EPA-450/2-74-004
APRIL 1974
STATE AIR POLLUTION
IMPLEMENTATION PLAN
PROGRESS REPORT,
JUNE 30 TO DECEMBER 31, 1973
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Air and Water Programs
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
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This report has been reviewed by the Office of Enforcement and General
Counsel and the Office of A1r Quality Planning and Standards of the
Environmental Protection Agency and approved for publication. Approval
does not signify that the contents necessarily reflect the views and
policies of the Environmental Protection Agency, nor does mention of
trade names or commercial products constitute endorsement or recom-
mendation for use.
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EPA-450/2-74-004
STATE AIR POLLUTION
IMPLEMENTATION PLAN
PROGRESS REPORT,
JUNE 30 TO DECEMBER 31, 1973
Prepared by
Office of Air Quality Planning and Standards
Office of Air and Water Programs
U.S. Environmental Protection Agency
Research Triangle Park, North Carolina 27711
and
Office of Enforcement and General Counsel
U.S. Environmental Protection Agency
Washington, O.C.
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Air and Water Programs
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
April 1974
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Document 1s available to the public through the National Technical
Information Service, Springfield, Virginia 22151.
Publication No. EPA-450/2-74-004
11
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FOREWORD
This is the second report depicting the progress States are
making toward the attainment of national standards required by
the Clean Air Act. This report covers the period June 30 to
December 31, 1973, although more current information is noted
when applicable.
The State Implementation Plan program continues to be a dynamic
process as national Issues are translated into effective programs
requiring regulations and resources that State control programs
utilize in meeting the Clean Air mandates.
As more parts of State Implementation Plans become operational,
State and EPA enforcement actions take on added importance to ensure
compliance with approved plans. The discussions that follow attempt
to compare the status noted in the previous report to subsequent
progress made.
B. J. Steigerwald
Deputy Assistant Administrator
for A1r Quality Planning and Standards
Robert Baum
Deputy Assistant Administrator
for General Enforcement
iii
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ACKNOWLEDGMENTS
The preparation of this report resulted from Information
provided by the State and local air pollution control agencies,
EPA Regional Offices, and various EPA headquarters groups.
As with the first report relating to State Implementation
Plan progress, this edition continues to be a joint effort
between the Division of Stationary Source Enforcement, Office
of Enforcement and General Counsel, and the Office of Air
Quality Planning and Standards, Office of Air and Water
Programs.
Information on enforcement activities was provided by the
Division of Stationary Source Enforcement, Office of Enforce-
ment and General Counsel. Additional specific information on
EPA air programs can be obtained by contacting the EPA Regional
Offices.
iv
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CONTENTS
Section Page
LIST OF TABLES vi
ABBREVIATIONS AND SYMBOLS vii
1 EXECUTIVE SUMMARY 1
State Implementation Plans 1
Air Quality and Emission Data 7
Plan Revision Management System 9
Source Compliance Activities '. . 12
State and Local Resources 14
2 NATIONAL ISSUES 17
Implementation of Clean Fuels Policy 17
Maintenance of Standards/Land Use Controls 18
Significant Deterioration 21
Supplementary Control Systems 22
Copper Smelters 23
3 STATE IMPLEMENTATION PLAN PROGRESS 25
EPA Actions . . 25
Extensions 30
Transportation Control Plans 35
4 PLAN REVISION MANAGEMENT SYSTEM 41
Background 41
Operation of the System 41
Action Procedures 42
PRMS Analytical Results 47
5 ENFORCEMENT OF STATE IMPLEMENTATION PLANS 53
Status of Power Plant Compliance 54
Enforcement of SIPs 59
Use of Section 114 66
Use of Section 113 67
6 AIR QUALITY MONITORING AND DATA REPORTING 87
Ambient Air Quality 87
Source Emissions 95
7 STATE AND LOCAL RESOURCES 99
Operating Funds and Types of Assistance 99
Special State Support . 99
Agency Resources Compared to SIP Estimates 104
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LIST OF TABLES
Table Page
2-1 Clean Fuels Policy Action Summary 19
3-1 Summary of A1r Quality Control Region Priority Classification. ... 26
3-2 Status of State Implementation Plans, Summary 28
3-3 Maintenance of A1r Quality Standards, Activity Schedule 29
3-4 Summary Status of State Activity on Indirect Source Plans 31
3-5 Status of State Implementation Plans 32
3-6 Status of Extensions 36
3-7 Summary of Transportation Control Plans 38
4-1 AQCRs Analyzed 1n PRMS 43
4-2 National Ambient A1r Quality Standards for PRMS Analysis 44
5-1 Point Source Compliance Status, Investigations, and
Data System Summary 62
5-2 Summary of EPA Air Enforcement Actions, May 1972-January 1974. ... 69
6-1 Status of CY 72 Monitoring Activity as Reported to NADB by
States, September 1973 . 88
6-2 Suspended Particulate Matter, Status of Air Quality, 1972 92
6-3 Sulfur Dioxide, Status of Air Quality, 1972 92
6-4 0x1 dants, Status of Air Quality, 1972 93
6-5 Carbon Monoxide, Status of A1r Quality, 1972 93
6-6 National Summary of State Monitoring as Reported to NADB
as of January 11, 1974 94
6-7 Air Quality Monitoring Sites, Actual versus Required 95
6-8 Nationwide Emissions, 1972 96
7-1 Special State and Local Support by Type of Assistance, FY 1973 ... 102
7-2 Special State and Local Support by Type of Assistance,
Estimated FY 1974. . 103
7-3 State and Local Agency Estimated Resource Needs, 1975 106
vi
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ABBREVIATIONS AND SYMBOLS
AQCRs Air Quality Control Regions
BOAs Basic Ordering Agreements
CDS Compliance Data System
CFP Clean Fuels Policy
CO Carbon monoxide
CY Calendar year
EPA (U.S.) Environmental Protection Agency
FGD Flue gas desulfurizatlon
FMVECP Federal Motor Vehicle Emissions Control Program
FY Fiscal year
HC Hydrocarbons
NADB National Aerometrlc Data Bank
NEDS National Emissions Data System
NO Oxides of nitrogen
N02 Nitrogen dioxide
OAQPS Office of Air Quality Planning and Standards (EPA)
OEGC Office of Enforcement and General Counsel (EPA)
0 Total oxldants
PRMS Plan Revision Management System
SAROAD Storage and Retrieval of Aerometrlc Data
SCS Supplementary Control Systems
SIPs State Implementation Plans
SO Oxides of sulfur
^\
S02 Sulfur dioxide
TCPs Transportation Control Plans
TSP Total suspended participates
TVA Tennessee Valley Authority
yr year
VII
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STATE AIR POLLUTION
IMPLEMENTATION PLAN
PROGRESS REPORT,
JUNE 30 TO DECEMBER 31, 1973
SECTION 1 - EXECUTIVE SUMMARY
STATE IMPLEMENTATION PLANS (SIPs)
Overview
Since the last SIP progress report, the number of fully approved
SIPs, with no regulatory disapprovals, has dropped from 17 to 16. (These
figures do not reflect the fact that all plans have been disapproved
with respect to maintenance of national standards and significant
deterioration.) The change in the total is the result of two disap-
provals related to compliance schedules and one approval based on
Environmental Protection Agency (EPA) delegation of authority for public
availability of data. Of the 39 plans still having deficiencies, 26
(an Improvement of 15 plans since the last report) have only regulatory
deficiencies, which have been corrected by EPA promulgation, and 13 (an
Improvement of 5) are in the stages of finalization by State or EPA action.
Maintenance of Standards
On June 18, 1973, EPA promulgated regulations requiring each State
to submit by March 18, 1974, a list of areas likely to violate the
national ambient air quality standards for any pollutant in the next
1. State Air Pollution Implementation Plan Progress Report, January 1
to June 30, 1973. U.S. Environmental Protection Agency. Research
Triangle Park, N. C. EPA-450/2-73-005. September 1973.
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10 years. EPA will review these and publish a final list by June 18,
1974, following which the States must submit plans to assure that such
violations do not occur. At present, it appears that the timetable for
these actions will be delayed by approximately two months.
Indirect Sources
The June 18, 1973, promulgation also requires States to set forth
legally enforceable procedures for a source-by-source review of certain
new or modified indirect sources to determine if such construction or
modification will violate any control strategy or will Interfere with
attainment or maintenance of any national ambient air quality standard,
because of emissions due to associated mobile source activities.
Fifteen State plans have been submitted; 21 additional plans are anti-
cipated by mid-1974, and there are 19 States for which there will
probably be no submittal. At present, 17 States lack legal authority
to regulate indirect sources.
For those States that did not submit plan revisions and those
revisions that were not approvable (all States except Florida and Guam),
EPA promulgated regulations for indirect source review on February 25,
1974. These will be withdrawn as approvable State plans are received.
Extensions for Development to Meet Secondary Standards
EPA has granted or provided 18-month extensions for the develop-
ment of control strategies for achieving secondary standards for par-
ti oil ate matter and/or sulfur dioxide in 19 States involving 37 Air
Quality Control Regions (AQCRs). Of the 37, 17 Involve particulate,
11 involve sulfur dioxide, and 9 involve both. Three plans for
sulfur dioxide and six for particulate matter have been submitted by
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the States; none 1s yet approved. Nine plans for sulfur dioxide and
six for particulate matter are under development by EPA.
State submlttals for participate matter and sulfur dioxide were
originally due July 31, 1973. However, the sulfur dioxide plan sub-
mi ttal date was changed on September 14, 1973, due to the promulgation
of a new secondary standard, thus, making the sulfur dioxide plan sub-
mi ttal date January 14, 1974. The particulate matter plan approval/
disapproval date was November 30, 1973. The EPA promulgation date for
sulfur dioxide 1s July 14, 1974, and the EPA promulgation date for
particulate matter was January 31, 1974.
Smelters
EPA 1s proceeding with the promulgation of smelter regulations
for three smelters in Utah, Idaho, and Nevada to attain both primary
and secondary standards for sulfur dioxide which would require use of
available control technology and supplementary control systems where
needed. It is anticipated that the regulations will be finalized in
the spring of 1974. Efforts are continuing to encourage the States
to submit approvable plans (i.e., Arizona, New Mexico, Idaho, Montana,
Utah, and Nevada). However, EPA promulgation will probably be
necessary. States may submit plans after the EPA promulgations so
that EPA regulations could be withdrawn. These actions will satisfy
the requirement for developing a plan for meeting the secondary
sulfur dioxide standard 1n these States. Thirteen smelters in the six
States listed are Involved.
Court Actions on SIPs
Several suits against EPA have had a significant Impact on the
SIP process. In Rhode Island, the court held that "urban place"
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population was not a proper basis for priority classification, and EPA
was required to justify the classification procedures. Further, the
court directed that SIPs must contain procedures for revising the plan
and that EPA must promulgate such procedures if the State refuses to
adopt them. The court held variance mechanisms must be consistent with
the provisions of the Clean Air Act or the Administrator must disapprove
the plan even though existing regulations allow EPA to dissapprove any
individual variance which is not in keeping with the Act. For the same
reasons that the Rhode Island variance procedure must be disapproved,
EPA must disapprove the enforcement authority of the Rhode Island air
pollution director which permits consideration of economic and social
factors and technical feasibility. EPA is to promulgate regulations
limiting considerations of economic and social factors or technical
feasibility in enforcement after the attainment date.
In Massachusetts, the courts allowed EPA to use Information other
than the SIP submittal to evaluate and approve or disapprove the plan.
The court also ruled that the public availability of emission data is
not the State's option and that emission data are not confidential;
therefore, EPA was required to disapprove two sections of the
Massachusetts plan and to promulgate substitute provisions. This has
been done.
In Ohio and Kentucky, the question of reasonableness of plans was
raised in a suit filed by Industrial interests. The courts held that
impossiblity of compliance, technical infeasibility, high cost/benefit
ratios, and resource unavailability should be "considered" by EPA in
approving or disapproving a State plan. It was also held that all
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Interested parties to SIPs must be given a chance by'EPA to comment on
them prior to EPA taking action but specifics and degree of detail were
not spelled out. Justification of approvals of SIPs and environmental
Impact statements were found not necessary.
In Georgia, the Fifth Circuit Court found that SIPs allowing or
directing withholding of emissions Information cannot be approved. The
court voided EPA's actions on the Ohio and Kentucky plan and directed
that the States resubmlt them and that EPA obtain public comment before
taking action. This procedure Is now in progress.
With regard to granting of time for compliance by sources
(variances, etc.) the court declared that np_ deviation from the require-
ments 1n the SIP can be allowed. This conflicts with decisions of
other courts which Indicated that some flexibility was allowable prior'
to the date for attainment of national ambient air quality standards but
that after such date, the procedures of Section 110(f) of the Act are the
only ones allowable. The decision appears unworkable since many State
regulations are effective on the date of adoption and thus variances and
other kinds of schedules are necessary. Therefore, EPA will seek Supreme
Court review of this part of the court decision.
Tall stacks and supplementary control systems can be permitted
only (1) If, and to the extent that, permanent quantitative emission
controls are not achievable or feasible, or (2) 1f such controls are
1n addition to permanent quantitative emission limitations and
"standing alone without the dispersion strategy" are adequate to
achieve the national ambient standards. State legal authority to
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consider costs and technology was struck down as being too broad and
as allowing too much consideration of such factors as opposed to
health factors.
Energy Issue
Although energy has become a major national Issue only in recent
months, EPA started Initiating actions and programs 1n late 1972 to
alleviate energy problems and 1s continuing to seek a long run balance
between energy considerations and the need for environmental protection.
EPA's major actions to date fall Into two broad categories: (1) actions
that reduce the energy Impact of environmental regulations, and (2)
actions that reduce total energy consumption.
In the first category, EPA Instituted Its Clean Fuels Policy In
late 1972. This policy 1s designed to encourage maximum utilization
of low-sulfur fuels in those AQCRs where they are needed to attain
primary air quality standards and to foster changes in State regulations
to allow use of higher sulfur fuels In their areas. In addition, EPA
has a policy of granting temporary variance from regulations concerning
sulfur in oil where low-sulfur oil 1s not available. EPA has also
been cooperating with the Federal Energy Office In permitting switching
from oil to coal in selected power plants where the environmental
Impacts can be minimized. Finally, EPA has recommended to Congress
changes in automotive oxides of nitrogen emissions standards that would
have the effect of Improving fuel economy. These measures aim at
temporarily easing the energy Impacts of environmental programs.
EPA has also prompted a number of environmental programs that
also reduce energy consumption. The most conspicuous programs of this
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type are the transportation control plans, which aim at improving air
quality but, in most cases, also result in reduced fuel consumption.
EPA has also initiated a new motor vehicle fuel economy labeling program
to inform consumers of expected mileage. Over the long run, energy and
environmental policies should have many common objectives.
AIR QUALITY AND EMISSION DATA
Air Quality Overview
Suspended particulates remain a problem, in spite of encouraging
evidence of downward trends. One-hundred-thirty-eight AQCRs reported
at least one station still above a primary standard (24-hour or annual)
in 1972. Thirty-four AQCRs have reported no annual 1972 particulate
data. Primary 24-hour or annual sulfur dioxide standards were exceeded
at one or more locations in only 19 of 162 AQCRs reporting 1972 data.
Data on oxidants and carbon monoxide are quite sparse, but if the
limited results are indicative, substantial problems exist with these
two pollutants. The primary oxidant standard was exceeded in 21 of 38
AQCRs reporting at least one quarter's data. The primary carbon
monoxide standards were exceeded in 42 of 48 AQCRs reporting in 1972.
Adequacy of Air Quality Reporting and Processing
At the conclusion of the fourth quarter of calendar year 1973, data
for the second quarter of CY 1973 reaching the Storage and Retrieval of
Aerometric Data (SAROAD) system represents less than 60 percent of the
total stations reporting in CY 1972. Consequently, an attempt to char-
acterize nationwide air quality status or trends using the incomplete
1973 data presently in hand would be premature and misleading. Four
quarters of 1973 data are expected to be in hand for summarization
in the next SIP progress report.
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Adequacy of A1r Quality Monitoring Networks
i
The number of air sampling stations by pollutant-type reporting
data as required 1n approved SIPs varies from 60 to 200 percent of
requirements. However, when the required reporting stations are
related to the SIP requirement the percentage by pollutant-type varies
from 39 to 84 percent.
Emission Data Reporting and Processing
Emissions data are continually changing due to additions and
corrections (e.g., updated emission factors, discovery of new sources,
new estimates of emissions from a source, installation of control equip-
ment, shutdown and start up of sources). Consequently, trends due to
control activities are characterized as Inconclusive. However, the 1972
data based on the National Emissions Data System (NEDS) show significantly
higher carbon monoxide and lower participate emission from industrial
processes when compared to the 1971 data. NEDS shows more carbon
monoxide for nearly every industrial category. It could be concluded
either that NEDS has not adequately accounted for carbon monoxide con-
trols or that the methodology used in 1971 overestimated the extent of
control. Another possibility, of course, is that sources of carbon
monoxide were Inadvertently missed in earlier inventories.
Industrial process particulate emissions compare favorably from
1971 to 1972, except for the mineral products industry, which 1n 1972
had much lower emissions. As 1n the case of carbon monoxide emis-
sions, the accountability of control measures for this category could
cause this discrepancy.
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PLAN REVISION MANAGEMENT SYSTEM
Overview
The Plan Revision Management System (PRMS) analysis has been ex-
panded from the original 17 AQCRs to 67 AQCRs. In addition, the PRMS
has been expanded from analysis in relationship to annual participate
matter and sulfur dioxide standards to analysis of all current national
ambient air quality standards, except that for nitrogen dioxide.
The Office of Air Quality Planning and Standards provides each
Regional Office with detailed copies of the individual PRMS site reviews
for each monitoring site identified as having a "possible deficiency"
within 60 days of the end of each semiannual reporting period. Data
review actions have been initiated by the Regional Offices to determine
causes of the Identified deficiencies in the first 17 AQCRs within the
PRMS.
Two important facts are germane in considering results of these
actions. First, because the system considers the applicable State and
Federal regulations, transportation control plans, and the Federal
Motor Vehicle Control Program in the development of the projected air
quality trend, an AQCR will not be "flagged" even though the air quality
1s considerably above the applicable air quality standards, so long as
the observed air quality is following the downward trend predicted on
the basis of enforcement of regulations and compliance schedules.
Second, the PRMS analyzes only the air quality data currently contained
in the SAROAD. Therefore, in a number of cases, because of the Incom-
plete Implementation of the quarterly reporting requirements for air
quality data, there may be an 8- to 10-month time lag in the currentness
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of the data. However, as more States begin to implement the reporting
requirements, the system will be able to provide an up-to-date
analysis of any specific AQCR and Its progress toward attainment of
the standards.
Results of Analysis
The current PRMS analysis has identified approximately the same
percentage of possible deficiencies (i.e., an air sampling site where
trends in air quality indicate that NAAQS will not be reached as of
the specified attainment date) in 10 of the original 17 AQCRs as were
identified in the first analysis. Seven AQCRs did not have an In-
creased number of monitoring sites available for review and had the
same or an increased percentage of possible deficiencies.
A review of the other 50 AQCRs analyzed showed adequate progress
being made toward attainment of air quality standards, with the excep-
tion of a few localized problems. The AQCRs that did not follow this
general trend were principally divided into two groups: (1) those
within limited data base and (2) those with Increasing ambient con-
centrations. The AQCRs with a limited data base had fewer than the
minimum number of sites required by the SIP and/or a minimal quantity
of available data from each site.
For particulate matter, 8 of the 67 AQCRs had a limited data base;
for sulfur dioxide, 32 of the 67 AQCRs had a limited data base.
Similarly, 14 of 25 AQCRs that were required to have carbon monoxide
instruments had less than the minimum number of sites required and 18 of
36 AQCRs that were required to have oxldant instruments had less than the
minimum number of sites required reporting sufficient data for analysis.
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Possible deficiencies associated with participate matter were
noted in 51 of the 67 AQCRs analyzed. Some of these deficiencies
appear to be local in nature since the remainder of the AQCR appears
to be progressing as predicted.
Possible deficiencies were associated with carbon monoxide in 13
AQCRs and with oxidant in 8. However, 29 AQCRs have values that are
currently above the national standards for carbon monoxide (although
only 25 of the 67 AQCRs required CO monitors, an additional 4 AQCRs had
data, thus, the 29), and 19 of the 36 AQCRs required to have oxidant
monitors have values above the standard. Again, it should be noted that
almost 50 percent of the AQCRs that were required to have carbon monoxide
and oxidant monitors had less than the minimum number of sites with suffi-
cient data for analysis. Additionally, some AQCRs have a carbon monoxide
Instrument where no current SIP requirement exists and have recorded
values tn excess of the standard.
In general, the PRMS analysis indicates that in most AQCRs
adequate progress appears to be being made for most sites; however,
no relaxation of any of the current ongoing programs should take place.
The possible deficiencies should be reviewed to determine their cause
and possible solution for that area of the AQCR where the deficiency
was noted. The status of sulfur dioxide, carbon monoxide and oxidant
will require additional data to really assess the situation and de-
termine 1f possible deficiencies exist.
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SOURCE COMPLIANCE ACTIVITIES
Overview
During the semiannual period covered by this progress report,
SIP enforcement activity by EPA has progressed from planning and
strategy development to active function. The outputs stemming from
Implementation of previous strategies cover the following areas:
(1) establishment of reasonable compliance schedules for all major
sources, (2) surveillance and Investigation programs to monitor
compliance schedules, (3) utilization of the automated Compliance
Data System for managing compliance data, and (4) EPA enforcement
actions to keep sources 1n compliance or on compliance schedules.
The States and EPA are In the process of completing the develop-
ment of compliance schedules. Progress has been made 1n ensuring com-
pilance by major point sources. As of December 31, 1973, EPA had
Issued notices of violation to some 82 facilities and abatement orders
to 24 of these. In addition, some 930 letters requesting emissions
data, other necessary Information, or, appropriate action have been
sent (Section 114, Clean Air Act). The Agency has made 600 Inspec-
tions and 24 source tests to ascertain the compliance status of
sources. The EPA objective is to have all point sources either in com-
pliance or on an approved compliance schedule by June 30, 1974. However
the present degree of compliance 1s not satisfactory to EPA. This Is
primarily due to the Inability of States and EPA to quickly focus
massive efforts Into plan enforcement.
Approximately 20,000 point sources are required to comply with SIP
emission standards. Of roughly 12,000 point sources Investigated by
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States and EPA, 7600 are In compliance, 1200 are on approved compliance
schedules and 1900 are not yet on schedule. Schedules for the 1600
remaining sources have been submitted by States to EPA and are being
reviewed for approval.
It should be noted that the compliance status of sources in many
facilities has not been verified by actual inspection or other investi-
gations. Thus, EPA, in cooperation with the States, is initiating a
major effort in compliance monitoring to specifically determine the
compliance status of sources.
Compliance Schedule Tracking
The Office of Enforcement and General Counsel has developed, and
has had in operation since June 1973, a computer system known as the
Compliance Data System (CDS). The CDS is an enforcement management
system designed to track compliance schedule status. At present, CDS
1s both expanding and refining the basic inventory of source and com-
pliance Information while evolving to provide faster and more versatile
reporting capabilities.
The CDS master file, which 1s maintained with regular weekly
updates by the Regions through computer terminals, Included, as of
January 23, 1974. about 7800 facilities with almost 27,400 related
compliance schedule records of emissions point/pollutant combinations.
To some extent, the degree of completeness of the master file reflects
the amount of effort being devoted to system implementation in each
Region.
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STATE AND LOCAL RESOURCES
Baste Ordering Agreement Assistance
Contractual type assistance has aided the States Cup to and In-
cluding fiscal year 1973) 1n the preparation of SIPs and transportation
control strategies, the collection of air monitoring and emission data
i
for use In control strategy development, and the preparation of com-
pliance schedules. In FY 1974, this support has been expanded to
Include assistance In SIP revisions and Implementation, Indirect
source and 10-year maintenance studies, and significant deterioration
plans. Candidate projects from the Regional Offices for FY 1974
totaled $9,781,000. Sixty-seven of these projects are being funded,
for an expenditure of $2,684,000.
State Assignee Program
Since July 1, 1970, when the first persons were assigned, 275
State assignees have participated in the program. As of January 1974,
there were 101 assignees on board, 98 assignees had converted to State
or local control programs, 16 assignees had converted to Federal
programs, and 60 assignees had resigned from the program.
Overall State and Local Manpower and Funds
Revised estimates (as of December 1973) received from the Regions
Indicate that by the end of FY 1975 approximately 9500 man-years and
$189 million will be required to accomplish the SIPs and revisions to
the SIPs. The Increase 1n resource needs 1s attributed primarily to
transportation control plans and to plan revisions due to significant
deterioration and maintenance of standards and Indirect source review.
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These estimates exceed the Initial SIP estimated 1975 manpower require-
ments by 900 man-years and $45 million. The current resource requirements
exceed the 1973 man-years and funding levels by 3800 man-years and
approximately $75 million. EPA 1s currently reassessing the level of
resource needs 1n non-Federal air pollution control agencies In light
of the requirements mentioned above. Data collected from selected
agencies are being analyzed and will be extrapolated to comprise nation-
wide estimates. The Information will be available in late spring
1974.
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SECTION 2
NATIONAL ISSUES
IMPLEMENTATION OF CLEAN FUELS POLICY
In 1972, EPA completed an analysis that showed that the projected
supplies of low-sulfur fuel and sulfur dioxide emission control equip-
ment would be inadequate to meet the aggregated requirements placed
upon stationary combustion sources by the sulfur emission limitations
of the SIPs. These supply shortfalls would be most severe in the 20
States comprising EPA Regions III, IV, and V, where over 60 percent of
the nation's combustion coal is consumed in electric power plants.
The EPA analysis showed that a substantial increase in acceptable
coal supplies would be realized if the sulfur emission limits were
revised upward where it could be shown by air quality modeling that the
1975 primary air quality standards would still be met. The Clean Fuels
Policy (CFP), to encourage the optimum utilization of the limited
supplies of low-sulfur fuels, was announced by EPA in November of 1972.
Under this policy, the States were encouraged to revise their emission
regulations to permit the continued burning of fuels from established
sources provided the primary air quality standard would not be violated
at least until attainment of primary standards was assured. This action
would reduce the demand for low-sulfur fuels and control equipment in
some locations, thereby increasing their availability in other areas
where severe environmental problems required their use.
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Current estimates by EPA project a requirement for 540 million tons
of combustion coal In 1975, of which approximately 115 million tons 1s
considered as Clean Fuels Policy Potential - that 1s, capable of being
burned without exceeding the primary ambient air quality standards even
though the resulting sulfur emissions would exceed SIP limitations.
Table 2-1 summarizes the State actions In EPA Regions III, IV, and
V in response to the Clean Fuels Policy. The table also reports the
level of technical assistance EPA 1s providing to the States.
The current energy shortage has placed an additional requirement on
EPA to provide the results of air quality modeling studies. These studies
are to aid In the selection of power plants that have an oil-to-coal
firing reconvertability and that can convert with a minimum adverse en-
vironmental Impact. These studies have been completed on 75 power plants,
with a potential oil savings of 560,000 million barrels per day, in the
northeastern states. Forty-six of these plants have been ranked accord-
Ing to their probable Impact on air quality if converted from oil to
coal burning. The conversion of many of these plants to coal burning
would have an adverse Impact on air quality.
MAINTENANCE OF STANDARDS/LAND USE CONTROLS (INDIRECT SOURCES)
As a result of the court order 1n Natural Resources Defense Council
v. Ruckelshaus. EPA has developed regulations requiring that SIPs Include
procedures to review construction of "Indirect sources" that would
Interfere with attainment and maintenance of the national standards.
The term "Indirect sources" has been used by EPA to describe
facilities which Indirectly cause air pollution by substantially Increas-
ing traffic, e.g., shopping centers and sports arenas and other similar
sources.
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Table 2-1. CLEAN FUELS POLICY (CFP) ACTION SUMMARY
Area
Region III
Delaware
District of
Columbia
Maryland
Pennsylvania
Virginia
West Virginia
Region IV
Alabama
Florida
Georgia
i
Kentucky
Mississippi
North Carolina
South Carolina
Tennessee
Region V
Illinois
Indiana
Michigan
Minnesota
Ohio
Wisconsin
Impact
of
CFPa
C
C
Cc
C
C
A
A
C
B
A
C
AC
B
A
C
A
A
C
A
C
Anticipated
date of
State CFP
regulation
changes'1
_-
--
--
Apr 74
May 74
May 74
--
May 74
f
--
--
May 74
May 74
--
May 74
Apr 74
May 74
--
Variances
May use
variance
Law enforce-
ment uses
variances
Use variances
for secon-
dary standard
EPA support to state
Level3
C
C
C
B
A
A
C
A
A
C
B
A
B
A
B
C
A
B
Type
d
Modeling, con-
sultation11
Consultation,
modelinq"
Consultation,
modelinq, TVAe
SIP disapproved;
consultation,
modeling
Consultation,
TVAe
Mode linn
Consultation,
modelinq, TVAe
Modelingd
Consultation,
modeling
Consultation,
modeling
Consultation,
modeling
Modeling
aA - significant, B - moderate, C - minimal.
Dash Indicates no action is anticipated.
Generally already in compliance with SIP regulations.
Priority I and IA AQCR's involved.
Conducted by Tennessee Valley Authority (TVA) with EPA
CFP status unknown.
support.
19
-------
The timetable for SIP actions Involving Indirect source review
requirements 1s as follows:
1. March 2, 1973 - Advance notice of proposed rulemaking for
an Indirect source regulation and of disapproval of SIPs.
2. April 18, 1973 - Published 1n Federal Register Notice of
i
Proposed Rulemaking to change 40 CFR 51 to Include provisions
for review of Indirect sources for purposes of maintenace of
standards.
3. June 18, 1973 - Published regulations for maintenance of
standards (forwarded to EPA Regional Offices).
4. August 15, 1973 - Due date for State submittal of Implementa-
tion plan revisions.
5. October 30, 1973 - Approval or disapproval of plan revisions by
EPA.
6. January 31, 1974 - Final promulgation of EPA regulations for
disapproved SIPs.
For the last date, the court had previously set December 15, 1973,
but changed 1t upon the petition of EPA for additional time 1n which to
evaluate public comment. Fourteen SIP revisions have been submitted
(see Table 3-3). For those States that have not submitted revisions
and those revisions that are not approvable, EPA proposed regulations
for Indirect source review on October 30, 1973 (see Table 3-4).2 EPA
promulgated regulations for Indirect sources on February 25, 1974.
1. Federal Register. Volume 38, p.9599, April 18, 1973.
2. Federal Register. Volume 38, No. 208, October 30, 1973.
3. Federal Register. Volume 39, No. 38, February 25, 1974.
20
-------
SIGNIFICANT DETERIORATION
On Nay 30, 1972, as the result of a suit filed by the Sierra Club,
EPA was ordered by the District Court of the District of Columbia to
disapprove all SIPs which "do not prevent significant deterioration of
air quality" 1n currently clean areas and to promulgate new regulations
that would prevent significant deterioration. The District Court
order was appealed to the Court of Appeals where it was affirmed, and
subsequently to the Supreme Court, which affirmed the decision by a
tie vote.
As a result, all SIPs were disapproved on November 9, 1972, to the
extent that they did not explicitly "prevent significant deterioration,"
and four alternative sets of regulations were proposed in the Federal
Register of July 16, 1973.4
EPA solicited widespread public participation in the rulemaking
activity because, despite the extensive litigation, there was no guidance
available regarding what level of deterioration is "significant," nor
what procedures should be implemented to prevent that level of deteriora-
tion from occurring. To this end, public hearings on the significant
deterioration Issue were held in Washington, D. C. (August 27-28, 1973);
Atlanta (September 5-6, 1973); and Dallas, Denver and San Francisco
(September 5-6, 1973). A 90-day period for public comment was completed
in October. Over 450 comments were received during the public hearing
and comment period. Main areas of emphasis were on: (1) requesting
Congressional clarification of the Issue, (2) the proposed definition
4. Federal Register, Volume 38, No. 135, July 16, 1973.
21
-------
of "best available control technology" 1n the regulations, and (3)
Indication of a desire for maximum and local flexibility in interpre-
tation of the regulations.
In addition, the Administrator met with governors or deslgnees on
January 11, 1974, to discuss in detail the State and Federal relationship
in this Issue. EPA held a similar meeting with representatives of city
and county governments on January 29, 1974. The Administrator 1s also
expected to discuss EPA's final decision on this issue with Congress
prior to promulgation. No final date has been set for promulgation.
SUPPLEMENTARY CONTROL SYSTEMS
A major Issue related to Implementation plans involves the question
of supplementary control systems (SCS) as an acceptable control strategy.
SCS involve both the temporal variation of emission rate, based on
expected meteorological conditions, to avoid high ground-level concentra-
tions during periods of poor dispersion potential, and the use of tall
stacks to lower ground-level Impact. Early in September 1973, EPA
proposed regulations and solicited public comment on them.
SCS are considered less desirable than constant emission limitations
and, as proposed, will be allowed only for large, remote existing sources
of sulfur dioxide and only where constant emission reduction systems are
not available to the source. Generally this restricts their use to non-
ferrous smelters (after use of add plant control systems) and rural
coal-fired power plants that will not be able to Install stack gas
cleaning equipment nor find low-sulfur coal. The regulations also pro-
posed many requirements for the design and operation of SCS.
5. Federal Register. Volume 38, No. 178, September 30, 1973.
22
-------
EPA has published 1n the Federal Register a policy statement In
the form of proposed regulations on tall stacks and the SCS
proposal. The policy allows consideration of stack extensions
only as a part of existing stacks. Additions to existing stacks up to
the height called for by good engineering practice will be allowed.
COPPER SMELTERS
As a matter of background, on May 31, 1972, EPA disapproved SIPs
for Arizona, New Mexico, Nevada, Utah, Idaho, and Montano because they
did not submit adequate plans to control sulfur dioxide from copper
smelters.7 Regulations for control of these sources to attain primary
standards were proposed by EPA, and public hearings on the regulations
were held during August, September, and October of 1972, at which time
a number of substantial comments were received. Numerous court suits
have been filed by the Individual copper smelters against the EPA-
proposed regulations.
Some of the Important Issues include the validity of the ambient
air quality data upon which the proposed regulations were based, the
accuracy of EPA's diffusion model analysis, and the allegation that
EPA should have provided adjudicative hearings on the proposed
regulations. The decision by the District Court of Colorado in the
Anaconda case was overturned, thus resolving in EPA's favor the issues
of whether or not EPA must file an environmental impact statement and
hold adjudicative hearings. In addition, EPA has initiated an ambient
air quality monitoring system within the vicinity of the smelters 1n
6. Federal Register, Volume 38, No. 178, September 1973.
7. Federal RegTsler. Volume 37, f.10842, May 31, 1972.
23
-------
order to obtain valid and representative data. These data will also
be used to validate the dlfftfsion model employed by EPA.
The major Issue with the smelters Involves the use of supplementary
control systems. On'September 14, 1973, EPA proposed regulations allow-
ing nonferrous smelters and coal-fired power plants meeting certain
8
requirements to employ SCS. In view of the comments received address-
Ing these regulations, It does not appear that there will be any
significant changes to the proposed SCS policy as It relates to
smelters. Therefore, at this time, EPA Is Devaluating State plans
or proceeding with the promulgation of smelter regulations to attain
both primary and secondary standards, employing SCS where appropriate.
Such a promulgation will satisfy the requirement of developing a
plan for the secondary sulfur dioxide standard within 18 months from
the Initial plan approval or disapproval and the requirement for de-
veloping substitute regulations to attain and maintain the primary
standards. Before proceeding with such a promulgation, 1t would be
necessary to again propose the regulations for attainment of primary
standards due to changes in air quality data and the SCS policy.
8. Federal Register. Volume 38, No. 178, September 14, 1973.
24
-------
SECTION 3
STATE IMPLEMENTATION PLAN PROGRESS
EPA ACTIONS
States were required to submit to EPA by January 31, 1972, their
plans for attainment of national ambient air quality standards
for six criteria pollutants (sulfur dioxide, particulate matter,
carbon monoxide, photochemical oxldants, hydrocarbons, and nitrogen
dioxide).
A priority classification system was established to categorize
A1r Quality Control Regions (AQCRs) according to the severity of the
air pollution problem in each AQCR for purposes of SIP development
and evaluation. The SIP requirements vary according to the priority
classification in order that the time and resources to be expended in
both plan development and carrying out the plan are commensurate with
the air pollution problem. The classifications have been based on
measured ambient air concentrations where known or, where not known,
on modeling estimates of air quality in the area of maximum pollutant
concentration.
AQCRs are classified as follows:
1. Priority I - ambient concentrations significantly above
primary standards.
1. Federal Register. Volume 36. No. 158, p. 15486, August 14, 1971
25
-------
2. Priority la - ambient concentrations significantly above
primary standards due to emissions from a single point
source.
3. Priority II - ambient concentrations significantly above
secondary standards.
4. Priority III - ambient concentrations at or below secondary
standards.
Table 3-1 is a summary of the AQCR priority classifications for
the various pollutants. It should be noted that 43 AQCRs Initially
classified Priority I or la for nitrogen dioxide were proposed
Table 3-1. SUMMARY OF AIR QUALITY CONTROL
REGION PRIORITY CLASSIFICATION
Pollutant
Part icul ate matter
Sulfur dioxide
Carbon monoxide
Nitrogen dioxide*
0x1 dant/hydrocarbon
Total
247
247
247
247
247
Priority
I
109
39
.29
4
54
Priority
la
11
21
Priority
II
70
41
Priority
III
57
146
218
243
193
Assuming reelass1f1cat1on is promulgated as proposed.
26
-------
2
to be reelasslfled Priority III on June 8, 1973. The proposed re-
classification 1s a result of new air quality data, which show lower
levels of nitrogen dioxide than those measured using the previous
analytical reference method (Jacobs-Hochheiser).
A priority classification of AQCRs by pollutant 1s contained in
EPA Publication 450/1-73-001.3
Plans were submitted by all 55 States (the 50 states plus the
District of Columbia, Guam, American Samoa, Puerto Rico, and the Virgin
Islands), and EPA approved or disapproved all portions of these plans.
Table 3-2 shows the status of the 55 plans with respect to the need
for EPA promulgation and the degree to which these promulgations have
been made. It should be noted that the number of plans fully approved
and with no regulatory disapprovals has dropped from 17 to 16 since the
A
previous SIP progress report. The change in the approval/disapproval
figures are the result of recent actions on compliance schedules.
Table 3-2 does not reflect plan disapprovals with respect to
"significant deterioration" or maintenance of the national standards.
Final determination on significant deterioration has not yet been made.
Maintenance of national standards is discussed below.
The Issue of maintenance of standards has been addressed in two
ways: a source-by-source review of Indirect sources, and long-range
plans for areas likely to exceed standards in the future. On June 18,
1973, EPA promulgated regulations requiring States to submit by
2. Federal Register. Volume 38, No. 110, p. 15180, June 8, 1973.
3. The National Air Monitoring Program: Air Quality and Emissions
Trends Annual Report, Volume I, EPA 450/1-73-001a, August 1973.
4. State Air Pollution Implementation Plan Progress Report, January 1
June 30, 1973. U.S. Environmental Protection Agency, Research
Triangle Park, North Carolina, Publication No. EPA 450/2-73-005,
September 1973.
27
-------
Table 3-2. STATUS OF STATE IMPLB1ENTATION PLANS, SUMMARY
SIPs approved through State submtttal 14
SIPs approved as submitted by States with exception of 2a
some nonregulatory deficiencies; not correctable by
EPA promulgation
SIPs submitted by States and requiring EPA promulgation 39
SIPs with all regulatory deficiencies corrected 26
by EPA promulgation
SIPs with all regulatory deficiencies not yet 13
corrected (finalized) by EPA promulgation
Total plans 55_
dEPA delegated authority to release emissions data (regulatory
provision) to South Dakota (Table 3-5).
March 18, 1974, a list of areas likely to violate national ambient air
5
quality standards far any pollutant within 10 years. EPA will review
and finalize these lists by June 18, 1974, following which the States
must submit plans for assuring that such violations do not occur. These
plans, due within 2 years from promulgation of the requirements, will be
reviewed and approved by EPA much as the original SIPs were. This
schedule 1s shown in Table 3-3.
The same promulgation requires States to set forth legally en-
forceable procedures for reviewing, on a sonrce-by-source basis, all
new or modified sources to determine if such construction or modifi-
cation win violate any control strategy or will interfere with
5. Federal Register* Volume 39, No. H6r June 18* 1973.
28
-------
Table 3-3. MAINTENANCE 01" AIR QUALITY STANDARDS, ACTIVITY SCHEDULE
Phase
Activity
Responsible
agency
1973
JJASOND
1974
JFMAMJJASOND
1975
JFMAMjJASOND
11
to
III
Promulgation of regulation EPA
Develop plan for Indirect
source review States
Plan review: approval/
disapproval EPA
Plan promulgation EPA
Guidelines for designa-
tion of problem areas EPA
Designation of problem
areas States
Review/publication of
list of problem areas EPA
Guidelines for analysis
and development of EPA
10-year plan
Testing of procedures for EPA/
analysis/plan develop- States
meht
Analysis of problem areas/
development of 10-year States
plan/submlttal
Review of submlttal,
approval/proposal/ EPA
promulgation
1/31/74
1Z/20/73
3/18/73
1 6/18/74
1 8/1/74
6/18/75
12/18/75
-------
attainment or maintenance of any national air quality standard, either directly
through emissions or indirectly through associated mobile source activities.
Table 3-4 shows the status of source review plans as of January 1974.
Table 3-5 displays the specific States (and 1n some cases AQCRs)
having deficiencies in regulatory or nonregulatory provisions.
EPA has the authority to propose or promulgate regulations to over-
come States' regulatory deficiencies. EPA, as a matter of policy, will
rescind its regulations when States enact adequate legislation or
regulations. Table 3-5 also lists the proposals and promulgations to
alleviate regulatory deficiencies and also indicates whether or not legal
authority 1s possessed by the State or if legal authority has been
delegated by EPA to the State. Sixteen States are deficient in legal
authority for nonregulatory provisions (Table 3-5).
States with unapproved nonregulatory provisions are also listed
in Table 3-5. It is noted that the nonregulatory deficiencies can be
corrected only by State action, i.e., State submittal of additional
information. The combination of the deficiencies of regulatory and
nonregulatory provisions reflects the States' overall plan conformance
to Federal Register requirements.
EXTENSIONS
Extensions for Attaining Primary Standards
The Clean Air Act provides for extensions of up to 2 years
beyond the 3-year period prescribed for attainment of national
primary ambient air quality standards in those AQCRs where needed
6. Federal Register, op c1t 1.
7. Clean Air Amendments of 1970, Public Law 91 604, December 31, 1970.
30
-------
Table 3-4.
EPA region
SUMMARY STATUS OF STATE ACTIVITY ON INDIRECT
SOURCE CONTROL REGULATIONS
State plans
submitted by
January 1, 1974
Probable
submittals
mid-1974
Probable
nonsubmlttals
Region I
Connecticut
Maine
New Hampshire
Vermont
Rhode Island
Massachusetts
Region II
New York
Virgin Islands
New Jersey3
Puerto Rico
Region III
Virginia
Delaware
District of Columbia
Maryland
Pennsylvania
W. Virginia
Region IV
Florida
Alabama
Kentucky
North Carolina
Georgia
South Carolina3
Tennessee9
Mississippi3
Region V
Illinois
Indiana
Michigan3
Minnesota
Ohio
Wisconsin
Region VI
Arkansas
Louisiana
Oklahoma8
New Mexico3
Texas3
Region VII
Nebraska
Iowa3
Kansas3
Missouri3
Region VIII
Colorado
Montana3
North Dakota3
South Dakota3
Utah3
Wyoming3
Region IX
Guam
American Samoa
Nevada
California
Ar1zona
Hawaii
Region X
Idaho
Washington
Oregon
Alaska3
Totals
15
21
19
aStates without legal authority to regulate Indirect sources.
31
-------
Table 3-5. STATUS OF STATE IMPLEMENTATION PLANS3
EPA Reglon/State/AQCR
Region I
Massachusetts
Metropolitan Boston
Hartford-New Haven-Springfield
Interstate
Rhode Island
Vermont
New Hampshire
Region II
New Jersey
New Jersey-New York-Connecti-
cut Interstate
Metropolitan Philadelphia
Interstate
New York
Hudson Valley Intrastete
Genesee-Flnger Lakes
Intrastete
Southern Tier West Intrastete
New York-New Jersey-Connecti-
cut Interstate -
Central New York Intrastete
Virgin Islands
Region HI
District of Colurtia
Maryland
Metropolitan Baltimore
Intrastete
National Capital Interstate
Pennsyl vania
Southwest Pennsylvania
. Intrastate
Metropolitan Philadelphia
Interstate
Virginia
National Capital Interstate
West Virginia
Region IV
Kentucky
South Carolina
Tennessee
Region V
Illinois
Metropolitan Chicago
Interstate
Indiana
Metropolitan Indianapolis
Interstate
Chicago
Michigan
Metropolitan Detroit-Port
Huron Intrastete
South Central Michigan
Intrastete
Metropolitan Toledo
Intrastete
Minnesota
Ohio
Cincinnati and Kami 1 ten County
Northwest Pennsylvania
Youngstown (Pa.)
Greater Metropolitan Cleveland
Steubenvl 1 It-Wei rton-
Hheellng (W.Va.)
Wisconsin
*
^
iff
a. « e
X(NLA)
NLA
X(NLA)
OLA
OLA
X
X(NU)
fjf Qt
O C 9k
Iff
"*J« O
iS-0
Sf S
X
X(NLA)
X
OLA
- -
? *"
C
°*3
111
0
0
c
0
0
X
X
X
>
c £
^"3
fl
S w
O Ml
A
X
X
X
X
0
0
0
0
0
0
X
X
X
0
X
X
X
X
X
X
X
c
**
u
O
o. p
VI t
5 O
t- 0
X
X
X
X
X(NLA)
NLA
X
X
X
X
X
NLA
X
X
0
X
Emission limitations
S02
0
0
0
0
0
0
0
0
TSP
0
0
0
0
0
0
0
HC
1
X
X
N02
0
xS
*> c
~- «
U L.
D
0
a
S c
f O
Ml *-
01
* Ml
1- T>
D
0
NLA
e
xo
II
W V*
UJ V
O(NLA)
'
i
!
,
1
«
Resourc
0
0
D
0
3
C
u
ES
$2
O
-------
Table 3-5 (continued). STATUS OF STATE IMPLEMENTATION PLANS3
EPA Region/State/AQCR
Region VI
Arkansas
Louisiana
New Mexico
Four Corners Interstate
Texas
El Paso-Las 'Cruces-Alaaagoro
Interstate
Austin-Waco Intrastate
Metropolitan Houston-Calves ton
Intrastate
Metropolitan Oal las-Fort Worth
Intrastate
Metropolitan San Antonio
Intrastate
Southern Louisiana-Southeast
Texas (La.)
Corpus Chrlstl-Victoria
Region VII
Iowa
Kansas
Missouri
Nebraska
>,
"
^
U ID *>
3 > «-
O. -0 O
X(NLA)
X(NLA)
X(NLA)
X
Jefferson, Gage, and Thayer
Counties
Region VIII
South Dakota
Colorado
Montana
Helena Intrastate
Utah
Four Corners Interstate
Wasatch Front Intrastate
Wyonlng
Region IX
Arizona
Pi ma County APCD
Phoenix-Tucson Intrastate
Arizona-New Mexico Southern
Border Interstate
Four Corners Interstate
California
Metropolitan Los Angeles
Intrastate
Sacramento Valley Intrastate
San Oitgo Intrastate
San Francisco Intrastate
San Joaquin Valley Intrastate
Southeast Desert Intrastate
Nevada
Region X
Alaska
Northern Alaska Intrastate
Idaho
Eastern Washington-Northern
Idaho Interstate
Oregon
Hashing ton
Puget Sound Intrastate
Eastern Washington-Northern
Idaho
OLA
f-S?
S£«
M V k
J< O
SI p £
1> o
CT U "O
X
X
X(NLA)
X(NLA)
X
NLA
X
X
X
Sin
c
c ? £
^- V **
o o
*-* c
«o ~-
9 »-
U L
..
»- o
* tj
Ci
S c
o ~-
II
T T
c I ?\
..7" «« . *. -"
c a* «^ O
* ° J £ V
1
4 ....
T
D
o !
1
0
! 0
1
0
i o
X
X
X
X
X
0
0
1
NLA
,
\
0
D |0(NLA)
0
0
D
0
D
0
0
*X « proaulgated; 0 proposed; 0 - deficient; NLA no legal authority; OLA legal authority delegated bw EPA.
33
-------
technology or other alternatives either are not available or will not
be available soon enough to attain the primary standards.
At present, there are 16 States involving 28 AQCRs with extensions
for attainment of primary standards (Table 3-6). Of these States,
14 required EPA promulgation; and an extension was provided as part of
the control strategy.
Extensions for Submitting Plans for Attaining Secondary Standards
Pursuant to Section 110(b) of the Clean Air Act, EPA has granted
or provided 18-month extensions for the development of control strat-
egies for achieving secondary standards for total suspended particulates
and/or sulfur dioxide. These extensions are summarized in Table 3-6.
These were granted on the basis of an apparent lack of reasonably
available control technology or equipment, or, in the case of some
plans for participate matter, inadequate data on which to base the
control strategy.
Thirteen States covering 26 AQCRs were given extensions for the
particulate standard. Of these, plans for six States covering 14 AQCRs
have been submitted to EPA. A plan for one State involving 2 AQCRs
has been submitted, and EPA has made it available for public comment.
The remaining plans for six States and 10 AQCRs are under development
by EPA. As of February 15, 1974, none has been approved or disap-
proved.
Twelve states covering 20 AQCRs were given extensions for the sulfur
dioxide standard. On September 14, 1973, after the 18-month extension
period was ended, before any plans for these AQCRs were received, the
standard was changed, and an additional 4 months (until January 14, 1974)
34
-------
was allowed for subnrfttal of these plans. To date, plans for three
States covering 5 AQCRs have been submitted to EPA; plans for nine
States Involving 15 AQCRs are under development by EPA. None has been
made available for public comment nor approved or disapproved by EPA.
EPA 1s currently developing regulations to achieve the secondary
standards for both total suspended particulate and sulfur dioxide in
these AQCRs where extensions were granted and no plan was submitted.
This includes specific regulations for sulfur dioxide emissions from
nonferrous smelters for six States (Arizona, New Mexico, Utah, Idaho,
Montana, and Nevada) where extensions were not requested by the States
but were provided by EPA.
TRANSPORTATION CONTROL PLANS
Eighteen States were required to submit Transportation Control
Plans (TCPs) for 32 AQCRs to achieve compliance with national ambient
air quality standards for carbon monoxide and photochemical oxidants
(hydrocarbons). The EPA has reviewed the transportation plans thus far
g
submitted by these States and commented on their deficiencies. The
status of EPA approved or promulgated plans as of February 11, 1974, is
shown in Table 3-7.
In Birmingham and Mobile, Alabama; Kansas City, Kansas; Kansas
City, Missouri; Baton Rouge/Lake Charles, Louisiana; Dayton and Toledo,
Ohio; Syracuse, New York; and Corpus Christi, Texas, it was determined
that both additional stationary source control and the Federal Motor
g
Vehicle Emissions Control Program (FMVECP) would be needed to attain
8. Annotated in Federal Register. Volume 38, No. 213, November 6, 1973,
9. Clean Air Amendments of 1970,' Public Law 91 804, December 31, 1970.
35
-------
Table 3-6. STATUS OF EXTENSIONS
EM KOotoo/Stote/WKR
legion 1
Canooctlcat
Conoetlait
NUMdMMttS
ftetraoollton Boston
Raglan 11
OMJereey
BoUopoHton HrflodMpMo
COHMCtiCOt
M toft
Control Mo» York
lotrectate
tLS[m.r **" '
Mofn Frontltr
OftaB III
District of ColvoMo
""o^ollten olttaere
'Rational Copitol
POBBSylvOBiO
Philadelphia lotrwtete
SottttlWt> PMMmflVMliA
VfFftate
otlonol Copitol
ogloo IV
teotm^
Looiovfllc
ooton V
tadiooo
toMooopoHi
CMcogo Interf tote
OMo
NotnpoYlton Clovcluid
Roaian VI
«Hn»4ho> HHrtco Border
tarConon
QolUk-Ft. Morth
Hoostoo-«o1voston
Netraoolltan Son tattoo
How? stonaords
Strto
plon
Hnolwri
.
o
f
0
%
*
0
«
AQCft
tmolwd
o
*
*
o
*
o
o
o
0
Oft
prooMlytton
Vos
Vos
Tos
Ho
to,
VOS
No
'
1
Tos
Tot
Pollutant Involved
md ottalnoont dote
0,
1
5-77
5-77
12-76
5-77
5-77
5-77
»
1
«
5-76
S-77
5-77
CO
5-77
8-76
12-K
. . _.
5-77
5-77
5-77
TSP
7-77
7-77
.
Sfe
7-77
7-77
,*^o
i
(IS-oontli extern tans)
Bion
iMOtootf
«
0
0
*
...
0
o
o
0
teS&d
'*
o
0
0
0
*
*
o
0
0
0
«
o
*
0
o
*
Pollutant
Involved
TSP
"
o
*
o
o
o
0
0
0
0
o
o
0
0
SOz
o
0
0
*
*
o
0
0
o
36
-------
Table 3-6 (continued). STATUS OF EXTENSIONS
EM Reglon/State/ADCR
Region VIII
Colors*
Denver
Sui Isabel
Pemne
Montana
Helena
Utah
Row Comers
Uesatch
Region II
AtoflM^^H
Arizona-Haw Nsxlco Border
Four Corners
Phoenix-Tuscan
California
Netropolttwi Los Angeles
Sacrascnto
San Olego
San Joaquin
Southeast Desert
HM«I
Hawaii
Newda
ftevada
Region X
AUska
Cook Inlet
North Alaska
Idaho
East NesMBfta*
East Idaho
Idaho Intrestate
Boise
HasMngton
Worth Ideho
Pugot Sound
Primary standards
State
plan
Involved
e
e
o
e
e
e
0
AQCR
involved
e
e
e
e
o
e
e
e
e
e
e
EM
proBulgatlon
required
res
Yes
Yes
Yes
Yes
Yes
TVS
Yes
Pollutant Involved
nd atttlHBtnt date
o,
5-77
5-77
5-77
5-77
5-77
5-77
5-77
CO
5-77
8-76
5-77
5-77
5-77
5-77
5-77
5-77
5-76
5-76
TSP
so?
Secondary standards
(18-«ontti e« tensions)
State
plan
involved
e
7-77
3-76
7-77
7-77
3-76
7-77
7-77
e
o
e
o
e
e
»
0
AQCR
involved
e
o
e
e
o
e
e
e
e
e
e
e
e
e
Pollutant
involved
TSP
e
e
e
e
e
0
S02
e
o
e
e
e
e
37
-------
Table 3-7. SUMMARY OF TRANSPORTATION CONTROL PLANS
EPA Region/
State/AOCR
Region I
Massachusetts
Metropolitan Boston
Interstate
Hertford-New Haven-
Sprlnqfleld Inter-
state
Region II
New Jersey
New York. New Jersey.
Com. Interstate
(Newark)
Metropolitan Phil-
adelphia Interstate
New York
New York, New Jersey.
Conn.
Rochester
Region III
District of Columbia
National Capital
Interstate (0. C..
Ve.. Md.)
Maryland
Metropolitan Balti-
more Interstate
{Baltimore)
Pennsylvante
Metropolitan Phil-
adelphia Interstate '
(Philadelphia)
toothwest Pennsyl-
vania Interstate
(Pittsburgh)
Region V
Illinois
Metropolitan Chicago
Interstate (Chicago)
Indiana
Metropolitan Indian-
apolis (EPA
Proposal)
Minnesota
NInneapolls-St. Paul
Okie
Metropolitan Cincin-
nati Interstate
Region VI
Tens
Austin-Mice
Corpus Christ!
Metropolitan Hotftan-
elvnton
Acceptable State portion (S) or EPA promulgation (E)
b*
t
CO
59
57
47
44
78
~
55
57
55
57
50
25
*
40
»
..
--
required. 1
V
68
16
60
45
68
45
60
62
53
48
__
M
43
27
56
75
Inspection/
maintenance
E
E
S/E
S/E
S
S
S/E
E
S/E
E
E
E
E
E
Catalytic
retrofit
E
E
E
S
Ef
E'
Ic
I!
E
S/E
E
4*
e
e
E
E
E
E
E
High altitude
modifications
EGR/alr bleed
E
E
E
EJ
1
3
Traffic flow
Improvements
E
S
E
E
E
E
S
|
Parking restrict
E
E
E
E
S
Mass transit
Improvements
i
S/E
E
S/E
E
E
S
E
S/E
E
S
a
Additional statl
source controls
E
E
E
S
S/E
S/E
S
E
E
S
E
E
I
i
*
E
Ed
I
$
Bus/cirpool loe*
E
E
E
S
E
E
E
E
M
S
e
S
3
E
Motorcycle
emission regs.
1
E
S/E
S
S
t
i
j
i
E
E«
|
£-
*>
£
1
s*
\\
!
1 *
p
s|
Miscellaneous
measures
:
Extension
granted.
months
1
E «b 24(0,)
1
i
'
-- 14
i '
1
' 14(CO)
E E ^ 24|0,)
14(00)
E E '24(0,)
t J
E
E
E
t
'
e
1
._n
-- 24|HC)
! 19(CO)
0
S/E
i
$9
S"
24(0,)
1
E 'E
E
E
24(0,)
--11 12(CO)
1
k 24 (CO)
E " ; isjo,)
, |
E
|
0
E
j m
E
1
13(0.)
0
A
*"fc t v
-- j 0
..p
24(0,)
38
-------
Table 3-7 (continued). SUrWARY OF TRANSPORTATION CONTROL PLANS
EPA Ragion/
State/AOCfl
Metropolitan Dellas-
* Ft. Forth
Metropolitan San
Antlonlo
El Paso-Las Cruces-
Alaangordo Inter-
state
jglon VIII
Colorado
Natropolltan Denver
Utah
Hasatch Front Inter-
state (Salt Lake
City
Region IX
Arizona
PhoenU-Tucson Intra-
state (Phoenix-
Tucson)
California
Sin Francisco Bay
Area
Metropolitan Los
Angeles
San Diego
Sacraaanto Valley
San Joaquln Valley
Southeastern Desert
Region X .
Alaska
Northern Alaska In-
trastate Region
(Fairbanks)
Oregon
Portland Interstate
Washington
Puget Sound Intre-
state (Seattle)
Eastern Washington-
Northern tdifio
Interstate (SDOkane)
Acceptable State portion (S) or EPA promulgation (E)
M
f
CO L>
"
..
~
64
59
66
37
78
SO
59
40
25
66
60
55
SO
33
45
34
56
33
78
87
75
67
67
79
43
20
Inspection/
Maintenance
E
S
S/E
S/E
S/E
S/E
S/E
S/6
S/E
_q
E
S
S/E
S/E
CaUlytlc
retrofit
S/E
E
E
E
E
E
^
E
II
S
S/E
S/E
E
E
E
I
S
S
s
E
E
High altitude
Modifications
S
S/E
|
L.
I
~
S/E
E
E
E
i
3
.
S/E
l|
»--
S
E
S/E
S/E
E
S
S/E
|
U
M
t
S
S/E
E
E
E
E
E
E
E
S
S/E
S/E
Miss transit
Inprovenents
S
S
S/E
S/E
1
** Ifl
Additional sti
source contro'
E
E
E
E
S
S/E
S/l
S/f
E
E
^
S
u
M
E
i
I
g
j
N,
IN
*"
E
E
i/l
E
E
E
E
E
E
E
|
s
1
1
£
S
E°
E°
E°
E°
B
NotorcycTe
emission regs
E
E
E
E
E
Idling
limitations
~
E
i
I
E
.
u
]j
E
E
S
E
E
E
E
n
c o
?*
f.
E
E
--
E
E
E
E
E
E
*
"*
S
li
..k
k
P
-b
_b
"*
Extension
grinud.
onths
0
24(0,)
0
24(00)
24(0,)
14(00)
>4(CO)
24(0,)
24(0,)
24(0,)
24(0,)
24(0,)
24(0,)
24(00)
12
12(00)
12(00)
"Percent reduction (oxldant reading - oildant standard)/ox1dant reading.
Pricing policies (E).
'Delivery prohibited.
Trenton.
*Tax1 ban. bridge tolls.
fFleet.
'Aircraft and taxi control.
Parking surcharge
fOn light- and nedlm-dut* vehicles.
Air/ fuel control retrofit on light-,
duty vehicles.
kA1rcraft controls.
'caaylete 1-36.
"Fringe parking and transit.
"Off-hlgtway user controls.
°1977.
pE^loyee carpool Incentives.
^Depends on control for Los Angeles.
i*-. and heavy-
39
-------
the air quality standards. In all other cases, plans only had to take
the FMVECP Into account, and these consisted of two basic types,
(1) Inspection/maintenance, and (2) retrofit of vehicles now 1n use to
reduce emissions per mile and a series of steps to reduce vehicular miles
of travel by carpooling and use of mass transit.
Hearings and other public airings of TCPs haye brought a variety
of reactions. Parking restrictions have been opposed by merchant
groups, motorcycle bans have been opposed by manufacturers, and almost
universal opposition arose to gasoline limitations and excessive
vehicular travel reductions. In some highly automobile-dependent areas,
such decisions may well be subject to review before final compliance
dates in 1977. On the other hand, mass transit programs and carpool
Incentives drew positive reactions. The public responded unfavorably,
however, to parking surcharge regulations and provisions for review of
all new parking facilities over a specified size limit. Accordingly,
the Administrator published appropriate notice 1n the Federal Register10
withdrawing all parking surcharges Imposed by the EPA and postponed
until January 1, 1975, regulations providing for review of all new
parking facilities.
Delays in the projected availability of the necessary hardware for
Implementing gasoline vapor control strategies at motor vehicle service
stations have postponed the estimated compliance date for these
strategies until June 1, 1974.
Compliance dates for certain other TCPs published in the Federal
Register are being adjusted to meet requests by appropriate State
authorities.
10. Federal Register. Volume 39, p. 1848, January 15, 1974.
40
-------
SECTION 4
PLAN REVISION MANAGEMENT SYSTEM
BACKGROUND
As discussed in the previous SIP progress report, one important
issue facing EPA is whether the approved SIP control strategies will
attain the national ambient air quality standards within the time
2
frame prescribed by the Clean Air Act. In response to this problem,
the Office of Air Quality Planning and Standards (OAQPS), EPA,
developed a Plan Revision Management System (PRMS) to identify Air
Quality Control Regions (AQCRs) with "possible deficiencies" that may
need a plan revision. The PRMS will identify possible deficiencies by
comparing the measured air quality values at each monitoring site
within an AQCR with projected emissions/air quality values based on
applicable SIP regulations, growth, transportation control plans, and
the interim automotive emission standards to determine if adequate
progress has been made toward attainment of the standards.
OPERATION OF THE SYSTEM
The system is designed to combine and utilize information con-
tained within SAROAD (air quality), NEDS (source emissions), and CDS
1. State Air Pollution Implementation Plan Progress Report, January 1
to June 30, 1973. U.S. Environmental Protection Agency, Research
Triangle Park, North Carolina. EPA-450/2-73-005, September 1973.
2. Clean Air Amendments of 1970, Public Law 91 604, December 31, 1970.
41
-------
(enforcement and compliance). Currently available data from all of
these systen.s are used to project the air quality levels that can be
expected from enforcement of the regulations submitted as part of the
SIP. From this Information, a projected emission/air quality curve 1s
developed for each AQCR under study. As additional ambient air quality
data are submitted (as required by 40 CFR 51.7),3 they will be entered
into the SAROAD system. PRMS will analyze these data by comparing
them to the projected air quality values to determine if adequate
progress has been made. In each case where measured levels exceed
projected levels (allowing for statistical variation), the AQCR will
be flagged as having a "possible deficiency." Since many factors
influence air quality measurements, it is not possible to state con-
clusively that a flagged AQCR has an adequate SIP. The system, by com-
paring the observed air quality to the predicted air quality, can
determine a priority list of monitoring sites that may warrant further
review. Thus. PRMS provides a management tool to Identify those areas
that appear to have a deficient SIP.
In addition to providing a management tool for Identifying AQCRs
that have possible deficiencies the PRMS can also be used to identify
AQCRs or portions of AQCRs whose air quality has significantly de-
teriorated. No action has been taken in this report relative to air
quality deterioration since the issue (significant deterioration) has
not been resolved.
3. Federal Register. Volume 38, No. 149, p. 20832, August 3, 1973.
-------
To date, the PRMS analysis has been expanded to Include the 67
AQCRs listed 1n Table 4-1. Additionally, the PRMS has been expanded
Table 4-1. AQCRs ANALYZED IN PRMS
Region I
Hartford-New Haven-Spr1ngf1eld
New Jersey-New York-Connecticut9
Metropolitan Boston
Metropolitan Providence
Merimac Valley-Southern NH
Region II
New Jersey-New York-Connecticut3
Metropolitan Philadelphia3
Northeast Pa-Upper Del Valley
Central New York
Genessee-Flnger Lakes
Hudson Valley
Niagara Frontier
New Jersey
Region III
Metropolitan Philadelphia3
National Capital
Metropolitan Baltimore
Northeast Pa-Upper Del Valley
Northwest Pa-Youngstown3
Central Pennsylvania
South Central Pennsylvania
Southwestern Pennsylvania
Central Virginia
Hampton Roads
Kanawha Valley
Southern West Virginia
E. Tenn-Southwestern Virginia3
Region IV
Metropolitan Birmingham
Mobile-Pensacola-Panama City
Jacksonvl11e-Brunsw1ck
West Central Florida
Augusta-A1ken
Chattanooga
Metropolitan Atlanta
Paducah-Calro3
Louisville3
Metropolitan Cincinnati3
Metropolitan Charlotte
Charleston
E Tenn-Southwestern Va.3
Middle Tennessee
Region V
Metropolitan Chicago
Metropolitan St. Louis3
Puducah-Cairo3
Louisville3
Metropolitan Cincinnati3
Metropolitan Indianapolis
Wabash Valley
Metropolitan Detroit-Port Huron
M1nneapolis-St. Paul
Dayton
Greater Metropolitan Cleveland
Metropolitan Columbus
Northwest Pa-Youngstown3
Southeast Wisconsin
Region VI
Central Arkansas
Shreveport-Texarkana-Tyler
Southern La-Southeastern Texas
Central Oklahoma
Northeast Oklahoma
Metropollan Houston-Galveston
El Paso-Las Cruces-Alamogordo
Region VII
Metropolitan St. Louis3
Metro Omaha-Council Bluffs
Metropolitan Kansas City
Nebraska
Region VIII
Metropolitan Denver
San Isabel
Wasatch Front
Region IX
Phoenix-Tucson
Metropolitan Los Angeles
San Diego
San Francisco
Hawaii
Region X
Eastern Wash-Nor them Idaho
Portland
Puget Sound
alnteragency AQCR.
-------
from the analysis of annual total suspended particulate matter and
sulfur dioxide standards to analysis of all current national ambient
air quality standards except that for nitrogen dioxide. The standards
considered in the PRMS analysis are given in Table 4-2. No PRMS
Table 4-2. NATIONAL AMBIENT AIR QUALITY STANDARDS FOR PRMS ANALYSIS
Pollutant
Total suspended
particulate
(TSP), ug/m3
Sulfur dioxide
(S02), wg/m3
Carbon monoxide
(C0),mg/m3
Total oxldants
(Ox), jig/m3
Standard
Primary
Averaging
time
Annual
24 hours
Annual
24 hours
8 hours
1 hour
1 hour
Concentration
75
260
80
365
10
40
160
Secondary
Averaging
time
Annual
24 hours
3 hours
8 hours
1 hour
1 hour
Concentration
60
150
1300
10
40
160
analysis for nitrogen dioxide was performed for any of the 67 AQCRs
due to the proposed changes in the reference measurement method dis-
cussed in 40 CRF 50.4
4. Federal Register. Volume 38, No. 110. p. 15178, June 8, 1973.
-------
Although the Phoenix-Tucson, Eastern Washington-Northern Idaho,
El Paso-Las Cruces-Alamogordo, and Wasatch Front AQCRs were included
in this report, the projected air quality curves for particulates and
sulfur dioxide did not consider the impact of smelter regulations and
fugitive dust regulations that are to be proposed by EPA (discussed
in Section 2). Thus, any possible deficiencies identified for these
AQCRs and associated with these emissions should be corrected by the
implementation of the smelter and fugitive dust regulations.
ACTION PROCEDURES
When a possible deficiency is identified, OAQPS notifies the
appropriate Regional Office (as discussed in the OAQPS guideline
document), which will then be responsible for investigating the special
details of the situation and determining the validity of the data and
the magnitude of any problems. This should be done in cooperation with
the respective State and local agencies. Such an investigation should
include a determination of the validity of the data in question as well
as a review of the effectiveness of the implementation plan control
strategy. This investigation should include the following actions, as
appropriate.
1. Data review actions:
a. Review and certification (if possible) of the data.
b. Review of meteorological conditions associated with
sampling period to determine if abnormal conditions could
have affected air quality levels.
5. Guidelines for Determining the Needs for Plan Revisions to the
Control Strategy Portion of the Approved State Implementation
Plans. CPDD, OAQPS, Environmental Protection Agency, Research
Triangle Park, N. C. QAQPS No. 1.2-011. November 30, 1973 (draft)
-------
c. Site Inspection to determine if monitor Is properly located.
d. Site Inspection to determine 1f site location 1s source
oriented. In this case, a unique projected curve might be
required for the site to facilitate analysis of the data.
e. Development of a more detailed projected curve for the
entire AQCR.
2. Program actions:
a. Review of compliance schedules for the AQCR to determine
If any sources have failed to meet any scheduled milestones
or final compliance dates.
b. Notification of the State that a more effective Implementa-
tion of the new source review procedures 1s needed to
restrict growth In certain areas.
c. Determination by special study of the cause of the present
air quality problem.
3. Legal actions:
a. EPA/State enforcement action.
b. SIP revision. The Regional Office should notify the State
of the need for the revision.
c. The State's plan revision has not been submitted or approved
and work has been Initiated by EPA to develop the necessary
plan revisions.
The above action procedures have been revised since the previous
d(
7
SIP progress report based upon additional Information and comments
received on the OAQPS Guidelines/
6. State Air Pollution Implementation Plan Progress Report, op clt 1
7. OAQPS No. 1.2-011, op c1t 5.
46
-------
To assist the Regional Offices with their review, OAQPS will
provide each region with detailed copies of the Individual PRMS site
reviews for each monitoring site that has been Identified as having a
possible deficiency within 60 days after the end of each semiannual
reporting period.
To date, some data review actions have been Initiated by the
Regional Offices to determine the cause of the Identified problems in
the previous SIP progress report, which covered 17 AQCRs. Additional
Investigations will be conducted as additional AQCRs are analyzed and
reviewed.
PRMS ANALYTICAL RESULTS
The following discussion presents a short generalized summary of
the PRMS analysis of the 67 AQCRs to date. Table 4-1 provides a 11st
of the AQCRs that are currently in the PRMS by Regional Offices. A
supporting document has been prepared by OAQPS that contains the de-
tailed summary, regional maps, and Important Individual site reviews
for each AQCR analyzed. This supporting document is available from
OAQPS upon request.
Several Important facts should be considered when reviewing any
results of the PRMS. First, the PRMS does not attempt to provide the
last or final word on the status of any AQCR. It is one tool that can
be used by the Regional Offices to assist them in the task of determining
the adequacy of the existing SIP. Regional Office personnel who have
day-to-day contact with the State and local agencies and are aware of
the many unique problems associated with an AQCR can provide the best
analysis of an AQCR. However, the PRMS can provide an indication of
-------
how the AQCR 1s progressing toward attainment of the air quality
standards based upon the air quality data available from SAROAD. Thus,
all "possible deficiencies" are just that, "possible." That 1s, they
require some further Investigation by those aware of any unique situa-
tions within the AQCR to determine the severity of the problem and what
type of corrective actions are required.
Second, because the system considers the applicable State and
Federal regulations, transportation control plans, and the Federal
motor vehicle control program in the development of the projected
emission/air quality curve, an AQCR will not be flagged if the observed
air quality is following the predicted path even though the air quality
is considerably above the applicable standard.
If no possible deficiencies are Identified or adequate progress Is
noted, it does not necessarily mean that the AQCR has attained the
standard nor does it necessarily mean that any relaxation should take
place in the implementation of the control programs outlined in the
SIP. The projected air quality curve is based on the assumption that
the local, State, or Federal agencies will continue Implementing their
regulations as prescribed. If this is accomplished, the air quality
data should reflect this enforcement by following the projected curve.
Thus, adequate progress indicates that the observed air quality data
are following the projected curve at this time and 1t appears that the
standards will be attained within the prescribed time frame. However,
the AQCR should remain under surveillance and all current program
activities associated with the AQCR, e.g., evaluation of the monitoring
sites locations, assurance of source compliance, etc., should continue.
-------
Third, the PRMS can only analyze the data currently within the
SAROAD system. Therefore, the analysis, in a number of cases, may be
less than current because of the incomplete implementation of the
quarterly reporting requirements for air quality data at this time.
However, as more States begin to implement the reporting requirements,
the system will be able to provide a more up-to-date analysis of the
AQCR and its progress toward attainment of the standards. It is
imperative to have the data in a timely fashion so that the analysis is
current and not a review of past history.
Fourth, it should also be noted that many AQCRs have less than
the minimum number of sites required in the SIP reporting sufficient
data for which any analysis can be performed. This is especially true
for sulfur dioxide, carbon monoxide and oxidants. Thus, for many of
the 67 AQCRs, the analysis for those pollutants may not be conclusive
until at least the minimum number of required sites are reporting
enough data for analysis and review. Consideration should be given to
the number of sites for which the analysis was performed compared to
the minimum number of sites required by the SIP before any conclusions
are made concerning the progress an AQCR is making. Many AQCRs that
at this time appear to be making adequate progress based on less than
the minimum number of monitors required may have severe SIP deficiencies
when the data from all the sites are available in sufficient quantity
for review.
A comparison of the initial analysis for the 17 AQCRs to the
current analysis indicates that, in general, States are submitting more
aerometric data, thus providing a larger air quality data base for
49
-------
review. In some cases, the increased data-base allowed for the
«
Identification of some additional possible deficiencies that were not
evident In the Initial analysis.
The results from the current analysis of 67 AQCRs Indicated four
principal types of problems: (1) limited data base, (2} localized
problem, (3) general problem, and (4) Increasing pollutant concentra-
tions.
The AQCRs with a limited data base resulted from having less than
the minimum number of sites required by the SIP. This was not a major
problem for particulate matter as only 8 of the 67 AQCRs had less than
the minimum number of sites currently reporting sufficient data for
analysis. However, this was not the case for sulfur dioxide; 32 of
the 67 AQCRs had less than the minimum number of monitoring sites
reporting sufficient data for analysis. Similarly, 14 of the 25 AQCRs
that were required to have carbon monoxide instruments had less than
the minimum number of sites required, and 18 of the 36 AQCRs that were
required to have oxidant Instruments had less than the minimum number
of sites required reporting sufficient data for analysis.
Possible deficiencies associated with total suspended par-
ticulates were noted in 51 of the 67 AQCRs analyzed. Some of these
deficiencies appear to be local in nature since the remainder of the
AQCR appears to be progressing as predicted. In addition, 65 of the
67 AQCRs have particulate concentrations above the national ambient
air quality standard.
Only 5 of the 67 AQCRs had possible deficiencies relative to
sulfur dioxide, and 9 AQCRs had values above the standards. As
50
-------
mentioned previously, however, almost 50 percent of the AQCRs analyzed
had less than the minimum number of sites required, and any general
conclusions on the status of sulfur dioxide would not be completely
accurate at this time.
Possible carbon monoxide deficiencies were noted 1n 13 AQCRs and
ox1dant deficiencies 1n 8. However, 29 of the AQCRs have values that
are currently above the national standards for carbon monoxide.
Nineteen (19) of the 36 AQCRs required to have oxldant Instruments
were above the standard. Again, It should be noted that almost 50 per-
cent of the AQCRs required to have carbon monoxide and oxldant monitors
had less than the minimum number of sites with sufficient data for
analysis. Additionally, four AQCRs that have a carbon monoxide Instru-
ment where no current SIP requirement exists have recorded values In
o
excess of the standard.
Two AQCRs have been noted as having possible deficiencies through-
out the AQCR, and further study should be Initiated to determine the
real extent of the problem.
To date, 8 AQCRs have reported pollutant concentrations that have
Increased over the past years. This problem appears to be local In
nature as only one or two sites in these AQCRs have shown Increases.
This problem relates primarily to particulate concentrations; however,
in a few areas, sulfur dioxide levels have also Increased slightly.
In general, the PRMS analysis Indicates that in most AQCRs
adequate progress appears to be being made for most sites; however,
8. Although only 25 of the 67 AQCRs required CO monitors, an additional
4 AQCRs had data; thus, the 29.
51
-------
no relaxation of any of the current ongoing programs should take place.
The possible deficiencies should be reviewed to determine their cause
and possible solution for that area of the AQCR where the deficiency
was noted. The status of sulfur dioxide, carbon monoxide, and oxldants
will require additional data to really assess the situation and
determine If possible deficiencies exist. However, for those areas
where a deficiency was noted, some work should begin to Investigate
the extent of the problem.
52
-------
SECTION 5 -ENFORCEMENT
OF STATE IMPLEMENTATION PLANS
In order to Implement the SIPs, the focus of Federal and State
activities needs to shift to ensuring compliance with approved emission
limitations through vigorous enforcement programs. The process of
ensuring compliance with the emission requirements In SIPs Is based
on the accomplishment of three major tasks:
1. Ensuring that affected sources are committed to a compliance
schedule containing Increments of progress.
2. Ensuring that the Increments of progress In the compliance
schedule are met in a timely manner.
3. Ensuring that sources Initially found in compliance or
sources that come into compliance continue to meet emission
requirements.
At the present time, the States and EPA are in the process of
completing the first of the three major tasks in achieving compliance -
the development of compliance schedules. Progress has been made in
ensuring compliance of major point sources. As of December 31, 1973,
EPA had Issued notices of violation to a cumulative total of 82 facili-
ties and abatement orders to 24 of these. In addition, some 930
Section 114 letters have been written and 600 inspections and 24
1. Clean Air Amendments of 1970, Public Law 91 604, December 31, 1970,
53
-------
source tests have been conducted by EPA to ascertain compliance status
of sources. These Investigations are expected to culminate In the
establishment of compliance schedules by either the State or EPA. The
goal 1s to attempt to achieve the EPA objective of having all point
sources either In compliance or on an approved, reasonable compliance
schedule by June 30, 1974.
However, the degree of compliance 1s not satisfactory to the EPA.
This 1s primarily due to the Inability of States and EPA to quickly
focus massive efforts Into plan enforcement. Adding to the complexity
of the task has been the contention by the utility Industry and others
that control technology for the abatement of sulfur oxides from fuel
combustion Is unavailable. During October and November 1973, EPA held
public hearings to Investigate the status of utility abatement programs
and availability of control measures. The following section Is a
special analysis of the compliance status of the electric utility
Industry.
STATUS OF POWER PLANT COMPLIANCE
From October 18 to November 2, 1973, EPA held a special public
hearing In the Washington, D. C., area to review the status of power
plant compliance with sulfur oxide (SO ) air pollution emission limlta-
^\ *
tlons. This hearing was called because power plants are the largest
source of SO emissions In the United States (emitting about 60 percent
^\
of total SO ), because large numbers of power plants are not yet in
^»
compliance with SO emission limitations, and because, in most cases,
^\
only 18 months remain under the established Implementation plans for
these plants to achieve compliance.
54
-------
There are about 970 fossil-fueled power plants In the United States
today having a combined generating capacity of about 302,000 megawatts.
Of this capacity, roughly 55 percent (166,000 megawatts) is produced by
coal-fired power plants, 17 percent (51,000 megawatts) by oil-fired
plants, and 28 percent (85,000 megawatts) by gas-fired plants. All gas-
fired plants are obviously now in compliance with SO emission require-
^\
ments. Some of the coal- and oil-fired plants were in compliance with
SO emission requirements when the requirements were adopted, and many
A
other plants have been or are now being brought into compliance by con-
verting to fuels having lower sulfur contents.
Switching to a low-sulfur fuel would seem to be the simplest route
to compliance with SO emission requirements. Coal washing and/or
^\
limited blending of present fuels with lower sulfur fuel would not be
required. However, use of supplies of low-sulfur western coal by plants
east of the Mississippi River would result in a failure to use readily
available high-sulfur eastern coal during a short-term fuel supply
crisis. The energy crisis will aggravate the existing shortage of low-
sulfur fuels. Since supplies of low-sulfur fuels will be Insufficient,
flue gas desulfurlzation (FGD) systems will be required on a large
number of power plants in order to achieve compliance with SO emission
^»
limitations. Use of FGD systems will enable power plants to meet
emission requirements while using Important high-sulfur fuel resources.
Many utilities have suggested that, rather than meet existing
SO emission requirements, they be allowed to use tall stacks and inter-
^t
mittent control systems (supplementary control systems) to achieve
ambient air quality standards. Such techniques rely upon the dispersion
55
-------
of pollutants Instead of the constant reduction of pollutant emissions.
As discussed In Section 2, EPA considers constant emission reduction
techniques, such as FGD, far superior to dispersion tecMnques and has
proposed regulations that limit the use of such dispersion techniques
to situations where constant emission reduction controls are not avail-
able. Dispersion techniques can, however, often be appropriately
required as Interim steps (to minimize the Impact of plant operation on
air quality) in schedules requiring compliance with emission limita-
tions.
Principal among the findings of the EPA hearing panel are the
following:
1. FGD technology must be Installed on large numbers of power
plants if SO emission requirements adopted pursuant to the
^\
Clean Air Act are to be met in the 1970's. Supplies of low-
sulfur fuels are now and will continue to be inadequate to
provide the sole means of complying with SO emission Hmita-
^\
tions.
2. With several noteworthy exceptions, the electric utility
industry has not aggressively sought out solutions to the
problems they argue exist with FGD technology.
3. Although most utility witnesses testified that FGD technology
was unreliable, that it created difficult sludge disposal
problems, and that it cost too much, the hearing panel found,
on the basis of utilities and FGD vendor testimony, that the
alleged problems can be, and have been, solved at a reasonable
cost. The reliability of both throwaway-product and saleable-
56
-------
product FGD systems has been sufficiently demonstrated on full-
scale units to warrant widespread commitments to FGD systems
for SO control at coal- and oil-fired power plants.
^k
4. The utility Industry has generally lacked a real Incentive
to develop FGD technology and to Install this technology where
needed to meet SO emission requirements.
^^
The hearing panel concluded that the electric utility industry
should:
1. Make immediate commitments to install FGD systems where
needed to meet SO emission requirements, giving priority to
A
those sources where controls are needed to meet primary ambient
air quality standards and new source performance standards.
2. Aggressively pursue FGD developmental programs to improve
reliability, to lower operating costs, and to advance FGD
technology that results in a saleable by-product.
3. Undertake further characterization and evaluation efforts on
sludge disposal, with emphasis on large-scale systems, to
assure the widespread applicability and effectiveness of
sludge disposal systems at reasonable costs.
4. Hire and train personnel with the skills needed to properly
design and operate FGD systems.
According to the panels, EPA and the States should:
1. Create a strong incentive for the installation of FGD systems
by establishing expeditious but reasonable compliance schedules
and by vigouously enforcing these schedules.
57
-------
2. Formalize procedures for dealing with unpreventable control
system malfunction where such formal procedures do not already
exist.
3. Urge State public utility commissions to treat Increased costs
from FGD control In the same manner as Increased fuel costs are
treated.
4. Consider such other methods of creating an Incentive to control
SO emissions as the Administration's proposed charge (tax) on
^%
SO emissions.
^%
The panel further concluded that compliance schedules established
by the utilities, States, and EPA should:
1. Be developed for each utility after considering the number and
types of plants requiring FGD systems and the need to properly
sequence Installations to preserve utility power reserves.
2. Give priority to Installation of FGD systems at those plants
where systems are needed to meet primary ambient air quality
standards and new source performance standards.
3. Require Installation of FGD systems at a rate commensurate
with vendor capacity.
4. Require, where feasible, the use of Interim control measures
such as Intermittent control systems 1n order to minimize the
Impact of SO emissions on air quality until FGD systems can
^
be Installed.
The Office of Enforcement and General Counsel (OEGC) and the
Regional Offices; of EPA have Initiated a program to carry out these
recommendations. In particular, basic data on each power plant are being
58
-------
gathered, and a strategy ts being developed to establish compliance
schedules for all utilities based on the priorities established.
ENFORCEMENT OF SIPs
During the semiannual period covered by this progress report, the
SIP enforcement activity of EPA has progressed from the planning and
strategy development phase to an active, functional level. The previous
o
report presented a detailed discussion of the development of enforce-
ment strategies and the various regulatory and litigation actions
available to EPA; this discussion will not be repeated here. Rather,
this report will focus on the outputs stemming from implementation of
these strategies and will cover the following four broad areas: (1)
establishment of reasonable compliance schedules for all major sources,
(2) surveillance and investigation programs to monitor compliance
schedules, (3) utilization of the automated Compliance Data System
(CDS) for managing compliance data, and (4) EPA enforcement actions to
keep sources in compliance or on complaince schedules.
Establishment of Compliance Schedules
During the first half of 1973, the primary emphasis of EPA's
enforcement program was to place major sources on compliance schedules
for meeting SIP requirements. As discussed in the previous report,
individual and categorical compliance schedules were promulgated by
States, and in cases where the State did not act, by EPA. Any source
whose emissions would violate applicable emission standards after
2. State Air Pollution Implementation Plan Progress Report, January 1
to June 30, 1973. U.S. Environmental Protection Agency, Research
Triangle Park, N. C. EPA-450/2-73-005. September 1973.
59
-------
January 1974 1s required to meet the Increments of progress In these
schedules (some 10,000 complying and noncomplylng point sources are
covered by these regulations). An additional 10,000 facilities are
subject to presently effective requirements, of which a large number
have been placed on some type of compliance schedule.
Although a large number of major sources have been placed on
schedules, a significant number of sources are known to require com-
1lance schedules, and determinations of compliance status have yet to
be made for many more. Compliance monitoring programs, addressed below,
are being Implemented to ensure compliance determinations are made for
all sources. As of December 31, 1973, approximately 3500 point source
facilities were still not on a reasonable schedule or In compliance.
Of these, schedules for 1600 point sources have been submitted by the
States and are in various stages of being approved by EPA in the
Federal Register. Table 5-1 provides detailed Information on the status
of compliance schedules in each State. A point source facility refers
to any facility having at least one emission point with an annual
potential emission greater than 100 tons per year of a criteria
pollutant.
For the remaining problem sources, one of the following mechanisms
must be used to establish these schedules:
1. State develops schedules and submits to EPA as plan revisions
If compliance date Is within attainment date set by approved
SIP.
2. State Issues enforcement orders establishing schedules and
submits to EPA for approval and/or joint enforcement action
60
-------
If necessary 1f compliance date 1s beyond attainment date In
SIP.
3. EPA Issues notice of violations and follows up with abatement
order.
If a violator cannot reasonably be expected to comply Immediately
with an applicable requirement and has been making a good-faith effort
to comply, Issuance of an order will normally be the most appropriate
action. The time allowed for compliance 1s required to be a reason-
able time, as determined by the Regional Administrator, taking Into
account the seriousness of the violation and any good faith efforts to
comply with applicable requirements. The person in violation will have
had or will have to be given an opportunity to provide Information on
this point at the statutorily required conference under Section
113(a)(4) of the Clean Air Act.
Monitoring Compliance
A major activity of air enforcement after the establishment of
reasonable compliance schedules 1s to keep sources on schedule and,
upon reaching final compliance, to ensure that sources remain in
compliance through proper operation and maintenance of the facility.
A program of compliance monitoring Including both paper surveillance
(citizen complaints, State semiannual reports, and Section 114 letters)
and field surveillance (Inspections, opacity observations, source tests,
etc.) 1s being Initiated 1n each Regional Office. The program will
concentrate on development of adequate Information to enable EPA to
fulfill Its role In monitoring State effectiveness In enforcing the
SIPs. It Is essential that all major point sources be Inspected
61
-------
Table 5-1.
POINT SOURCE COMPLIANCE STATUS, INVESTIGATIONS,
AND DATA SYSTEMS SUMMARY
r
£PA
Region
Sute
Region :
Connecticut"
Haine
Massachusetts*
Men Hampshire
anode Island
Vermont
-oul
Region II
New r0rkd
Men Jersey*
Puerto »ico
Virgin Islands
Total
Region III*
District Of
Columbia
OelaMre
Maryland
Pennsylvania
Virginia
West .trjtnia
"out
Region iv'J
Illinois
Indiana
Michigan
Minnesota
Ohio
Wisconsin
Total
Region «lk
Arkansas
Louisiana
Me» Ntiico
Oklahoma
Texas
Total
Region (II*
Nebraska
Io»a
Kansas
Missouri
Total
Region »III
Colorado
Montana
North Dakota
South Dakota
Utah
MyoBlng
Total
Region |i"
Arliona
California
Nevada
American Uno*
Total
Alaska
Idaho
Oregon
Mashing ton
Total ,
0'
Facilities
177
99
271
30
69
32
673
460
2S8
107
9
8S4
44
54
168
1.142
208
288
1.904
1.103
777
771
1.060
1.46S
2.026
471
$60
S.233
342
243
233
18$
450
'«'
1.594
164
201
92
91
1.500
2.048
22
129
244
128
523
94
39
SO
97
46
$4
380
263
1.560
172
64
8
15
2.082
21
60
334
330
74$
VCTE >» footnotes >' tfv
In
compliance
90
78
223
29
60
26
506
270
46
29
4
349
2
42
90
902
98
41
1.175
236
244
696
421
83
677
173
304
2.834
142
70
164
55
96
77
604
32
65
82
81,
1.480'
1.760
10
80
217
73
360
80
23
17
16
30
_JL_
199
HO,
1.473°
143
57
8
10
1. 181
2
a
. '**
.' 293
ne
-------
periodically by the responsible State or local agencies to ensure con-
tinuing compliance by sources. EPA Intends to Inspect a selected number
of major facilities as part of Its field surveillance effort. A point
source facility will not be considered in compliance unless a defini-
tive determination of that fact has been made by the State or EPA.
Table 5-1 presents the current status of Investigations undertaken
by EPA during the semiannual period covered by this report. It 1s
noted that the compliance status of sources, particularly for those
Indicated as 1n compliance In Table 5-1, has not been verified by
actual Inspection or other Investigations for many facilities. Thus,
EPA 1n cooperation with the States, Is Initiating a major effort in
compliance monitoring to definitively determine compliance status of
sources.
Compliance Data System
A program of compliance monitoring to determine affected sources
and their compliance status Is being initiated 1n each Regional Office.
Volnt sources and otter sources.
*The number of Identified point source fee 111 ties end their compliance status in Connecticut end Massachusetts Is suspect. Investigations ere under-
pay to determine the compliance status of sources In these Sutes
'Coamctlcut's COS source sire designations have not yet been entered Into the system.
"Point sources for NM Tort and Men Jersey are considered to be underestimated Number of sources and compliance status In MM Tort are particularly
suspect. CM hat Initiated a cooperative program with Nov York State to develop more accurate source Information.
'Although no schedules for Region III nere approved this period, a large number have been submitted and approval Is expected during the neit seml-
1 period.
'compliance Information on sources for Uest Virginia had not been provided by the State as of December 31. 1971. This Information Is expected toot
available for the neit semiannual progress report.
*A11 numbers for Region IV represent emission points, not source facilities
Compliance schedules submitted; EPA approval expected during neit semiannual period Alabama 779, Florida 477. Ceergla 3S, Mississippi 623.
Kentucky 174. North Carol 1n» 38. South Carolina t. and Tennessee 111.
Vll approved schedules In Region V uere promulgated by EPA Visible emission observations apply to emission points, not point sources
^Compliance schedules submitted; EPA approval eipected during next semiannual period: Indiana 28. Michigan 47. Minnesota 24. Ohio 80. and tflscon-
sle CO.
'compliance schedules submitted. EM approval eipected during neat semiannual period- Arkansas 132. Louisiana 61. New Mexico S. Oklahoma 10. and
Texas U.
'The number of sources designated as In compliance In Texas Is unusally high and Kill need to be verified by field Investigations.
"Compliance schedules for emission points (not facilities) submitted and CPA approval pending- Nebraska 22. low 90. Kansas 208. and Missouri 16.
"Compliance schedules submitted. EPA approval expected during neit semiannual period: Arizona 32, California 37. Htwll 3S. and Nevada 10.
°n» number of point sources In compliance In California has not been verified In all cases.
lM tvmmUtee; CM approval wpecteB during nut scBlaaottt period: Idthe ». Oremem 1C. jmd mUhtimjtM 7>.
63
-------
This program concentrates on the development of adequate source Informa-
tion to follow the States' progress In enforcing their SIPs.
OEGC has developed a computer system known as the Compliance Data
System (CDS), which has been 1n operation since June 1973. The CDS
1s not a data system, as such, but an enforcement management system.
It Is designed to assist Regional Office programs by performing the
following functions:
1. Provide statistical breakdowns of State enforcement progress
and produce source listings by compliance status, industrial
category, emission potential category, geographic location,
and/or pollutant in order that State enforcement strategies
may be developed and revised.
2. Ease the State burden of reporting enforcement progress semi-
annually through the use of simple questionnaires, tailored
to the actions the States should have monitored over the
preceding 6-month period.
3. Provide a means for managing numerous enforcement actions by
furnishing summaries of EPA-to-source Interactions, writing
form letters, tracking increments of progress or other dates
pertaining to enforcement, assisting in assigning work loads
such as inspection and source observations to personnel, and
producing summaries of future and overdue work actions.
4. Provide a summary of State enforcement actions that result
in civil or criminal penalties and a summary of EPA enforce-
ment activities including Inspections, source tests, notices
of violation, abatement orders, and civil/criminal actions.
These summaries have been designed to reflect in a meaning-
ful way both the States' and EPA's efforts toward Implement-
Ing the requirements of the SIPs.
64
-------
The present status of CDS is that of both expanding and refining
the basic inventory of source and compliance information while
evolving to provide faster and more versatile reporting capabilities.
Some assistance has been provided to a few Regional Offices to aid
their efforts in the startup of the system in those Regions. Within
the next few months, a great deal more assistance will be provided to
those Regions requiring help so that they can complete the startup
phase of system operations.
The CDS master file, which is maintained and updated by the
Regions through computer terminals and regular weekly updates, as of
January 23, 1974, included about 4000 point source facilities, which
is about 30 percent of the total number of point source facilities in
the nation. Depending on the Region and State, the quantity and
quality of this information varies greatly. To some extent, these
characteristics reflect the amount of effort being devoted to system
implementation in each Region.
Based on estimates provided to the Division of Stationary Source
Enforcement by the Regions in January 1974, the number of facilities
that could potentially emit 100 tons per year of a pollutant versus
those currently on CDS is shown by Region and State in Table 5-1.
Enforcement Actions
It is EPA's policy that violations of approved implementation plans
be promptly prosecuted either by the appropriate State or local agency
or by EPA. It is the intent of Congress that the Federal government
should defer to a State agency when such agency is moving effectively
to abate a source that is in violation of the SIP. However, a notice
of violation triggering Federal enforcement will be issued whenever it
appears that a State cannot or will not take effective abatement action
65
-------
within a reasonable period of time. In some cases, where a State
agency Is willing to enforce but lacks the resources to do so. EPA will
support the State with technical assistance rather than Initiate
Independent action.
It should also be remembered that SIPs do represent requirements
of Federal law and that EPA has ultimate responsibility for their
enforcement. Where serious violations have occurred, Federal enforce-
ment action may have more Impact and may be required to provide
adequate assurance of future compliance. EPA enforcement action In
such cases does not Imply that the State agency has failed to perform
Its responsibilities.
Regional Offices have the primary responsibility for the Initia-
tion and conduct of enforcement actions under Section 113 of the Clean
Air Act. Notices of violation are Issued by the Regional Administrator
In accordance with guidance and policy established by EPA's Assistant
Administrator for Enforcement and General Counsel.
USE OF SECTION 114
Section 114(a)(1) of the Clean A1r Act enables the Administrator
to require owners or operators of emission sources "to (A) establish
and maintain such records, (B) make such reports, (C) Install, use, and
maintain such monitoring equipment or methods, (0) sample such emissions
(1n accordance with such methods, at such locations, at such Intervals,
and In such manner as the Administrator shall prescribe, and (E) provide
such other Information, as he may reasonably require." Section 114(a)(2)
authorizes right of entry for certain purposes and the right of the
Administrator to sample emissions.
Section 114(a}(11) provides that the Administrator may require the
owner or operator of any source to provide Information for the purpose
66
-------
of determining "whether any person Is 1n violation of any such standard
or any requirement of such a plan." This 1s one of the most Important
enforcement tools under the Clean Air Act, In that the source can be
required to provide the information that may be the basis for enforce-
ment action by EPA. Regions are urged to make extensive use of
Section 114 for enforcement purposes since this is usually the most
effective method of obtaining the necessary information to begin an
enforcement action.
Section 114(a)(2) enables the Administrator or his authorized
representative to enter a source so that EPA can do its own monitoring,
sampling, inspecting, or copying of records. This authority also can
be used to determine whether a source is carrying out any obligations
Imposed on it by EPA under Section 114(a)(l).
Where a State has been delegated Section 114 authority from EPA,
the same authority EPA has to monitor, sample, Inspect or copy records,
and any other authority under Section 114(a)(l) and (2) of the Clean Air
Act can, in like manner, be exercised by the State. No representative
of EPA need accompany the State officials.
USE OF SECTION 113
Section 113 of the Clean Air Act provides for Federal enforcement
1n cases of violation of a Federal standard or any requirement of a
Federally approved SIP.
In the case of a violation of a provision of a Federally approved
SIP, the Administrator must first issue a notice of violation, unless
the Administrator has declared that State in which the violation
occurred to be 1n a "period of Federally assumed enforcement." (Federally
assumed enforcement, under which Federal enforcement procedures are
67
-------
more expeditious, Is appropriate whenever a State falls generally to
enforce an Implementation plan effectively.) Thirty days after the
Issuance of a notice of violation, the Administrator may Issue an order
or bring a civil action.
He may also Issue an order or bring a civil action In the case of
a violation of a new source performance standard or an emission standard
for a hazardous air pollutant. No notice of violation Is required In
such cases.
In addition, Section 113 makes 1t a criminal offense for any
person to knowingly violate any requirement of an applicable Imple-
mentation plan more than 30 days after Issuance of the notice of
violation (or at any time during a period of Federally assumed enforce-
ment). Criminal penalties are also provided for knowingly falling to
comply with any order of the Administrator, or for knowingly violating
a new source performance standard or an emission standard for a
hazardous air pollutant.
The criminal penalties provided under Section 113 are a fine of
not more than $25,000 per day of violation, Imprisonment for not more
than 1 year, or both. For any subsequent conviction, the penalties are
a fine of up to $50,000 per day of violation, Imprisonment for not
more than 2 years, or both.
Table 5-2 details each enforcement action taken by EPA since the
approval of SIPs. The next semiannual progress report Is expected to
show a significant Increase 1n such actions.
68
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Table 5-2. SUMMARY OF EPA AIR ENFORCEMENT ACTIONS, MAY 1972-JANUARY 1974
Company/type
of source
Location Pollution problem Type of action
Results or status
Allied Chemical Corp./ Claymont,
sulfurlc add plant Delaware;
Region III
Delmarva Power and
Light Company/
steam generator
Delaware City,
Delaware;
Region III
Violation of Dela-
ware mass
emission rate
regulations.
Notice of violation
Issued May 24, 1972.
Order to comply
Issued July 20,1972.
Violation of
Delaware regula-
tion requiring the
use of fuel con-
taining not In ex-
cess of 3.5 per-
cent sulfur.
Notice of violation
Issued March 6,
1972. Order to com-
ply Issued April 17,
1972.
Commencing on October 10, 1972, bi-
monthly progress reports have been
submitted to EPA. Information sub-
mitted to EPA on the construction
of an emission control facility to
comply with the regulations had re-
sulted in a construction schedule
with Increments of progress being
established. .Said schedule 1s
presently being complied with by
Allied Chemical Corp.
At the conclusion of litigation In-
stigated by Getty 011 Company for a
court order restraining enforcement
of the fuel sulfur content regula-
tion, the order to comply was up-
held. (The Interest of Getty Oil
Co. in this matter arises from a
contractual arrangement between
Delmarva Power and Light Co. and
Getty 011 Co. under which Getty pro-
vides Delmarva Petroleum coke for i
fuel 1n exchange for electricity.)
Getty Oil Co. (Eastern Operations)
vs. Ruckelshaus (342 F. Suppl. 1006;
467 F. 2d. 349; Jan. 15, 1973).
Source is presently in compliance.
-------
Table 5-2 (continued). SUMMARY OF EPA AIR ENFORCEMENT ACTIONS, MAY 1972-JANUARY 1974
Comoany/type
of source
Location Pollution problem Type of action
Result or status
of Woonsocket/
open burning
Woonsocket»
Rhode Island;
RepIon I
City of Newport/
open burning
Newport,
Rhode Island;
Region I
City of Mlddletown/
open burning
Mlddletown,
Rhode Island;
Region I
Open burning at Notice of violation
municipal refuse Issued on Feb. 7,
disposal facility 1973. Order to corn-
In violation of ply Issued July 7,
Rhode Island regu- 1973.
1 atIons.
Violation of Notice of violation
Rhode Island regu- Issued Oct. 23,
latlon prohibiting 1972. Order to corn-
open burning at ply Issued Jan. 11,
public refuse d1s- 1973.
posal sites and -
prohibiting the
emission of harm-
ful contaminants.
Violation of
Rhode Island regu-
lation prohibiting
open burning at
public refuse dis-
posal sites and
prohibiting the
emission of harm-
ful contaminants.
Notice of violation
Issued Oct. 13,
1972. Conference
held between EPA
and Mlddletown
officials Nov. 6,
1972.
On March 7, 1973, a conference was
held with representatives of the
city, who agreed to cease all open
burning of debris except that gener-
ated by Department of Housing and
Urban Development (HUD). Region I
1s attempting Informally to assist
HUD in the resolution of Its dis-
posal problems.
The Newport refuse disposal site Is
under surveillance, and pursuant to
Section 113, judicial proceedings
are authorized If further violations
of the regulations occur. Present-
ly 1n compliance.
Presently in compliance with regula-
tions, but order to comply will be
Issued 1f future violations occur.
-------
Table 5-2 (continued). SUMMARY OF EPA AIR ENFORCEMENT ACTIONS, MAY 1972-JANUARY 1974
Company/type
of source
Location Pollution problem Type of action
Result or status
Texaco, Inc./
petroleum manufacture
and distribution
Massachusetts;
Region I
American Barrel Co./ Massachusetts;
drum reclamation Region I
furnace and Incinerator
Northeast Utilities Massachusetts;
Service/steam generator Region I
Selling fuel with
higher sulfur con-
tent than permit-
ted- under Massa-
chusetts regula-
tions.
Operation of drum
reclamation fur-
nace violating
Massachusetts
regulations re-
garding open
burning, visible
emissions, and
general air pol-
lution.
Burning fuel with
a higher sulfur
content than per-
mitted under Mas-
sachusetts regu-
lations.
Notice of violation
Issued Feb. 1, 1973.
Notice of violation
Issued Mar. 15,
1973. Administra-
tive order Issued
Sept. 18, 19/3.
Notice of violation
Issued Mar. 16,
1973.
On Feb. 12, 1973, pursuant to a Sec-
tion 114 letter, Texaco met with
Region I personnel and provided In-
formation with respect to fuel avail-
ability and demand. Since this meet-
ing Texaco has ceased Its violation.
Presently In compliance with order.
Presently in compliance with regula-
tion.
-------
Table 5-2 (continued). SUMMARY OF EPA AIR ENFORCEMENT ACTIONS, MAY 1972-JANUARY 1974
Company/type
of source
Location Pollution problem Type of action
Result or status
U.S. Steel Corp.,
Gary Works, and Uni-
versal Atlas Cement,
BuffIngton Harbor
Plant/steel mill and
cement plant
Gary, Indiana; Operation of a
Region V
steel mill with
cement production
facilities 1n vio-
lation of Indi-
ana's regulations
regarding visible
emissions, com-
bustion for In-
dustrial heating,
and process oper-
ations.
Notice of violation
Issued April 18,
1973. Order to
comply Issued June
22, 1973.
Uabash Smelting Corp./
secondary aluminum
plant
H.N. Hartwell and
Son, Inc./ petroleum
distributor
Union Petroleum
Corp./'petroleum
distributor
Indiana; Violation of Indi-
Region V ana regulations
for visible emis-
sions and process
operations.
Massachusetts; Selling fuel with
Region I a higher sulfur
content than
permitted under
Massachusetts
regulations.
Massachusetts
Region I
Selling fuel with
a higher sulfur
content than
permitted under
Massachusetts
regulations.
Notice of violation
Issued Mar. 28,
1973. Order to
comply Issued May
30, 1973.
Notice of violation
Issued March 16,
1973.
Notice of violation
Issued March 16,
1973.
U.S. Steel requested U.S. District
Court, Hammond, Indiana, for a
stay of the order and declaratory
judgments to void order. EPA.
counterclaimed to enforce the
terms of the order (first Incre-
ment past) on August 15, 1973.
U.S. District Court denied U.S.
Steel's motion to stay and will
hold hearing on the merits of
declaratory judgment for those
Issues not dismissed. EPA has
entered Into settlement discus-
sions with U.S. Steel to obvi-
ate necessity for hearing on
merits.
Presently 1n compliance with terms
of the order.
Presently 1n compliance with regula-
tions.
Presently in compliance with regu-
lations.
-------
Table 5-2 (continued). SUMMARY OF EPA AIR ENFORCEMENT ACTIONS, MAY 1972-JANUARY 1974
Company/type
of source
Location Pollution problem Type of action
Result or status
Central Electric Power
Cooperatlve/power
plant
Hercules, Inc.,
Missouri Chemical
Works/fertilizer
manufacturer (ammon-
ium nitrate and urea
processes)
Asarco/prlmary
lead smelter
Centropolls Crusher,
Inc./stone crusher
City of Lawrence/
open burning
Jefferson City, Power company re-
Missouri; fused to submit
Region VII Information re-
quested In Sec-
tion 114 letter.
Louisiana,
Missouri;
Region VII
Glover,
Missouri;
Region VII
Kansas City,
Missouri;
Region VII
Lawrence,
Massachusetts;
Region I
Operation of
facility 1n vio-
lation of Mis-
souri particu-
late matter requ-
1ations regarding
process opera-
tions.
Violation of Mis-
souri S02 regula-
tions.
Refused to sub-
mit information
required in Sec-
tion 114 letter.
Violation of
Massachusetts
open burning
regulation.
Administrative
order Issued
May 2, 1973.
All the information required in the
administrative order has been pro-
vided.
Notice of violation Presently in compliance with terms
issued May 16, of order.
1973. Order to com-
ply Issued Oct. 15,
1973.
Notice of violation
issued July 2,
1973. Administra-
tive order issued
Oct. 23, 1973.
Order issued or.
June 6, 1973.
Notice of violation
issued June 6, 1973
On November 19, 1973, Asarco re-
quested U.S. District Court,
Kansas City, Missouri to stay the
order. Oral arguments will be
held if EPA and Asarco cannot
settle case out of court.
All Information required in the
order has been provided.
-------
Table 5-2 (continued). SUMMARY OF EPA AIR ENFORCEMENT ACTIONS, MAY 1972-JANUARY 1974
Company/type
of source
Location
Pollution problem Type of action
Result or status
South California
Edison. Mohave
Power Plant
City of Bristol/
open burning
Kalbab Industries/
wood waste burners
Western P1ne Indus-
tries/wood waste
burners
Western Moulding
Co., Inc./wood
waste burners
j
Wllfret Brothers
Realty Trust/
Incinerator
Nevada;
Region IX
Bristol,
Rhode Island;
Region I
Payson,
Arizona;
Region IX
Snowflake,
Arizona;
Region IX
Snowflake,
Arizona;
Region IX
*
Arlington,
Massachusetts;
Region I
Violation of State Notice of violation
visible emission Issued July 25,
regulations and 1973; order to com-
S02 emission ply Issued Nov. 1,
limits. 1973.
Open burning at
municipal refuse
disposal facility
1n violation of
Rhode Island
regulations.
Violation of
Arizona visible
emission regula-
tions.
Violation of
Arizona visible
emission regula-
tions.
Violation of
Arizona visible
emission regula-
tions.
Violation of
Massachusetts
regulations on
Incinerators.
Notice of violation
Issued April 23,
1973.
Notice of violation
Issued July 24,
1973. Administra-
tive order Issued
Sept. 26, 1973.
Notice of violation
Issued July 24,
1973.
Notice of violation
Issued July 24,
1973.
Notice of violation
Issued July 2,
1973. Administra-
tive order Issued
Nov. 30, 1973.
Presently 1n compliance with terms
of order.
Presently 1n compliance with terms
of order.
Presently 1n compliance with terms
of order.
-------
Table 5-2 (continued). SUMMARY OF EPA AIR ENFORCEMENT ACTIONS, MAY 1972-JANUARY 1974
Company/type
of source
Location
Pollution problem Type of action
Result or status
en
Penn Central Trans. Massachusetts;
Company/passenger and Region I
freight terminals
Independent Stave Co., Lebanon,
Inc./boilers, cyclones, Missouri;
tepee burner, and Region VII
Incinerator
Bethlehem Steel Corp.,
Bums Harbor Plant/
steel mill
Chesterfield,
Indiana;
Region V
Kaiser Steel Corp./
steel mill
Fontana,
California;
Region IX
Transfer of cement
products creating
visible emissions
problem and trucks
Idling contrary
to requirements of
Massachusetts
SIP.
Violation of Mis-
souri participate
matter (process
emissions) and
visible emissions
regulations.
Violation of
Indiana visible
emission and par-
ti cul ate emis-
sions (process
weight; regula-
tions.
Violation of
California visi-
ble emission and
S0 regulations
standard).
Notice of violation
Issued July 2, 1973.
Notice of violation
Issued July 9,
1973. Supplemental
notice of violation
Issued Oct. 10,
1973. Order to
comply on first
notice Issued Oct.
16, 1973.
Notice of violation No order Issued since three
Issued July 11, 1973. sources presently In compli-
ance and coke ovens on satis-
factory State order.
Notice of violation
Issued Aug. 7, 1973.
-------
Table 5-2 (continued). SUMMARY OF EPA AIR ENFORCEMENT ACTIONS, MAY 1972-JANUARY 1974
Company/type
of source
Location
Pollution problem Type of action
Result or status
Eight wood waste
burners
Seaboard Foundry,
Inc./gray Iron
foundry
Inland Steel Co./
Integrated steel
mill
Youngstown Sheet and
Tube Company/ Integra-
ted steel mill
Roberts Construction
Company/1Imestone
quarrying and
crushing
Missouri Power and
Light Company/power
plant
Mendodno and
Northern Sono-
ma County,
California;
Region IX
Johnston,
Rhode Island;
Region I
East Chicago,
Indiana;
Region V
East Chicago,
Indiana;
Region V
Sundance,
Wyoming;
Region \llll
Violation of Callfor- Notice of violation
n1a visible emission Issued Aug. 15,
regulations. 1973.
Violation of
Rhode Island
visible emissions
and participate
emissions (process
weight) regulations.
Violation of Indiana
visible emissions
from combustion for
Industrial heating
and process opera-
tions regulations.
Violation of Indiana
visible emissions
from combustion for
Industrial heating
and process opera-
tions regulations.
Violation of ambient
air standard for
total suspended par-
ti culates as pro-
vided 1n Wyoming
SIP.
Jefferson City, Refused to submit
Missouri; Information re-
Region VII quired in Section
114 letter.
Notice of violation
Issued Aug. 1, 1973.
Notice of violation At present time, no further
Issued July 18, 1973. Federal action anticipated since
cited sources either on enforce-
able State schedule or currently
In compliance.
Notice of violation
Issued July 18, 1973.
Notice of violation Presently 1n compliance with
Issued Aug. 16, 1973. terms of order.
Order to comply
Issued Sept. 28,
1973.
Administrative
order Issued
Aug. 1, 1973.
Source complied with terms
of order.
-------
Table 5-2 (continued). SUMMARY OF EPA AIR ENFORCEMENT ACTIONS, MAY 1972-JANUARY 1974
Company/type
of source
Location
Pollution problem
Type of action
Result or status
J. Edward Moran
Generating Station,
City of Burlington,
Elec"*1c ».1ght Dept./
boilers (power plant)
Atlantlc-Kichfleld
Corporation/oil
refinery
Mobil 011 Corpora-
tion/oil refinery
-vi American 011
"** Company/oil
refinery
Borden, Inc./
phosphate plant
Burlington,
Vermont;
Region I
East Chicago,
Indiana;
Region V
East Chicago,
Indiana;
Region V
Whiting,
Indiana;
Region V
Palmetto,
Florida;
Region IV
Violation of Vermont Notice of violation
participate matter issued on Aug. 14,
and visible emissions 1973.
regulations.
Violation of Indiana Notice of violation
SO? regulation (ARC- issued Sept. 10,
1973.
SO? i
13).
Source in compliance.
Source in comollance,
Violation of Indiana Notice of violation
SOg (APC-13) and vis- issued Sept. 10,
ible emission (APC- 1973.
3) regulations.
Violation of Indiana Notice of violation
S02 (APC-13) and vis- issued Sept. 10,
1ble emissions (APC- 1973.
3) regulations.
Refused to submit in- Administrative order Source complied with administra-
formation required in issued Aug. 17, 1973. tive order by submitting required
Section 114 letter. " data.
(NSPS development).
-------
Table 5-2.(cont.). SUMMARY OF EPA AIR ENFORCEMENT ACTIONS, MAY 1972-JANUARY 1974
Company/type
of source
Location Pollution problem Type of action
Results or status
New England Power Com- Somerset, Mas- Violation of Mas- Notice of violation
pany, Brayton Point
Power Station
Alpha Portland Cement
Company/clinker
cooler
U. S. Gypsum Company/
mill rock process,
shingle finish pro-
cess, packing process
Sullard Castings,
Inc./cupola furnaces
sachusetts;
Region I
Afften, Mis-
souri ;
Region VII
East Chicago,
Indiana;
Region V
Bridgeport,
Connecticut
Region I
sachusetts general Issued Sept. 6, 1973.
regulation to pre-
vent air pollution
and visible emis-
sion regulations.
Violation of M1s- Notice of violation
sourl, part1cu1ate Issued Sept. 28,
matter (process 1973.
weight) regula-
tion.
Violation of Ind1- Notice of violation
ana participate Issued Oct. 5, 1973.
matter (process
emission APC-5)
and visible emis-
sion (ARC-3) reg-
ulations.
Violation of Con-
necticut partleu-
late matter (pro-
cess emissions,
visible emissions,
and fugitive dust)
regulations.
Notice of violation
Issued Oct. 12, 1973,
-------
Table 5-2 (continued). SUMMARY OF EPA AIR ENFORCEMENT ACTIONS, MAY 1972-JANUARY 1974
Company/type
of source
Location
Pollution problem
Type of action
Result or status
U.S. Gypsum Co./ Wabash,
mineral wool processes: Indiana;
cupolas, blow chambers, Reqlon V
curing oven, asphalt
frame control
C.F. Industries/
ammonium nitrate
pulling process
Universal Atlas
Cement/cement
process
Cities of Lament,
Dayton, Connell, and
Oakesdale and Whit-
man County, Wash-
ington
NIPSCO Ballly State/
power plant boilers
West Penn Power Co.,
Mitchell State
Public Service Co.
of Indiana
Wabash River Station
Terre Haute,
Indiana;
Region V
Hannibal,
Missouri;
Region VII
Washington;
Region X
Gary,
Indiana;
Region V
Violation of Indiana
particulate matter
(process emission,
APC-5) regulations.
Violation of Indiana
particulate matter
(process emissions,
APC-5) regulations.
Refused to submit
Information re-
quested by Section
114 letter.
Violation of Wash-
ington open burn-
Ing regulations.
Violation of Indiana
S0« regulations
(Aft-13).
Courtney Violation of Penn-
(Wash. County), sylvanla SOX and
Pennsylvania; particulate matter
Region III regulations.
Terre Haute,
Indiana;
Region V
Violation of Indiana
SOX regulation
(APC-13).
Notice of violation
Issued Oct. 5, 1973.
Notice of violation
Issued Oct. 9, 1973.
Administrative order Source complied with terms of
Issued Oct. 1, 1973. order.
Notice of violation
Issued Sept. 21,
1973.
Notice of violation
Issued Sept. 13,
1973.
Notice of violation
Issued Sept. 13,
1973.
Administrative order pending.
Seventh Circuit decision.
Conference held on October 18,
1973.
Notice of violation Administrative order pending.
Issued Sept. 13, Seventh Circuit decision.
1973.
-------
Table 5-2 (continued). SUMMARY OF EPA AIR ENFORCEMENT ACTIONS, MAY 1972-OANUARY 1974
Company/type
of source
Location
Pollution problem
Type of action
Results or status
Can-Tex Industries,
Inc./clay shale
grinding and
storage
Pacific Company,
Washington Dump,
Peninsula Disposal
Service
U.S. fypsum/plaster
and panel
Container Corp. of
.America/boilers
Kleffer Paper Mill/
boilers
Cannellon,
Indiana;
Region V
Long Beach
(Pacific
County),
Washington;
Reqlon X
Shoals,
Indiana;
Region V
Wabash,
Indiana;
Region V
Brownstown,
Indiana;
Reqlon V
Violation of Indiana
particulate matter
(process emission,
ARC-5) regulations.
Violation of Wash-
ington open burn-
Ing regulations.
Violation of Indiana
particulate matter
(process emission,
APC-5) regulations.
Violation of Indiana
particulate matter
from combustion of
fuel for Indirect
heatlnq (APC-4R)
and S02 (APC-13)
regulations.
Violation of Indiana
particulate matter
from combustion of
fuel for Indirect
heating (APC-4C)
regulations.
Notice of violation
Issued Oct. 17,
1973.
Notice of violation
Issued Oct. 17,
1973.
Notice of violation
Issued Oct. 5, 1973
Notice of violation
Issued Oct. 9,
1973.
Notice of violation
issued Oct. 12,
1973.
-------
Table 5-2 (continued). SUMMARY OF EPA AIR ENFORCEMENT ACTIONS, MAY 1972-JANUARY 1974
Comoany/tyne
of source
Location
Pollution problem
Type of action
Results or status
Central Soya
Company/boilers
Indiana University
Physical Plant/
power plant
International Har-
2 vester Co./boilers
Apache Powder Co./
nitric acid plant;
solid waste and
open burning
Mid-Continent
Asphalt and
Paving/asphalt
and paving
facility
Indianapolis,
Indiana;
Realon V
Bloomlngton,
Indiana;
Realon V
Indianapolis,
Indiana;
Realon V
Benson,
Arizona;
Realon IX
Parkvllle,
Missouri:
Region VII
Violation of Indiana
particulate matter
from combustion of
fuel for Indirect
heatlnq (APC-4R)
regulations.
Violation of Indiana
particulate matter
from combustion of
fuel for indirect
heating (APC-4R)
regulations.
Violation of Indiana
particulate matter
from combustion of
fuel from indirect
heating regulations.
Violation of Arizona
visible emission,
open burning, and
NOX emission from
existing nitric add
plant regulations.
Violation of Missou-
ri visible emission
regulation.
Notice of violation
issued Oct. 12,
1973.
Notice of violation
issued Oct. 24,
1973; administra-
tive order issued
Jan. 8, 1974.
Notice of violation
issued Oct. 26,
1973.
Notice of violation
issued Nov. 13,
1973.
Notice of violation
Issued Oct. 19,
1973.
Presently in compliance with terms
of order.
-------
Table 5-2 (continued). SUMMARY OF EPA AIR ENFORCEMENT ACTIONS, MAY 1972-JANUARY 1974
Company/type
of source
Location
Pollution problem
Type of action
Results or status
United States Steel,
Clalrton Coke Works/
coke ovens
Bloomington Crushed
Stone Co., Inc./
quarry
The Heston Paper
and Manufacturing
Co./boilers
Dana Corporation/
cupolas
Columbia Mater and
Light Department/
boilers
Clalrton,
Pennsylvania;
Region III
Bloomington,
Indiana;
Region V
Terre Haute,
Indiana;
Region V
Richmond,
Indiana;
Region V
Columbia,
Missouri;
Region VII
Notice of violation
Issued Nov. 8, 1973
Violation of visible
emissions and parti-
culate matter emis-
sions regulations
(regulations are re-
sult of Pennsylvania
plan revision Incor-
porating consent de-
crees Into plan).
Violation of Indiana
visible emission and
Dart1culate matter
(process emission)
regulations.
Violation of Indiana
particulate matter
from combustion of
fuel for Indirect
heating and SOX
requlatlons.
Violation of Indiana
visible emission and
particulate matter
from existing found-
ry regulations.
Source did not test Administrative order
boilers 6 and 7 with- Issued Aug. 8, 1973.
In 2-month extension
given by Regional
Office as required
1n Section 114
letter
Notice of violation
Issued Oct. 31,
1973.
Notice of violation
Issued Nov. 9, 1973.
Presently 1n compliance with
regulation.
Notice of violation
Issued Oct. 30,
1973.
-------
Table 5-2 (continued). SUMMARY OF EPA AIR ENFORCEMENT ACTIONS, MAY 1972-JANUARY 1974
Company/type
of source
Location
Pollution problem
Type of action
Results or status
Foster Forbes Glass
Co./glass manufac-
turer
Hamilton County
Asphalt, Inc./
asphaltlc con-
crete
National Starch
and Chemical Corpo-
ration/boiler house
Lehlgh Portland Ce-
ment Company/kiln
coolers
Republic Steel Corp./
coke ovens
Marlon,
Indiana;
Region V
Logansport,
Indiana;
Region V
Indianapolis,
Indiana;
Region V
Mitchell,
Indiana;
Realon V
Chicago,
Illinois;
Region V
Chicago,
Illinois;
Region V
International Har-
vester Co., Wiscon-
sin Steel Division/
coke ovens
Colonial Brick Corp./ Cayuqa,
brick manufacturing Indiana;
processes: dryer, Region V
grinder, curing kilns,
and storage
Source refused re-
quested Informa-
tion as required
in Section 114
letter.
Violation of Indiana
particulate matter
emissions regulation
(APC-5).
Violation of Indiana
parti oil ate matter
and SOX regulations.
Violation of Indiana
Dartlculate matter
emission regulations.
Violation of Federal
compliance schedule
for coke oven push-
ing and quenching.
Violation of Federal
compliance schedule
for coke oven push-
1ng and quenching.
Violation of Indiana
particulate matter
regulation.
Administrative order
Issued Nov. 21, 1973.
Notice of violation
Issued Nov. 19,
1973.
Notice of violation
Issued Nov. 19,
1973.
Notice of violation
Issued Nov. 26,
1973.
Notice of violation
Issued Nov. 29,
1973.
Notice of violation
Issued Nov. 29,
1973.
Notice of violation
Issued Dec. 4, 1973.
The company has requested a con-
ference pursuant to Section 113
(a)(4) of the Clean A1r Act.
-------
Table 5-2 (continued). SUMMARY OF EPA AIR ENFORCEMENT ACTIONS, MAY 1972-JANUARY 1974
Company/type
of source
Location
Pollution problem
Type of action
Results or status
Magaw Construction,
Inc./aspha1t1c con-
crete
Central Illinois
Light Company,
R.S. Wallace Sta-
tion/boilers
_ Aluminum Company of
~ America (ALCOA)/
aluminum smelter
Blaw-Knox Foundry
and Mill Machinery,
Inc./open hearth
furnace
Foster Forbes Glass
Ccfmpany/glass fur-
nace
Sellersburg Stone
Company/stone
crushing, screening,
and conveying opera-
tions
Richmond,
Munde, and
Mt. Summit,
Indiana;
Region V
East PeoHa,
Illinois;
Region V
Newburg,
Indiana;
Region V
East Chicago,
Indiana;
Region V
Marlon,
Indiana;
Region V
Sellersburg,
Indiana;
Region V
Notices (3) of viola-
tion Issued Dec. 19,
1973.
Violation of Indiana
particulate matter
(process emissions)
and visible emissions
regulations.
Violation of Federal- Notice of violation
ly established com-
pliance schedule for
Illinois particulate
matter from combus-
tion of fuel for In-
direct heating emis-
sion limitation.
Violation of Indiana
oart1culate matter
(process emissions)
regulation.
Violation of Indiana
particulate matter
(orocess emissions)
regulation.
Violation of Indiana
particulate matter
(process emissions)
regulation.
Violation of Indiana
visible emissions
and particulate mat-
ter (process emis-
sions) regulations.
Issued Dec. 20,
1973.
Notice of violation
Issued Jan. 4, 1974.
Notice of violation
Issued Jan. 2, 1974.
Notice of violation
Issued Jan, 2, 1974.
Notice of violation
Issued Jan. 10,
1974.
-------
Table 5-2 (continued). SUMMARY OF EPA AIR ENFORCEMENT ACTIONS, MAY 1972-JANUARY 1974
Company/type
of source
Location
Pollution problem
Type of action
Results or status
Stauffer Chemical
Company/sulfurlc
add manufacturing
from elemental
sulfur
Hudson Pulp and
Paper Company/
pulp and paper
plant
Batley-Janss
Enterprises/
alfalfa mill
Georgia Pacific
Corporation/lum-
ber mill
G and R Lumber Co./
lumber mill
Louisiana-Pacific
Corporation/lum-
ber mill
Hammond,
Indiana;
Region V
Palatka,
Florida;
Region IV
Brawley,
California;
Region IX
Fort Bragg,
California;
Region IX
Cloverdale,
California;
Region IX
Covelo and
Fort Bragg,
California;
Reqlon IX
Violation of Indiana
S02 regulation.
Source missed first
Increment of State
adopted, Federally
approved compliance
schedule for S02 and
partleulate matter.
Operation of alfalfa
mill 1n violation of
particulate and visi-
ble emission regula-
tions of California.
Operation of wood
waste burner 1n vio-
lation of visible
emission regulations
of California.
Operation of wood
waste burner 1n vio-
lation of visible
emission regulations
of California.
Operation of wood
waste burner 1n vio-
lation of visible
emission regulations
of California.
Notice of violation
Issued Jan. 10,
1974.
Notice of violation
Issued Dec. 20,
1973.
Notice of violation
Issued Dec. 14,
1973.
Administrative order
Issued Dec. 20, 1973.
Administrative order
Issued Dec. 20, 1973.
Administrative orders
Issued Dec. 20, 1973.
-------
Table 5-2 (continued). SUMMARY OF EPA AIR ENFORCEMENT ACTIONS, MAY 1972-JANUARY 1974
Company/type
of source
Location
Pollution problem
Type of action
Results or status
Redwood Coast Lumber
Company/lumber mill
MasonUe Corp.,
Western Lumber
Division/lumber
mills
Uklah,
California;
Region IX
Calpella and
Cloverdale,
California;
Region IX
Ooeratlon of wood Administrative order
waste burner 1n vlo- Issued Dec. 20, 1973.
latlon of visible
emission regulations
of California.
Operation of wood
waste burners 1n
violation of visi-
ble emission regu-
lation of Califor-
nia.
Administrative orders
Issued Dec. 20, 1973.
-------
SECTION 6 AIR QUALITY
MONITORING AND DATA REPORTING
AMBIENT AIR QUALITY
State air pollution control agencies must satisfy two basic
requirements with respect to ambient air quality monitoring:
(1) establish a network of measurement stations for each designated
pollutant (total suspended participates, sulfur dioxide, carbon
monoxide, and oxidants) according to prescribed guidelines, adequate
1n number and comprehensive 1n distribution, to yield a representative
picture of pollutant means and extremes, and (2) submit the data from
these monitoring networks to EPA quarterly as evidence of meeting air
quality standards or of making proper progress toward a specified com-
pliance date.
Table 6-1 lists, by State, the level of monitoring activity for
calendar year 1972 being reported to EPA's National Aerometric Data
Bank (NADB) as of September 1973. Under each pollutant, the Initial
columns give the numbers of Individual stations initially required
In the August 14, 1971, Federal Register and the numbers of
stations for which data collected in 1972 have been reported.
1. Federal Register. Volume 36, No. 156, August 14, 1971.
87
-------
Table 6-1.
STATUS OF CY 72 MONITORING ACTIVITY AS REPORTED TO NADB BY STATES,
SEPTEMBER 1973
EPA Region/State
Region I
Connecticut
Maine
Massachusetts
New Hampshire
Rhode Island
Vermont
Region II
New Jersey
NM, York
Puerto Rico
Virgin Islands
Region III
Delaware
JHst pf Columbia'
Maryland
Pennsylvania
Virgin^
Nest Virginia
Region. IV
Alabw
Florida
beorgia
Kentucky
Mississippi
North Carolina
South Carolina
Tennessee
Region V
Illinois
Michigan
Minnesota
Ohio
Wisconsin
It
S
c
5
"5
4
.5
3
1
2
|jTptal SUSP
1 Total requ
Minimum required
16
^
39
8
7
4
i
4 19
8 i 72
1 ( }
1 3
2
1
6
6,
7
10
7
a
f
9
4
8
10
6
11
6.
7
a
3
4
31
68
47
24
34
32
43
30
11
54
35
39
54
29
25
78
2.4
_
Total reporting
25
6.
52
25
27
2
78
228
5
t,
16
2
85
105
116
36
60
3?
29
88
1
178
72
95
54
117
108
57
12J
7
Required not 3 !!
reporting °- £.
0
7
6
0
0
2
0
0
2
0
0
2
0
, 2
' 3
4
1
6
13
2
9
0
10
0
26
0
2
27
17
part
A,
k W
ll
M1nimum required \
2
5
4
3
1
2
3
6
1
1
1
1
4
4
6
10
6 1
6
9
9
4
A
10
6
9
6
6
14
8
Oxldan
Total required
Minimum required
Total reporting
4 j 0
n 0
7 o
n ' 0
0 ' 0
0 0
7
1Q
Q
0
1
l
7
0
0
0
1 1
6
11
7
0
4
4
1
3
2
2
1
5
in
n
0
16
4
n
1
0
l
2
n
2
0
1
0
2
1
0
1
7
0
Required not
reporting
4
0
7
n
0
0
4
13
0
n
i
0
6
10
&
0
3
2
1
1
2
1
1
1
0
0
0
8
4
ts
AQCR's
reporting
Hinnnum required
2
s
4
1
1
2
4
1
1
1
1
4
t.
5
10
f
4
«
8
3
7
0
L
O
f,
7
10
8
00
oo
-------
Table 6-1 (continued). STATUS OF CY 72 MONITORING ACTIVITY AS REPORTED TO NADB BY STATES,
SEPTEMBER 1973
EPA Region/State
Region VI
Arkansas
Louisiana
Oklahoma
Texas
Region VII
Iowa
Kansas
Missouri
Nebraska
Region VIII
Colorado
Montana
North Dakota
South Dakota
Utah
Wyoming
Region IX
American Samoa
Arizona
California
Guam
Hawai 1
Nevada
Region x
Alaska
Idaho
Oregon
Washington
Total
2
5
"f
at
o
7
j
8
12
[Total
[jptal
f
X
t
10
i 1
m
24
5
12 32
7 35
5
4
8
5
i
4
3
1
4
u
l
1
4
^
j
f,
30
11
28
13
5
6
11
7
1
17
64
1
3
13
11
15
20
i)
1377
SUSP
Treo>
t7>
C
t-
o
<9
**
O
28
11
90
160
26
57
46
36
68
2
16
2
8
0
32
18
3
14
17
25
68
^i4
667
vended
ired
o
c
v c
l|
ce c
0
0
0
0
9
2
6
0
0
11
0
L_ 4
2
4
1
0
47
0
0
0
1
2
0
0
233
part
A
rep
"£ T
0
0
0
0
3
0
1
0
0
hi
0
3
2
2
1
0
10
0
0
0
1
0
0
0
69
icu
OCR
ort
e
c
01
IN|i
*^<
r^<
0
0
0
0
1
1
0
0
0
0
0
0
1
0
0
0
0
0
0
0
0
1
0
0
33
ates
s
19
1
a
t
c
7
3
8
12
8
6
4
4
8
1
2
1
0
1
0
*
1
1
1
3
3
3
S
6
220
I Sulfu
Total
requir
1
"c
X
4
15
6
49
13
6
15
5
8
14
2
3
9
3
1
16
17
4
1
8
7
7
8
14
861
Total reporting
2
17
25
13
2
31
4
2
3
1
0
1
1
1
0
Ji
15
2
12
3
7
0
2
12
1049
r die
ed
i
0
c
T,?
II
3
0
0
37j
11
0
11
4
7
13
2
2
8
2
1
4
6
2
0
5
0
7
6
2
363
xide
A
-rep
c o
it
Minimum required
4
3
8
3
2
7
2
1
1
0
0
2
i_ 0
1
0
3
5
0
1
0
0
0
0
4
153
Minimum required o
rt |
0
0
0
1
0
1
6
0
3
0
0
0
2
0
0
3
29
0
0
2
1
0
3
7
133
Carbor
ll req
L.
O
t
3
o
0
0
2
n
0
3
1
1
1
0
0
0
4
0
0
1
42
0
1
0
1
0
2
8
125
Required not ^ g
reporting S. g
0
0
n
1
0
0
5
0
2
0
0
o
0
0
0
2
2
0
0
2
0
0
1
0
69
tide
AQCR's
reporting
C-o
It
V
0
0
0
1
0
0
2
0
1
n
0
0
0
0
0
1
1
0
0
1
0
0
0
0
23
c
6 t>
s!
si
0
0
0
0
0
0
0
0
n
0
p
0
0
n
0
0
0
0
n
0
0
0
l
ft
5
>Hinimum required
7
3
R
11
2
7
3
4
7
5
2
4
3
3
1
3
10
1
1
2
4
4
4
6
275
Ox i dan
Total required
Minimum required
0
5
4
19
2
3
t,
n
3
0
0
0
2
n
0
3
29
0
0
2
0
0
3
5
208
Total reporting
0
4
2
n
0
2
1
1
7
o
0
0
n
n
0
2
ftO
0
1
1
n
0
2
4
122
Required not
reporting
0
1
2
10
2
1
5
0
1
0
0
0
2
A
0
1
1
0
n
2
0
0
1
1
12*
;s _
AQCR's
reporting
Minimuni required
7
2
6
5
11
t
3
4
7
5
7
4
2
»
1
'
I1"!
1
1
' 2 '
4
4
4
S
255
00
(O
-------
The remaining columns 1n Table 6-1 categorize the number of Air
Quality Control Regions (AQCRs) within each State that are (1) reporting
less than half the required monitoring, (2) reporting from half up to
the required monitoring, and (3) reporting more than the minimum
required monitoring. (Requirements for Interstate AQCRs are apportioned
to the constituent States according to population.)
Note that some States in Table 6-1 are reporting as many stations
as required, and some are reporting more; but these stations are not
always distributed among the AQCRs In accord with minimum requirements
for each AQCR. Consequently, even In these States, one or more AQCRs
may not yet satisfy minimum monitoring requirements. Further, Table 6-1
Identifies how many of the minimum required stations are actually being
reported In each State. No attempt has yet been made to assess the
aspect of how representative these monitoring locations are.
Tables 6-2 to 6-5 summarize the status of air quality In the
nation's 247 AQCRs as portrayed by the data reported to NADB for
calendar year 1972. For each pollutant, the number of AQCRs In each
priority classification 1s shown, plus the number of AQCRs reporting
(1) at least one station-quarter's data and (2) at least one valid
station-year of data for particulates and sulfur dioxide, for which
annual standards pertain. The final column 1n each of these tables
reports the number of AQCRs wherein one or more reporting stations
exceeded a primary standard. The results 1n these four tables differ
?
from those presented 1n the previous SIP progress report as a
2. State A1r Pollution Implementation Plan Progress Report, January 1
to June 30, 1973. U.S. Environmental Protection Agency, Research
Triangle Park, N. C. EPA-450/2-73-005. September 1973.
90
-------
consequence of additional 1972 data and corrections received 1n the
Interim. The previously reported counts are shown in parentheses
In the tables.
In brief, suspended participates remain a problem 1n spite of
encouraging evidence of downward trends. One-hundred-thirty-eight
AQCRs have reported at least one station still above a primary standard
(24-hour and/or annual) 1n 1972. Thirty-four AQCRs had reported no
1972 partlculate data at that point. Primary 24-hour and/or annual
sulfur dioxide standards were exceeded 1n only 19 of 162 AQCRs re-
porting in 1972.
Data for oxidants and carbon monoxide are quite sparse, but if
these limited results are indicative, substantial problems exist with
respect to these two pollutants. The primary oxidant standard was
exceeded in 21 of 38 AQCRs reporting at least one quarter's data. The
primary carbon monoxide standards were exceeded in 42 of 48 AQCRs
reporting In 1972. More detailed information on AQCR status and in-
dividual station results 1s given 1n Publication No. EPA-450/1-73-004.3
The presence of Individual values or annual means over a standard
clearly Identifies problem AQCRs. The absence of such values or means
1n the data reported from other AQCRs does not necessarily warrant the
conclusion that the standards are being met in those AQCRs until their
monitoring networks have been thoroughly appraised for adequacy in
number and placement of monitoring sites. Many regions do not have
comprehensive networks operating; others are only just beginning to
3. Monitoring and A1r Quality Trends Report, 1972. U.S. Environmental
Protection Agency, Research Triangle Park, N.C. Publication No.
EPA-450/1-73-004.
91
-------
Table 6-2. SUSPENDED PARTieULATE MATTER, STATUS OF AIR QUALITY, 1972*
Priority
classification
I or la
II
III
Total
Number
of
AQCRs
120
70
57
247
AQCRs reporting
At least 1
station-quarter
118 (116)
63 (61)
37 (36)
218 (213)
At least 1
station-year
110 (106)
53 (47)
28 (26)
191 (179)
AQCRs exceeding
any primary
standard
102 (99)
22 (26)
14 (14)
138 (139)
Based on data reported by States as of October 6, 1973. Values reported 1n
EPA 450/2-73-005 are given in parentheses.
Table 6-3. SULFUR DIOXIDE, STATUS OF AIR QUALITY, 1972
Priority
classification
I or la
II
III
Total
Number
of
AQCRs
60
41
146
247
AQCRs reporting
At least 1
station-quarter
52 (51)
31 (30)
79 (73)
162 (154)
At least 1
station-year
41 (40)
27 (25)
55 (50)
123 (115)
AQCRs exceeding
any primary
standard
13 (17)b
4 (8)b
2 (2)
19 (27)
aBased on data reported by States as of October 6, 1973. Values reported in
EPA 450/2-73-005 are given in parentheses.
DThese original totals were In error.
92
-------
Table 6-4. OXIDANTS, STATUS OF AIR QUALITY, 1972*
Priority
classification
I
III
Total
Number
of
AQCRs
55 (54)b
192 (193)b
247 (247)
AQCRs reporting
at least 1
station-quarter
31 (25)
7 (3)
38 (28)
AQCRs exceeding
primary standard
25 (18)
3 (3)
28 (21)
Based on data reported by States as of October 6, 1973. Values
reported 1n EPA 450/2-73-005 are given in parentheses.
}Prov1dence AQCR has been reel ass1fled Priority I for oxidants.
Table 6-5. CARBON MONOXIDE, STATUS OF AIR QUALITY, 1972a
Priority
classification
I
III
Total
Number
of
AQCRs
30 (39)
217 (218)
247 (247)
AQCRs reporting
at least 1
station-quarter
22 (13)
26 (21)
48 (34)
AQCRs exceeding
primary standard
21 (13)
21 (20)
42 (33)
dBased on data reported by States as of October 6, 1973. Values
reported, in EPA 450/2-73-005 are given in parentheses.
93
-------
report scattered results from the Initial stages of network Implementa-
tion. Until assessments can be made of network adequacy (not necessarily
to be equated with the Initially specified minimum requirements listed
1n Table 6-1) a technical distinction exists 1n describing an AQCR
reporting no values above standards. For the present* 1t can only be
stated that such, an AQCR "experiences no violation." The goal, based
on data from an adequate network, will be to designate such an AQCR
as "In compliance" with national ambient air quality standards.
In some Instances, the lack of stations In an AQCR may be only an
apparent deficiency. Stations may exist for which the data are not yet
being expedltlously relayed or correctly Identified for acceptance 1n
the National AerometHc Data Bank. Table 6-6 provides clear evidence
Table 6-6. NATIONAL SUMMARY OF STATE MONITORING AS REPORTED
TO NADB AS OF JANUARY 11, 1974
Pollutant
TSP
S02a
Ox
CO
Total
1971
1313
409
50
58
1830
1972
2683
1064
113
128
3988
1973
1st
quarter
1914
694
31
42
2681
2nd
quarter
1449
766
52
75
2342
1974
proposed
3511
2129
458
457
6555
Legal
requirement
1377
861
208
133
2579
aIncludes both continuous samplers and West-Gaeke bubbler.
that the anticipated schedule of data submlttal from local or State
agencies through the EPA Regional Offices to NADB, Durham, North Carolina.
has not yet been realized. According to this schedule, data should reach
NADB 75 days after the close of a quarter; summaries of these data are
then provided 120 days after the close of quarter. However, at the
-------
conclusion of the fourth quarter (CV IV), dtU for the second quarter
of CV 1973 (CY II) retching NADB represents less than 60 percent of the
total stations reporting 1n CY 1972. Consequently* an attempt to
characterize nationwide air quality status or trends using the Incomplete
1973 data presently In hand would be premature and misleading at this
time. Sufficient 1973 data are expected to be 1n hand for summrlza-
tlon 1n the next SIP progress report.
The nuater of monitors reporting air quality data to NADB by
type varies from 60 to 200 percent of nationwide requirements, although
the percent of required stations reporting by type 1s considerably
lower, from 39 to 86 oercent (see Table 6-7).
Table 6-7. AIR QUALITY MONITORING SITES, ACTUAL VERSUS REQUIRED
Pollutant
TSP
S02
CO
Ox
Legal
requirement
1377
861
133
208
Total
reporting3
2667
1049
125
122
Ratio
reporting/
required
1.94
1.22
0.94
0.59
Requi red
not
reporting
233
363
69
128
Required
reporting
1144
498
64
80
Ratio required
reporting/
required
0.84
0.58
0.48
0.39
aNot all of total reporting sites necessarily satisfy legal requirement.
The wide variance between the percent of total reporting stations
and those stations reporting from required sites suggests a need for
EPA and State effort to Improve the distribution of air quality monitors
as well as to Increase the number of some types. It 1s anticipated
that this will change as EPA revises guidelines for minimum monotor1ng
networks 1n the future.
SOURCE EMISSIONS
The 1972 emission estimates shown 1n Table 6-8 are based on data
from the National Emissions Data System (NEDS) data bank. Until 1972,
95
-------
the emission estimates were obtained by applying overall emission
*
factors and Industry average control efficiencies to nationwide pro-
duction or consumption totals to calculate emissions. Emissions In
NEDS are calculated for each point and area source and sunned to arrive
at the totals shown 1n Table 6-8.
Table 6-8. NATION-WIDE EMISSIONS, 1972 (10* tons/yr)a
Source
Transportation
Fuel combustion in
stationary sources
Industrial processes
Solid waste
Miscellaneous
Total
CO
76.4
1.2
17.6
5.0
0.8
101.0
TSP
0.8
7.5
8.6
0.9
0.2
18.0
SOX
0.6
24.4
6.6
0.1
0
31.7
HC
16.0
0.5
6.5
1.6
1.8
26.4
NOX
8.6
12.3
0.7
0.2
21.8
Based on data from the National Emissions Data Bank.
The NEDS data bank lacks adequate data for estimation of emissions
from all sources. The most notable deficiencies 1n NEDS, with respect
to Table 6-8, are that (1) all New York State point sources are miss-
Ing, and (2) emission estimates are not made for forest fires, coal
refuse burning, and structural fires. According to data from the New
York SIP* significant additional emissions for point source fuel com-
bustion and Industrial processes could be expected. Perhaps an
additional one nil lion tons of sulfur oxides and smaller amounts of the
other pollutants may be added to the fuel combustion by stationary
sources totals to account for New York point sources. Industrial process
emissions of particulate 1n New York may be 200,000 tons, but less than
100,000 tons of the other pollutants. Emissions from forest fires, coal
96
-------
refuse burning, and structural fires should be added to the miscellaneous
category to make these totals comparable to the data for previous years.
Due to lack of source data on a detailed, county basis for these types
of sources NEDS does not presently account for these emissions.
The 1972 data based on NEDS show significantly higher carbon mon-
oxide and much lower participate emissions from Industrial processes
when compared to the 1971 data based on the old methodology. NEDS
shows more carbon monoxide for 1972 for nearly every Industrial category.
It 1s concluded either that NEDS has not adequately accounted for carbon
monoxide controls or that the old methodology overestimated the extent
of control. Another possibility 1s that relatively large emitters were
not accounted for 1n the old methodology. The apparent discrepancy
Is probably due to a combination of these factors. On the other hand,
recent Industrial process participate emissions from NEDS agree quite
well with old methodology estimates except for the mineral products
Industry and food and agricultural Industry categories. Recent NEDS
estimates show much lower emissions for both categories (5.2 versus
2.6 million tons for food and agricultural Industries). Again, the
discrepancy could be due to difficulties in correctly determining
control efficiencies. A more likely explanation in this case 1s that
NEDS does not adequately account for emissions from all sources in
these categories. It 1s known, for example, that NEDS does not contain
adequate source data to estimate emissions for all grain elevators and
feed mills.
97
-------
SECTION 7
STATE AND LOCAL RESOURCES
OPERATING FUNDS AND TYPES OF ASSISTANCE
Since the passage of the Clean A1r Act Amendments 1n 1970, the
primary purpose of grant assistance, special contract support, and
assignment of personnel has been to aid State and local agencies
2
in developing and executing SIPs. The previous SIP progress report,
provides tables showing State and local operating funds by source of
funds and type of assistance for fiscal year 1973. In FY 1974, the
total Federal funds available to the State and local agencies will
again approximate $51.5 million, with $48.5 million provided for grant
support and State Assignees and $3.0 million for special contract work.
SPECIAL STATE SUPPORT
Although the grants program provides the largest share of direct
support to State and local control agencies, the special assistance
provided to them results in an Important aspect of continued control
agency program achievement in meeting the State's implementation plan.
1. Clean Air Amendments of 1970, Public Law 91 604, December 31, 1970.
2. State Air Pollution Implementation Plan Progress Report.
January 1 to June 30, 1973.U.S. Environmental Protection Agency,
Research Triangle Park, North Carolina. Publication No. EPA
450/2-73-005, September 1973.
99
-------
Special Contracts and Demonstration Grants
Special contracts support and demonstration grant assistance help
the States accomplish specific tasks associated with meeting deadlines
imposed for the submlttal and modification of Implementation plans and
for meeting other Federally mandated requirements. Tables 7-1 and 7-2
show the types of special support provided 1n 1973 and the estimated
support to be provided in 1974 through contract and demonstration grant
support. The projects are submitted by each Regional Office on a
priority basis for consideration for funding. These projects can be
funded either as contracts known as Basic Ordering Agreements (BOAs)
or as demonstration grants.
Contractors with special skills and experience are utilized for
the majority of the BOA work. In comparison, a demonstration grant
approach 1s usually utilized by a control agency or other governmental
agencies to demonstrate a new air pollution control methodology. The
demonstration grant project should have regional or nationwide appli-
cation. (Since these grants are not as timely or as applicable from a
technical point of view as the contract work, they are not as desirable
to utilize as a support mechanism.)
In the past, the BOA type of assistance has aided the States in
the preparation of SIPs and transportation control strategies, the
collection of air monitoring and emission data for use in control
strategy development, and the preparation of compliance schedules. In
FY 1974 this support has been expanded to include assistance 1n SIP
revision and Implementation, Indirect source and 10-year maintenance
studies, and significant deterioration plans.
100
-------
State Assignees
Through the State Assignee program, direct manpower staffing
support 1s provided to State and local air pollution control agencies.
The program operates by assigning, on agency request, a limited
number of professional and technical personnel to positions in State
and local control programs. These Individuals serve 2-year assign-
ments as Federal employees under the Immediate supervision of the
State or local agencies. A major goal of the program is that the
agencies will hire each assignee at some time during the 2-year assign-
ment period.
Since July 1, 1970, when the first candidates were assigned, 275
assignees have participated in the program. As of January 1974, there
were 101 assignees on board, 98 assignees had converted to State or
local control programs, 16 assignees had converted to Federal programs,
and 60 assignees had resigned from the program.
This unique assignee program has provided the State and local
agencies with qualified personnel that cannot normally be obtained
within the limitations and'time constraints often encountered by the
agencies in their recruiting efforts. Currently, the assignee program
Is operating at a 100-position ceiling. Efforts are being made to
Increase this position level and to assure continued operation of the
program over the coming years. In this manner, the State and local
programs will have available another assistance mechanism that will
provide them resources for obtaining the manpower resource levels
necessary to accomplish the SIPs.
101
-------
Table 7-1. SPECIAL STATE AND LOCAL SUPPORT (dollars)
BY TYPE OF ASSISTANCE, FY 1973
EPA
Region/State
Region I
Connecticut
Massachusetts
Vemmt
New HMpsMr*
Rhode Island
Maine
Total 202.850
Region 11
NM Jersey
Hew York
Puerto Rico
Virgin Islands
Total 321.450
Region III
District of
Columbia
Maryland
Pennsylvania
Virginia
test Virginia
Delaware
Total 194,900
Region IV
AlatMM
Florida
Georgia
Nlsslssippi
Kentucky
Korth Carolina
South Carolina
Tennessee
Total 378.000
Region V
Illinois
Indiana
Minnesota
Michigan
Ohio
Wisconsin
Total 153,100
Region VI
Arkansas
Louisiana
New Mexico
OklahOM
Texas
Total 253,814
Region VII
Iowa
Kansas
Missouri
Nebraska
Total 102.000
Region VIII
Colorado
Montana
North Dakota
South Dakota
Utah
NyoMlng
Total 370.670
Region IX
Arizona
California
Hawaii
Nevada
Gua»
American Saam
Total $87,142
Region X
Hashing ton
Oregon
Idaho
Alaska
Total 197,560
Grand total
Transportation
plan
development
40.000
23.100
63.100
15.000
10.450
25.450 .
12.350
19.100
6.200
37.650
15.000
15.000
5.400
23.100
3.100
31.600
155.000
155.000
38,000
38.000
20.450
24.600
45,050
8.100
111.300
25,000
144,400
12.700
6.500
32,500
51.700
717.950
SIP
revision
40,000
40.000
5.400
18.000
21.000
5.400
5.400
5.500
60.700
33.125
40.625
25.000
31.125
45.625
27.500
27.500
32.500
263.000
7.500
7.000
7.000
7.000
7.000
7.000
42.500
6.134
6.134
12.500
12.500
25.000
50.000
50.000 _
6.134
6.134
6.134
18.402
16.500
16.500
533.036
SIP
secondary
standards
developnent
34.000
25.000
59.000
3.000
8.400
38.400
33,000
2.500
3.000
88.300
14,000
36,000
50.000
10.000
10.000
39.000
39.000
218.000
NEDS ealSSlon
inventories and
air qualify
data reporting
18.250
8,250
8.250
34.750
35.000
6.000
41.000
8.250
8.250
26.000
15.000
15.000
12.000
27.040
5.000
100.000
12,500
16.500
29,000
16.500
16.500
18.500
18.500
70.000
18.000
9,000
12.000
39,000
16.500
10,000
10.000
25.000
' 10.000
71.500
105.500
7.500
7.500
120.500
13.000
23.500
7,500
44.000
565.500
Oeawistratlon
grant
46.000
46.000
215,000
215.000
241,000
Saclter
study
22.680
22.680
136.080
68.040
204.120
248,480
45.360
293.840
46.360
46.360
567,000
Total
120.000 .
48.100'
18,250
8,250
8,250
202.850
15,000
300.450
6.000
321.450
20,750
45.500
65.600
38.400
7.900
16.750
194.900
74.125
55.625
40.000
31.125
45,625
39.500
54,500
37.500
378.000
39.400
7.000
46.600
7.000
46.100
7.000
153.100
16.500
16.500
47,314
18.500
155,000
253.814
18.000
21,500
38.000
24.500
102.000
86.950
136.080
10.000
10.000
117.640
10.000
370.670
262,714
232.934
7.500
83.994
587.142
42.200
30.000
85.360
40.000
197,560
2.761.486
102
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Table 7-2. SPECIAL STATE AND LOCAL SUPPORT (dollars)
BY TYPE OF ASSISTANCE, ESTIMATED FY 1974
EPA
Region/State
Region I
Connecticut
Massachusetts
Vermont
New Hampshire
Rhode Island
Milne
Subtotal
Region II
New Jersey
New York
Puerto R1co
Virgin Is.
Subtotal
Region III
O.C.
Maryland
Penna.
Virginia
W. Virginia
Delaware
Subtotal
Region IV
Alabama
Florida
Georgia
Mississippi
Kentucky
N Carolina
S. Carolina
Tennessee
Subtotal
Region V
Illinois
Indiana
Minnesota
Michigan
Ohio
Wisconsin
Subtotal
Region VI
Arkansas
Louisiana
N. Mexico
Oklahoma
Texas
Subtotal
Region VII
Iowa
Kansas
Missouri
Nebraska
Subtotal
Region VIII
Colorado
Montana
N Dakota
S. Dakota
Utah
Wyoming
Subtotal
Region IX
Arizona
California
Hawaii
Nevada
GUM
tear. Samoa
Subtotal
Region X
Washington
Oregon
Idaho
Alaska
Subtotal
Grand Total
Transportation
control plan -
development
50.000
50.000
100.000
50.000
30.000
86,666
60.000
25,000
25.000
g.ooo
135,000
26,000
50,000
54.000
1U.660
10.000
16.666
40.000
40.000
13.000
311.000
157555
538.000
SIP
revision
15.000
10,000
15.000
40,000
30,000
36,0*
20,000
50.000
15.000
557055
75.000
75.000
230.000
SIP
secondary
standards
development
18.000
100.000
1TS7555
20.000
20.060
5.000
5.066
20,000
20,000
100.000
160.665
56.000
56.666
319,000
NEDS emission
Inventories and
air quality
data reporting
20.000
20,000
53.000
5J7556"
'is. ooo
15,000
15.000
15.000
15,000
15,000
15,000
20.000
125,000
32,000
13,000
10.000
55,000
15.000
20.000
3T7556"
35,000
20,000
5.000
S57565
25.000
25.000
30.000
20.000
20,000
757565
443.000
Industrial
source
10-year
maintenance
10,000
10,000
5,000
5,000
10.000
10.000
50.006
50,000
50.000
100,000
15,000
15.000
25.000
10.000
5.000
5.000
75.606
12.500
12,500
12.500
12,500
12,500
12.500
12.500
12.500
100.600
20.000
20.000
15.000
20.000
15.000
10.000
100.666
15.000
15.000
15.000
15,000
15.000
75,666"
10.000
10,000
20,000
5TJ75W
12,500
12.500
12,500
12.500
12.500
12.500
75.600
25,000
50.000
10,000
15,000
100,000
15.000
15.000
10,000
10.000
557556
775.000
Demonstration
grant
50.000
50.000
210.000
Z1Q.OOO
44.000
10.000
10.000
64.006
324,000
Smelter
study
15.000
10.000
257555
30.000
30.000
55.000
Total
110,000
10,000
5.000
5.000
60,000
2flfeoW
70.000'
260.000
330,000
59.000
43.000
178.000
20.000
5.000
5.000
315.000
47,500
92.500
57.500
27.500
37.500
42.500
27.500
32.500
365,00d
80.000
52.000
15.000
58.000
85.000
25.000
325,006
15.000
15.000
61.000
65.000
69.000
225.660
45,000
10,000
100.000
TO75W
87,500
47.500
12.500
12.500
27,500
12.500
200,000
80.000
238.000
10,000
45.000
373.000
101.000
35.000
30.000
10.000
176,000
2.684,000
103
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AGENCY RESOURCES COMPARED TO SIP ESTIMATES
3
In the previous progress report, Information was provided that
compared available State and local agency resources with anticipated
national 1973 and 1975 SIP needs. Initial estimates of State and local
control agency needs have focused on the resources provided in the
original SIPs. Now new program responsibilities will tend to require
additional resources. In order to estimate the additional resources
that may be needed, the Regional Offices were asked to obtain from
States new resource estimates accounting for the new responsibilities.
These estimates were to include resources resulting from revisions of
the original SIP, control of indirect sources, and transportation
control plans.
The initial revised estimates received from the Regional Offices
indicate that approximately 9500 man-years and $189 million will be
required to accomplish the SIP and revisions to the SIP by the end of
FY 1975. Table 7-3 shows the original SIP projections for each State,
estimated revisions of those projections, and projections for SIP
accomplishment and revisions including additional programs of indirect
source control and transportation controls. If these new estimates
are substantiated and are made a part of each State's SIP, then the
resources required for State and local control operations will exceed
the initial 1975 estimated manpower requirements by 900 man-years and
$45 million and the available 1973 man-year and funding levels by 3800
man-years and approximately $75 million.
3. SIP Progress Report, op c1t.
104
-------
It 1s Important that such resource estimates be as reliable and
accurate as possible. Therefore, a reassessment of the type of
activities and manpower required for control programs Is being made
by the Control Programs Development Division, Office of Air Quality
Planning and Standards. This control agency resource study Is being
performed under contract and will be completed In FY 1974. This
study will form a basis on which projections of resource requirements
can be made and could also provide a basis for equitable allocation
of grant funds.
105
-------
Table 7-3. STATE AND LOCAL AGENCY ESTIMATED RESOURCE NEEDS (1975)
EPA
Region/State
Region I
Connecticut
Maine
Massachusetts
New Hampshire
Rhode Island
Vermont
Subtotal
Region II
New Jersey
New York
Puerto Rico
Virgin Islands
Subtotal
Region III
Delaware
01st. of Columbia
Maryland
Pennsylvania
Virginia
West Virginia
Subtotal
Region IV
Alabama
Florida
Georgia
Kentucky
Mississippi
North Carolina
South Carolina
Tennessee
Subtotal
Region V
Illinois
Indiana
Michigan
Ml nnesota
Ohio
Wisconsin
Subtotal
Region VI
Arkansas
Louisiana
New Mexico
Oklahoma
Texas
Subtotal
Stated In
applicable
SIPa
man-yr
209.5
24.0
145.0
29.0
24.0
11.9
443.4
265.5
1,398.1
57.9
8.0
1772TT
27.0
39.5
213.0
547.1
185.0
109.9
.1,T2T75
91.5
188.9
93.0
156.0
70.8
190.5
98.0
173.0
1,061.7
354.2
162.1
208.0
97.0
479.0
113.7
1,414.0
39.0
55.5
48.4
94.8
667.2
~90O~
$103
3,499
401
2,421
473
401
199
7,394
4,435
23,349
967
134
28.885
*451
660
3,557
9,137
3,090
1.835
1B7730
1,528
3,155
1.554
2,605
1,180
3,181
1,637
2.889
17,729
5,915
2,468
3,474
1.620
7,999
1.898
23,374
651
930
808
1,583
11.142
15,114
Revised estimates
for basic SIP
prior to revision"
man-yr
183.0
24.0
151.0
26.0
24.0
14.5
4"2~T5
211.5
932.0
63.0
.10.0
1,2T6^
36.6
40.0
105. 4d
490.0
207.0
110.0
5SO
143.0
188.9
93.0
156.0
70.8
202.0
98.0
173.0
1,124.7
415.3
162.0
215.0
98.0
468.7
75.0
1,434.0
39.0
55.7
38.0
94.8
667.2
894.7
$103
3,468.0
432.4
2,210.0
365.0
249.3
275.0
6,999.7
3,926.0
22,168.3
607.2
150.0
26,851.5
527.0
795.0
l,739.8d
9,384.0
3.021.0
1,572.8
17,039.6
2.150.0
3,155.0
1,554.0
2,605.0
1,180.0
3,181.0
1,637.0
2,889.0
18,351.0"
8,121.6
1,950.0
4,384.0
991.0
7,031,0
1.500.0
23,977.6
605.0
928.0
687.0
1,247.0
12.776.0
16,243.0
Estimates, with
SIP revisions0
man-yr
247.0
30.0
175.0
26.0
25.4
20.5
52T^
242.5
1,028.0
65.0
10.0
1,345.5
39.2
52.5
198.0
507.0
284.0
122.5
l,2"0n
151.0
220.9
96.0
176.3
72.8
215.0
119.0
191.0
1,210
622.8
176.0
220.0
105.5
497.0
84.0
1,705.3
56.0
55.7
55.0
101.8
739.2
1,007.7
$103
4,699.7
522.4
2.560.0
365.0
305.3
425.0
8,877.4
4,741.0
23,700.3
637.2
150.0
29,228.5
583.0
1,040.0
3,386.4
9,904.0
4,736.0
1,764.3
21,413.7
2,430.0
3,971.0
1,627.0
3,143.0
1,220.0
3,454.0
2,037.0
3,193.0
21,075.0
13,667.6
2,120.0
' 4,534.0
1,105.0
8,131.0
1.956.0
31,513.6
1,085.0
928.0
1,033.0
1,383.0
14,219.0
18,648.0
106
-------
Table 7-3 (continued). STATE AND LOCAL AGENCY ESTIMATED RESOURCE NEEDS (1975)
EPA
Region/State
Region VII
Iowa
Kansas
Missouri
Nebraska
Subtotal
Region VIII
Colorado
Montana
North Dakota
South Dakota
Utah
Wyoming
Subtotal
Region IX
Arizona
California
Hawaii
Nevada
Guam
Subtotal
Region X
Alaska
Idaho
Oregon
Washington
Subtotal
Grand total
Stated in
applicable
SIPa
man-yr
52.2
49.0
203.8
42.3
347.3
86.4
26.5
10.0
12.0
23.0
18.0
175.9
109.0
925.0
27.5
43.7
5.2
1,110.4
15.0
19.7
100.3
185.6
320.6
8,629.2
$103
872
818
3,403
706
5,799
1,443
442
167
201
383
300
2,936
1,820
15,447
460
730
87
18,544
250
329
1,675
3,099
₯7333
143,858
Revised estimates
for basic SIP
prior to revisionb
man-yr
52.2
49.0
170.6
42.3
3~T4~T
86.4
27.0
5.0
6.0
23.0
18.0
165.4
109.0
822.2
26.0
34.0
6.2
997.4
10.0
19.5
100.0
125.0
254.5
7,812.8
$103
872.0
818.0
3,403.0
769.0
5,862.0
1,443.0
524.5
55.0
85.0
383.0
300.0
2,790.5
1,535.7
21,275.0
400.0
450.0
93.4
23,754.1
400.0
390.0
1,612.0
2,500.0
4,902.0
146,771.0
Estimates, with
SIP revisions0
man-yr
63.2
51.0
183.6
47.3
3"45T
106.4
29.5
14.5
10.0
35.0
19.0
214.4
124.6
1,221.0
26.0
34.0
7.6
1,413.2
14.5
26.5
191.0
252.0
484.0
9,484.3
$103
1,055.7
851.4
3,617.0
832.0
6,356.1
2,042.0
585.0
175.0
155.0
533.0
354.0
3,844.0
1,870.5
31,140.0
400.0
507.4
108.1
34,026.0
580.0
680.0
3,712. 0«
8,908. 0«
13,880.0
188,862.3
aOrigina1 SIP estimates as determined from information provided by EPA Regional
Offices prior to Jan 1973 and reflecting original SIP submittals.
bEstimates from data provided by EPA Regional Offices in Dec 1973. These
estimates do not indicate which States have formally revised their resource
estimates as given in the plan.
cRevised estimates from data provided by the Regional Offices that reflect revisions
to implementation plan that may require additional resources. These estimates
do not indicate which States have formally submitted a resource revision to the
SIP. Revisions generally considered would be for transportation controls,
indirect source controls, significant deterioration activities, and the additional
monitoring and evaluation activities generated by these revisions.
Figures in table reflect state data only; the addition of locals data increases
man-years to 161.3 and dollars to $2,758,895.
eIncludes cost for TCP hardware.
107
-------
TECHNICAL REPORT DATA
(flette read /attractions on the revtne before comptelinx}
1 REPORT NO
3. RECIPIENT'S ACCESSION>NO.
4 TITLE AND SUBTITLE
STATE AIR POLLUTION IMPLEMENTATION PLAN PROG-
RESS REPORT, JUNE 30 TO DECEMBER 31. 1973
6. REPORT DATE
April 1974
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
8. PERFORMING ORGANIZATION REPORT NO.
9 PERFORMING ORGANIZATION NAME AND ADDRESS
Office of Air Quality Planning and Standards,
Office of Air and Water Programs. Research Triangle Park,
N.C. , and Office of Enforcement and General Counsel,
Washington, D.C.
10. PROGRAM ELEMENT NO.
1$. CONTRACT/GRANT NOT
12. SPONSORING AGENCY NAME AND ADDRESS
U.S. Environmental Protection Agency
Office of Air Quality Planning and Standards
Office of Air and Water Programs
Research Triangle Park, North Carolina
13. TYPE OF REPORT AND PERIOD COVERED
Progress, 6/30 to 12/31/73
14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
16. ABSTRACT
Plans for attainment of national ambient air quality standards have been sub-
mitted by all States. This report describes progress toward implementing those plans from
June 30 to December 31, 1973. Presently, 16 State Implementation Plans (SIPs) have been
fully approved by EPA, discounting disapprovals with respect to maintenance ot national
standards. Of the other 39 plans, 26 have only regulatory deficiencies, which have been
corrected by EPA promulgation, and 13 are being finalized. Extensions for attaining pri-
mary standards and for developing plans for attaining secondary standards have been
granted, and the status of these extensions is discussed. The status of Federal assistance
to States in implementation of SIPs and State and local resource requirements for SIP imple-
mentation are examined. National issues affecting the SIPs are discussed. The adequacy of
air monitoring networks and air quality data reporting is reviewed. Efforts are needed to
improve the distribution and quantity of monitors and to assure timely data reporting. EPA's
Plan Revision Management System is discussed. The System, which identifies "possible
deficiencies" in the attainment of air quality standards, has been extended to cover 67 Air
Quality Control Regions. Deficiencies identified are being investigated by the Regional
Offices. The status of EPA enforcement activities is also presented. Compliance schedules
are being developed for all major sources, and these schedules are being monitored and
enforced.
17.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.IDENTIFIERS/OPEN ENDED TERMS C. COSATI Field/Croup
Air pollution
Air quality standards
Enforcement (air quality standards)
State Implementation Plans
IS. DISTRIBUTION STATEMENT
Release Unlimited
IB. SECURITY CLASS
21. NO. Or PACES
119
22. PRICE
EPA Form 2220-1
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