PROGRESS IN THE PREVENTION AND
CONTROL OF AIR POLLUTION
IN 1975
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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PROGRESS IN THE PREVENTION AND
CONTROL OF AIR POLLUTION
IN 1975
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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CONTENTS
LIST OF TABLES 111
LIST OF FIGURES iv
PREFACE v
I. INTRODUCTION AND SUMMARY 1
Attainment 1
Air Quality Trends 2
State Implementation Plan Issues 2
Stationary Source Regulations 3
Mobile Source Regulations 4
Stationary Source Enforcement 4
Mobile Source Enforcement 5
Litigation 6
Research 6
Control Agency Support 6
II. THE STATUS OF STATE IMPLEMENTATION PLAN APPROVALS,
DISAPPROVALS, AND PROMULGATIONS, AND PROGRESS TOWARD
ATTAINMENT OF NATIONAL STANDARDS 8
Attainment of National Ambient Air Quality Standards .... 8
Revisions to State Implementation Plans 11
SIP Developments 15
Approval/Disapproval Status of Implementation Plans 25
III. DEVELOPMENT OF AIR QUALITY CRITERIA AND RECOMMENDED
EMISSION CONTROL REQUIREMENTS 34
National Ambient Air Quality Standards (NAAQS) 34
New Source Performance Standards (NSPS) 34
National Emission Standards for Hazardous Air
Pollutants (NESHAPs) 41
Health Effects Research 41
IV. STANDARDS SET OR UNDER CONSIDERATION PURSUANT TO
TITLE II 51
Motorcycle Regulations 51
Revised Light Duty Truck Regulations ". . . 5?
Interim Heavy Duty Vehicle Emission Regulations 53
Sulfuric Acid Emission Standard 53
Revised Evaporative Emission Regulations 54
Non-Methane Hydrocarbon Exhaust Emission Standards 55
Aircraft Emissions Regulatory Actions . 5fi
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CONTENTS (continued)
V. CONTROL OF MOBILE SOURCE EMISSIONS AND RELATED
RESEARCH EFFORTS ....................... 57
Measures Taken to Implement Mandated Title II
Emission Standards ..................... 57
Assessment of Mobile Source Technology ............ 62
Additional Activities in the Mobile Source Area ...... ! 65
VI. THE STATUS OF ENFORCEMENT ACTIVITIES ........... 74
Stationary Source Enforcement ................ 74
Mobile Source Enforcement .................. 87
Compliance by Federal Activities .............. 94
Summary of Litigation in 1975 ................
•VII. STATUS OF AIR MONITORING AND TRENDS IN AIR QUALITY ..... 106
Summary of Ambient Air Quality Data ............ 115
Trends in Air Quality, 1970-1974 .............. 117
Monitoring Implications of the Energy Supply and
Environmental Coordination Act (ESECA) .......... 120
VIII. THE DEVELOPMENT OF INSTRUMENTATION TO MONITOR EMISSIONS
AND AIR QUALITY .................. .... 121
Monitoring Developments .................. 122
Quality Control ...................... 123
IX. DEVELOPMENT OF NEW AND IMPROVED AIR POLLUTION CONTROL
TECHNIQUES FOR STATIONARY SOURCES .............. 125
Sulfur Oxides ...................... 126
Nitrogen Oxides (NO ) .................... 128
Particulates . . .x ................... ] ] 129
Other Pollutants .................. .'.'.'.' 130
X. STATUS OF STATE, INTERSTATE, AND LOCAL POLLUTION CONTROL
PROGRAMS ESTABLISHED UNDER AND ASSISTED BY THIS ACT ..... 132
Federal Financial Assistance to Air Pollution Control
Agencies .......................... 135
Progress of State and Local Air Pollution Control Programs . ! 135
XI. REPORTS AND RECOMMENDATIONS OF THE PRESIDENT'S AIR
QUALITY ADVISORY BOARD ................... 144
APPENDIX ............................ 145
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LIST OF TABLES
Table Page
II-l. Monitoring Requirements for Existing Sources Subject to
Emission Limitations as Part of an Approved Implementation
Plan 20
11-2. Status of Selected Portions of the State Implementation Plans. 27
III-l. Status of Standards of Performance 37
111-2. Regulatory Actions Related to Sections 111 and 112 40
V-l. Emission Standards for.Motor Vehicle Classes 60
VI-1. Compliance Status of Major Steel Processes vs all Major
Stationary Installations 82
VII-1. National Summary of Air Monitoring Stations Reporting 1974
Data to the National Aerometric Data Bank by September 1975. 108
VII-2. National Summary of 1974 AQCR Attainment Status By Pollutant,
As Reported to the National Aerometric Data Bank 109
VII-3. Growth in Number of Monitoring Instruments, 1970-1974 .... 110
X-l. Organizational Location of State and Local Control Agencies
Receiving Federal Funds in 1975 133
X-2. Distribution of Funds By Jurisdictional Areas of State and
Local Control Agencies 134
X-3. Summary of Federal Support to State and Local Air Pollution
Control Agencies By State 136
X-4. Estimated Man-Years of Effort Employed By State and Local
Air Pollution Control Agencies 141
X-5. Estimated Percentage of Resources Devoted to Air Pollution
Control Activities of National Priority By State and Local
Control Agencies in FY 75 143
m
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LIST OF FIGURES
Page
VII-1. Distribution of AQCRs Reporting Second High 24-Hour
Values for Particulates Ill
VI1-2. Distribution of AQCRs Reporting Maximum Annual Mean
Values for Particulates Ill
VII-3. Distribution of AQCRs Reporting Second High 24-Hour
Values for Sulfur Dioxide 112
VI1-4. Distribution of AQCRs Reporting Maximum Annual Mean
Values for Sulfur Dioxide 112
VII-5. Distribution of AQCRs Reporting Second High 1-Hour
Values for Carbon Monoxide 113
VII-6. Distribution of AQCRs Reporting Second High 8-Hour
Values for Carbon Monoxide 113
VII-7. Distribution of AQCRs Reporting Second High 1-Hour
Values for Oxidants 114
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;
(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."
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This report covers the period January 1 to December 31, 1975, and
describes the issues involved in the prevention and control of air
pollution and the major elements of progress toward that goal that
have been made by EPA since the last report.
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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 1975 in the control and prevention
of air pollution. Chapter headings are taken from the topics listed in
section 313 of the Clean Air Act, and additional measures of progress have
been added where appropriate. The major events which took place during
1975 are briefly summarized here, grouped by topic, and are discussed more
fully in the text of the report.
ATTAINMENT
0 Of the 247 Air Quality Control Regions (AQCRs), 115 (47 percent)
are judged likely to attain the primary National Ambient Air
Quality Standard (NAAQS) for total suspended particulate (TSP)
by the statutory date. Major factors contributing to non-
attainment have been identified for many of these AQCRs, including
fugitive dust (67 AQCRs), point sources (19 AQCRs), and smaller
sources (14 AQCRs). It should be noted that some AQCRs have a
combination of these problems.
0 For sulfur dioxide (S02), 212 AQCRs (86 percent) are judged likely to
attain the primary NAAQS by the statutory date. For the 35 AQCRs
that are not expected to attain the standard, analysis shows
the problem to be primarily emissions from large point sources;
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further enforcement of existing regulations is expected to
result in attainment of the SCL standard.
0 Current data show that in a number of AQCRs the carbon
monoxide (CO) standard is not being attained. When the
Federal Motor Vehicle Emission Standards are fully implemented,
however, the CO standard is expected to be attained in all but
a few areas of the nation.
0 The oxidant standard continues to be violated in many AQCRs,
urban as well as rural. Research to better characterize the
transport problems associated with oxidant is being emphasized
along with the implementation of reasonably available control
technology.
AIR QUALITY TRENDS
o Based on composite annual average data from 1096 TSP monitoring
3
sites, the ambient concentrations have declined from 80 yg/m to
66 yg/m3 for the period 1970-1974.
0 Based on composite annual average data from 258 SOp monitoring
3
sites, the ambient concentrations have declined from 38 yg/m in
1970 to 26 yg/m3 in 1974.
STATE IMPLEMENTATION PLAN ISSUES
o For all non-attainment areas, the efforts of EPA and state/local
agencies will focus on the control of emissions from existing
sources in high-pollution AQCRs. Future action will be based
on an analysis of the adequacy of the State Implementation Plan
(SIP) and an emphasis on enforcement activities.
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0 Final designation of 168 Air Quality Maintenance Areas was
published in 1975.
0 EPA suspended indefinitely those portions of the indirect
source regulations requiring pre-construction review of
parking-related facilities.
0 EPA's activities under ESECA -- review of coal conversion
submittals and a review of State Implementation Plans --
were completed.
STATIONARY SOURCE REGULATIONS
0 New Source Performance Standards (NSPS) for electric arc furnaces
and five phosphate fetrilizer processes were promulgated in
1975. NSPS for five more categories were promulgated in January
1976: primary copper, lead, and zinc smelters; coal cleaning
plants; and primary aluminum reduction plants.
0 In 1975 EPA promulgated regulations to implement section lll(d)
covering emissions from existing sources of "designated"
pollutants, i.e., those for which New Source Performance
Standards have been set but for which National Ambient Air
Quality Standards or National Emission Standards for Hazardous
Air Pollutants do not exist.
0 EPA promulgated revisions to the National Emission Standards
for Hazardous Air Pollutants (NESHAPs) for asbestos and
mercury, modifying the scope of regulations and amending the
test methods.
0 Vinyl chloride was added to the list of hazardous air
pollutants,and emission regulations were proposed on
December 24, 1975.
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0 Continuous monitoring regulations were promulgated October 6, 1975.
0 Modification regulations were promulgated December 16, 1975.
0 Revisions to the Stage II Gasoline Vapor Recovery regulations
were proposed October 9, 1975.
MOBILE SOURCE REGULATIONS
0 EPA imposed interim standards of 1.5 grams/mile (g/mi)
hydrocarbons (HC) and 15 g/mi CO for 1977 automobile emissions.
0 EPA waived Federal preemption for 1977 California State Motor
Vehicle Pollution Control Standards of 0.41 g/mi HC, 9 g/mi CO,
and 1.5 g/mi nitrogen oxides.
0 During 1975 the certification of most 1976 model year light
duty vehicles and light duty trucks was completed, and
certification of 1977 models began.
0 Notice of Proposed Rulemaking to control emissions from new
motorcycles was published in October 1975.
° Notice of Proposed Rulemaking to set more stringent standards
for evaporative emissions from light duty passenger vehicles
and light duty trucks was published in December 1975. If the
standards are promulgated at the proposed level, evaporative
emissions will be reduced in 1990 by 3,350,000 tons/year.
STATIONARY SOURCE ENFORCEMENT
o During 1975, nearly 600 enforcement actions were initiated
against stationary sources, bringing the total number since
1972 to about 1000.
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° Of the approximately 20,000 identified major sources, 82 percent
now comply with applicable emission limits or are meeting
compliance schedules, an increase of almost 2700 over 1974.
o As of October 1975, 246 sources have been found subject to NSPS,
and compliance levels of 89 percent have been achieved.
o Regulations were promulgated April 16, 1975, requiring compliance
with both air and water standards by facilities involved in
Federal procurement activities.
MOBILE SOURCE ENFORCEMENT
0 EPA conducted approximately 18,500 inspections of service
stations to ensure compliance with the unleaded fuel regulations.
Of the 15,000 samples taken, only 160 were found to be contam-
inated with lead. Approximately 3500 warnings and 260 complaints
have been issued, and about $31,000 in penalties were collected
in 1975.
0 Four motor vehicle tampering cases have been successfully
prosecuted in 1975, resulting in civil penalties of $4,950.
Enforcement personnel conducted 56 inspections of domestic and
foreign motor vehicle manufacturers and referred one investiga-
tion to the Justice Department for enforcement action.
0 EPA monitored 1,185,768 vehicles voluntarily recalled by
automobile manufactures for emission-related defects.
Two cases were referred to the Department of Justice for
alleged violation of motor vehicle import regulations.
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LITIGATION
o The Supreme Court upheld EPA's policy on variances and has been
petitioned to review Transportation Control Plans and feasibility
issues related to State Implementation Plan development.
o Various Circuit Court decisions upheld EPA's positions on three
major issues: the technical and economic analysis of the New
Source Performance Standard for Portland cement kilns, the issue
of dispersion technology vs constant controls, and the right for
state and Federal enforcement actions to be brought against a
polluter simultaneously.
RESEARCH
o The emphasis of health effects research during 1975 has been
on pollutants which may result from energy sources other than
petroleum.
° Epidemiologic studies of pollutants not subject to ambient air
quality standards have been intensified. The pollutants include
sulfates, nitrates, acid aerosols, and respirable particulates.
o Approximately $58 million was devoted to the development and
demonstration of control technology for stationary source air
pollution.
CONTROL AGENCY SUPPORT
0 In 1975, 55 state and territorial agencies and 236 local agencies,
working in coordination with states, expended approximately
$148 million and 7000 man-years to carry out the major portions
of the regulatory and enforcement aspects of the national air
pollution control effort.
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In FY 75, state and local funds for air pollution programs
increased 20 percent ($17 million) over FY 74 levels, and
Federal support during this period increased by 2 percent
($1.6 million).
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II. THE STATUS OF STATE IMPLEMENTATION PLAN
APPROVALS, DISAPPROVALS, AND PROMULGATIONS, AND
PROGRESS TOWARD ATTAINMENT OF NATIONAL STANDARDS
ATTAINMENT OF NATIONAL AMBIENT AIR QUALITY STANDARDS
The attainment date for primary standards in most states was May 31, 1975,
Analysis is underway to determine the attainment status of each Air Quality
Control Region (AQCR). Where National Ambient Air Quality Standards (NAAQS)
are computed as annual averages, it is necessary to have a complete calendar
year's data to determine final attainment status. Therefore, until 1976
data become available, there will be no final determinations regarding
annual NAAQS. However, analyses are being made of available data for each
AQCR. Preliminary judgments have been made for each AQCR, but these will
be subject to change as more data become available.
Significant progress in reducing levels of pollution has occurred.
Since 1970, for example, the percentage of air monitors reporting values
exceeding the primary (health) standard has decreased from 12 to 3 percent
ror sulfur dioxide, from 50 to 23 percent for total suspended particulate
(TSP) annual average, and from 16 to 8 percent for TSP 24-hour average.
The percentages for each of the compared years are based on the total number
of pollutant-specific monitoring instruments reporting to SAROAD in those
respective years.
Despite the very significant progress being made in improving air
quality and reducing emissions, a number of AQCRs are not expected to
attain one or more standards.
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Total Suspended Particulate (TSP)
It is currently anticipated that 132 AQCRs (53 percent of all AQCRs)
probably will not attain the TSP standard. A major problem in attaining
the TSP standard is fugitive dust (discussed in the "SIP Developments"
section of this chapter). Current analysis indicates that at least 67
AQCRs may not attain standards partly because of fugitive dust problems.
Problems with major point sources are major contributing factors to
probable non-attainment in approximately 19 AQCRs. EPA has also identi-
fied non-point sources as contributing to violation of the TSP standards
in at least 14 AQCRs. Non-point sources are smaller sources which emit
less than 100 tons per year of TSP.
It is important to note that in a given AQCR a number of factors, in
combination, may be causing non-attainment of standards. Much of the
analysis currently underway is directed at determining the causes of non-
attainment and the extent to which each type of source contributes to
non-attainment.
Sulfur Dioxide (SO?)
Considerable progress has been made in attaining sulfur dioxide standards.
On the basis of data currently available, EPA estimates that only 35 AQCRs
(14 percent) will probably not attain. Of these 35 AQCRs, 28 are also not
expected to attain the TSP standard. For the most part, the AQCRs which
are experiencing problems in attaining the S02 standards have emissions
from large point sources. In some 26 AQCRs major fossil fuel-burning power
plants have been identified as contributing to the problem. In an additional
three AQCRs, non-ferrous smelters are contributing to the problem. In most
of these cases, the Agency believes that further enforcement of existing
regulations will ensure attainment of the national S02 standards.
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Carbon Monoxide and Photochemical Oxidants (CO and Ox)
The attainment of standards for carbon monoxide and photochemical
oxidants in urban areas is in large part related to the control of trans-
portation sources. A detailed discussion of EPA's efforts to control mobile
source emissions is presented in Chapter V. Under the SIP process, trans-
portation control measures have been promulgated in 27 cities to meet the
oxidant standard, while transportation measures were promulgated in 26
urban centers for CO. An analysis conducted in the spring of 1975 indicated
that the major urban areas in 79 AQCRs (32 percent) are reporting violations
of the NAAQS for photochemical oxidants. The same review showed reported
violations of the CO standard in 69 AQCRs (28 percent).
The carbon monoxide problem is associated almost entirely with
motor vehicle emissions. It should be pointed out that, because of both
administrative and legislative actions, the auto emission reductions
originally required in the Clean Air Act have been deferred. Once
Federal Motor Vehicle Emission Standards are fully implemented, the CO
standard is expected to be attained in all but a few areas of the nation.
The photochemical oxidant problem is more complex and is a stationary
source problem as well as a mobile source problem. Moreover, recent studies
have found oxidant levels as much as twice the national standard in
rural areas. Although oxidants can be formed from emissions from natural
sources (e.g., coniferous forests), these recent studies indicate
that oxidants, or their precursors, are advected into the rural areas from
urban centers over a hundred miles distant. These studies provide preliminary
evidence that, to attain the Ox standard,.control of hydrocarbon stationary
sources (i.e., petroleum refineries, coating operations, etc.) over wide
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areas surrounding cities may be needed in addition to controls in urban
centers. Research in this area is continuing in order to better character-
ize the transport of oxiHants and their formation.
Nitrogen Dioxide (N02)
Judgments concerning the attainment of the N02 national standards
have been complicated by the discovery in 1973 that the ambient sampling
method for this pollutant was faulty. The method that had been in use
generally showed higher than actual levels of N02. An analysis of available
data in the spring of 1975 indicated that only 16 AQCRs (6 percent) have N02
concentrations at or above NAAQS. It is important to note that this is a
preliminary assessment which will be revised as more data become available.
Three alternative methods for measuring N02 were proposed on June 8, 1973
Since then further research has been conducted on each method. EPA now
expects to promulgate a final reference method for N(L by mid-1976.
REVISIONS TO STATE IMPLEMENTATION PLANS
On April 30, 1971, EPA promulgated National Ambient Air Quality
Standards (NAAQS) for five pollutants - sulfur dioxide, total suspended
particulate, carbon monoxide, photochemical oxidants and nitrogen dioxide.
Subsequent to that action, all states plus the four territories anrt thP
District of Columbia were required to submit a State Implementation Plan (SIP)
to EPA which described the control actions to be taken to reduce ambient
concentrations for each pollutant to levels at or below NAAQS. In most
cases, the SIPs were required to demonstrate attainment of standards by
May 31, 1975. Analysis is now underway to determine the final attainment
status of each Air Quality Control Region (AQCR). Where the NAAQS are
computed as annual averages, it is EPA's policy to determine attainment
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on the basis of a full calendar year of air quality data. This means that
final determinations cannot be made until CY 1976 data are available. EPA
is and will be directing particular attention to those AQCRs which have not
attained standards.
The passage of the May 31, 1975, attainment date for most areas marked
a significant milestone in EPA's efforts to implement section 110 of the
Clean Air Act Amendments of 1970. The initial efforts of EPA and the states
were directed at the development of the SIPs and then their implementation.
In the period from the first SIP approval/disapproval in 1972 until 1975,
major emphasis was given to implementing the SIPs. In many states, particular
sections of the SIP were revised by the state or EPA promulgated regulations
to correct specific deficiencies. With the exception of the transportation
measures, the majority of the revisions and promulgations addressed deficiencies
in SIP elements other than the basic control strategies and emission limitations,
and were intended to correct specific problems. With very few exceptions, there
were no fundamental reassessments that led to major SIP revisions.
With the passage of the May 31 date, however, the states and EPA began
an appraisal of the adequacy of all SIPs to attain and maintain standards.
As a result of this appraisal, many SIPs will be revised in FY 1977 to make
better provision for attainment and maintenance. These revisions will tend
to be more comprehensive than those in the past. Although the revisions for
attainment and for maintenance are related and in many cases will be handled
together, the two concepts need to be differentiated.
A SIP revision for attainment of NAAQS is undertaken to make the SIP
-emulations stringent enough to bring ambient concentrations down to standards.
In the majority of AQCRs where SIP revisions for attainment will be needed,
the revisions will involve more restrictive emission limitations on presently
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regulated sources and/or the addition of new emission limits for sources
not currently regulated. The actual emission limits will be based on a
revised control strategy and will include all measures which it is reason-
able to anticipate will be achievable within a reasonable period. If the
revised emission limits are not sufficient to attain standards, additional
measures such as transportation control will be required. However, the
major emphasis in attainment planning will be on the control of emissions
from existing sources that are contributing to violations of ambient
standards. It should be noted that in an AQCR where the SIP is now sub-
stantially inadequate, SIP revisions for attainment will be made for the
pollutant(s) for which a NAAQS is being violated. More specific consider-
ations relative to attainment revisions are discussed in the section on
"SIP Developments" in this chapter.
SIP revisions for maintenance of NAAQS will be considered in all areas
where attainment revisions are necessary. In addition, maintenance revi-
sions will be called for in designated Air Quality Maintenance Areas (AQMAs)
where standards are being met, but where growth projections indicate that
violations will occur within the next 10 years. Plan revisions for main-
tenance in most areas will deal primarily with the projected impact of
growth and development pf air quality. To maintain standards, the SIP
revisions will not only need to address the basic control strategy and
emission limits, but also may have to consider the review of new and modi-
fied sources, transportation controls, and land use. In addition, the
establishment of solid working relations between air pollution control
agencies and planning agencies, such as housing, transportation, Coastal
Zone Management, etc., is being emphasized. The maintenance revisions to
SIPs will be designed to prevent future violations of specific NAAQS which
are projected to occur if control measures are not taken.
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Regardless of whether violations are projected over the next 10 years,
all SIPs must be adequate to provide for maintenance of standards in all areas
and thus must contain provisions to ensure that unexpected growth does not
cause violations. The primary mechanism to do this is the new source review
procedure which includes an air quality analysis to decide whether a
violation will occur. If the analysis indicates that the construction of a
new source would cause a violation, the construction can be prohibited.
However, maintenance (and attainment) of standards is not solely dependent
on the SIPs developed under section 110 of the Clean Air Act. In addition
to SIP procedures, certain Federal emission standards will help to ensure
maintenance. In particular, New Source Performance Standards and Federal
Motor Vehicle Emissions Standards are expected to contribute significantly
to the maintenance of NAAQS.
In summary, the efforts of EPA and the states in non-attainment areas
will focus on the control of emissions from existing sources in high-pollution
AQCRs. SIP revisions for attainment will be developed with a primary
emphasis on control strategies and emission limits to solve current problems.
in maintenance, EPA and the states will focus on the management of growth
to minimize any future adverse impact on air quality. SIP revisions for
maintenance will be developed with a primary emphasis on methods for
avoiding future problems from growth. In areas requiring SIP revisions for
attainment, the attainment revisions will in most cases be followed by
maintenance revisions. In both cases, attainment/maintenance revision
areas and maintenance revision areas alone, the revisions will probably
be more comprehensive in nature than those of the past three years. Finally,
it should be noted that in both cases EPA is calling for revisions to the
SIPs and not for new and separate plans.
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Discussed below are the major national issues currently having an
impact on the development of SIPs. Where possible, the issues are related
to overall categories of attainment and maintenance.
SIP DEVELOPMENTS
Non-Attainment of NAAQS
Non-attainment of standards may result from one of two categories of
causes. In the first place, non-attainment may be the result of incomplete
implementation of the current SIP. In some non-attainment AQCRs, abatement
work is still underway and there is a reasonable expectation that NAAQS
will be achieved once it is completed. In such AQCRs, the emphasis for
attainment is on continued compliance and enforcement work to ensure that
current SIP regulations are fully implemented. A second category of cause
for non-attainment is an inadequate SIP. In a number of non-attainment AQCRs,
existing SIP regulations have been fully implemented and future improvements
in air quality cannot be expected. In such AQCRs, it will be necessary to
revise the SIP for attainment. To determine into which of the two categories
above each AQCR falls, the states and EPA are currently conducting detailed
reviews of the situation in each AQCR expected to show violations.
If SIP revisions for non-attainment are clearly necessary, EPA will
issue a request for such revisions to the states by July 1976. The request
will be as specific as possible in suggesting what new or revised regulations
are needed. In most cases, the request will also call for SIP revisions
for maintenance of NAAQS. The states will be asked to give priority to
revising, within one year, the existing emission limitations as needed.
The revisions are to demonstrate attainment of standards as expeditiously
as practicable. If other measures, such as transportation control
measures, are needed to attain and maintain NAAQS, they will be submitted
within two years of the initial call for revisions.
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To avoid interrupting compliance activities in the preparation of the
revisions, adding regulations to cover new sources not affected by present
regulations is preferred over revising existing regulations. EPA is making
every effort to ensure that the impact of attainment revisions on on-going
abatement will be minimal.
Maintenance of NAAQS
As a result of a 1973 court decision, EPA reviewed each SIP regarding
the maintenance of NAAQS and found that no plan adequately provided for the
maintenance of standards past 1975-77. EPA then promulgated in the June 18,
1973, Federal Register (38 FR 15834) requirements that each implementation
plan provide for the long-term maintenance of standards, including the
requirement that the plans list potential problem areas where standards
were or, because of projected growth, could be exceeded. The Federal
Register notice required that the SIPs be revised in the potential problem
areas (AQMAs) by June 18, 1975, to provide for maintenance of standards
for the following 10 years. In Federal Register actions of June 19, 1975
(40 FR 25814), and October 20, 1975 (40 FR 49048), the date for submission
and the planning period requirements were revised. Instead of requiring
uniform dates and planning periods, the new proposed regulations allow
the Administrator some flexibility in tailoring the requirements to an
area's needs.
Whereas the original SIP revisions for maintenance were to have pro-
vided for a period of 10 years, the requirements now allow the Administrator
to specify the period of time over which the revisions must demonstrate
maintenance. Most plan revisions will probably cover 10 years, but they
must address the same period as other Federally sponsored plans when such
plans address different planning horizons.
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Flexibility has also been introduced in the dates for AQMA plan revision
submission. The initial analysis of the problems in the AQMA are due by
April 1, 1976, but the Administrator can modify that date. The dates for
final plan revision submission will vary. However, the regulations require
that they be submitted "as expeditiously as practicable" for areas that will
fail to maintain NAAQS in the near future. For areas where maintenance is
a longer term problem, the maintenance revisions will generally be required
a number of years before they are to be implemented.
In a series of three Federal Register actions to date, the Administrator
has identified a total of 168 AQMAs for at least one pollutant. Of these,
159 were identified for total suspended paniculate, 61 for sulfur dioxide,
24 for carbon monoxide, 49 for photochemical oxidants, and 5 for nitrogen
dioxide. Under the proposed regulations no additional areas will be
formally identified. However, the states would still have to reassess all
areas periodically to determine if any areas need revisions.
Fugitive Emissions
During the development of the original SIPs, control strategies for
total suspended particulates (TSP) focused on the control of emissions from
the primary exhaust systems of point sources. Since that time, EPA and the
states have become increasingly aware that the attainment and maintenance
of the TSP standard may be adversely affected by both fugitive emissions
and fugitive dust emissions. Fugitive emissions are generated from industrial
operations and are released to the atmosphere through windows, doors, roof
vents, etc., but not through the primary exhaust system. On the other hand,
fugitive dust emissions result from the force of the wind or man's activity
on the land. This latter category includes windblown particulate from
crop land, unpaved roads, and exposed areas at construction sites, as well
17
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as particulate reentrained from streets by automobiles, tilling of crop
land, etc. Both types of emission are very difficult to quantify and, as
a result, the relative magnitude of the problem can only be estimated.
However, some 67 AQCRs, primarily in the West, are estimated to have
problems in attaining the TSP standard because of fugitive dust.
In the current round of revisions for attainment/maintenance, some
SIPs may be revised to include regulations for fugitive emissions. It is
possible to specify equipment standards for fugitive emissions from some
industrial sources. In addition, a visible emission regulation can be used
to force fugitive emission reductions. Although some controls for fugitive
dust emissions are available, NAAQS are probably not attainable in areas
where the principal problem is natural dust storms. Therefore, a number of
AQCRs will continue to experience violations of the standard because of
fugitive dust emissions.
Continuous Emission Monitoring
When the SIPs were first developed, it was EPA's position that
continuous in-stack emission monitoring systems were not sufficiently
reliable to warrant their inclusion as an SIP requirement. However, the
states were required to have the legal authority to require them. Since then,
the technology of in-stack monitoring has advanced sufficiently for EPA
to define realistic performance specifications for continuous monitors for
certain sources. In the Federal Register of October 6, 1975 (40 CFR 46240),
the Agency promulgated two regulatory actions that require the continuous
monitoring of emissions from a number of specified sources. One regulation
required continuous monitoring for certain new sources under EPA's New Source
Performance Standards program. The second regulatory action required the
states to adopt regulations to require emission monitoring on some existing
sources whose emissions are limited by regulations included as part of an
18
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approved SIP. The source operators will be required to report excess
emissions, their cause and any downtime in the continuous monitoring
system. Once the state submits such regulations and has them approved by
EPA, sources will have up to 18 months to acquire, install and begin to
operate the required monitoring systems. Table II-l lists the sources
that will be affected if they are covered by emission standards which are
part of an approved SIP.
Prevention of Significant Deterioration of Air Quality
In accordance with a court order resulting from a suit filed by the
Sierra Club, EPA has disapproved all SIPs with respect to significant
deterioration of air quality and has promulgated regulations applicable
nationwide. The regulations require the preconstruction review of any new
or modified source in 19 major source categories commencing construction
after June 1, 1975, to ensure that best available control technology is
installed and to ensure that specified air quality increments will not be
exceeded. The Class I increments would permit very little change in air
quality, Class II would permit changes consistent with moderate, well-
controlled growth, and Class III would permit deterioration up to but not
exceeding the most restrictive national standards. All areas of the country
were designated Class II initially, with provisions for states, Federal Land
Managers, or Indian Governing Bodies to initiate ^classifications for land
under their control.
Generally, the states have not initiated action to reclassify areas
from Class II to Class I or III, have not requested authority to carry out
EPA's regulations, and have not submitted their own plans to prevent signi-
ficant deterioration. Therefore, EPA is presently implementing its own
regulations on a nationwide basis. The states would prefer to wait for
Congressional action on this issue before taking any steps or action.
19
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Table II-I. MONITORING REQUIREMENTS FOR EXISTING SOURCES SUBJECT TO
EMISSION LIMITATIONS AS PART OF AN APPROVED
IMPLEMENTATION PLAN
Source category
Monitor required
Fossil fuel-fired steam generators
> 250 x 10 Btu/hr heat input and
> 30 percent annual capacity factor
Sulfuric acid plants
> 300 tons/day (100 percent acid)
Nitric acid plants
> 300 tons/day (100 percent acid)
Petroleum refineries
catalyst regenerators
> 20,000 bbls/day
fresh feed to fluid catalytic
cracker
Opacity,3 S02,b N0x,c 0? or C02d
SO,
Opacity
Only solid fuel-fired or liquid fuel-fired with a record of violation
of the opacity standard in the applicable plan.
Only for units using flue gas desulfurization equipment.
"Only for units > 1000 x 10 Btu/hr heat input in AQCRs where EPA has
determined that a control strategy for N0? is necessary.
d
Op or COp monitors are required only if needed to convert NO or S0?
Jata to the uni*s of the standard. x i
Q
Only in AQCRs where EPA has determined that a control strategy for
NOp is necessary.
20
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Sixteen separate suits have been filed on EPA's promulgated regula-
tions (one environmental group, one state, and fourteen industrial
petitioners). These have all been consolidated in the U.S. Court of
Appeals for the District of Columbia Circuit. Briefs for both sides have
been filed and a decision is expected 1n 1976.
Indirect Sources
On June 30, 1975, EPA suspended indefinitely those portions of the
indirect source regulations requiring pre-construction review of parking-
related facilities, as required by the FY 1975 appropriation act for the
Agency. Not affected were those provisions pertaining to highways and
airports. Indirect source reviews are similar in purpose to other new
source reviews. They are conducted to prevent the violation of a NAAQS
by emissions caused by a new source. As such, indirect source reviews are
part of the overall maintenance effort.
The Congress is presently considering the matter of indirect source
review, and the Agency expects guidance on this and other matters in the
form of amendments to the Clean Air Act.
Technical guidance for developing indirect source plans has been made
available to control agencies in Guideline for Air Quality Maintenance
Planning and Analysis, Volume 9: Evaluating Indirect Sources (EPA 450/4-
75-001).
Seventeen states/territories have submitted plans for regulation of
indirect sources. Plans have been approved for Alabama, Florida, Guam,
Idaho, Kentucky, Nebraska, Nevada, New York, North Carolina, Virgin Islands,
and West Virginia. Plans are under review for Connecticut, Delaware, New
Hampshire, Oregon, Pennsylvania (Philadelphia only), and Virginia.
21
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Tall Stacks
Tall stacks and the related issue, supplementary control systems, are
control strategies which reduce the impact of emissions from combustion
sources on air quality at ground level. Neither technique directly
involves the use of control equipment. Instead, both techniques rely upon
atmospheric dispersion to reduce the atmospheric concentrations of pollu-
tants, and both do little to reduce actual emissions. The use of tall
stacks relies on stack height increases to aid the dispersion of pollutants,
thereby reducing ground level concentrations, in some cases below the
level needed to attain NAAQS. Supplementary control systems involve
restrictions or modification to source operations during periods of poor
atmospheric dispersio.n so as to reduce emissions.
On February 8, 1974, a U.S. Court of Appeals opinion stated that
dispersion techniques could not be employed as substitutes for available
emission controls. The Agency has since prepared guidance setting forth a
uniform policy on the use of stack height increases by emitters. This
policy is applicable to a wide variety of sources and will give greater
assurance that NAAQS will be attained and maintained. The general philos-
ophy of the policy is that stack height increases are acceptable interim
control strategies on existing sources only after on-line installation of
all reasonably available control technology. Stack height augmentation will
not allow for any process operation modifications which would increase
emission levels at a source.
The policy guideline addresses the application of stack height
increases to both new and existing sources. Tfm guidance provide*- a
syst?^ in which air quality and existing stack height are factors for
determining compliance in any future control strategy demonstrations.
22
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Supplementary Control Systems
Development continues on control plans that would permit the temporary
use of supplementary control systems for SO on existing non-ferrous smelters
/\
in several western states where the use of all reasonably available emis-
sion controls is inadequate to attain ambient standards. EPA has proposed
and promulgated such regulations for Idaho and Nevada and proposed regula-
tions for Arizona and New Mexico.
Under these regulations, smelters are allowed to restrict or to modify
operations as necessary to permit adequate dispersion of pollutants as long
as reasonably available control technology is applied and the source accepts
responsibility for any violations of ambient standards within its desig-
nated liability area.
The strategy preferred by EPA for attaining and maintaining NAAQS is
one of constant emission limitation. The regulations state that supple-
mentary controls may be used only as a temporary measure to augment constant
control techniques, where the alternatives would be permanent curtailment
or cessation of production or delays in attaining air quality standards.
The final regulation in Nevada was challenged in court by an
affected emitter wishing to use SCS as a permanent control measure. How-
ever, EPA's regulation was found valid, and the Agency is continuing to
develop regulations for the states involved.
Energy Supply and Environmental Coordination Act (ESECA)
EPA's activities under ESECA were of two major types in 1975 --
review of coal conversion submittals and a review of State Implementation
Plans.
Review of Coal Conversion Submittals -- As of November 3, 1975, EPA
was involved in actions on 32 power plants in six EPA Regions. The air
pollution requirements fall into two general categories:
23
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(1) The emission-limiting regulations of an applicable SIP. If
the source is located in an AQCR where the primary NAAQS for
a pollutant is not being met, then the SIP regulation for
that pollutant must be met at the time the source converts to
coal. This situation existed for five plants for both TSP
and S02 and 21 plants for TSP only, as of November 3, 1975.
(2) Primary standard conditions. If the SIP regulation need not
be met at the time of conversion, EPA may specify interim
requirements, called primary standard conditions, to assure
that primary NAAQS are not violated. SIP requirements must
be met as soon as practicable but not later than January 1, 1979.
As of November 3, 1975, two plants for TSP and possibly 11
plants for SC^ are eligible for operation under primary
standard conditions.
In either case, the source cannot proceed to convert to coal until EPA
approves a source-submitted schedule for complying with SIP regulations as
soon as practicable, but no later than January 1, 1979.
State Implementation Plan Reviews
In compliance with section 4 of ESECA, EPA completed (in March 1975) a
^view of each State Implementation Plan to determine if emission-limiting
regulations for stationary fuel-combustion sources could be revised without
jeopardizing the attainment and maintenance of any NAAQS. The main objective
of the reviews was to stimulate a change of regulations that generate unnecessa /
demands for clean fuels or other control techniques.
Fifty-five states and territories (encompassing all 247 AQCRs) were
evaluated for both TSP and S02. Also, regulations for the control of N0?
werp evaluated for a limited number of AQCRs in New York, Maryland,
24
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Illinois, California, and Utah. Hydrocarbon and carbon monoxide regulations
were not addressed in the reviews because they do not -- with regard to
stationary fuel combustion sources -- constitute a major part of the strategy
to attain and maintain NAAQS or pose a roadblock to fuel use.
The reviews found that emission-limiting regulations for NCL are
necessary and are not unduly restrictive in the context of section 4 of ESECA.
The reviews found little indication that emission-limiting regulations for TSP
are overly restrictive. Of 247 AQCRs, 30 were found to be good candidates
for possible revision of TSP regulations and the remaining 217 were found to
be marginal or poor candidates. With regard to the limitations placed on
S02 emissions, the reviews found that the EPA's clean fuels policy of en-
couraging states to revise unnecessarily restrictive regulations had already
reduced much of the "overcleaning" required by the original SIPs. Only four
states were found to have some (very limited) potential for S02 regulation
revisions; these states had not initiated SIP revisions at the time of the study.
APPROVAL/DISAPPROVAL STATUS OF IMPLEMENTATION PLANS
Each state has submitted a SIP for EPA approval as required by the
Clean Air Act Amendments of 1970. Under the Act, EPA has authority to
propose and promulgate regulations to overcome regulatory deficiencies
in each SIP. Under this authority, the Agency has maintained an on-going
review of SIPs to identify regulatory deficiencies. Identified deficiencies
can arise from a number of different factors. A major factor has been the
better air quality and emission data now available on which to base control
strategies. Other major factors have been the court rulings and interpretations
which have necessitated a number of revisions to the original SIPs. The
introduction of new control technology has also necessitated revisions.
25
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As a result of all these factors, SIPs have been evolving and changing to
meet new situations. The SIP should be seen as a process and not a static
plan.
Table II-2 reports the approval/disapproval status of each SIP for
three key sections. The New Source Review section of a SIP is especially
important as EPA and the states begin to move into a maintenance mode.
The pre-construction review required under New Source Review includes both
a review against emission limits and a review for air quality impact.
These reviews will help to maintain standards. The transportation measures
included in some SIPs are a part of overall control strategies for 0 and
A
CO. The measures listed in Table 11-2 are, primarily, those needed to
control and manage emissions from mobile sources. Additional control measures
for Ox and CO are contained in the emission limitation section of each SIP.
These are measures to control emissions from stationary sources. Emission
limitations for each criteria pollutant are a part of each SIP. These
limitations are designed to reduce emissions and bring ambient concentrations
down to NAAQS. Emission limitations apply to existing sources of pollution,
but they are also used, as noted above, as one part of a review of proposed
new sources. Regarding emission limitations, it should be noted that in
many cases the deficiency listed in Table II-2 applies to only one AQCR.
Additional detail can be found in the State Air Pollution Implementation
Plan Progress Report, January 1 to June 30, 1975 (EPA-450/2-75-008,
September 1975).
Finally, it should be pointed out that this table reports the status
if SIPs before the calls for attainment and maintenance revisions. Calls
for these revisions will be made before June 1976 and will result in new
control strategy proposals being listed in the next report.
26
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Table II-2. STATUS OF SELECTED PORTIONS
OF THE STATE IMPLEMENTATION PLANS
Region/state
New source
review
Transportation
measures
Emission
limitations
Region I
Connecticut
Approved
Maine
Massachusetts
Approved
Approved
New Hampshire
Approved
Measures are re-
quired for Hartford
New Haven-Spring-
field AQCR and New
York-New Jersey-
Conn. AQCR
None required
Boston transpor-
tation controls
promulgated
6/12/75
None required
Approved
Rhode Island
Vermont
Approved
Approved
Measures required;
hearing 11/75
None required
Approved
Promulgation for
SO? (12/75-
suTfur content
of fuel),
Approved for
other pollu-
tants
Promulgation
for TSP
(11/75),
approved for
other pollu-
tants
Approved
Approved
Region II
New Jersey
Approved
New York
Approved
9/15/75
Measures promul-
gated for Phil-
adelphia and New
York, New Jersey
and Conn. AQCRs
TCP measures needed
for New York-New
Jersey-Conn. AQCR,
Gennessee-Finger
Lakes AQCR, and
Central New York
AQCR
EPA promul-
gation (7/73)
for HC,
approved for
other pollu-
tants
Rulemaking
for S02 (6/75),
approved for
other pollu-
tants
27
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Table II-2 (continued). STATUS OF SF.I.ECTFn PORTIONS
OF THE STATE IMPLEMENTATION PLANS
Region/state
New source
review
Transportation
measures
Emission
1 imitations
Region II cont.
Puerto Rico
Approved
U.S. Virgin
Islands
Approved for
all except
public com-
ment pro-
visions
(9/10/75)
None required
2
None required
Deficient in
part for SO
(9/75),
approved for
other pollu-
tants
Approved
Region III
Delaware
District of
Columbia
Maryland
Approved
Approved
Approved
None required
Measures promul-
gated for National
Capital AQCR
Measures promul-
gated for
Baltimore and
National Capital
AQCRs
Pennsylvania
Approved
Measures promul-
gated for Phil-
adelphia and
Southwest Pennsy-
lvania AQCRs
Approved
Approved
TSP limita-
tions proposed
(10/6/75); S0?
regulation
amended to
delete reduc-
tion from 1.0
to 0.5% sulfur
fuel for all
AQCRs except
Baltimore where
0.5% is effective
for 1 year
(12/5/75);
approved for
other pollutants
State
proposals for
TSP and S0?;
approved for
other pollu-
tants
28
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Table II-2 (continued). STATUS OF SELECTED PORTIONS
OF THE STATE IMPLEMENTATION PLANS
Region/state
New source
review
Transportation
measures
Emission
limitations
Region III cont.
Virginia
West Virginia
Approved
Approved
(11/10/75)
EPA promulgation
for National
Capital AQCR
None required
Approved
Approved
Region IV
Alabama
Florida
Georgia
Kentucky
Mississippi
North Carolina
Approved
Approved
Approved
Approved
Approved
Approved
None required
None required
None required
None required
None required
None required
Proposal for
S02 (9/75,1/76).
promulgations
for TSP (5/75,
8/75), proposal
for TSP (7/75),
approved for
other pollu-
tants
Promulgation
for S02 (10/75),
Approved for
other pollu-
tants
Promulgation
for TSP
(10/75), pro-
mulgation for
N02 (5/75),
Approved for
all other
pollutants
Approved
Approved
Approved
29
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Table 11-2 (continued). STATUS OF SFLECTFP PORTIONS
OF THE STATE IMPLEMENTATION PLANS
Region/state
Region IV cont.
South Carolina
Tennessee
Region V
Illinois
Indiana
Michigan
Minnesota
Ohio
Wisconsin
Region VI
Arkansas
Louisiana
New source
review
Approved
Approved
Approved
EPA promul-
gations
(5/73 & 2/74)
EPA promul-
gation (10/72)
Approved
EPA promul-
gation (4/74)
Approved
Approved
Approved
Transportation
measures
None required
None required
Measures promul-
gated for Chicago
AQCR
EPA promulgation
(4/74) for
Indianapolis AQCR
None required
Measures for
Minneapolis-
St. Paul AQCR
Measures promul-
gated for
Cincinnati AQCR
!
None required
None required
None required
Emission
limitations
Approved
Approved
CO strategy
disapproved
6/73; approved
for other
pollutants
Approved
Approved
Approved
HC strategy
disapproved,
SOp strategy
proposed
(11/75),
approved for
other pollu-
tants
Approved
Approved
Approved
30
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Table 11-2 (continued). STATUS OF SELECTFP PORTIONS
OF THE STATE IMPLEMENTATION PLANS
Region/state
Region VI cont.
New Mexico
Oklahoma
Texas
Region VII
Iowa
Kansas
Missouri
Nebraska
Region VIII
Colorado
Montana
North Dakota
New source
review
Approved
Approved
Approved
Approved
Approved
Approved
Approved
Approved
Approved
Approved
Transportation
measures
None required
None required
Measures being
prepared for
Austin-Waco,
Corpus Christi ,
Houston-
Gal veston,
Dallas, San
Antonio, El Paso
None required
None required
Measures submitted
for St. Louis AQCR
None required
Measures promul-
gated for Denver
AQCR
None required
None required
Emission
limitations
Revocation
of EPA promul-
gation for S02
proposed 11/75,
approved for
other pollu-
tants
Approved
EPA promul-
gations for
HC (11/73);
approved for
other pollu-
tants
Approved
Approved
Approved
Approved
Approved
Proposal for
S02 (10/75),
approved for
other pollu-
tants
Approved
31
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Table 11-2 (continued). STATUS OF SFLECTEn PORTIONS
OF THE STATE IMPLEMENTATION PLANS
Region/state
Region VIII cont.
South Dakota
Utah
Wyoming
Region IX
American Samoa
Arizona
California
Guam
Hawaii
New source
review
Approved
Disapproved
for TSP in
Wasatch
Front AQCR,
other sec-
tions
approved
Approved
Approved
Approved,
except for
Pima County
EPA promul-
gation (4/73)
for part of
state
Approved
Approved
Transportation
measures
None required
EPA promulgation
for Wasatch Front
AQCR (11/73)
None required
None required
Measures in effect
for Phoenix-
Tucson AQCR
i
Measures promul-
gated for San
Francisco, Los
Angeles, San
Diego, Fresno,
and Sacramento
AQCRs
None required
None required
Emission
limitations
Approved
EPA promul-
gations for
SO, and TSP
( 10/74 and
9/74), TSP pro-
mulgation
(smelter) 11/75,
approved for
other pollu-
tants
Approved
Approved
EPA promul-
gations for
SOn (3/73 and
3/74), TSP (5/73),
proposal for SC-2
from smelters (10/75)
apoTO!dntsfor other
EPA proposals
for TSP and
promulgation
for HC,
approved for
other pollu-
tants
Approved
Approved
32
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Table II-2 (continued). STATUS OF SELECTFP PORTIONS
OF THE STATE IMPLEMENTATION PLANS
Region/state
New source
review
Transportation
measures
Emission
limitations
Region IX cont.
Nevada
EPA promul-
gation (4/73)
for Washoe
County
None required
EPA promul-
gation for
S02 (2/75),
disapproved
for TSP (no
promulgation
to date),
approved for
other pollu-
tants
Region X
Alaska
Idaho
Oregon
Washington
Approved
Approved
EPA promulgation
for Northern
Alaska AQCR
None required
Approved
Approved
None required
Promulgations
for Seattle
and Spokane
AQCRs
Revisions
needed for
CO, approved
for other
pollutants
Promulgation
for S02 (11/75),
approved for
other pollu-
tants
Approved
Approved
33
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III. DEVELOPMENT OF AIR QUALITY CRITERIA
AND RECOMMENDED EMISSION CONTROL REQUIREMENTS
NATIONAL AMBIENT AIR QUALITY STANDARDS (NAAQS)
EPA has a continuing program for reviewing the existing scientific
data base for the criteria pollutants (those for which NAAQS have been
established) and for assessing the need for establishing new air quality
standards for other pollutants. Updates of the scientific data bases for
standards for carbon monoxide, oxidants and related hydrocarbons, and
oxides of nitrogen were initiated during 1975. In addition, four scien-
tific and technical assessment reports were published during the year:
Manganese, Cadmium, Particulate Polycyclic Organic Matter, and Vinyl
Chloride and Polyvinyl Chloride. Vanadium, Lead from Stationary Sources,
and Nickel are in the final clearance stage. Nitrosamines and Arsenic
are in various stages of preparation.
NEW SOURCE PERFORMANCE STANDARDS (NSPS)
New source performance standards (NSPS) were promulgated in 1971 for
five categories and in 1974 for seven more categories. Twelve additional
source categories were proposed in 1974. Half of these (electric arc
furnaces and five phosphate fertilizer processes) were promulgated in 1975,
NSPS for primary copper, zinc, and lead smelters, coal cleaning plants,
and primary aluminum reduction plants were promulgated in January 1976.
Seven additional promulgations (ferroalloy production, grain terminals,
by-product coke ovens, coal-refuse combustion in steam generators, carbon
black, lignite-fired steam generators, and crushed stone) are expected
34
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during 1976. In addition, 15 source categories are scheduled for pro-
mulgation in 1977-78, and many more categories are being studied for
possible promulgation.
Significant issues were raised during the year concerning control
costs, continuous monitoring, modification provisions, and application of
section lll(d) of the Act. Resolution of these policy and technical
questions has required considerable effort, as has the decision to include
environmental and inflation impact statements in the standard support
documents.
Continuous monitoring regulations were promulgated on October 6, 1975.
These establish a procedure whereby continuous emission monitors are checked
against manual performance tests required of new sources. Performance
specifications for acceptable monitors are included in the regulations.
On November 17, 1975, regulations to implement section lll(d) of the
Clean Air Act were promulgated. Under section lll(d) states are required
to submit plans for the control of designated pollutants (i.e., those
pollutants for which no National Ambient Air Quality Standards or National
Emission Standards for Hazardous Air Pollutants have been established) from
existing sources after the Agency promulgates NSPS for that source category.
Modification regulations, proposed in 1974, were promulgated December 16,
1975. These provisions limit application of NSPS to those situations in
which the modification requires a significant capital expenditure.
Eight AQCRs received assistance in the form of NSPS-type technical
studies and specific test methodology when the Agency proposed revisions
to the Stage II Gasoline Vapor Recovery regulations on October 9, 1975.
A strategy has been established for setting additional NSPS to
minimize projected increases in nationwide emissions. Over the next 15
35
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years, up to 400 pollutant/source combinations of NSPS will be promul-
gated. The effect of these standards will be to maintain particulate, SO ,
A
HC and CO emission levels at or below present levels despite projected
industry production increases.
36
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Table III-l. STATUS OF STANDARDS OF PERFORMANCE
Source
Steam generators
[>250 million
Btu/hr]
Municipal incin-
erators [>50
tons per day]
Portland cement
plants
Nitric acid
plants
Sulfuric acid
plants
Asphalt con-
crete plants
Petroleum
refineries
Petroleum
storage
Secondary lead
smelters and
refineries
Secondary brass
and bronze
refining
facilities
Iron and steel
mi 1 1 s
Affected facility
Coal-, oil-, and gas-
fired boilers
Incinerator
Kiln, clinker cooler
Process equipment
Process equipment
Process equipment
Process gas
combustion
Catalytic
regenerators
Gasoline, crude
oil , and dis-
tillate storage
tanks >65,000
gallons capacity
Blast and rever-
berate ry
furnaces
Reverberatory
furnaces
Basic oxygen
furnace
Pollutant
Particulate
S0x
N0x
Particulate
Particulate
NOX
S0x
Actd mist
Particulate
S0x
Particulate
CO
Hydrocarbons
Particulate
Particulate
Particulate
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
3/8/74
3/8/74
Remarks
Under remand
Judicial
review
decided in
favor of
EPA-5/22/75
Under remand
Undergoing
judicial
review
37
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Table Ill-l (continued). STATUS OF STANDARDS OF PERFORMANCE
Source
Sewage treatment
plants
Primary copper
smelters
Primary zinc
smelters
Primary lead
smelters
Primary aluminum
reduction
plants
Coal cleaning
plants
Phosphate
fertilizer
plant
Affected falility
Sludge incinerators
Roaster, smelting
furnace, converter
Dryer
Roaster
Sintering machine
Sintering machine,
electric smelting
furnace, converter
Blast or rever-
beratory furnace,
sintering machine
Pot line
Anode bake plant
Air tables
Thermal dryers
Wet process
phosphoric acid
Superphosphoric
acid
Di ammonium
phosphate
Triple super-
phosphate
Triple super-
Phosphate
storage
Pollutant
Particulate
S0x
Particulate
S0x
Pafticulate
S0x
Particulate
Fluorides
Fluorides
Particulate
Particulate
Fluorides
Fluorides
Fluorides
Fluorides
Fluorides
Promulgation
date
3/8/74
1/15/76
1/15/76
1/15/76
1/26/76
1/15/76
8/6/75
8/6/75
8/6/75
8/6/75
8/6/75
Remarks
38
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Table III-l (continued). STATUS OF STANDARDS OF PERFORMANCE
Source
Affected facility
Pollutant
Promulgation
date
Remarks
Iron and steel
mills
Ferroalloy
production
Electric arc
furnaces
Specific furnaces
Particulate
Particulate
CO
9/23/75
Proposed
10/21/74
Promulgation
scheduled
for mid-
1976
39
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Table II1-2. REGULATORY ACTIONS RELATED TO SECTIONS 111 AND 112
Subject of
regulation
Continuous moni-
toring
Section lll(d)
regulations
Modification
Revision to
hazardous
pollutant
regulations
Vinyl chlo-
ride
Affected facility
Process equipment
Pollutant
Asbestos
and mer-
cury
Vinyl
chloride
Promulgation
date
10/6/75
11/17/75
12/16/75
10/14/75
Remarks
Proposed
12/24/75
40
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NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAPs)
On October 14, 1975, the Agency promulgated revisions to the asbestos
and mercury National Emission Standards for Hazardous Air Pollutants
(NESHAPs). These revisions modify the scope of the regulations and amend
the test methods. For asbestos, manufacture of shotgun shells, manufac-
ture of asphalt concrete, and asbestos waste disposal were added to the
list of nine source categories covered by the regulations. Asbestos fab-
rication operations are excluded, and changes have been made in prevent-
ing emissions during demolition and renovation. Sewage sludge incinerators
were added as a source of mercury emission covered by NESHAPs.
On December 24, 1975, EPA added vinyl choloride to the list of
hazardous air pollutants and proposed a standard for vinyl chloride
emissions from ethylene dichloride/vinyl chloride and polyvinyl chloride
plants.
HEALTH EFFECTS RESEARCH
Research on health effects is fundamental to the Agency's responsi-
bility and ability to develop criteria and to promulgate and enforce
standards and guidelines. The effort is specifically designed to identify
pollutants which may pose a risk to health, to quantify the relationships
between exposure to those pollutants and their effects on health, and to
document the benefits of reducing or eliminating human exposure through
pollution control. In the health effects program, data bases are developed
for determining whether restricting exposure to particular pollutants is
necessary to protect public health and, if so, to what degree exposure
should be restricted. To do this, a combination of research approaches is
41
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used: toxicological studies which utilize animal models, human clinical
studies, and epidemic-logical studies of human populations in their actual
environmental settings.
The health effects research program is basically divided into four
pollutant areas: studies on criteria pollutants, non-criteria pollutants,
pollutants associated with transportation activities, and non-pesticide
organic and inorganic substances.
Criteria Pollutants
Criteria pollutants are those for which National Ambient Air Quality
Standards (NAAQS) have been set: carbon monoxide, sulfur dioxide, nitrogen
dioxide, particulates, hydrocarbons, and oxidants. The Agency is con-
tinuing to obtain health effects information on these pollutants in
several areas, such as exposure averaging times -- that is, short-term,
high-concentration exposure versus long-term, low-level exposure -- the
adequacy of existing safety margins, the health benefits of meeting the
standards, and the health risks of exceeding the standards. Thus, the
research in this area is basically directed toward expanding the health
data base for those pollutants for which NAAQS have been promulgated and
refining the criteria on which those standards are based. Any evaluation
and adjustment of the standards which may prove to be necessary will be
influenced substantially by these data.
Studies are also being conducted in the criteria pollutant area to
identify populations most at risk, to refine exposure-effects data for
such populations, and to determine the effects of exposure to combinations
of the criteria pollutants.
42
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Non-Criteria Pollutants
Non-criteria pollutants are those for which no NAAQS have been
established. Health effects research is also directed toward develop-
ing data on these pollutants, e.g., sulfates, nitrates, and respirable
particulates. Some existing evidence associates these pollutants with
harmful effects on human health. Questions being posed in this regard
include determination of exposure-response relationships for these
pollutants, both by themselves and in combination with other pollutants.
During this year, the Agency reoriented the air epidemiology program
into targeted population studies designed to test hypotheses developed
from the earlier Community Health and Environmental Surveillance System
(CHESS). Specific studies on sulfate and nitrate aerosols are part of
the series. For example, studies were begun in the South Coast Air Basin
of California, where a special problem may emerge as the use of fuels con-
taining higher proportions of sulfur is increased in an area of high
oxidant levels. Studies have been planned in the Northwestern Inter-
mountain Region where high sulfate levels occur in conjunction with
smelter operations. Further studies are designed for the highly indus-
trialized areas east of the Mississippi and south of the Great Lakes
where the potential exists for large, regional sulfate problems arising
from long-term transformation and long-range transportation of sulfur
oxides emitted largely from stationary sources.
Transportation-Associated Pol 1utants
A specially identified area of research in air pollution relates to
transportation. The purpose of this program is to develop comprehensive
43
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toxicological and epidemiological data bases on the public health con-
sequences of pollutants stemming from transportation sources. We are
conducting a series of studies to ascertain health risks associated with
emission products such as sulfuric acid, sulfates, carbon disulfide,
hydrogen sulfide, palladium, platinum and aluminum oxide from vehicles
equipped with catalytic converters. The effects of substances used as
fuel additives are also being investigated, and plans to begin work on
possible biological effects of diesel emissions have also been made.
The annual Catalyst Research Program Report represents a comprehen-
sive compilation of information obtained by a research program on mobile
source emissions. The work includes data on emission characterization,
atmospheric chemistry, and physics of mobile emission products with con-
sideration given to meteorology and other atmospheric factors; air
quality modeling; animal toxicology; and human population effects. Pol-
lutants of concern include acid sulfates, platinum, and palladium. The
data obtained is being provided to appropriate sectors of the Agency to
indicate the public health implications of non-regulated mobile source
pollutants so that prudent determinations can be derived with respect to
regulatory needs.
Inorganic and Organic Substances
Non-pesticide inorganic and organic substances are also topics of
investigation in the air program area. The health program addresses a
number of trace metals, including cadmium, copper, zinc, arsenic and lead.
Lead, for example, is a ubiquitous pollutant which may be found in the
air we breathe, the water we drink, the food we eat, and dust that
children sometimes ingest. In assessing the health implications of
44
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exposure to such pollutants, two important questions being examined are
the relative contribution of the various possible routes of exposure to
observed health effects and the exposure-response relationships exhibited
by these substances. Examples include population studies which were
initiated in 1975 on the health impact of these metals in communities
near primary smelters, and the development of screening systems for rapid
assessment of potentially hazardous biochemical activity.
Terrestrial Ecology Effects Research
The Agency's ecological research activities which deal with the effects
of air pollutants on 'land life other than man has proceeded along two broad
program fronts. The primary program thrust relates directly to strengthening
the scientific basis for air pollution control strategies mandated by the
definition of "welfare" effects in the Clean Air Act. The second major pro-
gram comprises a newly initiated effort in "energy" research to assess the
terrestrial impact of a representative coal-fired power plant located at
Colstrip, Montana.
Vegetation growing near a source of sulfur dioxide (S02) experiences
continuous but varying pollutant concentrations. Very high concentrations
occur infrequently but can be anticipated fairly accurately if adequate
historical data are available. A more realistic research approach to deter-
mine S02 and photochemical oxidant effects on plant growth and crop yield has
been initiated during the past year. Simulations of random variation in
pollutant concentration based on published national air quality data from
selected sites are applied under field conditions. Preliminary results show
pronounced effects on growth response curves for selected crops. These data
are being used to develop damage functions for economic loss assessments.
Vast areas of the United States receive precipitation which is consis-
tently 10 to 100 times more acidic than the geologic average. The problem
45
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is increasing in area as well as in severity, primarily because of the impact
of man's activities. Research is underway to determine the effects of acidic
rain on nutrient cycling and plant-soil processes over a three-year period.
Simulated rain treatments representing a range of averages (from the acid
content in the northeastern United States to an average for the entire United
States and, finally, a value representing a possible increase in acidity)
are applied for 3 to 4 hours for three days each week. Sulfates in rain
that result in the formation of sulfuric acid appear to be major contributors
to the acidic reaction, so the various pH values are controlled by adding
sulfuric acid. Responses being measured include nutrient leaching from
plant foliage and soil, decomposition of organic matter, nitrogen fixation
and nutrient uptake, and effects on productivity through foliar damage.
Results from this work will provide a sounder basis for future sulfate air
pollution control strategies on a regional level.
The conversion of atmospheric nitrogen to an organic form by legumes,
such as alfalfa and soybeans, is an essential natural process whereby
nitrogen fertilizer is added to the environment. Studies have been under-
taken to determine the influence of polluted air on the nitrogen conversion
properties of a legume. Alfalfa plants have been exposed to low levels of
ozone and sulfur dioxide throughout the growing season. The nitrogen content
of the plants was determined as a measure of the nitrogen fixation. Ozone
treatment reduced the nitrogen fixation by 40 percent. The ozone concentra-
tion was less than the present National Ambient Air Quality Standard for
photochemical oxidants. The presence of sulfur dioxide also significantly
reduced nitrogen fixation when the median concentration exceeded 0.06 parts
per million (ppm). This work indicates that natural nitrogen fixation is
46
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severely limited by atmospheric contaminants, an effect_whjch heretofore has
been unrecognized.
The measurement of air pollutant effects on plants generally has been
based on visual observations of injury. However, experience has shown that
these measurements are not sensitive and cannot be standardized. One tech-
nique developed to solve this problem measures plant production of stress
ethylene when exposed to ambient pollutants. Although ethylene production
increases when visible injury occurs, it also increases when the injury can-
not be seen and thus is useful in determining injury before it is visible.
The test to measure ethylene production is more sensitive that visual obser-
vation and can be used as a standardized quantitative method by all researchers.
Further research is in progress to delineate mechanisms and dose-response
relationships for cadmium compounds. These compounds include cadmium oxides,
chlorides, sulfates, sulfides and phosphates, which are toxic to many plants
and animals. The sources of these compounds include automobile exhausts,
tire residues, coal-fired power plants and parent rock material from which
phosphate fertilizers are produced. Cadmium is a ubiquitous element in the
earth's crust with no known nutritional value. A small amount of cadmium
can be extracted from most plants regardless of location; larger quantities
have been found to inhibit plant growth. Results of research on the nitrogen
fixation in the roots of red alder trees indicate that this vital process
is inhibited by cadmium. The effect may occur directly within the nitrogen
fixation system and/or through the effects on other processes within the
plant.
Research is also underway on the effects of pollutant stressors on soil
litter decomposition. Soil litter decomposition is a process whereby dead
47
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organic matter is mineralized for plant use. This is an essential biological
process without which life on the planet would cease. Research thus far has
shown that cadmium and selenium are two common polluting agents which affect
the rate of soil decomposition. Preliminary studies also indicate that some
decomposer organisms such as mites may be forced to migrate from their normal
litter habitat when subjected to sulfur dioxide. Data indicate that ozone
is capable of reducing ammonia nitrogen, thus decreasing the nitrogen pool
in some forest soils, and possibly affecting tree growth. Further studies
are necessary in this area.
The broad objective of the energy study on coal-fired power plants is
to develop a set of guidelines which planners can use in predicting the im-
pact of power plants on a grassland ecosystem. The study is concerned not
only with the stability of ecosystem organization in relation to ambient
conditions, but also with the predictability and reproducibility of changes
that occur. Insight into the mechanisms of responses of ecosystem components
to air pollution challenge is sought. Of special concern is the identifica-
tion of subsystem functions and mechanisms that contribute to ecosystem regu-
lation. The investigation is an effort to characterize the impact of air
pollutants on a total ecosystem. Included are the investigation of the
effects of coal-fired power plant emissions upon plant and animal community
structure; production, consumers and decomposers; plant and animal diseases;
both beneficial and harmful insects; indicators and predictors of pollution;
population biology; and health of vertebrate animals. This research project
is scheduled to be concluded in 1978.
48
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International Activities
International support in air pollution is provided through three main
areas: international organizations, international cooperative agreements,
and international contracts and grants.
Among the international organizations collaborated with by EPA,
assistance is currently being provided for the following: World Health
Organization (WHO), Organization for Economic Cooperation and Development
(OECD), Commission of the European Communities (CEC), Pan American Health
Organization (PAHO), Pan American Medical Association (PAMA), and Economic
Commission for Europe (ECE). Pollutant survey documents, air criteria and
guideline documents, and annotated bibliographies prepared by EPA are
provided to WHO, and one individual acts as an advisor to a Task Group
reviewing element pollutants. The Chairman of the Air Management Sector
Group for OECD was a staff member of the Health Effects Research Laboratory.
Research personnel are continuing to provide support to CEC on standardi-
zation for epidemiological studies as well as for assisting in a collabo-
rative study of analysis of lead, mercury and cadmium in blood and urine
samples. Advice has been provided to PAHO for epidemiological studies in
a UN/Mexico project in studies of carboxyhemoglobin levels and studies on
heavy metals in man. Personnel are involved directly with the PAMA Section
on Environmental Health Sciences, and the Secretary of the Section is an
EPA employee. Preparation for presentation of a paper on "The Health and
Welfare Effects of Increasing Sulfur Oxides Emissions" has been completed
for a U.S.-sponsored ECE seminar on desulfurization of fuels and combustion
gases.
49
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The United States has Individual international cooperative agree-
ments with five nations: Federal Republic of Germany (FRG), Israel, Japan,
Spain and the U.S.S.R. Each of these, in part, addresses health effects
to some degree. Cooperation with FRG includes provisions of copies of .
assessment studies of air pollutants, and continued cooperation in the
fields of carcinogenesis and mobile source emission studies. Health
effects researchers act as consultants to Israeli scientists on their
programs and are collaborating on such studies as a comparative study of
asthmatic populations in the two countries and a study on "Chronic Toxicity
Caused by Air Pollution and Its Effect on the Health and Productivity of
Domestic and Farm Animals." Cooperation with Japan includes: estimation of
environmental exposure to cadmium, evaluation of body burdens, establishment
of tissue banks, study of biological half-life, study of high-exposure
human populations, development of laboratory procedures and development of
field methodological exposures. Consultation is also provided in a 3-year
study comparing chronic illnesses in comparable executive populations in
New York and Tokyo. Direct health effects are not currently being pursued
under the Spanish agreement. The major health effect cooperation with the
U.S.S.R. lies in the specific fields of mutagenesis, heavy metals and
epidemiology.
Under International Contracts and Grants there are eleven active
research projects in Health Effects, funded under Public Law 480. Three of
these projects are in Egypt, one in India, five in Yugoslavia, and two
in Sweden. Two projects are under study in Poland.
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IV. STANDARDS SET OR UNDER CONSIDERATION PURSUANT
TO TITLE II
MOTORCYCLE REGULATIONS
A Notice of Proposed Rulemaking to control emissions from new motor-
cycles was published in October 1975.
Motorcycles are one of many small but significant sources of emissions.
The average uncontrolled motorcycle presently emits about twice as much car-
bon monoxide (CO) and about six times as much hydrocarbon (HC) as a new 1976
automobile, emissions from which have been reduced 85 percent over uncon-
trolled levels. When statutory standards for automobiles are met (90 percent
reduction over uncontrolled levels), uncontrolled CO emissions will be 10
times as high and HC over 20 times as high for the motorcycle as for the
automobile. As automobiles account for proportionately less of the CO and
HC problem, control of motorcycle emissions becomes an increasingly signifi-
cant factor in the further abatement of these pollutants.
All regions of the United States that are not meeting air quality
standards for CO and photochemical oxidants (0 ) will benefit in some way
/\
from these control standards since they will serve as one of many strategies
to help reduce overall emissions of HC and CO and thereby improve air quality.
About one-third of the U.S. population (68 million people) lives in areas
which are projected to have problems meeting these air quality standards in
1985.
51
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Interim and long-term emission standards for motorcycles designed for
street use are proposed. The 1978 interim standard for HC exhaust emissions
is dependent on engine displacement, requiring control to 5 grams per
kilometer (g/km) for motorcycles between 50 and 170 cubic centimeters (cc)
displacement. The standard increases proportionately with displacement
from 5 g/km at 170 cc to 14 g/km at 750 cc and above. CO emissions are
limited to 17 g/km, and nitrogen oxide (NOX) emissions are limited to 1.2
g/km for 1978. The 1978 standards also propose a prohibition on crankcase
HC emissions. These standards, if met throughout the life of the motorcycle,
will decrease average motorcycle emissions of HC by 30 percent and CO emis-
sions by 22 percent. Nitrogen oxide emissions, which are inherently quite
low, will increase somewhat as HC and CO are controlled.
REVISED LIGHT DUTY TRUCK REGULATIONS
Notice of Proposed Rulemaking is expected to be published early in 1976 to
enlarge the definition of the light duty truck (LOT) class to an 8500 pound gross
vehicle weight limit rather than the present 6000 pound limit. It also
proposes reduction in HC, CO, and NOX emissions to reflect application of
the same technology and degree of stringency that will be required of light
duty vehicles (LDV) under 1978 Federal standards. The proposed regulations
would be applicable to 1978 and subsequent model year light duty trucks.
The need for stricter standards has developed because, as increasingly
stringent controls are placed on passenger cars, the percentage of total
vehicular pollution caused by trucks increases. Air quality analyses fore-
cast that if no further controls are placed on light duty trucks used in
urban areas and if current statutory control of light duty vehicles is
effected, CO and N0x emissions from LDTs will equal LDV emissions by 1985.
52
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INTERIM HEAVY DUTY VEHICLE EMISSION REGULATIONS
In early 1976 a Notice of Proposed Rulemaking will be published for
more stringent control of gaseous exhaust emissions from heavy duty gaso-
line and diesel powered vehicles. A more stringent standard will also be
proposed for further control of peak smoke opacity from diesel engines.
Stricter emission standards for heavy duty vehicles are necessitated
by the inability of some Air Quality Control Regions to meet national am-
bient air quality standards without further control of HC, CO, and NOV.
A
Although the heavy duty vehicle population accounts for only approximately
5 percent of all registered motor vehicles, the levels of HC, CO, and NOX
that they emit are significant. It is estimated that without further con-
trols, emissions from heavy duty vehicles by 1990 will exceed those of
light duty vehicles controlled at statutory standards.
The proposed interim standards represent a significant step towards
alleviating excessive heavy duty vehicle emissions. Primarily because of
industry lead time requirements, the standards are projected to be effec-
tive as of the 1978 model year.
SULFURIC ACID EMISSION STANDARD
The need for control of automotive sulfuric acid emissions stems from
the great increase in their production by catalyst-equipped vehicles. In
addition to more restrictive California standards for HC and CO which have
led to the use of catalyst systems on nearly all automobiles sold in
California, many manufacturers have switched to production of catalyst-
equipped vehicles outside of California because they offer fuel economy
53
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advantages. Catalyst-equipped vehicles comprise over 70 percent of 1975
model year vehicles and are expected to comprise over 85 percent of 1976
model year vehicles.
In an effort to prevent further increases in sulfuric acid emissions,
a Notice of Proposed Rulemaking is currently expected to be issued in the
second quarter of 1976. Intensive study continues toward development of
an adequate test procedure and accurate assessment of acceptable sulfuric
acid emission levels. Primarily because of industry lead time requirements,
these standards would be effective as of the 1979 model year.
REVISED EVAPORATIVE EMISSION REGULATIONS
A Notice of Proposed Rulemaking to set more stringent standards for
evaporative emissions from light duty passenger vehicles and light duty
trucks was published in December 1975. The most significant change in the
regulations is the new evaporative emission test procedure. The present
test procedure has been found to give unrealistically low test results,
thereby passing vehicles which actually grossly exceed the level intended
by the present evaporative standard. The proposed standard of 2 g/test for
1979 and later model years, as measured by the new test procedure, will re-
duce HC emissions from light duty vehicles and light duty trucks from 1.76
g/n-iile to 0.15 g/mile at an estimated retail cost of only $11.00 per vehicle.
For the 1978 model year only, due to lead time constraints, a 6 g/test stan-
dard is proposed. This is the same level that California was authorized to
enforce for the 1978 model year.
If standards are promulgated at the proposed Bevels, evaporative emis-
sions will be reduced in 1990 by 3.35 x 106 tons/year. For comparison,
going from the current HC exhaust emission standard for light duty passenger
54
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vehicles to the statutory standard will result in a reduction of 900,000
tons/year.
NON-METHANE HYDROCARBON EXHAUST EMISSION STANDARDS
In 1974, an Advance Notice of Proposed Rulemaking was published for
conversion of current standards for motor vehicle hydrocarbon exhaust emis-
sions to a non-methane basis (39 FR 6904). This action was in response to
a formal petition by Ford Motor Company stating that catalyst-equipped
vehicles tended to have a greater proportion of methane (a non-reactive
and thus non-polluting hydrocarbon) in the exhaust than current vehicles.
Therefore an emission standard based on all hydrocarbons, including methane,
penalized vehicles with catalysts.
At this time, the analysis of the Advance Notice of Proposed Rule-
making comments is complete and results indicate that there would be little
benefit in either air quality or emission controls by requiring such a con-
version. Conversion would also result in considerable cost increase.
Accordingly, further work in this area has been assigned a low priority.
AIRCRAFT EMISSIONS REGULATORY ACTIONS
In 1974 EPA published Notice of Proposed Rulemaking applying to emis-
sions from engines powering supersonic aircraft. This followed up a commit-
ment made in the preamble to the basic EPA aircraft regulations promulgated
in 1973. This preamble stated that separate standards would be published
for supersonic aircraft because specialized technological constraints limit
their ability to meet standards applicable to subsonic aircraft.
The regulations proposed reflect the same types of combustor design
technology but make allowances for the less efficient engine cycles used
for propulsion of aircraft designed for supersonic flight speeds. Public
55
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hearings were held concerning this Notice of Proposed Rulemaking in Boston,
Massachusetts, on November 19, 1974, and in Los Angeles, California, on
November 26, 1974.
Comments and testimony have been analyzed and final standards have
been set, subject to EPA review procedures. Promulgation is currently
expected by spring 1976.
56
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V. CONTROL OF MOBILE SOURCE EMISSIONS AND
RELATED RESEARCH EFFORTS
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
As a result of Title II of the Act, standards of 0.41 gram per mile
(g/mi) HC, 3.4 g/mi CO and 0.4 g/mi NO were promulgated as the ultimate
A
statutory standards for those pollutants.
The 1970 amendments also provided that motor vehicle manufacturers could
apply for a one-year suspension of these standards. Application was made in
March 1972 to suspend the HC and CO standards. After an initial denial, the
U.S. Court of Appeals for the District of Columbia required EPA reconsidera-
tion and on April 11, 1973, a suspension was granted for the 1975 model year.
At this time interim standards of 1.5 g/mi HC and 15 g/mi CO were established.
The Administrator also took action which resulted in emission standards
applicable in California of 0.9 g/mi HC, 9.0 g/mi CO, and 2.0 g/mi NO for the
1 rN
1975 model year. The state standards waiver provision (Clean Air Act Section
209(b)) allows California, because it was the only state to adopt emission
standards prior to March 30, 1966, to set standards more strict than those
57
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of the Federal government unless the Administrator of EPA, after notice and
opportunity for hearing, finds either that California has not adopted more
stringent standards "to meet compelling and extraordinary conditions" or
that the "standards and accompanying enforcement procedures are not consist-
ent with section 202(a)" of the Act.
Further action was taken on July 30, 1973, when the 1976 model year
statutory N0x standard of 0.4 g/mi was suspended for one year and an interim
standard of 2.0 g/mi was established.
In June 1974 the passage of the Energy Supply and Environmental
Coordination Act (ESECA) provided that (1) the 1975 Federal and California
interim standards would also be applicable to the 1976 model year, (2) the
original statutory standards for HC and CO of 0.41 and 3.4 g/mi respectively
would be applicable tc the 1977 and subsequent model years, (3) the interim
N0x standard of 2.0 g/mi would be applicable to the 1977 model year, (4) the
original statutory N0x standard of 0.4 g/mi would be applicable to the 1978
and subsequent model years, and (5) any motor vehicle manufacturer could, at
any time after January 1, 1975, apply for a one-year suspension of the
imposition of the statutory HC and CO standards to the 1977 model year.
-:''spension of the HC and CO Emission Standards for 1977 Model Year Vehicles
On March 5, 1975, the EPA Administrator granted the request of Ford
Motor Company, General Motors Corporation, and Chrysler Corporation for a
one-year suspension of the 1977 motor vehicle emission standards.
Although effective control technology was available, the Administrator
determined that the sulfuric acid problem caused by the conversion of sulfur
in gasoline to sulfuric acid was a potential risk to public health in
heavily traveled areas and that this risk could be minimized by retaining
1975 interim standards and promulgating a sulfuric acid standard.
58
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Accordingly, the Administrator imposed 1.5 g/mi HC and 15 g/mi CO
as interim standards for 1977 and recommended to Congress that the Clean
Air Act be amended to retain these standards through the 1979 model year.
The rationale for the suspension and the Administrator's recommenda-
tion was that interim standards could be met using catalytic converters with-
out air pumps. It has been shown that the increased oxygen concentration
in the catalytic converter, caused by air pumps, results in much higher
emission levels of sulfuric acid.
Waiver of Federal Preemption of California State Motor Vehicle Pollution
Control.Standards
On May 20, 1975, the EPA Administrator granted a request from the
State of California for a waiver of Federal preemption for 1977 California
standards of 0.41 g/mi HC, 9 g/mi CO, and 1.5 g/mi NOX. Data presented led
the Administrator to a determination that compelling and extraordinary
conditions persist in California and that technology and adequate lead time
exist for manufacturers to meet the requested California 1977 standards.
The Administrator further determined that any assessment of either the
magnitude of the sulfuric acid risk or the measures needed to deal with it
is a matter of California's judgment.
Current standards reflecting ESECA provisions and EPA promulgation are
summarized in Table V-l.
Certification Testing
Certification of new passenger cars for compliance with Federal emission
standards began with 1968 model year vehicles. The program includes testing
of prototype vehicles that represent all new motor vehicles sold in the
United States.
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Table V-i. EMISSION STANDARDS FOR MOTOR VEHICLE CLASSES
Motor vehicle class
Light duty passenger
(Emissions expressed in
grams per mile)
National
California
Light duty trucks
(Emission expressed in
grams per mile)
National
California
Heavy duty vehicles3
(Emissions expressed in
grams per horsepower-hour)
National
California
1976
HC CO NOX
1.5 15.0 3.1
0.9 9.0 2.0
HC CO NOX
2.0 20.0 3.1
0.9 17.0 2.0
HC + NOX CO Smoke
16 40 15/20/50b
10 30
1977
HC CO
1.5 15.0
0.41 9.0
HC CO
2.0 20.0
0.9 17.0
HC + NOY CO
A
16 40
1C 25
NOX
2.0
1.5
NOX
3.1
2.0
Smoke
15/20/50b
7.5C
1978
HC CO NOV
A
0.41 3.4 0.4
HC CO NOV
A
0.9 17.0 2.0
HC + NOX CO Smoke
Gasoline and diesel have same standards but are tested under different procedures.
Diesel only; lugging/acceleration/peak.
cOPtion available for combined HC and N0x standard of 5 grams/brake horsepower/hour.
-------
The manufacturer is required by EPA to submit data from two tests
which evaluate vehicle conformance to Federal emission standards. First,
through the Durability Fleet Test, fleets are tested at 5000 mile intervals
up to 50,000 miles to determine the deterioration of the emission control
system. Second, through the Emissions Fleet Test, prototype fleets are
tested at 4000 miles to determine their emissions at close to the "break in"
point. To check manufacturers' data, EPA requires that a vehicle being
tested by the manufacturer for durability be brought to the EPA laboratory
in Ann Arbor, Michigan, for confirming tests. All emission data vehicles
are tested in the EPA laboratory.
During the past year, certification of most 1976 model year light duty
vehicles and light duty trucks was completed and certification of 1977 models
began. The certification program for the 1976 model year involved monitoring
the test programs of approximately 50 manufacturers, reviewing durability
data from approximately 300 vehicles and engines, and reviewing emission
data from 1100 vehicles and engines. To reach this level of certification,
EPA conducted approximately 2000 emission tests on 1976 light duty vehicles.
To prevent possible unauthorized and unreported maintenance practices,
EPA inspectors perform checks of manufacturers' facilities and records to
ensure that established test procedures are followed and investigate reports
of possible violations of regulations. In-depth inspections of major manu-
facturers' 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 production. Approximately 600 tests were con-
ducted during the past calendar year to determine emission compliance of
modified versions of certified vehicles.
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Since the 1971 model year, emission test results have been published
in tne Federal Register. Beginning with the 1973 model year, fuel consump-
tion 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
labels were posted on new cars by manufacturers participating in the EPA/
FEA-sponsored fuel economy labeling program. Fuel economy for 1973 and 1974
model year vehicles was based on the cold-start city test, representative of
typical city driving. A highway fuel economy test procedure was added in
the 1975 model year and, to provide additional fuel economy information, a
combined city-highway mileage figure is presented for 1976 model year
vehicles. EPA is thus 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
Motor Vehicles
The number of vehicles equipped with catalysts has continued to increase,
now comprising more than 85 percent of 1976 model year vehicles. Approxi-
mately 70 percent of 1975 model year vehicles were catalyst equipped. The
49-state interim standards for the 1976 model year (excluding California)
permit manufacturers to choose between catalyst and noncatalyst systems.
The greater use of catalysts for the 1976 model year results from the addi-
tional fuel economy advantage they offer.
The sales-weighted fuel economy of the 1976 model year fleet is 12.8
percent better than the 1975 fleet, according to EPA test data. This repre-
sents a 26.6 percent average fuel economy improvement for 1976 over 1974
cars. This gain is well over half of the President's goal of a voluntary
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40 percent fuel economy improvement by 1980. Changes in carburetion, weight
reductions, improved transmissions, lower axle ratios, and electronic ignition
systems should also continue to contribute to improved fuel economy within
present emissions standards.
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 recirculation. The
1976 models continue utilization of a greater variety of control approaches
that began in 1975. Saab, for example, uses fuel injection and no catalyst
to meet both Federal and California standards. Mazda uses a thermal reactor
and Honda uses its compound vortex controlled combustion (CVCC) stratified
charge engine to meet the California standards.
EPA's technical staff has analyzed extensive information provided by
automobile manufacturers under the provisions of section 202(b)(4) concern-
ing their progress toward meeting the Federal emission standards. The
paragraphs which follow represent the collective judgment of EPA engineers
directly responsible for the interpretation and analysis of the information.
There is doubt that manufacturers will be able to meet the 0.4 g/mi
NO standard in 1978. The most promising technologies for meeting this
n
standard, dual catalysts and three-way (single bed) catalysts, still have
unresolved problems. The present generation of dual catalysts have shown
poor durability. There are also concerns about potentially hazardous
unregulated emissions that require further study before such devices are
allowed to be used on a widespread basis, Several problems are associated
with meeting the 0.4 NOX standard with three-way catalysts. First, the three-
way catalyst is extremely sensitive to oxygen concentrations and conventional
carburetors cannot provide the control of air/fuel ratio required for their
proper operation. Lead time for the production of the number of electronic
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fuel injection systems or other advanced fuel metering systems required of
the entire auto industry is considered to be about 3 to 5 years. Second,
the N0x reducing activity of the three-way catalyst is too low to permit
large cars to comply with the 0.4 g/mi N0x standard. Third, the durability
of three-way catalysts is not yet proven. Also, there may be a shift in
the air/fuel ratio control point as the catalyst sensor ages.
Depending on advances made beyond present system designs, it is expected
that achieving 0.4 g/mi N0x for Federal emission standards will result in a
fuel economy penalty. If 1979 is the first year attainment of statutory NOX
Is required, the fuel economy penalty compared to 1976 levels could be as
. Further advances 1n technology would be expected to
decrease penalties to approximately 5 percent in 1980, relative to 1976.
Aircraft
Studies have continued 1n 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
emission 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 govern-
ment agencies in development of techniques for reducing emissions from piston
engine-powered general aviation aircraft; and (4) development of final stand-
ards applicable to engines that power supersonic transport aircraft.
In conducting the above programs, maximum advantage is taken of ongoing
efforts by other Federal agencies active in the aircraft emission area. These
are principally the National Aeronautics and Space Administration, the
United States Air Force, and the Federal Aviation Administration. In
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addition, the Department of Transportation has completed a Climatic Impact
Assessment Program, and EPA is studying its findings to ascertain whether
the EPA aircraft regulations already promulgated require modification to
respond to upper atmosphere problems.
ADDITIONAL ACTIVITIES IN THE MOBILE SOURCE AREA
Emission Factor Program
The Emission Factor Program is an ongoing series of studies designed
to obtain current data on emissions of in-use vehicles for the use of State
and local agencies, Federal air pollution officials, engine and vehicle
manufacturers, and concerned citizens.
Light Duty Vehicles - The most recent study, the third in the series, con-
sisted of exhaust emission tests of over one thousand 1966 to 1974 model
year in-use light duty vehicles. As in the earlier studies, the general
downward trend in HC, CO and NO levels continued. Comparing the results of
^
the first three programs reveals a general tendency for HC and CO levels
to increase with vehicle age and mileage, probably because older vehicles
may not be maintained in accordance with manufacturers' recommendations.
This third study was also the first program in which the effects of air con-
ditioning and vehicle loading upon emissions and fuel economy were measured
for in-use vehicles. Results indicated that the operation of air condi-
tioners had an adverse effect on both fuel economy and emission levels, as
did increased load weight of more than 500 pounds.
The fourth program (FY 74), in progress at this time, is the performance
of tests on approximately 2000 catalyst-equipped vehicles from around the
country. It will provide the first large-scale results of emission levels
of catalyst-equipped vehicles in use.
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Heavy Duty Vehicles - Present Federal test procedures for heavy duty vehicles
(HDVs) involve emission measurements during a nine-mode test for gasoline
engines and a thirteen-mode test for diesel engines using an engine dynamometer.
These tests provide accurate measurement of inter-city emission levels but
may not accurately represent emission levels from all pollutants in city
driving. Therefore, test procedures are under development which will employ
a chassis dynamometer and a driving cycle representative of truck operation
in urban areas. These tests and driving cycles may form the basis for pro-
posing new heavy duty standards and test procedures in the future.
The most recent study in this area has centered around the measurement
of emissions from heavy duty trucks operated on a road course and the corre-
lation of the results with those obtained on a chassis dynamometer. Chassis
dynamometer test results using the nine-mode and thirteen-mode Federal
test procedures correlated reasonably well with road course emission measure-
ments. Results generally indicated that road test emission levels were
slightly higher than those attained in the chassis dynamometer test for
hydrocarbons and carbon monoxide and slightly lower for oxides of nitrogen
emissions.
The results from these programs will improve the accuracy of HDV
emission factor estimation and provide data for evaluation of potential
improvements in certification test methods.
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 the fuel economy characteristics of new automobiles.
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EPA instituted a voluntary fuel economy labeling program in 1975 and 1976,
co-sponsored by the Federal Energy Administration.
Of all cars sold in the United States, 99 percent are now 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, transmission, and car
line. In some cases, the label may also specify that the fuel economy results
are representative of cars of the same weight and axle ratio. Each label now
bears three fuel economy figures—one determined by a city driving test, one
by a highway test, and a calculated composite of the two. The city fuel
economy figure is derived from the EPA emission certification test and the
highway fuel economy figure is derived from a special highway driving cycle
test performed on all certification cars tested by EPA. The composite is
calculated from a "harmonic averaging" of the two test results based on
Federal Highway Administration statistics indicating that the average
vehicle is driven 55 percent in city conditions and 45 percent in highway
conditions.
The results of EPA tests are also used to achieve uniformity in adver-
tising. The Federal Trade Commission issued voluntary guidelines effective
October 15, 1975, suggesting that any auto advertisement making miles-per-
gallon claims use EPA figures. Both highway and city figures should be
given and the characteristic vehicle information (engine size, number of
cylinders, fuel system, and transmission) should also be mentioned. Guide-
lines also suggest that advertisements mention that EPA figures are no
guarantee of a specific fuel economy value under all conditions or for all
drivers.
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EPA has again published, in cooperation with the Federal Energy
Administration, The 1976 Gas Mileage Guide for New Car Buyers, listing fuel
economy results for all 1976 model year passenger cars and light trucks. Two
added improvements to the 1976 guide are the separate MPG listings for all
vehicles offering manual versus automatic transmissions and the listing of
the mileage at which the catalytic converter should be replaced on those
cars that need such replacement. The pamphlet also describes the concept of
fuel economy and stresses its importance as a purchase criterion for new car
buyers.
Characterization of Currently Unregulated Emissions
Studies involving unregulated pollutants from both regulated sources and
fuels have continued through EPA contracts and in-house testing. In prior
years the emphasis involved characterization of reactive hydrocarbons,
aldehydes, polycyclic organic matter (POM), and particulate emissions.
Recently, additional unregulated pollutants such as platinum, nickel compounds
(nickel carbonyl), and sulfur compounds (HUS, COS, CSp) are being measured.
Sulfates are the only currently unregulated mobile source pollutant for
which regulations are being developed. However, measurement of the full
range of pollutants continues on advanced prototype vehicles sent to EPA for
testing as well as on catalyst-equipped vehicles, motorcycles, diesel-
powered vehicles, and aircraft.
Additional studies are continuing in an attempt to characterize unregu-
lated emissions resulting from the presence of scavengers used with lead in
leaded fuel and from manganese and other octane-boosting fuel additives.
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Sulfuric Acid Emissions from Catalyst-Equipped Vehicles
During the past year increased concern over sulfuric acid emissions
from catalysts has been responsible for intensive study by EPA's Office of
Air and Waste Management and Office of Research and Development. Primary
considerations include methods of measuring and controlling such emissions
and the estimated impact of sulfuric acid emissions on air quality and
public health.
EPA papers have been written reassessing the public health problems,
tests have compared the levels of catalyst sulfuric acid emissions with
those of non-catalyst vehicles, and public hearings have been held. These
were all instrumental in the March 1975 decision to suspend the 1977 model
year standards for HC and CO. The stricter 1977 standards were replaced by
a continuation of 1975 interim standards for these pollutants.
Measurement has established that the sulfuric acid emissions of a non-
catalyst car with a conventional internal combustion engine are approximately
0.001 gram per mile. Catalyst cars without air injection generally yield
somewhat higher results, but with air injection test results have generally
demonstrated much higher levels of sulfuric acid emission. It is important
to note, however, that large variations in test data exist.
Because long periods of time are required to complete new studies of
the risk that sulfuric acid concentrations pose to health, there remains
uncertainty as to the concentrations of sulfuric acid in the atmosphere
which would pose a threat to public health. However, limited test results
indicated that the risk was sufficient to warrant suspension of the more
stringent HC and CO standards that could only be met by the Installation of
air pumps. Air pumps would increase the levels of oxygen in the catalyst
and result in greater emission of sulfuric acid. By retaining the national
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interim standards, the Administrator concluded, the potential of a sulfuric
acid problem would be considerably decreased. Indications demonstrated that
interim standards could be met by some non-catalyst cars and those using
catalysts which would not necessitate air pumps.
The March 1975 suspension decision announced EPA's intent to establish
a sulfuric acid emission standard applicable to the 1979 model year. EPA
has worked closely with industry and held public meetings in relation to
this goal. Intensive study of emission data, catalyst technology, and test
procedures continues, and Notice of Proposed Rulemaking for sulfuric acid
emissions is expected in mid-1976 (see Chapter IV),
A new driving cycle closely resembling crowded freeway conditions has
been developed for measuring sulfate emissions. Various techniques for
reduction of sulfate emissions from catalysts such as a three-way catalyst
and sulfate traps are being explored, as well as the feasibility of gas
desulfurization. EPA also continues to monitor research toward achieving
standards for regulated pollutants without the use of catalysts.
Alternative Automotive Fuels
EPA has initiated investigations of automotive fuel alternatives to
conventional gasoline and distillate fuels from petroleum. Earlier investi-
gations determined that methanol from coal and distillate-like fuels from
coal and oil shale were the most economically feasible alternative fuels for
the years 1980 to 2000. In 1974, several programs were initiated to charac-
terize the physical and engine operational properties of methanol and
gasoline-methanol blends; this work is continuing.
In 1975 a program was initiated to evaluate the potential emissions from
engines using gasoline-like fuels derived from coal and oil shale. Potential
emission? to be considered include trace metals, sulfur and nitrogen
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compounds, aldehydes, particulates, acids, polycyclic organic matter,
alcohols and odors, both from the fuel itself and from its combustion
products.
Low Emission Vehicle Certification Board (LEVCB)
Section 212 of the 1970 Amendments to the Clean Air Act 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 up to double the market
value 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. To date no candidate vehicle submitted has accomplished
this.
As the likelihood of achieving the objectives envisioned by this section's
drafters is very small, the Administrator of EPA has recommended to the
Subcommittee on Environmental Pollution, Committee on Public Works, U.S.
Senate, that the following alternatives be considered: (1) eliminate
section 212 from the Clean Air Act,or (2) substitute a less cumbersome pro-
gram than that set up under section 212--perhaps one simply authorizing funds
for the General Services Administration and other Federal agencies to cover
the added costs of procuring electrically powered vehicles.
Federal Clean Car Incentive Program (FCCIP)
The Federal Clean Car Incentive Program was designed in 1971 to foster
the development of new types of low-emission vehicles capable of meeting
statutory standards. When the program began, twenty proposals were received;
seven of these were accepted for more detailed study. In May 1973 the
Advisory Committee on Alternative Automotive Power Systems advised EPA to
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phase out the FCCIP. Since that recommendation, no new candidates have been
accepted. Of the seven candidates accepted for study, two vehicles entered
the testing phase. The first candidate was rejected in 1974 because of
unacceptable emission degradation performance and the second was rejected in
May 1975 because of the failure to demonstrate compliance with FCCIP entry
requirements for NO and fuel economy.
/\
Research and Development on Automotive Emissions
On January 19, 1975, the President signed legislation creating the
Energy Research and Development Administration (ERDA). The bill included
the transfer of the research, development, and demonstration sections of
the Advanced Automotive Power Systems Program (AAPS) from the Environmental
Protection Agency to ERDA. Assessment, monitoring, and low emission
vehicle certification activities of AAPS were retained by EPA to ensure that
EPA remained abreast of technical advances in the field. The research and
development function of AAPS, however, is now coordinated by ERDA.
Transportation Control Plans
Progress has been made in implementing all of the transportation control
measures. For example, motor vehicle emission inspection and maintenance
programs are being implemented in New Jersey, Cincinnati, Chicago, and Los
Angeles, with other areas planning to begin programs this year. Five
California cities as well as Portland, Oregon, and Seattle, Washington,
are developing parking management plans. Several cities, such as
Philadelphia, are inaugurating new bus lanes to provide better mass transit
service, while other cities, such as Newark and Seattle, are instituting
"parking freeze areas" to discourage the use of automobiles in center city
areas. Still other cities, such as San Diego, are well advanced toward full
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implementation of gasoline vapor recovery regulations. In areas where
employer mass transit incentive regulations are in effect, numerous large
industries have submitted information describing the company's plans for
reducing single occupancy auto commuter trips by their employees.
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VI. STATUS OF ENFORCEMENT ACTIVITIES
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.
0 §110, State Implementation Plans (SIPs) - which provide
for establishing state air pollution limitations designed
to achieve health related (primary standards) and welfare
related (secondary standards) air quality goals.
0 §111. New Source Performance Standards fNSPS) - which
require EPA to develop emission limitations for newly con-
structed 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 section 110. After their promulgation,
states are encouraged to assume responsibility for the
enforcement of these standards.
0 §112, National Emission Standards for Hazardous Air
Pollutants (NESHAPs) - which require EPA to develoo emission
limitations for especially toxic pollutants for which air
quality standards cannot be adequately established. As
under section 111, states may request delegation of these
standards.
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While the Act placed the primary responsibility for attainment and
maintenance of air quality standards upon the states, EPA's enforcement
authority was also greatly strengthened under the 1970 amendments.
Section 114 of the Act authorizes EPA to make inspections, require reports
and recordkeeping, and require sources to sample their emissions in order
to verify compliance with the emission limitations established above.
Section 113 of the Act authorizes EPA to actively enforce against sources
violating requirements established under sections 110, 111, 112, and 114
by issuing an order to comply or by commencing civil or criminal action.
The Clean Air Act was further modified in 1974 with the addition of
section 119, "Energy-Related Authority," which defines EPA's role in the
implementation of the Energy Supply and Environmental Coordination Act of
1974. Under section 119, the Administrator is given the responsibility for
ensuring that attainment and maintenance of the ambient air quality stand-
ards is not endangered by any stationary fuel-burning source shifting from
oil to coal. This is to be accomplished through specific conditions and
limitations laid out in a compliance schedule for each source prohibited
by the Federal Energy Administration from burning oil, and is to be enforced
via the powers in sections 113, 114, and 119.
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 enforce-
ment 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.
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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.
§110, State Implementation Plans (SIPs)
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 five air pollutants:
particulate matter, sulfur dioxide, nitrogen dioxide, carbon monoxide,
-—• '.
and photochemTcal oxidants. Under the Act, the states then had just 9
months to develop comprehensive implementation plans (which included enforce-
able 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 enforceable emission limitations affecting stationary sources. The
Act allows 3 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 were to be met by May 31, 1975.
Of a total of 247 Air Quality Control Regions (AQCRs), however, it is
currently estimated that 132 are not achieving primary standards for partic-
ulates, and 35 AQCRs are not attaining primary standards for sulfur oxides.
The reasons for non-attainment differ in each AQCR, but the most common
causes, each contributing in varying amounts to air pollution problems,
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are: non-compliance by major and minor stationary sources, deficient SIPs,
and high background levels of fugitive dust. State and Federal programs
have faced an immense task in achieving compliance since there are estimated
to be over 200,000 stationary sources subject to SIP emission standards.
Approximately 20,000 of these sources 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 percent of all air pollution emitted
by stationary sources. Accordingly, EPA and state enforcement programs
have focused through 1975 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 investigated
only about 7,000 of these sources. By January 1975, 19,175 of these major
emitters had been identified and investigated, and to date state and Federal
programs have located and inspected about 19,958 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 six enforcement actions had been taken against stationary sources
in 1972. In 1973, the number of EPA enforcement actions increased to 112,
and in 1974 EPA took 271 enforcement actions. With the addition of nearly
600 enforcement actions to date, the cumulative number of actions brought
now approaches 1,000. A summary of these actions, current through June 1975,
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 limita-
tions. In 1972 only about 100 compliance investigations were made under the
authority of section 114 of the Act; in 1973 the number of field actions
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Increased to 2,000; In 1974 about 3,600 such investigations were completed;
and this year EPA completed over 6,000 field investigations. 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 19,958 identified major sources mentioned above, a total of
16,271 (82 percent) now comply with applicable emission limits or are meet-
ing compliance schedules, an increase of almost 2,700 over the number known
to comply a year ago. Of the 16,271 in compliance, 14,826 are in final
compliance with all requirements, and 1,445 are meeting increments in their
compliance schedules. About 6,500 major sources had yet to be identified
or investigated at the beginning of 1974; as of October 1975, very few
major sources are thought to remain outside state and EPA inventories, and
1,200 of the identified major sources are the targets of EPA and state
investigations to complete determinations of compliance status. Some 2,460
major sources (12 percent) 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 still pose large compliance problems, and the problems presented by
large numbers of non-complying "minor" sources (i.e., those emitting under
100 tons/year of a pollutant) are just now beginning to be addressed.
Although state and Federal agencies do not yet have adequate inventories of
minor air pollution sources, it is estimated that about 200,000 minor sources
exist that are subject to SIP emission limitations, and that a large pro-
portion of these are contributing to failures to attain the primary
-------
standards. EPA and states are now assessing the reasons for non-attainment
In each AQCR where primary standards are not being met and will in 1976
develop and begin to implement action plans based on these analyses. These
action plans will establish priorities for enforcement efforts to achieve
the greatest improvements in air quality as quickly as possible by identi-
fying, on a source-by-source basis, those non-complying major and minor sources
that are contributing to non-attainment problems. It is becoming evident,
as more major sources are brought into compliance, that although large
strides have been made in improving air quality, primary standards will not
be attained until vast numbers of smaller emitters comply with emission limits-
Although all the data are not yet collected and evaluated, it is likelvjtha.t „
the analyses will identify 130,000 such sources as possible targets for
enforcement attention.
Several notable categories of major polluters, however, remain under
close scrutiny by states and EPA. Nationwide programs are now being carried
out to bring about compliance as quickly as possible by coal-fired power
plants, iron and steel manufacturing plants, and smelters.
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 60 percent 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 limi-
tations 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
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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
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 and significant progress has been made since the
hearings. Approximately 400 coal-fired power plants in the U.S. (excluding
Ohio) together provide about 150,000 megawatts of generating capacity. About
three-quarters of these plants, representing only half of the generating
capacity, are in final compliance with applicable SIP requirements. A total
of 102 power plants with 73,795 megawatts of coal-fired capacity currently is
not in compliance. In addition, 46 plants in Ohio with a combined generating
capacity of 21,600 megawatts are not yet covered by promulgated S02 regula-
tions. (Regulations have been proposed and public hearings are underway.)
Ahout 40 of these 102 plants that are not meeting final SIP emission limita-
tions have firm plans for achieving compliance, leaving some 60 plants,
totalling 45,339 megawatts of generating capacity, out of compliance and
subjects of EPA enforcement actions—most of which will need substantial
control (FGD or low-sulfur coal) to achieve compliance.
Another measure of the effectiveness of EPA's power plant efforts is the
rise in use of FGD control devices. As of January 1976, 22 FGD installa-
tions were in operation and 20 were under construction. An additional 67
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units are in various stages of planning or consideration. These 109
units represent slightly more than half of the coal-fired capacity that
will need FGD systems by the end of 1980. The number of units now on-line
has more than doubled — from 10 to 27 — and three additional systems are
scheduled for startup in 1975. EPA estimates that approximately 90,000
megawatts of coal-fired generating capacity will need to install these
systems by the end of 1980.
Increasingly high reliability factors (in the 80 to 90 percent range
and up) are being evidenced, and several companies have purchased systems
to treat sludge by-products from nonregenerable scrubber systems. In
addition to the three units anticipated to be operable by the end of 1975,
11 more are expected by the end of 1976 and 20 more by the end of 1977,
bringing the total number of on-line systems to 62 by the end of 1977. The
rest of the units are scheduled for startup between 1978 and 1983, and some
startup dates are unknown because installation is tied to the startup dates
of new plants.
Although much progress has been made, full nationwide compliance by
coal-fired power plants has not yet been achieved and much work remains.
Sulfur oxide emissions from the remaining large power plants out of com-
pliance continue to have a major impact on achieving the primary ambient air
quality standards. Compliance by power plants therefore remains a high
priority for state and Federal programs, and EPA is continuing to bring
pressure on this industry to comply.
Iron and Steel Facilities - The iron and steel industry presents one of the
most difficult compliance problems confronting state and Federal air pol-
lution enforcement programs. There are nearly 200 of these installations in
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the United States which produce Iron and steel or solely coke to be used in
the metallurgical industry. Within these installations are a number of
major emitting processes, each of which presents tough technological problems
to control. The complex nature of the industry has also made it difficult
for control agencies to establish the degree with which various processes
within the facility do or do not comply with applicable air pollution laws.
When iron and steel facilities are compared to all stationary installations
capable of emitting more than 100 tons/year of a pollutant, it is apparent
that abatement of air pollution in the steel industry is far behind that in
most other stationary sources.
Table VI-1. COMPLIANCE STATUS OF MAJOR
STEEL PROCESSES VS ALL MAJOR
STATIONARY INSTALLATIONS
Sources
All major steel
processes (8/31/75)
All major stationary
installations
(9/30/75)
Number
1,177
19,958
Percent
complying
38
82
Percent in
violation
26
12
Percent
unknown
status
36
6
As indicated in Table VI-1, the steel industry is characterized by
less than half the degree of compliance of all other major sources, more
than double the violations, and a need for a great deal of investigation
of compliance status. It is important to note that in this comparison the
compliance status of individual processes within steel facilities is being
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compared to the status of total installations with major potential air pol-
lution problems. (The source of the stationary source compliance figures
is the EPA formal reporting system for September 30, 1975; under this
system a facility having several processes, only one of which is in viola-
tion or of unknown status, must be classified as in violation or unknown as
a whole.) Of a total of 1,177 such processes, 857 had been identified and
investigated to some extent by EPA and states by the end of August 1975.
Of the 857 processes investigated, 449 (52 percent) were found to comply
with emission limitations or compliance schedules; 301 (35 percent) were in
violation of the emission limitations without schedules or violating
schedules to achieve compliance; and 107 (13 percent) were under study by
EPA and state agencies to determine their compliance status. Of the six
major steel processes addressed in this summary, by-product coke batteries
were most often in violation of applicable standards - reflecting a
national controversy over the feasibility of controlling these types of
sources.
To date, EPA has taken a total of 54 enforcement actions at 33 iron and
steel facilities (32 notices of violation, 18 enforcement orders, and 4
referrals to Justice Department for civil/criminal prosecution), up from 8
such actions in 1973 and 25 actions in 1974. As a result of these actions:
- 2 installations contend they are in final compliance,
- 14 installations are meeting EPA schedules,
- 4 installations are meeting state schedules,
- 6 installations are negotiating schedules with EPA,
- 1 installation is negotiating a schedule with the state,
- 3 installations are subjects of state/EPA court actions, and
- 3 installations are involved in suits under section 307,
further enforcement action stayed.
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Although much remains to be accomplished in bringing steel mills and
coke plants into compliance, it is anticipated that the current enforcement
program will continue to yield results and that in 1976 most of the country's
iron and steel mills will be subjects of EPA enforcement actions leading to
firm compliance schedules.
Primary Non-Ferrous Smelters - Though small in number, the nation's 25 non-
ferrous smelters account for about 10 percent of the total sulfur oxides
emitted by stationary sources. Most of the Agency's problems in assuring
compliance by non-ferrous smelters have centered in the western U.S., where
six State Implementation Plans for sulfur dioxide affecting 13 smelters were
disapproved in 1972 as inadequate to meet the National Ambient Air Quality
Standards unless the smelters were controlled. Regulations have been pro-
mulgated for one smelter and proposed for three others, and will soon be
proposed for the remainder. These regulations require application of
reasonably available retrofit control technology and, if necessary, allow
the interim use of supplementary control systems (SCS) and tall stacks until
adequate constant emission control techniques become reasonably available.
Each smelter using SCS is further required to conduct a research and develop-
ment program to hasten the development of such technology. The one regula-
tion that has been promulgated (in Nevada) is now under review in the Ninth
Circuit Court of Appeals on a challenge under section 307 of the Clean Air
Act.
Five smelters in the eastern U.S. are now violating an approved
regulation. With few exceptions, state agencies are adequately responding
to the problem. In one case, EPA issued an administrative order to enforce
the regulation; in another, enforcement is stayed by a challenge to the SIP
under section 307; and one smelter ceased operations in May 1975, pursuant
to a state order.
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About half of the primary non-ferrous smelters are located in AQCRs
where statutory attainment dates have been extended to July 1977. No major
obstacles are anticipated that might prevent achievement of primary ambient
standards in the vicinity of these sources by the mid-1977 deadlines by
using SCS; however, installation of some constant control devices may not
be completed before the attainment date. Those subject to mid-1975 dead-
lines are, for the most part, now nearing compliance.
Summary - In summary, significant progress is being made in the enforcement
of SIP emission standards. Most national average concentrations for the
five 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. However, much remains to be accomplished in the next
several years as enforcement efforts are concentrated on the remaining major
hard-core polluters and on the vast number of minor polluters across the
country. While the health-related air quality goals have not yet been
attained in many areas, the progress being made in enforcement of SIPs will
ensure attainment as quickly as possible.
§111, New Source Performance Standards (NSPS)
New source performance standards (NSPS) were first promulgated on
December 23, 1971, for five categories of major emitters (steam electric
power plants, municipal incinerators, nitric and sulfuric acid plants, and
Portland cement plants). A second group of NSPS covering an additional 7
source categories was promulgated on March 8, 1974. NSPS for five categories
of the phosphate fertilizer industry were promulgated on August 6, 1975,
and NSPS for electric arc furnaces were promulgated on September 23, 1975.
NSPS for six other categories have been proposed and should be promulgated
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very soon. As of October 1975, 246 sources have been found subject to
promulgated provisions, and compliance levels of 89 percent have been
achieved.
Because these are primarily standards for new sources, relatively
little enforcement activity has developed to date from their promulgation.
However, sources starting up in 1976 are 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.
§112, National Emission Standards for Hazardous A1r Pollutants (NESHAPs)
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, beryl•
Hum, 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 com-
pliance by April 1975. EPA determined that only 620 of 13,000 potential
sources were actually covered by the regulations, and has to date brought
95 percent of these sources into compliance.
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.
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§119, Energy-Related Authority
The Energy Supply and Environmental Coordination Act (ESECA) of 1974
was enacted to maximize scarce-fuel savings, consistent with existing
commitments to protect and improve the environment. Under ESECA, the
Federal Energy Administration is empowered to prohibit the use of
petroleum products and natural gas at power plants and other major fuel-
burning installations in order to further the primary goal of fuel savings.
In recognition of the increase in emissions which will result from conver-
sions to coal, EPA is provided an integral role in the ESECA process to
ensure that primary standards are not exceeded while the FEA prohibition
order is in effect and to ensure expeditious compliance with applicable
SIP requirements. By December 1975, 74 generating units at 32 power
plants had been issued prohibition orders, and EPA is now completing
requisite analyses and drafting Federal Register proposals in order to
certify to FEA the date on which FEA's orders become effective.
MOBILE SOURCE ENFORCEMENT
The mobile source enforcement program is directed primarily toward
achieving compliance with vehicle emission standards and fuel regulations
promulgated by EPA under provisions of the Clean Air Act. Activities of the
program include preventing introduction of uncertified new domestic and
imported vehicles into commerce; auditing certification procedures of domes-
tic and foreign automobile manufacturers; enforcing vehicle assembly line
emission test activity and the recall, warranty, and tampering provisions
of the Act; developing and enforcing Federal regulations on the availability
of regulated fuels; and ensuring compliance with mobile source aspects of
the State Implementation Plans.
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Certification and Surveillance Procedures
Inspection/Investigation Programs - Under section 206(c) of the Clean Air
Act, EPA 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, 1975, mobile source enforcement personnel have con-
ducted 56 inspections of domestic and foreign motor vehicle manufacturers.
Such inspections include detailed audits of procedures and records, 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.
A total of eight vehicle manufacturer.investigations have also been
conducted since January 1, 1975; some of these arose from the inspections.
These investigations consist of a search of vehicle manufacturer records
and documents and interrogation of individuals to determine whether viola-
tions 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, 1975, five section 208 letters have been
issued.
Out of the eight investigations, one case was referred to the
Department of Justice for enforcement action. That referral dealt with
Chrysler Corporation's introduction into commerce of several hundred
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vehicles with incorrect emission components. Settlement and negotiation is
presently in progress among EPA, Chrysler and Justice. However, litigation
remains an alternative.
Selective Enforcement Audit Program - A new part of the EPA Mobile Source
Enforcement program concerns the development of an assembly line test
program. Called the Selective Enforcement Audit (SEA) program, this involves
the testing -- pursuant to an administrative order and in accordance with the
Federal Test Procedure -- of a statistically representative sample of pro-
duction vehicles from a specified configuration. If non-conformity is
established, EPA may revoke the certificate of conformity.
In December 1974, EPA proposed regulations concerning the implementation
of the Selective Enforcement Audit program and conducted a public hearing
on the proposed regulations in July.
Provisions for In-Use Motor Vehicles
Anti-Tampering Program - 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.
Since January 1, 1975, approximately 15 investigations have been conducted.
Further, the Regional Offices responded to many alleged violations of the
tampering prohibition during the same period. Three cases were referred to
the Department of Justice for action. Since January 1, 1975, four tampering
cases have been successfully prosecuted, resulting in civil penalties
totaling $4,950.
Recall Program - Section 207(c) of the Clean Air Act authorizes EPA to
order recall of vehicles if they do not conform to emission standards.
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Approximately 185,768 vehicles have been voluntarily recalled by manu-
facturers for correction of emission-related problems. EPA is monitoring
these recalls in addition to two recall campaigns begun in 1974 involving
approximately 1 million vehicles.
Since January 1975, EPA has conducted 22 investigations of possible
recalls and is currently conducting investigations involving General Motors,
Ford, Chrysler, AMC, Volvo, Toyota, and Volkswagen of America for possible
recalls.
Warranties and Aftermarket Parts Program - 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 lives.
The production warranty provision in section 207(a) of the Clean Air Act
requires that the manufacturers warrant that the vehicle or engine meets
applicable emission standards at the time of sale, and is free from defects
which, during the useful life, may cause the vehicle or engine to fail to
comply with the emission standards. Although this provision has been in
effect since the 1972 model year, it has proved of little utility to con-
sumers experiencing difficulties with their vehicle's emission control
system. The Agency believes that this is because consumers do not know with
any precision what components and failures are covered by the section 207(a)
warranty and, when they do make claims, are unable to sustain the burden
of establishing that the failure is indeed a defect causing the emissions
to exceed Federal standards, as section 207(a) is generally interpreted to
require. To overcome these difficulties and to make section 207(a) useful
to consumers with legitimate claims, the Agency intends ultimately to
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promulgate regulations defining the coverage of this provision. Major
activities since January 1, 1975, in support of this long-range goal include
the development of an advance notice of proposed rulemaking. To provide
technical support for this program, the relationship of defective vehicle
components to emissions is being investigated under contract. EPA also
continued to review owners' manuals to see that the section 207(a) warranty
is provided to consumers in language which adequately reflects the
statutory intent.
The performance warranty provision in section 207(b) of the Clean Air
Act, when implemented, will require that a manufacturer warrant that
properly maintained and used vehicles and engines comply throughout their
useful lives with emission standards when in actual use. This provision has
not been implemented because of the technical difficulty of identifying
relatively quick and inexpensive emission tests which "are reasonably
capable of being correlated" with the sophisticated test used on prototype
vehicles, as section 207(b) requires. Major enforcement activities in this
area since January 1, 1975, Include the continued analysis of correlation
data to attempt to identify correctable short tests and the response to a
Congressional report recommending that section 207(b) be substantially
repealed. This response was provided to the House Small Business Sub-
committee on June 26, 1975, and reiterated EPA's general support for section
207(b) as it is presently written.
In support of the warranty programs, and to protect against any possible
anti-competitive effects in the automobile aftermarket, EPA has endorsed an
industry-led voluntary self-certification program for certain automotive
aftermarket parts. The potential anti-competitive problems were the reason
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for the House Report recommending substantial repeal of section 207(b),
discussed above. Major efforts in this area since January 1, 1975, include
continued supervision of the industry'-s efforts to develop performance
standards for emission-related parts; an Agency report summarizing the com-
ments on the Federal Register Notice of November 14, 1974, outlining the
self-certification program; and the letting of a contract intended to
investigate the relationship between parts and vehicle emissions.
Imports Program - Sections 203(a)(l) and 203(b)(2) give EPA responsibility
for enforcing compliance of imported motor vehicles with emission standards.
In conjunction with the Bureau of Customs, EPA has monitored importation of
an estimated 2 million commercial and privately owned vehicles since
January 1, 1975. Through that program, 259 noncomplying vehicles imported
under bond have been modified pursuant to administrative orders. In
addition, 71 nonconforming vehicles have been exported pursuant to adminis-
trative orders. A total of 173 bond forfeitures have been assessed through
Customs for noncompliance with the regulations.
EPA has conducted 26 investigations of alleged illegal importations.
Two cases were referred to Justice Department for prosecution.
Fuels Enforcement Program - EPA has responsibility for enforcing section
211(c)(l) of the Clean. Air Act relating to the regulation 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.
EPA 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, through the use of a mobile van test facility.
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From January 1 of this year, EPA has conducted approximately 18,500
Inspections of service stations to ensure compliance with the unleaded
fuel regulations. Approximately 15,000 gasoline samples were taken, of
which about 160 were found to be contaminated with lead. Approximately
6900 minor violations were also found during this period. Because many of
r.
the stations contained multiple violations, the number of stations out of
compliance is estimated at 3000. Enforcement has issued approximately 3500
warnings and 260 complaints, and has collected close to $31,000 in penalties
during this period.
Generally, warnings are issued for minor violations, and penalties
are assessed for contamination, deliberate violations, repeated violations,
and failure to respond to warnings. The warning generally allows the
violator to come into compliance 1n a reasonable time. When a contamination
is found, a complaint is usually issued against both the retailer and his
supplier, with each given an opportunity to show that he is not responsible.
Inspection/Maintenance and Transportation Control Plans
During the past year, EPA has taken efforts to assure the implementa-
tion of state Inspection/Maintenance programs. Establishment of these
programs will reduce emissions from vehicles in use and will help assure
that National Ambient Air Quality Standards for carbon monoxide and photo-
chemical oxidants are achieved in certain Air Quality Control Regions.
During the past year, EPA has issued eight notices of violation under
section 113 for failing to implement Inspection/Maintenance programs. Two
enforcement orders under section 113 of the Clean Air Act were issued to
New York and Chicago.
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In relation to Transportation Control Measures, EPA has issued two
Notices of Violation and two section 113 orders to Chicago, 13 notices of
violation and seven section 113 orders to the City of New York, and 90
Notices of Violation to employers in New Jersey for failure to implement
employer carpool control measures.
While Title I gives EPA the authority to ensure enforcement of
Transportation Control Plans, recent Circuit Court decisions relating to
enforcement of Transportation Control Plans and Inspection/Maintenance have
taken opposing views on the issue of whether EPA has the authority to take
enforcement actions directed at governmental bodies. The courts have,
however, unanimously upheld EPA's authority to take enforcement actions
against individual sources.
COMPLIANCE BY FEDERAL FACILITIES
EPA's policy on Federal facilities, as expressed in Executive Order
11752 (December 17, 1973), is based on the belief that Federal facilities
should provide leadership in the prevention, control, and abatement of
pollution by complying with substantive standards and limitations of Federal,
State, and local laws, just as any person must comply with such standards
and limitations. To help facilitate compliance, certain responsibilities
of the Administrator and the heads of Federal agencies were established by
the Executive Order. The Administrator has three main duties with regard to
coordination and cooperation between Federal agencies and State and local
pollution control agencies:
1. Issue regulations and guidelines to expedite compliance.
2. Provide liaison to coordinate Federal agency action with State
and local programs for pollution control.
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3. Mediate conflicts between Federal agencies and State and local
*>
agencies in matters of compliance.
The heads of Federal agencies also have three main duties to assure
cooperation with the Administrator and State and local agencies:
1. Comply with the regulations and guidelines issued by the Admini-
strator.
2. Provide information to the Administrator and cooperate with the
State and local agencies to help determine compliance with applica-
ble standards.
3. Consult, when appropriate, with the Administrator and State and
local agencies concerning the best techniques for solving pollution
problems.
Although the Executive Order clearly expresses the policy that Federal
facilities are required to comply with substantive standards and limitations,
it also states that it is not the policy of the Executive Branch to require
Federal facilities to comply with State and local administrative procedures
with respect to pollution control. This distinction between substantive
standards and procedural requirements is the main issue in two conflicting
court cases - Kentucky^ v. Ruckelshaus in the Sixth Circuit Court of Appeals,
and Alabama v. Seeber in the Fifth Circuit. In the earlier case, Kentucky
v. Ruckelshaus, the court held that Federal facilities were not compelled
to apply for State operating permits, as such permits were considered pro-
cedural rather than substantive requirements. In so holding, the court
reasoned that subjection of Federal facilities to State and local permit
requirements was not intended by Congress in its plan to prevent and control
air pollution.
The Fifth Circuit Court of Appeals in Alabama v. Seeber, however,
reached a contrary decision. In that case the Court relied on section 118
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of the Clean Air Act to conclude that Congress did intend that Federal
facilities be required to obtain State permits by quoting language that
such facilities are subject to the same State requirements as any person.
The substantive/procedural distinction that was upheld in the Kentucky
case was rejected in this case, despite the existence of Executive Order
11752, which, according to the Court, cannot modify the Clean Air Act.
Contrary to the Seeber case it remains the position of EPA to
continue to follow the policy guidance of Executive Order 11752, and the
opinion in the Kentucky v. Ruckelshaus case. Since the parties in that
case have appealed to the Supreme Court, it is highly probable, especially
in the face of two conflicting Circuit Court decisions, that the case will
be heard soon.
Compliance through Federal Procurement Activities
Legal Authority and Background—Section 306, "Federal Procurement," was
designed to utilize the Federal contract, grant and loan processes as a
means of encouraging compliance with the Clean Air Act. Section 306(a)
prohibits any Federal agency from contracting to perform at any facility
giving rise to a criminal conviction under section 113 of the Act. Section
306(c) empowers the President to issue an Executive Order requiring each
Federal Agency to use the contract, grant, and loan processes to implement
these provisions of the Act and to set forth procedures, sanctions, penalties,
and such other provisions as the President determines necessary to carry
out the section. Section 306(d) empowers the President to exempt any
contract, loan or grant from the provisions of the section on the basis of
paramount national interest. This section is comparable to the language of
section 508 of the Federal Water Pollution Control Act of 1972, as amended
(33 U.S.C. 1251 et seq).
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Executive Order 11602, issued under the Clean Air Act to implement
section 306, was superseded by Executive Order 11738, issued on September 10,
1973. The Order used the same language as E.O. 11602 but made its provisions
applicable to both the Air and Water Acts.
Section 5 of Executive Order 11738 requires the Administrator of
EPA to issue implementing rules and regulations. Regulations implementing
the air requirements were promulgated in the Federal Register on December 27,
1973 (40 CFR Part 15, 38 FR 35310). On April 16, 1975, EPA promulgated
regulations to revise the previously promulgated air regulations and to
incorporate appropriate provisions of sections 306 and 508 and Executive
Order 11738. These regulations essentially repeat the requirements of
the December 27, 1973, air regulations but make them applicable to both the
Air and Water Acts. The regulations provide for the establishment of a
List of Violating Facilities which will show those facilities ineligible
for use in a Federal contract, grant or loan.
The most controversial issue surrounding the regulations concerned
whether EPA had the legal authority to go beyond a Federal criminal convic-
tion as a potential basis for listing a facility. Pursuant to section 306(c)
of the Clean Air Act and sections 1,4, 5, and 7 of the Executive Order, EPA
has such authority. Section 306(c) is independent of section 306(a) in that
it vests broad authority in the President to set forth "procedures, sanctions,
penalties, and other provisions " to carry out the purposes of the section.
Section 306(a) refers only to one, "non-discretionary" basis for listing,
i.e., Federal-criminal conviction, and pertains only to Government contracts.
The Executive Order supports this interpretation. Section 1 defines the broad
purposes of Section 306, i.e., "to assure that each Federal agency ... shall
undertake procurement and assistance activities in a manner that will result
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in effective enforcement of the Air (and Water) Acts." Section 5 directs
the EPA Administrator "to issue rules and regulations as he deems necessary
and appropriate to carry out the purposes of the Order." Section 7 vests
futher discretion in the Administrator to take "appropriate action" in
cases of noncompliance. Thus, EPA's reliance on section 306(c) of the Act
and section 5 of the Executive Order in issuing its regulations indicates
that the Administrator has exercised his discretion in going beyond the one
"mandatory" basis for listing (Federal criminal conviction) in order to meet
the goals of the Act.
Description of Program—The program established in the regulations published
on April 16, 1975, affects contract, grant and loan activities
of all Federal agencies as of July 1, 1975. It is facility-oriented, not
company-oriented, so that only the specific facilities placed on the EPA
list will be ineligible for use in a Federal contract, grant, or loan.
Facilities will be listed upon a determination by EPA of continuing or
recurring noncompliance with clean air (or water) standards. However,
Federal criminal convictions require an automatic listing. When Federal
criminal conviction is the basis for listing, removal will not occur until
the Administrator certifies that the condition which gave rise to the con-
viction has been completely corrected. State and local criminal convictions
and Federal, state, or local civil adjudications or administrative findings
that such facility is in noncompliance with clean air (or water) standards
also may serve as a basis for listing. In those cases removal from the
list will not occur until EPA enters into an approved plan of compliance
which will ensure that the condition which gave rise to the listing will
be corrected. In cases where a facility has been subject to state or local
civil adjudications or administrative findings, EPA shall only consider
listing at the request of the Governor.
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The program will apply to any contract, subcontract, grant, subgrant,
loan, or subloan in excess of $100,000 as well as to any contract of a
lesser amount involving a facility listed on the basis of a Federal
criminal conviction.
In order to ensure due process, no facility will be listed until its
representatives have been afforded an opportunity to confer and present
information to the Director, Office of Federal Activities, EPA (this is
called a Listing Proceeding). If, in turn, a request to be removed from
the list is denied, representatives of the facility will be afforded a
hearing before an EPA hearing officer with fair opportunity to present
evidence and to cross-examine.
It must be emphasized that the program is an additional arm of the EPA
enforcement effort and is primarily designed to encourage voluntary compliance
and not to penalize a facility.
Implementation Within the Federal Establishment—Pursuant to section 4 of
the Executive Order, each Agency of the Executive Branch is obligated to
implement the listing program through its contract, grant, and loan activities
Implementation involves amending the Federal Procurement Regulations (FPR),
the Armed Services Procurement Regulations (ASPR), and any supplemental or
comparable regulations as well as close coordination with EPA to ensure
that requirements of the program are fully carried out. The ASPR, FPR
(which guides civilian agencies), and NASA and ERDA procurement regulations
have been amended. Also, agency grant and loan provisions have been amended.
EPA will publish the List of Violating Facilities periodically in the
Federal Register. In addition, contact points within each Federal agency have
been identified to receive EPA's List of Violating Facilities every time a
new facility is added to ensure prompt implementation.
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Under the contract provisions each bidder must certify when bidding on
a particular contract that he is not on EPA's List of Violating Facilities
and that he will promptly notify the contract officer of the receipt of any
communication that he is under consideration for listing. If a particular
basis for listing has been identified against a facility but the facility
is not on the EPA list, the Director, Office of Federal Activities, EPA,
may request that an award of a particular contract be withheld for a
period not exceeding 15 days pending completion of an investigation.
It is also required that contractual provisions be inserted in every
non-exempt Federal contract. The contractor must agree that no portion of
the work will be performed at a facility on the EPA list; that he will
comply with the clean air (and water) standards issued prior to the contract
award and the requirements of records and inspection under the Air and Water
Acts; that he will use his best efforts to comply with clean air (and water)
standards where the facility has not been listed prior to award; and that
the contractor will insert these same requirements in any non-exempt sub-
contract. This last provision illustrates the reach of the program to
cover all sub-contractors.
These same requirements have been inserted in agency regulations
covering grants and loans.
It is emphasized that the awarding agency must determine whether the
solicitation and contract provisions are being followed and that each agency
can assist in the effectiveness of the program by encouraging contractors
to comply with clean air (and water) standards. Also, the head of each
agency has a responsibility to ensure that all officers and employees of
his agency involved in the contract, grant, or loan process be familiar
with the regulations. To further assist EPA in implementation, the head
of each agency has responsibility to promptly report to EPA any condition
in a facility which may involve noncompliance with air (or water) standards.
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SUMMARY OF LITIGATION IN 1975
Transportation Control Plans
By far the largest legal issue arising out of the extensive litigation
concerning transportation control plans has concerned the extent to which,
under the Clean Air Act and the Constitution, EPA may require states to
implement programs to reduce pollution from private vehicles using public
roads.
One court has sustained EPA in full on this issue, reasoning that any
other approach would be impractical and that the states may Constitutionally
be regulated when they engage in activities affecting commerce. Two others
have taken a different position, holding that an attempt to make a state
administer and enforce programs to control pollution by its citizens is not
2
authorized by the Act and may be unconstitutional. Finally, a fourth case
has held that EPA may compel such implementation, but only as to programs
very closely related to the actual operation of the state-owned roads them-
3
selves and only so long as EPA does not compel the state to legislate.
With the circuits in disagreement on the interpretation of the Clean Air
Act as it pertains to EPA's authority, EPA has requested the Solicitor
General to appeal the last three decisions to the Supreme Court.
Lead Additives in Gasoline
Petitions for review were filed by Ethyl Corporation and other
companies challenging EPA's regulations providing for a 65 percent reduction
in the use of lead additives in gasoline by 1979 on the ground that lead
emissions from motor vehicles endanger public health. On December 20, 1974,
a panel of the District of Columbia Court of Appeals set aside the
regulations in a 2-1 decision holding that EPA had misconstrued the
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"endangennent" test of section 211 of the Clean Air Act and that the evidence
did not show a hazard to health. On March 17, 1975, the full Court voted
6-3 to grant EPA's petition for rehearing en bane and vacated the original
panel decision. The case was reargued on May 30, 1975. A decision is
4
expected at any time.
New Source Performance Standards
The first final decision of any of EPA's new source performance stand-
ards promulgated under section 111 of the Clean Air Act was issued in 1975.
That decision upheld EPA's standards for Portland cement kilns and the
economic and technical analysis supporting those standards. In mid-December
the Supreme Court refused to review the lower court's decision. Thus, EPA's
basic approach to new source performance standards has been approved.
Variances
In the only Supreme Court decision to interpret the Clean Air Act
since the Sierra Club decision, the Court held that state-issued variances
may be treated by EPA as SIP revisions and do not have to satisfy the
rigorous requirements of section 110(f) unless the variance adversely impacts
attainment or maintenance of ambient air quality standards. In addition to
upholding the Agency's position on variances, the decision is significant
because of its extensive discussion of other Clean Air Act matters.
Review of SIPs
Several circuit courts decided cases involving the question whether
EPA must, as a prerequisite to approval of an SIP or revision thereof,
determine that 1t 1s economically and technologically feasible. Two of
these cases were decided by the Third Circuit. In both cases, the Court
102
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reiterated its original position that feasibility issues had to be
8
addressed at the time of plan approval. Moreover, this court held that
in the course of such review EPA must, among other things, assess the impact
of the plan on the profitability of the companies challenging the plan and,
should the Agency determine that a plan is infeasible, it must disapprove
it. EPA has petitioned for Supreme Court review of both cases (St. Joe
Minerals vs EPA and Duquesne Light Company vs EPA), and has asked that the
court defer consideration of these cases pending a decision by the court
g
in the Union Electric case.
The remaining courts to address the feasibility review issue arrived
at decisions contrary to Third Circuit. One held that challenge to the
feasibility of a plan may be raised at the state level during the develop-
ment of a plan or in Federal (or state) court at the time the plan is
being enforced, but not in Federal court at the time the plan is being
approved. Another court ruled that EPA cannot consider anything other
than the eight requirements of section 110(a)(2) of the Act at the time
9
it approves a plan. A third decision stated that disputes involving
technical infeasibility are to be resolved at the State level.^
Dispersion Technology vs Constant Controls
In a significant decision, the Sixth Circuit aligned itself with the
12
Fifth Circuit and, citing Train vs NRDC et a!., supra, for authority, held
that dispersion technology such as tall stacks or intermittent controls may
not be utilized to meet emission limitations unless constant controls such
as scrubbers are demonstrated to be unavailable.13 A similar decision was
recently reached by the Ninth Circuit.14
103
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Enforcement
In a recent decision, the Third Circuit has held that grand jury pro-
ceedings convened by the Federal government to investigate possible criminal
violations of the Clean Air Act may not be interrupted solely because the
source in question is challenging the feasibility of the subject regulations
15
in a civil contempt proceeding at the state court level. This case tends
to confirm statements in prior court decisions indicating that state and
Federal enforcement actions may be simultaneously brought against a
polluter.
REFERENCES
1. Pennsylvania vs EPA. 500 F.2d. 246 (3d. Cir. 1974).
2. Brown vs EPA. 9th. Cir. No. 73-3306 (decided August 15, 1975);
State of Maryland vs EPA. 4th Cir. No. 74-1007 (decided September
19, 1975).
3. District of Columbia vs Train, D.C. Cir. No. 74-1013 (decided
October 28, 1975).
4. Ethyl Corporation ys EPA, No. 73-2205 and related cases (D.C. Cir.,
filed December 6, 1973; reargued May 30, 1975.
5. Portland Cement Association vs EPA. 513 F.2d 506 (D.C. Cir. 1975).
6. NRDC vs Train, 421 U.S. 60 (1975).
7. St. Joe Minerals vs EPA. 508 F.2d 743 (CA 3, 1975) and Duquesne Light
Company et al.. No. 72-1542 (opinion issued August 21, 1975).
8. Duquesne Light Company et al. vs EPA. 481 F.2d 1 (CA 3, 1973).
9. Union Electric Company vs. EPA. 515 F.2d 206 (CA 8, 1975); petition
for certiorari granted October 6, 1975.
10. Indiana & Michigan Electric Company et al. vs EPA, 509 F.2d 839
(CA 7, 1975).
11. Buckeye Power Company et al. vs EPA. No. 72-1513 (.CA 6 opinion issued
October 24, 1975) (relying on Trafn" vs NRDC supra).
12. NRDC et al. vs EPA. 489 F.2d 390 (CA 5, 1974).
104
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13. Big Rivers et alI. vs EPA and TVA vs EPA, 8 ERC 1092, Nos. 74-2015
and 74-2020 (opinion issued September 4, 1975).
14. Kennecott Copper Corp. vs Train, No. 75-1335 (CA 9, opinion issued
November 28, 1975).
15. In Re: Grand Jury Proceedings, Nos. 75-1450 and 75-1456 (CA 3,
opinion issued September 3, 1975).
105
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VII. 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 pollutants for which ambient 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 sub-
mitted 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 addition, companion
computer files of data on point source and area emissions, plus meteorologi-
cal data, afford researchers within EPA and outside a sophisticated tool for
investigating these complex influences on air quality.
Before the formal status of compliance with a standard can be deter-
mined for an Air Quality Control Region (AQCR), a reasonable history of data
(at least one year) must be compiled from a representative network of moni-
tors. A single station reporting a second high value over the short-term
standard is sufficient to document a violation of that standard; similarly,
a single station reporting an annual average of values that exceeds the
annual standard is enough to document a violation of that standard. Compli-
ance must usually be demonstrated by more extensive evidence from a
106
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multi-station network. The target date for completing these networks was,
in most cases, July 1974. Table VII-1 summarizes the progress made by the
states through 1974 in completing the networks proposed in their SIPs. The
number of AQCRs reporting violations of standards is summarized in Table
VI1-2. (This number of AQCRs reporting violations is different from the
number of AQCRs listed in Chapter II as being unlikely to attain standards
by the statutory date because the assessment in Chapter II is based on a
number of factors, only one of which is air quality data.)
The diagrams in Figures VII-1 through Vli-7 portray the distribution
of the AQCRs above and below each of the standards. These analyses are
based on data from the station(s) in each AQCR that report the highest
second maximum daily value or highest annual mean. Information on nitrogen
dioxide networks is not included 1n these tables and figures because the
Federal reference method has been rescinded, and N02 monitoring cannot be
required until a new method is designated.
If a comparison were to be made with similar tables and figures in
last year's report (Progress in the Prevention and Control of Air Pollution
in 1974: Report to Congress), it would appear that the number of AQCRs
violating standards for each pollutant has 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 1974 than in 1973 (see Table VII-3); still
more can be expected when the 1975 summaries are complete. It can also be
expected that some of these additional stations may reveal additional
violations in areas not previously monitored.
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Table VII-1. NATIONAL SUMMARY OF AIR MONITORING
STATIONS REPORTING 1974 DATA TO THE NATIONAL
AEROMETRIC DATA BANK BY SEPTEMBER 1975
Air monitoring stations
No. proposed for 1974a
No. reporting minimum data
No. reporting valid annual data0
TSP
3,510
3,788
2,004
so2
2,132
2,241
1,030
CO
457
377
-
Ox
458
343
.-
aNumber of stations proposed by states in their SIPs to be operating
in 1974.
At least three 24-hour values for intermittent monitors or 400
hourly values for continuous monitors.
cFour consecutive quarters (a calendar year) of statistically valid
data.
108
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Table VII-2. NATIONAL SUMMARY OF 1974 AQCR
ATTAINMENT STATUS BY POLLUTANT, AS REPORTED
TO THE NATIONAL AEROMETRIC DATA BANK
Air Quality Control
Regions (AQCRs)a
No. reporting minimal data
No. exceeding 24-hour primary
standard0
No. exceeding annual primary
standard0
No. exceeding 1-hour standard0
No. exceeding 8-hour standardc
TSP
236
99
111
—
--
so2
210
22
11
—
--
CO
92
_ _
13
58
°x
86
_ _
76
—
aTotal number of AQCRs = 247.
bAt least three 24-hour values for intermittent monitors or 400 hourly
values for continuous monitors.
An AQCR must have all reported stations showing no violations to be
considered an "attainment AQCR." If a single station in an AQCR
reports a violation, the entire AQCR is considered a "non-attainment
AQCR."
109
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Table VI1-3. GROWTH IN NUMBER OF MONITORING
INSTRUMENTS,a 1970-1974
Year
1970
1971
1972
1973
1974
Parti cul ate
1283
2044
2975
3762
3788
SO?
403
729
1311
2008
2241
CO
73
133
191
299
377
Ox
51
82
162
265
343
aBased on stations reporting at least minimal
data to EPA; some are not yet reporting
comprehensive data.
110
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•a
(0
-o
c
(O
•M
CO
0
(O
a:
2.
2.
1.
1.
1.
1.
1.
0.
0.
0.
0.
51-3
01-2
71-2
41-1
21-1
11-1
01-1
91-1
81-0
61-0
31-0
3 0
3.0
2.5
2.0
1.7
1.4
1.2
1.1
1.0
0.9
0.8
0.6
0.3
15
16
ho
17
20
18
114
|9
|22
25
|45
|41
l«
24-hour Primary
Standar^
260 yg/m
Number of AQCRs
Figure VII - 1. Distribution of AQCRs reporting second-high
24-hour values for particulates (no data available
for 11 AQCRs).
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
i
H .
|12
|23
|28
|17
123
|28
|23
J25
111
3
Primary Annual
Mean Standard
75 yg/m
Number of AQCRs
Figure VII - 2. Distribution of AQCRs reporting maximum annual
mean values for particulates (no data available for
49 AQCRs).
Ill
-------
$-
(O
t/>
o
to
ce.
•o
S-
na
T3
c:
2.51-3.
2.01-2.
1.61-2.
1.31-1
1.11-1,
1.01-1,
0.91-1.
0.81-0.
0.61-0.
0.31-0.
.0
.0
.5
.0
.6
.3
.1
.0
.9
.8
.6
.3
0
0
~^
h
J4
|s
12
_J7
4
h5
46 1
tf !1K
?4-
24-hour Primary
Standard,,
365 ug/m°
Number of AQCRs
Figure VII - 3. Distribution of AQCRs reporting second-high
24-hour values for sulfur dioxide (no data available
for 37 AQCRs).
X3.0
2.01-3.0
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
b
h
[i
J3
J2
0
]z
^
114
131
jEr 93
Primary Annual
Mean Standard
80 ug/m3
Number of AQCRs
Figure VII - 4. Distribution of AQCRs reporting maximum annual
mean values for sulfur dioxide (no data available
for 92 AQCRs).
112
-------
•o
(tJ
•0
C
00
o
o
(O
on
-o
ro
t3
C
fO
00
5
o
-l->
1.21-1.5
1.01-1.2
0.81-1.0
0.61-0.8
0.31-0.6
^0.3
Figure VI]
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
_ 3
3
7
10
\7
|36
1-hour
40 rag/m
Number of AQCRS
[ - 5. Distribution of AQCRs reporting second-high
one-hour values for carbon monoxide (no data
available for 155 AQCRs).
6
10
16
16
10
10
10
8
8-hour
Standarc
10 mg/m3
Figure VII -
Number of AQCRs
6. Distribution of AQCRs reporting second-high
8-hour values for carbon monoxide (no data available
for 157 AQCRs).
113
-------
IO
ID
C
ro
-M
to
o
rO
3.01-4.
2.01-3.
1.51-2.
1.21-1.
1.01-1.
0.81-1.
0.61-0.
0.31-0.
<= 0.
0
0
0
0
5
2
0
8
6
3
10
9
Il3
8
19
17
r
i
1-hour
btanaarcu
160 pg/m
Figure VII -
Number of AQCRs
7. Distribution of AQCRs reporting second high
1-hour values for oxldants (no data available for
161 AQCRs).
114
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SUMMARY OF AMBIENT AIR QUALITY DATA
The status of air quality in the United States in 1974 was in many
respects similar to that reported for 1973. Approximately the same percentage
of reporting stations are still exceeding air quality standards, with one
exception: an evident decline in the proportion of stations exceeding the
8-hour carbon monoxide standard.
All 247 AQCRs are required to be reporting at least one monitoring
station for total suspended particulate (TSP). Of these, 198 AQCRs had at
least one sampler station reporting enough data to compute a yearly average
(four consecutive quarters of statistically valid data) for the primary
annual TSP standard. Of the 2004 monitoring stations reporting a valid
year's data, 1537 (77 percent) reported values achieving the annual standard.
The 460 stations that had readings exceeding the standard were located in 111
of the 198 AQCRs reporting data sufficient to compute a yearly average.
All but 11 AQCRs reported minimal data for the primary 24-hour TSP
standard. Of the 3788 monitoring stations in these 236 AQCRs, 3462 (90 percent;
reported values achieving the standard. The 326 stations that had readings
exceeding the standard were located in 99 of the 236 AQCRs submitting minimal
data.
As with particulates, all 247 AQCRs are required to be operating at
least one sulfur dioxide (S02) monitoring station. Of these, 155 AQCRs
reported a valid year's data for at least one station. Of the 1030 monitoring
stations reporting a valid year's data, 999 (97 percent) reported values
achieving the primary annual S02 standard. The 31 stations that reported
values exceeding the standard were located in 11 of the 155 AQCRs submitting
data sufficient to compute a yearly average.
*
At least three 24-hour samples from a hi-vol or a bubbler; or 400 hourly
values from a continuous monitor.
115
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All but 37 AQCRs reported minimal data for the primary 24-hour SCL .
standard. Of the 2241 reporting stations in these 210 AQCRs, 2142 (over 95
percent) reported values achieving the standard. The 99 stations that had read-
ings exceeding the standard were located in 22 of the 210 AQCRs submitting data.
Carbon monoxide (CO) data were reported from 377 stations in 92 AQCRs.
(Not all AQCRs are required to have CO monitors.) The 1-hour CO standard
was achieved by 350 stations (93 percent) in 13 AQCRs; the 8-hour CO standard
was achieved by 166 stations (44 percent) in 58 AQCRs.
Oxidant/ozone (0 /Oz) data were reported from 343 stations in 86 AQCRs.
(Not all AQCRs are required to have Ov/0z monitors.) The 1-hour standard
/\
was achieved by 70 of those stations (20 percent) representing 76 AQCRs.
Nitrogen dioxide (NOp) measurement methods are still being reviewed for
the purpose of redesignating a Federal reference method. Valid annual data
for NOp were reported from 582 stations using methods that are deemed candi-
dates for the status of reference or equivalent methods. These stations
are located in 101 AQCRs. Only 18 stations in four AQCRs exceeded the
currently defined annual standard for N0_.
Although data reporting is improving, some difficulties persist in
acquiring or reporting a full year's data for many monitoring stations. This
situation continues to handicap the evaluation of the nation's air quality.
From the preceding paragraphs it can be deduced that of the 3788 TSP moni-
toring stations and 2241 SO monitoring stations reporting minimal data in
1974, only 53 percent and 46 percent, respectively, reported data sufficiently
complete to permit calculating a valid annual mean. This not only means that
the annual standards for these pollutants can only be evaluated at about half
the existing stations, but also that the incidence of 24-hour standard viola-
tions is inconclusive wherever the data record is incomplete. Thus, expediting
the flow of data from the state and local monitoring agencies to EPA's national
data bank is being given increased emphasis.
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TRENDS IN AIR QUALITY, 1970-1974
Historical trends in air quality levels afford a convenient guide to
determining progress in the control of air pollution. For some pollutants,
lack of historical data on a national basis limits the inferences that may
be made. However, the recent expansion of air pollution monitoring networks
is providing data that will serve as a baseline for future trend assessment.
Currently, a good historical data base on the national level is available
for total suspended particulate and sulfur dioxide primarily in urbanized
areas. For oxidant, carbon monoxide, and nitrogen dioxide, historical data
are limited and the geographical distribution is very sparse. Therefore,
trends for these three pollutants are considered as a series of special
cases. The present status of historical data reflects the evolution of air
pollution monitoring efforts. For the most part, initial efforts were con-
centrated on the assessment of total suspended particulate and sulfur
dioxide in center city areas.
Based on composite averages from 1096 sites, TSP levels have improved
from 1970 to 1974. During this period, the composite annual average declined
from 80 to 66 jug/m . This is an overall decrease of 17 percent, or slightly
less than 5 percent per year. This improvement was generally reflected
throughout the nation but specific localities are still experiencing TSP
levels in excess of the National Ambient Air Quality Standards. The princi-
pal control problems are fugitive dust and urban background. During this
period, the estimated reduction in particulate emissions was 29 percent.
Sulfur dioxide levels have declined from an annual composite average
of 38 jjg/m in 1970 to 26 jjg/m3 in 1974. These averages are based on data
from 258 sites and represent an overall decrease of 32 percent, or approxi-
mately 9 percent per year. However, over 90 percent of these sites are
117
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located in urbanized areas and caution must be used in generalizing these
results. During this period, the decrease in estimated emissions was 8 per-
cent. The much greater reduction in ambient S02 levels may reflect the
shift in S02 emissions away from center city areas. Thus, the overall
decline in S02 levels may be the combined result of emission reductions and
redistribution of emission patterns. The data for 1975 are expected to show
some additional decline in S02 in response to the mid-1975 compliance
deadline.
Carbon monoxide trends in the few cities having historical data suggest
general improvement. This is consistent with the automobile emission reduc-
tions during this period. Data from the States of California, New Jersey,
New York, and Washington show reductions in the percent of time the 8-hour
CO standard is exceeded. The peak hourly values have been relatively stable,
but in the majority of urban areas the 8-hour standard is the more serious
problem and this is where improvement is being shown. Los Angeles and New
Jersey monitoring data indicate that the percent of time the 8-hour CO
standard was exceeded was reduced by approximately 50 percent from 1970-1971
to 1973-1974 (roughly 12 percent to 6 percent). The State of Washington
showed consistent progress during the 1971-1973 period.and New York State
and San Francisco data showed that less than 0.5 percent of the 8-hour values
were above the standard. On a national basis, the number of CO monitoring
sites increased consistently during 1970-1974, with more than a 400 percent
increase in 1974 over 1970 and a 25 percent increase in 1974 over 1973.
Oxidant trends in California continue to show long-term improvement.
Data in the Los Angeles and San Francisco areas show 20 to 50 percent
decreases in the number of times the 1-hour oxidant standard was exceeded.
However, an important characteristic of the oxidant problem is the recognition
118
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of the wide spatial distribution of high oxidant levels. Recent studies have
focused attention on oxidant as an area-wide phenomenon extending even to
rural areas. The number of oxidant or ozone monitors has increased nationally
by almost 600 percent between 1970 and 1974 with a 30 percent increase
in 1974 over 1973. As these sites continue to report data, it will become
possible to examine oxidant trends on a much broader basis.
Measurements of oxidants at rural stations from Ohio into Maryland and
Pennsylvania through the summer of 1974 have confirmed earlier reports of
high oxidant concentrations remote from urban areas. The history of air
masses, plus the presence of distinctive man-made pollutants in the air
masses, strongly suggests that the observed oxidant concentrations are the
product of man-made ingredients received by the air masses in passing over
an urban area. These ingredients continue to react, forming photochemical
oxidants, as the air masses move across the countryside.
Nitroqen oxide emissions have increased nationally since 1970 and
upward trends in N02 have been seen in Los Angeles and Philadelphia. Because
of recent changes in measurement methodology for monitoring nitrogen dioxide,
very few areas have sufficient historical data to assess N02 trends during
the 1970-1974 period. However, between 1973 and 1974, the number of stations
reporting a complete year of acceptable N0? data increased by almost 800
percent so that future reports should be able to more accurately assess
national trends in N02 levels.
Nationwide estimates of pollutant emissions from 1970 through 1974 show
steady declines in the tonnages of particulates and carbon monoxide being
dumped into our air. Emissions of sulfur oxides and hydrocarbons evidence
only slight declines. Nitrogen oxides show a slight increase in total
emissions.
119
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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 should be made
and, if so, the nature of the emission control equipment that may be
required. EPA is requiring the owners or operators of those facilities that
are granted compliance extensions to install sulfur dioxide monitors (and,
in some cases, monitors for TSP and sulfates) around such facilities and
to report the resulting data to EPA. These data will supplement the state
and local monitoring network data in EPA's evaluations of compliance, pro-
gress toward compliance, and potential deterioration of air quality.
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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 essen-
tial to EPA's abatement and control program. Initially, methods are needed
to determine the extent and causes of a pollution problem and to investigate
the health and welfare effects of the pollutants. When standards are pro-
mulgated, 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 separation of particulate matter into fine and coarse frac-
tions and a measurement of specific chemical entities, such as sulfates,
which are found in the fine particle fraction. Also, research is being car-
ried out to provide measurement technology for specific toxic materials,
such as vinyl chloride, nitrosamines, and aerocarcinogens, that are present
in the air near sources of these materials. For source emissions, the major
problem is that of the proper interfacing of instruments with the source to
allow representative samples to reach the instrument. There is also the
time-consuming and expensive problem of evaluation of all relevant sources
121
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because interfering substances and conditions vary from source to source.
Source emission measurement technology has advanced for many types of
sources, but for other sources it is still in a developmental stage.
MONITORING DEVELOPMENTS
Source Emission Measurement
Researchers made further advances in the technology of source emission
measurement during 1975. Research activities concerning analytical tech-
niques for use in implementing stationary source emission standards included:
(1) developing monitors for S02 (including in situ, extractive, and remote
methods) and sulfuric acid mist; and (2) evaluating previously developed in
situ and remote S02 monitors, two methods for measuring ammonia emissions,
and the use of a transmissometer as a particle mass monitor for several
source categories including coal-fired power plants. Other significant
advances included developing a prototype transpiration probe for quantita-
tive sampling and preconditioning of particle emissions; establishing the
feasibility of a portable lidar instrument for remote measurement of plume
opacity; demonstrating the use of a new x-ray diffraction method as a rapid
screening technique for asbestos analysis; and designing and constructing
a compact x-ray analyzer for on-site monitoring of emissions of potentially
hazardous trace elements.
Mobile source emission measurement research resulted in the development
of a colorimetric procedure to measure sulfate emissions from automobiles
and the automation of the procedure for routine use in testing 1975 produc-
tion vehicles. The procedure will be used to implement a forthcoming sul-
fate emission standard. Other research efforts deomonstrated that an infrared
spectrometer based on the gas filter correlation principle could be used
122
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effectively for analyzing several gaseous pollutants (e.g., formaldehyde,
methane, CO, and CO.) in automotive exhausts.
Ambient Air Measurement
Several important developments occurred during 1975 concerning instru-
ments and techniques to measure ambient air pollutants. Researchers devel-
oped and field-tested a dichotomous sampler for particulate matter. Sampler
operates on automatically programmed sampling periods of a few hours, and
segregates the collected particles into two size ranges--respirable and
non-respirable. It also rejects very large particles, thus eliminating
the undue influence they exert on mass values. The dichotomous sampler
overcomes the major shortomings of high-volume samplers, namely, the
inability to sample meaningfully for periods of less than 24 hours and to
discriminate fine particles.
Two unique instruments have been developed and are presently in the
field-testing stage. One is an instrument to measure vinyl chloride.
The instrument uses a detector operating on chemiluminescence principles
in combination with an automated gas chromatograph possessing the required
specificity and sensitivity for vinyl chloride. The other instrument is a
device to measure low levels of airborne sulfuric acid mist. The device
captures droplets of mist on an inert filter, then conveys the collected
acid to a sensitive sulfur-specific detector. It is capable of sampling
and analyzing cyclically every hour.
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,
123
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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) publica-
tion of procedures and guidelines, 4) evaluation of on-going monitoring
activities, and 5) training and technical assistance.
Standard measurement methods have been established for all of the
regulated ambient air pollutants except N02, and testing of systems required
for measuring source emissions has progressed on schedule. Respositories
of standard reference materials have been established. A number of quality
control guidelines manuals are now available for air measurement. Training
in the use of quality control guidelines and calibration standards is pro-
ceeding on schedule. Inter-laboratory performance testing programs have
been initiated for air pollutant measurements. On-site evaluations of all
EPA monitoring laboratories were initiated in April 1974, and 10 Regional
laboratories have been evaluated. Procedures are being developed to
evaluate any field monitoring laboratory, and the feasibility of a certi-
fication system for environmental monitoring laboratories is under study.
124
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IX. DEVELOPMENT OF NEW AND IMPROVED AIR POLLUTION
CONTROL TECHNIQUES FOR STATIONARY SOURCES
The development and demonstration of control technology for stationary
source air pollution is one of EPA's largest tasks. Approximately $58
million was devoted to this effort in Fiscal Year 1975. These funds sup-
ported both on-going studies to demonstrate control methods for sulfur and
nitrogen oxides, particulates and other pollutants, and expanded programs
addressing the environmental aspects of accelerated energy resource develop-
ment in the United States.
EPA's goal in stationary source air pollution control development is
fourfold:
• To describe at least one method for control of each
major source of pollution;
• To provide a technical base for the Agency's enforcement
activities;
• To establish technical and economic data to support New
Source Performance Standards (NSPS); and
• To provide information required to make environmentally
sound decisions on energy development policy.
125
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SULFUR OXIDES
Much of the Agency's research and development effort in sulfur dioxide
(S02) control has been directed toward the demonstration of flue gas desul-
furization (FGD) technology. This emphasis has been dictated by FGD's
economic feasibility and by its availability for near-term application as
compared to other S02 control options. EPA has funded, either totally or
partially, a number of major projects over the past several years. Included
in these projects are the following large-scale, electric utility-oriented
projects:
• Pilot work (at Research Triangle Park, N. C.) and
prototype systems (at the TVA Shawnee Steam Plant)
for development, demonstration and optimization of
lime and limestone scrubbing technology.
t Magnesium oxide scrubbing demonstrations at Boston
Edison Company and Potomac Electric Power Company.
0 Catalytic-oxidation scrubber demonstration at Illinois
Power Company.
0 Sodium sulfite/bisulfate scrubbing (Wellman-Lord
Process) at Northern Indiana Public Service Company.
Control techniques suited for smaller industrial and commercial combus-
tion sources are being examined through full-scale test programs at a General
Motors Double Alkali installation and a U.S. Air Force installation using the
Bahco lime scrubbing process.
The major demonstration projects are supported and supplemented by
other full-scale testing, numerous engineering studies and smaller-scale
hardware projects. The commercial economics of FGD by-product marketing
and disposal options, and the evaluation of new processes and process
126
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improvements are the subjects of continuing engineering efforts. A major
effort underway in technology transfer will promote use of the best and
most reliable techniques and equipment for future FGD installations.
A second method of reducing sulfur oxide (SOX) emissions is to remove
sulfur and other contaminants from the fuel prior to combustion. This pre-
treatment method of control is appropriate to SOV sources smaller than
f\
electric utility size, e.g., boilers and fuel-burning equipment. EPA is
supporting programs for research, development and environmental assessment
of several approaches for removing pollutants from fuels. One technique--
coal cleaning—involves methods of physically and/or chemically cleaning
coal of moderate sulfur content so that it can be burned in conformance with
clean air standards. EPA's objectives in this area are to develop commer-
cially available processes for removing inorganic sulfur and ash from medium-
sulfur coal, while rendering the coal-cleaning wastes suitable for reclama-
tion or disposal in an environmentally acceptable manner. Another EPA
program area involves clean synthetic fuels (high- and low-Btu gasified coal
and liquefied coal). The major objectives are to determine the potential
environmental impacts of synthetic fuel processing, and to develop control
technology to minimize the negative effects of these environmental impacts.
A third method for controlling SO involves modification of the combus-
A
tion process. Fluidized bed combustion (FBC) is the primary approach under
consideration. As part of the National Fluidized Bed Combustion Program
coordinated by the Energy Research and Development Agency (ERDA), EPA is con-
ducting research to determine potential environmental problems arising from
alternative designs and uses of fluidized bed combustors. EPA's participa-
tion in the interagency program consists of conducting environmental assess-
ments of FBC systems; optimizing control of S02, NOX, fine particulates and
127
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other pollutants; and continued testing of EPA's small (0.63 megawatt)
FBC mini-pilot plant.
In addition to combustion sources, industrial processes make a signif-
icant contribution to the ambient SOV problem. An effort is underway to
/\
evaluate and demonstrate SOV control by a commercial molecular sieve process
A
(PuraSiv S) on tail gases from sulfuric acid production. The evaluation
shows that the molecular sieve process is capable of limiting the SOX con-
centration to 100 parts per million (ppm) in tail gases for most sulfuric
acid plants. Work has also been initiated to identify alternative technol-
ogies for reducing petroleum refinery SO emissions to 80-90 percent below
/\
1974 levels.
NITROGEN OXIDES (NOJ
A
Combustion modification is the primary existing control technique for
preventing or minimizing N0y emissions from fossil-fuel burning. EPA-
supported and directed efforts have shown that recirculating flue gas is a
most effective technique for controlling NOX emissions originating from
thermal fixation of atmospheric nitrogen during the combustion of clean
fuels (natural gas and distillate oils). Staged combustion (often combined
with low excess air) is a most effective method for controlling NOV emis-
A
sions derived both from the thermal fixation of nitrogen emissions in the
combustion air and from the conversion of nitrogen atoms chemically bound
in the fuel (heavy oils and coal). Additional EPA research and development
efforts are aimed at redesigning burner/combustor systems, investigating
novel combustion modification approaches (such as catalytic combustion,
advanced power cycles, and alternative fuels) for emission reduction, and
providing a basic understanding of the physical and chemical factors
128
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influencing the formation and degradation of pollutants through fundamental
combustion research.
NOX flue gas treatment (FGT) is a relatively new control technique
under investigation for its potential in accomplishing high-efficiency con-
trol of large stationary sources. A program eventually leading to a demon-
stration of the technique on large coal-fired sources is in direct response
to increasing evidence that high-level control may be required to meet
future NO standards.
X
Finally, in the industrial area, EPA is currently supporting a project
to evaluate and demonstrate NO control by a commercial molecular sieve pro-
^
cess (PuraSiv N) on tail gases from nitric acid plants. The evaluation
demonstrates that the molecular sieve process is capable of economically
limiting NO concentrations to at least 100 ppm, and quite possibly to 50
X
ppm, on tail gases from absorbers in nitric acid production.
PARTICULATES
Control technology for large particulates has been fairly well estab-
lished, and EPA's efforts now are mainly concerned with development of
techniques for the control of fine particulates (defined as that fraction
of the particulate emission smaller than 3 microns). These small particles
remain suspended in the atmosphere and>are easily respirable and absorbable
by the body. Fine particulates may contain toxic trace metals and sulfates,
i)0th of which have considerable impact on health. One current program seeks
to better define the physical and chemical character of fine particulates.
Control technology for fine particulates is still seriously deficient. The
Agency's present efforts center on developing adequate detection and measure-
ment methods and on development and field testing of control methods. Addi-
129
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tionally, EPA is working to improve and demonstrate existing collection
capability for fine particulate control and to identify and ultimately to
demonstrate novel techniques which will offer both economic and performance
advantages over current methods.
OTHER POLLUTANTS
"Other" pollutants are both those pollutants for which no ambient air
quality standards have been established and those three pollutants (asbestos,
mercury, and beryllium) for which National Emissions Standards for Hazardous
Air Pollutants (NESHAPs) now exist. Control technology research efforts are
underway for a number of these pollutants, including trace metals, polycyclic
organic matter (POM) and miscellaneous hydrocarbons, fluorides, and odors.
To assess the emission of these pollutants, several tasks are being
funded for the field testing of 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
un i ts.
Source assessment has also been started for certain chemical processing
industries. The objective of this program is to assess the environmental
impact of sources of toxic and potentially hazardous emissions from the
organic materials, inorganic materials, combustion and open source categories
and to determine the need for control technology development for given source
types. Sources under assessment include petroleum refining, acrylonitrile,
asphalt paving, solvent evaporation operations, rubber and plastic processing,
phthalic anhydride, polyvinyl chloride, glass manufacturing, barium chemi-
cals, fertilizer mixing plants, brick kilns, lead storage batteries, and
ammonium nitrate.
130
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Control technology for the ferrous metallurgical industries is under
extensive development. Included in this area are emissions from cokemaking,
sintering, iron-making in the blast furnace, and steel-making in the basic
oxygen furnace. Additional programs are underway to assess and characterize
fugitive emissions from integrated iron and steel plants and from the mining,
beneficiation and pelletization of iron ores.
Efforts are underway to establish control techniques both for open
sources and for selected closed sources of asbestos. The key sources include
mining, milling, and manufacturing sites; the latter source tends to be
^
located predominantly in urban areas and thus substantially increases human
exposures to asbestos. The objectives here are to develop and demonstrate
control technology for handling, unloading, and disposal operations and,
in addition, to demonstrate a specific methodology for controlling closed
sources of asbestos in manufacturing operations. Completed programs include
a study to identify the sources of asbestos in the mining industry and a
project to identify the optimum operating mode for maximum efficiency of
baghouses for control of asbestos fibers. This work is undertaken to
permit quantification of the existing NESHAPs for asbestos, thus allowing
control effectiveness of the standard to be evaluated.
EPA is continuing development at the pilot plant level for the following
sources: glass manufacturing plants, asphalt roofing plants, ethylene
dichloride plants, coating operations for metal cans, hydrocarbon control
for gasoline distribution systems, and odor control for the rendering industry
131
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X. STATUS OF STATE, INTERSTATE, AND LOCAL
POLLUTION CONTROL PROGRAMS ESTABLISHED
UNDER AND ASSISTED BY THIS ACT
A primary role of the EPA and the EPA Regional Offices has been to
continue to improve the partnership between the Federal Government and the
state and local control programs responsible for administering the provi-
sions of the Clean Air Act. The Clean Air Act of 1970, as amended, in re-
quiring State Implementation Plans places emphasis on the responsibility-
sharing between the Federal, state, and local government units to achieve
effective control programs. In 1975, 55 state and territorial agencies
and 236 local agencies, working in coordination with states, expended
approximately $148 million and 7000 man-years to carry out the major por-
tions of the regulatory and enforcement aspects of the national air pollution
control effort.
In meeting the obligations imposed by the Clean Air Act, many state
agencies have continued to rely heavily on local expertise and resources.
Historically, Federal support has been used to stimulate local agency growth
and to encourage a regional or statewide approach to air pollution control.
Tables X-l and X-2 illustrate the extent of this Federal support to state
and local agencies by organizational location of the agency within the state
and local governmental structures and by jurisdictional areas served by
these agencies.
132
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Table Xrl. ORGANIZATIONAL LOCATION OF
STATE AND LOCAL CONTROL AGENCIES RECEIVING FEDERAL FUNDS
IN 1975
Principal
organization
type
Environmental
Health
Air pollution
Natural resources
Other
Total
State
Total
22
18
6
7
2
55
Number receiving
Federal funds
22
17
6
7
2
54
Local
Total
21
114
88
13
236
Number receiving
Federal funds
Direct
12
68
38
10
128
Indirect*3
1
19
14
34
aThrough specified provisions in grants to states
133
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Table X-2. DISTRIBUTION OF FUNDS BY JURISDICTION AREAS OF
STATE AND LOCAL CONTROL AGENCIES3
(ESTIMATED 1975 EXPENDITURES)
Jurisdictional
category
Local
Cities
Counties
Multi -county
Subtotal local
State0
Subtotal state
Total
Number of
agencies
44
91
27
162
54
216
Federal $
$ 5,900,000
10,400,000
3,100,000
19,400,000
33,200,000
$52,600,000
State/local $
$14,300,000
24,000,000
9,300,000
47,600,000
47,800,000
$95,400,000
Total
$ 20,200,000
34,400,000
12,400,000
67,000,000
81,000,000
$148,000,000
Total number of agencies receiving Federal monies for air pollution control
work either directly or by designation in grant to state agency. Direct
grants approximate 182 for 1975.
blncludes agencies that are combination city-county agencies, county agencies
that service large metropolitan areas, and city agencies serving more than
one county. Many county agencies cover a large metropolitan area; for
example, Los Angeles County, California; Wayne County, Michigan (Detroit);
Allegheny County, Pennsylvania (Pittsburgh).
cStates include District of Columbia, Puerto Rico, Virgin Islands and Guam.
American Samoa did not receive grant funds in 1975.
134
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FEDERAL FINANCIAL ASSISTANCE TO AIR POLLUTION CONTROL AGENCIES
In 1975 EPA provided financial assistance to 54 state agencies (all
except American Samoa) and 128 local agencies. In addition, 34 local
agencies received Federal monies through specified provisions of state
grants. The total expenditures of these 216 agencies represented approxi-
mately 96 percent of all expenditures for the 291 agencies having some air
pollution control responsibilities. The support provided to the agencies
was in the form of grants for planning, developing, establishing, improving
or maintaining control programs. This support also included special con-
tractual assistance and demonstration grants to assist the agencies in
meeting deadlines imposed for the submittal, revision, and preparation of
their implementation plans and for technical aspects of the enforcement and
revisions associated with the regulatory and monitoring provisions of the
local control strategies. The Federal support provided to states for Fiscal
Years 1972, 1973, 1974, 1975, and 1976 (estimated) is summarized in
Table X-3.
PROGRESS OF STATE AND LOCAL AIR POLLUTION CONTROL PROGRAMS
Total expenditures (Federal, state, local) for the support of air pol-
lution have grown at an average annual rate of approximately 28 percent,
from $13 million in Fiscal Year 1965 (FY 65) to an estimated $148 million
in FY 74. The growth rate in FY 75 was approximately 14 percent over the
FY 74 level.
The increase in the number of employees of state and local control
agencies is an indicator of the nation's growing commitment to controlling
air pollution. Table .X-4 shows that control agency staff has tripled in
135
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Table X-3. SUMMARY OF FEDERAL SUPPORT3 TO STATE AND LOCAL
AIR POLLUTION CONTROL AGENCIES BY STATE
State or territory
Alabama
Alaska
Arizona
FY 1972
$ 527,324
69,775
207,049
Arkansas 208,527
California
Colorado
3,690,260
900,784
Connecticut . 1,355,796
Delaware , 189
D. C. 225,000
Florida 885,741
Georgia 630,218
Hawaii 96,445
Idaho ! 81 ,687
1 1 1 i no i s
Indiana
2,423,520
826,034
FY 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
FY 1974
$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
FY 1975
Prel iminary
$1,286,686
162,623
590,408
355,716
4,205,275
625,374
1,671,935
327,500
340,000
949,491
757,031
131,749
227,051
3,172,853
1,073,245
FY 1976 .
Estimated
$1,000,000
190,000
640,000
365,000
4,230,000
700,000
1,300,000
300,000
220,000
1,400,000
800,000
150,000
265,000
3,400,000
1 ,250,000
oo
CT)
-------
Table X-3 (continued). SUMMARY OF FEDERAL SUPPORT3 TO STATE AND LOCAL
AIR POLLUTION CONTROL AGENCIES BY STATE
State or territory
Iowa
Kansas
Kentucky
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire
FY 1972
$ 559,243
335,761
159,028
175,000
-0-
987,000
794,385
1,613,510
365,669
421,724
717,574
231,460
231,929
245,702
185,409
FY 1973
$ 645,258
596,319
1,115,903
349,959
245,349
1,206,184
1,247,799
1,999,772
661,174
269,852
1 ,145,850
265,000
247,116
247,956
227,609
FY 1973
$ 579,780
476,293
953,267
807,200
106,000
1 ,365,901
1,116,982
1,999,424
674,098
392,875
1 ,090,698
326,000
408,642
293,311
172,546
FY 1975
Preliminary
$ 523,822
486,173
883,103
377,021
174,981
1,754,624
1 ,215,434
2,030,848
462,330
384,000
1,143,366
341,936
334,790
268,789
174,324
FY 1976 ,
Estimated
$ 675,000
575,000
900,000
500,000
200,000
1,300,000
1,200,000
2,100,000
1 ,250,000
450,000
1,120,000
400,000
385,000
290,000
200,000
OJ
-------
Table X-3 (continued). SUMMARY OF FEDERAL SUPPORT3 TO STATE AND LOCAL
AIR POLLUTION CONTROL AGENCIES BY STATE
State or territory
New Jersey
New Mexico
New York
North Carolina
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
FY 1972
$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
-0-
FY 1973
$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
FY 1973
$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
FY 1975
Preliminary
$2,314,964
510,500
4,926,479
1,403,056
84,000
2,581,495
520,437
651,296
3,026,440
202,026
567,364
113,826
1,135,232
2,600,908
153,780
FY 1976 .
Estimated
$2,550,000
590,000
4,750,000
1,750,000
100,000
2,600,000
590,000
720,000
3,195,000
235,000
600,000
80 ,000
1,150,000
3,000,000
250,000
to
co
-------
Table X-3 (continued). SUMMARY OF FEDERAL SUPPORT3 TO STATE AND LOCAL
AIR POLLUTION CONTROL AGENCIES BY STATE
State or territory
Vermont
Virginia
Washington
West Virginia
Wisconsin
Wyoming
American Samoa
Guam
Puerto Rico
Virgin Islands
Subtotal
Special support0
Multi regional
projects
Total
FY 1972
$ 224,426
1,062,000
1,129,910
317,620
965,448
68,133
-0-
54,774
464,417
100,043
$40,317,581
$40,317,581
FY 1973
$ 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
FY 1974
150,000
991,381
1,083,400
700,470
824,170
100,000
-fl-
ee, 150
226,124
77,735
$49,289,060
2,915,999
$52,205,059
FY 1975
Preliminary
164,640
1,268,129
1,165,274
840,000
966,191
100,000
-0-
70,000
399,667
79,000
$52,277,182
340,043
$52,617,225
FY 1976 b
Estimated
230,000
1,260,000
1,100,000
450,000
1,050,000
120,000
-0-
70,000
350,000
50,000
$54,595,000
673,000.
$55*268,000
u>
-------
Table X-3 (continued). SUMMARY OF FEDERAL SUPPORT TO STATE AND LOCAL
AIR POLLUTION CONTROL AGENCIES BY STATE
o
State or territory
Federal fiscal
year budget
FY 1972
FY 1973
$50,804,800
FY 1974
$51,518,000
FY 1975
Preliminary
$52,693,000
FY 1976 ,
Estimated
$55,268,000
aFederal support amounts are related to Federal fiscal year and include grants, State Assignees,
and special assistance (contracts, demonstration grants). For most states, dollars do not relate
to budgets for the state's fiscal year.
"Estimated amounts for FY 76 include grants, State Assignee, and special assistance monies
(contractor assistance and demonstration grants). These amounts are for planning purposes
only and each state's final amount will differ and will be provided the individual state by
the EPA Regional Office.
cSpecial support monies shown for FYs 75 and 76 are multiregional/contractor and demonstration
grant assistance benefitting several states. The majority of special support monies for FYs 75
and 76 (approximately $2.8 million) are shown within the appropriate state's total. In FY 72
special support funds were not considered as being part of control agency support funds.
-------
Table X-4. ESTIMATED MAN-YEARS OF EFFORT EMPLOYED BY
STATE AND LOCAL AIR POLLUTION CONTROL AGENCIES3
Fiscal
year
1969
1971
1973
1974
1975C
State
Positions
1000
1540
2930
3970
4360
nan-
years
920b
1420b
2770
3490
3800
Local
Positions
1840
2630
3270
3270
3680
Man-
years
1660b
2370b
2870
3000
3200
Total state/local
Positions
2840b
4170b
6200
7240
8040
Man-
years
2580
3790
5640
6490
7000
All figures involve estimating full- and part-time positions either from
manpower surveys or budgets provided in grant awards.
""Estimated from position information using verified man-year/position ratios
from 1973 and 1974.
'1975 estimates based on preliminary information.
141
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the last six years. The 1975 on-board positions represent approximately
7000 equivalent full-time man-years of effort.
Resources increased by approximately 500 man-years and $18 million
between June 1974 and July 1975. These increases were approximately the
same as the previous year's. Resources improved principally because state
and local funds increased approximately 20 percent ($17 million) over FY 74
levels. Federal support to these agencies increased by approximately 2
percent ($1.6 million).
The focus of Federal support to state and local control agencies has
been on the achievement of State Implementation Plans and national priori-
ties. In FY 75 the agencies gave highest priority to the enforcement
actions necessary for attaining total suspended particulate and sulfur
dioxide National Ambient Air Quality Standards and improvements to
monitoring networks required for continual assessment of pollutant concen-
trations. The estimated percentage of resources committed to various
aspects of these national efforts to attain standards is shown in
Table X-5.
142
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Table X-5. ESTIMATED PERCENTAGE OF RESOURCES DEVOTED TO
AIR POLLUTION CONTROL ACTIVITIES OF NATIONAL PRIORITY
BY STATE AND LOCAL CONTROL AGENCIES IN FY 75
Activity
Estimated percentage
of resources
Compliance with State Implementation Plan
regulations
State Implementation Plan revisions and
completion
Transportation Control Plans and mobile
source inspection and investigation
Air monitoring network operation and
completion
Supportive tasks (management, data and
policy review, environmental impact
statements, training, etc.)
44
6
7
18
25
100
143
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XI. REPORTS AND RECOMMENDATIONS OF THE
PRESIDENT'S AIR QUALITY ADVISORY BOARD
The President's Air Quality Advisory Board was abolished on
January 5, 1975, under the provisions of the Public Advisory Committee
Act of 1972 and therefore there are no reports or recommendations to
report.
144
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APPENDIX. SUMMARY OF EPA ENFORCEMENT ACTIONS
SECTION 110 - STATE IMPLEMENTATION PLANS
JULY - DECEMBER 31, 1975
STATE/CITY
Alabama,
Birmingham
Alabama,
Denopolis
Alabama,
Parish
Alabama,
Wilsonville
Alabama,
Bucks
Alabama,
Gadsden
Alabama,
Bridgeport
Alabama,
Eufaula
Alabama,
Scottsboro
COMPANY/TYPE
OF SOURCE
U.S. Gypsum
Alabama Power Co.
Power Plant
Alabama Power Co.-Gorgas
Power Plant
Alabama Power Co.-B.C. Gaston
Power Plant
Alabama Power Co.-Barry
Power Plant
Alabama Power Co.-Gadsden
Power Plant
Tennessee Alloys/ferro-Alloys Corp.
Power Plant
A.P. Green Refineries
Bauxite Mining
Revere Copper £ Brass, Inc.
Primary aluminum plant
POLLUTION PROBLEM
Particulate matter
Particulate
Particualte
Particulate
Particulate
Particulate
Particulate
Particulate
Particulate
TYPE OF ACTION
Consent order issued
8/9/75
NOV 11/5/75
NOV 11/5/75
NOV 11/5/75
NOV 11/5/75
NOV 11/5/75
NOV 11/21/75
NOV 12/8/75
NOV 1/12/75
NOV = Notice of violation.
-------
STAIF/CITY
2
Alabama,
Sheffield
Alabama,
Alexander
City
Alabama,
Holt
Alabama,
Talladega
Alabama,
Sheffield
Alabama,
Axis
-
cr> Alabama,
Woodward
Alabama,
Fairfield
Alabama,
Tarrant
Alabama,
Bessemer
Alabama,
Leeds
Alabama,
COMPANY/TYPE
CF SOURCE
Reynolds Metals Co.
Listerhill Reduction Plant
Primary Aluminum Plant
Russell Corp./Textile Mill
Industrial boilers
The Central Foundry
Gray Ircn Foundry
Newbury Mfg. Co.
Grey Ircn Foundry
Martin Industries
Gray Iron Foundry
Stauffer Chemical Co.
Sulfuric Acid Plant
Alabama Alloy, Inc.
ferro-alloy furnace
W.J. Bullock, Inc.
Non-ferros secondary smelting
(zinc, aluminum, etc.)
Clew Corp.
Gray Ircn Foundry (Pipes)
Jones Foundry Co.
Gray Ircn Fcundry
Universal Atlas Cement, Div.
U.s.s.c./Portland cement Plant
AMOCO Chemicals Corp./Chem. Plant
POLLUTION PROBLEM
Participate
Particulate
Particulate
Particulate
Particulate
S02
Particulate
Particulate
Particulate
Particulate
Particulate
Particulate
TYPE OF ACTION
NOV 12/8/75
NOV 11/21/75
NOV 11/21/75
NOV 11/21/75
NOV 11/21/75
NOV 11/21/75
NOV 12/17/75
NOV 12/17/75
NOV 12/17/75
NOV 12/17/75
NOV 12/17/75
NOV 12/17/75
-------
STATE/CITY
3
COMPANY/IYPE
OF SOURCE
Decater
Alabama,
Ragland
Alabama,
Eufanla
Alabama,
Mobile
Alaska
Ketchinken
Arizona
Kingman
Aurora
Industrial incinerators
National Cement Co.
Portland cement plant
Harbison-Walker Refractories
Refract, bricks
International Paper Co,
Pulp e paper mill
Herring Bay Lumber Co.
Teepee burner
Duval Corp.
Mineral Park molybdenum
concentrate roaster
Arizona
Sahuarita
Arizona
Scottsdale
Arizona
Benson
Duval Sierrita Corp.
molybdenum concentrate roaster
Industrial Asphalt
hot mix plant
Apache Power Company
nitric acid plant
California
Crockett
California
Visalia
California
Fresno
California
California and Hawaii Sugar Co.
char dust collection stacks
Stauffer Chemical Co.
whey drier
Johns -Manville Sales Corp.
reverbatory furnace stack
Atlantic Richfield Co.
POLLUTION PROBLEM
TYPE OF ACTION
Participate
NOV 12/17/75
Particulate
NOV 12/17/75
Particulate
NOV 12/31/75
particulate matter
order 9/24/75
violation opacity,
particulate matter and
sulfur compounds
compounds emission
stds.
Violation of particulate
matter std
violation of NSPS
test procedure
violation opacity,
open burning, and NOx
emission stds.
violation opacity std.
Admin, order 8/12/75
Admin, order 8/11/75
Admin, order 10/23/75
modification of order
violation of particulate
matter std.
violation of visible
emission std
violation of sulfur
NOV 8/12/75
Admin, order 9/30/75
Admin, order 9/3/75
NOV 10/2/75
Admin, order 12/16/75
Admin, order 10/28/75
-------
STATE/CITY
COMPANY/TYPE
OF SOURCE
Carson
Watson Refinery
California
Long Beach
Edgington Oil Co.
oil storage tanks
California
Wilmington
California
Los Angeles
Connecticut,
Naugatuck
Connecticut,
_, Middletown
co
Connecticut,
Waterbury
Connecticut,
Croton
Connecticut,
Plainfield
Delaware
Wilmington
District or
Columbia
Florida,
Piney Poi^nt
Wilmington Liquid Bulk
Terminals, Inc.
oil storage tanks
City of Los Angeles Dept.
of Water and Power Haynes
steam plant and the Fuel
Cil Operations Marine Tank
Farm
Cil storage tanks
Oniroyal Chemical/Rubber
Reclaim Facility
Feldspar Corp.
Feldspar kiln
Waterbury Rolling Mills, Inc.
Metal casting facility
General Dynamics/solvent spray
operation
Pervel Industries
Casting ovens, rotary
process 6 screen printers
Delmarva P6L
utility boilers
GSA-West Heating plant/toilers
Borden Chemical
POLLUTION PROBLEM
TYPE OF ACTION
dioxide and particulate
matter std.
violation Federally
promulgated State new
source review regulation
violation of Federally
promulgated State new
source review regulation
violation of Federally
promulgated State new
source review regulation
NOV 11/21/75
NOV 12/12/75
NOV 12/30/75
Hydrocarbon mass
emi ssi on
Particulate mass
emission
Order 7/7/75
Amendment to Order 8/27/75
Order 8/27/75
Particulate mass
emission
order 8/20/75
Photochemical solvents
mass emission
Organic compounds
NOV 8/8/75
Amendment to 2/14/74
Order 12/30/75
NOV 11/17/75
particulate matter
mass emission
particulate mass
emission
SOX emissions
order 9/15/75
consent agreement 8/15/75
consent order issued
8/28/75
-------
STftTE/CITY
5
COMPANY/TYPE
OF SOURCE
Florida,
Tampa
Florida,
Bartow
Florida,
Pace
Florida,
S. Pierce
Florida,
Jacksonville
Florida,
Titusville
Florida.
Mulberry
Florida,
Tampa
Florida,
Ft. Lauderdale
Florida
Plant City
Georgia,
Jessup
Georgia,
Riceboro
Kaiser Agricultural Chemicals
C.F. Industries, Inc.
Air Products C Chem.
Nitric Acid Plants
Agrico Chemical Co.
Sulfuric Acid Plants
C.I. Capps Co.
Gray Iron Cupola
Orlando Utilities Commission
Power Plant
Royster Company
Sulfuric Acid Plant
Tampa Municipal Incinerator
Incincerator
City of Ft. Lauderdale
Incinerator
Eorden Chemical
Defluronation Plant
ITT Rayonier
3-power boilers
(back fired)
Interstate Paper
recovery boiler
POLLUTION PROBLP1
TYPE OF ACTION
NOx emissions
SOX emissions
NOV
SO?
Participate
Particulate
Consent order issued
9/8/75
Consent order issued
11/1U/75
NOV 12/11/75
NOV 12/11/75
NOV 12/11/75
NOV 12/11/75
SO?
Particulate
NOV 17/11/75
NOV 12/11/75
Particulate
Particulate
Particulate
Particulates'
NOV 12/11/75
NOV 12/11/75
NOV 12/10/75
NOV 12/10/75
-------
S"1A-IK/CITY
6
COMPANY/TYPE
CF SOURCE
POLLUTION PROBLEM
TYPE OF ACTION
Oi
O
Georgia,
St. Marys
Georgia,
Carrollton
Georgia,
Savannah
Georgia,
Sandersville
Guam
Agana
Hawaii
Wai pah u
Hawaii
Honolulu
Hawaii
Ewa
Hawaii
Wainaku
Idaho
Priest River
Idaho
McCall
Idaho
Gilman Paper
1-power boiler
(tack fired)
Southwire Copper
an ode furnace and
copper connector
National Gypsum
7 Kettles, rotary dryer
Thiele Kaolin
Spray dryer
Guam Power Authority
Cabras Station power plant
Oahu Sugar Co., Ltd.
bagasse and oil-fired toiler
Standard Oil Co. of California
(Western Operations, Inc.)
Hawaiian Refinery fluid Catalytic
Cracker Unit.
Hawaiian western Steel Ltd
electric arc furnace
Hilo Coast Processing Co.
bagasse and oil firde boilers
Mearitt Brothers
Lumber Co.
Wigwam turner
Boise Cascade
Wigwam burner
Pack River Co.
Participate
Participate
Participate
Particulate
NOV 12/10/75
NOV 12/10/75
NOV 12/10/75
NOV 12/10/75
violation NSPS for power Admin, order 9/15/75
Plant Civil complaint filed
1/21/76
Violation of particulate NOV 7/11/75
matter and V/E std Admin, order 12/23/75
violation of particulate NOV 8/25/75
matter std.
violation of sulfur Admin, order 10/30/75
emission std
violation of Federally Admin, order 12/18/75
promulgated compliance
schedule and visible
emission standards
V/E
V/E
V/E
consent order 8/7/75
NOV 9/11/75
order 9/15/75
-------
STATE/CITY
7
COMPANY/TYPE
CF SOURCE
Osburn
Idaho
Pocatello
Idaho
Dun
Idaho
Post Falls
Idaho
Twin Falls
Idaho
Kellogg
Illinois
Chicago
Illinois
Cahokia
Illinois
Stickney
Illinois
Sterling
Illinois
Mascoutah
Illinois
Chicago
Illinois
Pekin
Illinois
Peoria
Illinois
Springfield
Wigwam Burner
FMC Corporation
Ore crusher
J.R. Simplot Co.
Nitric Acid Plant
Louisiana Pacific
Wigwam burner
Protein Processors
Animal Feed Mfg.
Bunker Hill Co.
lead & zinc smelter
Abitibi Corporation
painting process
Union Electric Co./Cahokia
Plant - power plant
Incinerator, Inc.
incinerator
Northwestern Steel 6 Wire Co.
electric arc furnaces
City of Mascoutah
municipal power plant
Abitibi Corp.
painting process
Commonwealth Edison
Powerton station f5
CILCO
Cuck Creek Power Stn.
City water. Light C Power Dept.
City Generating Stn. (toilers)
Illinois
Commonwealth Edison
POLLUTION PROBLEM
TYPE OF ACTION
particulate matter
Failure to complete
NSPS Testing
particulate matter V/E NOV 10/28/75
NOV 12/2U/75
consent order 10/1/75
NOV 10/1/75
particulate matter
particulate matter
(fugitive emission)
hydrocarbon
SOx
particulate
particulate
particulate & SOx
hydrocarbon
SOx
NSPS for SOx
NSPS for SOx
SOx
NOV 10/29/75
order 9/22/75
NOV 8/1/75
consent order 8/15/75
consent order 10/3/75
consent order 10/6/75
NOV 10/20/75
Consent order 10/22/75
NOV 10/28/75
NOV 10/30/75
NOV 11/13/74
NOV 11/26/75
-------
en
ro
STATE/CITY
d
Chicago
(Pekin)
Illinois
Rochelle
.Illinois
Peoria
Illinois
East Peoria.
Morton.
Vansant
Indiana
Terre Haute
Indiana
East Chicago
Indiana
Richmond
Indiana
Crawfords-
ville
Indiana
Plainfield
(Mt. Carmel)
Indiana
East Chicago
Indiana
East Chicago
Iowa
Xiddletown
COMPANY/TYPE
OF .SOURCE
Powerton Gen. Stn. *6
City of Rochelle/Rochelle
Steam Plant - Coal fired boilers
Celotex
coal fired boilers
Caterpillar
Tractor
C.F. Industries
ammonium nitrate mfg.
Inland Steel/Indiana Harbor
Works
Johns-Mansville Corp. •
melting furnaces
Crawfordsville Electric
Light e Power Company
Public Service Co. of Indiana
Gibson Generating Stn.
Inland Steel Co.
EOF Shop
Inland Steel
coke batteries
Iowa Army Airmunicion
Plant (Eept. of Army)
POLLUTION PROBLEM
TYPE OF ACTION
Iowa Wilson 6 Co. Inc.
Cdear Rapids
Iowa
Gra-lron Foundry Corp.
particulate
particulate & SOx
SOx
particulate
particulate & V/E
particulate
particulate
NSPS for sox
partculate 6 V/E
particulate
particulate
particulate
particulate
NOV 12/10/75
MOV 12/22/75
NOV 10/7/75
consent order 8/4/75
consent order 9/12/75
consent order 10/22/75
NOV 10/28/75
NOV 11/19/75
NOV 12/12/75
NOV 12/22/75
Memorandum of
understanding (MOD)
11/3/75
order 10/14/75
order 8/21/75
-------
STATE/CITY
9
Marshalltown
Iowa
Clinton
Iowa
Cedar Rapids
Iowa
Keokuk
Iowa
Davenport
Iowa
Marion
Iowa
Des Moines
Iowa
Charles City
Cedar Rapids
Iowa
Newton
Iowa
Centerville
Iowa
Centerville
Iowa
Dutuque
Iowa
Salix
Iowa
Sioux City
Iowa
COMPANY/TYPE
OF SOURCE
Hawkeye Chemical Co.
Penick 6 Ford, Ltd.
Midwest Carbide Corp.
Kelsey-Hayes, French
C Hect Division
Central Iowa Power Cooperative
Mid-American Dairymen, Inc.
. - spray dryer
White Farm Equipment Co.
Cargill, Inc. Blast Plant
Newton Foundry Co.
The Carter- Waters Corp.
L. Benac C Sons, Inc.
Interstate Power Co.
Iowa Public Service Co.
(George Neal Station)
launderville Construction Co.
McKee Buttons
POLLUTION PROBLEM
V/E
particulate
particulate 6 V/E
particulate
particulate
particulate/process wt.
particulate/process wt.
V/E
particulate
particulate
particulate
particulate
particulate
particulate
particulate
particulate
TYPE OF ACTION
order 8/22/75
order 8/1U/75 - 8/1/75
order 8/18/75
order 8/15/75
order 7/29/75
order 7/29/75
amended 7/30/75
order 8/7/75
order 8/7/75
order 8/1/75
order 8/1/75
order 7/31/75
order 8/1/75
Revised order 8/5/75
draft order 12/10/75
issued 1/76
order 12/23/75
-------
STATE/CITY
10
Miscati
Iowa
Mason City
Iowa
Independence
Iowa
Waterloo
Iowa
Muscatine
Iowa
Arlington
Iowa
Des Monies
Iowa
Durant
Iowa
Superior
Iowa
ilaquoketa
Kansas
Lawrence
Kansas
Fort Scott
Kansas
Independence
Kansas
Riverton
COMPANY/TYPE
OF SOURCE
Farmers Grain Dealers Asso.
Wapsie Valley Creamery Inc.
Bath Packing Co.
Grain Processing Corp.
Associated Milk
Producers, Inc.
Inland Mills Company
Busselloy Foundry
Superior Cooperative
Elevator Company
Clinton Engines Corp.
Cooperative Farm
Chemicals Assoc.
Tower Metals Products
Universal Atlas Cement
Empire-District Elec. Co.
POLLUTION P]
participate
participate
parti cul ate
particulate
particulate
particulate
particulate
particulate
particulate
particulate
opacity
opacity
opacity
particulate
Kansas
Pittsburgh
Kentucky,
Gulf Oil Chemicals Co.
American Standard
particulate
particulate matter
TYPE OF ACTION
order 12/23/75
order 12/22/75
order 12/27/75
order 12/23/75
order 9/9/75
order 8/6/75
Revised order 11/17/75
order 8/1H/75
order 8/13/75
order 10/15/75
order 8/13/75
order 9/12/75
NOV 7/22/75
order 12/23/75
order 8/1/75
Consent order issued
-------
STATE/CITY
11
COMPANY/TYPE
OF SOUHCE
Louisville
Kentucky,
Louisville
Kentucky,
Louisville
Kentucky,
Louisville
Kentucky,
Louisville
Kentucky,
Louisville
Kentucky,
Louisville
Kentucky,
Louisville
en Kentucky,
Louisville
Kentucky,
Louisville
Kentucky,
Louisville
Kentucky,
Louisville
Louisiana
Bastrop
Louisiana
Cotton
Valley
Anderson Mood Products
B.F. Goodrich
Falls City Brewing Co.
Fawcett Printing Corp. ;
City of Louisville
International Harvester
Henry Vogt Machine co.
Louisville Gas 6 Electric Co.
(3 facilities)
Louisville Gas 6 Elec. Co.
Lan Run U, 5 6 6
General Electric Co.
Appliance Park
Louisville Gas £ Elec. Co.
Mill Creek Units 162
International Paper Co.
(Louisiana Mill)
wood pulping mill
Cotton Valley Solvents Co.
Truck loading facility
Louisiana
Commercial Solvents Co.,
POLLUTION PROBLEM
TYPE OF ACTION
Particulate matter
Participate matter
Particulate matter
Hydrocarbon emissions
Particulate natter
Hydrocarbon emissions
Particulate matter
3ulfur oxide emissions
11/5/75
S02
7/23/75
Consent order issued
8/29/75
Consent order issued
7/11/75
Consent order issued
8/29/75
Consent order i.ssued
8/29/75
Consent order issued
8/29/75
Consent order issued
1/23/75
Consent order issued
11/24/75
Consent order issued
NOV 9/29/75
Pt/Hc
NOV 12/9/75
S02
NOV 12/19/75
particulate, V/E
Order 12/12/75
Hydrocarbons
NOV 7/21/75
order 10/30/75
particulate
NOV 7/31/75
-------
STATE/CITY
12
COMPANY/TYPE
OF SOURCE
POLLUTION PROBLEM
TYPE OF ACTION
Sterlington
Louisiana
Shreveport
Louisiana
Belle Chasse
Louisiana
Burnside
Louisiana
Franklin
Louisiana
Holden
__, Louisiana
en Lake Charles
Louisiana
Belle Chasse
Louisiana
Shreveport
Louisiana
Baton Rouge
Louisiana
Joyce
Louisiana
Fisher
Louisiana
Bogalusa
Thermatomic Carbon, Co.
carbon black recovery dryers
Bird 6 son. Inc.
asphalt roofing process
Gulf Oil Co. - U.S.,
Alliance Refinery- sulfur
recovery unit incinerator
Crmet Corp.-
calcining kilns
Cities Services Oil Co.
Columbian Oiv.
landfill
U.S. Plywood Co., Division
of Champion International -
conical wood waste turner
Cities Services Oil Co.
(refinery) fluid catalytic cracking
unit regenerator-sulfuric acid
Chevron Chemical Co.
incinerators
Kroehler Mfg. Co.
wood waste boiler
Allied Chemical Corp.
Eaten Rouge Polyolefins Plant
Specialty Chemicals Division
Crown Zellerbach-Joyce Hood
Products Plant - wood waste boiler
Vancover Plywood Co.
Inc., softwood Lumber Div.
wood waste boiler
Crown Zellerbach Corp.
(Bogalusa Mill)
particulate,
fugitive dust
S02
particulate, process
wt.
particulate (open
burning)
particulate V/E
particulate, SO2
particulate, SO2
particulate V/E
hydrocarbons
particulate, V/E
particulate, V/E
particulate, V/E
Termination of NOV
12/10/75
NOV 7/31/75
Termination of NOV
12/3/75
NOV 8/29/75
NOV 8/29/75
NOV 8/29/75
NOV 9/5/75
NOV 9/26/75
NOV 9/30/75
NOV 9/30/75
NOV 11/19/75
NOV 11/21/75
order 7/9/75
order ll/a/75
-------
STATE/CITY
13
COMPANY/TYPE
OF SOURCE
POLLUTION PROBLEM
TYPE OF ACTION
Louisiana
Springhill
Louisiana
Bastrop
Louisiana
Larose
Louisiana
Florien
Louisiana
DeRider
Louisiana
, Roanoke
on
' Louisiana
Winnfield
Maine,
Winslow
Maine,
Jay
Maine,
Auburn
Maine,
Auburn
Maine,
wood pulping mill
International Paper Co.
(Springhill Mill}
wood pulping mill
International Paper Co.
(Eastrop Mill)
wood pulping mill
Lafourche Parish Police
Jury-solid waste dump
Vancouver Plywood Co.,
Inc., Florien Plywood
Plant - conical wood waste
turner 6 sander dust turner
International Paper Co., wood treating
plant - conical wood waste burner
Roanoke Rice Coop
incinerator
Winnfield Veneer Co.
conical wood waste turner
Scott Paper Co.
Sulfite pulp mill
International Paper Co.
Androscoggin Mill/kraft
Recovery boiler
Androscoggin Foundry/Grey
Iron cupola
G.A. Peterson Co.
Asphalt batching operation
Premoid Corp.
particulate, V/E
particulate, V/E
particulate (open
burning)
particulate V/E
particulate V/E
particulate V/E
particulate V/E
S02 mass emission
Particulate matter
mass emission
order 12/12/75
order 12/12/75
Termination of NOV
9/19/75
Termination of NOV
11/12/75
Termination of NOV
12/3/75
Termination of 'NOV
12/3/75
Termination of NOV
12/3/75
order
NOV 8/13/75
Order 11/5/75
Particulate matter mass Order 11/17/75
emission
Particulate matter NOV 12/15/75
mass emission & opacity
Particulate-mass
NOV 12/30/75
-------
STATE/CITY
14
COMPANY/TYPE
CF SOURCE
Lincoln
Maine.
Woodland
Maine,
Millinocket
Maine,
Rumford
Maryland
Baltimore
Maryland
Dickerson
Massachusetts,
Chelsea
Massachusetts,
Canton
Massachusetts,
Mattapan
Massachusetts,
Newton
Massachusetts,
Lowell
Ma s sa ch u se tts,
Danvers
Lime kiln
Georgia-Pacific Corp.
Woodland Div./boiler
Great Northern Paper Co.
Sludge incinerator 6 dryer
Oxford Paper Co.
Kraft Pulp Mill
J.J. Lacey Foundry
PEPCO-Dickerson Station
Texaco
Gas loading terndnal
Plymouth Rubber Co.
Stedfast Rubber Co.
Spray operation
City of Newton
Municipal incinerator
City of Lowell
Municipal Incinerator
GTE Sylvania
Spray paint operation
POLLUTION PROBLEM
TYPE OF ACTION
emission
Participate mass
emission
Particulate mass
emission
NOV 10/3/75
Order 12/16/75
NOV 9/5/75
Order 11/5/75
Particulate emissions NOV 7/7/75
particulate matter mass NOV 8/14/75
emission
particulate mass
emission
Organic material
installation of vapor
recovery system
Particulate V/E
Oraanic material
emission
order 11/14/75
Consent order 7/9/75
order 8/510/75
NOV 8/7/75
Particulate mass
emission
7/21/75
Order 8/29/75
Particulate mass
emission
Organic material
mass emission.
irrler 7/28/75
NOV 6/26/75
Order 9/8/75
-------
STATE/CITY
15
COMPANY/TYPE
OF SOURCE
Massachusetts,
Lynn
Massachusetts,
Framingham
Massachusetts,
Lawrence
Massachusetts,
Winchester
Massachusetts
Quincy
Massachusetts,
Weymouth
en
North American Philips Lighting
Corp./spray paint operation
Dennison Mfg. Co.
Spray Operation
Maiden Mills
Textiles
City of Winchester
Municipal incinerator
General Dynamics
Eoiler
Town of Weymouth
Municipal incinerator
Massachusetts,
Revere
Massachusetts,
Chelsea
Mew Jersey,
Little Falls
Michigan
Detroit
Mississippi,
Laural
Mississippi,
Louisville
Sun Oil Co.
Gas loading terminal
Gulf Oil Co.,
Gas loading terminal
North Jersey Foundry Co. Inc.
Detroit Public Lighting Dept.
Mistersky stn.
Masonite, Corp.
Louisville Asphalt Co.
POLLUTION PROBLEM
TYPE OF ACTION
Organic material mass NOV 6/26/75
emission Order 8/29/75
Organic material mass Consent order 7/7/75
emission
Particulate mass
emission
order 9/26/75
Particulate mass
emission
NOV 10/2/75
Order 12/5/75
Particulate mass
emission
NOV 7/31/75
Order 10/30/75
Particulate emissions
Hydrocarbons
Order 7/7/75; civil action
instituted; consent
decree lodged
with court on 1/9/7
Consent order 6/13/75
Hydrocarbons
NOV 6/27/75
Particulate
particulate
Consent order 8/22/75
NOV 9/16/75
Particulate matter
Failed to resoonrt to
S114 request for
Consent order issued
12/12/75
Consent order issued
9/9/75
-------
STATE/CITY
16
COMPANY/TYPE
OKSOUKCt
Mississippi,
Gulfport
Capital Asphalt Co
Mississippi,
Laurel
Missouri
Knob Noster
Missouri
Grandview
Missouri
North Kansas
City
Montana
Bonner
Montana
Missoula
Montana
Great Falls
Nevada
KcGill
Masonite Corp.
Whiteman Air Force Base
(Dcpt of Air Force)
Richards - Gebaur A.F. Base
Fry Roofing Co.
U.S. Plywood—Main Boiler
3 Dutch oven boilers, veneer
dryer
Intermountain Company
Hog fueled burner
Superlite Products
Rotary Kiln
Kennecott Copper Corp., Nevada
Mines Division copper smelter
New York, Garden City Incinerator
Garden City
New York,
Lawrence
New York,
Long Beach
Sanitary District
*1 incincerator
Long Beach Incinerator
POLLUTION PROBLEM
TYPE OF ACTION
process & emission
information.
Failed to respond to
3114 request for
process and emis-
sion information
Particulate matter
particulate
opacity
particulate V/E
Consent order issued
11/21/75
NOV 6/19/75
MOD 8/29/75
MOD 8/14/75
NOV 9/25/75
violation of both
particulate emission
std and visitle emission
NOV 8/5/75
violation of particulate NOV 8/5/75
emission std
violation of particulate NOV 9/12/75
emission std
violation of Federally NOV 9/23/75
promulgated sulfur oxides
and particulate matter std.
Particulate
Particulate
Order 7/28/75
Amended 10/14/75
order 7/28/75
Particulate
Order 7/28/75
-------
STATE/CITY
17
COMPANY/TYPE
CF SOURCE
New York.
Valley Stream
New Jersey,
Irvington
New Jersey,
Medford
New Jersey,
Linden
New York,
Green Island
New Jersey,
Bogota
New Jersey,
Jersey City
New Jersey,
Newark
New York,
Plum Island
New York,
Buffalo
New York,
Brooklyn
New York,
Buffalo
Valley Stream Incinerator
Barnett Foundry £ Machine Co.
Lafferty Asphalt Co., Inc.
Public Service Elec. 6 Gas Co.
Bendix Corp.
Friction Mat'l Div.
Winston Mills
Woodward Metal Processing Corp.
Flockhart Foundry Co.
Plum Island Animal Disease
Center (Dept. of Agriculture)
Buffalo Municipal Incinerator
Detecto Scales, Inc.
Conner Hanna Coke Corp.
New York,
Freeport
New York,
Utica
New York,
Syracuse .
Freeport Incinerator
Dunlop Tire & Rubber
Niagara Mohawk Power Corp.
POLLUTION PROBLEM
TYPE OF ACTION
Particulate
Order 7/28/75
Particulate
NSPS-notif ication
performance tests
Opacity
NOV 7/8/75
Consent order 8/28/75
NOV & order 12/9/75
Consent order 7/18/75
NESHAPS-Asbestos
NOV & Order 7/28/75
Opaci ty
NOV 10/31/75
Particulate
Particulate V/E
NOV 11/11/75
NOV 11/17/75
Particulate
Consent agreement 11/19/75
Particulate
Order 8/20/75
Hydrocarbons
Order 7/30/75
Failure to respond to Order 8/20/75
Section 114 request for
information
Parti culate
Order 7/28/75
Particulate emissions NOV 9/2/75
Sulfur content in fuel NOV 7/31/75
particulate emissions
-------
STATE/CITY
13
COMPANV/TYPE
OF SOURCE
North Carolina,
Lenoir
North Carolina,
Roxboro
North Carolina,
Goldsboro
North Carolina,
Moncure
North Carolina
Glen Raven
North Carolina,
Rockingham
_, North Carolina,
0} Statesville
North Carolina,
Walnut Cove
North Carolina,
Whiteville
North Carolina
Aulander
North Carolina,
Aquadale
Eernhardt Industries, Inc.
Carolina Power 6 Light Co.
Roxboro Plant Unit 63
Carolina Power C Light Co.
H.F. Lee Plant Unit #3
Carolina Power & Light Co.
Cape Fear Plant Units 3 & 4
Glen Kaven Mills
Tenter-frame
Standard Coundry
Cupola
Troutman Foundry
Cupola
R.J. Reynolds Tobacco Co.
Tobacco Processing Line "A"
Georgia-Pacific Corp.
Eark Boiler
Planters Paanuts
Conical Burner
Carolina Solite Corp.
8 Rotary Kilns
Ohio
Cleveland.
Highland View Hospital
toilers
POLLUTION PROBLEM
TYPE OF ACTION
visible emissions
Particulate matter
Particulate
Particulate
Particulate
Visible emission
Consent order issued
8/28/75
NOV 11/21/75
NOV 11/21/75
NOV 11/21/75
NOV 11/21/75
Particulate
NOV 11/21/75
Particulate
NOV 11/21/75
Particulate
NOV 11/21/75
Particulate
NOV 11/21/75
Visible Emissions
NOV 11/21/75
Particulate & SO,
NOV 11/21/75
particulate
consent order 7/10/75
-------
STAT £/CITY
19
COMPANY/TYPE
OF SOURCE
POLLUTION PROBLEM
TYPE OF ACTION
cn
oo
Ohio
Youngstown
Ohio
Struthers
Ohio
Hillsboro
Ohio
Quincy
Ohio
Philo
Ohio
Painesville
Ohio
Gypsum
Ohio
Warren
Ohio
Ironton
Ohio
Mansfield
Ohio
Portsmouth
Ohio
Hamilton
Ohio
Middleiiranch
Ohio
Woodville
Ohio
Lancaster.
Youngstown Sheet 6 Tube
Eriar Hill Steel Works
Youngstown Sheet 6 Tute
Campbell Steel Works
Emerson Electric
Bell and Quincy Foundry
Ohio Ferro Alloys
Corporation, submerged arc furnace
Uniroyal, Inc.
U.S. Gypsum Co.
Copperveld Spec. Steel
Allied Chem/Semet-Solvay Div.
coke batteries
Ohio Brass Co.
Cupolas
Detroit Steel Corp/Empire-Detroit Steel Div.
open hearth furnaces
Gray Ircn Foundry Corporation
cupolas
Flintkote Co./Diamond Kosmos Cement Div.
cement kilns
Ohio Lime Co.
Loroco Industries
particulate and V/E
particulate and V/E
particulate and V/E
particulate and V/E
particulate and V/E
particulate
particulate
particulate
particulate £ V/E
particulate
particulate & V/E
particulate
particulate & V/E
particulate
particulate
consent order 7/25/75
consent order 7/25/75
consent order 7/23/75
consent order 7/23/75
consent order 7/31/75
order 7/7/75
order 7/7/75
order 7/7/75
NOV 8/6/75
consent order 8/6/75
order 8/11/75
consent order 8/11/75
consent order 8/11/75
order 7/8/75
order 10/9/75
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STATF./CITY
CCMFANY/TYPE
C? SOURCE
POLLUTION PROBLEM
TYPE OF ACTION
Cfi
Ohio
Steubenville
Ohio
Middlebranch
Ohio
Parma
Ohio
Cuyahoga
Heights
(Cleveland)
Ohio
Lima
(Shawnee
Township)
Ohio
Cakhill
Ohio
Cuyahoga
Ohio
Gypsum
Ohio
Warren
Ohio
Cleveland
Ohio
Painesville
Ohio
Cleveland
Ohio
Hillsboro
6 Quincy
Federal Paperboard
Flintkote Co./Diamond Kosmos
cement kilns
City of Parma
refuse incinerator
Chemetron Corp./Ohio Chemical
Plant - boliers
Vistron Corp. /subs of SOHIO
urea prill tower
Victory Charcoal Inc.
beehive kilns
McGean Chemical Co.
boilers
U.S. Gypsum
Copperweld Steel
Highland View Hospital
City of Painesville
Municipal Light Plant (toilers)
City of Cleveland/Lake Road
Gen. Stn. Coal fired toilers
Emerson Electric
particulate
particulate 6 V/E
particulate
particulate
particulate
particulate
particulate
particulate
particulate
particulate
NSPS for SOx
particulate
particulate
order 10/15/75
consent order 9/5/75
order 9/5/75
consent order 9/8/75
consent order 9/16/75
NOV 9/25/75
NOV 9/25/75
NOV 7/7/75
NOV 7/7/75
NOV 7/10/75
NOV 11/21/75
NOV 12/10/75
NOV 7/23/75
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STATE/CITY
21
COMPANY/TYPE
CF SOURCE
en
Ohio
Struthers
Youngtown
Oregon
Toledo
Oregon
Roseburg
Oregon
Springfield
Oregon
Portland
Oregon
Tillmook
Oregon
Portland
Oregon
Troutdale
Oregon
Porcland
Oregon
Portland
Oregon
Dillard
Oregon
Baker
Oregon
Uines
Oregon
Tillamook
Youngston Sheet 6 Tube Co.
Erien Hills 6 Campbell works
Georgia Pacific
Corporation pulp mill
S.O. Spencer fi Sons
Asphalt plant
Weyerhauser Co.
Lime Kilns
Nicolai Co.
Cyclones
Louisiana Pacific
Corp
Kigwam Eurner
Cargill Inc.
grain elevator
Reynold, Aluminum Co.
Louis Dreyfus Co.
grain elevator
Eunge Corporation
grain elevator
Permaneer Corporation
Particle board plant
Ellingson Lumber Co.
wigwam Waste Burner
Edward Hines Lumber
Hog Fuel toilers
Louisiana Pacific
wigwam burner
Oregon
Nicolus Co.
POLLUTION PROBLEM
TYPE OF ACTION
particulate
NOV 7/25/75
V/E
violation of NSPS
reporting
particulate matter
particulate matter
V/E
NOV 10/7/75
NOV 10/8/75
consent order 8/1/75
consent order 8/1/75
order 12/18/75
V/E
Opacity
Particulate matter
Particulate matter
Particulate matter
and opacity
particulate matter
V/E
particulate matter
V/E
particulate matter
Consent order 11/17/75
NOV 10/1/75
Consent order 11/26/75
order 9/26/75
NOV ll/U/75
order 11/4/75
NOV 9/22/75
NOV 11/10/75
consent order 8/1/75
-------
STATE/CITY
22
COMPANY/TYPE
OF SOURCE
POLLUTION PROBLEM
TYPE OF ACTION
Portland
Oregon
Springfield
Oregon
Valsetz
Oregon
Tigard
Pennsylvania
Templeton
Pennsylvania
Lebanon
Pennsylvania
Media
Pennsylvania
Marietta
01 Pennsylvania
O"1 Pittsburgh
Pennsylvania
Youngwood
Pennsylvania
Pittsburgh
Pennsylvaina
Monessen
Pennsylvania
Philadelphia
Pennsylvdnia
Avonmore
Pennsylvania
Newell
door manufacturing plant
Keyerhauser Co.
Draft Pulp Mill
Boise Cascade
hog fuel toilers
Western Foundry Co.
Iron £ Steel Foundry
Sharon Steel Corp.
Lebanon Chemical Corp.
Delaware County Dept. of Public
Works/municipal incinerator
U.S. Aluminum Corp.
Shenango Inc.
Steel facility
SwanJc/Dickerson/road construction
J.6 L. Steel Corp
wheeling-Pittsburgh steel Co.
Phila Heard of Education
toilers
General Steel Ind.
Allied Chemical Corp.
industrial Chemical Plant
particulate matter
particulate matter
particulate matter
consent order 8/1/75
consent order 8/1/75
consent order 8/1/75
failure to respond to order 8/5/75
Section 114 request
Failure to respond to order 8/1/75
Section 114 request
particulate matter mass order 10/16/75
emission
particulate matter mass NOV 7/7/75
emission order 12/75
particulate 6 SO2
particulate fugitive
dust
Particulate visible 6
SOx emission
Particulate visible 6
SOx emission
SOx sulfur content
particulate matter
mass emission
NSPS
NOV 7/3/75
NOV 7/22/75
order 9/19/75
order 10/8/75
NOV 10/17/75
consent order 7/23/75
order 7/31/75
order 7/21/75
Pennsylvania
Metro Edison Co.
particulate matter
order 7/9/75
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STATE/CITY
.23
CC.VPANY/TYPE
CF SOURCE
POLLUTION PROBLEM
TYPE OF ACTION
Middletown Crawford Station
Pennsylvania
Meadville
Pennsylvania
Potter
Township
Pennsylvania
-Kermett
Square
Pennsylvania
Farrell
Pennsylvaaia
Youngstown
Pennsylvania
Palmerton
Pennsylvania
Pennsylvania
Butler Co.
Pennsylvania
Meadville
Pennsylvania
Chambers-
burg
Pennsylvania
Sinking
Spring
Pennsylvania
Elrama
Abex Corp.
Engineering products
ARCO Polymers
plastic production
NVF. CO.
Sharon Steel Corp.
Youngstown
Pneumatic Concrete
New Jersey Zinc
Penn DOT (1-95)
Armco Steel
electric arc furnace
Dayton Malleable Inc.
toiler
Eorough of Chambersturg
Electric Power plant utility boiler
Sinking Spring Foundry Co.
grey iron cupola
Duquesne Light Co.
Elrama Station/utility toiler
mass emission
particulate matter
mass emission
SOx mass emission
Failure to respond to
Section 114 reguest
Failure to respond to
Section 114 request
visible emission
emission
visible emissions 6
particulates
particulate matter
fugitive
order 7/25/75
order 7/25/75
order 8/5/75
order 8/5/75
NOV 7/11/75
Amend, order 9/15/75
Particulate 6 visible NOV 12/16/75
NOV 7/11/75
consent order 10/29/75
particulate matter mass consent order 10/3/75
emission
particulate matter mass consent order 11/13/75
emission
particulate fugitives 6 consent order 11/28/75
opacity
particulte mass emission NOV 12/15/75
Pennsylvania Aluminum Co. of America
particulate mass
consent order 10/31/75
-------
STATE/CITY
24
COMPANY/TYPE
OF SOURCE
Pittsburgh toilers
cn
00
Pennsylvania
Washington
Co.
Puerto Rico,
Bayamon
Puerto Rico,
Catano
Puerto Rico,
Guayanilla
Puerto Rico,
San Juan
Puerto Rico,
Catano
Puerto Rico,
San Juan
Rhode Island,
Providence
Rhode Island,
Providence
South Carolina,
Hartsville
South Dakota
Sapid City
South Dakota
Sturgis
South Dakota
Rapid City
Climax Molybdenum Co.
Herreschoff roaster
Betteroads Asphalt
Corp. plant S3
Molinos de Puerto Rico, Inc,
Puerto Rico Water Resources
Authority
San Juan Cement
Puerto Rico Glass
Carribean Gulf
Refining Corp.
Tivian Labs.
Chemical lab
City of Providence
Sludge incinerator
Sonoco Products Co.
Division of Highways
portable aspnalt batch plant
Division of Highways
portable asphalt batch plant
Pete Lien and Sons, Inc.
Rotary Kiln and Vertical Kiln
South Dakota
Light Aggregates, Inc.
POLLUTION PROBLEM
TYPE OF ACTION
emission
SOx mass emisssion
consent order 10/21/75
NESHAPS-notificatlon NOV order 8/15/75
testing
Particulate
Consent order 7/3/75
SOx sulfur fuel content Consent order 10/20/75
NSPS-Portland
Cement Plant
Opaci ty
Visible emission and
organic compounds
PCB's mass emission
NOV 9/22/75
Order 12/31/75
Order 9/12/75
Order to comply with
3114 letter 12/18/75
Particulate V/E
NOV 11/3/75
Order 12/29/75
Particulate matter
Consent order issued
6/30/75
violation of participate NOV 7/9/75
emission std
violation of particulate NOV 7/9/75
emission std
violation of particulate NOV 7/16/75
violation of particulate NOV 7/16/75
-------
STATE/CITY
25
COMPANY/TYPE
CF SOURCE
POLLUTION PROBLEM
TYPE OF ACTION
crv
UD
Rapid City
Utah
Magna
Utah
Rowley
Utah
Lehi
Utah
Lehi
Utah
Lehi
Utah
Lehi
Utah
Ogden
Utah
Cgden
Utah
Geneva
Vermont,
Burlington
Vermont,
Hyde Park
Virgin Islands,
St. Croix
Virgin Islands,
St. Thomas
Hercules, Inc.
Coal-Fired Industrial Boiler
NL Industries, Magnesium Div.
Spray Dryer Exhaust Systems
Mountain States Lime, Inc.
4 vertical lime kilns
Mountain States Lime, Inc.
Hydrator Stack
Mountain States Lime, Inc.
Secondary Crusher C, Screening System
Mountain states Lime, Inc.
Rock Pulverizer Stack
Weber County Corp. Municipal
Incinerator Unit *2
Weber County Corp. Municipal
Incinerators $2 and #3
U.S. steel
Power Plant
City of Burlington
Eciler
Vermont Asbestos,
Inc.
Martin Marietta Corp.
(St. Croix Facility)
St. Thomas Paving Co., Ltd.
violation of particulate
emission std
violation of particulate
emission std
violation of particulate
emission std
violation of particulate
emission std
violation of particulate
emission std
violation of particulate
emission std
violation of particulate
emission std
violation of particulate
emission std
violation of particulate
emission std
Particulate mass
emission V/E
Asbestos visible
emissions
NOV 11/17/75
order 10/21/75
NOV 7/17/75
NOV 7/17/75
NOV. 7/17/75
NOV 7/17/75
NOV 7/14/75
Order 10/22/75
Order 9/29/75
Order 7/7/75
Order 10/10/75
SOX sulfur fuel content NOV 10/23/75
Operating w/o complying NOV 9/26/75
w/ new source review
requirements 40 CFR
52.2775(b)
Virginia
PEPCO-Fotamac River Station
Particulate matter mass order 8/27/75
-------
STATE/CITY
26
CCMPANY/TYPE
Of SOURCE
Alexandria
Virginia
Vansant
Virginia
Danville
Washington
Hoguiam
Washington
Port Angeles
Washington
Port Tounsend
Washington-
Shelton
Washington
Rock Island
Washington
Vancouver
Washington
Seattle
Washington
Peshastin
Washington
Koguiam
Washington
Shelton
Washington
Pasco
West Virginia
Weirton .
utility boiler
Jewell Coal & Coke Company
Dan River, Inc.
City of Hoguiam
Crown Zellerback
Corporation
Hog fuel boilers
Crown Zellerback
Corporation
Hog fuel boilers
Simpson Timber Co.
Hog Fuel toilers
Banna Mining Co.
ferro Alloy Plant
Carbonundum Co.
Center Oozing, Inc.
Feshastin Forest Products
ITT Rayonier
Hog Fuel boilers
Simpson Timber Co.
Hog Fuel Boilers
L.W. Vail, Inc.
Asphalt plant
National Steel/Steel facility
POLLUTION PROBLEM
TYPE OF ACTION
emission
Particulate 6 visible
emission
particulates
NOV 11/2U/75
consent order 10/3/75
open burning
NOV 10/7/75
particulate matter
consent order 8/15/75
particulate matter
consent order 8/27/75
particulate matter
consent order 8/1/75
visible and particulate consent order 9/30/75
matter
particulate matter
V/E
NESHAPS violation
NOV 12/18/75
NOV 11/25/75
Opacity
NOV 11/25/75
particulate matter
Consent order 8/1/75
particulate matter
consent order 8/1/75
opacity violation of
NSPS
NOV 7/28/75
particulate 6 SOx mass NOV 8/25/75
emission & opacity
-------
STATE/CITY
27
COMPANY/TYPE
OF SOURCE
West Virgina
Follanbee
Wisconsin
Milwaukee
Wisconsin
Kenosha
Wisconsin
Kenosha
Wisconsin
Mosinee
Wisconsin
Milwaukee
Wisconsin
Milwaukee
Wheeling-Pittsburgh Steel Co.
Amercian Motors Corporation
auto mfg.
American Motors corporation
auto mfg. (main plant)
American Motors Corporation
auto mfg. (main front plant)
Mosinee Papper Co.
Kraft Pulp/paper mill
Inryco Inc.
coil ccating operation
Lnryco, Inc.
Coil coating operation
POLLUTION PROBLEM
TYPE OF ACTION
Particulate 6 visible
SOx emission
hydrocarbon and
particulate
hydrocarbon
hydrocarbon
particulate
hydrocarbon
hydrocarbon
order 10/7/75
NOV 7/16/75
NOV 7/16/75
NOV 7/28/75
NOV 9/23/75
consent order 9/23/75
NOV 7/2/75
------- |