¦
CALLS FOR STATE IMPLEMENTATION PLAN (SIP) REVISIONS
TECHNICAL SUPPORT DOCUMENT
VOLUME I
March 9, 1934
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Table of Contents
title Page
1. Preface ii
2. Memorandum—Post 1982 Attainment program—Key Milestones
and Acti vities i i i
3. Memorandum—Cal 1 For State Implementation Plan (SIP) Revisions iv
4. Summary--CalIs for SIP Revision--February 24, 1984 viii
5. Regional Submissions*
Region 1 1-1
Region II 2-1
Region III 3-1
Region IV 4-1
Region V 5-1
Region VI 6-1
Region VII 7-1
Region VIII 8-1
Region IX 9-1
Region X 10-1
* Where applicable, this document supplies the following information for each
State in each Region making a SIP call under Section 110(a)(2)(H).
Areas Not Anticipated to Meet the Requirements of The Clean Air Act
List of Areas With SIP Calls and Areas Without SIP Calls
Abstract of Tier II Areas
Response to Comments
Letters From the Regional Administrators
i
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Preface
This document reports information used by EPA Regional Offices in
determining the need for States to revise their State Implementation Plans
(SIP1s) under Section 110(a)(2)(H). Information is supplied for ozone,
nitrogen oxides, carbon monoxide, and sulfur dioxide. Volume I of this
document identifies both areas with SIP calls and areas without SIP calls.
It contains a description of the factual basis for the calls and copies of
letters notifying the Governors of the need for revisions. Volume I also
includes Regional Office responses to individual comments on the February 3,
1983 FEDERAL REGISTER.
Volume II contains copies of the technical material (SAROAD Data
Compliance Order Agreements, etc.) used by the Regional Offices to determine
the need for a SIP call.
ii
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
JAN 2 7 1984
MEMORANDUM
SUBJECT: Post 1982 Attainment Program--jKey Milest&jaes and Activities
A number of important deadlines dealing with the post 1982 attainment
program are quickly approaching. The purpose of this memorandum is to
delineate how to process actions for nonattainment areas without attain-
ment date extensions and to transmit a sample letter which should assist
you in the preparation of your material. I hope this will provide formal
national consistency and a more efficient use of all our resources. This
memorandum will also mention some of the more pressing deadlines ahead
and CPDD's role in working with you on these.
Calls for SIP Revision
The most efficient way to handle the notices which call for State
Implementation Plan (SIP) revisions under Section 110(a)(2)(H) (which
includes both areas that did not attain and areas which have no approved
Part D SIP) is by formal letters from the Regional Administrators. These
letters should be addressed to the Governors and notify them of the need
for the revision(s). A sample form for the letter is attached.
This Regional action will be followed quickly by a national Federal
Register notice which summarizes all the SIP calls. The national notice
will be completed by CPDD and OGC and will feature a background section
as well as a simple listing of deficiencies by State, area, and NAAQS.
The material for the Federal Register notice which must be prepared by
the Regional Office is limited to a specific description of the boundaries,
the pollutant, and a brief description of the factual basis for the call.
A sample format developed by Region VII is attached. This information (in
this or a similar format) should be provided to us for all Tier II areas
identified on February 3, 1983.
FROM: Darryl D. Tyler, Director^
Control Programs Developmi
TO:
Air and Waste Management Division Director
Regions II-IV, VI-VI11, X
Air Management Division Director
Regions I, V, IX
lit
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2
Calls should be directed only towards Tier II areas that were
identified in the February 3, 1983, Federal Register notice. If a Region
has completed its analysis of 1983 data to a point that it has clearly
identified additional areas which require a SIP revision, the Region has
the option to issue a 110(a)(2)(H) notice to these areas as well. However,
you should be aware that the Agency intends to issue guidance soon on SIP
revisions based on a review of all air quality data collected through the
end of 1983. Hence, we recommend that action on newly identified areas
be deferred until that guidance is prepared. Where a Region adds additional
areas at this time, these additions should be reviewed with my office
prior to issuance of the SIP call to assure national uniformity.
The Agency intends to use the February 3, 1983, Technical Support
Document as the basic foundation for the technical support for this
notice. If the reason for calling for a revision is the same as in that
document, your office need not resubmit it. Where the basis has changed,
we will need new or supplemental material to explain the changes. In
addition, a document containing the Regional Office response to individual
comments on the February 3, 1983, notice should be prepared.
The material for the Federal Register notice (including any additional
technical support material) should be sent to Tom Helms by February 7,
1984. The letters to the States should be sent on February 17, 1984, and a
copy sent to Tom Helms. The national notice will be printed in the
Federal Register in March. Concerns have been expressed that the Federal
Register notice not lag behind the mailing of the letters by more than a
few weeks so it is very important that your material be submitted to us
by the deadlines. We will not hold the notice for Regions which cannot
meet these dates. Rather, if for any reason the deadlines are missed,
Regions will be responsible for preparing a supplemental Federal Register
notice announcing their SIP calls.
Conditional Approval Actions
The Federal Register notices revoking the nongermane conditions and
setting the new dates for less seriously deficient conditions should be
handled as they have been in the past. You should prepare your individual
notices and put them through the normal SIP review process. These notices
should be at Headquarters by February 17, 1984. We would like a memorandum
(by electronic mail) from you by February 3, 1984, which summarizes the
actions you intend to take on these conditions.
iv
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3
I think that the attached language developed by 06C and CPDD will
help us to approach these Federal Register notices in an efficient manner.
Please do not hesitate to have your staffcontact Tom Helms or John Calcagni
if there is anything else that is needed. Thank you for your excellent
cooperation in this important program.
Attachments
cc Air Branch Chief, Regions I-X
v
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V*.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
February 23, 1984
MEMORANDUM
SUBJECT: Calls for State Implementa
FROM: Darryl D. Tyler, Director
Control Programs Developme
Revi si ons
TO: Joseph A. Cannon, Assistant Administrator
For Air and Radiation (ANR-443)
Letters from the Regional Administrators to the Governors will be
sent tomorrow calling for 27 SIP revisions. Calls are being made in six
Regions for 15 States. Four Regional Offices had no calls. Two-thirds
of the calls (18) are for ozone. There will be six calls for carbon
monoxide, two for sulfur dioxide, and one for nitrogen dioxide. As you
know, we are deferring action on particulates for the moment. All of the
decisions on the calls were coordinated quite closely with the Regional
Offices.
On February 3, 1983, the Agency listed 148 areas not anticipated to
meet the requirements of Part D of the Clean Air Act (Tier II list). For
the moment we are deferring action on particulates which account for 72
areas that were on the Tier II list. Of the remaining 76 areas for the
other four pollutants (SO2, CO, O3, and N0X) 17 were on Tier II solely
because of unmet conditions. Conditions are being handled separately
from the calls for revisions by the individual Regions and should be
addressed by May. Calls for revisions are being made tomorrow for 27
of the remaining 59 areas. We have determined that calls are not appro-
priate for the remaining 32 areas at this time. Our bases for this are
generally more recent data or the receipt of subsequent State submittals.
In addition, the Agency will review air quality data for all areas this
summer and additional calls for revisions could come at that time.
I am attaching a chart which lists all of the calls by State and
Region and gives a brief description of the reason for the call. I am
also attaching a copy of the example letter to the Governors which was
sent to the Regional Offices for their use. The Regional Offices tailored
this letter for their specific needs.
The Regional Offices, the Headquarters Press Offices, and the Congressional
Affairs Offices have all been informed of these letters. We do not plan
to issue press releases but do want to inform these offices so they can
be responsive to inquiries.
vi
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2
Please call me if you need additional information on the calls.
Attachments
cc: Chief, Air Branch, Regions I-X
B. Bankoff
S. Meiberg
B. Pedersen
S. Meyers
S. Schulhof
0. O'Connor
T. Kaneen
D. Frantz
C. Rice
vii
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Calls For SIP Revision—February 24, 1984
Region
State
Area
Pollutant
Reason for Call
III
PA
Warren Co.
so2
Failure to submit
Scranton/Wilkes
Barre
03
Violations of standard in
Scranton 81-82
IV
AL
Jefferson Co.
03
Monitored violations 81-83
FL
Dade Co.
03
Monitored violations 81-82
Broward Co.
O3
Monitored violations 81-82
Palm Beach Co.
03
Monitored violations 81-82
GA
Atlanta metro-
politan area
03
Monitored violations 81-82
V
IN
Marion Co.
CO
Monitored violations 81-83
Wayne Co.
S02
Failure to submit
St. Joseph Co.
03
Failure to submit RACT
Elkhart Co.
O3
Failure to submit RACT
MN
Ramsey Co.
CO
Monitored violations 81-83
OH
Portage Co.
03
Monitored violations 81-83
Summit Co.
03
Monitored violations 81-83
VI
L'A
Baton Rouge
03
Monitored violations 83
OK
Tulsa Co.
03
Monitored violations 83
TX
Dallas Co.
03
Monitored violations 83
Tarrant Co.
03
Monitored violations 83
El Paso Co.
03
Monitored violations 83
El Paso Co.
CO
Monitored violations 81-82
VII
KS
Wichita
CO
Monitored violations 81-82
NB
Li ncoln
CO
Monitored violations 82-83;
failure to submit
Omaha
CO
Monitored violations 82;
failure to submit
vi i i
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2
Region
IX
State
AZ
CA
NV
Area
Pollutant Reason for Call
Maricopa Co.
Kern Co.
South Coast
Clark Co.
O3 Monitored violations 82
O3 Monitored violations 82
N0X Monitored violations 81-82
O3 Monitored violations 82-83
ix
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Region I
1-1
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Areas Not Anticipated to Meet
the Requirements of the Clean Air Act
STATE OF HEW HAMPSHIRE
AREA
POLLUTANT
•
UNLIKELY
TO ATTAIN
THE
HAAQS
FAILURE TO
COMPLY WITH
SIP CONDITIONS
FAILURE TO
SUBMIT AM
ADEQUATE SIP
Metropolitan Berlin,
Coos County
TSP
X
Nashua, Hillsborough County
CO
X
X
Mew Hampshire portion
Merrimack Valley
Southern New Hampshire
AQCR (including
Sullivan County, Merrimack
County, Belknap County,
Cheshire County, Hillsborough
County, Strafford County,
and Rockingham County)
03
x
1-2
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Areas With SIP Calls
Areas Without SIP Calls
STATE OF NEW HAMPSHIRE
AREA
POLLUTAH?
Call for
SIP
No Call For
SIP
Metropolitan Berlin,
Coos County
TSP
X
Nashua, Hillsborough County
CO
X
Hev Hampshire portion
Herrimacfc Valley
Southern New Hampshire
AQCR (including
Sullivan County, Merrimack
County, Belknap County,
Cheshire County, Hillsborough
County, Strafford County,
and Rockingham County)
03
X
1-3
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. N"'j i Hampshire
Boundaries: City of Nashua, H11lsborough County.
NH portion of AOCR 121
Pollutant: CO
Brief Description o£ Factual Basis for Call:
A newly designated non-attainment area. Nashua was designated
nonatta inment on April 1 1, 1980. A STP revision was submitted
on November 3, 1981. A proposed approval notice was prepared
by the Regional Office and sent to EPA Washington for
concurrence but the submittal was returned to the State on
March 8, 1983 as inconsistent with EPA policy. The area
needs to submit one SIP (per legal opinion attached) with a
sophisticated CO modeling analysis.
1-4
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Nashua, NH
RO Response to Individual Comments:
Our response to Mr. Esch's comment follows:
One commenter requested that the sanctions should not be
imposed over the entire AQCR.
According to the final Post-82 Attainment Policy <48 FR 50691)
newly designated non-attainment areas now have the time-
intervals established in Part D of the Act to attain the
NAAQS. The policy also allows an additional five years to
attain the ozone and carbon monoxide standards if a justifiable
request is submitted with the SIP.
The SIP Nashua submitted in 1981 included a request for an
additional five years to attain the CO NAAQS. Given the
Part D timetable, the extension to 1990 should be approvable.
Mr. Esch's concern about the breadth of the imposition of the
sanctions (AQCR-wide) was based on a concern that the extension
would not be granted. Since we expect that adequate support
for an extension will be included with the submittal, his
concern is no longer pertinent.
Another commentor asked for a reduction in the size of the
non-attainment area. If this is requested by the State of
New Hampshire with the appropriate documentation, EPA will
evaluate the request on its merits.
1-5
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ST<
O -
\ $ UNITED 8TATE8 ENVIRONMENTAL PROTECTION AGENCY
\ REGION I
J. F KENNEDY FEDERAL BUILDING. BOSTON. MASSACHUSETTS 02203
February 24, 1984
Honorable John H. Sununu
Governor of New Hampshire
State House
Concord, New Hampshire 03301
Dear Governor Sununu:
On November 2, 1983 EPA published the final policy concerning
areas which failed to attain the National Ambient Air Ouality
Standards by the end of 1982. This letter describes the
actions whi'ch you must take to satisfy the requirements of
the Clean Air Act as described in the policy. The two areas
presently subject to the policy are Nashua, for carbon monoxide,
and Berlin, for particulate matter.
The policy establishes a schedule to address "newly-designated"
non-attainment areas such as Nashua. Within sixty days you
must submit a schedule for adoption of an attainment plan for
Nashua. The schedule must result in final submittal of the
plan to me no later than one year from today. If the plan
demonstrates that you cannot attain the CO standard by 1985,
your submittal may request an extension for up to an additional
five years. The plan must contain quantifiable measures with
interim milestones and it must demonstrate attainment as
expeditiously as practicable.
My staff is available to assist you in development of the
schedule and the plan. Until a final plan is approved, the
construction ban in Nashua relating to construction or modifi-
cation of major stationary sources of carbon monoxide will
remain in effect.
In addition, as you know, Berlin has not yet attained the
primary total suspended particulate standards. The draft
attainment plan submitted to us in January is acceptable and
we look forward to its submission soon. I expect that we
will complete rulemaking on the plan by the end of August at
the latest.
1-6
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-2-
We will make additional findings of SIP inadequacy and calls
for revisions :f we receive air quality monitoring data in the
future indicating that other areas of the State covered by
fully or conditionally approved Part D plans continue to
experience NAAOS violations. At present, we are aware of no
such areas.
Please contact me or have your staff contact Harley Laing at
617/223-2226 if you have any questions regarding this letter.
Sincerely,
Michael R. Deland
Regional Administrator
1-7
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Region II
2-1
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Areas Mot Anticipated to Meet
the Requirements of the Clean Air Act
STATE OF NEW YORK
AREA
POLLUTANT
UNLIKELY
TO ATTAIN
THE
NAAQS
FAILURE TO
COMPLY WITH
SIP CONDITIONS
FAILURE TO
SUBMIT AN
ADEQUATE SIP
City
Erie
of Lackawanna,
County
TSP
Z
X*
* Area presently has restrictions on construction or modification of major stationary
sources for failure to submit an adequate SIP. The required 1979 SI? was submitted
but was not approved by CPA because a revised SIP was being prepared by the State.
This revised SIP, which is expected to be received in mid-1983, will reflect recent
emission source shutdowns in this location.
2-2
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Areas With SIP Calls
Areas Without Sip Calls
STATE OP HEW YORK
AREA
City of Lackawanna,
Erie County
Calls
POLLUTANT
2-3
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Region III
3-1
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Areas Not: Anticipated to Meet
the Requirements of the Clean Air Act
COMMONWEALTH OF PENNSYLVANIA
AREA
POLLUTANT
UNLIKELY
TO ATTAIN
THE
NAAQS
FAILURE TO
COMPLY WITH
SIP CONDITIONS
FAILURE TO
SUBMIT SlN
ADEQUATE 31?
Conewango Township,
Warren County
SO 2
X
Allegheny County, area within
a 2-mile radius of the
Hazlewood monitor
so2
X
Allegheny County,
A three-mile strip which is
within a perpendicular
distance two miles north and
east and one-mile south and
west of the Ohio and
Monongahela rivers from the
.1-79 bridge on the Ohio river
to the Westmoreland County
line on the Monongahela river
TSP
X
Sharon,
Mercer County
TSP
X
Scranton, Lackawanna County
X
Wilkes-Barre,
Luzerne County
03
X
3-2
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Areas With SIP Calls
Areas Aithout SIP Calls
COMMONWEALTH OF PENNSYLVANIA
AREA
POLLUTANT
Call For
SIP
No Call For
SIP
Conewango Township,
Warren County
so2
X
Allegheny County, area within
a 2-mile radius of the
Ha2 lewood mom tor
so2
X
Allegheny County,
A three-mile strip which is
within a perpendicular
distance two miles north and
east and one-mile south and
west of the Ohio and
Monongahela rivers from the
.1-79 bridge on the Ohio river
to the Westmoreland County
line on the Monongahela river
TSP
X
Sharon,
Mercer County
TSP
X
Scranton, Lackawanna County
°3
X
WiLkes-Barre,
Luzerne County
°3
X
3-3
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Area Pollutant Reason
Conewango Township SO2 No SIP has been submitted
for the area in the
vicinity of the Warren
Power Plant.
3-4
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Comments
Conevango Township, Warren County - The Commonwea 1 th of
Pennsylvania, Department of Environmental Resources (DER)
submitted comments on May 5, 1983 contending that this area
should be listed as "Likely to Attain the NAAQS" because there
have been no monitored violations. Comments dated March 7,
1983 from Penelec support the Commonwealth's position. EPA
does not agree. A dispersion model for complex terrain
predicts violations of the SO2 NAAQS and was the basis for
the original §107 nonattamment designation.
The Commonwealth also states that a modeling and monitoring
agreement has been reached with the company involved. This
agreement should be submitted as a SIP revision to EPA for
review and approval/disapproval. If the modeling protocol and
monitoring program are acceptable and the SIP revision approved
b • EPA, Warren County would then be considered to have an
adequate SIP.
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Allegheny County, area SO2
within a 2-mile radius
of the Hazelwood Monitor
A designated nonattamment
area which experienced 7
violations of the 24-hour
standard in 1981 and 2
violations in 1982.
3-6
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C jTimsn4;"
Allegheny County, area within a 2 mile radius of the Hazelwood
monitor - The Allegheny County Health Department submitted
comments on March 16, 1983 and June 7, 1983 relative to the
February 3, 1983 Federal Register notice. The Department has
stated that the SIP is not inadequate but rather that the pend-
ing steel stretch-out application from the Jones and Laughlin
Steel Corp. and the company's failure to bring its coke oven
gas desulfurization system into compliance during the applica-
tion pendancy caused the violations of the S0£ NAAQS. EPA
acknowledged the possibility of such problems in the February
3, 1983 notice when it stated "... the extended compliance
dates authorized under the provisions of these statutes (SICEA)
could have a significant effect on the ability of the area to
attain the primary NAAQS". EPA denied J & L's requested
stretch-out application on December 29, 1982.
EPA, Region III and J & L have now completed negotiations
revising the Consent Order requiring that this facility comply
with the appropriate regulations and air quality standards. As
soon as EPA, HQ signs this Consent Order, it will be lodged
with the Court where it will undergo a 30-day comment period
prior to becoming final.
The Consent Order will be foderally enforceable and, upon
completion of the control program, should result in attainment
of the SO2 NAAQS. In light of the above, EPA will take no
further action at this time to require a new SIP to be
submitted.
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Scranton, Lackawanna
Coun ty
Wilkes-Bar re,
Luzerne County
03
03
Data from the National.
Aerometric Data Bank,
Quick Look Report,
1/14/83, reported viola-
tions of the ozone
standard, highest value
was 0.175 ppm (Site
ID# 398040006F01).
3-8
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Comments
Scranton, Lackawanna County and Wilkes Darre, Luzerne County -
Again, comments received from the Commonwealth and local
officials contend that the area should be considered as "Likely
-o Attain" rather than as "Unlikely co Artairi to the S^AAQS"
because only one monitor in the area showed violations in
1982. EPA cannot agree with such a rationale.
Data from the Pennsylvania Air Quality Report provides the
following information:
1980 1981 1982
Site
Site
1st
2nd
Is t
2nd
1st
2nd
Name
Code
High
High
High
High
High
High
Scranton 1
SOI
.155
.151
.118
.104
.175
.158
Wilkes Barre
S21
.124
.115
.093
.093
.124
. 100
Carbondale
S 2 5
.076
.060
.106
.099
.132
.119
Nan ticoke
S 26
-
-
-
-
.125
.098
All readings are in ppm.
1. 14 violations occurred in this monitor in 1980 and 5
v.olations occurred in 1982.
Da^.a from the SAROADS Quick Look Report, 2/3/84, provides the
following information for 19S3:
1st Q
2nd Q
3rd Q
Si te
PA Site
SAROADS
1st
2nd
1st
2nd
1st
2nd
Name
Code
ID No.
High
High
Hi9.h
High
High
High
Scranton
SOI
398Q4QQ05F01
.047
.047
.115
.113
.102
. 100
Wilkes Barre
S21
399430101F01
.057
.049
.135
.130
. 114
. 107
Carbondale
S 2 5
391400100F01
.061
.056
.102
.096
.100
.095
Nanticoke
S 26
39630010 0F01
.051
.048
.120
.103
.096
.096
Ozone is a regionwide problem and the fact that only two of the
four monitors show exceedances does not mean that a re-planning
effort for the entire ares, is not necessary.
An approved SIP, including a VOC emissions reduction and
control program, is in effect. However, it does not appear to
be adequate because violations of the ozone NAAQS are still
being observed. For this reason, EPA has notified the Governor
that a replanning effort must be undertaken.
3-9
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Honorable Picnacd L. Thornburgh
Governor of Pennsylvania
Hamsburg, PA 17120
Dear Governor:
The Environmental Protection Agency (EPA) hereby notifies you
pursuant to Section 110(a)(2)(H) of the Clean Air Act, 42
U.S.C., Section 7410(a)(2)(H) , that it finds the State
Inplenencation Plan (SI?) for tne Commonwealth of Pennsylvania
substantially inadequate to achieve certain primary national
ambient air quality standards (NAAQS) in certain areas of tne
Commonwealth. The specific NAAQS ana areas are listed in the
attachment to this letter. The basis for the finding of in-
adequacy is EPA's conclusion that those areas either are
covered by fully or conditionally approved Part D plans and
are still experiencing NAAQS violations, or lack fully or
conditionally approved Part D SIP's. The attachment also
details the bases for these conclusions.
EPA calls upon the Commonwealtn to cure the inadequacies in
the SIP by revising it. For areas with fully or conditionally
approved plans for ozone, nitrogen dioxide, carbon monoxide,
and sulfur dioxide, EPA is extending the Section 110(c) (1) (C)
revision period to one year from today to provide a sufficient
amount of tine to adopt and submit revisions. Concerning the
Scranton, Lackawanna County, and Wilkes-Barre, Luzerne County
areas, EPA has determined that curative SI? revisions are
necessary for the attainment of the ozone standard. Therefore,
the Commonwealth must submit a schedule for the development of
the necessary SI? revisions to EPA not more than 60 days from
today. If the Commonwealth does not submit curative SIP
revisions to EPA within one year from today, EPA will proceed
to propose a construction ban under Section 173(4) , and funding
restrictions under Section 176, and possibly Section 316(b) for
the areas in question. The Section 173(4) construction ban
prohibits major stationary source construction or modification
m affected areas. Section 316(b) authorizes EPA to withhold,
condition, or restrict sewage treatment construction grants in.
affected areas.
For areas lacking fully or conditionally approved plans for
ozone, carbon monoxide, nitrogen dioxide, and sulfur dioxide,
EPA is requesting the Commonwealth to submit Part D plans
within 60 days of today's date. EPA has determined tnat, for
Conewango Township, Warren County, a final plan for sulfur
dioxide must be submitted witnin the 50 day time frame. EPA
3-10
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cannot extend this deadline because tne Clean Air Act
Amendments did require primary NAAQS1s for the aforementioned
areas to be attained by December 31, 1982. If the Commonwealtn
does not submit a plan revision within 60 cays, EPA will
propose funding restrictions under Section 176(a) or Section
176(b), as appropriate. After this proposal, if the
Commonwealth demonstrates that it is working rapidly to develop
and submit a plan revision, EPA will defer its final action on
funding restrictions for that area. EPA, however, does not
intend to postpone any final actions more than one year from
today. NOTE: EPA is not now calling for any revisions it.
particulate matter nonattainment areas.
EPA may propose to restrict funding under Section 176(a) only
for areas that are nonattamment for the transportation-related
pollutants of ozone, car bon monoxide, or nitrogen dioxide.
Section 176(a) limits both highway funds and Clean Air Act
funds. For sulfur dioxide nonattamment areas, EPA will
propose to restrict Clean Air Act funds under Section 176(b).
Section 176(b) limits only Clean Air Act funds.
This finding of inadequacy and call for SIP revision is issued
in accordance with the general policy that appears in the
Federal Register of November 2, 1983, entitled "Compliance with
the Statutory Provisions of Part D of the Clean Air Act." 48
Fed. Reg. 50686. EPA1s "Guidance Document for the Correction
of Part D SIP's for Nonattainment Areas" (January 1984)
contains more information on the content of the revisions EPA
is requesting.
EPA plans to publish a notice of this finding of inadequacy
and call for SIP revision in the Federal Register shortly. EPA
will make additional findings of SIP inadequacy and calls for
revisions if the Agency receives air quality monitoring data in
the future indicating that other areas of the Commonwealth
covered by fully or conditionally approved Part D plans
continue to experience NAAQS violations.
The requirements specified in this letter represent only a
small portion of the very significant progress that the
Commonwealth of Pennsylvania has maae in achieving Clean Air
Act air quality goals. The Commonwealtn is commended for the
efforts already taken to preserve and enhance the environment.
Please contact me or Mr. w. Ray Cunningham, Acting Director,
Air Management Division, if you have any questions regarding
this letter.
S l neerely,
Thomas P. Eichler
Re.gional Administrator
nclosure
3-11
-------
ATTACHMENT
A. Areas lacking a fully or conditionally, approved Part D SIP.
1. Conewango Townsnip, Warren County - a dispersion model for
complex terrain predicted violations of the Sulfur Dioxide
(SO2) NAAQS in the vicinity of the Penelec Power Plant and
was the basis for the original §107 nonattamment designation
in 1978. No SIP has been submitted to address this issue.
The Pennsylvania Department of Environmental Resources has
stated that a modeling and monitoring agreement has been
reached with the company involved. This agreement should be
submitted as a SIP revision to EPA for review and
appcoval/disapproval. If the modeling protocol and monitoring
program are acceptable and the SIP revision approved by EPA,
Warren County would then be considered to have an adequate SIP.
3. Areas with fully or cond1t1ona1ly approved Part D SIP's buc
still experiencing NAAQS violations.
1. Scranton, Lackawanna County and Wilkes-Bar re, Luzerne
County - the ozone NAAQS is .120 ppm and cannot be exceeded
more than once per year.
Data from the
Pennsylvania Air
Quality Report provides the
following information:
1930
1981
1982
Site
Site
lsc
2nd
1st
2nd
1st
2nd
Name
Code
Hiah
High
High
High
High
High
Scranton 1
SOI
.155
.151
.118
. 10 4
.175
. 153
Wilkes-Bar re
S 21
.124
.115
.093
. 093
.124
.100
Carbondale
S25
.076
.060
.106
. 099
. 132
. 119
Nanticoke
S 26
-
-
-
-
. 125
. 098
All readings are in ppm.
1. 14 violations occurred at this monitor in 1980 and 5
violations occurred in 1982.
Data from the SAROADS Quick Look Report, 2/3/84, provides the
following information for 1983:
1st Q 2nd Q 3rd Q
Site
PA Site
SAROADS
1st
2nd
1st
2nd
1st
2nd
Name
Code
ID No.
High
Kian
Hi ah
Hi ah
High
High
Sc ran ton
SOI
398040006F01
. 047
.047
. 115
. 113
. 102
. 100
Wilkes-Barre
S 21
399430101F01
.057
.049
. 135
. 130
.114
. 107
Carbondale
S 2 5
39 1400100F01
.061
.056
. 10 2
.096
. 100
.095
Nanticoke
326
396300100F01
,051
.043
. 120
. 103
.096
.096
3-12
-------
Ozone is a regionwide problem and the fact cnat only two of the
four monitors show exceedances does not mean that a re-planning
effort for the entire area is not necessary.
An approved SIP, including a VOC emissions reduction and
control program, is in effect. However, it does not appear to
be adequate because violations of the ozone NAAQS are still
being observed. For this reason, EPA has determined that a
replanmng effort muse be undertaken.
3-13
-------
Region IV
4-1
-------
Areas Hot Anticipated to Meet
the Requirements of the Clean Air Act
STATE OF ALABAMA
AREA
POLLUTANT
UNLIKELY
TO ATTAIN
THE
NAAQS
FAILURE TO
COMPLY WITH
SIP CONDITIONS
FAILURE TO
SUBMIT AN
ADEQUATE SIP
Those portions of Jefferson
County within Central
Birmingham and the area
surrounding the Universal
Atlas Cement Plant
TSP
X
X*
Jefferson County
03
X
That portion of Etowah County
within the western section of
Gadsden
TSP
X*
* Area presently has restrictions on construction or modification of major stationary
sources for failure to submit an adequate SIP. Restrictions vill remain in effect.
4-2
-------
Areas With SIP Calls
Areas Without SIP Calls
STATE OF ALABAMA
AREA
POLLUTANT
Call for
SIP
No Call for
SIP
Those portions of Jefferson
County within Central
Birmingham and the area
surrounding the Universal
Atlas Cement Plant
TSP
X
Jefferson County
°3
X
That portion of Etowah County
within the western section of
Gadsden
TSP
X
4-3
-------
DISPOSITION OF TIER II AREAS
State Alabama
Area (Pollutant) Birmingham (Ozone)
Tier II
Reason on Tier II failure to demonstrate attainment
SIP Status Approved (1979) but currently deficient
Construction Ban No
Redesignation Proposed No
Final Action By N/A
State's Designation Nonattainment
SIP Control Measures VOC control (100 TPY source)/FMVC
Additional Information Monitored exceedences during 1981, 1982, and 1983
confirms fact that SIP is inadequate and new SIP is reguired.
Recommendation Call for new SIP under §110
4-4
-------
ALABAMA
Comments:
Several commentators from the State of Alabama felt it was
presumptive and premature for EPA to declare Birmingham, Alabama
to be an area not anticipated to meet the requirements of the
Clean Air Act. They went on to state that the Birmingham area
had an EPA approved State Implementation Plan (SIP), reasonable
good faith efforts had been made in the area toward attainment,
and substantial progress in reducing the number of violations
was demonstratable.
Response:
EPA agrees that progress has been made toward attainment of the
ozone standard in the area. However, the previously approved
SIP is inadequate to attain and maintain the national ambient
air quality standard (NAAQS) for ozone. This fact has been
demonstrated by the magnitude (.171 ppm) and number (at least
5) of exceedences during the 1983 ozone season. Given the 1983
monitoring data and the date of EPA1s final action on this
matter, the Agency's determination has been neither presumptive
nor premature.
4-5
-------
vUOSf„
f r
I * UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
4 1984
REF: 4AW-AM
REGION IV
345 COURTLAND STREET
ATLANTA GEORGIA 30365
Honorable George C. Wallace
Governor of Alabama
State Capitol
Montgomery, Alabama 36130
Dear Governor Wallace:
The Environmental Protection Agency (EPA) hereby notifies you
pursuant to Section 110(a)(2)(H) of the Clean Air Act, 42 U.S.C.
§7410 (a)(2)(H), that it finds the Alabama State Implementation
Plan (SIP) substantially inadequate to achieve the primary national
ambient air quality standard (NAAQS) for ozone in Jefferson
County. The basis for the finding of inadequacy is EPA's conclusion
that the area is still experiencing ozone violations. An attachment
is enclosed detailing the basis for this conclusion.
EPA calls upon the State of Alabama to cure the inadequacies
in the SIP by revising it. For the Birmingham area, which has a
fully approved plan for ozone, EPA is extending the Section
110(c)(1)(C) revision period to one year from today to provide a
sufficient amount of time to adopt and submit a revision. The
State must submit a schedule for the development of the necessary
SIP revision to EPA not more than sixty days from today. If the
State does not submit the curative SIP revision to EPA within one
year from today EPA will proceed to propose a construction ban
under Section 173(4) and funding restrictions under Section 176
and possibly Section 316(b) for the area in question. The
Section 173(4) construction ban prohibits major stationary source
construction or modification in the affected area. Section 176(a)
limits both highway funds and Clean Air Act funds for transportation-
related pollutants (i.e., ozone, carbon monoxide, and nitrogen
dioxide). Section 316(b) authorized EPA to withhold, condition
or restrict sewage treatment construction grants in the affected
area.
This finding of inadequacy and call for SIP revision are issued
in accordance with the general policy that appears in the Federal
Register for November 2, 1983, entitled "Compliance with the
Statutory Provisions of Part D of the Clean Air Act" (48 Fed.
Reg. 50686). EPA's "Guidance Document for the Correction of Part
D SIPs for Nonattainment Areas" (January 1984) contains more
information on the content of the revisions EPA is requesting.
4-6
-------
EPA plans to publish a notice of this finding of inadequacy and
call for SIP revision in the Federal Register shortly. EPA will
make additional findings of SIP inadequacy and calls for revisions
if the Agency receives air quality monitoring data in the future
indicating that other areas of the State covered by fully or
conditionally approved Part D plans continue to experience NAAQS
violat ions.
Please contact me if you have any questions regarding this letter.
Sincerely yours,
char Iras' R. >e*ST
Regional ^raministrator
Enclosure
A-7
-------
Areas Not Anticipated to Meet
the Requirements of the Clean Air Act
STATE OF FLORIDA
AREA
POLLUTANT
UNLIKELY
TO ATTAIN
THE
NAAQS
FAILURE TO
COMPLY WITH
SIP CONDITIONS
FAILURE TO
SUBMIT AN
ADEQUATE SIP
3ade County
°3
X
Broward County
03
X
Palm Beach County
03
X
4-8
-------
Areas With SIP Calls
Areas Without SIP Calls
STATE OF FLORIDA
AREA
POLLUTANT
.Call for
SIP
No Call For
- SIP
Dade County
°3
X
Breward County
°3
X
Palm Beach County
03
X
4-9
-------
DISPOSITION OF TIER II AREAS
State Florida
Area (Pollutant) Broward, Dade and Palm Beach Counties (Ozone)
Tier II
Reason on Tier II failure to demonstrate attainment
SIP Status Approved (1979), but currently deficient
Construction Ban No
Redesignation Proposed No
Final Action By N/A
State's Designation Nonattainment
SIP Control Measures Ambient monitoring data for 1981, 1982, and 1983
Additional Information shows that the area failed to attain the NAAQS
for ozone by December 1982.
- State has requested redesignation to attainment
- Region IV disagrees and will not propose redesignation
Recommendation Call for new SIP under §110
4-10
-------
FLORIDA
Comments:
Serveral commentors felt that the three-county area of Broward,
Palm Beach and Dade should not be judged as nonattainment for
ozone based upon one monitor (Virginia Key Site) in Dade County.
They argued that: there is no evidence that transport of VOC' s
or ozone from Broward and Palm Beach Counties contributes to
exceedences measured in Dade County; when the original nonattain-
ment areas were designated, the counties were named individually
and plan development and enforcement have been carried out
individually; monitoring through 1982 has not shown an exceedence
of the standard in Broward and Palm Beach Counties; Broward and
Palm Beach Counties' SIPs have accomplished the required VOC
reduction projected to demonstrate attainment for the area;
Since three political entities are concerned, the single airshed
concept cannot work and each county should not be held accountable
if the other plans in an area are not adequate.
Response:
By way of a general discussion of unified airsheds, the Agency
has long taken the position that ozone is no respector of
political boundaries and any SIP must include the entire urbanized
area and any adjacent fringe areas of development. This approach
has been used in several areas of the country where urbanization
has blurred distinct geopolitical boundaries. Regionally, the
Cincinnati area (including counties in Ohio and Northern Kentucky)
and the Louisville area (including counties in Indiana and
Kentucky) are planning on a single design monitor. A quick
analysis of Florida along the Southeast coast shows that it is
one urbanized area through most of Dade, Palm Beach and Broward
Counties. Further, if we use procedures found in EPA's- Workshop
on "Requirements for Nonattainment Area Plans (revised April
1978)" for predicting the boundaries of principal influence from
an urbanized plume, we see significant overlap of each county's
emission plumes. A check of the 1980 census shows over three
million people living in these three counties with most of them
traveling, working, and living along the eastern corridor of
these counties. It is EPA's position that it is not prudent to
allow the ozone planning and maintenance process to be fragmented
along county boundaries in such an interdependent urbanized
area. With respect to the individual points raised by the
commentors, EPA's position is: although there may be no tangible
evidence that Broward and Palm Beach counties' VOC emissions
significantly contributed to the violations at Virginia Key,
there also is no tangible evidence that they did not; although
EPA made the original designations by county and has approved
individual SIP's, the individual SIP planning and control
4-11
-------
strategies were based on a single design monitor for the three
counties and the success or failure of the three plans were and
are dependent on showing attainment for the area and not an
individual county; the lack of demonstrated exceedences at one
or two monitors in the three county area does not demonstrate
attainment for the airshed; although the required emission
reduction under the previously approved SIP may have been
attained, the reductions were not adequate to attain and maintain
the NAAQS for ozone in the three county area; with respect to
individual accountability, EPA recognizes that each political
entity has its own area of responsibility. However, each
county supposedly planned for the same goal and used the same
design level, the responsibility for making attainment is
shared and when attainment does not occur, the need for new
SIP's is also shared.
Comment:
Several comments questioned the validity of certain exceedences
at the Virginia Key site. Specifically they challenged the
December 23-24, 1982 exceedences on the bases that the exceedences
were not representative of the nonattainment area because the
predominant wind direction during the exceedences was from the
ocean. Without the two exceedences recorded during this time
period, the three year exceedence rate for the area falls to
1.0 and thus the area can demonstrate attainment through monitoring.
Response:
Region IV's Environmental Services Division has fully validated
the data during this time period. There is no indication of
tampering or malfunction. With respect to the wind direction,
satallite photographs have readily depicted cyclonic air movement
over the State of Florida. Unless we're to assume the exceedences
were caused by ozone transport from transoceanic sources, the
air passing over the Virginia Key monitor could easily have
been from a cycling air mass over the southern part of Florida.
Therefore, the ozone being measured would have been the result
of emissions previously blown out to sea. In any event, the
commentors' arguments are not sufficient to discredit the
observed data. Therefore, this December data has been used and
the resultant analysis shows that Dade, Broward and Palm Beach
Counties have not attained the standard.
4-12
-------
* dtek \
I 5? UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
pro^° REGION IV
345 COURTLAND STREET
ATLANTA GEORGIA 30365
REF: 4AW-AM
Honorable Bob Graham
Governor of Florida
State Capitol
Tallahassee, Florida 32301
Dear Governor Graham:
The Environmental Protection Agency (EPA) hereby notifies you
pursuant to Section 110(a)(2)(H) of the Clean Air Act, 42 LJ.S.C.
§7410 (a)(2)(H), that it finds the Florida State Implementation
Plan (SIP) substantially inadequate to achieve the primary national
ambient air quality standard (NAAQS) for ozone in Broward, Dade,
and Palm Beach counties. The basis for the finding of inadequacy
is EPA's conclusion that the area is still experiencing ozone
violations. An attachment is enclosed detailing the basis for
this conclusion.
EPA calls upon the State of Florida to cure the inadequacies in
the SIP by revising it. For all 3 counties, each having a fully
approved plan for ozone, EPA is extending the Section 110(c)(1)(C)
revision period to one year from today to provide a sufficient
amount of time to adopt and submit the revisions. The State must
submit a schedule for the development of the necessary SIP revisions
to EPA not more than sixty days from today. If the State does
not submit curative SIP revisions to EPA within one year from
today EPA will proceed to propose a construction ban under Section
173(4) and funding restrictions under Section 176 and possibly
Section 316(b) for the counties in question. The Section 173(4)
construction ban prohibits major stationary source construction
or modification in affected areas. Section 176(a) limits both
highway funds and Clean Air Act funds for transportation-related
pollutants (i.e., ozone, carbon monoxide, and nitrogen dioxide).
Section 316(b) authorized EPA to withhold, condition or restrict
sewage treatment construction grants in affected counties.
This finding of inadequacy and call for SIP revisions are issued
in accordance with the general policy that appears in the Federal
Register for November 2, 1983, entitled "Compliance with the
Statutory Provisions of Part D of the Clean Air Act" (48 Fed.
Reg. 50686). EPA's "Guidance Document for the Correction of Part
D SIPs for Nonattainment Areas" (January 1984) contains more
information on the content of the revisions EPA is requesting.
4-13
-------
EPA plans to publish a notice of this finding of inadequacy and
call for SIP revisions in the Federal Register shortly. EPA will
make additional findings of SIP inadequacy and calls for revisions
if the Agency receives air quality monitoring data in the future
indicating that other areas of the State covered by fully or
conditionally approved Part D plans continue to experience NAAQS
violat ions.
Please contact me if you have any questions regarding this letter.
Sincerely yours,
Enclosure
4-14
-------
Areas Not Anticipated to Meet
the Requirements of the Clean Air Act
STATE OF GEORGIA
AREA
POLLUTANT
UNLIKELY
TO ATTAIN
THE
NAAQS
FAILURE TO
COMPLY WITH
SIP CONDITIONS
FAILURE TO
SUBMIT AN
ADEQUATE SIP
Atlanta Metropolitan area
(including
Clayton County,
Cobb County,
Coweta County,
DeKalb County,
Douglas County,
Fayette County,
Fulton County,
Gwinnett County,
Henry County,
Paulding County, and
Rockdale County)
°3
X
4-15
-------
Areas With SIP Calls
Areas Without SIP Calls
STATE OF GEORGIA
AREA
POLLUTANT
Call For
.SIP
No Call For
SIP
Atlanta Metropolitan area
(including
Clayton County,
Cobb County,
Coweta County,
DeKalb County,
Douglas County,
Fayette County,
Fulton County,
Gwinnett County,
Henry County,
Paulding County, and
Rockdale County)
°3
X
4-16
-------
DISPOSITION OF TIER II AREAS
State Georgia
Area (Pollutant) Metro-Atlanta - 11 county area (Ozone)
Tier II
Reason on Tier II failure to demonstrate attainment
SIP Status Approved (1979), but currently deficient
Construction Ban No
Redesignation Proposed No
Final Action By N/A
State's Designation Nonattainment
SIP Control Measures VOC controls, FMVC, TCM - including I/M
Additional Information Ambient monitoring data for 1981, 1982, and 1983
shows that the area failed to attain the NAAQS for ozone by December
1982.
Recommendation Call for new SIP under §110
4-17
-------
GEORGIA
Comment:
One commentor wrote to express her concerns about any potential
weakening of the Clean Air Act.
Response:
Although this comment is not strictly germane to the matter
being discussed in this action, EPA is also very concerned
about the upcomming revisions to the Clean Air Act and is
working closely with congress and the administration to develop
revisions that will offer maximum utility and continued protection
of public health and welfare.
Comment:
One public interest group requested imposition of section 176
(a) funding restrictions in Atlanta, specifically to stop
construction of the long debated Presidential Parkway.
Response:
On April 10, 1980 (45 FR 24692), EPA and the Department of
Transportation published a joint policy for the implementation
of the sections 176(a) funding restrictions. In that policy,
the two agencies took the position that the restrictions would
apply only in regions that had not submitted (or made reasonable
efforts to submit) Part D SIP's for transportation related
pollutants. Georgia did submit a SIP for the Atlanta area and
although it has subsequently been found inadequate for attainment
of the NAAQS, section 176(a), sanctions are not appropriate
unless the state fails to make reasonable efforts to submit or
fails to submit a SIP revision for the Atlanta area.
Comment:
On May 2, 1983, the State of Georgia commented that based on
its review of the number of days of exceedences starting in
1979 and running through 1982, and considering the meteorology
associated with ozone formation, they felt the Atlanta area was
attainment for ozone. They further stated that if redesignation
was not possible, the nonattainment boundaries for the Atlanta
area should be reduced from eleven counties to five counties.
The State's rationale was that the outlying counties in the
existing nonattainment area had insufficient emission densities
to generate ozone exceedences. They propose to drop Paulding,
Douglas, Coweta, Fayette, Rockdale and Henry counties from the
nonattainment area.
4-18
-------
Response:
Although the 1983 air quality monitoring data has not been
completely submitted, EPA is aware of at least ten exceedences
at the DeKalb county site, seven exceedences at the Rockdale
monitoring site, and six exceedences at the Paulding County
monitoring site. Therefore the data does not support redesig-
nation to attainment nor does it currently support a reduction
in the size of the nonattainment area. EPA continues to believe
that the entire urbanized area and fringe areas of development
must be covered in the nonattainment area. In order for EPA to
consider a reduction in the size of the Atlanta nonattainment
area, the state must satisfy the conditions articulated in EPA's
section 107 designation policy memorandums dated April 22, 1983,
and December 23, 1983. Specifically, the state would need to
have valid air quality data showing no NAAQS violations in the
proposed area of reduction and an approved fully implemented
SIP control strategy. Although the area has an implemented
control strategy, ambient monitoring does not support a reduction
in the geographic area of coverage.
4-19
-------
MOSM
o* fs
. z
JSZZ,
s UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
*>«lPR0^ REGION IV
343 COURTLANO STREET
ATLANTA GEORGIA 30365
REF: 4AW-AM
Honorable Joe Frank Harris
Governor of Georgia
State Capitol
Atlanta, Georgia 30334
Dear Governor Harris:
The Environmental Protection Agency (EPA) hereby notifies you
pursuant to Section 110(a)(2)(H) of the Clean Air Act, 42 U.S.C.
§7410 (a)(2)(H), that it finds the Georgia State Implementation
Plan (SIP) substantially inadequate to achieve the primary national
ambient air quality standard (NAAQS) for ozone in the Metropolitan
Atlanta area. The basis for the finding of inadequacy is EPA's
conclusion that the area is still experiencing ozone violations.
An attachment is enclosed detailing the basis for this conclusion.
EPA calls upon the State of Georgia to cure the inadequacies
in the SIP by revising it. For the Atlanta area, which has a
fully approved plan for ozone, EPA is extending the Section
110(c)(1)(C) revision period to one year from today to provide a
sufficient amount of time to adopt and submit a revision. The
State must submit a schedule for the development of the necessary
SIP revision to EPA not more than sixty days from today. If the
State does not submit the curative SIP revision to EPA within one
year from today EPA will proceed to propose a construction ban
under Section 173(4) and funding restrictions under Section 176
and possibly Section 316(b) for the area in question. The
Section 1*73(4) construction ban prohibits major stationary source
construction or modification in the affected area. Section 176(a)
limits both highway funds and Clean Air Act funds for transportation-
related pollutants (i.e., ozone, carbon monoxide, and nitrogen
dioxide). Section 316(b) authorized EPA to withhold, condition
or restrict sewage treatment construction grants in the affected
area.
This finding of inadequacy and call for SIP revision are issued
in accordance with the general policy that appears in the Federal
Register for November 2, 1983, entitled "Compliance with the
Statutory Provisions of Part D of the Clean Air Act" (48 Fed.
Reg. 50686). EPA's "Guidance Document for the Correction of Part
D SIPs for Nonattainment Areas" (January 1984) contains more
information on the content of the revisions EPA is requesting.
4-20
-------
EPA plans to publish a notice of this finding of inadequacy and
call for SIP revision in the Federal Register shortly. EPA will
make additional findings of SIP inadequacy and calls for revisions
if the Agency receives air quality monitoring data in the future
indicating that other areas of the State covered by fully or
conditionally approved Part D plans continue to experience NAAQS
violations.
Please contact me if you have any questions regarding this letter.
Sincerely yours,
Charles R. Jet^f
Regional Administrator
Enclosure
4-21
-------
Areas Not Anticipated to Meet
the Requirements of the Clean Air Act
COMMONWEALTH OF KENTUCKY
AREA
POLLUTANT
UNLIKELY
TO ATTAIN
THE
NAA QS
FAILURE TO
COMPLY WITH
SIP CONDITIONS
FAILURE TO
SUBMIT AN
ADEQUATE SIP
Bell County
TSP
X
Boyd County
TSP
X
That portion of Campbell
County in Newport
TSP
X
That part of Henderson County
in Henderson
TSP
X
Jefferson County
TSP
X
That portion of Lawrence
County in Louisa
TSP
X
McCracken County
TSP
X
That portion of Perry County
in Hazard
TSP
X
That portion of Madison County
in Richmond
TSP
X
That portion of Whitley County
in Corbin
TSP
X
4-22
-------
Areas With SIP Calls
Areas Without SIP Calls
COMMONWEALTH OF KENTUCKY
AREA
POLLUTANT
Call For
SIP
No Call For
SIP
Bell County
TSP
X
Boyd County
TSP
X
That portion of Campbell
County in Newport
TS?
X
That part of Henderson County
in Henderson
TSP
X
Jefferson County
TSP
X
That portion of Lawrence
County in Louisa
TSP
X
McCracken County
TSP
X
That portion of Perry County
in Hazard
TSP
X
That portion of Madison County
in Richmond
TSP
X
That portion of Whitley County
in Corbm
TS?
X
4-23
-------
Areas Not Anticipated to Meet
the Requirements of the Clean Air Act
STATE OF TENNESSEE
AREA
POLLUTANT
UNLIKELY
TO ATTAIN
THE
NAAQS
FAILURE TO
COMPLY WITH
SIP CONDITIONS
FAILURE TO
SUBMIT AN
ADEQUATE SIP
Those portions of Shelby
County vithin two sections of
downtown Memphis
TSP
X*
Those portions of Sullivan
County with a section of
Bristol and a section of
Kingsport
TSP
X
That portion of Knox County
located in metropolitan
Knoxville
CO
X
•Area presently has restrictions on construction or modification of major stationary
sources for failure to submit an adequate SIP. Restrictions will remain in effect.
4-24
-------
Areas With SIP Calls
Areas Without SIP Calls
STATE OF TENNESSEE
AREA
POLLUTANT
Call For
SIP
No Call For
SIP
Those portions of Shelby
County within two sections of
downtown Memphis
TSP
X
Those portions of Sulli van
County with a section of
Bristol and a section of
Kingsport
TSP
X
That portion of Knox County
located in metropolitan
Knoxville
CO
X
4-25
-------
DISPOSITION OF TIER II AREAS
State Tennessee ___
Area (Pollutant) Knoxville (CO)
Tier II
Reason on Tier II large number of exceedences 1980-1982
SIP Status Approved ( 1979)
Construction Ban No
Redesignation Proposed No
Final Action By N/A
State's Designation Nonattainment
SIP Control Measures FMVCP only
Additional Information Knoxville has argued that exceedences prior to
mid-1982 were caused primarily by construcion related to the World's
Fairf plus various Interstate improvements. Only one exceedance has
been recorded since then (October 1982), although no data were obtained
from mid-November '82 - February 1, 1983, due to a monitor failure. How-
ever, essentially complete CO data has been obtained since then and no
exceedences have been recorded through January 1984. Most of the data is
preliminary, but barring unexpected changes, it will probably show
attainment. Although adeguate guality assured data are not available
to reguest a redesignation, we do not feel a finding of post '82 non-
attainment is justified.
Recommendation No action will be taken at this time to find the area has
not attained the CO standard. If QA'd data show compliance, Tennessee
can reguest a redesignation. If exceedences are monitored, the finding
of nonattainment and the call for a SIP can be issued at that time.
4-26
-------
TENNESSEE
Comments on the February 3, 1984 proposal finding that Knoxville
had failed to attain the carbon monoxide standard by the end of
1982 were received from the local Chamber of Commerce, the
local chapter of the Sierra Club, the County air pollution
agency, the County Executive and the Mayor of Knoxville. All
of the comments expressed the opinion that the large number of
CO violations recorded prior to 1982 were primarily caused by
traffic disruptions resulting from (1) construction of various
major Interstate highway improvements and 2) construction
activity at and near the 1982 World's Fair site and that without
these disruptions the area would have attained the CO standard
by the end of 1982 as forecast in their SIP.
Some comments recommended that the areas attainment status be
changed to "unclassifiable" until "normal" conditions prevailed.
The local air pollution agency also provided significant
documentation of the highway and World's Fair related construction
activity taking place between 1980 and early 1982 and its
possible influence on the recorded CO levels. Other comments
objected to the deposition of sanctions as a remedy for failure
to attain in any case.
Because the primary Knoxville CO monitor is located very near
(about 250 feet from) the World's Fair site and the number of CO
exceedences were easily the highest in the winter immediately
prior to the Fair, it appears likely that traffic disruptions
near the Fair site did influence the number of exceedandes
recorded in Knoxville. During the winter of 1982-83, when more
or less "normal" conditions did prevail the number of exceedences
was substantially less (only 1 exceedence, on October 28, 29).
However, the CO monitor was down for repairs from November 8 to
February 1, thus missing much of the primary carbon monoxide
season. In its February 3, 1983, and November 3, 1983, Federa1
Register notices, EPA requested that areas which were nonattain-
ment could avoid additional requirements for failing to attain
by the end of 1982 if they submitted air approvable request for
redesignation under current EPA policy. Tennessee has not
submitted such a request, although Knoxville has recently
indicated its intent to forward a redesignation request based
on the absence of any recorded CO exceedences at the downtown CO
monitor since January 1, 1983. (This includes preliminary data
through January 1984.) Although January 1983 data were not
available due to a monitor malfunction, there have been no signi-
ficant gaps in data since that time. Therefore, there has been a
full year of CO data recorded at the site with no exceedence
recorded since the end of 1982. Not all of this data has been
quality assured and entered into SAROAD, but based on the pre-
liminary data, there is considerable reason to doubt that the
Knoxville area is still not attaining the CO standard. EPA policy
4-27
-------
normally requires 8 quarters of data with no exceedances for
redesignation to attainment. Only 4 quarters are available,
and not all of those have been quality assured. Therefore, EPA
does not feel that sufficient data is available at this time to
redesignate the area to attainment. However, based on the
lack of any monitored exceedences since the end of 1982, and
the likelihood that the traffic influences cited earlier may
have been substantialy responsible for most of the large number
of exceedences recorded prior to mid-1982, "EPA feels that a
finding that the Knoxville area is still nonattainment for CO
is not supportable. If quality assured data continues to in-
dicate no exceedences of the CO standard, we expect Tennessee
to request redesingation for Knoxville. In the interim, if CO
exceedences are uncovered when quality assured data are submitted,
EPA would then proceed with the finding of post-1982 nonattamment
and require submittal of a new SIP.
In response to other issues revised in the comments, redesigna-
tion of the area to unclassiflable is not the appropriate
mechanism to address the uncertainties associated with the 1981-
1982 CO data (Sheldon Meyer, April 21, 1983, memo.) Comments
about the imposition of sanctions have been resolved by EPA's
change to a call for new SIPs in the initial response for
failure to attain by the end of 1982.
4-28
-------
Region V
5-1
-------
Areas Hot Anticipated to Meet
the Requirements of the Clean Air Act
STATE OF ILLINOIS
AREA
POLLUTANT
UNLIKELY
FAILURE TO
FAILURE TO
TO ATTAIN
COMPLY WITH
SUBMIT AN
THE
SIP CONDITIONS
ADEQUATE SIP
NAAQS
Part of Cook County
TSP
X
Part of Macon County
TSP
X
Part of St. Clair County
TSP
X
Part of Madison County
TSP
X
Part of Peoria County
SO ?
X
Part of Tazewell County
SO 2
X
5-2
-------
Areas With SIP Calls
Areas Without SIP Calls
STATE OF ILLINOIS
AREA
Call For
SIP
No Call For
SIP
Parr of Cook County
Part of Macon County
Part of St. Clair County
Part of Madison County
Part of Peoria County
Part of Tazewell County
5-3
-------
Areas Not Anticipated to Meet
the Requirements of the Clean Air Act
STATE OF INDIANA
AREA
POLLUTANT
UNLIKELY
TO ATTAIN
THE
NAAQS
FAILURE TO
COMPLY WITH
SIP CONDITIONS
FAILURE TO
SUBMIT AN
ADEQUATE SIP
Part of Lake County
S02
X
Part of Lake County
TSP
X
X*
Marion County
so2
X
Part of Marion County
TSP
X**
Part of Marion County
CO
X
Part of La Porte County
so2
X
Part of Wayne County
SO 2
X**
Part of Porter County
TSP
X
St. Joseph County
°3
X**
Elkhart County
°3
X**
Allen County
03
X"
Part of Clark County
TSP
X
Vigo County
so2
X
* Area presently has restrictions on construction or modification of major stationary
sources for failure to submit an adequate SIP. Draft implementation plan has now been
submitted but not yet approved.
** Area presently has restrictions on construction or modification of major stationary
sources for failure to submit an adequate SIP. Restrictions will remain in effect.
5-4
-------
Areas With SIP Calls
Areas Without SIP Calls
STATE OF INDIANA
AREA
POLLUTANT
Call For
SIP
No Call For
SIP
Parr of Lake County
so2
X
Part of Lake County
TSP
X
Marion County
(/)
o
ro
X
Part of Marion County
TSP
X
Part of Kan on County
CO
X
Part of La Porte County
so2
X
Part of Wayne County
so2
X
Part of Porter County
TSP
X
St. Joseph County
°3
X
Elkhart County
X
-
Allen County
°3
X
Part of Clark County
TSP
X
Vico County
so2
X
5-5
-------
Marion County-CO:
Boundari es:
Basis:
Call for SIP revision per §110(a) (2) (H)
City of Indianapolis in an area bounded by: 11th
Street on the north, Capitol on the west; Georyi a
Street on the south; and Delaware on the east.
Second high eight-hour concentration of 13.6 mg/m^
in 1981 at the L.S. Ayres site (-152040034F01)
as indicated in the January 26, 1983 TSD.
5-6
-------
The City of Indianapolis comments that transpor-
tation control measures beyond those committed to
in the 1979 SIP are being considered for future
implementation. These control measures will
reduce CO emissions, helping to assure attainment
of the standard.
The USEPA encourages to City to proceed with
these activities. However, the City nas failed
to demonstrate via emission reduction estimates
and implementation schedules that these control
measures woula have prevented CO standard exceed-
ances after December 31, Viol. Therefore, tn1s
comment does not support a reversal of USE^A's
proposed action to find Indianapolis as being
unlikely to attain tne staiiodrd oy Oecsnocr 31,
1982.
The City of Incnanapolis comments that USEUA
should define whether it has reviewed the CO
data In terms of the 10 mg/m^ standard or tne
9 ppm standard (8-hour averages).
USEPA nas reviewed all CO monitoring data against
the 10 mg/mJ standard.
The City of Indianapolis believes that tie worst-
case monitor is unduly influenced by unique
meteorological conditions such as tne formation
of localized air flow vortices (tnese woulc act
to trap and concentrate pollutants). The City
believes the monitored worst-case concentrations
are unrepresentative of other locations in the City.
USEPA has previously inspected the worst-case
site and has determined that It meets UbEr'A
siting guidelines. The siting guidelines specify
m1n1mun distances to nearby structures to ntnmize
the effects speculated oy the City to oco-r at
thts monitor. The monitor meets tnese cordltions.
The City has provided no data to support its
case. Nor has the City established tne geogra-
phical extent of the supposed irregularity,
USEPA continues to cell eve that tr.e avail dole
monitoring data demonstrate the existence of a
CO nonattai nment problem in a owntown Ina*. anapo'i s.
-------
Issue: Tite City of Indianapolis comments that, the
majority of transportation control measures
committed in the 1979 SIP have oeen imp! evented.
These measures include:
1. A 10 percent annual Increase in tr.e ndership
on the local university shuttle bus.
2. Enforcement of a city ordinance prohibiting
taxi cruising and requiring taxis to be
recent car model s.
3. A 3.25 percent increase 1n public transit
ridersni p.
4. Operation of an areawide carped program.
5. Encuuragement of flex-time work practices by
State and local public offices.
6. Interconnection of downtown traffic signals.
These control measures along with tne Fedora)
Motor Vehicle Control Program (FMVCP) were
demonstrated in the 1979 SIP to 1 ead to attain-
ment of the CO standard by Oecember 31, 1932.
Therefore, the City comments that USFPA, wno
approved the SIP, should not assume that the
w-ea will not be nonattalnment after 1932.
Response: USEPA acknowledges that the City has, 1n good
faitn, Implemented the majority of the transpor-
tation control measures committed in the 1979
SIP. USEPA, however, disagrees wltn this argu-
ment on several counts. First, the CO demonstra-
tion ylven m the 1979 SlJ met USEPA inHimun
guidelines by demonstrating attainment tnru tne
consideration of :ota! CO emssions ove" tne
entire Indianapolis area. Tne demcnstra:ion
did not address trie Impacts or CU emissions in
the vicinity of the worst-case monitor Uself,
Given tnat CO exceedances are ooserved to oe
localized 1n nature in other urban areas, it is
possible, if not probable, tnat the implemented
control measures have not sufficiently reduced
tne local emissions to the extent needed to
attain the standarG at tne monitor. Second,
the City nas not demonstrated by ccnslaeration
of tne actual emission reductions acMsvcn that
the secondhlgh concentrati on observed in U31
(the basis for iJSEPA's February 3, 1933, proposed
action) is not Indicative of potential r.unattai-
ment proolems after 1982.
5-8
-------
Issue: The City of Lndianjpolts comments that USEPA
should consider 1982 data ratner than 19^1 oata
to determine which areas »nll probably not attain
the standard by December 31, 1982. If the USEPA
ignores trie December, 1982 data at the worst-
case monitor dae to an aonormal sojrea situation
in t*Mt month, the feni* or, r,n con-
centration, 10.9 my/tn^ (eintj
unlitcely to attain the standard. Ratner, it
seems to support USEPA1s proposed designation
of tne area as unlikely to attain tne standard.
5-9
-------
issue: The City of Indianapolis comments that, If cur-
rent trends 1n the frequency and magnitudes of
CO exceedance continue, trie Indianapolis araa
snould attain tne CO standard oy December 31, 1932.
Response: Al tnou^Si a", r quality trenas are re^le^ed for
planning p'jrpo>riS, simple consideration cf trenis
in oxceedance levels a '3d f^e^jancies is not con-
sidered to oe adequate for absessiient of current
attainment. Observation of year to year cnan^es
indicates that a consideraole a^ounc of "noise"
exists in the data. Tne trends analysis does
not provide sufficient evidence tnat periodic CO
standard violations wilt not occur in tne future.
Review of tne second-nyn CO concentrations from
1979 tnru 1931 does not indicate a slgnincant
Improvement towards attainment of tne CO standard
at the L.S. Ayres monitor.
Final Conclusion; Proceed with tne designation of tne CO r.onattaln-
ment area as unlikely to attain tne CO standard.
5—10
-------
Wayne County-SOg: Call for SIP revision per §11Q(a)(2)(rt)
Boundaries: Boston, Center, Frarulln, Wayne and Wcoster
Townsm ps.
Basis: Same as TSD dated January 26, 1983. oecause of
a recent Federal Court ruling, £°A is issuiny a
notice of SI? inadequacy to Indiana t'^r Su2 io
Wayne County and five other counties i :i Indiana.
(See 49 Frt ).
5-11
-------
Public Comments: The State of Indiana "indicates tnat no action
has been taken due to a court Injunction (con-
cerning the State's procedure for designating
the area as nonattai nment). Cnce all 1 e^al
obstacles have been removed, an appropriate con-
trol strategy will be developed 1f necessary.
The State understands Chat the grovrth restric-
tions will stay 1n effect until a plan is approved.
EPA Response: Because Wayne County is designated as nonattaln-
ment under §107 of the CAA and Indiana nas not
submitted a plan under Part D, '.JS£?A must notify
the State that the Slr> for tms area is Inadequate
and must promulgate a plan 1f the State fails to
submit the long overdue plan as required.
5-12
-------
St. Josepn and Elkhart Counti es-03: Call for SIP revision per
§UU(aH2)(H) and maintenance of existing growth sanctions.
Boundaries: The entire counties of St. Joseph and El^nart.
Basis: Failure of the State to submit an ap^rovaole
1-979 ozone SI? containing acceptaole commit-
ments to implement Reasonably Avallaolc Control
Technology (RACT) regulations.
5-13
-------
Three comnenters rioted that Volatile Organic
Compound (tfOC) emissions In the Soutn ¦iena area
have been reduced to the attainment goa1. ^Iven in
the 1979 SIP. Therefore, USEPA should coi^aer
the area ;o De In attainment..
As JSEP^ has previously int'oned tne State, l1 i s
OSEPA's policy to not approve ozone attainment
demonstrations in areas without RACT imp! ementa-
ti on commitments unless tne State nas slutted
an attainment demonstration Dasec on tne use of
a photochemi cal dispersion model . Since tne
State basea Its demonstration of attain-ient on
a rollodcfc approach, wtiicfi in no way can oo con-
strued to be a photocneml cal dispersion model ,
USEPA remains convinced tnat even tnouvjr, 7UC
emissions nave been reduced to the calculated
attainment level, the State nas not adequately
demonstrated tnat the application of RACT is
not required in tne Soutn Bend area.
One concenter points out that point source emis-
sions 1n the 5outh Bend area have cesn reduced
from 2572 tons/year in 1977 to 1675 tons/year
In 1981. The implication (not directly stated
by the commenter) of this 1s that significant
progress has oeen made in reduciny stdtionary
source emissions.
Although point source VJC emission reductions
may have actually occurred between 1977 and
1981, tne State has not demonstrated tnat these
reductions were due to the application of enforce-
able Stationary source emissions control rsyul a-
tlcns. There 1s no guarantee tnat those emission
reductions will not ae negated when the economy
Improves and Industrial production rates once
again Increase. The emission reductions can
not be accepted in 1 1eu of RACT commitments
from the State.
One commenter pointed out tnat, considering that
the area is already in attainment of the standard,
the cost requlrements of SACT Implementation
could not De justified. Therefore, tne State
should be released from the need to develop and
su&mlt RACT regulations for St. Joseph and
El khart Countl es.
5-14
-------
Response: Tne Clean Air Act, as amended 1977 , (§172(d)(2))
requires all nonattainment area SlPs to Include
provisions for tne 1 mpl enentati on of all reason-
ably avail aole control measures. The Clean Air
Act does not provide for or allow tne considera-
tion of economic factors 1n this portion of SIPs.
USEPA 1 nterprets tm s part of the Clean Air Act
to requlre ozone SI Ps to include commitments
for t'ne development ar.G Implementation of RACT
regulations. It should :e noted tnat iJSEPA
will taKe economic factors into consideration
when evaluating the extent of RACT requirements
for specific sources or source categories in
St. Josepn and El knart Counties.
Issue: Three convnenters stated tnat no violations of
the ozone standard have oeen recorded In the
most recent years, and tnat USEPA is being
requested to redesignate St. Joseph and Elkhart
Counties to attainment. Since tni s is tne case,
the commenters believe that the USE°A snould drop
Its requlrements for RACT ?nd should remove the
South Bend area from the 11st of areas subject
to sanctions.
Response: USEPA was submlttea a redeslgnati on request for
this area in December, 1983. Preliminary review
of this request indicates that additional data
beyond those included In the submittal will have
to be obtained and reviewed before USEPA can
make a decision on this redesi gnati on request.
If the area is redesignatea, USEPA will reconsl-
der the neea for RACT In the area. Until the
redesl gnati on is finally approved, however,
USEPA should continue to consider tne area to
nave a nonapprovable SIP and should continue the
present major growth sanction.
final Conclusion: Continue to consider the area to be in noncom-
pliance of tne Clean Air Act due to a failure
of the State to submit an approvaole 1979 SIP.
5-15
-------
Ml en County - O3:
Boundaries: The entire County of A11 en ,
Basis:
Failure of tne State to subiut an approvals
1979 ozone SIP containing acceptable comai;:-
ments to implement Reasonaoly AvallaDle Control
Tecnnol oyy (RACT) regulations.
5-16
-------
Puolic Comments
Issue:
Response:
Issue:
Response:
Three commenters noted mat tne 1 y79 SI5,
-------
V1 go County-SQj: Tm 5 area was cited in the January 26, 1983, TSO
due to a pending delayed compliance order for
the Public Service Indiana Wabasn River plant.
The February 3, 1983, Notice, however, allowed
nonattainment areas to be exempted from the
general SIP disapproval if tne area would nave
achieved the primary NAAQS by December 31, 1982,
"out for" the emissions of a source wnlcn nao
obtained a compliance date extension beyond
1982 under Section 113. Althouyh the November 2,
1983, Notice stated that no areas were included
1n this exemption, Vigo County (SU2) snould have
been. Consequently, EPA is correcting the
February 3, 1983, action at this time and rescinds
EPA's proposed disapproval of the V1 go County SO2
SIP. In addition, the PS1 plant has completed
Installation of the stack for which they had sought
the DCO.
5-18
-------
MGR.07 '84 09:00 EPft CHICGGO
P. 04
W
% gMtf .
fiT.y.<
Honorable Robert D. Orr
Governor of Indiana
Indianapolis, Indiana 46204
Dear Governor Orr:
The U.S. Environmental Protection Agency (EPA) hereby notifies you pursuant to
Section 110(a)(2)(H) of the Clean A1r Act, 42 U.S.C. §7410(a)(2)(H), that it
finds the Indiana State Implementation Plan (SIP) substantially Inadequate to
achieve certain primary National Ambient A1r Quality Standards (NAAQS) 1n
certain areas of the State. The specific areas and NAAQS are Maricn County
for carbon monoxide, Wayne County for sulfur dioxide, and St. Joseph and
Elkhart Counties for ozone. The basis for the finding of inadequacy 1s EPA's
conclusion that, even though Marion County is covered by a fully approved Part 0
plan for carbon monoxide, 1t still 1s experiencing NAAQS violations. Wayne
County for sulfur dioxide and St. Joseph and Elkhart Counties for ozone lack
fully or conditionally approved Part 0 SIP's. The bases for these conclusions
for each area and pollutant are 1n an attachment to this letter.
EPA calls Upon the State to' aire the' Inadequacies in the SIP by revising 1t.
For areas such as Marlon County with a fuliyor conditionally approved plan for
carbon monoxide, EPA is extending the Section 110(c)(1)(C) revision period to
1 year from the date of this letter to provide a sufficient amount of time to
adopt and submit revisions. The State must submit a schedule for the development
of the necessary SIP revisions to EPA not more than 60 days from the date of
this letter. If the State does not submit curative SIP revisions to EPA within
1 year from the date o-? this letter, EPA will proceed to propose a construction
ban under Section 173(4) and funding restrictions under Section 175 (and possibly
Section 316(b)) for the areas 1n question. The Section 173(4) construction ban
prohibits major stationary source construction or modification in affected
areas. Section 316(b) authorizes EPA to withhold, condition or restrict sewage
treatment construction grants 1n affected areas.
For areas lacking fully or conditionally approved plans for o2one (St. Joseph
and Elkhart Counties) and sulfur dioxide (Wayne County), EPA is requesting the
State to submit Part 0 plans within 60 days of today's date. EPA will not
extend this deadline because these plans are already over five years late. If
a State does not submit a plan revision within 60 days, EPA will propose
funding restrictions under Section 176(a) or Section 176(b), as appropriate.
After this proposal, 1f a State demonstrates that It 1s working rapidly to
develop and submit a plan revision, EPA will defer its final action on funding
restrictions for that area. EPA, however, does not intend to postpone any
final actions more than 1 year from the date of this letter.
EPA may propose to restrict funding under Section 176(a) only for areas that
are nonattalnment for transportation-related pollutants, such as ozone and
carbon monoxide. Section 176(a) limits both highway funds and Clean A1r Act 5_
ftinW* »11 ^4 aw MAMif f af anaae PDA ui 1 1 f h roctV*^t
UNITED STATES
ENVIRONMENTAL PROTECTION AGENCY
REGION v
230 SOUTH OEABBOAN ST.
CHICAGO. ILLINOIS 80®0«
REPLY TO ATTENTION OF-
-------
b-i c!r. !uc. Lrh
2-
Th1s finding of inadequacy and call for SIP revision 1s Issued in accordance
with the general policy that appeared 1n the Federal Register on November 2,
1983, entitled "Compliance with the Statutory Provisions of Part D of the Clean
A1r Act." 48 FR 50686# EPA1s "Guidance Document for the Correction of Part D
SIP's for Nonattainment Areas" (January 1984) contains more information
on the content of the revisions EPA is requesting.
EPA plans to publish a notice of this finding of inadequacy and call for SI9
revision in the Federal Register shortly. EPA will make additional findings
Of SIP Inadequacy and calls for revisions If the Agency receives air quality
monitoring data 1n the future indicating that other areas of the State covered
by fully or conditionally approved Part D plans continue to experience NAAQS
violations. At this time, EPA 1s not calling for any revisions in particulate
matter nonattainment areas.
The State may request EPA to redesignate an area to attainment 1f it submits
the necessary technical information to support such a request. Any re'deslgna-
tion request must meet EPA's Section 107 designation policy as discussed 1n
EPA's April 21, 1983, and December 23, 1983, guidance documents. If EPA approves
a redesignatlon request to full attainment for any area cited today as having
an Inadequate SIP, a revised SIP will no longer be required for that area. We
recognize that Indiana has-, submitted a request to redesignate St. Joseph and
Elkhart Counties from primary nonattai nment to attainment for ozone. TMs-
request 1s currently under review.
Please contact me at (312) 353-2000 if you have any questions regarding this
letter.
Slnferely yours
Valdas V. Adamkjs
Regional Adminlstrator
Valdas V. Adamkjs
Regional Adminlstrator
Attachment
ec: Ronald S* Blankenbaker, M.D., ISBH
Harry D. Williams, IAPC8
bee: Tom Helms
bbcc: Irene Little
Debra Marcantonlo
Robert Miller
Joe Pa1s1e
David Kee
Steve Rothblatt
6ary Gulezlan
5-20
-------
MAP.07 '84 03:03 EPP CHICAGO
P. 06
Attachment
Marlon County - Carbon Monoxide (CO)
Boundaries: City of Indianapolis 1n the area bounded by 11th Street on
the north; Capitol on the west; Georgia Street on the south;
and Delaware on the east. .
Basis: The second high eight-hour CO concentrations in 1S81 and 1932 at
the L.S. Ayres monitor site 1n Indianapolis violate the CO National
Ambient A1r Quality Standard (NAAQS).
Wayne, County - Sulfur Dioxide (SO2)
Boundaries: Boston, Center, Franklin, Wayne and Webster Townships
Bisis: Indiana has. not submitted.,a plan which assures the attainment
and maintenance of the SO2 NAAQS as required by Part 0 of the
Clean Air Act.
St. Joseph and Elkiart Counties - Ozone {O3)
Boundaries: Entire Counties
Basis: Indiana did not submit acceptable commitments to Implement Reaso^a^ly
Available Control Technology (RACT) regulations in St. Joseph and
Elkhart Counties as required by Part D.
5-21
-------
Areas Not Anticipated to Meet
the Requirements of the Clean Air Act
STATE OF MICHIGAN
AREA
POLLUTANT
UNLIKELY
TO ATTAIN
THE
NAAQS
FAILURE TO
COMPLY WITH
SIP CONDITIONS
FAILURE TO
SUBMIT AN
ADEQUATE SIP
Part of Wayne County
TSP
X
X
5-22
-------
Areas With SIP Calls
Areas Without SIP Calls
STATE OF MICHIGAN
AREA
POLXDTANT
Call For
No Call For
SIP
SIP
Parr of Wayne County
TSP
X
5-23
-------
Areas With SIP Calls
Areas Without SIP Calls
STATE OF MINNESOTA
AREA
POLLUTANT
Call For
SIP
No Call For
SIP
Hennepin County
TSP
X
Part of Stearns County
CO
X
Part of St. Louis County
CO
X
Dakota County
SO 2
X
City of St. Paul
(Ramsey County)
CO
X
5-24
-------
Stearns County - CO: Postpone call for SIP revision per §110(a)(2)(H)
Boundaries: City of St. Cloud
Basis: The original basis was a second high eight hour concentration of
13.1 mg/m* at site I243220025H01 In 1981. Since mid-1982, there
have been no monitored violations of the CO NAAQS. Emission
reductions from the Federal Motor Vehicle Program and other
measures appear to be responsible to some degree for noted
improvements 1n ambient air quality data since the middle of
1983. In view of the recent monitor data, the Region will
postpone a call for this area until the national sweep* 1n
Auyust. This will allow the State additional time to reanalyze
the CO air quality 1n this area and, 1f supportable, to submit a
redeslgnatlon request to attainment based on the recent data.
5-25
-------
St. Louis County - CO: Postpone call for SIP revision per §110(a)(2)(H)
Boundaries: City of Duluth
Basis: The original basis was a second high eight hour CO concentration
of 13,2 mg/p3 at site #241040018601 in 1981. The rationale for
postponement of a SIP call 1s the same as for Stearns County -
CO above.
5-26
-------
Oakota County - SO2: Postpone call for SIP revision per § 110(a)(2)(H)
Boundaries: Entire County
Basis: There have been no monitored exceedances since fourth quarter,
1982. Emission reductions from Installation of a scrubber on
SRU #3 at the only major SO2 source 1n the area (Koch Refining)
appear to be responsible to some degree for noted improvements
1n the ambient data since mid-1982. In view of these data, the
Region will postpone a call for this area until the national
'sweep* in August. This will allow the State additional time to
reanalyze the SO2 air quality 1n this area and, 1f supportable,
to submit a redesignation request to attainment.
5-27
-------
Ramsey County-CO: Call for SIP revision per §110(a)(2)(H)
Boundaries: City of St. Paul
Basis: Second mgh eight-hour concertrdti ons of lb.3 my/'n3
1n 1981 and 13.0 mg/m^ in 1982 at site *2433'J0042F01.
5-28
-------
Public Comments:
Issue: Four commenters stated tnat tne area suoject to
sanctions should be restricted to a snail area
surrounding the intersection of Snell 1ny Avenue
and University Avc-nue. This recommendation is
based on tne fol 1 own ny observations:
1. The historical monitoring data record implies
tnat tne CO prool e.T, in Ramsey County is
primarily due to moo 11 e source emissions.
2. The Snell 1 ng/um versl ty Intersection is tne
most heavily travail en arterial intersection
in the St. Paul area.
3. CO Modeling using USEPA's Carbon Monoxide Hot-
Spot Guidelines shows tnat CO 1 evel s at dl 1
intersections one block from expected to be
already in attainment of the ozone standard.
This demonstrates the 1 united geograpmcai
extent of tne CO Problem dt tne SnelMng/
University intersection.
4. Monitoring at two other locations in St. Paul
showed no e
-------
Issue: Two cornnenters noted that tne CO hotspot at
Snelliny and University was detected too late
for tne State to meet USEPA's January 1, 1979,
deadline for requesting an attainment date
extension for t'ns area, These co.mienters
be! leva that USEPA snout a alter its proposed
sanction policy to accomodate areas tnat *ere
recently discovered to tie nonattai nment. Tne
comnenters believe ttiat (JSE°A should no: sanction
an area found to be nor.attai'iment auMny tne last
several years. Tne concenters believe tnat the
USEPA sanction policy should specifically aaoress
this type of area.
Response: As may be noted In tne November 2, 1983, Federal
Reglster (48 PR 50686) , USEPA nas substantial 1 y
revised Its sanction policy. Tne requirements
for SIP revisions for areas like tne CO nonattai n-
ment area are outlined in tn1 s notice of ri nal
rul emaK1 ng. It snould be noted tnat tJSEPA will
allow what it considers to oe a reasonable amount
of time for tne State of Minnesota to develop
and submit an approvable SIP revision oefore
i niposl ng sancti ons.
5-30
-------
tlHr. . ej. £,« 0T1. ub trp ..-liCr-ikjO _
r".
UNITED STATES
ENVIRONMENTAL PROTECTION AGENCY
A 601 ON v
220 SOUTH OEARBOflN ST
CHICAGO. ILLINOIS 60604
R6PLV TO ATTENTION OF
fED r •: SB*
Honorable Rudy Perp1ch
Governor of Minnesota
St. Paul. Minnesota 55155
Dear Governor Perplch:
The U.S. Environmental Protection Agency (EPA) hereby notifies you pursuant to
Section 110(a)(2)(H) of the Clean Air Act, 42 U.S.C. §7410(a)(2)(H), that it
finds the Minnesota-State Implementation Plan (SIP) substantially inadequate to
achieve the primary National Ambient Air Quality Standard (NAAQS) for carbon
monoxide 1n the City of St. Paul (Ramsey County). The basis for the finding
of Inadequacy is EPA's conclusion that, even though this area 1s covered by a
fully approved Part 0 plan, 1t 1s still experiencing NAAQS violations. The
attachment briefly details the basis for this conclusion.
EPA calls upon the State to cure the inadequacy in the SIP by revising it.
.For areas with fully or conditionally approved plans for.carbon monoxide, EPA
fs extending the'Section 110(c)(1)(C) revision period to 1 year from the date
of this letter to provide a sufficient amount of time to adopt and submit
revisions. The State must submit a schedule for the development of the necessary
SIP revisions to EPA not more than 60 days from the date of this letter.
If the State does not submit curative SIP revisions to EPA within 1 year
from the date of this letter, EPA will proceed to propose a construction ban
under Section 173(4) and funding restrictions under Section 175, and possibly
Section 316(b), for the area in question. The Section 173(4) construction ban
prohibits major stationary source construction or modification in affected
areas. Section 316(b) authorizes EPA to withhold, condition or restrict sewage
treatment construction grants 1n affected areas. EPA may propose to restrict
funding under Section 176(a) for areas that are nonattalnment for the
transportation-related pollutants, such as carbon monoxide. Section 176(a)
limits both highway funds and Clean Air Act funds.
This finding of inadequacy and call for a SIP revision Is Issued 1ri accordance
with the general policy that appeared In the Federal Register on November 2,
1983, entitled "Compliance with the Statutory Provisions of Part 0 of the Clean
A1r Act." 48 FR 50686. EPA's "Guidance Document for the Correction of Part D
SIP's for Nonattalnment Areas" (January 1984) contains more information on the
content of the revisions EPA is requesting. At this time, EPA 1s not calling
for any revisions In particulate matter nonattalnment areas.
5- 31
-------
MflR.07 '34 09:08 EPA CHICAGO
•2-
p. li
EPA plans to publish a notice of this finding of inadequacy and call for SIP
revision in the Federal Register shortly. EPA will make additional findings
of SIP inadequacy and calls for revisions if the Agency receives any valid data
or Information 1n the future indicating that other areas of the State covered
by fully or conditionally approved Part 0 plans continue to experience NAAQS
violations.
ThA State may request SPA to redesignate an area to attainment if 1t submits
the necessary technical Information to support such a request. Any ^designa-
tion request must meet EPA's Section 107 designation policy as discussed 1n
EPA's April 21» 1933 and December 23, 1933 guidance documents. If EPA approves
a redesignation request to full attainment for any area cited today as having
an Inadequate SIP, a revised SIP will no longer be required for that area.
Please contact me at (312) 353-2000 if you have any questions regarding this
cc: Sandra S. Gardebr'ing, MPCA
J. Michael Valantine, MPCA
bcc: Tom Helms
Irene Little
David Kee
Steve Rothblatt
Gary Gulezlan
Debra Marcantonlo
-Delo'res Sieja
Joe Paisie
letter.
Sincerely yours
Valdas V. Adamt us
Regional Administrator
5-32
-------
Attachment
1. Ramsey County - Carbon Monxide (CO)
Boundaries: City of St. Paul
Basis: The second high eight-hour CO concentrations in lPfl1 and 19R? at t^e
1569 University monitor site in St. Paul which violate the CO
National Ambient Air Quality Standards.
5-33
-------
Areas Hot Anticipated to Meet
the Requirements of the Clean Air Act
STATE OF OHIO
AREA
PQLLOTAHT
U&LDCELY
TO ATTAIH
THB
KAAQS
FAIL ORB TO
COMPLY WITH
SIP COHDITIOHS
FAILURE TO
SUBMIT AH
ADEQUATE SIP
?*** of Puyai*9fl §gwftf
?§?
X
X*
P*rt of Ggim*bi^| @gg*^
f§?
*
xl
?»lt 9f Je|ffr?9fl §SM^
?§P
*
*<
?«t of \inq §esnw
*§?
X
art
RichLand
f??
*
Saadnaky feeft^r
?§?
*
Portage County
*
Soaoit County
®i
S
Fart of Coshocton Cggpty
§§2
S
• Area presently ft a*} ffqfcrigtigiui sofiatFuetio^ er podificftion of pa jo? stationary
sources fpf fsiiqre %% §ui?ag$ an gdapa&s §jpf Sjp h&s gieei* §ubautted but not yet
approvedt
5-24
-------
Areas With SIP Calls
Areas Without SIP Calls
STATB OF OHIO
J&JSJl
POLU7T2U2T
Call For
SIP
No Call For
SIP
P»rt of eaysyKogs §ou*ty
f§?
X
Part of @998^
?§P
X
Bart gf geffafsp* @egi?fcy
«P
X
»*** of §e^fl?y
?§»
X
ILiciilaAd §aa»fcy
???
X
Saadnsfey Gouutf
?§?
X
Portage County
§3
X
SoKsit County
©§
X
Part of Coshortcc Coaaty
§§?
X
5-25
-------
Portaye County-03: Ca"\ ^ for SI? revision per §110( a) (2) (J.)
Boundaries: Tho County of Portage
Basis: Second t\: gh one-nour ozone concentration of 0.158
parts per mil Mon at site fc3653c0001HGl in 1981 as
discussed 1n the January 26, 1933 TSD.
5-36
-------
Publ1c Comments:
Issues: Three ccmmenters recommended tn0t UbCPA consider
tne mure current 1S62 ozone aatd rattier tnan
the 1931 data. If 1982 data ore considered,
the coimenters yen 'it out th-it t'ia ozone standard
axceecldnce recorded cn May U, 19B2 at tne Laics
Rockwell site (site if36S59uU0 :r;0i) shojio be con-
sidered to oe anomalous becasuc it wai recorded
at 10 p.m. under daytime meteorological conditions
unfavorable to ozone formation, Fm 5 hi yfi ozone
concentration (.350 parts per million) co'Jd not
be explained in terms of oiond fomatl on ^rocesses
typically ooserveo 1n urb^n areas. If tm s high
valued is Ignored, the r*o remaining 19d2 ozone
Standard exceeoances (.133 and .135 parts per
million) are below tne .14 parts per million
ozone concentration cutoff used oy tne USE?3* in
its February 3rd notice of proposed rulemaking.
Therefore, the commenters Del leva USF.PA snould
eliminate Portae County from tne list of areas
unlikely to attain the standaa by December 31,
1982.
Response: In selecting the criteria for area classification
in the February 3rd proposed rulemaking, 'JSEPA
assumed that a 14 to 15 percent reduction in
peak ozone concentrations would result between
1981 and the end of 19B2 as a result of tne VOC
emission control measures implemented 1n
urban areas. If only 1932 data are considered,
it would be appropriate to consider a 1 ozone
cutoff concentration, such as .13 parts per
million. Soth exceedances in 1932 were ioove
tni s 1 evel .
In addition, and nore importantly, tne commenters
have not demonstrated why the criteria JSEPA
used for assessing 1981 data were inappropriate
or outdated by emission changes between mid-iysi
and 1932. To do this, tney would nave to nad to
used an appropriate modeling technique such as
dty-speci fi c £KMA. They made no such modeling
analysi s.
USEPA does agree tnat tne .350 parts per million
ozone concentration recorded on May 22, 1932,
appears to be anomalous, although quality assured,
and that it snould be excluded from future ozone
modeling analyses.
Final Conclusion: It is concluded on the oasis of 1981 data that
Portage County should continue to be considered
as unlikely to attain the ozone standard by
December 31, 19d2. It should be noted that qua-
lity assured ozone standard exceedances, furtner
discussed for Summit County below, recorded in
5-37
-------
Portage County during 1983 confirms USEPA's pro-
posed finding for Portage County as well as tne
adequacy of the ozone concentrauon cutoft
used Dy USEPA in its proposed rulemaking.
5-38
-------
Summit County-Uj: CaU for SIP revision uer § 110 (a) (2) (H)
Boundaries: The County of Summit
Basis: Second-mgh one-hour ozone concentration of
0.158 i^arts per million at a peak clownw .id site
~365580001H01.
5-39
-------
Pub!1c Comments:
Issue:
Response:
Issue:
Response:
Issue:
Three cornmenters recommend tnat 'JSEPA consider
the hign and sacond-mgh ozone concentrations*,
measured at Patterson Par* in Submit County
during 1931 to be anomalous. Tnese concentra-
tions occurred late at mgnt on aays wnicn were
meteorologically not conducive to ozone formation.
Since these concentrations were tne oasis far tne
proposed classification of Surnmt County to De
unlikely to attain tne ozone standard by 'Jecember 31,
1982, the corr.nenters believe USE3A, shoulJ reverse
Its proposed r„l enaki .
Upon evaluation of avail sale aata, USEPA agrees
with tne commenters that tne peak, values m 1^)41
may be considered to be ano^al ou s. However,
evaluation of 1981 monitoring daia for Portage
County indicates tnat Summit County sno/ic con-
tinue to oe classified as post-1932 non-attain-
ment on tne basis of 1931 data. Tne pea< concen-
trations In Portage County (.0.180 ana 0.156 parts
per mill Jon) occurred or days with westerly winds.
Ozone precursor emissions fron tne Aferon urbanized
area are tne likely caose of tnese eacet-cances.
Since Portage County nas seen determiner: to be
post-lS82 nonattainment on tna basis of tnese
concentrations, it would niake technical Sdnse co
simillarly classify Su.-n.mt County as unlikely to
attain the ozone standard oy December 3i, 19d2.
Two coinmenters have stated that USEPA should
drop tne consi aerati on of 1981 data in lieu of
considering more current I'932 data. The 1982
exceedances 1n Sunmit County were all Del ow the
.14 parts per million cutoff used oy USEPA.
Tne comnentars nave failed to prove tnat tne
USEPA 19«1 concentracion cutoff was Inappropri-
ate. In addition, as discussed above, relatively
high ozone concentrations in excess of 0.13 parts
per million we^e observed in neignooring 3ortage
County in 1982. Preliminary review of 19t32
meteorological data Imply these concentrati ons
may have been largely aue to ozone precursor
eirn ssi ons from Summit County.
Three conr.enters nave Indicated have indicated
tnat significant VQC emissions reductions nave
occurred djring recent years. Data presented by
the commenters indicate tnat Sunmit County VOC
emissions decreased by as nucn as 23 percent
between Jjly, 1381 and the end of 1982, Tne
implication is that tnese reductions -nay nave
led to ozone standard attainment oy tne end of
1932.
5-40
-------
Response:
Issue:
Response:
Review of the 1981 data for Portage County thru
the use cf a simple rollback analysis indicates
tnat a VOC emission reduction of 31 percent or
more wojIci nave been necessary between mic-1981
and tne end of 1932 to attain tne ozone standard.
Consider! n-j tne VQC amission reductiona actually
acm eveo , one can conclude tnat tna V!JC emission
reduction acniavea since mid-1931 nay nave seen
insufficient to acnieve the ozone stanaara in
Portage County by Qeconoer 31, H82, Again it
is assjned tnat Sui.im*.c County VOC emissions are
a significant contributor to ozor.e standard
excaedancss in Portae County.
One comment&r suggested tnat UScPA consider
only 1933 data in assessment of post 19B2
attainment/nonattai nment.
USEPA nas determined tnat a number (five in
Summit County and five in Portage County) of
quality assured ozone standard exceed aices were
monitored in the Akron area in 1983. Tnese data
confirm USEPA1s proposed assessment of Summit
and Portage Counties as unlikely to attain tne
ozone standard by December 31, 19«2, and confl rm
USEPA's selected 1981 ozene concentration cutoff,
issue: One commenter indicated tnat continuing to declare
Sumni t County as post-1432 nonattainment would
create a credibility 'jap vdtn local residents
who were told in mid-19b2 chat Aicron was one of
tne cleanest major urban ar^as in terir.s of air
pol 1 ution.
Response: A1 thougn A*ran residents were tola tn-.s, current
ozone data confirm a contmuiny problem exists
in the Akron area requiring a new Siv revision.
To deny tne current ozo.^e data would really
establish a technical credibility gap.
Final Conclusion: Continue to classify Summit County as unlikely
to attain tne ozone standard oy Qacenser 31, 1932,
on the basis of 1931 data for- °orta^e Cojnty,
5-41
-------
Cos rue ton County-Si^: Tnls area was cited in the Janary £5, i983, T50
due to a Oal ayod Compliance Oraer for :'ie Colunous
and Southern Ohio Electric Conesv:lie plant.
Tne Feoruary 3, 1933, Notice, However, alowed
nonattai nmenc areas to oe sx erupted from tne
general SIU disapproval if tns area woui t nave
achieved tne primary NAAOS V Oecenber 31, 1932,
"but for" tne emissions cf a source wM :n had
obtained a compliance date extension Seyund 1932
under Section 113. A! tnou^n tie Novomoer lyci3
riot 1 ce stated tnat no areas *ere included in
this exemption, Cosnoct?n County (S0;>) should
have been. Consequent ;, E°A is correct1 ng tne
February 3, 1933, action at tnis tine and rescinds
EPA's proposed disapproval or tne Coshocton
County SUg SI"<* -
5-42
-------
MAP. Q7 ;Bd 09:03 EPS CHICAGO
P. 07
a A
y*°
UNITED STATES
ENVIRONMENTAL PROTECTION AGENCY
region V
230 SOUTH DEARBORN ST..
CHICAGO. ILLINOIS 80604
REPLY TO ATTENTION OF;
FEB' 2 4 1984
Honorable. Richard F. Celeste
Governor of Ohio
Columbus, Ohio 43215
Dear Governor Celeste:
The U.S. Environmental Protection Agency (EPA) hereby notifies you pursuant to
Section 110(a)(2)(H) of the Clean Air Act, 42 U.S.C. §7410(a)(2)(H), that 1t
finds the Ohio State Implementation Plan (SIP) substantially Inadequate to
achieve the National Ambient Air Quality Standard (NAAQS) for ozone 1n Summit
and Portage Counties. The basis for the finding of inadequacy 1s CPA's con-
clusion that, evefl though these areas are covered by fully approved Part D
plans, they are still experiencing NAAQS violations. The attachment briefly
details the basis for this conclusion.
EPA calls upon the State to cure the Inadequacies 1n the SIP by revising 1t.
For areas with fully or conditionally approved plans for ozone, EPA 1s extending
the Section 110(c)(1)(C) revision period to 1 year from the date of this letter
to provide a sufficient amount of time to adopt and submit revisions. The
.State, must submit'a'schedule for the "development of the necessary SIP revisions "
to EPA not more than 60 days from the date of this letter.
If the State does not submit curative SIP revisions to EPA within 1 year
from the date of this letter, EPA will proceed to propose a construction ban
under Section 173(4) and funding restrictions under Section 175, and possibly
Section 316(b), for the areas 1n question. The Section 173(4) construction ban
prohibits major stationary source construction or modification in affected
areas. Section 316(a), authorizes EPA to withhold, condition, or restrict
sewage treatment construction grants in affected areas. EPA may propose to
restrict funding under Section 176(a) for areas that are nonattalnment for the
transportation-related pollutants such as ozone. Section 176(a) limits- both
highway funds and Clean A1r Act funds.
This finding of Inadequacy and call for SIP revisions Is Issued 1n accordance
with the general policy that appeared in the Federal Register on November 2,
1983, entitled "Compliance with the Statutory Provisions of Part 0 of the Clean
Air Act." 48 FR 50686. EPA's "Guidance Document for the Correction of Part 0
SIP's for Nonattalnment Areas" (January 1984) contains more Information on the
content of the revisions EPA 1s requesting.
5-43
-------
i'lnrr . L» i
-2-
EPA plans to publish a notice of these findings of Inadequacy and call for 51?
revisions In the Federal Register shortly. EPA will make additional findings
of SIP Inadequacy and calls for revisions 1f the Agency receives air quality
monitoring data In'the future indicating that other areas of the State covered
by fully or conditionally approved Part 0 plans continue to experience NAAQ3
violations.
The State may request E?A to redesignate an area to attainment If it submits
the necessary technical information to support such a request. Any redeslgna-
tlon request must meet EPA's Section 107 designation policy as discussed in
EPA's April 21, 1983, and December 23, 1983, guidance dbcuments. If EPA approves
a redesignation request to full attainment for any area cited today as having
an Inadequate SIP, a revised SIP will no longer be required for that area.
Please contact me at (312) 353-2000 1f you have any questions regarding this
letter.
icerely youpi, ¦
Valdas V. Ada
Regional Adm1
Attachment
X
Tkus / J
i1strator(_X
cc: Robert H. Maynard, Ohio EPA
Charles M. Taylor, Ohio EPA
bcc; Tom Helms
Irene Little
David Kee
Steve Rothblatt
Gary Gulezlan
Debra Marcantonlo
Joe Pa1s1e
5-44
-------
MAR.87 '64 09:06 EPA CHICAGO
P. 0?
Attachment
Portage County - Ozone (O3)
Boundaries; Entire County
Basis: Second high one-hour ozone concentrations 1n 1981, 1982 and 1983
at the 1570 Ravenna Road monitor site which violate the O3
National Ambient A1r Quality Standards (NAAQS)
Summit County - Ozone
Boundaries: Entire County
Basis: Second high one-hour ozone concentrations 1n 1981, 1982 and 1983
at the 800 Patterson Avenue monitor site which violate the O3
NAAQS.
5-45
-------
Areas Not Anticipated to Meet
the Requirements of the Clean Air Act
STATE OP WISCONSXM
AREA
POLLUTANT
DNZ.IKEL7
FAILURE TO
FAILURE TO
TO ATTAIN
COMPLY WITH
SUBMIT AN
THE
SIP CONDITIONS
ADEQUATE SIP
NAAQS
Part of Brawn,County
SO 2
X*
Fart of Milwaukee County
so2
X*
* Area presently has restrictions on construction or modification of major stationary
sources for failure to submit an adequate SIP. Restrictions will remain in effect.
5-46
-------
Areas With SIP Calls
Areas Without SIP Calls
STATE OP WISCONSIN
AREA
POIXOTAMT
Call For
SIP
No Call For
SIP
Part of Brc*rn Couxitry
SO 2
X
Pajrt of Hi Ivaukee County
so2
X
5-47
-------
DISPOSITION OF TIER II AREAS
State Wisconsin
Area (Pollutant) Brown and Milwaukee Company - SO2
Tier H
Reason on Tier II FTSAS
SIP Status
Construction Ban yes
Redesignation Proposed -
Final Action By -
State's Designation Primary nonattainment
SIP Control Measures
Addi tional Information SIP submittal on January 23, 1984
Recomiiiendatio n Aw ait Regi onal Office action on submittal
Note: This is only an example format that was convenient and useful in
our discussions with Region VII. Your particular information does not
necessarily have to be in this particular format but we do need this type
of information for all Tier II areas, whether or not there is a SIP call
oy February 7, 1984. We need to know about all Tier II areas so we
can peer review all ten Regional Office actions.
5-48
-------
I
Region VI
6-1
-------
Areas Not Anticipated to Meet
the Requirements of the Clean Air Act
STATE OF LOUISIANA
AREA
3aton Rouge including
East Baton Rouge Parish and
West Baton Rouge Parish
New Orleans including
Jefferson Parish,
St. Bernard Parish, and
Orleans Parish
POLLUTANT
UNLIKELY
TO ATTAIN
THE
NAAQS
FAILURE TO
COMPLY WITH
SIP CONDITIONS
FAILURE TO
SUBMIT AN
ADEQUATE SIP
6-2
-------
Areas With SIP Calls
Areas Without SIP Calls
STATS OF LOUISIANA
AREA
Baton Rouge including
East Baton Rouge Parish and
West Baton Rouge Parish
New Orleans including
Jefferson Parish,
St. Bernard Parish, and
Orleans Parish
POLLUTANT
6-3
-------
Louisiana
Areas-- ast Baton Rouge Parish and West 3aton Rouge P
Propos: --Deficient cue to projected nonattainment
Final Recommendation--Defici ent due to violations in 1933
Areas—Jefferson Parish, St. Bernard Parish, and Orleans Parish
]--Dsf1 '"i ent due to projected ncnattai nr.isnt
• ecOTi" atiop--Designate as Tier 1 due to no exceedances in
Comment:
Response:
j,' The State of Louisiana is in compliance with its approved .uC
and therefore all areas in 40 CFR 81 for Louisiana should be
reclassified.
Response: As explained in an April 21, 1983 memorandum from Sheldon
Meyers to the EPA Regional Offices, EPA needs eight
quarters of monitoring data for each area in the State for
which redesignation is requested. The information, along with
the redesignation request and any additional information which
helps prove that each area is in attainment, should be submitted
to the Regional Office. The Regional Office will then prepare
a rulemaking which will reclassify the area to attainment.
1983 monitoring data should be used in designations to account
for improvements in late 1982.
The Regional Office is considering 1983 data in reference to the
areas for which a call for control plan revisions will be made.
Currently, a control plan revision for the New Orleans area
will not be requested due to the monitoring data that EPA has
for 1983. Using that data, EPA is projecting the Mew Orleans
area to be in attainment, if 1984 data remains below the
standa rd.
Comment: Trie location of monitors at nontypical locations are not
representative of air quality.
Response: The Regional Office has reviewed the location of the ozone
monitors located in Louisiana, and has not found any monitors
which are not representative of the area in which they are
located. If Louisiana would like to submit information
concerning a specific monitor, EPA will review the information
and work with Louisiana on picking a more appropriate location
for the mom tor .
Comment: Orleans Parish is in attainment and should not be represented
by monitors in Jefferson Parish.
Response: For urbar areas, EPA considers monitoring data for ozone for
tee wnolp urban area due to the possibility of transport of
ozone throughout an urban area. Even though muni toring excur-
sions nave heen observed in Jefferson Parish in the past, the
1983 data shews no violations. If the 198^ data reTi:-^
below one standard, the State can proceed to request ; orange
to attainment for the New Orleans area.
6-4
-------
Comment- Ozone transport has not been adequately considered in designations.
Response: It is EPA policy that transport of ozone be considered when an
area is being considered for a nonatta1nment or attainment
designation. Typically urban areas emit hydrocarbon emissions,
which form ozone, and rural areas nearby are not penalized
with sanctions when the rural area's ozone problem is shown to
be transported from an urban area nearby. Regardless, Louisiana
did not submit to EPA analysis which demonstrated that the New
Orleans area, or the Baton Rouge area was exceeding the ozone
standard due to another urban area nearby.
Comment: Orleans Parish is in attainment.
Response: For the New Orleans area, our projections using 1983 monitoring
data predict that the area is in attainment, and should be listed
as a Tier 1 area. However 1984 ozone data will have to show no
exceedances of the standard in order for the New Orleans area
to be redesignated to attainment.
6-5
-------
isszzi
e«0 ^
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION VI
INTERFiRST TWO BUILDING 1201 ELM STREET
DALLAS TEXAS 73270
February 24, 1984
Honorable David C. Treen
Governor of Louisiana
State Capitol
Baton Rouge, Louisiana 70804
Dear Governor Treen:
The Environmental Protection Agency (EPA) hereby notifies you pursuant to
Section 110(a)(2)(H) of the Clean Air Act, 42 U.S.C. §7410(a)(2)(H), that
it finds the Louisiana State Implementation Plan (SIP) substantially in-
adequate to achieve certain primary national ambient air quality standards
(NAAQS) in certain areas of the State. The East Baton Rouge and West
Baton Rouge Parishes have inadequate plans for ozone (O3), since these
areas are experiencing NAAQS violations. The New Orleans area was previously
projected by EPA to exceed the O3 NAAQS. However, 1983 data showed no
violations, and the area's plan is not being identified as deficient.
EPA calls upon the State to cure the inadequacies in the SIP by revising
it. For East Baton Rouge and West Baton Rouge Parishes, EPA is extending
the Section 110(c)(1)(C) revision period to one year from today to provide
a sufficient amount of time to adopt and submit revisions. The State
must submit a schedule for the development of the necessary SIP revisions
to EPA not more than sixty days from today. If the State does not submit
curative SIP revisions to EPA within one year from today, the Clean Air Act
requires EPA to take action. In that event, EPA believes it would have no
choice but to propose a construction ban under Section 173(4), and funding
restrictions under Section 176, and possibly Section 316(b) for the
areas in question. The Section 173(4) construction ban prohibits major
stationary source construction or modification in affected areas. Section
316(b) authorizes EPA to withhold, condition, or restrict sewage treatment
construction grants in affected areas.
EPA may propose to restrict funding under Section 176(a) only for areas
that are nonattainment for the transportation-related pollutants of ozone,
carbon monoxide, or nitrogen dioxide. Section 176(a) limits both highway
funds and Clean Air Act funds. Section 176(b) limits only Clean Air Act
funds.
This finding of inadequacy and call for SIP revision is issued in accordance
with the general policy that appears in the Federal Register for November
2, 1983, entitled "Compliance with the Statutory Provisions of Part D of
the Clean Air Act" (43 FR 50686). EPA's "Guidance Document for the
Correction cf Part D SIPs for Nonattainment Areas" (January 1984> contains
more information on the content of the revisions EPA is requesting.
EPA plans to publish a notice of this finding of inadequacy and call for
SIP revision in the Federa1 Register shortly. EPA will make additional
findings of SIP inadequacy and calls for revisions if the Agency receives
air quality monitoring oata in the future indicating that other areas of
6-6
-------
2
the State covered by fully or conditionally approved Part D plans continue
to experience MAAQS violations. Of particular interest to Louisiana is
a change in the Agency's approach to rural ozone (O3) nonattainment areas.
If it can be shown that the O3 problems in an area are caused by emissions
in the area, then control strategy demonstrations of attainment and
possibly additional control measures would be required. Previously, if
O3 nonattainment areas were below 200,000 in population, no control
strategy demonstration was required. We will be reviewing all rural C3
nonattainment areas in Louisiana to determine if they are generating
their own O3 problem and require additional SIP revisions.
Please contact me if you have any questions regarding this letter.
Regional Administrator
cc: Winston Day
Secretary
Department of Environmental Quality
Tnc^cely yours,
6-7
-------
Areas Not Anticipated to Meet
the Requirements of the Clean Air Act
STATE OF NEW MEXICO
AREA
POLLUTANT
UNLIKELY
TO ATTAIN
THE
NAAQS
FAILURE TO
COMPLY WITH
SIP CONDITIONS
FAILURE TO
SUBMIT AN
ADEQUATE SIP
Portions of Bernalillo County
TSP
X
Portions of Grant County
TSP
X
Portions of Grant County
SO 2
X
6-8
-------
Areas With SIP Calls
Areas Without SIP Calls
STATE OP NEW MEXICO
AREA
POLLUTANT
Call For
SIP
No Cal1 For
SIP
Portions of Bernalillo County
TSP
X
Portions of Grant County
TSP
X
Portions of Grant County
SO 2
X
6-9
-------
S ta te
.'Is./ ,".OX ICO
Pollutant. SO2
Area--Grant County
Propose 1 --Defi ci ent due to attainment resulting f ro..i an unautnori zed
dispersion technique
Final Recotrvencati on--Desvjnate as Tier 1 diie to submission of State
approved 1 < S 0
6-10
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION VI
iNTERFlRST TWO BUILDING 120I ELM STREET
DALLAS TEXAS 75270
24, 1984
Honorable Toney Anaya
Governor of New Mexico
State Capitol
Santa Fe, New Mexico 87501
Dear Governor Anaya:
The Environmenta1 Protection Agency (EPA) hereby notifies you pursuant to
Section 110(a)(2)(H) of the Clean Air Act, 42 U.S.C. §7410(a)(2)(H), that
it finds the New Mexico State Implementation Plan (SIP) substantia 1ly
inadequate. The basis for the finding of inadequacy is that the New
Mexico SIP does not include acceptable permit requirements for areas not
attaining national ambient air quality standards (NAAQS). Previous
proposals of inadequacy for other areas in New Mexico (Grant County -
Particulates and Sulfur Dioxide and Bernalillo County - Particulates)
are not being included in this notice.
EPA calls upon the State to cure the inadequacy in the SIP by revising
it. For the New Mexico conditionally approved plan, EPA is extending the
Section 110(c)(1)(C) revision period to one year from today, to provide a
sufficient amount of time to adopt and submit revisions. We have received
schedules from the New Mexico Environmenta1 Improvement Division and the
Albuquerque Air Pollution Control Division that provide for the revisions
to be submitted witmn a year. If the State does not submit curative
SIP revisions to EPA within one year from today the Clean Air Act requires
EPA to take action. In that event, EPA believes it would have no choice
but to propose a construction ban under Section 173(4), and funding
restrictions under Section 176, and possibly Section 316(b) for all
nonattainment areas in the State. The Section 173(4) construction ban
prohibits major stationary source construction or modification in affected
areas. Section 316(b) authorizes EPA to withhold, condition, or restrict
sewage treatment construction grants in affected areas.
EPA may propose to restrict funding under Section 176(a) only for areas
that are nonattainment for the transportation-delated pollutants of ozone,
carbon monoxide, or nitrogen dioxide. Section 176(a) limits both highway
funds and Clean Air Act funds. For sulfur dioxide nonattainment areas,
EPA will propose to restrict Clean Air Act funds under Section l?6(b).
Section 176(b) limits only Clean Air Act funds. NOTE: EPA is not now
calling for any revisions in particulate matter nonattainment areas.
This finding of inadequacy and call for SIP revision is issued in accor-
dance with the general policy that appears in the Federal Register for
November 2, 1 983. entitled "Compliance with the Statutory F'rovi si ens of
Part D of tne Clean Air Act" (48 FR 50686). EPA's "Guidance Document
for the Correction of part D SIPs for Nonattainment Areas" (January
1984) contains more information on the content of the revisions EPA is
request!ng.
$32/
4 c»c~ t -
February
6-11
-------
2
EPA plans to publish a notice of this finding of inadequacy and call for
SIP revision in the Federal Register shortly. EPA will make additional
findings of SIP inadequacy and calls for revisions if the Agency receives
air quality monitoring data in the future indicating that areas of the
State covered by fully or conditionally approved Part D plans continue to
experience NAAQS violations.
Please contact me if you have any questions regarding this letter.
Regional Administrator
cc: Stephen Asher, Director
New Mexico Environmental Improvement Div.
Larry J. Gordon, M.P.H., Director
Albuquerque Environmental Health and Energy Department
6-12
-------
Areas Not Anticipated to Meet
the Requirements of the Clean Air Act
STATE OF OKLAHOMA
AREA
POLLUTANT
UNLIKELY
TO ATTAIN
THE
NAAQS
FAILURE TO
COMPLY WITH
SIP CONDITIONS
FAILURE TO
SUBMIT AN
ADEQUATE SIP
Tulsa County
°3
X
6-13
-------
Areas With SIP Calls
Areas Without SIP Calls
STATS OF OKLAHOMA
AR£A
POLLUTANT
Call for
No Call for
SIP
SIP
Tulsa County
°3
X
6-14
-------
State: Oklahoma
Pol 1utant--Ozone
Area—Tulsa County
Proposal--Deficient due to projected nonattainment
Final Recommendation--Deficient due to violations in 1983
6-15
-------
Oklahoma
Comment: One commenter said that since EPA approved the State SIP,
which demonstrated compliance with the applicable NAAQS on
or before December 31, 1982, all areas in the State are con-
sidered to he rightfully attainment.
Response: EPA's policy is that the State may request redesignation to
attainment for any nonatta1nment area whenever it can be
supported by monitoring data or a modeling analysis if no
data is available. At this time, monitoring data in the
nonattainment areas show that they are exceeding the NAAQS.
Therefore, EPA cannot presume that the areas are attainment.
6-16
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION VI
iNTEFtFlRST TWO BUILDING 1201 ELM STREET
DALLAS TEXAS 75270
February 24, 1984
Honorable George Nigh
Governor of Oklahoma
State Capitol
Oklahoma City, Oklahoma 73105
Hear Governor Nigh:
The Environmenta1 Protection Agency (EPA) hereby notifies you pursuant to
Section 110(a)(2)(H) of the Clean Air Act. 42 U.S.C. §7410(a)(2)(H).
that it finds the Oklahoma State Implementation Plan (SIP) substantially
inadequate to achieve the ozone (O3) primary national ambient air quality
standard (NAAQS) in Tulsa County. The basis for the finding of inadequacy
is that Tulsa County continues to experience violations of the NAAQS.
EPA calls upon the State to cure the inadequacy in the SIP by revising
it. For Tulsa County EPA is extending the Section 110(c)(1)(C) revision
period to one year from today to provide a sufficient amount of time to
adopt an<^ submit revisions. The State must submit a schedule for the
development of the necessary SIP revisions to EPA not more than sixty
days from today. If the State does not submit curative SIP revisions to
EPA within one year from today, the Clean Air Act requires EPA to take
action. In that event, EPA believes it would have no choice but to
propose a construction ban under Section 173(4), and funding restrictions
under Section 176, and possibly Section 316(b) for the areas in question.
The Section 173(4) construction ban prohibits major stationary source
construction or modification in affected areas. Section 316(b) authorizes
EPA to withhold, conaition, or restrict sewage treatment construction
grants in affected areas.
EPA may propose to restrict funding under Section 176(a) only for areas
that are nonattainment for the transportation-related pollutants of ozone,
carbon monoxide, or nitrogen dioxide. Section 176(a) limits both highway
funds and Clean Air Act funds. Section 176(b) limits only Clear Air Act
funds.
This finding of inadequacy and call for SIP revision is issued in accordance
with the general policy that appears in the Federa1 Register for November 2,
1983, entitled "Compliance with the Statutory Provisions of Pert D of the
Clean Air Act" (48 FR 50686). EPA's "Guidance Document for the Correction
of Part D SIPs for Nonatta1nment Areas" (January 1984) contains more information
on the content of the revisions EPA is requesting.
EPA plans to publish a notice of this finding of inadequacy and call for
SIP revision in the Federal Register shortly. EPA will make additional
findings of SIP inadequacy and calls for revisions if the Agency receives
Tj
.582 }
t.
6-17
-------
2
air quality monitoring data in the future indicating that other areas of
the State covered by fully or conditionally approved Part D plans continue
to experience NAAQS violations.
Please contact me if you have any questions regarding this letter,
rely yours,
Dick Whittin
Regional Administrator
cc: Joan K. Leavitt, M.D.
Commissioner of Health
Oklahoma State Department of Health
Edgar M. Cleaver, M.D., Director
Tulsa City-County Health Department
„ udL- Lj
6-18
-------
Areas Not Anticipated to Meet
the Requirements of the Clean Air Act
STATE OP TEXAS
AREA
POLLUTANT
UNLIKELY
TO ATTAIN
THE
NAAQS
FAILURE TO
COMPLY WITH
SIP CONDITIONS
FAILURE TO
SUBMIT AN
ADEQUATE SIP
Dallas County
X
Tarrant County
°3
X
Portions of Cameron County
(San Benito)
TSP
X
Portions of Harris County
(Houston)
TSP
X
x*
Portion of Nueces County
(Corpus Christi)
TSP
X
Portions of El Paso County
(El Paso)
TSP
X
El Paso County
03
X
Portions of El Paso County
(El Paso)
CO
X
* Area presently has restrictions on construction or modification of ma^or stationary
sources for failure to submit an adequate SIP. Restrictions will remain in effect.
6-19
-------
Areas With SIP Calls
Areas Without SIP Calls
STATE OF TEXAS
AREA
POLLUTANT
Call For
SIP
No Call For
SIP
Dallas County
°3
X
Tarrant County
°3
X
Portions of Cameron County
(San Beruto)
TSP
X
Portions of Harris County
{Houston >
TSP
X
Portion of Nueces County
(Corpus Chnsti)
TSP
X
Portions of El Paso County
(El Paso)
TSP
X
21 Paso County
°3
X
Portions of El Paso County
(El Paso)
CO
X
6-20
-------
Texas
"-.i. ' mrt. Count/, El Pabo Count/
ii-z^vioui — ^ ^ i i c i c.' 11 c f 11: co l reject'. J nor'attci^rf.j.nt
Final Recorc.ne.nda ti on--D2fi ci ent due to violations in 1033
Pollutant. CO
/¦Tec — Portion of El Paso County along the 3io Grande River (map attached)
Proposal--Deficient due to proiected nonattainnent
Final Recc ruenoation--Deficient aue zo project-u nona tta" n,7,ent
Comment- A Tarrant County auto manufacturer commented that the E.PA
Administrator has statutory authority to approve an extended
compliance date as a legitimate revision of the Texas SIP for
areas identified by EPA to have deficient SIPs.
Response: Any question on such compliance date extension is moot since
the State has requested approval of a bubble for this source.
Comment: The Cities of Richardson and Grand Prairie raised a question
of "inaccurate ozone data" and the possibility of stratospheric
intrusion of ozone.
Response: All data used in the attainment/nonattainment projections were
subject to rigid State/EPA quality assurance requirements and
are valid data. EPA has no information to show that Dallas
area ozone data are inaccurate. Further, there is no indication
that stratospheric intrusion has occurred with the frequency
or magnitude necessary to significantly impact the number of
exceedances or the level of ozone monitored in the Dallas area.
Comment: Several respondents questioned the representativeness of O3
stations in Dallas County and whether the county unit is the
logical one for nonattainment designation.
Response: Ozone is not emitted directly, but rather is the result of
chemical reactions, in the presence of sunlight, of emissions
over an entire urbanized/industrialized area. For this reason
ozone monitors showing violations of the standard are re-
presentative of problems over the entire area where emissions
occur. EPA considers the highest value from monitors in the
Dallas area to be representative of the highest values actually
occurring in Dallas County. This includes the mumcipali ties
of Richardson, Garland, and Grand Prairie. The stations used
in tne nonattainment designation were properly sited in
accordance with the monitor siting regulations (40 CFR Part
58).
Comment: Several respondents indicated that transport from Dallas County
was responsible for violations of the ozone NAAQS in Tarrant
County.
6-21
-------
Response EPA identified 13 days on which exceeaances of the ozone NAAQS
occurred in Tarrant County duriny the 1980 through 1982 period.
All these exceedance days were registered at the Meacham Field
site in North Fort Worth.
EPA surveyed air parcel trajectories for the eight days of
exceedances in years 1980 and 1981. Using meteorological data
collected by the Texas Air Control Board (TACB) at Meachan
Field, we have determined that, on at least two of the eight
days, emissions of precursors in Tarrant County were probably
exclusively the cause of ozone exceedances at the Meacham
Field monitor. Based upon only these two exceedances--one
each in 1980 and 1981 -- the expected exceedances totals are
1.054 and 1.179, respectively, which supports the inclusion of
Tarrant County as an area projected to exceed the O3 standard.
Comment: One commenter noted that 1981 and 1982 O3 values in El Paso
and Tarrant Counties did not exceed the 0.14 ppm cutoff values
used by EPA to project 1983 attainment.
Response: Our inclusion of El Paso and Tarrant County was based on the
facts that '81/82 ozone levels were at the cut off levels and
their expected exceedances were greater than one over the
period 1980 thru 1982. In addition, 1983 data shows violations
of the O3 standard in both counties.
Carbon Monoxide
Comment: Several respondents also raised the question as to whether or
not the CAMS 6 CO monitor and monitoring method was actually
producing reliable data.
Response: Prior to 1980 the TACB CO monitoring stations in El Paso used
the gas chromatograph flame ionization method which is not
recognized by EPA as either a reference or equivalent method.
However, EPA granted the TACB a waiver for continued use of
these monitors until 1980. EPA considers data resulting
from this method as reliable and valid. Since 1980 a reference
or equivalent method has been used. The data have met quality
assurance requirements and are considered valid.
Comment: Several respondents mentioned possible problems with siting
criteria at two crucial monitoring stations.
Response: EPA does not take issue with the claim that CAMS 6 is not
a neighborhood scale monitor, but this does not affect the
propriety of the siting. We also maintain that there is no
significant wind flow interference at CAMS 6. The other
monitoring station, CAMS 12, completely met the siting
requirements for SLAMS neighborhood scale.
6-22
-------
Comment
Response:
Comment:
Response :
Comment:
Response:
Two respondents mentioned that a low v.ind speed analysis
i ndi rh *<-<' a "hn' cno-" ,"*1,j = nce.
We consider such results moot as high concentrations under low
wind speeas are not necessarily indicative of a hot spot
lnf1uence.
Several respondents claimed that El Paso air quality has made
improvement.
This is a moot point as violations of the NAAQS, which still
occur, are the concern.
Several respondents alluded to the point that El Paso ambient
concentrations may be influenced by emissions from Mexico and
government installations in El Paso.
The fact that emissions from Mexico and government installations
may impact El Paso ambient concentrations does not alter the
fact that the standards are being exceeded. As was done in
the 1979 SIPs, States can either assume international contri-
butions are at the level of the standard or specifically account
for the lnternationa1 contributions, in developing control
strategies for areas like El Paso. Government facilities are
required by Section 118 of the Clean Air Act to comply with
State and Federal pollution requirements.
6-23
-------
i UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
$522/ REGION v.
v. iNTERFlRST TWO BUILDING 1201 ELM STREET
°°01 DALLAS TEXAS 73270
February 24, 1984
Honorable Hark W. White, Jr.
Governor of Texas
State Capitol
Austin, Texas 78711
Dear Governor White:
The Environmental Protection Agency (EPA) hereby notifies you pursuant to
Section 110(a)(2)(H) of the Clean Air Act, 42 U.S.C. §7410(a)(2)(H), that
it finds the Texas State Implementation Plan (SIP) substantia 1ly inadequate
to achieve certain primary national ambient air quality standards (NAAQS)
in certain areas of the State. The specific NAAQS, areas, and basis for
the inadequacy are listed below. NOTE: EPA is not now calling for any
revisions in particulate matter nonattainment areas.
Pol 1utant Areas Basis for Inadequacy
Ozone (O3) Dallas, Tarrant Areas experiencing
and El Paso Counties NAAQS violations
Carbon Monoxide Portion of El Paso County Area experiencing
NAAQS violations
EPA calls upon the State to cure the inadequacies in the SIP by revising
it. For Dallas, Tarrant, and El Paso Counties EPA is extending the
Section 110(c)(1)(C) revision period to one year from today to provide a
sufficient amount of time to adopt and submit revisions. The State must
submit a schedule for the development of the necessary SIP revisions to
EPA not more than sixty days from today. If the State does not submit
curative SIP revisions to EPA within one year from today, the Clean Air
Act requires EPA to take action. In that event, EPA believes it would
have no choice but to propose a construction ban under Section 173(4),
and funding restrictions under Section 176, and possibly Section 316(b)
for the areas in question. The Section 173(4) construction ban prohibits
major stationary source construction or modification in affected areas.
Section 316(b) authorizes EPA to withhold, condition, or restrict sewage
treatment construction grants in affected areas.
EPA may propose to restrict funding under Section 176(a) only for areas
that are nonattainment for the transportation-related pollutants of ozone,
carbon monoxide, or nitrogen dioxide. Section 176(a) limits both highway
funds and Clean Air Act funds. Section 176(b) limits only Clean Air Act
funds.
This finding of inadequacy and call for SIP revision is issued in accordance
with the general policy that appears in the Federa1 Regi ster for November 2,
1983, entitled "Compliance with the Statutory Provisions of Part D of the
Clean Air Act" (48 FR 50686). EPA's "Guidance Document for the Correction
of Part D SIPs for Nonattainment Areas" (January 1984) contains more infor-
mation on the content of the revisions EPA is requesting.
6-24
-------
2
EPA plans to publish a notice of this finding of inadequacy and call for
SIP revision in the Federal Register shortly. EPA will make additional
findings of SIP inadequacy and calls for revisions if the Agency receives
air quality monitoring data in the future indicating that other areas of
the State covered by fully or conditionally approved Part D plans continue
to experience NAAQS violations. Of particular interest to Texas is a
change in the Agency's approach to rural ozone nonattainment areas. If
it can be shown that the O3 problems in an area are caused by emissions
in the area, then control strategy demonstrations of attainment and
possibly additional control measures would be required. Previously if
O3 nonattainment areas were below 200,000 in population, no control
strategy demonstration was required. We will be reviewing all rural O3
nonattainment areas in Texas to determine if they are generating their
own O3 problem and require additional SIP revisions.
Please contact me if you have any questions regarding this letter.
cc: Bill Stewart, P.E.
Executi ve Di rector
Texas Air Control Board
John Blair
Chai rman
Texas Air Control Board
6-25
-------
Region VII
7-1
-------
Areas Not Anticipated to Meet
the Requirements of the Clean Air Act
STATE OF IOWA
AREA
POLLUTANT
UNLIKELY
TO ATTAIN
THE
NAAQS
FAILURE TO
COMPLY WITH
SIP CONDITIONS
FAILURE TO
SUBMIT AN
ADEQUATE SIP
Des Moines, Polk County
TSP
X
7-2
-------
Areas With SIP Calls
Areas Without SIP Calls
STATE OF IOWA
AREA
POLLUTANT
Call For
No Cal1 For
SIP
SIP
Des Moines, Polk County
TSP
X
7-3-
-------
Areas Not Anticipated to Meet
the Requirements of the Clean Air Act
STATE OF KANSAS
AREA
Kansas City, Wyandotte County
Wichita, Sedgwick County
POLLUTANT
UNLIKELY
TO ATTAIN
THE
NAAQS
FAILURE TO
COMPLY WITH
SIP CONDITIONS
FAILURE TO
SUBMIT AN
ADEQUATE SIP
7-4
-------
Areas With SIP Calls
Areas Without SIP Calls
3TATE OF KANSAS
AREA
POLLUTANT
Call For
No Call For
SIP
SIP
Kansas City, Wyandotte County
TSP
X
Wichita, Sedgwick County
CO
X
7-5
-------
State:
Area:
Pollutant:
Reason for Tier II:
SIP Status:
Construction Ban:
Redesignation Proposed:
State's Designation:
SIP Control Measures:
Recominendati on:
Kansas; Sedgwick County
Wichi ta
CO
Unlikely to attain the NAAQS
Approved
No
No
Nonattai nment
FMVCP, voluntary I/M, traffic flow improvements
Call for SIP
7-6
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
¦ " RCC ION' V II
V' ; i. A ,T Elf VfcfilH b"RE l£ T
ka\sas civ v.issouni - 6-1 lot-.
FEB 2 9 1984
cf - • : r^:
Irtc HEGlONAL ACMIMSTRATOO
Honorable John Carlm
Governor of Kansas
Topeka, Kansas 66612
Dear Governor Carlm:
As you know, the Environmental Protection Agency (EPA) identified in
the February 3, 1983, Federal Register a number of areas in the country
that presumably did not attain the National Ambient Air Quality Standards
(NAAQS). In November 1983, the EPA announced in the Federal Register a
pollcy of deallng with these areas i n terms of the CIean Air Act (CAA).
The purpose of this letter is to implement that policy by notifying you
that under Section 110(a)(2)(H) of the Clean Air Act that the EPA
finds the Kansas State Implementation Plan (SIP) for carbon monoxide
(CO) in Wichita substantially inadequate to meet the CO standard. A
description of the area is attached. Although a fully approved plan has
been implemented in Wichita, EPA believes that violations of the CO
standar.d are still occurring.
The regional office worked closely with the state- and the City of
Wichita during developmental stages of the original Part D plan. The
approved plan contained several elements which the state and EPA believed
would show attainment of the CO standard by December 31, 1982. Wichita
is the only area in the country that has a voluntary vehicle inspection and
maintenance program as part of an approved SIP.
The EPA requests the state to prepare a revised CO plan for the Wichita
nonattai-nment area. For areas with fully approved plans, the EPA extends
the Section 110(c)(1)(C) revision period to one year from today to provide
sufficient time to adopt and submit revisions. We ask that the State
submit a schedule for development of the necessary SIP revision to EPA
within sixty days from today. The Regional office will continue to work
with the state and the municipal agencies during the developmental stages
of the required SIP revision as necessary to assure a workable plan.
If the State does not submit a revised SIP to EPA within one
year from today, EPA will proceed to propose a construction ban under
Section 173(4) and funding restrictions under Section 176 and possibly
Section 316(b) for the areas in question. The Section 173(4) construction
ban prohibits major stationary source construction or modification in
affected areas. Section 316(b) authorizes EPA to withhold, condition or
7-7
-------
2
restrict sewage treatment construction grants in affected areas. EPA will
propose to restrict funding under Section 176(a) only for areas that are
nonattainment for the transportation-related pollutants of ozone, carbon
monoxide, or nitrogen dioxide. Section 176(a) limits both highway funds
and Clean Air Act funds. Section 176(b) limits only Clean Air Act funds.
We have previously given the Department of Health and Environment a
copy of EPA's "Guidance Document for the Correction of Part D SIPs for
Nonattainment Areas" (January 1984) which contains more information on
the content of the revisions EPA is requesting. We have also discussed
this action with Allan Abramson and his staff so they are aware of this
matte r.
The EPA plans to publish a notice of this finding of inadequacy, as
well as those for other states, and all calls for SIP revisions in the
Federal Register in the near future.
The EPA is not calling for a review on particulate matter SIPs at
this time. We will be in contact with the Department of Health and
Environment when further guidance is available.
Later this year, EPA plans to review all of the other air quality
monitoring data to ensure that the NAAQS are being attained. If we find
additional violations, you will be notified by a letter similar to this
requesting remedial action.
I am confident that together we can develop the revised air quality
plans necessary to protect the public health and welfare in Wichita as well
as any other areas. My staff is ready to assist you and the Department of
Health and Environment at any time. We are pleased with the positive re-
sponse and cooperation we have had to date and anticipate the same good
relatioaship in the future.
Please contact me if you have any questions regarding this letter.
The person on my staff that is most knowledgeable on this matter is Carl
Walter, who may be contacted at 816/374-3791.
cc: Allan Abramson, Director
Division of Environment;
Robert Eye, Manager
Bureau of Air Quality and Radiation Control
bcc: R. Ritter - CIGL
T. Helms - OAQPS/RTP
M. Sanderson - AWCM
J. Helvig - ENSV
R. Patrick - CNSL 7_8
Sincerely yours,
Morris Kay
Regional Admi ni strator
-------
WICHITA NONATTAINMENT AREA
Wichita, Kansas, area bounded by:
Grove Street on the east, 13th Street on the north,
the Arkansas River on the west, and Kellogg Avenue
on the south.
7-9
-------
Areas Not Anticipated to Meet
the Requirements of the Clean Air Act
STATE OF MISSOURI
AREA
POLLUTANT
UNLIKELY
TO ATTAIN
THE
NAAQS
FAILURE TO
COMPLY WITH
SIP CONDITIONS
FAILURE TO
SUBMIT AN
ADEQUATE SIP
St. Louis
(an area extending west about
2 miles from the Mississippi
River, north to near 1-270
and south to about 1 mile
beyond the city limits)
TSP
X
7-10
-------
Areas With SIP Calls
Areas Without SIP Calls
STATS OF MISSOtml
AREA
POLLUTANT
Call For
SIP
No Call For
SIP
St. Louis
(an area extending west about
2 miles from the Mississippi
River, north to near 1-270
and south to about 1 mile
beyond the city Limits)
TSP
X
7-11
-------
Areas Not Anticipated to Meet
the Requirements of the Clean Air Act
STATE OF NEBRASKA
AREA
POLLUTANT
UNLIKELY
TO ATTAIN
THE
NAAQS
FAILURE TO
COMPLY WITH
SIP CONDITIONS
FAILURE TO
SUBMIT AN
ADEQUATE SIP
Lincoln, Lancaster County
CO
X
X*
Omaha, Douglas County
CO
X
X*
Omaha, Douglas County
(24th 5 0 Street)
TSP
X*
Omaha, Douglas County
(11th fi Nicholas Street)
TSP
x*
Louisville, Cass County
(muni ci pa1 area)
TSP
X*
Weeping Water, Cass County
(municipal area)
TSP
X*
* Area presently has restrictions on construction or modification of major stationary
sources for failure to submit an adequate SIP. Implementation plan has now been submitted
but not yet approved.
7-12
-------
Areas With SIP Calls
Areas Without SIP Calls
STATE OF NEBRASKA
AREA
POLLUTANT
Call For
SIP
No Call For
SIP
Lincoln, Lancaster County
CO
X
Omaha, Douglas County
CO
X
Omaha, Douglas County
(24th & 0 Street)
TSP
X
Omaha, Douglas County
(11th & Nicholas Street)
TSP
X
Louisville, Cass County
(municipal area)
TSP
X
Weeping Water, Cass County
(municipal area)
TSP
X
7-13
-------
State:
Area:
Pollutant:
Reason for Tier II:
SIP Status:
Construction Ban:
Redesignation Proposed:
State's Designation:
SIP Control Measures:
Additional Information:
Recommendati on:
State:
Area:
Pollutant:
Reason for Tier II:
SIP Status:
Construction Ban:
Nebraska; Lancaster County
Lincoln
CO
Unlikely to attain the NAAQS; failure to submit an
adequate SIP.
Proposed approval; no final.
Yes
No
Nonattainment
FMVCP, traffic control.
Unconfirmed violation in 1983; one violation at each
of two sites in 1982.
Call for SIP - Request state to withdraw existing SIP,
Nebraska; Douglas County
Omaha
CO
Unlikely to attain the NAAQS; failure to submit an
adequate SIP.
Proposed approval; no final.
Yes
Redesignation Proposed:
State's Designation:
SIP Control Measures:
Additional Information:
No
Nonattai nment
FMVCP
No violations through December 4, 1983; 23 violations
in 1982.
Recommendation:
Call for SIP - Ask state to withdraw existing SIP.
7-14
-------
iFh.
SB. ? UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
'' .i.o,k" REGION VII
3?4 EAST ELEVENTH STREFT
KANSAS CITY MISSOURI - 64)06
FEB 29 1984
Iht: HEGiONAL AOMINISTRATOM
Honorable Robert Kerry
Office of the Governor
State of Nebraska
Box 94848
Lincoln, Nebraska 68509-4848
Dear Governor Kerry:
As you know, in the February 3, 1983, Federal Register the Environmental
Protection Agency (EPA) identified a number of areas in the country that
presumably did not attain the National Ambient Air Quality Standards (NAAQS).
On November 2, 1983, the EPA announced in the Federal Register a policy of
dealing with these areas in terms of the Clean Air Act. The purpose of
this letter is to implement that policy by notifying you that under Section
110(a)(2)(H) of the Clean Air Act, the Environmental Protection Agency
finds the Nebraska State Implementation Plan ("SIP") substantially inadequate
to achieve the carbon monoxide (CO) standards in Lincoln and Omaha. A
description of these areas is enclosed with this letter. The basis for
the finding of inadequacy is EPA's conclusion that these areas lack fully
or conditionally approved Part 0 SIPs.
Over the past few years, we have worked with the staff of the Department
of Environmental Control to develop State Implementation Plans to attain the
CO standards in Lincoln and Omaha. Under the 1977 Clean Air Act Amendments,
these plans were to demonstrate how these areas would achieve the standards
by December 31, 1982. On July 20, 1982, Governor Thone submitted the
state's plans, but we found we could not approve them because of the impending
attainment deadline of December 31, 1982. Although the SIPs showed that
the standards would be attained by that deadline, ambient air monitoring
data in 1982 showed numerous violations of the CO standard.
I am requesting that you withdraw the carbon monoxide plans submitted
in 1982 and develop and submit new plans. If the State chooses not to
withdraw these plans, EPA will be required to propose disapproval of them
and concurrently propose Section 176(a) funding restrictions on the carbon
monoxide nonattainment areas. Section 176(a) limits both highway funds
and Clean Air Act funds.
For areas such as Lincoln and Omaha which lack fully or conditionally
approved plans, EPA is requesting the State to submit Part D plans within
60 days of today's date. EPA will not extend this deadline because these
plans, which were due in 1979, are already over five years late. If the
State does not submit a CO plan revision within 60 days, EPA will propose
funding restrictions under Section 176(a). However, we recognize the
substantial difficulties involved in preparing, adopting and submitting
new plans. So, after this proposal, if the State demonstrates that it is
7-15
-------
2
working rapidly to develop and submit a plan revision, EPA will defer its
final action on funding restrictions for that area. EPA, however, does
not intend to postpone any final actions more than one year from today.
If the State is unable to develop and submit new carbon monoxide plan
revisions for Lincoln and Omaha within 60 days, the State must submit a
schedule for the development of such plan revisions within that time.
Although EPA will propose funding restrictions if SIPs are not received
within that time, we will consider the submission of a thorough schedule a
demonstration that the State is working toward the submission of a plan and
will defer final action on the funding restrictions for up to one year pro-
vided the State stays on its schedule.
You are probably aware that Section 110(a)(2)(I) of the Act prohibits
the construction or modification of major stationary sources of pollution
after July 1, 1979, in any nonattainment area whose SIP does not meet the
requirements of Part D of the Act. On July 2, 1979, EPA imposed this ban
in Lincoln and Omaha for sources of CO. This ban will continue to be ef-
fective until approvable Part D SIP revisions are submitted by the State
and approved by EPA.
We have previously given the Department of Environmental Control a
copy of EPA's "Guidance Document for the Correction of Part D SIPs for
Nonattainment Areas" (January 1984) which contains more information on
the content of the revisions EPA is requesting. We have also discussed
this action with Dennis Grams and his staff so they are fully aware of
this matter.
The EPA plans to publish a notice of this finding of inadequacy, as
well as those for other states, and calls for SIP revisions in the Federal
Register•in the near future.
The EPA is not calling for a review on particulate matters SIPs at
this time. We will be in contact with the Department of Environmental
Control when further guidance is available.
Later this year, the EPA plans to review all of the other air quality
monitoring data to ensure that the NAAQS are being attained. If we find
additional violations, you will be notified by a letter similar to this
requesting remedial action.
I am confident that together we can develop the revised air quality
plans necessary to protect the public health and welfare in Lincoln and
Omaha as well as any other areas. My staff is ready to assist you and the
Department of Environmental Control staff at anytime. We are pleased with
the positive response and cooperation we have had to date and anticipate
the same good relationship in the future.
7-16
-------
3
If you have any questions concerning this letter, please do not hesitate
to contact me at (816) 374-5493. The member of my staff who is most familiar
with this subject, Carl M. Walter, (816) 374-3791, can also provide additional
i nformation.
Enclosure
cc: Dennis Grams, Director
Department of Environmental Control;
Gene Robinson, Chief
Division of Air Pollution
bcc: R. Ritter - CIGL
M. Sanderson - AWCM
R. Patrick - CNSL
J. Helvig - ENSV
T. Helms - OAQPS/CPDD
Sincerely yours,
, //'>-'
Morn s/Kay
Regional Administrator
J-17
-------
Nebraska Carbon Monoxide Nonattainment Areas
Omaha: Municipal boundaries.
Lincoln: Antelope Creek basin, described as follows:
From Salt Creek south to Vine Street generally
between 13th and 22nd Streets; from Vine Street
south to "0" Street generally between 17th and
25th Streets; from "0" Street south to Randolph
Street generally between 19th and 27th Streets;
from Randolph Street south to "A" Street generally
between 22nd and 33rd Streets; and south from
"A" Street to South Street generally between
27th and 40th Streets.
J-J 8
-------
Region VIII
8-1
-------
Areas Not Anticipated to Meet
the Requirements of the Clean Air Act
STATE OF COLORADO
AREA
POLLUTANT
UNLIKELY
TO ATTAIN
THE
NAAQS
FAILURE TO
COMPLY WITH
SIP CONDITIONS
FAILURE TO
SUBMIT AN
ADEQUATE SIP
Denver area including
Denver County,
portions of Arapahoe County,
portions of Adams County
TSP
X
Pueblo, Pueblo County
TSP
X
X
8-2
-------
Areas With SIP Calls
Areas Without SIP Calls
STATE OF COLORADO
AREA
POLLUTANT
Call For
SIP
No Call For
SIP
Denver area including
Denver County,
portions of Arapahoe County,
portions of Adams County
TSP
X
Pueblo, Pueblo County
TSP
X
8-3
-------
Areas Mot Anticipated to Meet
the Requirements of the Clean Air Act
STATE OF MONTANA
AREA
POLLUTANT
UNLIKELY
TO ATTAIN
THE
NAAQS
FAILURE TO
COMPLY WITH
SIP CONDITIONS
FAILURE TO
SUBMIT AN
ADEQUATE SIP
Missoula, Missoula County
CO
X
X*
Billings, Yellowstone County
CO
X
Great Falls, Cascade County
CO
X
Butte, Silver Bow County
TSP
X
* Area presently has restrictions on construction or modification of ma^or stationary
sources for failure to submit an adequate SIP. Restrictions will remain in effect.
8-4
-------
Areas With SIP Calls
Areas Without SIP Calls
STATE OF MONTANA
AREA
POLLUTANT
Call For
SIP
No Call For
SIP
Missoula, Hissoula County
CO
X
Billings, Yellowstone County
CO
X
Great Falls, Cascade County
CO
X
Butte, Silver Bow County
TSP
X
8-5
-------
Disposition of Tier II Areas
State: Montana
Area and Pollutant: Missoula CD
Reason on Tier II:
The Missoula plan was originally disapproved by EPA in 1980 because no
plan was submitted, only a schedule for submitting a plan. In August 1981, a
plan was submitted which projected attainment of the standard by 1985. For a
variety of reasons an FR notice proposing to approve the Missoula plan has yet
to be published.
Construction Ban: Yes, 45 FR 14035, March 4, 1980.
SIP Control Measures: Reconstruction of intersection to improve traffic flow.
Final Action By: FR notice proposing approval is being circulated in Regional
Office. Final notice approving plan will be published by
June 1984.
Recommendation: Process and approve plan in FR.
8-6
-------
State: Montana
Area and Pollutant: Billings CO
Reason on Tier II:
Attainment of the 8-hour standard in Billings depended on the
reconstruction of an intersection. The intersection project was originally
scheduled for completion in 1982, but problems with right-of-way acquisition
precluded this. As a result, Billings had to request an extension, but
because the request was not submitted with the original package it was not
approvable.
Construction Ban: Mo because plan was conditionally approved.
SIP Control Measures: Reconstruction of intersection to improve traffic flow.
Final Action By: FR notice proposing approval is being circulated in Regional
Office. Final FR notice approving plan will be published by
June 1984.
Recommendation: Process and approve plan in FR.
8-7
-------
State: Montana
Area and Pollutant: Great Falls CO
Reason on Tier II:
Great Falls was designated nonattainment for CO in September of 1980 for
violations of the 8-hour CO standard. A plan has been developed which shows
attainment by 1985. The state will take the plan to public hearing in March
1984 and submit the plan to EPA in April 1984.
SIP Control Measures: No specific measures are necessary. Replacement of
older motor vehicles by newer models is expected to
resolve the problem.
Final Action: It is expected that a notice proposing to approve the Great
Falls plan will be drafted in April. Assuming three months to
process proposal, a final FR could be drafted in August and
published in September 1984.
Recommendation: Process and approve plan in the FR.
8-8
-------
Areas Not Anticipated to Meet
the RequireBents of the Clean Air Act
STATE OP UTAH
AREA
POLLUTANT
fTMT. 11 n.T
TO ATTAIN
THE
HAAQS
FAILURE TO
COMPLY WITH
SIP CONDITIONS
FAILURE TO
SUBMIT AN
ADEQUATE SIP
Portions of Salt Uke County
TSP
X*
Salt Lake County and
portions of Tooele County
so2
X**
* Area presently has restrictions on construction or modification of major stationary
sources for failure to submit adequate SIP* Restrictions trill remain in effect.
•* Area presently has restrictions on construction or modification of major stationary
sources for failure to submit an adequate SIP. The revised SIP is currently being evaluated
by EPA. The restrictions vill remain in effect.
8-9
-------
Areas With SIP Calls
Areas Wrthout SIP Calls
STATE OP UTAH
AREA
POLLUTANT
Call For
SIP
No Call For
SIP
Portions of Salt Lake County
TSP
X
Salt. Lake County and
portions of Tooele Cocuity
so2
X
8-10
-------
Salt Lake County and portions of Tooele County - SO2
On August 17, 1981, Utah Submitted a revisions to Its SO2 SIP for the
Kennecott Copper Smelter near Salt Lake City. Additional documentation was
provided in December, 1981. EPA 1s evaluating the revision and will determine
whether it can be approved. Data show the primary standards are being met.
8-11
-------
Region IX
9-1
-------
Areas Not Anticipated to Meet
the Requirements of the Clean Air Act
STATE OF ARIZONA
AREA
POLLUTANT
UNLIKELY
TO ATTAIN
THE
NAAQS
FAILURE TO
COMPLY WITH
SIP CONDITIONS
FAILURE TO
SUBMIT AN
¦ADEQUATE SIP
Phoenix, Maricopa County
-co
X
Phoenix, Maricopa County
03
X
Phoenix, Maricopa County
TSP
X
X*
Tucson, Pima County
CO
X
Tucson, Pima County
TSP
X
Ajo, Pima County
so2
X
X*
Ajo, Pima County
TSP
X
X*
Hayden, Gila & Pinal Counties
S02
X
X*
Hayden, Gila £ Pinal Counties
TSP
X
x«
Miami, Gila County
S°2
X
X*
Miami, Gila County
TSP
X
X*
Morenci, Greenlee County
so2
X
X*
Morenci, Greenlee County
TSP
X
X*
San Manuel, Pinal County
S02
X
X*
Douglas, Cochise County
SO 2
X
X*
Douglas, Cochise County
TSP
X
X*
Paul Spur, Cochise County
TSP
X
X*
* Area presently has restrictions on construction or modification of major stationary
sources for failure to submit an adequate SIP. Restrictions will remain in effect.
9-2
-------
Areas With SIP Calls
Areas Without SIP Calls
STATE OF ARIZONA
AREA
POLLUTANT
With SIP
Calls
Without SIP
Calls
Phoenix, Maricopa County
CO
X
Phoenix, Maricopa County
°3
X
Phoenix, Maricopa County
TSP
X
Tucson, Pisa County
CO
X
Tucson, Pima County
TSP
X
Ajo, Pima County
SO 2
X
Ajo, Pima County
TSP
X
Hayden, Gila & Pinal Counties
so2
X
Hayden, Gila fi Pinal Counties
TSP
X
Miami, Gila County
so2
X
Miami, Gila County
TSP
X
Morenci, Greenlee County
SO 2
X
Morenci, Greenlee County
TSP
X
San Manuel, Pinal County
so2
X
Douglas, Cochise County
so2
X
Douglas, Cochise County
TSP
X
Paul Spur, Cochise County
TSP
X
9-3
-------
'Area
Pollutant
SIP
Call
No
Action
Rationale
Arizona
Phoenix
Maricopa County
The standard of 0.12 ppm hourly average was not attained by
December 31, 1982 at six sites:
Phoenix - N. 52 Street (el =9.4 days/year)
Phoenix - N. 6 Street (e = 6.1 days/year)
Phoenix - 1845 E. Roosevelt (e = 3.5 days/year)
Glendale - W. Olive (e = 1.9 days/year)
Scottsdale - H. Scottsdale Rd. (e = 1.8 days/year)
Scottsdale - fJ. Miller Rd. (e =1.4 days/year)
See SAROAD Report NA 273, January 25, 1984, pages 19 and 20.
In 1983, the standard was exceeded at six sites:
Central Phoenix (5 days above standard)].
South Phoenix (2 days above standard)
Glendale (1 day above standard)
Scottsdale - n. Miller (2 days above standard)
Mesa (1 day above standard)
Indian School Road (3 days above standard)
X Approvable plans demon-
ricopa CO strating attainment by
na 1987 have been submitted
and are being reviewed
by Region 9.
),Morenci,
'den,San Manuel,
imi, Douglas
W
State regulations are in
effect and some sources are
on a compliance schedule
while the others are awaiting
publication of NSO regs and
will apply for NSO's when the
regs are published.
IThe value "e", the expected number of days per calendar year
with maximum hourly average concentrations above the NAAQS, has
been provided for the monitoring sites which did not attain the
standard by December 31, 1962. The value "e" is based on ambient
ozone data for the years 1980 through 1982 and is calculated per
^0 CFR 50.9 and Appendix H It should be noted that "e" is often
higher than the number of days actually monitored with concentrations
above the NAAQS The "e" values were not calculated for 1983 since
ozone data for the full year is not yet summarized. Instead,
the actual number of days above the NAAQS during 1983 have been
provided, where available, by the local air pollution control
agency.
9-4
-------
Response To Comments
Three comments were received during the public comment period
from three air quality agencies in Arizona. The comments indicated
that no extension for attaining the ozone standard in Phoenix was
requested based upon three factors: 1) ambient monitoring
"trends"; 2) no "violation days" during 1982; and 3) the "high
probability" that no violations would occur in 1983.
In response to these comments, EPA believes that air quality
"trends" are not a criteria for judging attainment of the NAAQS.
In 1982, the standard was exceeded at three sites;
Phoenix - N. 6 St. (e = 1.2 days/year)
Phoenix - 1845 E. Roosevelt (e = 1.1 days/year)
Glendale - W. Olive (e = 1.1 days/year)
In 1983, the standard was exceeded at six sites:
Central Phoenix (5 days above standard)2
South Phoenix (2 days above standard)
Glendale (1 day above standard)
Scottsdale - N. Miller (2 days above standard)
Mesa (1 day above standard)
Indian School Road (3 days above standard)
2 The "e" values were not calculated for 1983 since ozone data
for the full year is not yet summarized. Instead, the actual
number of days above the NAAOS during 1983 have been provided,
where available, by the local air pollution control agency.
9-5
-------
United States Regional Administrator Region 9
Environmental Protection 215 Fremont Street Arizona, California
Agency San Francisco CA 94105 Hawaii, Nevada
Pacific Islands
&EPA
February 24, 1984
The Honorable Bruce Babbitt
Governor of Arizona
State Capitol Building
Phoenix, AZ 85007
Dear Governor Babbitt:
The Environmental Protection Agency (EPA) hereby
notifies you pursuant to Section 110(a)(2)(H) of the Clean
Air Act, 42 U.S.C. §§7410(a)(2)(H), that it finds the Arizona
State Implementation Plan (SIP) substantially inadequate
to achieve the National Ambient Air Quality Standards (NAAQS)
for ozone in Maricopa County. The basis for the finding of
inadequacy is EPA's conclusion that the area is covered by a
conditionally approved Part D plan and is still experiencing
NAAQS violations. Details of the bases for this conclusion
are listed in the attachment.
EPA calls upon the State to cure the inadequacies in the
SIP by revising it. For areas with fully or conditionally
approved plans, EPA is extending the Section 110(c)(1)(C)
revision period to one year from today to provide a sufficient
amount of time to adopt and submit revisions. The State
must submit a schedule for the development of the necessary
SIP revisions to EPA not more than sixty days from today.
If the State does not submit a curative SIP revision to EPA
within one year from today EPA will proceed to propose a
construction ban and funding restrictions for the area in
question. The construction ban prohibits major stationary
source construction or modification in affected areas. The
funding restrictions limit Clean Air Act funds and sewage
treatment construction grants in affected areas. [Note:
EPA is not now calling for any revisions in particulate
matter nonattainment areas.]
EPA has determined that the carbon monoxide SIP has been
inadequate to attain the NAAQS in Pima and Maricopa Counties
by December 31, 1982. SIP revisions for these two areas have
been submitted to correct these inadequacies and are currently
under review. Our preliminary review of the revised plan for
Maricopa County shows that the plan lacks the legal authority
for an expanded inspection/maintenance program. Unless such
authority is granted by the legislature, EPA cannot approve
the carbon monoxide plan for Maricopa County. If EPA cannot
approve this plan, then we will proceed to propose a construc-
tion ban and funding restrictions for Maricopa County.
9-6
-------
-2-
With respect to the rural industrial SO2 nonattainment
areas of Ajo, Hayden, Miami, Douglas, Morenci and San Manuel,
EPA is not requesting the State to submit a Part D SIP at
this time. However, when EPA takes final action on the
non-ferrous smelter regulations, EPA will request the State
of Arizona to submit compliance schedules or Nonferrous
Smelter Orders as part of the Arizona State Implementation
Plan.
EPA's finding of inadequacy and call for SIP revision is
issued in accordance with the general policy that appears in
the Federal Register for November 2, 1983, entitled "Compliance
with the Statutory Provisions of Part D of the Clean Air Act"
(48 Fed. Reg. 50686). EPA's "Guidance Document for the
Correction of Part D SIPs for Nonattainment Areas" (January
1984) contains more information on the content of the revisions
EPA is requesting. If the State does not submit curative
SIP revisions to EPA within the time frames indicated above,
EPA will proceed with actions outlined in the November 2
Policy.
EPA plans to publish a notice of this finding of inadequacy
and call for SIP revision in the Federal Register 'shortly.
EPA will make additional findings of SIP inadequacy and
calls for revisions if the Agency receives air quality monitor-
ing data in the future indicating that other areas of the
State covered by fully or conditionally approved Part D
plans continue to experience NAAQS violations.
At this time, we also request that you reaffirm in writing
the organization or agency which you wish to designate as
lead planning agency for the development of the plans in each
nonattainment area in the State of Arizona pursuant to Section
174(a) o'f the Clean Air Act.
Any questions regarding this letter should be referred to
David P. Howekamp, Director of the Air Management Division
at (415) 974-8201.
Sincerely
Judith E. Ayres
Regional Administrator
Enclosure
9-7
-------
Areas Not Anticipated to Meet
the Requirements of the Clean Air Act
STATE OF CALIFORNIA
AREA
POLLUTANT
UNLIKELY
TO ATTAIN
THE
NAAQS
FAILURE TO
COMPLY WITH
SIP CONDITIONS
FAILURE TO
SUBMIT AN
ADEQUATE SIP
South Coast Air Basin
(Metropolitan Los Angeles
includung Orange County-all,
Riverside County-part,
San Bernardino County-part,
Los Angeles County-part)
N0X
X
South Coast Air Basin
(Metropolitan Los Angeles,
including Orange County-all,
Riverside County-part,
San Bernardino County-part,
Los Angeles County-part)
TSP
X
San Diego County
TSP
X
Santa Barbara County
(Western-Non-AQMA Part)
TSP
X
X
Ventura County (South Part)
TSP
X
X
Fresno County
TSP
X
X
Kern County
(San Joaquin Valley Part)
°3
X
X
Kern County
(San Joaquin Valley Part)
TSP
X
X
Kern County
(Bakersfield Metro Area)
CO
X
X
Kings County
TSP
X
X
San Joaquin County
TSP
X
Madera County
TSP
X
X
Merced County
TSP
X
X
Stanislaus County
TSP
X
X
9-8
-------
Areas Not Anticipated to Meet
the Requirements of the Clean Air Act
STATE OP CALIFORNIA
AREA
POLLUTANT
UNLIKELY
TO ATTAIN
THE
NAAQS
FAILURE TO
COMPLY WITH
SIP CONDITIONS
FAILURE TO
SUBMIT AN
ADEQUATE SIP
Tulare County
TSP
X
X
Tulare bounty
03
X
Los Angeles County
(Lancaster Area)
TSP
X
X*
Santa Barbara County
(Southern Area)
CO
X
Butte County
CO
X
Butte County
03
X
Sutter County
03
X
Yuba County
<>3
X
Kings County
°3
X
Madera County
03
X
Merced County
°3
X
Imperial County
03
X
San Bernardino County
(Desert AQMA)
03
X
San Bernardino County
(Victorville area)
TSP
X*
~Area presently has restrictions on construction or modification of major stationary
sources for failure to submit an adequate SIP. Restrictions will remain in effect.
9-9
-------
Areas With SIP Calls
Areas Without SIP Calls
STATE OF CALIFORNIA
AREA
POLLUTANT
With SIP
Cal Is
Without SIP
Calls
South Coast Air Basin
(Metropolitan Los Angeles
includung Orange County-all,
Riverside County-part,
San Bernardino County-part,
Los Angeles County-part)
NOx
X
South Coast Air Basin
(Metropolitan Los Angeles,
including Orange County-all,
Riverside County-part,
San Bernardino County-part,
Los Angeles County-part)
•TSP
X
San Diego County
TSP
X
Santa Barbara County
(Western-Non-AQMA Part)
TSP
X
Ventura County (South Part)
TSP
X
Fresno County
TSP
X
Kern County
(San Joaquin Valley Part)
°3
X
Kern County
(San Joaquin Valley Part)
TSP
X
Kern County
(BaJcersfield Metro Area)
CO
X
Kings County
TSP
X
San Joaquin County
TSP
X
Madera County
TSP
X
Merced County
TSP
X
Stanislaus County
TSP
x
9-10
-------
Areas With SIP Calls
Areas Without SIP Calls
STATE OF CALIFORNIA
AREA
POLLUTANT
With SIP
Calls
Without SIP
Calls
Tulare County
TSP
X
Tulare bounty
°3
X
Los Angeles County
(Lancaster Area)
TSP
X
Santa Barbara County
(Southern Area)
CO
X
3utte County
CO
X
Butte County
°3
X
Sutter County
°3
X
Yuba County
°3
X
Kings County
<>3
X
Madera County
°3
X
Merced County
°3
X
Imperial County
°3
X
San Bernardino County
(Desert AQMA)
°3
X
San Bernardino County
(Victorville area)
TSP
X
9-11
-------
Kern County
(San Joaquin Valley portion)
O3 - The standard of 0.12 ppm hourly average was not attained by
December 31, 1982 at three sites:
Edison (e1 = 37.8 days/year)
Oildale - Manor Street (e = 12.1 days/year)
Bakersfield - Chester (e = 7.2 days/year)
See SAROAD Report NA 273, January 25, 1984, pages 55,59 and 62.
TThe value "e", the expected number of days per calendar year
with maximum hourly average concentrations above the NAAQS, has
been provided for the monitoring sites which did not attain the
standard by December 31, 1982. The value "e" is based on ambient
ozone data for the years 1980 through 1982 and is calculated per
40.CFR 50.9 and Appendix H.
9-12
-------
South Coast Air Basin
(Metropolitan Los Angeles including Orange County - all; Riverside
County - part; San Bernardino County - part; Los Angeles County -
part)
NC>2 - The standard of 0.05 ppm annual mean was not attained by
December 31, 1982 at eleven sites:
Burbank (0.071 ppm)
Los Angeles - N. Main (0.067 ppm)
Pico Rivera (0.061 ppm)
Lennox (0.059 ppm)
Pasadena - Walnut (0.058 ppm)
Lynwood (0.057 ppm)
Pomona (0.055 ppm)
North Long Beach (0.054 ppm)
Whittier (0.054 ppm)
Pasadena - Wilson (0.054 ppm)
West Los Angeles - Robertson (0.052 ppm)
See California Air Quality Data Annual Summaries of 1981
and 1982.
9-13
-------
CO
Kern
Kern County currently has
eight quarters of viola-
tion free CO data; there
fore, a revised control
strategy does not appear
to be necessary at this
time.
9-14
-------
United States
Environmental Protection
Agency
Regional Administrator
215 Fremont Street
San Francisco CA 94105
Region 9
Arizona, California
Hawaii. Nevada
Pacific Islands
&EPA
February 24, 1984
The Honorable George Deukmejian
Governor of California
State Capitol Building
Sacramento, CA 95814
Dear Governor Deukmejian:
The Environmental Protection Agency (EPA) hereby noti-
fies you pursuant to Section 110(a)(2)(H) of the Clean Air
Act/ 42 U.S.C. §7410(a)(2)(H), that it finds the California
State Implementation Plan (SIP) substantially inadequate to
achieve national ambient air quality standards (NAAQS) for
ozone in Kern County and nitrogen dioxide (NO2) in the South
Coast Air Basin. The basis for the finding of inadequacy is
EPA's conclusion that those areas are covered by conditionally
approved plans but are still experiencing violations of the
NAAQS. The enclosure also details the basis for t;his conclu-
EPA calls upon the State to cure the inadequacies in
the SIP by revising it. EPA is extending the Section 110(c)(1)(C)
revision period to one year from today to provide a sufficient
amount of time to adopt and submit revisions to the plans.
The State must submit a schedule for the development of the
necessary SIP revisions to EPA not more than sixty days from
today. If the State does not submit curative SIP revisions
to EPA within one year from today EPA will proceed to propose
sanctions authorized by the Clean Air Act. Specifically, this
would entail the imposition of a construction ban and funding
restrictions for the areas in question. The construction ban
prohibits major stationary source construction or modification
in affected areas. The funding restrictions limit Clean Air Act
funds and sewage treatment construction grants in affected areas.
[NOTE: EPA is not now calling for any revisions in particulate
matter nonattainment areas.]
In addition, while EPA is not making a formal finding of
non-implementation at this time, you should be advised that
EPA has reason to believe that the South Coast Air Basin
portion of the SIP for NO2 has not been implemented pursuant
to Clean Air Act requirements. EPA will transmit a detailed
description of its findings to the South Coast Air Quality
Management District and the Air Resources Board (ARB) and
will provide an opportunity to these agencies to demonstrate
that the NO2 plan has been implemented to the fullest extent
possible. If this demonstration cannot be made, EPA intends
to propose a construction ban and funding restrictions for
failure to carry out the adopted NO2 Plan.
3 ion
9-15
-------
EPA's finding of inadequacy and call for SIP revision is
issued in accordance with the general policy that appears in the
Federal Register for November 2, 1983, entitled "Compliance with
the Statutory Provisions of Part D of the Clean Air Act" [48 FR
50686]. This policy also addresses the actions which EPA can
take with regard to areas which do not implement approved plan
provisions. EPA's "Guidance Document for the Correction of
Part D SIPs for Nonattainment Areas"' (January 1984) contains
more information on the content of the revisions EPA is requesting.
If the State does not submit curative SIP revisions to EPA within
an appropriate time frame, EPA will proceed under its November 2
policy to propose a construction ban and funding restrictions
for the areas in question.
EPA plans to publish a notice of this finding of inade-
quacy and call for SIP revision in the Federal Register shortly.
In addition, if necessary, within 60 days EPA will prepare a
notice proposing to impose sanctions for failure to carry out
the NO2 plan for the South Coast Air Basin.
EPA will make additional findings of SIP inadequacy and
calls for revisions if the Agency receives air quality moni-
toring data in the future indicating that other areas of the
State covered by fully or conditionally approved plans continue
to experience NAAQS violations.
Any questions regarding this letter should be referred to
David P. Howekamp, Director of the Air Management Division of
EPA Region 9 at (415) 974-8201.
Sincerely
Enclosure
9-16
-------
Areas Not Anticipated to Meet
the Requirements of the Clean Air Act
TERRITORY OF GUAM
AREA
POLLUTANT
UNLIKELY
TO ATTAIN
THE
NAAQS
FAILURE TO
COMPLY WITH
SIP CONDITIONS
FAILURE TO
SUBMIT AN
ADEQUATE SIP
Tanguisson
SO 2
X
X*
•Area presently has restrictions on the construction or modification of major stationary
sources for fialure to submit an adequate SIP. Restrictions will remain in effect
9-17
-------
Areas With SIP Calls
Areas Without SIP Calls
TERRITORY OF GUAM
AREA
POLLUTANT
With SIP
Without SIP
Calls
Calls
Tanguisson
SO 2
X
9-18
-------
Areas Mot Anticipated to Meet
the Requirements of the Clean Air Act
STATE OF NEVADA
AREA
POLLUTANT
UNLIKELY
FAILURE TO
FAILURE TO
TO ATTAIN
COMPLY WITH
SUBMIT AN
THE
SIP CONDITIONS
ADEQUATE SIP
NAAQS
Las Vegas, Clark County
X
Las Vegas, Clark County
TSP
X
Reno, Washoe County
TSP
X
McGill, White Pine County
S02
X
9-19
-------
Areas With SIP Calls
Areas Without SIP Calls
STATE OF NEVADA
AREA
POLLUTANT
With SIP
Calls
Without -SIP
Calls
Las Vegas, Clark County
°3
X
Las Vegas, Clark County
TSP
X
Reno, Washoe County
TSP
X
McGill, White Pine County
SO 2
X
9-20
-------
Area
Pol 1utant
SIP
Call
No
Action
Rationale
NEVADA
Las Vegas
Clark County
"OT
The standard of 0.12 ppm hourly average was not attained by
December 31, 1982 at one site:
Henderson (el = 9.5 days/year)
In addition, in 1983 the standard was exceeded at one site:
Las Vegas - Casino Center (1 day over standard)
See SAROAD Report NA 273, January 25, 1984, p. 10.
White Pine S02 X A federal regulation {52.1475)
is already in place (promul-
gated in 1975). Kennecott
is the only source. If it
were in compliance, the area
would be in attainment.
§119 of the Act provides
that smelters may get a
variance from SIP limits
up to 1/1/88. Kennecott
will apply for a NSO as soon
as new regs are published.
9-21
-------
United States
Environmental Protection
Agency
Regional Administrator
215 Fremont Street
San Francisco CA 94105
Region 9
Arizona, California
Hawaii, Nevada
Pacific Islands
•SEPA
February 24, 1984
The Honorable Richard H. Bryan
Governor of Nevada
State Capitol Building
Carson City, NV 89710
Dear Governor Bryan:
The Environmental Protection Agency (EPA) hereby notifies
you pursuant to Section 110(a)(2)(H) of the Clean Air Act,
42 U.S.C. §7 410(a)(2)(H), that it finds the Nevada State Imple-
mentation Plan (SIP) substantially inadequate in providing for
attainment of the national ambient air quality standards (NAAQS)
for ozone in Clark County. The basis for the finding of inade-
quacy is EPA's conclusion that the approved plan does not
satisfactorily address the ozone violations that have occurred
in the Southeast Valley portion of the County. The enclosure
also details the basis for this conclusion.
EPA calls upon the State to cure the inadequacies in the
SIP by revising it. Guidance on the content of these revisions
appears in a recent EPA publication entitled "Guidance Document
for Correction of Part D SIP's for Nonattainment Areas." EPA
is extending the Section 110(c)(1)(C) revision period to one
year from today to provide'a sufficient amount of time to
adopt and submit revisions. The State must submit a schedule
for the development of the necessary SIP revisions to EPA
not more than sixty days from today. If the State does not
submit curative SIP revisions to EPA within one year from
today EPA will proceed to propose sanctions authorized by the
Clean Air Act. Specifically, this would entail the imposi-
tion of a construction ban and funding restrictions for the
areas in question. The construction ban prohibits major
stationary source construction or modification in affected
areas. The funding restrictions limit Clean Air Act funds and
sewage treatment construction grants in affected areas.
[Note: EPA is not now calling for any revisions in particulate
matter nonattainment areas.]
EPA's finding of inadequacy and call for SIP revision is
issued in accordance with the general policy that appears in the
Federal Register for November 2, 1983, entitled "Compliance with
the Statutory Provisions of Part D of the Clean Air Act" [48 FR
50686]. EPA's "Guidance Document for the Correction of Part D
SIPs for Nonattainment Areas" (January 1984) contains more
information on the content of the revisions EPA is requesting.
9-22
-------
-2-
EPA plans to publish a notice of this finding of inade-
quacy and call for SIP revision in the Federal Register shortly.
EPA will make additional findings of SIP inadequacy and calls
for revisions if the Agency receives air quality monitoring
data in the future indicating that other areas of the State
covered by fully or conditionally approved plans continue to
experience NAAQS violations.
Any questions regarding this letter should be referred to
David P. Howekamp, Director of the Air Management Division of
EPA Region 9 at (415) 974-8201.
Sincerely
Judith E. Ayres
Regional Administrator
Enclosure
9-23
-------
Region X
10-1
-------
Areas Not Anticipated to Meet
the Requirements of the Clean Air Act
STATE OF IDAHO
AREA
POLLUTANT
UNLIKELY
TO ATTAIN
THE
NAAQS
FAILURE TO
COMPLY WITH
SIP CONDITIONS
FAILURE TO
SUBMIT AN
ADEQUATE SIP
Pocatello area including
Bannock County, and
Power County
TSP
X
Soda Springs/Conda,
Caribou County
TSP
X
10-2
-------
Areas With SIP Calls
Areas Without SIP Calls
STATE OF IDAHO
AREA
POLLUTANT
Call For
SIP
• No Call For
SIP
Pocatello area including
Bannock County, and
rower County
TSP
X
Soda Springs/Conca,
Caribou County
TS?
X
10-3
-------
Areas Sot Anticipated to Meet
the Requirements of the Clean Air Act
STATE OP ORBQOI
AREA
P0£URAHT
UHLZXEZ.7
TO ATTA33
THE
BAAQS
FAILURE TO
COMPLY WITH
SIP COHDITXOHS
FAXLDRE TO
SUBMIT AH
AOEQOATB SIP
Medford, Jaduoa County
TSP
X*
•Area presently has restrictions on construction or Modification of major
stationary sources for failure to submit an adequate SIP, Restrictions
trill remain in affect.
10-4
-------
Areas With SIP Calls
Areas Without SIP Calls
STATE OP ORBGOH
AS2&
POLLOTMT
Call For
No Call For
SIP
SIP
Bedford, Jadcsoo County
TSP
X
J.0-5
-------
Areas Hot Anticipated to Meet
the Requireaents of the Clean Air Act
STATE OP VASHXNGTOa
AREA
POLLUTAHT
UHLTTKLT
TO ASTAIH
THE
HAAQS
FAILURE TO
COMPLY WITH
SIP CONDITIONS
FAILURE TO
SUBMIT AH
ADEQUATE SIP
Tacoaa, Pierce County
CO
z
X*
Tacoaa, Pierce County
TSP
X
Spokane, Spokane County
CO
X
Spokane, Spokane County
TSP
X
Vancouver, Clark County
TSP
X
Seattle, King County
TSP
X
* Recent air quality data indicate that peak concentrations are occurring in a
different area froa that originally determined. The existing, EPA approved, 1979
State Iapleaentation Plan ensures attainment of the HAAQS by Deceaber 1982 only
in -areas originally deterained to be nonattainaent.- The State has not yet provided
an implementation plan adequate to ensure attainment of the HAAQS by Deceaber 1982
in the newfound area.
10-6
-------
Areas With SIP Calls
Areas Without SIP Calls
ST&TE OF WASHXNGTOH
AREA
PGLLUTAHT
Call For
SIP
No Call For
SIP
Tacoia, Pierce Coanty
CO
X
Tacoaa, Pierce Coanty
TSP
X
Spokam», Spokane Coanty
CO
X
Spokane, Spokane Coanty
TSP
X
Vancouver, Clark Coanty
TSP
X
Seattle, King Coanty
TSP
X
10-7
-------
Spokane, Washington Carbon Monoxide - EPA is requiring the
implementation of a contingency provision for I/m which is
already contained in the Washington SIP (see copy of EPA
letter dated January 4, 1984). A minor SIP revision is also
being called for which identifies the actual start-up date of
the mandatory I/M program and attainment date for the CO
standard. The specific date for submittal of this revision
is being negotiated between the State and EPA. Information
on boundaries that you requested was previously supplied as
part of the February 3, 1983 action.
Tacoma, Washington Carbon Monoxide - A small 3 block by 6
block area in the Tacoma Central Business District was
designated nonattainment on December 18, 1981. Accordingly,
under the current EPA policy, the Tacoma nonattainment area
is being treated as a newly discovered nonattainment area. A
SIP revision addressing the CO problem in Tacoma has already
been submitted to EPA. A separate Federal Register Notice
will be submitted addressing the approvability of this SIP
revision (Notice is in draft at this time). Thus, Tacoma
should be removed from the list of Tier II areas.
10-8
------- |