SUPPLEMENTARY WORKBOOK FOR
WORKSHOPS ON PROCEDURES TO DEMONSTRATE
ATTAINMENT OF THE NAAQS FOR OZONE IN 1982 SIP'S
by
PEDCo Environmental, Inc.
505 South Duke Street, Suite 503
Durham, North Carolina 27701
U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF AIR QUALITY PLANNING AND STANDARDS
RESEARCH TRIANGLE PARK, NORTH CAROLINA 27711
APRIL 1981
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CONTENTS
1. Introduction 1
2. Outline and Agenda for Workshop 3
3. Major Topics 14
Introduction 14
Policy 19
Implications of the NAAQS for ozone 63
Conceptual basis for EKMA 68
Monitoring needs - 77
Use of data to generate isopleths 92
Application of isopleth diagrams in EKMA 122
Determining the overall SIP control requirement 139
Efforts to validate EKMA 143
Modeling related issues 158
4. Commonly Used Terms and Acronyms 159
5. U.S. EPA Policy on 1982 SIP's for Ozone and Carbon Monoxide
and Administrator's SIP Criteria Memo 161
6. Useful References 190
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1.0 INTRODUCTION
This workbook is intended to serve as a supplement to workshops concerning:
1) the U.S. EPA's policy concerning 1982 [State Implementation Plans
(SI Ps) for ozone,
2) /-ef*€ procedure which may frequently be used to demonstrate that
implemented controls are likely to be sufficient to attain the National Ambient
Air Quality Standard IMAAQS) for ozone.'
The workshops take place during April 1981 in three cities. Each workshop is
three days in length. The first day is spent discussing key policy- related
issues including timing requirements, Federal versus State/local roles, stationary
source consideration, inspection/maintenance policy and its rationale and addi-
tional transportation control measures. At the end of the first day, parti-
cipants should have a working knowledge of the policy and U.S. EPA personnel
should gain insight into points which need further clarification.
The second and third days of the workshop are used to describe application
of city-specific EKMA to demonstrate attainment of the ozone NAAQS. It is
anticipated that this model will be widely used in the 1982 SIPs. However, many
of the issues which arise with city-specific EKMA are pertinent even if other
procedures are used to demonstrate attainment. It is intended for participants
to first gain a aeneral sense of what "city-specific EKMA" is and then why it is
viewed by the EPA as an acceptable, expedient approach for use in 1982 SIPs.
The conceptual model underlying EKMA implies several needs for air quality,
meteorological and emissions data. These data needs are next identified. A
detailed discussion of how these required data are applied to generate the ozone
isopleths used in EKMA follows. Once graphs of ozone isopleths are obtained,
control requirements can be estimated using the EKMA procedure. Determination
of control requirements is described and illustrated by the use of several
examples.
It is of interest. to know how well EKMA works. Efforts to evaluate the
performance of city-specific EKMA are next described. Finally, the^ is likely
to be a number of questions concerning the application of models in the 1982
SIPs. Each workshop concludes with an open discussion of issues raised by
members of the audience.
At the end of each workshop, the audience should have a general under-
standing of the EPA's policy concerning 1982 ozone SIPs, data needs, how to
generate and apply the ozone isopleths used in city-specific EKMA, and how well
the model has performed in evaluations conducted to date.
The remainder of this supplementary workbook is organized in the following
manner. Section 2.0 contains the agenda and overall outline followed in each
workshop. Section 3.0 provides a synopsis of the material covered in each of
the ten major paragraphs enumerated in the workshop outline. Each of the ten
subsections in Section 3.0 consists of an identification of the key points and
ideas the speaker wishes to convey, an outline of the speaker's presentation and
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the sequence of slides used in the presentation. Throughout each workshop, a
number of acronyms or tet,i s may be used which are not familiar to all members of
the audience. Section 4.0 is a glossary of such terms. Section 5.0 presents
the EPA policy on 1982 SIPs for ozone and carbon monoxide. Finally, Section 6.0
identifies a number of references which provide additional Information on various
requirements in the 1982 SIP subrnittals and on city-specific E 1A.
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2.0 OUTLINE AND AGEND1 FOP. THE WORKSHOP
I. INTRODUCTION
A. Administrative Details
B. Purposes of Workshop
1. — to identify and clarify policy related to attainment derncnstrations
in the 1982 SIPs.
2. — to describe in depth application of the simplest acceptable
approach (city-specific EKM ) for demonstrating attainment of the
ozone NAAQS in 1982 SiPs;
C. Outline Contents of Workshop
D. Definition of Coriinonly—used terms
-EKMA
OZIPP
— City-Specific EKt4A, or Level III analysis.
E. Briefly outline SIP requirements for 1982, with emphasis on pertinent
regulations or guidance on demonstration requirements
— pertinent excerpts from FR notices
— list of guidance documents and contents.
II. POLICY FOR SUBMITTAL OF 1982 OZONE IMPLEMENTATION PLANS
A. General Overview of Policy
- what constitutes reasonable further progress?
- what is the policy on the use of models?
— what degree of flexibility exists with regard to the July 1982
submittal date?
— what is to be done if it is impossible to hold public hearings
within alloted time frame?
— how are these requirements affected by the Clean Air Act review?
- what is the policy with regard to cities which have not requested
extensions and do not meet standards by 1982?
— what is the relationship between rural and urban nonattainrnent areas?
— nonattainment projected for 1987?
B. Stationary Source Commitments
— what size sources must have RACT?
— what CTG’s will be available before 1982, and when?
— what should a State do about sources not covered by a CTG?
- what is meant by additional stationary source controls?
— what are the inventory requirements for stationary sources?
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C. Inspection/Maintenance
- what guidance is available on the implementation of I/N programs?
- what type of IfJ programs are acceptable?
— when must I/N be implemented?
- must regulations be submitted on a commitment to implement?
D. Other Transportation Measures
- what other transportation measures must be included in the
1982 submittal?
- what is considered an unimplementable measure that can be
excluded from the 1982 plan submitted?
E. Miscellaneous Items
- what are the air quality and emission data submittal requirements?
- what is the policy on the size of the modeling area?
— what is the policy if the peak impact occurs in another jurisdictio
—how will uncertainty in model predictions be handled?
III. NATURE OF AIR QUALITY STANDARD AND RESULTING IMPLICATIONS
A. State the ‘NAAQS. Note the implications -- we are interested in
demonstrating that in the post-control state, a daily maximum concen-
tration of ozone is not expected to be greater than 0.12 ppm more than
once per year at any monitoring site.
B. Note that 03 levels depend on a number of factors (e.g., transport,
trajectory, etc.1 and that there is not necessarily a linear relation-
ship between VOC controls and peak 03. Hence, the day with the second
highest, ozone concentration will not necessarily correspond to the
control requirement needed to demonstrate attainment.
C. Illustrate what we are interested in determining with a frequency
distribution diagram of control requirements.
0. Describe procedure recommended to demonstrate attainment and its
underlying rationale and advantage. Contrast with procedure used
in previous SIPs.
IV. CONCEPTUAL BASIS FOR EKMA
A. Di tribution of photochernical pollutants in urban areas.
B. Factors affecting ambient ozone levels.
C. Desirable attributes for a model to have in simulating impact of
controls. Discuss the extent to which city-specific EKNA is consis-
tent with these attributes.
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D. Physical model underlying EKMA (.OZIPP)
— illustrate column model and its ability to consider such
factors as
— diurnal mixing height variations
- varying sunlight intensity
- varying emissions
- transported pollutants
— reactivity
- Justify assumptions concerning uniform vertical mixing with
data from Philadelphia and St. Louis and use of automotive
exhaust as an indicator of reactivity.
E. Chemical model in QZ1PP
- how derived and calibrated
F. Summarize advantages/disadvantages of city-specific EKMA
- say what EKJ A is appropriate for.
V. MONITORING EFFORTS NEEDED TO SUPPORT THE APPLICATION OF CITY-SPECIFIC
EKMA IN ATTAINMENT OEMO STRAff S (1 hourT
A. Purposes -- to characterize highest 03 concentrations undermeteoro-
logical conditions most conducive to high ozone
- to provide input to OZIPP and EK3 A to enable adequate simulation
of the impact of hypothetical changes in VOC and/or MO on
peak ozone levels.
B. Emission Inventory Needs of the Model
C.. Network design
- refer to November 14, 1979 FR
- ozone -- purpose downwind max and transport estimates
- NMOC —— initial conditions before photochemistry
- NO — same as NMOC
— gi e indtvkiual. siting requir rna.nts of 03, NMOC and NO
sites and the underlying rationale
- wind, temperature, pressure measurements.
0. Elaboration on Certain Aspects of Monitoring
1. estimating O transport -— difficulties, methods for doing so
2. estimating precursor transport
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3. measurement of NMOC
- sources of difficulty
- range of accuracy
- reason for using robust indicators
- best instruments and procedures according to EMSL TAD.
V I. USE OF DATA TO GENERATE OZONE ISOPLETHS WITH OZIPP
A. Make connection with previous section on monitoring -— idea to get
across is “how do we use the data which have been collected.”
B. Selection of days to be modeled.
C. Give overview of different inputs affecting the shape of the isopleth
diagram obtained with OZIPP
— dilution
- transport of ozone
— light intensity
- transport of precursors
- “post 8 a.in. emissions”
- reactivity.
D. Light Intensity
- why important
- what data are used
- sensitivity of predictions to parameter (i.e., how much care
is needed in estimating this input .
E. Dilution
- why important
— relationsip to mixing heights
- how mixing heights are estimated using temperature, pressure
and radiosonde data
- description of computer program (how to run and what inputs
are neededi
- illustrate exact format of input required
- sensitivity of predictions to parameter (i.e., how much care
is needed in estimating this input).
F. Transport of Ozone
— why important
- what data are needed
- some “typical” levels
- sensitivity of predictions to parameter (i.e., how much care.
is needed in estimating this input) ..
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G. Transport of Precursors
isopleths -—
estimate
This is
- why or why not important
— what data are needed -— need to explain why downtown and
upwind data are needed
- distinguish between surface transport and transport aloft
- typical, observed levels
- sensitivity of predictions to parameters (i.e., how much care
is needed in estimating this input).
H. •Post 8 A.M. Emissions
- why important
- what data are needed (spatial and temporal detail in emission
inventory
— go through procedure of calculating emission fractions carefully,
illustrating amply with examples
- sensitivity of predictions to parameter (i.e., how much care
is needed in estimating this input).
I. Reactivity
- sensitivity or lack thereof to different aspects of reactivity
- note difficulty inccnsidering changes in reactivity with
propylene/butane mechanism
- recall previously described justification for using automotive
exhaust.
J. Computer Operations with OZIPP
1. Go through the format for each input card.
2. Illustrate with a numerical example.
3. Describe pertinent procedures using OZIPP.
4. Describe output
— with and without offline plotter
— what typical running times and costs might a user
expect?
- meaning of different outputs (e.g., NOT W X., etc.),
utility of CALC mode
— operations and considerations (e.g., properly—
centered diagrams, program messages)
- illustrate output with an example.
VII. USE OF THE OZONE ISOPLETHS IN CITY-SPECIFIC EKMA TO ESTIMATE CONTROLS
A. Nake connection with previous discussion on how to generate
now that we have isopleth diagrams, how can they be used to
controls needed to reduce ozone to 0.12 ppm on a given day?
the EKMA procedure.
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B. First step is to establish a starting point on the isopleth diagram.
This is done using prevailing 6-9 a.m. OCJNO ratios and day-specific
ozone design values.
— use material in EPA-45O/2— 7-O2ib to show how to estimate
NMOC/NOX ratio; illustrate with example.
C. Go through example of how to calculate
1. control requirements -
2. impact of specified control reductions.
0. Note underlying assumptions:
1. both initial concentrations and post 8 a.m. emissions are
reduced proportionally
2. other input, such as transported ozone, remain constant.
E. Illustrate how EK A is applied when conditions Dl and 02 are not met
1. — post 8 a.m. emissions change differently than initial
conditions Cm what cases might this occur?)
2. - transported pollutants change
3. — elaborate on the most important case -- the case of changing
transport
- how are future transported ozone and/or precursors
estimated
— what is the rationale?
4. •illustrate application of EYJ& with concurrently changing
transport with a numerical example (including computer
input and output .
F. Note that it is possible to consider more than one concurrent change
simultaneously.
VIII. USING E A TO D 0NSTRATE ATTAINMENT OF THE OZONE NAAQS
A. Make connection with previous discussion -- we now know how EKMA
can be used to show what levels of control are needed to reach 0.12 ppm
03 on specific days. The final step is to use this information to
demonstrate attainment of the NAAQS.
B. Go through two participative examples to insure audience understands
how to demonstrate attainment of the statistical NAAQS for ozone.
IX. RESULTS OF EFFORTS TO VALIDATE EKIIA
A. We are most interested in establishing that EKMA provides good estimates
of VDC and/or NO control requirements
— not necessarily the same thing as successfully predicting 03
concentrations in the base state
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- problem: there are no absolute ’ right answers against which
to compare model performance.
B. Procedures
1. - comparison with trends
— rationale, steps and limitations
2. - comparison with sophisticated models’ predictions
— rationale, steps and limitations
3. - comparison with observed data -
— rationale, steps and limitations
4. — evaluation of OZIPP as used In city-specific EKNA as
an indicator of a city’s ozone-forining potential
— rationale, steps and limitations.
C. Extent of Comparisons
D. Results
1. with trends
2. with observed data
3. with other-models -— elaborate on this
t’ ote additional advantages of considering seyeral days.
4. use of OZIPP as an indicator of a city’s ozone forming
potential.
E. Ongoing work
X. 1 ODELi11G RELATED ISS’tJES
This will consist of a fairly Informal discussion between the speakers
and the audience. Possible topics which could arise are:
o size of itodeling region
o relationship to political boundaries
o degree of uncertainty in model ing
° use of different chemical mechanism or other deviations from the
“standard approach”
use of default VC1UCS
° elir inating certain days from consideration.
The content of the discussion will depend on the interests expressed by
members of the audience.
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WORKSHOP AGENDA
PROCEDURES TO DEMONSTRATE ATTAINMENT OF
THE NAAQS FOR OZONE IN THE 1982 SIPs
Time Topic Speaker
DAY 1
Edwin Meyer
Johnnie Pearson
8:30
9:00
9:30
10:45
11:00
12:15
1:15
3:00
3:15
4:15
5:15
Registration
Introduction
General overview of the policy for
submittal of 1982 ozone SIPs
BREAK
Policy for submittal of 1982 ozone SIPs
LUNCH
Transportation control measures
BREAK
Inspection/Maintenance
Open discussion
ADJOURN
Johnnie Pearson
Representative of
OTLUP
Representative of
OMSAPO
Johnnie Pearson
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AGENDA (continued)
Time Topic Speaker
DAY 2
Implications of the ozone standard
Conceptual basis for E Jv A
Monitoring requirements
BREAK
Generating ozone isopleths for use in EKMA
LUNCH
Generating ozone isopleths for use in EKMA
conti riued)
BREAK
Generating ozone isopleths for use in EKMP
(continued)
Open discussion
ADJOURN
Application of isopieths in EKNA procedure
BREAK
Estimating the SIP control requirement
EKMA validation
LUNCH
Modeling related issues and general
discussion
ADJOURN
‘ - ‘S - i
9:00
9:45
lt\ Ar.
.u: ‘ o
11:00
12:15
1:15
2:45
3:00
4:15
5:15
8:30
10:30
10:45
11:15
12:30
1:30
4:30
DAY 3
Edwin Meyer
Robert Kelly
Edwin Meyer
Gerald Gipson
Gerald Gipson
Gerald Gipson
Edwin Meyer
Gerald Gipson
Gerald Gipson
Edwin Meyer
Edwin Meyer
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SPEAKERS
Dr. Edwin L. Meyer
Chief, Technology Development Section
Air Management Technology Branch
Office of Air Quality Planning and Standards
MD-14
Research Triangle Park, North Carolina 27711
Telephone: 919-541-5522
Mr. Johnnie L. Pearson
Standards Implementation Brancft
Office of Air Quality Planning and Standards
MD-iS
Research Triangle Park, North Carolina 27711
Telephone: 919-541-5540
Mr. Jack Hidinger
Office of Transportation and Land Use Policy
ANR - 445
401 M. Street, S.W.
Washington, D.C. 20460
Telephone: 202-755-0480
Mr. Donald C. White
Inspection and Maintenance Staff
Office of Mobile Source Air Pollution Control
2565 Plymouth Road
Ann Arbor, Michigan 48105
Telephone: 313-668-4305
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Mr. Gerald L. Gipson
Air Management Technology Branch
Office of Air Quality Piannina and Standards
t1D14
Research Triangle Park, North Carolina 27711
Telephone: 919-541-5522
Mr. Robert F. Kelly
Air Management Technoioay Branch
Office of Air Quality Planning and Standards
MD-14
Research Triangle Park, North Carolina 27711
Telephone: 919—541-5522
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3.0 MAJOR TOPICS
3.1 Introduction
Introductory remarks are intended to set the tone for the workshop,
This is accomplished by identifying the purpose of the workshop and by indicat ng
how each major topic logically follows from the previous ones. The content of
the workbook is briefly touched on. Emphasis is placed on those acronyms appearing
in the glossary which are likely to be most frequently used during the workshop.
Key additional references, as well as references available at the workshop, are
also identified. The introductory remarks conclude with a brief synopsis of
events, key Federal Reqister notices and legal requirements which have led to the
need for submitting SW the EPA Regional Offices by July 1982 demonstrating
attainment of the ozone N&4QS by 1987.
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Introduction -- Outline
A. Administrative Details
B. Purposes of Workshop
1. Policy clarification
2. Description of city-specific EKJ A
C. Contents of Workshop
To the extent possible, we would prefer to defer questions until the end of
each speaker’s presentation. We will try to follow agenda closely. Indicate
speakers for each session.
1. On the first day, outline key aspects of agency policy on 1982
ozone SIPs. Note that policy is in Section 5.0 of the workbook.
2. Identify key aspects of the ozone NAAQS and how it impacts on
demonstration of attainment, particularly with city-specific EKMA.
3. Provide a conceptual discussion of EKMA as an overview.
4. Describe the air quality, meteorological and emission information
needed to support a city-specific E A analysis.
5. Describe how the information thus obtained is used to generate
city-specific ozone isopleth diagrams.
6. Show how the city-specific isopleths were used to make control
estimates (city-specific EKMA procedure).
7. Indicate how attainment requirements are determined.
8. Describe the extent to which city-specific EKMA and the OZIPP model
have been validated.
9. Discuss modeling-related issues raised by attendees.
D. Identify Other Key Features of Workbook
1. Alert attendees to key acron lns and note their presence in Section 4.0
of the workbook.
EKMA
OzIPP
City-specific E 1A
2. Identify key references listed in Section 6.0 of the workbook and how to
obtain references.
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EKMA Guideline
User’s l anual
TAD for {MOC instruments
Emission Inventory Guideline
E. Provide a Brief Background of Events Leading to 1982 SIPs
1. February 24, 1978 Administrator’s SIP criteria memo
2. 1279 SIPs containing provision for those areas not able to demonstrate
attainment by 1982
3. 1979 FR on data needs
4. CTG development on continuing basis
5. Emission inventory workshops
6. September 30, 1980 policy proposal and comments
7. Policy published in FR (January 1981)
8. EKMA guideline developed and revised in accordance with comments
9. Technical Assistance Document ori operation of continuous NMOC monitors
published
10. These workshops.
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NOTES
‘ , ‘ r:
o .
WORS OP
- — 4
OZONE WORKSHOP
• AGENCY POLICY
ON 1982 SIPs
• NATURE OF
OZONE NAAQS
• CONCEPTUAL VIEW
OF EKMA
• INFORMATION NEEDED TO USE EKMA
• How to generate city-specific isopleths
• How Isopleths used to estimate controls
• 1-low control estimates used to demonstrate
NAAQS attainment
• Validation of EKMA
• Modeling Issues
•Clarlfy policy
concerning 1982 SiPs
•Descrlbe city-specific
EKMA and its uses for
demonstrating attainmeni
01 the ozone NAAQS
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r.-r v
NAAQS RFP
OZIPP CTc
EKT 1A IIM
CJty-Speclflc EK1 t1A
WRiTE
OR CALL
U.S. EPA Library
M D 35
Research Triangle Park,
North CarolIna 27711
91 /541•2777 (comm.)
9i9!629 2777 (FTS)
THIS WORKSHOP
INSTRUMENTS
1979
SIP
POuC
SEPT. 30. 1980 FR
POLICY PROPOSED & COMMENT
CONTROl. 1Ec i OtO0Y EMISSIOH HvEHToM
GWDEUHE WOP KtHCPS
NOV. 14, 1979 — FR NOTICE DATA HEEDS
FEB. 24, 1978 — ADMW S W CRITERIA MEMO
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3.2 Policy
The Clean Air Act provides for attainment of the National Ambient
Air Quality Standards (NAAQS) by December 1982, except where a State has
requested and received an extension for either carbon monoxide or
ozone. States receiving such extensions are required to submit a SIP
revision which demonstrate attainment of these standards by 1987. In
order that States be aware of the requirements surrounding SIP revisions
due in 1922, the Agency, on January 22, 1981 (46 FR 7182), published its
policy on the submission of CO and ozone SIPs in July 1982. The purpose
of this policy is to set forth the basic and minimum requirements that
must be met by these States to have an approvable SIP. Many of these
requirements were previously stated in policy memorandum Cr workshops
and should come as little surprise to those agencies who have been
planning, since the submission of the 1979 SIP, for the 1982 submittal.
These requirements, or criteria for approval, can best be separated
into four general categories: (1) Control strategies and attainment
demonstration; (2) SIP development process, (3) datacollection, and (4)
modeling.
It must first be remembered that Congress, as a condition for
exten inq the attainment date, required that each SIP contains certain
provisions regarding stationary source control, vehicle Inspection/Maintenance
and transportation measures. These measures are to be implemented
regardless of the attainment date, if attainment is projected after
1982. Vehicle Inspection/Maintenance and transportation measures will be
addressed in additional presentations. This presentation deals primarily
with Stationary Source Controls.
The Clean Air Act in Section 172(b) requires States to impose
Reasonably Available Contract Technology (PACT) as expeditiously as
practicable. To assist States in this effort, EPA has prepared a number
of Control Techniques Guidelines (CTGs) covering most of the nationally
important sources of organic compounds. The drafts of the last in these
series are currently available. However, it is important to remember
that the State must determine what other stationary sources exist within
the nonattainment area and must develop and s ibrnit legally enforceable
emission limitations representing RACT for these sources in addition to
those covered by the CTGs. States should lock at the CTG documents for
assistance in these areas because many of the control technologies
presented may be equally applicable, transferrable to other sources
under consideration. It should also be recocnized that this is a minimum
requirement. States that are unable to demonstrate attainment by 1987
with the application of RP CT, must devolop more stringent stationary
source measures.
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REP
One of the major new provisions of the amendment of 1977, was the
concept of reasonable further progress. Congress was obviously concerned
that even though standards may not be attained for several years that we
progress at a specified rate toward that goal. The policy requires that
reasonable further progress be defined as a linear reduction in emissions
from the base year (1980) inventory to the attainment date. Several
commenters on the policy suggested that this was an unreasonable request
because of the time necessary to implement some of the measures, EPA
believes that the linear requirement is realistic because (a) States
can, to some extent, modify compliance dates particularly with respect
to control of stationary source emissions, (b) many of the emission
reductions projected from the 1979 plan submittal will not have taken
place until 1980 or after and can be included in the reasonable further
progress determination and (c) any other scheme would be virtually
impossible to implement or monitor.
Extensions Beyond 1987
The Agency recognizes that there may be’ a few areas that may not be
able to demonstrate attainment by 1g87 even after imposing stringent
stationary source controls and jmplementing mobile source measures. In
order to ensure that thse areas are imposing the most stringent controls
available EPA will, after submission of the 1982 SIPs, prepare a compilation
of the most stringent measures applied by any area as presented in the
SIPs. Areas unable to demonstrate attainment will be required to (1)
examine the feasibility of each measure and revise their SIPs accordingly,
(2) provide documentation measures already adopted are as stringent, or
(3) explain why equivalent measures cannot be adopted. In support of
these areas, EPA intends to address this issue of nonattainment in 1987
to the Congress in the upcoming review of the Clean Air Act. One option
available is to request authority to extend the attainment date beyond
1987 on a case—by-case basis. In such a case, extensions would be most
likely dependent upon the area demonstrating that the most stringent
measures possible have been adopted.
SIP Contents
The plan submitted in 1982 must include legally enforceable control
measures which demonstrate attainment of the CO or ozone NAAQS. If all
measures which can be implemented by 1987 are not adequate to demonstrate
attainment, additional measures which can be implemented after 1987
must be identified and adopted and attainment must be demonstrated by
the earliest possible date. The date of attainment, either before 1987
or after 1987, must be identified in the SIP. The SIP submittal must
also include imp1emen ation schedules and commitments, with respect to
data requirements, the most recent three years of air quality data must
he reduced, validated, and summarized in the plan, this will generally
reflect data collected through the third quarter of 1981. For the
emission inventory, the data should be submitted in the roco;R ended
format for both the base year, generally 1980, and for the year of
expected attainment. These two inventories will be used to define the
REP line.
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Transportation Control Plans (TCPj
The EPA guidance for the transportation portion of the 1979 SIP submittal
placed primary emphasis on the establishment of a continuing air quality-
transportation planning process. This guidance, which included the June 1978
EPA—DOT Transportation-Air Quality Planning Guidelines arid the Administrator’s
February 24 1978 memorandum, “Criteria for Approval of the 1979 SIP Revisions,”
remains as the principal set of policies that EPA will use in approving 1982
transportation control plans (TCP).
The final 1982 SIP policy reiterates arid attempts to clarify the TCP require-
ments. For example, the policy presents more detail on the requirements for
conTnitments and schedules. Also, the policy calls for an expansion of the portion
of the SIP submittal that will be dedicated towards meeting “basic transportation
needs.” The need for two new requirements, a monitoring plan and a contingency
plan, are explained.
The policy also outlines a step-by—step procedure for nonattainment areas
that will find it difficult to attain the standards by 1987. The policy then
discusses the approach EPA believes should be followed by those few large urban
areas where air quality problems are so severe that analysis may indicate that
attainment by 1987 is not possible.
The provisions of section 176(c), which requires all Federal activities to
conform to the SIPs, and section 316(b), which requires accorrinodation of any
emissions associated with a wastewater treatment facility, are addressed by the
policy.
The final subject for the OTLUP presentation is the SIP Development Process
which includes consultation among State and local officials; establishment of
emission reduction targets; and analysis of alternatives.
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Inspection/Maintenance (I/M )
According to the Clean Air Act, all major urban areas needing an extension
beyond 1982 for attainment of a standard for ozone and/or carbon monoxide
were required to include vehicle TIM as an element of the 1979 SIP
revision. States were required at that time to submit only evidence of
adequate legal authority, a commitment to implement and enforce a program
that will reduce hydrocarbon and carbon monoxide exhaust emissions from
light duty vehicles in 1987 by 25 percent, and a schedule for implementation.
The purpose of the 1982 SIP revision for TIM, which is due on July 1,
1982, is to incorporate in the SIP the final design elements of the
program. EPA ’s 1982 SIP policy for T/M names ten specific program
elements which must be officially submitted as part of the SIP. They
are: l).inspection test procedures; 2) emission standards; 3) inspection
station licensing requirements; 4) emission analyzer specification and
maintenance/calibration requirements; 5) record keeping and record
submittal requirements; 6) quality control, audit, and surveillance
procedures; 7) procedures to assure that noncomplying vehicles are not
operated on the public roads; 8) any other official program rules,
regulations, and procedures; 9) a public awareness plan; and 10) a
mechanics training program if additional emission reduction credits are
being claimed for mechanics training.
As part of the 1982 SIP review process, EPA will determine the overall
adequacy of the critical elements of each TIM program and, therefore,
the approvability of the 1982 SiP by comparing those elements to established
TIM policy. T/M program elements must be consistent with EPA policy or
a demonstration must be made that the program elements are equivalent.
With the completion of the 1982 revision, the SIP will contain a specific
and detailed TIM control strategy which is supported by the necessary
authority, commitments and resources. Where basic requirements of Part
O of the Clean Air Act have been met in previous SIP revisions, a state
need not resubmit this information in the 1982 SIP, but rather may
choose to incorporate this information by reference.
Special Considerations for JIM Planners
1) EPA policy regarding minimally acceptable programs is set out in
memoranda from David G. Hawkins to the EPA Regional Administrators
dated July 17, 1978 and February 21, 1979, and is clarified in a
memorandum from Michael P. Walsh to the Air and Hazardous Materials
Division Directors dated January 19, 1981.
22
-------
2) EPA policy requires that I/M programs achieve L um emission
reductions in 1987 relative to a non-I/NI scena ’io. The amount
of emission reduction produced by the I/M program is determined
based on estimated program stringency, geographic coverage,
vehicle types subject to inspection, test type, and start-up
date, as modified by age exemptions, cost waivers, and mechanics
training. Specific information on these program elements must
be available in the SIP, and a demonstration must be made by the
State using either MOBILE 1 or MOBILE 2 that the minimum emission
reductions will be achieved.
3) Following program start-up, States must report annually to EPA
information on program implementation and enforcement (42 U.S.C.
7410(a)(2)(B), 7414 and 40 CFR 51.321—51.328). The SIP should
contain a commitment to report to EPA data which allow a
determination of I/M program effectiveness.
4) One of the basic requirements for all SIP control strategies is
the identification and commitment of sufficient personnel and
financial resources to carry out the provisions of the plan (42
U.S.C. 7472(b)(7)). The 1982 I/NI SIP, therefore, must conta n a
demonstration that adequate resources have been committed to
implement, operate, and enforce the program.
23
-------
GENERAL OVERVIEW OF POLICY OUTLINE
I. Schedule
A. Policy proposed on September 30, 1980.
B. Comment period closed on December 1, 1980.
C. Final policy published on January 22, 1981.
D. Data base submitted on or before December 31, 1982.
E. SIP revision submitted by July 1, 1982.
F. Attainment by 1987.
II. Introduction
A. Congress recognized the difficulties involved with attaining
the CO and ozone NAAQS by 1982.
B. Many areas have requested and received extensions beyond 1982.
C. Attainment must be as expeditious as practicable but must be
by 1987.
D. Certain minimum requirements must be met for areas attaining
after 1982. These minimum measures are discussed in Section 1
of the policy.
E. Development of the 1982 SIP must follow certain processes and
procedures. These are presented in Section II of the policy.
F. 1982 SIP submittal must include updated emissions and air
quality data. The data requirements are discussed in Section
III.
0. Section IV describes the modeling requirements for the 1982
plan submittal.
24
-------
III. Control Strategies and Attainment Demonstration
A. 1982 SIPs must contain a fully adopted, technically justified
program.
B. Program must commit to implement adopted control measures that
will result in attainment of NAAQS.
C. SIP must provide for attainment of CO/Ozone NAAQS by 1987.
0. SIP must provide for “reasonable further progress” between
1980 and attainment date.
E. Attainment after 1987
1. State must adopt additional measures implementable after
1987.
2. Attainment date must be specified and be as early as
possible after 1987.
3. EPA will evaluate all SIPs for stringency and compile a
list of the most effective controls.
4. Areas unable to attain by 1987 will be required to adopt
most stringent measures or demonstrate reasons for not
doing so.
F. Control measures must be adopted in legally enforceable form.
C. SIP must also include implementation schedules and committments.
IV. Stationary Source Control
A. All major stationary sources must have RACT.
B. If attainment by 1987 not demonstrated using RACT, State must
go beyond RACT.
C. Stationary source commitments. As a condition for extending
the attainment date, Congress required that each SIP contain
certain control provisions for stationary sources. Key
stationary source policy questions are:
1. What size sources must have RACT?
2. What CTG’s will be available before 1982 and when?
3. What should a state do about sources not covered by a
CTG?
25
-------
4. What is meant by additional stationary source controls?
5. What are the inventory requirements for stationary
sources?
V. Vehicle Inspection/Maintenance
A. All major urban areas needing an extension beyond 1982 for
ozone must have i/M.
B. Also applies to Co.
VI. Transportation Measures
A. Reasonably available transportation control measures listed in
Section 108(f) of the CAA.
B. These are minimally acceptable requirements.
VII. Reasonable Further Progress (RFP)
A. SIP must demonstrate reasonable further progress.
B. RFP must be demonstrated from 1 8O to the date of attainment.
C. Annual reduction must be at least equal to a linear reduction
in emissions.
0. REP tracks emissions, not Air Quality.
E. REP tracks actual emissions.
F. REP tracking is not just a paper exercise. Emission decreases
obtained as a result of physically installing equipment,
actually implementing transportation measures, or imposition
of permit limitations on process, operating conditions or
hours of operation only are to be reported.
0. Emissions increases authorized as a result of new source
permitting must be included at time of permit approval (minus
offsets not already accounted for).
H. Projected emission reductions must be at least equal to the
linear reduction line.
I. All reductions since 1980 are creditable regardless of whether
they result from 1979 or 1982 plan.
3. Demonstration of RFP must include a breakdown between station-
ary and mobile source emissions.
26
-------
VIII. Additional Control Measures To Attain
A. More stringent stationary source control measures than
RACT.
B. Extending controls to sources smaller than the minimum RACT
levels.
C. implementing a broader range of transportation measures.
D. Adoption of post-1987 measures.
IX. SIP Development Process
A. Consultation with State and local officials.
1. Section 121 of the Act requires consultation with
a. local governments
b. organizations of locally elected officials
c. federal land managers.
2. Section 174 of the Act requires a joint determination of
respective roles in
a. SIP development
b. SIP implementation
c. SIP enforcement.
3. 1982 SIP must contain designation of responsible agencies.
B. Establish mode of emission reductions targets-—1982 SIP must
reflect agreement between State and local officials on the mix
of emission reduction measures necessary to achieve the NAAQS.
C. Analysis of Alternatives
1. Where alternative control measures exist, particularly
with respect to more stringent controls, the State must
analyze the effect of the alternatives.
2. The CAA requires that SIPs include an analysis of
a. air quality effects
b. health effects
c. welfare effects
d. economic effects
e. energy effects, and
f. social effects.
3. EPA believes two other national concerns should be
addressed
a. Conservation of petroleum and natural gas, and
b. protection of economies of declining areas.
27
-------
X. Areas requesting extensions are presented in Appendix A of January 22,
1981 policy notice.
XI. Miscellaneous Issues
A. The following are modeling related issues which were not
specifically addressed in the final ozone and CO policy.
1. What are the air quality and emission data submittal
requi rements?
2. What is the policy on the size of the modeling area?
3. What is the policy if the peak impact occurs in another
jun sdi cti on?
28
-------
TCM Outline
I. Transportation Control Measures
A. Reasonably available transportation measures
B. Commitments
C. Schedules
D. Basic Transportation Needs
E. Public Participation
F. Monitoring Plan
G. Contingency Provision
II. Additional Control Measures Required for Attainment
A. Control Measures•needed for Attainment by 1987
B. Post 1987 Attainment
III. Conformity of Federal Actions
A. Section 176(c)
B. Section 316
IV. SIP Devel:?ment Process
A. Cons tation Among State and Local Officials
B. Esta ?hment of Emission Reduction Targets
C. Ana f Alternatives
29
-------
I/M Presentation Outline
I. Purpose of the I/H SIP Revision
A. Documentation of the I/M Control Strategy
B. EPA Policy & Guidance
C. Basic SIP Requirements
II. SIP Elements
A. Inspection test procedures
B. Emission Standards
C. Inspection station licensing requirements
D. Emission analyzer specification and maintenance/calibration
requirements -
E. Record keeping and records submittal requirements
F. Quality control, audit and surveillance procedures
G. Procedures to assure that non-complying vehicles are not
operated on the public roads
H. Other official program rules, regulations and procedures
I. Public awareness plan
J. Mechanics training
III. RACT Compliance
A. Use of the emission factor model
B. Program design consideration
IV. EPA SIP processing
A. Partial submittals
B. Total i/H program approval
30
-------
NOTES
• Policy Proposed — 9130/80
• Policy Proposed — 9130180
• Comment Period — 1211180
• Policy Proposed — 9130/80
• Comment Period — 1211/SO
• Final Policy Published — 1122181
SIP
DEVELOPMENT
-------
NOTES
• Policy Proposed — 9130180
• Comment Period — 121ii80
• Final Policy Published — 1/22/81
• El. Data Base Due — 12/31/81
• Policy Proposed — 9/30/80
• Comment Period — 1211/80
• Final Policy Published — 1/22J81
• El. Data Base Due- — 12/31/81
• SIP Submitted — 711/82
• Policy Proposed — 9130180
• Comment Period — 12/1/80
• Final Policy Published — 1122181
• El. Data Base Due — 12J31I8 1
• SIP Submitted — 711/82
• Attainment — 1987
-------
NOTES
Current Policy
Basically Compilation
of Previous Guidance
INTRODUCTION
TO
POLICY
-------
NOTES
Developmefl . of SIP
must follow certain processes —
Section II of Policy
Plan must
demonstrate attainment
as practicable.
7 ,7 2 ’
NO LATER THAN 1987
Certain minimum
requirements must be met —
Section 1 of Policy
-------
NOTES
ii
1982 SIP must include
updated emissions and AQ data —
Section lii of Policy
SiP development must follow
certain modeling requirements —
Section IV of- PoUcy
CONTROL STRATEGIES
AND
ATTAiNMENT DEMONSTRATIONS
‘82 SiP must be
fully adopted
and techflicaUY justified.
-------
NOTES
ATTAiN
REASONABLE\ NO LATER
FURTHER THAN
1987
AFTER
19:8 7
SIPs Demonstrating
Attainment After
1987 May Be Accepted.
36
-------
NUi r-
Attainment Must Be
At Earliest Possible
Date After 1987.
Must Include Adopted
Measures Implementable
After 1987.
ngen
37
-------
NOTES
State WIU Be
Required To Adopt
Most Stringent Measures.
All measures must be
legally enforceable
In’82S1P
AU major stationarY
sources must
have RACT.
38
-------
NOTES
REASONABLY
AVAILABLE
CONTROL
TECHNOLOGY
REQUiREMENTS
A:SECTION 172 (b) (2) OF THE CLEAN AIR ACT
APPUCABILITY OF DISCUSSION
& RACT
B. STRINGENT BUT REASONABLE MEASURES
RACT
THE LOWEST EMISSION LIMIT THAT A
PARTICULAR SOURCE IS CAPABLE OF
MEETING BY THE APPLICATION OF
CONTROL TECHNOLOGY THAT IS
REASONABLY AVAILABLE CONSIDERiNG
TECHNOLOGICAL AND ECONOMIC FEASiBiLITY”
‘tYPES OP INFORMATION AVAILABLE
A.NEW URCE PERFORMANCE STANDARD (NSPS)
SUPPORT DOCUMENTS
B. NATIONAL EMISSION STANDARD FOR HAZARDOUS
AiR POLLUTANTS (NESHAPS) SUPPORT DOCUMENTS
C CONTROL TECHNIQUE DOCUMENTS FOR SPECIFiC
POLLUTANTS
D.EXISTING STATE AND FEDERAL REGULATIONS
E.CONTROL TECHNOLOGY GUIDELINE DOCUMENTS
FOR VOC.
39
-------
NOTES
If Can’t Demonstrate
Attainment By 1987 —
Go Beyond RACT.
STATiONARY
SOURCE
SPECIFiCS
What size
source must
have RACT?
• Present CTG Sources
• Future CTG Sources
• Major VOC Sources 100 tons!yr
• CO Sources 100O tonslyr
40
-------
What CTG’s will be
available in 1981?
• VOC STORAGE
• PETROLEUM DRY-CLEANING
• OFFSET LITHOGRAPHY
$ FUGITIVE VOC NATURAL GAS AND
NATURAL GAS ‘ROCESSING PLANTS
• POLYMERS AND RESINS
• FUGITIVE VOC, SOCMI
• STYRENE-BUTADI ENE COPOLYMER
MANUFACTURING
• AIR OXIDATION SOUl!
How should states handle
major sources not
covered by a CTG?
41
-------
NOTES
• Determine if additional controls
RACT
Legally enforceable measures
implementing RACT
• Documentation supporting
existing controls represent RACT
ADDITIONAL STATIONARY
CONTROLS
• IMPLEMENTABLE BY 1987
• No PAPER DEMONSTRATIONS
-- --
Examples
—More stringent than RACT
—Extend controls to minor sources
-------
NOTES
WHAT ARE THE
CLEAN AIR ACT
REQUIREMENTS FOR
EMLSStON INVEr JTORtES
0
WHAT ARE THE CLEAN AIR ACT
REQUIREMENTS FOR EMISSION
INVENTOR I ES?
• CLEAN AIR ACT SECTION 172 (b) (4)
• COMPREHENSIVE ACCURATE CURRENT
iNVENTORY
OZONE P J? VE’4TO 5
Cave
• Al > ‘ QO mtyr VOC
•
b 4 d a 1 a
d c3 c 5 da a oe -_ rwnit n
• Al CTCJRACT
— -- N
982 OZO 9? rwerrOc E
Cun t
•
— — —
• Al wna po aiid - s aC ç.da ed
Ió O U
to O
-------
NOTES
‘1982 OZONE SIP NYENTOR]ES
Actixrate
• Qu S ty Assurance prograxT to assure mp e{ei’
and actur cy o c± tz nLfa a)
• bitemal auc ting. e ro ’ detection and correction
pcOgTatT in e fec
WHAT IS THE
PURPOSE OF
AN EMISSION
INVENTORY
0
WHAT S THE PURPOSE OF AN EMISSION INVENTORY?
• PLAN DEVELOPMENT
• REASONABLE FURTHER PROGRESS EVALUATION
WHAT SOURCES OF
EMISSIONS SHOULD
BE INVENTORIED
G
tiLl
-------
19 2 OZOWE pV TORXB
A s YOC Po cy * t,k’iâ tisiçai
i’ y v 1a ioi
•
•
• ______________
• — J. _ . _ , ___ ,. .
•_____
• - —
2IES
WHAT SOURCES OF EMISSIONS
SHOULD BE INVENTORIED?
• NEED ACCURATE ACCOUNTING
• SOURCES GREATER THAN 100 TONS
PER YEAR POTENTIAL
• MOBILE SOURCES
19E2 OZONE P ThV 1TDR1 S
Po1 uantsA’OC
• I i e VoLaS Org2 Cøti oix & (RVO
•
• VOC Pcky
42 F 14 J?Y E. 79 7}
4 ’T 1 . 19 O)
4313 4 941 t*k . 8O}
• 41 __ ----- •- —
•
• — *-— c.nq
• J __ — _ — - —I — —
i e iTçc*r (y r i a*d by v&
-------
NOTES
Area
• Entire Nonattainment Area
• CountyWide
Base Year
• 1980 Data Base
• Impact of Implemented SIP
Regulat OflS
fi—
-------
NOTES
r
Projected Baseline Attainment
Year Inventory
• Growth Impact
• Impact of Adopted Regulations
• Other Anticipated Changes in
Emissions
tIM Required in AlL
Urban Areas Not in
Attainment h.y 1982
RTCM
In
in
Section 108(1)
‘82 SIP
1962 must
demonstrate
Reasonable
Further
Progress
Attain.
Date
1 9B0
-------
NOTES
Annual Emission Reductions
At Least Equal To
Linear Reduction in Emissions
1980
EL.
1980 Attainment
- Dale
RFP TRACKS
ACTUAL EMiSSIONS
NOT AQ
- -- - —
RFP IS NOT
PAPER EXERCISE
-------
NOTES
Reductions Creditable
Only When Actual
Reductions Have Occurred
Emission increases Due to
New Sources included at
Time of Operation
Projected Emissions
At Least Equal To
Linear Reduction Line
YES
1980
1987
-------
NO
1980
1987
E I after most
measure
Attainment
st nt
Date
Inventory
__ — __
1980 1987
Intermediate Year
inventories
• Each year between base
year and attainment year
• Distinguish between
mobUe and stationary
AU Reductions
Since 1980
Are Creditable.
50
-------
N TE
F(FP Demonstration I
Stationary Mobile
ADDITIONAL
CONTROL MEASURES
TO ATTAIN
• STATIONARY BEYOND RACT
• EXTEND CONTROLS TO SMALLER
THAN MINIMUM RACT SIZE
•BROADER RANGES OF TRANSPORTATION
MEASURES
•INCREASED COVERAGE AND
STRINGENCY OF I/M
51
-------
.1
Attaliunent
Adopt Measures To Be
implemented After 1987
I
NOTES
SIP
DEVELOPMENT
PROCESS
-------
CONSULTATION
NOTES
FLM
elected
of f c aI
Section 174 requires joint
determinations in SIP. .
— Development
— lrnplementafion
— Enforcement
‘82 SIP must designate
responsible agency
-------
NOTES
‘82 SIP must contain
agreement on mix of
control measures
ANALYSIS OF
ALTERNATIVES
Act requires analysis
to include:
Welfare
Sod a I
- tzit••
-------
NOTES
Miscellaneous
Issues
Projected 1982
SIP Strategy
Ozone
• Impact of Additional
Regulatory Controls
• Impact of ‘79 SIP
What are the AQ and
Emissions Data
submittal requirements?
-------
NOTES
• 1980 Inventory
• December 31, 1981
• Population and other forecast consistency
• Most recent 3.year AC
• Modeling data
• 3rd Quarter 1981 AQ
Size of
Modeling Area
— ---- —
• UrbanArea
• Area of Maximum Emissions
• Downwind Area of Maximum Concentration
• Multiple Urban Areas
- ____
-
POLICY IF PEAK
IMPACT OCCURS
IN ANOTHER JURISDICTION
56
-------
NOTES
1982 OZONE AND
CARBON MONOXIDE
STATE
I MPLEMENTAT-I ON
PLAN REQUIREMENTS
FEDERAL REGISTER NOTiCE
Control Strategies and
Attainment Demonstralion
• SIP Development Process
• Air Quality and Emission
Data Bases
• Modeling
CONTROL STRATEGIES
AND ATrAINMENT
DEMONSTRATION
• Minimum Control Measures
• Additional Control Measures
•RFP
-------
NOTES
CSAD
Additional Controis
• Beyond RACT for m or
t tion r ourc* s
• Extend controls to smaller
sources
• Broader r no e of
transportaiñon controls
• Increased I,’M
— - __ s __ p —
C SAD
if with additional controls
you don’t attain in 1987:
• Additional Control
beyond 19S7 -
• Clean Air Act Re ew
CSAD
RFP
• Nolag
• Distinguish mpbile and
stationary source
reductions
MODELING
CO SIPs
• Guidelines for
Air Quality Models
-------
NOTES
Am QUALIVs’ AND
EMISSION DATA EASES
• Gencral Quality
• 9 Best Data Av I1abIe
• 82 Dath Update
• Submittal by 12/3 /81
• 1980 lnveTIWrieS
• Most rece:nt 3 years air
quality data
PLAN REQUIREMENTS FOR NON ATTAINMENT AREAS
SECTION 172 i)
— -PROVIDE FOP ATtAINMENT OF EACH NATIONAL.
AMBIENT AIR DUALiTY STANDARD IN EACH SUCH AREA AS
EXPED OUSL.Y AS PRACTICASLE — — — (CONTROL
STRATEGYj
SECTION 172 (b)
7HE PLAN PROVISIONS REQUIRED BY SUSSECTION I )
$MALL———
(1) BEADOPTEDBYSTATE (OR
PROMULGATED BY THE ADMINIS-
TRATOR) AFTER REASONABLE
NOTICE AND PUBLIC HEARiNG.
(2) PROVIDE FOR IMPLEMENTATION
OF ALL REASONABLY AVAILABLE
CONTROL MEASURES AS EXPEDI-
TIOUSLY AS PRACTICABLE.
-------
NOTES
(3) REQUIRE INTERIM REASONABLE
FURTHER PROGRESS.
(4) INCLUDE A COMPREHENSIVE,
ACCURATE CURRENT INVENTORY
OF ACTUAL EMISSIONS FROM ALL
SOURCES AND SHOULD BE RESUB-
MITTED AS FREQUENTLY AS
NECESSARY TO ASSURE COMPLI-
ANCE WITH REASONABLE
FURTHER PROGRESS PROVISIONS.
(5) EXPRE LY IDENTIFY AND QUANTIF?
EMI )ONS FROM CONSTRUCTION
AND OPERATION OF NEW OR
MODIFiED SOURCES.
(6) REQUIRE PERMITS FOR CONSTRUCT-
ION AND OPERATION OF NEW OR
MODIFIED SOURCES IN ACC’URDANCE
WITH SECTION 173 (PERMIT REQU IRE-
MENTS.)
60
-------
NOTES
(1) IDENTIFY AND COMMIT THE
FINANCIAL AND MANPOWER
RESOURCES TO CARRY OUT
PLAN.
(8) CONTAIN EMISSION LiMITATIONS,
SCHEDULES OF COMPLIANCE.
(9). EVIDENCE OF PUBLIC AND LOCAL
GOVERNMENTAL INVOLVEMENT
AND CONSULTATION.
IDENTIFICATION AND ANALYSiS
OF AIR QUALITY, HEALTH WELFARE.
ENERGY AND SOCIAL EFFECTS.
SUMMARY OF PUBLIC COMMENT
ON ANALYSIS.
61
-------
NOTES
(10) WRiTTEN EVIDENCE OF STATE,
LOCAL GOVERNMENT ETC.
HAVE ADOPTED NECESSARY
REQUIREMENT TO IMPLEMENT
AND ENFORCE PLAN.
.
(11) MEET CERTAIN REQUIREMENTS F ATTAINMENT
DATE AFTER 19 2.
ADDITIONAL NEW SOURCE REVIEW ANALYSIS
SCHEDULE FOR IMPLEMENTING I & M
IDENTIFY OTHER MEASURES NECESSARY TO
ATTAiN BY 12—31—87
PLAN REQUIREMENTS
I CONTROL STRATEGY
• A OFT1ON AFTER PUELIC HEARING
• IMPLEMENT RACM
• RIASONA?(.E FUR }ER PROGRESS
• EMISSION INVENTORY FOR STRATEGY — DEVELOPMENT AND
PEASOI &BLE FURTHER PROGRESS
• OU&P4TIFICATIOS oc EMISSIONS F RON PJEW DR MODIFIED SOURCES
p PERMITS FOR HEW OR MODIFIED SOURCES
• FINANCIAL AID MANPOWER REQUIREMENTS
• EMISSION LIMITATION. SCHEDULES OF CCR4PLIANCE
• CONSULTATION
• ANALYSIS OF IMPACT OF PLAN & ALTERNATIVES & COMMENT
EON MAP V
• EVIDENCE OF CQVMITTMENT TO IMPLEMENT & ENFORCE
• REQUIREMENTS FOR?LANS WITH PROJECTED ATTAINMENT
EEYOND 1E52 ,
-------
3.3 Implications of the NAAQS for Ozone
Prior to discusstng city-specific E KJ1A, it is appropriate to address the
National Ambient Air QualIty Standard (INAAQS1 for ozone. The NAAQS affects the
choice of ozone -values input to EKMA, as well as the stringency of a city’s
calculated control requirements.
The National Ambient Air Quality Standard for ozone is attained when the
expected number of days per calendar year, with maximum hourly average concentra-
tions above 0.12 ppm, is equal to or less than one. Such a standard contains
several implications concerning demonstrations that a State implementation Plan
(SIP) is sufficient to attain the NMQS.
Two important differences with past practices occur as a result of the new
standard. First, only one hourly value is considered for each site on each day.
This can affect the set of candidate “ozone design values” used to estimate the
amount of controls needed to reach 0.12 ppm ozone. Formerly, extremely rare
episode days with a number of very high ozone values at any given site were
weighted disproportionately. The new standard inherently recognizes this problem
by allowing only one concentration (and therefore one control estimate) to be
considered per site per day.
Second, the phrase, “...e pected number of days per calender year...”
reduces a concern with the former standard that those States which have main-
tained conscientious monitoring programs over the years are penalized. Since the
expected or “average” number Of days per year with daily maximum ozone concentra-
tions greater than 0.12 ppm is of concern, this means that there can be more than
one day observing ozone concentrations in excess of 0.12 ppm If the data base is
one or more ozone seasons In length.
Another implication of the NMQS is that the frequency distribution of ozone
concentrations at each monitoring site which occurs after the implementation of
controls is the key consideration in demonstrating attainment. This has always
been the case. In the past, however, very simplistic models (e.g., rollback,
envelope curves) were used to demonstrate attainment. Minimal use was made of
meteorological or air quality data. Under such circumstances, choosing the ozone
value to input into a model in order to calculate control requirements was very
straightforward. The design value was simply the second highest value observed.
The degree of control needed to attain the NAAQS, however, is a function of
many things in addition to observed ozone concentrations during the base period.
For example, controls needed to attain the NAAQS are a function of pollution
transported from upwind sources, prevailing NMOCINO ratios and atmospheric
dilution. Therefore, it is conceivable that the se ond highest ozone design
value would not require the second highest control requirement to attain the
NAAQS if one uses city-specific E} A or more sophisticated models. Of paramount
interest is the frequency distribution of control estimates calculated with such
models. Depending on the length of the period of record at any given monitoring
station, one would choose the control estimates which would Insure that, on
average, the daily maximum hourly ozone concentration would not exceed 0.12 ppm
more than once per year at any monitoring site. For example, If the period of
63
-------
record: at one site were three years, the fourth highest calculated control esti-
ifiate would be chosen as demonstrating attainment at that site. The control
requirement needed to demonstrate attainment for the city as a whole is whatever
is necessary to demonstrate attafrmient at all ozone monitoring sites.
The procedure sunTnarized in the previous paragraph Is described at greater
length in Chapter 2.0 o.fGüidelifléfor Use of C y Speclfic EKMA in Preparinq
Ozone Sips . Numerical examples illustrating the procedure are discussed inihe
Tdeline and in Section 3.8 of this workbook.
64
-------
Implications of the NMQS for Ozone -- Outline
A. State the NAAQS for ozone
1. Highlight differences from previous standard
- expected number
— days per calendar year
- 0.12 ppm
2. Implications —— why important in demonstration of attainment
- affects ozone value input to EKMA
- affects severity of control requirements
- applies at all sites
- de-emphasizes rare episodes
- States with conscientious long term monitoring programs less
penalized than formerly
B. Note that for demonstration purposes) the prime concern is with whether or
not the NAAQS is attainedafter implementing controls.
1. Indicate NMQS depends on a number of factors which can be explictly
considered in EKMA.
2. Therefore, It does not necessarily follow that implementation of suffi-
cient controls to reduce peak 03 below 0.12 ppm on the day seeing the highest 03
will be sufficient to attain the NMQS.
C. Therefore, surest way to demonstrate attainment is to estimate control
requirements for several days and choose requirements as being the one sufficient
to show no more than one daily maximum 03 concentration above 0.12 ppm per year
on average.
In essence, what one needs is to estimate a frequency distribution of control
estimates.
D. The foregoing may present resource problems. A compromise suggested in the
EKMA Guidance is to iriodel five days with highest ozone at each site and select
the control requirements accordingly. This approach will be illustrated in
Section 3.8.
- Note that a site is assumed to have an ozone season’s worth of
data if 25% orinore days have valid observed daily maxima.
E. Examples to Illustrate Implications of NAAQS
11 Example 1 — - illustrates benefit of long term monitoring and that
attainment means meeting standard at all sites.
2 Example 2 —— in addition to the above, Example 2 illustrates that
standard is only concerned with daily maximuni values at each site.
65
-------
OZONE NAAQS
The NAAQS for ozone is attained
when the expected number of days
per calendar year with maximum
hourly average concentrations
above 0.12 ppm is one or less.
NOTES
implications of Ozone NAAQS
in Demonstrating Attainment
• Affects 03 value input to EKMA run.
• Affects severity of the control estimate
chosen for the control requirement.
• Applies at all sites -
• Deemphasizes rare episodes
• More equitable for states with long history
of monitoring.
Achievement of NAAQS depends on:
— Observed maximum 03 values
—Transported ozone
— NMOCINO 1 ratio
— Atmospheric dilution
— Differing patterns of fresh emissions
CONTROL REQUIREMENTS NEEDED TO
DEMONSTRATE ATTAINMENT OF OZONE NAAOS
>-
LU
U- ’
U - ’
-J
LU
CONTROL ESTiMATES CONTROL REQ WREMENT
-------
3 t— 1
? z (3 3 ’ .
3 ‘ 3 ) 3
I 3 1 1 (3
. :‘ t ss t
S . ‘ S (S I
( .c.l. LrC Cs . .
(3 ,,‘—S C.. C (.2 (3
53 3 31 2 .3
3 (4 3 31 3 (1
C S 43 6 43
I S 37 C
4 33 6 35 4’ 63
S SI 1 46
-------
3.4 Conceptual asis for EKMA
The purpose of this section is to provide a broad overview of the ozone
problem and resultinc needs for modeling analyses. The extent to which city-
specific EKMA can meet these needs is briefly discussed. Features of city-
specific EKMA are discussed in greater depth in subsequent sessions of the work-
shop, in Sections 3.6 - 3.8 of the workbook, and in Chapter 3 and 4 of Guideline
for Use of City-Specific EKMA in Preparing Ozone SIPs .
High ozone concentrations result from the interaction of organi pollutants
and oxides of nitrogen (NO ) in the presence of sunlight and, as a rule, limited
atmospheric dilution. Highest concentrations of precursors (i.e., organic pal-
lutants and NON) are typically found within large urban areas. Because net
production of ozone from precursors takes some time, and because the most iniiiediate
effect of fresh NO emissions is to scavenge ozone, highest ozone concentrations
are likely to be found several hours travel time downwind from cities. The peak
ozone concentrations found downwind of cities are also functions of ozone and, to
a lesser extent, precursors transported over long distances.
There are five desirable attributes for a model to possess if it is used to
demonstrate attainment of the NAAQS in ozone SIPs.
1. The model should have a sound chemical and physical basis.
2. The model should have the ability to explicitly consider key factors
affecting high ozone concentrations.
3. The model should have general applicability to a wide varietyof
cities.
4. There should be some demonstration that the model’s predictions are
accurate.
5. The resources to generate information required to run the model
must be capable 0 f being borne by State and local agencies responsible for pre-
paring SIPs.
To some extent, the fifth attribute is in conflict with the preceding four. As a
result, some compromises in the first four criteria are needed in order to accom-
inodate the fifth. City—specific EKNA represents such a compromise.
The model used to generate ozone isopleths needed In the city-specific EK1 tt .
approach is called OZIPP. OZIPP assumes a well mixed column of air, containing
concentrations of locally generated precursors, is located over an urban area in
mid-morning. As the day progresses, these pollutants are transported downwind
until their location corresponds to that of the maximum observed ozone concentra-
tion at the time of the observed maximum. As the hypothetical column of air is
transported, precursor concentrations interact with each other, with fresh emis-
sions, and with pollutants which are entrained from aloft as the atmospheric
mixing layer lifts due to solar heating. Chemical reactions anon; the pollutants
are simulated using a checmial kinetics mechanism that produces good agreement
68
-------
with smog chamber experiments in which automotive axhaust was irradiated with
artificial light.
OZ1PP allows the user to explicitly account for a number of factors affecti ig
the production of ozone. These include the date and location of the simulated
episode, atmospheric dilution, fresh emissions, and pollutants transported from
upwind sources. Because the model is predicated on some physical basis and the
user can manipulate the aforementioned inputs, OZIPP has greater potential to be
more generally applicable than simple models used In past SIP applications. Once
ozone isopleths have been generated using OZIPP, city-specific EKMA is applied to
estimate the impact of control programs on peak ozone. The prevailing ratio of
ambient organic pollutants to NO and the highest ozone concentration observed cn
each day modeled are used to ide tify a starting point on the isopleth diagram.
There has been and continues to be an ongoing effort to “validate” both
OZIPP and the control predictions obtained with city-specific EKMA. These efforts
are described in a subsequent session of the workshop and in Section 3.9 of the
workbook. -
Information needed to support a city-specific EKMA analysis has been identi-
fied on pages 65669-65670 of the November 14, l97 f ederal Register . The informa-
tion requested is consistent with the conceptual framnework of the OZIPP model.
It has been minimized in recognition of the resource constraints which exist for
many State and local agencies. The rationale for requested information is discussed
in the next workshop session and in Section 3.5 of this workbook.
69
-------
Conceptual Basis for EKMA — Outline
A. Ozone Chemistry
B. Factors Affecting Ambient Ozone Levels
C. Application to Ozone Problems in Urban Areas
1. Illustration of Ozone Formation in an Urban rea
2. Ozone Distribution in an Urban Area
- Ozone Peak Downwind of City
- Stagnation Case
D. Desirable Attributes for a Model that Simulates
the Impact of Ozone Control Strategies
E. Physical Model Underlying-EKI’IA (OZIPP)
1. User Controlled Factors in EKMA
2. Internal Factors
• 3. Simplifying Assumptions
F. Chemical Model in OZIPP
G. Advantages/Limitations of City-Specific EKMA
70
-------
NOTES
OZONE CHEMISTRY
OZONE CHEMISTRY WITHOUT ORGANIC COMPOUNDS —
START: NO,. 0,. SunhiQhl
SunIigM—-NO,--.N0 + 0
0, + 0 —0,
0, + NO - NO , + O
OZONE CHEMISTRY WITH ORGANIC COMPOUNDS —
START: P40, 0,, RO ,(OxidIzed Orpantc RadIc , SUnJIQhI
SunJighi ..— ..-N0 ,—-.NO + 0
0, + 0—0,
NO + RO,•—.-NO, # RO
OZONE CHEMISTRY WITHOUT
• ORGANIC COMPOUNDS —
START: NO,, 0,, SunlIght
+ 0
0, + 0 - 0,
0, + NO — NO, + 0,
OZONE CHEMISTRY WITH
ORGANIC COMPOUNDS —
START: NO,, 0,, RO, (OxidIzed Organic RadIcal), Sunlight
SunlIght - -—s ’44O,-’ NO + 0
0 + O—.0,
NO + RO, -- -NO , + R0
FINISH: NO ,, 0 , R0, 0,
fl! H: NO,, ° -. O
-------
FACTORS AFFECTING OZONE CONCENTRATiONS
• Precursor Concentrations and Chemistry
• Sunlight
• Dilution
• Windspeed
• Areal Extent and Intensity of Emissions
• Ozone and Precursor Transport From
Upwind Areas
PREVAILING WINO
IT
ES
DISTRIBUTION OF PHOTOCHEMICAL
POLLUTANTS IN-AN URBAN AREA
AM PM
0, NMOC
NMOC NO
NO, NMOC NO,
0, NO 0,
CENTER
r i CITY
NMOC NO,
NO 03
- =30-50 km
-------
DESIRABLE ATTRIBUTES FOR MODELS
Theoretical or Physical Basis
Ability to Consider Explicitly
Factors Affecting Ozone
Concentrations
General Applicability
Relatively Small Resource
Requirements
Validity
NOTES
JULY 19, 1976 ST. LOUIS RAPS DATA
n a*imt,m hourly aver i tppb)
D C I. 1. 1976 SI. LOUIS RAPS DATA
maximum houfty av ng (ppb)
-------
K I hT
‘ I
Resource Requirements
for
Various Modeling
Approaches
Ozone NOR, NMOC
Monitors Monitors
Linear
Roflback At least 3 None
City-S pecU IC
EKMA At least 3 1-2
Urban Airshed 10-20 6-12 NO
3-6 NMOC
1 -
— --
Meteorological Mess emn’ t -
L inear None
P ic t lbacl
City.3pedilic Morning and afternoon
mixing Peights at one site
SurtaCe winds and
temperatures at two CiteS
Urban Airshed 10-25 surface wind sites
5-15 surface temperature sUes
3.5 mixing height sites
2-3 sItes to measure solar
reduction
- - -
Emission to’reMory
Une ar Countywide inventory None
fietbacli for typical summer
day
City.Specitic Countywide inventory Canned program;
for typical summer small computers
day apprOx. 520-S3Oirufl
Urban Alra?re Hourly gridded Extensive computer
inventory estimates program: Iage
split intO 3-6 computerS approx.
organic classes S40O - &OCf Ufl
-------
BASIS FOR THE CHEMISTRY USED IN EKMA
• Propyfenelbufafle mixture used as surrogate
tot atmospeenc mutute.
• ROCOTtOnS of tosse corOo,jnds ODserved md
modeled ez,etsSJxetV.
• comoinaflcn of Oropytene and butane
s elected tO aoproeim$te behaxior of
lttmd.ated a 30501155
NOTES
FACTORS IN EKMA
Uses Speciltes
— Day o yxar ) ______________ City specific
— LOCSl C!5 at city .1 solar radiation
— Mixing g s 5 - DilutIOn
—Concefl atO ’S of Dolutants to
earty-rrcrnin; wtan area
— Srnr ssions
— Tran p rled ofutan1s
Internal to Model
—Rate of c ar e of mixing height
— Diurnal rariation Of sunhgltt
— Chemrstry
Column Model
— —--
MtJU-
LAYER————
MODEL
LJ MA—
HOUR (S1AHDARD lIME)
• ln ut to model i x g.. surigrit. dilution)
Iypd.ei local COndtiOflS-
-------
NOTES
CITY-SPECIFIC EKMA
Advantages:
— Isopleth curves give control
requirements based on organic
compoundJNO /O 3 .
— Can exp icifly consider
transported pollutants.
Can consider changes in lactors
such as transport, emissions, etc.
concurrently.
Limitations:
—Requires computer.
—City-specific data must be
collected.
—Lack of spatial resolution.
—Complete validation is
difficult.
-------
3.5 Monitoring Needs
The preceding discussion of the OZIPP-model and the scenarios it is intendec
to simulate imply several needs for monitoring and other data. Specifically) the
following needs are apparent:
1. estimating the peak ozone concentration downwind of a city;
2. estimating precursor concentrations during the morning within the
city being reviewed;
3. estimating ozone (and, in some cases, precursors) transported from
upwind sources;
4. estimating emissions encountered by the hypothetical column of air
as it moves downwind toward the site observing maximum ozone concentrations;
5. estimating the height of the well-mixed layer Into which pollutants
are dispersed;
6. estimating wind velocity to verify that air within the city durinq
mid—morning (6—11 a.m.1 Is likelyto impact the site observing highest ozone
concentrations.
Specific air quality and meteorological measurements and siting requirements are
identified on pages 65669. - 65670 of the November 14, 1979 Federal Register .
Emission inventory needs are also described in a report, Fi l Emission I 7entcry
Requirements for1982 Ozôr é State I’mplementation Plans ( E ’PA 45OJ4-8O-O16, December
T 801 and were elaborated upon in workshops held during October 1980. The informa-
tion presented in these references is summarized below:
1) At least three ozone monitoring sites
— one in the predominant surr ’rier daytime upwind direction
- one on the downwind edge of the city to measure peak ozone
during atmospheric stragnation periods;
— one somewhat further downwind (e.g., 15-40 km) to estimate
peak ozone during periods with light but well-defined winds.
2) At least one but preferably two collocated NMOC (non-methane
organic compounds), and N0 monitors
— sitetsl located within the commercial district of the city to
characterize the urban NM0C/N0 ratio and to estimate
morning precursor concentration’s.
31, Countywide reactive 0C and N0 emission estimates for a typical
suniner weekday.
77
-------
4) Surface temperature and pressure ITeasurements at a well yentilated
site near the center of the urban area. If need be, pressure data taken at a
nearby airport can be used instead. These data are used in conjunction with
National Weather Service CNWS1 radiosonde data or locally obtained urban vertical
temperature measurements of the atmospheric mixing layer. Use of these data to
estimate mixing heights is described in detaIl In Section 3.1.2 and Appendix A of
Guideline for Use of City-SpecificE Ain Prep rin 0 o eSIPs and in Section 3.6
f this workbook.
51 Surface wind speed and direction should be measured at at least two
sites, one of which is located In an area of high emissions. Wind data are
needed to verify that the site observing highest ozone Is being impacted by the
city. In city-specific E A, such sparse wind data are not used to generate the
“exact” trajectory followed by a hypothetical column of air.
Most of the -measurements described in the previous paragraphs have been
co non1y performed in the past. Two exceptions are the efforts to measure
transported ozone, and efforts to -measure N! OC. As discussed in subsequent
sessions, ozone transported aloft appears to exert the -most significant impact on
ozone concentrations modeled with OZIPP. Although several problems and procedures
for measuring 03 aloft are identified in the workshop, use of surface measure—
inents of ozone taken upwind from the city shortly after the breakup of the nocturnal
radiation inversion appears to be an acceptable approach for estimating ozone
transported aloft.
Measurement of ambient NMOC requires greater care than other routine air
quality measurements. An additional problem results from the fact that ambient
NMOC is estimated by taking the difference of two large numbers (total organic
pollutants and methane). As a result, small, apparently random, errors result in
NMOC measurements. The problem may be particularly severe for NMOC concentra-
tions less than about 0.5 pprnC. To circumvent difficulties imposed by these
random errors, robust indicators of ambient NMOC are used. Appropriate Indicators
are identified in Section 3.2.2 of Guideline for Use of City-Specific EKMA in
Preparing Ozone SIPs . A detailed Technical Assistance Document for the calibra-
tTon and operation of automated ambient nor-methane organic analyzers has recently
become available. It is recommended that persons operating these instruments
become thoroughly familiar with procedures described therein.
78
-------
Monitoring Support - Outline
A. Purpose:
To characterize conditions corresponding to highest observed concentrations
of ozone so that as realistic input as possible is used in the model.
B. Implications for 1 onitoring Posed by City-Specific EKMA
1. Must estimate wind velocity to determine upwind and “downwind” and
consistency of the model’s assumptions concerning trajectories.
2. l iust estii ate ozone and, possibly, precursors upwind of city.
3. l4ust estimate morning precursor concentrations within the city.
4. Must estimate the height of a well-mixed layer of air into which p01-
lutants are dispersed.
5. llust estimate typical summertime emissions encountered by an air parcel.
6. Must estimate peak ozone concentrations downwind of the city.
C. Wind Velocity
1. Purpose: upwind-downwind determinations.
2. What is upwind?
-3. Indicate why more detailed data are not required for city-specific EKNA.
D. Measurement of Upwind Ozone
1. Difficulties
2. Possible methods of measurement
a. aircraft
b. ozonesondes
c. surface data
3. Preference for surface data -- primarily because it is continuous.
4. What are we trying to measure
- note importance of ozone aloft versus surface ozone
5. Where and when should measurements be made?
- 404- n upwind
- shortly after breakup of the nocturnal inversion, before
photochemistry has had a chance to proceed very far.
79
-------
E. Measurement of Upwind t M0C and
1. Note that concentrations will gener iiy be low O.lpprnC NMOC, mm.
detectable for NO i .
2. Sum of species should be used for NMOC
— note disadvantage of this discontinuous method. Can only
estimate surface transport. Measurements aloft must be done
aboard aircraft.
3. Should measw-e 6-9 a.m. concentrations. As with 03, monitor should be
40+ km upwind.
F. Precursor Concentrations Within City
1. Why needed
- N1 0C/NO ratios
- as a basis for considering the role of fresh emissions
2. Siting Requirements
- N?’ 0C and NO monitors should be collocated in urban core
- two or more sites preferable
- locate -more than 200 -m from major individual sources
- monitor during ozone season (at least 30 days)
3. Difficulties
- with commercially available FID instruments cannot reliably
measure NJIOC .< 0.SpprnC with single instrument due to random
errors arising from taking the differences of two large
numbers.
- use robust measures
(a1 ratio NNOC 69 /NOX 6-9
(b) for single monitor use median 6-9 NMOC/NOX ratio
for five high days -
(ci for multiple sites whose ratios agree with 30 of their
mean, use the mean ratio for the day being modeled.
- NMOC Instruments require greater care than most.
G. Mixing Layer
1. Ordinarily calculated from surface temperatures, pressure measurements
and vertical temperature — pressure profiles such as those available from the S
at nearby airports.
80
-------
2. At least one temperature site at an urban location.
3. Collocated pressure data are preferable.
H. Emissions Data
— countywide reactive YOC and NO emissions for a typical sumer day
— for standard EKMA chemistry speciation is not required
— gridding is not required because it is not comensurate with the wind
field information
I. Downwind Ozone Data
1. Needed to-measure-illaxinium ozone due to city
2. Siting: Cal not within 200 in of major source of N0
on downwind edge of city to account for stagnation days
Ccl 15—30 km downwind from city s edge. For large cities,
this distance -may be most appropriately 40+ kin
J. Suirmary
- at least two wind monitors
- at least one temperature, pressure sensors
- at least three ozone -monitors
— at least one NHOC, NO inonitor
— countywide i’eactive YOC and N0 emission inventory for sun er day
81
-------
NOTES
-------
Specific Information
Provided By
Monitoring
NOTES
URBAN PRECURSOR
POLLUTANTS
FRESH PRECURSOR
EMISSiONS
PEAK OZONE
CONCENTRATION
-------
NOTES
Wind Velocity
MAKE
UPWIND.
DOWNWIND
DETERMINATIONS
STAGNATION
- Okm
* 4ø 4Q
L J
Acceptable
monitoring locations
for estimating transported ozone
Upwind Ozone Measurement
• Measuring and isolating transport component
• Complications introduced by atmospherir
strati fi cation
• Determining extent of urban recirculation
• Demarcation between an urban area and its
upwind neighbors is not always clear.
Methods of Measuring Upwind Ozone
• Surface Measurements
• Aircraft
• Balloons (ozonesondeS)
84
-------
NOTL:S
Surface Measurements
• Low levels caused by scavenging and deposition
• Little impact on urban peak ozone
• Take between 6 and 9 a.m.
ESTIMATING OZONE k.OFT
• CN4 BE SIGNIFICANT EVEN >OJ 2 PPM
• HAVE IMPACT ON PEAK OZONE CONCENTRATIONS,
AS OZONE IS ENTRAINED FROM ALOFT
• IF SURFACE MEASUREMENTS-ARE USED 1 ALOFT
MEASUREMENTS SHOULD BE MADE DURING MID-
• P NING AFTER BREPJ JP OF NOCTURNAL fl’NERS1Ot t
• LIO + KM UPWIND
MEASUREMENT OF UPWIND OZONE
SUNRISE
TEMPERATURE PROFILE
T
0
U i
OZONE PROFILE
TEMPERATURE
0
MEASUREMENT OF UPWIND OZONE
MID-MORNING
I .-
0
Ui
TEMPERATURE
Os
85
-------
NOTES
MEASUREMENT OF UPWIND OZONE
AFTERNOON
F-
I
0
w
TEMPERAT U RE
03
Measurement of Upwind Precursors
• Low concentrations likely
• NMOC measured by sum of species
o MeasurementS between 6 and 9 a.m.
of most interest -
• Aloft measurements must be made directiy.
Purpose of Monitoring Precursor
Concentration in City
• To estimate NMOC/N0 1 , ratios
• To consider fresh emissions
Siting Considerations — City Precursors
• NMOC and NO. monitors co-located
• Two or more sites preferred
• At least 200 m from major sources
• Montoring shOUld occur for at least 30 days
during ozone season.
-------
NOTES
DERIVING
NMOC/NO
RATIOS FOR
EKMA
-
1 monitor — Use median ratio of
highest ozone days with
precursor data.
2 or more monitors —
— If site ratios within 30% of
average, use day-specific ratio.
—If not, use mean median ratio
from all s1tes
Sftel Site ?
2 10:1 10.S:
3 13:1 8:
4 7:1 6:1
i ii
Median 9:1 ed fl 8:1
‘ e n Mediafl a io
‘ 5, use a raiO of 8. :1
-------
ES
Technical Assistance Document
for the
CALIBRATION AND OPERATION
OF
AUTOMATED NMOC ANALYZERS
MIXING LAYER
• Surface Temperature Data
—At least one urban site
• Surface Pressure Data
— Co-located with temperature data.
— If not, need to know elevation.
• Vertical Temperature Profiles
—Can use NWS data.
: -
-------
EMISSION DATA
* Know what
to reduce
* Estimate fresh
emIssion In
model
NOTES
COUNTYWIDE
REACTIVE VOC
for, a
Summer
Weekday
NO, EMiSSIONS
iNVENTORY
for a
Summer
Weekday
PURPOSE OF DOWNWIND OZONE DATA
— To measure maximum ozone
attributable to city.
SITING FOR DOWNWIND OZONE DATA
• At least 200 m from major NO sources
• At least two sites needed:
— One at downwind edge — stagnations
—One 15 to 40+ km downwind —
well-defined winds.
-------
NOTES
SUMMARY OF MONITOP NG REQUIREMENTS
• At least two wind monitors
.-,--
SUMMARY OF MONITORING REQUIREMENTS
• At least two wind monitors
• At least one urban ter hperature and
pressure sensor -
SUMMARY OF MONITORING REQUIREMENTS
• At least two wind monitors
• At least one urban temperature and
pressure sensor
• At least three ozone monitors
- - —. .
SUMMARY OF MONITORING REQUIREMENTS
• At least two wind monitors
• At least one urban temperature and
pressure sensor
• At least three ozone monitors
• At least one N DC monitor
I
-------
SUMMARY OF MONITORING REQUIE MENTS NOTES
• At least two wind monitors
• At least one urban temperature and
pressure sensor
• At least three ozone monitors
At least one NMOC monitor
• At least one NO monitor co-located with
NMOC instrument
S
SUMMARY OF MONITORING REQUIREMENTS
• At least two wind monitors
• At least one urban temperature and
pressure sensor
• At least three ozone monitors
• At least one NMOC monitor
• At least one NO monitor co-located with
NMOC instrument
• Countywide reactive VOC and NO
emission inventory
-------
3.6 Use of Data to Generate Isopleths
Previous discussions have focused on the conceptual basis for the model
underlying the EKMA technique and on the monitoring requirements for successful
application of the modeL In this section, we see how these are put together
such that city-specific ozone isopleth diagrams can be generated. Formulating
input data and running the OZIPP computer program to produce the necessary
diagrams are each described.
The city-specific input variables to the OZIPP program can be grouped in
six categories: light intensity, dilution, 03 transport, precursor transport,
post C800 emissions, and reactivity. These city-specific inputs determine the
positioning of the isopleths on a diagram, and thus directly affect control
calculations. Procedures for determining appropriate values for each of the
city-specific inputs have been developed, and are described below. In some
instances, optional procedures may be more suitable, and these are also discussed
to some extent.
The city-specific inputs controlling light intensity are city latitude,
longitude, and time zone, as well as specification of the day being modeled.
These inputs are straightforward, and present no problems to the OZIPP user.
Furthermore, sensiti\’ity analyses suggest that this particular set of input
variables does not have a substantial impact on control estimates, and this is
not a critical element of an 0ZIPP/EK? analysis.
Dilution in OZIPP is determined by the morning mixing height and the maximum
afternoon mixing height. Additional options allow specifying the time of growth,
but normally default times are assumed (i.e., 0800-LDT and the afternoon time
corresponding to 70% of the daylight hours). The recorrmended procedure for
estimating the mixing heights themselves makes use of city measurements of
temperature and pressure used in conjunction with National Weather Service (NWS)
radiosonde measurements. If other radiosonde measurements or special studies
(e.g., helicopter flights) are available, they may be used in place of the NWS
measurements. If neither of these are available, and the NWS data are not
representative, clIrnatological data may be used. However, because of the critical
nature of these variables, this approach should only be used as a last resort.
Sensitivity of control estimates to this set of variables is very complex due to
the interactions of pollutants transported aloft and effects of post 0800
emissions. Thus, every effort should be made to obtain accurate estimates of
these variables.
Another critical element of an OZIPP/EKMA analysis is estimating the levels
of ozone transported into the urban area from upwind. Such transport occurs by
two mechanisms: transport in the surface—based mixed layer and transport aloft
above the early morning mixed layer. Transport in the surface layer has been
found to be unimportant due to scavenging by readily available NO, and is recom-
mended to be set to zero. If explicit consideration Is desired, 6-9 a.m. urban
average levels of 03 may be used to provide appropriate estimates. On the other
hand, transport of 03 aloft has long been recognized as a significant factor,
and must be addressed in an OZIPP/EKMA analysis. The recon nended approach for
estimating the 03 level aloft is to use a mid—morning average concentration
92
-------
measured at a surface based continuous monitor ‘ . Is located upwind of the
city on the day being modeled. The mid-morning should correspond to the
breakup of the nocturnal inversion; but if inforTn : on on the latter is not
available, an 1100-1300 LDT average is recorimended. If direct measurements of
03 aloft are available (e.g., aircraft, helicopter, towers, etc.), they may be
used in place of surface data. If day-specific measurements are not available,
the median of all available estimates of 03 aloft for all days being modeled
should be used.
Little evidence exists to suggest that the transport of precursors is a
significant problem. Furthermore, sensitivity analyses suggest that low to
moderate levels of precursor transport are unimportant in an OZIPP/EKMA analysis.
As a result, explicit treatment of precursor transport Is not normally recom-
mended, and all transport levels should be set to zero. If detailed monitoring
of precursor transport levels is available and indicates significant transport
levels, then precursor transport should be addressed. In this instance, Appendix B
in Guideline for Use of CityrSpecific EKMA in Preparing Ozone SIPs should be
reviewed, and any questicn forwarded to EPA for special consultation.
The consideration of post 0800 emissions in an OZIPP/EKMA analysis can be
an important factor in many instances, and therefore should be explicitly
considered in the analysis. The procedure for developing the input data repre-
sents a compromise between accurately representing the physical processes taking
place and their associated data requirements. Because the latter can be extremely
resource intensive, several simplifying assumptions have been made to permit the
consideration of post 0800 emissions in a routine manner. First, the post 0800
emissions are determined by the air parcel trajectory leading to the observed
peak 03 level of interest. This trajectory is assumed to originate in the urban
core and move at uniform speed to the site of peak ozone by the time it is
observed. The actual hourly levels of post 0800 emissions are determined by the
magnitude of VOC and N0 emission densities in each county, and the county in
which the air parcel is located during each hour. However, post 0800 emissions
are input to OZIPP as fractions of initial concentrations added each hour. The
hourly emission densities defined by the trajectory are converted to fractions
by means of the model initial conditions, i.e., urban, early morning, precursor
concentrations, and mixing height. Thus, post 0800 emissions fractions input to
OZIPP are functions of the hypothetical trajectory, county emission densities,
early morning urban precursor levels, and initial (i.e., 0800 LDT) mixing
height.
Three city-specific inputs are associated with reactivity in OZIPP. Two
of these, the fraction of NMOC which is assumed to be propylene and the fraction
which is added as aldehydes, are associated with the overall reactivity of the
organic compounds. This reactivity was based on smog chamber studies of irradiated
automobile exhaust, and is explicitly tied to this study. To date, these fractions
have not been related to other atmospheric mixes and the specific recorr iended
values must be used. The other reactivity variable Is the initial N0 2 /N0
ratio. Normally, this variable is not critical, and a value of .25 is reèommended.
If specific inputs are desired, the N0 2 /NO ratio may be derived from 6-9 a.rn.
NO 2 and NO measurements taken in the urba core.
93
-------
The preceding city-specific variables are input to OZIPP by means of
exercising specific options (e.g.., the option DILUTION would be used to input
nixing height data). Each option contains a set of associated default inputs
which are assumed unless over-ridden by new input data. To actually generate an
isopleth diagram, the user exercises the ISOPLETH option. The scales of abscissa
and ordinate as well as the ozone Isopleths plotted, can be controlled by the
user. All city-specific options exercised prior to the ISOPLETH option will be
reflected in the ‘diagram. In deriving the diagram, It is important that the 03
isopleth of interest be located in the right half of the diagram to facilitate
computation of control estimates. The CALCULATE option Is an inexpensive means
of checking to insure that this occurs. This option performs a single simula-
tion corresponding to one point on the isopleth diagram. Thus, candidate scales
of the abscissa and ordinate can be checked using the CALCULATE option to Insure
that 1) the ozone level of interest is found within these scales, and 2) the
isopleth of interest is towards the right edge of the diagram.
94
-------
Generating Ozone Isopleth Diagrams - Outline
A. Introduction
— Overview of Discussion
- SunTnary of OZIPP Inputs
— Effects of City—Specific Inputs
B. Formulation of City-Specific input Variables
1. Sunlight Intensity
a. Significance
b. City-Specific Inputs
— Latitude
- Longitude
- Date
- Time Zone
c. Sensitivity
- Important for Ozone Generation
- Not Critical for Estimating Controls
2. Dilu ion
a. Significance
b. City-Specific Inputs
- Morning Mixing Height
— Final Mixing Height
- Start Time for Rise
- Ending Time of Rise
c. Procedures for Estimating Inputs
d. Sensitivity
— Complex Interactions
- Critical With Respect To Ozone Generation
— Control Estimates Tend to be Insensitive to Small Changes
in Dilution
- Affects Importance of Pollutants Transported Aloft
95
-------
3. Ozone Transport
a. Significance
b. Mechanisms of Transport
c. City-Specific rriputs
- Level Aloft
- Level in Surface Layer
d. Procedures for Estimating Inputs
e. Sensitivity
- Surface Layer Transport Unimportant
- 03 Aloft is iore Complex
4. Precursor Transport
a. Significance
b. City-Specific Inputs
- Levels Transported in Surface Layer
— Levels Transported Aloft
c. Recommended Procedures
d. Sensitivity
— NMOC Transport May Be Important if Levels Are High
— NO Transport Not Critical
5. Post 0800 Emissions
a. Significance
b. City-Specific Inputs
— Definition of Emission Fractions
- Sources of Data
— Conceptual Basis
c. Example Procedure for Estimating Inputs
d. Sensitivity
- Complex Interactions
— Sensitivity Increases with Lower Initial Concentrations
96
-------
6. Reactivity
a. Significance
b. City-Specific Inputs
Propylene Fraction
- N0 2 /NOX Ratio
- Aldehyde Fraction
c. Recommended Treatment of Reactivity
d. Sensitivity
C. OZIP? Computer Operations
1. System Overview
2. OZIPP Options and Card Formats
- PLAC
— DILU
- TRAN
— EMIS
- REAC
— ISOP
- CALC
3. Format for City-Specific Inputs
4. CALCULATE Procedure
- Purpose and Uses
- Computer Resources
- Options
— Outputs
5. ISOPLETH Procedure
- Purpose
- Computer Resources
- Options
- Outputs
97
-------
GBnerating
Ozone
Lsopleths
NOTES
Generating an Ozone Isop eth Diagram
• Formulation of City-Specific Inputs
— Significance of each variable
— Use of available monitoring data
— Sensitivity
• Operational Aspects of OZIPP
— —
— itt.
It’
St •
NI. MIPS —f &.Ifl$ ,f I n i I
I I . P•n..,.i I.fltI.d 1.11
OZLPP INPUT VARIABLES
1) Light Intensity
2) Dilution
3) Ozone Transport
4) Precursor Transport
5) Emissions
6) Reactivity
98
-------
SENSITIVITY
June 21 Los Angeles
versus
Sept. 15 PhUadelph a
• Decreases In predicted maximum
1.hIeveIsot4 1023%
• Conlro requirements
reduced by 1 lo 2
NOTES
4 —si—— q_I _
, 1 -‘-— -
I
1 1 I
r i
-1
.1 1— .
I it £‘
5 n c.nc.: ...cII ., ..Ies II
phOt&yIiC ..CI. t lb. O I po. .’ .t bs.n;
NO, t! NO • C
LIGHT INTENSITY
Inputs to OZIPP:
1) Latitude and longitude of city
2) Date
3) Time zone
-------
NOTES
SUMMARY
Inputs Straightforward
Resutts Relatively Insensitive to Inputs
—
4 .__L _ 4 _t 7 ._ __I _
. 5II tLi(
- . 1.1.t *I II—
i I i
Iii
i 1 t.i 1 i.. !1._T
$ 1I e.see 1 d 5l$s.v 5
,Uws ;.sI.C, 5.,.d m ..d .y,. •. 21v.ts o
sJ poII s. iv k. td .‘e41 .bs.. vhs
— •a.I flwln PEStC Ifltt
DILUTION
Inputs to OZIPP:
1) initial mixing height
2) Final mixing height
3) Starting time of rise in mixing height
4) Ending time of rise in mixing height
SOURCES FOR ESTIMATING INPUTS
Recommended: National Weather Service
RadiosOnde Data
Option 1: Special Monitoring Data
Option 2: Cumatological Data
100
-------
S lflSI TVZTY
Sensitivity complicated by interactions with pollutants
aloft end post 0800 emissions. In general.
— Ozone production reduced by ir.creased dilution
(can be substantial)
— Control requirements relatively ir.sensitive to
small changes in dilution
—Inportance of pollutants aloft heightened with
increasing dilution
Inputs estimated from day specific meteorological
measurements or clinatological data
Norna3.ly only 0800 LOT mixing height and ma.xim
afternoon mixing height estimated and default tiiaes
assumed for rise
Relative mixing heights are st ipcrtazit inputs
-------
DATA FORMAT FOR MIXING HEIGHT
PROGRAM
First Line —bbblbbl700.
NOTES
Columns 1-4 0= 0800 LCT
1 = Maximum
Columns 5-11 Climatological
Mixing Height
ground level)
Noles: b = Blank Column
Mixing Height
Mixing Height
Value for Maximum
(in meters above
74 1 ) 1*
———3
I
-
—- 01 I I
DATA NEEDED FOR ESTIMATION
OF MIXING HEIGHT
Surface Data:
0800 LCT-Temperature 23.2 °C
Pressure: 1010.3 crib
Maximum Temperature: 31.4°C at 1700 LCT
1700 LCT Pressure: 1008.6 mb
Sot nciing Uata.
m O T M ’ S. ..e 00000t0 e. . 4.q
p. 0 1 $$ — ‘ *AStl V.. ’. rd • ‘ . ‘i * . ’ .I —bl j4• 1 * l )**Su I. . ’. . rd
S ¶001 8 730 S %On I $10
0$ 1000 l Ot fiG ‘70000 VU 00*
S flY — 044 $4 I SO IS O? ‘04
— ISO ‘SIC 102 S UI — $04
S II? — III S Ill — I S O
$ U, — fl * S 718 — OS
— tee Ins .1 S IS O — $0.2
o *00 — 8* 0$ 000 4’*4 0.0
$ III — $0 $ 07* — I I
$ 107 — IS S St.’ — 15
— ‘ .O 5440 —05 — 5050 _7.3
S LI I — — 0.3 $4 *00 IStO —
o 451 — — II. ? S 4 ?’ — —74?
$ 404 — I SO TM 304 0050 _0J
$4 400 00*0 — I* ? S 70$ — — fl $
S 34* — 7$ — 010 0*100 -420
S 14$ — —7.1 5 705 — —$2 8
$ 704 — — no Ioor o ‘.01.3
— no flee — 33. , — Is. 1 1,00 ‘.50.0
5 001 — 1 10 S Ii ? —
S 700 10000 ‘.41 1 5 l O U — ‘.41 I
04 no • 3 $ - SI) S 000 5*00 — $3.0
S ISO 04.70 ‘.50* 5 10 12000 00S
o I4 — -5 1.5 — 54 7,0.0 —345
0’ 30 4$000 ‘.4*0
S 00 27510 —44
o ‘1 — • ‘ 0 1
M. ..40 14 t 1.4.0.000 . 51$ .. 1 10 . 110 .4 ’ I
I .. 5405 5 ? ’. $ 1 1. 0.7.400 * 41 0 . 2
,... o0000 ’ . ’ 1 S.- . . .4.. .s .141 .10044044.,.. GILt -
-------
1.
. 1
1700.
2.
62.0
1008.6
31.4
:
3.
114.0
1000.0
30.6
4.
1537.0
850.0
16.4
5.
99999.9
831.0
-
15.4
i
6.
99999.9
791.0
13.2
7.
99999.9
778.0
11.8
8.
99999.9
760.0
11.2
9.
3164.0
700.0
7.0
10.
@ E0F
POTENTIAL
HEIGHT
PRESSURE
TEMP.
TEMP.
-
•
MASt
62.0
MB
1008.6
OEG.C
31.4
OEG.K
303.9
114.0
1000.0
30.6
303.8
1537.0
850.0
154
303.4
99999.9
831.0
15.4
304.3
99999.9
791.0
13.2
.0
90999.8
778.0
11.1
.0
99999.9
750.0
11.2
.0
3164.0
700.0
7.0
.0
2.
62.0
1010.3
23.2
3.
139.0
1000.0
23.0
4.
99999.9
967.0
24.4
5.
1550.0
850.0
16.2
6.
99999.9
827.0
14.2
7.
99999.9
817.0
13.6
8.
3168.0
700.3
4.6
9.
@EOF
2nd line — bbbb62.Obb 1008.Sbb 31.4 Urban surface data
3rd lIne — bbbll4.Obb 1000.Obb 30.6 SoundIng data
Columns 1.8 — Height above sea level In meters
Columns 8.16 — Pressure In millibars
Columns 17-22 — Temperature In degrees Celsius
Notes: b Blank column.
For missing data
— use 99999.9 for height.
— use 999.9 for temp.
Urban surface data replace surface
level on the sounding (2nd I ne .
k
INL) I t
INPUT:
INPUT!OUTPUT FOR MAXIMUM MIXING HEIGHT
LiNE EXAMPLE
NUMBER
OUTPUT:
MAX. MIXING HEIGHT 1513.
METERS AGL 837.3 MIL.LIBARS.
THE cuMATOLOGIcAL MAXIMUM MIXING HEIGHT
VALUE ENTERED WAS 1700. METERS AGL.
INPUT: INPUTFO 1JTPUT FOR 0800 ICT MiXING HEIGHT
LINE EXAMPLE
NUMBER
-------
62.0
1010.3
232
295.5
139.0
1000 0
23.0
296.2
OUTPUT:
HEIGHT PRESSURE
MASL MB
POTENTIAL
TEMP. TEMP.
056.0 056 Ic
NOTES
A000RD(NG TO THIS METHOD. THE LOWEST
LAYER OF THE SOUNDING IS NOT WELL MIXED.
THIS IMPLIES A MIXING HEIGHT OF ZERO
METERS AGL THE URBAN MIXING HEIGHT IS
GREATER THAN THE 0. METER MIXING HEIGHT
COMPUTED BY THIS METHOD. 250 METERS AOL
SHOU 1D BE USED FOR THE ERMA 0800 LOT
MIXING HEIGHT.
THE CLIMATOLOGICAL MAXIMUM MIXING
HEIGHT VALUE ENTERED WAS 1700. METERS
AOL
POLLUTANTS: O,.NO.
I0O,, 2r6 XTC
NM IISPEM.A1U’t
ozONE
TRANSPORT
I r I
-------
O&OO—
u uu
I OO
---— ---— AX. U, T1ME)—
HIC 0, AI.OFI
(UN SCAY EN CEO)
NOTES
tMXING
DEPTH
y — =
D, 0ppm --
/
OZIPP APPLICATION IN CITY SPECIFIC EKMA
INPUTS TO OZIPP
1) Concentration of 03 aloft, ppm
2) Concentration of 03 transported
in surface layer, ppm
SOURCES FOR
ESTIMATING INPUTS
03 Aloft
Recommended: Use 1100-1300 LDT average
upwind surface measurement for day modeled
Option 1: Use available direct measurements
(e.g., aircraft, balloons, towers)
Surface Layer 03
Recommended: Set to zero.
Option 1: Use 6-9 a.m. urban average levels.
SENSITIVITY
• Ozone production and control estimates are
not sensitive to surface layer transport of
ozone.
• Sensitivity to ozone aloft is complicated by
interactions of dilution and post-0800
emissions. In general —
— O maxima increase with increasing 03
aloft (generally 50% additive).
—_Control estimates increase with 03 aloft.
-------
NOTES
SUMMARY
• 03 aloft usually is obtained from upwind
surface measurements.
• Surface layer transport can normally be
neglected.
• Cons deratjon of 03 aloft is a critical input.
Precursor
Transport
i ’n fl1 E
INPUTS TO OZIPP
1) NMOC and/or NO concentrations
transported in surface layer.
2) NMOC and/or NO concentrations
transported aloft.
— — __
. — -
SOURCES FOR ESTIMA1]NG INPUTS
A) Pracursors Aloft
Recornmen e Approach: Set to zero.
Option It threc.i rrreasurernerr?s are
a aitabe arrd e els are siç uticant, use
measu ernentS o estimate transporled
levels atctt.
8) Surface Layer Transport
ecom enCec Approacti: Set 10 2eT0.
Option 1: Use Upwind measuremeMs 10
derive :Qntr.0u1 c’r of Lrar Sp0r1 to r0an
le eIs. FolIo ;ui0ance cOr tae0 in EPA
450/4-E.3-027, nopsr ix B.
q
-------
f r
•17t? Vfl7C 3
Srt.: . ant C.t?1DI3’* . t o .
C. t,,a t. . **7t o S— 7. ‘.3 .3_ 37.o: . a: .-
:34 4 .t .7 .3 .3
32 .1 .3 3 .1 .3
.3 .1 .2
.14 4 C • .3
12 .3 — . •2 —33
14 .2 .4 .4
.32 I .3 * .3 .7
32 .3 . • .1 —
14 .3 • .5 .1 8
imn .o. Al o23
3t005’ot .o Of k3IX C 1O°t
B .4 .4 .32
12 .2 .4 .
31 .3 - .4
.24 I .7 . .3
32 *3 .3 .
14 .3 .5 .7
.3C $ .2 —2 .5
32 —1 .3 .4
54 *2 •3 .4
— - -.---- --
S#fl• .e tiy .r lv.R,flrt
$ . ..t. f.., ..
•..t. to . Z:,o3 5.1:-. 3C-7 ?. .3 . 42-32 %
3$ $ . .5 .3
12 *3 .5 .1 ‘Z U
5$ 44 .3 .5 .3 .3
. 7 4 I 4 . .7 44
32 *3 .3 7 U
31 .5 .1 * . .
$ 4 *1 .3 .
4 .3 .3 •1 2
11 4 .3 3 2 .2
“ .%.,3 $3 t5
C
C, o.. .. o l . 5 . 53 o.C - .
14 $ .3 .1
37 - *2 2
11 4 0
.3 4 1 .4 •3 -0
52 .5 .1 .
21 .1 $ .
— .1 *5 .
17 .1 .2 .3
3$ .7 $ .7
1
-------
SUMMARY
• Consideration not normally recommended
(i.e., assume zero).
NOTES
SUMMARY
• Consideration not normally recommended
(i.e., assume zero).
• Sensitivity studies suggest NO transport
would not have a significant impact on
control estimates.
SUMMARY
• Consideration not normally recommended
(i.e., assume zero).
• Sensitivity studies suggest NO, transport
would not have a significant impact on
control estimates.
• Direct measurements must be available for
precursor transport.
Post 0800 Emissions
C ;, a m . I.
1 flO
-------
INPUTS TO OZIPP NOTES
• Emission fractions for NMOC and NO,, for
each hour of emissions. Fractions express
post-0800 emissions relative to Initial
NMOC and NO,, concentrations.
SOURCES FOR ESTIMATING INPUTS
• Relationship between ozone maximum and
urban core (i.e., trajectory).
• Countywide emission inventory.
• Estimate of initial NMOC and NO,,
concentrations . _______________
Basis for Calculation of Emission Fractions
C 0 C 1
H 0 H,
=
8 9
E,n$i,.lon D.n.Ity (0 )
Example:
1) Assume an NO,, emission density of 47.3
kg!km 2 -h.
2) Let this emission flux be dispersed into a
column of constant height (0.250 krn) for a
period of one hour. After one hour the NO,,
concentration in the column should be —
C=QAt=Qt
V H
C = ( 47.3 kc!km 2 -h ) (1 hour)
- =0. i00pom
(1690 kgikm 3 ppm) (0.25 km)
Thus, the 47.3 kglkrn 2 -h emission density
would produce a concentration of 0.100
p m in the column. ____
-------
NOTES
3) An NO emission fraction for one hour
should be calculated by dividing the
emission-produced concentration by the
initial concentration. For example:
Initial Emission
Concentration Fraction
0.050 2.0
0.100 1.0
0.200 0.50
e r att’ p ct t Ca c a oci rniss on F ach is
En n (°t
Example:
1) Assume the initial NO,,
concentration = 0.200 ppm and the initial
mixing height=0.250 km.
. .-—-——— —
-
2) Ffrst, calculate an emission density that
would generate the initial concentration
after one hour.
Qo=CV = OH
At t
Qo=(0.200 ppm) (0.250 km) (1890 kglkm 3 ppm )
(1 hour)
= 94.5 kgikm2 h
P
-------
3) Calculate emission fractions by dividing
hourly emission densities by this initial
emission density. For example —
Hourly Emission
Emission Density Fraction
23.6 kgfkm 2 -h 0.25
47.5 0.50
94.5 1.0
NOTES
POST-0800 EMISS1O ’4S
EXAMPLE CALCULAT1ON
Step 1: Determine hour’y sequence of emissions.
AII*4on*.II.aA..Sfl. C.uety 1 4,. .Cfl. 0.Ia
P..1 .........d &4,... .4 AA4.. A
l.I.... lQO.I O3LC1. OC
II,. IA 2 tA
C•AIA$ lf (1A C.. . .AIy A,...I ..
* . . 2 W ,. ‘1
B OQ 3 ). ,G
C I64. ? eO
cc
R?D. 1.i7 1 9 A 1
A .I...V ’4 IW• IA b. 1 W . r.A4 I)
.. IA dovn.Ind •$ t -
II .. W 1 A* .Id .4 IAIA . A* .q ...I A .ç , MA
A .1 hA A ‘
•Ad I LCt.
c C&A.$.. hAI’. ..AT4 d.AU •
- * IAA I•I
lOc }S%% S*t. VOC £—.n.i
C.. . .My L... .& I . ••* II . —
A 120 S S.IO
$ 2 3 I,
o I
2 91. 3
3 3d. 10
t1.,0.
ad — ,—
NC £.unr
a.... . V. -
22 ‘
22
0 1
1 .tns.a 0—Sdv * .a ..,.rtaIJO ’
-------
NOTES
D$ Ip.7.4 1 7 1..q. ...7c. Al . .l..s
• 7.2. S.q..u.l VOC NO ( ,A ...on
I4 1I . .. (C T Lo .,2u . . (C .ut I o. .n.l y. k . ., —7. A .fl*Ilp. 49 . 7” 7
$0 A 470 220
I 0*0 703 101
3 lOll B $0 17
4 1 112 B 40 11
0 12 13 8 90 77
S 7314 BC 4$ Al
I 1410 C 07 04
Step 2: Determine initial conditions and calcutate
Initial emission density.
A £V UsbIs IM0.Thal204 1
Ur ..f.
MounD. P07 1 . 1 .01 8.7 7.4 1 -9 4-9
— Au O .oal.iy Oats 1 NMOC 23 20 2 5 t 9
NO 0200 02 ( 0 016.) 0270
NMOCI . ppmC
NO )PP l 1 l 2 NUOC 11 2.7 26 17
NO 7 0190 0.220 0170 0190
— 0500 LCT N n
0200 0rn
B) Cacul .l. 7.2.0.0 A.o,.g. £9 ( C I Cono.nl .ation
— 19. 1.7
CNMOC 2
CNO • 0220 • 0250 0200
C) CaIc . .’.I. 2nil el Em o.oo tl.nslti•$
77. VOC
0. 0 Co 106 (095 .n Dl 7Cll 1 0 . 7*CI 0 5 110) • . 11
07. NO
0. C . .ll0 — ll$906 .&p010Il020OP9**1ll0 2 7.,nl •
Step 3: Calcutate hourly emission fractions by
dividing hourly emission densities by the
initial emission density for each precursor.
VOC M .o .dI NO H7.ull
(..sl..l.o ISNOC E.rA. .D. L ..u ..lou 0o .Il 7.0 7. ou
N T7.. C1 F l7A l ) 7 *’
• 4*0 OIS 225
O 1D 009 lSl Ol
3 701 1 ,,
90 003 006
1411, 009 04 000
1S7.i1 17 •0 1 17*n &t *I, ’,7 1
I c.ct.’a • O.oolyfllfl,4 17* 0*07477)
— In, ,,.! VOC (4.’..!,’ • 2
— Vol .71 141 ) 0......, • IS “•
-------
NOTES
INPUTS TO OZ1PP
1) Propylene/butane split
2) Initial NO 2 /NO ratio
3) Fraction of initial NMOC added as
aldehydes
SENSITIVITY
• Sensitivity of control estimates to
post-0800 emissions is complicated by
interactions between initial conditions and
mixing heights. Sensitivity is greater at low
initial concentrations.
• Generally, ozone maxima increase with
increasing post•0800 emissions.
• Control estimates may be reduced with
inclusion of post-0800 emissions.
SUMMARY
• Post-0800 emissions information derived
from assumed trajectory, available emission
inventory, and initial conditions.
• Post-O800 emissions sho.uld be considered
because they can be important under some
circumstances.
Reactivity
0 ta ‘C
— — __%_,. 0 * *. —
-------
NOTES
ESTIMATION OF INPUTS
1) Propylenelbutane fraction should be set to
recommended value, i.e., 25% propylene.
2) NO 2 !NO ratio of 0.25 is recommended;
however, the ratio can be calculated Irom
urban 6-9 a.m. measurements of NO 2 and
NOR.
3) Aldehyde fraction should be set to
recommended value, i.e., 5%.
SENSITIVITY
• No basis for altering HC reactivities.
• Limited smog chamber studies suggest that
ozone production is not critically sensitive to
HC composition changea .
• 0, production and control estimates are
insensitive to N0 2 /N0 8 ratio.
—
SUM MARY
• Recommended values for HC reactivity
must be used.
• CONSIDERATION of NO 2 INO IS not
important.
—
OZIPP COMPUTER
OPERATIONS
ozIpr
I I PJ T
1 PP j11u1. E
(opti i)
OUTPUT
LISTIM
-------
NOT ES
OZIPP COMPUTER
OPERATIONS
inputs
Input Variables OZIPP Option
Light Intensity PLACE
Dilution D!WTIOM
Ozone Tran p rt IB SPORT
Precursor Transport TRAI4SPORT
Post-C300 Emissions . SiOwS
Reactivity E QTZV ITY
lsopleth Diagram j QPLEfl-i
Single Simul licn CAICULATE
- - --- - ---
Format
cc cc cc cc cc cc cc
1- 0 ii• 2 ’3O 3t - 0 41-Se 3 1-60 6i70
Field The Id F1e(d FIe FIeIdT Field
Optlon always goes In Field 1.
- - - — --- -
OZIPP COMPUTER OPERATIONS
INPUT FORMAT
F*Id I C*s 2 E.. e3 Fi. a F..IC S I5 S F., ø 7
PI Ln ’ 4. SN s 0.N V... M lP Oa
p4.oSei l1fl2sc Ot I’S7S iS.t i
51 ..
1Q.) tS3C. tfl3&)
1v...swl C, s.L C, . s kl.I 5.L N.Ao: .10 ,1 NO S L NO l ft
p.O) CC , 40.0, ,o .o
c e.fly WO,,’.O A10 .’ e
h .cI,On b . ’0”
2.25 1
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-------
NOT ES
OZIPP COMPUTER
OPERATIONS
Calculation Procedure
Purpose: To perform a single simulation for a
given initial NMOC and NO level
(corresponds to one point on the
isopleth diagram).
Uses: 1) To make an absolute ozone
prediction.
2) To define scales of isopleth
diagram.
Computer Resources:
Time: <20 seconds
(UNIVAC 1100)
Cost: $1.00
Output Options:
Minimal information option =0.0
Maximum information option=1.0
11
‘1
-------
J E ES
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118
-------
- CITY-SPECIFIC EXAMPLE NOTES
I I S I 5 5 1 5 5
-‘U
S.
.Ifl ..• •
. — 5 1 1 I S I I S
• S III 2 O •3S .11 3 S OS
OZIPP COMPUTER
OPERATIONS
Isopleth Option
Purpose: To generate an ozone isopleth
diagram.
Computer Resources:
Time: <1O minutes
Cost: <$30
Output Options:
1) Print time of 03 peak
2) Generate off line plot of isopleth diagram
(Use Plot Option)
3) Set scales of diagram
4) Set isopleth levels to be plotted
-------
n
(I’..S’C’’ . * I NOTES
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NOTES
-------
3•7 Application of Isopleth Diagrams in EKMA
The preceding section described how jndjyidual ozone Isopleth diagrams are
generated. Each diagram corresponds to conditions leading to the peak ozone
concentration measured at one particular site on a given day. In order to
determine the overall SIP control requirement, an estimate is needed of the VOC
emission reduction necessary to lower the observed peak to 0.12 ppm. The VOC
emission reduction for each specific case is estimated by means of the E 4A
technique using the isopleth diagram, observed peak ozone, and measured data on
the NM0C/NO ratio. Described below are the assumptions underlying this approach,
and procedures which should be used to make the calculations.
An isopleth diagram is generated by performing repeated simulations with
differing assumptions about initial precursor concentrations. Post 0800 emis-
sions also vary in proportion to the Initial concentrations because these emis-
sions are expressed relative to the initial concentrations. Therefore, points
on a diagram represent different emission levels. One point exists on each
diagram which corresponds to the base conditions (i.e., the measured NMOC/N0
ratio and observed O. peak). All other points represent effects of changingX
precursor emissions Li.e., both pre- and post 0800), relative to the base case,
assuming everything else remains constant. For example, assume the NMOC and NO
coordinates of the base point are 1.2 ppmC and .16 ppm, respectively. The poln
found at 0.6 ppuC NMOC and .12 ppm NO, would represent a 50% reduction in VOC
emissions and a 25% reduction in N0 emissions. Thus, once the base point is
defined, the diagram may be used 1) to evaluate the effect on any proposed
emission reduction, and 2) to estimate the overall degree of VOC emission reduc-
tion needed to reduce the ozone peak to 0.12 ppm, given a change in NO emissions.
As indicated above, all emissions (i.e., both pre -0800 and post 0800) re assumed
to change by the same percentage. Also, when a single diagram is used for one
of two purposes described above, ozone is predicted as a result 0 f precursor
emission changes alone, with all other conditions remaining fixed. For example,
when a single diagram is used, the level of transport aloft is assumed to
remain constant.
The actual procedure for estimating the VOC emission reduction needed to
lower a peak ozone level to 0.12 ppm consists of 1) locating a base point on the
diagram, and 2) finding a point representing the post-control state (i.e., the
point at which the 03 peak is predicted to be 0.12 ppm). The key to finding the
starting point is estimating the appropriate NMOC/NO ratio. A day specific
N OC/H0 ratio may be derived from urban 6-9 a.m. me surernents of NMOC and NO
provide that measurements are available from more than one site, and little
variability exists among individual site ratios (i.e., ratios for each site are
within +30% of the mean ratio). If neither of these criteria are met, then the
NMOC/N0 ratio used in control calculations should be the median of the NMOC/NO
ratios ëalculated for each day being modeled. The starting point on the diagra
is found by the intersection of this ratio with the ozone isopleth corresponding
to the measured peak. Note that, in effect, the OZIPP model is calibrated to
mE asured data by this procedure. The post control point is found by first
estimating the change in NO emissions likely between the base period and the
post control period (usuall 1987). The N0 level found at the base point is
122
-------
adjusted by this anticipated percentage change in NO emissions. The adjusted
NO level is then located on the 0.12 ppm isopleth i order to find the post
co tro1 point. The required VCIC emission reduction is computed as the percentage
difference in the NMOC levels associated with the base point and post control
point. This is the VOC emission reduction necessary to reduce the peak ozone
level to 0.12 ppm for a particular site/day combination, assuming all other
factors remain unchanged.
In some instances, control estimates should take into account changes in
other factors besides emissions. For example, the levels of ozone transported
aloft may change as a result of implementing control programs in areas upwind
of the city. Even though estin ating these changes Is an extremely difficult
problem, guidelines have been developed for deriving potential reductions
(EPA—450/4—80-027). The procedure for incorporating changes concurrent with
emission reductions involves the use of two isopleth diagrams. The first dia-
gram represents the base conditions and is generated exactly as described before.
The base point is found in the standard manner described in the previous para-
graph. However,- the post control point is located on a new diagram reflecting
the future conditions. For example, assume that for the base conditions, the
level of ozone aloft is found to be .08 ppm. The base diagram would be generated
using this value. However, according to EPA-450/4-80-027, the level aloft may
be reduced in the future by as much as .02 ppm. Assuming that the level of
ozone aloft in the future would be .06 ppm, a new diagram would be generated
with all inputs the same as for the base diagram except for this new level of
ozone aloft. The post control point would then be located on this new diagram,
and the VOC emission reduction calculated in the standard fashion. If other
conditions are assumed to change (e.g., precursor transport or gross changes in
post 0800 emissions), all changes should be reflected in the new, or future
case, diagram.-
123
-------
ppiication of Isopleth Diagrams in EKMA
A. Introduction
1. Overview of Discussion
2. Assu ptions Underlying Diagram
3. Use of Diagrams
4. Locating Base Point on Diagram
- 03 Level
- NM0C/NO Ratio
L Estimating Controls Using One Diagram
1. Procedure
2. Example Problems
C. Estimating Controls with Two Diagrams
1. Examples of Conditions Necessitating This Appraoch
2. Procedure
3. Example Problems with Change in 03 Aloft
- Problem Statement
- Procedures for Estimating Future 03 Aloft
- Problem Solution
4. Example Problem with More Than Two Concurrent Changes
L24
-------
NOTES
ESTiMATING CONTROLS
• Isopleth DIaGram As umpt ons
• Esteb ishing Bese Point
— NMOCINO, Ratio
— 0, Peak
• Using Single Diagrams
• Consideration of Changes
Concurrent With Emission
Reductions (e.g., Transport Levels)
$1M4oA D OZO, ‘SOPLE 4 OHOrnOMS
- —
$ .J%n. tc •N 545.S t %I —
-------
NOTES
isoploth Diagram can be used to:
• Estimate reduction in emissions necessary
to reduce peak 0, to 0.12 ppm (e.g.,
Doint B)
• Evaluate effect of specified control
requirements (e.g., Point C)
Key Point
in evaluating controls, only emissions are assumed
to change (dilution, transport, etc. remain
unchanged).
LOCATING
BASE POINT
• Intersection of appropriate
03 isopieth with design
NMOCINO ratio.
126
-------
NOTE 3
• 0 Isopleth corresponds
to 0 peak at sltelday
being modeled.
• NMOCINO ratio established
6.9 a.m. measurements in
urban core. Raflo surrogate
(or Initial conditions.
• NMOCINO. DESIGN RATIO
• Calculate site-specIfic 6-9 a•rn. average.
• Compute site-specific ratios.
• it more than one site, average.
If any individual ratio does not differ
from mean by more than 30%, use
ratio.
If not.
Use median of all ratios for all days
being modeled.
127
-------
NOTES
If NMOC and/or NO. data are not
available, use previous procedure.
Examples of
Calculation
Design 1118
NMOC/NOX
Ratios
GIven: Ratios at five urban core
sites on the day being
modeled are 9.1, 6.2 6.4, 6.5,
and 9.8, respectively.
Solution: First calculate the average ratio
R=L1 +6.2+6.4+6.5+9.8
5
A = 7.6
128
-------
NOTE ..
NOTE:
All the ratios are within ± 30% ol R. i.e.. all
the ratios are between 5.3 and 9.9. Then, the
design ratio is
DR=R=7.5
Given: Assume that only one site is
available for the study.
Assume also that the
NMOC1NOI ratios are
available for five of the
design days. These ratios
are 8.8, 8.6, 15.5, 9.7 and
14.3, respectively.
Solution: Since only one site Is avaflable, the
destçn ratio Is
DR median (8.3, 8.5, 15.5, 9.7, 14.3)
DR=9.7
ESTIMATE CONTROLS
(Single Diagram)
1) Generate base diagram
2) Locate base point
3) Calculate future NO 1 from
emission inventory assumptions
129
-------
NOTES
4) Locate post-control point
5) Compute VOC reduction
( NMOC), — (NMOC) 2
/ 0 R
(N MOC)
EXAMPLE 1
03 Design Value = 0.24
Design NMOC!NO = 8.1
Present Transport = 0.08 ppm
Cttange NO 1 = +10%
City-SPCWC Data:
Latitude 38.6
Loncitude 90.2
Time Zone = 6.0 CD1}
Day = June 5, 19Th
Morning Mixing Height 250 m
AtternOOfl Mixing Height = 1500 m
NMOC Emission Fractions = 0.25, 0.02.
0.02.0.02
NO. Emission Fractions = 0.42, 0.04
Q .04, 0.04.
What reduction in VOC emissions
wUL be needed to reduce 0.24 ppm
to 0.12 ppm?
-------
NOTES
OZIPP IN PUT DATA
TITL.E
EXAMPLE 1 BASE CASE
PLAC 38.6 90.2 6.0 1976. 6. 8
ST. LOUIS
OtLU 250 1500
IRAN 0.06
EMIS — 4.0 0.25 0.62 0.02 0.02
042 0.04 0.04 0.04
SOP 4.0 0.56
BLANK CA 0
.306
Base Point NMOC=2.45
Base Point NO =O..3O6
2.45
131
-------
NOTES
NO
(NOJ, = (NOJ,x(1 —
(NOJ, = 0.306 x (1 + “,,,) = 0.337 ppm
12
.337
.99
(NMOC)f.99
I.
132
-------
NOTES
2.45 0.99 : 60%
- 2.45
EXAMPLE 2
Same conditions as Examp’e 1
FIND —
PredIcted 0, if VOC emissions
reduced 50%.
133
-------
Solution:
1) Base point is the same as Example 1
(NMOC), = 2.45 (NO ), = 0.306
2) Future point is calculated as follows
(NO = (0.306) x (1 + ) = 0.337
(NMOC), (2.45) x (1 — ) 1.23
Step 3: Locate Future Point on
Diagram and Estimate Q 3 .
.12, ,.16
.337 - - -
1.23
03 0.16 ppm
F
I
CHANGES CONCURRENT WITH
EMISSION REDUCTIONS
(Two Diagrams)
Examples:
A) Change in ozone slot t due to upwind
control programs
B) Change! In precursor transport
C) Post-0800 emissions change differently
from initial conditions:
— Gross treatment only
• — Example: rapId growth In outlying
county
1
NOT ES
-------
Methodology: Use two diagrams — one
repr sentlng base conditions and the other
representing luture conditlona.
1) Generate base diagram
2) Locate base point on base diagram
3) Calculate futuie NO. point from
anticipated changes In NO. emfsslons
4) Generate future case diagram
5) Locate post-control point in future case
diagram
6) Compute VOC reduction
- — -- -- --—- -
EXAMPLE 3
Given: Assume the same conditions
as for Example 1 except that
03 aloft will change in the
future because of
implementation of upwind
controls.
-------
NOTES
FIND —
Reduction In VOC emissions
needed to reduce 0.24 ppm peak to
0.12 ppm.
Solution:
Steps 1 through 3 are exactly the same as for
Example 1. Therefore:
(NMOC). = 2.45
(N0J, 0.306
(N0J 1 = 0.337
Step 4: Generate Future DIagram.
First, future O aloft must be estl nated.
I I I
I
.15
1:/VT
Piei.. Gi... Tr....vt. p
• Nonattainment upwind areas 8HC — 10% NO = 0%
• Attainment upwind areas 614C = — 20% NO = 0%
Assume upwind nonattahirfleflt areas. Therefore. 0,
aloft reduced to about 00 from 0.08.
136
-------
STEP 4. GENERATE FUTURE DIAGRAM
‘I’ .. I L . .J T
¶976. 6. 8.
TITLE
EXAMPLE 3 FUTURE
PLAC 38.6 90.2 6.0
ST. LOU IS
DILU 250. 1500.
IRAN 0.06
EMLS 025 0.02
0.42 0.04 0.04
ISOP 0.28
BLANK C .RD
—4.0
0.04
2.0
0.02 0.02 0.02
.12
Step 5: Locate Post Control Point
.337
1.08
(NMOC) 7 = 108
STEP 6. COMPUTE VOC REDUCTION
%R =2.45 - 1.08 56%
2.45
EXAMPLE 4
More Than Two Concurrent Changes
Pn,blem Repeat Example 3 except assume
that VOC and NO emissions for the
last 3 hours will triple in the future.
1.37
-------
NOTS
STEPS 1 THROUGH 3 REMAIN THE SAME
Thai Is: Base Point
(NMOC}, = 2.45
(NOJ, 0.306
(NOJ, 0.337
Fulu e 03 alort = 0.06
However, emission lractions br hours 2
through 4 will now increase by a lactor b 3.
STEP 4. GENERATE FUTURE DIAGRAM
TITLE
EXAM PLE k FUTURE
PLAC 38.6 90.2 6.0 1976. 6.
8.
ST. LOUIS
DILU 250.
TRAN
EMIS -.4.0
042 0.12
ISOP 4.0
1500.
0.06
0.25
0.12
0.56
0.05 0.05 0.05
0.12
BLANK CARD
.12
Step 5: Locate Post Contro’ Point
.337
(NMOC) 2 = 1.10
1.10
STEP 6. COMPUTE VOC REDUCTION
%R =.? —_1c5%
2.45
-------
3.8 Determining the Overall SIP Control Requirem nt
By applying the EKMA technique with city-specific diagrams, controls needed
to reduce peak ozone levels to 0.12 ppm can be calculated. From these results,
the control level which will insure achievement of the NAAQS should be selected.
The choice of control level must be made in accordance with the statistical for
of the standard.
As noted earlier, controls are calculated for a minimum of five high ozone
days for each site experiencing ozone peaks above 0.12 ppm. Normally, this
would require application of the 0ZIPP/EKI A technique at least five times for
each appropriate site/day combination (i.e., at least five base case diagrams
for each site). In practice, however, considerable duplication in high ozone
days is likely for many sites in a monitoring network. When this occurs, the
same isopleth diagram (or set of isopleths) can usually be used to make control
estimates for a number of sites. The only exception to this rule occurs when
significantly different post 0800 emissions are found for trajectories leading
to different monitoring sites and these differences.slgnificantly affect posi-
tioning of the isopleths on the diagram. Thus, the number of isopleth diagrams
to be generated may be reduced by careful review of the highest days at all
sites. Use of the CALCULATE option can facilitate appropriate sensitivity
tests. In any event, control levels must be estimated for the ozone levels
found at each site on .the five days with the highest peaks (i.e., peaks greater
than 0.12 ppm).
The NAAQS for ozone is site specific, requiring that the daily maximum
hourly ozone concentration must not exceed 0.12 ppm more than once per year at
each site. A site specific control level is chosen such that the frequency
distribution of ozone levels at that site occurring after implementation would
not violate the standard. If a three year data base were used, this would be
the fourth highest control estimate; for a two year data base, it would be the
third highest; and for only one year of data it would be the second highest
control level. By choosing these particular levels of control, only one peak
level above 0.12 ppm would be predicted for each site. The final step in deter-
mining the SIP control level is selecting the highest site specific control
estimate. This level of control is necessary to insure that the t’ AAQS is achieved
at all r onitoring sites.
139
-------
DETERMINE THE OVERALL SIRCONTROL REQrnRENENT
A. Overview
B. Exaniple 1
C. Ex mp1e 2
140
-------
NOT s
Estimates of VOC reductions
needed to reduce five highest
peaks at each site to 12 ppm
.12 ppm
1\J\MJ\A
&
• Control Selected far Each Site:
Years of Choice of
Data Control
1 2nd
2 3rd
3 4th
• SIP central equals highest of sIte.spedflC
controls.
141
-------
NOTES
Example 1
One Year of Data
Rank of Site I Site 2
Day Date 07 %R Date 0, R%
1 1011 0.24 60 6/8 0.22 58
2 618 0.18 57 8/25 0.19 5.1
3 1012 0.15 45 1012 0.18 55
4 8/13 0.15 39 8/25 0.18 51
5 8/21 0.14 39 7126 0.17 g
SIP Control Pe uiremenI 57%
Example 2
Multiple Years of Data
Menk of SIte 1 Site 2
Day Date 0, %R Date 0, %R
715179 014 57 8/25179 0.26 65
2 1011150 0.24 60 7113179 0.24 60
3 617178 0.23 55 6/8150 0 22 58
• &7(79 0.22 50 9114(79 0.21 53
79 0.21 51 8125180 0.19 - Assume 3 years data
SIP Control Requhement a 58% • M 2 yezrl data
142
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3.9 Efforts to Validate EKMA
The primary question concerning validation of city-specific EKMA is, “how
well does the model estimate control requirements needed to attain the ozone
NAAQS?” This question cannot be answered unequivocally, because there is nc
observed or “right” answer against which to compare model performance. Hence,
four less direct approaches have been used to validate EKMA.
Approach 1. Comparison with Historical Trends
This approach is to ëompare the observed impact of implemented
controls with that which would have been predicted had city-specific EI A been
applied prior to the implementation of controls. The approach has been tried Th
Los Angeles using air quality and emissions data collected between 1963 and
1978. Comparisons suggest that about 70% of the predictions agree with obser-
vations within a rather narrow band of uncertainty. If uncertainty in NMOCJNO
ratios prevailing in the early 1960’s is considered, all observations and pre_X
dictions agree. However, in the latter case uncertainty is rather large.
Approach 2. Comparison with Predictions Obtained with Validated
Sophisticated Models
This approach compares the impact of specified reductions in
precursor levels using city—specific EP i4A with that obtained with validated
sophisticated photochemical dispersion models. Agreement suggests that the
control estimates obtained with city-specific EKMA are about as good as is
possible with state-of—the-art models. Such comparisons have been performed in
St. Louis, Los Angeles, San Francisco, Sacramento, and Tulsa using several
different dispersion models. Of the 33 comparisons available, 26 agreed within
10%. If the major concern is that city-specific EKMA may prescribe more controls
E n are necessary to attain the NAAQS, these comparisons suggest that chances
of prescribing a control requirement that is more than 10% too severe is only
about one in nine.
Approach 3 is to compare predicted peak ozone and corresponding ambient
precursor estimates with observed ambient air quality. Such an approach requires
a more detailed data base than is likely to be available for use with city-
specific EKMA. Consequently, it is a less direct test of city-specific EKMA as
it is used in SIPs. However, if it can be demonstrated that the OZIPP model
uncerlying EKMA works well in predicting absolute levels of ozone with a detai1ed
data base, the credibility of city—specific EKMA is enhanced. Approach 3 has
been applied in St. Louis, Los Angeles and San Francisco. in these tests, the
OZIPP model was found to systematically underpredict peak observed ozone. It
is apparent that surface wind data provide an inadequate descriptor of wind
flow for some of the days tested. Primarily for this reason, estimates agreed
with observations within 30% on only 10 of 16 occasions. The inconsistent ap-
plicability of surface wind data in these tests suggests that more complete
wind information than anticipated in the November 14, 1979 Federal Register
notice is needed if EKMA is to be applied as a simplified trajectory model
(i.e., Level II analysis).
143
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Approach 4 is to see whether city-specific EK 1A is a good indicator of
a city’s maximum ozone forming potential. As described above, sometimes it is
very difficult to estImate a trajectory from surface data. The trajectory
assumed in city—specific EKMA should tend to maximize the peak ozone predicted
by the model. In addition, simulations with photochemical grid models often
suggest that the maximum hourly ozone concentraticn does not occur at any of a
limited number of monitoring sites. Hence, if the other inputs to OZIPP are
accurate and the model is valid, it should act as an upper limit to observed
values.
Although this test has been applied for several cities with the standard
EK t isopleths (Level IV analysis), Approach 4 has only been tried in St. Louis
for city-specific isopleths. The same ten cases tested in Approach 3 have also
been tried with Approach 4. The results indicate that the model provides
unbiased predictions of observed peaks, with eight of ten estimates agreeing
within +30% of the observations.
144
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EKMA Validation Efforts -- Outline
A. Identify Key Questions in Evaluating 4odel Performance
— how well does a model predict control requirements needed to attain the
ozone NAAQS?
B. Problems
- there are no observations or “right” answers against which to compare
predictions -
— non-linearity of ozone
— therefore, cannot present an unequivocal demonstration that model works.
C. Approaches for Validating EK?
1. Approach 1: Comparison with Historical Trends
(a) Procedure:
(11 - review ambient precursor (or emlssions and ozone data
from a period. prior to Initiation of major controls;
(2J — note changes in.ambient precursors or emissions;
( .3} — use EKMA isopleths to estimate corresponding changes in
ozone concentrations;
(41.. — compare estimated changes with observed changes in ozone.
( .b) Strengths and Weaknesses
(l)_— intuitively-most appealing -— comes closest to answering
key questions concerning model performance;
(.21 — only LA has sufficient data to apply the approach;
(.3 1 much uncertainty about key parameters in base period
(e.g., NMOC/NO ratio in early sixties, transported ozone,
mixing heights ;
(.41 — relatively small changes in precursor levels.
2. Approach 2: Comparison of Changes In Ozone Predicted by E J1A versus
Those Predicted with Validated Sophisticated Models
(a) Procedure:
( IL— simulate a limited number of days for which sufficient
data exist using a “Level I” model;
(21 — satisfy oneself that the sophisticated model agrees satis-
factorily with observations;
(31 — simulate a contro’ strategy with the sophisticated model;
145
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(4) - simulate the same strategy with EKMA and note how closely
predicted changes in ozone agree with those in step (3).
(b) Strengths and Weaknesses
(1) - enables one to assess accuracy of predicted in
03 concentrations;
(2) — can examine under range of changes than possible with
trend data;
(3) — more flexible than Approach 1;
(4) - method assumes sophisticated model predicts changes in
ozone concentrations accurately -- non-linearity;
(5) - many of the data required by the sophisticated model may
be suspect;
(6) — laborious and requires large data base.
3. Approach 3: Comparison of Predicted Peak Ozone and Corresponding
Ambient Precursor Estimates with Ambient Air Quality Data
(a) Procedure — - the same as is used for sophisticated model
(1) - select a limited number of days with detailed meteoro-
logical and air quality data;
(2) — simulate each day as accurately as possible within the
limits imposed by the model (I.e., use a Level U analysis);
(3) - compare predictions with observations.
(b) Strengths and Weaknesses
(1) — stringent test utilizing an intense data base;
(2) — similar to tests of sophisticated models;
(3) — does not address key question directly;
(4) — is not the way in which city-specific EKMA is likely to
be applied;
(5) — laborious and data intensive.
4. Approach 4: Use of City-Specific EKMA as an Indicator of a City’s
Maximum Ozone Forming Potential
(a) Rationale - - becuase of the assumed trajectory and limited Air
Quality Monitoring Network, city-specific EKMA should tend to maximize
a city’s predicted ir pact on peak ozone. However, if predictions
are near or only slightly above observations, this suggests simpli—
fications invoked may not be critical.
(b) Procedures
146
-------
( .1). — predict peak ozone concentrations using OZIPP as recoIrrnend( d
in city—specific EKMA;
(.21 - plot observed versus estimated peak ozone;
(.31 - for most points on scatterplot, predictions should be c1os
to or above observations.
(c) Strengths and Weaknesses
(11 — reflects use of OZIPP as applied in city-specific EKMA;
(21 — does not rely soiruch on difficult-to—obtain data;
- does not directly address the key question concerning per-
formance of city-specific EKMA;
(.41 — less rigorous test than Approach 3.
D. Extent of Comparisons
1. Historical Trends: 1 city —— Los Angeles 1963—78.
2. Cot .parlson with Sophisticated ‘Models: 4 cities: St. Louis, Los Angeles,
San Francisco and Sacrai iento. Sophisticated models include Airshed,
LI? Q and SA l Trajectory Yodel.
3. Comparison with Air Quality Data Using Level II EKMA
10 comparisons in St. Louis, 3 comparisons In Los Angeles, 1 cornpari—
son in San Francisco.
4. Using EK?iA as an Indicator of Ozone-Forming Potential
10 observations in I city: St. Louis
E. Results
1. Historical Trends
(a) trend parameters used (maximum daily 03 and 95th percentile
max. daily 03)
(b} illustrate graphical output and show why each comparison is
independent
Cc) cite sources of shown uncertainty band as well as other sources
of uncertainty
— running 3 year averages
- spatial differences in precursors
— uncertainties in t i7 10C/N0 ratio
— lack of constant ’meteorology
147
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_d). Of 16 ayailabie comparisons, approximately 70% agreed with shown
bands of uncertainty for both 95th percentile and maximun ozone
(e) Within all uncertainties, all comparisons agree. However, these
uncertaintjes can be large.
2. Comparisons with Sophisticated Models
(a) explain types of strategies investigated. note that 33 cornpari-
sons have been made
Lb)I show ampie from St. Louis
(c i show and explain distribution diagram
- essentially, city—specific EKJ t tends to provide unbiased
estimates of sophisticated model estimates
(d) emphasize left-hand portion of diagram -— this represents likeli-
hood of prescribing controls which are too stringent. Results
suggest a likelihood of only about one chance in six of o-ver-
predicting needed controls by more than 10%.
3. Comparison with Air Quality Data using Level II EKNA
Cal briefly describe how predictions were made and the data base used
in making the comparison
(b). present scatter diagram and note correspondence of better pre-
dictions with days having consisient definition of wind fields.
Yiention results of sensitivity tests to kinetics mechanism.
4. Use of City—Specific EKJ A as an Indicator of Maximum Ozone-Forming
Potential
(a) note that predictions of absolute ozone concentrations were made
following the procedures outlined in the EKMA guidance
(b) present and describe scatter diagram of results
F. Surmiary
1. Ko approach provides irrefutable evidence that city-specific EKMA
works.
2. Comparison with historical trends suggests agreement, but only within
a range of uncertainty.
3. Generally similar results are obtained with E}(MA and sophisticated
models.
148
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4. Leve U EKMA tends to underpredlct obserye4 pealc Q. 3 in St 1 QUiS,
with worst predictions tendingto occur ondays with the jnostarnbiguous
wind fields.
5. City-specific EKMA tends to perform better than Level II EKM In esti-
mating peak ozone concentrations.
149
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NOTES
APPROACHES USED
TO VALIDATE EKMA
COMP RE...
W)T 4 }-HSTORICAL TRENDS
dIT SOPHISTICATED MODELS
WiTH A Q USING XTENS VE
DAi BASE
WITH A.C. USING LESS
EXTENSIVE DATA BASE
EFFOFTS TO
VALIDATE
EKMA
How well does model estimate
controls needed to attain N&AQS?
Problems in Eva uat3ng Model Per orrfl3rOe
• No “right” answet lot comparison
• Nonlinearity of ozone
-- - .-- c - -.--
-------
COMPARE WITH TRENDS
NOTE
• Review precursor data before controls
• Note change In precursors
• Predict change In 0,
• Predicted vs. observed
changes In 0
COMPARE WITH TRENDS
Strengths
• tntustively
appea ling.
• Cores close to
ac ressing key
ques or .
Weaknesses
• Only LA has
sufficient data.
• Much Uncertainty
— exists.
• Relatively small
changes observed.
OM PARE W 1TH MODEL3
• Simulate several days with
sophisticated models
• Ensure model “validates” adequately
• Simtilate control strategies with model
and note change In 0,
• Simulate with EKMA and compare
COMPARE WITH MODELS
Weaknesses
Strengths
• Assesses accuracy
of predicted
changes In ozone.
• Can examine wider
range of changes
than Is possible
with trend data.
• More flexible than
Approach 1.
• Assumes changes
predicted with
sophisticated model
are accurate
• Data required by
sophisticated model
may be suspect.
• Resource-intensive.
151
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CCAPARE WITH A,Q 1 USING
LEVEL III DATA
Strengths
• Reflects use of
OZIPP as applied
in city-specific
E K MA.
• No data-intensive.
Weaknesses
• Does not directly
address key
question.
• Less rigorous than
Appr: ach 3.
COMPARE
WITH AQ
DATA
NOTES
COMPARE WITH AIR QUALITY DATA
Strengths
• Stringent test with
detailed data base.
• Similar to validation
exercises with
sophisticated
models.
Weaknesses
• Does not directly
address key
question.
• yot the way city-
specific is likely to
be applied.
• Resc’urce-h,(ensive.
cOMPARE WITH A 1 0 1 USING
LEVEL III DATA
• Predict peak ozone with OZIPP.
• Plot observed vs. predicted ozone on
scatter diagram.
• Most predictions should be near or above
observations.
•
-r
-------
NOTrS
EXTENT OF EKMA EVALUATIONS
City App o.ch I Approach 2 App *ch 3 App oa h 4
SLLou a * a
Los Ançeles * a *
San FrandSCO a a
Sacr amento a
Results of Approach I —
Trends Parameters
• Maximum daily 03 concentratiOn
• 95th percentile daily maximum
0 concentratiOn
C
E
0.
z
0
I-
z
U i
0
z
0
0
Ui
z
0
p.J
0
?iCTUAL
OZONE
TRENDS
RESULTS OF THE VAUDATION STUDIES
PREDICTED
OZONE TRENDS
AZUSA
E5TH PERCENTILE OF DAILY MAXIMUM OZONE
PI%EDItTED TRENDS EASED ON EM SSWN TRENDS
49 A: SiziisticaI error in vnbianl ozone trends
a: Error in precurlor trend da%3
—
i i , T i T i I 1 1 1 1_I
YEAR
Sources of Uncertainty in
Comparsion of EKMA With Trends
• Smoothed averages
• Spatial differences in precursors
• NMOC!N0 1 ratios in 1960’s
• Unknown meteorological variations
-------
Using Ambient
Precursor Trends
Using Emission Trends
Trend
95th
Percentile
Includin Uncertair. y in
n NMOCINO ratio 16/16
Parameters
Maximum
Ozone
* Numerator Cases of agreement within uncertainty bounds
- - Denorninato : Number of comparisons
I .
r
I ;
L,
4 j H -,
: TTT1 N H
Summary of Los Ange es Trend Comparisons’
LI
NOTES
12116
10/16
1 .120
13/20
20/20
Exarnp e Set of Comparisons Between
EKMA and Another Mode’ for St. Louis
June 7, 1976
°, NMOC
%A NO
Airshe
(Model
% O
(.EKMA
Difference in
Sensitivity
(5KM A-Airsr ed)
+67 +17 —17 —42 —70 0—42 —42
0 0 0 0 0+20+20—20
+5 +3 —7—25—45 +1—22 —15
+15 +5 —6—21—S3 +3—25—21
10 2 —1 —4 4 2 —5 2
l er’ s 5’ e’ resse 2
0
.4
I -
-25 — II I II 25 3•
V .. P D1CC I,’ CK0 e.VD 0 .ICS
oIsTs:,.— c, c sE—ttS I C(I c y—spC::F c LOP I0 so
07. ’.ER
-------
PRo ILrry OF UNDERESTIMATING
IMPACT OF CONTROLS
SIZE OF
UNDERESTIMATE
LIKELIHoOD
20%
ic
31100
3127
319
]JL
- —3 %
,. o comparing
U EKMA witti ,“
air uaii(y
S
S
S.
S
S
-S
- 4
£
A
• . L
A LA.
I SF.
O9URVED MAXIMUM OZONE. pp
OBSEAVED MAXIMUM OZONE, ppm
155
-------
NOTES
Summary of Results
• Each approach used to validate EKMA
has flaws.
Summary of Results
• Each approach used to validate EKMA
has flaws.
• EKMA agrees with trends, but within a
fairly large range of uncertainty.
- - —-
Summary of Results
• Each approach used to validate EKMA
has flaws.
• EKMA agrees with trends, but within a
fairly large range of uncertainty.
• Generally similar results are obtained with
sophisticated models.
— __ & _ ---- -- — -- - -
Summary of Results
• Each approach used to validate EKMA
has flaws.
• EKMA agrees with trends, but within a
fairly large range of uncertainty.
• Generally similar results are obtained with
sophisticated models.
• Level 1! EKMA tends to underpredict
observed peak ozone.
-------
Summary al Results
• Each approach used to validate EKMA has
flaws.
• EKMA agrees with trends, but within a
fairly large range of uncertainty.
• Generally similar results are obtained with
sophisticated models.
• Level I I EKMA tends to underpredict
observed peak ozone.
• City•specific EKMA appears to perform
better than Level I I EKMA in predicting
peak ozone.
157
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3.10 Modeling Related Issues
This page may be used for notes concerning issues which arise during
this session of the workshop.
158
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4.0 CO ?4ONLY USED TERMS AND ACRONYMS
BACT Best Available Control Technology
City—Specific E (MA Also known as “Level III analysis.” The OZIPP computer
model is used to generate ozone isopleths for use in
EKMA. The isopleths reflect locally applicable meteo-
rological data, diurnal emission patterns and trans-
ported ozone and precursors.
CTG Control Techniques Guidelines
EKM Empirical Kinetics Modeling Approach. This is a
procedure in which an ozone isopleth diagram is used
to estimate reductions in NMOC and/or NO needed to
attain the ozone NAAQS.
I/’M Inspection and 1 aintenance
Level I Analysis Use of a validated photochemical atmospheric dispersion
model.
Level II .Analysis This has also been called a “simplified trajectory
model.” In this analysis, specific trajectories are
derived from an extensive array of wind data. Specific
air quality, emissions and meteorological inputs
encountered by an air parcel as it follows individual
trajectories, are used to derive the appropriate ozone
isopleths utilized In the EKMA procedure for each
- trajectory.
NA.AQS National Ambient Air Quality Standard. The NAAQS for
oZone is discussed in Section 3.3.
r*ioc All organic compounds i asured in the atmosphere with
the exception of methane.
NO Oxides cf Nitrogen —— includes nitric oxide (NO) and
X nitrogen dioxide (NO 2 ). The NMOC/NO ratio is an
Important determinant of how much co trols will be
needed to attain the National Ambient Air Quality
Standard for Ozone.
OZIPP Ozone Isopleth Plotting Package. This Is a computer
model which generates the ozone isopleths used in the
EKMA procedure.
RACT Reasonable Available Control Technology
RFP Reasonable Further Progress
159
-------
State Implementation Plan
Standard EKMA Also known as ‘ Level 1V analysis.H Utilizes a published
set of isopleth curves in applying the EKMA procedure.
Volatile Organic Compounds. An abbreviation for the
organic emissions important in the formation of ozone.
160
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5.0 u.s. EPA POLICY ON 1982 SIP’S FOR OZONE AND CARBON MONOXIDE AND
ADMINISTRATOR’S SIP CRITERIA MEMO
161
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—
-a
-
__ n _ —
— —
Thursday
January 22,; 1981
-
—
— - -‘--
— — —
- I-
—
- —
Part .VI•.
— — —
__ —
•
—
—
—
— —
—
162
EnvirOn méntäl
Protection Agency
State Implementation PIans Approval of
1 82 Ozone and Carbon Monoxide Plan
Revisions for Areas Needing an
Attainment Date .Extension; and
Approved Ozone Modeling Techniques;
Final PoI cy and Proposed Rulemaking
-------
Federal Register f VoL’ 46, No. 14 1 Thursday. lanuary 22. 1981 / Rules and Regulations
- —
EHVtRONMENTAL PROTECTioN Carolina 27711, telephone (919) 541— specific date after 1987. The policy now
AGENCY 5497. . - . - makes more explicit, however. EPA ’s -
Transpo tion policy contact - intent t care lly evaluate the -
40 CFR Part 51 Gary C. Hawthorn. once ,f :- effectiveness of measures in SIPs for all
Transportation and Landiise Policy” - area and ensure that the most effective
(A—FRI .. 1722-8] (ANR—445), Environmental Protection - measures have been adequately
Agency. 401 M Street. SW., Washington. considered in any area that does not
State Implementation Plans Approval D.C. 20460, telephone (202) 75s ci . demonstrate attainment by 1987.
of 1982 Ozone and Carbon Monoxide Vehicle inspection and maintenance EPA recognized in the proposal that
Plan Revisions for Areas Needing a contact Mr. Donald white, i int . provisions of the Clean Air Act
Attainment Date Exter.slon Vehicle Emission Test Lab, may not allow approval of a SIP that
AGEPICT Environmental Protection EnvL-cumental Protection provides for attainment of NAAQSs -
Plymouth toad. Ann Arbor, J i - after 1987 and that action by the -
48105. telephone (313) 668-4350. - - Congress may be necessary. EPA
a noic Final policy .
considers any request to the Congress
SUPPt.EMEKTARY NFOR AflOP4 for additional delay of att inr ent
sw Awd Provisions of the 1977 Clean the 60-day comment period for the deadlines to be a serious step and one
Air Act Amendments require states that proposed PolicY EPA received comm after it
have received an extension of the from 28 o r -ations and rnd1V dUals. — clear that all available and
atainment date for a national ambient - Comnzeuts from over 30 other - - - implementable control measures will be
a quality standard (I’L AQS) for ozone organizations and individuals were
o: carbon monoxide beyond 1922 received after the close of the comment : adopted. -
submit a state -implementation plan (SIP) - period. EPA carefully considered all the Providing Adequate Tune for SIP
evson by July 1. 1922. This policy comments and made several-changes to - Adoption :
descnbes the criteria that the the policy. Major issues raised by those -. ‘The proposed policy reiterated and
E vL-onmeotal Protection Agency (EPA) submitting comments EPA’s responses, - expanded upon the Clean Air Act
to vi th 1982 5 and any resultant changes in the policy -r qufrements that a fully adopted,
su:.mittals and also updates and are summarlze&below. A more detailed - i any enforceable SIP revision must be
s :;ieents the Atrator s summary of comments and EPA - submitted to EPA by July 1. 19a2.-
Fe:ruaxy 24,1978 andum. responses are included in Docket No.A— Several state and local agencies
“C.-iterma for Approval of i - SIP -. - 79-43 and available at EPA regional responsible for SIP development
Re sicos,” (43 FR 21673) and - -ur .. ccmmented that they would be unable
subsequent guidance. - - - - - to ensure the adoption and submittal of
EPA proposed this pølicy on - - III required measures by July 198Z
30, 195Q (45 p . In the proposed policy EPA particularly If EPA guidance mentioned
unced * 60-day recognized that a few la e urban areas in the proposed policy is not available
cn ’. t. The comments received on - -. - With V a7 $CV OZOne e.fld CO - early in 1981. EPA recognizes that
major Issues. EPA’s - . oxide problems may not be able to meeting the July deadline may be a - -
comments, and the - - atain NAAQSS by December ‘- - problem for some areas, but is - -
p posed policy are - ‘ ired below, ; the deadline satin the Clean -Air Act - constrained by the Clean Air Act from
A more detailed sr ” - ’ ’y of comments - EPA proposed that such areas should tgranting any time extensions.. - - - -
and the EPA responses have - submit SIP revisrons by July 1. 1 B2 that-;: EPA will continue the practice of
included i: ocket No. A—79-43 and are dofl3trBte at’. in ent as soon as -• granting conditional SIP approval
also available for review at EPA - pos ie after 1987 using additionai. - followed in acting on the plan revisions
regional offices. -‘ - -. - - - more effective measures beyond those due in 1979.115 SiP revision is in - -
___ required in other areas. - - substantial compliance with Pant D of -
DATE$ Final PolicY effective J ’ Y - - Some public and private org ’ tions the Clean Air Act and the state provides
-. - - - - - - -. commenting on this portion of the - — - - assurances that remaining minor -
i.oo ess Docket No. A79-43, - - proposal supported the course cf action daficiences will be remedied within a
conts g material relevant ° outlined by EPA; Others believed. - - short time. EPA may approve the plan
action, Is located at the EPA Central however, that such a policy would - with conditions that corrective actions
Docket Section. West Tower Lobby, encourage some areas to slow or - - will be completed according to a
Gallery 1,401 M Str L -. - abandon their air quality dean-up - - specthed schedule. For example, if
Washington. D.C 20460. The docket 37 efforts. For example. one state missing regulations applying RACT to -
be inspected between 8:00 a_m. and 400 - environmental agency commented that - - - required sources constitutes a minor
p.m. on weekdays and a reasonable fee granting any delay was inappropriate as - deficiency in the SIP and the state -
may be charged for coprng. A 7 federal policy and that asking the public - commits to a schedule for submitting -
of the comments received on the - to accept additional years of poor-air those regulations, then EPA may -
proposed policy and EPA responses to quality was unacceptable. Several state - conditionally approve the SIP.
the comments are also availabl, for and local agencies stated they-believed -: The proposed po 11 cy included the -
review at the EPA regional office - that the EPA A nir ctrator would be - requirement that states must adopt
locations listed In Appendix E . exceeding his authority under the Clea i - - regulations applying reasonably
FOR FURTHER INFORMATION CQNTACT Air Act if he accepted a SIP that did not - available control technology (RACT) to
Additional information about the policy - - demonstrate attainment by 1987.-- - all sources of volatile organic
is available from the foliowingi General The final EPA policy still permits the córzzpounds (VOCs) covered by a contr-o
- policy contact Mr. Johnnle L Pearson, submission from a few urban areas with technique guideline (CTG) and to all
Standards Implementation ranch, - severe ozone andcarbon monoxide - - -- other major sources of VOCs. EPA also
Environmental Protection Agency (MD-. problems of SIPs that provide for - ‘announced its intent to issue additional -
15). Research Triangle Park. North - expeditious att h rnent of NAAQSS by a CTGs during 1981. A number of agencie
- 163 -
-------
I .UiJ
- ‘‘ ( V Ji. & V. .L * £JLUIbUdY, JdL U L)’ L, I O ( A u.ie dJlLl 1W u uun
responsible for developing SIPS
commented that they do not have
sufficient resources to finalize
regulations for both CTG arid non-CTG
source categories. Some of the agencies
also indicated that the time necessary to
satisfy state and local procedural
requirements makes it unlikely that the
required regulations v .111 be fully
adopted by July 1982. A state
environmeatal agency, for example.
stated that although the agency agrees
in principle with the requirements for -
regula ng both C G and non-CTG
source categories, the agency does not -•
have adequate staff and financial
resources to complete the necessary
technical analysis and rulemaking
activities. In addition, the requments
of the state a rr ii, ctrative review.
• process cannot be met by july 1982,’
even if rulemaidng is limited only to
CTG sources. A local environmental
agency commented that it may not be
pcssible to submit regulations for source
categories covered by CFGs issued late
in i9si. In order for the regulations to be
Included in the July i 8z submittal, the
local agency must provide the
regulations to the state by the end of - .
igsi. . . . -: . - - -
To help ensure thatstates have
adequate opportuzxityto meet the July
1982 deadline, EPA will issue the new.
CTGs as early as possible hi 1981. The.
CTGsare in preparation and will be.. - -
available in draft form between January’
andM y 1981. The final CTGs will be
published between July and October
1981 ,11 state and local ag ncies begin
now to develop the necessary data and -
work with the draft CTGs, they should.
be able to complete development of -.. -.
regulations by July1982. : :: . -
Providing for the lmpl m ntation of I/M
Programs
Mprogram . but should evaluate the
program as a whole: that the KIM
guidance should be promulgated through
rulemaking to allow review and
comment by Interested parties; and that
the intent of requiring thei/M public V... -
awareness plan in the 1982 SIP is -
unclear. - -
A state agency also questioned .- - -
whether additional emission reductions
from other source categories could be
used to offset any shortfall from K/M.
rather than making the KIM program V
more stririgent That agency also ‘ V V
questioned whether. is a state with a
post-1978 atta rnr ent date and with
legislative authority which needed to be
changed before KIM effectiveness cot 4
be increased, commitments to obtain.
_____ needed legislative changes were
adequate for the 1982 SIP, rather than -
having the legislative chariges
themselves before July1982.’ ‘ -
EPA’s basic requirements for K/M
programs are included in a widely
dis ibuted July 17.1978 policy . -
memorand Subsequent clarifications -
to that policy have deflnedthefactors-
involved in desiring IIM program-
elements and provided Information on
designing programs wE lch optimize
technical and cost effecth,eness.
Additional information along these lines
provided.. V• V VV . ‘
The July 17, 1973 policy memorandum -•
wiflbetheprimarybasisfor V
_______ I !‘.J .— ——-o
: VV —-
the 1982 SI? process. Thi final policy
has been revised to reflect this. EPA
agrees that the policy should contai
provisions for those states that are
meeting an ae proved scheduls but will
not be able tomake.a completé-l/M. - .:
submission by July 1982 . Appropriate ‘V
____ changes have been Incorporated into theV
final policy. EPAaISO agrees that the 1/
M pro m st be evaluated as a : V V
The proposed policy included the . . whole, rather than element by element.
requirement that states submit, by July.’ EPA does not believe that KIM policy
1982. the rules arid regulations for and guidance needs to be promulgated
vehicle inspection and maintenance (1/ through rulemaking, but does agree that
M) programs. -as well as documentation review and comment by interested
of 10 other critical I/M program parties are important The appropriate
elements. The proposed policy stated place far rclemaldng for IJM is the SIP
that EPA would update I/M guidance for - review arid approval process. EPA feels
determining KIM program adequacy. - - that the sta tea and other Interested
Sortie state and local agencies parties have aiwlys been extensively
commented that guidance not available involved in the policy and guidance
for their use in pl ir ’g and development process. EPA will continue’ -
implementing K/M program.s should not, to seek such review -and comment
be used to evaluate the -I/M portion of EPA feels that the l/M public :‘: -
the 1982 SIP. Many of these agencies . awareness plan is critical for the --
were concemed that updated guidance successful implementation of an I/M- . . -.
wouid include new requirements which program and that It must be included as -
could adversely affect I/M activities part of the 1982 SIP. EPA recognizes. - - ‘
already in progress and which could not - however, that much of the public: - - - - ‘
be completed by July 1. 1982. Other awareness activity should generally
agencies commented that EPA should - - - have been completed before the 1982
not evaluate individual elements of an 1/ SIP deadline and will work with the-
states in developing and implementing
their public awareness plans. Guidance
is available on what should be included
in a good public awareness pran.
If an KIM programs fails to achieve the
requisite emission reduction.’ then the -
program will have to be modified to - -
obtain that reduction. Additional -
emission reductions from other sâurce
categories cannot be used to
compensate for a shortfall from I/M. -
Because section 172(c) of the Act
requires all measures in the 1982 SIP to -
be legally enforceable, any further - -
legislative authority will have to be . -
obtained before the 1982 .SIP is -
submitted. A commitment to obtain such
authority will not be sufficient for the -
1982 STh’. - - ..- : _ :. .--- - - -
Making Commitments to laplément -
Transportation Measures - - . . -- - - -
- The proposed policy required that the
1982 SIP submittal include coitinents
b’y state and local governments to - -
implement the necessary transportation
measures. The documentation of the - V
commitment must include identification
of costs, funding sources. and ...: .. ---
responsibilities ofstate and local
agencies and officials. Several state and -
local agencies commenting on thern - . •. -
proposal expressed concern about -
in a k i n g commitments to transpoi-tation
improvement projects that are only in
the early stages of pl nn ng and have.’-
not been included in state and local
budgets or been approved for federal -
_____ - - -
The definition of implementation . ‘ -
commitments contained in Appendix C -
hasbeen expanded toc larify the form of
the commitment for projects that are.
progressing towards implementation.-:’
but hav e not received budget approvals;
Essentially, the implementation . ‘- -
commitment for these projects or --
measures should be a schedule of the . : -
major steps required to advance the-
project through the pisiining and
progr r ming processes. This schedule
should also contain an identification of
the responsible agencies that must take
significant actions to Implement the-
ea sure. An Illustration of such a - -
schedule is also contained in Appendix -
C. - -:
If a particular measure cannot be -. -
- implemented because the necessary.
funds cannot be obtained from the - -
funding source identi ed in the schedule
and if the SIP pli rrning agencies can -
demonstrate compliance with the
provisions of the Clean Air Act requiring
priority teatment for projects important -
for improved air quality and basic -
transportation needs, then the measure
may justifiably be delayed. If this does -
occur, another substitute measure may
164
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j rnursaay, ] tuary 22. 1981 I Rules and Regulations
be needed for replacement to ensure
that NAAQSs are attained (see the
section on contingency plans).
Developing Monitoring and Contingency
Plans for Transportation Measures
The proposed policy Included
requirements for developing a
monitoring plan for regularly assessing
the effectiveness of transportation
measures and a contingency plan for
implementing additional transportation
measures if forecasted emission
reductions do n t occur. A number of
state and local governments commented
that they do not have su dent time and
resources to develop monitoring and
contingency plans at the same time that
they are developing the measures to -
meet the emission reduction targets for
tansportation. Some of those - -
commenting interpreted the monitoring -
requirements as being primarily for air - .
quality mouitcrin$ -•
In the final policy the monitoring plan
requirements emphasize the use of
r ethoas that rely on suogate measmes
and on data already being coflected for -
other purposes. The monitoring plan
need ot include ed4itinaal air quality. -
monitoring. -
The requirements far a contingency
plan have been revised to require a
listing only of transportation aasures
and projects that, becaus. of their
potentially adverse effect an air quality..
wi1fl e de’ayed while aSP1sben
revised. The projects will be delayed
when the Ad litrator of EPA flnds-
that a SIP ts inadequate to attain ozone
or carbon mono de NAAQS3 and calls
for a SIP revision mder section 110Cc) of
the Clean Air Act. EPA has also adopted
the suggestion of a local transportation -.
pl th g agency and is req ng that
the SIP include a dssc i;tiou of the
process to be used to develop ant -.
implement additional transportation
control measures when they axe -
determined necessary.
Establishing Emission Reduction Targets
The proposed policy required state -
and local aMciels to reach agreement on
the emission reductions necessary to.
attain NAAQSS. the extent to which the
emission reductions will come from
controls on iobfle orstationary sources.
and the responsibilities far
implementation of the measures. Several
comments were received noting the.
difficulties in deter ’th g emission
reduction targets for meeting the ozone
NAAQS because of the form of the
standard, the characteristics of the
Empirical Kinetic Mod !!r1 Approach
(EIQIU4 model, and the effects of
pollutant transport. Other comments
reflected confusion about where In the
SIP development process the as a result of measures in the 1979 -
identification of targets would occur. submittaL -
An August 1. 1978 EPA policy The final policy now also reiterates
memorandum outlined the reasons for the reporting requirements included it
establishing emission reduction ta gets the approval criteria for the 1979
through a negotiated process involving submittal and asks that the annual
state and local o cials from affected reasonable further progress reports be
jurisdictions. In the past. emission combined with related information
reduction targets and responsibilities for already being submitted on July 1 of
achieving the targets have sometimes each year. . -.
been determined without adequate . .
intergovernmental consultation, In some Ensuring Conformity of Federal Actrnxs
instances, for example, states attempted Section 176(c) of the Clean Air Act
to require local agencies to make up requires that federal actions conform t ,
large shortfalls in needed reductions SIPs. The proposed policy indicated that
entirely through transportation - states should, where possible, identify
measures without ex rnining whether :- the emissions associated with federal -
other measures, such as more ii gent - actions planned during the period -
exnissia limitations for stationary - covered by the SIP. A number of -
sources, might make up some of the - comments received on that portion of - -
ihortfafl. .- . - - : -:. the proposed po 11 cy requested - - - - -
The final policy has been revised to clarification of the process for ensuring
help clarify the intent of the section on conformity and the respective -
emission reduction targets. The process responsibilities of federal, state. and
for negotiating emission reduction -, local governments. The comments noted
targets becomes especiallylmportantin the potentially large number of actions
those areas where the r nm control involved, the associated work load for -
measures desc ed in subsections LB— state and local governments. and the -
LD are not su cieut to attain NAAQSs - lack of available state and local . - - -
and additional measures mast be .resourues. The comments also included-.
evaluated and sele ted. The subsection questions about the methods to be used
on analysis of alternatives has been; - for deterrnin g conformity. - . -
revised to indicate that the results of the. The final policy outlines the general -
evaluation of alternatives should be - responsibilities of federal, state, and
used in defining emission reduction -- local governments. Further clarification -
argeta. - - - . : . . :-: will be provided in a proposed rule that
- -.- - - EPA intends to issue sho y. Section -:
Dexnonstrabng Reasonable Further.. . 176(c) states that the assurance of - .
-Pro ss . .. - : conformity of federal actions is the -.
The proposed policy included . -. - - a rmative responsibility of the head of
requirements for demonstrating -. -- - each federa} agency. EPA believes that -
reasonable further progress towards each federal agency should establish
attai !1g NAAQSs.A substantial - - criteria and procedures for making
number of comments were received - . conformity determinations and that -
objecting to the requirement for a state and local governments should have
linear att i’ neut propam’ represented ,ppportur.ityto review proposed criteria
graphically by a straight line from base and procedures, as well as the
year to attai-irent year emissions. - Individual conformity determinations
Those commenting noted that many that result from their application. The
control measures. particularly thcse for proposed rule that EPA is preparing
vehicle emissions. have long lead times encourages the use of existing review
and do not have sigui cazit eEects processes. such as those required by the
within the first few years after adoption.. National Environmental Policy Act and.
Those measures that are implemented O ce of Management and Budget
within the early years will generally not Circular A-95. to reduce the resources -
result In a linear rate of emission required for ensuring Conformity.
reduction. . :; - - Interim criteria for use in making and
The final policy has been redraf ted to reviewing conformity determinations are
clarify that the linear a ’t irrn ent - - included in an advance notice of - - . -
program represents only the upper limit proposed rulemaking published by EPA
for annual net emissions from 1980 art April 1. 1980 (45 FR 21590). Criteria
through the year of at’ ir ment The - and procedures for evaluating the direct
measures encompassed by the linear and indirect air quality effects of -
att frrnent program include those In. wastewater treatment facilities funded -
both the 1979 and 1982 submittals. - under the Clean Water Act are include-i
Although there may be some lag time - - in the section 318 policy published on
before the measures in the 1982 August 11, 1980 (45 FR 53382). - -
submittal result in emission reductions. - Identification, during SIP preparation. if
reductions should already be occurring the emissions associated with future
165 -
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Feder 1 Register / Vol. 46. No. 14 1 Thursday, January 22.. 1981 1 Rules and Regulations.
7185
ajor federal actions wUl facilitate state
tnd local review of conformity -
determinations. -.
Consultation Among Stale and Local
f6c iaLs
Two state environmental agencies
commenting on the proposed policy
thought that the consultation provisions
were generally unclear. A local planning
agency asked that the policy be
supplemented to indicate that the
esignations of agency responsibilities
wade by governors prior to the 1979 plan
submittals remain in effect. A public
loterest group requested that the policy.
forbid states from making unilateral
changes in SIP provisions developed by
local governments.
Modifications were made in the
consultation provisions of the final
policy to help clarify apparently
ambiguous points and to indicate that
sew sectioz 174 agency designations are
Dot necessary. Although EPA agrees that
a state should not revise a locally
developed SIP provision without -.
consultog local c ciaIs, EPA believes
• that the regulations for implementing
section 121 of.the Clean Air Act already
adequately cover such a situation and
Fovide opportunity for appeal to EPA if
adequate consultation does not take
place. . -... . .. -
Deterrnning Data and Modeling -.
Requirements
The p roposed policy required that
emissicu inventories should, where
possible .. be prepared for a 1980 base
year. The policy also required that base
year and projected year emission
inventories for the ozone portion of the
SIP be seasonally adjusted annual
Inventories. The proposal required the
SIP to be based on the most recent three
years ofairquaiitydata.generafly .
Including data collected through the
third quarter of 1981. The proposal
recommended use of the city-specific
DY.A model to develop the ozone
portion of the SIP.
Several agencies responsible for
developing emission inventories ’
commented that agreements bad been
reached and work bad already begun on
inventories for base years other than
1980. The agencies recommended that
EPA remain flexible In the final policy
and accept inventories for those other
base years. The final policy continues to
allow inventories for base years other
thanig8 otobeused .
A number of state and local agencies
questlQned the validity of requiring
seasonally adjusted annual inventories
of VOCs. Most of those commenting
recommended that the inventories be
prepared icr a typical summer weekday
instead. The final policy requires the - regardless of the date after December
weekday inventory.- - 31.1982 when attainment can be -
Several agencies indicated in their demonstrated; These rn mum -
comments that their normal processing measures and their relationship to the
time to validate airquality data would plan’s attainment demonstatiori are -
prevent them from using data through described in Section I. Section I also.
the third quarter of 1981, if the SIP was discusses the approach that EPA
to be developed and submitted by July believes should be followed by those
1962. The final policy encourages the use few large urban areas where air quality
of data through the third quarter of 198 1, problems are so severe that analyses
but allows states to use earlier data. If a may indicate that attainment by 1987 Is
state selects to use earlier data, it still not possible. - - - -. . -
must present a summary of air uality in addition to including a - . -
data through 1981 in its July 1982 demonstration of attainment, the
submittal and describe how the data development of the 1982 SIP must
may affect the SIP. - - - . - conform to the process and follow the
State and local agencies that had- procedures required by the Clean Air
applied photochemical dispersioü Act and described in subsequent EPA
models in their previous Si? guidance. Section U identifies the major
development work commented that they steps in the SIP development process. -
should be allowed to use these models. Selected EPA guidance documents f
rather than the less sophisticated city- the SiP process era listed in Appendix B.
specific E134A mode], in developing Terms used in the Ira sportatio -alr - -
their 1982 submittals. The final polciy quality process are defined in Appendix
encourages the use of the photochemicai C. Also, the air quality and-emissions
dispersion mode l ; where the agency • data bases to be used in developing the -
developing the SIP has a demonstrated 1982 SIP inust be updated. The data
capability to use such models and . requirements for both ozone and carbon
wishes to do so. Use of a model other: monoxide are explained in Section ilL
than city-specific Qv1A or its -. - • The database for the ozone portion of
equivalent must be ’approved by EPA. : the SEP must be su dent to support at -
Final Policy-h-Criteria T - least a Level III modeling analysts. The
The 2232 Plan Revisions - . - - requirements for a Level Ill analysis are
• • •. - - -. - - . summarized in Appendix D. • -
L,mduc . ian . - -- :.... . Finally, Section IV describe, the - - -
in circumstances where a tatns of the various air quality models
received an extension beYond and alerts states to mode1in
att ini g a NAAQS for ozone or carbon re ufrements. EPA recommendi
monoxide, the Clean Air Act -: •., application of city-speci&EI3 4A or-an
Amendments of 1977 [ Section 12 9 ( C) of • equivalent method for developing the
Pub. L 5- 1 require the state to adopt .. ozone portion of the SIP, unless the
and schmit a . agency preparing the SIP eirea4 has - - -
At nictator of EPA by jui - 1 1. 1 . - - - the capability and wants to apply a .
The areas that ar affected by this - -, more sophisticated level of modeling.:.
requirement are listed in Appendix For the carbon monoxide portion. EPA -
The purpose of this notice is to outline -- recommends application of the models
the criteria that EPA will use -- -. identified in existing EPA guidance..
evaluating the adequacy of the 1982 SIP J. Control Sb ’ateies and Atlainment
revisions. These criteria fail into four Demonstration - - .
general categorier (1) Control strategies
and attainment demonstration. (2) SIP A. Summary . - •.
development process. (3) data collection. The Clean Air Act requires the 2 82
end (4] modeling. • SIPs to contain a fully adopted.
The Clean Air Act Amendments of technically justified program that adopts
1977 require all SIPs for the areas that and commits to implement groups of
have received an extension beyond 1982 - control measures that will result in
to demonstrate attainment of the - attainment of the ozone and carbon
NAAQSs for ozone and carbon — -. monoxide NAAQSS no later than 1987 -
monoxide as expeditiously . and that will provide reasonable further
practicable. hut not later than December - progress in the interim. All plans must --
.31.1987. As a condition for extending - - contain the three categories of minimum
the attar ment date. Congress also - - control measures deècibed in this -
required that each SIP contain certain section. 11 these mi’ imum control - -
control provisions covering stationary measures are not adequate to show--
sources, vehicle l M. and transportation attRir ment by 1987, additional measures -
measures. The control provisions must which can be implemented by 1987 must
be included in the SIP for an area where be identified and adopted. if fl : - • -
an extension li s been granted. - measures which can be implemented by
-166
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7186 dà 1 Register I /oL 46 No. 14 / Thursday.- January 22, 1981LI Rules and Regulations
1987 are not adequate todernonsfrate -
attainment by 1987, additional measures
which can be implemented after 1987
must be identifled and adopted and
attainment must be demonsfrated by the
earliest possible date. the date of
attainment must be specified in all SIPs.
In order to ensure equity among the
a.’eas unable to demonstrate att Jnment
by 198.7, EPA Intends to evaluate all SIPs.
submitted in July 1982 for the -
effectiveness of measures applied in all
areas. Should EPA find that any of the
areas not demonstrating attnin neut by
1987 have failed to aaopt the most -.
effective measures available, EPA will
compile a list of such controls and
require these areas to revise their SIPs -:
to include the more effective confrol , -
measures. - . - *
Subsections B-D des ibe In detail the
minimum control measures which mu.st,
be contained lxi each plan submitted in
July 1982. The state must demonstrate
that adoption and Implementation of
these elements will result in the
at riment of the ozone and carbon.
monoxide standards by the most
expeditious date poesfole. Control
measures must be adopted in legally
euiorueable fo The-SiP submittal-
must Include mpl . t2tion schedole
end commI rnte- Subsections E and P
describe reasonable further progress
ar. attaix ment demonstration - -
requirements. Sub’ectio ” G describes
the conformity of federal actions
B. Stationary Sources -. - -
S 72(b) of the CleaixAfrAct
requires states all -.
reasonably available onnt l meüure
as expeditiously as practicable and. in
the interim, maintain reascuable further
progress, including such reduction in
emissions from existing sources as may
be cbtalned through the, adoption. at a
n frthnum. of RACr. In order to complete
the requirement to adopt all reasonably
available control measures, states must
Include as part of the 2382 Submft .1.
adopted regulation applying RACT to
the fOllOwing categories of sources: (1)
All sources of VOCs covered by a C rC.
(2) all rem bth g major (emitting more.
than 100 tons per year potential
emissions as deftued under section
302(j) of the Clean Air Act) stationary
sources of VOCs, and (3) all sources of
carbon monoxide emitting more than
1.000 tons per yóar potential emissions.
The guidelines for the 2979 ozone -
submittals permitted states to defer the
adoption of regulations until the CFC for
a sour category was pubhslieL This...
delay allowed the states to make more
tecb iir tUy sound decisions regarding
the application of RACT. EPA- .- - .
anticipates Issuing a number of - Include: (1) Inspection test procedures;
additional CTGs in 1931 for various. . (2) emission standards (3) Inspection -
source categories of VOCs. These .. - - station licensing requirements: (4) . -
documents, In coxijunclion with the - . - emission analyzer specification and
previously Issued crGs 1 will address - maintenance/calibration requirements; -
most of the major source categories (5) recordkeeping and record snbnutta.l
which are of national importance... requirements; (6) quality control, audit,
Legally enforceable measures -- and surveillance procedures: (7)
implementing RAC1’ for all sources procedures to assure that noncomplying
addressed by these documents must be - vehicles are not operated on the pubic
included in the July 1982 submittal. . roads; (8) any other official program
There will remain numerous other . rules. regulations. and procedures; (9) a
major sources of VOCs that may be of - public awareness plan and (10) a. -
local importance for Which a CIG wilL ‘:mechauics tr inirig program if ad&tional
not be available. For the major sources emission reduction credits are being -
for which a CrC does not apply, a state . claimed for mer -h n cs training.. . -
must detprmine whether additional
controls representing RACT - - . As part of the 1982 SIP review- -
available. EPA will require the ubmift l process. EPA will determine the overall
to include either legally enforceable - adequacy of the Critical elements of
measures Implementing RACT th Se. each IJM program and. theralore, the
sources ox- documentation supporting a -. approvability of the 1982 SW by - -. -
- determination by the state that the comparing those elements t• established
- existing levelofconfrolrepresents - I/Mpoi y.IM program elements must
RAcrforeachofthesesources. - •. beconsistentwith EPApolicyora
• - if application of R.ACT to all sources demonstration must be made thatthe -
covered by a crc and all othe major - program elements are equivalent -- - -
sources, together with implementation f . State or local governments that have.:.
- a vehicle 1/M program and -‘ - - ‘ l/l 1 programs, but plan to increase the
- -. . transportation controls, does ot result - coverage and/ot stringency of the.
In attai 1-n.ent of the ozone standards by .T: prograinsin order to achieve greater
-1987, then additional stationary source - ‘ reductions, must submit the progam •-: -
• controls must be adopted by the state. modifications in. legally enforceable ... -
-: C. Vehicle ti n a form through the 1982 SIP revision : :
process. - - -
All majorirrban areas needing xi Ti! a state wishes to-submit all oi-part:
extension beyond 1982 or at i i tent of ,t the l/M elements required for the 1982
-a standard forozone orcarbon . - •:. SWre ion JoreJuiy 1982, with or-
monoxide were required to include - - - without other portions of the 1982 SIP
vehicle t/M as an element of the 1979 - revision, EPA will review and evaluate -. -
-- SIP revision. States were required at the submittal and take apprpxiate -
• that time to submit only evidence of - - action as expeditiously as practicabie. -
adequate legal authcrity. -a commitment the case of a partial subthittal. -:-
to implement and enfOrCe 8 O 8 1 - action will be limited to the availab
that will reduce hydrocarbon end
- carbon monoxide exhaust emissions - - program elements. Final action on the —
- fromlightduty-vehiclesini987byZ5 tutal l/Mprograxuuinstbereserved
- percent. arid a schedule - - until all elements era submitted and -
Implementation. Full implementation - reviewed in order to assure that the
that program. in accordance with EPA’s - program satisfies the provisions in Part -
established l/Mpolicy.isrequiredinall DoftheCleanAfrAct
cases by December . igs . - If a state is implementing an IJM
States with areas that have J/M -- program on an approved schedule which
programs under development or . extends beyond july 1.1982, and the
operational as part of their ig si state Is unable to finalize some of the
revisions were required to submit only critical elements of its I/M program in
qualitative descriptions of their t/M -. time to Include them in the 1982 SIP -
program elements in the 1979 SW - revision. the state may submit those -
submittal. The documentation discussed elements at a later date. This later date
below must be submitted by July iaa2. If must, however be identified and - . -.
- not previously submitted as evidence of Justified by the state in Its 1982 SIP - - -
compliance with the 1979 . . - - - revision and be consistent with the tIM -
Implementation schedule. The 1982 SW - - Implementation schedule in Its 1979 SIP
revision must include rules and - submittal. In such cases EPA will revie’
regulations and all other t/M elements the available program elements and, if -
which could effect the ability of the l/M - - adequate. conditionally approve the - - -
program to achieve the minimum -. t/M program on the submittal (by the
emission reduction requirements. More... - designated date) and approval of the - - -
- specifically, the 1.982 submittal must-- --S- - -outstanding elements. - - - - - -
167
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Federal Register I Vol. 46,. No. 14 / Thursday, 5 Jañua.r 22, i9àfj . .Riilés and Rè uiatioris - — 7187
local funds to implement the necessary - area has changed from that described in
improvements. Coxnxziitments and the 1979 submittaL en updated
schedules for the implementation of description. indudin key plarmlng .
these measures must also be submitted. programn ing, and funding decision
5. A description of public participation points, should be submitted in 1982.
and elected official consultation -. Solutions to carbon monoxide
activities during development of the problems can be found through
transportation measures. - metropolitan .wide planning, as well as
6. A monitoring plan for periodically through analyses of relatively small
assessing success or failure of - (liotepor) problem areas. Evidence of
transportation measures or packages of. - specific carbon monoxIde problem areas
measures in meeting emission reduction - is derived from modeling and monitoring
projections. The-plan should contain information. Although the geographic
methods for determining the reasons for area that is nonattainnient for carbon -
success or failure. - - monoxide may be small, the measures
7. Mniinktrative and technical - - necessary to meet standards may have
procedures and agency responsibilities to be applied over a larger area. it is
for ensuring, in response to section essential to guard against selecting
176(c) of the Clean Air Act, that measures that will solve the carbon
transportation plans, programs, and monoxide problem in a small geographic
projects approved by a metropolitan - area. but that will worsen the ozone•
planning organization (MPO) are in - . problem or simply transfer the carbon
conformance with the SIP. - - monoxide problem to another area.
8. A two-part contingency provision. .
the xst part is applicable to only those E. Reasonable Further Progress . -
areas with populations of 200.000 or The July1982 submittal must
more. These areas must submit as part - demonstrate that reasonable further
of the SIB a list of planned progress toward attainment of the ozone
transportation measures and projects - and carbon monoxide standards will
that may adversely affect air quality and chutinue to be made and reported
that will be delayed, while the SIP is. throughout the period of nonattainrne nt.
being revised. if expected e m i ssion . The annual emission reductions must at
reductions or air quality Improvementi ‘- least equal the emission reductions that
do not occur. The second part. which - would be achieved through a linear
must be submitted by all areas: - attair nt program. As described in thi
preparing 1962 SIP revisions, consists of iteria for approval of the 1979 SIP
a desaiption of the process that will b. submittal, this program is represented
used to determine and implement graphically by a straight line drawn
additional transnortation measures from the emissions inventory for the
beneficial to air quality that will - base year of the 1979 submittal to the
compensate for the unantidpated allowable emissions on the attainment - .
shortiafls In emission reductions. The date. Compliance with the reasonable
contingency provision m.u.st be initiated further progress requirement does not - -
when the EPA Ar__nictrator determines . authorize delays in implementation or-
that a SIP is inadequate to attain : adoption of any measures. All controls
NAAQSs and that additional emission must be implemented as expeditiously - -
reductions are needed. -as practicable. . .
The Ath—f-gtrator’s February 24. 1978 The demonstration of reasonable
memorandum, “Criteria for A prova1 of -: further progress must indicate the total
1979 SIP Revisions,” and the October a .mount of the annual reduction In.
1978 SIP Transportation Checklist emissions and must distinguish between
identified the elements necessary for the those reductions projected to result from
transportation portion of the 1g7g SIP. - mobile source and stationary source
The provisions listed above supplement measures. The projected reductions to
- the elements described in the earlier be achieved from these source., - -
guidance. categories must be consistent with the
The guidance for 1979 placed primary -emission reduction targest established - -
emphasis on the establishments of a - through the consultation process -- -
• continuing air quality-transportation involving state and local officials.
planning process. This-continuing - The criteria for approval of the 1979
planning process must be used in &ubmittai recognized that there would
• developing the transportation portion of be a lag In the early years In achieving -
the 1982 SIP revision. The process is reasonable further progress because
- described in the June 1978 EPA- - - most measures would not achieve
Department of Transportation (DOT) -. immediate reductions. By 1982, however,
Transportation-Air Quality Planning a significant number of the stationary
Guidelines and the May 1, 1980 EPA- source controls and transportation
DOT Expanded Guidelines for Public measures included in the 1979 submittal
Particination. Where the pri5cess for an will be implemented, as will the vehicle
D. Transportation Measures
The portion of the 1982 SIP addressing
emission reductions to be achieved
through the implementation of
b-ansportation measures must include -
the basic provisions listed below.
Further guidance will be issued. as
necessary. to describe these- -
requirements in greater detaiL -
1. An updated emission reduction
target for the transportation sector. As
discussed below, the target must be
determined by consultation among state
and local officials using the procedures -
established under sections 121 and 174
oftheAct. - -
2, All reasonably available
ansportation measures and packages
oi measures necessary for the -
expeditious attainment of the - -
transportation emission reduction target.
Categories of reasonably available -
transportation measures are identified
In section 108 (1 ) of the Act. The -
submittal should present documentation.
based on technical analysis, of the basis
for not implementing any of the -
measures identified in this section. The
1982 SIP submittal must contain
transportation emission reduction -
estiates for adopted measures and
packages of measures for each year
between 1982 and the attainment date.
Any reasonably available transportation
measures that have been adopted
between the submission of the 1979 -
revision and the preparation of the 1982
revision should be included in the 1982
submittal along-with the associated
emission reductions. - - -. -•
3. Commitnents. schedules of key
milestones, and, where appropriate, -
evidence of legal authority for - -
implementation . operation, and - - -
enforcement of adopted reesoàably -
available transportation measures.
Costs and funding sources for plarming. -
implementing. operating, and enforcing
adopted measures must be determined
for all measures. Tasks and
responsibilities of state and local -
agencies-and elected officials in carrying
out required programming.
Implementation. operation. and -
enforcement activities associated with
adopted transportation measures must
be identified. The 1982 submittal must
also indude documentation that state
and local goverr mAnts are continuing to
meet the schedules and commitments for
the transportation measures included in
the 1979 SIP.
4. Comprehensive public -
transportation measures to meet basic
transportation needs. The measures
must be accompanied by an
identification and commitment to use, to
the extent necessary, federal state. and
168
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7168 Federal Register / VoL 46 No. 14 / Thursday, January 22, 1981 / Rules and Regulations
emission l(M program. Emission . Many transportation measures which after 1937, EPA intends to seek
reductions will also continue to result cannot be implemented by 1987 can, legislative changes that will allow such
from the control systems required by the because of the additional lime and an approvaL The nature of any -
Federal Motor Vehicle Control Program resources available, be implemented by . - legislative change that the Agency rnay
for new vehicles. Accordingly, each plan— a post-1987 attainment date. The 108 (f) request will be based on a caz fnl -
must demonstrate for each year until measures ultimately selected should, evaluation of the status of state efforts
attainment is achieved that the annual both individually and collectively, be at to develop plans which attain the
net emissions fall on or below the point least as ambitious as applications of standards on or before 1967. One option
representing that year on the straight - these-measures in other comparable - for leelsiative chanee that EPA will
line.No lag period will be allowedin are A,inconsultalionwiththe
consicer recommencing wouiu proviae
1982 and later years. - DOT, will act as a clearinghouse in- -
The ciiteria for approving the 1979 SIP identifying ambitious performance area spe c a e es an con
submitteis included a requirement for levels for specific measures. - . .reqwreinents for each ox the areas that.
annual re rtirig of reasonable fther - The 1982 SIP revision to achieve a cannot demonstrate attainment by 1987.
progress. The information demonstrating post-1987 emission reduction target must C. Conformity of Federal Actions
reasonable further progress shall be include a convincing demonstration that
submitted along with the source . - the target cannot be achieved by 1987 Section 178(c) of the Clean Air Act
emissions and nnnal state action report end that the post-1987 date is the most requires all federal projects, licenses,
required by July 1 of each year (40 CER expeditions date possible. The permits, financial assistance and other
51.321 —51.328). - - - - - demonstration must identify the - - - activities to conform to SIPs. Assurance
• lr ,, , - ?nfr frnuin limes needed far plani , -. of conformity is an a rznative
P Au wr1 measures - - programming, and implementation of -- responsibility of the head of each :- -
or - - - adopted transportation and stationary federal agency. In addition, section
If the ni r n1um control easures source control measures arid must - 318 (b) requires that the direct and - - -
described in vth mions B— I ) are not - demonstrate that all possible measures nd r emissioi associated with any
adequate to demonstrate by —will be Implemented prior to 1987. lix wastewater treatment facility funded-
1987, the state must identify, evaluate, - -. addition, the demonstration must show -. imdà the Clean Water Act be -
and adopt addltionai measures which -- that projected fesources from available - accommodated I the SIP In prepaxinj
can be implemanted.u quickly as -: - - sources (federal, state, and local) are the 1982 SIP revision, states and locaL.
poss ]a, but no later than 1987. - - - - lnsu cient for faster implementation of + , . ,_ •.
* . governmen e
Examples of such measures include the the measures. -- - - - - -. , . , . . , - -
ii - • . . • - possi e, e an. in
- - . - -. use - . . - • *_ •
(13 Requiring control of all majar - prepared by a state to assess whether - - emissions a ss aateu wi Li major I c
sta cn*ry sources to levels more - - areas are maldzig all efforts possible . a ..oris, £ UM 6 as.ew ,a.er treatment
swmgectthanlhose generally regarded - attain the ozone and carbon monoxide - facility grants, that will taxe place -- -
-asRAcr, - - -.: -. standardsby l987.lfanareaisnnable - - during the penod coveredby the SIP, - -
(2) Extending controls td stationary to attain the ozone and CZ.-bon - - Explicit identification of emissions will
sources and scource categories other . monoxide NAAQSs by 1987, then the -- enable state and local governments to - -
than thos. subject to the r i ’ nrn - - “ iost expedjt1om date beyond g 7” - - -“more quickly and easily evaluate -
- connol measures described in ..- - - must be agreed to by state arid local. subsequent federal conformity — - - - -
subsection L - - - - -- agencies. The transportation and - - - determinations. To assist in detrm nfr g
(31 bnp lethasithrg a broader range of - stationary source control measures - - --- - - - conforziiity, the population projections
transportation COntrOls (14_ extending necessary for demonstrating a ‘rr en - onwhich the 1982 SIP revision is based - -
the gengraphic coverage of SO - -- by the most expeditious date muss be - should be capable of being - .. - -
measures or providing more intensive - - adopted as part of the i az SIP - - - disaggregated at the lime -of project -‘ - -
lmp!ementatio4 and - - - submitted to EPA. - analysis so that the areas affected by
(4) IncreasIng the ca erage and -: EPA believes that an approach which individual federal actions not explicitly
stringency of the vehicle emission UM - requires a state to demonstrate - accounted for in the SIP can be
program. • atthimnent by a certain date using identified. - - -
If Implementation of all measures - measures it is committed to implement - . -
which can be Impleurented by 1987 will is more In keeping with the spirit of the Developm eat Process
still not de ’n itrate att ir .nt by 2287. Clean Air Act thao an approach which m c i -
the state should then analyze would accept “paper” demonstrations of iv an’ subse uerzt tb
fransportation and other measures -- att* nent 1,y 1987 which relied on - i’• “ . A
possible in a*nger me frame that. - measures which would be v!rtue.fl • p .hwcIes am gui ance uin uave. -
- toga measures y - — impossible to implement EPA will not . + -
evaluated, will result in attainment as approve a plan which relies on such - requiremern4 or . eve oping -
quickly as possible alter 1W. The -- -- inimplementable measures to - - - revisions or nonattat ent areas. -. -
specific date for at r!m ,t shall be - demonstrate attainment, when it s clear Appendix.B includes a list-of selected
included in the SIP. State arid loch - - that the state is not committed to - -. guidance documents that should be used
governments must commit to - - - - Implement and enforce those aspects of in the preparation of the 1982 SIP. EPA
impl .”tation of such measures. - - - - - the plan. - - - - - - - regional offices will work with states
Given the additional time and - — EPA will review pThns with post-198 7 and affected local governments during
- potential resources available to areas - - attainment dates in accordance with the. - the preparation of the SIP to help ensur
with a post-1987 attainment date, more - requirements of the Clean Air Act If that procedural requirements are - - -
extensive evidence will be required to - EPA concludes that the current - -- - --- - satisfied and that interim products and - -
demonstrate that any of the measures provisions of the Act do not allow activities are completed on a schedule
identified In sectfonla8(1) of the Clean approval of a SIP that provides for that will enable the July 1 1982
Air-Act-is not reasonably available. - expeditious attainment of standards - submittal deadline to be met. - -. -
169
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Federal Register f Vol. 45 . No. 14 / Thursday. January 22. 1981 1 Rules and Regulations
7189
A. Consultation Among State and Local
Officials
Section 121 of the Clean Air Act
requires each state to provide a process
for consultation with local governments,
organizations of local elected officials,
and federal land managers during
certain actions under the Act, including
preparation ci SIP revisions for
nonattain. ent areas. Section 174 of the
Act requires a joint determination by
state and local officials of the roles that
various governmental agencies will take
In the SIP development. implementation.
and enforcement process. Section 174
also requires the governor of each state
to designate the agency or agencies
responsible for SIP development The
designation made by the governor for
the 1979 SIP submittal remains In effect.
unless the governor designates a new
agency. The joint determination of
responsibilities and any revised agency
designations should be completed early
in the process and must be submitted as
a part of the 1982 SiP revision. Final
regulations on section 174 and 1 (40
CFR Part 51. (Subpart M) were
published on Jima 18, 1979 (44 FR 35175).
B. Estabfishment of Emission Reduction
Targets :
The control strate ’ for the 1982 Si?
must reflect a eement among affected
state and local officials on the emission
reductions needed to attain NAAQSs. It
is particularly important that the
emission reduction targets established
for stationary and mobile sources be
determined through a process of
negotiation among state and local -.
offlcials ‘if affected jurisdictions. In’
most cases, the initial emission
reduction targets will be established
soon after the technical evaluation of
reasonably available stationary and
mobile source control measures. Targets
may have to be ravi.sed as additional
information becomes available during
SIP development. Revised targets should
also be determined through consultation
among state and local officials.
C. Analysis of Alternatives’ and Their
Effects ‘ -
In order for decision-makers and the
public to have adequate information -
• during development of SIPs requiring
measures beyond the i ,um-
descriked in subsections LB.-LD,
alternative control strategies should be
developed and analyzed. For example,
where a vehicle IIM pro am and RACE
applied to all major stationary sources
will not be &u thent. in combination
with reasonably available
transportation measures, to attain ‘
standards, a range of more stringent.
stationary and mobile source controls
should be evaluated to determine the
best combination to achieve the
required emission reductions. This V
evaluation should be used in-.
determining the emission reduction
targets described in the previous
subsection. Examples of these more
stringent controls are listed in
subsection V -
The Clean Air Act requires that SIP
submittals include-an analysis of air
quality, health. welfare, economic,
energy, and social effects of the SIP and V
of the alternative measures considered
during SIP development. EPA believes
that, in assessing the effects of V V
alternative control measures, two V V V V
national concerns should receive special
emphasis. These concerns are (1).
conservation of petroleum and natural
gas, and (Z) protection of the economies V
of dee1 ’thig urban areas. Additional
emphasis on the effects of SIPs on — V
energy conservation and economies of
distressed urban areas will implement
the intent of Executive Order 12185.
Conservation of Petroleum and Natural
Gas (45 FR 8537, February 7,1960), and
the Nationaltjrban Policy. ‘
IZ(. Air Quality a d V V V V
Bases V -. -
• The requirements for the 1.979 SIP
submittal included use of the best data
available at the time of SIP -
development. Although states generally
complied with this provision. in many
cases the available data base had many..
shottco s. All states will have had
adequate time by 1982 to have an - -.
updateddat base.-- -. -
States will need to have the data
- necessary for Si? development
;ign antlybeiore the July 1.1982.
submittal date. To ensure that this effort
receives appropriate priority and
attention. EPA expects states to
complete data collection, analyses, and
-documentation by Decamber 31. 1981.
This requirement in no way relieves a
state from any prior co rrn nts to
have such data available atan earlier -.
V date.. - V
Emission Inventories should, where
possible, be prepared for a 1980 base-
year and projected to a date that will, at
a rrt r mum. include the anticipated year
of attainment Population projections
and other forecasts used for deterrr inng
growth rates and areawide emission -
estimates must be consistent with
population projections developed In -
accordance with the EPA’s cost-
effectiveness guidelines for wastewater
treatment facilities (40 R Part 35, -
V Supart E Appendix A). -. .
The mostrecent three years of air - V
quality data from the state and local air
monitoring system network must be
reduced, validated, and summarized in
the plan submittal. Generally, this will
include all data collected through the
third quarter of 1981. All data from
special studies implemeuTted to support
the modeling effort must also be V
compiled. reduced, and documented. If a
state cannot reduce evaluate, and
validate data through the third quarter
of 1981 in sufficient time to develop the
SIP revision and still meet
intergovernmental con ultation. public
participation. and other requirements. -
the state shall present the data in the
SIP submittal and describe how the data’
may effect the plan.
A. Data for Ozone SIP Revisions • -
EPA previously described the .-..
minimum data that-the Agency . .
anticipated would be necessary to ‘
prepare an ozone modeling effort for -
four levels of analyses (44 FR 65687, - V
November 14. 1979). It now appears,
however, that many of the areas
requiring the more sophisticated levels.
of modeling will not be able to complete. -
the mare extensive data base coIlection.-
efforts required for these models inthne --
to support the 1982 SIP submittal.. : -.
Accordingly, every urban area-must
completeadatabasesufflcientto - •
support at least a Level Ill (city-specific
ElO..{A) modeling analysis. The elements-
of this data base axe summarized in -
AppendixD. • V • - -
EPA inticipates that states with . -•
especially severe ozone problems will, - -
need to apply a photochemical - - V
dispersion model an equivalent - - -
technique in subsequent modeiing.--. --’
analyses after 1982. Data collection V
efforts should be structured to provide
for this conlingencl. - - . - -
In order to ensure that all the data
bases will be compatible and that there
is a consistent level of documentation
and quality assurance, -state submittals -
of environmental data must be -
consistent In format and content with
the EPA guideline document. E .mission
Inventory Reqzzirewents for 2982 Ozone
sips.. • •
B. Data for Carbon Monoxide SIP .‘. - -
revisions . - . - -
The emission Inventory for carbon • -
monoxide must be of sufficient accuracy
and detail to provide the necessary • V
input to models, and to determine the -. -
effectiveness of proposed control -
measures- The inventory should ‘
normally represent a typical weekday
during the worst carbon monoxide’
ieason and should cover the entire
urban area. More detailed inventories -
for smaller hotspot areas may be needed
for analyzing specifically identified
170
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7190
problems. In developing carbon
monoxide emission inventories states
may, if they desire, limit the -
identification of stationary sources to
those with potential emissions of 1000
tons per year. The final acceptability of
the inventoRy developed will be
dependent on the modeling approach
selected and will be judged on a case-
by-case basis.
W Modeliz g
States will need to apply the best
tools available in their 1982 SIP
submittal. The air quality models that
EPA considers acceptable are identified
below.
A. Ozone Models
Photochenücal dispersion models
have the greatest potential for
evaluating the effectiveness of ozone
control strategies. This potential arises
primarily from the ability to relate
emissions directly to ambient ozone
concentrations, ‘ alclng into account:•
atnosphenc chemistry and dispersion. -
In most cases, howevez data
requfrements associated with applying
these models by 1982 are prohibitive. Of -
the generally available, less data
intensive models, only the various
applications Of DCMA consider local
m.etecrological influences and
atmospheric eh misty in evaluating
control requirements. Th city-spe flc
EKMA approach is the most pro ” - g - -
for 1982 and EPA recommends its tse.
the agency preparing the SIP already
has the capabilijy to apply amore
sophisticated level of modeling a
warts to do so. EPA enco ages such -
applications. The use of a modeling
approach other than city-specific E 3VfA
must be approved by EPA prior to a
commitment by the state to its use. EPA
Is currently fln.livi tg the guideline on
the use of city-speciZc OtLA the
guideline should be available by March
19814
The inability of other simpler models
to adequately consider chemical netics
and meteorological parameters reduces
their ability to represent local situations.
Accordingly. EPA will not consider
plansbasedonlinearorproportional
rollback to provide an adequate
demonstration of atta rn1. t . EPA is
publishing a proposal in todays Federal
Register to modify 40 CFR $1.14 by
deleting the provision allowing the use
of rollback as an acceptable modeling
technique. A state that used rollback In
the SIP revision submittal In 1979 to
4ezuonsfrate attainment by 1982 will not
be required to revise the analysis on
wbith its S W Is based ,inleu EPA
determines the SIP to be deficient for
attainir*g the ozone NAAQS. Upon such
a determination, the state will be
required to meet the provisions of this
policy including adoption of the
miikirnuin control measures, as well as
the modeling requirements. -
B. Carbon Monoxide Models
States and urban areas must estimate
the impact of local and regional control
strategies on carbon monoxide
nonattainment areas and demonstrate -
attninrnent of the carbon monoxide
standard. The generally available
carbon monoxide models are des ibed
In Guideline on Air Quality ModeJs ..
April1978, EPA 450/2-78-027. These
guidelines, and any subsequent updates,
should be followed In preparing a
carbon monoxide attainment analysis.
The acceptability of models other than
those listed in the guideline will be -
evaluated on a case-by-case basis. -- -
Other models proposed for use must be
adequately documented. and validated.
D&ted jam3asyj 198k. -
Dangles M Costis,
Administrator.
Appendli A—Extension Areas
Table 1. —Aiaas Requestihg an £rtens on
Beyond 1982 for Ar aJtth- g me Ozone Standaid
. , - 5 1 1*
Sa
— New Jee, 1 S *w ds. -
- NIe Y t________ hew YQ t y.
ci Col ei._.
• - West ion.
— , s4 -
PJs
Wa 1 *çt l .
I V I . ”wdiy Onv . I.ci ms.
V_____ s .— O ço. Lois.
• ONe -. OrorreL Q
-
vs I o .a l SLLo i s - -
vs. C øo -Dew
• _____SeS La a O
U Caliciro______ F,ew o’ Saa ewsc .
FfWl CO S I! AIlS
asse. v.ns..
- -
X - Putw .
W
* S is V. ’. 7 No M.m. -
• Seiai C. eaI t1Ov* 111i1 ,y,sI* Aiss.
Table 2.—Areas Request -ç an Extension Be-
yond 1982 for Attaining the Caiben Mon x-
ide 5ta,,da, -
•r 511* -.
Appendix B—Selected EPA Guidance for SIP
Development - - - - - -
The follow i giist identifies selected EPA
guidance for SIP development. A compilatc
of major EPA guidance for SIP development
Is included in the Air Programs Policy and
Guidance Notebook.’ which is distributed to
state and local agencies. Copies of the
notebook are available for copying at the
EPA Public Info rmation Reference Unit in
Wathington. D.C. and at each EPA regional
c ce. -
1. Cnte.-ia for Approval of 1979 SIP
Revisions. mamorandnm from Douglas M.
Costle. Aduinisfra tar of EPA to Regional
Administrators. Regions I-.X. February 24.
1975 (43 FR Z1873).
- 2. Meniorandum of Understanding
Between DOT and EPA Regarding the -
integration of Transportation and Air Quality
PIa miqg J me 1978. - - - - .
3. EPA-DOT Transportation-Air Quality
PIa’ithng Guidelines. June 1978. - -
4. inspection/Maintenance Policy,
memorandum from David C. Hawkins to
Regional Administrators, Regions l-X. July
17.1978. - -
5. Dete minafion of Emission Reduction
Responsibili es, memorandum from David .
Hawkins to Regional rr,ci. ators. Augt t
1.1978. - — - - -
Federal Register I VoL 46, No. 14 i --Thursday, January 22,1981 Rules and Regulations
New hee,
w .
New Mw e
I________ New . e .*my — Mw c y.
- SI
- - E F
- - !.
- N e w
• - - — - e
- -• Ai So
New Yok _________ )iuw Y k Oty.
c i Cc sre _ W* W -çor
__ -
— _
U Gs pa A* ia.
- - -
- Ne CWONe
• T.tv* . ... 144, LLe k
V O ga .
- - _____ New èew.
hew _____
w 5 . Lo*.
vu. _____Dew. C
• i•. -. -.
SM
U____
- C&dcvrie________
- - - -
• - - - B s c
• Ne ,ad s _L*V . .- -
X - Ciregc.,_________..._ Eu sn..
- _
- 511*5. T.OO.,II.
• ___
171
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Federal Register / VoL 48, No. 14 f Thursday. January 22. 1981 1 Rtil s -and Re idaliQr1s
7191
L General Preamble for Proposed
demaking. April 4. 1979 (44 PR 20372). The
tnera! Preamble was amended on the
sowing dates. April 30. 1979 (44 FR 25243);
ly 2.1979(44 FR 38583); August 28. 1979 (44
50371); September 17, 1979 (44 FR 53l8l)
.4 November 23. 1979 (4.4 57133).
7. 40 CFR Pert 51. Subpart M—
tergoverr .mezital Consultation. June 18. 1979
$FR 35176)
8. EPA-DOT Ex?anded Public
uticipalion G.. ..delines, May 1. 1980 (45 FR
P32).
g. DOT-EPA Procedures for Cfor anr .e
1Transpor ation Plans. Programi and
ecta with Clean Air Act State
plementa Lion Plans. June 12. 1983.
13. Policy and Procedures to Implement
totiort 318 of the Clean Au Act, as
mended. memorandum from Douglas M.
ostle to Regional Administrators. Regions
J’ .ly 23,1980. (45 FR 53382).
ppendix C.—Deseriplio of Terms Used in
i Transportation-Air Quality SIP
bvelopment Process
‘opted Measures
A tanap ationmeasure. program. or
olicy that state and local planning and
plementlng agencies and governments
ave agreed to include inthe o 1cia1 SIP
bmissi on. -
cnni s Process
The process defined in the September17,
975 Federal Highway Adnilnistation
HWA)-Urban Mass Transportation
dnñnistration (T.Th4TA) regulations. the June
S78 EPA-DOT Transportation-Air Quality
*annirig Guidelines, and the May 1. 1980
TA-DOT Expanded Public Participation
guidelines. Tarough this process
unsportation meas’.ues are introduced.
ivaluated. placed i the Transportation
ystezns Management CTSM] or long range
ilement of the urban transportation plan, and
idvanced to the Transportation Improvement
Program (TIP) and the annual element of the
ro rornnivig Process
The process by which transportation-
ateasures are advanced om the annual
lenent of the TIP to the capital programs
md budgets of implementing agencies and
then to funding by state and local
governments. FI WA (through the statewide
105 program). or UMTA (through the section 3
tad 5 pro arns ). -
Expeditious At± th nrent Data
The attainment date approved in the 1979
SIP submission. Thi, date may be modified if
it}e analysis of alta.rtatives done as part of
the development of the 1982 SIP submittal
shows that an earlier date is possible through
expeditious iplemantatioa of all reasonably
available control measures or that a later
date is necessary because the approved
attainment date cannot be achieved. -
P ecsonabJyAv JJcb1e Transportation
Mecsures -
A measure that has eera determined to be
beneficial to air quality and-which %vill ant
result in substa.ntlal and long-term adverse
Impacts. These measures need t o be adopted
by the affected state and local o cials
participating in the pl nr1ing end -
progrmini g processes. The process of
determining reasonably available
transportation measures is analytical.
participatory, and negotiatory, an d involves -.
thepublic. as well as local. state.and federal
agencies and o ciala. The analytic part of -
the process includes determinations of
technical and economic feasibility.
Expeditious Implementation of Reasonably
A vol/able Transportation Mecrszrres
Implementation by the earliest possible
date considenng
1. The m”irnum time required to advance
the measure through p 1 rtn ng and -
pragren’rr in.g processes.
.2. The minimum time required to obtain
implementation cammi enta . - -
3. The time required to construct
(if needed) and begin operation of the
measures. - -
Implementation Cam ituren
Certification (may be by reference to
budgets or other legally adopted documents)
by federal. state. and local agencies with the
authority to implement SIP measures that (1)
funds to-implement the measure are obligated
• and (2) all necessary approvals have been
-obtained. Identification by the implementing
agency of the scheduled dates for start of
construction (if appropriate) e nd (or start of
operation. - -. - -
I! a projectbas not reached the sta * of - -:
receivrng bucget approval, then the -
mpler øn tion ccmmi ent should be in the
form of a schedule that lists the projected
dates far cnmplating the major steps required
to advance the measure through the
remeini-ng pI .& g and programming
processes. The schedule should also contain
an identification of the responsible agencies -
that must tarce si ificant actions to- -
Impleme nt the measure. - - -
Actions by many agenries end elected -
c cial, are usually r qnired beiore a
transportation project is implemented. The
SIP should list the important actions, the
• agencies or 0 ff risis required to take each
action. and a schedule that will lead to
Implementation. -
The lead pianni ’ g agency i v usually
charged with obtaining the various
commitments. This requirem
1. Identifying aflremazning actions and the
agency or o nial responsible for each action.
2. Consulting with each agency or
to establish the date by when the action will
be taken.
The product of these eflorte should be
submitted in the SIP In a form aimi1a to the
following example.
Example - -.
The MPO for an urban area has adopted
for inclusion in the SIP a bueway that will
connect a suburban residential area with the
central business district Operation of the
• busway will require the purchase of 25 flew
buses. Corridor location studies have been
completed and final design is underway. The
provision in the 1982 SIP submittal should
Include an approximate schedule similar to -
that outlined below far completion of the
project --
1. MPO places project in annual element of
the STh each funding agency prepares budget
requests for nece ssaiy funds—Complete.
2. Transit operating agency adopts project
as part of capital program.-.Coznplete.
3. TransIt operating agency or appropriate
project sponsor solicits approval of local
government share of project costs from the
city and county councils—Fall 1982. -
- 4. Transit operating agency submits project
application to state department of
transportation—Winter 1982. - -
5. State department of transportation
requests state legislature to appropriate state -_
share of matching funds—Spring 1983.
6. Transit operating agency submits a grant
application to UMTA (submittal occurs If the
funding match has been approved: If the
• project is delayed at this point, contingency
- provisions will be adcpted)—Sumrner 1983.
• (Checkpoint project receives approval
from UMTA)-Spring 1 .984.
7. Transit operating agency places order for
new buses—Spczrg 1964.
8. State department of tra .nsp rtatioa starts
construction cant-act for buaway—Winter -
- . -
9. Agreement with state and local - -
enforcement authorities is signed —Sprtxrg
1988. - -. -
(Checkpoint Buses delivered and
construction completed)—Summer 1986.
10. Transit operating agency Initiates - -
operation—Summer 1986, - - - -
Justiflcotion for not Adopthig a Section lOsij?
- - - -
Justification should include:- - - - - - -
iD entation of as iality.bealth.
welfare, economic. energy, social and - -
mobility effects of the measure, as -
appropriate fat tht type of measure and the
scale of application. ‘ - - -
2. Documentation that the measure was
considered in a process that involved the
public and state and local oEdels.
3. Determination that implementation of the
measure results in substantial and long-term
adverse impacts. - • -
4. Demonstration that the air quality -
standards can be expeditiously attained
without the measure.
Monitoring Pica
The monitoring plan to be contained in the
1982 SIP should be designed for periodically -
assessing the extent to which transportation
measures, either individually or packaged.
are resulting in projected emission reductions
end thereasona for any shortfalls In
ieducttons. The monitoring plan need not
cover air quality monitoring. The plan should
contain methods for determining the reasons
for success or failure of the emission
reduction achievements of the transportation -
measures contained In the 1982 SIP. The
monitoring plan should depend upon existing
data. regularly collected data, surrogate
emission indicators (such as the number of
auto trips, tip speeds. etc.) and
approximation techniques. Collection of new
data should be minin.iaad .
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719Z Federal Resister I ‘Vol. 46, No. 14/ Thursday, January 22. 1981 / Rules and Regulations
Cantfrtgency Plan
The contingency provision is needed In the
event that EPA calls for a S revision based
an its determination that the reasonable
further progress schedule Is not being met.
The contingency provision contains two
parts. The first part is only for areas over -
200.000 population. For these areas, the
contingency prui.isiou iliould include a• -
locally developed list of projects which
imp!em ling agen c ies have agreed can be
delayed during an iflterim penod while the,
S is being revised. The second part of the
cautingen,cy provision Is a description of a
process for deterr in ng additional -
transportation measures beneficial to air
quality that can be implemented to
compensate for rmantidpated shortfalls In
emission reductions or can be accelerated to
replace adopted measures that are not
proceeding on schedule. This second part of
the coirthigency pmvmicn shOuld be incLuded
In every 19 SU submittaL -
Appendix D—Summazy of M ”r ” Level flI
Data Requirements for 29 Ozone Modeling
Sub mi ‘ ,.
Ass Rqufr*nmnts -
1. Spatial Reeohticrr. County-wide- ___
omission inventories foe VOCs end nitrogen
ax des LNOZ) are needed far a Level ifi
-
TempwulResolution. Typical sumner
wnshday emission es *t*s are required as
p ertoftheLeelmdatesubmittsl. -
Preparation of these estinatss is described in
the p Luvcoo y
?men sf -th. O e SIPs.
3. VCC Categories. C__i tion Into
rea e species of VOC. is not re r d farm
Le I1I IL
t sa e C, 7; Pm ’ It is
neen*sz.7 to separate the -
esr! ’ -!a according to rnajar source - -
cachasisdescribedinthe
g ’4deliue.Eo’zissiaa bvyiiequnemants
frr the Z , Ozone S This dlu egaticn
of estimates zsuseM far
of future e egaEed emissions.
fr Quality Data Raç - - ‘ - ; -:
I. Ozone MUzftom (3 sits.). Ozone
monitors should be located at (a) one upwind
sIt (b) one downwind site at the edge of the
urbanized area, and (cJ one downwind sIte
*ppreaimatsly i 0 kilcst*rs from the
- =ha In,d area.
2. 271C/CR. NO 1 , Monitory (1 site requize&
2 51t* desirable). Guidance presented to
EPA—4 !4—eo-o1i.
Cdhectkn of Ambi*nt ?JMOC Data for Use in
z az O’ tp e SIP DeveJopment and Network
Design cnASitin Czite4ofotheNMOCand
NO, Monito1Z should be followe&
3. Upwind Precursor Data. Optional-air
quality data for Level llI are measurements of
ambleut NO, and THC/CH. it one. site
upwind of an urbanized area. These data are
generally unnecessary and are needed oily
fea umisna1 cases when itis desirable to take
explicit a imt of transported pre son in -‘
the analysis. Most studits have bdi .ted that
transported ozone is of greeter significance -‘
tha* transported pre irsans in contributing to
es p b1. Because of thelsek of
precision associated with nournethane
hydrocarbon (NMHC) estimates from
continuous THC/CH 4 monitors at low
concentrations, use of these Inithiments at
upwind sites Is not recommended. It is.
preferable to collect a limited number of grab
samples, analyze these chroniatographically.
and sum species to estimate upwind NMHC.
Guidance presented in EPA-450/4-80-008.
Guidance for the Collection and Use of
Ambient Hydrocarbon Species Data in the
Development of Ozone Control Strategies,
should be followed. Continuous measurement
• of NO! NO, is appropriate.
C Me!aorologjcoJ Dala Reqrrfremeois
1. L pperAir and Swface Tempemture
- Data. Estimates of the morning (&O0 a.rn.l
• and maaimum ‘afternoon mbdng heights are -
required. Preferably. estimates should be
obtained using the nearest National Weather
Service radioaonde data [ if available) In -.
con mcUon with hourly urban surface - -
temperature data. If nadiosoode data are not
available. mthnlog and afternoon mixing -
heights can be estimated using AP-lol.
• “Mining Heights. Wind Speeds and Potential -
for Urban / Pollution gh i j
Contiguous United States.”
2. Sorfoce Wind Data. Surface wind data at
two sites (out site located lii an area of high
peecu.’sor emissions and another outside the
urban core) are required. The wind data are
used to help ensur, that the recorded design
value Is measured downwind of the city.
Appendix B—Regional O5ce Lecatlons of -
Comments and Responses on the Proposed
l9eZSIPPoIIcy - - -
The locations and timss for re w of thi
comments on th proposed 1982 SIP policy-
and EPA responses may be det r th .ed by -
- ccntscfing the following: - •‘ , -
Harley F. T -ikg . ieL Air Programs BreAch.
- EPA—Region I. John P. Xounedy Pede .-al -
Boston. MA 0 ’ 1 . 617-223-e883 -
Bill Baker ief. Air Programs Branch.
EPA—Region ll, 25 Federal Plaza, New
York. NY 1007.312-254-2517
Raymond Cm ,ii h.m . ieL Air Programs
- Branch. EPA—RegionlU. Czrtis Building.
8th & Walnut Streets, Philadelphia. PA -
iaioe. nss —at ’s -. . -.
Winston Smith, ief Air Programs Branch,
EPA—Region IV. 345 Courtland Street.
N.E.. Att ts . GA 30308.404-881-3043
Steve Rothblatt. CsieI. Air Programs Branch.
WA—Region V.250 South Dearborn Street
Od . qa , U. 80604, 312-353-6030
lack Divita. ChIeL Atr Programs Branch.,, --
EPA—Region VI. First International
3. .4h4 nj 1201 Elm S eet, Dallas, Th7sv0,
314-767-3742 -
Art Spratlis. Chief. Air Programs Branch.
EPA—Region VD 324 East Elevethh Street.
Kansas City. MO 84108.816-374-3791
R beit DeSpam. Chief. Air Programs Branch. -
EPA—Region VIII. 1860 LIncoln Street. . -
Denver, CO 80298.303-837-3411.
David Howekamp. Chief. Air Programs -. -
- Branch, EPA-Region DL 313 Premont —
Street. Saizjrancisco, CA 94108,415-556— -
4706 . - - .
Richard mli i. Chief. Air Programs Branch. -
EPA—Region I C. 1200 6th Avenue. Seattis,
WA 98101.206-442-1230 - -
RD c. n- P d r-m-.u era - -
Inuwa coos ra
173
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Memorandum,
“Criteria for Approval of 1979
SIP Revisions”
174
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S14 .
I T UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
_____ WASHINGTON. D.C. 20460
‘ :4
OFFICE OF
AIR AND WASTE MANAGEMENT
FEB 24 1978
SUBJECT: Criteria for Approval of ift 9 IP Revisions
PROM: The Administrator (A-lOQ) 1
TO: Regional Administrators, I-X
The attachment to this memo summarizes the elements
which a 1979 State Implementaticn Plaii (SIP) revision
for a non-attainment area must contain in order to be
approved by EPA as meeting the requirements of Part D of
the Clean Air Act.
In su n nary, the Act requires the demonstration of
attainment of the air quality standards (primary and
secondary) as expeditiously as practicable, but in the
case of national primary standards not later than
December 31, -1982. However, for carbon monoxide (CO) and
oxidants (Ox), if the State can demonstrate attainment
is not possible by 1982 despite the implementation. of all
reasonable stationary source and. transportation control
measures, the Act provides for up to a five-year extension.
In those cases the plan revisions must demonstrate
attainment as expeditiously as practicable but no later
than December 31, 1987. The extension is not automatic;
a demonstration of need must be made and the State must
fulfill the other statutory requirements.
It is the intent of the Agency to establish reasonable
and achievable goals for SIP submissions and to take a firm
posture on the imposition of sanctions where the reasonable
- goals are not achieved. Accordingly, while the policy
requires a commitment to many specific strategies in the
1979 submissions (e.g.,.RACT on stationary sources, inspec-
tion/maintenance programs where attainment for carbon
monoxide or oxidants extends beyond 1982, other reasonable
transportation control measures, etc.) the memo also
requires (for carbon monoxide and oxidants) a commitment
to a continuing process. This process must be one which
extensively involves the public as well as State and local
elected officials and which ambitiously pursues a wide
range of alternatives. -
175
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Since reliance on stationary controls and Federal
new car standards alone will not enable most areas with
oxidant and carbon monoxide problems to attain these
standards by 1982, each Regional Office will need to put
particular emphasis on additional measures to reduce
transportation system emissions. The process committed
to in the 1979 plan submission must lead to the
expeditious selection and implementation of comprehensive
transportation control measures. In judging the adequacy
of the 1979 plan submission for the transportation
sector, each Regional Administrator should ensure that
ambitious alternatives (as described in the draft
“Transportation Planning Guidelines” which have been
circulated) will be analyzed.
The Department of Transportation (DOT), Housing and
Urban Development (HUD) and EPA are seeking to integrate
the transportation/air quality planning and. implementation
required by the Clean Air Act into existing planning and
programming procedures. The air planning activities should
be included in the Unified Work Program required by DOT
and the adopted transportation measures should be included
in the Transportation Improvement Program required by DOT.
In complying with the Clean Air Act requirements, the Regions
should also keep in mind the requirements of the HUD-EPA
Agreement which provides for coordination of air quality
planning and planning assisted under the HUD Comprehensive
Planning Assistance (701) Program. Integrat±on of air
and transportation planning with comprehensive planning
which incorporates growth management concerns should improve
the effectiveness of air quality planning and could reduce
the need for enforcement measures in the future.
States will be provided some discretion regarding
the amount of emissions growth to be accommodated within
the SIP. EPA generally will not question the growth rates
desired by the State so long as reasonable further progress
is demonstrated and there is a demonstration of attainment
by the statutory deadline (1982 or 1987). However, the
growth rate identified in the SIP must be consistent with
growth rates used (or implied by) other planning programs
in the area (e.g., FWPCA 2O8, 201, HUD §701, FHWA
§134).
176
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You should note that there are other SIP revisions
which are not discussed in the attachment but which are
required by the 1977 Amendments. These include:
1.. Section 128 (relating to State boards)
2. Section 126 (relating to interstate pollution)
3. Section 127 (relating to public notification)
4. Part C (relating to prevention of significant
- deterioration)
5. Section 110(a)(2)(K) (relating to permit fees)
6. Section 123-(relating to stack heights for
existing source in other than non-attainment
areas)
7. Section 121 (relating to consultation)
Although incorporation of these provisions is required
by the law, failure to achieve final approval by
July 1, 1979 does not trigger the new source prohibition
of Section 110(a) (2) (I).
It is important to emphasize to the States that all
current SIP requirements remain in effect despite the
development of the 1979 revision3. Any suspension or
discontinuance of an existing SIP provision must be
submitted for EPA approval. This should be done as part
of the revision submitted in January 1979. Exceptions
to this procedure may be found in certain new provisions
of §110 relating to reduction of on-street parking, bridge
tolls, and other measures.
The development of the January 1979 SIPs to meet the
minimum requirements of the Clean Air Act Amendments of
1971 is a complex and demanding program. It will require
the commitment of significant resources on the part of the
air programs staff of the Regional Office to ensure that
the States develop and submit a comprehensive and
approvable plan. We are working with your staff to develop
the necessary guidance and follow-up programs which will
assist your office and the State to carry out this very
difficult but important part of the overall air program.
177
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Att achment
cc: Air Hazardous Division Directors
Air Branch Chiefs
178
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Criteria for Approval of 1979 State implementation Plan Revisions
for Non-Attainment Areas
Purpose
The purpose of this document is to define the criteria by which
State Implementation Plan (SIP) revisions for non-attainment areas
required by the Clean Air Act Amendments of 1977 (the Act) will be
approved. These revisions are to be submitted to EPA by January 1, 1979.
Categories of SIP Revisions
SIP revisions submitted by January 1, 1979 can be divided into
two categories:
1. Those which provide for attainment of the Primary Ambient
Mr Quality Standards (primary standards) for all criteria pollutants
on or before December 31, 1982.
2; Those which provide for attainment of the primary standards
for sulfur dioxide, nitrogen oxides, and particulate matter on or before
December 31, 1982 but show that despite the implementation of all
reasonable transportation and stationary source emission control measures
attainment of the primary standards for carbon monoxide and/or oxidants
cannot be achieved until after this date. In these cases, the revisions
must demorstrate attainment as expeditiously as practicable but no later
than December 31, 1987.
In order for an adequate SIP revision to fall into the second
category, the State has an affirmative responsibility to demonstrate
to the satisfaction of EPA that attainment of the primary carbon
ir r oxide and/or oxidants standards is not pesible in an area prior
t December 31, 1982.
It should be noted that SIP revisions of either category should
also provide for attainment of Secondary Ambient Air Quality Standards
(secondary standards) as expeditiously as practicable although there is
no specific deadline contained in the Act.
General Requirements of All 1979 SIP Revisions
Each 1979 SIP revision must contain the following:
1. A definition of the geographic areas for which control
strategies have been or will be developed. Consideration should be
given to the practical benefits of defining areas which correspond
whenever possible to those substate districts established pursuant
to Part IV, Attachment A of 0MB Circular No. A-95.
179
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2. An accurate, comprehensive, and current (1977 calendar year)
inventory of existing emissions.
3. A determination of the level of control needed to demonstrate
attainment by 1982 (including growth). This demonstration should be
made by the application of modeling techniques as set forth in EPA’s
Guideline on Air Quality Models. For oxidants, any legitimate modeling
technique (e.g., those referenced in “Use, Limitation and Technical
Basis of Procedures for Quantifying Relationships Between Photochemical
Oxidants and Precursors.” EPA 450/2-77—021a. November 1977) can be
used. Consideration of background and transport for oxidants should
generally be in accordance with the procedures documented in “Procedures
for Quantifying Relationships Between Photochernical Oxidants and
Precursors.” In developing photochemical oxidant control strategies
for a particular area, states may assume at a minimum that the standard
will be attained in adjacent states.
If a state can demonstrate that the level of control necessary for
attainment of the primary standards for carbon monoxide and/or oxidant
is not possible by 1982 despite the application of all reasonable
measures, an extension past 1982 (but not beyond 19 7J is authorized.
4.. Adoption in legally enforceable form l of all measures necessary
to provide for attainment by the prescribed date or, where adoption of
a11 such measures-by 1979 is not possible, (e.g., certain transportation
control measures, and certain measures to control the oxides of nitrogen
and total suspended particulate) a schedule for expeditious development,
adoption, submittal, and implementation of these measures. The
situations in which adoption f rne sures may be scheduled after 1979
are discussed in the pollutant specific sections of this document. Each
schedule must provide for implementation of all reasonably available
control measures as expeditiously as practicable. During the period
prior to attainment, these measures must be implemented rapidly enough
to provide at a minimum for reasonable further progress (see discussion
1 Written evidence that the State, the general purpose local
government or governments, or a regional agency designated by general
purpose local governments for such purpose, have adopted by statute,
regulation, ordinance or other legally enforceable document, the
necessary requirements and schedules and timetables for compliance,
and are cornitted to implement and enforce the appropriate elements
of the plan. The relevant organizations shall provide evidence that
the legally enforceable attainment measures and the “criteria,
standards and implementing procedures necessary for effectively guiding
and controlling major decisions as to where growth shall and shall not
take pi ce,” prepared by State and local governments in compliance with
Section 701 of the Housing Act of 1954, as amended, are fully coordinated
in the attainment and maintenance of the NAAOS.
180
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below). Each schedule will be considered part of the applicable
implementation plan and thus will represent a commitment on the part
of the State to meet the key milestones set forth in the submitted
schedule.
5. Emission reduction estimates for each adopted or scheduled
control measure or for related groups of control measures where
estimates for individual measures are impractical. It is recognized
that reduction estimates may change as measures are more fully
analyzed and implemented. As such estimates change, appropriate
responses will be required to insure that the plan remains adequate
to provide for attainment and for reasonable further progress.
6.- Provision for reasonable further progress toward attainment
of the primary and secondary standards in the period prior to the
prescribed date for attainment. Reasonable further progress is defined
as annual incremental redu;tions in total emissions (emissions from
new as well as existing sources) to provide for attainment by the
prescribed date. The plan shall provide for substantial reductions in
the early years with regular reductions thereafter.
Reasonable further progress will be determined for each area
by dividing the total emission reductions required to attain the appli-
cable standard by the number of years between 1979 and the date pro-
jected for attainment (not later than 1987). This is represented
graphically by a straight line drawn from the emissions inventory sub-
mitted in 1979 to the allowable an issions on the attainment date.
However, EPA recognizes that some measures cannot result in imediate
emission reduction. Therefore, if a State can show that some lag in
emissions reduction is necessary, a SIP will be acceptable even though
reductions sufficient to produce decreases at the “straight-line rate”
are not achieved for a year or two after 1979. This lag in achieving
the straight—line rate” for emissions reduction is to be accepted
only to accorrinodate the time required for compliance with the first set
of regulations adopted on or before January 1, 1979, if rmediate
compliance is not possible. It does not authorize delays in adoption
of control requirements.
The requirement to demonstrate reasonable further progress will,
in most areas designated non—attainment for oxidant or carbon monoxide,
necessitate acontinuous, phased implementation of transportation
control measures. In areas where attainment of all primary ambient
standards by 1982 is not possible EPA will not accept mere reliance on
the Federal Motor Vehicle Control Program by itself as a demonstration
of reasonable further progress.
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In determining “reasonable further progress”, those emission
reductions obtained from compliance between August 7, 1977, and
December 31, 1979, with (1) SIP revisions that have been submitted
after August 7, 1977, and (2) regulations which were approved by the
Agency prior to the enactment of the 1977 Clean Air Amendments, can
be treated as having been achieved during 1979. There should be an
assurance 1 however, that these are real emission reductions and not
just “paper” ones.
7. An identification and quantification of an emissions growth
increment which will be allowed to result from the construction and
operation of major new or modified stationary sources within the area
for which the plan has been developed. Alternatively, an emissions
offset regulation can be adopted to provide for major new source growth.
The growth rates established by states for mobile sources and new
minor stationary sources should also be specified, and in combination
with the growth associated with major new or modified stationary sources
will be accepted so long as they do not jeopardize the reasonable further
progress test and attainment by the prescribed date. However, the growth
rate identified in the SIP must be. consistent with the growth rates used
(or implied by) the other planning programs in the area (e.g., FWPCA
Section 208 [ 201), MUD Section 701, FHWA Section 134). A system for
monitoring the emission growth rates from major and minor new stationary
sources and from transportation sources and assuring that they do not
exceed the specified amounts must also be provided far in the revision.
8. Provision for annual reporting on the progress toward meeting
the schedules sumarized in (4) above as well as growth of mobile
sources, minor new stationary sources, major new or modified stationary
sources, and reduction in emissions from existing sources to provide for
reasonable further progress as in (6) above. This should include an
updated emission inventory.
9. A requirement that permits be issued for the construction and
operation of new or modified major sources in accordance with Section
173 and ll0(a)(2)(D).
10. An identification 0 f and com nitment to the financial and
manpower resources necessary to carry out the plan. The corr itment
should be made at the highest executive level having responsiblity for
SIP or that portion of it and having authority to hire new employees.
This corr itment should include written evidence that the State, the
general purpose local government or governments, and all state, local or
regional agencies have included appropriate provision in their respective
budgets and intend to continue to do so in future years for which budgets
have not yet been finalized, to the extent necessary.
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11. Evidence of public, local government, and state legislative
involvement and consultation. It shall also include an identification
and brief analysis of the air quality, health, welfare, economic,
ea ergy, and social effects of the plan revisions and of the alternatives
considered by the State, and a •summary of th public ccn nent on such
an lysi s.
12. Evidence that the SIP was adopted by the state after reasonable
notice and public hearing.
Additional Requirements for Carbon Monoxide and Oxidant SIP Revisions
,hich Provide for Attainment of the Primary Standards Later than 1982
For those SIP revisions which demonstrate that attainment of the
primary standards for carbon monoxide and/or oxidants is not possible
In an area prior to December 31, 1982 despite the implementation of all
reasonable emission control measures the following items must be
iRciuded in the January 1, 1979 submission in addition to all the
9eneral recuirements listed above :
1. A program which requires prior to issuance of any permit for
construction or modification of a major emitting facility an analysis
of alternative sites, sizes, production processes, and environmental
control techniques for such proposed source which demonstrates that
benefits of the proposed source significantly outweigh the environmental
and social cost imposed as a result of its location, construction, or
modification.
2. An inspection/maintenance program or a schedule endorsed by
and co m itted to by the Governor for the development, adoption, and
implementation of such a program as expeditiously as practicable.
Where the necessary legal authority does not currently exist, it must
be obtained by June 30, 1979. Limited exceptions to the requirement
to obtain legal authority by June 30, 1979 may be possible if the state
can demonstrate that (a) there was insufficient opportunity to conduct
necessary technical analyses and/or (b) the legislature has had no
opportunity to consider any necessary enabling legislation for inspection!
maintenance between enactment of the 1977 Amendements to the Act and
June 30, 1979. In addition, where a legislature has adequate opportunity
to adopt enabling legislation before January 1, 1979, the Regional
Administrator should require submission of such legal authority by
January 1, 1979. In no case can the schedule submitted provide for
obtaining legal authority later than July 1, 1980.
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Actual implementation of the inspection/maintenance program must
proceed as expeditiously as practicable. EPA considers two and one half
years from the time of legislative adoption to be the maximum time
required to implement a centralized inspection/maintenance program and
one and one haif years to implement a decentralized program. In no case
may implementation of the program, i.e., mandatory inspaction and
; d tory repair of failed vehicles be delayed beyond 1982 in the case
of a centralized program (either state lanes or contractor lanes) or
beyond 1981 in the case of a decentralized (private garage) system.
3. A commitment by the responsible government official or
officials to establish, expand, or improve public transportation
rneasuresto meet basic transportation needs as expeditiously as is
practicable.
4. A commitment to use insofar as is necessary Federal grants,
state or local funds, or any combination of such grants and funds as
n ay be consistent with the terms of the legislation providing such
grants and funds, for the purpose of establishing, expanding or
improving public transportation measures to meet basic transportation
needs.
Note that HUD has prepared jide1ir s for local development codes
and ordinances to provide special requirements for areas which for
significant periods of time may exceed the primary standards. These
guidelines specify criteria for new construction operation of buildings
which minimize pollutant concentrations to ensure a healthy indoor and
outdoor environment. States are er.:;uraged to adopt such measures as
part of the SIP.
Pollutant specific Require iients
Sulfur Dioxide
Specifically, with regard to item (4) of the General Requirements,
the January 1979 plan revisions dealing with sulfur dioxide must contain
all the necessary emission limitations and legally enforceable procedures
t provide for attainment by no later than December 31, 1982 (i.e.,
schedules for the development, adoption, and submittal of regulations
will not be acceptable).
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Nitrogen Oxides
For NOx, the January 1979 plan must contain all the necessary
emission limitations and the legally enforceable procedures, or as a
minimum, the appropriate schedules to adopt and submit the emission
limitations and legally enforceable procedures which provide for
implementation so that standards will be attained by no later than
December 31, 1982. EPA Is currently evaluating the need f3r a short
term NO 2 standard and expects to promulgate such a standard during
1978. If such a standard for air quality is promulgated, a new and
separate SIP revision will be required for this pollutant.
Particulate Matter
The. January 1979 plan revisions dealing with particulate matter
must contain all the necessary emission limitations and legally enforce-
able procedures for traditional sources. These emission limitations and
enfcrceable procedures must provide for the control of fugitive
emissions, where necessary as well as stack emissions from these
stationary sources. Where control of non—traditional sources (e.g.,
ui ban fuaitive dust, resuspension, construction, etc.) is necessary for
attainment, the plan shall contain an assessment of the impact of these
sources and a comitnent on the part of the state to adopt appropriate
control measures. This con nitment shall take the form of a schedule to
deveic , submit, and implement the legally enforceable procedures, and
programs for controlling non—traditional particulate matter sources.
These schedules n ust include milestones for evaluating progress and
pr vide for attainment of the primary standards by no later than
De: e 31, 1982, and attainment of the secondary standards as expe-
di ic sly as practicable. States should initiate the necessary studies
and demonstration projects for controlling the non—traditional sources
as soon as possible.
Carbon Monoxide and Oxidant
An adequate SIP for oxidant is one which provides for sufficient
control of volatile organic compounds (VOC) from stationary and mobile
sources to provide for attainment of the oxidant standard. Accordingly,
the 1979 plan revision nnist set forth the necessary emission limitations
and schedules to obtain sufficient control of VOC emissions in all non-
attainment areas. Theymust be directed toward reducing the peak
concentrations within the major urbanized areas to demonstrate attainment
as expeditiously as practicable but in no case later than December 31, 1987.
This should also solve the rural oxidant problem by minimizing VOC
emissions and more Importantly oxidants that may be transported from
urban to rural areas. The 1979 submission must represent a comprehensive
strategy or plan for each non-attainment area; plan submissions that
address only selected portions of non—attainment are not adequate.
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For the purpose of oxidant plan development, major urban areas are
those with an urbanized population of 200,000 or greater (U.S. Bureau
of Census, 1970). A certain degree of flexibility will be allowed in
defining the specific boundaries of the urban area.. However, the areas
must be large enough to cover the entire urbanized 2 area and adjacent
fringe areas of development. For non—attainment urban areas, the highest
pollutant concentration for the entire area must be used in determining
the necessary level of control. Additionally, uniform modeling tech-
niques must be used throughout the non—attainment urban area. These
requirements apply to interstate as well as intrastate areas.
Adequate plans must provide for the adoption of reasonably
available control measures for stationary and mobile sources.
For stationary sources, the 1979 oxidant plan submissions for
major urban areas must include, as a minimum, legally enforceable
regulations to reflect the application of reasonably available control
technology (RACT) 3 to those stationary sources for which EPA has
published a Control Techniques Guideline (CTG) by January 1978, and
provide for the adoption and -submittal of additional legally enforce-
abl.e RACT regulations on an annual basis beginning in January 1980, for
those CTGs that have been published by January of the preceeding year.
For rural non-attainment areas, the Ox plan must provide the
necessary legally enforceable procedures for the control of large HC
sources (more than 100 ton/year potential e nissions) for which EPA
•has issued a CTG by January 1978, and to adopt and submit additional
legally enforceable procedures on an annual basis beginning in
January 1980, after publication of subsequent CTGs as set forth above.
For mobile sources in urbantzed area (population 200,000) SIPs
must provide for expeditious imp1e entation of reasonably available
control measures. Each of the measures for which EPA will publish
information documents during 1978 is a reasonably available control
measure. These measures are listed on the following page:
2 As defined by the U.S. Bureau of Census, urbanized area generally
include core cities plus any closely settled suburban areas.
3 Whtle it is recognized that RACT will be determined on a case-by--
case basis, the criteria for SIP approval rely heavily upon the
information contained in the CTG. Deviations from the use of the CTG
must be adequately documented.
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1. To be published by February 1978
a. inspection/maintenance
b. vapor recovery
c. improved public transit
d. exclusive bus and carpool lanes
e. area wide carpool programs
2. To be published by August 1978
a. private car restrictions
b. long range transit improvements
c. on street parking controls
d. park and ride and fringe parking lots
e. pedestrian malls
f employer programs to encourage car and van pooling,
mass transit, bicycling and walking
g. bicycle lanes and storage facilities
h. staggered work jours
I. road pricing to discourage single occupancy auto trips
j. controls on extended vehicle idling
k. traffic flow improvements
1. alternative fuels or engines and other fleet
vehicle controls
m. other than light duty vehicle retrofit
n. extreme cold start emission reduction programs
The above measures (either individually or combined into packages
of measures) should be analyzed promptly and thoroughly and scheduled
for expeditious implementation. EPA recognizes that not all analyses
of every measure can be completed by January 1979 and, where necessary,
schedules may provide for the completion of analyses after January 1,
1979 as discussed below. (If analysis after January 1979 demonstrates
that certain measures would be unnecessary or ineffective, a decision
not to implement such measures may be justifiable. However, decisions
not to implement measures will have to be carefully reviewed to avoid
broad rejections of measures based on conclusory assertions of
infeasibility.)
As described previously, annual incremental reductions in total
emissions must occur in order to achieve reasonable further progress
during the period prior toattainment of the standards. Therefore,
not all transportation measure implementation activities should wait
until the comprehensive analyses of control measures are completed.
Demonstration studies are important and should accompany or precede
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full scale implementation of the comprehensive strategy. It is EPA ’s
policy that each area will be required to schedule a representative
selection of reasonable transportation measures (as listed above) fdr
implementation at least on a pilot or demonstration basis prior to the
end of 1980.
Every effort must be made to integrate the air quality related
transportation plan and implementation required by the Clean Air Act
into planning and programming prácedures administered by DOT. EPA will
publish “Transportation Planning Guidelines” which will, if followed
carefully, insure that an adequate transportation planning process
exists.
EPA recognizes that the planning and implementation of ver3’
extensive air quality related transportation measures can be a complicated
and lengthy process, and in areas with severe carbon monoxide or oxidant
problems, completion of some of the adopted measures may extend beyond
1982. Implementation of even these very extensive transportation
measures, however, must be initiated before December31 1 1982.
In the case of plan revisions that make the requisite showing to
justify an extension of the date for attainment, the portion of the 1979
plan submittal for transportation measures must:
1. Contain procedures and criteria adopted into the SIP by which
• it can be determined whether the outputs of the DOT Transportation
- planning process conform to the SIP.
2. Provide for the expeditious implementation of currently
planned reasonable transportation control measures. This includes
reasonable but unimplemented transportation measures in existing SIPs
and transportation controls with demonstrable air quality benefits
developed as part of. the transportation process funded by DOT.
3. Present a program for evaluating a range of alternative
packages of transportation options that includes, as a minimum, those
measures listed above for which EPA will develop information documents.
The analyses must identify a package of transportation control measures
to attain the emission reduction target ascribed to it in the SIP.
4. Provide.for the evaluation of long range (post-1982) trans-
portation and growth policies. Alternative growth policies and/or
development patterns must be examined to determine, the potential for
modifying total travel demand; One of the growth alternatives evaluated
should be that prepared in response, to. Section 701 of the Housing Act of
1954, as amended. .
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5. Include a schedule for analysis and adoption of transportation
control measures as expeditiously as practicable. The comprehens-ive
analysis of alternatives (item 2 above) must be completed by July 1980
unless the designated planning agency can demonstrate that analysis
of individual components (e.g., long range transit improvements) may
require additional time. Adopted measures must be implemented as
expeditiously as practicable and on a continuous schedule that demonstrates
reasonable further progress from 1979 to the attainment date. Deter-
minations of the reasonableness of a schedule will be based on the
nature of the existing or planned transport.ation system and the com-
plexity of implementation of an individual measure.
Additional Carbon Monoxide and Oxidant Monitoring Requirements
It is EPA’s policy to require that all SIPs which provide for
attainment of the oxidant standard after December 31, 1982, must con-
tain coninitments to implement a complete oxidant monitoring program in
major urbanized areas in order to adequately characterize the nature
and extent of the problem and to measure the effectiveness of the
control strategy for oxidants. The 1979 plan submittal must provide
for a schedule to conduct such CO monitoring as necessary to correct
a ny deficiencies as identified by the Regional Office.
SIPs for Unclassified Areas Redesignated Non—Attainment
With respect to unclassified areas which are later found to be
non-attainment areas the state will be required to submit a plan
within nine months of the non—attainment determination. During plan
development, the state will be required to implement the offset policy
for that area. However, it should be noted that in many cases, because
of previous plan revisions or adoption 0-f previous control regulations,
the baseline for offsets will be more restrictive and thus offsets may
be more difficult to obtain. For oxidants, state-wide regulatory
develQpment (for at least all sources greater than 100 tons/year),
however, would permit the state to utilize the regulations developed
for the entire state as the applicable plan for the newly designated
non—attainment area. This would normally constitute an approvable SIP
per the above criteria and could essentially accomodate the proposed
growth within the previously submitted state plan and not require
offsets once the area is designated as non-attainment.
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6.0 USEFUL REFERENCES
*1. U.S. Environmental Protection gency,GUide1i forUseofCjty-Specifjc
EKMA in Pr partng Ozone SIPs , PA-45O/4-8a-Q2J, (±i rch 19 81L.
Describes how alT quality, meteorological and emissions data are used to
generate ozone tsopleths in EKMA. Then descrtbes how city-specific EKMA is
used to demonstrate attainment of the ozone NMQS in SIPs.
*2. G. Z. WMtten and. H.-ttogo, i. ’Manual fOrKifletlcs1’ !odel andOzone
• IsoplethPlottjnc Packaqe, t -6OOf3-78-C14a, (.July 19781 .
Describes features of and how data are Input to the OZIPP computer program.
*3 U.S. Environmental Protection P gency, Ozone Isopleth Plotting Package (OZIPP) ,
• EPA-6OO/3-78-Q14t , G u1y 1Sk78)i.
Computer tape of the OZIPP model.
4. U.S. Environmental Protection Agency, iJses, Limitations and Technical
Basjsof Procedures for Quantifying Relationships Between Photochemical
Oxj ants and Precursors , EPA-450/2-77-021a, (November 1977).
Introduction to and conceptual discussion of EKMA.
5. U.S. Enviror.rnental Protection Agency, Procedures for Quantifying Relationships
Between PhotOchei ical Oxidantsand Precursors: SUpporting Documentation ,
EPA—45c•/2.-77-021b, cNovember 1978).
Useful discussion of procedures for estimating NMOC/NO. ratios.
6. T. C. Curran, Guideline for Interoretation of Ozone Air Quality Standard ,
EPA—450/4—79-003, January 1979).
Discussion of the ozone NAAQS and the impii ations resulting from its
statistical form.
7. U.S. Environmental Protection Agency, Guidance for Collection of Ambient
Non-Methane Orcanictompound(NMOC)Data or Use In 19820zone SIP Development,
and Network Design and Sitinq Criteria for the NMOC and NO Nonitors ,
EPA-450/4-80-O11, (June 198O .
General information on use of corrn’ ercia11y available NMOC instruments for
use in ozone SIPs.
8. U.S. Environmental Protection Agency, Final Emission Inventor ’ Requirements
for 1982 Ozone State linpiethentat iOn Plans , EPA-45014-80-016, (Deceither
T98 .
*9 F. W. Sexton, R. A. Michie, Jr., f. F. McElroy, and Y.L. Thompson,
Technical AssistanceDOcUmnentfor the Cal ibration and Qperation of Automated
Ambient Non-Methane Organic Compound Analyzers , EPA
March 19811.
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