EPA-450/3-75-045
APRIL 1975
     IMPLEMENTATION PLAN REVIEW
                  FOR
             CALIFORNIA
              AS REQUIRED
                   BY
          THE ENERGY  SUPPLY
                  AND
   ENVIRONMENTAL COORDINATION ACT
     U. S. ENVIRONMENTAL PROTECTION AGENCY

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  \
   ?      UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                               REGION IX
                          1OO CALIFORNIA STREET
                     SAN FRANCISCO. CALIFORNIA 941 1 1
Honorable Edmond G. Brown, Jr.
Governor of the State of California
Sacramento CA  95814

Dear Governor Brown:

      This letter is a report which the Environmental Protection Agency
has developed for the State under provisions of the Energy Supply and
Environmental Coordination Act (ESECA) of 1974.  As you know, the Clean
Air Act of 1970 required each State to submit to the EPA Administrator a
plan for the implementation, maintenance, and enforcement of the National
Ambient Air Quality Standards (NAAQS) within its boundaries.  You may
also be aware that Section IV of the Energy Supply and Environmental
Coordination  Act requires EPA to review each State Implementation Plan
(SIP)  with respect to its procedures for the control of fuel-burning sta-
tionary sources and to determine if revisions of fuel combustion emission
regulations can be made without interfering with the attainment and main-
tenance of any National Ambient Air Quality Standard.

      The intent of ESECA is that where it can be determined that emissions
from certain fuel burning sources can be increased and still attain and
maintain NAAQS, the State Implementation Plans be revised in the interest
of conserving low sulfur fuels or converting sources which burn oil or
natural gas to coal. Such fuel resource reallocations would be consistent
with both environmental and national energy needs.

      ESECA  provides  that EPA will report to each State as to whether its
plan may be revised.  Though ESECA does not require States to change any
existing plan, the  States may initiate implementation plan  revisions in
accordance with Section 110 of the Clean Air Act of 1970.

      The Implementation Plan Review for California required by ESECA
comes at a time  when the State is undertaking a major revision of its  current
plan.  The State may wish to consider some of the review findings when refor-
mulating the SIP.  A cursory analysis of the State of California's potential for

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                              -2-

revising fuel combustion emission regulations has been accomplished and is
summarized for your convenience in Table 2.  Although the ESECA review
is required to address the attainment and maintenance of all NAAQS, the
California review has focused on total suspended particulate matter (TSP),
nitrogen oxides  (NOX) and sulfur dioxide (862) emissions. This is because
stationary fuel combustion sources generally constitute a major source of
S02 emissions and are often a large source of TSP and NOX emissions.

      The data used in preparing the review are the most current available
to EPA. However, this Agency believes that the State  has more up-to-date
information for revising a plan.  Also, the resources which EPA has had to
prepare this review have not permitted the consideration of growth,  economics
and control strategy tradeoffs.  California is encouraged to verify and expand
the enclosed findings. Should the State wish to revise its plan along  the
lines of Section IV of ESECA, we suggest that control strategies be selected
which place emissions from fuel combustion sources into perspective  with
all sources of emissions. Furthermore,  we suggest that the State consider
the overall impact which the relaxation of overly restrictive emission regula-
tions might have on future control programs.  This may include air quality
maintenance, prevention of significant deterioration, increased TSP,  NOX,
and hydrocarbon emissions which occur in fuel switching, and other
potential air pollution problems such as  sulfates.

      California has avoided two of the most common causes of overly
restrictive emission regulations in the State Implementation Plans throughout
the country. These are:  (1) the use of the example region approach in
developing Statewide air quality control strategies;  and (2) and use of
"hot spots" in part of an Air Quality Control Region (AQCR) as the basis
for controlling the entire region. It is, however, the prerogative of the
State to surpass any NAAQS, 'and California standards are generally more
stringent, as summarized  in Table 1.

      The major findings for California are as follows:

            The review finds there to be little potential for the revision
            of particulate fuel combustion emission regulations in any of
            California's Air Quality Control Regions.  High TSP levels are
            jeopardizing the attainment of NAAQS in seven AQCR's:
            Metropolitan Los Angeles, North Central Coast, Sacramento
            Valley, San Diego, San Francisco Bay Area, San Joaquin
            Valley and the Southeast Desert.  Based on limited 1973 air
            quality data, this review finds no violations of the NAAQS for
            TSP in the following AQCR's:  Great Basin Valley, Northeast
            Plateau, North Coast and South Central Coast.

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                              -3-

            The Metropolitan Los Angeles AQCR and the San Francisco
            Bay Area AQCR show little potential for the revision of S02
            emission regulations since they have been designated as
            proposed Air Quality Maintenance Areas.  AQMA designations
            indicate that these highly urbanized regions have a potential
            for violating the SO2 NAAQS.  The only AQCR in California
            which shows even the slightest potential for the revision of
            S02 fuel combustion emission regulations is San Diego.  It
            must be cautioned, however,  that since the major sources
            of SC>2 fuel combustion emissions in the San Diego AQCR are
            power plants, changes to any current regulation might greatly
            affect the local air quality.  Potential revision should be under-
            taken only after monitoring and/or modeling in the vicinity
            of the plants is completed.  Limited 1973 air quality data shows
            no violations of the NAAQS for SO2 in the remaining AQCR's.

            The Metropolitan Los Angeles AQCR is currently experiencing
            violations of the N02 air quality standard and therefore shows
            little potential for the revision of NOX fuel combustion emission
            regulations. For  the remaining ten AQCR's,  insufficient
            data are available to make a determination of the restrictive-
            ness of regulations with respect to NOX.

      I hope the State will consider these matters in its current SIP revision
effort. If we can be of any assistance to your staff in this regard, we would
be pleased to do so.

                                Sincerely,
                                Paul De Falco, Jr.
                                Regional Administrator

Attachments

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                TABLE 1.   CALIFORNIA AMBIENT AIR QUALITY STANDARDS
                                                  ALL CONCENTRATIONS IN jig/nT


Federal Primary
Secondary
State
TOTAL SUSPENDED PARTICULATES
ANNUAL
75 (G)
60C(G)
60 (G)
24 HOUR
260a
150a
100a
SULFUR OXIDES
ANNUAL
80 (A)
-
-
24 HOUR
365a
-
260b
3 HOUR
-
1300a
-
1 HOUR
—
-
1300
NITROGEN DIOXIDE
ANNUAL
100 (A)
100 (A)
-
(A) = Arithmetic mean

(G) = Geometric mean


aNot to be exceeded more than once per year.
i                                                                       O            C
 In October, 1974, the State revised its 24 hour standard from 105 ^ig/m  to 260 jug/m"
 There will be a hearing in April 1975 to determine whether this revision should be
 modified.
'This is a guideline standard only (as of September 14, 1973).

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TABLE 2.    STATE IMPLEMENTATION PLAN REVIEW   (SUMMARY)


INDICATORS
• Are there any proposed Air Quality
Maintenance Areas?

• Are there indications of a sufficient
number of monitoring sites within
a region?
• Based on reported (1973) Air Quality Data,
does air quality meet NAAQS?

• Are the total emissions from stationary
fuel combustion sources lower than those
of other sources?
t Based on the above indicators, what is
the potential for revising fuel combustion
source emission limiting regulations?

GREAT BASIN
VALLEY AQCR

TSP


NO


NO


NDA

YES

c
E1
z

jU?


NO


NO


NDA

YES

c

z:
METRO
L. A.
AQCR
TSP


YES


YES


NO

YES


O
0
OL.
O0p


YES


YES


YES

YES


O
o
Q.
NORTH
CENTRAL
COAST
AQCR
TSP


NO


YES


NO

YES


0
(X
jUp


NO


NO


NDA

NO

V
c
Ol
10
z:
NORTH
COAST
AQCR
TSP


NO


YES


YES

NO

(Q
C
i_
^
SO.,


NO


NO


NDA

NO

ITJ
C
2"

NORTHEAST
PLATEAU
AQCR
TSP


NO


YES


YES

YES

c
Ol
s:
so?


NO


NO


NDA

NO

c
0)
s:
SACRAMENTO
VALLEY
AQCR
TSP


NO


YES


NO

YES


o
o
Q.
so,


NO


YES


YES

NO

t>
c
21
s:
SAN DIEGO
AQCR
TSP


YES


YES


NO

YES


O
a.
so,


NO


YES


YES

NO

c
C71
£
SAN
FRANCISCO
BAY AREA
AQCR
TSP


YES


YES


NO

YES


O
a.
S0?


YES


YES


YES

YES


o
Q_
SAN
JOAQUIN
VALLEY
AQCR
TSP


NO


YES


NO

YES


O

SO,


NO


YES


YES

YES

C.
i.

Sir
AQCR
TSP


NO


NO


YES

YES

(O
C
en
t-

S00


NO


NO


NDA

YES

(O
c
o>
z:
SOUTHEAST
DESERT
AQCR
TSP


NO


YES


NO

YES


$_
0
a.
so,


NO


NO


YES

YES

JO
C
ET
z:

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                  TABLE 2.    STATE IMPLEMENTATION PLAN REVIEW (CONTINUED)
 Data is from SAROAD data bank in EPA, Research Triangle Park,  North  Carolina.   By
 violations, it is meant the violation of any primary or secondary annual  or 24-hour
 NAAQS.

p
 The ratings in this table were determined by assessing the following criteria:

              Good                            Poor                    "   Marginal

       1) Adequate number of           1) Violation of NAAQS        1) Limited  air quality
          air quality monitoring                                       data
          sites
       2) No NAAQS violations          2) Proposed AQMA             2) Inconsistent "indicators"

       3) No proposed AQMA's

 For an AQCR to be rated as a good candidate, all  the criteria  listed under "Good" would
 have to be satisfied.  The overriding factor in rating an AQCR as a noor candidate is a
 violation of either the primary or secondary National Ambient  Air Quality Standards dur-
 ing 1973.  However, if the other consideration listed under "Poor" exists, the AQCR
 would still receive that rating.  The predominant reason for a marginal  rating is a
 lack of sufficient air quality data.


NDA = No Data Available

Note : This table summarizes only TSP and S02 status.

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                              TECHNICAL REPORT DATA
                       (Please read Instructions on the reverse before completing)
H-Ko/3-75-045
                         2.
                                                      3. RECIPIENT'S ACCESSION-NO.
CEMENTATION PLAN  REVIEW FOR CALIFORNIA AS
EQUIRED BY THE ENERGY  SUPPLY AND ENVIRONMENTAL
OORDINATION ACT
                                                      5. REPORT DATE
6. PERFORMING ORGANIZATION CODE
 HOR(S)
                                                      8. PERFORMING ORGANIZATION REPORT NO.
 ORMING ORGANIZATION NAME AND ADDRESS
  S. Environmental  Protection Agency, Office  of  Air
 uality Planning  and Standards, Research Triangle
 ark, N. C.,  Regional Office IX, San Francisco, Ca.,
 nd TRW, Inc.,  Redondo Beach, Ca.
                                                      10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
 NSORING AGENCY NAME AND ADDRESS
  S. Environmental  Protection Agency
 rfice  of  Air and Waste Management
 ffice  of  Air Quality Planning and Standards
 esearch Triangle Park, North Carolina   27711
13. TYPE OF REPORT AND PERIOD COVERED
14. SPONSORING AGENCY CODE
 PLEMENTARY NOTES
 TRACT
     Section IV of the Energy Supply  and Environmental Coordination Act  of  1974,
 ESECA)  requires EPA to review each State Implementation Plan (SIP) to determine
 f  revisions can be made to control regulations for stationary fuel combustion
 ources  without interfering with  the  attainment and maintenance of the national
ambient  air quality standards.  This  document, which is also required by Section
of  ESECA, is EPA's report to the  State indicating where regulations might be
revised.
                             IV
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
Air Pollution
State Implementation Plans
ISTHIBUTION STATUMENT
Release unlimited
I
b.lDENTIFIERS/OPEN ENDED TERMS

19. SECURITY CLASS i This Report)
Unclassified
20. SfcCUHl TY CLASS (i'liispagc)
Unclassified
c. COS AT I Held/Group

21. NO. Oh PAGtS
6
22. PRICE


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