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EPA-450/3-75-080-fo
AIR QUALITY ANALYSIS
EXECUTIVE SUMMARY
by
R.R. Cirillo, T.F. Tschanz , and A.E. Smith
Argonne National Laboratory
Argonne, Illinois 60439
Interagency Agreement No. EPA-IAG-D6-0902
Project No. F 52047
Program Element No. 2AO129
EPA Project Officer: David C. Sanchez
Prepared for
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Air and Waste Management
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
February 1976
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This report is issued by the Environmental Protection Agency to report technical
data of interest to a limited number of readers. Copies are available free of
charge to Federal employees, current contractors and grantees, and nonprofit
organizations - as supplies permit - from the Air Pollution Technical Information
Center, Environmental Protection Agency, Research Triangle Park, North
Carolina 27711; or, for a fee, from the National Technical Information Service,
5285 Port Royal Road, Springfield, Virginia 22161.
This report was furnished to the Environmental Protection Agency by Argonne
National Laboratory, Argonne, Illinois 60439, in fulfillment of Interagency
Agreement No. EPA-IAG-D6-0902. The contents of this report are reproduced
herein as received from Argonne National Laboratory. The opinions, findings,
and conclusions expressed are those of the author and not necessarily those
of the Environmental Protection Agency. Mention of company or product names
is not to be considered as an endorsement by the Environmental Protection
Agency.
Publication No. EPA-450/l-75-080-b
11
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TABLE OF CONTENTS
No. Title
1 INTRODUCTION
2 TECHNICAL PROBLEM AREAS
2.1 AIR QUALITY DATA
2.2 METEOROLOGY
2.3 EMISSION INVENTORY UPDATE
2.4 EMISSION PROJECTIONS
2.5 SUBCOUNTY ALLOCATIONS
2.6 MODELING
2.7 ANALYSIS OF MODELING RESULTS
2.8 STRATEGY DEVELOPMENT
2.9 STRATEGY SELECTION
2.10 SPECIAL ISSUES
3 EVALUATION OF THE WORKSHOPS
3.1 ADDITIONAL INFORMATION NEEDED
3.2 RELATION TO OTHER PROGRAMS
3.3 OVERALL EVALUATION
4 CONCLUSIONS
REFERENCES
1
4
4
5
6
10
12
13
15
16
19
20
23
23
27
28
29
32
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LIST OF TABLES
Page
1. Attendance at Air Quality Analysis Workshops 2
2. Distributions of Questions Concerning Air Quality Data .... 4
3. Distribution of Questions Concerning Meteorology • 6
4. Distribution of Questions Concerning Emission Inventory Update . . 7
5. Distribution of Questions Concerning Emission Projections ... 10
6. Distribution of Questions Concerning Subcounty Allocations ... 12
7. Distribution of Questions Concerning Modeling ....... 14
8. Distribution of Questions Concerning Analysis of
Modeling Results 15
9. Distribution of Questions Concerning Strategy Development ... 17
10. Distribution of Questions Concerning Strategy Selection .... 19
11. Distribution of Questions Concerning Special Issues 20
12. Distribution of Recommendations for Additional Guidance .... 24
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1. INTRODUCTION
Between November 24, 1975 and December 19, 1975 a series of eight two-
day Air Quality Analysis Workshops were conducted by the Energy and Environ-
mental Systems Division of Argonne National Laboratory under contract to the
Control Programs Development Division of the U.S. Environmental Protection
Agency. It was the objective of these workshops to provide assistance to
working level air pollution control engineers and regional, state, and local
1—13
planners in the use of previously published EPA guidelines for the devel-
14
opment of an analysis conforming with current federal regulations.
The major emphasis of the workshops was on the analytical and technical
procedures rather than on policy. They were designed to cover the entire
scope of an air quality analysis and used a fictitious county, County X,
based primarily on Fulton County, Georgia, to illustrate the procedures.
Several practical problems were included as part of the material. The test
case and problems dealt mostly with the analysis of particulate problems.
This was done to limit the scope of the workshop to a manageable size.
Workshops were held at EPA Regional Offices in Atlanta, Boston, New
York, Chicago, Denver, Seattle, Dallas, and Philadelphia. Representatives
of EPA, Region VII (Kansas City), and some of the state and local agencies
in that region attended the workshops in Chicago and Dallas. Workshop par-
ticipants were invited at the discretion of the Regional Office staff and
an attempt was made to assemble a cross-section of air pollution control,
planning, transportation, and other environmental control agency staff.
Table 1 indicates the distribution of attendees. It must be noted that at
some workshops a full attendance list was not taken so the counts are somewhat
incomplete. The table shows that state and local air pollution control agency
staff constituted the largest participant group. With the exception of the
Atlanta workshop, all had some representation of planning groups with Chicago
having the largest contingent. There was scattered representation of trans-
portation planners, other environmental control groups, and private contractors,
The indications were that the workshops reached the desired groups and about
in the expected proportions.
The objective of this report is to summarize the results of the work-
shops in terms of problem areas in the analytical techniques, issues needing
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Table 1. Attendance at Air Quality Analysis Workshops
Air Pollution Control
City
Atlanta3
Boston
New York
Chicago
Denver
Seattle
Dallas
Philadelphia
TOTAL
Federal
11
11
9
7
6
4
5
8
61
State
8
6
17
19
9
5
10
6
80
Local
10
0
5
18
0
7
6
15
61
Planning
State
0
0
0
1
1
0
0
2
4
Local
0
8
12
23
8
9
14
11
85
Transportation Planning
Federal
1
1
1
2
3
0
4
0
11
State
0
0
7
2
5
0
2
2
18
Local
0
0
0
0
0
0
0
0
0
Other Environmental
Federal
0
1
2
0
1
0
0
0
4
State
0
0
0
0
2
0
0
0
2
Local
1
0
0
0
1
0
0
0
3
b
Other
2
11
0
0
0
2
0
2
15
Counts based on questionnaire responses and do not represent total attendance.
Includes contractor, consumer group, industry representatives.
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resolution, and identification of points that require additional guidance.
The conclusions presented are designed to aid in the development of future
action plans for EPA. The format of this summary will follow that of the
air quality analysis workshop; that is, each technical analysis area will
be addressed in turn. A review of the policy issues raised and the logistics
of the workshops themselves will also be included.
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2. TECHNICAL PROBLEM AREAS
2.2 AIR QUALITY DATA
Section 3.1 of the workshop manual discussed the development of a base-
line air quality data base. Table 2 summarizes the questions and comments by
regional workshop.
Table 2. Distributions of Questions Concerning Air Quality Data
Workshop
Atlanta
Boston
New York
Chicago
Denver
S eattle
Dallas
Philadelphia
TOTAL
Number of Questions and Comments
Larsen's Observation Accuracy of
Methods Periods Measured Data
2 1
3 2
2
2 1
1 2
1
11 4 2
Lavsen's Method. The use of Larsen's statistical methods to estimate
pollutant concentrations raised the most questions about air quality data.
There was considerable concern as to whether a Larsen-type estimate of concen-
trations should be used as the basis for plan development or whether only
measured data should be used. The response to these questions was that Larsen's
method may be used as a planning tool and can be used in plan development
but that an assessment of a station being in violation of the National Ambient
Air Quality Standards could be made on the basis of measured data only. This
line of discussion led to inquiries as to the accuracy of Larsen's methods
(i.e. do they under- or over-predict), the "tailing off" of air quality data
at the upper end of the Larsen line, tests for log-normality, and the use
of other statistical means to determine concentrations from incomplete data
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sets. The general feeling seemed to be that the use of an estimated concen-
tration based on Larsen's techniques could leave plans open to severe
challenges based on the accuracy of the method. Some reemphasis of EPA's
position on this issue may be required.
Observation Periods . Another point of uncertainty that appeared
several times was the period of time over which concentrations are measured
and their representativeness. There was some feeling that since episode
conditions could lead to the highest concentration value and also second
highest concentration value, use of this sequentially occurring second high-
est concentration could lead to overly restrictive control plans. Some
agencies expressed the desire to eliminate certain data from consideration
on this basis as well as data from other unusual conditions (e.g, dust storms).
Response from Regional Office representatives indicated that all air quality
data should be submitted with the plan but that consideration would be given
to requests that certain data be eliminated providing sufficient justification
was available.
Accuracy of Measured Data. In several workshops questions arose as to
the reliability of monitored air quality data. Results were quoted of exper-
iments that showed two monitors located side-by-side could have substantially
different readings. The response to this was that these types of considera-
tions might be included in a discussion of the accuracy and reliability of
the analysis as provided for by the proposed regulations.
2.2 METEOROLOGY
Section 3.2 of the AQAW manual addressed the meteorological data require-
ments. This section did not generate a great deal of problems. Table 3 sum-
marizes the questions.
Worst Case Data. The question arose as to the use of worst case
meteorological data. It was not clear if an absolute worst case condition
that occurs only once in a long period of time should be used for plan develop-
ment or if a worst case segment of a typical year should be used. The use of
a typical year's data vs. long-term climatological averages also arose in the
same context. It appeared that the Regional Offices were not experiencing
a great deal of difficulty in resolving these issues on a case-by-case basis.
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Table 3. Distribution of Questions Concerning Meteorology
Number of Questions and Comments
Workshop Worst Case Data Unusual Meteorology
Atlanta 1
Boston 2
New York
Chicago
Denver
Seattle 1
Dallas 1
Philadelphia
TOTAL 3 2
Unusual Meteorology. Some states were having problems identifying the
appropriate meteorological data to use for unusual conditions (e.g., peninsula
effects, uneven terrain, etc.). The response was advice to be certain that
the dispersion model used was, in fact, capable of handling these conditions
and to avoid expending a great deal of effort on identifying the meteorology
precisely when the model is not sensitive to it. In two regions participants
commented that they had already made modifications to existing dispersion
models to account for complex meteorology. The models mentioned were Miller-
Holzworth and AQDM.
2.3 EMISSION INVENTORY UPDATE
Section 3.3 of the manual described procedures for updating the emission
inventory. Table 4 summarizes the questions and comments.
Fugit-ive Pust. The issue that raised the most questions was, by far,
the problem of estimating fugitive dust emissions. The questions arose at
every workshop. The most frequent question concerned the quality of the EPA-
published emission factors for fugitive sources. Some states were encount-
ering situations where the fugitive dust calculations comprised the largest
part of their emission inventory and would, therefore, present severe
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difficulties in devising control strategies. One state was using the fugi-
tive dust emission rate to, in effect, calibrate its dispersion model; that
is, the emission factors were adjusted until a good validation was achieved.
Some states reported such a lack of confidence in the emission factors that
they were not using them at all and were, instead, treating the situation
as background only. There were questions as to the validity of using a single
fugitive dust emission rate rather than one that is seasonally dependent.
Table 4. Distribution of Questions Concerning Emission Inventory Update
Workshop
Atlanta
Boston
New York
Chicago
Denver
Seattle
Dallas
Philadelphia
TOTAL
Fugitive
Dust
6
1
4
3
1
4
4
23
Number of
Fuel
Combustion
Sources
2
4
1
4
2
13
Questions and Comments
Point Trans- Validity of
Source portation Volume 7
Updating Data Procedures
3
1
1 1
1 1
2 1
2
922
There were questions as to the acceptability of using a particle size
cutoff of 30 urn. It was stated that HiVol samplers could collect larger
particle sizes and thus the emission estimates, especially near the source,
could be underestimates. It was also felt that the cutoff values for the
smaller particle sizes specified in Reference 15 might not be applicable
everywhere.
There were several questions on how soil silt content is determined
but these seemed to be the result of a lack of familiarity with soil analysis
techniques and thus present no special problems.
A number of questions arose as to how to estimate fugitive dust emis-
sions from sources other than the four listed in Reference 15 (i.e., unpaved
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roads, agricultural tilling, aggregate storage, and heavy construction).
Dust from paved roads was the most asked-about category but questions also
arose about agricultural fertilizer use, and vacant lots. The issue of
reintrainment of dust was raised a number of times with many feeling that
this phenomenon is creating many problems that cannot be adequately treated
at this time.
The general response to the questions on fugitive dust was that EPA
recognized the difficulties in getting good emission estimates and that the
current information was only a rough start; however, substantial research
efforts were under way to improve the information and in the meantime, the
published data could be used for plan development. The general impression
of the Argonne instructors was that most of the states had attempted to
address the fugitive dust emission estimation problem in one form or another
and that they would be most receptive to improved information. The many
criticisms about the current information were made in primarily a constructive
and suggestive fashion rather than in a purely critical fashion and the local
insight might make some valuable contributions to the development of better
data.
Fuel Combustion Sources. Several difficulties were apparent with the
development of an updated inventory for fuel combustion sources, the most
troublesome of which was the obtaining of oil consumption data. Several
states indicated that fuel oil dealers and state energy agencies were not
supplying the type of data needed. In many cases this was due to its general
unavailability. One question asked was if there is some form of legislation
to require disclosure of the information. Some state energy agencies were
compiling state fuel use and energy budget information, which, it was hoped,
could be coupled to the air quality analysis.
Commercial/institutional fuel use presented problems in two regions.
The procedures in Reference 7 led to negative fuel consumption estimates and
it was felt that these sources might require significant effort for emission
estimates.
The question of whether or not state energy conservation programs
and/or the impact of fuel shortages should be accounted for arose on two
occasions. The response was that they definitely should be, especially
when a model was to be validated on air quality data taken in time periods
where these programs had an effect.
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The use of the Steam Electric Plant Factors report by the National
Coal Association was considered to be of limited value since the data are
two years behind and the data do not contain fuel sulfur and ash contents.
More recent and complete data require more resources to extract.
The use of fuel intensity ratios for industrial fuel requirements was
questioned. It was stated, however, that these were probably better than
using only industrial heating requirements.
Point Source Updating. Virtually every state is using a Level 3, or
interview procedure, to update the point source emission inventory. Some
states are extending their point source file down to 10 ton/year or 1 ton/year
sources rather than cutting off at the 100 ton/year level. In some states,
the review is part of a regular surveillance program that will generate a
new emission inventory every few years. In other states the update required
for air quality maintenance planning is the first that has been done since
the development of the original SIPs.
The states are having varied experience with the interview process.
Some are finding industry especially cooperative and willing to supply the
necessary data, while some are experiencing considerable difficulty.
The use of EPA's SCC source code was questioned since there is virtually
no data from other sources that could be correlated directly to SCC codes.
The use of Standard Industrial Classification (SIC) codes was suggested as
a better alternative.
Transportation Data. Several states encountered difficulty in getting
good traffic data (e.g. vehicle-miles-travelled, speeds, etc.) for other
than major roadways. Those states with active transportation planning
agencies experienced the least difficulties.
Validity of Volume 7 Procedures. In several regions a number of ques-
tions were raised as to the accuracy of the procedures outlined in Reference
7 for emission inventory update. There were questions as to whether the
higher levels of detail do, in fact, give better results and, if so, by how
much. There was concern that the methods had not been tested and verified.
The main thrust of the answers to these questions was that an implementing
agency might conduct a sensitivity analysis to determine the impact of the
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various source categories on the projected air quality and upgrade the level
of analysis for the important sources.
2.4 EMISSION PROJECTIONS
Section 4 of the AQAW manual treated emission projections. Table 5
summarizes the questions.
Table 5. Distribution of Questions Concerning
Emission Projections
Number of Questions and Comments
Workshop
Coordination with
Other Agencies
Accuracy of
Growth Projections
Atlanta
Boston
New York
Chicago
6
1
2
2
3
4
3
Denver
S eattle
Dallas
Philadelphia
TOTAL
17
Coordination with Other Agencies . A large number of questions and
comments arose regarding the required coordination between air quality main-
tenance planning and other planning efforts (e.g., 208 water planning, 3-C
transportation planning, HUD 701 planning, etc.). The use of compatible data
bases and time scales were the issues most often addressed. Many states had
not yet entered the emission projection phase and were still trying to ident-
ify what a suitable data base was. Some agencies encountered situations where
the 208, 3-C, and 701 information were not compatible among themselves and the
air quality maintenance planning agency was having a difficult time choosing
the proper set of data. Tn other cases, state legislation dictated the data
to be used by all state agencies thus simplifying the situation.
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At several workshops the need to make the air quality maintenance plan-
ning time frame compatible with other federal planning programs was reempha-
sized several times in response to questions. The possible use of a less-
detailed analysis for periods beyond 1985 at the discretion of the Regional
Administrator was also discussed.
The use of the OBERS data for growth projections was, in some areas,
being dictated by the fact that the 208 planning agency was using this
information. One region suggested that the states could use better local
information and not be concerned with discrepancies with OBERS unless serious
problems arose. Agency evaluations of the quality of OBERS data ran the full
spectrum from being relatively close to other projections to being incompatible
and "useless."
Some coordination problems exist with regard to projecting future energy
consumption patterns. One state complained that the prediction of future
fuel mix should be a federal responsibility (e.g., FEA) and should not be
placed on local agencies. Some guidance was also requested on determining
the impact of future energy technologies.
In general it can be said that the air quality management agencies are
making attempts to coordinate their data with other planning groups but that
in a significant number of cases these efforts are being frustrated by forces
outside of the control of the agency. Incompatible data 'from other agencies,
indecision on the part of other groups as to what data they will eventually
use, and data bases that are not entirely suitable for air quality maintenance
planning analyses are among some of the problems. The shorter time scale
of the air quality maintenance planning requirements relative to the other
planning efforts is only compounding the problem.
Accuracy of Growth. Projections . The accuracy and reliability of fore-
casting future activity was of considerable concern at almost every workshop.
The questions ranged from asking where an agency could find data that might
accurately reflect growth to whether the EPA would accept plans based on what
might be totally unreliable data. The projection procedures of Reference 7
were questioned as to their validity and reliability.
At the same time that questions on the meaningfulness of the whole
practice of forecasting the future were being raised, questions on some of
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the fine details of growth projections were being asked. Questions concern-
ing the accounting for economic recessions, year-to-year variations in growth
rate, the obtaining of growth data by SCC classification, the determining of
source-by-source growth patterns, and the use of land use vs. employment based
projection procedures were discussed. The indications were that, despite
some of the uncertainties recognized by the agencies, they were investigating
alternative methods of tackling the problems associated with growth forecast-
ing. In this regard it appears that the integration of long-range planning
into the air quality management process is becoming an established practice.
The general response to questions about the reliability of forecasting
was to suggest the consideration of alternative scenarios and to conduct
sensitivity analyses to identify which growth patterns would have the
biggest impact on air quality. While it was generally agreed that this was
a useful approach, many groups expressed concern that they would have neither
the resources nor the time to conduct extensive analyses of alternatives.
2.5 SUBCOUNTI ALLOCATIONS
Section 5 of the manual dealt with allocating emissions to subcounty
areas. Table 6 tabulates the questions and comments.
Table 6. Distribution of Questions Concerning
Subcounty Allocations
Workshop
Atlanta
Boston
New York
Chicago
Denver
Seattle
Dallas
Philadelphia
TOTAL
Number of
Data
Resolution
1
3
1
5
Questions and
Accuracy
1
3
2
1
7
Comments
Allocation
of Growth
2
2
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Data Resolution. Several states commented on the approach they were
taking in using data with better than countywide resolution. Master enum-
eration districts, census tracts, ZIP codes, building permit records, and
employment projections were the most frequently referred-to data sources.
it . As with the emission update and projection techniques,
several questions were raised as to the accuracy of the various orders of
allocation procedures and the benefits that might be achieved by using a
more detailed approach. These were answered by the conclusion that no
systematic study of the relative accuracy of the methods had been made.
In the same context , there were several questions about the accuracy
to be gained from using different grid sizes. The improvement in predictive
capability by using finer grid spacing was questioned and, again, no specific
study results could be quoted.
Allocation of Growth. Although there were not a great deal of questions
recorded on the issue, the problem of where to allocate emissions from future
growth and development appeared to be unclear in many participants' minds.
Some states reported that they were planning to conduct their analysis using
a growth-in-place scenario. Others stated that they would rely on interviews
with industry to provide new plant locations. The process of allocating
emission growth on the basis of industrial employment or land use or some
other surrogate variable did not appear to be in widespread use at this point
in time. In many areas, the analysis has not yet proceeded to the point of
performing the subcounty allocation, which may account for the apparent un-
familiarity with the techniques.
2.6 MODELING
Section 6 of the AQAW manual dealt with air quality simulation modeling.
Table 7 summarizes the questions.
Model Calibration and Validation. Numerous questions were raised con-
cerning the procedures for and interpretation of model validation and calibra-
tion. The use of the simple regression analysis such as that included as
part of AQDM, was questioned as being incomplete. The poor regression line
slope and correlation coefficient achieved in the County X test case caused
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14
some concern as to the accuracy of modeling in general despite the fact that
the model had validated according to EPA guidelines. The response to these
concerns was that time restrictions did not permit an extensive effort to
improve the correlation but that such a need was certainly indicated. Several
suggestions were made that additional statistical tests be applied to deter-
mine model validity. Some improvements in correlation results since the
original SIP analyses was also reported.
Several states reported problems with validating a model under unusual
topographic and meteorological conditions and were considering switching
models.
Table 7- Distribution of Questions Concerning Modeling
Workshop
Atlanta
Boston
New York
Chicago
Denver
Seattle
Dallas
Philadelphia
TOTAL
Background
Number
Model Calibration
and Validation
4
2
2
2
1
1
12
ConcentTat'ions . The
of Questions and
Background
Concentrations
2
1
1
1
5
question of what
Comments
Pollutant
Scavenging Appendix J
1
1
1
2 1
1
1
4 4
are the appropriate
values of background concentrations to be used in modeling was raised several
times. Several states reported that the inclusion of fugutive dust and a
number of sources outside the study region was lowering the overall background
level. In several states where this had not yet been done, the question of
what the expected impact would be of including these other sources was raised.
The general answers given stated that as more sources were included in the
inventory, the background would begin to represent mostly those sources that
could not be inventoried and may, in fact, decrease from currently used values,
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15
Pollutant Scavenging. Questions were asked about appropriate values of
pollutant half-life to represent scavenging effects. The concern was mostly
with S02 although particulate scavenging was also considered. States using
half-life expressions in their modeling reported varying experiences with the
best values and ranged from 3 hours to 4 days. The conclusion based on
other's experience was that the half-life should be adjusted to give the
best correlation results.
Appendix J. Despite the fact that the workshop did not address the
oxidant issue in any detail, the discussion of models available for oxidant
analysis raised an almost unanimous concern as to the validity of Appendix J
as an oxidant model. Numerous criticisms were aimed at this model; however,
the only other model being applied to oxidant analysis was the SAI model which
is operational in California and is being tested in Denver and Chicago. There
appears to be a pressing need to develop a better analytical process for oxidant
studies. The response that EPA was working on the development of better oxidant
models did not seem to satisfy the immediate demand for workable tools.
2. 7 ANALYSIS OF MODELING RESULTS
Section 7 of the manual dealt with interpretation of modeling results.
Table 8 lists the questions and comments.
Table 8. Distribution of Questions Concerning
Analysis of Modeling Results
Number of Questions and Comments
Workshop Error Analysis
Atlanta
Boston 3
New York
Chicago 2
Denver
Seattle
Dallas 3
Philadelphia
TOTAL 8
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Error Analysis . The Indication that an evaluation of possible errors
and inaccuracies in the air quality analysis would be allowed as part of
the determination of whether control strategies were needed raised a great
many questions as to how such an error evaluation could be carried out.
There was a general lack of guidance from EPA as to what constituted an
adequate error analysis and what would be acceptable as far as plan require-
ments. Several participants asked if any standard error analysis routines
were being prepared. The answer was no. The use of a sensitivity analysis
to determine the most error-prone parameters was suggested.
One Regional Office representative suggested that the lack of EPA
guidelines on the acceptable methods of determining the range of error could
lead to some abuses in plan development. The suggestion was made that, in
the absence of such guidance, a more workable procedure would be to accept
the analysis results at full face value and take a conservative approach in
plan development. Many states, on the other hand, greeted the allowability
of error consideration as a sign of more flexibility in developing reasonable
control plans. In either case, clarification and amplification on how to
determine error ranges is needed.
2.8 STRATEGY DEVELOPMENT
Section 8 of the AQAW manual dealt with control strategy development
and testing. Most of the states had not proceeded into the strategy develop-
ment process and hence the discussions did not always reflect problems that
had actually been encountered. Table 9 summarizes the questions and comments.
Teohnologioal Control Strategies. The use of existing source retrofit
as a control strategy was questioned because of potential economic impacts.
Likewise, the use of source phaseout was questioned for the same reason. The
replies stated that economics could be considered when selecting strategies
and these considerations could dictate the use of other methods. The use
of phaseout as only a short-term solution to air quality problems was also
discussed.
The possibility for imposing emission standards more stringent than
federal New Source Performance Standards was raised and it was indicated that
this was a state perogative although it might encounter challenges as to its
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17
reasonability. This question was raised in the light of the possibility of
a source meeting emission limits but still creating an air quality violation.
Table 9. Distribution of Questions Concerning
Strategy Development
Workshop
Atlanta
Boston
New York
Chicago
Denver
Seattle
Dallas
Philadelphia
TOTAL
Number of Questions
Technological
Control Strategies
3
5
2
1
11
and Comments
Planning
Strategies
5
4
1
3
1
5
3
8
30
The use of supplementary control systems (SCS) as an interim control
strategy was questioned. The reply indicated that SCS could be used provided
the published EPA criteria were met by the source.
One state voiced concern that they may be required to demonstrate energy
conservation measures as part of their AQMA plan. It was replied that this
would not be required by EPA but may be required by the state. In general,
it was observed, the air pollution control agency would not have the authority
to enforce conservation measures.
The application of regulations to single sources was discussed as it
might raise questions of equal protection under the law. It was stated that
these types of regulations have withstood court tests.
Planning StTategi.es. The use of regional planning strategies as a
means to achieve air pollution control appeared to be met with mixed feel-
ings. Some states greeted the concepts with interest and some were, in fact,
attempting to develop the methods more fully. For example, one area was
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18
seriously considering restricting industrial growth to assembly and distribu-
tion facilities to minimize the air quality impacts. Another commented that
their experience with an emission density zoning regulation was working and
they could identify specific changes in the development pattern as a result.
Two others indicated that they were considering emission density zoning and
exclusionary zoning and had received considerable help from planning agencies,
which were working with them on the plan.
A number of other participants expressed reservations about the use of
regional planning for air pollution control on the basis of three issues:
(1) The accuracy and reliability of the air quality analysis is too uncertain
to base major planning decisions that might have significant socioeconomic
impacts on it. (2) There are exceedingly difficult legal problems involved
in trying to impose a land use plan on local communities and on areas with
overlapping jurisdictional boundaries. (3) The imposition of air pollution
considerations on planning decisions can often run contrary to good planning
practice; that is, it can encourage urban sprawl and can force industry to
locate in relatively clean areas and can conflict with other programs (e.g.
208 waste water management planning, prevention of significant deterioration) .
There appeared to be a prevelant feeling among the participants who questioned
the use of planning measures that these measures would, in effect, reduce
to two basic options of no-growth or dispersing industry.
Despite the expressed reservations about the utility of measures related
to land use and planning there was a great deal of interest in methodologies
available to conduct an analysis of these types of strategies as evidenced
by the questions concerning the emission density zoning example strategy.
This discussion, perhaps more than any other portion of the workshop, attracted
the interest of the representatives of planning agencies. Many questions
were aimed at identifying the planning implications of the control strategy
the use of other constraint conditions, and the mechanics of the linear
pro.gramming solution used to generate the emission density limits for the
County X example.
A number of questions also arose about the "first-come-first-serve"
problem of planning strategies in which the first industry to locate could
utilize the entire air resource and therefore preclude further development.
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19
Several EPA staff indicated that recent court tests have upheld the "first-
come-first-served" concept in other frameworks (specifically, several bill-
board location cases) and it would probably be upheld with regard to air
quality.
One participant suggested that an objective of strategy development,
particularly land-use-related strategies, should be to enlist the support
of other agencies for environmental control. There are some agencies (e.g.,
coastal zone management, open space preservation, etc.) that are natural allies
in the development of environmentally compatible land use plans.
2.9 STRATEGY SELECTION
Section 9 in the AQAW manual dealt with the selection of strategies on
the basis of economic, social, and institutional considerations. Only a small
number of questions were recorded for this section, although (as will be dis-
cussed later) these considerations were identified most frequently as needing
further clarification from EPA. The reason for the limited response at this
point in the workshops can possibly be explained by two factors: (1) most
agencies were not close to this stage of the analysis and had not given much
thought to what might be required for plan development; and (2) the workshop
presentation was, by design, only a survey of some possible analysis methods
that might be useful. Table 10 summarizes the comments that were recorded.
Table 10. Distribution of Questions Concerning
Strategy Selection
Number of Questions and Comments
Delphi Economic
Workshop Procedures Analysis
Atlanta 2 r~ o ^
Boston 1 1 t, c;> rj ;
New York 1 y o ' *
r.°
Chicago
Denver f
L.
Seattle '.
Dallas
Philadelphia 1
TOTAL 3 3
*, €..
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Delphi Procedures. The use of the Delphi techniques for decision-making
drew some interest. Questions as to how widespread its use was and what the
respondent group should be composed of were raised. It was observed that
getting all involved agencies to agree on a strategy, even using Delphi pro-
cedures, would be difficult.
Eeonomia Analyses. A question was raised as to the requirements for
economic analyses in air quality maintenance plan development. It was an-
swered by EPA staff that an economic analysis was not required as part of
the plan, but agencies are encouraged to perform some economic evaluations
of their strategies.
The use of cost figures that account for inflation in an analysis was
suggested. Also, the use of Internal Revenue Service guidelines on the def-
inition of what constitutes pollution control measures for the purpose of
making cost estimates was suggested.
2.10 SPECIAL ISSUES
The last portion of the workshop's second day was devoted to a discussion
of the policy issues that were raised and any special local problems. In all
the workshops this portion was, in general, informal and did not follow any
set agenda. Table 11 summarizes the comments.
Table 11. Distribution of Questions Concerning
Special Issues
Workshop
Atlanta
Boston
New York
Chicago
Denver
Seattle
Dallas
Philadelphia
Number of
Interagency
Cooperation
2
1
3
1
2
1
2
Questions and
Resources
1
1
1
1
1
1
1
1
Comments
Special
Circumstances
1
3
2
2
TOTAL 12
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Inteyggenc.y Cooperation. The issue that raised the most questions was
the need for coordination between the air quality maintenance planning agency
and the 208 waste water management agency. Formal coordination efforts are
at various stages of development with some areas just initiating contacts
and others already on the way toward using common data bases and projections.
Several problems have already been encountered in the coordination
efforts. The most frequent has been incompatibility of data bases. Wide
variations in the air quality maintenance planning and 208 timetable compounds
the problem since some air quality maintenance planning agencies are reluctant
to choose a data base until the 208 agency chooses one and they can, therefore,
be assured of compatibility. In some areas, the 208-chosen data base is not
adequate for the air quality maintenance planning effort and some resolution
of the problem is necessary. The fact that many 208 agencies have a local
orientation while the air quality maintenance planning agency generally has
a statewide orientation creates further difficulties.
A general feeling that 208 agencies are better funded and equipped than
are the air quality maintenance planning agencies has led to some frustration
on the part of the air quality agencies. Their impression is that their's
is a tougher job because of the tight time schedule and yet they must take
the risk of developing a plan that is inconsistent with the 208 plan and may
have to redo some of their work. Also, they feel that the 208 agency has
less incentive to be compatible with the air quality maintenance planning
agency because of its larger role.
Despite the complaints about coordination problems, the EPA Regional
Office staff did not appear to be confronted by any "surprises" on this
issue. Most of the difficulties appeared to have been recognized and some
attempt has been made to resolve some of them.
Two questions were raised as to what extent EPA could force cooperation
among states. The reply was that EPA had only limited mechanisms to achieve
this.
Resources . There were numerous complaints of inadequate resources
(money, manpower, time) to perform an adequate air quality analysis. Some
states expressed the desire to use some 208 money to develop data bases but
believed that they were prohibited from doing so by federal regulation.
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Others had already been using 208 money to develop data bases suitable for the
air quality maintenance planning effort. There appears to be some uncertainty
as to what is permissible under current federal guidelines. Regional Office
representatives were frequently questioned as to how much more grant money
would be available to use in air quality maintenance area plan development.
The question was raised regarding the development of a short-term plan
covering only 3 years to compensate for a lack of data and the resources to
collect it. It was stated that this could be considered by the Regional
Office.
Special Circumstances. Questions on how to handle several special
situations were raised. These included boundary problems (i.e., when a
problem source is out of the study area), attainment problems caused by
uncontrollable fugitive dust, and marginal indications of attainment and
maintenance problems (i.e., where the analysis shows only small violations
of the standards). The first issue was answered by stating that the study
area may need expansion or that another agency would have to take responsi-
bility for control. The last two issues were not resolved in any consistent
fashion in the workshops. Some Regional Office representatives indicated
that they would accept plans that showed that uncontrollable fugitive dust
or inaccuracy in the data were responsible for indicated air quality problems
while others said they did not know how EPA would respond. There appears to
be a need for policy clarification on these issues.
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3. EVALUATION OF TEE WORKSHOPS
All participants in the workshops were asked to fill out a questionnaire
to evaluate the overall content, presentation, and relevance of the workshop
material. This section will summarize the comments.
S.I ADDITIONAL INFORMATION NEEDED
Participants were asked to identify portions of the workshop that needed
more emphasis and to list areas in which they felt more guidance was necessary.
The following are the subjects listed and the number of times they appeared on
the questionnaires. Table 12 summarizes the results by workshop.
Strategy Implementation (41) . These comments included considerations
such as legal, political, institutional, social, and economic constraints on
strategy implementation and requests for information on prior experience with
various strategies. The AQAW did not attempt to address these considerations
in detail and currently there is little published guidance on how to conduct
an air quality analysis with these considerations in mind. The information
in the AQMA Guidelines series, does not treat these factors in great detail
and probably could not do so in any general fashion. Because of the local-
ized nature of these problems, the Regional Offices will probably have to
bear the major responsibility in helping the states to resolve these issues.
A compilation of prior experience with various strategies might be a useful
guideline for EPA headquarters to compile.
Modeling Techniques and Evaluation of Modeling Results (36). Apparently
there is still a great deal of unfamiliarity with the methods of air quality
simulation modeling. The workshop gave only a survey of the models available
and did not go into the details of the mathematical formulations and the
techniques of model application. With the large volume of literature avail-
able on air quality modeling, it is evident that many agencies have not done
a great deal of modeling before and are just "coming up to speed" on the meth-
odologies. What may be necessary is additional instruction aimed at agencies
with only limited modeling experience.
Strategy Development (27). Many states have not yet proceeded to the
strategy development stage, hence the need for additional guidance at this stage.
The workshop material evidently did not cover a broad-enough spectrum of strategy
options and possibilities to satisfy the demand for information in this area.
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Table 12. Distribution of Recommendations for Additional Guidance
Number of Recommendations
Subject
Strategy Implementation
Modeling
Strategy Development
Inter govern '1 Cooperation
Transportation
Other Pollutants
Projection Techniques
Emission Inventory
Accuracy of the Analysis
Emission Allocation
Fugitive Dust
Other Planning Programs
Interstate Transport
Anal, of Existing Air Qlty
Level of Analysis
Indirect Source Review
Atlanta
6
6
2
3
1
3
2
3
3
4
1
Particulate Background Cone.
Significant Deterioration
Dedesi gnat ion
Other Workshops
Short-term Air Quality
Adverse Met. & Topography
Seasonal Variations
2
Boston New York
3 5
4 5
7
4
3 1
1
1 4
1 2
3
2
2 1
1
1 1
1
1
1
Chicago Denver
15 5
6 4
9
4
3 2
1 4
4 2
1
4
1
2 1
1 2
2
1
1
1
1
Seattle Dallas Philadelphia
232
542
333
371
6 1
124
2 1
213
1 1
1 1
1
1
2 1
3
1
1
1
1
Total
41
36
27
22
17
16
16
13
9
8
8
6
4
4
3
3
3
2
2
2
1
1
1
NJ
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Local, State, and Federal Interactions and Intergovernmental Coopera-
(22) . The AQAW, by design, did not deal with intergovernmental cooper-
ation. This questionnaire response plus the questions asked during the work-
shop indicate some significant problems in this area remain to be solved.
These problems include formal mechanisms and organizational structures that
permit interagency coordination and methods by which other agencies can par-
ticipate in plan analysis and development. These structural problems are
apparently being compounded in some areas by lack of cooperation among the
various agencies. The lack of cooperation stems, based on some of the com-
ments, from incompatible goals, objectives, and priorities of the various
agencies. In some cases the air quality analysis agency was experiencing
difficulty in obtaining information and data from other agencies. There were
several comments that expressed a concern for how the air quality maintenance
plan would impact on the development plans of other agencies and how the in-
volved agencies could arrive at a mutually acceptable compromise. The problem
of a local governmental body being put in the position of enforcing a state-
developed plan was also raised.
Transportation Source Analysis (17). As above, little emphasis was
placed on the analysis and development of strategies for controlling mobile
source emissions. There were a number of comments suggesting that a similar
workshop dealing with mobile-source-generated pollutants would be helpful.
Strategies for Other Pollutants (16). Since the AQAW dealt only with
particulates there was a good deal of interest in other pollutants. This
included concern about potential pollutant interactions.
Techniques (16). Techniques for determining industrial ex-
pansion plans (e.g., interview forms), growth rates, and the details of making
projections were stated as needing more guidance. The workshop, in general,
assumed that this type of information was available from planning agencies.
This need for additional guidance may reflect an unfamiliarity on the part of
air pollution control agencies with growth forecasting methodologies used by
planning agencies. Planning agencies should probably document the techniques
used, as opposed to simply providing data, to help the air pollution control
groups understand the basis for projections.
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Emission Inventory (13}. Various aspects of the emission inventory
were cited as needing further clarification. These were interpretations of
land use plans into an emission inventory, area source data, open burning,
point source cutoff criteria, and collecting good data in general.
Accuracy and Reliability of Analysis (9). The comments asked for guid-
ance on conducting an evaluation of the accuracy of the analysis. This in-
cluded comments on how to evaluate the reliability of the data (e.g., emission
inventory, growth projections, etc.), and how to determine the accuracy of the
projection and allocation techniques (i.e., Volumes 7 and 13 procedures).
Guidance on how to incorporate consideration of the accuracy of the analysis
into plan development was also requested.
Emission Allocation (8). Most of these comments related to the need to
identify where to locate new point sources. One comment suggested the devel-
opment of an optimization procedure to allocate emissions.
Fugiti-ve Dust (8). There were requests for better data on fugitive
sources and for data on more source categories (i.e., reintrainment, paved
roads) .
Interface with Other Planning Programs (6). The need for additional
assistance in this area was evidenced also by the questions concerning the
impact of 208 waste water management planning on air quality maintenance
planning.
Interstate Transport of Pollutants (4). The comments requested guidance
on how to deal with pollutants that are transported into the study area from
sources outside the state over which the agency has jurisdiction and how to
adjust control strategies to be compatible in more than one air quality main-
tenance area.
Analysis of Existing Aiv Quality and Eeceptor Location (4). Guidance
was requested on evaluating and interpreting monitored air quality data.
Several specific comments related to determining if a given receptor location
was representative of the air quality picture or was dominated by a single
source (e.g., "in a traffic circle") and to handling situations where monitored
data was sparse or lacking altogether.
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27
Level of Analysis (3). The comments asked for more guidance on how to
balance the level of analysis and planning against time and resource constraints.
Indirect SOUTO& Review Procedures (3). Several comments were received
asking for clarification of EPA's requirements on indirect source review.
This was not included in the workshop because of the uncertainties in the form
that the final regulations will take.
Paptieulate Background Concentrations (3). Comments were received ask-
ing for information on determining appropriate levels of particulate background
concentrations. One comment was especially interested in background concen-
trations of particulates smaller than 10 urn.
Prevention of Significant Deter-iorat'Lon (2). Two comments asked for
guidance on how to deal with the significant deterioration of air quality in
plan development. This issue was not addressed in any detail in the workshop.
AQMA Dedesignation (2). Comments were received asking for guidance on
how, when, and on what basis to make a decision to dedesignate an air quality
maintenance area and what the reporting requirements would be.
Other Workshops for Speo-ial Problems (2). Two participants suggested
the possibility of setting up additional workshops to deal with specialized
problems as they arose in plan development.
Short-term Aiv Quality Analysis (1)_. One participant noted that the
workshop did not deal with short-term air quality standards in the County X
example.
Adverse Meteorology and Topography (1). One participant requested more
detailed information on how to treat unusual meteorology and topography in
the analysis.
Seasonal Variations (!)• One participant asked for information on how
to account for seasonal variations in emission patterns.
3.2 RELATION TO OTHER PROGRAMS
The participants were asked if the AQAW provided insight that would be
useful to other control programs. Most answers were a simple "yes" but sev-
eral indicated the specific programs. These included new source review (16),
all programs in general (11), indirect source review (11), prevention of sig-
nificant deterioration (3), 208 planning (3), land use planning and zoning (3),
permit programs (2), and FHWA compatibility analysis (1).
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28
3.3 OVERALL EVALUATION
The participants were asked to give an overall evaluation of the work-
shops. In general, the comments were very favorable. Of 94 comments tabu-
lated, 65 expressed a favorable reaction to the material. One of the most
frequent comments was that the AQAW provided a complete overview of the AQMP
process and gave the participants a feeling for the scope of the problems.
Several comments indicated that the AQAW manual would serve as a useful guide
to the "cumbersome" 13-volume guidelines set. The criticisms of the overview
approach came equally from both sides. Half of the comments stated that the
material was too general, while the other half stated it was too technical.
There were a number of comments that indicated a desire to continue the
instruction and delve into some of the specialized topics in more detail.
Criticism about the orientation of the workshop again came equally from
two sides. A number of participants said that the material was good but too
heavily oriented toward air pollution control personnel. An about equal number
stated that the information was a good introduction for planners but not air
pollution control agency staff. The diverse backgrounds of the participants
made these comments expected.
Several participants stated that the material would have been most help-
ful 6 to 18 months earlier and that much struggling might have been avoided.
Three comments indicated that the material was unrealistic in terms of the
resources available to carry out this type of analysis and in terms of the
feasibility of some of the strategies.
With regard to the logistics of the workshop, a number of participants
expressed satisfaction with the organization and presentation of the material.
Several commented that having the manual to work from was very helpful but
that it would- have been more beneficial to have sent it out several days prior
to the workshop. Two participants complained that the presentation followed
the manual too closely. Many comments were received that stated that the
schedule was extremely vigorous and a great deal of information was covered
in a short period of time. Some suggested extending the workshop to 3 to 4
days.
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4. CONCLUSIONS
Based on the questions, comments, and evaluations received about the
Air Quality Analysis Workshops, it can be concluded that they successfully
achieved the objective of providing an overview of the entire Air Quality
Maintenance Planning process for the working level staff of air pollution
control and regional, state, and local planning agencies. The most frequently
recorded comment concerned the good organization and continuity of the
material. This was, no doubt, the result of workshop preparation by a single
contractor and one principal EPA project officer. This approach appeared
to work more efficiently than the multiple contractor/multiple project
officer approach.
The mixing of air pollution control and planning agency staff as
workshop participants was an effective method of promoting the interchange
of ideas and perspectives. It generated the unavoidable problem of some
of the material being too elementary for some participants and too technical
for others. Nevertheless, each group was able to glean some valuable
information from the presentations.
Workshop participants indicated that substantial additional guidance
and assistance from EPA is needed in the following technical areas:
Strategy Development. Since most states have not
yet entered this phase there is a desire for
more information regarding the choice of workable
strategies. Special concern was indicated about
determining the implementability of various strat-
egies . The mechanics of developing land-use-
related measures need further clarification.
Modeling. The use of air quality simulation models
is a new experience for many agencies and they
require some additional assistance from EPA on
the basics of validation and calibration, pollutant
scavenging, and background determination. The more
experienced agencies are having their greatest
difficulties with oxidant modeling.
Accuracy of Analysis. There is a great deal of
interest in the fact that the new air quality main-
tenance planning regulations allow some considera-
tion of data accuracy in plan development. There
is also a feeling that there is virtually no guid-
ance on how to determine accuracy, how to conduct
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30
a sensitivity analysis, and what constitutes an
adequate and acceptable accuracy analysis. The
question of accuracy arose in almost all of the
workshop sections and this is one area that may
require new guidelines.
Fugitive Dust. More good emission data and
data from additional source categories, both
urban and rural, is requested. Also, guidance
on how to treat non-attainment situations that
are dominated by fugitive dust is needed. Fug-
itive dust generated more questions than any
other single portion of the workshops.
Allocation of Growth. Many agencies are apparently
attempting to identify specific locations for new
industrial plants or are using growth-in-place as
alternatives to using the surrogate variable tech-
nique described in the workshops. The surrogate
variable procedure may require further clarification
from EPA.
Projection Techniques. The mechanics of projecting
growth appear to be unclear in the minds of many
air pollution control agency personnel. There is
an apparent dissatisfaction with accepting the con-
cept that growth projections are generated externally
and need only be "plugged into" the analysis.
Response to this request for guidance could lead
to the involvement of air pollution control agfency
staff into formal planning activities.
In addition to the technical issues, several other problem areas were
raised that will require special attention.
Interagency Cooperation. The roles and responsi-
bilities of the air quality planning agency and
the 208 waste water management agency are in need
of further clarification and development. Coordi-
nation with other agencies is also a problem but
not as extensive. Although attempts are being made
to effect coordination, a great many local problems
remain to be solved.
Resources. The amount of additional resources
(money, manpower, time) that will be made available
to the agencies for air quality planning needs to
be determined. Most are not satisfied with their
current resources.
Level of Analysis Detail. Additional guidance on
balancing the level of analysis to resource con-
straints was requested.
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31
Any one of several mechanisms may be used to provide the needed
assistance. These mechanisms include EPA policy memoranda, additional
guideline documents, specialty workshops, and Regional Office-conducted
workshops.
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32
REFERENCES
Guidelines for Air Quality Maintenance Planning and Analysis, Volume 1:
Designation of Air Quality Maintenance Areas. Report No. EPA-450/4-74-
001. U.S. Environmental Protection Agency, Research Triangle Park, N.C.
, Volume 2: Plan Preparation. Report No. EPA-450/4/74-002.
USEPA, RTF, N.C. July 1974.
, Volume 5: Control Strategies. Report No. EPA-450/4-74-003.
USEPA, RTF, N.C. July 1974.
, Volume 4: Land Use and Transportation Considerations.
Report No. EPA-450/4-74-004. USEPA, RTF, N.C. Aug 1974.
, Volume 5: Case Studies in Plan Development. Report No.
EPA-450/4-74-006. USEPA, RTF, N.C. Dec 1974.
, Volume 6: Overview of Air Quality Maintenance Area Analysis.
Report No. EPA-450/4-74-007. USEPA, RTF, N.C. Sept 1974.
7. , Volume 7: Projecting County Emissions, Second Edition.
Report No. EPA-450/4-74-008. USEPA, RTF, N.C. Jan 1975.
8. , Volume 8: Computer-Assisted Area Source Emissions Gridding
Procedure. Report No. EPA-450/4-74-009. USEPA, RTF, N.C. Sept 1974.
9. , Volume 9: Evaluating Indirect Sources. Report No. EPA-450/
4-75-001. USEPA, RTF, N.C. Jan 1975.
10. , Volume 10: Reviewing flew Stationary Sources. Report No.
EPA-450/4-74-011. USEPA, RTF, N.C. Sept 1974.
11. , Volume 11: Air Quality Monitoring and Data Analysis.
Report No. EPA-450/4-74-012. USEPA, RTF, N.C. Sept 1974.
12. , Volume 12: Applying Atmospheric Simulation Models to Air
Quality Maintenance Areas. Report No. EPA-450/4-74-013. USEPA, RTF,
N.C. Sept 1974.
13. , Volume IS: Allocating Projected Emissions to Subcounty Areas.
(with Appendixes A and B) Report No. EPA-450/4-74-014. USEPA, RTF, N.C.
Nov 1974.
14. Maintenance of National Ambient Air Quality Standards. Title 40, Code of
Federal Regulations, Part 51. 38F#15834, June 18, 1973; 39^16343, May 8,
1974; 40F.S25814, June 19, 1975; and proposed revisions to be published.
15. Compilation of Air Pollutant Emission Factors, Second Edition. Report
No. AP-42 (with 5 supplements). USEPA, RTF, N.C. April 1973.
16. Steam Electric Plant Factors, 1974 Edition. National Coal Association.
Washington, B.C.
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TECHNICAL REPORT DATA
(rlease read Instructions on the reverse before completing)
1. REPORT NO. 2. ~ ~~
EPA-450/3-75-080-b
4. TITLE AND SUBTITLE ' ~
AIR QUALITY ANALYSIS WORKSHOP
VOL. 2 - EXECUTIVE SUMMARY
7.AUTHOR(S)
R. R. Cirillo, J. F. Tschanz , A. E. Smith
9. PERFORMING ORGANIZATION NAME AND ADDRESS
Energy and Environmental Systems Division
Argonne National Laboratory
Argonne, Illinois 60439
12. SPONSORING AGENCY NAME AND ADDRESS
Environmental Protection Agency
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
3. RECIPIENT'S ACCESSION-NO.
5. REPORT DATE
January 1976
6. PERFORMING ORGANIZATION CODE
8. PERFORMING ORGANIZATION REPORT NO.
10. PROGRAM ELEMENT NO.
2AC-129
11. CONTRACT/GRANT NO.
EPA-IAG-D6-0902
13. TYPE OF REPORT AND PERIOD COVERED
Final
14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES xhe Executive Summary is intended to provide air quality manage-
ment and planning officials with an assessment of 7 regional air quality analysis
workshops held between November 24 and December 19, 1975.
16. ABSTRACT
17. KEY WORDS AND DOCUMENT
a. DESCRIPTORS b.lDENT
13. DISTRIBUTION STATEMENT 19. SECU
Unc!
Unlimited 20. SECU
Unc]
ANALYSIS
FIERS/OPEN ENDED TERMS C. COSATI Field/Group
RITY CLASS (This Report) 21. NO. OF PAGES
Lassif ied
RITY CLASS (This page) 22. PRICE
.assif ied
EPA Form 2220-1 (9-73)
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