured air quality data
observed at a distance of 10 to 30 miles downwind of the urban area, rather
than data within the urban area itself. Depending upon the meteorological
conditions on the day in question, such data will probably represent air
quality resulting from the upwind urban emission sources rather than
local sources. In addition, it may be possible in those cases where
ambient monitors are available in upwind and downwind locations to
quantitatively determine the impact of emissions from urban areas on
air quality. However, because of the complexity of the chemistry
and meteorology involved, such assessments, though noteworthy, may not
provide precise definitions of transport. It should also be noted that
EPA believes that the urban control strategy will have a significant
effect on the amount of oxldant and precursors transported.
QUESTION - What, 1f any, 1s the impact of fuel switching due to ESECA?
ANSWER - The Impact of ESECA 1n relation to organic emissions 1s rela-
tively minor. Only 1/4% of the total U.S. organic compound emissions
are from utilities. Modification of oil-fired to coal-fired boilers
should give only a minor increase 1n organic emissions (I.e., from
0.30 Ibs. to 0.36 Ibs. per 12,000 BTU thermal heat input). Gas to
coal conversion would result 1n Increased organic emissions from
III-B-9
JAN 1977
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0.025 Ibs. to 0.36 "ibs. per 12,000 BVU thermal heat input. For a 500 MW
pi ant a conversion from gas to coal could result in an Increase from
approximately 10 tons/year to 140 tons/year, assuming all boilers
were converted, which 1s unlikely. This total is small compared with
total organics emitted within an area.
QUESTION - To what extent does growth information employed in plan
development for attainment and maintenance have to be internally con-
sistent and coordinated with other planning programs?
ANSWER - Growth projection applied to various emission source categories
must be internally consistent, i.e., projection developed for use in
assuring maintenance of the NAAQS must be consistent with the usually
more limited projections used to plan for the attainment of the NAAQS.
These projections must also be consistent with 208 area-wide waste
treatment planning as well as "3-C" planning done in the urban area.
This kind of consistency can usually be assured by determining which
source of growth information has the most reliable information and then
using that source for all emission projection tasks.
The level of detail available for emission projection purposes
is variable within selected source categories. For example, mobile
source emissions may be estimated for a projection year by calculating
emissions by the procedures in Volume 7 or 13 of the AQM Guidelines using
(1) VMT projections on a transportation link specific basis, (2)
total county VMT projections derived from motor vehicle registrations,
or (3) projected countywide fuel use usually based on population growth.
III-B-10
JAN 1977
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Selection of the level of detail necessary to project growth
for specific emission source categ-.Hti s^ou'd be governed by the
importance of that source to ':he air quality ovoblem at hand and
consideration of what kinds of controls and irvteragency coordination
might later be required. For example, use of link specific VMT
projections obtained from the area's transportdticn planning agency
through the regional (comprehensive) planning agency, while assuring
a common data base for air, land use and transportation planning
purposes, also provides a means, because of Its specificity, to
indicate possible Implementable air pollution controls through
changes in urban land use, the transportation network, or vehicle use
patterns.
QUESTION - What effect will the amendments to the Clean A1r Act have
on automobile emissions rates for organic compounds?
ANSWER - Several different proposals were considered by the 94th
Congress (Table 1) that would alter the existing date (1978) of Imple-
mentation of the 0.41 gram/mile hydrocarbon emission limitation for
automobiles. The proposals 1n Table 1 represent those under considera-
tion by Congress 1n April 1976. Until specific action 1s taken to
amend the law, it 1s recommended that the controls currently mandated
by the Act be used for planning purposes. These are Included in Table
1 under the column heading "Existing."
While there may be some changes in the effective date of emissions
reductions for automobiles, any delay of the nature Indicated 1n Table
1 will not have a significant Impact in the overall control strategy
due to the low rate of vehicle turnover and the fact that emissions
have already been considerably reduced.
III-B-11 JAN 1977
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An overall composite motor vehicle emission projection from 1970
to 1995 considering a 3% annual VMT growth rate, applicable motor
vehicle emission standard, and standard conditions is presented in
Figure 1.
TABLE 1
PROPOSED HYDROCARBON AUTOMOBILE EMISSION STANDARDS
(gm/mile)
Effective Existing Dingell House Sub- Senate House Administration
Year Amendment committee _ Report Proposal
1977
1978
1979
1980
1981
1982
1.5
0.41
0.41
0.41
0.41
0.41
1.5
1.5
1.5
0.9
0.9
0.41
1.5
0.9
0.9
0.41
0.41
0.41
1.5
1.5
0.41
0.41
0.41
0.41
1.5
1.5
1.5
0.41
0.41
0.41
1.5
1.5
1.5
1.5
1.5
0.41
DATE: April, 1976
QUESTION - Recently, it has been noted that evaporative emissions from
automobiles are much higher than originally estimated. What action is
being taken to control this source of organic emissions?
ANSWER - On August 23, 1976, EPA promulgated regulations requiring
70% control of evaporative emissions from light duty vehicles and trucks.
The new regulations and associated test procedures will reduce evapora-
tive emissions from these vehicles from 1.76 gm/mile to 0.6 gm/mile in
1978. These reductions should be accounted for in SIP development.
ADDITIONAL INFORMATION - Federal Register, Vol. 41, August 23, 1976,
page 35626.
QUESTION - It has been reported that the 1975 and 1976 model automobiles
are deteriorating at a higher rate than initially indicated, how should
this be taken into account?
HI-B-12 JAN 1977
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The Increase of deterioration of emission rates for automobiles
nas been noted primarily for carbon monoxide. While there has been an
increase 1n emissions of hydrocarbons the increase in emissions is gen-
era"; 1y rot significant. A new supplement to AP-42 will be released
shcm'.y and the emission rates given there should be used for calculating
automotive emissions.
JM, 1977
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NORMALIZED MOTOR VEHICLE EMISSIONS RATE FOR HC
1.4
1970
1975
1980 1985
CALENDAR YEAR
1990
1995
Assumption:
1. National average automobile and truck age distribution
2. Low altitude, standard conditions
3. 3% Compounded (annual) growth rate
4. National average vehicle mix (LDV 80.4%; LOT 11.8%, HDG 4.6%; HDD 3.2%)
5. 1970 composite emission factor 12.4 g/mi
6. Based on Emission Factors in Compilation of Air Pollution Emission
Factors, AP-42, according to current Federal Law.
III-B-14
1977
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III-C
- CONTROL TECHNOLOGY FOR SOURCES OF ORGANIC COMPOUND EMISSIONS -
QUESTION - What 1s "Reasonably Available Control Technology" (RACT)
for stationary sources, and how Is 1t determined for an Individual
source?
I ANSWER - As part of the original SIP development in 1971 and 1972, the
concept of RACT was expressed as a series of examples of emission limi-
tations attainable by various source classes and v/as published in
Appendix B of 40 CFR 51. This original concept is obsolete, for several
reasons. First, it is now realized that the many individual physical
specifications of plants cannot be covered by a rigid "one-number"
approach. Controls that may be achievable for a source in one area
may not be achievable for a similar source in another area because of
variations in the process, the lack of space to retrofit the controls,
or the like. In other instances, if an attempt 1s made to apply the
I same emission limit to all sources regardless of the specific situation,
one may inhibit the application of better controls that may be quite
I achievable for a specific source at a specific location. Further, it
m 1s the air quality that determines the degree of control necessary in
order to attain the NAAQS. Thus, similar sources may be treated d1f-
ferently in different areas because the reductions 1n air quality neces-
sary to meet the NAAQS will vary, depending on the severity of the air
| quality problem. In some instances, the SIP may not require controls
_ that are at the limit of achievable technology. There are, of course,
III-C-1
m JAN 1977
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situations where the amount of control required to meet the NAAQS is
clearly beyond the limit of achievable technology. In such cases, the
SIP is limited to achievable control measures. But even in such situa-
tions what is achievable in one area may or may not be achievable in
another area. For these reasons, a flexible procedure for determining
the RACT for various areas is appropriate.
With respect to individual point sources with defined emission
points (i.e., those amenable to the application of "classical" control
equipment), reasonably available control technology (RACT) defines the
lowest emission limit that a particular source is capable of meeting
by the application of control technology that is reasonably available
considering technological and economic feasibility. RACT may represent
a relatively stringent, or even "technology forcing," requirement that
goes beyond simple "off-the-shelf" technology.
ADDITIONAL INFORMATION - Strelow, R., to All Regional Administrators,
memorandum, Guidance for Determining Acceptability of SIP Regulations
in Non-Attainment Areas, December 9, 1976.
QUESTION - Which organic compounds react 1n the photochemical oxidant
process and what 1s the Agency's approach to controlling organic
emissions?
ANSWER - Originally it was believed that some organic compounds react
to produce ozone while others do not. It has since been determined
that virtually all organlcs react to produce ozone if Irradiated with
III-C-2
1977
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ultraviolet light for a long enough period. Hence 1n order to provide
for attainment of the photochemical oxidant standard, 1t will generally
be necessary 1n most urban areas to control all man-made non-methane
organic compounds.
QUESTION - Specifically, what regulations for the control of organic
compounds from stationary sources are available at the present time?
ANSWER - Part 51, Appendix B, originally represented the Agency recom-
mendation with regard to organic control. However, experience has
shown several defldences in Appendix B, particularly 1n the area of
organic compound emissions. These include (a) provisions which require
clarification, (b) provisions which contain inadequately defined source
categories, and (c) provisions which are obsolete. Appendix B there-
fore no longer represents Agency policy regarding achievable controls
for hydrocarbon sources and it 1s being modified to remove specific
limitations. A policy statement will be substituted for the current
Appendix B.
At present, EPA is investigating regulatory controls for non-
methane organic emissions from coating operations from existing plants
1n the following industries: (1) paper, (2) fabric (coating and rub-
berizing), (3) assembly of autos and light trucks, (4) cans, and
(5) coils. Copies will be distributed to the Regional Offices shortly
as part of the OAQPS Guideline Series. In addition, similar work has
begun on the following industries: (1) film and foil coating, (2)
degreasing, and (3) dry cleaning.
III-C-3 JAN 1977
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Additionally, Stage I and Stage II controls on gasoline marketing
can provide up to a 90% decrease 1n organic compound emissions from
those sources affected.
QUESTION - If it 1s known that control of all types of non-methane
organic compounds will generally be necessary to provide for attain-
ment of the oxldant standard, why does the Agency encourage the use
of substitution type regulations?
ANSWER - Control technology to minimize all NMOC emissions to acceptable
levels is not reasonably applicable to all sources or has not been
specifically defined for all sources at this time. In the Interim,
substitution of lesser reactive organics for more reactive organics
should reduce oxldant within the general area around the emitting sources.
QUESTION - What are considered available controls for transportation
related sources?
ANSWER - The Office of Transportation and Land Use Policy in a January 9,
1976, Guideline on Policies for the Inclusion of Carbon Monoxide and
Oxidant Controls In State Implementation Plans Identified reasonable
transportation measures for SIP's. Included in those measures deemed
III-C-4
1977
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reasonable are (1) Inspection/Maintenance, (2) Vapor Controls for
| Gasoline Marketing, (3) Heavy Duty Vehicle* (HDV) Retrofit, (4)
_ Transit Improvements, (5) Employer Incentives, (6) Parking Manage-
ment/Restrictions, (7) Traffic Management/Restrictions, and (8) Ship
and Barge Controls. Two measures listed as not reasonably available
were gasoline rationing and retrofit for light-duty vehicles.
| Further, both houses of the 94th Congress endorsed the following
additional land use and transportation type measures for the control
of auto-related pollutant emissions:
(i) motor vehicle emission inspection and maintenance pro-
grams;
(11) programs to control vapor emissions from fuel transfer
and storage operations and operations using solvents;
(111) programs for improved public transit;
(1v) programs to establish exclusive bus and carpool lanes
and areawide carpool programs.
ADDITIONAL INFORMATION - Policies for the Inclusion of Carbon Monoxide
and Oxidant Control in State Implementation Plans, Office of Transpor-
| tatlon and Land Use Policy, Jan. 9, 1976.
QUESTION - What reduction in NMOC's is expected to occur from the
* implementation of various Transportation Control Measures?
I ANSWER - Transportation measures such as mass transit, carpool incen-
tives, etc., will reduce organic compound emissions, and theSe reduc-
|| tions should be accounted for 1n the oxidant strategy.
*A heavy duty vehicle (HDV) is any vehicle in excess of 8500 Ibs. gross
vehicle weight.
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III-C-5
JAN 1977
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Auto-use and emissions reductions achieved by transportation
controls derive from the effects of the entire group of measures
included in a transportation control plan, rather than the effects
of individual measures. Moreover, the effectiveness of specific auto-
use reduction approaches is strongly dependent on local conditions.
Hence in any consideration of oxidant reductions identified with
specific control measures, it is necessary to view these reductions
as rough estimates which are subject to change when placed in the
operating framework of the entire TCP for a particular area.
Several control measures (such as retrofit and inspection/main-
tenance) are available to reduce emissions from 1n-use vehicles. Since
these control measures require that individual vehicle emissions be
reduced by a certain amount, it is relatively easy (when compared to
VMT reduction measures) to quantify emission reductions that may
result from the implementation of these control measures.
The maximum VMT reductions from transportation measures will
result from coordinated measures designed to discourage low occupancy
auto use and to encourage transit and carpool use. However, transit
and carpool incentives by themselves are insufficient for achieving
significant emissions reductions. Programs that do not incorporate
parking restrictions, surcharges, or other disincentives are unlikely
to achieve emission reductions greater than 5 to 10 percent.
In'C"6 JAN 1977
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I
ORGANIC EMISSION REDUCTION MEASURES
Impact on Reference
_ Measure Emissions Number
* 1. Inspection/Maintenance Up to 15% decrease (1)
2. HDV Retrofit Up to 85% decrease
(Catalyst w/a1r
J pump and EGR) (2)
3. Gaseous fuel conversion Up to 60% decrease (2)
References:
I (1) 40 CFR 51, Appendix N (currently being revised).
(2) Review of Control Strategies for In-Use Vehicles. EPA Contract
| Report - EPA 460/13-74-021, Dec. 1974.
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QUESTION - What are the costs associated with Inspection/Maintenance programs?
ANSWER - The following 1s an estimate of the cost associated with Inspection/
Maintenance Programs during 1975-76. i«H«.nun/
FIXED AND OPERATING COSTS OF A TWO-LANE INSPECTION STATION
EMISSIONS ONLY
CENTRALIZED PUBLIC FACILITY
(dollars)
FIXED COSTS Loaded Idle
Equipment
Analyzers (3, w/CO, i!C, CO? and
digital readout) 20,000 20,000
Dynamometers (2) 13,000
Site Costs (approx. 30,000 ft2
required) 20,000-140,000 20,000-140,000
Construction 80,000 70,000
Administrative Startup and
Miscellaneous 7,000 7,000
Extras: Computer Systems, Ignition
Analyzers
Total Fixed Cost 140,000-260,000 177,000-237,000
ANNUAL COSTS
Annualized Capital Cost 21,950-34,050 17,380-29,480
Operating Costs
Salaries (5 inspectors, 1 super-
visor @ 8 hrs/day, 300
days/yr) 80,000 80,000
Supplies 2,940 2,940
Overhead and Administrative Support 37,110 33,680
Total Annual Cost 142,000-154,100 134,000-146,100
COST PER VEHICLE
Design throughput, tests/year/lane 32,000 50,000
Design throughput, vehicles/year/lane 24,COO 38,000
(assumed 30 percent failure rate)
Cost per registered vehicle $2.96-3.21* $1.76-1.92*
*These costs cover only the basics of building and operating stations, end
do not include such highly desirable items as public relations, data analysis,
mechanic training, research, capital expansion as required, etc.
III-C-8 JAN 1977
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FIXED AND OPERATING COSTS OF AN EMISSIONS INSPECTION STATION
PRIVATE GARAGE
IDLE MODE
(ddllars)
CAPITAL COSTS
Equipment - Infrared Analyzer}/
Contingencies and miscellaneous
Total Capital Cost
ANNUAL COSTS
Annual ized capital cost (5 yrs-. @ 10%)
Salaries
Supplies
Alone
2,000
200
2.200
580
2,000
420
w/ ex is ting
safety
2,000
200
2,200
580
1,000
420
Total Annual Cost 3,000 2,000
ANNUAL COST TO LOCAL GOVERNMENT FOR PRIVATE GARAGE I/M, per one
million vehicles (costs of scale should be considered for
different size populations)
Administration 75,000 50,000
Enforcement 104,000 69,000
Annualized Capital Cost 14,500 10,000
Space Leasing, Contingencies, etc. 6,500 1,000
Total Annual Cost to Local Government 200,000 130,000
Per Vehicle Cost $0.20 $0.13
Extras: Mechanic Training (approx. $60,000 per million vehicles)
and certification of Repair Facilities
]_/ With average thruput per station of about 5 vehicles per day,
one analyzer can easily cover up to three bays.
III-C-9
JAN 1977
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Maintenance Cost Guide
Assumptions: a.) Costs applicable to 1976. Data base has been adjusted for
inflation.
b.) 3/4 of repairs are performed by commercial facilities, and
1/4 by do-it-yourselfers.
c.) No credit taken for repair that would be performed as part
of a normal maintenance regimen.
BASIC TABLE
Total* Failure Rate Cost per Serviced Vehicle
10% ' $33.00
20% - $29.00
30% $26.00
40% $24.00
50% $23.00
*Percentage of vehicles rejected for HC, CO, or both.
Conditions of Basic Table:
a.) Idle Test
b.) Proportion of all rejected vehicles failing for excessive
hydrocarbons is 0.35 (normal for most programs)
c.) Maintenance must be mandatory
Adjustments to Basic Table:
Loaded te
Hydrocarbon repair adjustment
x = proportion of all rejected vehicles failing for HC
a.) Loaded testadd three dollars to Basic Table values
b.)
y = adjustment factor (multiply by basic idle or loaded
repair cost).
x 0.0 0.1 0.2 0.3 0.4 0.5 0.75 1.0
' y 0.3 0.5 0.7 0.9~17T 1.3 1.7 O"
c.) Fleetwide Cost per vehicle multiply Cost per Serviced
Vehicle by Total Failure Rate
Example: A planned I/M program is to be loaded-mode, with an estimated
rejection rate of 32 percent, of which the HC failure proportion
is 0.2. Find Cost per Serviced Vehicle and fleetwide cost.
Basic Idle Test cost @ 32 percent $25.50 (interpolated)
Loaded Test Adjustment $3 $28.50
HC adjustment (x 0.7) $19.90 Cost per
Serviced Vehicle
Fleetwide Cost per Vehicle (x 0.32) $ 6.40
IH-C-10 JAN 1977
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QUESTION - What is the fuel savings due to Inspection/Maintenance programs?
ANSWER -
FUEL SAVINS FROM INSPECTION/MAINTENANCE PROGRAMS
Failure
Rate
(x)
50%
40%
30%
20%
10%
4.2
4.73
5.5
6.76
9.66
Annual Fuel
Savings-Serviced
Vehicles Only
(y)
% (gallons)
36
40
47
57
82
Dollar Savings
per Serviced
Vehicle
21.40
24.00
28.00
34.40
49.30
Annual Fuel
Savings-All
Vehicles
(%) (gallons)
Dollar Savings
per Vehicle-
All Vehicli b
2.1
1.89
1.65
1.35
0.97
18
16
14
11
8
10.70
9.60
8.40
6.85
4.90
All savings based on national averages of 11,500 vehicle-miles per
year and 13.58 mpg. Cost of fuel assumed at $0.60 per gallon.
These estimates are based on the most extensive and reasonable
data presently available to EPA: the Olson Short Cycle Tests, as reported
in Section 2.6.2.2 of "A Review of Control Strategies for In-use Vehicles."
An exponential function (resulting in the above table) relating annual
fuel savings for serviced vehicles to failure rate was derived, based
on HC and CO curves from the Olson Short Cycle Tests:
-0.514
y = 31.5(x)
Table figures are derived from tests on both pre-control and post-
control vehicles.
Other, more liberal, results on fuel economy are available, including
those from the IUCP program, New Jersey Bell Telephone, the New York
Taxicab Study, etc.
The Olson Degradation Study (144 vehicles, January 1975 population)
showed an annual fleetwide fuel savings of 3.02 percent at 41 percent
failure rate (OTLUP analysis).
III-C-11
JAN 1977
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QUESTION - What operational experience has been gained with Inspection/
Maintenance programs?
ANSWER - The following pages give pertinent facts concerning various
Inspection and Maintenance programs in New Jersey and Arizona.
Additional information sheets are included in Section IV for Cincinnati
and Hamilton County, Ohio; Chicago; Portland, Oregon; and Riverside,
California.
III-C-12
JAN 1977
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Location: New Jersey
I ...Type of Program: State operated permanent facilities» idle mode,
mandatory inspection and maintenance. Includes
safey inspection. Failed vehicles may be retested
. at certified private garages.
Sites: 39 sites, 69 lanes, 1 mobile van (rotates among sites)
I Chronology: Inspections began July 1972, with voluntary maintenance
phase. Fully mandatory program commenced Feb. 1, 1974,
with Phase I standards. On Nov. 1, 1975, Phase II
standards became effective, and private garage reinspection
. begar. a two-year trial period. Also beginning on this date,
new cars were withheld from inspection for their first two
yearly re-registrations.
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Geographic Coverage:. Entire State of New Jersey (3.8 million LDV's)
§ Administering,Agency: New Jersey Department of Environmental Protection
' *
(establishes standards and technical procedures),
Department of Motor Vehicles (administers testing
and enforces standards).
Capital Cost: $250,000 for analyzers and related equipment-inspection
facilities already in operation for safety.
I. Operating Cost: DEP, $330,000/yr
DMV, $464,000/yr, 20% of which is "fringe benefits"
Total $794,000/yr
I Cost to Motorist: $1.00 taken out of yearly registration fee, includes
safety. $1.00 additional fee at reinspection garages.
I Standards/Failure Rate: Phase I - approx. 12 percent rejection
Phase II - approx. 20 percent rejection
" Phase III - approx. 30 percent rejection
-All phases are four-stage, dependent on model
year.
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JAN 1977
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Enforcement: Vehicle cannot be registered unless inspection is passed..
Enforced by sticker system.
a
Instrumentation: 125 specially modified Sun "EET 910" analyzers w/ color-
coded scales and pass/fail lights.
Data Collection: Response card given to' each rejected vehicle. Record
kept of failure and refailure rates, cost of maintenance,
nature of repair, and type of facility performing
repair. . Initial refailure rate of 40 percent has
dropped to IB percent (under Phase I standards). NJDEP
al.so conducts periodic surveillance on groups of 2000
vehicles.
Mechanic Training: Plans to conduct training program at vocational
schools. Plans to certify mechanics through NJASE.
Exxon has already conducted mechanic training for
emissions, affecting about 15 percent of all service
stations in State.
Waiting Times: Major delays predated the advent of emission inspection
and continued into both emission Phases I and II. Delays
cause many vehicles to needlessly fail the CO emissions
test because of the "hot idle" effect. These vehicles
return to be retested for CO, making waiting lines even
longer. Private garage reinspection and the two year
exemption for new cars were instituted as a result of
excessive waiting times, but have not alleviated the
problem thus far. There have been no recent lane capacity
improvements in New Jersey.
Problems (other): Two year exemption for new cars means approx. 30,000
miles pass before cars are first inspected. Lack of
capital -- capacity improvements cannot be made,
instruments cannot be upgraded, programs (mechanic
training, etc.) cannot be undertaken. Refailure
rate has stabilized at 18 percent.
Achievements: Nation's longest ongoing I/M program, thirteen percent
improvement in ambient CO readings since program began.
This reduction is holding. Three thousand garages have
installed exhaust analyzers (as of 3/75). This number
has risen with the inception of the private
garage reinspection program.
III-C-14
JAN 1977
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Location: Arizona
Type of Program: Contractor operated, permanent and mobile facilities,
loaded mode. Mandatory inspection with voluntary
maintenance during 1976.
Sites: 12 permanent sites, 36 lanes (9 "metro" stations of 3 to 5 lanes
and 3 one-lane stations in outlying areas. One mobile station.
Chronology: Voluntary testing began December, 1975 and became mandatory
1-2-76. Maintenance becomes mandatory January 1977.
Geographic Coverage: Maricopa (Phoenix) and Pima (Tucson) Counties,
approx. 1.1 million vehicles including trucks
and motorcycles.
Administering Agency: Arizona Department of Health Services
Operated by: Hamilton Test Systems, Inc.
Capital Cost: $134,000 one-time appropriation by State.
$9.0 million to HTS, including location studies, administra-
tive start-up, etc., as well as equipment, land acquisition,
and construction.
Operating Cost: Est. $4.5 million by HTS in 1976.
Cost to Motorist: $5, including one free retest.
The legislature is considering maintenance waiver
provisions to accompany the 1977 mandatory maintenance
phase.
Standards/Failure Rate: HC and CO standards at low cruise, high cruise,
and idle dependent on engine type (2 or 4 stroke),
model year (4 stages), curb weight, and number
of cylinders. Cruise speeds dependent on vehicle
weight and"horsepower. 20% opacity standard .for
diesels. Projected rejection was 35 percent,
but 47 percent of vehicles were actually failing
. in early stages of program. All 50 cc and larger
engines are covered, including two-strokes and
diesels. Golf carts are exempted. New cars are
not inspected until one year old. 15 year and
older "moving exemption", e.g., in 1976, model
years 1961 and older are exempted.
III-C-15
JAN 1977
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Enforcement:
Vehicles cannot be registered without proof of inspection
in 1976, or proof of passed inspection starting in 1977.
Proof consists of embossed stamp on registration form by
Hamilton.
Under-hood check for tampering and PCV operation.
Besides annual registration, vehicles must also be inspected
at title change. Scrap and auction sales, and sales between
private individuals are exempted.
Instrumentation:
Data Collection:
All Otto-cycle vehicles tested on Hamilton infrared (NDIR)
exhaust analyzers for HC, CO, and C02. Wider range meter
for two-stroke engines. Opacity testing for Diesels.
Clayton dynamometers. Computer link provides automatic
printout of results (no engine hookup as in Riverside).
Vehicle ID information, all test results, lane location,
time of day, etc. for all vehicles.
Mechanic Training: ADHS has conducted 2-day seminars for mechanics.
Waiting Times:
Other Aspects;
Some problems experienced at start of program, but these
are expected to disappear due to optimizing hours of
operation and better public awareness of all station loca-
tions. 10 minutes is the planned maximum wait during a
typical peak hour.
Total Inspection'time is five minutes.
Of the 5$ inspection fee, $0.55 goes to the State.
Part of this money is used for its own operating expenses
and the remainder is deposited in a special fund to be
used for future expansion, contingencies, etc. Hamil-
ton's $4.45 share of the fee includes profit and program
public relations.
Problems: Initial adverse public reaction.
As of mid-February, repeal,of program remains possibility.
Lack of stabilized operating hours have caused complaints.
Achievements:
Nation's first contractor-operated program keeps cost to
State minimal.
Thruput good, with 100,000 vehicles in first 1 1/2 months.
In the November 1976 election the voters of the counties
Involved approved the I/M program.
III-C-16
JAN 1977
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QUESTION - What is meant by Stage I and Stage II vapor recovery?
ANSWER - Emissions of organic compounds from gasoline handling and
transfer operations result from displacement of vapors above the
liquid. For the purpose of control of these vapors, gasoline handling
and transfer operations have been divided Into three phases:
(1) Filling of tank trucks at bulk terminals.
(2) Filling of storage tanks at service stations, and
(3) Refueling of vehicles at service stations.
Stage I controls are concerned with recovery of gasoline vapors during
the first two phases of this operation. During the first phase of
this operation, gasoline vapors are displaced by the Incoming liquid
I through a vent pipe. Stage I controls require that the transfer of
gasoline not be accomplished unless a recovery system is operational to
| collect these vapors. These controls must be designed to recover
p approximately 90%, by weight, of those vapors normally vented to the
atmosphere. The system generally consists of a nozzle using two hoses,
one for the refilling operation and the other to be connected to the
recovery system. The same basic procedure is used during the second
f phase of operations with the vapors which are displaced from the storage
tank being vented to the tank truck for subsequent recovery at the bulk
terminal.
A Stage II controls apply to vehicle filling and while they generally
work on the same principle, collecting displaced vapors, as Stage I
M controls, there are additional problems Involved. While fill spouts
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HI-C-17 JAN 1977
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for storage tanks can usually be modified to a standard connection,
those on automobiles, trucks, etc., are not uniform and 1n many cases
Impossible to modify. Additionally, while most storage tanks have a
readily accessible vent pipe for the vapors to escape, most vehicle
fuel tanks do not. This means that the vapor must be collected from
the fillneck while fuel is being transferred. These two problems
have resulted in a variety of collection methods. The vapor balance
system requires a tight seal over the tank fillneck and depends upon
the displacement of vapor by the fuel entering the tank. One difficulty
with this is that the design of the vehicle fillneck varies by car model
and year. A second system is called the vacuum assist system. This
system uses a vacuum on the recovery system to pull the vapors from
the tank rather than depending upon simple displacement. The vacuum
assist system also requires a recovery system due to the excess air
taken 1n by the system during vapor recovery.
Stage I controls were promulgated 1n the Federal Register by EPA
for 17 AQCR's on November 8, 1973. Compliance with these regulations
was required prior to July 1976. Minor extensions to this date have
been granted. Stage II regulations were last proposed on November 1,
1976.
ADDITIONAL INFORMATION - A Study of. Vapor Control Methods for Gasoline
Marketing Operation: Volumes I & II, EPA 450/3-75-046a, EPA 450/3-75-046b,
III-C-18
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I
QUESTION - What Criteria must be met to ensure that air quality mea-
H sures are implemented as part of the urban transportation planning
process?
ANSWER - Specifically, five criteria must be met to insure that air
m quality measures are implemented as part of the urban transportation
planning process: (1) The metropolitan transportation planning
organization should participate in the development or revision of
transportation measures; (2) all transportation measures (excluding
source control measures, i.e., I/M and retrofit) scheduled for imple-
M mentation in the next 3 to 5 years should be included in the short-
range Transportation Improvement Program (TIP); (3) all measures
I involving improved transportation system management (e.g., bus priority
treatment, parking controls, traffic-free zones) should be included
| in the Transportation Systems Management (TSM) element of the metro-
_ politan area's transportation plan, regardless of when these measures
* are scheduled for implementation; (4) each transportation measure
must appear in the annual element of the TIP for the year in which
the transportation measure is scheduled for implementation; and (5)
f the transportation plan should be consistent with the ambient air
quality standards, with consistency defined as in the joint EPA-FWHA
guidelines for implementing Section 109(j) of Title 23, (page 17-18).
ADDITIONAL INFORMATION - FY 77 Regional Operations Guidance, Feb. 18,
1976.
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JAN 1977
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QUESTION - What is emulsified asphalt and is it's use an available
control measure?
ANSWER - Emulsified asphalt is asphalt which is in the form of an
emulsion using a nonflammable liquid, generally water and/or emulsifying
agent such as soap. This type of asphalt does not contain the volatile
petroleum distillate used in conventional asphalt paving material.
Emulsified asphalt paving is currently being investigated to determine
if it represents an available control measure for reducing organic
compound emissions.
III-C-20
JAN 1977
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*
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III-D
AIR QUALITY MONITORING FOR PHOTOCHEMICAL OXIDANT
QUESTION - What is the reference method for determining oxldant 1n
the ambient air?
v ANSWER - The Federal reference measurement principle and calibration
H procedure for determining oxldant 1n ambient air 1s the continuous
chenrilumlnescence measurement principle calibrated with neutral
buffered potassium Iodide (NBKI), as defined 1n Title 40, Code of
Federal Regulations, Part 50, Appendix D. This method 1s specific
| for ozone. As previously mentioned, Inaccuracies (I.e., positive
_ bias, approximately 5 to 10%) have been noted 1f the calibration method
* 1s not followed carefully. Interim modifications have been sent to
the Regions on techniques to minimize such inaccuracies while Inves-
tigations are continuing on an Improved calibration method.
| ADDITIONAL INFORMATION - (1) April 14, 1975, Memo from Dr. J.B. Clements,
_ Subj: Clarification of Reference Method for Photochemical Oxldant.
(2) 36 FR 22384, Nov. 25, 1971, As amended at 40 FR 7043, Feb. 18, 1975.
QUESTION - What other measurement methodologies are being used to
monitor photochemical oxldant? Are data collected by these other
I methodologies valid?
ANSWER - In 1973 and 1974 the methodologies 1n Table I were being used
in the field.
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III-D-1
JAN 1977
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III-D-2
JAN 1977
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As can be seen at the present time, data from the Neutral KI
m ColoHmetrlc (Code 14) and two coulometrlc methods (I.e., Codes 13
and 15) 1n addition to the FRM are designated as either approved
or unapproved (but acceptable). Unapproved methods may be used
m until equivalency regulations are promulgated. After promulgation
of those regulations (I.e., February 18, 1975), unapproved methods
A may be used only for limited time periods after which they must be
replaced with approved methods. Specifically, this may not be
B later than 5 years after promulgation for automated methods and six
_ months for manual methods after which time only approved methods
* are to be used. Use of methods designated "unacceptable" should be
discontinued. Further, data collected by such unacceptable monitoring
methods should not be used for control strategy purposes. More
J specifically, data from those methods listed as unacceptable cannot
be used for the following reasons:
I TOTAL Ox 44101 11 ALKALINE KI- INSTRUMENTAL
The alkaline KI method produces such variable results 1n different
hands that data from one site cannot be compared with data from
another.
TOTAL Ox 44101 51 PHENOLPHTHALIN
Results of this method do not agree with those obtained by other
m total oxidant methods.
TOTAL Ox 44101 81 ALKALINE KI BUBBLER
The alkaline KI method produces such variable results 1n different
hands that data from one site cannot be compared with data from
another.
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TOTAL Ox 44101 82 FERROUS OXIDATION
Results of this method do not agree with those obtained by other
total oxldant methods,
ADDITIONAL INFORMATION - (1) Designation of Unacceptable Analytical
Methods of Measurement for Criteria Pollutants. OAQPS 1.2-018, Sept., 1974.
QUEST 101^ - Must a correction factor be applied to relate data from the
various "acceptable" methods to the Federal Reference Measurement Prin-
ciple?
ANSWER - No correction factor need be applied to data collected by
any of the "acceptable" methodologies.
QUESTION^ - Because of the possible inaccuracies associated with the
procedure, must past data collected by the acceptable methodologies be
adjusted to provide a more accurate level of ambient concentrations?
ANSWER - Insufficient information is available to determine exactly
how such data should be adjusted, if at all. The data should be used
as 1s, with recognition given to the possible Inaccuracies 1n a quali-
tative manner.
ADDITIONAL INFORMATION - December 18, 1975, memo from Roger Strelow to
Regional Administrators, Subject: "Errors 1n Ozone/Oxidant Monitoring
System."
QUESTION - Where are maximum ambient concentrations of oxldant observed?
III-D-4
JAN 1977
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ANSWER - During Initial SIP development 1n 1971-72 and until recently
high oxidant levels were believed to be associated with metropolitan
areas. However, recent studies have shown that oxidant levels may
£ frequently exceed the NAAQS throughout large areas of the country. It
_ was always realized that oxidant formation 1s a time-dependent process
* and that maximum concentrations of oxidant would be observed downwind
of the urban center. The studies have shown that oxidant and Its
precursors may be transported in excess of 100 miles. In some cases
the "downwind" concentrations may exceed urban levels. However, such
"rural" concentrations are believed to be predominantly caused by
* transport of oxidant and urban emissions of its precursors. It 1s now
believed that the highest oxidant concentrations will be routinely
observed 10 to 30 miles downwind of the metropolitan area; however, the
I location of instantaneous peak concentrations will vary (I.e., either
closer to or farther from the urban area) depending upon meteorological
» conditions.
ADDITIONAL INFORMATION - Control of Photochemical Oxldants - Technical
Basis and Implications of Recent Findings - July, 1975, EPA-450/2-75-005.
I QUESTION - How does the ambient N0/N02 split Influence the design of
the oxidant monitoring network?
w ANSWER - While this split may have an effect on where highest oxidant
concentrations are observed, other variabilities such as meteorology
and reactivity of organics emitted will probably have a greater effect.
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Oxldant monitors should be located 10 - 30 miles from the urban center
1n the prevailing wind direction during those periods when peak oxidant
concentrations would be expected (I.e., late spring to early fall).
QUESTION - What type of review should be performed to determine whether
an adequate number of monitoring sites have been properly located to
assure the collection of representative data? When should this review
be done?
ANSWER - Air Quality Monitoring Netowrk Design and Instrument Siting.
OAQPS 1.2-012? provides guidance on the siting and numbers of monitors
that should be operated in the field to give representative Information.
Further, FY 77 Agency Guidance Indicates that especially 1n those areas
with ambient air quality levels above the standard that existing moni-
tor^ng methods be reviewed this FY to assure that measurements of the
maximum photochemical oxidant are being made.
While OAQPS Guideline 1.2-012 recommends that ozone Instruments
be placed 5 to 15 miles downwind, recent studies have shown that ozone
instruments should probably be placed 10 to 30 miles downwind (I.e.,
prevailing wind direction during daylight hours during oxidant season)
of metropolitan areas to measure high concentrations on a routine basis
FY 77 Regional Operation Guidelines states that for oxidant, the Regional
Offices should review the general location of oxidant monitors around
major urbanized areas to ensure that at least one oxidant monitor is
located 1n areas downwind of principal urban areas. Generally, no
III-D-6
JAN 1977
-------
overall Increase 1n the number of fixed station oxldant monitors
I appears needed at this time. However, whenever possible reorientatlon
of at least one monitor to a downwind location 1s recommended. Moni-
| tors located 1n rural areas will help provide Information on the
. pervasiveness of the oxldant problem and possibly define the need
* for additional controls.
ADDITIONAL INFORMATION - (1) A1r Quality Monitoring Network Design
and Instrument Siting. OAQPS 1.2-012, Jan. 1974; (2) FY 1977
P Regional Operations Guidance, February 18, 1976.
1
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JAN 1977
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III-E
- EMISSION DATA -
QUESTION - What are the major sources of organic emissions 1n the nation?
ANSWER - The following table 1s a summary of national organic emissions
by major emission category. As may be seen, approximately 50% of organic
emissions are transportation related.
NATIONAL ORGANIC EMISSIONS - 1975
Source Type
Stationary Sources
Organic solvent evaporation
Open burning and Incineration
Petroleum storage and transfer
Chemical manufacturing
Petroleum refining
Fuel combustion
Other Industrial sources
Total stationary sources
Transportation sources
Light duty vehicles
Heavy duty gas vehicles
Off highway vehicles
Heavy duty diesel vehicles
Rail
Vessels
A1 re raft
Total transportation sources
Total
Percent contribution
11.8
10.8
8.8
6.7
4.4
4.0
2.4
48.9
37.0
7.6
3.7
<0.5
<0.5
<0.5
1.9
51.1
100.0
Source: Impact of New Source Performance Standards on 1985
Emissions from Stationary
Tons/year
3,500,000
3,200,000
2,600,000
2,000,000
1,300,000
1,200,000
700,000
14,500,000
10,980,000
2,260,000
1 ,090 ,000
120,000
110,000
100,000
500,000
15,210,000
29,710,000
National
Sources, EPA Contract 68-02-1382,
Task 3, The Research Corporation of New England, Wethers field,
Connecticut.
III-E-1
JAN 1977
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QUESTION - Must emission Inventories of organic compounds contain
information on the reactivity characteristics of the emitted organic
compound?
ANSWER - Yes and no, depending upon the purposes for which the inventory
is to be used. For the purposes of (1) quantifying organic emissions in
an area; (2) determining necessary emission reductions to provide for
attainment of national standards; or (3) determining the actual reduc-
tion in organic emissions that implementation of organic control regu-
lations will achieve, only "total" organic compound emission data not
stratified by reactivity are needed. (NOTE: In some cases, however,
1t may not be possible to determine the composition of the organic
compounds emitted. Where it 1s possible to do so, those emissions
attributable to methane may be excluded from the Inventory.)
QUESTION - What sources and source information should be 1n an
organic compound emission Inventory?
ANSWER - Table 1 is a partial list of major stationary sources that gen-
erally emit significant amounts of organic compounds. Each of the
point sources within these sources categories should be Identified and
III-E-2
JAN 1977
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Included 1n an organic compound emission Inventory. As may be seen,
many Industries may emit organlcs from some portion of their process.
In addition to the Information that 1s generally obtained during
routine emission data collection activities, the following Information
should be collected:
(1) Specific organlcs or class of organlcs emitted and the amount
of such organics emitted - This information may be necessary when
determining the applicability of control regulations.
(2) Emission variability - Due to the nature of many organic
emissions (evaporative loss), the organic usage and emissions may vary
P by season, whereas the process may not. Additionally, some sources may
have a greater operating rate during the March to October period and
therefore have a greater impact on ozone/oxidant levels than a source
fl of the same size which operates at a constant level all year.
(3) Process equipment - In some cases for solvent usage, the oper-
£ ating conditions of the process can be adjusted to reduce emissions.
A recommendation to the source to operate equipment at a lower temper-
ature or to place Hds on vats of solvents may reduce the solvent usage
and thereby decrease emissions of organic compounds.
Mobile sources also account for a large percentage of the organic
jj compounds emitted to the atmosphere and must be inventoried. The
Inventory should include emission estimates by
(a) Light Duty Vehicles (LDV)
(b) Light Duty Trucks (LOT)
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TABLE 1
Major Sources of Volatile Organlcs From
Industrial Categories
Petroleum Ref1 irlng. Pistri button and Marketl ng
Miscellaneous point sources - refineries
Vacuum distillation
Process gas combustion
Crude, gasoline, AvGas, distillate, naphtha, etc.
Chemical Manufacture
Ammonia
Carbon black
Charcoal
Paint, varnish and printing ink
Pharmaceuticals
Synthetic resins, fibers and plastics
Organic chemical manufacture
Combustion
Boilers (coal, oil and gas)
Stationary engines
Solvent Evaporation
Degreasing
Drycleanlng
Graphic arts
Metal coating
Auto assembly
Can manufacturing
Coll coating
Appliances
Machinery
Commercial products
Furniture
Textile coating and finishing
Paper and film coating
Wood finishing
Tire manufacturing
Other Industrlal Sources
Wood processing
Metallurgical processes
Mineral processes
Food processing
III-E-4
,-AN 1977
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(c) Heavy Duty Gas Vehicles (HDGV)
(d) Heavy Duty Diesel Vehicles (HDDV)
(e) Aircraft
(f) Motorcycles and others
Specific procedures for compiling emission Inventories are contained
within Guidelines for Compiling a Comprehensive Emission Inventory,
APTD 1135. In addition, emission factors and specifications of the type
of information needed to calculate emissions from various sources 1s con-
talned within Compilation of A1r Pollution Emission Factors, EPA AP-42.
ADDITIONAL INFORMATION - (1) Guideline for Compiling a Comprehensive
Emission Inventory - APTD 1135. (2) Compilation of Air Pollution
Emission Factors. EPA, AP-42 with supplements. (3) Source Assessments;
Pr1or1t1zat1on of A1r Pollution from Industrial Surface Coating Operations;
EPA 650/2-75-019a, Feb. 1975. (4) Methodology for Inventorying
Hydrocarbons. EPA 600/4-76-013, March 1976.
| QUESTION - Are emission factors available for natural sources of
hydrocarbon?
ANSWER - EPA is currently undertaking studies to expand our knowledge
of emission rates for various types of natural sources. It 1s anti-
cipated that the present study Involving vegetation will be complete
Q 1n early 1977. Some of the natural sources of organic compounds
which may be included 1n the future are biological action, coal fields,
natural gas and petroleum fields and natural fires. Until the
emission studies are completed, no techniques exist to estimate natural
emissions. However, as pointed out on pages III-B-7 to III-B-8, 1t
I is believed that the impact of natural sources of organic compounds
will not be significant 1n relation to peak urban levels of photo-
I chemical oxldant.
JAN 1977
m in-E-5
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ADDITIONAL INFORMATION - (1) AP-42 - Compilation of A1r Pollutant
Emission Factors. (2) A1r Quality Criteria for Hydrocarbons. AP-64.
QUESTION - What Information is required 1n order to calculate vehicular
emissions of organic compounds?
ANSWER - In order to calculate organic compound emissions for mobile
sources5 it is necessary to know the emission rate by vehicle category
(e.g., light-duty vehicles, light-duty trucks, heavy-duty vehicles, etc.,
and vehicle year) and to know the number of miles travelled by each
vehicle category by vehicle year.
With respect to vehicle emission rates, EPA has determined emission
rates by vehicle category and by vehicle year. The results are published
in Compilation of Air Pollutant^Emission Factors, AP-42. Emissions vary
by model year because of (a) emission control devices, (b) deterioration
of such devices, and (c) varying engine characteristics. Also because
emission control systems deteriorate with time, the emission factor for
a 1974 car will be different in 1975 than 1n 1974. Therefore, to
accurately calculate mobile source emissions, it is necessary to know
the number of miles traveled by each model year of vehicle in the specific
calendar year for which emissions are to be determined.
Information on vehicle usage within a given area can be usually
obtained from local or State planning agencies, or agencies dealing with
motor vehicles. To the extent possible, the following Information
should be obtained from such agencies for the study area in question.
III-E-6
JAN 1977
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(a) VMT by vehicle category
(b) Age distribution of vehicles by vehicle category
(c) Anticipated growth 1n VMT by vehicle category
J If such data are not available, use of national averages which
are contained with AP-42 can be used.
* The specific procedure for calculating emissions may be found
in AP-42.
ADDITIONAL INFORMATION - Air Pollutant Emission Factors, EPA AP-42,
Third Printing, February 1976. (A new supplement will be available
shortly), Stralow, R., to Regional Administrators, memorandum,
m "Guidance for Determining Acceptability of SIP Regulations in Non-
Attainment Araas," December 9, 1976.
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* III-F
- CHEMISTRY OF PHOTOCHEMICAL OXIDANT -
QUESTION - What is the difference between oxldant and ozone?
B ANSWER - Oxidant 1s not a specific compound but 1s a broad group of
_ diverse compounds with the predominant constituent, ozone (O,), as
I
an Indicator of their presence. Oxldant is generally not emitted
directly from sources but 1s formed in the atmosphere as a
product of various reactions of its precursors (I.e., organlcs and
oxides of nitrogen). As presently used by the Agency, the term
applies to those compounds produced by the interaction of N0«, organlcs
and oxygen 1n the presence of ultraviolet radiation. Two basic com-
ponents of photochemical oxldant are (1) ozone - 03 and (2) peroxyacetyl-
nitrate - (PAN) - CH3 CONOg. Laboratory studies have shown that
I aldehydes such as (1) formaldehyde - HgCO, (2) acetaldehyde - CHjHCO,
and (3) other organic compounds may also be formed along with oxidant.
I Attempts have been made to quantify the relationship between total
g oxidant and ozone. This has generally been done through the use of dual
monitors at the same location, one specifically for ozone and the other
V which measures all constituents of photochemical oxidant (generally through
the use of potassium iodide (KI)). These measurements theoretically
| should provide the concentration of oxidation products other than ozone.
_ Some of these attempts to determine the percent of ozone in total oxldant
* has resulted in the measurement of ozone concentrations greater than
total oxldant concentrations. This in part has resulted from the dif-
ficulty 1n making an accurate measurement of total oxldant and negative
I
III-F-1
.IA.N 197?
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interferences of other substances; there may also be other, unknown
reasons. Most of this work has been done 1n Los Angeles, California, and
it was found that the percent of ozone to total oxidant varies with
meteorology and season; however, no explanation for this variation has
been found. It was generally found that ozone constitutes approximately
90% of total oxidant, although ozone fractions as low as 75% have been
found. It is conceivable that the ozone fraction will also vary by
concentration level and types of hydrocarbons emitted.
ADDITIONAL INFORMATION - Control of Photochemical Oxidants - Technical
Basis and Implications of Recent Findings. July 15, 1975, EPA 450/2-75-005.
QUESTION - When and how rapidly is 03 formed?
ANSWER - Due to the dependence upon sunlight, the photochemical formation
of ozone does not begin until sunrise. Due to the fast reaction with NO,
ozone buildup does not occur until almost all NO is depleted. Peak con-
centrations of ozone are usually reached approximately 2 to 3 hours
after the NOp has reached its peak. High concentrations of ozone persist
until the afternoon when reduced ultraviolet radiation decreases the
reaction rate of the photochemical cycle and increases in automotive
traffic increase the urban concentration of NO. High ozone concentrations
have been observed at night and this is generally ascribed to transport of
ozone aloft from one area to another. Atmospheric stratification (ground
III-F-2
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level Inversions) which frequently occurs at night may effectively
fl shield ozone from newly emitted NO. The ozone thus trapped will not be
depleted due to the scarcity of those compounds which normally reduce
I ozone. As the air parcel with the trapped ozone passes over the urban
£ area the Inversion may be broken by the topography of the urban area or
* by the fact that the ground level air 1s generally warmer than the upper
j level air, producing vertical mixing. An earlier rise 1n oxldant levels
may also occur as the ground level Inversion 1s destroyed by solar heating,
g allowing ozone aloft to become mixed with ground level emissions resulting
_ 1n an earlier rise in ozone levels.
ADDITIONAL INFORMATION - (1) Control of Photochemical Oxldants - Technical
Basis ana Implications of Recent Findings.
QUESTION - How 1s oxldant formed/depleted?
g ANSWER - There are presently over 300 reaction steps postulated 1n the
formation of photochemical oxldant. There are, however, a few basis
steps which generally describe the formation mechanism (Figure 1).
The constituents of oxldant are secondary pollutants that form 1n the
atmosphere. Elements which must be present for oxldant formation are
NO, organics, oxygen, and ultra-violet light (sunlight). Although
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JAN 1977
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oxidant may be present at almost any time of the year, oxidant in
excess of the standard is generally found during spring and through
late summer. Simplistically, nitric oxide (NO) reacts with either ozone
(O,) or oxygenated organic radicals (RO) to form nitrogen dioxide (NO^)
(Reactions 1 and 4). The NOp then photodissociates (Reaction 2) with
the free oxygen combining with oxygen molecules (CL) to form 0, (Reaction 3)
See Figure 2 for a schematic of the formation cycle.
(1) NO + 03 -> N02 + 02
(2) N02 +v NO + 0
(3) 0 + 02 + 03
(4) R01+ NO * N02 + RO
As already shown (Reaction 1), ozone may also be depleted. Some of the
depletion steps (Reactions 5 and 6) may result in compounds which generally
do not participate further in the photochemical cycle.
(5) 2 N02 + 03 -» N205 + 02
(6)
03 + HC + RC03
RCOj + N02 -» PAN
PHOTOCHEMICAL
BY-PRODUCTS
NITRIC
OXIDES
EMISSIONS
ORGANIC
COMPOUNDS
FREE
RADICALS
Figure 2 j
Photochemical production of oxidants.
HI 774
N 1977
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ADDITIONAL INFORMATION - Control of Photochemical Oxldants - Technical
Basis and Implications of Recent Findings.
QUESTION - What is the interrelationship between organlcs and NO in
oxidant formation?
ANSWER - Organlcs and NO are the two major constituents 1n oxidant
/\
formation. The exact relationship and effects that increase or decrease
ambient levels of either pollutant 1s currently under Investigation
within the Agency. However, it 1s known that NO emissions may depress
ozone around an NO source (i.e., excess NO to available organics would
tend to deplete Og), increased levels of ozone may be observed downwind
from an NO source, because the subsequent conversion of NO to N02
provides a needed precursor to initiate the reaction necessary to pro-
duce oxidant.
Notwithstanding the above, evaluation of smog chamber studies
Indicates that for most broad metropolitan areas control of NO emissions
A
to minimize ambient oxidant levels would be much less effective than
the control of organic compounds. It is believed that the ratio of
ambient non-methane organlcs (NMOC) to NOV (i.e., NMOC/NOV ratio) in
A X
urban areas is such that reduction in ambient concentrations of Ox
are best achieved by control of organic compound emission sources
rather than NO sources. The relationship 1s complex and preliminary,
and further work on the subject is continuing.
III-F-5
JAN 1977
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ADDITIONAL INFORMATION - (1) Control of Photochemical Oxldants - Technical
Basis and ImpVIcations of Recent findings/. (2) Oxldant Control Strategies,
Part I. An Urban Oxldant Control Strategy Derived from Existing Smog
Chamber Data. Dr. B! Dlmitriadas, 1976 - Submitted for publication.
(3) Co:*isied Use of Modeling Techniques and Smog Chamger Data to Derive
Ozone-Precursor Relationships, Dr. M.C. Dodge; (4) An Alternative to
the Appendix J^Method for Calculating Oxldant - and NOp - Related Control
Requirements, Dr. S. Dlnritn'ades. NOTE: References (3) and (4) were
presented at the International Conference on Photochemical Oxldant Pol-
lution and Its Control, Raleigh, N.C., 1976.
QUESTION - What are the Meteorological Factors Affecting Oxldant Levels?
ANSWER - Recant studies have revealed various meteorological factors
conducive to the occurrence of high oxidant concentrations. These Include
moderate to strong solar ultraviolet radiation, maximum dally temperatures
generally above 60° F, low surface winds (£8 mph), lack of a surface'-
based radlational Inversion but vertical mixing limited by a subsidence
inversion aloft, and existence of a slow moving high pressure air mass
system with highest concentrations developing toward the center and back
sections of such a system. High oxidant concentrations are a complex
function of precursor emissions initially generated in an area or region
and some combination of the above meteorological conditions.
Recent evidence suggests that relatively high concentrations may
occur simultaneouly over rather large geographic regions. However, the
highest levels are observed 1n the vicinity of urban areas usually 15 to
30 kilometers downwind of the central business district. Therefore,
III-F-6
JAN 1977
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relative to an urban area the prevailing wind direction 1s also of
Importance. The Incremental contribution to oxldant concentrations
of precursor emissions 1n individual urban area will depend on factors
such as urban area size, emission densities, the resulting atmospheric
pollutant mix, and proximity to upstream urban areas with sizable pre-
| cursor emissions.
ADDITIONAL INFORMATION - Formation and Transport of Oxldants Along
* Gulf Coast and in Northern U.S., EPA 450/3-76-033, August 1976.
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* SECTION IV
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Inspection/Maintenance Operation Experience
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Location: Cincinnati and Hamilton County, Ohio
Type of Program: Municipally operated permanent facilities, idle mode,
, mandatory inspection and maintenance.
Sites: Cincin.na.ti - 1 site, 4 lanes, includes safety inspection
' Norwood - 1 site, 1 lane, includes safety inspection
Hamilton County - 2 sites (NewLown and Glenway), 3 lanes total,
no safety inspection.
Chronology: Fully .mandatory I/M began in Cincinnati and Norwood on
Jan. |, 1975, with no voluntary phase-in periods. Newtown
began operation 8/75 and Glenway 9/75. Operations ceased
at Newtown and Glenway, Feb. 1, 1976.
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Geographic Coverage: Eventually the'whole of Hamilton County, about
600,000 LDV's.
Administering Agency: Individual local governments
Capital Cost: (Cincinnati) $12,600 for 9 analyzers inspection facilities
already in operation for safety.
Operating Cost: (Cincinnati) $130,000 for 11 additional positions.
Cost to Motorist: $3.75, including safety.
Standards: Same as Chicago, four-stage standards dependent on model
year projected 30 percent rejection.
Enforcement: (Cincinnati) Vehicle cannot be registered by City (sticker
issued) unless inspection is .passed. City Division of
Air Pollution Control has four vehicles issuing tickets
on a limited basis.
. (Hamilton County) No enforcement program.
Instrumentation: Sun # 910 I analyzers modified with color-coded scales
and pass/fail lights. Cincinnati has 9 of these, Norwood
2, and Hamilton County 4.
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Data Collection: Volumes passing and failing only. By November '75,
Cincinnati vehicles .were failing at 17 percent and
Norwood at 28 percent, both down considerably from
program inception.
Mechanic Training: None at present, but need exists. Region V is planning
courses and CSU has been contacted. City has responded
favorably to letter by Region concerning program.
Waiting Times: No major problems
Achievements: Demonstrated short lead time adding I/M to existing safety
program.
JAN 1977
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Location: Chicago
Type of Program: City-operated mobile vans, idle mode. Mandatory
inspection with no enforcement = voluntary inspection.
- - Voluntary maintenance.
Sites: 9 sites, 18 lanes
Chronology: Began inspection in June 1973. EPA Region V issued enforce-
ment (s 113) order to City to meet inspection rate of 3000
vehicles/day by December 1975. If failing to comply,
mandatory inspection and maintenance of all Chicago and *
Cook County vehicles entering Loop was to commence March 1976.
Geographic Coverage: City of Chicago only (1.0 million LDV's), but any
vehicle coming in will be inspected. Remainder of
Cook County is far behind in implementation.
Administering Agency : City of Chicago, Department of Environmental Control
Capital Cost:
Operating Cost: $1.65 million per year (estimated)
Cost to Motorist: Inspection fee collected as part of annual registration
fee, which was raised $5 at the time of I/M inception.
Cost of testing is about $2.25 per vehicle.
Standards: CO and'HC standards for four model-year groups - estimated 30
percent rejection.
Enforcement: None
Instrumentation: 18 Sun # 910 I analyzers, modified to include C02
testing and computer control. 11 backups w/o C02
modification.
Data Collection: Record kept on rejected vehicles, esp. model year 1975's,
which are failing at above 20 percent. Study done in
conjunction with EPA's Emission Factor Program showed
75's failing at 25 percent (on Chicago test).
Mechanic Training: Definite need, but none to date.
Waiting Times: No problems
JAN 1977
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-Location: Portland, Oregon
Type of .Program: Combination of permanent and mobile facilities, idle
.mode, mandatory inspection and maintenance. Inspection
is biennial at present.
Sites: 5 permanent sites, 10 lanes; 4 mobile vans, 5 lanes
9 sites, 15 lanes total. Plans call for expansion to 17 lanes.
Chronology: Voluntary inspection and maintenance commenced 1/74. In 18
months, 105,000 vehicles were tested. No transitional
mandatory/voluntary phase. Fully mandatory I/M.began 7/1/75.
Geographic Coverage: Portland Metropolitan Service District -- urbanized
portions of Washington, Multnomah, and Clackamas
Counties (580,000 LDV's total).
Administering Agency: Oregon Department of Environmental Quality (DEQ)
Capital Costs: Total cost of analyzers (29) was about $200,000.
Only one station was actually built for the program,
construction costing $77,000. Located on State right-of-
way, land costs are not included. This station has loaded-
mode and safety testing capabilities. The four remaining
permanent facilities are leased. A complete mobile van
setup, including new vehicle, 3 analyzers, and secondary
equipment, costs $40,000.
Operating Cost: Approx. $1.6 million for "on" year, $1.0 million for
"off" year.
Cost to Motorist: $5 for issuance of Certificate of Compliance. Unlimited
retests.
Standards/failure Rate: Multiple standards, based on manufacturer's specs,
involving model year groups, manufacturer groups,
and engine-modifications. Testing involves pre-
conditioning to offset hot idle effect. Vehicles
can also be rejected for exhaust dilution, visible
smoke, and excessive idle speed. Total failure
rate is about 35 percent.
Enforcement: Vehicles cannot be registered without Certificate of Compliance
JAN 1977
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Instrumentation:
Data Collection:
Mechanic Training:
2.
29 Sun "OEA 75" analyzers with digital readout of HC,
CO, and C02, and with remote viewing guages. Systems
are fully computer compatible, but are not computer
controlled at this time. For supplementary data
generation, 2 Clayton and 2 Autoscan dynomometers are
used. Oregon State University has CVS testing capabil-
ities.
Actual rejection rate, Dec. '75, was 32%. Refailure rate
of 16%. Record kept of all emission readings. Readings
are taken at idle speed, 2500 rpm (intended mainly as
pre-conditioning), and then again at idle, with the
lower of the idle readings governing. Supplementary
loaded testing is also performed occasionally, with
testing at 30 and 50 r.ph under loads proportional to
vehicle weight.
Emission-related tune-up course at Clackamas Community
College, in response to Oregon I/M. EPA Region X
Assisted with funding through DEQ. 75-80 enrollees.
Waiting Times:
Achievements:
With 1976 as an "on" year, a "reasonable maximum" (at the
Powell St. Station) is one hour. To combat long waits,
DLQ .k.eeps inspection lanes open on seven-day basis and
licenses private fleets (more than 100 vehicles) to
inspect themselves. During the "off" year of 1975, no
waiting problems existed.
Total inspection time averages 3 minutes.
Downward trends in ambient CO have been noted, but
contribution of I/M is not known.
Many garages are buying analyzers.
Of all I/M programs, has the most extensive, and therefore
the most equitable standards. Difficulties in identifying
vehicles and their standards have been minimal.
JAN 1977
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Location: Riverside
Type of Program:
State-operated permanent facilities, loaded mode
(hi-cruise, lo-cruise, idle). Mandatory inspection
with voluntary maintenance at present.
Sites: 2 sites, 6 lanes. Second station opened Feb. 19, 1976.
Chronology: Phase I (pilot program) - began inspections 9-2-75.
Assuming success of Phase I, Phase II begins 9-76 and
Phase III late in 1977. Under Phase II, program expands
to 25 sites with fully mandatory I/H for those vehicles
requiring registration changes (approx. 1.7 million
vehicles). Phase III, with 80 to 85 stations of 2 and
4 lanes (290 total), requires fully mandatory I/M for
all registered vehicles.on a yearly basis. "
Geographic Coverage:
Administering Agency:
Presently, City of Riverside only (120,000 LDV's).
Phases II and III will expand program to the
remainder of the South Coast Air Basin (approx.
6.6 million vehicles), including the whole or
parts of Riverside, San Bernardino, Los Angeles,
Orange, Ventura, and Santa Barbara Counties.
California Bureau of Automotive Repair - administra-
tion. California Air Resources Board - operations.
Capital Cost: $250,000 for 6 lanes of equipment (analyzers, dynos,
computer control). Land and building of currently
operating station are leased on a monthly basis.
Cost to Motorist:
Free at present. Phases II and III, $5.00 (estimated),
Waiver System - Maximum mandatory repair cost is $150
or 20 percent of the vehicle's value, whichever is
smaller. This limit is provided to the vehicle owner
via the computer-printout he receives.
Standards/Failure Rate:
Matrix of standards for three model year groups,
two engine size groups, and the presence or
absence of air injection. Projected rejection
under these standards is 25 percent. Standards
will be updated as required.
Vehicles may also be rejected for obvious safety
deficiencies (bald tires, etc.) that may cause
testing to be unsafe. Vehicles 1955 and older
are exempt from program.
JAN 1977
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Enforcement:
Phase I - not applicable.
Phase II ,- changes in registration (buying, moving into
State, etc.) cannot be made without passing
inspection.
Phase III - annual renewal of registration and changes in
registration cannot be made without passing
inspection.
Instrumentation:
Data Collection:
For Phase I, most analysis equipment, including
dynomometers, was manufactured by Autoscan. System
uses computer data processing.
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Odometer readings and vehicle age along with tailpipe
concentrations of CO, HC, and NOx, Computer hookup
(to tailpipe and engine) permits instant diagnosis,
with three-mode analysis of emission readings. Vehicle
owner is provided with printout, indicating probable
cause of malfunction and recommended service action.
After one month's operation, vehicles were being rejected
at about 30 percent.
Accompanying Phase I is a surveillance program involving
650 vehicles. Anticipated results of this effort
include program effectiveness (utilizing the 1975 FTP),
cost effectiveness, and "technical effectiveness"
(vehicle thruput, waiting times, etc.). Final report
should be available by mid-March 1976.
Mechanic Training: California has a program of mechanic licensing.
Under Phase I, a "certificate of qualification" is
required of mechanics to perform repairs resulting
from the I/M program. These mechanics must attend an
orientation seminar and either:
(a) possess a California "Class A" mechanic's license
. (b) pass a written examination
Waiting Time:
Achievements:
No problems. Demand-is kept uniform by mailing out notices
to 450 to 500 vehicle owners daily (chosen at random by
computer). The owner then has two weeks from date of
postmark to bring in his vehicle.
Total inspection time is about seven minutes.
Public reaction has been excellent. Unique combination
of exhaust analysis, engine monitoring, and computer
technology. Diagnosis helps insure satisfied consumer.
JAN 1977
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REFERENCES
JAN 1977
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8. D1m1tr1ades, Dr. B. "An Alternative to the Appendix J Method for
Calculating Oxldant - And NO, - Related Control Requirements, pre-
sented at the International Conference on Photochemical Oxldant
fl 1 1 .A. Jt . _.. J ^ ,L_ S*AU..i.u.^^ n.l.J L. hi f* ^ -. M.A. 1 ft IT 1 A If
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1. Angus, R.M. and Martinez, R.M., "Rural Oxldant and Oxldant Trans-
port," presented at the Conference on State-of-the-Art of Assessing
Transportation Related A1r Quality Impacts, Washington, D.C.,
October 22-24, 1975.
2. "Air Quality Criteria Document for Hydrocarbons," U.S. Environmental
Protection Agency, AP-64, March 1970.
3. "A1r Quality Monitoring Network Design and Instrument Siting," U.S.
Environmental Protection Agency, OAQPS Guideline 1.2-012, January
1974.
4. Clements, Dr. J.B., Memorandum, "Clarification of Reference Method
for Photochemical Oxldant," April 14, 1975.
5. "Compilation of Air Pollution Emission Factors," U.S. Environmental
Protection Agency-, AP-42, February 1976.
6. "Control of Photochemical Oxldants - Technical Basis and Impli-
cations of Recent Findings," U.S. Environmental Protection Agency,
EPA 450/2-75-005. July 1975.
7. "Designation of Unacceptable Analytical Methods of Measurement for
Criteria Pollutants," U.S. Environmental Protection Agency, OAQPS
Guideline 1,2-018, September 1974.
Pollution and its Control, Raleigh, N.C., Sept. 12-17, 1976.
9. Dimitriades, Dr. B., "Oxldant Control Strategies, Part I., An
Urban Oxldant Control Strategy Derived from Existing Smog Chamber
Data," 1976 (Submitted for Publication).
10. Dodge-, M.C., "Combined Use of Modeling Techniques and Smog Chamber
Data to Derive Ozone-Precursor Relationships," presented at the
International Conference on Photochemical Oxldant Pollution and its
Control, Raleigh, N.C., Sept, 12-17, 1976.
11. "Environmental Health Criteria for Photochemical Oxldants," World
Health Organization, Draft Report, EHE/EHC/WP/75.5, March 20, 1976.
12. "Formation and Transport of Oxidants Along Gulf Coast and Northern
U.S.," U.S. Environmental Protection Agency, EPA 450/3-76-003,
August 1976.
13. "Guideline for Compiling a Comprehensive Emission Inventory," U.S.
Environmental Protection Agency APTD 1135. March 1973.
JAN 1977
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14. "Guidelines for the Evaluation of Air Quality Data," U.S. Environ-
mental Protection Agency, OAQPS Guideline 1.2-015. February 1974.
15. "Guidelines for the Interpretation of Air Quality Standards," U.S.
Environmental Protection Agency, OAQPS Guideline 1.2-008, August 1974.
16. "Methodology for Inventorying Hydrocarbons," U.S. Environmental Pro-
tection Agency, EPA 600/4-76-013, March 1976.
17. Meyer, E.L. s et a!., "The Use of Trajectory Analysis for Determining
Empirical Relationships Among Ambient Ozone Levels and Meteorological
and Emission Variables," presented at the International Conference
on Photochemical Oxidant Pollution and its Control, Raleigh, N.C.,
Sept. 12-17, 1976.
18. "National Academy of Science Report to Congress," September 1974,
Serial 93-24, Volume 2 - Health Effects of Air Pollutants.
19. "Policies for the Inclusion of Carbon Monoxide and Oxidant Control
in State Implementation Plans", U.S. Environmental Protection Agency,
Office of Transportation and Land Use Planning, January 9, 1976.
20. "Quality Assurance Handbook for Air Pollution Measurement Systems,
Volume 1 - Principles," U.S. Environmental Protection Agency
EPA 600/9^76-005, Jaunary 1976.
21. "Review of Control Strategies for In-Use Vehicles," U.S. Environmental
Protection Agency, EPA 460/13-74-021, Dec. 1974.
22. "Source Assessments: Prioritization of Air Pollution from Industrial
Surface Coating Operations," U.S. Environmental Protection Agency,
EPA 650/2-75-019a, February 1975.
23. Strelow, R./Stan Legro to all Regional Administrators, Memorandum,
"Agency Policy Regarding Calling for Plan Revisions to Approved
State Implementation Plans that are Substantially Inadequate to
Attain National Standards," November 12, 1975.
24. Strelow, R., to Regional Administrators, Memorandum* "Errors in
Ozone/Oxidant Monitoring System," December 18, 1975.
25. Strelow, R., to Regional Administrators, Memorandum, "Guidance for
Determining Acceptability of SIP Regulations in Non-Attainment Areas,"
December 9, 1976.
26. "The Health Implications of Photochemical Oxidant Air Pollution to
Your Community," U.S. Environmental Protection Agency, EPA 450/2-76-015,
August 1976.
27. "Transportation Controls to Reduce Automotive Use and Improve Air
Quality in Cities," U.S. Environmental Protection Agency,
EPA 400/11-74-002, Nov. 1974.
JAN 1977
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