ENVIRONMENTAL PROTECTION AGENCY
ANALYSIS OF THE AIR POLLUTION CONTROL STRATEGY
FOR THE SACRAMENTO VALLEY INTRASTATE
AIR QUALITY CONTROL REGION
July 1976
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TABLE OF CONTENTS
Section Page
I. INTRODUCTION 1
II. ANALYSIS
A. Summary of Air Quality Analysis Documents 4
B. Summary of Air Quality Data 5
C. Air Quality Projections 12
D. Summary of Present Control Strategies 20
E. Enforcement Status and Analysis 24
F. Point/Non-Point (i.e., Major/Minor) 26
Stationary Source Analysis
G. Comparison of Present Strategy with 28
Reasonably Available Control Measures
«
III. SUMMARY AND CONCLUSION 33
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TABLES AND FIGURES
TABLES PAGE
TABLE I — National Ambient Air Quality Standards (NAAQS) 2
TABLE II — List of Monitoring Stations Reporting 6
Violations of National Ambient Air
Quality Stations (1974)
TABLE III — Summary of the 1973 Emission Inventory 14
for the Sacramento Valley AQCR
TABLE IV — Emission Inventory Growth Factors Projected 14
from Base Year 1973
TABLE V — Sacramento County Carbon Monoxide Emissions 14
Inventory, Emission Projections, and Emission
Growth Factors
TABLE VI — Butte County Carbon Monoxide Emissions 15
Inventory, Emissions Projections, and
Emission Growth Factors
TABLE VII — Summary of the 1973 Ambient Concentrations 1*>
*
TABLE VIII — List and Compliance Status of Point Sources 2^
in Violation of Emission Regulations
TABLE IX — Point/Non-Point Emission Data 27
TABLE X — List of Measures Considered Reasonably 29
Available Control Technology (RACT)
FIGURES
FIGURE I — Location of Carbon Monoxide Monitoring 7
Stations and Distribution of 8-Hour CO
Standard Violations (.1974)
FIGURE II — Location of Oxidant Monitoring Stations 8
and Distribution of 1-Hour Oxidant
Standard Violations (1974)
FIGURE III — Location of Total Suspended Particulate 9
Monitoring Stations and Distribution of
24-Hour Secondary Particulate Standard
Violations (1974)
FIGURE IV — Location of Total Suspended Particulate 10
Monitoring Stations and Distribution of
. Annual Particulate Standard Violations (1974)
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I. INTRODUCTION
In 1971 the Environmental Protection Agency (EPA)
established the National Ambient Air Quality Standards
(NAAQS) to safeguard the health and welfare of the
people of the United States. Two levels of standards
were developed: (1) primary ambient air quality
standards are those which allow an adequate margin of
safety and are requisite to protect the public health,
and (2) secondary standards are those which are req-
uisite to protect the public welfare from adverse
effects associated with the presence of air pollutants
in the ambient air. The National Ambient Air Quality
Standards are listed in Table I.
Section 110(a)(2)(H) of the Clean Air Act, as
amended, requires that State Implementation Plans —
SIPs (enforceable State plans which provide for the
attainment and maintenance of the national primary and
secondary ambient air quality standards) — provide
"for revision, after public hearings, of such plans (i)
from time to time as may be necessary to take account
of revisions of such national primary or secondary
ambient air quality standard or the availability of
improved or more expeditious methods of achieving such
primary or secondary standards;-or (ii) whenever the
Administrator finds on the basis of information avail-
able to him that the plan is substantially inadequate
to achieve the national ambient air quality primary or
secondary standard which it implements".
The Regional Administrator has the responsibility
to identify any SIP which is substantially inadequate
to attain and maintain national standards, priority
attention shall be addressed to attainment of primary
standards. Any plan revision for attainment of national
standards shall also consider maintenance of such
standards.
Requests for SIP revisions are to be publicly
announced through a letter to the Governor and a notice
in the Federal Register. The requests must specify the
schedule for submission of revisions by the State. An
SIP revision which requires the application of all
achievable emission limitations to the extent necessary
to meet national primary standards must be submitted by
- the State to EPA on or before July 1, 1977. The term
"achievable" is intended to mean "reasonably available
control technology" (RACT).
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TABLE I
National Ambient Air Quality Standards (NAAQS)
Pollutant
Carbon Monoxide (CO):
Nitrogen Dioxide (N02):
Photochemical Oxidants
(Ox)f measured as ozone
Hydrocarbons (HC) ,
measured as non-methane
organics:
Sulfur Oxides (SOX),
measured as Sulfur
Dioxide (SO2):
Particulate Matter
(PART), measured as
Total Suspended
Particulate (TSP):
Primary Standard
10 mg/m3 (9 ppm)
8-hour average
concentration*
and
40 mg/m3 (35 ppm)
1-hour average
concentration*
Secondary Standard
Same
Same
100 ug/m3 (0.05 ppm)
annual arithmetic mean
160 ug/m3 (0.08 ppm)
1-hour average
concentration*
160 ug/m3 (0.24 ppm)
3-hour (6 to 9 a.m.)
average concentration*,**
Same
Same
Same
80 ug/m3 (0.03 ppm) 1,300 ug/m3 (0.5 ppm)
annual arithmetic 3-hour average
mean; and concentration*
365 ug/m3 (0.14 ppm)
24-hour average
concentration*
75 ug/m3 annual
geometric mean; and
»
260 ug/m3 24-hour 150 ug/m3 24-hour
average average
concentration* concentration*
*Maximum value not to be exceeded more than once per year.
**To be used only as a guide in meeting the ox standard.
-2-
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An SIP revision which includes ail other measures
necessary to meet the national standards must be sub-
mitted by the State to EPA on or before July 1, 1978.
These "other measures" should include items such as
land use measures, transportation controls, transit
improvements, zoning ordinances, building codes (such
as" to increase insulation), inspection/maintenance
programs (for stationary and/or mobile sources), etc.
These "other measures" are often incorrectly construed
to be strictly "maintenance" measures; many are in fact
effective for attainment also.
The SIP revisions must specify new primary standards
attainment dates which are as expeditious as practicable.
Although this term carries a presumption of no more
than three years, in exceptional cases more than three
years may be necessary. The SIP revisions must specify
new secondary standards attainment dates' which represent
a "reasonable time". This term also carries a pre-
sumption of no more than three years, although addi-
tional flexibility is permitted in attainment of
secondary standards.
The decision to request an SIP revision is based
upon a summary of previous air quality analysis doc-
uments, an analysis of the present air quality, a
projection of future air quality, a summary of the
present control strategy, the status of enforcement
activity, an analysis of the relative contribution of
stationary point and non-point sources (i.e. major and
minor sources) to the air pollution problem, and a
comparison of the present control strategy with
reasonably available control measures, for each air
quality region (AQCR).
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II. ANALYSIS
A. SUMMARY OF AIR QUALITY ANALYSIS DOCUMENT
Following is a summary of a document reviewed by
EPA in assessing the air pollution problem in the
Sacramento Valley Air Quality Control Region (AQCR):
Air Quality Implementation Plan Development
for Critical California Regions; Sacramento Valley
Tntrastate AQCR/ prepared by TRW, Inc. for EPA, August
1973.
This study was directed towards standard attainment
for three pollutants: oxidants, carbon monoxide/ and
nitrogen oxides.
The study estimated that additional measures would
be necessary to reduce 1972 emissions to reach ambient
air quality standards by 1977* These measures include:
gasoline evaporative controls, various organic solvent
substitutions, burning controls, mandatory inspection/
maintenance, catalytic converter retrofit, aircraft
emission controls, and improved mass transit.- An
additional emissions rollback through a major reduction
of VMT would be necessary to achieve ambient air quality
standards according to the study.
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B. SUMMARY OF AIR QUALITY DATA
The following ambient air quality data summary
analysis for 1974 is an effort to identify the mag-
nitude and extent of the air pollution problem in the
Sacramento Valley Intrastate Air Quality Control Region
(AQCR). The National Ambient Air Quality Standards
(see Section I - Introduction) are the basis against
which the air quality is judged.
The majority of the ambient air monitoring in the
AQCR in 1974 was done by the California Air Resources
Board (ARE) and the local air pollution control dis-
tricts (APCD's), but EPA also operated air monitors in
the region. The local APCD's routinely submit air
quality data to the ARE which in turn submits both
district and State data to EPA. The data are stored at
the National level in the EPA National Aerometric Data
Bank (NADB) in North Carolina. The data presented in
this summary are for 1974, the most recent full year's
data in NADB and also include additional data from ARE
reports.
Table II displays the air quality standards vio-
lated in the Sacramento Valley AQCR in 1974.* For
standards with an averaging time of less than one year,
the second highest concentration over the standard, the
ratio of the second highest concentration to the
standard, and the number of days (or percent of values)
over the standard are presented for each station vio-
lating a standard. For the annual standards, the mean
concentration and the ratio of the mean to the standard
are presented. Air monitoring stations not violating a
standard are not listed in Table II but are included on
the map of station locations. The second highest
concentration is used since one excursion over the
standard per year is allowed. Oxidant values are
corrected where appropriate by the ARE recommended
oxidant calibration correction factors. The correction
factors are 0.85 for the San Diego County APCD stations,
and 0.80 for all other stations in California except
the Los Angeles County APCD stations, for which no
correction factor is necessary.
A map has been prepared for each standard violated
in the AQCR illustrating the location of monitoring
stations for which data has been reported by NADB and
ARB, and indicating the stations where violations
occurred during 1974 and the station with the maximum
concentration (see Figures I through IV).
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TABLE II
List of Monitoring Stations Reporting
Violations of National Ambient Air
Quality Standards (1974)
CARBON MONOXIDE; 8-hour average; standard = 10 mg/m3
Second Highest
Concentration
(mg/m3)
Ratio to
Standard
Days
Exceeding
Standard
13.1 1.31
OXIDANTS; 1-hour average; standard = 160 ug/m3
Site
Chico
Red Bluff
Redding
Sacramento
Sacramento
Yuba City
PARTICULATE MATTER:
Second Highest
Concentration
(ug/m3)
219
240
234
188
282
266
24-hour average;
secondary standard
Ratio to
Standard
1.
1.
1.
1,
1.
1.
37
50
46
18
76
66
Days
Exceeding
Standard
32
11
44
37
90
= 150 ug/m3
Site
Chico
Davis
Live Oak
Manzanita
Nord
Pleasant Grove
Sacramento
Sacramento
Yuba City
Second Highest
Concentration
(ug/m3)
196
163
238
172
193
177
162
183
197
Ratio to
Standard
1.31
1,
1,
09
59
1.15
1
1
1
1
,29
,18
,08
22
1.31
Percent of Values
Exceeding Standard
3.3
4.2
22.0
8.3
6.7
5.9
10.3
3.4
6.7
PARTICULATE MATTER: annual mean; standard = 75 ug/m3
Site
Chico
Live Oak
Yuba City
Placerville
Geometric Mean
Concentration
(ug/m3)
77
79
77
83
Ratio to
Standard
1.03
1.05
1.03
1.11
_ -6-
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/ Shasta Co.
» (part) |
« Location of Carbon Vonoxlde Monitoring
I Stations and Distribution of 8-Hour
! Carbon Monoxide Standard Violations, 1974
:
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^^ w •.^.'^ * Scale In miles
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@ Station violating NAAQS
Sacramento Valley Intrastate AQCR
, _ Figure I
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f
Location of Oxidant Monitoring Stations
and Distribution of 1-Hour Oxidant
Standard Violations, 1974
,
<
!
*
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i
Shasta Co.
(part)
L..
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Plumas Co.
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Glenn Co.
Butte Co>
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Nevada Co.
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® Station violating NAAQS
" t
© Station with maximum concentration j /*•——
to
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20
40
.
Scale in jni les
Sacramento Valley Intrastate AQCR
Figure II
— 8 —
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f
4
Location of Suspended Part5culate Matter
Monitoring Stations and Distribution of
24-Hour Secondary Particulate Standard
Violations, 1974
•
*
i
Shasta Co.
(part)
o
Teharra Co.
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1
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5
•s
Plurtas Co.
V
V
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Glenn Co.
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j
i.
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Butts Co.
e
Yuba
"X /
.
-------
j I Location of Suspended Partlculate Matter
f" - \ Monitoring Stations and Distribution of
/ j Annual Particulate Standard Violations, 1974
;
Shasta Co, *-••
(part) j
X O -N..^r —
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1 Yuba / •< ^ \
Co.usa Co. ^ $ut A C°' | / e
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C Sacramento j
O Monitoring station j Co. j p 20 40
»~-^ . Scale in miles
0 Station without known violations; • _ ., »•*""
data incomplete ,y »' % "
© Station violating NAAOS t-O""^*
® Station with maximum concentration
Sacrarento Valley Intrastate ACCR
Eigu^e IV
-10"-
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Following are brief discussions of the monitoring
and the air quality for each pollutant:
Carbon Monoxide (CO);
There were four CO monitoring stations in the AQCR
in 1974. No violations of the 1-hour CO air quality
standard were reported. One station reported violations
of the 8-hour standard. The maximum second highest
concentration was 1.3 times the standard and the standard
was exceeded on five days.
Nitrogen Dioxide (N02);
There were five NO2 monitoring stations in the
AQCR in 1974. None of the stations reported violations
of the annual standard.
Photochemicals Oxidants or Oxidants (Ox) •
Six stations monitored oxidants in the AQCR in
1974. All stations reported violations of the 1-hour
oxidant standard. The maximum second highest concen-
tration at any station was 1.8 times the standard, and
the maximum number of days the standard was exceeded at
any one station was 90.
Sulfur Dioxide (S02):
EPA had one SO2 monitor in the AQCR in 1974. No
violations of the 3-hour, 24-hour, or annual standards
were reported.
Particulate Matter of Total Suspended Particulate (TSP);
There were 27 high volume samplers located through-
out the AQCR in 1974. None of the stations violated
the 24-hour primary TSP standard. The 24-hour secondary
standard was violated at nine stations. The maximum
second highest concentration at any one station was 1.6
times the standard, and the maximum percentage of
values exceeding the standard at any one station was 22
percent.
The annual primary standard was violated at four
stations. The maximum geometric mean concentration at
any one station was 1.1 times the standard.
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C. AIR QUALITY PROJECTIONS
The relationship between pollutant emissions and
ambient pollutant concentrations must be determined
from a known point or base year, for which air pol-
lutant concentrations and the quantity of air pollutant
emissions are known. A base year then, is a year for
which: (1) the amount of emissions and the air quality
concentrations are known, and (2) a specific relation-
ship is determined to exist between emissions and air
quality. Future air quality is assumed to have the
same relationship to emissions in future years as that
determined for the base year.
The base year (i.e., 1973) emission inventory used
for this analysis is from a draft emission inventory
developed by the California Air Resources Board for the
Sacramento Valley Air Basin (see Table III). The
Sacramento Valley Air Basin boundaries and emissions do
not exactly coincide with those for the Sacramento
Valley AQCR. Emission inventory growth factors for
this AQCR, and therefore air quality projections, are
developed from California ARB emission inventory pro-
jections. The California ARB was able to supply
emission inventory growth projections for four years -
1980, 1985, 1990, and 1995. For the one pollutant, CO,
Butte and Sacramento Counties are analyzed individually
instead of on an AQCR wide basis.
AQCR wide emission growth factors were developed
by EPA for particulates, SOX, NOX, and oxidants. These
emission growth factors were based on ARB growth pro-
jections for Yolo, Yuba, Sacramento, and Sutter Counties,
those being the only data available.
The AQCR emission growth factors for CO were based
on expected Sacramento and Butte County CO emission
increases since the only CO excursions above the standard
occurred in those counties. No growth factors were
available for Butte County so neighboring counties with
similar CO emission inventory distributions were used
to predict Butte County emission growth.
The mobile source CO emission growth factor for
Butte County was derived from combined Sutter and Yuba
County emission growth projections. Growth in Butte
County waste burning CO emissions was predicted from
Sutter County. Both of these counties have rice
stubble and orchard prunings as the primary source of
waste burning CO emissions.
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Growth in Butte County CO emissions from the
combustion of fuels was predicted by population growth
factors for Butte County made by the California Depart-
ment of Finance.
Miscellaneous area sources contribute the final
portion of Butte County CO emissions. Wild fire CO
emissions were predicted to stay constant through 1995
based on projections for other counties. Other CO
emissions from miscellaneous area sources were pre-
dicted to grow at the average rate of Sutter and Yuba
Counties.
Sacramento County CO emission inventory growth
projections were available and were used to derive
growth factors for that county. (see Table V).
CO Projections were done for two locations because
the station having the 1973 AQCR high, Sacramento —
11.6 mg/m3, does not show violations in 1974 and is not
projected to have future violations, but the station
having the second high 1973 ambient CO concentration,
Butte County — 11.5 mg/m^, has the high 1974 CO con-
centration of 17.8 mg/m^, and is projected to violate
the CO standard in future years. Therefore,'the choice
of Butte County is appropriate for evaluating future CO
ambient problems.
The growth factors reflect the implementation of
only the presently adopted emission control measures.
The 1973 base year emission inventory for the six
county area of the Sacramento Valley AQCR is shown in
Table III, and the emission inventory growth factors
are- shown in Table IV. CO emissions and emissions
growth factors for Butte County are shown in Table VI.
A list of the 1973 highest and second highest ambient
concentrations for various pollutants, as reported by
the EPA-NADB, is shown in Table VII.
A direct proportional relationship is assumed to
exist between sulfur oxides (SOX) emissions and re-
sulting S02 ambient concentrations, nitrogen oxides
(NOX) emissions and resulting NO2 ambient concentrations,
particulate emissions and resulting TSP ambient concen-
trations and total organic gas (TOG) emissions and
resulting photochemical oxidant ambient concentrations.
For instance, if in some future year, a pollutant
emission rate is projected to double from that estimated
for the base year, then the air quality in the future
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TABLE III
Summary of the 1973 Emission Inventory
for the Sacramento Valley AQCR
Emissions (Tons/day)
Emissions Sources CO NOx TOG* SOx Part
Stationary 591 36 267 6.5 237
LDV & HDV 985 157 139 6.3 14
Other Mobile 241 51 43 8.9 8
Totals 1817 244 449 21.7 259
*Refers to "Total Organic Gas" emissions, which are a close
approximation of non-methane organic gas emissions.
TABLE IV
Emission Inventory Growth Factors
Projected from Base Year 1973
Sacramento Air Basin*
Pollutant Growth Factors/Year
NOx
TOG
SOx
Part
*Growth Factors calculated from Emission Inventory projections
for Sutter, Yuba, Yolo, and Sacramento Counties.
TABLE V
Sacramento County Carbon Monoxide
Emissions Inventory, Emission Projections,
and Emission Growth Factors
1975
0.93
0.94
1.02
1.08
1980
0.73
0.80
1.16
1.18
1985
0.63
0.82
1.31
1.31
1990
0.66
0.90
1.48
1.45
1995
0.60
0.99
1.53
1.59
Year
Total Emissions 197319751980
(tons/year) 569 508 349
Growth Factor 1.0 0.89 0.61 0.53 0.57 0.58
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TABLE VI
Butte County Carbon Monoxide
Emission Inventory, Emission Projectons/
and Emission Growth Factors*
Stationary
Emissions Year
(tons/year); 197319751980198519901995
Waste Burning1 44.4 45.7 49.7 54.6 59.5 63.5
Combustion of Fuels2 10.2 10.4 10.9 11.7 12.8 13.7
•5
Miscellaneous AreaJ 5.4 5.4 5.6 5.8 6.1 6.3
Total Stationary
Sources 60 61.5 66.2 '72.1 78.4 83.5
Total Mobile
Sources4 104 97.8. 77.0 75.0 79.0 87.4
Total Emissions 164 159.3 143.2 147.1 157.4 170.9
Overall Butte
County Emission
Growth Factors for
Carbon Monoxide; 1.0 0.97 0.87 0.90 0.96 . 1.04
"Waste burning" growth factor for Sutter County used for
Butte County projections.
^"Combustion of fuels" growth factors derived from population
growth factors for Butte County.
"Miscellaneous area sources" growth factors for Sutter and
Yuba Counties used for Butte County except that no growth
was projected for wild fires.
4
"Mobile source" growth factors for Sutter and Yuba Counties
used to project Butte County emission.
*1975 and later emission inventory growth projections were not
available for Butte County, and as a result EPA made growth
projections based on analogies to neighboring counties for
which projections were available.
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TABLE VII
Summary of the 1973
Ambient Concentrations
Pollutant Concentration Units High 2nd High
CO
NO2
Ox
S02
TSP
8-hour average
1-hour average
annual arithmetic mean
1-hour average
annual arithmetic mean
24-hour average
3-hour average
annual geometric mean
2 4 -hour average
mg/m3
mg/m3
ug/m3
ug/m3
ug/m3
ug/m3
ug/m3
ug/m3
ug/m3
11.6
18.0
54.0
376.0*
No data
9.0
No data
69.0
319.0
11.5
18.0
37.0
345.0*
No data
9.0
No data
62.0
247.0
*These values corrected by California ARE recommended oxidant
calibration Correction factor of 0.8.
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year is projected to deteriorate, or worsen, by a
factor of 2 from that measured in the base year.
Conversely/ if in some future year a pollutant emission
rate is projected to be only one half of that estimate
for the base year, then the air quality in this future
year is projected to improve and the air pollutant
concentrations are estimated to be only one half as
high as that measured in the base year. For all
national air quality standard concentration reporting
periods (e.g., 1-hour, 8-hour, and 24-hour average
concentrations), the maximum yearly air pollutant
concentrations are used for air quality projection
purposes.
Using the assumptions and data discussed pre-
viously, air quality projections are estimated by using
the following technique or equation:
(1973 Base Year Worst Case Air Quality) x (Year X
Emission Inventory Growth Factor) = Projected Air
Quality in Year X
Background pollutant emissions and concentrations
(.i.e. , those emissions and concentrations not related
to man-made activities) are difficult to quantify and
are not considered in this technique. If the projected
air quality in a future year X is greater than the
national air quality standards listed in Section I -
Introduction, then an air quality violation is predicted.
Using the technique just discussed, the following
air quality projections and analyses are presented for
those pollutants for which standards have been violated
in the base year, or are projected to be violated in
future years:
OXIDANT AIR QUALITY PROJECTIONS
The oxidant standard was violated in 1973 with a
maximum 1-hour concentration of 376 ug/m3, which is 2.4
times the standard. The emission inventory growth
factors show a reduction in TOG emissions and therefore
oxidant concentrations from 1973 to 1980. Starting in
1980, TOG emissions are expected to increase. The
1-hour oxidant concentration, projected from 1973 to
1980 by the air quality projection technique and the
ARE growth factor, is as follows for 1980:
*376 ug/m3 x .80 = 301 ug/m3
*This value is corrected by the California ARE
recommended oxidant calibration correction factor
of 0.8.
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The standard is thus projected to be exceeded in
1980 with the occurrence of a maximum 1-hour oxidant
concentration which is 1.9 times the standard. A
worsening trend is expected to follow.
CO AIR QUALITY PROJECTIONS
The 8-hour carbon monoxide standard (as opposed to
the 1-hour standard) is the most seriously violated CO
standard. This standard was violated in 1973 in Butte
County, with a maximum 8-hour average concentration
recorded of 11.5 mg/m3, and in Sacramento County with a
maximum R-hour average recorded of 11.6 mg/m , which
are 1.2 times the standard. CO emissions for Butte
County and Sacramento County are projected to decline
from 1973 to 1980. 1980 air quality estimated by the
air quality projection technique and using the EPA
derived growth factors is as follows:
Butte County 11.5 mg/m3 x .87 = 10.0 mg/m3
Sacramento County 11.6 mg/m3 x .61 = 7.1 mg/m3
In Sacramento County, therefore, in 1980 the CO'
ambient concentration is calculated to be below the
standard by the projection technique, and, thereafter,
maintenance of ambient air quality standards is ex-
pected to occur.
In Butte County the projected 1980 air quality is
equal to the primary ambient air quality standard.
However, a worsening trend is expected to follow with
primary standard violations expected.
TSP AIR QUALITY PROJECTIONS
The annual TSP standard was not violated in 1973,
but the primary and secondary 24-hour standards were
violated in the 1973 base year. The question of future
attainment of the standard is evaluated as follows,
using the 1973 annual and 24-hour concentrations, the
air quality projection technique and the year 1985:
69 ug/m3 x 1.31 = 90 ug/m3 annual geometric mean
319 ug/m3 x 1.31 = 418 ug/m3 24-hour average
concentration
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The national annual primary standard 75 ug/m3, and
the national 24-hour primary standard of 260 ug/m^ are
thus both projected to be exceeded in 1985. Particulate
emissions began increasing 1975 primarily as a result
of emissions increases in the mineral processing, the
food and agricultural processing, and the wood pro-
cessing industries. The national primary and secondary
ambient 24-hour particulate standards were exceeded in
1973 and in 1974, and violations are expected to con-
tinue as a result of the projected increase in parti-
culate emissions unless additional emission control
measures are implemented.
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D. SUMMARY OF PRESENT CONTROL STRATEGIES
Following are general descriptions of the present
air pollutant emission control strategies for the six
county area (Sutter, Yolo, Yuba, Placer, El Dorado, and
Sacramento) studied by EPA.
NOy Control
NOX emission control for stationary combustion
sources is accomplished primarily by lowering peak
combustion flame temperature, by reducing the oxygen
and nitrogen concentrations during the combustion
processes, and by reducing the gas residence time at
high temperatures. These concepts are appplied by the
use of such techniques as exhaust gas recirculation,
two-stage combustion, and low excess air. The tech-
niques are primarily applied to the large stationary
source combustion processes. Reducing NOX emissions
from new and in-use vehicle engines is primarily
accomplished by lowering peak-combustion flame tem-
peratures through the use of ignition retard, and
exhaust gas recirculation techniques.
The Sacramento AQCR counties have adopted reg-
ulations limiting NOX emissions from new or modified
fossil fuel burning steam generating equipment to 140
pounds per hour in Sutter, Placer, and El Dorado
Counties. In the Yolo-Solano Unified APCD existing and
new fossil fuel fired steam generating plants are
limited to 140 pounds per hour of NOX emissions.
Sacramento and Yuba Counties have no regulations
regarding NOX.
SOX-Control
SOX emission control is accomplished for mobile
and stationary emission sources primarily by limiting
the sulfur content of fuels. In addition, sulfur
recovery and sulfuric acid plant emissions can be
controlled by requiring the improved efficiency, sizing,
and operation of plant equipment; and, in some cases,
stack scrubbing can be employed. The Sacramento Valley
AQCR counties have adopted SOX emission control reg-
ulations that require a specific SOX exhaust gas con-
centration limitation of 0.2 percent by volume, calculated
as SO2. In addition, El Dorado, Placer, and Sutter
Counties require new or modified fossil fuel burning
steam generating sources to limit SOX emissions to 200
pounds per hour. Yolo-Solano APCD limits existing and
new steam generating plants to 200 pounds per hour of
SOX emissions.
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CO Control
Mobile source CO exhaust emission control is
accomplished by using the following techniques:
lowering CO emissions by converting them to harmless
CO2 gas as a result of improved engine combustion
efficiency; oxidizing exhaust CO to C02 by the use
of a catalyst device in the exhaust system? promoting
the use of more volatile fuels (e.g., liquified petro-
leum gas and compressed natural gas) and thereby
improving combustion efficiency; and implementing
various transportation control measures such as bus and
car pool lanes and transit service improvements, which
reduce the amount of CO-producing activities.
There are no Sacramento Valley AQCR county reg-
ulations which require the control of CO. emissions from
stationary sources.
Ox Control
Ambient concentrations of photochemical oxidants
(Px) are reduced by controlling the emissions of the
primary oxidant precursor, hydrocarbons (HC) (i.e.,
non-methane organics). Mobile source HC emissions
result from fuel evaporation as well as engine exhaust.
Fuel evaporation is controlled by enclosing the vehicle
fuel tank and carburetor systems, and venting them
through an HC collection system into the engine.
Exhaust HC emissions control is accomplished by using
the following techniques: venting crankcase HC emis-
sions back into the engine for combustion; lowering
engine HC emissions by improved combustion efficiency,
thus converting the HC to harmless CO2 and water;
oxidizing exhaust HC to C02 and water by the use of a
catalyst device in the exhaust system; promoting the
use of more volatile fuels (e.g., liquified petroleum
gas and compressed natural gas) and thereby improving
combustion efficiency.
The control of HC emissions from stationary
sources is accomplished through operational or process
changes, substitution of non-HC materials for HC
materials, and the installation of emission control
equipment. The techniques used in control devices
include incineration (after-burners to complete the
oxidation of organic emissions), adsorption (collection
of a gas on a special material or surface), absorption
(transfer of a soluble gas to a non-volatile liquid
absorbant), and condensation (collecting organic
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emissions by lowering the gas stream temperature to the
appropriate condensation point). The Sacramento Valley
AQCR Counties have adopted regulations which control HC
emissions from a range of stationary HC emissions
sources.
Sacramento County and the Yolo-Solano Unified APCD
have adopted gasoline vapor recovery regulations con-
trolling storage tanks, service station underground
tanks, and vehicle refueling. Placer, Sutter, El
Dorado, and Yuba Counties require a floating roof or a
vapor collection system on storage tanks in excess of
40,000 gallons capacity. Placer and Sutter Counties
'require submerged filling of 250 gallons capacity
gasoline storage tanks.
The Yolo-Solano APCD and the Sutter, Sacramento,
and Yuba County APCDs have adopted solvent emissions
control regulations.
Particulate Control
Visible emissions — Presently, Ringelmann Two
(40% opacity)is the allowable density for smoke, used
for evaluation of smoke plumes in the field.* Any plume
which obscures an inspector's view by more than 40
percent for longer than three minutes in an hour is in
violation.
Open Burning — All Sacramento AQCR Counties ban
dump fires and back yard trash burning at other than
single or dual family residences. They also subject
agricultural burning to meteorological controls.
Farmers are allowed to burn portions of their crop
waste during specified seasons on ARB-approved "burn"
days. Exempted from ARB's control are barbecues,
recreational fires and fires approved for the purpose
of disposing of diseased trees and brush, hazardous
materials, fire training, range, forest and wildlife
management, flood control, and the clearing of under-
growth in irrigation ditches.
Orchard Heaters — All six Counties require that
orchard heaters meet ARB emission limits of 1 gram per
minute or that they be ARB-approved for use.
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Incineration — Emissions from incinerators are
limited by the amount of reduction a multiple chamber
incinerator would achieve, except in Yuba County where
no regulation is in effect. Placer and El Dorado
Counties additionally limit new or modified incin-
erators to 0.2 grains per cubic foot at standard
conditions.
Fuel Burning — In all six counties particulate
emissions from a combustion operation are limited to
0.3 grains per standard cubic foot regardless of the
size of the facility. New or modified sources
(existing sources as of 1984) are limited to 0.1 grains
per cubic foot at standard conditions in El Dorado and
Placer Counties. New or modified fossil fuel fired
steam generators in Placer and El Dorado Counties are
limited to 10 pounds per hour of particulates derived
from the fuel. Yolo-Solano Unified APCD limits ex-
isting and new steam generators to 40 pounds per hour
of particulates.
General Processes — Manufacturing processes are
limited by two types of regulations in all six of the
Sacramento AQCR Counties: process weight tables and a
grain loading limitation of 0.3 grains per standard
cubic foot. At a process weight rate of 3,000 pounds
per hour, allowable emissions range from 5.1 pounds per
hour in El Dorado and Sacramento Counties to 6.0 pounds
per hour in the Yolo-Solano Unified APCD. At a process
weight rate of 60,000 pounds per hour, all six counties
limit particulate emissions to 40 pounds per hour.
New or modified asphalt batch plants in Placer
County and the Yolo-Solano Unified APCD must limit
emissions to 0.04 grains per dry standard cubic foot of
existing gas flow.
Yolo-Solano Unified APCD additionally has a new
source performance standard for electric arc furnaces
and hazardous pollutant regulations for mercury and
asbestos.
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E. ENFORCEMENT STATUS AND ANALYSIS
Approximately 149 point sources (stationary
sources which have potential emissions-emissions which
would occur if no controls were applied-of greater than
100 tons/year) have been identified by the Sacramento
Valley AQCR Counties for EPA's Compliance Data System
(CDS) network in the AQCR. Additional point sources
may exist in the AQCR but have not yet been identified.
Data submitted by the ARE for the second quarter of
1976 indicate that 91 percent of the identified point
sources are in compliance with all applicable portions
.of the State Implementation Plan. Of the remaining
point sources 6 percent are on compliance schedules and
3 percent are either of unknown status or are in vio-
lation of an emission regulation and not yet on a
compliance schedule.
The available EPA-CDS data would indicate that air
quality violations are not due to lack of enforcement.
Table VIII contains a list of point sources in
violation of emission regulations and an explanation of
their compliance status.
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TABLE VIII
List and Compliance Status of Point
Sources in Violation of Emission Regulations
Sources Status
El Dorado County
Golden W. Lumber Co. U
Glenn County
Louisiana Pacific, Elk Creek S
Sacramento County
Libby McNeil, Sacramento S
Southern Pacific Pipelines, Sacramento S
Standard Oil, Sacramento ' S
Yolo County
Adams, Schwab, and Adams, Woodland - S
Atlantic Richfield, West Sacramento U
Dixon Dryer, Clarksburg S
Yuba County
Beale AFB, Marysville V
Feather River Lumber Co., Camptonville S
Shasta County
John Stone Sandblast, Redding U
Kimberly-Clark Corp., Anderson S
Simpson Lee Paper Co. S
S"= Not in compliance — on a compliance schedule — meeting
the compliance schedule
U = Unknown compliance status
V = Not in compliance — violation of an emission regulation
-_ -25-
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F. POINT/NON-POINT (I.E., MAJOR/MINOR) STATIONARY
SOURCE ANALYSIS
EPA is concerned about the cumulative contribution
that relatively small stationary sources make to total
emissions, and therefore, the emphasis that should be
placed on controlling such sources. EPA has called
such relatively small sources "non-point sources", and
has defined such a source as any stationary source that
does not have potential emissions of 100 tons/year or
more. Table IX contains the 1972 emissions data for
point and non-point sources, as well as total emissions,
as supplied to EPA by the California ARE.
Non-point particulate sources emit approximately
62 percent of all particulate emissions. Of these non-
point emission sources, fugitive emissions, which
include emissions from agricultural operations, con-
struction and demolition, and unpaved road travel,
contribute 66 tons/day or approximately 30 percent of
total emissions; combustion of fuels and wood and
mineral processing operations emit 12 tons/day or
approximately 6 percent of total emissions; and fires
set for forest management and agricultural waste burning
emit 31 tons/day or approximately 14 percent of total
emissions.
The primary particulate standard is violated at
four stations. Continual violation of the primary
standard is projected based on the present control
strategy (see Sections II.B. and C.).
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TABLE IX
Point/Non-Point Emission Data
Emissions (Tons/Day)
Non-Point Point Total Stationary Total Stationary
Pollutant Sources Sources Sources and Mobile Sources
CO " Data not available ,
NOX Data not available
TOG Data not available
SOX Data not available
Part 139 67 206 223
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G. COMPARISON OF PRESENT CONTROL STRATEGY WITH
MEASURES CONSIDERED RACT
Table X is a list of emission control measures
that are considered by EPA to meet the definition of
reasonably available control technology (RACT) (see
discussion of RACT in Section I).
A comparison of the present control strategy with
the list of RACT measures will be made in this Section
for those pollutants for which national standards are
violated in the base year, or are projected to be
violated in some future year. Consequently no such
comparison will be made for NOX and SOx emission con-
trol, because the N02 and SOx air quality standards
have not been violated in the base year and no vio-
lations are projected.
The primary oxidant standard, the primary carbon
monoxide standard, and the primary and secondary
particulate standards were violated in the base year
and future violations are projected. Following are
comparisons of the present CO, oxidant, and particulate
control strategies with the RACT control measures
listed for these pollutants.
CO — RACT measures have been promulgated by EPA
(NovemEer 12, 1973, California Transportation Control
Plan), and by the State for the control of mobile
source CO emissions through the application of trans-
portation control measures and an Inspection/Maintenance
program. There are no regulations controlling sta-
tionary sources of CO.
- Ox — The implementation plan submitted by the
State and the EPA-promulgated plan employ the RACT
measures listed in this Section for the control of
non-methane organic emissions and, therefore, oxidants.
There are specific areas where stationary source reg-
ulations can be strengthened or expanded. This pos-
sibility is being actively investigated by the State
and EPA. However, it is determined that RACT measures
are either being implemented or have been promulgated.
This determination could, of course, be changed in the
near future, based on the results of EPA and State
studies.
-28-
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TABLE X
List of Measures Considered Reasonably
Available Control Technology
CO Emissions Control
Source Control Measures:
* Inspection/Maintenance for vehicle emissions control
* Petroleum refinery, chemical plant and other industry
controls
Transportation Measures:
* Transit improvement
* Employer incentives
* Parking management/restrictions
* Traffic management/restraint -
NOx Emissions Control
Combustion Modifications:
* Lower excess air
* Staged combustion
* Burner modification or replacement
* Flue gas recirculation (for gas or oil-fired boilers
with recirculation provisions)
Control of NOx emissions from nitric acid plants:
* Catalytic decomposition
Oxidants Control (Non-Methane organic gas emission control)
Source Control Measures:
* Inspection/Maintenance for vehicle emissions control
* Vapor controls for organic solvents
*
*• - Petroleum refinery, chemical plant and other industry
controls
* Vapor controls for gasoline marketing
-29-
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TABLE X (continued)
Transportation Control Measures:
* Transit improvement
* Employer incentives
* Parking management/restrictions
* Traffic management/restraint
SOx Emissions Control
* Combustion of natural low sulfur fuels
* Combustion of fuels with sulfur content lowered by
technological removal processes
* Control of SOx emissions from sulfur recovery and
sulfuric acid plants
* Control of SOx stack emissions from industrial
processes by gas cleaning devices
Particulate Emissions Control
Section 2 of Appendix B, 40 CFR Part 51 (see below),
lists measures considered by EPA to be RACT for particulates.
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a.O COXTSOI. Oy PA3ZICCULT
2.1 Vijibls emljtians. The emission of
visible air pollutants can be limited to a ;
cbade or density equal to but coi darker '
than that dss'.gnatett. M No. 1 en ths Hlngel-
irann chart or 20 percent opacity except for
brief periods during such operations 23 soot
blowing End startup. Tills limitation •would
generally dimluita visible pollutant emis-
sions frera stationary sources,
Tte erriK-jloa or visible air pollutants from
gasoline-powered raotor vehicles caa be
eliminated eieepi for periods not esceediag
6 consecutive seconds. The emission of visible
Blr pollutants Ircia di±3el»powered motor ve-
hicles can ba limltevi to s shade or density
equal to but not da^er thaa that designated
as No. 1 on tie Eisgeliaasa chart or 20
percent opacity escept for period* not ex-
ceeding 5 consecutive seconds.
2.2 j^uyititia tiujt. ppttsoTrp.hle precautions
bo taken to pr-jreat parttculata matter
from becoming e^irborsa. Soniq of taeset
reasonatila pres&uUaas Includa the follow*
Ing:
(a) Use, lwier» pcsslW*. of trater or
caf.Tti.1cftIa for control of dust la the demoli-
tion of esisUng bxiUdlngs or rtructvs~«3, con-
ctructioai operations, *•>»* grsdln/; of roods
or the clearing of Isad;
(b) AppUsatioa of asphalt, til. •water, or
eultabia r>)gm;r_y'i< oa dirt reads, materials
stockp!l«a, faA other surfaces widcix caa
glvs tts« to airbom* dusts;
(c) X&stallaUoA icxd us« of hoods, fans,
end fabric: filters to enclose &3d Tent the
tmndiJng of dusty ioAt>irlala. Adequato con-
tatsaaeat mathoda caa ba «z=?tloa,
open bodied trttciis, traasportlaaf ditortoia
llisly to gl-e riso to alrborna dusts;
(e) Conduit of agricultural practices such,
as tllliss of laad, application of fertilizers,
etc.. la such, manner &£ to prevent du*t from
becoming eirbonse;
(f) Tha paving of roadways end; their
rc£l&t»naaca La & clean condition;
(g) Tea prompt resioval or earth or other
xza,:erl%l frosa pa~ed str«it8 onto whlcii earth
or other inatertal haa b««a traasrported by
trucking or earta raoTlag equipment, eroetoa
by -witer. or other means.
Z3. Incineration, The ecolssloa of p&rtlc-
tUato matter from any incinerator can be lim-
ited to 0 20 pound per 100 pounds (2 gao/^S-)
Of refuse chargad. This emission IteitatJoa Is
based on the sourca test zoathod for statlon-
ftr-y saurcea of partlculata emissions -which,
vtll be published by ta» Ad=JrUstra^>r. This
method Includes both e. dry filter c=d iret
la=?Uiger3 &sd represanta partlculst* roatter
of 10' F. and 1 0 ataaosphere prcssors.
2.4 Fuel txrT.ir.y equipment. The ci=ls-
e!oa ot partlculat* raaitor from fuel bxiralng
equipment burning solid lusl can ba limited
to 0.30 pound per EiUllon B t u. (0 54 gm/10*
gin-cai) of heat Input. This enisson lltnlt^-
tloa Is based on ths sourc* test method for
stationary sources of part'culate emissions
•which irtU be published by tho Administrator.
This method Includes both a dry filter and
•wet in:?lns2rs tad represents partlculate
ZCAttcr of 70* x1. and 1 0 atmosphere pressure.
2 5 Process Ind^istriea—general. Th a emis-
sion of particular* taatter for tny process
eourca can ba limited In a manner suet £4
la table X Process •*r-!ght p*r hour raesns
the total velgnt of all matertala Introduced
lato &ny specie process that may cause any
emission oJ particulsta raat^r. Solid fuels
charged are cosxsldersd ts part of the process
•we-ght. but liquid tmd gaseous fuels and
combustion air era not. For a cyclical of batch,
operation, taa process weight psr hour Is
derived by illrldlsg the total process -weight
by tha numbs? ol tours In one complete op-
erstionf^Qm tao beginfliig of aay given proc-
esa to tha coiaplotlon thereof, excluding &ay
tlraa fiurtng •which, the equipment Is l£e.
Sor ft continuous operation, the procesa
•weight per hour L-i derlred by dividing the
proceso weight for B typical period of
.Proc&M
veigM rate
(tbJ-Jhr.)
gn ,.,„,„. .Tr
100 .. ,...„
500 ___
l.COO
5,000 .-
lQr*V^r.)
., n ss
^^^ fi.KS
1,53
2. 25
6.34
0 "Jt
„,„ 14, fl9
, LL !><>.erj
JT, a».i9
ss 5n
"" '^~7 ss. 11
<10 35
„ *R 72
Interpolation of tha data la. table Hor th&
process weight rates up to $0,000 Ib3,/hr. sbaJl
be accoinpUsaei by the USB oi tha equation:
E= 3JS9 P*-° P^30 toos/hr.
tnterpolatloa tad extrapolation of the
data for process freight rates In excess of
60.000 lbs-/iu-. *halt bs accocapllsaed by use
of tho equation:
£=17.31 P"* P=»JO tom/hr:
TThera: Z— Eralssloos la poucds perhoiir.
y=Process weight rat* ia. toaj per
liour.
Application cf mass emission limitations
oa ths basis of fill simlias uoits &t B plant
Is recommend^ in order to avoid -unequal
application of this tj-pa ot limitation to
plants -with the SMHB total erolssloa po».
tential but durerent clz» units.
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Particulate — The implementation plan submitted
by the State does not contain a source specific fugitive
dust regulation for this area. At present, fugitive
dust is controlled by the local enforcement of a nuisance
regulation. The adoption of source specific fugitive
dust regulations may prove beneficial in accomplishing
more effective particulate control.
The Ringelmann-opacity regulations in these six
counties of the Sacramento AQCR limit emissions to a
density of 40 percent opacity or #2 Ringelmann. More
stringent opacity regulations should be adopted for the
Sacramento Valley AQCR.
Process weight-emission rate tables for these six
counties are not exactly equivalent to RACT (Appendix B
allowable emission rates) and should be reviewed by the
ARE to determine if it is necessary to require a
greater degree of control.
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III. SUMMARY AND CONCLUSION
For some pollutants, air quality standards vio-
lations occurred during the base year and future vio-
lations are projected. A summary of the control strategy
deficiencies is presented, and a conclusion reached
concerning the need to call for an SIP revision. EPA
must request an SIP revision from the State in cases
where air quality violations are indicated and where
RACT measures are not required either as a result of
State or EPA regulations.
Oxidants/Non-methane Organics — The oxidant
standard is being violated, and standard attainment is
not anticipated. EPA's California Transportation
Control Plan requires implementation of RACT and other
control measures (e.g., gasoline rationing) for re-
ducing non-methane organic emission sources in order to
meet the oxidant standard by 1977. Certain elements of
the Transportation Control Plan were challenged by the
Air Resources Board and others in Federal court, and
this issue is currently being reviewed by the Supreme
Court. Implementation of many of the measures required
under the EPA Transportation Control Plan for the
Sacramento Valley AQCR, and not under court ohallenge
and review, are various EPA enforced stationary source
organic vapor control programs. Upon review of the
regulations in the Sacramento Valley EPA has noted that
some deficiencies still exist. Therefore, EPA will
continue to enforce its organic emissions control
regulations.
While EPA has determined that a major deficiency
in the State submitted oxidant control strategy exists
at-this time (i.e., Inspection/Maintenance), EPA is not
requesting a revision to the State Implementation Plan,
because an Inspection/Maintenance program as well as
other RACT measures are contained in the EPA Trans-
portation Control Plan that is presently under Supreme
Court review.
Since the EPA oxidant control plan is under court
review and oxidant standard attainment is not being
projected, the Air Quality Maintenance Area (AQMA)
planning process should address the problem of standard
attainment, as well as maintenance. EPA has designated
areas nation-wide which are not expected to attain, or
once attained would not maintain, certain of the
National Ambient Air Quality Standards during the
1975-1985 time frame. In such instances, EPA is
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encouraging local governments with assistance from the
State to develop locally acceptable plans for the
attainment and maintenance of the NAAQS for the speci-
fied pollutants, including but not limited to land use
and transportation controls. Such plans are expected
to be submitted as formal revisions to the State Imple-
mentation Plans. In the Sacramento Valley the planning
effort is being guided by an AQMP policy task force
which has recommended that the Sacramento Area Regional
Planning Commission undertake AQMP development. This
effort is being coordinated with a recent designation
of SRAPC to perform Areawide Wastewater Management
Planning (FWPCA §208) as well.
Carbon Monoxide — The carbon monoxide standard is
being violated/ and will continue to be violated until
1980 when a worsening trend will begin.
EPA's California Transportation Control Plan,
promulgated on November 12, 1973, requires implemen-
tation of vehicle Inspection/Maintenance and various
transportation related measures in order to control CO
emissions from mobile sources. Certain elements of the
Transportation Control Plan were challenged by the Air
Resources Board and others in Federal court,"and this
issue is currently being reviewed by the Supreme Court.
A major deficiency exists in the present State sub-
mitted CO control strategy because of the lack of a
vehicle emission Inspection/Maintenance program. EPA,
though, is not requesting a revision to the State
Implementation Plan on this basis at this time because
an Inspection/Maintenance program as well as other RACT
measures are contained in the EPA Transportation
Control Plan that is presently under Supreme Court
review.
The Sacramento Valley AQCR counties do not have
stationary source CO regulations although RACT measures
exist to control emissions from some CO sources.
Therefore, EPA is requesting a SIP revision to
correct this deficiency. Since this AQCR has been
designated an AQMA for carbon monoxide, a plan will be
developed through this process for maintaining the
standards through 1985.
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Particulate Matter — The primary and secondary
particulate standards have been violated in this AQCR.
Estimate of future emissions and air quality indicate
that the primary standards will be violated continually
through 1995. The Sacramento Valley AQCR presently
controls fugitive dust emissions through the provisions
of a nuisance regulation. Adoption of a source specific,
and, therefore, more effective fugitive dust regulation
appears needed; and the adoption of more stringent
particulate controls for industrial process equipment
will be needed in the future.
Since the standard violations appear to be sig-
nificantly affected by fugitive dust emissions which
are not controlled"by RACT, EPA is requesting a SIP
revision to correct this deficiency through the adop-
tion of source specific fugitive dust regulations that
could better control emissions from such non-agricultural
activities as earth moving, demolition, and construction.
The six counties in the ^Sacramento AQCR limit
visible emissions to 40 percent while RACT would require
a limitation of 20 percent. Therefore, EPA is requesting
a SIP revision to correct this deficiency and facilitate
attainment of the.ambient air quality standards.
Maintenance of particulate air quality will be ad-
dressed by the AQMA process.
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