REVIEW OF AIR DATA SYSTEMS
prepared for
The U.S. Environmental Protection Agency
Contract No. 68-01-3308
Task Order 68-01-3094
prepared by
Index Systems, Inc.
One Broadway
Cambridge, Massachusetts O2142
December, 1976
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REVIEW OF AIR DATA SYSTEMS
Prepared For
THE U.S. ENVIRONMENTAL PROTECTION AGENCY
Contract No. 68-01-3308
Task Order 68-01-3094
Prepared by
INDEX SYSTEMS, INC.
One Broadway
Cambridge, Mass.
December 1976
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TABLE OF CONTENTS
I. MANAGEMENT SUMMARY 1
II. AIR PROGRAM STRATEGY 34
1. Legislative Basis 34
2. Regulations and Policy Development 41
3. Stationary Source Program 50
4. Mobile Source Program 54
5. Research Monitoring and Enforcement Programs .. 58
6. Future Developments 65
III. AIR DATA NEEDS 72
1. Air Program Planning and Review Data Needs .... 72
2. Abatement Plan Implementation Data Needs 83
3. Problem Analysis and New Program Development
Data Needs 93
IV. CURRENT AIR ADP SYSTEMS 106
1. Storage and Retrieval of Aeromatic Data (SAROAD) 107
2. National Emissions Data System (NEDS) 120
3. Compliance Data System (CDS) 130
4. Comprehensive Data Handling System (CDHS) 135
5. Other AEROS Systems 146
6. Research Systems 159
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V. PROBLEM AREAS 167
1. Data System Deficiencies and Scientific
Limitations 167
2. Data Flow Problems 173
3. Technical and Operations Problems 176
4. Cost-Related Problems 189
5. System Management Problems 193
VI. EVALUATION OF ALTERNATIVE ACTIONS 200
1. Ambient Air Quality Data 200
2. Emissions and Compliance Data 221
3. System Efficiencies and Functional Service .... 220
4. System Management 240
VII. RECOMMENDATIONS 246
1. Ambient Air Quality Data 246
2. Technical System Actions 253
3. AEROS Systems Performance Evaluation 256
4. EPA Management Actions 257
5. Projected ADP Expenditures 260
APPENDIX A - INVENTORY OF CURRENT SYSTEMS 265
APPENDIX B - COST ESTIMATES 283
APPENDIX C - QUESTIONNAIRE RESPONSE SUMMARY 292
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INDEX OF EXHIBITS
1-1 Summary of Federal and State Air Program
Responsibilities 8
1-2 Air Data System Costs 11
1-3 Proposed Air Monitoring Data Reporting
Requirements 16
1-4 Comparison Summary of Air Quality System Design
Alternatives 20
1-5 Time-Phased Action Steps for Implementing
Distributed System Design 23
1-6 Projected ADP Operating Costs by Organization .... 3i
1-7 Projected ADP Operating Costs by System 32
2-1 Summary of Criteria Pollutants Sources and Areas
of Concern 37
2-2 Summary of Classification of Regions 44
2-3 Legislated Mobile Source Pollution Abatement Goals. 49
2-4 Summary of Air Research and Development Activities. 60
2-5 Automobile Emissions Over the Course of a Trip .... 68
3-1 Planning and Review Information Needs 73
3-2 Information Needed for EPA Air Headquarters
Planning 75
3-3 Summary of SIP Revision Process 80
3-4 Information Needed to Implement Abatement Plans ... 84
3-5 Information Needed for New Source Review 88
3-6 Information Needed to Analyze and Develop New
Programs , 94
3-7 Summary of Non-Criteria Pollutant Sources and Areas
of Concern 96
3-8 Information Needed for ESECA Analysis 103
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4-1 SAROAD Data Flows Ill
4-2 SAROAD ADP Costs 121
4-3 NEDS Data Flows 125
4-4 NEDS ADP Costs 129
4-5 CDHS Contractor Costs 145
5-1 NCC Monthly Performance 178
5-2 ADP Air Costs by EPA User 190
5-3 Air Data System Costs 192
6-1 Comparison Summary of System Design Alternatives.. 201
6-2 Utility Air Quality System Alternative 203
6-3 Hybrid Air Quality System Alternative 204
6-4 Current Air Quality System Alternative 205
6-5 Functional Service Air Quality Data Systems
Design Alternatives 209
6-6 Cost Evaluation of System Design Alternatives .... 212
6-7 Air Quality Data System Alternative Design Risks.. 215
6-8 System Management Comparison of Design Alternatives 217
6-9 Summary of Emissions Data System Design Approaches 223
7-1 Time-Phased Action Steps for Implementing the
Hybrid Air Quality System 248
7-2 Projected ADP Operating Costs by Organization 261
7-3 Projected ADP Operating Costs by System ,.... 263
B-l Costs Associated with Proposed Changes 291
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I. MANAGEMENT SUMMARY
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I. MANAGEMENT SUMMARY
During the period from January 19, 1976 through July 30, 1976,
Index Systems conducted a review of the major automated data
processing (ADP) requirements and systems operated on behalf of
the air pollution control programs of the U.S. Environmental
Protection Agency (EPA). This report presents (1) the study
team's findings and conclusions regarding air program informa-
tion needs, (.2) the efficiency and adequacy of current ADP usage
to support these needs, and (3) recommended long-term policies
and short-term action steps to reduce ADP costs and improve the
quality of ADP services in support of air program data requirements.
This management summary presents the key results contained in
the report. It is divided into five sections, as follows:
Project Objectives and Scope
Project Approach
Summary of Findings
Summary of Recommendations
Report Organization
1. PROJECT OBJECTIVES AND SCOPE
The main objective of this study has been to examine the
legislative and programmatic requirements of the air program
and to evaluate the degree to which current EPA air computer
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systems satisfy these requirements. Particular emphasis was
to be placed upon evaluating the use of separate national and
state data systems, upon evaluating the need for separate
program and research air monitoring data systems, and upon
analyzing the relative merits of current system design philo-
sophies as opposed to more centralized and more distributed
design approaches.
The scope of the study included four groups of systems, as
follows:
Systems operated by the Office of Air Quality,
Planning and Standards (OAQPS) including:
NEDS - National Emissions Data System
SAROAD - Storage and Retrieval of Aerometric Data
SOTDAT - Source Test Data System
HATREMS - Hazardous and Trace Element Inventory
System
SIPS - State Implementation Plans System
QAMIS - Quality Assurance Management Information
System
EDS - Energy Data System
FPC (67) - Federal Power Commission Data
SIEFA - Source Inventory and Emission Factor
Analysis Program
WSAP - Weighted Sensitivity Analysis Program
REPS - Regional Emission Projection System
CAASE - Computer-Assisted Area Source Emission
Gridding Procedure
PRMS - Plans Review Management System
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Data systems operated by the Office of Research and
Development (ORD) to support air program research
activities including:
RAPS - Regional Air Pollution Study
CHESS - Community Health and Environmental
Surveillance System
CHAMP - Continuous Health Air Monitoring Program
NASN - The filter bank system of non-criteria
pollutant data
The Compliance Data System (CDS) operated by the
Office of Enforcement (OE)
The Comprehensive Data Handling Systems (CDHS) operated
by state and local agencies
Each system or group of systems was reviewed with regard to
its purpose, usage, efficiency, functional adequacy and impact
upon air program activities.
2. PROJECT APPROACH
The activities undertaken to achieve the project objectives
consisted of five tasks, as follows:
(1) Analyze User Needs
During this task the Index project team reviewed and
documented the overall national air pollution control
strategy and characterized the data needs associated with
each major program activity.
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These information requirements were used during
the subsequent tasks to evaluate the adequacy of
current system support and to assess proposed changes
in systems scope, design and operations.
(2) Evaluate System Functional Capabilities
During this task the project team reviewed the func-
tional capabilities of the EPA air data systems and
evaluated the adequacy of these capabilities in satisfying
identified user information needs.
(3) Evaluate System Technical Characteristics and Costs
During this task the project team examined the technical
efficiencies of the various air data systems. This
examination covered four areas, as follows:
Efficiency of systems implementation
and operation on the EPA computer
facilities
Conformity of systems design and
documentation with sound ADP principles
Data volumes and data base management
procedures employed
Current and future system costs for each
system including personnel, contractor
and computer expenditures
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As a result of this task the project team linked the
identified system functional requirements with
technical system design and operation efficiency and
costs. Based on this information the project team
prepared preliminary system recommendations regarding
system modifications or enhancements to improve the
cost effectiveness of air system capabilities in
meeting high priority user needs.
(4) Evaluate System Management Procedures
During this task the project team analyzed the adequacy
of current ADP system management practices and procedures.
Particular emphasis was placed upon the cost effective-
ness of current system support organization and responsi-
bilities, the adequacy of current system personnel
resources and the responsiveness of system managers to
the user community.
(5) Develop Recommended Changes
Based on the preceding tasks, the project team developed
recommendations to improve air data system capabilities,
operations and management. These changes and the continued
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operation of current systems were cost-justified on
the basis of legislative and programmatic requirements
as determined during Task 1. In addition, expected
costs and resource requirements for continued operations,
enhancements, and implementation of recommendations as
well as expected cost savings from design efficiencies
and system consolidation were projected.
3. SUMMARY OF FINDINGS
The study team reviewed the adequacy of current and anticipated
future ADP systems in satisfying air program information needs.
In addition, the study team assessed the technical efficiency
of air data systems in providing required services.
(1) EPA's Overall Air Pollution Abatement Strategy Involves
a Shift in Day-to*Day Operating Responsibilities to
State and Local Agencies.
Prior to the creation of EPA, most federal air pollution
control programs were conducted in North Carolina by the
organization which later became EPA's air program office.
With the formation of EPA and with the passage of the
Clean Air Act, the Office of Air Quality Planning and
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Standards (OAQPS) became responsible for developing a
national air pollution abatement program and for
assisting state and local agencies in developing and
implementing regulations and control strategies to
meet nationwide standards. In recent years, as more
regional and state personnel have received training
in air pollution control methods, the relative responsi-
bilities of Headquarters and field personne] have been
changing. Exhibit 1-1, on the following pa^e, summarizes
the current program functions. Headquarters is responsi-
ble primarily for overseeing national progress, for
developing new strategies for the control of criteria
and non-criteria pollutants, and for developing new
tools for use in reducing current pollution levels.
EPA regions are responsible primarily for overseeing
and monitoring state progress in achieving air pollution
abatement objectives. State and local agencies are
responsible primarily for developing and enforcing
regulations that are part of the State Implementation
Plans (SIP). New programmatic functions, such as National
Emissions Standard for Hazardous Air Pollutants (NESHAPS)
regulations or non-significant deterioration regulations,
are developed by EPA but may be delegated to state agencies.
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Exhibit 1-1
U.S. Environmental Protection Agency
Summary of Federal and State Air Program Responsibilities
FUNCTION
Standards Develop-
ment
Plan Development
and Implementation
Special Activities
EPA
Establish national ambient standards
Establish NESHAPS
Revise standards
Analyze new pollutants
Establish mobile source emission standards
Develop new source performance standards
Review SIPS and SIP progress
Test mobile source emissions
Conduct fuels and vapor recovery programs
Review enforcement activity
Provide technical assistance
Develop and delegate NSD and AQMA programs
Conduct or delegate NESHAPS program
Perform health effects research
Develop new control strategies
Develop simulation models
ESECA
STATE AGENCIES
Establish state standards
Revise standards
Develop, evaluate and revise SIPS
Develop TCP's
Conduct new source reviews
Write permits
Conduct inspections and undertake
enforcement actions
Monitor ambient air quality
CO
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(2) State and Local Agencies Require Access to Detailed,
Local Ambient and Emissions Information in Order to
Conduct Abatement Control Functions.
In order to carry out their day-to-day operational
functions, state and local agencies require comprehensive
ambient air quality and emissions information to assure
compliance with standards and to support source-related
control activities. Most emissions and air quality data
used by state and local agencies are provided by local
monitoring stations and through industrial or governmental
source inspections. Increasingly, however, states have
begun to use transportation and demographic data to deal
with mobile source-related pollutants, such as CO and oxi-
dants, in geographic areas with significant mobile source
problems. Nonetheless, the majority of local data gathered
and used, at present, is TSP and S02 monitoring information.
(3) EPA Requires National Trend Data to Support Program Management
Functions and Specialized Data to Support Program Planning.
EPA planners and program management personnel require
data on national air quality trends in order to assess
nationwide performance in meeting Clean Air Act objectives.
In addition, EPA research and program personnel require
very accurate and specialized ambient and industrial data
to assess health effects of criteria and non-criteria
9
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pollutants, and to develop new pollution control tools
to expedite abatement activities. The Standing Air
Monitoring Work Group (SAMWG) task force has determined
that a much smaller number of trend stations will be
needed in the future to support EPA Headquarters program
management functions, that a slightly larger data base
of air monitoring data will be needed by regional
offices/ and that local data will be needed by state
and local agencies.
(4) Current Air Data Systems and ADP Expenditures Concentrate
Primarily Upon Maintaining Detailed National Data Bases
of Ambient Information.
Approximately one-half of air program expenditures for
data processing support and for related contractor and
personnel activities relate to the assembly, storage and
review of raw ambient data produced by state and EPA
monitoring networks. Exhibit 1-2, on the following page,
summarizes the current ADP expenditures in support of
air program activities for fiscal years 1975 and 1976.
The SAROAD, RAPS, CHESS/CHAMPS and NASN expenditures of
$1.55 million in 1976 are all for storing and manipulating
10
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Exhibit 1-2
U.S. Environmental Protection Agency
Air Data System Costs
SAROAD (includes regions)
NEDS
CDS
RAPS
CHESS/CHAMPS
EDS
CDHS
NASN
Other
TOTAL
1976
$ 903,000
150,000
105,000
250,000
347,000
183,000
300,000
54,000
834,000
$ 3,126.000
1975
$ 606,242
260,131
48,000
117,600
289,756
18,000
Not Available
89,000
875,378
$ 2,215,107
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ambient air quality data. These costs are in addition to
state-incurred costs for CDHS and other state-operated
systems to manage local ambient data. This emphasis upon
ambient air data acquisition and manipulation reflects
a policy adopted in prior years by OAQPS whereby EPA
maintained a central data bank of national ambient air
quality information. Recently, however, this policy has
undergone revision and increasingly states have been
encouraged to take responsibility for acquiring their own
data banks of ambient data, as needed, to carry out
abatement and enforcement functions.
(5) The Instability of the UNIVAC Computer Has Created
Problems for All Users of Air Data Systems.
Since its installation in 1974, UNIVAC hardware problems
at the National Computer Center (NCC) have created an
unstable system environment which has inhibited timely
data processing operations and has limited the accessibility
of the information stored in the principle air data systems.
Frequent system crashes and prolonged downtime have
increased processing backlogs and have delayed software
conversion and enhancement efforts. In recent months,
actions have been initiated to correct hardware malfunctions.
Although some improvements have been implemented, the
mean time between failure is still below the NCC goal of
15 hours.
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(6) Currently Planned Changes in Air Data Systems Will
Make Them Less Sensitive to UNIVAC Hardware Problems.
EPA has undertaken substantial changes in the design of
its major air data systems, NEDS and SAROAD, which had
been converted inappropriately when transferred to the
UNIVAC. These changes have been initiated in order to
reduce the running time required to perform system updates
and to facilitate report retrieval. Most changes are
scheduled for completion by the end of fiscal year 1976.
Current estimates suggest that these changes will reduce
SAROAD operating costs by 50%. More importantly, however,
these processing cost savings will greatly reduce the
d
risk exposure of NEDS and SAROAD to hardware and operating
system failures on the UNIVAC computer. For example, a
typical SAROAD update, which currently takes 30 hours
to execute, is estimated to take only six hours after
the new changes are completed. This shortening of the
update time requirements will reduce substantially the
chances of the computer "crashing" while a SAROAD update
is in progress and thereby will reduce proportionately
the number of times SAROAD must be reupdated to correct
for the computer "crash". As a result, SAROAD will be
updated on a more regular basis than at present and
users will be able to access the data base without the
week-or month-long delays which have been experienced
recently.
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(7) Data Handling Problems and Delays in State-submitted
Data Contribute to Data Currency Problems.
NEDS and SAROAD data handling and editing procedures
require many separate steps and thereby delay the entry
of current corrected data. In addition, poor interfaces
and non-compatible edits between state and federal data
systems complicate the data correction process. As a
result, Headquarters, regional office and state personnel
must interact extensively to track data submittals and
corrections. However, various regional offices and state
and local agencies have placed low emphasis upon submitting
and correcting submitted data. Consequently, EPA air data
system users have been hampered in analyzing some state-
submitted air quality and emissions data because of data
currency problems.
(8) Proposed Changes in the Air Monitoring Strategy Will Reduce
the Volume of State-collected Data Stored Centrally by EPA.
The Standing Air Monitoring Work Group (SAMWG) has
undertaken a project to revise the requirements for the
submittal of state-collected air monitoring data. Preliminary
results from SAMWG indicate that EPA will reduce substantially
the volume of data which it will require on a regular basis
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from states. State-collected air quality data will
be grouped into three groups, as follows:
National trend station data
State trend station data
Special purpose monitoring data
Exhibit 1-3, on the following page, illustrates the
proposed air monitoring data reporting requirements
associated with these three classes of data.
Under this proposed strategy a subset of the state-
collected data, National Air Quality Trend Station (NAQTS)
data, would be communicated bo EPA regularly and stored
on a central data base for analysis. SAMWG estimates
that the number of monitoring sites reporting data regu-
larly to EPA will be reduced by 80 percent. Some regional
offices may elect to require some non-National Trend Station
data reporting from states as may be defined in the future
by SAMWG. In most cases, Regional Offices and others
requiring summary statistics or raw data from non-NAQTS
would obtain this information, as needed, from the
state office which collects this special purpose data.
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Exhibit 1-3
U.S. Environmental Protection Agency
Proposed Air Monitoring Data Reportino
Requi reroen ts
NAQTS
Data
SLAI1S
Data
State-collected
Special Purpose
Monitoring Data
State
Office
(NAQTS Data)
EPA
Headquarters
Regional
Offices
FPA
Computer
JNAQTS
I Data
vo
N
State
Computer
j NAQTS Data
^SLAMS Data
JFpecial Purpose
[ Data
RegionalJ /Selected
nf~. • SLAMS Data
0fflce ! , and Special
Data Base' ]Purpose
1 Monitoring
' Data
1 NAQTS - National Air Quality Trend Stations
2 SLAMS - State and Local Air Monitoring Stations
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(9) The Absence of Formal ADP Responsibilities and Procedures
Has Lessened the Efficiency and Effectiveness of ADP
Utilization in Support of the Air Program.
Current EPA policies place operating responsibilities
for national air data systems within the National Air
Data Branch (NADB) in OAQPS. Although NADB contains
the largest number of trained ADP personnel with
experience in project management and development,
current responsibilities do not reflect centralized
control of system development projects within OAQPS.
For example, the Energy Data System (EDS), which was not
developed by NADB, will cost 10 times as much in ADP costs
next year as the original feasibility study justified.
More broadly, ADP users of the National Computer Center's
(NCC) UNIVAC computer are unaccustomed to managing or
controlling their ADP utilization to conform to budget
ceilings. Most system managers at the Research Triangle
Park laboratories, for example, were unable to provide
estimates of current- or future-year processing needs.
Instead, research managers tended to view ADP budgets
as interchangeable with program budgets and were not
concerned, therefore, with ADP budgets since they
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intended to reprogram from research into ADP sub-
allowances whenever necessary. Air program personnel
indicated a greater awareness of ADP budgeting but did
not have good accounting tools available whereby they
could monitor and control actual UNIVAC computing
expenditures. Regional ADP managers, by contrast,
indicated the greatest sensitivity to NCC computing
costs and demonstrated the most aggressiveness in
developing methods to manage and control ADP expenditure
levels.
4. SUMMARY OF RECOMMENDATIONS
\EPA should initiate actions to shift towards a hybrid
data processing philosophy for ambient air data and should
complete currently-contracted system enhancements to reduce
overall air data system expenditures,
;s. 1
(1) EPA Should Adopt a Hybrid Computer System Design Approach
for Storing Air Quality Data in Conformity With the
Revised Monitoring Strategy.
Costs will be reduced slightly and service will be improved
if EPA adopts a hybrid system design philosophy for the
management of state-collected air quality data. The
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hybrid system approach reflects the programmatic shift
in monitoring strategy as being developed by the Agency's
Standing Air Monitoring Work Group (SAMWG). This pro-
grammatic shift will require far less raw ambient data
for Headquarters and regional use and will free states
and local agencies to allocate more monitoring resources
for special-purpose local projects. Exhibit 1-4, on
the following page, contrasts the impact of a hybrid
design approach with a utility and the current design
approach. The hybrid and utility system alternatives
would improve data handling and correction capabdlities
and would offer Headquarters and states flexible re-
porting and good data availability. By comparison, under
the current system approach data handling and correction
problems would continue to contribute to completeness
and currency problems of EPA-maintained data as a result
of the large volumes of data transferred and the relative
distance and processing steps between the sources of data
and the EPA users.
A hybrid approach would reduce slightly aggregate computer
operating costs for EPA and state offices, yet would entail
development and installation costs comparable to those
needed to support the current design philosophy.
In addition, a hybrid system design would offer EPA lower
technical and cost risks than the utility or current
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Exhibit 1-4
U.S. Environmental Protection Agency
Comparison Summary of System
Design Alternatives
Utility
Hybrid
Current
Functional
Service
mproved data
handling with
ood availability
f state-collectec
ir quality data
Improved data
handling with
good availability
of monitoring
trend data
Good data
availability and
reporting flexi-
bility but poor
data handling
Annual Operating
Cost Impact
$625,000
$600,000
$300,000
Development and
Installation
$600,000 -
$1,000,000
$380,000
$330,000
Risk
High technical
and cost risk
Low technical
and cost risk
Moderate
technical risk
Management
Considerations
System management
problems with
state dependence
upon EPA for ADP
support
Less complex
system
management
Less dependence
of EPA and
states upon
each other
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approaches. Under a hybrid design EPA would maintain
a much smaller data base consistent with the SAMWG data
reporting requirements. This smaller data base would
be less sensitive to hardware problems. Similarly, the
cost risk would be reduced since the majority of data
processing would be controlled by the states who, in turn,
would be free to decide and pay for whatever data they
needed for local purposes. A hybrid design would provide
EPA with a system which is easy to manage and which would
not entail heavy dependence of states on EPA-provided
ADP support.
(2) EPA Should Initiate Five Major Action Steps During the
Next 2-3 Years in Order to Establish a Hybrid System for
the Management of Air Quality Data.
EPA should phase the implementation of the hybrid system
approach over a 2-3 year period after EPA acceptance of
the SAMWG data reporting recommendations. The phasing
of this approach is necessary to facilitate management
control and to insure a smooth and non-disruptive phasing
of individual states into the hybrid data reporting
strategy. The implementation process should be divided
into five steps, as follows:
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EPA should define the specific data reporting
requirements and procedures needed to support
the SAMWG-recommended changes in air monitoring
strategy. These definitions should include
procedures for regional offices to acquire and
maintain non-NAQTS data, as needed. Furthermore,
EPA should develop procedures for support of
those states without air quality data systems.
OAQPS and the regions should select three states
as prototypes to test the new monitoring strategy
data reporting requirements.
The prototype states should test the new
reporting procedures over a 6-9 month period.
EPA should assess the performance of the new
reporting procedures and revise these procedures
accordingly.
EPA should extend the new reporting procedures
to the other states over an eighteen month
period.
Exhibit 1-5, on the following page, indicates the relative
phasing of these actions. Most of this work could be
performed by EPA personnel. However, contractor assis-
tance would be required to design and implement a
management summary information system for use by EPA.
Contractor assistance could be used also to develop
detailed data reporting requirements consistent with
the SAMWG recommendations. Overall contractor costs for
these services would be approximately $75,000. Additional
contractor support for CDHS installation and EPA personnel
resource levels to coordinate these action steps would
not exceed currently budgeted resource levels.
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Exhibit 1-5
U.S. Environmental Protection Agency
Time-Phased Action Steps for Imple-
menting the Distributed Air Quality
System
ACTION STEPS
Define data reporting
requirements and pro-
cedures
Identify prototype
states to test new
data requirements
Test prototype states
over 6-9 month period
Assess performance
after test period
Extend data reporting
procedure to other
states
3 months
9 months
3
months
CN
18 months
EPA Acceptance
of SAMWG Recommendation
1st Year
2nd Year
3rd Year
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(3) EPA Should Refrain From Initiating Major New Changes to
NEDS and SAROAD Until Currently-contracted Enhancements
Have Been Completed and Tested.
EPA should be able to achieve substantial reductions in
current air data processing costs as a result of current design
changes in its major systems. However, in order to insure
that anticipated benefits are realized, EPA should
refrain from making other major design changes to NEDS
and SAROAD until Agency personnel have had an opportunity to
confirm the expected efficiencies. In addition, these
design changes should impact dramatically the accessi-
bility of NEDS and SAROAD to field users and should
provide more reliable edit, update and reporting services.
Accordingly, the patterns of report retrievals and data
submissions likely will change so that new processing
statistics will be needed to determine whether additional
opportunities for system efficiencies will be available.
However, minor changes in NEDS edit and update procedures
should be incorporated into current enhancement efforts.
In particular, current changes in the NEDS edit should
be expanded to allow regions to run validation checks
and to edit input cards against the NEDS user file.
These changes will reduce the time lags associated with
the correction of NEDS data and will cost approximately
$10,000 in additional contractor funds.
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Minor additional savings could be achieved through
additional design changes depending upon the operating
performance of the resulting air data systems. Six
specific changes could further reduce operating costs
and improve service, as follows:
Modify the method for calculating SAROAD
running averages
Revise the timing of SAROAD summary and
frequency of file creation
Develop a SAROAD violations file
Develop an enhanced NEDS regional edit
Enhance current CDHS data edit and validation
capabilities
Develop better interfaces between state and
federal emissions systems
More substantial design changes, as proposed by EPA
program personnel, have not been found to reduce ADP
costs. These proposed changes have included three
areas, as follows:
A change in the current design approach for the
management of emission data would not reduce
ADP expenditures.
Consolidating NEDS with CDS would not reduce
ADP expenditures.
The transfer of air data systems from the UNIVAC
to other EPA computers is not cost-justifiable
at this time.
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Overall, the currently planned technical changes
combined with a longer-term commitment to a distributed
ambient data system will reduce ADP costs without
disrupting program activities.
(4) EPA Should Conduct Immediately a System Audit of the
Energy Data System (EDS) Before Assigning Additional
Resources for Support and Development.
EPA should conduct immediately a system audit of EDS
to determine the value of the current system and to
ascertain whether additional resources should be
applied to support it. The statement of work for this
audit should include five areas for investigation, as
follows:
The air program information requirements to
be supported by the system
The adequacy of the current system in satis-
fying these requirements
The efficiency of the current system design
Operating cost analyses in terms of the decisions
for which the system provides information
System management responsibilities
The estimated cost for the EDS audit is $15,000 and the
elapsed time is estimated to be three months.
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(5) EPA Should Continue Its Support of CDHS and Insure
Sufficient Resource Commitments.
EPA should continue its support for CDHS by taking five
system-related actions, as follows:
Complete current identified modifications
to CDHS
Conduct a review of states to identify
additional CDHS enhancements necessary to
meet state information requirements
Provide additional enhancements to CDHS
reporting capabilities as specified by
state users
Improve current data handling procedures for
CDHS by incorporating more extensive edit
capabilities
Review and develop interface procedures
between state-operated systems and EPA-
maintained systems
These actions will require an estimated $250,000 in
contractor funds over a 12-month period. These con-
tractor funds have been requested and granted by OAQPS
and do not represent an additional level of effort
above current budget requests.
(6) MIDSD Should Conduct a Detailed Technical and Operating
Analysis of the UNIVAC and Its Management.
MIDSD should conduct a detailed technical analysis of the
UNIVAC in four areas, as follows:
27
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Hardware malfunctions
Throughput volume
Channel capacities
Operating system performance
This study should include an analysis of NCC processing
characteristics and performance with other comparable
UNIVAC installations. In addition, this study should
analyze the adequacy of current staffing levels, manage-
ment procedures, use of contractors and organization.
As a result of this study MIDSD should develop an
organizational and operations plan to reduce the overall
failure rate at NCC. This analysis is estimated to cost
$50,000 and could be completed within four months.
(7) EPA Should Consolidate Its Air Data Processing Responsi-
bilities and Formalize Its ADP Management Procedures.
Air data system development and operation should be
centralized within OAQPS and personnel with experience
in managing development projects should be allocated
by senior OAQPS management in proportion to the relative
priorities of each division's needs. In addition,
support for CDHS should be formalized as a high priority
responsibility of OAQPS data systems managers and
suitable training and assistance should be provided
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to regional coordinators to insure that states receive
adequate data systems support.
MIDSD should provide assistance to OAQPS and other air
data systems users to insure that good management
principles are adhered to in the design, development
and operation of ADP systems. This assistance should
include four areas, as follows:
Formalize statements of work to contractors
at RTF to insure that feasibility studies
are performed separately from system develop-
ment
Confirm that actual design and development
activities are consistent with cost justifi-
cations as produced in feasibility studies
Require formal ADP budgets from all NCC users
and explain to program managers that program
funds cannot always be interchanged with ADP
sub-allowances
Provide guidelines and accounting tools to NCC
users to help them to develop improved methods
for reducing processing costs
All these changes can be implemented internally by EPA
staff without contractor assistance.
(8) ADP Expenditures in Support of the Air Program Should
Remain Relatively Stable Over the Next Two Years.
Over the next two years ADP expenditures will remain
relatively constant while contractor costs will decrease
by an average of $250,000 annually.
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Exhibit 1-6, on the following page, compares FY '76
estimated ADP expenditures by organization with the
projected future annual costs. OAQPS will experience
the most significant reduction in computer operating
costs of approximately 37% compared to FY '76 expenditure
levels. On the other hand, regional and state ADP costs
will increase by approximately $275,000 as additional
CDHS systems are installed and as local and regional
personnel assume more responsibility for data analysis
and modeling activities. Index has not been able to obtain
projected ADP operating costs from either ORD Headquarters
or laboratory personnel. However, we have estimated ORD
operating costs to increase by 20% annually to reflect new
system development and continued research analysis. This
20% assumed increase reflects growth in annual ORD expen-
ditures of almost $350,000 over current levels. Exhibit
1-7, on the page following Exhibit 1-6, compares FY'76
estimated expenditures by system with projected future
annual costs. The most significant reduction in operating
costs will result from current technical SAROAD modifica-
tions. These technical changes plus the shift towards a
hybrid approach for managing air quality data will reduce
SAROAD computer costs by approximately 67%. On the other
hand, CDHS costs will increase significantly as additional
installations occur. EPA system managers have projected
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Exhibit 1-6
U.S. Environmental Protection Agency
Projected ADP Operating Costs by
Organization
OAQPS
ORD
OE
Regions
States
TOTAL
1976
($000)
1656
857
54
300
300
3126
1977
($000)
1360
1000
50
300
380
3090
1978
($000)
1066
1200
50
400
475
3190
31
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Exhibit 1-7
U.S. Environmental Protection Agency
Projected ADP Costs by System
SAROAD
NEDS
CDS
RAPS
CHESS/CHAMPS
EDS
CDHS
NASN
Other OAQPS Systen
Other ORD Systems
Other (including
unallocated regio
usage)
TOTAL
__
1976
($000)
903
150
105
250
347
183
300
54
s 380
200
254
lal
3126
1977
($000)
480
180
100
300
410
300
381
54
400
230
255
3090
1978
($000)
300
180
100
360
490
186
475
54
400
290
355
3190
32
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EDS operating costs to increase to $300,000 next year.
However, we anticipate that an EDS system audit will
identify areas where operating costs could be reduced
back to current year levels. Personnel levels in
support of the air data systems are expected to remain
stable during the next two years at Headquarters, in the
regions and in the states.
5. REPORT ORGANIZATION
The remainder of this report is divided into seven chapters
and three appendices. Chapters II through V present findings
regarding program strategy, user needs, data system functions
and related problem areas. Chapter VI presents an evaluation
of alternative actions to remedy identified problems and
Chapter VII presents the resulting recommendations. Appendix
A contains technical information on the air data systems
reviewed. Appendix B contains cost derivation information as
employed in the study analysis and Appendix C summarizes the
results of a questionnaire completed by system users throughout
the country.
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II. AIR PROGRAM STRATEGY
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II. AIR PROGRAM STRATEGY
This chapter presents an overview of the EPA air pollution control
program and its associated strategies. The chapter is divided
into six sections, as follows:
Legislative Basis for the Air Program
Regulations and Policy Development
Stationary Source Air Program
Mobile Source Air Program
Research and Development, Monitoring
and Enforcement Programs
Future Developments
1. THE CLEAN AIR ACT AMENDMENTS OF 1970 PROVIDE THE LEGISLATIVE
BASIS BY WHICH EPA HAS RESPONSIBILITY FOR DEVELOPING AND
MANAGING PROGRAMS FOR THE REDUCTION OF NATIONAL AIR POLLUTION
LEVELS.
With the enactment of the 1970 amendments to the Clean Air
Act and subsequent formation of the Environmental Protection
Agency (EPA), the role of the federal government changed from
one of limited authority in the abatement of air pollution
to one of nationwide involvement in air pollution control.
In 1955, the Department of Health, Education, and Welfare
was authorized to conduct research and provide technical
assistance to state and local communities in their attempt
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to prevent and control air pollution. In legislation of 1963
and 1967, Congress reaffirmed the policy of state and local
responsibility for air pollution control while expanding
the federal government's research and development activities.
The Clean Air Act Amendments of 1970 provided the basis for
federal leadership in the development of national, regional,
state and local programs to prevent and control air pollution.
(1) In Accordance With the Act, EPA Has Set National Primary
and Secondary Ambient Air Quality Standards for Each
Criteria Pollutant.
In 1970, EPA published criteria documents which de-
scribed the current scientific knowledge of the effects
on public health and welfare which could be expected
from the presence of various pollutants in ambient
air. Based on these documents, in April 1971 EPA
established primary and secondary standards for six
major pollutants, as follows:
Sulfur dioxide (S02)
Particulate matter
Carbon monoxide (CO)
Hydrocarbons (HC)
Nitrogen oxide (N°x)
Photochemical Oxidants
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Exhibit 2-1 on the following page, summarizes the
major source of each pollutant and the associated
general health-related area of concern.
National primary ambient air quality standards define
levels of air quality necessary to protect the public
health with an adequate margin of safety, while
secondary standards are designed to protect the public
welfare, specifically property, vegetation, and
wildlife.
As published in the Federal Register, each ambient
air standard specifies a reference method for sampling
and analyzing the ambient air and the reference condi-
tions to which measurements are to be corrected. Under
the Act states may establish ambient air quality
standards more stringent than the national standard
to prevent significant deterioration of existing air
quality within their state.
(2) States Are Required by Law to Develop and Carry Out
State Implementation Plans (SIP's) to Achieve and
Maintain National Ambient Air Quality Standards (NAAQS)
Established by the EPA.
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Exhibit 2-1
U.S. Environmental Protection Agency
Summary of Criteria Pollutants and
Associated Sources and Areas of
Concern
POLLUTANT
MAJOR SOURCE
GENERAL AREA OF CONCERN
Sulfur Dioxide
Particulate Matter
Carbon Monoxide
Hydrocarbons
Nitrogen Oxides
Photochemical
Oxidants
Stationary Sources
Stationary Sources
Mobile Source
Mobile Sources
Mobile Sources
Formed in the Atmosphere
from NO and HC
X.
Respiratory Illness
Respiratory illness
Lethal Gas
Contributes to Formation
of Oxidants
Respiratory, Contributes
to Formation of Oxidants
Respiratory Illness
r-
ro
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The ambient air standards became the basis for the
development of SIP's in 1972. State plans specified
the steps to be taken to control emissions from
existing sources of pollutants in order to achieve
ambient air quality standards. The Clean Air Act
gives EPA the authority to approve or disapprove
SIP's and all subsequent revisions that the states
may develop. Furthermore, EPA was required to
develop the implementation plan for any state if
one of the following three conditions existed:
The state failed to submit a plan within the
time prescribed by the Clean Air Act
EPA determined that the plan did not meet
the requirements of Section 110 of the
Clean Air Act
The state failed to make appropriate revisions
as deemed necessary by the EPA to achieve
NAAQS
The primary responsibility for enforcement of the SIP
rests with the state while EPA has concurrent authority
to enforce the SIP's, when necessary.
(3) Although the Clean Air Act Emphasizes State Responsi-
bility, the Clean Air Act Gives EPA Special Authority
in Certain Areas That Are Interstate in Nature or
Pose a Severe Threat to Health
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Special federal authority exists to control new
stationary sources of criteria pollutant emissions,
motor vehicle emissions, sale of fuel and fuel
additives, and emission of hazardous air pollutants.
EPA directly regulates new stationary sources by
setting uniform national standards for various new
sources of pollution. The standards of performance
published in the Federal Register are designed to
limit emissions through the use of the Best Available
Control Technology (BACT).
Since the abatement of mobile source pollution requires
national standards, the Clean Air Act dictated a schedule
for the abatement of automobile pollution. In accordance
with the Act, EPA prohibits the sale of new cars unless
the cars are based upon a tested and approved prototype
model.
In addition, EPA, in coordination with the Federal Energy
Administration (FEA), has written regulations concerning
fuels, and fuel additives. In 1974, EPA and FEA coordi-
nated actions to make non-leaded gasoline available at
service stations so as not to interfere with the perfor-
mance of the catalyst pollution control devices.
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After the 1973 oil embargo, Congress passed the Energy
Supply and Environmental Coordination Act (ESECA)
of 1974. ESECA required the FEA to issue orders
prohibiting power plants with coal burning capabilities
from burning natural gas or oil as a primary source
of energy. The act gives EPA responsibility for the
certification of FEA prohibition orders. Before an
FEA order becomes effective EPA must determine if
primary air quality standards will be violated as a
result of a conversion. The Clean Air Act was
amended in 1975 to authorize EPA to suspend temporarily
fuel and emission limitations for those sources which
have been issued orders by FEA and certified by EPA.
EPA has set national standards for air pollutants that
have proven to contribute to increased death rates.
Once promulgated, these standards are applicable to
all new and existing sources.
(4) As Specified in the Clean Air Act, EPA Has Established
a National Research and Development Program for the
Prevention and Control of Air Pollution .
The Office of Research and Development (ORD) conducts
a comprehensive and integrated research and development
program in support of the objectives of the Clean Air
40
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Act. ORD supports the Air Program in four general
areas, as follows:
Providing research on both the short and
long-term effect of air pollutants on human
health to be used as the scientific basis
for standards and regulations
Prescribing standard methods to measure and
assure quality control in programs to assess
environmental quality, implement plans and
enforce strategies
Identifying cost-effective pollution control
technology which is capable of achieving
short-term abatement objectives and possesses
long-term viability
Providing expert scientific assistance through
the dissemination of technical information
and technological transfer of capabilities
2. THE AIR PROGRAM STRATEGY IS DESIGNED TO ACHIEVE AND MAINTAIN
NATIONAL AMBIENT AIR QUALITY STANDARDS.
EPA has developed an air program strategy to achieve the
objectives of the Clean Air Act by taking six actions, as
follows:
Divide the nation into Air Quality Control Regions
Encourage states to develop and enforce implementa-
tion plans to achieve and maintain NAAQS
Develop performance standards for new stationary
sources
Conduct programs to prevent the further deteriora-
tion of air quality
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Develop a national mobile source air program
Establish national emissions standards for
hazardous air pollutants
These actions are designed to specify local air pollution
abatement objectives and to achieve these objectives through
the control of existing and new sources of pollution.
(1) EPA has Divided the Nation Into Air Quality Control
Regions (AQCR's) in Order to Develop and Implement
Plans Which Specify the Manner in Which NAAQS Will
Be Met and Maintained.
Under Section 107 of the Clean Air Act each state has
the primary responsibility for assuring air quality
within its boundaries. The country is divided into
247 AQCR's which reflect the unique features of local
air pollution features. An AQCR is a geographic unit
within which states analyze existing ambient air con-
ditions, develop plans, and determine priorities for
action. Each region is classified separately with re-
spect to each criteria pollutant so that the time and
resources expended in developing the SIP can be com-
mensurate with the complexity of the air pollution
problem, Each region is classified into one of three
categories, as follows:
A *5
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Priority I - most restrictive
Priority II
Priority III - least restrictive
Exhibit 2-2, on the following page, summarizes the
classification mechanism for each pollutant.
(2) EPA's Air Strategy Requires States to Develop and
Implement Plans to Achieve and Maintain NAAQS for
Each AQCR Within Their Geographic Jurisdiction.
State Implementation Plans (SIP) detail the steps
to be taken to abate and control emissions from
existing sources within an AQCR to insure attainment
of air quality standards. An implementation plan
includes four major elements, as follows:
Information on existing air quality and
source emissions
Control plan for achieving standards
Programs for monitoring ambient air quality
and source emissions
Description of legal authority
EPA may require a SIP revision under any of three
circumstances, as follows:
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Exhibit 2-2
U.S. Environmental Protection Agency
Summary of Classification of Regions
POLLUTANT
BASIS FOR
CLASSIFICATION
APPLICABLE
CLASSES
METHOD OF CALCULATION
Sulfur Oxides
Measured Ambient Air
Quality, or
Estimated Air Quality
in Area of Maximum
Concentration
I,II or III
Annual Arithmetic Mean,
24-hour Maximum and 3-hour
Maximum
Particulate
Matter
Measured Ambient Air
Quality, or
Estimated Air Quality
in Area of Maximum
Concentration
I,II or III
Annual Geometric Mean and
24-hour Maximum
Carbon Monoxide
Measured Ambient Air
Quality, or
1970 Bureau of Census
Population Information
I or III
1-hour Maximum and 8-hour
Maximum
Nitrogen Dioxide
Measured Ambient Air
Quality, or
1970 Bureau of Census
Population Information
I or III
Annual Arithmetic Mean
Photochemical
Oxidants
and
Hydrocarbons
Measured Ambient Air
Quality, or
1970 Bureau of Census
Population Information
I or III
1-hour Maximum
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Changes of national primary or secondary
national air quality standards
Evidence to EPA that the SIP is substan-
tially inadequate to achieve NAAQS
Changes in the availability of methods
and control technology necessary for
source compliance
In addition, in the development of a SIP, the state
must consider the effect of urban and economic growth
on a region's future air quality and adapt its con-
trol programs accordingly.
(3) New Source Reviews (NSR) and Environmental Impact
Statements (EIS) Are Mechanisms to Prevent the
Further Deterioration of Air Quality.
As a result of a 1972 District Court decision and sub-
sequent affirmation in 1974 by the U.S. Supreme Court,
EPA is required to disapprove SIP's which do not provide
a plan to prevent the significant deterioration of air
quality in areas that did not exceed national ambient
standards during 1974 for sulfur dioxide and particu-
late matter. Accordingly, EPA published regulations in
the Federal Register in 1974 establishing three classes
of AQCR's based on how much increase of ambient concentra-
tions of sulfur dioxide and particulate matter could be
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permitted without significant deterioration of air
quality. The three classes are defined, as follows:
CLASS I AQCR's where practically any
air quality deterioration would
be considered significant
CLASS II AQCR's where well-planned growth
would not be considered to add
significantly to the air quality
deterioration
CLASS III AQCR's where intense industrial
growth is desired but national
air standards for particulate
and sulfur dioxide must be
maintained
EPA designated all ACQR's as Class II, originally;
however, states may request redesignation of a region
in order to meet various social and economic objectives.
For purpose of significant deterioration determination,
areas designated as Class I or II are limited to
specific increases in particulate matter and sulfur
dioxide concentrations above January, 1975 ambient
air quality levels for those pollutants.
Nineteen source categories have been established for
the review of new or modified sources commencing
construction or modification after June, 1975. The
non-significant deterioration reviews are designed
to determine the effect on air quality of the proposed
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new source or source modification in conjunction with
changes in emissions from other sources in the area of
concern. EPA may delegate the responsibility for im-
plementing procedures for conducting non-significant
deterioration reviews to the individual states.
The National Environmental Policy Act of 1970 requires
each federal agency to prepare a statement of environ-
mental impact in advance of each major action that may
affect ambient air quality significantly. EIS's pro-
vide a mechanism by which federal agencies, the public,
and Congress can review the air quality consequences
associated with a pending government decision. The
Council on Environmental Quality (CEQ) is responsible
for coordinating actions relating to EIS production.
(4) EPA's Mobile Source Program Is Designed to Reduce the
Levels of Harmful Pollutants Emitted From Motor Vehicles.
In 1971, motor vehicles contributed 50% of all carbon
monoxide (CO), 40% of all hydrocarbons (HC) and 25% of
all nitrogen oxides (NO ) emitted into the air within the
H
United States. The Clear Air Act legislated strict
mobile source emission standards for the control of
these three pollutants. Exhibit 2-3, on the following
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page, summarizes the mobile source abatement goals
as legislated in 1970. In 1973, EPA granted a one-
year extension for the 1975 statutory standards.
The choice of how to meet the legislated standards
has been left to mobile source manufacturers. In
the early 1970's, most U.S. automakers elected to
use catalysts as a means of converting HC and CO
exhaust emissions into carbon dioxide and water. The
catalyst represented a control technology which could
reduce emissions to required levels while protecting
auto manufacturers' capital and technical investment
in the internal combustion engine.
(5) EPA Established National Emissions Standards for
Hazardous Air Pollutants (NESHAP).
EPA has established emission standards for air pollu-
tants which have been found to be harmful to the
public health and to which no ambient air quality
standard is applicable. Three hazardous pollutants
have been identified, as follows:
Asbestos
Beryllium
Mercury
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Exhibit 2-3
U.S. Environmental Protection Agency
Summary of Legislated Mobile Source
Pollution Abatement Goals
POLLUTANT
GOAL
Hydrocarbons
1975 new models reduction of
90% of 1970 model emissions
Carbon Monoxide
1975 new models reduction
of 90% of 1970 model emissions
Nitrogen Oxide
1976 new models reduction of
90% of 1971 model emissions
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Once promulgated, NESHAP's are applicable to both
new and existing stationary sources. States may
submit procedures for implementing and enforcing
NESHAP's for stationary sources located within their
geographic jurisdiction. Upon review and approval
of the procedures EPA may delegate the authority
to implement and enforce the NESHAP.
3. EPA'S STATIONARY SOURCE AIR STRATEGY IS DESIGNED TO CONTROL
THE LEVELS OF EMISSIONS EMANATING FROM MAJOR POINT SOURCES.
The identification of point sources is the first step in
attaining NAAQS. A point source is defined as any facility
capable of emitting more than 100 tons per year of any
single pollutant without pollution controls. Source
parameters and emissions information are needed to develop
and evaluate control strategies to be used in setting
compliance schedules for sources in non-attainment areas.
Of 20,000 major stationary sources of air pollution in
1975, 84% are complying currently with emissions regulations
or are meeting abatement schedules.
(1) SIP's Detail the Steps to be Taken for the Abatement
and Control of Emissions for Existing Point Sources.
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As a part of SIP development, states identify major
point sources, set source emissions limitations, and
establish schedules for compliance so that total
emissions are reduced to levels which permit ambient
air quality standards to be achieved. Included in
the SIP are provisions for monitoring and gathering
data to track source compliance with state-established
timetables.
(2) Emission Control Regulations (ECR) Are Based on
Control Strategies That Are Capable of Achieving
Desired Air Quality While Minimizing Overall Costs.
Emission control regulations are legally enforceable
emission control requirements which consist of emission
standards covering significant source types. The de-
velopment of the ECR1s is based on a review of four
areas, as follows:
Existing ambient pollution levels
Source and emissions inventories
Available control technology
Projections of increased source emission
due to urban growth
In the formulation of control regulations, states
evaluate various strategies in terms of their capability
of achieving desired air quality in the least costly
or disruptive manner.
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(3) EPA Has Established New Source Performance Standards
(NSPS) to Control Emissions From New Stationary Sources.
EPA has promulgated NSPS requiring all new sources of
pollution within specified industries to install the
best available control technology as an effective means
of controlling current and future air pollution levels.
Stationary sources are classified by types and sizes
for the formulation of NSPS. To date, EPA has
established standards for twenty industrial activities,
which can be grouped in eleven categories, as follows:
Fossil Fuel-Fixed Steam Generators
Municipal Incinerators
Cement and Asphalt Plants
Sulfuric and Nitric Acid Plants
Sewage Treatment Plants
Petroleum Refineries
Phosphate Fertilizer Industry
Iron and Steel Plants
Zinc, Lead and Copper Smelters
Coal Preparation Facilities
Aluminum Reduction Plants
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States may submit procedures for implementing and en-
forcing NSPS for sources within their geographic juris-
diction. Upon review and approval of the procedures
EPA may delegate to the state the authority to imple-
ment and enforce the NSPS.
(4) Models and Monitoring Are Used to Evaluate Control
Strategies and to Revise SIP's Where Necessary.
EPA and states have utilized models as tools to assist:
in the development of programs that lead to the attain-
ment of air quality standards. Monitoring information
and diffusion models are used to ascertain the effect
that the distribution of emissions from a point source
has on the ambient air quality. Monitoring, itself, is
expensive in terms of manpower and resources; therefore,
models are used as supplements to the monitoring effort.
In addition, accurate models provide a more comprehensive
picture of ambient air quality than do monitors, which
tend to reflect air quality only in the immediate vicinity
of the individual stations.
Once a control strategy is selected, state offices employ
air quality sampling to monitor progress toward achieving
SIP goals and national standards. Monitoring also serves
as a validation tool by which model developers observe how
well the relationship between air quality and source
53 index systems inc
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emissions is simulated. In this way, modeling and
monitoring supplement each other in identifying ap-
propriate control strategies.
4. EPA'S MOBILE SOURCE AIR STRATEGY IS DESIGNED TO LIMIT MOBILE
SOURCE EMISSIONS BY REGULATING MANUFACTURERS, REGULATING
MOTOR FUEL DISTRIBUTION AND FACILITATING THE DEVELOPMENT OF
TRANSPORTATION PLANS.
Although the Clean Air Act legislated strict emissions standards,
the proliferation of automobiles has hindered the abatement
process and contributed to a national energy shortage. In
1970, mobile vehicles traveled over a trillion miles. Statistics
have revealed that the majority of these auto trips were less
than five miles long and that 85% of commuting was done by car
with usually just the driver inside. This analysis demonstrated
that the mobile source problem had three facets, as follows:
Development of effective means of reducing
pollutants emanating from motor vehicles
Development of efficient transportation
systems
Land use planning and other methods of
reducing geographical concentrations of
automobile pollutants
Consequently, solutions to transportation and land use issues
are needed also to improve air quality and energy resource
utilization.
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(1) Mobile Source Program Personnel Interact With Auto-
mobile Manufacturers and Importers to Certify Com-
pliance With Emissions Standards as Legislated in
the Clean Air Act.
Each year motor vehicle manufacturers apply to EPA
for certification of compliance with emission stan-
dards. EPA provides this certification by testing
prototype vehicles prior to their introduction to
assure that each new model is engineered to conform
to emissions regulations over its useful life. As
a part of this program, EPA is authorized to inspect
records, procedures, and production facilities.
All motor vehicles manufactured abroad for sale in
the United States also must meet EPA auto emission
standards. Foreign manufacturers have been given
the same compliance schedules as domestic producers.
EPA coordinates its certification activities with
the U.S. Customs Department for the importation of
foreign-made vehicles. Any individual who purchases
a car overseas for importation into this country
is responsible for verifying compliance with emission
standards.
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(2) EPA Is Working With States and Municipalities to
Establish Transportation Control Plans (TCP's),
Inspection Maintenance Programs and Vapor Recovery
Programs.
The automobile emissions problem is especially serious
in certain urban areas; consequently, EPA has initiated
transportation control strategies to deal with the
problems unique to these areas.
Transportation Control Plans are designed to reduce
aggregate emission of pollutants from vehicles by
decreasing total vehicle miles traveled (VMT) through
five strategies, as follows:
Limited access areas
. Mass transit improvements
Traffic flow improvements
Carpool programs
Priority bus lanes
TCP's impose a social burden on the general
public because they affect the way people move from
one place to another and thereby impact urban
lifestyles.
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In addition, EPA is providing program guidance and
technical support to states and localities in developing
emissions inspection maintenance programs. These pro-
grams are designed to insure that vehicles continue to
achieve the same level of emission control as when they
were manufactured. EPA also conducts a vapor recovery
program to reduce the emission of hydrocarbon vapors
at gasoline filling stations as fuel is transferred
from storage tanks and trucks to stations and from
gasoline pumps to vehicles.
(3) The Mobile Source Program Monitors the In-Use Per-
formance of Motor Vehicles to Determine Emission Levels
After the Vehicles Have Been Purchased and Driven by
Their Owners.
Emission performance tests of vehicles in actual use
provide data to assure that vehicles continue to fulfill
federal emission requirements. Where necessary, enforce-
ment orders are given to manufacturers stipulating a re-
call of vehicles for corrective action. Under the Clean
Air Act, car manufacturers must provide a warranty of
five years or 50,000 miles 01 the emission control system
of their cars.
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The Office of Research and Development (ORD) derives
its activity priorities from the objectives set by
EPA in fulfillment of the legislative mandate of the
Clean Air Act. Exhibit 2-4, on the following page,
summarizes the ORD activities in support of the air
program.
Air pollution generally has been recognized as an
environmental influence on the public health. Con-
sequently, ORD conducts on-going research directed
toward the understanding of the relationship between
air pollution levels and public health. Research
continues on the six pollutants for which criteria
documents have been published; however, continual
emphasis is given also to pollutants not presently
controlled. In support of this research, EPA conducts
toxicological, clinical, and epidemiological studies
to gather information on four areas of concern, as
follows:
Exposure/response of various pollutants
over time
Development of standards that provide
an adequate margin of safety
Health benefits in meeting standards
Health risks in exceeding standards
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Exhibit 2-4
U.S. Environmental Protection Agency
Summary of Research and Development
Activities in Support of Air
Program
AREA OF ACTIVITY
ASSOCIATED OBJECTIVES
Health Effects
Understand relationship between air quality and public
health
Identify pollutants to be controlled
Develop criteria documents to be used for standard
setting
Technological
Assessment
Identify control technologies and ascertain effectiveness
viability, and economic implications
Evaluate health implications of control equipment and
future technological processes
Scientific
Methodologies
Understand atmospheric processes governing transport
and dispersion of pollutants from various sources
Develop, evaluate, and validate models for predicting
and analyzing emissions from a variety of sources
Quality
Assurance
Develop standardized measurement methods, reference
methods, and manuals
Evaluate laboratory instruments and data handling
capabilities
-------
Health effects research includes exposure/response
relationships of both criteria and non-criteria
pollutants by themselves and in combination with
each other.
ORD provides emission characteristics, measurement
methods, and health-related data for new control de-
vices, fuel additives and technical processes. For
example, the adoption of catalytic converters to con-
trol pollutants from mobile sources is under review
by research scientists. Toxicological studies are
being conducted to establish the health implications
of sulfates and sulfuric acid mist that are produced
by catalyst-equipped cars. Similarly, as new source
performance standards are proposed, ORD identifies and
evaluates available technology to meet the standards
in the most cost-effective manner.
In addition, ORD develops air quality simulation models
for predicting ambient concentration levels and for
analyzing emissions from various sources. In order
to develop effective models, scientific knowledge on
the transport and dispersion of pollutants in the
atmosphere is needed. During the past three years,
ORD has conducted a major Regional Air Pollution
Study (RAPS) in St. Louis to develop, evaluate, and
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validate urban air quality models for the criteria
air pollutants.
Air pollution monitoring methods require high per-
formance reliability at very low concentration levels
because of the nature and degree cf ambient pollution
levels. Although ORD does not have responsibility
for air monitoring, it is responsible for developing
and implementing a comprehensive quality assurance
program. The quality assurance program consists of
three activities, as follows:
Develop and publish standard measurement
methods and quality control manuals
Provide technical assistance to state and
regional offices for establishing quality
control programs
Review state proposals for assuring
quality control
As necessary, performance audits of monitoring sites
are conducted to assure that accurate and defensible
data are being gathered.
(2) EPA's Primary Ambient Air Monitoring Goal Is to
Provide Data of Adequate Quality to Arrive at Decisions
Regarding the Attainment of NAAQS.
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Data produced from the ambient air monitoring net-
works form the basis for the evaluation of air quality
trends and for the evaluation of the success of a SIP.
Moreover, monitoring data provide information to eval-
uate which areas are attaining NAAQS and which will re-
quire SIP revisions in order to attain air quality
standards.
EPA is concerned especially with three aspects of mon-
itoring data, as follows:
Enhancement of the quality of data through
development of site and laboratory quality
assurance programs
Optimal collection and use of data in order
to minimize collection of unnecessary data
Review of existing data for their adequacy
in support of SIP evaluation and strategy
development
The Standing Air Monitoring Work Group (SAMWG) is an
EPA task force analyzing the continuing need for and
use of monitoring data at Headquarters, the regions,
and in state and local agencies. Preliminary findings
of SAMWG indicate that less monitoring data will be
needed in the future by EPA to assess national trends,
but that more short-term monitoring will be needed by
state and local agencies to pursue abatement and en-
forcement activities.
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(3) The Air Enforcement Program Is Designed to Identify
and Investigate Suspected Violations and Establish
Compliance Schedules to Bring Violators into Con-
formity With Published Regulations.
EPS's current air enforcement programs consist of
nine major activities/as follows:
Enforcement of State implementation Plan
Regional and state coordination in moni-
toring compliance schedules of major
stationary sources
Enforcement of transportation control
plans
New Source Performance Standards enforce-
ment
NESHAPS enforcement
Establishing priorities in non-attainment
AQCR's for resource allocation
Providing technical, legal, and case de-
velopment assistance to state and regional
programs
Participation in ESECA coal conversion program
Participation in non-significant deterioration
programs
EPA efforts are aimed at encouraging states to assume
a larger role in enforcement as a key to national
compliance.
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6. THE FUTURE ACTIVITIES OF THE AIR PROGRAM WILL BE AFFECTED
BY THE IDENTIFICATION OF NEW POLLUTANTS, THE DEVELOPMENT
OF NEW TOOLS TO MEET AIR PROGRAM OBJECTIVES AND THE
CONTINUING DELEGATION OF AUTHORITY TO REGIONAL AND STATE
OFFICES.
The current air program strategy and activities are involved
primarily in the planning for and control of the criteria
pollutants through the SIP and NSPS mechanisms. These activ-
ities will be affected over time as new pollutants are identi-
fied and as new methods are developed for controlling pollution.
In addition, shifting emphasis from Headquarters to the field
likewise will change the levels and types of activities in which
pollution control officials will be involved.
(1) ORD Is Giving Special Emphasis to the Identification of
Pollutants Which Are Not Controlled Presently and Which
Would Require the Promulgation of Additional NAAQS and
NESHAP's.
In the past, health effects research has been conducted
primarily to ascertain the diseases which may be related
to criteria pollutants. Although this activity will con-
tinue, ORD will focus also on the environmental factors
which are associated with the causes of three categories
of diseases, as follows:
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Chronic Respiratory Diseases
Cardiovascular Diseases
Cancer
Through this effort new pollutants may be identified
which will require control. Emerging problems such
as vinyl chloride, sulfates and other potential haz-
ardous substances will receive increased attention.
Similarly, since the majority of most people's time
is spent indoors, EPA will expand its effort in
assessing the health effects associated with indoor
pollutant levels.
(2) As the Air Program Evolves, New Approaches Will Be
Developed to Assist in Accomplishing the Objectives
of the Clean Air Act.
As the SIP revision process continues, the rollback
strategy basis for plans is proving to be inadequate
and not appropriate in many cases. States increasingly
are using simulation models to evaluate control
strategies. Consequently, programs such as RAPS
play a key role in developing models which can simulate
accurately the dispersion of pollutants into the at-
mosphere. Emission inventories and demographic infor-
mation are important input data to support these efforts
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As motor vehicle emissions continue to be reduced
because of manufacturer design changes and the use
of the catalytic converter, transportation control
plans will shift emphasis from decreasing total ve-
hicle miles traveled to reducing the total number of
trips. Exhibit 2-5, on the following page, illustrates
the pattern of emissions over the course of an auto-
mobile trip. The start and end of the trip represent
the periods of largest concentration of emission.
Various air program planners from the State of California
believe that a strategy designed to reduce the number
of trips, rather than the total vehicle miles, may prove
effective in reducing aggregate emissions as part of a
TCP.
Different approaches may be needed to reduce ambient
air pollution levels because of unique characteristics
of specific pollutants. For example, ozone and other
oxidants have been considered to be an urban problem
because they were produced by photochemical reactions
of local emissions of hydrocarbons and nitrogen oxides.
In recent years, however, standard violations of am-
bient oxidant levels have been observed in several rural
areas of California and other states, far from major
sources of hydrocarbons and nitrogen oxides. Accordingly,
oxidant transport has been characterized as a phenomenon
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Exhibit 2-5
U.S. Environmental Protection Agency
Graphic Representation of
Automobile Emissions Over The Course
of a Trip
EMISSIONS
00
vo
START OF TRIP
END OF TRIP
-------
which can affect population clusters distributed over
relatively large geographic areas. The atmospheric
formation of oxidants is a complex issue of which there
is limited scientific understanding. Similarly, there
is little knowledge of the atmospheric chemistry associ-
ated with sulfate formation and transport. As a result,
fundamental questions arise concerning the chemicals,
methods and siting of monitoring stations. Furthermore,
these questions pose added difficulties with regard to
the use of data to plan and formulate control strategies.
(3) EPA Is Striving to Delegate Authority and Responsibility
for Accomplishing the National Air Program Objectives
to Regional and State Offices.
The air program has evolved from a centralized group
setting standards and national policy to one of regional
and state development, implementation, and enforcement
of programs to achieve and maintain national ambient
air quality standards. While various centralized functions
will continue, regional and state offices have the re-
sponsibility for the success or failure of accomplishing
national air program objectives within their geographical
areas. To this end, EPA is training personnel and allo-
cating resources to regions in the form of increased
regional budgets.
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This effort is augmented by regions supplying grant
monies to states in support of air pollution control
programs. The Office of Air Quality Planning and
Standards (OAQPS) has established the Air Pollution
Training Institute and Air Pollution Technical Infor-
mation Center to train state and local personnel and
to distribute instruction manuals and various
technical publications in support of air programs.
*******
In summary, the air pollution control strategy rep-
resents a cooperative effort between the federal,
state and local governments in reducing the level
of ambient air pollution as specified by the Clean
Air Act. The federal government develops air quality
standards and finances research into related technical
and medical areas; the state and local governments
establish and implement plans to achieve the federal
air quality standards. Most air quality control
efforts, at present, are designed (1) to reduce
emissions from current large point sources, (2) to
control the introduction of new point sources of
pollution, (3) to modify the design of motor vehicles
in order to reduce emission of pollutants and (4) to
influence driving patterns in order to reduce the
total amount of mobile source pollutants generated.
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As the air program continues to develop, increasing
emphasis will be placed upon refining the methods of
identifying and rectifying pollution problems. Im-
provements in modeling and control technology will
provide pollution control experts with better tools
to decrease the total amount of ambient air pollution
while minimizing the associated social or economic
disruption. In addition, as the program continues to
mature, proportionately more technical and personnel
resources may be required in the field to implement
and enforce the control plans whereas proportionately
fewer resources will be retained centrally for national
program planning, development and technical assistance.
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III. AIR DATA NEEDS
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III. AIR DATA NEEDS
This chapter discusses user information requirements associated
with air program activities. The chapter is divided into
three sections, as follows:
Information Needed to Plan and Review Air Program
Strategies
Information Needed to Implement Abatement Plans
and Programs
Information Needed to Analyze Problem Areas and
to Develop New Programs
1. REGIONAL AND STATE OFFICES REQUIRE COMPREHENSIVE,
ACCURATE AND CURRENT DATA TO REVISE STATE IMPLEMENTATION
PLANS WHEREAS HEADQUARTERS NEEDS SELECTED DETAIL AND ANNUAL
SUMMARY INFORMATION FOR VARIOUS PLANNING AND REVIEW FUNCTIONS.
Different types of information are needed at various
levels of involvement in the air program to plan and
review strategies in order to achieve the goals of the
Clean Air Act. Exhibit 3-1, on the following page,
summarizes the information need characteristics associated
with the four major planning and review activities.
(1) EPA Headquarters Needs Summary Information to
Develop and Rank National Air Program Plans and
to Report to Congress on the Progress in Achieving
the Objectives of the Clean Air Act.
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Exhibit 3- 1
2.S. Environmental Protection Agency
Planning and Review Information
Needs
Rank National Air
Program Plans and
Report to Congress
SIP Development
SIP Revision
TCP Development
Annual
Annual
V Quarterly
Annual
HC, CO,
NOx
r
-------
EPA Headquarters uses summary information on
the status of the national air program in order
to report to the public on the condition of the
environment and to prepare program guidance for
regional and state offices. This information
includes air quality, stationary source emissions
and compliance status data, which are collected
primarily from state and local agencies. In
addition, EPA itself assembles mobile source
emissions, technological, fuels and research
information for use in program planning. Exhibit
3-2, on the following page, illustrates the flows
and uses of this information.
Each fiscal year EPA prepares an Annual Air Program
Planning Guidance document for regional, state and
local offices to review in preparing program plans.
The environmental priorities contained in the
guidance are to assist regions and states in
allocating resources to achieve and maintain national
standards. EPA Headquarters uses trend information
on ambient air quality together with knowledge of
the availability of appropriate control technology
to formulate and order program plans. In addition,
information on the size and characteristics of
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Exhibit 3-2
U.S. Environmental Protection Agency
Information Needed for EPA Air
Headquarters Planning and Reporting
AMBIENT
AIR QUALITY
STATIONARY
SOURCE
EMISSIONS
SOURCE
EMISSIONS
COMPLIANCE
STATUS
TECHNOLOGICAL
INFORMATION
FUELS
CONSUMPTION
DEMOGRAPHIC
INFORMATION
RESEARCH
STATUS
CEQ AND
CONGRESS
EPA AIR
HEADQUARTERS
PROGRAM GUIDANCE
TO
REGIONS & STATES
75
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population segments affected by current pollution
levels and collected by other agencies is used to
assess the scope of the national air pollution problem.
EPA also uses air quality and emissions data summaries
to determine national manpower and resource needs.
Where possible, this summary information should be
complete and no more than one year old.
The Council on Environmental Quality provides infor-
mation about the condition of air quality and trends
in air quality factors to environmental scientists,
Congress and the general public. Annual government
publications and reports provide information on six
areas, as follows:
Ambient Air Quality
Stationary Source Emissions
Mobile Source Emissions
Compliance Status
Research Status
Technological Information
Other government agencies report annual national
fuel consumption and demographic information.
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EPA requires historical data to evaluate the progress of
national control efforts. Since the 1970-71 period
is the baseline period for evaluating overall progress
toward attainment of NAAQS, EPA would like to have data
representing ambient air quality for each period since
1970-71 to prepare trend reports and analyses. Trend
information concerning emission reduction requires
comparable historic data for comparison against current
emissions levels. However, most state agencies had only
limited air monitoring and data handling resources in
1970-71. Therefore, air pollution control programs have
been limited to whatever historic data had been assembled
during that period.
(2) Regional and State Offices Have Used Ambient Moni-
toring Information and Have Acquired Stationary Source
Emissions Data to Develop State Implementation Plans.
In 1971, as part of the SIP development process,
regional and state offices began to engage in three
activities, as follows:
Analysis of Ambient Air Quality
Identification of Sources of Pollution
Development of Control Strategies
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Regional and state offices evaluated the air quality of
each AQCR using available data to determine pollution
levels with respect to national standards. Detailed
annual ambient air data were collected from existing
monitoring sites to identify violations of national
primary standards.
Regional offices utilized contractors and state
agencies to identify sources of pollution within
problem AQCR's. The objectives in building the
source inventories were first, to identify all
potential contributing sources, and second, to
collect detailed emissions and parametric data for
these sources. Because of the time constraint
associated with the SIP development and the magnitude
of data collection, accurate and complete information
concerning the sources was often unavailable.
In most cases, roll-back strategies were used to
develop control regulations. Under the roll-back
approach an analysis was made to ascertain what
percentage pollution levels should be lowered to
meet national ambient air quality standards. The
required reduction was applied to the emissions of
the identified stationary sources and source compliance
78
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schedules were developed as a result.
(3) Regional and State Offices Need Detailed Monitoring
Information and Current Emissions Data to Revise
State Implementation Plans.
The FY 1976 air program guidance asked regional
offices to determine the attainment status of all
AQCR's for each criteria pollutant and to call for
needed SIP revisions by July, 1976. Exhibit 3-3, on
the following page, summarizes the data needs for
this SIP revision process.
Accurate, complete and reasonably current ambient
air monitoring data are needed for each criteria
pollutant to identify non-attainment areas. Data
must be consistent with the measurement units and
the averaging time for the respective NAAQS. Non-
attainment may result from the lack of an adequate
SIP or from the lack of appropriate enforcement efforts
under the existing plan. For this reason, accurate,
current and complete source compliance information
is needed also by regional offices. In addition,
short-term emissions data and expanded information
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Exhibit 3-3
U.S. Environmental Protection Agency
Summary of SIP Revision Process
AMBIENT AIR QUAINT? DATA
IDENTIFY NON-ATTAINMENT
AREAS
COMPLIANCE STATUS
IDENTIFY AREAS REQUIRING
SIP REVISION
EMISSIONS INVENTORIES
EVALUATE CONTROL STRATE-
GIES AND REVISE SIP
SO
-------
on seasonal and diurnal patterns of source operations
would be desirable to evaluate and revise SIP's. However,
these short-term and diurnal data are oftentimes
prohibitively expensive to acquire.
A SIP revision will culminate in the promulgation of
new control regulations. Regional, state and local
agencies must interact and review the restrictiveness
of existing regulations before new control strategies
which yield more stringent emissions limitations are
developed.
With the availability of representative source and
emissions data and validated models, air planners are
relying less on roll-back approaches to pollution
abatement. Consequently, modeling is being used
increasingly to evaluate control strategies. General
topographic information has a direct relationship to
the effectiveness of models because of the state-of-
the-art in model development. Additionally, the
effective utilization of models requires detailed
source parameters, emissions inventories and meteoro-
logical data to set initial conditions. Also, specific
and accurate local ambient data are required to
calibrate models. Modeling provides regional and state
offices with the capability to project changes in air
quality that may result from future source emissions or
new control strategies.
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In addition, regional and state offices require
general research information as to the availa-
bility of cost-effective control technology.
Regions need information concerning the short-
term abatement capabilities of differing classes
of control equipment and their associated long-
term viabilities.
(4) Regional and State Offices Require Localized
and Summary Data to Develop Transportation
Control Plans (TCP).
TCP's are used primarily in metropolitan areas
in order to control the aggregate emissions of
hydrocarbons, nitrogen dioxide and carbon
monoxide from mobile sources. Consequently,
annual air quality information is needed for
these three pollutants to identify urban areas
where TCP's would be appropriate.
Traffic flow information, fuel availability and
mobile source emissions for various model years are
needed to analyze pollution problems and to develop
appropriate control mechanisms. However, these data are
prohibitively expensive to acquire except on a very se-
lective basis. Localized demographic and meteorological
data are needed also to support the limited modeling
that is being done as a part of TCP development. For
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example, the State of California has projected
mobile source emissions in five-year intervals
from 1975 to 1995. Transportation data (CALTRANS),
emissions factors and growth indices are used in
conjunction with transportation models to update
regional transportation plans for the urbanized
areas of California. As a result of this
analysis, California determined that it
needed to establish stringent motor vehicle
emissions standards in order to achieve its
pollution reduction objectives.
2. EPA AND STATE OFFICES NEED COMPLIANCE AND SITE-SPECIFIC
MONITORING INFORMATION IN ORDER TO IMPLEMENT ABATEMENT
PLANS AND PROGRAMS.
Detailed and localized air quality, emissions and com-
pliance data are needed by regional and state offices
to carry out plans which will achieve the objectives of
the Clean Air Act. Exhibit 3-4, on the following page,
summarizes the information needs characteristics associated
with the implementation of abatement programs.
(1) EPA and States Require Compliance Status and
Emissions Information on Stationary Sources
to Monitor the Progress in State Plan Imple-
mentation.
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Exhibit 3-4
U.S. Environmental Protection Agency
Information Needs to Implement
Abatement Plans
Site Surveillance
SIP Enforcement
Non-Significant
Deterioration Reviews
Mobile Source
missions Performance
Monitor TCP, Fuels
and Vapor Recovery
Programs
Quality Assurance
Programs
1 r
NA N/A N/A
/ / /
/ y
Current
NA N/A N/A
Annual
>/ Annual \/
/
V
/
/
v
N/A
. r
10% Regions
Annual
100% State
/
/
/ y
Current
Annual y
N/A N/A
1
Current
Ccnplete
Current
Complete
Neighboring
Sources
In-use
Surveillance
Inspection
Results
Technical
Legal
Meteorological
Topographic
Demographic
Source
Inventories
Management
Control
Plans
D
D
D
D
S
D
L
L
L
N
L
L
CO
Bnportant characteristic
Blank represents less impor-
tant characteristic
N/A = Not applicable
-------
The successful implementation of state plans requires
that regional and state offices monitor major stationary
sources for compliance with established abatement
schedules. Regional Surveillance and Analysis (S&A)
divisions are advised by program plan guidance to
inspect at least 10% of the major point sources within
their jurisdiction each year. Moreover, in fulfillment
of EPA grant requirements, state inspectors must visit
all the major sources within their geographical area
annually.
SIP monitoring requires detailed and site-specific
source and emissions information along with status informa-
tion on source compliance with abatement schedules.
S&A divisions gather and analyze the field inspection
reports and advise Enforcement personnel of suspected
violations.
(2) EPA and States Need Current Detailed Technical and
Emissions Information to Support Enforcement Actions.
Enforcement actions may result from the analysis
and investigation of five sources of information,
as follows:
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Compliance status reports
Field inspection reports
Section 114 inquiries
Source performance reports associated
with NSPS or NESHAPS
Citizen complaints
Regional and state enforcement offices require
detailed, accurate and current emissions information
to conduct investigations and support case development.
Contractors are used often to augment EPA efforts to
collect technical data from state and plant files and
to conduct comprehensive source performance tests.
Regional enforcement personnel receive technical and
legal assistance from Headquarters offices, as needed.
Engineering expertise concerning abatement methods,
equipment and industrial processes is needed to
provide technical support in enforcement actions.
Legal information is obtained through oral and
written communications between state, regional and
Headquarters attorneys.
The Division of Stationary Source Enforcement (DSSE)
at Headquarters needs various air quality and emissions
information to support three activities, as follows:
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Development of national enforcement
strategies
Assessment of quarterly enforcement progress
for reporting to the Administrator
Preparation of annual reports to Congress
on source compliance status
To support these efforts DSSE has noted the need for data
which are no more than three-to-six months old. Furthermore,
base year data are needed to assess progress in attaining
goals.
(3) Regional Offices Require Ambient Monitoring, Technical
Source and Emission Information to Conduct New Source
Reviews (NSR).
Regional offices conduct NSR's to determine the
incremental effect on air quality of a proposed sta-
tionary source. Exhibit 3-5, on the following page,
summarizes the information needed for a review.
Localized and complete ambient monitoring and emission
data are needed for the January, 1975 baseline and for
the current period to perform analyses associated with
non-significant deterioration reviews. Regional
offices use models to project pollution levels and
to analyze the associated increments in air quality.
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Exhibit 3-5
U.S. Environmental Protection Agency
Information Needs for New Source Review
AIR QUALITY
DATA
NEIGHBORING
SOURCE
EMISSIONS
DATA
TOPOGRAPHIC
DATA
NEIGHBORING
SOURCE
COMPLIANCE
SCHEDULES &
STATUS
NON-SIGNIFICANT
DETERIORATION
REVIEW
METEOROLOGICAL
DATA
DEMOGRAPHIC
DATA
88
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Consequently, current, complete and accurate demo-
graphic and meteorological data concerning the area
surrounding the proposed source are needed as input
to various models. Additionally, regional offices
need compliance status and emissions history informa-
tion about neighboring sources to augment and interpret
model results.
(4) Prototype Test Results and In-use Monitoring Informa-
tion Are Needed to Assure Mobile Source Emissions
Performance.
Each year the mobile source program reviews applica-
tions from manufacturers to certify that new vehicles
comply with emission standards prior to their intro-
duction and sale. Detailed and accurate emission
data are collected on 600 prototype vehicles every
5,000 miles for 50,000 miles. The test procedures
generate data which are representative of the actual
use of the vehicles under various normal driving
conditions. EPA also needs actual use emissions data
on vehicles which have been purchased and driven by
owners. The results of this testing are used to
support four functions as follows:
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Analysis of vehicle emissions for compliance
with EPA requirements
Calculation of emissions rates for TCP and
SIP development
Analysis of control equipment for possible
enforcement orders to manufacturers for
recall
Investigation of possible emission control
tampering
As a by-product of the national emission testing, EPA
collects and publishes fuel economy data in cooperation
with the Federal Energy Administration.
(5) Compliance Status Information Is Required to Monitor
the Effective Implementation of Transportation Control
Plans, Vapor Recovery and Fuels Programs.
Regional and state offices need to review annual
ambient air data to ascertain the effectiveness of
TCP's in reducing mobile source-related emissions of
hydrocarbons, nitrogen dioxide and carbon monoxide
in selected urban areas.
Complete source inventories of service stations, fuel
distributors and bulk terminals are needed to schedule
inspections in order to review compliance with vapor
recovery regulations. When a plan is not on schedule,
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enforcement action can be taken to re-establish
conformity with schedules.
Regional offices visit service stations to inspect
for compliance with regulations concerning signs,
equipment and lead content. Data are gathered from
quick screening tests to find gross violations of the
unleaded standard and from an atomic absorption measure-
ment scheme for more precise quality control. Either
test may be used as a basis for an enforcement action.
Data from both tests are reported to Headquarters and
stored in the Fuels Data Base.
(6) Management Control Plans and Analyses of Detailed
Ambient Data Are Required to Support Regional and
State Quality Assurance Programs for Monitoring Sites.
Air quality data produced by federal, state and local
monitoring sites must be accurate and legally defensible,
Accordingly, states develop quality assurance programs
in conjunction with EPA personnel in order to correct
seven deficiencies associated with ambient monitoring,
as follows:
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Improper location of monitoring sites
Improper placement of instruments
Inadequate calibration of instruments
Improper measurement methods and materials
Inadequately trained site operators
Cumbersome data handling
Inadequate laboratory support facilities
Regional offices use statistical validation of air
quality data and audit results of equipment calibra-
tion, data handling and operational procedures to
evaluate monitoring site performance.
To support these effortsfthe Monitoring and Technical
Support Program within ORD, together with OAQPS,develop
agency-wide quality assurance guidelines and technical
information for use by regional and state offices.
This guidance includes four areas, as follows:
Standard measurement methods
Standard analytical reference materials
Monitoring site selection and validation
criteria
Training and technical assistance
EPA anticipates that efforts to upgrade state and
local monitoring programs will result in improved
data quality.
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3. EPA NEEDS DETAILED MONITORING, SOURCE AND METEOROLOGICAL
DATA AND CLINICAL TEST RESULTS TO ANALYZE PROBLEM AREAS
AND TO DEVELOP NEW PROGRAMS.
Various types of engineering and scientific information
are needed by Headquarters planners and research personnel
to deal with specific pollution problems and to develop
new control programs. Exhibit 3-6, on the following page,
summarizes the information needs associated with these
areas.
(1) EPA Needs Detailed Non-Criteria Ambient Air and
Clinical Test Data to Identify New Pollutants to
Be Controlled.
The Health and Ecological Effects program within ORD
collects data and provides information for the estab-
lishment and subsequent reevaluation of air quality
criteria. In support of this activity, detailed and
accurate short-term ambient air data are needed to
determine exposure-response relationships of various
pollutants. Specific health effects data are
collected from three sources, as follows:
Clinical studies
Toxicological studies
Epidemiological studies
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Exhibit 3-6
U.S. Environmental Protection Agency
Information Needs to Analyze Problem
Areas and to Develop New Programs
Identify New
Pollutants
Revise NAAQS
Develop
Simulation Models
New Source
Performance
Standards
ESECA
y
'
/
Annual
/
• 1
y •
Annual
Annual
/
Y
.
y
N/A
N/A
N/A
N/A
Health Studies
NASN Analysis,
Demographic
Health Studies
Topographic
Meteorological
Control
Technology
Source
Parameters,
Fuels
Availability
D
D
D
S
D
L
L
L
N
N
Y = Important characteristic
N/A = Not applicable
blank represents less important characteristic
-------
Most of the air quality monitoring in recent years has
been for the determination of ambient concentrations of
total particulate matter, sulfur dioxide, carbon monoxide
and oxidants. The section of these four pollutants has
been based primarily upon the state of scientific knowledge
about air pollution effects.
Recently, there has been an increasing need for air quality
information on non-criteria pollutants such as sulfates.
Exhibit 3-7, on the following page, summarizes some important
non-criteria pollutants and the associated areas of concern.
Data on ambient concentrations of non-criteria pollution
are collected primarily through the National Air Surveillance
Network (NASN) and analyzed by the Environmental Monitoring
and Support Laboratory within ORD. This federal network
consists of 250 monitoring sites located around the country,
primarily in urban areas.
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Exhibit 3-7
U.S. Environmental Protection Agency
Summary of Non-Criteria Pollutant
Sources and Areas of Concern
POLLUTANTS
Sulfates
Nitrates
Asbestos
Lead
Mercury
Beryllium
MAJOR SOURCES
Atmosphere reactions sulfur oxide pre-
cursors (in moist environment appears
as sulfuric acid mist or rain)
Atmospheric reactions of nitrogen
oxide precursors (in moist environment
appears as nitric acid mist or rain)
Asbestos mining and processing
Automotive emission; lead smelting
and processing
Mining and refining of mercury
Mining, smelting and machining of
beryllium
GENERAL AREA OF CONCERN
Aggravation of respiratory
diseases; corrosion of metals
and other substances
Aggravation of respiratory and
cardiovascular illnesses
Fibrosis, calcification and
cancer of the lungs
Impairment of nervous system,
bones and kidneys
Impairment of nervous system
Suspected cause of bone and
lung cancer
to
a\
-------
Non-criteria pollution data for a larger number of
areas are needed to allow more complete analyses of
ambient and population dosage levels.
Ambient monitoring data for pollution assessment and
research must be collected under rigorous quality
control conditions to assure validity and accuracy.
Consequently, prior to each study, researchers need
information concerning at least five areas, as follows:
Purpose for which data are collected
and used
Number and placement of monitoring sites
for spatial resolution
Frequency of sampling
Quality control associated with sampling
and analysis
Specific data constraints
Data needs are seldom identical from study to study;
therefore, raw ambient data collected through state
programs are not sufficient for the specific research
needs.
(2) EPA Needs Research Information to Reevaluate Air
Quality Criteria and Revise NAAQS.
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On a continuing basis EPA conducts research on both
the short- and long-term exposure effects on air
pollution on animals, materials and vegetation. This
effort provides the basis by which EPA reevaluates air
quality criteria and recommends revised NAAQS. EPA's
research is augmented by studies conducted by universi-
ties, other government agencies and other countries.
New research is being conducted also in various areas
to reassess the adequacy of current ambient air
standards. These research activities include analyses
of the effects of varying sizes of particulate material,
of the synergistic effects of combinations of chemicals
and of the feasibility of limiting or controlling the
presence of hazardous combinations of chemicals.
Researchers require a wide variety of specialized sta-
tistical and data-handling tools to assist them in these
efforts. In most cases the data and tools required to
support these analyses are very unique and cannot be
provided economically by national data bases of trend
and monitoring information.
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(3) EPA Requires Detailed Ambient, Emissions, Meteorological
and Topographic Information to Develop, Evaluate and
Validate Air Quality Simulation Models.
The Ecological Processes and Effects program of ORD
develops analytical techniques that relate source
emissions to ambient air pollution levels. The
monitoring sites associated with the Regional Air
Pollution Study (RAPS) in St. Louis collect detailed
and accurate air quality information that can be used
to calibrate and validate simulation models for
criteria pollutants.
Accurate and complete emissions inventories, meteorological
data and other scientific data are needed by ORD model
developers and contractors. Emission and process data are
required for a variety of industrial processes to develop
and update emissions factors. Additionally, ambient data
around large point sources, monitoring site informa-
tion that allows for spatial resolution and short-
term emissions data are needed to calibrate models
and to validate results. Appropriate meteorological
data are difficult to obtain. Information concerning
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wind speed and direction above and around stacks is
important for diffusion modeling; however, weather
information collected at high altitudes and at ground
level is usually the only data available. Furthermore,
topographic area characteristics are needed to provide
guidelines for physical model utilization. St. Louis
represents a relatively flat terrain; consequently,
models developed for that area would not be appropriate
for use in evaluating strategies in the more mountainous
western states, for example.
(4) The Office of Air Quality Planning and Standards
(OAQPS) Needs Summary Stationary Source Emissions
Data to Establish New Source Performance Standards.
EPA has initiated an assessment program to determine
which industries should be controlled by new source
performance standards. This effort is complicated
because of the large number of sources that can be
addressed. Accordingly, EPA ranks industrial source
categories by analyzing five types of information,
as follows:
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. National annual emissions by industrial
class for specific pollutants
Relative toxicity of the pollutants
Population in proximity to sources
Control technology availability, effec-
tiveness and costs
Physical configuration and industrial
processes associated with sources
OAQPS personnel gather this data with the assistance
of the Industrial Processes Program of ORD to
establish emissions standards which can achieve
desired levels of control economically.
For example, in January, 1976, EPA promulgated a
fluoride standard for new sources associated with
the primary aluminum industry. As part of its
analysis EPA considered the more stringent standards
that had been established previously by the State of
Oregon. There were several reasons why EPA elected
not to adopt standards equivalent to those of Oregon.
In particular, EPA believed that the Oregon standards
would require the installation of relatively ineffi-
cient, costly secondary scrubbing systems at virtually
all new primary aluminum plants. This action would
have had a substantial adverse economic impact on the
aluminum industry. By contrast, EPA's standard
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requires use of secondary control systems only for a
specific classification of aluminum plants. Therefore,
EPA concluded that cost considerations precluded
adopting the Oregon standards as NSPS for the primary
aluminum industry.
(5) EPA Requires Stationary Source Inventories, Fuels
Availability, and Ambient Monitoring Information
to Evaluate Conversion Plans Associated With the
Energy Supply and Environmental Coordination Act
(ESECA).
Under ESECA the Federal Energy Administration (FEA)
may issue orders prohibiting power plants and other
facilities from burning scarce petroleum products or
natural gas. Exhibit 3-8, on the following page,
summarizes the information required by EPA to analyze
and plan its actions associated with ESECA.
EPA and FEA have used source inventories to identify power
plants for potential conversion orders. Detailed and
complete air quality, emissions and meteorological
data are needed to model areas to determine the
incremental effect on pollution levels that would
result from conversion of these fuel-burning sources
to coal. In addition, information relating to the
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Exhibit 3-8
U.S. Environmental Protection Agency
Information Needs for ESECA Analysis
Source
Inventories
Identify
Potential
Sources
Air Quality, Emissions
Meteorological
Control Technology
Determine Incremental
Effect on Pollution
Levels
n
o
Fuel and Control
Technology
Availability
Establish Ordered
Conversion Schedules
-------
availability and associated transportation costs of
low-sulfur coal are needed to assess the feasibility
of conversion. If a conversion order is deemed
feasible, then EPA and FEA use the model results,
associated control technology information and demo-
graphic data to determine whether a suspension of
SIP requirements is required and justifiable in
order to convert the designated facility to coal.
In summary, air program personnel require a variety
of ambient, emissions, demographic, engineering and
research information. National summary ambient and
emissions data are needed by EPA program planners
and policy makers. Regional, state and local
personnel, by contrast, require significantly more
detailed local information to support SIP revision,
AQMA evaluations and modeling. Regions, in particular,
require detailed local source data for NSD, NSPS, NSR,
NESHAPS and enforcement activities. The increasing
use of models for SIP revision, new source review
and transportation control strategy development
requires complete localized source inventories and
comprehensive meteorological, topographical and
demographic information.
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The availability of required data is dependent upon
two factors, as follows:
The economic and scientific feasibility of
acquiring the information
The technical data processing considerations
associated with storing and reporting acquired
data
In most cases the data processing costs for storing and
reporting data are small compared to the costs for
measuring accurately the ambient, emissions, meterological
and other desired data. Program managers have made the
cost determinations feasible to capture. The next
chapter discusses the data processing systems which have
been employed to edit, store and report on these captured
data.
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IV. CURRENT AIR ADP SYSTEMS
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IV. CURRENT AIR ADP SYSTEMS
This chapter describes the ADP systems that support the
air program. These systems fall into six areas, as follows:
. Storage and Retrieval of Aeromatic Data (SAROAD)
National Emissions Data System (NEDS)
Compliance Data System (CDS)
Comprehensive Data Handling System (CDHS)
. Other Aeros Systems
Research Systems
Each of the systems are discussed with regard to six para-
meters, as follows:
History, purpose and uses
Data flows
Reporting capabilities
Technical efficiencies
System management
System costs
More detailed technical data on each system appear in
Appendix A.
106
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1. THE STORAGE AND RETRIEVAL OF AEROMATIC DATA (SAROAD)
SYSTEM STORES AND REPORTS AIR QUALITY AND SAMPLING SITE
DATA COLLECTED FROM MONITORING STATIONS AROUND THE COUNTRY.
SAROAD operates on the UNIVAC 1110 computer at the National
Computer Center (NCC) at Research Triangle Park (RTP),
North Carolina. It is maintained by the National Air Data
Branch (NADB) within the Office of Air Quality Planning and
Standards (OAQPS). SAROAD is designed to store and report
air quality-related data collected from air monitoring sites
around the country. Its data base consists of monitoring
site descriptive data, air quality sampling values, and sum-
mary statistics such as means, maximum values, and running
averages.
(1) SAROAD Is Used to Monitor, Analyze, and Plan Programs
for the Abatement of Air Pollution Levels.
SAROAD was developed initially in 1966 to store air
quality data collected from 250 federally maintained
monitoring sites associated with the National Air
Surveillance Network (NASN). In 1972, NADB was created
to maintain data supplied by states as part of their
state implementation plans. SAROAD was selected
by NADB to store these air quality data submitted by
the states. As a result, the number of active sites
tracked by SAROAD has increased to approximately 4,000.
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Since 1966, SAROAD has undergone two major conversions
to accommodate hardware changes. The latest conversion
occurred in 1974-1975 when SAROAD was shifted to the
UNIVAC. Problems associated with these equipment changes
and hardware malfunctions have impaired greatly NADB's
ability to provide SAROAD users with the level and quality
of ADP service which NADB desires to provide. Currently,
SAROAD is undergoing major modifications by contractors to
increase throughput, to improve data storage efficiencies,
and thereby to reduce the exposure of the current system
to UNIVAC hardware malfunctions.
EPA uses the data stored in SAROAD for four major
purposes, as follows:
Perform trend analysis
Determine compliance with ambient air standards
Evaluate abatement strategies
Support air quality maintenance planning
Users of SAROAD data have indicated that the system report
formats and flexibility are generally sufficient to meet
program needs. Major criticisms have been raised, however,
regarding data quality, completeness and currency. These
deficiencies are due primarily to the scientific complexity
of the air monitoring strategy and not to the SAROAD data
system itself. Regional users have noted, however, that
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the unstable UNIVAC hardware environment and the prolonged
data edit and correction procedures associated with SAROAD-
submitted data has resulted in regional and state reluctance
to insure that submitted data is examined sufficiently
and corrected promptly.
State usage of SAROAD is limited primarily to verifying
the accuracy of data which have been submitted to SAROAD.
States may request reports for analysis purposes, but
usually they do not rely on the SAROAD data to perform
analyses. Instead, states rely on data contained in
their own local automated or manual systems.
Other government agencies and private institutions also use
SAROAD information. Private industry can request informa-
tion under the Freedom of Information Act. These requests
are placed through the regions or through OAQPS.
(2) SAROAD Data Originate Primarily From the States and
Are Submitted Through the Regional Offices.
Most SAROAD data originate with the states, who are
required to submit quarterly air quality data to EPA
as part of their state implementation plans (SIPS).
Regional offices have been designated by EPA to act as
intermediaries for data transferred between the states
and the SAROAD system. The regions receive state data,
109 index systems inc
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initiate data input and editing, and review data
anomalies and errors with the states. Regional and
state personnel have indicated that they are often
late in submitting and correcting SAROAD data because
they have insufficient personnel resources to provide
all data and to correct erroneous data in a timely
fashion.
States do not have access to SAROAD directly. Instead,
the states must rely on regional contacts for informa-
tion regarding SAROAD contents. Exhibit 4-1, on the
following page, depicts the SAROAD data flow from states
through the regional offices into SAROAD.
Currently, SAROAD data must pass through six steps,
as follows:
State personnel code monitoring site
data
State personnel submit data to EPA
regional office
Regional personnel run edit programs on
state-submitted data
Regional personnel correct errors or
return to states for resolution
NADB consolidate regional data and update
SAROAD
NADB generate reports for EPA and others
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Exhibit 4-1
U.S. Environmental Protection Agency
SAROAD Data Flows
Monitor-
ing
Sites
States
Code
Data
Data
Submitted
to
Regions
Regions
Edit
Data
NADB
Consolidates
Regional Data
and Updates
SAROAD
Reports
for EPA,
States,
Other
Error List-
ings return
to regions
and states
for
correct-
ion
-------
The states are required to submit data on sites,
pollutants, and sampling values. They may submit
these data on coding forms, cards, or magnetic tape,
depending upon each state's data processing capabili-
ties. Regions, in turn, input these data into a
series of SAROAD edit routines which check for proper
formats, valid codes, and reasonable data values.
Edited data from the regions are updated periodically
into the SAROAD data base. These updates are initiated
only by NADB. Updates are scheduled based upon the
number of data values received by NADB and upon soft-
ware and hardware problems with SAROAD and the UNIVAC.
Regions usually enter data and retrieve reports via
RJE terminal. In cases where regions do not have
tape drives or where large quantities of data must
be transmitted, the regions mail data to the National
Computer Center.
(3) SAROAD Produces a Wide Range of Statistical and Raw
Data Reports.
SAROAD can produce about 20 standard reports and also
can support user-generated report programs. These
user reports can be produced by employing a wide
variety of selection parameters, such as geography,
pollutant and year. EPA users can access reports
112 index systems inc
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directly via RJE or through on-line low-speed termi-
nals. States, private industry and other federal
agencies can request data through either the regional
offices or OAQPS.
There are three major types of reports produced by
SAROAD, as follows:
Raw data reports
Summary reports
. Management reports
Raw data reports can show four different types of
data, as follows:
Sampling values
Site descriptions and sampling methodologies
Means, maximum values, standard deviations
and other arithmetic values for a specified
time period
Values which exceed standards
Summary reports do not show the actual interval values
but summarize these values by quarter or year. Other
descriptive information on sites and sampling methods
is similar to that on the raw data reports. Summary
reports include such values as minima, maxima, percen-
tiles and standard deviations.
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Management reports record the activity status of
sampling stations. These reports show four types
of data, as follows:
Measurements required by EPA
Measurements proposed in SIPS
Measurements actually reported
Minimum and maximum values for each
quarter by site
These reports can be accessed by batch terminal access
to the UNIVAC. Interactive reports can be retrieved
for certain select summary reports.
(4) Headquarters and Regional Users Are Satisfied with
SAROAD Reporting Capabilities.
Overall, users at OAQPS make extensive use of SAROAD
reporting features. Regional users have made more limited
use of SAROAD reports in the past because of problems with
the UNIVAC equipment and questions regarding the quality
and currency of SAROAD data. Regions have indicated, how-
ever, that SAROAD report formats meet their needs and that
they will increase their report request rate as the UNIVAC
hardware stabilizes. Some regions have begun to use SAROAD
reports to perform more comprehensive edit checks on state-
submitted data from CDHS. These regions have indicated that
the superior reporting capabilities of SAROAD enable them to
flag anomalous values which CDHS does not catch.
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(5) SAROAD Requires Substantial Computing Resources to
Perform Updates and Generate Reports.
SAROAD is a tape-oriented system operating on the
UNIVAC 1110 at the National Computer Center. All raw
data values are maintained on 26 tapes. These tapes
contain about sixty million values and are expanding
at the rate of twenty million values annually. For
each day's worth of data there is a key containing
ten parameters such as state, area, site, agency and
project. These keys are used by report programs and
system update routines to access specific data, as
required.
In addition to raw data tapes, SAROAD also contains
quarterly and yearly summary and frequency data stored
on sequential disk files. These files are accessed
by most summary report programs. Random access quar-
terly and yearly summary and frequency files are main-
tained also to facilitate direct access by system users,
These files are accessed by the AEROS Timesharing
System (ATS) to produce on-line summary reports.
A SAROAD update involves three steps, as follows:
Updating the raw data tapes from edited input
transactions
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Creating the sequential quarterly and yearly
frequency and summary files
Creating the direct access quarterly and yearly
summary and frequency files
The profile of resource hours required to perform
an update is shown in TABLE 1. These time estimates
assume an update volume of approximately 2,500,000
data values.
TABLE 1
Step SUP Time
Raw data files updated 7 hours
Summary 11.5 hours
Frequency files 12.5 hours
Total 31 hours
Thus SAROAD consumes approximately 31 SUP hours of
UNIVAC resources to complete an average update.
Report retrievals from the sequential tape files or
sequential disk files are time consuming, since
many records must be searched before a desired record
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is located. Total SAROAD update and report retrieval
time accounts for about 27% of the annual UNIVAC resource
utilization.
(5) SAROAD Currently Is Undergoing Technical Modifications
to Improve Data Storage and Throughput Capabilities.
Modifications to SAROAD are underway currently to
reduce data storage requirements and to improve pro-
cessing efficiencies. Some modifications have been
completed and others are scheduled to be finished by
the beginning of fiscal year 1977.
Preliminary estimates show that these changes
will reduce costs for updates and report retrievals.
Seven major changes are being implemented to the
system, as follows:
Store less than 24-hour data on disk rather
than tape and eliminate a large number of
tape files
Place summary and frequency files onto a
random access file and eliminate current
sequential files
Create summary and frequency files directly
from the raw data files rather than from
intermediary tape files
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Produce running averages during system up-
dates and store these averages within the
raw data file
Compress data from full-word to half-word,
thereby reducing the data base size by 50%
Reduce daily keys with one key for a year's
worth of data, thereby saving disk space
Produce summary and management reports from
direct access random files, thereby reducing
report retrieval times and eliminating tape
contention problems
These changes are expected to reduce SAROAD update
times from 31 SUP hours to approximately 8 SUP hours
and report retrievals by a smaller percentage.
(7) The National Air Data Branch Is Responsible for
Maintaining SAROAD.
The National Air Data Branch (NADB) in Durham,
North Carolina, is responsible for maintaining
SAROAD and the other AEROS systems. NADB is com-
posed of three sections, as follows:
Systems Development Section (SDS)
Data Processing Section (DPS)
Requests and Information Section (RIS)
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SDS has primary responsibility for system develop-
ment work, and system and user documentation.
Most contractor development activities related to
SAROAD and other AEROS systems are managed by
this section.
DPS is responsible for collecting and processing
all data submitted to EPA under state reporting
requirements and for formulating regional procedures
for data entry and retrievals. Under certain cir-
cumstances DPS will edit data for regional offices.
In addition, DPS initiates all SAROAD updates.
RIS coordinates with SAROAD users through three
activities, as follows:
Receives, coordinates and tracks the status
of all requests received by NADB, including
those by regions and those under the
Freedom of Information Act
Communicates with SAROAD user contacts within
each region
Distributes AEROS newsletters and coordinates
user training sessions
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(8) SAROAD ADP Costs Are $903,000 for Fiscal Year 1976.
SAROAD is the most expensive computer system running on
the UNIVAC. Fiscal 1976 costs, including regional and
OAQPS charges, are estimated at $903,000. Exhibit 4-2,
on the following page, presents a breakdown of these
ADP costs.
Approximately 23% of these costs are attributable to
modifications to the SAROAD system associated with
changing the system design to run more efficiently
within the UNIVAC environment. These costs are expected
to decrease substantially in 1977. Maintenance costs of
$314,000 include OAQPS editing and report generation.
Report costs of $390,000 include both regional and
OAQPS reporting. Contractor costs for 1976 are approxi-
mately $220,000. EPA personnel costs are difficult to
estimate because the responsibilities of personnel in
each of the three NADB sections include other AEROS
systems also. However, the EPA manpower in support of
all AEROS systems is approximately 20-25.
2. THE NATIONAL EMISSIONS DATA SYSTEM (NEDS) STORES AND
RETRIEVES POINT AND AREA SOURCE EMISSIONS DATA.
The National Emissions Data System is maintained by the
National Air Data Branch and is operated on the UNIVAC
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Exhibit 4-2
U.S. Environmental Protection Agency
SAROAD ADP Costs
Development
Maintenance
Reports
TOTAL
1975
$ 11,000
263,700
331,542
$ 606,242
1976
$ 199,000*
314,000
390,000
$ 903,000
* Most of these development costs are for the
redesign of SAROAD to run more efficiently
on the UNIVAC.
121
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1110 at NCC. NEDS contains emissions and descriptive
information on point and area sources throughout the
United States. NEDS was designed and developed initially
by EPA personnel to provide a basic source inventory for
program planners. It currently supports trend analysis
and modelling as well. Point source data were collected
initially by EPA and by outside contractors. Since 1973,
states have been responsible for submitting point source
data to EPA semi-annually on selected sites as part of the
state implementation plans. EPA continued to maintain the
NEDS area source and emission factor information.
(1) NEDS Is Used to Support Modeling and Control Stra-
tegy Evaluation.
NEDS stores descriptive data, emission factors and
emission estimates on 160,000 point sources and 3,200
area sources. These data are used mostly by OAQPS
and regional offices.
OAQPS uses NEDS primarily for generating national
emissions summaries and for refining emission
factors. OAQPS employs several customized analysis
programs to process NEDS data in support of these
functions. Regional offices use NEDS for three
additional purposes, as follows:
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Evaluating state air pollution control
strategies
Inputting, editing and reviewing state data
Modeling
States do not use NEDS directly but are responsible
for verifying their input data. Instead, states
maintain local automated or manual systems for tracking
local emissions data. Some NEDS data are used by
other government agencies and by private institutions.
Overall, NEDS has been used primarily by OAQPS.
Regions have tended to do less modeling than they would
like and have used state- or source-provided data when
doing modeling. Regions indicated a reluctance to use
NEDS because of the incomplete and non-current data
contained in the system. NADB noted that most of this
incompleteness was attributable, however, to state
offices which have failed to submit their data and to
regional offices which have failed to enforce these
reporting requirements.
(2) NEDS Data Originate Primarily With the States and
Are Submitted Through the Regional Offices.
Most NEDS data come from state and local agencies.
States are required to maintain accurate data on
all point sources which emit more than 100 tons
per year of criteria pollutants.
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States collect data on point sources through site
visits, audits and reviews of industry-submitted
documentation. Depending upon the data processing
capabilities of the submitting states, these data are
sent by states to regions on either coding forms,
cards or tape.
After the regions receive the state data, they mail or
transmit the data to NCC. NADB then edits the data
and mails edit listings back to the regions. These
listings are returned by the regions to the states for
verification. The flow of data from states to regions
to NADB and back to the regions for editing may take
as long as two months. States and regions have indi-<
cated that these delays in NEDS data flows hamper their
ability to assure that accurate and complete data is
submitted. Because of these delays, NADB has under-
taken the development of a NEDS edit for use directly
by regional offices. Exhibit 4-3, on the following
page, depicts the data flow for NEDS. Data edits and
updates occur concurrently for NEDS. Updates are
scheduled bi-weekly and are initiated only by NADB
The update process consists of an update to a master
tape file and the re-creation of a direct access user
file.
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Exhibit 4-3
U.S. Environmental Protection Agency
NEDS Data Flows
States Collect
and Code
Emissions
Data
Regional
Offices
Receive
Data
Data Are
Mailed To
NCC for
Processing,
NADB
Initiates
Edits and
Updates
Error List-
ings Mailed
to Regions
Reports to
EPA, States
and Others
125
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(3) The NEDS Data Base Supports Point and Area Source
Data Retrievals and Various Modeling and Statistical
Analysis Applications.
NEDS produces approximately twenty batch and on-line
reports for different selection criteria. Reports
can be printed locally or centrally at NCC and
mailed to the users. Specialized reports also
can be written by system users.
NEDS produces three types of reports, as follows:
Raw data reports
Summary reports
Management reports
These reports cover both area source and point
source files. Raw data reports for point sources
can include five types of information, as follows:
Plant identification and location
Plant operating characteristics
Stack and control equipment data
Emission estimates
Fuel or raw material processing rates
Area source raw data reports can contain three
types of information, as follows:
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Area identification
Emissions and activity levels of the area
source processes
Total emissions of the five criteria pollutants
Summary reports may be generated for geographic areas
or by SCC codes for emission and fuel usage data.
System management reports describe the data base con-
tents, including missing values and recent updated
sources.
(4) NEDS Is Currently Undergoing Modifications to Improve
Updating and Data Storage Efficiencies.
NEDS operates on the UNIVAC 1110 at the National Computer
Center. Its primary file is an indexed sequential user
file occupying 1-1/2 disk packs. This file contains
point and area source descriptive data and emissions
estimates for each source. This file is updated from a
tape containing the descriptive data and from various
smaller files containing geographic parameters and SCC
emission factors. NEDS calculates emissions based on
three factors, as follows:
Emission methods and estimates stored within
the descriptive file
Operating characteristics of the source
Relevant SCC emission factors
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All emissions are recalculated during each update,
regardless of whether the values have changed. The
current NEDS update procedure takes about two SUP hours.
Modifications are underway by contractors to alter the
NEDS updating procedure so that only records that
change are updated in the user file. This change is
expected to reduce NEDS updating costs by 50%.
(5) The National Air Data Branch Is Responsible
for Maintaining NEDS.
Procedures for operating and maintaining the NEDS are
similar to those for SAROAD. NADB is responsible for
updating the system and for managing new system devel-
opment activities. The three sections within NADB are
responsible for system development, operations, user
requests and engineering and scientific support. Doc-
umentation for NEDS is maintained by a central document-
ation group responsible for all AEROS systems. NEDS
user information appears in the monthly AEROS newsletter.
(6) NEDS Computer Costs for 1976 are $150,000.
The NEDS system is expected to cost $150,000 in fiscal
year 1976. Exhibit 4-4, on the following page, shows
the associated costs for OAQPS and regional offices.
The regional costs of $11,000 for 1976 reflect the
limited regional reporting activity during most of the
fiscal year. Overall costs for 1977 are not expected
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Exhibit 4-4
U.S. Environmental Protection Agency
NEDS ADP Costs
Development
Maintenance
Reporting
TOTAL
1975
$ 4,687
49,573
205,871
$ 260,131
1976
$ 32,000
14,000
104,000
$ 150,000
129
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to increase. However, there will be a shift of
some costs from OAQPS to regions as a result of
the decentralization of the NEDS edits and as a
result of increased regional reporting.
3. THE COMPLIANCE DATA SYSTEM (CDS) RECORDS AND REPORTS
STATIONARY AIR COMPLIANCE AND ENFORCEMENT DATA.
The Compliance Data System (CDS) operates on the IBM/370
at the Optimum Systems, Inc. (OSI) facility in Maryland.
The system was designed and developed in 1972-1973 by
the Division of Stationary Source Enforcement (DSSE)
within the Office of Enforcement. CDS provides automated
support to regional and Headquarters Air Enforcement
personnel. It records and retrieves information regarding
source increments of progress and enforcement actions
relating to SIPS, NSPS, and NESHAPS schedules. All data
input, file update, and data retrievals use batch processing.
(1) CDS Supports Regional Compliance Monitoring and DSSE
National Trends Analysis.
The primary users of CDS are regional office
compliance clerks and compliance engineers. Program
managers, and section, branch, and division chiefs
also use the printouts and summary reports. In addition,
DSSE personnel use system printouts prepared on a
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national basis for tracking enforcement progress for
major industrial categories and the nation as a whole.
CDS was developed in response to the long-range sta-
tionary source air pollution program plan which pre-
scribed a means of managing the vast amounts of facility-
related compliance information to be generated by the
air program. Headquarters planners defined the
essential requirements to be (i) to forecast when
increments of progress of compliance schedules were
to be completed by any source, and (ii) to track other
enforcement actions and compliance conditions. The
system was not considered to be a replacement for the
hardcopy files which are maintained in the regional
offices but rather to be a tool for managing and sum-
marizing the data contained in those files.
(2) Compliance Data Are Obtained From States and Are
Entered Into CDS by Regional Offices.
Regional offices are responsible for gathering
compliance information from state offices.
Information is obtained from state and local air
pollution personnel via standard reporting mechanisms,
routine daily conversations, and region/state
agreements on data exchange. In addition, regional
engineers, attorneys, and compliance clerks gather
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and provide information to the regional CDS clerks
for encoding. Generally, information is coded onto
regionally-customized forms prior to keypunching.
The EPA regional offices are responsible for the col-
lection, preparation and submission of data for input.
The regions review, edit and update reports and correct
any data errors or omissions. In addition, regions
formulate, code and execute retrievals at the regional
data centers for use by local personnel.
Presently, data are submitted in card image form for
editing. Transactions passing the edit are collected
on a storage file to be held and subsequently processed
during the next update.
Once entered and verified, data remain relatively un-
changed with the exception of the action-related records,
compliance condition items, and any comments records.
All regions are expected to keep these items current
within three months.
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(3) CDS Produces Reports for Tracking Stationary
Compliance Status and for Scheduling Enforcement
Activities.
The system was designed for use in tracking the
status of stationary air compliance with schedules
and emission regulations and for scheduling and
tracking the occurrence of enforcement-related
events. By providing the users with listings of
events that either are to occur, have occurred,
or should have occurred, the completion of an event
can be noted in the system files. Enforcement
action can begin and be noted on the system for those
sources which are delinquent in complying with
emission abatement schedules.
Four basic report formats are available from the system,
as follows:
Source Data Report
Quick Look Report
Action Questionnaire
Action Summary Report
These reports are available through a customized CDS
retrieval package.
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(4) CDS Employs a Tape Master File and a Disk-based Retrieval
Capability.
CDS was developed in COBOL for operation on an IBM/370
computer. It contains a sequential tape master file
which is copied to disk after each update for use by
the retrieval program. System software, source pro-
grams, load modules, procedures, files and related data
sets are maintained on two IBM 3330 disk packs.
CDS provides a list of facilities, emission points, and
compliance schedule actions that were to occur in the
previous six-month period. Facility and emission points
can be matched to NEDS records through the use of the
state, county, NEDS source cross reference, and NEDS
point cross reference codes.
The CDS files record data on over 30,000 major and
minor air facilities throughout the country. Each
week an average of 10,000 transactions are processed
in the update run.
(5) CDS Is Maintained and Operated By the Division
of Stationary Source Enforcement (DSSE).
DSSE is responsible for the overall operation and
maintenance of CDS. DSSE secures funds and manages
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contractor support for system operation, program
maintenance, system enhancement, data coding and key-
punching assistance. In addition, DSSE acts as a
central focal point for solving problems with system
operation and for coordinating and approving sug-
gestions for improvement. Modifications and enhance-
ments to the system are managed by DSSE under the
recommendation of an annual Headquarters/Regional user
meeting.
(6) CDS Computer Costs for Fiscal Year 1976 Are
$105,000.
CDS computer costs are divided into regional and
DSSE processing. The table below shows manpower
requirements and ADP contractor costs for 1975
and 1976 for both regions and Headquarters.
Computer Personnel Contractors
Headquarters
FY
FY
75
76
$
$
50,
54,
000
000
1
1
$
$
75,
75,
000
000
Regions
FY
FY
75
76
$
$
30,
51,
000
000
5
5
$
$
125,
125,
000
000
Regional contractor costs are for data encoding. These
costs are expected to decline slightly for fiscal year 1977.
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4. THE COMPREHENSIVE DATA HANDLING SYSTEM (CDHS) SUPPORTS
STATE EMISSION INVENTORY AND AIR QUALITY DATA PROCESSING
REQUIREMENTS.
CDHS is a combination of two separate computer systems,
the Air Quality Data Handling System (AQDHS-II) and the
Emission Inventory System (EIS/PR). AQDHS-II handles
air quality monitoring data and EIS processes emission
inventory, permit and registration data. AQDHS-II is
designed to interface with SAROAD, and EIS/PR is designed
to interface with NEDS. Both systems were developed by
EPA with outside contractor assistance and are implemented
on state ADP facilities with EPA contract funds. Currently,
25 AQDHS-II and 21 EIS/PR systems are operational or are
scheduled for installation. Either system can be operated
independently of the other.
(1) CDHS Supports State Collection, Editing and
Retrieval of Air Quality and Emissions Data.
In 1973, EIS/PR and AQDHS-II were developed by EPA
to support the data handling and reporting require-
ments of state agencies and to perform SAROAD and NEDS
functions, respectively, at the state level.
EIS/PR also contains permit and registration infor-
mation and local site data that are not contained
in NEDS. These systems support three functions,
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as follows:
Edit and store aeroraetric data
Provide reporting capabilities for retrieving
information from the data base
Produce card or tape formatted output that
can be used as input into NEDS and SAROAD
As of March, 1976, eleven states were using AQDHS-II
and fourteen states were using EIS. EPA managers
estimate that the number of states using these systems
will increase by 100%-150% over the next two years.
Currently, five-to-ten states maintain their own
local systems for performing AQDHS-II and EIS/PR
functions. The remaining states use manual filing
procedures.
Occasionally, regions request data from states to
compare state data against those found in EPA systems
or to correct currency or completeness deficiencies
in the EPA data bases.
(2) AQDHS and EIS Receive Data From State Air Pollution
Agencies and Produce Output Data for EPA AEROS
Systems.
Data gathering methods of EIS/PR and AQDHS-II data
are similar to those of NEDS and SAROAD. States
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collect emission inventory data from site audits
and from data supplied by point sources and submit
those data into EIS. Air quality data from
selected monitoring sites operated within the states
are collected, encoded, keypunched and entered into
AQDHS-II. Data can be loaded also from SAROAD or
NEDS into the AQDHS-II or EIS/PR data basis,respec-
tively. For EIS/PR, area source data can be taken
from NEDS, or can be input manually by the states.
Both AQDHS-II and EIS maintain edit routines to
check for proper formatting and to identify data
anomalies. Data which have passed edit routines
successfully are updated into the master files.
These updates are initiated by the individual states
or local agencies responsible for maintaining the
systems.
EIS/PR and AQDHS-II output information on cards or
tape for input to SAROAD and NEDS. These outputs
are in proper format for processing by the EPA systems.
However, since the AQDHS-II and EIS/PR edits have not been
identical to those of SAROAD and NEDS, not all CDHS
transactions have been accepted by the EPA systems. SAROAD
and NEDS edit listings are returned to the regions
and subsequently are returned to the state for veri-
fication. Since comparisons between the state and
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EPA systems must be done in a time-consuming manual
fashion, states often do not reconcile all data
inconsistencies between the local systems and NEDS
and SAROAD. For example, EIS/PR provides no automated
method, at present, of monitoring which data have
been submitted to NEDS and which transactions still
must be posted to reconcile the two systems.
By contrast, AQDHS-II maintains internal flags which
indicate the specific transactions which have been
used to generate SAROAD update transactions. However,
some regional offices submit all AQDHS-II and EIS/PR
data into the EPA systems periodically, rather than
attempt to identify the specific change transactions
which would be needed to reconcile the differences
between the data bases.
(3) AQDHS-II and EIS/PR Offer Standard Reporting and
Specialized Programming Capabilities.
AQDHS-II and EIS/PR produce standard reports but
users can also produce customized reports by using
COBOL or the CDHS report-generator package. There
are four standard AQDHS-II reports, as follows:
Detailed list reports by sampling interval
Sliding average reports, which include
the number of readings, mean and maximum
values
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Data analysis reports, which display arith-
metic values and percentiles for various
selection criteria
Formatted SAROAD output file dumps
There are three standard reports for EIS/PR, as
follows:
File lists, which show one point source
or area source record per page
Summary reports on emissions data across
various selection criteria
Formatted NEDS output file dumps
These standard reports are enhanced by user-generated
report retrieval programs which provide additional
information needed by state managers.
(4) CDHS Systems Are Designed to Operate on Different
Computer Configurations While Maintaining Standard
Edit, Report and File Maintenance Procedures.
AQDHS-II and EIS/PR are designed to operate on both
tape and disk files. The systems are written and
have been installed on a variety of different com-
puters including IBM, UNIVAC and CDC equipment.
EIS/PR is composed of three major components, as
follows:
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Master file
Edit, update and retrieval routines
Emission factors table
The master file can reside on either tape or disk.
It contains files similar to those of NEDS, although
the files are accessed only by plant segment, point
source, or fuel and process keys. The plant segment
contains descriptive data on the site, including
codes for geographical and plant identification.
Each point source contains information on operating
characteristics, compliance status, control equip-
ment and emissions. The fuel and process keys con-
tain data on process output and emission factors.
The EIS/PR master file also contains area source
parameters similar to those used within NEDS.
The EIS master file is constructed from information
supplied on add, change or delete transactions.
Unlike NEDS, which only tracks emissions data on
five pollutants, EIS/PR is capable of storing data
on as many as sixteen different pollutants. This
enables states to maintain emissions inventories
on non-criteria pollutants, such as lead or flouride,
which may be included in state regulations.
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EIS/PR also contains a special report-generator
program which allows the user to program special
reports. In addition, EIS/PR has routines for
converting EIS/PR point and area source data into
NEDS input format and for converting NEDS data
into EIS/PR readable formats.
AQDHS-II contains many of the same features as does
EIS/PR. AQDHS-II maintains a similar report retrieval
capability, and can convert data to SAROAD input
format. The AQDHS-II data base also contains data
similar to those which are maintained by SAROAD on
monitoring stations, sampling intervals and sampling
values. However, there are no summary or frequency
files maintained in AQDHS-II. Furthermore, CDHS
does not provide for on-line retrieval of information.
Editing capabilities for both EIS/PR and AQDHS-II are
more limited than those available from NEDS and SAROAD.
CDHS edits are adequate for screening out most for-
matting errors but do not provide good tools for
identifying unrealistic input values.
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(5) AQDHS-II and EIS/PR Are Maintained and Installed
by EPA and Contractors But Are Operated by
State Agencies.
The CDHS systems were first conceived in 1970 and
were developed with EPA funds during the period 1972-
1974. The first systems were installed in late 1973.
Systems generally are installed by EPA contractors
on computer systems used by the states. Installation
costs average $17,000 and include a one-week user
training session. Once a system is installed, the
state is responsible for subsequent operating costs
associated with the system.
The CDHS system software is maintained by NADB. An
EPA contractor is available to perform trouble-shooting,
when necessary, and to provide additional system
enhancements for implementation by the states.
Currently, there is one person responsible for coordi-
nating enhancements, programming problems, and user
interfacing. Periodically, NADB distributes a CDHS
newsletter to state and regional users which informs
users of changes in system capabilities.
The contract costs for AQDHS-II and EIS/PR are
difficult to identify separately since some contracts
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involve work related to both systems. Estimated
contractor costs for CDHS system development and main-
tenance, user support and documentation are shown
in Exhibit 4-5, on the following page. They amount
to $521,000 for fiscal year 1976. Seventy-two per-
cent of these costs are related to implementing the
systems within the states. The remainder is
associated with development and continuing user
support. NADB personnel responsible for CDHS
estimate that $400,000 will be needed over the
next two years to continue system development
and user support. Another $100-200,000 are expected to
be spent on state implementations. This estimate is
based on an additional five-to-ten systems being
implemented in the states over the next two years.
Actual computer processing costs for CDHS are difficult
to determine precisely, since usage varies with
state size and reporting needs, and state costs
differ depending upon state hardware and billing
algorithms. However, CDHS personnel estimate that
12-24 CPU hours are used annually by small states,
and 24-48 CPU hours for large states, at an average
of $300 per CPU hour.
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Exhibit 4-5
U.S. Environmental Protection Agency
CDHS Contractor Costs
State Implementations
Development &
Enhancements
User Support &
Documentation
Trouble-Shooting
TOTAL
1975
$123,000
$109,000
$ 55,000
$ 50,000
$337,000
1976
$380,000
$ 96,000
$ 20,000
$ 25,000
$521,000
1977-1978
(2 year estimate)
$100-200,000
$ 250,000
$ 50,000
§ 100,000
$500-600,000
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(6) The Enforcement Management System (EMS) Is Being
Replaced by State Systems Compatible with the
Compliance Data System (CDS).
EMS was developed in 1972 for use by state and
local agencies. Its purpose was to monitor the
compliance status of point sources. It is installed,
at present, in five states. The EMS system design
was used as the basis for the Compliance Data System,
which is operated by the Office of Enforcement.
However, EMS currently cannot interface easily with
CDS. Instead, the Division of Stationary Source
Enforcement (DSSE) is adapting CDS for use by states
to facilitate the interface between state data and
the EPA version of CDS. There are no plans to expand
the capabilities of EMS or to install it in additional
locations.
5. OTHER AEROS SYSTEMS ARE USED TO RETRIEVE AIR QUALITY OR
EMISSION DATA, AND TO PERFORM STATISTICAL ANALYSES.
There are ten other AEROS systems which are used to
support air program activities, as follows:
Energy Data System
Form 67
Quality Assurance Management Information
System (QAMIS)
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State Implementation Planning System (SIPS)
Source Test Data System (SOTDAT)
Hazardous and Trace Elements Inventory
System (HATREMS)
Weighted Sensitivity Analysis Program (WSAP)
Regional Emission Projection System (REPS)
Source Inventory and Emission Factor
Analysis (SIEFA)
Computer-Assisted Area Source Emissions
Guiding Procedure (CAASE)
These systems are designed to operate on the UNIVAC
1110, and in many cases, access data from either
SAROAD or NEDS.
(1) The Energy Data System (EDS) and the Federal
Power Commission Form 67 System Report Energy-
Related Data on Power Plants.
EDS and Form 67 are two separate computer systems
used by EPA for enforcement, modeling and planning.
EDS is being developed currently with contractor
support to operate on the UNIVAC 1110. Form 67
is maintained by the Federal Power Commission. EPA
receives a copy of the data base annually and operates
the system on the UNIVAC.
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The Strategies and Air Standards Division (SASD)
has developed EDS to aid in assessing the air
quality and energy impacts of environmental legis-
lation. EDS provides interactive access to energy-
related data collected from other EPA data banks.
EDS receives its data from NEDS, SAROAD, CDS and
Federal Power Commission Form 67. In addition,
emission regulations and environmental policy data
are entered manually into the system. When fully
developed, the data base will contain seven types
of data, as follows:
Fuel quantity and consumption data
Plant design and operating data
Emission regulations
Compliance information
Future megawatt capacities
Diffusion modeling results
Air quality data
EDS produces interactive reports that cover five
major areas, as follows:
Fuel use summaries by geographical region
and by categories
Emission and equipment information for
large fuel-burning sources
Compliance schedules and status
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Modeling results for large power plants
Air quality data in the vicinity of large
power plants
ADP costs for EDS for fiscal year 1976 are
approximately $186,000. EDS zero-based budget
estimates for 1977 are $300,000. EDS requires two man-
years of EPA staff to maintain the system and data
base. Development contractor obligations since 1974
have amounted to $402,000. These contract monies
include work scheduled for completion through 1977.
Since 1969, the Federal Power Commission (FPC)
has collected information on monthly and annual
fuel use by boiler, and associated sulfur and ash
content from each power plant over 25 megawatt
capacity. This information is stored in the
FPC's Form 67 system. EPA receives magnetic tapes
from FPC each year for inclusion in its data base.
Approximately 400 items are submitted annually for
each power plant. Currently, there are about 800
power plants in the file. Form 67 can report
power plant information according to various selec-
tion criteria and sort options. Fiscal year 1976 com-
puter costs are about $175,000. Contractor costs for
1976 and 1977 are expected to be $160,000.
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(2) The Quality Assurance Management Information System
(QAMIS) Stores and Retrieves Quality Control Data on
Air Pollution Collection Agencies.
QAMIS was designed in 1974 by the National Air
Data Branch to record questionnaire data submitted
to agencies, and laboratories involved in monitoring,
collecting, and interpreting air quality data. Data
were collected on approximately 250 agencies and
laboratories which collectively operated and
maintained 2,500 monitoring sites. The purpose
of the data was to evaluate the existing air
quality monitoring networks which were submit-
ting data to SAROAD. QAMIS provides the ability
to analyze quality assurance information relating
to SAROAD sites, agencies and measurement methods.
QAMIS produces reports by five standard selection
criteria, as follows:
Agency
Laboratory
. Site
Pollutant
Opinion survey
150
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The QAMIS system has not been updated since 1974
and there are no current plans by either OAQPS or
ORD to expand the system. Current annual costs
for computer usage are approximately $2,000.
(3) The State Implementation Planning System (SIPS)
Stores and Reports Text on State Implementation Plans.
In 1974, the SIPS system was designed by NADB as
a tool for storing, retrieving and analyzing text
associated with state implementation plans. With
the assistance of the Division of Stationary Source
Enforcement and regional offices, NADB input approxi-
mately 5,000 state regulations into the SIPS data
base. Parameter codes were established for legal
authorities, control strategies, geographic areas
and other identifying criteria. Currently, NADB
and the Standards Implementation Branch within
OAQPS are verifying and updating the text. The
primary source of current changes and modifications
to SIPS are taken from the Federal Register.
SIPS produces listings upon request of selected
portions of state implementation plans. Approxi-
mately 18 selection codes can be used to access
specific regulatory information. In addition,
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reports can be produced according to various selection
criteria, such as state, region, regulation status
and date. SIPS contractor development and maintenance
costs for 1976 are $38,000 and are expected to increase
slightly over the next two years. Manpower support
for SIPS is currently one-to-one-and-a-half manyears
and is expected to stabalize at two manyears in the
future. Computer costs for fiscal year 1976 will be
approximately $13,000.
(4) The Source Test Data (SOTDAT) System Stores, Analyzes
and Retrieves Stationary Source Test Data.
SOTDAT operates on the UNIVAC 1110 at the National
Computer Center and is maintained and operated by
the National Air Data Branch. This system was
developed beginning in 1973, with contractor
assistance, and became operational in January, 1976.
SOTDAT stores and retrieves data gathered from
stack tests and other emission measurements. SOTDAT
data differ from those stored in NEDS in that SOTDAT
data represent actual stack emissions data, whereas
NEDS data reflect estimated emission information
only. Currently, there are about 700 point source
test records stored within SOTDAT. These records
contain four major types of information stored on
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each test source, as follows:
Plant and fuel data
Process team parameters
Pollutant test results
Control device data
The primary purpose of SOTDAT is to provide a means
of updating and improving emission factors for
specific SCC codes. In addition, SOTDAT also
provides data for evaluating equipment performance
and for providing construction site cost estimates.
Furthermore, SOTDAT can be used to store information
related to enforcement activities.
There are three major types of report retrieval
capabilities within the SOTDAT system. Reports
can be produced by three criteria, as follows:
uata for all test runs by pollutant
Emission factors by SCC code
Descriptive data on source sites that
had associated test runs
These reports can be retrieved on-line or in
batch mode.
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Source tests are conducted by both EPA and non-EPA
sources for both enforcement and research purposes.
Stack test data are collected and coded by OAQPS
staff or contractors. Data sources include both
published articles as well as test results submitted
directly to OAQPS from other EPA offices or outside
sources. The current data base is expected to
increase by approximately 400~to-500 point source
records annually. It is estimated that two manyears
of effort are required to gather and encode data
and to update the SOTDAT system. Computer costs
for fiscal year 1976 are estimated at approximately
$38,000. This usage level is expected to remain
stable over the next several years.
(5) The Hazardous and Trace Elements Inventory System
(HATREMS) Is Designed to Store and Retrieve Operating
Parameters and Estimated Emissions Data for Non-Criteria
Pollutants.
HATREMS is being developed currently by OAQPS and
contractors to store and report emissions information
on non-criteria pollutants. HATREMS is expected to be
operational during fiscal year 1977. It is designed
to store point source descriptive data, emission
factors, and SCC data for non-criteria pollutants.
The data base will have a similar structure to that
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of NEDS in that it will maintain both a point source
and area source file. The majority of source sites
in HATREMS will be taken directly from NEDS. It is
estimated that an additional 100-to-500 point sources
will have to be input to make a complete inventory of
non-criteria pollutant sources.
HATREMS will be used by OAQPS staff to monitor and pro-
ject non-criteria pollutant emissions and to develop
emission factors for those pollutants. The initial
point source data will be taken directly from NEDS.
It is estimated that this system will cost between
$25,000 and $50,000 annually and require approximately
one manyear to maintain. The system will operate on the
UNIVAC 1110 and will be accessible by batch processing
only. Anticipated contractor costs for 1976 are approxi-
mately $50,000 and are expected to remain constant
for 1977.
(6) Four Analysis Packages Are Used by EPA to Perform
Emission Forecasts and Statistical Analyses Using
NEDS or SAROAD-Related Data.
NADB maintains four small reporting and analysis
packages that perform emission projections and analyze
existing emission data, as follows:
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Weighted Sensitivity Analysis Program (WSAP)
Regional Emission Projection System (REPS)
Source Inventory and Emission Factor Analysis
(SIEFA)
Computer-Assisted Area Source Emissions Guiding
Procedure (CAASE)
WSAP allows users to analyze quantitatively the
effects of potential errors in air pollution source
emissions inventories. The primary objective of
WSAP is to calculate the maximum variation in emissions
for each of the component sub-categories of the emis-
sion inventory. An acceptable error in total emissions
of a criteria pollutant is specified for a geographical
area. WSAP then calculates the maximum variance in
emissions for each sub-category in order to produce
the acceptable error rate for the total inventory.
REPS is a computerized air pollution emissions pro-
jection model. It combines national and regional
economic forecasts with NEDS point and area source
emission inventories for AQCR's. it projects annual
air pollution levels for the five criteria pollutants
up to the year 2000. REPS produces projections based
on three parameters, as follows:
Calculation of growth factors from economic
and demographic forecasts
156 index systems inc
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Projection of emissions from base year
inventories
Inclusion of the effects of emission control
devices on emission levels
REPS uses three primary sources for economic and
demographic forecasts, as follows:
EPA developed national economic growth
projections from the Strategic Environmental
Assessment System (SEAS)
The Department of Commerce regional activity
projections (OBERS)
The NEDS data base
SIEFA is an analysis package that estimates the
imprecisions associated with the NEDS inventory for
any given geographic area. Internal SIEPA tables store
pre-calculated errors and variances associated with
NEDS emission factors. NEDS area and point source
files are used to estimate the precision of the associated
emissions. A major part of the SIEFA system is devoted
to estimating the precision associated with mobile
sources. The SIEFA report includes the calculated pre-
cision and accuracy of emissions for each source category.
Precision is reported as the standard deviation of the
emission estimate. The accuracy is estimated by
counting those point sources within a source category
which had inadequate data for NEDS to calculate emissions.
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SIEFA substitutes standard values for these missing data
items and estimates the resultant source emission values,
These values are added to the NEDS emissions to present
an approximate indication of the accuracy of the NEDS
inventory. SIEFA reports can be printed by specifying
a criteria pollutant and a geographical area.
CAASE is used to restructure the NEDS county-organized
area source data into uniform grid areas. These grid
formats are necessary input to three mathematical
models, as follows:
Implementation Planning Program (IPP)
Comprehensive Dispersion Model (COM)
Air Quality Dispersion Model (AQDM)
CAASE apportions fuel and emissions data from the
NEDS area file based on demographic characteristics
within the respective areas, it provides activity
levels and emissions for each criteria pollutant.
REPS, SIEFA, CAASE, and WSAP are routines which
access the NEDS data base. Overall NEDS computer
costs include costs for these four programs.
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6. DATA SYSTEMS ARE USED WITHIN THE OFFICE OF RESEARCH AND
DEVELOPMENT TO SUPPORT HEALTH EFFECTS RESEARCH, TO DEVELOP
AIR QUALITY MODELS AND TO ANALYZE NON-CRITERIA POLLUTANTS.
The Office of Research and Development conducts various
studies which require large quantities of highly-reliable
data. Most of the ADP support related to air pollution
research is associated with three programs, as follows:
Community Health Environmental Surveillance
System (CHESS)/Community Health Air Monitoring
Program (CHAMP)
Regional Air Pollution Study (RAPS)
National Air Surveillance Network (NASN)
The principal data banks associated with each system are
maintained at the National Computing Center in RTF. ORD
use of these systems represents approximately 35% of
current UNIVAC 1110 utilization.
(1) The Community Health Air Monitoring Program (CHAMP)
and the Community Health Environmental Surveillance
System (CHESS) Provide Information on the Effects
of Specific Air Pollutants on Human Health.
The CHESS program was initiated in 1970 to gather
air quality and health information from 22 communities
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located in five metropolitan areas around the
country. Air quality data were collected over a
five-year period for various pollutants including
total and respiratory particulates, sulfur dioxide
and nitrogen oxides. In addition, health informa-
tion was collected from individuals and families
residing within two miles of the air monitoring
stations. Epidemiologic studies associated with
CHESS included three areas, as follows:
Chronic respiratory disease
Acute lower respiratory disease
. Asthmatic attacks
The CHESS system consists of 240 COBOL and FORTRAN
programs which were used to store and analyze the
daily averaged air quality data and health ques-
tionnaire responses. Four types of reports are
available from the system, as follows:
Air quality summaries
Demographic information
. Acute, episode and respiratory disease
summaries
Statistical analyses
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Currently, EPA researchers are analyzing the data
and proceeding with the publication of results of
the various CHESS studies.
In 1973, the CHAMP program was initiated to gather
data on short-term human exposures to various air
pollutants. The system collects air quality from
23 air monitoring stations located in five commu-
nities. Presently, the CHAMP system stores air
quality date for eight pollutants, as follows:
Nitric oxide
Nitrogen dioxide
Ozone
Sulfur dioxide
Methane and non-methane hydrocarbons
Carbon monoxide
Peroxyacetylnitrate (PAN)
Suspended particulate matter (total and
respirable)
In addition, each monitoring site collects meteoro-
logical information on wind speed and direction,
temperature, humidity and barometric pressure.
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The principal distinction between CHESS and CHAMP
is the sophistication of the monitoring network
and data flow. CHAMP has been designed to acquire
continuous air quality information through the use
of mini-computer-controlled monitoring stations
and to transmit the data to the National Computing
Center (NCC) via telephone lines. In addition,
each field mini-computer monitors various system
parameters against present limits to facilitate
equipment calibration.
Fiscal year 1976 computer charges for CHAMP/CHESS
are $342,000. These costs are expected to remain
stable for fiscal year 1977.
(2) The Regional Air Pollution Study (RAPS) Stores Emissions
and Air Quality Data for Use by Researchers in the
Development, Evaluation and Validation of Criteria
Pollutant Air Quality Models.
The RAPS program was initiated in FY 1973 to collect
detailed air quality and emissions data on the
criteria pollutants to be used by researchers in
the development and validation of urban dispersion/
diffusion models. The St. Louis AQCR was selected
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for study under the RAPS program because of its
relatively flat terrain and its isolation from
other major sources of pollution.
The Meteorology Laboratory at RTF within the
Office of Research and Development has overall
responsibility for the RAPS project with specific
responsibility for collecting ambient air quality
data and for operating the Regional Air Monitoring
System (RAMS). Twenty-five mini-computer-controlled
monitoring stations located around St. Louis
comprise the RAMS network. Sampling is done every
half-second and voltages from each station are
communicated to a central mini-computer in St. Louis
where a daily tape of one-minute averages is created.
A copy of this tape is sent to RTP for data validation
and archiving of hourly averages.
In addition, RAPS requires a detailed and compre-
hensive source and emission inventory. The National
Air Data Branch (NADB) has developed the emission
inventory techniques and is participating in the
collection of source/emission data.
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NCC charges associated with RAPS for FY 76 are
expected to be $250,000. $38,000 of these costs
are attributable to OAQPS emissions inventory data
collection. The remainder is attributable to ORD.
ORD costs are expected to remain constant for fiscal year
1977. OAQPS costs will be eliminated.
(3) The NASN System Is Used by Research Personnel to
Store and Analyze Air Quality Data on Non-Criteria
Pollutants.
The Environmental Monitoring and Support Laboratory
(EMSL) maintains and reports data on ambient levels
of non-criteria pollutants collected from 250 EPA
maintained NASN sites generally located in urban
areas. In 1966, the SAROAD system was designed to
store air quality data collected by the NASN network.
With the creation of the National Air Data Branch
in 1972, The SAROAD system increased in scope to
include air monitoring data reported to EPA by
state and local agencies.
EMSL continues to collect non-criteria data from
NASN and others. Filters from the various NASN sites
are sent to regional offices where they are
weighed and forwarded to EMSL for laboratory
analysis. Air quality data associated with NASN
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and other EMSL programs are stored in a data bank
similar in format and design to SAROAD. This
system, referred to as "mini-SAROAD", utilizes
specialized edit and report programs, although its
data base structure is essentially the same as
SAROAD. In 1974, the Filter Bank System (FBS)
was designed to assist the laboratory analysis
performed by EMSL. Various filter information and
test results are entered into FBS on-line. Approx-
imately every two weeks a transaction tape of filter
analysis data is created by FBS for an update of
"mini-SAROAD".
Subsequently, "mini-SAROAD" is used for validation
of data, report retrieval and non-criteria pollutant
analysis. On a periodic basis validated data are
provided to NADB for inclusion in the national
SAROAD data base.
Total NCC charges for FBS and "mini-SAROAD" in FY
76 are expected to be $54,000.
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In summary, air data systems operate primarily on the
UNIVAC 1110 in support of program personnel within OAQPS
and ORD. State personnel are supported primarily by
CDHS in those states which have operational versions of
CDHS, by locally developed systems or by manual record-
keeping systems. Regional personnel make limited use
of NEDS and SAROAD reports, and expend most of their
air data processing resources in entering and correcting
state-supplied ambient and emissions data.
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V. PROBLEM AREAS
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V. PROBLEM AREAS
This chapter presents an analysis of the problem areas
associated with ADP support for the air program. The
chapter is divided into five sections, as follows:
Systems Deficiencies and Scientific Limitations
Hindering Air Program Data Activities
Data Flow Problems
Technical and Operations Problems
Cost-related Problems
System Management Problems
1. THE SCIENTIFIC COMPLEXITY OF CURRENT MONITORING ACTIVITIES
LIMITS THE USEFULNESS OF CAPTURED DATA WHICH ARE STORED IN
THE AEROS SYSTEMS.
Completeness, accuracy and currency problems associated with
air quality and emissions data arise from the complex siting
and quality assurance problems associated with EPA's monitor-
ing strategy. These monitoring strategy problems limit the
usefulness of the data systems, NEDS and SAROAD in support-
ing modeling applications, significant deterioration review,
trend analysis and compliance monitoring/since the infor-
mation contained in the data systems can be no better than
the data acquired as part of the monitoring strategy.
167 . . .
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(1) The Incompleteness of State-submitted Air Quality
Data Limits the Scope of Trend and Compliance Analysis.
EPA air program personnel need to evaluate air quality
and emissions trends and compliance with standards in
order to perform three planning and review functions,
as follows:
Review national abatement plan progress
Develop and rank new national air program
activities
Prepare the national report for Congress and
the general public on the condition and trends
in air quality and emissions
However, limitations in the availability of S02 and TSP
air quality data and the absence of good quality nation-
wide ambient motor vehicle pollutant data have con-
strained EPA's ability to perform these functions.
EPA has established two criteria definitions concerning
the ambient data reported from a monitoring station, as
follows:
Minimal year of data - at least three 24-hour
monitor samples or 400 hourly values from
continuous samples
Valid year of data - at least five 24-hour
monitor samples or 75 percent of the possible
hourly values for a continous monitor in each
quarter of a calendar year
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Using these definitions, the Council on Environmental
Quality (CEQ) noted that only 15% of TSP stations
and 46% of S02 stations reporting minimal data sub-
mitted data sufficiently complete to allow for cal-
culation of a valid annual mean as needed to review
and analyze program progress. Approximately half of
the reporting stations could not be evaluated for
compliance with annual standards for these pollutants.
Furthermore, CEQ found that states had failed to sub-
mit sufficient data to determine the attainment status
of each AQCR by pollutant. This determination requires
that at least one station report a valid year of data
in order to evaluate annual standard compliance and
that at least one station report a minimal year of data
in order to evaluate short-term standard compliance.
In 1974, 37% of the AQCR's reported insufficient ambient
S02 data to determine annual standard attainment and 15%
of the AQCR's reported insufficient data to assess com-
pliance with any ambient 802 standard.
In addition, SAROAD received only limited historical
monitoring data for oxidants, carbon monoxide and
nitrogen dioxide, as needed to measure progress in air
pollution abatement of motor vehicle-related pollutants.
California is the primary source of most of the historical
air quality oxidant data. Consequently, most analyses
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are limited to the California area. Because of changes
in measurement methods for nitrogen dioxide, no areas
have sufficient historical data to assess NO- trends.
As a result, the historical monitoring data submitted
to and therefore available from SAROAD have proven
inadequate to assess national trends in oxidant formation
or in developing corresponding control strategies.
(2) Incomplete and Inaccurate State-submitted Emissions
Data Limit the Usefulness of NEDS-provided Information.
National emissions analysis and trend reporting are
hampered by completeness, currency and accuracy problems
associated with the source information submitted by
states to NEDS data base. In contrast to the direct
measurement used co report ambient air quality, emissions
estimates are the result of calculations obtained by
applying emission factors to source inventory informa-
tion. The accuracy, currency and completeness of NEDS
point source information is deficient because states
fail to notify Regions regarding new sources that come
into operation, cease operation, modify operation or
change fuels. Over 50% of the source records in NEDS
have not been updated since 1972 because of the low
priority given to submitting updated emissions data
by states.
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In the absence of good quality emissions data, analysts
have projected emission levels on the basis of industry
forecasts, fuel utilization and economic indicators.
These different estimating techniques, data sources,
working assumptions and definitions have produced
conflicting emissions estimates and have exposed EPA
and state agencies to legal attack from affected
companies.
(3) The Siting and Selection of Monitoring and Emissions
Information Does Not Satisfy the Data Needs of Modelers
and Researchers.
Simulation models are being used increasingly by state
and regional offices to support new source reviews, SIP
revisions, and air quality maintenance planning
activities. The models that are available currently for
use are concerned primarily with non-reactive pollutants
such as TSP, SO> and CO. Since most monitoring stations
are sited for reasons other than collecting data for
model calibration, most air quality data are only
partially adequate for calibration purposes. Submitted
emissions data available from NEDS are often inappro-
priate for use in modeling as well. As a result,
modelers use whatever ambient and emissions data have
been assembled in AEROS as part of the monitoring network
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strategy as a first pass. They then supplement these
data with specially acquired data to improve the
accuracy and validity of their modeling results.
Similarly, researchers are not always able to rely upon
the monitoring network data stored in SAROAD to support
special research projects for three reasons, as follows:
National monitoring stations are sited
primarily to provide a general index to
pollution levels and not to satisfy specific
research requirements.
The quality of the collected national monitor-
ing data is unknown in many cases.
The time interval over which air quality data
are sampled and averaged is not appropriate
for various research studies.
As a result, research programs have established their own
monitoring networks to supply specialized monitoring
information to support their research projects. For
example, the CHAMP program has selected certain
municipalities in which to study the health impact of
exposure to specific pollutants. The siting of stations
within these municipalities is far more concentrated
than would be needed to monitor SIP progress or to
perform related trend analysis.
In addition, both CHAMP and RAPS utilize mini-computers
to control and calibrate the various instruments used
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to acquire air quality data. By contrast, because
of cost considerations, most state and local monitoring
networks rely on human operators to record data from
strip charts and to perform various calibration efforts.
2. DEFICIENCIES IN NEDS AND SAROAD DATA FLOWS CONTRIBUTE TO
DATA INACCURACIES AND CAUSE UNNECESSARY MANUAL PROCESSING.
NEDS and SAROAD data originate primarily with states and then
are forwarded to EPA regional offices for entry into the
respective EPA systems. Numerous bottlenecks and inefficiencies
occur during these data flows.
(1) NEDS Data Flow Problems Stem From Cumbersome Procedures
Involving Multiple Organizations.
The flow of emissions data among states, regions and
NEDS is complicated by five factors, as follows:
Lengthy turnaround time for edits
The natural complexity of emissions data and
the NEDS input forms
Need for technical expertise at the regional
level to review state submittals
State procedures and organization whereby the
recorders of data (engineers) do not use the
data but view data recording as an externally
imposed burden
Late state submittals
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These factors affect the reliability of data submitted
to NEDS, and contribute to increased workloads for
regional and state offices. For example, regions
generally do not receive edit feedback on NEDS data
for three-to-four weeks after submittal. Corrections
to these data then require an additional three-to-four
weeks. Given the reluctance of state engineers to
"waste time" submitting or correcting NEDS forms,
these time delays contribute to the high incidence of
late or non-submittals.
Similarly, filling out portions of the NEDS input form
requires specialized engineering or technical expertise,
However, state offices have only limited trained man-
power available to perform these functions. As a
result, state clerical staff oftentimes are used to
fill out portions of the form. However, these clerical
personnel have difficulty filling in the correct SCC
and method codes. This problem is compounded by the
fact that NEDS does not maintain adequate SCC codes for
all plant types. NADB staff have estimated that 20% of
all SCC codes within NEDS are assigned incorrectly to
plants, either because of improper recording by state
personnel, or because no valid SCC code exists for the
plant.
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Regional offices also require technical expertise
to review state input and to identify incorrect or
suspicious data values. In addition, regions must
record which data have been submitted to NEDS. This
record-keeping is necessary to prevent the redundant
entry of NEDS data and to prevent the entry of data
which are out of sequence.
NEDS data completeness and currency are affected also
by late state submittals. By regulation, states are
required to submit NEDS data within forty-five days
after each semi-annual reporting period. In practice,
states are frequently late in submitting required data.
NADB personnel have estimated that as much as 65%-70%
of states submit data late or submit incomplete data.
Only one-third of the states meet the complete reporting
requirements on time.
(2) SAROAD Data Flow Problems Stem Primarily From Univac
Hardware Problems and Related System Design Inefficiencies.
The flow of ambient data among states, regions and
Headquarters is constrained by three factors, as follows:
Unstable hardware environment
Resulting infrequent system updates
Resulting slow report turnaround time
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SAROAD has been updated only three times between
December, 1975 and June, \916. The infrequency of
these updates has caused SAROAD data to be incomplete
and out of date. Data base inaccuracies are due also
to slow report turnaround times for regional offices
which wish to verify their SAROAD data. These delays
have been caused primarily by the instability of the
UNIVAC, by contention problems with data stored on
tape, and by system design characteristics which required
lengthy program runs which were more susceptible to
hardware failures.
3. COMPUTER HARDWARE AND SYSTEM DESIGN PROBLEMS HAVE REDUCED
THE USEFULNESS OF AIR DATA SYSTEMS.
Hardware instability of the UNIVAC together with various
data system design deficiencies have contributed to
inefficient computer resource utilization and have limited
the accessibility of stored data.
(1) The Instability of the UNIVAC System Environment
Has Created Problems for All Users of Air Data Systems.
Since its installation in 1974, hardware problems at
NCC have created an unstable system environment which
has inhibited timely data processing operations and
has limited the accessibility of the information
stored in the principle air data systems. Frequent
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system crashes and prolonged downtime have resulted
in three problems, as follows:
Data destruction
Increased processing backlogs
Delayed software conversion associated
with hardware transition
These problems have affected principally the ADP
operations associated with ORD and OAQPS which
together represent approximately 90% of the utili-
zation of UNIVAC.
Exhibit 5-1, on the following page, depicts recent
monthly NCC performance. The UNIVAC configuration
performed relatively better during the period October
through December, 1975. However, in January, 1976, the
equipment performance deteriorated substantially. The
high failure rate that has been experienced since
January is primarily attributable to the incorporation
of new hardware into the UNIVAC system on January 5.
These system failures have been attributable to five
general causes, as follows:
Direct hardware difficulties (memory, CAU,
disk subsystems and computer console mal-
functions)
Software deficiencies
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Exhibit 5-1
U.S. Environmental Protection Agency
NEC Monthly Performance
Month
Oct 75
Nbv 75
Dec 75
Jan. 76
Feb 76
March 76
April 76
May 76
MTBP1
16.3
13.7
15.6
9.6
8.2
10.2
10.5
10.4
^Failures
32
33
29
57
65
59
54
50
Total
Batch
11094
9477
9781
11624
11420
13648
12001
11603
Jobs
Demand
10294
9137
9574
13520
12418
16039
13951
14040
SUP He
Batch
822
685
682
782
854
997
864
799
TUTS
Demand
181
163
161
220
203
302
252
251
CO
Mean Time Between Failures.
Standard Unit of Processing (SUP) includes CPU, I/O times and executive requests.
-------
Computer and computer-room environment-
related problems or failures
Procedural and operational stops
Other unidentified causes
In recent months, actions have been initiated to
correct hardware malfunctions. Certain hardware
problems have been isolated and traced to the disk
subsystems and temperature problems in the computer
room. Operating system software problems have
been identified also and have been communicated to
UNIVAC for resolution. Although some improvements
have been implemented, the mean time between failure
is still below the NCC goal of 15 hours.
(2) SAROAD System Design and UNIVAC Operating Problems
Have Contributed to Delays in Updating and
Retrieving Air Quality Data.
Over the past year SAROAD updates and retrievals
have been delayed because of three factors, as follows:
Inadequate SAROAD program conversion from IBM
to UNIVAC hardware
Inefficient data base design
Cumbersome data files
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These factors together with the hardware instability
of the UNIVAC have contributed to operations and
scheduling problems at NCC. For example, because
SAROAD raw data have been stored on over 18 tape
reels, the processing of data file updates and
retrievals has necessitated sequential scheduling
of jobs to avoid data file contention problems. These
scheduling requirements together with frequent system
crashes have contributed to system backlogs and poor
turnaround time for users.
Many of the program modifications for SAROAD associated
with the IBM-to-UNIVAC hardware conversion were
performed inadequately by EPA contractors. Approximately
75% of the programs that were converted from PL/1 and
MARK IV to COBOL had to be modified again by EPA before
the UNIVAC SAROAD could be installed.
Prior to system modification to UNIVAC hardware, SAROAD
operated as a disk-based system with the data base
residing on 11 disk packs. Because of the growth
potential of the data base, NCC recommended that NADB
transform SAROAD into a tape-oriented system. The
data base has since more than doubled to over 25 tapes.
The SAROAD file structure and size have resulted in an
excessive amount of computer time needed to update and
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retrieve ravr data due to> file^rcontention problems. Further-
more, these long processing runs have made SAROAD
susceptible to UNIVAC system crashes. Over the past
year data file updates and summary file creation
frequently have utilized over 40 SUP hours. As a
result of frequent UNIVAC crashes, NADB has required
an average of three-to-four weeks to complete routine
data base maintenance functions.
(3) SAROAD Design and UNIVAC Operating Problems Have Forced
EPA to Implement Significant System Modifications.
Because of the serious design and operating problems
associated with running the poorly-converted SAROAD
on the UNIVAC 1110, EPA engaged Integrated Services, Ind.
(ISI) to undertake a major modification effort for
SAROAD. After careful analysis of data file structure
and content, ISI developed a scheme for a compacted
and technically efficient data base involving five
design changes, as follows:
Separate the raw data file by interval code
(less than 24-hour data and daily data)
Archive raw data creating a historical file
(1957-1973) and a current file (1974-present)
Create a compact key structure storing one
year's worth of data in half-words
Utilize fixed length records for less than
24-hour data
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Utilize random access devices for less than
24-hour data
The ISI SAROAD enhancement project is in the final
system testing phase. The preliminary results of
the system test demonstrate a dramatic reduction in
computer utilization for hourly raw data retrievals.
For example, raw data listings for all 1975 ambient
oxidant data formerly took four SUP hours, but have
taken only five SUP minutes when run off the new disk
version. These changes will eliminate also the
need to sequence retrieval requests. As a result,
typical turnaround time will be reduced from two-to-three
days to one day. ISI has projected that the new data
file update and summary file creation will utilize
less than eight SUP hours compared to the current average
of 31 SUP hours. Overall, these modifications will
make SAROAD less susceptible to hardware crashes
and will make the data more easily accessible for
update and retrieval activities.
(4) NEDS System Design and UNIVAC Operating Problems Have
Contributed to Data Accuracy, Reporting and System
Performance Problems.
Over the past year, NEDS technical performance and
data quality have been affected by three factors, as
follows:
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Inadequate NEDS report program conversion
from IBM to UNIVAC
Inefficient system updating routines
Limited editing capability
These factors have made it difficult for regions
and NADB to maintain timely and accurate NEDS data.
At present, regions cannot edit their NEDS data
directly but must rely upon NADB to initiate data
edits. Consequently, regions experience a delay of
two-to-three weeks, on average, before receiving
error reports. Notwithstanding this delay, the NEDS
data may still be in error since the edit routines
do not validate incoming data for reasonableness.
These delays and limited editing capabilities
contribute to data accuracy problems and require
additional effort to resolve.
Many of the retrieval programs associated with the
IBM-to-UNIVAC conversion were not converted adequately.
Programs were changed from PL/1 to COBOL using a
converter program which did not document programs
and which, in some cases, generated codes which did not
run properly. In addition, NADB analysts found that
subsequent enhancements could be performed more easily
by re-coding the converted programs than by trying to
patch the converted code. In order to rectify the
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problem, NADB used contractor assistance to modify
and enhance NEDS programs, and to prepare user documen-
tation to facilitate regional NEDS use. However,
regions had difficulty executing report programs while
these modifications were being implemented. These
problems were due, in part, to NADB and regional
pressure to provide regional reporting capabilities
as quickly as possible.
Despite the conversion and subsequent contractor efforts,
NEDS update procedures are still inefficient. After
every update, the entire user file is recreated. This
process would be more efficient if only those records
which have changed since the last update were modified.
Although this inefficiency does not affect NEDS data
flows or data accuracy, it does contribute to excess
processing cost since it takes as long to update one
record as it does to update the entire file. Processing
time reductions could be achieved by modifying the
update to modify only those records which change. NADB
has issued a contract to correct this problem.
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(5) CDHS Systems Require Minor Enhancement to Meet
State and EPA Needs.
The CDHS systems were designed to give states retrieval
and analysis capabilities similar to those offered by
NEDS and SAROAD, and to facilitate state submittals
of air quality and emissions data to EPA. However,
CDHS has three limitations which reduce the effective-
ness of these systems, as follows:
CDHS provides few standard reports and requires
states to develop their own customized reports.
User documentation is too technical for many
state personnel.
Only limited editing capabilities are provided
by the systems.
CDHS was designed to offer states versatile reporting
capabilities through the use of a report generator
package. However, most state and local agencies have
only limited ADP personnel available. As a result,
they have not been able to develop as many local
reports as they would prefer. Many of these states
have indicated that they would prefer EPA to develop
more standard CDHS reports to relieve state agencies
from this report design burden.
Although states are supplied with a training course
and system documentation, state managers have indicated
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that CDHS user documentation is generally too
technical for state employees who are involved with
coding, data entry or report generation. These
managers have stated that they require more complete
and descriptive documentation designed for use by
less technically-oriented state personnel.
Manpower expenditures for EIS/PR and AQDHS-II data
entry and correction could be reduced if CDHS edits
were more comprehensive and if CDHS/AEROS interfaces
were controlled more effectively. For example, EIS/PR
does not flag data that have been sent to NEDS.
Consequently, states track these transmittals manually
or resubmit data in order to insure that NEDS data will
be current. Region IV, for example, has instituted
a policy of resubmitting all EIS data to NEDS rather
than to attempt to track the specific data items which
have been updated successfully in the past. These
policies require more state and regional manpower and
ADP expenditures than should be needed otherwise.
(6) Interface Incompatibilities Between CDHS and EPA
Systems Contribute to Data Incompleteness and Non-
Currency.
The CDHS systems (EIS/PR and AQDHS-II) are designed to
facilitate the transmittal of air quality and emissions
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data to EPA air systems. However, technical features
of CDHS affect data completeness, accuracy and currency.
Data which are entered successfully into a state system
may be rejected subsequently when they are submitted
to NEDS or SAROAD. This occurs because CDHS and AEROS
do not employ the same edit and validation checks. As
a result, state, regional and Headquarters personnel
all become involved in modifying and correcting the EPA
system data. Region IV, for example, has identified
24 distinct steps which must occur in order to adjust
for data errors which result from these edit and
validation differences. As a result, the currency and
completeness of AEROS data suffers since the correction
process can take many months or more to complete.
(7) The System Objectives and Design of NEDS and SAROAD Have
Made Them Inappropriate for Supporting Selected New
Program Requirements.
Not all special studies and programs have been supported
adequately by the fixed set of reports and large,
cumbersome data bases associated with the principal
AEROS systems. NEDS and SAROAD were designed to provide
standard reports and not to be used as a universal data
base management system. Consequently, various other
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systems have been developed to fulfill specific needs
of air program personnel.
The Energy Data System (EDS) has been developed as a
tool for SASD planners to use in determining air
quality and energy impacts associated with environ-
mental legislation. Much of the data stored in EDS
is extracted from existing data systems such as NEDS,
SAROAD and CDS. EDS was designed to satisfy the need
for easier access and retrieval of emissions, fuel
consumption and air quality data than are available
from the individual systems.
Other systems have been developed also to fulfill
other emissions-related data needs. Since NEDS was
designed to store calculated emissions data for the
five criteria pollutants only, NADB is developing
the Hazardous and Trace Emissions System (HATREMS)
as an adjunct to NEDS in order to maintain and report
non-criteria emissions data. Similarly, the Source
Test Data System (SOTDAT) was developed to supply
EPA engineers with more detailed information with which
to update and improve emission factors than can be
provided by NEDS.
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4. AIR ADP SYSTEMS COSTS OF OVER THREE MILLION DOLLARS IN
1976 ARE EXPECTED TO BE REDUCED IN 1977.
EPA ADP system costs for the entry, storage and retrieval
of aerometric data are expected to be $3,126,000 in fiscal
year 1976. These costs include the operating costs for
state CDHS systems. Exhibit 5-2, on the following page,
shows air system costs for 1975 and 1976 for the four
principal EPA users, as follows:
The Office of Air Quality Planning and Standards
(OAQPS)
The Division of Stationary Source Enforcement
(DSSE)
The Office of Research and Development
The Regional Offices
These costs were taken from the Time-Sharing Services
Management System (TSSMS). The 1976 costs were annualized
from the June TSSMS report.
State costs are difficult to ascertain directly, since
state usage varies with data base size, reporting usage
and billing algorithms for each state computer facility.
The aggregate state CDHS costs of $300,000 are based on
annual computer resource estimates provided by NADB system
managers. The annual state computer utilization estimates
were extended by the number of new state installations and
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Exhibit 5-2
U.S. Environmental Protection Agency
ADP Air Costs by EPA User
OAQPS
ORD
OE
Regions
States
TOTAL
1976
l,656f 000
857,000
54,000
300,000
300,000
3,126,000
1975
1,299,205
590,822
48,000
277,080
Not Available
2,215,107
190
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were based on an average computer billing rate of $300
per hour.
Exhibit 5-3, on the following page, shows a breakdown of
costs by major system. SAROAD accounts for $903,000 of
total air system costs for fiscal year 1976. This figure
includes an estimated $55,000 of regional SAROAD usage
during the year and also $199,000 in SAROAD development
costs. SAROAD costs attributable to OAQPS account for
49% of the OAQPS computing costs, and total SAROAD costs
account for 28% of all air systems costs. OAQPS costs
are expected to decrease in 1977 by $300,000. Sixty per-
cent of this savings will be attributable to reporting
and maintenance due to current SAROAD enhancements. The
remaining 40% will be due to a reduction in total system
development work.
ORD costs are attributable primarily to the Regional Air
Pollution Study (RAPS), the Community Health Air Monitoring
Program (CHAMP) and the Community Health Environmental
Serveillance System (CHESS). Combined ORD expenditures
for these three systems amount to $597,000 for fiscal year
1976. Modeling efforts and analysis of data collected from
the NASN network accounts for the bulk of the remaining
$260,000 in ORD expenditures. Overall costs for ORD systems
are expected to increase for fiscal year 1977, although
exact figures could not be estimated by ORD system managers.
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Exhibit 5-3
U.S. Environmental Protection Agency
Air Data System Costs
SAROAD (includes regions)
NEDS
CDS
RAPS
CHESS/CHAMPS
EDS
CDHS
NASN
Other
TOTAL
1976
903,000
150,000
105,000
250,000
347,000
183,000
300,000
54,000
834,000
3,126,000
1975
606,242
260,131
48,000
117,600
289,756
18,000
Not Available
89,000
875,378
2,215,107
192
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RAPS is expected to increase slightly. CHAMPS is still
undergoing development work but operating costs should
increase.
The Division of Stationary Source Enforcement maintains
the Compliance Data System (CDS) and has spent $54,000
to operate the system during 1976. In addition, $51,000
has been spent by regional offices for data input, reporting
and related air enforcement computing. These costs are
expected to remain constant.
Because of various technical inefficiencies resulting from
faulty IBM-to-UNIVAC conversion, air system costs have
been higher than necessary. As a result, EPA has provided
funding for various system modifications which will have
the affect of reducing the related ADP costs.
5. DEFICIENCIES IN THE MANAGEMENT OF SYSTEM DEVELOPMENT AND
OPERATIONS HAVE LIMITED THE EFFECTIVENESS OF AIR DATA SYSTEMS.
The development and utilization of air data systems by EPA
and state offices have been hindered by management defi-
ciencies in three areas, as follows:
Ambiguous system management responsibilities
Non-rigorous management of ADP usage at NCC
Inadequate management of the UNIVAC computer and
related conversion efforts
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These deficiencies have limited the effectiveness of various
air data systems.
(1) The Lack of Clearly Defined System Management
Responsibilities Within OAQPS Contributes to Inefficient
Use of Computing Resources.
The management of ADP contractors and system development
efforts is a complex task which requires full-time
monitoring by personnel with a sound foundation in ADP
management principles. The National Air Data Branch
(NADB) is the organization within OAQPS with the
greatest experience in system development and management.
Nonetheless, some system development within OAQPS has
been managed by other OAQPS divisions. For example, the
Energy Data System (EDS) was designed and developed,
principally, under the direction of the Strategies and
Air Standards Division (SASD) within OAQPS. Contrary to
other system development work within OAQPS, such as
the SIPS project, NADB undertook only a secondary review
role concerning the EDS feasibility study, system design
and system interfaces. The primary development respon-
sibility rested with SASD personnel who were not as
familiar with system management principles as were
personnel within NADB.
194 index systems me
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The resulting data system, EDS, has proven extremely
expensive to develop and contains a variety of features
which make it very costly to operate. In retrospect,
it appears that an adequate feasibility study was
not undertaken for EDS. The EDS contractor was not
required to define specific data needs nor was he
required to analyze the costs and benefits associated
with all relevant alternatives. Rather, a preliminary
design was prepared which addressed functional capa-
bilities, availability of source data and an implemen-
tation approach. The missing system justification and
cost benefit analysis is precisely what more experienced
ADP managers would have required of their contractors.
As a result, the current EDS does not make efficient
use of computing resources both because its functional
design is no longer appropriate for serving management
needs efficiently and because it utilizes costly on-
line storage and retrieval of non-current redundant
data. For these reasons, OAQPS would have been served
better by limiting the management of new projects and
contractors to those personnel within OAQPS with the
most experience and training in ADP management practices
and policies.
195 index systems inc
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(2) ORD and OAQPS Will Need to Tighten Their Budgetary
Control Over NCC Utilization.
Historically, the EPA computing center at RTF served
ORD and OAQPS users exclusively and was regarded
essentially as a free resource by these offices.
Recently, the Management Information and Data Systems
Division (MIDSD) has prepared a plan to develop the
NCC into an Agency-wide resource subject to stricter
budgetary controls. Consequently, all Agency ADP users
will be allowed to shift their data processing to the
UNIVAC as their ADP sub-allowances and NCC resources
permit. Since the UNIVAC will be priced competitively
to the IBM computer at OSI, MIDSD anticipates increased
pressure for UNIVAC support from EPA program offices.
Furthermore, Agency-wide ADP budgets have been severely
constrained by Congress. Therefore, the program offices
will be less free to shift program funds into their ADP
sub-allowances to make up for ADP overruns. As a result,
competition for UNIVAC resources will increase and not all
air program requests necessarily will be satisfied.
Rather, OAQPS and ORD will need to manage their ADP
utilization more carefully than in the past to preserve
sufficient ADP funds to support high priority programs.
This will require increased management attention and
technical expertise to insure that current and future
applications operate as efficiently as possible.
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(3) Inadequate Management of the UNIVAC Computer and Related
Conversion Activities Has Created Major Operating Problems
For NCC Users.
MIDSD is responsible for operating the UNIVAC 1110 at NCC
yet it has failed to demonstrate any long-term improve-
ment in UNIVAC operating performance. This has occurred
despite the fact that other UNIVAC 1110 installations
have been operated without comparable downtime. During
late 1975, the UNIVAC finally began to meet established
operating performance objectives. However, rather than
continuing to operate the machine at this level, MIDSD
decided to expand the equipment configuration despite
the fact that such expansion in the past consistently had
resulted in a deterioration in operating system per-
formance. As a result, the UNIVAC has never returned to
its 1975 performance level.
Major conversion efforts undertaken in transferring AEROS
systems to the UNIVAC also indicate serious historic
deficiencies in NCC planning and technical judgement.
The line for line conversion approach adopted is an
extremely dangerous method for transferring complex file-
sensitive systems such as NEDS and SAROAD. Instead,
significant redesign analysis should have been undertaken
at conversion time to insure that the resulting systems
would operate efficiently under the new UNIVAC environment.
197 index systems inc
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In summary, EPA's primary air data systems do not
satisfy all user requirements in a timely and efficient
manner. For the most part, these deficiencies are
attributable to limitations in the data available from
the current monitoring networks and to hardware and
operating problems associated with the current UNIVAC
computing environment. In addition, however, the current
size of the major air computer data bases makes them
more susceptible to hardware failures. The large
volume of data submitted to these systems also has
proven cumbersome to state and regional personnel. As
a result, state and regional submitters have not expended
as much effort as necessary to submit and confirm the
accuracy of all collected data.
The Standing Air Monitoring Work Group (SAMWG) has
undertaken a project to revise the requirements for
state submittal of data. Preliminary results from SAMWG
indicate that EPA will reduce substantially the volume
of data which it will require from states. This change
in monitoring strategy and reporting requirements will
permit a change in air data processing strategy whereby
EPA could maintain AEROS systems containing far fewer
data values than at present. This change in data pro-
cessing strategy could reduce AEROS system sensitivity to
hardware problems and could free state and regional personnel
198 index systems inc
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to insure the quality and accuracy of the much smaller
volume of submitted data.
The next chapter examines the implications of such
a change in data processing strategy. It examines also
the implications of other changes to current systems
and practices.
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VI. EVALUATION OF ALTERNATIVE ACTIONS
index systems inc
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VI. EVALUATION OF ALTERNATIVE ACTIONS
The preceding chapters have described the air program strategy,
information needs, current ADP support and associated problem
areas. This chapter presents an evaluation of alternative ac-
tions to deal with the identified problem areas. This analysis
is divided into four sections, as follows:
Data system design philosophy for managing
ambient air quality data
Data system design philosophies for emissions
and compliance data systems
Technical data system actions to improve functional
service and data system efficiencies
Changes in ADP management responsibilities
Cost data related to the analyses performed in this chapter are
contained in Appendix B.
1. A HYBRID COMPUTER SYSTEM DESIGN APPROACH FOR STORING AIR QUALITY
DATA IN CONFORMITY WITH THE REVISED MONITORING STRATEGY CAN
IMPROVE SERVICE TO EPA AND CAN REDUCE ASSOCIATED OPERATING COSTS.
Cost can be reduced and service can be improved if EPA adopts a
hybrid system design philosophy for the management of air quality
data in conformity with the revisions to EPA's monitoring strategy.
Exhibit 6-1, on the following page, contrasts the impact of the
20 o index systems inc
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Exhibit 6-1
U.S. Environmental Protection Agency
Comparison Summary of System
Design Alternatives
Utility
Hybrid
Current
Functional
Service
Improved data
landling with
good availability
state-collectec
air quality data
Improved data
handling with
good availabilit;
of monitoring
trend data
Good data
availability and
reporting flexi-
bility but poor
data handling
Annual Operating
Cost Impact
$625,000
$600,000
$300,000
Development and
Installation
$600,000 -
$1,000,000
$380,000
$330,000
Risk
High technical
and cost risk
Low technical
and cost risk
Moderate
technical risk
Management
Considerations
System management
problems with
state dependence
upon EPA for ADP
support
Less complex
system
management
Less dependence
of EPA and
states upon
each other
201
-------
current design approach with a utility and a hybrid design
approach. The hybrid alternative is less costly and provides
better service at less risk than do the other approaches. The
hybrid system approach reflects the programmatic shift in
monitoring strategy as being developed by the Agency's Standing
Air Monitoring Work Group (SAMWG). This programmatic shift
will require far less raw ambient data for Headquarters and
regional use and will free states and local agencies to allocate
more monitoring resources for special-purpose local projects.
(1) Three Major Computer System Design Alternatives Could Be
Used to Manage Air Quality Data.
EPA could adopt three different computer system design
philosophies for managing air quality data, as follows;
A utility approach in which states input all
ambient data into a centralized EPA-operated
data base
A hybrid approach in which the bulk of data
resides on state data files with a subset
stored centrally on an EPA data base
The current approach in which data are stored
both on state data files and centrally on an
EPA data base
Exhibits 6-2 through 6-4, on the following pages, illustrate
the flow of data between state offices and EPA for each
alternative. Each approach represents a generic type of
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Exhibit 6-2
U.S. Environmental Protection Aqency
Utility Air Quality System Alternative
NAQTS
Data
SLAMS
Data
State-collected
Special Purpose
Monitoring Data
State
Office
EPA
Headquarters
Regional
Offices
EPA
Computer
INAQTS Data
5LAMS Data
Special Purpose
Data
1 NAQTS - National Air Quality Trend Stations
2 SLAMS - State and Local Air Monitoring Stations
203
-------
Exhibit 6-3
U.S. Environmental Protection Aqency
Hybrid Air Quality System Alternative
1
NAQTS
Data
2
SLAMS
Data
State-collected
Special Purpose
Monitoring Data
•••••^••••1
State (NAQTS Data)
' Office *"
v1**.
%fT^^.
•fr*t?o ,• ^^^
\ ^4?<>-
\ ^<£?e
V ***>
\
State f NAQTS Data
_ . \SLAMS Data
Computer \
Special Purp
Data
EPA
Headquarters
Regional
Offices
ose
^_^ FPA JNAQTS
~m . pata ^'
Computer I o
1
-------
Exhibit 6-4
U.S. Environmental Protection Agency
Current Air Oualitv cvster" Alternative
NAQTS
Data
SLAMS
Data
State-
collected
Special
Purpose
Monitoring
Data
State
Office
tState-collected
Monitoring Data)
•>
FPA
Headquarters
Regional
Offices
n
.3
FPA
Computer
f N^OTP Data
TSLAMS Data
1 Special
^ Purpose
Data
State
Computer
I*
NAQTS Data
I SLAMS Data
{Special Puroose
j Data
1 NAQTS - National Air Quality Trend Stations
2 SLAMS - State and Local Air Monitoring Stations
-------
system design. In turn, each generic type may have different
technical variations involving minor differences in data
flows, management and reporting responsibilities.
The utility alternative assumes that state offices would
communicate to a central air quality data base at an EPA
computing facility. All state-collected data, including
State and National Air Quality Trend Station data (as de-
fined by SAMWG) and special purpose monitoring data, would
be maintained centrally. Both EPA and state offices would
utilize the same data base for analysis. This approach is
similar to the system design for STORET, EPA's storage and
retrieval system for water quality data.
The hybrid alternative presumes that most air quality data
would reside on state data bases. States would utilize
their own air quality data systems to edit, update and
analyze local data. A subset of this data, National Air
Quality Trend Station (NAQTS) data, would be communicated
to EPA and stored on a central data base for analysis. Those
states which require air quality data systems support but
could not operate their own system economically could trans-
fer their data to EPA regions or Headquarters and could rely
on regional or central systems for update and report retrieval
of local data. Some Regional Offices may elect to operate a
206 index systems inc
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CDHS system either on the central EPA computer or on a regional
mini-computer. The regional systems could be used to provide
automated support to smaller states or to provide supplemen-
tary information regionally as may be defined in the future
by SAMWG. In most cases under the hybrid approach, Regional
Offices and others requiring summary statistics or raw data
from non-National Trend Monitoring Stations would obtain
this information, as needed, from the state office which
collects this special purpose data.
The current alternative is represented by the current
SAROAD/AQDHS-II system design. State offices and EPA would
continue to maintain separate systems operating at their
respective computer facilities. All state-collected data
would be transferred to EPA, periodically. EPA would utilize
its own data base for analysis and would supplement its
information, when necessary, by communicating with state
offices.
(2) The Hybrid and Utility Design Approaches Provide Better
Functional Service to EPA and State Offices Than Does the
Current Approach.
Hybrid and utility system alternatives for air quality data
would improve data handling and correction capabilities and
207 index systems inc
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would offer Headquarters and states flexible reporting and
good data availability. Exhibit 6-5, on the following page,
illustrates these advantages by comparing the functional
service provided by the three alternatives to Headquarters,
regional and state users.
The current design approach provides EPA and states with
good data availability and reporting flexibility since each
group uses its own data base for analysis. However, as a
result of the large volumes of data transferred and the
relative distance and processing steps between the sources
of data and the EPA users, data handling and correction
delays are created which contribute to completeness and
currency problems of EPA-maintained data.
A utility design would improve the functional service to
EPA. On the other hand, state service would be reduced
with a utility approach because a large centralized data
base would not allow for customized reporting to the same
degree as would a state data base. Although a utility
approach would eliminate date reconciliation problems be-
cause data would be entered only once, the size of the data
base and associated system management problems would create
additional operational problems.
208
index systems inc
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Exhibit 6-5
U.S. Environmental Protection Agency
Functional Service Air Quality
Data System Design Alternatives
Reporting
Flexibility
Data
Availability
Data Handling
Editing and
Correction
Overall
Functional
Service
Utility
S R
Fair
Good
Good
Good
Good
Good
H
Good
Good
Good
Improved data
handling with good
availability of
state-collected air
quality data
Hybrid
S R H
Very
Good
Very
Good
Good
Fair
Fair
Good
Good
Good
Good
Improved data
handling with good
availability of
monitoring trend
data
Current
S R H
Very
Good
Very
Good
Good
Good
Good
Poor
Good
Good
Poor
Good data
availability and
reporting flexi-
bility but with poor
data handling
CTi
O
CN
S = State Offices
R = Retional Offices
H = Headquarters
-------
The hybrid approach would improve data handling because less
data would be transferred to EPA and fewer opportunities for
errors would arise. Current SAMWG estimates indicate that
90% of the current reporting stations could be eliminated
from the central EPA data base under the hybrid approach.
States would be serviced equally well by current or hybrid
designs since the states would maintain control over their
own data bases and reporting. However, state-collected
special study data would not be as available to regional
offices under the hybrid approach. Regional offices would
need to rely on states to supply data in support of various
special programs, such as modeling applications.
The hybrid and utility approaches are comparable in functional
service because each approach would service the states and
Headquarters well while improving data handling and correction.
Regional offices and others requiring non-national trend data
would deal with data availability problems by communicating
with state offices, as needed.
(3) The Hybrid Approach Is Slightly Less Expensive Than the
Other Alternatives.
A hybrid approach for air quality data would reduce slightly
aggregate computer operating costs for EPA and state offices
yet would entail development and installation costs comparable
to those necessary to support the current design philosophy.
210 index systems inc
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Exhibit 6-6, on the following page, contrasts various cost
considerations for the three alternatives. Appendix B
presents more detailed derivations for the development and
operating costs associated with each of these alternatives.
The combined computer operating costs to EPA and state
offices with the current design approach are estimated to
total $800,000. These estimates assume the completion of
currently contracted modifications to reduce the operating
costs of SAROAD. Included in the total cost estimate is
the cost of additional data reporting that states provide
to EPA because of EPA data correction problems resulting
from reconciliation of the separate data bases. The system
modifications and development work associated with AQDHS-II
together with installation costs for additional states are
estimated to total $330,000.
The computer operating costs for a utility design would be
lower than those incurred with the current approach. However,
the costs associated with developing and installing a user-
oriented utility system would be $600,000 to $1,000,000. The
utility approach would allow larger states to reduce manpower
slightly but would require a slight increase in EPA staffing.
Overall, comparable numbers of personnel would still be needed
to handle data, initiate reports, coordinate and customize
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Exhibit 6-6
U.S. Environmental Protection Agency
Cost Evaluation Air Quality
Data System Design Alternatives
Utility
Hybrid
Current
Computer
Operating Cost
$700,000
$600,000
$800,000
Development and
Installation
Cost
$ 600,000
$1,000,000
$380,000
$330,000
Personnel
Cost
Lower by
approximately
five people*
Same as
present
Sane as
present
* This reduction could be translated into $75,000
212
-------
system usage and oversee system update and operations. Net
personnel savings in the states and EPA are estimated not to
exceed five positions.
The computer operating costs for a hybrid approach are esti-
mated to total $600,000, which is lower than the other two
alternatives. The development and installation costs would
be comparable to the current approach but lower than the
utility approach. In addition, personnel costs would be
similar to the levels experienced with the current design.
However, these staffing levels would be sufficient to insure
timely submission and correction of national trend station
data. By contrast, these same staffing levels have proven
inadequate to insure timely submission and correction of data
under the current approach. Regional offices have indicated
that as much as one extra person per region might be needed
to insure the accuracy of current volumes of data.
The hybrid approach is perferable because combined EPA and
state computer operating costs are lower than the other
alternatives and because system development and installation
costs are comparable to those that would be incurred under the
current mode of operation.
213 index systems inc
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(4) The Hybrid Approach Is the Least Risky of the Three
Alternatives.
A hybrid system design would offer EPA lower technical and
cost risks than the utility or current approach. Exhibit 6-7,
on the following page, compares risk and timing considerations
for the three alternatives.
The current approach presents a fairly high technical risk
to EPA because of the large EPA data base size and the
related UNIVAC system problems. The associated cost risk
is moderate, but manageable, because EPA and states control
their own systems,, that is, states can decide for themselves
how much special purpose storage and retrieval is cost-
effective without requiring that EPA store all state-desired
data as well.
On the other hand, the utility approach would present a very
high technical and cost risk potential because many users
would be dependent upon one large centralized system for all
air quality data. Therefore, EPA would need to store all
state-desired data whether or not these data were relevant
for national reporting or analysis. Moreover, because of the
service philosophy associated with the utility approach, data
base size and operating costs would not be controlled easily.
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Exhibit 6-7
U.S. Environmental Protection Agency
Air Quality Data System
Alternative Design Risks
Utility
Hybrid
Current
Technical Risk
Highly sensitive
to hardware
problems
Less sensitive
to hardware
problems
Sensitive to
hardware
problems
Cost Risk
Data base size
and operating
costs not easily
controlled
EPA and state
control of
respective
operating costs
EPA and state
control of
respective
operating costs
Timing
1-2 Years
2-3 Years
1-2 Years
Overall Risk
High technical
and cost risk
Low technical
and cost risk
Moderate
technical risk
215
-------
Conversely, the hybrid approach would present a lower technical
risk to EPA because EPA would maintain a much smaller data
base consistent with the SAMWG data reporting requirements.
Similarly, the cost risk would be reduced since the majority
of data processing would be controlled by the states who, in
turn, would be free to decide and pay for whatever data they
needed for local purposes. However, the hybrid approach may
require more time to become operational than would the other
alternatives because it presupposes a coordinated phasing of
data system strategy with SAMWG monitoring strategy.
Overall, the hybrid approach is preferable because of its
lower technical and cost risks.
(5) Management Considerations Favor the Hybrid Approach.
A hybrid design for air quality data would provide EPA with
a system which is easy to manage and which would not entail
heavy dependence of states on EPA-provided ADP support.
Exhibit 6-8, on the following page, compares three management
considerations for the feasible alternatives.
With a hybrid approach system management problems would be
limited since EPA and states would maintain their own systems
and only a small amount of data would be subject to recon-
ciliation problems. However, EPA would be forced to rely
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Exhibit 6-8
U.S. Environmental Protection Agency
Management Considerations of Air
Quality System Design Alternatives
Utility
Hybrid
Current
EPA Dependence
on States
EPA relatively
independent
of states
EPA dependent
on states for
special study
data
EPA relatively
independent
of states
State Dependence
on EPA
States highly
dependent on EPA
for ADP support
States
independent
of EPA
States
independent
of EPA
Ease of System
Management
Very complex
system which
is difficult
to manage
Easy to manage
at EPA and
state levels
Easy to manage
at state level
but sensitive
to hardware
problems at EPA
Overall
Management
Evaluation
High system
management pro-
blems with state
dependence on EPA
for ADP suDoort
Good ease of
system management
with EPA depen-
dent on states
for special study
data
Low dependence
of EPA and
states upon
each other
217
-------
on states to supply non-national trend data, as needed, to
support various special studies. On the other hand, state
dependence upon EPA for ADP support would be maintained at
a relatively low level. Furthermore, the hybrid approach
would be consistent with the data reporting and handling
requirement which SAMWG is developing currently.
The current approach presents more system management problems
than a hybrid design would present because of the large EPA
data base and associated data reconciliation problems. With
the current design, EPA dependence upon state offices is
better than the hybrid approach since EPA has its own data
base to support special studies. Still, EPA would need to
communicate with states to reconcile data and to acquire
missing data, as at present. Under both the current and
hybrid design approaches, states would not need to depend
heavily on EPA systems support.
The utility approach would impose more difficult management
problems. Management difficulties would increase as a
natural result of the use of a large central data base to
service a diverse set of users whose system objectives
would tend to differ over time. Although a utility approach
would reduce the dependence of EPA on state offices for
additional data support, states would be much more dependent
upon EPA for ADP resources than under the hybrid or current
218 index systems inc
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approaches. EPA managers have indicated that minimizing state
ADP reliance on EPA is a very significant policy objective
and that the federal-state political relationship can be
serviced best by allowing the greatest state flexibility.
This concern has resulted from state fears that Congressional
budget pressures could force EPA to sever its continuing
support for utility-type services to the states which, in
turn, would impose serious information processing problems
on state programs.
The hybrid approach is preferable because it entails the
fewest system management problems and does not increase
state dependence upon EPA for ADP support above current levels.
(6) The Hybrid Approach for Air Quality Data Could Be Imple-
mented by EPA Over a Two-to*Three-Year Period.
The implementation of a hybrid system design for the manage-
ment of air quality data would require phased action steps
over a two-to-three-year period. This transition from the
current approach to a hybrid approach would be coordinated
with the SAMWG-proposed changes in monitoring strategy and
could be accomplished through eight actions, as follows:
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Define the EPA air quality data reporting and
handling requirements associated with the
monitoring strategy developed by the Standing
Air Monitoring Work Group (SAMWG)
Complete modifications to AQDHS-II and proceed
with state installations
Identify several prototype states to test new
data reporting requirements associated with the
SAMWG study over a period of at least six
months
Define procedures for EPA regions and Headquarters
to acquire detailed state-maintained non-national
data, when needed
Define summary and violations data needed by EPA
for management analysis
Conduct preliminary system design and prototype
tests for ambient violations reporting
Define procedures for EPA support for those states
without data systems
After prototype testing, develop a phased plan for
other states to change data reporting to EPA over
a one-to-two-year period
These actions would require planning and coordination
between Headquarters, regional and state offices in order
to insure that functional service would be maintained for
system users during the system design transition period.
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2. CHANGES IN DESIGN PHILOSOPHIES FOR EMISSIONS AND COMPLIANCE
DATA SYSTEMS WOULD PRODUCE ONLY MARGINAL BENEFITS AT HIGHER
COSTS THAN PRESENTLY INCURRED.
Major changes in other air data system designs are not cost-
justifiable at this time. Only marginal benefits would be
realized by changing the current system design approach for
managing emissions data. Likewise, the integration of CDS
and NEDS or the consolidation of air research data would pro-
duce no substantial benefits.
(1) Changing the System Philosophy for Managing Emissions
Data Would Not Reduce ADP Expenditures*
Emissions data are used by EPA and state offices to sup-
port nine activities as follows:
Revising and evaluating SIPS
Reviewing new sources
Preventing significant deterioration of air quality
Maintaining air quality standards
Running simulation models
Developing and revising emissions factors
Performing energy studies
Establishing new source performance standards
Developing national emission summaries
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EPA managers have questioned whether a different system
design, such as a utility or hybrid approach, would improve
the completeness and currency of the emission data used to
support these activities. In addition, preliminary SAMWG
data reporting requirements indicate that small point
source emitters could be eliminated from a centralized EPA
data bank. Although these small sources are important to
state and local agencies, SAMWG has indicated that EPA has
little, if any, need for such data. Exhibit 6-9, on the
following page, summarizes the advantages and disadvantages
associated with the utility, hyprid and current approaches.
For the purposes of analysis, the utility approach assumes
that most point sources in the nation are stored centrally.
The current approach allows for a phased elimination of
smaller sources from the data base, whereas the hybrid
approach assumes a massive reduction in the number of
stored sources and source parameters. As indicated in the
Exhibit, the current approach remains the most practical.
A hybrid system design does not represent a feasible alter-
native at this time since EPA emissions information require-
ments could not be serviced adequately if this approach were
adopted. With a hybrid approach the majority of emissions
data would reside on the state data bases. As a result,
Headquaters would not have the necessary national emissions
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Exhibit 6-9
U.S. Environmental Protection Agency
Summary of Emissions Data System
Design Approaches
Utility
Hybrid
Current
Computer
Operating Costs
$400,000
N.E,
$400,000
Development and
Installation
Cost
$ 600,000 -
$1,000,000
N.E.
$250,000
$430,000
Functional
Service
Good data
availability
and improved
data handling
Good data
availability
Headquater^and reporting
feasibility
Poor data
availability
for
programs
Risk
High technical
and cost risk
Low technical
and cost risk
Moderate
technical risk
Management
System manage-
ment problems
and state de-
pendence upon
EPA for ADP
support
Less complex
system manage-
ment
Low dependence
of EPA and
states upon
each other
N.E. = Not estimated because the hybrid approach would not
provide adequate functional support.
223
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data available to support a variety of air planning and
review activities. For example, the development and
evaluation of new source performance standards and EPA's
ability to analyze nationwide trends in industry emissions
of specific pollutants would be hindered. Also, analyses
associated with various energy studies could not be per-
formed adequately without national emissions inventories.
In addition, intra-regional activities, such as modeling
applications that cross state geographic boundaries, would
be hampered. For these data availability considerations,
the hybrid approach is not justified currently as a
feasible alternative.
A utility approach would provide for good data availability
as does the current approach. However, a large central-
ized data base would not allow for customized reporting to
the same degree as would separately controlled state data
bases. Although the utility approach would eliminate data
reconciliation problems between EPA and state data bases,
the large centralized data base would present a high tech-
nical risk because of associated computing resource require-
ments and the susceptibility to ADP hardware failures.
The aggregate computer operating costs to EPA and state
offices are estimated to total $400,000 for both the current
and utility approaches. However, the cost risk potential
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is less for the current approach because EPA and states
control their own system. The development and installa-
tion of a user-oriented utility system would be $600,000-
$1,000,000 whereas system modifications, development
work, and additional installation costs associated with
the current NEDS - EIS/PR are estimated to total $250,000 •
$430,000. Furthermore, by changing to a utility approach,
no substantial personnel reductions would be realized.
(Appendix B presents more detailed cost derivations for
these alternatives}.
Current and utility approaches present systems management
difficulties, while the current design creates data
reconciliation problems for EPA, a utility design would
be more difficult to manage because of diverse user re-
quirements. Also, states would be much more dependent
upon EPA for ADP resources with a utility approach.
As a result of the increased cost potential and technical
risk associated with the utility approach, the current
system design should continue to be used to manage
emissions data. However, EPA will heed to coordinate
any reductions in the scope of centrally-maintained point
source data with future SAMWG recommended changes in
emissions data reporting requirements.
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(2) The Integration of CDS and NEDS Would Not Reduce ADP Expenditures
Air program and enforcement managers have questioned whether
emissions and enforcement data should be integrated into a
single data base in order to improve reporting capabilities
and reduce computer operating costs. They have suggested
that the consolidation of the two systems would eliminate
redundant data storage and would enable analysts to relate
compliance status to emission abatement.
Although the two systems both contain data about station-
ary sources, less than 10% of the actual data values stored
within the systems are common to both CDS and NEDS. Con-
sequently, under an integrated system neither the volume
of transactions nor the size of the data base would be
reduced substantially. In addition, the sources of CDS
and NEDS data differ so that consolidated data entry would
not be feasible. Overall, an integrated system would not
reduce operating costs but would require new systems devel-
opment expenditures of at least $200,000.
Furthermore, the integration of data bases would not im-
prove substantially the functional service to EPA, since
most EPA personnel who need emissions data and those that
need compliance information tend not to need both. Air
program personnel use emissions data for planning, review
and abatement activities, whereas air enforcement personnel
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need source compliance information to monitor conformity with
SIP regulations. NEDS emission calculations are not current
or precise enough to support enforcement actions. Rather, en-
forcement personnel use data acquired from source inspections,
114 inquiries and stack tests to support enforcement actions.
Air program personnel use source compliance status data to
support limited planning and review functions. NEDS currently
has a facility for storing a one-character compliance status
indicator which is sufficient for planning purposes.
In addition, the integration of CDS and NEDS would create
substantial system management problems. Currently, CDS is
supported by the Division of Stationary Source Enforcement
(DSSE) within the Office of Enforcement and NEDS is supported
by the National Air Data Branch (NADB) within the Office of
Air Quality Planning and Standards. An integrated data base
would be difficult to maintain because of the coordination
and communication problems that would result from the differ-
ent geographic locations and distinct organizational respon-
sibilities of the system users. Also, the nature and timing
of the compliance data flows differ from those associated
with emissions information. These differences in data sources,
timing and management responsibilities would cause serious
disruption in functional priorities and services. The inte-
gration of CDS and NEDS would not improve system capabilities
substantially nor would it reduce computer costs appreciably.
Consequently, the current separate system approach remains
the most practical.
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3. TECHNICAL SYSTEM ACTIONS COULD IMPROVE FUNCTIONAL SERVICE
AND SYSTEM EFFICIENCIES.
Various system modifications to improve data base design and
to reduce computing resource requirements would make current
data systems less susceptible to UNIVAC system failures. These
changes would make the transfer of various air systems to another
computing facility inappropriate and unnecessary. Additional
system modifications to NEDS, SAROAD and CDHS, however, could
streamline system operation further and, as a result, could
improve system utilization.
(1) Additional SAROAD Modifications Could Streamline System
Operation Still Further.
The current contractor modifications to SAROAD should im-
prove system efficiency by at least 50% and, as a result,
should improve data availability to the various system
users. However, three additional SAROAD design modifica-
tions could further reduce processing time and make SAROAD
more responsive to user needs, as follows:
Modify the method for calculating running
averages for certain pollutants
Revise the timing of summary and frequency
file creation
Develop a violations file
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The specific cost impact of each of these changes will
depend heavily upon the results of current contractor
enhancements. Whether or not to undertake these changes
will depend therefore upon the resulting SAROAD efficiency
and processing characteristics once the current enhance-
ments are completed.
Current enhancements will cause running averages to be cal-
culated from hourly monitoring data for SO-, NO-, and CO
during the update of raw data. As a result, 38% of the
values stored on the less-than-24-hour raw data file will
be associated with running averages. However, storage
costs could be reduced if running averages were not stored
but were calculated and reported only when needed. Whether
or not the frequency and distribution of running average
requests would justify this design change cannot be ascer-
tained from current NADB report logs. Instead, NADB should
track reporting activity once the enhancements are com-
pleted to determine whether running averages need to be
stored or could be recalculated when needed.
Under current modes of operation, summary and frequency
files are created after each raw data update. However,
the two processing steps do not have to be executed con-
currently. Instead, computer operating costs could be
reduced if the summary files were created at fixed time
intervals over the year independently of raw data updates.
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Various system users rely on SAROAD retrievals to pro-
vide information on air quality standards violations.
Presently, this reporting is accomplished by comparing
collected ambient data averaged over the appropriate
time interval to the associated NAAQS. Computer proces-
sing time could be reduced, however, if a violations file
were created which indicated all violations for a given
site and time period. In this way, subsequent calcula-
tions would not be needed to reidentify violations for
other analyses. Violations could still be calculated
from raw data files, however, if ambient values were
changed or if analysts wished to evaluate the violations
impact of changed ambient standards.
None of these changes can be cost-justified at present
with currently available information. Instead, NADB will
need to analyze the costs and benefits of these proposed
changes after current modifications have been completed.
Three areas could be analyzed in order to evaluate ac-
curately these costs and benefits, as follows:
Evaluate SAROAD modifications over a two-to-four
period to ascertain achieved processing effic-
iencies
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Analyze the frequency of various retrievals
by system user and determine the geographic
distribution of retrieval requests
Analyze the frequency of redundant violation
calculations
This information is not available now because SAROAD mod-
ifications are still underway. However, it is anticipated
that the frequency of retrievals will increase as the en-
hancements provide improved data availability.
(2) EPA and Emissions Inventory Information Support Could
Be Improved Substantially Through Minor Enhancements to
NEDS Edit Procedures.
Current enhancements to NEDS, including a regional edit
capability and improved update efficiencies, will not be
sufficient to improve emissions inventory accuracy and
currency because regions still will have only limited
editing capabilities. Many edit checks, and all valida-
tion checks, are scheduled to be performed during the
NADB-initiated update and therefore cannot be executed
by regions. As a result, regions still will have to wait
two-to-three weeks to receive update listings and valida-
tion reports from NADB. These processing characteristics
will continue to require extra regional effort to reconcile
errors and will delay further the input of corrected NEDS data.
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If regions had the ability to run validation checks and
to edit input cards against the user file, then these prob-
lems would be reduced substantially. Current contractor
efforts to modify the NEDS edit could be redirected to
this end for only a minor additional cost since current
enhancements have not yet been finalized and since the
design specifications employ a modular approach, which
could facilitate the redesign of the edits to run indepen-
dently of the update.
This enhanced complete regional NEDS edit capability, sim-
ilar to that offered by SAROAD, is necessary to maintain
higher emissions inventory data quality and to facilitate
regional processing efforts. This enhancement, in addition
to the improved reporting capability which has recently
been made available to regions, should improve significantly
NEDS data accuracy problems. Approximately $5,000 - $10,000
in additional contractor funds are needed to give regions
this enhanced edit capability.
It is anticipated that these changes should increase sub-
stantially the number of states submitting data to EPA on
time. To date, some states have not been submitting data
regularly because they felt that NEDS did not work. Fur-
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thermore, in some cases, regions have not discouraged
this attitude because they were backlogged with data
themselves and, as a result, were unable to input data
quickly enough to maintain the data base currency. A
workable system should improve state and regional re-
porting response.
(3) EPA Could Improve CPUS Performance by Proceeding With Five
Identified System-related Actions.
Pressure for dependable CDHS support will increase sub-
stantially as EPA moves towards a hybrid approach for
their management of ambient air quality data. Without
enhancements, neither EIS/PR nor AQDHS-II would meet
the data flow timing requirements of EPA and states
as effectively as would be needed to support a hybrid
systems approach. Rather, state and EPA users of hybrid
systems would require better reporting, editing and tracking
capabilities than are provided by CDHS at present. These
features could be provided through five NADB-identified
CDHS actions, as follows:
Conduct review of states for both EIS/PR and
AQDHS-II to identify additional system enhance-
ments necessary to meet state information needs
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Complete current identified modifications to
CDHS
Perform additional enhancements to CDHS re-
porting capabilities as specified by state users
Improve current data handling procedures for
CDHS by incorporating more extensive edit capa-
bilities
Review and develop interface procedures between
state-operated systems and EPA-maintained systems
The completion of currently identified CDHS modifications
is necessary to improve the effectiveness of the system
to state users. In addition, a joint EPA/contractor review
of state users would identify additional areas for function-
al system enhancement. For example, many states have indi-
cated that they would prefer EPA to develop more standard
CDHS reports. A state review would provide EPA with a
consolidated needs statement which would facilitate cen-
tralized enhancement efforts.
Improved data edit and validation procedures for CDHS would
facilitate the transmittal of state data to EPA and would
reduce the manpower required to correct data anomalies.
Furthermore, improved CDHS/AEROS interfaces would eliminate
the need to track data transmittals manually.
NADB has requested funding for these CDHS actions and has
developed plans for their implementation during 1977. These
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CDHS enhancements will improve the usefulness of
state-operated data systems and thereby service more
effectively EPA and state information requirements.
(4) The Transfer of Various Air Data Systems From the National
Computing Center (NCC) to Another Computing Facility Is
Not Cost-Justified at This Time.
EPA systems personnel have questioned whether the transfer
of air data systems to a system environment more stable
than the NCC would improve the usefulness of the systems.
They have suggested that data processing operations could
be performed in a more timely manner and that the accessi-
bility of information would improve if data systems were
operated on a facility that was less prone to frequent
system crashes and prolonged downtime.
Although the NCC has experienced hardware and software
problems since the beginning of the year, these difficulties
are expected to be resolved and performance, improved
in the future. In addition, various system modifications
are being implemented to improve data base design and to
reduce computing resource requirements. These modifications
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should make the current data systems far less susceptible
to computer failures.
In addition, the costs for running jobs at NCC will remain
lower than the costs for running these programs at other
EPA facilities such as OSI. EPA computer planning and
operations personnel estimate that air systems costs at
OSI would cost almost double the charge at NCC. In
addition, since EPA owns the UNIVAC, the cost to the
Agency for operating the UNIVAC would be incurred regard-
less of the computing load at NCC. As a result, overall
agency ADP expenditures would increase if current NCC-
operated systems were transferred to OSI or other computer
facilities.
Should UNIVAC performance deteriorate once again, however,
and should the dramatic reductions in AEROS processing
time requirements not prove sufficient to allow adequate
turnaround, then EPA will need to reconsider the possibility
of moving AEROS to another computer. In particular, EPA
should await the completion and testing for several months
of current design changes before reconsidering such a move.
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(5) A Management Audit of the Energy Data System Would
Establish Whether the Current System Design Efficiently
Fulfills Its Intended Purposes.
Energy Data System ADP costs have caused various EPA
system managers to question the feasibility of the EDS
system design and operation.
EDS was developed under contract to SASD in order to
satisfy three needs, as follows:
To provide an automatic means of correlating
energy-related data from various sources
To provide quicker turnaround of data analysis
than would be available otherwise
To provide an easier means of correcting erroneous
data than is available for related systems
The energy data base currently maintains over 58 million
characters on-line. The data base is increasing this year by
approximately six million values. The data base size is ex-
pected to grow at a lesser rate in future years depending upon
system manager and user needs. A large portion of these data
are stored also in other AEROS systems. NADB managers have
questioned whether the computing resources necessary to
support the storage of this volume of redundant data are
warranted. EDS support personnel estimate that FY 77 ADP
costs will be $300,000. However, the original EDS feasibility
study, which was used to authorize the system, had projected
that ADP costs would average only $25,000 per year. However,
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the feasibility study did not anticipate that EDS would con-
tinue to require ADP expenditures for on-going enhancements
and reporting. EDS managers have estimated that approximately
$190,000 to $219,000 of these ADP costs are used for these
enhancements. In addition, the structure of the data bases
which supply information to EDS has changed since the original
EDS feasibility study in 1974. As a result, EPA system mana-
gers have suggested that a different system design which
directly accesses the principle source data bases may be
more efficient than the current EDS design.
EDS system managers argue that because of the atl hoc nature
of data requests, most system inquiries require a selective
flexibly formatted reply within one day in order to be meaningful
to decision-makers. Although this short response time and
flexibility may be optimal, this rapid turnaround, in itself,
may not cost-justify an interactive retrieval system. Further-
more, proposed modifications to the supplying AEROS data sys-
tems should improve their response time so that one-day
turnaround might be possible from AEROS and thereby obviate
the need for some of EDS's more expensive capabilities.
A common complaint expressed by various EDS users has been
related to the completeness and currency of data contained
in the supplying data systems. EDS system managers have ex-
pressed a need to update and to change data in EDS indepen-
dently of changes in the other systems. Such modifications
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create data reconciliation problems between EDS and
the supplying systems. Moreover, subsequent data trans-
fers from emissions and air quality data bases could re-
place corrected data with erroneous data if the data base
management between the affected systems were not coordi-
nated.
A management audit is needed at this point in time to
determine in what manner system operations should continue
and to determine the level of ADP resources needed for
continued EDS support. A management audit would answer
five questions, as follows:
For what purpose is EDS used? By whom?
What are its information system require-
ments?
Presently, how does EDS satisfy these re-
quirements?
How efficient is EDS as an information
storage and retrieval system?
Are the ADP costs of EDS justified
in terms of decisions for which the sys-
tem supplies data?
Who should retain management responsibil-
ity for EDS?
This audit would enable EPA management to ascertain the
value of the current system and to determine whether ad-
ditional resources should be applied to it.
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4. THE CLARIFICATION OF MANAGEMENT RESPONSIBILITIES WILL IMPROVE
THE DEVELOPMENT AND USE OF AIR DATA SYSTEMS.
The development and operation of selected air data systems
could be enhanced if EPA system managers would utilize more
rigorous ADP management principles and would employ tighter
controls on the use of computing resources.
(1) The Development and Operation of Air Data Systems Could
Be Improved by Centralizing System Management Responsi-
bilities Within OAQPS.
The management of system development efforts and data
system operations requires full-time monitoring by per-
sonnel with a sound foundation in ADP management prin-
ciples. This is necessary both to insure that data sys-
tems make efficient use of computing resources and to
coordinate system development and operations between
interrelated data systems.
The National Air Data Branch (NADB) is the organization
within OAQPS with the widest expertise in system develop-
ment and operation. NADB has been responsible for most
of the data system development and operations associated
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with air program data systems. In those cases where
NADB has not been primarily responsible for system man-
agement, such as with EDS, ADP management principles
have not always been employed because of the unavaila-
bility of experienced ADP managers. In these instances,
feasibility studies and design efforts have been under-
taken without a full appreciation of the potential cost
and complexity of seemingly simple system features.
Only organizations with sufficiently broad and extensive
experiences with multiple systems can be expected to
have the level of expertise necessary to manage large
development activities. For this reason, system manage-
ment responsibilities should be centralized in OAQPS
within NADB and should be administered by those personnel
with the most experience and training in ADP management
practices. However, in order to insure adequate service
to the other divisions within OAQPS, NADB should receive
formal direction from OAQPS senior management regarding
office-wide priorities and support responsibilities.
C2) A Detailed Technical and Operating Analysis of the UNIVAC
and Its Management Is Needed to Improve Computer Reliability.
NCC's recurring hardware failures have caused significant
delays and complications for the air data system and other NCC
users. A detailed analysis of hardware malfunctions, throughput
volumes, channel capacities and operating system performance is
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needed to isolate specific areas for technical improvement.
In addition, this analysis would examine the effectiveness of
current NCC organization, management procedures, staffing levels
and contractor utilization. As a result of such an analysis,
EPA could determine whether or not to shift its current opera-
ting mix of batch and demand processing, to curtail future
hardware changes or to revise its current data center manage-
ment structure. This analysis is estimated to cost approxi-
mately $50,000.
(3) The More Widespread Utilization of Standard EPA ADP
Policies and Procedures Would Force a Closer Alignment
of System Capabilities with High Priority Program Needs.
In order to improve system effectiveness and performance,
EPA system managers should adhere to EPA policies and
procedures in three ADP related areas, as follows:
Development and review of system feasibility studies
Data system design and use
Consistent documentation and training
Appropriate guidelines and procedures for these areas are
discussed in the EPA Automated Data Processing Manual and
other related documentation.
Although managers and technical personnel within NADB and DSSE
have tended to conform to these principles, systems personnel in
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other parts of OAQPS and ORD have not always been as rigorous
in their use of formal development controls. The contracting
office in RTF has allowed some systems development projects
to proceed without requiring formal and separate feasibility
studies. For example, work is currently underway to enhance
the CHAMPS data system using contractor personnel. This con-
tractual effort was initiated without explicit design objectives
or acceptance conditions established. Instead, the statement
of work specified that the work effort would include both a
feasibility analysis and development effort by the contractor.
EPA system managers often utilize contractors to develop
feasibility studies for proposed data systems. However,
conflicts of interest and objectivity problems arise when
the same vendor is asked to assess the need for and to
build a system. Accordingly, contracting officials should
write and award feasibility study contracts independently
of subsequent system design efforts so as not to compro-
mise contractor efforts and to assure that an adequate
cost-benefit analysis is performed. Furthermore, feasi-
bility study preparation should be overseen and reviewed
subsequently by EPA personnel with appropriate ADP manage-
ment and technical expertise and not solely by program
personnel with little or no systems background.
In addition, air data systems should make use of consistent
documentation conventions and user training material. At
present, air systems documentation and user training vary
among the systems depending upon the standards employed
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by the original system developers. NDB has established
documentation conventions to be used for all systems
operated under its jurisdiction. These same guidelines
should be applied to systems operated within ORD and to
those CDHS systems provided to states.
(4) Tighter Controls on the Use of ADP Resources Need to Be
Employed by EPA System Managers.
As a result of Agency-wide ADP budget constraints, tighter
controls on the use of ADP resources will need to be em-
ployed by EPA system managers. Since a plan has been pre-
pared to develop the NCC into an Agency-wide resource which
will be priced competitively with the IBM computer at OSI,
MIDSD anticipates that the competition for UNIVAC resources
will increase. As a result, not all air program computing
requests will be satisfied. Consequently, EPA system
managers will need to analyze their ADP utilization to in-
sure that current and future applications operate effi-
ciently in order to free enough system resources to preserve
sufficient funds for high priority or emergency projects.
Better computing accounting records than have been main-
tained currently would provide system managers with more
detailed information on ADP utilization. System managers
should establish ADP project codes to reflect the develop-
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ment, maintenance and reporting costs associated with
the various data systems and system users. With these
sub-categories, system managers could ascertain the ADP
costs associated with data reporting for program offices
other than their own. Furthermore, this cost information
could provide MIDSD with a basis with which to reallocate
portions of various ADP sub-allowances to reflect the data
reporting that one program office performs on behalf of
another.
In summary, over the next two^to-three years a fundamental change in
the data system philosophy employed by EPA will be needed to manage
air quality data. A hybrid system design approach will improve
service to EPA while reducing associated operating costs. On
the other hand, comparable design changes to other systems will
not be needed. Rather, technical system changes will suffice in
improving system efficiencies and usefulness and thereby will
minimize many of the data handling and reporting problems which
have been experienced to date. These changes will require also
certain shifts in ADP resource allocations and management re-
sponsibilities. Overall, air data system design and utilization
need not undergo major additional changes, but rather can evolve
in a more gradual manner to satisfy changing functional require-
ments .
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VII. RECOMMENDATIONS
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VII. RECOMMENDATIONS
This chapter presents the recommended actions which EPA
should perform in order to improve the effectiveness and
functional adequacy of the air data systems. The recom-
mendations are grouped into three categories, as follows:
Actions to implement a hybrid system for
the management of air quality data
Technical system actions to improve air data
system efficiency and utilization
EPA management actions to improve ADP resource
utilization
In addition, this chapter presents the projected ADP
expenditures, contractor funding and EPA staffing asso-
ciated with the air data systems over the next two years.
The cost estimates for the proposed actions in this chapter
are summarized in Appendix B.
1. EPA SHOULD INITIATE FIVE ACTION STEPS OVER THE NEXT TWO-TO-THREE
YEARS IN ORDER TO ESTABLISH A HYBRID SYSTEM FOR THE
MANAGEMENT OF AIR QUALITY DATA.
EPA should adopt a hybrid system approach for managing
air quality data. The implementation of this hybrid system
should be phased over the next two-to-three years to facilitate
management control and to insure a smooth and non-disruptive
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phasing of individual states into the hybrid reporting
system.
The implementation process should be divided into five
steps, as follows:
Define data reporting requirements, procedures
and control agency grant implications
Identify prototype states to test new data require-
ments
Test prototype states over a six-to-nine month period
Assess performance after test period
Extend data reporting procedures to other states
Exhibit 7-1, on the following page, illustrates the time-
phasing for each action step. The segmentation of the
implementation process into well-defined phases will facili-
tate control by providing checkpoints whereby management
can evaluate the progress of each phase and initiate
corrective actions where necessary.
(1) EPA Should Define the Specific Date Reporting
Requirements and Procedures Needed to Support the
Air Monitoring Strategy Developed by the Standing
Air Monitoring Work Group (SAMWG).
OAQPS should develop a data system plan to support
the EPA air monitoring strategy and should assume
247 index systems inc
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Exhibit 7-1
U.S. Environmental Protection Agency
Tine-Phased Actions Step for Imple-
menting the Hybrid Air Quality
System
ACTION STEPS
Define data reporting
requirements and pro-
cedures
Identify prototype
states to test new
data requirements
Test prototype states
over 6-9 month period
Assess performance
after test period
Extend data reporting
procedure to other
states
3 months
3
months
9 months
3
months
CO
18 months
EPA Acceptance
of SAMWG
Recommendations
1st Year
2nd Year
3rd Year
-------
responsibility for its phased implementation. The
first step in this plan should be the definition of
the specific data reporting requirements and proce-
dures needed to support the monitoring strategy.
These procedure and requirements definitions should
include seven items, as follows:
Timing, mode and format of the raw national
trend station data to be submitted from state
offices to OAQPS
Specific summary and violations information
needed from states
EPA system requirements to support management
analysis of state summary and violations
information
Plans for additional installations of AQDHS-II
Procedures to interface with state-developed
data systems other than AQDHS-II
Procedures for EPA Headquarters and regional
offices to acquire non-national trend station data
from states
Procedures to support those states without
air quality data systems either with region-
ally-operated systems or with manual systems
These definitions can be formulated by OAQPS and regional
personnel should require approximately three months'
elapsed time after the publication of the air monitoring
strategy by SAMWG. Alternatively, this analysis
could be performed by outside contractors for approxi-
mately $25,000 during the same elapsed time period.
In addition, EPA should examine the implications of
249 index systems inc
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these changes on regulations and control agency grant
policies and revise these policies as deemed appro-
priate .
(2) OAQPS Should Coordinate With Regional Offices the
Identification of Several Prototype States to Test
the Monitoring Strategy Data Requirements.
Three states should be identified by EPA to serve
as prototypes in testing the data reporting requirements
and procedures associated with the EPA air monitoring
strategy. These states should be selected to reflect
four criteria classes, as follows:
Differing industrial and residential mixes
Different geographical and environmental
regions of the country
Varying population distributions
Varying local data handling and analysis
capabilities
The selection of these states should be a coordinated
effort between OAQPS, regional offices and interested
states. This identification and selection process
should be completed within three months after the
data reporting requirements are defined. During this
same time period, EPA should design and develop a
management summary and violations data system to
250 index systems inc
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process the summary data to be submitted by the state.
This management summary and violations data system
is estimated to cost $50,000 to design and implement
and may be developed from existing SAROAD reporting
modules.
(3) The New Data Reporting Procedures Should Be Tested
for the Selected Prototype States Over a Six-to Nine
Month Period.
The data reporting procedures should be tested for
the selected states over two or three reporting periods
so as to provide enough operating experience to
assess performance. In order to coordinate activities
during the test period, senior management within
OAQPS, regional and state offices must commit adequate
resources for support. Index estimates that one person
within OAQPS and one-half person in each associated region
and state office will be needed for the duration of
the test period to coordinate activities.
(4) After the Test Period EPA Should Assess the Performance
of the Data Reporting Procedures.
After approximately nine months of operation EPA
should assess the performance of the data reporting
procedures in the prototype states. The performance
251 index systems inc
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should be evaluated on three criteria, as follows:
Accessibility of data to users in support
of their respective program objectives
Cost history
Ease of management
With the assistance of the state offices, EPA should
identify problem areas and should develop solutions
before extending the procedures to additional states
Should special problems arise, it may be appropriate
to select additional prototype states and to test
for an extended period of time.
(5) EPA Should Extend the Data Reporting Procedures to
Other States Over an 18-Month Period.
After the problems associated with the new data re-
porting have been identified and solutions have been
— 7—-——
developed, EPA should extend the ljistribu_teq~approach
to other states in phased steps. To insure control,
EPA should rank states in terms of risk and priority,
and should implement the hybrid approach first
in those states which would be least susceptible to
a change in their data handling interaction with EPA.
In most cases, regional CDHS coordinators will take
responsibility for assisting the states in the reporting
changeover. The 18-month implementation period
252 index systems inc
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should be segmented so as to provide interim checkpoints
which would allow for periodic progress evaluation.
By the end of the implementation period all additional
AQDHS-II installations should be completed. Furthermore,
EPA should provide data processing support to those
states that require/but can not support economically,
automated data handling capabilities.
2. EPA SHOULD PERFORM FOUR TECHNICAL SYSTEM ACTIONS OVER THE
NEXT SIX MONTHS TO IMPROVE AIR DATA SYSTEM EFFICIENCY AND
EFFECTIVENESS.
The short-term changes to NEDS and SAROAD should be limited
to those currently contracted including the use of contractor
funds to implement CDHS enhancements. Before allocating
additional resources for EDS support and system enhancement,
however, EPA should conduct a system audit to reconfirm the
need for proposed new and expensive current features.
(1) EPA Should Conduct Immediately a System Audit of EDS
Before Assigning Additional Resources for Support and
Development.
EPA should conduct immediately a system audit of EDS
to determine the value of the current system and to
ascertain whether additional resources should be applied
253 index systems inc
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to support it. The statement of work for this audit
should include five areas for investigation, as follows:
The air program information requirements
to be supported by the system objectives
The adequacy of the current system in satisfying
these requirements
The efficiency of the current system design
Operating cost analyses in terms of the decisions
for which the system provides information
System management responsibilities
The estimated cost for the EDS audit is $15,000 and the
elapsed time is estimated to be three months.
(2) Short-Term Changes to SAROAD Should Be Limited to Those
Currently Being Performed by Outside Contractors.
Modifications to SAROAD should be limited to those currently
underway by contractors. Long-term changes should not
be authorized until a plan is developed by OAQPS for
the implementation of the hybrid approach for
managing air quality data and until NADB assesses
the performance of the current enhancements under a
stable AEROS software environment.
254 index systems inc
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(3) Modifications to NEDS Should Be Limited to Those Currently
Contracted Except That Data Edits Should Be Made Available
to Regional Offices.
Enhancements to NEDS should be limited to those currently
contracted, including a regional edit capability and im-
proved update efficiencies. Furthermore, the current con-
tractor efforts to modify the NEDS edit should be redi-
rected to provide the regions with the ability to run
validation checks and to edit input cards against the
user file. Approximately $10,000 in additional contractor
funds are estimated to be needed for this effort.
(4) EPA Should Use Its Budgeted $250,000 in Contractor
Funds for CDHS Enhancements.
EPA should maintain its support for CDHS by taking five
system-related actions, as follows:
Complete current identified modifications to
CDHS
Conduct review of states to identify additional
CDHS enhancements necessary to meet state infor-
mation requirements
Perform additional enhancements to CDHS reporting
capabilities as specified by state users
Improve current data handling procedures for
CDHS by incorporating more extensive edit capa-
bilities
Review and develop interface procedures between
state-operated systems and EPA maintained systems
255 index systems inc
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NADB has estimated that these enhancements will
require $250,000 in funds included in the FY 77
budget. The elapsed time for these actions is
estimated to be approximately 18 months.
3. AFTER CURRENT AEROS SYSTEM MODIFICATIONS ARE COMPLETED EPA
SHOULD EVALUATE SYSTEM PERFORMANCE BEFORE AUTHORIZING ADDI-
TIONAL ENHANCEMENT EFFORTS.
EPA should evaluate AEROS system performance after current
system modifications have been completed. This assessment
should be performed over a three-month period to evaluate
system efficiency and functional adequacy in a stable soft-
ware environment. After this test period, NADB should analyze
four areas for further modification, as follows:
Consider alternative methods for calculating running
averages for ambient data
Revise the timing of summary and frequency file
creation
Analyze the need for a violations file for ambient
data
Consider altering the scope of source emissions data
stored in NEDS consistent with any SAMWG recommended
change in data reporting requirements
This analysis is necessary to ascertain costs and benefits
of additional changes in light of the direction of future
air program data requirements. This analysis can be performed
256 index systems inc
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by NADB personnel and should not require outside contractor
assistance.
4. EPA SHOULD TAKE FOUR MANAGEMENT ACTIONS TO IMPROVE ADP
RESOURCE UTILIZATION.
System development and operation responsibilities should be
be centralized within OAQPS. MIDSD should conduct a detailed
analysis of the UNIVAC system problems. In addition,
MIDSD should encourage the use of standard ADP management
policies, especially within ORD, and should provide guidelines
to system managers on ADP accounting procedures and cost control,
(1) OAQPS Should Centralize System Operation and Development
Responsibilities.
System management and development responsibilities should
be centralized in OAQPS within NADB. Furthermore, in
order to insure adequate service to the other divisions
within OAQPS, NADB should receive formal direction from
senior OAQPS management regarding office-wide priorities.
The establishment of formal office-wide rather than divi-
sional priorities should eliminate the need for the other
divisions within OAQPS to develop new ADP systems on their
own.
257 index systems inc
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(2) NEDS and CDS Should Not Be Integrated and Separate System
Management Responsibilities Should Be Retained by OAQPS
and DSSE.
The current separate system approach for the management
of compliance and emissions data should be maintained.
Correspondingly, the system management responsibilities
for NEDS and CDS should be retained by OAQPS and DSSE,
respectively, as at present. In this way each organiza-
tion will continue to control its own data base in a
manner which is both practical and manageable.
(3) MIDSD Should Conduct a Detailed Technical and Operating
Analysis of the UNIVAC and Its Management.
MIDSD should conduct a detailed technical analysis of the
UNIVAC in four areas, as follows.
Hardware malfunction
Throughput volumes
Channel capacities
Operating system performance
This study should include an analysis of NCC processing char-
acteristics and performance with other comparable UNIVAC
installations. In addition, this study should analyze the
adequacy of current staffing levels, management procedures, use
of contractors and organization. As a result of this study
MIDSD should develop an organizational and operations plan to
index systems inc
258
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reduce the overall failure rate at NCC. This analysis is esti-
mated to cost $50,000 and could be completed within four months.
(4) MIDSD Should Encourage the Use of Formal ADP Management
Policies and Procedures.
ADP policies and procedures are discussed in the EPA
Automated Data Processing Manual and other related
documentation. MIDSD should encourage the use of these
procedures in four areas, as follows:
Development and review of system feasibility
studies
Data system design conventions and utilization
System and user documentation and training
Development of formal ADP budgets reflecting
full anticipated computer usage
The adherence by EPA system managers to these procedures
will reduce the likelihood of developing inefficient
data systems whose usefulness may be outweighed by their
costs. The Office of Research and Development, in particu-
lar, should be encouraged to adopt these standard ADP
management control procedures. Correspondingly, senior
ORD managers and their technical ADP support personnel
should stop treating ADP budgets as if they are inter-
changeable with other research funds and should begin to
manage their ADP sub-allowances more rigorously so as to
insure more effective use of computing resources.
259 index systems inc
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5. ADP EXPENDITURES IN SUPPORT OF THE AIR PROGRAM SHOULD REMAIN
RELATIVELY STABLE OVER THE NEXT TWO YEARS.
As a result of technical efficiencies, combined contractor
and ADP costs will not increase significantly compared
to current expenditure levels. Over the next two years
annual ADP expenditures will remain relatively constant
while contractor costs will decrease by an average of
$250,000 annually.
Exhibit 7-2, on the following page, compares FY '76 estimated
ADP expenditures by organization with the projected future
annual costs. OAQPS will experience the most significant
reduction in computer operating costs of approximately 40%
compared to FY '76 expenditure levels. The Office of
Enforcement has estimated that ADP expenditures will decrease
slightly over the next two years. On the other hand, regional
and state ADP costs will increase by approximately $375,000
as additional CDHS systems are installed and as local and
regional personnel assume more responsibility for data analysis
and modeling activities. Index has not been able to obtain
projected ADP operating costs from either ORD Headquarters
or laboratory personnel. However, we have estimated ORD
operating costs to increase by 20% annually to reflect
new system development and continued research analysis.
260 index systems inc
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Exhibit 7-2
U.S. Environmental Protection Agency
Projected ADP Operating Costs by
Organization
OAQPS
ORD
OE
Regions
States
TOTAL
1976
($000)
1656
857
54
300
300
3126
1977
($000)
1360
1000
50
300
380
^^^^^^^^^•^^^••••••^•^^^^^^••^•HMIBM^^
3090
1978
($000)
1066
1200
50
400
475
3190
261
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Exhibit 7-3, on the following page, compares FY '76 estimated
expenditures by system with projected future annual costs.
The most significant reduction in operating costs will re-
sult from current technical SAROAD modifications. These
technical changes plus the shift towards a hybrid
approach for managing air quality data will reduce SAROAD
computer costs by approximately 67%. On the other hand,
CDHS costs will increase significantly as additional instal-
lations occur. EPA system managers have projected EDS
operating costs to increase to $300,000 next year. However,
we anticipate that an EDS system audit will identify areas
where operating costs could be reduced back to current-
year levels. ORD personnel were unable to provide Index
with projected system operating costs. However, Index
estimates that RAPS and CHESS/CHAMPS costs will increase
by approximately 20% annually while system costs associated
with the NASN program will remain stable.
Overall ADP contractor costs will decrease over the next
two years. The table below compares current EPA contractor
expenditures for OAQPS, OE and state offices with those
anticipated in future years.
OAQPS
OE
States
1976
($000)
800
75
510
1977
($000)
750
60
205
1978
($000)
550
60
205
262 index systems inc
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Exhibit 7-3
U.S. Environmental Protection Agency
Projected ADP Operating Costs by System
SAROAD
NEDS
CDS
RAPS
CHESS/CHAMPS
EDS
CDHS
NASN
Other OAQPS Systei
Other ORD Systems
Other (including
unallocated regio
usage)
TOTAL
1976
($000)
903
150
105
250
347
183
300
54
s 380
200
254
lal
3126
1977
($000)
480
180
100
300
410
300
381
54
400
230
255
3090
1978
($000)
300
180
100
360
490
186
475
54
400
290
355
3190
263
-------
Most ADP contractor expenditures were estimated from detailed
contract listings contained in the Contracts Information
System (CIS) and adjusted, where necessary, by system manager
estimates.
OAQPS contractor expenditures for air data systems will decrease
over the next two years. SAROAD and NEDS contractor costs will
be offset by budgeted increases in CDHS support. While EDS con-
tractor costs are expected to continue through FY '77, they
are expected to be eliminated in FY'78 as a result of the
proposed audit. In addition, approximately $75,000 in con-
tractor support may be needed to implement the hybrid approach
for air quality data. The Office of Enforcement cost has been
estimated to decrease slightly in the future. State contractor
costs will decrease slightly over the next two years. Index
has not been able to obtain ADP contractor costs from either
ORD Headquarters or laboratory personnel. Personnel levels
in support of the air data systems are expected to remain
stable during the next two years at Headquarters, in the regions
and in the states.
264
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APPENDIX A - INVENTORY OF CURRENT SYSTEMS
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APPENDIX A - INVENTORY OF CURRENT SYSTEMS
The major ADP systems currently used by EPA and state
air program personnel are described in this appendix. Each
system write-up contains three types of information, as
follows:
System description
System costs
System management
Information contained in this appendix was obtained through
interviews with EPA system managers and through the reviews
of various system documentation.
255 index systems inc
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STORAGE AND RETRIEVAL OF AEROMETRIC DATA (SAROAD)
SYSTEM DESCRIPTION
Computer
Facility
Update Frequency
Data Base Accessible On-Line
Number of Standard Reports
Year Installed
Data Entry Transactions per Month
Transaction Size (Average)
Input Frequency
Data Editing
Programming Language for Update
Estimated Program Size
Data Retrieval Method Used
Master File Size
Retention Period for Master Files
Data Base Management System Used
UNIVAC 1110
NCC
Scheduled bi-weekly but,
in practice, irregular.
Yes
32
1974-1975
170,000
6-9 data elements/transaction
Continuous
Pre-edit uses no master files
Edit uses two files
COBOL, FORTRAN
104 programs
FORTRAN, COBOL
88,000,000 values
After three years old data
stored on historical file
None
SYSTEM COSTS
Fiscal 75 Computer costs
Fiscal 76 Computer Costs
$ 606,242
$ 903,000
266
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STORAGE AND RETRIEVAL OF AEROMETRIC DATA (SAROAD)
SYSTEM MANAGEMENT
System Documentation
Documentation Update Procedures
Contractors for System Operation
Contractors for System Maintenance
User Training Manuals
Yes
Yes
No
No
Yes
267
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NATIONAL EMISSIONS DATA SYSTEM (NEDS)
SYSTEM DESCRIPTION
Users
Computer
Facility
Year Installed
Update Frequency
Data Base Accessible on-line
Number of Standard Reports
Data Entry Method
Software Package Used
Average Number of Transactions/Month
Transaction Size (Average)
Entry Input Schedule
Programming Language for Update
Estimated Program Size
Data Retrieval Method Used
Number of Master File Records
Master File Record Size
Retention Period for Master Files
Data Base Management System Used
OAQPS, regional offices,
states, other EPA, outside
agencies and private
institutions
UNIVAC 1110
NCC
1975
Bi-weekly
No, although reports can be
requested interactively
39
Batch
None
30,000-40,000 cards
5-8 values per card
Continuous
COBOL
57 COBOL, 23 FORTRAN
COBOL, FORTRAN
93,200
552 characters
Indefinite
None
SYSTEM COSTS
Fiscal 75 Computer Costs
Fiscal 76 Computer Costs
$260,000
$150,000
268
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NATIONAL EMISSIONS DATA SYSTEM
SYSTEM MANAGEMENT
System Documentation
Documentation Update Procedures
Contractors for System Operation
Contractors for System Maintenance
User Training Manuals
Yes
Yes
No
No
Yes
269
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COMPLIANCE DATA SYSTEM (CDS)
SYSTEM DESCRIPTION
Users
Computer
Facility
Year Installed
Update Frequency
Data Base Accessible On-Line
Number of Standard Reports
Method
Software Package Used
Transactions per Month
Data Entry Input Frequency
Programming Language for Update
Data Retrieval Method Used
Number of Master File Records
Retention Period for Master Files
Average Number of Transactions
per Update
Data Base Management System Used
DSSE, regional and state
air enforcement personnel
IBM/370
OSI
1973
Weekly
No
4
Batch
None
40,000
Continuous
COBOL
COBOL
30,000
Permanent
10,000
None
270
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COMPLIANCE DATA SYSTEM (CDS)
SYSTEM COSTS
Fiscal 75 Computer Costs
Fiscal 76 Computer Costs
Fiscal 75 Contractor Costs(DSSE)
Fiscal 76 Contractor Costs(DSSE)
Current Manpower Support
$50,000 (DSSE)
$30,000 (Regions)
$54,000 (DSSE)
$51,000 (Regions)
$75,000
$75,000
1 (DSSE)
5 (Regions)
SYSTEM MANAGEMENT
System Documentation
Documentation Update Procedures
Contractors for System Operation
Contractors for System Maintenance
User Training Manuals
Yes
Yes
Yes
Yes
Yes
271
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ENERGY DATA SYSTEM (EDS)
SYSTEM DESCRIPTION
Users
Computer
Facility
Year Installed
Data Base Accessible On Line
Update Frequency
Average Record Size
Number of Data Values
Annual Data Base Increase
Data Base Management System
Programming Language
SASD
UNIVAC 1110
NCC
1975
Yes
Yearly or quarterly
depending on data
values, or as needed
N/A
58,000,000
6,000,000
System 2000
COBOL, FORTRAN
SYSTEM COSTS
1975 Computer Costs
1976 Computer Costs
1974-75 Contractor Obligations
1976 Contractor Obligations
Current Manpower Support
$ 18,000
$183,000
$273,000
$129,000
2 man years
SYSTEM MANAGEMENT
Management
System Documentation
Documentation - update procedures
Contractors for system operation
Contractors for system maintenance
User documentation
EPA support personnel
SASD and NADB
Not complete
Not complete
No
Yes
Yes
2+
272
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EMISSIONS INVENTORY SYSTEM (EIS)
SYSTEM DESCRIPTION
Users
Computer
Facility
Year Installed
Update Frequency
Data Base Accessible on-line
Number of Standard Reports
Number of Systems in Operation
Data Entry Method
Transactions per Month
Transaction Size (Average)
Input Frequency
Editing Procedure
Programming Language for Updates
Estimated Program Size
Data Retrieval Method Used
Number of Master File Records
Master File Record Size
Retention Period for Master Files
States
Varies
State facilities
1973
Any time
Batch only
17
14
Batch
500
3,000
Varies
Edit occurs during update
COBOL
16
COBOL
45,000-300,000
500-1,400 depending on
number of pollutants,
permits and registrations
Permanent
SYSTEM COSTS
Initial Development Costs
Implementation Costs
Fiscal 75 Computer Costs
Fiscal 76 Computer Costs
$150,000
$17,000/each
$9,000 annually per state
$9,000 annually per state
273
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EMISSIONS INVENTORY SYSTEM (EIS)
SYSTEM MANAGEMENT
System Documentation
Documentation Update Procedures
Contractors for System Operation
Contractors for System Maintenance
User Training Manuals
Number of EPA Personnel in System
Management and Operations
Number of State Personnel in System
Management and Operations
Yes
Yes
No
Yes
Yes
1
1-2 per state
274
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AIR QUALITY DATA HANDLING SYSTEM (AQDHS-II)
SYSTEM DESCRIPTION
Users
Computer
Facility
Year First Installed
Number of Systems in Operation
Update Frequency
Data Base On-Line Accessibility
Number of Standard Reports
Data Entry Method
Software Package Used
Transactions per Month
Transaction Size (Average)
Input Frequency
Data Editing Procedures
States
Varies
State facilities
1973
11
Depends on state
No
4
Batch
No
4,000
6-8 data elements/transaction
Varies
Uses site and parameter files
DATA MANAGEMENT
Programming Language for Update
Estimated Program Size
Data Retrieval Method Used
Number of Master File Records
Master File Record Size
Retention Period for Master Files
Average Number of Transactions
per Update
Data Base Management System Used
COBOL, FORTRAN
15
Report retrieval package
Varies between states
(40,000-500,000)
Variable length - 41-133
Indefinite
Varies
None
275
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AIR QUALITY DATA HANDLING SYSTEM (AQDHS-II)
SYSTEM COSTS
Initial Development Costs
Implementation Costs
Fiscal 75 Computer Costs
Fiscal 76 Computer Costs
$150,000
$17,000 per system
$9,000 per state
$9,000 per state
SYSTEM MANAGEMENT
System Documentation
Documentation Update Procedures
Contractors for System Operation
Contractors for System Maintenance
User Training Manuals
Number of EPA Personnel in System
Management and Operations
Number of State Personnel in
System Management and Operation
Yes
Yes
No
Yes
Yes
1
1-2 per state
276
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SOURCE TEST DATA SYSTEM (SOTDAT)
SYSTEM DESCRIPTION
Year Installed
Computer
Facility
Update Frequency
1976
UNIVAC
NCC
Variable
SYSTEM COSTS
Fiscal 76 Computer Costs
Fiscal 74-75 Contractor Costs
Fiscal 76 Contractor Costs
Manyears
$12,000
$34,442
$62,653
's-l many ear
277
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STATE IMPLEMENTATION PLANNING SYSTEM (SIPS)
SYSTEM DESCRIPTION
Users
Computer
Facility
Year Installed
Update Frequency
Regions, OAQPS
UNIVAC 1110
NCC
1975
Variable
SYSTEM COSTS
Fiscal 75 Computer Costs
Fiscal 76 Computer Costs
Fiscal 75 Contractor Costs
Fiscal 76 Contractor Costs
Current Manpower
$ 2,426
$ 9,600
$24,690
$38,000
11/2 many ears
278
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THE HAZARDOUS AND TRACE SUBSTANCE INVENTORY SYSTEM (HATREMS)
SYSTEM DESCRIPTION
Computer
Facility
Year Installed
Update Frequency
UNIVAC 1110
NCC
Projected for fiscal year 77
Unknown
SYSTEM COSTS
Fiscal 76 Computer Costs
Fiscal 75 Contractor Costs
Fiscal 76 Contractor Costs
Current Manpower
Expected Manpower
Not yet implemented
$25,000
$50,000
Jj manyear
1-2 manyears
279
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REGIONAL AIR POLLUTION STUDY (RAPS)
SYSTEM DESCRIPTION
Users
Computer
Facility
Year Installed
Update Frequency
Data Base Accessible On-Line
Number of Standard Reports
Storage Medium
Software Package Used
Transaction Size per Month
Data Entry Input Frequency
Programming Language for Update
Estimated Program Size
Data Retrieval Method Used
Master File Record Size
Retention Period for Master Files
Average Number of Transactions
per Update
Data Base Management System Used
SYSTEM COSTS
Fiscal 75 Computer Costs
Fiscal 76 Computer Costs
Fiscal 74-75 Contractor Costs
Fiscal 76 Contractor Costs
Current Manpower Support
ORD
UNIVAC
NCC
1973
Every ten days
Yes
10, plus numerous special
reports
Tape
None
38,000,000
One tape every ten days
FORTRAN, assembler
Over 100 programs
FORTRAN, assembler
2404 for minute file
Permanent
12,500,000
None
$117,000
$249,762
Not available to Index
Not available to Index
6 EPA
6-8 Contractors
280
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REGIONAL AIR POLLUTION STUDY (RAPS)
SYSTEM MANAGEMENT
System Documentation
Documentation Update Procedures
Contractors for System Operation
Contractors for System Maintenance
User Training Manuals
Yes
Yes
Yes
Yes
Yes
281
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COMMUNITY HEALTH AIR MONITORING PROGRAM (CHAMP)
SYSTEM DESCRIPTION
User
Computer
Facility
Health Effects Research Laboratory,ORD
UNIVAC
NCC
Although data gathering associated with CHESS has ended, data are
are being analyzed by researchers for report publication. Fiscal
1975 computer costs were $231,000. The CHAMP program is in the
data gathering phase. Currently, a feasibility study is under
way to evaluate system designs for managing air quality data
associated with CHAMP. However, cost data associated with the
feasibility study and projected operating costs were not available
to Index. An interim data system is operational for the capture
of air quality data associated with CHAMP. The fiscal 1976
computer costs for this system and the continuing CHESS analysis
are approximately $350,000. Other descriptive system and cost
related information were not available for CHESS and CHAMP.
282
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APPENDIX B - COST ESTIMATES
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APPENDIX B - COST ESTIMATES
This Appendix presents the estimation rules and assumptions
employed for evaluating alternative system actions and for
projecting ADP expenditures resulting from proposed changes.
Section 1 describes the estimation procedures as applied to
the evaluation of system design alternatives for managing air
quality and emissions data. Section 2 describes the consulting
and system development costs which result from proposed changes.
1. COST ESTIMATES FOR ALTERNATIVE SYSTEM DESIGNS ASSOCIATED
WITH THE MANAGEMENT OF AIR QUALITY AND EMISSIONS DATA
Cost estimates utilized for evaluating alternative system de-
sign philosophies were obtained from four sources, as follows:
Annualized data system operating costs from EPA
TSSMS reports
EPA system managers' ADP cost estimates
Development and operational costs of similar EPA
data systems adjusted for differences in data
volumes and scope
Cost estimates utilized in earlier studies per-
formed by Index and other contractors, where
appropriate
Cost estimates presented in this section do not include EPA
personnel costs.
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(1) Air Quality Data System Computer Operating Costs
The following cost estimates and assumptions were used to
approximate air quality computer operating costs:
Current SAROAD modifications have been estimated by
the current systems contractor to reduce annual data
retrievals and maintenance ADP costs by at least 50%
to approximately $190,000 and $160,000, respectively
Index estimates state computer billing rates to aver-
age $300 per hour
EPA system managers have projected that 35 states will
utilize either AQDHS-II or a locally-developed ambi-
ent air data system
A typical state-operated system requires 30 hours of
computer time to operate annually
An EPA-operated data system for states that
cannot support their own system requires 9 hours
of computer time to operate annually
The aggregate operating costs to EPA associated with
the states that cannot support their own data system
would be approximately $40,000
State coordination and data handling costs associated
with providing ambient monitoring data to EPA,
quarterly, have been estimated by Index to be $50,000
The operation and reporting associated with a summary
or violations information system are expected to
cost $35,000. This system would be similar in
complexity to the Formal Reporting System
Data communication costs for a utility approach would
constitute approximately 20% of the annual maintenance
and reporting costs
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The following cost parameters were defined in order to
estimate computer operating costs associated with the al-
ternative data system designs:
S = aggregate state maintenance and retrieval costs =
30 hours/year x 35 states x $300/hr = $315,000
E = EPA retrieval costs = $190,000
X = EPA maintenance costs for its data system = $160,000
Z = EPA operating costs for states that cannot support
their own data system = 9 hours/year x 15 states
x $300/hr = $40,500
M = operating and reporting costs associated with
management summary violations data = $35,000
The computer operating costs associated with the current,
hybrid and utility design approach have been estimated
by Index to be represented by three equations, as follows:
Current = S+1.5E+ X = $795,000
Hybrid - S+1.1E+0.1X+Z+M= $615,000
Utility = 1.5S + E + Z $705,000
These equations are adjusted to account for the relative
contribution of the previously mentioned parameters to the
aggregated operating costs for each alternative.
The operating costs associated with the current approach
include both EPA and state maintenance and retrieval
285 index systems inc
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costs (S, X, E). Because of completeness and currency
deficiencies associated with the current EPA-maintained
data base, data retrievals are supplied at present by
states to EPA. With a hybrid approach data system, the
operating costs to states would be similar to the cur-
rent approach. On the other hand, EPA reporting and main-
tenance costs (E, X) would be reduced substantially.
However, EPA would have to maintain air quality data (Z)
for those states that cannot support their own systems.
States would continue to supply data reports to EPA, as
needed. Furthermore, with a hybrid design EPA would
maintain a management reporting system (M) of summary and
violations data. With a utility approach operating costs
(S) to states would increase over the current and
hybrid approaches because of data communication costs and
additional costs associated with maintaining a central
utility data system for a diverse group of users.
(2) Air Quality Data System Development and Installation Costs
The following cost estimates and assumptions were used to
approximate air quality data system development and instal-
lation costs:
Installation costs for AQDHS-II are approximately
$17,000 per state
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An additional 10-15 states are expected to install
AQDHS-II within the next five years
Modifications to AQDHS-II necessary for the
current and hybrid design approaches are
estimated to total $100,000 - $125,000
Based on the scope of work necessary to develop
a utility-oriented air quality data system,
development costs would range between $500,000 -
$800,000
The installation and user training costs associated
with implementing a utility-oriented data system
for 35 states would be approximately $175,000
The development of a management reporting system
for violations information would be similar in
work scope to the Federal Water Supply System or
Federal Reporting System and would cost approxi-
mately $50,000
The current approach would involve additional AQDHS-II
installations and modifications and would cost approximately
$330,000. The development and installation costs necessary
for a hybrid approach would be similar to those costs
incurred for the current design, but would involve the
development of a management reporting system for violations
and summary information. These costs would total approxi-
mately $380,000. System development, installation and
training costs necessary for a utility design would cost
between $600,000 and $1,000,000.
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(3) Emissions Data System Computer Operating Costs
The following cost estimates and assumptions were used
to approximate emissions computer operating costs:
EPA system managers have projected that 35 states
would utilize either EIS/PR or a locally-developed
emissions data system
A typical state-operated system requires 15 hours
of computer time to operate annually
Index estimates state computer billing rates to
average $300 per hour
Maintenance costs for the EPA maintained data sys-
tem NEDS will remain stable at $30,000
EPA retrieval costs from NEDS would increase by
50% to $150,000
State coordination and data handling costs associ-
ated with providing machine-readable data to EPA
semi-annually are estimated to be $25,000
The cost estimates and assumptions were utilized to estimate
the computer operating costs for the current and utility
data system design. The various cost parameters for each
approach are illustrated below in Table 1.
Table 1
Current utility
State maintenance and retrievals $160,000 $240,000
EPA maintenance $ 30,000
State retrievals for EPA $ 50,000
EPA retrievals $150,000 $150,000
Semi-annual reporting costs $ 25,000
for states to EPA
TOTAL $415,000 $390,000
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The computer operating costs for the current and utility
approaches do not differ substantially considering the im-
precision of the estimation parameters. The elimination
of EPA maintenance, state reporting and retrieval costs
would be offset approximately by an increase of maintenance
and data communication costs with a utility design.
(4) Emissions Data System Development and Installation Costs
The following cost estimates and assumptions were used to
approximate emissions data system development and installa-
tion costs:
Installation costs for EIS/PR are approximately
$17,000 per state
An additional 10-15 states are expected to install
EIS/PR over the next five years
Modifications to EIS/PR necessary for the cur-
rent design approach are estimated to total $175,000
Based on the scope of work necessary to develop
a utility-oriented emissions data system, costs
would range between $500,000 - $800,000
The installation and user training costs associated
with implementing a utility-oriented data system
for 35 states would be approximately $175,000
The current approach involves additional EIS/PR installa-
tions and modifications and would cost approximately
$380,000. On the other hand, system development, install-
ation and training costs necessary for a utility design
would cost between $600,000 and $1,000,000.
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2. CONSULTING AND SYSTEM DEVELOPMENT COSTS WHICH RESULT FROM
PROPOSED CHANGES
Cost estimates utilized for projecting consulting and system
development efforts which result from proposed changes
were based on four factors, as follows:
EPA system managers' ADP cost estimates
Scope and magnitude of the consulting or system
development effort
Number of people and elapsed time appropriate
for each project
Travel time and associated expenses
For estimation purposes/ we have assumed the following average
manmonth ratesi
Contractor-consulting project $6000
Contractor-system development $4500
Exhibit B-l, on the following page, shows the cost derivation
of each of the proposed consulting and system development efforts,
290 index systems inc
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Exhibit B-l
U.S. Environmental Protection Agency
Costs Associated With Proposed Changes
Estimated Cost
Elapsed Time
Basis for Cost
Procedure and Requirements
definition for distributed
approach
$25,000
3 months
3.5 mm x $6,000 = $21,000
expenses = $ 4,000
$25,000
Management summary and
violations data system
development
EDS system audit
$50,000
6 months
$15,000
3 months
2 mm x $6,000
7 mm x $4,500
expenses
2 mm x $6,000
expenses
$12,000
$31,500
$ 6,500
$50,000
$12,000
$ 3,000
15,000
(Tl
CN
Regional NEDS edit and data
validation development
$10,000
2 months
2 mm x $4,500 = $ 9,000
expenses = $ 1,000
10,000
CDHS enhancements
NCC Technical Review
$250,000
$50,000
18 months
4 months
EPA system managers' estimates
7 mm x $6,000 = $42,000
expenses = $ 8,000
$50,000
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APPENDIX C - QUESTIONNAIRE RESPONSE SUMMARY
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APPENDIX C - QUESTIONNAIRE RESPONSE SUMMARY
The information contained in this appendix was obtained from
a questionnaire prepared by the Standing Air Monitoring Work
Group and the Management Information and Data Systems Division.
This appendix summarizes eight categories of information
reported on the questionnaire, as follows:
Primary uses of air data
Types of air data required
Problems with air data, information flows and
systems
Scope of air data requirements
Computer systems used
Preferred system design philosophy
Summary of respondants
Approximate Annual ADP -related costs
Questionnaires were completed by various EPA Headquarters,
Research and Regional offices. The findings from the
questionnaires provided additional background information
on the scope of air program data needs and various
aspects of the results were incorporated in the data
needs and analysis chapters of this report.
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The responses have been summarized by five respondent groups,
as follows:
Office of Air Quality and Planning Standards (OAQPS)
Office of Planning and Evaluation (OPE)
Division of Stationary Source Enforcement (DSSE)
Office of Research and Development (ORD)
Regional Offices
Apparent contradictory statements may appear within a group
as a result of the grouping of various responses. Also, the
responses have been separated into the eight information
categories listed above.
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SUMMARY CF AIR MONITORING AND SOURCE DATA NEEDS QUESTIONNAIRE
Primary Uses
of Air Data
a = Air Quality
Data
e = Emissions
Data
o = Other Data
OFFICE OF AIR QUALITY
AND PLANNING STANDARDS
.Determine air quality
status (a)
.Prepare annual trend
reports (a,e)
.Develop and revise
emission factors (e,
0)
.Determine environ-
mental impact of
NSPS, NESHAPS, FMVES
(a,e,o)
.Evaluate need to
revise standards
and to control new
pollutants (a,e,o)
.Perform special
studies (a,e,o)
.Develop and test
control strategies
(a,e,o)
.Determine national
manpower and re-
source needs
OFFICE OF PLANNING
AND EVALUATION
.Determine trends in
population exposure,
actual and potential
emissions (a,e)
.Determine impact of
new sources on
ambient air quality
(a,e,o)
.Validate air quality
models (a,e)
.Establish daily
ambient air pollu-
tion indicator (a)
DIVISION OF STATIONARY
SOURCE ENFORCEMENT
.Plan and order future
enforcement activ-
ities (a,e,o)
.Determine compliance
status (o)
.Measure progress in
emissions reduction
(e,o)
OFFICE OF RESEARCH
AND DEVELOPMENT
.Develop and evaluate
air quality and
source models (a,e,o)
.Research and poll-
utant assessment
studies (a,o)
.Identification of
new pollutants (a,o)
REGIONS
.Revise SIP's (a,e,o)
.New source review
(a,e,o)
.Enforcement actions
(a,e,o)
.Evaluate control
strategies (a,e,o)
.Modeling applications
(a,e,o)
.Air quality mainten-
ance planning
(a,e,o)
.TCP development
(a.e.o)
. Non-significant
deterioration (a,e,o)
.Determine source
compliance (e,o)
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OFFICE OF AIR QUALITY
AND PLANNING STANDARDS
OFFICE OF PLANNING
AND EVALUATION
DIVISION OF STATIONARY
SOURCE ENFORCEMENT
OFFICE OR RESEARCH
AND DEVELOPMENT
REGIONS
Air Data
Needs
Scope of
Air Data
.Raw and sumnazy
air quality data
(criteria and non-
criteria)
.Timely and conplete
air quality data
(representing 90
days or more)
.Area and point source
emissions for urban
areas
.Industrial process
data
.Ambient site infor-
mation
.Short-term emissions
data
.Modal and diurnal
data on source
operations
.Land use based
emissions
.Historical emissions
National (sane local
data needs for
modeling applic-
ations)
Historical (5 years)
.Ambient and source
data to allow
isopleths to be
drawn
.Timely, complete
and historical
emissions data
.Background and source
data for criteria
and non-criteria
pollutants
.Inclusion of new
sources, planned
technologies and
construction
schedules
.Meteorological data
.Complete ambient
data no more than
6 months old
.Annual emisssions data
.Compliance status
.Raw data for criteria
pollutants, metals
and toxic substances
.Power plant emissions
data
.Meteorological data
.Quality assurance in-
formation
. "CAMP" type data for
more non-urban
stations
.Sulfates and acid rain
data
.Particulate character-
ization
National (sane local
data needs for
modeling applic-
ations)
Historical (5 years)
National summery
Historical data not
necessary
National (some local
data needs)
Historical (5-20
years)
.Raw and sumnary air
quality data
.Meteorological data
.Ambient data for
non-criteria poll-
utants
.Compliance data
.Fuels data
.Automobile emission
data
.Quality assurance
information
.Point and area source
emissions inven-
tories
.Accuracy (- 10%)
un
cs\
CN
Regional and local
Historical (5 years)
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OFFICE OF AIR QUALITY
AND PLANNING STANDARDS
OFFICE OF PLANNING
AND EVALUATION
DIVISION OF STATIONARY
SOURCE ENFORCEMENT
OFFICE OF RESEARCH
AND DEVELOPMENT
REGIONS
Problems
Associated
With Data,
Information
Flows and
Systems
.Insufficient data
accuracy, complete-
ness and currency
.Non-criteria data
from more areas are
needed
.Limited software
capabilities
.Unstable hardware
.Slow turn-around
time
.More complete data
from fewer sites
needed
.Insufficient quality
control by data
collectors
.Less data needed per
site but covering
additional sites
.Incomplete, out-of-
date arvJ poor quality
data
.Methods not stand-
ardized
.Siting not always
appropriate
.Meteorological data
not localized enough
.Systems not designed
to store special
study data for
future use
.Limited state access
to EPA data bases
.Historical emissions
not maintained
.Ambient data presented
on site-by-site basis
are inadequate for
interpretation
.Ambient data too
old
.Unnecessary steps in
information flow
process
.Outdated and in-
complete emissions
data
.Unstable hardware
.Quality of data
unknown
.Access to raw data
difficult
.Inflexible software and
time delays in data
flow
.Limited mixing depth
data available
.More complete data
needed for fewer
locations
.Unfamiliarity with
UNIVftC software and
operations
.Poor quality and
outdated data
.Insufficient meteor-
ological data
.Siting and calibration
problems
.Operational costs for
CDHS not accurately
projected
.Slow turn-around time
.No plot capabilities
.No polygon retrievals
.Greater fliexibility
in retrieval programs
needed
.Training programs and
technical assistance
needed
.Awkward and time-con-
suming data flows
.ADP suballowance is not
sufficient to allow
increased NOC usage
without reprogramning
actions
.Qualification of data
by quality indicators
needed
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OFFICE OF AIR QUALITY
AND PLANNING STANDARDS
OFFICE OF PLANNING
AND EVALUATION
DIVISION OF STATIONARY
SOURCE ENFORCEMENT
OFFICE OF RESEARCH
AND DEVELOPMENT
REGIONS
Preferred
System
Design
Philosophy
.Centralized data bank
with standard data
formats, collection
and quality assur-
ance procedures
.Less lag time, more
believable data,
with Regional/state/
local access (at
cost)
.Highly decentralized
system
.Regional responsibil-
ity for operation
of data system
.Centralized processing
at regional level
with headquarters
access to regional
data bases
.Data collection,
reduction, storage
and retrieval auto-
matic with little
human interface
.Hybrid system with in-
depth data for Region!
on all monitoring
stations within
their geography
and smaller network
of reporting stations
with national rep-
resentation for head-
quarters use
.Hybrid system with
decentralized data
reporting and analy-
sis
.There can be no one
optimal system.
Systems are designed
for specific purposes
.State access and up-
date control of EPA
data systems
.Centralized data base
and control
.Decentralization of
all systems oper-
ations where econom-
ically feasible
.Partial interfaces
among all systems
.Data management pro-
gram at each level of
system usage
.Hybrid system with
limited trend data
fron a small number
of stations being
centralized and more
extensive data from
states handled by a
decentralized regional
system
.Direct edit capability
at NCC for states
tN
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OFFICE OF AIR QUALITY
AND PUNNING STANDARDS
OFFICE OF PLANNING
AND EVALUATION
DIVISION OF STATIONARY
SOURCE ENFORCEMENT
OFFICE OF RESEARCH
AND DEVELOPMENT
REGIONS
Computer
Systems
Used
SAROAD, NEDS, CDS,
RAPS, EOS, REPS,
CAASE, SOTDAT, HATREMS
SAROAD, NEDS, CDS
SAROAD, NEDS, CDS
SAROAD, NEDS, RAPS
other
SAROAD, NEDS, CDS
State Implementation of
CDHS
Respondents
Monitoring and Data
Analysis Division
Emission Standards and
Engineering Division
Strategies and Air
Standards Division
Control Programs Dev-
elopment Division
Office of Planning
and Evaluation
Division of Stationary
Source Enforcement
.Environmental Mon-
itoring and Support
Labs
-Corvallis
-RTF (2)
-Las Vegas
.Office of Health
and Ecological
Effects
.Monitoring Tech-
nology Division
All Regional Offices
CO
crt
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ESTIMATED ANNUAL ADP COSTS *
Organization
Office of Air Quality Planning
and Standards Monitoring and
Data Analysis Div.
Office of Planning and
Evaluation
Division of Stationary
Source Enforcement
Office of Research and
Development
Las Vegas
System
SAROAD
NEDS
Modeling
Other
Total
SAROAD,
NEDS, CDS
CDS
Computer
$ (000)
900
350
200
75
1525
65
Personnel
$ (000)
250
60
160
45
515
1 Man
Year
Contractor
$ (000)
250
210
300
200
960
35
Total
$(000)
1400
620
660
320
3000
60
47
CTl
CM
^Estimated annual ADP cost represent those costs stated on the questionnaire and do not
reflect necessarily the costs as projected by Index Systems.
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Organization *
Region II
Region III
Region IV
Region V
Region VI
Region VII
Region VIII
Region IX
System
CDS
Only
SAROAD
NEDS
CDS
AQDM
COM
SAROAD
CDS
CDS
AEROS
Other
Computer
$ (000)
14.7
15.0
10.0
10.0
2.7
1.6
12.6
.7
.4
8.9
1.3
7.0
3.0
6.0
Personnel
$ (000)
13.5
2 Man
Years
1 Man
Year
25.0
4.6
4.5
12.8
4.4
4.4
18.0
9.0
5.0
Contractor
$ (000)
3.0
50.0
6.0
6.0
Total
$ (000)
75-0
7.3
6.1
25.4
5.1
4.8
* Region I and X cost estimates not received by Index Systems.
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