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 ------- \ ? 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 ------- -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. ------- -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 ------- 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). ------- 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: ------- 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. ------- 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 ------- |