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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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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