ENVIRONMENTAL PROTECTION AGENCY
ANALYSIS OF THE AIR POLLUTION CONTROL STRATEGY
FOR THE SAN FRANCISCO BAY AREA 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 6
C. Air Quality Projections 12
D. Summary of Present Control Strategies 19'
E. Enforcement Status and Analysis 23-
F. Point/Non-Point (i.e., Major/Minor) 25
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 2
(NAAQS)
TABLE II - List of Monitoring Stations Reporting 8
Violations of National Ambient Air Quality Standards
(1974) ; ,; ,
TABLE III - Summary of "the 1973 Emission Inventory 13'
for the San Francisco Air Basin
TABLE IV - Emission Inventory Growth Factors 14
Projected from Base Year 1973
TABLE V - Summary of the 1973 Ambient Concentrations 15 -
TABLE VI - List and Compliance Status of Point 24
Sources in Violation of Emission Regulations
TABLE VII - Point/Non-Point Emission Data 27
TABLE VIII - List of Measures Considered Reasonably 30
Available Control Technology (RACT)
FIGURES
FIGURE I - Location of Carbon Monoxide Monitoring 9
Stations and Distribution of 8-hour CO Standard
Violations (1974)
FIGURE II - Location of Oxidant Monitoring Stations 10
and Distribution of 1-hour Oxidant Standard
Violations (1974)
FIGURE III - Location of Total Suspended Particulate 11
Monitoring Stations and Distribution of 24-hour
Secondary Particulate Standard Violations (1974)
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1. 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:
a) primary ambient air quality standards are those which
allow an adequate margin of safety and are requisite to
protect the public health, and b) secondary standards are
those which are requisite to protect the public welfare from
adverse effects associated with the presence of air pollu-
tants 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 (enforcable
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 available 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, and to request a plan revi-
sion. While the Clean Air Act requires attainment of both
primary and secondary 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 sub-
mission of revisions by the State. An SIP revision which
requires the application of all achievable emission limita-
tions 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).
i;
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TABLE I
NATIONAL AMBIENT AIR QUALITY STANDARDS (NAAQS)
Pollutant
Carbon Monoxide (CO)
Nitrogen Dioxide:
(N02)
Photochemical Oxidants
(Ox), 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*
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 AM)
average concentra-
tion*,**
80 ug/m3 (0.03 ppm)
annual arithmetic
mean; and
365 ug/m3 (0.14 ppm)
24 hour average
concentration*
75 ug/m3 annual geo-
metric mean; and
260 ug/m3 24 hour
average concentra-
tion*
Secondary Standard
Same
Same
Same
Same
Same
1,300 ug/m3 (0.5 ppm
3 hour average
concentration*
150 ug/m3 24 hour
average concentra-
tion*
*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 all other control mea-
sures necessary to meet the national standards must be
submitted 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 presumption of no more than
three years, although additional 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 documents, 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 prob-
lem, and a comparison of the present control strategy with
reasonably available control measures, for each air quality
control region (AQCR).
3..
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II. ANALYSIS
A. SUMMARY OF AIR QUALITY ANALYSIS DOCUMENTS
Following are summaries of formal documents reviewed
by EPA in assessing the air pollution problem in the
San Francisco Bay Area Air Quality Control Region
(AQCR) :
1. Prediction of the Effects of Transportation
Controls on Air Quality in Major Population
Areas, prepared by TRW, Inc. for EPA, APTD-
1363, November 1972:
This study was not directed at standard
attainment.
The study estimated 1977 San Francisco Bay
Area AQCR hydrocarbon emissions reductions from
1968 levels of 42 percent through internal automotive
controls, an additional 12 percent through imple-
mentation of an Inspection/Maintenance program and
less than 5 percent through traffic flow controls.
The study estimated 1977 San Francisco Bay
Area AQCR carbon monoxide emission reductions from
1968 levels of 35 percent by additional internal
automotive controls, an additional 10 percent
reduction through implementation of an Inspection/
Maintenance program, and a 20 percent reduction
through implementation of vehicle miles traveled
(VMT) reduction measures.
2. Air Quality Implementation Plan Development
for Critical California Regions, San Francisco
Bay Area Intrastate AQCR, prepared by TRW,
Inc. for EPA, August 1973:
This study was directed at identifying measures
which would allow attainment of the National
Ambient Air Quality Standards. Particulate,
reactive hydrocarbon, nitrogen oxides and carbon
monoxide emissions are estimated for the base year
of 1971, and projections are made for the years
1975, 1977 and 1980. The report concludes:
"Presently planned stationary and mobile source
controls are inadequate for achieving the ambient
air quality goals; therefore, additional control
measures are clearly indicated."
4.
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3. National Assessment of Particulate Problem,
Volume XIII, San Francisco, California, Draft
Final Report, prepared by GCA Corporation for
EPA, February 1976:
This report is one of a series of similar
studies done in other areas throughout the country
to provide a nationwide assessment of the nature
and reasons for the problem of non-attainment of
the national ambient particulate standards. The
report is structured so as to provide comparable
data on air quality, emissions, regulations,
compliance and other factors that may affect
particulate levels so that an assessment can be
made of the particulate problem, with recommendations
for actions to be taken.
This report indicates that fugitive dust
emissions make a major contribution to the violation
of the secondary standard, and suggests that the
control of fugitive dust could be improved by
implementing source specific fugitive dust regulations.
Fugitive dust is defined as particulate matter
that becomes airborne due either to forces of wind
or man's activity (e.g., windblown dust from
deserts and tilled farmland, or traffic_on unpaved
roads).
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B. SUMMARY OF AIR QUALITY DATA
The ambient air quality data summary analysis
below is made in an effort to identify the magnitude
and extent of the air pollution problem in the San
Francisco Bay Area Intrastate Air Quality Control
Region (AQCR). The National Ambient Air Quality
Standards (see Section I-Introduction) are the standards
against which -che air quality is evaluated.
The majority of ambient monitoring in the AQCR is
done by the Bay Area Air Pollution Control District
(BAAPCD), but both the California Air Resources Board
(ARB) and EPA operate air monitors in the region. The
BAAPCD routinely submits air quality data to the ARB
which in turn submits both the 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.
The second highest concentration over a 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 in Table II for each
station violating a standard. The second highest
concentration is used since one excursion over the
standard per year is allowed. Stations not violating a
standard are not listed. Oxidant values are corrected
where appropriate by the ARB recommended oxidant cali-
bration correction factors. The correction factors
are 0.85 for the San Diego County Air Pollution Control
District stations, and 0.80 for all other stations
in California except the Los Angeles County Air Pollution
Control District stations, for which no correction
factor is necessary.
A map has been prepared for each standard that has
been violated in the AQCR illustrating the location of
all monitoring stations for which there are data in the
NADB, and indicating the stations where violations
occurred and the station with the maximum concentration
(See Figures I thru III).
Following are brief discussions of the monitoring
and the air quality for each pollutant:
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Carbon Monoxide (CO):
There were 15 continuous instruments monitoring CO
in the AQCR in 1974. They were distributed throughout
the metropolitan area. The 8-hour CO standard was
violated at 4 of the stations. The maximum second
highest concentration at any one station was 1.9 times
the standard, and the maximum number of days the standard
was exceeded at any one station was 21. No violations
of the one-hour standard were reported.
Nitrogen Dioxide (NO2>:
There were 10 stations (8 BAAPCD, one ARE and one
EPA) with continuous monitoring instruments in the
AQCR. There were also 3 EPA National Air Sampling
Network (NASN) 24-hour composite bubbler samplers in
the metropolitan area. None of the stations reported
violations of the N02 standard in 1974.
Photochemical Oxidants or Oxidants (Ox);
There were 22 continuous oxidant monitors (21
BAAPCD, one ARE) in the AQCR. The one-hour oxidant
standard was violated at 20 stations in 1974*. The
maximum second highest concentration at any one station
was 2.6 times the standard, and the maximum number of
days the standard was exceeded at any one station was 65.
Sulfur Dioxide (SO2)'
The BAAPCD operated 10 continuous instruments
monitoring SO2 in the AQCR. Four instruments were
located to monitor the major sources, and the remainder
monitored population exposures in the general vicinity
of the sources. Three EPA NASN 24-hour composite
bubbler samplers were also located in the metropolitan
area. None of the stations reported violations of the
primary or secondary S02 standards in 1974.
Particulate Matter or Total Suspended Particulate (TSP):
There were 14 EAAPCD and 3 EPA NASN high volume
samplers located throughout the AQCR. None of the
stations recorded violations of the primary TSP standards
in 1974. The secondary TSP standard was violated at
two stations. The maximum second highest concentration
at any one station was 1.2 times the standard, and the
maximum percentage of values exceeding the standard at
one station was 4.6 percent.
7.
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TABLE II
LIST OF MONITORING STATIONS
REPORTING VIOLATION OF NATIONAL AMBIENT
AIR QUALITY STANDARDS
LIST OF MONITORING STATIONS (1974)
CARBON MONOXIDE; 8-HOUR AVERAGE; STANDARD =10 mg/m3
Site
Burlingame
San Francisco
San Jose
Vallejo
Second Highest
Concentration
(mg/m3)
10.3
10.5
19.3
13.7
Ratio to
Standard
1.03
1.05
1.93
1.37
Days
Exceeding
Standard
2
2
21
22
OXIDANTS; 1-HOUR AVERAGE; STANDARD = 160 ug/m3
Site
Burlingame
Concord
Fairfield
Fremont
Hayward
Livermore
Los Gatos
Mountain View
Napa
Oakland
Petaluma
Pittsburg
Pleasant Hill
Redwood City
Richmond
San Francisco
San Jose
San Leandro
Sunnyvale
Vallejo
Second Highest
Concentration
(ug/m3)
234
234
203
329
329
391
360
219
203
203
219
172
234
266
172
203
423
266
266
234
Ratio to
Standard
1,
1,
1.
2,
2,
46
46
27
06
06
2.44
2.25
1.37
1.27
1.27
37
08
46
66
08
1.27
2.64
66
66
1
1
1
1
1
1
1,
1.46
Days
Exceeding
Standard
6
14
16
26
29
65
44
12
16
3
7
2
13
9
1
1
60
11
22
15
PARTICULATE MATTER: 24-HOUR AVERAGE; SECONDARY STANDARD = 150 ugA
Site
Livermore
Vallejo
Second Highest
Concentra tion
(ug/m3)
173
183
Ratio to
Standard
1.15
1.22
Days
Exceeded
Standard
4.6%
3.4%
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'Location of Carbon Monoxide Monitoring Stations and Distribution
of 8-hour CO Standard Violations. 1974
Contra Costa Co.
O Monitoring station
0 Station violating NAAQS
A Station with naxlmum concentration
^ •
San Francisco Bay Area intrastate AQCR * ,' *-»-»iii
Figure I
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vocation of Oxidant Monitoring Stations and Distribution of 1-hour
Oxidant Standard Violations.1974
Contra Costa Co.
Monitoring station
Station violating NAAQS
Station with maximum concentration
San Francisco Bay Area Jntras~fate AQCR
figure II
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Location of Total Suspended Particulate Monitoring
Stations and Distribution of Secondary 24-hour
.Particulate Standard Violations.
1974
\ Santa Clara Co.
O Monitoring station
© Station without known
violations; data incomplete
Station violating NAAQS
Station with maximum concentration
San Francisco Bay Area Intrastats AQCR • .*
\rf
Figure m
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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 pollutant
concentrations and the quantity of air pollutant emis-
sions 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 relationship
is determined to exist between emissions and air
quality. 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 inven-
tory developed by the California Air Resources Board
for the San Francisco Bay Area Air Basin, and was
obtained from the ARB in February, 1976 (see Table III).
The San Francisco Bay Area Air Basin boundaries and
emissions closely approximate those for the San Francisco
Bay Area AQCR. Emission inventory growth factors for
this AQCR, and therefore air quality projections, are
developed by using growth factors which are derived
from a Bay Area Air Pollution Control District (BAAPCD)
Emission Trends Report dated February 6, 1976. The
California ARB was able to supply emission inventory
growth projections for two years, 1980 and 1985. With
the exception of nitrogen oxides (NOX) emissions, the
ARB estimates project larger emissions growth factors
than do those of the BAAPCD. The BAAPCD and ARB emission
growth factors are found in Table IV. The ARB projections
are used for worst case analysis purposes. The growth
factors reflect the implementation of only the presently
adopted emission control measures.
The 1973 base year emission inventory for the San
Francisco Bay Area AQCR is shown in Table III, and the
emission inventory growth factors are shown in Table IV.
A list of the 1973 highest and second highest ambient
concentrations for various pollutants, as reported by
the EPA-NADB, is shown in Table V.
A direct proportional relationship is assumed to
exist between sulfur oxides (SOX) emissions and resulting
SO2 ambient concentrations, nitrogen oxides (NOX) emissions
and resulting NO2 ambient concentrations, particulate
emissions and resulting TSP ambient concentrations, CO
12.
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Table III
Summary of the 1973
Emission Inventory for the
San Francicso Bay Area Air Basin
Emission Sources
Emissions (Tons/Day)
CO NO,, TOG*
SO,
Totals
3544
805
1106
281
Part
Stationary
LDV & HDV
Other Mobile
209
3080
260
253
433
119
611
420
75
223
16
42
140
43
20
203
*Refers to "Total Organic Gas" emissions, which are a close
approximation of non-methane organic gas emissions.
13.
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Table IV
Emission Inventory Growth Factors
Projected from Base Year 1973
-
Year
Growth Factor
BAAPCD
ARE
Year
Growth Factor
BAAPCD
ARB
Year
Growth Factor
BAAPCD
ARB
Year
Growth Factor
BAAPCD
ARB
•
Year
Growth Factor
BAAPCD
ARB
CO
1976 1980
.84 .53
.60
NOy
1976 1980
.93 .96
.92
TOG
1976 1980
.85 .71
.85
SOy
1976 1980
1.18 1.60
2.07
PART
1976 1980
.95 1.05
1.23
1985
.30
.49
1985
1.00
.84
1985
.66
.89
1983
1.78
1985
1.1
1.31
1990
.26
1990
1.10
1990
.70
1985 1990
1.65 1.51
2.2
1990
1.15
14.
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Table V
Summary of the 1973 Ambient. Concentrations
Pollutant Concentration
CO
NO2
Ox
SO2
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
24-hour average
Units
mg/m3
mg/m3
ug/m3
ug/m3
ug/m3
ug/m3
ug/m3
ug/m3
ug/m3
High
21
26
70
438*
21
106
No data
66
225
2nd Higl
15
26
-
406*
99
No data
188
*These values are corrected by the California ARE recommended
oxidant calibration correction factor of 0.8.
15,
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emissions and resulting CO ambient concentrations 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 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 estimated 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 previously,
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 NAAQS
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 438 ug/m^, which is 2.7
times the standard. The emission inventory growth
16.
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factors show a reduction in TOG emissions and therefore
oxidant concentrations from 1973 to 1985. Starting in
1985, TOG emissions are expected to increase. The
1-hour oxidant concentration, projected from 1973 to
1985 by the air quality projection technique and the
APCD growth factor, is as follows for this pivotal
year:
* 438 ug/m3 x .66 = 289 ug/m3
* This value is corrected by the California ARE
recommended oxidant calibration correction
factor of 0.8.
The standard is thus projected to be exceeded in
1985 with the occurrence of a maximum 1-hour oxidant
concentration which is 1.8 times the standard. A
worsening trend is expected to follow. Use of the more
pessimistic California ARE growth projections indicates
that even larger standard violations will occur.
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, with a
maximum 8-hour average concentration recorded of 21
mg/m3, which is 2.1 times the standard. CO emissions
are projected to steadily and significantly decline
from 1973 to 1990. 1980 air quality estimated by the
air quality projection technique and using the APCD
growth factor is as follows:
21 mg/m3 x .53 = 11 mg/m3
This concentration is 1.1 times the standard. The
standard is thus projected to be only slightly exceeded
in 1980, and standard attainment is expected prior to
1985. Use of the more pessimistic California ARE
growth projections suggests that standard attainment
will occur soon after 1985.
17'.
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TSP AIR QUALITY PROJECTIONS
The primary annual TSP standard (as opposed to the
24-hour standard) was the closest to being violated in
the 1973 base year. The question of continued attainment
of the standard is evaluated as follows, using the 1973
annual concentrations, the air quality projection technique
and the APCD growth factor for the year 1990:
66 ug/iri-^ x 1.15 = 76 ug/m^
The national annual primary standard of 75 ug/m^
is thus projected to be slightly exceeded in 1990.
Particulate emissions began increasing in 1975 and are
expected to continue to increase through the year 1990,
primarily as a result of the decreased use of natural
gas and the substitution of fuel oil for combustion
processes. Use of the more pessimistic California ARE
growth projections suggests that the annual standard
will be violated by 1980. The national secondary
ambient particulate standard was exceeded in 1973 and
in 1974, and violations are expected to continue as a
result of the projected increase in particulate emissions,
unless additional emission control measures are implemented,
18.
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D. SUMMARY OF PRESENT CONTROL STRATEGIES
Following are general descriptions of the present air
pollutant emission control strategies:
NOX 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 applied by the use of such techniques
as exhaust gas recirculation, two-stage combustion, and
low excess air. The techniques are primarily applied
to the larger stationary source combustion processes.
Reducing WOX emissions from new and in-use vehicle
engines is primarily accomplished by lowering peak
combustion flame temperatures through the use of
ignition retard, and exhaust gas recirculation techni-
ques. The BAAPCD has adopted regulations controlling
NOX emissions. In summary, these regulations limit NOx
emissions from certain new and modified equipment to
125 PPM for gaseous fuel use and 225 PPM for oil fuel
use; and for certain in-use equipment, NOx emissions
are limited to 175 PPM for gaseous fuel use, and 300
PPM for oil fuel use.
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 are controlled by
requiring the improved efficiency, sizing, and opera-
tion of plant equipment; and, in some cases, stack
scrubbing is employed. Stack gas scrubbing for SOX
removal is not widely used at this time in this AQCR.
The BAAPCD has adopted an SOX emission control regula-
tion that either requires a specific SOX exhaust gas
concentration limitation; or requires the employment of
a ground level monitoring system. In summary, the SOX
emissions regulation requires that sources either limit
their SOX stack emissions to 300 PPM or install a
ground level ambient SO2 monitoring system and be sub-
ject to certain SO2 ambient concentration requirements.
19
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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 C02 gas as a
result of improved engine combustion efficiency; ox-
idizing exhaust CO to C02 by the use of a catalyst de-
vice in the exhaust system; promoting the use of more
volatile fuels (e.g., liquified petroleum gas and com-
pressed 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 BAAPCD regulations which require the
control of CO emissions from stationary sources.
Ox Control;
Ambient concentrations of photochemical oxidants
(Ox) are reduced by controlling the emissions of the
primary oxidant precursor, reactive hydrocarbons (HC)
(i.e., non-methane organics). Mobile source HC emis-
sions 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 emissions 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 CO2 and water by the use
of a catalyst device in the exhaust system; promoting
the use of more volatile fuels (e.g., liquified petrol-
eum gas and compressed natural gas) and thereby improving
combustion efficiency; and implementing various trans-
portation control measures such as bus and car pool
lanes and transit improvements, which reduce the amount
of HC-producing activities.
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
20.
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emissions), adsorption (collection of a gas on a spe-
cial material or surface), absorption (transfer of a
soluble gas to a non-volatile liquid absorbant), and
condensation (collecting organic emissions by lowering
the gas stream temperature to the appropriate conden-
sation point). The BAAPCD has adopted a regulation
(i.e., Regulation 3) which controls HC emissions from a
range of stationary HC emissions sources.
Particulate Control
Visible emissions - Presently, Ringleman One (20%
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 20% for
longer than three minutes in any hour is in violation.
Open burning - Regulation One bans dump fires and back
yard trash burning. It also subjects agricultural
burning to meteorological controls. Farmers are allowed
to burn their crop waste during specified seasons on
district-approved "burn" days. Exempted from Regulation
One'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 undergrowth in irrigation ditches.
Incineration - Emissions from an incinerator with a
capacity greater than 100 tons per day are limited to
0.05 grains per standard dry cubic foot (scf). For an
incinerator with a capacity of less than, or equal, to,
100 tons per day, the emission limit is 0.15 grains per
standard cubic foot. The new source performance stand-
ard is 0.08 range per standard cubic foot for incinera-
tors with a capacity greater than 50 tons per day. The
incinerators must also meet SO2, H2S, hydrocarbon and
carbonyl emission limitations.
Fuel burning - Particulate emissions from a combustion
operation are limited to 0.15 grains per standard cubic
foot (0.25 pounds per 10^ BTU) regardless of the size
of the facility. The new source performance standard
for fossil fueled steam generators is 0.10 pounds of
particulate matter per million BTU heat input.
General processes - The allowable particulate emissions
for manufacturing processes are on a process weight
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rate basis. Exemptions from this weight rate can be
granted if the source can demonstrate that it does not
exceed a grain loading weight, ranging from 0.10 gr/scf
to 0.02 gr/scf depending on the gas volume.
Fugitive Dust - San Francisco does not have a specific
fugitive dust regulation, relying instead on control of
such sources under a nuisance provision of Regulation
Two and Article 10 of the Bay Area Air Pollution Control
Law. These controls prohibit a person from allowing
particulates of sufficient number and of a size large
enough to be identified as individual particulates at
the source, to fall on the property of another, thereby
constituting an nuisance.
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E. ENFORCEMENT STATUS AND ANALYSIS
Approximately 109 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 Bay Area APCD 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 ARB for the third quarter
of Fiscal Year 1976 indicate that 87 percent of the identified
point sources are in compliance with all applicable por-cions
of the State Implementation Plan. Of the remaining point
sources, 3 percent are on compliance schedules and 10 percent
are either of unknown status or are in violation of an emis-
sion 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 VI contains a list of point sources in
violation of emission regulations and an explanation of
their compliance status.
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Table VI
LIST AND COMPLIANCE STATUS OF POINT SOURCES IN
VIOLATION OF EMISSION REGULATIONS
Sources Status
Alameda County^
General Motors, Fremont V
Costra Costa County
Monsanto Chemical (Avon Plant) VS
Martinez
Phillips Petroleum (Avon Refinery) VS
Martinez
Fibreboard, Antioch U
C&H Sugar, Crocket U
San Francisco County
Feedstuffs Processing, V
San Francisco
Santa Clara County
Ford, Milpitas "~~" V
Solano County
Newhall Land Farming, Dixon
Travis AFB, Fairfield V
Sonoma County (Northern)
Boise Cascade, Healdsburg U
G&R Lumber Co., Cloverdale V
Annapolis Milling, Annapolis V
Chenoweth Lumber, Bodega S
Harris Pine Mills, Healdsburg U
M.G.M. Brake, Cloverdale U
Masonite Corp., Cloverdale U
Rolando Lumber Co., Cloverdale U
Key
S = Not in compliance—on compliance schedule—not
in violation of compliance schedule
V = Not in compliance—violation of emission
regulation
VS = •Violation of compliance schedule
U = Unknown
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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 the potential for emitting more
than 100 tons/year. Table VII contains the 1974
emissions data for point and non-point sources, as well
as total emissions, as supplied to EPA by the California
ARE.
Non-point SOX emission sources are apparently
insignificant, and at any rate, there appears to be no
SC>2 air quality problem in the AQCR, based on the SO2
analysis in Sections II.B. and C. Therefore, no additional
emphasis on non-point SOX emissions control is called
for at this time.
Non-point particulate sources emit approximately
59% of all particulate emissions. Of these^non-point
emission sources, fugitive emissions, which"include
emissions from agricultural operations, construction
and demolition, and unpaved road travel, contribute 33
tons/day or approximately 15% of total emissions;
mineral processing and manufacturing operations emit 27
tons/day or approximately 13% of total emissions; and
food and agricultural processing operations emit 21
tons/day or approximately 10% of total emissions.
The secondary particulate standard is violated at
two stations. Continual violation of the secondary
standard is projected based on the present control
stategy, and violation of the primary standard is
projected to occur as early, perhaps, as 1980 (see
Sections II.B. and C.).
Analysis referenced in Section II.A.3. suggests
that more stringent control of fugitive emissions may be
justified and that such control could be accomplished
if source specific fugitive dust regulations were
introduced. These regulations would be in addition to
the nuisance regulation which is presently being enforced
to control fugitive dust emissions.
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The contribution of non-point mineral processing
and manufacturing operations, and food and agricultural
processing operations to total particulate emissions is
significant, and accounts for 23% of total emissions.
EPA has no analysis to show that more stringent regulations
based on RACT, or more vigorous enforcement of the
present regulations, would reduce the emissions from
these two categories.
26.
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Table VII
Point/Non-Point Emission Data
Emissions (Tons/Day)
Non-Point Point Total Total Stationary
Pollutant Sources Sources Stationary and Mobile
Sources Sources
CO Data Not Available
NOX Data Not Available
TOG Data Not Available
SOX 4 223 227 282
Particulate 128 25 153 218
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G. COMPARISON OF PRESENT CONTROL STRATEGY WITH MEASURES
CONSIDERED RACT
Table VIII is a list of emission control measures
that are considered by EPA to meet the definition of
reasonably available control technolocy (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 control,
because the NC>2 and SOX air quality standards have not
been violated in the base year and no violations are
projected.
The primary oxidant standard, the primary carbon
monoxide standard, and the secondary particulate standard
were violated in the base year and future violations of
the primary particulate standard are projected. Following
are camparisons 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 (November 12,
1973, California Transportation Control Plan), and by
the State for the control of mobile source CO emissions
through the application of transportation control
measures and an Inspection/Maintenance program. There
are, however, no controls on CO emissions from petroleum
refineries, chemical plants, and other industrial
sources; therefore RACT measures are not being employed
for these stationary emission sources. Stationary
source CO controls should be required.
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 may be
specific source categories for which stationary source
regulations can be strengthened or expanded. This
possibility is being actively investigated by the State
and EPA. However, it is determined for now that RACT
measures are either being implemented or have been
28.
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promulgated. This determination could, of course, be
changed based on the results of the EPA and State
studies.
Particulate:
The implementation plan submitted by the State
contains with one exception, the RACT measures listed
in this section. This one exception results from the
lack of an adequate fugitive dust regulation in effect
for this area. At present, fugutive dust emissions are
controlled by the local enforcement of an nuisance
regulation. It is EPA's opinion that certain source
specific fugitive dust regulations are RACT measures,
and should be adopted.
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Table VIII
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
NOy 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
30.
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* Petroleum refinery, chemical plant and other industry
controls
* Vapor controls for gasoline marketing
Transportation Control Measures:
* Transit improvement
* Employer incentives
* Parking management/restrictions
* Traffic management/restraint
SOy 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.
31.
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TIONS
ABLE TECUMOIXJGT
or EMISSIOH
wrriz
AVAIL-
9.0 CONTSOt OP yjUrlCULATE EMISSIONS
2.1 Vistula emlations. The emission of
visible sir pollutants can be limited to a
shade or density equal to but cot darker
tb.an that designated as Ko 1 on the JUngel-
Tnftnn chart or 20 percent opacity except for
brief periods during such operations as soot
blowing and startup. Tills limitation •would
generally eliminate visible pollutant emls-
Eloas from stationary sources.
The emission of visible air pollutants from
gasoline-powered motor vehicles can be
eliminated except for periods not exceeding
6 consecutive seconds. The emission of risible
air pollutants from dlesej-powered motor ve-
hlcles can be limited to a shade or density
equal to but not darker than that designated
&s Ho. 1 on the Hlngelraann chart or 20
percent opacity except for periods not ex-
ceeding 5 consecutive seconds.
2.2 Fuciitt>e dust. Reasonable precautions
can be taien to prevent partlculate matter
from becoming airborne. Soma of these
reasonable precautions Include the follow-
ing:
(a) Use, whew possible, of water or
chemicals for control of dust in the demoli-
tion of existing buildings or structures, con-
struction operations, the grading of roads
or the clearing of land;
(b) Application of asphalt, oil, water, or
suitable chemicals on dirt roads, materials
ctoc&pUes. end other surfaces which can
give rise to airborne dusts;
(c) Installation and use of hoods, fans,
and fabric filters to enclose and vent the
handling of dusty materials. Adequate con-
tainment methods can be employed during
sandblasting or other similar operations;
(d) Covering, at all times when in motion,
op»n bodied trucks, transporting materials
llSely to gl-re rise to airborne dusts;
(e) Conduit of agricultural practices such,
as tllUng of land, application o* fertilizers,
etc., in such manner as to prevent dust from
becoming alroorne;
(f) Th9 paving of roadways and their
maintenance in a clean condition;
(g) Tie prompt removal of earth or other
material from paved streets onto whlcli earth
or other material has be*n transported by
trucking or earth moving equipment, erosion
by water, or other means.
2.3 Incineration. The emission of partlc-
ulat« matter from any incinerator can be lim-
ited to 0 20 pound per 100 pounds (2 gm/fcg )
. of refuse charged. This emission limitation is
based on the source test method for station-
ery saiirces of particulars emissions which
will be published by the Administrator. This
zsethod Includes both a dry filter and wet
iraplngers and represents particulars matter
of 70* F. and 1.0 atmosphere pressure.
2.4 Fuel burning equipment. The emis-
sion of particulate matter from fuel burning
equipment burning solid fuel can be limited
to 0.30 pound per million B t.u, (0 54 gm/10«
gm-ca!) of heat Input This emission limita-
tion Is based on the source test method for
stationary sources of participate emissions
which will be published by the Administrator.
This method Includes both a dry filter and
wet inplagera and represents particulate
matter of 70* P. and 1 0 atmosphere pressure.
2 5 Process ind'jatriet—general. The enus-
elon of particulate matter for any process
Bource can be limited In a manner such aa
la table I. Procesa ire'ght per hour means
the total veight of all materials Introduced
Into any specific process that may cause any
emission of partlculate matter. Solid fuels
charged are considered as part of the process
weight, but liquid and gaseous fuels and
combustion air are not. For a cyclical or batch
operation, tna procass weight per tour Is
derived by dividing the total process weight
by the number of hours in one complete op-
eration from the beginning of any given proc-
ess to the completion thereof, excluding any
time during which the equipment is Idle.
For a continuous - operation, the process
weight per hour Is derived by dividing the
process weight tor a typical period of time.
Process
weight rate
(Ibsjhr.)
60 --
100 __
500 _
1.000 __
5.000
IO.COO
20.000 —
60.0CO
80.000 ___
J20.000 -
160,000 __
200,000 -
400.000 __
1,000,000 _
Interpolation of the data In table I for the
process weight rates up to 60,000 lbs./hr. shall
be accomplished by the USB o' the equation:
2=3.59 P*-" P^30 tons/far.
and Interpolation and extrapolation of the
data for process weight rates In excess ot
60.000 lbs./hr. shall be accomplished by use
of the equation:
£=17.31 P"* P=»-30 tons/nr.
Where: £=Emisslon3 In pounds per hour.
P=Process weight rate in tons per
bour.
Application of m«-« emission limitations
on ths basis of all similar units at a plant
Is recommended In order to avoid unequal
application of this type ol limitation to
plants with the same total emission po-
tential but different size units.
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III. SUMMARY AND CONCLUSION
For some pollutants, air quality standard violations
occurred during the base year and for other pollutants
there were no base year violations, but future violations
are projected. For both of these situations, a summary of
the control strategy deficiencies is presented, and a
conclusion reached concerning the need to call for an SIP
revision. Generally EPA should request an SIP revision from
the State in cases where air quality violations are indicated
and where RACT is not required either as a result of State
or EPA regulations. The summary and conclusion is as
follows:
Carbon Monoxide
The carbon monoxide standard is being slightly vio-
lated, and standard attainment is projected as early as 1985
or perhaps shortly thereafter.
EPA's California Transportation Control Plan, promul-
gated on November 12, 1973, requires implementation 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.
While the State has implemented some transportation
related RACT measures (e.g., various bus and carpools lanes)
for CO control in the San Francisco Bay Area AQCR, a major
deficiency exists in the present State submitted 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.
There is, however, no regulation for the control of
stationary source emissions of CO; and because of this EPA
has determined that RACT measures are not being applied.
Therefore, EPA is requesting an SIP revision to correct this
deficiency through the adoption of regulations that will
better control stationary CO emission sources such as petroleum
refinery CO boilers and foundry combustion sources.
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Oxidants/Non-methane Organics
The oxidant standard is being violated, and standard
attainment is not anticipated. EPA's California Transporta-
tion Control Plan requires implementation of RACT and other
control measures (e.g., gasoline rationing) for reducing
non-methane organic emissions 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 by the Transportation Control Plan
will depend upon the Supreme Court decision.
Among the measures required under the EPA Transporta-
tion Control Plan for the San Francisco Bay Area AQCR, and
not under court challenge and review, are various stationary
source organic vapor control programs. The Bay Area Air
Pollution Control District subsequently adopted or modified
its regulations to implement such vapor control programs
(Regulation 3). Upon review of the District's Regulation 3,
EPA has noted that some deficiencies still exist. There-
fore, EPA will continue to enforce its organic emissions
control regulations, especially 40 CFR 52.254.
While EPA has determined that a major deficiency in the
State submitted oxidant control strategy exists at this time
(i.e., lack of 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 Transportation Control Plan that is
presently under Supreme Court review. There may be specific
source categories for which stationary source regulations
can be strengthened or expanded. This possibility is being
actively investigated by the State and EPA. However, as
previously stated, it is determined for now that RACT measures
are either being implemented or have been promulgated.
This determination could be changed based on findings from the
EPA and State studies.
Since the EPA oxidant control plan is under court
review and oxidant standard attainment is not being proj-
ected, 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
34.
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instances, the California ARB and EPA have been encouraging
local governments with assistance from the State to develop
locally acceptable plans for the attainment and maintenance
of the standards for the specified pollutants, including but
not limited to land use and transportation controls. Such
plans are expected to be submitted as formal revisions to
the State Implementation Plans. In the San Francisco Bay
Area the planning effort has been integrated into a larger
scale Environmental Management Plan development process of
which air quality is a discrete element. Designated pollutants
in the San Francisco Bay Area are oxidants, sulfur oxides
and particulate matter.
Particulate Matter
The primary particulate standards have not been vio-
lated in this AQCR. However, the secondary particulate
standards has been violated. Estimates of future emissions
and air quality indicate that the primary standards will be
violated, perhaps before 1980, and the continued violation
of secondary standards appears certain.
The Bay Area APCD 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 fuel
burning equipment may also be needed in the future. The
issue of particulate emissions control for industrial fuel
burning equipment is to be dealt with through the AQMA
planning process. Since the AQCR has been designated an
AQMA for particulate matter, a plan will be developed through
this process for maintaining the standards through 1985.
Therefore, EPA at this time is not requesting an SIP revi-
sion for the control of particulate matter from industrial
fuel burning equipment.
However, since the secondary standard violation appears
to be significantly affected by fugitive dust emissions
which are not controlled by RACT, EPA is requesting an SIP
revision to correct this deficiency through the adoption of
source specific fugitive dust regulations that could better
control emissions from such activities as earth moving,
construction and demolition.
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