United States
               Environmental Protection
               Agency
Office of Air
and Radiation
January 15, 1991.
              Air
&EFA
               Implementation Strategy for the
               Clean Air Act Amendments of 1990


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KS^, $        UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
-VVI/Z T                   WASHINGTON, D.C.  20460
 ---

                        JAN  | 5 1991
  OFFICE OF
AIR AND RADIATION
  Honorable William K. Reilly
  Administrator
  U.S.  Environmental Protection Agency
  401  M.  Street,  S.W.
  Washington,  D.C.  20460

  Dear Mr.  Reilly:

       The  Clean Air Act Amendments of 1990 were signed into law by
  President Bush on November 15, 1990.  These Amendments direct the
  Environmental Protection Agency to implement strong environmental
  policies  and regulations that will ensure cleaner air for all
  Americans.

       As you requested, the Office of Air and Radiation has
  developed the enclosed implementation strategy for the Clean Air
  Act  Amendments of 1990 within 60 days of enactment.  It reflects
  the  steps that EPA plans to take over the next two years to meet
  the  challenge presented by this landmark environmental
  legislation.

       The  strategy summarizes our plans to ensure the effective
  implementation of the Clean Air Act Amendments of 1990 within the
  timeframes set by Congress.  Implementation principles have been
  designed  to apply to the guidelines and regulations that will be
  developed to meet statutory requirements.  These principles are
  presented in Enclosure I and reflect three themes:

       (1)   Building on the President's goal to balance
       environmental protection and economic growth, market-based
       approaches and innovative strategies will be utilized, where
       appropriate.  Policies will be structured to offer
       incentives, choice, and flexibility to find the best
       solutions for obtaining environmental benefits at the lowest
       cost.
                                                          Printed on Recycled Paper

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     (2)   Because of the ambitious regulatory agenda outlined by
     the statute, broad consultation will be undertaken to build,
     where possible, consensus with interested organizations.
     Efforts to receive timely input include:  consulting with
     several Clean Air Act advisory committees; using,  where
     appropriate, formal regulatory negotiation procedures; and
     scheduling informal discussions with industry,
     environmental,  state and local, labor,  and federal
     organizations to discuss specific issues and to receive
     input early in the rulemaking process.

     (3)   Meeting deadlines is essential!  The implementation
     strategy outlines the groundwork underway to ensure that
     commitments will be met.

     The implementation strategy emphasizes the regulatory and
communication activities that will be undertaken during the first
two years after enactment.  Highlights of these activities are
presented in Enclosure II.  The strategy briefly summarizes a
number of major activities and issues associated with each title
of the Amendments.  In addition, timelines illustrating the
principal statutory requirements through the year 2010 are
included.

     Planning for implementing the Clean Air Act Amendments of
1990 will be a dynamic process.  We will continually review the
implementation activities for effectiveness, and make corrections
as necessary.  The Office of Air and Radiation will  update the
enclosed implementation strategy on an annual basis, focusing on
the forthcoming two year period.
                                   Sincerely
                                                 enberg
                                                 nistrator
                                                 Radiation
William G.
Assistant Ad:
  for Air an
Enclosures (3)

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                                    Enclosure 1

                   UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                 WASHINGTON, D.C.  20460
                        IMPLEMENTATION PRINCIPLES
                FOR THE CLEAN AIR ACT AMENDMENTS OF 1990
                                                                       OFFICE OF
                                                                    AIR AND RADIATION

PROMISE OF THE CLEAN AIR ACT

       o     "Every American expects and deserves to breathe clean air..."
                              President Bush

       o     These principles will guide us as we turn the promise of the  Act into a
             legacy of clean air.

POLICY

       o     E^: Achieve and maintain a healthy environment, while supporting strong
             and sustainable economic growth and sound energy policy.

       o     Market-based: Use market-based approaches and other innovative
             strategies to creatively solve environmental problems.

BUILD CONSENSUS

       o     Joint Venture: Recognize  the essential role played by state and local
             governments.

       o     Consultation: Conduct early and frequent discussions with interested
             parties, including other government organizations, industry, environmental
             groups, and academics. Where appropriate, use negotiation  techniques to
             resolve critical issues.

       o     Federal Coordination: Work closely with other EPA offices,  other Federal
             agencies,  and  Congress to ensure a coordinated approach that  will achieve
             environmental objectives in the most efficient manner possible.

MANAGEMENT

       o     Deadlines: Establish and meet commitments to effectively implement key
             provisions of the Act.

       o     Team Effort: Work together; attract and retain a diverse and talented
             workforce.
                                                                        Printed on Recycled Paper

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                          Enclosure 2
           CLEAN AIR ACT AMENDMENTS OF 1990
IMPLEMENTATION SCHEDULE HIGHLIGHTS: THE FIRST TWO
                           YEARS
 Communications Focus
Regulatory Activities
Getting Started

State 
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  Communications Focus
                Regulatory Activities
Cleaner Cars and
    Cleaner Fuels
MAY
1991
Title I  Nonattainment:
  STATES' Deadline for Reasonably Available Control
  Technology Requirements (Deficiency Corrections)
  Notify STATES of Intent to Modify Suggested
   Boundaries
  Publish Guidance on Stationary Source CO Contributions
  Finalize Criteria to Measure Ozone Transport
Title II   Mobile Sources:
  Finalize Gasoline Reid Vapor Pressure Regulations
  Finalize Tier I Car and Truck Standards
  Propose Reformulated Gasoline Requirements
  Propose Clean Fuels Fleet and California Pilot Credit
  Programs
  Propose Urban Bus Regulations
  Propose Emission Control Diagnostic Rule
Title III - Air Toxics:
  Propose Standards for Large Municipal Waste
   Combustors
  Publish Final Chemical List Petition Procedures
Title IV - Acid Rain:
  Propose Regulations for Auctions and Sales
Title VI - CFCs:
  Propose CFC Phase-out Regulations
Protecting the
     Ozone Layer
JUNE
1991
Title I - Nonattainment:
  Propose PM-10 Area Reclassifications
Title VI - CFCs:
  Propose Mobile Air Conditioning Recycling Regulations
Assisting Small
    Businesses
JULY
1991
Title I - Nonattainment:
  Propose Revisions to New Source Review Program
  Finalize Ozone, CO Nonattainment Boundaries
  Finalize List of Additional PM-10 Nonattainment
   Areas and SO2, Lead Designations
Title V - Permits:
  Publish Guidance on State Assistance to Small
   Businesses
Title VII - Enforcement:
  Propose Administrative Penalties Rules of Practice

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  Communications Focus
                Regulatory Activities
Attainment of Air
     Quality Standards
AUG
1991
Title I - Nonattainment:
  Propose PM-10 Reasonably Available Control Measures/
   Best Available Control Measures Guidance
  Issue Transportation Planning Guidance
  Publish Title I General Preamble
  Publish 1990 Air Quality Data
Title II - Mobile Sources:
  Publish Marketable Gasoline Oxygen Credit
   Guidelines
Title VII - Enforcement:
  Propose Rules for  Citizen Suits
Acid Rain
                                 SEPT
                                 1991
         Title IV - Acid Rain:
          Propose Emission Trading System
          Propose Acid Rain Permit Program
          Propose Continuous Emission Monitor Requirements
          Propose NOx Requirements for Utility Boilers
          Propose Conservation and Renewable Incentives
         Title VI - CFCs:
          Finalize CFC Phase-out Regulations
        , Opportunities ",„
    in. the Clean Air Act
OCT
1991
Title I - Nonattainment:
  Publish VOC and CO Emission Inventory Guidance
Title II - Mobile Sources:
  Finalize Cold Temperature CO Standards
  Publish Study on Non-road Engines
Title III - Air Toxics:
  Propose Maximum Achievable Control Technology for
  Coke  Ovens

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Communications Focus
Regulatory Activities
One Year of Progress
lovtara tMonersW'










































Air Toxics






NOV
1991











































DEC
1991



Title I Nonattainment:
Propose Tank Vessel Rule
Publish Conformity Criteria
Publish Guidance on Control Cost-effectiveness
STATES Submit PM-10 State Implementation Plans
Publish Outer Continental Shelf Rule
Publish Guidance on Inspection/Maintenance
Programs
Publish Guidance on Transportation Control
Measures
Title II - Mobile Sources:
Propose Clean Fuel Vehicle Standard
Finalize Vehicle Evaporative Emissions Regulations
Finalize Onboard Controls
Finalize Reformulated Gasoline Requirements
Finalize Urban Bus Regulations
Finalize Clean Fuels Fleet and California Pilot
Credit Program
Title III - Air Toxics:
Publish Final List of Source Categories
Propose Guidance for Modification Provisions
Publish Draft Regulatory Schedule for All Source
Categories
Finalize Standards for Large Municipal Waste
Combustors
Propose List of Substances for Accidental Releases
Prevention Program
Propose Maximum Achievable Control Technology for
Hazardous Organic Chemical Manufacturing
Propose Maximum Achievable Control Technology for
Dry Cleaners (per court order)
Finalize List of High Risk Pollutants (Lesser
Quantity Cutoff, 90%/95% Early Reductions)
Title IV - Acid Rain:
Finalize Regulations for Auctions and Sales
Title V - Permits:
Finalize State Permit Regulations
Propose Federal Permit Regulations
Title VI - CFCs:
Ban Nonessential Uses
Finalize Mobile Air Conditioning Recycling Regulations
Title VII - Enforcement:
Propose Rules for Field Citation Program
Propose Rules for Contractor Listing

Revise Two- Year Implementation Strategy
Title I - Nonattainment:
Finalize PM-10 Area Rectifications
Title IV - Acid Rain:
Propose List of Phase II Utility Allowances

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Communications Focus
Regulatory Activities
Enforcement :
























JAN
1992


FEE
1992

MAR
1992
APR
1992
MAY
1992








JUNE
1992
JULY
1992
Title III - Air Toxics:
Propose Standards for Small Municipal Waste
Combustors
Title VII Enforcement:
Finalize Administrative Penalties Rules of Practice
Title III - Air Toxics:
Propose Maximum Achievable Control Technology for
Chromium Electroplating
Title VII Enforcement:
Propose Monetary Awards Rules
Title III - Air Toxics:
Propose Maximum Achievable Control Technology for
Commercial Sterilizers
Title III Air Toxics:
Propose Maximum Achievable Control Technology for
Asbestos
Title I Nonattainment:
Finalize PM-10 Reasonably Available Control
Measures/Best Available Control Measures Guidance
Finalize Revisions to New Source Review Program
Finalize Rules for Ozone, NOx, VOC Enhanced
Monitoring
Title II Mobile Sources:
Finalize Emission Control Diagnostic Rule
Publish Mobile-Source Related Air Toxics Study
Title III Air Toxics:
Finalize Guidance for Modification Provisions
Title IV Acid Rain:
Finalize Emission Trading System
Finalize Continuous Emission Monitor Requirements
Finalize NOx Requirements for Utility Boilers
Finalize Conservation and Renewable Incentives
Finalize Acid Rain Permit Program
Title V - Permits:
Finalize Federal Permit Program
Title VI - CFCs:
Finalize CFC and HCFC Labelling Regulations
Title VII - Enforcement:
Propose Rules for Compliance Certification





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Communications Focus
Regulatory Activities









Meeting the Deadlines
m WP v*e0»» •/»* <»





























AUG
1992


SEPT
1992
OCT
1992

NOV
1992
























DEC
1992



Title I - Nonattainment:
Publish 1991 Air Quality Data
Title VII - Enforcement:
Finalize Guidance/Rules for Citizen Suits


Title III - Air Toxics:
Finalize Maximum Achievable Control Technology for
Coke Ovens
Title I - Nonattainment:
Finalize Tank Vessel Rule
Finalize Rules for Economic Incentives Program
Propose First Set of NSPS Rules
STATES Submit RACT Catch-up Rules, NSR Rules, CO
Attainment Demonstration, and Contingency Measures
STATES Submit Base Year Ozone/CO Emission
Inventories
Title II - Mobile Sources:
Finalize Clean-Fuel Vehicle Standards
Determine Significance of Non-road Engine
Emissions
Title III - Air Toxics:
Finalize Maximum Achievable Control Technology for
Dry Cleaners (per court order)
Finalize Maximum Achievable Control Technology for
Hazardous Organic Chemical Manufacturing
Finalize Regulatory Schedule for All Source Categories
Finalize List of Substances for Accidental Releases
Prevention Program
Title VI - CFCs:
Finalize Safe Alternatives Program
Title VII - Enforcement:
Finalize Guidance/Rules for Field Citation Program
Finalize Guidance/Rules for Contractor Listing
Finalize Rules for Monetary Awards
Title III - Air Toxics:
Finalize Standards for Small Municipal Waste
Combustors
Title IV - Acid Rain:
Finalize List of Phase II Utility Allowances

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       IMPLEMENTATION
          STRATEGY
           FOR THE
CLEAN AIR ACT AMENDMENTS
            OF 1990
United States Environmental Protection Agency
       Office of Air and Radiation

          January 15,1991
          (Printed on recycled paper)

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                       TABLE OF CONTENTS








1.0    Implementation Overview  	  1




2.0    Clean Air Act Implementation Principles	3




3.0    Policy  	7




4.0    Building Consensus	9




      4.1 Communication Activities 	9




      4.2 Joint Venture 	  10




      4.3 Consultation	  11




5.0    The Regulatory Process 	  13




6.0    The Regulatory Agenda:  The First Two Years  	  17




      6.1  Title I     Nonattainment	25




      6.2  Title II -   Mobile Sources  	27




      6.3  Title III -  Hazardous Air Pollutants	30




      6.4  Title IV -  Acid Deposition   	34




      6.5  Title V -   Permits 	35




      6.6  Title VI -  Stratospheric Ozone Protection	38




      6.7  Title VII - Enforcement 	40




      6.8  Title VIII - Miscellaneous 	41




      6.9  Title IX -  Clean Air  Research  	42




      6.10  Other Titles  	43

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APPENDICES




Appendix A:   Additional Information Sources	A-l




Appendix B:   Title-By-Title Statutory Requirements 	 B-l




Appendix C:   EPA Headquarters and Regional Offices	 C-l

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                       FIGURES AND TABLES


Figure 1       Implementation Principles  for the Clean Air Act
               Amendments of 1990	5

Figure 2       Regulatory Development Overview 	 15

Figure 3       Clean Air Act Amendments of 1990
               Implementation Schedule Highlights:  The First Two Years	 19

Figure 4       Title III:  Air Toxics  	31

Figure 5       Title V: Operating Permits	37


                                   Appendix B

Figure B-l     Title I: Nonattainment 	  B-l

Figure B-2     Title I: Ozone/CO Designation and Classification	  B-2

Table  B-l     Classification of Areas	  B-3

Figure B-3     Requirements for Ozone Plans  	  B-4

Figure B-4     Requirements for CO Plans	  B-5

Figure B-5     Ozone/CO SIP Control Strategy  	  B-6

Figure B-6     Title II:  Mobile Sources  	  B-7

Figure B-7     Title III:  Hazardous Air Pollutants	  B-8

Figure B-8     Title III:  MACT/GACT (2-Year Standards)	  B-9

Figure B-9     Title IV:  Acid Rain	  B-10

Figure B-10    Title IV:  SO2 Allowance Allocation/Trading	  B-ll

Figure B-ll    Title IV:  Emissions Monitoring	  B-12

Figure B-12    Title IV:  NOx Reductions	  B-13

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Figure B-13   Title V:   Perm, s	  B-14




Figure B-14   Title V:   Permit Program Startup  	  B-15




Figure B-15   Title V:   Permit Program Oversight	  B-16




Figure B-16   Title V:   Permit Regulation Development	  B-17




Figure B-17   Title V:   Permit Program Implementation Support	  B-18




Figure B-18   Title VI:  Stratospheric Ozone Protection	  B-19




Figure B-19   Title VII: Provisions Relating to Enforcement	  B-20




Figure B-20   Title VII: Administrative Enforcement Program 	  B-21




Figure B-21   Title VII: Compliance Certification Program	  B-22




Figure B-22   Title VII: Other Enforcement Programs  	  B-23




Figure B-23   Title VIII: Miscellaneous	  B-24




Figure B-24   Title IX:  Clean Air Research  	  B-25




Figure B-25   Title XI:  Clean Air Employment Transition Assistance  	  B-26






                                    Appendix C




Figure C-l     Office of Air and Radiation Organizational Chart  . . . . <	C-4

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                                                          Implementation Overview
                   IMPLEMENTATION STRATEGY FOR
              THE CLEAN AIR ACT AMENDMENTS OF 1990
1.0  IMPLEMENTATION OVERVIEW

      When President Bush signed into law the Clean Air Act Amendments of 1990 on
November 15,  1990, he stated, " Today, we add a long-awaited and long-needed chapter
in our environmental history, and we begin a new era for clean air." Truly, this law
represents the  most significant piece of environmental legislation ever passed to control
air pollution.  It directs the United States to implement strong environmental policies
and regulations that will ensure cleaner air for all Americans. To achieve this  goal, the
Environmental Protection Agency's (EPA) implementation strategy will not only employ
traditional approaches for controlling air pollution, but also strive to harness the power
of the marketplace, encourage local initiatives, and emphasize pollution prevention.
These efforts will be structured to achieve environmental benefits in a cost-effective
manner, ensuring consistency with national energy and economic policies.

      The Clean Air Act Amendments of 1990  signify a new era in environmental
regulation, offering solutions to some of the most resistant environmental problems by
promoting the  use of innovative regulatory approaches. The EPA Administrator,
William K. Reilly, has stated that, once fully implemented, the Amendments will:

      o       Remove 56 billion pounds/year  of pollution from the air (224
              pounds/year for every man, woman, and child in the United States);

      o       Reduce by 50% emissions causing acid rain;

      o       Reduce by 75% emissions and resulting risks from toxic air pollutants;

      o       Result in cleaner cars, fuels, factories, and powerplants;

      o       Assure that all areas of the country meet the national ambient air
              quality standards;

      o       Reduce damage to  lakes, streams, parks, and forests;

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Implementation Strategy for the Clean Air Act Amendments of 1990
       o       Reduce oil imports significantly; and

       o       Reverse the historical degradation of visibility in the country's most
               scenic areas.
      This document outlines the overall implementation schedule for the statutory
requirements, summarizes regulatory efforts currently underway, identifies some of the
major issues that will be addressed early in the implementation process, and describes
the steps that the Agency is undertaking to ensure the efficient and effective
implementation of the legislation. Emphasis has been p!  ->d upon the first two years
after enactment.  More than 25  rules will be developed i: :ie  first year and more than
55 in the first two years.  Thus,  activities undertaken in these years are critica.  they will
lay the foundation for effective implementation of the Clean Air Act Amendments of
1990.

      Planning to implement the Clean Air Act Amendments of 1990 is a dynamic
process.  The EPA intends to review continually all activities undertaken to implement
the Amendments, assess their effectiveness, and make modifications as necessary.  This
implementation strategy will be  updated on an annual basis, with each revision focusing
on the forthcoming two-year period.

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                                             Clean Air Act Implementation Principles
2.0  CLEAN AIR ACT IMPLEMENTATION PRINCIPLES

      The EPA is committed to implementing the Clean Air Act Amendments of 1990
wisely, quickly, and effectively. To meet this goal, EPA has developed implementation
principles to guide the Agency as it turns the promise of the Clean Air Act Amendments
of 1990 into reality.

      These implementation principles are presented in Figure 1. They emphasize
three areas. First, the Agency's  policies will be developed to ensure a healthy
environment while supporting national economic and energy policies.  Whenever
possible, traditional approaches  to solving environmental problems will be supplemented
with broader use of market incentives and other innovative  approaches. Second, EPA
recognizes that it  cannot implement the Clean Air Act Amendments of 1990 alone;
effective rulemaking requires the greatest possible consultation and consensus. Many
steps are being initiated to ensure that the views of interested parties (e.g., state and
local governments, industry, environmental groups) will be presented to the Agency early
in the rulemaking process.  Finally, internal Agency procedures will be modified to
ensure effective management of the implementation activities to meet the deadlines
specified by Congress.

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Implementation Strategy for the Clean Air Act Amendments of 1990

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                                     Figure 1

                   UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                WASHINGTON, D.C.  20460
                        IMPLEMENTATION PRINCIPLES
                FOR THE CLEAN AIR ACT AMENDMENTS OF 1990
                                                                      OFFICE OF
                                                                   AIR AND RADIATION
PROMISE OF THE CLEAN AIR ACT

      o      "Every American expects and deserves to breathe clean air..."
                              President Bush

      o      These principles will guide us as we turn the promise of the Act into a
             legacy of clean air.

POLICY

      o      Ef: Achieve and maintain a healthy environment, while supporting strong
             and sustainable economic growth and sound energy policy.

      o      Market-based: Use market-based approaches and other innovative
             strategies to creatively solve  environmental problems.

BUILD CONSENSUS

      o      Joint Venture: Recognize the essential role played by state and local
             governments.

      o      Consultation:  Conduct early and frequent discussions with interested
             parties, including other government organizations, industry, environmental
             groups, and academics.  Where appropriate, use  negotiation techniques to
             resolve  critical issues.

      o      Federal Coordination: Work closely with other EPA offices, other Federal
             agencies, and Congress to ensure a coordinated approach that will achieve
             environmental objectives in the most efficient manner possible.

MANAGEMENT

      o      Deadlines: Establish  and meet commitments to effectively implement key
             provisions of the Act.

      o      Team Effort: Work together; attract and retain a diverse and talented
             workforce.
                                                                       Primed on Recycled Paper

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Implementation Strategy for the Clean Air Act Amendments of 1990

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                                                                             Policy
3.0 POLICY

      A major challenge of the Clean Air Act Amendments of 1990 will be to develop
programs that provide environmental protection while fostering continued economic
growth and sound energy policy.  The Clean Air Act Amendments of 1990 offer
incentives, choice, and flexibility to achieve ambitious environmental goals at the lowest
cost to society. The EPA's policies will include making full use of innovative market-
based approaches.  The Amendments create incentives to utilize resources in the
cleanest, technologically feasible manner; at the same time, they offer inducements to
increase  energy conservation. If successfully implemented, the law will serve as a model
for regulatory reform, leading to the widespread use of market approaches here and
abroad.

      Several progressive and creative new themes are embodied in the Clean Air Act
Amendments of 1990.  Specifically, the new law:

      o      Encourages the use of market-based principles and other innovative
             approaches, such as performance-based standards and the banking and
             trading of emissions;

      o      Provides a framework to promote the use of cleaner fuels by setting
             standards that can be met  through the most cost-effective combination of
             fuels and technology in centrally-fueled fleets in the worst nonattainment
             areas and in a California pilot program;

      o      Promotes the use of clean low sulfur coal and natural gas, as well as
             innovative technologies to  clean high  sulfur coal through the acid rain
             program; and

      o      Promotes energy conservation.

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Implementation Strategy for the Clef    ir Act Amendments of 1990
      Pollution prevention activities as well as early emission reductions will be
emphasized throughout the implementation of the Clean Air Act Amendments of 1990.
For example, in controlling emissions of hazardous air pollutants, industries will be
encouraged to use the provisions which allow an alternative compliance date in exchange
for voluntarily implementing an early emission reduction program.  Effective
implementation of this provision will allow industry flexibility in achieving emission
reductions and will result in early environmental benefits.

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                                                                  Building Consensus
4.0  BUILDING CONSENSUS

       The regulatory timeframes identified in the Clean Air Act Amendments of 1990
are ambitious, but achievable.  These timeframes, however, can only be effectively met if
consultation with interested parties on regulatory issues is begun early. The EPA
recognizes that it cannot achieve the goals of the Amendments alone; effective
rulemaking on tight timetables requires the greatest possible consensus.  Standard notice
and comment procedures will, of course, be the principal avenue for formal public
participation in developing regulations. A number of additional  activities, however,  are
planned to ensure that all possible routes of consultation are used.  Critical players will
include state and local governments, Administration officials, labor, industry, academia,
and environmental groups.  Many steps have been initiated to educate and involve all
interested parties who wish to participate in the regulatory process. These activities are
briefly described below.

4.1  Communication Activities

       A key first step in  building consensus is educating the public about the statutory
requirements of the Clean Air Act Amendments of 1990.  The EPA has initiated a series
of efforts to communicate information to all key audiences, including state and local
officials (including, but not limited to,  air pollution control officials, governors, state
legislators, state attornies general, mayors, and other local officials); regulated and
affected businesses (both  small and large); public interest groups, environmentalists,
labor unions, citizen groups and members of the general  public; other federal agencies;
Members of Congress and their staffs; the international community; and the research and
academic communities.

       Critical to the outreach effort is a series of national and regional workshops to
explain the Clean Air Act Amendments of 1990 to target audiences. In November 1990,
EPA cosponsored a national videoconference with the Public Broadcasting System to
discuss  the impacts of the Amendments on small businesses. The EPA is  currently
working with the Air and  Waste Management Association and the  American Bar
Association to hold a similar videoconference for business and other interested parties
on February 21,  1991.  The EPA is also cosponsoring a series of at least ten regional
workshops with the American Lung Association and the State and  Territorial Air

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Implementation Strategy for the Clean Air Act Amendments of 1990


Pollution Program Administrators/Association of Local Air Pollution Control Officials.
Beginning in January 1991, these one and one-half day long conferences will enable state
and local officials, the general public, members of the regulated community and others to
discuss the Clean Air Act Amendments of 1990 and issues  related to its implementation.

      The EPA's communication efforts also  include the development and dissemination
of documents outlining the provisions in the Clean Air Act Amendments of 1990.  These
include detailed and summary overviews of the new  law. A list of the documents that
are currently available  is presented in Appendix A.  The EPA is also exploring other
methods of outreach to the interested public, including citizen guides, videotapes, and
journal articles.

      In addition to its initial educational efforts, EPA recognizes the need for
communication activities to continue throughout implementation of the Clean Air Act
Amendments of 1990.  Thus, EPA officials will continue making many presentations
around the country about the new law and the Agency's efforts to implement it. To the
extent possible, many of the outreach efforts will focus on upcoming regulatory efforts
and the need to build consensus and educate the public about impending regulatory
actions.

4.2 Joint  Venture

      A critical role will be played  by state and local governments during the
implementation of the  Clean Air Act Amendments of 1990. Successful implementation
requires a joint effort by federal, state, and local governments.  The Agency will work
closely with state and local agencies in all aspects of implementation, particularly in
those programs for which state and local governments are responsible. The EPA plans
to develop the tools, guidance, training and rules, as well as provide funds, that will
enable states to perform such critical activities as developing operating permit programs
and creating emissions  inventories.  The EPA recognizes that state  and local agencies
have valuable and extensive experience in many areas (e.g., permitting).  Therefore, the
Agency will  request state and local participation in many EPA work groups on  specific
regulations,  guidelines,  and studies.

      As  appropriate,  model legislation will be developed  to assist state agencies that
will require  new legislative authority in order to implement various requirements of the
new law.  In addition, EPA will continue to provide  technical assistance to states through
                                        10

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                                                                Building Consensus
such programs as the National Air Toxics Information Clearinghouse, the Control
Technology Center, and the Air Risk Information Support Center.

4.3 Consultation

      In order to meet tight timelines required by statute, consultation with critical
players must begin early. The EPA is planning to conduct early and frequent discussions
with interested parties in three ways:  (1) committees established under the Federal
Advisory Committee Act (FACA); (2) formal negotiated rulemakings; and (3) informal
discussions. Representatives for various  groups will be selected from all interested
sectors,  including industry, state and local governments, labor, agriculture, environmental
groups,  citizen groups, and academia. These consultations are  not intended to obviate
the standard notices of proposed rulemakings and comment periods undertaken through
the Administrative Procedures Act. Rather, these efforts will supplement and enhance
standard procedures.

      The EPA is currently involved in  several committees constituted  under FACA.
These committees are divided by the  primary type of advice that  is given: technical or
policy.  All meetings held by FACA committees are open to  the public.

      The technical advisory groups utilized by EPA include:  the National Air Pollution
Control Techniques Advisory Committee (NAPCTAC), the Clean Air Scientific Advisory
Committee (CASAC), and the Science Advisory Board (SAB).  The NAPCTAC advises
EPA on the economic and technological  feasibility of alternative  air pollution control
techniques.  It also reviews EPA information documents on control techniques for
sources  regulated under sections  111 and 112 of the Clean Air  Act. The CASAC advises
the Agency on technical issues relating to the national ambient air quality standards
(NAAQS). It  reviews the scientific basis for the levels of the primary and secondary
NAAQS, advises EPA on the effects of various attainment strategies, and suggests
research projects. This committee is part of a broader Science Advisory Board which
provides scientific and technical advice on a variety of subjects  including, but not limited
to, risk assessment, exposure modeling, and  monitoring.

      The Stratospheric Ozone Protection Advisory Committee (SOPAC) and two new
committees established by EPA for the Clean Air Act Amendments of 1990 - the Clean
Air Act Advisory Committee (CAAAC)  and the Acid Rain Advisory Committee
(ARAC) - have been established primarily to provide policy advice to the Agency.  The
SOPAC provides policy and technical advice to EPA on its program to  implement the
                                        11

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Implementation Strategy for the Clean Air Act Amendments of 1990


Montreal Protocol and protect the stratospheric ozone layer. The CAAAC is currently
being established.  It will provide policy advice on EPA's regulatory and programmatic
strategies for implementing the Clean Air Act Amendments of 1990.  Finally, the ARAC
will provide policy and technical advice to EPA to aid in the development of the new
acid rain program. An initial meeting was held in mid-December 1990 with  the full
ARAC. Four ARAC subcommittees have been established to focus on the following
areas:  (1) the allowance trading and tracking system; (2) permitting and technology; (3)
emissions monitoring and tracking; and (4) energy conservation and renewables.

       The Agency may also elect to use a formal negotiated rulemaking procedure,
commonly referred to as "reg neg".  Under this process,   . )mmittee is established under
FACA that fairly represents  all interest groups.  Issues ;.    .dentified and resolved in a
collective manner.  The regulatory negotiation process a; .-ws interested parties to have a
more direct input into the drafting of regulations, thus ensuring that the rule is more
sensitive to the needs and restrictions of both the parties and EPA. Rules drafted by
negotiation have been found to be more pragmatic and more easily implemented at an
earlier date, thus providing the public with the benefits of the rule while minimizing the
negative impact of a poorly conceived or drafted regulation.

       The regulatory negotiation process is usually effective where the standard(s) have
a broad impact, where the participants have an incentive to negotiate,  where issues are
complex, and where interest  can be identified and represented. In the past, EPA has
successfully used this process to develop air pollution control standards for woodstoves
and equipment leaks at chemical plants.

       Finally, a third forum for consultation will be informal discussions with interested
parties. The EPA is committed to sharing information with, and  soliciting informatio ;
from, interested parties early in the regulatory development process. Therefore, info:  nal
meetings will be held on specific issues on an ad hoc basis.  For example, a meeting was
held in early December with representatives from industry, state and local governments,
as well as environmental groups, to discuss the permit regulations being developed under
Title V. Similar meetings will be held in the future, as appropriate, to discuss specific
regulations and associated issues, and to provide public perspectives to EPA as it
deliberates on proposed regulations.
                                        12

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                                                              The Regulatory Process
5.0 THE REGULATORY PROCESS

      The EPA has traditionally followed a standard process for developing regulations.
This process is illustrated  in Figure 2. The public is informed of a proposed Agency
action through a notice of proposed rulemaking. Public comments are solicited at the
time this notice is published in the Federal Register.  These comments are considered as
EPA finalizes  the regulations.

      The Clean Air Act Amendments  of 1990 require publication of over 25 rules in
the first year and over 55  rules within the first two years. The EPA's traditional process
will not suffice to meet the demands of  issuing such a large number of regulations so
quickly. To meet the timeline required  by the Clean Air Act  Amendments of 1990, the
Agency has modified its internal process for reviewing regulations attendant to the
Amendments.  The process changes include providing four different types of regulatory
review, eliminating a duplicative step in the process of achieving final Agency
concurrence on rulemakings, and using the EPA Steering Committee  to resolve issues.
Early identification and resolution  of issues is critical to meet the  tight timetables
included in the Clean Air Act Amendments of 1990.  The new rulemaking processes are
described fully in a report to the EPA Deputy Administrator identified in Appendix A.

      The Agency has also  developed an internal process for coordinating the multiple
regulations being developed by its various program offices that affect  a given industry
sector (e.g., petroleum refineries), contaminant (e.g., lead), environmental resource (e.g.,
groundwater),  or geographic area.  This process, referred to as "regulatory clustering," is
designed to shift the regulatory development process from producing individual rules in
isolation to developing more integrated  strategies for addressing environmental
problems.   The goal is to  "cluster" regulations and policies around well-defined
environmental problem areas and to develop an integrated strategy for each problem
area.
                                         13

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Implementation Strategy for the Clean Air Act Amendments of 1990


      As in the past, review of proposed and final regulations will be conducted by the
Office of Management and Budget (OMB) under Executive Order 12291.  Given the
large  number of rulemakings to be reviewed, EPA will make every effort to involve
OMB early in the rulemaking cycle by providing briefings and early drafts of rules
whenever possible. In addition, OMB officials will be invited to participate in the
aforementioned informal discussions throughout the rulemaking cycle.
                                        14

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                                                                             The Regulatory  Process
                                         Figure 2

                REGULATORY DEVELOPMENT OVERVIEW
                                        Workgroup Formulation
                                                               Agency
                                                              Workgroup
 Preliminary
   Studies
                                                nformatkm Collection
                                                   and Analysis
                                                     Regulation
                                                    Development
Congressional
  Mandate
                                                                                 OAR Review
                                                                                    and
                                                                                 Concurrence
                                                             OMB Review
                                                                and
                                                             Concurrence
                                                   Agency Review
                                                        and
                                                    Concurrence
                                                                                ADMMSTRATOH
                                                                                APPROVES AND
                                                                                 SK3NS AFTER
                                                                                OMB CONCURS
                                Propose In
                                  Ftdfrtl
                                  Roalttar
                                                                                Promulgate In
                                                                                   Aden/
                                                                                  ftog/stor
NPRM   Notice of Propoaed Rulemaklng
NRM     Notice ol Rulemaklng
OAR     Office of Air and Radiation
OMB     Office of Management and Budget

•  Required for all major rules and selected
  significant rules
                                             15

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Implementation Strategy for the Clean Air Act Amendments of 1990
                                       16

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                                          The Regulatory Agenda:  The First Two Years
6.0 THE REGULATORY AGENDA: THE FIRST TWO YEARS

      The Clean Air Act Amendments of 1990 outline an enormous amount of
regulatory activity.  Figure 3 indicates the major regulatory activities that will occur over
the next two years.  As indicated in this figure, EPA's communication activities each
month will focus on the major regulatory activities proposed or finalized during that
timeframe.

      Title-by-title timelines of the requirements of the Clean Air Act Amendments of
1990 are presented in Appendix B.  All regulations identified will be proposed and
public comments will be solicited.  Where  a proposal date is not indicated in a timeline
contained in Appendix B,  the regulation may have been proposed prior to enactment of
the Amendments, or a proposal date may not yet have been established by EPA.  In
developing an implementation strategy, many specific requirements  have been grouped
into broad work areas.  Agency work groups with widespread participation have been
formed to address the activities within these broad work areas. To  foster the activities of
the work groups, planning materials have been prepared for each of the major work
areas.  Examples of these  planning materials are shown in Appendix B following the
initial title-specific timelines. These planning charts provide work groups a means of
focusing their  attention on developing overall programs to implement specific titles.
Planning charts have been developed for all major work areas. As work groups address
the various work areas, major issues are identified and surfaced for discussion and
resolution.

      In addition to the timelines presented in Appendix B, a compilation of fact sheets
for the regulatory activities that will begin  in the first two years is currently being
developed by the Agency.  This compilation will be available by February 15, 1991.

      Planning to implement the Clean Air Act Amendments of 1990 is a dynamic
process.  The EPA  intends to continually review all activities undertaken to implement
this law, assess their effectiveness, and make modifications as  necessary.  This
implementation strategy will be updated on an annual basis with each revision focusing
on the forthcoming two-year period.
                                        17

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Implementation Strategy for the Clean Air Act Amendments of 1990
                                      18

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                                  The Regulatory Agenda:  The First Two Years
                              Figure 3

            CLEAN AIR ACT AMENDMENTS OF 1990
IMPLEMENTATION SCHEDULE HIGHLIGHTS:  THE FIRST TWO
                             YEARS
 Communications Focus
Regulatory Activities
Getting Started

State & Local
Responsibilities

Building Consensus

Voluntary Reductions

Permit Program

DEC
1990
JAN
1991
FEE
1991
MAR
1991
APR
1991
Title I Nonattainment:
Issue "Getting Started" Letter to Governors
STATES Submit Request/Justification for
5% Classification Adjustments
Publish Two- Year Implementation Strategy
Title I - Nonattainment:
Publish Notice of Initial PM-10 Moderate
Nonattainment Areas
Initiate Additional PM-10, SO2, Lead Designation
Process
Title I - Nonattainment:
Act on 5% Classification Adjustment Requests
Title I - Nonattainment:
STATES Submit Nonattainment Area Designations
Title III Air Toxics:
Publish Draft Chemical List Petition Procedures
Publish 90/95% Early Reduction Guidance
Propose List of High Risk Pollutants (Lesser
Quantity Cutoffs, 90-95% Early Reduction)
Title I - Nonattainment:
STATES Submit PM-10 Areas Unable to Attain by 1994
STATES Respond to List of PM-10, SO2, Lead
Nonattainment Areas
Title III - Air Toxics:
Publish Draft List of Source Categories
Title V Permits:
Propose State Permit Regulations
                                19

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Implementation Strategy for the Clean Air Act Amendments of 1990
    Communications Focus
                Regulatory Activities
   Cleaner Cory and
      Cleaner Fuels
MAY
1991
Title I - Nonattainment:
  STATES' Deadline for Reasonably Available Control
  Technology Requirements (Deficiency Corrections)
  Notify STATES of Intent to Modify Suggested
   Boundaries
  Publish Guidance on Stationary Source CO Contributions
  Finalize Criteria to Measure Ozone Transport
Title II - Mobile Sources:
  Finalize Gasoline Reid Vapor Pressure Regulations
  Finalize Tier I Car and Truck Standards
  Propose Reformulated  Gasoline Requirements
  Propose Clean Fuels Fleet and California Pilot Credit
  Programs
  Propose Urban Bus  Regulations
  Propose Emission Control Diagnostic Rule
Title III - Air Toxics:
  Propose Standards for Large Municipal Waste
   Combustors
  Publish Final Chemical List Petition Procedures
Title IV - Acid Rain:
  Propose Regulations  for Auctions and Sales
Title VI - CFCs:
  Propose CFC Phase-out Regulations
  protecting the
       Ozone Layer
JUNE
1991
Title I - Nonattainment:
 Propose PM-10 Area Reclassifications
Title VI - CFCs:
 Propose Mobile Air Conditioning Recycling Regulations
  As$lstiitg Small
       Businesses
JULY
1991
Title I - Nonattainment:
  Propose Revisions to New Source Review Program
  Finalize Ozone, CO Nonattainment Boundaries
  Finalize List of Additional PM-10 Nonattainment
   Areas and SO2, Lead Designations
Title V - Permits:
  Publish Guidance on State Assistance to Small
   Businesses
Title VII - Enforcement:
  Propose Administrative Penalties Rules of Practice
                                              20

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                                               The Regulatory Agenda:  The First Two Years
  Communications Focus
                Regulatory Activities
Attainment of Air
     Quality Standards
AUG
1991
Title I - Nonattainment:
  Propose PM-10 Reasonably Available Control Measures/
   Best  Available Control Measures Guidance
  Issue Transportation Planning Guidance
  Publish Title I General Preamble
  Publish 1990 Air Quality Data
Title II   Mobile Sources:
  Publish Marketable Gasoline Oxygen Credit
   Guidelines
Title VII - Enforcement:
  Propose Rules for Citizen Suits
Acid Rain
                                 SEPT
                                 1991
         Title IV - Acid Rain:
          Propose Emission Trading System
          Propose Acid Rain Permit Program
          Propose Continuous Emission Monitor Requirements
          Propose NOx Requirements for Utility Boilers
          Propose Conservation and Renewable Incentives
         Title VI  CFCs:
          Finalize CFC Phase-out Regulations
Business Opportunities
    in the Clean Air Act
OCT
1991
Title I - Nonattainment:
  Publish VOC and CO Emission Inventory Guidance
Title II   Mobile Sources:
  Finalize Cold Temperature CO Standards
  Publish Study on Non-road Engines
Title III - Air Toxics:
  Propose Maximum Achievable Control Technology for
  Coke Ovens
                                             21

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 Communications Focus
                Regulatory Activities
One Year of Progress
    Toward Cleaner Air
NOV
1991
 Title I  Nonattainment:
  Propose Tank Vessel Rule
  Publish Conformity Criteria
  Publish Guidance on  Control Cost-effectiveness
  STATES Submit PM-10 State Implementation Plans
  Publish Outer Continental Shelf Rule
  Publish Guidance on  Inspection/Maintenance
   Programs
  Publish Guidance on  Transportation Control
   Measures
 Title II  Mobile Sources:
  Propose Clean Fuel Vehicle Standard
  Finalize  Vehicle Evaporative Emissions Regulations
  Finalize  Onboard Controls
  Finalize  Reformulated Gasoline Requirements
  Finalize  Urban Bus Regulations
  Finalize  Clean Fuels Fleet and California Pilot
   Credit  Program
 Title III   Air Toxics:
  Publish Final List of Source Categories
  Propose  Guidance for Modification  Provisions
  Publish Draft Regulatory Schedule for All Source
   Categories
  Finalize Standards for Large Municipal Waste
  Combustors
  Propose  List of Substances  for Accidental Releases
   Prevention Program
  Propose  Maximum Achievable Control Technology for
   Hazardous Organic  Chemical Manufacturing
  Propose  Maximum Achievable Control Technology for
   Dry Cleaners (per court order)
  Finalize List of High Risk Pollutants (Lesser
   Quantity Cutoff, 90%/95% Early Reductions)
Title IV - Acid Rain:
  Finalize Regulations for Auctions and Sales
Title V - Permits:
  Finalize State Permit  Regulations
  Propose  Federal Permit Regulations
Title VI -  CFCs:
  Ban Nonessential Uses
  Finalize Mobile Air Conditioning Recycling Regulations
Title VII - Enforcement:
  Propose  Rules for Field Citation Program
  Propose  Rules for Contractor Listing
 ir. Toxics
                                DEC
                                1991
        Revise Two-Year Implementation Strategy
        Title I - Nonattainment:
          Finalize PM-10 Area Rcclassilications
        Title IV - Acid Rain:
          Propose List of Phase II Utility Allowances
                                              22

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Communications Focus
Regulatory Activities
Enforcement










































TAN
J/\lN
1992



FEB
1992



MAR
1992

APR
1992

MAY
1992





















JUNE
1992
JULY
1992
T"iilt» TTT A i w T"/-vij-I r*f >
title 111 - Air 1 oxics:
Propose Standards for Small Municipal Waste
Combustors
Title VII Enforcement:
Finalize Administrative Penalties Rules of Practice
Title III - Air Toxics:
Propose Maximum Achievable Control Technology for
Chromium Electroplating
Title VII Enforcement:
Propose Monetary Awards Rules
Title III - Air Toxics:
Propose Maximum Achievable Control Technology for
Commercial Sterilizers
Title III - Air Toxics:
Propose Maximum Achievable Control Technology for
Asbestos
Title I - Nonattainment:
Finalize PM-10 Reasonably Available Control
Measures/Best Available Control Measures Guidance
Finalize Revisions to New Source Review Program
Finalize Rules for Ozone, NOx, VOC Enhanced
Monitoring
Title II - Mobile Sources:
Finalize Emission Control Diagnostic Rule
Publish Mobile-Source Related Air Toxics Study
Title III - Air Toxics:
Finalize Guidance for Modification Provisions
Title IV - Acid Rain:
Finalize Emission Trading System
Finalize Continuous Emission Monitor Requirements
Finalize NOx Requirements for Utility Boilers
Finalize Conservation and Renewable Incentives
Finalize Acid Rain Permit Program
Title V - Permits:
Finalize Federal Permit Program
Title VI - CFCs:
Finalize CFC and HCFC Labelling Regulations
Title VII - Enforcement:
Propose Rules for Compliance Certification




                                    23

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Communications Focus
Regulatory Activities









Meeting the Deadlines
in the Clean Air Act





























AUG
1992


SEPT
1992
OCT
1992

NOV
1992
























DEC
1992



Title I - Nonattainment:
Publish 1991 Air Quality Data
Title VII - Enforcement:
Finalize Guidance/Rules for Citizen Suits


Title III Air Toxics:
Finalize Maximum Achievable Control Technology for
Coke Ovens
Title I - Nonattainment:
Finalize Tank Vessel Rule
Finalize Rules for Economic Incentives Program
Propose First Set of NSPS Rules
STATES Submit RACT Catch-up Rules, NSR Rules, CO
Attainment Demonstration, and Contingency Measures
STATES Submit Base Year Ozone/CO Emission
Inventories
Title II Mobile Sources:
Finalize Clean-Fuel Vehicle Standards
Determine Significance of Non-road Engine
Emissions
Title III - Air Toxics:
Finalize Maximum Achievable Control Technology for
Dry Cleaners (per court order)
Finalize Maximum Achievable Control Technology for
Hazardous Organic Chemical Manufacturing
Finalize Regulatory Schedule for All Source Categories
Finalize List of Substances for Accidental Releases
Prevention Program
Title VI - CFCs:
Finalize Safe Alternatives Program
Title VII - Enforcement:
Finalize Guidance/Rules for Field Citation Program
Finalize Guidance/Rules for Contractor Listing
Finalize Rules for Monetary Awards
Title III - Air Toxics:
Finalize Standards for Small Municipal Waste
Combustors
Title IV - Acid Rain:
Finalize List of Phase II Utility Allowances
                                24

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                                          The Regulatory Agenda:  The First Two Years
       In the subsections to follow, regulatory highlights and major issues that EPA will
focus on over the next two years are presented for each title.  Additional information on
the statutory requirements have been summarized in several documents developed by
EPA as listed in Appendix A. For more information, a Headquarters or Regional EPA
office may be contacted (see Appendix C).

6.1 Title I - Nonattainment

       Title I includes provisions for attaining and maintaining the national ambient air
quality standards (NAAQS).  The NAAQS are set to protect public health and welfare
and have been established for six criteria pollutants (ozone, carbon monoxide, paniculate
matter, lead, sulfur dioxide, and nitrogen dioxide).  Although significant improvements in
air quality have occurred since the Agency was created twenty years ago, millions of
people still live in urban areas which do not meet the NAAQS. This results in adverse
human health effects  such as respiratory illness and premature mortality, and in adverse
environmental effects such as impairment of visibility, reduction in crop yields, and  forest
damage. A summary of the actions required by the title between now and the year 2010
is presented in Figure B-l found in Appendix B.

       The various actions required under Title I have been grouped into several major
work areas,  as follows:

       o     Designation and classification of areas;
       o     State implementation plan (SIP) control strategy development;
       o     Emission inventory and modeling;
       o     SIP procedures and permits;
       o     Federal measures;
       o     Tracking progress/sanctions and federal implementation plans;
       o     Ozone Transport Commission; and
       o     Special  studies.

Two of these work areas have been selected to illustrate EPA's planning efforts for Title
I:  designation and classification of areas and SIP control strategy development.

      The Clean Air Act Amendments of 1990 clarify how areas will be designated as
nonattainment and specify procedures to define the boundaries of these areas. Figure
B-2, found in Appendix B, presents an  example of the planning materials developed for
the designation/classification process. The various regulatory activities required by the
                                         25

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Implementation Strategy for the Clean Air Act Amendments of 1990
Clean Air Act Amendments of 1990 have been identified below the timeline.  Activities
needed to make the required regulatory activity happen are identified above the timeline.

       Nonattainment areas are classified for ozone, carbon monoxide, and particulate
matter in accordance with the severity of the air pollution problem.  (See Table B-l in
Appendix B.)  Depending upon the degree  to which an area exceeds the standard, that
area will be required to implement various  control programs and achieve attainment of
the NAAQS within a specified  timeframe.  For example, Figures B-3  and B-4  in
Appendix B identify the state implementation plan (SIP) requirements for the various
ozone and carbon monoxide nonattainment areas, respectively.

      The Amendments  allow some discretion in the classification of areas (5 percent
adjustment criteria) and the setting of geographical boundaries for the nonattainment
area. In applying this discretion, EPA must address several issues, including:

      o      How can consistency be ensured in boundary determinations across the
             country and for different pollutants?

      o      Should  these boundaries conform to recognized political/administrative
             boundaries?

      o      What criteria will be used to  approve or disapprove requests to change
             area classifications?

      Figure B-5 in Appendix  B presents activities over the next sev  il years related to
ozone and carbon monoxide SIPs.  An important early deadline for State air pollution
control agencies is six months after enactment - May 15, 1991.  At this time, all states
with ozone nonattainment areas designated before November  15, 1990, must revise their
SIPs to reflect required stationary and mobile sources and submit them to EPA.
Stationary source control  measures  required are the reasonably available control
technology (RACT) "fix-ups".

      Mobile source control measures include vehicle inspection and maintenance
(I/M) programs to reduce carbon monoxide and precursors to ozone. Under the new
law, I/M programs will be required in approximately 110 nonattainment  areas. Forty of
these areas do not presently have an I/M program.  Basic I/M programs will be required
in all moderate ozone nonattainment areas and enhanced I/M programs will be required
in serious, severe, and extreme nonattainment areas.  Enhanced I/M programs will be
                                        26

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                                          The Regulatory Agenda: The First Two Years
required to achieve emissions reductions greater than the current, or basic, programs.
One of the most common ways to enhance a program is, in addition to the usual tailpipe
emissions test, to check whether emissions control components have been tampered with
or removed.

       Annual inspections and centralized programs are required by the Clean Air Act
Amendments of 1990 unless a state can demonstrate that biennial or decentralized
programs are equally or more effective.  The EPA is required to review, revise, and
republish Federal guidance on I/M programs within 12  months of enactment.  The
Agency currently anticipates publishing this guidance earlier than required in order to
provide state agencies more time to obtain additional legislative authority, if needed.

       Major near-term issues that surface with respect  to the required SIP revisions
include:

       o     How can those states which earlier failed  to effectively implement similar
             requirements, be encouraged, within the short timeframe allowed, to adopt
             major SIP revisions?

       o     How should EPA effectively deal with an  area which fails to meet the
             required deadline?

       Several issues will need to be resolved by EPA with respect to  I/M programs,
including:

       o     Can decentralized programs be established so  that they  are as effective as
             centralized programs?

       o     What is the best mechanism to implement the "on-road  testing" required by
             the Amendments?

       o     Can biennial inspection programs be established so that they are as
             effective as annual programs?

6.2 Title II - Mobile Sources

       Title II of the Clean Air Act Amendments  of 1990 contains provisions relating to
the control of mobile source emissions.  Cars and  trucks currently account for
approximately 50% of the ozone precursors (volatile organic compounds and nitrogen
                                        27

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Implementation Strategy for the Clean Air Act Amendments of 1990
oxides) and up to 90% of the carbon monoxide emissions in urban areas. The principal
reason for this problem is the rapid growth in the number of vehicles on the roadways
and the total miles driven.  This growth has offset a large portion of the emission
reductions gained from motor vehicle controls in effect to date.

      Figure B-6 in Appendix B illustrates the deadlines for the mobile source
requirements identified in the Clean Air Act Amendments of 1990.  Specific areas that
will be addressed in the first few years by EPA include:  more stringent tailpipe
standards, reformulated gasoline, an oxygenated fuels program for carbon monoxide
nonattainment areas, a California clean car pilot program, and a clean fuels program for
vehicle fleets in 22 of the worst air pollution areas.

      Passenger car standards have not changed since 1981, though control technology
and reliability have advanced dramatically.  Therefore, the new law establishes tighter
tailpipe emissions standards for hydrocarbons, carbon monoxide,  and nitrogen oxides.
The Tier I standards are to be phased-in beginning with vehicles produced in model year
1994. By the end of 1999, the Agency will determine the need, cost, and feasibility of
additional Tier II standards for  vehicles produced in model  year 2004 and later.  The
new law also extends the useful life requirements for passenger cars from 5 years/50,000
miles to 10 years/100,000 miles. In addition, for the first time, EPA will establish a
tailpipe standard for carbon monoxide under cold temperature conditions.

      Vehicle emissions resulting from gasoline  evaporation during refueling will be
controlled. The EPA must also issue regulations to improve the  systems which control
evaporative emissions when vehicles are in operation or parked.

      New programs requiring  cleaner (reformulated) gasoline will be initiated in nine
U.S.  cities beginning in 1995.  These cities are those with the worst ozone problems.
Additional ozone nonattainment areas may elect to "opt-in" to this reformulated fuels
program.  Within one year of enactment, the Agency must promulgate regulations for
reformulated gasoline to be used in gasoline-fueled vehicles. These regulations must
require the greatest reduction in emissions of volatile organic compounds and toxic air
pollutants achievable considering costs, any air- or nonair-qualiry related health and
environmental impacts, and energy requirements.

      The major issues to be addressed for reformulated gasoline include:

      o      How can an accurate baseline fuel  best be established?
                                        28

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                                          The Regulatory Agenda: The First Two Years
       o     How can an adequate supply and distribution infrastructure for the
             reformulated gasoline best be assured?

       Fuel quality will also be controlled in 41 carbon monoxide nonattainment areas
during the winter months.  This program is scheduled to begin November 1, 1992 and
will require fuel with a 2.7% oxygen content.  However, EPA may delay the start of the
program by two years if the domestic supply and distribution capacity is insufficient. The
oxygenated fuels are to be sold for a minimum of four months of the year unless EPA
reduces the timeframe in  response to a state request.  Such a request must demonstrate
that, because of meteorological conditions, a reduced period will assure that there will be
no exceedences of the carbon monoxide standard outside of the reduced period. A key
issue to be addressed by the Agency in  implementing this program will be the
establishment of the criteria EPA will use to modify the effective months of the
oxygenated fuels program.

       Two clean fuel programs are identified in the Clean Air Act Amendments of
1990.  "Clean fuels" include:  compressed natural gas, ethanol, methanol, liquified
petroleum gas, electricity, reformulated gasoline, and possibly other fuels. The first
program is a California Clean Car pilot program. Requirements for this program will be
established by rule within two years of enactment.  The law establishes emission
standards and allows the auto and fuel industries to determine whether to meet the
standards by vehicle controls, new fuels, or a combination of both technologies.  The
program will be phased in beginning in 1996 with 150,000 cars and light duty trucks. By
1999, the program will expand to cover 300,000 cars per year.  More stringent standards
(Phase II) will begin in 2001.  States with  serious, severe, or extreme ozone
nonattainment  areas may  elect to "opt-in"  to the California program.

       The second clean fuels program requires 22 areas having the worst air quality to
limit the mobile source emissions from centrally-fueled fleets of 10 or more.  This
program will be phased-in beginning in 1998 unless the vehicles meeting these standards
are not being sold in California, in which case, the program will be delayed until 2001.
The EPA is to  develop regulations on the general fleet program and credits program by
November 15, 1991.  Through the credit program, credits may be issued for: (1) the
purchase of more clean-fuel vehicles than  required; (2) the purchase of clean fuel
vehicles which meet more stringent standards;  and (3) the purchase of vehicles in
additional vehicle categories. Within 24 months of enactment, the Agency will issue
regulations with respect to converting conventional vehicles to clean fuel vehicles.
                                         29

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Implementation Strategy for the Clean Air Act Amendments of 1990
       Section 177 of the Amendments allows states to adopt California's more stringent
tailpipe standards for cars sold within their boundaries. This option, currently being
considered by a number of states, may raise production and distribution problems for the
auto industry, as well as potential enforcement and compliance monitoring problems for
EPA and the states.

6.3 Title III - Hazardous Air Pollutants

       According to industry estimates, more than 2.4 billion pounds of toxic pollutants
were emitted into the atmosphere in 1988. These emissions may result in a variety of
adverse health effects including cancer, reproductive effects, birth defects, and respiratory
illness.  Only seven hazardous air pollutants were regulated under the previous Clean Air
Act.

       Title III of the Clean Air Act Amendments of 1990 provides new tools for
controlling emissions of these pollutants.  The title addresses not only routine but also
accidental releases of hazardous air pollutants. An overview of its basic requirement is
found in Figure B-7 in Appendix B. Emissions both from large and small facilities that
contribute to air toxics problems in urban areas will be addressed. As illustrated in
Figure 4, the new law restructures the process for  developing hazardous air pollutant
emission standards for  routine releases from stationary sources.  For planning purposes,
implementation of this title over the next several years has been divided into seven major
work areas:

       o     Section 112 - Implementation and Guidance;
       o     Maximum Achievable Control Technology (MACT)/Generally Available
             Control Technologies (GACT) (2-year standards);
       o     MACT/GACT (4-year standards) ;
       o     Air Toxics Studies;
       o     Section 129 - Solid Waste Incineration;
       o     State Enabling Activities; and
       o     Accidental Releases and Chemical Safety Board.

       Planning materials to assist in structuring the work under Title III have been
prepared. Figure B-7 in Appendix B presents, over a five-year  horizon, an example of
the planning materials  developed for the two-year MACT/GACT standards.  The various
regulatory activities required by the Clean Air Act Amendments of 1990 have
                                        30

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                                         The Regulatory Agenda:  The First Two Years
 1
Review
Review
                                   Figure 4

                          TITLE III:  AIR TOXICS
                  Pollutant
                    Lltt
          Petition*
        (llfflonti
\
                   Source
                  Category
                    UK
P        PeUllons  I
I	ft  |II»«n»irp<.«) •
                           Ranking
                 Regulatory
                   Agenda
                  MACT
   Three Year
   Compliance
                        Compliance
                        Extensions
                           Installation
                              of
                           Controls
                          |«
                                 10E-MTrlgg«r Bu«d en impl* margin of ul*ty

                                 B*nz*n« tf •ctolon rulM

                                 Compllanct In 00 days or two VMrt
                                       31

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Implementation Strategy for the Clean Air Act Amendments of 1990
been identified below the timeline. Activities needed to make the required regulatory
activity happen are identified above the timeline.

       The statute establishes an initial list of 189 hazardous air pollutants. Petitions to
add or delete pollutants from this list may be submitted to the Agency beginning May 15,
1991.  Using this list of pollutants, the Agency will publish, within one year of enactment,
a list of the source categories (major and area sources) for which emission standards will
be developed.  Within two years of enactment, it will publish a schedule establishing a
date for the promulgation of these standards. Petitions may also be submitted to the
Agency to remove source categories.

       For each listed source category, EPA will issue standards requiring the maximum
degree of emissions reduction that has been  demonstrated to be achievable. These are
commonly referred to as maximum achievable control technology (MACT)  standards.
The primary consideration in establishing these  standards must be demonstrated
technology.  Other considerations which may play some role in standard selection
include: costs, non-air quality health and environmental impacts, and energy
requirements. For area sources, EPA may elect to promulgate standards which provide
for the use of generally available control technologies or management practices (GACT).
As indicated in Figure 3, the first MACT/GACT standards will be proposed for coke
ovens in October 1991 and for chemical manufacturing and dry cleaners in  November,
1991.

       Efforts to achieve early environmental benefits are encouraged in Title III.  For
example, industries will be encouraged to use the provisions which allow an alternative
compliance  date in exchange for the implemention of an early emission reduction
program.  Effective use of these provisions will allow industry flexibility in achieving
emission reductions and will result in early environmental benefits.  As  indicated in
Figure 3, EPA plans to issue guidance for sources interested in exercising this option in
the Spring of 1991. In addition, other compliance extensions may be granted as indicated
in Figure 4.

       The standards developed under Title  III to control hazardous air pollutants will
be enforced under the operating permit program required under Title V. Several issues
associated with developing emission standards include:

       o      What is the definition of "source" as it applies to the various provisions of
             Title III?
                                        32

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                                           The Regulatory Agenda:  The First Two Years
       o     What factors should be considered in differentiating between different
             types and classes of sources in setting MACT/GACT standards?

       o     When should GACT versus MACT be used for area sources?

       o     How should guidance be developed on how to use the early emission
             reduction provisions effectively in order to secure early emission reductions
             in air toxic emissions?

       o     How "high" or "low" should the hurdle be for granting petitions to add or
             delete pollutants from the list of hazardous air pollutants or to remove a
             listed source category?
       Title III contains provisions for EPA to perform studies on a variety of air toxics
problems such as deposition of toxic air pollutants into the Great Lakes, urban air toxics
concentrations, and the emissions of toxic air pollutants from electric utilities. Within
the first two years, EPA will establish an air toxics monitoring network around the Great
Lakes.

       Section 129 of Title III includes provisions for a comprehensive regulatory
program for solid waste incinerators.  In January 1991, the Agency promulgated
standards for large capacity (> 250 tons per day) municipal waste combustors (MWCs)
for most pollutants.  Regulations for lead, mercury, and cadmium emissions from these
MWCs will be promulgated by November 1991. Standards for small capacity (< 250
tons per day)  MWCs will be promulgated by November 1992.  The EPA efforts will also
emphasize the development of regulations for medical waste incinerators, commercial/
industrial waste  incinerators, and all other waste incinerators.

       Title III also includes provisions to prevent accidental releases of hazardous  air
pollutants.  Implementation of the accidental release provisions will be the responsibility
of EPA's Chemical Emergency Preparedness and Prevention Office within the Office of
Solid Waste and Emergency Response. Within  two years, the Agency will promulgate  a
list of at least 100 chemicals which, if accidentally released, can seriously damage human
health or the environment.  Threshold quantities will be established for these pollutants
taking into consideration toxicity, reactivity, volatility, dispersibility, combustibility, or
flammability.  Based upon regulations finalized within three years  of enactment, any
facility at which  a listed pollutant is present at greater than a threshold quantity will be
                                         33

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Implementation Strategy for the Clean Air Act Amendments of 1990
required to prepare and implement a risk management plan.  The plan must address
how the facility will detect and prevent, or minimize, accidental releases.

      Title III also creates the Chemical Safety and Hazard Investigation Board, an
independent safety board. The board will be responsible for investigating any accidental
release that results in a fatality or substantial property damage. It will also report
regularly to Congress and make recommendations to EPA and the Department of Labor
related to the  preparation for, or prevention of, accidental releases.

      Several major issues related to chemical accident prevention include:

      o      How best can overlapping issues be coordinated with the Department of
             Labor?

      o      What is the best way to interface the requirements of Title III of the Clean
             Air Act Amendments of 1990 with related provisions contained in Title III
             of the Emergency Planning and Community Right-to-Know Act?

6.4 Title IV -  Acid Deposition Control

      Title IV of the Clean Air Act Amendments of 1990 addresses  the control of the
pollutants associated with acid rain.  The goal of this title of the Amendments is to
achieve a 10 million ton reduction  of sulfur dioxide  (SO2) and an approximately 2 million
ton reduction in nitrogen oxides (NOx), relative to  1980 levels.  The focus of the acid
rain program is an innovative market-based emission allowance program which will
provide affected sources flexibility in meeting the mandated emission reductions.  The
acid rain allowance trading program will be the first large-scale regulatory use of market
incentives, and is already being seen as a model for regulatory reform efforts here and
abroad. Figure B-9 in Appendix B illustrates the statutory requirements of this title.
Figure B-10 presents a timeline for activities related to the SO2 allowance and  trading
provisions.

      The EPA will allocate SO2 allowances to utilities in two phases:

      o      Phase I:  Beginning in 1995, large, high-emitting coal-fired utility units will
            be affected.
                                        34

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                                           The Regulatory Agenda:  The First Two Years
       o     Phase II:  Beginning in 2000, an additional 2000 utility units with an output
             capacity of greater than or equal to 25 megawatts are included.

       o     Both phases require facilities to install continuous emission monitoring
             systems to track progress and assure compliance.  Figure B-ll in Appendix
             B identifies the regulatory events associated with emissions monitoring.

       The new law allows utilities to trade allowances within their systems and/or buy
or sell allowances to and from other affected sources.  Each source must have sufficient
allowances to cover its annual emissions; if it does not, it becomes subject to excess
emissions fees  and must offset the excess emissions in the following year.  The EPA will
promulgate regulations  for the allowance system within 18 months of enactment.  The
Agency will take  all available  steps to facilitate active trading of allowances.  This will
serve to minimize compliance costs,  maximize economic efficiency, and allow for growth.
In addition, the allowance trading system incorporates an incentive for energy
conservation and technology innovation, both of which can lower the cost of compliance
and yield  pollution prevention benefits.

       When effectively implemented, Title IV of the Clean Air Act Amendments of
1990 will  achieve a reduction in NOx of approximately 2 million tons.  Specifically, the
statute requires EPA to establish stringent new NOx emissions rates for various types of
utility boilers.  The rates are to be set at a level expected to be achievable through the
use of low NOx burner  technology and will be phased-in.  Figure B-12 presents the
major activities and timing associated with the NOx provisions.

       Key issues associated with implementing Title IV include:

       o     What is the most effective way  to use allowance trading and tracking
             procedures, as well as emissions monitoring, to achieve the economic,
             technological innovation, and energy efficiency benefits of the program?

       o     How best can permitting procedures and emissions monitoring provisions
             be established to ensure accountability and confidence that emissions
             reductions are occurring on time?

6.5 Title  V - Permits

       The Clean Air Act Amendments of 1990 establish a comprehensive operating
permit program for air emissions.  It is modelled after a similar program established
                                         35

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Implementation Strategy for the Clean Air Act Amendments of 1990
under the Federal National Pollution Elimination Discharge System (NPDES), and
brings air pollution legislation in line with other environmental statutes (e.g., the Clean
Water Act).

      The purpose of the operating program is to put in one place all of the
requirements concerning air emissions that apply to affected sources.  When fully in
place, these permits will ensure that sources are not being subjected to conflicting
requirements and that all parties have a clear picture  of those requirements.

      The permit program contained in Title V provides the building block for
implementing major portions of the Clean Air Act Amendments  of 1990. Figure 5
provides an illustration of the links between the permit program, several titles of the new
legislation, and ongoing air pollution  control programs.  Implementing the permit
program must entail close coordination with all of these programs.

      Figure B-13 presents a timeline for Title V  regulatory activities (see  Appendix B).
Major work group areas through which EPA plans to  implement these activities include:

      o     Permit Regulation Development
      o     Permit Program Start-Up
      o     Permit Program Oversight
      o     Permit Program Implementation Support

Planning material for carrying our these major work areas are contained in  Appendix B,
Figures  B-14, B-15, B-16, and B-17.

      The permit program is one of  the most important procedural reforms contained in
the new law. The EPA will develop program regulations within one year following
enactment defining the minimum elements required in a state operating permit program.
State agencies have three years from  enactment to submit a permit program to EPA for
approval. The EPA has one year to approve or disapprove a program. The operating
permit program will enable states to collect permit fees from the affected sources to
cover reasonable direct and indirect operating costs for the permit program. A permit is
to be issued for a fixed term, not to exceed five years. Though administration will be
conducted by states with approved programs, EPA will still assume federal oversight
responsibilities and all permits will be subject to public comment.
                                        36

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                                      The Regulatory Agenda:  The First Two Years
                                 Figure 5


                     TITLE V:  OPERATING PERMITS
                   Title IV
                  Acid Rain
                                Existing
                              SIP Program
    Title I
Nonattainment
                                                 Title
                                               Air Toxics
     TITLE V
PERMIT PROGRAM
                                               State
                                               Permit
                                              Programs
    Title VII
Enforcement and
  Compliance
                                     37

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Implementation Strategy for the Clean Air Act Amendments of 1990
       Title V also includes a provision requiring states to establish, as part of the SIP,
a small business stationary source technical and environmental compliance assistance
program.  The program must be in place by November 1992.  Within nine months of
enactment (August 1991), EPA will:  (1)  establish a program to assist states in
developing these small business assistance programs; (2) issue guidance for the states to
use during implementation of the programs, including guidance on alternative control
technologies and pollution prevention methods for small stationary sources; and (3)
provide for the implementation of the program if a state fails to submit a program.  The
EPA Small Business Ombudsman will monitor the program and report to Congress on its
effectiveness.

      Some of the major issues which must be addressed in implementing Title V
include:

      o      Program Scope - What sources should be considered and when?

      o      Program Startup - How can EPA effectively encourage early development
             and approval of state programs?

      o      Operational Flexibility - What is the best way to ensure that the
             requirements to issue operating permits do not unduly interfere with the
             day-to-day operations of a source?

      o      SIP/Permit Program - How can EPA best ensure that  permits will not
             erode SIP demonstrations and that SIPs will  not gridlock the permit
             process?

      o      EPA Oversight - What is the  most  effective mechanism for EPA to provide
             adequate oversight of permit  programs managed by  state agencies?
6.6 Title VI - Stratospheric Ozone Protection

      In Title VI, the Clean Air Act Amendments of 1990 essentially codify and expand
upon the Revised Montreal Protocol that was negotiated by the United States to address
the depletion of the stratospheric ozone layer. Figure B-18 in Appendix B presents the
statutory requirements of this title. The law requires a complete phase-out of
chlorofluorocarbons (CFCs) and halons with interim reductions.  Ozone-depleting
                                        38

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                                          The Regulatory Agenda:  The First Two Years
substances will be grouped into two classes.  Class I chemicals (CFCs, halons, and carbon
tetrachloride, and methyl chloroform) will be phased out by 2000, with the exception of a
methyl chloroform phaseout by 2002.  Class  II chemicals (hydrochlorofluorocarbons
(HCFCs)) will be phased out by 2030.

      Regulations are required to reduce the use and emissions of Class I and Class II
substances to the "lowest achievable level" and to maximize the recapture and recycling
of these chemicals. The EPA will develop a regulation for the use and disposal of Class
I chemicals during the service, repair, or disposal of appliances and industrial process
refrigeration.  This rule is scheduled to be promulgated  by January 1,  1992 and to
become effective on July 1, 1992.  A subsequent rule promulgated by November 15, 1994
will establish standards and requirements regarding all other uses and disposal of Class I
and II chemicals.  In addition, the Clean Air Act Amendments of 1990 require EPA to
establish standards by November 15, 1991 for the recapture and recycling of refrigerant
during the service of motor vehicle air conditioners (MACs).  By November 15,  1992, the
Agency will promulgate rules with respect to safe alternatives for Class I and II
chemicals. At this time, EPA will also publish a list of the substitutes prohibited for
specific uses and the safe alternatives identified for specific uses. Of key importance in
this program is the need to evaluate each alternative based on its overall impact on the
environment.  The EPA will attempt to  select alternatives that will maximize benefits,
minimize  costs, avoid double chemical shifts, ensure safety, and enhance energy
efficiency.

      Critical issues that must be assessed include:

      o      How may HCFCs be used to lower chlorine levels?

      o      How may the energy efficiency of substitutes be improved?

      o      How can disruptions to key user sectors be minimized?

      o      How can the global warming potential of substitues be minimized?

      In  addition, EPA will develop labeling regulations for products made with or
containing Class I and Class II chemicals. The Agency is also required to promulgate  a
ban on nonessential products containing Class I chemicals by  November 15, 1991.
                                         39

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Implementation Strategy for the Clean Air Act Amendments of 1990



      Title VI also requires EPA to prepare several reports on methane emissions,
technologies available to control these emissions, and the cost-effectiveness of various
control options.
6.7 Title VII - Enforcement
       The EPA is committed to strong enforcement, and the Clean Air Act
Amendments of 1990 expand and enhance the tools available to the Agency.  The new
law incorporates enforcement features of other recent environmental statutes, including
felony penalties for knowing violations  of the Act and misdemeanor penalties for
negligent releases of hazardous pollutants.  Figure B-19 in Appendix B presents a
timeline illustrating the statutory deadlines  included in Title VII.  Figures B-20, B-21,
and B-22 in Appendix B illustrate additional enforcement activities required by the
statute.

       Under Title VII, EPA will have  more administrative enforcement procedures
available to enable the Agency to respond more  quickly to violations.  The EPA will be
able to issue administrative enforcement penalties orders of up to $200,000, and to issue
administrative orders with compliance schedules  of up to 12 months. Additionally, EPA
has the authority to establish, through regulation, a field citation program for minor
violations.  These field citations for minor violations may be issued on site during an
inspection, for up to $5,000 per day of violation.  Development of the field citiation
program will involve identifying violation types suited for field enforcement and
establishing the appropriate penalty levels.

       The EPA also has expanded authority in the contractor li?     uogram.  For
example, the authority which  excludes Clean Air  Act violators fr       leral government
contracts,  grants, and loans has been expanded to apply to any fa    .y owned or operated
by the violator. This could have broad implications for violating companies, as well as
for other Federal agencies which use those  companies.

       The Clean Air Act Amendments of 1990 have strengthened EPA's authority to
obtain reliable  compliance data from the regulated industries. Titles V and VII of the
statute provide for certifications of compliance from sources, and give explicit authority
to EPA to develop regulations which require enhanced monitoring of stationary sources.
The EPA  will need to define  appropriate source  categories to target for this enhanced
monitoring program, as well as appropriate monitoring methods. These requirements, as
implemented in part through  the operating  permit program, will facilitate compliance
                                        40

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                                           The Regulatory Agenda:  The First Two Years
determinations, and give a more accurate picture of the compliance status of the
regulated community.

       Finally,  the Amendments significantly expand a citizen's authority to enforce
Clean Air Act  requirements.  Citizen suits may now include the assessment of civil
penalties, and EPA will be provided with sufficient notice to intervene in these suits.  A
fund will be established from the ensuing penalties which EPA can use for air
compliance and enforcement activities. Hence, the Agency will need  to establish
guidelines on the appropriate use of this fund.  Further, the Clean Air Act Amendments
of 1990 provide for monetary awards of up to $10,000 to citizens who provide
information leading to a criminal conviction or a civil penalty.

       Major issues associated with Title VII include:

       o     How should criteria for categorizing violations and setting penalties be
             defined?

       o     What will be the scope of the field citation program?

       o     What should the criteria be for enhanced monitoring requirements and
             over what timeframe will they be implemented?

       o     What will be the critieria for utilizing monies gained from citizen suits?

6.8 Title VIII  - Miscellaneous

       Title VIII of the Clean Air Act Amendments of 1990 includes  various
miscellaneous provisions.  Figure B-23 in Appendix B illustrates the requirements of this
title.  Two key provisions address visibility and emissions from sources on the Outer
Continental Shelf. The visibility provision requires EPA to:  (1) conduct research to
identify and evaluate those  sources and source regions that either impair visibility or
provide predominantly clean air for Class I areas; and (2) assess the impacts of the
implementation of provisions of the Clean Air Act Amendments of 1990 as to the
progress and improvement of visibility in Class I areas. A visibility transport region may
be established when the Agency determines that current  or projected  interstate transport
of air pollutants from one or more states contributes significantly to visibility impairment
in Class I areas located in the affected states. A Grand Canyon Visibility Transport
Commission must  be established by November 15, 1991.
                                         41

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Implementation Strategy for the Clean Air Act Amendments of 1990
      The Outer Continental Shelf provisions require EPA to promulgate regulations to
control air pollution for sources located offshore of the states along the Pacific, Atlantic,
and Arctic coasts as well as sources offshore of Florida on the United States Gulf Coast.

      Title VIII also  includes provisions related to several studies and reports.
Examples include a study of renewable energy and energy conservation incentives, a
study and test program on the development of a hydrogen fuel cell electric vehicle,  and
an analysis of costs and benefits.  For many of these efforts, EPA will consult with other
federal agencies.  This title also establishes a program to monitor and improve air
quality in regions along the U.S./Mexico border.

6.9    Title IX - Clean Air Research

      Title IX of the Clean Air Act Amendments of 1990 addresses air pollution
research areas including monitoring and modelling, health effects, ecological effects,
accidental releases, pollution prevention and emissions control, acid rain, and alternative
motor vehicle fuels. Figure B-24  in Appendix B presents the  statutory requirements of
Title IX.  The provisions require ecosystem studies on the effects of air pollutants on
water quality, forests,  biological diversity and other terrestrial and aquatic systems
exposed to air pollutants; call for  the continuation of National Acid Precipitation
Assessment Program (NAPAP); mandate the development of technologies and strategies
for air pollution prevention from stationary and area sources; and call for several major
studies.  The EPA must improve methods and techniques for  measuring individual air
pollutants and complex mixtures, and conduct research on long- and short-term health
effects, including the requirement for a new interagency task force to coordinate these
research programs.  Finally, the Agency must develop improved monitoring and
modeling methods to increase the understanding of tropospheric ozone formation and
control.

      To implement the research provisions, the EPA plans to conduct research in
emissions inventories, atmospheric modeling,  source/ambient monitoring, control
technologies, health, and ecological monitoring.  Both ecological and ambient monitoring
will be done jointly with other agencies who also need these data to meet their mission.
Other proposed work  includes developing improved risk assessment methods,
maintaining existing networks or establishing new ones for aquatic and terrestrial effects
monitoring, and continuing work on deposition chemistry as required for the NAPAP
confirmation.  Again,  these efforts in particular will be supported, in part, by other
agencies.
                                        42

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                                          The Regulatory Agenda: The First Two Years
6.10  Other Titles

      Title X addresses disadvantaged business concerns, and Title XI contains
provisions to provide additional unemployment benefits to workers laid off because of
compliance with the Clean Air Act through the Job Training Partnership Act.  Figure B-
25 in Appendix B presents the requirements of Title XL
                                         43

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           APPENDIX A
ADDITIONAL INFORMATION SOURCES

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                               APPENDIX A

                 ADDITIONAL INFORMATION SOURCES
           FOR  THE CLEAN AIR ACT AMENDMENTS OF 1990
To obtain a copy of any of the references mentioned below, please circle the item
number and complete the following information:

NAME:                  	

ORGANIZATION:	

ADDRESS:               	

CITY, STATE, ZIP:       	
                          General References Available


1.     The Clean Air Act Amendments of 1990:  Summary Materials.  U.S. EPA,
      November 15, 1990.  (20 pages; includes glossary, one page title summaries,
      legislative chronology)

2.     Clean Air Act Amendments of 1990:  Detailed Summary of Titles.  U.S. EPA,
      November 30, 1990. (approximately 150 pages; includes a detailed summary for
      all titles)

3.     Report to the Deputy Administrator:  Clean Air Act Implementation Task Force
      (July 1990)

                                 Enforcement

4.     Impact of Title VII on EPA Enforcement (10/26/90).

5.     Provisions Related to Enforcement (11/8/90).

6.     Immediately Effective Provisions of Title VII (12/12/90).
                                     A-l

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To receive copies of these documents, please send this form to:

             U.S. EPA - Office of Air and Radiation
             ANR - 443
             401 M. Street, S.W.
             Washington, D.C.  20460
                                       A-2

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              APPENDIX B
TITLE-BY-TITLE STATUTORY REQUIREMENTS

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                                                             Figure B - 1
                                        Title I  - Nonattainment
            Designation/Classification
         Boundaries - Serious and Up
     Update transp. planning guidelines
         Cost-Effectiveness Guidance
                   NOx, VOC Study
                Marine Vessels Rule
               Review existing CTGs
        CTGs for 11 source categories
        CTGs - aerospace/shipbuilding
       ACT - 25 ton VOC, NOx sources
           Ozone Design Value Study
                      NSPS Rules
           Consumer Products Study
           Consumer Products Rules

        RACT Corrections SIP revision
                     I/M Guidance
           Emissions Statement SIPs
   New Source Review (ind. NOx) SIPs
                Emissions Inventory
     Plan for 15% Reduction in 6 years
ACT-exist. CTGs, maj. VOC.NOx sources
            Stage 2 Vapor Recovery
               Enhanced monitoring
       Plan for 3% per year reductions
           Attainment Demonstration
                     Enhanced I/M
  VMT demonstration + Annual Updates
                 Special NSR rules
         Economic Incentive Program
       Measures to offset VMT growth
      Plan for source fee if fail to attain
     Employer vehicle occupancy TCM
           Clean fuel/low NOx boilers
     Convene NE transport commission
   Enhanced I/M,  RACT, Mod. area req.
     Measures Comparable to Stage
    Plan for Oxygenated Fuels Program
                Emissions Inventory
                     Enhanced I/M
       VMT Demonstration + Updates
           Attainment Demonstration
       Measures to offset VMT growth
         RACM and BACM Guidance
     Additional RACM/BACM Guidance
                     Designations
        Attainment Demonstration SIP
                  Implement RACM
      Plan for Permitting Major Source
            Redesignation to Serious
                       BACM SIP
        Attainment Demonstration SIP
                      Designation
                 Existing Area SIPs
                                  91   92   93  94  95  96   97   98  99
                                                Des gnations/Classificatiqns I
                                                        Federal Measures I
                        Promul-    Othw Federal    State
                         gallon  Actlon-guld«nc«,«tc.  Action
^jnffl.M
                                                      | Marginal Areas
                                                     | Moderate Areas
                                                         I Serious Areas I
        //771^aoAttf erory yr
                                                  !  I Transport Region
             Carbon Monoxide
                 3 yra unfl ittiinm«nl
                                                      | Federal Actions
              —; — :—•!—i—!- —i
                                                      | Moderate Areas |
              SO2/NO2/Lead
                                                      B-1

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                                                 Figure B - 2
                                                   TITLE  I
                 OZONE/CO  DESIGNATION  AND  CLASSIFICATION
      Guidance on
      Appropriate
      Boundaries
      (AQMD/TSO)
 Policy Memo on
 Use of "Latest"
 A.Q. Data
 (AQMD/TSD)
  Design Value

  (TSD/AQMD)
 Design Value
 Memo
 (TSD/AQMD)
         Classification Adjustment
         Criteria
         (AQMD/TSD)
Guidance for Areas
Which Will Give 45-day
Notice RE: Changing  MSA
Boundary
(AQMD/OCS/TSD)
          Guidance for Rural
          Transport Areas
          (See Modeling)
          (TSD/AQMD)
                            1yr|
                           2yr
                 3yr
4yr
Syr
Governor Gives Notice
Of Intent to Analyze
Boundaries
   EPA Gives Notice of
   Adjusted Classification
   (5%)
  Governor Submits List
  of Area Designations/
  Boundaries;  and Gov
  Requests Areas Which
  Should Be  Rural Transport
           Administrator
           Suspends
           Requirements
           for Transitional
           Areas
EPA Gives  Further
Notice  of Adjusted
Classification (5%)
         Publish Notice
         of -
          ^Designations
          Classifications
                      Submit Ozone Design Value
                      Study to Congress
        Final Notice on
        Boundaries
       Notify Governor if
       Changing Area
       Designations/Boundaries

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             Table B-l
   CLASSIFICATION OF AREAS
 CLASS
LEVEL - PPM
ATTAINMENT
    DATE
Ozone





Carbon
Monoxide
Marginal
Moderate
Serious
Severe 1
Severe 2
Extreme
Moderate
Serious
.121 to .138
.138 to .160
.160 to .180
.180 to .190
.190 to .280
.280 and above
9.1 to 16.4
16.5 and up
3 years
6 years
9 years
15 years
17 years
20 years
12/31/95
12/31/00
For ozone and CO: Adjustment Possible Based On 5%
Rule; EPA May Grant Two One-Year Extensions of
Attainment Date
PM-.10



Moderate

Serious

N/A

N/A

12/31/94
6 years for future areas
12/31/01
10 years for future areas
Possible Extension of Attainment Date Up to Five Years
for Serious Areas
                B-3

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                                    Figure B - 3
    REQUIREMENTS FOR OZONE PLANS
                                       SEVERE
                                   t
                                                       EXTREME
                                 SERIOUS
                                                     TRAFFIC CTROLS DURING CONGESTION
                                 CLEAN FUELS ROT FOR BOILER (PLAN IN 3 YRS)
                                                NO WAIVERS FROM 15 OR 3% REDUCTION ROT
                                              ROT FOR FEES.. MAJOR SOURCES IF FAIL TO ATTAIN
                                             MEASURES TO OFFSET VMT GROWTH... DUE 2YRS
                                           CONTINGENCY MEASURES IF -MILESTONE1 MISSED
                    MODERATE
            MARGINAL
                  T
SHADING INDICATES ITEMS
THAT MAY REQUIRE NEW
STATE LEGAL AUTHORITY
                                         SPECIFIC NSR REQUIREMENTS FOR EXISTING SOURCE MODS
                                       VMT DEMONSTRATION (A TCM* IN NEEDED)...6 YRS
                                     CLEAN FUELS PROGRAM (IF APPUGABLE)....42MOS
                                   ENHANCED 1/M....DUE 2 YRS
                                 DEMONSTRATION OF ATTAINMENT...4 YRS
                               PLAN FOR 3% ANNUAL AVERAGE REDUCTIONS-DUE 4YRS
             BASIC I/M (IF NOT ALREADY REQUIRED)....IMMEDIATELY
           STAGE II GASOLINE VAPOR RECOVERY.. J>UE 2 YRS
          RACT -CATCHUPS', RACT ON MAJOR SOURCES....2 YRS
        PLAN FOR 15% VOC REDUCTIONS WITHIN 6 YRS...DUE 3 YRS
                      NEW SOURCE REVIEW PROGRAM (INCLUDING CORRECTIONS)...2 YRS
    RACT -FIXUPS-...6 MOS.
EMISSION INVENTORY DUE IN 2 YRS.
            I/M CORRECTIONS...IMMEDIATELY
EMISSION STATEMENTS..2 YRS.
PERIODIC INVENTORIES

-------
                               Figure B - 4
           REQUIREMENTS FOR CO PLANS
00
I
Ul
     SHADING INDICATES ITEMS
     THAT MAY REQUIRE NEW
     STATE LEGAL AUTHORITY
                              SERIOUS
                    MODERATE
>
                                   TCMS IN 2 YRS, TO OFFSET VMT
                               CLEAN FUEL FLEET PROGRAM (>16.0PPM)
                             ATTAINMENT DEMO IN 2 YSR. (>12.7PPM)
                           ENHANCED I/M IN 2 YRS, (>12,7PPM)
                        CONTINGENCY MEASURES IN 2 YRS. (>12.7PPM)
                       VMT FORCASTS & ANNUAL UPDATES (>12.7 PPM)
                     BASIC I/M, IF NOT PREVIOUSLY REQUIRED
                   OXYGENATED FUELS....MSA/CMSA
                 EMISSIONS INVENTORY...2 YRS; 3-YR UPDATES

-------
                                                     Figure B - 5
                                                     TITLE  I
                         OZONE/CO  SIP  CONTROL  STRATEGY
 Guidance on CO demonstrations
 and  milestones (AQMD/TSD)
Guidance on significance of
stationary source CO
contributions
 Issue "Getting Started"
 guidance (AQMD)	
Decision on schedule for
providing  CTGs  (see "Federal
measures") (AQMD/ESD)
New guidance -
•Stage II (ESD/AQMD)
•New RACT requirements
(ESD/AQMD/SSCD)
•Implement future CTGs.
(ESD/AQMD/SSCD)
•Enhanced I/M (OMS/OGC/AQMD)^
•Onboard diagnostics (OMS/OGC)
•Alternate fuels opt out (QMS)
•NOx altemdte fuels program
(Extreme areas) (QMS)

•Oxygen fuels programs
(OMS/RO/AQMD)
•Percent reduction calculation
(AQMD/OGC/OMS)
•TCM offsets (AQMD/OMS)
•Planning procedures
(AQMD/OGC/OPAR)
•NSR requirements (AQMD)
                                                  New guidance  —
                                                   •Alternate fuels program (QMS)
                                                   •Consultation  (Section  121)
                                                    (OGC/AQMD)
                                                   •Percent reduction  calculation for
                                                    subsequent periods (<&: NCs/
                                                    substitutions) (AQMD/OGC)
                                                   •Extreme Ozone  plan contents
                                                    (eq. commitments/contigency
                                                    measures)  (AQMD/OGC/OMS)
                                                   •Contigency  measures
                                                    (AQMD/OGC/OMS/OPAR)
                                                                                          J
                            1yr
     2yr
         3yr
4yr
5yr

SIP with -
•RACT corrections



Guidance on -
•Stage II as appropriate
•Basic I/M and I/M
corrections
•NCy substitution for
VOC may be Included
•Transportation planning


Promulgate conformity criteria
Publish draft EPA/NAS NOXAOC
study	
TCM Guidance
Submit NOX/VOC studX to Congress |
SIP  revisions  to Include TCM program
Rule for enhanced monitoring
                                       SIP wlth-
                                        •Conformlty procedures
                                        •Stage II  (Moderate Ozone)
                                        *RACT rules - VOC/NCy Non-CTG  sources
                                        •Enhanced I/M (Serious Ozone)
                                        •Clean fuels substitution (Serious Ozone)
                                        •Enhanced
          I/M
          (aiT
(CO)
                                        •Oxy fuels (all CO areas)
                                        •Attainment Demonstration (CO)
                                        WMT SIP (CO)
                                        •VMT SIP (Serious Ozone)
•NSR corrections
•Revised major source definitions (CO)
•Contigency measures (CO  and  Moderate Ozone)
•Needed changes to planning procedures
                                        •Permits for  new  major sources  (Ozone)
•Revision for blended gas (Serious CO)
                                        •Revision to Include TCMs (Serious  CO)
•Inclusion of  emission  source statements
                                                 Report to Congress  on
                                                 Transportation Impacts
                                                 on Clean  Air
        EPA acts on request for
        substitute for clean fuel
        program
                                                 SIP  with  -
                                                  •NOX clean fuels
                                                   (Moderate Ozone)
                                    •1555  reduction through 6th
                                     year (Moderate Ozone)
                                     •First emission source
                                      statement (all areas)
                                      I  Rules for Economic Incentives  Programs
                                   SIP with -
                                    •Attainment demonstration
                                                  •3% &  milestones beyond 6 years
                                                   (Serious  Ozone)	

-------
                                              Figure B - 6
                                  Title II - Mobile Sources
               Tier I Standards
  Evaporative Emission Controls
                Short FTP Test
         Phase I Cold Temp. CO
 Clean Fuel Fleet Credit Program
       Onboard Vapor Recovery
   Emission Control Diagnostics
      CA Fuel Adoption Deadline
 Voluntary Opt-in by Other States
   Clean Fuel Vehicle Standards
Clean Fuel Conventional Vehicles
  California Pilot Clean Fuel Prog
     Report on CA Pilot Program
Urban Bus Retrofit Requirements
          Urban Bus Standards
       In-Use Urban Bus Testing

             Gasoline Volatility
      Marketable Oxygen Credits
       Valve Wear Testing Rules
         Reformulated Gasoline
           Sulfur in Diesel Fuel
         Detergents in Gasoline

      Clean Fuel TCM Exemption
             FTP Modifications
     Mobile Source Toxics Study
 Mobile Source Toxics Standards
      Nonroad Emissions Study
   Nonroad Emission Standards
         Locomotive Standards
            Rapeseed Oil Study
      Phase 2 Cold CO "Trigger-
                  Tier II Report
           Tier II Determination
                                                 94  .95   96   97    98
                               Proposal
  Other Federal
Actton-guM*nc«,*tc.
                                         B 7

-------
                   Figure B  7     Title III   Hazardous Air Pollutants
     Pollutant Petition guidance
          List of major sources
       Early reduction guidance
        Modifications guidance
         Schedule for standards
  MACT for 41 source categories
   MACT for 1st 25% categories
  MACT for 2nd 25% categories
 MACT for remaining categories
          Residual risk 41 SC's
 Residual risk 1st 25% categories
Residual risk 2nd 25% categories
    Residual risk remaining SC's

     Accidental release list/regs.
    Chemical safety board report
    Chemical process safety rule

             Great Lakes study
         Electric Utilities study
                Mercury study
         Hydrogen sulfide study
       Hydrogen fluoride study
              Coke oven study
  Area source program study/list
     NAS risk assessment study
     EPA risk assessment study
    Risk assessment commission
        State program guidance
  Mercury health threshold study
      Status reports to Congress

 Mun. Waste NSPS/EG >250 tpd
 Mun. Waste NSPS/EG <250 tpd
    Med. Waste Incin. NSPS/EG
Commercial/ind. incin. NSPS/EG
  Schedule for incineration NSPS
                               Proposal    Promulgation Other Federal  State Action  Source Action
                                                           Actions
                                               B  8

-------
                                          Figure B - 8
                                            TITLE  III
                        MACT/GACT  (2-YEAR  STANDARDS)
CD
I

CD
                      FR Proposal
                      (ESD)
                   OMB Review
                 Working group
                 closure
Engineering
St economic
analyses
(ESD)
                      I
               Test Methods
               CTSD)
                                OMB Review
Working Group
Closure
                               Enabling document
                               (ESD)
                          1yr
                       2yr
                     3yr
4yr
Syr
                               Final MACT standards for 40 source
                               categories and coke ovens

-------
                                                        Figure B  9
                                             Title IV -  Acid Rain
                                                      96 . 97 . 98 . 99 ,
          Auctions/sales Regulations
                 Phase II Allowances
            Compute Phase I Reserve
             Allowance System Rules
             Election Source Program
   Energy Conserv ./Renewable Progrm
       Issue Diesel Refin. Allowances
             Allocate Phase I Reserve
         Annual Allowance Allocation

           NOx Allowable Limit Rules
          NOx Alternative Limit Rules
       NOx Emission Averaging Rules
             Revise NOx Utility NSPS

          Elect Repowering Extension
              CCT Demo: NSPS, NSR
         Repowering Permit Appl. Due
             Repowering Exten. Rules
         Final Repowering Exten. Due

CEM, Monitoring, Recordkeeping Rules
                Sources Install CEMs
              Acid Rain Permit Rules
                 Phase I Permits Due
            State Permit Program Due
            Phase II SO2 Permits Due
            Phase II NOx Permits Due

        National Acid Lakes Registery
       Report: Feas./eff. of A.Rain Std
       Study on Interpollutant Trading
         Report on Canadian Program
     5 Yr Report, SO2 Em. Projections
                                                                                                9  10
                                                              —•	\Phase2 \   \
                                                               llowance System ; ;: I .  !:  t  . J,...... ,J.
                  ; BonuB Allowance Ends
                  K
                  Repowering Allowance Bnd»
        8.95 MM Ton Cup Starts
       plus Bonus &. Repowering
            Allowances
      Requ rements
   'Wering/CIean Coal  |
Permits/Compl
       and Reports
                                        PropoMl
                                                               Other Fedwsl
                                                             Adlon-guklance.etc.
                                                 B-10

-------
Trading
                                                                                         Figure B-10
                                                                                                                                                              SO2 Allowances
                                                                                                                                                             Allocation/Trading
                Promulgate annual auction* and
                sales regulation ($416
-------
                                                     Figure B -11
                                                                             Emissions Monitoring
CXI
Implementation Activities
Emissions tracking system
Emissions monitoring system
—Phase 1 sources
—Phase II sources
Assess industry
technical capabilities
Training
Reporting
Auditing
Promulgate regulation(s) lor CEMS, —
for any alternative monitoring
system, and lor recordkeeping and
reporting ol Information
(§412(a).(d))
Prescribe means to calculate —
emissions lor periods when
CEMS or alternative data are
unavailable (§4 12
-------
Figure B-12
                                 NOx Reductions

Propose revised NSPS for NOx —
emissions from fossil fuel fired
steam generating unils
(§407(c)(1))
Promulgate NOx emissions I
averaging regulations (§407(e|)
Promulgate NOx annual allowable —
emission limitation regulations lor Type 1
boilers (tangendalty fired boilers and dry
bottom wall- fired boilers) (J407(b)(1))
Publish proposed rule
ENACTMENT (7/91)
11/13/90
|lllll lilll|lil Iliilfl
1991 1992 18
CO I I
CO
JmoloiminUtlon ActlvlllM I I

technical capabilities
I I
Promulgate ^
regulations ft
(wet bottom
types of boile
[Illllllllll
93 1(

Option to revise emission limits —
for Type 1 boilers not covered
under §407(b)(1)
*Dx annual allowable emission limitation —
>r Type II boilers
wall fired boilers, cyclones, and all other
rs) (§407(b)(2))
- Promulgate NSPS
(S407(c)(1»
Publish proposed rule — i
(&95)
Phase! begins— i
\ 1 1 1 1 1 1 1 1 C 1 I 1 |
)94 1995 1996 19
I
I
I L^L^M
I
Initiate necessary new | 1
research
Tyrv. II r«giJ«rJon«




compliance ^
• — NOx applications due
,- Phase II begins
97 1998 1999 2000 2001 2002 2003 2004 2005
I
I
I
I

-------
                                              Figure B-13
                                       Title V - Permits
         Regulation Development
             Part 71 Regulations
Small Source Assistance Program
              State Permit Plans
              EPA Plan Approval
         Permit Applications Due
                 Permits Issued
               Federal Oversight
                                       91    92    93    94   95  ,  96  ,  97  ,  98  |  99  ,  0
                                       Proposal
Promul-     Other Federal      State
 gation   Action-guidance,etc.    Action
                                          B-14

-------
                                                Figure B - 14
                                                  TITLE  V
                                  PERMIT PROGRAM  STARTUP
oo
i

en
            Review State
            Transition Plans
            (AQMD/RO/SSCD)
          State Legislative
          Change Support
          (OPAR/AQMD/RO)
Early Financial
Support
(AQMD/RO/OPMO)
                    Program
                    Development
                    Guidance
                    (AQMD/SSCD/OGC/RO)
                    Fee Guidance
                    (AQMD)
Conduct Workshops
(AQMD/RO/ESD/TSD/
SSCD)
Plan Approval
Guidance
(OGC/RO/AQMD)
                                                                              Transition Support
                                                                              (RO/AQMD/SSCD/OGC)
                              1yr
                                   2yr
                Syr
             4yr
5yr
                   Establish Small
                   Source Program
                            Small Source
                            SIP Revisions
                            Submitted
                            NB: EPA Acts
                            If State Fails
             State   Plans
             Submitted
                         Revised Plan
                         If Disapproval
                                          EPA Action On Interm
                                          State Fee Programs
                                                             EPA Action
                                                             On  Plans

-------
                                                     Figure B -15
                                                   TITLE  V
                               PERMIT  PROGRAM  OVERSIGHT
                                Develop Audit
                                Procedures
                                (AQMD/RO/SSCD)
CO
                        Prepare Management
                        Tracking Systems
                        (AQMD/TSD/RO)
         Review Transition
         Plan  Implementation
         (AQMD/RO)
                    Waive Veto for
                    Certain Sources
                    (AQMD/OGC/SSCD)
                             Audits
                                                                          MOUs
            Guidance Regarding
            Imposition of
            Sanctions
            (AQMD/OGC/OPPE)
                       Fee Accounting
                       Procedures
                       (AQMD/RO)
                                         Procedures for
                                         Evaluating State
                                         Permits
                                         (AQMD/RO/SSCD)
                         Feedback to
                         Air Programs
                         (AQMD)
                            1yr
2yr
3yr
4yr
Syr
                                                      May Sanction
                                                      If No Plan
                                                                   May Sanction
                                                                   If Inadequate
                                                                   Implementation
                                                                   May Promulgate
                                                                   Limitations on
                                                                   Veto
                                       Sanctions If No
                                       Nonattalnment
                                       Premit Program
                                         Federal
                                         Promulgation
                                         If State Action
                                         Insufficient
                                                         Permit  Review/
                                                         Veto
                                                         Terminate,
                                                         Modify, Revoke
                                                         or Reissue
                                                         Permits

-------
                                         Figure B -16
                                           TITLE V
                        PERMIT REGULATION  DEVELOPMENT
                  Work with NMQS,
                  NESHAP, and Acid
                  Deposition Programs;
                  Shapiro SuperGroup
                  (AQMD/OAIAP/ESD)
00
           Prepare Draft
           Regulations
           (AQMD/OGC/OPPE)
     Form Workgroup
     Conduct Sessions
     (AQMD/SSCD/ESD/TSD)
Analytic Methods
Guidance Development
CTSD/ESD/ORD)
                          1yr
            2yr
   Syr
4yr
5yr
       Propose
       Federal  Regs
   Promulgate
   Federal  Regs
Optional
Analytic Methods
Rulemaking

-------
                                              Figure B-17
                                                TITLE  V
                   PERMIT  PROGRAM  IMPLEMENTATION SUPPORT
00
               Establish State/
               Federal Permltter
               Network
               (AQMD/RO/SSCD/OGC)
Bulletin Board
Clearinghouse
(AQMD/TSD)
     Specify data system
     Requirements
     (TSD/AQMD/RO)
     Support State
     Program Needs
     (AQMD/SSCD/RO)
                 Support OAQPS/
                 ORD Technical Centers
                 (AQMD/ESD/ORD/TSD)
                             1yr
                                      Develop Data
                                      Management System
                                      CTSD/AQMD)
                       Standard Application
                       Forms and Completeness
                       Guidance/Model Permits
                       (AQMD/RO/SSCD/TSD)
                          2yr
   Permit Writer Training
   Courses/Workshops
   (AQMD/ESD/RO/SSCD)
3yr
4yr
Syr

-------
                                                                 Figure B - 18
                              Title VI  - Stratospheric Ozone Protection
     Listing of Class l&ll Substances
   Assign Ozone-Depleting Potential
         Allowance Transfer Rules
    Assign Global Warming Potential
     Class I Subs. Production Rules
      Alternatives for Class l/ll Subs
    Rules Implem. Montreal Protocol
      Class I Substance Phase-Out
      Methyl Chloroform Phase-Out
    Essential Use-Methyl Chloroform
  Execption for Developing Countries
     Class II Subs. Production Rules

                  Labeling Rules
           Class II Warning Labels

         Auto Air Conditioner Rules
      Auto Air Conditioner Servicing
    Small Auto Refrig. Container Ban
        Appliance/lnd. Refrig. Rules
            Refrigerant Prohibition

        Nonessential Product Rules
   Prohib. Certain Nonessential Prod.
    Prohib. Other Nonessential Prod.

        Federal Procurement Rules
   Compliance w/ Procurement Rules

         Monitoring/Reporting Rules
     NASA/NOAA Monitoring Report
     Class l/ll Substance Use Report
     Ozone Depletion Effects Report
   Fire Suppression Assess. Reports
             Airline Safety Report
Technology Status Report to Congress

               Sources/Inventory
           International Emissions
 Preventing Increased Concentrations
       Determining Natural Sources
       Limiting Growth in Emissions
                                         Proposal
Promul-
gation
   Other Federal
Action-guidancs.etc.
State
Action
Source
Action
                                                               B-19

-------
                                      Figure B-19
            Title VII - Provisions Relating to Enforcement
  Compliance Certif./Monitoring

Past Violations Amend, in Effect
91

92
••
•••
A
93
.
94

95

96

*

«

99

°

                                Proposal
Promul-   Other Federal    State
gation  Action-guidance,etc.   Action
Source
Action
                                         B-20

-------
                                                    Figure B - 20
                                                    TITLE  VII
                       ADMINISTRATIVE  ENFORCEMENT  PROGRAM
            Implementing
            Guidance on
            Administrative Orders
           Review Hearing and
           Discovery Procedures
         General Guidance on
         Title VII Authorities
     Guidance on Minimum
     Requirements for State
     Enforcement Program
en
Survey of
Administrative Penalty
and  Reid Citation
Programs
                                        Implementing
                                        Guidance on
                                        Administrative
                                        Penalties
                                       ' (DOJ)
                                                  SUPPORT
                       Develop
                       Administrative
                       Penalty Matrix
Revise
Enforcement
Policies
                        Implementing
                        Field Citation
                        Guidance
Inspector
Training  Course
State/Local Guidance  on
How to Develop
Admlnstratlve Penalty  or
Field Citation Program
                               1yr
                                          2yr
                                   3yr
                          4yr
                           Syr
                 Propose Part 22
                 Hearing Procedures
                 for Administrative
                 Penalties (OE)
                                  Promulgate
                                  Part 22
                                  Amendments
                                  (OE)
                                                  PRODUCTS
                   Propose Field
                   Citation Program (DOJ)
                   and Rules for
                   Discovery
                                              Promulgate Field
                                              Citation Requlations (DOJ)
                                             and  Rules
                                             for Discovery
             (All products and support require SSCD and AED/OE development)

-------
                                                  Figure B - 21
                                                  TITLE  VII
                         COMPLIANCE  CERTIFICATION PROGRAM
CD
           Methods Development
           (ORD/TSD)
         Survey of Monitoring
         Methods and
         Identification of
         necessary new/
         revised methods
         (ORD.TSD)
Proposal of Title V
Regulations
(AQMD)
        Decision memo
        on implementation
        approach
       Provide Title V
       Workgroup with
       Compliance
       Certification
       Requirements
                    Promulgation of
                    Title V Regulations
Data System
Development
CTSD)F
                 Define
                 Compliance
                 for Monitoring
                 Methods
                                                 Enforcement
                                                 Response Manual
                                     Data System
                                     Guidance
             Permit Writers'
             Handbook
                                                                                 SUPPORT
                              1yr
                                   2yr
                              Syr
4yr
Syr
                 Propose Compliance
                 Certification Regulations
                                       Promulgate Compliance
                                       Certification Regulations
                                                   PRODUCTS
      (All products and support require SSCD development)

-------
                                                 Figure B - 22
                                                TITLE  VII
                            OTHER  ENFORCEMENT  PROGRAMS
ro
CO
                  Review
                  Federal/State
                  Award Programs
                 Manual on how to use
                 Award Regulations
                 Guidance on
                 Contractor
                 Inspections
Evaluate existing
tracking mechanism
for citizen suits
and awards
(DOJ/OE)
Guidance on
Listing
    SUPPORT
                             1yr
           2yr
        3yr
4yr
5yr
                   Propose Citizen
                   Suit Regulations
                    Propose Contractor
                    Listing Regulations
                    (OE)
                                           I    I
           Promulgate Contractor
           Listing Regulations
           (OE)
                          Propose Award
                          Regulations
                          (DOJ)
           Promulgate Award
           Regulations
           (DOJ)
                                                                            PRODUCTS
        (All products and support require SSCD and AED/OE development)

-------
                                      Figure B - 23
                          Title VIII - Miscellaneous
   OCS Rules - except Gulf Coast
             OCS Impact Study
  States Must Submit 2/5 of Grant
        Emission Factor Revision
 Hydrogen Fuel Cell Vehicle Study
        Renewable Energy Study
     President's Report on Trade
      Economic Impact Analyses
    Contaminated Used Oil Study
        Impact Study on Visibility
   Interagency Research Program
     Grand Canyon Commission
       EPA Response/Regulation
NAS Role of Secondary Standards
      Magnetic Levitation Report
                    Proposal
Promul-
gation
  Other Federal
AcHon-g,uldanee,etc.
State
Action
                                                                Source
                                                                Action
                                          B-24

-------
                                          Figure B - 24
                          Title  IX - Clean Air Research
Mon., Modeling, Inventory Research
     Effectiveness of Nat'l Network
     Env. Health Effects Research
   Create Health Effects Task Force
   Rank 189 Chem. for Assessment
      24 Assess me nts/Yr for 8 Yrs
             Ecosystem Research
   Liquefied Gaseous Fuels Facility
      Control/Prevention Research
                  NIEHS Studies
        Interagency Research  Plan
  EPA Report on Implementing  Plan
             Revised NAPAP  Plan
Biannual NAPAP Report to Congress
   NAPAP Report on  Critical Loads
           Clean Alternative Fuels
   Int'l Control Technologies Report
   Adirondacks Effects Assessment
         Western Acid Deposition
, 91 , 92
No schedule
93

94

95

%

97

98

1 "

| °

                      Proposal      Promul-    Other Federal     State
                                  gatlon   Actlon-guidance.etc.   Action
Source
Action
                                              B-25

-------
                                Figure B - 25
   Title XI - Clean Air Employment Transition Assistance
  DOL Rules to Implement Sec. 326
GAO Report on Employment Effects
1 91
l» 	
92
•n
93
IS
94
m
95

96

97

98

99

°

                               Proposal
Promul-   Other Federal   State
gallon Actlon-guidance.etc. Action
Source
Action
                                 B-26

-------
                APPENDIX C
EPA HEADQUARTERS AND REGIONAL AIR OFFICES

-------
                                 APPENDIX C

          EPA HEADQUARTERS AND REGIONAL AIR OFFICES
      The responsibility for implementing the Clean Air Act Amendments of 1990 is
held primarily by EPA's Office of Air and Radiation (OAR). The OAR will utilize the
expertise of many EPA offices as it undertakes this challenge, including, the Office of
General Counsel, the Office of Research and Development, the Office  of Solid Waste
and Emergency Response, and the Office of Pesticides and Toxic Substances.

      The OAR is organized into six offices. The structure of OAR is  presented in
Figure C-l and a brief description of each program offices' responsibilities is presented
below. In addition, EPA has ten regional offices, each with a division that focuses on air
issues. Addresses and telephone numbers for appropriate headquarters and regional
offices are identified following the description of the OAR program offices.
OFFICE OF PROGRAM MANAGEMENT AND OPERATIONS

      The Office of Program Management Operations (OPMO) supports the Assistant
Administrator for Air and Radiation in the areas of budget formulation, resource
allocation, strategic planning, information management, and program evaluation.  The
OPMO staff provides advice and recommendations to the AA and serves as a liaison
with OAR program offices.  This office coordinates its activities with other EPA offices,
the Office of Management and Budget, Congressional Staffs, state and local agencies,
and other federal agencies.
OFFICE OF POLICY ANALYSIS AND REVIEW

      The Office of Policy Analysis and Review (OPAR) coordinates and reviews the
analytical basis of all major OAR regulations and policies.  The office is responsible for
development, formulation, and implementation of analytical studies, both in-house and
through contracts, to  support the policy decisions of the Assistant Administrator.  In
addition, OPAR  reviews and analyzes the major regulatory and policy actions of the
program offices as well as those developed in other media programs. The OPAR staff
also provides analytical support on legislative initiatives related to the Clean Air Act.
Interagency coordination of OAR regulations and policy analysis of relevant pollution
                                       C-l

-------
control programs, including those proposed in international forums, is another function
of OPAR.  The office provides direction or is otherwise substantially involved when
comprehensive reviews of major policies take place.
OFFICE OF RADIATION PROGRAMS

      The Office of Radiation Programs (ORP) coordinates the Agency's radiation
protection activities. This office will be involved in developing specific regulations for
radionuclides developed under Title III of the Clean Air Act Amendments of 1990. The
ORP has developed seven programs that each carry out specific objectives. The Radon
Action Program provides technical and educational assistance  to the states, industry and
the public. The Nuclear Accident Response Program monitors and assesses offsite
radiation exposures, and provides guidance during any coordinated federal response to
nuclear accidents.  In the area of radioactive waste disposal, ORP sets generally
applicable environmental standards for the safe disposal of radioactive waste. The
Radioactively Contaminated Site Program supports Superfund cleanup activities. The
ORP has developed an extensive Industrial Radiation Sources Program to help  the states
implement regulations covering radionuclide emissions from industrial facilities.  The
Nonionizing Electromagnetic Fields Program takes measurements of these facilities and
analyzes and distributes the data.  Finally, in the area of technical assistance, ORP
laboratories perform radiochemical analyses, site surveys, and  evaluations of radon
measuring devices.
OFFICE OF AIR QUALITY PLANNING AND STANDARDS

      The Office of Air Quality Planning and Standards (OAQPS) is responsible for the
development of national air quality programs, technical policies, regulations, guidelines,
and criteria for air pollution control.  It supports many varied state and local government
programs in preventing and controlling air pollution.  With respect to the
implementation of the Clean Air Act Amendments of 1990, OAQPS has primary
responsibility for Titles I, III, V, and VII.

      The OAQPS is divided into four divisions. The Air Quality Managment Division
is responsible for assuring that the various  air quality management programs and
objectives required by the Clean Air Act are implemented and  that  the national  ambient
air quality standards (NAAQS) are maintained.  The Emission  Standards Division has
responsibility for evaluating the need to regulate potential air pollutants, developing
national emission standards for stationary sources, and providing consultation to  other
segments of the Agency and state and local programs. The Technical Support Division
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directs a national program to provide scientific and technical guidance to EPA
headquarters and regional officces, and state and local agencies regarding air quality
monitoring, emissions factors, and source test methods.  The Stationary Source
Compliance Division is the only headquarter-based component of the office responsible
for ensuring that stationary sources achieve and maintain compliance with the Clean Air
Act.
OFFICE OF MOBILE SOURCES

      The Office of Mobile Sources (QMS) sets and enforces emission standards for
motor vehicles, engines, and fuels, and provides guidance and technical support to state
and local programs for the control of motor vehicle emissions.  As such, it has the lead
in implementing Title II of the Clean Air Act Amendments of 1990.  Engineering and
other scientific assessments of control technologies and fuel economy are conducted in
this office. Assessments of the economic aspects of control requirements, including the
identification and development of market-based alternative control mechanisms are
carried out. The office conducts investigations to determine compliance with EPA
regulations and develops and carries out studies for assessing sources of air pollutants
from motor vehicles.  New or emerging pollution control technologies for motor vehicles
and fuels are analyzed to determine, for example, emissions of toxic substances.
OFFICE OF ATMOSPHERIC AND INDOOR AIR PROGRAMS

      The Office of Atmospheric and Indoor Air Programs (OAIAP) has lead
responsibility for the Agency's acid rain, indoor air, and stratospheric ozone programs.
In addition, OAIAP examines various strategies for mitigating climate change.  With
respect to implementation of the Clean Air Act Amendments of 1990, OAIAP has
responsibility for Titles IV and VI.

      The OAIAP  is divided into three divisions.  The Acid Rain Division was recently
created to respond  to the acid rain provisions in the Clean Air Act Amendments of 1990.
The Global Climate Change Division has responsibility for reducing  atmospheric change
through the stratospheric ozone protection program, energy initiatives, and pollution
prevention strategies. The Indoor Air Division is responsible for overall Agency indoor
air policy, coordination of federal and private sector efforts to characterize and mitigate
pollution problems  in buildings, and development and dissemination  of information on
indoor air quality to a wide range of audiences.
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                                          Figure C-l

           OFFICE OF AIR AND RADIATION ORGANIZATIONAL CHART
      Office of
Program Management
     Operations
                                          ASSISTANT
                                        ADMINISTRATOR
                                             FOR
                                      AIR AND RADIATION
     Office of
Radiation Programs
       Criteria
    and Standards
       Division
       Analysis
     and Support
       Division
       Office of
  Radiation Programs
     (Las Vegas)
       Eastern
    Environmental
   Radiation Facility
    (Montgomery)
                                            Office of
                                         Policy Analysis
                                          and Review
                              I
     Office of
Air Quality Planning
  and Standards
 Emissions Standards)
   and Engineering
       Division
   Stationary Source
     Compliance
       Division
      Air Quality
     Management
       Division
      Technical
       Support
       Division
       Radon
       Division
   Office of
Mobile Sources
   Certification
     Division
 Emission Control
    Technology
     Division
    Engineering
    Operations
     Division
                                                                        Office of
                                                                     Atmospheric and
                                                                    Indoor Air Programs
                                                                           Global
                                                                           Change
                                                                           Division
                                                                           Indoor
                                                                             Air
                                                                           Division
                                                                            Acid
                                                                            Rain
                                                                           Division
   Manufacturers
    Operations
     Division
                              Field Operations
                               and Support
                                 Division
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              OFFICE TELEPHONE NUMBERS AND ADDRESSES

                          HEADQUARTERS OFFICES

Office and Address                                     Telephone Number

Office of Air and Radiation

      Office of the Assistant Administrator                (202) 382-7400
      U.S. EPA,  ANR-443                              FTS  382-7400
      401 M. Street, S.W.
      Washington, D.C. 20460

      Office of Program Management Operations           (202) 382-7415
      U.S. EPA,  ANR-443                              FTS  382-7415
      401 M. Street, S.W.
      Washington, D.C. 20460

      Office of Policy Analysis and Review                (202) 382-5580
      U.S. EPA,  ANR-443                              FTS  382-5580
      401 M. Street, S.W.
      Washington, D.C. 20460

      Office of Radiation Programs                       (202) 475-9600
      U.S. EPA,  ANR-458                              FTS  475-9600
      401 M. Street, S.W.
      Washington, D.C. 20460

      Office of Air Quality Planning and Standards         (919) 541-5616
      U.S. EPA,  MD-10                                FTS  629-5615
      Research Triangle Park, North Carolina  27711

      Office of Mobile Sources                           (202) 382-7645
      U.S. EPA,  ANR-455                              FTS  382-7645
      401 M. Street, S.W.
      Washington, D.C. 20460

      Office of Atmospheric and Indoor Air Programs       (202) 382-7407
      U.S. EPA,  ANR-445                              FTS  382-7407
      401 M. Street, S.W.
      Washington, D.C. 20460
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Office and Address                                      Telephone Number

Office of Solid Waste and Emergency Response

      Chemical Emergency Preparedness and
       Prevention Office                                (202) 475-8600
      U.S. EPA, OS-120                                 FTS  475-8600
      401 M. Street, S.W.
      Washington, D.C. 20460

Office of General Counsel

      Air and Radiation Division                         (202) 382-7606
      U.S. EPA, LE-132A                               FTS  382-7606
      401 M. Street, S.W.
      Washington, D.C. 20460

Office of Research and Development

      Office of the  Assistant Administrator                (202) 382-7676
      U.S. EPA, RD-672                                FTS  382-7676
      401 M. Street, S.W.
      Washington, D.C. 20460

                             REGIONAL OFFICES

Office and Address                                      Telephone Number
Region I -   Air Management Division                   (617) 565-3800
            U.S. EPA - Region I                        FTS  835-3800
            John F. Kennedy Building
            Boston, MA 02203

Region II -   Air and Waste Management Division         (212) 264-2301
            U.S. EPA - Region II                       FTS  264-2301
            Jacob K.  Javitz Federal Building
            26 Federal Plaza
            New York, NY  10278
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Office and Address                                       Telephone Number

Region III -  Air, Toxics, and Radiation Division            (215)  597-9390
             U.S. EPA - Region III                       FTS   597-9390
             841 Chestnut Building
             Philadelphia, PA 19107

Region IV -  Air, Pesticides, and Toxics
             Management Division                       (404)  347-3043
             U.S. EPA - Region IV                       FTS   257-3043
             345 Courtland Street, N.E.
             Atlanta, GA 30365

Region V -   Air and Radiation Division                   (312)  353-2212
             U.S. EPA - Region V                        FTS   353-2212
             230 South Dearborn Street
             Chicago, IL 60604

Region VI -  Air, Pesticides, and Toxics Division            (214)  655-7200
             U.S. EPA - Region VI                       FTS   225-7200
             First Interstate Bank Tower at Fountain Place
             1445 Ross Avenue,  12th Floor, Suite 1200
             Dallas, TX  75202-2733

Region VII -  Air and Toxics Division                      (913)  551-7020
             U.S. EPA - Region VII                      FTS   276-7020
             726 Minnesota Avenue
             Kansas City, KS  66101

Region VIII-  Air and Toxics Division                     (303)  293-1438
             U.S. EPA - Region VIII                      FTS   330-1438
             999 18th Street, Suite 500
             Denver, CO 80202-2405

Region IX-  Air and Toxics Division                      (415)  744-1219
             U.S. EPA - Region IX                       FTS   484-1219
             75  Hawthorne Street
             San Francisco, CA  94105
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Office and Address                                      Telephone Number
Region X -  Air and Toxics Division                      (206) 442-4152
            U.S. EPA - Region X                        FTS  399-4152
            1200 Sixth Avenue
            Seattle, WA 98101
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