Air Program Strategy for Attainment
 and Maintenance of Ambient Air Quality
Standards and Control  of Other Pollutants
  U. S. Environmental Protection Agency
        Washington, D. C.  20460

                  1977

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                           TABLE OF CONTENTS



 Preface  	   i

 I.   Introduction	1

     A.   Overview	1

     B.   Legislative  Philosophy  and Objectives  	  10
         1.   Overview of Legislative Authorities  	  10
         2.   Legislative Objectives	11
         3.   State  Implementation Plans	13

     C.   Overview of  Status of Implementation of  the  Act's
           Requirements  and Future Actions  	  15

     D.   Issues  Related  to  the National  Ambient Air
           Quality  Standards  	  18
         1.   Overview	18
         2.   Total  Suspended  Particulates	22
         3.   Sulfur Dioxide and  Sulfates 	  26
         4.   Photochemical  Oxidants	27
         5.   Nitrogen Dioxide	33

     E.   Monitoring Air  Pollution.  .  .-	33

II.   Status of Air  Pollution  Control and Future Actions	37

     A.   Overview of  Progress to Date	37

     B.   SIP Revisions	40

     C.   Emission Reductions  from Sources—Issues and Policy ...  42
         1.   Introduction	42
         2.   Total  Suspended  Particulates  and  Sulfur Dioxide ...  43
             a.   Primary Non-Ferrous Metals Smelters 	  45
             b.   Iron and Steel  Mills/Coke Plants	47
             c.   Coal-Fired Power Plants 	  48
             d.   Tall Stacks  and Supplemental  Control Systems.  .  .  49
             e.   EPA's Policy on SIP  Revisions  Aimed at
                   Permitting Use of  Higher Sulfur Fuels 	  51
         3.   Photochemical  Oxidants,  Carbon Monoxide, and
               Nitrogen  Dioxide	54
             a.   Introduction	54
             b.   Motor Vehicle Emissions Control  	  56
             c.   Motor Vehicle Emissions Inspection
                   and Maintenance	62
             d.   Control of Stationary Sources  	  64

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                      TABLE OF CONTENTS  -  (CONT'D)
      D.   Attainment/Maintenance  of  Standards  in  Problem
            Areas  and  New  Sources Control	67
          1.   Introduction	67
          2.   Development  of a  Comprehensive  Planning
                and  Decision-Making  Process  	  69
          3.   EPA's  Formal Planning  Requirements	73
          4.   New  Stationary Sources Review and  Control  	  75
              a.   Introduction	75
              b.   New  Sources in  Nonattainment Areas--
                    "Emissions  Offset"  Policy  	  77
              c.   Prevention of Significant Deterioration
                    of Air Quality	78
              d.   Federal  New Source Performance Standards
                    (NSPS) for  Criteria Pollutants	32

III.   The Control  of Other Than Criteria Pollutants 	  85

      A.   Introduction	85
      B.   National Emission Standards for Hazardous
            Air Pollutants	87
      C.   Control  of Selected Pollutants	90
      D.   Lead	90
      E.   Arsenic	91
      F.   High Volume  Industrial  Organic Chemicals (HVIOC)	  92
      R.   Polycyclic Organic Matter	  95
      H.   Polychlorinated  Biphenyls  (PCBs)	96
      I.   Cadmium	97
      J.   Manganese	97
      K.   Other Trace  Metals	97
      L.   Odors	98
      Table I
          Summary of NESHAP	89

      Table II
          High Volume Industrial Organic Chemicals Being
            Assessed for Air Pollution Potential	94

      Appendix A
          1.  National Ambient Air Quality Standards	A-l
          2.  Sources of Information on Health Effects
                of Air Pollutants	A-2

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                 TABLE OF CONTENTS - (CONT'D)
Appendix B
    Summary of New Source Performance Standards 	 B-l

Appendix C
    Determination of Best Available Control Technology
      and Reasonably Available Control Technology 	 C-l

      A.  Best Available Control  Technology 	 C-l

      B.  Reasonably Available Control Technology 	 C-2
          1.  General	C-2
          2.  Specific Application of the RACT Concept. . .  . C-4
              a.  As an Aid in Defining BACT	C-4
              b.  RACT coupled with Tall Stacks and/or SCS.  . C-5

      C.  Reasonably Available Control Measures for
    '        CO and Ox	C-8

Appendix D
    Summary of States Issued Calls for SIP Revisions
      July 1, 1976, and Pollutants for Which Plan
      Revisions Are Required	D-l

Aopendix E
    List of Abbreviations, Symbols, and Acronymns 	 E-l

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                                Preface

This Air Program Strategy for Attainment  and  Maintenance  of  Ambient
Air Quality Standards states EPA's  strategy for implementation  of the
Clean Air Act's requirements for compliance with ambient  air quality
standards, to be achieved principally through adherence  to  air  quality-
based emission limitations.   This strategy also applies  to  the  control
of pollutants less pervasive than those  covered by air quality  standards.
These less pervasive pollutants are generally subject to  direct emission-
oriented controls.

     The discussion which follows is a statement of the  Agency's objectives
and plans for future air pollution  control efforts, based on the require-
ments and philosophy of the Clean Air Act and on the national  status of
air pollution control.  This document should be considered  both as a
status report and as an outline of  directions for the future.

     The discussion is not intended as a complete statement of the
Environmental Protection Agency's air pollution control  program; it is
related primarily to the operational objectives and programs of the
Agency and the requisite companion  programs of the States in achieving
the Clean Air Act's goals.  Thus, the discussion does not cover the
Agency's substantial effort to define health effects, welfare effects,
control technology for mobile and stationary sources, or the definition
of mechanisms for atmospheric transportation of pollutants, nor is it
an exhaustive compendium of all matters  related to air pollution control.

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              AIR PROGRAM STRATEGY  FOR  THE  ATTAINMENT  AND



             MAINTENANCE OF  AMBIENT AIR QUALITY  STANDARDS



                    AND CONTROL  OF  OTHER POLLUTANTS







I.   Introduction



     A.   Overview





     The 1970 Amendments to  the  Clean Air Act have been  considered a



landmark in the nation's efforts to control  air  pollution  both in terms



of their comprehensiveness and in terms of their setting forth the



institutional framework for  State and Federal action.   Pursuant to that



Act, National Ambient Air Quality Standards were established for six



significant and widespread air pollutants,  implementation  plans for the



attainment and maintenance of these standards were developed by the



States, a program for the establishment of Federal emission standards



for significant new air pollution sources and for hazardous air pollu-



tants was initiated, and statutorily specified limitations on emissions



from light duty motor vehicles were imposed.





     The Clean Air Act's fundamental goal is the protection of public



health and welfare from the effects of  air pollution.   This goal is to be



attained through:  the restoration of unhealthy air (and its preservation,



once restored) to at least acceptable status through State controls on



stationary sources and transportation systems and Federal  controls on



new motor vehicles; clean air is to be  preserved from unnecessary and

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significant degradation;  future increases  in  emissions  are  to  be
minimized in an equitable manner (that does  not put  particular regions
of the country at a competitive disadvantage  or advantage)  through
Federal new source emissions limits based  on  best technology (considering
cost); and national emission limits are to be set for the strict  control
of hazardous localized pollution problems.  In achieving these goals,
the Act recognizes the high priority need  for State  control actions.

     The Act, in general, envisions the development  and implementation
of air pollution controls as a State responsibility, with the Federal
government setting minimally acceptable criteria for assuring that
public health and welfare are adequately protected.   For all cases in
which the Federal government has not set standards,  the States are free
to impose whatever controls they see fit.   For cases in which the
Federal government has set controls, the States may  establish a more
stringent requirement but may not set a more lenient requirement.  The
Act largely  reserves to  the Federal government the control of new motor
vehicles, and also places on it primary responsibility for the control
of hazardous pollutants  and the setting of emissions standards for new
significant  stationary sources.  In the case of both hazardous emissions
standards and new stationary sources controls  the States may  request the
delegation of enforcement responsibilities.  Given  the policy of State
primacy  in the Act,  it has been EPA policy to  defer  to the  States and to
take  action  (generally after extensive consultation with States) only in
cases of State failure to act or in cases where Federal action is
directly indicated.
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     The past six years  have  served as a major  testing ground for both
the fundamental  goals  of the  Act  and  the institutional arrangements
contemplated for their achievement.

     Six years after the passage  of the Act,  violations of  the  National
Ambient Air Quality Standards for one or more pollutants  still  exist  in
at least 160 of the 247 air quality control  regions.   These standards
were to have been attained in the 1973-1975  time  frame.   Yet substantial
progress has been made:

     .   The estimated  number  of people exposed to total  suspended
        particulates in excess of the annual  primary  standard decreased
        from 73 million in 1970 to less  than 50 million  in  1975,  i.e.,
        the exposed population has been  reduced by more  than one-third
        since the passage of  the  Clean Air Act.
     .  The concentrations of sulfur  dioxide in urban areas have
        decreased by an average of 30 percent since 1970.  Only a  few
        monitors in a small number of urban areas report violations of
        standards.

     .  At monitoring sites where data exist  covering three or more
        years, some 80 percent show improvement in measured levels of
        carbon monoxide.

     Outside of  California, monitoring data for oxidants and nitrogen
dioxide are inadequate to characterize trends since the passage of the
                                - 3 -

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Clean Air Act.   With more stringent  automobile  standards, some  improvement
in oxidant levels would be expected.   However,  widespread violations of
one-hour ambient air quality standards are  reported  and  the  problem of
hydrocarbon emission remains as one  of the  more pressing priorities in
air pollution control.   With respect to nitrogen dioxide, the  reverse is
true.  Only limited controls over stationary source  emissions  have been
imposed and no Federal  limits for emissions from new motor  vehicles
existed prior to the 1973 model year.   With increased energy consumption,
the trends in ambient levels of nitrogen dioxide would be expected to be
up.  However, in contrast to oxidants, very few areas have  violations of
the ambient air quality standards.  Control considerations  with respect
to nitrogen dioxide are, in general, ones more  of prevention of future
pollution problems than of remedial  action directed  at current levels.

     Other air pollutants that have been of traditional  concern, such as
polycyclic organic matter (POM), show decreasing trends  in  ambient air
concentrations.  These trends are generally due to the imposition of
controls under the State Implementation Plans for other pollutants
(e.g., general particulate control leads to reductions in  the emissions
of many of the specific substances that may be of concern), to the  shift
in the use of certain fuels  (e.g., the reduction in POM is  due to the
decreasing use of coal as a  fuel for home and commercial heating),  or to
the imposition of specific controls for the pollutants in  question
(e.g., control of the lead content of gasoline).  Additional, newer
evidence indicates that certain substances not heretofore considered
                                - 4 -

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significant air pollutants  may  represent  an  increasing threat to public
health.   An example of these  substances is sulfates  (which may account
for, at least partially,  the  health  effects  associated with sulfur
dioxide and/or particulates), whose  concentrations have not been reduced
in keeping with the reductions  achieved for  sulfur dioxide.  Other  such
substances are the organic  chemicals emitted by  the  chemical industry;
these substances are increasingly suspected  of being toxic and/or
carcinogenic, yet emissions are increasing and the ambient concentrations
(as well as the effects)  are  not known.   Other substances have  only
recently been found to be of great concern in terms  of  environmental
impacts through the air.   An  example of  these is polychlorinated  biphenyls
(PCB), which may have to be controlled as an air pollutant due  to  the
contribution of air emissions to water pollution problems.

     Air pollution control  is predicated  upon the development  of  regulations
covering emitting sources and the compliance with regulations  by  the
affected sources.  More than 200,000 sources are subject to  the limitations
prescribed in State Implementation Plans.  Of these  sources,  some 22,000
are defined as major, i.e., capable of emitting  more than 100  tons of
pollutants a year.  As a class, these major  sources  produce  about 85
percent of all air pollution from stationary sources.  Consequently,
enforcement efforts (both State/local and Federal) have concentrated on
bringing these emitters into compliance with applicable regulations.  As
a result, some 90 percent of these sources are either now in compliance
or on firm schedules leading to compliance.
                                   - 5 -

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     Although the Clean Air Act clearly  sets  forth  the concept of
State primacy in enforcing State Implementation  Plan-based air pollution
regulations, a major Federal  effort has  been  required.   Since 1972,  the
Federal  enforcement staff has increased  by  640 percent.   Over 10,000
investigations a year are being conducted by  Federal  enforcement  personnel.
This situation has resulted from both  the insufficiency  of State/local
resources for enforcement related work (it  is estimated  that on a
nationwide basis State/local  air pollution  control  agency staffing  is
only about 70 percent of what is required to  implement Clean Air  Act
requirements) and the extremely difficult task of imposing control
requirements on certain inherently dirty industries (i.e., steel,  primary
smelters, coal fired electric power generation)  that are national  in
scope.  Also, the responsibility for enforcing  Federal New Source
Performance and Hazardous Air Pollutant  regulations continues  to  be with
the Federal government.  Less than 15 States  have been delegated  responsi-
bility to carry out these provisions of  the Clean Air Act.
     Failure to achieve air quality standards in many areas  despite
substantial reductions in emissions due  to  a  major Federal  program to
both promulgate and enforce air pollution regulations under  State
Implementation Plans represents the six-year reality of  the  implementation of
the Clean Air Act.  What happens next and what are the  priorities of
EPA are the questions addressed and put into perspective in  the strategy
document discussion.  Essentially the strategy projects  a continuation
into the future of the basic programs which have served  to define the
                              - 6 -

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implementation of the Clean Air Act over  the  past  six years, modified
where appropriate on the basis  of the  experience gained  and new  infor-
mation obtained during that time:

     1.   The primary objective is the attainment  of ambient air quality
          standards.  On July 1, 1976  the Governors of 45  States were
          notified that their implementation  plans were  inadequate  to
          attain standards and  were requested to develop appropriate
          revisions.  These revisions  are expected to  involve  the appli-
          cation of reasonably  available  controls  to all sources as
          required to attain and maintain standards.   Additionally, to
          the extent that (even after the application  of these restrictions)
          an area still does not meet, or will not maintain,  the air
          quality standards, more long-range  actions are required,
          dealing with growth,  polluting  facility  siting,  and  institutional
          changes.  Pollution emitting facilities  are  expected to come
          into compliance with  new regulations as  soon as  practicable,
          but not more than three years after the  effective date of the
          regulation except in  exceptional circumstances.

     2.   A major Federal role  in meeting ambient  air  quality standards
          will continue.  Failures by the States in  some cases  to develop
          the requisite regulatory framework for air pollution control
          will continue to necessitate Federal action  to fill  the gaps
          in otherwise adequate State control programs.   Likewise, the
                                - 7 -

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     extension  of air  pollution  control  to  a  large  number of
     sources  not presently  covered,  or  covered  inadequately, will
     intensify  the need  for enforcement action.   EPA will seek  to
     supplement State/local resources to facilitate State assump-
     tion of  enforcement responsibilities,but,  as necessary,  it
     will continue to  undertake  Federal  enforcement action  under
     State implementation plan regulations.

3.    EPA activities to identify  and  control  pollutants  other  than
     those covered by  National Ambient  Air Quality  Standards  are
     likely to  expand.  The definition  of the substances  emitted
     by the chemicals  manufacturing  industry in terms  of  the  sources,
     amounts, and potential health effects of the substances  is
     underway.   It is  expected that  a  number of these  substances will
     turn out to be of a toxic and/or  carcinogenic  nature,  requiring
     control  as hazardous air pollutants.  As a precautionary measure,
     the setting of new source performance standards  will  be aimed
     at minimizing increases in the  emissions of these substances.

     Additional studies of the emissions of various substances
     (e.g., metals and other chemicals) from various  sources are
     likely to result in the identification of the  need for the
     development of control requirements, such as the control of
     PCB's from incinerators  and the control of arsenic from
     smelters.   Other work in the occupational health and
                            - 8 -

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          environmental  health  fields  can  be  expected  to  reveal  the need
          for protection of the public health from  the effects of many
          substances  not heretofore  identified as air  pollutants.

     To a large extent the  hardest phase of  the efforts to  meet  ambient
air quality standards is yet to come.   The previously  mentioned  progress
has been achieved through the application  of controls  to  sources generally
amenable to control  requirements.  The problems of  the future may be  of
such a magnitude and of such inherent  difficulty that  ambient air quality
standards may not be achieveable in  some areas for  many years or even
decades.  However, new regulatory  requirements, new approaches to
difficult problems,  and continued  attention  to problems of  sources
compliance (including the continuing compliance of  mobile sources with
Federal new car emission standards)  are all  needed  before it can be
concluded that all possible efforts  have been made  to  meet  the goals  of
the Clean Air Act.
                                 - 9 -

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     B.    Legislative  Philosophy and Objectives
          1.    Overview of  Legislative Authorities

     In  order to protect health and welfare,  the Clean Air Act* establishes
several  mechanisms to  reduce and prevent  air  pollution while minimizing air
pollution control  as either an  impediment to  interstate  commerce or  a
factor in interstate competition for new  polluting  facilities.  As the
basic objectives to be achieved  in the abatement of existing pollution,
the Clean Air Act calls for National Ambient  Air Quality Standards (NAAQS).
The NAAQS set forth the allowable concentrations in  ambient air  for a set
of pollutants associated with diverse  sources widely distributed throughout
the nation.**  To attain and maintain  the NAAQS, States  (or EPA, if
necessary) must establish appropriate  emission limits and other necessary
measures for specific  facilities or  activities.  These emission limits
are set forth in a State Implementation  Plan  (SIP).

     To prevent pollutant buildups  (and  to aid in  maintaining  as well  as
attaining the NAAQS),  the Clean Air  Act  provides  several mechanisms
aimed particularly at  new sources:   New  Source Performance  Standards
(NSPS), emission standards for new vehicles,  and  prevention of significant
*  References to the Clean Air Act (or simply the "Act") in this document
   imply reference to all its amendments, notable among them being the
   Energy Supply and Environmental Coordination Act (ESECA) of 1974
   (PL 93-319), Clean Air Amendments of 1970 (PL 91-604), and the Air
   Quality Act of 1967 (PL 90-148).  The 1970 amendments specified the
   mandatory time frames for attainment and maintenance of standards.
** Appendix A summarizes these standards.

                                - 10 -

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deterioration.   Of course,  the NAAQS-based  and  derived  emission  restrictions
(i.e., those set under SIPs)  apply to new sources  as  well.

     For the control of pollutants other than those for which  NAAQS  are
set, the Clean Air Act provides two basic alternatives.  First,  National
Emission Standards for Hazardous Air Pollutants (NESHAP) can be  set  to
abate less widespread new and existing sources  of pollutants that are
very harmful even in limited, localized concentrations.  Second, New
Source Performance Standards provisions of the Act also provide  authority
for the control of new or modified sources of localized pollutants.
Except where NSPS relate to pollutants controlled by NAAQS or NESHAP,
establishment of NSPS trigger requirements for States to control
existing sources of specified pollutants pursuant to Federal guidelines.
In addition, authorities are available for the control  of fuel additives
and aircraft emissions.

          2.   Legislative Objectives
     The Act gives  first priority to the protection of  health, establishing
mandatory times for the attainment of standards protective  of health.
For standards protective of welfare, the Act provides  for limited administrative
discretion  as to  the time of attainment.*  The setting  of environmental
standards that are  to be met nationally  reflects  the Congressional
decision to provide   for an adequate level  of health  and welfare protection
 *   NAAQS  set  for  the  protection of public health are called primary
    standards;  those set  for  protecting welfare are called secondary
    standards.
                                  -  11  -

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(through Federal  standards)  while  preserving  State*  prerogatives  in
making specific control  decisions  (through the development  and  imple-
mentation of State air pollution control  plans).

     Several interrelated types of action make up the process  by  which
environmental standards are to be attained.   The  Act mandates  the adoption
of legally enforceable emission reduction plans.   It also provides for
emission limitations to be achieved on a  nationwide basis.  For example,
emission limits achievable by best adequately demonstrated  technology
(considering cost) are to be set for new  or modified stationary air
pollution sources and mandated emission reductions are set for new light
duty motor vehicles.  The Act further requires the use of certain
controls not traditionally applied  to air pollution control,  such as
the control of land use and transportation when conventional emission
limits are inadequate to meet the environmental goals within the mandatory
time schedules set forth in the Act, or when States choose to use such
controls in lieu of more traditional control measures.
     The philosophy circumscribing the State  Implementation Plan process
is as follows:
      .  The Federal Government  is to set environmental standards.
      .  The States are required to design and  implement  the plan for
        achieving the environmental standards.
*  The Act defines as States the 50 states, the District of Columbia,
   Puerto Rico, Guam, American Samoa, and the Virgin  Islands.
                                - 12 -

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      .  Opportunity must be provided for public participation in the

        development of Federal standards, State plans, and subsequent

        changes  in such standards or plans.  Furthermore, information

        must  be  made available to the public on State progress in

        carrying out the plan.

      .  The Federal Government is to take action when States do not

        adopt or carry out an adequate plan for achieving .the standards.


           3.   State Implementation Plans


      The  setting of National Ambient Air Quality Standards triggers  the

 planning  and  control program development and implementation  requirements

 of Section 110 of  the Act.  The  promulgation of National Ambient Air

 Quality Standards  on April 30, 1971, for six pollutants* set in motion

 the Act's planning and plan execution, process  for achieving  those

 primary NAAQS by the mandatory 1975 to  1977 period.**
 *  Although NAAQS have been  set for  six  pollutants,  the  standard  for
    hydrocarbons is to be used as a guide in  devising implementation
    plans to achieve the oxidants standard.   The  control  of  hydrocarbons
    is treated in this document as a  part of  the  oxidants control  program.

**  Since 1970, court decisions have  helped define  certain parts of
    of the Act as follows:   transportation and  land  use  controls  must
    be included in SIPs where necessary to attain or  maintain  the
    ambient standards; the control of indirect sources of air  pollution
    (such as shopping centers and highways) is an appropriate  method of
    reducing the direct pollution from the automobiles which they  attract;
    SIPs must prevent significant deterioration  of  air quality where the
    air is now cleaner than the ambient standards;  and constant emission
    controls must be used to the maximum extent  achievable in  preference
    to pollutant dispersion techniques.
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     The Act places  primary  responsibilities  for  air  pollution control
on the States.   The  development of control  strategies  by  the States for
the achievement of NAAQS  constitutes  the  essence  of the planning process.
 The State Implementation Plans (SIPs)  set  forth  the  control strategies
that will be followed and enforced by a State (within  given time frames),
for achievement of NAAQS  within specified geographic  areas, i.e.,  Air
Quality Control Regions (AQCR).  The  SIPs are to  specify  the plan  of
action for achieving the  Act's objectives,  i.e.,  reduction  in  emissions
levels requisite for meeting NAAQS and the  prevention of  excessive
increases in emissions in the future  in order that NAAQS  be maintained
and that significant deterioration of air quality be  prevented.*

     As a planning process,  the SIPs  are  dynamic.  Constant review and
necessary improvements of the plans are a part of this process.  The  Act
as well as EPA's implementing regulations include important features  for
reviewing, updating, and  changing plans for the purpose of  accommodating
changing requirements (be they social or  economic conditions,  growth
patterns, or the changing status of technology),  provided  these  are
consistent with the Act's essential requirements, i.e., the achievement
of air quality levels consistent with protection of public  health  and
welfare within specified  time frames  and  the preservation of  the  nation's
air resources.
*  The semi-annual reports on State progress provide summaries of the
   status of each State plan.  The report State Air Pollution Implementation
   Plan Progress Report, January 1 to June 30, 1975, U.S.E.P.A. Office
   of   Air and Waste Management, Office of Air Quality Planning and
   Standards,   Research Triangle Park, N.C.  27711; September 1975 (EPA
   450/2-75-008)    contains detailed information on the status of each
   SIP.  Subsequent  reports provide additional information.
                               -  14  -

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     C.    Overview of Status  of  Implementation of  the Act's
          Requirements and  Future  Actions

     The highest priority Federal  and  State  action has  generally  been
directed towards those Air  Quality Control Regions where  pollutant
concentrations exceed national  standards which are protective  of  health.
The Agency has had the most success in carrying  out those parts of  the
law that involve the control  of specific sources of emissions  by  the
application of a specific emission limitation.   It has  had less success
in trying to implement pollution control measures  that  involve very real
changes  in lifestyles and land  use patterns.  These are changes  that can
take place only over periods of time;  they entail  very  basic social,
economic and environmental  choices and tradeoffs which  can best  be  made
by the people involved, i.e., through  the  political process at the
State, local and regional levels.

     In some areas, the standards cannot  be  attained in the mandatory
time period with all achievable control measures.   In some Air Quality
Control  Regions, the level  of social and  economic change which may  be
required to meet ambient standards on  time is unacceptable  in the  near
future, in terms of economic and social impact.    In other areas,  there
are problems associated with deficiencies  in the SIPs1  provisions for
attainment and/or maintenance of the standards,  or with the degree of
source compliance with requisite emission limitations.   The net effect
has been that many areas have not attained the standards by the statutory
deadlines.
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    In areas affected by  control  requirements having a severe economic
and social  impact,  the Act provided  only  limited  flexibility:  Two-year
extensions  of time  for a  given Air Quality  Control  Region  and an additional
one-year extension  for compliance of specific sources  (or  classes of
sources) with plan  requirements.   The strict time-tables imposed by the
Act and the limited discretion provided were the  result of Congressional
decisions that progress in controlling air  pollution would only be made
if stringent criteria for performance were  imposed.

     In areas that  are not attaining standards  due  to  SIP  or SIP imple-
mentation deficiencies, actions for  the near future have to concentrate
           3
on defining and implementing requisite solutions  (i.e., additional
enforcement activity and derivation  and implementation of  better control
plans).  Control actions aimed at the prevention  of future problems
(e.g., new source controls) and aimed at  the development of control
measures (or other solutions) for problems  which  have  been recently
documented (e.g.,  long-range transport of  air  pollutants), should  also
be implemented expeditiously.

     One major future challenge in air pollution  control  is to deal
effectively with the issues of growth—the  issues involved in trying  to
preserve and maintain air quality—and to relate  and  reconcile different
environmental concerns such as clean air with social  and  economic
concerns such as housing, jobs, and energy.  This issue involves
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an increasing shift in emphasis  from the abatement to the prevention  of
pollution, including an increased emphasis  on the control  of those
pollutants likely to lead to future air pollution problems.   The air
pollution issues associated with growth will  require the development
of planning and control processes which recognize and accommodate  the
extraordinary diversity of needs, conditions, and aspirations which make
up this country.
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     D.    Issues Related to the  National Ambient Air Quality Standards
          1.    Overview

     The key element in the control  of air  pollution under  the air
quality management concept embodied  in the  Clean Air Act  is the setting
of ambient air quality standards,  since control requirements are  derived
on the basis of calculations as  to the emissions reductions necessary  to
attain and maintain the ambient  standards.   Other  systems for developing
control plans exist and are in use in other countries.   In  developing
the Clean Air Act, the Congress  adopted this system as  the  one  most
desirable for air pollution control  in this country.  This  basic  policy
decision of the Congress is not  reassessed  in this document.  The Agency
does not believe that there is reason for a change in  this  basic  policy.

     Any consideration of NAAQS  must-take into account  the statutory
basis and the policy decisions made to develop the legislative  mandates.
The Congress provided that public health protection should be of the
highest priority and that no other considerations  enter into  the setting
of the standards.  The statute reflects this policy.*  The Clean Air
Act, in Section 109, states that:
     "National primary ambient air quality standards...shall be ambient
     air quality standards the attainment and maintenance of which in
     the judgement of the Administrator...allowing an adequate margin of
     safety, are requisite to protect the public health...
 *   It  should be noted that the consideration of other factors related
    to  the control of air pollution under the NAAQS, such as costs and
    feasibility of control, may be taken into account as part of the
    state control plan development process provided that the plan is
    sufficient to attain and maintain the ambient standards;  for this
    purpose, the Act specifies that the Administrator is to provide
    information to the States on control techniques.
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     "Any national  secondary  ambient air quality standard...shall
     specify a level  of air quality the attainment and maintenance of
     which in the judgement of  the Administrator...is requisite to
     protect the public welfare from any known or anticipated adverse
     effects associated with  the presence of  such air pollutant in the
     ambient air..."*
     The Act specifies  that the  basis  for  setting  the NAAQS be documented

in criteria documents.   The issuance of a  criteria document is to be

accompanied by proposed NAAQS, which are to  be  finalized within 90 days

of proposal.  In the words  of Section  108, the  criteria are to:


     "...Accurately reflect the  latest scientific  knowledge useful in
     indicating the kind and extent of all identifiable effects on
     public health or welfare which may be expected  from  the  presence  of
     such pollutant in the  ambient air, in varying quantities.  The
     criteria for an air pollutant, to the extent  practicable, shall
     include information on -

          "(A) those variable factors  (including atmospheric  conditions)
          which of themselves or in combination with other factors may
          alter the effects on public health or welfare of such air
          pollutant;

          "(B) the types of air  pollutants which,  when  present in  the
          atmosphere, may interact with such pollutant  to produce  an
          adverse effect on public health  or welfare; and

          "(C) any known or anticipated adverse effects on welfare..."


     On April 30, 1971, NAAQS were set for total  suspended particulates

(TSP), sulfur dioxide ($02), carbon monoxide (CO), photochemical  oxidants

hydrocarbons (HC) and nitrogen dioxide (N02).  With  the
   Welfare effects are defined by Section 302 of the Act as including
   but not limited to, "effects on soils, water, crops, vegetation,
   manmade materials, animals, wildlife, weather, visibility, and
   climate, damage to and deterioration of property, and hazards to
   transportation, as well as effects on economic values and on
   personal comfort and well being."
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exception of the criteria for nitrogen oxides,  all  other criteria

documents had been published prior to 1971.*


     The basis for the NAAQS and the costs of attaining them have been

thoroughly assessed by various review groups.  In general, these groups

have concluded that there is no basis for changing the NAAQS.  The most

extensive recent reassessment was carried out by the National Academy

of Sciences  (NAS) under contract with the U. S. Senate.  The NAS,

although dissatisfied with the available data bases for setting standards,

concluded that:
     "In general the evidence that has accumulated since the
     promulgation of the Federal ambient air quality standards
     by the E.P.A. Administrator on April 30, 1971, supports
     those standards.  Hence, on balance, the panels found no
     substantial basis for changing the standards."
In relation to the implementing controls on motor vehicles, the NAS

stated that:
      "Weighing all of these estimates, and their uncertainties,
      we conclude that the benefits in monetary terms that could
      reasonably be expected to accrue from implementing the
      Federal statutory emission control standards for automobiles
      are commensurate with the expected cost."**


*A  portion of the criteria on S02  (effects on vegetation) was
   revised  in 1973, resulting in a change in the secondary NAAQS
   for this pollutant.

** Air Qua1ity and Automobile Emission Control, A Report by the
   Coordinating Committee on Air Quality Studies, National Academy
   of Sciences-National Academy of Engineering, prepared for  the
   Committee on Public Works United  States Senate,  pursuant to
   S. Res.  135 approved August 2, 1973.   Volume 1,  Summary Report,
   September 1974.  Serial No. 93-94, pages 1  and 3.  U. S. Government
   Printing Office, Washington, D. C. 1974.
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Similarly, the Agency's  Science  Advisory  Board  (SAB)  found  the standards
to be adequate.

     The MAS and SAB findings indicate that there  is  no  reason  to  change
the Agency's concerns with respect to pollutants covered by NAAQS.
Additional data that have become available since the  publication of the
criteria documents confirm the need for control.

     Pursuant to the advice of the National Air Quality  Criteria Advisory
Committee, the criteria  are being updated to incorporate recent findings
of research work.  It is expected that the criteria will be revised in
the following order:  photochemical oxidants and  related organic substances;
nitrogen oxides; carbon  monoxide; and sulfur oxides and  particulates.
Draft revisions are expected to be available starting in late 1977 and
extending through 1980.   The revisions of the criteria documents will
result in an improvement of the data base available in support of  the
standards.  If the evidence so indicates,  the Agency will  initiate
actions for revising the NAAQS.

     Although  the current standards are judged to be necessary and
proper, the Agency recognizes issues associated with them.   A summary
discussion of  the issues associated with particulates, oxidants, and
nitrogen dioxide is provided below.  The issues related to carbon
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monoxide and sulfur dioxide* are limited to those  related  to  the  implementation

of controls; these issues are discussed later in  this  document.   Since

evidence exists that some of the effects ascribed  to  TSP and/or  $03  may

be due to sulfates, a short discussion of sulfates and SC^ is also

provided.**


          2.   Total Suspended Particulates


     The issues associated with the total suspended particulates  (TSP)

NAAQS are related to the health effects associated with the non-specific

complex known as TSP, and the difficulty in developing control measures

for certain sources of particulates that have not traditionally  been

associated with air pollution control programs.


     The NAAQS are set for total suspended particulates which is opera-

tionally defined as the material that is captured on the filter of a

high volume sampler.  In general, particulates of concern  are those in

the respirable size range (i.e., those that can penetrate
*   In relation to sulfur dioxide, it should be noted that the recent
    public controversy on the use of data from the Community Health
    Effects Surveillance Studies (CHESS), although widely publicized, has
    no bearing on the validity of the NAAQS for sulfur oxides or on
    EPA's standard-setting process.  Exhaustive investigations carried
    out by Congressional committees and the EPA have not substantiated
    the allegations made in the press in relation to the conduct of
    the studies or the publication of the findings.  In any event, the
    CHESS investigations have no bearing on the current NAAQS since
    the CHESS were initiated after the NAAQS were set.  The CHESS data,
    along with all other relevant data, will be used for updating
    the criteria documents.

**  For information on the effects of air pollutants, the reader is
    referred to the publications listed in Appendix A.
                                - 22 -

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deeply into the lungs and be deposited  there).   The  high  volume
measurement method, however, does not discriminate between  respirable
and non-respirable particles.   This  factor becomes a matter of concern
where large quantities of particulate matter are collected  by  the
sampling method during dust storms,  leading to  violations of the NAAQS.
Although these natural emissions and associated air  quality levels can
be discounted from total ambient pollutant loadings  where they can be
documented, available information indicates a distinction between
natural and other sources of particulates cannot be  readily made.
     Another dimension of particulate-related issues is that of  the
actual composition of the particulate.   There is health effects  evidence
that incriminates specific substances as being responsible  for observed
health effects currently ascribed to total suspended particulates.
Examples of such substances are sulfate, sulfite, nitrate,  heavy metals,
and polycylic organic matter.  Controls for each of these substances
cannot be set at this time, although the Agency is proceeding to develop
the requisite data for setting appropriate standards (e.g., sulfates)
or has already initiated control action for a specific substance
(i.e., lead).

     Certain sources of particulates present a third category of issues.
Difficult to control sources can contribute significantly to TSP levels.
Examples of these types of sources are the "urban particulate background,"
the natural sources mentioned earlier, fugitive emissions, and  the
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formation of participates in the atmosphere as  a  result  of photochemical
or other reactions involving gaseous substance  emissions.   These
problems are addressed to a very limited extent by existing SIP
control strategies.

     The control of "urban particulate background," such as particulates
emitted by automobiles  and resuspended dust from roads, is of a long-
term nature, to be addressed in the future.  Longer-term or more
difficult solutions, such as the reduction of secondary particulates
formation, must await the implementation of controls for specific
pollutants (e.g., oxidants, sulfates) or the development of long-term
air quality maintenance plans which can take into account these problems.
Fugitive emissions from stationary 'sources generally escape to the
atmosphere in ways other than through'a primary exhaust system or are
more directly emitted to the atmosphere from industrial  processes that
operate out-of-doors, such as coke ovens and rock-crushing operations
at quarries.  Fugitive emissions also result from poor maintenance of
process equipment and from careless process operations.   Once captured,
fugitive emissions can be ducted to available emission control systems,
such as baghouses for particulates and  scrubbers  for gaseous pollutants,
where  they can  be effectively collected.   A regulatory approach which
requires the elimination of or  the capture and cleaning of fugitive
emissions is the  recommended control  strategy for control of fugitive
particulate emissions at the present  time.
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     Fugitive dust emissions from natural  or non-point sources* are found
in the more arid areas of the nation, such as the Southwest, and also
where farming operations and unpaved roads are prevalent.   Windblown
dust (both natural dust and soil  exposed by man, e.g., farms, roads)
and dust generated directly by man's activity (e.g., driving on unpaved
roads), creates high ambient concentrations of particulate matter.  The
control strategies determined necessary to attain national standards
in AQCR's impacted by fugitive dust generally indicate that unconventional
air pollution control techniques  may be required, such as:

     .  Chemical stabilization of soils;

        Implementation of soil management control programs;
     .  Paving of more heavily traveled unpaved roads in generally
        urbanized portions of AQCRs;

        Speed control on all unpaved roads; and
     .  Stabilization or watering of construction sites, material
        storage piles, tailing piles, and animal feedlots.
     These fugitive dust control  strategies have not been fully
implemented because they include some controls  that are considered  to
be socially disruptive and unreasonable.  Some  of the areas which would
*  The term "fugitive dust" should be distinguished from the term
   "fugitive emissions."  "Fugitive emissions" generally refer to
   industrial process emissions which do not pass through a
   stack or chimney.
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have to implement these control  measures  for  fugitive  dust  control  also
tend to be impacted by high particulate levels  resulting  from  natural
wind-blown dust from storms.

          3.   Sulfur Dioxide and Sulfates

     The issue  associated with sulfates  is whether or not  the health
effects currently ascribed to sulfur dioxide are actually related to
sulfates in general, or perhaps, to specific sulfur-containing compounds,
such as sulfuric acid, zinc ammonium sulfate, ferric sulfate,  and cupric
sulfate.  The significance of this is that sulfates tend to be more
persistent in the atmosphere than S02 itself, and much of a  24-state area
in the Northeast has sulfate levels approaching or exceeding the ambient
concentrations which may be associated with health effects  even where
S02 levels are meeting the  S02 NAAQS:  In addition, there may be synergistic
health effects associated with the action of sulfates and other pollutants.
The sulfate issue is further compounded by the long-term environmental
effects that are suspected  but not yet proven, such as acidification of
rain.  The  information currently available is sufficient to cause concern,
but not sufficient  to warrant specific regulatory action.
      EPA's  policy on sulfates  (outlined in the September 1975 Position
Paper on_  the Regulation of Atmospheric Sulfates*) recommends  1 imiting
 *   U.  S.  Environmental  Protection Agency, Office of Air and Waste
    Management,  Office of Air Quality  Planning and Standards, Research
    Triangle  Park,  North Carolina  27711; EPA - 450/2-75-007
    September 1975.
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increases in SOX emissions.   Health  effects  studies  are continuing, but
the complexity of the problem is  such  that  standards  specific  to sulfates
will probably not be set prior to 1982.   EPA's  policy recommends limiting
any SOX emission increases in a broad  24-state  area  of the  heavily
industrialized eastern and northern  states  until  better data are collected
on the adverse health effects of sulfates.

          4.   Photochemical  Oxidants
     Issues associated with the NAAQS  for photochemical oxidants are
related to regional transport, natural ozone levels, the  components  of
photochemical oxidants other than ozone,  and the relationship  between
hydrocarbon emissions and photochemical  oxidants in  the ambient air.

     A significant new dimension is  added to the oxidant  air  pollution
problem by two recently acknowledged factors:  It appears that all  non-
methane hydrocarbons and other reactive organic substances  eventually
participate in photochemical  reactions, and oxidant  precursors are
transported large distances in stagnant air parcels  associated with high
pressure systems.  Although oxidant (and precursor)   transport has been
identified as one of the causes of ambient air quality levels in excess
of  NAAQS in some areas, it should be noted that the primary cause of
violations of the NAAQS is the emission of oxidant precursors in the
area where high readings are found.   The oxidant levels measured
                                  -  27  -

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in or immediately downwind of a major urban area are principally due
to emissions in that urban area, not to rural  emissions or emissions
from other urban areas upwind.  Control within broad urban areas will
continue to be most effective in reducing peak oxidant levels.

     The mechanism postulated for oxidant transport is as follows:
As high pressure systems travel through the U. S. in the summer, they
provide ideal conditions for oxidant formation—large amounts of HC
and NOX are injected into the air mass by the multiplicity of sources
in these areas (both urban and rural), extended time periods are
provided for all HC to participate in photochemical reactions, the
high temperatures and insolation associated with these systems enhances
photochemical reactions, and little opportunity exists for dissipation
of oxidants formed.  In brief, these atmospheric systems enhance
photochemical reactions and impede natural cleansing of the atmos-
phere.  In addition, evidence indicates that all non-methane hydrocarbons
and other reactive organic substances eventually react photochemically
if given sufficient time to react.  (Studies in the past had concen-
trated on limited timeframes and limited geographical areas.)  This
means that all non-methane hydrocarbon and other reactive organic
substance emissions are of significance for the control of photochemical
oxidants, and that emissions in one city or area can result in high
oxidant levels in other areas or cities.

     EPA is currently attempting to better define  the nature and
magnitude of precursor transport, but  the  implications for control
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programs are clear:   control  programs will  have  to consider and

encompass wide geographic areas,and  all  sources  of photochemical

oxidant precursor emissions may have to  be  abated.  Although  the

adequacy of our understanding of emission  reductions  required to

attain NAAQS for oxidants is not as  good as would be  desirable

(current techniques  being less than  ideal  for deriving  control require-

ments*), it is clear that reductions of  HC  emissions  lead to  improvement

in oxidant air pollution.  Trends in the Los Angeles  area (which  has

available the largest data base on oxidants) and laboratory data

support this conclusion.   Therefore, EPA's  strategy  for oxidant control

is to reduce hydrocarbon emissions whenever it is  feasible-   Oxidant

control plans are to focus on the areas  responsible  for the greatest

proportion of hydrocarbon emissions, i.e.,  urban areas.  (States  can,

if they so choose, extend controls for hydrocarbons  to  areas  outside

the urban concentrations which are the focus of EPA's strategy.)
*  The factors which determine the concentrations of oxidants formed
   in the atmosphere include:  the amount and kinds of organic
   compounds initially present and the rate at which additional
   organics are emitted into the atmosphere,  the amount of nitrogen
   oxides initially present and their emission rates,  and sunlight
   ultra-violet intensity, temperature, and other meteorological
   factors.  The interactions of these factors and the chemical
   reactions involved are very complex and have been the subject of
   continuing scientific investigation during the last 20 years,
   including atmospheric studies, laboratory smog chamber studies,
   and computer simulation of the oxidant forming process.  Nitric
   oxide (NO) is the major form of nitrogen oxide emitted in combustion
   processes.  Nitrogen dioxide (N02) is formed from NO and is the
   compound which decomposes in sunlight to initiate the formation of
   ozone.  Because the relationship between hydrocarbon emissions and
   oxidant concentrations is dependent on so many factors, various
   attempts have been made to develop a simplified relationship.  These
   bases for control strategy derivation are not discussed in this
   document.

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     It should be noted that in many cases SIPs do not provide for
oxidant precursor control for areas violating NAAQS since data on
ambient air concentrations of oxidants were not available at the
time of plan preparation.  Furthermore, current SIP control strategies
for the attainment of the oxidant NAAQS were developed on the assumption
that local high readings of oxidants were the result of precursors
emitted in the area surrounding the monitor reporting the high readings.
The new data on air quality and photochemical oxidant formation indicate
that very complex and far-reaching control programs will have to be
developed if the standards are to be attained in the future.  The
clear implication is that controls probably will be required on a
much broader geographic scale than has been the case to date.

     In urban areas, the ratio of hydrocarbons to nitrogen oxides
tends to be low so that changes in levels of photochemical oxidants
locally generated are quite sensitive.to changes in the levels of
hydrocarbon present.  Thus, hydrocarbon emission control programs
would be expected to be effective in reducing the amount of photo-
chemical oxidants locally generated in the urban area,  thus also
reducing the amount transported to neighboring rural areas.

     An investigation is underway to determine the extent of  the
geographical area around urbanized locations where hydrocarbon
emission control programs will be most effective in reducing  photo-
chemical oxidant levels.  Early findings of this investigation
indicate that these areas may be proportional to city size and may
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extend up to 85 miles  from major  metropolitan  areas.   In addition,
upwind-downwind measurements  around  smaller  urban  areas and  isolated
point sources of hydrocarbons and nitrogen oxides  indicate that  there
is little if any increase in  observed  photochemical  oxidant  concen-
trations as a result of the emissions  from such  smaller urban  areas
and isolated point sources.  Although  very limited data are  available,
it appears that urban  areas with  a population  less than 200,000
produce little, if any, measurable increase  in photochemical oxidant
levels.

     In view of the widespread nature  of oxidant problems, emphasis
for setting new source performance standards for stationary  sources
is being shifted to sources of oxidant precursors.  Mobile sources
controls also concentrate on this objective—all significant mobile
sources of HC and NOX emissions are in the  process of being  covered by
stringent standards applicable to new  sources.  However,  new source
controls will not lead to attainment of the  standards in  many  areas
of the nation, nor is there assurance  that  purely technological
solutions will lead to requisite emission reductions to  attain and
maintain the NAAQS.  A rethinking of many of the ways in  which
transportation sources are used is required, as well as  long-term
consideration of the air pollution impact of the sources  of  hydrocarbons,

     An additional issue encountered with the NAAQS for photochemical
oxidants is the low value of the standard (0.08 parts per million,
                                - 31  -

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one hour average)  when compared  to reported  natural  background  values,
which range in the order of 0.04 to 0.06  ppm.   It  has  been  argued  that
many areas with reported violations of the NAAQS are violating  NAAQS  due
to natural causes  (due to ozone  formed from natural  HC sources, such  as
forests, or due to ozone advected  from the stratosphere),  and, therefore,
that no control actions are possible.  Whatever merit these  arguments  may
have, levels in excess of the NAAQS are generally  related to human
sources of photochemical oxidant precursors, so the need for HC  controls
will not be diminished.

     Another issue is related to the measurement  of oxidants.   The NAAQS
for photochemical  oxidants were  established on the basis of evidence
related to the health effects of oxidants; the currently accepted
Federal Reference Method (FRM) for ambient air quality monitoring of
oxidants is specific for ozone,  one of the components  of photochemical
oxidants.  (The oxidant found in largest amounts  is ozone;  oxidants also
include the group of compounds referred to as PAN, or  peroxyacetyl
nitrates, and other compounds produced in much smaller quantities.)  It
has been argued that ozone, by itself, is a poor proxy for the complex
known as photochemical oxidants, and that control  plans derived on the
basis of measurements made with  the FRM are not necessarily justified.
However, it should be noted that ozone measurements are closely related
to measurements for total net oxidants.*
*  Air Quality Criteria for Photochemical Qxidants, U. S. DHEW,
   NATCA, March 1970, Publication AP-63.
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          5.    Nitrogen  Dioxide

     The review of the NAAQS  indicated  that a  possible deficiency of the
N02 NAAQS was the lack of a short-term  standard  for protection against
the effects of peak levels of this  pollutant.  Current evidence  suggests
that the ambient air quality  standard should  include  a limitation on
peak levels of exposure; the  data  suggest that the  limitation should be
on repeated peak levels rather than a limitation on one  peak per year,
but the health effects data base is not yet sufficient to  warrant control
action on this basis.  The short-term standard is expected to be in
addition to the current annual average  standard, which will continue to
be used to assess plan adequacy and to  implement controls  for NC^-
     E.   Monitoring Air Pollution

     Proper judgments about  the attainment and maintenance of the
NAAQS can only be made with  data obtained from an adequate monitoring
program.  It is essential that strategies for the control  of  pollut-
ants also include monitoring  of these  pollutants.  Monitoring covers
those activities which are related to  establishing  the concentration
or quantity of a pollutant.   These activities include ambient air
monitoring, source emission  monitoring, and dispersion modelling.
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     In recognition of the critical  role that monitoring  plays  in
air quality management decisions at  all  organizational  levels,  EPA
has established the Standing Air Monitoring Work Group.   The Work
Group has reviewed air monitoring activities performed  in support
of SIP's and has developed an overall  monitoring strategy which,
when fully implemented, should correct identified problems and
improve current monitoring operations.   (The final strategy
document is to be available by summer 1977.)  The implementation
of this strategy is intended to be phased over a five year period
since it is recognized that rapid changes to on-going monitoring
programs entail  the risk of decreasing the effectiveness of con-
trol program activities dependent on monitoring data.
     The monitoring strategy emphasizes the need for quality
assurance.  Since the quality of the monitoring data has  profound
impact and implications on the soundness of pollution control
decisions, the implementation of a minimum quality assurance program
for both source and ambient air monitoring activities is  to  be given
greater emphasis.  The goal is to assure that all agencies involved
in air monitoring use the best available instrumentation and quality
assurance techniques within their limited resources.
     Key changes in air monitoring are directed towards  increasing
EPA's and State/local agencies' ability to make decisions concerning
attainment and maintenance of the NAAQS through a refined ambient
air monitoring program.  These changes are to be made after  a
comprehensive review of existing state air monitoring networks.

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The strategy recommends that as a result of this review,  a small

core of fixed National Air Quality Trend Stations operated by

State and local agencies be established.  Data from these stations

will  in most cases  be adequate to meet EPA HQ minimum needs for

determining trends and evaluating and developing national control

policies.

     Since the national trend stations will meet only a part of the

State and local agency needs for air monitoring data, additional

sites will be operated by these agencies as required.  These moni-

toring sites will be used to supplement the national trend site data

and provide for more complete geographic coverage, especially in

non-attainment areas.  The sites comprising this network would be

reviewed annually as to the need for relocation.  All monitoring

performed apart from these fixed networks would be flexible and

thus easily adaptable to changing priorities and needs of the

State and local agencies.  This type'of monitoring should enhance

the usefulness of the fixed station data by increasing the coverage
                                               ,•
of that network for short time periods and by producing data where

none existed previously or where data are no longer valid.

     In the future, State and local agencies will need to rely more

heavily upon dispersion models to augment their capabilities to

predict the impact on air quality of individual sources or source

categories.  This is especially important to support activities

involving new source reviews.  Multi-source urban dispersion

modelling can also be used to evaluate effectiveness of proposed



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SIP revisions and, in conjunction with population distribution infor-
mation, is an extremely valuable tool in estimating the exposure of
the population to levels above the ilAAijS.  This latter effort is
valuable in displaying information to the public in a readily under-
standable manner as well as providing a good measure of the success
of control programs.
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II.   Status of Air Pollution  Control  and  Future Actions
     A.    Overview of Progress  to  Date

     The air has become measurably cleaner  since  1970.*   Reductions
in emissions have resulted in improvements  of  ambient  air quality  in
terms of the actual levels of air  pollutants in  the  air  and  in  terms
of the number of times that the NAAQS are exceeded.  Both of these
measures indicate that population  exposures to unhealthy levels of air
pollution are decreasing.   Although standards  are not  universally  met
at this time, important reductions in population  exposure have  been
achieved.  Continued progress in reducing population exposures  is
expected in the future and is the  focus  of  control  programs.

     The concentration of particulate"s  in the  ambient  air has decreased
annually at an average rate of 5 percent through  1975.   A review of
the most recent sulfur dioxide ambient  data shows that concentrations
in urban areas have decreased an average of 30 percent since 1970.
Fewer than 10 percent of all  urban monitors are  exceeding the sulfur
dioxide standards.

     For carbon monoxide, associated mainly with motor vehicles,
historical data are limited.   Available data in  the several  States
*  Additional material on environmental status is available in
   National Air Quality and Emissions Trends Report, 1975, U.  S.
   E.P.A., Office of Air and Waste Management, Office of Air
   Quality Planning and Standards, Research Triangle Park, North
   Carolina  27711; November 1976 (EPA-450/1-76-002).   This report
   is issued annually.
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and major cities suggest a continuation in the general  improvement
noted previously in EPA trend reports.   The average number of occa-
sions in which 8-hour concentrations exceed the carbon  monoxide
standard has declined, typically by 50 percent in many  of the urbanized
portions of these States.

     Historical data on oxidants, which are produced largely by
hydrocarbon and nitrogen oxides emissions from both stationary and
mobile sources, are non-existent in all but a few urban areas.  Los
Angeles and San Francisco have shown notable improvements where the
number of hours in excess of the oxidant standard has been reduced
by as much as 50 percent since 1970 at many of the monitoring stations.
(It should be noted that California has imposed stringent HC emission
control programs.).
     Nitrogen dioxide emissions have increased nationally about 10
percent since 1970.  Because of recent changes in measurement methodology
for monitoring  nitrogen dioxide, few areas have sufficient historical
data to assess  trends.  Valid data  indicate that only a few areas of
the country have ambient nitrogen dioxide concentrations  in excess of
the national standard.

     Although significant progress  has occurred, many problems remain.
The solutions to these problems affect fundamental activities of  the
nation such as  power generation, industrial production, transportation,
and agriculture.  Some pollutant levels can be reduced through better
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compliance with existing regulations.   Others  require  new  and
innovative revisions to existing control  strategies.

     Particulates and sulfur dioxide are  predominantly associated with
stationary sources of pollution.  Approximately 22,000 major indus-
trial emitters (those capable of emitting over 100 tons of pollutants
each year) account for about 85 percent of the stationary  source air
pollution.  By July 1977, EPA expects over 90  percent  of these major
emitters to be in compliance with existing State Regulations.   For
particulate matter, numerous small sources in  urban centers require
control.  Some areas will require control strategies beyond the
classic stack controls, including controls of fugitive emissions,
other particulates, and fugitive (windblown) dust.  For sulfur dioxide,
non-attainment results primarily from'delayed implementation of
existing regulations for emissions from power plants and non-ferrous
smelters.

     For photochemical oxidants, strategies are based on controls of
hydrocarbon emissions from both stationary and mobile sources.  Oxidant
and carbon monoxide concentrations are expected to improve somewhat
in most areas of  the country as controlled automobiles replace older,
uncontrolled vehicles.  Even with substantial   improvement  in air
quality for oxidants and carbon monoxide, however, a  large number of
AQCRs are expected  to experience violations of the ambient standards
during the next  10 years.  Additional  urban areas will require
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transportation control  measures in order to attain standards  even  by  the
mid-1980's.

     For nitrogen dioxide, the typical  problem, where it does exist,  is
in an urban area where observed nitrogen dioxide concentrations are
either slightly above or below the standard.  Such conditions generally
represent a problem for maintenance rather than for attainment of the
standard.

     B.   SIP Revisions

     Actions taken by EPA and the States with respect to non-attainment
areas involve a mix of actions aimed at continued implementation of
emission reduction provisions of the SIPs, at identifying areas which
require revisions of the SIP, and at revising the SIPs where current
SIPs are found to be substantially inadequate to attain the NAAQS.  The
process involves identifying non-attainment AQCRs, identifying the
factors that result in non-attainment, developing plans for corrective
action, and implementing the corrective actions.
     Initial calls for SIP revisions were  issued by July 1, 1976, for
SIPs which were determined to be substantially inadequate to attain the
NAAQS.  Calls for SIP revisions were issued as follows:
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                                    Pollutants  for  Which  a
                                   Plan  Revision  Is Required
                               ISP.     sp_2      co     gx
Number of States issued
a call for revision*            31       12      22     29
*  Appendix E identifies the specific States.

     The indication that a State needs a SIP revision does not necessarily
indicate that conditions exceeding the national  ambient standards prevail
throughout the State.   The calls for revision indicate that a State has
to reassess its air pollution problem and develop,  if warranted, addi-
tional control measures for attaining standards.   In addition, special
planning procedures must be followed for 119 areas  identified as air
quality maintenance problem areas.

     The State implementation plan revisions now being required are
subject to two submission dates.  First, if needed, all achievable
emission limitations must be submitted as SIP revisions no later than
July 1, 1977.  The term "achievable" is intended to require reasonable
"technology forcing" regulations if necessary, rather than regulations
based simply on "off-the-shelf" technology.  Second, all other measures
needed to attain and maintain the NAAQS must be submitted no later
than July 1, 1978.  These "other measures" should be comprehensive and
innovative where needed, and may include items such as land use measures,
transportation controls, transit improvements, zoning ordinances,
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building codes (such as to increase insulation,  thereby decreasing
energy use), and inspection/maintenance programs (for stationary
and/or mobile sources).  This schedule for plan  revision is under-
going revision as EPA and the States determine the actual  controls
required.  Some delays beyond these dates are to be expected in the
process for plan revision, especially in relation to oxidants.

     By 1978, it is expected that all achievable control measures
would have been identified if required for the attainment of the
NAAQS, that a plan for the implementation of these measures will have
been submitted by the states and approved by EPA, and that the  process  for
identification and adoption of the measures requisite for the maintenance
of the standards will have been implemented.  Beyond 1978, actions
would be related to the implementation of the control plans.  It is
expected that a relatively greater emphasis will be placed in this
time period on new sources, both for purposes of prevention of air
pollution (including prevention of significant deterioration) as well
as the maintenance of NAAQS.

     C.   Emission Reductions from Sources — Issues and Policy

          1.   Introduction

     The preceding discussion of issues associated with the NAAQS
highlighted the factors that affect  the current status of  the national
air pollution control program and that have dictated the Agency's
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strategy in implementing the Clean Air Act.   The currently  documented
widespread need for revisions of the SIPs reflects  the  improved  under-
standing, developed over the last few years,  as  to  the  factors that
affect air quality and the actions that still  must  be taken if the
environmental protection goals are to be achieved.   Another factor that
has contributed to the lack of attainment of  the standards  has been  the
lack of action  on the part of pollutant sources  in reducing emissions.
The significant issues that have impeded full  implementation of  these
controls are examined below.

          2.   Total Suspended Particulates  and  Sulfur  Dioxide

     The stationary  sources of particulates  and sulfur oxides  (e.g.,
factories, power plants, home heating) have  traditionally been the
focus of air pollution abatement efforts since these sources have been
recognized   as   responsible for the bulk of the particulate and sulfur
dioxide air  pollution.  Based on an overall  assessment  of the status
of compliance of sources and the need for corrective actions, EPA
generally has placed highest priority on the implementation of  control
requirements for sources of sulfur oxides and particulates.  This
emphasis has resulted in the improvements in air quality indicated in
the preceding section.
     With a  few minor exceptions  (e.g., particulates emission limitations
for the State of Illinois) all states now have enforceable emission
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limitations for stationary installations.*   Except  for  portions of
16 States (where extensions of up to 2 years were granted  for  one or
more pollutants), the primary National Ambient Air  Quality Standards
were to be achieved by May 31, 1975, i.e.,  substantially all sources
should have been in compliance with the SIP emission  limitations  by this
date.  EPA, State, and local enforcement programs have  focused first  on
ensuring compliance by major emitters in order to produce  the  greatest
reduction in pollution levels with available resources.  Despite  progress
in SIP enforcement, a number of facilities  within major source categories
have not achieved compliance with emission  standards  within the time
limits prescribed by the Act.  Notable among these  source  categories  are
coal-fired power plants, iron and steel manufacturing plants,  and
smelters; these sources are discussed below.

     In addition to the problems caused by  continuing violations  by
classes of heavy industrial emitters, it is becoming  increasingly apparent
that in many areas of the country poor air  quality  is the  result of
large numbers of violations by smaller emitters (i.e.,  less than 100
tons per year).  EPA and States are conducting analyses of non-attainment
AQCRs to identify those where minor sources are responsible for delays
in the attainment of health-related air quality standards  so that enforce-
ment efforts and adoption of adequate regulations  can be initiated where
needed.
*  On the order of 200,000 stationary sources are subject to SIP emission
   limitations.  Of this number, approximately 22,000 are major emitters.
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     Furthermore,  it is clear that,  in  many  cases,  traditional  control
of stationary sources (e.g.,  limitations  placed on  emissions  from  a
smokestack) will not suffice  to attain  and maintain the  NAAQS.   Ambient
air loadings of particulates  often are  significantly influenced by other
than stack emissions:  the formation of particulates in  the atmosphere
from gaseous emission; the contributions  from motor vehicle exhausts;
the re-entrainment of dust from streets;  and dust-producing activities
such as construction, unpaved roads, and  farming operations.   These
issues are discussed earlier, under the TSP  NAAQS section.

     In relation to sulfur dioxide, shortages of low-sulfur-content  fuels
and the national policy of reducing reliance on insecure foreign sources
of petroleum will result in the utilization  of higher sulfur content
fuels  (e.g., coal rather than fuel oil, fuel oil rather than natural gas)
in the future.  EPA views these developments with concern since they have
potential for aggravating sulfur dioxide air pollution problems as well
as increasing the resulting atmospheric loading of sulfates.
                a.   Primary Non-Ferrous Metals Smelters

     The nation's 25 non-ferrous smelters account for about 10 percent
of the total sulfur oxides emitted by stationary sources.  Regulations
for control of  smelters located in several States* were proposed by
EPA in 1972.  Numerous court  suits were filed  by the individual non-ferrous
 *  These  states  are Arizona, New Mexico, Nevada, Utah,  Idaho and Montana.
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metal smelters against both the proposed regulations  as  well  as
subsequent final rulemaking.  The issue involved is the  degree to
which utilization of Supplementary Control  Systems (SCS) and  increased
stack height is to be permitted and the amount of emission reductions
that should be required through the application of constant emission
reduction systems.

     The regulations applicable to smelters require application of best
available control technology (BACT) as a long-term goal, but during
the interim permit the use of reasonable available retrofit control
technology (RACT) and, if necessary, also allow the interim use of SCS
and tall stacks until BACT-calibre techniques that are less costly than
those that exist today become available.  Each smelter using SCS is
further required to accept liability for NAAQS violations in its area
of liability and to conduct a research and development program to hasten
the development of less-costly, BACT-calibre emission reduction technology.

     For some smelters, the alternative to the use of SCS and RACT would
be economically unrealistic.  This industry is mostly composed of older
plants and is. in competttion with foreign smelters.  EPA has taken into
account the specific problems affecting this industry.  Thus, special
dispensation has been granted and EPA, for the interim,  is not requiring
that NAAQS be met solely through emission reduction techniques.  It
should be noted that, in general, EPA is not requiring any changes in
process equipment,as would be required in many instances if BACT-calibre
equipment were  the present-day standard.  EPA  is requiring only  that
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RACT emission control  facilities  be  installed  and  maintained and, for
the interim, is also allowing  SCS to be  used  for gas  streams that would
otherwise require BACT-calibre control equipment.   In all  events the
control strategy permitted must demonstrate attainment and maintenance
of national ambient standards.

               b.   Iron and Steel Mills/Coke Plants

     The iron and steel industry presents one of  the  most difficult
compliance problems for state and Federal air pollution enforcement
programs.  There are about 246 steel and coke-making  installations  in
the United States, of which 218 produce  iron  and  steel (and may or  may
not produce coke).  The remainder solely produce  coke to be used in
metallurgical and other industries.   Nearly all  of these installations
are located in areas where the primary NAAQS  have  not been attained.   At
least  one SIP emission limitation is being violated at almost  every
installation.

     The steel industry is characterized by less  than half the degree of
compliance of all major sources.  Although the iron and steel  industry
industry faces difficult problems in meeting emission limitations  and,
in general, in complying with air pollution control  requirements,  this
industry generally has failed to make reasonable progress in controlling
air pollution.   The Agency judges the lack of progress to have been
caused,  in many  cases, by industry  failure to do what is  achievable
rather than the  magnitude of  the task facing the industry.  However, there
are substancial  differences in control levels from company to company,
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 and  significant recent progress has been made at a number of iron and
 steel mills.  The Agency will continue to concentrate its enforcement
 efforts  to assure that iron and steel mills come into compliance with
 SIP  requirements.

               c.   Coal-Fired Power Plants

      Coal-fired power plants account for approximately 55 percent of
 sulfur air loadings.  By mid-1973, it became evident to EPA that many
 coal-fired power plants were not making plans to comply with sulfur
 oxide emission limitations because supplies of low-sulfur coal  (the
 favored  approach to compliance with emission standards) were becoming
 scarce,  and  the principal alternative means to compliance, the  stack gas
 scrubber, was viewed by the industry as unreliable.  National public
.hearings were held in the fall of 197-3 to determine the validity of the
 utilities' contentions regarding optional means of compliance.  The 1973
 hearing  panel concluded that the basic technology problems associated
 with flue gas desulfurization  (FGD) had been solved or were within the
 scope of current engineering and, further,  that FGD could be applied at
 reasonable cost.  A special EPA enforcement program was then initiated
 for  power plants on the basis  of these findings.

      EPA recognized, when it approved the State Implementation  Plans,
 that there would be shortages  of acceptable coal  if all the  States
 enforced their control regulations.  To alleviate this  potential  shortage,
 EPA  developed a policy  (the  "Clean  Fuels  Policy") of encouraging  State
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review of plans in order that sulfur emission limits  be  modified
whenever this could be done without exceeding the primary air quality
standards.  A similar policy was adopted by the Congress in the Energy
Supply and Environmental Coordination Act of 1974 (ESECA).  The policy
encouraged the States to analyze their control requirements in a more
detailed fashion than was generally done at the time of initial SIP
development.  These actions are specific to each State,  as the degree
of control required to achieve the primary standard varies widely
between air quality control regions and individual sources in each
region.  Reviews of SIPs (required by ESECA) have been carried out.  The
results have been submitted to the States for their consideration and
action.

               d.   Tall Stacks and Supplemental Control  Systems

     EPA's policy on the use of pollution dispersion techniques, such
as tall stacks and supplemental control systems  (SCS)*, was  published
in the Federal Register of  February 18, 1976  (41FR7450).   The  policy
is also contained in a guideline to EPA regional offices  on  the
acceptability of tall stacks and SCS as part of  the SIP  control  strategy
*  The term "supplemental control system" means any  system which  limits
   the amount of pollutant emission during periods when meteorological
   conditions conducive to ground-level concentrations in excess  of
   national standards exist or are anticipated.  SCS will be  generally
   effective only for isolated sources.
                                 -49  -

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for SC>2 control.*  This  policy is  effective  as  of  January  13,  1976.

     The policy (derived pursuant  to  opinions  rendered  by  three  United
States Circuit Courts of Appeal),  in  essence,  is  that stack  height
increases and/or SCS are acceptable control  strategy measures  only  after
the application of other available control measures and are  never permitted
as a means of allowing the increase of emissions  at any source.   Constant
emission limitation is the preferred  strategy  for attaining  and  maintaining
the national standards.   For smelters and certain older power  plants,
SCS is acceptable only as a temporary measure  in  conjunction with the
use of reasonably available control technology (acid  plants  for  smelters
and coal washing for power plants) and only  in circumstances wherein the
SCS can reliably attain and maintain the national  standards.  SCS is not
allowed for new sources.
     The EPA guidance is used by the regional  offices  in reviewing  plan
revisions and in re-evaluating existing State  Implementation Plans  to
determine whether any such plans have the potential  for, or explicitly
permit, the use of dispersion dependent technology as  a means  of achieving
ambient air quality standards.  The principles set forth in the document
will also be used in reviewing State new source construction permits.
* There is no guidance provided in regulatory format.  Regulatory
  action on tall stacks and SCS is part of the specific SIP approval/
  disapproval and promulgation actions.  The EPA guideline document
  is Legal Interpretation and Guideline to_ Implementation of Recent
  Court Decisions on the Subject of_ Stack Height Increase as a_
  Means_ of Meetin'gTederal Ambient Air Quality Standards, 0"A~QPS
  No. 3.0-003.

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     There are generally three situations--!imited to  SC^ emissions--
which permit the application of SCS:

     (1)  Under prohibition orders issued by_ FEA under the Energy Supply
and Environmental Coordination Act.  Power plants required to convert to
coal must install control equipment and/or use fuel which would comply
with the SIP as expeditiously as possible.  In the interim, ESECA
requires that the primary standards be met; an enforceable and reliable
SCS can be used to achieve this purpose when primary standards are
attained and coal which conforms with SIP requirements is unavailable.
     (2)  Under Enforcement Orders.  When EPA issues an enforcement
order  to a source to come into compliance with the SIP, it may be
necessary to require the source to apply an SCS for an interim period
in  order to protect the ambient standards.

     (3)  AJ Part of an SIP Revision.  Under this mechanism, a source
cannot operate an approved SCS unless a number of conditions are met,
including installation of Reasonably Available Control Technology  (RACT)

               e.   EPA's Policy  on SIP Revisions Aimed at Permitting
                    Use of Higher Sulfur  Fuels

     The energy  situation, the economy, and to some extent the low S02
levels being reported  in most  areas are causing  a  number  of  States to
consider revisions to  SIPs which  will permit  higher sulfur fuel  to be
used in  selected AQCRs.  However, changes  in  fuel  use will tend  to
                                 - 5T -

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increase emissions  of sulfur,  resulting  in  increased  sulfate concen-
trations.   Given the lack of a defined control  requirement  for  sulfates,
the Agency cannot deny State requests  for changing  regulations  appli-
cable to fuel  sulfur content if the State demonstrates  that the S02
standard will  be attained and maintained.  On  the other hand, evidence
available to date indicates that the effect of sulfates may be  as
important, if not more so, than the effects of currently controlled
pollutants.  Therefore, the Agency views with  concern the trend to
increase the emissions of sulfur to the  atmosphere  by the use of higher
sulfur content fuels.

     EPA's policies and programs involving  sulfates,  significant
deterioration, tall stacks, SCS and New  Source Performance Standards  are
aimed principally at minimizing S0_ increases.  The sulfate policy
recommends limiting any SC^ emission increases in  a broad 24-state  area
of the heavily industrialized eastern and northern  States until better
data are collected on the adverse health effects of sulfates.
 The prevention of significant deterioration regulations legally limit
SOp air quality increases by establishing constraints below the NAAQS
for S02-*  The tall stack and SCS policies, recently confirmed  by
Federal court decision, require the application of all available permanent
control measures before dispersion techniques  can be used to attain
standards.
*  It should be noted that a change to the use of fuels which lead to
   increased emissions is not covered by the PSD regulations.
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     On the other hand,  the Clean  Fuels  Policy,  which was  initiated
early in 1972 for coal-burning sources,  was  an  attempt  by  EPA  to  permit
continued burning of relatively high-sulfur  coal,  where this would  not
lead to violations of the ambient  standards, in order  to release
presently limited supplies of lower sulfur coal  for use in other, more
critical, areas.  If a State emission reduction schedule prevented
continued burning of high sulfur coal that was  adequate to meet the
NAAQS, the Clean Fuels Policy encouraged the State to  revise its  SIP to
make it legal.  Congress reinforced and extended the philosophy of  the
Clean Fuels Policy by its passage of ESECA in 1974.  The intent of
Section 4 of ESECA was to encourage States to relax S02 emission  limits
where possible without causing violations of the ambient S02 standards,
even if this means an actual increase in SCL emissions.  The Clean  Fuels
Policy and the ESECA legislation reflect a policy of cooperating with
States which want to relax emission constraints, provided that the S02
standard is attained and maintained.

     Given the potential conflicts among the foregoing policies, the
general policy on SIP revisions which relax SCL emission  limitations is:
First, the basis for approval must be whether the national primary
standards will be attained and maintained in accordance with  the Clean
Air Act.  The secondary  standard must be attained within  a reasonable
time.  Second,  EPA must  cooperate with national energy  programs  to the
fullest extent  possible  consistent with the timely attainment and
maintenance of  standards.  Finally,  in view of  the concern over  other
                                 - 53 -

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pollutants and effects related to S02 emissions (e.g.,  sulfates,
secondarily formed particulate, and acid rain), rigorous demonstrations
that proposed SIP revisions will attain and maintain standards will  be
demanded.

     It is expected that the end result of these policies and activities
will be:to attain the current primary sulfur dioxide standards everywhere
as rapidly as possible; ensuring that the health effects from sulfate
particulates are minimized; electrical power generation capability will
not be disrupted; and domestic energy resources will be used.  This
approach will also allow electric utilities to continue to use available
high sulfur coal production to meet    the nation's energy demands where
such fuel will not cause violations of NAAQS.
          3.   Photochemical Oxidants, Carbon Monoxide, and
               Nitrogen Dioxide*
               a.   Introduction

     Motor vehicles are responsible for virtually all man-made emissions
of CO in all areas of the nation; they account for a variable (yet
substantial) proportion of hydrocarbon and NOX emissions  (between 27
percent and 87 percent for hydrocarbons and  25 percent  to 65  percent
for NOX).  The control of CO,  oxidants, and  NOX is  significantly
*  For convenience,  the pollutants will be referred to as CO  (for
   carbon monoxide)  and N02  (for nitrogen dioxide).  These pollutants
   are also referred to as automotive-related pollutants due  to  the
   predominance of motor vehicles as  the principal emissions  source.
                                  -  54 -

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 related  to the control of motor vehicle emissions.  However, the

 variations in the contributions of sources for different areas of the

 nation have  resulted  in the development of specific control measures

 unique to each area.* Control strategies are primarily concentrated

 on  reducing  emissions of photochemical oxidants precursors  (i.e.,

 organics**)  and  carbon monoxide.  Somewhat lower  emphasis has been

 placed to date on the control of NOV  (also an oxidant precursor***)
                                   A

 emissions due to the  lesser magnitude of the N02  air pollution problem,

 the reliance on  organics control for achieving oxidant reductions, and

 limited  available control techniques.


      EPA policy  for control actions limits implementation to those controls

 which are not economically or socially disruptive.  Highest priority  for

 control  has  been given to attaining emission reductions from stationary

 sources  of HC through the application of Reasonably Available Control

 Technology and  the  implementation of  State motor  vehicle  emissions

 inspection and maintenance programs for those areas for which SIPs
 *  In relation  to  automotive-related  pollutants,  it  should  be  kept in
    mind that SIPs  are less  well  advanced  in  terms of development and
    implementation  of adequate  planning  processes  and controls  than
    are the SIPs for TSP and S02.

 ** The principal  sources of organic compounds  are the hydrocarbon
    emissions from  automobile and truck  exhausts,  gasoline vapors,
    paint solvent evaporation,  open  burning,  dry cleaning  fluids, and
    industrial  operations.   There are  also natural sources such as
    seepage from the ground  and emissions  from  vegetation.

*** Nitrogen oxides are emitted primarily  from  combustion  sources such
    as electric power generation units,  gas and oil-fired  space heaters,
    and automobiles, diesel  and jet  engines.
                                  _ 55  .

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already provide for such measures.   Adoption of control  measures for

areas requiring SIP revisions will  follow guidelines as  to reasonableness

of control measures.*


               b.   Motor Vehicle Emissions Control**


     Given the nature of the automobile industry and the universal  use
             •

of automobiles, the most effective point for controlling motor vehicle

emissions is by providing for the incorporation of controls into new

vehicles prior to sale to the ultimate user.  The Clean  Air Act provides

for a comprehensive control strategy aimed at the control of new

vehicles.                                              '


     The Federal Motor Vehicle Control Program (FMVCP) provides for a

cumulative improvement in ambient air quality (all other factors being

equal) as vehicles covered by increasingly stringent standards are

introduced and replace higher emitting cars.  Full turnover of the

vehicle population requires about ten years.  Therefore, although

significant emission reductions from motor vehicles may have already

been achieved, the statutorily mandated new motor vehicle emission
*  A summary of these guidelines is provided in Appendix C.

** For background material on the motor vehicle emissions control
   programs of the Agency, the reader is referred to the report
   Progress in the Implementation pjf Motor Vehicle Emission Standards
   June 1975"TU.S. EPA, Publication EPA 230/1-76-001; U. S. Government
   Printing Office, 1976) which provides a good summary description of
   the activities carried out for the control of motor vehicles and
   presents the status of programs implemented to that date.
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reductions in CO and HC emissions  impact  only  minimally  on  the ability
to meet ambient air quality objectives  prior  to  the  1985-90 period  in
the areas not currently attaining  standards.

     Growth of both the vehicle population  and vehicle  use, deterioration
of emission control systems on vehicles in  use,  the  slow turnover  of
the vehicle population, and changes  in  the  date  by which automobiles  are
to meet statutory emission standards greatly  reduce the impact  of the
motor vehicle standards.   However, it is  also  clear  that the FMVCP will
have a significant impact on the achievement  and maintenance of  the
NAAQS in most areas of the country.   In addition, in keeping with  the
strategy of placing controls on new vehicles,  more  stringent controls
for heavy duty and medium duty vehicles,  and controls for motorcyles
are being developed; these controls will  further reduce the future air
pollution impact of these sources.

     Available data indicate that many  in-use motor  vehicles do  not
meet emission standards.   It is clear that  if in-use motor vehicles
met the emissions standards for CO through  their useful  life, the
problems related to CO air pollution would  be solved relatively  soon
through the operation of the Federal Motor  Vehicle Pollution Control
Program.  The failure of in-use vehicles to perform in a way that  is
consistent with the intent of the emission  standards appears to  be
due primarily to a lack of proper maintenance; surveillance testing
of vehicles that were tuned-up prior to the emission test has shown
that tuned-up vehicles have mean emissions  that do comply with applicable
                                 - 57 .

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emission standards,  whereas vehicles that were tested in their as-is
condition typically  had mean emissions that exceeded some of the
standards.   Other factors affecting emissions performance are deterior-
ation of the vehicles'  emission control  systems,  real-world conditions
that are not properly accounted for by the Federal  standards and the
associated testing and compliance programs, and tampering with emission
control systems.  Recent data on 1975 model year in-use vehicles
indicate that CO emissions from such cars are in many instances sub-
stantially higher than had been anticipated.  Similar problems have been
encountered with 1976 model year vehicles.  The cause for such high CO
emissions has yet to be fully determined, but preliminary analysis
suggests that a major factor in these high emissions involves maladjustment-
whether accidental or purposeful—of idle mixtures and choke settings.
Such problems are amenable to correction by State programs (i.e., by
inspection and maintenance and anti-tampering programs, and mechanic
training).  EPA expects that with the implementation of assembly-line
testing, an expanded recall program, the promulgation during the latter
part of calendar year 1977 of short-tests that (in conjunction with
inspection and maintenance programs) can trigger the warranty provisions
of Section 207(b) of the Clean Air Act, and the eventual implementation
of I/M programs, problems of maladjustment or tampering with vehicles
will be reduced sharply, and the expected degree of emission control
will be achieved in actual use.  (It should be noted that  in-use
performance of emissions controls for HC and  NOY is not significantly
                                               /\
different from that expected.)


                                 - 58 -  •

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     The Agency's strategy for motor vehicles  emissions  control  is
to place the burden for compliance with emissions  limitations,  throughout
the useful  life of the vehicle, on the manufacturers  rather than the
owners of the vehicles.  The Agency considers  this the most effective
point of control.  To this end, EPA is assessing the  reasons for in-use
vehicle failure to meet emissions standards and will  develop appropriate
corrective measures.   As an initial step in this direction, EPA has
requested the manufacturers to correct deficiencies in the maintenance
procedures followed by the service organizations in the  country and to
improve the manufacturers' recommended procedures  for maintenance.
EPA intends to concentrate more thoroughly on  reviewing  the appropriate-
ness of manufacturers' maintenance instructions and intends to issue
maintenance regulations which define guidelines for acceptable maintenance.
The Agency also intends to expand its recall efforts  to  encourage
manufacturers to produce complying vehicles and through  this enforcement
tool to foster greater maintainability of in-use cars.  If warranted,
EPA will set appropriate regulations and additional requirements under
the certification process for prototype vehicles to correct deficiencies.
It is expected that these actions will result in a much improved service
industry capability for maintaining in-use vehicles according to
manufacturers' specifications and, by improving vehicle design, will  greatly
increase the potential of vehicles for meeting emissions standards while
in actual consumer use.
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     Although actions aimed at the manufacturers are expected to
result in future improvements in newer model  year vehicles  insofar
as in-use emissions performance is concerned, the totality  of the
vehicle population will not be impacted by the actions taken at the
manufacturer level until approximately the early 1980's when new model
years (incorporating emissions control features which reflect the need
for in-use emissions performance that is improved over that currently
experienced) start to replace the existing vehicle population.   In
addition, the Agency has no authority (except in the anti-tampering
area) to take action for improving emissions  performance for vehicles
beyond 5 years or 50,000 miles since the Clean Air Act defines  useful
life at these levels.  However, typical vehicles last approximately
10 years or 100,000 miles.  Only in-use control strategies  are effec-
tive for the control of vehicle emissions from vehicles that are more
than 5 years old or have accumulated more than 50,000 miles.

     It will only be in the late 1980's, at the earliest, that there
will be a significant  impact from the Federal certification efforts at
improving in-use vehicle emissions performance.  Additional action that
can be taken to improve emission performance of the vehicles that will
be on the roads up to  that time will be in the area of improvements
in the maintenance of  vehicles, recall of vehicles, and anti-tampering
activities.  In this regard, State and local  programs for improving
maintenance of vehicles, including their inspection and mandatory
maintenance if the inspection  is failed, have a significant role to  play.
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     Reducing emissions from in-use vehicles can be achieved  by two
types of actions:  (1) Reductions in emissions by improved maintenance
or vehicle modification (e.g., recall  fixes or retrofitting)  for
achieving emission reductions from individual  vehicles beyond those
achieved by the Federal (or California, for that State) standards for
new vehicles applicable to the specific model  year, and (2) reductions
in total motor vehicle emissions by reducing the use, or vehicle miles
traveled (VMT)*, of all vehicles.  VMT reduction measures, in general,
require changes in established patterns with respect to use of privately
owned passenger cars.  Technological approaches to reductions in
emissions from individual  vehicles require no changes in vehicle use.

     Given the present and projected status of attainment of the NAAQS
with currently implementable new vehicle control strategies, the need
for the imposition of additional transportation control measures exists.
Some means of lowering VMT below current levels (and, for CO, reducing
congestion) will have to be 1n effect in some AQCRs indefinitely.  CO
air pollution can be effectively reduced by the lessening of congestion
and other actions aimed at vehicle use related factors in addition to
inspection and maintenance,since CO is essentially a  "hot spot" problem
related to concentrations of motor vehicles  generally traveling at
speeds that are  lower than average urban speeds.   It  is expected that
*  VMT reductions are an alternative total emissions control measure
   in addition to Individual vehicle emission reductions, since total
   emissions are also a function of vehicle use as well as vehicle
   emissions.
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States will  address the non-vehicle emissions  factors  that affect CO air
quality through the Metropolitan Planning Organizations  (MPO)  and
transportation system planning processes.  It  is  EPA's policy  that  new
and revised transportation strategies be developed by  transportation
agencies, 1n coordination with air pollution control agencies, through
the normal urban transportation planning process.   It  is expected  that
the SIP revisions will Incorporate improved transportation  plans  that
take Into account the air quality Impact of transportation-related
sources.

               c.   Motor Vehicle Emissions Inspection and
                    Maintenance
     Motor vehicle inspection and maintenance  (I/M) is a program of
periodic vehicle emissions inspection-  and the mandatory performance of
maintenance for those vehicles found to emit excessive amounts of a
pollutant.*  In a given metropolitan area with an inspection/maintenance
program in effect, the latest estimates  indicate that the vehicle fleet,
on the average, will emit up to 50 percent fewer pollutants over several
years than would be the case without such a program.  Initial  reductions
of 24 and 37 percent are possible for HC and CO  respectively.  Depending
on the particular mix of stationary and  mobile sources in an area,
Inspection/maintenance can obtain at least 6 to 18
*  The amount found to be excessive is determined by the locality or
   State carrying out the program.  Emissions pass/fail points vary
   with the model year of the vehicle; this is to take into account
   the variations in the standards which the vehicles were built to
   meet.
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percent of the needed hydrocarbon  reduction  and  20  to  40  percent  of
the needed carbon monoxide reductions.*

     Although I/M has not been widely implemented,  largely due to
doubts as to its benefits and inconvenience  it may  cause  the public,
the implementation of programs to  date indicates their feasibility
and illustrates their financially  self-supporting capability.   For
example, in Arizona a franchised contractor  operates the  program for
the State  without State funds being utilized in program  operation.
In Arizona, as well as other areas, costs are recovered through inspec-
tion fees.

     Given the need for achieving emission reductions of  both CO and HC
from in-use vehicles, I/M is the highest priority program for control
of motor vehicle emissions under the SIPs.  EPA considers this measure
to be  implementable and effective in reducing motor vehicle emissions
and is proceeding with actions aimed at facilitating their implementation--
mechanics1 training is being supported; warranties for properly maintained
and used vehicles are to be  implemented; and additional technical support
data are being developed.
*  By serving as a check to insure that vehicles are maintained properly
   throughout their lifetime, an inspection/maintenance program
   contributes to the goal of reducing fuel consumption by motor
   vehicles.  The fuel savings to vehicles which are repaired  in order
   to pass  the inspection check can be significant—fuel consumption
   can  be reduced by 4 to 10 percent on these cars.
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               d.    Control  of Stationary  Sources

     Essentially no  problems are presented by  stationary  sources  of
CO.   However,  large  amounts  of hydrocarbons and  other  photochemically
reactive substances  are emitted to  the atmosphere  as a result  of
evaporation resulting from the storage, handling,  use  and transpotation
of hydrocarbon-containing substances  as well as  from the  chemical
industry.   Controls  available for these emissions  vary.   Storage  vessels
can be constructed and operated in  a  fashion such  that emissions  are
minimized and  that economic  benefits  are accrued;  an example of this
type of control is the use of floating roofs on  tanks  used for storage
of petroleum and petroleum products—net savings occur by keeping
valuable products from evaporating.   (New  source performance standards
for storage vessels  require the use of floating  roofs.)
     Certain sources of organic substances, such as solvents (used for
dry cleaning and in  paints), can be controlled by using substitutes
if they are available.  Substitution of materials is  based on the concept
of reactivity, i.e., certain types  of organic  substances  tend to more
readily participate  in photochemical  reactions than do other types.
Control is based on  substituting the less  reactive organics for those
judged to be more reactive.   (This  approach has  been  extensively used
in the Los Angeles area.)  However, more recent understanding of the
organics1 role in photochemical reactions   (i.e., all  organic substances
react photochemically if given sufficient time)  indicates that the
substitution of one type of organic substance for another on the basis
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of reactivity considerations cannot be considered  as  a  long-term
control strategy for oxidants control.  The replacement of organic
substances with other substance, e.g., water based paints, is an
effective long-term strategy for reducing HC emissions.  EPA will  not
allow credit in the SIP control strategy for substitution of less
reactive organics for those considered to be more reactive.

     The amount of control achievable by the foregoing techniques  is
generally not sufficient to assure attainment of the NAAQS.  Additional,
more effective controls must be implemented.  These controls are
generally the recovery or capture of  the gases and their  incineration
or recovery for additional use.  Current issues related to these means
of control are the energy consumption aspects of some of  these systems
(i.e., incineration, with net energy  losses and the use of scarce
natural gas supplies) and the technical feasibility of the control of
evaporative emissions from the  refueling of motor vehicles.  (It  should
be noted that process losses and transportation or transfer  losses can
also be minimized by the use of equipment and proper housekeeping
procedures.)
     One of the most significant control requirements  currently in
effect for the control of HC from  stationary sources are  those applicable
to gasoline marketing.  Gasoline vapor  control regulations  require the
control of evaporative hydrocarbons  emissions during the  storage,
transport, and dispensing of gasoline.  Uncontrolled emissions from
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these operations account for about six percent of HC emissions in a
typical AQCR, divided equally among terminal operations, gasoline
delivery to service station storage tanks, and refueling of automobiles.*

     Significant emissions reductions and fuel saving are ascribable
to vapor recovery controls.  Uncontrolled emissions from vehicle
refueling are approximately equal to th.e hydrocarbons that will be
emitted from the tailpipes of vehicles meeting statutory Federal
standards.  Controls on gasoline marketing operations will generally
capture about 11 percent of the needed reductions of hydrocarbons in
an urban area and may, in certain cases, capture as much as 20 percent
of the needed reductions.

     The control of evaporative emissions when gasoline is delivered
to storage tanks at service stations is being implemented since
available technology is simple and clearly capable of providing the
requisite control.  Likewise, control of terminal operations presents
no technical issues.  Issues related to control of evaporative emissions
during refueling of automobiles are the imprecise definition of control
requirements, lack of control equipment that has been adequately demon-
strated in actual use, the absence of test and certification procedures,
and the general risks (technical and financial) to be assumed  by service
station owners or operators.  Technical issues are being resolved--EPA
*  In the EPA regulations, these controls are referred to as Stage I
   (for delivery to service station) and Stage II (for refueling
   of automobiles).
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has reproposed the Stage II  regulations  for additional  public  review
of the issues.  It is EPA's  policy to require earlier application  of
control  measures by the larger gasoline  marketers since they are
generally better able to assume the risks  associated with the instal-
lation of control  equipment  that is not  yet fully proven in actual use.

     D.    Attainment/Maintenance of Standards in Problem Areas
          and New Sources Control
          1.    Introduction

     Practically all major urbanized or  industrialized areas of the
country are not meeting one  or more of the NAAQS.  Although there  have
been significant improvements in air quality both in terms of reduc-
tions in ambient concentrations of the pollutants and in terms of  the
number of times that the standards are exceeded, it is expected that
the violations of the NAAQS  will continue in the future.  The principal
issues currently related to  air pollution control are those associated
with the attainment of the standards and    how to assure overall
reduction in  total emissions  (and, eventually, attaining NAAQS), while
at the same time allowing for necessary  growth of industry, commerce,
and services  associated with  population  increases (e.g., housing,
schools, entertainment facilities, transportation).

     The Agency has focused planning for the future maintenance of
standards on  selected areas that will most likely require  long-term
planning, the Air Quality Maintenance Areas  (AQMA).  The planning
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that focuses on AQMA,  however,  will  not  solve  the  current attainment
problems.   Most growth will  occur  in areas  currently above  the
standards—the issue is one  related  to growth  in areas  that have yet to
attain the standards,  not one of growth  in  areas that may have  to be
concerned  with future air pollution  problems.   Growth must  be handled  in
the context of attainment of the standards.  As far as  air  pollution
impact is  concerned, growth  considerations  are limited  to consideration
of the impact on ambient air quality of  changes in emissions  from
sources (e.g., new sources,  changes  in fuel  use or industrial processes,
increased  production or capacity of  existing sources, and increased
motor vehicle use or congestion).

     Air quality standards attainment issues often require  complex,
long-term solutions.  The air quality planning process  provides the
tools to address these long-term problems.   The solution  to such
problems as growth in emissions involves tradeoffs that cannot  always  be
adequately assessed on a case-by-case basis and must  be viewed  within
the larger framework of community  goals.  The  support of the  community
is necessary to implement complex  control  strategies.   Many controls
require a long lead time for development and implementation.   All  of
this requires a systematic planning  process.
     EPA's policy is to address long-term problems,  or  plan revisions
that may have  wide-ranging  effects  on a community (be  they related to
attainment or maintenance),  through  the  process specified in  regulations
stating the criteria for the revision of SIPs  for the maintenance of
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standards.   Any required plan revision (including  revisions  for
attainment) can be developed using this process.

     EPA's aim is the development of an air quality management process
which would more explicitly establish the relationship among all  air
quality related requirements.  This would be aimed at making trade-offs
at the State and local levels, with citizen participation, among  the
various means of achieving the standards.  EPA has established a  flexible
process for SIP revision so that State and community participation is
assured and to permit the integration of all other planning requirements,
such as 208 area-wide waste treatment management,  coastal zone management,
and transportation planning.

          2.   Development of a Comprehensive Planning and
               Decision-Making Process

     For areas that  have attainment problems, SIP revisions are generally
required,and difficult choices as to new sources have to be made.  For
areas that have no significant attainment problems, actions will  have
to be taken to avoid future emission increases that would violate
standards.  After existing sources have  reduced their emissions to the
lowest practical level, further air pollution control can only be
accomplished by implementing rational planning procedures for management
of all new sources of air pollution.  This will require extensive
cooperation among the air pollution control community--regional, state,
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and local  planning agencies;  state and  local  governments;  and  the
general public—in order to  ensure that  future growth  plans include
appropriate air quality considerations.

     In addition, it should be noted that case-by-case review  of new
sources as to air quality impact usually cannot  adequately provide  for
maintenance of the standards—such reviews alone would tend to ignore
the cumulative impact on air quality of the sources which  may  be
individually approved,and would not provide for  consideration  of the
small individual (but,  in the aggregate, significant) contribution  of
the types of sources that would not be  subject to individual  review.
Furthermore, a source-by-source review  procedure allocates the air
resource on a first-come, first-served  basis.  For example, the first
source to receive approval  may preclude the later approval of  all other
sources in the future since the first source may have emissions suffi-
cient to approach the NAAQS in a way that would  preclude approval for
any additional sources.  A more rational allocation of the air resource
requires more than a source-by-source decision making process.
     The nature and magnitude of the restrictions necessary to implement
the provisions of the Act requiring maintenance of standards will  vary
with the nature of the specific issue addressed, but determination  of
the nature of land use and an assessment of the air pollution impact
of a variety of types of human activity are required.  The maintenance
of standards on a regional  basis is to be achieved by the development
and implementation of air quality maintenance plans for specific air
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quality maintenance areas  (AQMAs)  as  a  minimum.   Plans must be developed
for other areas with identified maintenance  problems  as well.*

     The planning process  requires a  preliminary  analysis  of work  that
may be required to be carried out  for plan development and, on  the basis
of this preliminary analysis, an agreement between  states  and EPA  regional
offices as to the timing of plan revisions.   Issues that  States  and
localities will have to resolve during the planning for attainment and
maintenance of standards are related  to (1)  the development and  implementation
of a planning process that will lead  to the  identification and  incorporation
of all relevant factors affecting  ambient air quality,  and (2)  the
extent to which emission reductions can be adopted  and  implemented once
identified.  It is clear that a comprehensive air quality plan  should
incorporate consideration of all social and  economic aspects  of the
affected areas.  Rational  control  choices have to be made by  the affected
communities.   It is EPA's policy to assure as widespread  as  possible
participation  in this decision-making process.

     The success of air quality planning depends not only on  the ability
to control emissions but also on the ability to guide development in
ways that will minimize the deterioration in specific areas  and the
expected long-term growth in emissions.  Location decisions  for
*   An "Air Quality Maintenance Area" is a sub-regional geographic area
    in which the maintenance of NAAQS is deemed to warrant special attention.
    When an AQMA is established, one or more pollutants are designated as
    having the potential of being in future violation of NAAQS.  A
    regional-scale analysis of such potential violations is then carried out.
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major pollution sources such as power plants and industries must be
checked carefully for their air quality effects; existing regulations
are aimed at doing this.  More difficult to take into account, however,
are decisions on such matters as housing, sewer and water systems, and
so on.  Thus, to be effective in the long run,  air quality planning
must be a factor in decisions on land use, resource development, trans-
portation, housing, and commercial  and industrial  development.

     The Metropolitan Planning Organizations (or similar organizations),
acting in coordination with air pollution control  agencies, should have
the principal responsibility for developing the transportation measures
needed to achieve the ambient air quality standards.  This activity
should take place as part of the normal urban transoortation planning
process and should be oriented toward developing transnortation plans
and programs that are consistent with air quality requirements and other
community objectives.  Ideally, the transportation plans and programs
developed through the urban transportation planning process should be
adequate for inclusion in SIP's with no other transportation control
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measures required.*


          3.    EPA's Formal  Planning Requirements


     Regulations pertaining  to the analysis and development of plans

for Air Quality Maintenance  Areas (AQMA's)  were promulgated on May 3,  1976.**

The regulations specify the  procedures to be used  in estimating future

air quality concentrations and for developing any  new control  strategies

necessary to ensure the maintenance of the national  ambient air quality

standards.  They specify the approvable form and content of the analysis
*  On September 17, 1975, DOT issued the Transportation Improvement
   Program regulations which govern the planning and programming of
   Federally sponsored urban transportation improvements (40 FR 42979).
   The most significant air pollution control  aspects of the DOT regula-
   tion are the requirements for the preparation of a Transportation
   System Management (TSM) plan and a-short-range Transportation
   Improvement Program (TIP).  The TSM plan is oriented toward making
   efficient use of existing transportation resources and providing
   for the movement of people in an efficient manner.  It involves
   traffic engineering, public transportation, regulatory , pricing,
   management, and operational improvements to the existing urban
   transportation system,not including new transportation facilities
   or major changes in existing facilities.  Examples of TSM measures
   are traffic flow improvements, preferential treatment of buses,
   parking management, pricing policies, and auto-free zones.  The
   TIP is a staged 3- to 5-year program of transportation improvement
   projects recommended for advancement during the program period.
   The TIP identifies priorities and includes estimates of program
   costs and revenues for the program period.   In effect, the TIP is
   a plan for transportation improvements over a 3- to 5-year period.
   The TSM plan and TIP are developed by the Metropolitan Planning
   Organization (MPO) in each urban area.  The MPO provides a forum
   for cooperative decision-making by principal elected officials of
   general purpose local governments.

** Federal Register, May 3, 1976, pages 18382 to 18391.  These regula-
   tions modify key parts of Part 51 regulations and add a Subpart D,
   Maintenance of National Standards, to Part 51.  Part 51 regulations
   set forth EPA's criteria for development and approval of SIPs.
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and plan revisions required in AOMAs and other areas identified by
EPA.  Although the procedures are aimed at the planning for maintenance
of standards, they are generally applicable to air quality planning.
At the Regional  Administrator's discretion, these procedures can be
applied to other areas in need of implementation plan revisions for
attainment and maintenance.

     Briefly, the process for developing a maintenance plan consists
of the following tasks:  Projecting emissions into the future;
allocating emissions according to estimated projections of location of
sources; calculating air quality resulting from the future emission
pattern; developing a control strategy needed to maintain the national
ambient air quality standards; and adopting regulations to make the
control strategy enforceable.

     The regulations leave in the hands of the States the choice of
measures that are needed to maintain the national air duality standards.
EPA's policy is to be flexible with regard to these plans to allow
maximum consideration of varying local conditions.  EPA will call for
plan revisions for maintenance whenever their need is determined on a
case-by-case basis.  The time period for which maintenance is to be
insured will also vary from area to area.  The date by which such plan
revisions are to be submitted will be determined by EPA in consulta-
tion with States.  EPA requires a reanalysis of all areas of all States
at least every five years to determine if any areas are in need of
plan revisions.

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     The regulations require States  to  analyze air  nualit.y  for  20
years.   EPA Regional  Administrators,  however, have the  authority  to
shorten the analysis period to no less  than  10 years.  Where  long-ranee
data are unreliable, the Regional Administrators  can set a  shorter
period (at least three years) for the  period over which  a plan  must
demonstrate maintenance of the NAAOS.   The analysis beyond  10 years
is designed to foster awareness of existing  State land use  and  trans-
portation plans that extend beyond 10  years, so that the State  can
consider the air quality implications  of these other plans.   Additionally,
the regulations limit EPA's discretion  on actinci  on State reauests for
modification:  The Administrator must  act within  45 days of receipt of
the request, or the request will be deemed automatically approved.

          4.   New Stationary Sources'Review and  Control
               a.    Introduction
     A key element in the control  of increases in emissions is reviewing
the air pollution impact of new sources (or modifications of existing
sources) prior to the time a commitment to construct or modify is made.
Conceptually, the aim of new source review is to assure that the proposed
source's impact on air quality does not interfere with the attainment
or maintenance of the NAAOS or other ambient air Quality goal (e.g.,
the prevention of significant deterioration of air quality).*  New
*  Of course, new sources also have to comply with all other emission
   limitations, such as New Source Performance Standards or hazardous
   pollutant emission standards.  New source reviews can also be
   carried out to verify compliance with these emission limitations.
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sources have basically two options  under  a  new  source  review  process.
They can either meet emissions  limitations  that are  consistent  with  the
air quality goals that are applicable to  the  proposed  location  of  the
source (sometimes derived during the review process),  or  they can  select
an alternative site where air quality is  not  a  problem or control  needs
are less.  In order to consider decisions on  new sources  in  their  proper
social and economic as well as  air  quality  context,  EPA's policy.is  one
of encouraging the development of appropriate decision-making processes
at the State and local level.  The  policies for developing comprehensive
plans were discussed above.  Policy decisions on new sources  in nonattainment
areas are discussed below.

     State  Implementation Plans are required  by 40 CFR 51.18 to contain
procedures for preconstruction review of  new  sources to assure  that  such
sources will not cause violations of the  ambient standards or any
applicable control strategy.  Most SIPs have  approved State procedures
(and State responsibility for action), while  a  few have provisions
promulgated by EPA (and EPA is responsible for  carrying out new source
review).*  Specific decisions on individual sources  may require much
technical analysis and the commitment of  significant resources  to  comply
with emission limitations.
*  New source reviews are generally administered through a permit system.
   Under such systems, a source applies for permission to construct
   or operate; the permit application generally includes data on the
   facility, its air quality impact, etc.  The procedural outcome of a
   review, then, is the approval or disapproval of permission to operate
   or construct the facility.
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     In general,  the  first  determination  that must be made for a new
source review is  whether or not the  source  is covered by an applicable
emission requirement  and, if so,  if  it meets  the limitation of that
requirement.   In  those cases where the proposed  new source will not meet
the applicable emission requirements,  a permit to construct must be
denied.

     If the appropriate emission limitations will be met, an air quality
impact analysis is required for major  sources.   If  the  air quality
impact analysis indicates that the source's emissions will not  lead  to
the violation of  the  NAAQS  or contribute to it,  a permit  to construct  is
issued.  However, this presents a difficult situation for  those areas  of
the country where NAAQS are currently  exceeded.  Arguably, no new source
should be permitted in these areas since any  increase in  emissions could
aggravate air quality problems.

               b.   New Sources in Nonattainment Areas--
                    "Emissions Offset" 'Policy
     It is EPA's  policy to allow the location  of major  new and  expanded
sources in areas  where NAAQS are currently exceeded only  to  the extent
that the resulting emissions do not  exacerbate  current  violations  of the
primary standards and do not interfere with making  reasonable  progress
toward the timely attainment of the  standards.

     EPA's policy, based on its conclusions as  to  the most flexible  yet
rational interpretation of  the Clean Air Act's  requirements,  has  been
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documented In an Interpretative Ruling.*  This  ruling  addresses  the
issue of whether and to what extent national  air quality  standards
established under the Clean Air Act may restrict or  prohibit  growth  of
major new or expanded stationary air pollution  sources.   The  ruling
provides in general  that a major new source may locate in an  area with
air quality worse than a national standard only if stringent  conditions
can be met.   These  conditions  are designed to  insure  that the  new
source's emissions will be controlled to the greatest  degree  possible;
that more than equivalent offsetting emission reductions  ("emission
offsets") will be obtained from existing sources;  and  that there will be
progress toward achievement of  the standards.  The reader is  referred to
the ruling itself for its specific provisions.   While  the ruling is
effective now, EPA is actively  soliciting public comment  on the ruling's
basic policies and detailed provisions.  (EPA also intends to modify the
Part 51 regulations, specifying SIP requirements,  in keeping  with  this
ruling.)

               c.   Prevention  of Significant Deterioration
                    of Air Quality
     The Clean Air Act requires the prevention  of significant deteriora-
tion of air quality  in currently clean areas.  EPA has promulgated
regulations which implement this requirement of the  Act.   (Final regulations
were promulgated on  December 5, 1974.)  EPA's requirements are  implemented
*  This ruling was published in the December 21, 1976 Federal  Register,
   pages 55524 to 55528.  This ruling interprets the way in which the
   requirements of 40 CFR 51.18 are to be implemented.
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through a new source review procedure.   In developing its implementing
regulations, EPA had to decide  what  degree of  air quality deterioration
would be considered "significant"  since  there  has been no specific
judicial or Congressional  guidance.   In  areas  having very clean air,  it
was not possible to set standards  based  on any measurements  of damage to
the public health and welfare.   On the other hand,  it was the intent  of
the law to prevent air quality  everywhere  from being uniformly degraded
through a "leveling out" of the Nation's air pollution.  The EPA  regulations
seek to define "significant" in a  reasonable way  that will  allow  for
protection of clean areas and for  national economic growth.  Any  growth
that occurs will be with the application of  best  available  control
technology.

     For purpose of implementation,  the  country will ultimately be
divided into three types of areas:

     Class  I—regions where practically  any  air quality  deterioration
would be considered significant.

     Class  II--regions where deterioration in  air quality  that  would
normally accompany moderate, well-planned  growth, would  not be  con-
sidered significant.
     Class  Ill—regions where intensive  major industrial growth is
desired.
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     The benchmarks  to be used  in  judging  the  impact of  new sources on
clean areas are increments of ambient  concentrations of  total suspended
particulates and sulfur dioxide.   The  start  for  assessing  source  impact
against these increments was January 1,  1975.  These increments for
areas are:
     Area           TSP  Qug/m3)     	S02 (ug/m3)
Classification*
Class I
Class II
Annual
5
10
24 hr.
10
30
Annual
2
15
24 hr.
5
100
3 hr
25
700
     Issues related to these regulations  concern  industrial  development
and impacts of development in Class III areas  on  surrounding Class  I  or
II areas.  EPA believes that normal,  orderly growth  is  possible  within
the framework of the regulations.   The air pollution limit  for a Class
II area, for example, would (under normal  circumstances)  permit  construction
of any of the major source categories listed below.   In a Class  III
area, an aggregation of major industrial  projects may be constructed  as
long as air quality standards are not exceeded.   (These standards must
be met everywhere even in the absence of  these regulations.)

     The increments for Class II areas were developed taking into
account the impact that they would have on industrial development.   The
Class II increment will permit construction and operation of major,
economically sized industrial facilities.  The increments do place
constraints on control technology requirements and siting considerations.
*  Class  III areas would be allowed to reach the levels of the most
   restrictive NAAQS.
                                 -80   -

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None of the limitations  in  spacing  of  plants would  lead to a general
prohibition on industrial  growth.

     EPA has initially designated all  areas of  the  country as  Class  II.
Under the EPA regulations,  the States  (including  sovereign  Indian
governing bodies) may request redesignation of  an area  to Class  I  or
Class III.  (Managers of Federal  land, however, may request  designation
only from Class II to Class I.)  The redesignation  of an area  may  be
necessary to achieve the social,  economic or  environmental  objectives  of
its population or of the Nation as  a whole.   The  regulations give
the primary decision-making responsibility to the States  to  help them
achieve their various objectives.   The area  reclassification process is
expected to be similar to the process for public  participation for
development of maintenance of NAAQS plans.

     Apart from the reclassification process,  which is  a  planning  and
decision-making process, compliance with the  regulations  is  strictly a
new source review procedure; new sources can  be approved  until the point
that the air quality increments applicable to an  area are  exhausted.  In
case that the air quality increment is exhausted, an area  can be
reclassified if additional growth in emissions is desired.   However, at
no time can the NAAQS be exceeded.
     The prevention of significant deterioration regulations require the
application of BACT for major source categories as  a condition for the
permit  to construct:  Fossil-fuel steam electric plants of more than
1,000 million  B.T.U. per hour heat  input; coal cleaning plants; kraft
                                 -  81  -

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pulp mills;  portland cement plants;  primary zinc  smelters;  iron  and
steel mills; primary aluminum ore reduction plants;  primary copper
smelters; municipal  incinerators capable of burning  more than  250  tons
of refuse per day; sulfuric acid plants; petroleum refineries;  lime
plants; phosphate rock processing plants; by-product coke oven batteries;
sulfur recovery plants; carbon black plants; primary lead smelters;  fuel
conversion plants; and ferroalloy production facilities.

     EPA believes that decisions about development of affected areas
should not be based only on environmental factors.  For this reason, as
long as proper procedures are followed and decisions are not arbitrary
or capricious in light of the relevant factors, State and local  decisions
about whether to reclassify an area to Class I (minor development)  or
Class  III (whatever development the air quality standards will  allow)
will not be questioned.

               d.   Federal New Source Performance Standards
                    (NSPS) for Criteria Pollutants

     The setting of performance standards for new sources is authorized
under  Section 111 of the Act.  NSPS prevent or reduce the magnitude of
increases in emissions from stationary sources resulting from expanded
industrial  activity and/or new or modified  sources, provide a mechanism
by which the Federal Government determines  (and makes available to
States)  the feasibility of control for emerging industries  (i.e.,
defines  BACT), and  provide the only means  for control of stationary
sources  of  selected pollutants  for which a  NAAQS  or hazardous pollutant
designation is  not applicable.
                              - 82 -

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     The setting of NSPS  must  (as  required  by  the Act)  take  into
consideration the costs of achieving  the  emission levels  to  be  required.
Therefore, issues related to the NSPS largely revolve around  the standard-
setting process rather than source compliance  with  emission  limitations.
In general, the courts have upheld the  NSPS challenged  to date.
     As indicated earlier, the prevention of air pollution problems  due
to future growth in hydrocarbon emissions and  nitrogen  oxide emissions
is highly dependent on the controls that  are to be  applied to new
sources of these pollutants.  The problem related to N02  is  currently of
low significance; only five AQCRs are classified as requiring emission
controls.  However, there is a clear danger that increases in emissions
due to expanded economic  activity will  lead to widespread NAAQS violations
by the 1980s unless new sources are controlled.  The current control
philosophy for mobile sources emissions stresses the need for stringent
NOX controls in the 1980s; a complementary program for  the control of
stationary sources is required.  The setting of standards for new
sources now is preferable to the setting  of control requirements  under
the SIP process later in order to prevent the possibility of widespread
NAAQS violations in the future.  The need to prevent increases in
emissions of hydrocarbons for new stationary sources is similar to the
need for  such control of NOX.  NSPS  to be set in the future concentrate
on sources of these pollutants.  The sources covered by NSPS and sources in the
process of, or  under  consideration 'for, being covered are listed in Appendix B.
                              - 83 -

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     Procedural  requirements  applicable  to  sources  covered  by  NSPS are
minimal.  In brief, compliance with emissions  limitations  is  required as
well as compliance with certain self-monitoring requirements.
State* or EPA enforcement of NSPS entails maintaining surveillance over
sources covered, preconstruction review  at  the request of  the  source
owner or operator, observation of source tests and  evaluation  of
results, and enforcement proceedings against sources  found  not to be  in
compliance.  EPA involvement with delegated NSPS entails  the  monitoring
and evaluation of State enforcement progress,  making  determinations  on
how the standards are to be applied, the provision  of technical  advice
and support, and, if needed, direct enforcement action.
*  EPA may delegate to States the enforcement of NSPS.  It is the
   policy to delegate the authority to enforce these standards.to. the
   States whenever States meet requisite criteria, i.e., the State
   submits a plan for enforcement of the NSPS and EPA approves it.
                                -  84 -

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III.  The Control  of  Other Than Criteria Pollutants

     A.    Introduction

     The Clean Air Act  provides  various mechanisms for the control of
pollutants depending on such  factors  as their effects, the types of
sources  that emit them, ^and  the  best  means  of controlling them.  The
preceding discussion dealt with  those pollutants  for which criteria have
been issued and NAAQS set.   This part of  the discussion  outlines the
controls in effect or projected  for pollutants  not controlled  by NAAQS.
For pollutants emitted  from  less widespread sources or a  limited class
of sources, or having limited effects, possible control  mechanisms are
provided by sections 112 (hazardous pollutants), 111(d)  (control of air
pollutants not covered  by  NAAQS and  not  determined to be hazardous
under section 112),  and section  211  (regulation of  fuels, for  control of
pollutants which are emitted as  a result  of having  been  incorporated
into motor vehicle fuels).*

     Pollutants with significant localized  effects  are of concern  to
EPA.  It is EPA's policy to  proceed as expeditiously  as  possible with
control  actions, under  the most  appropriate authorities  of  the Act,
*  Pollutants controlled under these authorities are generally known
   as "noncriteria" pollutants, i.e., not covered by criteria documents
   issued under section 108 of the Act.   Only TSP, S02,  CO,  Ox, ^2>
   and HC are covered by criteria documents.   There are  additional
   authorities related to non-criteria pollutants under  section 119(d)
   (3) (B).  These authorities are limited to prohibition orders
   issued by FEA for the use of coal and are of limited  applicability.
   They are not discussed here.
                             -85  -

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for the control  of those pollutants  which  present  a  significant risk to
health or welfare and those pollutants for which Federal action is the most
effective means  of control.   (It should  be noted  that  there are cases
for which State  action  is appropriate  in the  absence of Federal action;
States are encouraged to utilize their authorities for the control of
air pollutants whenever warranted.)   For those  pollutants for  which
Federal control  action  is appropriate, the philosophy  of the Act  requires
primary Federal  action  for the control of sources  of hazardous air
pollutants, with provisions  for delegation of enforcement responsibilities
to the States.  Furthermore,  the Act requires primary  State action for
the control of existing sources of the pollutants  controlled under
section 111 *(based on  EPA guidance) with a secondary  Federal  role
thereafter, i.e., EPA action is required only upon State failure  to  act.

      If a pollutant is  of such a hazardous nature that immediate  abatement
of emissions is  desired from both existing and  new facilities  (i.e.,  the
Administrator of EPA finds that there .is no applicable ambient air
quality standard and the pollutant,  in the judgement of the Administrator,
causes or contributes to an increase in  mortality or an increase
in serious irreversible, or incapacitating reversible, illness)  then
direct Federal control  under section 112 is indicated.  Under  Section
112,  all new sources are subject to control immediately upon  promulgation
of standards by EPA,and all  existing sources are to be in compliance
within 90 days of the EPA action unless  granted waivers.
   But not controlled by NAAQS or NESHAP,

                                - 86 -

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     Where a non-criteria  pollutant  is  not hazardous  (as that term is
defined by section 112),  i.e.,  it  has a lower potential for impacting
public health,  then section 111  would be the mechanism  for action.
Pollutants emitted by only specific  sources may  be  controlled under  the
provisions of section 111   by the  setting of performance standards for
new sources; if such a standard is set  for a pollutant  not  covered by
criteria and not determined to be  hazardous under section  112,  then
existing sources of the pollutant  are  to be controlled  by  the  States
(or, in the absence of State action, by EPA) subsequent to  the  issuance
of NSPS by EPA.  Under section lll(d),  States  prepare plans  for the
control of existing sources under  a process  similar to the State :
Implementation Plans.

     B.   National Emission Standards  for Hazardous Air Pollutants

     Section 112  of the Clean Air Act requires the Administrator to
establish national emission standards  for hazardous air pollutants.   A
list of such substances (identifying asbestos,beryl 1iurn, and mercury as
hazardous pollutants) was  published in  the Federal Register on
March  31, 1971.   In accordance with waiting periods and public hearing
requirements of the Act,  proposed regulations  for their control were
published in the  Federal  Register on December 7, 1971.  Final  regulations
were promulgated  April 6,  1973.  Clarifying regulations were promulgated
May 3, 1974, October  14,  1975, and March 2, 1977.  Sources and pollutants
covered by  the NESHAP are  listed in Table I.*  EPA also has promulgated
 *  The regulations  are  contained under 40 CFR 61; a detailed explanation
    of the Agency's  positions on the control of asbestos, mercury, and
    beryllium may  be found  in the April 6, 1973, Federal Register,
    38 FR 8820,  et.  seg.
                               - 87 -

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regulations to control  emissions of vinyl  chloride from facilities  that
manufacture both vinyl  chloride monomer and polyvinyl  chloride.*   At
this time benzene and organic compounds emitted from coke ovens are
scheduled to be added to the list of hazardous air pollutants.   In
addition, investigations are currently underway for several  pollutants
to determine the optimum control option for each, which may include
Section 112.

     EPA Regional Offices are maintaining surveillance over sources,
observing source tests and evaluating results, and carrying out
enforcement proceedings against sources found not to be in compliance.
These activities may be carried out by States when they are delegated
enforcement authority, i.e., when they submit an acceptable plan for
carrying out such actions.  It is the Agency's policy to delegate
enforcement authority to States; they are encouraged to develop programs
for enforcing these regulations.
*  The regulations for vinyl chloride were published in the October 21,
   1976, Federal Register (4 FR 46560 et. seq.).
                               - 88 -

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                      Table  I  -  Summary of  NESHAP
Pollutant

Asbestos
                           Applicable to:
                         10/14/75
Beryllium
 4/6/73
Mercury
Vinyl Chloride
 4/6/73


10/14/75

10/21/76
Asbestos mills
Roadway surfacing (asbestos
  tailings)
Manufacturing of products
  containing asbestos (textiles,
  cement, fireproofing and
  insulating materials,
  friction products, paper,
  millboard, felt, floor tile,
  paints,  coatings, caulks,
  adhesives, and sealants)
Chlor-alkali manufacture
Demoli ti on

Manufacture of shotgun shells
  and asphalt concrete
Fabricating
Waste disposal

Extraction plants
Ceramic plants
Foundries
Incinerators
Propellant plants
Machining operations
Rocket motor firing

Ore processing
Chlor-alkali manufacture

Sludge dryers or incinerators

Ethylene dichloride manufacture
  by reaction of oxygen and
  hydrogen chloride with
  ethylene.
Vinyl chloride manufacture
Polymer manufacture via vinyl
  chloride
                                - 89 -

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     C.    Control  of Selected Pollutants

     Section lll(d) of the Act provides a mechanism for the control
of pollutants not covered by criteria (Section 108) or National  Emission
Standards for Hazardous Air Pollutants (Section 112).   The Act provides
that States set up a system for the control  of existing sources  of the
non-criteria pollutants for which EPA sets NSPS.   Sulfuric acid  mist
from sulfuric acid plants and fluorides from primary aluminum reduction
and phosphate fertilizer plants are currently covered by this requirement.

     The criteria to be used for developing State control programs
require a separate rule-making action on the part of EPA.  These
separate State guidelines will specify the levels of emissions control
that are achievable for existing sources and will provide guidance
as to economic factors to be considered by the States in the development
of control plans applicable to existing sources.   States are to  submit
their control plans nine months after EPA promulgation of the guidance
document.

     D.    Lead

     EPA has chosen to control lead as a fuel additive since this is
the most effective means of reducing environmental exposures:  90
percent of lead emissions to the atmosphere come from motor vehicles.
The reduction of lead in gasoline is required under regulations  issued
under the authorities of section 211 of the Clean Air Act.  These
                                  -90  -

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regulations are currently effective,  EPA's  position  having  prevailed
after two years of litigation  initiated  by  fuel  additive manufacturers.
(Another set of regulations  set  under Section  211,  requiring  the
availability of lead-free gasoline for use  in  vehicles  equipped with
catalysts, is  also in effect.)

     Another court case has  resulted  in  an  order requiring  the listing
of lead as one of the air pollutants  for which the  EPA  Administrator
intends to issue criteria and  NAAQS.   EPA will  issue a  criteria document
and proposed NAAQS for lead  during August 1977.

     E.   Arsenic

     Available ambient air quality data  indicate that airborne arsenic
is not a widespread air pollution problem.   However, both  air quality
data and emission estimates  indicate  that substantial amounts of  arsenic
can be emitted during non-ferrous ore smelting operations.   The  need
for emission standards is being  investigated for the several  smelter
sites where a local problem may  exist.  Other sources of arsenic
emissions do not appear to be a  significant problem.
     Because the air quality level and estimated emissions of arsenic
around some non-ferrous smelters appear to be significant, regulatory
action on arsenic may be necessary.  However, the current data base
is not comprehensive enough to support such action.   Studies carried
out by EPA should provide sufficient basis for and background upon

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which to make a decision regarding action on arsenic, with the decision
for control action probably to be made in two years.   In the interim,
EPA will initiate studies to develop control technology information
to be used in the regulation (if warranted) of arsenic emissions from
smelters.

     F.    High Volume Industrial Organic Chemicals (HVIOC)

     Increasingly, the industry viewed as a significant source of toxic
and carcinogenic agents is that  of the rapidly expanding manufacture of
synthetic organic chemicals.  EPA is aiming at widespread control of
many types of organic pollutants through the use of new source performance
standards  (NSPS) under Section 111 of the Act.  Section 111 can be used
to cover most of the organic compounds which have potential adverse
health effects in addition to those organics that contribute to the
oxidant problem, i.e., setting NSPS for these sources will result in
control  for both criteria and non-criteria pollutant emissions.
Significant emission reduction through this mechanism will require many
years, but the growth of the chemical industry is rapid, replacement
of obsolete processes is common, and new source standards represent a
good start for control of emissions.

     There are approximately 11,000 commercial organics currently
marketed with hundreds of new compounds synthesized each year.  An
initial group of these chemicals  has been  selected for assessment as
potential  toxic atmospheric pollutants.  (Table II lists these
                                  -  92 -

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pollutants.)   One of the 22,  benzene,  has  been  identified  as  a
pollutant for which a more detailed  assessment  should  be conducted
in the near future.  It is expected  that  such an  assessment will  be
completed by the end of FY 1977.   An additional group  of substances,
numbering about 700, is under review.

     As a group, these materials  are of concern as  toxic agents,
contributors to oxidant formation, and, some species (freons), as  a
threat to upper atmospheric stability.  Wide ranging information
gathering and engineering activities are  underway in each  of  these  areas.
Emission standards are anticipated for several  industries  where  emissions
contribute significantly to oxidant  formation.  Although EPA  has made
studies to assess the impact of controlling freons, at this  time
evidence does not warrant control for- these chemicals  under  the  Clean
Air Act.
     Recent examples of chemicals causing concern from an  air pollution
standpoint include vinyl chloride and nitrosamines.  Most  of the members
of the class of nitrosamine compounds are documented carcinogens in
animals.  Nitrosamine levels in the  atmosphere  have been  found to be
the result of direct emissions from  a rocket fuel manufacturing  facility
and amine producing plants.  They may also be produced in  the atmos-
phere or in the body by reactions of nitrogen oxides and  certain amine
precursors.  At present and over the near-term, efforts will  be focused
on the  identification of sources of nitrosamines, their precursors,
                                 - 93 -

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     Table II - High Volume Industrial Organic Chemicals
         Being Assessed for Air Pollution Potential
cresols
toluene
ethylene dibromide
trichloroethylene
perchloroethylene
vinylidene chloride
"carbon tetrachloride
nitrobenzene
phthalic anhydride
Maleic anhydride
dimethyl terephthalate
acetylene
acrylonitrile
acetone
cyclohexanone
formaldehyde
methyl methacrylate
oxylene (1,3 dimethyl benzene)
methyl alcohol
adipic acid
ethylene dichloride
benzene
                             -  94 -

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and techniques for control.   Regulatory  action  for vinyl  chloride  was
completed in October 1976.

     Virtually all organic  chemicals also are photochemically reactive,
with some compounds reacting quickly to  form oxidants  while others react
more slowly, thus causing oxidant problems many miles  away.   Many
organic chemicals have the  potential for reacting with other chemicals
in the atmosphere or deteriorating to produce other potentially
dangerous compounds.  There is evidence  that the combination of a  number
of these compounds in the atmosphere may cause synergistic effects or
act as co-carcinogens.

          In the short term, use of NSPS minimizes emission increases of
pollutants which may already be a problem but have not been recognized,
or for which documentation is not sufficient to initiate other
regulatory options.   In the longer term, the use of NSPS should result
in substantial decreases in organic chemical emissions due to the rapid
equipment replacement rate typical of the chemical industry.

     G.   Polycyclic Organic Matter

     Ambient air  concentrations of POM have been decreasing since 1966
as a result of control of smoke and general particulates.
The remaining significant source,  coke ovens, may be controlled by
Federal  regulation  under section  112 of the Act.
                                -  95  -

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     H.    Polychlorinated  Biphenyls  (PCBs)

    "PCBs are primarily a  human  health  problem due  to  their  bioaccumulation
in fish.   Also of significance are the  potential  effects  of  PCBs  on
aquatic food chains.   The  significance  of the air route of direct human
exposure has not yet been  assessed.   These problems associated  with  PCBs
may necessitate the control  of selected sources of  air emissions  (e.g.,
transformer and/or capacitor plants) if current monitoring work confirms
these plants as significant sources  of  PCBs.   Such  action may be
required even with the stringent control  of PCBs  required by the  Toxic
Substances Control Act.

     Municipal incinerators are  also being investigated to determine
their impact as sources of PCBs.  Should these investigations confirm
that they are significant  sources, the  upgrading of control  systems  for
PCBs control will be quite costly and probably justifiable only on the
basis of the control  of a  number of toxic organics, as opposed  to
control of PCBs alone.  These control actions are also dependent  on  the
success or failure of efforts to eliminate PCBs by  substitution.
                                 - 96 -

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     I.    Cadmium

     EPA is concerned over environmental  loading  of  cadmium  via  the
air route; however,  even under the most  pessimistic  assumptions,  it
cannot be concluded  that collective environmental  exposure to all
routes of body entry present a human health problem.   The primary route
of entry of cadmium  to the body is through food ingestion.  A secondary
source is from inhalation of cigarette smoke.   Inhalation of ambient
air represents the least important route of entry to the body and it
would require air concentrations five times those found under worst
case conditions to be of concern to human health.

     J.    Manganese
     Manganese does  not present a human  or environmental health threat
at existing ambient  levels and warrants  no national  regulatory program.
However, EPA will reassess this conclusion if manganese becomes widely
used as a fuel additive.
     K.    Other Trace Metals

     Screening and assessment of other trace metals (chromium, nickel,
selenium, zinc, copper, platinum, vanadium, iron, barium) is underway
both through the National Academy of Sciences and within  EPA.  There
is no evidence to date that would require control action  for any of
these materials at this time.
                                -97  -

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     L.    Odors





     Odors are considered primarily a problem that should be handled



by state and local  authorities.   With the exception of Federal  emission



standards for total reduced sulfur from pulp mills and sulfur recovery



plants,  no national regulatory program for odors is being pursued.
                                  - 98  -

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                              APPENDIX A
                                                       a/
              1.   National  Ambient Air  Quality Standards-
  Pollutant

Particulate
  matter-7
Sulfur
  Dioxide
Carbon
  Monoxide
Photochemical
  oxidants-
Hydrocarbons-
  (nonmethane)

Nitrogen  ,
  Dioxide^
  Averaging
     Time

Annual (Geo-
metric mean)
  24-hour

Annual (Arith-
metic mean)
  24-hour

   3-hour
   8-hour

   1-hour



   1-hour
   3-hour
(6 to 9 a.m.)
Annual (Arith-
metic mean)
 n •     b/
 Primary-'
Standards

 75 ug/m3

260 ug/m3

 80 ug/m3
(0.03 ppm)
365 ug/mj
(0.14 ppm)
 10 mg/m
 (9 ppm)3
 40 mg/m
(35 ppm)
160 ug/nr
(0.08 ppm)

160 ug/m
(0.24 ppm)
•100 ug/m
 (0.05 ppm)
          c/
 Secondary-
 Standards

  60 yg/m

 150 ug/m
                                                            1300
                                                            (0.5 ppm)
Same as
primary
Same as
primary

Same as
primary


Same as
primary
a/  All standards (other than annual  standards) are specified as not to
    be exceeded more than once per year.  The measurement methods are
    also specified as Federal Reference Methods.  The air quality
    standards and a description of the reference methods were published
    on April 30, 1971 in 42 CFR 210,  recodified to 40 CFR 50 on
    November 25, 1972.
b/  Set for the protection of health.
c_/  Set for the protection of welfare, which, in the words of the Act
   "includes, but is not limited to,  effects on soils, water, crops,
    vegetation, manmade materials, animals, wildlife, weather, visibility,
    and climate, damage to and deterioration of property, and hazards
    to transportation, as well as effects on economic values and on
    personal comfort and well being."  (Section 302 (b).)
d_/  The secondary annual standard (60 ug/m ) is a guide to be used in
    assessing implementation plans to achieve the 24-hour secondary standard.
e/  Expressed as ozone by the Federal Reference Method.
f_/  This NAAQS is for use as a guide in devising implementation plans
    to achieve oxidant standards.
g_/  No Federal Reference Method currently in effect.

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             2.   Sources  of  Information on Health  Effects
                   of Air Pollutants
     The following pubications  provide  information  on  the  effects of
air pollutants:

1.    Air Quality Criteria for Particulate  Matter. U. S.  Department  of
     of Health,  Education, and  Welfare,  Public  Health  Service
     Environmental Health Service,  National  Air Pollution  Control
     Administration, Washington,  D.  C.,  January 1969,  Publication
     No. AP-49.

2.    Air Quality Criteria for Sulfur Oxides, U. S.  Department  of Health,
     Education,  and Welfare, Public Health Service, Environmental Health
     Service, National  Air Pollution Control Administration, Washington,
     D. C., Publication No. AP-50.

3.    Effects of Sulfur Oxides in  the Atmosphere on  Vegetation; Revised
     Chapter 5 for Air Quality Criteria for Sulfur  Oxides, National
     Environmental Research Center, Office of Research and Development,
     U. S. Environmental Protection Agency, Research Triangle  Park,
     North Carolina  27711, September 1973, EPA-R3-73-030.

4.    Air Quality Criteria for Carbon Monoxide,  U.  S. Department of
     Health, Education, and Welfare, Public Health  Service, Environmental
     Health Service, National Air Pollution Control Administration,
     Washington, D. C., March 1970, Publication No. AP-62.

5.    Air Quality Criteria for Carbon Monoxide,  NATO Committee  on the
     Challenges of Modern Society,  Air Pollution Technical Information
     Center, Office of Air Programs, Environmental  Protection  Agency,
     Research Triangle Park, North  Carolina  27711, N. 10.

6.    Air Quality Criteria for Photochemical Oxidants,  U. S. Department
     of Health, Education, and Welfare, Public Health  Service,
     Environmental Health Service,  National Air Pollution Control
     Administration, Washington,  D. C., March  1970, Publication No. AP-63.

7.    Air Quality Criteria for Hydrocarbons, U.  S.  Department of
     Health, Education, and Welfare, Public Health Service,
     Environmental Health Service,  National Air Pollution Control
     Administration, Washington,  D. C., March  1970, Publication No. AP-64.
                                 A-2

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3.    Air Quality Criteria  for  Photochemical Oxidants and Related
     Hydrocarbons,  Committee on  the  Challenges of Modern Society,
     North Atlantic Treaty Organization,  Air  Pollution Technical
     Information Center, Office  of Air  and  Water Programs,  Environmental
     Protection Agency,  Research Triangle Park, North Carolina  27711,
     U.S.A.,  N. 29.

9.    Air Quality Criteria  for  Nitrogen  Oxides, Environmental  Protection
     Agency,  Air Pollution Control Office,  Washington, D. C., January
     1971, Publication No.  AP-84.

10.   Air Quality Criteria  for  Nitrogen  Oxides, NATO Committee on  the
     Challenges of  Modern  Society, Air  Pollution Technical  Information
     Center,  Office of Air Programs,  Environmental Protection Agency,
     Research Triangle Park, North Carolina  27711, N. 15.

11.   Automotive Air Pollution  and Human Health:  A Seminar  in Hartford,
     Connecticut, October  1975.  U. S.  Environmental Protection  Agency,
     Air & Hazardous Materia-ls Division,  Region  I, Boston,  Massachusetts,
     October  1975.

12.   The Health Implications of  Photochemical  Oxidant Air Pollution
     to Ypur  Community,  U.  S.  Environmental Protection Agency,
     August 1976.
                                 A-3

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                              APPENDIX  B
              Summary of New Source Performance  Standards
   Date
Effective*

August 17,
  1971
August 17,
  1971
August 17,
  1971
August 17,
  1971

August 17,
  1971

June 11,
  1973

June 11,
  1973
June 11,
  1973
Sources Covered
 Pollutants
 Controlled
Fossil  fuel-fired  S02,  NOX &
steam generators   particulate
                   matter
Incinerators
Portland cement
plants
Nitric acid
plants

Sulfuric acid
plants

Asphalt concrete
plants

Petroleum
refineries
Storage vessels
for petroleum
liquids
 Particulate
 matter
 Particulate
 matter
NO,
S02, acid
mist
Particulates
carbon monox-
ide and hydro-
gen sulfide
      Affected Facility
Each fossil fuel-fired steam
generating unit of more than
250 million B.T.U. per hour
heat input.

Each incinerator of more
than 50 tons per day
charging rate.

Kiln, clinker cooler, raw
mill system, finish mill
system, raw mill dryer, raw
material storage, clinker
storage, finished product
conveyor transfer points,
bagging and bulk loading and
unloading systems.

Each nitric acid production
unit.

Each sulfuric acid
production unit.
Particulates    Process equipment.
Catalyst regenerators
fluid catalytic cracking
units, process gas burners
Hydrocarbons    Entire facility
   The effective date for NSPS is that of proposal  in the Federal
   Register.  All affected sources that are being or have been modified
   or construction started as of this date must comply with the standards.
   Definitions of applicability of standards are contained in 40 CFR 60.

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                            NSPS
(Continued)
Date
Effective
June 11 ,
1973
June 11 ,
1973
Sources Covered
Secondary lead
smelters
Secondary brass
and bronze and
Pollutants
Controlled
Particulates
Particulates
Affected
Furnaces
Furnaces
Facility


June 11,
  1973

June 11,
  1973

October 21,
  1974

October 22,
  1974

October 23,
  1974

October 21,
  1974
October 24,
  1974

October 16,
  1974
ingot production
plants

Iron and steel
plants
Particulates
Sewage treatment   Particulates
plants
Electric arc
furnaces
Particulates
Phosphate fertil-  Fluorides
izer  plants

Primary aluminum   Fluorides
plants
Ferroalloy
production
 Particulates
and CO
Coal preparation   Particulates
plants

Non-ferrous        Particulates,
smelters: copper,  S02
zinc, and lead
Basic oxygen process
furnaces

Sludge incinerators
 Electric submerged arc
furnaces and dust
handling equipment
                             B-2

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Currently in process for NSPS-setting are the following:

     Source Category                                 Pollutant
Lignite steam generators
Grain terminals
Kraft pulp mills
Coal/refuse boilers
Coke ovens - charging
Sulfur recovery at refineries
Gas turbines
Chior-alkali
Crushed stone plants
Degreasing
Phosphate rock preparation
Carbon black
Iron & steel sintering
Gasification of fossil fuel
Stationary internal combustion engines
Lime plants
Coke ovens-pushing
Grey iron-electric arc furnaces
Asphalt roofing
Sulfur recovery at oil fields
NO , Part.
Particulates
Part., odors*
Particulates
Particulates
SOX and Particulates
SOX NOX, HC, Part.
Mercury
Particulates
HC
Particulates
HC, Part. CO
Particulates, SOX
Particulates, SOX
NOX, HC, Particulates
Particulates
Particulates, HC
Particulates
Particulates, HC
SOv
Under consideration for action are:

     Source Category

Boilers (3 sizes)
Taconite 'beneficiation
Wood waste boilers
Motor vehicle surface coating
Coal liguefaction
Ethylene oxide manufacturing
Explosives
Charcoal manufacture
Farm machinery surface coating
Industrial machinery surface coating
    Pollutant
NOY, particulates
HC
Particulates, SO?
HC
NOX, SOX, particulates
HC
HC
HC
   TRS, or total reduced sulfur, is to be controlled.
                                 B-3

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(Continuation)
     Source Category                                 Pollutant

Commercial machinery surface coating             HC
Major appliances surface coating                 HC
Dry cleaning                                     HC
Foundries-steel                                  Particulates
Auto body incineration                           Particulates, HC
Cast iron boundry (Coke Ovens)                   Particulates, HC
Coke ovens-pushing operations                    Particulates, HC
Nylon acetate fibers                             HC
Industrial/commerical incinerators               HC, Particulates
Plywood manufacture                              HC, Particulates
Shale oil processing                             $03, HC, TRS
                                 B-4

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                              APPENDIX  C
                Determination of Best Available Control
        Technology and Reasonably Available Control  Technology

A.   Best Available Control  Technology

     BACT is defined in 40CFR  §52.01 (f)  as follows:

     The term "best available control technology,"  as  applied to any
affected facility subject to New Source Performance Standards,  means any
emission control device or technique which is capable  of limiting
emissions to the levels proposed or promulgated as  NSPS.  Where no
standards of performance has been proposed or promulgated for a source
or portion thereof, best available control technology  is determined on a
case-by-case basis considering the following:

     (1)  The process, fuels, and raw materials available and to be
          employed in the facility involved;

     (2)  The engineering aspects of the application of various types of
          control techniques which have been adequately demonstrated;

     (3)  Process and fuel changes;

     (4)  The respective costs of the application of all such control
          techniques, process changes,  alternative fuels, etc.;
     (5)  Any applicable State and local  emission limitations; and

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     (6)  Locational  and siting considerations.*

This definition is applicable to all  EPA regulatory actions related to
SIPs, specifically in relation to the use of tall  stacks for new
facilities and the prevention of significant deterioration of air
quality.

B.   Reasonably Available Control Technology

     1.   General

     BACT may not always be applicable to sources, especially existing
ones that require retrofitting under SIPs.  For these cases, the Agency
requires the application of RACT.  At the present time, the concept
of RACT is important in regard to:
        Determining whether existing SIP  regulations are
        "adequate" or not.
      .  Determining whether a given overall control strategy represents
        the most  comprehensive and aggressive control program that  is
        reasonably practicable.  This determination will  be  important
        as states develop and  EPA reviews  (or promulgates)  SIP  revisions
        in the actions  scheduled for the  period July  1976 to July  1978.
        When all  RACT  is applied, other measures  are  required to demon-
        strate attainment.   If all RACT  is  not  applied  by a  state,  EPA
*   40  CFR  52.01
                                  C-2

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        would require the state to do so or will  promulgate  its



        own regulations.





     .   Determining when  SCS or a tall  stack may  be used to  prevent



        violations of NAAQS by existing sources.





     The concept of RACT  was involved in the SIPs developed  in late



1971 and early 1972.  It  served as a basis for determining whether a



State could be granted an 18-month extension of the date when plans to



attain the secondary standards were to be submitted.   If control



measures more stringent than those defined as RACT were needed to attain



secondary standards, an extension could be granted.  To assist in



creating an understanding of what RACT meant, a series of examples of



emission limitations attainable by various source classes with RACT



was prepared and was incorporated as Appendix B of 40 CFR 51.  Appendix B



was also used as one input in determining whether a two-year extension



of the primary standards  attainment date would be granted.  If control



technology needed to attain was not available soon enough to permit



implementation in three years, an extension could be granted.





     EPA is engaged in a  number of projects to provide additional



guidance and reference publications which will be useful in  determining



what RACT means in a wide variety of situations, and in making use of



such information in conducting various air pollution control operations.



These documents will be used in development of SIP revisions in the
                                 C-3

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July 1976 - 1978 time period.   Specifically,  the  guides*  for  use  in
preparation of SIPs  for several  pollutants  make reference to  the  various
publications that can be used  to acquire information  on  RACT.   EPA
expects these guides to be used as basic manuals  (or  references)  in  the
SIP preparation process.  They address policy, conceptual,  and  technical
matters.

     2.   Specific Application of the RACT  Concept

          a.   As an Aid in Defining BACT

     The definition of BACT is based on either the applicable NSPS  or
(when no NSPS is applicable) a case-by-case determination
(taking into account the factors listed under the BACT definition).
When no NSPS is applicable, the availability of  information as  to what
RACT is will provide a presumptive ceiling  of emissions  which could not
be exceeded and still qualify as BACT and,  in most cases, will  provide
assistance  in determining how much lower than RACT the BACT limit might
be.

     The Agency has already developed specific criteria applicable to
determinations of RACT  for sources wishing to use tall stacks and/or
*  These guides document policy statements, technical information and
   guidance on control strategies relating to NOx, TSP, and oxidants.
   They include a discussion of the Agency's concept of RACT, describe
   procedural methods for determining RACT, and reference appropriate
   detailed guidance.  It should be emphasized that much material is
   currently available on defining RACT.  Support documents for emissions
   standards (NSPS and NESHAP) provide valuable reference documents
   for reaching a definition of RACT.
                               C-4

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SCS, and in relation to the application of certain measures  for oxidants
and carbon monoxide controls.   These policies are discussed  below.

          b.   RACT Coupled with Tall  Stacks and/or SCS*

     In given instances, the technology envisioned by the BACT concept
may be available in a state-of-the-art sense; however, its retrofit onto a
specific existing source may be extremely onerous for economic reasons
or ill-advised for engineering or siting reasons.   It is expected that
such instances will occur only in the cases of a few smelters and some
power plants.

     Where these circumstances do occur, particularly where  a source is
threatened with shutdown, the Agency believes that administrative relief
can be considered.  Accordingly, where a source demonstrates to the
State (and the State thereafter demonstrates to EPA) that, as applied to
the source, BACT is economically unreasonable or technologically
unsound, EPA will approve a control strategy demonstration which, for
that source, is based upon reasonably available (as opposed  to best
available) control technology coupled with unlimited stack height.
However, such a control strategy will  only be approved as a  temporary
measure for attaining and maintaining ambient air quality standards and
is  conditioned according to the tall stack and SCS policies.

     For this purpose, RACT is not necessarily equivalent to the
40  CFR 51, Appendix B definition; RACT becomes a factor only after it
*Extracted from EPA's Stack Height Increase Guideline, 41 F.R. 7450
(February 18, 1976).
                             C-5

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has been determined,  on a  case-by-case  basis,  that  retrofit of BACT
on the existing source would  be unreasonable.   This requires  that  RACT
be determined by considering  the processes,  fuels,  and  raw materials
to be employed; the engineering aspects of the application of various
types of control techniques,  process and fuel  changes;  the cost  of
employing the available techniques;  and the cost of certain control
techniques due to plant location, configuration, basic  process  design
and expected remaining life.

     Remaining life and capacity are major factors  determining  the
reasonableness of an FGD installation for existing  coal-fired power
plants.  For these plants, the following should be  considered in
determining reasonableness:

     (i)  Plant Life:  If a plant has ten to fifteen years  remaining
life or less, and is projected to operate at an annual  average  of no
more than 25 percent capacity, F^D installation might be considered
unreasonable.  In such instances, the source owner  should provide the
anticipated shutdown date, and that date must be included in the
compliance schedule.
     (ii) Space Limitations:   FGD may be unreasonable due to space
limitations.
                                 C-6

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     In the event that it is  determined  on  a  case-by-case  basis  that
FRD is not reasonable for a  specific  power  plant,  alternate  control
measures must still  be considered.  The  use of low sulfur  coal and
coal washing, either separately or  in combination,  might be  appropriate
options and acceptable in meeting RACT criteria.   The  capital  as well  as
operating costs of applying  these control  techniques are to  be taken
into account in making the case-by-case  determination  and, when  the
cost of using low sulfur coal is not  significantly less than the cost
of FRD, coal washing alone might be considered RACT.*  Only  after
application of whatever measures are  determined to be  RACT would the
source be able to take any credit for stack height increase.
     In the case of existing smelters, BACT will,  in most  cases, be
economically unreasonable and could,  in  some  cases, result in  shutdown.
Under such circumstances, RACT will usually eouate to  control  of all
strong gas streams through pronerly operated  and maintained  double
contact acid plants (or single contact acid plants where single  acid
plants are already on line).   Hhere increased acid olant capacity is
required to treat presently untreated strong  gas streams,  RACT for
such gas streams must be double acid  plants.

     Since RACT involves a decision that is based  principally upon
economic and engineering considerations, the  definition of RACT
*  The circumstances under which the use of low sulfur coal  would be
   deemed to be unreasonable are expected to be extremely rare.   EPA
   analyses indicate that low sulfur coal supplies are sufficient to
   accommodate demand.
                                 C-7

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should be subject to future re-evaluation  to  determine  if more  effective
control measures would be applicable.
C.   Reasonably Available Control  Measures for CO and Ox
     EPA's guidelines for the development  of  control  measures  aimed at
hydrocarbon and carbon monoxide sources* provide guidance  as to
"reasonably available" control measures in terms of the stage of SIP
development and the severity of the air pollution problem.   Reasonably
available measures are:
     Source Control Measures
  i)  Inspection/Maintenance
 ii)  Vapor Controls for Organic
      Solvents
iii)  Petroleum Refinery,
      Chemical Plant and Other
      Industry Controls
 iv)  Vapor Controls for Gasoline
      Marketing
  v)  HDV Retrofits
     Transportation Measures
  i)   Transit Improvement
 ii)   Employer Incentives

iii)   Parking Management/
      Restrictions

 iv)   Traffic Management/
      Restraints
Every one of these control measures is considered reasonably available
and should be  included  in SIP revisions where necessary for attainment.
*   Policies for  the  Inclusion of Carbon Monoxide and Oxidant Controls
    in State Implementation  Plans (TCP Policy Paper), Office of Trans-
    portation and Land Use Policy, Office of Air and Waste Management,
    Environmental Protection Agency, December 1975.
                                 C-8

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However, the most cost-effective mix of measures  must  be  locally
detennined.    The policies governing the application of control
measures are:

          Policy for changing existing transportation  and
          stationary sources measures included in Oxidant
          and Carbon Monoxide Control Strategies  of SIPs:
     EPA's policy is that revisions should be made to  the existing
transportation and stationary source control  measures  for Ox and  CO
in SIPs only if, on the basis of valid technical  analysis, the measures
are found not to reduce pollutant emissions.   In  this  case, changes
should be made.  If states develop measures that  are  eaual or better in
effectiveness, in terms of reducing emissions, than are the reasonably
available measures EPA promulgated, then such substitute  measures should
be adopted.   (If standards cannot be attained by  using the reasonably
available source control measures promulgated by  EPA,  new State measures
may supplement, but not replace, the EPA promulgated  measures.)*

          Policy for transportation measures  being revised
          pursuant to court orders or for new transportation
          measures now being developed for addition to SIPs:
     States are expected to adopt all reasonably  available transportation
control measures.
*  Gasoline rationing and catalytic retrofits for light-duty vehicles
   (included in some SIPs) are not considered reasonably available measures
                                 C-9

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          Policy for inclusion  of  transportation measures
          for non-attainment areas  for  which  calls  for  SIP
          revisions  are issued:

     Reasonably available measures  should  be  identified,and  the  State
is to submit the required measures.
          Policy for areas where transportation measures
          are included in SIPs  and  where standards  will
          be attained by Clean  Air  Act  deadlines:

     Some areas to which transportation measures  apply  are  not designated
air quality maintenance areas.   However, SIP  revisions  may  be needed
for standards maintenance.  Needed SIP  revisions  should be  determined
through the analyses required for maintenance revisions.
                                 C-10

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                              APPENDIX  D
           Summary  of  States  Issued  Calls  for  SIP  Revisions
                July 1,  1976,  and  Pollutants for Which
                      Plan  Revisions Are  Required
                                               POLLUTANTS*
                                    TSP
S02
                                     x
                                     x
CO
0>
X
X
X
X

X

X X
XXX
XXX
X
X X
   State

Alabama
Alaska
Arizona
Arkansas
California
Colorado
Connecticut
Delaware
District of Columbia
Florida
Georgia
Hawaii
Idaho
111inois
Indiana
Iowa
Kansas
Kentucky
*  Where an "x" is shown, EPA has asked the State to revise its
   implementation plan for that pollutant for at least one area.
                                                           x
                                                           x
N02

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                                              POLLUTANTS*
                                   TSP      SO?     CO     Ox     N02
Louisiana                           x
Maine                               x               x
Maryland                            x               x
Massachusetts                       x        x      x
Michigan
Minnesota
Mississippi
Missouri                            x        x
Montana                             x        x
Nebraska                            x
Navada                                              x
New Hampshire                       x               x
New Jersey                          x        x      x
New Mexico                          x        x      x
New York                            x        x      x
North Carolina                                      x
North Dakota
Ohio                                                x
Oklahoma
Oregon                              x               x
Pennsylvania                        x        x      x
Rhode  Island                        x        x      x
South Carolina                      x
 *  Where  an  "x"  is  shown,  EPA  has  asked  the  State  to  revise  its
   implementation plan  for that  pollutant  for  at least  one area.
                                  D-2

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                                              POLLUTANTS'*
   State                           TSP     S02     CO      Ox     N02
South Dakota                        x

Tennessee                           x                     x

Texas                               x

Utah                                x

Vermont                                             x     x

Virginia                                            x     x

Washington

West Virginia                       x                     x

Wisconsin                                                 x

Wyoming                             x

American Samoa

Guam

Puerto Rico                         x       x

Virgin Islands
*  Where an "x" is shown, EPA has asked the State to revise  its
   implementation plan for that pollutant for at least one area.
                                 D-3

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                              APPENDIX E
             List of Abbreviations,  Symbols,  and Acronyms
AQCRs
AQMA
AQMP
BACT
BOAs
CFP
CO
DOT
EPA
FEA
FGD
FMVCP
FRM
FY
GVW
gm/m
HC
HQ
MPO
NMQS
NESHAP
Air Quality Control Regions
Air Quality Maintenance Area
Air Quality Maintenance Plan
Best Available Control Technology
Basic Ordering Agreements
Clean Fuels Policy
Carbon monoxide
(U.S.) Department of Transportation
(U.S.) Environmental Protection Agency
Federal Energy Administration
Flue gas desulfurization
Federal Motor Vehicle Control Program
Federal Reference Method
Fiscal year
Gross vehicle weight
Grams per mile
Hydrocarbons
Headquarters  (EPA)
Metropolitan  Planning Organization
National Ambient Air Quality Standard
National Emission  Standards for Hazardous
  Air Pollutants

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NOX                           Nitrogen oxides
N02                           Nitrogen dioxide
NSPS                          New Source Performance Standards
Ox                            Total  oxidants
RACT                          Reasonably Available Control  Technology
SCS                           Supplementary Control  Systems
SIPs                          State  Implementation Plans
SMSA                          Standard Metropolitan  Statistical  Area
SOX                           Sulfur oxides
S02                           Sulfur dioxide
TCPs                          Transportation Control Plans
TIP                           Transportation Improvement Program
TRS                           Total  reduced sulfur
TSM                           Transportation System Management
TSP                           Total  suspended particulates
VMT                           Vehicle miles travelled
                              Micrograms per cubic meter
                                 E-2

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