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 pictures—they 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 clean—and 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 standards—including 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 40—Part 51
                    • lists requirements for SIPs
                       Title 40—Part 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 hearing—much 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
uuimm
   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
unnm
           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
mtmm
 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 work—downtown 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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   ft^': •
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         , in.
         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
tmummmnuH
     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
.mromroroufflimmmmiuin
         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
mmnmmmmuumuuuuuu
                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
nmmnmmumnumummm
                  Chemists

                  • conduct laboratory
                   analyses
                  • operate, calibrate,
                   and maintain air
                   quality measurement
                   instruments
                 151

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Equivalent
Ian-years
r,300 -
,000
          '<-r-&
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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 standards—including 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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