PROGRESS tHe
PREVENTION*
CONTROL AIR
POLLUTION in 1974
   Report to Congress
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY • 4TH & MSTREET SOUTH WEST

       WASHINGTON, D.C. 20460

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   PROGRESS IN THE PREVENTION AND
      CONTROL OF AIR POLLUTION
               IN 1974
           ANNUAL REPORT
              OF THE
ADMINISTRATOR OF THE ENVIRONMENTAL
         PROTECTION AGENCY
                 TO


  THE CONGRESS OF THE UNITED STATES
           IN COMPLIANCE WITH
      THE CLEAN AIR ACT AS AMENDED

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                                Table of  Contents

     Chapter                                                         Page
     Preface .............................  v
  I.  Introduction  ..........................  1
 II.  Progress and Problems  Associated with Control of
     Mobile Source Emissions  and the Research  Efforts
     Related Thereto   ................... ......  5
     -  Measures  Taken  to  Implement Mandated Title  II
       Emission  Standards  ......................  5
     -  Transportation  Control  Plans   .................  12
     -  Additional Activities  in the Mobile Source  Area    .......  ..
                                                                       16
     -  Mobile Source Research and Development   ............
                                                                       26
III.  The Development of Air Quality Criteria and Recommended
     Emission Control  Requirements    .................
     -  National  Ambient Air Quality Standards   ............  32
     -  National  Emission  Standards  for  Hazardous Air
       Pollutants (NESHAPS) ......................  33
     -  New Source Performance Standards  (NSPS),  section 111 -
       Clean Air Act .........................  ™
     -  Health Effects  Research   ...................  ,o
 IV.  The Status  of Enforcement Actions  Taken Pursuant  to this  Act.  .  .  ^
     -  Stationary Source  Enforcement  .................  41
     -  Mobile Source Enforcement
                                                                       53
  V.  The Status of State Implementation Plans Approvals,
     Disapprovals, and Promulgations,   and Progress  Towards
     Attainment of National  Standards   ................  61

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      Chapter                                                        Page
      - Attainment of National  Ambient Air  Quality  Standards  	  63
      - Issues Affecting Development  and  Implementation of
        State Implementation Plans  	  67
  VI.  Status of Air Monitoring  and  Trends in Air  Quality  	  79
      - Air Quality Trends:  1970 -  1973	81
      - Monitoring Strategy  and Methods   	  85
 VII.  The Development of New and Improved Air  Pollution
      Control Techniques 	  97
      - Stationary Source Air Pollution Control   	  97
VIII.  The Development of Instrumentation  to Monitor Emissions  and
      Air Quality	103
      - Monitoring Development  	  104
      - Quality Control   	  105
  IX.  Standards Set or Under Consideration  Pursuant to Title  II  of this
      Act	107
   X.  The Status of State, Interstate, and  Local  Pollution  Control
      Programs Established Pursuant To and  Associated By  This  Act   .  .  113
      - Federal Financial Assistance to Air Pollution Control
        Agencies	114
      - Progress of State and Local Air Pollution Control Programs . .  114
      Appendix - Summary of EPA's Stationary  Source Air  Enforcement
        Actions   	123
                                           ii

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                             TABLES
                                                                   Page
Table 1    -Major Air Pollution Control  Regulations and
              Standards Issued During 1974	       2

Table 2    -Existing Emissions Standards	       7

Table 3    -Emissions Standards for Heavy-Duty Gasoline and
              Diesel Engines	       8

Table 4    -Areas Requiring Transportation Control Plans	      15


Table 5    -Status of Standards of Performance	      36

Tables    -Mobile Source Enforcement Actions 	     60


Table 7    -Status of State Implementation Plans, Summary	      62

Table 8    -National Summary of Air Monitoring Stations Reporting
              1973 Data To the National  Aerometric Data Bank,
              June 1974	       87

Table 9    -National Summary of AQCR Status Versus Particulate
              Standards, 1973	       88

Table 10   -National Summary of AQCR Status Versus Sulfur Dioxide
              Standards, 1973	       89

Table 11   -National Summary of AQCR Versus Carbon Monoxide
              Standards, 1973	       90

Table 12   -National Summary of AQCR Status Versus the Oxidant
              Standard, 1973	       91

Table 13   -Growth in Number of Monitoring Instruments, 1970-1974    92

Table 14   -Summary of Grant Awards to State and Local Air Pollu-
              tion Control Agencies, by State	      ''5

Table 15   -Personnel Employed by State and Local Air Pollution
              Control Agencies	
                                   m

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                          Table of Figures
                                                                Page
Figure 1      -National  and Regional  Trends in Total
                Suspended Particulates, 1970-1973	 93

Figure 2     -National  and Regional  Trends in Sulfur
                Dioxide, 1970-1973	 94

Figure 3     -Composite Averages of Second High Annual  1-hour
                Oxidant Values for Areas Within
                Cal ifornia	 95

Figure 4     -Annual  Average Percent of Values Above the 8-hour
                Carbon  Monoxide Standard for Selected Areas,
                1970-1973	 96

Figure 5     -Comparison of Actual and Needed State  and Local
                Air  Pollution Control  Program Manpower	 ^2^

Figure 6      -Comparison of Actual and Needed State  and Local
                Air  Pollution Control  Program Funds	  122
                                  IV

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                              PREFACE


     The Clean Air Act, as amended,  authorizes  a  national  program  of

air pollution research, regulation,  and enforcement activities.  This

program is directed at the Federal  level  by the U.  S.  Environmental

Protection Agency (EPA).  However,  primary responsibility  for the  prevention

and control of air pollution at its  source rests  with  State and  local

governments.  EPA's role is to conduct research and development  programs,

set national goals (via standards and regulations), provide technical  and

financial  assistance to the States,  and,  where  necessary,  supplement  State

implementation and enforcement programs.

     Section 313 of the Clean Air Act requires  the  Administrator to

report yearly on measures taken toward implementing the purpose  and intent

of the Act.  Section 313 reads as follows:

          "Not later than six months after the  effective
          date of this section and not later than January
          10 of each calendar year beginning after such date,
          the Administrator shall report to the Congress on
          measures taken toward implementing the purpose and
          intent of this Act including, but not limited to,
          (1) the progress and problems associated  with
          control of automotive exhaust emissions and  the
          research efforts related thereto; (2) the develop-
          ment of air quality criteria and recommended emission
          control requirements; (3)  the status  of enforcement
          actions taken pursuant to  this Act; (4) the  status
          of State ambient air standards setting, including
          such plans for implementation and enforcement as
          have been developed; (5) the extent of development
          and expansion of air pollution monitoring systems;
          (6) progress and problems  related to  development
          of new and improved control techniques; (7)  the
          development of quantitative and qualitative  in-
          strumentation to monitor emissions and air quality;

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          (8) standards set or under consideration pursuant
          to title II of this Act; (9) the status of State,
          interstate, and local  pollution control programs
          established pursuant to and assisted by this Act;
          and (10) the reports and recommendations made by
          the President's Air Quality Advisory Board."
This report covers the period January 1  to December 31, 1974, and describes

the major elements of progress toward the prevention and control of air

pollution that have been made by EPA since the last report.
                                  vi

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                      I.   INTRODUCTION AND SUMMARY


     This report reviews  the progress that the  U.S.  Environmental

Protection Agency (EPA) has made during the year 1974  in  the control  and

prevention of air pollution.  It follows the order of  topics listed  in

Section 313 of the Clean  Air Act, except that additional  measures  of progress

have been added where appropriate.

     The major events which took place during 1974 are briefly summarized

here, and discussed more  fully in the text of the report.  Table 1,  which

follows, lists the major  regulations and standards to  control air pollution

which were issued by EPA  during 1974.

          o  Passage of the Energy Supply and Environmental Coordination
             Act, which:

             -  set a new deadline of 1977 for interim auto-
                mobile emissions standards for hydrocarbons and
                carbon monoxide, with the possibility for a 1-year
                extension.

             -  calls for a review of each State Implementation Plan
                to determine whether revisions can be made to alleviate
                the shortages of clean fuels without interfering with
                attainment of NAAQS.

          o  Identification of 34 areas requiring transportation
             controls, and review of air quality data  to  determine
             whether additional areas will need these  controls.

          o  Initiation of alternative automotive fuels feasibility program

          o  Review of National Ambient Air Quality Standards (NAAQS) by
           .  the National Academy of Sciences, which supported the standards
             and the bases on which they were set.

          0  Revisions and amendments proposed to the National Emissions
             Standards for Hazardous Pollutants asbestos and mercury.

          o  Promulgation of New Source Performance Standards for seven
             source categories, and proposal of standards for eight
             additional categories.

          o  Submission of EPA's final response to the remand of the NSPS
             petition for review in Portland vs Ruckelsh«ust on November
             5, 1974.                                    *

                                     1

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ro
                                                       Table 1
                        Major Air Pollution Control Regulations and Standards Issued During 1974
Subject
National Emission Standards for Hazardous Pollutant
-Clarifying Amendment
-Increased Applicability
New Source Performance Standard (Group II)
New Source Performance Standard (Group II-A)
New Source Performance Standard (Group III)
New Source Performance Standard - general regulations
Regulations for the Prevention of Significant
Deterioration of Air Quality
Indirect Source Regulations
Emission Standards for Supersonic Aircraft
Date
Published
in Federal
Register

May 3, 1974
Oct. 25, 1974
March 8, 1974
Oct. 16, 1974
October, 1974
Sept/Oct, 1974
Dec. 5, 1974
Feb. 25, 1974
July 22, 1974
Status

Final
Proposed
Final
Proposed
Proposed
Proposed
Final
Final
Proposed
Discussed
in Chapter

III
III
III
III
III
III
V
V
II

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   Proposal  under New Source Performance Standards  of general
   regulations concerning the definition of modifications  for
   NSPS application, procedures for submission of State plans
   for non-criteria pollutants, and use of continuous emission
   monitors.

   Initiation of 271 enforcement actions against stationary
   sources.
o  Proposal of 188 potential  problem areas for maintenance
   of air quality, with final  designation of these areas
   scheduled for early in 1975.

o  Promulgation of the area classification plan for prevention
   of significant deterioration  of air quality, with a request
   to Congress to further review this issue.

o  Promulgation of regulations requiring States to develop
   procedures to assess the air  quality impact of indirect
   sources, later suspended until July 1, 1975.

o  Discovery of data from CO and Ox monitors in Priority III
   AQCR's showing values exceeding the national ambient air
   quality standards for these two pollutants.

o  Monitoring which shows average concentrations of TSP and SOg
   on a predominant downward trend in the nation as a whole.

o  Techniques for detection of vinyl chloride developed as a
   laboratory prototype.

o  Promulgation of regulations for control of emissions from
   diesel powered, light-duty trucks.

o  Issuance of an Advance  Notice of Proposed Rulemaking to
   control emissions from new motorcycles.

o  Publication of an Advance Notice of Proposed Rulemaking for
   conversion of standards for motor-vehicle hydrocarbon exhaust
   emissions to a non-methane basis.

o  Promulgation of regulations requiring certification of new
   vehicles offered for sale in high altitude regions.

o  Proposal of emissions standards for supersonic aircraft.

o  Increase of EPA support of State and local control agencies
   from $50.5 million in Fiscal  Year 1973 to $51.5 in Fiscal
   Year 1974.

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Increase of State and local control agency personnel  from
6195 in Fiscal Year 1973 to 7236 in Fiscal Year 1974.

Increase of State and local control agency funding by 13%
and manpower by 15% from 1973 to 1974.

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II.  THE PROGRESS AND PROBLEMS ASSOCIATED WITH CONTROL OF MOBILE SOURCE
     EMISSIONS AND THE RESEARCH EFFORTS RELATED THERETO
      Title II of the Clean Air Act mandated at least 90 percent reductions
in carbon monoxide (CO), hydrocarbons (HC), and oxides of nitrogen (NOX)
emissions from light-duty vehicles and engines, and gave the Administrator
authority to prescribe certain other emission standards for automobiles,
trucks, and planes.
         MEASURES TAKEN TO IMPLEMENT MANDATED TITLE II EMISSION STANDARDS
Suspension of HC and CO Emission Standards for 1975 Model Year Autos
     In 1972, EPA denied the requests of five manufacturers for 1-year
suspension of the nationwide statutory 1975 automobile emission standards
for HC and CO.  As a result of a decision by the U.S. Court of Appeals for
the District of Columbia Circuit, EPA in 1973 was required to reconsider
its earlier decision.  Following extensive public  hearings, EPA on April 11.
1973,     suspended the statutory 1975 HC and CO emission standards until
1976 and established a set of interim standards for 1975.  A more restrictive
set of interim standards was established for vehicles sold In California than
for vehicles sold in the rest of the country.  The California standards were
designed to require the use of catalyst systems on automobiles sold in that
State.  Suspension of the nationwide standards was intended to avoid economic
        t
difficulties involved in forcing catalyst technology on all 1975 domestic
vehicles, while the State of California adopted standards which provide for
a gradual phasing-in of catalyst technology prior to 1976.  However, many manu-
facturers have opted to use catalysts on most of their "non-California"  1975
vehicles, due to the fuel  economy advantage that catalysts offer.

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 Suspension of NOx Emission Standard for 1976 Model Year Light-Duty Vehicles
 On July 30, 1973, after 9 days of public hearings, the Administrator granted
 Ford Motor Company, General Motors Corporation, and Chrysler Corporation a
 suspension of the effective date of the statutory 1976 NOx emission standard
 for light-duty vehicles for 1 year as allowed by Section 202(b)(5)(D) of the
 Clean Air Act.
      The Administrator established an interim standard of 2.0 grams per
 mile.  The suspended standard was 0.4 grams per mile.
 Extension of Deadlines for Statutory Emission Standards by the Environmental
 Supply and Energy Coordination Act of 1974 -- With the passage of Energy
 Supply and Environmental Coordination Act of 1974, the status of the interim
 standards changed and new deadlines were set for achievement of the standards,
 corresponding to the 90% reductions mandated by the Clean Air Act of 1970.
 The new Act provides that those statutory standards for HC and CO (originally
 to be met by the 1975 model year) are now to be met by the 1977 model year with
 the possibility of an additional 1-year extension.  The Clean Air Act statutory
 standards for NOx (originally to be met by the 1976 model year) are now to be
met by the 1978 model year.  Current standards reflecting the Energy Act
 provisions and EPA promulgations are summarized in Tables 2 and 3.
Certification Testing
      Certification of new passenger cars for compliance with Federal
 emission  standards began with 1968 model year vehicles.  The program in-
cludes testing prototype vehicles which represent all new motor vehicles
sold in the United States.  The manufacturer is required to submit data
showing that prototypes conform to Federal  standards for exhaust, crank-
case, and fuel evaporative emissions.  EPA carries  Out a review of the
manufacturer's data and performs conformatory tests on selected prototypes.

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                                                          TABLE   2

                                              EXISTING EMISSIONS STANDARDS
                                             1975
1976
1977-
1978
TYPE OF VEHICLE
uignc-duty gasoline
passenger vehicle
Light~duty diesel .
passenger vehicle
Light-duty gasoline
truck
Light-duty diesel
truck (proposed)
(National)
(California)
(National )
(California)
(National;
(California)
(National )
HC CO
NOx
HC
CO
NOx
HC CO NOx
HC CO NCfc:
(emissions expressed as grams per mile)
1.5 15
.9 9
:.5 15
.9 9
>.0 20
>.0 20

3.1
2.0
3.1
2.0
3.1
2.0

1.5
.9
1.5
.9
2.0
.9
2.0
15
9
15
9
20
17
20
3.1
2.0
3.1
2.0
3.1
2.0
3.1
0.41 3.4 2.0
0.41 3.4 2.0
2.0 20 3.1
2.0 20 3.1
0.41 3.4 0.4
0,41 3.4 0.4


-'   NOTE:   The 1977 emission standards for hydrocarbons and carbon monoxide are listed in this table.
           The guidelines for determination of a 1 year suspension of HC and CO are found in House  Report 93-1013 (pages 23-25).

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                            TABLE  3


                     EMISSIONS STANDARPS FOR
            HEAVY-DUTY GASOLINE AND DIESEL ENGINES


                                                         (a)
                                 1975 and 1976 Model years
                                 (grams/brake horespower/hour)

                                           (b)
Type of Engine                     HC and NOx	CO
Heavy-duty
Gasoline engine
Heavy-duty
Diesel engine
(National)
(California)
(National)
(California)
16
10
16
10
40
30
40
30
a)  Standards for 1977 and 1978 have not been set.

b)  Standards apply to the combined emission of hydrocarbon and
   nitrogen oxides.
                              8

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      During the past year, certification of most 1975 model year  light-
duty vehicles and heavy-duty engines was completed*  and certification
of 1976 models is now underway.   The certification program for the 1975
model year involved monitoring the test programs of approximately  60
manufacturers, and reviewing durability data from approximately 450 vehicles
and engines, and emission data from 700 vehicles and engines.   These figures
represent an increase over the previous model year of 100% for durability
checks and 42% for emissions checks.  To reach this level  of certification,
EPA conducted approximately 2,500 planned emissions tests, or an increase
of 100% over the previous year.   The increase resulted primarily from
California's adoption of a separate set of emission standards which most
manufacturers met by producing a different vehicle to be marketed only in
California*
      As a result of the unauthorized and unreported maintenance practices
by Ford Motor Company on 1973 certification vehicles, EPA has expanded its
certification program to increase surveillance of domestic manufacturers'
testing programs.  EPA Inspectors now perform periodic checks of manufacturers'
facilities and records to  Insure that established test procedures were
followed, and investigate  reports of possible violations of regulations.  In-
depth inspections of major manufacturers' programs are made annually.
      In addition to the requirements for certification of motor vehicles
and engines prior to mass  production, EPA has regulations governing changes
to vehicles and engines during mass production and during introduction of
new models.  Approximately 850 requests  for  such changes during this past
calendar year were reviewed and more than 200 tests were conducted  to determine
compliance with standards.

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      Since the 1971 model year, emission test results have been published
in the Federal Register.  Beginning with the 1973 model year, the fuel
consumption during the emission test has also been determined and published
in the Federal Register, as well as in a booklet for consumer use.  Fuel
economy information was presented to car buyers by manufacturers participating
in the EPA/FEA sponsored fuel economy labeling program.  The driving cycle
used in that emission test is representative of typical city driving common
to urban commuting.  To provide the consumer with additional fuel economy
information, a highway fuel economy test procedure was developed early this
year for testing 1975 and later model year vehicles.  EPA will be able to
provide emission test results and a broad picture of fuel economy test results
for consumers who are concerned with both air quality and fuel economy.
Assessment of Mobile Source Technology
      More than 70 percent of all 1975 model cars are expected to be equipped
with catalysts, a considerably larger number than  EPA's earlier expectations.
The 49-State interim standards for the 1975 model year (excluding California)
permit manufacturers to choose between catalyst and noncatalyst systems.  The
greater than expected use of catalysts for the 1975 model year results from
the fuel  economy advantage they offer0  A problem recently discovered - sulfate
emissions from catalysts - is discussed on page 21.
      The sales-weighted fuel economy of the 1975 model year fleet, assuming the
same model mix in 1974 and 1975, is 13.5 percent better than the 1974 fleet
according to EPA certification data.  In addition to catalysts changes in
carburetion, lower axle ratios, and electronic ignition systems will contribute
to improved fuel economy.
                                   10

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    In meeting past emission standards, most manufacturers used the
same basic approach of engine modification (i.e., spark retard, intake
manifold preheating and faster acting chokes) and exhaust  gas recircula-
tion.  The 1975 models are utilizing a greater variety of control
approaches.  Saab, for example, is using fuel injection and no catalyst
to meet both the Federal and California interim standards.  Mazda  is
using a thermal reactor.  Honda will use its  compound vortex controlled
combustion (CVCC) stratified charge engine to meet the California  interim
standards.
    EPA's technical staff have analyzed extensive information provided
by automobile manufacturers under the provisions of Section 202(b)(4)
concerning their progress toward meeting the Federal emission standards.
The paragraphs which follow represent the collect! ve judgement of EPA
engineers directly responsible for the interpretation and analysis of
the information.
    It is expected that manufacturers will not need to drop many,  if
any, of the line of vehicles offered in the 1975 model year in order
to meet the 0.41 grams/mile HC, 3.4 grams/mile CO, and 2.0 grams/mile
NOY standards required by Congress for the 1977 model year.  Fuel
  4\
economy at these levels will depend heavily on the advances made beyond
the systems designed to meet the 1975 California interim standards.  If
manufacturers do nothing but add spark retard to their California systems,
there will be significant losses of fuel economy on 1977 models relative
to 1975 models.  If manufacturers are willing to increase the costs of
emission control systems, such techniques as improved catalyst formulation
and configuration, improved quick-heat manifolds, and improved exhaust
                                11

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 gas  redrculation  can be  used  to make the average fuel economy of
 1977 models  as  good or better  than  that of 1975 models.
     Automobile  industry research to meet the Clean Air Act statutory
 levels was drastically reduced during 1973 due to the uncertainty of
 the  need to  meet a 0.40 grams/mile  NOx standard.  The primary obstacle
 to meeting the  standard with reducing catalysts or single bed oxidation-
 reduction catalysts appears to be the lack of an advanced fuel metering
 system and advanced hydrocarbon control techniques.  The use of an oxidation
 catalyst in  front  of the  reduction  catalyst shows promise of avoiding
 sudden increases in oxygen concentration caused by the lack of precise
 fuel metering.   In general, a  0.40  NOx standard, the present legislative
 target for light-duty passenger vehicles, would be expected to solidify the
 use  of catalytic technology.
                      TRANSPORTATION CONTROL  PLANS
      Some 34 metropolitan areas  in 23 States (including  the District
of Columbia)  are currently required to implement transportation  control
measures, in  addition to  stationary source  emissions  controls  and the
Federal  new car emission  controls,  to attain  ambient  air  quality standards
for CO or photochemical oxidants.   In addition,  the latest air quality
data are  being examined to identify other metropolitan areas in  which
air quality standards  for CO or photochemical  oxidants might be  exceeded.
Initial  review of these data indicates that measures  similar to  transporta-
tion controls may be needed 1n 20 additional areas.   (See  Chapter VI.)
      A number of States  submitted transportation control  plans  for
EPA's approval.   When review of the State plan did  not demonstrate that
                                 12

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air quality standards would be attained,  EPA 0) published notice  to
that effect in the Federal  Register, and  (2) proposed a transportation
control plan.   EPA's proposed plans were  presented at hearings to
permit public participation in the proposed rulemaking.  For those States
that did not prepare and submit transportation control measures, EPA
published in the Federal Register proposed strategies to reduce CO or
HC emissions from motor vehicles.  Public hearings were also held to
consider thes3 proposed transportation control plans.  The promulgation of
EPA-proposed rulemaking in the Federal Register was generally completed
in January of 1974.  Table 4 summarizes the actions EPA has taken to
date on transportation control plans.  It is EPA policy to withdraw its
proposed or promulgated plans as soon as  an approvable State plan is
submitted.  In certain areas, such as Colorado, additional portions of
plans have been submitted and approved since the plan was promulgated
by EPA.
      The transportation control plans have been worked out through
close cooperation between Federal, State, and local officials.  The
following control measures may be used in transportation control plans:
filling storage tanks at service stations; filling auto tanks; loading
and unloading barges; solvent and degreasing operations; architectural
coating operations; operations of dry cleaning establishments; inspection
and maintenance of both light-duty and heavy-duty vehicles; improved
mass transit; improved  traffic flow; bus-car pool lanes; car-pool
matching system; transportation by-pass; parking restrictions; bridge tolls;
                                 13

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 vehicle-free zones; delivery bansj idling and taxi cruise restrictions;
 motorcycle limits; mechanical retrofit by vacuum spark advance dis-
 connect, air bleed, catalyst, high-altitude modifications, and truck
 retrofit; and gasoline limitations.  In the California cities where auto-
 related air pollution is generally considered to be among the worst in
 the Nation,  the transportation controls include most of those listed.  Most
 of the other urban plans contain some combination of these controls, depending
 on the severity of the local air pollution problem.
      Progress has been made in Implementing all these controls, especially
 with Inspection/maintenance programs, bus lanes, employer incentive programs,
 and parking management plans.  The need for these strategies has generated
 a great deal of local activity, particularly in the development of parking
 management plans for five California cities as well as for Portland, Oregon
 and for Seattle, Washington.
      During 1974 court suits Involving transportation control plans in
 Massachusetts, New York, Pennsylvania, and Texas were decided.  Wherever the
 issue was raised,  these upheld EPA's authority to impose transportation
 control-type measures requiring compliance by both private parties and govern-
 mental entities.  In two cases, EPA was required to further validate its data
 base before completing implementation of some features  of the plans. Thes€ technical
 reviews are being completed at this time, and are tending to show the need
 for measurejequal  to or more stringent than those in the original plans.
      EPA has asked Congress for flexibility in working out achievable
 schedules for those cities requiring drastic control measures.  On March 22,
 1974, EPA proposed amendments to the Clean A1r Act 1n order to deal realis-
 tically with specific problems of Inability to achieve the statutory deadline
 for the ambient air quality standards in severe problem areas such as
 Los Angeles.   However,  EPA believes that  all  of the control  techniques are
technically.feasible, and except for severe gasoline limitations, reasonable
for most areas.
                               14

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                                      Table 4
                   Areas Implementing Transportation Control Plans
 1.  Boston, Massachusetts  (E)

 2.  Springfield, Massachusetts  (E)

 3.  New York City, New York  (S)

 4.  Rochester, New York  (S)

 5.  New Jersey Suburbs of N.Y.C.  (E)

 6.  New Jersey Suburbs of Philadelphia (E)

 7.: Philadelphia, Pennsylvania  (S/E)

 8.  Pittsburgh, Pennsylvania  (E)

 9.  Baltimore, Maryland (E)

10.  Maryland Suburbs of Washington, D.C.
     (S/E)

11.  Virginia Suburbs of Washington, D.C.
     (S/E)

12.  Washington, D.C.  (S/E)

13.  Chicago, Illinois (E)

14.  Indianapolis, Indiania (E)

15.  Minneapolis, Minnesota   (S)

16.  Cincinnati, Ohio  (S/E)

17.  Austin-Waco, Texas  (E)
18.  Corpus Christi, Texas  (E)

19.  Houston-Galveston, Texas  (E)

20.  Dallas - Fort Worth, Texas  (E)

21.  San Antonio, Texas  (E)

22.  El Paso, Texas  (E)

23.  Denver, Colorado   (S/E)

24.  Salt Lake City, Utah   (S/E)

25.  Phoenix-Tucson, Arizona   (S/E)

26.  San Francisco, California   (S/E)

27.  Los Angeles, California   (S/E)


28.  San Diego, California  (S/E)


29.  Fresno, California (S/E)

30.  Sacramento, California  (S/E)

31.  Portland, Oregon   (S)

32.  Seattle, Washington   (S/E)

33.  Spokane, Washington   (S/E)

34.  Fairbanks, Alaska  (E)
 (E)   " EPA promulgated controls
 (S)   • State submitted controls
 (S/E) - Both acceptable State controls and  promulgation of additional EPA measures
                                            15

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            ADDITIONAL ACTIVITIES  IN THE MOBILE SOURCE AREA

  NOX  Emission Standard
        EPA  has  recommended  (November 1973) that Congress consider the
  revision of the 90% NOX emission  reduction for passenger cars required
  in 1978.   The  NOX emission standard will be discussed, along with the
  HC and CO  standards and fuel economy in the combined 202(b)(4) and
  202(b)(5)  hearings to be held by  EPA in the spring of 1975.  Further
  recommendations for the level and timing of passenger car emission
  standards  will follow those hearings.
  Automotive Exhaust Emission Survey
        As often as practical, EPA develops current data on emissions
  of in-use  vehicles so that State and local agencies, Federal Air
  pollution  officials, engine and vehicle manufacturers, and concerned
  citizens can estimate the impact of motor vehicle emissions on air quality.
Light Duty Vehicles.  — The  most recent study involved testing of over 1,000
1966 to 1972 model  year vehicles based  on the procedures  applicable to
certification of 1975 model  year vehicles.   This study, the second in this
series, continues  to  show a  significant downward trend in HC and  CO emissions
since the advent of Federal  emissions  standards.  During  the same time period
that HC and  CO levels decreased  levels  of NOx emissions increased.  NOx emis-
sions werenot regulated until  the 1973  model  year and have remained somewhat
stable since that  time.   Comparison between this study and the prior one
shows that average HC and CO emission  levels  are adversely affected by
increasing vehicle age and mileage.
      The third  program in  this  series,  the results of which are  in a
preliminary form,  indicate  that  the general year-to-year  downward trend
in HC and CO emissions is continuing.   Data on 1973 and 1974 model year
                                   16

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vehicles also shows that the recent standards for NOx emissions have resulted
in a drop in levels of this pollutant from the 1968-1972 model  year  values.
     The fourth program in this series will  begin soon and will be the first
to provide large scale testing of catalyst-equipped automobiles in the hands
of private owners.
     A report entitled "Refinement of the Automobile Exhaust Emission Modal
Analysis Model" has been completed for EPA.   This report updates an  earlier
work in describing a mathmatical model and allied computer programs  for
calculating the emissions of groups of vehicles over any specified driving
sequence.  The techniques prescribed in this report will be used in  air
quality impact analysis.
Heavy-Duty Vehicles. — A contract was completed which provided for monitoring
exhaust emissions from 1970 and 1971 model year heavy-duty gasoline-powered
vehicles.  This work involved simulation of the 1970 Federal Test Procedure
on a chassis dynamometer.  A similar contract covering emission surveillance
of heavy-duty vehicles powered  by diesel engines has been completed.
     A third contract is underway to measure exhaust emissions from pre-
controlled gasoline-powered vehicles during actual operation over a prescribed
road route.  This will complete the work initiated earlier on  diesel-powered
and controlled gasoline-powered trucks and will result  in a consolidated
report on all three programs.
     The most recent program in this  series  is directed  toward testing
various types of  heavy-duty vehicles  in a manner similar to that  used  in
certification of  light-duty vehicles.  Both diesel and  gasoline-powered
trucks will  be operated on chassis dynamometers using transient driving cycles
representative of  typical operation  in urban  and suburban situtations.  This
type of testing differs from the current  Federal Test Procedure which provides
                                  17

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that engines alone be operated at various steady state conditions on an
engine dynamometer.  Results from this program will  be more directly useful
in air quality assessments as well  as providing an evaluation of such techniques
for potential use in certification testing.
Auto Fuel Economy Labeling Program
     In the President's Energy Message to Congress of April 16, 1973, EPA
was assigned, in cooperation with the Department of Commerce and the
Council on Environmental Quality, the responsibility for developing a program
to inform the public of fuel economy characteristics of new automobiles.  EPA
instituted a voluntary fuel economy labeling program for automobiles in the
1974 model year and expanded the program in the 1975 model year.
     Presently over 90% of all cars sold in the United States are covered
by the voluntary labeling program.  Usually these cars bear a label which
gives a sales-weighted average fuel economy for all  cars tested by EPA
which represent cars of that same manufacturer, engine size and car line.
In some cases, the label may also specify that the fuel economy results
are representative also of cars of the same weight, transmission, and axle
ratio.  Each label bears two fuel economy figures—one for city driving and
one for highway driving.  The city fuel economy figure is derived from the
EPA emission certification test; the highway fuel economy figure is derived
from a special highway driving cycle test performed on all certification
cars tested by EPA.
     EPA has also published, in cooperation with the Federal Energy
Administration, a fuel economy guide which provides a complete listing of
fuel economy results for all 1975 model year passenger cars and light
trucks.  This pamphlet describes the concept of fuel economy and stresses
its importance as a purchase criterion for new car buyers.
                                 18

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Emissions at Nonstandard Temperatures
     Ambient temperatures outside the 68° to 86° F range specified in
the Federal procedure for emission testing of light-duty vehicles were
studied in a program conducted for EPA by the U. S. Bureau of Mines.
The vehicles tested included precontrol (1967) models, production cars
from model year 1969 through 1974, several developmental cars equipped
with advanced emission control systems (including catalytic converters),
and a diesel and a stratified charge powered car.  The test temperature
ranged from 20° to 110°F.  Cars equipped with air conditioners were also
tested at 110°F with the air conditioner in operation.  The tests show
that exhaust emissions are adversely affected by deviations from the
standard test temperature of 75°F and by air conditioner operation.  Fuel
economy is adversely affected by temperatures lower than 75°F and by air
conditioner operation.  Emissions of hydrocarbons and carbon monoxide are
more sensitive to ambient temperature changes than emissions of nitrogen
oxides.  In general, as the absolute level of emissions in the newer and
developmental cars drops, the sensitivity to change in temperature becomes
greater.  Of all 26 cars tested, the diesel and the stratified charge cars
are lowest in emissions, highest in fuel economy, and least sensitive to
ambient temperature.
Characterization of Currently Unregulated Emissions
     In prior years, studies on unregulated emissions from motor vehicles
have concentrated on characterization of reactive hydrocarbons, aldehydes,
polycyclic organic matter (POM) and particulate emissions.  More recently,
other unregulated pollutants have been identified and are being thoroughly
investigated by EPA.  These new compounds include sulfates, platinum and
                                 19

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other noble metal emissions from catalysts, and miscellaneous compounds
such as nickel and hydrogen sulfide.
     EPA's Office of Research and Development has recommended classifying
all hydrocarbons as reactive except for five compounds (one of which Is
methane) which are generally considered totally non-reactive photochemically.
Instrumentation for measuring reactive hydrocarbons has been developed at
EPA's National Environmental Research Center in Research Triangle Park,
North Carolina.  The Motor Vehicle Emissions Laboratory 1n Ann Arbor is
setting up this instrumentation to measure reactive hydrocarbons by this
reactivity scale.  However, EPA is also investigating the feasibility of
having a non-methane emission standard, which would be inherently simpler
than the reactivity approach.  Thus, lower priority has been given this area
of investigation.
     While aldehyde compounds are a distinct chemical class from hydro-
carbons, they are considered in conjunction with reactive hydrocarbons
since both are photochemically reactive.  Routine measurement of aldehyde
emissions is conducted on advance prototype vehicles sent to EPA for
testing.  Although isolated points show high aldehyde levels, this work
continues to show that aldehydes generally amount to only about 10 percent
of the total  hydrocarbon emissions.
     Since previous work showed that properly functioning advanced light-
duty vehicles (including those equipped with catalytic converters) emit
significantly small amounts of POM, little has been done in this area the
past year.  However, investigations of POM emissions from light and heavy-
duty diesel  vehicles are currently being conducted.
                                20

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     Under EPA contract, higher participate emissions from catalyst-
equipped vehicles were measured in 1972.   During this work, the contractor
discovered that these cars also emit higher levels of sulfates.  EPA
then began intensive research in the sulfate area.  Contract work was
recently completed to measure total  particulate emissions from advanced
prototype vehicles.  EPA has recently aquired the in-house ability to
measure particulate emissions from light-duty vehicles, so the total
level and composition of these emissions are being assessed.
Sulfate Emissions from Catalyst-Equipped Vehicles
     Since the discovery of sulfate emissions, more extensive characteriza-
tion of these emissions has been done by various groups, including EPA's
Office of Mobile Source Air Pollution Control and Office of Research and
Development.
     EPA has measured sulfate emissions on a number of different catalyst,
noncatalyst, and alternative engine automobiles.  Measurements were made
by a variety of methods under various steady state cruise conditions and
on the LA-4 driving cycle used in certifying light-duty vehicles.  The
lack of a standard measurement procedure has hindered the comparison of
data and to some extent, impeded further research.
     Results to date on the sulfate question point to the following
tentative conclusions:
     0    Noncatalyst cars with conventional internal combustion
          engines emit very low levels of sulfates.  Data from EPA-
          ORD, GM,  Ford, and  Exxon  show sulfate emissions  to  be  about
          0.001  grams  per mile or less than  1  percent  of  the  fuel
          sulfur with  the remainder being  S02.   Chrysler  data indicates
          that sulfate emissions  from noncatalyst cars  are lower for
          leaded than  non-leaded  fuel.
                                 21

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     0    Catalyst-equipped cars emit more sulfates than non-catalyst
          cars.
     0    Pelleted catalysts emit substantially lower levels of sul-
          fates than monolith catalysts in the  EPA Test Procedure.  At
          higher speeds, the emission levels of the two types of
          catalysts appear to be similar.   The  difference may be
          due to sulfate storage on the pelleted catalysts at low
          speeds.
     Using available data on sulfuric acid emissions from catalyst-
equipped cars and anticipated fuel sulfur  levels, the EPA has also
employed several predictive models to estimate  the increase in exposure
to acid sulfates likely to result under various assumptions of traffic,
meteorology, and extent of use of catalysts on  cars.  These studies,
whose results were presented by the EPA to the  Senate Public Works
Committee early this year, show that when  catalyst-equipped cars account
for about 25% of miles driven (roughly two model -years equipped with
catalysts), the additional exposure of commuters on our busiest express-
ways to acid sulfates during periods of low atmospheric dispersion  would
exceed levels associated with adverse health effects in susceptible
segments (about 10%) of the population.  In less busy areas, such levels
would be anticipated after perhaps six model years were catalyst-equipped.
It should be emphasized that while these projections have been based  on
preliminary information, they indicate a need for close study of this
potential adverse side effect of catalyst  usage.  Additional studies  of
automotive sulfate emissions which the EPA is conducting will obtain
addtional characterization data, develop more reliable measurement methods
and further assess the technology for control of sulfate emissions.
     If it is confirmed that continued use of oxidation catalysts would
result in dangerous levels of sulfates or  other pollutants, EPA will
take regulatory action to prevent such a condition from occurring.   With
                                 22

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respect to sulfate emissions in particular, EPA would have basically
two options.
     One would be to restrict the amount of sulfur contained in the unleaded
gasoline used by catalyst-equipped cars.  Removing the sulfur-containing
impurities from the gasoline would eliminate the sulfate emissions.  The
technology for doing this in the refining process is known, but implementa-
tion of this approach would be expensive and it would take some time for
all refiners to build up the required capacity.  EPA is studying this
further, as well as possible interim steps to maximize the use of low sulfur
refinery products in the unleaded gasoline.
     The other alternative would be to adopt an emission standard  limiting
the auto manufacturer in terms of the amount of sulfates his cars may emit.
The manufacturer would have two possible ways of responding to such a
standard.  One would be to drop the catalyst and change over to an alternative
engine.  This would take a number of years to fully implement since the lead
time for manufacturers to obtain the new tooling needed to manufacture an
alternative engine is quite long.  Alternatively, the manufacturers might be
able to change the design of their catalyst systems to minimize the formation
of sulfates or install devices to trap or neutralize the sulfates and prevent
their emission.  Such devices are theoretically possible, but proven technology
to accomplish this doesn't exist at this time.
Alternative Automotive Fuels
     In 1974, the Environmental Protection Agency initiated a program to
investigate the feasibility of alternative automotive fuels to conventional
gasoline and distillate fuels from petroleum.  Feasibility studies were
initiated for the selection of the most promising future fuels.  As a result
                                 23

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of these studies which were completed at the beginning of FY 1975, research
investigations are currently in progress to characterize the properties and
auto engine performance of the following fuels:
     0    Gasoline-like fuels from coal and oil shale.
     0    Unconventional fuels from non-petroleum energy resources -
          e.g., methanol from coal.
     These alternative fuels are considered as promising additions to
the use of conventional fuels for the time period 1980-2000.  Beyond
this time period it is contemplated that synthetic hydrocarbons, and
possibly hydrogen, will be produced for automotive transportation from
one or more non-fossil energy resources.
Clean Car Incentive Program
     The Federal Clean Car Incentive Program is designed to foster
development of new types of low-emission vehicles capable of meeting
1978 standards.  EPA leases a candidate prototype which is subjected to
stringent emission and performance tests.  If the prototype passes the
initial tests, EPA may purchase additional prototype cars for testing.
Up to 500 vehicles may be purchased for further evaluation and limited
fleet use.
     Approximately 20 proposals were received when the program began
in January, 1971, of which seven were accepted for more detailed study.
Two candidate vehicles entered the testing phases of the program.  One,
a vehicle powered by an internal combustion engine with catalytic after
treatment, has been rejected because of unacceptable emissions degrada-
tion performance with mileage accumulation.  The second vehicle, powered
by a hybrid system involving a rotary engine and electric storage battery
combination, has completed the initial test phase and the data are currently
                                 24

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undergoing analysis.
Low Emission Vehicle Procurement Program
     The 1970 Amendments to the Clean Air Act established Section 212
which provides for a Low Emission Vehicle Certification Board (LEVCB).
The Board has the responsibility for certifying vehicles which EPA has
determined to have emissions substantially lower than existing Federal
standards.  If certified, the vehicle qualifies for preferential  purchase
at increased cost by agencies of the Federal Government.  The vehicle,
to be certified, must meet all the requirements of some existing class
of vehicles used in Federal service and to date no vehicle submitted has
met these requirements.  The three applications submitted since inception
of the program in 1970 have all been electric storage battery powered
vehicles which comply with the emissions requirements of Section 212,
but do not meet the performance requirements of any current Federal procure-
ment specification applying to existing classes of vehicles used by the
various agencies.
     Recognizing that there may be some applications in Federal service
which electrically powered vehicles might serve, the LEVCB has conducted
a survey of the major Federal agencies which utilize vehicles to determine
whether such vehicles could be used.   In addition, a detailed study has
been made of the problems  limiting the success of the Section 212 program
which the LEVCB may use  as a  basis for recommendations  for changes in this
section of the Clean Air Act.
                                   25

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                 MOBILE SOURCE RESEARCH AND DEVELOPMENT

Research and Development on Automotive Emissions
     The Alternative Automotive Power Systems (AAPS) Program was announced
by the President in his February 1970 Message on Environment.  At that time,
there was concern in the Executive Office of the President that increasingly
stringent exhaust emission standards for automobiles would be required during
the decade of the 70's and that the conventional internal  combustion engine
might not be capable of being controlled to meet the expected low emissions
levels required by the standards.  In 1970 serious work to develop alternative
power systems was not underway nor was such work planned by Industry.  Thus,
the AAPS program was initiated with the goal of objectively evaluating
alternative power systems for automobiles.  It was intended that the program
provide a basis for government decisions regarding the technological feasibility
of new engine systems in meeting the standards.  Within five years (by 1975)
as part of the evaluation process and as announced by the President, the
Federal government would demonstrate virtually pollution-free engines for
automobiles.  To accomodate this demonstration goal, the exhaust emission
levels to be met were made equivalent to achievement of the Federal emissions
standards originally planned for model year 1976.
     The work of the AAPS program was formally initiated in July 1970.
There were initially five types of candidate power systems in the AAPS
program.  These systems included:  Rankine cycle systems, gas turbines, two
types of hybrids (heat engine/battery and heat engine/fly wheel) and battery
powered electric systems.  It was planned that each system would be carefully
studied, designed, component or system test data gathered on each; that the
systems would be ranked on the basis of their potential for being practical,
energy efficient systems which would be capable of meeting the original 1976

                                    26

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 Federal emissions standards; and that the highest ranked systems concepts
 would be developed into prototype hardware appropriate for the demon-
 strations by 1975.*   It was anticipated that other types of alternative
 systems could be brought into the program for evaluation as time went on.
 It was recognized from the beginning that only prototypes of these type
 systems could be demonstrated by 1975/76 and that none could be mass
 produced by that date.  It was felt that if the needed technologies were
•successfully advanced in the program, and the systems demonstrated were
 practical and met the emissions standards and numerous road performance
 goals of the program, then the program would serve to catalyze industry to
 pick up these advances and produce their own versions (improved) of the
 systems which would  be demonstrated.
     The two versions of hybrid systems were judged  to be not viable
 replacements for the conventional engine for several reasons, including
 their requirement for exhaust after-treatment, high  degree of system
 complexity, and relatively high cost to produce.  Continued work on the
 all electric system  has been deferred because the most essential component
 of  the system,  the battery, requires a development program longer  than the
 five-year commitment encompassed by the current program.  Other government
 agencies continuing  with the battery development work are the National Science
 Foundation, the Atomic Energy Commission, the National Aeronautics and Space
 Administration, the  Department of Defense, and the Department of Transportation.
 *The original  program plan called for demonstration of the new power systems
 in full  size (4500 Ib) passenger cars by 1975.   In 1973 the program was
 reoriented to emphasize more the achievement of good fuel  economy and,
 as part of this reorientation, the program plans were changed to provide
 a compact car (3500 Ib) demonstration by 1976 rather than the original
 1975 goal.
                              27

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     As noted earlier it was anticipated that other alternative systems
might be brought into the program after the program had started.  This
was the case for the stratified charge versions of Otto cycle engines.  In
1971 the AAPS program assisted in funding the continued development of
open-chamber stratified charge engines through the U. S. Army Tank
Automotive Command (ATAC) which had initiated work on these systems in
the early 60's.  The development of two versions (Ford PROCO and Texaco
TCCS) proceeded to the point where in 1973 the TCCS was selected by the
Army to proceed Into a final development phase before production.  At that
time AAPS funding was terminated because the engine development had
progressed to the point where different members of industry were continuing
development of their own versions of this type of combustion process.
     The current engine candidates in the program are the Rankine cycle
system and the Gas Turbine.  Combustion systems research and combustor
component development on these systems had progressed sufficiently by
1973 to where tests of these components confirmed that the stringent
emissions standards appeared achievable when installed in complete power
systems.  At that time the emphasis in the AAPS program changed to focus
on improving the fuel economy of the best type systems.
     Four versions of the Rankine cycle system have been under development
since the program began in 1970.  These systems included the steam/reciprocator,
steam/turbine, organic/reciprocator and organic/turbine version.  Early in
1974 the number of competing systems was reduced to the two which offered the
most promise.  These two are the steam/reciprocator which is the prime
candidate and the organic/reciprocator which is the backup system.  As of
October 1974 only the steam/reciprocator remains in the program.
                                   28

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     Unlike the work on the Rankine cycle system, the Gas Turbine
activity has focused on problem-solving research and not on the develop-
ment of a completely new version of engine.  This approach is being used
because in the past, industry has made serious efforts to develop auto-
motive gas turbines and has invested considerable funds in this area.
As a result, the problem-solving approach appears to be the most efficient
use of Federal funds to properly evaluate the gas turbine for automobile
application.
     The problems of the gas turbine that are being attacked include:
NOx reduction, development of low cost materials and manufacturing processes,
and improvements in fuel economy.  Teams of technical specialists from many
industries and from the U. S. National Aeronautics and Space Administration
currently are working on solutions to these problems for the regenerated
free-turbine.
     To ensure that the resulting solutions from the problem solving
research on the turbine are practical, a test bed or baseline engine
program is being conducted in parallel with a problem solving research
activity.  The baseline engine program is providing the automotive type
turbine engines needed to demonstrate the hardware developed in the
research program.  In addition, the baseline engine program contractor,
Chrysler Corporation, is conducting a similar problem solving research
activity to that of the independent research contractors.  Chrysler will
update the turbine engine with all component improvements integrated into
the system and will demonstrate the improved gas turbine engine sized for
                                   29

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a compact car by 1976.  In this process the current baseline of 180 hp
is being redesigned by Chrysler to a 100 hp level  to meet the compact car
requirements.
     The oil embargo in 1973 added emphasis on the need to improve energy
efficiency in motor.vehicles to effect a reduction in demand for petroleum.
New projects dealing with energy efficiency.include: feasibility studies
relating to use of non-petroleum based fuels for automotive ground
transportation, use of Rankine bottoming cycle on diesel  trucks, use of
turbo-compounding and new engine accessory drives.
Research and Development on Aircraft Emissions
     Studies have continued in support of the regulations which EPA has
promulgated limiting the emissions of carbon monoxide, hydrocarbons,
nitrogen oxides, and smoke in commercial and private aircraft.  Current
efforts are concentrated in the following areas:
     1.  Improvement of the precision of the emissions sampling and
         measurement techniques specified in the EPA regulations.
     2.  Assessment of progress by private industry and other government
         agencies in development of techniques for reducing emissions
         from turbine-powered aircraft.
     3.  Assessment of progress by private industry and other government
         agencies in development of techniques for reducing emissions
         from piston engine powered general aviation aircraft.
     In conducting the above programs, maximum advantage is taken of on-
going efforts by other Federal agencies active in the aircraft emissions
                                   30

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area.  These are principally the National  Aeronautics and Space Administration,
the United States Air Force, and the Federal Aviation Administration.  In
addition, the Department of Transportation's Climatic Impact Assessment
Program is being closely followed in order to ascertain whether the EPA
aircraft regulations already promulgated require modification to respond
to upper atmosphere problems.
                                   31

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 III.   THE DEVELOPMENT OF AIR QUALITY CRITERIA AND RECOMMENDED EMISSION
       CONTROL REQUIREMENTS

            NATIONAL AMBIENT AIR QUALITY  STANDARDS (NAAQS)

      EPA has  a continuing program for review of  the  existing  criteria
 pollutant standards and  for assessing the  requirement  for  establishing
 new ambient air quality  standards for other  pollutants.  Assessments
 completed in  1974 by EPA and independent groups  do not indicate  the
 need  for new  or revised  standards.
      A recent in depth review by the National  Academy  of Sciences  (NAS)*
 concluded that there was no substantial  basis, relative to health  and
 welfare effects,  for changing the standards.   This assessment has  been
 supported by  research conducted through  EPA's  laboratory and  community
 studies.
* Air Quality and Automobile Emissions Control, A report by the Coordina-
ting Committee on Air Quality Studies, National Academy of Sciences,
National Academy of Engineering (4 Volumes) dated September 1, 1974.
Prepared for the Committee on Public Works, U. S. Senate.
                                   32

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   NATIONAL  EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAPS)

     On May  3,  1974,  the Agency  issued  clarifying  amendments to  the NESHAPS
promulgated  in  April  1973.   These amendments  generally  advised the public
how the regulations were being  interpreted  in Agency enforcement actions.
     On October 25, 1974, the Agency proposed amendments to the  asbestos
and mercury NESHAPS which, in addition  to amending test methods  and  pro-
cedures, proposes to revise the scope of the regulations.  For asbestos,
it has been proposed that the manufacture of shotgun shells, manufacture
of asphalt concrete, and asbestos waste disposal be added to  the list of
nine source categories covered by the regulations.  Asbestos fabrication
operations are excluded and changes have been proposed  in the regulations
concerning demolition and renovation.  The October  25 proposal  also in-
cludes  the addition of  sewage sludge incinerators as a  source of mercury
emissions regulated by  the  NESHAPS.
                                   33

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      NEW SOURCE PERFORMANCE STANDARDS (NSPS), SECTION 111- CLEAN AIR ACT
      In 1974, the number of sources regulated by promulgated NSPS more
than doubled, and an additional 12  NSPS were proposed with promulgation
planned for early 1975.
      Promulgated March 8, 1974, were NSPS for new asphalt concrete plants,
catalytic cracking units in petroleum refineries, petroleum storage tanks,
secondary lead smelters, secondary brass and bronze ingot plants, basic
oxygen furnaces in iron and steel mills, and sewage sludge incinerators.
The proposed standards, all issued during October 1974, were for primary
copper, zinc and lead smelters, ferroalloy production facilities, five
categories of sources in the phosphate fertilizer industry, primary alumi-
num plants, and coal  preparation plants.   Proposed and promulgated NSPS
at the close of 1974 totaled 24, nearly five times the number of NSPS a
year ago.   Table I summarizes all 24 NSPS.
      Only one of the new NSPS has been challenged; a petition for review
of the asphalt concrete regulations was filed by the National Asphalt  Paving
Association.  The final EPA response to a court remand on a 1971 NSPS
petition for review (portland cement plants) was issued November 5, 1974.
The use of visual  opacity observations, a major issue in the remand, was
supported  by extensive field investigations.
      Requirements concerning continuous emission monitoring and performance
testing were proposed on September 11, 1974.  Generally, the proposal
established a procedure whereby continuous emission monitors are checked
against the manual  performance tests required of new sources.   Performance
specifications for acceptable monitors are included in the Regulations.
                                     34

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      On October 7, 1974, the Agency proposed regulations to implement
Section lll(d) of the Clean Air Act.  Under Section lll(d) States are to
submit plans for the control of non-criteria pollutants from existing
sources after the Agency promulgates NSPS for the source category.  The
proposed regulations would require States to adopt emission standards
which reflect best available retrofit technology,  but States  would be
able to impose less stringent standards  where special  circumstances
exist.
      Amendments to the general provisions to the standards of performance
were proposed on October 15.  The amendments generally defined the Agency's
interpretation of when the NSPS would be applied to modified sources.  Under
the Clean Air Act NSPS apply to existing sources when a modification has
been made which increases atmospheric emissions.  The basic policy stated
in the proposed amendments would limit application of the NSPS to those
situations wherein the modification required a significant capital expenditure.
                                       35

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                                                              Table  5

                                                    STATUS-OF STANDARDS-OF PERFORMANCE
SOURCE
Steam Generators
[>250 Billion Btu/hrJ
Municipal Incinerators
[>50 tons per day]
Portland Cement Plants
Nitric Acid Plants
Sulfurlc Acid Plants
; Asphalt Concrete Plants
PetroleiM Refineries
t
!
PetraleuR Storage
Secondary Lead Smelters
and Refineries
AFFECTED FACILITY
Coal and oil fired boilers
Coal and 011 fired boilers
Coal, oil, and gas-fired
boilers
Incinerator
K1ln, clinker cooler
Process equipment
Process equipment
Process equipment
Process gas combustion
Catalytic regenerators
Gasoline, crude oil. and
distillate storage tanks
>65,000 gallons capacity
Blast and reverberatory
furnaces
POLLUTANT
Participate
S0x
NO*
Parti cul ate
Parti cul ate
NOX
sox
Add Hist
Parti cul ate
sox
Parti cul ate
CO
Hydrocarbons
Parti cul ate
OPACITY
REGULATION
/
/
/
/
/
/
/

/
PROMULGATION
DATE
12/23/71
12/23/71
12/23/71
12/23/71 .
12/23/71
12/23/71
3/8/74
3/8/74
3/8/74
3/8/74
3/8/74
3/8/74
REMARKS
Under remand.

Final Response Filed
November 5, 197^
Under remand.
Undergoing judicial
review.



<*>.
en

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                                                                       Table 5 (Cont'd)
                                                              STATUS OF STANDARDS OF PERFORMANCE
SOURCE
Phosphate Fertilizer
Plant


Iron and Steel Mills
Ferroalloy Production

Continuous Monitoring
Section lll(d) Regulations
Modification
Revision to Hazardous
Pollutant Regulations
AFFECTED FACILITY
Wet process phosphoric
Superphosphoric acid
01 ammonium phosphate
Triple superphosphate
Triple Superphosphate Storage
Electric arc furnaces
Specific furnaces





POLLUTANT
Fluorides
Fluorides
-Fluorides
Fluorides
Fluorides
Parti cul ate
Parti cul ate
CO
General Provisions
General Provisions
General Provisions
Asbestos and
Mercury
OPACITY
REGULATION

/
/
/
/
/





PROMULGATION
DATE










REMARKS
Proposed 10/22/74.


Proposed 10/21/74.
Proposed 10/21/74.

Proposed 9/11/74.
Proposed 10/7/74.
Proposed 10/15/74.
Proposed 10/25/74.
CO

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                                                                       Table 5 (cont'd)
                                                              STATUS OF STANDARDS OF PERFORMANCE
SOURCE
Secondary Brass «nd
Bronze Refining
Facilities
Iron and Steel Mills
Sewage Treatment Plants
Primary Copper Smelters
Primary Zinc Smelters
Primary Lead Shelters

Primary Aluminum
Reduction Plants
Coal Cleaning Plants
AFFECTED FACILITY
Heverberatory furnaces
Basic oxygen furnace
Sludge Incinerators
Roaster, smelting furnace,
converter
Roaster
Sintering machine
Sintering machine, electric
smelting furnace, converter
Blast or reverberatory.
furnace, slnterfng each.
Pot lines
Anode Bake Plants
Air Tables
Thermal dryers
POLLUTANT
Parti cul ate
Paniculate
Paniculate
so*
SOX
Paniculate
S0x
Paniculate
Fluorides
Fluorides
Parti cul ate
Paniculate
OPACITY
REGULATION
/
/
/
/
/

/
/
/
/
/
PROMULGATION
DATE
3/8/74
3/8/74
3/8/74






REMARKS



Proposed 10/16/74.
Proposed 10/16/74.
Proposed 10/16/74.

Proposed. 10/23/74.
Proposed 10/24/74.
00

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                        HEALTH EFFECTS RESEARCH

    The Community Health Effects Surveillance Studies (CHESS)  program
was initiated to provide data relating to human health effects to
long and short-term exposure of population subgroups to SOX, respirable
particulates, NOX, CO, and photochemical oxidants.  The CHESS  Studies
have demonstrated the benefits from improved air quality with  respect
to the chronic respiratory disease experience of subjects who  have
moved to communities having cleaner air.  Also, the studies have shown
that children living for 3 or more years in communities having high
levels of air pollution have more acute respiratory disease  episodes
than recent immigrants to the community.
    Data obtained from the CHESS program indicate that adverse health
effects are consistently associated with exposure to suspended sulfates,
indeed, more so than to S02 or total suspended particulates.  This
information has initiated further study in the transport processes and
control techniques for suspended sulfates.
    Studies were initated to evaluate potential health effects of fuel
and fuel additive emissions from internal combustion engines.   As a
result of this work it has been determined that the physiological
availability of lead compounds from street dust is similar to that of
other lead compounds.  A study of various lead components associated
with auto exhaust and  paint has shown  positive correlation between
blood lead levels and lead levels in  bone, kidney, liver and  spleen.
    Studies have been undertaken to investigate the effects of exposure
to  total emissions from  mobile sources with and without oxidation
                                      39

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catalysts, as well as to catalytic attrition products.   Preliminary
results underscore the benefits of reduced morbidity when carbon
monoxide; nitrogen oxide and hydrocarbon emissions are  reduced but
a risk of increased morbidity from acid mist produced by the
catalyst.  Research and analysis are being conducted to evaluate
these risk/benefit tradeoffs associated with automotive emissions.
                                40

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  IV.   THE STATUS OF ENFORCEMENT  ACTIONS TAKEN PURSUANT TO THIS ACT
                  STATIONARY  SOURCE  ENFORCEMENT
     The Clean Air Act amendments of 1970  approached  the  task  of  protecting
health and welfare from the effects  of  air pollution  from stationary  sources
in three key sections:
          o  S110, state Implementation Plans  (SIPs)  -
             which provide for establishing State air pollution limit-
             ations designed to achieve health related  (primary standards)
             and welfare related  (secondary standards)  air quality goals.
          o  §111. New Source Performance  Standards (NSPS)  -
             which require  EPA to develop emission limitations for newly
             constructed or modified major emitters,  based  on  best available
             control technology and cost;  these  standards are  to  be a major
             factor in the maintenance of acceptable air quality  achieved
             under §110.  After their promulgation, States are encouraged to
             assume responsibility for the enforcement of these standards.
          o  §112, National Emission Standards for Hazardous Air
             Pollutants (NESHAPS) -  which require  EPA to develop emission
             limitations for especially toxic pollutants for which air
             quality  standards cannot be adequately established.   As
             under §111, States may request delegation of these standards.
     While the Act placed the primary responsibility for attainment and main-
tenance of air quality standards upon the States, EPA's enforcement authority
was also  greatly  strengthened under the 1970 amendments,  ill4 of the Act
authorizes EPA to make inspections, require reports and  recordkeeping
and require sources to sample their emissions in order to verify  compliance
                                     41

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with the emissions limitations established above.  §113 of the Act authorized
EPA to actively enforce against sources violating requirements established
under sections 110, 111, 112, and 114 by issuing an order to comply or
commencing civil or criminal action.  In accordance with the intent of the
Act, it is EPA's policy to defer to State enforcement where effective
progress is being made.  EPA enforcement actions to ensure compliance with
emission limitations established under the State Implementation Plan are
therefore undertaken to stimulate or assist State enforcement programs, and
States are encouraged to request delegations of the enforcement of NESHAPS
and NSPS.  Much of EPA's stationary source air enforcement program to
bolster State efforts is carried out through the provision of technical
and legal assistance, provision of specialized skills or expertise, special
contractual efforts, and control agency grants.
     The effectiveness of EPA and State enforcement efforts under each of
the above sections of the Act over the past year is addressed separately
below.
                                      42

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 §110.  State  Implementation Plans (SIP)
     The Act established a stringent timetable for EPA and States to abate
air pollution.  In accordance with this schedule, EPA promulgated ambient
air quality standards on April 30, 1971, for six air pollutants:   particulate
matter, sulfur dioxide,, nitrogen dioxide, carbon monoxide, photochemical
oxidants, and hydrocarbons.  Under the Act, the States then had just 9 months
to develop comprehensive implementation plans (which included enforceable
emission limitations) designed to achieve these ambient standards, and EPA
was allotted 4 months for the review and approval or disapproval  of these
plans.  These deadlines were substantively met when EPA approved most portions
of the SIPs in May 1972.  With a few notable exceptions (e.g., sulfur oxide
emission limitations In the State of Ohio), all states now have fully enforce-
able emission limitations affecting stationary sources.  The Act allows three
years from the date of State plan approval for EPA and  the  State  to reduce
pollution levels to the health-related ambient air quality standards.   Except
for portions of 16 States, where an extension of up to 2 years has been granted
for one or more pollutants, these primary ambient air quality standards are
required to be met by July 1975.
     State and Federal programs face an immense task in achieving compliance
since there are estimated to be over 200,000 stationary sources subject  to
SIP emission standards.  Of this number, however, approximately 20,000 are
major emitters (i.e., facilities individually capable of emitting over 100
tons of a pollutant per year)   which, as a class, produce about 85% of all
air pollution emitted by stationary sources.   Accordingly, EPA and State
enforcement programs have focused on ensuring compliance by this class of
emitters in order to have the greatest impact on pollution abatement.  From
approval of most SIPs in May 1972 until May 1973, EPA and the States had
                                     43

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 investigated only some 7,000 of these  sources.   By  January  of 1974,  some
 13,500 of these major emitters  had  been  identified  and  investigated,
          A vigorous  program mounted over the  last year  to locate and  inspect
 these sources has resulted  in the identification of about 19,175 facilities,
 nearly all of the estimated 20,000 major sources.
      As reported in the last review of EPA enforcement  under the Clean  Air
 Act, only 6 enforcement actions had been taken against  stationary  sources in
 1972 (4 notices of violation, and 2 administrative  orders). In 1973, the
 number of EPA enforcement actions Increased to 112  (82  notices of  violation
 and 30 enforcement orders), and in 1974  EPA took 271  enforcement actions
 (179 notices of violation and 92 enforcement  orders or  civil or criminal
 actions).  A summary of these actions  is contained  in the Appendix.   As shown
 in the Appendix, State action for many of these sources has been stimulated
 by EPA initiation of enforcement.  The actions also represent the  results of
 a major effort on the part of EPA to establish the  compliance status of sources
 subject to SIP emission limitations.  In 1972,  only about 100 compliance
 investigations were made under  the authority  of §114 of the Act, in  1973 the
 number of field actions increased to 2,000 (Including some  1,200 plant
 inspections, opacity observations,  and emission tests,  and  800 required
 reports), and in 1974 some 3,600  such investigations (comprising  some  1700
 field investigations and 1900required  reports) were completed.
      This increase in enforcement activity was mirrored by  the State enforcement
 programs, resulting in a great  increase  in the number of major sources  brought
 into compliance.
    Of the 19,000 identified major sources mentioned above,  a total  of 13,585
(71%) now comply with  applicable emission  limits or are meeting  compliance
schedules; this has increased from some 7,890 known to comply a  year ago.
Of the 13,585 in compliance, 10,618  are in final compliance with all require-
ments, and 2,967 are meeting increments on their compliance  schedule.

                                44

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On the order of 6,500 major sources had yet to be identified  or investigated
at the beginning of 1974; as of December 1974, less than 1000 major  sources
are thought to remain outside State and EPA inventories, and  3,400 of the
identified major sources are the targets of EPA and State investigations to
complete determinations of compliance status.  Nearly 2,200 major sources
(11%) are known to violate emission limitations or compliance schedules at
the present time - these sources are the subject of current EPA and  State
case development programs.
     Despite this progress in SIP enforcement, several categories of major
sources may not achieve compliance with emission standards within the time
limits prescribed by the Act.  Notable among these sources are coal-fired
power plants, iron and steel manufacturing plants, smelters,  and industrial/
commercial boilers.  Special efforts are now being implemented by EPA to
ensure compliance by these classes of sources as quickly as possible.
Coal-fired power plants.-- Control of emissions from power plants is essential
to the attainment of the health-related air quality standards for sulfur oxides
in many areas of the U.S.  As a class, coal-fired steam electric plants emit
about 6Q% of the total sulfur oxides produced by all sources.  During the
summer of 1973, it became increasingly apparent to EPA that progress to meet
applicable State-adopted sulfur oxide emission limitations by this sector of
industry was severely lagging.  New supplies of low-sulfur content coal, the
favored approach to reducing sulfur oxide emissions,were becoming increasingly
scarce and utilities were extremely reluctant to use flue gas desulfurization
(FGD) systems  (scrubbers) to remove sulfur oxides from the stack after  high
sulfur content  coal has  been burned.  EPA held national  public  hearings in the
fall of 1973 to review the  status  of power plant compliance with  sulfur oxide
 emission  limitations  and to determine  whether FGD offered an available control
                                     45

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alternative to the use of cleaner fuels.   On  the basis  of  testimony  by
utilities, FGD vendors, and other authorities on the subject,  the  hearing
panel concluded that the basic technological  problems associated with FGD
raised by the utilities had been solved or were within  the scope of  current
engineering and that FGD could be applied at  reasonable cost.
     In light of these recommendations, a special  enforcement  program for
power plants was implemented.   As detailed in the Appendix,  31  notices of
violation have been issued to  power plants (6 in 1973,  25  in 1974),  14
enforcement orders have been issued, and  13 consent orders establishing  firm
schedules of compliance have been signed.
     A measure of the effectiveness of EPA's  power plant efforts is  the  rise
of the use of flue gas desulfurization control  devices. In  1974 the number of
FGD installations in operation, under construction, or  otherwise committed to has
more than doubled—from 44 units at the time  of the hearings to about 100 units  by
the end of 1974.  These 100 units represent approximately  40 percent of  the coal-
fired capacity that will  need  flue gas desulfurization  systems by  the end of 1980.
EPA estimates that approximately 90,000 megawatts of coal-fired generating
capacity will need to install  these systems by the end  of  1980.
     The number of units now on-line has  doubled—from  10  to 20, and additional
systems are scheduled for startup in January  1975.
     Increasingly high reliability factors (in the 80 to 90  percent  range) are
being evidenced and several companies have purchased systems to treat sludge by-
products from nonregenerable scrubber systems.   It is anticipated  that 12 more
units will be operable by the  end of 1975, and 12 more  at  the  end  of 1976, bringing
the total number of on-line systems to 44 by  the end of 1976.   A few units are
scheduled for startup later than 1977, and some startup dates  are  unknown because
installation is tied to the startup dates of  new plants, but the bulk of the 100
units committed to will be on-line by December 1977.

                                  46

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    However, we will not see nationwide compliance by coal-fired power plants
by mid-1975 deadlines contained in most SIPs.  As of December 1974, only
about half of the coal being used by utilities met SIP sulfur content limits.
Of the remaining 50% of 1974 utility coal, about 12% was burned at noncomply-
ing plants owned by utilities with firm plans to comply, about 16% was burned
at plants having no known compliance plans, and about 22% was used at plants
covered by SIPs that are under legal challenge or that are being revised.
    In order to ensure that health-related ambient air quality standards
for sulfur oxides are attained as quickly as possible, EPA has, over the
last year, given enforcement priority to those noncorr.plying plants (about 90)
having an impact upon these primary standards.  Of these plants, 3 have
achieved compliance, 23 are now subjects of state and EPA enforcement actions,
and 20 are now on acceptable federal, state, or local compliance schedules.
Unfortunately, enforcement against about half of these priority plants is
stayed pending conclusion of litigation or is prevented by ongoing SIP
revisions.
Iron and Steel Mills and Coke Plants.— Iron and steel mills and associated
coke plants represent one of the larger and more complex categories of problem
sources in stationary source enforcement.  There are about 200 of these sources
in the U.S., they are large, and the processes that occur in these plants are
diverse.  In addition, the enforcement effort is made more complex by a number
of SIP regulations that limit emissions of particulate matter from only certain
portions of the coking cycle, such as charging, under-firing, etc.
    About 70 major U.S. facilities are equipped with coke ovens, and the
majority of these are out of compliance with SIP regulations.  There are
another 45 major non-coking iron and steel facilities which produce pig iron
using blast furnaces and raw steel using open hearth or basic oxygen furnaces
                                  47

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  or a combination thereof.   Nearly all of  these facilities have at least one
  process that is out of compliance.   EPA enforcement priorities in 1974 have
  concentrated on these  115 major  sources of particulate matter.  There are,
  in addition, some 85 iron and  steel  plants producing raw steel with electric
  furnaces that charge mostly scrap metal instead of pig iron.  Although
  these sources have  not yet  received close enforcement scrutiny, EPA
  estimates  that approximately 20%  are out of compliance.
      In 1974,  EPA expanded its  enforcement program to inspect and document
  violations occuring  at iron and  steel mills and coking facilities; this
  expanded program resulted in an  increase in enforcement actions taken —
  from 8 in  1973 to a  total of 33  by December 1974.
      During 1974, efforts were also directed toward identifying those state
 implementation plans containing deficient regulations or regulations that
 did not limit emissions from all  aspects of the coking cycle.  In addition,
 the Agency initiated a  program to test and then determine the applicability
 and effectiveness of control technologies for coke oven emissions. Although
 much remains  to be accomplished in bringing steel mills and coke plants
 into compliance,, it is  anticipated that most of these facilities will be
 inspected, and by mid-75 will  be  subjects  of  EPA  enforcement actions
 leading to firm compliance  schedules.
Primary Non-Ferrous Smelters. — Most of the Agency's  problems in  assuring
compliance by the Nation's 28 primary non-ferrous  smelters  have centered  in
the Western U. S.» where 13  of these smelters  are  not  subject to federally-
enforceable regulations  for  the control  of sulfur  oxides.   In May  1972,  the
SIPs for the States of Arizona, Idaho, Montana,  Nevada,  New Mexico,  and  Utah
were disapproved insofar as  they applied to these  very large sources of
particulates and sulfur  oxides.  Federal  replacement regulations have not
been promulgated since May 1972 due to controversies over  the availability
of controls and the possible use of intermittent control systems and tall
                                48

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stacks.  However, resolutions to these problems were  approached  in
late 1973 and EPA is now finalizing federal  regulations  for  the
control of SOX from primary non-ferrous smelters.   Regulations that
will soon be proposed require the application  of the  best available
retrofit control technology, and, if necessary, allow the interim use
of supplementary control systems (SCS) and tall stacks until adequate
constant control techniques become available.  Each smelter  using SCS
is further required to conduct a research  and  development program to
hasten the development of such technology.
     Six smelters in Eastern regions are in violation of an  SIP-approved
regulation; with few exceptions, State agencies are adequately responding
to the problem.  In one case, EPA has filed suit to enforce  the  regulation,
and in another, enforcement is stayed by a §307 challenge to the SIP.
     The  national  program  for assuring compliance  from  primary  non-ferrous
smelters  is making headway.   Regulations  for  the control of sulfur oxides  have
been proposed  for  two  smelters and promulgated for another.  The additional
regulations are in the final  stages of development,  and should  be proposed
in  the  near future.   In nearly all  cases, smelters are  taking steps  to comply
with regulations,  including several  which are not  yet  subject  to final
regulations.
     About half of the primary non-ferrous  smelters  are located in air quality
control regions where  statutory attainment dates have been  extended  to
July 1977.  No major obstacles are anticipated that  might  prevent achievement
of  final  compliance by these sources by the mid-77 deadlines.   Those subject
to  mid-75 deadlines are, for the most part, nearing  compliance.
                                      49

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Industrial Boilers.-"  There are about 3500 coal-fired industrial  and
commerical boilers in the United States.  Control  of these sources is
especially needed in urban areas not yet meeting the primary ambient air
quality standards for sulfur dioxide.  Basic enforcement problems  are
presented by the large number of these sources and the difficulty  in
establishing reasonable and expeditious compliance schedules when  the supply
of low-sulfur fuels may be in question and the supply of FGD systems is
limited.  In selective enforcement actions, EPA issued 26 notices  of
violation to facilities having industrial boilers, resulting in the issuance
of 11 orders to comply.

Summary. —  in summary, significant progress is beina made in the enforcement
of SIP emission standards.  Most national average concentrations for the six
criteria pollutants show a general, but distinct,  downward trend from the
1960's into the 1970's, especially in those areas having the worst pollution
problems.   While many areas may be delayed in achieving the health-related
air quality goals past dates mandated by the Act,  the progress  being made
in enforcement of SIPs will ensure attainment as quickly as possible.
                                     50

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§yn.   New Source Performance Standards (NSPS)
     New source performance standards  were first promulgated  on  December  23,
1971, for 5 categories of major  emitters  (steam electric  power plants, municipal
incinerators, nitric and sulfuric acid plants,  and asphalt cement plants).
A second group of NSPS covering  an additional  7 source categories was  promulgated
on March 8, 1974 and NSPS for 5  more categories were proposed in October  1974.
By June of 1974 over 100 detailed investigations were made by EPA of sources
suspected of being subject to NSPS.  Of this number, 28 sources  were determined
to be subject to the first set of NSPS; five of these are now operating  in
full compliance, and the remainder are still being built.  Enforcement of
provisions covering both groups  of NSPS was initiated during  the summer  of
1974 by EPA.  As of December 31, 1974, 104 sources have been  found subject
to these provisions (the three-fold increase of sources in the past six  months
reflecting the promulgation of the second group of standards).   To date,  all
of these sources are under construction or have yet to be fully  assessed for
final compliance.
     While relatively little enforcement activity has developed  to date  from
the promulgation of these standards, additional promulgations of standards
is expected to result in a great increase in enforcement.  The importance of
these standards as a means of maintaining the improving air quality will  also
increase in years to come.
                                   51

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§T12.   National  Emission Standards for Hazardous Air Pollutants  (MESHAPS)
     On April  6, 1973, EPA promulgated regulations  limiting  emissions  from
certain sources of three air pollutants deemed  hazardous  to  human  health
under the Clean Air Act provisions establishing National  Emission  Standards
for Hazardous  Air Pollutants (NESHAPS).   The  pollutants were asbestos,  beryllium
and mercury, and the regulations required that  certain categories  of sources
of these pollutants be brought into compliance  within 90  days, be  shut down,
or be placed on EPA-approved schedules bringing them into compliance by
April 1975.
     EPA determined that only 620 of  13,000 potential sources were actually
covered by the regulations, and has since brought 500 sources into compliance;
of 120 sources suspected or known to  be in violation of  NESHAPS  requirements,
50 are completing increments of progress in EPA-approved  schedules to  achieve
compliance by  April 1975.   EPA enforcement orders to comply  have been  issued
to ten additional violating sources and evidence for additional  enforcement
actions is being developed.
     NESHAPS provisions also cover two stationary,  but temporary,  sources of
asbestos:  spraying of asbestos insulation and  demolition of asbestos-containing
buildings.  EPA estimates that at least 30,000  spraying  and  demolition
operations occur each year.  Because  of the transitory nature of these sources,
enforcement at the federal  level is difficult;  the  controls  can  best be imposed
at the State and local levels.  Therefore, EPA  is making  every effort  to
delegate responsibility for these efforts to  the States.  While  these  provisions
are still the responsibility of EPA,  the agency's enforcement program  has focused
on the most recalcitrant violators.   As detailed in the  Appendix,  EPA  has issued
8 enforcement orders and initiated 7  criminal actions against transitory  sources
                                   52

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               MOBILE SOURCE ENFORCEMENT
     Under various provisions of Title I and Title 11 of
the Clean Air Act,  the Mobile Source Enforcement Division
has the responsibility for enforcement of motor vehicle emission
standards for new and in-use vehicles, for enforcinq transportation
control plans where the states fail to do so, and for regulating
fuels and fuel additives.
NEW SOURCES ACTIVITIES
     Under Section 206(c) of the Clean Air Act, the Mobile
Source Enforcement Division is entrusted with enforcement of
requirements for  "new" motor vehicles or engines -i.e., motor
vehicles or engines which have not yet been sold to the
ultimate purchaser
     Since January 1,  1974, the Mobile Source Enforcement
Division has conducted 17 inspections of domestic and foreign
motor vehicle manufacturer certification procedures.  Such
inspections include detailed audits of procedures and visual
inspection of facilities and vehicles in order to determine
whether manufacturers are and have been acting in compliance
with the Clean Air Act and its regulations.
     The Mobile Source Enforcement Division has also conducted
a total of 10 vehicle manufacturer investigations since
January 1, 1974,  some of which arose from the inspections.
This activity consists of a search of vehicle manufacturer

                                53

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records and documents and interrogation of individuals to



determine whether violations of the Clean Air Act and its



regulations have occurred.  Issuance of orders for production



of information pursuant to Section 208 of the Act frequently



accompany such investigations, and such orders have recently



been expanded to include requiring the manufacturer to develop



emission test data where technical violations may be accompanied



by effects on emission performance.  Since January 1, 1974,38



§  208 letters have been issued by Mobile Source Enforcement.



    Out of the 17 investigations, 1 case  was referred to the



Department of Justice for enforcement action.  That referral,



which included 2 violations by Volkswagen of America, has



been prosecuted.  A complaint against Volkswagen AG and Volkswagen



of America for the unreported existence of emission control



"defeat devices" on certain 1973 Volkswagens was settled by



stipulation in the amount of $120,000.




IN-USE SOURCES



    The Mobile Source Enforcement Division is also responsible



for enforcing provisions of the Clean Air Act relating to in-use
                            54

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motor vehicles.  Such provisions relate to  tampering,  recall,
warranty, and imports.
    Tampering
    Section 203(a) (3) makes it a prohibited act  for  any
manufacturer or dealer knowingly to remove  or  render inoperative
a vehicle's emission control system after sale of  the vehicle
to the ultimate purchaser.  From January 1,  1974,  to January
1, 1975, the Mobile Source Enforcement Division  conducted
approximately 15 investigations with  the regional  offices
responding to many alleged violations of the tampering
prohibition of  the Clean Air Act.  Five cases  were referred
to the Department of Justice for action.  Since  January 1, 1974,
a total of four tampering cases have  been successfully prosecuted,
A prosecution against Haney Chevrolet, of Orlando, Florida, in
February, 1974, resulted in a  fine in the amount of $500.
Other cases and penalties were Gowin  Dodge, Milton,  Florida
for $2500, Haney Chevrolet of  Larchmont, New York for $1,000
and Jim Wanger  Chevrolet of Milwaukee,  Wisconsin for $1,200.  This re-
presents the first tampering prosecution under the Clean Air Act.
    Recall
    Section 207 (c) of the Clean Air Act authorizes EPA to
order recall of vehicles if they  do not conform to emission
standards.
    One  recall  under  the Clean Air Act  has  been ordered since
January  1, 1974.   On  March  6,  1974, EPA ordered Chrysler
Corporation to  recall 826,000  motor vehicles to correct
                               55

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 defective  temperature  sensing devices.   In addition,  282,863
 vehicles have been voluntarily recalled by manufacturers to
 repair vehicles not conforming with  standards.
     The Chrysler CCEGR Recall  Campaign,  ordered by EPA on March 6, 1974, is
 a large scale campaign requiring a relatively low cost repair and has cost
 about $6 per car or a total of  approximately $2.4 million to date.  This is
 based on EPA's estimate that fixed costs  in this campaign were approximately
 $1 million and parts and labor  for each car fixed amounted to $3.50 per car
 (400.000 X 3.50 = $1,400,000).
     The Agency estimates the fixed costs of an EPA ordered recall campaign
 (initial notification, overhead, provision for subsequent notification record-
 keeping, etc.) to be in the range of $1-3 per car campaigned and expect that
 voluntary campaigns would be of similar or slightly lower costs due to greater
 flexibility  available to the manufacturer in a voluntary campaign.
     Since  January, 1974,   the Mobile Source Enforcement Division
has  conducted 29  investigations  of  possible recalls.  MSED
is currently conducting investigations involving General
Motors,  Ford, Chrysler, and Volkswagen of  America for possible
recalls.
     Warranties and Aftermarket Parts
     The warranty  provisions of the  Clean Air  Act are designed
to help assure that manufacturers develop  and produce vehicles
that meet emission standards throughout their useful life.
     the  207 (a) production warranty  provision  of the Clean
Air  Act  requires  that  the manufacturer warrant that the vehicle
                             56

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or engine meets applicable emission standards at the time of
sale, and is free from defects which may cause the vehicle or
engine to fail to comply with the emission standards.
    The 207 (b) performance warranty provision of the Clean
Air Act requires that a manufacturer warrant vehicles and
engines comply with emission standards when in actual use.
EPA is working to develop these warranties into meaningful
remedies for purchasers of nonconforming vehicles.  In support
of the warranty programs, and to protect against any resulting
anti-competitive effects in the automobile aftermarket, EPA
                             56a

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has endorsed a voluntary self-certification program for certain



automotive aftermarket parts, and MSED is working toward



its development.



     Imported Vehicles



         Sections  203(a)(1) and 203(b)(2) gives the Mobile



Source Enforcement Division the responsibility for enforcing



compliance of imported motor vehicles with emission standards.



In conjunction with the Bureau of Customs, the Mobile Source



Enforcement Division has monitored importation of an estimated



3 million commercial and privately owned vehicles since



January 1, 1974.  Through that program, a total of 284



administrative orders to modify noncomplying vehicles have been



issued as well as 72 orders to export nonconforming vehicles



imported under bond.  Thirty-nine bond forfeitures have been



assessed through Customs for noncompliance with the regulations.



     The Mobile Source Enforcement Division has conducted 46



investigations of alleged illegal importations.  One case was



referred to Justice Department for prosecution against the



Grossman Motor Car Corporation of West Nyack, New York.  On



June 12, 1974, a civil penalty of $25,000 and a criminal



penalty of $30,000  (remitted to $4,500) were assessed against



the Corporation for the illegal importation of 14 motor vehicles
     Transportation Control Plans



          Under sections 110 and 113 of the Clean Air Act
                                57

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(Title I) EPA has the authority to ensure enforcement of



Transportation Control Plans.  Mobile Source Enforcement Division



coordinates the accompanying regional enforcement program.



During the past year, since January 1, 1974, Section 113



notices of violation were issued to 390 employers in the Boston



area for failure to submit employee parking space reduction



plans, one Spokane parking lot operator for operating a parking



facility in violation of a freeze in Spokane, Washington,



22 service station operators in the Denver area for failure



to submit control plans pursuant to Stage I Vapor Recovery



Regulations, and the State of New York for failure to meet



a number of implementation milestones.  In addition, 99



section 114 letters of inquiry have been sent.
                              58

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    Fuels Enforcement



    The Mobile Source Enforcement Division has responsibility



for enforcing section 211 (c) (1)  of the Clean Air Act relating



to the regulations of fuels and fuel additives. On January



10/ 1973, EPA promulgated regulations requiring the general



availability of unleaded gasoline by July 1, 1974 for use



in 1975 and later model cars equipped with catalytic emission



control systems.



    The Mobile Source Enforcement Division has established a



nationwide Fuels Enforcement Program for ensuring that affected



retail outlets are in compliance with these regulations.



This program entails sampling of the fuel at retail outlets by



Regional EPA Field Inspectors, though the use of a mobile



van test facility.



    During the past year, beginning with the effective date



of the lead-free fuel regulations on July 1, 1974, EPA has



conducted 5,360 inspections of service stations to ensure



compliance with the lead-free fuel regulations.  EPA has



detected 1895 minor violations of the lead-free fuel regulations



and 66 violations for contamination of lead-free gasoline.



There have been 796 warning letters and 97 complaints issued,



18 settlement conferences held, and 3 ($1750) penalties collected,
                               59

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    Sixty-six (66) cases of contaminated unleaded gasoline were  detected
during the first two quarters of Fiscal  Year 1975.   In each case both  the
retailer and the supplier of the gasoline (refiner and/or distributor)  are
deemed in violation.  In those cases which have been settled,  the supplier
has usually been found to be liable for  the contamination.  The  contamination
most often occurs in that link of the distribution chain which connects the
terminal or bulk plant to the retail outlet.  Common causes of contamination
include the retention of some leaded gasoline in the delivery  truck or its
manifolding which mixes and adulterates  a subsequent batch of  unleaded gasoline,
or misdirected unloading of leaded gasoline into an unleaded underground
storage tank.
    During the same period of time, 1, 895 cases of minor violations were
detected.  However, because many of the stations in violation  contained
multiple violations, the number of stations out of compliance  is estimated
at 650.  For the most part, the retailer is responsible for complying  with
these nozzle, sign and label provisions.  Most of these cases  are handled
on an informal basis; a warning letter rather than a complaint is issued to
the retailer notifying him of the nonconforming situation at his outlet.
If the retailer remedies the situation within a stated grace period, the
case is closed without the issuance of a complaint.  Only when the retailer
fails to bring the station into compliance in a timely manner  is a complaint
issued against the retailer assessing a civil penalty.  As set out in Guide-
lines from Headquarters, the penalties are uniformly lower than  those assessed
against distributors and refiners.
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                                                     Table  6

                                       MOBILE SOURCE ENFORCEMENT ACTIONS
TYPE OF SOURCE
INSPECTIONS
INVESTIGATIONS
ADMINISTRATIVE
   ORDERS
TOTAL
                     5360
REFERRAL TO
  DEPT. OF
  JUSTICE
                                                                          PROSECUTED
                                                                    FINE
NEW SOURCES
Automotive
Manufacturers
IN-USE SOURCES
Tanpering
Recall
Imports
FUELS
10 Inspections
17 Investigations 36 1 1 $120,000
15 0 54 $5,200.
29 1 o
46 395 11 $29,500.

                                                                                       $1750.
                     5477
                        432
                                               $154,700.

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V.  THE STATUS OF STATE IMPLEMENTATION  PLAN APPROVALS,  DISAPPROVALS,
    AND PROMULGATIONS, AND PROGRESS  TOWARDS ATTAINMENT  OF NATIONAL
    STANDARDS
     On April 30, 1971, EPA promulgated National  Ambient Air  Quality
Standards (NAAQS) for five pollutants—sulfur dioxide,  particulate matter,
carbon monoxide, photochemical  oxidants, and  nitrogen  dioxide.   Subsequent
to that action, each of the 50  States,  four U.S.  territories, and the
District of Columbia, were required  to  submit a State  Implementation Plan
(SIP) to EPA which described the procedures and control actions  that would
be taken to reduce existing ambient  concentrations  for each pollutant  to
levels at or below the national standards.   For purposes  of SIP  development,
the entire geographic area of the nation was  divided by EPA,  after  con-
sultation with State agency officials,  into  247 Air Quality Control  Regions
(AQCR's).  SIP's which demonstrated  the attainment and maintenance  of
NAAQS were required to be submitted  for each  of the AQCR's  and for  each of
the pollutants.
     Each of the States submitted SIP's for EPA approval  (or disapproval)
as required under the Act.  These plans were  more or less complete,  with
the exception of 42 AQCR's which were granted an 18-month extension to
develop SIP's for secondary standards for particulate matter or sulfur
dioxide.  Under the Clean Air Act, EPA has the authority to propose and
promulgate regulations to overcome States' regulatory deficiencies.  Table 7
shows  the current status of the 55 SIP's with respect to the need for EPA
promulgation and the  degree to which these promulgations have been made.
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                                                             (a)
Table  7     STATUS OF STATE IMPLEMENTATION PLANS, SUMMARY
    SIP's approved through State submittal                 3

    SIP's submitted by States and requiring EPA
      promulgation                                        52

    SIP's with all regulatory deficiencies corrected
      by EPA promulgation                                 38

    SIP's with all regulatory deficiencies not yet
      corrected (finalized) by EPA promulgation           14
a All  plans are disapproved with respect to "significant deterioration"
  and"maintenance of the national  standards."
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l*iile most parts of many SIP's have been approved, one or more elements
of the SIP's was deficient, resulting in a small  number of SIP's  being
totally approved.
     The State and EPA control regulations were believed to be adequate
at the time of SIP approval to reduce ambient levels to the national
standards.  While it is premature in many cases to determine if in fact
the national standards will be attained by the implementation of these
control plans, (primarily because numerous emission limiting regulations
and compliance schedules do not require compliance until the 1975 time
period), some general conclusions can be drawn.

          ATTAINMENT  OF  NATIONAL AMBIENT AIR  QUALITY STANDARDS
Sulfur Dioxide
     With regards to sulfur dioxide, significant progress has been made
in reducing ambient concentrations throughout the nation.  Nationally, a
25% decrease in annual  average SO, concentrations has been observed.   For
the most part, the AQCR's with air quality not yet meeting the  national
standards generally have emissions from large uncontrolled point sources,
such as power plants.   In most cases, it is believed that enforcement of
existing  regulations will  be adequate to attain  national  sulfur
dioxide standards.
Particulate Matter
     Some progress has been made in reducing particul ate matter concentrations,
but reductions are made more slowly for particulates than for S02.  On a national
average, a 15% decrease has been observed. However, two distinct problems have
been noted which may affect the attainment of the national particulate matter
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standards.  These problems include the impact of fugitive or windblown
dust on air quality, particularly in the West where windblown dust from
farms, unpaved roads, and construction sites may cause high ambient concen-
trations.  The second particulate problem involves the high background con-
centrations in many urban areas.  It is believed that numerous miscellaneous
sources contribute to high background concentrations such that the attain-
ment of national standards may be difficult without the application of new
and long range control techniques.  Background sources include:   tire
particles, pollen, vegetative matter, sand and salt particles from snow
control, windblown dust from exposed surfaces, reentrainment of street dust
caused by wind and traffic flow, as well  as secondary particulate formation
in the atmosphere from the conversion of gaseous pollutant emissions by
complex atmospheric transformations.
     Preliminary evaluations in major problem cities have indicated that
the measures necessary to attain national standards for particulate matter
would include: conversion to gaseous fuels* extremely stringent emission
limitations; elimination of small incinerators; extremely low sulfur content
fuels;  elimination of additives  such as  lead in fuels; comprehensive
 fugitive dust control; and tight control of hydrocarbons (to reduce
 photochemical  aerosols).   Replanning of  future growth and development
 would  also be involved in at least some  areas.
Carbon  Monoxide and  Photochemical Oxidants
     The attainment  of national standards for photochemical oxidants and
carbon  monoxide in major cities is directly associated with control of
transportation sources.  Twenty-seven cities have been determined to need
                                    64

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a transportation control  plan (Tcp) to meet tne oxidant standard, while
TCP's  for carbon monoxide are needed in 26 AQCR's.  TCP's may require
such measures as traffic flow improvements, mass transit improvements,
car pool locator services, or, in extreme cases, gasoline limitations
and selective vehicle exclusion from downtown areas.  Such measures are
planned  to  reduce  the emission of photochemical oxidant precursors such
as unburned hydrocarbons and nitrogen oxides.  Since these measures would
have major  social  and economic impact, the Agency has suggested to Congress
an amendment of the Clean Air Act that would allow the attainment date for
ambient air quality standards for  these  pollutants to be  extended
thereby  eliminating  the  need for  rapid  application of control
actions  that would have  serious adverse social or economic effects.
     The oxidant attainment  problem is  further complicated by the  fact
 that recent measurements of  oxidant levels in rural areas have  shown that
national standards are exceeded regularly, in some  cases more than 20% of
the time.   Though  it is  known that natural emissions from such  sources
as coniferous  forests can cause the formation of photochemical  oxidants,
data from  remote ambient air monitoring sites,'when correlated with
meteorological  data, indicate that oxidants are advected  into these remote
 areas  from  large metropolitan areas that may  be hundreds of miles  distant.
Additionally,  east of the Mississippi  River,  where  large cities are  in close
 proximity,  research  data show that oxidantein  remote areas may  come  from
 different  source cities  depending on wind direction.   Further research
 is being done  on this problem to  identify the source of  oxidants  in  remote
                                   65

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areas and to determine if the greater distances  between  cities  in  the
western part of the country decreases the oxidant  levels  in  remote areas.
Nijtrogen Dioxide
     An issue related to the attainment of national  standards  for  nitrogen
dioxide was the discovery, in 1973, that the routine ambient sampling
method for the pollutant was faulty.   The method generally indicated higher
than actual ambient levels of nitrogen dioxide.   Because  of  this finding,
the Agency proposed to reclassify 43 of the 47 AQCR's from Priority I
to Priority III.  This action was deemed appropriate since new  sampling
methods did not indicate an N02 problem throughout the nation  as had the
original method.
     On May 8, 1973, EPA finalized in the Federal  Register the  reclassi-
fication of 42 of the 47 Priority I AQCR's to Priority III.  Five  AQCR's will
remain Priority I, i.e., where air quality levels  are near or  above the
national standards.  These AQCR's include Los Angeles, Chicago, Baltimore,
Salt Lake City, and New York-New Jersey-Connecticut.  Additionally, a
limited amount of air quality data from the Denver AQCR  (Priority  III)
suggested that this AQCR may need to be reclassified Priority  I.   Additional
data are being collected by the Agency in these  areas.
     In those AQCR's which were reclassified Priority III and where the States
had previously adopted emission regulations calling for  control of NO  from
                                             '                       A
stationary sources, EPA will  favorably consider  States'  requests for plan
revisions that would rescind such regulations.
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ISSUES AFFECTING DEVELOPMENT  AND IMPLEMENTATION OF STATE  IMPLEMENTATION
PLANS
Maintenance of National  Ambient Air Quality  Standards
   As directed by a 1973 court decision,  EPA reviewed  its  initial  approvals
and disapprovals of State implementation  plans  regarding  the maintenance
of NAAQS.  The review indicated that no plans adequately  provided  for  the
continued maintenance of national standards  for a significant  time beyond
1975-77.  Consequently, EPA promulgated in the  Federal  Register on June 18,
1973, requirements that the implementation plans  provide  for both  indirect
source review and continued long-term maintenance of the  national  air
quality standards.  The regulations require in  part  that  SIP's identify
areas that may, as a consequence of current air quality and/or the projected
growth rate of the areas, have the potential for exceeding any national
air quality standard within the subsequent 10-year period.  EPA is to
publish, based upon the information submitted by the State, a  list of
potential problem  areas.  Each State is required to submit a  detailed
analysis of the impact on air quality of projected growth in  each  potential
problem  area  designated by the Administrator.  Where the analysis  indicates
that  an  area  will  not maintain the national standards, once attained,  for
the  following 10 years, the State must also submit a plan containing
measures to ensure the maintenance of the NAAQS  during the ensuing 10-year
period.  Furthermore, to ensure  the continued maintenance of  the national
standards, States  must  perform  the area identification-analysis-pian
development process  at  least  every  5 years.
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     During 1974,  EPA published  guidance to the States concerning the
process of problem area identification, analysis, and plan development.
Additional guidance will  be published  in early 1975.  EPA proposed a list
of potential problem areas  in the  Federal  Register on July 10 and August 12,
1974.  A total of 188 areas for  at least one  pollutant were proposed.  Of
these, 167 were for particulate  matter, 56 for sulfur dioxide, 29 for
carbon monoxide, 54 for photochemical  oxidants,  and  9 for nitrogen dioxide.
The  final area identifications are scheduled  to  be published  in  early  1975.
The  problem area analyses and plans are scheduled for submission to  EPA
later  in  1975.  If EPA determines  that a  potential problem  area  will not
attain a  primary national ambient  air quality standard  by the attainment
date,  EPA will issue a notice to revise the implementation  plan  for  both
attainment and maintenance.  In  this case, the maintenance  plan  would  not
necessarily be due in 1975, but  would be  due  on  the  date stated  in the
notice to revise the implementation plan.   Detailed  requirements for pre-
paring, adopting, and submitting air quality  maintenance plans are scheduled
for  promulgation in mid-1975.
Prevention of Significant Deterioration of Air Quality
     On May 30, 1972, as a result of a suit filed by the Sierra  Club,
EPA  was ordered by the District Court of the District of Columbia to
disapprove all SIP's which do "not prevent significant  deterioration of
air  quality"  in currently clean areas and to promulgate new regulations
which  would prevent signfficant deterioration.   The  District  Court order
was  appealed  to the Court of Appeals where it was affirmed, and  subse-
quently to  the Supreme Court, where it was affirmed  by  a tie  vote
                                  68

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 (June, 1973).  As a result of the initial court action,  all  SIP's  were
disapproved on Nov. 9, 1972, to the extent that they did not explicitly
"prevent significant deterioration."
     In the absence of firm judicial  or legislative  guidance as  to just
what constitutes significant deterioration and  what  are  acceptable means
to prevent such deterioration,  EPA solicited widespread  public  comment.
In order to establish  the conceptual  issues and assist in their resolution,
four alternative plans were proposed  in the Federal  Register of July 16,
1973.  The analysis of considerable public comment together  with several
contract studies and numerous interfaces with governmental agencies
at all levels (all of which extended  well  into  1974)  suggested  that an
allowable air quality increment concept was preferable.
     In response to a timetable for court compliance established in
mid-1974, EPA reproposed the favored air quality classification plan
for procedural and technical comment on August  27, 1974. The results
of the 30 day public comments were considered and further multi-agency
review was undertaken.  Some changes  were made  and the area  classification
plan was promulgated on November 27,  1974. The regulations  as  promulgated
would affect all new sources of 18 major types  commencing construction
after June 1, 1975.  However, both the Sierra  Club  and Dayton Power and
Light have petitioned for a court to review the details  of EPA's promul-
gation.
     EPA's activities on significant deterioration  in 1974 also included
the March 22 transmittal of a proposed amendment to  the  Clean Air Act
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which would eliminate any requirements to prevent significant deterior-
ation of air quality.  Although EPA did not support this proposal, the
Agency  believes that the significant deterioration issue should be
examined by th  Congress.   Because of the potential for further liti-
gation, the importance of this issue to our environment and our
energy problems, and the potential  impact of EPA's  regulations  on  State
and local  land use responsibilities,  EPA  has  encouraged Congress to explore
all alternatives for dealing with the significant deterioration issue.

Supplementary  Control Systems
     EPA proposed regulations on September H, 1973, for the use of
Supplementary Control Systems (SCS) and requested public comment.   This
proposal depicted SCS as a temporary measure applicable only to sulfur
oxide emissions from isolated non-ferrous smelters and coal-fired power
plants, where the sole alternatives are permanent curtailment df
production, closing of the plants, or delays in attainment of the standards.
The essence of SCS is to allow the pollution source, subject to certain
restraints, to cut back or modify  its operation as necessary to permit
adequate dispersion of air pollutants and thus avoid air concentrations
in excess of  national standards.   However, constant emission limitation is
the  preferred  strategy for attaining  and maintaining the standards  in  the
long  term.  SCS  is acceptable only as a  temporary measure  where its use is
necessary to  augment constant emission limitation techniques as determined  on
a case-by-case  basis, and only in  circumstances wherein SCS  can be  expected to
exhibit a high  degree of  reliability  and enforceability  and where the
emission  sources  can be  readily  and  unequivocally  identified.
                                  70

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     EPA is currently proceeding with the development of control  plans for
all affected non-ferrous smelters to correct the currently deficient State
plan and to satisfy the 18-month extension for submittal of a plan for
attaining and maintaining the secondary sulfur dioxide standard.   To date,
EPA has proposed regulations allowing the use of SCS at two smelters
located in Idaho and Nevada.  These regulations require the installation
of emission control equipment to the extent technically feasible  and further
state that SCS may be employed only  if certain conditions outlined  in the
regulations are met, and  its  use  is needed  to achieve national standards. Other
proposed regulations and the finalizing of the two proposals can  be
expected in the near future.
     A similar concept is being developed for application to specific
coal fired power plants which will alleviate some of the problems created
by the current deficit in low sulfur fuels as well as the extensive time
required to retrofit flue gas desulfurization systems on existing facilities.
 Indirect Sources
     In response to a court order requiring EPA and the States to take further
measures to insure maintenance of the National  Ambient Air Quality Standards,
EPA issued regulations requiring States to develop procedures to  assess  the
air quality impact of new facilities, such as shopping centers and sports
arenas, which could generate significant auto traffic,  i.e., indirect sources.
     Approximately seventeen States and territories have submitted such
provisions of which EPA has approved  six.  Indirect sources located in the
remaining 49 States or territories are subject to an EPA regulation promulgated
on July 9, 1974, following receipt of public comments pertaining  to a
February 25, 1974 proposal.

                                 71

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     On December 30, 1974, EPA suspended the effective date of the
 Federally promulgated provisions from January 1, 1975, to at least July 1,
 1975.  Thus, the Federal regulations will not be effective for facilities
 that commence construction prior to July 1, 1975 and perhaps later.

Tall Stacks
     EPA proposed regulations on September 14, 1973, limiting the use of
stacks taller than that consistent with "good engineering practice" as
a  control strategy measure except as part of an approved supplementary
control system.  This general concept was confirmed on February 8, 1974,
by a Court of Appeals opinion which stated that dispersion techniques could
not be employed as a substitute for available emission controls.
     Final regulations have not yet been promulgated to formally implement
this policy due to the difficulty in defining "good engineering practice
stack height" and "available control measures" applicable to all sources
on  a nationwide basis.  Extensive consultations and analyses have been
conducted, and regulations are expected to be published in  1975.

Clean Fuels Shortage
     Because of a known shortage of clean fuels (low sulfur fuels), the
Agency developed the Clean Fuels policy in November 1972.  Under this
policy, States were (and still are) encouraged to revise their adopted
emission regulations to permit the continued burning of any fuel from
established sources, provided that primary air quality standards are not
violated.  This action reduces the demand for the more scarce low sulfur
fuels in those locations where the primary standards are already being met,
                                  72

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thereby increasing their availability to other areas where severe
environmental problems exist.
     This policy relies on cooperative efforts by EPA and State
environmental agencies to extend compliance timetables for secondary
standards or to revise emission regulations where primary standards
would not be jeopardized.  This program has thus far resulted in 42
million tons of coal being made legally acceptable through revisions
in the sulfur regulations of SIPs.  EPA expects that an addition 70
million tons will be realized by July 1, 1975.
     The three procedures by which this policy are being realized are:
     1.  the revision of sulfur emission regulations in the applicable
         SIPs to permit the  burningof "air quality acceptable" coal,
     2.  the granting to applicable utilities variances permitting them
         to continue burninotheir present quality coal, and
     3.  the attainment of the secondary S02 standard (i.e., to protect
         for welfare effects)  at a reasonable date.
       To overcome any sudden shortages of acceptable clean fuels
  due  to strikes, embargo,  etc., the Agency established in October 1974
  procedures for the  processing of variance requests  (permitting the use
  of high sulfur fuels)  for all fuel types and  consumption sources.  Any
  variance would be  considered an SIP revision,  therefore,  requiring approval
  by the Administrator.  The  expedited  procedures  are  designed to assure
  expedited  action  on the requests, while  protecting  the  public  health and
  welfare.

  Energy Supply and Environmental  Coordination Act
        During  1974,  the  Agency  became  further involved with the  energy
  situation, primarily as directed by  Section 4 of the Energy Supply  and
  Environmental  Coordination  Act  (ESECA).  The Act requires EPA to review
                                     73

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each SIP with respect to fuel-burning stationary sources,  and to determine
if revisions can be made which would alleviate the fuels  shortage without
Interfering with attainment of any NAAQS or otherwise adversely affecting
public health.  Further, the Act requires the Agency to report to the
States on the SIP review findings.
     Although the ESECA is related to the "Clean Fuels Policy" it 1s  larger
In scope,  and therefore  requires a larger coordination effort with the
responsible State agencies.  The review of SIP's will principally address
total suspended particulate and sulfur dioxide emissions  relative to  the
achievement of both primary and secondary standards and will  focus on
emissions from power plants, very large industrial sources,  and area  sources,
Approximately twenty SIP's were reviewed in 1974 and the  remaining SIP
reviews are scheduled to be completed by early 1975.

In-Stack  Emission Monitoring for  Existing Sources
     When SIP's were first developed, it was the Agency's  position that
continuous in-stack emission monitoring systems were not  sufficiently
reliable to warrant their inclusion as part of the SIP requirements.   At
that time, States were required to have legal authority to require such
monitoring but were not required to implement that authority.  Since  then,
the performance and reliability of these monitors has improved such that
the Agency has now defined realistic minimum performance  specifications
for continuous monitors  for certain source categories.
     On September 11, 1974, the Agency proposed regulations  to require
continuous monitoring of emissions from the following source categories:

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     1.   Specified fuel-fired steam generators  of more  than 250
         million BTU per hour heat  input (particulates/opacity, sulfur
         dioxide, nitrogen oxides,  and  oxygen);
     2.   Nitric acid plants (nitrogen dioxide);
     3.   Sulfuric acid plants (sulfur dioxide);  and
     4.   Petroleum refineries'  fluid catalytic  cracking unit  catalyst
         regenerators (particul ates/opacity).
     The source categories were chosen  to  coincide with the development of
New Source Performance Standards (NSPS) since  the NSPS  are directed toward
the most significant stationary sources and more information  on the
performance of continuous monitoring equipment  is available for these
source categories.

Extensions for Developing and Implementing SIPs
     The Clean Air Act provides for extensions  of up to 2 years beyond
the 1975 goal for attainment of primary National Ambient Air  Quality Standards
in those AQCR's where needed technology or other alternatives either are not
available or will not be  available soon enough to attain the  primary standards,
At present, twenty-eight  AQCR's in sixteen States have been granted extensions
for attainment  of primary standards.  The majority of these extensions have
been granted in  the  latter part of 1973 primarily for those Regions requiring
transportation  control plans.  Therefore, these extensions mainly affect the
attainment of the carbon  monoxide and photochemical oxidant standards.  In
addition, many  States containing non-ferrous smelters have been granted
extensions for  attainment of the sulfur dioxide standards.  In fourteen of
                                     75

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the sixteen States granted extensions, EPA is required  to  promulgate
regulations and the extension was provided as part  of EPA's  control
strategy.
     The Clean Air Act also provides for 18-month extensions  for  submitting
plans for attaining secondary standards.   On May 31,  1972, EPA  granted
18-month extensions to 24 States involving 42 AQCR's  to  prepare control
strategies for the criteria pollutants for which secondary standards  have
been set, i.e., particulate matter and sulfur dioxide.   Thirteen  States
were required to submit particulate matter control  plans by  July  31,  1973.
Of these, plans for eight States, covering 16 AQCR's, have been submitted
to EPA.   Because of the announcement on May 12,  1973, that S02  secondary
standards might be revised, States had until January  30, 1974,  to submit
their S02 control  strategies.  Only three of the required  twelve  States
have submitted a plan for the attainment and maintenance of  the secondary
S02 standard.  The remaining plans for particulate  matter  and sulfur
dioxide are under development by EPA.   This includes  specific regulations
for control of sulfur dioxide emissions from non-ferrous smelters in  six
States (Nevada, New Mexico, Montana, Utah, Arizona, and  Idaho)  where
extensions were not requested by the State but were provided  by EPA.
Court Actions on Variances
     As a result of suits filed by the Natural Resources Defense  Council
(NRDC),  the First, Second and Eighth Circuit Courts have held that
source compliance dates could be deferred through the mechanism of a
State-issued and EPA-approved variance or enforcement order  but only  up
to the attainment date for meeting the primary ambient  air quality standards,
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In most instances, the date for meeting the primary standards  is  July 31,
1975.  However, in some air quality control regions (AQCR's),  primary
standard attainment dates have been deferred up to two years  through
extensions granted under authority of illO(e) of the Act.
     When the same issue was brought before the Fifth Circuit  Court,
this Court held that lllO(f) of the Act is the exclusive means of
postponing a compliance date even where the postponement does  not go
beyond the date for meeting the primary standards.  The Agency believes
that compliance date deferrals which do not go beyond applicable  attainment
dates should be treated as plan revisions, and should not be  subject  to
the procedures of illO(f).  Upon request by EPA, the Supreme  Court stayed
the Fifth Circuit's decision until it completes a review of the decision.
Although final Agency action must await the outcome of this review, the
proposed regulations for the six States within the Fifth Circuit  jurisdiction
are those the Agency intends to promulgate should the Supreme Court reverse
the Fifth Circuit's decision.
     From a technical standpoint, the opinions of the three circuit courts
referred to above can be treated as applying only to those States which
are within the jurisdiction of these courts.  However, when three appellate
courts uniformly resolve an issue which is common to every State, the
decisions of the courts constitute strongly persuasive guidance for
Agency action in all States.  Therefore, on September 26, 1974, EPA
published disapprovals for all States having postponement authority in-
consistent with the terms of 40 CFR Part 51 and proposed substitute
regulations for those disapproved plans.
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 Review  of  SIPs for Reasonableness
     Three separate court cases, involving challenges of the reasonableness
of regulations contained in SIP's approved by EPA,, resulted in the ruling
that EPA must consider technical feasibility and economic practicality when
 approving  SIP regulations. In the future, EPA policy will be to consider avail.
 ability of technology, economic practicality/vagueness of definitions or test
methods, and adequacy of compliance time in determining the enforceability
and approvability of SIP regulations.
     Other court cases have stated that EPA has  the duty to disapprove
State statutes and regulations which are submitted by a State as part of an
SIP,  but which fail  to meet Clean Air Act requirements or which have no
relationship to the attainment of the NAAQS.   The Courts pointed out that
if there were a class of regulations or laws  submitted by the States which
EPA took no action to disapprove, the result  would be substantial  confusion,
unnecessary litigation, and a hampering of EPA's enforcement efforts.
Because it is critical that the SIP as finally approved sets forth precisely
what is required, it will be EPA's policy to  specifically identify those
measures submitted by a State which are related  to attainment of the
National ambient air  quality standards and are therefore part of an
approved implementation plan enforceable by EPA.
                                     78

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VI.  STATUS OF AIR MONITORING AND TRENDS IN AIR QUALITY
     The State air pollution control  agencies have been delegated the
responsibility to install  adequate air monitoring networks for criteria
pollutants (those for which air quality standards have been set), as  part
of the State Implementation Plan (SIP) process.
     EPA bases its assessments of national  air quality to a major extent
on the data submitted from these networks.   The States submit their data
to EPA's data storage and retrieval  system.  Summaries are then compiled
of both the status of air quality with respect to Federal standards and
the current scope of the composite national monitoring effort.  In addi-
tion, companion computer files of data on point source  and area emissions,
plus meteorological data afford researchers within EPA and outside a
sophisticated tool for investigating these complex influences on air
quality.  As of mid-1974, EPA's data bank contained information from  over
6000 air monitors, and emission data on some 77,700 point sources and
3,300 (counties) area sources.
     Before the formal status of compliance with a standard can be con-
ferred on an Air Quality Control Region (AQCR), a reasonable history  of
data (at least one year) must be compiled from a representative network
of monitors.  A single station, reporting two values or an annual mean
over a standard, is sufficient to document a violation; compliance must
usually be demonstrated by more extensive evidence from a multiple-
station network.  The target date for completing these networks was,
in most cases, July 1974.  Table 8 summarizes the progress made by the
states through 1973 in completing the networks obligated in their SIP's.
The picture of the nation's air quality status with respect to standards
                                      79

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remains partially incomplete to the extent that some areas  were as  yet
unmonitored or incompletely monitored when these summaries  were prepared.
     The number  of AQCR's reporting violations of standards is   summarized
in Tables 9 through 12.
     Table 9, for suspended particulate matter, shows the number of AQCR's
in each Priority Classification (I = substantial problem, II  = moderate
problem, III = minor problem).   The second column shows  the number  of
AQCR's reporting at least a bare minimum of analyzable data ,  namely 75% of the
scheduled measurements  for at least one quarter from one or more stations.
(The differences from the Priority Class totals in the first  column are
the numbers of AQCR's reporting no  usable data for 1973, as  of June 1974).
The next column shows the number of reporting stations within an AQCR
that violated the 24-hour particulate standard  (a primary or health related
standard).  The next column shows the number of AQCRs that have reported
data for a  full year from one or more stations  in 1973, thus  affording at
least  a tentative appraisal of the annual  (primary) particulate standard.
The final column shows how many of these AQCRs  reported one or more stations
violating the annual  standard for particulates.  As indicated above, the
complementary group of AQCR's whose reported data include no  violations will
not be conferred the status of compliance until sufficient  data have been
reported, subsequent to the network completion date of July 1974,to appraise
the adequacy of each AQCR's network coverage.
     The diagrams at the bottom of Table 9 portray the distribution of the
AQCR's in each Priority Class above and below the particulate standards.
This analysis is based on data  from  stations in  AQCR's reporting the highest
second maximum daily value or highest annual mean.
                                      80

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     TablelO presents a similar summary of sulfur dioxide (S02)  data
for 1973.
     Tablesll and!2 summarize AQCR status for carbon monoxide (CO)  and
ozone/oxidants (Ox), respectively.  Note that, for these two pollutants,
there are only Priority Classes I and III, and that the Priority III
AQCR's are not required to monitor for these two pollutants.  However, a
number of states have elected to install monitors in some Priority  III
AQCR's and many of these stations are recording values exceeding the  CO
and oxidant standards.
     If a comparison were to be made with these corresponding tables  in
last year's report, it would appear that the number of AQCR's violating
standards for each pollutant had increased this year.  However,  these
AQCR totals are not yet a reliable measure of changes in air quality
because the coverage of monitoring networks is still expanding and
improving.  More stations reported data in 1973 than in 1972 (see Table 13);
still more can be expected when the 1974 summaries are complete.  It  can
also be expected that some of these additional stations may reveal
additional violations in areas not previously monitored.
     To discuss trends, a selected group of stations consistently reporting
data over a period of years must be examined.  That analysis is  discussed
in the next section.
                      AIR QUALITY TRENDS:  1970-1973
     All the data used in this analysis are from the National Aerometric
Data Bank which is comprised of State and local data submitted to EPA
along with data  from the Federal networks.  National and regional  trends
                                       81

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 are  examined  for  total suspended participate  (TSP) and sulfur dioxide (S09),
 while  trends  in specific geographical areas are examined for oxidant (0 )
                                                                       ^
 and  carbon monoxide  (CO).
      In order to  be  selected, a site had to have  valid data for a year for
 TSP  and S02,  at least a valid quarter per year for CO and at least a
 valid  third quarter  per year(summer season) for Ox.   For TSP and S0«
 non-continuous sampling instruments, a valid year of data is defined as
 a year of data with  4 valid quarters, where a valid quarter must have a
 minimum of five samples.  If no samples are collected in one month, neither
 of the other  two  months in that quarter may have less than two samples
 reported.  For 0  , CO and SO/> continuous sampling instruments, both a valid
                n           £
 quarter and valid year must have at least 75 percent of the total  number
 of possible observations.  Finally.to be included in this analysis a site
 had  to meet these criteria in either 1970 or 1971 and 1972 or 1973.  There
 are  984 sites meeting the requirements for TSP, 213 for S02, 66 for CO
 and  28 for 0  .  The  reason for the extremely limited data base  for CO
            A
 and  0  is the fact that many States have not had monitoring networks in
     A
 operation for these  pollutants until this year.
     For purposes of making regional comparisons in TSP and S0« the
 nation was divided   into   five geographical areas:  Northeast, South,
 North  Central, Midwest and West.  In terms of EPA Regions, the Northeast
 consists of EPA Regions I, II and III, the South is EPA Region IV, the
 North  Central  is EPA Region V, the Midwest consists of EPA Regions VI,
 VII and VIII and the west consists of EPA Regions IX and X.
National  and Regional Trends in Total  Suspended Particulates
     As demonstrated in Figure 1, the trend in TSP is downward for the
 national  composite of all  stations and in each of the geographical areas

                                      82

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 examined  during  the period  1970 to 1973.  The decreasing trend is also
 evident when  the 1970-1971  time period is compared with the 1972-1973 time
 period.   Using the averages for these two time periods, it was found that
 45% of the sites exceeded the primary annual mean standard in 1970-1971
 compared  with 32% in 1972-1973.  This general improvement was also reflected
 in a 14%  decline (from 77.9 ug/m3 to 66.7 ug/m3) in the national composite
 average during this time period.  Interestingly enough, the composite
 average of the second highest values showed a 15% decline (from 202.3 ug/m3
 to 171.1  ug/m )  in this same period which is quite comparable with the
 trend in  average levels.  Of course, for a specific site the percent decline
 in annual average level may not be as closely matched by a corresponding
 decrease  in the  peak value because the latter is more subject to temporary
 influences "f atypical meteorology and emissions.  There were 35 background
 sites used in the trend analysis, and these showed a slight decline due
 primarily to decreases in the Midwest.
 National  and Regional Trends in Sulfur Dioxide
     As with TSP, the predominate S02 trend is downward in the nation
and in the geographical areas during the period 1970-1973{Figure 2).  These
 low levels of S02 generally result from  the  successof control measures for
regulations on the sulfur content of fuels, strong enforcement practices ,
and fuel  switching to cleaner fuels.   In contrasting the T970-1971  period
with the 1972-1973 period, the composite average shows a 25% decline (from
         3             3
36.8 ug/m  to 27.5 ug/m , while the composite average of the peak values
shows a 26% decline (from 175.6 ug/m3 to 130.3 ug/m3).  Therefore, as for
TSP, there is good agreement between the trends in composite averages and
composite peak values.  Only 10 background sites satisfied the validity
criteria and these showed no predominant pattern.
                                       83

-------
 Trends in  Oxidant
      Most of the  sites measuring  oxidant which were able  to meet our
 minimum data requirement  are  located  in California.   Essentially three
 areas were examined:  Coastal  Los Angeles,  Noncoastal  Los Angeles and the
 San  Francisco Bay Area.   Figure 3 presents  the yearly trend in the composite
 average of the second high  one hour oxidant values.   The  Coastal Los Angeles
 sites were the only sites which showed a sharp increase in the composite
 average of the second high  value.  The California Air Resources Board
 attributes this to adverse  meteorological conditions  in 1973.
      The general  improvement  seen in  the Noncoastal Los Angeles area, the
  an  Francisco Bay Area and  the Coastal Los  Angeles area prior to 1973 can
 be explained in part by the reduction in total hydrocarbon emissions.
 Trends  in Carbon  Monoxide
      Carbon monoxide trends are presented for four groupings:  Los Angeles,
 New  Jersey, Washington State  and  U. S. Remainder.  As can be seen in
 Figure  4,  the percent of  values above the eight hour  standard has generally
 declined in each  of the groupings.  The progress seen in  the reduction  in
 the  percent of values above the eight hour  standard can be attributed in
 part to the success of the  Federal Motor Vehicle Emissions Control Program.
Monitoring Implications of the Energy Supply and Environmental
Coordination Act (ESECA)                   '         ~	
      Fossil  fuel  fired electric  generating plants and other major  fossil
fuel  users are being encouraged, where  feasible to convert from oil or
gas to coal.  Adaptability of the equipment  is, of course, an essential
element of this feasibility.  The Act provides that air quality in the
area  shall also be a guiding determinant of  whether the fuel conversion
                                       84

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should be made, and if so, then the nature of the emission control  equip-
ment that may be required.  EPA is considering the possibility of requiring
the owners or operators of those facilities that are granted suspensions
or compliance extensions to install sulfur dioxide monitors around such
facilities and to report the resulting data to EPA.  These data would
supplement the state and local monitoring network data in EPA's evaluations
of AQCR compliance, progress toward compliance, or potential deterioration
of air quality.
                     MONITORING STRATEGY AND METHODS
     In addition to the supplemental monitoring to be required of specific
point sources, under ESECA, EPA is evaluating modifications to the recom-
mended monitoring strategy employed by state and local agency networks.
Growing experience in interpreting the existing data, plus concerns over
newly emerging aspects of the nation's air pollution picture recommend
more comprehensive monitoring in three principal categories:
     1.  AQCR's classed Priority III for CO and oxidants.  Originally,
an AQCR that was classed Priority III for one of these pollutants was not
required to monitor for that pollutant.  As remarked in a previous section,
some states have elected to place CO and/or oxidant monitors in some
Priority III AQCR's and a surprising number of these monitors are recording
violations.  The Environmental Protection Agency is recommending that
urbanized areas with a population greater than 250,000 in AQCRs that are
Priority III for one or both of these pollutants install  at least two
monitors for one or both pollutants.
                                       85

-------
     2.   In AQCR's where discrete sample monitors (hi-vols and 24-hour
SOp bubblers), operating on the prescribed every sixth-day schedule report
one value over the corresponding 24-hour standard, there is a substantial
probability that the standard was in fact exceeded a second time, consti-
tuting a violation, on one of the intervening, unmonitored days.  In
these borderline cases, EPA recommends that the sampling schedule at
such sites be increased to every third day.  This increase in measurement
frequency will substantially improve either the probability of detecting
actual violations or the confidence with which the status of compliance
is assigned.
     3.  Recent evidence of elevated oxidant concentratiops in rural areas
lead EPA to recommend inclusion of nonurban oxidant monitors in monitoring
network plans.  These data will help to establish the origin and fate of
those high oxidant concentrations.
Status of Nitrogen Dioxide Monitoring
     The reference method for nitrogen dioxide (NCL) has been found to be
inadequate.   Subsequent to the revocation of the original reference method
for measuring ambient N02 concentrations, eight other candidate methods
have been evaluated.   As the study of these candidate methods nears its
conclusion,  it is apparent that the chemiluminescence method will be named
the reference method.  Two other methods, the TGS and the sodium arsenite
methods,  are likely to be named as acceptable equivalent methods.  When
these method selections are formally confirmed, a report will be prepared
reviewing AQCR status in the light of available current data.
                                       86

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                     TABLE  8   National  Summary  Of Air  Monitoring  Stations
                               Reporting 1973  Data To The National Aerometric
                               Data Bank,  June 1974
          Stations  registered
          with EPA:   1973
               SIP  Stations:
               Others:
                     TOTAL:
                                  TSP
3022
 569
3591
          Continuous
350
 72
422
           Bubbler
1104
 402
1506
           CO
238
 60
298
216
 36
252
         Obligated baseline
            SIP  stations:
3512
698
1434
457
455
oo
          Total  stations
          reporting at  least
          -one valid quarter;
          -valid annual data:
3390
1306
250
 51
1385
 394
213
 62
188
 52

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          TABLE  9.  National Summary of AQCR Status  Versus
                           Particulate Standards, 1973
                     AQCRs Reporting   AQCRs       AQCRs  Reporting    AQCRs
Priority   Number     At Least One   Exceeding       At  Least One   Exceeding
  Class   of  AQCRs  Station-Quarter  24-hr. Std.   Station-Year    Annual Std.
                                                           92             66
                                                           50             23
                                                           30             10
I/IA
II
III
120
70
57
118
66
41
83
16
16
  Total
247
225
115
172
99
RATIO TO
STANDARD
> 3.0
2.51 • 3.0
2.01 • 2.5
1.71-2.0
1.41 -1.7
1.21 -1.4
1.11-1.2
1.01 -1.1
0.91 • 1.0
0.81 • 0.9
0.61 • 0.8
0.31 • 0.6
<0.3
1
-n" 1
114
18
In
117
__Jio
[6
=£,
112

0
PRIORITY
II
0
ll
U3
It
J2
~J4
I
A
122
lie
|2
III
0
i
J2
0
~|3
~J4
Ss
nil
|6
1»
l»






24-hour
STANDARD




                             a. SECOND HIGH 24-houf VALUE
                                    PRIORITY
       RATIO TO
       STANDARD
>3.0
2.51-3.0
2.01-2.5
1.71-2.0
1.41-1.7
1.21-1.4
1.11-1.2
1.01-1.1
0.91-1.0
0.81 • 0.9
0.61 • 0.8
0.31 • 0.6
•< 0.3
1
"l
=8
16
16
	 JW
19
111
ft
0
0
0
0
^
19
—^
18
112
J'
0
0
0
0
l2
J3
J3
fi
PRIMARY ANNUAL MEAM
STANDARD
*~
                            b. MAXIMUM ANNUAL MEAN VALUE

-------
          TABLE  10.  National Summary of  AQCR Status Versus
                          Sulfur Dioxide  Standards, 1973
                     AQCRs Reporting
Priority    Number   At Least One
  Class    of AQCRs  Station-Quarter
 AQCRs
Exceeding
24-hr. Std.
AQCRs Reporting
  At Least  One
 Station-Year
 AQCRs
Exceeding
Annual Std.
I/IA
 II
III

Total
 60
 41
146
247
                           55
                           35
                           97

                          187
    12
     4
     1

    17
      33
      24
      43

     100
     8
     2
     0
    10
                                  PRIORITY
RATIO TO
STANDARD
> 3.0
2.51-3.0
2.01 • 2.5
1.61-2.0
1.31-1.6
1.11 -1J
1.01-1.1
0.91-1.0
0.81 - 0.9
0.61 • 0.8
0.31 • 0.6
«S OJ
1 II III
'
Jl
U

[l
16
112
119
0
0
I',
0
0
n
0
0
ll
113
117
o 	
0
0
0
0
0
uo
Tl
•^3
^7
- 	 - 	 U 185


PRIMARY 24-hour
STANDARD





                           I. SECOND HIGH 24-hour VALUE
                                 PRIORITY
RATIO TO
STANDARD
> 3.0
2.01 • 3.0
1.71-2.0
1.41 • 1.7
1.21 • 1.4
1.11 -U
1.01 -1J
0.91-1.0
0.81 • 0.9
0.61-0.8
0.31-0.6
1 I' III
1
1
1
1
0
0
3,
113

0
0
0
0
0
0
12
0
\
114

0
0
0
0
0
0
0
0
0
0
	 17
	
ANNUAL MEAN
STANDARD

                          b. MAXIMUM ANNUAL MEAN VALUE
                                        89

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             TABLE 11.  National Summary of AQCR Status  Versus

                          Carbon Monoxide Standards,  1973
                      AQCRs  Reporting
Priority     Number      At  Least One
  Class     of AQCRs  Station-Quarter
    I

   III

  Total
 30

217

247
26

34

60
  AQCRs
Exceeding
1-hr. Std.

     9

     1
  AQCRs
Exceeding
8-hr. Std.


    25

    28
    10
    53
                                    PRIORITY
               RATIO TO
               STANDARD
1.21 -1.5
1.01-1.2
0.81 -1.0
0.61 - 0.8
0.31 • 0.6
^0.3
_ 1
1
|7
^
0
0
11
14
HI
117
11
1-hour
STANDARD

              RATIO TO
              STANDARD
                             a. SECOND HIGH 1-hour VALUE
                                   PRIORITY
> 3.0
2.01 - 3.0
1.51-2.0
1.21 -1.5
1.01 -1.2
0.81 • 1.0
0.61 • 0.8
0.31 - 0.6
<; 0.3
[4
)ll
18
1
1
0
0
ll
0
0
— \1
111
^
t
T)
0


8-tiour
STANDARD

                              b.  SECOND HIGH 8-hour VALUE
                                    90

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          TABLE 12.  National Summary of AQCR Status  Versus  the

                        Oxidant Standard, 1973
Priority
  Class
  Number
of AQCRs
AQCRs Reporting
  At Least One
Station-Quarter
AQCRs Exceeding
 1  hr. Standard
    I

   III


  Total
    55

   192


   247
       41

       16


       57
       39

       12


       51
                                   PRIORITY
              RATIO TO
>4.0
3.01 • 4.0
2.01-3.0
1.51 -2.0
1.21-1.5
1.01-1.2
0.81-1.0
0.61 - 0.8
0.31 - 0.6
<0.3
5
]7
jio
[7
u
J2
0
0
0
0
0
Ti
12
>
I?
0
0




1-hour
STANDARD



                                   91

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Table 13. Growth in Number of Monitoring Instruments,3  1970-1973
so2
Year
1970
1971
1972
1973
Participate
1345
2099
3033
3591
(Continuous)
107
223
335
422
(Bubblers)
332
596
1080
1506
CO
82
171
241
289
Ox
53
9S
181
252
aBased on stations registered with E.P.A.;  some  are  not yet  reporting
 comprehensive data.
                             92

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to
1WV
90
10
70
W
SO
40
30
CONCENTRATION, ft-t/t?
S S S » 5 3
70
60
SO
40
30
20
10
0
1111
~~ NATIONAL COMPOSITE ~~
— *"-^~^»^ —
- ^^-^» 9 -
— NATIONAL SITES ~~
— _.
— —
- * * 	 * 	 • —
_ 35 BACKGROUND SITES
1 1 1 1
1 1 1 1
NORTHEAST ~"
^^— MM
~ *^-- -^
^ 	 •
— » •«
^^ ^MB
^^ ••••
^^ -^^Ml
MV i^^H
i i r i
1 1 1 I
~" SOUTH ~~
— •— 	 »^^^ -
_ * 	 • -
— —



1 1 1 1
*
J NORTH CENTRAL 1
- ^^\^__^ -
— ~~
— —
— —
— —
— —
1 1 1 1
I I i I
MIDWEST
•^^ ^M^
~ *^^^

^^•> ^B**
^^» ••>•
•^•H ^^B*
^™* ^KHB
1 1 1 1
I 1 1 1
*E5T
^^— ^M«


	 —
	 	
_ _
1 1 1 1
70 71 72 73 70 71 72 73 70 71 72 73
                                                                                   YEAR
                                           Figure 1  . National and regional trends in total  suspended paniculate. 1970 - 1973.

-------
vo
-p.
100
90
80
70
60
SO
40
30
"»e 20
"i*
* 10
^ inn
3 90
o
0 SO
70
60
SO
40
30
20
10
0

III
NATIONAL COMPOSITE
— _
— 	
— —
*^^__^
__ NATIONAL SITES
, *~^___-
| 10 BACKGROUND SITES |
1 1 1 	 1 	
NORTH CENTRAL ~~
— 	



riii"

i i i i
—~ -_
NORTH EAST
— — _
•~ . — —
— —
•
~ *^*\_


1 1 1 1
1 1 1 1
MIDWEST ~~
— —

"^ 	

*~^~~*^-^^
1 1 1 1
I 1 1 1
SOUTH




L_J 	 i 	 i i
i i i i
WEST ~~
— —
• 	 41 -41 • —
	 1 	 I_ 1 1
                            70
71
72
                                                        73
                                                                          70
                                                                                                     73
                                              71        72
                                                  YEAR
             Figure  2.  National and regional trends in sulfur dioxide. 1970 - 1973.
                                                                                                                       70
                                                                                  71
72
                                                                                                                                                  73

-------
   (00
   700
    600
LLJ
0
    500
   400
    300
                                          NON COASTAL LA. (5 SITES)


                                               COASTAL L.A. (4 SITES)
                                                                  BAY AREA (6 SITES)
                                                                  • A
                     70
71
72
73
                                           YEAR
          Figure  3 .  Composite averages of second high annual 1-hour oxidant

          values (or various areas within California.
                                         95

-------
   II
   It
   14
   12
   10
   8

I!

I;
• . *  v
i        i       n        r
       LOS ANGELES
                  T—i—i—-r
                           NEW JERSEY
(CENT OF VALUES
; s si s
10
i
6
4
2
0
1 1 i 1
— WASHINGTON STATE —
— —
— —
— —
~ * '^•^^^ -
— —
1 1 1 1
           70
       71      72
          YEAR
73
70
                                                             I        I
                                                            REMAINING U.S.
71       72
   YEAR
                                                                             73
     Figure  4 . Annual average percent of values above the 8-hour carbon monoxide standard
     for selected areas, 1970 • 1973.
                                          96

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VII.  THE DEVELOPMENT OF NEW AND IMPROVED AIR POLLUTION CONTROL TECHNIQUES
               STATIONARY SOURCE AIR POLLUTION CONTROL
      The development and demonstration of stationary source air pollution
control technology is one of EPA's largest tasks.  Approximately $28 million
were spent on this activity in FY '74.  Seventeen million dollars was pri-
marily for on-going programs to demonstrate control methods for sulfur and
nitrogen oxides, participates and other pollutants.  Over eleven million
dollars (energy supplement) was to expand the programs to respond to the
control technology research and development required by the accelerated
development of energy resources in the United States.
      The purpose of these activities is fourfold:
      -  To describe at least one method of control for each major
         source of pollution.
      -  To provide a technical base for EPA enforcement activities.
      -  To establish technical and economic data  to  support New
         Source Performance Standards  (NSPS).
      -  To provide  information required to make environmentally
         sound decisions  on energy  development  policy.
                                  97

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Sulfur Oxides
     The emphasis of the SOX control program has been on demonstrating
4 methods of flue gas cleaning which are applicable to new, existing,
and future coal and oil-fired utility and industrial combustion units.
The four control systems are:
      -  A wet lime/limestone scrubber at the TVA Shawnee steam plant
         at Paduca, Kentucky.
      -  A magnesium oxide scrubber at Boston Edison's oil fired
         Mystic Station, Everett, Massachusetts.
      -  A catalytic-oxidation scrubber at Illinois Power System's
         Wood River Station.
      -  A sodium-Ion scrubber (Wellman-Lord) at Northern Indiana
         Public Service  Company, Gary,  Indiana.
      On  the  basis of this and other work, EPA has concluded  that demon-
 strable  control technology does  exist for SOX emissions  from utility plants.
 Completion of  these demonstrations  will advance the technology closer to
 the maturity level so that it is routinely applicable.
      In  addition to utilities, smaller  industrial and commercial sources
 make  a significant contribution  to  the  ambient SOX  problem.  Additional
 emphasis will  be placed  on the developing SOX control technology for these
 sources.
      Lime and  limestone  flue-gas scrubbing processes produce a  sludge
 by-product that creates  a disposal  problem.  Work has been  initiated to
 assess existing techniques and develop  technology to stabilize  these sludges
 for environmentally sound disposal  and  to find uses for these  by-products.
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      A second technique to reduce the sulfur oxide emissions is to re-
move the sulfur from the fuel prior to combustion.  EPA is supporting
research in this field particularly in coal-cleaning methods and fuel
oil desulfurization.  Feasibility studies have been completed for several
fuel cleaning processes and demonstrations are being planned.  The Energy
Research and Development Agency will now have lead agency responsibility
for fuel cleaning research and development.  EPA will continue supporting
research in environmental assessment and control technology.
      A third technique in the SOX control strategy is combustion process
modification.  This is the modification of the combustion process which
will reduce both sulfur oxide emissions and nitrogen oxide emissions.
Several processes are under consideration, including fluidized bed com-
bustion and submerged combustion.  The Energy Research and Development
Agency will also have lead agency responsibility for fluidized bed
combustion.  ERDA, EPA and other agencies have developed a National
Fluidized Bed Program which will be supported by EPA.
Particulates
       The control technology for large particulates  is fairly well
 developed; therefore EPA efforts are mainly concerned with  Research
 and Development for control of  fine particulates,  that fraction  of  the
 particulate emission smaller than  3 micrometers.   These small particles
 remain suspended in the atmosphere and are easily  respirable and
 absorbable into the body.   Fine particulates may contain  toxic  trace  metals
 and sulfates, each of which has considerable impact on health.   Control
 technology for fine particulates is seriously deficient.  Current EPA
 efforts center on developing adequate devices and  on field  testing  as well
                                      99

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 as development of control  methods.
       EPA is working both  to improve and demonstrate already available
 collection for fine particulate control  devices and to identify and
 ultimately demonstrate novel devices.
Nitrogen Oxides
      Combustion modification is the only demonstrated method for control
of NOx emissions from fossil fuel burning.  Tests of flue gas treatment
techniques have shown little promise to date.  Presently, the application
of combustion technology will allow NOX emissions from gas and oil-fired
utility boilers to be controlled to the NSPS that have been set for these
fuel categories.
      EPA programs for combustion modification to control NOX include:
           o  Air/fuel mixture control  (low excess air combustion)
           o  Staged combustion
           o  Boiler component design
Other Pollutants
      National Emissions Standards for Hazardous Air Pollutants (NESHAPs)
have been set for mercury,  asbestos, and beryllium.  Other materials which
are considered pollutants but for which standards have not been set include
trace metals, polycyclic organic matter (POM) and miscellaneous hydrocarbons,
fluorides, odors, etc.  In general, control technology research efforts are
necessary for these materials.
      One current goal of the Air Technology Program 1s to characterize the
major sources and the specific chemical and physical properties of trace
metal emissions.  This 1s a necessary first phase In the development of
control systems.
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      Several tasks are being funded for field testing coal-fired utility
and industrial boilers, and for limited source characterization of gas-
and oil-fired units.  A field testing program is also planned for residential
and commercial heating units.
      In addition, control technology development is planned for certain
chemical processing sources.  These include the zinc compounds Industry, a
significant source of metallic particulates, and the glass industry, which
emits large quantities of arsenic, fluorides, and fine particulates.
      Efforts are underway to establish control techniques both for open
sources and for selected closed sources of asbestos.  The key sources in-
clude mining, milling, and manufacturing sites; the latter source tends to
be located predominantly in urban areas and contributes substantially to human
exposure to asbestos.  The objective of the efforts is to develop and demonstrate
control technology for handling, unloading, and disposal operations, 1n
addition to demonstrating the operation of a specific methodology for
controlling closed sources of asbestos in manufacturing operations.  This
work is undertaken to supplement control via NESHAPS, since their effectiveness
1s still unknown.
      In control of mercury, an effort 1s being undertaken to remove
mercury from waste gases containing SOX (such as those gases derived from
combustion and nonferrous metallurgical sources) via a combined SOX and
mercury control system.  Because both of these substances come from
combustion sources, it would be highly useful to have a single system that
could effectively control both.
      Current methods of POM detection and analysis are generally complex,
costly, and time-consuming.  Also,  it is unknown to what extent  POM may

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actually be emitted as a gas which condenses  to a  participate  substance,
rather than emitted as a particulate.   There  is, in  addition,  a  problem
in obtaining quantitative data on POM  emissions, whether  in  particulates  or
gaseous form.  In situ methods for measuring  POM and determining its
characteristics are required, as well  as techniques  for upgrading combustion
processes to avoid POM formation.  The air program will focus  attention on
these problems.
      EPA has begun to develop control systems through the pilot plant
stage of development for the following sources—aerylonitrile  plants,  refinery
crackers, asphalt roofing plants, and  ethylene dichloride plants.
                                       102

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VIII.  THE DEVELOPMENT OF INSTRUMENTATION TO MONITOR EMISSIONS  AND
       AIR QUALITY

    Methods for the quantitative detection of pollutants  in air are
essential to EPA's abatement and control  program.   Initially, methods
are needed to determine the extent and causes of a pollution problem
and in  investigations of the health and welfare effects  of the
pollutants.  When standards are promulgated, reference or compliance methods
must also be promulgated, for determining achievement and maintenance
of the standards.  Furthermore* implementation plans call for determining
ambient air quality levels and stationary and mobile source emission levels.
For these applications, the methods and associated devices employed must
be low cost, reliable, and capable of unattended operation or use by
relatively untrained  personnel.
     In the area of air quality measurements  technology,  the major problems
relate to  the  reduction  in cost to allow more economical deployment in
monitoring networks and  to improve sensitivity  for  use in  background
locations.   For source emissions, the major  problem is that of  the  proper
interfacing  of instruments with the  source  so as  to allow  representative
samples  to reach  the  instrument.  There  is  also the time-consuming  and
expensive  problem of  evaluation on  all  relevant sources, since  inter-
fering substances and conditions  vary  from source to source.   Source
emissions  measurements  technology is still  in a developmental  stage.
                                103

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                        MONITORING DEVELOPMENTS

Equivalency
    On October 12, 1973, EPA published in the Federal  Register a notice
of proposed rule making for determining equivalence of ambient air
monitoring methods.  When finalized, the proposal  will establish require-
ments and procedures applicable to determinations as to whether methods
for sampling and analyzing the ambient air may be designated "equivalent"
to the established'"reference methods."
    During 1974 the equivalency document has been reviewed and revised
by the Steering Committee and the Office of Management and Budget.
Concurrence is expected soon and, following this, publication in the
Federal Register is anticipated.
Source Emission Measurement
    During 1974 performance specifications and test procedures were
developed for SOX, NOX^ and opacity monitors.  A stationary source
simulator test facility was constructed for the purpose of evaluating
measurement methods for gas and particulate emissions.  New instrument
developments included: an X-ray fluorescense multlspectrometer system; a
prototype continuous monitor for mass vs. size distribution of particulates
(range 0.1 to 10 urn diameter); an automated procedure for the analysis of
sulfate emissions from vehicles; an objective quantitative method for
diesel odor assessment; and a gas correlation Instrument designed and
built for measuring the low levels of carbon monoxide associated with
well controlled vehicles.
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Ambient Air Measurement
    The X-ray fluorescence unit developed in 1973 has been successfully
operated to analyze up to 35 elements in several  hundred ambient air
aerosols.  The concept of the size selective sampling of particulates
presented in the 1973 report has been pursued with the development of a
prototype dichotomous instrument.  Routine field use of this type of
Instrument will be investigated.
    New, highly sensitive instrumentation for the primary pollutants
carbon monoxide and sulfur dioxide and the secondary pollutant N02 was
developed.  These instruments are currently being evaluated.  A
chemiluminescence technique for detection of the alleged carcinogen
vinyl  chloride has been developed as a laboratory prototype and is being
fabricated for monitoring applications.  Laser techniques for monitoring
over distances of one kilometer have been used for the first time in
a regional air pollution study.
                            QUALITY CONTROL
    A quality control strategy was adopted by the Environmental Protection
Agency  in February 1973.  Its goal is to  improve and document the quality
of all  environmental measurements, ensuring that data collected by EPA,
contractors, or State and local agencies  have the highest validity.  The
program incorporates five major functions:  1) standardization of measure-
ment methods, 2) distribution of standard reference materials, 3) pub-
lication of procedures and guidelines, 4) evaluation of on-going
monitoring activities, and 5) training and technical assistance.
                              105

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    Standard measurement methods have been established for the  regulated
ambient air pollutants, and testing of systems  required for measuring
source emissions has progressed on schedule.  Measurement methods  pursuant
to Section 304(g) of PL 92,500, "National  Pollution Discharge Elimination
System," are undergoing performance testing.  Repositories of standard
reference materials have been established  for ambient air and water,
pesticides, radiation, and lead in fuels.   A  number of quality  control
guidelines manuals are now available for air, water, radiation, and
pesticides measurement.  Training in the use  of quality control guidelines
and calibration standards is proceeding on schedule.  A pilot project  is
underway to automate routinely used instruments at four EPA laboratories
by means of minicomputers, and a prototype Regional laboratory data
measurement system has been developed.  Inter-laboratory performance  testing
programs have been initiated for measurements in air, water, pesticides,
and radiation.  On-site evaluations of all EPA  monitoring laboratories
were initiated in April 1974, and 7 Regional  laboratories have  been
evaluated.  Procedures are being developed to evaluate any field monitoring
laboratory, and a feasibility study of a certification system for
environmental monitoring laboratories is nearing completion.
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IX.  STANDARDS SET OR UNDER CONSIDERATION PURSUANT TO TITLE
     II OF THIS ACT
     A number of emission standards have been set, and many regulations
have been Issued to support EPA's control program In the mobile source
area.
Regulations for Light Duty Diesel Trucks
     Regulations for the control of emissions from diesel-powered light-
duty trucks,  effective with the 1976 model year, were promulgated on
October 22, 1974 (39 F.R. 37610).  Emission regulations for this light-
duty category were not issued previously since no light-duty diesel-
powered trucks were being marketed In the United States.  The regulations
were 1n response to notification by one manufacturer of plans to market
a light-duty diesel truck for the  1976 model year.  Other manufacturers
have since  indicated that they may also market a  light-duty diesel
truck as early as  the 1976 model year.
     The standards contained 1n  the proposal are  the same as those
promulgated for light-duty gasoline-fueled trucks and  are expected to
be  met  through application of existing  technology.  The  standards would
be  applicable beginning  In the  1976 model year.
Motorcycle  Regulations
         i
     An Advance Notice of Proposed Rulemaking  to  control emissions
from new motorcycles was published on January  17, 1974,  (39 F.R.  2108).
The need  for  control of  motorcycle emissions stems  from the increasing
numbers of motorcycles  in the  urban  environment  and their  relatively
high emission levels compared  to new cars.   The  Advance Notice of
 proposed  Rulemaking communicates to  motorcycle manufacturers  the course
                              107

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of action EPA is considering regarding the stringency and timing of
motorcycle regulations, thus providing them with the maximum possible
lead time, and also seeks comments on technical aspects of the regula-
tions.
     Many factors -- for example, increased personal income, increased
leisure time, improved products and greater general public acceptance —
have caused the motorcycle population to expand sharply over the past
few years.  EPA estimates that 2.3 million motorcycles will be offered
for sale in 1976, compared with a projected 12 million automobiles.  On
the average, an uncontrolled motorcycle emits 20 times more hydrocarbons
per vehicle mile than an automobile controlled to the 1977 standards.
The average motorcycle however, annually travels only one-third the
miles of the average automobile.  Based on these data, the new motorcyles
sold in 1976 and thereafter will, if left uncontrolled, add a greater
hydrocarbon burden to the atmosphere than all new automobiles sold in
each of those years.
     In addition, the proposed rulemaking for the Approval and Promulgation
of Implementation Plans (40 CFR Part 52) for the States of Arizona,
California, and New Jersey includes certain limitations on the regulation
and operation of motorcycles.  These limitations are necessary to reduce
total  hydrocarbons and carbon monoxide levels in those regions and to
prevent a counterproductive shift from automobiles to motorcycles as
a result of other elements of the control strategy.  The proposed
rulemaking states, "In an attempt to remove the ceiling on motorcyle
registration, the Agency will evaluate the feasibility of establishing
                              108

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emission standards for new motorcyles and will evaluate the availability
of motorcycle emission control technology for meeting emission standards
for retrofit."  In comments submitted to EPA in response to this proposed
rulemaking, the motorcycle industry stated that technology is available
and can be implemented with reasonable production lead time.
     Proposed regulations for new motorcycles are expected to be published
in mid-1975.
Non-Methane Hydrocarbon Exhaust Emission Standards
     On May 10, 1974, an Advance Notice of Proposed Rulemaking was
published for conversion of current standards for motor vehicle hydro-
carbon exhaust emissions to a nonmethane basis (39 F.R. 16904).  This
action was in response to a formal petition by Ford Motor Company for
such an amendment.
     The rationale set forth in Ford's petition may be summarized as
follows:  (1) methane is a photochemically non-reactive hydrocarbon;
(2) catalyst-equipped vehicles are likely to have a greater proportion
of methane in their exhaust than current vehicles; (3) current standards
limit emissions of all hydrocarbons including methane, thereby penalizing
catalyst-equipped vehicles; and (4) this penalty creates a hardship by
making it more difficult to control NOX and causing fuel economy to
suffer.
     Ford did not provide any evidence to support its contention of
hardship and informal contacts with other manufacturers indicated a
difference of opinion on the need to adopt a non-methane based standard.
                              109

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Therefore, EPA's position was that additional  information  justifying
the need for the change was required before it could embark on  a  program
to develop regulations.  The Advance Notice of Proposed Rulemaking  was
aimed at obtaining the comments of other manufacturers and interested
parties so as to allow EPA to base its decision on the merits of  the
issue.  The comments on the Advance Notice have been received and are
presently being reviewed by EPA.
Regulations for Certification of New Vehicles  Intended for Sale at
High Altitudes
     On October 18, 1974, EPA promulgated rulemaking which would  require
that new motor vehicles offered for sale in high altitude regions in  the
Nation be certified for compliance with Federal emission standards  at
high altitudes (39 F.R. 37300).  Under the previous certification process,
all certification test vehicles including those intended for sale at
high altitude areas were tested in Ann Arbor,  Michigan, at essentially
sea level conditions; those complying with the standards could be sold
anywhere in the Nation.
     The Clean Air Act requires that all new vehicles, wherever  sold
or operated, meet Section 202 emission standards. EPA has promulgated
these regulations because its studies of comparative emission levels
of various United States cities show that vehicles at high altitude
have higher emissions than those same vehicles at low altitude.  For
1968 through 1971 model year  vehicles tested  in Denver, carbon monoxide
and hydrocarbon levels were 60 percent and 50  percent respectively,
above the national average.  Three air quality control regions at high
                             110

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altitudes — Denver, the Wasatch Front (Salt Lake City,  Odgen,  and Provo,
Utah), and El Paso, Texas/Las Cruces Alamogordo, New Mexico --  have
ambient air levels high enough to require transportation controls.
Substantial improvements in ambient air quality in these regions are
expected to come from the new Federal emission standards for autos
when the new 1977 autos are equipped to meet the emissions standards
at high altitude.
Regulations for Certification of Low-Emission Vehicles
     The purpose of regulations for certification of low emission
vehicles is to encourage development of vehicles with significantly
lower emission levels than vehicles certified to meet Federal emission
standards.  Vehicles so certified are then eligible for purchase by
the Federal Government at premium prices.  Low emission vehicle certifica-
tion regulations, applicable to 1973 and 1974 model year light duty
vehicles, were issued by EPA in 1971.  On September 10.  1974 EPA promulgated
regulations extending the provisions to 1975 and later model year light-
duty vehicles (39 F.R. 32612).
Aircraft Emissions Regulatory Actions
     EPA published a Notice of  Proposed Rulemaking applying to emissions
from engines powering supersonic aircraft on July 22, 1974  (39 F.C. 26653).
This followed up a commitment made  in the preamble to the basic EPA
aircraft regulations promulgated on  July 17, 1973, stating  that because
of specialized technological constraints limiting the ability of supersonic
aircraft to meet the same standards  applicable  to subsonic  aircraft,
separate standards would be  published for this  class.
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     The regulations proposed reflect the same  types  of contustor
design technology but make due allowances for the less  efficient
engine cycles used for propulsion of aircraft designed  for  super-
sonic flight speeds.  Public hearing were held  concerning this
Notice of Proposed Rulemaklng in Boston,  Massachusetts, on  November
19, 1974, and in Los Angeles, California, on November 26, 1974.
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X.  THE STATUS OF STATE,  INTERSTATE,  AND LOCAL POLLUTION CONTROL
    PROGRAMS ESTABLISHED  PURSUANT TO  AND ASSISTED BY  THIS  ACT
     A single agency is designated to administer Air Quality
Control Programs in each of the 50 States, the District of
Columbia, Guam, Puerto Rico, the Virgin Islands, and American
Samoa.  In addition, approximately 265 local agencies, concerned
with air pollution control at the municipal level, work in
coordination with the 55 .State agencies.  The State agencies are
generally organized as follows:
     o  32 environmental agencies combining air, water and
        possibly other environmental protection programs, and
        in at  least 6 States exercising significant natural
        resources management.
     o  17 health agencies  combining air  pollution control
        functions  (and possibly other  environmental protection
        programs) with traditional medical  health  protection
        functions.
     o  6 air  agencies  specializing  predominately  in  the  control
         of air pollution
      Local governmental  agencies  (cities, counties,  etc)  have
 traditionally  carried out the  major portion of the regulatory  and
 enforcement  aspects of air pollution  control, including air monitor-
 ing .   In recognition of the regional  nature of air pollution
 problems,  several  of these local  agencies have organized into
 regional organizations   in recent years.  Outside of major
                            113

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cities, the provision of air pollution services by a single
 agency in  several governmental jurisdictions has  resulted  in a
 number of  multi-county  agencies.   In  1974 only 26  percent  of the
 local  agencies  were  in  city  governments,while 40  percent were
 at  the county level,  and  34  percent were in a city-county,
 multi-county, multi-city  or  some  other broaden coverage kind
 of  organizational arrangement.
      FEDERAL FINANCIAL  ASSISTANCE TO  AIR POLLUTION  CONTROL AGENCIES
      EPA provided financial  assistance to 54 State  agencies (the
 single exception being  American Samoa) and 150 local  agencies.
 Twenty-two local agencies also received Federal monies as  specified
 through State grants.   The: total  expenditures  of these 204 agencies
 represented  approximately 95% of the  total  expenditures  of all  State and
local air pollution control agencies  in FY1974.   This assistance takes the
form of grants  for planning,  developing,  establishing, or improving or
 maintaining programs  for  the prevention and control  of air pollution,
 supplemented by special contractual assistance for  the conduct
 of  specific Federally-required planning activities.   Grants awarded
 in  Fiscal  Years 1972, 1973,  and 1974  are summarized in Table 14.
      PROGRESS OF STATE  AND LOCAL  AIR  POLLUTION CONTROL PROGRAMS
      Total expenditures for  the support of air pollution control
 programs have grown  at  an average annual rate of  approximately
 30  percent, from $13 million in Fiscal Year 1965  to an estimated
 $129 million in Fiscal  Year  1974.  The percentage  of these expenditures
 provided by Federal  financial assistance has increased from
                          114

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Table 14


Summary of Grant Awards to State and Local
Air Pollution Control Agencies
by State
State or Territory
Al abama
Alaska
Arizona
Arkansas
California
Colorado
Connecticut
Del aware
D. C.
Florida
Georgia
Hawai i
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine
1972
527,324
69,775
207,049
208,527
3,690,260
900,784
1,355,796
189
225,000
885,741
630,218
96,445
81 ,687
2,423,520
826,034
559,243
335,761
159,028
175,000

1973
786,059
183,240
718,104
280,295
3,637,559
595,626
1,014,406
388,454
80,823
1,153,204
600,366
175,400
148,237
2,897,780
772,809
645,258
596,319
1,115,903
349,959
245,349
1974
Preliminary
1,443,312
165,100
658,761
407,000
3,611,240
646,333
1,240,972
256,069*
334,134*
924,493
684,250
189,435
205,100
2,914,358
1,183,822
579,780
476,293
953,267
807,200
106,000
19752
Estimated
875,000
186,000
715,000
250,000
3,863,000
710,000
1,414,000
270,000
240,000
1,025,000
780,000
251 ,000
214,000
2,945,000
1,310,000
540,000
479,000
1,170,000
385,000
192,000
115

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Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
New York
North Carolina
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
987,000
794,385
1,613,520
365,669
421,724
717,574
231 ,460
231,929
245,702
185,409
2,135,581
706,440
3,967,790
1,489,039
45,000
1,798,153
484,906
486,828
2,080,700
133,899
111,783
32,025
703,614
2,603,299

1,206,184
1,247,799
1,999,772
661,174
269,852
1,145,850
265,000
247,116
247,956
227,609
1,837,292
302,543
4,748,350
1,157,038
61,950
2,450,000
481 ,408
567,060
2,559,125
197,117
773,546
32,000
1,165,570
2,789,526
164,100
1,365,901
1,116,982
1,999,424
674,098
392,875
1,090,698
326,000
408,642
293,311
172,546
2,178,144
328,800
4,849,997
1,361,523
69,000
2,605,619
471 ,600
668,400
2,689,400*
265,000
493,967
27,667
884,317
2,398,800
150,000
1,153,000
1,123,000
1,875,000
705,000
470,000
1,114,000
340,000
324,000
388,000
211,000
2,230,000
495,000
4,980,000
1,450,000
120,000
2,522,000
520,000
729,000
3,290,000
185,000
550,000
95,000
1,010,000
2,910,000
165,000
                                    116

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Vermont
Virginia
Washington
West Virginia
Wisconsin
Wyoming
American Samoa
Guam
Puerto Rico
Virgin Islands

   Subtotal
                   3
    Special Support
    Multireglonal Projects
Total
Federal Fiscal Yr Budget
Awards are related to Federal Fiscal Year and include Federal  Assignees,  and
 dollars carried from previous year.  For most states, dollars  do not  relate
 to budgets for the State's Fiscal year.
2The estimates for 1975 include Special Support monies (contractor assistance
 and demonstration grants) provided States.
^special support include grant and contractor assistance for State Implementation
 plan revision, development, and evaluation.
*For these States preliminary 1974 estimates are related to awards made during
 Fiscal year 1974.
224,426

1,062,000
1,129,910

317,620
965,448
68,133
-0-
54,774
464,417
100,043


>cts
540,317,581
;t
173,669

1,005,674
1,209,263

586,935
883,700
88,824
-0-
-0-
691,552
72,806
47,882,510
2,964,259

50,846,769
50,804,800
150,000
*
991,381
1,083,400
*
700,470
824,170
100,000
-0-
66,150
226,124
77,735
49,289,060
2,915,999

52,205,059
51,518,000
180,000

954,000
1,151,000

458,000
905,000
130,000
-0-
156,000
400,000
80,000
51,182,000

336,000
51,518,000
51,518,000
                                    117

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 approximately 31  percent  in  Fiscal  Year  1965  to a  peak of 43%, and took
 a downward turn  to  41  percent  in  FY 1974.  However, the portion of these
 expenditures  provided  by State and  local revenue sources has
 grown eight-fold during the  same  period, from $9 million in
 Fiscal Year 1965 to an estimated  $76.7 million in  Fiscal Year
 1974,
     The increase in the number of  employees of State and local
 control agencies is an indicator  of the Nation's growing capability
 to control air pollution.  Table  15 shows that the number of on-
 board personnel has more than doubled in the last  5 years.   The
 on-board positions represent approximately 6500 equivalent full-
 time manyears of effort.

                         Table 15
              Personnel Employed by  State and Local  Air Pollution
                      Control Agencies (On Board)  Full and part-time

                                       Fiscal  Year
Agency Level 1969
State 997
Local 1.840
Total 2,837
1971
1,537
2,628
4,165
1973
2,929
3,266
6,195
1974
3,261
3,975
7,236
manpower level by FY 75 of about 8,500 would be necessary to accomplish
clean air objectives.  The trend indicated in Table 15  is encouraging; it
1s hoped that the original manpower estimates will be met.  However, it
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should be noted that since this estimate was made additional
requirements have been put on the States because of additional
actions required on transportation  controls implementation,
prevention of significant degradation of air quality,  and indirect
sources/maintenance of standards.
       Additional  resource   estimates made in December 1973 indicate
  that a  total  level  of 9500 manyears is  required  to implement the
  SIPs in  1974  and 10,200 manyears would  be  required by 1975.  The
  1973 estimates  accounted  for  some  of  the program demands anticipated
  in  the  above  actions.  However, these reassessments may be  low
  in  States  where revisions to  control  plans must  be made to  attain
  standards, where air quality  maintenance plans must be  implemented,
  and where  implementation  of Federal programs  such as enforcement of
  new source performance standards will  be carried out.   In addition
  the involvement of  States in  the Federal Energy  Act policies con-
  cerning  air pollution control strategies may  also result in the
  States  making an additional upward projection of their  resource
  needs.
       Figure5  compares the actual  growth of agency manpower with
  estimated  levels (original and revised for SIP achievement) as
  well as  with  estimates derived from a manpower model.   In
  July 1974, the agencies  had available approximately  70  percent of
  the manpower  stated as  being  needed by 1975  to accomplish  the  basic
  SIPs and revisions  to  those SIPs.   However,  approximately  two-fifths
  of the States did not  expend  in 1974-a manyear effort  equivalent to
  60 percent of the State  needs.
                                119

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     Figure 6 .compares actual State and local program funds to
estimates of SIP needs - original and revised - and to estimates
based on program costs commensurate with the manpower model.   The
anticipated 1975 and 1977 expenditures for the accomplishment of
the basic SIP and anticipated revisions are approximately $188
million and $210 million, respectively.  In 1974, the agencies
had available approximately 69 percent of the funds stated as
needed by 1975.  Approximately one-third of the States spent less
than 60 percent of their revised 1975 needs.
     Significant increases were made between July 1973 and July
1974 in agency resources.  Funding increased by approximately 13
percent ($15 million) and manyears of effort by 15 percent
(850 manyears}.  State and local funds increased by 21 percent
                                •
over a similar period (July 73 - July 74), while available
Federal funds increased by only 4 percent.
     Accomplishments of the State programs have been reflected
throughout this report in the sense of their activities in
developing, implementing, and enforcing SIPs.
                                 120

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                                                                                 (11,000)
CO
e:

LU

i
2
<
o
UJ
         .',  1'
                                                                               (6,-94)
                                                                                                [10,-.0',)
                                                                                                                                  CVJ
                     I      t      I      I	I	I	1	1
                                                                                    i      '	I	1	1	L
                                                   1970
                                                                                  1975
                                                                                               1977
                                                                    YEAR
                       Figure   5  Comparison of actual and needed State and local air pollution control program manpower.

-------
                                                                                             (209)
Q
=>
CQ
         20
                1965
                                                                               (200)
                  I - 1111)11
I      I      I       I
                                                                              2575
                                                                                          1977
                                                                                                                               CM
                                                                                                                               CM
                                                                 YEAR
                      Figure  6   Comparison of actual and needed State and local air pollution control program funds.

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            APPENDIX
Summary of EPA's Stationary Source Air
          Enforcement Actions
        May 1972 - November 1974
                    123

-------
                                              SUMMARY OF EPA ENFORCEMENT ACTIONS

                                           SECTION 110 - STATE IMPLEMENTATION PLANS

                                                        December 1974
             MOTE-  SOURCES ARE LISTED IN ALPHABETIC ORDER FOR EACH .STATE WITHIN EACH EPA REGIONAL OFFICE.  FACILITIES KITH ACRONYMS FOR NAMES
                   (E6 AAA MFG. CO.) ARE LISTED AT THE END OF EACH STATE
                       COMPANY/TYPE                   REGION I.
  STATE/CITY
                        OF SOURCE
                                             POLLUTION PROBLEM
                                            TYPE OF ACTION
                                                                                           BESOMS/STATUS
Connecticut,
   Bockville
Connecticut,
   Bridgeport
Connecticut,
   Derby
Connecticut,
   Middletown
Connecticut,
   Haterbury
Amerbelle Corp.

   Printing
   Plant
Bullard Castings,
Inc.

   Cupola Furnaces
Hull Dye and Print
Works

   Textile
   Plant
Russell Mfg. Div.
Fenner America Ltd.

   PVC Belting
   operation

Waterbury Rolling
Mills, Inc.

   Metallurgical
   Operation
Violation of hydro-
carbon emission
standard.
Violation of parti-
culate  (opacity
process weight,
and fugitive dust)
emission stds.

Violations of
opacity, and
hydrocarbon emis-
sion std. caused
by uncontrolled
emissions from the
drying operation.

Violation of opa-
city std.
Violations of
opacity std.
Notice of violation
issued 8/5/74.  Admin.
order issued 9/13/74.
Notice of violation
issued 10/12/73
Admin, order issued
2/14/74.
Notice of violation
issued 12/5/73.  Admin.
Order issued 2/14/74.
Order amended 8/14/74.
extending date for
final compliance to
Notice of violation
issued 12/14/73.
Admin, order issued
7/5/74.
Notice of violation
issued 10/31/73.
Admin, order issued
2/14/74.
Co. has chosen reformulation
as means of compliance.  The
order requires submittal of
all formulations used which
it has not fully complied with
to date.

Co. has complied with second
set of increments in order.
State is monitoring compliance.
Co. complied with the first
increment on 9/15/74.  Com-
pletion of installation of
control equipment should
take place by 1/1/75.  State
is monitoring their progress.
Appear to be in final compliance
as of 12/1/74.  compliance status
to be established.
Due to continued financial
problems the Co. is shut down
indefinitely.  The order
remains in effect should
they decide to reopen.

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         STATE/CITY

      Maine,
         Winslow
COMPANY/TYPE
 OF SOURCE

Scott Paper Co.

   Paper Mfg.
IM
      Massachusetts,
          Boston
      Massachusetts,
          Norwood

      Massachusetts,
          Boston
      Massachusetts,.
          Boston
       Massachusetts,
          Everett
American Barrel
Co.

   Incinerator

American Biltxite


Boston, city of

   Incinerator
Boston Edison Co.
 L Street Station

   Power Plant

Boston Edison Co.
Mystic Station

   Power Plant
                      POU.OTION PROBLEM

                      Violation of
                      State compliance
                      increments of
                      progress.
Violation of
opacity and open
burning regs.
Violation of hydro-
carbon regs.

Violation of opaci-
ty and particulate
emission limitat-
ations.

Violation of parti-
culate (opacity)
emission regs.
Violation of parti-
culate (opacity)
emission regs.
                     TYPE OF ACTION

                     Consent order was
                     issued 6/7/74.
                                           Notice of violation
                                           issued 3/15/73. Admin.
                                           Order issued 9/18/73.
                                           Notice of violation
                                           issued 10/11/74.

                                           Notice of violation
                                           issued 11/20/74.
                                           Notice of violation
                                           issued 11/9/73.
                                           Notice of violation
                                           issued 11/9/73.
RESULTS/STATUS

EPA is monitoring co.'s
progress in accordance with the
Consent Order, state implementation
dates.  The co. has complied with
the 3rd increment of the consent
order which is to achieve the
specified interim SO2 emission
limitation by 10/30/74.

Source complying with terms
of order.
Conference held.
issued.
Order will be
conference held 12/20/74.
stack testing program has been
completed.  Edison is presently
compiling data and preparing  •
report for Dec. 1974. submittal.

Stack testing program has been
completed.  Edison is presently
compiling data and preparing
report for Dec. 1974 submittal.

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co
        STRTE/CTTY

      Massachusetts,
         Boston
      Massachusetts,
         Quincy
      Massachusetts,
         Lynn
      Massachusetts,
         Boston
      Massachusetts,
         Lawrence
COMPANY/TYPE
 OF SOURCE

Boston Edison Co.
New Boston Sta-
tion
   Power Plant

General Dynamics
General Elec. Go.

   Electronics
   Mfg.

H.N. Hartwell 6 Son

   Fuel Distrib.
 Lawrence, City of

    Open Burning
PQUJITTOH PROBLEM

violation of
particulate (op-
acity stds.
                                                                            9?
                     Notice of violation
                     issued 11/9/73.
Violation of parti-  Notice of violation
culate  (fugitive     issued 10/4/74.
dust) & hydro-
carbon regs.
                        RESULTS/STATUS

                        Edison is presently preparing
                        report of emission test results
                        as evidence of compliance status.
                        Conference held.  Co.
                        submitted hydrocarbon process
                        info, as per sl!4 Itr.  Consent
                        order will be issued for open
                        shot blasting 6 spray paint
                        operations.  Pending.
Violation of hydro-
carbon regs.
Violation of sul-
fur oxide std.
 (regs prohibiting
sale of high sul-
fur fuel)

Violation of open
burning regs.
Notice of violation is- First increment not due at this
sued 10/4/74.  Order    time.
issued 12/18/74.
Notice of violation
issued 3/16/73.
Notice of violation
issued 6/6/73.
                                                                                                         final compliance.
                                              The transfer  station has  been
                                              completed and is operational
                                              confirmed by  EPA inspection.
                                              Dump  is  currently being closed
                                              in accordance with MA DPH regs.
      Massachusetts,
         Lowell
 Lowell,  City of

    Incinerator
violation of parti-
culate emission
limitations.
Notice of violation
issued 11/20/74.

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                COMPANY/TYPE
                 QF
              POLLOTIOM
"-S3ZS-
                Marblehead
                  Incinerator
              limitations.
                 Brayton Point

                  Power Plant
                             TYPE OF ACTTQN
                             SS3
                             asase—
             .
             *
Power plant
              limitation.
                                                 ,e Conducted on flue gas
                                              desul furization .
                                              — — «-
-rasa-
Terminals
              trary to require-
              ments of MA SIP

                                                           «—

                                       ^
              tions.

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                                                            VBOBLHi    TTPB OP ACT1O.B
      Massachusetts*
         somerville
      Massachusetts,
         North Baston
Massachusetts*
en
      Massachusetts,
         Heymouth
      Massachusetts,
         Arlington
      Rhode island,
         Bistol
      Rhode Island*
         Middletown;
      Rhode island,
         Newport
      Rhode island,
         Johnston
Somerville Smelting

   Metallurgical
   Process
Steadfast Robber
Co. Inc.

   ^h»^KhB_^fe^ ••fll^K
   Runner Krg.

lexaco. Inc.

   Foal distrib.
                            Onion Fetroli
                            Corp.

                               Fael distrib.
fisymooth* Vown of

   Incinerator

Vilfret Bros.
Realty Trust

   Incinerator

Bristol, city of

   Open dnnp

Middletown, City of

Open dump

Newport, City of

   Open dn*p
seaboard Foundry
Inc.

   Grey Iron
   Foondry
Violation of opa-
city reg.
Violation of hydro-
carbon enission
standard.
Violation of
salfor oxide emis-
sion limitations
fregs .prohibiting
sale of high sal-
fur fuel)

Violation of sol-
fur oxids std.
(regs. prohibiting
sale of high sul-
fur content fuel)

Violation of parti-
culate emission
limitations.

Violation of parti-
culate emission
stds.
Violation of
open burning
Violation of open
burning reg.
Violation of open
burning reg.
Violation of  pur-
ticulate (opacity
and process weight)
stds.
Notice of violation
issued 1/8/74.
order issued «/30/7«r
   •ended 8/29/74.
                                                                                         Co. issued purchase order •
                                                                                         submitted installation  schedule
                                                                                         per 4/30/74 Order.  Order amended
                                                                                         8/29/74 to incorporate  installation
                                                                                         schedule.
Consent Order issued
11/11/74.
                                                                       Notice of violation
                                                                       issued 2/1/73.
                                           Notice of violation
                                           issued 3/16/73.
Notice of violation
issued 11/20/74.
Notice of violation
issued 7/2/73.
order issued 12/3/73.
Notice of violation
issued 4/23/73.
Notice of violation
issued 10/13/72.
Notice of violation
issued 10/23/72.
Enforcement order
issued 1/11/73.

Notice of violation
issued 8/1/73.
                        Achieved final compliance
                        2/12/73.
                                                                                               Achieves* final compliance
                                                                                                Conference held 12/23/74.
                                                                                          Presently in compliance with
                                                                                          terms of  order.
                                                                                                In final compliance.
                                                                                                Achieved final compliance
                                                                                                Achieved final compliance
                                                                                                Achieved  final compliance.

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Ol
        STATE/CITY

      Hew Jersey,
         Ridgefield
         Park
      Hew York,       /
         Niagara Fall*
      Hew York,
         Tonawanda
      Hew York,
         Babylon
      Hew York,
         Schenectady
      Hew York,
         Fort Edward
COMPANY/TYPE
 OF SOURCE

Arnatex Dyeing ft
Finishing Co., Inc.
   Textile Mfr.

Airco Alloys.


   Foundry

Ashland Petro. Co.



   Refinery

Babylon, City of

   Incinerator

Cashing Stone
Company, Inc.

   Bock Crushing

Decora, Div. of
United Merchants
6 Manufacturers,
me.
                                 REGION H
                      POLIOnOH PROBLEM    TYPE OF ACT1OH
                      Violation of opac-
                      ity reg.
Failure to respond
to section 114
inquiry.
Failure to respond
to a section 114
inquiry.
Violation of opac-
ity reg.
Failure to file
HYS recertifica-
tion forms.
Failure to file
NYS recertifica-
tion forms.
                     Notice of violation
                     issued 9/26/74.
                     Admin. Order issued
                     11/20/74.
Admin, order is-
sued 10/10/74.
Admin, order is-
sued 10/24/74.
Notice of violation
issued 8/28/74.
Notice of violation
issued 9/11/74.
Notice of violation
issued 9/19/74.
                        RESULTS/STATPS

                        Source in compliance
                        with EPA order.
                                                                   Source complied with EPA
                                                                   order.
                                                                   Source complied
                                                                   with EPA order.
                                                                   Conference held 9/30/74.
                                                                   Negotiating order.
                                                                   Source in compliance.
                                                                   Source in compliance
      Hew York,
         Green Island
      Hew York,
         Hew York
Ford Motor Co.

 Industrial Boiler

Frank Mascali and
sons Inc.

   Asphalt concrete
   Nfr.
Violation of opa-
city reg.
Violation of opac-
ity reg.
Notice of violation is-
sued 1/11/74.
Notice of violation
issued 11/4/74.
                                                                   Source installed new toiler and
                                                                   upgraded operating procedures;
                                                                   presently in compliance.

                                                                   Conference held 12/3/74.

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Hew rork,
   Haterford
Hew rork,
   Buffalo
Hew York,
   Bickersvillc
Hew rork,
   Roslyn
Puerto Rioo,
   Ponce
Puerto Rico,
   San Joan
Puerto Rico,
   San Juan
 or SOURCE

General Electric
Co.. silicone
Prods. Oept.

   Electronics Mfg.

The Banna Furnace
Corp.,

   Steel Mfg.

Hooker Chen. Corp.
Ruco Div.

   Chen. Mf r.

North Hempstead
Municipal Inci-
nerator
   Incinerator

Puerto Rico Cement
Inc.

    lime kilns

Puerto Rico cement
Inc.

   Live Kilns

Puerto Rioo water
Resources Authority
•Palo seco"  (Toa
Baja) Station/power
plant.
                                                                      OF ACTION
Failure to file
HTS recertifica-
     forms.
                     notice of violation
                     issued 9/19/74.
                                                                                         Source in compliance.
Failure to respond   Order issued 10/15/7*.  Source in compliance.
to section 11*
inquiry.
Failure to file      Notice of violation
NTS recertification  sent 9/12/7*.
forms.
                                            Violation of opac-   Notice of violation
ity regs.
                     issued «/7/7*;
                     Administrative order
                     issued 9/25/7*;
                     amended 10/11/7*.
                                                                                         Source in compliance
                                             Conference held on 6/26/7* and
                                             10/3/7*.
Violation of opac-   Notice of violation     conference beld-covered
ity reg.             issued 5/9/7*.  TWO     Ponce* facility also.
                     consent orders signed
                     8/12/7*.

Violation of opac-   Notice of violation     Source in compliance with
ity reg.             issued 5/9/74.  Consent consent order.
                     Order signed 8/12/7*.
Violation «f opac-   Notice of violation
ity reg.             issued 9/19/7*.
                                             Additional information submitted
                                             and being reviewed.  Conference
                                             held  11/21/7*.

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       STATE/GIT?

     Puerto Rico,
        San Juan
COMPANY/TTPB
 OF gODRCE

Puerto Rico Water
Resources Authority
Puerto Nuevo
Station.
POLLUTION PROBLEM    TYPE OF ACTION
Violation of opac-
ity reg.
Notice of violation
issued 9/19/74.
RESULTS/STATUS

conference held 11/21/74.
Additional info submitted and
being reviewed.
     D.S. Virgin
        Islands
     Virgin Islands,
        St. Croix
     virgin islands,
        St. Croix
i
CD
   Power Plant

St. Croix Petro-
chemical Corp./
petrochemical
company.

St. Croix Petro-
chemical Corp.

   Chemical Mfg.
Vir. Us. water
S Power Authority

   Power Plant
Violation of feder-
ally promulgated
new source review
requirements of
SIP.
Violation of feder-
ally promulgated
new source review
requirements of
SIP.

Violation of fed-
erally promulgated
SIP new source re-
view regulations.
Notice of violation
10/18/74.
Notice of violation
issued 10/18/74.
Notice of violation
issued 11/8/74.
Co. stopped construction
until approval to con-
struct was granted.
Co. stopped construction
until approval to con-
struct was granted.
Sourc* has filed required
new source review data.

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                                                               REGION  III
         STATE/CITY

       Delaware*
          Claymont
COMPANY/TXPB
 OF SOURCE

Allied chemical
Corp.
                                                             PBOPT-EM
Violation of emis-
sion std for sulfur
oxides.
                                                                        TYPE OF ACTION
                                                                                                BESOLTS/STATOS
Notice of violation is- commencing on 11/10/72
       Delaware,
          Delaware City
UD
       Delaware,
          Bilge Moor
       Maryland,
          Eastern Shore
       Maryland,
          Sabillesville
       Maryland,
          Emittsburg
       Maryland,
          Thurmond
Delmarva Power *
Light Co.

   Power Plant
 E.I.  duPont  de
 Nemours  Co.  Inc.

    Sulfate
    Mfg.

 Bayshore Foods,

    Grain Dryer
 Benchoffs Dump

    Open Damp

 Charles Metzel Damp

    Open Damp

 Fogels Dump

    Open Damp
Violation of sulfur
oxide emission
standard.
sued on 5/24/72. Order
comply issued on
6/18/72.

Amended order is-
sued on 6/18/74.
Notice of violation
issued 3/6/72 En-
forcement order
issued 4/17/72.
Violation of parti-   Consent  order issued
culate  emission      10/25/74.
std.
Violation of opac-
ity stds.
                      12/28/73 - Notice of
                      violation issued.
 Violation of parti-  consent- order issued
 culate (open burn-   10/10/74.
 ing)  std.

 Violation of parti-  consent order issued
 culate (open burn-   10/10/74.
 ing)  std.

 Violation of parti-  Consent order issued
 culate (open burn-   10/10/74.
 ing)  std.
                                             bimonthly*progress re-
                                             ports have been submitted
                                             to EPA resulted in con-
                                             struction schedule with
                                             increments of progress,
                                             schedule is presently being
                                             complied with.  Amended order
                                             issued to discontinue monthly
                                             reporting.

                                             Getty Oil (supplying high sulfur
                                             fuel to Delmarva) litigated the
                                             EPA order.  Court upheld EPA
                                             in Getty Oil vs. Ruckelshaus
                                              (342 F. Suppl. 1006; 467 F. 2d.
                                             349:1/15/73).  Source is presently
                                             in compliance with emission std.
                         1/24/73 - conference held
                         7/5/74 - draft consent
                         order mailed  to co.
                         Letter of intent received
                         in  December 1974.

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                                                                  10
  STATE/CITY

Maryland,
   Bethesda
Maryland,
   Silver Spring
Maryland
   O.c. Area
Maryland
   D.C. Area
o   Maryland
        D.C. Area
Maryland,
   Eastern Shore
COMPANY/TYPE
 OF SODRCE

National Med.
Center

   Industrial Boiler
   and Incinerators

Naval Ordinance
Laboratory

   Incinerator

PEPOO Chalk
Point Station

   Power Plant

PEPCO Oickerson
Station

   Power Plant

PEPCO Morgantown
Station

   Power Plant

Perdue, Inc.

   Grain Dryer
POLLUTION PROBLEM
                     TYPE OF ACTION
                                             RESULTS/STATUS
Violation of parti-  Consent agreement
colate emission      signed 12/1/74.
std.
Violation of parti-  Consent agreement
culate emission      signed 12/16/74.
std.
Violation of sulfur
oxide and parti-
culate emission
standard.

Violation of sulfur
oxide and Parti-
culate 'emission
std.

Violation of sulfur
and particulate
emission std.
Violation of opac-
ity stds.
Notice of violation
issued 6/04/74.
Notice of violation
issued 6/01/74.
                                                                 Notice of violation
                                                                 issued 6/04/74.
12/28/73 - Notice of
violation issued.
                                                                                              Conference held on 7/25/74.
                                                                                              Conference held on
                        Conference held on
                                                                                              1/24/73 - conference held
                                                                                              7/5/74 draft consent orders
                                                                                              mailed to co.  Letter of intent
                                                                                              received Dec. 1974.

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                                                                 11
  SPITS/CITY

Maryland,
   Eastern Shore
Maryland,
   Baltimore
Maryland,
   Eastern Shore
Pennsylvania,
   Meadville
Pennsylvania,
    Evansvilie.
Pennsylvania,
    Delaware
Pennsylvania,
   Kittanning
Pennsylvania,
   Hyondssing
COHPANT/TZPB
 OF SOORCE

Snow Hill Grain

   Grain Dryer


Southern states
Grain Coops.

   Grain Dryer

Hhittington Poul-
try Farms

   Grain Dryer

Abex Corp.

   Smelting
Allentown Port-
land Cement Co.

   Cement Plant

Delaware County
Municipal Inci-
nerator

   Incinerator

Manor  Minerals,
Inc.

   Mineral
   Processing

Metals Engineer-
ing, Inc.

   Metallergy Shop
Vffr.-r.iff TOW PROBLEM

Violation of opac-
ity standards
violation of opaci-
ty stds.
Violation of opac-
ity stds.
Violation of parti-
culate emission
stds.
Failure to respond
sl!4 letter.
TYPE OF ftCTIOH

12/28/73 - notice of
violation issued.
12/28/73 - Notice of
violation issued.
12/28/73 - notice of
violation issued.
notice of violation
issued 5/1/74.
Consent order signed
9/4/74.
RESOLTS/STMOS

1/21/73 - conference held
7/5/74 draft consent orders
mailed to co.  Letter of intent
received Dec. 1974.

1/24/73 - conference held
7/5/74 draft consent orders
•ailed to co.  Letter of intent
received Dec. 1974.

1/24/73 - conference held
7/5/74 - draft consent
mailed to co.  Letter of
intent received Dec. 1974.

In compliance with terms
of order.
                                                                 Order issued on 5/3/74. Co. complied with, order.
Violation of parti-  Notice of violation
culate emission      issued 6/25/74.
stds.
No response to sl!4
letter requesting
information re-
garding facilities
emissions.

Failure to respond
to sill letter.
                                                                 Order issued 4/3/74.
Order  issued on
4/3/74.
                        Conference held on
                        6/19/74.  Delco determining
                        applicability of ESP as
                        central technique.
                        Company complied with
                        order.
                                                                                         Company complied with

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                                                                     12
      STATE/crry

    Pennsylvania,
       New Florence
    Pennsylvania.
       Erie
   Pennsylvania,
        Homer City
   Pennsylvania,
      Shelocta
—•  Pennsylvania,
1X1     Saxton
   Pennsylvania,
       Seward
   Pennsylvania,
      Cleazfield
 COMPANY/TrPE
  OF SOPRCE

 Perm. Elec. Co.
 Conemaugh sta-
 tion

    Power Plant

 Penn. Elec. Co.
 Front St.  station

    Power Plant

 Penn. Elec. Co.
 Homer city Sta-
 tion

    Power Plant

 Penn.  Elec. Co.
 Keystone Station

    Power Plant

 Penn.  Elec.  Co.
 Saxton Station

    Power Plant

 Penn.  Elec.  Co.
 Seward Station

    Power Plant

 Penn. Elec.  Co.
 Shawville Sta-
tion.

   Power Plant
                      TYPE OF
 Violation of parti-
 culates and sulfur
•oxide emission
 stds.
 violation of parti-
 culates and sulfur
 oxide emission stds
Violation of parti-
culates and sulfur
oxide emission
stds.
Violation of  parti-
culates and sulfur
oxide emission
stds.

Violation of  parti-
culates and sulfur
oxide emission
stds.

Violation of  parti-
culates and sulfur
oxide emission
stds.

Violation of parti-
culates and sulfur
oxide emission
stds.
 Notice of violation
 issued 6/19/74.  con-
 sent order issued
 11/18/74.
 Notice of violation
 issued 6/19/74.   Con-
 sent order issued
 11/18/74.

 Notice of violation
 issued 6/19/74.   Con-
 sent order issued
 11/18/74.
Notice  of  violation
issued  6/19/74.  Con-
sent order issued
11/18/74.

Notice  of  violation
issued  6/19/74. Con-
sent order issued
11/18/74.

Notice  of  violation
issued  6/19/74.  Con-
sent order issued
11/18/74.

Notice of  violation
issued 6/19/74.  Con-
sent order issued
11/18/74.
 BESOLTS/STATO?

 Company is complying with
 terms of the order.
 Company is complying with
 terms  of the order.
 Company  is complying with
 terms  of the  order.
Company is complying with
terms of the order.
Company is complying with
terms of the order.
Company is complying with
terms of the order.
Company is complying with
terms of the order.

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                                                                     13
CO
      STRTE/CITY

    Pennsylvania,
       Warren
    Pennsylvania,
       Williamsburg
    Pennsylvania,
        Phila.
     Pennsylvania,
        Phila.
     Pennsylvania,
        Reading
     Pennsylvania,
        Clairton
COMPANY/TYPE
 Of SOURCE

Penn. Elec. Co.
Warren Station

   Power Plant

Penn. Elec. Co.
Williamsburg
Station

   Power Plant

Philadelphia
Electric Co.
Comby Station

   Power Plant

Philadelphia
Electric Co.
Eddystone
Station

   Power Plant

Reading Gray
Iron Casting,

   Gray Iron
   Foundry

U.S. steel Clairton
works

   Coke Ovens
                                                          PROBLEM
Violation of parti-
culates and sulfur
oxide emission
stds.

Violation of parti-
culates and sulfur
oxide emission
stds.
violation of parti-
culates and sulfur
oxide emission
stds.
Violation of parti-
culates and sulfur
oxide emission
stds.
Failure to respond
to  s!14 letter.
Violation of opac-
ity and particulate
emission stds.
TYPE OF ACTION

Notice of violation
issued 6/19/74. Con-
sent order issued
11/18/74.

Notice of violation
issued 6/19/74. Con-
sent order issued
11/18/74.
Notice of violation
issued 6/19/74.  Con-
sent order  issued
11/18/74.
Notice of violation
issued 6/19/74.  Con-
sent order  issued
11/18/74.
RESOLTS/STATDS

Company is complying with
terms of the order.
Company is complying with
terms of the order.
Company is complying with
terms of the order.
Company is complying with
terms of the order.
Order issued on  4/3/74. Company responded to order
                        on 5/15/74.
Notice of violation
issued 11/8/73.

Referred to O.S. Atty.
for combustion stacks
door leaks, £  topside
emission on 6/7/74.

Referred to O.S. Atty.
for pushing sent on
7/11/74.
On 11/29/74. Honorable J.L.
Miller stayed  effect  on
subpeonas  until  1/6/75.

-------
                                                                      14
                                SOURCE            POLLUTION PROBLEM    TYPE OF ACTION          RESOLTS/STATOi!
                                                                      as           0"     «-*—•• «-»
                            Station               oxide  stds.
                               Power Plant
                            KiftE?^7"        Violation of parti-  Notice of violation    Awaiting stack test
                            Incinerator           culate emission      sent on 3/14/74.        results.
                                                                      Order to stack test
                                , ,                                   issued 7/2/74.
                               Sludge
                               Incinerator


                                  Cascadc        Violation of parti-  Notice of violation    Company complied with
                                                 culate eml88ion      issued 3/15/74.   ^    fir^ Increment of order
                               inaust.  Boiler    stds.                foroement order issued  On 10/16/74 company notified
                                                                      6/7/74.                EPA that it will shut down
                                                                                             in January 1975 due to
                                                                                             economic reasons.
                                                                      Notice of violation     Conference held on 7/29/74
^       -t/anvi*AB           station              culate emission      issued " "" —
 '                                                limitation.
.^                             Power Plant
      V±rlichmond           5S^aUaper         Violation of parti-  Notice of  violation     Awaiting stack test
         Richmond           Board Inc.            culate emission      issued 4/17/74.         results.
                                                 limits.
                               industrial
                               Boiler
                                o         RlVer ' yiolf^?n of °Pac-   Notice of violation     Conference held 2/27/74.
                            Station               ity limitation.      issued 1/30/74.

                              Power Plant                             Administrative order    Meeting to discuss order
                                                                      issued 6/25/74.         with Co. scheduled for
                                                                                             7/25/74

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                                                                    15

                                                           REGION
                                                IV
     STATE/CICT

   Alabama,
      Tuscombia
   Alabama,
      Stevenson
   Florida,
      Pierce
   Florida,
      Lakeland
   Florida
      Bradley
i'
in
   Florida,
      Joy Oil Field
   Florida,.
      Chatahoochie
   Florida,
      Gibsonton
COMPANY/TYPE
 Of SOURCE

TVA-Colbert Sta.

   Power Plant

TVA-Widows Creek
Station

   Power Plant

Agrico. Chemical Co.


   Rockdryers

Bordon chemical Co.

   Rock dryers

Brewster Phosphate
Co.

   Rock Crushing
 Exxon Louisiana
 Land Corp.

    Refinery

 Florida State Hosp.
    Industrial
    boiler

 Gardinier Inc.

    Phosphate rock
    dryers
POLLUTION PROBLEM

Violation of par-
ticulate emission
std.

Violation of par-
ti culate emission
std.
Violated particu-
late std.
Violation of par-
ticulate emission
std.

Violation of
Federally approved
compliance schedule
for particulate
emission std.

Violation of sul-
fur oxide emis-
sion  std.
 Violation of  par-
 ticulate emission
 std.

 Violation of  par-
 ticulate and  sul-
 fur oxide stds
TYPE OF ACTION

Notice of violation
issued 12/4/74.
Notice of violation
issued 12/4/74.
Notice of violation
issued 8/26/74.
Notice of violation
issued 8/30/74.
Notice of violation
issued 8/26/74.  Enforce-
ment order  issued
10/9/74.
 Notice of violation
 issued 9/13/74.
 Notice of violation
 issued 8/27/74.
 Notice of violation
 issued 6/11/7U.   Admin.
 order for particulate
 issued 9/6/74.
                                                                                            RESULTS/STATUS

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                                                                      16
       STATE/CITy

     Florida,
        Bartow
     Florida
        Chatahoochie
     Florida,
        Linhaven
     Florida,
        Pensaeola
     Florida
        Palatka
 COMPANY/TYPE
  OF
en
     Florida,
        Nichols
     Florida,
        White  Springs
     Florida,
        Bartow
 H.  R.  Grace

    Phosphate rock
    dryers

 Gulf Power Co.

    Power plant

 Gulf Power Co.

    Power plant

 Gulf Power Co.

    Power Plant

 Hudson Pulp 6
 Paper  Co.

    Pulp  and Paper
    Plant
Mobile chem. Co.

   Phosphate rock
   dryers

Occidental Chemical
Co.
Swift Chemical Co.

   Rock dryers
 POLLOTION PROBLEM

 Violation of Par-
 ticulate  and sul-
 fur  oxide emission
 stds.

 Violation of par-
 ticulate  and sul-
 fur  oxide stds.

 Violation of par-
 ticulate  and sul-
 fur  oxide stds.

 Violation of par-
 ti culate  and sul-
 fur  oxide stds.

 Source missed 1st
 increment of State
 adopted, federally
 approved  compliance
 schedule  for sulfur
 oxide and par-
 ticulate  matter.

 Violation of Fla.
 PM and SO2 reg.
Violation of
sulfur oxide
std.

Violation of par-
ticulate emission
std.
 TYPE OF ACTION

 Notice  of violation
 issued  6/11/74.   Admin.
 order issued 9/6/74.
 Notice  of violation
 issued  8/30/74.
 Notice  of  violation
 issued  8/30/74.
Notice of  violation
issued 8/30/74.
Notice of violation
issued 12/20/73.  Admin.
order issued  1/21/74.
                                                                   RESDMS/STATDS
Notice of violation
issued 6/11/74.  Admin.
order issued 9/6/74.
Notice of violation
issued 8/26/74.
Notice of violation
issued 9/13/74.

-------
Florida,
   Tampa
Florida,
   Bartow
Florida,
   Ft. Mead*
Kentucky,
   Paradise
OQNBMn/TOZ
 OF SOTTBCt

 Tampa Electric Co.

    Power Plant


 U.s.S. Agrichendcal
>co.
    Bock Dryers

 U.S.S. Agrichemical
 Co.

    Bock Dryers

 TVA-Paradise Sta.

    Power Plant
                                                                      of
Violation of par-
ticulate and sul-
fur oxide emissions
limitations.

Violates particu-
late std.
Violates particu-
late std.
Violation  of par-
ti culate emission
std.
                                          notice  of  violation
                                          issued  8/23/74.
                                           notice of violation
                                           issued 8/26/74.
                                           Notice of violation
                                           issued 8/26/74.
                                           Notice of violation
                                           issued 12/4/74.
I
»J
Kentucky,
    Paducah
 TVA-Shawnee Sta.

    Power Plant
Violation of  par-
ticulate emission
std.
                                           Notice of violation
                                           issued 12/4/74.
 Mississippi,
    Jackson
 Mississippi,
    Natchez
 Tennessee,
    Columbia
 Tennessee
    oak Ridge
 Tennessee,
    Gallatin
 Tennessee,
    Waverly
 Tennessee,
    Kingston
Cook Construction
Co.
   Open burning

International Paper
Co.

   Pulp S Paper Mill
Monsanto Industries
Chen. co.

   Rotary kilns

TVA-Bull Run Sta.

   Power Plant

TVA-Gallatin Sta.

   Power Plant

TVA-Johnston Sta.

   Power Plant

TVA-Kingston Sta.

   Power Plant
 Violation of
 particulate emis-
 sion std.

 Violation of par-
 ticulate emission
 std.

 Violation of sulfur
 oxide emission stds.
                       Violation  of  par-
                       ticulate emission
                       std.

                       Violation  of  par-
                       ticulate emission
                       std.

                       Violation  of  par-
                       ticulate emission
                       std.

                       Violation  of  par-
                       ticulate emission
                        std.
                                            Notice of violation
                                            issued 11/29/74.
                                            Notice of violation
                                            issued 9/24/74.
                                            Notice of violation
                                            issued 4/20/74.
                      Notice of violation
                      issued 9/12/74.  Admin.
                      Order issued 12/4/74.

                      Notice of violation
                      issued 12/4/74.
                      Notice of violation
                      issued 12/4/74.
                      Notice of violation
                      issued 12/4/74.

-------
oo
         STATE/CTry

      Illinois,
         Chicago
      Illinois,
         Quincy
      Illinois
         East Pcoria
      Illinois,
         Bartonvllle
     Illinois,
         Hood River
     Illinois,
        Granite city
     Illinois,
        Blue island
  COMPANY/TYPE
   OF SOURCE

  American Brick
  Company

  Brick Kiln £
  Crusher

 Celotex Corp.
    Industrial
    Boilers

 Central Illin-
 ois Light Co.
    Bower Plant

 Central Illinois
 Light Co.  Edward
 Station
 Power Plant

 Clark oil  Refinery

    Refinery
Granite City
Steel Co.

   Coke ovens
Illinois Brick
Company

   Brick Mfg.
                       18

                REGION  V

 POLLDTTON PROBT.BM     TYPE OP ACTTOW
 Violation of 111.
 opacity and parti-
 •culate enission
 standards.
 Violation parti-
 culate stds.
Violation of Feder-
al compliance
schedule for Illi-
nois particulate
stds.

Violation of sulfur
oxide std C
Federal compli-
 FCC unit violates
 particulate, hydro-
 carbon  6 carbon
 monoxide stds.

Violation of
particulate std.
and federal
compliance
schedule for coke
ovens.

Kilns violate par-
ticulate std.
 Notice of violation
 issued 1/21/74.
                                            Consent order
                                            issued 11/20/74.
                      Notice of violation
                      issued 12/20/73.
                      Notice of violation
                      issued 5/31/74.
Notice  of  violation
issued  10/24/74.
Notice of violation
issued 3/13/74.
Notice of violation
issued 3/4/74.
                                              RESOLTS/STATna

                                              State suit filed, no
                                              further Federal action
                                              at this time.
                                                                                               Conference held  8/1/74.
                                                                                               Draft consent order sent to company
                                                                                               for ————•*-                    «—~J
                         Conference held 8/1/74.
                         Draft consent order sent to Co.
                         for comment.
                                                                                               Conference held 11/19/74.
                                                                                               Awaiting decision of ill.
                                                                                               APCB on new carbon monoxide stds.
                                             State action anticipated,
                                             further EPA action deferred.
                                             complaint  field before
                                             Illinois Pollution Control
                                             Board, further Federal
                                             action deferred pending State
                                             action.

-------
                                                                 19
Illinois,
   Alton
Illinois,
   Chicago
Illinois,
   Chicago
Illinois,
   Thornton
Illinois,
   sterling
Illinois,
   Chicago
Illinois,
    Chicago
 Illinois,
    Chicago
 Illinois,
    SKokie
COMFANY/TtPB
 Of SOURCE

Illinois Power Co.

   Power 'Plant

Interlace, Inc.


   Coke ovens

International
Harvester Co.


   Coke ovens

Harblehead Line
Company

   Quarry

Northwestern Steel
6 Wire

   Steel Mfg.

Republic Steel Co.

   Steel Mfg.


 Republic  Steel
 Corp.

    steel  Mfg.


 Sheffield Foundry

    Foundry

 Skokie, Village
 of

    Municipal
    Incinerator
                                            POIXOTIQN
Violation of sulfur
oxides stds.
coke oven  {pushing
6 quenching) Opera-
ting violate parti-
culate stds.

Violation of
federal compliance
schedule for coke
oven quenching
and pushing

violaton of parti-
culate std.
 Electric arc
 furnaces violate
 particulate stds.


 Melt shop * Blec.
 arc furnaces vio-
 late particulate
 stds.

 Violation of fed-
 eral compliance
 schedule for coke
 oven pushing and
 quenching.

 Cupala violates
 participates
 emissions stds.

 Violation of parti-
 culate matter
 emission std.
                                                                      OP ACTION
Notice of violation
issued 9/3/74.
Notice of violation
issued 8/16/74.
Notice of violation
issued 11/29/73.
Consent order
issued 4/11/74..
 Notice of violation
 issued 3/19/74. Ord«
 issued 7/3/74.
 Notice  of  violation
 issued  8/2/74.
 Notice of violation
 issued 8/28/74.
 Notice of violation
 issued 11/29/73.
 Order issued 4/11/74.
 Notice of violation
 issued 10/24/74.
 Notice of violation it
 sued 2/20/74* consent
 order issued 4/2/74.
                                             RESULTS/STATUS

                                             Conference held 10/10/74.
Conference held 9/27/74.
Co. will submit data in January
on new control eqpt.
In compliance with terms of order.
terms of order.
In compliance with terms
of order.
Conference held 8/28/74.
Meeting in mid-December to discuss
compliance schedule.


Conference held 9/27/74.
                                                                                          In compliance witb
                                                                                          with terms of order.
                                                                                          Now in compliance.  No further
                                                                                          Federal action.
                                                                                          Presently in compliance witb
                                                                                          terms of order

-------
                                                                          20
 t
ro
o
        Illinois,
           Xawrenceville
        Illinois,
           Cahokia
        Illinois,
           Venice
       Illinois,
          Chicago
       Illinois,
          Elgin
       Indiana,
          Newburg
       Indiana,
          Monster
 CQKPANr/TXPS
  OF SOURCE

 Texaco Refinery
 Inc.

    Refinery

 Onion Blec. Co.

    Power Plant

 Onion Elec.  Co.

    Power Plant

 O.s.  Steel Corp.
 South Works

    Steel Mfg.

Woodruff
Edwards,  Inc.

   Foundry

ALCOA

   Aluminum SMlter

American Brick Co.

   Brick Kiln £
   Crusher
 Violation of car-
 bon monoxide and
 hydrocarbon stds.
 by storage tanks.

 Violation of parti-
 culate & sulfur
 oxides stds.

 Violation of parti-
 culate & sulfur
 oxides stds.

 Violation of parti-
 culate emission
 stds.
Coupola violates
carbon.monoxide
stds.
Violation of parti-
culate stds.
Violation of parti-
culate and opacity
standards.
 TYPE OF Acrmp

 Notice of violation
 issued 3/26/7*.
 Order issued 7/3/74.
 Notice of violation
 issued 10/23/74.
 Notice of violation
 issued 10/23/7*.
Notice of violation
issued 9/5/74.
Notice of violation
issued 6/7/74.
Notice of violation
issued 1/4/74.
 RESULTS/STAMPS

 Presently in compliance
 with terms of order.
                                                                                                 Conference held 12/5/74.  Draft
                                                                                                 order being prepared.
                                                                                                 Conference held 12/5/74.  Draft
                                                                                                 Order being prepared.
Conference held 9/27/74.
Meeting mid-January to discuss
Consent Order.
Awaiting results of
stack test.
Now in compliance with terms
of state order.
                    i8' Awa±ti»9 »•»**• of stack test.

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                                                                      21
     Indiana*
        Whiting
     Indiana,
        Noblesville
     Indiana,
        East Chicago
     Indiana*
        Chesterfield
ro
        Bast Chicago
     Indiana*
        T«rxe Haute
     Indiana*
        Bloosdngton
COMPANY/TYPE
 OP SCORCB

American Oil Co.

   Oil Refinery

Hamilton Cty.
Asphalt, Inc.

   Asphaltic
   Concrete

Atlantic Richfield
Corp.

   Refinery

Bethlehem  steel
Corp.*  Burns  Harbor
Plant

    Steel plant

Blaw-Know  Foundry

    Foundry  .


 Bloomington .

    Ammonium Nitrate
    Process.

 Bloomington
 Crashed Stone
 CO.

    Quarry
                                                           PROBLEM
                                                                           or ACIIOB
Violation of sulfur
oxide and opacity
standards.

Violation of parti-
culate matter emis-
sion standard.
Violation of  sul-
for oxi.de stds.
violation of par-
ticulate (opacity
and process weight
stds.
 Open hearth furn-
 ace violates parti*
 culate stds.
 Violation of opaci-
 culate matter emis-
 sion standards.
 Violation of opaci-
 ty and particulate
 natter emission
 standards.
Notice of violation
issued 9/10/73.
BESOMS/STATUS

Presently on enforceable
state order, further EPA
action obviated.
Notice of violation is- Presently in compliance with
issued 11/19/73. Admin, terms of order.
order issued 1/28/7*.
Notice of violation
issued 9/10/73.
notice of violation
Issued 7/11/73
                                                                                              source in compliance.
Coke ovens placed on  satisfactory
state schedule.  Other  points of
emission achieved compliance.
 Notice of violation     Presently in compliance with
 issued 1/21/7*. Admin-  terms of order.
 istrative order is-
 sued 4/15/7*.

 Notice of violation is- Presently in compliance with
 sued 10/9/73, Admin.    terms of order.
 order issued 1/31/7*.


 Notice of violation is- Presently in compliance with
 sued 10/31/73.          regulation

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                                                                  22
   STATE/CITX

 Indiana
    Cannellon
Indiana
   Largo
Indiana
   Indianapolis
Indiana,
   Cayuga
Indiana,
   Wabash
Indiana,
   Richmond
Indiana,
   Terre Haute
 COMPANY/TYPE
  OF SOURCE

 Can-Tex Industries,
 Inc.

    Rock Crushing

 Celotex corporation

    Indust.  Boilers

 Central Soya Co.

    Indust.  Boilers

 Colonial Brick Corp.

    Brick Mfg.

 Container Corp. of
 America

    Industrial
    Boilers

 Dana Corp.

    Foundry

J.W. Davis Co.

    Boilers
 POLLUTION PROBLEM    TYPE OF ACTION
                                              RESOLTS/STATO'S
 Violation of parti-
 culate matter emis-
 sion standard.
 Violation  of  parti-
 culate matter emis-
 sion standard.

 Violation  of  parti-
 culate matter emis-
 sion standard.

 Violation  of  parti-
 culate emission
 standard.

 Violation  of  parti-
 culate and sulfur
 oxide stds.
Notice of violation is- Presently in compliance with
sued 10/17/73 Admin.    terms of order.
order issued 1/21/74.
Notice of violation     Presently in compliance with
issued 1/23/74. Admin,  order.
order issued 3/26/74.
Notice of violation
issued 10/12/73.
Presently in compliance
Notice of violation is-
sued 12/4/73.
Notice of violation is- state schedule adopted, further
sued 10/9/73.           EPA action obviated.
Cupolas violate op-  Notice of violation is- Presently in compliance.
acity and partic-    sued 10/30/13.
ulate stds.

Violation of parti-  Notice of violation is- Presently in compliance
culate matter and    sued 4/26/74; Admin.    with terms of order.
opacity emission     order issued 6/15/74.
standards.

-------
                                                                       23
        STATE/CITY

      Indiana,
         Indianapolis
      Indiana,
         Marion
ro
GJ
      Indiana,
         Petersburg
      Indiana,
         Bloomington
      Indiana,
         East Chicago
      Indiana,
         .Indianapolis
      Indiana,
         Richmond
 COMPAHT/TYPB
  OF SOURCE

 Ford Motor Co.

    Boilers paint
    spraying, drying
    oven 6 degreaser.


-------
                                                                         2«
i
IN)
          STATE/CITY

        Indiana,
           Brownstovn
       Indiana,
          Mitchell
       Indiana,
          Mt. Summit
       Indiana,
          Muncie
       Indiana,
          Richmond
       Indiana,
          Bast Chicago
       Indiana,
          Derby
       Indiana,
          Indianapolis
 COMPANY/TYPE
  OF SOURCE

 Kieffer Paper Mill

    Boilers

 Lehigh Cement Co.

    Kilns

 Magaw Construction
 Inc.

    Asphalt Plant

 Magaw Construction
 Inc.

   Asphalt Plant

Magaw Construction
Inc.
                                            TYPE CF ACTION
                                                  RESCLTS/STATOS
   Asphalt Plant

Mobil Oil Corp.

   Refinery
 Violation of parti-
 culate  matter emis-
 sion standard.

 Violation of parti-
 culate  matter emis-
 sion standards.

 Violation of opaci-
 ty and  particulate
 matter  emission
 standards.

 Violation of opac-
 ty and  particulate
 matter  emission
 standards.

Violation  of opaci-
 ty and particulate
matter emission
standards.
    Violation of opa-
    city 6 sulfur oxide
t*--."^ limitations.
   Quarry

Nat'l Starch C Chen.
Corp.

   Industrial Boiler
                                                   opacity standards.
                      Violation of parti-
                      culate matter and
                      sulfur oxide emis-
                      sion standard.
                                            order issued 1/25/74


                                            su'edC12/19/73?ati0n
                                           Notice of  violation
                                           issued 9/10/73.
                                                  Presently in  compliance.
                                                                                                ******** **
                                                              compliance
                                             Source in compliance.
                               l/f JS^S?" i8' fresentiy ** compliance with
                              zi/19/73 admin.    terms of order.
                         order issued 2/13/74.

-------
                                                                       25
ro
tn
      Indiana,
         Gary vicinity
      Indiana,
         Indianapolis
      Indiana,
         Terr*  Haute
      Indiana*
         Indianopolia
      Indiana,
         Indianapolii
      Indiana,
         sellersburg
         BaMiend
      Indiana,
         LaPorte
COMPANY/TOPE
 or SOURCE

NIPSCO

   Bower Plant

Phillips Petro.
company

   Refinery

Public Service Co.
of Ind. Wabash Sta.

   Power Plant

RCA Corp.

   Electronics
   Manufacturer

Bock island
Refining Corp.

   Refinery

Sellersbnrg  Stone
Company

   Rock Crushing

Stauffer Che*.
Company

   Sulfuric  acid
   Manufacturer

Teledyne Casting
Service

   Foundry
                                                            PROBIiB*   TYPE OF ACTION
Violation of sulfur
oxide emission
standard.

Violation of hydro-
carbon emission
standards.
Violation of sulfur
oxide emission
standard.
Violation of hydro-
carbon emission
standard.
violation of hydro-
carbon and carbon
monoxide emission
standards.

Violation of opaci-
ty and particulate
matter emission
standards.

Violation of sulfur
dioxide emission
 Cupola violates
 particulate matter
 emission standard.
notice of violation is- Administrative order pending
sued 9/13/73.           Seventh Circuit decision.


Notice of violation is- EPA action pending legal inter-
sued 5/30/74.           pretation of BC reg.
Notice of violation.
sued 9/13/73.
Notice of violation is-
sued 7/1/74.
Notice of violation
issued 3/13/74.
Notice of violation
issued 1/10/74.
                                                                       Notice of violation
                                                                       issued 1/10/74.
In compliance with State
enforcement order.
Achieved compliance with
regulations.
                        in  compliance with terms of order
                        issued by  local agency.
 Notice of violation is- Evaluating stack test
 sued 4/6/74.             report.

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                                                                        26
         STATB/CITT

       Indiana,
          East Chicago
      Indiana,
          Indianapolis
      Indiana,
         Shoals
      Indiana,
         Habash
      Indiana,
          Gary
r\s
en
      Indiana,
         Habash
 COMPANY/TYPE
  OF soosca

 U.S. Gypsum Co.

    Milling

 Onion Carbide Corp.

    Industrial Boiler

 U.S. Gypsum

    Plaster Mfg.

 0.8. Gypsum Co.

    Mineral wool
    cupolas

 O.S.  Steel Corp.
 Gary works

    Steel Mill,
    Cement  Plant
Habash Smelting
Corp.

   Aluminum
   Plant
 Violation of Parti-
 culate matter and
 opacity standards.

 Violation of par-
 ticulate natter
 emission standard.

 Violation of parti-
 culate matter emis-
 sion standard.

 Violation of par-
 ticulate matter
 std.
 TYPE OF ACTiqs


 sued 10/5/73.
    BESOMS/STATES

is- on enforceable state
    schedule.
Operation of a ste-
el mill with cement
production facil-
ities  (Oniversal
Atlas Co.) in
violation of opaci-
ty and particulate
emission standards.
 Notice of violation
 issued 5/29/74.
 Notice  of violation
 issued  10/5/73.
Notice of violation
sued on  10/5/73.
Notice of violation
issued 4/18/73.  Order
issued June 22, 1973.
Violation of opaci-
ty standards.
Notice of violation
issued 3/28/73. Order
issued 5/30/73.
    On enforceable state Schedule
                                                                                                On enforceable State
                                                                                                schedule
                                                                                               On enforceable state  Schedule
    O.  S.  steel brought suit in  the
    O.S. District  Court,  Hammond,
    Ind. to void the  EPA order.  The
    Court  issued a consent decree on
    11/21/74, establishing a compli-
    ance schedule  for the facility.
    The first increment of progress
    requires the closing of  open
    hearth furnace #  4  in January 1975.

    Presently in compliance  with
    terms  of the order.

-------
                                                                 27
3>
ro
  STATE/CITY

Indiana,
   wabash
Indiana,
   East Chicago
Michigan,
   Hillsdale
Minnesota,
    International
    Falls
Minnesota,
    Brainerd
 Minnesota*
    Red Wing
 Minnesota,
    Minneapolis
COMPANY/TYPE
 qF SOURCE '_

wabash smelting,Inc.

   Smelter

Youngstown sheet
and Tube Co.

   Steel Mill

Hillsdale Foundry



Boise Cascade  Corp.

    Kraft,  pulp and
    paper mill.

 Burlington northern
 Inc.

    Ind. Boilers

 Conwed Corp.

    Foundry


 L. Dreyfus Corp.

    Grain Handling
                                            POLLUTION PROBLEM    TyPK Of ACTION
 Violation of parti-
 culate matter and
• opacity standards.

 Violation of parti-
 culate and opacity
 standards.
 Violation of parti-
 culate matter emis-
 sion standard.

 Violation of parti-
 culate matter emis-
 sion standard.
 Violation of parti-
 culate matter emis-
 sion standard.
 Cupola 6  blow
 chambers  violate
 sion standards.
 particulate stds.

 Marquette grain
 elevator, rail
 dump, storage
 bins violate
 particulate stds.
                                                                      Notice of violation it
                                                                      sued 6/27/74.
                                                                      Notice of  violation if
                                                                      sued 7/18/73.
                                                                       Notice of violation
                                                                       issued 4/9/74.
                                                                       Notice of violation
                                                                       issued 4/18/74.
                                                                       Consent order is-
                                                                       sued on 5/20/74.

                                                                       Notice of violation
                                                                       issued 2/20/74.
                                                                       Notice of violation
                                                                       issued 2/20/74.
                                                                       Notice of violation
                                                                       issued 8/8/74.
                                                                       Enforcement Order
                                                                       issued 11/15/74.
                                              Conference held 7/22/74.
                                                                                         On enforceable State order.
                                                                                         State legal action has been
                                                                                         initiated to enforce schedule.
                                                                                         Presently  in compliance with
                                                                                         terms of order.
                                                                                          State order issued 6/26/74.
                                                                                          On enforceable State order.

-------
                                                                      28
       siMB/cryy

     Minnesota,
        Buhl
    Minnesota,
       Springfield
    Minnesota,
       Collegeville
to  Minnesota,
00     Duluth
    Minnesota,
       City of
       Two Harbors
    Ohio,
       PortSMoath
    Ohio,
       Cleveland
    Ohio,
       Norwalk
 COMPANTXTTPB
  OF SOURCE

 Public Utilities
 Commission

    Power Plant

 Public Utilities
 Commission

    Power Plants

 St. John's Univ.

    industrial Boiler

 U.S. steel-
 South  works

    Coke ovens

 Water  S Light
 Plant

    Power Plant

 Empire-Detroit steel
 Steel  Co.

    Steel Mfg.

Jones  & Laughlin
 Steel  Corp.

    steel Mfg.

Ohio Liquid Dispos-
al, Inc.

   Incinerator
 POT-TrOTTQW PBQBT.1

 Violation of
 particulate
 stds.
 Violation of par-
 ticulate stds.
                      CTPE OF ACTION

                      Notice of violation
                      issued 7X25X74.
                      Notice of violation
                      issued 9X4X74.
SfiE1^?* e*4'  Mot^e of violation is-
Coke ovens violate
particulate stds.
Boiler »2
violates parti-
culate stds.
open hearth furnace
violate particulate
stds.
Sinter plant viola
tes particulate
stds.
Violation of parti
culate std.
                      Notice of violation
                      Issued 5X2/74.
                     Notice of violation
                     issued 11X5X74.
                     Notice of violation
                     issued 11X1X74.
                     Notice of violation
                     issued 11/29/74.
                     Notice of violation
                     issued 9/6/74.  '
 RESOLTSXST^Tns

 State handling conversion of
 customers to fuel oil.  will
 continue to monitor.
                                                                                              Enter agreement with state for
                                                                                              compliance early 1976.
                                                                                              Evaluating stack test report
                                                                                             State  filed suit  10X7/74.  Further
                                                                                             federal action deferred.     -*«««
Conference held 12/S/74.
Conference held 12X2X74.
State initiated action; Co.
now out of business.

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                                                                        29
ro
10
         STATE/CITY

      Ohio
          Canton
       Ohio,
          Cleveland
       Ohio,
          Massillon
       Ohio,
          Alliance
       Wisconsin,
          Whitewat*
       Wisconsin,
          Hixton
       Wisconsin,
          Milwaukee
       Wisconsin,
          Milwaukee
       Wisconsin,  .
          Milwaukee
COMPANY/TYPE
 OF SOPRCE__

Republic Steel Corp.

   steel Mfg.

Republic steel Corp.

   Steel Mfg.


Republic steel Corp.

   Coke ovens

Transue * Wns.

   Foundry
   Industrial
   boilers

Alpha Cast,  inc.

    Foundry

 Husky industries.
 Inc.

    Charcoal Mfr.

 Miller Brewing Co.

    Brewery



 Milwaukee solvay
 Coke co.

    Coke Ovens

 Pabst Brewing Co.

    Brewery
                                                             PROBLEM
                                                                            OF ACTION
Elec arc furnace
violate participate
stds.

Sinter Plant, BOF,
OHF, * Coke Batter-
ies violate parti-
culate stds.

Coke Batteries vio-
late particulate
stds.

Forging operation
& boilers violate
particulate stds.
                    Notice of violation
                    issued 9/27/74.
                    Notice of violation
                    issued 9/29/74.
                     Notice  of violation
                     issued  9/27/74.
                     Notice of violation
                     issued 8/15/74.
Violation of parti-  Notice of violation
culate stds.         issued 9/25/74.
RESULTS/STATOS

Conference held 11/8/74.
Awaiting policy decision on
pending 307 challenge.

Conference held 11/8/74.
                                                                                                conference held 11/8/74.
Control  program for boiler house
being evaluated.
                                             conference held 10/25/74.
                                             Co.  to submit control plans
                                             in mid-December.
Violation of  parti-   Notice  of  violation is-  State order  issued  6/28/74.
culate matter emis-   sued  4/3/74.
sion standard.
                      Notice of violation
                      issued 4/3/74.   Con-
                      sent order issued
                      6/6/74.
 Incompliance with terms of  consent
 order.
violation of parti-
culate matter emis-
sion. Federal com-
pliance schedule
for hydrocarbon
emission standard.
Violation of parti-
culate matter opa-
city and hydrocarbon
emission standards.

Violation of parti-  Notice of violation is- State order issued 6/20/74.
culate matter emis-  sued 4/3/74.
sion standard.
                      Notice of violation is- State order issued 6/11/74.
                      sued 1/9/74.

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                                                                 30
3>

•O
 Louisiana,
    Shreveport
 Louisiana,
    Elizabeth
Louisiana,
    Pollock
Louisiana,
   Tallnlah
Louisiana,
   Oodson
Louisiana,
   Baton Rouge
Louisiana,
   Larose
  COMPANY/TYPE
  _OF SOURCE

 Bird $ son Inc.
 Calcasieu Paper Co.
 Inc.

    Indus, boilers,
    pulp mill

 Carroll w. Maxwell
 Co., inc.

    conical Inciner-
    ator

 Chicago Mill 6
 Lumber  Co.

    Indus.  Boiler

 Bunt Lumber Co.,
 Inc.

    Conical
    Incinerator

 Ideal Cement

   Cement Kilns

LaFourcbe Pariah
Police Jury

   Open burning
                                                                 REGION VI
                                                    POLLUTION PBOBT.EM    IYPE OF ACT TON
                                                   Violation of parti-
                                                   culate matter
                                                    (Fugitive dust)  reg.
                                                                sued
                                             RESULTS/STATUS
                                         i8~  confer«>« waived negotiating
                                             agreed order.
                                                   Violation of opaci-
                                                   ty and particulate
                                                   matter regs.
                                                   Violation of opaci-
                                                   ty and incinerator
                                                   regs.
                     Notice of violation
                     issued 11/11X74.
                                                                                        Conference scheduled for
                                                                                        12/17/74.
                                                                  edll    ™
                                                                sued 11/29/74.
                                        i8~ Coof«ren«* requested not
                                            yet scheduled.
                                                                                           4- ssrsssss-
Violaton of opacity Notice of violation is-
particulate matter  sued 6/27/74.
and open burning
regulations.
                                                  Violation of parti-  Notice of violation
                                                  culate matter regs.  issued 8/12/74.
                                                  Violaton of open
                                                  burning reg.
                    Notice of violation
                    issued 10/3/74.
                                            Conference held 11/21/74,
                                            Order being prepared.
Conference waived,  source
reports compliance,  inspection
to be conducted.

-------
                                                31
        STATE/CEtt
          Ploritn       	
                     Plywood
                                   SWSAS- ass asss-
                       Oonical
                       Incinerator
                     Plywood Corp.

                       Conical
                       Incinerator
i
CO

-------
                                                                            32
oo
ro
             STATE/CITY

           Iowa
              Clinton
           Iowa,
              Ft.  Dodge
          Kansas,
             Kansas City
          Missouri,
             N. Kansas City
Missouri,
   Affton
          Missouri,
             Glover
          Missouri,
             Jefferson City
          Missouri
             Kansas City
         Missouri,
            Columbia
                       COMPANY/TYPE
                       _OF SOURCE

                       Clinton Com
                       Processing Co.

                          Grain Dryers

                       Georgia Pacific
                       Corp.
                          wallboard Mfg.
 Erman Corp.

    Railroad Car
    Salvage

 ADM Milling Co.

    Grain Mill

 Alpha Portland
 Cement

    Cement Mfg.

 Asarco


    Lead  Smelter

 Central  Electric
 Pwr Co-op.

    Power Plant

 Centropolis Crusher
 Inc.

    Rock  Crushing

Columbia Hater 6
Light Oept.

   Power plant
                                        REG ION VII
                        PQLLOTEON PROpT.EH    TYPE OP
                       Violation  of  par-
                       ticulate emission
                       standard
                       Violation of par-
                       ticulate and
                       opacity stds.
                                             Violation of open
                                             burning (particu-
                                             late matter)  reg.
Violation of par-
ti culate emission
standard.

Clinker cooler
violates particu-
late std.
                                            Violation of
                                            sulfur oxide emis-
                                            sion standard
                                            Co. refused to
                                            submit data
                                            required by section
                                            114 letter.

                                            Co. refused to
                                            submit data
                                            required by sec-
                                            tion 114 letter.

                                            Source did not test
                                            boilers 6 & 7  as
                                            required in Sec-
                                            tion 114  letter.
                                                                    RESULTS/STATUS
 forcement order issued
 7/31/74.

 Notice  of violation
 issued  7/11/74.
 Enforcement order
 issued  10/21/74.

 Notice  of violation
 issued  5/3/74
                                                                 Notice of violation
                                                                 issued 1/14/74.
Notice of violation
issued 9/28/73.
                     Notice of violation
                     issued 6/2/73.  Admin.
                     order issued 10/23/73.


                     Admin,  order is-
                     sued  5/2/73.
                    Admin, order
                    issued 6/6/73.
                                             Source presently in com-
                                             pliance with terms of
                                             order.
                                             open burning ceased, source
                                             now in compliance.
                    Admin.
                    8/8/73.
      order issued
 Source is now meeting
 terms of EPA approved
 compliance schedule.

 Source is now meeting terms
 of EPA approved  state com-
 pliance schedule,  further
 EPA action deferred.

 Order has been rescinded
 mooting present  litigation.
 Entering into stipulation with
 company to resolve case.

 Company complied with order.
                       Company  complied with order.
Information received,  boilers
6 fi 7 in compliance.

-------
             gTATE/CICT

           Missouri,
              Louisiana
           Missouri,
              Lebanon
:>

CO
           Missouri,
              Hannibal
           Missouri,
              Parkville
           Missouri,
              St. Louis
              county
           Missouri,
              St. Louie
              County
           Missouri,
              St. Louis
              county
           Missouri,
              Hannibal
           Missouri,
               Bonne Terre
COMPANY/TXPE
 9F SOURCE

Hercules, Inc.

   Fertilizer Mfr.

Independent Stave
Co,, Inc.

   Industrial
   Boilers
Marion County
Milling

    Grain  Dryers

Mid-Continent
Asphalt and
Paving Co.

    Asphalt  Mfg.

Union Electric Co.
Labadie Station

    Power  Plant

Onion Electric Co.
Meramec Station

    Power  Plant

Union Electric Co.
Sioux Station

    Power  Plants

Universal Atlas
Cement Co.

    Cement Mfr.

 valley Mineral
 Prod. Corp.

    Sock Crushing
                                                       POLLUTION PROBLEM    TYPE OF ACTION
In violation of
particulate matter
emissions stds.

Violation of par-
ticulate natter
(process emissions)
and opacity stds.
Violation of opaci-
ty standard
Violation of opaci-
ty  standard
Violation of
sulfur  oxide  emis-
sion  limitation
Violation of
sulfur  oxide  emis-
sion  limitation.
 Violation of
 sulfur oxide emis-
 sion limitations
 Co.  refused to
 submit data
 required by sec-
 tion 114 letter.

 Violation of
 particulate and
 opacity stds.
Notice of violation
issued 5/16/73.
Order issued 10/15/73.

Notices of violation
issued 7/9/73 and
10/10/73.  Enforce-
ment order issued
10/18/73.  Criminal
conviction returned
on 11/20/74 for
violating order.

Notice of violation
issued 6/16/74.
Notice of violation
issued 10/19/73.
Admin, order issued
4/25/74.
Notice of violation
issued 5/31/74.
Notice of  violation
issued 5/31/74.
 Notice of violation
 issued 5/31/74.
 Adminis.  Order
 issued 10/1/73.
 Notice of violation
 issued 1/14/74.
RESULTS/STATUS

Presently in compliance with
terms of order.
                                                                                                    Awaiting sentencing.
Source presently complying
with acceptable State
compliance  schedule
Source  has completed
installation of control
equipment and is in
compliance.


Company filed suit under
section 307 of the CAA
against EPA for review of
Missouri SIP.

Company filed suit under section
307 of  the CAA against EPA for
review  of Missouri SIP.
 Company filed suit under section
 307 of the CAA  against EPA for
 review of  Missouri SIP.
                                                                                                    company complied with order.
 On acceptable state
 compliance schedule.

-------
                                         3«
                                        TYPE OP ACTJQ^          RESOMS/SIATOS


      tnd^ie.   g^Jg-tj.      .JJgn. order issued     cony .ee^ng re.uire.en*.

                   particulate matter
Foundry            emission std.
                   for particxil*t«8     M«in. order issued
„ _
Power Plant

-------
                                                                            35
ico
in
           Colorado,
              Pueblo
            Utah,
               Salt: Lake City
            Utab,
               Woods Cross
            Utah,
               salt Lake City

            Utah,
               Salt Lake City
Utah,
   floods Cross
            Otah,
               salt take City
            Otah,
               Salt lake City
            Wyoming,
               Sundance
                                 COMPANY/TYPE
                                     SOORCE
                           Steel Corp.

                         Steel Mill
Concrete Products
Co.

   Cement Mfg.

Crown Refining Co.

   Refinery

W. B. Gardner


Granite Mill and
Fixture Co.

   Rock Crushing

Lloyd A. Fry Roof-
ing Co,

   Roofing Mfg.

Otah. Sand  6 Gravel

   Rock Crashing
                      western States
                      Engineering £
                      Milling

                      Roberts Construction
                      company

                         Quarry
                      Violation of
                      opacity std.
                                            Violation of
                                            opacity std
                  REGION VIII
                     TYPE OF ACTION

                     Notices of violation
                     issued 5/8,15,17 and
                     6/6/74.  Orders issued
                     8/27/74 and 10/17/74.

                     Notice of violation
                     issued 8/28/74.
                                            Violation of SIP
                                            new source review.
                                            Violation of
                                            opacity std.

                                            Violation of
                                            opacity standard.
violation of
opacity std.
                                            Violation of
                                            opacity std.
                      Violation of
                      opacity  standard
                       Violation of
                       ambient air std
                       for total sus-
                       pended particulates
                       as provided in
                       Wyoming SIP.
                     Notice of violation
                     issued 5/6/74.  Order
                     issued 7/26/74.

                     Notice of violation
                     issued 8-23-74

                     Notice of violation
                     issued 6/20/74.
Notice of violation
Issued 1/23/74.
                     Notice of violation
                     issued 6/20/74.
                     Notice of violation
                     issued 8/6/74.
                     Notice of violation
                     issued 8/16/73.
                     Order issued 9/28/73.
                        RESPITS/STATUS

                        Company complying with
                        terms of order.
                        in compliance.   Ceased
                        operation.
                        Complying with order
                        Plant production unit
                        closed.

                        Presently in compliance.
                        Presently in compliance
EPA action pending out-
come of State adminis-
trative hearing deter-
mination.

conference held 8/7/74.
No further violations noted.
Requesting improvement of
OSM Plan.

In compliance.
                        Presently in compliance with
                        terms of order.

-------
i
CO
           Arizona
              Benson
           Arizona,
              Mineral Park
           Arizona,
              Payson
           Arizona,
              Douglai
Arizona,
   Pag*
          Arizona,
             Snowflake
          Arizona,
             Snowflake
          California,
             Richmond
          California,
             north Bolly-
             wood
                      COMPAIW/TYPE
                       Cg SOORCE


                      Apache Powder Co.

                         Nitric  acid
                         plant and
                         open burning.

                      Ouval  Corp.

                         Mining, ore
                         roasting

                      Kaibab Industries

                         Incinerators
                      Phelps Dodge Corp.

                        copper Smelter
Salt River Navajo
Plant

   Power Plant
                     western Moulding Co.
                     Industries

                        Incinerators

                     Western Pine
                     Inc.

                        Incinerators

                     Allied  Chen, corp,

                        Sulfuric Acid
                        Plant

                    ALCO Gravure

                       Printing Co.
                                                      PQLLOTION PROBLEM
                                          36

                                        REGION IX

                                          TYPE OF ACTION
                                                                                                 RESOLTS/STATOS
and nitrogen oxide
emission standards.


Violation of sulfur
oxide emission
stds.
                                                                          issued 2/13/74
                     Two notices of viola
                     tion issued 10X7/74.
                                                                 state to bold
                                                                 1/9/75.
                                                                JJBJB?
                     Violation of opac-
                     ity & particulate
                     matter emission
                     standards.
                                                                         order issued 9/26/73.
                    Notice of violation is- Presently employino
                    sued 3/27/74; Admin.   with terms of order.
                    order issued 6/6/74.
                    amended 11/12/74.
compliance sched-    issued 9/18/74.
ule for particulate
matter.

Violation of opaci-  Notice of violation
ty standards.        issued 7/24/73.
                                                                Placed on State schedule.
                                                                Final compliance verified  5/8/7«.
                     Violation of opaci-
                     ty standards.        sued  7/24/73.
                    Violation of sulfur
                    oxide emission
                    standard.
                                                                              ,  x
                                                                             7/18/74.
                                       ls" Placed on state compliance
                                           schedule.  Achieved final
                                           compliance 8/26/74.


                                       is" EPA  is disapproving existing
                                           regs.   New regs to be promulgated.
                    SS^Si&E"10-  Sft&EftoSSr^ SPSS* -*»*•» -»•—
                    ««l>4u*.           1..U..J 10/M/71.

-------
                                                                        37
       California,
          Azuza
       California*
          Brawley
       California,
          Cloverdale
 i      California,
itf        Long Beach
COMPANY/TYPE
 OF SOURCE

Avery Label Co.

   Printing
Batley-Janss
Enterprise

   Alfalfa Mill
Cloverdale Plywood
Co. (Fibreboard
Corp.)

    Incinerator
 Dept.  of Water fi
 Power
POLLUTION PROBLEM

violation of hydro-
carbon stds.
violation of parti
culate and opaci-
ty emission
standards.
Violation of opaci
ty standards.
Violation of nitro-
gen oxide emission
                                                                             OF ACTIOB
                     consent order is-
                     sued 8/30/74.
RESOLTS/STATOS

Source complying with
terms of order.
                     Notice of violation is- In compliance  (source shut-
                     sued 12/14/73           down).
                     Notice of violation is- Order expired 7/1/74.
                     sued 8/10/73. Admin.    Compliance status will be
                     order issued 12/21/73.  verified.
                      Consent  order issued
                      7/9/74.
 Source is late in meeting
 some increments of progress
 while ahead in others.
       California,
          Vernon
       California,
           Cloverdale
    Power Plant

 Fibreboard Corp.

    incinerator

 GSR Lumber Co.

    incinerator
 Violation  of opaci-
 ty standard.


 Violation  of opaci-
 ty standards.
                      Notice of violation is- Achieved final compliance
                      sued 3/11/73.  Admin.    7/8/74.
                      order issued 12/21/73.

                      Notice of violation is- Achieved final compliance.
                      sued 8/10/73. Admin.
                      order issued 12/20/73.

-------
                                                                  38
   STATB/cmr

 California,
    South Gate
California,
    Fort Bragg
 COMPANY/TYPE
  Of SQDBCg


 Gen* Motors Corp

    Auto Nfr.
 Georgia Pacific
 Corp.

    incinerator
 PQLLOTIOH PROBI.Bf    TYPE OP
 Failure to submit
 a compliance
 schedule for hydro-
 carbon emission
 standards.

 Violation of opaci-
 ty standard.
Consent order is-
sued 6/3/74.
                         RESOLTS/STATDq


                         Achieved final compliance
                         8/5/71.
                                 flnal c°Bpllance
                                                                  order issued 12/20/73.
California.
       Angelet
California,
   Fontana
California,
   covelo
California,
   Fort Bragg
 Gravure W.  Printing
 CO.

   Printing
Kaiser Steel Corp.

   Steel Mill
Louisiana Pacific
Corp.

   Incinerator

Louisiana Pacific
CO.

   Incinerator
                                             sion standard.
                      emission standards,
Violation of opaci-
ty standard.
                                                                 order issued  6/11/74,
                                                                 amended 11/11/7*.
                                             Achieved final
                                                                 orders issued 12/20/73.
     fl,             18~
sued 8/10/73. Admin.    5/14/74.
order issued 12/20/73.
                                      compliance

-------
                                                                 39
California,
   Calpella
California,
   cloverdale
California,
   Monolith,
California,
   Martinez
California,
   Martinez
California,
    Okiah
California,
   Anderson
COMPANY/TTPB
 OF SOURCE

Masonite Corp.,

   Incinerator

Masonite Corp.


   Incinerator

Monolith Portland
Cement Plant

   cement Kilns

Monsanto-Avon Plant

   Indus. Boilers

Phillips Petro.
Co. - Avon Plant

   Refinery

Redwood Coast
Lumber Co.

   Incinerator

Simpson Lee
Paper Co.

   Boiler
                                            Pnr.T.tTTTON PROBLEM
                                                                 TYPE OF ACTION
                                                                                         RESm.TS/STflTaS
Violation of opaci-  notice of violation is- Achieved final compliance
ty standards.        sued 8/10/73. Admin.    6/1/74.
                     orders issued 12/20/73.

Violation of opaci-  Notice of violation is- Achieved final compliance
tv std               sued 8/10/73.  Admin.   6/27/74.
 *                   order issued 12/20/73.
Violation of opaci-
ty and paniculate
emission standards.
Violation of sulfur
oxide emission std.
Violation of sulfur
oxide emission std.
Violation of opaci-
ty  standard reg.
violation of opaci-
ty particulate and
sulfur oxide  (TBS)
emission standard.
Notice of violation is- Presently in compliance
sued 11/20/73; admin.   with terms of order.
order issued 5/10/74.


Notice of violation is- Conference held 8/29/74.  RPA is
sued 7/18/74.           disapproving reg., new regs to be
                        promulgated by EPA.

Notice of violation is- Conference held 8/29/74.  EPA is
sued 7/18/74.           disapproving reg., new regs to be
                        promulgated by EPA.
                        Achieved final compliance
                        7/8/74.
Notice of violation it
sued 8/10/73.  Admin.
order issued
12/21/73.

Notice of violation is- Presently in compliance
sued 3/21/74. Admin.    with terms of order.
order issued 4/9/74.

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                                                                  40
   STATE/ciry

 California,
    El segundo
 California,
    Richmond
 California,
    Carson
California.
    Kern cty.
California,
    Los Anoeles
Hawaii,
   Halaula
Nevada,
   Gabbs
Nevada,
   S. Calif.
 COMPANY/TYPE
  OF SOORCB

 Standard Oil of
 Calif,

    Oil Refinery

 Standard Oil of
 Calif.
 Texaco,  Inc.


    Sulfur Rec-
    overy Plant

 U.S.  Borox

    Mining

 Oniroyal,  Inc.

    Rubber  Mfr.
Kobala Corp.
Sugar Mill
   Industrial
   Boiler

Basic Industries

   Quarry Hill


S. Calif. Edison

   Power Plant
                      TYPE OT ACTION
 Violation of Calif.
 review of new
 sources and mod-
 ifications regs.

 Violation of sulfur
 oxide emission
 standard.

 Violation of sulfur
 oxide emission
 standards.
 Violation of opac-
 ity std.
 Failure, to submit
 approvable com-
 pliance schedule
 pursuant to Fed-
 erally promulgated
 regulation.

 Violation of opaci-
 ty and particulate
 matter emission
 standards.

Violation of parti-
culate £  opacity
emission  stds.
                         RESULTS/STATUS

                                  final
                                                   8/12/74.
                                                                  order issued 3/5/74.
                     i8" S01*6""" be" 8/13/74.  EPA is
                         disapproving regulation; will pro-
                         mulgate new requirements.
                                                                  order issued 5/9/74.
 Notice of violation
 issued 10/10/74.
                      - AcMeved £inai
Conference held 12/9/74.
O. S. Borax to submit
compliance schedule to EPA.
                        comFlyin9 with
                                                                  order issued 6/18/74.
Consent order is-
sued 7/16/74.
Violation of opaci-
ty and sulfur oxide
emission stds.
Notice of violation is- Conference held 6/13/74.
sued 5/2/74.            state adopted revised reg «
                        placed source on compliance.
                        schedule 11/8/74.

Notice of violation is- Presently in compliance
sued 7/25/73! order is- with terms of order
sued 11/1/73, ammended
9/18/74.

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Idaho
   Pocatello
COMPANY/TYPE
 OF SOURCE

FMC Corp.

   Phosphorus Mfg.
                                                              REGION X
                                            POU.nCTOM PROBLEM    TYPE OF ACTION
Cooler fl violates
particulate stds.
Notice of violation
issued 3/8/7a.  Order
issued 11/21/74.
                                             RESOLTS/STATUS
Idaho
   Lewiston
Washington,
   Connell
Washington,
   Dayton
Washington,
   Lament
Washington,
Oaksdale
Washington,
   Long Beach
Washington,
   Whitman
Potlatch Corp.


   Kraft Pulp Mill
   Indust. Boilers

Connell, City of

   Open burning



Dayton, City of

   Open burning

Lamont, City of

   Open burning


Oaksdale,  City of

   Open burning

Peninsula  Sani-
tation Service

   Open  burning

Whitman County

   Open burning
Violation of
opacity and
particulate emis-
sion stds.
Violation of open
burning  (Particu-
late) Stds.
Violation of open
burning  (Particu-
late) stds.

Violation of open
burning  (partic-
ulate) stds.
Violation of open
burning  (Particu-
late) Stds.

Violation of open
burning  (particu-
late) stds
 Violation of open
 burning (particu-
 late)  Stds.
Notice of violation
issued 2/8/7U.
Order issued 4/8/7U.
                        Presently in compliance
                        with terms of order.
                                                                                         In compliance with order.
Notice of violation
issued 9/21/73.
Admin, order issued
12/11/73.  Amended
order issued 9/19/7*.

Notice of violation     Presently complys with
issued 9/21/73.  Admin, order*
order issued 12/12/73.
                        Presently complying with
                        order.
Notice of violation
issued 9/21/73.
Admin, order
issued 12/12/73.

Notice of violation     Presently complies
issued 9/21/73.  Admin, with order.
order issued 12/12/73.
Notice  of  violation
issued  10/17/73.
                        Compliance status being
                        reverifled.
 Notice of violation     In technical violation
 issued 9/21/73.   Admin,  of order,  county
 order  issued 12/12/73.   taking action.

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                                      SUMMARY OF CURRENT EPA ENFORCEMENT ACTIONS

                                                        UNDER

                            §112 - RATIONAL EmSSIOH STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAPS)

                                                  December 1974
 STATE/CITY
 COMPANY/TYPE
  OF  SOURCE
 POLLUTION PROBLEM
                                                                              TYPE OF ACTION
                                                                         RESULTS/STATUS
 REGION I

[  Massachusetts,
>    N.  Brookhaven
  Rhode,  Island,
     Pawtucket
  Vermont
    Eden
Asbestos Textile

  Textile Mfr.
American Insula-
ted Wire

  Wire Mfr.

Eden, Town of

  Road surfacing
 Violation of NESHAPS
 (asbestos) standards
Violation of NESHAPS
(asbestos) standards
Asbestos Tailings;
source failed to
respond "to §114.
letter.
Admin,  order  is-
sued  7/17/74.
Administrative
Issued 8/1/74.
Administrative
order issued
5/9/74.
Source  is also in violatior
with OSHA Regulations.
Will shutdown or comply
with EPA_& OSHA requirement
by 12/31/74


Maintenance to control
device ceased violation,
presently in compliance.
§114 response received.

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STATE/CITY
COMPANY/TYPE
 OF SOURCE
                                         POLLUTION PROBLEM
                          TYPE OF ACTION
                                                                                                 RESULTS/STATUS
Vermont,
  Hyde Park
Vermont,
  Jay
Vermont,
  Lowe!1
Vermont,
  Newport
Hyde Park, Town of  Asbestos Tailings;
  Road surfacing    source failed to
                    respond to 3114
                    letter.
Jay, Town of
  Road surfacing
Lowell, Town of
  Road surfacing
Newport, Town of
   Road surfacing
Asbestos Tailings;
source failed to
respond to 9114
letter.

Asbestos Tailings;
source failed to
respond to §114
letter.

Asbestos Tailings;
source failed to
respond to §114
letter.
                          Administrative order
                          issued 5/9/74.
Administrative order
issued 5/9/74.
Administrative order
issued 5/9/74.
Administrative order
issued 5/9/74.
                              Possible Cease and Desist
                              Order.
Possible Cease and Desist
Order.
                                                                                                  §114 response  received.
                                                                                                  §114  response  rceived.
 CO

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. STATE/CITY
REGION II
New Jersey,
Patterson

New Jersey
Millington

i, New Jersey,
*• Boundbrook
New York
Solvay
COMPANY/ TYPE
OF SOURCE

Brassbestos Mfg.
Corp.
FHctlon mtl .
mfg.
National Gypsum
Co.
Asbestos shingle
mfg.
Union Carbide Corp.
Plastic mfg.
Allied Chemical
Corp.-Ind.
Chemical Div,
POLLUTION PROBLEM

Violation of NESHAPS
reporting requirements

Violation of NESHAPS
reporting requirements

Violation of NESHAPS
reporting requirements
Violation of NESHAPS
reporting requirements
TYPE OF ACTION

§113 enforcement order
issued 11/22/74.

§113 enforcement order
issued 10/24/74

§113 enforcement order
issued 10/16/74
§113 enforcement order
issued 6/25/74.
RESULTS/ STATUS

Report received, under
review.

Report received, under
review.

Source indicates use of
asbestos will be discontinuec
Awaiting confirmation.
Source complied with order.
Chi oral kali plant
New York,
Watervliet
Passonno Corp.
Violation of NESHAPS
reporting requirements
§113 enforcement
order issued 2/8/74.
Source complied with order.
Bldg.  Demolition

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STATE/ CITY
REGION V
Illinois,
Chicago
COMPANY/ TYPE
OF SOURCE
Branderberg
Wrecking Co.
POLLUTION PROBLEM
Failed to notify EPA
prior to demolition
of building containing
TYPE OF ACTION
Criminal action re-
referred to U.S. Attorney
1/28/74.
RESULTS/ STATUS
Dependent motion to dismiss
criminal information
pending before court.
    Illinois,
      Chicago
01
    Illinois,
     Chicago
    Illinois,
                       Demo!ition
Harvey Wrecking
Co.

  Demolition Co.
Keystone Wreck-
ing Co.

  Demolition Co.
Nardi Wrecking
Co.

  Demolition Co.
as required by NESHAPS
regs.

Failed to remove
friable asbestos
from building prior
to demolition as
required by NESHAPS
regs.

Failed to remove friable
asbestos from building
prior to demolition
as required by NESHAPS
regs.

Failed to notify EPA
prior to demolition of
building containing
friable asbestos and
did not remove asbestos
as required by NESHAPS
regs.
Criminal action re-
ferred to U. S. Attorney
1/28/74.
Administrative order
issued 12/18/73.
Criminal action referred
to U. S. Attorney 1/28/74.
Dependent motion to dismiss
criminal information
pending before court.
Presently in compliance
with term of order.
Dependent motion to dismiss
criminal information
pending before court.

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STATE/CITY
COMPANY/TYPE
 OF SOURCE
.POLLUTION PROBLEM
TYPE OF ACTION
RESULTS/STATUS
Illinois,
  Chicago
Illinois,
  Chicago
Toledo,
  Ohio
Michigan,
  Detroit
Nat'l Wrecking Co. Failed to remove friable
                   asbestos from building
  Demolition Co.   prior to demolition as
                   required by NESHAPS regs.
Speedway Wreck-
ing Co.

  Demolition Co.
 Failed  to  notify  EPA
 prior to demolition of
 required by  NESHAPS regs.
  B & C Trucking & Failed to respond to
  Wrecking, Co.    §114 letter concerning
                   NESHAPS asbestos demoli-
    Wreckers       tion standards and noti-
                   fication requirements.
  Adamo Wrecking
  Co.
    Demolition Co.
Failed to notify  EPA
prior to demolition
of building containing
friable asbestos  and
did not remove asbestos
as required by NESHAPS
regs.
                          Criminal action
                          referred to U. S.
                          Attorney 1/28/74.
Administrative order
issued 12/18/73.
                          Admin, order  issued
                          1/11/74.
Administrative order
issued 12/18/73; criminal
action, referred to U. S.
Attorney 4/30/74.
                             Dependent motion to dismiss
                             criminal information
                             pending before court.
Presently in compliance
with term of order.
                             Presently in compliance
                             with terms of order.
Case awaiting trial.

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STATE/CITY
Michigan,
Octroi t


Michigan,
Detroit
COMPANY/ TYPE
OF SOURCE
Cuyahoga Wreck-
ing Co.


Sarko Equip. Inc.


POLLUTION PROBLEM
Failed to remove friable
asbestos from building
prior to demolition as re-
quired by NESHAPS regs.
Violation of NESHAPS
asbestos demolition

TYPE OF ACTION
Admin, order issued
issued 12/18/73.


Admin, order issued
4/8/74.


RESULTS/ STATUS
Presently


Presently

in compliance.


in compliance.

Demolition Con-
tractor
regs.  (demolition
procedures and re-
porting requirement).

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-p»
oo
        STATE/CITY
   COMPANY/ TYPE
   of SOURCE
 POLLUTION PROBLEM    TYPE OF ACTION
RESULTS/ STATUS
        REGION VI

        Louisiana,
           New Orleans
Big Chief, Inc
                             81 dg. Demolition
Violation of NESHAPS  Criminal action re-
asbestos requirements ferred to U. S.
                      Attorney 8/29/74.
Awaiting U. S. Attorney
to initiate criminal
action
        Texas,
           Dallas
J&J Wrecking and
Excavation Co.

  Bldg. Demolition
Violation of NESHAPS  Admin. Order issued
reporting requirement 2/22/74.
Source is complying with
terms of order

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STATE/CITY
COMPANY/TYPE
 OF SOURCE
POLLUTION PROBLEM
TYPE OF ACTION
RESULTS/STATUS
REGION VII

  Kansas,
    Topeka
  Missouri,
    Kansas City
  Missouri,
    Hannibal
Vince Bahm Wreck-
ing Co.

  Demolition
Failure to report as re-
quired in NESHAPS re-
gulations.
Centropolis Crusher Refused to submit in-
Inc.                formation required in
                    Section 114 letter.
  Stone Crusher
Universal Atlas
Cement

  Cement Process
Refused to submit in-
formation requested by
Section 114 letter.
Criminal action re-
ferred to U. S.
Attorney on 8/16/73.
Administration order
issued Feb. 25, 1974.

Order issued on
6/6/73.
Admin, order issued
10/1/73.
Presently in compliance
with order.
                                                        All information required in
                                                        the order has been provided.
                                                        Source now in final  complian
Source complied with terms
of order.

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I
01
o
        STATE/CITY
COMPANY/ TYPE
OF SOURCE
POLLUTION PROBLEM
                                                                    TYPE OF ACTION
                      RESULTS/STATUS
        REGION IX

        Arizona,
           Globe
    Jaquays Mining Corp.

       Asbestos Mill
   Violation of NESHAPS
   (asbestos) emission
   limitation.
Administrative Order
issued 11/29/73.
Presently in compliance
with terms of order
        California,
           Riverside
    Certain-Teed Prod.
    Corp.
       Rock crushing
   Violation of NESHAPS
   (asbestos) emission
   limitation
Aministrative Order
issued 9/23/74.
Presently in compliance
with terms of order

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STATE/CITY
COMPANY/TYPE
 OF SOURCE
.POLLUTION PROBLEM
TYPE OF ACTION
RESULTS/STATUS
Illinois,
  Chicago
Illinois,
  Chicago
Toledo,
  Ohio
Michigan,
  Detroit
Nat'l Wrecking Co. Failed to remove friable
                   asbestos from building
  Demolition Co.   prior to demolition as
                   required by NESHAPS regs.
Speedway Wreck-
ing Co.

  Demolition Co.
 Failed  to  notify  EPA
 prior to demolition of
 required by  NESHAPS regs.
  B & C Trucking & Failed to respond to
  Wrecking, Co.    §114 letter concerning
                   NESHAPS asbestos demoli-
    Wreckers       tion standards and noti-
                   fication requirements.
  Adamo Wrecking
  Co.
    Demolition Co.
Failed to notify  EPA
prior to demolition
of building containing
friable asbestos  and
did not remove asbestos
as required by NESHAPS
regs.
                          Criminal action
                          referred to U. S.
                          Attorney 1/28/74.
Administrative order
issued 12/18/73.
                          Admin, order  issued
                          1/11/74.
Administrative order
issued 12/18/73; criminal
action, referred to U. S.
Attorney 4/30/74.
                             Dependent motion to dismiss
                             criminal information
                             pending before court.
Presently in compliance
with term of order.
                             Presently in compliance
                             with terms of order.
Case awaiting trial.

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STATE/CITY
Michigan,
Octroi t


Michigan,
Detroit
COMPANY/ TYPE
OF SOURCE
Cuyahoga Wreck-
ing Co.


Sarko Equip. Inc.


POLLUTION PROBLEM
Failed to remove friable
asbestos from building
prior to demolition as re-
quired by NESHAPS regs.
Violation of NESHAPS
asbestos demolition

TYPE OF ACTION
Admin, order issued
issued 12/18/73.


Admin, order issued
4/8/74.


RESULTS/ STATUS
Presently


Presently

in compliance.


in compliance.

Demolition Con-
tractor
regs.  (demolition
procedures and re-
porting requirement).

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-p»
oo
        STATE/CITY
   COMPANY/ TYPE
   of SOURCE
 POLLUTION PROBLEM    TYPE OF ACTION
RESULTS/ STATUS
        REGION VI

        Louisiana,
           New Orleans
Big Chief, Inc
                             81 dg. Demolition
Violation of NESHAPS  Criminal action re-
asbestos requirements ferred to U. S.
                      Attorney 8/29/74.
Awaiting U. S. Attorney
to initiate criminal
action
        Texas,
           Dallas
J&J Wrecking and
Excavation Co.

  Bldg. Demolition
Violation of NESHAPS  Admin. Order issued
reporting requirement 2/22/74.
Source is complying with
terms of order

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STATE/CITY
COMPANY/TYPE
 OF SOURCE
POLLUTION PROBLEM
TYPE OF ACTION
RESULTS/STATUS
REGION VII

  Kansas,
    Topeka
  Missouri,
    Kansas City
  Missouri,
    Hannibal
Vince Bahm Wreck-
ing Co.

  Demolition
Failure to report as re-
quired in NESHAPS re-
gulations.
Centropolis Crusher Refused to submit in-
Inc.                formation required in
                    Section 114 letter.
  Stone Crusher
Universal Atlas
Cement

  Cement Process
Refused to submit in-
formation requested by
Section 114 letter.
Criminal action re-
ferred to U. S.
Attorney on 8/16/73.
Administration order
issued Feb. 25, 1974.

Order issued on
6/6/73.
Admin, order issued
10/1/73.
Presently in compliance
with order.
                                                        All information required in
                                                        the order has been provided.
                                                        Source now in final  complian
Source complied with terms
of order.

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I
01
o
        STATE/CITY
COMPANY/ TYPE
OF SOURCE
POLLUTION PROBLEM
                                                                    TYPE OF ACTION
                      RESULTS/STATUS
        REGION IX

        Arizona,
           Globe
    Jaquays Mining Corp.

       Asbestos Mill
   Violation of NESHAPS
   (asbestos) emission
   limitation.
Administrative Order
issued 11/29/73.
Presently in compliance
with terms of order
        California,
           Riverside
    Certain-Teed Prod.
    Corp.
       Rock crushing
   Violation of NESHAPS
   (asbestos) emission
   limitation
Aministrative Order
issued 9/23/74.
Presently in compliance
with terms of order

-------