SN 14838.000
  Proposed Implementation Plan for  the
Control of  Particulates  and Sulfur  Oxides
                       for the
                State of Indiana Portion
                       of the
 Metropolitan Cincinnati  Interstate Air Quality Control Region
                   September
                     prepared for
        National Air Pollution Control Administration
                TRW i

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            PROPOSED IMPLEMENTATION PLAN FOR THE
          CONTROL OF PARTICULATES AND SULFUR OXIDES
                          FOR THE
                 STATE OF INDIANA PORTION
                           OF THE
METROPOLITAN CINCINNATI INTERSTATE AIR QUALITY CONTROL REGION
                      SEPTEMBER 1970
                       Prepared for

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     The wprk upon which the publication is based was performed by Resources
Research, Inc., a subsidiary of TRW Inc., pursuant to Contract No.  CPA 70-29
with the National Air Pollution Control Administration,  Environmental Health
Service, Public Health Service, Department of Health, Education and Welfare.

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                             TABLE OF CONTENTS

Section                            Title                             Page
  1.              DESCRIPTION OF THE REGION                           1-1
  1.1            General Characteristics                             1-1
  1.2            Topographical Features                              1-3
  1.3            Demography                                          1-3
  1.4            Meteorological Data                                 1-6
  1.4.1          Climatology                                         1-6
  1.4.2          Data for the Atmospheric Dispersion Model           1-9
  1.5            Emission Inventory                                  1-9
  1.6            Regional Air Quality                                1-15
  1.6.1          Sampling Stations                                   1-15
  1.6.2          Regional Distribution of Particulate Pollutants      1-21
  1.6.3          Regional Distribution of Sulfur Dioxide             1-21
  1.6.4          Air Quality Standards                               1-36
  1.7            Sampling Records in Indiana                         1-36
  1.7.1          Station Locations                                   1-36
  1.7.2          Air Quality Data                                    1-38
  2.              CONTROL PLAN                                        2-1
  2.1            Description of the Simulation Model                 2-1
  2.1.1          Atmospheric Diffusion Model                         2-1
  2.1.2          Control Cost Model                                  2-2
  2.1.3          Control Strategies Model                            2-2
  2.2            Rationale for Selection of Optimal Strategy         2-3
  2.2.1          Compatibility with Air Quality Standards            2-3
  2.2.2          Regional Cost                                       2-3
  2.2.3          Enforceability                                      2-4
  2.2.4          Summary                                             2-4
  2.3            Model Verification                                  2-4
  2.3.1          Suspended Particulates                              2-6
  2.3.2          Sulfur Oxides                                       2-10
  2.4            Control Strategy Selection                          2-16
  2.4.1          Particulate Control Strategies                      2-16
  2.4.2          Particulate Simulation Results                      2-23
  2.4.3          Sulfur Oxides Control Strategy                      2-32

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                            TABLE OF CONTENTS
                               (continued)

Section                            Title                             Page

  2.5            Proposed Control Strategy                            2-36
  2.6            Timetable for Implementing Proposed Regulations     2-38
  2.6.1          Adoption of Proposed Control Regulations            2-38
  2.6.2          Enforcement of Control Regulations                  2-39
  3.             LEGAL AUTHORITY                                     3-1
  3.1            Scope of Discussion                                 3-1
  3.2            General Discussion of the  Powers of
                 Administrative Agencies                             3-1
  3.3            Criteria for Effective Air Pollution Regulation     3-2
  3.4            Legislative Intent                                  3-2
  3.5            Legislative Definition of  "Air Pollution"           3-3
  3.6            Powers of the Indiana APC  Authority                 3-3
  3.7            Implementation of Emergency Actions                 3-16
  3.8            Organization of Regional Enforcement Activities     3-16
  3.9            Interstate Planning and Services Authority          3-17
  3.10           Summary of Legislative and Administrative Actions
                 Needed to Effect the Implementation Plan            3-17
  4.             CONTROL REGULATIONS                                 4-1
  4.1            Existing Regulations                                4-1
  4.2            Proposed Regulations                                4-14
  4.2.1          General Provisions                                  4-14
  4.2.2          Particulate Matter                                  4-14
  4.2.3          Sulfur Oxides                                       4-15
  4.2.4          Modified Regulations                                4-16
  5.             EMERGENCY EPISODE AUTHORITY AND PROCEDURES          5-1
  5.1            Comprehensive Emergency Episode Plan                5-1
  5.1.1          Episode Criteria                                    5-2
  5,1.2          Episode Communications                              5-3
  5.1.3          Episode Surveillance                                5-6
  5.1.4          Episode Legal Authority                             5-11
  5.1.5          Emission Reduction Plan                             5-11

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                            TABLE OF CONTENTS
                               (continued)

Section                           Title

  5.1.6          Time Schedule for Emergency Episode Plan
                 Development
  5.2            Interim Emergency Episode Plan
  6.             AIR QUALITY MONITORING
  6.1            Objectives
  6.1.1          Location of Sampling Stations
  6.1.2          Frequency of Collection
  6.1.3          Methods of Sampling
  6.1.4          Data Handling and Analysis
  6.2            Control of Emission Sources
  6.2.1          Source Surveillance
  6.2.2          Source Inspections - Field Operations
  6.2.3          Schedule
  6.3            Regional Data Bank
  6.4            Air Quality Data Transmissions
  7.             RESOURCES
  7.1            General
  7.2            Calculated Man-Years
  7.3            Funding
APPENDIX A       Meteorological Data
APPENDIX B       Indiana Air Pollution Control Law
APPENDIX C       Regional Organizational Structure
5-12
5-12
6-1
6-1
6-2
6-5
6-5
6-5
6-9
6-9
6-11
6-12
6-12
6-13
7-1
7-1
7-1
7-5
A-l
B-l

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                               LIST OF FIGURES


Figure Number                       Title                            Page

     1-1         Metropolitan Cincinnati Interstate Air
                 Quality Control Region                              1-2

     1-2         Population Density in the MCIAQCR                   1-5

     1-3         Emission Inventory Grid Map Showing Locations
                 and Sizes of Areas into which Area Emissions
                 Sources were Grouped                                1-11

     1-4         Point Sources in the MCIAQCR Emitting More
                 than 10 Tons per Year of Either Pollutant           1-14

     1-5         Sulfur Oxides Emission Density by Geographical
                 Areas                                               1-17

     1-6         Particulate Emission Density by Geographical
                 Areas                                               1-17

     1-7         Average Annual Particulate Concentrations
                 During 1967 - 1969                                  1-22

     1-8         Annual Average SO  Concentrations During
                 1968 - 1969                                         1-26

     1-9         Location of Stations in Indiana Portion of
                 the MCIAQCR                                         1-37
     2-1         Particulate Measuring Stations Used in
                 Model Verification                                  2-7
     2-2         Particulate Diffusion Model Verification
                 (Winter Data , November 1969-January 1970)          2-8

     2-3         Annual Geometric Mean Concentrations of
                 Suspended Particulate Pollutants as Measured
                 at Selected Sampling Stations and Annual
                 Arithmetic Mean Concentrations as Estimated
                 by Diffusion Model                                  2-9

     2-4         Sulfur Oxides Measuring Stations Used in
                 Model Verification                                  2-12

     2-5         Winter Sulfur Oxides Model Verification
                 (November 1969 - Janary 1970)                       2-13

     2-6         Annual Mean Concentrations of Sulfur Oxides
                 as Measured at Selected Sampling Stations and
                 Annual Arithmetic Mean Concentrations as
                 Estimated by Diffusion Model                        2-14

     2-7         Existing Emission Standards in the MCIAQCR
                 Based on Input Heat Capacity                        2-17

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                             LIST OF FIGURES
                               (continued)


Figure Number                     Title                              Page


     2-8         Additional Heat Input Type Standards Tested
                 in Proposed MCIAQCR Particulate Control
                 Strategies                                          2-20
     2-9         Two Sets of Emission Standard Curves for
                 Industrial Process Type Emissions Used
                 in the Particulate Control Strategies
                 Evaluated for the MCIAQCR                           2-21

     2-10        Allowable Particulate Emissions Based on the
                 Potential or Uncontrolled Source Emissions
                 Applied to Industrial Process,  Fuel Combustion,
                 and Solid Waste Disposal                            2-22

     2-11        Predicted Ground Level Concentrations
                 Following Application of Proposed Control
                 Strategy (1969 Emission Inventory)                   2-29

     2-12        Projected Ground Level Particulate Concentra-
                 tion Following Application of Proposed Control
                 Strategy (Projected 1980 Emission Levels)            2-31

     5-1         Indiana Episode Sequence                            5-4

     5-2         Daily Advisory from Weather Bureau at Greater
                 Cincinnati Airport                                  5-9
     5-3         Procedure for Developing the Emission Reduction
                 Plan                                                5-13

     5-4         Indiana Emergency Episode  Plan  Time  Schedule         5-21

     6-1         Location of Proposed Air Quality Monitoring
                 in the MCIAQCR                                      6-6

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                             LIST OF TABLES
Table Number                      Title                              Page

    1-1          Population Growth by County and for Selected
                 Cities                                              1-4

    1-2          Monthly Mean Afternoon Mixing Heights (meters)
                 for the Metropolitan Cincinnati Interstate
                 Air Quality Control Region                          1-7
    1-3          Seasonal and Annual Average Frequency of
                 Occurrence of Conditions Favorable for High
                 Pollution Values                                    1-8
    1-4          Existing Sulfur Oxide Emissions in the MCIAQCR
                 by Source Category and Location Based on 1969
                 Emission Inventory                                  1-12
    1-5          Existing (1969) Particulate Emissions in the
                 MCIAQCR by Source Category                          1-13
    1-6          MCIAQCR Sampling Stations                           1-18

    1-7          Quarterly Summary Statistics for MCIAQCR Study
                 November 1969 - January 1970, Pollutant:
                 Particulates                                        1-23
    1-8          Quarterly Summary Statistics for MCIAQCR Study
                 November 1969 - January 1970, Pollutant: S02        1-27
    1-9          MCIAQCR Sulfation Data, November 1969-January 1970  1-28

    1-10         Air Quality Standards for the MCIAQCR               1-35
    2-l(A)       Existing Particulate Emission Standards for
                 Industrial Process Sources (City of Cincinnati
                 Regulation)                                         2-18
    2-2          Initial Screening of Particulate Control Strategies 2-24
    2-3          Detailed Rerun of Selected Group of Strategies
                 for the MCIAQCR                                     2-26

    2-4          Particulate Emissions Following Application of
                 Proposed Emission Standards Based on 1969
                 Emission Inventory                                  2-28
    2-5          Particulate Emissions Following Application of
                 Proposed Emission Standards Based on Projected
                 1980 Emission Levels                                2-30
    2-6          Ambient Sulfur Dioxide Concentrations as Measured
                 at the CAMP Station, Cincinnati                     2-34
    2-7          Effect of Proposed Sulfur Oxides Control Strategy
                 on MCIAQCR Emission Levels (1969 Emission
                 Inventory)                                          2-35

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                              LIST OF TABLES
                                (continued)

Table Number                       Title                             Page

    2-8          Emissions Following Application of Proposed
                 Sulfur Oxides Control Strategy Based on 1980
                 Emission Projections                                2-37
    3-1          Analysis of Indiana Air Pollution Control Laws
                 and Regulations as of July 1970                     3-5
    3-2          Summary of Legislative and Administrative
                 Actions Taken to Effect the Implementation
                 Plan for the State of Indiana                       3-18

    5-1          Organizations Contacted During Episodes             5-3

    5-2          Emission Reduction Plan Elements                    5-14

    5-3          Proposed Emergency Source Categories for the
                 MCIAQCR                                             5-15

    5-4          Metropolitan Cincinnati Interstate Air Quality
                 Control Region, Interim Emergency Episode Plan      5-16

    5-5          Major Point Sources in the MCIAQCR                  5-22

    6-1          Projected Regional Air Quality Monitoring
                 Network                                             6-3

    7-1          Input Characteristics of Indiana Needed for
                 Manpower Estimates                                  7-2

    7-2          Summary of Man-Year Estimates for Indiana
                 Portion of MCIAQCR                                  7-3

    7-3          Estimated Present Manpower Utilization by
                 Control Agency for Indiana and for the Total
                 MCIAQCR                                             7-4

    7-4          Average Salary Estimates for Agency Operations      7-6

    7-5          Estimated Expenditures for Indiana Portion of
                 MCIAQCR                                             7-7

    7-6          Estimated Capital Expenditures for the Indiana
                 Program Within the MCIAQCR                          7-8

    A-l          Meteorological Input Data for the Annual Season     A-l

    A-2          Meteorological Input Data for the Winter Season     A-6

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                            LIST OF TABLES
                              (Continued)

Table Number                     Title                               Page

    7-4          Summary of Estimated Man-Years for Ohio Portion
                 of the MCIAQCR                                      7-6

    7-5          Average Salary Estimates for Agency Operations      7-7

    7-6          Estimated Expenditures for Ohio Portion of the
                 MCIAQCR                                             7-8

    7-7          Estimated Capital Expenditures for the Ohio
                 Program Within the MCIAQCR                          7-10

    A-l          Meteorological Input Data for the Annual Season     A-l


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                      1.  DESCRIPTION OF THE REGION

1.1  GENERAL CHARACTERISTICS
     The Metropolitan Cincinnati Interstate Air Quality Control Region
(MCIAQCR) was designated by the Secretary of the Department of Health,
Education and Welfare on May 2, 1969.  The Region is comprised of approxi-
mately 3000 square miles of land area located in the extreme southwestern
portion of Ohio and the adjacent state of Indiana and the Commonwealth of
Kentucky (Figure 1-1).  There  is  a total of nine counties, including the
territorial areas of all municipalities within the counties in the MCIAQCR,
namely:
     Indiana
       Dearborn County
       Ohio County
     Kentucky
       Boone County
       Campbell County
       Kenton County
     Ohio
       Butler County
       Clermont County
       Hamilton County
       Warren County
Current estimates place the population of the Region at approximately
1.5 million persons, of which about 500,000 reside within the City of
Cincinnati.  The population within the Region is centered on Cincinnati
with nearly two-thirds of the populace living with 15 miles of the
confluence of the Ohio and Licking Rivers.  Projections of future growth
indicate that the total population of the Region should increase to
1.8 million by 1975 and 2.0 million by 1980.
     The MCIAQCR is primarily an industrial area with about one-third
of the total employment in manufacturing industries.  The principal
industries are aerospace, soap products, automotive, primary metals,
fabricated metals, petroleum products, rubber, plastics, chemical,
and machine tool manufacture.  Industry is concentrated along the
Mill Creek, Great Miami and Little Miami Rivers in Ohio, and the
Licking River in Kentucky.

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Figure 1-1.  METROPOLITAN CINCINNATI INTERSTATE
             AIR QUALITY CONTROL REGION

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     The major sources of sulfur oxides are related to fuel combustion
with the most significant sources being the several large electric
generating plants located in the Region.  Fuel combustion also contri-
butes heavily to the total emission of particulates,  and again the elec-
tric power generating plants represent major point sources.  Significant
amounts of particulates are also emitted by industrial fuel combustion
sources as well as industrial process losses.  Solid  waste disposal by
open burning is permitted within the Region; and as a result, such sources
emit large quantities of particulate pollutants.

1.2  TOPOGRAPHICAL FEATURES
     The area in and around Cincinnati consists of an upland plain
about 900 feet above sea level which is cut by the flood plain of the
Ohio River.  Hills and valleys are more pronounced in the southern
and western portions of the Region.  The basin area within the flood
plain of the Ohio River is surrounded by steep bluffs rising 200 to
400 feet  to the general level of the upland plain.  These bluffs are
cut frequently by the valleys of small streams which produce a setting
of promontories and steep hills.  In general, throughout the Region
the hills and valleys have only a minimal effect on air movement;
however, within the steep walled meandering valleys,  the air flow is
strongly influenced by the surrounding terrain.

1.3  DEMOGRAPHY
     Population statistics for each county and for six principal cities
within the MCIAQCR are presented in Table 1-1.  The City of Cincinnati
with a population exceeding 500,000 accounts for one-third of the total
population of the Region.  The four Ohio counties include over 80 percent
of the population in the MCIAQCR.  Population density for the entire
Region averages 494 persons per square mile but varies from 52 persons
per square mile in Ohio County, Indiana, to 2384 persons per square
mile in Hamilton County, Ohio.  The counties of Boone in Kentucky and
Warren in Ohio showed the greatest growth in the ten-year period
1960 - 1970.  (Figure 1-2)

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                                                                                          1970
                Increase
Land Area
(sq.mi.)     1960
                                                  1965
  Estimated

1970       1975
   Density
Persons/Sg.Mi^
Indiana
Dearborn Cty.
Ohio County
Kentucky
Boone County
Campbell County
Kenton County
Ohio
Butler County
Clermont Cty.
Hamilton Cty.
Warren Cty.
MCIAQCR
3
3
2
7
22
5
6
9
10
14
5
25

.0
.0
.7
.3
.6
.2
.6
.1
.6
.9
.6
.0

739
306
87
563
249
149
165
1751
471
458
414
408
3032
32
28
4
230
22
87
121
1,214
199
80
867
66
1,477
,936
,771
,165
,289
,033
,119
,137
,000
,897
,874
,214
,015
,225
34
29
4
242
25
90
127
1,319
221
96
934
77
1,606
,301
,901
,400
,584
,112
,336
,136
,421
,194
,697
,301
,229
,306
35,320
30,800
4,520
260,300
30,800
95,000
134,500
1,439,500
244,700
111,100
987,200
96,500
1,735,120
36,
31,
4.
278,
36,
99,
141,
1,550
268,
125,
1,040
115,
1,864
340
700
640
400
700
800
900
,000
300
600
,200
900
,740
48
100
52
462
124
638
815
822
520
242
2384
284
572
   Percent of
Total Population


     2.0

     1.8
     0.2

    15.1

     1.8
     5.5
     7.8

    83.0

    14.2
     6.3
    56.9
     5.6
Source:  Ohio, Kentucky, Indiana Regional Planning Authority
                      Table 1-1.  POPULATION GROWTH BY COUNTY AND FOR SELECTED CITIES

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Residents Per Square  Mile
   Eliim  more  than  500

   l':-:^x-:-l  100 to  500

          less  than  100
Figure 1-2.  POPULATION  DENSITY IN
             MCIAQCR

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1.4  METEOROLOGICAL DATA
1.4.1  Climatology
       Climate of the MCIAQCR is typically continental with a wide range of
temperatures from winter to summer.  Summers are warm and rather humid,
with temperatures reaching 100°F or more one year out of three.  Above 90°F
temperature occurs about 28 days each year.  Winters are moderately cold
with frequent periods of extensive cloudiness.  However, during an average
winter the temperature reaches zero or below only on two days.
       The Region is subjected to frequent changes in the weather due to
the passage of numerous cyclonic storms in the winter and spring and
thunderstorms during the summer.  Minimum precipitation occurs in the fall.
Nearly one-third of the yearly precipitation occurs during the summer months
when prevailing south-to-southwest winds on the western sides of the Bermuda
high carry warm, moist air from the Gulf of Mexico up the Mississippi and
Ohio Valleys.  South-to-southwest flow predominates throughout the year
with average wind speeds at Greater Cincinnati Airport between 10 to 11 m.p.h.
from November to April, between 7 to 9 m.p.h. from May to September, and
9 m.p.h. over the year.  Wind speeds within the city limits average about
2 to 3 m.p.h. lower than these recorded at the Airport.
       Table 1-2 gives estimates of monthly mean afternoon mixing heights
in meters above ground, averaged over each month and the year as a whole.
These data, interpolated from values computed by Holzworth  for the nearest
surrounding radiosonde observation stations, Joliet, Illinois, Pittsburgh,
Pennsylvania, and Nashville, Tennessee, cover the 10-year period 1946 -
1955.  Table 1-3 shows seasonal and annual frequencies of noctural inversions,
nighttime cloud cover equal to or less than 3/10, nighttime wind speed equal
                                                        2
to or less than  7 m.p.h.  The data, adapted from Hosier , apply to Greater
Cincinnati Airport.  In the city, nocturnal inversions occur less fre-
quently than at the airport despite the higher frequency of light winds.
 Holzworth, G.C., "Estimates of Mean Maximum Mixing Depths in the Contiguous
 United States", Monthly Weather Review, 92, 5, 235-242 (May 1964).
2
 Hosier, C.R., "Low-Level Inversions Frequency in the Contiguous United
 States", Monthly Weather Review, 89, 319-339 (September 1961).

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January   February   March   April   May   June   July   August   September   October   November   December

  500       570       1020    1140  1250   1320   1550    1440      1200        950       670        520


                                              Annual

                                               1010


                  Table 1-2.  MONTHLY MEAN AFTERNOON MIXING HEIGHTS (meters)
                              FOR THE METROPOLITAN CINCINNATI INTERSTATE AIR

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                      Winter   Spring   Summer   Autumn   Annual
(1) Inversions          25*      28       32       37       30

(2) Cloud Cover Equal
    to or Less Than     26       36       55       54       42
    3/10

(3) Winds Equal To Or   31       38       69       50       47
    Less Than 7 m.p.h.
* Percent of Total Hours
        Table 1-3.  SEASONAL AND ANNUAL AVERAGE FREQUENCY OF
                    OCCURRENCE OF CONDITIONS FAVORABLE FOR
                    HIGH POLLUTION VALUES

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1.4.2  Data for the Atmospheric Dispersion Model
       The dispersion model used for the development of control strategies,
discussed in Section 2, requires input of the following meteorological data:
       •  Wind:  direction and speed
       •  Atmospheric stability
       •  Average mixing height
       Wind and stability are combined in a 480-unit, three-dimensional
frequency distribution based on 16 wind directions,  six wind speed classes,
and five stability categories.  The data used for this analysis are listed
in the Appendix in two tables:
       •  Table A-l.  DATA COVERING THE YEAR 1965 THROUGH 1969, TO ESTIMATE
          AVERAGE ANNUAL GROUND LEVEL POLLUTANT CONCENTRATIONS
       •  Table A-2.  DATA COVERING THE THREE MONTHS NOVEMBER 1969 THROUGH
          JANUARY 1970, FOR VALIDATING THE MODEL
       Average annual and winter afternoon mixing heights for the five-year
period were determined to be 1315 meters and 680 meters, respectively.  These
values, derived from radiosonde data for Dayton, Ohio, are higher than inter-
polated climatological data given in Table 1-2, which cover an earlier and
longer period of record.
       The model also provides for a computation of  effective stack height
                                       3
based on Holland's Plume Rise Equation.  Meteorological data required for
this computation include barometric pressure, here assumed to be 1000 millibars,
and mean ambient temperature, assumed to be 32°F, or 273°K.

1.5  EMISSION INVENTORY
     In October 1968, the Division of Air Quality and Emission Data, National
Air Pollution Control Administration, completed an inventory of all sources
of air pollution in the nine-county MCIAQCR.  A partial emission inventory
for the City of Cincinnati was completed by the Division of Air Pollution
Control and Heating Inspection in December 1968.  Following this, in
October 1969, the Kentucky Air Pollution Control Commission conducted an
inventory of sources of pollution for Boone, Campbell and Kenton Counties.
The APC agencies for Ohio and Indiana conducted inventories in December 1969.
3Holland, J.Z., "A Meteorological Survey of the Oak Ridge Area," USAEC
 Report ORO-99, Oak Ridge National Library, 1953.


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     Information derived from all of the above surveys was used to compile
the comprehensive emission inventory'upon which this Implementation Plan
is based.  All sources  emitting more than 10 tons/year of pollutants
were treated as point sources.  Those with emissions less than 10 tons/
year were included with the area emission sources.
     The Universal Transverse Mercator (UTM) grid system was used to locate
all sources of pollution in the Region.  The basic grid for the Region is
100 x 100 kilometers (Figure 1-3).  All points sources are located by their
easting and northing coordinates.  Area sources of pollution are computed
for grids varying in size from 2.5 x 2.5 KM to 20 x 20 KM, the smaller
grid  size being used in areas with high  emission densities.  Area source
grids are located by the easting and  northing  coordinates  of the  lower  left
corner of the grid.
     A summary of all point and area sources of emission is presented in
Table 1-4 for sulfur oxides and in Table 1-5 for particulates. * A total of
389,000 tons of sulfur oxides are emitted  annually  from  all  sources within the
Region.  Fuel combustion for stationary sources accounts for nearly
375,000  tons  or  96.4 percent  of  sulfur oxide emissions. More than 82 percent
of all sulfur oxides emitted in the Region comes from electric power
generating plants.  Even though the MCIAQCR is basically a manufacturing
center, industrial process losses account for only 2 percent of the total
sulfur oxide emissions.
     In excess of 172,000 tons of particulate pollutants  are emitted into
the atmosphere within the MCIAQCR each year.  Again, fuel combustion sources
represent the dominant contributors of particulates,  accounting for 68
percent (117,600 tons/year).  Electric power generating plants are
the single most important type of source in that they emit 80,8000 tons/
year or about 47 percent of all particulates.  Industrial process losses
emit 25,000 tons and solid waste disposal 20,800 tons of particulates
each year.  For solid waste disposal,   'open burning accounts for 18,400
tons of particulates each year.  The  geographical  distribution of point
sources emitting more than 10 tons per year is presented in Figure 1-4.
It is apparent that the majority of the point sources are located in Ohio
with the greatest concentration of point sources in Hamilton County.
 *The  complete emission  inventory has  been  supplied  to NAPCA  and only
  summary  tabulations appear in this  report.

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4390
                   680                700               720               740

                           Shaded  area  composed of forty 1  km2 areas
760
                             Figure  1^3.  EMISSION  INVENTORY GRID MAP SHOWING
                                          LOCATIONS AND SIZES OF AREAS INTO WHICH

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Source Category
Fuel Combustion, Stationary
Apartments, Commercial,
Government
Industrial
Power Plants
Residential
Fuel Combustion, Mobile
Gasoline Powered
Diesel Powered
Industrial Process Emissions
Solid Waste Disposal
Open Burning
Industrial
Commercial, Government
Municipal
Incineration
Industrial
Commercial, Government
Municipal
GRAND TOTAL
POLITICAL JURISDICTIONS
Cincinnati
10,845.88
5,765.54
4,463.39
0
616.95
1,299.65
984.09
315.56
0
550.81
113.23
110.23
3.00
0
437.58
0
47.03
309.55
12,696.34
Indiana
126,081.09
463.38
1,689.20
123,844.50
111.01
149.94
107.90
42.04
0
57.33
57.33
37.33
5.40
14.60
0
0
0
0
126,288.36
Kentucky
2,496.73
1,910.15
271.78
0
314.80
544.97
404.55
140.42
0
97.16
97.16
28.10
54.46
14.60
0
0
0
0
3,138.86
Ohio
230,716.90
4,956.40
28,253.75
196,041.50
1,465.25
2,895.74
2,153.08
742.66
8,584.80
2,552.54
2,453.99
335.14
224.50
1,894.35
98.55
0
0
98.55
244,749.98
TOTAL
370,140.60
13,068.47
34,678.12
319,886.00
2,508.01
4,890.30
3,649.72
1,240.68
8,584.80
3,257.84
2,721.71
510.80
287.36
1,923.55
536.13
0
47.03
489.10
386,873.54
I
M
t-0
                     Table  1-4. EXISTING SULFUR OXIDE EMISSIONS IN THE MCIAQCR  BY  SOURCE  CATEGORY


-------

Source Category
Fuel Combustion, Stationary
Apartments , Commerci al ,
Government
Industrial
Power Plants
Residential
Fuel Combustion, Mobile
Gasoline Powered
Diesel Powered*
Industrial Process Emissions
Solid Waste Disposal
Open Burning
industrial
commercial, government
municipal
Incineration
industrial
commercial, government
municipal
GRAND TOTAL
POLITICAL JURISDICTIONS
Cincinnati
6,302.41
2,538.80
3,431.91
0
331 . 70
2,179.90
1,312.11
867.79
365.00
3,677.59
1,887.50
1,837.39
50.11
0
1,790.09
0
235.19
1,554.90
12,524.90
Indiana
25,092.55
190.72
1,222.00
23,633.75
36.08
259.47
143.86
115.61
91.25
1 ,201.37
1,201.37
622.27
90.00
489.10
0
0
0
0
26,634.64
Kentucky
1,251.27
833.93
265.13
0
152.21
1,692.04
539.39
1,152.65
7,489.80
1,905.37
1,905.37
468.50
907.62
529.25
0
0
0
0
12,338.48
Ohio
85,965.89
2,166.12
25,119.54
58,104.35
575.88
4,913.08
2,870.77
2,042.31
16,968.85
14,006.54
10,929.59
5,585.67
4,964.32
379.60
3,076.95
0
0
3,076.95
121,854.36
TOTAL
118,602.12
5,729.57
30,038.58
81,738.10
1,095.87
9,044.49
4,866.13
4,178.36
24,914.90
20,790.87
18,424.08
8,513.83
6,012.05
3,898.20
2,166.04
0
235.19
1,930.85
173,352.38
        Table 1-5.  EXISTING (1969) PARTICULATE EMISSIONS IN THE MCIAQCR
                    BY SOURCE CATEGORY (tons/year)

-------
Figure 1-4.   POINT SOURCES IN THE MCIAQCR
             EMITTING MORE THAN 10 TONS  PER
             YEAR OF EITHER POLLUTANT


-------
There are two power generating plants in Dearborn County, Indiana, and one
in Clermont County, Ohio.  Emission sources located in the Cities of
Hamilton and Middletown, Ohio, are shown by separate clusters to the north
of the City of Cincinnati.
     Contributions from area sources of emissions are presented in terms
                                  2
of emission densities (tons/day/km ) for sulfur oxides (Figure 1-5) and
particulates (Figure 1-6).  The two pollutants show the same geographical
pattern with areas of highest emission densities centered on the City of
Cincinnati and the northern Kentucky cities of Covington and Newport.  The
Cities of Hamilton and Middletown in Butler County also show up as signi-
ficant area sources for both SO,, and particulates.  Grid number 223 in
Boone County shows relatively high particulate emissions as a result of
aircraft activity at the Greater Cincinnati Airport.

1.6  REGIONAL AIR QUALITY
1.6.1  Sampling Stations
       Measurements of ambient concentrations of particulates and sulfur
oxides have been made at various locations in the MCIAQCR since 1957.  For
the most part, the sampling sites were located in or near the City of
Cincinnati and were operated for periods of one year or less on a project
basis.  As a result, there is a paucity of data for the Region as a whole.
       Table 1-6 lists the most recent sampling sites, identified by site
numbers used on NAPCA and state and local programs.  Locations are shown
in UTM coordinates.  At four locations, three in Cincinnati and one in
Covington, measurements made under federally sponsored programs span a
number of years.  Station 106, operating under the Continuous Air Moni-
toring Program (CAMP) has an uninterrupted record dating back to 1961.
Three stations, Numbers 98 and 109 in Cincinnati and 105 in Covington,
are part of the National Air Sampling Network (NASN); the record for
Station 109 dates back to 1957.
       Further data on sampling stations are given in connection with
specific projects and results discussed below.

-------
                                  KENTON    CAMPBELL
.05-.10
                   Figure  1-5.  SULFUR OXIDES  EMISSION DENSITY BY
                               GEOGRAPHICAL AREAS

-------
                                         KENTON    CAMPBELL
iii  -05--10
                                    Figure 1-6,
                                       1-17
PARTICULATE EMISSION DENSITY BY

-------
                                    Table 1-6.   MCIAQCR SAMPLING  STATIONS
         STATION NUMBER
      NAPCA  State & Local
  COORDINATE
  (kilometer)
Easting  Northing
oo
10
39
42
70
71
72
73
74
75
76
77
78
79
80
81
82
83
84
85



2
3
6
13
16
17
20
21
23
31
30
36
37
43
44
45
721.80
716.20
707.00
694.67
701.27
707.39
709.37
717.73
717.55
723.69
719.81
722.24
729.39
728.13
740.94
735.58
709.75
708.42
711.69
4331.90 Tenn;
4329.50 Newpi
4321.80 Erla;
4335.75 Nortl
4348.52 New :
4340.25 Monfi
4331.84 Seat.
4341.15 Seym<
4339.31 Laid
4349.82 Shan
4344.81 Lock
4339.72 Nati-
4327.69 Ande
4334.13 Newt.
4323.40 Amel
4314.80 New ]
4363.87 City
5362.39 Monr
4366.20 Kami
Name
Tennyson Pumping Station
Newport Mall
Erlanger City Hall
North Bend Fire Station
New Baltimore Fire Station
Monfort Heights Fire Station
Seaton High School
Seymour Fire Station
Laidlaw
Sharonville Elem. School
Lockland Fire Station
Nativity Elem. School
Anderson Township School
Newton Elem. School
Amelia Elem. School
New Richmond Fire Station
City Building
Monroe Elem. School
Hamilton No. Water Treatment
Plant
   LOCATION
City or County
Cincinnati
Newport
Erlanger
North Bend
New Baltimore
Monfort Heights
Hamilton County
Hamilton County
Cincinnati
Sharonville
Lockland
Hamilton County
Hamilton County
Newton
Amelia
New Richmond
Hamilton
Hamilton
Butler County
State
Ohio
Kentucky
Kentucky
Ohio
Ohio
Ohio
Ohio
Ohio
Ohio
Ohio
Ohio
Ohio
Ohio
Ohio
Ohio
Ohio
Ohio
Ohio

-------
                          Table 1-6.  MCIAQCR SAMPLING STATIONS (continued)
   STATION NUMBER
NAPCA  State & Local
  COORDINATE
  (kilometer)
Easting  Northing
86
87
88
89
90
91
92
93
94
98
105
106
107
109
110
111
112
113
114
202
46
47
52
53
54
55
56
58
59
2










712.20
712.03
723.57
723.69
727.75
728.42
725.46
733.05
740.12
711.60
715.60
714.40
712.20
715.00
685.00
714.30
687.10
615.10
742.10
712.80
4364.40
4361.45
4376.70
4374.77
4378.12
4376.08
4374.50
4381.58
4368.94
4341.60
4328.80
4331.60
4331.60
4331.20
4331.10
43333.30
4329.30
4329.20
4322.40
4335.40
Gran
Van :
Midd
Garf
Mane'
Cree
Pion
Fran
Leba
Coll
Covi
CAMP
Wast
Libr
Gree
WLW '
Lawr
IRS
Volu
High
Name
Grant School
Van Buren Elem. School
Middletown High School
Garfield Elem. School
Manchester Jr. High School
Creekview Elem. School
Pioneer Standard Electronics
Franklin High School
Lebanon High School
College Hill
Covingtnn NASN
CAMP
Waste Water Treatment Plant
Library
Greendale Utilities
WLW TV Tower
Lawrenceburg Police & Fire Station
IRS Building
Volunteer Fire Department
Highway Maintenance
   LOCATION
City or County
Hamilton
Hamilton
Middletown
Middletown
Middletown
Middletown
Middletown
Franklin
Lebanon
Cincinnati
Covington
Cincinnati
Cincinnati
Cincinnati
Greendale
Cincinnati
Lawrenceburg
Covington
Amelia
Cincinnati
State
Ohio
Ohio
Ohio
Ohio
Ohio
Ohio
Ohio
Ohio
Ohio
Ohio
Kentucky
Ohio
Ohio
Ohio
Indiana
Ohio
Indiana
Kentucky
Ohio

-------
                              Table 1-6.  MCIAQCR SAMPLING STATIONS (continued)
   STATION NUMBER
NAPCA  State & Local
  COORDINATE
  (kilometer)
Easting  Northing






H1
1
0
203
204
207
209
244
245


725.30
727.70
719.10
711.60
715.90
723.32


4337.90
4340.40
4336.30
4336.70
4326.70
4376.96


Name
French Bauer (Dairy)
Maderia Board of Education
Norwood Fire Station #2
Cincinnati Gas & Electric
Substation
Rockcastle Motor Sales
City Building Annex
   LOCATION
City or County
State
Cincinnati
Maderia
Norwood
Cincinnati
Covington
Middletown
Ohio
Ohio
Ohio
Ohio
Kentucky

-------
1.6.2  Regional Distribution of Particulate Pollutants
       Figure 1-7 shows isopleths of average annual ground level concentrations
of suspended particulates measured over a portion of the Region during 1967
to 1969.  The observational records used to develop this figure include those
of the CAMP and NASN stations and the combined data of several measurement
programs irregularly spaced throughout the period.  From Figure 1-7 it is
apparent that areas of high pollution are centered on Cincinnati and Newport,
Kentucky, the City of Hamilton and the vicinity of the Ohio and Indiana
border near the Ohio River.  It will also be apparent, from the table of
Air Quality Standards in Section 1.6.4 infra, that these standards are
being exceeded over a significant part of the MCIAQCR.  These indications
are further supported by a three-month study from November 1969 through
January 1970, results of which are shown in Table 1-7.  All measurements
reported in micrograms per cubic meter were made by means of high volume
samplers ("hi-vols").  At one site, in Newport, Kentucky, soiling index
(smoke shade) measurements reported in COHs per 1000 linear feet were
made on an AISI tape sampler.  These units are not used for Air Quality
Standards and no factor to convert them to equivalent micrograms per
cubic meter is universallly agreed upon.

1.6.3  Regional Distribution of Sulfur Dioxide
       Ambient air monitoring data for sulfur dioxide are scarcer than for
particulates, both on a regionwide and a local basis.  In recent years,
however,  several projects were undertaken to obtain measurements of sulfur
oxides, using sulfation networks, wet impingers ("bubblers"), and con-
tinuous SO- analyzers.  Figure 1-8 shows isopleths of annual average ground
level concentrations of S09 derived from several projects in operation
during 1968-1969.  Table 1-8 gives results for the three-month period
corresponding to Table 1-7.  Table 1-9 also covers the period November 1969
through January 1970, but the data are measurements of sulfation taken from
a close network of stations.  The station numbers are different from those
previously listed for the Region.  Coordinates are given to the nearest
kilometer, measured from the origin at (660.0, 4290.0)  in the UTM system.

-------
o      HAMILTON

x
o
 Figure 1-7.  AVERAGE ANNUAL PARTICULATE CONCENTRATIONS

              DURING 1967 - 1969 (micrograms per cubic

              meter)

-------
                                  Table 1 - 7  QUARTERLY SUMMARY STATISTICS FOR
                                               MCIAQCR STUDY, NOVEMBER 1969 - JANUARY 1970
                                               POLLUTANT:  PARTICULATES          yg/m3
                                                               ARITHMETIC
GEOMETRIC
I
ho
OJ
STATION
10
39
42
70
71
72
73
74
75
76
77
78
79
80
81
82
83
NUMBER OF
READINGS
31
29
29
30
30
30
30
28
28
30
30
30
30
31
21
29
28
MAXIMUM
178
342
191
221
191
228
263
248
281
154
426
225
108
122
131
143
244
MINIMUM
24
59
19
24
25
28
33
30
25
27
35
11
16
25
12
28
27
MEAN
77
162
62
78
71
74
70
119
126
75
136
95
53
63
67
82
85
STANDARD
DEVIATION
34
67
35
42
40
44
48
66
71
32
95
42
20
24
34
34
56
MEAN
70
148
55
69
63
65
61
102
108
69
111
85
50
59
58
74
73
STANDARD
DEVIATION
1.55
1.54
1.67
1.62
1.62
1.64
1.60
1.79
1.78
1.53
1.90
1.73
1.45
1.46
1.78
1.64

-------
     Table 1 - 7  Continued
                                                                                             GEOMETRIC
to
-P-
STATION
84
85
86
87
88
89
90
91
92
93
94
98
105
106
107
109
no
111
112
NUMBER OF
READINGS
31
30
31
27
30
27
30
28
28
28
19
30
70
48
30
31
31
29
13
MAXIMUM
195
333
211
140
196
212
130
188
344
156
103
213
203
233
276
248
187
250
148
MINIMUM
15
28
27
28
49
37
26
15
50
20
21
29
52
49
26
35
26
40
41
MEAN
56
90
78
66
93
99
64
74
128
68
56
68
113
110
107
102
67
89
85
STANDARD
DEVIATION
41
74
39
27
35
45
26
37
65
32
23
41
66
44
60
49
36
50
35
MEAN
47
73
71
61
88
89
59
66
115
62
52
60
98
102
93
93
59
80
79
STANDARD
DEVIATION
1.80
1.81
1.55
1.51
1.43
1.63
1.50
1.70
1.61
1.59
1.53
1.65
1.79
1.45
1.71
1.53
1.64
1.54

-------
    Table 1 - 7 Continued
                                                                ARITHMETIC
GEOMETRIC
I
N>
Ul
STATION
113
202
203
204
207
209
244


039
NUMBER OF
READINGS
28
31
25
22
27
30
24


725
MAXIMUM
219
443
160
228
244
211
196

Pollutant:
260
MINIMUM
31
39
31
48
42
30
50
ADDENDUM
Parti culates
0.00
MEAN
89
135
92
95
100
83
105

Units:
0.34
STANDARD
DEVIATION
46
86
31
40
47
47
36

Soiling Index,
0.39
MEAN
79
117
87
89
91
73
99

COHs/1000
0.22
STANDARD
DEVIATION
1.58
1.68
1.43
1.44
1.54
1.64
1.40

linear feet

-------
                    KENTON    CAMPBELL
Figure 1-8.   ANNUAL AVERAGE  SC>2  CONCENTRATIONS
             DURING 1968-1969  (micrograms per
             cubic meter)


-------
                                  Table 1 - 8
QUARTERLY SUMMARY STATISTICS FOR
MCIAQCR STUDY. NOVEMBER 1969 - JANUARY 1970
                                               POLLUTANT:   SO-
                    UNITS:   ppm
                                                                                          GEOMETRIC
I
NJ
STATION
39

70
75

77
82
83
105
106

109
110
114
203
245
(NOTE)
NUMBER OF
READINGS
(1)
(2)
(1)
(1)
(3)
(3)
(1)
(3)
(1)
(1)
(2)
(1)
(1)
0)
(1)
(3)

6
513
30
22
1659
1906
29
1144
6
6
2079
5
27
25
28
1171

MAXIMUM
.018
.290
.130
.045
.150
.350
.040
.150
.025
.020
.250
.015
.075
.055
.040
.140

MINIMUM
.002
.000
.005
.010
.000
.000
.005
.000
.010
.005
.000
.005
.000
.005
.005
.000
•
MEAN
.008
.020
.028
.027
.023
.033
.016
.022
.016
.012
.031
.008
.027
.018
.021
.029

STANDARD
DEVIATION
.008
.027
.027
.011
.019
.037
.011
.026
.006
.005
.028
.004
.025
.012
.009
.024

MEAN
.005
.014
.020
.024
.018
.023
.013
.151
.015
.011
.023
.007
.017
.014
.018
.022

STANDARD
DEVIATION
2.78
2.44
2.37
1.58
2.08
2:29
1.93
2.59
1.44
1.60
2.18
1.67
3.14
1.95
1.73
2.28

       1) Wet Impinger, West-Gaeke & Pate Technique
       .2) Colorimetric,  Continuous Analyzer

-------
Station


    1
    2
    3
    4
    5
    6
    7
    8
    9
   10
   11
   11A
   12
   13
   14
   15
   16
   17
   17A
   18
   19
   20
   21
   22
   23
   24
   25
   26
   27
   28
   29
   30
   31
   32
   33
   34
   35
   36
   37
   38
   39
   40
   41
   42
   43
   44
   45
   46
   47
   48
   49
   50
                Table  1-9 MCIAQCR SULFATION DATA Nov.  1969-Jan.  1970

                                                       S0o/cm2/day
 County

Dearborn
Dearborn
Dearborn
Dearborn
Dearborn
Hami1 ton
Haini 1 ton
Hamilton
Hamilton
Hami1 ton
Dearborn
Dearborn
Dearborn
Dearborn
Dearborn
Dearborn
Dearborn
Dearborn
Dearborn
Dearborn
Boone
Boone
Boone
r>.- .-i >« r>
Boone
Boone
Boone
Boone
Boone
Boone
Boone
Boone
Boone
Boone
Boone
Clermont
Clermont
Clomont
Clermont
Clermont
Clermont
Clermont
Clermont
Clermont
Clermont
Clermont
Clenr.ont
Clennonfc
Clerniont
Clcniiont
Clermont
Hamilton
Coordinates

  25, 39
  24, 37
  23, 38
  25, 38
  26, 39
  28, 41
  29, 42
  31, 42
  32, 43
  28, 46
  27, 44
  26, 42
  24, 40
  24, 41
  24, 42
  24, 39
  22, 42
  22, 41
  21, 36
  21, 34
  24, 36
  28, 39
  30, 37
   on
   4- 'J J
   28, 36
   26, 37
   22, 34
   42, 35
   42, 38
   39, 40
   35, 44
   33, 43
   31, 41
   35, 37
   30, 32
   72, 32
   73, 31
   76, 31
   76, 30
   74, 31
   74, 29
   75, 26
   75, 25
   74, 27
   75, 29
   75, 30
   76, 28
   78, 27
   81, 29
   79, 34
   74, 37
   65, 40
Nov.
6
3
5
6
7
6
9
10
22
4
4
8
11
5
4
6
6
6
2
5
4
8
3
r
7
7
5
6
2
5
6
10
10
6
4
4
6
11
3
3
6
7
2
4
10
10
9
6
4
9
6
3
Dec.
11
6
12
10
6
12
10
13
15
8
6
6
9
6
8
10
11
11
6
10
6
15
6
n
12

12
14
6
7
11
11
11
10
6
4
3
2
3
2
5
4
6
2
9
8
12
11
4
6
5
3
"
Jan.
15
10
14
•14
15
11
21
21
14
14
17

11

18
14
15
11
16
14
19
11
17
18

13
18

19
16
17
19
17
11
11
10
15
15
14
17
11
10
11
16
17
14
14
13
16
14
10
x*
11
6
10
10
9
11
17
15
19
9
8
10

7

11
10
11
6
10
8
14
7
11
12

10
• 13

10
11
13
13
11
7
6
6
9
7
6
9
7
6
6
12
12
12
10
7
10
8
5
                                           1-28

-------
            yg S02/cm2/day
Station
51
52
53
54
55
56
57
58
59
59A
60
61
62
63
64
65
66
67
68
69
70
71
72
73
74
76
77
80
81
82
83
84
85
86
87
88
90
91
92
93
93A
94
94A
County
Hami 1 ton
Hamilton
Hamilton
Campbell
Campbell
Campbell
Campbell
Campbell
Campbel 1
Campbell
Campbell
Campbell
Campbell
Campbell
Campbell
Campbell
Campbel 1
Campbel 1
Campbel 1
Campbel 1
Campbel 1
Campbell
Campbell
Campbell
Hamilton
Clermont
Clermont
Hamilton
Boone
Boone
Boone
Boone
Boone
Boone
Kenton
Hami ! ton
Boone
Boone
Boone
Boone
Boone
Boone
Boone
Coordinates
65, 38
68, 37
70, 36
60, 36
65, 33
70, 32
69, 30
70, 31
72, 29
72, 28
70, 27
72, 26
73, 27
73, 28
72, 29
79, 17
77, 21
75, 21
73, 17
70, 18
66, 25
69, 23
72, 22
75, 23
63, 43
75, 34
79, 32
60, 45
38, 30
33, 35
27, 30
28, 26
28, 21
41, 25
50, 30
70, 39
38, 36
33, 41
37, 39
31, 40
31, 38
35, 33
26, 36
Nov.
3
5
6
4
5
4
4
5
2
2
6
2
3
4
3
3
3
3
3
8
6
4
6
3

7
6
5
5
7
5
5
6
6
7
6
5
11
7
13

6
5
Dec.
3
5
3
10
10
8
9
13
7
5
10
5
8
8
8
6
3
13
8
10
11
7
10
7
/
3
6

10
14
8
7
8
10
11
5
9
14
11
12
10.
13
7
Jan.
7
8
13
10
10
6
7
14
8
6
13
8
10
9
1C
8
8
13
9
13
14
9
12
9
10
22
14

15
17
10
12
16

15
18
14
24
19
13
18
19
12
T
4
6
7
8
8
6
7
11
,6
4
10
5
7
7
7
6
5
10
7
10
10
7
9
6
•
11
9

10
13
8
8
10

11
10
9
16
12
13

13
8

-------
                         2
               pg  502/cm /day
Station
95
96
97
98
99
100
101
102
103
104
105
106
107
108
109
no
111
112
114
115
116
117
118
119
120
121
122
123
124
125
126
127
128
129
130
131
132
133
134
135
136
137
140
141
142
143
144
145
146
County
Boone
Boone
Boone
Boone
Boone
Boone
Hamilton
Hamilton
Hami 1 ton
Hami 1 ton
Hamilton
Hamilton
Hamilton
Hami 1 ton
Hamilton
Dearborn
Dearborn
Dearborn
Dearborn
Dearborn
Hamilton
Butler
Butler
Butler
Butler
Butler
Butler
Butler
Butler
Butler
Butler
Butler
Butler
VJarren
Warren
Warren
Warren
Warren
Warren
Warren
Warren
Warren
Dearborn
Dearborn
Hamilton
Hami 1 ton
Hami 1 ton
Hamilton
Kenton
Coordinates
31, 29
27, 33 .
24, 35
23, 34
27, 32
43, 29
32, 57
29, 57
30, 50
33, 49
32, 48
34, 48
34, 47
33, 44
30, 45
22, 37
20, 47
15, 51
09, 60
19, 59
39, 59
30, 70
31. an
29, 89
39, 89
39, 79
39, 70
50, 68
59, 69
59, 80
51, 80
50, 90
60, 90
70, 89
79, 90
90, 90
89, 80
80, 81
70, 78
70, 70
79, 70
90, 70
25, 41
26, 40
65, 47
67, 50
59, 46
54, 43
47, 31
Nov.
6
5
4
3
5
6
9
5
2
9
6
8
9
14
9
3
2
3
5
3
-
8
3
5
7
9
8
6
6
9
5
6
4
6
6
6
2
8
6
10
6
5
11
8
5
6
8
10

Dec.
_


7

10
11
7
7
13
6
7
9
6
9
8
7
7
5
4
9
7
6
10
10
10
7
9
8
10
8
10
7
4
3
10
5
10
6
10
7
6
11
7
6
9
8
13

Jan.
15




15
18
10
8

14
10
11

16
12
9

18
10
13
14
11
16
18
19
18
12
14
14
12
22
13
14
13
14
9
15
12
14
11
13
18
15
13
14
13
16
12
X





10
13
7
- 6

9
8
10

11
8
6

9
6

10
7
10
12
13
'11
9
9
11
. 8
13
8
8
7
10
5
11
8
11
8
8
13
10
8
10
10
13


-------
2
yg S02/cm /day
Station
151
152
153
154
155
County
Hami 1 ton
Hami 1 ton
Clermont
Campbell
Hami 1 ton
Coordinates
58, 55
34, 45
75, 24
56, 39
61, 41
Nov. Dec.
7

7


Jan.
14
12
11

14
X





159        Kenton                57,  37                                12
160        Hamilton              51,  41             5         10       14   10
161        Hamilton              52,  45             6          9      -
162        Kenton                55,  39            19                  16
163        Hamilton              57,  49            19          9       16   15
164        Hamilton              51,  45                        6

201        Dearborn              20,  37             4         4        13    7
202        Dearborn              19,  40             2         5        14    7
203        Dearborn              18,  42             68        18   11
204        Dearborn              16,  43             4        10        15   10
205        Dearborn              12,  44             5        10        13    9
206        Dearborn              09,  47             6        14        17   12
207        Dearborn              07,  40             2         8        15    8
208        Dearborn              13,  37             6        14        14   11
209        Dearborn              17,  35             6         8        14    9
210        Dearborn              13,  40                       6         9
211        Deaicorn              11,41             3         6        158
212        Ohio                  26,  23             4         5   .     13    7
213        Ohio                  23,  30             4         9        13    9
214        Ohio                  20,  26             23        10    5
215        Ohio                  17,  23             6         5        13    8
216        Ohio                  18,  18           ,6        10        14   10
217        Ohio                  06,  18             6         7        14    9
218        Dearborn              04,  25             5         9        14    9
219        Dearborn              08,  30             3         8        117
220        Ohio                  13,  26           "6         6        11    8
221        Dearborn              15,  31             5        11        14   10
222        Dearborn              13,  34             2                   8
223        Dearborn.              07,  36             5        11        17   11
224        Dearborn              07,  48             6        12        16   11


250        Hamilton              60,  50             4         2        12    6
251        Hamilton              60,  56             2         5        12    6
252        Hamilton              60,  61             2         2        14    6
253        Hamilton              50,  61             2         4        18    8
254        Hamilton              50,  57             2         4
255        Hamilton              50,  51             3         3        14    7

-------
                                                         S02/cm2/day
 St_atjjDn __ County _ Coordinates _ Nov. ________ Dec.     ^  Jan.  T

 256           Hamilton               50, 45            5        3        14
 257           Hamilton               50,' 40                     -        12
 258           Hamilton               40, 41                     5        12
 259           Hamilton               40, 46                     7        14
 260           Hamilton               40, 51                     2        11
270           Hamilton               64, 51                    11         17
271           Hamilton               54, 48                     7
272           Hamilton               55, 45                     5         14
273           Hamilton               57, 44                     6         22
274           Hamilton               62, 47                    12         15
275           Hamilton               45, 46                     5         10
276           Hamilton               60, 53
277           Hamilton               53, 51
278           Hamilton               47, 42                    10
279           Hamilton               44, 39
300           Clermont               73,  35            9        1         14     8
301           Hamilton               63,  35            4        4         12     7
302           Hamilton               71,  33            5        2         11     6
303           Clermont               76,  26            3        2         10     5
304           Clermont               77,  25            6        4         17     9
305           Clermont               80,  26            5        4         14     8
306           Clermont               80,  39            6        2         14     7
307           Clermont               90,  40            5       10         14    10
308           Clermont               89,  29            2        5         12     6
309           Clermont               73,  41            6        6         15     9
310           Clercoiit-               77,  38            3        2         14     6
311           Clermont               80,  36            7        5         15     9
312           Clermont               77,  35            6        2         15     8
313           Clermont               77,  33            8        2         17     9
314           Clennont               77,  31            4        2         10     5
315           Clennont               78,  28            8        2         18     9
316           Clermont               77,  27            5        9         10     8
317           Clermont               78,  26            2        2         94
318           Clennont               82,  25            5        2         15     7
319           Clermont               79,  23           10        4         14     9
320           Vermont               75,  33           11         2         18    10

-------
                                                            S02/cm2/day
Station	County	Coordinates	Nov.     Dec.	Jan.
321
322
323
324
Hamilton
Clermont
Clermont
Hamilton
70,
80,
90,
67,
50
49
49
45
6
3
2
5
4
8
10
3
15
15
14
9
8
9
9
6
  326       Boone                      25,  32          15        6        11    11
  327       Boone                      38,  20          18
  328       Boone                      39,  10          16        6        15    12
  329       Campbell                    60,  39           6        8        13     9
  330       Clermont                   89,  20           2        4       , 13     6
  331       Campbell                    61,  30           9       10        14    11
  340       Clermont                   99,  09                   5        13
  341       Clermont                   84,  14                   6         9
  342       Clermont                   79,  19                   49
  343       Clermont                   90,  59
  344       Clermont                   80,  59                   5        ^9
  345       Hamilton                   69,  59                   6        12
  346       Hamilton                   64,  45                  10        17
  347       Hamilton                   64,  54                   9        20
  348       Hamilton                   61,  54                   9
  349       Hamilton                   54,  54                   8        15
  350       Hamilton                   57,  52                   7        15
  351       Hamilton                   55,  41                   6
  352       Hamilton                   53,  40                  10        15
  353       Hamilton                   54,  42                   9        15


  400       Campbell                   66,  13                   6        10
  401       Kenton   •                  51,  21                   4         «
  402       Kenton                     61,  20                   7        14
  403       Kenton                     53,  10                   8        12
  500       Hamilton                   44,  55                            18
  501       Hamilton                   58,  47                            13
  502       Hamilton                   54,  46                            17
  503       Hamilton                   56,  43                            16
  504       Hamilton                   60,  42                            10
  505      'Hamilton                   62,  40                            12


-------
                                                                  S02/cm  /day
Station
    County
Coordinates
Nov.
Dec.
Jan.
   506
   507
   508
   509
   510
   511
   512
   513
   514
   515
   516
   517
   518
   519
   520
   521
   522
   523
Hamilton
Hamilton
Campbell
Hami1 ton
Hamilton
Hamilton
Hamilton
Hami1 ton
Hamilton
Hamilton
Clermont
Hamilton
Hamilton
Hami1 ton
Hami1 ton
Clermont
Hamilton
Hamilton
   66, 42
   55, 48
   58, 42
   60, 49
   63, 39
   51, 54
   46, 58
   54, 59
   59, 59
   65, 58
   75, 47
   69, 47
   43, 49
   43, 43
   46, 52
   73, 48
   70, 43
   75, 44
                  15
                  15
                  10

                   9
                  14
                  16
                  14
                  15
                  18
                   9
                  18
                  11
                  14
                  10
                  11
                  10
                  10

-------
                  Table 1-10.  AIR QUALITY STANDARDS FOR MCIAQCR
                               (concentrations in micrograms per cubic meter)

State
Indiana
Kentucky
Ohio
SULFUR OXIDES
Annual
43 (AM)1
57(GM)2
43 (AM)
Monthly 24 Hours
286
143 286
286
1 Hour
1201
858
858
PARTICULATES
Annual
75 (GM)
65 (GM)
65 (GM)
24 Hours
1 Percent-*
200
180
200
Maximum
200
220
260
 AM - Arithmetic Mean
"GM - Geometric Mean

-------
1.6.4  Air Quality Standards
       The Air Quality Standards adopted by the States are shown in
Table 1-10.  These are the goals which the implementation planning process
must be  designed to achieve.  Although the standards vary somewhat from
state to state within the Region, these discrepancies are not significant
enough to prevent effective regionwide planning for air pollution control.
Indeed, considering the transport of pollution from one section of the
Region to another, there appears to be no reason why control strategy
development cannot proceed on a regional basis leading to the eventual
adoption of uniform emission control regulations throughout the Region.

1.7  SAMPLING RECORDS IN INDIANA
1,7.1  Station Locations
       In the two Indiana counties (Ohio and Dearborn) that are part of
the MCIAQCR, no air quality sampling stations have been in operation until
November 1969.  At that time, two stations designed as Nos.,110 and 112
were established in Dearborn County.  Their locations are shown in
Figure 1-9.

-------
Figure 1-9.  LOCATION OF STATIONS IN INDIANA PORTION
             OF THE MCIAQCR

-------
       Both stations are equipped with high volume samplers (hi-vols)  for
measuring suspended particulates.  In addition, Station No. 110 is sampling
24-hour concentrations of S0_ bi-weekly by means of bubblers,  analyzed by
the West-Gaeke technique.

1.7.2  Air Quality Data
       Since the observational record is fragmentary, no data  summaries of
significance are  as yet available

-------
                              2.0 CONTROL PLAN

     An Emission Control Strategy is made up of a set of compatible
emission standards.  Each standard applies to emissions from a specific
type of operation  (e.g., fuel combustion, industrial process, solid waste dis-
posal) ,and the summation of the several standards included within each strategy
defines allowable emission levels from each source in the region.  In an air
quality control region made up of several political jurisdictions (states,
counties, or cities), each set may apply to a specific political jurisdiction
within the region.   Separate emission control strategies are defined for
each pollutant.

2.1  DESCRIPTION OF THE SIMULATION MODEL
     The simulation model used for strategy evaluation was the Implementation
Planning Program developed by TRW Systems Group under contract with the
National Air Pollution Control Administration, U. S. Department of Health,
Education and Welfare.  This program uses three computer models to perform
an analytic evaluation of each proposed control strategy.

2.1.1  Atmospheric Diffusion Model
       This model,  operating on a data base consisting of a regional source
emission inventory and annual average meteorological data, produces expected
ground level pollutant concentrations on an annual arithmetic average basis.
Expected ground level concentrations are calculated at a large number
(200-250) of receptor sites throughout the region.  Isopleth maps and other
visual displays of projected air quality are produced to aid in regional
evaluations.  Existing air quality measurements are used to verify the
predicted concentration values so that further extrapolations and projections
can be made with some assurance (see Section  2.3).  The atmospheric diffusion
model provides the key link between pollutant emissions and ambient air
quality necessary to make informed decisions relating to proposed emission
regulations.  The diffusion model, by providing a set of factors relating
each emission source to receptor points throughout the air quality control
region, allows the effect of various degrees of emission reduction to be
examined in terms of expected ambient pollutant concentrations.

-------
2.1.2  Control Cost Model
       A complete evaluation of an air pollution control strategy should
include consideration of the various control techniques and measures which
would be required by the emission reduction plan.  This can be accomplished
by an examination of all the control alternatives available to each source
within the region.  This examination should include not only the control
efficiencies expected from the various control measures but also an estimate
of the cost of each measure.  Only with such information developed on the
basis of available control technology can a judgment  be made concerning
the feasibility and cost of various emission reduction plans.  The Control
Cost Model prepares a listing of applicable control techniques for each
pollution source identified in the regional emission inventory.  This
listing defines the types of available devices or control measures and
estimates the control efficiency and cost of each.  The data generated
by this model is utilized in the subsequent control strategy evaluation
section of the program.
2.1.3  Control Strategies Model
       This model operates upon information produced by the two computer
models described above to provide summary compilations relating to the
regional effects of various control strategies.  Control strategies consist
of a set of compatible emission standards covering all political jurisdictions
and source types included in the air quality control region.  Emission
standards, the basic building blocks of control strategy, generally specify
maximum emission levels of a particular pollutant for certain source types.
A combination of emission standards covering all the sources of a pollutant
is thus an emission control strategy.  By applying the emission reductions
which would be required under each strategy to the atmospheric diffusion
model described above, it is possible to estimate the ambient air quality
levels which would result.  Also, the overall cost to the region of
bringing each source into compliance with the various emission standards
is estimated.  The degree to which current control technology is able to
supply the required emission reductions is available for review.  The
Control Strategies Model is capable of simulating a variety of control
alternatives available to regional control officials and provides them
information with which to judge the relative merits of each.  Regional
growth predictions and other factors can also be analyzed with the model.


-------
     The overall computer simulation program thus provides the user with
the type of data on which an informed judgment concerning air quality
control regulations may be based.

2-2  RATIONALE FOR SELECTION OF OPTIMAL STRATEGY
     Several criteria are available with which to measure the desirability
of any control strategy.  The use of the computer simulation modeling
technique aids control strategy selection by providing detailed technical
estimates of the regional effects of various alternative strategies.  The
following is a list of the criteria used in selecting the optimum control
strategy in this Implementation Plan, together with a brief description of
how these criteria are compiled.

2.2.1  Compatibility with Air Quality Standards
       Air quality standards for particulate and sulfur dioxide pollutants
have been adopted by the three states making up the MCIAQCR.  The primary
purpose of emission control regulations is to bring ambient pollutant
levels into compliance.  By simulation modeling of the emission reductions
required, a control strategy can be evaluated with atmospheric diffusion
calculations.   The process leads to rejection of those strategies under
which emission levels remain too high to allow achievement of the desired
air quality.

2.2.2  Regional Cost
       After one or more strategies have been found which will permit
attainment of air quality standards, the total cost of implementing
these emission standards must be considered.  As was mentioned in
Section 2.1  tne simulation model being used provides an estimate of
cost based on available control technologies.  If two control strategies
promise nearly equal ambient air quality, then the less costly of the
two would be the most desirable.  In addition to the overall cost of
implementing a particular control strategy, some source categories may
experience greatly different control requirements under different strategies.
The computer simulation output enables examination of this phenomenon with
respect to important source categories.

-------
 2.2.3   Enforceability
        Certain types  of  emission  standards may  be  easier  for  a  control
 agency  to administer  and enforce  than  others; even  though  equivalent
 pollutant reductions  are required.   Field experience  gained in  actual
 control agency operations is  invaluable  in making  an  evaluation of this
 factor.  The control  agency resource requirements  may well be influenced
 by  the  type  of emission  standards ultimately  adopted.

2.2.4   Summary
        Each  of the  alternate  strategies  was evaluated according to the above
 criteria and the  optimum set  of emission standards was selected.  These
 emission standards  were  used  in formatting the proposed control regulations
 (Section ik2).

2.3   MODEL VERIFICATION
     The use of measured  ambient  pollutant  data is  an  essential
 step in the  simulation process.   The model verification or validation compares
 model estimates of  pollutant  concentration with  actual measured values.   Several
 potential errors  in the  atmospheric  transport and  diffusion calculations
 may be  examined and systematically accounted  for by this  procedure.
     a)  The pollutant emission inventory can be examined for consistency
         with air quality measurements.  Errors  or omissions  in the  inventory
         are often  detected at this  stage and may  be  corrected  before
         continuing with the  strategy  simulation exercise.
     b)  Topographic  conditions peculiar to the  air quality region may be
         evaluated.   While the diffusion model  does not explicitly consider
         terrain  features, their  effect  on air  quality may be accounted for
         by  the verification  process.
     The basic results generated  by  the  model verification are  a  statistical
 regression line relating measured to calculated  ground level  concentrations
 and a correlation coefficient.  Based  on the  correlation  coefficient and  the
 number  of measurement stations, it is  possible  to  make a  statistical estimate
 regarding the validity of the model  predictions  compared  with actual air
 quality measurement.  A  high  correlation coefficient  (close to  unity) indicates
 that the diffusion  model results  correctly indicate the trend in  pollutant
 concentrations as measured in the region.


-------
     The regression line relating predicted to measured pollutant concen-
trations is used to correct the model estimates.   The two parameters of the
linear regression each have a particular meaning  and interpretation in the
diffusion model verification.
     y-Intercept - The regression line may be visualized by plotting
                   measured versus calculated concentrations on the
                   x and y axis, respectively, of a scatter plot diagram
                   (See figures 2-2 and 2-5).  The y intercept, yo, is
                   the minimum value that may be  predicted using the
                   regression line to relate calculated to measured con-
                   centrations.  In this sense, y  may be considered a
                   background concentration.
           Slope - The slope of the regression line indicates the amount
                   of increase observed in the measured concentrations
                   (or in the concentration predicted using the regression
                   line) due to a given increase  in that calculated by the
                   diffusion model.
     The air quality data available for model verification in the MCIAQCR
consisted of the results of measurements made throughout the region during
the months of November and December 1969, and January 1970.  The use of
                                                                       •
seasonal air quality data as a basis for verifying a model designed basically
to predict average annual concentration values is open to question.  Indeed
the results described in this section show that for the MCIAQCR it
was not possible to develop a useful model verification from the winter
period for sulfur dioxide.
     In addition to the air quality data, several other types of information
were used during the model verification  exercise. Meteorological data used
were the average winter mixing height as measured at the Dayton (Ohio)
Airport, and the wind direction and speed data for the three month period
collected at the Cincinnati Airport located in Covington, Kentucky.  The
same sources of meteorlogical data were used in making the annual concen-
tration estimates based on the atmospheric diffusion model.  In this case,
however, averages taken over five years were used rather than a specific
annual period.  (See Appendix A for meteorological data.)
     No specific effort was made to account for the topographic features
of the region in the model verification procedure.


-------
2.3.1   Suspended Particulates
        Diffusion model verification for suspended particulates used air
quality measurements made by the 24 hour high volume filter technique.   The
location of these stations is displayed in Figure 2-1.   These stations
adequately cover the geographical area of the MCIAQCR.   A number of model
verification runs were made based on the data collected from these stations.
During the initial runs, a number of errors in both the original emission
inventory and in the air quality data were detected.    The errors were
corrected and a final verification run was made.
       Figure 2-2 displays the results of this computation.  This figure
shows the measured air quality data plotted against the model calculations
for the same location based on the emission inventory and meteorological
data.  The line shown is the regression line calculated on the basis of
the data.  The regression is highly significant in a statictical sense
(less than a 1% probability that no correlation exists).  The background,
                    3
yo, value of 36 pg/m  is also regarded as acceptable, i.e.,it represents a
reasonable approximation of background levels of suspended particulates, or
the irreducible level due to uncontrollable sources.
       The results of using the regression line resulting from this
verification to project average annual concentrations are shown in
Figure 2-3.  Available average annual measured concentrations (also
shown) correlated well with the model estimates.  Figure 2-3 indicates  that
the use of seasonal data (winter) for air quality measurements, meteorological
and emission data appeared fairly effective in the case of particulates.
       Measurements of ambient concentrations of suspended particulate
pollutants have been made at various locations in the MCIAQCR since 1957.
For the most part, the sampling sites were located in or near the City
of Cincinnati and were operated for periods of one year or less.  As a
result, there is a paucity of data for the Region as a  whole.  There are
four locations (three in Cincinnati and one in Covington) where data are
available for the year 1969.  These four stations include three which
are a part of the National Air Sampling Network and the CAMP station.
The annual (1969) geometric mean concentrations at these stations are
shown on a map of the Region (Figure 2-3).  Included on the map are the
geometric mean concentrations for the stations in the Northern Kentucky
Air Monitoring Network (July 1968 to April 1969) and the Cincinnati

-------
Figure 2-1.  Particulate Measuring Stations
             Used in Model Verification

-------
00
•a
a
t-i
    140-1
    120-
    100-
     80-
     60-
     40-
                                                                          70
     20-
slope = .53


    R = .85
                 20        40        60        80

                                Calculated  (yg/m3)
    100
120
140
160
                     Figure  2-2.  Particulate Diffusion Model Verification

                                   (Winter Data - November 1969  -  January 1970)

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                                                          V-A.
                                      KENTON    CAMPBELL
• 1969 NASN, CAMP
o 1968/1969 Northern  Kentucky Network
  Concentration in yg/nr*
                     Figure 2-3.  ANNUAL GEOMETRIC MEAN CONCENTRATIONS OF
                                 SUSPENDED PARTICULATE POLLUTANTS AS MEASURED
                                 AT SELECTED SAMPLING STATIONS AND  ANNUAL ARITHMETIC
                                 MEAN CONCENTRATIONS AS ESTIMATED BY DIFFUSION
                                 MODEL

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School Study (October 1967 to May 1968).
     In order to illustrate the geographical distribution of particulate
pollutants for the entire MCIAQCR, the measurement data must be supplemented
by estimates of concentration from the diffusion model.  The isopleths
shown on Figure 2-3 represent annual arithmetic mean concentrations as
determined by the model using the 1969 emission inventory and climatological
data for the period 1965-1969.  (See Section 2.1  for discussion of model.)
     There is an inconsistency in Figure 2-3 in that the measurement data
are presented as geometric means and the diffusion model estimates are pre-
sented as arithmetic'means.  This inconsistency stems from the fact that
the annual air quality standards are expressed in terms of geometric means
        3                               3
(65 Mg/m  for Kentucky and Ohio, 75 yg/m  for Indiana) and the Martin-Tikvart
diffusion model provides only annual arithmetic mean concentrations.  For
comparative purposes, the arithmetic means can be reduced by 10-15 percent
to obtain geometric means.
     From Figure 2-3 it is apparent that there are large areas within
the MCIAQCR where the air quality standards for particulate pollutants
are being exceeded.  Areas of high pollution are centered on Cincinnati
and Newport, Kentucky, the City of Hamilton and the vicinity of the Ohio
and Indiana border near the Ohio River.
     This verified diffusion model was used to test various alternative control
strategies (Section 2.4).

2.3.2  Sulfur Oxides
       Considerably more difficulty was experienced in obtaining a
satisfactory model verification for sulfur oxides.  Problems relating to
data incompatibility with the diffusion model caused the simulation technique
to be abandoned for this pollutant.
       Initial air quality data were available from fourteen measurement
sites for the three month winter period (November 1969 through January
1970).  Three measurement techniques were used; West-Gaeke analysis
employing liquid impinger samplers, continuous conductimetric measurements,
and continuous colorimetric measurements.  A satisfactory relationship
could not be developed between the different sampling and analytic
techniques used and it was necessary to restrict the model validation

-------
exercise  to a single measurement type.  At one station, number 106, both
West-Gaeke and continuous colorimetric measurements were made during the
three month study period.  The results show that colorimetric measurements
                             3
gave average  readings 50Mg/m  higher than the West-Gaeke technique during
the three month period.  Since the West-Gaeke method is widely regarded
as the standard method only  these measurements were  used in the model veri-
fication  procedures.
     Other sampling stations were not used because insufficient samples were
taken to  provide a representative average of the sampling period.  The result
of these  restrictions was to reduce the number of air quality measuring sites
available for verification to seven and to reduce the geographical coverage
of the region.
     Figure  2-4 shows the locations and identification numbers of the
sampling  stations used in the model validation.  The relationship between
measured  and calculated sulfur dioxide concentrations at these sites is
shown in  Figure  2-5.  The regression  line and  its  coefficients are  also  displayed
in this figure.  This represents the best model verification which could be
obtained  for the winter season based on the air quality data and emission
inventory available.
     It was recognized that  any acceptable verification of the model must
be applicable to annual as well as winter conditions before the simulation
of control strategies could  be accomplished.  An attempt was made to use
annual average sulfation plate data to verify the diffusion model.  This
was unsuccessful because the sulfation data did not record a wide enough range
of air quality to yield a regression line slope that was significant in either
a statistical or practical sense.
     Annual average pollutant concentrations were calculated for the
MCIAQCR based on the model verification presented in Figure  2-5.  These
concentrations are presented in Figure 2-6.
     The  ambient air monitoring data for sulfur dioxide are more scarce,
both on a regiowide basis and locally, than vas the case for particulates.
Presentation of regional air quality must necessarily depend on measurements
gathered  at relatively few stations.   Some localized and short-term measure-
ments specific to this state are presented in Section 1.

-------
Figure 2-4.  SULFUR OXIDE MEASURING STATIONS USED
             IN MODEL VERIFICATION

-------
   100-1
6

W)
0)
l-i
3
CO
ed
0)
    60H
    40 H
    20H
                v  =  32.4
                 o
             slope =  .41

                 R =  .89
                20
40        60       80

Calculated  (yg/m3)
120
140
                    Figure 2-5.  WINTER SULFUR OXIDES MODEL VERIFICATION
                                  (November 1969 - January 1970)

-------
                                         KENTON    CAMPBELL
•  NASN
o  Northern Kentucky  Network
   Concentration  in ug/m3
                        Figure  2-6. ANNUAL MEAN CONCENTRATION OF SULFUR OXIDE
                                    AS MEASURED AT SELECTED SAMPLING STATIONS
                                    AND ANNUAL ARITHMETIC MEAN CONCENTRATIONS
                                    AS ESTIMATED BY DIFFUSION MODEL

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     Figure  2-6 shows the available annual average sulfur dioxide
measurements taken in the MCIAQCR during 1968-1969.  The Northern
Kentucky Network was operated from August 1968 through April 1969.  The
National Air Sampling Network (NASN) sites shown represent averages for
the calendar year 1969.  Also shown in Figure 2-6 are the annual average
isopleths predicted by the computerized atmospheric diffusion model.  (See
Sections 2.2 and 2.3).  It should be noted that the concentration values
show as model predictions (isopleths) and those from NASN stations are
presented as annual arithmetic means.  Kentucky's sampling results are displayed
on an annual geometric mean since the adopted Air Quality Standard in
that state is in terms of a geometric mean.  Comparison can be made between
the two sets of values by increasing the Kentucky values by about 20%.
     It is obvious from an examination of Figure 2-6 that the model pre-
dictions and measured air quality data are not in agreement.  The model
appears to be over-predicting by a factor of approximately two in the area of the
sampling stations.  This indicates that the verification developed for the
diffusion model during the winter season is not applicable when projected
to annual average conditions.  Unfortunately, the annual data presented
in this section was found to be inadequate for model verification because
of lack of range in sampled values and the lack of proper geographical
coverage.  The results presented in Figure 2-6 are discussed further in Sections
2.3.2 and 2.4.3.
     It was apparent from the comparison of verified model estimates and
annual average measurements (by the West-Gaeke technique) that the winter
verification which had been done did not accurately reflect the annual
average sulfur dioxide concentrations in the MCIAQCR.  Since it was
impossible to verify the model on an annual basis it was decided to abandon
the computer simulation technique for the evaluation of sulfur oxide control
strategies.

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2.4  CONTROL STRATEGY SELECTION
2.4.1  Particulate Control Strategies
       A total of 18 particulate control strategies was tested in the
simulation exercise.  Each of these strategies specifies an allowable emission
level for each type of source within the region (e.g., fuel combustion,
industrial process and solid waste disposal).
       1.  Existing Control Regulations Through the Region
           This strategy displayed the air quality resulting from complete
           compliance with existing control regulations in the MCIAQCR.
            Figure 2-7shows existing fuel combustion standards.   Table
           2-1 indicates existing standards for industrial processes
           and describes existing solid waste  disposal  standards.
       2.  Most Stringent Existing Regulations Applied  Through Region
           Emission standards for fuel combustion, industrial processes,
           and solid waste disposal were taken from the existing regula-
           tions of Kentucky, Indiana, and Cincinnati,  respectively.
       3.  Most Stringent Existing Fuel Combustion, Second-Most Stringent
           Industrial Process Regulation
           Emission standards for fuel combustion, industrial processes,
           and solid waste disposal were taken from the regulations of
           Kentucky, Indiana, and Cincinnati.
       4.  Most Stringent Industrial Process Regulation, Second-Most
           Stringent on Fuel Combustion
           Industrial process and solid waste disposal  standard as for
           Strategy 2, with Cincinnati's fuel combustion control standard.
       5.  Cincinnati Particulate Regulations Applied Throughout the Repion
       6.  Maximum Technology Control
           This strategy allows fuel combustion sources to switch to
           natural gas and eliminates all incineration.  Industrial process
           sources are controlled with the most effective control device,
           usually in fabric filter or efficient electrostatic precipitation.
       7.  Maximum Technology Control without Fuel Switching
           This strategy allows fuel combustion control with the best

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  10
   1
 0.8
0.24
 0.1
0.01
                                           11 • • 1111 if i • • • ijy • 11 • ii | • i • i

                                           "^^r—--iiJN,
                                                Indiana
                                                                                «»-•».
                                                                   Stack Height (it.)
                                                                                            Kentucky
                      10
       100                1000

Equipment Capacity Rating (10  BTU/hr)
10,000
100,000
                   Figure 2-7.  Existing Emission Standards  in the MCTAQCR Based on Input Heat

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  Table 2 - l(.A) Existing Particulate Emission Standard
            for Industrial Process Sources (.City of
            Cincinnati Regulation!
Effective Height of                  Allowable Emissions
Process Vent, ft^                 '	 Ib/hr ^
Up to    50                                   k
         75                                  10
        100                                  17
        125                .                  27
        150                                  Ho
        175                                  53
        200                                  68
        225                                  88
        250                                 110
        275                                 130
        300                                 160
(a)
    Allowable Emissions for intermediate heights shall be
    determined by linear interpolation.
(B)  Standard for particulate emissions from incinerators:
    O.U pounds of particulate matter per 1000 pounds of
    discharged gases adjusted to 12 percent C0p.  (City
    of Cincinnati)

-------
           available control device applied.   Other sources are controlled
           as in strategy number 6 above.
       8.   Maximum Technology Control'with Fuel Switching,  Solid Waste
           Disposal Control To Level of Existing Cincinnati Standard
       9.   Most Stringent Existing Regulations, Maximum Technology
           Without Fuel Switching
           Industrial processes and solid  waste disposal are controlled to
           same level as in Strategy 1.
      10.   Most Stringent Set of Control Standards, Not Maximum Technology
           Stringent heat input curve for  fuel combustion sources (Figure
            2-8A)  process weight curve for industrial processes (Figure
            2-9A)  and 0.05 grains/scf allowable emissions for incinerators.
      11.   Same As Strategy 10 with Relaxation of Solid Waste Disposal
           Standard
           Incinerator emission must be controlled to 0.2 grains/scf.
      12.   Same as Strategy 10 with Process Weight Standard for Industrial
           Process Emissions as Shown in Figure 2-9B
      13.   Same as Strategy 11 with Process Weight Standard (Figure 2-9B
      14.   Same as Strategy 10 with Heat Input Standard for Fuel Combustion
           Sources as Shown in Figure 2-8B
      15.   Same as Strategy 11 with Standard for Fuel Combustion (Figure
           2-8B)
      16.   Same as Strategy 12 with Standard for Fuel Combustion (Figure
           2-8B)
      17.   Same as Strategy 13 with Standard for Fuel Combustion (Figure
           2-8B)
      18.   Potential Emission Standard
           This standard relates the allowable emissions for each source
           to its uncontrolled or potential emissions.   Standard is applied
           to all source categories and is displayed in  Figure 2-10.
     This set of strategies represents a blend of control standards
existing in the Region, theoretical maximum control levels, and control
standards developed and used in other parts of the country.  Simulation of

-------
       10
  •fl
  P
  £
      0.6
ro
o t

      1.15
  en

  o  0.11

  3    0.1
  o
    ON



  I
      0.01
                              10
       100                 1000        4000   10,000


Equipment Capacity Rating (10^ BTU/hr)
100,000
                       Figure 2-8.  Additional Heat Input Type Standards Tested in Proposed MCTAQCR


-------
      100
       30
       10
(V)
10
  W
  cn
      0.1
         10
100
 1000                10,000


Process Weight Rate (ib/hr)
100,000
1,000,000
                        Figure 2-9.    Two  Sets  of  Emission  Standard Curves  for Industrial Process Type

                                       Emissions Used in  the Particulate  Control Strategies Evaluated for


-------
t-1
o
 M
n
c
M  M

ro  M
ro  £«£
   M
   C/l
   en
   M

   §
T)
O


3
CL
O
                                      Figure 2-10.
   1000
    300
                                                       ALLOWABLE PARTICULATE EMISSIONS BASED ON

                                                       THE POTENTIAL OR UNCONTROLLED SOURCE EMISSIONS

                                                       APPLIED TO INDUSTRIAL PROCESS, FUEL COMBUSTION, & SOLID WASTE DISPOSAL
    100
     60
     10
                             10
                                                   100
1000
10,000    30,000
100,000.

-------
these standards with the resulting ground level concentration values and
required emission reductions allows an informal choice regarding that set
of control standards most suited to the needs of the MCIAQCR.

2.4.2  Particulate Simulation Results
       After the 18 particulate control strategies described in the previous
section were selected, a control strategy simulation was carried out.  This
simulation predicted ground level particulate concentrations on the basis
of the verified atmospheric diffusion model discussed in Section 2.3.
       Table 2-2 provides a brief summary of the results of this exercise.
The task at this stage was to select a small group of potentially feasible
control alternatives for further detailed analysis.  The two receptor sites
noted in this tabulation were selected as being roughly descriptive of the
overall regional air quality.
      Three relatively distinct groups of control strategies can be defined
in Table 2-2.  The first group consists of Strategies 1 through 5 and essen-
tially represents various combinations of emission standards already being
applied in political jurisdictions within the MCIAQCR.  In general, these
strategies had a fairly low regional cost and could be administered rather
easily.  None of them, however, appeared to give promise of achieving regional
                                3         3
air quality standards of 65 yg/m  (75 yg/m  in Indiana).  It was decided
that Control Strategy 1, existing regulations, should be included in the
more detailed strategy analysis.
       Strategies 6 through 9 represented variations in maximum control
technology.  In general, these strategies could be characterized by having
rather high regional control costs but producing acceptable air quality
values.  Strategy 7 was included in the more detailed analysis since the
strategy should apply the most effective control techniques throughout
the region.  The administrative acceptability of this type of regulation
was not great, but a view of the best control technology was desired in
the detailed analysis.
        The third group of control strategies, Numbers 10 through 18,
represented various combinations of proposed or existing emission control
standards from throughout the country.  All seemed to produce acceptably
low ground level concentrations.  Strategies 14 through 17 also were rela-


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                                                    Selected  Receptor  Concentration
Strategy
Number
Existing
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
Regional Control Cost*
($ in millions)

1.7
3.0
2.7
2.2
1.9
20.0
6.4
5.9
5.6
7.0
6.9
7.2
7.0
3.7
3.5
3.9
3.7
not tested
264
134.8
80.0
79.5
79.0
79.8
79.3
63.5
67.7
71.0
71.5
65.1
65.3
64.9
65.1
68.8
64.5
64.2
64.3

(yg/m3)
269
141.8
83.7
82.9
82.6
83.3
83.0
66.5
70.9
75.7
76.6
68.5
68.9
68.3
68.8
71.5
67.8
67.2
67.6

*Control Cost of Point Sources Only
                      Table 2-2.  INITIAL SCREENING OF  PARTICULATE  CONTROL

-------
 tively low in cost and were considered feasible in terms of practical
 administrative considerations.  Strategies 15 and 18 were selected to
complete the group of  four strategies for more detailed analysis.  (Strategy 18
was not tested in the initial screening but was considered to be similar in
stringency to those in the 14 to 17 group.)
       After the initial strategy simulation runs, a number of minor errors
in the emission inventory data base was  discovered and corrected.  Certain
suspected program malfunctions were also investigated.  The more detailed
control strategy summaries cannot be compared with the output presented in
Table  2-2. The general results, however, were similar in both cases.
       Table 2-3 presents more complete information on those strategies
selected during the initial screening procedure.  The maximum receptor
concentration occurring after application of each strategy is presented.
Also, the emission reduction percentages are shown for both point  and
area sources and the new emission rates for these categories.
       Strategy 1, existing regulations, appears totally unlikely to achieve
satisfactory regional air quality and was dismissed from further consideration.
       The maximum concentrations reported for the other control strategies
must be interpreted with a certain degree of care.  Only for strategy 15 was
a reduction in area source emissions projected.  This was done as  a test to
determine the effect this factor had on receptor concentrations.   It was felt
on the basis of reduction in open burning throughout the region and trend in
fuel usage toward natural gas and away from coal for small fuel users that
this degree of reduction would be reasonable for any of the three  strategies.
On this basis the maximum concentration would be least (probably between 60
and 65) for Strategy 7.  Strategy 18 would be essentially equal to Strategy 15.
Since all three control strategies appear to be able to achieve the regional air
quality standards within the limits of simulation modeling accuracy,  the final
selection of a control  strategy to be proposed  for the MCIAQCR was  left  to  practical
administrative and technical considerations.
       Strategy 7 was considered to be quite difficult to administer and since
its regional cost nearly doubled that of the other two strategies, it was
eliminated.

-------
 POINT SOURCES
Strategy
Number
Existing
1
7
15
18
Percent New Emissions Rate Percent New Emission Rate
Reduction (ton/day) Reduction (tons/day) $ x

72.
97.
89.
87.

3
1
2
1
386
102
11
41
49
.7
.5
.7
.8
.0
212.
212.
212.
33. 142.
212.
6
6
6
4
6

1.
6.
3.
3.
106

6
1
3
4
$/ton removed

15.
44.
26.
28.
Maximum
Receptor
(yg/m3)
150
137
76
69
81
.5
.9
.1
.2
.9

-------
    Strategy 15 was chosen over Strategy 18 since it contains more familiar
types of emissions standards.  For this reason it was considered .to be
politically more acceptable and administratively easier to handle.
     A detailed breakdown of the emission reductions required under Strategy
15 is presented in Table 2-4.  Examination of this table, coupled with a
review of particular source-control device combinations, lead to the conclusion
that although significant emission reductions are required, they are not
beyond the state-of-the-art in control technology.
     An isopleth plot of ground level particulate concentrations after
application of this strategy, as shown in Figure  2-11.  Comparison with the
plot of existing concentrations (Figure 2-6) graphically shows the improve-
ment in regional air quality expected following application of Control Strategy
15.
     To insure that the selected set of control standards would indeed be
able to achieve and maintain acceptable air quality levels over the next
several years, an exercise was carried out to project emission rates to the
year 1980.  These projections were based on economic projections for the
MCIAQCR supplied by the United States Department of Commerce.  Factors with
which to scale existing emission levels were developed for each industrial
classification.  The revised emission rates expected for the year 1980
are displayed in Table 2-5.  Factors were developed to project emission levels
based on the 1969 emission inventory to a 1980 basis.  These projections
were by industrial and commercial categories.  The same percentage control
of emissions that is currently required was assumed to continue thooughout
the projection period.  As can be seen, the overall regional emission rate
actually declines slightly during this ten-year period.  The decline is
basically due to large increases projected for relatively nonpolluting
industrial classifications and to a change in regional fuel usage toward
increased use of natural gas and oil.  Based on this anaylyis the emission
standards comprising Particulate Control Strategy 15 appears to be suitable
to the needs of the MCIAQCR.  Figure 2-12 displays the projected ground level
concentrations for 1980.

-------
                                                                 SOURCE CLASSIFICATION
   Political  Jurisdiction
Area
Apartment
Commercial
Government
                                                           Industrial
Fuel
Combustion
Process
Power
Plants
Solid
Waste
Total
Cincinnati
Existing
Controlled
% Reduction
Indiana
Existing
Controlled
% Reduction
Kentucky
Existing
Controlled
% Reduction
Ohio
Existing
Controlled
% Reduction
Region
Existing
Controlled
% Reduction

8030
5402
32.7

1679
1131
32.6

4526
3029
33.1

19012
12738
33.0

33248
22301
32.9

708
354
50.0

0
0
0

44
29
33.3

0
0
0

752
383
49.0

2464
650
73.6

894
117
86.9

18
18
0

22177
3099
86.0

25554
3884
84.8

365
365
0

91
91
0

7490
544
92.7

16,969
2,427
85.7

24,915
3,427
86.3

0
0
0

23,634
•1,482
93.7

0
0
0

58,104
5,577
90.4

81,738
7,059
91.4

1555
376
75.8

489
0
100

529
0
100

5592
' 124
97.8

8165
500
93.9

13,122
7,147
45.5

26,787
.2,821
89.5

12,607
3,621
71". 3

121,855
3,966
80.3

174,371
37,555
78.5
I
N3
00
                              TABLE  2-4   .  PARTICIPATE EMISSIONS FOLLOWING APPLICATION OF
                                           PROPOSED EMISSION STANDARDS BASED ON 1969 EMISSION

-------
                                      KENTON    CAMPB
            Figure 2-11. Predicted Ground Level Concentrations  Following
                        Application of Proposed Control  Strategy
                        (1969 Emission Inventory)
Note:  Annual Average Concentrations in

-------
                                                      SOURCE CLASSIFICATION


Political
Cincinnati



Indiana



Kentucky



Ohio



Region





Jurisdiction Area

Existing
Controlled
% Reduction

Existing
Controlled
% Reduction

Existing
Controlled
% Reduction

Existing
Controlled
% Reduction

Existing
Controlled
% Reduction

8030
5402
32.7

1679
1131
32.6

4526
3029
33.1

19012
12738
33.0

33248
22301
32.9
Apartment
Commercial
Government

741
369
50.0

0
0
0

55
36
33.3

0
0
0

796
405
49.1
Industrial
Fuel
Combustion

3467
912
73.6

1172
153
86.9

22
22
0

31467
4398
86.0

36128
5485
84.8


Process

434
434
0

139
139
0

9191
668
92.7

20279
2902
85.7

30043
414
86,2

Power
Plant

0
0
0

23,634
1,482
93.7

0
0
0

9,213
887
90.4

32,846
2,369
92.8

Solid
Waste Total

5209
1259
75.8

1639
0
100.0

1774
0
100.0

18732
416
97.8

27353
1675
93.9

17,881
8,377
53.2

28,262
2,905
89.7

15,567
3,756
- 75.9

98,703
21,342
78.4

160,414
37,380
77.3
K3
I
CJ
o
                            TABLE 2-5.    PARTICIPATE  EMISSIONS  FOLLOWING APPLICATION OF
                                          PROPOSED  EMISSION STANDARDS  BASED ON PROJECTED 1980

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                            KENTON/^ CAMPBELL
Figure 2-12.   Projected Ground  Level Particulate Concentration
              Following Application of Proposed Control Strategy
              (Projected 1980 Emission Levels)
Note:   Annual Average Concentration  in .yg/m3

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2.4.3  Sulfur Oxides Control Strategy
       It was not possible on the basis of available air quality and emission
data to develop a suitable annual verification of the diffusion model for
sulfur    oxides.  (See Section 2.3.2.)  Control strategy development for
this pollutant had to be undertaken by the use of rollback considerations.
(The computer simulation exercise, however, was still performed on a limited
group of control strategies.  The amount of pollutant reduction required
under  various emission reduction plans is necessary input to this strategy
section procedure.  Four sulfur oxide control strategies were simulated
on a regional basis.  Each of these strategies applied specific restrictions
to the fuels used within the MCIAQCR.  The four strategies, in order of
increasing stringency, are   defined as follows:
       1.  Limitation of all fuel to 1.25% sulfur content or less
       2.  Limitation of all fuel to 0.8% sulfur content or less
       3.  Limitation of all fuel to 0.3% sulfur content or less
       4.  Switch of all combustion sources to the use of natural gas
       On an annual basis, the limited air quality data for SOo available
in the MCIAQCR indicate  that ambient S02 levels are not exceeding the Air
                                              o
Quality Standard (Ohio and Indiana) of 43 yg/m .  On a short-term basis,
however, the existing levels exceed the standards.  This is discussed in
more detail in Section 1.7.
       During the three-month effort to collect data for this study
(November 1969 through January 1970) periods were observed during which the
average for 24 hours and for one hour were higher than allowed by the
standard.  At sampling station number 77(located in Ohio),the maximum
hourly average was 1000 yg/m .  This is compared with an Air Quality
Standard (Ohio and Kentucky) for the maximum one-hour average in any year
of 858 yg/m^.  Since the sampling only covered a period of three months,
a minimum reduction of 14% in ambient air quality is required to comply
with air quality standards.
       During this same period, sampling station number 70 (located in
Ohio) recorded a maximum 24-hour average of 371 yg/m .  The maximum 24-
hour average allowed by the Air Quality Standards (in all jurisdictions*)
*0hio's standard specified that this value shall not be exceeded more

-------
is 286 yg/m^.  An overall reduction in sulfur dioxide pollution levels of
23% will be required to bring this value into compliance with the standards.
The observations cited in this and the preceding paragraph indicate that air
pollution levels need to be reduced approximately 20 to 25%.
       An examination of continuous air monitoring data collected over a
period of six months  is shown in Table 2-6.   These data also reveal the
existence of undesirably high, short-term, sulfur dioxide concentrations.
In particular, the hourly maximum for April 1970 was 1550 yg/m^.  This value
exceeds the adopted air quality standard of 858 for this averaging time
by about 45%.  These   excessive  short-term concentrations illustrate the
need for a regional reduction of sulfur oxides emissions.
       A reduction of each sulfur oxide source in the region by the specified
percentage is not an administratively attractive nor technically sound
control alternative.  Since the majority of this type of pollutant emission
is generated by fuel combustion,  various control alternatives limiting
allowable fuel sulfur content were examined.   Reduction of the allowable
sulfur content in fuels to 0.3% or 0.8% produced greater emission reductions
than would seem to be required by the observational data cited above.  The
application of the existing City of Cincinnati fuel sulfur content regulation
throughout the region was determined to produce sufficient emission reductions.
This regulation has been proven to be technically and administratively
feasible in one of the political jurisdictions comprising the MCIAQCR and
is recommended in this implementation plan as the basis for a regionwide
sulfur oxides control strategy.  A slight change to the existing Cincinnati
regulations is proposed for non-power plant fuel combustion sources.  According
to the detailed emission inventory information compiled for this study,
nearly all smaller fuel users within the region are already using fuel with
less than 1.0% sulfur content.  Accordingly,  to prevent increases in emission
from these source categories, the proposed limitation on sulfur content in
fuels not used for electrical power generation is set at 1.0%.
       Table 2-7 displays the emission reductions required by the adoption
of this strategy on a regionwide basis.  By far, the greatest reduction in
sulfur oxide emissions occurs in the electric power generation source eater-
gory.  This reflects the fact that these sources are the only significant
users of high sulfur fuels in the region.  This pattern of emission reduction

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              Table 2-6.  <\MBIENT SULFUR DIOXIDE CONCENTRATIONS
                          AS MEASURED AT THE CAMP STATION,
                          CINCINNATI •
Period
January 1970
February 1970
March 1970
April 1970
May 1970
June 1970
Arithmetic Mean
 Concentration*
     136
      94
      68
      55
      31
      24
24-Hour
Maximum*
  286
  186
  305
  251
  106
  106
One-Hour
Maximum*
  675
  758
  780
 1550
  638
  492
*A11 concentrations are in units of yg/m .

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                                               SOURCE  CLASSIFICATION
        Political Jurisdiction
Area
Apartment
Commercial
Government
   Fuel                Power      Solid
Combustion  Process    Plants     Wastes
TOTAL
Cincinnati



Indiana



Kentucky



Ohio



REGION



Projected
Controlled
% Reduction

Projected
Controlled
% Reduction

Projected
Controlled
% Reduction

Projected
Controlled
% Reduction

Projected
Controlled
% Reduction

7,227
7,227
0

1,204
1,204
0

3,029
3,029
0

12,632
12,632
0

24,093
24,093
0

1,576
1,576
0

0
0
0

102
. 102
0

0
0
0

1,679
1,679
0

3,398
3,398
0

1,328
1,328
0

0
0
0

25,017
20,856
16.6

29,743
25,582
14.0

0
0
0

0
0
0

0
0
0

8,584
2,609
69.6

8,584
2,609
69.6

0
0
0

123,844
50,895
58.9

0
0
0

196,052
93,206
52.5

319,896
144,102
55.0

390
390
0

14
14
0

14
14
0

2,047
2,047
0

2,467
2,467
0

12,592
12,592
0

126,392
53,443
57.7

3,146
3,146
0

244,334
131,352
46.2

386,465
200,534
48.1
NJ

Ln
                            Table  2-7.  EFFECT OF PROPOSED SULFUR OXIDES CONTROL
                                        STRATEGY ON MCIAQCR EMISSION LEVELS
                                        (tons of pollutant/year)(based on

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appears to be consistent with the goal of reducing maximum short-term ambient
concentrations.  Large    emission sources are very important under the
unfavorable meteorological conditions which cause the highest hourly and
daily concentrations.
       Table 2-8  displays the result of the projection of regional growth
and the associated sulfur oxide emissions to the year 1980.   Despite pro-
jected regional population and commercial growth, the expected levels of
sulfur oxide emissions remain fairly constant.  For this reason,  it appears
that the proposed control strategy, as described above, will be adequate to
achieve and maintain air quality standards during this period.

2.5  PROPOSED CONTROL STRATEGY
     The following emission control strategies were selected for adoption
throughout the MCIAQCR on the basis of procedures and considerations presented
in the preceding section (2.4).  These strategies represent  emission limita-
tion standards which, when adopted and enforced, should lead to acceptable
levels of both suspended particulate and sulfur dioxide as defined by the
regional Air Quality Standards.  Legally enforceable control regulations
based on these emissions standards are presented in Section 4.2.
     The proposed particulate control strategy consists of emission standards
covering three general categories of emissions sources:
     •  Industrial Process Emissions
        Sources within this category are allowed emissions based on
        process weight as defined by curve A, Figure 4-11 covering
        this source category.  (This standard is fully defined in
        Section 4.2, Proposed Control Regulations.)
     •  Fuel Combustion Emissions
        Allowable emissions are defined according to the curve B, Figure 4-10
        for heat input versus mass particulate emission rate.  (This standard
        is also presented in Section 4.2)
     •  Solid Waste Disposal
        Incinerators are allowed emissions of 4 pounds/ton of refuse charged
        and open burning is prohibited under the standard relating to this
        source category.
     The proposed regional sulfur oxides control strategy consists of those
emissions standards on which the regulations already in effect in the City of
Cincinnati are based.  Two emission categories are considered by these

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                                               SOURCE CLASSIFICATION
      Political  Jurisdiction
Area
Apartment
Commercial
Government
   Fuel
Combustion
Process
Power
Plants
Solid
Wastes
TOTAL
Cincinnati
Projected
Controlled
% Reduction
Indiana
Projected
Controlled
% Reduction
Kentucky
Projected
Controlled
% Reduction
Ohio
Projected
Controlled
% Reduction
REGION
Projected
Controlled
% Reduction

7,227
3,431
52.5

1,204
547
52.5

3,029
1,423
52.5

12,632
6,000
52.5

24,093
11,402
52.5

1,569
1,569
0

0
0
0

138
138
0

0
0
0

1,708
1,708
0

4,883
4,883
0

1,741
1,741
0

0
0
0

35,058
29,238
16.6

41,683
35,847
14.0

0
0
0

0
0
0

0
0
0

13,041
3,963
69.6

13,041
3,963
69.6

0
0
0 -

123,844
50,900
58.9

0
0
0

76,536
36,355
52.5

200,381
90,171
55.0

1,306
1,306
0

47
47
0

47
47
0

6,858
6,858
0

8,259
8,259
0

14,986
11,190
25.3

126,837
53,652
57.7

3,215
1,609
49.9

144,127
77,540
46/2

289,167
150,077
48.1
I
U>
                                       Table 2-8.  EMISSIONS FOLLOWING APPLICATION OF
                                                  PROPOSED SULFUR OXIDES CONTROL STRATEGY
                                                  BASED ON 1980 EMISSION PROJECTIONS

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       •  Industrial Process Emissions
          Sulfur oxide emissions from industrial process are limited to
          2000 parts per million by volume of the exhaust gas stream.
          Acid plants shall control to 36 pounds/ton acid for sulfuric
          acid plants.
       •  Fuel Combustion Emissions
          The maximum sulfur content of fuel used shall be 1.25% with 1.00%
          being the allowable limit for smaller combustion sources.
2.6  TIMETABLE FOR IMPLEMENTING PROPOSED REGULATIONS
     Implementation of control regulations logically divides into two
separate tasks.  First, the new regulation must be officially adopted by
the responsible state agency.  Second, field enforcement and control of
pollution sources affected by the regulation must be carried out.  The
length of time required to carry out these actions are discussed in the
following two sections.
2.6.1  Adoption of Proposed Control Regulations
       Indiana's Air Pollution Control Board has been granted by the State
Legislature all the powers necessary to hold public hearings, and adopt
control regulations»•,  Since, no additional powers are needed, the process
will begin immediately.  The following steps will be carried out in this
effort.
       1.  Prepare proposed control regulations in appropriate legal form
           Section 4.2 of this document indicates the general form the
           control regulations should take.  Administrative considerations
           may require redrafting.  Time required will be one month.
       2.  Hold public hearings
           This is a necessary step in assuring public acceptance and
           cooperation with the expanded air pollution control activities
           proposed in this document.  This will be completed by November 2,
           1970.
       3.  Final adoption
           It will be necessary to incorporate changes or additions deemed
           acceptable following the public hearings; and possibly a final
           hearing would be necessary at this stage.  This step will be
           completed by January 4, 1971.

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2.6.2  Enforcement of Control Regulations
       The primary portion of   the Indiana enforcement program will be the
permit and source surveillance system described in Section 6.2.  It is antic-
ipated  that legislation proposed in Section 3 to all the Indiana APC Board
to set up and operate a permit system will be passed by the Legislature by
January 1971.  It is anticipated that source registration and  surveillance
procedures and the permit system will be fully operational within 18 months
following the adoption of the necessary legislation and regulations (i.e.,
by July 1972).  State actions to begin to achieve compliance with the proposed
control regulations will begin well before this time.
       Particulate emission sources should be brought substantially into
compliance with the new regulation by July 1972.  There are no new control
technologies necessary to bring particulate emission sources into compliance
with the proposed standards.  The approximate 18-month period allowed for
compliance after the adoption of the control regulations allows pollution
sources an opportunity to design, fabricate or purchase, and install
necessary control devices.
       The regulations relating to sulfur oxides emissions control may
require a longer period in which to achieve compliance.   Choice of the most
satisfactory control method is usually made by the source after all of the
various technical, economic, political and social factors are given serious
consideration.  The options for fuel substitution are numerous.  Natural
gas, low sulfur fuel oil, low sulfur coal, and coal-derived gas or oil are
available or can be made available at a price..  Although considerable pilot
plant work has been conducted and many processes are commerically available,
the application of full-scale flue gas desulfurization processes to coal-
fired power plants is limited.  As soon as possible, but not later than six
months after the adoption of the proposed control regulations,  the applicable
sources will be required to submit a control plan of how they will come into
compliance.  The control plans should cover no more than a two-year period.
Therefore, by July 1973 the sources will be in compliance.  During this
period, the data from the air quality monitoring network will be closely
observed to determine the exact trends in the sulfur dioxide concentrations
in the Region.  If this data indicates that additional control is needed,
the Implementation Plan will be modified accordingly.

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                            3. LEGAL AUTHORITY
 3.1 SCOPE OF DISCUSSION

     This section will address itself to legal deficiencies and remedies
of the various aspects of air pollution control as they relate to the
State of Indiana.  Generally, the discussion will be confined to the
adequacy of legal authority of the regional entity to fully implement
a control program, including the organization of regional enforcement
activities, promulgation and enforcement of regulations, and implementation
of emergency action.  However, the legal aspects of the proposed emission
and control regulations are not discussed in this section.
     In general, the format of this section is designed to identify the
legal problems which exist in Indiana  and the legislative and regulatory
action necessary to remedy the deficiencies found in the respective programs.

3.2  GENERAL DISCUSSION OF THE POWERS OF ADMINISTRATIVE AGENCIES
     It is the general rule that the powers of administrative agencies
are limited by the intent of the legislature as expressed in the statutes.
That is to say that administrative agencies have no inherent powers.
     However,  legislative intent may give rise to implied powers and the
courts, in interpreting the powers of such agencies, are not limited by
the mere words of the statute.  This is especially true where the adminis-
tration of health and safety is concerned.  It is a general principle of
law that every grant of power carries with it the reasonable use of necessary
means for its effective execution.  Thus an administrative agency has every
power which is indispensable to the powers specifically granted.
     Notwithstanding liberal construction as regards health legislation, it
is best to expressly endow the agency with the powers necessary to carry out
the intent of the legislature.  For while the courts may uphold an agency's
exercise of implied power, such litigation is time consuming and ought not
to be encouraged by lack of legislative specificity.  On the other hand,
the intent of the legislature may be defeated by subsequent litigation if
 that  body fails to express  its  intent  in  the statute.


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 3.3  CRITERIA FOR EFFECTIVE AIR POLLUTION REGULATION
     Compliance with the requirements discussed in the previous section
requires that legislative criteria be set.  That is, a check list of all
the necessary elements of effective air pollution control legislation must
be presented to determine that adequate authority is given the agency.
     Thus, statutes relative to air pollution regulation must be analyzed
to determine that the legislature has expressed its intent and has defined
"air pollution" so as to permit the administrative agency to act to prevent
conditions which threaten to endanger the public health prior to the occur-
rence of actual injury.   Additionally, the state agency must have sufficient
authority to adopt emission regulations and other control regulations, imple-
ment emergency action, gather and evaluate air quality and emissions data,
require reporting of information, require permits to construct, require permits
to operate, grant and repeal variances, inspect facilities, test facilities,
issue orders, hold hearings, subpoena witnesses and evidentiary materials,
impose penalties, obtain injunctions, and grant enforcement powers to local
agencies.

 3.4  LEGISLATIVE INTENT
     Legislative intent has been expressed in the Indiana Air Pollution Control
Laws.   In general, the language provides for protection of public health and,
consistent with economics and industrial development, the protection of public
enjoyment of the states' air resources.
     Indiana Statute §35-4601 states:
     "It is the intent and purpose of this act to maintain the purity
     of the air resource of the State, which shall be consistent with
     protection of the public health ...."
     While qualifying language has been adopted as regards the intensity of
control, it is clear that the protection of public health is unqualifiedly
declared to be the public policy.
1.   Indiana Stat. §36-4601.

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 3.5'  LEGISLATIVE DEFINITION OF "AIR POLLUTION"
     Adequate air pollution control can only be realized if the adminis-
 trative agency has the power to act to protect welfare and property as
well as health and, in addition, to prevent conditions which reasonably
 threaten  the public health and welfare.  Therefore, it is necessary that
 the legislative definition of "air pollution" be sufficiently broad to en-
                                                                   2
 compass the above factors.  Indiana state law defines air pollution
broadly   enough     to include those conditions which are injurious to
property, or which unreasonably interfere with the comfortable enjoyment of
 life and  property.  However, the definition does not include those conditions
which threaten to be injurious.
     It could be argued that a threat of injury interferes with comfortable
          3
enjoyment.   While it has not been seen that the original definitions sub-
stantially impaired the agencies' ability to cope with situations which posed
a mere threat to the public health or welfare, legislative clarification is
                                                           4
preferred.  The following statutory change will be adopted:
          Indiana Stat. §35-4602 (c);
          "Air Pollution" is presence in the outdoor atmosphere
          of one or more air contaminants in sufficient quantities
          and of such characteristics and duration as is or threatens
          to be injurious to human, plant, or animal life or to
          property, or which unreasonably interferes with  the  com-
          fortable enjoyment of life and property.
     The  amendment to the Indiana Act can be adopted early in 1973.

 3.6 POWERS OF THE INDIANA APC AUTHORITY
     Indiana's Air Pollution Control Act  as amended through 1969, establishes
 a State Air Pollution Control Board which is generally empowered  to adopt
 and enforce regulations, with the assistance of the State Board of Health.
Primary responsibility for air pollution control is at the State  level.  The
 original  1961 act impaired the State's authority to act  however, and the
 restricting language was subsequently deleted by the Legislature  in 1969.
The same  Legislature amended another section  of the 1961 Act so  as to again
 restrict  state enforcement action.  That 1969 revision, in effect, grants
 jurisdiction to the State Board only after an air quality jurisdiction fails

 2.  Indiana Stat. §35-4602  (c).
 3.  "Comfortable enjoyment" is a term which signifies mental quiet as well as
    physical comfort.
 4.  Underlining indicates new material; * indicates deletion.
 5.  Indiana Stat. §35-4601, et seq.
 6.  Opinions of the Attorney General of Indiana, 1966, No. 32, p. 221.
 7.  Indiana Stat. §35-4608  (e).


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                                Q
 to enforce the local ordinance.   Even after such failure is proven, con-
 sultation with the local authority is a condition precedent to lawful enforce-
 ment action by the State Board.  The requirements of proof as to failure of
 enforcement, and the consultation requirement tend to hinder state enforce-
 ment efforts.
      The Act provides the Board adequate authority to adopt emission regu-
 lations and other control regulations.  While, on its face, the Legislature's
                    9
 statement of intent  seems to limit the Board's authority in this regard,
 the general rule is that enabling health legislation will be liberally con-
 strued in order to effectuate the purpose of the enactment.    No apparent
 authority exists to enable the Board to require the reporting of information,
 adopt a permit system, or conduct source testing.  However, a liberal con-
 struction of the Act   indicates that the Board could engage in such regulatory
 action provided the action was reasonable and consistent with the general
 intent of the Act.  An analysis of the legal authority of the Indiana APC
 Board as of July, 1970, is summarized in Table  3-1.
      The enabling legislation requires that the State APC Board must adopt
 regulations before effective control authority is vested in the fields of
 emergency action, information reporting, permit systems, and variances.  As
 of July, 1970, the legislative power grant had been exercised only as regards
 construction permits.  To this extent, the State Board has inadequate authority
 to act in the other areas mentioned above.  That is to say, it has legislative
 authority to regulate  but lacks administrative authority.
      Action is proposed to remove the restraints imposed upon the State Board
 where local ordinances are adopted.  While local enforcement activity is to be
 8.   The language of §35-4608 (e) reads as follows:
      (e) When an air quality jurisdiction, or administrator thereof fails to
      enforce the local ordinance which affords protection to the public equal
      to that provided by state law, the Control Board, after consultation with
      that jurisdiction or administrator may take such appropriate action as
      may be necessary to enforce applicable provisions of state law.  (As
      amended by Chapter 357, Acts of 1969).
 9.   Indiana Stat. §35-4601.
10.   Blue v Beach, 155 Ind. 121, 56N.E. 89, (1900).
11.   The Board is empowered to adopt and promulgate reasonable rules and
      regulations consistent with the general intent of the Act and necessary
      to carry out the purposes of the Act.  Indiana Stat. §§35-4604 (A)  (3).
12.   Indiana APC Board Regulation APC-1.

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                                              TABLE  3_!

                    ANALYSIS OF INDIANA APC LAWS AND REGULATIONS AS OF JULY, 1970
Desirable or Essential Powers
Agency Possessing
Specific Power
Statute Expressly Conferring
Specific Power or Regulation
Implementing General
Conferral of Power
1.   Definition of air pollution
     in State Law must be suffici-
     ently broad to enable the
     agency to protect welfare and
     injury to property as well as
     health
APC Board
Ind. Stat. §35-4602(c)
2.    Under the definition of air
     pollution, the agency must be
     able to control and prevent
     conditions which threaten or
     endanger the public health
     or welfare before the
     occurrence of actual injury
APC Board
Ind. Stat. §35-4602(c),
Further clarification of the
statute is desirable
3.   Power to hold public hearings
     relating to any aspect of the
     administration of air pol-
     lution laws and regulations
APC Board

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                                         TABLE 3-1.  Continued
Desirable or Essential Powers
Agency Possessing
Specific Power
Statute Expressly Conferring
Specific Power or Regulation
Implementing General
Conferral of Power
4.   Power to adopt, amend and
     repeal rules and regulations
APC Board
Ind. Stat. §35-4604(A) (3)
5.   Power to enforce the law by
     appropriate administrative
     and judicial proceedings, in-
     cluding injunctive relief
APC Board
Ind.  Stat.  §35-4604(A) (4)
6.   Power to compel the attendance
     of witnesses at hearings and
     other administrative pro-
     ceedings (subpoena power)
APC Board

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                                               TABLE 3_]_> Continued
       Desirable or Essential Powers
                                      Agency Possessing
                                      Specific Power
Statute Expressly Conferring
Specific Power or Regulation
Implementing General
Conferral of Power
       7.   Power to gain access to rec-
            ords relating to emissions
            of air contaminants
                                      APC Board
Ind. Stat. §35-4604 (A) (3),
U)
Power to compel the pro-
duction of books and records
for use in administrative pro-
ceedings (subpoena power)
                                                  APC Board
Ind. Stat. §§35-4604(A) (4)
and 63-3021
            Power to secure necessary
            technical information by
            contract or otherwise
                                                                          Chap. 397. Acts, 1969,
                                                                          Item 2 under "Other Operat-
                                                                          ing Accounts for Services
                                                                          by Contract".   (This is
                                                                          under the biennial

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                                             TABLE 3-1.  Continued
    Desirable or Essential Powers
                                           Agency Possessing
                                           Specific Power
Statute Expressly Conferring
Specific Power or Regulation
Implementing General
Conferral of Power
    10.    Power to prepare comprehensive
          plans for the control of air
          pollution
                                           State Board of Health
Ind. Stat. §35-4604(8) (2)
i
oo
11.    Power to collect and dissemi-
      nate information concerning
      air pollution (including con-
      duct of studies, investiga-
      tions and research)
                                               State Board of Health
Ind. Stat. §35-4604(B) (3)
    12.    Power to establish ambient
          air quality standards and
          emission standards for all
          or parts of the State
                                           APC Board
Ind. Stat. §35-4604(A)
and §35-4604a
Air Pollution Control
Regulations APC-9 (Air
Quality Standards)

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                                        TABLE  3-1. Continued
Desirable or Essential Powers
Agency Possessing
Specific Power
                                                                                      Statute Expressly Conferring
                                                                                      Specific Power or Regulation
                                                                                      Implementing General
                                                                                      Conferral of Power
13.   Power to classify air con-
     taminant sources and require
     reports from such classes
APC Board
                                                                                      Ind. Stat. §35-4604(A) (3),
                                                                                      General conferral of
                                                                                      authority
y3      14.   Power to establish a permit
^°           system for the construction
            and operation of new sources
            and control apparatus as well
            as for the alteration of exist-
            ing sources and control
            apparatus
                                           APC Board
                                    Ind. Stat.  §35-4604  (A)  (3)
                                    General conferral of
                                    authority
                                    Air Pollution Control Regu-
                                    lation APC-1 (New Installa-
                                    tions only)
15.  Power to inspect, subject to
     legal limitations regarding
     search warrants, the loca-
     tions of contaminant
     sources
State Board of Health

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                                        TABLE  3-1.Continued
Desirable or Essential Powers
                                                   Agency Possessing
                                                   Specific Power
Statute Expressly Conferring
Specific Power or Regulation
Implementing General
Conferral of Power
16.  Power to conduct tests of
     emissions of air contaminants
     from any source
                                                   State Board of Health
Ind. Stat. §35-4604(B) (9)
Implied from language of
statute.
I
I—1
o
17.  Power to utilize variances
     Subject to careful procedural
     and substantive controls
                                                   APC Board
Ind. Stat. §35-4604(A) (3)
General Conferral of
authority
18.  Power to provide for the con-
     fidentiality of information
     acquired from private sources,
     without unduly restricting
     ability to enforce the
     applicable law
                                                   APC Board
Air Pollution Control

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                                        TABLE 3_1>  Continued
Desirable or Essential Powers
Agency Possessing
Specific Power
Statute Expressly Conferring
Specific Power or Regulation
Implementing General
Conferral of Power
19.  Power to exercise emergency
     authority to limit or elimi-
     nate emissions from stationary
     sources with minimum delay
APC Board
Ind. Stat. §35-4605
20.  Power to impose penalties for
     air pollution violations
APC Board
Ind. Stat. §35-4607(b)
21.  Power to receive and admin-
     ister grants or gifts made for
     the purpose of carrying out
     the statute and regulations
State Board of Health

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                                               TABLE  3-1.Continued
      Desirable or Essential Powers
Agency Possessing
Specific Power
Statute Expressly Conferring
Specific Power or Regulation
Implementing General
Conferral of Power
      22.  Power to advise, consult, coop-
           erate and enter into agree-
           ments with the governments
           and agencies of the adjacent
           States, and any interstate or
           regional agency representing
           any such State or political
           subdivision
APC Board
State Board of Health
Ind. Stat. §§53-1101 et seq.
I
(-•
NJ
      23.  Power to take any action
           necessary to carry out
           statute and regulations
                                    None
      24.  Power to delegate performance
           of duties to a subordinate
           agency
                                    Ind. Stat. §35-4608 APC Act
                                    does not limit authority of

-------
encouraged, such authority should be concurrent with, and not in lieu of,
state authority.  The recommended legislative action, therefore, will consist

of the deletion of subsection (e) of Indiana Statute §35-4608.  Such action
will not impair effective local control of air pollution.

     Further action is deemed desirable in regard to the delegated powers

of the Indiana Air Pollution Control Board and the State Board of Health.

Specific authority is granted for adequate regulation in the area of information

reporting, permit system, and source testing.  It is proposed that the above-

mentioned powers be given the State Board of Health by amendment to Indiana

Stat. §35-4604 (B) as follows:13

          (B)   Powers and Duties of the State Board of Health - The
          duty and power to assist and cooperate with other groups in-
          terested in and affected by air pollution is hereby vested in
          the State Board of Health and such Board is hereby empowered to:
          (1)   Advise, consult and cooperate with other agencies in the
          State, towns, cities and counties, industries, other states and
          the federal government, and with affected groups in the prevention
          and control of new and existing air contamination  sources within
          the State.
          (2)   Encourage and conduct studies, investigations, and research
          relating to air pollution and its causes, effects, prevention, con-
          trol and abatement.
          (3)   Collect and disseminate information relating to air pollution,
          its prevention and control.
          (4)   Encourage voluntary cooperation by persons, towns, cities,
          and counties or other affected groups in restoring and preserving a
          reasonable degree of purity of air within this State.
          (5)   Encourage authorized air pollution agencies of towns, cities
          and counties to handle air pollution problems within their respective
          jurisdictions to the greatest extent possible.
          (6)   Provide technical assistance to towns, cities, or counties
          requesting same for the furtherance of air pollution control.
          (7)   Represent the State of Indiana in any and all matters per-
          taining to plans, procedures, or negotiations for interstate com-
          pacts in relation to the control of air pollution.
          (8)   Accept and administer grants or other funds or gifts for the
          purpose of carrying out any of the functions of this Act.
          (9)   Enter at all reasonable times in or upon any private or public
          property except private residences for the purpose of inspecting and
          investigating conditions  *  and conducting tests on any air con-
          taminant source to determine compliance with this Act.
          (10)Require the person responsible for any air contaminant source
          to file reports with the State Board of Health containing information
          as to location, size, and height of air contaminant outlet, and rate,
13.   Underlining indicates new material;  *  indicates deletion.

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          duration, temperature, and composition of the air contaminant.
          (11)  Prohibit the installation, alteration, or use of any air
          _ccmt_aminant source, or the, appurtenant equipment thereto, unless an
          .appropriate permit therefore has been obtained from the State Board
          of Health.
          (12)  Adopt rules and regulations with respect to the issuance of
          permits.
          (13)  Investigate complaints received by it or referred to it by the
          Control Board, make such reports to the Control Board of its investi-
          gations as it deems advisable and participate, on behalf of this
          State, in proceedings or public hearings before the Control Board.
          (14)  The State Board of Health is authorized to budget and receive
          duly appropriated monies for expenditures to carry out the pro-
          visions and purposes of this Act.

     In addition, specific authority will be given to the State APC Board to
grant and repeal variances from the Board's emission standards.  The amendatory

language appears in subsection (5) of Indiana Statute §35-4604 (A) and should
read substantially as follows:

          §35-4604 (A) - Powers and Duties of the Air Pollution Control
          Board.  The duty and power to administer and carry out the ad-
          judicatory provisions of this Act hereinafter set forth in this
          Section is hereby vested in the Air Pollution Control Board and
          such Board is hereby empowered to:

          (a)  Any person who owns or is in control of any plant, building,
          structure, process or equipment may apply to the (agency) for a
          variance from rules or regulations.  The (agency) may  grant
          such variance if it finds that:
               1.  The emissions occuring or proposed to occur do
               not endanger or tend to endanger human health or
               safety; and
               2.  Compliance with the rules or regulations from which
               variance is sought would produce serious hardship
               without equal or greater benefits to the public.

          (b)  No variance shall be granted pursuant to this Section
          except after public hearing on due notice and until the
          (agency) has considered the relative interests of the applicant,
          other owners of property likely to be affected by the dis-
          charges, and the general public.
          (c)  Any variance or renewal thereof shall be granted within
          the requirements of subsection  (a) and for time periods and
          under conditions consistent with the reasons therefor, and
          with  the following limitations:
                1.  If the variance is granted on the ground that there
                is no practicable means known or available for the adequate
                prevention, abatement or control of the air pollution
                involved, it shall be only until the necessary means for
                prevention, abatement or control become known and
                available, and subject to  the taking of any substitute
                or alternate measures that  the  (agency) may prescribe.


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               2.  If the variance is granted on the ground that
               compliance with the particular requirement or require-
               ments from which variance is sought will necessitate the
               taking of measures which, because of their extent or cost,
               must be spread over a considerable period of time, it
               shall be for a period not to exceed such reasonable
               time as, in the view of the (agency) is requisite for
               the taking of the necessary measures.  A variance granted
               on the ground specified herein shall contain a timetable
               for the taking of action in an expeditious manner and
               shall be conditioned on adherence to such timetable.

               3.  If the variance is granted on the ground that it is
               justified to relieve or prevent hardship of any kind other
               than provided for in terms 1 and 2 of this subsection, it
               shall be for not more than (one) year.

          (d)  Any variance granted pursuant to this Section may be
          renewed on terms and conditions and for periods which would
          be appropriate on initial granting of a variance.  If complaint
          is made to the (agency) on account of the variance, no renewal
          thereof shall be granted, unless, following public hearing on
          the complaint, the (agency) finds that renewal is justified.
          No renewal shall be granted except on application therefor.
          Any such application shall be made at least (sixty) days prior
          to the expiration of the variance.  Immediately upon receipt
          of an application for renewal the (agency) shall give public
          notice of such application in accordance with rules and
          regulations of the (agency).

          (e)  A variance or renewal shall not be a right of the appli-
          cant or holder thereof but shall be in the discretion of the
          (agency).  However, any person adversely affected by a variance
          or renewal granted by the (agency) may obtain judicial review
          thereof by a proceeding in the (appropriate court).  Notwith-
          standing any provision of Section 12 of this ordinance, judicial
          review of the denial of a variance may be had only on the
          ground that the denial is arbitrary or capricious.

          (f)  Nothing in this Section and no variance or renewal
          granted pursuant hereto shall be construed to prevent or
          limit the application of the emergency provisions and procedures
          of Section II of this ordinance to any person or his property.

          (g)  Any hearing held under the provisions of this Section
          shall conform with the relevant requirements set out in Section
          12 of this ordinance.

     The above amendments will be presented for adoption during the 1971

session of the Legislature.

     In addition to the above legislative action, it is necessary for the

State APC Board to adopt and promulgate regulations for the implementation

of emergency action, information reporting, operation permits and variances,

This will be done by late 1970.


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3.7  IMPLEMENTATION OF EMERGENCY ACTION
     As has been indicated in section 3.6, Indiana has sufficient legislation
for the implementation of emergency action.  In this section, we shall con-
sider this phase of the air pollution control program in greater detail.
     Enabling legislation for the implementation of emergency action was
                                          14
passed by the Indiana Legislature in 1969.    The statute provides authority
for the technical secretary of the State Board of Health, to determine that
air pollution in an area constitutes an unreasonable and emergency risk to
the health and safety of those in the area.  Thereupon the determination
shall be communicated to the Governor who may, by proclamation, declare an
emergency and order immediate abatement of contaminant emissions.  In addi-
tion, the Governor may request the State Attorney General to initiate in-
junctive proceedings or to take such other action as may be necessary.
     The procurement of temporary injunctions, an ex parte proceeding,
in cases where health hazards are imminent, can be realized within a short
time so as to effectively cope with the emergency situation.  The necessary
evidentiary material is discussed in Section 7.0   The next section, 3.8,
indicates that Indiana may enter into regionwide agreements for episode control.

3.8  ORGANIZATION OF REGIONAL ENFORCEMENT ACTIVITIES
     The Indiana APC Board may engage in effective intrastate enforcement
activities through  the authority of the state's Air Pollution Control Act15
and the state's Constitution.  Local political subdivisions only have
such powers as granted by statute and state agencies such as the APC Board
retain superior jurisdiction notwithstanding local programs.    Therefore the
Board may establish a regional organization to enforce state standards in
Ohio and Dearborn Counties.
     Indiana's APC Board may participate in an interstate planning endeavor
with the air pollution authorities of Kentucky and Ohio  through  the authority of
that state's Interlocal Cooperation Act.
14.  Indiana Stat. §35-4605.
15.  See section 5.6.1, supra.
16.  See section 5.6.1, supra.
17.  Indiana Stat. §53-1101 et. seq.

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     No lagislative action is required for the proposed organization of re-
gional operations within the Indiana portion of the MCIAQCR.

3.9  INTERSTATE PLANNING AND SERVICES AUTHORITY
     Interstate cooperation in the form of planning and computerized
support services is a necessary element of the proposed regional structure.
Services may be generally provided by contract with the City of Cincinnati
and by contract with an interstate planning authority.  Existing Ohio Law
permits any board of county commissioners and the legislative authority
of any municipality to cooperate with other such entities in Ohio and
in sister states to create by agreement an interstate regional planning
commission.  The various political subdivisions in Indiana are empowered
to enter such agreement pursuant to the authority given them by the state's
                           19
Interlocal Cooperation Act.
     In light of an analysis of existing state laws applicable to MCIAQCR,
it appears that the Regional Commission will have adequate authority to con-
duct a program of information exchange and air pollution control planning
and coordination.  Ohio law, ORC §713.33 (A), states that the "commission
may make studies, maps, plans, and other reports relative to the region
and shall recommend procedures and policies to the appropriate authorities,
based on physical ... conditions and trends, to promote ... the general
health, welfare, convenience, and prosperity of the people of the region."
(Emphasis supplied.)

3.10  SUMMARY OF LEGISLATIVE AND ADMINISTRATIVE ACTIONS TAKEN TO EFFECT
      THE IMPLEMENTATION PLAN
     The preceding discussion pointed out the legal and administrative
deficiencies which exist in the Indiana Programs, and the proposed remedial
action.  This is summarized in the following table.
18.  Ohio Rev. Code §§713.30 et seq.
19.  Indiana Stat. §§53-1101 et seq.

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                               TABLE 3-2
       SUMMARY OF LEGISLATIVE AND ADMINISTRATIVE ACTIONS TAKEN TO

                 AFFECT THE IMPLEMENTATION PLAN FOR THE

                            STATE OF INDIANA
Responsible
tody	
Potential
Effective
Date
          Purpose
Discussed
on P. No.
 legislature
 .egislature
 legislature
APC Board
APC Board
APC Board
APC Board
Interstate
Agreement

^egislature
Feb. 1973
Jan. 1971
Jan. 1971
Sept.
1970

Oct.
1970

Oct.
1970

Dec.
1970

Aug.
1973

Jan. 1971
Amend Ind. Stat. §35-4602 (c)
to define air pollution
sufficiently broad to abate
prior to actual occurrence of
in j ury

Amend Ind. Stat. §35-4604 (B)
to give the State Board of
Health power to require the
reporting of information,
adopt a permit system for new
and existing installations,
and conduct source testing.

Amend Ind. Stat. §35-4604 (A)
to give the State APC Board
power to grant variances

Emergency Action procedures
Information reporting


Use permits


Variances


Interstate control of
episodes

Amend Ind. Stat. §35-4608 (e)
to provide effective state
jurisdiction where local
APC program exists.
                                                  3-3
                                                                  3-13
 3-14



 3-15


 3-15


 3-15


 3-15


 3-16


 3-13

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                        4.  CONTROL REGULATIONS
4.1  EXISTING REGULATIONS
     The current control regulations for the State of Indiana are as
follows.

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                       AIR POLLUTION CONTROL BOARD
                                 OF THE
                            STATE OF INDIANA

               PROPOSED AIR POLLUTION CONTROL REGULATIONS
     New installations or new potential sources of air pollution will
be subject on the effective date of these regulations to the limits
contained therein.  All persons must comply within one year with
Regulation APC 2.  Existing installations which are sources of air
pollution must within one year submit a program and timetables to
comply with Regulations APC 3, APC U, APC 5, APC 6 and APC 7.

DEFINITIONS

     The following terms as used in these Rules and Regulations shall,
unless the context otherwise requires, have the following meanings:

     AIR CONTAMINANT - Particulate matter, dust, fumes, gas, mist, smoke
or vapor, or any combination thereof, but excluding uncombined water.

     AIR CONTAMINANT SOURCE - Any and all sources of emission of air
contaminants, whether privately- or publicly-owned or operated.  Without
limiting the generality of the foregoing, this term includes all types of
business, commercial and industrial plants, works, shops and stores, and
hydrocarbon combustion plants, power generating plants, and steam heating
platts and stations, building and other structures of all types, including  .
single and multiple family residences, apartments, houses, office buildings,
hotels, restaurants, schools, hospitals, churches, and other institutional
buildings, aircraft, automobiles, trucks, tractors, buses and other motor
vehicles, garages and vending and service locations and stations, railroad
locomotives, ships, boats and other water-borne craft, portable fuel-
burning equipment, incinerators of all types, indoor and outdoor, refuse
dumps and piles, and all stack and other chimney outlets from any of the
foregoing.

     AIR POLLUTION - Presence in the outdoor atmosphere of one or more air
contaminants in sufficient quantities and of such characteristics and
duration as to be injurious to human, plant or animal life or to property,
or which unreasonably interefere with the enjoyment of life and property.

     ASME - The American Society of Mechanical Engineers.

     ASTM - The American Society for Testing and Materials.

     AUXILIARY FUEL FIRING EQUIPMENT - Equipment to supply additional heat,
by the combustion of an auxiliary fuel, for the purpose of attaining
temperatures sufficiently high (a) to dry and ignite the waste material,
(b) to maintain ignition thereof, and (c) to promote complete combustion of
combustible solids, vapors, and gases.

     BACKYARD INCINERATION - The burning of material originating on the
premises of single and multiple family residences.

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     BIAST FURNACE - The furnace and equipment used in the smelting
process in which primarily oxygen is removed from the ore and molten
metal produced with gas as a by-product.  The furnace and equipment
consists of, but is not limited to, trie furnace proper, charging equip-
ment, stoves, bleeders, gas dust catcher, gas cleaning devices and
other auxiliaries pertinent to the process..

     BOARD - The Air Pollution Control Board of the State of Indiana.

     BASIC OXYGEN FURNACE (EOF) - A furnace in which the melting and
refining of iron are accomplished by the high velocity addition of
large quantities of high purity oxygen to the atmosphere above the surface
of the metal bath.  The metal is held in a tiltable vessel with a basic
refactory lining.  Such a furnace includes furnace proper, oxygen lance,
scrap and flux charging units, iron transfer units, gas collecting and
cleaning equipment and stacks and any other auxiliaries pertinent to the
process,

     BRITISH THERMAL UNIT - The quantity of heat required to raise one
pound of water from 59 degrees F to 60 degrees F.  (Abbreviated B.T.U.,
BTU or Btu.)

     BY-PRODUCT COKE PLANT -  A plant used in connection with the
distillation process to produce coke in which the volatile matter is
expelled, collected, and recovered.  Such plant consists of, but is not
limited to, coal and coke handling equipment, by-product chemical plant
and other equipment associated with and attendant to the coking chambers
or ovens making up a single battery operated and controlled as a single
unit.

     CARBONACEOUS FUEL - Any form of combustible matter — solid, liquid,
vapor or gas, consisting primarily of carbon containing compounds in
either fixed or volatile form which are burned primarily for their heat
content.

     CATALYTIC CRACKING UNIT - A unit composed of a reactor, regenerator
and fractionating tower which is used to convert certain petroleum
fractions into more valuable products by passing the material at elevated
temperature through a bed of catalyst in the reactor.  Coke deposits
produced on the catalyst during cracking are removed by burning off in the
regenerator.

     COMBUSTiON FOR INDIRECT HEATING - The combustion of fuel to produce
usable heat that is to be transferred through a heat-conducting materials
barrier or by a heat storage medium to a material to be heated so that the
material being heated is not contacted by, and adds no substance to the
products of combustion.

     ELECTRIC FURNACE - A furnace in which the melting and refining of
metals are accomplished by means of electric energy.

     ENGINEER - Any person meeting the requirements as set forth in
Chapter lU8, Acts of 1935, Indiana General Assembly, as amended, and who is
registered under the Act as a Professional Engineer.  He shall be the person

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who designed or is responsible for the design of the equipment or
air pollution control devices and preparation of the plan documents«

    EQUIPMENT - Fuel burning, combustion or process devices or
apparfttua including incineratoro, fuel-bujfning *qulpm*n%, r«fU*«-
burning equipment used for the burning of fuel or other combustible
material from which the products of combustion are emitted.  Also
this shall include apparatus which generates heat and may emit
products of combustion; and manufacturing chemical, metallurgical
or mechanical processes which may emit smoke, particulate matter or
other air contaminants.  Processes are defined as equipment according
to this regulation.

    EXCESS AIR - That air supplied in addition to the theoretical
Quantity necessary for complete combustion of ft.1.1 fuel and/or
combustible waste material present.

    EXISTING EQUIPMENT - Equipment under construction, installed or
operated on the effective date of these regulations.  Any existing
eauipment which subsequent to the effective date of these regulations
is altered, repaired or rebuilt at a cost of 30$ or more of its
replacement value shall be deemed new equipment.  The cost of air
pollution control equipment and of its installation is not to be
included as a cost of altering, repairing or rebuilding existing
equipment.

    FOUNDRY CUPOIA -  A stack-type furnace used for melting of metals
consisting of, but not limited to, furnace proper, tuyeres, fans or
blowers, tapping spout, charging equipment, gas cleaning devices and
other auxiliaries.

    FOUNDRY OPEN HEARTH - An open hearth furnace as defined herein
but used in the foundry industry.

    GARBAGE - Animal and vegetable matter such as that originating in
houses, kitchens, restaurants and hotels, produce markets, food service
and processing establishments, and greenhouses.

    GAS CLEANING DEVICE - Facility designed to remove air contaminants
from equipment exhaust gases.

    HEATING AND REHEATING FURMCE - A furnace in which metal is heated
to permit shaping or forming, or to achieve specific physical properties,

    HEATING VALUE - The heat released by combustion of one pound of
waste or fuel measured in BTU's on an as received basis.

    INCINERATOR - Combustion apparatus designed for high temperature
operation in which solid, semi-solid, liquid, or gaseous combustible
wastes are ignited and burned efficiently and from which the solid .
residues contain little or no combustible material.

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     OPEN BURNING - Any burning of combustible materials wherein the
products of combustion are emitte'd directly into the open air vdthout
passing through a stack or chimney.

     OPEN HEARTH FURNACE - A furnace in which the melting and refining of
metal is accomplished by the application of heat to a saucer-type or
shallow hearth in an enclosed chamber.  Such furnace consists of, but is
not limited to, the furnace proper, checkers, flues, and stack and may
include a waste heat boiler, an oxygen lance, and other auxiliaries per-
tinent to the process.

     PARTICULA.TE MATTER - Any material, except water, that exists in a
finely divided form as a liquid or solid.

     PERSON - Any individual, partnership, co-partnership, firm, company,
corporation, association, joint stock company, trust, estate, political
subdivision, or any other legal entity, or their legal representative, agent,
or assigns.

     PLAN DOCUMENTS - Reports, proposals, preliminary plans, survey and
basis of design data, general and detail construction plans, profiles,
specifications and all other information pertaining to the equipment.

     POLITICAL SUBDIVISION - Any municipality, city, incorporated town,
village, county, township, district or authority, or any portion or
combination of two or more thereof.

     PROCESS - Any action, operation, or treatment and the equipment used.in
connection therewith, and all methods or forms of manufacturing or processing
that may emit air contaminants.

     PROCESS WEIGHT - The total weight of all materials introduced into any
source operation.  Solid fuels charged will be considered as part of the
process weight but liquid and gaseous fuels and combustion air will not.

     PROCESS WEIGHT RATE - (a) For continuous or long-run steady-state
source operations, the total process weight for the entire period of
continuous operation or for a typical portion thereof, divided by the number
of hours of such period or portion thereof.
                           (b)  For a cyclical or batch source operation,
the total prbcess weight for a period that covers a complete operation or an
integral number of cycles, divided by the hours of actual process operation
during such a period.

     When the nature of any process or operation or the design of any equipment
is such as to permit more than one interpretation of this definition, the
interpretation that results in the minimum value for allowable emission shall
apply.

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REFUSE—Includes garbage, rubbish and trade wastes.
RINGELMANN CHART—The chart published and described in
  the U. S. Bureau of Mines Information Circular 8333, and on
  which are illustrated graduated shades of gray to black for
  use in estimating the light-obscuring power of smoke.
Rl'BlUSH—Solids not considered to  be highly  flammable or
  explosive such  as, but not  limited to,  rags, old clothing,
  leather, rubber, carpets, wood,  excelsior,  plastics, paper,
  ashes,  tree branches,  yard  trimmings,  furniture, tin cans,
  glass, crockery,  masonry, and other similar  materials.
SALVAGE OPERATIONS—Any business, trade or industry en-
  gaged in whole or part in salvaging or reclaiming any product
  or material, such  as, but not limited to, metals,  chemicals,
  shipping containers, or drums.
SINTERING PLANT—The plant used in connection with the
  process of  fusing  fine particles of  metallic ores causing
  agglomeration of such particles.  Such plant consists of, but
  is not limited to, sintering machines, handling facilities, wind
  boxes, stack and other auxiliaries pertinent to the process.
SMOKE—Small gas-borne particles resulting from incomplete
  combustion, consisting  predominantly, but  not exclusively,
  of carbon,  ash  and other  combustible material,  that form
  a visible plume  in  the  air.
SMOKE MONITOR—A device  using a light source and a light
  detector which  can automatically measure  and record  the
  light-obscuring  power of smoke at a specific location in the
  flue or stack of  a source.  Measuring and recording to be at
  intervals  of not less than 15 seconds.
SOURCE OPERATION—The last operation preceding the emis-
  sion of an air  contaminant, which  operation: (a)  results
  in the  separation  of the air contaminant from the process
  materials or in  the conversion of the process materials into
  air contaminants,  and (b) is not  an air pollution  abatement
  operation.
STACK OR CHIMNEY—A flue, conduit or opening permitting
  particulate or gaseous  emission into  the  open air, or con-
  structed or arranged for such purpose.
STANDARD  CONDITIONS—A  gas  temperature  of 70 degrees
  Fahrenheit and a  gas  pressure  of 14.7 pounds per square
  inch absolute (psia).
STANDARD CUBIC  FOOT (SCF)—The  standard cubic foot is
  a measure of the volume of one cubic foot of gas at standard
  conditions.
STANDARD  METROPOLITAN STATISTICAL AREA (SMS A)—
  The county which has at least one city with a population of
 . at least 50,000 and the contiguous counties which contain the
  suburban areas  for these cities.

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TECHNICAL  SECRETARY—The Technical  Secretary  of  the
  Air Pollution Control Board of the State of Indiana.
THEORETICAL AIK—The exact amount of air required  to sup-
  ply the required oxygen for complete combustion of a given
  quantity  of a specific fuel or waste.
TKADE WASTE—All solid or liquid material or rubbish result-
  ing from'cb'rislruc'tion, building operations, or the prosecution
  of any business, trade or industry such as, but not limited to,
  plastic products, chemicals, cinders and other forms of solid
  or liquid  waste materials.


                 REGULATION APC 1

             Reports, Flans and Specifications
  Any person planning to construct a new installation which
will  or might reasonably be expected to become a source of
air pollution or make modifications to an existing installation
which will  or might reasonably be expected to  increase the
amount or change the effect or  the  character of  air con-
taminants  discharged,  so that such  installation may  be ex-
pected to become a source of air pollution,  or planning to
install an  air-cleaning  device shall submit a  report, plans
and  specifications for approval prior  to  initiation of con-
struction.
  The following  listed installations  are exempted  from  the
submission  of reports, plans and specifications:
  a.  Comfort  heating equipment,  boilers,  water heaters, air
     heaters, and steam  generators with a  rated capacity of
     less than one million BTU per hour.
  b.  Fuel-burning equipment and  incinerators  used singly or
     jointly by occupants of dwellings containing four or less
     apartment units.
  c.  Comfort ventilating systems.
  d.  Unit space heaters.
  e.  Vacuum-cleaning systems used exclusively for commercial
     or residential housekeeping.
  f.  Laboratory hoods which exhaust to outer air.
  g.  Exhaust systems for controlling steam  and heat.
  h.  Fuel-burning equipment using as fuel only natural  gas,
     or L.P. gas, or a  mixed gas  distributed by a utility in
     accordance with the rules of the Public Service Commis-
     sion of the  State  of Indiana.
  Reports, plans and specifications filed  for approval shall in-
clude the following:
  a.  Expected composition  of effluent stream both before  and
     after any cleaning device, including  emission rate, con-
     centration,  volume and temperature.
  b.  Expected physical characteristics of particulates.

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  c.  Size, type and performance characteristics of air-cleaning
     devices.
  d.  The  location and  elevation of the emission point and
     other factors relating to dispersion and diffusion of the
     air contaminant in the outer air, and  the relation of the
     emission  to nearby  structures,  window openings, and
     other information necessary to appraise the possible ef-
     fects of the effluent.
  e.  When necessary to ascertain compliance, the location of
     planned sampling points and the tests to be made of the
     completed installation  by the  owner.
  f.  Any other reasonable and pertinent information  that may
    . be required by the Board.
  Any  information  relating  to secret  processes, methods  of
manufacture, or production  submitted in connection with re-
ports, plans and specifications or testing  shall be protected
communications and shall  not  be  released  or. made public
without the express  permission  of  the  person supplying the
information.
  The Board, at its discretion, may accept in  lieu of detailed
plans and specifications a  certificate that the proposed air
pollution  control device will operate in accordance  with the
emission  limitations  of the  Rules and Regulations.


                REGULATION  APC 2

                      Open Burning
  No person shall conduct a  salvage  operation by open burning
except on  written approval  of the Board.  The Board must
seek advice and guidance of local  authorities before issuing
such approval.
  No person  shall burn  any refuse in  any open fire except
as follows:
  a.  Camp fires and  fires used solely for recreation purposes
     where such fires are  properly controlled by a responsible
     person.
  b.  Backyard incineration.
  c.  Burning of rubbish  on  a farm, derived from an agricul-
     tural operation, when the prevailing winds, at the time of
     burning, are away from populated areas and no nuisance
     is created.
  d.  Open burning,  in  remote areas, of highly explosive  or
     other dangerous materials  for which there is  no other
     known method  of disposal or  for special purposes when
     approved by the Board.
  The exceptions apply in all areas where they are not pro-
hibited by local  ordinances  or by other  officials having juris-
diction such as local fire  officials.

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                REGULATION APC 3
            Smoke and Other Visible Emissions
  The Ringelmann Chart shall be used for grading the light-
obscuring power of smoke. No person  shall operate any com-
bustion  installation so as to  produce, cause,  suffer or  allow
smoke  to be emitted,  the appearance, density or shade  of
which is darker than No. 2 of the Ringelmann Chart. When
cleaning a fire  or blowing tubes,  smoke  which is  not darker
than a No. 3 Ringelmann Chart may be  emitted for a period
or periods not exceeding five minutes in any 60-minute period,
such emissions  shall  not be  permitted  on   more than  six
occasions during any  24-hour period.  When  building a  new
fire, smoke not darker than  a No. 3  Ringelmann  Chart  may
be  emitted not to exceed ten minutes on one occasion per
day. The Board, at its  discretion,  may accept  an extension  of
the time period and number  of such time periods per day.
  When a breakdown of equipment or a change of  fuel results
in smoke darker than a No.  2 of  the Ringelmann Chart, the
Board shall be  notified immediately.
  The opacity of any color equivalent to the Ringelmann Chart
may be  used as prima-facie  evidence  in determining process
emissions but may be refuted by approved stack emission tests
or  other  evidence acceptable to the Board.

                REGULATION APC 4
             Combustion for Indirect Heating
  Emission of  particulate matter from  the  combustion  of
fuel for indirect heating shall be limited by the ASME Standard
No. APS-1, dated June 15,  1966, "Recommended  Guide for
the Control of  Dust  Emission-Combustion for Indirect Heat
Exchangers." For purposes of this Regulation, the maximum
allowable emission shall be calculated  using equation (15)  in
this Standard with a maximum downwind ground level dust
concentration of 50 micrograms per  cubic meter for a 30-  to
60-minute time  period.  Figure 2 of the Standard may be used
to  estimate  allowable  emissions.  However,   irrespective  of
stack height, the maximum allowable  emission for any stack
shall be  0.6 pounds for new  equipment and  0.8 pounds for
existing equipment of particulates per  million  BTU input.


                REGULATION APC 5
                   Process  Operations
  No person shall operate any process so as to  produce, cause,
suffer or allow  particulate matter to be emitted in excess  of
the amount shown in the following table.  Exceptions are com-
bustion for indirect heating, incinerators, open burning, exist-
ing cement kilns, existing catalytic cracking units, and exist-
ing foundries.

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              Allowable Rate of Emission  Based
                   on Process Weight Rate1
Process
Weight
Rate
I.bs/Hr Tons/Hr
100
200
400
600
800
1,000
1,500
2,000
2,500
3,000
3,500
4,000
5,000
6,000
7.000
8,000
9,000
10,000
12,000
0.05
0.10
0.20
0.30
0.40
0.50
0.75
1.00
1.25
1.50
1.75
2.00
2.50
3.00
3.50
4.00
4.50
5.00
6.00
Rate of
Emission
Lbs/IIr
0.551
0.877
1.40
1.83
2.22
2.58
3.38
4.10
4.76
5.38
5.96
6.52
7.58
8.56
9.49
10.40
11.20
12.00
13.60
Process
Weight
Rate
Lbs/Hr Tons/Hr
10,000
18,000
20,000
30,000
40,000
50,000
60,000
70,000
80,000
90,000
100,000
120,000
140,000
160,000
200,000
1,000,000
2,000,000 1
6,000,000 3

8.00
9.00
10.00
15.00
20.00
25.00
30.00
35.00
40.00
45.00
50.00
60.00
70.00
80.00
100.00
500.00
,000.00
,000.00

Rate of
Emission
Lbs/Hr
16.5
17.9
19.2
25.2
30.5
35.4
40.0
41.3
42.5
43.6
44.6
46.3
47.8
49.0
51.2
69.0
77.6
92.7

  When the process weight  exceeds 200 tons/hour, the maxi-
mum allowable emission may exceed that shown in the table,
provided  the concentration  of participate matter in the dis-
charge gases to the atmosphere is less than 0.10 pounds per
1,000 pounds of gases  at standard conditions.

  Existing  cement  manufacturing operations  equipped  with
electrostatic precipitators,  bag niters, or equivalent gas-clean-
ing  devices  shall be allowed  to  discharge concentrations of
particulate matter in accordance with E=8.6 P°-6T below 30 tons
per hour of process weight  and E=15.0 P°5  over  30 tons per
hour of process weight.

  Existing petroleum  catalytic cracking  units  equipped  with
cyclone separators,  electrostatic  precipitators,  or  other  gas-
cleaning systems shall recover 99.97% or more of the circulat-
ing catalyst or total gas-borne particulate.
•Interpolation of the data In this table Tor process weight rates up to  60,000
 Ibs/hr shall be accomplished by use of the equation E = 4.10 P°-c", and Inter-
 polation and extrapolation of the data for process weight rates in excess  of
 60,000 Ibs/hr shall  be accomplished by use of  the equation E — 55.0 PH-U-W,
 where E=rate of emission in Ibs/hr and P=process weight In tons/nr.

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                 REGULATION  APC 6
                     Existing' Foundries
  No person shall operate  any existing foundry so as to pro-
duce, cause, suffer, or allow  particulate matter to  be emitted
in excess of the amount  shown in  the  following table.  All
new foundries shall not exceed the requirements of Regulation
APC  5.
         Allowable Emissions from Foundry Cupolas
                (Existing  Emission  Sources)
  Process Weight Rate                 Allowable Emission
                                    of Particulate Matter
        Lbs/Hr                            Lbs/Hr
         1,000                                3.05
         2,000                                4.70
         3,000                                6.35
         4,000                                8.00
         5,000                                9.65
         6,000                                11.30
         7,000                                12.90
         8,000                                14.00
         9,000                                15.50
        10,000                                16.65
        12,000                                18.70
        16,000                                21.60
        18,000                                22.80
        20,000                                24.00
        30,000                                30.00
        40,000                                36.00
        50,000                                42.00
        60,000                                48.00
        70,000                                49.00
        80,000                                50.50
        90,000                                51.60
       100,000                                52.60

                REGULATION  APC 7
                        Incinerators
  No person shall cause  or permit the emission of  particulate
matter from the stack or chimney of any incinerator in excess
of the following:
  a.  Incinerators  with a  maximum  refuse-burning  capacity
     of 1,000 or more pounds per hour, 0.4 pounds of  particulate
     matter per 1,000 pounds of dry  exhaust gas at standard
     conditions corrected to  50% excess air.
  b.  All  other  incinerators, 0.7 pounds of particulate matter
     per 1,000 pounds of dry gas at standard  conditions cor-
     rected to  50% excess air.
  c.  No incinerator shall emit or produce smoke in excess of
     the requirements in Regulation APC 3.
  All new incinerators shall be multiple chamber or equivalent
incinerators.

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                             REGULATION APC 13

                  Maximum Allowable Concentrations for
            Sulfur Dioxide Emissions for the State of Indiana
                 and   Federally-Designated Metropolitan
          Interstate and Intrastate Air Quality Control Regions

     In accordance with the provisions of  the Federal Clean Air Act of
Public Law 'yO-lhS>) select high-population  density areas of the State of
Indiana ha\e been designated as Intel-state and Intrastate Air Quality
Control Regions.  In such areas, ambient c.ir quality standards and emission
standards to achieve these air quality standards are essential.  It is
also  essential that ar.iDierit air quality in all other less densely populated
parts of the State be established for  the  purpose of protecting public
health and welfare.

     Cpmbuction of Fuels for Indirect Heating

          Etaission of sulfur dioxide from  the combustion of fuel for
     indirect heating shall be limited to  sixty (60) percent of the
     maximum allowable particulate matter  as covered in Regu)stion
     APC k.  For purposes of this Regulation, reference ca.n be made
     to AST'S Standard No. AP3-1, dated June 15, 1566, "Kecocmended
     Guide for the Control of Dust Enissiori-Cocibustion for Indirect
     Heat Exchangers."  Figure 2 of this ASKE Standard, using the
     60 percent factor, may be used, to estimate maximum allowable
     emissions.  Hovcrer, .-i-rre^.ppctive of  stpck height the ~axiTj.m
     allowalvIs.e sulfur dioxide emission per million Btu. input shall
     be 0.3'5 pounds for new equipment and  O.U# pounds f'O7' existing
     equipment.  In addition, where fuel combustion operations utilize
     a number of stacks of the sane height, the rraxiraum allowable
     emission (estimated^as being frcra one f.tack) shaLl be divided
     nuir.ericfe.lly by  n    , where "n" is the mirier of sts.cks.  For
     a total plant load utilizing stacks of unequal height, weighted
     factors may be used to obtain an equivalent stack height.

     Process Operations

         Dnission of sulfur dioxide from any sources, except those
     covered by the preceding  paragraph,  shall be limited'to 0.05
     percent by volume of the exhaust gases.  Dilution of the exhaust
     gases to circumvent the intent of this Regulation shall be
     considered grounds for irrxi.edi.atc- action on the part of the Board
     to start injunction proceedings.

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                                     TABLE  2

                       ALLOWABLE  RATE OF  EMISSION  BASED ON
                             PROCESS  WEIGHT  RATE
                                                a,b
Process Weight
Rate
Lb/Hr Tons/Hr
100
200
400
600
800
1,000
1,500
2,000
2,500
3,000
3,500
4,000
5,000
6,000
7,000
8,000
9,000
10,000
12,000
0.05
0.10
0.20
0.30
0.40
0.50
0.75
1.00
1.25
1.50
1.75
2.00
2.50
3.00
3.50
4.00
4.50
5.00
6.00
Rate of
Emi ssion
Lb/Hr
0.551
0.877
1.40
1.83
2.22
2.58
3.38
4.10
4.76
5.38
5.96
6.52
7.58
8.56
9.49
10.4
11.2
12'.0
13.6
Process Weight
Rate
• Lb/Hr Tons/Hr
16,000
' 18,000
20,000
30,000
40,000
50,000
60,000
70,000
80,000
90,000
100,000
120,000
140,000
160,000
200,000
1,000,000
2,000,000
6,000,000

8.00
9.00
10.
15.
20.
25.
30.
35.
• 40.
45.
50.
60.
70.
80.
100.
500.
1,000.
3,000

Rate of
Emission
Lb/Hr
16.5
17.9
19.2
25.2
30.5
35.4
40.0
41.3
42.5
43.6
44.6
46.3
47.8
49.0
51.2
69.0
77.6
92.7

"Sections  of major importance  with  reference  to  this  table are sections 2024,
 2027,  3213, 3214, and  6112.2.

Interpolation  of the data  in  this  table  for  process  weight rates up to 60,000 Ib/hr
 shall  be  accomplished  by use  of the  equation E  = 4.10pu<  , and interpolation and
 extrapolation  of the data  for process  weight rates in excess of 60,000 Ib/hr shall
 be accomplished by use of  the equation:
E = 55.
                   p '
                         -  40,  where  E  =  rate  of  emission in Ib/hr and
                         P  =  process  weight  rate  in  tons/hr.
     Section 6112.4  Any volume of gases  passing  through  and  leaving an  air pollu-
tion abatement operation may be substituted  for the  source  gas  volume of the  source
operation served by such air pollution abatement  operation, for the purposes  of
section 6112.3, provided such air pollution  abatement  operation emits no more than
40% of the weight of particulate matter entering  thereto; and provided further that
such substituted volume shall be corrected to  standard conditions and to a moisture
content no greater than that of any gas stream entering such  air pollution abatement
operation.

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4.2  PROPOSED REGULATIONS
                                 e
     It is proposed that selected portions of the existing State regulations

be modified and that additional regulations be added where necessary.


4.2.1  General Provisions

       Regulation APC 1 does not adequately provide for a comprehensive
permit system.  The regulation will be modified to include provision for

both a construction permit and operating certificate for new and existing

sources rather than mere approval of plans and specifications.  See

Section 4.2.4 for the proposed modifications.

       Existing regulations do not provide for registration of emission

information, source testing, approval of control plan and compliance

schedules and control of   nuisance.  The additions to existing regula-
tions are proposed in Section 4.2.4.


4.2.2  Particulate Matter

       •  Open Burning

          Existing Regulation APC 2 currently exempts backyard burning AND
          rubbish burning on a farm.  These exemptions will be deleted from
          this regulation for application in the Cincinnati Interstate
          AQCR.

       •  Visible Emissions

          Regulation APC 3 currently regulates black smoke emissions
          according to the Ringelmann No. 2 scale and other color air
          contaminants by equivalent opacity.  However, opacity regulations
          can be refuted by the violator using stack emission tests or
          other evidence.  It is proposed that Regulation APC 3 be
          strengthened by reducing allowable smoke emissions to Ringelmann
          No. 1 in accordance with current technology and deleting exceptions
          to opacity regulations to enhance field enforcement aspects of
          the regulation.
       •  Fuel Burning Equipment

          Existing Regulation APC 4 is not consistent with modern control
          technology.  Regulation APC 4 will be substituted  by the proposed
          Regulation APC 4.  (See Section 4.2.4.)

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       •  Process Equipment
          Existing Regulation APC 5 is consistent with the control strategy
          except for the exemptions.   Exceptions for cement kilns, catalytic
          cracking units and foundries will be deleted from Regulation APC 5.
       •  Incinerators
          Existing Regulation APC 7 for incinerators is not completely
          consistent with the control strategy.   This regulation will be
          rewritten to require all incinerators  to meet an emission
          standard of 0.2 pounds of particulate  matter  per 100 pounds of
          refuse charged on a mass emission rate basis.  The regulation
          will also incorporate changes in design and operational require-
          ments.   See Section 4.2.4 for the proposed Regulation APC 7.
       •  Fugitive Dust

          There currently are no regulations for control of fugitive dust.
          Refer to Section 4.2.4 for Regulation  APC 9

4.2.3  Sulfur Oxides

       •  Fuel Equipment
          No regulations are in effect for control of sulfur oxides from
          the use of fuels.  The proposed regulation APC 10 is intended
          to implement the control strategy selected.  (See Section 4.2.4.)

       •  Process Equipment
          No regulations are in effect for control of sulfur oxides from
          industrial process operations.  Since  no sources exist in the
          Indiana portion of the Region, none are proposed at this time.

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4.2.4  Modified Regulations




                      (REVISED) REGULATION APC 1


                          General Provisions




A.  PERMITS AND OPERATING CERTIFICATES


    (1)  Any person planning to construct a new installation which will


    or might reasonably be expected to become a source of air pollution


    or make modifications to an existing installation which will or


    might reasonably be expected to increase the amount or change the


    effect or the character of air contaminants discharged, so that


    such installation may be expected to become a source of air pollution,


    or planning to install an air-cleaning device shall submit a report,


    plans and specifications for approval prior to initiation of construction.


    No person shall commence construction until receipt of a valid


    construction permit from the Director.


    (2)  No person shall cause or permit the. use or operation of a


    new installation or air-cleaning device for which a construction


    permit is required without first obtaining an operating certificate


    from the Director.


    (3)  No person shall cause or permit the use or operation of an


    existing installation or air-cleaning device without obtaining an
                  «

    operating certificate from the Director within six months of the


    adopted date of these regulations  or an approved  control plan in


    accordance with Section B of this  regulation.


    (4)  The following listed installations are exempted from the submission


    of reports, plans and specifications:

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   a.   Comfort heating equipment,  boilers,  water heaters,  air




   heaters, and steam generators with a  rated capacity of  less




   than one million BTU per hour.




   b.   Fuel-burning equipment and  incinerators used singly or




   jointly by occupants of dwellings containing four or less




   apartment units.




   c.   Comfort ventilating systems.




   d.   Unit space heaters.




   e.   Vacuum-cleaning systems used  exclusively for commercial  or




   residential housekeeping.




   f.   Laboratory hoods which exhaust to outer  air.




   g.   Exhaust systems for controlling steam and heat.




   h.   Fuel-burning equipment using  as fuel only natural gas, or




   L.P. gas, or a mixed gas distributed  by  a utility in accordance




   with the rules of the Public Service  Commission of the  State of




   Indiana.




(5)  Reports, plans and specifications filed for approval  shall




include the following:




   a.   Expected composition of effluent  stream both before and




   after any cleaning device, including  emission rate, concentration,




   volume and temperature.




   b.   Expected physical characteristics of particulates.




   c.   Size, type and performance  characteristics of air-cleaning




   devices.




   d.   The location and elevation  of the emission point and other




   factors relating to dispersion and diffusion of the air

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       contaminant in the outer air, and the relation of the emission
                                    /

       to nearby structures, window  openings,  and other information


       necessary to appraise  the possible effects of the effluent.


       e.  When necessary to ascertain compliance, the location of


       planned sampling points and the tests to be made of the


       completed installation by the owner.


       f.  Any other reasonable and pertinent information that may be


       required by the Director.


    (6)  Any information relating to secret processes, methods of


    manufacture, or production submitted in connection with reports,


    plans and specifications or testing shall be protected communcations


    and shall not be released or made public without the express


    permission of the person supplying the information.


    (7)  The Director, at his discretion, may accept in lieu of detailed


    plans  and specifications a certificate that the proposed air


    pollution control device will operate in accordance with the


    emission limitations of the Rules and Regulations.




B.  CONTROL PLAN AND TIME SCHEDULE


Except as otherwise specified, compliance with the provisions of these
                  «.

regulations shall be according to the following time schedule:


    (1)  New Installations


    All new installations shall comply as of going into operation.


    (2)  Existing Installations


    All existing installations not in compliance as of the effective


    date of these regulations shall be in compliance within six months


    of the effective date of these rc-gulal ions unless the owner or





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    person responsible for the operation of the installation shall
                                   e

    have submitted to the Department in a form and manner satisfactory


    to it, a control plan and schedule for achieving compliance, such


    plan and schedule to contain a date on or before which full


    compliance will be attained, and such.other information as the


    Department may require.  If approved by the Department, such date


    will be the date on which the person shall comply.  The Department


    may require persons submitting such a plan to submit subsequent


    periodic reports on progress in achieving compliance,.  In no event


    shall the control plan and schedule exceed two and one-half years from the


    adopted date of these regulations.



F.  SUBMISSION OF EMISSION INFORMATION


The Director may require the submission of air pollutant information,


from any or all potential sources for purposes of maintaining an air


pollutant emission inventory.  Such information shall be provided on


forms furnished by the Department.



G.  MEASUREMENT OF EMISSIONS OF AIR CONTAMINANTS


    (1)  The Director may require any person responsible for emission


    of air contaminants to make or have made tests to determine the


    emission of air contaminants from any source in order to obtain


    an operating certificate or whenever the Department has reason to


    believe that an emission in excess of that allowed by these


    regulations is occurring.  The Department may specify testing


    methods to be used in accordance with good professional practice.


    The Department may observe the testing.  All tests shall be


    conducted by reputable, qualified personnel.  The Department shall





-------
    be given a copy of the test results in writing and signed by the
                                  .'

    person responsible for the tests.


    (2)  The Director may conduct tests of emissions of air contaminants


    from any source.  Upon request of the Department the person


    responsible for the-source to be tested shall provide necessary


    holes in stacks or ducts and such other safe and proper sampling


    and testing facilities, exclusive of instruments and sensing


    devices as may be necessary for proper determination of the


    emission of air contaminants.



H.  AIR POLLUTION NUISANCES PROHIBITED


    (1)  No person shall cause or permit the discharge from any source


    whatsoever such quantities of air contaminants or other material


    which cause injury, detriment, nuisance, or annoyance to any


    person or to the public or which endanger the comfort, repose,


    health, or safety of any such person or the public or which cause


    injury or damage to business or property.


    (2)  Nothing in any part of these regulations concerning emission


    of air contaminants or any other regulation relating to air


    pollution shall in any manner be construed as authorizing or
                «
    legalizing the creation or maintenance of a nuisance.

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                      (REVISED) REGULATION APC  4
                                   ,'


            RESTRICTION ON EMISSION OF PARTICULATE MATTER

                      FROM FUEL BURNING EQUIPMENT





A.  GENERAL PROVISIONS



    (1)  This regulation applies to installations in which fuel is



    burned for the primary purpose of producing heat or power by



    indirect heat transfer.  Fuels include those such as coal, coke,



    lignite, coke breeze, fuel oil, and wood but do not include refuse.



    When any products or by-products of a manufacturing process are



    burned for the same purpose or in conjunction with any fuel, the



    same maximum emission limitations shall apply.



    (2)  The heat content of coal shall be determined.according to



    ASTM method D-271-64 Laboratory Sampling and Analysis of Coal or



    Coke or ASTM method D-21-5-62T Gross Calorific value of Solid Fuel



    by the Adiabatic Bomb Calorimeter, which publications are made a



    part of this section by reference.



    (3)  For purposes of this regulation the heat input shall be the



    aggregate heat content of all fuels whose products of combustion pass



    through a stack or stacks.  The heat input value used shall be the

                  ii


    equipment manufacturer's or designer's guaranteed maximum input,



    whichever is greater.  The total heat  input of all fuel burning



    units on a plant or premises shall be used for determing the maximum



    allowable amount of particulate matter which may be emitted.



    (4)  The amount of particulate matter emitted shall be measured



    according to the American Society of Mechanical Engineer's Power



    Test Codes - PTC-27 dated  1957 and entitled Determining Dust

-------
    Concentrations in a Gas Steam, which publication is made a part




    of this section by reference.







B.  EMISSION LIMITATIONS




    (1)  No person shall cause or permit the emission of particulate




    matter, caused by combustion of fuel in fuel-burning equipment,




    from any stack or chimney in excess of the quantity set forth in




    the following  Figure 1

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  O



  I
  fd
NJ
OJ
   bd
   i-3
      0.11
      0.01
                              10
        100                 1000

Equipment Capacity Rating  (10° BTU/hr)
10,000
100,000

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                      (REVISED) REGULATION APC 7


              RESTRICTION ON EMISSIONS FROM INCINERATORS
                                   i*



A.  GENERAL PROVISIONS



    (1)  This regulation shall apply to any incinerator used to dispose



    of refuse or other wastes by burning and the processing of salvable



    material by burning.  Notwithstanding definitions in other regulations,



    as used in this regulation the word refuse includes garbage, rubbish,



    trade wastes, leaves, salvable material, agricultural wastes, and



    other wastes.  The word incinerator, as used in this regulation,



    includes incinerators and other devices, structures, or contrivances



    used to burn refuse (as defined herein) or to process refuse by



    burning.



    (2)  The burning capacity of an incinerator shall be the manufacturer's



    or designer's guaranteed maximum rate or such other rate as may be



    determined by the Director in accordance with good engineering



    practices.  In case of conflict, the determination made by the



    Director shall govern.



    (3)  The amount of particulate matter emitted from any incinerator



    shall be detewmined according to the National Air Pollution Control



    Administration publication, "Specifications for Incinerator Testing



    at Federal Facilities" which publication is made part of this



    regulation be reference.



    (4)  For the purposes of this regulation the total of the capacities



    of all furnaces within one system shall be considered as the



    incinerator capacity.

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B.  EMISSION LIMITATIONS




    (1)  No person shall cause, suffer, or allow to be emitted into the




    open air from any incinerator, air contaminants the appearance,




    density, or shade of which exceed No. 1 of the Ringelmann Chart, or




    an equivalent opacity.




    (2)  No person shall cause, suffer, or allow to be emitted into the




    atmosphere from any incinerator or to pass a convenient measuring




    point near the stack outlet, fly ash in the gases to exceed 0.20




    pounds per 100 pounds per hour of rated capacity.






C.  DESIGN-OPERATION REQUIREMENTS




    (1)  No residential or commercial single-chamber incinerator shall




    be used for the burning of refuse for a period in excess of eighteen




    (18) months after the adopted date of this regulation.




    (2)  All new incinerators and all existing incinerators after January




    1, 1972 shall be multiple-chamber incinerators, provided that the




    Director may approve any other type of incinerator if he finds that




    the emissions do not exceed those allowed in this regulation.




    (3)  No person shall operate or cause or permit the operation of




    any incineratoV at any time other than between the hours of




    10:00 A.M. and 4:00 P.M.  This restriction shall not apply to




    incinerators having a refuse-burning capacity of five (5) tons




    per hour or more.




    (4)  Incinerators, including all associated equipment and grounds,




    shall be designed, operated and maintained so as to prevent the




    emission of odors.

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                        (PROPOSED)  REGULATION APC  <*
          RESTRICTION OF EMISSION OF FUGITIVE DUST AND GASES
A.  No person shall cause or permit the handling or transporting or

storage of any material in a manner which allows or may allow unnecessary

amounts of particulate matter to become air-borne.


B.  No person shall cause or permit a building or its appurtenances

or a road, or a driveway, or an open area to be constructed, used,

repaired or demolished without applying all such reasonable measures as

may be required to prevent particulate matter from becoming air-borne.

The Director may require such reasonable measures as may be necessary to

prevent particulate matter from becoming air-borne including but not

limited to paving or frequent cleaning of roads, driveways and parking

lots; application of dust-free surfaces; application of water; and the

planting and maintenance of vegetative ground cover.

C.  When dust, fumes, gases, mist, odorous matter, vapors, or any

combination thereof escape from a building or equipment in such manner

and amount as to cause a nuisance or to violate any regulation, the

Director may order that the building or equipment in which processing,

handling and storage are done be tightly closed and ventilated in such

a way that all air and gases and air-  or gas-borne material leaving

the building or equipment are treated by removal or destruction of air

contaminants before discharge to the open air.

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                       (PROPOSED) REGULATION APC 10
                                   ^



              RESTRICTION OF EMISSIONS OF SULFUR DIOXIDE


                           FROM USE OF FUEL







A.  GENERAL PROVISIONS




    (1)  This regulation shall apply to any installation in which fuel is




    burned and in which the sulfur dioxide emission is due largely to




    the content of the fuel burned, and in which the fuel is burned




    primarily to produce heat or power by indirect heat transfer.




    (2)  For purposes of the regulation, a fuel-burning installation is




    any single fuel-burning furnace or boiler or other unit, device, or




    contrivance in which fuel is burned or any grouping of two or more




    such furnaces or boilers or other units, devices, or contrivances




    on the same premises or otherwise located in close proximity to each




    other and under control of the same person.  The capacity of such




    installations shall be the manufacturer's or designer's guaranteed




    maximum heat input rate.




    (3)  The method for determining the percent of sulfur in coal shall




    be that described in ASTM D-271-64, Standard Methods of Laboratory




    Sampling and Analysis of Coal and Coke or equivalent method approved




    by the Direct»r.  The method for determining the heat content of




    coal shall be described in ASTM D-271-74, Standard Methods of




    Laboratory Sampling and Analysis of Coal and Coke or D-2015-62T,




    Tentative Method of Test for Gross Calorific Value of Solid Fuel




    by the Adiabatic Bomb Calorimeter.  All coal analyses and heat

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contents are to be made on a d,ry basis.  Moisture content of coal

is to be determined in all cases and results reduced to facilitate

calculations of actual pollutants.  The method for determining the

sulfur content of fuel oil shall be that described in ASTM D-129-64

Standard Method of Test for Sulfur in Petroleum Products by the

Bomb Method.  The method for determining the heat content of fuel oil

shall be that described in ASTM D-240-64 Standard Method of Test

for Heat of Combustion of Liquids by Bomb Calorimeter or other

method giving comparable results.  The testing methods specified

in the subsection A (3) are hereby made a part of this regulation,

by reference.

(4)  The Director is authorized to take samples of any fuel by any

appropriate means for the sampling of the quantity which he finds,

at any reasonable time or place, for purposes of determining

compliance with this regulation.  Where applicable, the following

methods will be used.

      For coal:  ASTM:  D-492-48 (1958), Standard Method of Sampling
                 Coals Calssified According to Ash Content

                 ASTM:  D-2013-64T, Tentative Method of Preparing
             •   Coal Samples for Analysis

                 ASTM:  D-2234-65T, Tentative Method for Mechanical
                 Sampling of Coal

      For oil:  ASTM:  D-270-64, Standard Method of Sampling Petroleum
                and Petroleum Products

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B.  PROHIBITIONS




    (1)  No person shall burn, sell or make available for sale for




    burning in fuel burning equipment, any fuel containing in excess




    of 1% sulfur by weight after July 1, 1971 except for fuel combustion




    units having heat capacities in excess of 200 million BTU/hour; for




    these units, fuel in excess of 1.25% sulfur by weight are prohibited.




    (2)  Any person offering to sell or deliver fuel or any person




    responsible for fuel burning equipment, shall, upon request, submit




    to the Department such ana /ses of the fuel as may be required to




    determine compliance with these regulations.




    (3) It shall be unlawful for any person to import, sell, offer for




    sale, expose for sale, exchange, deliver or transport for use and




    consumption in the State of Indiana or to use or consume in the State




    of Indiana any fuel which does not meet the requirements of this




    regulation.




    (4)  Fuels in excess of the limits set out in B(l) above may be burned,




    sold or made available for sale for burning in fuel burning equipment




    on which control equipment to desulfurize stack gases has been




    installed or other methods or devices are used that will produce




    results equivalent to those that would have resulted from the burning




    of fuel containing one percent or less sulfur by weight without these




    added control features and for which approval for use has been




    obtained from the Director.

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          5.  EMERGENCY EPISODE AUTHORITY AND PROCEDURES
     The purpose of an Emergency Episode Plan is to prevent the ambient
concentrations of pollutants from ever reaching levels where it appears
that the health, safety,  and welfare of the community may be in danger.
The objective of this Emergency Episode Plan is to temporarily control
sources within the Indiana portion of the MCIAQCR during episode  periods
when dilution is not adequate to prevent high ground level concentrations
of pollutants.  Planning for emergency episodes assures that the reduction
of emission from sources is conducted in a well-structured manner with
minimum inconvenience to the emitters as well as the citizens of Indiana.
     The Emergency Episode Plan is presented in the following sections.
The Plan is designed for the emergency control of particulates and
sulfur oxides.  Emergency episode plans for other pollutants such as
carbon monoxide, oxidants, and nitrogen oxides will be submitted to the
Secretary of the Department of Health, Education and Welfare.
     The proposed Emergency Episode Plan is viewed as a mechanism that
will eventually be sensitive to all air contaminants which may be
hazardous to human health during episodes.   This is to say, the Plan
that is outlined for development is designed with an awareness of the
future requirements of the State.  The intensity of study which supports
the development of the proposed Plan is justified on the grounds that
the emergency control of pollutants, in addition to particulates and
sulfur oxides, will be eventually coordinated by one common Plan.

5.1  COMPREHENSIVE EMERGENCY EPISODE PLAN
     The comprehensive Emergency Episode Plan is an outline of the steps
that will be taken by Indiana to establish a viable episode organization.
The Plan is based on the MCIAQCR episode organization as presented in
Appendix  C   of this report.  Since episodes are regional problems,
cooperation among the jurisdictions in the MCIAQCR will be mandatory.
The utilization of the MCIAQCR EOCC* will assist the cooperative effort.
     The comprehensive Plan is viewed as an  outgrowth of the interim
Plan which is presented in Section  5.2   The interim Plan calls for a
number of specific actions which are recommended for episode avoidance.
*Emergency Operations Control Center

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The comprehensive Plan, once developed, will replace parts of the interim

Plan with an approach which is based on scientific and engineering fact.

The comprehensive plan will provide for intensive evaluation of the emission

sources  as well as  air  quality  and meteorological parameters   to  determine  a
Plan  that is  sensitive  to  the needs of the  Indiana  portion  of  the MCIAQCR.


 c i  ]_  Episode  Criteria

        The following  episode criteria  will  trigger  preplanned emergency
 actions in the Indiana portion  of the MCIAQCR:

        1.  Status:  "Forecast"  -  An internal watch  will  be  activated
           on the basis of  a Weather Bureau HAPPA* or  equivalent
           indication that  a high air  pollution  potential will exist
           for  the  next 36  hours.

        2.  Status:  "Alert" - At  the  initiation  of, and  periodically
           during   a  "Forecast" period, air quality information  for
           the  preceding 24-hour  period will be  reviewed.  If for
           any  consecutive  24-hour period the average sulfur dioxide
           level is equal  to or exceeds 0.10 ppm and  the soiling
           index for  the same period  is equal to or exceeds 2.0  COHs,
           an "Alert" status is established.

        3.  Status:  "Warning" - If for any  consecutive 24-hour period
           during an  "Alert", the average sulfur dioxide level is
           equal to or  exceeds  0.25 ppm and the  soiling  index  for
           the  same period  is equal to or exceeds 4.0 COHS, a
           "Warning"  status is  established.

        4.  Status:  "Emergency" - If  during the  "Warning" period, it
           appears  imminent that  for  a 24-hour period, the  average
           sulfur dioxide  level will  equal  or exceed  0.40 ppm  and the
           soiling  index for the  same  period will equal  or  exceed
           6.0  COHs,  an "Emergency" status  is established.

        5.  Status:  "Termination" - Once declared,  any status  reached
           by application  of these criteria will remain  in  force
           until the  criteria for that status are no  longer met.
           At such  time, the next lower status will be resumed.   This
           procedure  will  continue until the episode   is terminated.

        Emergency actions will be  taken by each state  when any monitoring
site  within  the MCIAQCR records ambient air quality in excess of  that
designated in the criteria.  Adverse air quality need not be regionwide

to trigger emergency  control actions.  Also, the Alert,  Warning,  and
Emergency  stages can  and should be activated on  the basis of deteriorating
air quality  alone;  a  High Air Pollution Potential Advisory  need  not be
in effect.
 *High Air Pollution Potential Advisory


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       The entire Emergency Episode Plan operates around the relationship
between the measured air quality during the episode and the predetermined
levels established by the episode criteria.  The relationship between
criteria and  the remainder of the Plan is illustrated in Figure  5-1.

r  i  o  Episode  Communications
J • JL • £•  — * ----                                      .    ...
       Indiana, as a member of  the Air Pollution Control Officers  Committee*
will  actively participate in MCIAQCR episode activities.  Through  the EOCC ,
the  field inspection team and the State air pollution officials will be
in  direct contact with  the organizations listed in Table  5-1.

          Table 5-1.  ORGANIZATIONS CONTACTED DURING EPISODES
•  Legal Authority                  •  Neighboring Jurisdictions
•  Emission Sources                 •  Other State and Local Governmental
•  Air Quality  Data Sources
   u  *.    i   •  i ™     r.            •  News Media
•  Meteorological Data  Sources
 .  NAPCA
                                    •  Telephone Company

 5.1.2.1  Communications Center
          The objective of  the MCIAQCR EOCC is to serve as the facility
 for  reception  and processing of data relating to. air pollution episodes
 and  for determination of avoidance actions.  It will accept information,
 process raw information into intelligence data, and determine corrective
 actions.  The  implementation of specific source control actions will be
 left  to the individual states.
          During air pollution episodes, the MCIAQCR EOCC will be manned
 by the  staff of the City of Cincinnati and personnel from the state agencies
 in Ohio,  Kentucky, and Indiana.  Other specialists such as physicians may
 also  be called upon to volunteer their services during the serious stages
 of episodes.   In general,  they will recommend appropriate actions as well
 as assist in the interpretation of air quality data, meteorological factors,
 public  health  effects, and engineering considerations.
 *Abbreviated APCO

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 METEOROLOGICAL
   MONITORING
STAGE
STAGE 2
STAGE 3
 STAGE 4
                            State of Indiana
                                           AIR
                                       MONITORING
 HIGH AIR
 POLLUTION
 POTENTIAL
  ADVISORY
            FORECAST

METEOROLOGY CONDITIONS ONLY
     • AGENCY PREPARE FOR
      POTENTIAL EPISODE

     • ADVISE MAJOR SOURCES
CONDITION*
CONTINUES
                                                  I
              ALERT
   NO ACUTE HEALTH  EFFECTS,BUT
   PREVENTIVE ACTION REQUIRED
     • PUBLIC ANNOUNCEMENT
     • FUEL SWITCHING
     • CURTAIL INCINERATION &
       BURNING
                                                              POLLUTANTS
                                                               REACH
                                                              1ST LEVEL
CONDITION*
CONTINUES
            WARNING

    PRELIMINARY HEALTH HAZARD


   • SELECTIVE CURTAILMENT
     OF INDUSTRIAL ACTIVITIES
                                                                            POLLUTANTS
                                                                             INCREASE
                                                                           TO 2ND LEVEL
CONDITION*
CONTINUES
                                              EMERGENCY
                                        DANGEROUS HEALTH HAZARD
                                        MAJOR CURTAILMENT OF ALL
                                        ACTIVITIES IN COMMUNITY
                                                                            POLLUTANTS
                                                                             INCREASE
                                                                           TO 3RD LEVEL
 *Whl le poor meteorological conditions will continue to be present,
  a formal HAPPA statement by ESSA is not a requirement.
                        Figure 5-1.   INDIANA EPISODE  SEQUENCE


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         The staff requirements for episode actions under the comprehensive
Episode Plan will be similar to the staff identified for the interim Plan
in Table  5-5.   All of the staff, except for the technicians,  field
inspectors, and enforcement personnel (who have field responsibilities)
will report to the EOCC when so directed.  Staffing schedules will be
determined by the APCO Committee so that the Center will be manned on a
24-hour basis during the more severe stages of an episode.  During each
episode, a team will be selected to prepare a post-episode report.  This
team will coordinate with NAPCA in preparing such a document.
         Nearly all communications will be conducted over standard
telephone lines.  Dedicated telephone lines may be installed to assure
communications with such organizations as:  major sources of pollution,
ESSA, and NAPCA.  Such channels may be required because of the heavy
load that will be placed on the regular telephone system during episodes.
         A fleet of two-way radio equipped automobiles will be needed
for air quality inspection, source inspection, and enforcement to maintain
continuous contact with the field and to assure adequate surveillance
of the emergency conditions.
         Equipment needed in the EOCC in addition to standard items such
as  conference tables, typewriters, and calculators include wall charts
and maps for display of:
         •  Air Quality Data
         •  Meteorological Information
         •  Source Control Data
         •  Traffic Flow Patterns
Essential equipment for the EOCC will be purchased and installed according
to the time schedule presented in Section  5.1-".

5.1.2.2  Communications Manual
         A Communications Manual will be developed to simplify the procedure
of communicating with the organizations listed in Table  5-1.  The Manual
will specify the operations to be followed by each member of the EOCC
operating staff at each episode stage.  The Manual will also identify the
steps to be taken by the field personnel.

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         A series of prepared press releases will be included in the Manual
for immediate release during the early stages of an episode.   Procedures
for publicizing these messages and other specially prepared announcements
will be clearly presented.
          The Communications Manual wil1 be  completed by July  1971.
5.1.3  Episode Surveillance
5.1.3.1  Air Quality Monitoring
         During episodes, short-period averages of air quality measurements
will be available from four  fixed stations  described  in Section  6.1. Three .
of these sites are in Ohio and one in Kentucky.  Initially, only the exist-
ing CAMP station located near downtown Cincinnati will be in operation;  but
all four  should be operative by  September  1,  1971, the  season  of greatest
episode  probability.
         Continuous sulfur dioxide analyzers at each site will permit
averages to be obtained for sampling  periods as  short as 15 minutes and
running sums, averages, or combined indices  over longer periods  as  required,
updated hourly.
         Tape Samplers will be used to provide soiling measurements at all
sites.  They will be equipped with recorders for real-time measurements
and easier retrospective  analysis.  Normal sequential sampling interval
is two hours; however, the sampling time will be reset for hourly or
half-hourly  intervals when ambient concentrations are high.
         Concentrations of suspended particulates will be measured by
hi-vol samplers, one at each station.  During non-episode periods, hi-
vols will be set to take  a midnight-to-midnight reading on a schedule
of operation yet to be determined.  One schedule under consideration calls
for hi-vol operation every third  day.  However, during episodes, hi-vols
will be  operated at maximum  frequency consistent with the work load.

 5.1 3.2 Meteorological Monitoring
         During  episodes  periods, both predictive and observational
weather  information may be required.  The revised Federal Mesometeorological
Plan developed by  the  U.S. Environmental Science Services Administration
 (ESSA) provides  for the  establishment of an  ESSA Meteorological Support
Unit  (EMSU)  for  the MCIAQCR.   This unit consist of  an urban  (air  pollu-


-------
 tion) meteorologist, a technical assistant, and two technicians.  The
 technicians normally take two low level soundings a day, one near day-
 break and one early in the afternoon near the time of maximum imixing
 height.  During episodes one or two additional soundings may be taken.

         Low level soundings provide vertical profile data on temperature
and wind and derivative data such as mixing height, transport wind, and
ventilation index.  They differ from ordinary rawinsonde observations in
that  they utilize a slow-rising balloon to allow high resolution and
terminate at 10,000 feet.  An observational site for taking low level
soundings has not yet been determined.  Sites that are representative
of urban conditions are preferred to the airport sites used for ordinary
rawinsodes.
         The target date for EMSU implementation is during fiscal year
1972.  However, shortage of funds and qualified manpower has resulted in
long  delays in establishing EMSU units at many designated regions.  As
an interim arrangement, therefore, meteorological support will be pro-
vided by the existing Weather Bureau facility at Greater Cincinnati
Airport, located in Boone County, Kentucky.  This office is directed to
establish close working relations with air pollution control agencies
and related interests in the metropolitan Cincinnati area.  Since the
present office is responsible for the full spectrum of weather services
to the community as well as support to aviation, it lacks the resources
for a complete service to air quality control activity such as the EMSU
specialists can provide.  However, as a minimum the Weather Bureau office
will  furnish observational data and up-to-the-minute local advisories
adapted from the High Air Pollution Potential Advisory (HAPPA), which
is issued by the National Meteorological Center (NMC)  at Suitland,
Maryland.
       The HAPPA message is disseminated over Teletype Service C daily
at 12:20 E.S.T.   The criteria for issuing an advisory  are so restrictive,
particularly with regard to a minimum size for the affected area, that
local communities may not be alerted by this means against limited
incidents of high pollutant concentrations.   Hence,  service that is
tailored to the needs of the region will go beyond mere adaptation of

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HAPPA messages.  As a first step, arrangements will be made to have a
daily air pollution potential sheet prepared by the Weather Bureau at
Greater Cincinnati Airport and the data routinely telephoned to the
Cincinnati Division of Air Pollution Control or to a specified coordi-
nating office such as the Cincinnati Regional Office of the State of
Ohio control agency.  Data will be adapted from the 7:00 a.m.  rawinsonde
run taken at Wright-Patterson Air  Force Base, Dayton, which is the  closest
reporting station for upper air temperature and wind data.   When air
pollution measurements reach or are expected to reach specified levels,
the receiving office will relay the meteorological data and other
pertinent information to the State agencies of Indiana, Ohio,  and
Kentucky.  A sample informational sheet is shown in Figure 5-2.
         When the EMSU unit becomes operative, it will take over the
responsibility for  preparing, disseminating,  and  applying  the daily
air pollution potential sheet.  Furthermore, the HAPPA program is
expected to be decentralized, so that advisories will be better
geared to local situations.  Under this new arrangement,  advisories
for the MCIAQCR will originate from the Cleveland, Ohio Forecast Office.
         In addition to the low level soundings that the EMSU unit will
provide, pilot balloon ascents are made at the Greater Cincinnati Airport
and at Standiford Field, Louisville, Kentucky, at 0100 and 1300 E.S.T.
Observational data from Louisville are often indicative of conditions
in the Cincinnati area a few hours in advance.  During episodes,  surface
data from the following locations may also be useful:
         •  Lunken Airport
         •  Abbe Observatory (now operated by University of Cincinnati)
         •  MCIAQCR Surveillance Network:   Four   Primary Stations
            (See Section 6.1.1.)
One or more developmental types of instrumentation such as the radiothermo-
sonde (scanning radiometer) and acoustical soundings may become  operational
in the near future.
         It is still uncertain how these observational data will be utilized
during an air pollution episode.  They may be important input in short-
period prediction models that are expected to be available.  Certain

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                 Figure  5-2.  DAILY ADVISORY FROM WEATHER BUREAU
                              AT GREATER CINCINNATI AIRPORT
                                                    Date

                         AIR POLLUTION POTENTIAL SHEET
  I.  Temperatures (°F)
      a.  Maximum yesterday
      b.  Minimum this morning
      c.  Maximum this afternoon

 II.  Mixing Height (meters)

      a.  Maximum yesterday
      b.  Minimum this morning
      c.  Maximum this, afternoon
      d.  Minimum tomorrow morning
      e.  Maximum tomorrow afternoon
                                              URBAN
                                                      RURAL
  III.
    Base
    Inversion Data (a.m.)  (1.  Surface, 2.  Aloft)


                                      Base     Top
          URBAN
           Top
Tx needed
to break
Tx needed
to break
1.

2.
                                  1.

                                  2.
   IV.  Winds
                                         URBAN
                                                          RURAL
        a.  Surface at 1000 LST
        b.  Surface forecast
        c.  Morning AW (Actual)
        d.  Afternoon AW (Forecast)
        e.  Yesterday's observed AW
                         (Noon)
                         (6-7 p.m.)
                                            Kt.
                                                                   Kt. .
                                                     Kts.
                                           _m/sec.
                                            m/sec.
                                                                   m/sec.
                                                                   m/sec.
                                            m/sec.
                                            m/sec.
                                                                   _m/sec.
                                                                   m/sec.
  V.  Cloudiness

      a.  Today until 7p.m.
      b.  Tonight (7p.m. until 7a.m.)

 VI.  Ventilation

      a.  This afternoon(AW x MXHT)
                         m2/sec
VII.  Index
      a.  This morning  (actual)
      b.  This afternoon (forecast)
      c.  Tomorrow morning (forecast)
                                                  AMOUNT (0-10)
                                         URBAN
                                                          RURAL
            Tomorrow afternoon (forecast)
NOTE:
           AW = average ventilation wind through the mixing layer
            TX = Maximum Temperature
            MXHT = Mixing Height

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 developmental models of  this type are predicated upon winds that vary in
 space  and  time.  Interim application of these data remains qualitative
 and  subjective and should be handled by an experienced meteorologist.

 5.1.3.3 Data Handling
         Data acquired during episodes will be handled as described in
 Section 5.1.4.However, the greater frequency and shorter sampling inter-
 vals prescribed  for episodes will require a much heavier workload than
 normal.  The extra level of effort involved both in observational pro-
 cedures and in data reporting, reduction, and analysis will be consistent
 with manpower and program funding limitations.  In light of criteria that
 have been  established for determining whether manual and semi-automatic
 networks should  be converted to  telemetered  real-time data reduction
 systems, the planned network does not yet warrant real-time operation.
However, the need and justification for this type of  operation will  be
periodically reviewed.

 5.1.3.4 Source  Inspection
         Under episode conditions, it is the principal field duty of the
 enforcement personnel to ascertain that the Emission Reduction Plan
 described  in Section  5.1.5 is being executed.  The available tools and
 procedures to exercise this  function are the same as those used in
 normal operations  (see Sections  6.2.1 and  6.2.2)  except  that  emphasis will
 be placed  upon quick action and rapid response measures.  Equipment
 needed for communications is specified in Section  5.1.2
         Verification of compliance is sometimes difficult.  For example,
 Ringelmann and opacity tests are of little use when a sulfur dioxide
 episode occurs.  Since an effective control technology for particulates
 is available today and reduction of visible emissions will inevitably
 result after outlay of  funds, effort  and public resolve, the major
 problem will become the  enforcement of sulfur dioxide emission reduction.
 Violations might sometimes be traced through monitoring station measure-
 ment, but  conclusive evidence must be obtained at the points of emission.
 It may be  necessary to enter the premises of a suspected violator armed

-------
with necessary legal instruments and test equipment.  Remedies may then
come too late to affect  the source of the episode.  More direct, faster,
legally admissible  techniques for determining the amount and type of
gaseous emission by scanning the plume from a distance will aid in
achieving compliance with  the Emission Reduction Plan.

5.1.4  Episode Legal Authority
       Enabling legislation necessary for the implementation of emergency
action exists in Indiana.  The discussion of episode legal authority  is
presented in Section 3 of  this report.
 5.1.5
       Emission Reduction Plan
       The objective of an Emergency Episode Plan is the temporary reduction
of emissions during episodes.  The Emission Reduction Plan  (ERP) is that
part of  the total episode plan which directs the orderly and equitable
control  of source emissions.  The ERP builds upon and utilizes the other
parts of  the episode plan that have been previously presented in Section  5.1,
that is:  episode criteria, surveillance networks, communications center,
and legal authority.
       An ERP objectively and quantitatively evaluates all  sources within
a region  and  selects  the sources for  control.  The criteria for selection
include  technical feasibility and economic reasonableness of emergency
control  and minimal disruption of community activities-
       The ERP  for the Indiana portion of the MCIAQCR will  be developed
promptly  after  the submission of this Implementation Plan.  Through
engineering and economic analyses of the sources in the two-county area
a series  of optimum emergency control strategies will be developed.
       Cooperation among the numerous jurisdictions in the  MCIAQCR is
imperative in developing the Emission Reduction Plan.  This is so because
(1)  the Plan,  once adopted,  must  be  executed  on a  regionwide basis  and  (2)
economices of  scale will result  by having one central  unit,  the APCO
Committee, responsible for all episode avoidance activities  of  the  Region.
Thus,  in developing the Emission Reduction Plan for  the MCIAQCR,  some
specific responsibilities will be performed by the Committee

-------
and others by the individual States.  The separation of tasks and the
procedure for developing the ERP is,illustrated by the flowchart in
Figure  5-3.  The elements of the Emission Reduction Plan are summarized
in Table  5-2.
       To curtail emissions during  episodes, a set of emergency strategies
for achieving rapid step-wise reductions will be developed.  Progressively
more stringent control strategies will be specified for each episode
level as greater emission reduction is required.  Substantial background
information will be necessary to determine the essential strategies.
       As indicated in Figure 5-3,  Emergency Control Questionnaires will
be used in conjunction with Emission Reduction Guides to obtain the
required technical and cost information from selected sources.  The
plans submitted by the surveyed sources will be reviewed and approved by
the air pollution control agency of each state.  Plans that are not
acceptable will be returned to the  source.  If the source does not resub-
mit a plan, the air pollution control agency will make the necessary
revisions.  Such adjusted plans will be  enforced during episodes.
       Once alternative strategies have been evaluated, the optimum
strategy will be announced to sources and the public with additional
information on recommended procedures for acting and communicating
during episodes.

 5.1.6 Time Schedule for Emergency Episode Plan Development
       The development of the Emergency Episode Plan will require significant
time and effort to  complete.  A time schedule for the completion of essential
requirements of the Plan is presented in Table  5.4   The schedule is based
on estimates which assume State personnel will begin actively developing
the Plan soon after the adoption of the Implementation Plan.

5.2  INTERIM EMERGENCY EPISODE PLAN
     Since the comprehensive Emergency Episode Plan will not be immediately
available, an interim Plan will be adopted to protect the citizens of the
Region.  Specific actions for control control, agency personnel, and
relevant organizations have been developed for the MCIAQCR and the states

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      Air Pollution
         Control
        Officers
        Committee
                                   Select Emergency

                                   Source Categories
                              Develop
                             Emission
                             Reduction
                            Guides (ERG)
                          Develop
                         Emergency
                          Control
                        Quest.  (ECQ)
I
I—>
L^J
          State
           of
         Indiana
   Develop
   Survey
  Procedures
                                                                                    Survey
                                                                                   Candidate
                                                                                    Sources
                                                      eview
                                                 Source Control
                                                      Plans
Develop Source
Status Report
   Procedure
                                                                                                         Not
                                                                                                         Acceptabl<
                                                               Acceptable
                                                                                   Evaluate
                                                                                 Control Plans
                                                                                for All Sources
                                                       Periodically
                                                       Update Plans
                                                       & Strategies
                                                     Prepare
                                                   Alternative
                                                    Emergency
                                                   Strategi es
                  Figure 5-3.
PROCEDURE FOR DEVELOPING THE
EMISSION REDUCTION PLAN
  Announce
Most Probable

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Emergency*
 Source
Category
II & III
IV
Emission Reduction Guides   Emergency Control Questionnaires
Detailed process and fuel
combustion analysis
per source category;
extensive review of con-
ventional and emergency
control techniques

Review of fuel combustion
and incineration operating
techniques and emergency
control alternatives

None
                                        Complete examination of emissions
                                        control alternatives and direct
                                        and indirect effects on emitters,
                                        region, and nation
                                        Quantification of emission
                                        curtailment alternatives and
                                        effectiveness
                                        None
Source Surveys
Questionnaire followed
by visitation and con-
sultation
Questionnaire reviewed
by telephone if necessary
                                                                              None
Source Status Report
Detailed report of
immediate ability to
control plus impact
of actions on other
sources and region
Observation of fuels
used
                                                                                                         Observation of traffic
                                                                                                         density
emergency Instruction
	Notification

Detailed instructions
to source emissions
control and communi-
cate responsibility
during episode
Instructions on required
actions during episode
                                                                                                                     Instructions on required
                                                                                                                     actions during episode
*See Table 5-3 (which directly follows) for the proposed Emergency Source
 Categories for the MCIAQCR

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           Table 5-3.  PROPOSED EMERGENCY SOURCE CATEGORIES FOR THE MCIAQCR*
ESC-I:  INDUSTRIAL AND STEAM ELECTRIC POWER
           Food and Kindred Products
           Furniture and Fixtures
           Paper and Allied Products
           Printing, Publishing  and Allied Industries
           Chemicals and Allied Products
           Petroleum Refining and Related Products
           Stone, Clay, Glass and Concrete Products
           Primary Metals Industries
           Fabricated Metal Products, except Ordnance, Machinery and
           Transportation Equipment
           Machinery, except Electrical
           Electric, Gas, and Sanitary Services (except incinerators)
ESC-II: COMMERCIAL FACILITIES
           Commercial
           Office Buildings
           High-Rises
           Hospitals
           Private and Professional Schools
           Construction
ESC-III;GOVERNMENTAL FACILITIES

        •  Governmental Offices
        •  Municipal Incinerators
        •  Schools
        •  Military Bases

ESC-IV: TRANSPORTATION AND RESIDENTIAL

        •  Automobiles
        •  Airlines
        •  Mass Transit
        •  Private Dwellings
*See Table 5-2

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    TABLE 5-4. METROPOLITAN CINCINNATI INTERSTATE AIR QUALITY CONTROL REGION, INTERIM EMERGENCY EPISODE PLAN
Section I
EPISODE CRITERIA
High Air Pollution Potential
Advisory (hours)
Air Quality
Measurements
(24-hour '
Averages)
Particulates
(COH/1000 LF)
Sulfur Dioxide
(ppm)
(F)
FORECAST
36
No specified level
No specified level
(A)
ALERT
None needed
2.0
0.10
(W)
WARNING
None needed
4.0
0.25
(E)
EMERGENCY
None needed
6.0
0.40
Section II
INTRASTATE EPISODE AUTHORITY
Authorized State AP Official
State Governor(or AP Commissioner)
State Attorney General Office
(F)
FORECAST
Alert staff
No action
No action
(A)
ALERT
Activate "alert" staff and
announce "alert"
No action
Nc action
(W)
WARNING
Activate "warning" staff
Announce "warning"
Assist enforcement procedures
(E)
EMERGENCY
Activate "emergency" staff
Announce "emergency"
Assist enforcement procedures
Ul
I
Section III
EPISODE SURVEILLANCE
Air Quality Monitoring
Meteorological Monitoring
Data Handling
Source Surveillance
(F)
FORECAST
Increase measurement frequency
Increase frequency of measurements
Evaluate incoming data and
prepare wall charts
No action
(A)
ALERT
Maintain hourly measurements
Maintain frequency of measurements
Evaluate incoming data and
prepare wall charts
Inspect major sources
(W)
WARNING
Maintain hourly measurements
Maintain frequency of measurements
Evaluate incoming data and
prepare wall charts
Follow plan for source
inspection
(E)
EMERGENCY
Maintain hourly measurements
Maintain frequency of measurements
Evaluate incoming data and
prepare wall charts
Follow plan for source

-------
H

cr
M


Ul
 I
o
o
3
rr
SECTIOH IV
TTATE I^TTION REDUCTION PLANS
Control Strategist
Power Generating
Other Fuel Burning Sources
Industrial
Commercial
Processing
Residential
Fuel Suppliers
Incineration
Municipal
Commercial
Residential
Open Burning
Manufacturing
Cont inuous
Batch Process
Commercial
Entertainment
Office Work
Business
Government
Schools
General Office
Construction
Motor Vehicles
Public Transportation
(F)
FORECAST
Review emission reduction plans
inform of conditions
No action
No action
No action
No action
No action
Alert
No action
No action
Alert
No action
Alert
No action
No action
No action
No action
No action
Ho action
No action
No action
(A)
ALHTT
Request "alert" control
Substantial reduction - fuel
switch or load shift
Fuel svitch - limit cleaning and
start-up;partial shutdown
Substantial reduction
Fuel switch; limit cleaning and
start-up
No action
Provide assistance to customers
Maximum reduction
Maximum reduction
Prohibit operations
Prohibit operations
Minimum reduction
Minimum reduction
No action
No action
No action
No action
No action
Shut down dust production
activities
No action
No action
(W)
WARNING
Request "warning" control
Maximum reduction - fuel switch
or load shift
Fuel switch - limit cleaning and
s tart- up ; part i al s hut down
Maximum reduction
Fuel switch; limit cleaning and
start-up
Limit electrical consumption and
reduce room temperature to 65°F
Provide assistance to customers
Prohibit operations
Prohibit operations
Prohibit operations
Prohibit operations
Maximum reduction
Partial shutdown
Prepare to shut down
Prepare to shut down
Prepare to shut dovn
Prepare tc shut down
Prepare to shut down non-
essential activities
Prepare to shut down all
activities

be stopped
Ho action
(E)
EMERGENCY
Request "emergency" control
Maximum reduction - fuel switch
or load shift
Maximum possible reduction
Maximum possible reduction
Maximum possible reduction
.
reduce room temperature to 65°?
Provide assistance to customers
Prohibit operations
Prohibit operations
Prohibit operations
Pr ohib it ope rat i ons
Maximum reduction or curtail
operations "
Curtail operations
Shut down
Shut down
Shut down
Shut down
Shut down non-essential
activities
Shut down all activities
Prevent all but emergency travel
to downtown

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                                                               Table  5-4.    (continued)
SECTION V
EPISODE COMMUNICATIONS
(from emergency operation contra! center to:)
Federal Facilities
Emission Sources
News Media (puDlic)
Hospitals
Police Department
Telephone Company
NAPCA
ESSA (U.S. Weather Bureau)
State Governor (or AP Commissioner)
State Pepartnent of Traffic 1 Highway
C
S
C
C
S
C
C
C
S
5
(F)
FORECAST
Not notified
Inform selected sources
Not notified
Not notified
Not notified
Not notified
Report conditions
Request meteorological info.
Not notified
Not notified
(A)
ALERT
Contact through NAPCA
r epresentat ive
Contact through news media and
telephone
Send press release "AM
Recom™:ena precautionary measures
Alerted
Alerted
Report conditions
Request meteorological info.
Report condit ions
Alerted
(w)
WARRING
Contact through NAPCA
representative
Contact through news media and
telephone
Send press release "W"
Recommend precautionary measures
Request enforcement assistance
Request emergency procedures
Report conditions
Request meteorological info.
Request "Warning" Announcement
Request traffic reroute
(E)
EMERGENCY
Contact through NAPCA
representative
Contact through news media and
telephone
Send press release "E"
Recommend precautionary measures
Request enforcement assistance
Request emergency procedures
Request assistance
Request meteorological info.
Request "emergency" announcement

q
NOTE:
 C = announcement resulting from APCO Committee dicision

-------
                                                                   Table  5-4.   (continued)
SECTION VI
EMERGENCY EPISODE STAFF
"OCC Director
Chief Chemist
Chief Engineer (Strategist)
Chief Compliance Officer
Program Management, Chief
Control Engineers
Meteorologist
Chemists
Technicians
Inspectors
Clerical
Records Analysts
Physicians (volunteers)
Communication Specialists
State Police Department
E
E
E
S
E
S
E
S
S
S
E
E
E
E
S
(F)
FORECAST
Alerted
Alerted
Alerted
Alerted
No action
No action
Issue local air pollution
advisories
No action
Collect air quality samples
No action
Record data and operate
telephones
Review emergency control data
No action
No action
No action
(A)
ALERT
Direct staff, communicate with
state official, review public
announc emen t
Coordinate air quality monitoring
and analysis
Determine optimum source
control strategy
Coordinate Field inspections
Coordinate data handling effort
Assist sources and evaluate
control status

data, evaluate data.
Analyze samples
Collect and evaluate air quality
samples
Source inspections
Record data and operate
telephones
Supply strategist with data and
maintain wall charts
Ho action
Prepare special press releases
Review enforcement procedures
(w)
WARNING
Direct staff, communicate with
announcement
Coordinate air quality monitoring
and analysis
Determine optimum source
control strategy
Coordinate field inspections
Coordinate data handling effort

control status

data, evaluate data
Analyze samples
Collect and evaluate air quality
samples
Source inspections
Record data and operate
telephones
Supply strategist with data and
maintain wall charts
Consult with Director

Assist with enforcement

-------
in the MCIAQCR.  The actions are presented in Figure 5-4.   The following
aspects of the Emergency Episode Plan are presented for the Forecast,
Alert, Warning, and Emergency stages:
     I.  Episode Criteria
    II.  Intrastate Episode Authority
   III.  Episode Surveillance
    IV.  State Emission Reduction Plans
     V.  Episode Communications
    VI.  Emergency Episode Staff
     The interim Emergency Episode Plan heavily depends upon voluntary
compliance of major sources within the MCIAQCR.  Nearly all sources are
candidates for emergency control during episodes.  A list of the ma.lor
point  sources  is presented  in Table  5-5.  Only three of the sources
in  Indiana have particulate or  sulfur oxide  emission rates equal
to  or  greater  than  one  ton  per  day.  The pollutant emission rates
were determined by  the  NAPCA emission inventory for the MCIAQCR.
     The interim Plan includes the required actions to be taken by
each source category at specific stages of an air pollution episode.
The Plan is based on general knowledge of the source types and the
ability of such sources to control emissions during episodes.
     At the present time, the engineering and economic information about
each source within the MCIAQCR is not available to determine scientifically
the optimum strategy or series of preferred strategies.  Short-term episode-
meteorological diffusion models for regions are not available at this time
to test the adequacy of the proposed interim Plan.  Without analytical tools
to evaluate the effectiveness of the Plan, a philosophy which stresses
the protection of the health of the citizens has been taken.  Thus, a
relatively stringent Plan is recommended.  When meteorological tools are
developed and are practical for a region the size of the MCIAQCR, such
will be incorporated into the comprehensive Emergency Episode Plan.
     A selected emergency emission reduction strategy may be used when
an episode is discovered in one localized area.   The most efficient and
economical strategy in such a case will be the emergency control of sources
within the immediate geographical area or control of nearby sources that
are directly affecting the episode.


-------
Tasks:
 July     Dec.     July     Dec.     July
j 1970    | 1970    I 1971    [ 1971    [ 1972
Dec.
1972
July
1973
Develop Emergency Operations
Control Center
Develop Emission Reduction Plan
                  Figure 5-4.    INDIANA EMERGENCY EPISODE PLAN

-------
        Table 5-5.  MAJOR POINT SOURCES IN THE MCIAQCR
         „                             Sulfur Oxides     Particulates
         bource                         (tons/year)        (tons/year)
INDIANA

  Dearborn Dump No. 4                       0.03              1.13

  Jos. E. Seagram & Sons, Inc.              3.64              2.45

  Indiana & Michigan Elec. Company        339.30             64.75
   (Tanners Creek Station).

-------
     Whenever possible, sources in similar source categories will be
treated equally.  The factors of:  (1) effectiveness of temporary
control, (2) the required response time for emergency control, and
(3) economic impact on the source will all be considered  in  deter-
mining the interim ERP, when such factors are known.
     Although the interim ERP will be based on voluntary compliance
of major point sources, temporary injunctive relief can be requested
through local courts  when sources will not voluntarily comply with
control orders.
     Until the recommended air quality monitoring network is
operational, the existing network will satisfy the need for episode air
quality determination.
     Meteorological information will be obtained from the U.S. Weather
Bureau.  Additional meteorological information, if needed, will be
obtained through private sources.

-------
                        6.   AIR QUALITY MONITORING

 6.1  OBJECTIVES
      Ambient air sampling  is required to assess  current  air quality,  determine
 the degree of improvement  necessary and measure  the results of control and
 abatement actions.   A second major requirement is for the provision of in-
 telligence prior to, during, and following actual or potential air pollution
 episodes in order to determine emission curtailment tactics for episodal
 avoidance.
      Requirements are divided into two categories, based on desired averaging
 times:
      •   Contaminant concentration on a schedule; intermittent  hourly/daily
         basis
      •   Continuous  real-time monitoring providing 15-minute average
         concentrations and running averages of one hour, eight hours,
         and 2k hours
      Based on these criteria, two types of air quality monitoring sites
 are required.  These are designated as primary and secondary monitoring
 stations.
      The following are the pollutants of immediate concern, the techniques
 for monitoring, the type of equipment needed,  averaging  time,  and data
 summary report period for  primary and secondary  monitoring sites.
                  Monitoring
                  Technique
Primary Monitoring Station

        Sensor
Averaging
  Time
                  Colorimetric
                       or
                  Coulometric
        Continuous
Hourly
Pollutant
Sulfur Dioxide
 Particulates
 Wind Speed**
 *One-Hour averaging during episodes
**Taken at several selected sites (to be determined)
Report
Period
Monthly
Filtration
(Suspended)
Filtration
(Soiling)
Anemometer
Wind-Vane
Intermittent
Continuous
Continuous
Continuous
2^-Hour
2-Hour*
Hourly
Hourly
Quarterly
Monthly
Monthly
Monthly

-------
                       Secondary Monitoring Station
Pollutant
Monitoring
Technique
Sulfur Dioxide   Colorimetric
Particulates
Filtration
(Suspended)
                               sensor
Averaging
  Time
Hourly
Intermittent
(daily, 2U
samples)
Intermittent   2^-Hour
Report
Period
Monthly
                Quarterly
6.1.1  Location of Sampling Stations
       Air quality monitoring sites represent pollutant density in their
immediate area (normally within a radius of 1/2 - 3/U mile around the site),
are directly influenced "by the proximity of emission source.^ (emission
density), and monitor the impact of pollutants on people working of living
in their immediate area (dosage).  Therefore, each projected station has
been evaluated according to these three considerations as follows:
       •  Pollution Density*
          Based on real and simulated pollutant averages, annual levels of
          suspended particulates and sulfur oxides were plotted according
          to multiple concentration ranges.  These were classified as values
          greater than, equal to, and less than approved Air Quality
          Standards.
       •  Population Density*
          Based on 1968 data, population density  was plotted by three
          categories; high, median, and low.
       •  Emission Density*
          Based on emissions inventory data (1969) compiled for this report
          for suspended particulates and sulfur oxides, annual emission
          densities were plotted.  These are representative of high, median,
          and low levels of source concentrations.
       Table 6-1 presents the projected regional air quality monitoring
network.  Each site is des.cribed by category and evaluated according to
the above noted criteria.  Its location in the AQCR is fixed and its
actual or scheduled start-up is listed.  The numbers and general  locations
of sampling sites were selected to represent the best judgment regarding
the allocation of resources necessary to meet the previously stated sur-
veillance  objectives.
*Maps showing the pollutant concentrations, population density, and emission
 density are presented in Section 1 and we:'e used in determining  sampler
 placement.

-------
TABLE 6-1.  PROJECTED REGIONAL AIR QUALITY
            MONITORING'NETWORK
Station
Type

o Primary
o Primary
o Primary
o Primary
o Secondary
o Secondary
o Secondary
o Secondary
o Secondary
o Secondary
o Secondary
o Secondary
o Secondary
Pollution
Density
H
X
X

X
X
X


X
X



M


X



X



X
X

L







X




X
Population
Density
H
X
X
X
X
X
X
X

X

X


M







X

X

X
X
L













Emission
Density
H
X
X

X
X
X



X



M


X



X

X


X

L







X


X

X
Location

Central and Ann
Streets, Cincinnati,
Ohio
Drake Hospital
Galbraith Road
Cincinnati, Ohio
Main and Dayton
Streets, Hamilton,
Ohio
600 5th Street
Newport , Kentucky
1055 Laidlaw Avenue
Cincinnati, Ohio
General Protestant
Orphanage, Madison
Road, Cincinnati , Ohio
Parkland & Twain
Saylor Park
Cincinnati, Ohio
800 Bauer Ave.-B.H.S.
Batavia, Ohio
Galbraith & Blue Ash
Deer Park, Ohio
E. Uth St. - F.H.S.
Franklin , Ohio
Sharon & Winton Roads
Greenhills, Ohio
230 S. Elm Street
Harrison, Ohio
25 Oakwood Avenue
Lebanon, Ohio
Start-Up
Date

Jan. ,
1962
Jan. ,
1971
April,
1971
Jan. ,
1971
Jan. ,
1968
April,
1971
July ,
1971
July,
1971
July,
1971
Jan. ,
1971
July,
1971
Jan. ,
1971
Jan. ,
1971

-------
TABLE 6-1 Continued:
Station
Type

o Secondary
o Secondary
o Secondary
o Secondary
o Secondary
o Secondary
o Secondary
o Secondary
o Secondary
o Secondary
o Secondary
o Secondary
Pollution
Density
H

X

X

X

X




M
X

X





X
X
X

L




X

X




X
Population
Density
H

X





X
X



M


X

X
X



X
X
X
L
X


X


X





Emission
Density
H

X
X


X
X
X


X

M
X







X



L



X
X




X

X
Location

State & Hill Streets
Miamitown, Ohio
12 Uo Central Avenue
Middletown, Ohio
N.E. Fire Dept. ,
Market Street
Nev Richmond, Ohio
U.S. 50 & St. Rt. 128
North Bend, Ohio
Talawanda High School
Chestnut Street
Oxford, Ohio
Short & E. Williams
Lawrenceburg, Indiana
State Route 56
Rising Sun, Indiana
7th and Scott Street
Covington, Kentucky
505 Commonwealth Ave.
Erlanger, Kentucky
Veterans Hospital
Ft . Thomas , Kentucky
Rt. 20
Petersburg, Kentucky
U.S. 25 & Stevenson
Road
Walton , Kentucky
Start-Up
Date

Jan. ,
1971
April ,
1971
July,
1971
July,
1971
Jan. ,
1971
Jan. ,
1970
Jan. ,
1971
Jan. ,
1968
Jan. ,
1967
Jan. ,
1971
July,
1971
Jan. ,
1971

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     Figure 6-1 graphically displays the network configuration.  Superimposed
on the display of sampling location is•an isopleth projection of predicted
annual arithmetic average particulate concentrations.  (See Section 2.2.)
This display indicates that areas of maximum pollutant concentrations will
"be adequately sampled by the proposed network.

6.1.2  Frequency of Collection
       Data will be collected on a continuous basis from all automatic S0_
analyzers utilized.  Sequential samplers will measure S0? for 2k consecutive
one-hour periods every'third calendar day.
       Twenty-four hour concentrations of suspended particulates will be
collected on all hi-vol samplers utilized every third calendar day.
       Soiling particulates will be collected continuously at two-hour
intervals at all primary  monitoring stations.

6.1.3  Methods of Sampling
       Prescribed methods of measuring and monitoring atmospheric sulfur
oxides are referenced from Public Health Service Publication No. 999-AP-6
(196^).  The methods for atmospheric sampling and analyses of suspended
particulate matter are referenced from the APCA Recommended Standard Method,
APM-2.5 (1967).  The methods for atmospheric sampling and analysis of
soiling particulate matter are referenced from the APCA Recommended Standard
Method, APM-2.1.

6.1.U  Data Handling and Analysis
6.I.U.I  Suspended Particulates
         Following the 2^-hour sample collection period, filters from the
high volume samplers are sent to the Analytical Laboratory operated in
Indianapolis by the Division of Air Pollution Control.  A laboratory
technician determines the concentration of particulates and records the
value and the appropriate identification information on data record forms.
Routine monthly and annual reports as well as specialized data analyses

-------
                            HAMILTON ~  .80
                                        KENTON   | CAMPBELL

                                         O
• Primary Station
O Secondary Station
              Figure 6-1.   Location of Proposed Air  Quality Monitoring
                           Stations in the  MCIAQCR.
                           Superimposed are Ground Level Particulate
                           Isopleth Concentrations (See Section U.2).
                           (Concentrations  shown represent annual
                           arithmetic mean  values in u/m^.

-------
are prepared manually.  Consideration is now being given to the  development
of a computerized data handling system.   Such a system would,  of course,
be designed to handle data from all State air monitoring activities.

6.1.4.2  Sulfur Dioxide
         The sequential samplers used to determine sulfur dioxide
concentrations yield 2k one-hour average samples.   These samples are
forwarded to the laboratory in Indianapolis for analysis.  Presently,
all data handling including the preparation of monthly and annual
reports and special data analyses is done manually.
         When and if a computerized data handling  system is developed
for the air monitoring activities conducted statewide by the Commission,
data from the sequential samplers will also be handled by automated
techniques.

6.1.U.3  Episode Sampling
         During conditions of high or potentially  high air pollution,
the primary sampling stations, none of which are located in Indiana,
will be of foremost importance.  The Episode Control Officer may,
however, direct collection of special samples at the two secondary
stations located within this State.  These samples would be analyzed
at a central laboratory within the MCIAQCR rather  than at Indianapolis,
since rapid utilization of the air quality data is of the utmost impor-
tance in emergency situations.

-------
are prepared manually.  Consideration is now being given to the development
of a computerized data handling system.   Such a system would,  of course,
be designed to handle data from all State air monitoring activities.

6.1.U.2  Sulfur Dioxide
         The sequential samplers used to determine sulfur dioxide
concentrations yield 2k one-hour average samples.   These samples are
forwarded to the laboratory in Indianapolis for analysis.   Presently,
all data handling including the preparation of monthly and annual
reports and special data analyses is done manually.
         When and if a computerized data handling  system is developed
for the air monitoring activities conducted statewide by the Commission,
data from the sequential samplers will also be handled by automated
techniques.

6.1.U.3  Episode Sampling
         During conditions of high or potentially  high air pollution,
the primary sampling stations, none of which are located in Indiana,
will be of foremost importance.  The Episode Control Officer may,
however, direct collection of special samples at the two secondary
stations located within this State.  These samples would be analyzed
at a central laboratory within the MCIAQCR rather  than at Indianapolis,
since rapid utilization of the air quality data is of the utmost impor-
tance in emergency situations.

-------
This page is blank.

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6.2  CONTROL OF EMISSION SOURCES

     This function of the total air pollution control effort encompasses

both Engineering and Enforcement services personnel.   It includes tvo
separate systems, each system being made up of two programs as follows:

     •  Source Surveillance

        (a).  Source Identification and Registration
        (b).  Permit to Construct
        (c).  Permit to Operate

     •  Source Inspection - Field Operations

        (a).  Fuel Burning Sources, Industrial Sources
        (b).  Complaint Investigations and Field Patrol


6.2.1  Source Surveillance

       All new or existing control apparatus and/or appropriate equipment

used within the Region will be required to obtain a Permit to Construct

and/or a Permit to Operate.  This mechanism will guarantee source identi-
fication and registration.  The following apparatus and equipment will be

required to obtain Permits:

       •  All control apparatus

       •  Equipment used in a manufacturing process involving  surface
          coating, including but not limited to spray and dip painting,-
          roller coating, electrostatic depositing or spray cleaning
          which emits air contaminants into the open air and in which
          the quantity of material used in any source operation is in
          excess of 10 pounds in any one hour.

       •  Equipment used in a manufacturing process involving metal
          cleaning or surface preparation, including but not limited
          to degreasing, etching, pickling, or plating which emits air
          contaminants into the open air from a tank or vessel, the
          capacity of which is in excess of 100 gallons.
       •  Equipment, used in a manufacturing process, with some exceptions
          to be defined, which emits air contaminants into the open air
          either directly or indirectly and in which the combined weight
          of all materials, excluding air and water,  introduced into any
          one source operation is in excess of 50 pounds in any one hour.
       •  Liquid storage tanks, reservoirs, and containers, used for
          the storage of acids, solvents, diluents or thinners, inks, -
          colorants, lacquers, enamels, varnishes, liquid resins and
          having a capacity in excess of 10,000 gallons.

       •  Pneumatic material handling or conveying systems.

-------
       •  Commercial fuel burning equipment in which the rate of solid
          fuel burned is in excess of 1,000,000 BTU's in any one hour.
       •  Any equipment used for the burning or incineration of non-
          commercial fuel or process by-products in the form of liquid,
          solid, or gas.
       •  Any incinerator, except incinerators constructed, installed,
          or used in one or two family dwellings or in multi-occupied
          dwellings containing six or less family units, one of which is
          owner occupied.
       Prior to issuance of a Permit to Operate, an engineer will observe
the equipment in operation at design capacity.  At that time, the equipment
will be checked with the plans and specifications previously submitted.
During the inspection, observations will be made to determine that:
       •  the equipment is physically located as shown on the equipment
          location drawing,
       •  the equipment is constructed as indicated in the application,
       •  the equipment is capable of operating in compliance with the
          applicable rules and regulations of the State Air Pollution
          Control Agency,
       *  source testing is or is not necessary.
Based on the engineers' inspection and evaluation of the equipment and
process as well as relevant source test results, a recommendation will
be made by the engineer regarding the issuance or denial  of permit  to
operate.  After review and approval of the recommendation, action will
be taken by the State Agency to approve or deny the Permit to Operate.
       Source testing capability  to support the Permit to Operate program
currently exists in the Cincinnati Agency,  for the Ohio Program.
It will be developed or expanded in the Kentucky and Indiana state agencies.
This capability will consist of trained personnel (normally a two-man team)
and equipment for determining particulates ,sulfur oxides, and other gaseous
emissions.
       A person desiring to construct or alter and operate any equipment
capable of emitting air contaminants will be required to apply for a
Permit to Construct from the appropriate air pollution control agency.
The agency will furnish application forms, written instructions, and
information required for proper filing.  The application will be logged,
dated, and assigned an identification number.   All information pertinent

-------
to the application, including data and drawings, will be submitted to an
air pollution control engineer for review and evaluation.  Based on the
engineer's review, the application will be approved and the applicant may
proceed with construction, or the applicant will be requested to confer with
the engineer to discuss questionable aspects of the application.  In the
event that disagreements cannot be resolved by submission of additional
information, minor changes in the proposals, or an acceptable explanation
by the applicant, the application will be denied.
       This mechanism will be installed and operated by the
Necessary emissions inventory data will be abstracted at the local level
by the State Agencies for entry into the Regional Data Bank.  The State
will reserve the right to negate Permits to Operate issued to sources
which are found   in  violation       of State regulations.

6.2.2  Source Inspections - Field Operations
       Equipment installed, placed in operation, and issued a Permit  to
Operate will then come under the jurisdiction of Enforcement Services
personnel.  This group is responsible for policing sources of air pollution
within its area of jurisdiction to insure compliance with applicable rules
and regulations of the agency.
       Each Enforcement Unit will encompass the following functional
activities:
       Industrial Inspections
       •  Continuously inspect assigned manufacturing plants
       •  Prepare source inventories
       •  Check compliance with permit system and conditions of variances
          in assigned industries
       •  Investigate breakdowns
       •  Investigate complaints made against assigned industries
       Field -Patrols
       •  Patrol assigned zones including highways and waterways for all
          visible violations from stationary and mobile sources
       •. Enter and cite all plants where visible violations are observed
       •  Keep under surveillance plants on referral from other sections
       •  Answer public complaints


-------
       C ommun i c at i ons
       •  Maintain and operate radio transmitter and receiver 2k hours a
          day for:
          a.  Complaints, instructions, and data to mobile units
          b.  Declaration of alerts to specified industries and all
              mobile units
          c.  Receipt and recording of data from air monitoring stations

6.2.3  Schedule
       The Source Surveillance System vill be completely implemented and
operational by January 1973.
       The Field Operations and Inspection Systems will be operational
by January 1972.

6.3  REGIONAL DATA BANK
     A regional data bank will be established and maintained by the City
of Cincinnati agency.  In order to maximize the utility of collected data
in planning and decision making, a total data management system will be
developed.  Following is a brief summary of the elements of such a system
and an estimate of the monthly computer time.
     t  Air Quality and Meteorological data (Operational by July 197l)•
     It will be necessary to develop a series of ten computer programs to
handle the routine processing of air quality and meteorological data.  The
air quality monitoring system will yield in excess of 50,000 measurements
each month.  It will be necessary to convert these data to engineering
units, validate the data, update master files, and prepare routine data
tabulations and statistical summaries.  The monthly computer usage will
be ten hours.
     These programs will provide a continuing evaluation of the progress
toward the attainment of air quality standards.  In addition, the programs
will provide frequency distributions of pollutant concentrations, relation-
ships among air quality and meteorological parameters, geographical
distribution of pollutants, and the like.  The monthly computer usage will here
be six hours.  Approximately two hours per month of an x - y plotter will
be utilized.


-------
     •  Emission Inventory (Operational by January 1971)
     The data bank will maintain a current inventory of all sources of air
pollution.  Such data is necessary to show progress being made in the
reduction of total emissions to the atmosphere.  A series of k-6 computer
programs will be developed to handle this data; the actual update of the
inventory will result from the data collected through the operation of the
Permit System.  File update  will require four hours of computer time per
month.
     •  Permit System (Operational by January 1971)
     To maintain control of sources of air pollutants, a permit system
will be established.  Administration of this system will require a series
of 3-1+ computer programs.  Monthly computer time required will be four
hours per month.
     •  Diffusion Modeling (Operational by January 1972)
     In order to assess the adequacy of emission regulations, it is
necessary to supplement measurements of air quality with estimates of air
quality derived from a mathematical model of atmospheric diffusion.
Computer programs are available from NAPCA.  Minor modifications will be
made to adapt these programs to the RCA Computer.  Diffusion modeling
will be performed on an annual basis and will require 20 hours per year.

6.1*  AIR QUALITY DATA TRANSMISSION
     Routinely, data from the continuous analyzers will be manually reduced,
punched on input cards, and stored in the computer.  No extensive telemetry
system will be initially employed.
     However, a telephone interrogation system for the automatic monitors
at all primary sampling stations will be installed as the stations are
activated.  This system will consist of a telephone, data processing set,
and a teletype printer located at the control center (Cincinnati Air
Pollution Control Agency).  A data transmission set and a computer-
serializer unit will be located at each remote site.  A command from the
control center, generated by dialing the unlisted phone of the field station,

-------
will signal the data transmission set which then activates the computer-
serializer unit.  This unit takes a millivolt signal from the appropriate
automated monitor and converts it to a signal compatible with the Bell
System transmissions equipment.  At this point, the transmission set sends
a signal over the Bell System's lines to the central control station.   The
signal is then processed and displayed by means of a teletype printer.
After processing sequentially through the available field monitors, the
computer-serializer generates a disconnect pulse for the completion of
the sequence.
     The major objectives of this system are:
     •  Routine interrogation of field stations to establish the
        priority of maintenance requirements.  A more efficient
        utilization of the instrument technician will be achieved,
        thus resulting in the overall reduction of manpower needs.
     •  Frequent interrogation during emergency episode periods
        to provide the EAC with a link to "real-time" data.

-------
                               7.  RESOURCES

7.1  GENERAL
     The enactment of enabling legislation and the adoption of emission control
regulations will not of themselves accomplish the air quality goals set forth
in this Implementation Plan.  Realization of these goals depends to a great
extent upon the ability of the control agencies to enforce abatement programs.
Such enforcement, in turn, is contingent upon the availability of adequate
resources, the most crucial resource being manpower.

     In the determination of manpower requirements, the NAPCA model was used.
Briefly, this model uses four area characteristics (land area, population, number
of manufacturing establishments, and capital expenditures) to establish man-years
of effort required to support some fourteen functions carried out by a control
agency.
     The organizational structure of the various control agencies within the
MCIAQCR is an important factor in determining the required  resources.  An
analysis of the various organizational alternatives considered in the preparation
of this Implementation Plan is presented in Appendix C.
     The following two sections present the control agency requirements for the
Indiana portion of the MCIAQCR as determined by the manpower model.  All
funds will be provided by the state with matching federal funds and all
personnel will be hired by the Indiana State Agency.  All state operations will
be directed from the central offices in Indianapolis.

7.2  CALCULATED MAN-YEARS
     Area characteristics for each county are presented in Table 7-1.  The
manpower model was used to estimate man-years of effort required in the
entire Indiana portion of MCIAQCR.  A summary of the output from the manpower
model is presented in Table 7-2.  A total of 3.1 man-years of effort is
required to sustain an adequate control program for the four county area.

     A summary of man-years which existed at the end of FY 1970 (June 30, 1970)
is presented in Table 7-3.  It is apparent that the manpower presently
committed to the four county control agencies are far from adequate.  Assuming
that the necessary funding discussed in the following section is available,
the recruitment of the necessary personnel presents a serious problem.

-------
TABLE 7-1  .   INPUT CHARACTERISTICS OF INDIANA NEEDED FOR MANPOWER ESTIMATES
County (ies)
Indiana
Dearborn
Ohio
Total
Region Total
Area
(Sq. Miles)

306
87
393
2707
Population
(1970 est.)

30.8 x 103
4.5 x 103
35.3 x 103
1.735 x 106
Manufacturing
Establishments

33
6
39
2172
Capital
Expenditure
($)

6
2.2 x 10
8 x 10"
2.2 x 106
94.6 x 106

-------
TABLE 7-2  .   SUMMARY OF MAN-YEAR ESTIMATES FOR INDIANA PORTION OF MCIAQCR
FUNCTION
1.
2.
3.
4.
5.
6.
7.
8.
9.
10 .
11.
12.
13.
14.
Monitoring
Primary
Secondary . ,
Total
Inspections
Complaints
Permits
Policy
Training
Special Studies
Emission Estimates
Engineering Reports
Administration
Data Processing
Source Testing
Instrumentation
Laboratory
PREDICTO'R
0
3
•
•
•
i.
i.
i.
i.
i.
i.
i.
0.
0.
0.

04
3
02
2
2
2
2
2
2
2
3
7
8
MANPOWER FACTOR
0
0
2
1
9
0
0
0
0
0
0
0
0
0
0
.5
.2
.8
.0
.7
.22
.12
.06
.05
.06
.59
.09
.10
.25
.35
CALCULATED
MAN-YEARS
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0
6
6
1
3
2
3
2
1
1
1
7
1
1
2
3
   Total                                                                3.1

-------
TABLE 7-3  .   ESTIMATED PRESENT MANPOWER UTILIZATION. BY CONTROL AGENCY
                     FOR INDIANA,.AND FOR THE TOTAL MCIAQCR
CONTROL PROGRAM
Management
Policy
Training
Administrative
Sub-Total
Enforcement
Inspections
Complaints
Source Registration
Sub-Total
Engineering
Permits
Emission Est.
Source Test.
Reports; Reg.
Sub-Total
Technical Services
Monitoring
Special Studies
Data Processing
Instrumentation
Laboratory
Sub-Total
TOTALS
STATE AGENCY
INDIANA

0.1
0.1
0.1
0.3
0.5

0.1
0.1
0.1
0.3

0.1
0
0
0
0.1

0
0
0
0
0
0
0.9
7-4
REGIONAL
TOTALS

2.6
1.6
2.6
6.8
11.0

2.4
5.3
1.1
8.8

0.2
3.3
1.1
0.0
4.6

1.0
0.0
0
0.0
1.0
2.0

-------
Approximately two additional full time men are required to adequately staff
the Indiana portion of the MCIAQCR.  These personnel will be hired over the
period FT 1971 through FY 1973.

7.3  FUNDING
     The funding required to support the Indiana Control Agency operating in the
MCIAQCR is projected upon the basis of the staffing presented in Table 7-2.
Salaries for the various categories of personnel are based upon information
contained in the NAPCA Program and Financial Needs Report for the MCIAQCR
(Table 7-4).  Salalies are burdened by an overhead factor equivalent to
one third of the base salary.  Overhead includes such things as; fringe
benefits, facilities and support, and additional operating expenses (travel,
utilities, consumables, etc.).

     A summary of costs for three years beginning with FY 1971 is presented
in Table 7-5.  The goal is to reach the required level of  peration by FY 1973
when it is estimated that in excess of $69,000 will be necessary.  This
represents about a three-fold increase over the existing level of funding.

     The sources of revenue which will produce the projected level of
funding are uncertain as of the writing of this report.  It is assumed that
basic program support will remain at the state level.  Furthermore, it is
assumed that  present Federal grants will be extended and two for one matching
funds will be provided for new monies put forth by local or state jurisdictions.

     A summary of the capital expenditures necessary to support air monitoring
activities over the period FY 1971 to FY 1973 is presented in Table 7-6.  The
total is distributed over each of the three fiscal years in Table 7-5.

-------
TABLE 7-4  .   AVERAGE SALARY ESTIMATES FOR AGENCY OPERATIONS
Management Activities                                   Annual

     Professional (25%)                              $ 16,000

     Non-Professional  (75%)                             8,000

Enforcement Activities

     Inspectors                                        10,000

Engineering Activities

     Engineers                                         14,000

Technical Services

     Chemists (40%)                                     10,000

     Technicians (60%)                                  5,000
Fringe Benefits, Facilities and Support,
plus Additional Operating Expenses                  33 1/3 % of Base
                                                             Salary

-------
          Table 7-5.   ESTIMATED EXPENDITURES  FOR INDIANA PORTION  OF MCIAQCR
                                Fy 71
                         72
                     73
Management Operations
     Salaries
     Operating Expense
     Facilities and support
   16,000
    5,300
      500
   21,800
   20,000
    6,600
      500
   27,100
  24,000
   7,900
     500
  32,400
Enforcement Operations
     Salaries
     Operating Expense
     Facilities and support
    5,000
    1,700
      500
    7,200
    5,000
    1,700
      500
    7,200
   5,000
   1,700
     500
   7,200
Engineering Operations
     Salaries
     Operating Expense
     Facilities and support
    7,000
    2,300
    5.000
   14,300
    7,000
    2,300
    1.000
   10,300
   7,000
   2,300
   1.000
  10,300
Technical Service Operations
     Salaries
     Operating Expense
     Facilities and support
Expenditures for Agency
   10,000
    3,300
    7.000
   20,300

   63,600
   10,000
    3,300
    4.000
   17,300

   61,900
  12,500
   4,100
   3.300
  19,900

  69,800
Expenditures for Region
1,083,400
1,230,350
1,472,450

-------
TABLE 7-6  .   ESTIMATED CAPITAL EXPENDITURES FOR THE INDIANA PROGRAM
                             WITHIN THE MCIAQCR
     ITEM
INDIANA
REGIONAL TOTALS
Air Monitoring Network

 Continuous Station

   Shelter

   Cont. S02 (Recorder)

   Tape Sampler

   Hi-Vol Sampler

   S02 Bubblers
                          $72,000

                           48,000

                           16,000

                            4,000

                            1,200

                            2,800
 Intermittent Station

   Hi-Vol Sampler

   S02 Bubblers

   Misc. Static


 Laboratory Equipment

 Computer Facilities
      (Time Sharing)

TOTALS
 $2,200 (2)

    600

  1,500

    100


 $10,000

   1,000
    $23,400 (21)

      6,300

     15,700

      1,000


    $50,000

      5,000
 $15,400
   $244,000

-------
                  APPENDIX A
                  TABLE  A-l
METEOROLOGICAL INPUT DATA FOR THE ANNUAL SEASON
               Stability Class 1

                   WINDSPEED CLASS
WIND DIRECTION
N
NNE
NE
E
ESE
SE
SSE
S
SSW
SW
WSW
W
WNW
NW
NNW

0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
1
.0001
.0
.0002
.0001
.0001
.0001
.0000
.0001
.0001
.0001
.0001
.0002
.0
.0001
.0001

0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
2
.0001
.0
.0001
.0002
.0003
.0003
.0001
.0003
.0002
.0001
.0002
.0002
.0
.0001
.0002

0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
3
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0

0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
4
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0

0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
5
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
6
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0

-------
                           TABLE A-l  (Continued)
               METEOROLOGICAL INPUT DATA FOR THE ANNUAL SEASON
                              Stability Class 2

                                    WINDSPEED CLASS
WIND DIRECTION
      N
      NNE
      NE
      ENE
      E
      ESE
      SE
      SSE
      S
      SSW
      SW
      WSW
      w
      WNW
      NW
      NNW
1
0.0009
0.0007
0.0012
0.0007
0.0007
0.0002
0.0004
0.0010
0.0020
0.0013
0.0010
0.0008
0.0009
0.006
0.0005
0.0003
2
0.0016
0.0010
0.0020
0.0012
0.0025
0.0012
0.0013
0.0013
0.0021
0.0020
0.0021
0.0028
0.0020
0.0010
0.0010
0.0012
3
0.0006
0.0008
0.0008
0.0014
0.0015
0.0010
0.0006
0.0006
0.0010
0.0012
0.0010
0.0018
0.0014
0.0011
0.0007
0.0009
4
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
5
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
6
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0

-------
            TABLE A-l (Continued)
METEOROLOGICAL INPUT DATA FOR THE ANNUAL SEASON
               Stability Class 3
                       WINDSPEED CLASS
1IRECTI
N
NNE
NE
ENE
E
ESE
SE
SSE
S
SSW
SW
WSW
W
WNW
NW
NNW
ON 1
0.0005
0.0003
0.0005
0.0006
0.0005
0.0002
0.0003
0.0003
0.0010
0.0013
0.0009
0.0007
0.0005
0.0002
0.0002
0.0002
2
0.0012
0.0014
0.0012
0.0009
0.0017
0.0010
0.0016
0.0010
0.0025
0.0036
0.0028
0.0022
0.0022
0.0006
0.0010
0.0008
3
0.0041
0.0019
0.0031
0.0032
0.0030
0.0025
0.0016
0.0017
0.0039
0.0052
0.0072
0.0073
0.0076
0.0039
0.0023
0.0016
4
0.0007
0.0003
0.0003
0.0005
0.0010
0.0003
0.0001
0.0001
0.0006
0.0010
0.0016
0.0012
0.0013
0.0008
0.0001
0.0002
5
0.0001
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0002
0.0001
0.0001
0.0
0.0
0.0
6
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0001
0.0001
0.0
0.0

-------
            TABLE A-l (Continued)

METEOROLOGICAL INPUT DATA FOR THE ANNUAL SEASON
               Stability Class 4

                   WINDSPEED CLASS
DIRECTION
N
NNE
NE
ENE
E
ESE
SE
SSE
S
SSW
SW
WSW
W
WNW
NW
NNW
1
0.0004
0.0003
0.0004
0.0006
0.0005
0.0004
0.0004
0.0011
0.0016
0.0012
0.0008
0.0010
0.0009
0.0010
0.0008
0.0002
2
0.0051
0.0035
0.0054
0.0050
0.0062
0.0051
0.0044
0.0043
0.0103
0.0077
0.0074
0.0071
0.0076
0.0041
0.0047
0.0033
3
0.0138
0.0089
0.0101
0.0114
0.0127
0.0082
0.0099
0.0091
0.0210
0.0211
0.0196
0.0156
0.0177
0.0130
0.0089
0.0061
4
0.0134
0.0070
0.0065
0.0058
0.0056
0.0039
0.0028
0.0036
0.0119
0.0186
0.0244
0.0184
0.0262
0.0193
0.0138
0.0070
5
0.0009
0.0005
0.0002
0.0003
0.0002
0.0003
0.0001
0.0001
0.0008
0.0028
0.0039
0.0029
0.0052
0.0036
0.0010
0.0005
6
0.0002
0.0001
0.0001
0.0
0.0
0.0001
0.0001
0.0
0.0001
0.0003
0.0010
0.0008
0.0012
0.0001
0.0001
0.0001

-------
                          TABLE  A-l (Continued)
              METEOROLOGICAL INPUT DATA FOR THE ANNUAL ASEASON
                             Stability Class 5
WIND DIRECTION
     N
     NNE
     NE
     ENE
     E
     ESE
     SE
     SSE
     S
     SSW
     SW
     WSW
     W
     WNW
     NW
     NNW
WINDSPEED CLASS

0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
1
.0023
.0033
.0034
.0039
.0058
.0055
.0047
.0045
.0148
.0131
.0102
.0035
.0029
.0021
.0017
.0009

0
0
0
0
0
0
0
2
.0067
.0079
.0088
.0107
.0114
.0098
.0088
0.0092
0
0
0
0
0
0
0
0
.0215
.0261
.0166
.0078
.0089
.0047
.0055
.0025

0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
3
.0046
.0030
.0030
.0045
.0043
.0016
.0011
.0017
.0039
.0039
.0060
.0041
.0063
.0035
.0029
.0014

0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
4
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0

0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
5
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0

0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
6
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0

-------
                  TABLE A-2

METEOROLOGICAL INPUT DATA FOR THE WINTER SEASON
              Stability Class 1
                       WINDSPEED CLASS
WIND DIRECTION
N
NNE
NE
ENE
E
ESE
SE
SSE
S
SSW
SW
WSW
W
WNW
NW
NNW
1
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
2
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
3
0.0
0.0 .
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
4
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
5
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
6
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0

-------
             TABLE A-2 (Continued)

METEOROLOGICAL INPUT DATA FOR THE WINTER SEASON
               Stability Class 2
                       WINDSPEED CLASS
WIND DIRECTION
N
NNE
NE
ENE
E
ESE
SE
SSE
S
SSW
SW
WSW
W
WNW
NW
NNW
1
0.0
0.0
0.0
0.0005
0.0
0.0
0.0
0.0
0.0009
0.0005
0.0005
0.0005
0.0005
0.0005
0.0
0.0
2
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
3
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
4
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
5
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
6
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0

-------
             TABLE A-2 (Continued)

METEOROLOGICAL INPUT DATA FOR THE WINTER SEASON
                Stability Class 3
                       WINDSPEED CLASS
WIND DIRECTION
N
NNE
NE
ENE
E
ESE
SE
SSE
S
SSW
SW
WSW
W
WNW
NW
NNW
1
0.0000
0.0005
0.0001
0.0005
0.0000
0.0000
0.0000
0.0001
0.0005
0.0011
0.0002
0.0011
0.0000
0.0001
0.0001
0.0007
2
0.0005
0.0
0.0009
0.0005
0.0005
0.0005
0.0005
0.0009
0.0005
0.0009
0.0018
0.0014
0.0009
0.0009
0.0014
0.0023
3
0.0005
0 . 0005
0.0005
0.0009
0.0005
0.0
0.0014
0.0
0.0014
0.0009
0.0027
0.0009
0.0027
0.0018
0.0009
0.0023
4
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
5
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
6
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0

-------
             TABLE A-2 (Continued)

METEOROLOGICAL INPUT DATA FOR THE WINTER SEASON
                Stability Class 4
                        WINDSPEED CLASS
WIND DIRECTION
N
NNE
NE
ENE
E
ESE
SE
SSE
S
SSW
SW
WSW
W
WNW
NW
NNW
1
0.0015
0.0005
0.0001
0.0000
0.0000
0.0010
0.0005
0.0010
0.0015
0.0024
0.0034
0.0011
0.0016
0.0006
0.0010
0.0001
2
0.0100
0.0050
0.0082
0.0032
0.0032
0.0046
0.0059
0.0041
0.0128
0.0091
0.0118
0.0146
0.0146
0.0087
0.0105
0.0100
3
0.0255
0.0123
0.0087
0.0068
0.0105
0.0137
0.0087
0.0091
0.0246
0.0150
0.0219
0.0173
0.0392
0.0319
0.0250
0.0114
4
0.0228
0.0041
0.0027
0.0014
0.0014
0.0064
0.0041
0.0055
0.0132
0.0150
0.0291
0.0314
0.0442
0.0364
0.0246
0.0137
5
0.0009
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0014
0.0082
0.0059
0.0105
0.0055
0.0032
0.0009
6
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0005
0.0014
0.0005
0.0009
0.0
0.0
0.0

-------
            TABLE A-2 (Continued)

METEOROLOGICAL INPUT DATA FOR THE WINTER SEASON
              Stability Class 5
                      WINDSPEED CLASS
WIND DIRECTION
N
NNE
NE
ENE
E
ESE
SE
SSE
S
SSW
SW
WSW
W
WNW
NW
NNW
1
0.0014
0.0016
0.0009
0.0025
0.0020
0.0034
0.0022
0.0018
0.0069
0.0051
0.0104
0.0075
0.0022
0.0020
0.0013
0.0007
2
0.0023
0.0036
0.0023
0.0027
0.0064
0.0118
0.0077
0.0050
0.0109
0.0128
0.0196
0.0077
0.0073
0.0027
0.0082
0.0046
3
0.0036
0.0023
0.0018
0.0046
0.0018
0.0009
0.0014
0.0014
0.0032
0.0032
0.0109
0.0041
0.0087
0.0073
0.0055
0.0014
4
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
5
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
6
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0

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                 APPENDIX.B .
  Indiana Air Pollution Control Law
     Chapter 171, Acts of 1961, as amended
           Indiana  General Assembly
Air Pollution Control Board of the State of Indiana
           1330 West Michigan Street
               Indianapolis 46206

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        INDIANA AIR  POLLUTION CONTROL  LAW

   Chapter 171, Acts of 1961 as amended by Chapter 357, Acts of 1969
Be it enacted by the General Assembly of the State of Indiana:

   SECTION 1. It is the intent and purpose of this act to maintain the
purity of the air resource of the State, which shall be consistent with pro-
tection of the public health and welfare and the public enjoyment thereof,
physical property and other resources, flora and fauna, maximum employ-
ment and full industrial development of the State.  The Control  Board
shall safeguard the air resource through the prevention, abatement  and
control of air pollution by all practical and economically feasible methods.
   It is declared that local and air quality basin control programs  are to
be supported to the extent practicable  as  essential instruments for the
securing and maintenance of appropriate levels of air quality.
   It is further declared that this can be done most effectively by  focus-
ing on goals to be achieved by a  maximum  of cooperation  among all
parties concerned and that codes, rules and regulations established under
the provisions  of this act should  be  clearly  premised upon scientific
knowledge of causes as well as of effects.
   The  State Board of Health shall provide assistance on air pollution
matters to towns, cities and counties.  (As amended by Chapter 357, Acts
of 1969.)

   SEC. 2.  The following tenns as used  in this Act shall,  unless  the
context  otherwise requires, have the following  meanings:
   (a)  "Control Board" is the Air  Pollution Control Board  of the State
of Indiana.
   (b)  "Person" is any   individual,  partnership, co-partnership, firm,
company, corporation,  association,  joint  stock company, trust, estate,
municipality, or any other legal entity, or their legal representative,
agent or assigns.
   (c)  "Air Pollution" is presence  in the outdoor atmosphere of one or
more air contaminants in  sufficient quantities and of such characteristics
and duration as to be injurious to human,  plant or animal life or to
property, or which unreasonably interfere with the comfortable enjoyment
of life and property.
   (d)  "Air Contaminant" is dust, fumes, gas, mist, smoke, or vapor, or
any combination thereof.
   (e)  "Air Contaminant  Source" is any and all sources of  emission of
air contaminants, whether privately  or publicly owned or operated.  With-
out limiting the generality of the foregoing, this term includes all types
of business, commercial and industrial plants, works, shops and stores, and
heating and power plants  and stations,  buildings and  other structures of

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all types, including  single and multiple family residences, apartments,
houses, office buildings, public buildings, hotels, restaurants, schools, hos-
pitals, churches and  other  institutional buildings, automobiles,  trucks,
tractors, buses and other motor vehicles, garages and vending and service
locations and stations, railroad locomotives, ships, boats and other water-
borne craft, portable fuel-burning equipment,  incinerators  of all  types,
indoor and  outdoor, refuse  dumps and  piles,  and all stack  and other
chimney outlets from any of the foregoing.

   SEC.  3.  There is hereby created an administrative board to be known
as the Air Pollution Control Board of the State of Indiana.
   The powers and duties of the Air Pollution Control Board shall be
vested in a seven (7)  member board. The Secretary of the Indiana State
Board of Health shall serve as an ex-officio member of said Board. The
remaining six (6)  members  shall be  appointed  by  the  Governor, one (1)
of whom shall be a physician who holds an unlimited  license to practice
medicine in the  State of Indiana, one  (1) shall be a  qualified graduate
engineer  registered in Indiana, one (1) representing agriculture, one (1)
representing industry, one (1) representing municipal government  and
one (1) representing  the general public. The appointed members' terms
of office shall be four years except that the terms of those first appointed
shall expire as follows:

   one at the end of one year after date of appointment,
   one at the end of two years after date of appointment,
   two at the end of three years after date of appointment,
   and

   two at the end of  four years after the date of  appointment as  desig-
nated by the  Governor at the time of appointment.  The  terms  of  all
members shall continue until their respective successors have been duly
appointed and qualified.  If  a vacancy occurs in the appointed member-
ship, the Governor shall appoint a member for the remaining portion of
the unexpired term created  by the vacancy.  The Governor may remove
any appointed member for cause. The ex-officio member of the Control
Board shall serve without additional compensation. Other members of
the Control Board shall be paid mileage and a per  diem of fifteen dollars
($15.00) for each and every day, or part of a day, in actual attendance at
any meeting or hearing of the Control Board, which per diem and mileage
shall be valid claims against the  Division of Health and Preventive Medi-
cine of the State Department of Health (also known as the State  Board
of Health).
   The Control Board shall  hold  at least two (2)  regular meetings each
calendar  year at a place and time to be fixed by the Board. The Control
Board shall select at its first meeting following the passage of this Act,
one of its members to serve as chairman  and another  of its members to
serve as vice-chairman.  At the first regular meeting in each calendar
year  thereafter, the chairman and vice-chairman for  the ensuing year
shall be elected.  The Secretary of the State Board of Health shall appoint

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from the staff of the State Board of Health a qualified sanitary engineer
registered in Indiana as technical  secretary of the Control Board.  He
shall receive no additional compensation for such services and during the
interim between meetings of the Control Board he shall handle such cor-
respondence, make  or  arrange for  such investigations  and surveys and
obtain, assemble or prepare such reports  and data as the Control Board
may direct and authorize.  Special meetings may be called by the chair-
man or by two (2)  members of the Control Board by delivery of written
notice  at the office of each member  of  the  Control  Board.  Four  (4)
members of the Control Board shall constitute a quorum.

   SEC.  4.  (A)  Powers and Duties of the Air  Pollution Control Board.
   The duty and power to administer and  carry out  the adjudicatory
provisions of  this  Act hereinafter set forth in this Section is hereby
vested in the Air  Pollution Control Board  and  such  Board is hereby
empowered to:
   (1) Make investigations, consider complaints and hold hearings.

   (2) Enter such  order or determination as may be necessary to effectu-
ate the purposes of this Act.  If the Control Board shall find  that  the
condition  of air  pollution  exists,  as that term  is denned herein, such
order may  require the taking  of  such  action as  is  indicated by  the
circumstances to cause  the  abatement of  such condition.
   In making its orders and determinations hereunder, the Control Board
shall take into consideration all the  facts and circumstances bearing upon
the reasonableness of the emissions  involved including, but not limited to:
       (a)  The character and degree of injury  to, or interference with,
comfort,  safety, health, or the reasonable use and enjoyment of property;
       (b)  The  social  and  economic  value of the activity causing  the
emissions; and
      (c) The practicability, both scientific and economic, of reducing or
eliminating  the emissions resulting from  such  activity.
   The order or determination of the Control Board  may include such
advisory  recommendation as the Control Board may deem appropriate for
the control of  emissions  from  any  air  contaminant source  and  the
reduction of the emission of air contaminants.
   (3) Adopt  and promulgate reasonable rules and  regulations  con-
sistent with the general intent and  purposes of this Act declared in Sec-
tion  1  hereof and necessary to carry out  the provisions and  purposes of
this  Act.  All rules and regulations  shall be adopted  and promulgated
in accordance with the provisions of the statutes of this State concerning
the establishment and promulgation of rules and regulations.  .
   (4)  Bring appropriate action to enforce its final orders or determi-
nations under the Indiana Administrative  Adjudication and Court Review
Act.  Such action shall be brought in the name of The Air Pollution
Control Board of the State of Indiana.

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   (B)  Powers and Duties of the State Board of Health.
   The  duty and power to assist and cooperate with other groups inter-
ested in and affected by air pollution rs hereby vested in the  State Board
of Health and such Board is hereby empowered to:
      (1)  Advise, consult and cooperate with  other agencies  of  the
State, towns, cities, and counties, industries, other states and the federal
government, and with  affected groups  in the prevention and control of
new and existing air contamination sources within the State.
      (2)   Encourage  and conduct studies, investigations and research
relating to  air pollution and its  causes, effects, prevention,  control  and
abatement.
      (3)  Collect and  disseminate information relating to air pollution,
its prevention and control.
      (4)  Encourage voluntary cooperation by persons, towns, cities  and
counties or other affected groups in restoring and preserving a reasonable
degree of purity of air within this State.
      (5)  Encourage authorized air  pollution agencies of towns, cities
and  counties to  handle  air pollution  problems within  their respective
jurisdictions to the greatest extent possible.
      (6)  Provide  technical  assistance  to   towns, cities   or  counties
requesting same  for the furtherance  of air pollution control.
      (7)  Represent the State of Indiana in any and all matters pertain-
ing  to  plans,  procedures,  or  negotiations  for interstate  compacts in
relation to the control of air pollution.
      (8)   Accept and administer grants or other funds or gifts for the
purpose of carrying out any of the functions of this Act.
      (9)  Enter  at  all reasonable  times in or  upon  any  private or
public property except  private residences for the purpose of inspecting
and  investigating conditions relating  to the pollution of  the air of  this
State.
      (10)  Investigate complaints received  by it or referred  to it by
the Control  Board, make such reports  to the Control Board of its investi-
gations  as it deems advisable and participate, on  behalf of this  State, in
proceedings  or public hearings before  the Control  Board.
      (11)  The  State   Board  of  Health is  authorized to  budget  and
receive  duly  appropriated  monies  for expenditures to  carry out  the
provisions and purposes of this Act.

   SEC. 4a. The  Control Board  shall adopt  and  promulgate rules  and
regulations  which shall create air quality basins based  upon  scientific
study of geographical, topographical, meteorological data, and shall adopt
and  promulgate  standards for ambient air  quality for each basin to
effectuate the purposes of this Act.  (As amended by Chapter 357, Acts
of 1969.)

   SEC. 4b. (a)  As the state of knowledge and  technology  relating to
the control of emissions from motor vehicles may permit or make appro-

-------
priate, and in furtherance of the purposes of this Act, the Control Board
may provide by rules and regulations for the control of emissions from
motor vehicles provided that the Control  Board shall, prior to the estab-
lishment of  such rules and regulations pertaining to the  control of
emissions from motor vehicles, forward to each member of the Indiana
General Assembly a copy  of such proposed rules and regulations.  Such
rules and regulations may prescribe requirements for the installation and
use of equipment designed to reduce or eliminate emissions and  for the
proper maintenance of such equipment  and  of vehicles. Any rules or
regulations pursuant to this section shall  be consistent with provisions of
federal law, relating to control of emissions from the vehicles concerned.
The Control Board  shall not  require, as a condition  precedent to the
initial sale of a vehicle or vehicular equipment, the  inspection, certifica-
tion or  other approval of any feature or equipment,  designed for the
control of emissions from motor vehicles, if  such feature or equipment
has been certified, approved  or otherwise authorized pursuant to federal
law.
      (b)  Except as permitted or authorized  by law, no person shall fail
to maintain  in good  working  order or remove, dismantle or otherwise
cause to be  inoperative any air pollution control system or mechanism
which  is used  solely to  control air  pollution of a motor vehicle and
required  by  rules or regulations of the Control Board to be maintained in
or on the vehicle. Any such failure to maintain in  good working  order
or  removal,  dismantling  or causing  of  inoperability  shall  subject the
owner or operator  to suspension or cancellation of  the  registration for
the vehicle by the Commissioner of the Bureau of  Motor Vehicles. The
vehicle shall not  thereafter be eligible for registration until the emission
control equipment of the  motor vehicle  has  been restored,  replaced or
repaired  and is in good working order.
      (c)  The  remedies  and  penalties  provided in this  section  shall
apply to  violations hereof, and no provision of Section  7 (b)  of this Act
shall apply thereto.
      (d)   As used in  this section "motor vehicles" shall mean "vehicle
subject to inspection" as defined by Section  2, Subsection (e), Acts of
1967,  Chapter 317.  (As amended by Chapter 357, Acts  of 1969.)

    SEC.  5.  The  discharge into the outdoor atmosphere of air contami-
nants so  as to cause air pollution and create a  public  nuisance is contrary
to the public policy of the State of Indiana and the provisions  of this Act.
    Air pollution  may at certain times and places so seriously affect the
public health and so threaten the  population as to warrant  emergency
powers to prevent or minimize disasters of unforeseen proportions. If the
technical secretary of the Control Board, in consultation with the Secre-
tary of the  State Board of Health of Indiana, determines that air pollu-
tion in any  area constitutes  an unreasonable  and emergency risk to the
health and safety of those in the area, such determination shall be imme-
diately communicated to the Governor. The Governor may, by proclama-
tion, declare that an emergency exists and order all persons  causing or

                                  6

-------
contributing to the air pollution to reduce or discontinue immediately the
emission of air contaminants.  Not  more  than 24 hours thereafter the
Attorney General of the State of Indiana, at the request of the Governor,
shall initiate injunctive proceedings  in the appropriate court against the
person or persons causing or contributing to the air pollution to stop the
emission of contaminants causing such  pollution  or to take such other
action as may be necessary. If such  action is not commenced •within such
24-hour period, the  Governor's  proclamation shall become void.   (As
amended by Chapter 357, Acts of 1969.)

   SEC. 6.  The Air Pollution Control Board  may  hold a  hearing  with
respect  to any suspected violation of the provisions of this Act.
   (1)  upon its own motion,
   (2)  upon complaint filed with the Board by any person, and
   (3)  upon complaint filed with the Board by the appropriate officer of
any town, city or county or of the State Board of Health.
   Notice of hearing, the conduct of such hearing and  appeal from any
order or decision of the Control Board  shall be in accordance with the
provisions of the Indiana Administrative Adjudication and Court Review
Act, as amended.

   SEC. 7.  (a) It  shall be unlawful to  refuse to comply with any rule,
regulation or order of the Control  Board, or  to  in any manner  hinder,
obstruct,  delay, resist, prevent or in any way interfere or attempt to
interfere with  the Control Board of the State Board of Health, and its
personnel in the performance of  any duty  hereunder, or refuse to permit
such personnel to  perform their duty  by refusing them,  after  proper
identification  or presentation  of written  order of  the Control  Board,
entrance at reasonable hours to any premises.
      (b)  Any person who violates any provision  of this Act  or any
such regulation or  order of the Control  Board shall be  deemed guilty of
a misdemeanor and may be punished by a fine of  not to exceed five hun-
dred dollars ($500) per act of  violation.  Each day that the court may
find  the defendant in violation  of the Act shall  be a  separate offense.
(As amended by Chapter 357, Acts of 1969.)

   SEC. 8. (a) Nothing within this Act shall prevent towns, cities or
counties from enforcing local air pollution ordinances consistent with the
provisions of this  Act, or from enacting or enforcing more restrictive
ordinances to further the expressed purposes of this Act.
      (b)  For the maintenance of the quality of  the air resource, the
board of commissioners of any county may enact  and enforce ordinances
controlling air pollution. Such ordinances  shall not include municipalities
with an air pollution ordinance  pursuant to the  provisions of this  Act.
      (c)  Any town, city or county within  an  air quality basin may
administer its  air pollution control program in cooperation with one (1)
or  more  town, city or county  of  this State, in  accordance  with the
provisions of the Interlocal Cooperation Act.

-------
      (d)  Each  air  pollution control agency shall  submit such annual
reports as may be requested by the Control Board.
      (e)  When an  air quality jurisdiction, or administrator thereof,
fails to enforce the local ordinance which affords protection to the public
equal to that provided by state law, the Control Board, after consultation
with that jurisdiction or administrator, may take such appropriate action
as may be necessary to enforce applicable provisions of state law. (As
amended by Chapter  357, Acts of 1969).

   SEC.  9.  If any section, subsection, sentence, clause, phrase, or word
of this Act is  for any reason held to be unconstitutional, such determina-
tion  shall not affect  the validity of any of the remaining  portions  of
this  Act.

   SEC.  10.  This Act shall  be in  full force  and effect  on or  after
January 1, 1963.

   NOTE:  Since  Chapter  357,  Acts of  1969,  contains  an emergency
           clause, it shall be in full force and effect on or after  March
           15, 1969.

-------
                                APPENDIX C
                     REGIONAL ORGANIZATIONAL STRUCTURE
PURPOSE OF REGIONAL EXAMINATION
       An effective air pollution control program must be based on a complete
technical evaluation of the conditions in the control area.  This evaluation
is necessary but not in itself sufficient.  The question of political control
and administration of the control agency among and within the various juris-
dictions is also vital to the development of a functioning program.
      Two closely related problems had to be resolved for this Implementation
Plan with regard to the acceptability on a political level of its recommen-
dations for an air pollution control regional organization:
      1.  The MCIAQCR overlaps three states; Ohio, Kentucky, and Indiana,
          with a total of nine counties in the three states.  Instead of
          one authority which could impose an implementation plan on subor-
          dinate political subdivisions, this study dealt with three
          independent sovereign states.  Agreement to cooperate had to be
          obtained, with no single authority that could force consent.
      2.  Each part of the MCIAQCR is located in two distinct areas, its
          state and the region.  NAPCA understandably is looking primarily
          toward a regional plan, because MCIAQCR is one airshed.  Each
          state, however, looks upon its portion of the region as simply
          a part of the state.  Each state board has state-wide responsi-
          bility for air quality.  The two, three, or four counties of the
          state which happen to be located in the region are no different,
          in the eyes of each state board, than any other counties in the
          state.
      These basic problems had been anticipated in the development of the
Plan.   A methodology was developed by which various organizational alterna-
tives  could be tested (Section 3.3).  This procedure was carried out to insure
that completed Implementation Plans would be both technically and politically
feasible.
ORGANIZATIONAL ALTERNATIVES
      Four organizational alternatives were considered in performing the
political acceptability analysis:

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      1.  Interstate Compact.  All control agency functions would be
          delegated by the states with Federal approval to a central
          interstate agency.
      2.  Interstate Agreement.  All of the program except legal enforcement,
          which would be retained by the states, would be handled by an
          interstate agency.  This organization avoids the need for Congres-
          sional approval of a compact.
      3.  Intrastate Enforcement with a Central Cooperating Mechanism.
          Basic control authority and operations are retained at the state
          level.
      4.  County Enforcement with a Central Cooperating Mechanism.
      Each of the above, except the compact, provided a number of suboptions
which had to be considered.  A description of these .four basic plans, in-
cluding legal considerations and the organization's  function in the control
of emergency episodes was prepared.
      These four alternatives were selected to represent possible methods
of controlling and administering an air pollution control program in the
MCIAQCR.  The following analytic effort was undertaken to determine which
of these alternatives would be most appropriate in terms of citizen and
political acceptance within the Region.
ANALYSIS
      In order to determine which of the above alternatives would best
meet the needs of the MCIAQCR, it was necessary to present them to a cross-
section of area citizens and leaders.  A seminar technique was utilized
for this purpose since a full explanation of the various organizations could
be presented.  The seminar also provided a forum for discussion and comments
regarding the various alternatives.  A seminar was scheduled for each of the
three states and a group consisting of members of the state legislature, the
state air pollution control board, city officials, and concerned citizens
was invited to attend.  The seminar plan provided for a morning session in
which the alternatives, including their legal Implications and plans for
emergency episode control were explained.  Following lunch, the study team
answered questions from the participants and generally noted the reactions
to the proposals, and thus got a feedback as to what was considered to be
the most acceptable organizational alternative.

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      The Ohio Seminar was held on April 3, 1970 at the Holiday Inn,
Downtown, Cincinnati and although attendance was somewhat below expectations,
the meeting was considered to be a success.  The participants did react and
did provide the staff with clear ideas concerning their views on what was
acceptable.  To verify whether or not this reaction represented also the
feeling of concerned legislative leaders, one staff member met separately
with selected legislators.
      The substance of the Ohio reaction was that Ohio's agreement to an
interstate compact was contingent upon agreement by the other states.  The
general consensus was that a plan for intrastate enforcement by the state
board would be preferred.
      The next seminar,  scheduled for April 17, 1970 in Indiana, had a
substantially larger guest list than that for Ohio.  However, in spite of
this larger list of invitees, practically no reservations were received
even in response to telephone followup.  The meeting was therefore canceled.
The reasons appeared to be most important:  (1)  a conflict of dates with
another meeting, and (2) indifference to the interstate aspects of air
pollution control.  Only two small Indiana counties are included in the
MCIAQCR, with a total population of 30,000.  Other Indiana and Kentucky
counties contiguous to these counties are essentially rural, with no serious
pollution problems.  Furthermore, the state board had been reasonably active
for some time, and apparently was thought to be equal to the task.
      The Kentucky meeting, April 24, 1970 at the Holiday Inn in Covington,
produced a turnout of 50, plus staff.  This turnout resulted from several
causes:  (1) a high level of interest in pollution control, (2) an expanded
list of invitees; and (3) inclusion of Indiana residents who had been
interested in a meeting, but had not been able to attend when originally
scheduled.
      The same format was followed as at the Ohio meeting, but with a
larger audience, greater participation resulted.  The message was un-
mistakable.  Kentucky was proud of its control program, and wanted no part
of a compact or any other device that might dilute the authority and
responsibility of the State Board.  The audience was virtually unanimous in
insisting on a state program (alternative 3), with a willingness to cooperate
with other states provided this cooperation did not dilute state responsibility.
The Indiana citizens shared the Kentucky viewpoint.

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      The basic objective of this phase of the analysis was thus satisfied
with the identification of intrastate control programs with some interstate
cooperation as the desired organizational form.
      Nevertheless, the two meetings had come to grips only with the basic
plan.  Assuming control by the state boards in their receptive areas, two
questions remained:
      1. To what extent, and in what areas, would there be coopera-
         tion among the states?
      2. Through what mechanism would this cooperation be exercised?
      To resolve these problems, a third meeting was called, this time
limited to representatives of the three state boards, the City of Cincinnati,
one concerned legislator, and representatives of the Ohio-Kentucky-Indiana
Regional Planning Authority, the recognized planning agency for the nine
counties of the MCIAQCR.
      The various representatives quickly agreed that cooperation was
necessary.  They pointed out that for many months, they had cooperated through
an ad hoc device known as the Air Pollution Control Officers Committee.
      They also agreed that, to the extent interstate planning would be needed
after implementation, this would require an interstate mechanism.
      As a group, the meeting failed to define any role for the OKI Regional
Planning Authority.  This perhaps came about because of the existence of one
well-established agency, the City of Cincinnati, in the heart of the region.
The City, as will be described more fully in sections 5 and 8 of this report,
is recommended as the agent of the State of Ohio under contract for air
quality control in the four Ohio counties.  It has expertise.  It also has
a powerful data processing unit, with ample  capacity  to serve  as the regional
data bank.  The consensus was that the City of Cincinnati agency is a more
logical data bank, so that this data can be most useful particularly in
emergency episode control.

 ORGANIZATIONAL RECOMMENDATIONS
      The seminars indicated which of the various organizational alternatives
would be politically viable in the MCIAQCR.  Based on the procedure described

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above, the following general recommendations are presented.  ( Sections
3, 6,  7, describe in some detail how these recommendations are to be imple-
mented. )
      1. Responsibility for air quality control in the MCIAQCR should be
         lodged in the respective state boards.
      2. The Ohio and Kentucky boards should establish district offices
         within the region, with appropriate staff.  Indiana should
         continue to operate from its present headquarters in Indianapolis.
      3. Ohio can best develop a capability by contracting with the City
         of Cincinnati and other municipal air pollution control agencies
         to service the four Ohio counties.
      4. Coordination of efforts among the three states should be
         achieved as follows:
            a. The City of Cincinnati, as part of its contract with
               the Ohio Board, should assume responsibility for
               maintaining a regional data bank.
            b. The existing Air Pollution Control Officers Commit-
               tee should continue its existence as a cooperation
               mechanism.
            c. This Committee should establish its meeting place
               in the offices of the OKI Planning Authority.  The
               staff of the Planning Authority should be used for
               staff to the Committee when necessary.  Whenever
               interstate planning or any other unforeseen studies
               are necessary, the staff of the Planning Authority
               should be used.
            d. While responsibility for air pollution control
               rests with the three respective boards, the OKI
               Regional Planning Authority board is the only
               existing mechanism for bringing together the
               elected officers of the counties comprising MCIAQCR.
               As such, this board could be used as necessary by
               the state boards as a means of determining local
               attitudes.
      5. Financing of air quality control is a matter for each state
         board.

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EPISODE ORGANIZATION
       The Air Pollution Control Officers Committee will have overall
responsibility for promoting interstate planning for air pollution
episodes.   Because the Committee will have numerous, diverse responsi-
bilities,  a separate, subordinate organization is expressly recommended
for episode planning purposes.   This organization will be called the
Region Episode Board.  The Board will be comprised of one member from
each state in the MCIAQCR.  It  is possible that members of the Committee
may serve as members of the Episode Board.  Alternatively, a member
from the state agency expressly responsible for state episode planning
may be a superior candidate for the Board position.
       The Board will have planning and operating responsibilities.  During
the first few years, the Board  will be responsible for developing episode
avoidance procedures for the Region.  Such procedures are briefly outlined
in Section 5 of this report.  The board will also assume limited responsi-
bilities for actions during episodes.  The actions will be in the form of
recommendations to each state at the more severe stage of an episode
(i.e., actions which have interstate consequences such as restrictions
on automobile travel or shutdown of commercial business activity).
        The Board will routinely (e.g., bi-monthly) neet to perform the
necessary planning functions.  During episodes, the Board will conduct
emergency meetings when the Alert stage is reached.
       The Board will meet in the office  of the OKI Planning Authority
for routine meetings.   Meetings during episodes will be held at the
office of the City of Cincinnati air pollution agency or , when developed,
the Ohio District Office for the MCIAQCR.
       Staff members from the three states will be used to coordinate and
conduct background studies for  the purpose of developing an Emergency
Episode Plan.  When possible, members of the OKI staff will also parti-
cipate.
       See Section 5.1.1 for further discussion on the MCIAQCR Episode
Organization.

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      One regional Emergency Operations Control Center (EOCC)  will serve
the MCIAQCR.  The required facilities will be located in the City offices
in downtown Cincinnati, Ohio.

        The routine operation of the EOCC will be  conducted  by the
 City of Cincinnati staff.   During non-episode periods,  such operations
 are minimal.   The routine watch of air quality and meteorological
 conditions will be a part-time responsibility of  one of the professional
 staff.   Under normal conditions there will be no  extensive  distribution
 of air  quality or meteorlogical data to any of the  state  organizations.
        The presently active Air Pollution Control Officers  Committee
 will have overall responsibility for promoting interstate planning for
 air pollution episodes.   The Committee will have  planning responsibilities
 during  non-episode periods and will participate in decision-making
 operations during episodes.  During an 18 month period  after  the submission
 of the  Implementation Plan, the Committee will be responsible for
 developing episode alert procedures for the Region.  Such procedures
 are briefly outlined in Section 5 of this report.  The  Committee
 will routinely meet to perform the necessary planning functions.  Such
 meetings will be held at the EOCC.
        The manner in which the members of the Committee organize
 during  episodes is dependent upon the size of the geographical
 area affected by the episode.   There are essentially two distinct
 cases;   localized episodes and regionwide episodes.  Under  both
 situations, all surveillance information will be  received and
 evaluated by the MCIAQCR EOCC.  In the case of a  localized  episode
 (i.e.,  an episode which  affects a part of one state), the control
 officers will communicate via telephone; but episode actions will
 be taken only by the control official in the state affected.   When
 a regionwide episode occurs, the members of the Committee will meet
 at the  MCIAQCR EOCC to plan unified actions.
      The episode organization for the MCIAQCR will operate  effectively
 because of uniformity of episode criteria and control actions by the
 states.  The combined air quality monitoring networks of the  three
 states  involved will effectively serve the EOCC.

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     Staffing and funding the EOCC by the three states is a consideration
that will be resolved by the Air Pollution Control Officers Committee.
Naturally, each state will contribute agency personnel to help run the
EOCC during episodes.  The size of the staff and procedures followed will
be determined by the Committee and published in the Standing Operating
Procedures for the EOCC.

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EXISTING INTERSTATE COOPERATION
     Representatives of the governmental jurisdictions encompassed by
the MCIAQCR are acutely aware of the necessity for a coordinated program
to control air pollution in the Region.  Following the designation of the
Metropolitan Cincinnati Interstate Air Quality Control Region, an Air
Pollution Control Officers Committee was formed for the Region.  Following
are excerpts from the document which established the Metropolitan
Cincinnati Interstate Air Quality Control Region Air Pollution Control
Officers Committee.
     .  . . This document, concurred in by representatives of the
     air pollution control agencies of the States of Ohio and Indiana,
     the Commonwealth of Kentucky, and the City of Cincinnati, Ohio,
     is designated to set forth basic policies of interjurisdictional
     cooperation in the area designated by the Secretary of Health,
     Education and Welfare as the Metropolitan Cincinnati Air Quality
     Control Region (hereinafter referred to as the "Region").  The
     purpose of this document is to establish a flexible mechanism
     whereby the control officers within the Region can readily exchange
     information and data of common interest, and coordinate, insofar
     as possible, each other's control programs so as to achieve
     optimum utilization of data and avoid unnecessary expense and
     duplication of effort.  This document is intended to set forth
     an informal arrangement by and between the control officers of
     the aforesaid agencies, and the policies expressed herein should
     not be construed to be official policy of any of  the control
     agencies represented.
                             Policies and Procedures
     I.  Name:   The organization shall be known as the Metropolitan
     Cincinnati Interstate Air Quality Control Region - Air Pollution
     Control Officers Committee (hereinafter referred to as the
     "Committee").
     II. Membership: Representatives of the following governmental air
     pollution control agencies shall be members of the Committee:
                 The State of Ohio
                 The State of Indiana
                 The Commonwealth of Kentucky

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            The City of Cincinnati, Ohio

III.  Designated Representatives:  For purposes of giving notice,
meetings, exchanging data and other pertinent information, etc.,
the following are designated as the Representatives for each respective
control agency:

The State of Ohio -
The State of Indiana -
The Commonwealth of Kentucky -
The City of Cincinnati, Ohio -

IV.  Federal Representation:  Due to the impact of the Air Quality
Act on the control efforts of the various agencies having jurisdiction
within the Region, and the desire of the representative control officers
to be informed of federal activities and available technical assistance
which may inure to each other's benefit, it is felt that federal
representation on the Committee would be appropriate and advantageous.
Therefore, it is mutually agreed that an official of the National Air
Pollution Control Administration shall be invited to attend and
participate in all activities of the Committee, such official's
name upon designation to be appended to this document.
V.   Organization, Meetings, Minutes:
    A.  Organization - The organizational conduct of the Committee
    meetings shall be as informal as possible.  The Committee shall
    have no permanent chairman or secretary, but shall, at the
    discretion of the members, delegate such responsibilities and
    duties in an equitable manner.
    B.  Meetings - It is felt that the purposes of the Committee


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         can, for the most part, be achieved by routine correspondence
         and telephone communications.  Therefore, the Committee shall
         have no regularly scheduled meetings, but shall meet at a
         mutually agreeable time and place on the call of one of the
         members when matters of importance arise.
         C.  Minutes - Minutes of Committee meetings shall be recorded
         and distributed to the members by the person designated as the
         secretary for the meeting.
     VI.   Program Coordination:  The representative control officers
will attempt, insofar as possible, to establish program efforts within
the Region consistent with the following practices and procedures:

         A.  Reference System - Data points shall be keyed to the
         Universal Transverse Mercator System referenced to principal
         coordinates of 39° 12' 30" latitude, and 84° 27' 30" longitude,
         which locate a central point in the Region in the vicinity of
         U. S. Interstate 1-75 and Amity Road, Cincinnati, Ohio.  Graphic
         presentations of data using a grid system shall be consistent with
         Universal Transverse Mercator System, with grid size, depending
         on need, ranging from one to twenty-five square kilometers.
         B.  Air Quality Monitoring - Preferred general practices for
         air quality monitoring shall be determined by the Designated
         Representatives for:
         1.  Equipment
         2.  Sampling Schedules
         3.  Laboratory Procedures
         4.  Data Reporting Factors
         C.  Emission Information - Point source emission data shall,
         insofar, as practicable, be obtained and reported in a consistent
         manner.
     VII.  Exchange of Information: It is the intention of the Committee
members that information and data of common interest should be freely
exchanged between the representative control agencies.  Such exchange shall
be directed to the Designated Representative for each respective control
agency.  Without limiting the scope of exchange, the following matters will
form the basis of interjurisdictional exchange of information and data:

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         A.  Legislative and Administrative:  The representative control
         agencies shall exchange copies of enabling legislation, adopted
         regulations or ordinances, annual reports, and any other pertinent
         information relative to control activities within the Region.
         B.  Proposed Standards - The representative control agencies shall
         forward prior to publication copies of proposed ambient air quality
         and emission standards applicable to any portion of the Region
         for the Committee member's review and comment.  Notice of any
         public hearings held relative to the adoption of said standards
         shall be given the Committee through each control agency's
         Designated Representative.
         C.  Air Quality Monitoring Data - The representative control
         agencies shall exchange summary tabulations of air quality
         monitoring results for each agency's jurisdiction on a periodic
         basis as such summaries become available.
         D.  Source Emission Data - Insofar as consistent with the
         confidentiality requirements of each control agency's enabling
         legislation, specific point source emission information shall
         be available for any Committee member's review in the offices
         of the agency possessing such information.  Mass emission data
         not making specific reference to any particular  plant or
         industry will be freely exchanged between the Committee members
         through the Designated Representatives.
     VIII.  Expression of Intent:  The undersigned hereby witness that
they concur with the aforesaid purposes and objectives, and that they
recognize the desirability and indeed the necessity of coordination of
technical matters in interstate areas of joint interest and concern.   It
is understood that no legal liabilities or other binding committments
are hereby made, but that a positive intent for cooperation in all the
above matters is expressed .

                                        I si Samuel I.  Lord,  Jr.  11/10/69
                                    Kentucky Air Pollution Control Comm.
                                       /s/ A.  C.  Offutt, M.D.  11/25/69
                                    Indiana Air Pollution Control Board

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      /s/ E. W. Arnold, M. D. 12/69

 Ohio Air Pollution Control Board
      /s/ R. L. Krabach   12/69
  City of Cincinnati Air Pollution
                     Control Board

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