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).
                              -1-

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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).
                          -3-

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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.
                               -4-

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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).
                          -5-

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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
                                     »            -V~~
@   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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              Shasta Co.
                (part)
                            L..
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                                                Plumas Co.



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          Glenn Co.
                             Butte Co>
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                                               / Placer Co.
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O Monitoring station

® Station violating NAAQS
                                     " t
© Station with maximum concentration   j  /*•——
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                                              U
                                                                 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

•

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i
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                (part)
                o
                      
                  Teharra Co.
                                »—
                                         n
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                                                       Plurtas Co.
                                        V
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          Glenn Co.
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                          /
                                    Butts Co.
                                        e
                                    Yuba
          "X /
                                               .
                                                
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                   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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       «                              r-»'     •          Plumas Co.         \

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                    %                            e /       E! Dorado Co.
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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.
                          -11-

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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.
                          -12-

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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
                          -13-

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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
                               -14-

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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.
                              -15-

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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.
                              -16-

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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.

                        ---17-

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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
                          -18-

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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.
                         -19-

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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.

                           -20-

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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
                          -21-

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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.
                          -22-

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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.
                          -23-

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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.
                          -24-

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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.).
                          -26-

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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
                              -27-

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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.
                               -30-

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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.
                                                  -31-

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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.
                           -32-

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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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