EVALUATION OF
NATIONAL AMBIENT
AIR QUALITY
STANDARDS
(naaqs)
NON-ATTAINMENT:
METHODOLOGY AND
EXAMPLE TOTAL
SUSPENDED
PARTICULATE
ANALYSIS FOR
SPOKANE COUNTY
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION X, AIR & HAZARDOUS MATERIALS DIVISION
SEATTLE, WASHINGTON fttlOl
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EPA 910/9-75-016
EVALUATION
OF
NATIONAL AMBIENT AIR QUALITY STANDARDS (NAAQS)
NON-ATTAINMENT: METHODOLOGY AND
EXAMPLE TOTAL SUSPENDED PARTICULATE ANALYSIS
FOR
SPOKANE COUNTY
by
Victor Yamada and Robert Missen
PACIFIC ENVIRONMENTAL SERVICES, INC.
1930 14th Street
Santa Monica, California 90404
and
Michael Schultz
U.S. ENVIRONMENTAL PROTECTION AGENCY
Region X
1200 Sixth Avenue
Seattle, Washington 98101
BOA No. 68-02-1378 TASK 16
EPA PROJECT OFFICER - MICHAEL SCHULTZ
Prepared for
U.S. ENVIRONMENTAL PROTECTION AGENCY
Region X
Air Programs Branch
Air and Hazardous Materials Division
1200 Sixth Avenue
Seattle, Washington 98101
January 1976
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ACKNOWLEDGMENT
The authors wish to express particular gratitude for the
responsiveness and cooperation displayed by members of the Spokane
County Air Pollution Control Authority. Without their assistance in
providing comprehensive air quality and emissions data as welt as
related technical information, the "Total Suspended Particulate
Analysis for Spokane County" viould not have been possible.
We also wish to thank the Washington State Department of
Ecology for their aid in providing air quality and available
meteorological data.
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EXECUTIVE SUMMARY
Environmental Protection Agency (EPA) has placed high
priority during FY 1976 on identifying State Implementation Plan (SIP)
control strategy deficiencies. In response to this, a methodology
was developed to provide a framework within which an agency may work
to evaluate control strategy deficiencies in light of National
Ambient Air Quality Standards (NAAQS) non-attainment. The methodology,
tailored to the evaluation of total suspended particulates (TSP) and
sulfur dioxide (S02), was then applied to an analysis of the TSP non-
attainment problem in Spokane County.
The approach first required completion of an air quality profile
for the non-attainment area of concern. An air profile is a product
representing the compilation and reduction of available ambient air
quality, emission and relevant meteorological data. From this infor-
mation and the findings from any previously conducted related studies,
source-receptor relationships are to be defined. The development,
implementation, and enforcement of the existing SIP control strategy
may then be analyzed. Finally, the corrective actions necessary for
attainment of NAAQS are to be delineated.
The method of assessing source-receptor relationships relies on
the logical analysis of available data and information as opposed to
emphasizing a mathematical modeling approach. This assessment is
divided into (1) seasonal and annual analyses and (2) a day-by-day
analysis of data. The long-term analysis may involve:
1. Correlating seasonal meteorological patterns with seasonal
emission activity patterns.
2. Performing other statistical evaluations such as correla-
tion analyses among sampling sites.
3. Evaluating the findings from previous modeling or filter
analysis studies.
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4. Evaluating the worth of modeling, and applying as needed
and capabilities permit.
The day-by-day analysis may include activities such as:
1. Isolating days and monitoring sites where short-term
standards were violated.
2. Determining what meteorological conditions could have
accounted for the NAAQS violations.
3. Performing modeling to determine, under worst case condi-
tions, what the impact of key sources may have been.
4. Performing microscopic analyses of selected filters to
determine likely major contributing sources on violation days.
5. Performing statistical evaluations.
An evaluation of the State Implementation Plan (SIP) may
include:
1. A review of the SIP for correctness of data input.
2. Comparison of regulation stringency with reasonably avail-
able control technology (RACT).
3. A review of the control strategy implementation and en-
forcement.
Corrective actions required for ensuring attainment may include:
1. Increased enforcement activity, and/or
2. Waiting for sources now on compliance schedules to come
into compliance, and/or
3. Specific control strategy revisions for those aspects of
control strategies found to be substantially inadequate.
The analysis of the TSP non-attainment problem in Spokane
disclosed findings which include the following:
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1. The geographical area of non-attainment for primary TSP
NAAQS appears to extend in a band from the Spokane central downtown
area east-northeasterly for approximately 3.5 miles (5.6 kilometers).
2. The two stations with the highest TSP concentrations are
those located at Crown Zellerbach and the Aluminum Supply Company.
Both are industrial areas. The highest annual geometric mean for
3
CY 1974 in the Spokane area was 90 ^g/m at the Crown Zellerbach
site. During FY 1975 which was the first 12 months of record at
the Aluminum Supply Company monitoring site, a geometric mean of
3
119/xg/m was recorded.
3. A strong pattern of high TSP concentrations during the
relatively dry months of July through October is exhibited at all
five sampling sites in the above described TSP non-attainment area.
4. Lower wind speeds are prevalent during the late summer and
early fall months.
5. The largest single point source in Spokane County is Kaiser
Mead, a primary aluminum reduction plant. Emissions are 1482 tons
per year of particulates, based on the 1975 emissions inventory.
The impact of these emissions on ambient air quality could not be
made in this evaluation due to inadequate data. Kaiser Mead is
located approximately 4 miles (6.4 km) north of the city center and
the TSP non-attainment area.
6. Seasonal activities include agricultural harvest activi-
ties with associated increased grain handling operations and field
burning, and gravel pit-crushing-screening-stockpiling operations.
These activities are reported to be greatest during the summer and
early fall months. Four different companies conduct gravel pit,
crushing, screening, and stockpiling operations within a 0.5 mile (0.8 km)
radius of the Aluminum Supply Company monitor. Combined emissions
are estimated to be 111 tons per year plus 25 tons per year from
a rotary asphalt dryer. Production is strongly dependent upon the
seasonal demand for gravel and concrete.
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7. As of 1974, it was estimated that 240 miles (384 km) of
dirt roads in the City of Spokane contributed 1,000 tons of parti-
culates annually. Within a radius of 0.5 mile (0.8 km) of the Crown
Zellerbach and Aluminum Supply Company monitors, there are (as of
January 1974) approximately 7.8 (12.5) and 2.4 (3.8} miles (km) of
unpaved roads respectively. Calculated emissions show that these
roads in the area of the Crown Zellerbach monitor contribute approxi-
mately 44 tons per year of particulates less than 10 microns in size.
The 2.4 miles (3.8 km) of roads around the Aluminum Supply Company
monitor were calculated to contribute 12 tons of less than 10 microns
particulates annually. Emissions are likely to be concentrated during
the dry part of the year.
8. The data shows a good correlation between dry periods and
ambient TSP values. An analysis of 27 days with ambient TSP concen-
3
trations in excess of 150 ^g/m showed that 25 of the days were pre-
ceeded by rainless periods of three days to over one month.
9. No correlation between wind direction and TSP concentrations
was rioted. Such a correlation was attempted for the Aluminum Supply
Company and Crown Zellerbach monitors for August through October 1974.
15
10. Droege and Clark performed a special study in 1972 and
1973 to describe the TSP problem in Spokane County. Findings include:
a. Higher TSP concentrations are found on dry days
as opposed to days with precipitation, regardless
of the time of year.
b. TSP concentrations are higher during the summer
than the winter.
c. High TSP concentrations are associated with strong
winds and low humidity.
d. Considering the sampling months of May, August
through September, November and January, the metals
and organic composition were highest in November.
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e. Only half as many filters were in the brown-green
range (as opposed to gray) during the November/
January sampling periods compared to the May/
August - September sampling period.
11. The rollback calculations upon which the TSP control
strategy was based were strongly deficient -with respect to the cor-
rectness of data input. Maximum ambient TSP concentrations were
much higher than shown by available data at the time of SIP deve-
lopment. Emission inventory figures were also seriously under-
estimated, due primarily to the omission of unpaved roads.
It was concluded that fugitive dust/fugitive industrial
emissions are the likely major cause of TSP non-attainment in Spokane.
The likely major contributors are (1) unpaved roads, (2) emissions
from gravel pit, rock crushing, screening, and stockpiling operations,
and (3) possibly natural wind blown dust.
Recommended corrective actions include:
1. Initiation of a program to control emissions from unpaved
roads to the City of Spokane.
2. Reassess the magnitude of fugitive emissions from industrial
operations in the geographical non-attainment area. Re-evaluate
the compliance status of such sources.
3. Conduct a special monitoring study to determine the impact
of emissions from gravel pit - crushing - screening - stockpiling
operations on ambient air qua! ity.
4. Determine RACT for gravel pit - rock crushing - screening -
stockpiling operations. Compare existing emission controls with RACT
for those operations conducted in the Spokane city area.
5. Consider revising the control strategy through the additions
of specific fugitive emission regulations.
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EVALUATION
OF
NATIONAL AMBIENT AIR QUALITY STANDARDS (NAAQS)
NON-ATTAINMENT: METHODOLOGY
7
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TABLE OF CONTENTS
Section Page
I. BACKGROUND 9
II. PURPOSE 12
III. APPROACH OVERVIEW 13
IV. DETAILED APPROACH 18
A. UPDATE OF AIR PROFILES 18
B. ASSESSMENT OF SOURCE RECEPTOR
RELATIONSHIPS 18
C. ANALYSIS OF EXISTING STATE IMPLEMENTATION
PLANS 23
V. SUMMARY, CONCLUSIONS AND RECOMMENDATIONS .... 29
APPENDIX A. AVAILABLE DATA SOURCES
LIST OF FIGURES
Figures Page
1. OVERALL NON-ATTAINMENT ANALYSIS 11
2. FLOW DIAGRAM FOR EVALUATION METHODOLOGY .... 17
3. DEVELOPMENTAL ASPECTS OF A CONTROL STRATEGY . . 25
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I. BACKGROUND
With the realization that a number of Air Quality Control
Regions (AQCRs) would not be meeting National Ambient Air Quality
Standards (NAAQS) by the Congressionally established attainment
date of July 1975 the Environmental Protection Agency (EPA) is
placing high priority during Fiscal Year (FY) 1976 on identifying
State Implementation Plan (SIP) control strategy deficiencies.
Where plans are found to be substantially inadequate to ensure
attainment of NAAQS, EPA is to notify the States of the deficiencies
and request corrective action. As required by EPA Headquarters,
this notification is to appear in the Federal Register by July 1,
1976. A description and outline of this requirement appears in
OAQPS Draft Guideline No. 1.2-011 entitled "Guidelines for Deter-
mining the Need for Plan Revisions to the Control Strategy Portion
of the Approved State Implementation Plan."
In preparation for this activity, EPA Region X, during FY 1975,
designated 20 counties (including two Alaska boroughs) as priority
abatement areas (PAAs). PAAs were defined as counties (or Alaska
boroughs) where attainment of primary NAAQS by July 1975 for one or
more criteria pollutants was not expected. During the latter half
of FY 1975 and first month of FY 1976, an air profile was com-
pleted for each PAA. An air profile is a product representing the
compilation and reduction of all available ambient air quality,
emission, and pertinent meteorological data. The primary purpose of
a profile is to address the magnitude and geographical extent of the
non-attainment problem as well as make a preliminary assessment, where
possible, of the reasons for non-attainment of NAAQS. Thus, the
profile is envisioned as being the foundation upon which the more
specific non-attainment evaluation is to be built.
EPA Region X has worked closely with the states in outlining
the tasks necessary to complete the non-attainment evaluations. The
states agreed to complete the following in their FY 1976 work plans:
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1. Make attainment - non-attainment determinations on all
anbient data which has not been submitted to Region X.
2. Perform profile evaluations for all non-attainment areas.
This includes updating, where necessary, existing profiles for PAAs
and constructing profiles for any additional non-attainment areas.
3. Complete specific non-attainment evaluations for each
non-attainment area except where non-attainment of standards is
documented as being due solely to fugitive dust from natural or
agricultural practices.
4. Recommend specific SIP control strategy revisions or more
stringent enforcement policies where necessary to ensure attainment
of NAAQS.
Figure 1 depicts the organization of those non-attainrnent
evaluation activities as envisioned by EPA Region X. Note that
the initiation of a non-attainment evaluation requires the comple-
tion of both attainment - non-attainment determination and profile
tasks. EPA Region X has agreed to provide technical assistance to
the states in carrying out these tasks.
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Figure 1. OVERALL NON-ATTAINMENT ANALYSIS
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II. PURPOSE
The purpose of this document is to describe a detailed
methodology specific to Region X for the evaluation of the non-
attainment of total suspended particulate (TSP) and sulfur dioxide
(S02) NAAQS. It is felt, however, that the same general approach
and many of the specific concepts presented in this document are
applicable to carbon monoxide {CO), photochemical oxidants and
nitrogen oxides (NO ) as well.
X
This methodology is intended for use by EPA Region X, State
and local agency personnel as a guideline for identifying source-
receptor relationships and evaluating existing SIP control strate-
gies and control strategy enforcement. The methodology presented
here is not intended to be a step-by-step procedure which must be
strictly adhered to, but is more a recommended framework or guide-
line within which an agency may work to answer those questions
necessary to evaluate NAAQS non-attainment problems. Due to the
unique nature of individual non-attainment situations, it is
recognized that no single method will meet the specific needs of
all non-attainment areas. Each evaluation must be approached on
a case-by-case basis. Thus, it is expected that considerable
ingenuity will be required in performing non-attainment evaluations.
The methodology presented here is intended to be used with latitude
and flexibility limited only by the requirement that SIP deficiencies
and the reasons for NAAQS non-attainment be documented and corrective
actions leading to attainment of NAAQS be proposed.
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III. APPROACH OVERVIEW
The proposed methodology for evaluation of the non-attainment
of NAAQS involves identifying the extent of non-attainment and then
determining the causes of that non-attainment. This procedure can
be divided into three evaluation steps - 1) update and strengthen
the existing air profile as necessary, 2) identify source-receptor
relationships, and 3) analyze the implementation and enforcement
of the existing SIP control strategy. Particular non-attainment
causes are to be documented and quantified. A brief discussion of
possible corrective actions in response to the non-attainment
findings is to be made.
Figure 2 shows the flow diagram for the evalution methodology.
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Data Input
Attainment - Non-
Attainment
Determinat ions,
Profiles, Update
of Air Profile
(where needed)
Update
of
Air
Profile
Identification
of the Scope of
Geographic
Problem
Area(s)
Detailed
Long
Term
Analysis
Understanding
of
Basic
Source-Receptor
Relationship
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Correlation of
Amb ientyEmission
Concentrations
LD
Analysis of
Seasonal Meteorology )
and Emission Activity I"
Evaluation of
Previous Modeling
and Filter Analysis
Identification of
Jnusual Emission Condition
Performance of
Statistical Evaluations
Performance of ; f
Statistical Evaluations j
Analysis of ;
Meteorological Conditions.
Assessment of Source-Receptor Relationships
Long Term Modeling/
Evaluation
of
Future Modeling Needs
Performance ,
I of |-
Short Term Modeling j
Performance of
Microscopic Analysis/
Identification of the
Need for Such Analyses
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Analysis of
Existing
State
Implementation
Plan
Review of Existing
Control Strategy
L
Review of Data Input
Correctness
Design Concentration
Particulate Background
Cone.
Base Emissions
Growth Projections
Comparison of
Regulation Stringency
with RACT
Modifications on
Anticipated Air
Quality Improvement
with Revised
Emission Rollback
Calculations
Review of Existing SIP Control Strategy
H
Review of Control
Strategy
Implementation/
Enforcement
Ift
Review of Point
Source
Compliance Status
Review of Area
Source
Compliance Status
Identification of
Anticipated Air
Quality Improvements
from Emissions
Yet to be Reduced
Review of Control Stategy Implemention/ Enforcement
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Tabulation and
Quantification
of
Non-Attainment
Causes
Recommendations on
Corrective Actions
Required
Conclusions/Recommendations
Figure 2. FLOW DIAGRAM FOR EVALUATION METHODOLOGY
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IV. DETAILED APPROACH
A- UPDATE OF AIR PROFILE
Evaluation of a present ambient air quality problem must first
include an identification and characterization of that problem. This
is the purpose of air profiles, required for all non-attainment areas
and completed for the 20 PAAs. These reports provide an
analysis of ambient air quality trends, point and area source emission
data, meteorology and summarized findings from any modeling and/or
hi vol filter analysis studies already completed. The most recent
air quality, emissions, meteorological and other pertinent data
should be added, when available and when needed to update and
strengthen earlier profiles.
Of special interest in the profile is a discussion of the
representativeness at each monitoring site - i.e., what is being
sampled at each site; what sources are influencing the site? A
detailed description of each site should be made. Specific charac-
teristics may include surrounding terrain, land use and sources.
One purpose of determining the representativeness of monitoring
sites is to prevent the misinterpretation of data from a site that
may be strongly biased by a single local source.
B. ASSESSMENT OF SOURCE-RECEPTOR RELATIONSHIPS
1. Narrowing the Geographical Scope of Non-attainment Problem
Areas - The initial transitional step from the air profiles is the
discussion of geographic areas where NAAQS are not being attained.
This discussion should address whether the non-attainment problem
is localized or relatively widespread. The point and area sources
that are located within these areas should be identified. Identi-
fication of major point and area sources outside the non-attainment
areas that may be affecting monitoring stations within the problem
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areas should also be made. Maps may be utilized to show the moni-
toring sites and the pertinent emission sources.
Understand!ng of Basic Source-Receptor Relationship - The
non-attainment evaluation should be based upon the basic source-
receptor relationship described by the following fundamental model:
Where = Ambient Air Quality Concentration
Q = Emission Rate
ay = Standard Deviation of Plume Concentration Distribution
in the Horizontal Cross-Wind Direction
CTz = Standard Deviation of Plume Concentration Distribution
in the Vertical
U = Wind Speed
H = Effective Emission Height
The equation was taken from "Workbook of Atmosphere Dispersion
Estimates", D. Bruce Turner, U.S. Public Service Publication No. 999-
AP-26, 1969. It should be noted that this equation applies only to
continuous point sources, but that the principles involved are applica-
ble to any source.
The formula identifies the pertinent emission and meteorological
factors and their effects on ambient air quality concentration. The
direct proportionality between emission rate and ambient concentra-
tion, and the inverse proportionality between wind speed and ambient
concentration can be seen in this formula.
If mathematical modeling is utilized in assessing the source-
receptor relationships, the above equation or a modified version
should be used. If a modeling approach is not utilized, the formula
is still of significant value in logically directing an assessment
of source-receptor relationships in non-attainment areas.
exp
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Mon-attainment evaluations should be addressed to long term
(annual and seasonal) and 24 hour time frames since these generally
represent the averaging periods for both particulate matter and
sulfur dioxide NAAQS. For sulfur oxides, an additional discussion
on the 3-hour secondary standard should be included.
3. Long Term Analysis - A map may be prepared with air quality
(annual) isopleths along with the location of significant point and
area sources. Emission source strengths may be indicated in terms
of point source emission rates and/or area densities. Significant
source emission-ambient concentration correlations may be identi-
fied and discussed.
The air quality data should be analyzed for seasonal influence
of meteorology and emission activity patterns. Correlations between
air quality concentration and these seasonal meteorological and
emission patterns should be made where possible. Specific items
of interest are:
• Meteorological Patterns - wind speed, wind direction,
vertical stability, temperature, precipitation, etc.
• Seasonal Emissions - industrial operations (grain
terminals, rock and gravel dredging and crushing,
etc.), agricultural activities (plowing, burning,
etc.), open burning (residential, slash, etc.), and
dirt roads.
Unusual meteorological patterns and their influence on ambient
air quality should also be analyzed. The years being evaluated
should be compared with normal values for various meteorological
parameters based on historical record to ascertain the represen-
tativeness of these years.
Where possible, peak 24-hour values caused by unusual events
should be identified. The effect of these concentrations on
seasonal to annual averages can be measured by eliminating the peak
values and recalculating.
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Findings from previous modeling studies should be reviewed
for information on source-receptor relationships. Information
from previous filter analysis (color, microscopy, chemical
analyses, etc.) studies should also be reviewed. Such informa-
tion may provide insight on the origins and transport mechanisms
of the suspended particulate material found on the filters.
Additional data tabulations and statistical evaluations
may be beneficial. These may include, but are not limited to the
following:
• Correlation of air quality trends among monitoring
sites through a review of daily concentrations over
an extended period. Such an examination may disclose
to what extent non-attainment is due to a common
emission problem.
• Tabulations and comparisons of weekend concentra-
tions and week-day concentrations. The comparisons
may be done for all days, or only days when the
NAAQS were exceeded. They may provide insight into
specific source category-receptor relationships
through correlations between weekend - weekdays
variations in emission activity and corresponding
variations in ambient concentrations.
Finally, an evaluation of the worth of modeling to determine long
term impact of sources on specific air monitors should be con-
sidered. If modeling is to be performed, it should be applied as
needed and capabilities permit.
4. Short Term Analysis - First, for the previous one or more
years those days when monitors recorded concentrations exceeding
NAAQS for the pollutant of concern should be isolated. A tabula-
tion of the number of times the NAAQS were exceeded at each site
may be useful.
Meteorological conditions accounting for the NAAQS being
exceeded should be identified where possible. Consideration with
respect to wind speed and direction may include, but not necessarily
be limited to:
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• Average wind speed correlation with pollutant
concentrati ons.
• Wind direction correlation with peak 24-hour concen-
trations.
• Wind direction versus frequency of concentration
graphed for each monitoring site.
• Upwind pollutant concentrations to indicate relative
location of major emission sources.
• Strong winds accounting for blowing dust.
Stability or inversion analysis may be conducted to identify
the atmospheric structure's influence on air quality. The
frequency and duration of inversions and stagnations may account
for high air quality levels.
Temperature information may be reviewed. Unusually warm
or cold weather may result in a change in fuel consunption which
inay have caused high ambient levels.
Precipitation records may also be reviewed to correlate
rainfall (the lack of) with high 24-hour concentrations. Long
periods of exceptionally dry weather may increase the particulate
matter emissions from fugitive dust sources.
Unusual emission conditions which may have accounted for
NAAQS being exceeded should be evaluated. Occurrence of the
following activities should be checked since such events could
result in short term high ambient concentrations:
• Point source startups, upsets, malfunctions and
control equipment shutdown.
• Area source activities such as fires, demolition,
construction etc.
Control agency records including citizen complaint files, and
building department records may be sources of this information.
Additional data tabulations and statistical evaluations may
be needed for the short term air quality data evaluation. These
22.
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may include, but are not limited to the following.
• Frequency distribution of pollutant concentrations
for each monitoring site for all days with high
ambient concentrations of the pollutant of
concern. By comparing the relative frequency and
magnitude of short term NAAQS exceedences among
sites, one may gain insight into which monitors
are more strongly affected by local sources.
• General relationships among all sites for each
day when one or more monitors indicate exceedences
of NAAQS. The frequency and strength of repeated
patterns may indicate the degree to which each
site is affected by sources having local or area-
wide effects.
The performance of short term modeling should be considered.
The impact of one or more key sources on a given monitor under
worst case conditions, can thus be determined. The peak 24-hour
concentrations and appropriate meteorological conditions should be
utilized. The results of this modeling may also permit an estimate
of the likely or possible impact of other sources on the monitoring
site.
The performance of microscopic analyses of selected high
volume filters to determine likely major contributing sources on
days that the NAAQS were exceeded should be considered. These
analyses may be needed only if previous evaluations failed to ade-
quately identify source-receptor relationships. If such analyses
are identified as being needed, the specific scope of work, inclu-
ding those filters to be examined, should be described.
C. ANALYSIS OF EXISTING STATE IMPLEMENTATION PLANS
It is next necessary to consider an evaluation of the adequacy
of the existing SIP in light of the understanding obtained on the
source-receptor relationships in non-attainment areas. Specifically,
the existing SIP control strategy and its implementation and enforce-
ment should be reviewed to determine the need for strategy
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revisions and/or increased enforcement activity because of
identified non-attainment causes. This aspect of the evaluation
may thus blueprint future SIP activities in control strategy
revision and/or enforcement necessary to resolve the non-attainment
causes.
1. Review of Existing SIP Control Strategy - An inadequately
designed control strategy may have directed control activities
in an improper direction or with less stringency than necessary.
Control strategy development aspects of interest are data inputs
and enforcement mechanisms. Figure 3 depicts the control
strategy development aspects.
Five major data inputs were needed to develop control strate-
gies for SIPs: existing air quality, background particulate con-
centration, existing emissions inventory, growth factors and
meteorological conditions.
The design concentration value (that used to calculate
necessary emission rollback) utilized in the initial plan should
be determined. The sampling site location of the design concen-
tration value should be identified.
Background particulate concentrations are defined as that
portion of the ambient particulate level derived from natural
sources. The background concentration utilized should be reviewed
to determine if the original background concentration is reasonable
or if it should be adjusted.
The base emissions inventory should be checked to see if all
source categories were included and properly quantified. In some
areas, the collection of smaller point sources (less than 100 tons per
year but not included in area sources) represents a significant
amount of pollution which is not recorded in inventories. This
situation should be reviewed by checking point source files and
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iMETEOROLOGICAL/TOPOGRAPHIi
CAL CONDITIONS '
f
Figure 3. DEVELOPMENTAL ASPECTS OF A CONTROL STRATEGY
25
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methods of area source inventory techniques. In addition,
source categories such as fugitive emissions (fugitive industrial
emissions and fugitive dust from dirt roads) and agricultural
burning may not have been included in the initial inventory. If
updated emission information or emission factors (from references
such as the most recent AP-42) are available, these should be
used.
Growth projections applied to base emissions for control
strategy purposes should be obtained. Actual growth data since
strategy development should be obtained for comparison. Infor-
mation on various growth elements - population, industrial, fuel
consumption, transportation activities, etc. may provide checks
on the projected growth trends utilized.
Another major area of concern related to control strategy
development deals with the applicable control regulations for
the selected strategy. The type, specificity and strength of the
regulations should be defined. The scope of coverage of individual
regulations should be assessed and a determination of the effect
of broader coverage on emission reductions may be considered.
The strength of regulations should be determined; the term strength
being defined by how much emission reduction is required versus
what is achievable with reasonably available control technology
(RACT), as defined in the September 14, 1973 Federal Register.
The possible effects of more stringent regulations on emission
reductions, up to RACT, should be determined as needed.
After consideration of the above elements in the existing
SIP, all appropriate data base changes should be made. The
proportional rollback calculations should be redone to determine
the revised projected effect on air quality. Each significant
incremental change in the initial SIP should be related to its
resultant change in projected air quality. This will, in effect,
result in the development of more realistic air quality improvement
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projections through the implementation and enforcement of the
existing SIP control strategy.
Consideration may also be given to performing an elementary
rollback calculation for the specific geographic area(s) where
NAAQS are being exceeded. By selecting data from a monitoring
site "representative" of this area for the design concentration
value, geographically limiting the emission inventory, and assuming
or determining a background pollutant concentration (concentration
of pollutant in the air mass entering the geographical area of
concern), one could apply the rollback modeling technique to each
definable geographical area where NAAQS are being exceeded. Thus,
a more realistic projection may be made on required emission
reductions to meet NAAQS in each area of concern.
2. Review of Control Strategy Implementation/Enforcement - A
primary measurement of control strategy implementation is the com-
pliance status of sources. The total number type and emission size
of point sources should be identified. Those subject to control
regulations should be reviewed for compliance status. Compliance
status categories include: 1) in compliance; 2) out of compliance
on a schedule; and 3) out of compliance not on a schedule. Sources
on compliance schedules should be checked to identify the adequacy
of progress being made on these schedules. A tabulation of those
point source categories which are in compliance, soon to be coming
into compliance, and those not likely to be coming into compliance
should be made. Special precautions should be taken in evaluating
source compliance information obtained solely from the Compliance
Data System (CDS). For example, a source may be considered in
compliance, but may experience periodic or frequent upsets, mal-
functions, or short term violations. Such emissions may signi-
ficantly impact ambient monitors.
27
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For area sources, compliance status by source category
should be determined. Compliance status should be estimated
based on discussions with state and local agency personnel.
Emission reductions achieved by these point and area
source compliance actions as well as those yet to be reduced should
be determined. Those sources yet to achieve compliance may be
presented on a map. Anticipated air quality improvement resulting
from emission reductions when all sources come into compliance
should be determined. These determinations will more clearly
reflect the amount of impending emission reductions and the
geographical distribution of the subject sources.
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V. SUMMARY, CONCLUSIONS AND RECOMMENDATIONS
Findings on the major reasons for non-attainment of the
NAAQS should be discussed. These findings will be drawn from the
assessment of source-receptor relationships. A ranking on rela-
tive importance should be assigned to the identified reasons.
Quantification of these reasons should also be made.
If sufficient source-receptor relationships cannot be
established with the available data and time frame then recommen-
ded further studies should be defined. These may deal principally
with modeling and/or microscopic analyses of hi vol fiters. Each
recommended study should be specific with respect to objectives
and detailed scope of work.
Recommendations of needed corrective actions to achieve
attainment of NAAQS should be listed. These should be expressed
in terms of an inadequate control strategy development or in-
sufficient control strategy implementation/enforcement - i.e.,
control strategy revision and/or increased enforcement activity.
Likely categories of recommendations may deal with the following:
• CONTROL STRATEGY REVISION
• More restrictive emission limitations for specific areas
• Stricter point source emission limitations up to RACT
• Industrial fugitive emission control
• The need for road and parking lot dust control and paving
• The need for limitations on agricultural operations
• The need for street cleaning requirements
• Prohibition of residential open burning
29
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• I IMPLEMENTATION/ENFORCEMENT ACTIVITY
• Awaiting compliance for sources on compliance schedules/
enforcement orders
• Increased enforcement activity to achieve compliance on
sources not on compliance schedules/enforcement orders
• More active compliance assurance program to ensure that
those sources considered in compliance are in fact
operating in compliance with applicable emission limitations.
30
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APPENDIX A
AVAILABLE DATA SOURCES
1. Assessment of Source-Receptor Relationships - The following
data sources and types of information should be available:
a. Air profile
• air quality data
• emissions inventory
• meteorological data
b. SAROAD
• air quality data
• station description
c. Quarterly air quality reports
• air quality data
d. NEDS
• emissions inventory
e. Semi annual progress reports
• emission inventory
f. Other local, state, federal, etc. reports
• air quality data
• pollutant composition
m emissions inventory
• source/receptor relationship
2. Analysis of Existing State Implementation Plans
a. SIP
• background air quality for particulates
• highest air quality concentration
31
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• emission categories
• emission quantities
• source distribution
• meteorological conditions
« growth factors
• strategy testing technique
• strategy testing results
• emission regulations
b. Semi annual progress reports
• source compliance status
• emission reductions
• new sources
• enforcement actions
c. CDS
• sources in compliance
• sources out of compliance on compliance schedules
% sources out of compliance not on a schedule
• progress of sources on schedules
32
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EVALUATION
OF
NATIONAL AMBIENT AIR QUALITY STANDARDS (NAAQS)
NON-ATTAINMENT:
EXAMPLE TOTAL SUSPENDED PARTICULATE ANALYSIS
FOR
SPOKANE COUNTY
33
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TABLE OF CONTENTS
Secti on Patje
I. INTRODUCTION 37
II. DESCRIPTION OF THE SPOKANE COUNTY PRIORITY
ABATEMENT AREA 38
A. GEOGRAPHY 38
B. METEOROLOGY 38
C. DEMOGRAPHY 39
D. INDUSTRY 39
E. AGENCY JURISDICTION 39
III. UPDATE OF AIR PROFILE 41
A. AIR QUALITY DATA 41
B. EMISSIONS DATA 43
C. METEOROLOGY 44
IV. ASSESSMENT OF SOURCE-RECEPTOR RELATIONSHIPS . . 46
A. IDENTIFICATION OF GEOGRAPHIC NON-
ATTAINMENT AREAS 46
B. SEASONAL AND ANNUAL 47
C. DAY-BY-DAY 53
V. ANALYSIS OF EXISTING STATE IMPLEMENTATION PLAN . 59
A. REVIEW OF EXISTING SIP CONTROL STRATEGY . . 59
B. REVIEW OF CONTROL STRATEGY IMPLEMENTATION/
ENFORCEMENT 62
VI. SUMMARY 64
VII. CONCLUSIONS 68
VIII. RECOMMENDATIONS 71
34
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LIST OF FIGURES
Figures
1. SPOKANE COUNTY PRIORITY ABATEMENT AREA LOCATION
2. TOPOGRAPHIC MAP OF SPOKANE AREA
3. MONITORING STATION LOCATIONS
4. ISOPLETH MAP OF 1974 ANNUAL GEOMETRIC MEANS
5. 1974 MONTHLY GEOMETRIC MEANS FOR STATIONS 5, 6, 7, 8 and 10
6. 1975 MONTHLY GEOMETRIC MEANS FOR STATIONS 5, 6, 7, 8 and 10
7. HISTORICAL ANNUAL GEOMETRIC MEAN DATA
8. HISTORICAL MONTHLY GEOMETRIC MEAN DATA
9. FREQUENCY DISTRIBUTION FOR 24-HOUR VALUES IN 1974
10. HISTORICAL SECOND HIGHEST 24-HOUR DATA AT SPOKANE CITY HALL (LOCAL)
AND GONZAGA UNIVERSITY
11. PLOT OF 24-HOUR CONCENTRATIONS AT THE NINE MONITORING STATIONS
FOR 1974/1975
12. NON-ATTAINMENT GEOGRAPHIC PROBLEM AREA
13. MONITORING STATIONS AND POINT SOURCES IN AND NEAR THE CITY
OF SPOKANE
14. MONITORING STATIONS AND EMISSION SOURCES IN AND NEAR THE
CITY OF SPOKANE
15. AMBIENT DATA VERSUS MIXING HEIGHT AT ALUMINUM SUPPLY COMPANY
AND CROWN ZELLERBACH
16. MONTHLY AIR QUALITY DATA VERSUS PRECIPITATION AT ALUMINUM COMPANY
AND CROWN ZELLERBACH
17. DAILY AIR QUALITY DATA VERSUS WIND SPEED/DIRECTION AT ALUMINUM
SUPPLY COMPANY AND CROWN ZELLERBACH
LIST OF TABLES
Tables
1. MONITORING STATION DESCRIPTIONS
2. 1974/1975 ANNUAL GEOMETRIC MEANS
3. 1970/1975 ANNUAL GEOMETRIC MEANS
4. 1974/1975 SECOND HIGHEST 24-HOUR VALUES
5. SOURCE CATEGORY PARTICULATE EMISSION INVENTORY
6. POINT AND AREA SOURCE PARTICULATE EMISSIONS INVENTORY
FOR SIGNIFICANT SOURCES
35
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LIST OF TABLES (continued)
Tables
7. SPOKANE AIRPORT/GONZAGA UNIVERSITY METEOROLOGICAL DATA
8. FREQUENCY OF ADVERSE VERTICAL MIXING CONDITIONS AT SPOKANE AIRPORT
9. SUMMARY OF STABILITY DATA, SPOKANE AIRPORT
10. WEEKDAY VERSUS WEEKEND AIR QUALITY DATA AT ALUMINUM SUPPLY
COMPANY AND CROWN ZELLERBACH
11. AIR QUALITY/METEOROLOGICAL DATA FOR 8 SELECTED DAYS
12. INITIAL SIP REDUCTION REQUIREMENTS
13. REVISED SIP REDUCTION REQUIREMENTS
14. COMPARISON OF 1970 AND 1973 EMISSIONS INVENTORY
15. REVISED EMISSIONS REDUCTIONS
16. COMPARISON OF GROWTH DATA
17. COMPARISON OF REGULATION STRINGENCY
18. POINT SOURCE COMPLIANCE STATUS
19. POINT SOURCES KNOWN TO BE OUT OF COMPLIANCE
36
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I. INTRODUCTION
In January, 1972, the Washington State Department of Ecology
s u bm i 11 e d A Plan for the Implementation, Maintenance and Enforce-
ment of National Ambient Air Quality Standards in the State of
Washington to the Environmental Protection Agency. The plan
included a control strategy and regulatory provisions to attain the
National Ambient Air Quality Standards (NAAQS) for suspended par-
ticulates in the Washington portion of the Eastern Washington -
Northern Idaho Interstate Air Quality Control Region (AQCR) by
July, 1975.
Recent air quality data indicates that the AQCR, more
specifically Spokane County, will not achieve the NAAQS for
suspended particulates by the defined attainment date. An assess-
ment was undertaken to determine the reasons for non-attainment
so that corrective action to achieve the standards can be taken.
This report describes the evaluation first by identifying
and characterizing the present air quality problem in terms of
ambient air quality trends, point and area source emission data,
and meteorology. This updates and strengthens the existing air
profile. The non-attainment problem is discussed with respect
to the source-receptor relationships. Specific factors are
identified as likely reasons for non-attainment. These likely
non-attainment reasons are then discussed with respect to inade-
quacies in the design of the initial control strategy and the
possibility of insufficient implementation of the adopted plan.
Finally, corrective actions necessary to achieve the NAAQS for
suspended particulates are addressed.
37
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II. DESCRIPTION OF THE SPOKANE COUNTY PRIORITY ABATEMENT AREA
A. GEOGRAPHY
The Spokane County Priority Abatement Area is one of the
eight Washington counties in the Eastern Washington-Northern
Idaho Interstate AQCR. The County's total land area is 32,848
acres (133 sq. km). The County's general location is shown in
Figure 1. (All figures and tables can be found in the back of the
report).
Spokane County lies in the topographical area called the
North Central Highlands. The area is on the upper plateau where
the long gradual slope from the Columbia River meets the sharp
rise of the Rocky Mountain Ranges. Physically, the area is charac-
terized by steep cliffs, old cascades, swampy meadows, mesas and
potholes—all remnants of former water courses.
The topography in the vicinity of the City of Spokane ranges
from 1900 feet (570 m) along the Spokane River to about 3000 feet
(900 m) in the nearby hills. Much of the urban area of Spokane
lies within the Spokane River Valley at an elevation of about
2000 feet, (600 in) but the residential areas have spread to the
crests of the plateaus on either side of the river with elevations
up to 2,500 feet (750 m). Figure 2 is a topographic map of the
Spokane area.
B. METEOROLOGY
The climate of Spokane is dominated by the mid-latitude belt
of westerly winds. Pacific frontal systems pass the area fairly
frequently during the winter months bringing precipitation usually
in the form of snow. However, there are also numerous periods
during the winter when a ridge of high pressure (both at the sur-
face and aloft) will build over the area with associated stagnant
38
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air flow and subsidence inversions.
During the summer months the skies are typically clear or
partly cloudy. With these conditions, there is a high probability
that a surface-based temperature inversion will form at night, but
an equally high probability that these inversions will be broken
by solar heating during the daylight hours. It can be expected
that a fumigation/inversion breakup condition would be a fairly
regular occurrence in the summer months.
Annual precipitation totals in the area are generally less than
20 inches (51 cm). Approximately 70% of the total annual precipi-
tation falls between the first of October and the end of March and
about half of that falls as snow. The growing season usually
extends over nearly 6 months from mid-April to mid-October.
C. DEMOGRAPHY
The County's 1975 population is 307,440 of which over 55
percent is concentrated in the City of Spokane.
D. INDUSTRY
While the largest single industrial employer in the Spokane
area is primary aluminum reduction, the industrial activities within
Spokane County include a wide variety of air pollution emission
sources such as secondary smelting and refining of non-ferrous
metal, sawing and planing mills, grain handling and milling, veneer
and plywood production.
E. AGENCY JURISDICTION
The Spokane County Air Pollution Control Authority (SCAPCA)
serves the County as the principal agency for engineering, enforce-
ment and surveillance of air pollution control activities. The
39
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Washington Department of Ecology (DOE) provides technical advice
and consultation to the Local Agency. The State Agency, directed
by the Washington Clean Air Act, has set ambient air standards and
assumed jurisdiction for certain source categories on a statewide
basis.
40
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III. UPDATE OF AIR PROFILE
A. AIR QUALITY DATA
In 1974 and the first half of 1975, nine suspended particu-
late monitoring stations were operating in Spokane County. The
location of the seven stations in the immediate Spokane area are
shown in Figure 3. The two other stations, Turnbull Wildlife Refuge
and Cheney City Hall, are located approximately 10 to 15 miles
(16 to 24 km) southwest of downtown Spokane. Specific station
descriptions relating sampler location, areal representativeness,
and operating agency are included in Table 1 J
Air quality data from the nine monitoring stations are pre-
sented in Table 2 with annual geometric mean values for comparison
2
with the primary and secondary NAAQS for suspended particulates.
Information for 1974 and the first half of 1975 is included.
Although annual standards are based upon a calendar year (CY), data
for Fiscal Year (FY) 1975 are presented to depict 12 month means
from the most current data available. An isopleth map of the data
3
is presented in Figure 4.
In 1974, three of the sampling stations exceeded the primary
standard on the basis of an annual geometric mean. The one site
significantly exceeding the standard, Crown Zellerbach, is indus-
trially oriented. The other two stations, Spokane City Hall (Local)
and Gonzaga University, only slightly exceeded the standard. The
same three sampling stations were the only sites exceeding the
secondary standard guide on the basis of an annual geometric mean.
A fourth monitor, located at the Aluminum Supply Company was in
operation for only the last 7 months of CY 1974. During this
period, the geometric mean was almost twice the primary annual
standard.
Monthly geometric means for the five highest recording
stations, Spokane City Hall (Local), Crown Zellerbach, Gonzaga
41
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University, Spokane City Hall (Federal) and Aluminum Supply Company,
are graphed in Figures 5 and 6.
Historical annual geometric mean data for the nine stations
4
are tabulated in Table 3. Periods of record range from 1970 to
1975.
This information is shown in graphic form in Figure 7.
Considering the period 1972 through 1974, an improvement trend in
air quality levels is apparent at all sampling sites except the
Turnbull Wildlife Refuge background site which already meets the
secondary standard. For the Spokane City Hall (Local) site, which
is the station with the longest period of record, an overall
improvement is observable from 1970 to 1974.
Historical monthly geometric mean data for the nine
stations are shown in graphic form in Figure 8. Periods of record
range from 1970 to 1975. It can be observed that the high concen-
trations generally occur in April and July through October. The
lower concentrations are typically in November through March.
Table 4 shows the 1974 second highest 24 hour TSP concentra-
tion for each site as well as the number of times each site was
found to exceed the value of the 24 standard for that year. Three of
the stations exceeded the primary standard on the basis of the
second highest 24-hour value. The three are Crown Zellerbach,
Gonzaga University and Aluminum Supply Company. All but two of the
nine sampling stations exceeded the secondary standard on the basis
of the second highest 24-hour value. The two meeting the secondary
standard were the Turnbull Wildlife Refuge and Millwood City Hall.
Table 4 also shows the total number of samples taken at each
site in 1974. The percentage of occurrences in 1974 over the 24
hour value standard at Cheney City Hall and Rogers High School
stations are 5 to 8% respectively. The five other stations,
Spokane City Hall (Local), Crown Zellerbach, Gonzaga University
42
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Spokane City Hall (Federal) arid Aluminum Supply Company have a
much higher proportion of occurrences over the secondary 24
hour value ranging from 10 to 45%.
Frequency distribution tabulations for 24-hours values
observed during 1974 at the nine stations are presented in Figure 9.
Historical second highest 24-hour data for Spokane City Hall
(Local) and Gonzaga University are shown in Figure 10. Such
data for the other stations were unavailable for this study.
All 24-hour concentrations recorded in 1974 and the first
half of 1975 at the nine monitoring stations are plotted in Figure
11.
B- EMISSIONS DATA
The source category emissions inventory for the Spokane
County area is presented in Table 5 and 5. ^'^'®The most currently
available emissions data are presented and used for discussions.
It is important to note that due to inherent inaccuracies of
emission inventories, all emissions data presented and discussed
are considered best available and approximates only.
The largest single source category, dirt roads, contributes
approximately 7,500 tons per year of particulate matter and accounts
for over 50X of the County particulate emissions. Aluminum plants
and transportation, the next most significant source categories,
each contribute about 1,600 tons per year and account for a total
22% of the County particulate emissions. The aluminum plant cate-
gory total is comprised of the two Kaiser facilities at Mead and
Trentwood, and Hillyard Processing.
The emissions inventory has also been tabulated by an
3
individual point and area source delineation in Table 6. Area
sources account for 84% of the total emissions while point sources
-------
account for 16%. Those point sources listed in Table 6 and located
in or near the City of Spokane are shown in Figure 13,
C. METEOROLOGY
Meteorological data from two locations in Spokane County are
available for 1974 and the first half of 1975.^'^'^ The primary
meteorological station is located at the Spokane International
Airport, situated on the plateau 6 miles (9.6 km) west/southwest
and some 400 feet (120 m) higher than the downtown business district.
The Gonzaga University Air Sampling and Meteorological Station is
discussed in Table 1.
Table 7 presents wind speed and direction on a monthly basis
at the Spokane International Airport and Gonzaga University. It
also includes mean monthly wind speeds and prevailing wind direction
based on historical data at Spokane International Airport.
Note that various expressions of wind direction, and speed
are included in Table 7. These include both average and resultant
wind speeds and resultant and prevailing wind directions. The most
useful expressions for air pollution considerations may be prevailing
wind direction and average wind speed; resultant wind speed and
resultant wind direction statistics were provided for general infor-
mation, and should be used with caution as they may be misleading.
Table 7 reveals that monthly average wind speeds for 1974
at the Airport were consistently higher than respective historical
monthly means for each of the first 9 months and for December. Only
for October and November in 1974 were monthly average wind speeds
less than respective historical monthly means. Average wind speeds
are also shown to be consistently lower during 1974 at the Gonzaga
site than at the Airport, often by as much as 50% or more.
The frequency of occurrence of adverse mixing conditions
measured at Spokane International Airport is presented in Table 8.^
44
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The information covers 1974 and has been summarized by months,
For the purposes of this study "adverse mixing" is defined to
occur when the mixing height is 2,500 feet (750 m) or less.
A summarized version of the full stability wind rose (STAR
data-joint frequency distribution between stability, wind direction,
and wind speed) on a seasonal and annual basis for the year 1974 for
the Spokane Airport is presented in Table 9.^ The data shows that
stable conditions (Classes E and F) predominate throughout the year,
while unstable conditions (Classes A and B) are relatively infre-
quent. Table 9 shows that during the September, October and Novem-
ber period Class F conditions occur almost 40% of the time. It
can also be seen from the table that the lowest wind speeds occur
in the fall period when the prevailing wind speed is in the 4-6
knots range, compared to an annually prevailing wind speed range
of 7-10 knots.
The STAR data also shows that winds from the southwesterly
quadrant predominate in all four seasons with a secondary small
maximum from the northeast. During the fall period the bi-modal
distribution is more pronounced, and considering a 16-point wind,
rose winds from the northeasterly direction actually are most pre-
valent. During the fall and on an annual comparison, winds from
the northeast tend to be higher than winds from the southwest.
One would expect stability conditions in the downtown area
to be somewhat different from those encountered at the airport,
since Spokane sits in a broad valley bounded by hills up to about
500 feet higher than the valley floor. Two factors could affect
the stability conditions - night time drainage winds and the heat
island effect. These two factors, however, would have an opposing
affect on the atmospheric stability in downtown Spokane so that one
may expect that the stability conditions measured at the Airport
would be reasonably representative of the downtown area.
45
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IV. ASSESSMENT OF SOURCE-RECEPTOR RELATIONSHIPS
A. IDENTIFICATION OF GEOGRAPHIC NON-ATTAINMENT AREAS
The air quality monitoring data previously discussed indicates
that the geographical area exceeding the NAAQS extends from down-
town in an east/northeasterly direction through the industrial
corridor. This area is shown in Figure 12. Five sampling stations,
Spokane City Hall (Local), Spokane City Hall (Federal), Crown
Zellerbach, Gonzaga University, and Aluminum Supply Company are
located in this area. In 1974, all of the five stations except
Spokane City Hall (Federal) exceeded the value of the primary
24 hour standard.
These four stations generally exhibit the same annual trend,
pointing to the conclusion that the same overall source receptor
relationship likely affects all the four stations, but in varying
degrees. The relative ranking of air quality measured at the four
stations is as follows, starting with the worst - Aluminum Supply
Company, Crown Zellerbach, Gonzaga University and Spokane City
Hall (Local).
As indicated in Table 1, both Aluminum Supply Company and
Crown Zellerbach are industrially oriented monitoring sites.
Aluminum Supply Company has a number of point sources within one-
half mile (0.8 km) of the sampling station. Crown Zellerbach also
has several point sources within a mile (1.6 km) of the monitoring
site. Both locations have surrounding dirt roads as a significant
area source.
Gonzaga University is a commercially and industrially oriented
monitoring site. A few point sources are located within a mile
(1.6 km) of the station. Spokane City Hall (Local) is a commercially
oriented station located in the downtown area.
Figure 13 shows the monitoring sites and pertinent emission
12
sources.
46
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13. SEASONAL AND ANNUAL
The source-receptor relationship discussion that follows
addresses both long-term (annual and seasonal) and short-term
(daily) NAAQS. As mentioned before, four monitoring stations in
the non-attainment area measured concentrations in excess of both
the standards for annual geometric mean and second highest 24-hour
value. Aluminum Supply Company and Crown Zellerbach monitors were
the highest recording sites in both long-term and short-term
respects.
Both the Aluminum Supply Company and Crown Zellerbach monitors
appear to be surrounded by point sources, unpaved roads, and addi-
tional fugitive emission sources. This is shown in Figures 13 and 14.
It appears that these two monitors may be significantly affected by
emissions from all three categories of sources.
The air quality data was then analyzed for seasonal influence
of meteorology and emission activity patterns. It was observed that
in 1974, the highest concentrations occurred in the months of
September and October. The "Historical Monthly Geometric Mean Data"
shown in Figure 8 and discussed earlier indicates that the occurrence
of peak TSP concentrations in September and October is also an annual
pattern. A review of the wind speed data indicates that at Gonzaga
University wind speeds were lower than the year's average during
August through December of 1974 with the lowest occurring in October.
At the Spokane International Airport wind speeds were lower than the
year's average during June through December with the lowest occurring
in October. Normal values for the Airport indicate below average
winds occur in July through November. It appears that in general
wind speeds in Spokane are lower in the latter part of the calendar
year, thus possibly contributing to high TSP concentrations in the
late summer and fall.
It is important to note that the occurrence of high TSP con-
centrations during the months of July through October (discussed
in the Update of Air Profile) coincides with dry warmer weather.
47
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This would direct one to suspect fugitive dust or other seasonal
emissions as likely major contributors to the TSP non-attainment
problem. A further evaluation of seasonal meteorological patterns
is also warranted.
Table 8 shows the frequency of occurrence of adverse vertical
mixing conditions (mixing depth less than 2,500 feet (750 m) feet).
Adverse vertical mixing conditions occurred every morning of the
year and the mixing depth remained below 2,500 feet (750 m) through-
out most days in January, February, November and December. The
afternoon mixing depth exceeded 2,500 feet (750 m) every day in
August.
A plot of ambient particulate concentration against mixing
depth showed no observable trends (Figure 15) which indicates that
the mixing depth has little or no statistical correlation with
the ambient particulate concentration in the Spokane area.
However, highest 24-hour average concentrations occurred in
September and October which does correspond to the increased fre-
quency of occurrence of low wind speeds and increased stability of
the atmosphere. This is seen from the complete plots of ambient
data (Figure 11) and stability wind rose information (Table 9).
Monthly air quality geometric mean data at Crown Zellerbach
and Aluminum Supply Company was plotted versus monthly rainfall at
the Spokane Airport in Figure 16. It can be observed that, in
general, those months having less than an inch of precipitation had
higher air quality values. The likely conclusion is that dirt
roads, fugitive emissions and/or industrial operations requiring
dry conditions are relatable factors for higher air quality values.
Seasonal emission activities in Spokane include industrial
operations, agricultural activities, open burning and dirt roads.
48
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Gravel pit operations with associated crushing, screening
and stockpiling are thought to be a major industrial source of
13
seasonal particulate emissions. Within a radius of less than one
mile (1.6 km) from the Aluminum Supply Company, monitor, gravel
pits, crushing, screening and stockpiling operations are conducted
by Acme Concrete, Ace Concrete, Inland Asphalt, and Central Premix.
Combined emissions from these sources is 111 tons per year, plus
an additional 25 tons per year from ari asphalt rotary dryer. It
is estimated that most of these emissions occur during the summer
and early fall due to seasonal demand for the products and to the
increased fugitive emissions during the drier part of the year.
Blowing dust from gravel stockpiles during periods of strong winds
13
has been observed to significantly decrease ambient air quality.
It is apparent then that these four sources are likely to strongly
influence the TSP concentrations found at the Aluminum Supply
Company monitoring site, particularly during the late summer and
early fall as is shown in Figures 8 and 11.
Grain handling/processing activities are somewhat seasonal
13
in their effect but are generally well controlled.
Agricultural activities such as plowing/cultivation and field
burning may have some impact. The nearest field burning areas are
approximately lb miles (24 km) east and 30 miles (48 km) southeast
13
of downtown Spokane. Burning occurs primarily in August and
September and as indicated in the September 1975, SCAPCA monthly
report, burning on bad ventilation days can cause smoke and reduced
14
visibility in the Spokane downtown area. SCAPCA reported that
total acres (sq. km) burned within the county totalled approximately
22,800 (92.2) in 1974 and 16,700 (67.6) in 1975.
SCAPCA conducted a special air monitoring study in Fairfield,
located approximately 23 miles (37 km) southeast of Spokane, during
14
the 1974 harvest season. The objective of the study was to quanti-
14
fy the local impact of agricultural operations. Grain elevators
49
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and processing facilities are located both upwind and downwind from
the monitoring station. In addition, area sources would likely have
contributed significantly to the suspended particulate problem. These
area sources include the burning of turf grass and cereal grain
stubble fields, agricultural field plowing, and wind blown dust
from fields in fallow. Sampling data was accumulated for 10 days
during the period from August 14, 1974 to September 18, 1974. The
3
highest concentration recorded was 181 Mg/m . Only one other vio-
3
lation of the 150 fjg/m secondary standard occurred. Thus, it would
appear unlikely that these agricultural activities would have a
significant impact on the violations of primary NAAQS in Spokane.
Residential open burning should not be a significant emission
source in the non-attainment area since the City of Spokane is
designated as a "no-burn" area.
Emissions from dirt roads would be expected to occur primarily
during the dry summer and early fall months. The location of these
12
dirt roads are generally indicated in Figure 14. Approximately
240 miles (384 km) of dirt roads were located in the City of Spokane
g
as of 1973. This accounts for approximately 1,000 tons per year
of particulate emissions which, again, are produced primarily in
the summer and early fall months.6 As can be seen from Figure 14,
Crown Zellerbach monitor is located in the center of one of the
largest concentrations of unpaved roads in the area. Based upon an
analysis of a Spokane City Engineering Department map (updated
through January 1974) there are approximately 7.8 miles (12.5 km) of
unpaved roads within a one-half-mile (0.8 km) radius of the Crown
Zellerbach monitor. A similar county map shows approximately 2.4
miles (3.8 km) of unpaved roads within a one-half-mile (0.8 km)
radius of the Aluminum Supply Company monitor. Based upon these
figures as well as the following information provided by Jim Frank
with the Spokane County Air Pollution Control Authority, (SCAPCA),
50
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annual TSP emissions from the unpaved roads within a one-half
mile (0.8 km) radius of the Crown Zellerbach and Aluminum Supply
Company monitors are approximately 44 tons per year and 12 tons per
year, respectively:
(1) Number of vehicle trips per day, estimated jointly
by SCAPCA, and the City and County planning agencies.
(a) Crown Zellerbach monitor area - 40
(b) Aluminum Supply monitor area - 35
(2) Estimated mean vehicle speed - 20 mph (32 km per hour)
(3) 2 lbs. of TSP (<10 microns) emitted per vehicle mile
at 20 mph - based on work done by John Roberts with
the Puget Sound Air Pollution Control Agency
(4) 140 potentially dusty days per year in Spokane based
upon an evaluation of temperatures and rainfall records
for 1973 and 1974.
With the emissions from these unpaved roads being concentrated
during the dry summer and early fall months, it is evident that these
emissions could substantially impact air quality, particularly in
the area of the Crown Zellerbach monitor. Again, these emissions
are likely to be greatest during that same time of year when
highest TSP concentrations are encountered.
A special study was conducted by Droege and Clark of the
15
Washington State Department of Ecology in 1972 and 1973. The
purpose was to determine the variation of particulate concentrations
in various areas of Spokane County and the relationship with meteo-
rological conditions, chemical and phsyical analyses of the collected
material, and the season of the year. Sampling sites were selected
at 7 different locations in and around the City of Spokane. A
standard gravimetric determination of the suspended particulate
loading was made for each sample. Additional analyses were run
on each filter to determine the metal and organic content in the
sample. An estimate was made of the color of the filter. Finally,
51
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a microscopic evaluation was made of each filter to determine in a
qualitative way the basic physical characteristics of the particu-
late material.
A reasonably consistent pattern was found in the relative
dirtiness of Spokane. The Gonzaga University, Spokane City Hall
(Local) and Crown Zellerbach sites were generally dirtier than
Rogers High School and the Spokane Airport. The meteorological
conditions which may have produced high concentrations of particulate
material were not easily defined.
However, an interesting correlation between TSP concentra-
tion and seasonality - meteorology was noted. During the first
two sampling periods of May 1972 and mid-August through mid-Septem-
ber 1972, TSP concentrations for the 16 samples collected averaged
3
114 Mg/m . During the four sampling days on which rain fell, the
3
mean concentration was 54 Mg/m . For the 12 dry days, the mean
3
TSP concentration was 134 Mg/m or approximately 2 1/2 times as
great. Little difference was noted in average wind speed between
dry days and those with rain. The mean wind speeds were 6.5 (10.4)
and 5.8 (9.3) rnph (km per hour) respectively.
During the last two sampling periods of November 1972 and
3
January 1973, the 18 samples collected averaged 60 Mg/m (compared
3
to 114 Mg/m during the May/August-September sampling periods). The
mean TSP concentrations for the five days on which rain fell was
3
43 Mg/m ; for the 13 dry days, the TSP concentration averaged
3
67 Mg/m . Mean wind speeds for these two categories of sampling
days were 4.8 rnph (7.7 km per hour) and 4.4 mph (7.0 km per hour)
respectively.
The strong pattern of higher (by a factor of almost 2) TSP
concentrations during the May/August-September periods compared to
the November/January periods and the sharp drop in TSP concentra-
tions during days with rainfall, regardless of the time of year,
52
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suggest fugitive dust/fugitive emissions as the primary source
of high TSP concentrations.
Droege and Clark determined that highest TSP concentrations
were associated with both high winds and low relative humidity,
further substantiating the fugitive dust/fugitive emissions theory.
The authors also were able to make two very noteworthy
observations concerning the composition of collected TSP. It was
found that the highest concentrations of aluminum, lead, and organic
fraction occurred in November, the month with the lowest TSP con-
centration. Also, a major shift in filter color distribution was
found to occur between the first two and last two sampling periods.
During the November/January sampling periods, only half as
many filters were observed to be in the brown-green range as
during the May/August-September periods (31% vs 72%).
One could strongly conclude from the color and chemical
composition analyses that, again, fugitive dust (usually brown in
color)/fugitive emissions is the predominant source of TSP during
the drier summer months, and that it contributes less to TSP load-
ings during the late fall and winter months when precipitation has
increased. Correspondingly, with the decreased role of fugitive
dust during the winter, the percent impact of non-ferrous metals
from industrial emissions or automotive exhaust becomes greater.
The increase in combustion products (organic fraction) would also
be expected during the colder months due to increased heating.
C. DAY-BY-DAY
As mentioned previously, four monitoring stations exceeded
the secondary standard for the second highest 24-hour concentration.
These were Aluminum Supply Company, Crown Zellerbach, Gonzaga
University and Spokane City Hall (Local). A tabulation of the number
of times the NAAQS was exceeded at each site is made in Table 4.
53
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An analysis of 27 days on which the 24-hour ambient
standard (150 ^g/m ) was exceeded, showed that for 25 of these
occasions the day in question was preceded by dry spells ranging
in duration from 3 days to over one month. On one of the two
remaining days a trace of rain was recorded at the Airport and this
day was preceded by a 15-day dry spell, but it is not known if
any rain fell in the central Spokane area. On the remaining day
a thunderstorm was reported at the Airport and it should be
pointed out that in eastern Washington thunderstorms are often pre-
ceded by blowing dust caused by the associated strong, gusty winds.
However, it is not known whether a thunderstorm occurred in the
central Spokane area. This analysis shows that occurrences of
high particulate concentrations are associated with spells of
dry weather.
Wind conditions accounting for the NAAQS being exceeded
were analyzed. At Aluminum Supply Company and Crown Zellerbach,
a correlation was attempted between average wind speed and pollu-
tant concentration for August-October, 1974. This is shown in
Figure 17. It indicates that high TSP concentrations occur with
both low and high wind speeds.
At both Aluminum Supply Company and Crown Zellerbach, a
correlation was attempted between mean wind direction and pollu-
tant concentration for August-October, 1974. This is also shown
in Figure 17. No significant correlation was found indicating
measured TSP concentrations at each monitor were not being strongly
affected by a single point source.
Unusual emission conditions accounting for the exceeding
of the NAAQS were evaluated. Control equipment breakdown and
13A
citizen complaint logs were reviewed. Occurrence of unusual fires,
demolition, and construction activities were noted by the SCAPCA
13
Control Officer. Based upon an evaluation of the limited data
54
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available, positive correlations between these activities and
high TSP concentrations were dismissed. Residential open burn
areas do not include Spokane City, and thus emission from such
sources are not likely to be a local influence.
Additional data tabulations and statistical evaluations
were made for the short-term air quality data. Geometric means
for weekday and weekend samples at Aluminum Supply Company and Crown
Zellerbach are shown in Table 10. The means were calculated from 20
weekday and 9 weekend Aluminum Supply Company samples, and from 44
weekday and 14 weekend Crown Zellerbach samples. The weekday and
weekend values were generally comparable. The weekday mean was
approximately 10 percent lower than the weekend mean at the Crown
Zellerbach site, but about 10 percent higher at the Aluminum Supply
Company site. These findings suggest that the TSP problem is not
significantly affected by weekend-weekday variations in industrial
activity.
General relationships for the highest individual TSP concen-
tration days were reviewed to identify and evaluate the reasons for
these occurrences. Table 11 presents the pertinent data for eight
days in 1974 - April 17, August 27, September 8, September 20,
September 26, October 14 and October 20. Air quality data for the
five higher measuring stations were reviewed.
The ranking of highest TSP concentrations at the stations
corresponds with the ranking of annual geometric means - Aluminum
Supply Company being the highest, and Spokane City Hall (Local)
and Spokane City Hall (Federal) being in the lower group.
The high TSP values occurred with both higher than average
wind speeds (3 days) and lower than average speeds (5 days). Note,
however, that on the day with highest TSP concentration, winds were
strong and blowing dust with limited visibility was noted at the
Spokane Airport. Wind direction did not seem to be directly
55
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correlated to high concentrations of TSP. Limited mixing
height did not seem to be a requirement for the high concentration
days since only one day had both limited mixing height in the
morning and afternoon.
A modeling study was conducted for two days in which
elevated ambient concentrations were recorded. These days were
November 19, 1974, for the Aluminum Supply Company station and
September 26, 1974, for the Crown Zellerbach station. The data
available consisted of morning and afternoon soundings taken at the
Airport, wind speed and direction at the Gonzaga University station,
and emissions data from a NEDS listing. Procedures given in
Turner's Workbook were followed to determine one-hour averaged
16
concentrations. Twenty-four hour averaged values were then
obtained by dividing the one-hour average by four according to the
procedures qiven in the Federal Register (Vol. 36, No. 158, August
14, 1971.)17
Emissions from Spokane Seed Company, a significant point
source located near the Aluminum Supply Company monitor, were modeled
to determine likely maximum impact on TSP concentrations at this
monitoring site. Spokane Seed is located approximately 0.3 miles
(0.5 km) southeast of the monitoring station. Based on the 1973
inventory, emissions were 106 tons per year from the dump pit, and
6 tons per year from the secondary screening operations. These
emission figures were used as opposed to the presently indicated
emissions of 34 tons per year for the source because: (1) according
to SCAPCA, a baghouse, the major air pollution control device for
the facility, was installed in 1971, (2) the day selected for
modeling was in 1974, and (3) according to SCAPCA, no additional
control equipment was installed until 1975. Meteorological condi-
tions on November 19, 1974, the day selected for modeling, were a
wind speed of 7.3 mph {11.7 km per hour) from the direction of
the source to the monitor and an atmospheric stability class of E.
56
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3
A TSP concentration of 152 Mg/m at the Aluminum Supply Company
monitor was recorded for this day. This specific day was selected
because of the meteorological conditions and relatively high TSP
concentrati on.
Using the value of 112 tons per year and the appropriate
meteorological conditions, it is estimated that Spokane Seed could
3
have contributed a maximum of about 880 M9/m over a one-hour time
3
period at the sampler (220 Kg/m over a 24-hour period). This
indicates that Spokane Seed may have had a significant impact on
the 24-hour averaged values recorded at the Aluminum Supply monitor
3
(152 ng/m on November 19, 1974). It is important to note, however,
that with emissions reduced from 112 tons per year to 34 tons per
year, the potential impact of emissions from this source on air
quality has been reduced correspondingly.
A similar modeling study was performed on the impact of
emissions from Long Lake Lumber on the Crown Zellerbach monitor.
The source is located approximately 0.9 mile (1.5 km) east north-
east of the monitor. Particulate emissions of 395 tons per year,
as provided in the 1973 emissions inventory, were used for the
modeling calculations. The day for which modeling was performed
is September 25, 1974. This date, according to SCAPCA, preceeds
by one month or less the installation of a baghouse on the facility's
hog fuel boiler. This modification resulted in a decrease of total
plant emissions from 396 to 106 tons per year. Meteorological con-
ditions on September 26, 1974, were a wind speed of 16 mph (26 km
per hour) from the direction of the source to the monitor and an
3
atmospheric stability class of D. A TSP concentration of 323 ^g/m
was recorded for this day at the Crown Zellerbach monitor. Although
September 26 was selected for modeling due to wind direction and
high TSP concentrations, it is important to note that strong winds
were prevalent, and as indicated in Table 11, blowind dust noted at
the Airport.
57
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The modeling analysis indicated that Long Lake Lumber could
3
contribute a one-hour averaged concentration of up to 112 Mg/m ¦
3
(28 Mg/m over a 24-hour period), which would thus be a reasonaoly
3
significant contribution to the 24-hour avearged value of 323 pg/m .
However, as stated above, data for 1975 indicate that Long Lake
Lumber's emissions have been reduced to 106 tons per year. Since
the ambient concentration is directly proportional to the emissions
strength, this facility's impact on concentrations measured at the
Crown Zellerbach station is now likely to be minor.
58
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V. ANALYSIS OF EXISTING STATE IMPLEMENTATION PLAN
An evaluation of the adequacy of the existing SIP in light
of the understanding obtained on the source-receptor relationships
was performed. Specifically, the existing SIP control strategy, its
development, and its implementation/enforcement were reviewed for
deficiencies or inadequacies. It was felt that the findings from
such a review may aid in identifying the need for strategy revisions
and or increased enforcement activity.
A. REVIEW OF EXISTING SIP CONTROL STRATEGY
1• Maximum Concentration Value
Air quality data from the Spokane City Hall (Local) site were
utilized in the development of the original state implementation plan
18
and its control strategy. The pertinent 1970 data for this station
are presented in Table 12. This was the only operating station in
1970 at the time of plan development.
As discussed in the previous section, a number of sampling
stations have begun operation since 1970. Information from Table 3
shows that the Spokane City Hall (Local) was not the maximum concen-
tration site in the AQCR. The Aluminum Supply Company, Crown Zeller-
bach and Gonzaga University sampling stations have recorded higher
concentrations between 1971 and 1974. Since the Aluminum Supply
Company station operated only part of 1974, the Crown Zellerbach
station 1972 information was used to obtain the revised rollback
calculations shown in Table 13. The revised rollback calculations
more correctly reflect the required emission reductions necessary
to meet the suspended particulate standards. For attainment of the
primary standard a 28 percent reduction is required in addition to
that identified in the SIP, for attainment of the secondary guide
an additional 18 percent reduction is needed. These figures are
59
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based only upon revising the TSP concentration upon which rollback
calculations are based.
2• Particulate Background Value
3
The particulate background value of 30 Mg/m was used in the
initial control strategy development. Sampling at a background station,
Turnbull Wildlife Refuge, since 1971 has indicated annual geometric
3
means no higher than 22 M9/m . This indicates a slight overestimation
of the background concentration and subsequently a small overestimation
of the magnitude of TSP reduction required through implementation of
the control strategy.
3. Base Emissions Data
A comparison of the base emissions inventory used in the initial
control strategy development and the 1973 inventory is presented in
Table 14. A significant source category, dirt roads, was not
included in the initial inventory. In 1973, this category accounted
for 7,500 tons per year, which was 47 percent of that year's total.
Additional emissions differences of much smaller significance are
also shown in Table 14. The sum of these changes reflect 7,490 tons
per year in addition to the base inventory, increasing the total by
87 percent.
Revised rollback calculations based on only the 1973 inventory
changes described above, while holding other control strategy deve-
lopment elements constant, result in the computations presented in
Table 15. Thus for achievement of the primary standard, this
exercise would indicate that an additional 1,723 tons/year of
particulate matter emissions must be eliminated. Removal of an
additional 3,671 tons/year of emissions would similarly be required
for achievement of the secondary guide.
60
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4. Growth Projections
Growth projections utilized in control strategy development
1° 20
are presented in Table 16 along with actual growth information.
From the limited data available, actual population and industrial
growth in the City of Spokane appeared to be in line with the pro-
jected growth. The remainder of the County, however, experienced
a more substantial population growth.
5. Regulation Stringency
SCAPCA and DOE regulations comprising the adopted control
strategy are compared with those considered as reasonably available
control technology in Table 17.^^ »^2,23 effeC£ 0f SCAPCA
regulations appears to be more stringent for particulate emissions
from incineration and fuel combustion than reasonably available
control technology. Maximum industrial process and visible emission
limitations are comparable. With respect to fugitive dust controls,
the SCAPCA guidelines are comparable except for the notable lack of
limitations on public unpaved roads. These guidelines, since not
part of the SIP, may also be weak from an enforceability standpoint.
A review of regulations governing fugitive industrial emissions for
compatabi1ity with RACT was not made due to time limitations.
6. Summary
It is apparent that the combined effect is of having inade-
quate ambient TSP and incomplete particulate emission data at the
time of SIP development resulted in a serious underestimation of the
control strategy requirements. Maximum TSP concentration in the
AQCR was probably at least 30 percent higher than that used for
rollback calculations. Emissions, due largely to the exclusion of
unpaved roads in the original inventory, were close to 40 percent
greater than that indicated in the SIP rollback. Further, an apparent
61
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absence of any control program for emissions from public unpaved
roads may have resulted in a signficant control strategy short-
coming.
e. REVIEW OF CONTROL STRATEGY IMPLEMENTATION/ENFORCEMENT
1. Point Source Compliance Status
The total number of particulate emitting point sources located
in and near the City of Spokane (as shown in Fiqures 73 and 14}
24
and their compliance status are shown in Table 18. As of November
28, 1975, twenty-two of the twenty-seven identified point sources
were classified by the Compliance Data System (CDS) as in compliance
with applicable regulations.
Four of the five sources not in compliance are scheduled to be
in compliance by July 1976. The remaining source, Washington Water
Power (gas/oil boiler) is thought to be out of compliance for only
about 30 minutes per day during soot blowing and only when oil is
being burned. The status of this source is presently being negotiated.
Spokane Seed is the only source of the other four that is presently
not meeting its schedule. The remaining three sources are Boyd
Conlee, Inland Empire Pea Growers, and Inland Foundry.
The present emission size and geographical distribution of the
five sources yet to come into compliance would indicate that little
improvement in TSP concentrations would likely follow attainment of
compl l'ance.
As shown in Table 19, four of the five sources are presently
less than 25 tons per year each and Washington Public Power, the largest
of the sources, is rated at only 59 tons per year. Inland Empire Pea
Growers and Spokane Seed are both located within 0.3 mile (0.5 km) of
the Aluminum Supply Company monitor but have combined particulate emissions
of only 43 tons per year. Boyd Conlee is about 0.3 mile east of the Gonzaga
monitor, but is only a 30 ton per year source. The location of Inland
Foundry and Washington Water Power, the remaining two sources, can
be seen in Figure 13.
62
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2. A rea Source Compiiance Status
The preliminary Air Profile indicates the paving of dirt
roads was expected to reduce 6% (9G4 tons per year) of the total
1973 emissions by 1975. The control of particulate emissions from
dirt roads is not included as a part of the present control
strategy. However, the paving and use of oil pallative on dirt
roads are being encouraged as voluntary dust suppression measures.
It should be remembered that emissions from dirt roads are estimated
to total 7,500 tons per year in 1973.
The restrictions on burning of turf grass fields became
effective with the 1974 harvest.^ In 1973, total acreage (sq.km)
burned was 28,077 (114) while in 1975, acreage (sq.km) burned was
about 17,000 (69). The emission reduction achieved from 1973 to 1975
was 166 tons per year. Emissions in 1973 from grass field burning
were 421 tons per year and in 1975 were 255 tons.
Further information on area source compliance status was not
available for this study.
-------
VI. SUMMARY
The following summary presents those significant findings
which contribute to a description of the reasons for TSP standards
non-attainment in Spokane County:
1. The geographical area of non-attainment for primary TSP
NAAQS appears to extend in a band from the Spokane central down-
town area east-northeasterly for approximately 3.5 miles (5.6 km).
The most recent available ambient data indicates that four monitors
within this area are exceeding the 24-hour and or annual primary
TSP standards.
2. The two stations with the highest TSP concentrations are
those located at Crown Zellerbach and the Aluminum Supply Company.
Both are in an industrial area. The highest annual geometric mean
3
for Calendar Year (CY) 1974 in the Spokane area was 90 pg/m at the
Crown Zellerbach site. During Fiscal Year (FY) 1975, the first 12
months of record at the Aluminum Supply Company monitoring site,
3
a geometric mean of 119 Mg/m was recorded.
3. A strong pattern of high TSP concentrations during the
relatively dry months of July through October is exhibited on all
five sampling sites in the above described TSP non-attainment area.
4. Lower wind speeds are prevalent during the late summer
and early fal1 months.
5. The largest single point source in Spokane County is
Kaiser Mead, a primary aluminum reduction plant. Emissions are
1482 tons per year of particulates, based on the 1975 emissions
inventory. The impact of these emissions on ambient air quality
could not be made in this evaluation due to inadequate data. Kaiser
Mead is located approximately 4 miles (6.4 km) north of the city
center and the TSP non-attainment area described above. Prevailing
64
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winds would carry emissions from this facility away from Spokane
during most of the year except the winter months when TSP concen-
trations have been noted to be lowest.
6. Seasonal activities include agricultural harvest acti-
vities with associated increased grain handling operations and
field burning, and gravel pit-crushing-screening-stockpiling opera-
tions. These activities are reported to be greatest during the
summer and early fall months. Some or all of the seven grain
handling facilities in the Spokane City area experience increased
activity during this time of year. Estimated emissions from grass
field burning (no closer than 15-30 miles (24-48 km) from the City
of Spokane) have been reduced from 421 tons in 1973 to 225 tons
in 1975. Four different companies conduct gravel pit, crushing,
screening, and stockpiling operations with a 0.5 mile (0.8 km)
radius of the monitor located at the Aluminum Supply Company.
Combined emissions are estimated to be 111 tons per year plus 25
tons per year from a rotary asphalt dryer. Production is strongly
dependent upon the seasonal demand for gravel and concrete.
7. As of 1974, it was estimated that 240 miles (384 km)
of dirt roads in the City of Spokane contributed 1,000 tons of
particulates annually. Within a radius of 0.5 mile (0.8 km) of the
Crown Zellerbach and Aluminum Supply Company monitors, there are
(as of January 1974) approximately 7.8 (12.5) and 2.4 (3.8) miles
(km) of unpaved roads respectively. Calculated emissions show that
these roads in the area of the Crown Zellerbach monitor contribute
approximately 44 tons per year of particulates less than 10 microns
in size. The 2.4 miles (3.8 km) of roads around the Aluminum Supply
Company monitor were calculated to contribute 12 tons of less than
10 micron particulates annually. Emissions are likely to be con-
centrated during the dry part of the year.
8. The data shows a good correlation between dry periods and
ambient TSP values. An analysis of 27 days with ambient TSP
65
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3
concentrations in excess of 150 fjg/m showed that 25 of the days
were preceeded by rainless periods of three days to oyer one month.
9. No correlation between wind direction and TSP concentra-
tions was noted. Such a correlation was attempted for the Aluminum
Supply Company and Crown Zellerbach monitors for August through
October 1974.
10. No significant weekend-weekday variation in TSP concen-
trations were found.
11. Data from a maximum TSP concentration site was not
available when the SIP rollback calculations were being performed.
The maximum concentration site value used for the original control
strategy rollback was approximately 37 percent lower than the annual
value recorded two years later at the Crown Zellerbach site during
its first year of operation.
12. The original emissions inventory upon which rollback cal-
culations were based was approximately 43 percent lower than a more
comprehensive inventory completed in 1973, due largely to the
omission of the contribution from unpaved roads in the SIP inventory.
13. No regulations in the control strategy govern the
emissions from, or the paving of, unpaved roads. It was not deter-
mined in this study if RACT is being applied to fugitive industrial
emissions such as grain handling facilities and rock crushing,
screening, and stockpiling operations. All remaining aspects of the
control strategy appear consistent with, or are more stringent than
RACT.
14. Twenty-two of the twenty-seven listed particulate emitting
point sources located in the Spokane City area are in compliance.
Four of the five remaining sources are scheduled to be in compliance
by July 1976 or before. The remaining source has only periodically
exceeded emission limits and its compliance status is presently
being negotiated. All five of these sources are located in an area
66
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with a radius of 2 miles (3.6 km). Four of the five sources are located
within the previously described TSP non-attainment area. The total
particulate emissions from all five sources that are out of compliance
is only 145 tons per year.
15
15. Droege and Clark performed a special study in 1972 and
1973 to describe the TSP problem in Spokane County. Their findings
are consistent with those of this study and include:
a. Higher TSP concentrations are found on dry days
as opposed to days with precipitation, regardless
of the time of year.
b. TSP concentrations are higher during the summer
than the winter.
c. High TSP concentrations are associated with strong
winds and low humidity.
d. Considering the sampling months of May, August
through September, November and January, the metals
and organic composition were highest in November.
e. Only half as many filters were in the brown-green
range (as opposed to gray) during the November/
January sampling periods compared to the May/August
- September sampling period.
67
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VII. CONCLUSIONS
Fugitive dust/fugitive industrial emissions are the likely
major causes of TSP non-attainment in Spokane. The likely major
contributors are (1) unpaved roads, (2) emissions from gravel
pit, rock crushing, screening, and stockpiling operations, and
(3) possibly natural wind blown dust. All monitoring sites in
the non-attainment area exhibit the same general trend of high
TSP concentrations during the summer and early fall months. No
apparent correlation between wind direction and TSP concentration
was noted. These two findings would imply an area fugitive dust
source.
The two monitors with highest TSP concentration, Aluminum
Supply Company and Crown Zellerbach are centrally located in major
fugitive dust-fugitive emission areas. The Aluminum Supply Company
monitor is surrounded by nine sources within a radius of .8 miles
(1.3 km), all of which would be associated with fugitive emissions.
The sources include three feed-grain operations, four gravel pit-
crushing-screening-stockpiling (plus one asphalt) operations
(136 tons per year), one sand blasting operation (5 tons per year),
and one automobile fragmentor (15 tons per year). Total inventoried
emissions from these operations are 205 tons per year. It should be
noted, however, that fugitive industrial emissions are not easily
quantified and estimations may be subject to considerable error.
In addition, calculated emissions from the 2.4 miles (3.8 km) of
unpaved roads located within a 0.5 mile (0.8 km) radius of the
monitor are 12 tons per year. Most all of these emissions are
seasonally oriented, tending to be concentrated in the dry summer
and early fall months. This corresponds to the observed annual
pattern of high TSP from July through October.
The Crown Zellerbach monitor is located in the center of one
of the largest concentrations of unpaved roads in the city. Within
68
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a 0.5 mile (0.8 km) radius alone, 7.8 miles (12.5 km) of unpaved
roads were calculated to emit approximately 44 tons of particulates
annually. In addition, five point sources located within one mile
(1.6 km) west to northwest of the monitor emit a total of 188 tons
of particulates annually. It is important to note that most of
these emissions come from Long Lake Lumber (106 tons per year) and
the Washington Water Power boiler (59 tons per year). Long Lake
Lumber is considered in compliance with applicable emission limi-
tations. Emissions from the Washington Water Power boiler (com-
pliance status presently being negotiated) are seasonal, but are
concentrated in the winter months when combustion of oil and
associated soot blowing operations are more prevalent. Since high
TSP values are recorded predominantly during the late summer and
early fall, emissions from this boiler do not appear to be associa-
ted with the non-attainment problems. Long Lake Lumber emissions
are likely to be relatively consistent throughout the year. Rough
modeling calculations have shown that the maximum impact of emissions
from this source on TSP concentrations at the Crown Zellerbach
monitoring site are now likely to be minor. Emissions were reduced
from 396 tons per year to 106 tons per year with the installation
of a baghouse on the hog fuel boiler in October 1974. It is relevant
to note that emissions release points for both Washington Water Power
and Long Lake Lumber are elevated, with effective stack heights
permitting much better particulate dispersion than the ground level
emissions from dusty roads. Since (1) no correlation was noted
between TSP concentration and wind direction when studied at this
monitoring site during August through October 1974, (2) high TSP
concentrations are found predominantly during the late summer and
early fall, and (3) modeling has shown the maximum impact of
emissions from Long Lake Lumber on the Crown Zellerbach site to be
minimal, it appears likely that unpaved roads are strongly affecting
the TSP concentrations at the Crown Zellerbach monitor.
69
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The Gonzaga University and Spokane City Hall monitors may
be influenced primarily by the numerous emission sources discussed
above that are located near the Aluminum Supply Company and Crown
Zellerbach monitors (Consult figures 13 and 14).
Periodically, during periods of strong wind, high TSP
concentrations are likely to result from wind blown dust origina-
ting from natural sources, barren farm lands, dusty roads, stock
piled materials (such as gravel), etc. April, one of the months
noted as having high TSP concentration, is shown in Table 7 as
also having the highest average monthly wind speed.
Agricultural field burning is not likely to be a significant
contributor to high TSP in Spokane, particularly with the acreage
reduction program being implemented. This is further substantiated
by the following: (1) The nearest two field burning areas are 15
(24) and 30 (48) miles (km) from Spokane, (2) burning is normally
conducted on days with meteorological conditions favorable for
dispersion of emissions.
The rollback calculations upon which the particulate control
strategy was based were strongly deficient with respect to data
input. Ambient TSP concentrations have been shown to be at least
36 percent higher than the concentrations available during SIP
development. Countywide emissions to be reduced have also been
shown to be nearly 90 percent higher than emissions estimated in the
rollback calculations.
70
-------
VIII. RECOMMENDATIONS
1. Initiate a program to control emissions from unpaved
roads in the City of Spokane. This may or may not entail a
revision to the control strategy.
2. Reassess the magnitude of fugitive emissions from
industrial operations in the geographical non-attainment area.
Re-evaluate the compliance status of such sources.
3. Conduct a special monitoring study to determine the
impact of emissions from gravel pit-crushing-screening-stockpi1ing
operations on ambient air quality. A network of particulate
sampling devices together with appropriate meteorological equipment
should be located immediately downwind of these operations in the
area of the Aluminum Supply Company. Sampling should be conducted
during both operating and non-operating periods, and during wind
conditions which are both favorable and unfavorable for measuring
maximum impact of emissions from these sources.
4. Determine RACT for gravel pit-rock crushing-screening-
stockpiling operations. Compare existing emission controls with
RACT for those operations conducted in the Spokane city area.
5. Consideration may then be given to revising the control
strategy through the addition of specific fugitive emission regulati
-------
SPPKAt'E COU-TY PRIORITY ArATEt.E-:T AREA LOGATIO
-------
-------
-------
-------
1974
FIGURE 5. 1974 MONTHLY GEOMETRIC MEMS FOR STATIONS 5,6,7,8 & 10
-------
STATIONS 5.6.7,8.10
"•"CH APRIL
JC i>5 8 ID IS 2O 9% a 10 »S to 29
juke jult auoust (crrcMacft
lO <¦.- 2P 25 S lO 15 ?Q as 9 10 13 20 ?S 3 «0 15 SC
300-
275-
E5C
225-
CT*\ r
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s. .
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. tft
75-
5TATI0N:5= ©SPOKANE CiTY HALL "(LOCAL)'
- - 6- *C ROW'N ZELLERBACH
7 = AGQNZAGA UNIVERSITY
§, = DSPOKANE CITY HALL (fEOERALJ
J5= A ALUMINUM SUPPLY CO, > ....'
1975
¦rr,.-r-
.. r-
'\r
-------
SUSPENDED PARTICULATES (/Ulq/m3^
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-------
FIGURE 8. HISTORICAL MONTHLY GEOMETRIC MEAN DATA
-------
-------
-------
FREQUENCY DISTRIBUTION
00
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YEAR i974
STATION
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TOTAL SAMPLES!37
FIGURE 9
-------
FREQUENCY DiS i RiBU
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TOTAL SAMDLES'.40
-------
FREQUENCY DISTRIBUTION
00
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YEAR 1S74
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TOTAL SAMPLES'-40
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FREQUENCY DISTRIBUTION
00
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FREQUENCY DISTRIBUTION
YEAR 1374
STATION #6
00
cn
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FREQUENCY DISTRIBUTION
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TOTAL SAMPLES*. 63
-------
REQUENCY DISTRIBUTION
YEAR 1974
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TOTAL SAMPLES:26
-------
FREQUENCY DISTRIBUTION
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FREQUENCY DISTRIBUTION
YEAR !974
STATION #\
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-------
STATION :5= ~ SPOKANE CITY HALL(LOCAL)
7 = 0 GONZAGA UNIVERSITY
400-
350-
300-
250
200-
150-
100-
50-
1970 1971 1972 1973 1974
FIGURE 10. HISTORICAL SECOND HIGHEST 24 HR. DATA AT SPOKANE CITY HALL
(T,OCAT,> AND GQVZAr-A UNIVERSITY
-------
TURN BULL WILD LlFh REFUGE- station
1974
-------
TURNSU'JLWtLtfu[ft. WPJGE- fflncw
KC-C«*£S
.?-
ii ¦
1974
rr'
! -
'1,
-------
SOC--
27?-
250-
-------
ROGERS HIGH SCKCOL-
: 9
-------
300-
275-
25C — •
P
225- li
•I
SPOKANE CITY HALL(LOCALVsta-ion*5
-------
300—
CROWN ZELLERBACH-s^tio.^s
32 o. *
- A
y
1\
u\
>\h
i \
i i !
A
N
—6
i ;
' W
L &
o-^
/ . ;;
\ /—
I;
A
/
\/
!• j?
/\ n
-------
GOMZAGA JUIVE^SITY—s-a-cn^7
1974
-------
30C —
O—~
SP CITY HALL'FEDEPAUs^:on-e
-------
27 j—
250 —
225—
^2CC—
K) I
¦f- -
Si'5o—
! 125-
1!
ajiCO-
75-
¦\-i
"V/
i
25 —
MILLWOOD CITY HALL-sta-:on
-------
30C —
275-
250-
22a-
D
2 1e
o
200-
:75—
150-
125—
00 —
75-
50
25
0
ALUMINUr/1 SUPPLY CO. -s-aT'O^o.
1974
-------
•~oi
1— (-25-
-------
3C0 —
^j275-
I
O,
tt!
P
-------
UJ
o
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W~ 4 X
V
* i \
\ i
t h i-
h _ J [ __
. ?. / i M
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\ f • l ;
-V- \: '
A
. /
4
" A "A
- ¦ A
\ ' \/
k
-
\ /
197 5
ROGERS HiG- SCHOOL-station^
-------
m
UJi 215-
I— ;
<;
i:
Z) 200-
U;
I— >
!S75
SPQKAME CITY HaLLCLOCAQ-s~a~icn^
-------
300-
J 275-
o — - -
CROWN ZELLEREACH-stat!on**6
(s
19/5
-------
fceoJA*Y
u
30C-
'
Z^25C~
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225-
: r - • c • ^ ? * t - ~ • -: ' ¦* * * ¦ • ' :
1975
-------
SPOKANE CITY HALL (FEDERAL) ~ s tat ic n ~8
1- .T
300 —
r
L-.
1
2 75-
fc;
v.
^25 0-
¦
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C:
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/
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' 97 5
-------
300-
rl
i. '2 7 5 •
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-a! r
lO.ZZb-
;2CC —
Oi
-------
* r-> :?*
1975
ALUMINUM SUPPLY CO-staticn^
5-TTfVK'
s 10 :s .-? r: 5 to •"• z*
\
-------
-------
-------
Legend:
Point Sources and Emissions in Tons Per Year
1.
Kaiser Mead - 1482 tpy
<«
14.
Central Premix (Carnahan Rd.) - 10 tpy
2.
Kaiser Trentwood - 125 tpy
15.
Acme Concrete - 11 tpy
3.
Long Lake Lumber - 106 tpy
16.
Ace Concrete - 70 tpy
4.
Imperial Wood Products - 24 tpy
17.
Inland Asphalt - 45 tpy
5.
Spokane Pres-to-log - 37 tpy
18.
S & F Construction - 11 tpy
6.
Sentex Veneer - 27 tpy
19.
Washington Water Power - 59 tpy
7.
Spokane Seed - 34 tpy
20.
Inland Foundry - 13 tpy
8.
Boyd Conlee - 30 tpy
21.
Spokane Steel Foundry - 7 tpy
9.
Inland Empire Pea Growers - 9 tpy
22.
American Recycling - 15 tpy
10.
Inland Farmers - 6 tpy
23.
Hillyard Processing - 20 tpy
11.
Western Farmers - 6 tpy
24.
N. Pacific Grain Terminal - 12 tpy
12.
United Paving - 20 tpy
25.
Burlington Northern (boiler) - 7 tpy
13.
Central Premix (Gov. Way) - 28 tpy
26.
N. W. Sandblasting - 5 tpy
27.
Centennial Mills - 5 tpy
113
-------
-------
STATION #6 CROWN ZELLERBACH
m -
300
250-~
200
• •
130-
• •
-*Hr
• •
4-
4-
4-
-4
6300
900 1800 2700 3600 4500 5400
PM MIXING HEIGHT (FT.)
¥T flllBlf 1 5 - AMRTB1JT HAT A UKBSMS MTYTMrt HRT f2UT
7200
4-
4
8100 9000
-------
AAA _
r STATION #10 ALUMINUM SUPPLY CO.
359 •
30G ¦»
250
i
200 '
= 150 f
«
H
<
100 ¦-
50 ir
-4 • * • I \ 1 1 » *
90018002700360043005400630072008100
PM MIXING HEIGHT (FT.)
-------
MONTHLY AVERAGED CONCENTRATION v MONTHLY PRECIPITATION
30CH
£
v_y
2
O
1—
<
cr
i.
200-
p—
2
LlJ
O
2
O
o
-
UJ
e>
<
a:
UJ
>
<
100-
>-
L
X
t
t—
2
O
2
X SEP
XOCT
uOCT
~ SEP
X AUG
XJUN
~ AUG
~ JUN
0
X = ALUMINUM SUPPLY
~ = CROWN ZELLERBACH
0APL
~ MAY
X JUL
~ JUL
~ MAR
XDEC
XNCV
~FEB
~ DEC
~ NOV
~ JAN
0
.0 2.0 3.0
MONTHLY PRECIPITATION (INCHES}
FIGURE 16. MONTHLY AIR QUALITY DATA VERSUS PRECIPITATION
4.0
-------
400-
X236
X.-ALUMINUM SUPPLY
C = CROWN ZELLERBACH
..NUMBERS SHOWN REFER TO MEAN .
WIND DIRECTION AT GONZAGA STATION.
f:
-—I
Xi90
—0236-
300-f-
«n
c
: Qt23
~ "X123
-0 67 —
I . .
X67-
-a
x
X93
t— i- -
ir 200-f—
iu
o
2
O
o
I-
j
I
122
3122
-13142;— -
vl95
fiIS5
100
I—
I
I ;
I
¦I-- —
~ 93
- *142
g!04
"155"
DI90
xl IS
0118
XI75
0175
*216
.0216
T~
. t.
I
--f-
0-(-
—
3
5 6 7
WIND SPEED (mpn)
-1
8
FIGURE 17. DAILY AIR DATA VERSUS WIND SPEED/DIRECTION
-------
TABLE 1. MONITORING STATION DESCRIPTIONS
}
Station Kaxe
Station ID Xunber J
SAROAD/DOE/SCAPCA |
Address
I
Sar-.pler !
KeipVit j
Operating !
Agency ;
Areal
Consents
Turnbull
a'ildlife
Refuge
49206CC02I01 !
3250C04E I
1 t
N'at'l Wildlife
Refuge, Cheney
15' j
i
i
c i !
Spokane !
APCA |
Located in rural area. j
background station. j
jCheney
City Hall
1
49032002F01 !
3214002E 1
2 1
I
2nd and D St.,
Cheney
30' '
i
Spokane i
APCA |
\
i
1
i
Conrr.ercial and residential
oriented, Sear center of
town. One block from flour
rill, 4 block? €rc~ 12 g,rain
storage tovers.
Sogers High
;School
j
t
492040017101 i
3273006E 1
4 i
Helena and
Welleslv Street?
30'
Spokane
APCA
Residential oriented site.
iSffokane City
iHail
:(Local)
492040011F01 i
327S001A. |
5 i
221 S. Wall St.
70'
T.Cash. T}0E
.
Commercial oriented site. ;
Leer red in clox.Titovn area. ¦
i
• Crown
'Znllerbach
1
492040016X01 j
3276009E
6
¦
¦
3530 E. Ferry
23'
Spokane
AFC A
Industrial oriented site.
Lor£ Lake L'.inb^r, Centennial
Crovi.:rs. IcnLgh Ce-iont vitkin'
1 -lie, survc-T.cing cu«ty
rojen.
jGcnzaga
i'Jniversi ty
1
1
492040012701 ¦
3278060A
— - 1
i
302 E. Boone St.
15'
Wash. DOE
Corniercial arc industrial
oriented. Ccr.sc Tree:nr. ;
Central Prer.iy. and Inland
!'e';als vitbr'.n *. nil?.
jCity Hall
j (Federal)
1
1
j 492040001AC1 i
i «
221 N. Wall St.
70'
Same Spokane City Hall 1
(Local). i
'Mil Ivrood City
Jlall
i
t
! 492050002101
: 3230004E 1
1
i
?1C3 E. Frederick,
Mill'-ood
20'
i
Spokane
APCA
Cemerciai ar.d residential
oriented. SCO y-rac fror. i
Inlr.nd Empire- P.irer. ^
V'npaved reads T.csPt of ?ite.
jAluslnum
[Supply Co.
i
i
i
V
1
i
i
800 X. Fancher Road
15'
i
1
Spokane
APCA
i
Industrial oriented site.
Spokane Seec, Inland
Asphalt. Ac-«. rvc.e, Ccn-
: trrj. ?rcni>:. Inl
-------
TABLE 2. 1974/1975
ANNUAL GEOMETRIC MEANS
Primary Standard
for Annual
Geometric Mean
- 75/ig/m3
Secondary Guide
for Annual
Geometric Mean -
¦ 60/ig/m3
1974
FY 1975*
Station Name Station ID Number Number
of Annual
Number of
Annual
SCAPCA
Samples Geometric Mean (pig/m )
Samples
Geometric Mean (ptg/n
Turnbull Wildlife Refuge
1
37
21.1
45
21.5
Cheney City Hall
2
40
59.4
55
50.9
Rogers High School
4
40
55.1
45
62.8
Spokane City Hall (Local)
5
61
75.2
58
65.5
Crown Zellerbach
6
58
90.0
57
83.3
Gonzaga University
7
63
75.5
59
73.2
Spokane City Hall (Federal)
8
26
74.9
25
68.7
Millwood City Hall
9
34
59.3
46
55.3
Aluminum Supply Co.
10
29
148.2**
58
119.3
~Although annual standards are based upon a calendar year, data for the Fiscal Year are presented to depict
12 month means from the most current data available.
**Station operated only last 7 months of year
-------
TABLE 3. 1970-1974 ATNTAL GEOMETRIC KEASS
3
Primary Standard for Annual Geometric Mean - 75 jig/ta
Sscc-.cary Guide for Annual Geometric Meats - 60 jig/a"*
Station Natne
> T'irrrb-ull '-'i-olife
I Rrtune
I
; Ocr = y Zizy rial!
: "Sobers HigV. School
r.pcCit;' Ka! L
I CJ.cc?.]j
Crcvn Zellerbach
J Gonzaga University
' 5cc''ean
•'} of
Amual
¦i of
Annual
Samples > Geo. y.eari j Samples j Geo. Mean
90.6
56
57
25
2}. 5
66.4
98.7
£1.5
¦86
65
91
60
100
19
21.0
76. 2
52. 1
i
120.5
i 110.7
99.8
j •' of Annua"-
i Samples ! Geo. Me.-n
i_ j—.
Goo. Mean Sar.plec
39
54
58
52
6S
22
I
67.0
82.i
113.5
si
63
26
34
29
21.1
55
i 57
i 55
! 25
1
i r5
I >!
*Gez;r.etrlc ceat\ based upon data available only for the last 7 months of the year.
-------
TABLE 4 1974 SECOND HIGHEST 24-HOUR VALUES
Primary Standard for Second Highest 24-hour Value - 260
Secondary Standard for Second Highest 24-hour Value - 150fig/:r.
Staticn Nane
SCAPCA Station
ID
Sur.ber
N-jTuber
of Samples
Second Highest
24-hr. Ave.
0ig/ra3)
Number of Samples
Above Prinarv Standard
Number of Sar.ples j
Above Secondary Standard j
I
iTurnbull Wildlife Refuge
1
jCheney City Hall
2
i
iRoger? Kigh School
I
4
1
iSpok.an» City Rail (Local)
5
jCrcvn Zellerbach
6
t
1 Gor.za^a University
7
!Spokane City Hall (Federal)
8
[Millwood City Eall
9
;
t
;V'.cnfcaura Supply Co.
10
37
147
40
249
40 ;
161
61 |
225
i
58
323
i
288
26 i
i
1S6
34 |
122
29
325
2
6
15
11 ,
5
1
16
-------
TABLE 5. SOURCE CATEGORY PARTICULATE EMISSION INVENTORY
Most Recent
Emiss ions
Percent of Total
Source Category
1975
1973
Emissions
Proce s s...Losses
Aluminum Manufacturing
1627
11.3
Wood Products Manufacturing
194
1.4
Grain Handling
117
.8
Asphalt/Concrete
195
1.4
Foundries
20
.1
Other
20
.1
2155
15.1
Fue1 Combustio n
Residential
280
1 .9
Other
71
.5
351
2.4
Transportation
1578
11.1
Solid Waste Disposal
Slash Burning
663
4.6
Open Burning
449
3.5
On-site Incineration
1188
8.2
2350
16.3
Ml seellaneous
Unpaved Roads
7500
52.0
Structural Fires
156
1.1
Construction Land Area
120
.8
Other
191
1.3
¦
7967
S5.2
-------
TA8LF 6. POINT AND AREA SOURCE PARTICULATE EMISSION
INVENTORY FOR SIGNIFICANT SOURCES
Most Recent Emissions (TPY)
1973 Emissions
Source Category
1975
1973
Percent of Total
Emissions
(TPY)
Point Sources
Kaiser Meade
1482
10.3
2877
Kaiser Trentwood
125
.9
564
Hillyard Processing
20
,1
Long Lake Lumber
106
.7
396
Imperial Wood Products
24
.2
Spokane Pres-to-log
37
.3
Suntex Veneer
27
.2
119
PaLouse Seed Co.
(Fairfield)
7
.1
Spokane Seed
34
.2
112
Rockford Grain Growers
(Mead)
5
0.0
Boyd-Conlee
30
.2
Inland Empire Pea Growers
9
.1
Centennial Mills
5
0.0
Inland Farmers
6
0.0
Western Farmers
6
0.0
I
National Biscuit Co.
(Cheney)
15
.1
1
United Paving
20
.1
30
Central Premix (Gov Way)
28
.2
Central Premix (Carnahan
Road)
10
.1
Acme Concrete
11
.1
Ace Concrete
70
.5
Inland Asphalt
45
L ¦
.3
11
124
-------
TABLE 6. POINT AND AREA SOURCE PARTICULATE EMISSION
INVENTORY FOR SIGNIFICANT SOURCES (cont)
Source Category
Most Recent Emissions (TPY)
1973 Emissions
(TPY)
1975
1973
Percent of Total
S & F Construction
ll
.1
Burlington Northern
Boiler (Hillyard)
7
J
Washington Water Power
59
.4
15
Fairchild AFB Boilers
5
0.0
Inland Foundry
13
.1
13
Spokane Steel Foundry
7
,1
American Recycling
15
.1
N.W. Sandblasting
5
0.0
Subtotal 2244
15,6
Area Sources
1
1
I
1
Unpaved Roads
7500
52.0
1
!
On-site Incineration
1188
8.2
Slash Burning
663
4.6
Transportation
1578
10.9
914
Open Burning
449
3.5
Residential
280
1.9
380
Structural Fires
156
1.1
i
Construction Land Area
120
.8
(
!
Other
191
1.3
Subtotal 12,175
84.3
TOTAL - 14,419
100
1 or
-------
TABLE '!. SPOKANE AIRPORT/GOMZAGA UNIVERSITY METEOROLOGICAL DATA
1974 - Spokane
1974 - Gonzaga
: Noras Thru
1
1974-
International Airpo
rt
Univers
-tv
Spokane Int'I
Airport
Resultant
Resultant
Average
Average
Average
j Prevailing j
Average
tJind Direction
Wind Speed
Wind Soe-ed
Wind Direction
Wind Spaed
j Wind j
Wind Speed j
Month
(Degrees)
(MPH)
(MPH)
(Degrees)
1 Direction
-------
TABLE 8.
FREQUENCY OF ADVERSE VERTICAL MIXING
CONDITIONS AT SPOKANE AIRPORT
Month
Adverse Mixing Frequency (Percent)
4 A.M.
4 P.M.
January 1974
100%
92%
February
100%
52%
March
100%
48%
April
100%
36%
May
100%
29%
June
100%
10%
July
100%
6%
August
100%
-0-
September
100%
6%
October
100%
35%
November
100%
93%
December
100%
100%
127
-------
TABLE 9: SUMMARY OF STABILITY DATA; SPOKANE INTERNATIONAL AIRPORT, 1574
Dec., Jan., Feb.
March, April, May j
June, July, Aug. Sept, Oct. Nov. . Annual
! : !
Stabilitv
Freq. ' Wind ! Freq.
sets j
Wind
kts
Freq.
Wind
kts
j Freq,
hind
kts
t rrca.
B.
D.
r.
:otal
0.0
0.4 i 1-3
i
0.0
2.2
23.8 | 11-16
52.6
19.6
100
7-10 >100
4-6
C. | 3.6 ¦ 7-10 9.0 ; 7-10
t
7-10 I 31.8 17-10
/—10 ; 20.5 i 4-6
36.5 ! 11-16
1.0
11.8
19.6
17.7
34.2
7-10 ; 100
i
4-6
4-6
O.C
3. 8
r-io ; ii.8
11-16 j 21.2
4-6
7-10 5100
<-10
7-10
11-16
15.8 I 7-10 ! 24.3 '7-10
38.9 10-
<4-6
24.8
1100
J 0.2 ! 4-5
4.6 : 4-6
11.0 . 7-10
¦ !_1i
31.0 ; 7-10
: 4-6
! 7-10
-------
TABLE 10, 1974 WEEKDAY/WEEKEND AIR QUALITY DATA
AT ALUHINUM SUPPLY COMPANY/CROWN ZELLERBACH
Geometric Mean (p-g/m )
Station
Name
A'll
Samples
Weekday
Samples
Weekend
Samples
Crown
Zellerbach
90.0
87.9
96.8
Aluminum
Supply
Company
148.2
152.4
139.3
129
-------
TABLE 11 AIR QUALITY/METEOROLOGICAL DATA FOR 8 SELECTED DAYS
1974
"
i
Suspended Particulates
Average
Teno.
1
1 Wind Dir
action
Average
Soet d
i
J Mixing
; Height
Day i
Cf ;
Weak.
>
Gonzaga/
Airport
(Degrees)
J Average j
i Gor.-aga
.(Depress) j
Resultant
Airport
(Degrees)
! Morning/
j Afternoon
! (Ft)
1 Data
#5
i:6
"
i'8
•'ilO
n.irpor c
(M?K)
Cortnencs
1 4/17
1
i
Wed.
324
159
151
50/
46
97
i
t i
" " "
60
4/
7.2
! o/
! 4500
i>o Precipitation
' 0/27
Tuas.
184
1
|1S6
188
75/
j 122 ;
350
3/
: o/
No Preexcitation
I
73
i
5.9
J 4900
! 9/8
i
Sun.
180
168
206
66/
62
\ 115 \
\ ;
I ;
| j
220
7/
9.9
; c i
j 55CQ
So Precipitation
9/20
1
Fri.
.
279
t
199
177
266
65/
64
" r
! 67 i
! i
1 i
30
4/
7.8
; 0/
! 4300
i
So Precipitation
9/26
1
i
Thurs.
224
| 323
i
467
61/
55
i — r
; 236 :
! 1
f ;
280
9/
19.0
0/
; 3000
4* sU
Trace
1
I
! oo
o
Tues.
i 182
!
i
j 2S9
i
)
i
->gi
257
_ /
1
53
! 123
I
1
40
^ . 3/
b.O
! o/
(
i 2800
No Precipitation
j 10/14
! '
Mon.
.
j
1
! 261
263
150
253
~I
44
I 47
i
200
i.i/
3.9
0/
| 4400
No Precipitation
j 10/2C
1
1
J
Sun.
~
i
225
5 281
i
j
, 288
32S
47
j 151
:
210
5.7/
12.9
1
: 0/
1
: 8oo
N'o Precipitation
.
* ff5 Spokane Cicy Hai I (Local) ** 31owir.;; observed at airport from 1215-1310 hours FST.
v6 Crown Zelierbacii Visibility limited to 5 miles.
r7 Gonz3g3 Inivc r.;: tv
;,;8 Spckar.e City (Federal)
#10 Aluminum Supply Conpany
-------
TA3LE 12 INITIAL SIP REDUCTION REQUIREMENTS
Year !
of j
Record 1
Sice
1 !
i
1 i
; i
1 i
Highest
24-Hr
i
j N£Xl
! Highest
; 24-Kr
; i
' i
j Annual !
i Geo. i Background
I j
i Reduction Needed j
1 to Meet i
' 1
; Primary i Secondary I
1
I
No.
! Location j
Value
• Value
f
| Moan ! Value
( Stanaara ' i^uice
i '
1970 j
5
; Spokane City Hall j
j (Local) j
479
j 2S2
; 89 .-s/nJ 30 f-g/n"'
23% | 491 :
; i 1
! 1 1
TABLE 13
REVISED SI? REDUCTION REQUIREMENTS
Your !
i
i
!
! i
; j
C~ ;
Record |
i
Site
i
i Highest
j 24-Kr
: Next
j Highest
! 24-Hr
I •
' 1
I .-tnr.ual |
| Geo. ' Background
( Reduction Needec j
j ;c Meet ;
i Primary : Secondary j
j
No.
Location
! Value
j Value
j Mean ! Value
! Standard ! Guide ;
i
1972 j
o
: Crown Ze Heron ch
i
-
i
! 120.5 rs/~3 I 30 :-g/-uJ
512, i o7/a :
1 i
-------
TABLE 14. COMPARISON OF 1970 AND 1973 EMISSIONS INVENTORY
Source Category
- ' — " — "
Emissions T/Yr
I
1970
1973
Process Losses
i
Aluminum plants
2877 !
Wood manufacturing
i
515 1
Grain handling
1
i
367
Asphalt batch plants
27
Other
657
4592 :
4443 |
Fuel Combustion
Wood fired boilers
877
l
Area coal
1051 ;
i
Residential
380 j
Other
323
15
2251
395
1
Transportation
784
914
Solid Waste Disposal
Wigwam burners
Slash burning
90
663
Open burning
9
499
On site incineration
53
1188
152
2350
Miscellaneous
Dirt roads
7500
Structural fires
156
Construction land area
120
Other
800
191
800
7967
Total
8579
16,069
132
-------
TABLE 15, REVISED EMISSION REDUCTIONS BASED OS REVISED INVENTORY ONLY
SIP Identified
Percentage
Previous E~is:--;or.
; i
"Modified Er.issicr.
Reduction deeded
1
Reduction Neeced
'
Reduction N'eoced
to Keen
i
: Previous j
to Mc-5"
Modified !
to Meet
Prir.u~ry 1 Secondary
j £.17:1 ssi c r:
Primary 1 £eco;ids.rv
Er.irr.ion 1
Prirorv ¦ Secondary-
i
Standard ! Guica
Total
;
Standard Guide
Tot-1 :
St.-duru ¦ Gu^
232 49%
| S579 7/Yr
I
1973 T/i'r : -203 T/Yr
1 lb,060 T/Yr ;
3c96 17yr 7s74 7,-Vr
j
-------
TABLF 16. COMPARISON OF GROWTH DATA
Category
Growth Projections
1970-1975
Actual Growth
1970-1975
Population
3%
2.3% (City)
12.8% (County)
Industrial
Rated capacity of
existing sources,
new sources currently
under construction
.7% (City)
1U
-------
Agency/'Regulation Nunber/Category
Control Strategy
Limitation
Limitation Defined by
Seasonably Available
Control Technology
a?-.:a
Regulation I
Visual Emissions
Not to equal or be darker than No. 2 Ringelmann or 40%
opacity except 3 ir.inutes in an;.' one-hour period for
existing sources
Not to equal or be darker than Ho. 1 Ringelmann or 20%
opacity except 3 minutes in any one-hour period for new
sources and (ir. revised regulations not yei in approved
SIP) for ail sources after July 1. 1575.
The emission -of visible air pollutants can
be limited to a shade or density equal to but
not darker than that designated as Mo. 1 on the
Ringelmann chart cr 20 percent opacity except
for brief periods during such operations as
soot blowing anc startup. This 1 imitation would
general'.*.- eliminate visible pollutant emissions
irem. stationary source?.
lgitive Dust Control
(N'ct part cf control strategy
limitation but contained in
SCAPCA "Guidelines foi Ccntro
of Air Pollution from
Parking Lots, i>e>edway.s. and
Open /.re.-:;.)
Roadwavs: Private roads shall be cor-trolled b--
paving.
oiling or other surface treatment which, prevents visi-
ble dust emission and mud carryout. Good housekeeping
measures shall be used to miniirizs the accumulation of
mud or dust or. the surface. of roads. I'npaveJ shoulders
shall be maintained in such a way as to nir.inize visible
dust being generated by wind of traffic.
Parking Lots: Parking lots snail be controlled by pavir.j
oiling or other surface treatnert which prevents visible
dust emission and :.-,ud carryout. Good heysekceping rr;«a-
sarc-s shall be used to m-hoimize the accumulation of mud
cr dust on the surface of parking areas.
Open Areas: Unpaved open areas shall bo controlled by
vegetation cover or other equally effective method of
nir.isiizing wind blown, dust.
Constrjcticn, Repair and Cleaning: Visible dust gene-
rated by construction, repair and cleaning cf roads and
parking areas shall be rcintTnizcc by methods such as
wetting and the use of chemical suppressants. In
addition, at the end cf each shift all public roadways
shall be cleaned o. r.ud and dust.
Reasonable precautions c=.n be taken to prevent
particulate matter from recomirj; airborne. Some
of these reasonable precautions include the
following:
(a) Use, where possible, of water or cher.icals
for control of dust ir, the demolition cf existing
buildings or structures, construction operations.
the grading of roads
the clearing of land:
(b) Application of asphalt, oil, water, or
suitable chemicals oa dirt roads, mate:
piles, and other surface? which can,
airborne dusts;
_ais s'.cc-:-
;ive rise to
(c) Installation, and use of hoods, fans,- and
fabric filters to enclose and vert the handling of
dusty materiaIs. Adequate containment methods can
be c-aployed curing sandblasting or other similar
opera tions;
(d) Covering , at all times when in Tactic
[bodied trucks, transporting materials
rise to v -.-borne dusts;
open
to give
I
(e) Conduct cf agricultural practices such as
tilling of land, application of fertilisers, etc.
in such manner as to prevent dust frees becoming
I airborne;
"he paving cf roadwavs and
an condition:
; en
in a o]
; (s) i
|from pav
! material has he-en transported
ncvirg equipment, ores J ?"; by
their ~s inter:ance
:e prompt removal of earth cr ctner material
;d streets onto which, earth c1" other
by trucking cr earth
C!.* ^ *;'v.-1 ** IT ;
-------
¦
Limitation Defined by
Control Strategy
> "easonably Available
Agency/Regulation Number/Category
Limitation
Control Technology
•en Burning Restrictions
Prohibited, except for the following:
• fires set Cor religious ceremonies, recreational
purposes and cooking of toed for human consumption
• fires fron flares, torches, ana waste gas burners
• fires authorised by a Fire Chief, Fire Masnal or head
of a local fire district
J
icinerator
Approved multiple chamber or equivalent.
(See also grain loading limitation)
2gu. lit ion II
0.1 grains per standard cubic foot for non-combustion
Incineration: The emission of particulate
Grain Loading
sources (0.095 lbs/100 lbs refuse)
matter from any incinerator can be limited to 0.20
.
0.1 grains per standard cubic foot @ 12% CC^ for
combustion sources (.17 lbs/10^ STL')
pound per 100 pounds (2 gm/kg.) of refuse charged.
This emission limitation is based on the source
test method for stationary sources of particulate
Maximum emission rate of 40 pounds per hour.
emissions which ¦¦¦•ill bo published by the Administra-
tor . This method incivc2s both a crv filter and
•wet izpingors and represents particulate nat ter of :
j7C°F. and 1.0 atmosphere pressure. j
i I
1 Fuel Burning Ecuipnent: The emission of
particulate natter frora fuel burning equipment I
I burning solid fuel can be limited to 0.20 pcund per :
• si I lien B.t.u. (0.54 gm/1011 gm-cal) cf heat inputs.
This cT.i ssion linitation is based on the source test'
method for stationary sources of particulate |
emissions which will be published by the Administra-!
|tor. This method includes both a dry filter and :
| vet impinscrs and represents particulate matter of i
;70°F. and 1.0 atmosphere pressure. •
! Process Industries - General: The emission j
.of particulate natter for anv process source can be |
i litaited in a manner such as in Table I. Process j
'• weight per hour aeans the tctal weight cf all _ S
1 materials introduced into any specific process that '
nay cause any emission cf r-.Tticulate natter. Scltdi
; fuels charged are con.-icsrec as part of the process
I weight, but licuid and gaseous fuels ar.d combustion !
; .iir are not. For a cyclical or batch operation, the,
I protest- weight p»r hour is derived by rfvic-''-c !
1 total nrocess weight the number cf .tours one 1
-------
I Limitation Defined by
i
Control Strategy
| Reasonably Available
1
1
Ag-;ncy/Regalation Number/Category
Li-ication
j Control Technology
c;;i-l-3tion II (continued)
process to the c.-pletion
thereof, excluding any ;
Cra in Lcadin.;
j tin-.c curing vhiclv the equi
p-.ent is icle. Tor a J
continuous operation, the
process weight per heer '
is derived by dividing the
process weight for a ;
'
j typic :I period cf tire.
i
1
!2I
ter 10-16
Kicld Lurninr.
V'.OV
VriTirv Al'-asinum Plants
Ls'-U'I Ki: issicr.s
i-rocess
reight rate
(Ibs./hr.)
50 . .
2. .000
5.000
10, OX
20,000
60.000
30 n ^
120,000
160,000
L/' »j j '1;
"CO,COO
1,000,000
Open burning of field grasses shall be prohibited
after the 1973 harvest. Open Vivnirs of al j turf
grasses scheduled icr the tear cut shall be pro-
hibited effective in 1975
15 lbs/ton of alu:r.ir.i:.n proc
cn a dai1v basis
r'o",: 'ill nev sources and after July
"c ivcss, no person shall cause or
for core thr.n 3 minutes in any one
tarsinr.nt f'or: ar.y source which at
exceeds 20"' o.Mcitv.
L, 1073 for all
;rnit the. emission
.our, or an air con-
:e -mission coir.t
Emission
rate
(Ibs./hr.)
0. 36
0
1. 51'
2 . 25
6. 3i
1 .4 . ^
o5
3-.i:
40. 35
46.72
i
\
i
-------
TABLF IS. POINT SOURCE COMPLIANCE STATUS
Total Point Sources - 27
Greater than 1000 T/Yr 1
Less than 1000 but greater than 100 T/Yr 2
Less than 100 T/Yr 24
Point Source Compliance Status
In compliance with schedule 3
Not in compliance with schedule 2
138
-------
TABI F 19. POINT SOURCES KNOWN TO BE OUT OF
COMPLIANCE AS OF NOVEMBER 28, 1975
Emissions (TPY) Compliance Date
Out of Compliance Meeting Schedule
Boyd Conlee
Inland Empire Pea Growers
30
9
4/30/76
7/2/76
Inland Foundry
13
3/31/76*
Out of Compliance Not Meeting Schedule
Spokane Seed
Washington Water Power**
34
59
7/1/76
* Date obtained from information provided in SCAPCA "Board Meeting
Minutes - October 27, 1975.
** Based on a December 15, 1975 conversation with Rick White of the
Region X Air Compliance Branch, the Washington Water Power boiler
is out of compliance for only approximately 30 minutes each day
during soot blowing operations and only during those periods
when oil is burned.
139
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REFERENCES
1. "Preliminary Evaluation of the Washington Air Quality Monitoring
Network FY 75", Surveillance and Analysis Division, Environmental
Protection Agency, Region X, Seattle, March, 1975-
2. "Air Quality Data, Spokane County", Spokane County Air Pollution
Control Authority, 1974, January - June, 1975.
3. "Spokane County Ambient Air Profile", Spokane County Air Pollution
Control Authority, January, 1975.
4. "Air Quality Data, Spokane County", Spokane County Air Pollution
Control Authority, 1970 - 1973.
5. "Preliminary Spokane Air Quality Profile, June 1974", Surveillance
and Analysis Division, Environmental Protection Agency,
Region X, Seattle, January 1975.
6. "Emission Inventory Information for Point Sources, Dirt Roads,
Turf Grass Burned", Spokane County Air Pollution Control
Authority, August, 1975.
6A. "NEDS Point Source Listing - Spokane County", Surveillance and
Analysis Division, Environmental Protection Agency, Region X,
Seattle, October 1975.
6B. "Point Source Emissions Summary" from SCAPCA, November 1975.
7. "Local Climatological Data - Spokane International Airport",
National Oceanic and Atmospheric Administration, U.S. Department
of Commerce, January - December, 1974, January - June, 1975.
8. "Local Climatological Data, Annual Summary with Comparative Data -
Spokane, Washington", national Oceanic and Atmospheric
Administration, U.S. Department of Commerce, 1974.
9. "Air Quality Data Summary Report - Spokane Boone Street Station",
Washington Department of Ecology, January - December, 1974,
January - June, 1975.
10. "Information on Radiosonde Soundings - Spokane International
Airport", National Oceanic and Atmospheric Administration,
U.S. Department of Commerce, 1974.
11. "Joint Frequency Distribution of Wind Direction, Wind Speed and
Stability", National Climatic Center, Asheville, N.C., 1974.
140
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12. "Paved/Unpaved Roads - Spokane City", Spokane City Engineer,
January 1974.
"Paved/Unpaved Roads - Spokane County", Highway Planning Division,
Washington Department of Highways, 1974.
13. Telephone Conversatior with Fred Shiosaki, Director, and Jim Frank,
Engineer, Spokane. County Air Pollution Control Authority,
October 23, 1975 and December 4, 1975 respectively.
13A. "Log of Air Pollution Control Equipment Breakdowns - 1975;
Complaint Form - 19 74, 1975", Spokane County Air Pollution
Control Authority.
14. "Activity Report - September, 1975", Spokane County Air Pollution
Control Authority.
15. "Variation in Composition of Suspended Particulate Material in
Spokane", H.F. Droege and S. Clark, Presented at PNWIS - APCA
Annual Meeting, November, 1972 and November, 1973.
16. Workbook of Atmospheric Dispersion Estimates, D.B. Turner,
National Air Pollution Control Administration, Cincinnati,
Ohio, 1969.
17. "Requirements for Preparation, Adoption, and Submittal of
Implementation Plans, Appendix A - Air Quality Estimation",
Federal Register. August 14, 1971.
18. A Plan for the Implementation, Maintenance and Enforcement of
National Ambient Air Quality Standards in the State of
Washington, Washington State Department of Ecology, Second
Edition, January, 1973.
19. "1970 - 1975 Land Use and Population Data", Spokane City Plan
Commission, September, 1975.
20. "1970 - 1975 Commercial, Industrial and Population Data", Spokane
County Planning Commission, August, 1975.
21. "SCAPCA Regulation I", Spokane County Air Pollution Control Authority,
September, 1971.
"SCAPCA Regulation II", Spokane County Air Pollution Control
Authority, October, 1971.
"Guidelines for Control of Air Pollution from Parking Lots, Roadways
and Open Areas", Spokane County Air Pollution Control Authority,
June, 1975.
-------
22. "Washington General Regulations for Air Pollution Sources",
Chapter 18 - 04 WAC, July, 1974.
"Washington Open Burning Regulations", Chapter 18 - 12 WAC,
September, 1973.
"Washington Field Burning Regulations", Chapter 18 - 16 WAC,
September, 1973.
"Washington Suspended Particulate Standards", Chapter 18 - 40 WAC,
January, 1972.
"Washington Air Pollution Control Board Regulations, Primary
Aluminum Plants", Chapter 18 - 52 WAC, May, 1970.
23. "Requirements for Preparation, Adoption, and Submittal of
Implementation Plans, Appendix B - Examples of Emission
Limitations Attainable with Reasonably Available Technology",
Federal Register, September 13, 1973.
24. "CDS Source Data Report - Spokane County", Surveillance and
Analysis Division, EPA Region X, August, 1975.
"Extracts from First and Second Semi Annual Reports, Washington
State Air Quality Implementation Plan", Washington State
Department of Ecology, February and August, 1973.
Analysis of Final State Implementation Plans - Rules and
Regulations, Office of Air Programs, Environmental Protection
Agency, Research Triangle Park, July, 1972.
Air Quality Data for 1967 from the National Air Surveillance
Network, APTD - 0741, Environmental Protection Agency, Research
Triangle Park, August, 1971.
Guidelines for Air Quality Maintenance Planning and Analysis,
Volume 11: Air Quality Monitoring and Data Analysis, Office
of Air/Waste Management, Environmental Protection Agency,
Research Triangle Park, September, 1974, 450/4-74-012.
"Guidelines for Need for Plan Revisions to the Control Strategy
Portion of the Approved State Implementation Plan (Draft)",
Office of Air Quality Planning and Standards, Environmental
Protection Agency, Research Triangle Park, August, 19 75,
OAQPS 1.2-011.
14?
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I BIBLIOGRAPHIC DATA
•«•••'* r
. Report No.
EPA 910/9-75-016
4. Title and Subtitle
Evaluation of National Ambient Air Quality Standards (NAAQS)
Nonattainment: Methodology and Example Total Suspended
Particulate Analysis for Spokane County
7. Author(s)
Victor Yamada & Robert Missen (PES), Michael Schultz (EPA-RX)
3. Recipient's Accession No.
5. Report Date
January 1976
6.
8, Performing Organization Rept
No.
9. Performing Organization Name and Address
Pacific Environmental Services, Inc.
1930 - 14th Street
Santa Monica, California 90404
10. Project/Task/Work Unit No.
Task Order No.: 16
M. Contract/Grant No.
BOA No. 68-02-1378
12. Sponsoring Organization Name and Address
Air Programs Branch, Air & Hazardous Materials Division
EPA - Region X
1200 Sixth Avenue, Seattle, WA 98101
13. Type of Report & Period
Covered
July 1975 - January 1976
14.
-_j
15. Supplementary Notes
16. Abstracts methodology is presented to assess reasons for nonattainment of NAAQS and
to propose corrective actions which would lead to attainment of the standards. An
application of this methodology to evaluate the TSP nonattainment situation in Spokane
County is also presented. The methodology, tailored primarily for TSP and S02. consist
primarily of: (1) a logical, primarily nonmodeling approach to identifying source-
receptor relationships and (2) an analysis of the development, implementation, and
enforcement of the existing SIP. Likely categories of corrective actions are also
presented.
The primary area of TSP nonattainment in Spokane County extends in a band from the
Spokane City Center east-northeast for approximately 3h miles through the industrial
corridor. Likely major reasons for nonattainment include fugitive dust from unpaved
roads and fugitive industrial emissions. Recommendations include control of emissions
from unpaved roads in the city and conducting an ambient monitoring study to assess the
•impart nf funit.ivp pmi<;sinn<; frnm flraupl nppratinir;
17 KevWords and Document Analysis. 17o. Descriptors
17. Key
1.
2.
3.
4.
5.
6.
Air Pollution
Dust
Aerosols
Sulfur Dioxide
Regulations - Pollution
Standards
17b. Identifiers/Open-Ended Terms
1. National Ambient Air Quality Standards
2. Attainment of Ambient Air Quality Standards
3. Nonattainment Evaluation
4. Control Strategy Revision
5. Spokane County
^7c. COSAT1 Field/Group
18. Availability Statement
Unlimited
19. Security Class (This
Report)
UNCI .ASSIFIF.D
21. No. of Pages
143
50. Sec urit y Class (Vhis
Page
UNCLASSIFIED
22. Price
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