EPA/450/2-81/0171
U.S. Environmental Protection Agency
Air Pollution Training Institute
COURSE 81:422
3rd Edition
AIR POLLUTION CONTROL
ORIENTATION COURSE
Unit 9
Air Quality Management
i
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United States Air Pollution Training Institute EPA 450/2-81-0171
Environmental Protection MD 20 June 1981
Agency Environmental Research Center
Research Triangle Park NC 27711
Air
APTI
Course S 1:422 3rd Edition
Air Pollution Control
Orientation Course
Unit 9
Air Quality Management
Prepared By: Under Contract No.
Northrop Services, Inc. 68-02-2374
P. 0. Box 12313 EPA Project Officer
Research Triangle Park, NC 27709 R. E. Townsend
United States Environmental Protection Agency
Office of Air, Noise, and Radiation
Office of Air Quality Planning and Standards
Research Triangle Park, NC 27711
This is one of nine self-instructional units in the
Air Pollution Control Orientation Course SI:422.
This unit consists of a cassette tape and this flip-
book, which you will use simultaneously.
Turn the page and read the tips on effective use
of this material.
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lipi tor .titective Use of This Material
1. Listen to the recorded script while you go through this flipbook. The recorded
portion is coordinated with the flipbook. Wait for the tape to finish the details
of one point before studying the next point on the page,
2. When you hear a "beep" on the tape, direct your attention to the next page in
the flipbook.
S. Pay attention to both words and picturesthey both convey important informa-
tion. The flipbook will usually summarize main points or give examples.
4. Stop the tape at any point if you wish to spend more time reading a page in the
flipbook. Rewind the tape if you wish to review a portion of the script.
5. Review the lesson objectives before answering the questions at the end of each
lesson. Ask yourself whether you have mastered the information indicated in the
objectives.
6. Answer the questions. They will help you assess your progress in mastering the
course materials.
7. Check your answers. The correct responses can be found on the page(s) follow-
ing the question page(s).
8. If you answer a question incorrectly, review the flipbook material covering the
subject matter. Now Turn On the Tape Recorder and Begin Lesson I.
n
Lesson I: Introduction to
Air Quality Management
Objectives
1. Define "air quality management" in general terms.
2. Name and describe the two most common approaches to air
quality management.
3. Name and describe the three types of standards applied in air
pollution control and state whether primary responsibility for
their enforcement belongs to federal or State government.
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Air Quality
Management
All activities directed
toward making our
air cleanand keeping
it that way
nnjmmnmmmm
Air Pollution Control
"Air Quality Management"
Approach
preparing criteria documents and establishing
ambient air quality standards
establishing emission limitations for specific
pollutant sources
setting up and operating enforcement systems
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Air Pollution Control
"Best Available Technology"
Approach
source owner or operator must use
the best control techniques available for the
control of emissions of pollutants
Types of Standards
In the National Program
National Ambient Air Quality Standards
New Source Performance Standards
National Emission Standards for Hazardous
Air Pollutants
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NAAQS
National Ambient Air
Quality Standards
specify maximum pollutant levels allowed in
the air surrounding a city, community
or region
set to protect public from adverse effects of
pollutants on public health and welfare
iimimwmniHMnuuuwmun
NSPS
New Source Performance
Standards
reflect the degree of emission limitation that
can be achieved by using the best available
technological system of continuous emission
reductions
cost and other factors taken into account
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NESHAPS
National Emission
Standards for Hazardous
Air Pollutants
set to control pollutants for which no NAAQS
have been set, and which may reasonably be
expected to cause or contribute to an increase
in deaths, serious irreversible illness, or
incapacitating reversible illness
Primary Enforcer Types of Air Quality Standards That
Programs are Designed to Achieve
NAAQS
National Ambient Air Quality Standards
NSPS
New Source Performance Standards
NESHAPs National Emission Standards for
Hazardous Air Pollutants
State responsibilities can be delegated to counties, municipalities,
or regional groups.
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When a State government has
responsibility for a control
function or program, it may
delegate authority to local govern-
mental bodies; however, the State
is still ultimately responsible for
the control functions.
Federal authority can be delegated
to State and local agencies.
niwwimmmnmiuwiwuwi
NAAQS
National Ambient Air Quality
Standards
The Clean Air Act requires EPA to collect and analyze data on
effects of pollutants.
n
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NAAQS
Criteria Pollutants
If a pollutant is detrimental to
public health or welfare, and arises
from many diverse sources, that
pollutant is classified as a criteria
pollutant.
Criteria must be published and stan
dards set for these pollutants.
12
ummmmimnimmuimnini
NAAQS
Documents
Air quality criteria documents con-
tain information on the effects of air
pollutants on health and welfare.
Control technique documents
describe the "state of the art" for
controlling emissions.
13
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M A AOS
Use of Documents
Air quality criteria documents are
used to derive National Ambient Air
Quality Standards.
Control technique documents are
used by states in development of
emission control regulations for
State Implementation Plans.
NAAQS
Criteria Pollutants
Sulfur Oxides Ozone
Nitrogen Oxides Carbon
Paniculate Matter Monoxide
Hydrocarbons Lead
This list is revised or updated as
necessary. 15
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NAAOS
Types of NAAQS
Primary
set to protect public health
Secondary
set to protect public welfare
16
mmmmmiunmmuumuim
NAAOS
State Implementation Plans
Since direct control of pollutants in the Strategies must be developed for control-
ambient air is not possible... ling emissions from pollutant sources.
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NAAQS
Whenever a new National Ambient Air Quality
Standard is adopted, each state
has 9 months to adopt and submit
a SIP
must provide for implementation,
maintenance, and enforcement of the stan-
dard
must provide for the review of new sources
18
MAAOS
If a state fails to produce or the EPA Administrator
all or part of an implemen- disapproves all or part of
tation plan a submitted plan
Then EPA has six months
to supply the necessary
parts or to develop an
implementation plan for
the state.
19
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NSPS
New Source Performance Standards
* Performance standards for certain
categories of large new stationary
sources of pollutants
20
NSPS
Federal New Source
Performance Standards
apply uniformly
nationwide. . .
but states may use their own
standards if they are at least
as stringent as the EPA
standards.
21
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NSPS
NSPS also apply to modification of
sources if the modified source will emit
more of a pollutant or emit a pollu-
tant that was not previously emitted.
22
unmmmmmmnnmumuim
NSPS
apply to sources which contribute significantly
to air pollution which causes or contributes to
the endangerment of public health or welfare
state the degree of emission limitations that
can be achieved through the application of
the best technological system for continuously
reducing emissions taking into account cost
and other environmental, health, and energy
impacts.
23
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HSPS
While states must review and approve
construction plans for proposed new
facilities, EPA is authorized to review
construction plans only upon request
from the source owner or operator.
24
NSPS
Til
If emissions from a proposed new
facility will violate emission standards
or interfere with the attainment or
maintenance of National Ambient Air
Quality Standards or cause significant
deterioration of existing air quality,
the state should deny the new facility a
permit to construct.
25
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NSPS
Additions or Changes
appear in Federal Register
first, as proposals for public comment
later, as EPA legal declarations
included in Code of Federal Regulations,
Title 40, Part 60
26
NSPS
Enforcement Responsibility
Primary responsibility for ensuring
compliance rests with EPA (which may
delegate this authority to State or local
agencies see SI:422 Enforcement
Systems).
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NSPS
Owner or Operator must:
1. notify EPA within 30 days after beginning construction or modification,
2. notify EPA 30 to 60 days before the anticipated start-up of operations,
3. notify EPA of the actual start-up date within 15 days after starting,
4. conduct performance tests according to methods approved by EPA within 6
months of the start-up date,
5. notify EPA of the test date at least 30 days in advance so that an EPA observer
can be present, and must demonstrate to EPA that the facility operates in com-
pliance with Federal emission standards,
6. provide some of the performance test facilities, such as sampling ports, plat-
forms, and other structures,
7. permit EPA officials to conduct tests at any reasonable time, and
8. conduct continuous emission monitoring on certain source types.
28
NSPS
State must review construction plans for any
new facility subject to emission performance
standards. This includes all sources subject to
NSPS, and usually other sources as well.
State must assess potential interference with
the attainment and maintenance of NAAQS
or other air pollution control requirements.
State must deny permit to construct if proposed
source would violate any requirements.
29
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NESHAPS
National Emission
Standards for Hazardous
Air Pollutants
set for air pollutants for which no NAAQS
have been set and which may reasonably be
anticipated to cause or contribute to an
increase in deaths, serious irreversible illness,
or incapacitating reversible illness
30
mmnnnnnuiiivnuummmm
NESHAPS
Hazardous Pollutants
Asbestos Benzene
Beryllium Mercury
Vinyl Chloride
Newly designated hazardous pollutants
will be listed in the Federal Register
and become part of the Code of
Federal Regulations.
31
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^B^B ^^^T ^^^T ^L^H ^H^& ^^^^B ^^^T ^^^^^^^^^^^^^^^^^^MMMMMMMMHU^W
The EPA Administrator
must propose nationwide
emission limitations for
both new and existing
sources that emit hazardous
pollutants.
32
ummnnrnMiiiiumimuinm
NESHAPS
EPA must publish the
standards after public
hearings, unless informa
tion presented at the
hearings shows that the
pollutant is not really
hazardous.
33
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NESHAPS
Owner or operator must obtain
EPA approval before construc-
tion or modification begins.
Existing sources must comply
with NESHAPS within 90 days
after a standard is set, unless
they obtain a waiver from EPA,
S4
(NESHAPS
Ensuring attainment of
NESHAPS is the responsibility
of the federal government.
Authority has been delegated to
some state or local agencies
but the federal government still
has primary responsibility,
should the state or local agency
fail to require compliance.
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EPA may
promulgate a stan-
dard regulating
design, equipment,
work practices, or
operations if it is not
feasible to specify
numerical emission
limits.
36
mmmrnimmmmtuutmum
If a State's air pollution control
requirements are not as strict as the
Clean Air Act requires, then EPA's
standards preempt the State's
standards.
37
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Lesson I
Questions
1. Give the term generally used to refer to all activities used to
make our air clean and keep it that way.
2. .Which of the following are common approaches to air quality
management?
a. national pollution control approach
b. PQSAD approach
c. best available control technology approach
d. air quality management approach
e. SLAM approach
f. air and water maintenance approach
38
3. Match each type of standard listed on the left with its
description.
i. National Ambient Air
Quality Standards
ii. National Emissions
Standards for Hazardous
Air Pollutants
a. reflect the degree of emis-
sion limitation that can be
achieved by using the best
available technological
system of continuous emis-
sions reduction taking cost
and other factors into
account
b. specify the maximum pollu-
tant levels which are
allowed in the air surroun-
ding a city, community, or
39
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(ii continued)
\\\. New Source Performance
Standards
region set to protect the
public from the adverse
effects of air pollutants
set to control pollutants for
which no other standards
have been set, and which
may reasonably be expected
to cause an increase in
deaths, serious irreversible
illness, and incapacitating
reversible illness
Answers on the next page.
40
nmmnmmiiiiiiuiuuuminn
Lesson I
Answers
1. air quality management
2. c,d. BACT approach and AQM approach
3. i. b
11. c
iii. a
After checking your responses, please turn on the tape recorder.
41
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Lesson II: Air Pollution Control Strategies
Objectives
1. Describe what is meant by the term "air pollution control
strategy".
2. List in sequence the ten steps in control strategy development
and describe each step.
42
Control Strategy
A list of actions which
must be carried out in
order to control air
pollution
43
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Objectives of Control Strategies
To attain and maintain NAAQS
To prevent significant deterioration of air
quality
44
Development of Control Strategies
Ten basic steps:
1. measurement of present ambient air quality and estimation of
future ambient air quality,
2. estimation of emission levels of existing stationary and mobile sources and pro-
jection of future emission levels,
3. determination of the degree of improvement needed to meet standards,
4. adoption of emission control regulations for various source categories,
5. development of emergency air pollution episode contingency plans,
6. negotiation to establish a legally enforceable compliance plan for air pollution
emergency episodes,
7. development of plans for long-term maintenance of air quality,
8. development of plans to prevent the significant deterioration of air quality,
9. implementation of air quality monitoring, and
10. initiation of enforcement action against violators of emission standards.
45
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Step 1
Measurement of present ambient air quality;
estimation of future ambient air quality
measurement of present air quality is obtained
by ambient air monitoring
estimation of future air quality is based upon
projections of growth in population, industry,
transportation, and the economy and upon
results of dispersion modeling
46
inmwnnmm
Step 2
Estimation of emission levels for existing
sources; projection of future emission levels
estimations and projections based upon emis-
sion inventories
two types of stationary sources
point source one concentrated source
area source large number of small, diffuse
sources
47
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StepS
Determination of the degree of improvement
needed to meet Federal standards
accomplished by comparing existing and pro
jected air quality
reduction needed usually estimated by using
modeling techniques
48
Step 4
Adoption of emission control regulations for
various source categories
takes into account control technology
currently available
establishment of registration/permit systems
49
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Step 5
Development of an emergency air pollution
episode contingency plan
air pollution episode adverse meteorological
conditions cause the concentration of pollutants
in the atmosphere to approach or exceed a level
that would endanger human health
50
Step 6
Negotiation to establish legally enforceable
compliance schedules for air pollution episodes
applies to all source categories affected by
emission control regulations and air pollution
episode contingency plan requirements
local agencies negotiate with local source
owners or operators
51
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Step 7
Development of plans for long-term
maintenance of air quality after attainment of
NAAQS.
includes
projection of population growth
projection of industrial growth
calculation of expected emissions
development of ways to allocate authorized
emissions for expected needs
development of ways to remain in compliance
with air quality standards
52
Step 8
Development of a plan to prevent significant
deterioration of air quality
concerned with the prevention of significant
deterioration in areas where the air is already
purer than required by NAAQS
high-priority areas where population and
industrial development are either non-existant
or minimal and dispersed
53
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Step 9
Implementation of air quality monitoring
an air quality management feedback step
continued surveillance of air quality and emissions
used to determine whether sources are complying
with standards
used to determine whether the control
strategies are appropriate for improving and
maintaining air quality
54
Step 10
Initiation of enforcement action against
violators of emission standards
violation notices
court injunctions
permit revocations
administrative orders
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Adoption of an effective control
strategy is necessary to achieve
NAAQS
Type of control strategy helps deter-
mine the laws, regulations, manpower,
and organizational structure required
56
Air quality management is a feedback
process. Information from one part of
the system is used in another part of
the system.
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Lesson II
Questions
1. Briefly describe what is meant by the term "air pollution
control strategy".
2. List in sequence the ten steps in control strategy development.
Answers on the next page.
58
Lesson II
Answers
An air pollution control strategy is a list of actions which
must be carried out in order to control air pollution in a
specific area.
1. measurement of present ambient air quality and
estimation of future ambient air quality
2. estimation of emission levels of existing stationary and
mobile sources and projection of future emission levels
3. determination of the degree of improvement needed to
meet standards
4. adoption of emission control regulations for various
source categories
59
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5. development of emergency air pollution episode con-
tingency plans
6. negotiation to establish a legally enforceable compliance
plan for air pollution emergency episodes
7. development of plans for long-term maintenance of air
quality
8. development of plans to prevent the significant deteriora
tion of air quality
9. implementation of air quality monitoring
10. initiation of enforcement action against violators of emis-
sion standards
After checking your responses, please turn on the tape recorder.
60
Lesson III: Implementation Plans and
Control Regulations
Objectives
1. Define "State Implementation Plan".
2. List and describe eight types of authority that a State must
have in order for EPA to accept its State Implementation
Plan.
3. Describe Federal treatment of disapproved implementation
4. Name the five basic types of source regulations often found in
State Implementation Plans.
61
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SIP I State Implementation Plan
legal document, formally adopted,
committing state to carry out its air
pollution control strategy
includes control regulations that are
both specific and enforceable
62
State Implementation Plans
1970
1972
- each state required to submit an SIP by early 1972
- all SIPs were disapproved to the extent that they did
not contain adequate provisions for prevention of
significant deterioration of air quality
1973 all states had submitted some sort of plan. Twenty state
plans approved. Defective parts of others replaced
by regulations issued by EPA.
1975 parts of all SIPs were disapproved because of their lack
of adequate provisions for long term air quality
maintenance
1977 specific updates and revisions required by
amendment to the Clean Air Act; to have been completed
by January 1, 1979
63
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State implementation plans must give the state air pollution
control agency authority to
1. Adopt and amend emission control regulations and other control measures
needed.
2. Enforce applicable laws, regulations, and standardsincluding those which pro-
vide for operation of a construction permit program with a fee system, and
those which authorize abatement actions on an emergency basis.
3. Prevent construction, modification, or operation of sources which would violate
air quality standards.
4. Require sources to keep records, and make inspections and tests to assess com-
pliance with emission standards.
5. Require sources to install and use monitoring devices and report on emissions.
6. Make pollutant emission data available to the public.
7. Prevent significant deterioration of air quality.
8. Operate a motor vehicle emission inspection/maintenance program in areas
where such is required.
64
Authority to Adopt Emission Control
Regulations
j^*--. -1*7*"^ ^ - - -,
Control Agency/
L
varies from state to state
varies in terms of which
agencies or persons hold
authority, and degree of
detail in requirements
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Authority to enforce applicable laws, regulations,
and standards and to require implementation of
episode control plans
includes authority to
seek injunctive relief from
the courts if a source refuses
to comply
66
I1J1111
Authority to prevent construction, modification,
or operation of stationary sources which would
cause violation of air quality standards
defines the need for a permit
or registration system
provides authority to obtain
information to evaluate
potential threat to air quality
may include authority to set
operating permit require-
ments for existing sources
Permit
to Operate
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Authority to gather information about sources to
assess compliance with emission standards, laws,
and regulations
includes authority to require
recordkeeping by sources,
make inspections, and con-
duct source tests
68
nmnv
Authority to require sources to install pollutant
monitoring devices and to report the data to the
control agency
Examples of monitoring devices are
opacity monitor
continuous sulfur dioxide monitor
Authority to operate a motor vehicle
inspection/maintenance program
must determine whether emission controls are
installed and working properly
must require correction of malfunctioning
control devices
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Authority to make emissions data available to
the public.
Control agency may make
data available in periodic
reports or in response to the
request of an individual or
group.
70
nnnmmm
Authority to prevent significant deterioration
of air quality which is cleaner than required
by the NAAQS
regulations for classification
of PSD area
provisions for review of
"new" sources
regulations/permits
requiring BACT
system for tracking use of
PSD increments
71
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.mm
Coae of Federal Regulations
Title 40Part 51
lists requirements for SIPs
Title 40Part 52
lists current SIPs and
EPA additions and
changes in the plans
sets out basis for EPA
disapproval of SIPs
without PSD provisions
outlines necessary
requirements for PSD
Handling of Disapproved Portions
of SIPs
nonregulatory portions EPA provides
detailed legal and technical evaluation, but
no substitute provisions
regulatory portions EPA issues regulations
to replace or fill-in deficient portions
73
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General State Emission Regulation
Philosophies
air quality management approach adopts
regulations to attain and maintain air quality
standards at a certain level
best available control techniques approach
adopts regulations to require all sources to use
the best available control techniques to reduce
emissions
74
nmmmn
Clean Air Act
requires all states to provide for
attainment and maintenance of
NAAQS, PSD, and reasonable
progress toward attainment in
nonattainment areas
75
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States may differ in
the stringency of
control regulations.
76
Five Basic Types of Source Regulations
regulations setting maximum allowable
emissions
operating equipment and control device
design regulations
regulations prohibiting use of certain types of
equipment
regulations banning certain operations
regulations specifying permissible and non-
permissible fuels
77
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Source
Regulations
Regulations Setting Maximum
Allowable Emission
some based on the quantity of pollutant emitted
(some in relation to the total amount of energy
or materials fed into or passing through the
process)
others based on limiting visible emissions in
the exhaust plume to a certain degree of
opacity
78
Source
Regulations
Operating or Control Equipment
Design Regulations
specify features relating to design use
of specified kinds of operating or
emission control equipment.
79
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Source
Regulations
Regulations Prohibiting Use of
Certain Types of Equipment
> apply to specified kinds of equip
ment such as single chamber
incinerators and teepee burners
80
mmmmmmmmmmmuun
Source
Regulations
Regulations Banning Certain
Operations
apply to operations such as:
open burning in a residential area
disposal of solvents by evaporation
air-blowing of asphalt without emission
control
81
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Source
Regulations
Regulations Specifying Permissible
and Non-permissible Fuels
most are intended to limit the sulfur,
ash,or volatile material content
of fuels
82
nnmmmimumiHiimmmui
SIPs
the legal expression of a State air pollution
control program
contain the State's regulations that are
specific and enforceable and other material
Clean Air Act and Federal regulations
require States to have specific air pollution
control authorities. These are incorporated
into the SIP.
83
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Lesson III
Questions
1. Describe what is meant by the term "State Implementation
Plan".
2. List eight types of authority that a state must have in order
for EPA to accept its State Implementation Plan.
3. Describe what happens when a State Implementation Plan is
disapproved.
4. Name the five basic types of source regulations often found in
State Implementation Plans.
Answers are on the next page.
84
iimmmmmiiinmmmuunu
Lesson III
Answers
1. A State Implementation Plan is a legal document, formally
adopted, committing a State to carry out its air pollution
control strategy.
2. Authority to:
1. adopt emission control regulations.
2. enforce applicable laws, regulations, standards, and air
pollution episode control plans.
3. prevent construction, modification, or operation of sources
violating air quality standards.
4. monitor sources to assess compliance with emission
standards.
5. require sources to install monitoring devices and report on
emissions. 85
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6. make available to the public criteria pollutant data.
7. maintain air quality that meets NAAQS.
8. prevent significant deterioration of air quality.
3. For nonregulatory portions, EPA provides a detailed legal
and technical evaluation but no substitute provisions. For
regulatory portions, EPA issues regulations to replace or fill-
in deficient portions of the plan.
4. 1. emission regulations setting maximum allowable emissions
2. operating equipment and control device design regulations
3. regulations prohibiting use of certain types of equipment
4. regulations banning certain operations
5. regulations specifying permissible and non-permissible
fuels
After checking your responses, please turn on the tape recorder.
86
inmmnmmi
t t
Lesson IV: Enforcement of Regulations
Objectives
1. Describe the legal basis for State air pollution control aeencv
enforcement authority.
2. Identify examples of the types of power given to State air
pollution control agencies by the legislature.
3. List and describe the basic steps in the enforcement of air
quality regulations.
4. List five alternative procedures for dealing with violations of
air quality regulations.
87
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State Air Pollution Control Agency Powers
special powers usually spelled out in an "enabling" act
passed by state legislature
usually consist of powers
to adopt emission control regulations
to be exercised in day-to-day situations
to be exercised during an air pollution episode
Day-to-day Powers
Authority to:
inspect facilities
conduct source tests
require plant owners or operators to submit
emission information
prohibit evasion of regulations
issue citations
stop motor vehicles that are operating with
excessive visible emissions
89
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Powers During
Air Pollution Episodes
Authority or right to:
adopt emergency emission standards stricter than those
normally in effect
require sources to submit plans for curtailment or shutdown
of emissions
prepare regulations restricting community activities
establish emergency communication systems between the
agency, selected industries, and the public
90
Enforcement of Air Quality Standards
scheduled inspection of new and existing sources
patrolling in the field to detect permit evasion or violation
source emission tests and continuous emission monitoring
negotiation of compliance schedules
initiation of legal action
follow-up inspection to check compliance
91
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imun
Field inspections
scheduled for
new sources under
permit systems
existing sources under
permit or registration
systems
other significant sources
92
Some sources are inspected more often than others..
Sources being
built under
construction
permits
«M M*MIT 1» OPMATI
Sources apply-
ing for permits
to operate
ICHtDUkt
a
Q
Q MAKCM
a AW!
O
Q
MAdCH
I AMML
93
Sources modi-
fying processes
according to
compliance
schedules
Other
sources of
significant
amounts of
pollutants
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Field inspectors patrol in the field looking for violations
excessive visible emissions
odor problems
constructing without a permit
operating without a permit
open burning
fugitive dust problems
94
innnnmrommmHuumumn
95
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If a violation of emission regulations
is suspected, an inspector will often
arrange for a source emissions test.
If a violation is found, there will be
negotiation.
96
iimmmnwiHUiuummmnii
Inspector informs
source owner or
manager about
regulations
Negotiation
takes place
Follow-up
inspections are
If negotiation
fails to bring
about compliance, made to
court action may determine
9? be taken to force compliance
compliance
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Enforcement Management System
maintains files on all sources
schedules field inspections and activities
supporting enforcement cases
keeps track of all cases in progress toward
abatement
98
Data systems play an important role in
enforcement
data analysis indicates degree of
achievement of emission goals
data are available for evidence in
court cases
99
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Procedures for Dealing With Repeated or
Continuing Violations
vary from State to State
include:
notices of violation
administrative hearings or conferences
abatement orders
revocation of operating permits
civil penalties
temporary injunctions stopping source operation
100
nnmmmnuiiiiiumumHnm
Notice of Violation
Formal notice
to source owner or operator
indicates alleged violation of regulations
may be first legal step in process leading to court action
101
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Administrative Hearing/Conference
Discussion between source management and
control agency
quicker, less expensive than court action
can lead to a compliance schedule
often effective in gaining compliance
clarifies issues
102
Administrative Order
Formal hearingmuch like a trial
Leads to administrative order
directs source to take specific action
sometimes suspends/revokes operating permit
103
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Court Action
Generally to seek an injunction to stop
source operation or a court order requiring
specific actions of source
Penalties for violations may be assessed
Contempt of court penalties available
104
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Civil Penalties
to remove economic benefits from continuing
in violation
105
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Remember
Agency's goal is to obtain compliance
Agency enforcement actions are
prescribed/limited by law
106
Lesson IV
Questions
1. Describe the legal basis for State air quality pollution control
agency enforcement authority.
2. Which of the following are types of power given to State
agencies by State legislatures?
a. right-of-entry to inspect facilities
b. right to conduct source tests
c. right to require plant owners or operators to submit
information on pollutant emissions
d. authority to issue citations
e. authority to stop motor vehicles operating with excessive
visible emissions
f. all of the above
107
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3. List the six basic steps in the enforcement of air quality
regulations.
4. List five alternative procedures for dealing with violations of
air quality regulations.
Answers are on the next page.
108
Lesson IV
Answers
1. Powers are given to the air pollution control agency by
the State legislature. These are usually spelled out in an
"enabling" act passed by the legislature.
2. f.
3. 1. scheduled inspection of new and existing sources
2. patrolling in the field to detect permit evasion or
violation
3. source emission tests and continuous emission monitoring
4. negotiation of compliance schedules
5. initiation of legal action
6. follow-up inspection to check compliance
109
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4. 1. notices of violation
2. administrative hearings or conferences
3. abatement orders
4. revocation of operating permits
5. civil penalties
6. temporary injunctions stopping source operation
After checking your responses, please turn on the tape recorder.
110
Lesson V: Air Quality Surveillance Networks
Objectives
1. Give the full name of and briefly describe the purpose of
SLAMS, NAMS, SPM, and PSD air sampling stations.
2. List three ways that a state can use data from an air quality
surveillance network.
3. Describe the area covered by each of the five spatial scales of
representativeness discussed in this lesson.
4. List the five general steps followed in the design of an air
quality surveillance network.
5. List factors that must be taken into consideration when
designing the data system for an air quality surveillance
network.
in
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Air Quality Surveillance Network
ultimate means for measuring effectiveness of
emission control strategy
uses variety of monitoring devices at a number
of sites
uses facilities for analyzing and storing the
collected data
112
Two Basic Components
monitoring sites with measure-
ment devices and personnel
113
facilities and personnel for
data recording, transmitting,
analyzing, storing, and
retrieving
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Designing Air Quality
Surveillance Networks
define purpose of network
assemble background materials
design sensor system
design data system
combine sensor and data systems
114
Define Purpose of Network
Judging attainment of NAAQS
Evaluating progress in achieving/maintaining
NAAQS
Developing/re vising SIPs
Reviewing air quality impacts of new sources
115
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Establishing baseline air quality levels for PSD
Developing/revising national control policies
Providing data for atmospheric dispersion
model development/validation
Supporting enforcement actions
116
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Documenting episodes and initiating episode
controls
Determining pollutant effect on public health
and welfare
Providing air quality information to the
public
117
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Assemble Background Materials
meteorological data, topography and land use
data, population distribution data, source
location and emission data, and legal and
administrative information
allows characteristics of each pollutant to be
considered when network is being designed
118
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Design Sensor System
What to monitor
How to monitor
How often to monitor
Where to monitor
119
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What to Monitor
Determined from monitoring objectives
Regulated pollutants
Non-regulated pollutants
120
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How to Monitor
Specified by State/local regulations
Specified by EPA reference and equivalent
methods
121
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How Often to Monitor
Determined from monitoring objectives
For example, judging attainment of NAAQS
Providing data for atmospheric dispersion
model development
122
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Where to Monitor
Determined from monitoring objectives
Determined from site characteristics
123
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Microscale
several meters to 100 meters
parking lots and unpaved roads
Middle scale
up to several city blocks
areas that people pass through but do not remain in to live
or workdowntown areas and major highways
Neighborhood scale
V£ to 4 kilometers
where people spend a lot of their time living or working
Urban scale
4 to 50 kilometers
a whole urban community
Regional scale
10's to 100's of kilometers
usually rural areas 124
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Factors to consider when selecting a
site include
availability
representativeness of spatial scale
accessibility
security
effects of topography, meteorology, and
nearby structures and sources
125
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Effects of Surrounding
Structures on Monitoring
of Carbon Monoxide
CO can build up in street
canyons. Thus an instrument
located near street level would
register an entirely different
concentration than would an
instrument on a nearby roof.
126
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in.
Sampling Probe
Placement
Based upon
monitoring objectives
type of pollutant
monitored
site conditions
127
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Probe placed to
avoid effects of
stirred-up dust
Choice of site for
probe placement
must be based upon
surveillance system
objectives.
Probe Placement for Most
Gaseous Pollutants
3 to 15 meters above ground
1 to 2 meters vertical/horizontal
clearance from support structure
129
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Design Data System
Recording
based on data
needs and
costs
often involve
choice between
manual and auto-
mated recording
Transmission
based on how
fast data are
needed
make system as
simple, efficient,
and inexpensive
as possible
Handling
format clear, well-
documented
storage secure,
systematic
retrieval secure,
efficient
analysis kinds
needed
ISO
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Combine Sensor & Data Systems
combine and integrate the
sensor and data systems
131
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Each state monitors pollutants for which
NAAQS have been established, following EPA
requirements.
EPA specifications include
minimum number of monitoring stations
kinds of locations of sampling sites
minimum sampling schedules
analytical procedures
auditing and quality assurance schedules
data handling
data reporting
132
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Monitoring Stations
State and Local Air Monitoring
Stations (SLAMS)
Special Purpose Monitoring stations
(SPM)
Prevention of Significant Deterioration
stations (PSD)
National Air Monitoring Stations
(NAMS)
133
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SLAMS
number and locations jointly determined by the State and
regional EPA office
Data reported to EPA in form of an annual summary
SPM stations
not SLAMS
not subject to any EPA requirements unless monitoring is to
support a SIP revision or to demonstrate a control strategy
PSD stations
SLAMS could serve as PSD stations, but PSD stations other-
wise not part of a SLAMS network
NAMS
locations designated by EPA headquarters
must report data quarterly to EPA
must use continuous monitors for gaseous pollutants 134
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SLAMS Network
Must meet 4 objectives
determine highest concentrations expected to occur
determine representative concentrations in densely
populated areas
determine effect of significant sources or source categories
on ambient pollution levels
determine general background concentration levels
135
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Appropriate Siting Scales
micro- middle neighbor- urban regional
scale scale hood scale scale scale
Monitoring Objectives
1. determine highest
concentrations
2. determine representative
concentration in high
population density area
3. determine impact of
significant sources
4. determine background
concentration levels
D D
B D
D
D D
D D D D
136
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Federal Guidelines for Selecting Spatial Scale
Spatial
scale
Scales applicable for SLAMS
TSP
SO2
CO
03
NO2
Scales required for NAMS
TSP
SO2
CO
NO2
Micro
Middle
Neighborhood
Urban
Regional
137
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For additional information on Federal
regulations for State air quality
surveillance networks, see the Code of
Federal Regulations, Title 40, Part 58.
138
nwwmmn
Lesson V
Questions
1. The following acronyms are used to refer to air monitoring
stations. What does each stand for?
i. SLAMS
ii. NAMS
iii. SPM
iv. PSD
2. List three ways that a state can use data from an air
surveillance network.
139
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3. Match the spatial scale of representativeness on the left with
the description of the area it covers given on the right.
i. microscale
ii. middle scale
iii. neighborhood scale
iv. urban scale
v. regional scale
a. from several meters to 100 meters
b. from four to fifty kilometers
c. from tens to hundreds of kilometers
d. from one-half to four kilometers
e. up to several city blocks
uimnimn
140
4. List the five general steps followed in the design of a surveillance
network.
5. List factors that must be taken into consideration when
designing the data system for an air surveillance network.
Answers are on the next page.
141
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Lesson V
Answers
1. i. State and Local Air Monitoring Stations
ii. National Air Monitoring Stations
iii. Special Purpose Monitoring
iv. Prevention of Significant Deterioration
2. Any three of the following:
Judging attainment of NAAQS
Evaluating progress in achieving/maintaining NAAQS
Developing/revising SIPs
Reviewing air quality impacts of new sources
Establishing baseline air quality levels for PSD
Providing data for atmospheric dispersion model development/validation
Supporting enforcement actions
Documenting episodes and initiating episode controls
Determining pollutant effect on public health and welfare
Providing air quality information to the public
142
mnmnmnmuiuuuumumu
3. i. a. from several meters to 100 meters
ii. e. up to several city blocks
iii. d. from one-half to four kilometers
iv. b. from four to fifty kilometers
v. c. from tens to hundreds of kilometers
4. 1. define purpose of network
2. assemble background materials
3. design sensor system
4. design data system
5. combine sensor and data system
5. data recording, data transmission, and data handling
After checking your responses, please turn on the tape recorder.
143
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Lesson VI: Air Quality Management
Personnel
Objectives
1. List four factors that affect the kind and number of
personnel needed in an air quality management agency.
2. List five types of personnel often employed in a comprehe
sive air pollution control organization.
3. Briefly describe trends in costs and funding for State and
local air pollution control agencies.
144
WWWmWHHUUWUHHIIIIIII
Number and kind of personnel needed
is dependent upon
size of area to be managed
complexity of air pollution problem
amount and kinds of pollutants
number and type of emission sources
145
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Basic Personnel
Administrative Personnel
Air Pollution Specialists
mmnnmmn
Inspectors
Chemists
146
Engineers
Other Specialists
Administrative
Personnel
plan the program
manage the program
provide for administrative
services
transportation
personnel
purchasing
communicati ons
office and lab space
etc.
147
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Inspectors
evaluate visible
emissions
investigate complaints
inspect plants
assist chemists and
engineers
calibrate and maintain
equipment and
instruments
collect samples
148
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Engineers
evaluate pollution sources
review construction plans
make emission inventory
calculations
develop pollutant
emission control
strategies
149
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Air Pollution
Specialists
gather and interpret
data
assist in complex
surveillance operations
assist in evaluating
permit applications
150
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Chemists
conduct laboratory
analyses
operate, calibrate,
and maintain air
quality measurement
instruments
151
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Equivalent
Ian-years
r,300 -
,000
'<-r-&
-------
A number of socio-economic factors
have conflicted with the allocation of
funds for air quality management
inflation
reduced tax revenue
pressure for economy in government
spending
claims by industry of hardships caused by
pollution control expenditures
154
Lesson VI
Questions
1. List four factors that affect the kind and number of
personnel needed in an air quality management agency.
2. List five types of personnel basic to a comprehensive air
control organization.
Answers are on the next page.
155
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Lesson VI
Answers
1. size of the area to be managed
complexity of the air pollution problem
amount and kinds of pollutants
number and types of emission sources in the area
2. administrative personnel
inspectors
engineers
air pollution specialists
chemists
After checking your responses, review any material that you are not sure of, and
then take the Unit Test which begins on page 157.
156
mwwHwniHiiin»mnmniii
Unit Test
Questions
1. A term often used to refer to all activities used to make our air clean and keep
it that way is:
a. clean air management
b. prevention of significant deterioration approach
c. air quality management
d. environmental management
e. lowest achievable emissions approach
2. For each standard on the left, choose its description from the righthand column.
i. NAAQS a. These state the degree of emission limitation that can be
ii. NESHAPS achieved by using the best available technological
iii. NSPS system of continuous emission reduction. The Federal government has
primary enforcement responsibility.
b. These specify the maximum pollutant levels which are allowed in the
air surrounding a city, community, or region. The States have primary
enforcement responsibility.
c. These are set to control emissions for which no other standards have
been set, yet which may reasonably be expected to cause or contribute
to an increase in deaths, serious irreversible illness, or incapacitating
reversible illness. The Federal government has primary enforcement
responsiblity.
157
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S. What is meant by "air pollution control strategy"?
4. What are the eight types of authority that a State must have in order for EPA to accept its
State Implementation Plan?
5. Which of the following is(are) basic types of source regulations?
a. Emission regulations setting maximum allowable emissions
b. Operating equipment and control device design regulations
c. Regulations prohibiting use of certain types of equipment
d. Regulations banning certain operations
e. Regulations specifying permissible and non-permissible fuels
6. What is the legal basis for State air pollution control agency enforcement authority?
7. List the six basic steps usually followed when enforcing air quality regulations.
8. What does the acronym SLAMS stand for?
9. Which of the following is(are) ways that a State can use data from an air surveillance
network?
a. judging attainment of NAAQS
b. developing/revising SIPs
c. reviewing air quality impacts of new sources
d. supporting enforcement actions
e. documenting episodes and initiating episode controls
10. List four factors that affect the kind and number of personnel needed in an air quality
management agency.
158
immnHimmmiiwwwmuui
Unit Test
Answers
1. c.
2. i. b
ii. c
iii. a
3. An air pollution control strategy is a list of actions which must be carried out in order to con-
trol air pollution in a specific area.
4. Authority to:
adopt and amend emission control regulations and other control measures needed
enforce applicable laws, regulations, and standardsincluding those which provide for
operation of a construction permit program with a fee system, and those which authorize
abatement on an emergency basis
prevent construction, modification, or operation of sources which would violate air quality
standards
require sources to keep records, and make inspections and tests to assess compliance with
emission standards
require sources to install and use monitoring devices and report on emissions
operate a motor vehicle emission inspection/maintenance program in areas where such is
required
make pollutant emission data available to the public
prevent significant deterioration of air quality
159
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5. a, b, c, d, and e
6. Powers given to the air pollution control agency by a State legislature. They are usually
spelled out in an "enabling" act.
7. Scheduled inspection of new and existing sources
Patrolling in the field to detect permit evasion or violation
Source emission tests and continuous emission monitoring
Negotiation of compliance schedules
Initiation of legal action
Follow-up inspection to check compliance
8. State and Local Air Monitoring Stations
9. a, b, c, d, and e
10. size of the area to be managed
complexity of the air pollution problem
amount and kinds of pollutants
numbers and types of emission sources in the area
160
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