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TABLE OF CONTENTS
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VOLUME XV
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_ Control Strategy Preparation Manual for Participate Matter. CPDD. 9/77.
OAQPS No. 1.2-049.
I Requirements and Procedures for Implementing Section lll(D). CPDD. 3/77.
OAQPS No. 1.2-072.
I Control of Volatile Organic Emissions From Existing Stationary Sources -
* Volume II: Surface Coating of Cans, Coils, Paper, Fabrics, Automobiles,
and Light-Duty Trucks. ESED. 5/77. OAQPS No. 1.2-073.
Guidance for the Future Use of NASN. MDAD. 6/77. OAQPS No. 1.2-075.
Regulatory and Technical Control Strategies for Fine Particles. SASD.
~ 6/77. OAQPS No. 1.2-076.
Guideline for Implementation of the Standardized SIP Filing System. CPDD.
| 7/77. OAQPS No. 1.2-077.
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EPA-450/2-77-023
September 1977
(OAQPS No. 1.2-049)
CONTROL STRATEGY
PREPARATION MANUAL
FOR PARTICIPATE MATTER
GUIDELINE SERIES
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Air and Waste Management
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
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EPA-450/2-77-023
(OAOPS NO. 1.2-049)
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I CONTROL STRATEGY PREPARATION
| MANUAL FOR PARTICIPATE MATTER
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Standards Implementation Branch
_ Control Programs Development Division
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U.S. ENVIRONMENTAL PROTECTION AGENCY
I Office of Air and Waste Management
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
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September 1977
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OAQPS GUIDELINE SERIES
The guideline series of reports is being issued by the Office of Air Quality
Planning and Standards (OAQPS) to provide information to state and local
air pollution control agencies; for example, to provide guidance on the
acquisition and processing of air quality data and on the planning and
analysis requisite for the maintenance of air quality. Reports published in
this series will be available - as supplies permit - from the Library Services
Office (MD-35), Research Triangle Park, North Carolina 27711; or, for a
nominal fee, from the National Technical Information Service, 5285 Port
Royal Road, Springfield, Virginia 22161.
Publication No. EPA-450/2-77-023
(OAQPS No. 1.2-049)
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PREFACE
The Clean A1r Act, as amended through 1977, provides that a State
Implementation Plan (SIP) which demonstrates attainment and maintenance
of national ambient air quality standards (NAAQS) in each air quality
control region (AQCR) must be developed by each State. Since the years
of initial development, a continuous refinement of our knowledge and
understanding of air quality problems has occurred. New knowledge has
led to exploration of sources of pollution, such as "fugitive dust" from
construction activity, unpaved roads, etc., and "fugitive emissions" from
industrial activity, which were not generally considered in the original
development of SIPs. Other activities have pointed to the need for more
comprehensive and long-term planning for maintenance of air quality
standards in order to accommodate the growth of new sources of pollution.
As a result, it is clear that a SIP must be flexible and dynamic if it
is to perform adequately the function prescribed for it by the Clean
Air Act. The control strategies which comprise a SIP must be designed
accordingly.
This manual has been prepared to assist EPA, State and local agencies
in the task of developing control strategies for particulate matter (PM).
The manual includes a general discussion of the technical aspects of
control strategy development under 40 CFR 51; it does not detail the
specific requirements of SIP development as described in 40 CFR 51
Subpart D - "Maintenance of National Ambient Air Quality Standards
Summary."
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Many control strategies will be revised as a result of the deter-
minations of SIP adequacy performed by the Agency during 1976 and
required by the Clean Air Act amendments of 1977. The manual is
intended to address the need for guidance in the accomplishment
of this task. The emphasis in the manual is on a brief discussion
of pertinent facts supplemented by references to generally available
technical documents.
The policies referred to in this manual were developed before the
recent passage of the Clean Air Act amendments of 1977. Due to the
large scope of these amendments, it is difficult to predict how policies
concerning the control of particulate matter emissions will change.
Incorporated in this manual are the specific non-policy changes, such
as changes in the SIP revision submission dates. As new policies
develop under the implementation of these amendments, this manual will
be revised to reflect these changes.
The manual is separated into ten sections. Section I provides
an overview of the various factors to be considered in the development
of an approvable control strategy for particulate matter (PM). Section
II sets forth a step-by-step procedure that a control strategy developer
should follow in preparing an approvable control strategy. Sections
III - VIII provide, in question-and-answer format, a more detailed
explanation of the recommended procedures outlined in Section II. Section
IX 1s a glossary of terms used throughout the manual. Section X is
the bibliography of memoranda, technical papers, etc., referred to in
the manual.
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1
ITo facilitate distribution of future updates to this manual and
to maintain a record of those persons using the manual it is requested
that the card below be filled out and mailed to:
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Plans Guidelines Section
Control Programs Development Division
U.S. Environmental Protection Agency (MD 15)
Research Triangle Park, MC 27711.
_ If additional copies are necessary please note
space.
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Please send future updates of the Control Strategy
_ Manual for Parti cul ate Matter to:
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NAME :
I ADDRESS:
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in the appropriate
8/77
Preparation
In addition please send additional copies of the Control Strategy
Preparation Manual for Partlculate Matter.
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ACKNOWLEDGEMENTS
Initial drafts of this manual were prepared by Neil Eflrd under
the direction of Edward LUlis, formerly Chief of the Analysis and
Reports Section, Standards Implementation Branch. Comments were Incor-
porated and revisions made as appropriate by Ted Creekmore and Bruce
Polkowsky under the direction of Joseph Sableski , Chief of the Plans
Guidelines Section, SIB.
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TABLE OF CONTENTS
Page
Preface 111
List of Figure Titles ix
List of Table Titles x
Section I: Overview of Factors Affecting Attainment of National
Standards for Particulate Matter (PM) 1-1
Section II: Procedures for the Review and Development of a
Control Strategy for PM II-l
Section III: Questions Concerning Sources and Types of Particulate
Emissions III-l
- What 1s the typical composition of urban PM? III-l
- What are the major sources of PM in the nation? III-5
- What are the major categories of man-made particulate matter
emissions (I.e., traditional sources) in the nation? III-6
- What are "secondary particulates"? III-7
- What is the difference between fugitive dust and fugitive
emissions? III-8
- What are the most significant man-made fugitive dust sources? . 111-11
- What emission factors are available for fugitive dust sources,
and what work is underway to develop additional factors? . . . III-ll
- What silt content should be used in calculating the emissions
from unpaved roads? 111-13
- Which existing stationary sources of PM are required to con-
tinuously monitor opacity? III-14
- Which new stationary sources of PM are required to monitor
opacity? 111-15
Section IV: Questions Concerning Air Quality Standards and
Measurement IV-1
- What are the National Ambient Air Quality Standards for PM? . . IV-1
- Are the current standards for PM being reviewed? IV-1
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- When would the secondary annual standard of 60 jjg/m , annual
geometric, mean be used as a guide to determine attainment of
the 24 hr. standard of 150 jug/m^ not to be exceeded more than
once per year? IV-2
- Is there any consideration being given to the promulgation of
a national standard that considers particle size or chemical
composition? IV-3
- What ambient measurement techniques are acceptable for moni-
toring PM? IV-4
- What is meant by the term "background concentration" and what
are the typical values taken to represent "background"? .... IV-4
- What is the impact of traditional (stationary) sources on air
quality? IV-7
- What is the impact of the most significant man-made fugitive
dust sources on air quality? IV-9
- What is the impact of mobile sources on air quality? IV-11
- How much ambient PM data are needed to indicate that a SIP
needs to be revised; or to serve as the basis of a control
strategy? IV-12
- Historically, what type of air quality trends have been observed
for PM? IV-12
- What guidance is available with regard to locating and operating
PM monitors in the field to provide representative samples? . . IV-14
- What is EPA policy on the use of correction factors for adjust-
ing TSP H1-vol readings to allow for accumulation of particu-
late matter during the static mode? IV-15
Section V: Questions Concerning Data and Funds Utilization . . . . V-l
- To what extent does growth information employed in plan develop-
ment have to be internally consistent? V-l
- How could one utilize 208 Planning funds for developing air
quality projections and subsequent plan development? V-4
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Section VI: Questions Concerning Modeling VI-1
- What mathematical diffusion models are recommended for esti-
mating ambient concentrations of PM? VI-1
- What assistance is available for using the models in Volume 12
and the Guideline Air Quality Models? VI-5
- What techniques are available for fugitive dust modeling? . . . VI-6
- What techniques are available for fugitive emissions modeling? VI-9
Section VII: Questions Concerning Control Technology VII-1
- What 1s "Reasonably Available Control Technology" for stationary
sources, and how 1s it determined for an individual source? . . VII-1
- What guidance is available or is being prepared to assist in
determining reasonably available control technology for specific
sources? VI1-2
- How significant are emissions from oil-burning facilities and
how can emissions from such sources be minimized? VI1-4
- Must any particular emission measurement test method be pre-
scribed as the test method for determining compliance with
adopted State emission limitations for PM? VI1-6
- What potential control measures have been identified for con-
struction sources? VI1-7
- What control measures are available to minimize fugitive dust
from unpaved roads? VI1-8
Section VIII: Questions Concerning the Control Strategy, its
Development, and its Revision VII1-1
- What consideration should be given to control automotive parti-
culate emissions 1n the control strategy? VIII-1
- What potential control measures have been identified for
reentrained particulates? VIII-3
- What Intergovernmental coordination and review are generally
necessary in the development of SIP control strategies? .... VIII-4
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- How should secondary particulate matter be considered in a PM
control strategy? VIII-7
- How should fugitive dust sources be considered in the control
strategy? VI11-10
- How should ambient data collected during dust storms and other
unusual events be considered in a control strategy? VI11-13
- How does the EPA new source review emission offset policy
affect SIP revisions? VI11-13
- How should the impact of stationary source fuel switches required
by ESECA be considered in strategy development? VIII-15
- What is the effect of malfunctions or breakdowns of control
equipment on ambient air quality and what is the present policy
in handling such periods in a control strategy? VIII-16
Section IX: Glossary IX-1
Section X: Bibliography X-l
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_ LIST OF FIGURE TITLES
I Figure 1: An Example Use of Isopleths 11-17
Figure 2: Normalized Particle Size Distributions Showing
Typical Grouping of Major Chemical Components . . . 111-3
Figure 3: Annual Geometric Mean Sulfate and Nitrate Levels
- at Nonurban NASN Sites - 1974 111-9
Figure 4: Composite Annual Geometric Mean TSP Levels at Non-
urban NASN Sites from 1970 through 1973 IV-8
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LIST OF TABLE TITLES
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Table 1: Emission Source Categories ............ II-8 |
Table 2: Emission Source Data Required .......... 1 1-9
Table 3: Composite Summary of Filter Analysis by Site
Classification .................. III-2
Table 4: Regional Variation Major Chemical Classes Typically
Occurring as Fine Parti cul ate .......... VIII-8
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* OVERVIEW OF FACTORS AFFECTING ATTAINMENT OF THE
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NATIONAL STANDARDS FOR PARTICULATE MATTER
g The following statements summarize the pertinent facts concerning
f the nature and extent of the particulate matter problem and the tech-
* nical information available to assist in the analysis and development
fl| of approvable control strategies for particulate matter.
1. The National Primary Ambient Air Quality Standards for par-
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ticulate matter (PM) are 75 jug/m , annual geometric mean, and 260 /jg/m ,
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_ maximum 24-hour concentration, not to be exceeded more than once per year.
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m The National Secondary Ambient Air Quality Standards are 60 ^ig/m , annual
geometric mean, as a guide to be used in assessing implementation plans
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to achieve the 24-hour standard, and 150 >jg/m , maximum 24-hour concen-
| tratlon, not to be exceeded more than once per year.
M 2. The term particulate matter (PM) represents a broad group of
* diverse substances. These substances can be chemically categorized as
primary or secondary particulate matter. Primary particulate matter
is any particulate matter that is emitted directly from a source, natural
I or manmade, and remains relatively unchanged chemically in the atmosphere.
^ Secondary PM 1s formed in the atmosphere from gaseous precursors. Precur-
* sors are generally "pollutant gases" (S09, NO , HC) emitted from many
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M of the same sources as the primary PM and also gaseous constituents
such as ammonia from natural sources, such as decaying vegetation. PM
I may also be classified physically by mass fractions as a function of
particle size. The "fine" fraction is usually defined as being the mass
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of particulates that have an aerodynamic diameter between 0.01 and 2.0
micrometers. The coarse particulate fraction roughly encompasses those
particles with an aerodynamic diameter of 2.0 to 100 micrometers.
3. Existing ambient air quality standards do not differentiate
with regard to chemical composition or particle size. Studies suggest
that both primary and secondary components of PM have serious health
effects. EPA is still studying the need for specific air quality stand-
ards for fine and/or secondary particulates. Recent evidence suggests
an approach which places greater emphasis on the control of selected
categories of particulate matter such as sulfates, organlcs, etc., with
continued reliance on the current PM standard for overall control of
particulates rather than the development of a fine particulate standard.
In a recent court action, NRDC v. Train (9 ERC 1425, 2nd Cir. 1976),
EPA was directed to develop an air quality standard for lead. Additional
air quality standards with regard to other fractions may be developed
in the future, depending on research and court action.
EPA has scheduled review and revision of the Air Quality Criteria
Document for particulate matter by August 1979.
4. The Federal Reference Method for measuring particulate matter in
the ambient air is the high-volume sampler. The results are expressed
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as the mass concentration of suspended particulates in jjg/m . No procedures
for determining equivalency of alternate methods have been developed;
hence, the high-volume sampler is the only acceptable method. In 1974,
2,004 sites reported valid* (all four quarters) PM data to the Storage and
Retrieval of Aerometric Data (SAROAD) system.
*Validity refers to the fact that there are sufficient values to calcu-
late an annual average.
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5. Observed concentrations of particulate matter are sensitive
to the siting of monitors. Slight changes in either the horizontal or
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vertical placement of the monitor may result 1n significant differences
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in ambient measurements. Studies have shown that a 10 to 25 ^ig/m d1f-
ference in measured annual air quality levels can result from moving a
monitor only a few hundred feet. The development of uniform siting
criteria has been considered by the Standing Air Monitoring Work Group.
The Work Group document, which will be discussed in Section IV, is Air
I Monitoring Strategy for State Implementation Plans. EPA 450/2-77-010,
g June 1977.
6. Even though ambient concentrations of parti cul ate matter on
I a national basis have been reduced by approximately 4% per year between
1971 and 1975, violations of national standards are still recorded 1n
many portions of the nation. In fact, 23% of the stations reporting
g valid data to SAROAD in 1974 had concentrations that exceeded the pri-
mary annual standard. These sites were located within 111 of the 247
air quality control regions (AQCRs) in the nation.
7. While abatement actions scheduled under the original State
| Implementation Plans (SIPs) will continue to reduce ambient concentra-
tm tlons in a number of areas of the nation, it is now clear that some of
the original SIPs are not adequate to provide for attainment and main-
I tenance of national standards. In such areas, the SIPs will need to be
revised to include either more stringent emission limitations or controls
Q on sources which were not controlled by the original SIPs. In July,
- 1976, EPA officially notified 29 States, the District of Columbia and
" Puerto Rico that their SIPs needed to be revised for PM.
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8. To the extent possible, except for the contribution of fugitive
dust, 1t 1s recommended that diffusion modeling 1n lieu of rollback
modeling be used in defining a source/receptor relationship where SIP
revisions are needed. There are several models which are suggested for
use in control strategy development, as discussed in Section VI. Fugi-
tive dust problems require modified techniques not yet incorporated in
these models, but suggested approaches are also discussed in Section VI.
9. In areas where emissions from stationary sources contribute to
violations of national standards, emission limitations representing at
least reasonably available control technology (RACT) or more stringent
controls if necessary to demonstrate attainment are to be fully imple-
mented by December 31, 1982. These plans are to be adopted and submitted
by January 1, 1979.
10. With respect to individual point sources with defined emission
points, reasonably available control technology (RACT) defines the
lowest emission limit that a particular source 1s capable of meeting by
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. The determination of RACT may vary
from source to source due to specific source configurations, retrofit
feasibility, operation procedures, raw materials, and other characteristics
of an individual source or group of sources.
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11. Various efforts have either been completed or are underway
to provide guidance on determining RACT for any particular sources.
| These efforts are specifically identified in later portions of this
_ document.
* 12. It has been generally acknowledged that fugitive process
M emissions (I.e., industrial emissions which escape to the atmosphere
through doors, windows, etc., but not through a primary exhaust system)
P were generally not included in the original SIPs. In some cases, it has
been shown that fugitive emissions may be responsible for an annual
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air quality impact of up to 25 jjg/m . A study on fugitive process
emissions has recently been completed. The study, Techn1ca 1 Gu1deline
for Industrial Process Fugitive Particulate Emissions, EPA Report No.
§ 450/3-77-010 (Prepared by PEDCo, Environmental Inc., Cincinnati, Ohio),
concentrates on the development of techniques to control industrial pro-
cess fugitive particulate emissions defined as . . ."Particulate matter
A which escapes from a defined process flow stream due to leakage, materials
charging/handling, inadequate operational control, lack of reasonably
available control technology, transfer or storage." The guideline also
includes techniques for estimating ambient concentrations due to these
sources.
13. Numerous investigations to determine the cause of non-attain-
ment of national standards in many areas have concluded that various
f fugitive dust sources are contributing significant concentrations of
particulate matter. Fugitive dust is particulate matter that becomes
suspended due to wind or man's activity or both. Fugitive dust from
unpaved roads, construction activity, and re-entrainted particles from
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paved roads have been noted as being the primary cause of non-attainment
in certain areas. A study, Technical Support Document for Development
of Control Strategies in Areas with Fugitive Dust Problems, conducted in
Phoenix, AZ, suggests techniques for estimating fugitive dust emissions,
the control available, and the costs associated with controlling such
sources. The document includes proposed diffusion modeling techniques
for fugitive dust in arid western U.S. regions which may be useful in
the following situations:
(1) To assess the relative importance of the fugitive dust problem.
(2) To assess the need for additional stationary source control in
the context of the overall problem.
(3) Give a preliminary evaluation of the potential impact of
various fugitive dust control measures. This evaluation could give a
preliminary assessment of the likelihood of attainment/maintenance and
an initial screening of those fugitive dust control measures which appear
most promising for further evaluation.
Estimates have been made concerning the air quality impact of certain
sources of particulate matter. These include:
Construction Activity - Typical impact due to construction is on
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the order of 1 to 3 jjg/m increase in citywide annual averages. Pri-
mary impact is at sites within the immediate vicinity and downwind
from the construction activity up to distances of one mile.
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Rubber T1re Particles - Typical annual impacts of several jjg/m
have been found with the highest Impact at Industrial and com-
merclal sites. Sites located near heavy traffic areas average
twice the levels at other sites.
Resuspended Dust - Annual average Impact is variable, but a typical
level of Important residential monitors is estimated at 10 to 15
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jjg/m and 15 to 20 jug/m at commercial and industrial sites respec-
tively. The composition of this component is mostly mineral matter
and secondary PM.
Additional studies are underway to address the solution to fugitive
dust problems in other areas of the U.S., and guidance 1s expected to be
made available by September 1977.
14. States must consider the control of fugitive dust in their SIPs
where it is a manmade problem, especially in large urban areas. The date
(1 for submittal of plans for the control of fugitive dust as well as other
fi control measures is January 1979. These plans must include specific
regulatory actions that may be needed to attain national standards, and
may include various interagency agreements, demonstration grants to
investigate possible control solutions and other actions which may be
needed for an adequate control strategy.
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PROCEDURES FOR THE REVIEW AND DEVELOPMENT OF A
CONTROL STRATEGY FOR PARTI CULATE MATTER
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m Scope and Objectives
The development of an air pollution control strategy designed to
attain and maintain the National Ambient Air Quality Standards (NAAQS)
requires an analysis of current and possible future air quality problems.
It is the objective of this section to briefly present the quantitative
M and qualitative procedures used in developing an acceptable plan for
the control of parti culate matter. The amount of work involved in each
step will vary from area to area depending on available data, magnitude
of the n on- attainment or maintenance problem, types of emission sources,
m etc. These steps can be summarized as follows:
STEP 1: Review available air quality data for PM to determine if
national standards are not being attained or will not be
maintained.
STEP 2: Determine the validity of available air quality data.
I STEP 3: Review valid air quality data to determine their representa-
tiveness and their limitations.
STEP 4: Determine if valid air quality data are of such concentrations
I that a further analysis of existing and anticipated emissions
data should be conducted.
it STEP 5: Determine the boundaries of the geographic area to be considered
m in the analysis.
STEP 6: Determine the sources of parti culate matter emissions within
the area and calculate the emissions from each source.
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STEP 7 : Determine the spatial distribution of emission sources through-
out the area of analysis and allocate emissions accordingly.
STEP 8 : Using a recommended atmospheric diffusion model, determine
the baseline source/receptor relationship for the area.
STEP 9 : Determine the degree of control that will occur from full
compliance with adopted regulations.
STEP 10: Determine the expected increase of emissions due to growth
profiles, generally for the next 20 year period.
STEP 11: Factor growth into diffusion model to predict future air
quality.
STEP 12: If additional control measures are needed to provide for attain-
ment and maintenance, determine the effectiveness of various
emission control measures on reducing ambient PM levels.
STEP 13: Determine the most expeditious date of attainment, which must
be before December 31, 1982.
Detailed explanations of the foregoing steps now follow. More detail
and background on this procedure can be found 1n Air Qualjty Analysis
Workshop, Volume I - Manual. EPA-450/3-75-080a, November 1975.
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STEP 1 - Review available air quality data for PM to determine 1f
| sufficient data are available to provide evidence that the national
g standards are not being attained or will not be maintained. Compari-
son of measured ambient levels with the NAAQS is the primary means of
fl determining whether air quality requirements are being achieved. Where
the NAAQS are being exceeded, the reason for the high levels must be
1 determined and the need for corrective action evaluated. Valid data
_ from at least one site with one year of data should be available. How-
* ever, 3 years or more of data are preferable. Comparison of data over
a period of years for a specific area can indicate developing air
quality trends. In areas exceeding the NAAQS, the trend can be used
| as a monitor of progress in attaining the standards. In areas where
_ NAAQS are being met but where growth and development are occurring,
* upward trends in measured concentrations may dictate a reevaluation of
fl the need for specific maintenance measures in addition to existing
stationary source and mobile source programs.
fl Data should also be available from areas of expected maximum con-
centrations ; however, lack of such data should not preclude the develop-
* ment of a control strategy if available data indicate valid violations
I of national standards. Where data are limited, predictive models are
available to estimate ambient PM air quality levels.
fl STEP 2 - If ambient air quality data indicate a potential attainment or
maintenance problem, review the data to determine its validity.
(a) Determine if a satisfactory measurement procedure was used to
collect the data being reviewed. Insure that each monitoring site uses
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a high volume sampling device, as described in 40 CFR, Part 50, Appendix
B. The high-volume method is the Federal Reference Method for total
suspended particulates and is the only acceptable method. No procedures
for determining equivalency of alternative methods have been developed;
so all other methods are to be considered unacceptable.
(b) Analyze the available air quality data to assure their validity
and reliability. Determine if the data were collected by monitors that
are properly operated, maintained and calibrated, and if adequate quality
control procedures were utilized to assure validity of data.
Several guidelines have been developed to assist 1n the review and
validation of air quality data:
I. Guidelines for the Evaluation of Air Quality Data. OAQPS No. 1.2-015,
Feb. 1974.
II. Guidelines for the Evaluation of A1r Quality Trends. OAQPS No. 1.2-014,
Feb. 1974.
III. Guidelines for Air Quality Maintenance Planning and Analysis,
Volume 11, A1r Quality Monitoring and Data Analysis, OAQPS No. 1.2-030,
Sept. 1974.
IV. Designation of Unacceptable Analytical Methods of Measurement for
Criteria Pollutants. OAQPS No. 1.2-018, Sept. 1974.
NOTE: The purpose of Step 2 1s to insure that the data which will be used
as the basis of a control strategy are valid, or can reasonably be assumed
to be valid. If it 1s 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
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hand, all reasonable measures have been followed 1n the collection of
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the data, and unless the validation efforts prove the data to be Invalid,
then such data should be assumed valid and usable.
STEP 3 - Review the valid air quality data to determine their represen-
tatlveness and Its limitations.
(a) Determine the representativeness (I.e., how well the data
reflect the air pollutant concentrations caused by emission sources
1n the area of interest), as suggested by the location of the monitor,
and whether the measured concentrations are widespread or restricted to
the local area. This will aid in developing regulations which will be
aimed at the true cause of the violation. For example, if a monitor is
Influenced predominantly by street dust, a new control regulation which
addresses stationary sources would be ineffective 1n reducing levels at
that monitor; only controls aimed at reducing street dust would reduce
these levels. Thus, in order to formulate appropriate measures later 1n
m the development of the control strategy, it 1s Important to define as
well as possible the sources which influence the monitor.
(b) Identify unusual conditions which may have influenced the data.
Events such as dust storms, forest fires, control equipment malfunctions
or shutdowns can temporarily cause abnormally high ambient concentrations.
EPA regulations (40 CFR Part 51.12(d)) allow states to discount abnormal
measurements which occurred during such unusual conditions. Data col-
lected during unusual conditions should not be used as the basis for
increasing the stringency of control regulations.
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STEP 4 - Determine if valid air quality data are of such concentrations
that a further analysis of existing and anticipated emissions data should
be conducted. This analysis should be conducted if ambient air quality
levels are equal to or exceed national standards. Also, in those areas
where growth of new emission sources is expected, the analysis should
be conducted even if national standards are being attained on a marginal
basis.
STEP 5 - Determine the boundary of the geographic area to be considered in
the analysis. From available data, determine the geographic area where
national standards are violated or are anticipated to be violated due to
growth of emission sources. It is not necessary to^use an entire AQCR
or county. The area does not have to be a political entity. Some con-
sideration should be given to political boundaries, however, since the
regulations may be enforced by local governments. Although some advantages
accrue to the use of a commonly identified geographical area, as long as
the area is clearly defined, any area is appropriate for development of
a control strategy. The area of concern should be "future-oriented," in
that strong consideration should be given to growth of emission sources.
A diffusion model analysis may be useful in defining the boundaries of
the study area (See STEP 8).
STEP 6 - Determine the sources of particulate matter emissions 1n the area
and calculate the emissions from each source.
The air pollutant emission inventory forms the basis of making an
assessment of air quality management problems. Because of growth, develop-
ment, and regulatory programs applied to pollutant producing activities,
II-6
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I
the emission Inventory can be expected to change with time, hence it will
generally be necessary to update the Inventory.
The Inventory should be updated to the most recent time period for
which adequate data are available. All portions of the inventory should
I be adjusted to the same year. Further, the emission inventory should
cover the same time period as that represented by the air quality data.
In other words, 1f 1975 air quality data are to be used in the analysis,
then 1975 emission data should be used.
The emission data which are generally needed are generally divided
I into six major source categories and various subdivisions as indicated
in Table 1. Point sources are generally any stationary sources which
I may be specifically defined (or restricted) by an emission limit or
constraint. An area source 1s a collection of sources whose individual
emission rates are small but whose collective impact may be large.
Exceptions to the point source definition would be large boilers using
residual fuel oil and apartment house incinerators such as those found
1n New York City. These are subject to "specifically defined emission
limits," but are best treated as area sources in the analysis. Table
2 lists the general types of information needed for each source type.
There are several special considerations that will influence the
development of an emission inventory. These include:
a. Intent of Inventory - It is important to realize that there are
various purposes for which the emission data are needed. The two basic
purposes are (1) to assess where the ambient PM problem originated, and
I (2) to determine the emission reduction Impact of various possible
control regulations on source emissions. Data should be collected to
| satisfy both objectives.
I
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TABLE 1 - EMISSION SOURCE CATEGORIES
Source Category
Subdivisions
Source
Description
Industrial Process
Fuel Combustion
Transportation
Electricity Generation
Incineration
Miscellaneous
Chemical manufacture
Food/agriculture
Primary metals
Secondary metals
Mineral products
Petroleum industry
Wood products
Evaporation
Metal fabrication
Leather products
Textiles
Inprocess fuel
Other
Internal combustion
External combustion
Highway Vehicles
Light duty gasoline autos
Light duty gasoline trucks
Motorcycles
Heavy duty gasoline trucks
Heavy duty diesel trucks
Off-highw,ay vehicles
Rail locomotives
Vessels
Aircraft
Solvent evaporation
Fires
Fugitive dust
Point
Point, Area
Area
Point
Point, Area
Point, Area
Source: Air Quality Analysis Workshop Volume IManual, oj?. cit., page 41
II-8
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Table 2 - Emission Source Data Required
Source Type Data Desired
I Point Pollutant emission rates
Process activity - type of process, process weight
Irate
Control equipment - type and efficiency
Stack parameters
Geocoded location
Compliance information
Land areaa
Employment3
J Area Pollutant emission rates
Area geometry
I Area geocoded location
Area source type and activity level
m aMay be useful for certain strategy considerations.
Source: Air Quality Analysis Workshop Volume l--Manual, op. cit. , page 42.
| b. Level of Petal 1 - The level of detail in the inventory must
« be suitable to the analysis to be performed. It is not adequate to
develop an inventory of a source category, for example, with crude
I approximation methods if the analysis will require a detailed considera-
tion of that source's impact on air quality. The most detailed level
| should be used on major sources that are expected to impact signlfi-
M cantly on air quality. Less detailed procedures may be used for minor
sources. Recent work on the development of A1r Quality Maintenance
tt Plans includes a detailed discussion of Inventory updating procedures.
The reader is referred to the Air Quality Analysis Workshop Volume I -
I Manual, op. cit., page 44, and Guidelines for Air Quality Maintenance
m Planning and Analysis, Volume 7, Projecting County Emissions, OAQPS
No. 1.2-026, January 1975, for a detailed discussion of inventory up-
dating procedure.
II-9
I
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c. Actual vs. Allowable Emissions - In the development of the
emission Inventory, it is important to keep 1n mind that the desired
inventory is one that represents, as closely as possible, the actual
situation. In this light, the effect of the following items must be
considered:
Variances granted.
Non-compliance.
Compliance schedules.
Improved performance.
Seasonal operation.
The Incorporation of stack test data into the inventory whenever
possible will ensure that these considerations are included. For sources
not yet in operation or for the projected inventories, the first approxi-
mation of assuming that sources will just meet the emission regulations
will be adequate; however, where information is available to the contrary,
it should be Included.
d. Applicability of strategies - In developing the emission inven-
tory, it is necessary to foresee what type of information might be needed
to evaluate alternative control strategies. If, for example, it is felt
that a strategy based on emission density (I.e., emissions per unit area)
will receive consideration, then it is necessary to know what land area
is currently owned by the sources in the inventory. If a strategy will be
directed toward a certain type of process activity, it will be necessary
to know which sources use that process.
Comprehensive guidelines are available on procedures for calculating
emissions from various sources. The reader 1s referred to Guide for Com-
piling a Comprehensive Emission Inventory. EPA/APTD 1135, March 1973.
Also, EPA Document AP-42 with Supplements 1-6, April 1976, contains emis-
sion factors for estimating emissions from numerous sources.
11-10
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* Modeling of fugitive PM sources requires considerably more detail
1n the emissions Inventory data with respect to the physical characteris-
tics of partlculates. In this regard, merely because an emission inven-
| tory is modified to account for fugitive dust and fugitive emissions,
£ 1t will in all likelihood not be amenable for use in existing diffusion
* models. This is because the model to be used must be modified to pro-
fl perly consider fugitive PM, e.g., particle size and density distributions
must be suitable for such considerations as tilt of the plume, gravlta-
| tional settling, surface deposition, wet removal and re-entra1nment of
£ settled PM by wind. Current model improvement projects are underway to
provide techniques to handle these problems, and guidance should be
available by the Fall of 1977.
STEP 7 - Determine the spatial distribution of emission sources through-
| out the area of analysis and allocate emissions accordingly.
£ To this point, the focus of the emission inventory portion of the
analysis has been to generate the emission pattern generally for the entire
area under study such as a county. Prior experience with air quality
management has shown that countywide spatial resolution of emissions is
| usually too coarse for parti culate matter. The effects of individual
g sources are generally localized in impact and an adequate analysis and
control strategy development relies on a spatial resolution of emissions.
ft The identification of the level of spatial resolution is a function of
several variables:
| Available data.
Anticipated problem areas.
Anticipated problem sources.
I Applicability to modeling.
Applicability to strategies.
Resources available.
-------
The principle constraint on spatial resolution is the available data.
If the information is on too coarse a geographical scale, then an
effort is required to improve the data base. The spatial resolution
should be fine enough to distinguish special problem areas and special
problem sources. As an illustration, it is not possible to treat a major
metropolitan city in its entirety. The spatial resolution should be
able to distinguish the Central Business District (CBD) from industrial
parks and from residential neighborhoods. Further, the applicability of
control strategies is an important consideration and is one of the prime
reasons for using a sub-county resolution. In some cases, control stra-
tegies may not be appropriate for application to an entire county and
the analysis should be sensitive to these considerations.
In order to provide for the needed spatial distribution of emission
sources, it 1s necessary to establish a master grid system for the area of
analysis. There are a variety of rectilinear coordinate systems that can
be used in developing a master grid. It 1s desirable, however, to use
Universal Transverse Mercator (UTM) coordinates, which are universally
available on U.S. Geological Survey maps. The UTM coordinates offer the
widest generality and applicability. The only translation problem occurs
when an analysis area lies between two UTM zones where the abscissas are
not continuous. This is treated by means of careful bookkeeping.
The master grids chosen should, in general, be square with variations
in size depending on the resolution of the subcounty areas. The smallest
11-12
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I
grid square chosen should be 1 km x 1 km. Smaller grids should be
considered only if the necessary data are available. A "micro-inventory"
around monitoring sites may be needed to establish source receptor rela-
tionships, such as in the case of the larger size fugitive dust particles,
I The largest grid square chosen should be 8 km x 8 km. Larger grids would
cancel some of the subcounty resolution already achieved. The use of
dispersion models dictates certain limits on the size and number of grids
and hence on the spatial resolution. Although the models can theoreti-
cally treat any size grid, the accuracy suffers if the grids are too
I large and computation expense increases if they are too small.
Once the master grid has been established, the calculated emissions
can be allocated throughout the area. There are basically three proce-
dures for determining spatial allocations of emission-producting activity;
Locate the activity directly from available data,
Develop a distribution function of activity using an allocation
parameter (e.g., population), and
A combination of the above procedures.
Volume 13 of the AQMA series (Allocating Projected Emissions to Sub-
County Areas) outlines the recommended procedures for these methods as
applicable to each of the source categories. The sources that can be
spatially located directly are, existing and new:
I Industrial point sources.
Commercial/Institutional point sources.
I Steam-electric power plants.
Limited access highways.
I
11-13
I
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If the source activity cannot be located directly, a distribution
function can be used to allocate emissions. A simple model would start
with the knowledge of the activity on a countywide basis and then distri-
bute this activity to each subcounty area based on that area's proportion
of some county wide parameter, such as population or employment. The
types of distribution functions that can be developed include: population,
dwelling units, dwelling units by fuel use, employment, land use, and area.
More detailed guidance on the subject of allocating emissions to subcounty
areas is available in the AQMA guidelines:
(a) Volume 2. Plan Preparation. OAQPS No. 1.2-021, July 1974.
(b) Volume 7, Projecting County Emissions, OAQPS No. 1.2-026, Jan.
1975.
(c) Volume 13, Allocating Projected Emissions to Subcounty Areas,
OAQPS No. 1.2-032, Nov. 1974.
Until July 1, 1979, allocation of future emissions for major new
point sources may be discounted where EPA's emission offset policy is
applicable. This policy does not prohibit major new or expanded sources
1n areas that exceed NAAQSs, provided that the new effect of the new emis-
sions together with reductions from existing facilities beyond that required
by the SIP does not exacerbate current primary standard violations, but
instead contributes to reasonable progress in attaining such standards.
Due to the Clean Air Act amendments of 1977, SIPs must be submitted by
January 1, 1979, to demonstrate attainment by 1982, and there will be a
change in the usage of the offset policy after July 1, 1979. The offset
policy may be incorporated into the SIP 1n nonattainment areas as part of
11-14
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I
^ the process to demonstrate attainment and allow for new growth by reducing
emissions from existing sources. See page VIII-13 for a discussion of
EPA's emission offset policy.
NOTE: The procedures outlined in STEP 6 should not be viewed as necessarily
J separate and distinct from the development of the baseline inventory des-
cribed in STEP 7. In many instances these techniques can be used in parallel
rather than in series with the previous methods.
STEP 8 - Using recommended atmospheric diffusion model, determine the
baseline source/receptor relationship for the area.
g An atmospheric diffusion model is used to convert the air pollutant
emission data into ambient air pollutant concentration estimates. The
model is an analytical tool that helps the air quality analyst determine
the effectiveness of his control strategies.
In the task of developing a control strategy, the choice and use
| of a model is a key step. Some means of relating air quality, meteorology,
and emissions to appropriate control regulations must be used, and this
" necessitates the development of a "source/receptor" relationship which is
as accurate as possible. Caution must be used, because atmospheric simu-
lation models are useful only if the user understands their applications
| and limitations. The services of air pollution meteorologists and engi-
neers are especially important in the application of the more sophis-
ticated models and in locales with complex meteorology or topography.
The choice of which model to use is a function of many considerations
including pollutant, averaging time, data requirements, model output,
ease of use, availability, reliability, and applicability to air quality
11-15
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analysis. A description of the models most frequently used by EPA 1s
presented 1n Guidelines for Air Quality Maintenance Planning and Analysis,
Volume 12: Applying Atmospheric Simulation Models to A1r Quality Main-
tenance Areas, OAQPS No. 1.2-031. Sept. 1974; an updated listing 1s pre-
sented In the Guideline on Air Quality Models and Associated Data Bases,
February 1977 (Draft).
Techniques for fugitive dust modeling are currently under study by
EPA. A discussion of this issue 1s included on page VI-6.
A useful form of output for those models that can compute concentra-
tions at any point is the isopleth or line of constant concentration. If
the computations are made at a large enough number of receptor points, then
the Isopleths are easily drawn by interpolating between adjacent points.
The use of Isopleths is an extremely valuable tool in visualizing the
general air quality situation and identifying "hot spots" (See Figure 1).
In determining the Impact of various sources on air quality at a
given location, it is worthwhile to develop a list of the contributions
of each source to the calculated concentration at a given receptor. Since
all of the recommended models made use of the principle of superposition
in that the concentration is calculated as the sum of the emissions dis-
persed from each individual source, it is conceptually straightforward
to develop such a list. The AQDM model has a routine incorporated into it
that prepares such a list with no additional burden on the user. This
Information is extremely useful in control strategy development and analysis,
STEP 9 - Determine the degree of control that will occur from full com-
pliance with adopted regulations.
Consider the impact on PM emissions (both Increases and decreases)
that may result from (a) source compliance with adopted particulate
11-16
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50
Figure 1. An Example Use of Isopleths.
11-17
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matter control regulations, or the regulations adopted primarily to
minimize emissions of another pollutant but which may have an effect
on particulate matter emissions or concentrations, and (b) fuel switches
that may Increase or decrease particulate matter emissions. For the
analysis, it 1s important to tabulate such changes in emissions according
to the dates on which they are scheduled to occur. For fugitive dust
sources, Improvements such as city plans for paving roads will reduce
emissions.
In some cases, air quality problems are caused by non-compliance
with existing regulations. Therefore, prior to the consideration of
developing new control programs, it 1s necessary to review the enforce-
ment of existing programs. It should be a first priority in the air
quality analysis to determine if enforcement of existing regulations
could achieve the air quality goals. Only after it is determined that
full compliance with current regulations is Inadequate to attain and
maintain the NAAQS should effort be expended on developing new control
programs. Atmospheric diffusion modeling can be a valuable tool in
this determination.
STEP 10 - Determine the expected increase of emissions due to growth
profiles, generally over the next 20-year period.
Growth is an inherent part of the air pollution analysis, and consi-
deration of growth is thus indispensable in the development of a control
strategy. The variables that can be projected Include the following:
11-18
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I
Industrial process activity,
Fuel consumption,
Transportation activity,
I Electricity demand,
Solid waste generation, and
Miscellaneous emission-producing activity.
In addition, the temporal and spatial distribution of these variables
(e.g. , when new plants will come on line and where they will be located)
I is important to the air quality analysis. In most situations, projections
of these parameters are not available or are available only on a cruder
scale than needed for an adequate air quality analysis, especially in
attainment/maintenance problem areas. Reliance must then be placed on
surrogate variables such as population, employment, land-use, earnings,
and others that are projected with reasonable accuracy and precision and
m that can then be transformed Into growth factors for the desired variables.
The information needed to develop growth factors originates from
fl Federal agencies, State and local governments, and private business
interests. Fairly specific information can be obtained from State and
I local planning agencies and this is generally the recommended source for
m such data. If the data are unavailable from local agencies, various
Federally funded planning programs should provide the growth projections.
These include: Planning under (1) Section 701 of the Housing and
Urban Development Act of 1974, (2) the Coastal Zone Management Act of
| 1972, (3) the Federal Aid Highway Act of 1962 (as amended) and the
Urban Mass Transportation Act of 1964 (as amended), and (4) Section 208
of the Federal Water Pollution Control Act Amendments of 1972. Also
I OBERS projections of economic activity in the U.S., prepared for the U.S.
Water Resources Council provides projections on the basis of Standard
| Metropolitan Statistical Areas.
I
11-19
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Various guidelines have been prepared with regard to obtaining and
projecting growth in emissions and allocating such growth. These tech-
niques are too detailed to summarize here. The reader is referred to
various Air Quality Maintenance Guidelines on the subject:
(a) Volume 2, Plan Preparation. OAQPS No. 1.2-021, July 1974.
(b) Volume 7, Projecting County Emissions. OAQPS No. 1.2-026, Jan.
1975.
(c) Volume 13. Allocating Projected Emissions to Sub-county AQMA,
OAQPS No. 1.2-032, Nov. 1974.
(d) Appendices A and B. Volume 13. OAQPS No. 1.2-032, March 1975.
(e) Volume 13b, Accounting for New _Source Performance Standards
in Projecting and Allocating Emissions - Hypothetical Example,
OAQPS No. 1.2-032, Jan. 1975.
11-20
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STEP 11 - Factor growth into the diffusion model to predict future air
I quality. This will allow predictions of the effect of anticipated growth
in an area on air quality during specified future periods, and aid in
I selection of control strategies to attain/maintain air quality stand-
ards throughout the periods. The model will indicate the reasons for
future problems in meeting the standards such as: point sources, area
I sources, land use, or growth.
STEP 12 - If additional controls are needed to provide for attainment
and maintenance, determine the effectiveness of various emission control
m measures on reducing ambient PM levels.
When the results of the diffusion modeling analysis indicate that
control measures above and beyond the existing regulations are needed
to attain and maintain the NAAQS, then an additional analysis will be
needed to examine the effectiveness of various types of control measures.
Traditional air pollution control programs have relied on technological
controls on stationary sources to generally achieve desired air quality
levels. Technological controls are the controls that require emission
reductions from specific source categories through the addition of flue-
gas cleaning devices, changes in process method or equipment, or fuel
substitution. In some cases, in order to attain and maintain NAAQS,
it may be necessary to require additional non-traditional considerations
such as land use and transportation planning measures. In choosing
strategies for evaluation, both options should be considered through
I the use of diffusion modeling where possible; however, since land use
control measures are in general significantly more difficult to implement
flj consideration in strategy choice.
and enforce, the use of technological controls should be given first
I
11-21
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Specifically, if current regulations do not require existing
stationary sources to install reasonably available control technology,
then such controls should be required where they are needed to provide
for attainment and maintenance of national standards. Use of this
strategy should be considered in light of the potential hardships that
might be created by land use or transportation controls.
Use of the modeling results from STEP 11 provides information on the
magnitude and geographical extent of the control measures needed. In
general, more than one option should be considered for each problem situ-
ation. This will give the control agency a perspective on the range of
possibilities that could be employed to attain and maintain the NAAQS.
It also gives the agency a contingency plan in the event that a particular
option is found to be unacceptable at some later point. It should be
recognized that control strategies need not be applied uniformly across
the study area. Certain sub-areas may require stricter controls on dif-
ferent types of sources.
The coordinated effort between air pollution control, regional
planning, transportation planning, and other groups is an underlying
assumption for the entire air quality analysis system. The agency taking
the lead role in the analysis must consult with other groups as necesary.
The choice of strategies for evaluation is one of the most crucial points
at which this consultation takes place. Some strategies may be eliminated
on the basis of social, economic, or institutional constraints without the
11-22
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I
necessity of a detailed evaluation of these considerations. Agencies
| participating 1n the air quality analysis should have the experience to
know which options are unacceptable for the study area.
STEP 13 - The State must determine the most expeditious date for attaln-
I ment, which must be before December 31, 1982.
I
I
I
I
I
I
I
I
I
I
I
I
I
- II-23
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I
I
QUESTIONS CONCERNING SOURCES AND
| TYPES OF PARTICULATE EMISSIONS
I QUESTION - What is the typical composition of urban PM? In other
words, if one were to analyze the material on a high-volume filter,
what would one find?
ANSWER - Recently a number of hi-volume filters collected in 14
different cities were analyzed by optical microscopy. These samples
gj were collected at areas of various land use categories within the
_ cities to determine the "typical" composition characteristics of
urban PM. The results are shown in Table 3. As can be seen, minerals
and combustion products are the major categories with approximately
65% and 25% of the total PM being comprised of these components
H respectively. It should be noted that in undeveloped or rural areas,
_ the mineral portion of PM is significantly high (i.e., approximately
90%).
The particle size and chemical composition of PM are important.
Optical microscopy does not "see" particles less than 1-2 micrometers
in diameter. Thus, a chemical analysis and accompanying particle
sizing would provide the most revealing information about the compos i-
tion of PM. Figure 2 illustrates both the general chemical makeup
and particle size distribution of PM in the air. The plot is constructed
so that the area under any section of a curve is proportional to the
I concentration in that size range. It is clear that very fine particles
I
III-l
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Table 3. ' COMPOSITE SUMMARY OF FILTER ANALYSES BY SITE CLASSIFICATION3
Site classification
No. of filters
No. of sites
Average concentration,
ug/tn3
Components
Minerals
Quartz
Calclte
Feldspars
Hematite
Mica
Othcrb
Combustion Products
Soot:
Oil
Coal
Ktsc. aootb
Classy fly ash
Incinerator fly ash
Burned wood
Burned paper
Magnetite
Carbon black
Otherb
BloloRlcal Material
Pollen
Spores
Paper
Starch
Misc. plant tissue
Leaf trichomcr
Miscellaneous
Iron cr steel
Rubber
Otherb
Commercial
114
29
120
Quantity,
percent
Average
(63)
28
20
6
9
<1
<1
(26)
8
4
7
4
3
<1
6
7
7
3
<1
1
<1
( 2)
1
<1
<1
<1
1
<1
( 6)
1
5
<1
Range
9-96
2-70
0-93
0-45
1-50
0-6
.0-46
1-89
0-40
0-40
0-88
0-76
0-45
2-10
\
0-15
0-12
0-33
0-25
0-2
0-10
0-7
0-6
0-45
0-25
0-45
0-15
Undeveloped
11
5
86
Quantity,
percent
Average
(90)
32
40
3
15
<1
( 8)
5
2
'
" 1
<1
<1
1 <1
( 1)
<1
<1
<1
<1
1
CD
" <1
1
Range
79-99
15-60
10-60
-------
a:
iU
cc
a.
a.
"a
'A1ISN3Q AiHIQVOOUd
Q)
B1.
iu rn
*£
w
QJ
0)
0) '(fl (U
9 q p
p -H SH
III-3
-------
make up most of the total suspended particulate 1n terms of numbers of
particles and surface area. The mass (inferred from volume) shows a
bimodal distribution.
The distinct minimum at about 2 pm between the two modes provides
a convenient size classification for atmospheric particles. The size
range between 0.1 and 1.0 pm is called the "accumulation" mode and
typically makes up about one third of the total suspended particulate
mass. Fine particulate mass "accumulates" in the 0.1 to 1 jum range
by coagulation of smaller particles or by condensation of gases on
existing particles. It is thought that most of the mass in the
accumulation model is formed by physical and chemical processes which
convert gases into particles, including trace element fumes from high
temperature sources and the transformation products of sulfur oxides,
nitrogen oxides, and organic compounds. The large particle fraction
of the bimodal distribution is termed the "coarse" mode. Coarse
mode particles are generally formed by mechanical processes such as
grinding or rubbing, for example, industrial processes, soil, street
dust, and rubber tire wear. Chemical composition in this range is
dominated by compounds of soil and mineral derived elements such as
silicon, iron, and aluminum. There appears to be very little exchange
of mass between the fine and coarse particle ranges in the atmosphere
because the far greater number and surface area associated with the
accumulation mode dominate the condensation and coagulation growth
processes. Thus, the fine and coarse particle modes generally have
distinctly different origins and chemical compositions.
III-4
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1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
REFERENCES AND ADDITIONAL INFORMATION - National Assessment of the Urban
Parti cul ate Problem,
Prepared for EPA by GCA Corporation, Bedford,
Massachusetts, EPA 450/3-76-024, July 1976.
QUESTION - What are
ANSWER - A few years
the major sources of partlculate matter in the nation?
ago, the answer to this question would have been a
tabulation of the emissions that had been Inventoried for major source
categories , such as
solid waste disposal
(a) fuel combustion, (b) Industrial processes, (c)
, and (d) transportation sources, etc. Today, how-
ever, as these sources are being controlled and ambient levels of PM
remain high, investigators are finding that other sources of PM also have
a significant impact
general categories:
Source-category
Man-made fugitive
on ambient PM levels. These include the following
Example
dust Dust from paved and unpaved roads
Fugitive process emissions Industrial emissions that are not
Mobile sources
Natural sources
emitted through a stack
Rubber tire particles, vehicle exhaust
Pollen, sea salt, dust storms.
REFERENCES AND ADDITIONAL INFORMATION - National Assessment of the Urban
Parti cul ate Probl em,
op. cit.
III-5
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QUESTION - What are the major categories of man-made participate matter
emissions (I.e., traditional sources) in the nation?
ANSWER - On a national basis, the major source categories of man-made
particulate matter include the following:
Tons/yr Percent
Industrial process 9,265,430 50
Fuel combustion 7,460,856 40
Solid Waste Disposal 884,910 5
Transportation 773,643 4
(tailpipe and rubber tire particles)
Miscellaneous 182,909 1_
Total 18,556,748 100
NOTE: It 1s believed that in general only a limited portion of the
fugitive process emissions (I.e., those which escape through windows,
doors, and the like, but not through a stack) have been estimated.
Man-made fugitive dust sources or secondary particulates are not In-
cluded 1n the above table.
REFERENCES AND ADDITIONAL INFORMATION - 1972 National Emissions Report.
EPA 450/2-74-012, June 1974, p. 1.
III-6
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I
QUESTION - What are "secondary participates"?
I ANSWER - Secondary particulates are the products of chemical reactions
_ occurring 1n the atmosphere. They can be formed directly from the gas
* phase or as a result of reactions between gases and already existing
I particles. The major factors which affect the formation of secondary
particulates are sunlight, temperature, pre-existing oxidant, meteorolo-
| gical conditions, and the presence of gases such as sulfur dioxide,
_ ammonia, nitric oxide, water vapor, and hydrocarbons, which enter the
* atmosphere from both natural and manmade sources. Secondary parti cu-
A lates range in size from molecular clusters with diameters on the
order of 0.005 micrometers to particles with diameters as large as
| several micrometers. Field studies of urban aerosols have shown that
_ most of the mass of secondary particulates 1s usually found in the particle
* size range 0.1 to 1.0 micrometers. The concentration of particles in
I this size range can vary directly with Intensity of sunlight and concentra-
tion of ozone. Nationwide, about one third of total suspended particulates
| can be classified as secondary particulates.
_ The principal factors governing distribution by size are the
respective rates of particulate formation and the rates of removal. The
smallest particles (0.1 ym), which are created constantly during the daylight
hours, coagulate into larger particulates (0.1 to 1 pi). The overall life
J cycle of secondary particulates is difficult to determine; estimates range
_ from several days to several weeks. In the end, the particles are either
I
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removed from the atmosphere by precipitation or dry deposition.
During this period, however, they may be transported vast distances
from the source of the gaseous precursors.
Found in both urban and rural areas, secondary particulates
are in general composed of three chemical classes or categories -
sulfates, organics, and nitrates. Annual geometric levels of sulfate
and nitrate levels at certain non-urban sites for 1974 are given in
Figure 3.
REFERENCES AND ADDITIONAL INFORMATION -
0) National Assessment of the Urban Particulate Problem, op. cit.
(2) Total Suspended Particulates: Review and Analysis, pre-
pared for EPA by R. Murray Welk, Radian Corporation, EPA 600/2-76-092,
April 1976.
QUESTION - More frequently, two sources, fugitive dust and fugitive
emissions, are being identified as significant sources of PM. How
are the two terms defined, and what are the differences between
"fugitive dust" and "fugitive emissions"?
ANSWER - There are no universally accepted definitions to characterize
and differentiate between the two separate "fugitive" categories. In
fact, some include all fugitive sources in a single definition. Fugi-
tive dust emissions are generally related to natural or man-associated
dusts (particulate only) that become airborne due to the forces of
wind, man's activity, or both. Fugitive dust emissions may include
III-8
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windblown parti oil ate matter from unpaved dirt roads, tilled farm
lands, exposed surface areas at construction sites and the like.
Natural dusts that become airborne during dust storms are also in-
cluded as fugitive dusts. It has been found that fugitive dusts
from tilled farm lands, unpaved roads, and construction sites, as
well as windblown natural particulate emissions from arid lands
(desert) during dust storms and other meteorological conditions cause
ambient concentrations above national particulate matter standards,
particularly in the West and Southwest.
Fugitive emissions, on the other hand, include both gaseous and
particulate emissions that result from industry-related operations and
which escape to the atmosphere through windows, doors, vents, etc.,
but not through a primary exhaust system, such as a stack, flue, or
control system. Fugitive emissions may result from metallurgical
furnace operations, materials handling, transfer and storage operations,
and other industrial processes where emissions escape to the atmosphere.
Fugitive emissions are generated during various industrial, manufac-
turing, and/or materials crushing, grinding, transfer or storage
operations. In other cases, fugitive emissions are more directly
emitted to the atmosphere from those industrial processes that operate
out-of-doors, such as coke ovens, rock-crushing operations at quarries,
and sand-blasting operations. Fugitive emissions also result from
poor maintenance of process equipment and from environmentally care-
less process operations. For example, fugitive emissions can result
from leakage from oven doors at coke ovens because such doors cannot
be properly sealed due to excessive warpage.
111-10
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REFERENCES AND ADDITIONAL INFORMATION -
(1) Lillis, E.J., and Young, D. , "EPA Looks at 'Fugitive
(| Emissions'," Journal of Air Pollution Control Association, 25: 1015-
« 1018, October 1975.
* (2) National Assessment of the Urban Particulate Problem, op. cit.
fl QUESTION - What are the most significant man-made fugitive dust sources?
ANSWER - Included in this category are reentrainment of road dust,
I fugitive dust emissions from construction and demolition operations,
_ dust from unpaved areas and dust generated by other urban activities
such as unpaved parking lots and bare unvegetated lots. In a number of
cases, particulates from these sources have prevented urban areas from
attaining ambient standards and, unless controlled, they will continue
M to do so. Given the current downward trend in emissions from
traditional sources, particulate matter from fugitive dust sources will
proportionally pose a greater problem for attainment and maintenance of
the ambient standards.
REFERENCES AND ADDITIONAL INFORMATION - National Assessment of the Urban
p Particulate Problem, op_. cit.
QUESTION - What emission factors are available for fugitive dust sources
and what work is underway to develop additional factors?
ANSWER - Section 11.2 of Compilation of Air Pollution Emission Factors
(AP-42), February 1976, contains emission factors for" heavy construction
I operations sites, aggregate storage piles, agricultural tilling, and
unpaved dirt and gravel roads. The emission factors for unpaved roads
I
are being refined by current studies for which the field work is now
beginning.
III-ll
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Additionally, unpaved roads are another fugitive dust source for
which emission factors are being developed. The field testing for these
emission factors has been completed, and the factors should be finalized
within several months and published within AP-42. Dust from paved roads,
sometimes called "re-entrained" particles, is a major portion of the PM
load in many areas.
Other attempts have been made to determine emission factors from
various fugitive dust sources. A 1974 report provides estimates for
partlculate matter emissions from cattle feedlots, tailings piles, and
windblown dust from farm lands. For farm lands, the USDA wind erosion
equation was used to estimate emissions. Individual calculations for
each major crop were performed since ground cover conditions, and hence
soil erosion potential, vary from crop to crop.
The caution stated earlier in Section II should be reiterated here.
Emission data on PM sources require considerable detail, especially
concerning particle size and density information, before use in diffusion
models. PM sources cannot be arbitrarily input to conventional models.
REFERENCES AND ADDITIONAL INFORMATION -
(1) Investigation of Fugitive Dust Sources, Volume I - Sources,
Emissions, and Control. EPA 450/3-74-036(a), June 1974.
(2) Compilation of Air Pollutant Emission Factors, Second Edition,
with Supplements 1-5, February, 1976; EPA Publication AP-42.
(3) Development of Emission Factors for Fugitive Dust Sources,
EPA 450/3-74-037, June 1974.
111-12
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QUESTION - What silt content should be considered 1n calculating the
_ emissions from unpaved roads?
ANSWER - The most comprehensive studies show that roadway dust emissions
are directly proportional to the silt content of the loose soil on the
road surface and to vehicle speed. "S1lt content," defined as the per-
| centage (by weight) of soil particles less than 75jjn 1n diameter, 1s an
_ essential part of the development of accurate emission factors for
unpaved roads.
As published 1n Compilation of A1r Pollutant Emission Factors
(AP-42, Part A), the quantity of fugitive dust emissions from an unpaved
f road, per vehicle-mile of travel, may be estimated (within +_ 20 percent)
using the following empirical expression:
.81 s\ S V 365-v
-fo.
"\
I where: E = Emission factor, pounds per vehicle-mile
s = S1lt content of road surface material, percent
I S = Average vehicle speed, miles per hour
w = Mean annual number of days with 0.01 1n. (0.254 mm)
or more -of rainfall
I The equation 1s valid for vehicle speeds in the range of 30-50 m1/hr
(48-80 km/hr).
| On the average, dust emissions from unpaved roads, as given by
. equation 1, have the following particle size characteristics:
Particle size Weight percent
< 30 jjm 60
> 30 jm 40
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The silt content of gravel roads averages about 12 percent, and the
dirt road may be approximated by the silt content of the parent soil
in the area. However, a recent study 1n the Phoenix, Arizona, area
demonstrated that the silt content of soil on a roadway may vary as
much as 20 to 60 percent from the average silt content of the sur-
rounding soil. It is, therefore recommended that field test data
of the silt content of the roadway be used in conjunction with the
above AP-42 emission factor formula.
REFERENCES AND ADDITIONAL INFORMATION -
(1) Compilation of Air Pollutant Emission Factors (AP-42). op.cit.
(2) An Implementation Plan for Suspended Particulate Matter in
the Phoenix Area, TRW Inc., Draft Report, Nov. 1976.
(3) Appendix F and Problem 3-3 in Air Quality Analysis Workshop
Volume I - Manual, op. cit.
QUESTION - Which existing stationary sources of PM are required to con-
tinuously monitor opacity?
ANSWER - On October 6, 1975, EPA promulgated regulations (40 FR 46240)
requiring States to revise their SIPs to include requirements for the
continuous monitoring of emissions from certain categories of existing
stationary sources affected by emission limitation of an approved SIP.
Appendix P of 40 CFR 51 lists the following source categories as being
covered by the regulation for monitoring of opacity:
1. Coal-fired, and some oil-fired steam generators in excess of
250 million BTU/hr heat input, with certain exceptions for age and use
of each boiler.
111-14
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2. Fluid bed catalytic cracking unit catalyst regenerators (at
I petroleum refineries) of greater than 20,000 barrels per day fresh
M feed capacity.
Revisions to SIPs to require continuous emission monitoring were
8 scheduled to be submitted by the States to Regional Offices by October
6, 1976. The State regulations may allow 18 months after EPA approval
| of the State submitted SIP revisions for sources to procure, install,
. and begin operating the monitoring instruments. Quarterly reports of
(1) emissions in excess of SIP emission limitations, and (2) the moni-
I toring system downtime must be submitted by the sources to the States.
REFERENCES AND ADDITIONAL INFORMATION - "Emission Monitoring of
§ Stationary Sources," (40 FR1 46240), Oct. 6, 1975.
_ QUESTION - Which new stationary sources of particulate matter are
~ required to monitor opacity?
ANSWER - On October 6, 1975, EPA promulgated regulations (40 FR 46250)
under 40 CFR, Part 60, New Source Performance Standards, which require
| continuous monitoring of particulate emissions from certain new sources,
_ which are specified by category. The primary source categories are
fossil fuel-fired steam generators and fluid bed catalytic cracking
unit catalyst regenerators. The regulation requires that all new fluid
bed catalytic cracking unit catalyst regenerators apply continuous moni-
jj toring for opacity and that all new fossil fuel-fired steam generators
_ of greater than 250 million BTU per hour heat input (except those where
* only gaseous fuel is burned) apply continuous monitoring for opacity.
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In addition, two other source categories are regulated by continuous
monitoring under New Source Performance Standards. The September 23,
1975, Federal Register contains regulations (40 CFR 60.272) for electric
arc furnaces 1n the steel industry. The regulations require continuous
monitoring of the opacity of emissions discharged Into the atmosphere
from the control device(s) of "any furnace that produces molten steel
and heats the charge materials with electric arcs from carbon electrodes."
The Federal Register contains regulations which require continuous
monitoring of the opacity of emissions discharged into the atmosphere from
the control device(s) of ferroalloy production facilities, including
"electric submerged arc furnaces which produce silicon metal, ferrosilicon,
calcium silicon, silicomanganese zirconium, ferrochrome silicon, silvery
iron, high-carbon ferrochrome, charge chrome standard ferromanganese,
silicomanganese, ferromanganese silicon, or calcium carbide" and the "dust
handling equipment" associated with these facilities.
REFERENCES AND ADDITIONAL INFORMATION -
(1) "Emission Monitoring Requirements and Revisions to Performance
Testing Methods", (40 FR 46250), Part 60, Oct. 6, 1975.
(2) (40 FR 43850), Sept. 23, 1975 (40 CFR 60.273).
(3) (41 FR 18502), May 4, 1976 (40 CFR 60.264).
111-16
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QUESTIONS CONCERNING AIR QUALITY
STANDARDS AND MEASUREMENT
QUESTION - What are the National Ambient Air Quality Standards (NAAQS)
for parti cul ate matter?
3
ANSWER - The primary NAAQSs are 75 jjg/m (annual geometric mean) and
2
1260 jjg/m (maximum 24-hour average concentration not to be exceeded
o
more than once per year). The secondary NAAQSs are 60 pg/m (annual
I geometric mean) and 150 ^g/m (maximum 24-hour concentration, not to
be exceeded more than once per year). Although referred to as a
standard, the 60 ug/m annual geometric mean is "a guide" (i.e., not
a standard). It may be used in developing and assessing implementation
plans to achieve the secondary 24-hour standard.
| REFERENCES AND ADDITIONAL INFORMATION -
(1) 40 CFR Part 50.7', National Primary and Secondary Standards
for Particulate Matter, promulgated April 30, 1971.
(2) Air Quality Criteria for Parti cul ate Matter, AP-49, January
1969.
QUESTION - Are the current standards for particulate matter being reviewed?
ANSWER - Yes. Plans were made at a joint ORD/OAQPS meeting on August 6,
I 1976, to revise and reissue the air quality criteria documents. The ori-
* ginal criteria document for parti cul ate matter was issued in 1969 and
has remained unchanged. Revision of all criteria documents has been
recommended by the National A1r Quality Criteria Advisory Committee of
the Science Advisory Board.
IV-1
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In addition, the Clean A1r Act as amended in 1977 requires that
"not later than January 1, 1980 and at five-year intervals thereafter a
review of the national primary and secondary ambient air quality standards
shall be completed..." Furthermore, revision of the documents allows the
Agency to publish the latest technical information supporting the National
Ambient A1r Quality Standards and the national regulatory program.
The criteria document for particulate matter is scheduled for revision
by August 1979.
REFERENCES AND ADDITIONAL INFORMATION -
Steigerwald, B.J., and Barth, D., Memorandum to Roger Strelow and
Wilson Talley, "Revision of Air Quality Criteria Documents," August 26, 1976.
o
QUESTION - When would the secondary annual standard of 60 jjg/m , annual
geometric mean, be used as a guide to determine if a control strategy
3
will result in attainment of the 24-hour standard of 150 jjg/m not to be
exceeded more than once per year?
ANSWER - To determine the average concentration for a period of 24-
hours, three options are available. The preferred option 1s to use a
model to estimate concentrations hour-by-hour for the period under consi-
deration and average the values of all the hours calculated. This option
is discussed in detail in the Guideline on Air Quality Models and Associated
Data Bases. (EPA, Monitoring and Data Analysis Division, Draft May 1977).
>
If this is not possible, the second option is to convert a concentration
for one averaging time (annual) to a concentration for a shorter time by
empirical techniques for urban multi-source areas or by empirical techniques
and data on the peak-to-mean ratio for point sources.
IV-2
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The second option may not be possible 1f certain statistical infor-
o
standards by using the 60 pg/m annual guide as a planning tool rather
3
than the secondary 24-hour standard of 150 >jg/m .
matlon such as the standard geometric deviation (sgd) of partlculate
I concentrations is not available. Also, such sgd information as is avail-
able may be unreliable because of variability. Finally, the option of
m using the secondary annual guide would apply where diffusion modeling
cannot be performed because of lack of Input parameters. For this case,
it would be necessary to use a proportional model such as rollback. In the
last two situations, it 1s reasonable under the regulations in Part 51 to
develop a control strategy which demonstrates attainment of the secondary
QUESTION - Is any consideration being given to the promulgation of a
national standard that considers particle size or chemical composition?
ANSWER - Yes. When the current PM standards were promulgated in 1971,
1t was generally recognized that other national standards for specific
fractions or components of PM might be necessary. Studies have indicated
that fine and secondary components of PM have serious health effects
I associated with them. EPA 1s still studying the need for specific air
quality standards for these components. Recent evidence suggests an
approach which places greater emphasis on the control of selected cate-
m gories of partlculate matter such as sulfates, nitrates, etc., with con-
tinued reliance on the current PM standard for overall control of parti-
culates rather than developing a fine partlculate standard.
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In a recent court action, NRDC v. Train (9 ERC 1425, 2nd C1r. 1976),
EPA was directed to develop an air quality standard for lead. Additional
air quality standards with regard to other fractions may be developed
1n the future, depending on research and/or court action.
It 1s worthwhile to note that it is not anticipated that the current
PM standard will be rescinded or replaced 1n the next several years. It
may be supplemented but 1t will not be withdrawn. Attainment of current
PM standards should be the goal everywhere.
REFERENCES AND ADDITIONAL INFORMATION -
(1) Stelgerwald, B.J., Memorandum to Rober Strelow, "Fine Partlculate
Control Strategy," July 2, 1975.
(2) Padgett, J. , and Bachman, J., "Regulatory and Technical Control
Strategies for Fine Particles," given at June 1976 APCA Meeting, Portland,
Oregon, APCA Paper No. 76-30.07.
QUESTION - What ambient measurement techniques are acceptable for moni-
toring PM?
ANSWER - The hl-volume method is the Federal Reference Method (FRM) for
total suspended particulates. Since the air quality standard is defined
by the method, the hi-volume sampler is the only acceptable method. No
procedures for determining equivalency of alternative methods have been
developed, so all other methods are to be considered unacceptable for
determining attainment or status with respect to NAAQS.
REFERENCES AND ADDITIONAL INFORMATION -
40 CFR Part 50, Appendix B, Reference Method for the Determination
of Suspended Particulates in the Atmosphere (High Volume Method).
QUESTION - What 1s meant by the term "background concentration" and what
are typical values taken to represent "background"?
ANSWER - Background concentrations are defined' 1n 40 CFR 51.13 as follows:
IV-4
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For purposes of developing a control strategy, back-
I ground concentration shall be taken into consideration with
respect to particulate matter. As used in this subpart,
'background concentration' 1s that portion of the measured
I ambient levels of particulate matter that cannot be reduced
by controlling emissions from manmade sources; 'background
concentration' shall be determined by reference to measured
ambient levels of particulate matter in nonurban areas.
i Unfortunately, this definition reflects to some extent the prevalent
m variation 1n usage of the word "background," and hence contradictory
usage of the term continues. Under the first part of the last sentence,
1n which background is defined as the uncontrollable portion of PM,
EPA regulations provide for rollback calculations to ascertain the
degree of emission control necessary for the attainment of the air
m quality standards. The rollback formula:
ambient - standard
M reduction required = ambient - background
tacitly assumes that the background level is a lower limit below which
tt the ambient concentration cannot be reduced. On the other hand, in
air quality modeling efforts, the background is frequently defined as
| the difference between the measured concentrations and the calculated
g concentrations which includes Into background any source not Included
* in the Inventory used. In still other circumstances, an agency may
choose to regard as "background" any PM coming across the boundary into
their jurisdiction, regardless of whether that jurisdiction extends
| appropriately into nonurban areas.
^ Contradiction in the usage of the term background also arises from
* the latter part of the above citation referring to the actual measure-
ment of background. Following that concept, the background levels most
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IV-5
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often used 1n air quality reflect measurements of the ambient air
quality 1n some remote rural area; this may possibly be within the
county, AQCR, or state, depending upon the jurisdiction of the planning
agency; or may be very far away. Where possible, these measurements
are made upwind of the prevailing flow of air so as not to sample the
particulate contribution of the area. However, what these remote
monitors are actually measuring is not necessarily an uncontrollable or
nonmanmade level of PM. Rather, these measurements simply reflect the
particulate concentrations coming into the urban area, including not
only the natural, uncontrollable particulates but also man's contribution
to the nonurban particulate levels; these latter include emissions 1n
rural areas, particles transported from distant urban areas, and secon-
dary particulates. They can be broken down as follows:
1. Natural particulate - PM contributed solely by natural pro-
cesses and thus uncontrollable; Includes a global contribution, which
includes both primary and secondary particulates, and a continental
contribution, primarily from wind erosion of soil.
2. Transported particulate - PM levels that arise due to emissions
from man's activities in "upwind" urban and industrial areas; include
both primary and secondary particulates transported from one area to
another.
3. Local particulate - PM measured at nonurban monitors that 1s
contributed by emissions in rural areas and affected by the placement of
the monitor.
IV-6
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Thus, the term "background concentration" can have a variety of
p meanings. The control strategy developer and/or reviewer should be
aware of the possible variations and act accordingly.
'
I
Figure 4 provides a national view of PM levels at certain non- urban
sites for 1970 through 1973.
REFERENCES AND ADDITIONAL INFORMATION -
National Assessment of the Urban Particulate Problem, op. cit.
QUESTION - What 1s the Impact of traditional (stationary) sources on
" air quality?
ANSWER - Cities with heavy industrial activity have been found to have
o
citywlde PM levels averaging from 10 to 60 |ig/m above the levels of
M cities with little or no industry; sites particularly close to heavy
o
m industrial activity typically averaged up to 25 jjg/m higher than other
* industrial sites. Further, it can be shown that as source emissions
are controlled, ambient PM levels show corresponding decreases. For
example, in Buffalo, New York, the effectiveness of the stationary
g source control program can be seen 1n the Improvement that has occured
in ambient air quality levels. Average annual air quality levels at
I 3
eight sites located throughout the Buffalo area in 1969 were 130 )ig/m ,
3 3
fl with Individual sites ranging from 80 jjg/m to 229 pig/m . In 1974,
after control efforts were well underway (but not complete), the area-
J wide average for the same sites was 82 yg/m with an individual site
3 3
range from 58 yg/m to 121 jjg/m . (Annual Reports, 1973 and 1974, Air
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Pollution Control Division, Department of Health, Erie County, New
York.) These data Indicate the significant Impact of stationary source
emissions on air quality and the necessity of minimizing stationary
source emissions as an important part of any PM control strategy.
REFERENCES AND ADDITIONAL INFORMATION -
(1) National Assessment of the Urban Particulate Problem, op. cit.
* QUESTION - What 1s the impact of the most significant man-made fugitive
dust sources on air quality?
I ANSWER - The air quality impact of fugitive dust sources varies, depending
upon the specific fugitive dust source. Estimates have been made for
some fugitive dust categories. These include:
Reentrained dust - In an urban area, particulate matter accumulates
on the various city surfaces due to various mechanisms, including atmos-
pheric fallout. Especially heavy loads on streets can result from dirt
and mud carryout from unpaved parking lots and roads, spillage from
I
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. IV-9
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trucks, and sand and salt applied for snow control. This material can
then become entrained and at least temporarily suspended in the ambient
air due to (a) wind erosion, or (b) man's activities disturbing the
surface. The annual average Impact on residential monitors 1s estimated
3 3
at 10 to 15 jjg/m and 15 to 20 jjg/m at commercial and industrial sites,
respectively, but varies widely with traffic and monitor placement.
The composition of this component is mostly mineral matter.
Construction activity - Several sites, often center city commercial
sites, are hindered in meeting national standards by dust entrained from
construction sites of various types, including urban renewal, small
building construction, and highway and subway construction. Particu-
late matter emissions are generated by a wide variety of operations over
the duration of the construction, including land clearing, blasting,
ground excavation, and on-s1te traffic, as well as the construction of
3
the facility Itself. Annual average impacts of 10 to 20 pg/m are
common only if the construction is close to the monitoring site. Cities
with typical levels of construction were found to have citywide annual
average Impacts on the order of 1 to 3 ^g/m . Construction will gener-
ally elevate concentrations downwind from the site for distances of up
to 1/2 to 1 mile; the amount of increase 1s related to the level of
activity, type of activity, distance from the activity, and control
measures employed.
REFERENCES AND ADDITIONAL INFORMATION -
National Assessment _of the Urban Particulate Problem, op. cit.
IV-10
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QUESTION- (What is the Impact of mobile sources on air quality?
ANSWER - Partlculate emissions from mobile sources have generally
m been only lightly considered in past control strategies. Recent
studies have indicated that particulate emissions from such sources,
specifically rubber tire particles and automotive exhaust can be
significant. For example:
Rubber Tire Particles - This source varies with neighborhoods.
3
I Typical annual average impacts are 3 jug/m at residential sites and
3
5 jig/m at commercial and industrial sites. Sites located particularly
near heavy traffic averaged twice the levels at other sites.
Automotive Exhaust - This source also varies somewhat with neighbor-
hoods, with typical annual average concentrations of 3 jjg/m 1n reslden-
3
mm tial and 4 to 5 yg/m in commercial and industrial areas. This estimate
1s for the primary particulate only and is generally about 15 to 25
I percent lead. The value could be higher if measured close to heavy
traffic.
I REFERENCES AND ADDITIONAL INFORMATION -
0) National Assessment of the Urban Particulate Problem, op.cit.
(2) Lillis, E.J. , and Dunbar, D.R., "Impact of Automobile Particle
Exhaust Emissions on Air Quality", OAQPS, EPA, November 13, 1975,
unpublished paper.
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- iv-n
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QUESTION - How much ambient PM data are needed to Indicate that a SIP
needs to be revised, or to serve as the basis of a control strategy?
ANSWER - There 1s no absolute answer to this question. Measured air
quality data are considered the best evidence to Indicate that a SIP is
inadequate to provide for attainment of national standards and to serve
as the indication of the degree of control needed to provide for attain-
ment and maintenance of standards. However, lack of such data do not
preclude determination of SIP adequacy or control strategy development.
For PM, various simulation models exist which provide a mathematical
technique for estimating air quality concentrations 1n most areas. While
ambient PM concentrations should be available 1n most areas where national
standards may potentially be violated, models can be used to supplement
existing measured data or replace measured data when 1t is not available.
REFERENCES AND ADDITIONAL INFORMATION -
Air Quality Analysis Workshop Volume I - Manual. Prepared for EPA
by Argonne National Laboratory, Argonne, Illinois, EPA 450/3-75-080a,
Nov. 1975, Ch. 7.
QUESTION - Historically, what type of air quality trends have been observed
for PM?
ANSWER - On a national basis, general improvement has been observed in
annual PM levels since 1970.
IV-12
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I
The trends have been observed from a data base of approximately 1800
" monitoring sites which are located throughout the county and have
sufficient historical data for use in determining trends.
The general improvement 1n PM ambient air quality is continuing.
J| Recent trends since 1971 indicate a general improvement of 4 percent
_ per year. There have been some geographical differences with Northeast
and Great Lakes areas improving at even higher rates. Levels in some
of the Western states have been fairly stable, probably due to fugitive
(wind blown) dust and to some extent due to secondary particulates
£ caused by photochemical reactions in areas such as Los Angeles.
m This progress with respect to PM means that nationally 33 percent
fewer people were exposed in 1974 to annual mean levels 1n excess of
V the primary standard than were exposed in 1970. Further improvements
in PM air quality levels are anticipated, but the present rate of
J| progress may not be sustained since fewer traditional sources remain to
be controlled and since fugitive dust, re-entrained urban particulates,
and secondary parti culates are more difficult to control.
Even though Improvements have been made, a significant PM ambient
problem still remains. The most recent data (1975) show that approximately 50
I percent of the state and local monitoring stations have annual averages
in excess of the secondary annual PM air quality standard.
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I IV-13
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REFERENCES AND ADDITIONAL INFORMATION -
(1) National A1r Quality and Emission Trends Report, 1975,
EPA 450/1-76-002, Nov. 1976.
(2) Monitoring and A1r Quality Trends Report. 1974, EPA 450/1-
76-001, Feb. 1976.
QUESTION - What guidance is available with regard to locating and
operating PM monitors in the field to provide representative samples?
ANSWER - The proper siting of monitoring instruments and the proper
design of a monitoring network is crucial to collecting representative
samples. The subjects are addressed in detail in Guidance for Air
Quality Monitoring Network Design and Instrument Siting (Revised).
OAQPS No. 1.2-012, Sept. 1975. This document is comprehensive in
nature and describes various monitoring objectives, based on the
intended uses for the air quality data. The document contains guidance
for placement of the hi-vol monitor between 2 and 15 meters above ground
level, with at least 2 meters horizontal clearance from supporting
structures or other restrictions to air flow.
It is recognized that these guidelines have generally allowed flexi-
bility to State and local agencies in locating ambient PM monitors. Thus,
monitoring networks across the nation are generally termed "non-uniform."
More specific guidance on siting of monitors and design of monitoring
networks has been developed. The Agency's Standing Air Monitoring Work
Group has drafted Air Monitoring Strategy for State Implementation Plans,
EPA Report No. 450/2-77-010, June 1977. The purpose of this guidance 1s
to provide more uniform and accurate monitoring patterns to assure that
basic data needs of air pollution control programs are met and to ensure
IV-14
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I
I uniformity 1n the data collected throughout the nation. The results
B of this report suggest an Increase 1n the monitors Included 1n the
* Quality Assurance Monitor Program from the present level of 6 percent
to approximately 15 percent. It also calls for revision to 40 CFR
51 to reflect the diminished need for large quantities of data which
£ will not be needed in the control programs for ambient air quality
maintenance. These and other recommended revisions will be incorporated
" in a revised version of the Siting Guideline OAQPS No. 1.2-012, now
in preparation.
QUESTION - What 1s EPA policy on the use of correction factors for
| adjusting TSP h1-vol readings to allow for accumulation of particulate
^ matter during the static mode?
ANSWER - EPA has examined this Issue and does not feel that use of a
correction factor is appropriate at this time because:
(a) Studies conducted to date may not be reliable. All the
g studies were conducted over a short-time period (three months or less)
_ and none had any discussion or documentation of quality assurance pro-
* cedures used.
1| (b) The Environmental Monitoring and Support Laboratory Research
Triangle Park (EMSL-RTP) has embarked on a one year particulate sampling
J characterization study. This study will take a comprehensive look at
fc parameters affecting hi-vol measurements.
* Once the EMSL-RTP study 1s completed, this issue will be re-
tt examined. In the interim, if a control agency feels that the static
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mode contribution 1s significant they should be encouraged to service
the h1-vo! as soon as possible before and after the sampling day. EPA
recognizes that additional travel will be necessary. However, only
those sites which are essential for particulate matter attainment/main-
tenance decisions would need to be serviced immediately before and after
the sampling day. If the hi-vols were located with continuous monitors,
dally trips (or visits more frequent than once every six days) to the
site may already be agency practice and thus little additional travel
would be necessary.
REFERENCES AND ADDITIONAL INFORMATION -
Barber, Walter C., Memorandum to Directors, Air and Hazardous
Material Divisions, Regions I-X, "Correction Factor for Static Mode
Contribution to TSP Air Quality," May 17, 1977.
IV-16
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I
V
QUESTIONS CONCERNING DATA
I AND FUND UTILIZATION
QUESTION - To what extent does growth Information employed 1n plan
development have to be Internally consistent?
ff ANSWER - Growth Information employed 1n plan development where 40 CFR 51
Subpart D applies (A1r Quality Maintenance Regulations) must be in
| accordance with applicable AQM guidelines unless alternative techniques
are approved by the Administrator. Emissions must normally be projected
for the following categories:
I Industrial process activity.
Fuel consumption.
Transportation activity.
t Electricity demand.
Solid waste generation.
Miscellaneous emission-producing activity.
I These may be converted to emissions using emission factors. In addition,
the temporal and spatial distribution of these variables (e.g., when new
plants will come on line and where they will be located) is important
flj to the air quality analysis. In most situations, projections of these
parameters are not available or are available only on a cruder scale
I than needed for an adequate air quality analysis, especially in attain-
ment/malntenance problem areas. Reliance must then be placed on surrogate
" variables such as population, employment, land use, earnings, and others
that are projected with reasonable accuracy and precision and that can
then be transformed into growth factors for the desired variables. These
I surrogate variables are used to develop predicted growth patterns for
the future.
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One of the problems that the lead agency has 1n developing growth
factors is the reconciliation of the various planning outputs. In order to
use information from the various groups, it will be necessary to insure
that they are based on compatible assumptions and data bases. The need
for a coordinated effort on the part of the involved organizations is
reemphasized by this need for a unified projection plan upon which to base
the analysis. The question of how many alternative growth patterns
should be evaluated as part of the air quality analysis 1s answered by
the available resources.
However, 1t is difficult to get consistent projections because of
different time frames and data bases used by the various planning groups.
Transportation planning groups base their projections on various trans-
portation scenarios (e.g., highway development emphasis, transit emphasis,
etc.). Comprehensive planning groups may use land-use development
scenarios as the driving mechanism. These differences can result in wide
discrepancies in the projection of regional development.
Long-range planning has been carried out for many years in a number
of areas. The information required for the air quality analysis should
build on the experience and background of the planning groups that have
been involved 1n these activities. There are four federally-funded plan-
ning programs that should be able to provide some framework for the
projections. They are:
HUD 701 planning,
FHWA 3-C planning,
EPA 208 planning,
CZM planning.
The OBERS growth projections are also federally funded, and a good
source of overall growth data.
V-2
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I
There are, of course, numerous local and regional studies that can be used
to supplement this information. A detailed discussion of planning pro-
^ grains listed above can be found in Air Quality Analysis Workshop Volume I -
Manual , op. cit. , page 63.
The agency should evaluate all these projections, choose the most
accurate and reliable, and use these variables as a basis for all pro-
jections. Also, growth information employed in development of SIP
" revisions involving control strategies should be consistent with that
employed in the development of a Water Quality Management (WQM) program
under Section 208 of the Water Pollution Control Act Amendments of 1972.
This kind of consistency is usually not a problem if one reliable source
of growth information is used.
1 REFERENCES AND ADDITIONAL INFORMATION -
(1) Guidelines for A1r Quality Maintenance Planning and Analysis,
Vol. 3: Control Strategies. EPA 450/4-74-003, July 1974, (OAQPS No. 1.2-022).
Guidelines for Air Quality Maintenance Planning and Analysis.
Vol. 7; Projecting County Emissions (Second Edition), EPA 450/4-74-008,
1 January 1975 (OAQPS No. 1.2-026).
(3) Air Quality Analysis Workshop Volume I - Manual, op. cit. , Chapter 4.
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QUESTION - How could one utilize 208 planning funds for developing air
quality projections and subsequent plan development?
ANSWER - The use of 208 funds can be used to project air quality result-
ing from the implementation of Water Quality Management (WQM) programs.
Some specific activities which can be funded by 208 program funds include:
(1) developing common data bases for WQM and Air Quality Management
(AQM) programs, (2) development of comnon public participation programs,
(3) development of control strategies or measures that will achieve the
objective of both AQM and WQM plans, and (4) development of statutes,
regulations, or administrative procedures relating air, water and land
use. More information on specific uses, and EPA policy relating to the
interrelationship of AQM and WQM programs, can be found in the memo;
"Relationship Between Air Quality Planning and the State and Areawide
Water Quality Management Program." This 1s available in the OAQPS Guide-
line Series, OAQPS No. 3.0-022, November 15, 1976.
V-4
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I
VI
QUESTIONS CONCERNING MODELING
I
I
I
QUESTION - What mathematical diffusion models are recommended for
estimating ambient PM concentrations?
ANSWER - Various technical guidance has been prepared on available
I models, one of which is Volume 12 of EPA's Guidelines for Air Quality
Maintenance Planning and Analysis: Applying Atmospheric Simulation
I Models to Air Quality Maintenance Areas. (EPA 450/4-74-013, September
m 1974, OAQPS 1.2-031). Although the title specifically identifies
"maintenance" areas rather than "attainment" areas, this document can
be useful in selecting dispersion models for other strategy situations
except fugitive PM problems. The document contains a good summary
J| of the availability, advantages and disadvantages of individual simu-
m lation models.
The Guideline on Air Quality Models and Associated Data Bases
fl (Draft) was circulated by OAQPS to all Regional Offices for comment
in February 1977. Late that month EPA held a Specialist Conference on
8 the guideline and a report is in preparation. Following several public
f comment workshops and at least one comprehensive conference, the final
version of the guideline is expected to be Issued in early 1978. The
guideline will update the Volume 12 information.
A brief discussion of the more important models listed in Volume
( 12 and the guideline above follows.
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VI-1
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Models Available for Particulate Matter (Annual Average) - The
A1r Quality Display Model (AQDM) of the CUmatologlcal Dispersion Model
(COM) 1s used to evaluate control strategies for both point sources
and multi-source complexes. However, the Single Source (CRSTER) Model
1s perferred for analysis of point sources when they are analyzed
separately. With the approval of the Regional Administrator, other
models may be used 1n the following circumstances:
(1) If a more accurate or more detailed model 1s available for
simulation, especially 1f the region has major meteorological or
topographic complexities, that model may be used.
(2) If the meteorological or topographic complexities of the
region are such that the use of any available air quality model 1s
precluded, then the model used for strategy evaluation may be limited
to a Rollback Model.
Models Available for Particulate Matter (24-Hour Averages). -
Point source models which consider critical dispersion conditions
characterized by looping, fumigation, high-wind coning, limited mixing,
etc., are used to evaluate control strategies for Individual point
sources. Point source models other than those referenced shall be used
only with approval of the Regional Administrator.
RAM is recommended for use in evaluating control strategies for
multi-source complexes. If the resources required to operate RAM are
not available, then AQDM or COM may be used. AQDM or COM must be used
VI-2
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I
with procedures for the statistical conversion of averaging times as
| discussed by Larsen to convert annual average concentration estimates
m to 24-hour average concentrations; other similar statistical techniques
. for making this conversion may also be used. Only with the approval of
V the Regional Administrator may other models be used in the following
circumstances:
| (1) If a more detailed or more suitable model is available,
M especially in a Region which has major meteorological or topographic
complexities, that model may be used.
(2) If the meteorological or topographic complexities of the
Region are such that the use of any available air quality model is
Q precluded, then the model used for control strategy evaluation may be
g limited to a Rollback Model.
* (3) If a more accurate or more detailed model, e.g., the Valley
H Model, is available for simulation in a Region with major meteorological
or topographic complexities and the Regional Administrator judges 1t
J appropriate, the model may be used.
REFERENCES AND ADDITIONAL INFORMATION -
" (1) 40 CFR Part 51, Appendix A, Air Quality Estimation.
I (2) A1r Quality Analysis Workshop. Vol. I - Manual. Chapter 6,
"Model Procedures," EPA 450/3-75-80a.
Q (3) Strelow, R. , Memorandum to various RO Division Directors,
g Regions I-X, "Use of Dispersion Model Estimates to Identify Potential
A1r Quality Standard Violations," November 1, 1976.
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(4) Environmental Protection Agency. "User's Network for Applied
Modeling of A1r Pollution (UNAMAP)." (Computer Programs on Tape for
Point Source Models, HIWAY, CHmatologlcal Dispersion Model and APRAC-1A)
(NTIS PB 229771), National Technical Information Service, Springfield,
Virginia, 1974.
(5) Carpenter, S.B., et al. "Principle Plume Dispersion Models:
TVA Power Plants." J. A1r Poll. Control Assn.. Vol. 22, No. 8, pp.
491-495, 1971.
(6) Environmental Protection Agency. "Reviewing New Stationary
Sources." Guidelines for A1r Quality Maintenance Planning and Analysis,
Volume 10; OAQPS No. 1.2-029, (NTIS PB 237535/AS), Environmental Protec-
tion Agency, Research Triangle Park, North Carolina, September 1974.
(7) Novak, J.H. and D.B. Turner. "An Efficient Gaussian-Plume
Multiple-Source A1r Quality Algorithm." J. A1r Poll. Control Assn.,
Vol. 26, No, 6, pp. 570-575, 1976.
(8) Turner, D.B. and J.H. Novak, Memorandum to EPA Dispersion
Model Users, "Provisional Availability of RAM," August 11, 1976.
(9) Pooler, F. "Potential Dispersion of Plumes from Large Power
Plants." PHS Publication No. 99-AP-16. (NTIS PB 168790). Superintendent
of Documents, Government Printing Office, Washington, D.C., 1965.
(10) Smith, M.E., Ed. "Recommended Guide for the Prediction of the
Dispersion of Airborne Effluents." The American Society of Mechanical
Engineers, New York, N.Y., 1968.
VI-4
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I
(11) Turner, D.B. "Workbook of Atmospheric Dispersion Estimates."
PHS Publication No. 999-AP-26 (NTIS PB 919482), Office of Technical
I Information and Publications, Environmental Protection Agency, Research
Triangle Park, N.C., 1970 (Rev.)
(12) Larsen, R.I. "A Mathematical Model for Relating A1r Quality
Measurements to Air Quality Standards." Office of Air Programs Publica-
tion No. AP-89 (NTIS PB 205277), Office of Technical Information and
Publications, Environmental Protection Agency, Research Triangle Park,
N.C., November 1971.
QUESTION - What EPA assistance is available for using the models in
Volume 12 and the Guideline A1r Quality Models?
ANSWER - The National Technical Information Service (NTIS), U.S. Depart-
I ment of Commerce, 5285 Port Royal Road, Springfield, Virginia 22161
(telephone 703-557-4650) stocks the following user's guides.
Model Access Number
AQDM PB 189-194
COM PB 227-346-AS
| PT (UNAMAP) Models PB 229-771
Copies can be obtained directly from NTIS. A computer card deck for the
AQDM program is available from EPA Office of Administration, Technical
Information Center, Research Triangle Park, N.C. 27711 (MD 35). More
specific assistance is available through EPA Regional Offices.
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Q.UEST_I01j - What techniques are available for fugitive dust modeling?
ANSWER.- The models currently available do not adequately consider
typical fugitive dust sources or the number of mechanisms involved
with fugitive dust. Typical Gaussian-type dispersion models do not
properly consider the physical characteristics or the emissions of un~
paved roads, storage piles, resuspended street dust or other fugitiva
dust sources. Nor do they consider gravitational settling or dry and
wet deposition of particulate matter, since all pollutants are treated
as though they were unreective gases. Gravitational settling and dry
deposition become increasingly important as the diameter of the particles
exceeds about 10 urn and become critically important when the particle
diameter exceeds 20 urn. Data from a number of studies indicate that
typical fugitive dust sources are difficult to precisely identify and
quantify. However, available data indicate that such emissions have a
large proportion of mass in the range of 20-70+ pm. Therefore, appli-
cation of conventional Gaussian plume models may be inadequate for air
quality evaluation where fugitive dust is a significant problem.
Thus, there is an immediate need for an analytical technique by
wrr,ch States may quantitatively identify fugitive dust sources, assess
their significance, and begin evaluating potential control measures. At
tne same time, the shortcomings of existing Gaussian dispersion models
riuSt be recognized. Ideally, one could adaot or modify the Gaussian
models such as AQDM or COM to explicitly consider fugitive dust sources
and the mechanisms of gravitational settling and deposition (both dry
and wet). Since these mechanisms are primarily a function of particle
diameter and density, this would also require development of a detailed
VI-6
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I
m Inventory which properly characterizes sources and stratifies emissions
by particle size. By utilizing this "particle-sized" Inventory with the
modified model, one could derive source-receptor relationships to be
used in evaluating alternative measures for control of fugitive dust and
8 1n planning SIP revisions.
m As an interim approach, the technique developed by TRW based upon
their work in Phoenix which is applicable to arid western locations 1s
I available. This technique used a modified CUmatologlcal Dispersion
Model (COM) to model fugitive dust emissions. Essentially, COM is a
regional model which accepts the emissions Inventory in the form of
m grldded input. Long term concentrations are obtained by inputting the
point frequency distribution functions of the surface winds. Turbulence
I 1s parameterized 1n terms of the standard Pasquill-Glfford Scheme.
Recognition of the diurnal variation in mixing layer height is made by
an algorithm which assigns a separate height for each stability class.
m Also, the variation in the horizontal wind with height 1s modeled according
to the wind power law. Pollutant removal, by whatever means such as
I coagulation, sedimentation, Brownian diffusion, is handled only in a
gross way through an exponential decay term.
I COM 1s useful for particles of a size governed primarily by dis-
M persion forces, but not useful for the larger particles where gravitational
settling becomes the dominant force. Because of the deposition problems
associated with fugitive dust, 1t was necessary to treat emissions from
local sources 1n the air quality modeling effort differently from those
I
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VI-7
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area wide sources with smaller particle sizes which COM could repre-
sent accurately. To facilitate this modified modeling approach, the
emissions model was altered so that it would prepare a gridded inventory
for each of four particle size ranges. The particle size ranges were
selected based on approximate cutoff points in dispersive behavior. The
four size ranges are as follows: 0-10 microns; 11-20 microns; 21-70
microns; and greater than 70 microns. Although the inventory techniques
are rudimentary, they do provide a first-approximation of the level and
significance of various sources of fugitive dust. Thus, the TRW tech-
nique combines use of COM (modified to account for deposition of 11-20
;jm particles) with a parameterization of the air quality impact of
particles larger than 20 pm using measured PM data and several key
assumptions. The nature of these assumptions imposes severe limitations
on the use of this technique as a predictive model. However, the TRW
technique for western U.S. locations if properly applied can be useful
to:
(1) Assess the relative importance of the fugitive dust problem.
(2) Assess the need for additional stationary source control in
the context of the overall problem.
(3) Give a preliminary evaluation of the potential impact of
various fugitive dust control measures. This evaluation could give a
preliminary assessment of the likelihood of attainment/maintenance and
an initial screening of those fugitive dust control measures which
appear most promising for further evaluation.
VI-8
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I
Work is also progressing to refine techniques which will be appli-
cable to those locations where the TRW technique may not be expected to
J yield adequate results, i.e., areas where traditional emissions are
responsible for major air quality Impact. Source receptor relationships
incorporating findings from a GCA study of urban particulate problems
have been Investigated and additional guidance is available in that
report (Volume III of reference 1 below).
| REFERENCES AND ADDITIONAL INFORMATION -
(1) An Implementation Plan for Suspended Particulate Matter in
the Phoenix Area. Volumes I-IV, (EPA-450/3-77-021a-d), Prepared for
EPA by TRW, Redondo Beach, California, August 1977.
(2) Guidelines for Development of Control Strategies in Areas With
I Fugitive Dust Problems. OAQPS Guideline Series, OAQPS No. 1.2-071,
Draft, April, 1977.
QUESTION - What techniques are available for fugitive emissions modeling?
ANSWER- Similar drawbacks to these just discussed for fugitive dust apply
to modeling of industrial process fugitive particulate emissions techniques
I with respect to gravitational settling, dry deposition and wet removal
of PM. Dispersion modeling, although usually less expensive than field
measurements, has associated with 1t the problems of (1) Inadequate
handling of physical interferences, (2) lack of complete data needed for
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I VI-9
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the model, and (3) lack of expertise 1n applying the model, all of which
can lead to poor estimates. These general problems of modeling are
compounded when dealing with fugitive emissions in a similar way to fugitive
dust since: (1) the emissions are not well defined (by location or rate),
and (2) where emissions are close to ground level , they may be effected
by gravity and may disperse in a non-Gaussian plume.
An existing dispersion model is presently being modified to consider
all fugitive emissions in an industrial complex and should be available
by late fall 1977. A review of present techniques to assess the impacts
of fugitive emissions can be found in Technical Guidance for Control of
Industrial Process Fugitive Particulate Emissions (EPA 450/3-77-010),
March 1977. This document reviews state-of-the-art emissions measuring
techniques and methods for determining empirical source-receptor relation-
ships based on upwind-downwind monitoring programs. Simplified dis-
persion modeling techniques are presented for preliminary assessment
of air quality impact in the short term. These techniques will not
completely account for the complicating factors mentioned before
such as multiple sources or non-Gaussian dispersion, but win help with
estimates until the modified model is completed.
REFERENCES AND ADDITIONAL INFORMATION -
Technical Guidance for Control of Industrial Process Fugitive
Particulate Emissions. EPA 450/3-77-010, March 1977.
VI-10
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VII
QUESTIONS CONCERNING CONTROL TECHNOLOGY
QUESTION - What is "Reasonably Available Control Technology" (RACT)
for stationary sources, and how is it determined for an individual
source?
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
I limitations attainable by various source classes and was 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, the availability of complying fuels, or the like. In
other instances, if an attempt is made to apply the same emission
limit to all sources regardless of the specific situation, one may in-
hibit the application of better controls that may be quite achievable
for a specific source at a specific location. Further, it is the air
^ quality that determines the degree of control necessary in order to
attain the NAAQS. Thus, similar sources may be treated differently
in different areas because the reductions in air quality necessary to
I meet the NAAQS will vary, depending on the severity of the air quality
problem. In some instances, the SIP may not require controls that
I
I VII-1
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I
are at the limit of achievable technology. Under the requirements of
the Clean Air Act Amendments of 1977, controls must be applied at the
level which will result in attainment before 1983. For these reasons, I
a flexible procedure for determining the RACT for various areas is
appropriate,
With respect to individual point sources with defined emission A
points (i.e., those amenable to the application of control equipment)
reasonably available control technology (RACT) defines the lowest emis-
sion limit that a particular source is capable of meeting by the appli-
cation 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. The determination of RACT will vary I
from source to source due to source configuration, retrofit feasiblity,
operation procedures, raw materials, and other characteristics of an
individual source or group of sources.
QUESTION - What guidance is available or is being prepared to assist in
determining reasonable available control technology for specific sources? I
ANSWER - Various efforts have either been completed or are underway to
document reasonably available control technology for existing sources.
1. Technical support documents are available for those sources
for which new source performance standards have been promulgated. Work
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VII-2
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I
1s continuing on the standards support and environmental Impact state-
ment documents (SSEIS) for many other sources. These SSEIS documents
| contain the results of technical Investigations and the recommended NSPS.
They serve as valuable reference documents 1n defining RACT for existing
* sources. It should be noted that similar technical support documents
have been prepared for those sources affected by national emission stan-
dards for hazardous pollutants. To date such standards have been pro-
| mulgated for asbestos, beryllium, and mercury and vinyl chloride. The
m technical support documents associated with these hazardous pollutant
standards are also a source of Information to assist 1n defining RACT.
A 2. A contract effort has been recently completed which defines
available control technology for particulate matter from oil-burning
| boilers and furnaces. Control measures and procedures for reducing par-
ticulate emissions from oil-burning Indirect heating plants are described
for residential, commercial, industrial, and power plant sources. (Refer-
ence 1.)
3. A contract has been completed that describes available control
| technology for approximately 40 particulate matter source categories. The
_ source categories are assessed according to (a) typical plant size and
associated emissions, (b) applicable control equipment efficiency, and
(c) potential for compliance with new source performance standards and
the most and least restrictive SIP regulatory limitations. The document
J presents data typical of current emissions and control techniques. It
_ is envisioned that this document will be useful for agencies faced with
revising a SIP by identifying source categories where controls may be
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I VII-3
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tightened. Once these categories have been Identified then other
references should be employed to determine exactly how much additional
control can be gained. (Reference 2.)
4. A contract effort has been undertaken to summarize all the
available information concerning fugitive emissions and provide a
guideline on Its control for use by the states in the development of
necessary revisions to the particulate matter control strategy. (Refer-
ence 3.)
REFERENCES AND ADDITIONAL INFORMATION -
(1) Control of Particulate Matter from Oil Burners and Boilers.
EPA 450/3-76-005, April 1976.
(2) Controlled and Uncontrolled Emission Rates and Applicable
Limitations for 80 Processes, Prepared for EPA by the Research Corpora-
tion of New England (TRC), Contract No. 68-02-1382, Sept. 1976.
(3) Technical Guidance for Control of Industrial Process Fugitive
Particulate Emissions. EPA 450/3-77-010, March 1977.
QUESTION - How significant are emissions from oil-burning facilities,
and how can emissions from such sources be minimized?
VII-4
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I
« ANSWER - In a recent study of partlculate pollution 1n five cities 1n
" which more than one-third of the dwelling units used fuel oil, it was
found that ambient partlculate levels on an annual basis resulting from
fuel oil combustion ranged from 8-13% of the mass on the hi-vol filter.
I The study further concluded that in midwestern cities, where coal 1s
_ used significantly, even very major oil-fired combustion units, such as
utility boilers, have in some cases been Ignored as sources because
they are cleaner than equivalent coal-fired units.
There is a significant range in the stringency of emission regula-
tlons applied to combustion sources 1n general, and one of the areas
where there is room for further reductions in emissions 1s residential
space heaters. Virtually all of these sources burn oil and are controlled
only by visible emissions enforcement, if at all. The degree of which
these sources contribute to the PM problem 1s not yet clearly defined.
| Several control measures were evaluated for residential, com-
_ mercial, Industrial and utility size oil burners during a recent study,
Control of Partlculate Matter from Oil Burners and Boilers (EPA 450/3-76-005,
April, 1976). The study contains an extensive review of the literature
and presents possible partlculate control measures for the residential,
jj commercial, Industrial and utility categories. As an example, possible
_ control measures for utility size boilers and furnaces Include such
general approaches as improved burner servicing, equipment design
changes, and fuel additives. Tables presenting similar Information
I
for residential, commercial, and industrial oil fired burners and
boilers are Included in the report.
VII-5
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REFERENCES AND ADDITIONAL INFORMATION -
(1) National Assessment of the Urban Particulate Problem, op. cit.
(2) Control of Particulate Matter from 011 Burners and Boilers,
Prepared for EPA by the Acurex Corporation, Mountain View, California
94040, EPA 450/3-76-005, April 1976.
(3) Pace, T.G. , "Impact of Energy Conversion Processes on Participate
Matter Air Quality," presented at 1976 Energy and Environment Conference,
Cincinnati , Ohio.
QUESTION - Must any particular emission measurement test method be
prescribed as the test method for determining compliance with State
adopted emission limitations for particulate matter?
ANSWER - No. Under the State Implementation Plan process, States have
the flexibility to determine the emission test method they will use to
determine source compliance with adopted emission limitations. States,
however, must define the specific test method which they will use to
determine source compliance with adopted emission limitations. This is
necessary for two reasons. First, it is necessary so that the anticipated
emission reduction that will result from source compliance with the emis-
sion limitation can be determined to assess whether the control strategy
is adequate to provide for attainment of national standards. Secondly,
it is necessary to identify the specific test method because differences
between test methods may allow more particulate matter emissions to be
captured by one method versus another method. If the test method were
not prescribed, then a conflict could exist as to whether test data using
one method which showed compliance with the standard as more valid than
test data using a second test method which indicated noncompliance with
the emission limitation. In cases where States do not specifically
VII-6
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I
B Identify a test method 1n their State Implementation Plan, EPA will use
EPA emission test methods to determine emissions and source compliance,
I where necessary. 40 CFR 52.12(c) provides that "For purposes of Federal
Q enforcement, emissions from sources subject to provisions of a plan
which did not specify a test procedure. . .will be tested by means of
the procedures and methods prescribed 1n the appendix to Part 60 of this
title, and emissions from sources subject to approved provisions of a
I plan wherein a test procedure was specified will be tested by the
g specified procedure."
QUESTION - What potential control measures have been identified for con-
structlon sources?
ANSWER - The control of dust from construction activities is often
| approached through the use of "nuisance" or reasonable-precaution regu-
g latlons. Control measures that can be applied include watering and
chemical soil stabilization. Watering produces an average control
efficiency of approximately 30%, and a 50% control' efficiency is feasible
with watering twice a day at the rate of 0.5 gallons per square yard.
I Chemical stabilization can produce a reduction of approximately 80% to
_ 85% in emissions. Several commercial chemicals have demonstrated strong
binding or crusting properties which are effective as long as the area
is not exposed to traffic.
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VII-7
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Another control measured to minimize emissions from construction
activities is one of minimizing the exposure time that cleared earth
may be exposed before construction activities begin. In some areas,
there is a frequent practice of clearing vast plots of land many
months before construction activities actually begin. Regulations
which limit the exposure time can reduce fugitive dust emission in
such cases.
Another control option includes reducing the amount of material
from a construction site that may get on streets 1n the vicinity of
the project where it can become resuspended. To minimize this problem,
various control mechanisms are available. One way is to require all
vehicles leaving the construction site to be cleaned in such a way
that they will not carry out loose soil and deposit it on the streets.
A second option is to require the operator of the construction site
to frequently clean the streets in the vicinity of the project,
perhaps daily.
REFERENCES AND ADDITIONAL INFORMATION -
(1) Investigation of Fugitive Dus.t. Volume I - Sources,
Emissions, and Control. EPA 450/3-74-036a, June 1974.
(2) An Implementation Plan for Suspended Particulate Matter in
the Phoenix Area (TRW. Inc.) Interim Report, Emissions Inventory,
May 1976.
QUESTION - What control measures are available to minimize fugitive
dust from unpaved roads?
VII-8
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I
ANSWER - Five control measures have been Identified: paving, surface
| treatment with penetration chemicals, application of soil stabilization
« chemicals, watering, and traffic controls. Paving 1s the most expen-
sive and effective measure, however, a benefit of paving is the elinrina-
tion of routine maintenance costs for blading and regrading unpaved
roads.
| Initial surface chemical treatment for dust suppression is relatively
g Inexpensive, but no treatment material has been found which remains
effective for more than two months under normal traffic conditions.
Penetration chemicals, worked into the roadbed to a depth of two
to six inches, are a good interim control measure, because they create
| a base for paving. The cost of this measure approaches the cost of
_ paving.
Watering is not feasible because of the high frequency of treatment.
fl In special cases, such as at construction sites, it may be appropriate.
Some comparisons of costs among various methods have been performed
I which address various options among paving and chemical stabilizing
_ measures including various combinations of traffic control measures, as
shown in the table below:
I
CONTROL TECHNIQUES FOR UNPAVED ROADS
Control Cost
Control Method Efficiency (%) ($)
Paving 3" bituminous surface 85 20,000 - 26,000/mile
I Paving, single chipseal on prepared
roadbed 50 8,500 - 14,000/mile/yr
Soil stabilization chemicals worked
. into the roadbed 50 5,000 - 12,000/mile/yr
Source: Investigation of Fugitive Dust. Volume I - Sources, Emissions.
and Control, op.cItT, pages 4-29.
I ~
VII-9
I
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Traffic controls have a negligible cost and can be effective.
Controls on vehicle routing are more effective than speed controls,
because emissions increase at a rate more rapid than increases in
vehicle speed and vary in proportion to the number of vehicles on
the road. Dust emissions increase exponentially with vehicle speed
up to 30 mph. The table illustrates the dust emission rate at dif-
ferent speeds for a vehicle traveling over a typical dirt road in
the Phoenix, Arizona, area. Restriction of traffic from unpaved roads
is not feasible since almost all roads provide some necessary access.
DUST EMISSION RATE AT DIFFERENT VEHICLE SPEEDS
Speed of Emission ratea Degree of Emissl
Vehicle (mph) (lb/vehicle mi.) Reduction (%)
35
30
25
20
22
19
13
8.5
14
41
62
aBased on exponential increase (to the power) in emissions from 0 to
30 mph, and linear increase above 30 mph. the base line emission rate
(35 mph) was calculated, assuming the typical dirt road silt content
of 24%. (Emission factor in Supp. 5, Compilation of Air Pollution
Emission Factors. AP-42, p. 11.2.2).
For new roads, an effective control approach would be to require
that all new roads be paved within an urban area. This would tend to
minimize future growth of various fugitive dust sources.
VII-10
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I
REFERENCES AND ADDITIONAL INFORMATION -
(1) Investigation, of Fugitive Dust. Sources. Emissions, and
I Control. Volume I. EPA 450/3-74-036a, June 1974.
(2) An Implementation Plan for Suspended Participate Matter
I 1n the Phoenix Area, Draft Report, November 1976.
I
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I
I VIII
QUESTIONS CONCERNING THE CONTROL STRATEGY,
ITS DEVELOPMENT, AND ITS REVISION
I
QUESTION - What consideration should be given to the control of automotive
I emissions in the control strategy?
ANSWER - Automotive emissions of PM can contribute approximately 3 to 5
jjg/m per cubic meter to ambient PM levels. Emission testing studies have
shown that lead compounds comprise approximately one fourth of automotive
exhaust particulates. Thus, one would expect that if lead levels in gaso-
line were reduced or non-leaded gasoline were used, a corresponding 20 to
30% reduction in PM should take place.
However, Page D-29 of Supplement Number 5 of AP-42 indicates that
particulate emissions from automobile exhaust for leaded fuel are estimated
at 0.34 grams/mile while estimates of unleaded fuel are estimated at 0.05
I grams/mile. This represents an 85% reduction 1n particulate emissions due
to the removal of lead from gasoline for light duty vehicles. These data
appear contrary to the above information which indicates that lead comprises
approximately one sixth of total exhaust particulate emissions from the
automobiles. Other additives, such as bromine compounds, are Introduced
I into leaded gasoline to scavenge lead oxides which deposit on an engine's
pistons and cylinder walls. When lead 1s removed as an additive, therefore,
not only are lead related particles removed, but these other compounds
that also contribute to the particulate emissions are also eliminated.
I
I VIII-1
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Some Independent test results have Indicated that significant reductions
in exhaust particles mass emissions were observed under all test conditions
when tetraethyl lead and lead scavengers were removed from gasoline. A
reduction of 77%* with non-leaded fuel was observed under stabilized operat-
ing conditions, although a range of 40% to 93% reduction was observed under
various test conditions. Therefore, the 85% reduction in particulate
emissions from the use of non-leaded fuels seems to be substantiated.
Consequently, when EPA regulations controlling the lead content in
gasoline are implemented, a significant reduction in automotive emissions
should result. These regulations will reduce the average lead 1n gasoline
from the current level of approximately 2.0 grams per gallon to 0.5 grams
per gallon by 1979. Further reductions of lead in gasoline should result
as automobiles equipped with catalytic devices replace non-catalytic auto-
mobiles in use. Automobiles equipped with catalytic converters cannot
use gasoline with high lead contents (in excess of 0.05 grams per gallon)
since the lead would contaminate the catalytic device. Consequently, as
more new cars equipped with catalysts replace non-catalyst equipped cars,
automotive particulate emissions should be further reduced. These antici-
pated reductions in particulate emissions should be considered in SIP
plan development.
EPA's suggested procedure for determining lead emissions from mobile
sources will appear in the forthcoming publication, Supplementary Guidelines
for Lead Implementation Plans, scheduled for publication around March 1978.
* 200 test cycles were run in sequence. After the 30th test cycle, emission
reductions of PM stabilized at approximately 77 percent.
VIII-2
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I
REFERENCES AND ADDITIONAL INFORMATION -
| (1) L1llis, E. and Dunbar, D. , "Impact of Automotive Particle Exhaust
_ Emissions on A1r Quality," SIB, CPDD, OAQPS, November 13, 1975, unpublished
paper.
I (2) Supplement 5 for Compilation of A1r Pollutant Emission Factors
(Second Edition) (AP-42) OAQPS, April 1975.
| (3) "Fuels and Fuel Additives - Control of Lead Additives in Gaso-
_ line," (41 FR 12675) Sept. 23, 1976.
QUESTION - What potential control measures have been Identified for re-
entrained parti culates?
ANSWER - Three control options which have been suggested include:
I (a) Regulations which reduce the amount of material which gets onto
_ streets ,
(b) Increased and/or improved street cleaning procedures, and
(c) Reduction in vehicle miles travelled within areas affected by
such problems.
I While it is reasonable to regulate and prohibit material from getting
_ onto streets, these measures are probably ineffective by themselves 1n
resolving the problem. This is because they are generally temporary mea-
sures , such that control actions need to be implemented frequently. Further-
more, from an enforcement point of view they are generally resource- intensive
I and difficult to enforce. Street cleaning 1s another option frequently
suggested; however, data are available which indicate that more particles
may be available for resuspension after street cleaning than before when
the most common operated brush type sweeper is used to clean streets. VMT
I
reduction 1s theoretically available for appli cation ; however, 1t is an
extreme measure to implement without first investigating the effectiveness
VIII-3
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I
of the other approaches. Also, no data are available that show that reduc-
tlons 1n VMT will reduce PM levels. One study has suggested that the total
air quality impact from resuspension may result from only a relatively I
small VMT, such that proportional reductions in VMT may not improve air
quality accordingly. At the present time, an EPA study is under way in I
Kansas City to investigate various factors with regard to control of
resuspended material has been completed. This study, Control of Re-
entrained Dust from Paved Streets, July 1977, is available through the I
EPA Library, Research Triangle Park, NC 27711.
REFERENCES AND ADDITIONAL INFORMATION - |
(1) Dunbar, D. , "Resuspension of Particulate Matter," Standards
Implementation Branch, Control Programs Development Division, OAQPS,
March 15, 1976, unpublished paper. I
(2) National Assessment of the Urban Particulate Problem, op. cit.
QUESTION - What intergovernmental coordination and review are generally |
necessary in the development of SIP control strategies?
ANSWER - The Clean Air Act Amendments of 1977 require that strategies
that contain transportation controls, air quality maintenance plans, I
or requirements for preconstruction review of new sources, or strategies
pertaining to non-attainment requirements or prevention of significant |
deterioration must be reviewed under a process of consultation. This
process of consultation must include local governments, designated
organizations of elected local government officials and any Federal
land manager with authority over land to which the State plan applies.
Regulations governing the development of State plans of consultation |
I
VIH-4 I
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I
win be promulgated by the Administrator by February 7, 1978. This
new process of consultation will become effective for reviews conducted
after August 7, 1978.
Presently, Intergovernmental cooperation under 40 CFR 51.21
I requires provisions for cooperation in interstate regions, and provision
_ for cooperation among the various state and local agencies whose function
affects, or 1s affected by the SIP revision.
Where the revision is developed under 40 CFR 51, Subpart D, several
specific provisions for Intergovernmental cooperation are required. These
I provisions appear under Section 51.58 - AQMA plan: Intergovernmental
Cooperation. They are summarized as follows:
(1) Agency which is developing the SIP revision must be specified
by the State.
(2) The developing agency must ensure the continuous involvement
| of other agencies whose function will be affected by the SIP revisions
_ such as:
a. State A1r Pollution Control Associations, Departments of Trans-
portation, etc., local Air Pollution Control Districts.
b. Elected officials.
| c. Agencies responsible for areawide waste treatment management
_ planning under Section 208 of the Federal Water Pollution
' Control Act Amendments of 1972.
d. Other planning arms of the Federal government established in
the Department of Housing and Urban Development, Department of
J Transportation, Office of Management and Budget, etc.
I
VIII-5
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(3) The developing agency must coordinate with other planning
bodies substantially affected by the SIP revision to develop a procedure
for using common data bases, similar policy advisory bodies, public
comment policy, etc.
(4) Where SIP revisions are being prepared for adjoining areas,
such revisions must be coordinated.
(5) Office of Management and Budget A-95 review must be performed.
(6) The SIP revision must describe how the before mentioned coor-
dination was and/or will be carried out.
(7) Public Participation must be provided for the development of
the SIP revision.
Coordination with the agencies responsible for areawide waste treat-
ment management planning under Section 208 of the Federal Water Pollution
Control Act Amendments of 1972 is very Important because EPA will not
approve water quality management and air quality maintenance plans which
are in conflict.
Although the above provisions are mandatory only for 40 CFR 51, Sub-
part D actions (Air Quality Maintenance Regulations), they represent an
excellent guide to follow for all SIP control strategy revisions.
REFERENCES AND ADDITIONAL INFORMATION -
(1) Maintenance of National Ambient A1r Quality Standards - Summary
(41 FR 18382), May 3, 1976.
(2) Briedenbach, W. and Strelow, R., Memorandum to All Regional
Administrators, "Relationship Between Air Quality Planning and the State
and Areawide Water Quality Management Program; Eligible Uses of Section
208 Funds for A1r Quality Analyses," November 15, 1976.
VIII-6
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I
QUESTION - How should secondary particulate matter be considered in a
PM control strategy?
I ANSWER - Secondary particulates can contribute up to 50 percent of the
PM in an area. Knowledge of the relationship between the precursors of
I secondary particulates- sulfur oxides, nitrogen oxides, and organic com-
pounds is limited. We do know that they are almost always fine, and
the chemical composition of such fine particulates varies considerably
from one geographic area to another. Table 4 illustrates this variation.
It can be seen that the water soluble sulfates are the principal fine
I particulate component in the eastern United States, with organics and
mm nitrates relatively more important in western areas.
A comprehensive study of PM problems in Los Angeles, California
concluded that "To achieve the primary ambient air quality standards
for particulate matter, effort must be continued to control SOV, NOV, and
IX A
reactive hydrocarbon emissions from all sources..." Areas which have
mm attainment/maintenance problems for PM should be aware that under cer-
tain environmental conditions, emissions of gases such as SCL, NCL, and
I
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VIII-7
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TABLE 4- Regional Variation Major Chemical Classes Typically
Occurring as Fine Parti oil ate (Annual Arithmetic
Average Based on 1966-1968 NASN Data)
Regi on
East0
Mideastd
South
Mi dwest6
Mountain
Southwest
West Coast
so= a
(«g?m3)
18.9
14.6
10.0
5.9
3.4
4.4
9.4
BSOb3
7.8
7.3
7.8
5.3
4.7
5.5
8.9
N03 3
2.1
2.9
2.5
7.8
1.3
2.1
3.8
Pb 3
1.2
1.3
1.0
1.0
1.3
1.0
1.9
TotaJ
30
26
21
14
10
13
24
Measured NH^ partitioned to SOj, NO^
Benzene soluble organics, about 1/2 to 2/3 of total organics
cProvidence, R.I. to Washington, D.C.
Ohio, Michigan, Indiana, Illinois /*
*
Minnesota, Iowa, Nebraska, Missouri
Source: A.P. Alshuller, Principal Species in Atmospheric Fine
Particulate Matter, in Minutes of Meeting of U.S. EPA
Agency Air Pollution Chemical and Physics Committee,
Alexandria, Virginia, April 17-18, 1970. p. 15.
VIII-8
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I
reactive hydrocarbons can result 1n the formation of sulfates, nitrates,
and organic aerosols. Two approaches to the control of secondary par-
tlculates are (1) control of emissions of gaseous precursors to fine
particulates which account for the majority of fine particulate mass,
and (2) Control of the mechanisms which promote transformation of
gases to particles. Gaseous substances are converted to secondary par-
ti culates by a number of uncompletely understood mechanisms which
I involve atmospheric variables such as levels of other pollutants, humi-
dity, sunlight intensity, and temperature. Control of certain pollutants
may slow these reactions and reduce the amount of gases which form par-
ticulates. For example, aerosol formation appears to be accelerated by
photochemical activity. Hence, reductions in photochemical oxldant
levels would indirectly influence secondary particulate levels by reducing
the amount of gases which are transformed into aerosols. Since reactive
I HC emission reduction is the principal method of oxldant control, organic
aerosols would be both indirectly and directly affected by oxldant reduc-
tion programs. Although some benefit can be expected from controlling
I pollutants which influence aerosol formation mechanisms, many other
important variables, such as humidity, cannot be controlled. Thus, con-
trol of mechanisms which form particles in the atmosphere 1s likely to
be a supplement to control of direct precursor gases, rather than a com-
plete strategy. Additional understanding of aerosol formation mechanisms
I is needed.
I
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I VIII-9
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Whenever possible in these non-attainment areas, the air quality
samples should be chemically analyzed for secondary particulates. Where
these concentrations are high, the control of precursors of secondary
particulates should be considered in the control strategy.
REFERENCES AND ADDITIONAL INFORMATION -
(1) Stelgerwald, B.J., Memorandum to Roger Strelow, "Fine Partlcu-
late Control Strategy," July 2, 1975.
(2) Padgett, J. and Bachman, J., "Regulatory and Technical Control
Strategies for Fine Particles," Presented at the June 1976 APCA Meeting,
Portland, Oregon, Paper No. 76-30.7.
(3) H1dy, G.M. , Characterization of Aerosols in California, Final
report to the A1r Resources Board, State of California, Volumes 1-4,
1974.
(4) Position Paper on Regulation of Atmospheric Sulfates, EPA
450/2-75-007, September 1975.
QUESTION - How should fugitive dust sources be considered in the control
strategy?
ANSWER - A fugitive dust policy has been developed. The recommended
policy with regard to consideration of fugitive dust sources 1n SIP
control strategy development is as follows:
1. The major emphasis for fugitive dust control will center upon
urban areas. Rural areas should be encouraged to develop programs on
a voluntary basis at this time where 1t 1s determined by measured air
quality concentrations that some action may be desirable.
VIII-10
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2. In urban areas, an analysis should be made to Identify all
sources of particulate matter and to consider various measures that
might be used to reduce particulate emissions from both conventional
stationary and fugitive dust sources and determine what the impact of
such measures would have on ambient air quality. From this evaluation,
J an appropriate control program should be developed.
3. It 1s not recommended that unreasonable controls be implemented
which would cause severe adverse social or economic disruption.
4. In urban areas, control of fugitive dust at construction acti-
vities is reasonably available and should be required if needed to meet
I national standards or minimize the ambient concentrations greater than
national standards in urban areas. Also, reasonable efforts can be taken
to stabilize cleared land awaiting construction. Similarly, it is gen-
erally reasonable in urban areas to control fugitive dust from demolition
and similar activities, commercial driveways, parking lots, and truck
I parking areas. In urban areas where there is enough rain or water avail-
able, it may be reasonable to require owners of vacant lots to maintain
B some type of vegetative cover to minimize the potential for soil loss by
wind erosion.
5. In urban areas, fugitive dust control measures such as street
sweeping or street cleaning, paving of roads, stabilizing road shoulders
and roadways, requiring that new roads be paved, and constructing curbs
along roadways may be reasonable. Such measures should be considered
by the State, where needed, and adopted when they can be successfully
implemented.
I
I vm-n
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6. At the present time, 208 water planning agencies are considering
various techniques to minimize water runoff from "non-point sources"
which are similar to fugitive dust sources. In particular, dust which
collects on streets may be a water pollution problem as well as an air
pollution problem. Coordination of air management planners with water
management planners may be mutually beneflcal and 1s encouraged. See
reference for additional Information and page V-4 for a discussion of
this coordination.
7. In urban areas where fugitive dust contributes to violations
of national standards, existing stationary sources should generally be
required to apply all reasonable measures to minimize emissions if they
contribute significantly to the air quality levels in the area of question,
In such areas, a case-by-case determination of needed controls for sta-
tionary sources within fugitive dust areas is 1n order. (Note: Thus
all sources throughout an AQCR will not necessarily need to apply such
measures, but only those sources within the particular geographic area
where excursions of national standards occur and their impact is judged
to be significant.)
8. The calls for SIP revisions 1n July 1976 set July 1978 as the
deadline for submitting revisions to account for fugitive dust. Under
the Clean Air Act Amendments of 1977, this date has been changed to
January 1, 1979.
VIII-12
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REFERENCES AND ADDITIONAL INFORMATION -
I (1) Briedenbach, W. , and Strelow, R., Memorandum to all Regional
Administrators, "Relationship Between A1r Quality Planning and the State
I and Areawlde Water Quality Management Program; Eligible Uses of Section
208 Funds for A1r Quality Analyses," November 15, 1976.
(2) "Fugitive Dust Policy: New Source Review," CPDD-OAQPS, August
I 1, 1977.
I
I
QUESTION - How should ambient data collected during dust storms and other
unusual events be considered in a control strategy?
ANSWER - 40 CFR 51.12(d) provides that: "For purposes of developing a
I control strategy, data derived from measurements of existing ambient
levels of a pollutant may be adjusted to reflect the extent to which
occasional natural or accidental phenomena, e.g., dust storms, forest
fires, Industrial accidents, demonstrably affected such ambient levels
during the measurement period." The rationale underlying this policy is
the concept of "reasonableness" in control strategy development, in that
strategies based on such unusual conditions would clearly be unreasonable.
I REFERENCES AND ADDITIONAL INFORMATION -
Guidelines for the Interpretation of Air Quality Standards. OAQPS
* No. 1.2-008, February 1977, (Revised).
QUESTION - How does the EPA new source review emission offset policy
affect SIP revisions?
I ANSWER - The Clean Air Act of 1970 required State Implementation plans
(SIPs) to Insure that National ambient air quality standards be attained
not later than mid-1975 (or 1977 if an extension has been granted). Since
I the statutory attainment dates established by the 1970 Act, have already
pased and the ambient standards have not been attained 1n many areas of the
I country, questions
VIII-13
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have arisen as to whether and to what extent new sources may legally
be permitted to construct in these areas. In answer to this question
EPA has developed an "emission offset" policy. Essentially, this
policy would allow construction of major new sources in areas of non-
attainment if, in the area of the proposed source, emission reductions
are obtained such that the total emissions from existing and proposed
sources are significantly less than emissions in the area prior to con-
struction of the new sources. This result might be reached by "off-
setting" reductions in emissions from existing sources for the emissions
of the new source, i.e., more stringent control of existing facilities.
The Clean Air Act Amendments of 1977 will change the use of the
offset policy before July 1, 1979. The offset policy may be waived
by the Administrator for any pollutant if the State review program meets
requirements as stated in the amendments. These requirements include
an inventory of emissions, an enforceable permit system which has emis-
sion limitations and control on existing sources incorporating reasonably
available control technology as a minimum, and a program to reduce
emissions prior to January 1, 1979, to provide reductions equivalent to
the reductions possible under the offset policy. This waiver can be
terminated by the Administrator if the requirements are not met.
For the period after July 1, 1979, the new Act requires as a pre-
condition for the construction or modification of major stationary
sources in nonattainment areas that SIPs in nonattainment areas provide
for attainment as expeditiously as practicable but not later than
December 31, 1982, for the primary standards. There are also additional
requirements specified in the Act for a new or modified major stationary
source to obtain a permit after July 1, 1979. These requirements appear
1n Section 173 of the Act.
VIII-14
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I
REFERENCES AND ADDITIONAL INFORMATION -
(1) Steigerwald, B.J., Memorandum to All Regional Administrators
I "Meeting to Discuss EPA New Source Review Policy in Non-Attainment Areas,"
October 28, 1976.
I (2) "Air Quality Standards; Interpretative Ruling", (41 FR 55525),
_ December 21, 1976.
QUESTION - How should the impact of stationary fuel switches under the
Energy Supply and Environmental Coordination Act of 1974 (ESECA) be
considered in control strategy development?
I ANSWER - Under ESECA, the Federal Energy Administrator (FEA) has authority
« to order facilities to switch from oil or gas to coal, but any such order
shall not become effective until EPA certifies that such plan or installa-
I tion will be able to comply with the applicable air pollution require-
ments. These requirements are the applicable State Implementation Plan
| (SIP). In practice, EPA requires, in 40 CFR 55.06(a), that sources ordered
_ to convert to coal submit to EPA (1) "A certification of the date that
the source will be able to burn coal and comply with all applicable air
pollution requirements," and (2) a plan for compliance which includes
the necessary steps the source must take to comply with all applicable
| air pollution requirements." Even 1f the affected facility 1s in an
_ area estimated to be a "nonattainment" area and/or 1s in an area covered
by a SIP which is suspected tp be or declared to be "substantially
inadequate," the only requirement which must be met is the applicable SIP.
Therefore, if a fuel conversion under ESECA is expected to be
| ordered 1n the area of concern for the control strategy, the strategy
I
VIII-15
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developer must evaluate the expected Increase 1n emissions which will
result from the conversion on a case-by-case basis and adjust the
overall strategy accordingly. Where the conversion causes a violation
of the NAAQS, a SIP revision would be called. This revision would be
handled like any other SIP revision.
In addition, the Clean Air Act Amendments of 1977 require States
to review the effects of fuel conversion in preparation for the SIP
revisions due in January 1979.
REFERENCES AND ADDITIONAL INFORMATION -
Energy Supply and Environmental Coordination Act of 1974 (ESECA),
Public Law 93-319, 93rd Congress, H.R. 14368, June 22, 1974.
QUESTION - What is the effect of malfunctions or breakdowns of control
equipment on ambient air quality and what 1s the present policy in
handling such periods in a control strategy?
ANSWER - Studies have indicated that under certain conditions a mal-
function or breakdown will effect ambient air quality. Present policy
toward including such periods as violations under enforcement pro-
visions shall be continued.
In the decision, as to whether notices of violation issued under
such conditions would be followed by any other action, the agency
would look at the following conditions stated 1n the April 27, 1977
Federal Register (42 FR 21473):
(1) The air pollution control equipment process equipment or
processes were at all times maintained and operated, to the maximum
extent practicable, in a manner consistent with good practice for mini-
mizing emissions.
VIII-16
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(2) Repairs were made as expedltlously as practicable Including
the use of off-shift labor and overtime.
(3) The amount and duration of the excess emissions were m1n1-
mlzed to the maximum extent practicable during periods of such emissions,
and
I (4) Bypass of strong S02 streams around acid plants was limited
to the maximum extent practicable.
If these conditions were met then it is present policy not to
I proceed with the implementation of criminal penalties.
There are many different State controls for malfunction or break-
down occurences, but there is no uniform manner to incorporate them into
m one control strategy for PM.
REFERENCES AND ADDITIONAL INFORMATION -
I Assessment of Particulate Attainment and Maintenance Problem, Vol.
1, Appendix A (GCA Report) Sept. 1976.
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IX
GLOSSARY
Aerosol - A dispersion of solid or liquid particles of microscopic
size in a gaseous medium, such as smoke, fog or mist.
Affected Fa elli ty - With reference to a stationary source, any apparatus
to which a standard is applicable.
A1r Quality Control Region (AQCR) - The basic geographic area on which
air pollution control strategies are formulated. The AQCR boundaries
are designated as much as possible to be consistent with the air shed
concept. That is, the sources in a given area theoretically share a
common air mass and the air quality Is a result of the emissions con-
tribution of all the sources in a given area. EPA, assisted by the
States, has devided the country into 247 AQCRs. A region may cover
only part of one State or it can Include portions of several States
which share a common air pollution problem.
Air Quality Maintenance Plan (AQMP) - A control strategy designed to
ensure that once an air quality standard 1s attained, pollutant levels
will not increase to levels that would again exceed the prescribed air
quality standard. An AQMP 1s part of the State Implementation Plan.
Background Concentration or Background Level - Ambient concentrations
which are caused by natural sources of pollution. In some cases, back-
ground may also include man-made pollutants advected into the area. Back-
ground 1s often used to denote those concentrations which are uncontroll-
able, either because they are of natural origin or because they are trans-
ported from another area not subject to the jurisdiction of the air
pollution control agency.
Best Available Control Technology (BACT) - The best available control
technology means an emission limitation based on the maximum degree of
reduction of each pollutant subject to regulation emitted from any
major emitting facility, taking into account energy, environmental,
and ecnomic impacts.
Control Strategy - Those activities and functions within a broader pro-
gram of air resource management that collectively are directed toward
the reduction of excessive emissions of pollutants; the regulatory
aspects of an air resource management program.
Emission Factor - An estimate of the rate of which a pollutant is
released to the atmosphere as a result of some activity such as com-
bustion or industrial production, divided by the level of activity.
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Emission Standard - A part of a legally enforceable regulation setting
forth an allowable rate of emissions Into the atmosphere or prescribing
equipment specifications for control of air pollution emissions.
Fugitive Dust - A type of partlculate emission made airborne by forces
of wind, man's activity or both, such as unpaved roads, construction
sites, tilled land, or windstorms.
Fugitive Emissions - Particles which are generated by Industrial or
other activities and which escape to the atmosphere not through primary
exhaust systems, but through openings such as windows, vents or doors,
m-f1tt1ng oven closures, or poorly maintained equipment.
Ground Level Concentration - The mass per unit volume of solid, liquid,
or gaseous material In mlcrograms per cubic meter of air, measured from
0 to 2 meters above the ground.
High Volume Sampler (Hi-Vol) - A device for collecting fine suspended
partlculate matter by drawing air through a filtering medium. The
Federal Reference Method for Total Suspended Particulates.
Model/ModelIng - A mathematical or physical representation of an
observable situation. In air pollution control, models afford the
ability to predict pollutant distribution or dispersion from identified
sources for specified whether conditions.
National Ambient Air Quality Standards (NAAQS) - A legal limit on the
level or atmospheric contamination necessary to protect against adverse
effects on public health and welfare. Primary standards are those
related to health effects. Secondary standards are related to protec-
tion against adverse welfare effect.
Opacity - The degree to which emissions reduce the transmission of light
and obscure the view of an object in the background.
Particle Size Distribution - The relative percentage of weight or
number of each of the different size fractions of partlculate matter.
Re-Entrainment - The resuspension in the atmosphere of particles from
streets, rooftops, etc., by wind, passing vehicles, or other such forces.
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Reference Conditions - EPA requires that all measurements of air quality
be corrected to a reference temperature of 25°C and to a reference pres-
sure of 760 millimeters of Hg (1,013.2 millibars).
Settleable Particulate - Partlculate matter which Is emitted Into the
atmosphere such that 1t may deposit onto horizontal surfaces due to
gravitational settling.
State Implementation Plan (SIP) - A document prepared by each State,
as required by^the Clean Air Act, describing existing air quality condi-
tions and setting forth a program to attain and to maintain National
Ambient Air Quality Standards and prevent significant deterioration of
air quality.
Suspended Particulate - Particulate matter which will remain airborne
for an appreciable period of time.
Source: Glossary derived from Appendix A of Technical Guidance for
Control of Industrial Process Fugitive Particulate Emissions
Prepared "by "^Ed'Co" Environmental, Inc., Cincinnati, Ohio,
EPA 450/3-77-010, Contract No. 68-02-1375.
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X
BIBLIOGRAPHY
AIR QUALITY MAINTENANCE GUIDELINES
A1r Quality Analysis Workshop, Volume I - Manual, Prepared for EPA by
Argonne National Laboratory, Argonne, 111., EPA 450/3-75-080a, Nov. 1975.
Guidelines for A1r Quality Maintenance Planning and Analysis, Volume
11, A1r Quality Monitoring and Data Analysis, OAQPS No. 1.2-030,
Sept. 1974.
Guidelines for Air Quality Maintenance Planning and Analysis, Volume
3 (OAQPS No. 1.2-022, July 1974), Volume 7 (OAQPS No. 1.2-026, Jan. 1975),
Volume 12 (OAQPS No. 1.2-031, Sept. 1974), Volume 13 (OAQPS No. 1.2-032,
Nov. 1974), Volume 13, Appendices A and B (OAQPS No. 1.2-032, March 1975).
"Maintenance of National Ambient Air Quality Standards," (40 FR_ 18382),
May 3, 1976.
AIR QUALITY ANALYSIS
Guidelines for the Evaluation of A1r Quality Data, OAQPS No. 1.2-015,
Feb. 1974.
Guidelines for the Evaluation of A1r Quality Trends, OAQPS No. 1.2-014,
Feb. 1974.
40 CFR Part 51, Appendix A, Air Quality Estimation.
Guidelines for the Interpretation of Air Quality Standards, OAQPS No.
1.2-008, Aug. 1974.
Monitoring and A1r Quality Trends Report, 1974, EPA 450/1-76-001,
Feb. 1976.
National Air Quality and Emission Trends Report, 1975, EPA 450/1-76-002,
Nov. 1976.
AIR QUALITY MONITORING
Designation of Unacceptable Analytical Methods of Measurement for Criteria
Pollutants, OAQPS No. 1.2-018, Sept. 1974.
40 CFR_ Part 50, Appendix B, "Reference Method for the Determination of
Suspended Partlculates in the Atmosphere (High Volume Method)."
Guidance for Air Quality Monitoring Network Design and Instrument Siting
(Revised), OAQPS No. 1.2-012, Sept. 1975.
X-l
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Strelow, R., Memorandum to various Division Directors, Regions I-X,
"Use of Dispersion Model Estimates to Identify Potential A1r Quality
Standard Violations," Nov. 1, 1976.
EMISSION INVENTORY AND MEASUREMENT
Guide for Compiling a Comprehensive Emission Inventory, EPA/APTD 1135,
March 1973.
Compilation of A1r Pollutant Emission Factors (AP-42), Second Edition,
with Supplements 1-5, Feb. 1976, with Supplement 6, April 1976.
"Emission Monitoring of Stationary Sources," (40 £R_ 46240), Oct. 6,
1975.
"Emission Monitoring Requirements and Revisions to Performance Testing
Methods," (40 FR. 46250), Oct. 6, 1975.
(40 FR 43850), Sept. 23, 1975, 40 CFR 60.273.
(41 FR_ 18502), May 4, 1976, 40 CFR 60.264.
PARTICULATE MATTER STANDARDS AND GENERAL STUDIES OF PARTICULATE MATTER
PROBLEMS
40 CFR_ Part 50.7, "National Primary and Secondary Standards for Parti-
culate Matter," April 30, 1971.
Air Quality Criteria for Parti oil ate Matter, AP-49, Jan. 1969.
National Assessment of the Urban Particulate Problem, Prepared for EPA
by GCA Corporation, Bedford, Massachusetts, EPA 450/3-76-024, July 1976.
Control of Particulate Matter from 011 Burners and Boilers, Prepared
for EPA by the Acurex Corp., Mountain View, Calif., EPA 450/3-76-005,
April 1976.
Controlled and Uncontrolled Emission Rates and Applicable Limitations
for 80 Processes, The Research Corporation of New England (TRC), Sept. 1976.
"Fuels and Fuel Additives - Control of Lead 1n Gasoline", (41 FR_ 12675),
Sept. 28, 1976.
1972 National Emissions Report, National Emissions Data System (NEDS)
of the Aerometrlc and Emissions Reporting System (AEROS), EPA 450/2-74-012,
June 1974.
Bernard Steigerwald/Delbert Barth Memorandum to Roger Strelow and
William Talley, "Revision of A1r Quality Criteria Documents," Aug. 26, 1976.
X-2
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Total Suspended Particulates: Review and Analysis, Prepared for EPA
by Radian Corporation, Austin, Texas, EPA 600/2-76-092, April 1976.
LHHs, E.J., and Dunbar, D.R., "Impact of Automobile Particle
Exhaust Emissions on A1r Quality," OAQPS, EPA, Nov. 13, 1975, un-
published paper.
Pace, T.C., "Impact of Energy Conversion Processes on Particulate
Matter A1r Quality," presented at the 1976 Energy and Environment
Conference, Cincinnati, Ohio.
Breidenbach, A.M., and Strelow, R., Memorandum to All Regional Adminis-
trators, "Relationship Between A1r Quality Planning and the State and
Areawlde Water Quality Management Program; Eligible Uses of Section 208
Funds for A1r Quality Analyses," November 15, 1976.
FINE AND SECONDARY PARTICIPATES
Steigerwald, B.J., Memorandum to Roger Strelow, "Fine Particulate
Control Strategy," July 2, 1975.
Padgett, J., and Bachmann, J. , "Regulatory and Technical Control
Strategies for Fine Particles," Presented at the June 1976 APCA
Meeting, Portland, Oregon, Paper No. 76-30.7.
Hitz, G.M., "Characterization of Aerosols in California," Final
Report to the A1r Resources Board, State of California, Volumes 1-4,
1974.
FUGITIVE DUST AND FUGITIVE EMISSIONS
mils, E.J., and Young, D. , "EPA Looks at 'Fugitive Emissions',"
Journal of the Air Pollution Control Association, 25:1015-1018, Oct. 1975.
Dunbar, David, "Resuspension of Particulate Matter," Standards Imple-
mentation Branch, Control Programs Development Division, OAQPS, March
15, 1976, unpublished report.
Investigation of Fugitive Dust, Volume I - Sources, Emissions, and
Control, Prepared for EPA by PEDCo Env. Specialists, Cincinnati, Ohio,
EPA 450/3-74-036a, June 1974.
An Implementation Plan for Suspended Particulate Matter in the Phoenix
Area, TRW, Inc., Draft Report, Nov. 1976.
Development of Emission Factors for Fugitive Dust Sources, Prepared
for EPA by Midwest Research Institute, Kansas City, MO, EPA 450/3-74-037,
June 1974.
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Technical Guidance for Control of Industrial Process Fugitive Parti -
culate Emissions. EPA Report 450/3-77-010, March 1977. Prepared
by PEDCo, Cincinnati, Ohio.
Guideline for Development of Control Strategies in Areas with Fugitive
Dust Problems, Draft Report, Prepared for EPA by TRW, Redondo Beach,
California, Nov. 1976.
SIP REVISION
Strelow, R., and Legro, S., Memorandum to All Regional Administrators,
"Agency Policy Regarding Calling for Plan Revisions to Approved State
Implementation Plans that are Substantially Inadequate to Attain
National Standards," Nov. 12, 1975.
Strelow, R., Memorandum to Regional Administrators, "Regional Air
Quality Attainment/Maintenance Activities," March 15, 1976.
Guidelines for Determining the Need for Plan Revisions to the Control
Strategy Portion of the Approved State Implementation Plan, OAQPS No.
1.2-011, Nov. 1975.
ENERGY SUPPLY AND ENVIRONMENTAL COORDINATION ACT
Energy Supply and Environmental Coordination Act of 1974 (ESECA),
Public Law 93-319, 93rd Congress, H.R. 14368, June 22, 1974.
NEW SOURCE REVIEW
Steigerwald, B.J., Memorandum to All Regional Administrators, "Meeting
to Discuss EPA New Source Review Policy in Non-Attainment Areas,"
Oct. 28, 1976.
CLEAN AIR ACT AMENDMENTS OF 1977
Public Law 95-95, 42 USC 7401, et seq.
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1 REPORT NO.
EPA 450/2-77-023
4 TITLE AND SUBTITLE
Control Strategy Preparation Manual for Particulate
Matter
3. RECIPIENT'S ACCESSIOf»NO.
5. REPORT DATE
Sept. 1977. Date of approval
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
Standards Implementation Branch
8. PERFORMING ORGANIZATION REPORT NO,
OAQPS No. 1.2-049
9. PERFORMING ORGANIZATION NAME AND ADDRESS
Environmental Protection Agency
Office of Air Quality Planning and Standards
Control Programs Development Division
Research Triangle Park, NC 27711
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS
13. TYPE OF REPORT AND PERIOD COVERED
Final
14. SPONSORING AGENCY CODE
200/04
15. SUPPLEMENTARY NOTES
16. ABSTRACT
This manual has been prepared to assist EPA, State and local agencies in the
task of developing control strategies for particulate matter (PM). The manual
Includes a general discussion of the technical aspects of control strategy develop-
ment under 40 CFR 51. The emphasis in the manual is on a brief review of pertinent
facts supplemented by references to generally available technical documents. Sub-
jects addressed include: Attainment of NAAQS; Procedures for review and develop-
ment of a PM control strategy; and Question and answer sections discussing parti-
culate emission sources and types, measurement methods, data and funds utilization,
modeling, control technology, and control strategy Issues. The manual also contains
a glossary and subject oriented bibliography.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.lDENTIFIERS/OPEN ENDED TERMS C. COS AT I Field/Group
Particulate Matter
Control Strategy Development
Control Technology Review
Emission Sources
8. DISTRIBUTION STATEMENT
Unrestricted
19. SECURITY CLASS (ThisReport)
unclassified
21. NO. OF PAGES
20. SECURITY CLASS (Thispage)
unclassified
J2L
22. PRICE
EPA Form 2220-1 (9-73)
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