SURVEY OF EPA USER INTEREST
FOR
PROPOSED STATE IMPLEMENTATION PLAN
AUTOMATED INFORMATION SYSTEM
Prepared for
ENVIROMENTAL PROTECTION AGENCY
Office of Air Quality Planning and Standards
Monitoring and Data Analysis Division
National Air Data Branch
Durham, North Carolina
Contract No. 68-O2-1O95
NOVEMBER 3O, 1973
CSC
COMPUTER SCIENCES CORPORATION
-------
SURVEY OF EPA USER INTEREST FOR PROPOSED
STATE IMPLEMENTATION PLAN
AUTOMATED INFORMATION SYSTEM
Prepared by
COMPUTER SCIENCES CORPORATION
For
Environmental Protection Agency
Office of Air Quality Planning and Standards
Monitoring and Data Analysis Division
National Air Data Branch
Durham, North Carolina
Under
Contract No. 68-02-1095
Prepared by:
R.JJU-Xuiil 7
C --"'" *
Date
Approved by:
Dudek
'Deputy Director,
Special Projects
-------
ABSTRACT
This document presents the results of a survey to define EPA user require-
ments for a proposed State Implementation Plan (SIP) automated information.
system. It addresses the relationship of such a proposed information system
to existing data bases such as NEDS and SAROAD. It describes and analyzes
survey results. Finally, it makes recommendations based on the results re-
garding the computerization of certain parts of the SIPs.
ii
-------
TABLE OF CONTENTS
Section 1 - Executive Summary 1-1
Section 2 - Objective of the Survey 2-1
Section 3 - Survey Approach. 3-1
Section 4 - General Description of the SIPs 4-1
Section 5 - Questionnaire Format and Interview Scenario 5-1
Section 6 - Description of Sample Surveyed. 6-1
Section 7 - Analysis of Results 7-1
7.1 Introduction 7-1
7. 2 Explanation of Appendix D Tables 7-1
7. 3 EPA Durham 7-4
7.3.1 Rules and Regulations 7-5
7.3. 2 Control Strategies 7-6
7.3.3 Surveillance 7-7
7.3.4 New Sources and Modification of Existing Sources 7-8
7. 3. 5 Compliance Schedules 7-9
7.3. 6 Legal Authority 7-10
7. 3. 7 Resources 7-10
7.3.8 Intergovernmental Cooperation 7-10
7.3.9 Emergency Episodes 7-11
7.4 EPA Washington and Las Vegas NERC 7-11
7.4. 1 Rules and Regulations 7-12
7.4.2 Control Strategies 7-13
7.4.3 Surveillance 7-14
7.4.4 Resources 7-14
7.4.5 New Sources and Modification of Existing Sources 7-15
7.4. 6 Legal Authority 7-15
7.4.7 Emergency Episodes 7-15
7.4. 8 Compliance Schedules 7-16
7.4.9 Intergovernmental Cooperation 7-16
7. 5 Regional Offices 7-17
7. 5.1 Rules and Regulations 7-17
7. 5.2 Control Strategies 7-19
7. 5. 3 Resources 7-19
7. 5.4 Legal Authority 7-20
in
-------
TABLE OF CONTENTS (Cont'd)
Section 7 (Cont'd)
7.5. 5 Surveillance 7-21
7.5.6 Intergovernmental Cooperation 7-21
7. 5. 7 Emergency Episodes 7-22
7. 5. 8 Compliance Schedules 7-23
7.5.9 New Sources and Modification of Existing Sources 7-23
7.6 Uses of NEDS, SAROAD, and Other Data Bases 7-23
7.6.1 Introduction 7-23
7. 6. 2 NEDS and SAROAD 7-24
7.6.3 Other Data Bases 7-24
7.7 General Questions 7-25
Section 8 - Recommendations 8-1
8.1 Introduction 8-1
8.2 SIP Information System Recommendations 8-1
8. 2.1 Interest in Computerization : 8-1
8.2.2 Estimated Frequency and Volume of Use 8-2
8.2.3 Recommendation to Pursue Computerization 8-3
8. 2.4 Time Requirements for Implementation 8-3
8. 3 Basis for SIP Information System 8-4
8.3.1 Evaluation Files 8-4
8.3. 2 Interpretive Material 8-4
8.3. 3 Periodic Reports 8-5
8.3.4 County, City, and Local Codes 8-5
8. 3. 5 Summarization 8-6
8.3. 6 Establishment of a Definitive Set of SIPs 8-6
8.4 Updating Procedures 8-7
8.4.1 Development of Manual System 8-7
8.4. 2 Frequency of Updating 8-7
8.4.3 Organizational Responsibility for Updating 8-8
8. 5 Recommendation Concerning Major SIP Categories 8-9
8.5.1 Introduction 8-9
8. 5. 2 Rules and Regulations 8-9
8.5.3 Control Strategies 8-13
8.5.4 Surveillance 8-14
8. 5. 5 Legal Authority 8-15
8. 5. 6 Resources 8-15
8. 5. 7 New Sources and Modification of Existing Sources 8-16
8. 5. 8 Compliance Schedules 8-16
IV
-------
TABLE OF CONTENTS (Cont'd)
Section 8 (Cont'd)
8.5.9 Intergovernmental Cooperation . . : 8-17
8. 5.10 Emergency Episodes 8-17
8. 6 Computerization of General Areas 8-17
8. 6.1 Indexing 8-17
8.6. 2 Other Areas 8-18
8.7 Protection of Data 8-19
8. 7.1 Accessing Data 8-19
8. 7. 2 Information System Updating 8-20
8. 8 Query Capability 8-20
8. 8.1 Access 8-20
8. 8. 2 Output 8-20
8. 8.3 Recommendations 8-20
Appendix A - Questionnaire, Survey of EPA User Requirements
Regarding State Implementation Plans
Appendix B - User Interest Form
Appendix C - List of People Surveyed
Appendix D - Tabulation of Results
Appendix E - Information Provided by Interviewees
-------
SECTION 1 - EXECUTIVE SUMMARY
A survey to define EPA user requirements for a proposed State Implementation
Plan (SIP) automated information system was conducted for the National Air
Data Branch, Monitoring and Data Analysis Division of the Office of Air Quality
and Standards. The primary purpose of this survey was to determine what parts,
if any, of the SIPs should be computerized, and in what manner (e.g., full text,
abstracts). The survey, in the form of personal interviews, was conducted at
EPA Washington, EPA Durham, four Regional Offices, and the Las Vegas NERO.
The existing SIPs differ considerably in size, level of detail, and format. They
are not static documents, but are constantly undergoing update and change. In
addition to the initially issued documents plus updates, the basis for an SIP
data system might also include evaluation files, interpretive material, periodic
reports, and county, city, and local codes.
The diverse nature of the SIPs does not provide a well-defined basis for stand-
ardized revision and update. In fact, there does not appear to be a standardized
mechanism for update, such as the issuance of replacement pages. Perhaps
because of this, there does not appear to be a definitive set of SIPs in existence,
although one set each in Durham and Washington appear to have local recogni-
tion as being definitive. For a computerized system to be effective, it must be,
or be equivalent to, the definitive system, and a standardized means to update
it at regular intervals must be provided. It is recommended in this report that
the elements that comprise the SIPs be identified, and a process for updating
be established and tested before a comprehensive computerized system is
implemented.
Survey results are presented in tabular form in Appendix D, and are analyzed
in the report. Comments, made by interviewees regarding factors outside the
survey questions, were recorded and are included.
1-1
-------
Based upon survey results of those interviewed plus a projection of potential
users from the six Regional Offices not surveyed, it is estimated that 20 SIP
information system queries per day would be made. Most of these 20 queries
would come from people who wish to access rules and regulations in some
form. It is, therefore, recommended that computerization of rules and regula-
tions be pursued as a first priority item.
Interest was expressed in baseline air quality and emission data. It is recom-
mended that these data be compiled and published in report form. Interviewees
expressed an interest in current information concerning monitoring stations.
SAROAD and the SIP Semi-Annual Progress Reports provide a better source
of this information than do the SIPs and it is recommended that they be utilized.
Additional capabilities might be required in SAROAD to provide ready access to
monitoring station information. Interviewees were interested in current re-
source information, which is not available in the SIPs but can be found in Air
Pollution Control Program Grant information.
Rules and regulations related to new sources and modifications of existing
sources were of interest. One means of accessing regulations might be by those
regulations that apply to new and modified sources. A means to access new
sources could also be provided as an additional NEDS capability. It is recom-
mended that these two approaches be pursued. Interviewee interest in com-
pliance schedules should be satisfied by the Compliance Data System; no
additional SIP computerized capability should be required. Interest in other
areas of the SIPs was comparatively slight, and it is generally recommended
that computerization of those areas not be pursued at this time.
1-2
-------
SECTION 2 - OBJECTIVE OF THE SURVEY
The purpose of this activity was to plan, organize, and conduct a survey to de-
termine EPA user requirements for a planned State Implementation Plan (SIP)
automated information system. The survey was designed to answer the follow-
ing specific questions:
1. What parts of the SIPs should be computerized and in what manner
(e.g., full text, abstracts, formatted files)?
2. What should the update frequency and methodology be and who should
perform the updating ?
3. What are the retrieval requirements, volumes, and request fre-
quencies for information contained in the SIPs ?
4. What are the turnaround requirements for update and retrieval of
the SIP system ?
5. What query capability is necessary for this system?
In addition, the relationship and interaction of the SIP user requirements with
NEDS, SAROAD, and other data bases were to be investigated. The survey was
also designed to define system requirements with respect to file interaction,
priority on types of retrieval, unstructured requests, and cathode ray tube
utilization.
The survey was conducted for the National Air Data Branch, Monitoring and
Data Analysis Division, Office of Air Quality Planning and Standards. It in-
volved personal interviews with cognizant EPA personnel at EPA Washington,
EPA Durham, four Regional Offices, and one NERC. The interviews were
conducted by Computer Sciences Corporation (CSC) personnel, accompanied by
the Monitoring and Data Analysis Division project officer, Mr. Gerald Nehls.
2-1
-------
SECTION 3 - SURVEY APPROACH
To collect information required to answer the questions posed, three primary
means were available. These were: 1) questionnaires distributed and returned
by mail, 2) telephone interviews, and 3) personal interviews. The last method
was chosen for several reasons. Primarily, it was desired to get potential
users of an SIP information system to express their needs as freely as possible.
Thus a relatively free-form question-and-answer session scenario was devel-
oped; such a scenario is most effective when conducted as a personal interview.
The relatively short length of time available (3-1/2 months) to develop ques-
tions, conduct the survey, and analyze and report results further precluded
the use of a written questionnaire. To satisfy the scheduling requirements of
many people, two or more interviews were frequently held at the same time.
Telephone interviews would not have permitted such a ready interchange of
information between more than two people. In addition, it would not have been
possible to have telephone interviewees see and comment upon the sample fig-
ures contained in the survey questionnaire.
3-1
-------
SECTION 4 - GENERAL DESCRIPTION OF THE SIPs
In the course of examining a sample of 12 State Implementation Plans to design
the survey questions, the diverse nature and format of these plans were noted.
The SIP volumes appear to fill anywhere from 1 inch to 2 feet of shelf space.
This vast difference in quantity is due in part to the size and diversity of the
states themselves, and because some states submitted entire plans for county,
local, or other intrastate levels, thus resulting in the effect of several-plans-
in-one with a consequent increase in the size of the SIP. It also reflects, how-
ever, a noticeable difference in the level of detail between certain SIPs.
The SIP volumes that were reviewed can be divided into three major parts:
1) correspondence, 2) main body, and 3) appendixes. The correspondence in-
cludes transmittal letters and letters related to requests for extension. In
some instances, correspondence relates to additions and corrections to the
SIPs, and relevant data might be contained therein. In such a case, a revision
letter itself might contain the information used to update the SIP, as opposed to
functioning only in a transmittal sense for replacement or additional pages.
Correspondence, therefore, must generally be included as part of the SIP.
The main body is generally subdivided into major chapters that correspond to
the sections defined in the Federal Register of November 25, 1971, Part 51,
Subpart B - Plan Content and Requirements.
These 13 sections are:
General Requirements
Legal Authority
Control Strategy: General
Control Strategy: Sulfur Oxides and Particulate Matter
4-1
-------
Control Strategy: Carbon Monoxide, Hydrocarbons, Photochemical
Oxidants, and Nitrogen Dioxide
Compliance Schedules
Prevention of Air Pollution Emergency Episodes
Air Quality Surveillance
Review of New Sources and Modifications
Source Surveillance
Resources
Intergovernmental Cooperation
Rules and Regulations
By combining the three control strategy sections into one, the two surveillance
sections into one, and eliminating the general requirements section, which does
not provide the basis for any user interest questions, the 13 sections were re-
duced to nine general categories, which provided a basis for the organization
of the user questionnaire.
While these categories are addressed in all the plans that were reviewed, the
organization and level of detail vary considerably between the plans. In par-
ticular, information related to a certain topic might often be addressed in
various parts of a SIP, rather than in one place. Such a case is illustrated by
the example mentioned above, when revision material is contained in the body
of a letter, rather than as a replacement to existing pages.
Most of the plans reviewed contained appendixes, which varied considerably in
scope and level of detail. Appendixes were frequently used for the presenta-
tion of emission inventory and air quality data in tabular form. In some cases,
state laws showing legal authority to carry out the plans were incorporated as
4-2
-------
appendixes. Appendixes were also used as a means to introduce changes to the
original plans.
The Federal Register of May 31, 1972, published evaluations of the State Im-
plementation Plans, stating approval and/or disapproval of these plans or por-
tions of the plans. At this time, some states were required to submit additional
transportation control plans. These additional plans must also be included as
part of the SIPs, as should any additions or modifications to the plans, whether
promulgated by EPA or enacted by the states. Several transportation plans
were studied and survey questions were developed related to transportation.
This section has discussed the content and structure of the SIPs to demonstrate
that, while they have a commonality of purpose, considerable differences exist
between them and that they are changing rather than static documents. On the
other hand, this discussion is not intended to be an evaluation of either the con-
tent or the quality of any SIP.
4-3
-------
SECTION 5 - QUESTIONNAIRE FORMAT AND INTERVIEW SCENARIO
Two survey questionnaires were developed. One was concerned primarily
with user interest in the nine major SIP categories. It also was designed to
determine the current use of NEDS, SAROAD, and other data bases. A second
questionnaire was used to determine the system requirements for computeriza-
tion of areas of interest in the SIPs that were identified via the first question-
naire.
The interview scenario, starting with the first survey questionnaire, went as
follows. Background information was obtained to identify each interviewee and
his organization. Then a series of questions was asked to determine current
use of NEDS, SAROAD, and other data bases. This area of questioning was
developed to help determine the interaction of a potential SIP information sys-
tem with existing data bases. Then several general questions were asked.
These questions were SIP-related, but did not fall under any of the nine major
categories. Finally, the nine categories were addressed by asking if the inter-
viewee had a general interest in the first category (legal authority). If the
answer was yes, specific questions under that category were asked. If the in-
terviewee was not interested in computerization of SIP-related legal authority
information, then the next category was addressed. In this manner all nine
categories were covered. Then the interviewee was asked to provide any addi-
tional comments to ensure that all areas of potential interest were identified.
The first survey questionnaire is included in this report as Appendix A.
The interview scenario continued using the second questionnaire. The inter-
viewee was asked to rank the SIP categories of strongest interest. Questions
were asked concerning those categories of interest regarding SIP computeriza-
tion requirements. These included job turnaround, frequency of use, and
responsibility for updating a computerized SIP system. These questions con-
cluded the interview. This second questionnaire is included as Appendix B to
this report.
5-1
-------
Although this scenario was generally adhered to, interviewees sometimes ex-
pressed opinions and wishes that were not in direct response to questions. This
free exchange of information was considered useful and was not discouraged.
Many of the comments made by interviewees are included in Section 7 of this
report.
5-2
-------
SECTION 6 - DESCRIPTION OF SAMPLE SURVEYED
The survey was conducted at EPA Washington, EPA Durham, the Las Vegas
NERC, and four EPA Regional Offices. The individuals surveyed are listed in
Appendix C. An extensive sample of people in EPA Washington and Durham
who were thought to have an interest in such a proposed information system
were contacted by Mr. Nehls or by a CSC task member. All who expressed
interest were interviewed. On occasion, one individual was designated by a
respondent to represent a particular branch or section, rather than have each
potential SIP information system user in the organization be interviewed. This
was done primarily when it was felt one person's opinion would represent the
entire organization accurately. A means to weigh this situation was developed
by asking that the estimated number of times the SIP information system would
be accessed (e. g., number of estimated runs per week) for the entire organiza-
tion represented. In that way, an appropriate estimate of the frequency of use
by the entire organization was obtained.
A total of 53 people were interviewed. Nineteen were interviewed in Durham,
11 in Washington, 21 in the Regional Offices, and 2 in the Las Vegas NERC.
6-1
-------
SECTION 7 - ANALYSIS OF RESULTS
7.1 INTRODUCTION
This section explains the Appendix D tables that display the survey results.
These results are separated into three groups: EPA Durham; EPA Washington
and the Las Vegas NERC; and the Regional Offices. Results were separated in
this fashion so interviewees can see readily any significant differences between
group opinions. Because the Las Vegas NERC appeared to be more closely
associated with EPA Washington than with Durham or the Regions, it was so
grouped.
After a discussion of results for these three EPA groups, results related to the
use of NEDS, SAROAD, and other data bases are presented. A discussion of
results related to general SIP questions concludes the section.
7.2 EXPLANATION OF APPENDIX D TABLES
Table D-l summarizes, for the 19 Durham interviewees, general interest in
the nine SIP categories and indexing. The indexing capability would provide the
user with page numbers and/or section and subsection references in response
to key word queries. The user would then refer to printed (as opposed to com-
puterized) SIP volumes for the desired information, using the reference num-
bers provided via such a computerized indexing capability. Such a capability,
if implemented, is not envisioned as an index to all SIP categories. Any por-
tions of the SIPs that are computerized as full-text files would not also be
indexed.
Interest in a given category was determined by such questions as, "Are you
interested in accessing SIP information related to Category X?" for each of
the nine categories and indexing. After general interest for all categories was
determined, respondents were asked to rank their categories of interest as:
strongest interest, second strongest interest, and third strongest interest.
7-1
-------
These rankings are shown in the table. Not all respondents indicated as many
as three choices; some did not indicate any choices. Categories of interest for
which no choice was expressed are indicated by Xs. The number of first, sec-
ond, and third areas of interest are totaled for each category. A weighted total
is then computed, using weighting factors of three for a first choice, two for a
second choice, and one for a third choice. A ranking by weighted total is pro-
vided in the right-hand column.
Table D-2 presents the same information as Table D-l, for the Washington and
Las Vegas interviewees' responses. Table D-3 provides information related to
the Regional Offices, displayed in the same manner as Tables D-l and D-2.
The order of presentation for the next group of tables is the same as for the
first three (i. e., Durham, Washington/Las Vegas, and the Regional Offices).
Because Rules and Regulations and Control Strategies proved to be the cate-
gories of greatest interest, specific areas of interest in these two categories
were tabulated. Tables D-4, D-5, and D-6 depict information related to inter-
est within Rules and Regulations for Durham, Washington/Las Vegas, and the
Regional Offices, respectively. In these tables, general interest in the Rules
and Regulations category, line 2 from Tables D-l to D-3, is repeated for con-
venience. Interest in an indexing capability, similar to that described earlier
but for Rules and Regulations only, is shown on line 2. Interest in an "his-
torical" capability, to allow accessing of formerly effective, noncurrent regu-
lations is shown on line 3. Interest in abstracts or tabular summaries of
regulations is shown on line 4. Interest in full text is shown on the last line.
The letter X indicates interest. The four columns at the right of the tables
show (from left to right): total interested, percentage interested of those inter-
viewed, percentage interested of those interested in Rules and Regulations, and
rank by total interested.
Tables D-7 through D-9 depict information related to interest within Control
Strategies for Durham, Washington/Las Vegas, and the Regional Offices,
7-2
-------
respectively. Line 1 shows general interest, repeated from Tables D-l
through D-3. Lines 2 through 5 relate to baseline information contained in the
SIPs. Lines 2 and 3 show interest in baseline emissions and air quality data,
respectively, used in the formulation of the control strategies. Interest in the
model or models used (e.g., rollback or AQDM) in the control strategy for-
mulation is shown on line 4. Interest in baseline costs is shown on line 5.
Lines 6 and 7 relate to mobile sources. Interest in accessing control strategies
specifically related to mobile sources is shown on line 6. Line 7 shows interest
in baseline mobile source cost data. The four columns at the right show totals
in the same fashion as for Tables D-4 through D-6.
Tables D-10 through D-12 depict information related to: estimated computer
query turnaround requirements; interest in a graphics output [i.e., cathode
ray tube (CRT) capability]; and respondent opinion regarding where the re-
sponsibility to update a proposed SIP data base should lie. The tables are for
Durham, Washington/Las Vegas, and the Regional Offices, respectively. Cate-
gories associated with computer query turnaround requirements are: Within
Hours or As Soon As Possible (ASAP), Within a Day, About 2 or 3 Days (longer
than a day and less than a week), About 1 Week, and Over a Week. Respondents
were asked to estimate their typical computer requirements, assuming that their
categories of interest were available in an SIP data base. CRT interest and re-
sponsibility for SIP data base updating are shown following job turnaround.
Tables D-13 through D-15 show, for Durham, Washington/Las Vegas, and the
Regional Offices, respectively, estimated frequency of use of a proposed SIP
information system and the desired extent of data. Frequency of use is defined
as the number of computer queries submitted daily, weekly, monthly, semi-
annually, or annually. Extent of data refers to the level of detail that would
normally be desired in accessing SIP data. Levels of detail from which the
respondent could select were EPA region, state, AQCR, and local.
7-3
-------
Tables D-16 through .D-18 show the frequency with which interviewees desire
the proposed SIP information system to be updated.
Table D-19 indicates the interviewees who are current users of the NEDS and
SAROAD systems. Tables D-20 through D-22 show the use of data bases other
than NEDS and SAROAD [i.e., Bureau of the Census, GSA Property, Form
FPC-67 (Federal Power Commission), Dun and Bradstreet, Polk Vehicle Regis-
tration, and Federal Facilities Files]. While the use of these data bases does
not directly relate to a potential SIP information system, they are available to
EPA users via the National Air Data Branch. Response shown in Tables D-20
through D-22 reflects use of the other data bases in both printed form and via
the NADB computer tapes.
7.3 EPA DURHAM
In this section, summary information, extracted from Appendix D, is presented
and evaluated for EPA Durham interviewees. In addition, user comments and
requests concerning computerization of portions of the SIPs are noted. These
comments and requests are not generally in response to specific survey ques-
tions, but instead represent individual opinions and wishes that were volunteered.
The rankings and weighted point totals from Table D-l are repeated below, for
convenience.
Weighted Point
Rank Category Total
1 Rules and Regulations 36
2 Control Strategies 19
3 Surveillance 13
4 Legal Authority 5
5 New Sources 4
Compliance Schedules 4
7-4
-------
Weighted Point
Rank Category Total
7 Resources 3
8 Intergovernmental 2
Cooperation
9 Emergency Episodes 1
Each category in rank order is described below. Pertinent comments made by
interviewees are included, along with interpretations of results, whenever
applicable. Interviewees generally were interested in more than one topic or
subcategory; thus the interest totals of subcategories are greater than the in-
terest totals by category.
7.3.1 Rules and Regulations
Of the 19 Durham interviewees, 12 expressed an interest in the computerization
of rules and regulations. Table D-4 lists subcategories of interest.
Eleven people indicated that abstracts, or summaries of the regulations would be
satisfactory for their needs. Sample summaries and abstracts are provided in
Tables E-l and E-2. Table E-l shows a summary of North Carolina Air Pollu-
tion Control Regulations for sulfur compound emissions and nitrogen oxide
emissions, and a process weight table. Table E-2 shows 1975 SO require-
.x.
ments for coal-burning equipment, by AQCR, for Alabama, Alaska, Arizona,
Arkansas, and California. Table E-2 has the advantages of compactness and
easy readibility. A disadvantage is that a Remarks section is invariably re-
quired for tables of rules and regulations.
One person indicated a need for a full-text capability and felt abstracts might
not be completely reliable, insofar as the meaning of a regulation could be
distorted by the word selection used in formulating the abstract. Two indicated
a need for both full text and abstracts.
7-5
-------
Six indicated a desire for an indexing capability. Indexing would not be con-
sidered for computerization if either a full-text or abstract capability were
implemented. In both cases, page or SIP section references could be provided,
thus making indexing redundant.
Four were interested in obtaining historical information, i.e., ability to access
noncurrent regulations. One of these felt that while such a capability would be
desirable it might not be cost-effective to provide it. Another felt that while it
was desirable to obtain historical information, such a capability would not be
used very frequently.
One person indicated a desire to access complex source regulations.
One expressed an interest in a summary table showing effective dates of mobile
source regulations, including the compliance date.
One interviewee expressed an interest in determining an emission output, such
as sulfur content, for a particular source or group of sources, via NEDS, and
then comparing it with the value that would result if a different regulation was
in effect.
Seven interviewees responded specifically to how frequently they felt the regu-
lations portion of a proposed SIP data base should be updated. All indicated
that updating should take place whenever revisions were published in the Federal
Register, or as soon as possible. Several of these estimated that, on the aver-
age, new or revised regulations are published weekly in the Federal Register,
and that typically four or five regulations might be affected at one time.
7.3.2 Control Strategies
Fourteen of the 19 Durham interviewees expressed an interest in control stra-
tegies. This is two more than the number who expressed an interest in rules
and regulations. Due to the stronger interest in the latter, however, the
weighted point total was higher for regulations than for control strategies.
7-6
-------
Questions were asked to determine interest in accessing baseline data related
to the development of control strategies for stationary sources.
Eight were interested in accessing air quality baseline data and six were in-
terested in accessing baseline emissions data. Several people indicated that
the baseline emission data was of poor quality. One indicated that baseline air
quality data would be difficult to find in certain SIPs. Interest in predicted
emission and predicted air quality data was also shown by one person, who felt
that such information might best be made available in published report form,
rather than via a computerized information system.
Seven people were interested in accessing information related to models used
to develop control strategies in the SIPs.
Six were interested in cost data associated with stationary source control stra-
tegies implementation, if such data are generally available. One person com-
mented that cost data were available only if the Implementation Planning Pro-
gram (IPP) had been run, and felt that this had not occurred frequently. This
person also felt that most of the available information found in the SIPs related
to mobile source control strategies was probably outdated and of dubious value.
Concerning mobile sources, five were interested in information related to
control measures, and two were interested in associated cost data, if avail-
able.
7.3.3 Surveillance
Eleven of the 19 Durham interviewees indicated an interest in surveillance
information. Surveillance questions were related to Figures 8 through 11 on
pages A-21 to A-24. Four were interested in information similar to that dis-
played in Figures 8 and 9. Figure 8 shows, in tabular form, monitoring tech-
niques, types of sensors, and averaging times by pollutant, for a given
monitoring station or group of stations. Wind speed and wind direction are
also shown. Figure 9 shows the station location, starting and ending dates,
7-7
-------
and an indication of pollution density and population density for certain stations.
Six were interested in a table similar to that shown in Figure 10, which gives
for specific areas AQCR, the minimum number of federal monitoring sites re-
quired vs. the number of state proposed sites, etc. This information is cate-
gorized by pollutant and further subdivided by equipment type (e.g., gas
bubbler). Seven were interested in displays similar to Figure 11, which pro-
vides criteria for station location. These figures were incorporated to show
respondents generic types of displays of SIP information, rather than to define
output formats specifically.
One respondent noted that information displayed in Figure 8 generally is avail-
able in SAROAD. This person also noted that data contained in the first two
columns in Figure 9 are also available via SAROAD. It was indicated by one
respondent that station location information, such as might be displayed in
Figure 9, should be more specifically given than by street address. It was
noted by several people that information displayed in Figure 11 would be diffi-
cult to obtain in all the SIPs. Although most respondents indicated that the
proposed data base should be updated as new data becomes available, less
urgency was associated with surveillance updating than with the updating of
rules and regulations.
7.3.4 New Sources and Modification of Existing Sources
Six people interviewed were specifically interested in new source information.
One of these indicated a possible interest in the ability to access this portion
of the SIPs on a full-text basis. Two indicated an interest in text abstracts.
Three persons indicated that they would like to be able to access an inventory
of new sources since a preselected date. One indicated a desire to access an
inventory of new sources by SIC code and two desired access by SCC code.
Two indicated that they would use NEDS to obtain the information they desired,
and therefore would not require a new source file specifically as part of an SIP
data base. One indicated the desire to access new source standards by state
7-8
-------
and by AQCR. Another indicated the desire to access the location of new or
modified sources, the type of source, who tested the source, the results of the
testing, and whether compliance with new source performance standards was
required. Another respondent indicated a desire to reference permit systems
and questionnaires or forms that states might employ to register new and modi-
fied sources. This person also would like to have available by state what new
and modified sources are reviewed, and what information is required to be sub-
mitted by the source.
7.3.5 Compliance Schedules
While 11 interviewees showed an interest in accessing information related to
compliance, survey tabulations indicate that there is a lack of strong interest
in this area. A possible explanation of this is that the Compliance Data Sys-
tem (CDS), developed by the Office of Enforcement and General Council (OEGC),
is expected to supply much of the information that might be supplied in a com-
pliance schedule section of an SIP data base. Almost everyone interested in
compliance indicated they would use CDS.
Four wanted information that would tell whether the compliance schedules were
those submitted by the state or those enacted by EPA. Three indicated that
some kind of abstracts or summaries of the schedules should be made available.
Two felt that it would be desirable to identify any variations permitted from
compliance schedules. Two specifically stated that a compliance schedule por-
tion should not be incorporated as part of an SIP data base, that CDS would be
satisfactory. One person was interested in information that would be provided
by the pollutant source, giving its schedule for compliance. Another wanted
information regarding when a region (e.g., AQCR) is scheduled to come into
compliance. Two people were interested in compliance related to area sources.
There apparently will be no provision in CDS for area source compliance infor-
mation. One person indicated a desire for summary information (e.g., the
7-9
-------
number of compliance schedules approved, and the number of schedules dis-
approved) .
7.3.6 Legal Authority
Five people interviewed in Durham expressed an interest in computerization of
information related to legal authority. For the most part, this interest was of
a general nature, rather than related to specific requirements. Three people
were interested in whether a state has provided itself with the proper legal
authority to execute an implementation plan.
7.3.7 Resources
Six Durham interviewees expressed an interest in resource information. Five
of these expressed a general interest in the subject of resources, while the
other had more specific requests. These include updates to the resource in-
formation contained in the SIPs, resources estimated for the enactment of
transportation controls, job classifications of state employees, and information
showing the states that are spending less than the SIP budget estimates. This
person wanted access to historical data, not only current data; not all of this
data is available in the SIPs. Two were interested in a tabular display of sal-
ary estimates, such as that shown in Figure 12, page A-27. The person with
greatest specific interest in resources indicated that he felt that this portion of
an SIP data base should be updated quarterly.
7.3.8 Intergovernmental Cooperation
Five interviewees were interested in intergovernmental cooperation. One of
these expressed interest in abstracted portions of the SIPs. Three of the five
were particularly interested in being able to identify readily the agencies in a
state that are directly responsible for specific functions. Such information, if
generally available, would lend itself to a tabular presentation. This was done
in the Georgia SIP where, for each county, responsibilities were tabulated as
state and/or local. The categories in this table were quite detailed. One user
7-10
-------
who had a relatively strong interest in intergovernmental cooperation felt that
this information should be updated quarterly.
7.3.9 Emergency Episodes
Three people were interested in information related to emergency episodes.
Two of these were interested in a display such as the one shown in Figure 5,
page A-17. All three expressed an interest in knowing whether states had
developed emergency control programs for point sources. Two were interested
to know the states that have submitted contingency plans; one of these wished to
have portions of these plans available in abstract form via computer. One was
interested in what type of control action is to be imposed for a particular epi-
sode stage by source type. This type of information is depicted in Figure 6,
page A-18. Two were interested in a table of emergency source categories
that might be displayed by AQCR, and is depicted in Figure 7, page A-19.
One was interested in information related to exemption from controls of certain
source categories, information related to the closing of industries, and any
priorities related to prohibition and restrictions of various activities during
emergency episodes. This person was also interested in any additional moni-
toring requirements that might be imposed during emergency episodes and, in
particular, the stations that were designated for this additional monitoring.
The interviewee who expressed the strongest interest in this category felt that
emergency episode information should be updated as frequently as possible.
7.4 EPA WASHINGTON AND LAS VEGAS NERC
Survey results for EPA Washington and the Las Vegas NERC are discussed in
this section. The format used for presentation of results in this section is the
same as that used in the previous section.
7-11
-------
The rankings and weighted point totals from Table D-2 are repeated below, for
convenience.
Weighted Point
Rank Category Total
1 Rules and Regulations 21
2 Control Strategies 17
3 Surveillance 9
4 Resources 4
New Sources 4
6 Legal Authority 3
7 Emergency Episodes 1
8 Compliance Schedules 0
Intergovernmental Cooperation 0
7.4.1 Rules and Regulations
Eleven interviewees expressed an interest in the computerization of rules and
regulations. Several people expressed an interest in more than one subcate-
gory, as shown in Table D-5. A summary of this interest is given below.
Six were interested in abstracts or summary information, while five preferred
a complete text capability. Included among these interviewees were three who
wanted both full text and abstracts. Two who wanted full text felt that abstracts
would not be reliable. Three wanted an indexing capability, and three were in-
terested in the capability of obtaining historical information. All of the latter
felt that a historical capability, while useful, would not be essential. Two ex-
pressed a general interest, and did not specifically indicate a preference for
any of these categories.
One respondent who was interested in both full text and abstracts felt that regu-
lations do not lend themselves well to summaries, but that summaries would be
useful if enough accurate information and detail could be included; he also felt
7-12
-------
that it would be difficult to perform this abstraction or summarization accu-
rately. This person expressed an interest in accessing local regulations, when
they are more stringent than state regulations. In addition, he was interested
in the inclusion of point source locations in UTM units, when point sources are
identified specifically in a regulation. Two felt that regulations should all be
expressed in common units (e.g., micrograms per cubic meter). One person
specifically mentioned that the effective date of the regulation should be in-
cluded. Another noted that a proposed SIP data base should be able to differ^
entiate between regulations that relate to new and to existing sources. One
expressed an interest in accessing regulations on an exclusion basis (i.e.,
which plants are not included under certain types of regulation). Several people
wanted to be able to evaluate the incremental contribution or benefit that would
be derived from specific regulations. These people also were interested in the
increase in surveillance requirements associated with increased transportation
controls.
It was the general consensus of those most strongly interested in rules and re-
gulations that this part of the SIP data base should be updated as frequently as
new information becomes available.
7.4.2 Control Strategies
Eight of those interviewed in this group were interested in control strategy in-
formation. All of these expressed an interest in more than one subcategory,
as is shown in Table D-8. All eight were interested in baseline air quality data
and in the models used to establish the control strategies for stationary sources.
Six were interested in the baseline emissions data. Six were interested in ac-
cessing information related to mobile source control measures. Two were in-
terested in costs associated with both stationary and mobile source control
strategies. One indicated a desire to see baseline data used in transportation
plans that relate to mobile sources. One person expressed an interest in being
7-13
-------
able to determine current air quality versus the air quality when the SIPs were
developed. Those who expressed a strong interest in control strategy informa-
tion felt that this part of a proposed SIP data base should be updated as soon as
new information becomes available.
7.4.3 Surveillance
Seven of the Washington and Las Vegas interviewees were interested in SIP-
related surveillance information. Several people indicated an interest in more
than one subcategory, as indicated in this discussion. Four interviewees spe-
cifically indicated that SAROAD data would fill their primary requirements.
Three were generally interested in Figure 9, page A-22; two of these wanted
information related to proposed monitoring stations. Three were interested in
a display such as that shown in Figure 10, page A-23. Two were interested in
the Figure 11 information (page A-24), if available. Two were particularly
interested in station locations given in UTM units. These people were also
interested in what pollutants are being monitored, and would be interested in
some sort of display of station locations, possibly via an incremental plotter.
One was particularly interested in quality assurance data (e.g., calibration of
instruments). The respondents who were most interested in surveillance did
not feel that information related to monitoring stations would need to be up-
dated very frequently. One of these indicated that an annual update would be
satisfactory.
7.4.4 Resources
Six were interested in information related to resources. Of these, one was
specifically interested in a tabular display of salary estimates, such as the
sample displayed in Figure 12, page A-27. This person was also interested
in a table of physical resources that might include the number of items avail-
able and projected, such as testing equipment, monitoring equipment, and lab
equipment. Another person was particularly interested in money and manpower
data, both baseline and updates, in as much detail as possible. Another was
7-14
-------
primarily interested in baseline information, broken down by function. The
remaining three interviewees were interested in resources allocated to moni-
toring, and wanted this information on levels such as instrumentation funds,
technical resources, manpower, and dollars. One person was interested in
how many dollars and other resources are put into specific areas, and what
benefit is derived from them.
7.4.5 New Sources and Modification of Existing Sources
Three interviewees were interested in information related to new sources.
One of these expressed only a general interest. Another was particularly in-
terested in being able to differentiate between rules and regulations that apply
to new sources and those that apply to existing sources. This person and one
other were interested in accessing inventories of new sources by all the cate-
gories mentioned in question 6, page A-25. These categories are: since a
particular date, by SIC, by SCC, by political subdivision, by AQCR, by proc-
ess, and by size. One was interested in projected new sources and in what
controls apply to new sources.
7.4.6 Legal Authority
Three interviewees were interested in legal authority. Two of these indicated
that any computerization related to this area should be on a full-text basis.
Both particularly wanted to be able to access legal authority related to complex
sources. One was interested in state code and constitutional citations, and full
text of applicable legislation. Two people were interested in a display such as
that shown in Figure 2, page A-8. This figure references statutes by number
and gives a brief summary of each. Two were interested in legal authority
related to motor vehicle emissions and land use controls.
7.4.7 Emergency Episodes
Two interviewees expressed an interest in information related to emergency
episodes. In both cases, interest centered upon the regulatory aspects of this
7-15
-------
four expressed only a slight general interest. One indicated that a table of
state versus local responsibility for various regulatory functions would be
useful. This table should indicate whether state or local regulations apply.
Another was interested in who has the authority to enforce the most stringent
regulationstate or local agencies.
7.5 REGIONAL OFFICES
Twenty-one people were interviewed at the Atlanta, San Francisco, Chicago,
and Boston regional offices. Results of these interviews are given in Table D-3,
a summary of which is provided below for convenience.
Weighted Point
Rank Category Total
1 Rules and Regulations 30
2 Control Strategies 15
3 Resources 9
5 Legal Authority 5
Surveillance 5
6 Emergency Episodes 3
Compliance Schedules 3
8 Intergovernmental Cooperation 2
9 New Sources 0
A discussion of each category follows, given in rank order.
7.5.1 Rules and Regulations
Seventeen of the 21 people interviewed expressed an interest in rules and regu-
lations. A summary of subcategory preferences taken from Table D-6 is pro-
vided below. As Table D-6 indicates, most of those interested in regulations
are interested in more than one subcategory.
Ten of the 17 displayed an interest in abstracts or summaries of regulations,
and 6 were interested in full text. Several of the latter felt that abstracts might
7-17
-------
not be reliable. Seven were interested in accessing historical information.
Six were interested in an indexing capability. Six expressed interest in know-
ing the source or sources of regulations (i.e., state or EPA). Three were
interested in a standardized format for display of regulations, including a
standardized set of units. An additional discussion of user comments is given
in the following paragraph.
One person expressed an interest in regulations that apply to confidentiality of
data (e. g., throughput of emissions). Another indicated a need to know the
status of regulations (i.e., approved or disapproved). One respondent pre-
ferred process/weight curves as a means to summarize the regulations. One
wanted to be able to access adopted, effective, and attainment dates of regula-
tions. Of these, he felt that the effective date was most important. He was
also interested in Federal Register publication dates of regulations by section
number, and when regulations were proposed and when they were promulgated.
Another person who was interested in summary information rather than full
text felt that a table giving regulation numbers for source types by jurisdiction
would be useful. A sample of this type of display was provided and is included
as Table E-3. Another interviewee felt that as soon as a regulation change
request was submitted, it should be incorporated into an SIP data base. It
could be designated later as approved or disapproved. One person wanted to
be able to identify regulations that give delegated authority from the Federal
Government regarding new source performance standards. Three people were
interested in accessing effective dates of regulations. Further discussion re-
lated to dates associated with regulations is contained in Section 8.5.2 of this
report. One person noted that rules and regulations are available in a non-
EPA, weekly publication called the Environment Reporter. This publication is
available in that regional office. The Environment Reporter publishes federal
laws, federal regulations, and state air laws in addition to other environmental
information. It does not, however, include rules and regulations at the local
(i.e., city or county) level. Interest was expressed by one person in being able
7-18
-------
to determine the number of sources in an AQCR for which a particular regula-
tion applies. Another person felt that an EPA evaluation of the quality of regu-
lations would be desirable.
7.5.2 Control Strategies
Seven people interviewed in the regional offices expressed an interest in con-
trol strategy information. Of these, five were interested in baseline emissions
and air quality data, and in models used for stationary source control strate-
gies. Four of these five were interested in control measures associated with
mobile sources. One of the five was interested in cost data associated with
stationary sources, but noted that it was not likely to be available in the SIPs.
The other two people expressed only a general interest in control strategy in-
formation. This paragraph has summarized results listed in Table D-9. Addi-
tional comments made by interviewees are discussed below.
One person expressed an interest in control strategy formulation, particularly
when computer models such as AQDM and D?P were used. This person was
interested in the calibration method used when these two models were exer-
cised and in an historical table of computer runs made. This information is
probably not available in the SIPs. One person felt that a standardized sum-
mary format would be satisfactory for baseline emission datathe lowest level
of detail would not be necessary. Another person felt that as complete an emis-
sion inventory as was available in the SIPs should be supplied.
7.5.3 Resources
Eight people were interested in accessing information related to resources.
This part of the SIPs essentially contains baseline data with projections. Six
of the eight were interested specifically in more current resource data; four
of these felt this information would be available from Air Pollution Control Pro-
gram Grant information. The fifth of these six people felt that current data
would be available via the state quarterly reports. The sixth indicated that
baseline data is being updated as part of SIP revisions. Of the remaining two,
7-19
-------
one was primarily interested in resource information related to monitoring, as
was one of the previously cited six. The last person expressed only a general
interest in resource information. Specific comments are discussed below.
One person who was interested in monitoring related resource information
wanted to access funding data for laboratories and instrumentation. He also
wanted to see the percent of these funds allocated to monitoring.
Another person was interested in a table of salary estimates, as depicted in
Figure 12, page A-27. He wanted to access tables of manpower and projected
funds by the major function areas specified in Appendix K of the November 25,
1971 Federal Register. These areas are enforcement services, engineering
services, technical services, and management services. He was also inter-
ested in a further functional breakdown, if available.
7.5.4 Legal Authority
Seven people were interested in accessing information related to legal authority.
Four of these expressed only a general interest in the subject, and did not vol-
unteer "specific comments. Detailed comments from the other three are ex-
pressed below.
One person felt that an historical status of laws (e.g., enacted, repealed, un-
constitutional) would be desirable. Dates and other related information asso-
ciated with such a status report would be of use to this person. A summary
of provisions of legal authority, such as that shown in Figure 2, page A-8
would also be desired.
The second person was also interested in an historical status of laws. He was
further interested in accessing information related to legal authorities dealing
with motor vehicle emissions and land use controls.
The third person was particularly interested in information related to suits
filed against EPA that affect the SDPs. For example, this person might want
to access all decisions that affect SO0 regulations.
Lt
7-20
-------
7.5.5 Surveillance
Five people were interested in surveillance information. One of these ex-
pressed only a general interest without any specific preferences. Comments
made by the others are discussed below.
One person was somewhat interested in displays such as those shown in Fig-
ures 8 and 9, pages A-21 and A-22. He indicated that the figures, which show
monitoring station locations and monitoring techniques, would be more useful
if quality control information related to the monitoring equipment could be in-
cluded. He indicated a desire for a map that might display all monitoring sites
within a certain distance from a source. Such a map might be output, he felt,
either via an incremental plotter or a cathode ray tube display.
Two people expressed an interest in Figures 9 and 10. One of these felt that
monitoring site locations, updated as new information becomes available via
semiannual reports, would be of value.
The last person expressed an interest in Figure 9 information. He was pri-
marily interested in monitoring site locations within a particular area. He
indicated he would then utilize SAROAD to get more specific information.
7.5.6 Intergovernmental Cooperation
Interest in this category was expressed by seven people. Interest appeared to
be primarily related to intrastate cooperation, rather than interstate. Six of
the seven expressed an interest in a table of state versus local responsibilities
for various regulatory functions. One of these was also interested in accessing
text displays from this portion of the SIPs. This person also wanted to see
where agreements exist between states, with some indication of the type of
agreement (i.e., memos, laws, etc.). Another of these who was interested in
a table of state versus local functions felt that this information would be useful
for Air Pollution Control Program Grant purposes. The seventh person was
7-21
-------
primarily interested in names, addresses, and organization charts that would
aid in establishing responsibility between various intrastate agencies.
7.5.7 Emergency Episodes
Five people were interested in accessing information related to emergency
episodes. Two of these were interested in a general sense only, and made no
specific comments.
One of the other three interviewees expressed an interest in accessing the
first 10, 25, 50, etc., point sources that would be subject to control in a
particular area during an emergency episode. The number of sources would
be an input parameter to the computer run.
Comments from the other two are given below. Both were interested in the
following information: a display that summarizes what control action is to be
imposed for a particular stage by source type (Figure 6, page A-18), abstracts
of contingency plans including control programs required of certain point
sources, tabulations of prohibitions or restrictions of various activities during
emergency episodes, exemptions of certain source categories from control, and
information related to the people who have responsibility to combat emergency
episodes. One was interested in abstracts of contingency plans. This person
was also interested in accessing episode levels on an historical basis, to use
them as a predictive tool. The other person expressed considerable interest
in the subject of emergency episodes, and indicated that when he required infor-
mation it was needed very quickly. For the most part he had already compiled
much of the information, which is kept on file for ready update and access.
Therefore, it is not clear that a computerized system would benefit such a per-
son. His further comments and requirements have been included so all survey
responses could be included in this report. He indicated an interest in a table
of emergency source categories, as shown in Figure 7, page A-19. Questions
that arise when an emergency occurs, to which he must respond, are as fol-
lows: When were the monitoring instruments in the area last calibrated? How
7-22
-------
reliable is the reading and how qualified is the operator ? What contingency
plans are supposed to be enacted ? What is actually being done ? Will there be
any requirements for EPA inspections ? Much of the information that is re-
quired is not in the SIPs. He also noted that air quality information would be
required on at least a daily basis during emergency episodes.
7.5.8 Compliance Schedules
Eleven interviewees expressed an interest in compliance schedules. As indi-
cated for Washington/Las Vegas interviewees, while there is considerable
interest in the subject of compliance schedules, most people intend to use CDS.
Therefore, no strong interest was shown in computerizing SIP information re-
lated to this area.
One person expressed an interest in compliance schedules related to area
sources. Several interviewees indicated that daily turnaround would be re-
quired for CDS runs in their region.
7.5.9 New Sources and Modification of Existing Sources
Four interviewees were interested in this category. Three expressed a general
interest, without mentioning any specific requirements. The fourth was inter-
ested in information related to permit systems. He expressed an interest in an
inventory of new sources by various categories, and felt that this could be han-
dled via NEDS and CDS. He also expressed an interest in new or modified
sources that might be exempted from applicable regulations.
7.6 USES OF NEDS, SAROAD, AND OTHER DATA BASES
7.6.1 Introduction
In addition to determining requirements related to a potential SIP information
system, a secondary objective of this survey was to determine the interaction
of such a system with NEDS, SAROAD, and other data bases. "Interaction"
refers to the use, in one computer query, of two or more data bases, such as
7-23
-------
a proposed SIP data base and NEDS. To assist in determining interviewee
opinion regarding the interaction of a proposed SIP data base and other data
bases, questions were asked concerning the use of these other databases.
7.6.2 NEDS and SAROAD
Table D-19 shows current use of NEDS and SAROAD for Durham, Washington
and Las Vegas, and the four regional offices that were surveyed. In this table,
interviewees who specifically responded as using or not using these data bases
are shown. Others who did not specifically respond can be assumed not to use
either data base. Several interviewees, not shown in this table as users, esti-
mated that future use of NEDS would be made when new NEDS programs, cur-
rently being developed, are available.
7.6.3 Other Data Bases
Tables D-20 through D-22 show the use of other data bases for Durham,
Washington and Las Vegas, and the Regional Offices, respectively. The term
"data bases" is used in its most general sense in the context of this paragraph.
For the most part, interviewees were using data provided in printed form from
the various organizations listed in these tables, rather than using computerized
data bases. The National Air Data Branch does have tapes of data supplied by
these organizations, and can provide selective printouts for certain categories
of information. One purpose of this survey, not specifically related to the pro-
posed SIP information system, was to discuss the availability of these data
bases with interviewees. The Compliance Data System (CDS) is not included
in these tables, but is discussed instead under the Compliance Schedule portions
of this report.
Bureau of Census data usage has some relevance to a proposed SIP information
system, because demographic data is contained, at least to some degree, in the
SIPs. A significant number of interviewees (37 percent) use Bureau of Census
data in their work. Most interviewees felt that demographic data contained in
7-24
-------
the SIPs should not be computerized, because Bureau of Census data was suf-
ficient for their needs. In addition, current demographic data are available via
the Bureau of the Census, while any SIP data is base line in nature.
No interpretation of the remaining data presented in Tables D-20 through D-22
is attempted, because they do not specifically relate to a proposed SIP informa-
tion system.
7.7 GENERAL QUESTIONS
Nearly all the SIP-related questions asked fell into the nine major categories
that have been discussed. Several general questions were asked that did not
fall into any major category. One of these related to interest in an indexing
capability. Such a capability would not be utilized for portions of the SIPs that
are to be computerized in full-text form. For other portions, such a capa-
bility would provide a means to input a key word or topic, and receive page,
section, or subsection references. These references would then enable the
user to access his area of interest via a set of printed SIP volumes. Results
of the question related to indexing are displayed in Tables D-l to D-3. Thirty
people, or 58 percent, expressed an interest in such a capability.
Survey response to other general questions is not tabulated in Appendix D. Dis-
cussion and recommendations related to these questions are provided in Sec-
tion 8.4.6.
7-25
-------
SECTION 8 - RECOMMENDATIONS
8.1 INTRODUCTION
This section presents recommendations concerning computerization of the SIPs.
It includes a discussion of what sources of information should be considered as
a basis for an SIP information system. It also discusses the need to establish
a systematic procedure to update such an information system. Along with this,
it discusses survey results that relate to frequency of update and opinions re-
garding who should have the responsibility for performing the update. Specific
recommendations, based upon survey results, are made regarding the portions
of the SIPs that should be computerized. These recommendations are made in
view of the interaction between a proposed SIP data base and other existing and
proposed data bases. Additional discussions and recommendations are made
concerning how such a data base might be accessed.
8.2 SIP INFORMATION SYSTEM RECOMMENDATIONS
8.2.1 Interest in Computerization
All 19 of the EPA personnel interviewed at Durham were interested to some
degree in a computerized SIP information system. Eight of the 13 interviewed
in Washington and Las Vegas, and 14 of the 24 people in the regional offices
were also interest in the proposed SIP information system. All 12 of those
who expressed little interest did voice some opinions regarding the portions of
the SIPs most desirable to computerize. Most of these people indicated they
would access a computerized data base if it were available.
8-1
-------
8.2.2 Estimated Frequency and Volume of Use
Results from Tables D-13 through D-15 are combined and presented below.
Estimated Frequency of Use
Survey Data
Survey Data Extrapolated
Daily or more frequently 8 11
Weekly 15 24
Monthly 13 19
Semiannually 1 1
Annually 3 3
Total 40 58
Twelve interviewees are not included in this total; most of these indicated
they would use an SIP information system; however, they were unable to esti-
mate their frequency of use.
The data in this table represents only the sample interviewed, not all of EPA.
Four of 10 regional offices were surveyed. The regional results might there-
fore be multiplied by 2-1/2 to reflect all 10 offices; this procedure was used
to obtain the data presented in the "Survey Data Extrapolated" column. No
basis for a similar extrapolation for those people in Washington or Durham
who might use an SIP information system but who were not interviewed is
available. Therefore the data presented above represents a least upper bound.
In addition, one interviewee who estimated daily or more frequent usage in-
dicated that about 30 queries per day would be submitted in his area if some
computer output could be obtained within hours and the rest of the output ob-
tained within a day. Another user estimated five queries a day would be sub-
mitted from his area. If these additional totals are included, and all requests
are put on a daily basis, more than 50 queries per day would be submitted.
The estimated 30 queries per day from this one potential user clearly dominate
8-2
-------
the projected daily usage figure. However, if this user's requirements are
discounted, the estimated usage still amounts to more than 20 queries per day.
This lower projected usage is sufficient to warrant an automated SIP informa-
tion system.
8.2.3 Recommendation to Pursue Computerization
Based on the survey results of an estimated minimum submission of 20 jobs
per day, it is recommended that a computerized SIP information system be
pursued further. Recommendations specifically related to the major SIP cate-
gories and to the general areas are discussed in Sections 8.5 and 8.6.
8.2.4 Time Requirements for Implementation
Nearly all interviewees who indicated a date by which they desired to have an
SIP information system available for use stated that they could use such a
system as soon as it could be made available. Several people noted that be-
cause clean air standards are to be met as early as 1975, an SIP information
system should be available no later than autumn 1974. They felt that the pri-
mary need for such a system would be before the target dates designated for
achievement of the primary standards.
Several interviewees further stated that if an SIP information system could not
be made available before 1975, there would be little value in its implementa-
tion after January 1975.
Survey results were not entirely conclusive on this point, however. It was
stated or inferred by several others, for example, that while clean air stand-
ards are to be met as early as 1975, the process of meeting them will continue
over a period of years with corresponding revisions occurring to the SIPs.
It was further stated that even after air quality standards are met for the major
pollutant classes, SIP revisions will still be required in other areas, such as
transportation controls and hazardous pollutants.
8-3
-------
It is recommended that any implementation of an SIP data base be scheduled,
if possible, to be completed no later than the last quarter of 1974. It is further
recommended that any implementation that would not be completed before 1975
not be undertaken unless a subsequent survey indicates that new capabilities
would still be of use at that time. Such a survey could be conducted quickly by
telephone of no more than five or six of the most frequent potential users.
8.3 BASIS FOR SIP INFORMATION SYSTEM
During the course of conducting this survey for EPA, it became apparent that
the SIPs cannot be conceived as static documents. Even the concept of docu-
ments initially issued, which undergo update and revision, is not entirely suf-
ficient. To include all possible sources of information that define the SIPs, it
is necessary to look beyond the basic documents and both State- and EPA-
promulgated revisions.
8.3.1 Evaluation Files
During the initial EPA evaluation of the SIPs, considerable data were accumu-
lated concerning the plans that are not part of the SIPs themselves. These data,
referred to as evaluation files, are potentially part of an SIP information sys-
tem.
8.3.2 Interpretive Material
The process of working with SIPs and SIP-related information has caused inter-
pretations of these plans to be formulated. The most obvious form of interpre-
tation is that issued via the courts. Court decisions probably constitute the best
defined and most readily available of all the interpretive material related to the
SIPs. However, people within EPA have developed and acquired additional
interpretive information that supplements SIPs and their published updates.
This interpretive material is potentially part of an SIP information system.
8-4
-------
8.3.3 Periodic Reports
As previously noted, the SIPs are documents that are undergoing changes and
revisions. This is particularly true in the area of rules and regulations and
compliance schedules. In other areas, such as resources and surveillance,
baseline information provided in the SIPs has not always been updated via SIP
revisions or, if updated, not updated frequently. Individuals who are concerned
with accessing data such as the current number and location of monitoring sta-
tions in a particular AQCR would not normally refer to the appropriate SIP or
SIPs. Instead, the information would usually be obtained from a source or
sources within EPA who were known to have acquired up-to-date information.
Possible sources of this information are periodic reports issued by the states
and by EPA that update baseline SIP information. Such a report is the First
State Implementation Plan, Semi-Annual Progress Report for January 1 to
June 30, 1973. Periodic reports are, therefore, potentially part qf a SIP infor-
mation system.
8.3.4 County, City, and Local Codes
In some instances, certain implementation plan responsibilities have been
delegated to city, county, and various other jurisdictions within a state. For
this reason, certain applicable rules and regulations that are not part of the
SIPs and not federally enforceable might not be found in SIPs but, instead, are
located in city or county codes or ordinances. To obtain all SO regulations
X
for oil and coal, for example, it was necessary for one person at EPA
Washington to access information from New York City Rules and Regulations
and various other local regulations not in the SIPs. This survey has indicated
that such an example might represent a typical query of a potential SIP data
base. It appears, therefore, that such a data base, to be complete, should
include such interstate codes.
8-5
-------
8.3.5 Summarization
In this section, an effort is made to identify the various sources, in addition
to the basic SIP documents, that might constitute the basis for a potential SIP
information system. Potential sources of information from which a SIP data
base might be defined are:
Basic SIP documents
State-issued updates and revisions
EPA-issued updates and revisions
Evaluation file data
Interpretative information, including the results of court decisions
Periodic EPA and state reports
County, city, and local codes
This list is believed to be complete; however, other sources of information
might exist.
Before starting the computerization of any portion of the SIPs, the elements
that comprise such a system must be defined specifically. It is recommended
that this basic and essential step be taken as an initial activity of the SIP infor-
mation system development.
8.3.6 Establishment of a Definitive Set of SIPs
During the course of the survey, it became apparent that there is no single,
definitive set of SIPs within EPA. EPA Washington, EPA Durham, and the
Regional Offices maintain their own individual sets of SIPs. While these sets
might be updated carefully and frequently, it was agreed generally by inter-
viewees that no standardized procedure or timetable for updating exists. It is
recommended that a definitive set of SIPs be identified or established before
any effort to pursue computerization is begun.
8-6
-------
8.4 UPDATING PROCEDURES
8.4.1 Development of Manual System
In conjunction with establishing the sources of information that are to constitute
the basis for an SIP information system, it is desirable to create a data base,
in the form of printed documents, before investigating computerization of any
of the information. Additionally, before computerization, this SIP data base
should undergo regular updates. This will identify any problems related to the
flow of updating information before making such a system generally available.
Specifically, this process would identify the length of time that elapses between
the origination of new data items and their incorporation into the data base.
If the elapsed time is longer than desired, steps could be initiated to reduce
the time required to update. It is axiomatic that, unless an information system
can be established in document form, accessed from a file cabinet, and updated
"by hand, " it will be impossible to perform comparable processes via computer.
Computerization of a manual system of this type adds additional possibilities
of error and ambiguity (e.g., incorrect transcription of data to load sheets,
keypunch errors, and nonstandard filing procedures). It is desirable to identify
and correct as many potential problem areas as possible before the development
of a computerized system. Therefore, it is recommended that the basis for the
SIP information system be established and a process for updating such a system
be established and tested before computerization is pursued.
8.4.2 Frequency of Updating
Any information system, regardless of its software sophistication, is only as
good as the data available in its data base. The time interval between when new
data are obtained and when new data are placed in the data base must be min-
imized to provide an optimal user-oriented capability.
8-7
-------
Most of the people interviewed for this survey who desire to access rules and
regulations feel that this portion of an SIP data base should be updated as soon
as new information is received. Rules and regulations represent the area of
strongest user interest, and it appears that updating of regulations should take
place as often as weekly. This assumption is based on the comments of several
interviewees, who felt that revised regulations might be published on an average
of once a week in the Federal Register. To make weekly updates meaningful,
a system of information transmission would have to be developed to get all
the requisite information to the updating organization in a timely fashion. In-
deed, this is necessary regardless of update frequency.
8.4.3 Organizational Responsibility for Updating
Interview results concerning where the responsibility for updating should reside
were not conclusive. Regional office personnel expressed a willingness to
perform the updates; Washington and Las Vegas felt that updates should be per-
formed centrally, i.e., in Durham where the data base would be located.
Durham interviewees were closely divided between a preference for regional
and central updating. Several regional interviewees felt that they would be
doing as much work by sending updates to a central location as they would be
doing the updates themselves. No clearcut recommendations can be made on
where the updating should be performed on the basis of the survey inputs.
A meaningful compromise is indicated in which the regions and the local EPA
personnel would validate and prepare the data in the format required by the
SIP system and Durham would be responsible for actually putting the new data
into the master data file. This procedure emphasizes the distinction between
the mechanics of updating and the responsibility for updating. The former in-
volves data gathering, entry of data onto coding sheets, key punching, verifying,
submission of computer runs to enter the data onto the data base, and various
checking or verification processes. The mechanics can, and generally are,
8-8
-------
handled by different parts of an organization to eliminate bottlenecks. Thus,
in the case of a computerized SIP data base, all phases except the actual update
job submission might be accomplished at the state and regional level. Verifi-
cation of the goodness of the data could take place at one or several levels.
Responsibility for updating is associated with actual job submission to perform
the update (i.e., modify the data base).
There must be a centralized responsibility for preservation of the integrity of
the data base, regardless of where and by whom the updates are performed.
8.5 RECOMMENDATION CONCERNING MAJOR SIP CATEGORIES
8.5.1 Introduction
In this section, recommendations are made concerning data base development
for the nine major SIP categories. Recommendations made in this section are
based on the survey results presented in Section 7.
8.5.2 Rules and Regulations
8.5.2.1 General Recommendations
It is recommended that computerization of the rules and regulations portion of
the SIPs be addressed. Due to the high degree of user interest, computeriza-
tion of the regulations portion of the SIPs should be addressed as the first
priority item. While more interviewees preferred abstracts or summaries of
regulations than preferred full text, estimated frequency of use data indicates
that more inquiries would be made requiring access to full text.
In addition, several interviewees indicated that only full-text versions of rules
and regulations would be satisfactory for their needs; they felt that summaries
and abstracts might not be sufficiently accurate. For these reasons, it is
recommended that data base development be considered on a full-text basis
for rules and regulations.
8-9
-------
EPA- or state-promulgated
By type of regulation (i.e., control regulation, variance type, per-
mit type)
By source exclusion (i. e., the sources that are not included in a
regulation)
By permit (i.e., the sources that do or do not require permits)
By local regulations that are more stringent than state regulations
By confidentiality of data (i.e., throughput of emissions)
By status (i.e., approved or disapproved)
The ability to access regulations with two or more parameters, all of which
might apply, would be essential (e.g., pulp and paper mills with 100 tons of
emissions). Such a list could be longer, as this list undoubtedly does not
include all possible parameters by which to access certain regulations. Survey
results indicate, however, that access by the first nine items in the list would
satisfy most potential users. It is, therefore, recommended that access be
provided initially by these first nine parameters. Additional capabilities could
be provided at a future date. To do this, the design of the data records must
be such that all parameters that might be utilized in the future are provided in
the record. A list of itemsnot specifically parameters by which regulations
might be accessed, but meaningful data items that interviewees expressed a
desire to seeis provided below. Provision for these items, which might not
be part of the regulations themselves, might be made in the data records.
Date the regulation was adopted
Attainment data associated with the regulation
To whom does the regulation apply (i. e., supplier or user); there
might be different effective data related to suppliers and users
8-11
-------
EPA- or state-promulgated
By type of regulation (i.e., control regulation, variance type, per-
mit type)
By source exclusion (i. e., the sources that are not included in a
regulation)
By permit (i.e., the sources that do or do not require permits)
By local regulations that are more stringent than state regulations
By confidentiality of data (i.e., throughput of emissions)
By status (i.e., approved or disapproved)
The ability to access regulations with two or more parameters, all of which
might apply, would be essential (e.g., pulp and paper mills with 100 tons of
emissions). Such a list could be longer, as this list undoubtedly does not
include all possible parameters by which to access certain regulations. Survey
results indicate, however, that access by the first nine items in the list would
satisfy most potential users. It is, therefore, recommended that access be
provided initially by these first nine parameters. Additional capabilities could
be provided at a future date. To do this, the design of the data records must
be such that all parameters that might be utilized in the future are provided in
the record. A list of itemsnot specifically parameters by which regulations
might be accessed, but meaningful data items that interviewees expressed a
desire to seeis provided below. Provision for these items, which might not
be part of the regulations themselves, might be made in the data records.
Date the regulation was adopted
Attainment data associated with the regulation
To whom does the regulation apply (i. e., supplier or user); there
might be different effective data related to suppliers and users
8-11
-------
Expression of regulations in terms of common units
Regulations that give delegated authority regarding new source
performance standards
Test methods (i.e., method by which a test value was determined)
8.5.2.4 Recommendation Not to Provide Historical Capability
Some interest was displayed in the ability to access noncurrent regulations
(an "historical" capability). This interest was not sufficiently strong to justify
the added storage requirements necessary to support such a capability. It is,
therefore, recommended that an historical capability to access rules and reg-
ulations not be pursued at this time.
8.5.2.5 Recommendations Concerning Indexing, Abstracts, and Summaries
Assuming that a full-text capability for regulations is developed, it is felt that
there would be little justification for an indexing capability for either regula-
tions or for abstracts of regulations. The ability to access specific regulations
and groups of regulations via the parameters previously described should
obviate the need for a separate indexing capability. To provide abstracts,
when full text is available, would be redundant. It is, therefore, recommended
that indexing and abstracts of regulations not be implemented.
There was considerable interest in summary tables of rules and regulations;
some interviewee-submitted samples are included in Appendix E. The compact,
tabular format of this type of presentation is sufficiently different from full text
that, if both were made available, no redundancy would result. It is recom-
mended that the development of summary tables be pursued on a lower priority
basis than full-text development.
8.5.2.6 Additional Recommendations
Recommendations for SIP information system development have thus far related
to full text and summaries of regulations and how such information might be
8-12
-------
categorized or defined. An additional capability of interest relates to the dis-
play of the number of regulations, as opposed to the. full text of these regulations,
that apply to categories previously listed. A user might, for example, request
the number of regulations that relate to SO . Assuming that the result was a
x
rather large number, the user might then request the number of SO regula-
.X
tions for a specific AQCR. Assuming a tractable number resulted, a third
query could be made to access further details regarding these regulations.
The survey indicates that unless results from queries such as those described
above can be provided within a short time (i.e., minutes or an hour), such a
capability would have little value. To be meaningful, such a capability would
have to be provided on a rapid turnaround, perhaps interactive, basis. Because
such an option would be a useful adjunct to a full-text capability, it is recom-
mended that it be investigated. It is further recommended that it be implemented
only if it can be provided on a rapid turnaround basis.
8.5.3 Control Strategies
8.5.3.1 Discussion
Interest in this category was related primarily to the air quality and emissions
data on which the control strategies in the SIPs were based. These data are
available in the SIPs in varying levels of detail. These data are not identified
as baseline SIP data in NEDS and SAROAD, and thus are not readily available
via either system. Interviewees expressed an interest in accessing this base-
line data to examine the control strategies set forth in the SIPs. There was also
interest in the models and techniques used to develop the control strategies.
Interest was also displayed in the percent reduction by pollutant that overall
control strategies would effect. Very little interest was displayed in specific
control strategies; instead, rules and regulations that implement the control
strategies are of primary interest. Some interest was displayed in control
strategy costs associated with both stationary and mobile sources. Such cost
data are not generally provided in the SIPs.
8-13
-------
8.5.3.2 Recommendations
Sufficient user interest was displayed in baseline air quality and emissions data
so such data should be made available. Because the data are, by definition,
static and unchanging, there does not appear to be sufficient justification to
incorporate them into an information system. It is, therefore, recommended
that this baseline data be compiled and published in report form. It is under-
stood that such a report is currently being prepared within EPA. Such a report
could also include information related to the model used for control strategy
development. Modeling results, if available, could also be included. A figure
or table depicting percentage reduction by pollutant, by time could be extracted
from the SIPs and published. It is not recommended that any computerization
of the control strategy portion of the SIPs be pursued at this time.
8.5.4 Surveillance
8.5.4.1 Discussion
Interest in this category was centered about the number of monitoring stations,
monitoring station locations, and information related to monitoring techniques.
Interviewees were interested in current information, rather than the baseline
data contained in the SIPs. Some interest was displayed in quality assurance
data such as calibration of sampling instruments; however, this type of infor-
mation would generally not be available via the SIPs.
Certain information related to current monitoring site locations is contained
in the National Aerometric Data Bank (NADB), and is available via the SAROAD
system. This information, which was of general interest to interviewees, in-
cludes site locations, monitoring station types, site elevations, and supporting
agency information. Current information related to the number of monitoring
stations, existing and proposed, is contained in the State Implementation Plan
Semi-Annual Progress Reports.
8-14
-------
8.5.4.2 Recommendations
There was no discernible interest in full-text access of the surveillance portion
of the SIPs. SAROAD and the SIP Semi-Annual Progress Reports provide an
existing source of current monitoring site information. The basic SIP docu-
ments do not provide current information, but instead contain baseline infor-
mation, which was compiled when the SIPs were first written. Information
related to monitoring locations does not change rapidly; most interviewees
felt that semiannual updates of this information in a proposed SIP data base
would be sufficient. It is recommended, therefore, that no specific computer-
ization of the surveillance section of the SIPs be initiated. It is recommended
that a capability be developed in SAROAD to display monitoring site information
by state or AQCR.
8.5.5 Legal Authority
Interest in computerization of legal authority information was expressed by 15
of 52 interviewees. Interest was primarily in whether a state had provided
itself with sufficient legal authority to obtain compliance with clean air standards.
SIP-related legal authority information does not appear likely to change fre-
quently. For these reasons, it is recommended that no computerization be
initiated for this SIP category at this time.
8.5.6 Resources
Approximately half of the interviewees were interested in resource information.
This interest was primarily related to current information, rather than the
baseline data with projections that appear in the SIPs. Most of the current in-
formation desired would be available from Air Pollution Control Program
Grant information. The latter is not part of a potential SIP data system, but is
itself a potential area for computerization, apart from the SEPs. If the Air
Pollution Control Program Grant information is made available in computerized
form, then it is recommended that baseline SIP resource data be included.
8-15
-------
Another means to make the SIP resource data more readily available would be
to compile and publish it via printed form. It is recommended that no comput-
erization of SIP-related resource information be undertaken.
8.5.7 New Sources and Modification of Existing Sources
Specific interest in this category was expressed by one-quarter of the inter-
viewees. Most of the interest relates to rules and regulations that apply to
new and modified sources. It was previously recommended that one means of
accessing regulations might be by those regulations that apply to new and mod-
ified sources.
The National Emissions Data Bank contains point and area source information
and can be accessed via the National Emissions Data System (NEDS). An
inventory of new sources, in which some intereviewees were interested, might
be provided as an additional capability under NEDS. The SIPs do not specifi-
cally contain new source inventories.
It is recommended that no specific computerization of the new source SIP cate-
gory be undertaken. It is recommended that, if possible, a means be provided
to access new point source information via NEDS. An example might be to
enable a NEDS user to access information related to all sources in a given
jurisdiction that started after a certain date.
8.5.8 Compliance Schedules
About 60 percent of the interviewees expressed an interest in compliance sched-
ules. Almost all of them indicated that the Compliance Data System (CDS),
which is currently under development, should provide sufficient information for
their needs. NEDS is another source of compliance information. Several peo-
ple expressed an interest in more detailed information than they felt would be
provided in CDS; however, this level of detail is not available in the SIPs. It
is recommended that no computerization of compliance schedules be undertaken
8-16
-------
as part of an SIP information system. Instead, it is recommended that CDS
be utilized as the primary computerized source of compliance data. If addi-
tional detail is needed, means to provide it should be pursued, preferably within
the CDS or NEDS systems.
8.5;9 Intergovernmental Cooperation
Interest was primarily related to the intrastate aspects of this category, rather
than interstate. Interest was expressed in being able to identify the agency
(i.e., state or local) that has the authority for various regulatory authorities.
Tables providing this sort of information are available in some, but not all,
SIPs. Due to their somewhat static nature, such tables are not prime candidates
for computerization; however, they might be compiled and published in docu-
ment form. No computerization is recommended for this portion of the SIPs.
8.5.10 Emergency Episodes
Interest in this category was comparatively slight. One reason for this is that
regional office personnel who are concerned with emergency episodes have most
of the required SIP material readily available in printed form. In addition, the
frequency of emergency episodes is expected to decrease; ideally, no more
will occur after 1975. Thus, the category of emergency episodes is expected
to lose importance in the future. Due to the slight amount of interest, it is
recommended that no computerization be undertaken for emergency episode
SIP-related information.
8.6 COMPUTERIZATION OF GENERAL AREAS
8.6.1 Indexing
As noted before, a majority of those people interviewed (58 percent) expressed
an interest in an indexing capability. It has been previously recommended that
the computerization of rules and regulations be pursued, and it was also recom-
mended that no indexing of regulations be undertaken. Indexing would help
8-17
-------
overcome the diverse nature of the SIPs by providing a means to access all
references to one particular topic. Yet the diversity and lack of consistent
organization would make the task of indexing the SIPs quite difficult.
Due to the level of interest in this area, it is felt that it should be pursued
further. An indexing capability might be implemented as follows: An effort
to compile and print indexes could be attempted for a small number of SIPs
(e.g., those in one EPA region). This would take the form of printed material,
similar to the index of a textbook. After a trial period of use in the state or
region and EPA headquarters, it could be determined if the indexing effort
should be expanded to include all SIPs and, if so, if such a capability should
be computerized. The job of compiling indexes by hand would have to be under-
taken as a first step to computerization and, thus, would not be a wasted effort
if the decision for computerization was made.
If a computerized indexing capability is developed, it is felt that it should be
made available on a rapid job turnaround basis. Rather than wait most of a
day or overnight for page references via computer, most users would instead
go directly to the printed SIP to find the desired material. A potential problem
associated with this approach is in making such a capability available in a timely
fashion (i.e., before 1975).
8.6.2 Other Areas
Some interest was shown in a display of AQCR priority level (I, II, or in) by
pollutant type by AQCR. A sample of such a display is given in Figure 1 in
Appendix A. Those who did not want such a table computerized generally felt it
was unnecessary, because the information is contained in the Federal Register
or had been compiled within EPA. Others felt that it should be computerized
for ready availability throughout EPA, and so its update could be handled
centrally.
8-18
-------
A summary showing the number of AQCRs in each priority classification by
pollutant is given in the First SIP Semi-Annual Report, January 1 to June 30,
1973, page 28. A priority classification of AQCRs by pollutant is provided in
The National Air Monitoring Program; Air Quality and Emissions Trends
Annual Report, Volume I, EPA 450/1 -73-OOla, August 1973. Because these
references should provide sufficient sources of information, it is recommended
that this information not be computerized.
General questions were asked that related to computerization of population data
contained in the SIPs, comparison of differing air quality standards within a
state, and communications between EPA and the states. Users expressed a
preference for Bureau of Census-supplied population data, and it is therefore
recommended that SIP-contained population data not be computerized. There
was no appreciable interest in comparisons of differing air quality standards
within a state. Most people queried felt that EPA standards were of greater
significance than state standards. It is, therefore, recommended that this
area not be computerized. It has previously been recommended that the basis
for an SIP information system be established, and that state/EPA communica-
tions be considered part of that basis. It is, therefore, recommended that no
separate computerization of letters and communications be undertaken.
8. 7 PROTECTION OF DATA
8.7.1 Accessing Data
Interviewees were asked if they felt data contained in an SIP information system
should be protected by a password or some other identification procedure before
allowing user access. All but one or two people felt that this was not necessary,
indicating that no proprietory data was contained in the SIPs. Those who felt
that some sort of protection was desirable, mentioned that certain types of
emissions data might be considered proprietory. It is not recommended that
any SIP emissions data be computerized; therefore, no protection for accessing
emissions data is required.
8-19
-------
8.7.2 Information System Updating
All interviewees questioned agreed that a potential SIP information system
should be protected in some fashion against inadvertant destruction of data.
Implicit in this is the need to have the authority to modify data limited to desig-
nated individuals.
8. 8 QUERY CAPABILITY
8.8.1 Access
Interviewees were asked how they wished to access an SIP information system
in terms of computer job submission. Suggested ways were via batch jobs
using fixed input data formats, and/or via a set of 5 to 10 input questions that
would define the type of report to be produced. The latter method would lend
itself readily to interactive terminal job submission. Most interviewees did
not express firm opinions regarding these questions, and no conclusive reaction
was recorded.
8.8.2 Output
Interviewees were asked if they preferred computer output in some form other
than computer printout. Possible alternatives suggested were printer plots
and graphics displays via cathode ray tube (CRT). Slightly more than one
quarter of the interviewees indicated they would prefer CRT output. Two peo-
ple indicated that incremental line plots might be useful. Those who expressed
an interest in CRT output seemed to associate this type of output with rapid job
turnaround, rather than as a distinct output means.
8.8.3 Recommendations
No specific recommendations are made regarding input/output devices and
means of job submission on the basis of answers to related survey questions.
It is felt that turnaround requirements dictate, to some degree, the type of
I/O devices that should be considered. Due to the large percentage of responses
8-20
-------
that are desired within hours, it is felt that some type of rapid turnaround must
be provided. Most interviewees felt that a priority system was necessary to
meet their requirements.
If a priority system cannot quarantee turnaround of some queries within hours,.
then it is recommended that an interactive capability be considered. Interactive
typewriter terminals could provide users with the capability to receive small
amounts of printout directly via the terminal. Larger quantities of output, on
which overnight or longer turnaround should be satisfactory, would be provided
via the central computer printing facility.
Interactive terminals lend themselves readily to the question-and-answer format
of unstructured requests. The latter, in turn, seem to be well-suited for the
specification of rules and regulations. The nine parameters by which regula-
tions could be accessed would provide a basis for such questions.
An interactive capability, by which users might display rules and regulations
on a CRT and scan the text of the regulations by the execution of keyboard com-
mands, appears to be an attractive alternative to some types of batch proc-
essing. An advantage of this type of display is that it eliminates printing
large quantities of output, which might be read only once and then discarded.
It is possible to have a selective printing capability associated with graphics
scanning, so that users can selectively print only the displays which are of
interest. It is recommended that, after interactive terminal capabilities
regarding rules and regulations are investigated, interactive graphics be in-
vestigated further.
8-21
-------
APPENDIX A - QUESTIONNAIRE, SURVEY OF EPA USER
REQUIREMENTS REGARDING STATE IMPLEMENTATION PLANS
This appendix contains a sample survey questionnaire.
A-l
-------
Date of Interview
I. Background Information
A. Person being interviewed*
Name:
Title:
Telephone: ( ) Ext.
B. EPA organization represented:
Name:
Address:
C. Job responsibility of person interviewed and mission or role of his organization
(may be obtained prior to interview).
A-2
-------
II. Current Uses of NEDS, SAROAD and Other Data Bases
A. Do you or people in your organization use information from NEDS
and SAROAD in your current work? (If no, skip to II, B)
1. If so, which, or both
NEDS
SAROAD
2. How frequently are they utilized for similar types of requests?
3. How frequently are they utilized for all types of requests ?
4. How are the computer runs made, or initiated?
via the National Air Data Branch
via the regional office
made by yourself, or someone from within your immediate
organization.
5. How are the computer outputs obtained?
remote batch
dial up batch
interactive terminal
6. What particular reports/data are obtained?
7. Are the means by which the computer outputs are obtained
satisfactory?
8. Could they be improved by:
a. Being provided more quickly
b. More readable format
c. Other
A-3
-------
B. Would NEDS and/or SAROAD have been used if any of the following
capabilities had been available ?
1. Additional reports ?
a. What type ?
b. How frequently ?
2. Existing reports made available more frequently?
a. Which reports ?
b. How frequently ?
3. Existing reports presented in a different format?
a. Which reports ?
b. What kind of format ?
C. Have you used any other data bases ? (if no, skip to Section III).
D. Have you used any of the following data bases and, if so, for what purpose ?
1. Bureau of the Census
2. GSA Property
3. Form FPC-67
4. Dun and Bradstreet
5. Polk Vehicle Registration
6. Federal Facilities Files _
7. Other
A-4
-------
III. SIP's - General Questions
The SIP's must include provisions for at least the following nine major categories:
legal authority, control strategy, compliance schedules, emergency episodes,
surveillance systems, review of new sources, resources, inter-governmental
cooperation, and rules and regulations. Prior to asking questions on each of
these categories, several general questions are covered.
Each AQCR is graded by EPA as Priority I, II, or
HI on the basis of the known or estimated levels
of the six pollutants presently covered by national
standards.
1. Would it be useful to have available survey
information related to priorities vs. AQCR
for each pollutant type? example (Figure 1):
The SIP's usually contain a section which describes the state in
general terms and includes demographic information.
2. Would information related to total population - current and
projected - be useful? If so, how often should it be updated?
3. Would information related to population densities - current
and projected - be useful? If so, how often should it be updated?
4. Would a comparison of differing air quality standards within
a state be useful?
5. Communications between the state and EPA are contained in
the volumes which contain the SIP's. This information may
range from notification of non-compliance with certain standards,
to information regarding forthcoming informal meetings. Should
this information be included in the SIP data base ?
6. Would an index of the SIP be desirable (e. g. a table of contents
with page reference)? If so, would more detail than a simple
table of contents be desirable? How detailed?
A-5
-------
Figure 1
Priority Level by Pollutant Type by AQCR
\ Pollutant
AQCR \TyPe
1
2
3
4
Part.
I
III
SOX
II
II
CO
I
HI
Photo-
Chemical
Oxidants
II
III
HC
I
II
NOX
II
II
A-6
-------
IV. Legal Authority
1. Are you interested in accessing any information regarding the legal
authorities needed to meet EPA requirements? (If no, go to V.)
2. Although the law pertaining to various areas may differ in con-
tent, historical information concerning the law's status could be
presented in similar fashion for all areas. Would a report of such
a historical status (e. g. enacted, repealed, unconstitutional) be
desirable? If so, would information related to the responsible
organization (e.g. court repealed, agency enacted) be useful?
3. In going beyond law status, is any of the following information useful:
a. State code/constitution citations ?
b. Abstracts of the applicable legislation?
c. Full text of the applicable legislation?
d. Case citations upholding or striking down pertinent legislation ?_
If so, full text or abstracts of the case citations
e. Information whether a change made the new law more or less
restrictive than the old .
Some of this information might be depicted as in Figure 2.
4. What requirements are needed for those legal authorities relating to
motor vehicle emissions or land use controls? (list and go to User
Interest Form for each item).
5. Given amendments to laws, enactment of new laws, etc., are provisions
necessary for updating the legal authority information?
6. Should a given state fail to enact needed authority, are any automatically
generated messages or notices needed to identify such a problem ?
7. Are there any other items of interest related to legal authority? (If so,
list and go to interest form).
A-7
-------
State of
Figure 2
. Legal Authority Summary
Summary of Provisions
Statute Expressly Conferring
Specific Power or Regulations
Implementing General Conferral
of Power
1. Adopt emission standards and limitations
and other measures necessary for attain-
ment and maintenance of national standards
23-25-5(d)
2.
etc.
A-8
-------
V. Rules and Regulations
The legal authority discussed earlier usually allows for the promulgation of
more specific rules and regulations to implement the objectives of the enabling
legislation. The rules may come in the form of actual statutes, e.g. municipal
codes, or rules and regulations issued by some state executive department
(e.g. health) or a pollution control agency. The SIP rules and regulations,
therefore, have a variety of differing formats and content.
1. Are you interested in accessing information regarding
rules and regulations? (If no, go on to VI).
2. Would a complete text of a set of rules and regulations
be desirable?
3. Would a summary or abstract of the rules and regulations
be desirable ?
4. Do you need a table of contents of the entire set of rules
and regulations of a state/county/city/region?
5. Would it be desirable to know which set of regulations apply
to a particular pollutant?
6. Would it be desirable to be able to identify which regulations
apply to control strategies, or any other major category in
the SIP's?
7. Are you interested in knowing the source or sources of the
rules and regulations (i.e. state, EPA)?
within a state ?
within a control region within a state ?
8. Would it be desirable to know whether the rule or regulation
had been modified or repealed? (If no, go on to question 15).
A-9
-------
9. Would it be useful to know how the rule changed ?
10. Would it be useful to obtain the former rule ?
11. Would it be desirable to obtain all rules on a particular subject,
e. g. open burning?
12. Would it be desirable to obtain all rules on geographical location/
pollutant combination? e.g. SO emission regulation for a
2*
particular state for particular types of plants.
13. Each set of rules and regulations has its own format. Would a
standardized format, reorganizing each set without omissions
and with ocassional duplications (e.g. the same rule may apply
to more than one section in the standardized format) be of interest?
14. Is there any other pertinent information relating to rules and regula-
tions which could be made more easily available to you ?
A-10
-------
VI. Control Strategies
A control strategy is defined as "a combination of measures designed to achieve
the aggregate reduction of emission necessary for attainment and maintenance of
a national standard." If a control strategy file were to be developed containing
information from all the SIP's, which specific items would interest you? If
none, go to question 3 of this section.
1. Are you interested in accessing any information concerning
control strategies? (If no, go to VII).
Questions 2 through 9 are primarily concerned with the control of stationary
sources.
2. Would a summary table of controlled pollutant vs. source
type or process type be of any use ? (see Figure 3)
3. Concerning actual control strategies (devices, methods and
other measures) for stationary sources, would a comprehensive
table of pollutant-source be of any use ?
4. Regarding the EPA response to each state on its control
strategies, would some type of summary be of interest in
terms of full text or abstract?
5. Should baseline emission rate data (i.e. data used in the
formulation of control strategies) be incorporated into the
SIP data base ? If so, would it be of interest to know how
this data were obtained (i.e. sampling methods, modeling methods)?
6. Should baseline air quality data (i.e. data used in the formulation
of control strategies) be incorporated into the SIP data base ?
7. . Would a summary of how control strategies were formulated and
validated (e. g. use of computer simulation, manual computation,
etc.) be of interest?
A-ll
-------
8. Regarding the method employed in estimating control effective-
ness and the results of the estimation, would this type of information
in a tabular form be of interest?
9. Would the information concerning the installation and operating costs
for applying the controls for stationary sources be of interest?
Questions 10 and 11 are related to mobile sources.
10. For mobile source, primarily automobiles, what type of information
would be useful concerning control strategies (e.g. exhaust emission
control system, parking restriction, etc.)?
11. Would the costs associated with the mobile source control strategies
be of use ?
12. Is there other pertinent information concerning control strategies ?
A-12
-------
Figure 3
Percentage of Control
(Pollutant vs. Source Type)
\
Fuel
combination
Industrial
process
Solid
waste
disposal
SOX
55%
CO
Part.
HC
NOX
Photo-
chem.
oxidants
A-13
-------
VII. Compliance Schedules
The compliance schedules in individual SIP's vary considerable from generalized
statements regarding dates when standards will be met to detailed tables indicating
sources, outputs, projected outputs and dates for attaining compliance, etc.
1. Are you interested in accessing any information regarding
compliance schedules? (If no, go to VIII).
2. Are you presently using the Compliance Data System (CDS),
which is handled by OSI. (If no, G. Nehls describe CDS,
go to 4). (If yes, continue to 3).
3. Is there any information contained in the SIP'S and not
available in your present data system that would be of
interest to you? (list and go on to 4).
4. Are provisions for hearings (date, results, summaries, etc.)
necessary ?
5. Should information be provided which would tell whether the
compliance schedules were those submitted by the state, or
those enacted by the EPA ?
6. Is any other information of interest concerning compliance
schedules? (list and go to interest form).
A-14
-------
VIII. Emergency Episodes
In heavily polluted areas, consideration must be given to the emergency measures
needed when the pollution level threatens to reach or exceed the danger point.
Such occurrences are referred to as episodes.
1. Are you interested in accessing any information related to
emergency episodes ? (If no, goto DC).
2. Some states have submitted contingency plans for Priority I
control regions. Would it be useful to know which states have
submitted contingency plans ? (if no, go to 5). If so, would it
be desirable to be able to have available portions of these plans
in full text or abstract form? (select and go to interest form).
3. EPA regulations include a suggested model plan which includes
a first alert stage, a second warning stage, and a third emergency
stage. Would it be useful to be able to obtain episode criteria of
this type for the States? (see Figure 5).
4. Some states have developed emergency control programs for
point sources (usually those emitting >100 tons/year). Would
it be desirable to know if these are available? If so, would it
be desirable to obtain more details ?
5. Would information be useful which summarizes what control
action is to be imposed for a particular stage by source type ?
(see Figure 6).
6. The contingency plan includes control programs to be required of
each stationary source emitting more than 100 tons of pollutants
annually. Would it be desirable to be able to abstract portions
of these programs ? For example, would it be desirable to know
which sources will be inspected during emergency episodes?
A-15
-------
7. Would a table of emergency source categories, possibly by AQCR,
be useful ? These are the sources which would be contacted to
ensure compliance with emission reduction objectives. They
are also the sources which would be inspected during an emergency
episode, (see Figure 7).
8. Prohibitions or restrictions of various activities may be imposed.
Would any tabulation of these restrictions be useful ?
9. Would priorities related to prohibition and restrictions be useful
(i.e. who would be controlled first)?
10. Certain source categories may be exempted from control. Would
it be useful to know which categories would be exempted?
11. Would information related to the closing of industries be useful?
12. Would information related to which people have responsibility to
combat emergency episodes be useful? This might include names, phone
numbers, titles, and organization.
13. Should any full text or abstracts from the SIP's related to emergency
episodes be available ?
14. Are there any other items of interest regarding emergency episodes ?
A-16
-------
Figure 5
Episode Criteria for State of
Stage
Forecast
Alert
Warning
Emergency
Criteria/Action to be Taken
Meterology conditions only
Agency prepare for potential episode
Advise Major Sources
No acute health effects, but preventive action required
Public announcement
Fuel switching
Curtail incineration and burning
Preliminary Health Hazard
Selective curtailment of industrial activities
Dangerous Health Hazard
Major curtailment of all activities in community
A-17
-------
Figure 6
Control Action Summary
State or Region for Alert* Stage
Source of Air Pollution
1. Coal or oil-fired electric power
generating facilities
Control Action
a. Substantial reduction of fuels having
low ash and sulfur content.
b.
c.
2. Coal and oil-fired process steam
generating facilities
a.
b.
c.
3.
etc.
*Note, this report could also be produced for the other episode stages.
A-18
-------
Figure 7
Proposed Emergency Source Categories
Industrial and Steam Electric Power
Food Products
etc.
Commercial Facilities
Construction
etc.
Governmental Facilities
Schools
etc.
Transportation
Autos
etc.
A-19
-------
IX. Surveillance Systems
1. Are you interested in accessing information related to surveillance
systems, including monitoring stations ? (if no, go to X).
2. For a particular monitoring station or group of monitoring stations,
would a table such as the one shown in Figure 8 be useful ?
3. Would a table as depicted in Figure 9 showing the present air
quality monitoring network be useful ?
4. Would the same information related to proposed monitoring stations
be of use ?
5. Would a tabular comparison of the Federal Requirements for the
Air Quality Surveillance Network and the State Proposed Air
Quality Network be useful? (see example in Figure 10). (If so,
note that this information is currently available.)
6. Would the basis for location of existing surveillance networks
be of interest? (see Figure 11).
7. Are there any other items of interest regarding surveillance
systems ?
A-20
-------
Figure 8
Pollutant/ Monitoring Sensor Averaging
Parameter Technique Time
SOX Calorimetric Continuous Hourly
Part
CO
NOX
Total Oxidants
Hydrocarbons
Wind Speed Anemometer
Wind Direction Wind Vane
A-21
-------
FIGURE 9
Station and Location Start-up Ending Pollution Population
Number Date Date Density Density
H M L H M L
1 XX
2 XX
3 XX
4 XX
5 , XX
etc.
A-22
-------
Figure 10
Pollutant Minimum Number of Sites in State Proposed
Federal Monitoring Operation Number of
Sites As Of Monitoring Sites
Sulphur Dioxide
Gas bubbler 5 21
continuous 2 4
CO
A-23
-------
Figure 11
State or AQCR
Basis for Locating Existing Surveillance Network
Location
(City, County)
etc.
Station
Number
1
2
3
etc.
Criteria
123456789 10 etc.
X XXX XXXX
XX XXX X
Numerical criteria are explained by a key
1. Center of city location
2. Residential
3. Accessible
4. Industrial
5. Area of projected growth
6. Request from local residents for sampling,
etc.
A-24
-------
X. Review of New Sources and Modification of Existing Sources
EPA requires that each SIP contain legally enforceable procedures that will enable
the state agency to prevent the construction or modification of any stationary source
that would interfere with attainment or maintenance of a national standard.
1. Will you be interested in any information related to new sources ?
(if not go to XI).
2. Would the full text of this portion of the SIP's be useful?
3. Would an abstract be useful ?
4. Would information regarding permit systems for new and
existing sources be useful? This might include whether a
state has such a system and, if so, what the regulations are
in full text and/or abstract form, (select and go to interest form).
5. Would information regarding registration fees involved in obtaining
permits be of interest?
6. Would any type of inventory of new sources be useful? Such an
inventory could be categorized in many ways, e.g.
a. New sources since a particular date (any interest?).
b. New sources by SIC (any interest?).
c. New sources by SCC (any interest?).
d. New sources by political subdivision (any interest?).
e. New sources by AQCR (any interest?).
f. Other (select and go to interest form).
7. Would any other information related to new sources or modified sources
be useful?
A-25
-------
XI. Resources
Each plan includes a description of the manpower and funds needed to carry
out the plan for five years. The description includes current resources plus
projections of additional resources needed at one, three, and five-year intervals.
1. Are you interested in accessing any information regarding resources?
(if no, go to XII).
2. Would a table of salary estimates for staff agency operation be useful?
(see Figure 12). This information would be that which was provided
in the SIP (i.e. not necessarily current).
3. Would any sort of table of physical resources be useful? For example,
state or county vs. the type of resources with the quantity of each
resource available in the table. Types of resources might include
testing equipment, vehicles equipped with cameras for photographing
emissions, etc.
4. Would any other information related to resources be useful?
A-26
-------
Figure 12
Salary Estimates for
Title . Grade Salary Range
Chief, Division of Air Pollution 99 to
etc.
A-27
-------
XII. Intergovernmental Cooperation
Each SIP must provide for the exchange of all necessary information among the
responsible agencies in each control region whose boundaries lie in more than
one state. Provisions regarding INTRA state cooperation are also included.
1. Are you interested in accessing any information regarding inter-
governmental cooperation? If no, go to Section XIII.
2. Do you presently use any data base which pertains to inter-
governmental cooperation (if no, go to question 4)?
3. Is all the information you desire which is contained in the SIP's
included in your data base ? (If yes, go to Section XII).
4. Should the cooperation and dissemination of information be extended to
INTRA-state communication, plans as well?
5. Would it be of interest to allow for exchange of information between
a) adjacent states and/or regions
b) similar "priority" regions
c) similar "control strategy" regions
d) similar "legal authority" regions?
(select and go to interest form).
6. Are any functions under this category appropriate for "automatic"
dissemination of information via the SIP system, e.g. when a change is
made to data in a priority II region for SOX, should all other similar
regions be notified? (if yes, solicit comments on the other questionnaire).
7. Would an abstract of this portion of the SIP's be useful?
8. Would any other information regarding interstate cooperation be
useful?
A-28
-------
XIII. Additional Comments
Are there any additional comments you wish to make ?
A-29
-------
APPENDIX B - USER INTEREST FORM
This appendix contains a sample User Interest Form questionnaire used in this
survey.
B-l
-------
USER INTEREST FORM
1. Name
2. Question identification
3. Please indicate the time requirement and the order of priority of those
capabilities you wish to be made available.
4. Should this information be categorized by:
EPA region
State
AQCR
Other
5. Would the kind of information you want be preferred in some form other
than computer printout ?
If so, what kind? (i.e., printer plots, graphics displays, published
reports).
6. If submitting a computer job to retrieve this information, what turnaround
requirements do you anticipate?
need it within hours
need it within a day
need it within 2 or 3 days
need it within a week
over a week is acceptable
7. How often do you anticipate you would request this information?
B-2
-------
8. Would your needs be urgent enough so that a priority system (some means
to guarantee you output within a certain time) would be desirable?
9. How frequently do you feel that this portion of the SIP data file should be
updated? That is, what turnaround do you want from the time new data
is submitted until it is on the data file available for access ?
10. Who should perform the updating and what procedure should be employed
(e.g., centralized or regional)?
11. Do you think that this information or data should be protected, say by
some identification procedure for updating and/or accessing?
12. Should the method of data access be interactive, for example:
Q. What portion of the SIP is of interest?
A. a. Legal authority
b. Control strategies
c. Compliance schedules, etc.
Q. What is the geographical area of applicability?
A. a. State
b. AQCR
c. Area (city or county)
Q. What is the category of interest?
A. Assume that "control strategies" were selected for question 1, a
numerical key might be entered which would define the type of
report desired, such as:
a. Detailed report of control strategies for each source
b. Operating costs associated with control strategies
c. etc.
B-3
-------
Q. What is the sub-category of interest?
A. This would further define the report to be produced, and might
specify such things as year, pollutant, etc.
and/or batch mode with standard input specification ?
13. Any other comments you wish to make?
B-4
-------
APPENDIX C - LIST OF PEOPLE SURVEYED
C.I EPA, WASHINGTON
L. Bockh
C. Edlund
J. Montgomery
K. Mullen
G. Parker
E. Peckin
R. Penna
P. Quarles
E. Reich, Esq.
W. Sayers
R. Smith
J. Steyer
D. Tuttle
C.2 EPA, DURHAM
K. Berry
Office of Program and Management
Operations
Division of Stationary Source En-
forcement
Office of Program and Management
Operations
Planning and Review Staff, Office
of Monitoring Systems
Assistant to the Chief of the Enforce-
ment, Surveillance, and Investiga-
tion Branch, Division of Stationary
Source Enforcement
Office of Planning and Evaluation
Mobile Source Enforcement Division
Enforcement Proceedings Branch,
Division of Stationary Source Enforce-
ment
Chief, Enforcement Proceedings
Branch, Division of Stationary Source
Enforcement
Director of Planning and Review
Staff, Office of Monitoring Systems
Office of Program and Management
Operations
Office of Planning and Management,
Economic Analysis Division
Office of Policy Analysis and Ocean
Disposal
Chief, Regulations and Guidelines
Section, Standards Implementation
Branch
C-l
-------
M. Berry
J. Bosch
R. Cole man
J. Crenshaw
D. deRoeck
N. Dunfee
D. Dunbar
N. Edmisten
Dr. J. Hammerle
V. Henderson
A. Hoffman
M. Jones
C. Mears
J. O'Connor
T. Swearington
G. Walsh
A. We he
C. Whitmore
C.3 REGIONAL OFFICES
C.3.1 Region I
N. Beloin
T. Devine
L. Gitto
Pollutant Strategies Branch
National Air Data Branch
Pollutant Strategies Branch
Pollutant Strategies Branch
Evaluation and Support Branch
Chief, Evaluation and Support Branch
Chief, Analysis and Reports Section,
Standards Implementation Branch
Chief, Standards Implementation
Branch
Chief, National Air Data Branch
Monitoring and Reports Branch
Chief, Trends Analysis Section,
Monitoring and Reports Branch
Chief, Strategies Analysis Section,
Pollutant Strategies Branch
Source Receptor Analysis Branch
Chief, Cost Analysis Branch
Pollutant Strategies Branch
Assistant to the Director of the
Emission Standards and Engineering
Division
University of Louisiana
Evaluation and Support Branch
Acting Chief, Technical Assistance
and Planning Section, Air Branch
Chief, Technical Operations Sec-
tion
Chief, Systems Analysis Branch
C-2
-------
M. Knudson
A. Leriche
W. Serovy
M. Storlazzi
W. Walsh
D. White
C.3.2 Region IV
L. Bittner
M. DeBusschere
T. Gibbs
G. Glahn
J. Riley
J. Wilburn
C.3.3 Region V
B. Bolka
D. Maddox
V. Yamada
C.3.4 Region IX
R. Cummins
P. Roncetti
M. Stenburg
Chief, Surveillance Branch
Inventory and Monitoring Section,
Surveillance Branch
Systems Analysis Branch
Chief, Air Branch
Chief, Inventory and Monitoring Sec-
tion, Surveillance Branch
Inventory and Monitoring Section,
Surveillance Branch
Chief, Legal Support Branch
Trends Monitoring Report Coordi-
nator
Chief, Air Programs Branch
Chief, Agencies Support and Eval-
uation Section
Chief, Emergency Episode Control
Center
Chief, Air Enforcement Branch
Air Data Analysis Section, Air
Surveillance Branch
Chief, Programs Support Branch
Chief, Control Agency Evaluation
Section, Programs Support Branch
Chief, Air Section, Surveillance
Branch
Arizona and Nevada Planning Sec-
tion, Planning Branch
Chief, Surveillance Branch
C-3
-------
T. Stumph
P. Wondra
C.5 NERC, LAS VEGAS
E. Schuck
R. N. Snelling
Chief, Compliance Branch
Arizona and Nevada Planning Section,
Planning Branch
Chief, Monitoring Systems Analysis
Office
Chief, Data Acquisition and Analysis
Branch
C-4
-------
APPENDIX D - TABULATION OF RESULTS
The tables in this appendix present the statistical information gathered for use
in this study.
D-l
-------
Table D-l. Interest and Priority for SIP Categories and
Indexing for Durham Interviewees
CATEGORY
LEGAL AUTHORITY
RULES & REGULATIONS
CONTROL STRATEGIES
COMPLIANCE SCHEDULE
EMERGENCY EPISODES
SURVEILLANCE
NEW SOURCES
RESOURCES
INTERGOVERNMENTAL
COOPERATION
INDEXING
INTERVIEWEE
1
1
2
3
2
1
4
1
2
5
1
3
2
6
1
2
7
1
2
8
1
3
2
9
1
2
10
1
2
11
1
2
12
1
2
13
1
2
3
14
1
2
3
15
1
16
1
3
2
17
1
18
1
3
2
19
1
FIRST
1
12
2
0
0
2
0
1
0
SECOND
1
0
5
1
1
3
2
0
1
THIRD
0
0
3
2
0
1
0
0
0
WTED. TOTAL
5
36
19
4
2
13
4
3
2
*
z
<
tr
4
1
2
5
9
3
5
7
8
o
to
LEGEND: BLANK = NO INTEREST
= INTEREST BUT NO PRIORITY ASSIGNED
1 = INTEREST AND FIRST PRIORITY
2 = INTEREST AND SECOND PRIORITY
3 = INTEREST AND THIRD PRIORITY
-------
Table D-2. Interest and Priority for SIP Categories and Indexing for
Washington and Las Vegas NERC Interviewees
CATEGORY
LEGAL AUTHORITY
RULES & REGULATIONS
CONTROL STRATEGIES
COMPLIANCE SCHEDULE
EMERGENCY EPISODES
SURVEILLANCE
NEW SOURCES
RESOURCES
INTERGOVERNMENTAL COOPERATION
INDEXING
INTERVIEWEE
1
1
2
1
3
2
3
1
3
2
4
3
2
1
5
2
1
6
1
3
»
2
7
1
e
2
8
1
2
9
1
2
10
1
11
1
12
3
2
o
1
CO
DC
u.
0
6
3
0
0
3
0
0
0
SECOND
1
1
3
0
0
0
2
2
0
THIRD
1
1
2
0
1
0
0
0
0
WTED. TOTAL
3
21
17
0
1
9
4
4
0
RANK
6
1
2
8
7
3
4
4
8
O
co
LEGEND: BLANK = NO INTEREST
= INTEREST BUT NO PRIORITY ASSIGNED
1 = INTEREST AND FIRST PRIORITY
2 = INTEREST AND SECOND PRIORITY
3 = INTEREST AND THIRD PRIORITY
-------
Table D-3. Interest and Priority for SIP Categories and Indexing for
Regional Office Interviewees
CATEGORY
LEGAL AUTHORITY
RULES & REGULATIONS
CONTROL STRATEGIES
COMPLIANCE SCHEDULE
EMERGENCY EPISODES
SURVEILLANCE
NEW SOURCES
RESOURCES
INTERGOVERNMENTAL
COOPERATION
INDEXING
INTERVIEWEE
1
2
1
2
3
1
2
3
1
4
1
5
1
2
6
3
1
2
7
2
1
8
1
9
1
2
*
3
10
1
2
11
1
12
1
2
3
13
1
3
2
14
1
2
15
1
2
16
'
17
18
19
20
21
(
fe
tr.
u.
i
8
2
1
1
1
0
1
0
SECOND
1
2
4
0
O
1
0
2
1
THIRD
0
2
1
0
0
0
0
2
0
WTED. TOTAL
5
30
15
3
3
5
0
9
2
V.
z
<
D:
.4
1
2
6
6
4
9
3
8
O
LEGEND: BLANK = NO INTEREST
= INTEREST BUT NO PRIORITY ASSIGNED
1 = INTEREST AND FIRST PRIORITY
2 = INTEREST AND SECOND PRIORITY
3 = INTEREST AND THIRD PRIORITY
-------
Table D-4. Interest in Subcategories Under Rules and Regulations
for Durham Interviewees
SUBCATEGORY
GENERAL INTEREST
INDEXING
HISTORICAL
ABSTRACT
FULL TEXT
INTERVIEWEE
1
2
3
.
4
5
.
6
7
8
.
9
.
10
.
11
12
.
13
.
14
.
15
16
.
17
.
.
18
.
.
19
.
^
t-
O
t-
12
6
3
11
3
o
UJ
tr
H
Z
f
63
31
16
58
16
O
UJ
w
UJ
IT
UJ
I-
Z
ae
50
25
92
25
^
z
^
OC
2
3
1
3
t)
en
-------
Table D-5. Interest in Subcategories Under Rules and Regulations for
Washington and Las Vegas NERC Interviewees
SUBCATEGORY
INDEXING
HISTORICAL
ABSTRACT
FULL TEXT
INTERVIEWEE
1
2
3
e
4
5
6
7
8
9
10
11
12
_i
<
o
I-
3
3
6
5
LU
UJ
5
UJ
>
tn
LU
I-
z
^
yz
25
25
50
43
O
LU
u
LU
cc
UJ
1-
Z
ss
27
27
54
46
y
z'
<
CL
3
3
1
2
-------
Table D-6. Interest in Subcategories Under Rules and Regulations
for Regional Office Interviewees
SUBCATEGORY
INDEXING
HISTORICAL
ABSTRACT
FULL TEXT
INTERVIEWEE
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
*
20
21
<
e
6
7
10
6
0
UJ
<
UJ
>
oc
£
29
33
48
29
Q
UJ
K
co
-------
Table D-7. Interest in Subcategories Under Control Strategies for
Durham Interviewees
SUBCATEGORY
GENERAL INTEREST
STATIONARY BASELINE
EMISSIONS
AIR QUALITY
MODELS USED
COSTS
MOBILE
CONTROL MEASURES
ASSOCIATED COSTS
INTERVIEWEE
1
2
3
4
5
6
7
8
9
10
*
11
12
13
14
15
16
17
18
19
TOTAL
14
6
8
7
6
5
2
% INTERVIEWED
73
32
42
37
32
26
11
% INTERESTED
43
57
50
43
36
14
X
Z
<
X
3
1
2
3
5
6
u
00
-------
Table D-8. Interest in Subcategories Under Control Strategies for
Washington and Las Vegas NERC Interviewees
SUBCATEGORY
GENERAL INTEREST
STATIONARY BASELINE
EMISSIONS
AIR QUALITY
MODELS USED
COSTS
MOBILE
CONTROL MEASURES
ASSOCIATED COSTS
INTERVIEWEE
1
2
0
e
3
»
4
5
6
7
8
9
10
11
12
TOTAL
8
6
8
8
2
6
2
% INTERVIEWED
67
50
67
67
17
50
17
% INTERESTED
75
100
100
25
75
25
v.
z
<
IT
3
1
1
5
3
5
G
CO
-------
Table D-9. Interest in Subcategories Under Control Strategies for
Regional Office Interviewees
SUBCATEGORY
GENERAL INTEREST
STATIONARY BASELINE
EMISSIONS
AIR QUALITY
MODELS USED
COST
MOBILE
CONTROL MEASURES
ASSOCIATED COSTS
INTERVIEWEE
1
2
3
4
5
6
7
8
9
10
11
12
13
14
.
15
16
17
18
19
20
21
TOTAL
7
5
5
5
1
4
0
% INTERVIEWED
33
24
24
24
4
19
0
% INTERESTED
71
71
71
14
57
0
RANK
1
1
1
5
4
G
o
I-"
o
-------
Table D-10. Job Turnaround Requirements, CRT Interest, and Responsibility for
SIP Data Base Update for Durham Interviewees
SUBCATEGORY
TURNAROUND
WITHIN HOURS, OR ASAP
1 DAY
2-3 DAYS
1 WEEK
OVER A WEEK
CRT INTEREST
INTERVIEWEE
1
C
2
C
3
C
4
R
5
R
6
C
7
R
8
9
R
10
R
11
R
12
R
13
C
14
C
15
C
16
C
17
C
18
C
19
<
2
5
7
2
1
1
7
10C
7R
o
»C = CENTRALIZED
R= REGIONAL
-------
Table D-ll. Job Turnaround Requirements, CRT Interest, and Responsibility for
SIP Data Base Update for Washington and Las Vegas NERC Interviewees
O
i
M
to
SUBCATEGORY
TURNAROUND
WITHIN HOURS, ASAP
1 DAY
2-3 DAYS
1 WEEK
OVER A WEEK
CRT INTEREST
SIP DATA BASE UPDATE*
INTERVIEWEE
1
C
2
C
3
C
4
5
.
6
C
7
C
8
C
9
C
10
11
12
C
_i
0
1
3
1
5
0
2
8C
OR
*C = CENTRALIZED
R= REGIONAL
-------
Table D-12. Job Turnaround Requirements, CRT Interest, and Responsibility for
SIP Data Base Update for Regional Office Interviewees
SUBCATEGORY
TURNAROUND
WITHIN HOURS, ASAP
1 DAY
2-3 DAYS
1 WEEK
OVER A WEEK
CRT INTEREST
INTERVIEWEE
1
2
R
3
R
4
5
6
R
7
8
9
R
10
R
11
R
12
13
R
14
R
15
16
R
17
18
19
20
21
_i
<
O
1-
1
5
4
1
0
5
OC
9R
o
I-1
05
*C= CENTRALIZED
R= REGIONAL
-------
Table D-13. Estimated Frequency of Use and Extent of Data for
Durham Interviewees
ITEM
ESTIMATED FREQUENCY OF USE
DAILY
WEEKLY
MONTHLY
SEMIANNUALLY
ANNUALLY
EXTENT OF DATA
EPA REGION
STATE
AO.CR
LOCAL
INTERVIEWEE
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
TOTAL
3
6
5
2
1
3
12
14
2
d
-------
Table D-14. Estimated Frequency of Use and Extent of Data for Washington
and Las Vegas NERC Interviewees
O
h->
01
ITEM
ESTIMATED FREQUENCY OF USE
DAILY OR MORE FREQUENTLY
WEEKLY
MONTHLY
SEMIANNUALLY
ANNUALLY
EXTENT OF DATA
EPA REGION
STATE
AQCR
LOCAL
INTERVIEWEE
1
2
3
4
«
5
*
6
7
8
9
10
11
12
_,
e
3
3
4
0
2
2
6
9
2
-------
Table D-15. Estimated Frequency of Use and Extent of Data for Regional
Office Interviewees
ITEM
ESTIMATED FREQUENCY OF USE
DAILY
WEEKLY
MONTHLY
SEMIANNUALLY
ANNUALLY
EXTENT OF DATA
EPA REGION
STATE
AQCR
LOCAL
INTERVIEWEE
1
2
3
4
5
6
7
8
9
10
*
11
12
13
14
*
15
*
16
17
18
19
20
21
TOTAL
2
6
4
0
0
0
10
10
7
O
h->
05
-------
Table D-16. Frequency of Update of Data Base for Durham Interviewees
AS SOON AS NEW INFORMATION
BECOMES AVAILABLE
UPON PUBLISHING OF A CHANGE
IN THE FEDERAL REGISTER
WHENEVER THE SIP IS REVISED
MONTHLY
QUARTERLY
SEMIANNUALLY
ANNUALLY
INTERVIEWEE
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
A
.B
16
17
18
19
H
K
4
8
1
0
2
0
1
A - REGULATIONS ONLY
B - EVERYTHING OTHER THAN REGULATIONS
-------
Table D-17. Frequency of Update of Data Base for Washington and
Las Vegas NERC Interviewees
O
h-'
00
FREQUENCY OF UPDATE
AS SOON AS NEW INFORMATION
BECOMES AVAILABLE
UPON PUBLISHING OF A CHANGE
IN THE FEDERAL REGISTER
WHENEVER THE SIP IS REVISED
MONTHLY
QUARTERLY
SEMIANNUALLY
ANNUALLY
INTERVIEWEE
1
2
3
.
4
.
5
.
6
.
7
8
g
.
10
11
12
O
1-
4
1
3
1
0
0
1
-------
Table D-18. Frequency of Update of Data Base for Regional Office Interviewees
FREQUENCY OF UPDATE
AS SOON AS NEW INFORMATION
BECOMES AVAILABLE
UPON PUBLISHING OF A CHANGE
IN THE FEDERAL REGISTER
WHENEVER THE SIP IS REVISED
MONTHLY
QUARTERLY
SEMIANNUALLY
ANNUALLY
INTERVIEWEE
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
<
(-
o
H
0
1
0
2
2
4
0
d
l->
to
-------
Table D-19. Use of SAROAD and NEDS
LOCATION
SAROAD
DURHAM
WASHINGTON & LAS VEGAS
REGIONS
NEDS
DURHAM
WASHINGTON & LAS VEGAS
REGIONS
INTERVIEWEE
1
X
2
3
X
X
4
5
X
X
X
X
6
X
X
7
X
X
X
X
8
e
9
X
10
X
X
11
0
X
12
»
13
14
15
16
17
18
X
X
19
20
21
TOTAL USING
13
2
7
10
4
9
% USING
68
17
33
53
33
43
d
to
o
- INDICATES INTERVIEWEE USES THE DATA BASE
X - INDICATES INTERVIEWEE DOES NOT USE THE DATA BASE
BLANK - INDICATES NO RESPONSE, PROBABLE NO USE
-------
Table D-20. Use of Other Data Bases by Durham Interviewees
DATA BASE
BUREAU OF CENSUS
GSA
FPC67
DUN &BRADSTREET
POLK
FFF
BUREAU OF MINES
DEPARTMENT OF THE INTERIOR
NOAA
BUREAU OF ECONOMIC
AFFAIRS
DEPARTMENT OF
AGRICULTURE
INTERVIEWEE
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
TOTAL
10
0
5
1
1
1
0
1
1
1
1
d
to
-------
Table D-21. Use of Other Data Bases by Washington and Las Vegas
NERC Interviewees
G
CO
to
DATA BASE
BUREAU OF CENSUS
GSA
FPC67
DUN & BRADSTREET
POLK
FFF
BUREAU OF MINES
DEPARTMENT OF THE INTERIOR
NOAA
BUREAU OF ECONOMIC
AFFAIRS
DEPARTMENT OF
AGRICULTURE
INTERVIEWEE
1
2
3
«
4
5
6
7
8
9
10
11
12
TOTAL
3
1
6
4
0
0
1
0
0
0
0
-------
Table D-22. Use of Other Data Bases by Regional Office Interviewees
DATA BASE
BUREAU OF CENSUS
GSA
FPC67
DUN & BRADSTREET
POLK
FFF
BUREAU OF MINES
DEPARTMENT OF THE INTERIOR
NOAA
BUREAU OF ECONOMIC
AFFAIRS
DEPARTMENT OF
AGRICULTURE
INTERVIEWEE
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
TOTAL
6
0
2
0
1
0
1
0
0
0
0
CO
CO
-------
APPENDIX E - INFORMATION PROVIDED BY INTERVIEWEES
This appendix contains sample tables pertinent to this study that were provided
by various interviewees. They are presented here not so much for their spe-
cific contents, but rather as examples of ways in which information contained
in various implementation plans are documented.
E. 1 SUMMARY OF NORTH CAROLINA AIR POLLUTION CONTROL REGULA-
TIONS
NOTE: All existing sources of emissions shall comply with applicable regula-
tions and standards at the earliest possible date with all sources being
in compliance within 3 years from the approval of the State Implemen-
tation Plan by the Federal Government. All new sources shall be in
compliance prior to commencing operation.
See Table E-l.
E.I.I Sulfur Compound Emissions
1. Fuel Combustion (effective 7/1/71) (constructed after 7/1/71)
a. New Sources - limited to 1. 6 Ibs SO /mm Btu input
U
b. Existing Sources - limited to 2. 3 Ibs SO /mm Btu input
Lt
By 7/1/80, existing sources shall be limited to 1. 6 Ibs
SO /mm Btu input
2t
2. Sulfuric Acid Plants (effective 7/1/71)
SO limited to 27 Ibs/ton of acid produced
4
Acid mist limited to 0.5 Ibs/ton of acid produced
3. Lightweight Aggregate (effective 7/1/71)
All stacks serving kilns or dryers shall be equipped with control
devices capable of controlling SO emissions to not more than
Li
1. 6 Ibs/mm Btu input.
E-l
-------
Table E-l. Miscellaneous Industrial Processes Allowable Rate of
Emission Based on Actual Process Weight Rate
PROCESS WEIGHT
RATE
LB/HR
100
200
400
600
800
1,000
1,500
2,000
2,500
3,000
3,500
4,000
5,000
6,000
7,000
8,000
9,000
10,000
12,000
TON/HR
0.05
0.10
0.20
0.30
0.40
0.50
0.75
1.00
1.25
1.50
1.75
2.00
2.50
3.00
3.50
4.00
4.50
5.00
6.00
RATE OF
EMISSION
LB/HR
0.551
0.877
1.40
1.83
2.22
2.58
3.38
4.10
4.76
5.38
5.96
6.52
7.58
8.56
9.49
10.4
11.2
12.0
13.6
PROCESS WEIGHT
RATE
LB/HR
16,000
18,000
20,000
30,000
40,000
50,000
60,000
70,000
80,000
90,000
100,000
12JO.OOO
140,000
160,000
200,000
1,000,000
2,000,000
6,000,000
TONS/HR
8
9
10
15
20
25
30
35
40
45
50
60
70
80
100
500
1,000
3,000
RATE OF
EMISSION
LB/HR
16.5
17.5
19.2
25.2
30.5
35.4
40.0
41.3
42.5
43.6
44.6
46.3
47.8
49.0
51.2
69.0
77.6
92.7
INTERPOLATION OF THE DATA IN THIS TABLE FOR PROCESS WEIGHT RATES UP TO 60,000 LB/HR
SHALL BE ACCOMPLISHED BY USE OF THE EQUATION E = 4.10 pO-67 AND INTERPOLATION AND
EXTRAPOLATION OF THE DATA FOR PROCESS WEIGHT RATES IN EXCESS OF 60,000 LB/HR
SHALL BE ACCOMPLISHED BY USE OF THE EQUATION:
E =
(55.0 P°'11)-40
WHERE E = RATE OF EMISSION IN LB/HR AND
P - PROCESS WEIGHT RATE IN TONS/HR.
E-2
-------
E.I.2 Nitrogen Oxide Emissions
1. Fuel Burning Equipment of capacity s 250 mm Btu/hr input are
limited by the following: (effective 7/1/72)
Maximum Allowable NC>2 Emissions
Ibs/mm Btu
Oil or gas-fired boilers 0.6
Coal-fired boilers 1.3
2. Nitric Acid Plants (effective 7/1/72)
NO limited to 5. 8 Ibs/ton of acid produced
£t
3. Sulfuric Acid Plants utilizing the chamber process (effective 7/1/72)
NO limited to 5. 8 Ibs/ton of acid produced
Ll
E.2 SURVEY OF REQUIREMENTS FOR COAL-BURNING EQUIPMENT
Table E-2 is part of a larger table that lists the 1975 SO requirements for
i\
coal-burning equipment for each state. Table E-2 is presented to show the
format and the type of information represented.
E-3
-------
Table E-2. 1975 SOV Eequirements for Coal-Burning Equipment, by AQCR
STATE
*1. ALABAMA
ALASKA
2. ARIZONA
ARKANSAS
3. CALIFORNIA
AQCR
1. ALA. & TOMB R.
2. COLUMBUS, PHOENIX
3. E.ALA.
4. BIRMINGHAM
5. MOBILE, S. MISS. , NWFLA.
6. SE ALA.
7. TENNR.. CUMBER.
8. 6TH INLET
9. NORTHERN
10. S. CENT.
11. SE
12. ARIZ.-N. MEX.
13. CLARK, MOJAVE
"14. 4 CORNERS
15. PHOENIX, TUCSON
16. CENT. ARK.
17. FT. SMITH
18. MEMPHIS
19. MONROE, ELPRODO
20. NE ARK.
21. NWARK.
22. SHREVEPT., TEXOLA
23. GREAT BASIN VALV.
24. LOS ANG. L. BEA.
25. N. CENT. COAST
26. N. COAST
27. NE PLATEAU
28. SACRAM. U.
29. SAN DIEGO
30. SAN FRAN. BAY
31. SAN JOAN U.
32. S. CENT. COAST
33. SE DESERT
OLD
AQCR NO.
182
59
181
29
68
183
72
82
47
89
25
124
64
34
78
125
126
80
145
6
146
147
148
149
150
10
151
152
153
UTILITIES (EXISTING)
1.5 LBS SO2/106 BTU HEAT INPUT
1.2LBSSO2/106BTU HEAT INPUT
1.2 LBS SO2/106 BTU HEAT INPUT
1.2 LBS SO2/106 BTU HEAT INPUT
1.2 LBS SO2/106 BTU HEAT INPUT
1.2 LBS SO2/106 BTU HEAT INPUT
1.2 LBS SO2/106 BTU HEAT INPUT
500 PPM SO2
500 PPM SO2
500 PPM SO2
500 PPM SO2
1.0LBSSO2/106BTU
1.0LBSSO2/106BTU
1.0LBSSO2/106BTU
1.0LBSSO2/106BTU
NO STANDARD FOR EMISSIONS
NO STANDARD FOR EMISSIONS
NO STANDARD FOR EMISSIONS
NO STANDARD FOR EMISSIONS
NO STANDARD FOR EMISSIONS
NO STANDARD FOR EMISSIONS
NO STANDARD FOR EMISSIONS
0.5% S. COAL
0.5% S. COAL
0.5% S. COAL
0.5% S. COAL
0.5% S. COAL
0.5% S. COAL
0.5% S. COAL
0.5% S. COAL
0.5% S. COAL
0.5% S. COAL
0.5% S. COAL
UTILITIES (NEW)
1.2 LBS SO2/106 BTU HEAT INPUT (NSPS)
1.2 LBS SO2/106 BTU HEAT INPUT (NSPS)
1.2 LBS SO2/106 BTU HEAT INPUT (NSPSI
1.2 LBS SO2/106 BTU HEAT INPUT INSPS)
1.2 LBS SO2/106 BTU HEAT INPUT (NSPS)
1.2 LBS S02/106 BTU HEAT INPUT (NSPS)
1.2 LBSSO2/106 BTU HEAT INPUT (NSPS)
500 PPM S02
500 PPM SO2
500 PPM SO2
500 PPM SO2
0.8LBSS02/106BTU
0.8LBSSO2/106BTU
0.8LBSSO2/106BTU
0.8 LBS SO2/106 BTU
1.2 LBS SO2/106 BTU (NSPS)
1.2 LBSS02/106 BTU (NSPS)
1.2 LBS SO2/106 BTU (NSPS)
1.2 LBS S02/106 BTU (NSPSI
1.2 LBSSO2/106BTU (NSPS)
1.2 LBS S02/106 BTU (NSPS)
1.2 LBSSO2/106BTU (NSPS)
0.5% S. COAL2
0.5% S. COAL2
0.5% S. COAL2
0.5% S. COAL2
0.5% S. COAL2
0.5% S. COAL2
0.5% S. COAL2
0.5% S. COAL2
0.5% S. COAL2
0.5% S. COAL2
0.5% S. COAL2
NON -UTILITY
1.5LBS.SO2/106BTU
1.2LBSSO2/106BTU
1.2 LBSSO2/106BTU
1.2 LBSSO2/106BTU
1.2LBSSO2/106BTU
1.2 LBS SOj/I^BTU
1.2LBSSO2/106BTU
500 PPM SO2
500 PPM SO2
500 PPM SO2
500 PPM SO 2
NO EMISSION STANDARD
NO EMISSION STANDARD
NO EMISSION STANDARD
NO EMISSION STANDARD
NO STANDARD FOR EMISSIONS
NO STANDARD FOR EMISSIONS
NO STANDARD FOR EMISSIONS
NO STANDARD FOR EMISSIONS
NO STANDARD FOR EMISSIONS
NO STANDARD FOR EMISSIONS
NO STANDARD FOR EMISSIONS
0.5% S. COAL
0.5% S. COAL
0.5% S. COAL
0.5% S. COAL
0.5% S. COAL
0.5% S. COAL
0.5% S. COAL
0.5% S. COAL
0.5% S. COAL
0.5% S. COAL
0.5% S. COAL
-------
REMARKS
r*
1. ALABAMA; Current 1. 2 Ibs SO /10 Btu applicable only in the following
g ^
counties, with 1.5 Ibs SO /10 Btu standard applicable in other counties:
z
AQCR #2: Autauga, Lee, Montgomery, Pike, Russell Cos.
AQCR#3: Calhoun, Etowah, Talladega Cos.
AQCR #4: Jefferson, St. Clair, Shelby, Tuscalloosa, Walker Cos.
AQCR#5: Mobile County
AQCR #6: Coffee, Convington, Dale, Houston Cos.
AQCR #7: Colbert, Cullman, Jackson, Lauderdale, Madison,
Morgan Cos.
Revisions in current SIP regulations are being made, with the following
regulations expected:
FOR ALL PRIORITY I REGIONS (AQCR'S #5 and #7):
f*
1.6 Ibs SO /10 Btu
A
FOR ALL OTHER REGIONS:
4. 0 Ibs SO./106 Btu
z
2. ARIZONA: In the Four Corners AQCR (No. 14), the following standard
was promulgated for large-sized power plants:
3 S
E = 5.7 x 10
H
where E = allowable SO .emissions
£
S = sulfur content of fuel by weight
H = heat content in Btu's 1 Ib
E-5
-------
f»
In no case shall E exceed . 9 Ibs SO /10 Btu, or if E .16 Ibs SO /
6
10 Ibs the formula shall not apply. Stated standard of 1.0 Ibs SO /
6 '
10 Btu applicable only to steam generating sources of greater than
500,000 Btu's 1 Ib.
3. CALIFORNIA: Regulations are different in each of 57 counties. The
0.5% sulfur coal requirement is typical of most county regulations.
E-6
-------
E03 SIP APC REGULATIONS APPLICABLE TO GIVEN SOURCE COMPLIANCE
SCHEDULE TYPES
Table E-3 lists these SIP APC regulations for several Southern states. It is
another sample of how rules and regulations can be presented in tabular form.
E-7
-------
Table E-3. SIP APC Regulations Appli-
cable to Given Source Com-
pliance Schedule Types
SOURCE TYPE
COMPLIANCE DATES REGU-
LATION APPLICABLE
1. FUEL COMBUSTION
PART
S02
NOX
PART & SO2
PART & NOX
SO2& NOX
ALL
II. INCINERATION
PART
III. PROCESS INDUSTRIES
ALPHALTPART
CONICAL BURNERS PART
COTTON GINS PART
FERTILIZERS PART
FOUNDRIES
PART
CO
PARTS CO
KRAFT PULP PAPER
PART
SOX
PART * SO2
MINERAL PROCESSING
PART
NITRIC ACID
PART
NOX
PART + NOX
NON-FERROUS SMELTERS
PART
S02
PART + SO2
PETROLEUM REFINERIES
CO
S02
HO
CO + S02
CO * HC
SO2 + HC
ALL
PORTLAND CEMENT PART
SULFITE PULP PAPER
PART
S02
PART + SO2
SULFUR RECOVERY
PART
SO2
PART + SO2
CODE NUMBER
99
01
02
03
04
05
06
07
08
09
10
11
12
13
14
15
16
17
18
19'
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
ALABAMA
CH 19.3
CH4.3
CH 5.1
CH3.2
CH 4.4
CH4.4
CH4.6
CH 4.5
CH 7
CH 4.4
CH 4.4
CH 4.4
CH8.2
CH4.4
CH 7
CH 5.1.5
CH6
CH 4.4
CH 4.4
CH 4.4
CH 53
FLORIDA
CH 17-2.03(21
17-2.04(6l(el2
17-2.04161(612
17-2.04(6l(e)2
17-2.04(61(3]
17-2.04(21
17-2.04(21
17-2.04(2)
17-204(2)
17-2.04(2)
17-204(6>(d>
17-2.04(2)
17-2.04121
17-2.04(6llg)
17-2.04(2)
172.04(51
172.04(6X0
17-2.04(2)
17-2.04(2)
17-2.04(6)(h!
GEORGIA
270-5-24-.02(2l(ml
270-5-24-.02(2l(d)
270-5-24-.02(2)(gl
270-5-24-.02(2)(cl
270-5-24-.02(2)(m)
270-5-24-.02(2l(kl
270-5-24-.02(2l(ml
270-5-24-.02I2KI)
270-5-24-.02(2>(m>
270-5-24-.02(2l(q)
270-5-24-. 021211ml
270-5-24-.02(2l(r)
270-5-24-.02(2Ho>
270-5-24- .02(2l(e]
270-5-24-.02(2)(rnl
270-5-24-. 02(21(9)
270-5-24-.02(2)(pl
270-5 24-. 02(2l(e)
270-5-24- 021211m)
270-5-24-02(21(1)
270-5-24-.02(2)lel
270-5-24- .02(2l(m)
270-5-24- .02(2l(gl
270-5-24-.02(2)(9)
270-5-24-.02(2l(ml
270-5-24-.02(2llel
270-5-24-.02(2lle>
270-5-24-.02(2)(ml
270-5-24-.02(2l(9l
270-5-24-.02(2l(el
270-5-24-.02(2l(m)
270-5-24-.02(2)(gl
KENTUCKY
AP1-11
AP3-2
AP4-1
AP7-1
AP3-1
AP3-3I3I
AP3-K2I
AP3-3I3I
AP3-3I3I
AP3-3I3)
AP6-2
AP3-3I3)
AP4-2
AP3-3I3I
AP3 3(31
AP7-2
AP3-3I3)
AP4-3
AP6-2
AP4-3
AP-5
AP3-3I3I
AP3-3I3I
AP4-4
AP3-3I3)
AP43
MISSISSIPPI
APC-S-1 3.4
APC-S-1-4.1
APC-S-1 3.8
APC-S-1 3.6
APC-S-1-36
APC-S-1-3.6
APC-S-1 -3.6
APC-S-1-3.6
APC-S-l-3.6(bl
APC-S-1-4.2
APC-S-1-3.6
APC-S-1-3.6
APC-S-1-3.6
APC-S-1-4.2lel
APC-S-1-4.2
APC-S-1-3.6
APC-S-1-36
APC-S-1-4.2
APC-S-1-3.6
APC-S-l-4.2(d)
N.CAROLINA
11-6.5
IV-1.10
IV-2.40
IV-2.70
IV-2.71
IV-1.30
IV-1.40
IV-2.30
IV-2.30
IV-1.50
IV-2.20
IV-230
IV-1.20
IV-1.00
IV-1.70'
IV-1.80
IV-1.90
IV-2.30
IV-2.72
IV-2.30
IV-2.10
IV-2.30
IV-2.30
S.CAROLINA
R4A
S2A-I
S2A-II
S4A-I
S5A-VI(a)
S5A-VII
S5A-V
S5A-VII
S5A-VII
55A-II
S5A-III
S5A-VII
S5A-VII
S5A-IV
S5A-VII
S5A-VII
TENNESSEE
VI-2A-"
VI 48(1)
V1-2C
VII-2; VII-4
VI-2D
VII-2
VII-4
VII-2
VII-4
Vll-98
VII-2
VII-4
VII-8BI1)
VII-2
VII-4
VII-2
VII-4
VII-90I1I
VII-2
VII-4
VII-8BI1I
VII-8BI1)
VII-2; VII-4
VII-2
VII-4
VII-8BI1)
VII-2
VII-4
VII-80I1I
E-8
-------
TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1. REPORT NO.
EPA-450/3-73-011
2.
3. RECIPIENT'S ACCESSION>NO.
4. TITLE AND SUBTITLE
Survey of EPA User Interest for Proposed State
Implementation Plan Automated Information System
5. REPORT DATE
November 1973
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
Computer Sciences Corporation
System Sciences Division
8728 Colesville Road
Silver Spring, Maryland 20910
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
68-02-1095
12. SPONSORING AGENCY NAME AND ADDRESS
Environmental Protection Agency
Research Triangle Park, North Carolina
13. TYPE OF REPORT AND PERIOD COVERED
Final (8/15-11/30)
14. SPONSORING AGENCY CODE
27711
15. SUPPLEMENTARY NOTES
This Report Will Not Be Duplicated
16. ABSTRACT
This report describes a user survey which was conducted of selected EPA
employees to determine their requirements with respect to state implementation
plans. The results were analyzed and recommendations made as to how to satisfy
these requirements. Where the requirement specified computerization, what to
computerize and how to do it were also addressed. A feasibility study was
performed to determine whether or not to automate any parts of the system.
17.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.lDENTIFIERS/OPEN ENDED TERMS
c. COSATI Field/Group
State Implementation Plans
User Survey
Computers
13. DISTRIBUTION STATEMENT
Release Unlimited
19. SECURITY CLASS (ThisReport)
Unclassified
21. NO. OF PAGES
133
20. SECURITY CLAS* (Thispage)
Unclassified
22. PRICE
EPA Form 2220-1 (9-73)
E-9
------- |