REGIONAL AIR STRATEGY
REGION IX
ENVIRONMENTAL PROTECTION AGENCY
March, 1976
-------
REGIONAL AIR STRATEGY
REGION IX
ENVIRONMENTAL PROTECTION AGENCY
March, 1976
-------
TABLE OF CONTENTS
Section
I. Introduction
II. Purpose, Goals, Techniques
A summary of air pollution goals and Approaches
III. State Strategies - Summary Sheets
IV. AQCR Summaries
Arizona Southern Border
Arizona Clark-Mohave
Arizona Four Corners
Arizona Phoenix-Tucson
CA Great Basin Valley
CA Los Angeles Metropolitan
CA North Central Coast
CA North Coast
CA Northeast Plateau
CA Sacramento Valley
CA San Diego
CA San Francisco Bay Area
CA San Joaquin Valley
CA South Central Coast
CA Southeast Desert
NV Clark-Mohave
- NV Intrasfeate
- NV - Northwest Nevada
HI - Hawaii
- GU - Guam
V. Program Descriptions
A. AQMP
B. A/W Coordination - 201
C. A/W Coordination - 208
D. Air/Transportation Coordination
E. Air/Energy
F. EIS Review
G. Prevention of Significant Deterioration
H. Indirect Source Review (Nevada only)
I. New Source Review
J. New Source Performance Standards
K. NESHAPS (National Emission Standards for
Hazardous Air Pollutants
L. Non-Criteria Pollutants (lll(d))
M. EPA Compliance Verification
N. State/local Compliance Verification
0. EPA Enforcement
P. Emergency Episodes
Q. Vapor Recovery
A.
B.
C.
D.
E.
F.
G.
H.
I.
J.
K.
L.
M.
N.
0.
P.
Q.
R.
S.
T.
AQCR #12
AQCR #13
AQCR #14
AQCR #15
AQCR #23
AQCR #24
AQCR #25
AQCR #26
AQCR #27
AQCR #28
AQCR #29
AQCR #30
AQCR #31
AQCR #32
AQCR #33
AQCR #13
AQCR #147
AQCR #148
AQCR #60
AQCR #246
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
37
38
39
40
41
42
43
45
46
47
49
50
51
52
53
54
55
-------
R. Other Organics
S. Inspection/Maintenance
T. Fuel Additive
U. In-Stack Monitoring ;
V. Special Air Monitoring
W. Emission Inventory Development
X. Emission Inventory Data Processing
Y. Air Monitoring Quality Assurance
Z. Air Monitoring Data Processing
AA. Isolated Point Sources
VI. Prioritization schemes
VII. Glossary
VIII.Narratives
Basic Program
Arizona
California
Guam
Hawaii
Nevada
57
58
59
60
61
62
63
65
66
67
68
70
71
BP-1 to BP-
A-l to A-15
C-l to C-41
G-l to G-3
H-l to H-3
N-l to N-10
ll
-------
INTRODUCTION
General
The Regional Air Strategy is a response to the perceived
need to formulate and implement a coordinated air program
within Region IX. The strategy provides a framework for
making decisions for programs in unrelated administrative
units with the confidence that those decisions will be
supportive of the Region's goals and objectives over the
short- and long-term, and will not be contradictory of
specific efforts in other programs. The benefits of such
a strategy are obvious; the more important issues to bear
in mind are (1) implementation, (2) resolution of. conflict
with headquarters guidance, and (3) staff recognition
of how the strategy was developed and general agreement
throughout the Region that this represents- the course for
EPA involvement. As with any plan there must be a procedure
for amendment or mid-course correction. Such a process
is not specified in this strategy, but clearly the RAS is
a beginning articulation of a dynamic plan which will provide
a basis for further refinement and definition.
Implementation
The key to controlling EPA's Air Program lies first
in a plan or strategy - this is the RAS. Once adopted,
the RAS serves as a basis for setting priorities and objectives
fehroughout the Region. The RAS serves as a guideline then,
for directing the actions of sections performing the Planning,
Enforcement and Surveillance roles which, combined, represent
Regional air programs. The RAS is a reference document that
is to be available to all air staff that they can read, be
familiar with, and understand their role within the overall
air program and the Region. It will be the experience of
those staff using the RAS that will lead to the refinement
and amendments that-will keep it current and useable.
Conflict Resolution
Throughout its development, the RAS was shown to be
tending towards recommendations which were not always congruent
or even consistent with other guidance, notablv that from
Headquarters. One of the benefits of'preparing, using,
amending and implementing the RAS, is the ability to recognize
conflicts early and to propose exceptions or modifications
such that the air program is conducted efficiently and
effectively. To the extent that national guidance may not
be universally applicable within the Region, the RAS may
serve as a basis for requesting exceptions to national guidance,
-------
History /Evolution:..
The RAS developed out of a series of staff "hearings"
during which consensus, was achieved on most major issues
surrounding the severity, type, and nature of the air
pollution problem in each Air Quality Control Region in
Region IX. A task force used that data and applied the
objectives of each of the programs currently being implemented
by EPA to develop a list of applicable programs which would
essentially either reduce emissions directly or contribute
to the further identification of a poorly understood air
quality problem. (A more defined, 5-step criteria was
actually applied.) The resulting discussion and -amendment
through "hearings" with Section Chiefs produced what the
RAS contains as "narratives".
Prom the Narratives, major themes, programs and major
elements applicable in each State were extracted as well
as summary discussions for each AQCR prepared for presentation
at Branch, Division and Executive levels of Region IX.
The RAS presented in this document is a total package
composed mainly of the Narratives as the prime communicating
tool and supported by the program descriptions, AQCR summaries,
-------
II. PURPOSE, GOALS, TECHNIQUES
Purpose
Objectives
1. Develop long- and short-range objectives.
2. Describe the means to attain these objectives.
3. Define the roles of the Regional Office, EPA and Federal,
State and local agencies in meeting these objectives.
4. Provide the rationale for the objectives, means and roles.
Application
1. Coordination
2. Resources
3. MBO output commitments
4. Contract funds
a. Regional Office
b. Headquarters
5. R&D needs
6. State communication
7. Grants
a. Base
b. Priority Objectives
8. State Assistance
a. IPA
b. Assignees
Goals
1. Attainment and maintenance of NAAQS in non-attainment areas.
2. Maintenance of NAAQS in attainment areas.
3. Preservation of air quality in areas meeting NAAQS.
4. Delegation of Federal programs to State and local agencies
where legally possible. Support compatible State and local
environmental programs.
5. Integration of EPA environmental program objectives with local,
State and Federal programs.
6. Promotion of a public environmental ethic.
-------
Techniques
A. Goals 1-3: Attain, maintain, and enhance air quality.
1. Develop professional Regional Office capability, both
programmatic and technical.
2. Include State and local agencies in regional decision
making process.
3. Impact national environmental policy with regional
priorities and perspectives.
B. Goal 4: Delegation of programs
1. Develop EPA credibility.
2. Develop State and local agency capability.
3. Delegate and Overview,expectations must be realistic.
4. Interagency Cooperative Agreements or Memorandum of
Understanding may be indicated.
C. Goal 5: Integration of EPA environmental program objectives
1. Establish interagency liaison.
2. Develop an understanding of other agencies' programs.
3. Integrate environmental factors into other agencies'
decision making process.
D. Goal 6: Public involvement
1. Obtain public participation in environmental decision
making.
2. Inform public of EPA environmental position.
3. Build public confidence in EPA.
-------
III. STATE STRATEGIES - Summary Sheets
-------
ARIZONA
PROBLEMS
Oxidant: moderate problem in Phoenix, Tucson and Yuma
metropolitan areas.
Carbon
Monoxide: moderate problem in Phoenix metropolitan area.
Particulate
Matter: slight to moderate problem throughout State.
gross problem in vicinity of copper smelters.
Sulfur
Dioxide: gross problem in vicinity of copper smelters.
STRATEGY
Ox
Reassess pollutant source/causes. X
Reassess control strategy. X
Ensure compliance with existing
regulations.
Integration of air quality
programs with other planning
agencies. X
Long-term planning and implemen-
tation by State and local agencies. X
ACTIVITIES SUPPORTING STRATEGIES
CO
X
X
PM
X
X
SO,
X
X
X
Strategy
Reassess pollutant
sources
Reassess control
strategy
Ensure compliance
Integrate air quality
programs/long-term
planning
Principle Activities
Emission inventory
development
SIP analysis and revision
Compliance Verification
AQMP, Air/201 and 208,
Air/Transportation
Additional Activitie
Quality Assurance
Source Surveillance
Isolated point sourc
I/M
Enforcement
EIS
ROLES
EPA
1. Perform 10% overview of major stationary sources by inspection
Emphasis on particulate and hydrocarbon sources. Major Federa
facilities are included.
2. Encourage State and local enforcement against non-complying
sources.
3. Perform overview and liaison on AQMP development and Air/Water
and Air/Transportation planning.
-------
4. Provide technical and R&D assistance in State/local identified
needs.
5. Perform quality assurance audit.
State 1. Revise SIP for TSP and SC^ (smelters) and CO and Ox
(Phoenix and Tucson).
2. Perform major source compliance verification.
3. Enforcement.
4. Implement statewide quality assurance program.
Local 1. Perform major source compliance verification.
2. Develop emission inventories.
3. Provide air planning support to water and transportation
planning agencies.
-------
CALIFORNIA NON-ATTAINMENT AREAS
PROBLEM
Oxidant
Carbon
Monoxide
Particulate
Matter
NOx
Gross problem in South Coast.
Moderate problem in other metropolitan areas.
Moderate problem in Central Valley.
Gross areawide problem in Los Angeles metropolitan area.
Localized problems in other metropolitan areas and the
Central Valley.
Slight-moderate problem in four AQCR's.
Gross problem in four AQCR's.
No present problem [but natural gas curtailment may cause
violations].
Significant problem in Los Angeles metropolitan area.
STRATEGY
Strategy
Reassess pollutant sources/causes
Reassess control strategy
Ensure compliance with existing
regulations
Integrate air quality programs
with other planning programs
Long-term planning and implementation
by State and local agencies
Ox CO PM SO? NOx
XXX
X X X X
XXX
XX X
X X X X X
-------
ACTIVITIES SUPPORTING STRATEGIES
Strategy
Reassess pollutant
sources
Reassess control
strategy
Ensure compliance
Integrate air quality
programs/long-term
planning
Principle Activities
Emission inventory
development
SIP analysis and
revisions
Compliance Verification
AQMP; EIS
Additional Activities
Quality assurance
Special monitoring
Source Surveillance
New Source Review
I/M
Air/Energy coordination
201 A/W-
208 A/W
Air/Transportation
ROLES
EPA
STATE
LOCAL
1. Support State and local programs to maximum extent
possible, maintaining a monitoring or overview role.
2. Provide technical and R & D assistance.
3. Continue to act as required by statute in those areas
where state and local agencies have not assumed responsibility.
1. Overview stationary and mobile source emission control programs.
2. Initiate state legislation.
3. Revise SIP.
1. Perform basic first line of stationary source control and
compliance determination.
2. Assume responsibilities for programs such as vapor recovery
hydrocarbon controls, inventory refinement, and long-term
planning.
3. Maintain accurate current data base.
-------
CALIFORNIA ATTAINMENT AREAS
Ten AQCR's are in attainment for one or more pollutant.
Ox CO PM S00 NOx
STATUS
STRATEGY
Strategy
Ensure compliance with existing
regulations X X X X
Integrate air quality programs
with other planning programs
X X X X
Long-term planning and implemen-
tation by State and local agencies X X X. X X
ACTIVITIES SUPPORTING STRATEGIES
Strategy
Ensure compliance
Integrate air. quality
pr ogr atre /long-term
planning
Principle Activities
Compliance verification
Prevention Significant
Deterioration
ROLES
EPA
State
Local
Additional Activities
New Source Review
NSPS
Air/Energy Coordinati
201 A/W
208 A/W
EIS Review
1. Maintain low profile in observing State/local programs.
2. Support State/local programs through R&D, contracts or
program grant if indicated.
3. Support local programs through comments on Federal actions
through EIS review.
1. Overview local program activities.
2. Provide technical assistance.
3. Support local basic program through subvention.
4. Initiate necessary legislation.
5. Assume enforcement against non-complying sources in
absence of effective local action.
1. Has primary responsibility for control of stationary
sources, monitoring and reporting to State. *
2. Enforces against non-complying sources.
3. Maintain accurate and current data base.
* May object to reporting on minor sources when no violations are present,
attributable to such sources. . n
-------
GUAM
PROBLEM
Particulate
Matter - Slight localized problem
Sulfur
Dioxide - Moderate localized problem
STRATEGY
PM S02
Reassess pollutant source/causes.
Reassess control strategy and revise SIP. X X
Ensure compliance with existing regulations. X
Integration of air quality planning with
other programs.
Long-term planning and implementation by
State and local agencies
ACTIVITIES SUPPORTING STRATEGY
STRATEGY PRINCIPLE ACTIVITIES
Reassess pollutant sources
Reassess control strategy SIP revision
Ensure compliance Compliance verification ,.
Integrate air quality
programs/long term planning EIS
ROLES
EPA 1. Support State compliance verification program with
minimal overview.
STATE 1. Perform compliance verification.
2. Conduct ambient monitoring.
3. Revise SIP for PM and S02.
11
-------
HAWAII
PROBLEM
Particulate
Matter
Sulfur
Carbon
Monoxide
STRATEGY
- Slight problem throughout State
- Gross problem near two power plants
- Slight localized problem in Honolulu
Reassess pollutant source/causes.
Reassess control strategy and revise SIP.
Ensure compliance with existing regulations.
Integration of air quality planning with
other planning programs.
Long-term planning and implementation by
State and local agencies.
ACTIVITIES SUPPORTING STRATEGY
TSP
X
STRATEGY
Reassess pollutant
sources
Reassess control
strategies
Compliance
Integration air program/
long term planning
ROLES
PRINCIPLE ACTIVITY
Ambient Monitoring
SIP Revision (S02 regula-
tions)
Compliance verification
208 (upcoming FY-77)
EIS
S02
CO-
X
X
ADDITIONAL ACTIVITI
Ambient Monitoring
EPA 1. Support State compliance verification program with minimal
overview.
STATE 1.
2.
2.
Perform compliance verification.
Conduct ambient monitoring.
Promulgate final power plant S02 regulations
12
-------
NEVADA
PROBLEM
Particulate
Matter
Sulfur
Dioxide
Carbon
Monoxide
Oxidant
STRATEGY
- Moderate problem throughout State
- Gross problem in vicinity of smelter
- Moderate problem in Reno and Las Vegas;
Seasonally near alert in Las Vegas.
- Moderate problem in Las Vegas; decreasing for
unknown reasons.
PM CO Ox
Reassess pollutant source/causes.
Reassess control strategy.
Ensure compliance with existing
regulations.
Integration of air quality programs
with other planning programs.
Long-term planning and implementation
by State and local agencies.
ACTIVITIES SUPPORTING STRATEGY
X
X
X
X
X
X
X
X
X
X
X
STRATEGY
Reassess pollutant
sources
Reassess control
strategies
Compliance
Integration air program/
long term planning
PRINCIPLE ACTIVITY
Quality Assurance
SIP analysis and revision
Compliance verification
Air/Transportation; AQMP
A/W 208
ADDITIONAL ACTIVITIES
Special Ox study
Vapor recovery
A/W 201
EIS; I/M
ROLES
EPA
STATE
LOCAL
1. Support local efforts to develop and maintain programs,
maintaining minimal overview.
2. Support State compliance verification program with 10% overview
and audit. No overview to locals.
3. Act in statutorily required capacity only when efforts to engage
State/local action exhausted.
4. Manage special Ox study including audit.
5. IPA/State assignee.
1. Operate ambient monitoring and stationary source control/
compliance verification and enforcement programs.
2. Revise SIP for particulate matter and S02-
3. Promote needed legislation.
1. Operate first line ambient monitoring and stationary source/
compliance verification and enforcement programs.
2. Revise SIP for oxidant~
3. Provide air planning support to water and transportation
planning agencies.
4. Maintain accurate and current data base.
13
-------
IV. AIR QUALITY CONTROL REGION (AQCR) SUMMARIES
14
-------
AQCR #12 ARIZONA SOUTHERN BORDER
PROBLEM:
GOALS:
PROGRAMS:
Moderate PM
Gross S02
Long-term
Short-term
Long-term
Short-term
Maintain NAAQS
Prevent Significant Deterioration
Define PM Problem
Stationary Source Compliance
Attain S02 and PM Standards
NSR
SIP Revision-Isolated Point
Sources (S02 and PM)
Emission. Inventory (PM)
Compliance Verification
Emission inventory Data Processing
Quality Assurance
EPA Compliance Verification
15
-------
AQCR f!3 - ARIZONA CLARK - MOHAVE
PROBLEM:
Slight PM
Moderate Ox
GOALS:
Long-term
Attain Ox and PM Standards
Define PM problem
PROGRAMS:
Short-term
Long-term
Define Ox problem
Emission Inventory (PM & HC)
SIP Revision (Ox & PM)
Vapor Recovery (-if needed)
Short-term
Quality Assurance (Ox)
Compliance Verification (PM)
EPA Compliance Verification
16
-------
AQCR #14 - ARIZONA FOUR CORNERS
PROBLEM:
GOALS:
Slight PM
Long-term
Short-term
Maintain Standards
Prevent Significant Deterioration
Delegate NSR-PSD
Reclassify Pristine Areas to Class I
PROGRAMS:
Long-term
Short-term
NSR
Significant Deterioration
Quality Assurance
Compliance Verification
Compliance Verification (PM, S02)
SIP Revision - Isolated Point
Source (Navajo Power Plant)
NSR/NSPS (S02, PM)
Significant Deterioration
Indian Land Jurisdiction
17
-------
AQCR #15 - ARIZONA PHOENIX - TUCSON
PROBLEM:
Moderate CO
Moderate Ox
Moderate PM
Gross SO2
GOALS:
Long-term
Short-term
Maintain S02 Standards
Attain PM, CO, and Ox Standards
Attain SO2 Standards
Implement I/M
Define Ox and PM Problems
PROGRAMS:
Long-term
Short-term
AQMP
NSR
Vapor Recovery (if needed)
Air Energy Coordination
Quality Assurance
In Stack Monitoring
SIP Revision (CO/OX) and Isolated
Point Sources (S02/ PM)
AQMP
Emission Inventory Development
(PM & HC)
5/L Compliance Verification (PM, 502)
Emergency Episodes (CO, S02)
I/M (CO, Ox)
Data Processing
Quality Assurance
NSR
Fuel Additives
201/208/Transportation Consistency
EPA Compliance Verification (PM, 0.
18
-------
AQCR #23 - GREAT BASIN VALLEY
PROBLEM:
None (Part-time monitor for PM shows AGM 40% of Standard.)
GOALS:
Long Term - Avert development of air quality problems.
Short Term - Work toward PSD classification system or
State equivalent.
PROGRAMS: (All long-term)
PSD
New Source Review (19 NSD categories.)
State/local Compliance Verification
19
-------
AQCR #24 - LOS ANGELES METROPOLITAN
PROBLEM:
Ox - Gross
CO - Gross (8 hr standard)
PM - Slight
N02 - Moderate (AAM)
GOALS:
Long Term:
Eliminate technical disagreement on all issues
Improve data base
Establish planning process
Establish I&M
BACT controls on sources of HC
Net Annual Decrease in HC, CO, NO2 and PM
Maintain S02 standard
Short Term:
Implement HC controls (existing)
Solve reactivity issue and source testing issue
Begin improvement of data base
Tighten Surveillance/Enf. Stationary Sources
Institutional relationships for AMP
Monitor growth-related projects
PROGRAMS:
Short Term:
Vapor recovery
*0ther organics
*I&M
*Emissions Inventory (Development and Data Handling)
*AQMP
*State/local Compliance Verification
Fuel Additives
Quality Assurance
Air/201, Air/208, Air/Energy Coordination*, Air/
Transportation*
Coordination
EIS Review
NSR
In-Stack monitoring
EPA Compliance Verification
*EPA Enforcement (if needed)
Emergency Episodes
Long Term programs marked by *
20
-------
AQCR. |25.N.ORTH CENTRAL COAST
PROBLEM:
GOALS:
Moderate Ox
Slight PM
Define air quality problem for Ox, PM and S02,
Improve validity of data.
Plan for attainment/maintenance.
PROGRAMS:
Long-term
Short-term
PSD
Emission Inventory
Quality Assurance (Ox, PM, SO-)
Other organics
A/W 208
Air/energy coordination
State/local compliance verification
-------
AQCK #G6 - NORTH COAST
PROBLEM:
GOAL:
PROGRAMS:
Slight particulate
Attainment/Preservation
Coordination with
Forest Service
RWQCB
R&D to develop alternate uses of redwood bark and waste,
EPA surveillance/compliance verification, low priority.
State/local compliance verification.
Prevention of Significant Deterioration
22
-------
AQCR 127--, NORTBEAST;;:PLATEAU
PROBLEM:
Slight particulate matter
GOAL:
Attainment/Preservation
PROGRAMS:
State/local compliance verification
Coordination with Forest Service
Air Conservation Areas/PSD
23
-------
AQCR 128 -^SACRAMENTO VALLEY
PROBLEM:
GOALS:
PROGRAMS:
PROBLEM:
GOALS:
PROGRAMS:
Moderate Ox
Moderate CO
Slight PM
Plan for attainment/maintenance.
Implement technological controls.
Define extent of CO problem.
Long-term I/M
AQMP
Short-term Vapor recovery
Other organics
Quality Assurance
State/local Compliance Verification
NSR
EIS
Air/Transportation Coordination
Fuel Additives
EPA Compliance Verification
LAKE TAHOE PORTION
Suspected Ox and CO violations.
Define problem.
Plan for attainment/maintenance/presentation.
Intergovernmental executive liaison.
Designation as interstate AQCR.
24
-------
AQCR #29 SAN DIEGO
PROBLEM:
Ox - Gross
PM - Moderate
CO - Slight
GOALS:
Long Term:
Maintain existing planning process
Improve emissions data base
Identify magnitude of L.A. contribution to Ox
problem.*
I&M
Modify HC regulations to increase level 'of control
Annual net decrease in HC, CO, and PM
Do whatever is possible on Mexican sources
Achieve NAAQS for CO, Maintain S02
*SDAPCD wants to start this in FY-77.
Short Term:
Implement existing HC regulations. Reexamine HC
controls.
Complete RAQS-II (AQMP)
Revise emission data management system
Tighten surveillance on existing sources of HC
Monitor, growth related projects
Determine cause of PM violation
PROGRAMS:
Short Term:
Vapor Recovery
Other organics
*State/local Compliance Verification
EPA Compliance Verification
EPA Enforcement (if needed)
*I&M
Fuel Additive
Instack Monitoring
*AQMP
*Air/208
*Emission Inventory Development
*Emission Inventory (Data Management)
Air/201
*Air/Transportation
*Air/Energy Coordination
*EIS Review
A/M Quality Assurance
o C
Long term programs marked by *
-------
AQCR: f30 >u SAN FRANCISCO BAY AREA
PROBLEM;
GOALS:
Photochemical oxidant - moderate, pervasive
Carbon monoxide - slight localized
Particulate matter - marginal attainment
Sulfur dioxide - may become a problem
Media-wide environmental planning process with appropriate
institutions for implementation.
Refined inventory.
Implement proven technological controls.
PROGRAMS:
Long-term
Short-term
AQMP
I/M
Vapor recovery
Other organics
State/local Compliance verification
EPA Compliance verification
201 A/W
208 A/W
EIS Review
Air Energy Coordination
In-stack monitoring
Transportation coordination
Fuel Additives
Quality Assurance
Emissions Inventory Dev.
AQMP
NSR
26
-------
AQCR §31 ~'£AN JQAQUIfl VALLEY
PROBLEM:
Gross Ox
Slight PM
Moderate CO
GOALS:
Plan for attainment/implementation.
Improve air quality pending AQMP.
PROGRAMS
Long-term AQMP
PSD
Short-term Vapor recovery
Other Organics
State/local compliance verification
Quality Assurance (CO)
EPA compliance verification
EIS
A/W 201
A/W 208
Air/Transportation coordination.
Fuel additives
Emissions Inventory Development
AQMP
27
-------
AQCR #32 SOUTH CENTRAL COASTAL
PROBLEM:
Ox - moderate
GOALS:
Long Term - Monitor and improve definition of oxidant
problem. Watch Morro Bay Power Plant.
Short Term - Confirm Ox data. Improve KC inventory.
PROGRAMS:
Short Term:
NSR (until delegated)
Quality Assurance
*Emission Inventory Development (HC)
*State/local Compliance Verification
*BSD
EIS's and 201
*Air/Energy Coordination for Morro Bay Power Plant
Long Term programs marked by *
28
-------
AQCR #33 SOUTHEAST DESERT
PROBLEM:
Ox - moderate.
PM - gross.
GOALS:
Long-term
- Mitigate the effect of growth locally and
seek solution via Los Angeles and San Diego,
Identify the role of point sources in the
PM problem.
Short-term - Maintain low profile surveillance of growth
in East Los Angeles County and Coachella
Valley.
PROGRAMS: (All long-term)
AQMP/208 (Coachella only)
201 Coordination
EIS Review
Air monitoring for trends
State/Local Compliance Verification
29
-------
NEVADA AQCR #013 CLARK-MOHAVE
RROBLEM;
GOALS:
Moderate CO
Moderate TSP
Moderate Ox
Long-term
Short-term
PROGRAMS:
Loner-term
Short-term
Implement and enforce CO, Ox, ar
TSP control programs.
Analyze Ox trend.
Develop Ox control program.
Improve CO control program.
Compliance Verification
I/M
Other Organics
Vapor Recovery, Stage II
AQMP/208
Vapor Recovery, Stage I
Ox Ambient Monitoring/Quality As
AQMP/208/Transoortation plannino
Compliance Verification
Enforcement for non-compliance
Instack Monitoring
ISR
I/M
30
-------
AQCR §147"T NEVADA INTRASTATE
PROBLEM:
GOALS:
Moderate TSP
Moderate S02
Long-term
Short-term
PROGRAMS:
Long-term
Short-term
Prevent deterioration of air quality,
Meet SO- standard.
Implement existing regulations.
PSD: delegation of NSR and
reclassification of areas,
Compliance verification
Non-compliance enforcement
Compliance verification
Enforcement
Ambient Monitoring
Instack Monitoring
ISR
Isolated Point Source
31
-------
PROBLEM:
:,'nV/Ti. AQCR §148 NORTHWEST NEVADA
Moderate CO
Moderate TSP
GOALS:
Long-term
Short-term
Maintain Ox standard.
Attain CO standard.
Maintain source compliance.
Correct deficient CO monitoring.
Launch long-term air planning effc
Ensure quality assurance of OX
monitoring.
PROGRAMS:
Long-term
Short-term
AQMP/Transportation planning/208
Compliance Verification
AQMP/2-08/Transportation planning
Ambient Monitoring/Quality Assurar.
ISR '
201/EIS
Instack Monitoring
Compliance Verification
32
-------
AQCR 160 - HAWAII
PROBLEM:
Slight CO
Slight TSP
Gross SO2
GOALS:
Long-Term:
Prevent stationary source violations
Develop CO control program
PROGRAMS:
Short-Term: Implement existing source regs
Promulgate SO2 emission regs for
power plants
Define CO problem
Long-Term: Compliance verification; AQMA
Short-Term:
Ambient Monitoring (CO, SO2)
SIP Revision (S02 emission regs)
Air/Water (208) integration
Compliance Verification
Non Compliance Enforcement
33
-------
AQCR §246 - GUAM
PROBLEM:
Slight PM
Moderate SO2
GOALS:
Long-term
Short-term
Maintain NAAQS SO2, NOX,
Eliminate S02 Hot Spots
CO, Ox
Verify S02 Standard Attainment
Stationary Source Compliance (SO2
PROGRAMS
Long-term
Short-term
Compliance Verification
NSR
In Stack Monitoring
SIP Revision (PM and SO2)
-Isolated Point Sources
Compliance Verification
Quality Assurance
Emergency Episodes (SO2)
NSR
Air/Energy Coordination
208 Coordination
Ambient Monitoring/Quality Assurar
34
-------
V., PROGRAMS.
OMP
/if COORDINATION - 201
i/tf COORDINATION - 208
OR/TRANSPORTATION COORDINATION.
kIS/ENERGY
SIS REVIEW
PREVENTION OF SIGNIFICANT DETERIORATION
INDIRECT SOURCE REVIEW (NEVADA ONLY)
/
NEW SOURCE REVIEW
NSPS
NESHAPS
icHOK-CRITERIA POLLUTANTS (lll[d])
EPA VERIFICATION COMPLIANCE
STATE/LOCAL VERIFICATION COMPLIANCE
EPA ENFORCEMENT
EMERGENCY EPISODE
VAPOR RECOVERY
OTHER ORGANICS
INSPECTION/MAINTENANCE
FUEL:. ADDITIVE
IHSTACK MONITORING
SPECIAL AIR MONITORING
SESSIONS INVENTORY DEVELOPMENT
EJEESSIONS INVENTORY DATA PROCESSING
35
-------
A/M QUALITY ASSURANCE
A/M DATA PROCESSING
ISOLATED POINT SOURCES
36
-------
Air Quality Maintenance Planning
DESCRIPTION:
AQMP is designed to foster local institutional development
to address long range air quality standards attainment and
maintenance. Within two years a plan to accomplish this goal
is to be produced and appropriate implementing institution is
to be selected/formed.
GOALS:
Long term attainment and maintenance of NAAQS.
SPECIAL ATTRIBUTES:
Local plan development & public participation.
CURRENT STATUS:
California: varied degree of success;
Nevada: very slow; Arizona: by contract, progressing.
STRATEGY:
California: work through ARB in developing local task forces
to do AQMP.
Others: Develop local air constituency, support through
contracts.
f"
CONSTRAINTS:
Willingness of States and local groups.
TACTICS:
1. Program grant: direct and pass-through.
2. Staff and executive liaison.
3. Contract support - B.O.A.
APPLICABILITY:
All designated AQMAs (9 in California, 2 in Nevada, 2 in
Arizona).
RELATED PROGRAMS:
Refined inventory, basic programs of APCDs, transportation
coordination, Air-Water Coordination (201 and 208) , EIS review,
Air-Energy Coordination.
OTHER RELEVANT FACTORS:
EPA grant conditions on FWPCA §208 grants require consistency
with air planning, in many areas the planning boundaries are
very similar to AQMAs and integration of the two plans is possible.
37
-------
Air/Water Coordination §201
DESCRIPTION:
Provide consistency between wastewater treatment facility
construction grants and the air programs.
GOALS:
EPA construction grants consistent with SIP and AQMP.
SPECIAL ATTRIBUTES:
An internal EPA program in terms of statutory responsibility.
CURRENT STATUS:
Air/Water M.O.U. to provide air comments on significant
201 projects.
STRATEGY:
1. Develop state expertise so that ARE can assume role at
State level.
2. Develop local expertise through AQMP/208 so that decisions
are made locally recognizing the issues involved.
CONSTRAINTS: - .
- 1. Ability or perception ,of State.
2. Availability of local agencies with authority and ability.
TACTICS:
1. Support AQMP/208 integration to develop local expertise.
2. Inter-governmental liaison and education of State to
assume role of mediator.
APPLICABILITY:
Regionwide with major emphasis in AQMAs.
RELATED PROGRAMS:
AQMP/AW Coordination §208
OTHER RELEVANT FACTORS:
'Consistency' should be defined as a "zero net increase in
emissions" to be compatible with NSR policy.
38
-------
Air/Water Coordination §208
DESCRIPTION:
Provide guidance to 208 agencies so that the air quality
assessment is adequate and so that it is consistent with
AQMP and the SIP generally.
GOALS:
Develop local capability to make decisions where air/water
conflicts arise.
SPECIAL ATRRIBUTES:
A new opportunity to improve local awareness of this issue.
CURRENT STATUS:
Varied progress, depending on the status of AQMP and 208.
STRATEGY:
Develop local expertise in air/water interelationships and
analysis.
CONSTRAINTS:
Willingness of local agencies to accept this responsibility,
the willingness of State air and water agencies to assist.
TACTICS:
Intergovernmental and executive liaison. Program grant to
State agency.
APPLICABILITY:
208 areas.
RELATED PROGRAMS:
AQMP, A/W 201, EIS review
OTHER RELEVANT FACTORS:
39
-------
AIR TRANSPORTATION COORDINATION
DESCRIPTION:
Coordination with transportation agencies in order to
insure adequate consideration of the air quality implication
of their projects.
GOALS:
Transportation plans and projects consistent with the SIP.
SPECIAL ATTRIBUTES:
CURRENT STATUS:
Moderate participation in-the Intermodal Planning Group and
compliance with Federal Aid Highway Act 109 3.
STRATEGY:
1. Impact D. 0. T. planning and projects through IPG and
109j consistency reviews.
2. Prepare AQMP groups to raise similar concern at local
level to resolve issues at earliest opportunity.
CONSTRAINTS:
TACTICS:
1. Continue participation in IPG and 109j review.
2. Intergovernmental staff and executive liaison.
3.
APPLICABILITY:
Primary: interest in AQMA's
Secondary: regionwide
RELATED PROGRAMS:
AQMP, EIS review
OTHER RELEVANT FACTORS:
40
-------
Air/Energy
DESCRIPTION:
Evaluate the impact on air quality of the potential increase
in SO2 emissions through fuel switching; and develop addi-
tional control regulations as needed,
GOALS:
Achieve a greater control of S02 emissions in critical AQCR's
with a significant air pollution potential.
SPECIAL ATTRIBUTES:
CURRENT STATUS:
New program - Existing regulations may be inadequate.
STRATEGY:
Encourage and provide assistance for the local adoption of
approvable regulations.
CONSTRAINTS:
More stringent regulations may not be locally acceptable
because of energy needs. Availability of low sulfur oil is
limited.
TACTICS:
Support ARE study to quantify potential increase in S02
emissions and their impact on air quality. Provide technical
assistance for model regulation develop by ARE. Provide grant
support for adoption of model regulation by APCD's.
APPLICABILITY:
Los Angeles, Sacramento, San Joaquin, Bay Area, San Diego
North Central Coast (Long Term).
RELATED PROGRAMS:
New source review, emission inventory development, EPA
compliance verification.
OTHER RELEVANT FACTORS:
Undefined energy policy
Extent of natural gas curtailments
41
-------
EIS REVIEW
DESCRIPTION:
Review and comment on the air quality impact of all.
Federal projects on which NEPA statements are submitted
to EPA.
GOALS:
Insure that the projects direct or indirect impact on
air quality is taken into consideration and any adverse
impacts are minimized.
SPECIAL ATTRIBUTES:
Allows EPA a window into decisions which can have a
considerable"effect on future air quality.
CURRENT STATUS:
EPA comments on all projects. Owing to resource and
policy limitations/ many comments are ineffective.
STRATEGY:
Focus EPA reviews on those projects with the most significar
potential impact, and on those geographic areas with the
worst problems. Adopt review policy for critical non-
attainment areas consistent with new source review? i.ev,
no net increase in emissions.
CONSTRAINTS:
EPA is required to review all projects submitted to the
agency (although specific air quality comments are not
required in each case). Many Federal agencies object to
critical EPA comments.
TACTICS:
In-house review with the time spent on each project made
roughly proportional to its priority.
APPLICABILITY:
Region-wide but particularly important in urban "growth
areas" with significant oxidant problems.
RELATED PROGRAMS:
Air/Energy, Air/Transportation
42
-------
. . \
PREVENTION OF SIGNIFICANT DETERIORATION
DESCRIPTION:
Program designed to protect air quality in areas where
air is cleaner than NAAQS for SO2 and TSP only; growth of
SO2 and TSP emissions can be limited by controlling
construction of 19 specific source types through new
source review and reclassifying areas not now exceeding
NAAQS according to amount of change from current air
quality considered significant for each specific area.
GOALS:
To protect air quality in pristine areas and prevent
degradation of them.
SPECIAL ATTRIBUTES:
EPA has no authority to reclassify areas; only States,
Federal Land Managers, and Indian governing bodies can
reclassify.
CURRENT STATUS:
No delegations have been made. Education to AZ, CA
and NV with regard to EPA regulations and guidelines
completed.
STRATEGY:
To develop equivalent State regulations and guidelines.
To perform new source reviews in house until program
delegated. To encourage FLM's and IGB's to act on
authorities granted.
CONSTRAINTS:
CAA Amendments may "kill" PSD. CA regulations likely
to be similar, but not strictly equivalent to EPA regulations,
TACTICS:
Intergovernmental coordination with large Indian nations.
Inhouse pre-permit conferences. Inhouse review of SIP
revisions.
APPLICABILITY:
All States, especially CA and AZ due to their interest.
Navajo and Hopi nations, Federal lands in pristine areas.
43
-------
BELATED PROGRAMS:
New Source Review
NSPS
OTHER RELEVANT FACTORS:
44
-------
INDIRECT SOURCE REVIEW (NV)
DESCRIPTION:
Review indirect sources such as shopping centers, hotel
complexes, roads, airports, etc., to be sure that these
sources do not create violations of NAAQS.
GOALS:
Prevent build-up of CO hot spots in areas with a high level
of public exposure.
SPECIAL ATTRIBUTES:
Helps to insert air quality considerations in planning
decisions in areas with low environmental awareness.
CURRENT STATUS:
Low level State/local program
STRATEGY:
Unless EPA acts, this program will self-destruct in January,
1977. In the interim, fulfill EPA's moral commitment by
providing support for State/local activity.
CONSTRAINTS:
TACTICS:
Provide grant funding to support those agencies technically
capable of performing the review. (Should total no more
than $10,000.)
APPLICABILITY:
Nevada only, primarily Tahoe Basin, Reno and Las Vegas.
RELATED PROGRAMS:
OTHER RELEVANT FACTORS:
45
-------
NEW SOURCE REVIEW
DESCRIPTION: "
Review and issue permit for the construction of new sources
or the modification of existing sources.
GOALS:
Ensure that new or modified sources do not cause vio-
lations of NAAQS, interfere with the applicable control
strategy for attainment, or violate an allowable increment
of degredation in "clean air" areas.
SPECIAL ATTRIBUTES:
CURRENT STATUS:
EPA has the legal authority to issue permits for routine
review in much of California and for the IB categories of
sources covered by PSD in all states. In other cases it is
a state/local program.
STRATEGY:
Delegate authority to state or local agencies ASAP. In CA?
sure agencies receiving delegation are required to perform
effective reviews. For PSD, seek joint review with states t
local agencies until the program is delegated.
CONSTRAINTS:
Considerable resistance to new ARE model regulations which
require an effective review. The procedures for delegation
of review authority under PSD are very cumbersome. Many
states/locals do not want to bother to seek it.
TACTICS:
Enforce existing grant agreement with ARE and many local
agencies which required delegation in California during FY-'
Assist ARE to develop review guidelines to assist locals in
conducting effective reviews.
APPLICABILITY: .
Regionwide
RELATED PROGRAMSi,
Air/Energy Coordination (S. California), Emission Inventory
Development.
OTHER RELEVANT FACTORS:
46
-------
- NEW S0HRCE PERFORMANCE STANDARDS
DESCRIPTION:
Program which requires installation of BACT on certain
categories of new or modified sources.
GOALS:
Promote application of available control technology.
Minimize emission of various criteria and non-criteria
pollutants.
SPECIAL ATTRIBUTES:
CURRENT STATUS:
The Region is attempting, with limited success, to delegate
program to the States and locals, through the grant
mechanism.
STRATEGY:
Delegate to those agencies who §eek delegation, but phase
down the resources committed to delegation after FY-76.
CONSTRAINTS:
Delegation procedures are cumbersome. Many State/locals
do not want delegation, given the effort required.
TACTICS:
In-house review until delegation.
APPLICABILITY:
Regionwide.
RELATED PROGRAMS:
NESHAPS (delegation procedures)
OTHER RELEVANT FACTORS:
No permit involved.
More categories being added each year.
47
-------
OTHER RELEVANT FACTORS:
ARE and major local agencies in California feel this
program is a long-term necessity.
48
-------
NESHAPS
DESCRIPTION:
Apply RACT to sources of hazardous air pollutants.
GOALS:
Minimize emission of toxic (non-criteria)^pollutants.
SPECIAL ATTRIBUTES:
Can be directly related to public health.
CURRENT STATUS:
Ongoing program implemented by both local/State agencies and
EPA, depending on the status of delegation. Only 4 agencies
have received formal delegation.
STRATEGY:
Delegate review authority to any agencies who seek it.
Continue EPA oversight where program not done by States or
locals.
CONSTRAINTS:
Many agencies do not desire delegation. Efforts to delegate
: under the grant have failed.
TACTICS:
In-house effort.
APPLICABILITY:
RELATED PROGRAMS:
NSPS (delegation procedures)
OTHER RELEVANT FACTORS:
Only 4 source categories covered - Mercury, Beryllium,
Asbestos and Vinyl Chlorides (proposed).
49
-------
Ill (d) Hon-criteria Pollutants"
DESCRIPTION:
Order SIP revision to require certain existing sources of
non-criteria pollutants to apply RACT.
GOALS:
Reduce emissions of specified non-criteria pollutants.
SPECIAL ATTRIBUTES:
CURRENT STATUS:
New program with no current Regional involvement. It will
begin very slowly with one source category covered in FY 77.
STRATEGY:
Devote no resources to this program until HQ acts, probably
in mid FY 77. There after, encourage state action.
CONSTRAINTS:
TACTICS: - - .
Notify states of pending requirement.
APPLICABILITY:
Regionwide
RELATED PROGRAMS:
OTHER RELEVANT FACTORS:
Not related to violations of NAAQS.
50
-------
EPA Compliance Verification
DESCRIPTION: -
Direct EPA inspections of sources: (1) as an overview of
state/local compliance verification; (2) in support of EPA
enforcement actions; (3) in support of local agencies
(particularly for Federal Facilities); (4) as part of an
audit of an agency's permit and inspection program.
GOALS:
To determine the compliance status of the source inspected.
To encourage thorough, accurate inspections by state/local
agencies. To improve the capability of state/local agencies.
SPECIAL ATTRIBUTES:
Provides EPA with first-hand information.
CURRENT STATUS:
Growing program. 5 man-years in-house. Conduct 250 inspections
in-house; 20-40 source test observations. Other inspections
by contract and NEIC (Denver) total 150.
STRATEGY:
Concentrate on major sources which contribute to non-attain-
ment in areas with high populations at risk. Increase use of
program audits to assist state/local agencies to improve their
programs. Handle Federal facilities with the same priority
scheme.
CONSTRAINTS:
HQ pressure to treat all unknowns the same regardless of
their potential contribution to air quality problems. HQ
pressure to inspect large numbers of Federal facilities despite
their importance.
TACTICS:
Largely an in-house program. HQ contract funds and NEIC
also used.
APPLICABILITY:
Primarily urban AQCR's with significant problems.
RELATED PROGRAMSi
State/local Compliance Verification, EPA Enforcement, Other
Organics, NESHAPS
OTHER RELEVANT FACTORS:
-------
State/local Compliance Verification
DESCRIPTION:
Annual verification of the compliance status of point sources
by state or local agencies.
GOALS:
Ensure that sources are in compliance with local rules
there by reducing emissions and improving air quality.
SPECIAL ATTRIBUTES:
CURRENT STATUS:
Two year old rapidly expanding program with established re-
porting mechanism in all states. To date, the program has
concentrated on accounting for all sources greater than 100
tons (potential emissions).
STRATEGY:
Encourage State/local verification. Concentrate on major poir.
sources which emit pollutants which contribute to the non-
attainment of NAAQS. With one exception, do not require repor
ing on minor sources.
CONSTRAINTS:
State/local resentment of reporting requirement. HQ push to
. expand program to include minor sources. Competing resources
at the local level, particularly for vapor recovery.
TACTICS:
Use grant to require reports on all major point sources. Use
grant to insure adequate verification of sources of critical
pollutants in selected non-attainment areas. Use reports and
in-the-field EPA overview to insure annual verification of all
pollutants.
APPLICABILITY:
Regionwide for major sources, minor sources only in the LA
metro AQCR (and only for HC).
RELATED PROGRAMS:
EPA Compliance Verification, EPA Enforcement
OTHER RELEVANT FACTORS:
52
-------
EPA ENFORCEMENT
DESCRIPTION: .
Direct EPA enforcement action against non-complying sources,
GOALS:
Provide incentive for local/state agencies to run fair but
firm enforcement programs.
Bring individual sources into compliance.
SPECIAL ATTRIBUTES:
CURRENT STATUS:
Program operates with a quota of EPA enforcement actions.
STRATEGY:
Use this program to apply pressure to Hearing Boards and
agencies with poor enforcement records. Assist those agencies
operating under political constraints by taking action.
Yield to effective local action whenever possible. Go after
problem pollutants.
CONSTRAINTS:
\
Direct Federal action is nearly always resented by local
elected officials.
TACTICS:
Basically an in-house program that involves extensive
coordination with states/locals.Local enforcement action is
mandated by the Basic Program portion of the grant requirements
APPLICABILITY:
Region wide-priority given to areas- under the jurisdiction
of bad enforcement agencies and sources of problem pollutants.
RELATED PROGRAMS:
EPA Compliance Verification. Isolated Point Sources
OTHER RELEVANT FACTORS:
53
-------
EMERGENCY EPISODES
DESCRIPTION:
Take coordinated areawide control measures to predict and
to reduce pollutant concentrations which pose an immediate
danger to the public health.
GOALS:
Protect public health.
SPECIAL ATTRIBUTES:
Implementation results in direct reduction of emissions.
CURRENT STATUS:
California plan for Ox in Los Angeles faces litigation.
Other areas have programs in place. EPA role diminishing.
STRATEGY:
Minimize EPA involvement. Episode programs are intended
to be operated by local and/or.State agencies.
CONSTRAINTS:
Litigation on L. A. EPA could be ordered to promulgate
: a plan of its own.
TACTICS:
Approve ARE plan for L. A. and take our chances in court.
APPLICABILITY:
Primarily L. A. (Ox), Phoenix and Las Vegas (CO) and
Guam (S02).
RELATED PROGRAMS:
OTHER RELEVANT FACTORS:
Improvements in air quality has probably eliminated Stage 3
episodes. There will apparently be few, if any, Stage 2
episodes in Los Angeles.
54
-------
Vapor Recovery
DESCRIPTION:
Bring about the installation of control equipment on tanks
and vehicles involved in the transfer and marketing of gaso-
line. (Transfer to retailers is Phase I, Transfer to private
vehicles Phase II) .
GOALS: * '.
Achieve expeditious control of gasoline vapors in areas
with significant Ox problems.
Over 5 year period, increase the % of emissions controlled.
SPECIAL ATTRIBUTES:
Directly reduces a significantly large category of emissions
of a problem pollutant. Comparatively cost effective.
CURRENT STATUS:
*
Phase I completed or nearing completion in California.
Phase II being implemented with technical and legal problems.
EPA regulations still legally in force despite existence of
local regulations.
STRATEGY:
Support continued local agency implementation of local
regulations including those requiring vapor balance systems.
- Accept less than 90% control in the short run to achieve some
control ASAP. Re-evaluate local rules in 2-3 years. Encourage
adoption and implementation of Phase I in Las Vegas.
CONSTRAINTS:
Legal challenges (resistance) by oil companies. Slow certifi-
cation of safety of control equipment. Outstanding technical
issues related to the effectiveness of control systems.
TACTICS:
Encourage implementation of local regulations through grant
support. Displace EPA regulations by approving local regula-
tions ASAP. Do not enforce EPA regs in the interim. Use
executive liaison to encourage ARB to adopt controls for small
valley floor APCD's which have not acted. Use grant to require
implementation in Las Vegas.
APPLICABILITY:
Los Angeles, Bay Area, Sacramento Valley, San Joaquin Valley,
San Diego, Las Vegas.
55
-------
RELATED PROGRAMS:
Other organics - Control of other types of fuels may use
similar technology.
OTHER RELEVANT 'FACTORS:
56
-------
Other Organics
DESCRIPTION:
Evaluate the effectiveness of the HC control regulations
in selected AQCR's, quantify the extent of unregulated
emissions and revise and/or develop additional regulations
as needed.
GOALS:
Achieve a greater control of non-methane HC emissions in
AQCR's with significant Ox attainment problem.
SPECIAL ATTRIBUTES:
CURRENT STATUS:
New Program - Existing regulations are inadequate.
STRATEGY: '
Encourage and provide assistance for the local adoption
of approvable regulations.
CONSTRAINTS:
. Incomplete inventories of HC sources. Reactivity definition
unresolved with Southern California APCD. Some APCD's may
resist additional controls.
TACTICS:
Support ARE study to evaluate existing regulations, quantify
emissions. Provide technical assistance for model regulation
development by ARE. Provide grant support for adoption of
model regulation by APCD's.
APPLICABILITY:
Los Angeles, Sacramento, San Joaquin, Bay Area, San Diego
*
RELATED PROGRAMS:
New Source Review, emission inventory development, EPA
compliance verification.
OTHER RELEVANT FACTORS:
57
-------
Inspection/Maintenance
DESCRIPTION:
Annual, mandatory inspection of all light duty vehicles to
determine compliance with emissions limitations.
GOALS:
Insure the maximum effectiveness of vehicle control devices,
thus reducing emissions of CO, HC and NOX
SPECIAL ATRRIBUTES:
v
The program can support itself by charging no .ial inspection
fees.
CURRENT STATUS:
Pilot program in California (LA area); limited to change of
registration in NV (Las Vegas); and in danger of being scrapped
in AZ (Phoenix-Tucson).
STRATEGY:
Encourage adoption of regulations and proliferation of pro-
grams to areas with automobile-related problems. (This is a
5-year strategy.)
CONSTRAINTS:
Effectiveness of program unquantified. EPA lacks legal
authority to require implementation. Public and political
opposition.
TACTICS:
Encourage adoption etc^through executive liaison, and public
relations.
APPLICABILITY:
Over 5 years - Phoenix-Tucson, L.A.,. Bay Area, San Diego
Las Vegas and Reno.
RELATED PROGRAMS:
Federal Motor Vehicle Control Program (HQ activity).
OTHER RELEVANT FACTORS:
58
-------
FUEL ADDITIVES
DESCRIPTIONr
Inspection of gasoline retailers to check for the availability
of non-leaded gasoline. Analyze gasoline Camples for lead
content.
GOALS:
Protect catalytic control devices on late model automobiles,
Poisoned catalysts result in increased emission of NOx, CO
and HC.
SPECIAL ATTRIBUTES:
Program also protects the consumer.
CURRENT STATUS:
EPA and contracted inspections. State handles program under
contract in California. Number of inspections phasing down.
STRATEGY:
Continue phasing down the number of inspections and concentrate
on major urban areas with significant oxidant or CO problems.
If a very low violation rate occurs, phase out program.
CONSTRAINTS: " " - '
TACTICS:
Use HQ contract funds.
APPLICABILITY:
Urban areas with significant oxidant or CO problems.
RELATED PROGRAMS:
Federal Motor Vehicle Control Program (HQ)
OTHER RELEVANT FACTORS:
59
-------
IN STACK MONITORING
DESCRIPTION:
Install continuous monitors in the stacks of certain types
of sources.
GOALS:
Imnrove quality of emission data and provide continuous
enforcement oversight.
SPECIAL ATTRIBUTES:
Major step forward in source monitoring.
CURRENT STATUS:
EPA regulations proposed on 4 source categories. Similar
legislation enacted in California and proposed in Nevada.
STRATEGY:
Yield to State requirements whenever possible, particularly
in California. Press implementation areas with known or
pending problems first.
CONSTRAINTS:
Applies to small number of sources. Covers only SOx, NOx,
and PM.
TACTICS:
Executive liaison and intergovernmental coordination to get
State programs enacted and implemented.
APPLICABILITY:
Primarily California, but also relevant in other States
in the Region.
RELATED PROGRAMS:
Air/Energy Coordination, EPA Enforcement.
OTHER RELEVANT FACTORS:
60
-------
Special Air Monitoring
DESCRIPTION: -
Special monitoring done to improve knowledge of an apparent
air quality problem or analysis of trends in air quality data.
GOALS:
Provide information needed to decide whether or not to develop
and implement control strategies.
SPECIAL ATTRIBUTES:
CURRENT STATUS:
Commitment to SO2 monitoring in Hawaii.
STRATEGY:
Very low level effort which should be coordinated with
appropriate state or local agency..
CONSTRAINTS:
TACTICS: . ' *
Coordination with States and locals - some in-house work
with selective contract support.
APPLICABILITY:
Hawaii (S02)t California - Obtain S02 data in North Central
Coast; Analyze trends in South East Desert.
RELATED PROGRAMS:
OTHER RELEVANT FACTORS:
This program responds to known data problems and cannot be
effectively projected over a 5-year period.
61
-------
Emission Inventory Development
DESCRIPTION:
Develop an accurate, relevant emission data base.
GOALS:
Define the cause of air quality problems so control strategi-
can be developed and analyzed.
SPECIAL ATTRIBUTES:
Good data is critical to an effective control strategy.
CURRENT STATUS:
Data base poor in many areas of the Region. Problems range
from no inventory at all to lack of sufficient sophisticate
STRATEGY: (5 year)
In major urban areas, and in cooperation with State and
local agencies, review and refine the data for problem
pollutants as necessary to pinpoint targets for additional
control. In selected non-urban areas, develop an inventory
in sufficient detail to determine the cause of NAAQS vio-
lations .
CONSTRAINTS: '
Emission data development is time consuming and resource
intensive. Contractual efforts can easily be ineffective.
TACTICS:
Whenever possible, carry out joint Federal/State/local
effort to insure that all parties buy into the results.
Support with grant and (selectively) with contract funds.
In some instances, perform in-house "quickie" evaluations
to bring deficiencies into focus.
APPLICABILITY:
Regionwide with emphasis on AZ-NM So. Border (PM),
Phoenix/Tucson (HC, PM) Los Angeles (HC), North Central
Coast (HC) , San Diego (PMj, San Francisco Bay (HC) and
South Central Coast (HC).
RELATED PROGRAMS:
Emission Inventory (Data Handling), AQMP, New Source
Review, Air/Transportation, Air Energy, EIS, Other Organics-
OTHER RELEVANT FACTORS:
62
-------
EMISSION INVENTORY (DATA HANDLING)
DESCRIPTION:
Development of a computerized system of handling large
volumes of emission data where needed.
GOALS:
Make data accessible to those who need it, especially for
modeling purposes. Standardize formats so trends, and
control measures can be analyzed by ARE and EPA.
SPECIAL ATTRIBUTES:
Long term, resource intensive effort. Necessary for
sophisticated modeling techniques.
CURRENT STATUS:
Essentially, a new program. Most emission data are not
accessible for modeling. Data which are available are
incomplete and/or inaccurate. ARB is beginning statewide
data management system in FY-76.
STRATEGY:
5-year. Install software (EPA's EIS/P&R) where needed and
convert existing emission data to the required format. Begin
periodic updates in CA and continue them in other States via
NEDS.
CONSTRAINTS:
Overall cost of program could approach $1 million in CA
and consume considerable manpower. Effective use of
contractors, aside from software installation, is limited.
TACTICS:
Joint effort with ARB providing overall administrative
direction and technical assistance, the local agency providing
manpower, and EPA providing oversight, technical assistance
and contract and grant support on a matching basis.
APPLICABILITY:
California, although Arizona is also installing the software
system in FY-76.
RELATED PROGRAMS:
Emission Inventory Development, AQMP, New - Source Review and
other programs employing math modeling.
63
-------
OTHER RELEVANT FACTORS:
There is a minority staff view that EIS review is still
cost/effective without the "no net increase" policy.
64
-------
Air Monitoring Quality Assurance
DESCRIPTION:
On site inspections of air monitoring stations and
laboratories. Standarization of equipment operation
and calibration procedures, and inter-laboratory.sample
exchanges.
GOALS:
The production of consistently accurate air quality data.
SPECIAL ATTRIBUTES:
A sense of the accuracy of data is a pre-requisite to any
control strategy.
CURRENT STATUS:
EPA involvement very low level except for selected site
visits and inter-laboratory cross checks. Some states
are developing quality assurance programs for extension
to locally operated networks.
STRATEGY:
Continue selected EPA site visits and network evaluations.
Phase down EPA involvement as standarized operation and
- calibration procedures are implemented by state and local
agencies.
CONSTRAINTS:
Wide variation in type of equipment operating in Region. EPA-HQ
policy still unclear in some areas.
TACTICS:
In-house site visits in selected areas. Continued grant
support for local agency implementation of statewide
procedures.
APPLICABILITY:
Regionwide but need site visits to Phoenix/Tucson, AZ/NM
South Border, Clark/Mohave (AZ), L.A., N. Central Coast,
San Diego, So. Central Coast and Sacramento, In Nevada,
Las Vegas and Reno.
RELATED PROGRAMS:
Nearly all programs.
OTHER RELEVANT FACTORS:
65
-------
Air Monitoring - Data Processing
DESCRIPTION:
Provide computerized handling of air quality data where
needed at the state level and input to the NADB. (SAROAD)
GOALS:
Make air quality data available to those who use it.
SPECIAL ATTRIBUTES:
CURRENT STATUS: .;-f
Software systems (AQDHS-II) being installed in Arizona,
Nevada, California.
STRATEGY:
Complete installations - Phase down EPA involvement.
CONSTRAINTS:
TACTICS:
Contract funding.
APPLICABILITY:
RELATED PROGRAMS:
OTHER RELEVANT FACTORS:
66
-------
Isolated Point Sources
DESCRIPTION:
Combination of regulatory development and enforcement action
directed toward bringing isolated major sources under control.
GOALS:
Reduce emissions from these sources in order to attain NAAQS.
SPECIAL ATTRIBUTES:
CURRENT STATUS:
Involved in disputes over regulations for SO2 and PM control
for smelters. S02 for power plants.
STRATEGY:
Pick our fights more carefully. We should be careful to have
reliable air quality and emission data available before impos-
ing or proposing to impose additional controls on these sources.
Phase down EPA involvement in favor of state/locals.
CONSTRAINTS:
Political power of the sources. Program has a long history
and national visibility. We lack good data, particularly for PM.
TACTICS:
Involve the cognizant state and local agencies in all steps
we take. Use contractors carefully. Place low priority on
sources in areas with no NAAQS violations.
APPLICABILITY:
Primarily Arizona but also have problems in Guam, Hawaii
and Nevada.
RELATED PROGRAMS:
EPA Enforcement. Air Monitoring. Emission Inventory Develop-
ment. EPA Compliance Verification.
OTHER RELEVANT FACTORS:
National policy on tall stacks/SCS.
67
-------
f ^
AQCR's were ranked by the following procedure:
i. Programs and AQCR's were arranged in a matrix.
2. Programs were evaluated for their role in each AQCR based upon
the following criteria:
A. Directly reduce emissions of problem pollutant and improve
air quality. 3 points.
B. Critical to definition of known or suspected air quality
problem. 2 points.
C. Direct beneficial effect as minor air quality problem or
necessary to maintain standards. 1 point.
3. Summation of points for programs serving the defined roles
within the AQCR provides an index of the number and importance
of EPA programs within the AQCR. Some programs were found to
be either non-critical in the AQCR or of only administrative
importance and hence did not appear in the matrix.
A. Some subjective judgement was necessary to place planning
programs within the definition of roles.
5. The highest point total xrould represent the highest priority
AQCR using this analysis.
68
-------
RANKING OF AQCR'S
priority Ranking
LA Metro
SF Bay Area
San Diego
NV Clark-Mohave
San Joaquin Valley
Phoenix-Tucson
Sacramento Valley
N. Central Coast
S. Central Coast
N. W. Nevada (Reno)
Guam
AZ Southern Border
AZ Clark-Mohave
AZ Four jGorners
NV Intrastate
CA S. E. Desert
North Coast
Hawaii
Great Basin Valley
CA N. E. Plateau
Population Ranking
LA Metro
SF Bay Area
San Joaquin Valley
San Diego
Pho enix-Tu c s on
Sacramento Valley
Hawaii
S. E. Desert
North Central Coast
NV Clark-Mohave
North Coast
S. Central Coast
Four Corners
N. W. Nevada (Reno)
Lake Tahoe
AZ Southern Border
AZ Clark-Mohave
Guam
N. E. Plateau
Nevada Intrastate
Great Basin Valley
69
-------
GLOSSARY
Gross
Moderate
Slight
Ox = 3-6x 1 hr. Standard
CO = 3-6x 8 hr. Standard
PM = 3-6x AGM
S02 = 3-6x 24 hr. Standard
Ox = 2-3x 1 hr. Standard
CO = 2-3x 8 hr. Standard
PM = 2-3x AGM
S02 = 3-6x 24 hr. Standard
Ox = l-2x 1 hr. Standard
CO = l-2x 8 hr. Standard
PM = l-2x AGM
S02 = 3-6x 24 hr. Standard
N00 = l-2x AA
70
-------
VIII. NARRATIVES
71
-------
The Basic Program
Several years ago, in response to a major national
redirection of EPA's "105" air program grant policy, Region
IX developed the "Basic Program" concept. In essence, the
Basic Program describes what EP7\ feels should be an agency's
routine operation; a minimum standard for agency capability
to conduct an air pollution control program in any AQCR with
significant air quality problems.
The Basic Program concept also underlies the Regional
Air Strategy. Many important program areas are not mentioned
specifically in the narrative portions of the Strategy.
Routine air monitoring, for example, is not highlighted in
any AQCR, although it obviously forms a cornerstone for
other programs. Effective enforcement action against violating
sources is a second important example.
The Regional Air Strategv, then, assumes that the Basic
Program will be carried out in each AQCR. To that extent it is
part of the Strategy. In addition, in some AQCR's, Basic
Program activities such as "State/Local Compliance Verification"
are specifically mentioned because they are of special signifies
Under no circumstances should any reader of the Strategv assume,
that because a Basic Program activitv such as air monitoring
or major source comnliance verification does not appear, that
EPA is not concerned about its accomplishment.
The elements of the Basic Program follow:
(1) Review, and, where needed, revision of the grantees'
rules and regulations to assure consistencv with
the applicable state implementation plan (SIP).
This may include revision of control strategies
where indicated by air auality projections. Revisions
will be submitted to EPA through the State in
accordance with 40 CFR 51.4, 51.5, and 51.6.
(2) Operation of an effective enforcement program, taking
action as necessary to bring violating sources into
compliance with applicable rules and regulations.
This includes the development, submittal and (when
appropriate) the revision and re-submittal, of
compliance schedules (variances) to EPA for sources
which are unable to come into prompt compliance.
Sources on compliance schedules are to be monitored
and their status reported to EPA via the Compliance
Data System (CDS).
BP-1
-------
(3) Operation of an effective source surveillance program
which, as a minimum,, involves annual verification of
compliance of all major sources (>100 tons per year
potential emissions) with all applicable regulations
by an acceptable verification technique. (See attached
table for more information on the acceptability of
various techniques.) If the grantee has been delegated
authority, in whole or in part, to operate a program
to implement Section 112 of the Clean Air Act (NESHAPS),
the grantee shall maintain surveillance over sources
of hazardous pollutants in accordance with the terms
of the delegation. Finallv, in California, grantees
are expected to recmire in-stack monitoring of certain
sources consistent with ARB's Resolution 75-59, adopted
on October 27, 1975.
(4) Operation of an air monitoring network consistent with
appropriate procedures and practices within the
agency's jurisdiction. Reporting ambient air quality
data in accordance with 40 CFR 51.7 and, where installed,
operation of AQDHS-II software.
(5) Development and maintenance of a current emission
inventory which, as a minimum, includes.all major
point sources ( 100 T/y). Report emissions to EPA
in accordance with 40 CFR 51.7 [and where installed,
operation of EIS/P&R software]. (Note: California
agencies are temporarily exempted from the emissions
data reporting format specified in 40 CFR 51.7 by
Region IX administrative policy.)
(6) Implementation of an emergency episode program, including
air cruality forecasting capability and effective public
information capability in accordance with 40 CFR 51.16.
(7) Provision for the training and development of agency
personnel in accordance with the requirements of the
grantee's program.
(8) Operation of an active public information program on
air pollution control in the grantee's geographic area
of responsibility.
(9) Operation of a program for the receipt and investigation
of citizen complaints.
(10) Operation of a permit program for the review of new and
modified sources in accordance with the recmirements of
the applicable SIP. If the-grantee has been delegated
authoritv, in whole, or in part, to operate a program
to implement Section 111 of the Clean Air Act (NSPS),
the grantee shall apply performance standards in
accordance with the terms of the delegation.
BP-2
-------
(11) Compliance v/ith the requirements of EPA and other
Federal grant regulations as to:
a. Application, expenditure and accounting of
Federal funds,
b. Submission of periodic progress reports as
provided by 40 CFR 35.530 (c).
(12) Review and comment on Federal or State Environmental
Impact Statements (Environmental Impact Reports
in California) from the standpoint of air quality.
BP-3
-------
- tP/A UK i>!AIL L-.Ni-UKCJl-.FitN I -
W
VALIDITY OF
T-rtKTfl'Ir.S
ACCEPTABLE
Note: At least
one increment of
progress in every
schedule should
be verified by a
preferred
technique
i
(
*
NOT ACCEPTABLE
INCREMENTS OF PROGRESS IN SCHEDULES
Development of final
control plan
o Copy of plan
(preferred) . .
c Letter from
responsible
corporate officer
. certifying achieve-
Vicnt
' _
Date of binding coi:;ni tmcnt
to purchase control topt.
.
o Copy of contract
(preferred)
9 Letter from responsible
corporate officer
certifying achievement
Initi'ife On site
construction
n Inspection
(preferrred)
9 Letter from
responsible cor-
porate officer
certifying
achievement
Complete on site
construction
s Inspection
(preferred)
e Letter from res-
ponsible cor-
porate officer
certifying
achievement
v »'
'
Telephone calls or other such unsubstantiated evidence
'
.
FINAL
COMPLIANCE
(in order cf accuracy)
5 Emission tost conducted and
results evaluated by EPA
(or State)
o Emission test observed and
results evaluated by EPA
(or State).
9 Opacity observation, where
applicable, by certified
observer.
9 'Inspection by qualified EPA
(or State) personnel to obtain
adequate operating data to
calculate compliance or compare
to operation during previous
emission test.
o Emission factors for SO?
emissions at fuel burning in-
stallations with ro pel liijrjcn
controls (d^ta subni ttt1" -J..1
response to 3114 or equivalent
State statute requirement)
c EPA (or State) contractors report
of inspection or emission test
when evaluated by EPA or State.
* Emission factors for SOj from
combustion sources with controls
and all other pollutants based
on data from §1 14 letter
responses when calculated cmissio
are much less (generally a factor
of tcnjthan allowed.
8 Unobserved emission test report
submitted by source which is
, evaluated and believed to be
. accurate.
o Emission test not observed I
report unsvcluated
o Opacity observations not sub-
stantiated by inspection of
plant operations
e Unevaluated contractor's report
o Unsubstantiated emission factor
analysis
o Emission Inventory data
-------
REGIONAL AIR STRATEGY
REGION IX
ENVIRONMENTAL PROTECTION AGENCY
Geographic Narrative on the
Air Quality Control Region(s)
for the State of
Arizona
March, 1976
-------
REGIONAL AIR STRATEGY
REGION IX
ENVIRONMENTAL PROTECTION AGENCY
Geographic Narrative on the
Air Quality Control Region (s)
for the State of
Arizona
March, 1976
-------
TABLE OF CONTENTS
FOR ARIZONA
Section
I. General Introduction
II. Basic Program
III. Narrative for Arizona AQCR's
AQCR #12 - Southern Borders
AQCR #13 - Clark-Mohave
AQCR £14 - Four Corners
AQCR #15 - Phoenix-Tucson
-------
A - 1
AQCR £12 - ARIZONA SOUTHERN BORDERS
INTRODUCTION
This interstate AQCR includes the three southeastern
Arizona counties of Graham, Greenlee and Cochise, as well as
three counties in New Mexico. The Arizona portion of this
region covers 12,753 square miles (11.2% of the state total)
and has a population of 88,826 (5% of the state total). Large
areas are unpopulated or only sparsely settled; approximately
half of the population is concentrated in small towns of 2,000 -
13,000 people. Major industries are agriculture, copper mining
and smelting and tourism. There are 38 identified point sources
of air pollution.
PROBLEM
Sulfur dioxide; Both the annual and the 24-hour standard are
exceeded in Morenci and Douglas. In Morenci, concentrations
are equivalent to 3 times the annual standard and 3 times the
24-hour standard. In Douglas, concentrations are equivalent
to 1-1/2 times the annual standard and 6 times the 24-hour
standard. The Phelps-Dodge copper smelters are "the source of
these S02 violations.
PARTICULATE: Particulate standards are violated in both Morenci
and Douglas. Particulate levels equal to 1-1/4 times the annual
occur in Douglas and are widespread (three stations). The
annual standard for particulate was violated in Morenci at only
one station by about 1-3/4 times the standard. Violations of
the 24-hour standard are more widespread in both areas; con-
centrations are about 1-1/2 times the standards. The Phelps-
Dodge copper smelters are suspected to contribute to these
violations. Also, the smelters' tailings (Morenci) and other
sources (unpaved roads, etc.) contribute to fugitive emissions.
GOALS
18 months:
Determine respective contributions from stationary,
fugitive and other particulate sources; relate emissions
to ambient levels.
Achieve compliance for stationary sources.
Attain particulate and sulfur dioxide standards.
-------
A - 2
5 years:
Develop and enforce a program to maintain National
Ambient Air Quality Standards for particulate and S02-
Develop and enforce a program to prevent significant
deterioration.
PROGRAMS
ISOLATED POINT SOURCES
Participates: The State will develop process weight regula-
tions for the smelters and submit them as SIP revisions. Based
upon the results of the particulate emissions inventory, new
regulations for fugitive sources will be developed and sub-
mitted to EPA.
S02: The State is developing S02 regulations which they
plan to adopt prior to EPA finalizing its proposed regula-
tions. Both State and local proposed regulations should be
jointly coordinated to avoid duplication and to insure
approvability of the final State regulation. EPA must be
prepared to finalize and enforce its proposed regulations if
necessary.
Emission Inventory Development (particulate)
By contract effort, EPA will develop a particulate emission
inventory to define particulate sources, determine the
stationary source contribution (including fugitive emissions),
and define other particulate sources. The contract would
then relate particulate emissions to ambient TSP concentra-
tions and hence to the standards.
Compliance Verification (sulfur dioxide, particulate)
State will do an annual compliance verification of major
stationary sources of S02 and particulate emissions. As part
of their basic program, the results will be submitted to EPA
in CDS format.
EPA Compliance Verification (sulfur dioxide)
EPA will inspect only the smelters for compliance as a
separate program to verify State inspections. The State will
be invited to participate.
Emission Inventory Data Processing (particulate, sulfur dioxide)
-------
A - 3
The State will update and maintain the emissions inventory
in NEDS format and submit it semi-annually to EPA. The
process will-include accounting for the missing data items
and resolving rejects. This program is critical because
controls are being planned and implemented .at the smelters,
especially at Morenci.
Quality Assurance (particulate, sulfur dioxide)
This is a State program to fully implement approved Quality
Assurance procedures and practices to assure validity of
ambient data (TSP and 602). The State will participate in
the EPA (Headquarters) interlab testing program. EPA (R.O.)
will maintain a minimal overview program to insure compliance
with QA guidelines and approved State program.
STRATEGY
The strategy in this AQCR is to address the S02 problem
first, and establish final regulations, preferably state
regulations. The smelter at Morenci is lower priority;
Because of its old age, the Douglas smelter presents a more
serious problem. EPA will contract for an economic analysis
of the impact of the SO2 control regulations as the regulations
are finalized.
When the issues surrounding the process weight table
regulation are resolved, an assessment must, be made of the
percent control required, and the smelters' ability to meet
the requirement.
The particulate problem needs to be better defined. Since
the SIP control strategy was based on an example AQCR (Phoenix-
Tucson) , it is necessary to define the particulate sources and
their contribution to the ambient concentrations in this AQCR,
expecially Douglas. This will be done by contract prior to -
revising the SIP.
-------
A
#13 - ARIZONA CLARK-MOHAVE
INTRODUCTION
This interstate region is formed by the counties of Mohave and
Yuma in Arizona and Clark County in Nevada. The two Arizona counties
Are 23,200 square miles in area (20.5% of the state) and hav^ a population
of 86,684 (4.9% of the state). Most of the area is sparsely settled; most
of the population is concentrated in several small towns, of which Yuma is
the largest (29,007). Major industries are tourism, especially along the
Colorado River, agriculture, mining and commercial trade. Both counties
exhibit an exceptionally high growth rate. There are 40 point sources of
air pollution.
PROBLEM
Oxidant: Recent data indicates that concentrations in Yuma are twice
the national standard. The source of such high levels is unknown, although
resident motor vehicles, solvents, federal facilities and long-range transpoi
are possibilities.
Particulate: In Yuma, total suspended particulate levels are about 1-1/2 tir
the annual standard, and in Bullhead City, about 2 times the standard. Fugit
emissions and stationary sources such as cotton gins are probable sources for
high particulate levels.
GOALS
18 month:
Determine the source and magnitude of the oxidant problem in Yuma.
/
5 year:
Determine the source and magnitude of the particulate problem.
Develop and enforce a program to attain and maintain the oxidant
and particulate standards.
PROGRAMS
Quality Assurance (oxidant): EPA will conduct a site inspection of the
Yuma monitoring station to assess Quality Assurance procedures and
practices for monitoring operations. The inspection will be directed toward
evaluating sources in the vicinity, calibration, frequency and
procedures, operator training and practices. Also, EPA will review
1975 data to evaluate the extent of the oxidant problem. State
participation will be invited.
-------
A - 5
Compliance Verification (particulate): This program is a State and
local program to annually verify stationary source compliance with
particulate regulations. CDS reporting for these sources will be
j-equired under the state's basic program.
EPA Compliance Verification (oxidant, particulate): EPA will do a 10%
overview of major stationary sources for compliance. State and local
participation will be invited. Additionally, Federal facilities with
known or suspected hydrocarbon or particulate emissions will be inspected
in order to halp define the problem and identify emission sources.
STRATEGY
The strategy in this AQCR is directed toward the oxidant problem
in the short-term while maintaining the State and local role with respect
to stationary sources. Our intent is to verify the existence and magnitude
of the oxidant problem based upon an additional year of data (1976).
If verified, a comprehensive hydrocarbon emission inventory would
be developed. Also in the long-term, a particulate emission inventory
would be conducted. The inventories would include the impact of
federal facilities and fugitive emissions.
Both inventories would be geared toward possible SIP revisions for
hydrocarbons and particulates. Vapor recovery and transportation
coordination/consistency would be included if indicated.
-------
A - 6
AQCR #14 - ARIZONA FOUR CORNERS
INTRODUCTION
This interstate AQCR includes the Arizona counties of
Apache, Navajo, Coconino and Yavapai, and 13 counties or areas
in Utah, Colorado and New Mexico. The Arizona portion of
this region has an area of 47,712 square miles (42*1% of the stat
and a population of 165,026 (9.3% of the state). The bulk of
the population is concentrated in about a dozen small towns
(Flagstaff, 26,117 and Prescott, 13,134 are the largest). Much
of the area is Indian reservation and about half of Arizona's
Indian population lives in these counties. Major industries
are tourism (Grand Canyon), lumber, mining and cattle ranching.
There are 36 identified point sources.
PROBLEM
Particulates; Widespread monitoring (14 stations) indicates
violations of the annual standard at only one station, Eager
(1-1/4 times the standard). Regarding the 24-hour particulate
standard, the Page station records violations at about twice
the -standard. Open burning on the Apache land northeast of
Phoenix has contributed to a recent CO episode in Phoenix
and reduced visibility. Such occurrences emphasize the
question of jurisdiction over Indian lands; this question is
critical because of the predominance of Indian land in this
AQCR.
GOALS
18 month:
Delegate responsibility to the State for New Source
Review and Significant Deterioration.
Identify sensitive and pristine areas and reclassify
to Class I (initiated by State and by Federal land
managers).
5 year:
'Develop a program to maintain national particulate
standards.
Implementation of program to prevent significant
deterioration.
-------
A - 7
PROGRAMS
Compliance Verification (particulate, sulfur dioxide):
This is strictly a State program to inspect annually and report compliance
quarterly to EPA on CDS format. It is the State's responsibility to
resolve any non-compliance.
Isolated Point Source (sulfur dioxide): For the Navajo power plant at
Page, EPA will evaluate the results of the contract effort and assist the
state in resolving the percent control required.
NSR/NSPS (sulfur dioxide, particulate): For power plants, NSR/NSPS is
primarily a state program with minor EPA overview if necessary.
P/Significant Deterioration (sulfur dioxide, particulate): A low level
effort should be made to inform Indians, Federal land managers, and the
State of this program and the need to reclassify to prevent future air quality
problems. Resources permitting, EPA should push Federal Land I^nagers to
reclassify now.
INDIAN LAND JURISDICTION
The question of jurisdiction over Indian Lands has been a continuing
problen and predominates in this AQCR. Arizona Attorney Generals in the past
have been unable to develop a single, coherent interpretation.-
The jurisdiction questions should be resolved. Because of the State's
informal interest in reclassifying areas under PSD. They should be
supported by EPA in formal reclassification procedures utilizing Indian
lands as a test case. If the State is unable to unwilling, EPA should
select a test case and cooperate with the State in forcing the jurisdiction
issue.
STRATEGY
The strategy in the Four Corners AQCR is one of prevention of air pollution
and hence the preservation of existing air quality. For the most part, this
is a long-term program. A minimal short-term EPA program will be directed
toward resolving the issue of what percent control is required on the Navajo
Power Plant to meet standards, resolving the question of jurisdiction over
Indian Lands, and informing the public about prevention of significant
deterioration. State activity will be directed toward compliance verification
of major point sources of particulate matter and review of new sources and new
source performant standards. If requested, EPA will provide assistance and .
guidance in NSR.
-------
A - 8
Long-term efforts would essentially be the same programs
as listed above v/ith the addition of quality assurance.
-------
A -
AQCR #15 .^'-ARIZONA PEOENIX-TUCSON
INTRODUCTION
This intrastate region is composed of the five counties
of Maricopa, Pima, Gila, Final, and Santa Cruz. The region
encompasses 29,753 square miles (26.2% of the state), and
has a population of 1,431,954 (80.8% of the state). Most
of the population resides in the Phoenix and Tucson metro-
politan areas; these urban areas are growing at a very
rapid ratev Major industries are manufacturing, wholesale
and retail trade, tourism, agriculture, and copper mining
and smelting. Of the 395 identified point sources in the
state, 312 are located in this AQCR (Maricopa County, 181;
Pima, 41; Other, 90).
PROBLEM
Carbon monoxide; In Phoenix, there are chronic violations
of the 8-hour standard (approximately twice the standard).
While Tucson is now barely meeting the CO 8-hour standard,
violations are expected, and maintenance planning is necessary.
The source of the CO problem is the automobile and unusually
high VMT.
Oxictant; There are violations of the oxidant standard in
both Phoenix (twice the standard) and Tucson (1-1/2 times
the standard). The primary source is the automobile, although
there is also a small amount of hydrocarbon emissions from
point and area sources.
Sulfur dioxide; Violations occur in the non-urban areas due
to copper smelters in Ajo, Miami, Hayden and San Manuel. Levels
equal to 4 times the annual standard and 24-hour standard have
been recorded.
Particulates; Violations of the standards are pervasive throughout
the AQCR. These violations are due to fugitive emissions,
fugitive dust (natural) and stationary sources (in that order).
In Phoenix, about 50% of the fugitive emissions are related
to agricultural activity; in Tucson, they are caused mainly
by construction and unpaved roads.
GOALS
18 month:
Attainment of SO- standards through implementation of
smelter regulations.
Implementation of the mandatory state I/M program.
-------
A - 10
Definition of HC and TSP problems through completion
of HC emission inventory (Phoenix) and an urban particulate
study (Phoenix).
5 year:
Maintain SC>2 standards in vicinity of smelters.
Attainment and maintenance of TSP standards and auto-relatei
standards (CO,,HC, Ox).
PROGRAMS
Isolated Point Source (sulfur dioxide, particulate): EPA has proposed SO2
regulations for non-ferrous smelters and has held hearings. The State is
developing its own regulations to be submitted to EPA before we finalize
our regulations. EPA will then approve these State regulations, or if they
are not approvable, EPA will finalize its own regulations.
The process weight regulation for smelters has been suspended by the State.
It will be the State's responsibility to resolve this issue. EPA will
assist with a testing program. If the current regulation cannot be supports:
the BOA contract study may be needed to determine the contribution of
smelters to TSP violations and hence provide guidance for the percent con-
trol required.
As the problem is defined and RACT is delineated, State and local agencies
will add regulations to control fugitive emissions from agriculture,
unpaved roads, construction.
CO/Oxidants; EPA will analyze the adequacy of the currently-approved
Control strategy, and order revisions as needed.
Emission Inventory Development (Particulate, oxidant): A Phoenix emission
inventory for particulate matter is under development by BOA contractor and
will be completed in July, 1976. Regional Office internal effort or BOA
contract effort should be added to study non-urban areas. Joint agency
evaluation of the results of these inventories is required. Pima County is
interested in a longer term, and more refined fugitive study.
Recent emission data submitted to S&A by Motorola indicate inaccuracies in
existing inventory (Large difference in THC). Maricopa County is working
on a revised hydrocarbon emission inventory. ADHS must evaluate HC inventor
for both Phoenix and Tucson and make reconmendations for updated or revised
controls. This effort is to be coordinated with AOMP efforts and any hydro-
carbon regulation reviews related to the SIP.
-------
A - 11
EPA Compliance Verification (particulate, oxidant) : S&A will
perform by inspection, an overview of 10% of the major stationary
sources. Emphasis will be on sources of particulate and hydrocarbon,
Major Federal facilities are included. VEO compliance verification
is hampered by a 40% standard. »
State/Local Compliance Verification (particulate, sulfur dioxide,
oxidant):State and local agencies will perform annual compliance
verification on major stationary sources for which thev are
responsible. (State should delegate responsibility for
all stationary sources except smelters to local agencies. CDS
reports will be submitted. Minor sources will be considered
after their contribution has been better defined by the TSP
inventory contracts.
Emergency Episodes (carbon monoxide, sulfur dioxide): This is
a State and local program. Since CO and SC>2 episodes occurred
in 1975, only a minimal Regional Office overview is anticipated
to insure compliance with approved SIP regulations.
Inspection and Maintenance (carbon monoxide, oxidant): The
inspection portion of this program is now being conducted in
Maricopa and Pima Counties by contract with Hamilton Systems.
Passing the inspection will become mandatory in 1977 and
maintenance will be required. The I/M program is in jeopardy
in the State Legislature and mav be repealed. The next 2-3 months
are critical. Top management 'in Air Programs and OER should
initiate a program in support of I/M. Air Programs will also
provide a list of-alternatives available for GO/Ox strategy if
the State repeals I/M.
If the I/M program survives, the State will conduct an audit
program. EPA should work with the state inspectors on joint
audits of test stations and fleet dealers.
Data Processing (all pollutants): Air ouality data contractors
are currently installing AQDHS II at State level and in Pima
County. This effort will allow quarterly air quality data
reports to be submitted to the Regional Office in SAROAD format
on magnetic tape. Contractor follow-up is provided for six
months and training is included. Upon completion of the
contracts, operation will be strictly State.and local, including
funding.
-------
A - 12
EPA will be involved only in evaluating submitted data and as State liaison
for resolving data rejections.
Emission Data; Contractor assistance will be provided to ADHS to install
EIS/P&R by about May 1976. After AQDHS II installation is completed, train-
ing, debgging and six-month follow-up will be provided. By the end of 1976,
this will be strictly a State function except for EPA-Region IX receipt of
data and liaison with State in resolving data rejections.
Quality Assurance (all pollutants): This is primarily a State and local
program (both State and local agencies operate Air monitoring networks).
The State is developing a quality assurance program, which, when finalized,
will be implemented statewide. While EPA is providing guidance, EPA's
primary role, now and in the future, is audit checking to assure validity of
data. The program includes inter-lab testing of standard samples (i.e., Star
and local participation in collaborative testing) and field audits of con-
tinuous instruments to assure accuracy (using standards, calibration checks,
etc.).
New Source Review (particulate, oxidant, sulfur dioxide):
The reviev; of new sources will be strictly a State and local
program.
Fuel Additives (carbon monoxide, oxidant): This is an EPA
program to insure availability of unleaded gasoline and unconta-
minated gasoline. Regional Office inspection and sample
analysis are involved. This program is necessary to prevent
widespread inactivafcion of the catalysts.
Because of the I/M uncertainties, the fuel additives program
is critical in this AQCR.
208, 201, Transportation Planning Consistency (carbon monoxide, particulate,
oxidant): This involves EPA review of 201 constructiion projects, 208
planning and 3-c transportation plans for consistency with the SIP and
strategies to maintain NAAQS.
Air Quality Maintenance Plan (particulate, oxidant, carbon monoxide):
Phoenix is an AQMA for TSP, Ox, and CO. An analysis of air quality projec-
tions and possible strategies will be developed by a BOA contractor. The
previously-mentioned emission inventory refinement for TSP and HC must be in-
cluded in the AQMP baseline.
Tucson is an AQMA for Ox and particulates. An attainment and maintenance
plan is under development now by the Pima County Air Quality Control District.
Completion is scheduled for FY-78. Their preliminary oxidant analysis shows
attainment by 1981.
-------
A - 13
Changes in the State I/M program would alter the situation.
The long-term programs and "r year strategy" for the
Phoenix-Tucson AQCR are a continuation of existing programs
and are dependent upon successful implementation of the short-
term programs. With the exception of the visibility/fine
particulate standard/secondary aerosol research work is
needed to define the standard and control technologv development.
STRATEGY
The short-term strategy in this AQCR has three major parts:
1) Obtain better definition of the sources and their
respective contributions to ambient concentrations
(TSP and HC).
2) Improve old regulations, establish new regulations
and enforce existing regulations (TSP process weight
and visible emissions, HC stationary sources).
3) Insure continuation of the State Inspection/Maintenance
Program for vehicles in Maricopa and Pima Counties.
The emission inventory work for TSP is being'done in
Phoenix by contract, and for HC by Maricopa County. The contract
results and EPA Headquarters guidance will be the basis for
development of_fugitive emission control regulations. Additional
contracts for TSP in Tucson and the non-urban area of this AQCR
have been suggested. Funding will depend on applicability of
the results of the present contract (scheduled for completion
by July, 1976) to Tucson and the non-urban area. The TSP
inventory in the Southern Borders AQCR, when completed, could
be applied to the smelters in this Region.
The hydrocarbon emission inventory being conducted by
Maricopa County is now underway. The State will evaluate the
results and supplement the data by HC source inspections if
necessary.
Both the particulate and hydrocarbon inventory should
lead to new or revised regulations to control emissions.
The strategy for compliance and enforcement is to have
the appropriate^State or local agency inspect all major sources-
annually to assure compliance. Minor sources may be looked at in
the long-term, depending on the particulate matter emission
inventory development. EPA will conduct a 10% overview of
major stationary sources annually. While emphasis will be on
PM and HC, inspections will include sources under the different
agencies' jurisdiction. Enforcement of non-compliance is to
be strictly a State and local effort with EPA involvement only
in the event of State and local inaction.
-------
A - 14
The strategy for episode control is Abatement action by State and
local agencies. Because of CO and SO2 episodes in Phoenix, and Miami/
Hayden in 1975, a minimal EPA surveillance overview must be maintained.
EPA's strategy on the Arizona I/M program is to insure its continuation
We should initiate three efforts immediately: (1) OER-related efforts to
support I/M, (2) Air Programs preparation of an issue paper on the options an:
alternatives available to EPA, should the State repeal the program, (3) RC
investigation of the possibility of providing support to the State in the
event of a legal challenge.
In the data provessing program our strategy is to have AQDHS II installe
on the state computer by May, 1975. EIS and P&R data processing installation
will follow imriediately on the same computer.
The installation of this software is supported by joint Regional/
Headquarters funding. EPA is monitoring the contracts and
provides assistance through the first SAROAD and NEDS data
submittals to us. Operational costs are to be paid for by the
State. EPA is also funding contract effort for the installation
of AQDKS II in Pima County. Once installed, the operation
becomes part of the local program. Overall, once the State
systems are operational, EPA's role is one of guidance (i.e.,
Headquarters changes in the software package), and the State
is responsible for maintaining the data base and submitting
the data.
EPA will take a low profile on NSR and defer to the State.
In addition, EPA will encourage the State to develop its own
PSD regulations.
Quality Assurance is to be a State and local program with
minimal guidance from EPA. The State will insure a uniform
QA program statewide while EPA will continue to provide an inter-
lab testing program (from Headquarters RTP).
EPA's strategy on fuel additives is critical in this
AQCR. Because of the automobile-related pollution problem,^
the program should be continued at the existing level. Similarly
the coordination between 201, 208 and air transportation
consistency must remain a viable program in both Phoenix and
Tucson.
-------
A - 15
The AQMP strategy is to let a contract for the Phoenix
AQMP in March, 1976. The AQMP will have to be coordinated
with the emission inventory development work (EC and TSP)
even at the risk of delaying the plan. In Tucson, the County
is proceeding on schedule with AQMP analysis and plan development,
Submission of the plan is due in FY-78. Both AQMP's could
be seriously affected if the inspection/maintenance program is
renealed.
-------
REGIONAL AIR STRATEGY
REGION IX
ENVIRONMENTAL PROTECTION AGENCY
Geographic Narrative on the
Air Quality Control Region (s)
for the State of
California
March, 1976
-------
REGIONAL AIR STRATEGY
REGION IX
ENVIRONMENTAL PROTECTION AGENCY
Geographic Narrative on the
Air Quality Control Region (s)
for the State of
California
March, 1976
-------
TABLE OF CONTENTS
FOR
CALIFORNIA
FY-77 REGIONAL AIR STRATEGY
Section Page
I. General Introduction 1
II. Basic Program BP-1
III. Narrative for California AQCR's
AQCR #23 - Great Basin Valley C-l to C-l
AQCR #24 - Metropolitan Los Angeles C-3 to (X
AQCR #24 - North Central Coast C-9 to C-!
AQCR #26 - Northcoast C-12 to C-
AQCR #27 - Northeast Plateau C-14
AQCR §28 - Sacramento Valley C-15 to C-
AQCR #29 - San Diego C-20 to C-
AQCR #30 - San Francisco Bay Area C-25 tc C-
AQCR #31 - San Joaquin Valley C-32 to 0
AQCR #32 - South Central Coast C-36 to C-
AQCR #33 - Southeast Desert C-39 to C-
-------
AQCR #23 -'GREAT BASIN VALLEY
INTRODUCTION
The Great Basin Valley AQCR lies on a narrow strip of central
California between the eastern crest of the Sierra and the
Nevada border. The AQCR is sparsely populated (24,700) and
mountainous. The climate is characterized by very low rain-
fall and a large variation in winter/summer temperatures.
Its scenic attractions include Mono Lake, the Owens Valley and
the Death Valley National Monument. The primary industries
are agriculture (Owens Valley) and tourism. The three counties
in the AQCR, Mono, Alpine and Inyo, have formed the Great Basin
Valley Unified APCD.
PROBLEM
Virtually no data is collected in this area. The ARB has some
intermittent PM data for 1974 from Bridgeport showing an AGM
of 31, less than half the standard. There is no data available
on other pollutants.
GOALS
Eighteen-Month:
Work toward implementation of the State version of PSD.
Five-Year:
Work with ARB, the APCD, the City of Los Angeles (which
controls land- in the Owens Valley) and Federal land
managers to.avert air quality problems.
PROGRAMS
Prevention of Significant Deterioration - This would
primarily be a State effort with a low level of involve-
ment by EPA. EPA would coordinate with ARB in the
establishment of Air Conservation Areas.
New Source Review - EPA must review and permit any sources
in the 19 categories covered by PSD regulations until
delegation occurs. EPA will coordinate the review with
the Great Basin Valley APCD.
-------
C - 2
State/local compliance verification - The local district
will verify the compliance status of the 14 major point
sources located in the AQCR. EPA will require a quarterly
status summary from ARE via the grant mechanism.
STRATEGY
Since there are no known problems there is no need for
extensive Federal involvement.
-------
C - 3
AQCR f 24 '- METROPOLITAN LOS ANGELES
INTRODUCTION
The Los Angeles Metropolitan AQCR contains almost ten million
people, some 47% of the State's population. While the AQCR
contains some mountainous, sparsely populated areas, it is
largely urbanized and industrialized. Owing to the magnitude
and intensity of emissions and the generally stable meteoro-
logical conditions of most of the AQCR, pollutant concentra-
tions tend to be high. Since meteorological conditions are
extremely favorable for photochemical reactions, oxidant (or
ozone) concentrations are the highest in the nation. Problems
persist despite long-standing controls on stationary sources
and automobiles and the widespread use of clean fuels.
The AQCR has three local air pollution control agencies but
one of them, the Southern California APCD, covers more than
90% of both the population and the total emissions of the
AQCR. Santa Barbara and Ventura counties also operate air
districts.
PROBLEM
Based on 1974 data, the AQCR experiences severe and pervasive
violations of NAAQS for oxidants, CO, PM and NO2- Ifc is
currently meeting S02 standards but pending fuel switching
will likely cause violations.
All 45 stations reported violations for oxidants in 1974.
The readings ranged from .15 ppm (max. 1 hour) along the
coast to .63 ppm at Upland, some 40 miles inland. The high
oxidant readings result from the emission of reactive hydro-
carbons (HC) from a variety of sources in the AQCR.
The SCAPCD and EPA disagree significantly on the percentage
of "reactive" HC emissions emitted by stationary sources.
SCAPCD holds that only 27% of the total inventory comes from
stationary sources, while EPA feels the contribution is
closer to 40% with the percentage increasing yearly. (ARB
largely concurs with EPA.) The difference is not with the
data base (although it needs to be improved) but with differing
definitions of reactivity.
Twenty-three out of 33 stations showed violations of the
eight-hour CO standard in 1974, with a maximum of 30 ppm in
Lennox. Only two stations, however, (Lennox and Lynwood)
show violations of the one-hour standard.
-------
- C - 4
Twenty out of 30 stations showed violations of the annual
geometric mean (AGM) standard for PM. (Violations of the 24
hour standards are rare, however.) Violations occur in both
urbanized and rural areas.
Ten of 18 N02 stations reporting an annual arithmetic mean
(AAM) showed violations of the standard. The highest readings
tend to be inland.
Mobile sources remain the largest emission source category,
however, regardless of their share of the HC inventory.
They account for more than 75% of the NOX and over 99% of
the CO. According to APCD data, they are also responsible
for 50% of the PM emitted daily. Almost 90% of the SC>2,
however, is stationary source related with the percentage on
the increase as natural gas use decreases. Gasoline desul-
phprization will also increase SO2 emissions if it becomes
necessary because of State auto emission standards.
GOALS
These goals were selected on the basis of the air quality
problems presented above. They are divided into short-term
(18-month) and long-term (5-year) categories.
Eighteen-Month:
Implement available programs to reduce reactive HC
emissions and survey other possible control measures.
Reach an agreement on the reactivity of all significant
categories of HC. Resolve source test equivalency
issue.
Improve the quality and accessibility of the data base
through standardization of the emissions inventory and
quality assurance measures on all air monitoring stations.
Insure the best possible local surveillance of existing
stationary sources of all criteria and hazardous pollutant:
and the strict enforcement of existing regulations. HC
sources merit top priority.
-------
C - 5
Define and establish the institutional relationships
required for a viable, regional long-range air quality
management process. Begin plan development.
Closely monitor growth-related projects in both the
public and private sectors and, to the greatest possible
extent/ work to mitigate their impact on air quality.
Five-Year:
Eliminate all areas of significant technical disagreement
among the SCAPCD, the ARE and EPA which interfere with
the development of a unified approach to solving air
quality problems.
Develop a complete, accurate and sophisticated data
base that will enable all levels of government to
improve their understanding of the various air quality
problems.
Establish a long term planning process to enable cognizant
agencies to periodically update their coordinated
efforts to improve air quality and approach (and in
some cases, achieve) NAAQS.
Establish an efficient and effective program for annual
mandatory I & M on all light duty vehicles.
Modify regulations as required -to require BACT control
over all stationary sources of reactive HC.
Bring about a consistent annual net decrease in the
emission of HC, CO, NC>2 and PM.
Maintain the NAAQS for SC>2 while promoting energy
conservation and the effective use of clean fuels.
PROGRAMS
The following programs were developed to achieve the 18-
month goals stated above.
Vapor Recovery - EPA will formally approve local
regulations and support their implementation with 105
grant funding. EPA will try to avoid enforcement of
EPA-promulgated regulations until they are formally
rescinded.
-------
C - 6
Other Organics (HC Review and Revision) - Carry out a
joint Federal/State/local effort to review and, if
indicated, revise local regulations to increase the
level of control on reactive solvents, petroleum refining,
petroleum manufacturing, petroleum storage and other
source categories of reactive HC. ARE will take the
lead in developing model rules. ARE/EPA contract
support is indicated during the rule development stage
and EPA grant support may be used for rule revision.
Local agencies aid in rule development, adopt and
implement needed changes or additions.
I & M - ARE has the lead in monitoring the progress of
the pilot program. EPA and ARE will carry out the
required executive liaison with the Legislature and
Administration to encourage full implementation.
New Source Review - EPA will carry out the review
function in-house until delegated using a "no net
increase in emissions" policy. EPA to delegate the
program as called for in the FY76 grant agreements.
ARE and/or local agencies to implement program.
Emission Inventory Development - Like many other high
priority programs this must be a cooperative effort.
Local agencies would have primary responsibility for
improving their data base. EPA grant and contract
support (see Emission Inventory (data handling) below)
will supplement state and local resources. ARB is to
coordinate the overall State effort, resolve technical
issues (selection of industrial categories for example)
and help set priorities. Top priority should be given
to stationary sources of HC (the reactivity definition
issue must be resolved) followed by S02, NOX and PM.
Emission Inventory (data handling) - SCAPCD and Ventura/
Santa Barbara will install the EIS/P&R software system
with EPA contract and/or grant support. The grant
would also aid in the tedious job of data conversion.
EPA to use the grant to coordinate priorities with ARB
and the locals. The total effort to bring about data
base improvement is expected to take two to three
years.
-------
C - 7
AQMP/208 - The AQMP effort is primarily a regional
program with ARE and EPA oversight. Local APCD's have
the responsibility to provide needed technical input to
non-air agencies involved in the process. All parties
must assure coordination with the "208" wastewater
management effort.
ARE efforts should be directed primarily toward the
building of the institutional relationships required
for a viable process. EPA will use such tools as
executive liaison, inter-governmental coordination,
public information, and financial assistance to assist
the overall effort. All participants, but particularly
local APCD's should ensure that related programs (Example:
emission inventory development) are operated with AQMP
in mind.
Since their AQMP effort is farther along than the rest
of the basin, Ventura County may operate a separate,
but coordinated, program.
EPA Compliance Verification - Owing to the magnitude of the
problem EPA oversight should be slightly above the
normal 10% overview, concentrating on HC and PM sources.
EPA may look closely at the inspection programs of the
San Bernardino and Riverside portions of the SCAPCD.
State/Local Compliance Verification - EPA will provide
direct grant funding for local review of HC sources
including, in the SCAPCD, some categories of minor HC
sources. (The APCD can choose the categories with EPA
concurrence.) ARE will report on the status of all
major sources plus the minor sources selected above.
Fuel Additive - Inspections and analyses will be
performed by ARE under an EPA contract. .Part of the
contract is funded by Region IX and the rest by " '
EPA HQ. " ~
Quality Assurance - EPA will provide grant support for
standardization of State and local operation and cali-
bration procedures in accordance with ARE guidelines.
ARB will assist local agencies in the implementation of
their procedures.
-------
C - 8
Air/201, Air/EIS, Air/Transportation Coordination -
Active EPA intermedia review, plus intergovernmental
coordination, will occur to work toward the goal of no
net increase in emissions from major infra-structure
development. The ARB and local APCD's are expected to
continue their past role in these review processes.
Air/Energy Coordination - Action in this area will key
off the ongoing ARB effort to analyze the impact of
fuel switching on air quality; particularly on SC>2
levels. If, as expected, a strategy revision is indicated
by the ARB's analysis, rule revisions would occur
through a joint State/Federal/local effort. The ARB
would be expected to develop model rules for S02 and
NOX and the local APCD's would be expected to adopt and
implement needed changes. EPA grant fvinding will
support the effort.
All agencies, including EPA, should also be active in
the public relations area to help the public to understand
the effects of fuel switching and to promote support
for stricter controls on industry.
Emergency Episodes - Air quality has improved to the
point that Stage 2 episodes will be a rarety and Stage 3
episodes will not occur. The emergency episode program
is a State/local program with only Basic Program 'EPA
grant support.
In-stack Monitoring - EPA will defer to the State
program as long as satisfactory progress continues.
STRATEGY
There are two major short-term themes: Improve cooperation
with local agencies, particularly the SCAPCD, and concentrate
our efforts on stationary sources of HC.
In the long run, all agencies should work to continue to
tighten controls on all sources that contribute to air
quality problems while realizing that attainment of the .08
oxidant standard is a goal we can approach but probably not
attain. There is a need to have an overall AQCR control
plan that all institutions can understand and support. We
should support, tougher-than-national automotive emission
controls by the ARB backed by an I & M program that insures
that controls are being effective. Public support for all
programs must be actively cultivated.
-------
C - 9
AQCR #25 - NORTH CENTRAL COAST
INTRODUCTION
The North Central Coast AQCR contains 425,000 residents
in four counties around Monterey Bav. There are a few
major population centers with many smaller communities
spread throughout the area. The AQCR is not in attain-
ment for oxidant and particulate. There is no monitoring
for S02, CO and NOx are apparently in attainment. Monterey
County%/as proposed as an. AQMA for oxidant in 1975, however,
at the State's request that designation was not finalized.
The unified district reports on 21 point sources.
PROBLEM
Oxidant:
Monitors are located at Salinas, Gonzales, Carmel Valley,
Santa Cruz and Monterey. Four reported two or more
violations during 1974. During 1974, the APCD revised the
stationary source inventory and re-calculated the rollback
required to demonstrate attainment. Based on the re-calculation
and the revised inventory, the district projects attainment
in 1976.
Particulate;
The Salinas station does not attain the primary annual § p
geometric mean standard. In both 1973 and 1974, single w^
violations of the 24-hour standard were recorded. Other «^
stations do not report violations. :o c
r c £ o
c -H
Sulfur Dioxide: '£>£"&
. n} nj u.
u -, T1
There is no monitoring for this pollutant. Some citizen "M-I §-H
complaints have been received regarding materials damage %rc > tn
possibly caused by sulfuric acid mist. The Moss Landing e u "u
power plant is permitted for both natural gas and low
sulfur fuel oil with no emissions limitations nor ambient
SOx monitoring reauirements. *N_eed to perform spot jnonitorinc
due tg_jPOgs_ibjLe^exacerbation of SOp ambient air quality due
to fuel switching.
N09f CO:
No violations of these standards for these pollutants have
been reported.
-------
C - 10
GOALS
Eighteen month:
Assess air quality data and inventory for hydrocarbons
and oxidant.
Call for plan revision if appropriate.
Review need for S0_ monitoring, planning.
Five Year:
Maintain air quality standards.
PROGRAMS .
Quality Assurance (oxidant):
EPA to make site inspections of monitoring stations to
provide a brief overview of the monitoring network and
opinion on its reliability. Over the next six months
the State should provide a more thorough quality assurance
program to insure that the data is reliable. Program
Grant funds could support this effort.
Inventory Assessment (hydrocarbon/oxidant):
Concurrent with Quality Assurance, The State should
evaluate the inventory for- hydrocarbons. Program grant
funds could support this effort.
Monitoring (S02):
The State should investigate and implement any needed
facilities to monitor SO,, concentrations.in the vicinity
of the Moss Landing Power Pland tnd the San Ardo Oil Field
Other Organics (hydrocarbon/oxidant):
A joint State, Local. EPA review of hydrocarbon regulation:
may be indicated if data continues to demonstrate non-
attainment £6r oxidant.
-------
C - 11
Air Energy Coordination (sulfur dioxide):
With the prospect of further natural gas curtailment,
EPA's role will be one of providing public information,
testifying at EPA/FEA hearings and executive liaison to
establish a place for environmental considerations in
fuel allocation decisions. In this AQCR the problem,-
if any, has not been documented.
-------
C - 12
AQCR" 126- NORTff COAST
INTRODUCTION
The population of 250,000 is spread through smaller
communities along major transportation routes (U.S. 1,
U.S. 101). Communities tend to be located around re-
creation areas and industrial centers. Industry is pre-
dominantly wood products oriented including lumber, paper
and intermediate processes. Particulate matter and odors
appear to be the major air pollution problems. Around
Humboldt County some total reduced sulfur monitoring is
being done in an effort to measure some of the mercaptan
or other sulfurous odor problems. B6_ major sources are
reported to EPA from this AQCR.
PROBLEM
Particulate;
Violations of the annual geometric mean are reported at
five stations: Samoa, Ft. Bragg, Ukiah, Willets, and
Calpella. Infrequent scattered violations of the 24 hour
concentration occurred in 1974. Sources appear to be of
smaller stationary types associated with wood waste dis-
posal as well as a smaller number whose emissions are
process oriented.
GOALS
Eighteen month:
Initiate program to solve wood waste disposal problems.
Support State's Prevention of Significant Deterioration
program or its equivalent.
Low priority oversight of State/Local Compliance Verifi-
cation Program.
Five Year:
Provide for attainment/maintenance of standards.
-------
C - 13
PROGRAMS
Intergovernmental Coordination (particulate):
Seek a program or process to reuse or to dispose of
problem wood industry byproducts and wastes. Agencies
to be contacted: Forest Service, Regional Water Quality
Control Board, Air Resources Board, and Air Pollution
Control Districts. In cooperation with the concerned
industries try to interest State leadership in seeking a
solution to the problem.
State/Local Compliance Verification (particulate):
Due to the nature of the problem for the widespread
particulate violations, the activities of the APCD in
keeping other sources in compliance is of interest for
maintenance. Since this program is part of the normal
district operation, the basic element of the §105 program
grant can be reduced and phased down in the next five
years.
Prevention of Significant Deterioration (particulate):
As in other areas, this program has not been accepted by
the State, which is promoting an independent approach
encompassing all criteria pollutants. Region IX should
provide policy support whichever program the State de-
termines to implement.
-------
C - 14
AQCR £27 - NORTHEAST PLATEAU
INTRODUCTION
This sparsely populated (60,000) Northeast Section of
the State has small communities that are either recreation
or lumber industry dependant. A single particulate raon-
itor records a violation. 25 point sources are reported
to EPA from this AQCR.
PROBLEM
Particulate;
The Mt. Shasta monitor shows a violation of the annual
geometric mean. The violation appears to be associated
with local lumber industry.
GOALS
Eighteen month;
State/local action to provide source compliance and attain
standards.
Commence planning for prevention of significant deteriorati
Five Year;
Maintain standards.
Prevent significant deterioration.
PROGRAMS
State/Local Compliance Verification (particulate);
The State's basic program should include inspection/en-
forcement to provide attainment of the particulate standard
in this AQCR. No special EPA commitment is indicated.
Prevention of Significant Deterioration (particulate);
The State has not accepted EPA's PSD program and has
commenced its own effort based on Air Conservation Areas
which would apply to all pollutants. Whichever program
the State ultimately adopts should receive EPA policy
support.
-------
C - 15
AQCR £28 - SACRAMENTO-VALLEY
INTRODUCTION
The Sacramento Valley AQCR is enclosed by the Coastal
Range, Sierra Nevada, and Cascade Range on the West,
East and North and is administratively dissected from
the San Joaquin Valley at the Sacramento-San Joaquin
County Line. The 1.4 million residents are concentrated
in linearly distributed metropolitan centers following
the major North-South transportation corridors (US-99/
1-5). The major urban center is the city of Sacramento
and its suburbs, which spread across county lines into
Placer and El Dorado counties. The ARB has split out
the foothill-mountain areas of this and the San Joaquin
AQCR to form the Mountain Air Basin. Additionally, the
ARB designated the California side of the Lake Tahoe
area as an air basin. This action represents a desire
to deal with Lake Tahoe's unique problems separately
and to open communications with the State of Nevada.
The AQCR is in violation of the primary standards for
CO, TSP and oxidant.
PROBLEM
Particulate:
There are fourteen particulate monitors in the central
portion of the AQCR; three report violations of the
annual geometric mean (Chico, Live Oak, Yuba City); five
have exceeded the 24-hour standard concentration once,
which is allowed, but it clearly represents marginal
attainment. The sources are largely fugitive agricultural
emissions with limited point source contributions. The
ARB is producing an agricultural burning inventory which
should aid in defining the problem.
Carbon Monoxide;
A limited monitoring network indicates violations of the
eight-hour standard at Chico. The Sacramento monitors
show values just under the eight-hour standard (9.6 ug/m3)
using sites that may be questionable in terms of sampling
likely high CO concentrations.
-------
C - 16
Oxidant;
All six oxidant monitors in the AQCR report one-hour
standard violations on from 19 to 136 days per year
(1974). Exceedances of over twice the standard have
been reported. Quality of data is good, although some
stations reported for limited times during 1974. Hydro-
carbon sources in the valley are dominantly mobile source
related.
GOALS
Eighteen month:
Define the extent of the CO problem. Reduce hydrocarbon
emissions through available controls.
Commence planning for attainment and maintenance through
support of AQMP.
Five Year:
Oxidant and CO attainment through AQMP implementation.
Prevent significant deterioration.
PROGRAMS
Vapor Recovery (hydrocarbon/oxidant):
The ARE is interested in expanding vapor recovery on the
valley floor and in highly developed areas; this approach
should be supported by EPA since AQCR wide implementation
would be resource intensive without significant increased
emissions reductions. This will be supported through the
§105 grant to ARE.
Other Organics (hydrocarbons/oxidant):
Through a joint State, local and EPA review, insure con-
sistency and appropriate hydrocarbon regulations through-
out the AQCR. EPA will support through the §105 grant
to ARE.
-------
C - 17
Quality Assurance (all) :
EPA site visits to the CO monitoring stations in Chico
and Sacramento should be performed to insure that data
is being properly collected and measured. The state
program implemented in FY-76 should provide for quality
assurance for other pollutants AQCR wide.
State/Local Compliance Verification (hydrocarbon/oxidant):
Although this is a part of the basic State-local program,
EPA should support inspections of problem pollutant sources.
In this AQCR EPA should support inspection of hydrocarbon
sources only to districts receiving grant support. Other
point sources are to be inspected and reported under the
basic program.
EPA Compliance Verification (hydrocarbon/oxidant):
EPA has an oversight role in this AQCR and should concen-
trate its efforts on hydrocarbon sources. Similarly EPA
Enforcement will be a low key effort centered on hydro-
carbon control.
New Source Review (hydrocarbon/oxidant, particulate):
This is a state program which should continue to be a
state/local effort with low level EPA oversight.
Agricultural Burning (particulate, CO):
A state program which both regulates burning and assesses
the hydrocarbon, particulate and carbon monoxide emissions
from burning practices in the Sacramento Valley.
Fuel Additives (hydrocarbon/oxidant, CO):
A state program operated under EPA headquarters contract
to insure availability of proper fuels for catalytic con-
verter equipt vehicles.
Transportation Coordination (hydrocarbcn/oxidant, CO):
EPA should continue to be involved in this effort through
-------
C - 18
inter-governmental coordination with the Intermodal
Planning Group, comments on the D.O.T. Overall Work
Program, and comments to F.H.W.A. on transportation
plan consistency with SIP under F.A.H.A. §109 (j). EPA
should try to involve the AQMP task force in impacting
transportation decisions in the Metropolitan Sacramento
AQMZV.
EIS Review (hydrocarbon/oxidant, CO, others):
EPA should continue to comment on projects projecting
an increase in emissions in this AQCR.
AQMP (hydrocarbon/oxidant, particulate):
The AQMP task force in Sacramento is progressing slowly.
EPA should continue supporting this program through grants
to the APCD and pass through funds from ARE. Particulate
was included in recognition of the existing problem, howeve.
appropriate controls are not apparent at this time.
SPECIAL INTEREST AREASacramento Valley AQCRLake Tahoe Portior
PROBLEM
The ARE operates two monitors in the Lake Tahoe Air Basin.
The ARE is considering more stringent CO and particulate
standards in this basin in recognition of the high altitude
and great scenic beauty of the area respectively. C ALT RAITS
monitors have detected violations of the oxidant standard.
The air pollution problem is poorly defined and inadequate
for strategy purposes. The ARE is expected to request that
EPA designate the entire Lake Tahoe basin as an Interstate
AQCR in hopes that this will assist their efforts in co-
ordinating with the State of Nevada.
STRATEGY
EPA agrees that an Interstate AQCR would be desirable,
however, EPA's ability to react is limited at this time.
There is a possibility that the 1976(7} amendments will
provide this flexibility.
While the problem is undefined, its resolution is left to
State initiative and EPA wil.1. not undertake an extensive
effort at this time.
-------
C - 19
PROGRAM
Intergovernmental Liaison:
Try to create an atmosphere of cooperation in which the
states can meet to develop programs applicable to the
meteorologically defined air basin.
-------
C - 20
AQCR #2"9 SAN .DIEGO
INTRODUCTION
With the exception of a narrow, sparsely populated strip on the
eastern edge, the San Diego AQCR is coterminus with San Diego
County. The climate is similar to Los Angeles in that metero-
logical conditions are conducive to the build up of high con-
centrations of both primary and secondary pollutants. Since
the population is less than 1/6 of the Los Angeles Metro AQCR
(1,508,000), and the degree of industrialization is also much
less, San Diego's problems are not as severe as those to the
north. Air -quality in San Diego, however, is clearly influenced
by its neighbors. The North County experiences occasional
high concentrations of oxidants transported (at least in
part) from Los Angeles. It appears that high particulate
levels at San Ysidro in the south, may be influenced by
heavily emitting Mexican sources. Uncontrolled Mexican
vehicles also contribute to concentrations of CO, NOX and
oxidants.
Air quality planning in San Diego has drawn support from both
the cities and the County APCD. The cities, through their COG
(the Comprehensive Planning Office), have participated in the
Air Planning Team which, in turn, has developed the Regional
Air Quality Strategy (RAQS).
PROBLEM
NAAQS are violated for Ox, PM and CO. The oxidant problem is
both significant and pervasive. In 1974 all 8 stations showed
violations, ranging from a .18 ppm maximum 1 hour at San Diego
(39 days in violation) to .33 ppm maximum at Oceanside (48 days
in violation). The most consistently high readings occurred
at Escondido which had a .27 ppm maximum with 112 days in
violation.
Oxidant violations are the source of some controversy between
local planners and EPA. The San Diego Air Quality Planning Team
concluded that higher levels are caused by transport from LA and
that .20 is the maximum level that could be produced by indigenou
sources. EPA feels that past transport studies are not conclusiv
enough to permit quantification of concentrations. Approximately
40% of the "reactive" HC emitted in San Diego County come from
stationary sources (1972 "Revised" Inventory).
-------
C - 21
The Annual Geometric Mean standard for PM was violated at 6 of 7
stations including urban, coastal areas. The highest readings
were recorded at San Ysidro, immediately across the border from
uncontrolled sources in Mexico. The AGM there in 1974 was 161.5
and there were also 3 violations of the 24 hour primary standard.
The source of the PM problem is unclear. The APCD attributes
more than 90% of total emissions to unpaved roads.
Violations of the CO standard were few (14 days at 3 stations),
extremely low level (11 ppm maximum) and involved only the
8 hour standard.
Based on the data alone, there is no indication that CO is any-
thing but a borderline maintenance problem in San Diego. APCD
monitoring stations, however, are not located to pick up CO
"hot spots.1' Street level readings, to which much of the popu-
lation is exposed, are not a part of the data base.
NAAQS were not violated for NOX or S02 in 1974.
GOALS
The following short term (18 month) -and long term (5 years) goals
were developed in response to the air quality problems outlined
above.
18 MONTH
Implement available programs for the control of reactive HC.
Survey other possible controls.
Complete RAQS II (AQMP/Phase II) including the adoption and
implementation of rule changes contained therein.
Improve the quality and accessibility of the data base through
standardization of the emissions inventory format with ARB.
Insure the best reasonable surveillance of existing sources
of RHC, PM and hazardous pollutants (if any). Insure adequate
surveillance of all others.
Closely monitor growth-related projects in both the
public and private sectors and, to the extent possible,
work to mitigate their impacts on air quality.
Define the source of the PM problem.
-------
C - 22
5-YEAR GOALS
Maintain the coalition of agencies responsible for the
Regional Air Quality Strategy as a permanent air manage-
ment planning process.
Develop a complete, accurate and sophicated data base to
enable all concerned parties to understand and "buy-in"
to control strategies.
Determine the magnitude of the LA contribution to Ox
violations in San Diego County. (The APCD feels this is
a high short term priority.)
Begin an efficient and effective program for the annual
mandatory inspection of vehicles.
Modify regulations as required to require BACT control
over all stationary sources of HC.
Bring about a consistent annual net decrease in the
emission of HC and CO and PM.
Participate as required in a nationally directed effort
to reduce emissions from sources located in Mexico.
(Including the control of vehicles.)
Achieve NAAQS for CO at all monitoring locations and
maintain standards for S02-
PROGRAMS
The following programs were developed to achieve the 18-month
goals listed above.
Other organics (review and revision of HC controls) - This is
a joint local/state/federal program. ARB is primarily resonsible
for identifying deficiencies and developing model rule revisions.
The APCD will assist in the identification of deficiencies and
will adopt needed changes. EPA will provide technical assistance
and grant support.
Vapor Recovery - This is a local program. EPA will continue
to encourage the District to complete Phase II through the
use of grant funding.
-------
C - .23
EPA Compliance Verification - EPA will conduct approximately
a 10% overview unless pending ARE evaluation of the APCD in-
spection program shows a need for a higher level of activity.
EPA will concentrate on sources of HC and PM.
State/Local Compliance Verification - This is primarily a
local program. The APCD will verify the compliance status of
all major point sources and report to ARE. ARB will insure
APCD performance and report to EPA. EPA will provide direct
grant support for the verification of sources of HC and indirect
(Basic Program) support for the verification of sources of other
criteria pollutants and for reporting.
AQMP - This is a regional program with ARB/EPA oversight. EPA
will insist on close coordination of RAQS-II completion with the
"208" wastewater management planning process. EPA financial
support of these processes will be closely coordinated to avoid
duplication.
The APCD will begin implementation of RAQS-II control measures.
EPA will, for the short run, agree to having RAQS-II proceed
toward a target of .20 ppm maximum oxidant concentration.
Fuel Additive - EPA will continue to provide needed contractual
financial support to the ARB for State inspections and analyses.
Air/Energy Coordination - EPA and ARB will continue to encourage
the PUC to make natural gas available in the basin. Upon com-
pletion of the ARB study of the quantitative relationship between
fuel switching and air quality, ARB will, if appropriate, develop
and adopt model rule revisions to control SC>2, NOX and PM. The
APCD will adopt needed changes. EPA will provide technical
assistance and contract and/or grant support.
All agencies should carry out active public information programs
to educate the public to the impact of fuel switching on air
quality.
Emission Inventory Development - EPA will perform an in-house
analysis of the adequacy of the APCD's inventory for reactive
HC and PM. If indicated, the APCD will begin a multi-year
effort to improve the inventory working closely with the EPA
and the ARB on priorities. EPA will request R&D or other con-
tractual study of transport from LA and insure involvement of
SCAPCD.
New Source Review - Full authority for local control of new
sources should be delegated as quickly as possible. A time-
table is described in EPA's FY 1976 grants with ARB and the
SDAPCD.
-------
C - 24
Emission inventory (Data Handling) - This is a joint local/state/
federal effort to improve the APCD's data handling system to
allow routine access for modeling in support of AQMP and other
programs. It will probably mean installation of EIS/P&R soft-
ware and conversion of existing data to the new format. If
required, EPA will participate financially with grant and/or con-
tract assistance. ARE will also contribute resources to the
effort and coordinate with statewide data management system.
Air/Transportation Coordination - All agencies will continue the
current level of liaison with transportation planning (109 (j)).
EIS Review - All agencies will insist on a thorough treatment
of the air quality impact of any projects in the AQCR,
Air/201 Coordination - ARE and EPA will continue to work through
pre-certification liaison and the EIS/EIR mechanism to mitigate
air quality impacts of any expansion of treatment capacity in the
AQCR. The APCD will continue its current role.
Quality Assurance - This is primarily a state/local program to
standardize operation and calibration procedures. ARB will assist
the APCD to implement ARB-developed operation and calibration
guidelines.
In-stack monitoring - EPA will defer to the State program if
satisfactory progress is maintained.
STRATEGY
The oxidant problem is the most serious and challenging of San
Diego's problems and merits top priority. Programs which directly
reduce emissions should be implemented immediately. Further
definition of the oxidant and particulate problems (refinement
of the emission inventory) are also required. The APCD feels
that transport from LA (which definitely exists under certain
meteorological conditions) needs further study immediately.
EPA agrees that it must be addressed but sees it more as a
long term goal. A similar situation exists with respect to
Mexican emissions. In the long run, San Diegans will not support
highly restrictive controls which they feel are only necessary
to compensate for the excesses of others.
The institutional framework that has produced the Regional Air
Quality Strategy must be preserved and, if possible, integrated
with the "208" planning process.
-------
C - 25
. AQCR .#30-- SAN FRANCISCO BAY AREA
INTRODUCTION
The Bay Area is a major metropolitan center with a well
defined, dense urbanized core surrounded by low density
residential suburbs. Older suburbs are developing indi-
vidual financial/commercial centers as they mature. The
AQCR has 4 million residents, or about 23% of the state
population. The Bay Area APCD does not control all of
the area included in the AQCR since Northern Sonoma and
Eastern Solano counties are controlled by other agencies
in accordance with the ARB's air basin boundary amendments.
The area has air quality violations of the oxidant and
carbon monoxide standards. There have been historical
violations of the S02 standard, although they were related
to specific industries which have since discontinued opera-
tion; S02 remains a significant issue with the prospect
of fuel switching and curtailment of natural gas supplies.
Current EPA contracts should provide guidance on further
S02 control efforts. The BAAPCD reports to EPA on 106
major stationary souces in the district.
PROBLEM
Oxidant;
The region experiences widespread, significant oxidant standard
violations with occasional Stage I episodes in the South Bay
Area. Some stations reported more than 400 violations of the
one hour standard during 1974 with the maximum value being 3.4
times the standard. Of the 25 stations reporting in 1974 ARB
data, only one demonstrated attainment; the monitoring system
is judged adequate to characterize the problem.
Carbon Monoxide;
Areas of the Bay Region do experience violations of the 8-hr
CO standard. These are local conditions. Monitors at Burlingame,
San Francisco, San Jose and Vallejo showed more than one ex-
ceedance during 1974. San Jose and Vallejo have the most
significant problem with over 20 days of violation reported
in 1974.
-------
C - 26
Nitrogen Oxides;
The AQCR is apparently not in violation of the annual arithmetic
mean standard, however, NOx control is part of the oxidant con-
trol program. Violations of the 24-hour State standard (N02
0.25 ppm) were recorded at Redwood City, San Jose, San Leandro
and Sunnyvale in 1974.
Sulfur Dioxide;
The AQCR has apparent attainment of this standard. Due to the
likelihood of natural gas curtailment and attendant switching
to fuel oils with higher sulfur content, the AQCR was designated
an AQMA for S02.
Particulate;
The AQCR is in technical compliance with this standard as the
annual geometric mean reaches within only a couple micrograms
per cubic meter of the annual geometric mean standard. The
problem of maintenance is at issue with the prospect of natural
gas curtailment and the combustion of particulate forming fuels.
The AQCR was designated an AQMA for particulate.
GOALS
Eighteen month;
Encourage and actively support comprehensive regional
environmental planning providing for the attainment and
maintenance of air quality standards. [Environmental
Management Task Force jointly with and including the Bay
Area Air Pollution Control District].
Advance, support and enforce available technological con-
trols to ensure appropriate levels of control of new or
existing stationary sources.
Support and oversee development of an accurate and updated
data base.
Five Year;
Oversee implementation of Environmental Management Plan,
approve AQMP elements as revisions to applicable SIP.
-------
C - 27
PROGRAMS
Vapor Recovery (hydrocarbon/oxidant) :
The local effort should be supported through §105 grant
funds if requested. The vapor balance system being im-
plemented can be upgraded to vacuum assist should the
increase in capture appear to be significant and cost-
effective considering the long lead time required to
implement it. To require vacuum assist now would delay
existing efforts for a year while regulations are amended
to match an EPA promulgation.
Other Organics (hydrocarbon/oxidant):
The existing program for hydrocarbons control should be
reviewed to check for exemptions of significant sources.
Such a regulation review should be performed jointly by
the ARE, BAAPCD and EPA. Should the district not act
to upgrade a weak regulation the State would be in a
position to adopt appropriate regulations. The program
grant will be employed to provide timely ARB/BAAPCD
cooperation. The results of this program are to be fed
into the inventory/baseline requirements of the EMTF (AQMP).
Energy Coordination (sulfur dioxide, particulate):
In most respects this program will be aimed at mitigating
the impacts of natural gas curtailment and educating the
public as to the consequences of fuel allocation programs.
Through the §105 grant the BAAPCD should be encouraged
to consider regulations for S02 emissions from all fuel
oil burning sources specifying an emission limitation and
providing for both annual update, reporting (of percentage
of time fuel oil was burned, etc.) and requiring appropriate
monitoring to detect violations of the standards. [The
current approach by the district has been to consider
sulfur content regulations, however, this approach assumes
an adequate, economical supply of 0.5 sulfur fuel oil which
is not necessarily going to be the case. The district has
estimates that fuel oil of up to 4% sulfur may in fact be
all that is available.]
-------
C - 28
The EPA role in this program should begin with projections
of the S02 impact potential should all interruptable cus-
tomers be curtailed with varying percentages of sulfur fuel
oils being available. Proper preparation and distribution
of these results through the Office of External Relations
could aid in building public support for allocation of
natural gas based on impact. EPA should also testify on
the impacts of natural gas curtailment at FPC, FEA, and
PUC public hearings to insure that the issue is properly
presented to those decisionmakers.
Fuel Additives (hydrocarbon/oxidant, carbon monoxide):
This is a program funded by EPA headquarters through a
statewide contract to ARE which provides for 2500 in-
spections for a FY'77 budget of $44,000. It is an important
program in terms of preserving the efficacy of the catalytic
devices in use, but requires no local and little or no
Region IX funding or effort.
Transportation Coordination/EIS Review:
As in other AQMA's EPA should remain active in reviewing
the efforts of other Federal agencies. The baseline re-
view criteria is a zero net increase in emissions resulting
from project construction and operation. [This criteria
is consistent with that used in New Source Review and
recommended for 201 facility Air/Water coordination.] Im-
plementing this program shall be through coordinating with
the Interrnodal Planning Group by commenting on the Overall
Work Program. Further EPA shall comment to FHWA as required
during the §109 (j) consistency review process. Comments
to the IPG and FHWA shall be made utilizing whatever con-
tribution is possible from the EMTF, thus providing EMTF
with a conduit to these important transportation decision
points.
EPA Compliance Verification (hydrocarbon/oxidant):
EPA should ensure that all major point sources are in CDS
and are being followed by the district. Emphasis should
be on sources of hydrocarbons. This effort would be on-
going in order to pick-up any sources included in the
program following any regulatory changes found necessary and
after review of existing regulations. EPA to commence the
-------
C - 29
process by requesting a justification as to why all
reported NEDS sources are not included in CDS. EPA will
oversee the district program by inspection of selected
sources.
EPA's role will include compliance verification for Federal
facilities. Of specific note in this area are the unknown
emissions from jet engine test cells and jet fuel dumping
during simulated emergency conditions. An effort will be
pursued to identify the magnitude of these emissions and
include them in the inventory.
State/Local Compliance Verification (hydrocarbon/oxidant):
The major compliance verification effort remains a State
local responsibility, reporting their progress through
C.D.S. Since this is essentially a part of the basic
program the §105 grant would provide specific funding for
inspection of hydrocarbon sources only.
Air/Water Coordination - 201/208:
Most of the major regionalizations under the construction
grant program will be granted within the next 19 months.
EPA's position with regard to these facilities should be
consistent with its position on similar actions [New Source
Review, 109j consistency, EIS comments, etc.], that is,
that the operation of the facility (secondary impacts in
this case) not result in a net increase in emissions. This
policy would have a direct effect on the issuance of grants
to those future projects prior to completion of the AQMP
(Environmental Management Plan) and to those projects not
yet past the final EIS stage. While this step does not, of
itself, directly reduce emissions and thereby improve air
quality, it would preserve options for AQMP and 208 planning
to improve air quality/reduce population exposure through
planned decisions for amount, location and phasing of
increased capacities. For comments on 208 see AQMP.
AQMP (oxidant, sulfur dioxide, particulate):
In this AQMA, the AQMP task force has been combined with
the 208 citizens advisory group to form the Environmental
Management Task Force (under ABAC1s Regional Planning
Committee) which will carry out both functions. The
significance of the merger has been emphasized as a national
-------
C - 30
precedent and should continue to receive EPA support.
The mechanism for support is twofold. The §105 grant
to ARE can embody funds to be 'passed through1 for tasks
required by the EMTF for AQMP needs. Similarly the §105
grant to the BAAPCD should provide for its policy repre-
sentation, guidance, technical assistance, staff liaison
and staffing commitment to the EMTF. Direct EPA support
through staff assistance will continue through the double
representations of one air staff member and one water staff
member, thereby insuring a consistent, unified EPA voice
to the EMTF.
Instack Monitoring:
This program will be of benefit in terms of monitoring
emissions from power plants and certain refinery processes
for NOx and S02. The mechanism is through straight Fed-
eral Regulation. The results of this program will support
the EMTF (AQMP) effort as well as efforts to improve the
inventory. It may provide a way of verifying compliance
(or provide basis for enforcement actions) for major source
of these pollutants.,
Imported Auto:
The Bay Region is a major port involved in offloading
imported vehicles. Currently headquarters has an agreement
with Customs to inspect these vehicles for compliance with
Federal requirements. The regional office has no role in
this program and should make sure that staff know proper
referral agencies.
New Source Review:
This program is not specifically mentioned since the ARE
is providing consistent NSR regulations and procedures
statewide. The BAAPCD regulations will either be found
equivalent to the State regulation or the State will adopt
regulations for the district.
STRATEGY
The operating principles in the AQCR are to continue po-
tentially productive planning efforts, support measures
contributing directly to emissions reductions and to avoid
administrative disagreement with local agencies over levels
-------
C - 31
of control attainable by programs unless the discrepancy
becomes significant. Enforcement activity will be pri-
marily aimed at controlling emissions from hydrocarbon
sources, beginning with a joint review of existing regula-
tions and carrying through to enforcement against sources
that are out of compliance. Enforcement against sources
of pollutants not currently in violation of standards will
have a lower priority. Review of EPA actions unrelated to
air programs, EIS reviews, transportation plans, etc.
shall be uniformly judged against a 'no net increase in
emissions' criteria.
* See Errata for additional program narrative on
Quality Assurance and Emissions Inventory Develop-
ment
-------
ERRATA
FY-77 REGIONAL AIR STRATEGY
AQCR £30 - SAN FRANCISCO BAY AREA
Quality Assurance (all pollutants): This is primarily
a State and local program (both State and local agencies
operate air monitoring netv;orks) . The State is implementing
a Quality assurance program statewide. EPA's primary
role is to provide guidance and perform audit checks to
assure validity of the data.
Emissions Inventory Development: Like many other high
priority programs, this must be a cooperative effort. The
local agenc'- would have primary resnonsibilitv for improving
their data base. The improved data base will be instrumental
in assisting both AQMP and. Hew Source Review decisions. Owing
to the large volume of data involved, and the anticipated
need for areav;id.e modeling, improvements to the District's
data handling capability seem to be indicated. EPA grant and/or
contractual support will supplement non-Federal resources.
ARE is to coordinate the overall State effort, resolve
technical issues (selection of industrial categories, for
example) and help set priorities. TOP priority should be
given to stationary sources of HC, followed by PM, S02, NOx,
and CO.
AQCR #31 ~ SAN JOAQUIN VALLEY
Emissions Inventory Development: Like many other high priority
programs, this musVbe a cooperative effort. The local agencies
would have primary responsibility for improving their data base.
The improved data base will be instrumental in assisting both
AQMP and New Source Review decisions. Kern and Fresno counties
may have to improve their data handling capabilities bv installing
the EIS/P&R system. EPA grant support will supplement non-
Federal resources. ARE is to coordinate the overall State
effort, resolve technical issues (selection of industrial
categories, for example) and help set priorities. TOP priority
should be given to stationary sources of HC (the reactivity
issue must be resolved) followed by CO and PM.
-------
C - 32
AQCR * 31 - SAN JOAQUIN VALLEY
INTRODUCTION
The San Joaquin Valley covers the area from the crest of
the Coastal Range to the midline of the Sierra Nevada.
from San Joaquin County on the North to Kern County on
the South. The ARE has split out some of the northern
foothill and mountain areas into the separate Mountain
Counties Air Basin which extends North into the
Sacramento Valley AQCR. Development is found in a string
of medium sized metropolitan centers generally following
the alignment of U.S. 99. Many smaller communities are
distributed around the valley serving the agricultural
community. The AQCR contains 1.74 million residents.
The air quality is persistantly in exceedance of the
oxidant and TSP standards. Some urban areas experience
CO violations. Enforcement receives reports on 347 point
sources in the AQCR.
PROBLEM
Oxidant problem is persistant, pervasive and significant.
Three" stations violated the 1 hour standard more than 100
days. Kern County recorded a stage I episode during 1975.
The data base is acceptable for strategy development.
Sources are mainly vehicle related with more work necessary
to accertain oil field emissions.-
GOALS
Eighteen month:
Support local implementation of programs having direct
effect of reducing emissions of problem pollutants.
This does not include particulate matter since the
problem appears to be non-point source generated.
Support State/local planning, particularly AQMP as
the favored program for providing attainment and
maintenance. State program equivalent to Prevention
of Significant Deterioration should be supported.
5 Year:
Support implementation of AQMP and equivalent of P.S.D,
-------
C - 33
Carbon Monoxide violations of the 8-hour standard, have
been found at four of the five monitoring station
(Bakerfield (79) , Modesto (2), Stockton (28) and Visalia
(23)). The data is acceptable and identifies a wintertime,
vehicle related urban problem.
Particulate violations of the annual geometric mean
occurred pervasively over the valley with three station
exceeding the 24 hour primary standard more than once
(Bakerfield, Fresno, Kern Refuge). Agriculturally reated
fugitive dust appears to be the major cause of the parti-
culate problem; none appear to be specifically associated
with major point source problems.
GOALS
PROGRAMS
Vapor Recovery (hydrocarbon/oxidant)
Several districts adopted Phase I V.R. under the FY-75
program grant. While the overall effort should be state
responsibility EPA will continue 'to support Phase II in
funded districts. ARB will support the program in metro-
politan areas on the valley floor with foothill implement-
ation being a lower priority. The State's effort will be
supported as there are doubts whether EPA's effort to
expand the areal scope of the program would be accompanied
by significant decreases in emissions.
Other Organics (hydrocarbon/oxidant)
A joint EPA, ARB, local review of regulations will be con-
ducted in order to see if currently exempt sources are
significant. The effort can be supported by inventory im-
provement in such areas as oil-field emissions. Solvent
controls are adopted by EPA-funded districts, the State
should insure that all districts have equivalent regulations;
this can be accomplished by a grant objective in the State.
Quality Assurance (Oxidant, CO)
CO data for the AQCR is acquired by relatively few mointors.
EPA site visits should be conducted to see that available
instruments are properly located, exposed, and operated.
Evaluation of the adequacy of the network itself may be an
output of the AQMP effort. - -
-------
C - 34
State/Local Compliance Verification (hydrocarbon/oxidant, etc.)
This is the major mechanism for assuring source compliance
with existing regulations. Since it is a part of the basic
program conducted by districts; EPA will provide funding for
inspection of sources contributing to the hydrocarbon/oxidant
problem.
EPA Compliance Verification (hydrocarbon/oxidant)
This an overview of local efforts conducted by EPA personnel
of 10% of the sources. Since most sources in this AQCR are
particulate emitters and work is also scheduled to review
the hydrocarbon regulations, this program should be directed
principally at hydrocarbon sources for which there are rules
now and will be included under new rules as they are adopted.
Air Quality Maintenance Planning (oxidant, particulate)
There are three areas in the AQCR that are identified as Air
Quality Maintenance Areas. The progress in these areas has
been relatively slow. Continued support through funding
by 'pass through' to ARB and by direct §105 funding to con-
cerned APCDS should be provided. The reluctance on the part
of local agencies, officials and the public may well be
traced to a low public awareness of the costs of air pollution.
A State or EPA Public Relations effort highlighting the cost
of agricultural crop damage may be beneficial.
Prevention of Significant Deterioration
The State has not accepted the EPA PDS program and is in the
process of developing a concept using Air Conservation Areas
which would apply to all criteria pollutants. Whichever
program the State ultimately endorses and implements should
receive EPA policy support.
Air Transportation Coordination (hydrocarbon, CO)
This effort will continue through EPA participation as an
ad-hoc member of the Intermodal Planning Group, comments on
the D.O.T. Overall Work Program and advisory comments to
F.H.W.A. under Section 109(j) of the Federal Aid Highway Act.
AQMP task force comments should be solicited by EPA to en-
sure their involvement and eventual assumpation of the major
technical review task.
-------
C - 35
201 A/W Coordination
This effort will continue, especially in AQMAs. The effort
will be to involve the AQMP task forces and the ARB in
making the decisions necessary to insure intermedia consis-
tency.
EIS Review
Continue to offer comments on projects whose emissions will
further deteriorate or prevent attainment of the NAAQS.
Fuel Additives (hydrocarbon, CO)
The State is implementing this program under a contract
from EPA headquarters with small Region IX contribution.
This should continue.
STRATEGY
1. The major issue is consistency of programs throughout
the AQCR. The programs implemented in funded APCDs
have little regional impact if non-funded APCDs don't
have comparable regulations and implement them. This
requires close coordination with ARB in sharing the
the responsibility.
2. Coordination with BLM/Forest-Service/Park Service to
implement air conservation area scheme in mountain areas
or PSD whichever appears to be the most visable. At
this time the State's lack of interest in PSD and em-
phasis on their program would indicate that Federal
cooperation with the State, encourage by EPA, would
have benefits.
3. Long term programs (I/M, AQMP) have best chance of
achieving/maintaining NAAQS. These programs are slow
at present. AQMP is being received reluctantly.
Greater EPA emphasis/presence at Task Force meetings
might aid in convincing APCDS-local governments of
EPA's seriousness for these long term efforts.
* See ERRATA for additional program narrative
on Emissions Inventory Development.
-------
C - 36
AQGR #32 - SOUTH CENTRAL COAST
INTRODUCTION
This AQCR is located along the coast of central California,
north of Los Angeles, stretched between Pt. Conception in
the south and Monterey County in the north. The AQCR is
scenic and mountainous with roost of its 253,000 inhabitants
located in scattered valley population centers. Petroleum
production and refining (primarily associated with natural
gas fields in northern Santa Barbara County) and electrical
power production are the major industries of concern from an
air quality standpoint.
Since there are only 12 known major stationary sources in
the AQCR, the efforts of local control agencies are quite
low key. The Santa Barbara County APCD expends the vast
majority of its resources in the narrow strip of the county
south of the Santa Ynez Range that lies in the Los Angeles
Metro AQCR.
Geographically, the area has coastal areas suitable for
deepwater/offshore port development. Owing to the strong
protectionist sentiment of Santa Barbara, however, San Luis
Obispo County seems the more vulnerable of the two counties
to development pressures.
PROBLEM
NAAQS are attained for all pollutants except oxidants. All
four monitoring stations showed low-level violations in 1974.
The most serious was at Santa Ynez with 56 days in violation
and a maximum one hour concentration of .17 ppm. San Luis
Obispo had 11 days in violation and a .15 ppm maximum one
hour concentration (ARB data - non adjusted). The cause
of the problem is unknown. A refinery and a large gas field
in Santa Barbara may contribute significantly to the problem
there.
GOALS
The following goals are based on the problems outlined above.
Both short-term (18-month) and long-term (5-year) goals are
listed.
-------
C - 37
Eighteen-Month:
Work to improve the definition of the oxidant problem by
seeking to verify the accuracy of air quality data.
Providing the data is verified, improve the emissions
inventory for HC in order to determine the cause of the
oxidant problem.
Five-Year:
Continue to monitor trends in the apparent oxidant problem
and to determine its scope and its causes while building
local agency capability to deal with it.
Monitor the effects of any changes in fuel use at the
huge Morro Bay Power Plant in San Luis Obispo County.
Work to limit the introduction of additional emissions in
the AQCR as necessary to maintain NAAQS for CO, PM, SOX
and NC>2.
PROGRAMS .
The following programs are directed toward achieving the goals
outlined above.
New Source Review - EPA will carry out a thorough review
of new sources, particularly of HC, until the program
is delegated. Delegation, particularly for San Luis Obispo,
should be scrutinized by EPA and ARE to be sure they have
the technical capability to make the required analyses.
Quality Assurance - EPA will conduct site visits to analyze
the accuracy of oxidant monitoring data in the AQCR. This
will be done before taking any further action on the apparent
Ox problem. If the data is^not valid, no action will be
taken on the following two programs.
Emission inventory - Working with the APCD, EPA will perform
a brief in-house review of the existing emission inventory
for HC in northern Santa Barbara County to determine the
scope of any needed improvements. EPA will then ask the
APCD to make these improvements and will provide grant
assistance. This may be a 2 year effort.
-------
C - 38
EIS and 201 Coordination - If the oxidant problem is veri-
fied by EPA's site inspections, careful air quality analyses
of any growth related projects will be required by all
agencies.
State/local compliance verification - The ARE will report
to EPA quarterly on the status of major sources in the
AQCR. EPA will support the reporting effort with grant
assistance.
Prevention of significant deterioration - EPA will defer
to state action. If indicated, EPA will be involved in
low profile liaison with ARE in the classification of
portions of the AQCR as Air Conservation Areas.
Air/Energy Coordination - A joint State/local EPA review
of local regulations will be conducted to ensure that
they are adequate to cope with changes in fuel use.
STRATEGY
The apparent oxidant problem must be verified before further
action is taken. If it is real, its causes must be identified
and dealt with. Overall, the AQCR must be watched closely so
other problems can be prevented.
-------
AQCR # 33 - SOUTHEAST DESERT C - 39
INTRODUCTION:
The Southeast Desert AQCR is a vast, arid, thinly
populated area along the southeast border of California.
Rainfall is less than 4 inches annually, so population
centers and industry generally must depend on imported
water. Industry is scattered with only 20 known major point
sources operating in the AQCR.
The Region's population is fairly large at 661,000,
but tends to be scattered in moderate sized population centers.
The largest population centers are located at or near military
bases (China Lake, Edwards), resort areas (Lake Arrowhead,
Palm Springs) or irrigated agricultural areas (Imperial Valley).
On the surface there are two major'factors which hinder
progress on the AQCR's more serious air quality problem.
First, the key air control agencies in the AQCR tend to
concentrate on more severe problems elsewhere in their
jurisdictions. Second, a major share of the AQCR's oxidant
problem is imported. Fortunately, these problems tend to
cancel out, rather than compound each other. The efforts
of the Southern California APCD, the San Diego APCD and
the ARE are directed toward reducing the same emissions
which aggrevate problems in the Southeast Desert.
PROBLEMS:
NAAQS were violated for oxidants and particulate matter
in 1974. Oxidant concentrations more than triple the NAAQS
are regularly recorded in the Coachella Valley. These levels
are clearly influenced bv transport from the Los Angeles area.
Other lower level violations occur at Lancaster (.15 ppm maximum
for 1 hour, 75 davs), Victorville (.20 ppm, 108 days), Barstow
(.15 ppm, 64 days) and El Centro (.17 ppm, 50 days). Transport
is widely regarded as the most significant factor in all cases.
Particulate violations are widespread but are worst in
the Imperial Valley where readings more than triple the NAAQS
(Annual Geometric Mean) are recorded. With the exception of
Calexico, violations are conventionally blamed on agriculture
and fugitive dust. (Calexico is adjacent to some poorly
controlled point sources in Mexico.) In fact, however, there
is no data available to confirm this. Point sources may
contribute significantly to the problem in areas like El Centro.
(Note: The State standard for NO2 (.25 ppm-1 hr.) was
violated on 4 davs in Barstow, but nowhere else. The Federal
standard, which is an annual arithmetic mean, was not violated.)
-------
C - 40
GOALS:
The following short (18 month) and long (5 year) term
goals are based on the problems described above.
18 month
Local APCD's will continue to conduct routine programs
to control emissions from stationary sources.
EPA and ARE will maintain low profile surveillance of
infrastructure investments (examples: highways, airports)
which create development pressures in eastern Los Angeles
and central Riverside counties. Local agencies may be
asked for technical assistance on a case-by-case basis.
Begin development of a long-range plan to improve air
quality in the Coachella Valley. (See also the "Los Angeles
Metropolitan AQCR"i)
5 year
Overall, continue to assume that the solution to the
oxidant problem lies in the solution to the-Los Angeles
and San Diego problems.
Mitigate the adverse environmental effect of development
and population growth in areas like Palmdale and the Coachella
Valley, to be sure localized problems do not develop.
Achieve a better definition of the PM problem in the AQCR.
Initiate reasonable controls.
Monitor air quality trends in the AQCR to verify the
assumption that the Los Angeles and San Diego AOCR's are
responsible for oxidant problems in the Southeast Desert.
PROGRAMS:
The following programs are directed toward the accomolishmer.
of the short-term goals described above:
AQMP/208 planning: EPA and ARE will use the AQMP process to
involve local government in the Coachella Valley area in long-
term planning. As the plan develops, it will probably be
necessary to quantify the contribution of local sources to the
Valley's air auality problems. AQMP will be largely a local
effort with ARE oversight and EPA grant support.
-------
C - 41
201 Coordination; EPA and ARE will work with State and
local agencies to ensure that 201 projects do not contribute
to the deterioration of air quality in sensitive areas.
EIS Review; All agencies will carefully review projects
which promote growth and development in order to mitigate
adverse air aualitv impacts, particularly in the Palmdale/
Lancaster area of Los Angeles County where there is no
long-term planning effort (AQMP) to consider air quality
problems.
State/Local Compliance Verification: Local agencies will
determine,and the Air Resources Board will report,con the
compliance status of major sources quarterly. Reporting
will be funded by the EPA via the grant mechanism.
Air Monitoring; EPA will continue to insist on routine
monitoring in order to track trends. Over a 3-year period,
EPA will analyze trends in-house to determine if the trend
in oxidant concentrations is consistent with that of the
Los Angeles Metropolitan AOCR. If oxidant concentrations
remain high, all agencies will need to look more closely
at the emissions inventory to determine the cause.
STRATEGY:
Transport from Los Angeles is obviously a major factor
in the high oxidant levels experienced in the AQCR. The
basis of the EPA strategy is that the solution to the
Los Angeles oxidant problem will also be the solution for
the Southeast Desert. Since the PM problem appears to be
related to fugitive emissions, there are no short-term
programs to deal with it other than routine surveillance
of major stationary sources.
-------
REGIONAL AIR STRATEGY
REGION IX
ENVIRONMENTAL PROTECTION AGENCY
Geographic Narrative on the
Air Quality Control Region(s)
for the State of
Guam
March, 1976
-------
j REGIONAL AIR STRATEGY
\
1 REGION IX
ENVIRONMENTAL PROTECTION AGENCY
Geographic Narrative on the
Air Quality'- Control Region (s)
for the State of
Guam
March, 1976
-------
TABLE OF CONTENTS
FOR - ,
GUAM
FY-77 REGIONAL AIR STRATEGY
Section " Page
I. General Introduction 1
II. Basic Program . BP-1
III. Narrative "-
AQR 4.246 - Guam _. ~ .. G-l to G-3
-------
G - 1
AQCR #246 - GUAM
INTRODUCTION
Guam is a small Pacific island characterized by a
hot and humid climate, heavy rainfall, steady trade winds,
and fairly even terrain except for a few small hills in
the southern part of the island. The population (1970:
86,926) clusters in towns and villages and in the Air
Force and Naval bases.
The air pollution problems are stationary source
and fugitive dust related. Four steam generated power
plants use high sulfur fuel and consequently violate
sulfur dioxide standards. It is believed that the particulate
violations are due both to such man-made activities as
construction and unpaved roads.
PROBLEM
Based on 1974 data from the approved monitoring network,
it appears that particulate matter is in violation of the
primary national ambient air quality standards in Guam.
Special spot sampling indicates that sulfur dioxide is
in violation as well. ' . ' '
Particulate:
The island has one monitoring station which violated
the primary annual geometric mean several times in 1974,
with values as high as one and one-half times the standard.
Fugitive dust and the power plants are believed to be the
pollution sources.
Sulfur dioxide;
The power plants all burn high sulfur fuel (2.75 -
3.2%). Spot sampling indicates localized high sulfur dioxide
levels, reaching four-five times the primary twenty-four
hour standard.
GOALS
These goals were selected since they represent the best
possible effort toward attaining the sulfur dioxide and
particulate matter standards. We have grouped the goals
according to those which can be reached within the next
eighteen months and those achievable within five years.
Eighteen month:
Resolve sulfur dioxide attainment issue through the
-------
G - 2
upcoming court decision on power plants.
Insure local surveillance of major stationary sources
and compliance with revised particulate and sulfur
dioxide regulations.
Insure operation of the particulate and sulfur dioxide
netv;ork in accordance with proper quality assurance
practices and procedures.
5 year:
Prevent stationary source violations for particulate
and sulfur dioxide.
PROGRAMS:
Compliance Verification:(particulate, sulfur dioxide):
GEPA will verify compliance of the six major stationary
sources annually. EPA will support this effort through
the 105 grant.
Isolated Point Source (particulate," sulfur dioxide):
-GEPA has revised the particulate regulations, and
designed a control strategy demonstrating attainment-^.
The revision is awaiting Gubernatorial approval prior to
submittal to EPA as an SIP revision. EPA executive liaison
will be used to encourage final Guam approval of the
regulations.
The current sulfur dioxide regulations are not
approvable by EPA unless Guam requests an extension in
the attainment date for this pollutant. We recognize
Guam's concern about the economic infeasibility of requiring
permanent controls or low sulfur fuel at this time.
After the court decision regarding New^Source Performance
Standards and the Cabras power plant, EPA will work with
Guam in designing an acceptable strategy dealing with
sulfur dioxide.
Ambient Monitoring/Quality Assurance;(particulate,sulfur dioxL
GEPA will be encouraged to follow accepted quality
assurance practices and procedures for sampling and analysis,
especially for the continuous sulfur dioxide instrument
located at the maximum .concentration sites. EPA will
support this effort through the 105 grant.
-------
G - 3
Emergency Episodes (sulfur dioxide):
Until the Cabras court decision is made, GEPA will
maintain this program minimally because of the potential
for high sulfur dioxide build-up under certain meteorological
conditions. The necessary regulations and use of power
plant reduction plans will be enforced. The plan will be
reevaluated, if necessary, after the court decision.
STRATEGY
Our strategy in air pollution control for Guam will be to
encourage GEPA to assume most responsibilities. Since
GEPA has indicated a low priority for air, we can assume
the number of responsibilities carried will be few. EPA
will continue to support one State assignee and contribute
to the air pollution program through the consolidated
grant in order to keep the program going. In summary, GEPA
will condinue to send EPA SAROAD, NEDS and CDS data, to
conduct compliance verification inspections and to operate
an air monitoring program with adequate levels of Quality
Assurance.
-------
REGIONAL AIR STRATEGY
i
\, REGION IX
ENVIRONMENTAL PROTECTION AGENCY
Geographic Narrative on the
Air Quality Control Region(s)
for the State of
_ . . . Hawaii
March, 1976
-------
TABLE OF CONTENTS
FOR
HAWAII
FY-77 REGIONAL AIR STRATEGY
Section Page
I. General Introduction 1
II. Basic Program - BP-1
III. Narrative
AQCR #60 - Hawaii _ H-l to H-3
-------
H - 1
AQCR #60"-" HAWAII
INTRODUCTION
The Hawaii AQCR is an eight (major) island archipelago
with strongly contrasting land forms which range from
mountains, broad valleys, deserts to sandy beaches. Ambient
temperatures remain fairly constant throughout the year.
Rainfall varies throughout the islands, dependent more
on location and elevation than season. Steady tradewinds
from the northeast regularly sweep the islands clean of
pollutants. The winds, plus the absence of large-scale
industrial development have kept Hawaii free from large-
scale air pollution problems.
Intensive use of the automobile in Honolulu has
generated a carbon monoxide problem in the city. Hawaii's
population (1970; 769,913) tends to cluster in urban centers
like Honolulu, with the balance of the inhabitants spread
throughout the largely rural"agricultural areas that embrace
the cities. Most air pollution problems in the rural areas
are of a localized nature, for example, burning of cane
fields and power plants.
t
PROBLEM ... . " '." " " - '. '
/Based on 1974 data from the approved monitoring network,
it appears that particulate matter is in violation of the primary""
ambient air quality standards in Hawaii. Special mobile
monitoring indicates sulfur dioxide is in substantial
violation of national standards.
Particulate; Fugitive dust is believed to be the chief
cause for violations, which are low level. The primary
annual geometric mean and primary second highest twenty-
four hour value were well within standards for fourteen of
the fifteen stations.
Sulfur dioxide; Special temporary monitoring near two
power plants, Kahi on Oahu and Kahului on Maui, indicates
violations four-five times the primary twenty-four hour
standard. Based on data from permanent sulfur dioxide
monitors, the sources are not in violation, but it is
believed this is due to the location of monitors away
areas of maximum concentration.
-------
H - 2
GOALS
These goals were selected because they represent
the best effort tov/ard attaining the sulfur dioxide
standard, attaining and maintaining the carbon monoxide
standard, and preventing degradation of air quality for
particulate matter. We have grouped the goals according
to those which can be reached within the next eighteen
months and those achievable within five years.
18 month:
Build up the stationary source inspection and compliance
enforcement capability of the Department of Health.
Define clearly the extent and magnitude of the carbon
monox'ide problem, confirming its nature as hot spot or
areawide.
Issue final sulfur dioxide regulations for the Kahi
and Kahului power plants.
5 year:
Prevent stationary source violations for all criteria
.pollutants.
Develop and enforce a carbon monoxide attainment and
maintenance program.
PROGRAMS
Compliance Verification (particulate matter, sulfur dioxide)
The State will conduct visible emission observations and
some in-depth inspections of all 65 major stationary sources.
EPA will support such efforts through 105 grant support.
In addition, EPA plans a mid-year visit to conduct (1) an
audit of the State's compliance verification program and
(2) joint inspections with the State concentrating on
sugar mills and federal facilities.
Isolated Point Source/Ambient Monitoring (sulfur dioxide)
EPA will design and set a contract to gather and
analyze the sulfur dioxide from the two power plant sites
to confirm the magnitude of sulfur dioxide violations.
The State will then promulgate final regulations.
-------
H - 3
Ambient Monitoring (carbon monoxide)
The State will operate a temporary monitoring system
to collect meteorological and carbon monoxide data both
in Honolulu, and in various locations outside the city.
EPA will support the State through the 105 grant program.
The data will be used in reviewing new sources and in
evaluating long-range land use and transportation planning.
Air/208 (particulate matter)
The 208 grant will encourage establishment of procedures
to integrate air quality planning activities of the State
with the 208 plan development.
STRATEGY
We recognize that annual or more frequent visits
by EPA cannot substitute for permanent state presence.
With the 105 grant and contracts, plus a mid-year visit
by the Surveillance and Analysis Division personnel, we
will support a minimum state presence. EPA will encourage
development of sound, fundamental source surveillance and
enforcement skills, and ambient monitoring talents of
State staff.
-------
REGIONAL AIR STRATEGY
| REGION IX
ENVIRONMENTAL PROTECTION AGENCY
Geographic Narrative on the
Air Quality Control Region (s)
for the State of
Nevada
March, 1976
-------
« REGIONAL AIR STRATEGY
I
\
\ REGION IX
ENVIRONMENTAL PROTECTION AGENCY
Geographic Narrative on the
Air Quality Control Region(s)
for the State of
Nevada
March, 1976
-------
TABLE OF CONTENTS
FOR
NEVADA
FY-77 REGIONAL- AIR STRATEGY
Section Page
I. General Introduction .. 1
II. Basic Program BP-1
III. Narrative for Nevada AQCR's
AQCR §13 - Clark-Hohave N-l to N-5
AQCR #147 - Intrastate N-6 to N~7
AQCR §148 - Northwest Nevada N-8 to N-1C
-------
N - 1
AQCR #13 - NEVADA CLARK - MOHAVE
INTRODUCTION
The Nevada portion of the Clark-Mohave AQCR, whose
boundaries are contiguous with Clark County, is characterized
by a semi-arid climate and varying terrain, ranging from
desert basins to mountain peaks. The Las Vegas metropolitan
area lies in a large bowl surrounded by mountains and is
subject to inversion conditions, particularly in the fall-
winter months. The population (1970: 273,300} concentration
is in Las Vegas and the nearby communities of North Las Vegas,
Henderson, and Boulder City.
Due to the sprawling low density nature of urban
development and the reliance on automobiles for transit, the
air pollution problems are predominantly mobile source
related. Most of the fifty stationary sources are known to
be in compliance with existing emission standards. Some
problems remain with certain industrial processes (chlorine
and similar compounds) located near Henderson.
It is suspected that the particulate violations are due
to such manmade activities as construction and unpaved roads.
PROBLEM . '"."/""
Based on 1974 data from the approved monitoring network, .
it appears that carbon monoxide, oxidant, and particulate
matter are the three pollutants in violation of the primary
national ambient air quality standards in Clark-Mohave.
Carbon monoxide; Data from the two permanent stations posted,
respectively seventy-two and sixteen violations of the eight-
hour standard in 1974. Second highest readings were 1-1/2 times
the standard. Near episode levels are reached occasionally;
for example, during this winter, carbon monoxide levels were
above 2-1/2 times the eight-hour standard.
Since the carbon monoxide network has been fully
operational for only two years, no trend analysis has been
performed. The violations are believed to be localized_in
areas such the length of the "Strip".
Based on an inventory completed in February, 1975, the
majority of emissions are mobile source related.
Oxidant; Data from two permanent stations indicate a moderate
oxidant problem, albeit a peculiar oxidant jtrend. In 1974,
the second highest one-hour reading was twice the standard.
The monitors posted forty-two and one hundred ninetv one-hour
violations, respectivelv.
-------
N - 2
The trend of -oxidant violations over the r>ast four
years has been substantially downward. The number of
violations in 1972 was 1500; in 1973: 775; 1974: 192;
and in 1975: 29. The magnitude of the one-hour violation
has remained the same, vet VMT has risen steadily. A
satisfactorv exnlanation for the contradictory evidence
has not been found.
Based on the February, 1975 inventorv, the majority of
reactive-hydrocarbon emissions are mobile source related.
Particulate: The primary annual geometric mean (AGM) and
second highest twenty-four hour value were well within
standards for thirteen of the twenty particulate stations.
Data from six additional stations was slightlv over the
AGM and 24-hour standard. Only one station posted readings
up to 1-1/3 times the AGM and 24-hour standard.
An inventory currently under construction will help
define the nature of the particulate problem.
GOALS
These goals were selected because thev represent the
best effort toward attaining and maintaining the carbon
monoxide, oxidant, and particulate standards. We have
grouped the goals according to those which can be reached
within the next eighteen months and -those achievable within
five years.
eighteen month
Develop and enforce an oxidant control program that
embraces vapor recovery and areawide transportation
planning coordination.
Improve the carbon monoxide control program by upgrading
the Inspection-Maintenance program, and. continuing
areawide transportation planning coordination.
Prevent stationary source violations, stressing
particulate, carbon monoxide, and hydrocarbon sources.
five year
Broaden the oxidant control program to cover vapor
recoverv, State II, and possibly organics.
Prevent stationary source violations for all criteria
pollutants.
-------
N - 3
PROGRAMS
Vapor recovery (oxidant): The Clark County District Health
Department (CCDHD) will develop and enforce regulations to
implement State I vapor recovery, which covers transfer from
delivery trucks to gasoline station?:storage tanks. These
regulations will apply immediately to new stations and to
existing stations through two-year retrofit. EPA will assist
this effort through the 105 grant and will promulgate local
regulations as part of the SIP.
Organics (oxidant): CCDHD will survev paint manufacturers ,
dry" cleaning, degreasing, and architectural coating firms
to understand the magnitude of their hydrocarbon contribution.
No regulations will be developed at this time. EPA support
will be via the 105 grant.
Ambient monitoring/quality assurance (oxidant, particulate,
carbon monoxide):In association with EMSL, CCDHD will
continue its auality assurance program for its air monitoring
network. In addition, CCDHD will attempt to assess the
unexplained trend in ambient oxidant levels. 105 grant support
will be provided.
Inspection/Maintenance (carbon monoxide; ox-idant) : The
existing program run-_-5v the Department of Motor Vehicles covers
only change-of-ownership vehicles. Toward possible amendment
of the I/M program, EPA will contract for a study that examines
the cost, management, and air quality benefits of the current
program and recommends means to improve the I/M program. EPA.
will work with the Environmental Commission, the State
Department of Human Resources, and thecCDHn i-n designing a
contract whose results will satisfy the 'information reauirements
of the Nevada Legislature.
Indirect source review (carbon monoxide): Program will be
operated by CCDHD until January, 1977, when state statutorv
authority for indirect source reviews will expire. EPA
grant assistance will be provided.
Air Quality Maintenance Planning/208 (oxidant, particulate
matter,carbon monoxide):CCDHD will analvze the designation
of the Las Vegas AQMA for carbon monoxide, particulate matter,
and oxidant consistent with the requirements of 40 CFR 51.40 -
51.51. In addition, the CCDHD will review the PEDCO contract
results which examined fugitive emissions and will adopt/amend
local regulations to control emissions from agriculture,
unpaved roads, construction, playgrounds, parking lots, and
the like.
CCDHD will implement the public education campaicn whose
groundwork was laid in FY-76. In addition, a local citizens
-------
N - 4
advisory group will be developed, possibly dovetailed with
the 208 citizen advisory group, to use as political means to
support such control measures as vapor recovery, instack
monitoring, and revision of old/development of new regulations.
Control measures proposed would be sieved through such a task
force prior to their formal proposal.
EPA will assist the AQMP effort throughboth assignment of
an individual to the Health Department through the Interagencv
Personnel Act and the 105 grant.
CCDHD will be paid by the 208 grantee to oversee the
secondary impact analvsis of the 208 plan.
Non-criteria pollutants (chlorine): An investigation of the
fugitive emissions associated with point sources in Henderson
is warranted. EPA will support such an investigation through
contractual assistance, possibly- through EMSL. A scope of
work will be designed jointly by CCDHD and EPA.
Instack monitoring (oxidant, particulate): CCDHD expresses
support for the concept of continuous monitoring and is willing
to develop eauivalent regulations. EPA_will support this
effort through the 105 grant.
Air/Transportation planning (oxidant, carbon monoxide): CCDHD
will continue to act as technical advisor to the Clark County
Area Transportation Policy Committee. EPA. will continue to
foster this sound relationship as requested and will perform
the annual 109 (j) consistencv reviews.
Compliance verification (particulate, carbon monoxide, oxidant):
CCDKD will inspect all major stationarv sources, and has
expressed willingness to inspect some minors. EPA will support
inspections of major sources of hydrocarbon and particulate
matter and CDS reporting through grant priority objective: the
balance of inspections supported through the basic program.
It is anticipated that there will not be an EPA joint inspection
overview for FY-77.
STRATEGY
Because the majority of carbon monoxide and hydrocarbon
emissions are auto-related, the CCDHD has in the past two
vears expanded its approach to air pollution control to
address mobile sources as well as stationary sources.
EPA will incourage this expanded approach and support
adoption of regulations and programs dealing with mobile
source related emissions. Because of the unexplained downward
trend in oxidant violations, it is not advisable to adopt
numerous, stringent hydrocarbon control regulations in FY-77
-------
N - 5
and expect easy public acceptance. Therefore, only Staae I
vapor recovery.will be adopted next year and an organic solvent
survey conducted.
Stationary source compliance verification will continue
as part of the basic program. Because EPA believes the
compliance verification program to be sound (unless a spring
1976 visit proves otherwise), it will eliminate any overview
function. Clark County will inspect major sources throughout
the fiscal year for compliance verification and will report
hydrocarbon and particulate source status to EPA through
CDS quarterly.
EPA will commit through contract, grant and executive
liaison work with the Nevada legislature to supnort indirect
source review and inspection/maintenance as carbon monoxide
control measures. If Congress breathes new life into indirect
source review in the Clean Air Act amendments, then the local
agency will ask for EPA assistance in ISR statutory extension.
If Congress kills ISR, the State and locals will wage the
battle alone, if at all.
Lastlv, EPA will support the AQMP effort in Clark Countv
through an IPA. assignment and the 105 .grant. A nublic education
program developed in FY-76 will be launched in FY-77 in a
low-key effort to raise consciousness about the definition and
meaning of the pollution problems in Clark County. A local
citizen task force will be developed to use as a political
in support of a variety of control pleasures. Finally, the
designation of the AQMA will be thoroughly analyzed and development
of an AQMP launched.
-------
N - 6
NEVADA INTRASTATE AQCR # 147
INTRODUCTION
The Nevada Intrastate AQCR is a huge, sparsely populated
(1970: 63,116) land mass cut by north-south mountain ranges
interspersed with valleys. Rainfall, temperatures, and even
economic activity vary considerably throughout the AQCR.
Elko (1970: 7,600), the largest town in the region, is one
of many settlements serving as economic centers for the
livestock, agriculture, and mining industries in the region.
The AQCR has particulate and sulfur dioxide problems. It
is believed that stationary sources are largely responsible.
PROBLEM
Based on 1974 data from the approved monitoring network,
it appears that particulate matter and sulfur dioxide are the
two pollutants in violation of the primary national ambient
air quality standards (NAAQS) in the Nevada Intrastate.
Sulfur dioxide; Violations, which exceeded the twenty-four
hour standard up to a factor of three, are caused by the
Kennecott copper smelter located in Ely. EPA's suit requiring
more stringent emission controls than either the smelter or
state felt were necessary is now moot since Kennecott has
decided to close the smelter.
Particulate; The primary annual geometric mean (AGM) and
second highest twenty-four hour value were both just above
standards for two of the twelve monitoring stations. Seven
stations' recorded no violations. The balance had violations for
either the twenty-four hour or AGM standard. The 1973
emission inventory for particulate attributes the majority
of particulate emissions to stationary sources as opposed
to fugitive dust.
GOALS
These goals were selected because they represent the
best effort toward attaining the particulate standard and
preventing degradation of air quality.
eighteen month and five year
Prevent deterioration of air quality by enforcing current
programs and revising regulations as needed.
-------
N - 7
PROGRAMS
Compliance verification: * The State will conduct compliance
verification inspections of the fifty major stationary sources
using._acceotable techniques. EPA will support such efforts
throuah 105 grant support. EPA also will conduct joint
inspections and will audit the State's compliance verification
program.
Instack monitoring; The State endorses the concept of continuous
monitoring and will adopt equivalent regulations. EPA will provide
105 grant assistance.
Indirect source review; The State v/ill conduct indirect source
reviews until its authority expires. EPA will support this
effort through the grant.
Prevention of Significant Deterioration (particulate,sulfur
dioxide) : " ~~ ~ ~~ ~
j^
The State will develop equivalent regulations and ^ J
request delegation of the program. EPA v/ill develop . : in
delegation procedures and support the State effort through § §
the 105 errant. " -H tr
4-> O
U-! M
The Itfevada legislature has ordered a study of the "ro
social and economic impacts of the existing power plant g &
regulations. EPA will offer contractual assistance to * K
the State in executing the study. In addition, if requested,
EPA will testify on behalf of the stringent State regulations
before the legislature in FY-77.
STRATEGY
The State's small environmental protection Division
traditionally has been oriented toward stationary source
compliance verification and enforcement. EPA will continue
to support this orientation through the 105 grant, overview
inspections, and an audit.
EPA will also support the ISR function via the grant
through the first half of FY-77. There are two reasons:
1) The ISR has served to modify (to the advantage of air
quality) the design of indirect sources built in the critical
Tahoe Basin and 2) EPA has a moral commitment to support
Nevada for six months since we persuaded them to adopt the
regulations in the first instance.
The State has expressed desire to broaden its activities
to include long-range air quality planning. EPA would support
service as technical advisor to the State Department of
Highways on transportation planning and to the local agencies for
AQMP and 208 planning.
-------
N - 8
AQCR #148 - NORTHWEST NEVADA
INTRODUCTION
The Northwest Nevada AQCR is marked by a seasonally
varied climate, desert and mountainous terrain, and varied
rainfall. The northern part of the AQCR is very sparsely
settled; most of the population is found in valleys, which
accomodate small towns, and large cities such as Reno-Sparks
(1970: 97,100) and Carson City (15,500). A large Paiute
Indian tribe lives on a reservation north of Reno near a
large lake (Pyramid Lake).
Reno-Sparks, which lies in a large north-south valley
known as Truckee Meadows, has a confirmed particulate problem
and an emerging carbon monoxide (and possibly oxidant) problem.
PROBLEM
Based on 1974 data from the approved monitoring network,
it appears that particulate matter and carbon monoxide are in
violation of the primary national ambient air quality standards
(NAAQS) in Northwest Nevada. Data from an air quality study
contracted by the Nevada Department of Highways will be
formally released in early spring, but information received
to date indicates the Study found carbon monoxide and possibly
oxidant to be in violation of the NAAQS.
Particulate; The primary annual geometric mean and second
highest twenty-four hour value were two-four times the standards
for four of the nine permanent particulate monitors. Data
from two additional stations indicates violations of the AGM
just above the standard. The suspicion that fugitive dust
is largely responsible for the particulate problem is being
explored-and. confirmed by an emission inventory due in June,
1976; the contract will also characterize the nature of the
fugitive dust and mitigation measures.
Carbon monoxide; The second highest eight hour values were
slightly "above the.standard for the carbon monoxide monitor
located in Reno. An emission inventory is scheduled for
completion April, 1976.
GOALS
These goals were selected because they represent the
best effort toward attaining the particulate standard and
drawina up a plan of action to address the carbon monoxide
(and oxidant) problem. We have grouped the goals according
to those which can be reached within the next eighteen
months and those achievable within five years.
eiahteen month
*
Ensure the quality of data from the carbon monoxide
and oxidant stations.
-------
N - 9
Develop a carbon monoxide control program, beginning
with an AQMP designation for CO.
Implement where possible the particulate control
measures outlined by contract.
five year
Develop and enforce an oxidant attainment and maintenance
program, if necessary.
PROGRAMS
Air monitoring/quality assurance (carbon monoxide; oxidant):
EPA "jointly with the Washoe County District Health Department
(WCDHD) will perform a formal audit of the carbon monoxide and
oxidant network, including side-by»side monitoring.
Indirect source reviews (carbon monoxide): Program will be
operated bv WCDHD in Washoe County until January, 1977, when
state statutory authority for indirect source reviews will
expire. EPA will support ISR through the grant. The state
will perform reviews for sources in the AQCR outside Washoe
County.
Air/Transportation planning (carbon monoxide; oxidant): WCDHD
will continue to act as advisor to the Washoe County Area
Transportation Policy Committee. EPA will continue to foster
this sound relationship as requested and will perform the
annual 109 "(j) consistency review.
201 - EIS (carbon monoxide; oxidant): In FY-77, ^a sewage
treatment plant expansion grant may be offered to the City
of Reno. One alternative plant plan would accomodate twice
the-current population. EPA will work closely with the EIS
contractor to produce an acceptable secondary air impact
analysis and to design reasonable mitigation measures.
Compliance verification (particulate): WCDHD will verify
compliance of the six major stationary sources and report
their status to EPA via CDS. EPA will support this effort
through the grant.
Instack Monitoring; The WCDHD endorses the concept of continuous
monitoring and will adopt equivalent regulations. EPA will offer
105 grant assistance.
-------
N - 10
AOMP/208 (carbon monoxide; oxidant; particulate):
WCDHD analyzes the designation of the Reno-Sparks AQMA for
particulate matter consistent with the requirements spelled
out in 40 CFR 51.40 - 51.51. WCDHD will also perform a similar
analysis for carbon monoxide, and, if warranted, will designate the
area as an AQMA. EPA will offer limited grant support.
T7CDHD will also develop a public education forum for Reno's air
pollution problems using the Blue Ribbon Task Force. The Task
Force will review the particulate control measures outlined by
contract and make a selection of feasible measures. EPA will
cooperate and assist the program as requested, but no grant
assistance will be offered. The HD will continue its liaison
with W-COG, the 208 agency.
STRATEGY
The Washoe County District Health Department is in the
process of improving its technical capability and professional
credibility. This effort should be supported by EPA. EPA
will provide training funds to cover, generally, compliance
verification of stationary sources and short- and. long-range
air quality planning. Specific .training needs will be identified
by V7CDHD; a specific plan to satisfy those needs will be
worked out between EPA and WCDHD.
Starting now, EPA is committed to shaping the EIS for
the 201 project to address air quality impacts and to mitigate
adverse impacts. Early in the next fiscal year, EPA will
audit the CO and Ox monitors to ensure that the data recorded
is sound, and trends can be properly tracked. WCDHD will refine
its AQMA effort and continue its liaison with the local trans-
portation planning agency and the 208 grantee.
------- |