ENVIRONMENTAL PROTECTION AGENCY
ROCKY MOUNTAIN-PRAIRIE REGION
REGION VIII
COMPLETION OF STATE IMPLEMENTATION
PLAN (SIP) APPROVALS AND
ESTABLISHMENT OF COMPLIANCE SCHEDULE
JUNE 5, 1972

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ACCOMPLISHMENT PLAN
REGION VIII
Completion of State Implementation Plan
(SIP) Approvals and Establishment
of Compliance Schedule
June 5, 1972

AND EVALUATION

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I. Priority Area Identification
This plan covers the States of Colorado, Montana and Utah,
which includes 16 AQCR's, of which 9 are priority I or IA. Table I
gives the names of,,those specific AQCR's and the pollutants of concern.
TABLE I
AQCR's of Priority I or IA
Colorado
Pawnee Intrastate
(AQCR 1) (northeast)
Metro Denver (AQCR 2)
San Isabel (AQCR 4)
Four Corners (AQCR 6)
Montana
Helena Intrastate
(AQCR 4)
Missoula Intrastate
(AQCR 1)
Great Falls Intrastate
(AQCR 2)
Utah
Wasatch Front
(SLC - AQCR)
Four Corners
Part.
I
I
IA
IA
I
IA
SO
x
IA
IA
IA
I
IA
NO,
IA
I
IA
CO
HC-O.
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II. Problem Assessment
Colorado
Problems encountered may be summarized as follows:
(a)	State lacks authority to require owners or operators
of stationary sources to install, maintain and use emission
monitoring devices, and to make reports on nature and amount
of emissions from such stationary sources.
(b)	AQCR's 1, 2 and 4 were given an 18-month extension
for submission of plans for secondary NAAQS for particulate
matter, because achievement of the NAAQS through conventional
controls could not be demonstrated.
(c)	AQCR 2 was given a 2-year extension for attainment
of primary NAAQS for CO and Hc - 0^.
The problems stated above have been resolved, through the
delegation of legal authority or the granting of extensions to
meet the air quality standards, and the plan has therefore been
approved. The State has indicated its intent to develop any
land use and transportation controls that are necessary to
achieve the air quality standards for CO and H - 0 . They
will seek the legal authority in the 1973 legislative session.
Montana
Problems encountered with SIP may be summarized as follows:
(a) Emission limitations cited in the plan are
insufficient to attain and maintain national standards for S0X
in AQCR 2 and 4. However, the smelter in AQCR 2 has ceased
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operations effective April 1972.
(b) SIP does not allow for disapproval of new sources
if it will interfere with the attainment of the national ambient
air quality standards.
The deficiencies will be resolved via state revision or
EPA promulgation. It is anticipated that the State will
eliminate the deficiency listed in item b. EPA will probably
have to promulgate S0X emissions control regulations for the
smelters. Existing compliance schedules appear to be adequate
upon a cursory review. An in-depth review will be completed
by October 1972.
Utah
Problems encountered with State SIP are as follows:
(a)	Plan does not provide for emission data to be
made available to the public. A small number of sources may
be able to prevent release of data due to a confidentiality
clause in the Utah regulations. The Governor has indicated
his intent to alleviate this loophole with appropriate
legislation in 1973. In the interim the EPA will have to be
able to provide for the release of the data.
(b)	Plan does not provide for adequate control strategy
to attain and maintain national standards for S0x in Wasatch
Front Intrastate Region (Salt Lake City) and Utah portion of
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Four Corners Intrastate Region.
(c)	Part of plan pertaining to particulate emissions
from stationary sources is not legallyenforceable.
(d)	Plan does not provide for degree of nitrogen
oxides emission reduction attainable through application of
reasonably available control technology on stationary sources
in Wasatch Front Intrastate Region.
(e)	Portion of plan concerned with control strategy
for sulfur oxides in the Wasatch Front Intrastate Region does
not have a legally enforceable compliance schedule.
(f)	Plan does not provide for disapproval of
construction of a new source or modification of an existing
source if it will interfere with attainment of national ambient
standards.
(g)	Portion of plan concerned with manpower program
does not allow for adequate engineering activities.
(h)	Wasatch Front Intrastate Region was given a 2-year
extension for attainment of primary NAAQS for CO. The State
has indicated the intent to seek the legislation and regulation
in order to achieve the standards through transportation controls.
The deficiencies will be resolved through plan revision. EPA
will be providing the assistance for the State to make these
revisions. The State needs to attain legal authority for land use
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and transportation controls in the 1973 legislative session.
Existing compliance schedules,in some instances, are inadequate
and will need revision or promulgation if necessary. A detailed
review of additional compliance schedules must be made. Future
negotiated compliance schedules must be scrutinized.
III.	Specific Agency Objectives
(a)	Provide technical assistance to the State in order
to acquire adequate revisions or promulgate sections, if required,
to alleviate deficiencies in the SIP on July 31, 1972.
(b)	The remaining portion of SIP and transportation
controls must be submitted by February 15, 1973. Review by
EPA will be completed in March 1973.
(c)	Approve individually negotiated compliance schedules
for primary NAAQS SIP's by March 1973.
(d)	Obtain plans from states if not previously submitted
for achieving secondary national ambient air quality standards,
and approve/disapprove by November 1973.
IV.	Approach
The bulk of the work to be performed to assure SIP process
completion is covered by PE 245137. A list of the actions involved
in the completion of the SIP approvals is summarized in the
Accomplishment Schedule.
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State of Montana
The SIP does not meet the national primary standards for
S0X. It will probably be necessary for EPA to propose and
promulgate regulations for the smelters in order to achieve
the sulfur oxide standards. Headquarters personnel are
actively involved in this problem providing diffusion
modeling and other support as necessary. Assistance will be
provided by the Regional Office to the State agency in reviewing
emergency episode contingency plans; also, in completing the
installation of the air quality surveillance network. Regional
Office will continue to assist the State in the review of
variance applications.
A major source of particulate emissions in the State is
slash burning. The State has requested assistance on the
problem from EPA. The U.S. Forest Service will also provide
expertise in this area. Headquarters and Regional Office
representatives have met with State officials and a plan for
attacking the problem will be formulated. A joint task force
consisting of the EPA, the U.S. Forest Service, and various State
agencies will be formulated within the next six months to study
the entire agricultural burning situation. Slash burning must
be emphasized because of the magnitude of its impact upon air
quality in the Western States. The joint task force position
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paper will be issued in order for the States to impose the
recommended controls by June 30, 1973.
Potential problems in terms of particulate emissions could
accompany the anticipated power plant development in Southeast
Montana. The Regional Office and the State agency are following
developments in this area.
In view of the limited capabilities of the State source
monitoring programs and inadequate Regional Office resources,
the monitoring activities during FY 73 and FY 74 can only be
accomplished by an EPA contract effort.
Monitoring of approved compliance schedules will be a
joint State-Regional Office activity. Individually negotiated
compliance schedules or variances will be reviewed by the
Regional Office as well as the State.
State of Utah
The SIP does not provide for the attainment of primary
standards for sulfur oxides, particulate matter and nitrogen
oxides. By July 1, 1972, EPA will propose regulations to insure
attainment of these standards. Headquarters is actively involved
in diffusion modeling to provide the basis for the Garfield
smelter sulfur oxides control regulation and the Huntington Canyon
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power plant sulfur oxides control regulation. Process weight,
fuel combustion, incinerator, and coke oven particulate control
regulations have been developed. A nitrogen oxides control
regulation from steam generating plants has been developed. If
the State does not provide the required revisions by July 31,
1972, the EPA will be required to promulgate its own regulations
in areas not covered by State revisions.
Since the State agency may have problems in releasing
emission data, the Regional Office will have to follow this
closely to see that the general public has access to this data.
If the State agency doesn't make the information available, EPA
will be required to do so.
The Headquarters - Regional Office will be providing the
State assistance in developing a transportation control plan
to reduce emissions of CO and N0X to meet NAAQS in Salt Lake City
area. Recommendations on transportation and land use controls
will be presented to the State legislators by January 1, 1973.
A plan to show how the CO and N0X standards will be achieved
by 1977 will be submitted by the State by February 15, 1973. It
is expected that the enabling authority to adopt land use and
transportation control regulations will be granted by the
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legislature by July 30, 1973. The proposed State Plan must then
be implemented through adopted regulations by December 30, 1973.
If at any point in this transportation control development the
State fails, the EPA must step in. Although the State Department
of Transportation has not been actively involved to date, it
is expected to provide assistance to the State agency during
the coming year.
A review of the newly submitted emergency episode control
plans will be completed in March 1973 by the Regional Office
with the assistance from Headquarters-EOCC. If the State Plans
are inadequate, the EPA must take the required action. Portions
of the existing compliance schedules are inadequate and new
compliance schedules will be developed either through State
revisions or promulgation as part of the S0X, NO2 and particulate
matter regulations. This will require substantial effort by
the Regional Office. Legal assistance will be provided by
HQ-OEGC.
The State does not have adequate procedures to review the
impact of new sources. Consequently, unless revisions are made,
the Regional Office and Headquarters will be required to utilize
diffusion modeling to predict the potential effect on the
environment. State agency has allotted insufficient manpower
for engineering and enforcement activities.
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Ambient air monitoring procedures must be evaluated by
the Regional Office since the State uses methods different from
those recommended by EPA. If the State does not demonstrate
equivalency or change to the recommended methods by July 1974,
the Regional Office will have to provide a substantial manpower
and funding effort. The Regional Office will provide assistance
to the State to develop adequate procedures.
The Four Corners power plant complex (as planned) may cause
problems in terms of particulate matter, sulfur oxides and
nitrogen oxides. The State agency and RO - HQ will study the
possible consequences of the proposed complex further. RO - HQ
will also assist the State agency in evaluating the potential
particulate emissions from the proposed oil shale development
tracts in the Uinta Basin.
State of Colorado
The Regional Office will review the additional portions of
the SIP emergency episode plan to be submitted on February 15, 1973,
for adequacy. If deemed inadequate, the EPA must promulgate
adequate plans. A transportation control plan for the Denver
AQCR must be submitted by February 15, 1973. The Regional Office
will provide assistance in the development of this plan. It is
expected that the enabling authority to adopt land use and
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transportation control regulations will be granted by the
legislature by July 30, 1973. The proposed State plan must be
implemented through adopted regulations by December 30, 1973. If
at any point in this transportation control development, the State
fails, the EPA must step in.
The State received a two-year extension in achieving the
primary standards for 0X, HC and CO. The Regional Office will
be working closely with the Stat6 agency and will provide
assistance as needed to achieve the standards. An 18-month
extension was granted the State to achieve the secondary standard
for suspended particulates. Although the major point sources
will be controlled, it is possible that problems may still
exist due to the area source problem. The State agency and the
Regional Office will continue to study this problem.
In summary, program element 245137 covers the Regional Office
work required to complete the SIP development and approval in
the States of Colorado, Montana and Utah.
Sub-element 3A1121 (Stationary Forces Enforcement) covers
the work related to approving compliance schedules. Regional
Office will assist the states in developing acceptable compliance
schedules and will have formal conferences with each State agency.
Topics such as: (1) adequacy of legal authority of State agency
to grant variance or develop compliance schedule; (2) adequacy of
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legal authority to enforce content of the schedules;and
(3) the format and content of the compliance agency will be
discussed at the conferences. With the exception of Utah,
little difficulty is foreseen. For Utah, it may be necessary
for the Regional Office to supply considerable manpower and
funds to insure that an approvable compliance schedule is
forthcoming.
A minor amount of resources will be required from 2A4136
(Air Control Agency Grants) for State assignees who spend part
of their time in work related to objectives of the Accomplishment
Plan. Montana, Colorado and Utah have 3, 2 and 2 State assignees,
respectively. No effort has been made to estimate the portion
of the time State assignees spend on work described in the
Accomplishment Plan.
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PLANNED ACCOMPLISHMENTS SCHEDULE
1. TYPE OF FLAN
H O. SUB-ELEMENT
[ | b. PART SU0*£L EM EN*
'"Xl C. GEOGRAPHICAL AREA
2. PROGRAM S'JB-ELEMENT TITLE
TECHNICAL SUPPORT & EVALUATION
3. SUB-ELEVENT NO.
2A5137
4. SHEET NO.
1 of 2
5. GEOGRAPHICAL AREA TITLE
Region VIII
6. GEOGRAPHICAL AREA CODE
7. PRIORITY
8. I 9.
CODE 1 NO.
10. SCHEDULE
~ ATE OF
COMPLETION
11.
F_ANNED ACCOMPLISHMENTS
i
l

State of Colorado





l
2/15/73
Recommendation on approval for emergency episode control plans for



priority I regions

2
3/15/73
Recommendation on approval for transportation control plan for Denver to



obtain CO and Hp_ standards

3
11/30/73
Recommendation oh approval for SIP for secondary particulate standard

A
1/30/74
Recommendation on approval for transportation control regulations for Denver

5

Promulgate (if required) part or all of secondary NAAQS SIP



1



j
State of Montana



|

6
7/31/72
1
Promulgate (if required) portions of primary NAAOS SIP

7
2/15/73
Recommendation on approval for emergency episode control plans for !



priority I regions
1 2. FY 1973
13. FY 1974
14. PREPARED l)Y AND DATE
Norman A. Huey - 6-2-72
15. REVIEW BY AND DATE
a, $1000
b. MAN-Y EARS
0. $1000
b. M AN- Y EARS




16. APPROVED TOR RPIO
EPA Form 3500-4 (Rev. 4*72)
PLANNED ACCOMPLISHMENTS SCHEDULE

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PLANNED ACCOMPLISHMENTS SCHEDULE
1. TYPE OF PLAN
PI!] SUB* E L EM EN T
¦ 1 b. PART SUB-ELEMENT
I^C, GEOGRAPHICAL area
2. PROGRAM SUB-ELEMENT TtTLE
TECHNICAL SUPPORT & EVALUATION
3. SUB-ELEMENT NO.
2A5137
4. SHEET NO.
2 of 2
5. GEOGRAPHICAL AREA TITLE
Region VIII
6. GEOGRAPHICAL AREA CODE
7. PRIORITY
CODE
9,
NO.
*0, SCHEDULE
DATE OF
COMPLETION
11.
PLANNED ACCOMPLISHMENTS

i
I

State of Utah j
j


1
! 8
1
7/31/72
Promulgate (if required) portions of primary NAAQS SIP
I-
:.9
2/15/73
Recommendation on approval for emergency episode control plans

j

I
for priority I regions ]

10
3/15/73
Recommendation on approval for transportation control plan for



; i
Salt Lake City to obtain CO standards j

11
12/30/73 -
Recommendation on approval for transportation control regulations



for Salt Lake City







I



I












12. FY 1973
1 3. FY 1974
14. PREPARED OY AND DATE
Norman A. Huey - 6-2-72
IS. REVIEW BY AND DATE
O. $ 1000
b. M AN-Y E A RS
0. $ 1000
b. M AN- Y EARS




16. APPROVED F OR RPIO
EPA Form 3500-4 (Rev. 4-72)	PLANNED ACCOMPLISHMENTS SCHEDULE

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1. TYPE OF PLAN
' 1 O. SUB-ELEMENT
1 b. P49* sub-element
¦' ¦ e. geographical area
2. PROGRAM SJS-EIEWENT TITLE
Completion of SIP Approvals and Compliance Schedules
3. S'J 3-ELEMENT NO.
2A4136
4. SHEET NO.
5. GEOGRAPHICAL AREA TITLE
6. GEOGRAPHICAL AREA CODE
7. PRIORITY
b. jS.
CODE | NO.
|
10. SCHEDULE
date of
COMPLETION
1
F' L ANN ED ACCOMPLISHMENTS
1
1
i
1

State of Colorado

!
1
Ongoing
2 State Assignees working with State agency







State of Montana

2
Ongoing
3 State Assignees working with State agency-







State of Utah

3
Ongoing
2 State Assignees working with State agency




























12. FY 1973
13. FY 1974
14. PREPARED BY AND DATE
Norman A. Huey - 6-2-72
IS. REVIEW BY AND DATE
O. $1000
b. MAM-Y CARS
O. $ 1000
b. MAN. YEARS


-

16. APPROVED I'OH RPIO
EPA Form 3'00-4 (Rev. 4-72)
PLANNED ACCOMPLISHMENTS SCHEDULE

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PLANNED ACCOMPLISHMENTS SCHEDULE
1. Type of Plan
a -iJ Sub-Elesent
b.f J Part. Sub-Elen
-	f-.l Ifieo. Area	
_	Completion of SIP Approvals
2. Program Sub-Elenent Title and Compliance Schedi.W
5. Geographical Area Title
3. Sub-Elenent No.
3A1121 -
6. Geo. Area Code
4.Sheet Mo.
7.Priority
.Code
9. No.
OS


\
105chedDate
of Cojp.
UL_
PLANNED ACCOMPLI SHUNTS
States of Colorado. Montana and TTt-ah
7/31/72
Receive existing compliance schedules
8/31/72
Formal Conference with State agencies to discuss form and content of complianr.p.
schedules

2/15/73
Approve/disapprove the submitted existing compliance schedules
Compliance schedules received bv RO
4/15/73
-Compliance schedules approved/disapproved

Continuouii Assist state agencies in making necessary changes in compl lanrp. schedule
-I
J
r\
\
12.
FY 1973
13,
FY 1974
b.
a.
b.
14. Prepared by & Date
Norman A. Huey-6-2-72
15. Reviewed bv & Date
16.Approved forRPlO.

Planned Accomplishments

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